UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

MEMORANDUM Date: August 29, 2013 SUBJECT: Chloropicrin: Review of Human Incidents PC Code : 08 I 50 I DP Barcode: 0414490 Dec ision No.: 47643 I Pe tition No.: NA Registration No .: NA Regulatory Action: NA Case No .: NA Risk Assessment Type: NA TXR No.: NA CAS No.: 76-06-2 40CFR: NA MRID No.: NA FROM:

# anna Recore, Industrial Hygienist Toxicology and Epidemiology Branch Health Effects Di vision (7509P) and Elizabeth Evans, Environmental Protection Special i st Toxicology and Epidemiology Branch Health Effects Di v ision (7509P) THROUGHfbavid J. Miller, Acting Branch Chief 

# J./t. Toxicology and Epidemiology Branch /. Health Effects Division (7509P) TO: Shalu Shelat, Risk Assessor Risk Assessment Branch VI Health Effects Division (7509P) and Andrea Mojica, Chemical Review Manager Risk Management & Imp lementation Branch 4 Pesticide Re-evaluation Division (7508P) Summary and Conclusions Yer.Apr.08

In the 2008 Reregistration Eligibility Decision (RED) for Chlorop i crin, EPA identified acute inhalation as the main risk of concern for handlers (including persons involved in the ap plica tion, and also persons involved in tarp perforation and removal activities), workers, and bys tand ers (July 9, 2008, EPA 738-R-08-009)
. The current incident data from IDS (from January 1, 2008 to February 19 , 20 13) a nd NIOSH SENSOR-Pesticide (1998-2009) provide s u pport these ri s k Page 1 of9concerns . In part as a result of the RED, on December 1, 2012 the final phase EPA

-required new safety measures for soil fum igant pesticides (chloropicrin , dazomet , metam sod ium /potas s ium , and methyl bromide) went into effect. These safety meas ures were in stituted to i ncrease protec ti on for agricult ural workers and bystanders. At the t ime of t his re port , there is in suffic ient informat ion availa b l e to dete rmin e if the new ly requ ired safety measures hav e impacted the frequency of incidents occurring s ince implementation. However , the Agency w ill continue to monitor the incident information and provide an updated review of in cident , co nsidering pre- and post-mitiga tion incidents se parately , when the information becomes available. The Agricu ltura l Health Study (AHS) is also a potential so urce of inf o rm atio n associ ated w i th human health effects associated w it h certain pesticides. C hloropicrin i s n ot jncluded in the AHS, and there fo re this study does not provide inf ormation for this report.
Detailed Review I. ACTION REQUESTED This review i s intended to fu lfill our requirement to docket summaries of incident data that were reported to th e Ag en cy , as well as to ensure hum an incident data a nd the Agricultural Health Study (AHS) a re part of th e problem fo rmul ation ph ase of registration revi e w . Reports o f adv erse health effects a ll egedl y due to a specific pesticide ex po sure (i.e. , an " in c ident ") are largely self

- reported and therefore, generally speaki ng, nei th er exposure to a pestic id e or reported symptom (or the connection between the two) i s validated or otherwise confirmed. Typically, causation cannot be determined based on inci d ent data
. H owever , incident information can be an important so ur ce of feedback to the Agency: i nc id e nts o f severe outcome, or a suggested pattern or trend among less severe incidents , can signal the Agency to further investigate a particular c h emical or produ ct. Ob servati o nal epi d emio l ogy studies relate the risk o f disease, 

### e.g., canc e r, and exposure to an age nt suc h as a pesticide p roduct in the ge neral population or specific sub-g ro ups like pe stic id e ap pli cato rs. II. BACKGROUND C hloropicrin i s a broad-spectrum fumigant che mical that can be used as an antirrucrobial , fu ngicide, herbicid e, i n sect ici de, and nematic id e. It i s often combin e d with other fumigants, suc h as methyl bromide, to broaden the pest contro l spectrum. Chloropicrin , a restricted use pesticide (RUP), is u sed as a pre-plant soi l fumigant at agricu ltural sites, tre e rep lant sites , and g re e nhou ses; a warning age nt w ith other so il fu mi gant s including methy l bromide and iodomethan e; a warning agent in residential s tructures before su lfuryl fluoride fumigations ; and an antimi crobial for remedial wood treatment. As a pre-plant so il f umi gant , c hloropicrin is either injecte d (e.g. , by shank) in to the soil or app li ed v ia drip irrigation. Th ese applications can eith er be tarped or untarp e d. For thi s e v aluatio n , both OPP I ncident D ata Syste m (IDS) and the Centers for D isease Co ntrol an d Prevention/National Insti tute for Occupational Safety and H ealth (CDC/N IOSH) Sentinel

