United States Prevention, Pesticides EPA 738-R-06-017 

Environmental Protection and Toxic Substances April 2006 

Agency (7508C) 

Reregistration

Eligibility Decision 

(RED) for Permethrin 
______________________ 

________________________ 

REREGISTRATION ELIGIBILITY 

DECISION 

for 

Permethrin

Case No. 2510 

Approved by: 

Debra Edwards, Ph.D. 

Director, Special Review and 

Reregistration Division 

Date 

ii 
TABLE OF CONTENTS 

Permethrin Reregistration Eligibility Decision Team ................................................................... v 

Glossary of Terms and Abbreviations .......................................................................................... vi 

Abstract.......................................................................................................................................viii 

I. Introduction........................................................................................................................... 1 

II. Chemical Overview........................................................................................................... 2 

A. Regulatory History............................................................................................................ 2 

B. Chemical Identification - Permethrin ............................................................................. 3 

C. Use Profile.......................................................................................................................... 4 

D. Estimated Usage of Permethrin....................................................................................... 5 

III. Summary of Permethrin Risk Assessments....................................................................... 7 

A. Human Health Risk Assessment ........................................................................................ 8 

1. Toxicity of Permethrin ................................................................................................... 8 

a. Acute Toxicity Profile................................................................................................. 9 

b. FQPA Safety Factor Considerations.......................................................................... 9 

c. Toxicological Endpoints ........................................................................................... 10 

2. Carcinogenicity of Permethrin..................................................................................... 11 

3. Metabolites and Degradates....................................................................................... 12 

4. Permethrin Endocrine Effects ................................................................................... 12 

5. Dietary Risk from Food and Drinking Water ............................................................. 12 

a. Dietary (Food and Drinking Water) Exposure Assumptions ............................. 12 

b. Population Adjusted Dose ...................................................................................... 13 

c. Acute and Chronic Dietary (Food and Drinking Water) Risk ........................... 14 

d. Cancer Dietary (Food and Drinking Water) Risk ............................................... 14 

6. Residential Exposure and Risk.................................................................................. 15 

a. Residential Handler Risks...................................................................................... 16 

b. Residential Post-Application Risks .......................................................................... 18 

7. Aggregate Risk ............................................................................................................ 22 

a. Acute Aggregate Risk ............................................................................................. 24 

b. Short-Term Aggregate Risk................................................................................... 24 

c. Intermediate-Term & Long-Term Aggregate Risk............................................. 26 

d. Cancer Risk ............................................................................................................. 26 

e. Permethrin Pesticide and Pharmaceutical Use Co-Exposure Assessment ........ 27 

8. Occupational Exposure and Risk .............................................................................. 28 

a. Occupational Handler Exposure and Risk........................................................... 29 

b. Occupational Post-Application Exposure and Risk ............................................ 35 

c. Incident Reports..................................................................................................... 39 

B. Environmental Fate and Effects Risk Assessment....................................................... 40 

1. Environmental Fate and Transport............................................................................. 40 

2. Ecological Exposure and Risk...................................................................................... 41 

a. Terrestrial Organisms.............................................................................................. 42 

b. Aquatic Organisms................................................................................................... 45 

c. Endangered Species.................................................................................................. 54 

3. Ecological Incidents...................................................................................................... 56 

IV. Risk Management, Reregistration, and Tolerance Reassessment................................... 56 

A. Determination of Reregistration Eligibility ..................................................................... 56 

iii 
B. Public Comments and Responses .................................................................................. 57 

C. Regulatory Position .......................................................................................................... 57 

1. Food Quality Protection Act Findings ......................................................................... 57 

a. “Risk Cup” Determination....................................................................................... 57 

b. Determination of Safety to U.S. Population.......................................................... 57 

c. Determination of Safety to Infants and Children ................................................ 58 

2. Endocrine Disruptor Effects ...................................................................................... 58 

3. Cumulative Risks ........................................................................................................ 59 

4. Endangered Species .................................................................................................... 59 

D. Tolerance Reassessment Summary ............................................................................... 60 

E. Regulatory Rationale ...................................................................................................... 66 

1. Human Health Risk Management............................................................................. 66 

a. Dietary (Food and Drinking Water) Risk Mitigation.......................................... 67 

b. Residential Risk Mitigation................................................................................ 67 

c. Aggregate Risk Mitigation ..................................................................................... 73 

d. Occupational Risk Mitigation................................................................................ 74 

2. Non-Target Organism (Ecological) Risk Management ........................................... 81 

a. Terrestrial Organisms ............................................................................................ 81 

b. Aquatic Organisms ................................................................................................. 81 

4. Significance of Permethrin to Users...................................................................... 88 

5. Risk/Benefit Balancing Analysis................................................................................ 90 

6. Summary of Mitigation Measures............................................................................. 91 

7. Performance Measures............................................................................................... 93 

F. Other Labeling Requirements ....................................................................................... 95 

1. Endangered Species Considerations ......................................................................... 95 

2. Spray Drift Management ........................................................................................... 95 

Appendix A-1............................................................................................................................. A-1 

Appendix A-2........................................................................................................................... A-12

Appendix B ................................................................................................................................ B-1

Appendix C................................................................................................................................ C-1

Appendix D................................................................................................................................ D-1

iv 
Permethrin Reregistration Eligibility Decision Team 

Office of Pesticide Programs 

Biological and Economic Analysis Assessment 

David Brassard 

Tim Kiely 

TJ Wyatt 

Environmental Fate and Effects Risk Assessment 

José Melendez 

Mike Rexrode 

Health Effects Risk Assessment 

Samuel Ary 

Sherrie Kinard 

Bill Smith 

Yung Yang 

Registration Support

 George LaRocca 

 Kevin Sweeney 

Risk Management 

Neil Anderson 

Jacqueline Guerry 

General Counsel

 Angela Huskey 

v 
Glossary of Terms and Abbreviations 

ai Active Ingredient 

aPAD Acute Population Adjusted Dose 

APHIS Animal and Plant Health Inspection Service 

ARTF Agricultural Re-entry Task Force 

BCF Bioconcentration Factor 

CDC Centers for Disease Control 

CDPR California Department of Pesticide Regulation 

CFR Code of Federal Regulations 

ChEI Cholinesterase Inhibition 

CMBS Carbamate Market Basket Survey 

cPAD Chronic Population Adjusted Dose 

CSFII USDA Continuing Surveys for Food Intake by Individuals 

CWS Community Water System 

DCI Data Call-In 

DEEM Dietary Exposure Evaluation Model 

DL Double layer clothing {i.e., coveralls over SL} 

EC Emulsifiable Concentrate Formulation 

EDSP Endocrine Disruptor Screening Program 

EDSTAC Endocrine Disruptor Screening and Testing Advisory Committee 

EEC Estimated Environmental Concentration. The estimated pesticide concentration in an environment, 

such as a terrestrial ecosystem. 

EP End-Use Product 

EPA U.S. Environmental Protection Agency 

EXAMS Tier II Surface Water Computer Model 

FDA Food and Drug Administration 

FFDCA Federal Food, Drug, and Cosmetic Act 

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act 

FOB Functional Observation Battery 

FQPA Food Quality Protection Act 

FR Federal Register 

GL With gloves 

IDFS Incident Data System 

IPM Integrated Pest Management 

RED Reregistration Eligibility Decision 

LADD Lifetime Average Daily Dose 

LC50 Median Lethal Concentration. Statistically derived concentration of a substance expected to cause 

death in 50% of test animals, usually expressed as the weight of substance per weight or volume of 

water, air or feed, e.g., mg/l, mg/kg or ppm. 

LCO Lawn Care Operator 

LD50 Median Lethal Dose. Statistically derived single dose causing death in 50% of the test animals 

when administered by the route indicated (oral, dermal, inhalation), expressed as a weight of 

substance per unit weight of animal, e.g., mg/kg. 

LOAEC Lowest Observed Adverse Effect Concentration 

LOAEL Lowest Observed Adverse Effect Level 

LOC Level of Concern 

LOEC Lowest Observed Effect Concentration 

mg/kg/day Milligram Per Kilogram Per Day 

MOE Margin of Exposure 

MP Manufacturing-Use Product 

MRID Master Record Identification (number). EPA's system of recording and tracking studies submitted. 

MRL Maximum Residue Level 

N/A Not Applicable 

NASS National Agricultural Statistical Service 

NAWQA USGS National Water Quality Assessment 

vi 
NG No Gloves 

NMFS National Marine Fisheries Service 

NOAEC No Observed Adverse Effect Concentration 

NOAEL No Observed Adverse Effect Level 

NPIC National Pesticide Information Center 

NR No respirator 

OP Organophosphorus 

OPP EPA Office of Pesticide Programs 

ORETF Outdoor Residential Exposure Task Force 

PAD Population Adjusted Dose 

PCA Percent Crop Area 

PDCI Product Specific Data Call-In 

PDP USDA Pesticide Data Program 

PF10 Protections factor 10 respirator 

PF5 Protection factor 5 respirator 

PHED Pesticide Handler's Exposure Data 

PHI Preharvest Interval 

ppb Parts Per Billion 

PPE Personal Protective Equipment 

PRZM Pesticide Root Zone Model 

RBC Red Blood Cell 

RED Reregistration Eligibility Decision 

REI Restricted Entry Interval 

RfD Reference Dose 

RPA Reasonable and Prudent Alternatives 

RQ Risk Quotient 

RTU (Ready-to-use) 

RUP Restricted Use Pesticide 

SCI-GROW Tier I Ground Water Computer Model 

SF Safety Factor 

SL Single layer clothing 

SLN Special Local Need (Registrations Under Section 24(c) of FIFRA) 

TEP Typical End-Use Product 

TGAI Technical Grade Active Ingredient 

TTRS Transferable Turf Residues 

UF Uncertainty Factor 

USDA United States Department of Agriculture 

USFWS United States Fish and Wildlife Service 

USGS United States Geological Survey 

WPS Worker Protection Standard 

vii 
Abstract 

The Environmental Protection Agency (EPA or the Agency) has completed the human 

health and environmental risk assessments for permethrin and is issuing its risk management 

decision and tolerance reassessment. The risk assessments, which are summarized below, are 

based on the review of the required target database supporting the use patterns of currently 

registered products and additional information received through the public docket. After 

considering the risks identified in the revised risk assessments, comments received, and 

mitigation suggestions from interested parties, the Agency developed its risk management 

decision for uses of permethrin that pose risks of concern. As a result of this review, EPA has 

determined that permethrin-containing products are eligible for reregistration, provided that risk 

mitigation measures are adopted and labels are amended accordingly. That decision is discussed 

fully in this document. 

Permethrin is part of the pyrethroid class of pesticides and was first registered in 1979. It 

is a broad spectrum, non-systemic, synthetic pyrethroid insecticide, and is registered for use on 

numerous food/feed crops, livestock and livestock housing, modes of transportation, structures, 

buildings, Public Health Mosquito abatement programs, numerous indoor and outdoor residential 

spaces, pets, and clothing. Initial risk assessments indicated some occupational and residential 

handler and post-application risks of concern. Risk estimates were revised based on refinements 

to the assessments and in some cases agreed to mitigation measures, and the Agency will be 

requiring additional data for some exposure scenarios. Occupational risks have been mitigated 

through personal protective equipment or engineering controls requirements on the labels; 

residential risks to homeowners have been mitigated by discontinuing or restricting certain 

application methods and reducing some application rates; and ecological risks have been 

addressed through adding buffer zone requirements and product stewardship statements to the 

labels, and amending use patterns for many uses. 

viii 
I. Introduction 

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was amended in 1988 

to accelerate the reregistration of products with active ingredients registered prior to November 

1, 1984. The amended Act calls for the development and submission of data to support the 

reregistration of an active ingredient, as well as a review of all submitted data by the U.S. 

Environmental Protection Agency (referred to as EPA or “the Agency”). Reregistration involves 

a thorough review of the scientific database underlying a pesticide’s registration. The purpose of 

the Agency’s review is to reassess the potential hazards arising from the currently registered uses 

of the pesticide; to determine the need for additional data on health and environmental effects; 

and to determine whether or not the pesticide meets the “no unreasonable adverse effects” 

criteria of FIFRA. 

On August 3, 1996, the Food Quality Protection Act (FQPA) was signed into law. This 

Act amends FIFRA and the Federal Food, Drug, and Cosmetic Act (FFDCA) to require 

reassessment of all existing tolerances for pesticides in food. FQPA also requires EPA to review 

all tolerances in effect on August 2, 1996, by August 3, 2006. In reassessing these tolerances, 

the Agency must consider, among other things, aggregate risks from non-occupational sources of 

pesticide exposure, whether there is increased susceptibility of infants and children, and the 

cumulative effects of pesticides with a common mechanism of toxicity. When a safety finding 

has been made that aggregate risks are below the Agency’s LOC and the Agency concludes that 

there is a reasonable certainty of no harm from aggregate exposure, the tolerances are considered 

reassessed. EPA decided that, for those chemicals that have tolerances and are undergoing 

reregistration, tolerance reassessment will be accomplished through the reregistration process. 

As mentioned above, FQPA requires EPA to consider available information concerning the 

cumulative effects of a particular pesticide’s residues and “other substances that have a common 

mechanism of toxicity.” Potential cumulative effects of chemicals with a common mechanism of 

toxicity are considered because low-level exposures to multiple chemicals causing a common 

toxic effect by a common mechanism could lead to the same adverse health effect as would a 

higher level of exposure to any one of these individual chemicals. Permethrin is a member of the 

pyrethroid class of pesticides. Although all pyrethroids alter nerve function by modifying the 

normal biochemistry and physiology of nerve membrane sodium channels, EPA is not currently 

following a cumulative risk approach based on a common mechanism of toxicity for the 

pyrethroids. Although all pyrethroids interact with sodium channels, there are multiple types of 

sodium channels and it is currently unknown whether they the pyrethroids have similar effects on 

all channels. Nor do we have a clear understanding of effects on key downstream neuronal 

function e.g., nerve excitability, nor do we understand how these key events interact to produce 

their compound specific patterns of neurotoxicity. There is ongoing research by the EPA’s 

Office of Research and Development and pyrethroid registrants to evaluate the differential 

biochemical and physiological actions of pyrethroids in mammals. This research is expected to 

be completed by 2007. When available, the Agency will consider this research and make a 

determination of common mechanism as a basis for assessing cumulative risk. For information 

regarding EPA’s procedures for cumulating effects from substances found to have a common 

mechanism on EPA’s website at http://www.epa.gov/pesticides/cumulative/.For additional 

information regarding EPA’s efforts to determine which chemicals have a common mechanism 

of toxicity and to evaluate the cumulative effects of such chemicals, see the policy statements 

released by EPA’s Office of Pesticide Programs concerning common mechanism determinations 

1
and procedures for cumulating effects from substances found to have a common mechanism on 

EPA’s website at http://www.epa.gov/pesticides/cumulative/. 

This document presents EPA’s revised human health and ecological risk assessments, its 

progress toward tolerance reassessment, and the reregistration eligibility decision for permethrin. 

The document consists of six sections. Section I contains the regulatory framework for 

reregistration/tolerance reassessment; Section II provides an overview of the chemical and a 

profile of it’s use and usage; Section III gives an overview of the human health and 

environmental effects risk assessments; Section IV presents the Agency's decision on 

reregistration eligibility and risk management; and Section V summarizes the label changes 

necessary to implement the risk mitigation measures outlined in Section IV. Finally, the 

Appendices list related information, supporting documents, and studies evaluated for the 

reregistration decision. The revised risk assessments for permethrin and all other supporting 

documents are available in the Office of Pesticide Programs (OPP) public docket 

(http://www.regulations.gov.) under docket number EPA-HQ-OPP-2004-0385 and are available 

on the Agency’s web page at http://www.epa.gov/oppsrrd1/reregistration/permethrin/. 

II. Chemical Overview

 A. Regulatory History 

Permethrin was first registered and tolerances established in the United States in 1979 for 

use on cotton (April 29, 1979 44FR 24287). The registration was made conditional due to the 

need for additional toxicology data to fully evaluate carcinogenicity and the need for additional 

ecological effects data to fully evaluate aquatic risk. Laboratory studies indicated that 

permethrin was highly toxic to fish and aquatic invertebrates and the use on cotton was classified 

as Restricted Use pesticide (RUP). In making its decision to conditionally register the product, 

EPA considered the beneficial role of this compound in cotton pest management, the reduction 

of use of other cotton insecticides with known carcinogenic potentials, and the absence of 

suitable and sufficient supplies of alternatives for control of resistant insect strains. 

From 1979 to 1982, there was considerable scientific debate over the interpretation of the 

carcinogenicity database, which considerably delayed the establishment of new crop tolerances 

and non-food registrations. After additional toxicity data were reviewed, EPA concluded that 

permethrin was a weak carcinogen. From 1982 to 1989, 55 + crop tolerances were approved for 

a wide variety of crops, including vegetables (i.e., broccoli, celery, lettuce, potatoes, etc.), alfalfa, 

pears, meat, milk and eggs. During this time, EPA regulated new crop uses on the basis of 

average daily intake (ADI) and not by quantitative cancer risk assessment. 

In 1985 a Data Call-In (DCI) for ecological effects data for permethrin was issued, which 

include a full complement of ecological effects data. The additional data required were estuarine 

mollusc acute tests, estuarine invertebrate life cycle and fish life cycle tests. After evaluation of 

this data EPA concluded that the current RUP classification be maintained for all products for 

wide area agricultural uses (except livestock and premises uses) and outdoor wide area non-crop 

uses because of the possible adverse effects on aquatic organisms from spray drift and runoff. 

 In 1988 a comprehensive DCI was issued requiring additional residue chemistry, 

2
environmental fate and toxicological data. This DCI was issued so that data required by 40 CFR 

Part 158 would be available to EPA for reregistration. 

 In 1990 EPA issued conditional registrations with product expiration dates for various 

synthetic pyrethroids prescribed specifically for use on cotton. The reason for time-limited 

tolerances/registrations was aquatic toxicity concerns. EPA required interim risk mitigation 

measures, i.e. buffer zones around water, an education program to inform growers on reducing 

off target spray deposition and additional data requirements. Since permethrin was registered for 

use on cotton, it was subject to this conditions and product expiration dates. However in 1994 

the producers of products containing permethrin for use on cotton requested voluntary 

cancellation of this use and were no longer subject to the conditions of registration. 

From 1994 thru 2000 permethrin was subject to specific DCIs requesting data to assess 

agricultural and residential exposure, agricultural re-entry, and mosquito ULV products. In 2000 

the Agency notified the producers of concentrated (40 – 65%) permethrin “Spot-On” products 

for use on dogs of concerns about the potential misuse, of these products on cats. The Agency 

was made aware of instances of consumers using these dog products accidentally on their pet 

cats and/or not being aware of the danger of allowing cats to interact with newly treated dogs. 

The producers of these products voluntarily agreed to make a number of label changes to reduce 

this potential misuse such as adding in large bold type “Do Not Use On Cats” and the icon of a 

cat in a circle with a slash through it and a statement indicating the cats which actively groom or 

engage in physical contact with treated dogs may be at risk of harmful effect. 

B. Chemical Identification - Permethrin 

Permethrin [(3-phenoxyphenyl)methyl 3-(2,2-dichloroethenyl)-2,2-dimethylcyclopropane 

carboxylate] is a synthetic pyrethroid insecticide. Permethrin is a racemic mixture of the cis and 

trans isomers. Permethrin is a colorless crystal to a pale yellow viscous liquid with a melting 

point of 35ΕC and a boiling point of 220ΕC (0.05 mm Hg). Permethrin is soluble in water at less 

than 1 ppm, and is miscible in most organic solvents except ethylene glycol. Permethrin is 

soluble in acetone, ethanol, ether, and xylene. 

Chemical Structure: 

Common Name: Permethrin 

Chemical Name: (3-phenoxyphenyl)methyl 3-(2,2-dichloroethenyl)-2,2­

dimethylcyclopropane carboxylate 

Chemical Family: Synthetic Pyrethroids 

3
Case Number: 2510 

CAS Number: 52645-53-1 

PC Code: 109701 

Molecular Weight: 391.3 

Empirical Formula: C21H20CL2O3 

Technical Registrants: Bayer Environmental Science 

 Clark Mosquito Control 

 Control Solutions Incorporated 

 FMC Corporation 

Gharda Chemicals LTD 

LG Life Sciences LTD 

 McLaughlin Gormley King Company 

 Meghamani Organics Limited 

 Micro Flo Company 

 Syngenta Crop Protection, Incorporated 

 United Phosphorus, Incorporated 

 Valent BioSciences Corporation 

C. Use Profile 

The following is information on the currently registered uses of permethrin, including an 

overview of use sites and application methods. A detailed table of the uses of permethrin 

eligible for reregistration is available in Appendix A. 

Type of Pesticide: Insecticide 

Target Pests: Permethrin controls a broad spectrum of pests, including public 

health pests such as mosquitoes. 

Mode of Action: Permethrin is a type I pyrethroid (i.e., it lacks a cyano group at the 

α carbon position of the alcohol moiety) with the primary target 

organ being the nervous system of insects which then causes 

muscle spasms, paralysis and death. 

Use Sites: Permethrin is registered for use on/in numerous food/feed crops, 

livestock and livestock housing, modes of transportation, 

structures, buildings (including food handling establishments), 

Public Health Mosquito abatement programs, and numerous 

residential use sites including use in outdoor and indoor spaces, 

pets, and clothing (impregnated and ready to use formulations). 

Additionally, permethrin has non-FIFRA pharmaceutical uses as a 

pediculicide for the treatment of head lice and scabies. The Food 

and Drug Administration (FDA) approves use of the pesticidecontaining pharmaceutical under FFDCA. 

4
Use Classification: Permethrin is a restricted use pesticide for crop and wide area 

applications (i.e. nurseries, sod farms) due to high toxicity to 

aquatic organisms. It is a general use pesticide for residential and 

industrial applications. 

Formulation Types: Permethrin formulations include emulsifiable concentrate, wettable 

powders, dusts, granular, and ready-to-use formulations. 

Application Methods: Permethrin application methods include broadcast or banded 

application using ground or aerial application; handheld equipment 

such as low and high pressure hand wand sprayers, handgun 

sprayers, backpack sprayers, hose-end sprayer, paint brush, 

foggers, and dip applications; automatic mister systems; and a 

number of ready-to-use methods such as shaker and aerosol cans, 

wipes, ear tags and flanges. 

Application Rates: Permethrin application rates vary depending on the use pattern. 

For most agriculture uses, maximum seasonal rates range from 0.1 

to 0.4 pounds active ingredient per acre (lb ai/A), and depending 

on the crop, the maximum number of permethrin applications per 

season can range from 1 to 8. The maximum application rate for 

the public health use of permethrin is 0.018 lb ai/A, however, the 

typical application rate ranges from 0.0035 to 0.007 lb ai/A, and 

the number of applications depends on the need of the abatement 

district. Application rates vary for residential use products 

depending on indoor or outdoor use, and consumer or professional 

or commercial operator use. The maximum residential application 

rate is use on turf, 0.87 lb ai/A. 

Application Timing: Permethrin can be applied pre- or post-emergence, and most labels 

suggest “as needed.” 

D. Estimated Usage of Permethrin 

According to Agency data, approximately 2 million pounds of permethrin are applied 

annually to agricultural, residential and public health uses sites. The majority of permethrin, 

approximately 70%, is used in non-agricultural settings, whereas approximately 30% is used on 

food/feed crops in agricultural settings. According to the Pyrethroid Issues and Reregistration 

Task Force (PIRTF), approximately 1,450,000 pounds of permethrin active ingredient is used on 

non-agricultural sites per year; 55% is applied by professionals, 41% is applied by homeowners 

on residential areas, and 4% is applied on mosquito abatement areas. 

The Agency’s screening-level usage analysis (SLUA) of permethrin from 1998 to 2004 

indicates that approximately 605,000 pounds of permethrin are used annually on agricultural use sites 

in the United States. In terms of pounds applied, the greatest use is on corn (100,000 lbs ai per year); 

5
however, annually this represents between <1 to 5 percent of corn acreage treated. In terms of percent 

crop treated (%CT), the greatest use is on celery, pistachios, spinach, hazelnuts, and Brussels sprouts, 

with on average, ≥50% crop treated. Table 1 summarizes the best estimates of permethrin usage 

currently available to the Agency. 

Table 1. Estimated Annual Permethrin Crop Usage Summary1 

Crop 

Pounds of Active 

Ingredient Used on 

Annual Basis 

% Crop Treated 

Average Maximum 

Alfalfa 40,000 <1 <2.5 

Almonds 20,000 20 30 

Apples 3,000 5 5 

Apricots <500 5 5 

Artichokes 1,000 30 65 

Asparagus 2,000 10 20 

Avocados 1,000 5 10 

Beans, Green 1,000 <1 5 

Broccoli 3,000 15 30 

Brussels Sprouts <500 50 50 

Cabbage 4,000 15 20 

Cantaloupe 3,000 10 20 

Cauliflower 1,000 15 25 

Celery 8,000 65 85 

Cherries 3,000 10 20 

Chicory <500 ND* ND 

Collards <500 5 5 

Corn 100,000 <1 5 

Cotton 5,000 <1 <2.5 

Cucumbers 5,000 10 15 

Eggplant <500 5 5 

Garlic 1,000 15 20 

Grapes 1,000 <1 <2.5 

Greens, Turnips <500 10 10 

Hazelnuts (Filberts) 1,000 50 70 

Lettuce 50,000 50 70 

Onions 5,000 10 20 

Other Lettuces 10,000 35 35 

Peaches 10,000 20 25 

6
Crop 

Pounds of Active 

Ingredient Used on 

Annual Basis 

% Crop Treated 

Average Maximum 

Pears 1,000 5 10 

Peas, Green <500 <1 <2.5. 

Pecans <500 <1 <2.5 

Peppers 3,000 5 15 

Pistachios 20,000 55 70 

Potatoes 20,000 5 10 

Prunes & Plums <500 <1 <2.5 

Pumpkins 4,000 15 20 

Sorghum 2,000 <1 <2.5 

Soybeans 20,000 <1 <2.5 

Spinach 9,000 50 70 

Squash 3,000 10 15 

Strawberries <500 <1 <2.5 

Sweet Corn 30,000 15 30 

Swiss Chard (CA only) 1,000 ND ND 

Tobacco <500 <1 <2.5 

Tomatoes 8,000 5 10 

Walnuts 5,000 5 10 

Watermelon 5,000 10 15 

*ND – Not Determined 1 Based on EPA data from 1998-2004. 

III. Summary of Permethrin Risk Assessments 

The following is a summary of EPA’s revised human health and ecological risk 

assessments for permethrin, as presented fully in the documents, Permethrin: Fifth Revision of 

the HED Chapter of the Reregistration Eligibility Decision Document (RED), dated April 4, 

2006, 2006, and The Agency Revised Risk Assessment for the Reregistration Eligibility Decision 

on Permethrin After Public Comments, Phase III, dated April 5, 2006. The purpose of this 

summary is to assist the reader by identifying the key features and findings of these risk 

assessments, and to help the reader better understand the conclusions reached in the assessments. 

The human health and ecological risk assessment documents and supporting information 

listed in Appendix C were used to reach the safety finding and regulatory decision for permthrin. 

While the risk assessments and related addenda are not included in this document, they are 

7
available from the OPP Public Docket EPA-HQ-OPP-2004-0385 and may also be accessed on 

the Agency’s website at http://www.regulations.gov. Hard copies of these documents may be 

found in the OPP public docket under this same docket number. 

A. Human Health Risk Assessment 

The human health risk assessment incorporates potential exposure risks from all sources, 

which include food, drinking water, residential (if applicable), and occupational scenarios. 

Aggregate assessments combine food, drinking water, and any residential or other nonoccupational (if applicable) exposures to determine potential exposures to the U.S. population. 

The Agency’s human health assessment is protective of all U.S. populations, including infants 

and young children. 

The EPA released its preliminary risk assessments for permethrin for public comment on 

August 31, 2005 for a 90-day public comment period (Phase 3 of the public participation 

process). The preliminary risk assessments may be found in the OPP public docket at the 

address given above and in EPA’s electronic docket under docket number EPA-HQ-OPP-2004­

0385. In response to comments received and additional data submitted during Phase 3, the risk 

assessments were updated and refined. The revised risk assessments may be found in the OPP 

dockets under the same docket number identified above. Scenario specific revisions to the 

human health risk assessment occurred based on exposure or usage data provided by the 

registrants or PIRTF for several occupational and residential uses. Major revisions to the 

permethrin human health risk assessment include the following: 

• Revised drinking water concentrations provided in the Revised Tier II Estimated 

Drinking Water Concentrations of Permethin, dated December 27, 2005, which is 

also available in the public docket; and 

• Inclusion of wash-off data for the impregnated clothing exposure scenarios 

(residential and occupational), which assumes clothing is usable for up to 30 

washes and that the first wash results in a 33% permethrin loss, the second wash 

results in a 6% loss, washes 3 through 10 each result in a 3% loss, and washes 11 

through 30 result in a total loss of 6.5% permethrin. For more detail, on the washoff assumptions refer to the Third Revision of the Occupational and Residential 

Exposure Assessment for the Reregistration Eligibility Decision Document, dated 

January 31, 2006. 

For more information on the permethrin revised human health risk assessment, see: 

Permethrin: Fifth Revision of the HED Chapter of the Reregistration Eligibility Decision 

Document (RED), dated April 4, 2006. 

1. Toxicity of Permethrin 

Toxicity assessments are designed to predict whether a pesticide could cause adverse health 

effects in humans (including short-term or acute effects such as skin or eye damage, and lifetime or 

chronic effects such as cancer, developmental effects, or reproductive effects), and the level or dose at 

which such effects might occur. The Agency has reviewed all toxicity studies submitted for 

8
permethrin and has determined that the toxicological database is sufficient for each exposure scenario, 

FQPA evaluation, and for important endpoints and dose-response evaluation. However, the Agency 

is requiring a confirmatory developmental neurotoxicty study (DNT) for additional assurance as to the 

dose-response in characterizing neurotoxic effects. For more details on the toxicity and 

carcinogenicity of permethrin, see Permethrin: Fifth Revision of the HED Chapter of the 

Reregistration Eligibility Decision Document (RED), dated April 4, 2006, which is available 

under docket number EPA-HQ-OPP-2004-0385. 

a. Acute Toxicity Profile 

Permethrin is classified as category III for acute oral and acute dermal toxicity. No acceptable 

data on acute inhalation toxicity for permethrin technical is available (Data Gap). Permethrin is 

classified as category III for eye irritation potential and category IV for dermal irritation potential. 

Permethrin technical is not considered a skin sensitizer based on a weight-of-evidence evaluation of 

available data.The acute toxicity profile for permethrin is summarized in Table 2 below. 

Table 2. Acute Toxicity Profile for Permethrin 

Guideline Study Type MRID No. Results 

Toxicity 

Category 

870.1100 Acute Oral Toxicity in 

Rats 242899 LD50 =3580 mg/kg (M) 

 2280 mg/kg (F) III 

870.1200 Acute Dermal 

Toxicity in Rabbits 242899 LD50 > 2000 mg/kg III 

870.1300 Acute Inhalation 

Toxicity in Rats Data Gap ND* 

870.2400 Primary Eye Irritation 

in Rabbits 242899 Irritation 24-48 hrs. All cleared by 72 hrs. III 

870.2500 Primary Dermal 

Irritation in Rabbits 242899 All irritation cleared by 48 hrs. IV 

870.2600 Skin Sensitization in 

Guinea Pigs EPA Memo** Non-sensitizer*** Not Applicable 

* ND: No Data 

** EPA Memorandum, June 13, 1995, “Permethrin: Review of a series 81-6 dermal sensitization study (guinea pig 

maximization test) and a series 85-2 dermal penetration study.” 

*** Based on a weight of evidence evaluation of other sensitization study data do not indicate that permethrin should be 

regulated as a potential sensitizer. 

b. FQPA Safety Factor Considerations 

The Federal Food, Drug, and Cosmetic Act (FFDCA), as amended by FQPA, directs the 

Agency to use an additional ten fold (10x) safety factor (SF) to account for potential pre- and postnatal 

toxicity and completeness of the data with respect to exposure and toxicity to infants and children. 

FQPA authorizes the Agency to modify the 10x FQPA SF only if reliable data demonstrate that the 

resulting margin of safety would be safe for infants and children. 

For permethrin, the database is adequate in terms of endpoint studies and dose response 

information to characterize any potential for prenatal or postnatal risk for infants and children. 

Developmental and reproductive toxicity studies demonstrated that there is no evidence (qualitatively 

9
or quantitatively) for increased susceptibility to infants and children following in utero and/or 

pre/postnatal exposure to permethrin. Additionally, there is no evidence that permethrin induces any 

endocrine disruption. 

There is, however, concern for developmental neurotoxicity based on evidence of 

neurotoxicity at high doses in a subchronic neurotoxicity study. The Agency is requiring a 

confirmatory developmental neurotoxicity study (DNT) for further characterization of neurotoxic 

effects. However, although a DNT is required, a dose-analysis with the existing reliable toxicity 

data for permethrin, that included an evaluation of the acute and subchronic neurotoxicity studies 

in addition to the 3-generation reproduction study, indicates that that the results of the DNT 

would not have an impact on the risk assessment. Therefore, an FQPA database uncertainty 

factor (UFDB) is not required for acute and chronic risk assessments or for residential (nondietary) exposures. The Agency has determined that, based on the existing exposure and toxicity 

data for permethrin, the risk assessment, as conducted, indicates a reasonable certainty of no 

harm to infants and children. In addition, the dietary food exposure assessment demonstrates 

that acute and chronic exposures do not underestimate the risk and are not of concern, and the 

residential exposure assessment is based on reliable data and is unlikely to underestimate 

exposure and risk. Therefore, the FQPA SF is reduced to 1x. 

c. Toxicological Endpoints 

The toxicological endpoints used in the human health risk assessment for permethrin are listed 

in Table 3 below. An estimated dermal absorption factor of 15% also is used in the risk assessment. 

The dermal absorption factor of 15% was estimated by comparing the Lowest Observed Adverse 

Effect Level (LOAEL) of the rat acute oral neurotoxicity study of 75 mg/kg/day and No Observed 

Adverse Effect Level (NOAEL) of the rat 21-day dermal study (because no LOAEL was established) 

of 500 mg/kg/day. The estimate is considered to be a conservative high-end estimate because the oral 

dose represents a LOAEL rather than a NOAEL. The uncertainty factors (UF) and safety factors used 

to account for interspecies extrapolation, intraspecies variability, and special susceptibility of infants 

and children (FQPA SF) are also described in Table 3. 

Table 3. Toxicology Endpoints for Permethrin 

Exposure Scenario 

Dose, Uncertainty 

Factors 

FQPA Safety Factor and 

Level of Concern Study and Endpoint for Risk Assessment 

Acute Dietary 

(Females 13 to 49 

years of age) 

Acute RfD= not applicable Since there is no developmental or reproductive toxicity of concern for 

permethrin, no appropriate endpoint or study was selected for the 

female (13-49) subgroup. The selected dose/endpoint for general 

population would provide adequate protection for females 13-49 years 

old. 

10
Table 3. Toxicology Endpoints for Permethrin 

Exposure Scenario 

Dose, Uncertainty 

Factors 

FQPA Safety Factor and 

Level of Concern Study and Endpoint for Risk Assessment 

Acute Dietary 

(General 

population 

including infants 

and children) 

Oral NOAEL=25 

mg/kg/day 

UF = 100X (10x 

interspecies and 10x 

intraspecies) 

Acute RfD= 0.25 

mg/kg/day 

FQPA SF = 1X 

aPAD=Acute RfD

 FQPA SF 

aPAD= 0.25 mg/kg/day 

Acute Neurotoxicity Study in Rats 

LOAEL = 75 mg/kg/day based on 

observations of clinical signs (i.e. 

aggression, abnormal and/or decreased 

movement) and increased body 

temperature. 

Chronic Dietary 

(All populations) 

Oral NOAEL = 25 

mg/kg/day 

UF = 100 

Chronic RfD = 0.25 

mg/kg/day 

FQPA SF = 1X 

cPAD = Chronic RfD 

FQPA SF 

cPAD= 0.25 mg/kg/day 

Short- and 

Intermediate-Term 

Incidental Oral 

Oral NOAEL = 25 

mg/kg/day 

UF = 100 

Residential LOC for 

MOE =100 

Short-, 

Intermediate-, and 

Long-Term Dermal 

Dermal NOAEL = 500 

mg/kg/day 

UF = 100 

Residential LOC for 

MOE =100 

Occupational LOC for 

MOE =100 

21-Day Dermal Toxcitiy Study in Rats 

LOAEL was not established. 

Short-, 

Intermediate-, and 

Long-Term 

Inhalation 

Inhalation NOAEL = 0.042 

mg/l (converts to oral 

equivalent of 11 

mg/kg/day) 

UF = 100 

Residential LOC for 

MOE =100 

Occupational LOC for 

MOE =100 

15-Day Inhalation Study in Rats 

LOAEL = 0.583 mg/l (converts to oral 

equivalent of 154 mg/kg/day) based on 

body tremors and hypersensitivity to 

noise. 

Cancer 

(Oral, dermal, 

inhalation) 

Classification: “Likely to be Carcinogenic to Humans” with a Q1* (mg/kg/day)

-1= 9.6 x 10-3 

(Dermal absorption rate=15% for dermal portion of the cancer equation) 

UF = uncertainty factor, FQPA SF = FQPA safety factor, NOAEL = no observed adverse effect level, LOAEL = lowest observed 

adverse effect level, PAD = population adjusted dose (a = acute, c = chronic), RfD = reference dose, MOE = margin of exposure, 

LOC = level of concern 

2. Carcinogenicity of Permethrin 

As described in Table 3 above, the Agency classified permethrin as “Likely to be 

Carcinogenic to Humans” by the oral route. This classification was based on two reproducible 

11 
benign tumor types (lung and liver) in the mouse, equivocal evidence of carcinogenicity in LongEvans rats, and supporting structural activity relationships (SAR) information. For the purpose 

of risk characterization, a low dose extrapolation model (Q1

*

) was used. The Q1

* is 9.6 x 10-3 

(mg/kg/day)-1 and was derived from the female mouse lung (adenoma and/or carcinoma) tumors. 

For more information, see the document Permethrin Report of the Cancer Assessment Review 

Committee (Third Evaluation), dated October 23, 2002. 

3. Metabolites and Degradates 

The Agency reviewed the metabolism of permethrin, and concluded that for tolerance 

expression and risk assessment, the parent (both cis- and trans-permethrin) is the only residue of 

concern for both plants and livestock, and drinking water exposure. For additional details refer to 

Permethrin: Fifth Revision of the HED Chapter of the Reregistration Eligibility Decision 

Document (RED), Dated April 4, 2006. 

4. Permethrin Endocrine Effects 

The EPA is required under the FFDCA, as amended by FQPA, to develop a screening 

program to determine whether certain substances (including pesticides active and other 

ingredients) “may have an effect in humans similar to an effect produced by a naturally 

occurring estrogen, or other such endocrine effects as the Administrator may designate.” In the 

available toxicity studies on permethrin, there was no toxicologically significant evidence of 

endocrine disruptor effects. When additional appropriate screening and/or testing protocols 

being considered under the Agency’s Endocrine Screening Disruption Program have been 

developed, permethin may be subject to further screening and/or testing to better characterize 

effects related to endocrine disruption. 

5. Dietary Risk from Food and Drinking Water 

EPA conducted acute, chronic, and cancer dietary (food and drinking water) risk 

assessments for permethrin using the Dietary Exposure Evaluation Model software with the Food 

Commodity Intake Database (DEEM-FCIDTM, Version 1.3), which incorporates consumption 

data from USDA’s Continuing Survey of Food Intakes by Individuals (CSFII), 1994-1996 and 

1998. The acute and chronic non-cancer and cancer dietary risk assessments were conducted for 

all supported permethrin food uses. The estimated surface drinking water concentrations 

(EDWCs) for permethrin were calculated using the Tier II Pesticide Root Zone Modeling 

(PRZM) and Exposure Analysis Modelng System (EXAMS) and also includes the Index 

Reservior (IR) and Percent Crop Area (PCA) factor requirements. The EDWCs from 

groundwater sources of drinking water were derived from the Tier I model SCI-GROW. The 

EDWCs were included in the DEEM-FCID analyses to estimate combined exposures from food 

and drinking water. 

a. Dietary (Food and Drinking Water) Exposure Assumptions 

As stated above, the acute dietary (food) risk assessment for permethrin was conducted 

using the DEEM-FCIDTM computer model. Highly refined acute (probabilistic), chronic, and 

12
cancer dietary exposure assessments were conducted to estimate the dietary risks associated with 

the reregistration of permethrin. Permethrin residue estimates used in these assessments include 

cis- and trans-permethrin, calculated as total permethrin, along with the Agency’s percent crop 

treated data. The anticipated residue (AR) estimates are based primarily on the USDA Pesticide 

Data Program (PDP) food sampling data. Processing data was also used on a number of crops if 

available. 

Drinking water exposure to pesticides can occur through surface and ground water 

contamination. EPA considers both acute (one day) and chronic (lifetime) drinking water risks 

and uses either modeling or monitoring data, if available and of sufficient quality, to estimate 

those exposures. Permethrin is relatively persistent in the environment, and is stable to 

hydrolysis and photolysis. The parent compound has a very low mobility and has a high affinity 

to bind to soils/sediments and organic carbon; therefore, it is not expected to leach to 

groundwater. However, like several other chemicals in its class, it can reach surface waters by 

spray drift or in run-off events via erosion. Table 4 lists the EDWCs used to assess the exposure 

to permethrin in drinking water from surface water and groundwater sources. Based on 

screening-level model results, these values generally represent upper-bound estimates of the 

concentration that might be found in surface water and groundwater sources of drinking water. 

Because the surface water EDWCs from the screening-level PRZM-EXAMS model were higher 

than those predicted from the SCI-GROW model for groundwater sources, the relevant EDWC 

model value from surface water was used in the dietary exposure assessment conducted using the 

DEEM-FCID model to be protective. 

Table 4. Permethrin Surface Water and Groundwater EDWC 

Drinking Water Source Duration EDWC (ppb) 

Surface Water* Acute (Peak) 4.79 

Chronic 0.90 

Cancer 0.75 

Groundwater** All Durations 0.012 

*The surface water EDWCs are based on the Georgia onion use scenario – a maximum application rate of 0.285 lb ai/A and 7

applications per year. 

**The groundwater EDWC is based on the California almond use scenario – a maximum application rate of 0.4 lb ai/A/year and

5 applications per year. 

For more detail on the calculation of the EDWCs, refer to the Second Revision Tier II 

Estimated Drinking Water Concentrations of Permethrin, dated January 17, 2006 available in the 

public docket. 

b. Population Adjusted Dose 

The dietary risk assessment incorporates both exposure and toxicity of a given pesticide. 

For acute and chronic dietary assessments, the risk is expressed as a percentage of a level of 

concern (i.e., the dose predicted to result in no unreasonable adverse health effects to any human 

13
sub-population, including sensitive members of such sub-populations). This level of concern is 

referred to as the Population Adjusted Dose (PAD). Dietary risk is characterized in terms of the 

PAD, which reflects the Reference Dose (RfD), either acute or chronic, that has been adjusted to 

account for the FQPA SF. For permethrin, the FQPA SF is 1x. 

Estimated dietary risks less than 100% of the PAD, either acute (aPAD) or chronic 

(cPAD), are below the Agency’s level of concern (LOC). The aPAD is the dose at which a 

person could be exposed at any given day with no adverse health effects expected. The cPAD is 

the dose at which an individual could be exposed over the course of a lifetime with no adverse 

health effects expected. Risk estimates from permethrin in food and drinking water are 

summarized in Table 5 below. 

c. Acute and Chronic Dietary (Food and Drinking Water) Risk 

Acute and chronic dietary risk estimates are provided for the general U.S. population and 

various population subgroups, with the major emphasis placed on the exposure estimated for 

infants and children. The Agency concluded that for all supported registered commodities, the 

acute and chronic (non-cancer) dietary (food and drinking water) risk estimates do not exceed the 

LOC (less than 100% of the aPAD and cPAD, respectively), with the highest exposed subgroup 

being infants (<1 year old) at 16% of the aPAD and <1% of the cPAD. Table 5 below 

summarizes the acute and chronic (non-cancer) risk estimates from dietary (combined food and 

drinking water) exposure to permethrin. 

Table 5. Permethrin Dietary (Food + Drinking Water) Exposure Analysis Using DEEM FCID. 

Population Subgroup 

Acute 

Exposure 

(mg/kg/day)* 

% aPAD 

99.9th Percentile 

Chronic 

Exposure 

(mg/kg/day)* 

% cPAD 

U.S. Population 0.010971 4 0.000184 <1 

Infants (<1 year old) 0.039416 16 0.000432 <1 

Children 1-2 years 0.024494 10 0.000385 <1 

*mg/kg/day = milligram per kilogram per day. 

d. Cancer Dietary (Food and Drinking Water) Risk 

The cancer dietary assessment was conducted for the general U.S. population. To 

estimate cancer risk, the 70-year lifetime average daily exposure is multiplied by the cancer 

potency factor (Q1*) to yield a unitless number that represents the excess number of cancers 

potentially attributed to exposure to the pesticide over a lifetime. For the cancer dietary 

assessment, risk estimates within the range of an increased cancer risk of one in a million (1 x 

10-6) are generally below EPA’s level of concern; however, the Agency generally considers risks 

up to 3 x 10-6 to be within the negligible risk range and below the Agency’s LOC. A Q1* is an 

estimate of the upper bound on cancer risk. 

14
The estimated lifetime average daily exposure of the general U.S. population to 

permethrin from food and drinking water is 0.000117 mg/kg/day. Applying the Q1* of 9.6 x 10-3 

(mg/kg/day)-1 to the exposure value results in a combined cancer risk estimate of 1.1 x 10-6 for 

food and drinking water, which is considered to be within the negligible risk range of 1 x 10-6 

and does not exceed the Agency’s LOC. See Table 6 below for cancer dietary risk estimates. 

Table 6. Permethrin Cancer Dietary (Food + Drinking Water) Risk Estimates 

Dietary Exposures Assessed Q1 * Cancer Risk Estimate 

Food Alone 

9.6 x 10-3 

(mg/kg/day)

-1 

9.76 x 10-7 

Drinking Water Alone 1.52 x 10-7 

Food and Drinking Water Combined 1.1 x 10-6 

6. Residential Exposure and Risk 

Residential exposure assessments consider all potential non-occupational pesticide 

exposure, other than exposure due to residues in foods or in drinking water. Permethrin has a 

wide variety of residential uses, including use on pets, indoor and outdoor surfaces, turf and 

garden crops, and use of clothing (ready to use formulations or impregnation). Permethrin is 

also labeled as a mosquito adulticide, and can be used by Public Health Officials for mosquito 

abatement and other mosquito control programs. It can also be used for mosquito and general 

pest control in residential and commercial areas through outdoor automatic mister systems. 

The Agency has determined that there is a potential for exposure to permethrin in 

residential settings for homeowners who handle (mix, load, and apply) products containing 

permethrin, as well as post-application exposure from entering permethrin-treated areas, such as 

lawns, home gardens, or indoor areas. Risk assessments have been completed for both 

residential handler and post-application scenarios. 

To estimate residential non-cancer (dermal and inhalation) risks, the Agency calculates a 

margin of exposure (MOE), which is the ratio of the NOAEL selected for risk assessment to the 

exposure. This MOE is compared to a level of concern which is the same value as the 

uncertainty factor (UF) applied to a particular toxicity study. The standard UF is 100x (10x to 

account for interspecies extrapolation and 10x for intraspecies variation), plus any additional 

FQPA SF retained due to concerns unique to the protection of infants and children. The FQPA 

SF for permethrin is reduced to1x for reasons explained in section III.A.1.b. 

To estimate the residential cancer risk, the lifetime average daily dose is calculated, 

which assumes the homeowner will be exposed to permethrin in the same manner for 50 years 

within a 70-year life span, and then multiplied by the Q1* value. Similarly, residential cancer 

risk estimates within the range of an increased cancer risk of one in a million (1 x 10-6) are 

generally below EPA’s level of concern; however, the Agency generally considers risks up to 3 x 

10-6 to be within the negligible risk range and below the Agency’s LOC. The cancer risk 

assessments also include the number of exposure events (handler and post-application) that could 

15
occur per year before the estimated cancer risk reached the Agency’s level of concern. 

a. Residential Handler Risks 

The Agency determined that exposure to homeowners handling a permethrin product is 

likely to occur via dermal (skin) and inhalation routes during the residential use of permethrin in 

a variety of indoor and outdoor environments, including use on lawns, gardens, ornamentals, 

indoor surfaces and spaces, and contact with pets. Permethrin is one of the most widely used 

pesticide active ingredients, and has an extraordinary number of use patterns. The risk 

assessment considered 25 major residential exposure scenarios, based on the types of equipment 

and techniques that can potentially be used to make permethrin applications; such as various 

handheld equipment, for example low pressure hand wand sprayers, backpack sprayers, hose-end 

sprayer, paint brush, and dip applications; automatic outdoor mister systems; and a number of 

ready-to-use (RTU) methods such as shaker and aerosol cans, wipes, ear tags and protective 

flanges. The use patterns assessed are considered to be representative scenarios that are believed 

to represent the vast majority of permethrin uses. 

The Agency considered residential handler exposure scenarios to be short-term (1-30 

days) only due to infrequency of use associated with homeowner products. According to the 

data submitted by the Residential Exposure Joint Venture (REJV), which is a group of companies 

that conducted a survey of homeowners to ascertain how consumer pesticide products are used 

(e.g., rate, frequency, pests, etc), a permethrin product is used by homeowners on average 5 

times a year. The residential risk assessment is also based on estimates of what and how much 

homeowners would typically treat, such as the size of the lawn or garden, based on the Agency’s 

standard operating procedures for residential exposures and best professional judgment. For 

more information on the daily volume handled and the area treated used in each residential 

handler scenarios, refer to Permethrin: Third Revision of the Occupational and Residential 

Exposure Assessment for the Reregistration Eligibility Decision Document, dated April 4, 2006. 

Non-cancer (dermal and inhalation) risks for homeowners handling permethrin products 

are below the Agency’s LOC. The combined (dermal and inhalation) MOEs for all scenarios 

assessed are greater than 100 (ranging from 690 to 22 million) and are, therefore, not tabulated in 

this document, but are available in the document referenced above. For residential handler 

cancer risks, the Agency considered the REJV homeowner use pattern information discussed 

above, that homeowners use pesticide products on an average of 5 times a year, to assess whether 

homeowner use scenarios were above the Agency’s LOC. Handler scenarios that result in a 

cancer risk estimate of ≤3 x 10-6, which the Agency considers to be within the negligible cancer 

risk range, at 5 or more exposure events a year, are below the Agency’s LOC and are similarly 

not tabulated in this document. All assessed residential handler cancer risk estimates are below 

the Agency’s LOC at ≥5 exposure events per year, except for the eight use site scenarios listed in 

Table 7. 

Table 7: Residential Cancer Handler Risk Estimates 

Exposure Scenario Use Site Application 

Rate 

Area Treated 

Daily or Amount 

Applied per Day 

# of Events per 

Year to Reach 

3 x 10-6 LOC 

Mixing/Loading/Applying 

16
Table 7: Residential Cancer Handler Risk Estimates 

Exposure Scenario Use Site Application 

Rate 

Area Treated 

Daily or Amount 

Applied per Day 

# of Events per 

Year to Reach 

3 x 10-6 LOC 

Emulsifiable Concentrates 

(EC) with Low Pressure 

Handwand 

Outdoor surfaces 

0.46 lb 

ai/gallon 5 gallons 3 

Ornamentals: outdoor trees 

0.043 lb 

ai/gallon 5 gallons 3 

Perimeter treatment: 

outdoor wood surfaces 

0.4 lb 

ai/gallon 5 gallons 3 

EC with a Hose-End Sprayer 

Ornamentals: outdoor tress 

0.043 lb 

ai/gallon 

100 gallons <1 

Stored lumber, wood piles 0.04 lb 

ai/gallon 

100 gallons <1 

Ornamentals: outdoor 

0.02 lb 

ai/gallon 

100 gallons 3 

EC via Sponge Horses 

0.005 lb 

ai/gallon 

2 animals 2 

Granulars via Belly Grinder Turf 0.65 lb ai/acre 0.5 acres 2 

For the complete residential handler assessment and risk estimates refer to the 

Permethrin: Third Revision of the Occupational Residential Exposure Assessment for the 

Reregistration Eligibility Decision Document, dated April 4, 2006. Additionally, refer to 

Permethrin: Comparing Cancer Target Levels of Concern (1 x 10-6 vs 3 x 10-6), dated April 4, 

2006, for refined residential cancer risk estimates. 

The area treated daily used in the risk assessment for each scenario was based on the 

Agency’s standard operating procedures for each application method. Additionally, the 

residential cancer risk assessment assumes a homeowner would be using a permethrin product in 

the manner assessed for 50 years of a 70-year lifetime. For most of these scenarios, the Agency 

does not believe they are feasible or likely to occur based on the frequency of application, 

amount of product handled, and the application method paired with the use patterns assessed 

above. For example, the Agency did not think it was likely that a homeowner would be applying 

5 gallons of finished spray to outdoor surfaces, ornamentals, and perimeter treatments with a low 

pressure handwand more than three times a year, which would be a total of 15 gallons a year on 

these use sites. Further, the Agency does not believe it is likely that a homeowner would use a 

belly grinder to treat 0.5 acres of turf more than twice a year. Low pressure handwands and belly 

grinder are not conducive to handling a large amount of product (liquid or granular respectively) 

or treating a large area. The equipment would require multiple refills and would be labor 

intensive. Finally, the Agency does not believe a homeowner will be applying 100 gallons of 

finished spray in a day, as assumed above in the mixing/loading/applying EC formulated 

products with a hose-end sprayer scenario. Therefore, these scenarios are considered not to be of 

concern to the Agency. The Agency does not believe these scenarios are likely to occur in a 

year, and are highly unlikely to occur multiple times per year over 50 years. 

The only handler scenario listed in Table 7 that the Agency considers to be of cancer risk 

concern is mixing/loading/applying the EC formulation via sponge to horses. The Agency 

believes that this use pattern is likely to occur as assessed. However, because the Agency lacked 

exposure data for this specific use pattern, data from a Chemical Manufacturers Association 

17
(CMA) Antimicrobial Exposure Assessment Study was used to assess exposure to individuals 

who used wipes to apply antimicrobial pesticides. This study was judged to be the best available 

surrogate for this exposure scenario. While the wipe data from this study provides the best 

available information on handler exposure to sponge scenarios, there are some uncertainties 

associated with the data used, such as: good laboratory practices were not closely followed, 

extraction efficiencies were below the minimum level suggested in the guidelines, calibration of 

the air monitoring equipment resulted in much of the data being less than detection, and the 

limited number of replicates (the guidelines recommend 15 replicates). Therefore, although this 

scenario results in a risk estimate above the Agency’s LOC, there are a number of uncertainties 

that may be addressed with better quality data. 

b. Residential Post-Application Risks 

The Agency refers to the term “post-application” to describe exposures to individuals that 

occur as a result of being in an environment that has been previously treated with a pesticide. 

