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 

Decision No.: 47643 I 

Petition No.: NA 

Registration No.: NA 

Regulatory Action: NA 

Risk Assessment Type: NA Case No.: NA 

TXR No.: NA CAS No.: 76-06-2 

MRID No.: NA 40CFR: NA 

FROM: anna Recore, Industrial Hygienist 

Toxicology and Epidemiology Branch 

Health Effects Division (7509P) 

and 

Elizabeth Evans, Environmental Protection Specialist 

Toxicology and Epidemiology Branch 

Health Effects Division (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 & Implementation Branch 4 

Pesticide Re-evaluation Division (7508P) 

Summary and Conclusions 

Yer.Apr.08 

In the 2008 Reregistration Eligibility Decision (RED) for Chloropicrin, EPA identified acute 

inhalation as the main risk of concern for handlers (including persons involved in the application, 

and also persons involved in tarp perforation and removal activities), workers, and bystanders 

(July 9, 2008, EPA 738-R-08-009). The current incident data from IDS (from January 1, 2008 to 

February 19, 20 13) and NIOSH SENSOR-Pesticide (1998-2009) provide support these risk 

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concerns. In part as a result of the RED, on December 1, 2012 the final phase EPA-required 

new safety measures for soil fumigant pesticides (chloropicrin, dazomet, me tam 

sodium/potassium, and methyl bromide) went into effect. These safety measures were instituted 

to increase protection for agricultural workers and bystanders. At the time of this report, there is 

insufficient information available to determine if the newly required safety measures have 

impacted the frequency of incidents occurring since implementation. However, the Agency will 

continue to monitor the incident information and provide an updated review of incident, 

considering pre- and post-mitigation incidents separately, when the information becomes 

available. 

The Agricultural Health Study (AHS) is also a potential source of information associated with 

human health effects associated with certain pesticides. Chloropicrin is not jncluded in the AHS, 

and therefore this study does not provide information for this report. 

Detailed Review 

I. ACTION REQUESTED 

This review is intended to fulfill our requirement to docket summaries of incident data that were 

reported to the Agency, as well as to ensure human incident data and the Agricultural Health 

Study (AHS) are part of the problem formulation phase of registration review. Reports of 

adverse health effects allegedly due to a specific pesticide exposure (i.e. , an "incident") are 

largely self-reported and therefore, generally speaking, neither exposure to a pesticide or 

reported symptom (or the connection between the two) is validated or otherwise confirmed. 

Typically, causation cannot be determined based on incident data. However, incident 

information can be an important source of feedback to the Agency: incidents of severe outcome, 

or a suggested pattern or trend among less severe incidents, can signal the Agency to further 

investigate a particular chemical or product. Observational epidemiology studies relate the risk 

of disease, e.g., cancer, and exposure to an agent such as a pesticide product in the general 

population or specific sub-groups like pesticide applicators. 

II. BACKGROUND 

Chloropicrin is a broad-spectrum fumigant chemical that can be used as an antirrucrobial, 

fungicide, herbicide, insecticide, and nematicide. It is often combined with other fumigants, such 

as methyl bromide, to broaden the pest control spectrum. Chloropicrin, a restricted use pesticide 

(RUP), is used as a pre-plant soil fumigant at agricultural sites, tree replant sites, and 

greenhouses; a warning agent with other soil fumigants including methyl bromide and 

iodomethane; a warning agent in residential structures before sulfuryl fluoride fumigations; and 

an antimicrobial for remedial wood treatment. As a pre-plant soil fumigant, chloropicrin is either 

injected (e.g., by shank) into the soil or applied via drip irrigation. These applications can either 

be tarped or untarped. 

For this evaluation, both OPP Incident Data System (IDS) and the Centers for Disease Control 

and Prevention/National Institute for Occupational Safety and Health (CDC/NIOSH) Sentinel 

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Event 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 (FIFRA) 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 only, 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 IDS 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 19,2013, there were 12 incidents reported 

for single chemical only in the database. One incident was classified 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 involving 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 a e bl 1 M am . IDS M aJor . I . nc1 d ents £ or t e h smg1 e c h em1. c al Chi orop1cnn 

Human Incident Chemical: Chloropicrin I PC Code: 081501 

Incident 

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 inhaled 

the product, causing 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 

antibiotics. He returned to 

work the following day. 

About a week later, he still 

had a cough. He returned to 

MD and was diagnosed with 

chemical pneumonia and 

was Rx steroids and 

antibiotics. He was told not 

to return to work until 

conditions improved . . . *HB-Human MaJor (1fthe person alleged or exh1b1ted symptoms whiCh may have been hfe-threatemng, or resulted m adverse 

reproductive effects or in residual disability) 

b. SENSOR-Pesticides 

The SENSOR-Pesticides database covers 11 states from 1998-2009, although reporting varies 

from state to state. Cases of pesticide-related illnesses are ascertained from a variety of sources, 

including: reports from local Poison Control Centers, state Department of Labor workers' 

compensation claims when reported by physicians, reports from State Departments of 

Agriculture, and physician reports to state Departments of Health. Although both occupational 

and non-occupational incidents are included in the database, SENSOR-Pesticides focuses on 

occupational pesticide incidents, and is of particular value in providing that information. The 

state coordinator at the 11 respective state Departments of Health conducts case follow-up 

activities such as obtaining medical records to verify symptoms and severity. Using standardized 

protocol and case definitions derived from poison center reporting, the state SENSOR-Pesticide 

coordinator enters the incident information into the state-based system which is sent to NIOSH 

annually to be aggregated. 