Page 2 of9Event Notification System for Occupational Risk-Pesticides (SENSOR) databases were consulted for pesticide incident data on the active ingredient chloropicrin (PC Code: 081501 ). The purpose of the database search is to identify potential patterns in the frequency and severity of the health effects attributed to chloropicrin exposure. In addition, findings from the Agricultural Health Study (AHS) were reviewed. The AHS is a high quality, prospective epidemiology study evaluating the link between pesticide use and various health outcomes including cancer. Chloropicrin is not included in the AHS, and therefore this study does not provide information for this report.


### III. RESULTS/DISCUSSION a. IDS (Incident Data System) OPP's IDS includes reports of alleged human health incidents from various sources, including mandatory Federal Insecticide , Fungicide and Rodenticide Act (FI FRA) Section 6(a)(2) reports from registrants, other federal and state health and environmental agencies, and individual consumers. Since 1992 , OPP has compiled these reports in IDS. IDS contains reports from across the U.S
. and most incidents have all relevant product information recorded. Reports submitted to the IDS represent anecdotal reports or allegations onl y , unless otherwise stated in the report. IDS records incidents in one of two modules: Main IDS and Aggregate IDS:
o Main IDS contains incidents resulting in higher severity outcomes and provides more detail with regard to case specific. This system stores incident data for death, major and moderate incidents, and it includes information about the location, date and nature of the incident. Main ID S incidents involving only one pesticide are considered to provide more certain information about the potential effects of exposure from the pesticide.
o Aggregate IDS contains incidents resulting in less severe human incidents (minor, unknown, or no effects outcomes)
. These are reported by registrants only as counts in what are aggregate summaries. For the Main IDS , from January 1, 2008 to February 19 ,2 013 , there were 12 incidents reported for single chemical only in the database. One incident was c l assified as major severity; six incidents were classified as moderate severity; four incidents were classified as minor severity; one incident was unspecified classification
. The major incident is described further in Table 1. There were 30 additional incidents reported invol ving more than one chemical. Overall, there are few incidents involving chloropicrin reported to IDS. In Aggregate IDS, from January 1, 2008 to February 19,2013, there were 18 reported incidents involving chloropicrin
. These incidents were classified as minor severity.

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### T bl 1 

### M
. ID S 

### M
. I .d 

## £ h a e am aJor nc1 ents or t e smg1 e ch
. al Chi em 1 c orop1cnn Human Incident Che mical: Ch loropicrin 

## I PC Code: 081501 Inc ident Package Incident Reg Exposure Report Date Location Number Product Name Severity* Incident Description 021202 8/17/2009 BRANDON, 075341- TIMBERFUME HB A 50 year old male applied

- 00001 OR 00003 the product to a utility pole by injection into a drilled hole
. While he was hammering the plug into the hole the product splashed out and hitting the male in the chest area . He in haled the product , caus i ng hi eyes to water, nose to run , and burning in his lungs
. He became nauseous , dizzy , and vomited. He was diagnosed with low oxygen levels and prescribed a ntibiotics. He returned to work the following day
. About a week late r, he still had a cough. He retu rned to MD and was diagnosed with chemical pneumonia and was Rx steroids and antibiotics
. He was told not to return to work until conditi ons improved
.
. . *HB-H uman MaJ o r (1ft he p erson alleged or exh1b1ted sym ptoms w h iCh may ha ve been h f e-t

hreate mng , or resu lted m a dver se r e pro ductive effects or in res i d ual di s a b ility) 