Permethrin can be used in many areas that can be frequented by the general population including 

residential areas (indoor and outdoor areas). As a result, individuals can be exposed by entering 

these areas if they have been previously treated. Permethrin can also be used on companion 

animals, which can lead to exposure by contact with the treated animals. Further, permethrin is 

used in Public Health Abatement Programs as a mosquito adulticide, where it can be applied to 

wide areas through ultra-low volume (ULV) spraying, which can result in post-application 

exposure to the general population. 

Permethrin is also used to treat clothing (ready to use formulations and impregnation), 

which can lead to exposure during use of the clothing. The Agency is aware that there are a 

variety of commercial application/impregnation methods currently being used to produce 

permethrin treated clothing, and that some of the new more technologically advanced 

application/impregnation methods will result in less exposure to individuals wearing this 

clothing. However, the Agency used the best available data collected from clothing treated with 

older and less technologically advanced application/impregnation methods when assessing postapplication exposure to permethrin impregnated clothing. The Agency recently received a pilot 

exposure study based on a newer technologically advanced impregnation method currently being 

used by one permethrin registrant. This study is currently being reviewed by the Agency to 

determine the scientific viability and applicability of the study. However, based on a cursory 

review, the Agency has found that the “pilot study” (as it is referred to by the registrant) includes 

a very limited number of biomonitoring and patch replicates. Assuming a full review deems the 

study scientifically viable and applicable, it would appear that this pilot, product-specific 

exposure study suggests no risks in excess of those from the conservative assessment discussed 

above. Therefore, the Agency believes that the current assessment results in conservative and 

protective estimates of exposure and risk to permethrin impregnated clothing produced by any 

currently used application/impregnation method. 

Unlike residential handler exposure, where the EPA assumed only adults will be handling 

and applying permethrin products, individuals of varying ages can potentially be exposed to 

permethrin when reentering or performing activities in areas that have been previously treated, 

wear permethrin treated-clothing, or have contact with treated companion animals. The 

18
residential populations that were considered in the risk assessment include: 

• Residential adults engaged in: 

o Mowing or exercising on a treated lawn, 

o Working in a treated garden, 

o Outdoor activities after a mosquito abatement public health ULV 

application (truck fogger and aerial spray), 

o Outdoor activities after the use of an outdoor residential mister system, 

o Playing/exercising on treated indoor surfaces, such as carpets and hard 

floors, 

o Pet contact activities, and 

o Wearing permethrin treated clothing. 

• Residential youth (representative age 10-12) engaged in: 

o Working in a treated garden, and 

o Wearing permethrin treated clothing. 

• Residential toddlers (3 years) engaged in: 

o Playing on a treated lawn, 

o Outdoor activities after a mosquito abatement public health ULV 

application (truck fogger and aerial spray), 

o Outdoor activities after the use of an outdoor residential mister system, 

o Wearing permethrin treated clothing, 

o Pet contact activities, and 

o Playing/exercising on treated indoor surfaces, such as carpets and hard 

floors. 

Post-application exposures to permethrin for adults are most likely through the skin and 

inhalation routes (mosquito abatement scenarios), whereas children may also receive oral 

exposures from mouthing behaviors (i.e., hand-to-mouth, object-to-mouth, and soil ingestion). 

Non-Cancer Risks 

The non-cancer risks (dermal and inhalation) from post-application exposure to 

permethrin, for the scenarios listed above, including wearing impregnated clothing, are below the 

Agency’s LOC for residential adults and youth (MOEs ranged from 120 to 500 billion) for adults 

and 3,700 to 48,000 for youth), and are, therefore, not tabulated in this document, but are 

available in Permethrin: Third Revision of the Occupational and Residential Exposure 

Assessment for the Reregistration Eligibility Decision Document, dated April 4, 2006. 

Additionally, most of the toddler risk estimates are also below the Agency’s LOC (MOEs 

ranging from 140 to 250 billion); however, the incidental oral and dermal toddler postapplication risk estimates for the indoor surface spray (carpet) scenario are of concern to the 

Agency (MOEs <100) and are listed in Table 8 below. 

Table 8: Toddler Risk Estimates for Post-application Exposure to Permethrin 

Exposure Scenario Route of 

Exposure 

Application Rate MOE on day of application 

19
Table 8: Toddler Risk Estimates for Post-application Exposure to Permethrin 

Exposure Scenario Route of 

Exposure 

Application Rate MOE on day of application 

Hand to mouth activities on indoor 

surfaces - Spray (carpet) 

Oral 0.0001 lb ai/sq. ft. 37 

Indoor Surfaces (high contact 

activities)- Spray (carpet) 

Dermal 0.0001 lb ai/sq. ft. 69 

Both scenarios in Table 8 assume a 1% concentration of permethrin in a directed spray, a 

rate only used by professional applicators. Further, table 8 does not include aerosol sprays, 

which were assessed separately in the risk assessment referenced above, and are result in risk 

below the Agency’s LOC (MOEs for oral and dermal exposure are 8,500 and 16,000, 

respectively). 

The Agency also combines risk values from separate post-application exposure scenarios, 

when it is likely that they can occur simultaneously based on the use pattern and the behavior 

associated with the exposed population. The non-cancer risk estimates for toddlers were 

combined since toddlers are the most sensitive population assessed, and are presented in Table 9 

below. 

Table 9: Permethrin Post-application Residential Scenarios for Combined Non-cancer Risk Estimates 

Post-application Exposure Scenario 

Margins of Exposure (MOEs) 

(UF=100) 

Individual 

Exposure 

Combined (Total) 

Exposure 

Toddler Turf – Sprays 

(0.87 lb ai/A) 

Dermal 12,000 

6,400 

Hand to Mouth 15,000 

Object to Mouth 250,000 

Incidental Soil 

Ingestion 

570,000 

Toddler 

Indoor Carpet ­

Aerosols 

Dermal 8,500 5,600 Hand to Mouth 16,000 

Toddler 

Indoor Carpet – 

Fogger 

Dermal 410 270 Hand to Mouth 770 

Toddler Pet - Shampoo 

Dermal 12,000 350 Hand to Mouth 360 

Toddler Pet- Dusts Dermal 1,600 720 Hand to Mouth 1,300 

Toddler 

Impregnated Clothing: 

Long Sleeves/Long 

Pants 

Dermal 2,700 

2,400 

Object to Mouth 24,000 

The combined MOEs for the individual turf spray, indoor carpet-aerosol, indoor carpetfogger, pet dust, pet shampoo, and impregnated clothing scenarios are all greater than 100, and 

therefore, do not exceed the Agency’s LOC. 

Cancer Risks 

Similar to the residential handler cancer risk assessment, the post-application risk 

assessment includes the number of exposure events that could occur per year before the cancer 

20
risk reached the negligible risk range (≤3 x 10-6) and assumes the same exposure occurring over 

a period of 50 years of a 70-year lifetime. Moreover, for indoor post-application exposure to 

toddlers, the Agency assumed 8 hours of exposure for carpet sprays, and 4 hours for vinyl 

flooring. Additionally, the post-application risk assessment assumed exposure to permethrin 

residues the same day the area was treated (i.e., day 0 residue), which are considered reasonably 

conservative assumptions, considering indoor residues are removed over time through cleaning 

and other indoor activities. Therefore, for example, 5 days of post-application exposure to day 0 

residue, would assume 5 treatment event per year. Since the Agency assumed a residential 

handler would be applying a pesticide on average 5 times per year, the same assumption was 

used for post-application risk assessment, except for the impregnated clothing scenario. In 

general, the post-application risk estimates that reached the ≤3 x 10-6 negligible risk range after 5 

or more exposure events per year (over a period of 50 years of a 70-year lifetime) are considered 

to be below the Agency’s LOC. 

The same residential adult scenarios that were assessed for the non-cancer risk estimates 

were also assessed for the cancer risk estimates. All outdoor and pet contact scenarios assessed 

are below the Agency’s LOC and are, therefore, not tabulated in this document. The number of 

exposure events per year (over a period of 50 years of a 70-year lifetime) to reach the cancer 

negligible risk level for these outdoor and pet contact scenarios are all > 5 (ranging from 18 to 

365 days). However, two indoor scenarios are of concern to the Agency, and are presented in 

Table 10 below. 

Table 10: Summary of Permethrin Post-application Residential Cancer Risks of Concern 

Exposure Scenario Route of 

Exposure 

Application Rate # of Events/Year to 

Reach LOC 

Indoor Surfaces (high Contact 

Activities) - Spray 

Dermal 0.0001 lb ai/sq. ft. <1 

Indoor Surfaces (high contact 

activities)- Fogger 

Dermal 0.0023 lb ai/s6 oz 

fogger 

2 

For the impregnated clothing scenario, the Agency estimated the number of days an 

article of clothing would typically be worn within a year’s time. Unlike the other postapplication scenarios, that considered each post-application exposure event to be day 0 residues, 

the Agency considered wash-off data to determine the potential exposure that would occur after 

each consecutive wear and wash of the garment. The Agency believes that consumers will 

primarily use permethrin treated clothing recreationally (i.e., weekends, outdoor activities, 

sporting events), as well as seasonally when mosquitoes are most active. Therefore, it is likely 

individuals will wear permethrin impregnated clothing more than 5 times per year, but highly 

unlikely that a consumer will wear a treated shirt 151 times per year, or treated pants and a long 

sleeve shirt 92 times per year, as presented in Table 11 below. Furthermore, the cancer risk 

assessment assumes that the consumer will wear the combination of permethrin treated clothing 

stated in Table 11 below each year for 50 years. Therefore, based on the use pattern discussed 

above, the cancer risk estimates for wearing impregnated clothing are below the Agency’s LOC. 

Table 11: Summary of Permethrin Post-application Impregnated Clothing Cancer Risks for Adults 

Exposure Scenario Route of 

Exposure 

Application Rate # of Days/Year to Reach 

LOC 

Impregnated Clothing: Long Sleeve Dermal 0.125 mg ai/cm2 151 

21
Table 11: Summary of Permethrin Post-application Impregnated Clothing Cancer Risks for Adults 

Shirt 

Impregnated Clothing: Long Sleeve 

Shirt/Long Pants Dermal 0.125 mg ai/cm2

 92 

Permthrin is also used in outdoor residential misting systems. The Agency assessed the 

potential risks to both adults and toddlers exposed to permethrin during applications via outdoor 

residential misting systems. The MOE for adults by inhalation route is 160,000, and the MOE 

for toddlers is 69,000. The non-cancer risk estimates are below the Agency’s LOC (MOE≥100). 

Further, it took 365 exposure events to reach the Agency’s cancer LOC. The Agency does not 

believe an individual will be exposed to permethrin from an outdoor residential misting system 

application daily for 50 years. Therefore, the cancer risk estimate is below the Agency’s LOC. 

For the entire homeowner post-application assessment and risk estimates, refer to 

Permethrin: Third Revision of the Occupational Residential Exposure Assessment for the 

Reregistration Eligibility Decision Document, dated April 4, 2006. Additionally, refer to 

Permethrin: Comparing Cancer Target Levels of Concern (1 x 10-6 vs 3 x 10-6), dated April 4, 

2006, for refined residential cancer risk estimates. 

7. Aggregate Risk 

The FQPA amendments to the Federal Food, Drug, and Cosmetic Act (FFDCA, Section 

408(b)(2)(A)(ii)) require “that there is a reasonable certainty that no harm will result from 

aggregate exposure to the pesticide chemical residue, including all anticipated dietary exposures 

and other exposures for which there is reliable information.” Aggregate exposure will typically 

include exposures from food, drinking water, residential uses of a pesticide, and other nonoccupational sources of exposure. 

In accordance with the FQPA, the Agency must consider and aggregate pesticide 

exposures and risks from three major sources or pathways: food, drinking water and, if 

applicable, residential or other non-occupational exposures. For permethrin, the Agency 

conducted a refined aggregate risk assessment that combines exposures across all pathways. The 

Agency included acute, chronic and cancer EDWCs directly in the dietary exposure assessments 

to calculate aggregate dietary (food + drinking water) risk. This was accomplished by using the 

relevant screening-level PRZM-EXAMS model value as a residue for drinking water (all 

sources) in the dietary exposure assessment conducted using the DEEM-FCIDTM model. 

The short-term residential and other non-occupational exposure assessments consider all 

potential pesticide exposure, other than exposure due to residues in food and/or in drinking 

water. Each route of exposure (i.e., oral, dermal, inhalation) is assessed. Risk estimates from all 

relevant pathways (i.e., food, drinking water, and residential or non-occupational) for permethrin 

from all sources were calculated to assess aggregate risks. When aggregating exposure and risk 

from various sources, both the route and duration of exposure are considered. Exposure to 

multiple sources that are expected to co-occur are also considered in the aggregate risk estimate. 

In this case, preliminary results from the REJV survey were used to further refine the aggregate 

assessment. Again, the REJV survey is a 12-month longitudinal survey that examined pesticide 

22
use in a residential environment. The data evaluated by the Agency in this analysis were 

information collected in 2001 and 2002. 

The following scenarios were aggregated: 

o Acute: food + drinking water 

o Short-term 

o Food + drinking water + (lawn care and post-application vegetable garden) 

o Food + drinking water + (U.S. Population: handler lawn care and postapplication indoor surface spray on carpet) 

o Food + drinking water + (U.S. population: handler lawn care and post-application 

vegetable garden) 

o Food + drinking water + (Females 13-49: handler lawn care and post-application 

indoor surface spray on carpet) 

o Food + drinking water + (Females 13-49: handler lawn care and post-application 

indoor surface spray on carpet) 

o Food + drinking water + (Toddler: post-application lawn and post-application 

indoor surface spray on carpet) 

o Food + drinking water + (Toddler: post-application lawn and post-application 

indoor surface spray on vinyl) 

o Food + drinking water + (Toddler: post-application lawn and post-application pet 

shampoo) 

o Long-term (chronic): food + drinking water 

o Cancer 

o Food + drinking water + (U.S. Population: handler lawn care and postapplication vegetable garden) 

o Food + drinking water + (U.S. Population: handler lawn care and postapplication indoor surface spray on carpet) 

A technical registrant submitted an aggregate assessment for permethrin conducted with 

CARES (Cumulative and Aggregate Risk Evaluation System), a software program which 

performs single chemical, aggregate, and cumulative (multichemical) exposure and risk 

assessments. In the submission, exposures through food, drinking water, and residential 

pathways were assessed. The Agency reviewed and evaluated the CARES submission with 

respect to the internal guidelines and standard operating procedures for submission of 

probabilistic assessments. The Agency’s review particularly focused on the residential pathways 

of exposure as these exposures were the main driver in the Agency’s non-cancer deterministic 

aggregate assessment. Overall, the Agency concluded that the assessment submitted selected 

reasonable input parameters to estimate exposure to permethrin from the food and residential 

pathways. However, the CARES assessment does not reflect the revised EDWC developed in 

the Second Revision Tier II Estimated Drinking Water Concentrations of Permethrin, dated 

January 19, 2006, and instead relied on the EDWC developed from the State of Maine potato 

scenario in Tier II Estimated Drinking Water Concentrations of Permethrin, dated July 16, 2004. 

Both documents are available in the public docket. The CARES assessment only considered 

acute aggregate and short-term aggregate risks, and not cancer aggregate risks, and is discussed 

in more detail in the Acute Aggregate Risk and Short-Term Aggregate Risk sections below. 

23
a. Acute Aggregate Risk 

The acute aggregate risk estimate includes the contribution of risk from dietary (food + 

drinking water sources) only. Acute aggregate risk estimates from exposures to food and 

drinking water, associated with the use of permethrin, do not exceed the Agency’s level of 

concern (<100% aPAD). The estimated acute dietary risk for the general U.S. population is 4% 

of the aPAD, and 16% of the aPAD for infants, the highest exposed population subgroup (see 

Table 5). 

The CARES assessment reported dietary (food only) exposures (on a mg/kg per capita 

basis) and MOEs corresponding to the 99.9 percentile for both children 1-2 and adults 20-49. 

For children 1-2 years old, the CARES assessment reported food only exposures at the 99.9th 

percentile of 0.0269 mg/kg (equivalent to an MOE of 929). For adults 20-49, the food only 

exposures at the 99.9th percentile were 0.0107 mg/kg (equivalent to an MOE of 2,332). The 

CARES assessment also reported drinking water exposures (on a mg/kg per capita basis) and 

MOEs corresponding to the 99.9 percentile for both children 1-2 and adults 20-49. For children 

1-2 years old, the drinking water exposures at the 99.9th percentile were 0.000749 mg/kg 

(equivalent to an MOE of 33,391). For adults 20-49, the CARES assessment reported drinking 

water exposures at the 99.9th percentile of 0.000447 mg/kg (equivalent to an MOE of 55,932). 

Again, these results do not reflect the results presented in the Second Revision Tier II Estimated 

Drinking Water Concentrations of Permethrin, dated January 19, 2006. 

b. Short-Term Aggregate Risk 

Aggregate short-term (1-30 days) risk estimates include the contribution of risk from 

chronic dietary sources (food + drinking water) and short-term residential sources. There are a 

number of exposure scenarios that could be aggregated. According to the preliminary results of 

the REJV survey, uses on lawns and on indoor crack and crevice sites account for the most use in 

the residential market place. For this assessment, the Agency used the REJV survey to 

determine the likelihood of a co-occurrent application scenario. 

For adult aggregate short-term risk, chronic food and drinking water exposures for the 

U.S general population and for females 13-49 years of age were combined with residential 

handler and post-application exposures. Residential handler dermal and inhalation exposures for 

mixing/loading/applying EC formulated products with a low pressure handwand to lawns were 

combined with post-application exposures (dermal) for vegetable gardens. Residential handler 

dermal and inhalation exposures for mixing/loading/applying EC formulated products with a low 

pressure handwand to lawns were also combined with post-application exposures (dermal) for 

indoor carpet surface sprays. 

To assess short-term aggregate risks for toddlers, chronic food and drinking water 

exposures for children 1-2 years of age were added to three separate combinations of postapplication residential exposure scenarios that are likely to occur for toddlers, based on the REJV 

survey. These scenarios include 1) hand-to-mouth activity and dermal contact to lawns and 

indoor carpets; 2) hand-to-mouth activity and dermal contact to lawns and indoor vinyl floor 

24
sprays; and 3) hand-to-mouth activity and dermal contact to lawns and pets. 

Table 12 summarizes the short-term aggregate risks to the general U.S. population, adult 

females (13-49), and toddlers. With the exception of post-application exposure of toddlers to 

treated lawns and indoor surfaces (carpets), the combined residues of permethrin from food, 

drinking water, and other potential residential exposures do not result in short-term aggregate 

risks of concern to population subgroups (MOEs >100). 

Table 12: Estimated Short-Term Aggregate Risk for Permethrin [Dietary (food + drinking water) and 

Residential Exposures] 

Population 

Residential Scenarios 

Included in the 

Aggregate 

Short-Term Exposure 

EPA’s 

Aggregate 

LOC 

MOE 

food + 

water 

MOE 

incid. 

oral 

MOE 

dermal 

MOE 

inhalation 

Aggregate MOE 

(dietary and 

residential) 

U.S Pop 

Lawn care, Postapp 

Vegetable 

100 210,000 NA 

4,200 1,000,000 4,100 

Lawn Care, Postapp 

Indoor Surface Spray 

on Carpet 

120 1,000,000 120 

Adult 

Female 

 (13-49) 

Lawn care, Postapp 

Vegetable 

100 220,000 NA 

4,200 1,000,000 4,100 

Lawn Care, Postapp 

Indoor Surface Spray 

on Carpet 

120 1,000,000 120 

Toddler 

(1-2) 

Post-App Lawn 

Care, Post-App 

Indoor Surface Spray 

on Carpet 

100 88,000 37 69 NA 24 

Post-App Lawn care, 

Post-App Indoor 

surface Spray on 

Vinyl 

100 88,000 150 440 NA 110 

Post-App Lawn 

Care, Post-App Pet 

Shampoo 

100 88,000 350 6,000 NA 330 

The aggregate assessment considers the highest exposure, by route, from each scenario 

included. For example, for the aggregate assessment for toddlers, this considers post-application 

exposure from treated lawns and indoor surface sprays, the highest exposures result from the 

indoor surface sprays on carpet and vinyl. Therefore, the exposures from the indoor surface 

sprays are driving the aggregate risk estimates. For a detailed discussion of the short-term 

aggregate risk assessment and the REJV co-occurrence matrix, please refer to Permethrin. Fifth 

Revision of the HED Chapter of the Reregistration Eligibility Decision Document, dated April 4, 

2006. 

The CARES assessment estimated residential exposures (on a mg/kg per capita basis) and 

MOEs corresponding to the 99.9th percentile for both children 1-2 and adults 20-49 based on the 

11 residential scenarios reported in the REJV survey data, including indoor and outdoor use. For 

more detail on the input parameters used in the residential CARES assessment, refer to 

Permethrin: Review of Valent BioSciences Corporation’s CARES Aggregate Submission entitled 

“Preliminary Evaluation of Potential Aggregate Human Health Risks Associated with 

25
Agricultural and Consumer Uses of Permethrin”, dated June 21, 2005, which is available in the 

public docket. 

The residential portion of the CARES assessment relied extensively upon the data from 

the REJV survey. Based on the information collected under the REJV and the scenarios used in 

the Agency’s human health risk assessment, the CARES assessment included 15 residential uses 

[including lawn care operator/pest control operator (LCO/PCO) applications] for permethrin 

including lawn and vegetable garden care, wasp and hornet control, indoor crack and crevice 

treatments, termite treatments, pet care, indoor and outdoor fogger, indoor flying insect 

knockdown aerosols, impregnated clothing, indoor carpet aerosols, and public health mosquito 

control. The Agency verified that these scenarios are of most interest with respect to high-end 

exposures and most relevant for inclusion in the residential portion of an aggregate probabilistic 

risk assessment. 

For children 1-2 years old, the CARES assessment reported exposures at the 99.9th 

percentile of 0.801 mg/kg (equivalent to an MOE of 624). For adults 20-49, the CARES 

assessment reported exposures at the 99.9th percentile of 0.337 mg/kg (equivalent to an MOE of 

1484). These estimates are expressed on a per capita basis, i.e., all individuals (or all exposuredays) are considered and not just those individuals (or exposure days) on which an actual 

application occurs. This is a fundamental difference between the residential assessment 

calculations performed by the EPA in its assessment, in accordance with the Agency’s standard 

operating procedures, and those performed in the CARES submission. The residential exposure 

estimates calculated by the Agency reflect exposure estimates to a user on the day of application, 

whereas those represented in the CARES assessment apply to all individuals (i.e., whether they 

are users or not, and on all days, and whether permethrin was used or not). The two methods of 

expressing risk cannot be considered directly comparable, but should rather be seen as two 

alternate ways in which exposures can be viewed. The Agency’s short-term aggregate 

assessment is more conservative and is, therefore, relied upon in this document. 

c. Intermediate-Term & Long-Term Aggregate Risk 

All residential/recreational exposures are expected to be short-term (1-30 days) in 

duration. Therefore, no intermediate-term (1-6 months) aggregate risk was assessed. Moreover, 

because labeled uses indicate no long-term (>6 months) or chronic residential or other nonoccupational exposures, chronic aggregate risk estimates include exposures from food and 

drinking water sources only. As indicated in Table 5, chronic aggregate risk, associated with the 

use of permethrin, do not exceed the Agency’s level of concern for the U.S. population and all 

population subgroups (all populations were less than 1% of the cPAD). 

d. Cancer Risk 

Cancer food and drinking water exposures for the U.S. general population were combined 

with residential handler and post-application exposures similar to the short-term aggregate risk 

assessment. Residential handler dermal and inhalation exposures for mixing/loading/applying 

EC formulated products with a low pressure handwand to lawns were combined, by exposure 

route, with post-application exposures (dermal) for vegetable gardens. Residential handler 

26
dermal and inhalation exposures for mixing/loading/applying EC formulated products with a low 

pressure handwand to lawns was also combined, by exposure route with post-application 

exposures (dermal) for indoor carpet surface sprays. 

Table 13 summarizes the cancer aggregate risk estimates associated with the use of 

permethrin. With the exception of exposure to indoor carpet sprays, the Agency can conclude 

that combined exposures to residues of permethrin from food, drinking water, and other potential 

residential use scenarios are within the negligible risk range of ≤3 x 10-6 and do not result in 

cancer aggregate risks of concern. 

Table 13: Estimated Permethrin Cancer Aggregate Risk 

Population 

Residential Scenarios 

Included in Aggregate 

Cancer Risk from 

Dietary 

Cancer Risk from 

Residential 

Aggregate Cancer 

Risk (Dietary and 

Residential) 

U.S. Pop 

Lawn Care, Postapp 

Vegetable 1.1 x 10-6 

4.3 x 10-7 1.5 x 10-6 

Lawn Care, Postapp Indoor 

Surface Spray on Carpet 1.4 x 10-5 1.5 x 10-5 

Similar to the short-term aggregate risk assessment, the aggregate cancer assessment 

considers the highest exposure from each scenario included. For a detailed discussion of the 

aggregate cancer risk assessment and the REJV co-occurrence matrix, please refer to Permethrin. 

Fifth Revision of the HED Chapter of the Reregistration Eligibility Decision Document, dated 

April 4, 2006. 

e. Permethrin Pesticide and Pharmaceutical Use Co-Exposure 

Assessment 

As indicated above, in determining the risk to human health, the Agency examines more 

than just dietary exposures. Section 408 of FFDCA requires EPA to consider potential sources 

of exposure to a pesticide in addition to the dietary sources expected to result from a pesticide 

use subject to the tolerance. In order to determine whether to maintain a pesticide tolerance, 

EPA must “determine that there is a reasonable certainty of no harm. . . .” Under FFDCA 

section 505, the Federal Drug Administration reviews human drugs for safety and effectiveness 

and may approve a drug notwithstanding the possibility that some patients may experience 

adverse side effects. EPA does not believe that, for purposes of the section 408 dietary risk 

assessment, it is compelled to treat a pharmaceutical patient the same as a non-patient, or to 

assume that combined exposures to pesticide and pharmaceutical residues that lead to a 

physiological effect in the patient constitutes “harm” under the meaning of section 408 of the 

FFDCA 

Rather, EPA believes the appropriate way to consider the pharmaceutical use of 

permethrin in its risk assessment is to examine the impact that the additional non-occupational 

pesticide exposures would have to a pharmaceutical patient exposed to a related (or, in some 

cases, the same) compound. Where the additional pesticide exposure has not more than a 

minimal impact on the pharmaceutical patient, EPA could make a reasonable certainty of no 

harm finding for the pesticide tolerances of that compound under section 408 of the FFDCA. If 

the potential impact on the pharmaceutical user as a result of co-exposure from pesticide use is 

27
more than minimal, then EPA and FDA could discuss appropriate measures to reduce exposure 

from one or both sources. The Agency provided its findings with respect to permethrin to FDA 

in a letter dated August 10, 2005, which is available on the public docket (EPA-HQ-OPP-2004­

0385). 

The exposure estimates used in the determination of permethrin pharmaceutical and 

pesticide co-exposure assessment, attachments A and B to the August 10, 2005 letter referenced 

above, reflect the external dermal dose of permethrin a patient treated with a pharmaceutical 

permethrin product would receive in a reasonable worst-case scenario. EPA’s pesticide exposure 

assessment has taken into consideration the appropriate population, exposure route, and exposure 

duration for comparison with exposure to the pharmaceutical use of permethrin. Using the 

permethrin 1% and 5% registered pharmaceutical labels, EPA estimated exposure from a typical 

treatment of both products, and compared those to the potential exposure an individual would 

receive from the pesticide uses of permethrin. Because the permethrin 1% and 5% creams are 

used over a 10 minute period and an 8 - 14 hour period, respectively, EPA considers the 

pharmaceutical use as a short-term exposure. To estimate combined pesticide exposure for a 

short-term scenario, EPA integrated average dietary exposure estimates (food + drinking water) 

with one of the non-occupational exposure scenarios (i.e. post-application to permethrin treated 

residential lawns). EPA chose the treated residential lawn exposure scenario because this 

application is a reasonable high-end scenario, and the REJV survey data showed this use to be 

among the most frequent exposure scenarios. 

EPA estimates that the permethrin exposure a patient is expected to receive from a typical 

single application of Nix (1%) and Elimite (5%) creams, respectively, is 450 to 2300 times 

greater than the combined exposure from the dietary and other non-occupational sources of 

permethrin. FDA has reviewed these estimates and determined that pesticide exposure in 

patients receiving treatment with a pharmaceutical permethrin drug product would fall within the 

expected range of exposure following treatment with permethrin drug product alone, and would 

not present an increased safety risk. 

8. Occupational Exposure and Risk 

Workers can be exposed to a pesticide through mixing, loading, and/or applying the 

pesticide, or re-entering a treated site. For dermal and inhalation exposures, worker risk is 

estimated by a Margin of Exposure (MOE) which determines how close the occupational 

exposure comes to the No Observed Adverse Effect Level (NOAEL) selected from animal 

studies. Please see Table 3 for the toxicological endpoints used in the permethrin occupational 

assessment. The risk assessment for short-term (1-30 days) and intermediate-term (1-6 months) 

occupational exposures are similar because the toxicity endpoints (NOAELs) are numerically the 

same, and the target MOE of 100 is the same for both durations. Based on the registered use 

patterns of permethrin, long-term (> 6 months) handler exposure is not expected to occur for 

permethrin. The dermal and inhalation risks were combined for all scenarios assessed because 

the adverse effects for the dermal and inhalation routes of exposure were the same 

(neurotoxicity). Since permethrin is currently classified as a “likely to be carcinogenic to 

humans,” the Agency assessed both cancer and non-cancer risks for occupational handlers and 

post-application workers. A dermal absorption factor of 15% was used for the dermal 

28
component of the cancer equation for the cancer risk assessment. 

For permethrin, MOEs that are greater than 100 and cancer risks within the range of an 

increased cancer risk of 1 x 10-6 generally do not exceed the Agency’s level of concern. 

However, when occupational MOEs are less than 100 or occupational cancer risks exceed 1 x 

10-6, EPA strives to reduce worker cancer risks through the use of personal protective equipment 

and engineering controls. The Agency generally considers occupational cancer risks within the 

range of 1 to 3 x 10-6 (approximately 1-3 in 1 million persons) or less to be negligible, but will 

consider risks as high as 1 x 10-4 (1 in 10,000 persons) when all mitigation measures that are 

practical and feasible have been applied and when there are critical pest management needs 

associated with the use of the pesticide. 

a. Occupational Handler Exposure and Risk 

Exposure to permethrin by pesticide handlers (mixers, loaders, applicators and flaggers) 

is likely during the use of permethrin based on the type of equipment and techniques that can 

potentially be used. Thirty-nine occupational exposure scenarios were assessed based on 

registered labels, equipment, and techniques that could be used for permethrin applicators. Due 

to the scope of the various permethrin occupational uses (there are over 900 registered 

permethrin products), it would be difficult to assess each individual exposure scenario. 

Therefore, the following selected scenarios are representative of the worse-case exposure 

scenarios to represent the major ways permethrin can be handled in the occupational 

environment. The scenario numbers correspond to the non-cancer and cancer risk estimate tables 

presented in the Permethrin: Third Revision of the Occupation and Residential Exposure 

Assessment for the Reregistration Eligibility Decision Document, dated April 4, 2006. Scenarios 

denoted with a “*” could not be evaluated quantitatively because applicable unit exposure data 

are not available; however, the Agency believes other assessed scenarios are protective of these 

specific, and specialized, uses. 

Mixer/Loaders: 

1a Liquids for Aerial Applications; 

1b Liquids for Groundboom Applications; 

1c Liquids for Airblast Applications; 

1d Liquids for Truck Mounted ULV Applications; 

1e Liquids for Dip Applications; 

1f Liquids for Residential Mister Systems; 

2a Wettable Powder for Aerial Applications; 

2b Wettable Powder for Groundboom Applications; 

2c Wettable Powder for Airblast Applications; 

2d Dusts for Mechanical Duster Applications (using PHED WP mixer/loader data); 

2e Dusts for Dust Bag Applications (using PHED WP mixer/loader data); 

3a Granulars for Aerial Applications; 

3b Granulars for Tractor Drawn Spreader Applications 

Applicators: 

4 Aerial Applications (Sprays); 

29
5 Groundboom Applications; 

6 Airblast Applications; 

7 Truck Mounted ULV Applications; 

8 Dip Applications*; 

9 Aerial Applications; 

10 Tractor Drawn Spreader Applications (Granulars); 

11 Mechanical Duster Applications*; 

12 Dust Bag Applications*; 

Flaggers: 

13 Flagging for Aerial-Sprays; 

14 Flagging for Aerial-Granulars; 

Mixing/Loading/Applicators: 

15 Liquid: Low Pressure Handwand Sprayer: 

16 Liquid: Handgun Sprayer; 

17 Liquids: High Pressure Handwand Sprayer; 

18 Liquid: Termite Injector; 

19 Liquid: Foam Applicator Equipment (using ORETF low pressure handwand 

data); 

20 Liquid: Watering Can (using ORETF residential hose end sprayer data); 

21 Liquid: Backpack ULV Sprayer (using ORETF low pressure handwand data); 

22 Liquid: Paint Brush; 

23 Liquid: Cold Fogger*; 

24 Wettable Powder: Low Pressure Handwand Sprayer; 

25 Wettable Powder: Handgun Sprayer; 

26 Wettable Powder: High Pressure Handwand Sprayers*; 

27 Water Soluable Bag: Handgun Sprayer; 

28 Wettable Powder: Cold Fogger*; 

29 Dusts: Shaker Cans; 

30 Liquid: Fogger/Mister Generator*; 

31 RTU: Liquid: Pour On Applications (using PHED mixing/loading liquid data); 

32 RTU: Ear Tag Applications*; 

33 RTU: Hand Applications (Shampoos)*; 

34 RTU: Wipe Applications*; 

35 RTU: Trigger Pump Sprayer Applications; 

36 RTU: Aerosol Cans; 

37 RTU: Fogger (using PHED aerosol can data); 

38 RTU: Protective Flanges*; 

39 RTU: Vapor Recovery Systems Tubes*. 

The level of personal protective equipment (PPE) varies on the numerous permethrin 

labels. Some labels only require the minimum level of PPE, while others require additional PPE, 

such as chemical-resistant gloves, respirators, etc., depending on the labeled handler activity. 

Therefore, the Agency considered the following levels of PPE or engineering controls in the 

30
occupational non-cancer and cancer exposure assessments: 

• Baseline, or long-sleeve shirt, long pants, no gloves, and no respirator. (Baseline) 

• Baseline plus chemical-resistant gloves, and no respirator. (PPE-G-NR) 

• Coveralls worn over long-sleeve shirt and long pants, chemical-resistant gloves, and 

no respirator. (PPE-G-DL-NR) 

• Baseline plus chemical-resistant gloves and an 80% PF (quarter-face dust/mist) 

respirator. (PPE-G-80%R) 

• Coveralls worn over long-sleeve shirt and long pants, chemical-resistant gloves, and 

an 80% PF (quarter-face dust/mist) respirator. (PPE-G-DL-80%R) 

• Engineering Controls, or closed mixing/loading system, enclosed cab, or enclosed 

cockpit. (EC) 

No chemical-specific information was available for permethrin handler exposure 

assessments. Therefore, the Agency used the Pesticide Handler Exposure Database (PHED, 

Version 1.1, 1998) data, as well as acceptable surrogate exposure data, to calculate unit exposure 

values to estimate occupational handler exposures to permethrin for each scenario assessed. 

For each of the 39 handler scenarios above, the Agency considered numerous crops or 

target use sites with various application rates and area treated daily to reflect the way in which 

permethrin can be applied (approximately 200 various use patterns were assessed). Additionally, 

due to the broad spectrum use of permethrin, the Agency believes that occupational exposure can 

occur over a single day or up to a week’s time for many use-patterns, and intermittent exposure 

over several weeks are also anticipated. Therefore, the non-cancer risk assessment considers 

both short- (1-30 days) and intermediate-term (1-6 months) exposure to permethrin, and dermal 

and inhalation exposures are combined. 

Non-Cancer Risks

 The majority of the non-cancer risk estimates were below the Agency’s level of concern, 

MOEs ranged from 120 to 200 million, when baseline PPE and chemical-resistant gloves were 

applied and are, therefore, not tabulated in this document; however, six of the approximately 200 

use patterns assessed required additional PPE before the risk estimates were below the Agency’s 

LOC and are listed in Table 14. The number next to each scenario corresponds to the handler 

scenarios listed above, and the non-cancer risk estimate tables and calculations in the 

Permethrin: Third Revision of the Occupation and Residential Exposure Assessment for the 

Reregistration Eligibility Decision Document, dated April 4, 2006, which is available in the 

public docket. 

Table 14. Summary of Permethrin Non-Cancer Handler Risk Estimates Requiring PPE greater than Baseline and 

Gloves 

Exposure Scenario Crop or Use Max. 

Application 

Rate 

Max. 

Area 

Treated 

Daily 

Baseline PPEG-NR PPEG-DLNR PPEG80%R PPEG-DL80%R EC 

Mixer/Loader (M/L) 

M/L Wettable Powder 

(WP) for Aerial 

Corn: Sweet (FL 

only) 

0.25 lb ai/A 1200 acres 21 55 56 650 840 ND 

31
Table 14. Summary of Permethrin Non-Cancer Handler Risk Estimates Requiring PPE greater than Baseline and 

Gloves 

Exposure Scenario Crop or Use Max. 

Application 

Rate 

Max. 

Area 

Treated 

Daily 

Baseline PPEG-NR PPEG-DLNR PPEG80%R PPEG-DL80%R EC 

Mixer/Loader (M/L) 

Application (2a) Alfalfa, corn (field, 

pop, seed, sweet), 

corn: field 

(preplant), range 

grasses, soybeans 

0.2 lb ai/A 1200 acres 26 69 70 820 1100 ND 

Loading Dusts via 

Mechanical Duster 

(2d) 

Animal: poultry 0.0025 lb 

ai/animal 

100000 

animals 

25 66 67 780 1000 ND 

Mixer/Loader/Applicator (M/L/A) 

M/L/A WP via Low 

Pressure Handwand 

(24) 

Conifer: field grown 0.2 lb ai/gal 40 gal ND 75 78 500 680 NF 

M/L/A Emulsifiable 

Concentrates via Cold 

Fogger (23) 

Mushroom Houses 0.0078 lb ai/ 

sq ft 

40000 sq 

ft 

(8000 sq ft 

per house) 

ND ND 4000* ND ND ND 

Indoor Spaces 0.00036 lb 

ai/cu ft 

200000 cu 

ft 

ND 35000* ND ND ND ND 

ND= No Data 

NF= Not Feasible 

*The exposure data used in the risk assessment (Nigg, 1987) reflect the dermal and respiratory exposure from the use of hand 

held backpack foggers in a greenhouse. The applicators in this study were wearing chemical resistant protective clothing 

(Tyvek coveralls) over long sleeve shirt and long pants, gloves, boots, and goggles. 

Four of the scenarios, wettable powder and dust formulations, in Table 14 require 

baseline PPE with chemical-resistant gloves and respirator (PPE-G-80%R) to be worn by 

workers before the estimated MOEs are >100 and are, therefore, below the Agency’s LOC at this 

level of PPE. The two emulsifiable concentration scenarios with a ULV cold fogger applicator 

are below the Agency’s LOC with double layer PPE. 

Cancer Risks 

The occupational handler cancer risk assessment considered the same use patterns 

(approximately 200) for each handler activity listed above. Based on EPA information, it is 

assumed that all handlers (small, medium, and large scale growers, as well as commercial 

applicators) would handle permethrin approximately 10 days per year. In addition, a 35-year 

career and a 70-year life span were considered in the cancer risk estimate calculations. PPE and 

engineering controls were also evaluated in the assessment. 

The estimated cancer risks for the majority of grower scenarios are also within the 

negligible risk range (≤3 x 10-6) or less with baseline PPE and gloves and were, therefore, below 

the Agency’s LOC and not tabulated in this document. However, 45 of the approximately 200 

use patterns assessed results in risk in the 10-5 to 10-6 range at this level of PPE, and either 

require additional PPE before the cancer risk estimates are below the negligible risk range of ≤3 

x 10-6, have no data available to estimate risk ,or further mitigation measures are not feasible. 

Table 15 below presents the predicted cancer risk estimates for these scenarios at the baseline 

PPE and gloves, and lists the required level of PPE at which the cancer risk estimate reaches the 

32
negligible risk range. The handler scenarios are grouped by formulation, and, again, the number 

next to each scenario corresponds with handler scenarios listed in the section above. 

Table 15: Permethrin Occupational Handler Cancer Risk Estimates Between 10-4 and 10-6 

Exposure Scenario Use Site Application 

Rate 

Area Treated 

Daily or 

Amount 

Applied per 

Day 

Baseline PPE 

& Gloves 

PPE to Reach 

LOC 

Wettable Powders 

Mixing/loading Wettable 

Powder for Aerial 

Applications (2a) 

Pine seed orchard 1.2 lb ai/A 100 acres 1.50x10-5 EC 

almonds, apples, filberts, pears 

(dormant & pre-bloom combo), 

pistachios, walnuts 0.4 lb ai/A 350 acres 1.80x10-5 EC 

artichokes, garlic, nectarines, onion: 

dry: bulb, peaches 0.3 lb ai/A 350 acres 1.30x10-5 EC 

Corn: sweet (FL only) 0.25 lb ai/A 1200 acres 3.80x10-5 EC 

Corn: sweet (FL only) 0.25 lb ai/A 350 acres 1.10x10-5 EC 

alfalfa, corn (pop, field, seed, sweet), 

corn: field (preplant), range grasses, 

soybeans 0.2 lb ai/A 1200 acres 3.10x10-5 EC 

Cabbage, Chinese cabbage, corn (pop, 

seed, sweet), cucurbits, eggplant, leafy 

vegetables, peppers: bell, potatoes, 

tomatoes, tomatillos 

0.2 lb ai/A 350 acres 9.00x10-6 EC 

asparagus, broccoli, Brussels sprouts, 

cauliflower, Chinese broccoli, collards 

0.1 lb ai/A 350 acres 4.50x10-6 PPE-G-80%R 

Mixing/loading Wettable 

Powder for Groundboom 

(2b) 

corn: sweet (FL only) 0.25 lb ai/A 200 acres 6.40x10-6 

PPE-G-DL80%R 

alfalfa, corn (pop, field, seed, sweet), 

corn: field (preplant), range grasses, 

soybeans 0.2 lb ai/A 200 acres 5.1x10-6 PPE-G-80%R 

Mixing/loading/applying 

Wettable Powder with Low 

Pressure Handwand (24) 

Conifers (field grown) 0.2 lb 

ai/gallon 40 gallons 3.60x10-5 PPE-G-DL 

Mixing/loader/applying 

Wettable Powder with a 

Handgun Sprayer (25) 

confier (field grown) 0.2 lb 

ai/gallon 40 gallons 6.40x10-5 PPE-G-DL 

rose: field grown 

0.02 lb 

ai/gallon 40 gallons 6.40x10-6 PPE-G-DL 

Mixing/loading/applying 

Water Soluable Bags with 

Handgun Sprayer (27) 

Chrysanthemum 0.005 lb 

ai/gallon 1000 gallons 4.10x10-6 PPE-G-DL 

rose: greenhouse, ornamental nursery 

stock (non-bearing) 

0.002 lb 

ai/gallon 1000 gallons 4.10x10-5 PPE-G-DL 

Mixing/loader/applying 

Wettable Powder with a High 

Pressure Handwand (26) 

rose: field grown 

0.02 lb 

ai/gallon 1000 gallons ND ND 

Chrysanthemum 0.005 lb 

ai/gallon 1000 gallons ND ND 

rose: greenhouse 0.002 lb 

ai/gallon 1000 gallons ND ND 

33
Table 15: Permethrin Occupational Handler Cancer Risk Estimates Between 10-4 and 10-6 

Exposure Scenario Use Site Application 

Rate 

Area Treated 

Daily or 

Amount 

Applied per 

Day 

Baseline PPE 

& Gloves 

PPE to Reach 

LOC 

Mixing/loader/applying 

Wettable Powder with via 

Cold Fogger (28) 

mushroom houses 0.0078 lb ai/ 

sq ft 

40000 sq ft 

(8000 sq ft per 

house) 1.2x10-6 PPE-G-DL 

Indoor surfaces 0.00036 lb 

ai/cu ft 200000 cu ft 2.8x10-7 PPE-G-DL 

Emulsifiable Concentrate (EC) 

Applying EC via dip (8) 

animal: livestock (beef and dairy 

cattle), horses, swine 

0.0023 lb 

ai/animal 400 animals ND ND 

animal: dogs 0.005 lb 

ai/dog 10 gallons ND ND 

Military battle dress 

0.0000011 lb 

ai/cm2 of 

fabric ND ND 

Mixing/loading/applying EC 

with a handgun sprayer (16) 

Conifers (field grown) 0.2 lb 

ai/gallon 1000 gallons 2.80x10-5 NF 

perimeter treatment 0.08 lb 

ai/gallon 500 gallons 5.5x10-6 PPE-G-DL 

ornamental: outdoor 0.046 lb 

ai/gallon 1000 gallons 6.30x10-6 

PPE-G-DL80%R 

Mixing/loading/applying EC 

with low pressure handwand 

(15) 

Termites 

33.2 lb 

ai/1000 linear 

feet 

1000 linear 

feet 5.90x10-6 

PPE-G-DL90%R 

Mixing/loading/applying EC 

with a high pressure 

handwand (17) 

rose: field grown 0.02 lb 

ai/gallon 1000 gallons 1.90x10-5 PPE-G-DL 

agricultural premises 0.012 lb 

ai/gallon 1000 gallons 1.10x10-5 PPE-G-DL 

Chrysanthemum 0.005 lb 

ai/gallon 1000 gallons 4.60x10-6 PPE-G-DL 

animal: poultry 0.00027 lb 

ai/animal 4000 gallons 2.50x10-5 PPE-G-DL 

Mixing/loading/applying EC 

Liquids via Fogger/Mist 

Generator (30) 

Animal premises 0.012 lb 

ai/1000 sq ft. 1000 sq ft ND ND 

indoor spaces 0.00036 lb 

ai/1000 cu ft. 1000 cu ft ND ND 

Mixing/loading/applying EC 

with an injector (18) Termites 0.08 lb ai/gallon 2000 gallons 1.70x10-5 PPE-G-DL 

Dust Formulation 

Applying Dusts via 

Mechanical Duster (11) 

animal : dairy and beef cattle, horses 0.000031 lb 

ai/animal 400 animals ND ND 

animal : poultry 0.0025 lb 

ai/animal 

100,000 

animals ND ND 

animal: swine .00016 lb 

ai/animal 400 animals ND ND 

Applying Dusts via Dust Bag 

(12) animal : dairy and beef cattle, horses 0.000031 lb 

ai/animal 400 animals ND ND 

34
Table 15: Permethrin Occupational Handler Cancer Risk Estimates Between 10-4 and 10-6 

Exposure Scenario Use Site Application 

Rate 

Area Treated 

Daily or 

Amount 

Applied per 

Day 

Baseline PPE 

& Gloves 

PPE to Reach 

LOC 

animal: swine .00016 lb 

ai/animal 400 animals ND ND 

Loading Dusts via 

Mechanical Duster (2d) ­

using PHED data for WP 

animal: poultry 0.0025 lb 

ai/animal 

100000 

animals 3.20x10-5 NF 

Applying ready to use 

formulations via RTU Ear 

Tag (32) 

Animal 0.0044 lb ai/2 

ear tags 

400 cattle (2 

tags/cattle) ND ND 

Applying RTU formulations 

via hands (33) animal: dogs 0.0062 lb 

ai/animal 8 animals ND ND 

Applying RTU formulations 

via wipes (34) animal: dogs, horses 0.0062 lb 

ai/animal 8 animals ND ND 

Applying RTU formulations 

via Protective Flanges (38) Ants ND ND ND ND 

Applying RTU Vapor 

Recovery Systems (39) Engines 0.000189 lb 

ai/tube ND ND ND 

ND= No Data 

NF= Not feasible to reach 10-6 range with highest level of PPE. 

None of the occupational handler scenarios assessed in Table 15, for which there is 

available exposure data, have non-cancer MOEs <100 or cancer risks estimates greater than 1 x 

10-4 at some level of PPE. Further, most cancer risk estimates are less than 1 x 10-6 with some 

level of PPE. However, there are several occupational scenarios that the Agency was unable to 

assess due to lack of data. The Agency believes that other scenarios assessed are appropriate 

surrogates for some of these uses. In other cases, where the use is specialized and/or the Agency 

does not believe other scenarios assessed are an appropriate surrogate for the use, the Agency 

will require additional data. 

b. Occupational Post-Application Exposure and Risk 

The Agency uses the term “post-application” to describe exposures to individuals that 

occur as a result of being in an environment that has been previously treated with a pesticide 

(also referred to as reentry exposure). There are distinct job functions or tasks related to the 

kinds of activities that occur in previously treated areas. Job requirements (e.g., the kinds of jobs 

to cultivate a crop), the nature of the crop or target that was treated, and the degradation of 

residues in the environment can cause exposure levels to differ over time. Each factor has been 

considered in this assessment. Additionally, the EPA considered post-application risks for both 

agricultural scenarios and impregnated clothing scenarios. 

i. Agricultural Scenarios 

To assess post-application exposures and risks, the Agency estimates the amount of 

contact with a treated surface a worker likely would have while doing a specific post-application 

task or activity, such as hand harvesting, conducting scouting activities, crop maintenance tasks 

35
(e.g., irrigating, hoeing and weeding), and turf maintenance. To determine the amount of postapplication exposure for each crop and post-application activity, the EPA used dislodgeable 

foliar residue (DFR) and turf transferable residue (TTR) data in the post-application risk 

assessment. The Agency’s standard transfer coefficients were also used to assess worker reentry 

exposures. EPA has received permethrin-specific post-application DFR data on cotton and 

peaches, as well as TTR data from treated turf. DFR data do not cover all crops treated with 

permethrin; therefore, the existing DFR data were extrapolated to the remaining crops by 

considering the effects of application method, crop type, and climate. 

Post-application exposures are calculated by multiplying the DFR or TTR concentrations 

and transfer coefficients factors by an 8 hour work day. Exposures are then normalized by body 

weight and adjusted for dermal absorption (if necessary) to calculate absorbed doses. Risk 

estimates were then calculated. Post-application risks diminish over time because permethrin 

residues eventually dissipate in the environment. As a result, risk values were calculated over 

time based on the specified retreatment interval and the changing residue levels over that time. 

Permethrin labels specify retreatment intervals as needed or 7 days, except for conifers grown for 

seed where the retreatment interval is 28 days. The risk assessment assumed the average foliar 

residue between 1 to 7 days for all crop scenarios, except conifer seed cone harvesting, which 

assumed an average foliar residue value between 1 to 28 days. 

The use of personal protective equipment or other types of equipment to reduce 

exposures for post-application workers is not considered a viable alternative for the regulatory 

process. This is described in some detail in EPA’s Worker Protection Standard (40CFR170). 

However, the Restricted-Entry Interval (REI) is an approach to reduce the risks. The REI is the 

required time period following a pesticide application during which entry into the treated area is 

restricted. The REI on current permethrin labels is 12 hours. 

EPA assessed the post-application exposure to permethrin to both hired hand and migrant 

agricultural workers. The Agency assumed growers and hired hands would perform postapplication activities 10 days per year and migrant workers would perform post-application 

activities 30 days per year. Inhalation exposures are thought to be negligible in outdoor postapplication scenarios, because of the low vapor pressure and due to the infinite dilution expected 

outdoors. As such, inhalation post-application exposures are not considered in this assessment. 

The Agency assessed 20 post-application crop scenarios, with various post-application activities 

or tasks associated with each crop scenario. 

For short- and intermediate-term post-application exposure, the target MOE is 100. For 

all agricultural post-application scenarios assessed, the non-cancer risks do not exceed the level 

of concern (MOEs > 100) on the day of application, approximately 12 hours following 

application. The MOEs range from 1,900 to 130,000 and are, therefore, not tabulated in this 

document. A summary of the results for each post-application crop/activity combination 

considered is detailed in the Permethrin: Third Revision of the Occupation and Residential 

Exposure Assessment for the Reregistration Eligibility Decision Document, dated April 4, 2006. 

As stated in the section above, the Agency generally considers occupational cancer risks 

within the range of 1 to 3 x 10-6 (approximately 1-3 in 1 million persons) or less to be negligible, 

36
but will consider risks as high as 1 x 10-4 (1 in 10,000 persons) when all mitigation measures that 

are practical and feasible have been applied and when there are critical pest management needs 

associated with the use of the pesticide. Most of the post-application cancer risk estimated for 

both hired hands and commercial/migratory farm workers are in the 10-5 to 10-7 range. The 

highest risk estimates, in the 10-4 range, are for conifer seed cone harvesting and thinning of 

certain fruit trees. Table 16 below summarizes the post-application scenarios for migratory 

workers that result in cancer risk estimates between 10-4 and 10-6. These present the worst case 

cancer risk estimates since the Agency assumed migratory workers are exposed to postapplication residues of permethrin for 30 days per year for 35 years. 

Table 16: Permethrin Occupational Post-Application Cancer Risk Estimates for Migrant Workers Between 10-4 and 

10-6 

Crop Activity 

Cancer Risk Estimate 

(30 days/yr for 35 yr) 

conifer seed orchard seed cone harvesting 1.90x10-4 

apples, pears 

thinning 9.60x10-5 

hand-weeding, irrigation, scouting 4.80x10-5 

almonds, filberts, pistachios, walnuts 

hand-harvesting, hand-pruning, 

propping, training 

4.80x10-5 

hand-weeding, irrigation, scouting 3.20x10-5 

cherries:sweet and sour, nectarines, 

peaches 

thinning 7.20x10-5 

hand-harvesting, hand-pruning 3.50x10-5 

hand-weeding, irrigation, scouting 2.40x10-5 

avocados, conifer (field grownchristmas trees), papayas 

thinning 4.80x10-5

 hand-pruning 2.40x10-5 

hand-weeding, scouting 1.60x10-5 

ornamentals hand-prunning 6.40x10-6 

alfalfa, soybeans 

hand-harvesting 9.10x10-6 

irrigating, scouting (full development) 5.40x10-6 

corn detasseling, hand-harvesting 6.20x10-5 

curbits hand-harvesting, hand-pruning 9.10x10-6 

irrigating, scouting 5.40x10-6 

onions: dry bulb, garlic 

hand-harvesting 

1.20x10-5 

hand-weeding, irrigating, scouting, 

thinning (min development) 8.20x10-6 

potatoes hand-harvesting 9.10x10-6 

37
Table 16: Permethrin Occupational Post-Application Cancer Risk Estimates for Migrant Workers Between 10-4 and 

10-6 

Crop Activity 

Cancer Risk Estimate 

(30 days/yr for 35 yr) 

hand-weeding, irrigating, scouting, 

thinning (full development) 5.40x10-6 

turnips hand-harvesting 4.50x10-6 

cabbage 

hand-harvesting, hand-pruning, 

irrigating 

1.80x10-5 

scouting 1.50x10-5 

hand-weeding 7.20x10-6 

broccoli, Brussels sprouts, cauliflower, 

Chinese broccoli 

hand-harvesting, hand-pruning, 

irrigating 9.10x10-6 

scouting 7.20x10-6 

hand-weeding 3.60x10-6 

collards hand-harvesting 4.50x10-6 

Chinese cabbage, leafy vegetables 

hand-harvesting 9.10x10-6 

irrigating, scouting, thinning (all at 

medium development) 5.40x10-6 

artichokes hand-harvesting, hand-pruning 5.40x10-6 

cut flowers cut roses 1.40x10-5

 ii. Impregnated Clothing Scenarios 

The Agency considered two different types of occupational post-application exposures to 

permethrin treated clothing: military personnel who wear battle dress impregnated with 

permethrin on a daily basis (i.e., approximately 250 days/year) and factory workers who work 

with fabric or clothing after impregnation during making of garments or packaging of clothing 

on a work-day basis (i.e., 250 days/year). 

