UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

MEMORANDUM 

Date: February 2, 2015 

SUBJECT: Iron Salts: Tier I Review of Human Incidents for Draft Risk Assessment 

PC Code: 034902,050507 

Decision No.: 499562 

Petition No.: NA 

Risk Assessment Type: NA 

TXRNo.: NA 

MRID No.: NA 

DP Barcode: 0425357 

Registration No.: NA 

Regulatory Action: NA 

Case No.: NA 

CAS No.: 10028-22-5, 17375-41-6 

40CFR: NA 

Yer.Apr.08 

FROM: Shanna Recore, Industrial Hygienist ~ n .. " f\. n 

Toxicology 

Health Effects 

and 

Division 

Epidemiology 

(7509P) 

Branch ~ ~ 

and fi.kJ '1J JfJt Elizabeth Evans, Environmental Protection SpecialisW )~· ' 7 1 

/ v Toxicology and Epidemiology Branch '• v ', 

Health Effects Division (7509P) 

THROUGH: David J. Miller, Acting Branch Chief ·' ~;J #$. 62-/eJ '-OI.f 

Toxicology and Epidemiology Branc~1 

Health Effects Division (7509P) 

TO: Matthew Lloyd, Risk Assessor 

Risk Assessment Branch VII 

Health Effects Division (7509P) 

and 

Katherine St. Clair, Chemical Review Manager 

Risk Management & Implementation Branch 2 

Pesticide Re-evaluation Division (7508P) 

Summary and Conclusions 

TEB has been asked to review the incidents in IDS and NIOSH SENSOR-Pesticides and review 

the findings in the AHS for the iron salts preliminary risk assessment. Based on the low 

frequency and mostly low severity of incident cases reported for iron salts in both IDS and 

NIOSH SENSOR-Pesticides, there does not appear to be a concern at this time that would 

Page I of6 
warrant further investigation. The Agency will continue to monitor the incident information and 

if a concern is triggered, additional analysis will be conducted. 

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

human health effects associated with certain pesticides. Iron salts are not included in the AHS, 

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

Detailed Review 

I. ACTION REQUESTED 

Iron salts are being considered under the FQPA-mandated Registration Review program 

established to review, on a 15 year cycle, pesticides for which a Re-registration Eligibility 

Decision has been made. One component of the Agency's Registration Review Program is 

consideration of human incident data. In conjunction with a human health risk assessment based 

on other data sources, such human incident data can assist the Agency in better defining and 

characterizing the risk of pesticides/pesticide products. 

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 

Iron salts are registered for use as herbicides to control moss on lawns, turf, ornamental 

herbaceous plants, woody shrubs and vines. 

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 

Event Notification System for Occupational Risk-Pesticides (SENSOR) databases were 

consulted for pesticide incident data on the active ingredient iron salts (PC Codes: 034902, 

050507). The purpose of the database search is to identify potential patterns in the frequency 

and severity ofthe health effects attributed to iron salts 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. Iron salts is not included in the AHS, and therefore 

this study does not provide information for this report. 

Page 2 of6 
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, 2010 to January 28,2015, there were 3 incident reported for 

single chemical only in the database involving iron salts. These incidents were classified as 

moderate severity (Table 1). There were no additional incidents reported involving more than 

one chemical. 

In Aggregate IDS, from January 1, 2010 to January 20, 2015, there were 18 reported incidents 

involving iron salts. These incidents were classified as minor severity. Overall, there are few 

incidents involving iron salts reported to IDS. 

Page 3 of6 
Table 1. Mo d erate Iron S at 1 I . nc1 d ents m am rom . M . IDS f J anuary 1 , 20 l 0 to J anuary 20 2015 ' 

Human Incidents I Chemical: Iron Salts 1 PC Code: 034902. 050507 

Incident 

Package Incident PC 

Report Date Location Reg Number Product Name Code Incident Description 

An 86 year old male applied the 

product to his lawn. His glove 

broke halfway through the 

application. He finished 

broadcasting the product. 

Afterwards he took a shower and 

changed clothes. For the next 

several days he experienced loss of 

appetite, chills, and shaking. He 

saw the MD who prescribed 

TURF medicine for a UTI which did not 

BUILDER help. He has a history of heart 

02236 1 - ROCHESTER, WITH MOSS bypass/heart condition and 

00009 8/30/2010 NY 000538-00223 CONTROL 050507 hypertension. 

A 76 year old male spread the 

product with a hand spreader. 

Later that night he had irregular 

TURF heart beat and went to the ER. 