### b. SENSOR-Pesticides The SENSOR

-Pe s ticides database covers 11 states from 1998-2009 , although reporting varies from state to state. Cas e s of pesticide-related illnesses are ascertained from a variety of source s, including: report s from l ocal Poison Control C e nters , state Department o f Labor workers ' compensation claim s when reported by physician s, reports from Stat e Departments of Agriculture , and phy s ician reports to state Departments of H ealth. Although both occupational and non- occupational incidents are included in the data b ase, SENSOR-Pesticides focuses on occupational pesticide incident s, and is of particular value in providing that information. The state coordinator at the 11 respective state Departments of H ealth conducts case follow-up activ ities such as obtaining medical records to verify symptoms and severity. Using standardized protocol and case definitions derived from poison center reporting , the s tate SENSOR-Pesticide coordinator enters the incident information into the state-based system which is sent to NIOSH annually to be aggre g ated. 

### Chloropicrin
Page 4 of9A query of SENSOR-Pesticides 1998-2009 indentifies 78 cases, stemming from 31 events, involving chloropicrin; 10 cases are single ai and 68 are multiple ai cases. There was one case fatality; two cases were high in severity; 25 cases were moderate in severity; and 50 cases were low in severity. A summary of reported health effects is provided in Table 2. Case descriptions for fatal, high and moderate cases are provided in Table 3.

Tab l e 2
. SENSOR-Pesticides 1998-2009: Reported Health Effects for Chloropicrin Cases (N = 78)

Health Effect #ofTimes Reported Dennal 17 Ocular 57 Respiratory 63 Gastrointestinal 34 Renal 0 Nervous System 38 Cardiovascular 4 Miscellaneous 9 

### * Cases may report mu ltiple health effects Multiple case events In Florida in 1999, 31 individual cases were reported for one exposure event. Employees working at or near a tomato packing house received varied levels of exposure resultant from a MeBr/chloropicrin spill and drift
. All3 1 cases were low in severity and symptoms included respiratory irritation, headache and burning eyes. Chloropicrin and MeBr Because chloropicrin and methy l bromide are often co-formulated, the symptoms of these cases were reviewed to determine if the symptoms reported could be distinguished as attributable to either chloropicrin or methyl bromide. Fifty seven of the 78 cases involve chloropicrin and methyl bromide (6 cases involve chloropicrin and methyl bromide and 5 cases involve chloropicrin and sulfuryl flouride). Of the 57 cases involving exposure to both methyl bromide and chloropicrin, there was one fatality, 20 moderate severity cases and 36 low severity cases . The fatality occurred in California in 2009 when a handler was filling a drum of methyl bromide and chlorop i crin (product name Helena MBC-33; EPA reg# 8853-3) and it ruptured and exploded. Regarding the cases of methyl bromide and chloropicrin exposure, the most commonly reported health effects involved the eye (n=46) such as eye irritation and lacrimation, also respiratory effects (n=46) including upper respiratory pain and cough. Of the 57 methyl bromide and chloropicrin cases, 29 reported a nervous system effect, generally a headache. Although it is difficult to determine which active ingredient was responsible for the health effects, it appears Page 5 of9that symptoms most frequently reported (burning, watery eyes and respiratory irritation) are consistent with chl oropicrin exposure.