Since both post-application occupational exposures are more than 180 days per year, the 

duration of exposure considered for this non-cancer assessment is long-term. The cancer 

assessment assumed that these populations would be exposed to permethrin from postapplication activities involving impregnated clothing 250 days per year. These assumptions are 

conservative in nature and were selected based on best professional judgment. Inhalation 

exposures are thought to be negligible for post-application scenarios involving exposure to 

permethrin-impregnated clothing, and as such, inhalation post-application exposures are not 

considered in this assessment. 

When assessing post-application exposures to impregnated clothing, EPA used the latest 

approaches to estimate the post-application exposures. The data required for estimating post38
application potential doses include the clothing residue concentration (assumed to be equivalent 

to the application rate on a mass per area basis, as determined from the label), surface area of the 

skin that is in contact with the fabric, the transfer factor, and the body weight. EPA estimated 

exposures to permethrin-impregnated clothing by considering exposure frequency and duration, 

as well as degree of contact. 

Dermal exposures to military personnel are based on the clothing contact surface area of 

adults exposed to permethrin-impregnated clothing (0.85 m2). This number is based on the 

assumption that military personnel wear briefs and undershirts underneath the battle dress and, 

therefore, the surface area of arms and legs (but not the torso) for an adult are used. Dermal 

exposures to garment workers are based on the contact surface area of adults exposed to 

permethrin impregnated clothing in a factory after the impregnation process (0.22 m2). This 

number is based on the hands and forearms of an adult garment worker. 

For the cancer assessment, risks were calculated for wearing impregnated military 

clothing calculated to have an average exposure level of 0.038 mg permethrin/cm2. This average 

was calculated by assuming the uniform is usable for up to 30 washes and that the first wash 

results in a 33% permethrin loss, the second wash results in a 6% permethrin loss, washes 3 

through 10 each result in a 3% permethrin loss, and washes 11 through 30 result in a total loss of 

6.5% permethrin (MRID 457519-02). It was also assumed that each individual would wear a 

uniform for 7 days before a washing event took place to take into account military personnel 

being in the field for extended periods of time. Further, the exposure durations for military 

personnel and garment workers were assumed to 10 and 35 years, respectively. 

All non-cancer post-application exposure scenarios for permethrin-impregnated clothing 

do not exceed the Agency’s level of concern. The MOEs are 6,700 and 26,000 for military 

personnel and garment workers, respectively. Further, all of the post-application cancer risk 

estimates for both populations are in the 10-6 range. The cancer risk estimates are 3.2 x 10-6 and 

9.5 x 10-6 for military personnel and garment workers, respectively. 

c. Incident Reports 

The Agency evaluated reports of human permethrin poisonings and adverse reactions 

associated with its use from the following sources: OPP Incident Data System (IDS); Poison 

Control Center Data; California Pesticide Illness Surveillance Program; National Pesticide 

Information Center (NPIC); the National Institute of Occupational Safety and Health; and 

scientific literature. Review of these data sources concluded that it is likely that most poisonings 

from permethrin resulted from misuse or inadvertent exposures. The large majority of cases 

resulted in minor effects to the skin (primarily rash, irritation, itching), eyes (redness, pain, 

burning), headache, dizziness, nausea, vomiting, and shortness of breath or difficulty breathing. 

Loss of consciousness appears to occur only in cases of ingestion involving 700 mg/kg body 

weight or more. Persons handling permethrin directly are the most likely to experience 

symptoms. Permethrin does not appear to pose significant risks from exposure to residues or 

drift, based upon a relatively small number of documented cases. 

39
Compared to other pesticides, permethrin is much less likely to result in serious or 

persistent medical outcome/condition. Even ingestion of suicidal or potentially lethal doses can 

be resolved within a few days with medical treatment. The only death reported was due to 

pneumonitis, and was likely due to xylene solvent rather then permethrin. Although it is a 

relatively safe product, it can aggravate asthma or lead to asthma like symptoms. 

The EPA performed a review of animal incidents reported between April 1, 1998 to 

March 31, 2002. For permethrin containing products, there were 18,343 incidents involving 

domestic animals. The products were either used directly on the animals or for other uses, such 

as household ant or roach killer. There have also been severe adverse reactions, including 

deaths, in cats exposed directly to concentrated permethrin products or secondarily exposed to 

treated dogs. As such, the registrants voluntarily included a warning statement on permethrin 

concentrated spot-on products indicating they are highly toxic to cats. 

B. Environmental Fate and Effects Risk Assessment 

A summary of the Agency’s environmental fate and effects risk assessment is presented 

below. For detailed discussion of all aspects of the environmental risk assessment, please see the 

Agency Revised Risk Assessment for the Reregistration Eligibility Decision on Permethrin After 

Public Comments, Phase III, dated April 5, 2006, which is available on the internet and in the public 

docket. This risk assessment was refined and updated to incorporate comments and additional 

studies submitted by the registrant. Major changes to the risk assessment include the following: 

• Consideration of 150 and 25 foot buffer zone for aerial and ground agricultural 

applications consistent with the buffer zones required for all pyrethroids; 

• Clarification of agricultural use patterns, such as typical application rates and 

number of applications; 

• Revisions to the public health use parameters based on the provisions of the PR 

Notice 2005-1, which aims to standardize the use of public health use pesticides. 

• Modification to the down-the-drain residential assessment to include revised 

production numbers of permethrin used in pharmaceuticals provided by the US 

Food and Drug Administration (FDA). 

1. Environmental Fate and Transport 

Permethrin is a persistent pyrethroid in the environment, and was immobile in several 

soils tested, both sterile and viable (Koc >5000). It is also slow to hydrolyze and biodegrade. It 

is relatively stable to hydrolysis at pHs ranging from 3 to 7 when stored in the dark at 25o

C. At 

pH 9, permethrin degraded very slowly with a half-life of 125–350 days. The half-life reported 

for permethrin in an anaerobic aquatic study ranged from 113 days to 175 days, which indicates 

that the degradation in soil and water is slower as the oxygen levels are reduced. The relatively 

low water solubility and hydrophobic nature of permethrin leads to strong soil adsorption and a 

tendency to partition to sediment in aquatic systems. The high octanol/water partition coefficient 

suggests that permethrin will bioconcentrate in aquatic organisms. Permethrin has a vapor 

pressure of 2.15x10-8 mm Hg, water solubility of 0.0055 mg/L, and an estimated Henry’s law 

constant of 1.4x10-6 atm-m3

/mol. Based upon its Henry’s law constant and vapor pressure, 

40
permethrin is expected to have a relatively low potential for volatilization from soil and water 

surfaces. Permethrin’s potential for volatilization is also reduced significantly because it adsorbs 

strongly to soils and suspended solids or sediment in the water column. 

Based on laboratory and field studies that were submitted to the Agency, permethrin has 

very low mobility, is moderately persistent and has a high affinity to bind to soils/sediments and 

organic carbon. This compound binds readily to particulate matter and organic carbon in a lake 

or stream, thus possibly reducing its bioavailability in this medium after 48 hours. However, as 

the particulate-bound permethrin settles out of the water column and onto the benthos, there is an 

increase in permethrin sediment concentrations that could result in toxic exposure to benthic and 

epibenthic aquatic organisms (e.g., early life stage of many invertebrates and fish, as well as 

crabs and shrimp). 

Additionally, like several other chemicals in its class, permethrin can reach surface 

waters by spray drift or in runoff events via erosion. However, as opposed to many other 

synthethic pyrethroids, permethrin labels currently do not have a required buffer zone to protect 

bodies of water against spray drift. In addition to drift and runoff from agricultural areas, 

permethrin residues can also be transported to aquatic systems via release of water from 

wastewater treatment plants. The Agency assessed the occurrence of permethrin residues being 

found in wastewater as a result of laundering permethrin treated clothing and the disposal 

wastewater from of other household uses (e.g., pet shampoo and pharmaceutical shampoo 

rinsate). 

2. Ecological Exposure and Risk 

To estimate potential ecological risk, EPA integrates the results of exposure and 

ecotoxicity studies using the risk quotient method. Risk quotients (RQs) are calculated by 

dividing acute and chronic estimated environmental concentrations (EECs), based on 

environmental fate characteristics and pesticide use data, by ecotoxicity values for various 

wildlife and plant species. RQs are then compared to levels of concern (LOCs), and when the 

RQ exceeds the level of concern for a particular category, the Agency presumes a risk of concern 

to that category. In general, the higher the RQ, the greater the potential risk (see Table 17 below 

for the Agency’s LOCs). Risk characterization provides further information on potential adverse 

effects and the possible impact of those effects by considering the fate of the chemical and its 

degradates in the environment, organisms potentially at risk, and the nature of the effects 

observed. To the extent feasible, the Agency seeks to reduce environmental concentrations in an 

effort to reduce the potential for adverse effects to non-target organisms. 

Table 17. EPA’s Levels of Concern (LOCs) and Risk Presumptions 

If a calculated RQ is greater than the LOC presented, then the Agency presumes 

that... 

LOC 

terrestrial 

animals 

LOC 

aquatic 

animals 

LOC 

plants 

Acute Risk ...there is potential for acute risk; regulatory action may be warranted in 

addition to restricted use classification 0.5 0.5 1.0 

Acute Restricted Use ...there is potential for acute risk, but may be mitigated through 

restricted use classification 0.2 0.1 NA 

41
Table 17. EPA’s Levels of Concern (LOCs) and Risk Presumptions 

If a calculated RQ is greater than the LOC presented, then the Agency presumes 

that... 

LOC 

terrestrial 

animals 

LOC 

aquatic 

animals 

LOC 

plants 

Acute Endangered Species ...endangered species may be adversely affected 0.1 0.05 1.0 

Chronic Risk ...there is potential for chronic risk 1 1 NA 

For permethrin, the Agency modeled EECs for six crop scenarios, which are listed in Table 18 

below. The scenarios were selected to represent a variety of crops among the major uses, and a 

variety of sites in the U.S. 

Table 18: Input parameters for permethrin used in PRZM/EXAMS 

Crop Modeled Location Max. App. Rate* (lb ai/A) 

[Typical App. Rate**] 

Maximum # of Apps.* 

[Typical #**] 

Alfalfa California 0.2 [0.1] 5 [1] 

Corn North Dakota 0.2 [0.8] 3 [1] 

Potatoes Maine 0.2 [0.11] 8 [1] 

Sweet Corn Oregon 0.2 [0.15] 6 [2] 

Apples Pennsylvania 0.3 [0.13] 2 [1] 

Tomatoes Florida 0.2 [0.13] 6 [7] 

*The maximum application rates and number of applications were derived from currently registered labels. 

**The data for the typical application rates and number of applications are from EPA and USDA National 

Agricultural Statistics Service (NASS) databases for the years 2002-2004, and reflect the annual number of 

applications, and maximum annual application rate for the selected crops for the US. The annual averages are 

straight averages. The National Potato Council provided typical use information, which was corroborated by the 

Agency and used in the assessment. 

a. Terrestrial Organisms 

Birds and Mammals 

The Agency terrestrial exposure model (ELL-FATE, Version 1.4, dated April 7, 2004) 

was used to estimate exposures and risks to avian and mammalian species. Input values on avian 

and mammalian toxicity, as well as chemical application and foliar dissipation half-time data, are 

required to run the model. The model provides estimates of both exposure concentrations and 

RQs. Specifically, the model provides estimates of concentrations (maximum and average) of 

chemical residues on the surface of different types of foliage that may be sources of exposure to 

avian, mammalian, reptilian, or terrestrial phase amphibian receptors. The surface residue 

concentration (ppm) is estimated by multiplying the application rate (pounds active ingredient 

per acre) by a value specific to each food item. 

ELL-FATE was run for permethrin for use on potato crops using the inputs provided in 

Table 19 below. In the absence of foliar dissipation half-life data for permethrin the Agency’s 

42
default half-life value of 35 days because the Agency did not have half-life data for the crops 

used in the assessment. 

Table 19: Input Parameters for Permethrin Used in ELL-FATE. 

Parameter Value 

Application rate (lbs ai/A) 0.2 

Foliar half-life (days) 35 

Retreatment interval (days) 4 

Maximum applications per year 8 

Effects characterization describes the potential effects a pesticide can produce in a 

terrestrial organism, and is based on registrant-submitted studies that describe acute and chronic 

effects toxicity information for various terrestrial animals. Table 20 summarizes the toxicity 

effects and reference values used to assess risks for permethrin to mammals and birds. 

Table 20. Toxicity Reference Values for Mammals and Birds for Permethrin. 

Exposure 

Scenario Species Exposure Duration 

Toxicity 

Reference Value 

Toxicity Category/ 

Effect 

Mammals 

Acute Rat Single dose LD50 = 8,900 mg/kg /day Practically non-toxic 

Chronic Rat Developmental 

Toxicity 

NOAEC = 1,000 ppm (50 

mg/kg/day) 

LOAEC = 3,000 ppm 

(150 mg/kg/day) 

Decreased mean fetal 

bodyweight 

Birds 

Acute Mallard duck 5-day dietary LC50 > 10,000 ppm Practically non-toxic 

Chronic Mallard duck Reproduction study NOAEC = 500 ppm Slight decrease in egg 

production 

As presented in Table 21 below, avian acute RQs are below the acute, restricted use, and 

endangered species LOCs and the chronic RQs are below the chronic LOC at registered 

maximum application rates for permethrin for all forage items. 

Table 21. Acute and Chronic Risk Quotients for Birds Exposed to Permethrin 

Food Item Maximum EEC (ppm) Bird 

Acute RQs 

Bird 

Chronic RQs 

Short grass 295.8 0.03 0.59 

Tall grass 135.6 0.01 0.27 

43
Table 21. Acute and Chronic Risk Quotients for Birds Exposed to Permethrin 

Food Item Maximum EEC (ppm) Bird 

Acute RQs 

Bird 

Chronic RQs 

Broadleaf plants 

small insects 166.4 0.02 0.33 

Fruits, pods, 

large insects, seeds 18.5 <0.01 0.04 

Table 22 below presents the acute RQs for small mammalian species that forage on plants 

and insects containing permethrin residues. All acute RQs were below the acute LOC for each 

environmental scenario and therefore not of concern. 

Table 22. Acute Risk Quotients for Terrestrial Mammals Exposed to Permethrin 

Food Item Maximum EEC 

(ppm) 

Mammal Acute RQs 

by Body Weight 

15g 35 g 1000 g 

Short grass 295.8 0.04 0.02 <0.01 

Tall grass 135.6 0.02 0.01 <0.01 

Broadleaf plants 

small insects 166.4 0.02 0.01 <0.01 

Fruits, pods, 

large insects, seeds 18.5 <0.01 <0.01 <0.01 

Chronic RQs for mammals were calculated using the results of a developmental toxicity study 

performed with rats. Dose based RQs based on the Maine Potatoe scenario, which is the most 

conservative of the crop scenarios assessed, range from 0.02 to 2.57. This study was conducted via 

oral gavage and represents a more intense dosing regime than that of the 3-generation rat 

reproduction studies (dietary exposure) which the Agency typically relies on to estimate chronic 

effects and risk to mammals. Therefore, given the questionable toxicological response and the 

intense dosing regime, it should be noted that this NOAEC represents a conservative estimate of 

toxicity and its use may result in the overestimation of chronic risk to mammals. Thus, the 

results are not tabulated in this document. The Agency is not requiring additional data at this 

time. For more details, refer to the Addendum to Revised Draft EFED RED Chapter for 

Permethrin, dated April 5, 2006. 

Non-Target Insects 

EPA currently does not estimate RQs for terrestrial non-target insects. However, permethrin 

toxicity data show that the compound is highly toxic to honeybees, as well as beneficial insects. 

A hazard assessment shows that permethrin exposure can result in acute toxicity to honeybees 

and is considered to be highly toxic on both a contact and an oral basis (contact LD50 = 0.13 

ug/bee; oral LD50 = 0.024 ug/bee). Permethrin was also found to be highly toxic to honeybees 

exposed to foliage that had been sprayed with a permethrin formulation. Several field studies 

were submitted that showed the effects of permethrin formulations on non-target insects. These 

studies show that applications of formulations of permethrin are likely to reduce the numbers and 

possibly eliminate populations of beneficial insects. 

44
Non-Target Plants 

Toxicity data are not available for terrestrial plants. Therefore, the potential for risk to 

terrestrial plants from exposure to permethrin cannot be assessed, and remains an uncertainty. 

However, any toxicity to plants would occur for reasons other than permethrin's insecticidal 

mode of action, because permethrin works in insects as a neural toxin. Unlike insects, plants do 

not have neural networks that could be affected. 

b. Aquatic Organisms

 i. Agricultural Use of Permethrin 

Freshwater and Estuarine/Marine Fish and Invertebrates 

To assess potential risks to aquatic animals, the Agency considers predicted EECs in surface 

water using the Tier II model PRZM/EXAMS. Unlike the drinking water assessment described in the 

human health risk assessment section of this document, the exposure values used in the ecological risk 

assessment do not include the Index Reservoir (IR) and Percent Cropped Area (PCA) factor 

refinements. These factors represent a drinking water reservoir, not the variety of aquatic habitats 

relevant to a risk assessment for aquatic animals, such as ponds adjacent to treated fields. Therefore, 

the EEC values used to assess potential exposure and risk to aquatic animals are not the same as those 

used to assess exposure and risk to humans from pesticides in drinking water. 

Peak EECs were compared to acute toxicity endpoints to derive acute RQs. The highest 

EECs were observed for the Maine potatoes scenario followed by Pennsylvania apples. These 

results are summarized in The Agency Revised Risk Assessment for the Reregistration Eligibility 

Decision on Permethrin After Public Comments, Phase III, dated April 5, 2006. 

Effects characterization describes the potential effects a pesticide can produce in an 

aquatic organism, and is based on registrant-submitted studies that describe acute and chronic 

effects toxicity information for various aquatic animals. Table 23 summarizes the toxicity 

effects and reference values used to assess risks for permethrin to aquatic organisms. 

Table 23. Permethrin Toxicity Reference Values for Aquatic Organisms 

Exposure Scenario Species Exposure 

Duration 

Toxicity Reference Value 

(ppb) 

Toxicity Category/ 

Effect 

Freshwater Fish 

Acute Bluegill sunfish 96 hours LC50 =0.79 ppb Very highly toxic 

Chronic Fathead minnow Full life cycle NOAEC = 0.30 ppb 

LOAEC = 0.41 ppb Reduced survival 

Freshwater Invertebrates 

Acute Hexagenia 

bilineuta 

48 hours EC50 = 0.1 ppb Very highly toxic 

45
Table 23. Permethrin Toxicity Reference Values for Aquatic Organisms 

Exposure Scenario Species Exposure 

Duration 

Toxicity Reference Value 

(ppb) 

Toxicity Category/ 

Effect 

Chronic Daphnia magna Life cycle NOAEC = 0.039 ppb 

LOAEC = 0.084 ppb Reproduction and growth 

Estuarine/Marine Fish 

Acute Atlantic silverside 96 hours LC50 = 2.2 ppb Very highly toxic 

Chronic Sheepshead 

minnow 

28 day early life 

stage 

NOAEC 0.83 ppb1 

LOAEC 10 ppb Reduced survival 

Estuarine/Marine Invertebrates 

Acute Mysid shrimp 96 hours LC50 = 0.019 ppb Very highly toxic 

Chronic Mysid shrimp 30 day life cycle 

NOAEC = 0.011 ppb 

LOAEC = 0.024 ppb Mortality 

As noted in Table 18, the Agency considered the maximum labeled application rate, as 

well as the typical use scenario in order to evaluate the potential for permethrin to cause acute 

and chronic toxic risk to fish and aquatic invertebrates (freshwater and estuarine/marine). As 

presented in Table 34, at the maximum application rates, most acute RQs for both freshwater and 

estuarine/marine fish and invertebrates exceed the Agency’s acute LOC (0.5), and all exceed the 

Agency’s endangered species LOC (0.05). 

Table 24. Acute Risk Quotients for Aquatic Organisms Exposed to Permethrin (no buffer zone; Maximum 

application rate and number of applications) 

Crop Scenario 

Peak EECs 

(ppb) 

Freshwater RQs Estuarine/Marine RQs 

Fish 

96 hr. LC50= 

0.79 ppb 

Invertebrates 

96 hr. EC50 = 0.10 

ppb 

Fish 

96 hr. LC50 = 

2.2 ppb 

Invertebrates 

EC50 = 

0.019 ppb 

California 

Alfalfa .54 0.68 5.4 0.25 28.4 

Maine Potatoes 5.32 6.73 53.2 2.42 280.0 

North Dakota 

Corn 0.55 0.7 5.5 0.25 29.0 

Oregon Sweet 

Corn 0.96 1.22 9.6 0.44 50.5 

Pennsylvania 

Apples 1.83 2.32 18.3 0.83 96.3 

Florida 

Tomatoes 1.11 1.41 11.1 0.50 58.4 

As presented in Table 25, at the maximum application rates, RQs for both freshwater and 

estuarine/marine invertebrates exceed the Agency’s chronic LOC (1.0). The RQs for freshwater and 

estuarine/marine fish exceed the chronic LOC only for the Maine potato scenario. 

46
Table 25. Chronic Risk Quotients for Aquatic Organisms Exposed to Permethrin [no buffer zone; Maximum 

application rate and number of applications) 

Crop Scenario 

21-d/60-d 

EECs 

(ppb) 

Freshwater RQs Estuarine/Marine RQs 

Fish 

NOAEC= 

0.30 ppb 

Invertebrates 

NOAEC = 

0.039 ppb 

Fish 

NOAEC = 

0.83 ppb 

Invertebrates 

NOAEC = 

0.011 ppb 

California 

Alfalfa 0.1/0.09 0.3 2.6 0.1 9.1 

Maine Potatoes 1.3/1.0 3.4 33.9 1.23 120 

North Dakota 

Corn 0.16/0.11 0.4 4.1 0.1 14.6 

Oregon Sweet 

Corn 0.35/0.24 0.8 9.0 0.3 31.8 

Pennsylvania 

Apples 0.29/0.24 0.8 7.4 0.3 26.4 

Florida 

Tomatoes 0.24/0.18 0.6 6.2 0.2 21.8 

If typical application rates and numbers of applications are considered, all resulting RQs are 

reduced from the maximum rate and are listed in Table 26. However, the resulting freshwater and 

estuarine/marine invertebrate RQs still exceed the acute and endangered species LOCs for all crops 

simulated. All of the freshwater and estuarine/marine fish RQs exceed the endangered species LOC, 

and most exceed the acute LOC. 

Table 26. Acute Risk Quotients for Aquatic Organisms Exposed to Permethrin (no buffer zone; typical application 

rate and number of applications) 

Crop Scenario 

Peak EECs 

(ppb) 

Freshwater RQs Estuarine/Marine RQs 

Fish 

96 hr. LC50 = 

0.79 ppb 

Invertebrates 

96 hr. EC50 = 0.10 

ppb 

Fish 

96 hr. LC50 = 

2.2 ppb 

Invertebrates 

EC50 = 

0.019 ppb 

California 

Alfalfa 0.24 0.30 2.4 0.11 12.6 

Maine Potatoes 0.61 0.77 6.1 0.28 32.1 

North Dakota 

Corn 0.20 0.25 2.0 0.09 10.5 

Oregon Sweet 

Corn 0.43 0.54 4.3 0.20 22.6 

Pennsylvania 

Apples 0.38 0.48 3.8 0.17 20.0 

Florida 

Tomatoes 0.74 0.93 7.4 0.34 39.0 

For typical use scenarios, RQs for both freshwater and estuarine/marine invertebrates exceed 

the Agency’s chronic LOC (1.0) in most cases, and are presented in Table 27. The RQs for freshwater 

and estuarine/marine fish calculated for typical use scenarios do not exceed the chronic LOC. 

47
Table 27. Chronic Risk Quotients for Aquatic Organisms Exposed to Permethrin [no buffer zone; typical 

application rate and number of applications) 

Crop Scenario 

21-d/60-d 

EECs 

(ppb) 

Freshwater RQs Estuarine/Marine RQs 

Fish 

NOAEC= 

0.30 ppb 

Invertebrates 

NOAEC = 

0.039 ppb 

Fish 

NOAEC = 

0.83 ppb 

Invertebrates 

NOAEC = 

0.011 ppb 

California 

Alfalfa 0.1/0.09 0.03 0.5 0.01 1.8 

Maine Potatoes 1.3/1.0 0.3 3.1 0.1 10.9 

North Dakota 

Corn 0.16/0.11 0.03 0.5 0.01 1.8 

Oregon Sweet 

Corn 0.35/0.24 0.23 2.3 0.08 8.2 

Pennsylvania 

Apples 0.29/0.24 0.17 1.5 0.06 5.5 

Florida 

Tomatoes 0.24/0.18 0.43 4.4 0.16 15.5 

Effect of Spray Buffers 

In addition to considering typical application rates and numbers of applications, the 

Agency considered buffer zones proposed by the registrant of 150 ft for aerial applications that 

do not involve Ultra Low Volume (ULV) and 25 feet for ground applications. The effects of 

spray drift and the use of buffer zones in reducing exposure to bodies of water adjacent to treated 

areas were investigated using the AgDRIFT model. 

Table 28 and 29 below present the acute and chronic RQs to aquatic organisms, respectively, 

exposed to permethrin at the maximum labeled application rates, and with a 150 foot buffer zone for 

aerial applications, and 25 feet for ground application (PA Apples). 

Table 28. Acute Risk Quotients for Aquatic Organisms Exposed to Permethrin (Buffer Zone 150 ft, 25 ft for PA 

apples; Maximum application rate and number of applications) 

Crop Scenario 

Peak EECs 

(ppb) 

Freshwater RQs Estuarine/Marine RQs 

Fish 

96 hr. LC50 = 

0.79 ppb 

Invertebrates 

96 hr. EC50 = 0.10 

ppb 

Fish 

96 hr. LC50 = 

2.2 ppb 

Invertebrates 

EC50 = 

0.019 ppb 

California 

Alfalfa 0.42 0.53 4.20 0.19 22.11 

Maine Potatoes 5.27 6.67 52.70 2.40 277.37 

North Dakota 

Corn 0.43 0.54 4.30 0.20 22.63 

Oregon Sweet 

Corn 0.83 1.05 8.30 0.38 43.68 

Pennsylvania 

Apples 1.83 2.32 18.30 0.83 96.32 

Florida 

Tomatoes 1.00 1.27 10.00 0.45 52.63 

At the maximum application rates, most acute RQs for both freshwater and estuarine/marine 

fish, invertebrates, and sediment organisms exceed the Agency’s acute LOC (0.5), and all exceed the 

48 
Agency’s acute LOC for restricted use risk (0.1) and endangered species (0.05). 

Table 29. Chronic Risk Quotients for Aquatic Organisms Exposed to Permethrin [Buffer Zone 150 ft, 25 ft. for PA 

apples; Maximum application rate and number of applications) 

Crop Scenario 

21-d/60-d 

EECs 

(ppb) 

Freshwater RQs Estuarine/Marine RQs 

Fish 

NOAEC= 

0.30 ppb 

Invertebrates 

NOAEC = 

0.039 ppb 

Fish 

NOAEC = 

0.83 ppb 

Invertebrates 

NOAEC = 

0.011 ppb 

California 

Alfalfa 0.08/0.07 0.23 2.05 0.08 7.27 

Maine Potatoes 1.28/0.98 3.27 32.82 1.18 116.36 

North Dakota 

Corn 0.13/0.09 0.30 3.33 0.11 11.82 

Oregon Sweet 

Corn 0.29/0.20 0.67 7.44 0.24 26.36 

Pennsylvania 

Apples 0.28/0.24 0.80 7.18 0.24 25.45 

Florida 

Tomatoes 0.20/0.15 0.50 5.13 0.18 18.18 

In contrast to the acute risk estimate, most of the freshwater and estuarine/marine chronic risks 

to fish are below the Agency’s chronic LOC (1). However, the chronic RQs for freshwater and 

estuarine/marine invertebrates and sediment organisms exceed the LOC (1) in all scenarios. 

The effect of a spray buffer on potential exposure may be underestimated by the risk quotients 

shown above. AgDrift was used to evaluate the effect of spray buffers on the amount of permethrin 

reaching the standard pond via spray drift. However, the PRZM model is an edge-of-field model 

which cannot simulate an untreated area between the field and the receiving water body. Therefore, 

the RQs for the scenario with the 150-foot buffer reflect the same amount of loading from 

runoff/erosion as the RQs with no buffer at all. Presumably, the mass of permethrin that would be 

applied to that portion the field within an untreated spray buffer zone would be less than that applied 

to the rest of the crop, and would decline with distance, but the resulting reduction in the loading from 

runoff and erosion cannot currently be quantified. 

All of the risk quotients reflect the same predicted reduction in spray drift for any particular 

spray buffer, but different contributions from runoff/erosion. This is important because while the EEC 

from PRZM/EXAMS used in the screening model represents a 1-in-10-year exposure from combined 

runoff/erosion and spray drift, the typical drift fractions calculated by AgDrift used for the bufferanalysis RQs above represent the amount of exposure from spray drift that could occur any time a 

pesticide is applied. Therefore, while the buffer may not reduce exposure below LOCs when 

permethrin exposure from spray drift coincides with heavy rain events, it will reduce exposure from 

spray drift even when runoff does not occur. Comparison of the results from PRZM/EXAMS runs in 

the risk assessment performed with varying amounts of spray drift with those from the hypothetical 

"no drift" scenario suggests that exposure from drift alone might be enough to exceed some acute 

aquatic LOCs. 

49
Risk to Sediment Dwelling Organisms 

The ecological risk assessment also considers the potential for risk to epibenthic and sedimentdwelling invertebrates from exposure to permethrin in sediment pore water. The risk assessment 

estimates pore water exposure to sediment organisms through the use of equilibrium-partitioning 

predicted porewater concentrations of permethrin normalized to the organic carbon (OC) in 

sediment. Since aquatic invertebrates living in the water column are no less sensitive to toxic 

compounds than those invertebrates living in the benthos, and toxicity data were not available for 

sediment-dwelling invertebrates, the assessment uses standard water-column toxicity values with 

the model-generated porewater exposure values for RQ calculations. As presented in Table 30, 

the resulting RQs indicate a potential for acute and chronic risk to epibenthic and sedimentdwelling invertebrates from exposure to permethrin in sediment pore water, based on maximum 

application rates and no buffer zone restrictions. 

Table 30. Acute and Chronic Risk Quotients for Aquatic Organisms Exposed to Permethrin in Sediment Pore 

Water [no buffer zone; Maximum application rate and number of applications) 

Crop Scenario 

Acute/Chronic 

pore water 

EECs 

(ppb) 

Acute RQs Chronic RQs 

Freshwater 

Invertebrates 

EC50 = 

0.1 ppb 

Estuarine/Marine 

EC50 = 

0.019 ug/L 

Freshwater 

Invertebrates 

NOEC = 

0.039 ppb 

Estuarine/Marine 

Invertebrates 

NOEC = 

0.011 ug/L 

California 

Alfalfa 0.05/0.05 0.5 2.6 1.3 4.6 

Maine Potatoes 0.56/0.55 5.6 29.5 14.1 50 

North Dakota 

Corn 0.05/0.05 0.5 2.6 1.3 4.6 

Oregon Sweet 

Corn 0.12/0.12 12.0 6.3 3.1 10.9 

Pennsylvania 

Apples 0.12/0.12 12.0 6.3 3.1 10.9 

Florida 

Tomatoes 0.08/0.07 0.80 4.2 1.8 6.4 

Non-Target Plants 

Toxicity data are not available for aquatic plants. Therefore, the potential for risk to 

aquatic plants from exposure to permethrin cannot be assessed, and remains an uncertainty. 

However, any toxicity to plants would occur for reasons other than permethrin's insecticidal 

mode of action, because permethrin works in insects as a neural toxin. Unlike insects, plants do 

not have neural networks that could be affected. 

a. Public Health Use of Permethrin 

Permethrin is registered as a mosquito adulticide for use in Public Health Abatement 

Programs. Permethrin used in mosquito abatement programs to control adult mosquitoes in 

residential and recreational areas can lead to potential exposure to various types of water bodies. The 

Agency conducted aquatic exposure modeling for mosquito abatement to consider the risk to aquatic 

50
organisms from this use of permethrin. 

Mosquito adulticides are more efficacious if they come into contact with insects in flight. For 

that reason, mosquito abatement using permethrin (as well as other mosquito adulticides) is typically 

applied via aerial spray methods with very fine mists to prevent immediate deposition of the pesticide. 

Therefore, the modeling approach for this type of use included calculations of spray drift using the 

Agricultural Disperal (AGDISP) model. This model estimates the deposition of the pesticide to the 

treatment area and deposition assessment to the adjacent bodies of water (i.e. standard pond). 

Most input parameters are standard for AGDISP; however, some are variable. For example, 

the temperature and relative humidity were selected to be similar to those conditions where 

mosquitoes grow, a wind speed of 10 miles per hour was selected, a low evaporation rate was 

assumed, and the volatile fraction was very small. The current permethrin labels vary in their 

specificity of application parameters (i.e. boom height, droplet size, application rate, and number of 

applications). Therefore, the Agency relied upon the guidelines and recommendations in the 

Pesticide Registration (PR) Notice 2005-1, which presents Agency guidance for pesticide 

products intended for wide-application to control adult mosquitoes. The specific label 

statements and label organization principles recommended in the Notice are intended to improve 

existing labels by clarifying language conveying environmental hazards posed by the products, 

as well as specific use direction and instructions to the applicators. The Agency also considered 

public comments submitted to the Agency by the American Mosquito Control Association 

(AMCA) during Phase 3 of the public process for reregistering pesticides. 

Most labels specify a maximum boom height of 300 feet; however, most do not specify a 

minimum boom height. The Agency initially assumed a minimum boom height of 25 feet. However, 

following receipt of comments from the AMCA that most applications do not take place lower than 

100 and 75 feet for fixed wing and helicopters, respectively, the Agency also assessed minimum 

boom heights of 75 and 100 feet. The current and proposed labels provide a range of droplet size 

ranging from 20 to 50 ug; however, the proposed labels recently submitted to the Agency in response 

to PR-2005-1 propose a droplet size of 60 ug. Larger droplets are expected to result in higher 

deposition and potential exposure in the spray area, but lower deposition outside the spray area. In 

order to be conservative in its assessment, the Agency considered the two larger sized droplets, 50 ug 

and 60 ug, in the risk assessment. Based on the Agency’s assessment there was little difference in risk 

to aquatic organisms between 50 ug and 60 ug. 

 Currently, the maximum application rate registered for aerial application is 0.021 lb ai/A; 

however, according to the AMCA and technical registrant, this is rate is hardly used. The “high-end” 

application rate used in mosquito abatement programs is 0.007 lb ai/A, and the “typical” application 

rate is 0.0035 lb ai/A. The Agency assessed both the proposed high-end and typical application rates 

in the risk assessment. Further, most permethrin labels do not specify the number of applications and 

application timing. The Agency assumed 26 applications per site per season in the risk assessment 

based on use data provided for another mosquito adulticide. 

Finally, the current permethrin mosquito adulticide labels maintain a 100-foot buffer zone 

between the treated area and any body of water. However, according to PR-2005-1 the buffer zone 

may not be warranted, because it was added to labels out of concern for aquatic toxicity that might 

51
result due to runoff from agricultural sites, and not as a result of risks associated with the significantly 

lower concentration of the active ingredient involved in ULV mosquito control applications. Further, 

the PR Notice contends that protecting human health from mosquito-borne diseases with pesticides 

now available often involves some degree of ecological risks, and that a buffer zone may require 

leaving potentially infested areas untreated. Therefore, to determine the extent of the ecological risk, 

and the need for a buffer zone on permethrin mosquito adulticide labels, the Agency considered a 

zero, 100, and 150 foot buffer zone in its assessment. 

The Agency assessed a number of scenarios with different variables, such as boom height and 

application rate, with the various buffer zones (zero, 100 ft, and 150 ft). Based on the risk estimates, 

the Agency concluded for the public health use of permethrin, a buffer zone does not serve to reduce 

the potential risk to aquatic organisms. Further, a zero foot buffer zone and a minimum boom of 100 

ft results in over a 50% reduction in acute and chronic exposure to aquatic fish and invertebrates as 

compared to a 75 ft. boom height. Additionally, as stated above, there was little difference in risk to 

aquatic organisms between 50 ug and 60 ug. For more detail on the various scenarios assessed, refer 

to The Agency Revised Risk Assessment for the Reregistration Eligibility Decision on Permethrin 

After Public Comments, Phase III, dated April 5, 2006, available on the internet and in the public 

docket. 

Based on the conclusions above, the tables below are provided to present the acute and 

chronic RQs to freshwater and estuarine/marine fish and invertebrates with a zero foot buffer, a boom 

height of 100 feet, and a droplet size of 50 ug. Table 31 presents the RQs when the high-end 

application rate is used, and Table 32 presents to RQs when the typical application rate is used. 

Table 31. Comparison of the Freshwater and Estuarine/Marine Acute and Chronic RQs for Fish and Invertebrates (Application 

rate 0.007 lb ai/A, boom height 100 feet, Buffer Zone 0 ft., Droplet size 50 ug) 

Depth of 

Water 

Fish Invertebrates 

Freshwater Estuarine/Marine Freshwater Estuarine/Marine 

Acute Chronic Acute Chronic Acute Chronic Acute Chronic 

6.6 feet 0.07 0.10 0.03 <0.00 1.46 0.76 3.00 2.73 

The reduction in application rate to the typical rate of 0.0035 lb ai/A can further result in a 

reduction in potential permethrin exposure to freshwater and estuarine/marine fish and invertebrates. 

The RQs associated with this rate at a boom height of 100 feet and zero buffer zone do not exceed the 

Agency’s acute and chronic LOC for all fish and the chronic LOC for freshwater invertebrates. 

However, although a reduction in rate reduced the overall risk to invertebrates, RQs exceed the acute 

LOC both freshwater and estuarine/marine invertebrates and the chronic LOC is exceeded for 

estuarine/marine invertebrates. See Table 32 below for more details. 

52
Table 32. Comparison of the Freshwater and Estuarine/Marine Acute and Chronic RQs for Fish and 

Invertebrates (Application rate 0.0035 lb ai/A, boom height 100 feet, Buffer Zone 0 ft., Droplet size 50 ug) 

Depth of 

Water 

Fish Invertebrates 

Freshwater Estuarine/Marine Freshwater Estuarine/Marine 

Acute Chronic Acute Chronic Acute Chronic Acute Chronic 

6.6 feet 0.03 0.05 0.01 <0.00 0.71 0.38 1.47 1.36 

b. Down-the-Drain Assessment 

 As part of its aquatic exposure assessment, the Agency also assessed the ecological impact of 

permethrin released into domestic wastewater, and eventually into Publicly Owned Treatment Works 

(POTWs). The Agency relied on the Office of Pollution Prevention and Toxics (OPPT) consumer 

exposure model, Exposure and Fate Assessment Screening Tool (E-FAST). The Down-the-Drain 

module of E-FAST is specifically designed to address all sources of permethrin that could potentially 

be disposed to domestic wastewater from a down-the-drain application. This model provides 

screening-level estimate of chemical residues in surface water that may result from household uses 

and the disposal of consumer products into wastewater. The model uses input parameters that include 

annual production volume of the pesticide and takes into account the fraction of the chemical removed 

during wastewater treatment. The assumptions of the model state that in a given year, the entire 

production volume of permethrin is parceled out on a daily per capita basis to the entire US population 

and converted to a mass release per capita. This mass is diluted into the average daily volume of 

wastewater released per person per day to arrive at an estimated concentration of target permethrin in 

wastewater prior to entering a treatment facility. The concentration of permethrin in untreated 

wastewater is then reduced by the fraction removed during the wastewater treatment process before 

release into a river or stream. The remaining chemical is discharged into surface water, where it is 

assumed that it is instantaneously diluted, with no further removal. A stream Dilution Factor is the 

volume of the receiving stream flow divided by the volume of the wastewater released from the 

POTW. The resulting EEC values are then used to assess potential ecological risks resulting from this 

exposure scenario. 

The Agency included permethrin pesticide products (pre-treated clothing and pets products), 

as well as permethrin pediculicide pharmaceutical products, both over the counter (OTC) and 

prescription, in the down-the-drain assessment. Production volume of permethrin for these specific 

uses was based on unpublished market data, from the U.S. Food and Drug Administration, the 

technical registrants, and by Agency sources. A total of approximately 252,000 kg ai of permethrin 

are used per year for pet products, products to treat clothes, impregnated clothing, and OTC and 

prescribed drugs. 

 Information on the degree of removal of permethrin from wastewater at POTWs is limited. 

Agency data shows the removal of permethrin in pretreatment systems employing granular activated 

carbon and resin adsorption to be 52, 75 and 94%. For permethrin, granular carbon and resin 

adsorption is considered the best available technology economically achievable. Although the values 

of removal varied widely, the Agency considers this the best available data and relied on it for the 

down-the-drain assessment. 

53
Table 33 summarizes the risk estimates for aquatic organisms’ exposure to permethrin 

from surface waters containing permethrin after varying levels of removal at POTWs. Acute and 

chronic RQs were below the LOCs at the three removal levels for freshwater and 

estuarine/marine fish. However, aquatic invertebrates appear to be at acute risk from exposure to 

surface waters containing permethrin from wastewater. Acute RQs exceeded some LOCs for 

freshwater and estuarine/marine invertebrates at most treatment levels of removal. Additionally, 

chronic RQs were below the LOC for all aquatic invertebrates. See Table 33 below. 

Table 33. Estimated risks to aquatic organisms from permethrin consumer products released into domestic wastewater after 

different levels of removal a POTWs 

Level of 

Removal 

Fish Invertebrates 

Freshwater Estuarine/Marine Freshwater Estuarine/Marine 

Acute Chronic Acute Chronic Acute Chronic Acute Chronic 

52% 0.06 0.01 0.02 <0.01 0.44 0.09 2.33 0.09 

75% 0.03 0.01 0.01 <0.01 0.23 0.05 1.21 0.16 

94% 0.01 0.01 <0.00 <0.01 0.06 0.01 1.29 0.04 

iii. Other Non-Agricultural Use 

The other non-agricultural applications of permethrin that include perimeter treatments in and 

around buildings, lawn care, outdoor surfaces, etc., may result in exposure to aquatic organisms in 

adjacent water bodies because of irrigation that can result in runoff and/or erosion. Even though 

permethrin has a strong affinity to bind to soils and surfaces, residue monitoring in non-agricultural 

areas, such as in certain areas of California, have shown that residues toxic to aquatic organisms are 

occurring in aquatic areas that receive runoff from suburban developments. A recent monitoring 

study conducted in an urban area of California found residues of permethrin and other pyrethroids in 

adjacent water bodies from these residential areas and suggested that these areas are unlikely to be 

unique with similar profiles occurring in other suburban areas, particularly in dry regions where 

landscape irrigation can dominate seasonal flow in some water bodies. The Agency recognizes the 

potential of aquatic toxicity from non-agricultural uses, but was not able to assess the risks associated 

with these uses at this time due to lack of available data. The Agency’s plan to consider aquatic 

exposure from non-agricultural uses of permethrin is further discussed in Section IV. 

c. Endangered Species 

Based on a screening-level assessment, permethrin will have no direct acute or chronic 

effect on listed terrestrial mammal, avian, and plants species, or aquatic plants species. The 

screening level assessment, however, indicates there is a potential concern for direct effects to a 

variety of aquatic organisms, should exposure actually occur at the modeled level. These are as 

follows: 

• Freshwater Fish and Aquatic-phase Amphibians- The acute endangered LOC (RQ 

54
>0.05) for direct effects were exceeded for all maximum application rates for 

corn, sweet corn, potatoes, alfalfa, orchards, tomatoes, and mosquito abatement 

modeled scenarios. Estimated concentrations in surface water due to waste water 

containing permethrin were also used to calculate RQ values and show acute 

endangered species LOC exceedance. Potential chronic exposure for fish was 

limited to the corn modeled scenario. (In the ecological risk assessment for 

permethrin, freshwater fish toxicity data are used as surrogates for aquatic-phase 

amphibians). 

• Freshwater Invertebrates- The acute and chronic LOC was exceeded for the 

maximum application rate for all crops relative to aquatic macroinvertebrate 

exposure. Permethrin is expected to reach surface water concentrations high 

enough to exceed the acute endangered LOC (acute RQ > 0.05) for aquatic 

invertebrates. 

• Estuarine/Marine Fish- The acute endangered LOC (acute RQ >0.05) is exceed 

for all maximum application rates. The Agency also calculated estimated 

concentrations of permethrin in surface water due to waste water and noted the 

potential for acute endangered species exceedances. However, maximum 

application rates only showed that the potential for chronic exposure to fish was 

limited to the corn modeled scenario. 

• Estuarine/Marine Invertebrates- The endangered species acute LOC and chronic 

LOC is exceeded for all modeled use sites and maximum label rates. However, 

currently there are no listed estuarine/marine invertebrates. 

Although a hazard assessment shows that permethrin exposure can result in acute toxicity 

to honey bees and is considered to be highly toxic on both a contact and an oral basis (contact 

LD50 = 0.13 ug/bee; oral LD50 = 0.024 ug/bee), an assessment method for estimating the risk to 

bees is not yet available; therefore, we cannot preclude the possibility of potential effects to 

listed insect species. Additionally, the Agency currently does not have toxicity data to quantify 

risks for permethrin at the screening-level for terrestrial and aquatic plants and, therefore, can not 

preclude potential direct effects to plants. However, a review of permethrin’s mode of action 

(neural toxin) suggests that direct toxicity to plants should not be an issue of concern. Finally, 

the agency cannot preclude the potential for indirect effects to listed species that may be 

dependent upon taxa that experience direct effects from the use of permethrin. These findings 

are based solely on EPA’s screening-level assessment and do not constitute “may affect” 

findings under the Endangered Species Act (ESA) for any listed species. Rather, this assessment 

serves as a screen to determine the need for any species specific assessments that will evaluate 

whether exposure may be at levels that could cause harm to specific listed species and their 

critical habitat. That assessment refines the screening-level assessment to take into account the 

geographic area of pesticide use in relation to the listed species, the habits and habitat 

requirements of the listed species, etc. If the Agency’s specific assessments result in the need to 

modify use of the pesticide in specific geographic areas, those changes to the pesticide’s 

registration will take through the process described in the Agency’s Federal Register Notice (54 

FR 27984) regarding implementation of the Endangered Species Protection Program. 

55
 3. Ecological Incidents 

The incident reports reported to the Agency since 1994 support the conclusions of the 

risk assessment that exposure to permethrin has a low acute toxicity to terrestrial animal and 

plants, but is highly toxic to aquatic species and beneficial insects. According to the Ecological 

Incident Data System (EIDS), terrestrial risks from exposure to permethrin appear to be low. 

Three incidents resulting in seven bird kills and one dog incapacitation have been reported. Six 

occurrences of damage to plants have been reported, the largest reported damage occurring on 

142 acres of soybeans in Wisconsin. The majority of incidents (21) reported are fish kills, 

ranging from 50 to 3000. Finally, three beneficial insect, bees and butterflies, kills were also 

reported. 

Incidents entered into EIIS are usually categorized into one of several certainty levels: 

highly probable, probable, possible, unlikely, or unrelated. Additionally, incidents entered into 

the EIIS are also categorized as to use/misuse. Unless specifically confirmed by a state or 

federal agency to be misuse, or there was very clear misuse, such as intentional baiting to kill 

wildlife, incidents would not typically be considered misuse. The permethrin incidents data 

available in the EIIS is inconclusive of the probability and if the incidents were a result of misuse 

or registered use. 

IV. Risk Management, Reregistration, and Tolerance Reassessment 

A. Determination of Reregistration Eligibility 

Section 4(g)(2)(A) of FIFRA calls for the Agency to determine, after submission of 

relevant data concerning an active ingredient, whether or not products containing the active 

ingredient are eligible for reregistration. The Agency has previously identified and required the 

submission of the generic (i.e., active ingredient-specific) data required to support reregistration 

of products containing permethrin as an active ingredient. The Agency has completed its review 

of these generic data, and has determined that the data are sufficient to support reregistration of 

all products containing permethrin. 

The Agency has completed its assessment of the dietary, occupational, residential, and 

ecological risk associated with the use of pesticide products containing the active ingredient 

permethrin. Based on a review of these data and on public comments on the Agency’s 

assessments for the active ingredient permethrin, the Agency has sufficient information on the 

human health and ecological effects to make decisions as part of the tolerance reassessment 

process under FFDCA and reregistration process under FIFRA, as amended by FQPA. The 

Agency has determined that permethrin-containing products are eligible for reregistration 

provided that: (i) the risk mitigation measures outlined in this document are adopted and (ii) 

label amendments are made to reflect these measures. Label changes are described in Section V. 

Appendix A summarizes the uses of permethrin that are eligible for reregistration. Appendix B 

identifies the generic data requirements that the Agency reviewed as part of its determination of 

reregistration eligibility of permethrin, and lists the submitted studies that the Agency found 

acceptable. Data gaps are identified as generic data requirements that have not been satisfied 

56
with acceptable data. 

Based on its evaluation of permethrin, the Agency has determined that permethrin 

products, unless labeled and used as specified in this document, would present risks inconsistent 

with FIFRA. Accordingly, should a registrant fail to implement any of the risk mitigation 

measures identified in this document, the Agency may take regulatory action to address the risk 

concerns from the use of permethrin. If all changes outlined in this document are incorporated 

into the product labels, then all current risks for permethrin will be adequately mitigated for the 

purposes of this determination under FIFRA. Once an Endangered Species assessment is 

completed, further changes to these registrations may be necessary as explained in Section III. 

B.2.c. of this document. 

B. Public Comments and Responses 

Through the Agency’s public participation process, EPA worked with stakeholders and 

the public to reach the regulatory decisions for permethrin. EPA released its permethrin 

preliminary risk assessments for public comment on August 31, 2005, for a 60-day public comment 

period (Phase 3 of the public participation process). During the public comment period on the risk 

assessments, which closed on October 31, 2005, the Agency received comments from the 

technical registrants, the PIRTF, stakeholder groups, such as the American Mosquito Control 

Association, the American Mushroom Institute, and the National Association of Clean Water 

Agencies, State and Local government entities in California, California Water Boards, Publicly 

Owned Treatment Works, Mosquito and Vector Control Districts, and several private citizens. 

These comments in their entirety, responses to the comments, as well as the preliminary and 

revised risk assessments, are available in the public docket (OPP-2004-0385) at the address 

given above and in the EPA’s electronic docket at http:www.regulations.gov. 

C. Regulatory Position 

1. Food Quality Protection Act Findings 

a. “Risk Cup” Determination 

As part of the FQPA tolerance reassessment process, EPA assessed the risks associated 

with this pesticide. The Agency has determined that, if the mitigation described in this document 

is adopted and labels are amended, human health risks as a result of exposures to permethrin are 

within acceptable levels. In other words, EPA has concluded that the tolerances for permethrin 

meet FQPA safety standards. In reaching this determination, EPA has considered the available 

information on the special sensitivity of infants and children, as well as exposures to permethrin 

from all possible sources. 

b. Determination of Safety to U.S. Population 

The Agency has determined that the established tolerances for permethrin, with 

amendments and changes as specified in this document, meet the safety standards under the 

FQPA amendments to section 408(b)(2)(D) of the FFDCA, and that there is a reasonable 

57
certainty no harm will result to the general population or any subgroup from the use of 

permethrin. In reaching this conclusion, the Agency has considered all available information on 

the toxicity, use practices and exposure scenarios, and the environmental behavior of permethrin. 

As discussed in Section III, the acute, chronic, and cancer dietary (food and drinking water) risks 

from permethrin are below the Agency’s acute and chronic LOC. 

c. Determination of Safety to Infants and Children 

EPA has determined that the established tolerances for permethrin, with amendments and 

changes as specified in this document, meet the safety standards under the FQPA amendments to 

section 408(b)(2)(C) of the FFDCA, that there is a reasonable certainty of no harm for infants 

and children. The safety determination for infants and children considers factors on the toxicity, 

use practices and environmental behavior noted above for the general population, but also takes 

into account the possibility of increased dietary exposure due to the specific consumption 

patterns of infants and children, as well as the possibility of increased susceptibility to the toxic 

effects of permethrin residues in this population subgroup. 

In determining whether or not infants and children are particularly susceptible to toxic 

effects from exposure to residues of permethrin, the Agency considered the completeness of the 

hazard database for developmental and reproductive effects, the nature of the effects observed, 

and other information. On the basis of this information, the FQPA SF has been reduced to 1X 

for permethrin. The rationale for the decisions on the FQPA SF can be found in Section III and 

the following document: Permethrin: Fifth Revision of the HED Chapter of the Reregistration 

Eligibility Decision Document (RED), dated April 4, 2006. 

2. Endocrine Disruptor Effects 

EPA is required under the FFDCA, as amended by FQPA, to develop a screening 

program to determine whether certain substances (including all pesticide active and other 

ingredients) “may have an effect in humans that is similar to an effect produced by a naturally 

occurring estrogen, or other endocrine effects as the Administrator may designate.” Following 

recommendations of its Endocrine Disruptor Screening and Testing Advisory Committee 

(EDSTAC), EPA determined that there was a scientific basis for including, as part of the 

program, the androgen and thyroid hormone systems, in addition to the estrogen hormone 

system. EPA also adopted EDSTAC's recommendation that EPA include evaluations of 

potential effects in wildlife. For pesticides, EPA will use FIFRA and, to the extent that effects in 

wildlife may help determine whether a substance may have an effect in humans, FFDCA 

authority to require the wildlife evaluations. As the science develops and resources allow, 

screening for additional hormone systems may be added to the Endocrine Disruptor Screening 

Program (EDSP). 

