EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR PESTICIDE 

PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: Shaja Joyner (703)308-3194 

Company Name: Taminco US Inc. 

OPP Petition No.: 

EPA has received a pesticide petition from Taminco US Inc., Two Windsor 

Plaza, Suite 411, Allentown, PA 18195 pursuant to section 408(d) of the Federal Food, 

Drug and Cosmetic Act (FFDCA) 21 U.S.C. 346a(d), to amend 40 CFR part 180. 

By establishing a permanent import tolerance for residues of thiram in or on the raw 

agricultural commodity banana at 0.8 parts per million (ppm), EPA has determined that the 

petition contains data or information regarding the elements set forth in section 408 (d)(2) of 

FDDCA; however, EPA has not fully evaluated the sufficiency ofthe submitted data at this time 

whether the data supports granting of the petition. Additional data may be needed before EPA 

rules on the petition. 

A. Residue Chemistry 

1. Plant metabolism. The metabolism and chemical nature of residues of thiram in plants 

has been extensively evaluated and is adequately understood. 

2. Analytical method. Banana samples were analyzed according to Analytical Method# 

Meth-100, Revision #4, "Determination of Thiram in Raw Agricultural Commodities, 

Processed Commodities and Other Plant Material." Detection and quantitation for 

thiram (as CS2) were conducted using gas chromatography (GC) employing sulfurspecific flame photometric detection (FPD). The limit of quantitation (LOQ) was 0.05 

ppm. 

3. Magnitude of residues. Banana residue trials were conducted in 5 countries that 

represent the major banana growing countries that export bananas to the TJnited States. 

Formulations containing either 42% thiram or 60% thiram were applied at c rate of 1.1? 

pounds thiram per acre. Application began when the fruit had completPly emerged from 

the ftower, were trimmed and bagged. The applications continued on a fi•. ,e to eighc day 

basis until immediately prior to harvest maturity for a total of 10 applications. The LCt1 

for the analytical method ranged from 0.05 ppm to 0.079 ppm. A time-li:nited import 

tolerance for thiram in or on bananas of 0.8 ppm was established in 2009.. 
B. Toxicology Profile 

l. Acute toxicity. The acute oral LD50 was 2600 mg/kg (Toxicity Category III). The acute 

dermal LD50 was greater than 2000 mg/kg (Toxicity Category III). The acute inhalation 

LC50 for was >_ 3.46 mg/L (Toxicity Category III). Thiram is a moderate eye irritant, a 

very slight dermal irritant and a moderate skin sensitizer. 

In an acute neurotoxicity study, Sprague-Dawley rats were orally gavaged at 0, 5, 150, 

and 600 mg/kg, and were subsequently evaluated in functional observational batteries 

(FOB) and motor function observations. Neuropathological evaluations were performed. 

The Lowest Observed Adverse Effect Level (LOAEL) was 150 mg/kg based on FOB 

effects (lethargy, lower temperature, reduced startle response, no tail pinch response), 

reduced motor activity, and reduced brain weights. The No Observable Adverse Effect 

Level (NOAEL) for neurotoxicity was 5 mg/kg. 

2. Genotoxicity. 

Genotoxicity evaluations of thiram were negative in a mammalian cell gene mutation 

assay with Chinese Hamster V9 cells, a chromosomal aberrations assay in Chinese 

hamster ovary cells, an DNA repair study in cultured rat hepatocytes and an in vivo 

micronucleus study in mice. 

3. Reproductive and Developmental Toxicity 

In a developmental toxicity study in rats, a maternal NOAEL was not achieved. The 

maternal LOAEL was 7.5 mg/kg/day based on reduced body weight gains and clinical 

signs of toxicity. The developmental NOAEL was 7.5 mg/kg/day. 

Pregnant female rabbits were dosed with thiram via gavage on gestation days 7 to 19. 

The NOEL for maternal and developmental toxicity was 10 mg/kg/day, the highest tested 

dose. 

Two multigeneration studies with thiram were conducted in rats. In both studies, the 

rates were exposed over two generations. In the first study, the parental NOEL was 25 

ppm, the reproductive NOEL was 50 ppm and the fetal NOEL was 50 ppm. The results 

from the second study showed a parental NOEL was 20 ppm, the reproductive NOEL 

was > 180 ppm and the fetal NOEL was 20 ppm. 