Page 6 of9Table 3. FataVHigb/Moderate Severity Cases for Chloropicrin SENSOR-Pesticides 1998-2009 CaseiD Severity* Y ear Case Description CA 177 86 D eath 2009 Whil e being fi lled, a 650 # drum ofMBC and chloropicrin ruptured and explode d
NC01015 High 2008 Pri vate applicator trying to unclog d is connected lines on fumigator rig, was spl ashe d in eyes by fumigant left in lines .
A 32 y/o male switchman foreman , a 46 y/o locomotive engineer, and a 34 y/ o switchman a ss i stan t were tran sporting a tank car with 16, 000 gallons of WA02903 High 2008 restricted use pesticide tox icity class l (danger) fumigant by rail to its destination , a t ank farm 13 m iles from the rail yard
. All three men noticed an odor at times during the 3-hour ride
. In the fmal30 minutes of the trip, stain marks were observed l eaking from the top ofthe car, down both sides
. CA08 1 16 Moderate 2000 B rief fume expo, got di zzy loading drums on trailer
. work 2 days la ter
smelle d tech nical chloropicrin leaking from drum CA08877 Moderate 2000 No further information provided
. CA08878 Moderate 2000 No further information provide d
. CA08879 Moderate 2000 No further information provided. CA08880 Moderate 2000 No further informat i o n provided
. CA09289 Moderate 2000 No further information provided. CA09350 Moderate 2000 No further information p rovided
. CA10162 Moderate 2001 No further inf ormation provided.
CA1 4 1 89 Moderate 2004 Expo sed to chloropicrin gas at work CA l 57 54 Moderate 2005 FL00436 Moderate 1 999 V icti m removing plastic sheets after fumigation of tomato field with methyl bromide
. FL0044 1 Moderate 1999 Patient was across the street from when the chem ical w as released. FL00448 Moderate 1 999 FL00450 Moderate 1999 Was across the street from contamin ation site
. Became ill from c h emica l exposure and was taken to E R
. F L00455 Moderate 1999 Patient wa s across the street from the co ntamjnation site when she became ill. FL00465 Moderate 1 999 Was across th e street from contamination site
. Ex perienced repercussions from a c hemical drift. Suffering l ong term problems. FL00473 Moderate 1999 S he w as w g across the street from the contamination site, experie nce d health problems as a result of the chemica l drift
. *SENSOR-Pesticides S e verity I ndex


### Page 7 of9Death Human Fatality High Life threatening, requires treatment >5 days lost work/time Moderate Involve s sys temi c effects 3-5 days lost work/time Minor Symptoms typ ically resolve without treatment <3 days lost work/time


### c . Agricultural Health Study (AHS) The AHS is a high quality, prospective ep id emio lo gy study evaluating the link between pesticide use and various health outcomes including cancer. The AHS includes private and commercial pesticide applicators and their spouses. 

### Ifthere are AHS frndings relevant to a particular pesticide going through registration re view, the Age nc y will ensure they are considered in the problem formulation/sco ping phase of the process and, if appropriate , fully reviewed in the ri sk assessment phase of the process. The AHS includes information on use of 50 different p est icide active ingredients commonly used in agriculture. Chloropicrin is not included in the AHS , and therefore this study does not provide information for this report. 

### IV
. CONCLUSION In the 2008 Rere gistration Eligibility Deci s ion (RED ) for Chloropicrin, E PA identified acute inhalation as the main risk of concern for handlers (including persons involved in the application, and also pers ons involved in tarp perforation and remo val activi ties), workers, and bystanders (July 9, 2008, EPA 738

- R-08-009). The current incident data from ID S (f rom January 1, 2008 to February 19 , 2013) and NIOSH SENSOR

- Pesticide (1998

-2009) support these risk concern s . On December 1 , 2012, newly required new safety measures for all soil fumigant pesticides (chlorop icrin , dazomet, metam sodium/potassium, and methyl bromide) went into effect. The se new safety requirements were implemented to increase protection for agricultural workers and bystanders. These safety measures include designation as a Restricted Use (metam sodium/potassium and dazomet only: methyl bromide and chloropi c rin were already RUP s), rate reductions, us e site limitations, applicator training, and buffer zones around all treated fields. For more information on the new soil fumigant safety requirements visit: http: // www. epa. govIoppOOOO 1 /reregistration/ so il
_fumigants/ Because the safety meas ures are only newly implemented (December 1 , 20 12) , there is insufficient information a v ailable to determine if the newly require d safe ty measures have impacted the frequency of incidents occurrin g s ince implementation. However, the Agency will co ntinue to moni t or the inc ident information and provide an updated review of incident , considering pre- and post-mitigation incident s separately, when the information becomes available
. Page 8 of9The Agricultural Health Study (AHS) is also a potential source of information associated with human health effects associated with certain pesticides. Chloropicrin is not included in the AHS, and therefo re this study does not provide information for this report.

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