In the available toxicity studies on permethrin, there was no toxicological significant 

evidence of endocrine disruptor effects. When additional appropriate screening and/or testing 

protocols being considered under the Agency’s EDSP have been developed, permethrin may be 

subjected to further screening and/or testing to better characterize effects related to endocrine 

disruption. 

58
3. Cumulative Risks 

Permethrin is a member of the pyrethroid class of pesticides. Although all pyrethroids 

alter nerve function by modifying the normal biochemistry and physiology of nerve membrane 

sodium channels, EPA is not currently following a cumulative risk approach based on a common 

mechanism of toxicity for the pyrethroids. Although all pyrethroids interact with sodium 

channels, there are multiple types of sodium channels and it is currently unknown whether they 

the pyrethroids have similar effects on all channels. Nor do we have a clear understanding of 

effects on key downstream neuronal function e.g., nerve excitability, nor do we understand how 

these key events interact to produce their compound specific patterns of neurotoxicity. There is 

ongoing research by the EPA’s Office of Research and Development and pyrethroid registrants 

to evaluate the differential biochemical and physiological actions of pyrethroids in mammals. 

This research is expected to be completed by 2007. When available, the Agency will consider 

this research and make a determination of common mechanism as a basis for assessing 

cumulative risk. 

4. Endangered Species 

The Endangered Species Act required federal agencies to ensure that their actions are not 

likely to jeopardize listed species or adversely modify designated critical habitat. The Agency 

has developed the Endangered Species Protection Program to identify pesticides whose use may 

cause adverse impacts on federally listed endangered and threatened species, and to implement 

mitigation measures that address these impacts. To assess the potential of registered pesticide 

uses that may affect any particular species, EPA puts basic toxicity and exposure data developed 

for the REDs into context for individual listed species and considers ecological parameters, 

pesticide use information, the geographic relationship between specific pesticide uses and 

species locations and biological requirements and behavioral aspects of the particular species. 

When conducted, these analyses take into consideration any regulatory changes recommended in 

this RED being implemented at that time. A determination that there is a likelihood of potential 

effects to a listed species may result in limitations on the use of the pesticide, other measures to 

mitigate any potential effects, and/or consultations with the Fish and Wildlife Service or National 

Marine Fisheries Service, as necessary. If the Agency determines use of permethrin “may 

affect” listed species or their designated critical habitat, EPA will employ the provisions in the 

Services regulations (50 CFR Part 402). 

The ecological assessment that EPA conducted for this RED does not, in itself, constitute 

a determination as to whether specific species or critical habitat may be harmed by the pesticide. 

Rather, this assessment serves as a screen to determine the need for any species specific 

assessment that will evaluate whether exposure may be at levels that could cause harm to 

specific listed species and their critical habitat. That assessment refines the screening-level 

assessment to take into account the geographic area of pesticide use in relation to the listed 

species, the habits and habitat requirements of the listed species, etc. If the Agency’s specific 

assessments for permethrin result in the need to modify use of the pesticide, any geographically 

specific changes to the pesticide’s registration will be implemented through the process 

described in the Agency’s Federal Register Notice (54 FR 27984) regarding implementation of 

59
the Endangered Species Protection Program. Until that species specific analysis is completed, 

the risk mitigation measures being implemented through this RED will help to reduce the 

likelihood that endangered and threatened species may be exposed to permethrin at levels of 

concern. 

D. Tolerance Reassessment Summary 

Tolerances for residues of permethrin in/on plant RACs are currently expressed in terms 

of permethrin and the sum of its metabolites, DCVA and MPBA [40 CFR §180.378 (b), and (d)]. 

Tolerances for residues of permethrin in/on cottonseed expired on November 15, 1997. 

Tolerances for permethrin residues in/on animal RACs are currently expressed in terms of 

permethrin and the sum of its metabolites, DCVA, MPBA, and 3-PBA [40 CFR §180.378 (c)]. 

The Codex Alimentarius Commission, Canada, and Mexico have established maximum 

residue limits (MRLs) for permethrin residues in/on various plant and animal commodities. U.S. 

tolerances are not currently compatible with Codex, Canadian, and Mexican MRLs, because the 

U.S. tolerance expression includes the parent permethrin and its DCVA and MPBA metabolites 

(also 3-PBA in animal commodities). The Agency concluded that for purposes of tolerance 

assessment, the regulated residues of permethrin would include only the cis- and trans-isomers 

of permethrin. Accordingly, the tolerance definition for permethrin should be amended to 

include only isomers of the parent, permethrin. In addition, the tolerances currently listed under 

40 CFR §180.378 (b) and (c) for plant and animal commodities should be reassigned to 

§180.378(a) under general tolerances. Once the U.S. tolerance definition is amended, it will be 

compatible with the Codex, Canadian, and Mexican MRL definitions. 

Table 34 summarizes the reassessment of the permethrin tolerances. 40 CFR must be 

reorganized to reflect the tolerance reassessment values in the table below. The tolerances listed 

in 40 CFR must be reorganized in order to: (i) incorporate the recommendations made by the 

Agency concerning the permethrin residues of concern that need to be regulated for plant and 

animal commodities; (ii) include tolerances that are needed to cover permethrin residues of 

concern in/on the raw agricultural commodities and processed commodities of rotational crops; 

and (iii) conform with the requirements of FQPA. 

Table 34. Tolerance Reassessment Summary for Permethrin. 

Commodity 

Current 

Tolerance 

(ppm) 

Range of Residues 

(ppm) 1 

Tolerance 

Reassessment 

(ppm) 

Comment/Correct Commodity 

Definition 

Tolerances listed under 40 CFR §180.378 (b): 

Alfalfa, fresh 2 

25.0 

0.1 lb ai/A (0 DAT): 

2.1-15.2 

0.2 lb ai/A (14 DAT): 

0.51-12.6 20.0 

Residue data support lower 

tolerances. 

Alfalfa, hay 2 

55.0 

0.1 lb ai/A (0 DAT): 

0.7-44.5 

0.2 lb ai/A (14 DAT) 

<1.0-31.4 45.0 

Almond 0.05 0.01-0.05 0.05 

Almond, hulls 20.0 0.043-18.1 20.0 

60
Table 34. Tolerance Reassessment Summary for Permethrin. 

Commodity 

Current 

Tolerance 

(ppm) 

Range of Residues 

(ppm) 1 

Tolerance 

Reassessment 

(ppm) 

Comment/Correct Commodity 

Definition 

Apple 0.05 <0.02 (2x) Reassign 

Residue data support 

establishing a 0.05 ppm 

tolerance on pome fruits. 

Concomitant with establishing 

a 0.05 ppm tolerance on fruit, 

pome, group 11, the tolerance 

on apples should be deleted. 

Artichoke, globe 

10.0 0.28-4.00 5.0 

Residue data support a lower 

tolerance. 

Asparagus 

1.0 0.11-1.24 2.0 

Residue data indicate that a 

higher tolerance is required. 

Avocado 1.0 0.10-0.80 1.0 

Broccoli 

1.0 

0.03-1.76 

(0.8-1.2x) 2.0 

Residue data indicate that a 

higher tolerance is required. 

Brussels sprouts 

1.0 

0.04-1.0 

(0.9-1.4x) 1.0 

Cabbage 

6.0 <0.01-18.5 TBD 3 

The majority of the available 

data reflect 1x the maximum 

seasonal rate, but only 0.5x the 

maximum single use rate, 

therefore EPA is requiring 

additional cabbage field trial 

data (860.1500) to determine 

the appropriate tolerance level. 

Cauliflower 

1.0 <0.05-0.32 0.50 

Residue data support a lower 

tolerance. 

Celery 

5.0 0.47-4.02 

1.0 

Reassign 

The tolerance should be deleted 

once a tolerance is established 

for Leaf petioles, subgroup 4B. 

Cherry 

3.0 0.47-3.94 4.0 

Residue data indicate that a 

higher tolerance is required. 

Corn, forage 

60.0 

0.21-42.6 

(1x-1.3x) 50.0 

Residue data support a lower 

tolerance. Separate tolerances 

should be established for Corn, 

field, forage and Corn, sweet, 

forage each at 50 ppm. 

Corn, grain 

0.05 <0.01-0.02 0.05 

Separate tolerances should be 

established for Corn, field, 

grain and Corn, pop, grain 

each at 0.05 ppm. 

61
Table 34. Tolerance Reassessment Summary for Permethrin. 

Commodity 

Current 

Tolerance 

(ppm) 

Range of Residues 

(ppm) 1 

Tolerance 

Reassessment 

(ppm) 

Comment/Correct Commodity 

Definition 

Corn, stover 60.0 field corn: <0.02-16.97 

sweet corn: 1.40-27.1 30.0 

Residue data support a lower 

tolerance. Higher residues on 

sweet corn fodder reflect the 

shorter PHI for sweet corn (1 

day) than field or pop corn (30 

days) Separate tolerances 

should be established for Corn, 

field, stover and Corn, sweet, 

stover, and Corn, pop, stover 

each at 30 ppm. 

Corn, sweet, kernel 

plus cob with husks 

removed 0.1 <0.01-0.08 0.10 

Eggplant 1.0 0.008-0.26 0.50 Residue data support a lower 

tolerance. 

Filbert 0.05 <0.02 0.05 

Garlic 0.1 no data 0.10 

Grass, range 15.0 1.79, 2.13 4 TBD 

Reassign 

Residue data are required. This 

tolerance should also be listed 

with other tolerances having 

regional restrictions. 

Horseradish 

1.0 <0.01-0.48 0.50 

Residue data support a lower 

tolerance. 

Kiwifruit 2.0 no data Revoke No registered uses. 

Leafy Vegetables 

(except Brassica) 20.0 

Celery: <0.01-1.0 

Head Lettuce: 0.01-16.8 

Leaf lettuce: 4.98-10.7 

Spinach: 9.04-18.2 

TBD 

No data are available 

supporting the use on leaf 

lettuce. Depending on the 

results from the requested leaf 

lettuce field trials, a tolerance 

on Leafy greens, subgroup 4A 

may be appropriate. The 

available celery field trial data 

will support a separate 

tolerance on Leaf petioles, 

subgroup 4B. 

Lettuce, head 

20.0 0.17-10.7 Reassign 

If supported by the requested 

leaf lettuce data, the separate 

tolerance for head lettuce 

should be deleted and a 

tolerance should be established 

for Leafy greens, subgroup 4A. 

Mushroom 6.0 <0.02-4.9 5.0 

Residue data support a lower 

tolerance. 

Onion, dry bulb 0.1 

<0.01-0.09 

(1.2x, 0 DAT) 0.10 

Peach 5.0 0.20-0.92 1.0 

Residue data support a lower 

tolerance with a 14-day PHI. 

62
Table 34. Tolerance Reassessment Summary for Permethrin. 

Commodity 

Current 

Tolerance 

(ppm) 

Range of Residues 

(ppm) 1 

Tolerance 

Reassessment 

(ppm) 

Comment/Correct Commodity 

Definition 

Pear 3.0 #0.02 

(1x-2x) Reassign 

Residue data support 

establishing a 0.05 ppm 

tolerance on pome fruits. 

Concomitant with establishing 

a 0.05 ppm tolerance on Fruit, 

pome, group 11, and the 

separate tolerance on pears 

should be deleted. 

Pepper, bell 

1.0 0.10-0.47 0.50 

Residue data support a lower 

tolerance. 

Pistachio 0.1 <0.008-0.093 0.10 

Potato 0.05 <0.01-0.04 0.05 

Soybean 0.05 <0.01-0.05 0.05 Soybean, seed. 

Spinach 20.0 9.04-18.2 20.0 

If supported by the requested 

leaf lettuce data, the separate 

tolerance for head lettuce 

should be deleted and a 

tolerance should be established 

for Leafy greens, subgroup 4A. 

Tomato 2.0 0.08-1.3 

(0.7x-1.8x) TBD 

The majority of the available 

data reflect 0.5x the maximum 

single use rate. Only limited 

data (6 samples) are available 

supporting the current use rate. 

New tomato field trial data are 

required. 

Vegetable, 

curcurbit, group 9 3.0 

Cucumbers: <0.036-0.52 

Melons: <0.01-1.2 

Squash: 0.11-1.27 

1.50 Current use pattern and residue 

data support a lower tolerance. 

Watercress 5.0 <6.4-15.5 Revoke No registered uses. 

Tolerances currently listed under 40 CFR §180.378 (c): 

Cattle, fat 3.0 0.88 5 1.50 Residue data support lower 

tolerances. Eggs were lowered 

to only 0.1 ppm to harmonize 

with the Codex MRL. 

Cattle, meat 0.25 0.064 0.10 

Cattle, meat 

byproducts 2.0 0.048 0.10 

Egg 1.0 0.023 0.10 

Goat, fat 

3.0 0.88 1.50 

Residue data support lower 

tolerances. 

Goat, meat 0.25 0.064 0.10 

Residue data support lower 

tolerances. 

Goat, meat 

byproducts 2.0 0.048 0.10 

Hog, fat 3.0 <0.01 0.05 

Hog, meat 0.25 <0.01 0.05 

Hog, meat 

byproducts 3.0 <0.01 0.05 

Horse, fat 

3.0 0.88 1.50 

Residue data support a lower 

tolerance. 

63
Table 34. Tolerance Reassessment Summary for Permethrin. 

Commodity 

Current 

Tolerance 

(ppm) 

Range of Residues 

(ppm) 1 

Tolerance 

Reassessment 

(ppm) 

Comment/Correct Commodity 

Definition 

Horse, meat 0.25 0.064 0.10 Residue data support lower 

Horse, m tolerances. eat 

byproducts 2.0 0.048 0.10 

Milk, fat 

6.25 

0.088 whole milk 

−2.20 milk, fat 3.0 

Residue data support a lower 

tolerance. Milk fat (reflecting 

0.0.88 ppm in whole milk) 

Poultry, fat 0.15 0.11 0.15 Maximum excepted residue in 

poultry meat and fat were 

estimated using data from the 

oral poultry metabolism study. 

Poultry, meat 

0.05 <0.01 0.05 

Poultry, meat 

byproducts 0.25 <0.01 0.05 

Residue data support a lower 

tolerance. 

Sheep, fat 

3.0 0.88 1.50 

Residue data support a lower 

tolerance. 

Sheep, meat 0.25 0.064 0.10 Residue data support lower 

Sheep, m tolerances. eat 

byproducts 2.0 0.048 0.10 

Tolerances currently listed under 40 CFR §180.378 (d): 

Collards 

20.0 1.48-11.27 15.0 

Residue data support a lower 

tolerance 

Papaya 1.0 0.610-0.697 1.0 

Turnip, greens 

20.0 0.30-8.25 10.0 

Residue data support a lower 

tolerance. 

Turnip, roots 

1.0 0.02-0.12 0.20 

Residue data support a lower 

tolerance. 

Tolerances needed under 40 CFR §180.378(a): 

grain, aspirated 

fractions 

None 0.386 6 0.50 

Residue data from a corn grain 

processing study indicate that a 

tolerance is required on 

aspirated grain fractions. 1 Unless otherwise indicated, the reported range of residues for permethrin are from commodities treated at 1x the 

maximum specified use rate and harvested at the minimum specified PHI. Rates other than 1x are reported in 

parentheses. 2 Residue ranges reflect residues in/on forage and hay harvested at a 0-day PHI following applications up to 0.1 lb ai/A or 

at a 14 day PHI for applications at 0.2 lb ai/A. 3 TBD = To be determined. Tolerance level cannot be determined at this time because additional data are required. 4 Results for the two samples of rangeland grass were originally reported on a dry weight basis (3.33, 4.42 ppm), but have 

been converted to a fresh weight basis. 5 For animal commodities, the residues are the estimated maximum residues for the 1x MTDB using data from the feeding 

studies or metabolism studies. 6 Calculated residue value bases on 19.3x concentration factor in aspirated grain fractions from corn and HAFT residues of 

0.02 ppm from field corn grain. 

a. Tolerances Listed Under 40 CFR §180.378(a) 

The temporary tolerance for residues of permethrin in/on cottonseed expired on 

November 15, 1997, and therefore 40 CFR §180.378(a) should be removed. 

64
b. Tolerances Listed Under 40 CFR §180.378(b) 

The tolerance expression and tolerances in 40 CFR §180.378(b) should be recodified as 

40 CFR §180.378(a)(1). Based on available residue data, the existing tolerances are adequate on 

almond, almond hulls, apple, avocado, Brussels sprouts, corn grain, filbert, garlic, dry bulb 

onion, pistachio, potato, soybean seeds, spinach and walnuts. Tolerances can be lowered for 

residues in/on alfalfa fresh and hay, artichoke (globe), cauliflower, celery, corn forage, stover 

and sweet, cucurbit vegetables, eggplant, horseradish, mushroom, peach, pear, and pepper (bell); 

the recommended tolerances are listed in Table 34. Tolerances for permethrin should be 

increased to 2.0 ppm in/on asparagus and broccoli and to 4.0 ppm in/on cherry. 

Tolerances on kiwifruit and watercress should be revoked as there are no registered uses 

for permethrin on these commodities, and these tolerances are no longer needed. 

Additional residue data are required to support the existing tolerances on cabbage, grass 

(rangeland), tomato, and leafy vegetables (excluding Brassica). The existing residue data on 

cabbage are incomplete, but indicate that the current 6 ppm tolerance may be too low. The 

existing residue data on tomatoes are also incomplete, but indicate that the current 2.0 ppm 

tolerance is likely to be adequate. The available rangeland grass data indicate that the current 15 

ppm tolerance may be too high. In addition, the tolerance for grass (rangeland) should be 

reassigned to §180.378 (d), as this is a regionally restricted use. 

The current crop group tolerance for leafy vegetables (excluding Brassica) is supported 

by adequate field trial data on celery, head lettuce, and spinach. However, no residue data are 

available on the representative commodity leaf lettuce, which is likely to incur the highest 

residues based its growth habit and the current use pattern. Although incomplete, the available 

data indicate that separate tolerances should be established for the leafy greens (4A) and leaf 

petiole (4B) subgroups of the leafy vegetable crop group, as residues in/on celery are 

substantially lower than on head lettuce and spinach. The existing celery data would support a 

general tolerance of 1.0 ppm for the Vegetable, leaf petiole, subgroup 4B. Once the requested 

leaf lettuce data are available, a separate tolerance should be established for the Vegetable, leafy 

greens, subgroup 4A. 

The apple and pear field trial data also indicate that a single tolerance of 0.05 ppm would 

be appropriate for Fruit, pome, group 11. Concomitant with establishing this crop group 

tolerance, the separate tolerances of apple and pear should be removed. 

c. Tolerances Listed Under 40 CFR §180.378(c) 

The tolerance expression and tolerances in 40 CFR §180.378(c) should be recodified as 

40 CFR §180.378(a)(2). Part 180.378(b) should be established for Section 18 emergency 

exemptions as is current Agency practice, and reserved. Sufficient data are available to ascertain 

the adequacy of the established tolerances on animal commodities provided that adequate data 

depicting the stability of permethrin in frozen animal matrices are submitted. 

Data from the ruminant and poultry feeding studies were used as the basis for reassessing 

65
tolerances. Based upon residue data from feeding studies and studies involving direct 

applications to livestock and their housing, dietary exposure to permethrin residues is the route 

that results in the highest potential residues in animal commodities. As feeding studies are not 

available for swine, the ruminant feeding studies were used to reassess tolerances for hogs. 

For tolerances on commodities of cattle, goats, horses, and sheep, the available data 

indicate that the tolerances for fat, meat, meat byproducts, and milk fat should be lowered to 1.50 

ppm, 0.10, 0.10 ppm, and 3.0, respectively. The tolerance for fat of hogs, hog meat and meat 

byproducts can be lowered to 0.05 ppm. 

For poultry commodities, the 0.15 ppm tolerance for fat is adequate. Tolerances for 

poultry meat and meat byproducts should be lowered to 0.05 ppm, and the tolerance for eggs 

should be lowered to 0.10 ppm. 

d. Tolerances Listed Under 40 CFR §180.378(d) 

The tolerance expression and tolerances in 40 CFR §180.378(d) should be recodified as 

40 CFR §180.378(c) for regional registrations as is current Agency practice. Part 180.378(d) 

should be established for indirect or inadvertent residues, as is current Agency practice, and 

reserved. Sufficient data are available to ascertain the adequacy of the established tolerances 

with regional registration for papayas and turnip roots and tops. The current 1.0 ppm tolerance 

in/on papaya is adequate and the available turnip data indicate that tolerances for turnip roots and 

tops can be lowered to 0.20 and 10.0 ppm, respectively. 

Additional data are required on collards before the tolerance level can be determined, but 

the currently available data would support lowering the tolerance to 15.0 ppm. 

e. New Tolerances Needed Under 40 CFR §180.378(a)(1) 

The available corn grain processing study indicates that a tolerance is required on 

aspirated grain fractions (grain dust). Based on the HAFT residues for field corn grain of 0.02 

ppm and the observed processing factor of 19.3x for grain dust, the maximum expected residues 

in corn grain dust would be 0.386 ppm. These data would support establishing at tolerance of 

0.50 ppm for residues of permethrin in grain, aspirated fractions. 

As indicate above, the available celery, apple and pear field trial data support establishing 

crop group tolerances for the leaf petiole vegetables subgroup 4B and the pome fruits group 11. 

E. Regulatory Rationale 

The following is a summary of the rationale for mitigation measures necessary for 

managing risks associated with the use of permethrin for permethrin products to be eligible for 

reregistration. Where labelling revisions are warranted, specific language is set forth in the 

summary table of Section V. 

1. Human Health Risk Management 

66
a. Dietary (Food and Drinking Water) Risk Mitigation 

Acute dietary (food and drinking water) risk is below the Agency’s level of concern; 

acute dietary risk estimates are 4% of the aPAD for the general U.S. population, and 16% for 

infants, the subgroup most exposed. Additionally, the chronic dietary (food and drinking water) 

risk is below the Agency’s level of concern; risk estimated are <1% cPAD for the general U.S. 

population and all population subgroups. The estimated cancer dietary (food and drinking water) 

risk, 1.1 x 10-6, is within the negligible risk range of up to 3 x 10-6, and is also below the 

Agency’s LOC. No mitigation is required to address dietary risks. 

b. Residential Risk Mitigation 

A dermal absorption factor was used for the dermal part of the cancer equation for 

residential. The Agency calculated the dermal absorption factor from an oral to dermal toxicity 

ratio (oral exposures LOAEL of 75/dermal NOAEL of 500), and concluded 15% is appropriate 

for the dermal part of the cancer equation for cancer risk assessment. 

The permethrin registrants and the PIRTF believe that 15% is still a highly conservative 

factor, and requested that the Agency employ a weight-of-the-evidence approach to determine 

the human dermal absorption factor for permethrin from existing peer-reviewed published 

studies and registrant-submitted data which, in this view, supports a 2-5% dermal absorption 

factor. The Agency previously concluded that the dermal penetration study submitted by the 

registrants to support a 2-5% dermal absorption factor does not satisfy the basic criteria for an in 

vivo survival primate study, and therefore, was determined to be scientifically unacceptable. 

Further, the Agency contends that after consideration of other data available for permethrin, a 

weight-of-evidence approach was utilized to reduce the dermal absorption factor to 15%. Again, 

this value is considered to be a conservative high-end estimate because the oral dose represents a 

LOAEL rather than a NOAEL. 

Although the Agency recognizes that the 15% dermal absorption factor used for 

residential risk assessment is a conservative high-end factor, without an additional guideline 

dermal absorption study, the Agency does not have the confidence to further reduce the dermal 

absorption factor. However, if a guideline dermal absorption study were voluntarily submitted, 

the Agency would review the data and consider the results with the risk assessments and risk 

mitigation measures for this RED. 

i. Residential Handler 

The Agency assessed the potential non-cancer (dermal and inhalation) and cancer risks to 

homeowners handling (mixing, loading, and applying) permethrin products in residential settings 

(indoor and outdoor). All handler scenarios assessed were below the Agency’s non-cancer LOC 

(MOEs ≥100). However, the Agency is concerned with the potential cancer risks associated with 

exposure a homeowner could receive when mixing, loading, and applying emulsifiable 

concentrate (EC) formulation of permethrin to horses via sponge (see Table 7). 

67
Mitigation for Sponge Application of EC formulation 

This scenario reached the Agency’s cancer LOC (≤3 x 10-6) after 2 exposure events (2 

days) per year. Current registered labels recommend this application for use on horses, foals, 

dogs, cats and kittens to treat numerous pests, such as face flies, stable flies, deer flies, fleas, 

ticks, mosquitoes, gnats, mites, chiggers, and lice. Additionally, the labels recommend for initial 

treatment to apply to the animal daily, and as the infestation subsides, reapply every 2-3 days as 

needed. Given the broad range of target pests, coupled with the re-treatment instructions, the 

Agency believes an individual using a permethrin product for this purpose will be exposed more 

than 2 times per year. 

To determine the potential exposure a homeowner could receive for this scenario, the 

Agency relied on Chemical Manufacturers Association antimicrobial wipe exposure data, which 

is the best available data for the sponge application scenario. However, as stated in Section III, 

the Agency has concerns regarding the quality of the data and believes exposure data specific to 

this scenario would be more reliable, and potentially result in a reduced risk estimate. However, 

neither the technical registrants nor any member of the PIRTF have volunteered to conduct 

exposure data to support this application method. 

Therefore, to mitigate the risks associated with this use, the registrants have agreed to 

discontinue the use of sponge application for products applied as a liquid, and amend their 

respective labels appropriately (see Section V, Table 35). Other application methods are 

available for this use, such as RTU wipes, RTU pour-on, and RTU trigger pump sprays. The 

Agency assessed these alternative application methods in the residential handler risk assessment 

and both non-cancer and cancer risk estimates for all scenarios were below the Agency’s noncancer and cancer LOCs, respectively. 

ii. Residential Post-Application 

The non-cancer dermal, inhalation and oral risks from post-application exposure to 

permethrin are below the Agency’s LOC for residential adults and youth aged children (MOEs 

ranged from 120 to 500 billion). Additionally, most of the toddler non-cancer risk estimates are 

also below the Agency’s LOC (MOEs ranged from 140 to 250 billion); however, the incidental 

oral and dermal risk estimates for toddlers exposed to post-application of permethrin on carpets 

by directed surface sprays were above the Agency’s non-cancer LOC (MOEs <100). The MOEs 

are 37 and 69 for oral and dermal exposures respectively. 

Additionally, all post-application outdoor and pet contact activities were below the 

Agency’s cancer LOC. Based on the REJV survey data, a typical homeowner uses permethrin 

products approximately 5 times per year. The number of exposure events per year for these 

scenarios to reach the Agency’s cancer LOC ranged from 18 to 365 days. However, two indoor 

scenarios assessed were of concern to the Agency; 1) post-application exposure treated with 

permethrin products by directed carpet sprays (broadcast and crack and crevice) and 2) total 

release foggers. These scenarios reached the Agency’s cancer LOC in <1 and 2 events per year, 

respectively. Moreover, the Agency assumed 8 hours of exposure for carpet sprays, and 4 hours 

for vinyl flooring. Additionally, the post-application risk assessment assumed exposure to 

68
permethrin residues the same day the area was treated (i.e., day 0 residue), which are considered 

reasonably conservative assumptions, considering indoor residues are removed over time 

through cleaning and other indoor activities. 

To address the non-cancer and cancer risks associated with these post-application 

scenarios, the following mitigation measures are to be implemented. 

Mitigation for Indoor Directed Surface Sprays: 

The permethrin registrants and PIRTF members suggested that 1% ai was a high-end 

concentration, and a large majority of indoor products for either PCO or consumer use contains 

0.5% ai or less. The Agency’s Standard Operating Procedure, which is based on a number of 

indoor deposition studies, identifies the ISR for 0.5% broadcast sprays as 15 μg/cm2, and 7.5 

μg/cm2

 for crack and crevice treatment. The Agency calculated comparison cancer risk 

estimates for 0.5% ai broadcast products using a 15% dermal absorption factor. As a result, 

these products also reached the Agency’s cancer LOC in <1 event/year. Additionally, the 0.5% 

crack and crevice sprays reached the Agency’s cancer LOC in approximately 2 events/year. 

Based on these comparison risk assessments, a reduced application rate would not mitigate the 

cancer risks of concern. 

The registrants also pointed to the conservative dermal absorption factor used in the 

cancer risk assessment. To determine if a reduced dermal absorption factor would significantly 

reduce the risks, the Agency calculated potential risk estimates using a hypothetical 10% and 5% 

dermal absorption factor for 0.5% ai concentrated products. The Agency determined that for 

both broadcast and crack and crevice applications, neither a 10% nor a 5% reduced dermal 

absorption factor would significantly increase the number of exposure events to a level that 

would be below the Agency’s cancer LOC. However, if a guideline dermal absorption study was 

voluntarily submitted, which supported a dermal absorption factor less than 5%, the Agency may 

consider the results following this RED determination. 

According to the PIRTF, the majority of RTU sprays contain 0.5% ai permethrin or less. 

Therefore, the Agency assessed a 0.5% ai spray, based on a pyrethrin and piperonyl butoxide 

deposition study following the use of an aerosol spray submitted by the Non-Dietary Exposure 

Task Force, with an ISR of 0.21 μg/cm2. The Agency believes aerosol sprays and trigger pump 

sprays will result in similar deposition. These application methods are used on indoor surfaces, 

but unlike the indoor broadcast and crack and crevice applications used by PCOs, they are 

mostly consumer products used more as spot treatments, thus, the deposition is considerably less 

than the directed sprays intended to treat larger areas. Both the non-cancer and cancer risk 

estimates for application of aerosol sprays on indoor surfaces (hard and carpet) were below the 

Agency’s LOC. For carpet and vinyl floors, the post-application MOEs for toddlers, the most 

sensitive sub-population, are 8,500 and 35,000 (oral route) and 16,000 and 84,000 (dermal 

route), respectively. Also, for the US general population, the number of events per year it takes 

the cancer LOC to reach the negligible risk range are 57 and 114, respectively, which is 

significantly greater than the average number of times per year permethrin products are used in 

the home in this manner, according to the REJV survey. 

69
Therefore, in order to mitigate the non-cancer and cancer risks, the registrants have 

agreed to discontinue all directed spray application methods (i.e., low pressure handwands, ULV 

cold foggers, and backpack sprayers) for use on indoor surfaces, and amend their respective 

labels as appropriate (see Section V, Table 38). RTU consumer sprays, such as aerosol and 

trigger pump sprays, will be the only application methods for use on indoor surfaces. Based on 

its risk assessment, the Agency is limiting RTU sprays to concentrations of 0.5% ai or less. 

However, the Agency acknowledges that there are specialized sprays with higher concentrations, 

up to 3% ai, which are intended to be injected directly into cracks and crevices and behind walls 

or spaces, and therefore, result in little to no potential exposure. The Agency will consider these 

products if the registrants for these products are able to provide justification or data to the 

Agency which demonstrate that little to no exposure will occur due to the specialized use of the 

product. The registrants have agreed to limit use of all aerosol sprays with a concentration of no 

more than 0.5% ai of permethrin, and amend their respective labels as appropriate (see Section 

V, Table 38). 

Mitigation for Indoor Total Release Foggers 

The Agency assessed a 0.58% ai concentrated indoor total release fogger (TRF) with a 

maximum application rate of 0.0023 lb ai/6 oz fogger, which is labeled to treat 6000 cubic feet 

(ft3) or less. A permethrin specific deposition study was available to the Agency, which 

determined the ISR for a 0.5% ai concentrated 6 oz TRF to be 4.8 μg/cm2 when treating a space 

approximately 2000 ft3. Therefore, the Agency used an ISR of 4.8 μg/cm2 in both its non-cancer 

and cancer risk assessments. 

The non-cancer risk estimates on both hard surfaces and carpets were below the 

Agency’s LOC for both adults and toddlers. However, the cancer risk estimate for total release 

foggers reached the Agency’s cancer LOC in 2 exposure events/year for carpet, and 5 exposure 

events/year for vinyl surfaces. This estimate assumes that an individual is exposed to permethrin 

residues the day of treatment, and is engaged in high contact activities, such as exercising or 

playing, for 8 hours on carpet and 4 hours on vinyl. According to the registrants, a single 

permethrin active ingredient fogger loses efficacy below approximately 0.48% ai. However, 

there are combination products registered that contain permethrin with other chemicals, often 

other pyrethroids, and a synergist, such as PBO. These combination products contain 

approximately 0.25% of permethrin or less. The Agency calculated the potential cancer risk 

estimate from a TRF with a 0.25% ai concentration (ISR of 2.4 μg/cm2

). The risk estimates 

reached the Agency’s LOC after 5 exposure events and 33 exposure events for carpet and vinyl 

surfaces, respectively. According to the REJV survey data, a typical homeowner will use a TRF 

approximately 3 times per year. Therefore, the Agency believes the use of permethrin TRF 

products with 0.25% ai concentration or less are below the Agency’s LOC, and are eligible for 

reregistration. 

In order to mitigate the cancer risks associated with this use, the registrants have agreed 

to limit all TRF products to no more than 0.25% ai permethrin. The Agency will consider 

products with higher concentrations if the registrants of the products can provide justification or 

data to the Agency which demonstrates that an equivalent ISR of 2.4 μg/cm2

, or less, will result 

in a room size of 2000 ft3

 or less. 

70
Further, unlike the indoor surface sprays, a reduced dermal absorption factor does 

significantly decrease the risk associated with post-application exposure to a 0.5% ai 

concentrated permethrin TRF. Using a hypothetical 10% dermal absorption factor, the risk 

estimates reach the Agency’s LOC in 4 and 8 exposure events for carpet and vinyl, respectively; 

and using a hypothetical 5% dermal absorption factor, the risk estimates reach the Agency’s 

LOC in 8 and 16 exposure events, respectively. As stated in the discussion of the dermal 

absorption study above, the Agency may consider the results of a guideline dermal absorption 

study, which is proposed to be voluntarily conducted and submitted by the registrants, following 

this RED determination. 

iii. Other Residential Uses To be Addressed in RED 

Outdoor Residential Misting Systems 

As stated in Section III, the Agency considered post-application exposure to adults and 

toddlers who are exposed to permethrin from an outdoor residential misting system pesticide 

application. These systems are fairly new to the pesticide market, and vary in their system 

design. Based on outreach to the permethrin registrants and review of labels currently registered 

for use in these systems, the Agency used the following assumptions in the permethrin risk 

assessment: 

• The breathing rates utilized were: 

o adult breathing rate for moderate activity is 1.6 m3

/hour, and 

o toddler breathing rate for light activity is 0.8 m3/hour. 

• Cubic feet treated is based on the assumption that nozzles are placed at 10 feet from the 

ground (e.g., on eaves) creating a ceiling of 10 feet in height; 

• The emission is to be treated as an “instant release” scenario where all active ingredient is 

assumed to be released in the air immediately (this is assumed to represent a conservative 

approach); and 

• It was assumed that in an individual (toddler or adult) was exposed to one nozzle that 

released 1.5 fl. oz. in a one minute period of time. 

As stated in section III, based on these assumptions, the Agency has no risk concerns 

associated with post-application exposure to permethrin from outdoor residential misting 

systems. However, the Agency recognizes that due to the variation in the systems’ design and 

the way in which the systems are installed, these assumptions may not be inclusive of all systems 

available in the market. However, the Agency did not receive any comments on the assumptions 

used in the permethrin risk assessment during the Phase 3 public comment period. 

Statutory Requirements 

Further, the distribution or sale, and use of pesticides in outdoor residential misting 

systems are subject to several statutory requirements. At this time, permethrin, pyrethrins, and 

piperonyl butoxide (PBO) appear to be the only chemicals used in outdoor residential misting 

systems; however, it is possible that other pesticide registered for residential outdoor use to 

71
might also be used in a similar systems. Section 2(ee)(3) of FIFRA permits the use of any 

application methods that are not prohibited by the pesticide’s labeling; however, the application 

must only be to target sites specified by the labeling and at no more than the maximum dosage 

rates specified by the labeling. Since most pesticide labels do not explicitly prohibit use in 

outdoor residential misting systems, other chemicals that target similar pests could be used in 

these misting systems. The Agency is not aware of other pesticides being used in outdoor 

residential misting systems, and therefore, has not assessed the potential risks to homeowners 

associated with use of pesticides in these systems from pesticides other than permethrin, 

pyrethrins, and PBO. 

All permethrin, pyrethrins, and PBO registrants that do not support outdoor residential 

misting systems use for their products, will be expected to amend their Manufacturing Use 

Product label to state the following, “This product must not be formulated into an end use 

product for use in outdoor misting systems.” Additionally, all registrants of permethrin, 

pyrethrins, and PBO wettable powder or EC formulated EPs, with outdoor residential use, will 

be expected to include a statement prohibiting use in an outdoor residential misting system or 

include separate and specific instructions for use in outdoor residential misting systems, 

including the maximum application rate per day, use directions, and restrictions specified in 

Section V, Table 38. Although this action will only address permethrin, pyrethrins, and PBO 

products, the Agency plans to issue broader guidance pertaining to use of outdoor misting 

systems, and the pesticides which can be used in these systems, as part of its on-going effort to 

standardize the way in which these systems are used. 

Finally, in accordance with FIFRA Section 2(e)(1) and (gg), leaving unapplied pesticide 

at a use site constitutes the distribution or sale of a pesticide. In order to be in compliance with 

FIFRA, companies which sell, install, and service outdoor residential misting systems must 

ensure that one of the following transactions occur when providing these services: 

• the unopened registered pesticide is distributed or sold to the use site owner prior to 

mixing and loading into the equipment; or 

• the diluted registered pesticide is distributed or sold as a custom blend in accordance with 

EPA’s custom blending policies at 3.4 and 7.1 of the Enforcement Policy Compendium; 

or 

• the diluted pesticide is registered and is distributed or sold to the use site owner prior to 

loading into the equipment. 

Although the Agency’s post-application assessment for adult and toddler exposure to 

permethrin via outdoor residential misting systems indicates exposures below the Agency’s 

LOC, several issues, in addition to those discussed above, have been raised to the Agency 

through State FIFRA Issues Research and Evaluation Group issue papers, stakeholder forums 

and comments, and other sources regarding the use of these systems. These issues include, but 

are not limited to, the potential for inadvertent exposure and risks to residents, misuse of the 

systems and pesticide products, offsite drift and potential exposure to non-target organisms, and 

resistance issues. The Agency is aware of a cooperative effort lead by the National Pest 

72
Management Association involving state and industry stakeholders, and pest management 

professionals to standardize these systems and address the issues raised above, and intends to 

continue to address these on-going issues through continued involvement and discussions with 

the States, industry and stakeholder groups. 

The Agency is providing a 60-day comment period after the publication of the RED to 

solicit feedback on the assumptions used in the permethrin risk assessment, the required label 

language in Section V, Table 38, and the statutory requirements addressed above. 

Permethrin Impregnated Fabrics 

The Agency has approved methods for impregnating fabric with permethrin when 

treating bulk fabric (prior to being cut and constructed) and treating the finished fabric (after 

being cut and constructed into an article of clothing, tents, netting, etc.). The issue has been 

raised to the Agency that several different finishing processes i.e., pre-washing, dying, 

permanent press etc. can occur, before a fabric is finished which may compromise the efficacy of 

the permethrin treatment. 

Further, the labeling of current impregnated fabric products claim to retain a level of 

permethrin that is efficacious up to 25 washings. The Agency has received comment that 

depending on the manufacturing method, the claims may not be accurate and that the product 

may lose efficacy in less than 25 washings. 

To address these uncertainties, the Agency is requiring product specific efficacy data for 

all permethrin impregnated fabric products, and wash-off data to support the efficacy claims. 

Refer to the product-specific data call-in (PDCI) for more detail regarding the required data. 

c. Aggregate Risk Mitigation 

Acute Aggregate Risk 

For permethrin, the acute aggregate risk estimates are the same as those presented in the 

acute dietary (combined food and drinking water) risk section of this document. Since acute 

aggregate risks are below the Agency’s LOC, no mitigation is necessary. 

Short-Term Aggregate 

This section describes the aggregate (combined) risk from food, drinking water, and 

short-term residential exposures, as well as risk refinements and the mitigation measures that 

need to be implemented to manage risks of concern. As noted above in Section III of this 

document, short-term aggregate risks for the U.S. general population and adult females were 

below the Agency’s LOC. However, the short-term aggregate risk for toddlers exceeded the 

Agency’s LOC for one scenario, with an aggregate MOE of 24, due to the incidental oral and 

dermal risks associated with post-application exposure to indoor carpets treated with directed 

sprays (see Table 12). In order to mitigate these risks, the registrants agreed to discontinue use 

of directed spray applications on indoor surfaces. As a result, aerosol cans will be the only 

73
remaining application method. This measure reduces the toddler non-cancer incidental oral and 

dermal exposures, thus increasing the MOEs to 8,500 and 16,000, respectively. Provided these 

mitigation measures are implemented, the short-term aggregate risks are below the Agency’s 

LOC and no further mitigation measures are necessary. Moreover, the Agency believes it is still 

appropriate to include this post-application scenario in the short-term aggregate risk assessment 

because, according to the preliminary results of the REJV survey, permethrin use on lawns and 

on indoor crack and crevice sites account for the most use in the residential market place, and are 

likely to co-occur. Thus, Table 35 summarizes the short-term aggregate scenarios that 

previously were of concern and the new risk results based on mitigation measures detailed 

above. 

Table 35: Short-Term Aggregate Risk with Mitigation 

Population 

Short-Term Scenario 

Previous Short-Term Aggregate MOE 

[Food, Drinking Water and Residential (Lawn 

Care and Indoor Surface Spray on Carpet)] 

Revised Short-Term Aggregate MOE 

 [Food, Drinking Water and Residential (Lawn 

Care and Indoor Aerosol Spray on Carpet)] 

Toddler 24 4709 

Cancer Risk 

Similar to the short-term aggregate risk assessment, the indoor surface spray application 

was the risk driver for the cancer aggregate risk scenario that was above the Agency’s level of 

concern. With implementation of the same risk mitigation measures to address the short-term 

aggregate risks of concern, the cancer risk estimate on the first day of application for aerosol 

sprays to treat indoor carpets is 5.7 x 10-8, and takes 18 exposure events per year to reach the 

Agency’s LOC. Table 36 summarizes the cancer aggregate scenario that was previously of 

concern and the new risk results based on mitigation measures detailed above. 

Table 36: Cancer Aggregate Risk with Mitigation 

Population 

Short-Term Scenarios 

Previous Short-Term Aggregate Cancer Risk 

[Food, Drinking Water and Residential (Lawn 

Care and Indoor Surface Spray on Carpet)] 

Revised Short-Term Aggregate Cancer Risk 

 [Food, Drinking Water and Residential (Lawn 

Care and Indoor Aerosol Spray on Carpet)] 

U.S. Pop 1.5 x 10-5 1.1 x 10-8 

d. Occupational Risk Mitigation 

It is the Agency’s policy to mitigate occupational risk to the greatest extent practical and 

feasible. Occupational exposure assessments are completed by the Agency considering the use 

of baseline PPE, and, if warranted, for handlers, increasing levels of PPE and engineering 

controls in order to estimate the potential impact on exposure and risk. The target MOE for 

permethrin is 100, based on information provided in Section III of this document. For 

occupational cancer risks, estimates within the negligible risk range of up to 3 x 10-6 do not 

exceed the Agency’s level of concern. When occupational MOEs are estimated to be less than 

74
100 or occupational cancer risk estimates exceed the general range of ≤3 x 10-6, EPA strives to 

reduce worker risks through the use of PPE and engineering controls or other mitigation 

measures. The Agency generally considers occupational cancer risks in the general range of 1 x 

10-6 or less to be negligible, but may accept risks as high as 1 x 10-4 when all mitigation 

measures that are feasible and practical have been applied, particularly when there are critical 

pest management needs associated with the use of the pesticide. 

Mitigation measures may include reducing application rates, adding PPE to end-product 

labels, requiring the use of engineering controls, and other measures. Levels of PPE considered, 

as described in Tables 14 and 15, and applicable to the proposed mitigation are described below: 

• Baseline, or long-sleeve shirt, long pants, no gloves, and no respirator. (Baseline) 

• Baseline plus chemical-resistant gloves, and no respirator. 

• Coveralls worn over long-sleeve shirt and long pants, chemical-resistant gloves, and 

no respirator. 

• Baseline plus chemical-resistant gloves and an 80% PF (quarter-face dust/mist) 

respirator. 

• Coveralls worn over long-sleeve shirt and long pants, chemical-resistant gloves, and 

an 80% PF (quarter-face dust/mist) respirator. 

• Engineering Controls, or closed mixing/loading system, enclosed cab, or enclosed 

cockpit. 

A wide range of factors are considered in making risk management decisions for worker 

risks. These factors include, in addition to the estimated MOEs and cancer risk estimates, 

incident data, the nature and severity of adverse effects observed in the animal studies, 

uncertainties in the risk assessment, alternative registered pesticides, the importance of the 

chemical in integrated pest management (IPM) programs, and other factors. 

Similar to the residential cancer risk assessment, a dermal absorption factor of 15% was 

used for the dermal part of the cancer equation for the occupational cancer risk assessment. As 

discussed above, the registrant may voluntarily conduct a guideline dermal absorption study to 

refine this estimate; however, unlike for some residential exposure scenarios, a reduced dermal 

absorption factor is not expected to significantly affect the risk mitigation for any of the 

occupational risks discussed below. 

i. Handler Risk Mitigation 

As stated in Section III, most of the non-cancer and cancer risk calculations for 

occupational handlers were below the Agency’s LOC when handlers wore baseline PPE and 

gloves. However, as summarized in Tables 14 and 15, some handler scenarios required 

additional PPE to be below the Agency’s non-cancer and cancer LOCs, respectively. Therefore, 

specific mitigation measures and additional data needs are necessary to address these risk 

concerns. Following the implementation of the formulation specific and activity specific risk 

mitigation measures, handler risks will no longer be of concern to the Agency. The registrants 

have agreed to the following mitigation: 

75
Mixing, Loading and Applying Emulsifiable Concentrate (EC) and Granular Formulations 

All non-cancer risk estimates are below the Agency’s LOC for workers handling the 

granular formulation of permethrin (MOEs ≥1700) with baseline PPE and gloves. Additionally, 

all cancer risk estimates were ≤1.2 x 10-6 with the same level of PPE, which is within the 

negligible risk range of ≤3 x 10-6 and not of risk concern. 

For all handlers scenarios of the liquid (EC) formulations, except for those which utilize 

handheld equipment (i.e., handwands, handgun sprayers, backpack sprayer, etc.), all non-cancer 

risk estimates are below the Agency’s LOC (MOEs ≥1500) with baseline PPE and chemicalresistant gloves, and all cancer risk estimates were ≤2.6 x 10-6 with the same level of PPE, which 

is also within the negligible risk range of 1 x 10-6 and not of risk concern. For handlers of the EC 

formulation with handheld equipment, all non-cancer risk estimates are below the Agency’s 

LOC (MOEs ≥160) with baseline PPE and chemical-resistant gloves, and all cancer risk 

estimates were ≤2.8 x 10-5 with the same level of PPE. Since additional PPE (i.e., double-layer 

clothing, respirator, etc.) beyond baseline PPE and gloves will only marginally reduce the cancer 

risk estimates, and instead may cause additional heat related stress to workers, the Agency has 

determined additional PPE will be an undo burden and is not required. Therefore, products 

containing the EC or granular formulations of permethrin are eligible for reregistration provided 

the following PPE is required on the labels: baseline PPE and chemical-resistant gloves. 

Mixing, Loading, and Applying Wettable Powder (WP) Formulations 

The non-cancer and cancer risk estimates for workers handling WP in the scenarios 

identified Table 14 and 15, respectively, require additional risk mitigation measures in order for 

scenarios with the WP formulation to be below the Agency’s LOC. The Agency determined that 

engineering controls (i.e., water soluble packages) significantly reduce the non-cancer and cancer 

risks associated with mixing and loading activities (all MOEs >100; MOEs range from 5700 to 

420000, and cancer risk estimates are less than 1 x 10-6). Additionally, the Agency believes that 

the reduced exposure to mixers/loaders/applicators as a result of the engineering controls does 

not require additional PPE, and thus, baseline and chemical-resistant gloves are protective. 

Therefore, in order to be eligible for registration, the following mitigation measures are required: 

1) wettable powder formulations must be packaged in water soluble bags (see Table 38 for PPE 

requirements for engineering control), and 2) all mixers and loaders plus applicators using 

handheld equipment applicators must wear baseline PPE and chemical-resistant gloves (except 

RTUs and products applied as fogs or dips, see below). An apron will also be required for 

handlers exposed to the concentrate and applicators applying liquid via dip application to 

animals as specified below. 

Mixing, Loading and Applying Dry Flowables 

Although permethrin is not currently manufactured into a dry flowable formulation, one 

technical registrant stated the company would prefer to change over all its WP products to dry 

flowable products, instead of packaging the WP products in water soluble bags as required for 

reregistration. Because there are no current registrations of permethrin products formulated as 

dry flowables, an assessment was not conducted to evaluate worker risks associated with the use 

of these products. However, available information on the units of exposure for both dermal and 

76
inhalation routes indicate that they are significantly less for dry flowable formulations than for 

liquid formulations. As a result, the Agency believes the level of PPE required for mixing, 

loading, and applying liquid (EC) formulation products of permethrin will be protective for 

workers handling dry flowables. Therefore, baseline PPE and chemical-resistant gloves would 

be required for mixing, loading, and applying dry flowable formulation products, if 

manufactured. 

Mixing, Loading, and Applying Dusts 

The non-cancer and cancer risk estimates for workers handling dusts in the scenarios 

identified Table 14 and 15, respectively, require additional risk mitigation measures in order for 

scenarios with the dust formulation, for which there is available data, to be below the Agency’s 

LOC. The non-cancer risk estimate for loading the dust formulation into a mechanical duster 

(poultry use based on the assumption that 100,000 animals are treated each day) requires 

baseline PPE, chemical-resistant gloves and a PF5 respirator to be below the Agency’s noncancer LOC (MOE=780). The cancer risk for this scenario is 1.6 x 10-5 with this level of PPE; 

however, additional PPE only marginally decreases the risk estimate. For example, with the 

maximum PPE feasible for this scenario (i.e., double layers, gloves, and a PF10 respirator), the 

cancer risk estimate is decreased to only 1.1 x 10-5. In addition, the assumption that 100,000 

animals are treated daily is a high-end estimate and is likely not to be generally performed. 

Considering the high-end assumption used to estimate the handler risks for this particular 

scenario, and the fact that additional PPE beyond baseline PPE, gloves, and a PF5 respirator will 

not measurably reduce exposure, and instead may cause additional heat related stress to the 

worker, the Agency has determined additional PPE to be an undo burden and is not required for 

loaders. Additionally, all other loading scenario assessed for the dust formulation resulted in 

MOEs ≥ 3 million, and cancer risk estimates ≤4.1 x 10-9 with the same level of PPE. Therefore, 

the Agency believes baseline PPE, chemical-resistant gloves, and a PF5 respirator is protective 

of both non-cancer and cancer risks for all scenarios, and is required for loaders handling the 

dust formulation. 

The Agency did not have exposure data to assess the potential exposure to workers 

applying the dust formulation via shaker can, mechanical duster, or dust bag. Dust applications 

are made to livestock animals, dogs, and cats. The Agency believes little to no exposure to 

applicators will occur with the mechanical duster and dust bag application methods because 

applications are not made manually. Although applications via shaker can are made manually to 

either a single animal (dog or cat) or to a smaller number of livestock animals, the shaker can is 

rarely used in an occupational environment. Therefore, the Agency believes the PPE protective 

of non-cancer and cancer risks for loaders will also be protective for applicators. Thus, dust 

formulations are eligible for reregistration provided baseline PPE, chemical-resistant gloves, and 

a PF5 respirator are required for all handler activities, and the Agency will not be requiring 

additional data. 

Applying RTU Products 

Although there is no available data to assess potential occupational risks associated with 

the application of RTU permethrin products, such as RTU wipes, ear tags, animal shampoos and 

77
spot-ons, and protective flanges, etc., the Agency believes there will be little to no exposure to 

handlers and that any potential exposure will be adequately reduced by the use of gloves, since 

handler scenarios for agricultural uses, which involve much higher volumes of product, are 

adequately protected with the same level of PPE. Therefore, in order for RTU permethrin 

products to be eligible for reregistration, baseline PPE and chemical-resistant gloves are 

required, and the Agency will not be requiring additional data. 

Applying Liquids via Dip 

Exposure data is not available to assess the potential risks associated with applying liquid 

products via dip applications. Currently, the dip application method is registered to treat military 

battle dress (MBD), as well as to treat livestock animals, dogs, and cats. Permethrin is used by 

the U.S. Department of Defence to treat MBD while in the field. The dip is provided to the 

servicemen and women in a RTU package with plastic gloves provided. Based on this use 

scenario, the Agency believes little to no exposure will occur to the individual treating his/her 

MBDs with a RTU dip, and that baseline PPE and chemical-resistant gloves, the PPE required 

for all liquid formulations, will be adequately protective. 

Further, the Agency believes little exposure will occur with dip applications to livestock 

animals. The animals move through the dip relatively unaided, and are primarily handled prior 

to entering the dip and afterwards. Individuals treating smaller animals, such as dogs or cats, via 

dip will possibly receive more exposure since they will most likely be lifting the animal in and 

out of the dip. The Agency believes that based on the non-cancer and cancer risk estimates for 

occupational handlers using the liquid formulation of permethrin for agricultural crop uses, 

which involve much higher volume of product, baseline PPE and chemical-resistant gloves will 

be adequately protective for all dip applications as well. However, to reduce additional exposure 

that may result from potential splashing of the product onto the individual during the dip 

application, the Agency is additionally requiring chemical-resistant aprons to be worn for animal 

use. 

Applying Liquids via Handheld Cold Foggers and Fog/Mist Generators 

A cold fogger is a handheld ULV application method that is used to treat a number of 

indoor spaces, such as mushroom houses, animal premises, and warehouses. The Agency does 

not have permethrin specific data for this application method; however, the exposures for the 

hand held ULV fogger application were based on surrogate data from a pulse fogger application 

in a greenhouse (Nigg, 1987). The exposure data used in the risk assessment to estimate the 

potential risk to occupational handlers using ULV cold fogger application equipment reflect the 

dermal and respiratory exposure from the use of hand held backpack foggers in a greenhouse. 

The applicators in this study were wearing chemical resistant protective clothing (Tyvek 

coveralls) over long sleeve shirt and long pants, gloves, boots, and goggles. Although this study 

is the best available data to use as surrogate data for the ULV cold fogger application method, 

the Agency believes there are uncertainties with this data because the study only has three usable 

replicates. 

The workers in this study were wearing chemical resistant protective clothing (Tyvek 

78
coveralls); generally the Agency does not require workers to wear Tyvek coveralls because of 

concerns over potential heat stress related injuries. Therefore, the Agency believes that double 

layer PPE (coveralls over long pants and long sleeved shirt with socks and shoes) with gloves 

will be protective because the dermal exposure an individual will receive from using a cold 

fogger is likely equivalent to the dermal exposure he/she will receive when applying a liquidbased spray of permethrin via any high pressure handheld application method. 