Chloropicrin 

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A query of SENSOR-Pesticides 1998-2009 indentifies 78 cases, stemming from 31 events, 

involving chloropicrin; 1 0 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. 

Table 2. SENSOR-Pesticides 1998-2009: Reported 

Health Effects for Chloropicrin Cases (N=78) 

Health Effect #of Times Reported 

Dennal 17 

Ocular 57 

Respiratory 63 

Gastrointestinal 34 

Renal 0 

Nervous System 38 

Cardiovascular 4 

Miscellaneous 9 

* Cases may report multiple 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 methyl 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 chloropicrin (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 

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that symptoms most frequently reported (burning, watery eyes and respiratory irritation) are 

consistent with chloropicrin exposure. 

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Table 3. FataVHigb/Moderate Severity Cases for Chloropicrin 

SENSOR-Pesticides 1998-2009 

CaseiD Severity* Year Case Description 

CA17786 Death 2009 While being filled, a 650 # drum ofMBC and chloropicrin ruptured and 

exploded 

NC01015 High 2008 Private applicator trying to unclog disconnected lines on fumigator rig, was 

splashed 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 assistant were transporting a tank car with 16,000 gallons of 

WA02903 High 2008 restricted use pesticide toxicity class l (danger) fumigant by rail to its 

destination, a tank farm 13 miles 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 leaking from the top of the car, down both sides. 

CA08116 Moderate 2000 Brief fume expo, got dizzy loading drums on trailer. work 2 days latersmelled technical chloropicrin leaking from drum 

CA08877 Moderate 2000 No further information provided. 

CA08878 Moderate 2000 No further information provided. 

CA08879 Moderate 2000 No further information provided. 

CA08880 Moderate 2000 No further information provided. 

CA09289 Moderate 2000 No further information provided. 

CA09350 Moderate 2000 No further information provided. 

CA10162 Moderate 2001 No further information provided. 

CA14 189 Moderate 2004 Exposed to chloropicrin gas at work 

CAl 57 54 Moderate 2005 

FL00436 Moderate 1999 Victim removing plastic sheets after fumigation of tomato field with methyl 

bromide. 

FL0044 1 Moderate 1999 Patient was across the street from when the chemical was released. 

FL00448 Moderate 1999 

FL00450 Moderate 1999 

Was across the street from contamination site. Became ill from chemical 

exposure and was taken to ER. 

FL00455 Moderate 1999 

Patient was across the street from the contamjnation site when she became 

ill. 

FL00465 Moderate 1999 Was across the street from contamination site. Experienced repercussions 

from a chemical drift. Suffering long term problems. 

FL00473 Moderate 1999 

She was w g across the street from the contamination site, experienced 

health problems as a result of the chemical drift. 

*SENSOR-Pesticides Severity Index 

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Death Human Fatality 

High Life threatening, requires treatment >5 days lost work/time 

Moderate Involves systemic effects 3-5 days lost work/time 

Minor Symptoms typically resolve without treatment <3 days lost work/time 

c. Agricultural Health Study (AHS) 

The AHS is a high quality, prospective epidemiology study evaluating the link between pesticide 

use and various health outcomes including cancer. The AHS includes private and commercial 

pesticide applicators and their spouses. If there are AHS frndings relevant to a particular 

pesticide going through registration review, the Agency will ensure they are considered in the 

problem formulation/scoping phase of the process and, if appropriate, fully reviewed in the risk 

assessment phase of the process. The AHS includes information on use of 50 different pesticide 

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 Reregistration Eligibility Decision (RED) for Chloropicrin, EPA identified acute 

inhalation as the main risk of concern for handlers (including persons involved in the application, 

and also persons involved in tarp perforation and removal activities), workers, and bystanders 

(July 9, 2008, EPA 738-R-08-009). The current incident data from IDS (from January 1, 2008 to 

February 19, 2013) and NIOSH SENSOR-Pesticide (1998-2009) support these risk concerns. 

On December 1, 2012, newly required new safety measures for all soil fumigant pesticides 

(chloropicrin, dazomet, metam sodium/potassium, and methyl bromide) went into effect. These 

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 chloropicrin were already RUPs), rate 

reductions, use 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. gov I oppOOOO 1 /reregistration/soil_ fumigants/ 

Because the safety measures are only newly implemented (December 1, 20 12), there is 

insufficient information available to determine if the newly required safety measures have 

impacted the frequency of incidents occurring since implementation. However, the Agency will 

continue to monitor the incident information and provide an updated review of incident, 

considering pre- and post-mitigation incidents separately, when the information becomes 

available. 

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The 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 therefore this study does not provide information for this report. 

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