BUILDER They observed him and sent him 

022762- WITH MOSS home. His symptoms have 

00001 1/30/201 1 WA 000538-00223 CONTROL 050507 resolved. 

An adult male applied this product 

LILLY to his lawn. He used a rotary 

MILLER applicator but he could taste the 

MOSS OUT dust so he switched to a drop 

PLUS feeder. A couple days later he 

025759- FERTILIZER experienced blisters, erythema, 

00001 7/25/2013 WA 000802-00543 20-2-5 20LB 050507 pruritus, and peeling skin. 

b. SENSOR-Pesticides 

The SENSOR-Pesticides database covers 12 states from 1998-2011, 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 focuses on occupational 

pesticide incidents, and is of particular value in providing that information. A state SENSOR 

contact specialist attempts to follow-up with cases and obtains medical records to verify 

symptoms, circumstances surrounding the exposure, severity, and outcome. Using standardized 

protocol and case definitions derived from poison center reporting, SENSOR coordinators at 

State Departments of Health enter the incident interview description provided by the case, 

medical report, physician and patient into the SENSOR data system. The SENSOR data system 

is accessible to participating states and EPA. 

Page 4 of6 
A review of SENSOR-Pesticides from 1998-2011 identifies a total of 33 single active ingredient 

(ai) cases involving iron salts (pc codes 034902 and 050507), stemming from 33 separate events. 

Thirty one of these cases were reported from Washington State. Thirty of the cases were not 

work-related. Twenty-six of these 33 cases were applying or mixing/loading the product. Most 

cases involved the applicator (mainly homeowner applicators) applying the moss product to their 

lawn and having ocular exposure from spray, spill, or splash. 

One case was high in severity, four cases were moderate in severity, and 28 cases were low in 

severity. Ocular symptoms were the most frequently reported symptoms (n=25); 23 of the 25 

cases with ocular symptoms reported eye pain/irritation/inflammation. The reported effect are 

reported in Table 2. 

Table 2. SENSOR-Pesticides 1998-2011 

Reported Health Effects for Iron Salt Cases 

(N=33) 

Health Effect # ofTimes Reported 

Ocular 25 

Respiratory 9 

Nervous System 6 

Dermal 5 

Gastrointestinal 3 

Cardiovascular 3 

Renal 0 

* Cases mav report multiple health effects 

The one high severity case is the most recently reported case in the SENSOR database, it 

occurred in Washington in 2010. The case was mixing/loading two products: Lilly/Miller 

MossOUT (Reg No 802-509) and 30-Seconds (Reg. No 87429-1). The case description states, 

He had used 213 of the 30-sec product already and had some MossOUT concentrate mixed with some water 

in a hand sprinkler container. He decided to miv: them. He added 30-sec then a cloud puffed up in his nose 

on his skin. " 

He then experienced shortness of breath and coughing. The case also reports preexisting health 

conditions including: coronary artery disease, hypertension, dyslipidemia, and hypothyroidism. 

This case has a "prevention code" that is "mixing of incompatible products." This high severity 

case also includes a prevention narrative. 

The case stated in his interview with SENSOR that "you can't prevent if people won't read the label" (he 

didn't read until afteJ). "But if they put a skull and crossbones to get your attention, that might have 

helped." In ve1y fine print, 30 seconds label cautioned against mixing with other household chemicals. He 

mixed 2 moss killing products together. 30 seconds label recommends wearing protective clothing to 

protect c/othingfrom bleaching. Moss out label cautions to wear safety glasses. 

The case descriptions for the moderate cases are listed in Table 3. 

Page 5 of6 
Table 3. SENSOR-Pesticides 1998-2011 

Moderate Severity Iron Salt Case Descriptions 

Case 10 Case Description 

WA01719 A 46 y/o male was helping his neighbor treat his property 

to control moss. He "accidentally got some chemical in his 

eye".· 

WA01407 An 83 y/o male applied a moss control product with a hose 

end applicator. While unloosening the container it dropped 

from his 

WAOlllS Gas was generated when two compounds were mixed 

NY01695 While applying product, she believes that she inhaled the 

granules. No skin exposure, case states that she was 

wearing long sleeves and pants. 

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 findings 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. 

Iron salts are not included in the AHS, and therefore this study does not provide information for 

this report. 

IV. CONCLUSION 

Based on the low frequency and mostly low severity of incident cases reported for iron salts in 

both IDS and NIOSH SENSOR-Pesticides, there does not appear to be a concern at this time that 

would warrant further investigation. The Agency will continue to monitor the incident 

information and if a concern is triggered, additional analysis will be conducted. 

Page 6 of6