Fog/mist generators are registered for use in similar indoor areas. However, they are not 

handheld; instead, soon after the product is released the worker leaves the space. Therefore, the 

Agency believes the potential exposure a worker will receive from application of permethrin via 

a fog/mist generator is less than a handheld cold fogger. Thus, the level of PPE required for cold 

fogger applications will be adequately protective for fog/mist generator applications. 

The Agency has determined that permethrin products that are applied with cold foggers 

and fog/mist generators on indoor areas are eligible for reregistration given the following PPE is 

required: double layer PPE, and gloves. However, confirmatory dosimetry data for cold fogger 

applications indoors is required. Given that the Agency believes the potential exposure from a 

cold fogger will be greater than the potential exposure from a fog/mist generator, the outcome of 

the dosimetry data for cold foggers will be protective of the fog/mist generator use and, 

therefore, additional exposure data for fog/mist generators is not required. 

Applying Liquid Formulations via High Pressure Handwand in Mushroom Houses 

The Agency previously assessed the use of high pressure handwands in mushroom 

houses in the Updated Revised Occupational and Residential Exposure Assessment for the 

Reregistration Eligibility Decision Document, dated June 29, 2005. The cancer risk estimates for 

handlers that mix/load/apply liquids via high pressure handwand in mushroom houses was above 

the Agency’s LOC, 1.3 x 10-4, assuming the highest level of PPE possible, which is coveralls 

worn over long-sleeve shirt and long-pants, chemical-resistant gloves, and a 90% respirator. 

Engineering controls are not feasible with this use scenario. 

The American Mushroom Institute (AMI) provided the Agency with information 

regarding permethrin use in mushroom houses during phase 3, the public comment phase. 

According to the AMI, they could find no grower that uses high pressure handwands to apply 

permethrin in mushroom houses. Instead, ULV cold foggers and fog/mist generators are the 

typical and preferred application methods. 

In response to Phase 3 comments, the Agency removed this scenario from the current 

revised occupational risk assessment. In order to ensure that high pressure handwands are not 

used in mushroom houses, the registrants have agreed to amend their wettable powder and EC 

formulation products labeled for use in mushroom houses to specify that high pressure 

handwands are prohibited. See Section IV, Table 38 for amended label language. 

Aerial Applications – Liquid and Granular Formulations 

For aerial applications of permethrin liquid or granular formulations, pilots must use an 

79
enclosed cockpit that meets the requirements listed in the Worker Protection Standard (WPS) for 

agricultural pesticides [40 CFR 170.240(d)(6)]. 

ii. Post-Application Worker Risk Mitigation 

For workers re-entering treated fields to conduct post-application activities, such as 

irrigation and hand weeding, all non-cancer risk estimates are below the Agency’s LOC (MOEs 

range from 570 to 200,000) at a 12 hour restricted-entry interval (REI). Additionally, most 

cancer risk estimates are in the 10-5 to 10-7 range, except for migrant workers engaging in conifer 

cone seed harvesting and thinning activities in certain tree orchards 30 days per year. The 

predicted cancer risk for these scenarios is in the 10-4 range. Although the Agency typically tries 

to mitigate all cancer risk estimates to be less than 1 x 10-6, the Agency does not believe that 

extending REI is practical for permethrin because, according to Agency use and usage data, most 

applications of permethrin on agricultural crops coincide with post-application activities, such as 

trimming, pruning, or harvesting. Moreover, available dislodgeable foliar residue data indicate 

that permethrin residues on foliage degrade slowly, requiring the REI to be several weeks in 

order for cancer risk estimates to be below the LOC. 

However, according to Agency data, permethrin is primarily used during the post-harvest 

and dormant season apple and pear production, which indicated little chance for repeated and 

prolonged exposure to residues. Only about 10-12% of treated acres, on average, are treated 

during the period between bloom and harvest. Further, only about 5% of pome fruit acreage are 

treated with permethrin annually. Together, these data suggest that it is unlikely that workers 

would be annually exposed to permethrin residues for 30 days in commercial orchards (such as 

migrant workers) or 10 days in small orchards (such as self-employed producers). Production 

practices in tart cherry imply that exposure concerns are also unlikely. Further, very low and 

sporadic treatments make it unlikely that frequent exposure would occur in the following crops: 

hazelnut, walnut, avocado, alfalfa, potato, soybean, and turnip and collard greens. 

The Agency also anticipates post-application exposure from conifer cone seed harvesting 

to be low. According to the U.S. Forest Service, the last application of permethrin each season is 

usually made at least 30 days prior to cone harvest. Additionally, it is highly improbable that a 

cone picker would be exposed to permethrin for 30 days in a year because permethrin is not 

typically used as a final application in very few orchards, and it would be very unusual for 

migrant pickers to work on two or three permethrin treated orchards sequentially. Considering 

the use pattern of permethrin on conifer cone seeds, and characterization of the cone seed 

harvesting, the Agency reassessed the cancer risk estimate with an REI of 30 days. A 30 day 

REI reduces the cancer risk to the 10-5 range. The registrants have agreed to amend their labels 

to reflect this mitigation. 

In addition, the registrants have agreed to reduce maximum application rates and number 

of applications per year or season to help reduce potential post-application risks to workers. The 

specific use pattern reductions are listed in Table 37. Based on these measures, and the 

impracticality to extend the REI, the Agency intends to maintain the current 12 hour REI for all 

crop uses, except for conifer cone seed harvesting, which will require a 30 day REI. 

80
2. Non-Target Organism (Ecological) Risk Management 

a. Terrestrial Organisms 

Birds and Mammals 

EPA’s screening-level risk assessment, based on maximum application rates, for both 

aerial and ground application scenarios for permethrin, suggests no acute risks of concern for 

birds and mammals. The highest acute RQ is approximately 0.03 for birds feeding on short grass 

and 0.04 for the smallest mammals feeding on short grass (see Tables 21 and 22). Chronic RQs 

for mammals were calculated using the results of a developmental toxicity study performed with rats. 

Dose based RQs based on the Maine Potatoe scenario, which is the most conservative of the crop 

scenarios assessed, range from 0.02 to 2.57. This study was conducted via oral gavage and 

represents a more intense dosing regime than that of the 3-generation rat reproduction studies 

(dietary exposure) which the Agency typically relies on to estimate chronic effects and risk to 

mammals. Therefore, given the questionable toxicological response and the intense dosing 

regime, it should be noted that this NOAEC represents a conservative estimate of toxicity and its 

use may result in the overestimation of chronic risk to mammals. Thus, the results are not 

tabulated in this document. The Agency is not requiring additional data at this time. 

Non-Target Insects 

Available toxicity data shows that permethrin is highly toxic to honeybees, as well as 

beneficial insects on both a contact and oral basis. Further, permethrin was also found to be 

highly toxic to honeybees exposed to foliage that had been sprayed with a permethrin 

formulation. Therefore, a precautionary statement is required on permethrin product labels to 

limit the exposure to honeybees and other beneficial insects during applications of permethrin. 

Plants 

Although the Agency does not have plant toxicity data to assess risks associated with 

permethrin exposure to terrestrial plants, permethrin’s mode of action for controlling insect pests 

would not be expected to be a mode of action that would harm plants because it is a neurotoxin. 

The Agency is not requiring plant toxicity data at this time. 

b. Aquatic Organisms 

i. Agricultural Uses 

Freshwater and Estuarine Fish, Invertebrates, and Sediment Organisms 

EPA’s screening-level risk assessment for permethrin, based on maximum rates and both 

aerial and ground application scenarios, suggests it is highly toxic to both freshwater and 

estuarine aquatic organisms. The acute LOC (0.5) was exceeded for most scenarios modeled for 

freshwater and estuarine fish, invertebrates, and sediment organisms. The screening-level risk 

assessment also shows the potential for chronic risks to both freshwater and estuarine 

81
invertebrates and sediment organisms. The chronic LOC (1) was exceeded for all scenarios. 

However, the risk assessment also suggests that chronic risks to freshwater and estuarine fish are 

less likely to occur. The chronic LOC was only exceeded in the Maine Potatoes scenario, which 

assumes a maximum application rate of 0.2 lb ai/A, applied 8 times per year. According to 

comments received by the National Potatoes Council, permethrin is applied only once or twice 

per year on potatoes due to treat for Colorado Potato Beetles. Use is limited by the need to rotate 

products due to the potential for resistance development. Based on this information, the Agency 

believes chronic risk to fish is below the Agency’s LOC. 

In order to reduce the exposure of permethrin to aquatic organisms, the registrants have 

agreed to impose a 150 foot buffer zone for aerial applications, and a 25 foot buffer zone for 

ground applications. The screening-level risk assessment suggests that the use of a buffer zone 

will decrease the EEC by approximately 20%, and reduce both the acute and chronic risks to 

freshwater and estuarine aquatic organisms. Further, the acute and chronic RQs are reduced 

further when typical application rates and number of applications are considered. Typical 

application rates and number of applications, which are based on Agency use data, reduce acute 

RQs by over half for all freshwater and estuarine/marine fish, invertebrate, and sediment 

organisms, and can result in even greater reduction of chronic RQs. 

The registrants have also proposed a number of reductions in single and seasonal 

maximum application rates, as well as number of applications. In many cases, the registrants 

reduced the seasonal maximum application rate by half, and in all cases specified a minimum 

retreatment interval. Although the Agency did not revise its risk estimated based on this 

mitigation, the Agency believes these reductions will serve to further reduce the risks to aquatic 

organisms. Table 37 lists the amended use patterns for permethrin on agricultural labels. 

Table 37. Amended Agricultural Use Patterns 

Current Labels Mitigation Per the RED 

Crop Max. Rate 

per 

application 

(lb ai/A) 

Minimum 

retreatment 

interval 

(days) 

Seasonal 

Maximum 

Appication 

Rate (lb 

ai/A) 

New 

Maximum 

rate per 

application 

(lb ai/A) 

New 

Minimum 

retreatment 

interval 

(days) 

New 

Seasonal 

Maximum 

Appication 

Rate (lb 

ai/A) 

Alfalfa 0.2 14 0.2 per 

cutting 

0.2 30 0.2 per 

cutting 

Almonds 0.4 3 2 0.25 10 0.75 

Hazelnuts 0.4 As needed 1.6 0.25 10 0.75 

Pistachios 0.4 As needed 1.6 0.3 10 0.9 

Walnuts 0.4 As needed 1.6 0.25 10 0.75 

Apples 0.4 As needed 0.6 0.25 10 0.5 

Pears 0.4 As needed 0.8 0.25 

(0.4 

dormant 

only) 

10 0.65 

Cherries 0.2 As needed 1.2 0.2 10 0.6 

Peaches/Nectarines 0.3 7 1.5 0.25 10 0.75 

Artichokes 0.3 As needed 1.5 0.3 10 0.9 

Asparagus 0.1 As needed 0.4 0.1 7 0.4 

Avocados 0.2 7 1.2 0.2 7 0.8 

82
Table 37. Amended Agricultural Use Patterns 

Current Labels Mitigation Per the RED 

Crop Max. Rate 

per 

application 

(lb ai/A) 

Minimum 

retreatment 

interval 

(days) 

Seasonal 

Maximum 

Appication 

Rate (lb 

ai/A) 

New 

Maximum 

rate per 

application 

(lb ai/A) 

New 

Minimum 

retreatment 

interval 

(days) 

New 

Seasonal 

Maximum 

Appication 

Rate (lb 

ai/A) 

Broccoli 0.2 As needed 0.8 0.2 5 0.8 

Brussels Sprouts 0.2 As needed 0.8 0.1 5 0.4 

Cabbage 0.2 5 1 0.2 5 0.4 (0.8 in 

HI) 

Cauliflower 0.2 As needed 0.8 0.1 5 0.4 (0.6 in 

HI) 

Cantaloupes 0.2 7 1.6 0.2 7 0.8 (1.2 in 

HI) 

Cucumbers 0.2 As needed 1.6 0.2 7 1.2 

Pumpkins 0.2 As needed 1.6 0.2 7 1.2 

Squash (summer, 

winter) 

0.2 As needed 1.6 0.2 7 1.2 

Watermelon 0.2 As needed 1.6 0.2 7 1.2 

Eggplant 0.21 3 2 0.15 7 0.6 (1.0 in 

HI) 

Peppers, bell 0.2 As needed 1.6 0.2 5 0.8 

Tomatoes 0.2 5 1.2 0.2 7 0.6 (0.8 in 

HI) 

Celery 0.2 As needed 2 0.2 7 1.0 (1.2 in 

HI) 

Lettuce 0.2 3 2 0.2 7 0.8 (1.2 in 

HI) 

Spinach 0.2 As needed 2 0.2 3 0.6 

Collards 0.2 As needed 0.8 (0.4 in 

SC, GA, 

FL, WA) 

0.15 3 0.45 

Greens, Turnip 0.2 As needed 0.8 (0.4 in 

SC, GA, 

FL, WA) 

0.15 3 0.45 

Corn, Field 0.2 6 0.6 0.15 7 0.45 

Sweet Corn 0.25 3 1.2 0.2 3 0.8 

Garlic 0.3 As needed 2 0.2 10 0.8 

Onions 0.3 As needed 2 0.3 7 1.0 

Horseradish 0.21 As needed 0.6 0.15 10 0.45 

Papaya 0.4 7 1.2 0.15 10 0.75 

Potatoes 0.2 As needed 1.6 0.2 10 0.8 

Soybeans 0.2 As needed 0.4 0.2 10 0.4 

ii. Public Health Uses 

The Agency has conducted a screening-level ecological risk assessment for the mosquito 

control use of permethrin based on aerial applications of permethrin to Florida turf. Based on the 

available data, the Agency has identified potential acute risks of concern to freshwater and 

estuarine/marine invertebrates, and potential chronic risks of concern for estuarine/marine 

invertebrates. While there is a slight estimated exceedence of the endangered species LOC (0.5) 

83 
for freshwater fish at the high-end application rate of 0.007 lb ai/A (RQ=0.07), the Agency 

expects risks of concern to be limited based on the following: 1) aerial release (boom) heights 

typically occur at height much higher than assessed, which will further reduce the risks, and 2) 

there are no risks of concern associated with this use for freshwater fish at the typical application 

rate (0.0035 lb ai/A). 

Although the acute RQs for freshwater and estuarine invertebrates exceed the restricted 

use LOC (RQ > 0.1), the Agency believes that the use restrictions specified in the guidelines and 

recommendations of PR-2005-1 will serve to reduce overall risk to aquatic organisms and, 

therefore, it is not necessary to classify permethrin as a restricted use product for wide area 

mosquito abatement applications. Additionally, the Agency believes that the typical application 

practices of mosquito abatement districts, as stated in comments received by the American 

Mosquito Control Association, such as application rate, number of applications, and release 

height, etc. employed by public health abatement districts result in a reduced risk to aquatic 

organisms as compared to the maximum rate and number of applications, and minimum release 

height assessed in the risk assessment. 

Further, in order to reduce the acute and chronic risks to invertebrate organisms, the 

registrants have agreed to the following mitigation measures for products labeled for wide area 

mosquito abatement: 

• Reduce maximum daily application rate to 0.007 lb ai/A, and a maximum yearly 

application of 0.18 lb ai/A; 

• Require minimum boom height of 100 feet for fixed wing, and 75 feet for helicopter 

applications; and 

• Specify droplet size to <60 microns for aerial applications, and droplet size <30 

microns for ground applications. 

Finally, the screening-level ecological risk assessment also determined that the use of a 

buffer zone during wide area applications of permethrin for mosquito abatement did not serve to 

reduce the risk to aquatic invertebrates. Therefore, in accordance with PR-2005-1, a 100 foot 

buffer zone is no longer required for wide area mosquito applications. However, permethrin is 

also registered as an adult mosquito adulticide for ground barrier treatments. Unlike wide area 

applications where the permethrin application is intended to stay adrift in the air, and targeted 

flying mosquitoes, barrier treatments are intended to treat the foliage and target resting 

mosquitoes. Therefore, the 100 foot buffer zone requirement will still apply to mosquito 

adulticide barrier applications of permethrin. 

Plants 

As stated above, although the Agency does not have plant toxicity data to assess risks 

associated with permethrin exposure to aquatic plants, permethrin’s mode of action for 

controlling insect pests would not be expected to be a mode of action that would harm plants 

because it is a neurotoxin. The Agency is not requiring plant toxicity data at the time. 

iii. Other Non-Agricultural Uses 

84
One of the risk assessment goals of the Office of Pesticide Programs (OPP) is to estimate 

pesticide exposure through all significant routes of exposure from both agricultural and non-crop 

uses. However, the ecological risk assessments for pyrethroid insecticides focus predominantly 

on the agricultural uses for these insecticides, because pesticide transport models are available to 

estimate potential aquatic exposure. Based on laboratory toxicity tests with terrestrial and 

aquatic animals, aquatic exposure would be more likely to cause adverse effects in the 

environment. 

However, sales data indicate that non-crop uses of the pyrethroids comprise a much 

larger fraction of total use than agricultural uses. The use of pyrethroids in urban and suburban 

settings has increased since the phase-out of these uses of the organophosphate insecticides 

diazinon and chlorpyrifos. Sales data indicate that the majority of urban use of pyrethroids is for 

structural pest control, such as for control of termites or ants. Other outdoor non-crop uses 

include landscape maintenance, and homeowner lawn and garden use. Indoor uses include insect 

control, and treatment of pets and clothing. 

The Agency uses a “down-the-drain” model to perform a screening-level aquatic risk 

assessment for indoor uses of pesticides. In these simulations, waste water containing pesticide 

residue flows into a building drain and passes through a sanitary sewer and publicly owned 

treatment works (POTW) before being discharged to surface water. However, no analogous 

exposure model has been developed to allow a similar screening-level assessment for pesticides 

applied in an outdoor urban setting. As a result, the Agency has had to take a qualitative 

approach to characterize the potential aquatic risk from urban and suburban use of pyrethroids. 

For outdoor urban uses, it is assumed that runoff water from rain and/or lawn watering 

may transport pesticides to storm sewers and then directly to surface water. Conceptually, a 

greater contribution to pyrethroid loading to surface water bodies would be expected from 

application to impervious surfaces such as walkways, driveways or the sides of buildings, than to 

lawns or bare ground, because of the pyrethroids’ strong affinity to bind to organic carbon in 

soils. However, the Agency is unaware of any model which can simulate the different 

application methods for urban use and the physical representation of the urban landscape, storm 

sewer and receiving water configuration. 

There are models available which can be calibrated to simulate sites and pesticides for 

which extensive flow and pollutant data have been collected in advance. The HSPF/NPSM 

model, for instance, which is included in the Office of Water’s BASINS shell, has been used to 

calibrate stream flow and copper pesticide use data to simulate loading of these pesticides 

consistent with concentrations measured in surface water monitoring. Risk assessors with the 

California Department of Environmental Protection confirmed in conversations with the Agency 

that they also have used watershed models to calibrate to previously collected flow and pesticide 

monitoring data, but that they did not know of any models capable of predicting concentrations 

of pyrethroids that might occur because of outdoor urban uses. 

Development of a screening model which could simulate the fate and transport of 

pesticides applied in an urban setting would require a large body of data which is currently 

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unavailable. For instance, an urban landscape cannot be simulated as easily as an agricultural 

field. The PRZM model simulates runoff from an agricultural field using readily available data 

describing surface soil characteristics and laboratory data detailing the persistence and mobility 

of pesticides in these soils. The agricultural field simulated is homogenously planted to a single 

crop, and soil and water are transported from the field to a receiving water body with dimensions 

consistent with USDA farm-pond construction guidelines. 

By contrast, an urban landscape or suburban housing development consists of impervious 

surfaces such as streets and sidewalks, and pervious surfaces such as lawns and parkland. One 

could expect much greater mobility for pesticides applied to impervious surfaces, but laboratory 

soil metabolism studies may not provide an accurate measure of the persistence of pesticides on 

these surfaces. The path runoff water and eroded sediment might take is less obvious for an 

urban setting than an agricultural field. First, an urban landscape cannot be considered 

homogeneous, as the proportion of impervious and pervious surfaces varies for different 

locations. In addition, the flow path of runoff water and sediment is not necessarily a direct path 

over land, but can pass below ground through storm sewer networks, or be directed or slowed by 

pumping stations or temporary holding ponds. 

Finally, the timing and magnitude of urban uses is less well defined for urban uses than 

agricultural uses. While agricultural uses would occur within a predictable window during the 

growing season, the need for urban uses could occur at different times each year, and might 

occur at different times within the same watershed. In addition, since records of how and to 

what extent pyrethroids are applied by homeowners are less well defined than for professional 

applications, it is harder to estimate the total load to model. 

Pyrethroid monitoring data 

The Agency considers surface water monitoring data in addition to modeling results 

when they are available. However, surface water monitoring for pyrethroids has been limited, 

perhaps because the pyrethroids would more likely be associated with aquatic sediment than the 

water column. The USGS NAWQA program included permethrin as the only pyrethroid among 

its pesticide analyses, and detected it in 0.15% of 1185 agricultural stream samples from 78 

sample locations. Permethrin was not detected in 803 urban stream samples taken from 33 

sample locations. The NAWQA program also analyzed for cis-permethrin in bed sediments, and 

had similar detection rates in between the agricultural (1.5%) and urban (1.0%) land use sites; 

trans-permethrin was detected in 0.8% of bed sediment samples. 

More recently, researchers from the University of California-Berkeley have published 

studies which reported transport of pyrethroids to stream bed sediment as a result of urban uses. 

In 2004, Weston, et al. collected sediment from creeks draining a residential area in Rosedale, 

California. The sediments were analyzed for 7 pyrethroids (including permethrin and 

cypermethrin, which are currently in the reregistration process), as well as for other insecticides. 

All of the pyrethroids were detected in the bed sediment from at least one sampling location. 

The researchers exposed the aquatic amphipod Hyalella azteca to the 21 sediment samples they 

collected; pesticide concentrations in 9 of these samples was sufficient to cause 90% mortality in 

the amphipods after a 10-day exposure. The concentrations of pyrethroids detected in the 

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sediments were above the level expected to cause 50% mortality in H. azteca, suggesting that the 

pyrethroids were responsible for the observed toxicity. 

In a subsequent study, Weston, et al. collected samples from 15 urban creeks in 

California and 12 in Tennessee. Toxicity to H. azteca was observed at least once with sediments 

taken from 12 of the 15 California sampling sites. In most cases, the toxicity could be accounted 

for by the concentrations of pyrethroids detected in the sediment. Pyrethroids were rarely 

detected in the Tennessee sediment samples, and exposure to the Tennessee sediments did not 

prove to be toxic to H. azteca. 

Future steps 

The results of the Weston, et al. studies has led a number of organizations, such as the 

California State Water Resources Control Board (SWRCB) to submit comments to the Agency 

during the reregistration process of several pyrethroid insecticides, calling for mitigation 

measures to prevent pyrethroid surface-water contamination. However, the lack of knowledge 

which makes it difficult to develop an urban pesticide transport model also makes it difficult to 

identify meaningful mitigation at this time. The Agency has developed some initial mitigation 

options during the reregistration process, and intends to identify steps which can be taken to 

allow a greater understanding of potential ecological risk from urban pyrethroid uses. 

One reason that broad mitigation measures cannot be adopted during reregistration is that 

only three pyrethroid insecticides are required to be reviewed for reregistration in accordance 

with FQPA. If use restrictions were placed on one of these three pesticides, one of the other 

pyrethroids would likely replace it for that use. It is important, as some commenters have 

suggested, to perform a risk assessment for all of the pyrethroids at the same time. The Weston 

papers indicated that the sediments which proved toxic to the tested aquatic invertebrate were 

contaminated not only with the pyrethroids undergoing reregistration, but also other pyrethroids 

such as bifenthrin and lambda-cyhalothrin. 

The next opportunity to assess the pyrethroids as a group will occur during the 

Registration Review program, for which the Agency issued a proposed rule in July 2005 and 

plans to issue the final rule and implement the program in 2006. The purpose of Registration 

Review is to ensure the periodic review of all pesticides to make sure they continue to meet 

current scientific and regulatory requirements, with the goal of reviewing each pesticide every 

fifteen years. The pyethroids are tentatively scheduled for re-evaluation under the proposed 

Registration Review program in 2010. 

A number of steps are planned for the intervening years which should improve the 

Agency’s ability to assess the level of aquatic exposure to pyrethroids from urban use. One step 

is to better identify what conditions in an urban setting might lead to greater vulnerability to 

transport to urban water bodies. Although the Weston papers reported sediment toxicity from 

samples from California but not Tennessee, the authors could only speculate what differences in 

use or geography made an area more vulnerable to exposure than the other. 

Further investigation into the dominant urban uses and application practices of 

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pyrethroids around the country would help provide a clearer picture of relative vulnerability. 

The SWRCB commented that structural pest control is likely a major source of pyrethroids in 

urban runoff, and suggested best management practices (BMP). The Pyrethroid Working Group 

(PWG) indicated that irrigation of lawns in areas of California with little rainfall during the 

application season could be a major contributor, and has contacted organizations such as 

Responsible Industry for a Sound Environment (RISE) and the Coalition for Urban/Residential 

Environmental Stewardship (CURES) to develop BMPs as part of their product stewardship 

plan. As further sediment monitoring studies are published describing parts of the country with 

different weather and pest pressures, more detailed usage data will make it easier to correlate the 

causes of pyrethroid use practices. 

The Agency will also continue in its efforts to develop a screening-level model for urban 

pesticide uses. Advances in the resolution of GIS databases may allow better representation of 

the impervious and pervious portions of a typical urban landscape. As it becomes clearer which 

uses are most likely to lead to transport of pyrethroids to surface water, the conceptual model of 

how urban transport should be simulated will be more focused. 

Finally, the Agency will evaluate available published literature and call-in data to resolve 

data gaps to ensure a robust comparison of the potential ecological risk of all the pyrethroids 

during Registration Review. Toxicity data cited by several commenters from published literature 

are included in the Agency's ECOTOX database. The Agency will evaluate the quality of 

studies to identify those to be included in the risk assessments during Registration Review. The 

PWG is currently performing specific toxicity studies identified by the Agency as data gaps, 

such as sediment invertebrate toxicity tests. 

Data Needs 

The Agency will be issuing a generic data call-in for all registered pyrethroids after the 

permethrin RED to be used to assess pyrethroids as a group in Registration Review. 

Stewardship Language 

While the Agency cannot currently assess the potential risks to aquatic organisms from 

non-agricultural uses of permethrin, the Agency is still seeking to reduce the potential drift and 

run-off of permethrin into aquatic habits through explicit directions for use on both professional 

and consumer use products for use in residential settings. These use directions include best 

management and stewardship practices which are formulation specific, and will serve reduce the 

potential run-off and drift that can occur from applications of these products. Label statements 

implementing these measures are listed in the "direction for use" section of the label table (Table 

38) in Section V of this RED document. 

4. Significance of Permethrin to Users 

Non-Agricultural Use 

According to data provided by the PIRTF, over 70% of permethin, approximately 1.5 

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million pounds, is used on non-agricultural settings. Of this amount applied in residential 

settings: 55% is applied by professionals; 41% is applied by the homeowners; and 4% is used in 

mosquito abatement districts. 

Permethrin is used to control a wide variety of pests in and around residential structures. 

Although permthrin is heavily relied upon by both pest management professionals (PMPs) and 

homeowners, and over a million pounds is used on residential areas per year, there are a number 

of available alternatives registered for similar indoor and outdoor use sites. The recent loss of 

chlorpyrifos and diazinon for residential pest control has resulted in a greater reliance on 

permethrin and the pyrethroids among residential users. Based on Agency data, in the absence 

of permethrin, homeowners and PMPs would most likely substitute other pyrethroid insecticides 

for use in or around home, such as cyfluthrin, cypermethrin, deltamethrin, esfenvalerate, lambda 

cyhalothrin, pyrethrins, resmethrin, sumithrin, tetramethrin, and tralomethrin. Permethrin users 

may also substitute insecticides from other chemical classes, such as malathion, carbaryl, and 

imidicloprid, as well as a non-chemical methods. 

Permethrin is the only pesticide registered to pre-treat fabric. The U.S. Department of 

Defense uses permethrin as part of its vector control efforts; pre-treated military battle dress 

(MBD) are made available to servicemen and woman, as well as RTU packages for treatment of 

MBDs in the field. Comments received by the Armed Forces Pest Management Board strongly 

support the use of permethrin as a clothing repellent, due to that fact that medical preventive 

countermeasures (i.e., vaccines) do not exist for many arthropod-borne diseases, such as West 

Nile Virus, which once acquired can cause permanent disability or death. Therefore, the 

AFPMB believes permethrin treated fabrics serve as a viable method to control or help prevent 

the transmission of these diseases. 

Given its efficacy at controlling public health pests, permethrin is the most widely used 

mosquito adulticide in the U.S. and is used to treat 9 to 10 million acres annually (out of 32-39 

million acres treated with a mosquito adulticide). Permethrin’s widespread use can be attributed 

to its low cost, high efficacy, low incidence of pest resistance, and broad labeling. Alternatives 

to permethrin for adult mosquito control include resmethrin, sumithrin, pyrethrins, malathion, 

and naled. Permethrin alternatives are comparably priced and are likely to be as effective as 

permethrin in many situations, but are not likely to universally substitute for all permethrin uses 

because of labeling constraints or resistance concerns. The Agency believes that the loss of 

permethrin would adversely affect the ability of mosquito abatement professionals to control 

mosquitoes in some situation, such as agricultural-urban interface and areas with known 

resistance to alternatives. 

Agricultural Uses 

Based on Agency data, approximately 600,000 pounds of permethrin is used to treat a 

variety of crops, such as pome and stone fruit, nut crops, other tree crops (avocado, papaya, 

conifer), seed cone, ornamentals and cut flowers, field crops, dry bulb crops, greens, and cole 

crops. According to comments received from various growers, the broad spectrum of pests that 

permethrin targets makes its use highly beneficial since the agricultural industry has been losing 

a number of insecticides, and the newer insecticides replacing them have chemistries that target 

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specific insects and are narrow in their spectrum. Further, USDA has established limits on how 

many insect parts can be present in finished product, and according to growers, many other 

alternatives have labeled pre-harvest intervals (PHIs) that are too long to accommodate the 

narrow harvest window required to comply with these standards. Permethrin has a 1 day PHI, 

which allows for effective pest control near harvest of registered crops. 

Further, based on Agency data and analysis, permethrin is considered to be of high 

benefit to the following crops because it is applied to 30% or more of the growing crop: 

almonds, artichokes, Brussels sprouts, celery, lettuce, other lettuces, pistachios, and sweet corn. 

Although permethrin is applied to less than 1% of the soybeans, alfalfa, and corn (field), and 

maybe considered of low benefit, because approximately 20,000, 40,000, and 100,000 pounds 

are applied to each crop, respectively, per year, it constitutes a significant amount of use. 

In general, the Agency believes that fourth generation pyrethroids (i.e., bifenthrin, 

lambda-cyhalothrin, cypermethrin, cyfluthrin, deltamethrin, esfenvalerate, fenpropathrin, 

flucythrinate, fluvalinate, prallethrin, tau-fluvalinate, tefluthrin, tralomethrin, and zetacypermethrin) are as effective as permethrin and would be acceptable alternatives as long as they 

are registered and used on the crops in question. The fourth generation pyrethroids generally 

control the same pests and have a longer period of residual effectiveness than permethrin. 

However, these pyrethroids are also assumed to pose a greater ecological risk to aquatic 

organisms given their persistence in the environment. The Agency has not assessed the 

comparative ecological toxicity of all registered pyrethroids as part of reregistration, however, it 

intends to assess pyrethroids as a group in Registration Review, as discussed in section 

IV.E.2.b.iii above. 

5. Risk/Benefit Balancing Analysis 

The Agency has determined that permethrin-containing products are eligible for 

reregistration, provided that risk mitigation measures are adopted and labels are amended 

accordingly. On the human health side, residential risks to homeowners that exceeded the 

Agency’s level of concern have been mitigated completely by discontinuing or restricting certain 

application methods and reducing some application rates, and occupational risks have been 

mitigated through personal protective equipment or engineering controls requirements on the 

labels. 

The remaining risks are found on the ecological side. Ecological risks can occur as a 

result of agricultural use, use of permethrin as a mosquito adulticide, and residential uses, 

including uses in and around homes. Although data suggest that permethrin is practically nontoxic to small mammals and avian species on an acute basis, it has a toxic effect on beneficial 

insects. The Agency is proposing to limit this effect by requiring precautionary labeling on 

permethrin product labels to limit the exposure to honey bees and other beneficial insects during 

applications of permethrin. Data also suggest that permethrin is highly toxic to both freshwater 

and estuarine aquatic organisms. As a result, the Agency is imposing a number of restrictions on 

agricultural uses (e.g., spray drift buffer zones and reductions in single and seasonal maximum 

application rates, as well as increased retreatment intervals), which will reduce both the acute 

and chronic risks to freshwater and estuarine aquatic organisms. The Agency is also imposing a 

90
number of requirements on permethrin’s use as a mosquito adulticide (e.g., reduction in the 

maximum application rate, restrictions on number of applications, mandatory boom heights, and 

specific droplet sizes), which the Agency believes will reduce acute and chronic risks to aquatic 

invertebrates. 

There are a number of reasons why the Agency has concluded that the risk/benefit 

balance tips in favor of finding permethrin eligible for reregistration despite the ecological risks. 

With respect to the ecological risks, the Agency has reduced those risks by imposing various 

conditions that should reduce exposure of aquatic species to permethrin. With respect to the 

benefits, as described above in the section entitled Significance of Use, permethrin offers 

substantial benefits to users. In the agricultural area, permethrin provides a high benefit to the 

agricultural industry because of its broad label and 1 day PHI. According to comments received 

from various growers, the broad spectrum of pests that permethrin targets makes its use highly 

beneficial since the agricultural industry has been losing a number of insecticides, and the newer 

insecticides replacing them have chemistries that target specific insects and are narrow in their 

spectrum. Further, permethrin has a 1 day pre-harvest interval, which allows for effective pest 

control near harvest of registered crops. Also alternatives to permethrin, such as the fourth 

generation pyrethroids, may pose a greater risk to aquatic organisms because of their persistence 

in the environment. 

 For the public health use, permethrin is the most widely used mosquito adulticide in the 

United States because of its low cost, high efficacy, and low incidence of pest resistance. 

Although permethrin alternatives are comparably priced and are likely to be as effective as 

permethrin in many situations, they are not likely to universally substitute for all permethrin uses 

because of labeling constraints or resistance concerns. The Agency believes that the loss of 

permethrin would adversely affect the ability of mosquito abatement professionals to control 

mosquitoes in some situation, such as agricultural-urban interface and areas with known 

resistance to alternatives. With regard to the treatment of fabrics, permethrin is the only 

pesticide registered to pre-treat fabrics, which the AFPMB strongly supports as a method of 

preventing many diseases that might afflict military personnel in the field. On other uses, such 

as residential uses, where there may be a potential for ecological effects due to urban runoff, the 

Agency intends to identify steps which can be taken to allow a greater understanding of potential 

ecological risk from urban uses of pyrethroid as a whole during Registration Review. 

Given the significance of the use of permethrin and the mitigated nature of the risks of 

permethrin, the Agency believes, on balance, that the benefits of permethrin outweigh the risks. 

Therefore, permethrin-containing products are eligible for reregistration, provided that risk 

mitigation measures are adopted and labels are amended accordingly. 

6. Summary of Mitigation Measures 

The following mitigation measures are necessary for permethrin to be eligible for 

reregistration. 

Dietary Risk 

No label changes are necessary for these risks. 

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Residential Risk 

• Discontinue use of sponge application method for formulations applied as liquids. 

RTU products, such as wipes and trigger pump sprays will still be available for this 

use pattern. 

• Discontinue use of all directed broadcast and crack and crevice sprays (i.e., low 

pressure handwand, backpack sprayer, cold fogger) on all residential indoor surfaces, 

except for aerosol sprays. 

o Limit concentration of RTU consumer sprays to 0.5% ai of permethrin. 

The Agency will consider products with higher concentrations if the 

registrants for these products are able to provide justification or data to the 

Agency which demonstrate that little to no exposure will occur due to the 

specialized use of the product. 

• Limit all total release fogger formulation to 0.25% ai of permethrin. 

o The Agency will consider products with higher concentrations if the 

registrants are able to provide justification or data that an equivalent 

indoor surface residue of 2.4 μg/cm2, or less, will result in a room size of 

2000 ft3 or less. 

• Amend all liquid and wettable powder products registered for outdoor residential use 

to either prohibit use in outdoor residential misting systems, or provide specific use 

directions. 

• Efficacy data for all finished pre-treated permethrin products, and wash-off data to 

support efficacy claims is required. 

Occupational Risk 

Handler 

• Require wettable powder formulations to be packed in water soluble packaging. 

• Require all aerial applications to be in closed cab aircraft. 

• Discontinue the use of high pressure handwands in mushroom houses. 

• Add PPE requirement to labels as follows: 

o Wettable Powders- baseline PPE and chemical-resistant gloves for mixers, 

loaders, and applicators. 

o Emulsifiable Concentrations- baseline PPE and chemical-resistant gloves for 

mixers, loader, and applicators. Additional chemical-resistant apron is 

required for applicators performing animal dip applications. 

o Dry Flowables- baseline PPE and chemical-resistant gloves. 

o Dust- Double layer, chemical-resistant gloves, and a PF5 respirator for loaders 

and applicators. 

o RTU Formulations- Baseline PPE and chemical-resistant gloves. 

o Applicators of liquids via cold foggers and fog mister/generators. 

 Require applicators to wear DL, chemical-resistant gloves, and PF10 

respirator. 

Post-Application 

• Increase REI for conifer cone seed harvesting to 30 days. 

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• Amend agricultural labels to include new use pattern (rate reductions, seasonal 

maximum reductions, and minimum retreatment interval) identified for the selected 

crop uses specified in Table 37 above. 

Ecological Risks 

• Include standard pyrethroid specific spray drift language, including a 25 foot buffer 

zone for ground applications, 100-foot for aerial application, and 450 foot for ULV 

applications. 

• Amend agricultural labels to include new use pattern (rate reductions, seasonal 

maximum reductions, and minimum retreatment interval) identified for the selected 

crop uses specified in Table 37 above. 

• Include the following statement in the environmental hazard section of the end use 

products, as specified in Table 38 below: 

o This pesticide is highly toxic to bees exposed to direct treatment on blooming 

crops or weeds. Do not apply this product or allow it to drift to blooming 

crops or weeds while bees are actively visiting the treatment area. 

• For all wide area mosquito abatement products: 

o Reduce daily maximum application rate to 0.007 lb ai/A, and a maximum 

yearly application rate of 0.18 lb ai/A; 

o Remove 100 foot buffer zone restriction; 

o Specify minimum release height of 100 feet for fixed wing aircraft, and 75 

feet for helicopter applications. 

o Require droplet size <60 microns for aerial application, and <30 microns for 

ground application. 

• Include stewardship language in the directions for use section of all products 

registered for outdoor use in residential areas. 

o Requirements for Granular Formulations with outdoor uses: “Do not 

apply directly to or near water, storm drains, or drainage ditches. Do not apply 

when windy. Apply this product directly to your lawn or garden, and sweep 

any product landing on the driveway, sidewalk, or street, back onto the treated 

area. To prevent product run-off, do not over water the treated area(s) or 

apply when heavy rain is expected.” 

o Requirement for Liquid and Dust Formulations except for Ready to Use 

with outdoor uses: “Do not apply directly to or near water, storm drains, or 

drainage ditches. Do not apply when windy. To prevent product run-off, do 

not over water the treated area(s) or apply when heavy rain is expected. Rinse 

applicator over lawn or garden area only.” 

o Requirement for Ready to Use Formulations with outdoor uses: “Do not 

apply directly to or near water, storm drains, or drainage ditches. Do not 

apply when windy. To prevent product run-off, do not over water the treated 

areas or apply when heavy rain is expected.” 

7. Performance Measures 

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As stated in the EPA’s Strategic Plan, the Agency’s objectives are to protect human 

health and the environment from pesticide exposures. The mitigation resulting from chemical 

reviews contributes to the Agency’s ability to meet its strategic targets by reducing pesticide 

exposure in people’s diet, in and around the home, in occupational settings, to non-target species 

and to water resources. Because of the tremendous difficulty and costs associated with 

measuring the direct effects of the work accomplished in OPP, the Agency continues its 

development of indicators and measures to help evaluate the program’s effect on human health 

and the environment. 

For permethrin, there were no estimated dietary (food and drinking water) risks of 

concern. Therefore, no mitigation measures were required to reduce potential permethrin 

exposure in people’s diets. However, risks of concern were identified from various applications 

of permethrin products in an around homes. Specifically, handler and/or post-application risks 

of concern were identified for indoor broadcast, and crack and crevice surface spray applications; 

indoor foggers; and sponge application of EC formulated products on animals. With 

implementation of the required mitigation measures, the Agency expects that potential exposure 

to permethrin residues by individuals in the home will be reduced. 

For occupational handler risks, the Agency is requiring specific levels of PPE or 

engineering controls on product labels, depending upon the formulation being used. Most 

products will include baseline PPE with chemical-resistant gloves, which are likely most 

commonly being used by workers in the field. In cases where respirators are being additionally 

required, such as for use of dust formulation or cold foggers, it is likely that most handlers are 

already using a respirator for these particular uses. Therefore, in these cases, the protective 

measures being required on the labels will likely not result in measurable reductions in handler 

exposures or reports of worker incidents. However, for wettable powder formulations, the 

Agency is requiring that engineering controls (i.e., water soluble packaging) be utilized to reduce 

exposures to handlers. Some registrants indicated that they may transfer these products to dry 

flowable formulations, which result in relatively low unit exposures to workers. Thus, these 

measures may result in possible reductions in worker exposures and incidents. 

In addition, the permethrin registrants have agreed to reduce application amounts and/or 

extend re-treatment intervals for many uses. These changes are stipulated in Table 38. While 

many of these changes likely reflect actual current use patterns by most users, because of the 

extensive number of agricultural uses and associated number of products available, the Agency 

believes that these measures to specify use patterns will limit the number of over-use events, and 

thus contribute to reducing exposure to workers and the environment. 

To address ecological risks, the Agency is requiring spray drift restrictions, such as buffer 

zones, droplet size, application height, and other requirements. These measures are expected to 

reduce the amount of exposure to aquatic habitats. In addition, for all wide area mosquito 

abatement products, a maximum application rate and other similar requirement are being 

specified. Finally, as stated above, the Agency intends to assess pyrethroids as a class in 

Registration Review, and in particular, water quality issues resulting from use in urban settings. 

In order to being to reduce potential spray drift and run-off of permethrin products used by 

consumers in a residential outdoor setting, the registrants have agreed to include stewardship 

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language in the directions for use section of all products registered for outdoor use in residential 

areas. 

F. Other Labeling Requirements 

To be eligible for reregistration, various use and safety information will be included in 

the labeling of all end-use products containing permethrin. For the specific labeling statements 

and a list of outstanding data, refer to Section V of this RED document. 

1. Endangered Species Considerations 

At this time, the Agency is not requiring label changes specific to the protection of listed 

species. If, in the future, specific measures are necessary for the protection of listed species, the 

Agency will implement them through the Endangered Species Protection Program. While RQs 

exceeded the Agency’s endangered species LOC for several taxa, these results were based on a 

screening-level assessment and do not constitute “may affect” findings under the Endangered 

Species Act. As explained earlier, after a species-specific assessment is conducted, a 

determination that there is a likelihood of potential effects to a listed species may result in 

limitations on the use of the pesticide, other measures to mitigate any potential effects, or 

consultations with the Fish and Wildlife Service or National Marine Fisheries Service as 

appropriate. Until that species specific analysis is completed, the risk mitigation measures being 

implemented through this RED will reduce the likelihood that endangered and threatened species 

may be exposed to permethrin at levels of concern. 

2. Spray Drift Management 

The Agency has been working closely with stakeholders to develop improved approaches 

for mitigating risks to human health and the environment from pesticide spray and dust drift. As 

part of the reregistration process, EPA will continue to work with all interested parties on this 

important issue. 

From its assessment of permethrin, as summarized in this document, the Agency 

concludes that certain drift mitigation measures are needed to address the risks from off-target 

drift for permethrin, including a requirement for medium to coarse droplet size. Label statements 

implementing these measures are listed in the "spray drift management" section of the label table 

(Table 38) in Section V of this RED document. In the future, permethrin product labels may 

need to be revised to include additional or different drift label statements. 

V. What Registrants Need to Do 

The Agency has determined that permethrin is eligible for reregistration provided that the 

risk mitigation measures outlined in this document are adopted and label amendments are made 

to reflect these measures. To implement the risk mitigation measures, the registrants will be 

required to amend their product labeling to incorporate the label statements set forth in the Label 

Summary Table in Section C below. In the near future, the Agency intends to issue Data Call-In 

(DCI) Notices requiring label amendments, product-specific data and additional generic 

(technical grade) data. Generally, registrants will have 90 days from receipt of a DCI to 

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complete and submit response forms or request time extension and/or waiver requests with a full 

written justification. For product-specific data, the registrant will have eight months to submit 

data and amended labels. For generic data, due dates can vary depending on the specific studies 

being required. Below are tables of additional generic data and label amendments that the 

Agency intends to require for permethrin to be eligible for reregistration. 

A. Manufacturing-Use Products

 1. Generic Data Requirements 

The generic data base supporting the reregistration of permethrin has been reviewed and 

determined to be substantially complete. However, the Agency has identified data necessary to 

confirm the reregistration eligibility decision for permethrin. These studies are listed below and 

will be included in the generic DCI for this RED, which the Agency intends to issue at a future 

date. 

Toxicology: 

870.6300 Developmental Neurotoxicity Study 

870.1300 Acute Inhalation Toxicity Study 

Residue Chemistry: 

860.1200 Directions for Use 

860.1340 Enforcement Analytical Method-Animals 

860.1380 Storage Stability 

860.1500 Magnitude of the Residue in Crop Plants (leaf lettuce, collards, and cabbage) 

Occupational Exposure

875.1200 Dermal Exposure Indoors (ULV Cold Fogger) 

875.1400 Inhalation Exposure Indoors (ULV Cold Fogger) 

Environmental Toxicology 

850.1735 Whole sediment acute toxicity for estuarine/marine invertebrates 

850.1740 Whole sediment acute toxicity for estuarine/marine invertebrates 

EPA/600/R-99/064 (ORD Study Method) Chronic Freshwater Sediment Testing 

EPA/600/R01/020 (ORD Study Method) Chronic Estuarine/Marine Sediment Testing 

2. Labeling for Manufacturing-Use Products 

To ensure compliance with FIFRA, manufacturing-use product (MP) labeling should be 

revised to comply with all current EPA regulations, PR Notices, and applicable policies. The 

MP labeling should bear the labeling contained in Table 38. 

B. End-Use Products

 1. Additional Product-Specific Data Requirements 

96
Section 4(g)(2)(B) of FIFRA calls for the Agency to obtain any needed product-specific 

data regarding the pesticide after a determination of eligibility has been made. Registrants must 

review previous data submissions to ensure that they meet current EPA acceptance criteria and if 

not, commit to conduct new studies. If a registrant believes that previously submitted data meet 

current testing standards, then the study MRID numbers should be cited according to the 

instructions in the Requirement Status and Registrants Response Form provided for each 

product. The Agency intends to issue a separate product-specific data call-in (PDCI), outlining 

specific product-specific data requirements. 

As discussed earlier, the Agency does not have adequate efficacy studies on pre-treated 

fabrics to support the efficacy claims of finished products. To address this uncertainty, the 

Agency is requiring efficacy data for all finished pre-treated permethrin products, and wash-off 

data to support the efficacy claims. These data requirements will also be included in the PDCI. 

2. Labeling for End-Use Products 

To be eligible for reregistration, labeling changes are necessary to implement measures 

outlined in Section IV above. Specific language to incorporate these changes is specified in 

Table 38. Generally, conditions for the distribution and sale of products bearing old 

labels/labeling will be established when the label changes are approved. However, specific 

existing stocks time frames will be established case-by-case, depending on the number of 

products involved, the number of label changes, and other factors. 

C. Labeling Changes Summary Table 

For permethrin to be eligible for reregistration, all permethrin labels must be amended to 

incorporate the risk mitigation measures outlined in Section IV. Table 38 describes specific 

label amendments. 

97
 Table 38: Summary of Labeling Changes for Permethrin 

Description Amended Labeling Language Placem

Manufacturing Use Products 

For all Manufacturing Use Products 

Only for formulation into an insecticide for the following use(s) [fill blank only 

with those uses that are being supported by MP registrant]. “Not for formulation into Wettable Powder formulations unless they are packaged in water soluble bags.” If Registrants are not supporting outdoor residential misting systems use for their products, the following statement must appear on the MUP label of all liquid or wettable powder products: “Not for formulation into an end use product for use in outdoor residential misting systems” 

Directions for Use 

One of these statements may be added to a label to allow reformulation of the product for a specific use or all additional uses supported by a formulator or user group 

“This product may be used to formulate products for specific use(s) not listed on the MP label if the formulator, user group, or grower has complied with U.S. EPA submission requirements regarding support of such use(s).” “This product may be used to formulate products for any additional use(s) not listed on the MP label if the formulator, user group, or grower has complied with U.S. EPA submission requirements regarding support of such use(s).” 

Directions for Use 

Environmental Hazards Statements Required by the RED and Agency Label Policies 

“This pesticide is extremely toxic to aquatic organisms, including fish and invertebrates. Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance, contact your State Water Board or Regional Office of the EPA.” 

Precautionary State

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Description Amended Labeling Language Placem

End Use Products Primarily Intended for WPS and Occupational Use (includes commercial pest control operato

Restricted Use Pesticide (For all products used for wide area outdoor broadcast application including agricultural crops, golf courses, nurseries, and sod farms, except wide area mosquito adulticide use.) 

“RESTRICTED USE PESTICIDE Due to Toxicity to Fish and Aquatic Organisms. For retail sale to and use only by certified applicators or persons under the direct supervision and only for those uses covered by the certified applicator’s certification.” 

Top front panel of 

PPE Requirements Established by the RED1 

For Wettable Powder (only wettable powder formulations packaged in water soluble bags will be eligible for reregistration). Note: If the use of ULV foggers or fog or mist generators is not permitted or not feasible for the end-use product, the statement requiring special PPE and respirators for those uses may be omitted. Note if aerial application is not permitted or not feasible for the end-use product, the engineering 

APersonal Protective Equipment (PPE) Some materials that are chemical-resistant to this product are (registrant inserts 

correct chemical-resistant material). If you want more options, follow the instructions for category@ [registrant inserts A,B,C,D,E,F,G,or H] on an EPA chemical-resistance category selection chart.” “Applicators using ULV cold foggers or fog/mist generators in indoor spaces must wear: > Coveralls over long-sleeved shirt and long pants, > Chemical-resistant gloves, > Chemical resistant footwear plus socks, and > Chemical-resistant headgear, if overhead exposure. “Applicators using ULV cold foggers and/or fog/mist generators in outdoor spaces must wear: > Long-sleeve shirt and long pants, > Shoes plus socks, and > Chemical-resistant gloves. Note to Registrant: If cold fogger and/or fog/mist generator use is prohibited on the label, the above PPE for these uses may be omitted. 

Immediately followPrecautionary StateHumans and Dome

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Description Amended Labeling Language Placem

control statements referring to pilots may be omitted. 

“All other mixers, loaders, applicators, and other handlers must wear: > Long-sleeve shirt and long pants, > Shoes plus socks, > Chemical-resistant gloves for all handlers except for applicators using motorized ground equipment, pilots, and flaggers, > Chemical-resistant apron for mixers/loaders, persons cleaning equipment, and persons exposed to the concentrate and for handlers performing animal dip applications.” “See engineering controls for additional requirements.” Instruction to Registrant: Drop the “N” type prefilter from the respirator statement, if the pesticide product contains, or is used with, oil. 

PPE Requirements Established by the RED1 

For Liquid Concentrate and Dry Flowable Formulations (Dry Flowables not registered at this time, but may be registered in the future.) Note: If the use of ULV foggers or fog or mist generators is not permitted or not feasible for the end-use product, the statement requiring special PPE and respirators for those uses may be omitted. Note if aerial application is not permitted or not feasible for the end-use 

“Personal Protective Equipment (PPE): Some materials that are chemical-resistant to this product are (registrant inserts 

correct chemical-resistant material). If you want more options, follow the instructions for category [registrant inserts A,B,C,D,E,F,G,or H] on an EPA chemical-resistance category selection chart.” “Applicators using ULV cold foggers and/or fog/mist generators in indoor spaces must wear: > Coveralls over long-sleeved shirt and long pants, > Chemical-resistant gloves, > Chemical resistant footwear plus socks, and > Chemical-resistant headgear, if overhead exposure” “Applicators using ULV cold foggers and/or fog/mist generators in outdoor spaces must wear: > Long-sleeve shirt and long pants, > Shoes plus socks, and > Chemical-resistant gloves.” “All other mixers, loaders, other applicators, and other handlers must wear: > Long-sleeve shirt and long pants, 

Immediately followPrecautionary StateHumans and Dome

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Description Amended Labeling Language Placem

product, the engineering control statements referring to pilots may be omitted. 

> Shoes plus socks, > Chemical-resistant gloves for all handlers except for applicators using motorized ground equipment, pilots, and flaggers, and > Chemical-resistant apron for handlers performing animal dip applications.” “See engineering controls for additional requirements.” Instructions to Registrant: Drop the “N” type prefilter from the respirator statement, if the pesticide product contains, or is used with, oil. If cold fogger and/or fog/mist generator use is prohibited on the label, the above PPE for those uses may be omitted. 

PPE Requirements Established by the RED1 

For Granular Formulations 

“Personal Protective Equipment (PPE) Some materials that are chemical-resistant to this product are” (registrant inserts correct chemical-resistant material). “If you want more options, follow the instructions for category” [registrant inserts A,B,C,D,E,F,G,or H] “on an EPA chemical-resistance category selection chart.” “All loaders , applicators, and other handlers must wear: > Long-sleeve shirt and long pants, > Shoes plus socks, and > Chemical-resistant gloves for all handlers except for applicators using motorized ground equipment, pilots, and flaggers.” “See engineering controls for more requirements.” 

Immediately followPrecautionary StateHumans and Dome

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Description Amended Labeling Language Placem

PPE Requirements Established by the RED1 

For Dust Formulations Note: if application with aerial or motorized ground equipment is not feasible with the labeled uses, the prohibition statement may be eliminated. 