A developmental neurotoxicity study was conducted in which female rat;, r ,~ ;P;ved d;Pis 

containing 0, 20, 45 or 90 ppm thiram from gestation day 3 through post ,iatal c:ay 20. 

The maternal systemic and neurotoxicity LOAEL was 90 ppm based on d%;rP.-sed b>dy 

weight, body weight gain and food consumption, clinical signs of toxicity und FB 

findings. The maternal NOAEL was 45 ppm. The offspring systemic arc' ~eurotox:city 

LOAEL was 45 ppm based on increased locomotor activity in females on T`ND 17. The 

offspring NOAEL was 20 ppm. 

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4. Subchronic Toxicity 

Thiram was administered via the diet to rats for 13 weeks. The LOEL was 250 ppm 

based on effects on body weight, body weight gain, food consumption, hematologic and 

clinical chemistry parameters, organ weights and liver histopathologic findings. The 

NOEL was 50 ppm. 

In a subchronic neurotoxicity study, rats were exposed to thiram technical (98.76% a.i.) 

in their diet at doses of 0, 30, 125, or 500 ppm. The neurotoxicity LOAEL is 125 ppm, 

based on increased numbers of rearing events and elevated incidences of hyperactivity in 

females at weeks 8 and 13. The NOAEL was 30 ppm for females and 125 ppm for 

males. 

5. Chronic Toxicity 

In a combined chronic/oncogenicity study, Thiram technical was administered to albino 

rats in the diet for 104 weeks. The LOAEL was 119 ppm based on a reduction in body 

weight gain, changes in hematology and clinical chemistry parameters, and an increased 

incidence of bile duct hyperplasia. The NOAEL was 16.3 ppm. 

Thiram was administered to male and female beagle dogs via the diet for 52 weeks. The 

LOAEL was 90 ppm (2.6 mg/kg/day) based on elevated cholesterol levels and increases 

in liver-to-body weight ratio. The NOAEL was 30 ppm (0.84 mg/kg/day). 

6. Animal Metabolism 

Thiram is readily absorbed (via the oral route), distributed, extensively metabolized and 

eliminated primarily in the expired air and urine of rats within 24 hours following single 

or repeated oral administrations. No sex differences in metabolism were noted and very 

low levels were found in tissues (1.5-4.2%). 

7. Metabolite Toxicity 

No metabolites oftoxicologic concern have been noted. 

8. Endocrine Disruption 

No indication of potential endocrine effects have been seen in any of the toxicological 

studies including reproductive and developmental toxicity studies conducted with thiram. 

C. Aggregate Exposure 

1. Dietary exposure 

i. Food 

Dietary exposure is expected from this petition as residues of thiram are fo-and in wl:ole 

bananas. 

ii. Drinking water 

No additional water exposure is expected. 

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1. Non-dietary exposure 

N/A-Remove 

D. Cumulative Effects 

The USEPA is developing methodologies for assessing cumulative risks for chemicals 

having common mechanisms of toxicity. No available data indicate that the toxic effects 

produced by thiram would be cumulative with those of any other chemical compounds. 

E. Safety Determination 

l. U.S. Population 

The acute dietary exposure for the General U.S. Population was 1.9% of the aPAD. 

Total acute exposure for females 13-49 years, the population group with the highest acute 

dietary exposure, was estimated to be 0.008637 mg/kg/day, equivalent to 62% of the 

aPAD. 

Chronic dietary exposure for the General U.S. Population was 15% of the cPAD. 

2. Infants and Children 

Chronic dietary exposure for Children 1-2 years old was 0.011943 mg/kg bw (80% of the 

cPAD). 

F. International Tolerances 

Codex MRLS have been established for the Dithiocarbamates as the sum of residues of 

zineb, ziram, thiram, nickel bis(dimethyl dithiocarbamate), ferbam, propineb, 

polycarbamate, mancozeb, maneb and metiram which are calculated as carbon disulfide. 

Applicable MRLs (Codex, February 2006) for thiram are apples (5 ppm), bananas (2 

ppm), stone fruits (7 ppm) and strawberries (5 ppm).