“Personal Protective Equipment (PPE) Some materials that are chemical-resistant to this product are (registrant inserts 

correct chemical-resistant material). If you want more options, follow the instructions for category [registrant inserts A,B,C,D,E,F,G,or H] on an EPA chemical-resistance category selection chart.” “Loaders, applicators, and other handlers must wear: > Long-sleeve shirt and long pants, > Shoes plus socks, > Chemical-resistant gloves, and > A NIOSH-approved respirator with: -- a dust/mist filter with MSHA/NIOSH approval number prefix TC-21C or -- any N, R, P, or HE filter.” “Application with aerial or motorized ground equipment is prohibited.” 

Immediately followPrecautionary StateHumans and Dome

User Safety Requirements “Follow manufacturer's instructions for cleaning/maintaining PPE. If no such instructions for washables exist, use detergent and hot water. Keep and wash PPE 

separately from other laundry.” “Discard clothing and other absorbent materials that have been drenched (except as required by directions for use) or heavily contaminated with this product=s concentrate. Do not reuse them.” 

Precautionary StateHumans and Domeimmediately below 

Engineering controls for Wettable Powder Formulations 

“Engineering controls Water-soluble packets when used correctly qualify as a closed mixing/loading system under the Worker Protection Standard for Agricultural Pesticides [40 CFR 170.240(d)(4)]. Mixers and loaders using water-soluble packets must : -- wear the personal protective equipment required in the PPE section of this labeling for mixers and loaders, and -- be provided and must have immediately available for use in an emergency, such as a broken package, spill, or equipment breakdown chemical resistant footwear and dust/mist respirators. Pilots must use an enclosed cockpit that meets the requirements listed in the 

Precautionary StateHumans and Domeimmediately below Requirements 

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Description Amended Labeling Language Placem

Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240(d)(6)].” 

Engineering controls for Liquids, Dry Flowable, and Granular Formulations 

“Pilots must use an enclosed cockpit that meet the requirements listed in the Worker Protection Standard (WPS) for agricultural pesticides [40 CFR 170.240(d)(6)].” 

Precautionary StateHumans and Domeimmediately below 

Environmental Hazards Statements for products labeled for outdoor uses other than as a wide area mosquito adulticide: (PR Notice 2005-1 recommends separating labels intended for wide area mosquito adulticide applications.) 

“This product is extremely toxic to aquatic organisms, including fish and invertebrates. Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean water mark. Do not apply when weather conditions favor drift from treated areas. Drift and runoff from treated areas may be hazardous to aquatic organisms in neighboring areas. Do not contaminate water when disposing of equipment wash waters.” “This chemical can contaminate surface water through spray drift. Under some conditions, it may also have a high potential for runoff into surface water (primarily in runoff events accompanied by erosion), for several to many months post-application. These include poorly draining or wet soils with readily visible slopes toward adjacent surface waters, frequently flooded areas, and areas overlying extremely shallow groundwater, areas with in-field canals or ditches that drain to surface water, areas not separated from adjacent surface waters with vegetated filter strips, and areas over-lying tile drainage systems that drain to surface waters.” “This pesticide is highly toxic to bees exposed to direct treatment on blooming crops or weeds. Do not apply this product or allow it to drift to blooming crops or weeds while bees are actively visiting the treatment area.” 

Precautionary Statefollowing the User Recommendations 

Environmental Hazards Statements for products labeled solely for use as a wide area mosquito adulticide: (PR Notice 2005-1 recommends separating 

“ENVIRONMENTAL HAZARDS” “This pesticide is extremely toxic to aquatic organisms, including fish and invertebrates. Runoff from treated areas or deposition of spray droplets into a body of water may be hazardous to fish and aquatic invertebrates.” “Before making the first application in a season, it is advisable to consult with the state or tribal agency with primary responsibility for pesticide regulation to 

Precautionary StateEnvironmental Haz

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Description Amended Labeling Language Placem

labels intended for wide area mosquito adulticide applications.) 

determine if other regulatory requirements exist.” “This pesticide is highly toxic to bees exposed to direct treatment on blooming crops or weeds. Do not apply this product or allow it to drift to blooming crops or weeds while bees are actively visiting the treatment area.” “Do not apply over bodies of water (lakes, rivers, permanent streams, natural ponds, commercial fish ponds, swamps, marshes or estuaries), except when necessary to target areas where adult mosquitoes are present, and weather conditions will facilitate movement of applied material away from the water in order to minimize incidental deposition into the water body. Do not contaminate bodies of water when disposing of equipment rinsate or washwaters.” 

Environmental Hazards Statements for products labeled as a wide area mosquito adulticide and is labeled for other outdoor uses as well: (PR Notice 2005-1 recommends separating labels intended for wide area mosquito adulticide applications.) 

“ENVIRONMENTAL HAZARDS for TERRESTRIAL APPLICATIONS” “This product is extremely toxic to aquatic organisms, including fish and invertebrates. This product may contaminate water through drift of spray in wind or via runoff events. Use care when applying in areas adjacent to any body of water. Do not apply when weather conditions favor drift from target area.” “Except as specified in the directions for use, do not apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment wash-waters or rinsate.” “ENVIRONMENTAL HAZARDS for WIDE AREA MOSQUITO ADULTICIDE APPLICATIONS” “This pesticide is extremely toxic to aquatic organisms, including fish and invertebrates. Runoff from treated areas or deposition of spray droplets into a body of water may be hazardous to fish and aquatic invertebrates.” “When applying as a wide area mosquito adulticide, before making the first application in a season, it is advisable to consult with the state or tribal agency 

with primary responsibility for pesticide regulation to determine if other regulatory requirements exist.” 

Precautionary StateEnvironmental Haz

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Description Amended Labeling Language Placem

“This pesticide is highly toxic to bees exposed to direct treatment on blooming crops or weeds. Do not apply this product or allow it to drift to blooming crops or weeds while bees are actively visiting the treatment area.” “When applying as a wide area mosquito adulticide, do not apply over bodies of water (lakes, rivers, permanent streams, natural ponds, commercial fish ponds, swamps, marshes or estuaries), except when necessary to target areas where adult mosquitoes are present, and weather conditions will facilitate movement of applied material away from the water in order to minimize incidental deposition into the water body. “ 

Environmental Hazards For Products labeled only for Indoor Use EXCEPT ready to use impregnated materials (e.g. flea collars, ear tags, coils, mats) (Note: Products used on domestic animals like flea collars and ear tags, generally do not require an Environmental Hazards statement.) 

Note to registrant: Products labeled solely for indoor use except as noted below may omit the Environmental Hazards statements. Such products must have the following statement in the Directions for Use: “For indoor use only.” For products packaged in containers equal or greater than 5 gallons or 50 lbs, add the following statement: “Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance contact your State Water Board or Regional Office of the EPA.” 

Precautionary Statefollowing the User Recommendations 

Restricted-Entry Interval for products with directions for use within scope of the Worker Protection Standard for 

“Do not enter or allow worker entry into treated areas during the restricted entry interval (REI) of 12 hours.” “PROHIBITION - Harvesting of conifer seed cones is prohibited within 30 days 

Directions for Use, Requirements Box 

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Description Amended Labeling Language Placem

Agricultural Pesticides (WPS) Note: If use on conifer cone seeds is not on the label, the above prohibition statement may be omitted. 

of application.” 

Early Entry Personal Protective Equipment for products with directions for use within the scope of the WPS 

“PPE required for early entry to treated areas that is permitted under the Worker Protection Standard and that involves contact with anything that has been treated, such as plants, soil, or water, is: * coveralls, * shoes plus socks, and * chemical-resistant gloves made of any waterproof material.” 

Direction for Use Agricultural Use R

Entry Restrictions for products having nonWPS uses applied as spray Note: This excludes products labeled for use when people are present (e.g. outdoor residential misting systems, fabric treatments and pet applications) 

Entry Restriction for products applied as a surface spray (does not apply to products applied directly to domestic animals): “Do not enter or allow others to enter until sprays have dried.” Entry Restriction for products applied as a space spray or fog: “Do not enter or allow others to enter until vapors, mists, and aerosols have dispersed, and the treated area has been thoroughly ventilated.” 

If no WPS uses on the appropriate statfor Use Under GenRestrictions. If the WPS uses, then creUse Requirements Notice 93-7 and plstatement inside th

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Description Amended Labeling Language Placem

Entry Restrictions for products having nonWPS uses applied as granular or dusts 

“Do not enter or allow others to enter until dusts have settled.” For products with use instructions requiring watering in after application: “Do not enter or allow others to enter the treated area until dusts have settled. If soil incorporation is required after the application, do not enter or allow others to enter the treated area (except those persons involved in the incorporation) until the incorporation is complete. If the incorporation is accomplished by watering-in, do not enter or allow others to enter the treated area until the surface is dry after the watering-in.” 

Entry Restrictions for products labeled solely for use when people are present (e.g. fabric treatments, livestock, wide area mosquito adulticide applications, and pet applications) 

No entry restrictions are required. See below under “Use Restrictions” for further requirements. 

Entry Restrictions for products labeled for use when people are present (e.g. fabric treatments, livestock, pet applications)and for use on other sites as a directed or space spray. 

Products labeled for use as a directed spray (does not apply to products applied directly to domestic animals): “Except when (insert application method or site that allows people to be present), do not enter or allow others to enter until sprays have dried.” Products labeled for use as a space spray or fog: “Except when (insert application method or site that allows people to be present), do not enter or allow others to enter until vapors, mists, and aerosols have dispersed, and the treated area has been thoroughly ventilated.” Note to Registrant: An example is as follows: Except when applying to pets or livestock, do not enter or allow others to enter until sprays have dried. 

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Description Amended Labeling Language Placem

General Application Restrictions for products with WPS or non-WPS uses on the label Note: This excludes products that contain any directions for when people are permitted to be present in the treated area (e.g. wide-area mosquito adulticide applications, fabric treatments, and applications to livestock and pets) 

“Do not apply this product in a way that will contact workers or other persons, either directly or through drift.” “Only protected handlers may be in the area during application.” 

Place in the Directi

General Application Restrictions for products with WPS and non-WPS uses on the label AND are labeled for use when people are may be present (e.g. . wide-area mosquito adulticide applications, fabric treatments, and applications to livestock and pets) 

“Except when” (insert application method or site that allows people to be present) “do not apply this product in a way that will contact workers or other persons, either directly or through drift.” “Except when” (insert application method or site that allows people to be present) “only protected handlers may be in the area during application.” “Do not breathe dusts, vapors, or spray mist.” 

Place in the Directi

General Application Restrictions for products solely labeled for use when people may be present (e.g. wide-area mosquito adulticide applications, fabric 

No general application restrictions are required. See below under “Use Restrictions” for further requirements. 

Place in the Directi

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Description Amended Labeling Language Placem

treatments, and applications to livestock and pets) Other Application Restrictions (Risk Mitigation) 

Products labeled for use in mushroom houses: “Use of high pressure hand wand prohibited in mushroom houses.” Products formulated as dusts: “Use of handheld power duster equipment is prohibited.” Products labeled for or intended to be applied by sponge application: Application instruction for sponge application must be removed from the label, and the following statement must be added: “This product may not be applied by sponge application.” Products labeled for or intended for use as directed surface sprays for use on residential indoor surfaces (excludes Ready to Use products and Total Release Foggers: Application instruction for directed surface sprays (such as low pressure hand wand, backpack sprayer, and ULV cold fogger) to indoor surfaces at residential sites must be removed from the label, and the following statement must be added: “Do not apply as a broadcast, crack and crevice, or spot treatment to indoor surfaces at residential sites.” Ready to Use Products labeled or intended for use on residential indoor surfaces: Ready to Use consumer spray products labeled for use on indoor surfaces 

Directions for Use 

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Description 

Use-Specific Application Rate and Related Restrictions (Note: The maximum application rate and maximum seasonal rates specified in this table must be listed as pounds or gallons of formulated product per acre/square ft/ppm/cubic feet etc., not just as pounds active ingredient) 

Amended Labeling Language Placem

(broadcast, spot, and crack and crevice) at residential sites must be formulated to contain no more than 0.5% of permethrin active ingredient. Total Release Foggers labeled or intended for residential indoor use: Total release foggers labeled for indoor use at residential sites must be formulated to contain no more than 0.25% permethrin active ingredient. Note to Registrant: The Agency will consider products with higher concentrations if the registrants of the products can provide justification or data to the Agency which demonstrates that an equivalent ISR of 2.4 μg/cm2, or less, will results in a room size of 2000 ft3 or less. Total release foggers labeled for any indoor use (commercial/industrial and/or residential) must contain the following entry restriction: “Wait four (4) hours after application, then open windows, vents and doors for one hour. There should be no remaining trace of pesticide fog or aerosol. If an odor is still detected additional ventilation is required.” 

Directions for Use Instructions 

Amend all agricultural use product labels with the following crops to reflect the following maximum application rate, retreatment intervals, and seasonal maximum application rates: 

Crop Maximum rate 

per application 

(lb ai/A) 

Retreatment 

interval 

(Days) 

Seasonal 

Maximum 

Appication Rate 

(lb ai/A) 

Alfalfa 0.2 30 0.2 per cutting Almonds 0.25 10 0.75 Hazelnuts 0.25 10 0.75 Pistachios 0.3 10 0.9 Walnuts 0.25 10 0.75 Apples 0.25 10 0.5 

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Description Amended Labeling Language Placem

Pears 0.25 

(0.4 dormant 

only) 

10 0.65 

Cherries 0.2 10 0.6 Peaches/Nectarin es 

0.25 10 0.75 

Artichokes 03 10 0.9 Asparagus 0.1 7 0.4 Avocados 0.2 7 0.8 Broccoli 0.2 5 0.8 Brussels Sprouts 0.1 5 0.4 Cabbage 0.2 5 0.4 (0.8 in HI) Cauliflower 0.2 7 0.8 (1.2 in HI) Cantaloupes 0.15 7 0.75 (1.2 in HI) Cucumbers 0.2 7 1.2 Pumpkins 0.2 7 1.2 Squash (summer, winter) 

0.2 7 1.2 

Watermelon 0.2 7 1.2 Eggplant 0.15 7 0.6 (1.0 in HI) Peppers, bell 0.2 5 0.8 Tomatoes 0.2 7 0.6 (0.8 in HI) Celery 0.2 7 1.0 (1.2 in HI) Lettuce 0.2 7 0.8 (1.2 in HI) Spinach 0.2 3 0.6 Collards 0.15 3 0.45 Greens, Turnip 0.15 3 0.45 Corn, Field 0.15 7 0.45 Sweet Corn 0.2 3 0.8 Garlic 0.2 10 0.8 Onions 0.3 7 1.0 Horseradish 0.15 10 0.45 Papaya 0.15 10 0.75 Potatoes 0.2 10 0.8 Soybeans 0.2 10 0.4 

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Description Amended Labeling Language Placem

Use-Specific Application Restrictions for all liquid and wettable powder labels 

Products not labeled or intended for use in outdoor residential misting systems must contain the following statement: “Not for use in outdoor residential misting systems.” 

Directions for Use Precautions and ReApplication Instruc

(Outdoor residential misting system requirement) 

Products labeled or intended for use in outdoor residential misting systems must contain the following statements: 

Note to registrant: also express this application rate as pounds or gallons of end-use product formulation. 

“Directions for use in outdoor residential misting systems:” “When using this product installers and service technicians must comply with the license, certification, or registration requirements of the state(s), tribe(s), or local authority(ies) where they are installed.” “Do not apply this pesticide when people, pets, and food are present.” “Do not use in an evaporative cooling system.” “Direct nozzles to spray towards the target area and away from swimming pools, water bodies, or eating and cooking areas.” “If used in a system with a reservoir tank for the end use dilution, the system reservoir tank must be locked. Securely attach the end use pesticide label and a dilution statement to the system reservoir tank in a weather protected area or plastic sleeve. The dilution statement must be phrased as follows: this container holds __ parts [product name] to __ parts water” “If used in a direct injection system, the pesticide container must be locked. Securely attach the end use label to the pesticide container in a weather protected area or plastic sleeve.” (These instructions not applicable to wettable powder products). “This product may only be used in systems that have been calibrated to apply no more than the maximum application rate of 0.25 grams per 1000 cubic feet per 

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Description Amended Labeling Language Placem

day.” “If the system works on an automatic timer, set the timing for application when people, pets, and food are unlikely to be present.” “If the system works when a person operates a remote activation device, then application of this pesticide when people, pets, and food are present is prohibited.” Note to registrant: also express this application rate as pounds or gallons of enduse product formulation. 

Products with use instructions for use as a wide area mosquito adulticide (PR Notice 2005-1 recommends that separate registrations be issued for products with these use patterns.) 

Amend label instruction to reflect the following: 

• Recommendations and requirements specified in Pesticide Registration 

Notice 2005-1; 

• Remove 100 foot buffer zone use restriction from the product label; and 

• Maximum application rate 0.007 lb ai/A. 

In addition, labels must be amended to include the following statements: “Do not apply more than 0.007 lb ai/A per day. Do not apply more than 0.18 lb ai/A per year. More frequent treatments may be made to prevent or control a threat to public and/or animal health determined by a state, tribal or local health or vector control agency on the basis of documented evidence of disease causing agents in vector mosquitoes or the occurrence of mosquito-borne diseases in animal or human populations, or if specifically approved by the state or tribe during a natural disaster recovery effort.” “Apply when wind speed is greater than or equal to 1 mph.” “Do not apply by fixed wing aircraft at a height less than 100 feet, or by helicopter at a height less than 75 feet unless specifically approved by the state or tribe based on public health needs.” 

Directions for Use Precautions and ReApplication Instruc

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Description Amended Labeling Language Placem

“Aerial Application: Spray equipment must be adjusted so that the volume median diameter product is less than 60 microns (Dv 0.5<60 um) and that 90% of the spray is contained in droplets smaller than 80 microns (Dv 0.9 <80 microns). The effects of flight speed and, for non-rotary nozzles, nozzle angle on the droplet size spectrum must be considered. Directions from the equipment manufacturer or vendor, pesticide registrant or a test facility using a wind tunnel and laser-based measurement instrument must be used to adjust equipment to product acceptable droplet size spectra. Application equipment must be tested at least annually to confirm that pressure at the nozzle and nozzle flow rate(s) are properly calibrated.” “Ground-based application: Spray equipment must be adjusted so that the volume median diameter is less than 30 microns (Dv 0.5 <30 um) and that 90% of the spray is contained in droplets smaller than 50 microns (Dv 0.9 < 50 um). Directions from the equipment manufacturer or vendor, pesticide registrant or a test facility using a laxer-based measurement instrument must be used to adjust equipment to produce acceptable droplet size spectra. Application equipment must be tested at least annually to confirm that pressure at the nozzle and nozzle flow rate(s) are properly calibrated.” 

Spray Drift (for RUP products) 

“OBSERVE THE FOLLOWING REQUIREMENTS WHEN SPRAYING IN THE VICINITY OF AQUATIC AREAS SUCH AS LAKES; RESERVOIRS; RIVERS; PERMANENT STREAMS; MARSHES OR NATURAL PONDS; ESTUARIES AND COMMERICAL FISH FARM PONDS. Do not apply by ground equipment within 25 feet, or by air within 150 feet of lakes; reservoirs; rivers; permanent streams; marshes or natural ponds; estuaries; and commercial fish farm ponds. Increase the buffer zone to 450 feet when ultra low volume (ULV) application is made. Risk of exposure to sensitive aquatic areas can be reduced by avoiding applications when wind direction is toward the aquatic area. 

Directions for Use Precautions and ReApplication Instruc

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Description Amended Labeling Language Placem

Do not cultivate within 10’ of the aquatic area so to allow growth of a vegetative filter strip. OBSERVE THE FOLLOWING REQUIREMENTS WHEN SPRAYING IN ALL OTHER AREAS, INCLUDING THE SENSATIVE AREAS STATED ABOVE. For aerial applications, the spray boom should be mounted on the aircraft as to minimize drift caused by wingtip or rotor vortices. The minimum practical boom length should be used and must not exceed 75% of wing span or rotor diameter. For groundboom and aerial applications, use only medium or coarser spray nozzles according to ASABE (S572) definition for standard nozzles. Aerial applicators must consider flight speed and nozzle orientation in determining droplet size. Spray should be released at the lowest at the lowest height consistent with pest control and flight safety. Applications more than 10 feet above the crop canopy should be avoided. Apply using a nozzle height of no more than 4 feet above the ground or crop canopy. Make aerial or ground applications when the wind velocity favors on target product deposition (approximately 3 to 10 mph). Do not apply when wind velocity exceeds 15 mph. Avoid applications when wind gusts approach 15 mph. Low humidity and high temperatures increase the evaporation rate of spray droplets and therefore the likelihood of increased spray rift to aquatic areas. Avoid spraying during conditions of low humidity and/or high temperatures. When applications are made with a cross-wind, the swath will be displaced downwind. The applicator must compensate for this displacement at the downwind edge of the application area by adjusting the path of the aircraft upwind. 

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Description Amended Labeling Language Placem

Do not make aerial or ground applications into temperature inversions. Inversions are characterized by stable air and increasing temperatures with height above the ground. Mist or fog may indicate the presence of an inversion in humid areas. The applicator may detect the present of an inversion by producing smoke and observing a smoke layer near the ground surface.” 

Products Primarily Used by Consumers/Homeowners 

Environmental Hazard Statements 

For products that have outdoor uses (except for RTU products, such as pet collars, ear tags, and impregnated clothing): “This product is extremely toxic to fish. Do not apply directly to or near water. Drift and run-off may be hazardous to fish in water adjacent to treated areas. Do not contaminate water when disposing of equipment, washwater, or rinsate. See Directions for Use for additional precautions and requirements.” 

Precautionary State

Entry Restrictions except for products labeled for use when people are present (e.g. livestock and pet applications) 

Entry Restriction for products applied as a spray (does not apply to products applied directly to domestic animals): “Do not allow adults, children or pets to enter until sprays have dried.” Entry Restriction for products applied as a space spray or fogger: “Do not allow adults, children or pets to enter until vapors, mists, and aerosols have dispersed, and the treated area has been thoroughly ventilated as specified on the label.” Entry Restriction for products applied dry (does not apply to products applied directly to domestic animals) : “Do not allow people or pets to enter the treated area until dusts have settled. If watering in is required after the application, do not enter or allow others to enter the treated areas (except those involved in the watering) until the watering-in is complete and the surface is dry.” 

Directions for use uPrecautions and Re

Entry Restrictions for No entry restrictions are required. See below under “Use Restrictions” for further 

116
Description Amended Labeling Language Placem

products labeled solely for use when people are present (e.g. livestock and pet applications) 

requirements. 

Entry Restrictions for products labeled for use when people are present (e.g. livestock and pet applications) and for use on other sites as a directed or space spray. 

Products labeled or intended for use as a directed sprays: “Except when (insert application method or site that allows people to be present), do not enter or allow others to enter treated area until sprays have dried.” Products labeled for or intended for use as a space spray or foggers: “When applied as a space spray or fogger, do not enter or allow others to enter treated area until vapors, mists, and aerosols have dispersed, and the treated area has been thoroughly ventilated.” Note to Registrant: An example is as follows: Except when applying directly to pets, do not enter or allow others to enter treated area until sprays have dried. 

General Application Restrictions Note: This excludes products labeled for use when people are present (e.g. fabric treatments and livestock and pet applications) 

“Do not apply this product in a way that will contact workers or other persons, either directly or through drift.” “Only protected handlers may be in the area during application.” 

Place in the Directi

General Application Restrictions for products labeled for use when people may be present (e.g. fabric treatments and livestock and pet applications) AND labeled for use on other 

“Except when” (insert application method or site that allows people to be present) “do not apply this product in a way that will contact workers or other persons, either directly or through drift.” “Except when” (insert application method or site that allows people to be present) “only protected handlers may be in the area during application.” 

Place in the Directi

117
Description Amended Labeling Language Placem

sites as a directed surface or space application. General Application Restrictions for products solely labeled for use when people may be present (e.g. misting systems, fabric treatments and pet applications) 

No general application restrictions are required. See below under “Use Restrictions” for further requirements. 

Place in the Directi

Additional Application Restrictions Requirements for Granular Formulations labeled or intended for outdoor 

uses: “Do not apply directly to or near water, storm drains, or drainage ditches. Do not apply when windy. Apply this product directly to your lawn or garden, and sweep any product landing on the driveway, sidewalk, or street, back onto the treated area. To prevent product run-off, do not over water the treated area or apply when heavy rain is expected.” Requirements for Liquid and Dust products labeled or intended for outdoor uses (excludes Ready to Use Products): “Do not apply directly to or near water, storm drains, or drainage ditches. Do not apply when windy. To prevent product run-off, do not over water the treated area(s) or apply when heavy rain is expected. Rinse applicator over lawn or garden area only.” Requirements for Ready to Use Formulations labeled or intended for outdoor use: “Do not apply directly to or near water, storm drains, or drainage ditches. Do not apply when windy. To prevent product run-off, do not over water, or apply prior to heavy rainfall.” 

Directions for Use Precautions and Re

118
Description Amended Labeling Language Placem

Products labeled or intended for sponge application: Application instructions for sponge application must be removed from the label, and the following statement must be added: “This product may not be applied by sponge application.” Ready to Use Products labeled or intended for use on indoor surfaces at residential sites: Ready to Use consumer spray products labeled for use on indoor surfaces at residential sites (broadcast, spot, and crack and crevice) must be formulated to contain no more than 0.5% ai or less of permethrin active ingredient. Note to Registrant: The Agency will consider specialized sprays with higher concentrations, up to 3% ai, which are intended to be injected directly into cracks and crevices and behind walls or spaces. The Agency will consider products with higher concentrations if the registrants of the products can provide justification or data to the Agency which demonstrates that the specialized use will result in little to no exposure. Total Release Foggers labeled or intended for indoor use at residential sites: Total release foggers labeled for indoor use at residential sites must be formulated to contain no more 0.25% permethrin active ingredient. Note to Registrant: The Agency will consider products with higher concentrations if the registrants of the products can provide justification or data to the Agency which demonstrates that an equivalent ISR of 2.4 μg/cm2, or less, will results in a room size of 2000 ft3 or less.  “Wait four (4) hours after application, then open windows, vents, and doors to outdoors for one hour. There should be no remaining trace of pesticide fog or 

119
Description Amended Labeling Language Placem

aerosol. If an odor is still detected, continue ventilating until no remaining trace or odor of pesticide remains.” 

Use-Specific Application Restrictions for all liquid and wettable powder labels (Outdoor residential misting system requirement) (Note: The maximum allowable application rate and maximum allowable seasonal rate must be listed as pounds or gallons of formulated product per acre, not just as pounds active ingredient per acre. All rates must be expressed in terms the applicator can use in order to arrive at the maximum application rate. For example, for sprays rates must specify the duration of spray to a specific area, i.e., spray for X seconds to a space Y feet by Z feet.) 

Products not intended for use in outdoor residential misting systems must contain the following statement: “Not for use in outdoor residential misting systems.” Products labeled or intended for use in outdoor residential misting systems must contain the following statements: “Directions for use in outdoor residential misting systems:” “When using this product installers and service technicians must comply with the license, certification, or registration requirements of the state(s), tribe(s), or local authority(ies) where they are installed.” “Do not apply this pesticide when people, pets, and/or food are present.” “Do not use in an evaporative cooling system.” “If the system is activated by an automatic timer, then set the timer to activate the system when people, pets, and/or food are not expected to by present.” “If the system is activated using a remote, then the person operating the remote must not activate the system when people, pets, and/or food are present.” “Direct nozzles to spray towards the target area and away from swimming pools, water bodies, or eating and cooking areas.” “If used in a system with a reservoir tank for the end use dilution, the system reservoir tank must be locked. Securely attach the end use pesticide label and a dilution statement to the system reservoir tank in a weather protected area or plastic sleeve. The dilution statement must be phrased as follows: this container holds __ parts [product name] to __ parts water” 

Directions for Use Precautions and ReApplication Instruc

120
Description Amended Labeling Language Placem

“If used in a direct injection system, the pesticide container must be locked. Securely attach the end use label to the pesticide container in a weather protected area or plastic sleeve.” (These instructions not applicable to wettable powder products). “This product may only be used in systems that have been calibrated to apply no more than the maximum application rate of 0.25 grams of active ingredient per 1000 cubic feet per day.” Note to registrant: also express this application rate as pounds or gallons of end-use product formulation. 

Environmental Hazards For Products labeled only for Indoor Use EXCEPT ready to use impregnated materials (e.g. flea collars, ear tags, coils, mats) (Note: Products used on domestic animals like flea collars and ear tags, generally do not require an Environmental Hazards statement.) 

Note to registrant: Products labeled solely for indoor use except as noted below may omit the Environmental Hazards statements. Such products must have the following statement in the Directions for Use: “For indoor use only.” For products packaged in containers equal or greater than 5 gallons or 50 lbs, add the following statement: “Do not discharge effluent containing this product into lakes, streams, ponds, estuaries, oceans, or other waters unless in accordance with the requirements of a National Pollutant Discharge Elimination System (NPDES) permit and the permitting authority has been notified in writing prior to discharge. Do not discharge effluent containing this product to sewer systems without previously notifying the local sewage treatment plant authority. For guidance contact your State Water Board or Regional Office of the EPA.” 

Precautionary Statefollowing the User Recommendations 

1 PPE that is established on the basis of Acute Toxicity of the end-use product must be compared to the active ingredient PPE in this d

protective PPE must be placed in the product labeling. For guidance on which PPE is considered more protective, see PR Notice 93-7

121
Appendix A-1

Food and Feed Use Patterns Subject for Reregistration of Permethrin 

Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Food/Feed Crop Uses Alfalfa (including alfalfa grown for seed) 

Postemergence broadcast Ground and aerial equipment 

EC 

WP 0.2 lb/A 1 per cutting Not Specified (NS) 

A 0-day PHI is specifie

lb/A, and a 14-day PHI applications at >0.1 lb/Do not exceed 0.2 lb aiApply in a minimum of ground equipment, resp

Alfalfa (grown for seed) 

Postemergence broadcast Ground and aerial equipment EC 0.2 lb/A NS NS 

SLN No. AZ850006: Agal/A using aerial or grSLN No. CA820081: Ausing aerial equipment. Do not feed treated hay feed or food. 

Almonds 

Foliar and soil broadcast applications Ground and aerial equipment 

EC 

G 

0.4 lb/A 5 NS 

A 7-day PHI is specifieApply no more than 2 l0.8 lb ai/A applied duriApply in a minimum of equipment. Do not graze livestock crops from treated area

Foliar and soil broadcast applications Ground equipment 

EC 

A 7-day PHI is specifieApply no more than 2 lApply in a minimum of only. Do not graze livestock crops from treated area

A-1
Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Apples 

Broadcast foliar application Ground equipment 

EC 

WP 0.25 lb ai/A 2 10 

Do not apply more than Do not apply after petaApply in a minimum of equipment. Do not graze livestock crops from treated area

Artichoke 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 

0.3 lb/A 

3 10 

A 0-day PHI is specifieDo not apply more than Apply in a minimum of ground equipment, resp

Broadcast foliar application Ground equipment 

EC 

WP 

A 0-day PHI is specifieDo not apply more than Apply in a minimum of only. 

Foliar application Aerial equipment EC NS NS No PHI is specified. Apply in a minimum of 

Asparagus 

Broadcast postemergence application Ground equipment 

EC 

WP 0.1 lb/A 4 7 

A 1-day PHI is specifieDo not apply more than A minimum application 

Avocados 

Broadcast foliar application Ground equipment 

EC 

WP 0.2 lb/A 4 7 

A 7-day PHI is specifieDo not apply more than than 6 applications/seasApply in a minimum of Do not graze livestock crops from treated area

Broccoli, Chinese broccoli 

A-2
Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 5 4 

A 1-day PHI is specifieDo not apply more than Labels specify minimum gal/A using aerial or gr

Brussel sprouts 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 

0.1 lb/A 4 5 

A 1-day PHI is specifieDo not apply more than Labels specify minimum gal/A using aerial or gr

Cabbage and Chinese cabbage (tight-heading varieties only) 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 2 (4 in HI) 5 

A 1-day PHI is specifieDo not apply more that Labels specify minimum gal/A using aerial or gr

Cantaloupe 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 4 (6 in HI) 7 

A 0-day PHI is specifieDo not apply more than Apply in a minimum of equipment and 20 gal/A 

Cauliflower 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.1 lb/A 4 (6 in HI) 5 

A 1-day PHI is specifieDo not apply more than Labels specify minimum gal/A using aerial or gr

Celery 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 5 (6 in HI) 7 

A 1-day PHI is specifieDo not apply more than Apply in a minimum of ground equipment, resp

Cherry 

A-3
Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Broadcast foliar application Ground equipment 

EC 

WP 0.2 lb/A 3 10 

A 3-day PHI is specifieDo not apply more than Do not graze livestock crops from treated areaApply in a minimum of 

Collards (only in AR, AZ, GA, IL, NC, OK, SC, and TX) 

Broadcast foliar application Ground equipment 

EC 

WP 

0.15 lb/A 3 3 

A 1-day PHI is specifieThe maximum seasonaai/A. Apply in a minimum of 

Broadcast foliar application Ground and aerial equipment EC 

For use only in AR, INA 1-day PHI is specifieDo not apply more than Apply in a minimum of ground equipment, resp

Corn, field and pop 

Broadcast or banded preemergence application and broadcast foliar applications Ground and aerial equipment 

EC 

WP 

G 

0.15 lb/A 3 7 

Apply preemergence fremergence. A 0-day PHI is specifiespecified for grain and Do not apply more than Apply in a minimum of ground equipment, resp

Corn, sweet 

A-4
Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Broadcast preemergence and foliar applications Ground and aerial equipment 

EC 

WP 

G 

0.2 lb/A 4 3 

A 1-day PHI is specifieDo not apply more than Apply in a minimum of ground equipment, resp

Cucurbit vegetables (except cantaloupes) 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 6 7 

A 0-day PHI is specifieDo not apply more than Apply in a minimum of equipment and 20 gal/A 

Eggplant 

Broadcast foliar application Ground or aerial equipment 

EC 

WP 0.15 lb/A 

4 

(except HI 

see use 

limitation) 

7 

A 3-day PHI is specifieDo not apply more than Apply in a minimum of ground equipment, resp

Filberts 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.4 lb/A 4 NS 

A 14-day PHI is specifDo not apply more than Labels specify minimum using ground equipmenequipment. Do not graze livestock crops from treated orch

Garlic 

A-5
Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Broadcast foliar application Ground or aerial equipment 

EC 

WP 0.2 lb/A 4 10 

A 1-day PHI is specifieDo not apply more than Apply in a minimum of equipment, and 20 gal/A 

Grass, rangeland (NM only) 

Broadcast application Ground and aerial equipment 

EC 

WP 0.01 lb/A 1 NA 

Do not apply more than Cattle may be present dDo not harvest or feed The Label 100-985 has Apply in a minimum of ground equipment, respSLN No. NM840005 spqt/A for aerial applicatiSLN No. NM840006 spaerial application of 1 qwater. 

Horseradish 

Preplant dip EC 0.83 lb/100 gal (0.1% ai solution) 1 NA Soak sets for 30 minuteBroadcast foliar application Ground equipment 

EC 

WP 0.15 lb/A 3 10 

A 30-day PHI is specifDo not apply more than Apply in a minimum of equipment. 

Leafy Vegetables (except Brassica, Celery, Lettuce, and Spinach) 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 10 3 

A 1-day PHI is specifieDo not apply more than Apply in a minimum of ground equipment, resp

Lettuce 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 4 (6 in HI) 7 

A 1-day PHI is specifieDo not apply more than Apply in a minimum of ground equipment, resp

Mushrooms (mushroom houses and adjacent premise areas) 

A-6
Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Fogging or aerosol application prior to filling house, during cooldown, during spawning, up to pinning, and between breaks. 

EC 

D 

1 oz/qt 

(1 oz per 35,000 ft3 or 

8,000 ft2) 30 per crop 

of 5 breaks 1 

A 3-day PHI is specifieDo not use when mushDo not make more than of first break; more thabreak; and no more thacrop of 5 breaks. 

Surface application until runoff to walls and ceilings prior to filling house, during cool-down, during spawning, up to pinning, and between breaks. 

WP 

0.14 oz/gal 

(0.34 oz/1,000 ft2) 

Onions (dry bulb only) 

Broadcast foliar application Ground or aerial equipment 

EC 

WP 0.3 lb/A 

1.0 lb ai 

seasonal 

max. 

7 

A 1-day PHI is specifieDo not apply more than Apply in a minimum of equipment, and 20 gal/A 

Papayas (FL only) 

Broadcast foliar application Ground Equipment 

EC 

WP 

0.15 lb/A 

5 10 

A 7-day PHI is specifieDo not make more than apply more than 0.15 lb Apply in a minimum of Do not graze livestock crops from treated area

Peaches/Nectarines 

A-7
Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.25 lb/A 3 10 

A 14-day PHI is specifDo not apply more than Apply in a minimum of ground equipment, respDo not graze livestock crops from treated area

Pears 

Dormant through delayed dormant (prebloom) applications Ground and aerial equipment 

EC 

WP 

0.25 lb/A 

(0.4 lb/A for dormant 

only) 

0.65 lb/A 

seasonal 

max. 

10 

Do not apply more than Dormant applications o8 gal of spray oil/acre. Apply in a minimum of ground equipment, respDo not graze livestock cover corps from treate

Peppers, bell 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 4 5 

A 3-day PHI is specifieDo not apply more than Apply in a minimum of ground equipment, resp

Pistachios 

Broadcast foliar application prior to 10% hull split Ground and aerial equipment 

EC 

WP 

G 

0.4 lb/A 2 or 4 NS 

A 0-day PHI is specifieThe maximum seasonaand 0.8 lb ai/A on all oDo not apply after 10% Apply in a minimum of ground equipment, respDo not graze livestock crops from treated areaThe label for the 1.5% prohibits use on pistach

Potatoes 

A-8
Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 4 10 

A 14-day PHI is specifDo not apply more than Apply in a minimum of ground equipment, resp

Potatoes (for greenhouse grown seed potatoes or transplants) 

Foliar application Handsprayers EC 0.03 oz/gal 9 NS 

Only for use in CA. A maximum of 9 applicThe use of treated potaconsumption is prohibi

Soybeans 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 2 10 

A 60-day PHI is specifDo not apply more than Do not graze or feed soApply in a minimum of ground equipment, respmade in vegetable oil a

EC 0.1 lb/A 2 

10 

For use only in AR, FLA 40-day PHI is specifDo not apply more 2 timDo not graze or feed soApply in a minimum of ground equipment, respApplications can includ

10 

For use only in AL, GAA 60-day PHI is specifDo not apply more than Do not graze or feed soGA830007 specifies mand 5 gal/A using aeriarespectively; the other volumes. Applications can includ

Spinach 

A-9
Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 3 3 

A 1-day PHI is specifieDo not apply more than Apply in a minimum of ground equipment, resp

Tomatoes 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.2 lb/A 6 NS 

FMC labels include use A 0-day PHI is specifieDo not apply more than Do not apply as a bandDo not apply to tomato fruit <1 inch in diameteApply in a minimum of aerial equipment, respe

Turnips (only in FL, GA, IL, IN, OK, SC, TX, and WA) 

Broadcast foliar application Ground equipment 

EC 

WP 0.15 lb/A 3 3 

A 1-day PHI is specifieDo not apply more than Apply in a minimum of 

Broadcast foliar application Ground and aerial equipment EC 0.1 lb/A 8 NS 

For use only in AR, INA 1-day PHI is specifieDo not apply more than Apply in a minimum of aerial equipment, respeDo not graze treated arlivestock. 

Walnut 

Broadcast foliar application Ground and aerial equipment 

EC 

WP 0.25 lb/A 3 10 

A 1-day PHI is specifieDo not apply more than Apply in a minimum of equipment and 25 gal/A Do not graze livestock crops from treated area

Seed Treatments Seed Treatments (commercial seed treaters only) 

A-10
Site 

Application Type 

Application Timing 

Application Equipment 

Formulation Max. Single Application Rate 

(ai) 

Max. # 

Apps. 

Minimum 

Retreatment 

Interval (Days) 

Us

Seed Treatment by commercial seed treaters 

EC 

WP 0.5 oz/100 lb seed 1 NA 

For application to seedBrussel sprouts, cabbagtypes), cucurbits, eggplBrassica), peppers (BelNot for use on agricultutreatment equipment at Do not use treated seed 

Livestock Uses Livestock Housing and Premises (dairies, barns, feedlots, stables, poultry houses, swine and livestock houses) 

Surface application to building walls and ceilings 

EC 

WP 0.17 oz/1000 ft2 NS 1-2 weeks Do not treat manure or 

Do not apply directly to 

Dairy and Beef Cattle, Goats, and Sheep 

Dilute whole body spray 

EC 

0.05% a.i. solution at 1-2 

qt/animal 

(.907 mg ai/animal) 

NS 10 

No PSI is specified Concentrated Mid-line and ear 

spray 

0.5% a.i. solution at 

−6 fl oz/animal 

(.212 mg/animal) 

NS NS 

Self oiler 0.125% ai in oil NA NA Poultry Whole body spray EC 

0.33% a.i. solution at 1 gal/100 birds (.120 mg ai/bird) 

NS NS 

Swine 

Whole body spray or dip EC 

0.05% a.i. solution at 1-2 

qt/animal 

(.907 mg ai/animal) 

NS 14 

A 5 day PSI is specified 

Horses 

Spot application to back, face, legs, tail, and ears EC 

0.63% ai solution at 2 fl. 

oz/animal 

(.354 mg ai/animal) 

NS NS 

Whole body wash/dip 0.063% ai solution NS NS 

A-11
Appendix A-2

Non-Food and Non-Feed Use Patterns Subject for Reregistration of Permethrin 

Site Form 

Code 

Max.App 

Rate/App 

Unit 

(ai) Use Pattern/Limitations 

0.2125 lb/A Remove or carefully protect food products and 

food packaging. 

Do not treat animals under 12 weeks of age. AGRICULTURAL 

UNCULTIVATED AREAS EC 0.0523 lb/1K 

sq.ft 

0.0801 lb/moun 

d 

AGRICULTURAL/FARM 

PREMISES WP 0.1212 bag/1K 

sq.ft 

14 day MRI. 

12 hour REI 

ALFALFA WP 0.2 lb/A 

12 hour REI. 

0.1067 lb/A Remove animals prior to treatment. 

Remove feed and water prior to treatment. 

0.0801 Do not apply to plant foliage. lb/moun 

d 

0.04 lb/1 gal 

EC 

6.18E-04 lb/1K 

cu.ft 

For use only in New Mexico (SLN 

Registration) 

Remove animals prior to treatment. 

Remove feed and water prior to treatment. 

Do not apply to plant foliage. 

14 day MRI. 

0.4604 lb/1K 

sq.ft 

For use only in New Mexico (SLN 

Registration 

Remove animals prior to treatment. 

Remove feed and water prior to treatment. 

Do not apply to plant foliage. 

Do not treat animals under 12 weeks of age. 

ANIMAL KENNELS/SLEEPING 

QUARTERS (COMMERCIAL) EC*RTU 0.008 lb/1K 

sq.ft 

PRL NS 

Remove or carefully protect food products and 

food packaging. 

Cover feed and water prior to treatment. 

Do not allow children or pets on treated areas 

until surfaces are dry. 

14 day MRI. 

0.0974 lb/A 

SC/L 

2.72E04 lb/1K cu.ft Cover feed and water prior to treatment. 

0.0457 lb/1K sq.ft 

0.0366 lb/1 gal 

SC/L* 

RTU 0.0974 lb/A 

SC/L* 

RTU 0.0098 lb/1K sq.ft 

AUTOMOBILES - TAXIS -

LIMOUSINES - RECREATIONAL 

VEHICLES - & TIRES 

PRL NS 

Do not allow children or pets on treated areas 

until surfaces are dry. 

A-12
Site Form 

Code 

Max.App 

Rate/App 

Unit 

(ai) Use Pattern/Limitations 

BATHROOM PREMISES/HARD 

SURFACES EC 0.7805 lb/1K sq.ft 

Remove food and animals from premises prior 

to treatment. Remove or carefully protect 

food products and food packaging. 

Remove animals prior to treatment. 

Do not allow children or pets on treated areas 

until surfaces are dry. 

BATHROOM PREMISES/HARD 

SURFACES PRL NS 

Remove or carefully protect food products and 

food packaging. 

Remove animals prior to treatment. 

Do not allow children or pets on treated areas 

until surfaces are dry. 

14 day MRI. 

CADAVERS AND CASKETS PRL NS 

Do not allow children or pets on treated areas 

until surfaces are dry. 

D 1.56E04 lb/Animal Do not treat animals under 12 weeks of age. 

14 day MRI. 

EC 0.0039 lb/1 gal 

CATS (ADULTS/KITTENS) PRL NS 

Do not treat animals under 30 weeks of age. 

90 day MRI. 

Do not treat animal under three months of age. 

14 day MRI. 

RTU 1 sec lb body 

wt (L) 

Retreat as needed. 

CATTLE FEEDLOTS SC/L 0.0175 lb/1 gal 

Remove animals prior to treatment. 

Retreat as needed. 

CHRISTMAS TREE 

PLANTATIONS EC 

1.047 lb/A 

Do not allow children or pets on treated areas 

until surfaces are dry. 

Disallowed in CA. 

5 day MRI. 

12 hour REI. 

0.02 lb/tree 

Do not allow children or pets on treated areas 

until surfaces are dry. 

5 day MRI. 

12 hour REI. 

CHRISTMAS TREE 

PLANTATIONS WP 0.2 lb/A 

Disallowed in CA. 

5 day MRI. 

12 hour REI. 

COMMERCIAL 

STORAGES/WAREHOUSES 

PREMISES 

EC 0.7805 lb/1K sq.ft 

Remove food and animals from premises prior 

to treatment. 

Remove or carefully protect food products and 

food packaging. 

Remove animals prior to treatment. 

Do not allow children or pets on treated areas 

until surfaces are dry. 

SC/L 

0.0366 lb/1 gal 

2.72E04 lb/1K cu.ft 

0.0457 lb/1K sq.ft 

A-13
Site Form 

Code 

Max.App 

Rate/App 

Unit 

(ai) Use Pattern/Limitations 

PRL NS 

Remove animals prior to treatment. 

14 day MRI. 

EC 

0.4604 lb/1K sq.ft 

Remove food and animals from premises prior 

to treatment. 

Remove or carefully protect food products and 

food packaging. 

Remove animals prior to treatment. 

Do not allow children or pets on treated areas 

until surfaces are dry. 

COMMERCIAL 

TRANSPORTATION FACILITIESNONFEED/NONFOOD 

0.08 lb/1 gal 

SC/L 

2.72E04 lb/1K cu.ft 

0.0457 lb/1K sq.ft 

0.0366 lb/1 gal 

PRL NS 

Remove food and animals from premises prior 

to treatment. Remove or carefully protect 

food products and food packaging. 

Remove animals prior to treatment. 

Do not allow children or pets on treated areas 

until surfaces are dry. 

14 day MRI. 

COMMERCIAL/INDUSTRIAL 

LAWNS EC 2.47E04 lb/1K sq.ft 

Do not allow children or pets on treated areas 

until surfaces are dry. 

12 hours REI. 

EC 

0.4604 lb/1K sq.ft Remove food and animals from premises prior 

to treatment. 

Remove or carefully protect food products and 

food packaging. 

Remove animals prior to treatment. 

Do not allow children or pets on treated areas 

until surfaces are dry. 

0.08 lb/1 gal 

SC/L* 

RTU 0.0974 lb/A 

0.0974 lb/A 

COMMERCIAL/INSTITUTIONAL 

/INDUSTRIAL PREMISES/EQUIP. 

(INDOOR) 

SC/L 

2.72E04 lb/1K cu.ft 

0.0457 lb/1K sq.ft 

0.0366 lb/1 gal 

PRL NS 

Remove or carefully protect food products and 

food packaging. 

Remove animals prior to treatment. 

Do not allow children or pets on treated areas 

until surfaces are dry. 

14 day MRI. 

FM 1.75 fl.oz (L) Remove food and animals from premises prior 

to treatment. 

Remove or carefully protect food products and 

food packaging. 

Remove animals prior to treatment. 

Do not allow children or pets on treated areas 

until surfaces are dry. 

12 hour REI. 

COMMERCIAL/INSTITUTIONAL 

/INDUSTRIAL 

PREMISES/EQUIPMENT 

(OUTDOOR) 

SC/L 0.0175 lb/1 gal 

EC 

0.85 lb/A 

0.7805 lb/1K sq.ft 

0.1561 lb/mound 

0.04 lb/1 gal 

A-14
Site Form 

Code 

Max.App 

Rate/App 

Unit 

(ai) Use Pattern/Limitations 

CONIFERS (SEED ORCHARD) EC 0.016 lb 1K trees 

For use in Florida and Texas (SLN 

Registrations) 

1 application per crop cycle or year. 

D 7.81E06 lb/Animal 

Do not treat animals under 12 weeks of age. 

14 day MRI. 

0.0067 lb/Animal 

EC 0.1727 lb/1 gal 

0.1068 lb/20 gal 

Do not treat animals under 26 weeks of age. 

90 day MRI. 

DOGS/CANINES 

(ADULTS/PUPPIES) 

PRL 8 sec lb body 

wt (L) Do not treat animals under 3 months of age. 

14 day MRI. 

RTU 8 sec lb body 

wt (L) 

Remove or carefully protect food products and 

food packaging. 

Do not treat animals under 12 weeks of age. 

14 day MRI. 

SC/L 0.0438 lb/12.5 gal Do not treat animals less than 4 weeks of age. 

DRAINAGE SYSTEMS EC 0.4604 lb/1K sq.ft 

Remove or carefully protect food products and 

food packaging. 

EC 0.1992 lb/minute Remove or carefully protect food products and 

food packaging. 

EATING ESTABLISHMENTS SC/L 0.0974 lb/A 

SC/L* 

RTU 0.0974 lb/A 

EC 0.7805 lb/1K sq.ft 

Remove food and animals from premises prior 

to treatment. 

Remove or carefully protect food products and 

food packaging. 

Do not allow children or pets on trated areas 

until surfaces have dried. 

SC/L 2.72E04 lb/1K cu.ft 

SC/L 0.0457 lb/1K sq.ft 

EATING ESTABLISHMENTS 

NON-FOOD AREAS (NONFOOD 

CONTACT) 

SC/L 0.0366 lb/1 gal 

PRL NS 

Remove food and animals from premises prior 

to treatment. 

Remove or carefully protect food products and 

food packaging. 

Do not allow children or pets on trated areas 

until surfaces have dried. 

14 day MRI. 

FOREST TREES (SOFTWOODS -

CONIFERS) 

WP 0.2 lb/A 5 day MRI. 

12 hour REI. 

30 day REI for Conifer Cone Seed Harvesting 

only. 

EC 1.047 lb/A 

0.02 lb/tree 

A-15
Site Form 

Code 

Max.App 

Rate/App 

Unit 

(ai) Use Pattern/Limitations 

0.016 lb/1K trees 

For use only in Alabama, Arkansas, Georgia, 

Lousianna, North Carolina, South Carolina, 

Tennassee, Texas, and Virginia (SLN 

Registrations). 

1 day MRI. 

12 hour REI. 

30 day REI for Conifer Cone Seed Harvesting 

only. 

EC 0.1992 lb/minute 

0.0974 lb/A 

GOLF COURSE TURF 

SC/L 

0.0175 lb/1 gal 

SC/L* 

RTU 0.0974 lb/A 

GREENHOUSE-EMPTY EC 0.7805 lb/1K sq.ft 

Remove food and animals from premises prior 

to treatment. 

Do not allow children or pets on trated areas 

until surfaces have dried. 

D 2 oz/animal Do not treat more than once every three days. 

RTU 6.52E04 lb/Animal 1 day MRI. 

SC/L 0.0366 lb/1 gal 

SC/L* 

RTU 0.0098 lb/1K sq.ft 

HORSES 

(SHOW/RACE/SPECIAL/PONIES) 

WP 

0.1212 bag 1K sq.ft 

14 day MRI. 

12 hour REI 

0.0455 lb/1K sq.ft 

7.69E04 lb/1K cu.ft For use only in New Mexico (SLN 

Registration). 

0.1068 14 day MRI. lb/1K sq.ft 

EC 0.0021 lb/Animal 

0.0268 lb/unit 

0.1727 lb/1 gal 

5 days preslaughter interval. 

Do not treat animals under 12 weeks of age. 

HOSPITALS/MEDICAL 

INSTITUTIONS PREMISES 

6.18E04 lb/1K cu.ft For use only in New Mexico (SLN 

Registration). 

Remove food and animals from premises prior 

to treatment. 

Remove or carefully protect food products and 

food packaging. 

Remove feed and water prior to treatment. 

(HUMAN/VETERINARY) 

EC 0.4604 lb/1K sq.ft 

0.08 lb/1 gal Remove food and animals from premises prior 

to treatment. 

Remove feed or carefully protect food 

products and food packaging. 

Do not allow children or pets on treated areas 

until surfaces have dried. 

EC*RTU 0.0488 lb/1K sq.ft 

SC/L 

2.72E04 lb/1K cu.ft 

0.0457 lb/1K sq.ft 

0.0366 lb/1 gal 

A-16
Site Form 

Code 

Max.App 

Rate/App 

Unit 

(ai) Use Pattern/Limitations 

SC/L* 

RTU 0.0098 lb/1K sq.ft 

PRL NS 

Remove food and animals from premises prior 

to treatment. 

Do not allow children or pets on treated areas 

until surfaces have dried. 

14 day MRI. 

HOUSEHOLD/DOMESTIC 

DWELLINGS CONTENTS 

EC 0.7805 lb/1K sq.ft 

Remove food and animals from premises prior 

to treatment. 

Remove feed or carefully protect food 

products and food packaging. 

Do not allow children or pets on treated areas 

until surfaces have dried. 

RTU NS 

PRL NS 

Do not allow children or pets on treated areas 

until surfaces have dried. 

Do not enter treated areas without protective 

clothing until spray has dried. 

14 day MRI. 

EC 0.7805 lb/1K sq.ft Remove food and animals from premises prior 

to treatment. 

Remove feed or carefully protect food 

products and food packaging. 

Do not allow children or pets on treated areas 

until surfaces have dried. 

RTU NS 

2.72E04 lb/1K cu.ft 

HOUSEHOLD/DOMESTIC 

DWELLINGS INDOOR 

SC/L 0.0457 lb/1K sq.ft 

0.0366 lb/1 gal 

PREMISES 

PRL NS 

Do not allow children or pets on treated areas 

until surfaces have dried. 

Do not enter treated areas without protective 

clothing until spray has dried. 

14 day MRI. 

HOUSEHOLD/DOMESTIC 

DWELLINGS OUTDOOR 

PREMISES 

EC 

0.7805 lb/1K sq.ft 

Remove food and animals from premises prior 

to treatment. 

Remove feed or carefully protect food 

products and food packaging. 

Do not allow children or pets on treated areas 

until surfaces have dried. 

0.0076 lb linear ft Remove food and animals from premises prior 

to treatment. 

Remove feed or carefully protect food 

products and food packaging. 

Do not allow children or pets on treated areas 

until surfaces have dried. 

0.042 lb min 

0.1561 lb/mound 

0.04 lb/1 gal 

1 part (L) 

0.2422 lb/A Disallowed in FL. 

RTU NS 

RTU 0.1 lb/A Remove food and animals from premises prior 

A-17
Site Form 

Code 

Max.App 

Rate/App 

Unit 

(ai) Use Pattern/Limitations 

1.56E04 gal mound to treatment. 

Remove feed or carefully protect food 

products and food packaging. 

Do not allow children or pets on treated areas 

until surfaces have dried. 

G 0.005 lb/1K sq.ft 

0.0038 Tsp ant hill 

0.0554 lb/1K sq.ft 

RTU 5.57E05 lb ft 

0.0974 lb/A SC/L 

0.0175 lb/1 gal 

SC/L* 

RTU 0.0974 lb/A 

EC 0.4604 lb/1K sq.ft Remove or carefully protect food products and 

food packaging. 

Remove animals prior to treatment. 

Do not allow children or pets on treated areas 

until surfaces are dry. 

HUMAN BEDDING/MATTRESSES 

RTU NS 

HUMAN CAMPING EQUIPMENT PRL NS 

Do not enter treated areas without protective 

clothing until sprays have dried. 

14 day MRI. 

HUMAN CLOTHING (INSECT 

AND MOLD/MILDEW CONTROL) 

PRL 

NS 

Do not enter treated areas without protective 

clothing until sprays have dried. 

14 day MRI. 

60 sec (L) 14 day MRI. 

RTU NS 

MEAT PROCESSING PLANT 

PREMISES (NONFOOD 

CONTACT) 

EC 0.0035 lb/1K sq.ft 

For use only in New Mexico (SLN 

Registration). 

Remove animals prior to treatment. 

Cover feed and water prior to treatment. 

14 day MRI. 

EC*RTU 0.0488 lb/1K sq.ft Remove animals prior to treatment. 

MEAT PROCESSING PLANT 

PREMISES (NONFOOD 

CONTACT) 

SC/L 2.72E04 lb/1K cu.ft 

SC/L 0.0457 lb/1K sq.ft 

SC/L 0.0366 lb/1 gal 

SC/L* 

RTU 0.0098 lb/1K sq.ft 

MORGUES/MORTUARIES/AUTO 

PSY/EMBALMING ROOM 

PREMISES 

PRL NS 

Do not allow children or pets on treated areas 

until surfaces are dry. 

120 MRI. 

MUSHROOM HOUSES-EMPTY 

PREMISES/EQUIPMENT 

D 0.0017 lb/1K cu.ft 3 day PHI. 

1 day MRI. 

24 hour REI. FM/S Maximum of 30 applications per crop cycle. 

2.18E04 gal 1K cu.ft 

A-18
Site Form 

Code 

Max.App 

Rate/App 

Unit 

(ai) Use Pattern/Limitations 

EC 0.0019 lb/1K cu.ft 

12 hour REI. 

Maximum of 30 application per crop cycle. 

0.375 lb/A 3 day PHI. 

12 hour REI. 

WP 0.0057 gal 1K sq.ft Maximum of 30 application per crop cycle. 

0.0455 lb/1K sq.ft 

NONAGRICULTURAL AREAS 

(PUBLIC HEALTH USE) 

SC/L 0.0974 lb/A 

SC/L* 

RTU 0.0974 lb/A 

0.85 lb/A Do not allow children or pets in treated area 

until sprays have dried. 

12 hour REI. EC 

0.04 lb/1 gal 

NONAGRICULTURAL OUTDOOR 

BUILDINGS/STRUCTURES 

0.7805 lb/1K sq.ft Remove food and animals from premises prior 

to treatment. 

Remove or carefully protect food products and 

packaging. 

Do not allow children or pets in treated area 

until surfaces are dry. 

0.1561 lb/mound 

SC/L 0.0974 lb/A 

SC/L* 

RTU 0.0974 lb/A 

NONAGRICULTURAL RIGHTSOFWAY/FENCEROWS/HEDGEROW 

S 

0.85 lb/A 

Do not allow children or pets in treated area 

until surfaces are dry. 

12 hours REI. 

NONAGRICULTURAL RIGHTSOFWAY/FENCEROWS/HEDGEROW 

S EC 

0.04 lb/1 gal 

NONAGRICULTURAL RIGHTSOFWAY/FENCEROWS/HEDGEROW 

S 

0.7805 lb/1K sq.ft 

Remove food and animals from premises prior 

to treatment. 

Remove animals prior to treatment. 

Do not allow children or pets in treated area 

NONAGRICULTURAL RIGHTS- until surfaces are dry. 

OFWAY/FENCEROWS/HEDGEROW 

S 

0.1561 lb/mound 

0.85 lb/A Do not allow children or pets in treated area 

until surfaces are dry. 

12 hours REI. 

NONAGRICULTURAL 

UNCULTIVATED AREAS/SOILS 

EC 

0.3951 lb/1K sq.ft 

0.0801 lb/mound 

0.04 lb/1 gal 

RTU 

0.0316 lb min 

0.0053 lb/A Disallowed in Florida. 

ORNAMENTAL AND/OR SHADE 

TREES 

D NS 

WP 

0.0195 lb/10 gal Do not apply through any type of irrigation 

system. 

0.2 lb/100 gal 12 hour REI. 

0.2 lb/A Disallowed in California. 

12 hour REI. EC 0.2 lb/A 

EC 0.7805 lb/1K sq.ft See below. 

A-19
Site Form 

Code 

Max.App 

Rate/App 

Unit 

(ai) Use Pattern/Limitations 

0.0319 lb lin. ft/ft 

depth 

Remove food and animals from premises prior 

to treatment. 

Remove animals prior to treatment. 

Do not allow children or pets in treated area 

until surfaces are dry. 

0.1992 lb minute 

EC 

0.1561 lb/mound 

4.28 lb/tree 

0.08 lb/1 gal 

0.02 lb/10 gal 

4.28 lb/100 gal 

PRL NS 

RTU NS 

0.0195 lb/10 gal Do not apply through any type of irrigation 

system. 

WP 0.5 lb/100 gal 

Disallowed in California. 

12 hour REI. 

7 day MRI. 

0.2 lb/A For use in California and Florida. 

12 hour REI. 

ORNAMENTAL HERBACEOUS 

PLANTS 

0.2 lb/A 

For use only in Florida. 

Disallowed in California. 

Do not allow children or pets in treated area 

until surfaces are dry. 

12 hour REI. 

EC 

0.7805 lb/1K sq.ft Remove food and animals from premises prior 

to treatment. Remove animals prior to 

treatment. 

Do not allow children or pets in treated area 

until surfaces are dry. 

0.1992 lb minute 

0.1561 lb/mound 

0.0355 lb/1 gal 

0.02 lb/10 gal 

0.5 lb/100 gal 

PRL 

NS 

RTU 

0.7805 lb/1K sq.ft Remove food and animals from premises prior 

to treatment. Remove animals prior to 

treatment. 

Do not allow children or pets in treated area 

until surfaces are dry. 

EC 

0.0319 lb lin. ft/ft 

depth 

0.1561 lb/mound 

ORNAMENTAL LAWNS AND 0.08 lb/1 gal 

TURF 1.56E04 gal mound 

G 0.0075 lb/1K sq.ft 

0.0038 Tsp ant hill 

ORNAMENTAL 

NONFLOWERING PLANTS 

EC 0.2 lb/A 

For use in Florida. 

Disallowed in California. 

Do not allow chilren or pets in treated area 

until surfaces are dry. 

12 hour REI. 

A-20
Site Form 

Code 

Max.App 

Rate/App 

Unit 

(ai) Use Pattern/Limitations 

0.2 lb/100 gal 12 hour REI. 

0.7805 lb/1K sq.ft Remove food and animals from premises prior 

to treatment. Remove animals prior to 

treatment. 

Do not allow children or pets in treated area 

until surfaces are dry. 

0.1992 lb/minute 

0.1561 lb/mound 

0.0355 lb/1 gal 

0.02 lb/10 gal 

RTU NS 

0.1 lb/A 12 hour REI. 

WP 0.2 lb/100 gal 

0.0195 lb/10 gal Do not apply through any type of irrigation 

system. 

PRL NS 

PRL 

NS 

RTU Remove food and animals from premises prior 

to treatment. 

Remove animals prior to treatment. 

Do not allow children or pets in treated area 

until surfaces are dry. 

0.7805 lb/1K sq.ft 

0.0319 lb lin. ft/ft 

depth 

0.1992 lb minute 

0.1561 lb/mound 

ORNAMENTAL WOODY SHRUBS 

AND VINES 

EC 0.08 lb/1 gal 

0.02 lb/10 gal 

0.25 lb/A 

Disallowed in California. 

Do not allow children or pets in treated area 

until surfaces are dry. 

0.2 lb/100 gal Disallowed in California. 

12 hour REI. 0.5 lb/A 

WP 0.2 lb/100 gal 

0.0195 lb/10 gal Do not apply through any type of irrigation 

system. 

0.0523 lb/1K sq.ft Remove food and animals from premises prior 

to treatment. 

Remove animals prior to treatment. 

Do not allow children or pets in treated area 

until surfaces are dry. 

PATHS/PATIOS 

EC 2.72E05 lb linear ft 

1 part (L) 

RTU 5.57E05 lb ft 

D NS Remove food and animals from premises prior 

to treatment. 

Remove animals prior to treatment. 

Do not allow children or pets in treated area 

until surfaces are dry. 

PET LIVING/SLEEPING EC 0.7805 lb/1K sq.ft 

QUARTERS PRL NS 

RTU NS 

A-21
PINE (FOREST/SHELTERBELT) EC 

1.047 lb/A Do not allow children or pets in treated area 

until surfaces are dry. 

0.02 12 hours REI. lb/tree 

1.05 lb/A Do not allow children or pets in treated area 

until surfaces are dry. 

12 hours REI. 

Maximum of 6 applications per crop cycle. 

PINE (SEED ORCHARD) 

EC 

0.02 lb/tree 

1.6 lb/A 28 day MRI. 

12 hour REI. 

Maximum of 6 applications per crop cycle. WP 

1.6 lb/tree 

POME FRUITS WP 0.2 lb/100 gal 12 hour REI. 

POULTRY PROCESSING PLANT 

PREMISES (NONFOOD 

CONTACT) 

EC 

3.27E04 lb/1K cu.ft For use only in New Mexico (SLN 

Registration). 14 

0.0139 day MRI. lb/1K sq.ft 

EC*RTU 0.0488 lb/1K sq.ft 

Do not allow children or pets in treated area 

until surfaces are dry. 

RECREATION AREA LAWNS EC 2.47E04 lb/1K sq.ft 12 hour REI. 

0.7805 lb/1K sq.ft Remove food and aminals from premises prior 

to treatment. Remove or carefully 

protect food products and food packaging. 

Do not allow children or pets in treated area 

until surfaces are dry. 

0.1953 lb min 

EC 0.1561 lb/mound 

1 part (L) 

2.422 lb/A 

0.1341 lb minute 

0.1 lb/A Disallowed in Florida. 

RTU 

NS 

RECREATIONAL AREAS 0.0077 lb/A 

0.0422 lb min 

0.0464 lb minute 

0.0974 lb/A 

SC/L 0.0175 lb/1 gal 

Do not allow children or pets in treated area 

until surfaces are dry. 

0.0011 part A For use only in Utah (SLN Registration). 

SC/L* 0.0974 lb/A 

RTU 0.1406 lb minute 

REFUSE/SOLID WASTE 

CONTAINERS (GARBAGE CANS) PRL NS 

REFUSE/SOLID WASTE SITES 

(INDOOR) EC 0.7805 lb/1K sq.ft 

Remove food and aminals from premises prior 

to treatment. Remove or carefully 

protect food products and food packaging. 

Do not allow children or pets in treated area 

until surfaces are dry. 

12 hour REI. 

REFUSE/SOLID WASTE SITES 

(OUTDOOR) EC 0.85 lb/A 

REFUSE/SOLID WASTE SITES 

(OUTDOOR) EC 0.3951 lb/1K sq.ft 

REFUSE/SOLID WASTE SITES 

(OUTDOOR) EC 0.04 lb/1 gal 

A-22
RESIDENTIAL LAWNS EC 2.47E04 lb/1K sq.ft 

Do not allow children or pets in treated area 

until surfaces are dry. 

EC 6.18E04 lb/1K cu.ft 

EC 0.0021 lb/Animal 

EC 1.65E04 lb ear 

SHEEP EC 0.1068 lb/10 gal 

SC/L* 

RTU 0.0098 lb/1K sq.ft 

SC/L* 

RTU 0.0017 lb/Animal 14 day MRI. 

SC/L 0.0089 lb/1 gal 

EC 0.1992 lb minute 

Do not treat animals under 12 weeks of age. 

1 day MRI. 

PRL NS 14 day MRI. 

SPECIALIZED ANIMALS 0.0974 lb/A SC/L 

0.0175 lb/1 gal 

SC/L* 

RTU 0.0974 lb/A 

2.422 lb/A 

EC 

0.1953 lb min 

0.1992 lb minute 

NS 

EC*RTU 0.1341 lb minute 

0.1 lb/A Disallowed in Florida. 

URBAN AREAS 

RTU 

0.0077 lb/A 

0.0422 lb min 

0.0464 lb minute 

0.0974 lb/A 

SC/L 0.0175 lb/1 gal 

0.0011 part A For use only in Utah (SLN Registration). 

SC/L* 0.0974 lb/A UT-a FL-d 

RTU 0.1406 lb minute 

2.422 lb/A 

EC 0.1953 lb min 

1 part (L) 

EC*RTU 0.1 lb/A Disallowed in Florida. 

WIDE AREA/GENERAL 

OUTDOOR TREATMENT 

(PUBLIC HEALTH USE) 

0.1341 lb minute 

RTU 

0.0077 lb/A Disallowed in Florida. 

0.0422 lb min 

0.0464 lb minute 

SC/L 0.0011 part A For use only in Utah (SLN Registration). 

SC/L* 

RTU 

0.0234 lb/A For use only in Utah (SLN Registration). 

0.1406 lb minute 

A-23
WOOD PRESSURE TREATMENT 

TO FOREST PRODUCTS EC 3.2 lb/40 gal 

12 hour REI. 

WOOD PROTECTION 

TREATMENT TO 

BUILDINGS/PRODUCTS INDOOR 

EC 0.7805 lb/1K sq.ft 

Remove food and animals from premises prior 

to treatment. 

Do not allow children or pets on treated areas 

until surface has dried. 

WOOD PROTECTION 

TREATMENT TO 

BUILDINGS/PRODUCTS 

OUTDOOR 

EC 

0.1 lb/1K sq.ft Remove food and animals from premises prior 

to treatment. 

Do not allow children or pets on treated areas 

until surface has dried. 

0.0319 lb lin. ft/ft 

depth 

0.08 lb/1 gal 

0.0324 lb linear ft For use only in Mississippi (SLN 

Registration). 

Do not allow children or pets on treated areas 

until surface has dried. 

0.0081 lb sq.ft 

3.2 fl.oz (L) 

WOOD PROTECTION 

TREATMENT TO FOREST 

PRODUCTS (SEASONED) 

EC 0.0379 lb/1 gal 

Do not allow children or pets on treated areas 

until surface has dried. 

WOOD PROTECTION 

TREATMENT TO FOREST 

PRODUCTS (UNSEASONED) 

EC 

3.2 lb/A Remove food or animals from premises prior 

to treatment. 

Do not allow children or pets on treated areas 

until surface has dried. 

0.7805 lb/1K sq.ft 

0.1561 lb/mound 

3.2 lb/40 gal 

NS- The use rate is not specified because product is labeled as a spot treatment. 

A-24
Appendix B 

GUIDE TO APPENDIX B 

Appendix B contains listings of data requirements which support the reregistration for active 

ingredients within the case 2510 covered by this Reregistration Eligibility Decision Document. 

It contains generic data requirements that apply to 2510 in all products, including data 

requirements for which a "typical formulation" is the test substance. 

The data table is organized in the following format: 

1. Data Requirement (Column 1). The data requirements are listed in the order in which 

they appear in 40 CFR Part 158. The reference numbers accompanying each test refer to the test 

protocols set in the Pesticide Assessment Guidelines, which are available from the National 

Technical Information Service, 5285 Port Royal Road, Springfield, VA 22161 (703) 487-4650. 

2. Use Pattern (Column 2). This column indicates the use patterns for which the data 

requirements apply. The following letter designations are used for the given use patterns: 

A Terrestrial food 

B Terrestrial feed 

C Terrestrial non-food 

D Aquatic food 

E Aquatic non-food outdoor 

F Aquatic non-food industrial 

G Aquatic non-food residential 

H Greenhouse food 

I Greenhouse non-food 

J Forestry

 K Residential

 L Indoor food 

M Indoor non-food 

N Indoor medical 

O Indoor residential 

3. Bibliographic citation (Column 3). If the Agency has acceptable data in its files, this 

column lists the identifying number of each study. This normally is the Master Record 

Identification (MRID) number, but may be a "GS" number if no MRID number has been 

assigned. Refer to the Bibliography appendix for a complete citation of the study. 

B-1 
Data Supporting FIFRA Guideline Requirements for the Reregistration of Permethrin 

Guideline Requirement 

MRID Citatio

Guideline Number 

New Old Study Title 

PRODUCT CHEMISTRY 

830.1550 61-1 Chemical Identity & Composition 44994001, 44707101, 4484830.1600 830.1620 61-2A Starting Material & Manufacturing Process 44994001, 40943601, 44707101, 830.1670 61-2B Formation of Impurities 44994001, 40943601, 44707101, 830.1700 62-1 Preliminary Analysis 44812001, 41136401, 44707101, 830.1750 62_2 Certification of limits 44994001, 41136401, 44707101, 4484830.1800 62_3 Enforcement Analytical Method 44812001, 41136401, 44707101, 830.6302 63-2 Color 44994002, 42377601, 44707201, 830.6303 63-3 Physical State 44994002, 42377601, 44707201, 830.6304 63-4 Odor 44994002, 42377601, 44707201, 830.7050 UV/Visible Absorption 44994002, 44707201, 830.7200 63-5 Melting Point 44994002, 42377601, 44707201, 830.7220 63-6 Boiling Point 42377601, 44707201, 44841202, 830.7300 63-7 Density 44994002, 42377601, 44707201, 830.7840 830.7860 63-8 Solubility 44994002, 45095801, 42109801, 830.7950 63-9 Vapor Pressure 45095801, 42109801, 44707830.7370 63-10 Dissociation Constant 45095801, 4484830.7550 63-11 Octanol/Water Partition Coefficient 44994002, 42109801, 43651601, 44707

B-1 
Guideline Requirement 

MRID Citatio

Guideline Number 

New Old Study Title 

830.7000 63-12 pH 44994002, 43164801, 44707201, 830.6313 63-13 Stability 44994002, 42377601, 43651601, 44707201, 

ECOLOGICAL EFFECTS 

850.1735 73-1 

Whole sediment: acute freshwater 

invertebrates Data Gap 

850.1735 73-1 Whole sediment: acute marine invertebrates Data Gap 850.1740 74-1 

Whole sediment: chronic freshwater 

invertebrates Data Gap 

850.1740 74-1 

Whole sediment: chronic marine 

invertebrates Data Gap 

850.2100 71-1 Avian Acute Oral Toxicity - Quail 41888402 850.2200 71-2A Avian Dietary Toxicity – Quail 41888403 850.2200 71-2B Avian Dietary Toxicity – Duck 41888401 850.2300 71_4A Avian Reproduction - Quail 42322902 850.2300 71_4B Avian Reproduction – Duck 42322902 850.1075 72-1A Fish Toxicity Bluegill 40098001 850.1075 72-1B Fish Toxicity Sheepshead Minnow 42277001 850.1075 72-1D Fish Toxicity Rainbow Trout- TEP 43740601 850.1010 72-2A Acute Aquatic Invertebrate Toxicity 40098001, 00110850.1010 72-2B Invertebrate Toxicity- TEP 42277004, 43740602, 

 72-3A Acute Estuarine/Marine Tox Fish (Active) 40228401 72-3B Acute Estuarine/Marine Mollusk (Active) 00042140 

B-2 
Guideline Requirement 

MRID Citatio

Guideline Number 

New Old Study Title 

 72-3C Acute Estuarine/Marine Shrimp (Active) 40228401 

None 72-3D Estuarine/Marine Toxicity Fish – TEP 43394601 None 72-3E Estuarine/Marine Toxicity Mollusk – TEP 42723301 None 72-3F Estuarine/Marine Toxicity Shrimp – TEP 00110661 

850.1400 72-4A Fish Early Life Stage Hansen et al., 1

 72-4B Life Cycle Aquatic Invertebrate 43745701, 41315

850.1500 72-5 Fish Lifecycle Toxicity 00110666 850.3020 141-1 Honey Bee, acute contact 42674501

 141-2 Honey Bee Residue on Foliage 42009301 

TOXICOLOGY 

870.1100 81-1 Acute Oral Toxicity-Rat 242899 870.1200 81-2 Acute Dermal Toxicity-Rabbit/Rat 242899 870.1300 81-3 Acute inhalation toxicity Data Gap 870.2400 81-4 Primary Eye Irritation-Rabbit 242899 870.2500 81-5 Primary Skin Irritation 242899 870.2600 81-6 Dermal Sensitization 

EPA Memorandum, June 13, 1995, “Perm

dermal sensitization study (guinea pig maxi

dermal penetration 

870.6200 81-8-SS Acute Neurotoxicity Study – Rat 43046301, 45657870.3100 82-1A 90-Day Feeding – Rodent 92142123 870.3150 82-1B 90-Day Feeding - Non-rodent (Dog) 92142123 870.3200 82-2 21-Day Dermal - Rabbit/Rat 41143801, 42653

B-3 
Guideline Requirement 

MRID Citatio

Guideline Number 

New Old Study Title 

870.4100 83-1A Chronic Feeding Toxicity – Rodent 92142123 870.4100 83-1B 

Chronic Feeding Toxicity ­

Non-Rodent 00129600 

870.4200 83-2A Oncogenicity – Rat See 870.4100 870.4200 83-2B Oncogenicity – Mouse 00102110, 92142032, 00062870.3700 83-3A Developmental Toxicity – Rat 40943603 870.3700 83-3B Developmental Toxicity – Rabbit 92142091, 40943602, 870.3800 83-4 2-Generation Reproduction – Rat 00102108, 00120271, 92142870.5100 84-2 Gene Mutation 41031107 870.5395 84-2 

In Vivo Mammalian Cytogenetics Tests: 

Erythrocyte Micronucleus Assay 42723302 

870.5550 84-2 Other Genotoxic Effects 40943604 870.7485 85-1 General Metabolism – Rat 00089006, 00054719, 92142041, 92142870.7485 85-1 General Metabolism – Dog 0054721, 00042870.6200 82-7 Subchronic Neurotoxicity Screening Battery 40766807 870.6300 83-6 Developmental Neurotoxicity Study Data Gap 870.7600 85-3 Dermal Absorption in Rats 43169001 

OCCUPATIONAL/RESIDENTIAL EXPOSURE 

B-4 
Guideline Requirement 

MRID Citatio

Guideline Number 

New Old Study Title 

875.1100 231 Dermal Exposure – Outdoor 

ORETF Data 

PHED v. 1.1 D

See Appendix D for Chemica

875.1200 232 Inhalation Exposure – Outdoor 875.1200 233 Dermal Exposure- Indoor 875.1400 234 Inhalation Exposure- Indoor 875.2100 132-1A Foliar Residue Dissipation

 875.2200 132-1B Soil Residue Dissipation 

875.2400 133-3 Dermal Passive Dosimetry Exposure 875.2500 133-4 Inhalation Passive Dosimetry Exposure 875.2500 133-4 Inhalation Passive Dosimetry Exposure 

None 231 

Estimation of Dermal Exposure at Outdoor 

Sites 

None 232 

Estimation of Inhalation Exposure at 

Outdoor Sites 

ENVIRONMENTAL FATE 

835.2120 161-1 Hydrolysis 102043, 11293835.2240 161-2 Photodegradation - Water 40242801 835.2410 161-3 Photodegradation - Soil 40190101 835.4100 162-1 Aerobic Soil Metabolism 41970602, 42410835.4200 162-2 Anaerobic Soil Metabolism 41970601 835.4400 162-3 Anaerobic Aquatic Metabolism 43982001 835.4300 162-4 Aerobic Aquatic Metabolism 43938201 835.1240 163-1 Leaching/Adsorption/Desorption 41868001, 45170102, 43424

B-5 
Guideline Requirement 

MRID Citatio

Guideline Number 

New Old Study Title 

835.6100 164-1 Terrestrial Field Dissipation 42359101 835.1200 164.2 Aquatic Field Dissipation 44030501, 44157

None 165-4 Bioaccumulation in Fish 41300401, 41300402, 

RESIDUE CHEMISTRY 

860.1200 171-3 Directions for Use 860.1300 171-4A Nature of Residue - Plants 00025919, 00025920, 00094393, 00094394, 860.1300 171-4B Nature of Residue - Livestock 

42196702, 42196703, 42410001, 42503

43505201, 43713301, 43713302, 43713

44196101, 44196102, 

860.1340 171-4C Residue Analytical Method - Plants 

00043877, 00054724, 00072582, 00160

40446404, 40556804, 41641001, 4213

860.1340 171-4D Residue Analytical Method - Animals 

00064675, 00064678, 00070916, 43962

44417802 

860.1380 171-4E Storage Stability Data 

00102107, 00110622, 00137902, 00165

43494701, 43505201, 

860.1480 171-4J 

Magnitude of Residues ­

Meat/Milk/Poultry/Egg 

00054723, 00064674, 00064676, 00064679, 

00064684, 00064685, 00064686, 00070914, 

00079386, 00079387, 00110

860.1850 Confined Accumulation in Rotational Crops 43174401 860.1900 Field Accumulation in Rotational Crops 44428201, 44428202, 

Crop Field Trials – Root and Tuber Vegetable Group 

B-6 
Guideline Requirement 

MRID Citatio

Guideline Number 

New Old Study Title 

860.1500 171-4K Crop field trial- horseradish 00035517, 41565860.1500 171-4K Crop field trial- potatoes 00025985, 00025986, 00081578, 00081860.1500 171-4K Crop field trial- turnip roots 00155947, 4157

Crop Field Trials – Leafy Vegetables (Except Brassica) Group 

860.1500 171-4K Crop field trial- cabbage 

00034779, 00080054, 00080055, 00080057, 

41065802 

860.1500 171-4K Crop field trial- celery 00025921, 00081628, 00102082, 860.1500 171-4K Crop field trial- lettuce, leaf 00034780, 00034781, 00110622, 00139530, 860.1500 171-4K Crop field trial- spinach 00150293, 41065808, 42431401, 860.1500 171-4K Crop field trial- turnip greens 00155947, 41575

Crop Field Trials – Bulb Vegetables 

860.1500 171-4K Crop field trial- onions 40404001 

Crop Field Trials – Brassica (Cole) Leafy Vegetables 

860.1500 171-4K Crop field trial- broccoli 00034774, 00034778, 00080054, 860.1500 171-4K Crop field trial- Brussels Sprouts 00034775, 00080860.1500 171-4K Crop field trial- cauliflower 00034776, 00080054, 860.1500 171-4K Crop field trial- collards 0015029, 00155947, 

Crop Field Trials –Legume Vegetables (Succulent or Dry) 

860.1500 171-4K Crop field trial- soybeans 

00026542 00026548 00057091 00110622 

00155947 00165525 

Crop Field Trials –Fruiting Vegetables 

860.1500 171-4K Crop field trial- eggplant 00129296, 41565

B-7 
Guideline Requirement 

MRID Citatio

Guideline Number 

New Old Study Title 

860.1500 171-4K Crop field trial- pepper 00129296, 41565403, 860.1500 171-4K Crop field trial- tomato 00026543, 00026546, 00034785, 00110622, 

Crop Field Trials – Cucurbit Vegetables 

860.1500 171-4K Crop field trial- vegetable, cucurbit group 

00126691, 00151251, 00155167, 40556801, 4

41565405, 44182701, 

Crop Field Trials – Pome Fruits 

860.1500 171-4K Crop field trial- apple 4283810 860.1500 171-4K Crop field trial- pear 00042620, 00042621, 00083

Crop Field Trials – Stone Fruit 

860.1500 171-4K Crop field trial- cherry 41065803, 44135860.1500 171-4K Crop field trial- peach 00118504, 4334

Crop Field Trials – Trees Nuts 

860.1500 171-4K Crop field trial- almond 00100520, 00110564, 42322860.1500 171-4K Crop field trial- almond, hull 00100520, 00110564, 42322860.1500 171-4K Crop field trial- filbert 00142263 860.1500 171-4K Crop field trial- walnut 00072833, 42322

Crop Field Trials – Cereal Grains 

860.1500 171-4K Crop field trial- Corn (field and pop) 00069651, 00069652, 00088973, 41065804, 860.1500 171-4K 

Corn, sweet (kernel, plus cob with husks 

removed) 

00034777, 00034778, 41052

Crop Field Trials - Forage, Fodder, and Straw of Cereal Grains 

860.1500 171-4K Corn (Forage and Fodder) 00069651, 00069652, 00080047, 43149501, 

B-8 
Guideline Requirement 

MRID Citatio

Guideline Number 

New Old Study Title 

Crop Field Trials – Grass, Forage, Fodder, and Hay 

860.1500 171-4K Crop field trial- grass range 00128728, 41565

Crop Field Trials – Non-Grass Animal Feed Group 

860.1500 171-4K Crop field trial- alfalfa, fresh 

00025992, 00026551, 00026552, 00047632, 0

40072401, 42909001, 

860.1500 171-4K Crop field trial- alfalfa, hay 00047634, 00047635, 00151832, 40072

Crop Field Trials – Misc. Commodities 

860.1500 171-4K Crop field trial- artichoke 00145266, 42137860.1500 171-4K Crop field trial- asparagus 40446401, 40446860.1500 171-4K Crop field trial- avocado 00144307, 41565401, 860.1500 171-4K Crop field trial- cottonseed 

00043877, 00043879, 00043883, 00054888, 0

00102107, 00109336, 00110610, 00110622, 

00155947 

860.1500 171-4K Crop field trial- mushroom 00165524 860.1500 171-4K Crop field trial- papaya 00144307, 41565401, 860.1500 171-4K Crop field trial- pistachios 00133293, 41065805, 860.1500 171-4K Crop field trial- watercress 00145971 

Processed Food/Feed Studies 

860.1520 171-4I Processed foods/feed – apple 42824702 860.1520 171-4I Processed foods/feed – corn 42860601, 42910101, 860.1520 171-4I Processed foods/feed – cottonseed 00044517 860.1520 171-4I Processed foods/feed – Potato 42824701 

B-9 
Guideline Requirement 

MRID Citatio

Guideline Number 

New Old Study Title 

860.1520 171-4I Processed foods/feed – soybean 00070912, 43364860.1520 171-4I Processed foods/feed- tomato 41404301 

B-10 
Appendix C 

TECHNICAL SUPPORT DOCUMENTS 

Additional documentation in support of this RED is maintained in the OPP docket, 

located in Room S-4400, One Potomac Yard (South Building), 1777 S. Crystal Drive, Arlington, 

VA. It is open Monday through Friday, excluding legal holidays, from 8:30 am to 4 pm. 

The preliminary risk assessments for permethrin are available in the public docket and in 

e-dockets under docket number OPP-2004-0385. This contains risk assessments and related 

documents as of August 2005. During the comment period, the registrant submitted additional 

data for permethrin. EPA reviewed these data and incorporated them into the revised risk 

assessments for permethrin. These revised risk assessments form the basis of the regulatory 

decision described in this RED. These risk assessment and related documents are available 

under docket number OPP-2004-0385. 

Technical support documents for the Permethrin RED include the following: 

Human Health Risk Assessment Documents; 

1. Permethrin. Fifth Revision of the HED Chapter of the Reregistration Eligibility 

Decision Document (RED), dated April 4, 2006; 

2. Permethrin. Second Revised Acute, Chronic, and Cancer Dietary Exposure 

Assessments for the Reregistration Eligibility Decision (RED) Document, dated 

February 1, 2006; 

3. Permethrin. Revised Residue Chemistry Chapter of the Reregistration Eligibility 

Decision, dated March 17, 2005; 

4. Permethrin. Third Revision of the Occupational and Residential Exposure 

Assessment for the Reregistration Eligibility Decision Document, dated April 4, 

2006; 

5. Permethrin: Toxicology Discipline Chapter for the Reregistration Eligibility 

Decision Document (RED), dated December 16, 2003; 

6. Permethrin. Product Chemistry Chapter for the Reregistration Eligibility Decision 

(RED) Document, dated June 4, 2004. 

Environmental Fate and Effects Documents; 

1. The Agency Revised Risk Assessment for the Reregistration Eligibility Decision on 

Permethrin After Public Comments, Phase III, dated April 5, 2006; 

2. Addendum to the EFED Red Chapter for Permethrin, dated April 5, 2006; 

3. Second Revision Tier II Estimated Drinking Water Concentrations of Permethrin, 

dated January 17, 2006. 

And the following documents on use and usage, and biological and economic analysis; 

1. BEAD Review of American Mosquito Control Association Comments and 

Alternative Analysis Regarding the User of Permethrin for Adult Mosquito 

C-1 
Control and Indoor; Outdoor Residential Uses, dated March 14, 2006; 

2. Qualitative Information about the Role of Permethrin in Select Uses to Inform 

Risk-Benefit Decision, dated March 01, 2006. 

C-2 
Appendix D 

Bibilography 

MRID Citation Reference 

00025919 Capps, T.M.; Munger, D.M.; Reynolds, J.L.; et al. (1979) Metabolism of Permethrin in 

Cabbage: M-4130. (Unpublished study received Mar 7, 1980 under 10182-18; prepared by 

FM1978 under 275-18; Mar 7, 1980 under 10182-18; prepared by FMC, submitted by ICI 

Americas, Inc., Wilmington, Del.; CDL:099273-F) 

00025920 Capps; T.M.; Munger, D.M.; Reynolds, J.L.; et al. (1979) Isolation and Structure Elucidation 

of FMC 33297 Metabolites in Cabbage: M 4331. (Unpublished study received Mar 7, 1980 

under 10182 18; prepared by FMC, submitted by ICI Americas, Inc., Wilmington,Del.; 

CDL:099273 G) 

00025921 Ussary, J.P. (1979) Permethrin Metabolite Residues on Celery: Report Series TMU0439/B. 

Including method dated Nov 1978. (Unpublished study received Mar 7, 1980 under 10182 18; 

submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099273 H) 

00025922 Hillhouse, T.L.; Daniel, J.; Sexson, G.D.; et al. (1979) Permethrin Metabolite Residues on 

Soybeans: Report Series TMU0449/B. (Unpublished study received Mar 7, 1980 under 10182 

18; submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099273 I) 

00025985 Ussary, J.P.; Whiteman, C.R.; Sexson, G.D.; et al. (1979) Permethrin Residues on Potatoes: 

Report Series TMU0451/B. (Unpublished study received Feb 18, 1979 under 10182 18; 

submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099148 H) 

00025986 Ussary, J.P.; Ekeh, M.K.; Whiteman, C.R. (1979) Permethrin Metabolite Residues on 

Potatoes: Report Series TMU0458/B. (Unpublished study received Dec 18, 1979 under 10182 

18; submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099148 I) 

00025992 Ussary, J.P.; Haulsee, R.E.; Wilson, D.; et al. (1979) Permethrin Metabolite Residues on 

Alfalfa: Report Series TMU0462/B. (Unpublished study received Dec 18, 1979 under 

10182-18; submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099152-C) 

00026542 Ussary, J.P.; Haulsee, R.E.; Harrison, S.; et al. (1978) Permethrin Residues from Aerial 

Applications to Soybeans: Report Series TMU0454/B. (Unpublished study received Dec 18, 

1979 under 10182 EX 6; submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099145 B) 

00026543 Ussary, J.P.; Haulsee, R.E.; Whiteman, C.R.; et al. (1978) Permethrin Residues on Tomatoes: 

Report Series TMU0435/B. Rev. (Unpublished study received Dec 18, 1979 under 10182 EX 

6; submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099145 C) 

00026546 Ussary, J.P.; Haulsee, R.E.; Gouger, R.J.; et al. (1978) Permethrin Metabolite Residues on 

Tomatoes: Report Series TMU0441/B. (Unpublished study received Dec 18, 1979 under 

10182-EX-6; submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099145 F) 

00026548 Ussary, J.P.; Haulsee, R.E.; Hillhouse, T.L.; et al. (1978) Permethrin Metabolite Residues on 

Soybeans: Report Series TMU0449/ B. (Unpublished study received Dec 18, 1979 under 

10182 EX 6; submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099145 H) 

D-1 
MRID Citation Reference 

00026551 Ussary, J.P.; Anderson, K.; Cammack, M.W.; et al. (1978) Permethrin Residues on Alfalfa: 

TMU0388/B. (Unpublished study received Dec 18, 1979 under 10182 EX 6; submitted by ICI 

Americas, Inc., Wilmington, Del.; CDL:099145 M) 

00026552 Ussary, J.P.; Haulsee, R.E.; Anderson, K.; et al. (1978) Permethrin Metabolite Residues on 

Alfalfa: Report Series TMU0462/B. (Unpublished study received Dec 18, 1979 under 10182 

EX 6; submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099145 N) 

00034774 ICI Americas, Incorporated (1978) Residues in Broccoli. (Unpublished study received Dec 

18, 1979 under 10182 EX 6; CDL: 099144 B) 

00034775 \ICI Americas, Incorporated (1977) Residues in Brussels Sprouts. (Unpublished study 

received Dec 18, 1979 under 10182 EX 6; CDL: 099144 C) 

00034776 ICI Americas, Incorporated (1977) Residues in Cauliflower. (Unpublished study received 

Dec 18, 1979 under 10182 EX 6; CDL: 099144 D) 

00034777 ICI Americas, Incorporated (1978) Residues in Sweet Corn. (Unpublished study received 

Dec 18, 1979 under 10182-EX-6; CDL:099144 E) 

00034778 ICI Americas, Incorporated (19??) Permethrin Metabolite Residues. (Unpublished study 

received Dec 18, 1979 under 10182-EX-6; CDL:099144 F) 

00034779 ICI Americas, Incorporated (1978) Residues in Cabbage. (Unpublished study received Dec 

18, 1979 under 10182-EX-6; CDL:099144-G) 

00034780 ICI Americas, Incorporated (1978) Residues in Lettuce. (Unpublished study received Dec 18, 

1979 under 10182-EX-6; CDL:099144 H) 

00034781 ICI Americas, Incorporated (19??) Permethrin Metabolite Residues. (Unpublished study 

received Dec 18, 1979 under 10182-EX-6; CDL:099144 I) 

00034785 ICI Americas, Incorporated (19??) Permethrin Metabolism Residues in Celery, Tomatoes and 

Soybeans. (Unpublished study received Dec 18, 1979 under 10182 EX 6; CDL:099144 M) 

00035517 Felsot, A.; Wilson, J.; Eastman, C. (1979) Summary: [Ambush]. Includes method dated Dec 

11, 1979 entitled Permethrin Residues in Horseradish: Analytical Methods and Results. 

(Unpublished study received Jun 17, 1980 under 10182 18; prepared in cooperation with 

Illinois, Natural History Survey, Pesticide Residue Laboratory, submitted by ICI Americas, 

Inc., Wilmington,Del.; CDL:099463 A) 

00042140 Thompson, R.S.; Hill, R.W.; Cornish, S.K. (1977) Investigation of the Acute Toxicity of PP 

557 to the Pacific Oyster (Crassostrea gigas?): BL/B/1796. Includes undated method entitled: 

The determination of low levels of PP 557 in seawater samples from bioassay tests. 

(Unpublished study received Aug 22, 1977 under 10182-EX-3; prepared by Imperial 

Chemical Industries, Ltd., submitted by ICI America, Inc., Wilmington, Del.; CDL: 096325­

AC) 

D-2 
MRID Citation Reference 

00042160 Bratt, H.; Slade, M. (1977) Permethrin: Tissue Retention in the Dog: Report No. CTL/P/353. 

(Unpublished study received Aug 22, 1977 under 101823; prepared by Imperial Chemical 

Industries, Ltd., submitted by ICI Americas, Inc., Wilmington, Del.; CDL: 096330_O) 

00042620 Fujie, G.H.; Hidalgo Gato, E.; Johnson, M.; et al. (1980) Determination of Permethrin 

Residues on Pears (Pre bloom Applications): RAN 0005. (Unpublished study received Sep 

24, 1980 under 279 3014; submitted by FMC Corp., Philadelphia, Pa.; CDL:099655 B) 

00042621 Fujie, G.H. (1980) Determination of Permethrin, Dichlorovinyl acid and m Phenoxybenzyl 

alcohol Residues in/on Pears (Pre bloom Applications): RAN 0008. (Unpublished study 

received Sep 24, 1980 under 279 3014; prepared by Analytical Bio Chemistry Laboratories, 

Inc., submitted by FMC Corp., Philadelphia, Pa.; CDL:099655 C) 

00043877 Ussary, J.P. (1976) A Gas Liquid Chromatographic Method for the De termination of 

Permethrin in Oily Crops: Report Series TMUO199/ 76A. (Unpublished study received Aug 

22, 76A. (Unpublished study received Aug 22, 1977 under 10182 EX 3; submitted by ICI 

Americas, Inc., Wilmington, Del.; CDL:096337 D) 

00043879 Ussary, J.P. (1977) Stability of Permethrin Residues in Cottonseed Samples Stored at 20-C: 

Report Series TMU0275/B. (Unpublished study received Aug 22, 1977 under 10182 EX 3; 

submitted by ICI Americas, Inc., Wilmington, DE.; CDL:096337 F) 

00043883 Ussary, J.P.; Koubek; Kramer, J.A., Jr.; et al. (1977) Permethrin Residues in Cottonseed: 

Report Series TMUO195/76B. (Unpublished study including report series TMUO196/76B, 

TMUO197/76B, TMUO210/76B..., received Aug 29, 1977 under 10182 EX 3; submitted by 

ICI Americas, Inc., Wilmington, Del.; CDL:096337 J) 

00044517 Fujie, G.H. (1976) Letter sent to Route List dated Jun 7, 1976: Determination of parent FMC 

33297 residues in cottonseed and cottonseed by products from a cottonseed processing study: 

W 0105. (Unpublished study received 1976 under 6G1769; submitted by FMC Corp., 

Middleport, N.Y.; CDL:095536 E) 

00047632 FMC Corporation (1980) Results of Tests for the Amount of Residue Remaining and a 

Description of the Analytical Methods: [Pounce 3.2EC]. (Unpublished study received Jul 11, 

1980 under 2793014; CDL:099528 A) 

00047634 Fujie, G.H.; Eames, M.A.; Grana, B.; et al. (1980) Determination of Permethrin Residues On 

Alfalfa: W 0247. (Unpublished study received Jul 11, 1980 under 279 3014; submitted by 

FMC Corp., Philadelphia, Pa.; CDL:099528 C) 

00047635 Nelsen, T.R.; Burt, J.E.; Carlin, J.L.; et al. (1980) Determination of Dichlorovinyl acid and M 

Phenoxybenzyl alcohol Residues in/on Green Alfalfa and Alfalfa Hay: M 4457. (Unpublished 

study received Jul 11, 1980 under 279 3014; submitted by FMC Corp., Philadelphia, Pa.; 

CDL:099528 D) 

00054719 Mills, I.H.; Mullane, M. (1976) PP557: Absorption and Excretion in the Rat: Report No. 

CTL/P/228. (Unpublished study received Aug 22, 1977 under 10182-EX-3; submitted by ICI 

Americas, Inc., Wilmington, Del.; CDL:096334D) 

D-3 
MRID Citation Reference 

00054721 Mills, I.H.; Slade, M. (1977) PP557: Absorption, Distribution and Excretion in the Dog: 

Report No. CTL/P/285. Includes undated methods entitled: Measurement of radioactivity and 

Extraction, clean-up and chromatography. (Unpublished study received Dec 5, 1977 under 

10182EX3; prepared by Imperial Chemical Industries, Ltd., submitted by ICI Americas, Inc., 

Wilmington, Del.; CDL: 096334F) 

00054723 Edwards, M.J.; Iswaran, T.J. (1977) Permethrin: Residue Transfer and Toxicology Study with 

Cows Fed Treated Grass Nuts: Report Series TMJ 1519 B. Includes undated method entitled: 

Analysis of feed, milk and tissues for residues of Permethrin. (Unpublished study received 

Aug 22, 1977 under 10182 EX 3; prepared by Imperial Chemical Industries, Ltd., submitted 

by ICI Americas, Inc., Wilmington, Del.; CDL:096334 J) 

00054724 Imperial Chemical Industries, Limited (1977) Determination of Residues of Permethrin 

(PP557) in Fruit and Vegetable Crops. Method no. 29/1 dated Jul 1, 1977. (Unpublished 

study received Aug 22, 1977 under 10182 EX 3; submitted by ICI Americas, Inc., 

Wilmington, Del.; CDL:096334 K) 

00054888 ICI Americas, Incorporated (1977) Cottonseed Residue Studies. (Compilation; unpublished 

study received Mar 23, 1977 under 10182 EX 3; CDL:096909 E) 

00057091 FMC Corporation (1975) Summary: [33297 Technical]. Summary of studies 226419 B 

through 226419 AA. (Unpublished study received on unknown date under 279 EX 60; 

CDL:226419 A) 

00062806 FMC Corporation (1980) Analysis of Physical Observations: Bio/dynamics Project 76_1695; 

FMC Study No. ACT 115.35. (Compilation; unpublished study received Dec 5, 1980 under 

unknown admin. no.; CDL:243863_A) 

00064451 ICI Americas, Incorporated (1976) Cottonseed Residue Studies. Summary of study 229220 F. 

(Unpublished study received Mar 28, 1977 under 10182 EX 3; CDL:229220 E) 

00064674 Edwards, M.J.; Iswaran, T.J. (1977) Permethrin: Residue Transfer and Toxicology Study with 

Cows Fed Treated Grass Nuts: Report Series TMJ 1519 B. (Unpublished study received Nov 

3, 1980 under CO 80/19; prepared by Imperial Chemical Industries Ltd., England, submitted 

by state of Colorado for ICI Americas, Inc.,Wilmington, Del.; CDL:243664 G) 

00064675 Imperial Chemical Industries Limited (1977) Determination of Residues of Permethrin 

(PP557) in Milk and Animal Tissues. Residue analytical method no. PPRAM 31 dated Jul 1, 

1977. (Unpublished study received Nov 3, 1980 under CO 80/19; submitted by state of 

Colorado for ICI Americas, Inc., Wilmington, Del.; CDL:243664 I) 

00064676 Edwards, M.J.; Swaine, H. (1977) Permethrin: Incorporation of Permethrin in the Diet of 

Laying Hens. Part II: Residues in Eggs and Tissues: Report Series TMJ 1520 B. 

(Unpublished study received Nov 3, 1980 under CO 80/19; prepared by Imperial Chemical 

Industries Ltd., England, submitted by state of Colorado for ICI Americas, Inc., Wilmington, 

Del.; CDL:243664 J) 

D-4 
MRID Citation Reference 

00064678 Imperial Chemical Industries Limited (1977) Determination of Residues of Permethrin (PP 

557) in Eggs. Residue analytical method no. PPRAM 37 dated Jun 28, 1977. (Unpublished 

study received Nov 3, 1980 under CO 80/19; submitted by state of Colorado for ICI 

Americas, Inc., Wilmington, Del.; CDL:243664 M) 

00064679 Bewick, D.W.; Leahey, J.P.; Saunders, R. (1977) Permethrin: Absorption in Pigs after Dermal 

Treatment: Report Series TMJ 1448B. (Unpublished study received Nov 3, 1980 under CO 

80/19; prepared by Imperial Chemical Industries Ltd., England, submitted by state of 

Colorado for ICI Americas, Inc., Wilmington, Del.; CDL:243664 O) 

00064680 Leahey, J.P.; Bewick, D.W.; Gatehouse, D.M.; et al. (1977) Permethrin: Absorption in 

Chickens after Dermal and Oral Treatments: Report Series TMJ 1481B. (Unpublished study 

received Nov 3, 1980 under CO 80/19; prepared by Imperial Chemical Industries Ltd., 

England, submitted by state of Colorado for ICI Americas, Inc., Wilmington, Del.; 

CDL:243664 P) 

00064682 Ussary, J.P.; Braithwaite, G.B. (1979) Ectiban Insecticide: Residue Monitoring under Section 

18 Program for Fly Control in Caged Layer Poultry Houses 1979: Report Series TMU0476/B. 

(Unpublished study received Nov 3, 1980 under CO 80/19; submitted by state of Colorado for 

ICI Americas, Inc., Wilmington, Del.; CDL:243664 S) 

00064683 Ussary, J.P.; Braithwaite, G.B.; Fitzpatrick, R.D.; et al. (1980) Residues of Permethrin and 3 

Phenoxybenzyl Alcohol in Tissues and Eggs from Ectiban® Treated Chickens (Trial No. 

35NC79 003): Report Series TMU0492/B. Includes undated provisional method entitled: Gas 

liquid chromatographic determination of permethrin, free and conjugated 3 phenoxybenzyl 

alcohol in animal tissues and eggs. (Unpublished study received Nov 3, 1980 under CO 

80/19; submitted by state of Colorado for ICI Americas, Inc., Wilmington, Del.; CDL:243664­

U) 

00064684 Ussary, J.P.; Braithwaite, G.B.; Fitzpatrick, R.D.; et al. (1980) Residues of Permethrin and 3 

Phenoxybenzyl Alcohol in Tissues from Ectiban® Treated Swine (Trial No. 35NC79 002): 

Report Series TMU0491/B. Includes undated provisional method entitled: Gas liquid 

chromatographic determination of permethrin, free and conjugated 3 phenoxybenzyl alcohol 

in animal tissues and eggs. (Unpublished study received Nov 3, 1980 under CO 80/19; 

submitted by state of Colorado for ICI Americas, Inc., Wilmington, Del.; CDL:243664-V) 

00064685 Ussary, J.P.; Braithwaite, G.B.; Fitzpatrick, R.D.; et al. (1980) Residues of Permethrin and 3 

Phenoxybenzyl Alcohol in Cow Tissues (Trial No. 35N79 001): Report Series TMU0493/B. 

Includes undated provisional method entitled: Gas liquid chromatographic determination of 

permethrin, free and conjugated 3 phenoxybenzyl alcohol in animal tissues and eggs. 

(Unpublished study received Nov 3, 1980 under CO 80/19; submitted by state of Colorado for 

ICI Americas, Inc., Wilmington, Del.; CDL:243664-V) 

D-5 
MRID Citation Reference 

00064686 Ussary, J.P.; Braithwaite, G.B.; Fitzpatrick, R.; et al. (1980) Residues of Permethrin and 

Permethrin Metabolites in Milk from Ectiban^(R) Treated Cows (Trial No. 35N79 001): 

Report Series TMU0490/B. Includes undated methods entitled: Determination of residues of 

permethrin and its metabolites in whole milk by electron capture gas chromatography and 

Determination of 3 phenoxybenzoic acid and cis trans dichlorovinyl acid; Derivatization using 

pentafluorobenzyl bromide. (unpublished study received Nov 3, 1980 under CO 80/19; 

submitted by state of Colorado for ICI Americas, Inc., Wilmington, Del.; CDL:243664-X) 

00065903 Gaughan, L.C.; Unai, T.; Casida, J.E. (1976) Permethrin Metabolism in Rats. (Unpublished 

study, including submitter summary, received Jan 3, 1978 under 279-3013; prepared by Univ. 

of California Berkeley, Div. of Entomology & Parasitology, submitted by FMC Corp., 

Philadelphia, Pa.; CDL:096692B) 

00069651 Tilka, M.A.; Hidalgo Gato, E.; Johnson, M.A.; et al. (1980) Determination of Permethrin 

Residues in Field Corn Forage, Fodder and Grain: RAN 0004. (Unpublished study received 

Feb 19, 1981 under 279 3014; submitted by FMC Corp., Philadelphia, Pa.; CDL:099922 B) 

00069652 Nelsen, T.R.; Burt, J.E.; Lover, G.E.; et al. (1980) Determination of Dichlorovinyl Acid and 

M Phenoxybenzyl Alcohol Residues in/on Field Corn, Forage, Fodder, and Grain: M 4525. 

(Unpublished study received Feb 19, 1981 under 279 3014; submitted by FMC Corp., 

Philadelphia, Pa.; CDL:099922 C) 

00070912 Ussary, J.P.; Pearson, F.J.; Koubek, K.G. (1981) Permethrin Residues in Process Fractions 

from Laboratory Fortified Soybeans: Report No. TMU0604/B. (Unpublished study received 

Apr 7, 1981 under 10182 18; submitted by ICI Americas, Inc., Wilmington, Del.; 

CDL:099977 F) 

00070914 Swaine, H.; Francis, P.D.; Rippington, D.; et al. (1980) Permethrin: Residue Levels of the 

Major Metabolites of the Insecticide in the Milk and Tissues of Cows Fed on a Treated Diet: 

Report No. RJ 0124B. Includes undated method entitled: Multiresidue analytical method for 

the determination of residues of metabolites of permethrin in milk and animal tissues. 

(Unpublished study received Apr 7, 1981 under 10182 18; prepared by Imperial Chemical 

Industries, Ltd., England, Submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099976­

B) 

00070915 Swaine, H.; Sapiets, A. (1981) Permethrin: Residue Transfer Study with Dairy Cows Fed on a 

Diet Containing the Insecticide at 150 Mg Kg-1: Report No. RJ 0188B. (Unpublished study 

received Apr 7, 1981 under 10182 18; prepared by Imperial Chemical Industries, Ltd., 

England, submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099976 C) 

00070916 Sapiets, A.; Swaine, H. (1981) Determination of Residues of the Major Metabolites of 

Permethrin and Cypermethrin in Products of Animal Origin. Method PPRAM 48 dated Mar 

1981. (Unpublished study received Apr 7, 1981 under 10182 18; prepared by Imperial 

Chemical Industries, Ltd., England, submitted by ICI Americas,Inc., Wilmington, Del.; 

CDL:099976 D) 

D-6 
MRID Citation Reference 

00070917 Swaine, H.; Francis, P.D.; Rippington, D.; et al. (1980) Permethrin: Incorporation of 

Permethrin in the Diet of Laying Hens: Part III Metabolite Residues in Eggs and Tissues: 

Residue Data Report RD/557/27. (Unpublished study received Apr 7, 1981 under 10182 18; 

prepared by Imperial Chemical Industries, Ltd., England, submitted by ICI Americas, Inc., 

Wilmington, Del.; CDL: 099976 E) 

00071952 Glaister, J.R.; Pratt, I.; Richards, D. (1977) Effects of High Dietary Levels of PP557 on 

Clinical Behaviour and Structure of Sciatic Nerves in the Rat: A Combined Report of Two 

Studies: Report No. CTL/P/317. (Unpublished study received Jan 27, 1978 under 1018218; 

prepared by Imperial Chemical Industries, Ltd., England, submitted by ICI Americas, Inc., 

Wilmington, Del.; CDL: 096768B) 

00072582 Imperial Chemical Industries, Limited (1976) Determination of Residues of Permethrin 

(PP557) in Fruit and Vegetable Crops. Method PPRAM 29 dated Feb 13, 1976. 

(Unpublished study received May 7, 1981 under 1E2515; submitted by ICI Americas, Inc., 

Wilmington, Del.; CDL:070069 E) 

00079385 Ussary, J.P.; Braithwaite, G.B.; Pearson, F.J.; et al. (1981) Permethrin and Permethrin 

Metabolite Residues in Cow Tissues Trial No. 35NC79 001: Report Series TMU0656/O 81/5; 

submitted by Trial No. 35NC79 001: Report Series TMU0656/B. (Unpublished study 

received Aug 27, 1981 under 1F2564; submitted by ICI Americas, Inc., Wilmington, Del.; 

CDL:070264 D) 

00079386 Ussary, J.P.; Braithwaite, G.B.; Fitzpatrick, R.D.; et al. (1981) Permethrin and Permethrin 

Metabolite Residues in Swine Tissues Trial No. 35NC79 002: Report Series TMU0655/B. 

(Unpublished study received Aug 27, 1981 under 1F2564; submitted by ICI Americas, Inc., 

Wilmington, Del.; CDL:070264 E) 

00079387 Ussary, J.P.; Braithwaite, G.B.; Kramer, J.A.; et al. (1981) Residues of Permethrin and 

Permethrin Metabolites in Milk from Ectiban® treated Cows (Trial No. 35NC79 001): Report 

Series TMU0653/B. Final rept. (Unpublished study received Aug 27, 1981 under 1F2564; 

submitted by ICI Americas, Inc., Wilmington, Del.; CDL:070264 F) 

00080047 Ussary, J.P.; Fitzpatrick, R.D.; Beguhn, M.A.; et al. (1981) Permethrin and Permethrin 

Metabolite Residues on Corn Fodder: Report Series TMU0628/B. (Unpublished study 

received Aug 20, 1981 under 10182 18; submitted by ICI Americas, Inc., Wilmington, Del.; 

CDL:070217 B) 

00080054 Fujie, G.H.; Grana, B.; Casida, M.E.; et al. (1976) Determination of Parent FMC 33297 

Residues in/on Cabbage, Brussels Sprouts, Broccoli, and Cauliflower: Analytical Report W 

0125. (Unpublished study received Aug 25, 1981 under 1F2562; submitted by FMC Corp., 

Philadelphia, Pa.; CDL:070232 B) 

00080055 Stearns, J.W.; Topolewski, T.V.; Grana, B.; et al. (1980) Determination of Permethrin 

Residues on Cabbage: RAN-0015. (Unpublished study received Aug 25, 1981 under 1F2562; 

submitted by FMC Corp., Philadelphia, Pa.; CDL:070232-\C) 

D-7 
MRID Citation Reference 

00080057 Nelsen, T.R.; Burt, J.E.; Carlin, J.L.; et al. (1980) Determination of Dichlorovinyl Acid and M 

Phenoxybenzyl Alcohol Residues in/on Cabbage: M 4512. (Unpublished study received Aug 

25, 1981 under 1F2562; submitted by FMC Corp., Philadelphia, Pa.; CDL:070232 E) 

00080058 Nelsen, T.R.; Burt, J.E.; Siedlecki, A.J.; et al. (1980) Determination of Dichlorovinyl Acid 

and M Phenoxybenzyl Alcohol Residues in/on Cabbage: M 4591. (Unpublished study 

received Aug 25, 1981 under 1F2562; submitted by FMC Corp., Philadelphia, Pa.; 

CDL:070232 F) 

00081578 Ussary, J.P.; Crain, L.; Harkins, J.T.; et al. (1980) Permethrin Residues on Potatoes: Report 

Series TMU0532/B. (Unpublished study received Aug 11, 1981 under 10182 18; submitted 

by ICI Americas, Inc., Wilmington, Del.; CDL:070286 A) 

00081579 Ussary, J.P.; Fitzpatrick, R.D.; Furqueron, T.C.; et al. (1981) Permethrin and Permethrin 

Metabolites on Potatoes: Report Series TMU0630/B. (Unpublished study received Aug 11, 

1981 under 10182 18; submitted by ICI Americas, Inc., Wilmington, Del.; CDL:070286 B) 

00081628 ICI Americas, Incorporated (1981) Permethrin Residues in Celery. (Compilation; unpublished 

study received Aug 11, 1981 under 10182 18; CDL:070287 A) 

00083972 Interregional Research Project Number 4 (1980) Summary of Residue Chemistry Data: 

[Permethrin]. (Compilation; unpublished study, including published data, received Sep 28, 

1981 under 1E2580; CDL:070369A) 

00088973 ICI Americas, Incorporated (1980) Residues: [Permethrin]. (Compilation; unpublished study 

received Dec 30, 1981 under 10182 18; CDL:070568 E) 

00089006 Bratt, H.; Mills, I.H.; Slade, M. (1977) Permethrin: Tissue Retention in the Rat: Report No. 

CTL/P/352. (Unpublished study received Dec 30, 1981 under 1018264; prepared by Imperial 

Chemical Industries, Ltd., England, submitted by ICI Americas, Inc., Wilmington, Del.; 

CDL:070565\G) 

00093708 FMC Corporation (1981) Crop Residues: [Pounce 3.2 EC]. (Compilation; unpublished study, 

including RAN 0011 and RAN 0017, received Jan 15, 1982 under 279 3014; CDL: received 

Jan 15, 1982 under 279 3014; CDL:246593 A) 

00094393 Capps, T.M.; Reynolds, J.L.; Selim, S.; et al. (1979) Metabolism of Permethrin in/on Soybean 

Plants: M 4131. (Unpublished study received Mar 7, 1980 under 10182 18; prepared by FMC 

Corp., submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099273 D) 

00094394 Capps, T.M.; Munger, D.M.; Reynolds, J.L.; et al. (1979) Translocation of Permethrin in 

Soybean Plants: M 4097. (Unpublished study received Mar 7, 1980 under 10182 18; prepared 

by FMC Corp., submitted by ICI Americas, Inc., Wilmington, Del.; CDL:099273 E) 

00096713 Alexander, D.J.; Clark, G.C.; Jackson, G.C.; et al. (1980) Permethrin Technical: Inhalation 

Study in Rats: 15 X 6 Hour Exposures over a 3 Week Period: WLC 34/80323. Includes 

method CAL 1173 dated Sep 21, 1979. (Unpublished study received Mar 17, 1982 under 

59200; prepared by Huntingdon Research Centre, England, submitted by Burroughs 

Wellcome Co., Research Triangle Park, N.C.; CDL:247019G) 

D-8 
MRID Citation Reference 

00097426 Bond, A.; Woollon, R.M.; Dayan, A.D.; et al. (1980) Neurotoxicity of Permethrin after Oral 

Administration in the Hen: Doc. No. HEFG 80_14. (Unpublished study received Mar 17, 

1982 under 59_200; prepared by Wellcome Foundation, Ltd., England, submitted by 

Burroughs Wellcome Co., Research Triangle Park, N.C.; CDL:247019_H) 

00100520 Stearns, J.W.; Hidalgo Gato, E.; Fung, R.; et al. (1981) Determination of Permethrin, 

Dichlorovinyl Acid and Metaphenoxybenzyl Alcohol Residues in Almond Meats, Shells and 

Hulls: RAN 0035. (Unpublished study received Apr 29, 1982 under 279 3014; submitted by 

FMC Corp., Philadelphia, Pa.; CDL:070823 B) 

00102043 Allsup, T.L., (1976). Hydrolysis of FMC 33297 Insecticide. Reference 44 J and Reference 45 

J. W-0103. 

00102082 ICI Americas, Inc. (1977) [Determination of Residues of Permethrin in Fruit and Vegetable 

Crops]. (Compilation; unpublished study received Dec 8, 1977 under 10182 EX 9; 

CDL:096677 G) 

00102107 ICI Americas, Inc. (19??) Stability of Permethrin Residues in Samples of Cottonseed Process 

Fractions Stored at 18 C. (Unpublished study received Jan 27, 1978 under 10182 18; 

CDL:096770 A) 

00102110 Hart, D.; Banham, P.; Glaister, J.; et al. (1977) PP557: Whole Life Feeding Study in Mice: 

Report No. CTL/P/359. (Unpublished study received Jan 27, 1978 under 10182_18; prepared 

by Imperial Chemical Industries, Ltd., submitted by ICI Americas, Inc., Wilmington, DE; 

CDL:096773_C; 096767) 

00102185 Bewick, D.; Leahey, J. (1978) Permethrin: The Analysis of the Permethrin Metabolite 3-(2,2­

Dichlorovinyl)-1-methylcyclopropane-1 2-Dicarboxylic Acid in the Excreta of Rats Given a 

Single Oral Dose of 14C_Permethrin: Report Series RJ0019B. (Unpublished study received 

May 23, 1978 under 1018218; prepared by Imperial Chemical Industries, Ltd., Eng., 

submitted by ICI Americas, Inc., Wilmington, DE; CDL:233991F) 

00109336 Ussary, J.; Moody, R.; King, E.; et al. (1982) Permethrin Residues on Cottonseed from ULV 

Applications: TMU0816/B. Final rept. (Unpublished study received Jul 13, 1982 under 

10182 70; submitted by ICI Americas, Inc., Wilmington, DE; CDL:247927 C) 

00110564 ICI Americas, Inc. (1982) Ambush Insecticide (Containing Permethrin): Residue Chemistry. 

(Compilation; unpublished study received Aug 19, 1982 under 10182 18; CDL:248182 A) 

00110610 ICI Americas, Inc. (1976) Ambush Pyrethroid Insecticide: [Residue on Cotton]. 

(Compilation; unpublished study received Dec 1, 1976 under 10182 EX 3; CDL:095628 A) 

00110622 FMC Corp. (1976) Results of Tests of the Amount of Residues Remaining and Description of 

the Analytical Method: [FMC 33297]. (Compilation; unpublished study received Jan 31, 1977 

under 279 EX 67; CDL:096006 B) 

D-9 
MRID Citation Reference 

00110624 Edwards, M.; Iswaran, T. (1977) Permethrin: Residue Transfer and Toxicology Study with 

Cows Fed Treated Grass Nuts: Report Series TMJ 1519 B. (Unpublished study received Oct 

25, 1977 under unknown admin. no.; prepared by Imperial Chemical Industries Ltd.,Eng., 

submitted by ICI Americas, Inc., Wilmington, DE; CDL:096395 F) 

00110634 FMC Corp. (1976) Results of the Amount of Residues Remaining and Description of 

Analytical Methods: [FMC 33297]. (Compilation; unpublished study received on unknown 

date under 279 EX 60; CDL: 226420 A) 

00110661 Heitmuller, T. (1975) Acute Toxicity of FMC 33297 3.2 EC to Eastern Oysters (Crassostrea 

virginica), Pink Shrimp (Penaeus duorarum), and Fiddler Crabs (Uca pugilator): (Submitter) 

NCT 620.61. (Unpublished study received Jan 3, 1978 under 279-3013; prepared by 

Bionomics, EG & G, Inc., submitted by FMC Corp., Philadelphia, PA; CDL:096699-G) 

00110666 Sauter, S. (1977) Accumulation of FMC-33297 by Fathead Minnow (Pimephales promelas) 

and Bluegill (Lepomis macrochirus): Submitter NCT 162.74. (Unpublished study received Jan 

3, 1978 under 279-3013; prepared by EG & G, Bionomics, submitted by FMC Corp., 

Philadelphia, PA; CDL:096699-Q) 

00110690 ICI United States, Inc. (1976) Ectiban Pyrethroid Insecticide 25% Wettable Powder 

(Containing Permethrin). (Unpublished study re- ceived Feb 3, 1977 under 10182-18; 

CDL:228186-A) 

00110693 ICI Americas, Inc. (1978) Ambush Pyrethroid Insecticide (Containing Permethrin): Petition 

for Tolerance for Permethrin on Cabbage and Lettuce: Section D Residue Chemistry. 

(Compilation; unpublished study received Mar 30, 1979 under 10182 18; CDL: 098040 A) 

00112933 Ross, D.; Roberts, N.; Cameron, M.; et al. (1977) Examination of Permethrin (PP 557) for 

Neurotoxicity in the Domestic Hen: ICI/ 157NT/77468. (Unpublished study received Oct 25, 

1977 under unknown admin. no.; prepared by Huntingdon Research Centre, Eng., submitted 

by ICI Americas, Inc., Wilmington, DE; CDL: 096395A) 

00112936 Alvarez, M., and J.E. Dziedzic (1977). Hydrolysis of FMC 33297. Reference 46J; CGP-77­

12. 

00118504 ICI Americas, Inc. (1982) Ambush Insecticide (Containing Permethrin): Residue Chemistry. 

(Compilation; unpublished study received Dec 2, 1982 under 10182 18; CDL:071276 A) 

00120271 Hodge, M.; Banham, P.; Glaister, J.; et al. (1977) PP557: 3 Gener_ ation Reproduction Study 

in Rats: Report No. CTL/P/361. (Unpublished study received Jan 27, 1978 under 1018218; 

prepared by Imperial Chemical Industries, Ltd., Eng., submitted by ICI Americas, Inc., 

Wilmington, DE; CDL:096772C) 

00126691 Interregional Research Project No. 4 (1982) The Results of Tests on the Amount of 

Permethrin Residues Remaining in or on Pumpkins, Including a Description of the Analytical 

Method Used. (Compilation; unpublished study received Mar 28, 1983 under 10182 18; 

CDL:071505 A) 

D-10 
MRID Citation Reference 

00128728 Interregional Research Project No. 4 (1980) The Results of Tests of the Amount of Permethrin 

Residues Remaining in or on Range grass, Including a Description of the Analytical Method 

Used.(Compilation; unpublished study received Jun 16, 1983 under 3E2911; CDL:071700 A) 

00129296 Interregional Research Project No. 4 (1983) The Results of Tests on the Amount of 

Permethrin Residues Remaining in or on Eggplant and Peppers Including a Description of the 

Analytical Method Used. (Compilation; unpublished study received May 17, 1983 under 

3E2892; CDL:071608 A) 

00129600 Kalinowski, A.; Banham, P.; Chart, I.; et al. (1982) Permethrin: One Year Oral Dosing Study 

in Dogs: Report No. CTL/P/647. (Unpublished study received Jul 28, 1983 under 1018218; 

prepared by Imperial Chemical Industries PLC, Eng., submitted by ICI Americas, Inc., 

Wilmington, DE; CDL:250845A) 

00133293 ICI Americas, Inc. (1983) Ambush Insecticide (Containing Permethrin). (Compilation; 

unpublished study received Nov 22, 1983 under 10182 18; CDL:072147 A) 

00135413 FMC Corp. (1979) Results of Tests for the Amount of Residue Remaining and a Description 

of the Analytical Methods: [Pounce 3.2 EC]. (Compilation; unpublished study received Apr 

12, 1979 under 279 3014; CDL:098202 A) 

00137902 FMC Corp. (1977) Results of the Amount of Permethrin Residues Remaining and Description 

of Analytical Methods. (Compilation; unpublished study received Jan 3, 1978 under 279 

3013; CDL:096701 A) 

00140140 FMC Corp. (1979) Results of Tests for the Amount of Residue Remaining and a Description 

of the Analytical Methods: [Pounce]. (Compilation; unpublished study received Jul 31, 1979 

under 279 3014; CDL:098899 A) 

00142263 FMC Corp. (1984) Results of Tests for the Amount of Residues Remaining and a Description 

of the Analytical Methods. Unpublished compilation. 37 p. 

00144307 Interregional Research Project No. 4 (1983) The Results of Tests on the Amount of 

Permethrin Residues Remaining in or on Avocados and Papayas Including a Description of 

the Analytical Method Used. Unpublished compilation. 105 p. 

00144855 Markle, J. (1984) Determination of Permethrin, Dichlorovinyl Acid and m Phenoxybenzyl 

Alcohol in/on 40 Day PHI Soybeans: RAN 0125. Unpublished study prepared by FMC 

Corporation. 29 p. 

00145266 ICI Americas, Inc. (1984) Ambush Insecticide (Containing Permethrin): Residue Chemistry: 

(Artichoke Buds). Unpublished compilation. 61 p. 

00145971 Interregional Research Project No. 4 (1983) The Results of Tests on the Amount of 

Permethrin Residues Remaining in or on Watercress. Unpublished compilation. 29 p. 

00150293 ICI Americas Inc. (1984) Residue Chemistry with Ambush Insecticide Containing Permethrin 

. Unpublished compilation. 105 p. 

D-11 
MRID Citation Reference 

00151251 Interregional Research Project No.4 (1984) The Results of Tests on the Amount of Permethrin 

Residues Remaining in or on Cantaloupes. Unpublished compilation. 92 p. 

00151832 FMC Corp. (1984) Results of Tests for the Amount of Residues Remaining and a Description 

of the Analytical Methods: Pounce. Unpublished compilation. 94 p. 

00155167 Fitzpatrick, R. (1985) Permethrin and Permethrin Metabolite Residues on Pumpkins: Report 

Series TMU1691/B. Unpublished study prepared by ICI Americas Inc. 28 p. 

00155947 Interregional Research Project No. 4 (1985) The Results of Tests on the Amount of 

Permethrin Residues Remaining in or on Collards, Mustard and Turnip Including a 

Description of the Analytical Method Used. Unpublished compilation. 192 p. 

00156265 ICI Americas Inc. (1980) Permethrin Residues on Lettuce and Cabbage . Unpublished 

compilation. 173 p. 

00160394 ICI Americas Inc. (1984) (Response to EPA's Comments on Analysis of Permethrin on Leafy 

Vegetables: Includes Analytical Methods and Residue Data in Sweet Corn). Unpublished 

compilation. 93 p. 

00165524 Markle, J. (1982) Determination of Permethrin, Dichlorovinyl Acid and Metaphenoxybenzyl 

Alcohol Residues in Mushrooms: Pounce Insecticide: RAN 0047. Unpublished study 

prepared by FMC Agricultural Chemical Group, Richmond. 30 p. 

00165525 Nelsen, T. (1982) Cold Storage Stability of Dichlorovinyl Acid and M Phenoxybenzyl 

Alcohol Residues in/on Green Alfalfa, Alfalfa Hay, and Lettuce: Pounce Insecticide: M 4838. 

Unpublished study prepared by FMC Agricultural Chemical Group, Middleport. 22 p. 

40072401 Rabenold, J. (1986) Permethrin & Metabolites Magnitude of Residue in Alfalfa: Final Report 

#34688/FMC Corp 138ALFR03. Unpublished study prepared by Analytical Bio Chemistry 

Laboratories. 94 p. 

40190101 Brown, P.M., and J.P. Leahy (1987) Permethrin: Photolysis on a soil surface. Labroratory 

Project ID: RJ0581B. Prepared and submitted by ICI Americas Inc., Wilmington, DE. 

40404001 Stearns, J. (1987) Determination of Permethrin, Dichlorovinyl Acid and m Phenoxybenzyl 

Alcohol Residues in/on Onion Bulbs: Study No. 1380NIR02. Unpublished study prepared by 

FMC Corp. 87 p. 

40404002 Stearns, J. (1987) Methodology for the Determination of Permethrin, Dichlorovinyl Acid and 

m Phenoxybenzyl Alcohol Residues in/on Onion Bulbs: Study No. 1380NIR02. Unpublished 

study prepared by FMC Corp. 35 p. 

40446401 Armentrout, T.; Koch, D. (1987) Pounce Insecticide Magnitude of the Residue of Permethrin 

in/on Asparagus: Laboratory Project ID 35803. Unpublished study performed by Analytical 

Bio Chemistry Laboratories. 33 p. 

D-12 
MRID Citation Reference 

40446402 Rizzi, L. (1987) Pounce Insecticide Magnitude of the Residue of Dichlorovinyl Acid and m 

Phenoxybenzyl Alcohol in/on Asparagus: Study No. 138ASPR01. Unpublished study 

prepared by FMC Corporation. 37 p. 

40446403 Armentrout, T.; Koch, D. (1987) Pounce Insecticide Analytical Method for the Determination 

of Permethrin in/on Asparagus: Report No. 35803 M. Unpublished study prepared by 

Analytical Bio Chemistry Laboratories. 19 p. 

40446404 Rizzi, L. (1987) Pounce Insecticide Analytical Method for the Determination of 

Dichlorovinyl Acid and m Phenoxybenzyl Alcohol in/on Asparagus: Study No. 138ASPR01. 

Unpublished study prepared by FMC Corporation. 28 p. 

40556801 Armentrout, T.; Koch, D. (1987) Permethrin and Its Major Metabolites Magnitude of the 

Residue in Cucumbers: Study No. 138CURR01. Unpublished study prepared by Analytical 

Bio Chemistry Laboratories. 47 p. 

40556802 Armentrout, T.; Koch, D. (1987) Permethrin and Its Major Metabolites Magnitude of the 

Residue in Melons: Study No. 138CURR01. Unpublished study prepared by Analytical Bio 

Chemistry Laboratories. 49 p. 

40556803 Armentrout, T.; Koch, D. (1987) Permethrin and Its Major Metabolites Magnitude of the 

Residue in Squash: Study No. 138CURR01. Unpublished study prepared by Analytical Bio 

Chemistry Laboratories. 47 p. 

40556804 Armentrout, T.; Koch, D. (1987) Permethrin, Dichlorovinyl Acid and m Phenoxybenzyl 

Alcohol Methodology for Cucurbits: Study No. 138CURR01. Unpublished study prepared by 

Analytical Bio-Chemistry Laboratories. 46 p. 

40766807 Snodgrass, H. (1986) Neurotoxicity in Rats Following Subchronic Ingestion of Permethrin 

Treated Food: Proj. ID 7551035187. Unpublished study prepared by US Army Environmental 

Hygiene Agency. 

40943601 Wilks, K.; Eitelman, S. (1988) Permethrin Technical: [Product Chemistry]: ICI No. 

TMR0006C. Unpublished study prepared Western Research Center. 104 p. 

40943603 Hodge, M. (1988) Permethrin: Teratogenicity Study in the Rat: Laboratory Project ID: 

CTL/P/2269. Unpublished study prepared by ICI Central Toxicology Laboratory. 

40943604 Truemann, R. (1988) Permethrin: Assessment for the Induction of Unscheduled DNA 

Synthesis in Primary Rat Hepatocyte Cultures: Laboratory Project ID: CTL/P/1888. 

Unpublished study prepared by Imperial Chemical Industries PLC. 

40955301 Halfon, M. (1988) Permethrin: Product Identity and Disclosure of Ingredients: Description of 

Starting Materials and Manufacturing Process: Discussion on the Formation of Impurities. 

Unpublished study prepared by FMC Corp. 75 p. 

41031107 Callander, R. (1989) Permethrin: An Evaluation in the Salmonella Mutation Assay: Report 

No. CTL/P/2423: CTL Study No. YV2410. Unpublished study prepared by ICI Central 

Toxicology Laboratory. 

D-13 
MRID Citation Reference 

41054701 Knarr, R. (1988) Exposure of Applicators to Propoxur During Trigger Pum Spray Application 

of a Liquid Product: 99100. 

41054701 Knarr, R. (1988) Exposure of Applicators to Propoxur During Trigger Pum Spray Application 

of a Liquid Product: 99100. 

41065802 Leppert, B. (1985) Determination of Permethrin, Dichlorovinyl Acid and m Phenoxy benzyl 

Alcohol Residues on Broccoli, Cauliflower and Cabbage Treated with Pounce 3.2 EC 

Insecticide: Proj. ID RAN 0162. Unpublished study prepared by FMC Corp. 64 p. 

41065803 Leppert, B. (1985) Determination of Permethrin, Dichlorovinyl Acid and m Phenoxy benzyl 

Alcohol Residues on Cherries Treated with Pounce 3.2 EC Insecticide: Proj. ID RAN 0145. 

Unpublished study prepared by FMC Corp. 38 p. 

41065804 Leppert, B. (1985) Determination of Permethrin, Dichlorovinyl Acid and m Phenoxy benzyl 

Alcohol Residues in Field Corn Treated with Pounce 3.2 EC Insecticide at the Brown Silk 

Stage at a 10X Rate: Proj. ID RAN 0150. Unpublished study prepared by FMC Corp. 31 p. 

41065805 Stearns, J. (1983) Determination of Permethrin Residues in/on Pistachio Nuts: Proj. ID RAN 

0073. Unpublished study prepared by FMC Corp. 16 p. 

41065808 Leppert, B. (1985) Determination of Permethrin, Dichlorovinyl Acid and m Phenoxy benzyl 

Alcohol Residues in Spinach Treated Aerially with Pounce 3.2 EC Insecticide: Proj. ID RAN 

0159. Unpublished study prepared by FMC Corp. 29 p. 

41136401 Kahn, B. (1989). Analyisis and Certification of Product Ingredients in Permethrin Insecticides: 

Rept. No. WRC 89-57. Unpublished study prepared by ICI Americas Inc. 132 p. 

41143801 Citation: Milburn, G. (1989) Permethrin: 21 Day Dermal Study in Rats: Report No. 

CTL/P/2445: Study No. LR0533. Unpublished study prepared by ICI Central Toxicology 

Laboratory. 

41150901 Halfon, M. (1989) Analysis and Certification of Product Ingredients: Permethrin. Unpublished 

Compilation prepared by FMC Corp. 31 p. 

41300401 Burgess, D. (1989) Uptake, Depuration and Bioconcentration of 14C-Permethrin by Bluegill 

Sunfish (Lepomis macrochirus). Laboratory Report #PC-0117. Unpublished study performed 

by Analytical Bio-Chemistry Laboratories, Inc., Columbia, MO, and submitted by FMC 

Corporation , Princeton, NJ. 

41300402 Tullman, R. (1989) Accumulation Studies: Lavboratory Studies of Pesticide Accumulation in 

Fish: Acid (Cycloprophyl)-

14C-Permethrin in the Bluegill Sunfish. Laboratory Report 

#138E5489E1-1. Unpublished study performed and submitted by FMC Corporation, 

Princeton, NJ. 

41300403 Singer, S. (1989) Accumulation Studies: Laboratory Studies of Pestcide Accumulation in 

Fish: 14C-Alcohol (Phenyl)-Labled Permethrin in the Bluegill Sunfish. Laboratory Report 

#138E5489E1-2. Unpublished study performed and submitted by FMC Corporation, 

Princeton, NJ. 

D-14 
MRID Citation Reference 

41404301 Francis, P. (1990) Ambush (Permethrin) Magnitude of the Residue Study on Processed 

Tomato Products: Lab Project ID 0557 89 PR 01. Unpublished study prepared by ICI 

Americas, Inc. 129 p. 

41560201 Sapiets, A.; Swaine, H.; Hayward, G.; et al. (1982) Permethrin: Residue Transfer Study with 

Laying Hens Fed on a Diet Containing Insecticide: Lab Project Number: PP557BB01. 

Unpublished study prepared by ICI Agrochemicals. 115 p. 

41560202 Swaine, H.; Rippington, D.; Ward, R. (1978) Permethrin: Storage Stability of Residues in 

Deep Frozen Apple and Cabbage: Lab Project Number: M5117B. Unpublished study prepared 

by ICI Agrochemicals. 19 p 

41565401 Choban, R. (1984) Permethrin: Magnitude of the Residue In or On Avocados and Papayas: 

Lab Project Number: IR 4/1727,1729: PP4E31 46. Unpublished study prepared by Univ. of 

Florida in cooperation with USDA ARS. 11 p. 

41565402 Choban, R. (1984) Permethrin: Magnitude of the Residue In or On Cantaloupe: Summary ...: 

Lab Project Number: IR 4 /1730: PP 5E 3225. Unpublished study prepared by USDA ARS. 

11 p. 

41565403 Choban, R. (1983) Permethrin: Magnitude of the Residue In or On Egg plant and Bell 

Peppers: Summary ...: Lab Project Number: IR 4/ 1259, 1357: PP 3E2892:. Unpublished 

study prepared by Rutgers Univ. in coop. with USDA ARS and ICI Americas, Biological 

Research Ctr. 12 p. 

41565404 Choban, R. (1981) Permethrin: Magnitude of the Residue In or On Horseradish: Reformat of 

MRID'S 3551718 and 9460910: Lab Project Number: IR 4/3684: PP OE2377. Unpublished 

study prepared by ICI Americas Inc., Biological Research Ctr. and Illinois Natural History 

Survey. 51 p. 

41565405 Choban, R. (1982) Permethrin: Magnitude of the Residue In or On Pumpkin: Summary . . .: 

Lab Project Number: IR 4/1732: PP 3E2861. Unpublished study prepared by ICI Americas. 

12 p 

. 

41565406 Choban, R. (1980) Permethrin: Magnitude of the Residue In or On Range Grass: Summary ...: 

Lab Project Number: IR 4/2323: PP 3E2911. Unpublished study prepared by ICI ARS. 11 p. 

3E2911. Unpublished study prepared by ICI Americas Inc. 10 p. 

41575901 Choban, R. (1984) Permethrin: Magnitude of the Residue in or on Collards and Turnips: Lab 

Project Number: IR 4 PR NO. 941. Unpublished study prepared by Yakima Agricultural 

Research Laboratory, USDA. 135 p. 

41641001 Leppert, B. (1990) Methodology for the Determination of Permethrin, Dichlorovinyl Acid and 

m Phenoxybenzyl Alcohol Residues in/on Pistachios: Lab Project Number: 138PIS87R1. 

Unpublished study Prepared by FMC Corp. 38 p. 

41641002 Leppert, B. (1990) Pounce Insecticide Magnitude of the Residue of Permethrin, 

Dichlorovinyl Acid and m Phenoxybenzyl Alcohol in/on Pistachios: Lab Project Number: 

138PIS87R1. Unpublished study prepared by FMC Corp. 43 p. 

D-15 
MRID Citation Reference 

41868001 Davis, M.L. (1991) Sorption/Desorption of 14C-Permethrin on Soils by thr Batch Equilibrium 

mMethod. Study performed by Battelle Memorial Institute. Columbus, OH, and submitted by 

FMC Corporation, Princeton, NJ. 

41970601 Hawkins, D., et al. (1991) The Metabolism of 14C-Permethrin in Sandy Loam Soil Under 

Anaerobic Conditions. Laboratory Report No. HRC/ISN 236/91107. Unpublished study 

performed and submitted by ICI Agrochemicals, Huntingdon Research Center, Ltd. 

Huntingdon, England. 

41970602 Hawkins, D., et al. (1991) The Effects of Application Rates and Soil Moisture Content on the 

Rater of Degredation of 14C-Permethrin. Laboratory Report No. HRC/ISN 247/91296. 

Unpublished study performed and submitted by ICI Agrochemicals, Inc., Huntingdon 

Research Center, Huntingdon, England. 

42109801 Alvarez M. (1989) Permethrin: Physical Properties: Lab Project No. 138AF88113. 

Unpublished study prepared by FMC Corp. 50 p. 

42009301 Lynn, S.; Hoxter, K. (1991) Permethrin Wettable Powder-Ambush 25 W: A Foliage Residue 

Toxicity Study with the Honey Bee: Lab Project Number: WIL 123-165. Unpublished study 

prepared by Wildlife International Ltd. 28 p. 

42137201 Leppert, B. (1991) Pounce 3.2 EC Insecticide--Magnitude of the Residue on Artichoke from 

Field Trials Using Aerial Applications : Lab Project Number: 138ART91R1. Unpublished 

study prepared by FMC Corp. 77 p. 

42137202 Leppert, B. (1991) Pounce Insecticide: Residue Analytical Methods for the Determination of 

the Residues of Permethrin and Its Metabolites on Artichokes: Lab Project Number: 

138ART91R1. Unpublished study prepared by FMC Corp. 46 p. 

42196701 Cranor, W. (1991) Leaching Characteristics of Soil Incorporated Permethrin Following 

Aerobics Aging. Laboratory Report #39227. Performed by ABC Laboratories, Inc., 

Columbia, MO. Submitted by FMCCorporation, Princeton, NJ. 

42196702 Leahey, J.; et al. (1977) Permethrin: Absorption in Chickens after Dermal and Oral 

Treatments. Unpublished study prepared by ICI Agrochemicals. 33 p. 

42196703 Leahey, J.; Cameron, ?.; et al. (1978) Permethrin: Residues in Cows after Dermal 

Applications. Unpublished study prepared by ICI Agrochemicals. 32 p. 

42322904 ICI Americas; FMC Corp. (1992) Permethrin: Residues in Lettuce: Addenda to MRID 

92142116. Unpublished study. 7 p. 

42322905 ICI Americas; FMC Corp. (1992) Permethrin: Residues in Pears: Addenda to MRID 

92142117. Unpublished study. 3 p. 

42322906 ICI Americas; FMC Corp. (1992) Permethrin: Residues in Walnuts: Addenda to MRID 

072833. Unpublished study. 25 p. 

D-16 
MRID Citation Reference 

42359109 Becker, J.M. (1992) Pounce 3.2 EC Insecticide - Terrestrial Field Dissipation. Vol 3 of 8. 

FMC Study#138E4191R1. Performed and submitted by FMC Corporation, Princeton, NJ. 

42377601 Wollweton, C.; Husband, R. (1992) Permethrin: Physico-Chemical Study on Technical Grade 

Active Ingredient: Lab Project Number: RJ1141B: 92JH3. Unpublished study prepared by 

ICI Agrochemicals; Jealott's Hill, UK. 17 p. 

42410001 Hawkins, D.; Kirkpatrick, D.; Shaw, D. (1992) The Metabolism of [carbon 14] Permethrin in 

the Goat: Lab Project Number: HRC/ISN 248/920216. Unpublished study prepared HRC/ISN 

248/920216. Unpublished study prepared by Huntingdon Research Centre, Ltd. 97 p. 

42410002 Hawkins, D.R., et al (1992) The Aerobic Soil Metabolism of 14C-Permethrin. Laboratory 

Report No. HRC/ISN 251/911499. Unpublished study performed by ICI Agrochemicals, 

Huntingdon research Center, Huntingdon, England. 

42431401 Dansbury, L. (1992) US EPA/OPP dated July 31, 1992 from Linda Dansbury [FMC] with 

Attachments 1 and 2 of preliminary data on residues of Permethrin in spinach. Unpublished 

study prepared by Rhone Poulenc Ag. Co. 4 p. 

42503201 Hawkins, D.; Kirkpatrick, D.; Shaw, D.; et al. (1992) The Metabolism of [Carbon 14] 

Permethrin in the Hen: Lab Project Number: HRC/ISN 272/920435. Unpublished study 

prepared by Huntingdon Research Centre Ltd. 84 p. 

42653301 Citation: Milburn, G. (1989) Permethrin: 21 Day Dermal Study in Rats: Individual Animal 

Data Supplement: An Addendum: Lab Project Number: CTL/P/2445: LR0533. Unpublished 

study prepared by Zeneca Central Toxicology Lab. 

42723302 Fox, D.; Mackay, J. (1993) Permethrin: An Evaluation in the Mouse Micronucleus Test: Lab 

Project Number: CTL/P/3934. Unpublished study prepared by Zeneca, Ltd. 

42802701 Alvarez, A. (1993) Response to Questions Raised by EPA Regarding MRID 42109801: 

Permethrin Product Chedmistry: Lab Project Nos. P-2822: 138AF93248. Unpublished study 

prepared by FMC Corp. 36 p. 

42824701 Francis, P.; Grant, C. (1993) Permethrin (ICIA0557): Residue Processing Study Following 

the Application of AMBUSH to Potatoes: Lab Project Number: PERM-92-PR-02: RR 

93-026B. Unpublished study prepared by Zeneca, Inc. and Wm. J. Englar & Associates, Inc. 

81 p. 

42824702 Francis, P.; Grant, C. (1993) Permethrin (ICIA0557): Residue Processing Study for AMBUSH 

on Apples: Lab Project Number: PERM 92 PR 01: RR 93 023B. Unpublished study prepared 

by Zeneca, Inc. and ACDS, Inc. 75 p. 

42838101 Francis, P. (1993) Permethrin (ICIA0557): Residue Levels in Apples from Trials Carried Out 

in the USA During 1992: Lab Project Number: PERM 92 MR 04: PERM 92 MR 05: RR 93 

060B. Unpublished study prepared by Zeneca Ag Products. 83 p. 

D-17 
MRID Citation Reference 

42860601 Munoz, W. (1993) Magnitude of the Residues of Permethrin, Dichlorovinyl Acid and meta 

Phenoxybenzyl Alcohol in/on Sweet Corn Processed Products (Cannery Waste) Treated with 

Pounce 3.2EC Insecticide: Lab Project Number: RAN 0247. Unpublished study prepared by 

FMC Corporation. 116 p. 

42909001 Francis, P. (1993) Permethrin (ICIA0557): Residue Levels in Alfalfa Forage, Hay and Meal 

from Trials Carried Out in the USA During 1992: Lab Project Number: RR 93 071B: PERM 

92 MR 01: PERM 92 MR 02. Unpublished study prepared by ZENECA Ag Products. 117 p. 

42910101 Hebert, V.; Starner, K. (1993) Magnitude of the Residue of Permethrin, Dichlorovinyl Acid 

and Meta phenoxybenzyl Alcohol Residues in/on Field Corn Grain Treated with Pounce 3.2 

EC Insecticide at Exaggerated Label Rates: Lab Project Number: 138COF92R2: RAN 0246. 

Unpublished study prepared by FMC Corp.76 p. 

42919201 Eckstein, C. (1993) Part III: Final Report on Storage Stability of Pyrethroid Metabolites 

(PP890, 3 PB acid, 3 PBalcohol, and DCVA) in Raw Agricultural Commodities (36 Month 

Interval): Lab Project Number: PYRE 89 SS 01. Unpublished study prepared by Western 

Research Center. 73 p. 

42933701 Freeman, C. (1993) Permethrin Technical: Subchronic Neurotoxicity Screen in Rats: Lab 

Project Number: A923647. Unpublished study prepared by FMC Corp. 

42979901 Lepert, B. (1993) Magnitude of the Residues of Permethrin, Dichlorovinyl Acid and meta 

Phenoxybenzyl Alcohol in/on Spinach Treated with Ten Applications of Pounce 3.2 EC 

Treated with Ten Applications of Pounce 3.2 EC Insecticide of Pounce 25 WP Insecticide at 

0.2 lb Active Ingredient per Acre per Application: Lab Project Number: 138SPI92R1: RA 

0240. Unpublished study prepared by FMC Corp. 165 p. 

43046301 Freeman, C. (1993) Permethrin Technical: Acute Neurotoxicity Screen in Rats: Lab Project 

Number: A923646. Unpublished study prepared by FMC Corporation, Toxicology Lab. 

43088401 Biehn, W. (1994) Permethrin in/on Raspberry (Amendment IR 4 Petition 8E 3675, MRID 

40782901, EPA 28 NOV 88 Response Letter): Lab Project Number: IR 4 PR NO. 2564: 

2564.91 CAR 02: 89:CAR:005. Unpublished study prepared by IR 4 Western Region 

Analytical Lab.; Washington State Univ., Research & Extension Unit; N. Willamette Research 

& Extension Ctr. 274 p. 

43149501 Munoz, W. (1994) Magnitude of the Residue of Permethrin, Dichlorovinyl Acid and Meta 

Phenoxybenzyl Alcohol Residues in/on Field Corn Treated with Pounce 3.2 EC Insecticide: 

Lab Project Number: 138COF93R2: RAN 0255. Unpublished study prepared by FMC Corp. 

120 p. 

43164801 Goodman, M. (1993) Permethrin - pH: Lab Project Number: APP-020: RR-93-051B. 

Unpublished study prepared by Western Research Center, Zeneca Ag Products. 7 p. 

43169001 Lythgoe, R. (1993) Permethrin: In vivo Percutaneous Absorption Study in the Rat: Lab 

Project Number: CTL/P/3984. Unpublished study prepared by Zeneca Central Toxicology 

Lab. 

D-18 
MRID Citation Reference 

43173801 Groome, J.M., et. Al. (1992) Permanone 10ECSpray Drift Study. Study performed by 

Wellcome Foundation LTD., Berkhamsted, United Kingdom, and Fairfield America Co., 

Frenchtown, NJ. 

43174401 Schanne, C. (1993) Confined Rotational Crop Study in the Greenhouse with (carbon 14) 

Labelled Permethrin: Lab Project Number: 265724. Unpublished study prepared by R C C 

Umweltchemie Ag. 248 p. 

43307801 Flueckiger, J. (1994) Plant Metabolism Study in Field Grown Sweet Corn with (Carbon 14) 

Permethrin: Lab Project Number: 265735. Unpublished study prepared by RCC 

Umweltchemie AG. 157 p. 

43343101 Eckstein, C. (1994) Permethrin (ICIA0557): Magnitude of the Residue Study on Alfalfa Seed 

and Seed Screenings After Treatment of Alfalfa with AMBUSH or AMBUSH 25W from 

Trials Carried out in the USA During 1992: Lab Project Number: PERM 92 MR 03: RR 93 

107B: 16 ID 92 121. Unpublished study prepared by Zeneca Ag Products. 65 p. 

43343102 Francis, P. (1994) Permethrin (ICIA0557): Magnitude of the Residue Study on Potatoes After 

Treatment with AMBUSH or AMBUSH 25W from Trials Carried out in the USA During 

1992: Lab Project Number: PERM 92 MR 08: PERM 92 MR 09: RR 94 011B. Unpublished 

study prepared by Zeneca Ag Products. 79 p. 

43348101 Robbins, J. (1994) Permethrin (ICIA0557): Magnitude of the Residue Study on Peaches After 

Treatment with AMBUSH and AMBUSH 25W from Trials Carried out in the USA During 

1992: Lab Project Number: RR 94 040B: PERM 92 MR 06: PERM 92 MR 07. Unpublished 

study prepared by Zeneca Ag Products, Western Research Lab. 75 p. 

43350501 Hebert, V. (1994) Magnitude of the Residues of Permethrin, Dichlorovinyl Acid and m 

Phenoxybenzyl Alcohol in/on Celery Treated with Ten Applications of with Pounce 3.2 EC 

Insecticide or Pounce 25 WP Insecticide at 0.2 lb Active Ingredient per Acre per Application: 

Lab Project Number: 138CEL92R1: RAN/0258. Unpublished study prepared by FMC 

Corp.155 p. 

43350502 Jang, D. (1994) Magnitude of the Residues of Permethrin, Dichlorovinyl Acid and m 

Phenoxybenzyl Alcohol in/on Spinach Treated with Five Applications of with Pounce 3.2 EC 

Insecticide at 0.2 lb Active Ingredient per Acre per Application: Lab Project Number: 

138SPI93R1. Unpublished study prepared by FMC Corp. 149 p. 

43350503 Brooks, M. (1994) Magnitude of the Residues of Permethrin, Dichlorovinyl Acid and m 

Phenoxybenzyl Alcohol in/on Sweet Corn Ears, Husks and Stalks Treated with Pounce 1.5 

Ears, Husks and Stalks Treated with Pounce 1.5 G and 3.2 EC Insecticides: Lab Project 

Number: 138COS92R1: P/2947. Unpublished study prepared by FMC Corp. 180 p. 

43364701 Jang, D. (1994) Magnitude of the Residue of Permethrin, Dichlorovinyl Acid and m 

Phenoxybenzyl Alcohol Residues in/on Field Corn Treated Using Pounce 3.2 EC Insecticide: 

Lab Project Number: 138COF92R3: RAN 0256. Unpublished study prepared by FMC Corp. 

188 p. 

D-19 
MRID Citation Reference 

43364702 Jang, D. (1994) Magnitude of the Residue of Permethrin, Dichlorovinyl Acid and meta 

Phenoxybenzyl Alcohol Residues in/on Field Corn Treated with Pounce 1.5 G and/or 3.2 EC 

Insecticide: Lab Project Number: 138COF93R1: RAN 0257. Unpublished study prepared by 

FMC Corp. 163 p. 

43364703 Stearns, J. (1994) Magnitude of the Residue of Permethrin, Dichlorovinyl Acid and meta 

Phenoxybenzyl Alcohol Residues in/on Soybean Seeds (Dry) and Processed Products Treated 

with Pounce 3.2 EC Insecticide at 60 Day PHI: Lab Project Number: 138SOY92R4: RAN 

0261. Unpublished study prepared by FMC Corp. 116 p. 

43364704 Stearns, J. (1994) Magnitude of the Residue of Permethrin, Dichlorovinyl Acid and meta 

Phenoxybenzyl Alcohol Residues in/on Soybean Seeds (Dry) Treated with Pounce 3.2 EC 

Insecticide at 60 Day PHI: Lab Project Number: 138SOY92R2: RAN 0262. Unpublished 

study prepared by FMC Corp. 88 p. 

43364705 Stearns, J. (1994) Analytical Methods for the Determination of Permethrin, Dichlorovinyl 

Acid and meta Phenoxybenzyl Alcohol Residues in/on Soybeans and its Processed and/or 3.2 

EC Residues in/on Soybeans and its Processed Products: Lab Project Number: 138SOY92R1: 

138SOY92R2: 138SOY92R3. Unpublished study prepared by FMC Corp. 72 p. 

43374601 Castro, T. (1993) Magnitude of the Residue of Permethrin, Dichlorovinyl Acid and m 

Phenoxybenzyl Alcohol Residues in/on Field Corn Grain and Processed Products (Wet and 

Dry Mill Products) Treated with Pounce 3.2 EC Insecticide at Exaggerated Label Rates: Lab 

Project Number: 138COF92R4: RAN 0249. Unpublished study prepared by FMC Corp. 186 

p. 

43424901 Gravelle, W.D. (1994) Adsorption/Desorption of 14C-trans-DCVA on Four Soils. Study 

performed and submitted by FMC Corporation, Princeton, NJ. 

43458801 Baker, P.; Dighton, M.; Elsom, L. et al. (1994) The Dermal Metabolism of (carbon 14) 

Permethrin in Cows: Interim Report: Lab Project Number: ISN/335. Unpublished study 

prepared by Huntington Research Center Ltd. 11 p. 

43458802 Baker, P.; Dighton, M.; Elsom, L. et al. (1994) The Dermal Metabolism of (carbon 14) 

Permethrin in Hens: Interim Report: Lab Project Number: ISN/334. Unpublished study 

prepared by Huntington Research Center Ltd. 13 p. 

43494701 Samoil, K. (1994) Magnitude of Residue: Permethrin on Pepper (Bell): Lab Project Number: 

IR/4/PR/1357. Unpublished study prepared by New Jersey Agricultural Experiment Station. 

353 p. 

43505201 Kirkpatrick, D. (1994) Addendum to MRID 42410001, (carbon 14) Permethrin Metabolism in 

the Goat: Further Investigations of the Residue in Milk and Tissues: Lab Project Number: ISN 

307/931858. Unpublished study prepared by Huntingdon Research Centre Ltd. 45 p. 

43651601 Robson, C.; Pearson, F. (1995) Permethrin: Physico-Chemical Study on Technical Grade 

Active Ingredient: Addendum to MRID 42377601: Response to EPA Review: Lab Project 

Number: RJ1141B. Unpublished study prepared by Zeneca, Inc. 19 p. 

D-20 
MRID Citation Reference 

43713301 Baker, P.; Cameron, D.; Dighton, M.; et al. (1995) Fate of (Carbon 14) Permethrin When 

Applied to Hens: In Life Phase: Lab Project Number: ISN 334/943254. Unpublished study 

prepared by Huntingdon Research Centre, Ltd. 84 p. 

43713302 Dighton, M.; Elsom, L.; Hawkins, D. (1995) The Metabolite Profiles in Tissues, Eggs and 

Excreta of Hens After Dermal Application of (Carbon 14) Permethrin: Lab Project Numbers: 

ISN 343/950908. Unpublished study prepared by Huntingdon Research Centre, Ltd. 92 p. 

43713303 Baker, P.; Cameron, D.; Dighton, M.; et al. (1995) Fate of (Carbon 14) Permethrin When 

Applied to Cows: In Life Phase: Lab Project Numbers: ISN 335/950271. Unpublished study 

prepared by Huntingdon Research Centre, Ltd. 65 p. 

43713304 Dighton, M.; Elsom, L.; Hawkins, D. (1995) The Metabolite Profiles in Tissues, Milk and 

Urine of Cows After Dermal Application of (Carbon 14) Permethrin: Lab Project Numbers: 

ISN 344/951571. Unpublished study prepared by Huntingdon Research Centre, Ltd. 93 p. 

43755701 Belcher, T. & Schuster, L. (1995) Dissipation of Dislodgeable Foliar Residues of Permethrin 

Applied to Orchards (Peaches). Sponsor: Zeneca Ag Products, Inc.: C/O permethrin Task 

Force; Performing Laboratories: Analytical - ABC Laboratories, Pan-Ag Division. 

43755701 Belcher, T. & Luster, S. (1995) Dissipation of Dislodgeable Foliar Residues of Permethrin 

Applied to Orchards (Peaches). Sponsor: Zeneca Ag Products, Inc.: C/O permethrin Task 

Force; Performing Laboratories: Analytical - ABC Laboratories, Pan-Ag Division. 

43903501 Francis, P.; Grant, C. (1996) Permethrin (ICIA0557): Magnitude of the Residue Study on 

Broccoli after Treatment with Ambush: Lab Project Number: PERM 94 MR 01: RR 95 085B: 

02 CA 94 571. Unpublished study prepared by Zeneca Ag Products' Western Research 

Center. 51 p. 

43938201 Robinson, R.A., and J.E. Ryan (1996) Aerobic Aquatic Metabolism of [14]C-Permethrin. 

Study performed by XenoBiotic Laboratories, Inc., Plainsboro, NJ, and submitted by AgrEvro 

Environmental Health, Montvale, NJ. 

43938801 Curry, K. (1992) Phase 3 Reformat of MRIDs 00110564 and 100520: AMBUSH and 

POUNCE Magnitude of the Residue in or on Almonds: Lab Project Number: RR 92 012B: 

TMU0482/B: TMU0571/B. Unpublished study prepared by ICI Americas Inc, Western 

Research Center. 255 p. 

43962801 Skidmore, M. (1996) Permethrin: Supplemental Information on MRID Nos. 42410001 and 

43505201 Submitted in Response to EPA Goat Metabolism Study Oral Dosing: Lab Project 

Number: HRC/ISN 248/92021SUP1. Unpublished study prepared by Jealott's Hill Research 

Station, Zeneca Ag Products. 49 p. 

43982001 Robinson, R.A., and J.E. Ryan (1996) Anaerobic Aquatic Metabolism of [14C]Permethrin. 

Study performed by XenoBiotic Laboratories, Inc. Plainsboro, NJ, and submitted by AgrEvro 

Environmental Health, Monvale, NJ. 

D-21 
MRID Citation Reference 

44020501 Volumes 1-5. Michael W. Hatfield. May 10, 1996. Aquatic Field Dissipation of Permethrin in 

California and North Carolina. Study Sponsor: Agrevo, 95 Chestnut Ridge Road, Montvale, 

New Jersey 07645. Field Phase : American Agricultural Services, Inc., 404 East Chatham 

Street, Cary North Carolina 27511. Analytical Phase: EN-CAS Analytical Laboratories, 2359 

Farrington Point Drive, Winston-Salem, North Carolina 27107, Project #94-0024. 

44135001 Samoil, K. (1996) Magnitude of Residue: Permethrin on Cherry: Lab Project Number: 

05744.94 MI06. Unpublished study prepared by Interregional Research Project No. 4. 473 p. 

44157101 Michael W.H. November 5, 1996. Addendum to Aquatic Field Dissipation of Permethrin in 

California and North Carolina MRID No:44030501. Study Sponsors: Agrevo, 95 Chestnut 

Ridge Road, Montvale, New Jersey 07645. Field Phase: American Agricultural Services, Inc. 

404 East Chatham Street, Cary, North Carolina 27511. Analytical Phase: EN-CAS Analytical 

Laboratories, 2359 Farrington Point Drive, Winston-Salem, North Carolina 27107, Project 

#94-0024. 

44162601 Francis, P. (1994) Permethrin: Magnitude of the Residue Study on Potatoes after Treatment 

with Ambush and Ambush 25W from Trials Carried out in the USA During 1992: Addendum 

to MRID 43343102: Lab Project Number: RR 94 011BADD. Unpublished study prepared by 

Zeneca Western Research Center. 8 p. 

44182701 Thompson, D. (1996) Permethrin: Magnitude of Residue on Cucumber: (Final Report): Lab 

Project Number: PR 05126:05126.92 MSR03: 05126.92 CA54. Unpublished study prepared 

by Interregional Research Project No. 4. 396 p. 

44182702 Thompson, D. (1996) Permethrin: Magnitude of Residue on Squash (Summer): (Final 

Report): Lab Project Number: PR 05127: A5127:05127.92 FL23. Unpublished study 

prepared by Interregional Research Project No. 4. 421 p. 

44196101 Benner, J.; Hamlet, J.; Skidmore, M. (1996) Permethrin: Further Investigation of Residues in 

Liver Following Oral Administration to the Goat and Radiovalidation of Enforcement 

Methods for Analysis of Animal Tissues: Addendum to MRID Nos. 42410001, 43505201 and 

43962801: Lab Project Number:95JH203: RJ2135B. Unpublished study prepared by Zeneca 

Agrochemicals. 50 p. 

44196102 Benner, J.; Mathis, S.; Prevett, A. (1996) Permethrin: Further Investigation of Residues in 

Liver and Kidney Following Dermal Application to Cows: Addendum to MRID 

Nos.43713303 and 43713304 in Response to EPA CBRS Review dated 10/5/95: Lab Project 

Number: 96JH013: RJ2197B. Unpublished study prepared by Zeneca Agrochemicals. 54 p. 

44196103 Earl, V. (1996) Radiovalidation of the Residue Analytical Method for the Analysis of 3 

Phenoxybenzoic Acid (3 PBA) in Animal Tissues: Lab Project Number: 96JH096: RJ2162B. 

Unpublished study prepared by Zeneca Agrochemicals. 37 p. 

44229501 Samoil, K. (1997) Magnitude of Residue: Permethrin on Avocado: Lab Project Number: 

07127: 01727.94 FL82: 01727.95 CA97. Unpublished study prepared by Cornell University; 

University of Florida; and University of California. 584 p. 

D-22 
MRID Citation Reference 

44417801 Crook, S.; Boseley, A. (1997) Residue Analytical Method for the Determination of 3 

Phenoxybenzoic Acid and DCV Monoacid in Products of Animal Origin: Lab Project 

Number: RAM 295/01. Unpublished study prepared by Zeneca Agrochemicals. 33 p. 

{OPPTS 860.1340} 

44417802 Kennedy, S. (1997) Independent Validation of Standard Operating Procedure 41/295/01 

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44428203 Flowers, S. (1997) Field Accumulation Studies on Rotational Crops: Residues of Permethrin 

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D-23 
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D-24 
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D-25 
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