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UNITED STATES ENVI ONMENTAL PROTECTION AGENCY 

WASH T NGTON, D.C. 20460 

OFFEOF 

PREVENTION, PESTICIDES AND 

TOXK: SUBSTANCES 

MEMORANDUM 

Subject: EEBrs chapters fo 074002) 

RED 

From: Anthony Maciorows 

/4 6-20.? 7 

Ecological Effects 

~nvironmental ~atg and Effects Division (7507C) 

To : Kathryn Davis 

Product Manager 5 

Special Review an Reregistration Division 75088 

We have prepared our Registration 

Eligibility Document for 

The documents are at ached. Please contact Dr. 

James J. Goodyear at 305- 726 if you have any questions. 

Recycled/Recydeble 

Printed with SoyICanda Ink on paper that 

wntalns at least 5(r#recyded fiber 
EFFECTS 

SODIUM CYANIDE (M44) 

TOPIC A L SUMMARY 

The registrant, volume waivers for ecological effects teestiing 

of its end-use Product, the cyanide capsule for killing Coyotes and other 

carnivores that depredate of 1990 BEAD concurred with their request 

for waivers for the end use product. 

EFFECT ON BIRDS 

No studies were received under this top c. il 

Sodium cyanide as a "Violentpoison." We waived 

the acute avian studies because Sodium cyanide is a well known toxicant 

in the human conducting a study with it poses a hazard 

to the Sodium cyanide as "Very highly 

Because of its use pattern and its characteristics (rapid degradation) 

we do not feel that Sodium cyanide hazard to birds. We have waived the 

Avian dietary study requirements No further avian studies are required. 

PRECAUTIONARY LABELING 1 

"This pesticide is TOXIC TO WILDLIF ." M-44 Use Restrictions as per their list of July 

15, 1993. 

EFFECTS ON FRESHWATER FISH 

L 

INVERTEBRATES 

One study was evaluated under this The study was done by EPA's Animal Biology 

Laboratory in 1977. It partially requirement for the TG in support of the TEP 

("M-44"). This study used the Sodium Cyanide Balls" (EPA Registration 

Number 430-01) and Rainbow nzykiss) . The chemical was categorized 

as "Highly toxic" to Rainbow of information about the conditions 

of the study, it was study is listed below: 

APHIS requested waivers for further 

volume. We agreed to these waivers. 

aquatic testing because of its use pattern and low 

Based on the existing study and the known 
SODIUM CYAN E (M-44) TOPICAL SUMMARY 7 

characteristics of Sodium cyanide, we ill consider it to be "Very highly toxic" to aquatic 

organisms for the purpose of risk 

PRECAUTIONARY LABELING 

"Keep out of lake, ponds, or streams. o not contaminate water by cleaning of equipment 

or disposal of wastes." M-44 Use ictions as per their list of JulylS, 1993. 

SECONDARY POISONING 

APHIS presented evidence (their nce in finding nontarget kills, the distribution of 

Sodium cyanide in the body of a animal, and the fate and distribution of Sodium 

cyanide in the environment) that ry poisoning would not be expected with Sodium 

cyanide. We found that they had that secondary poisoning is unlikely in the use of 

the M-44 Sodium cyanide device. Sodium dyanide is a low volume pesticide and 

its prevalence in the Therefore, the requirements for studies on 

secondary poisoning were waived. 

EFFECTS ON ESTUARINE AND IWU@E ORGANISMS 

No studies were required under this topi . ! 

EFFECTS ON NONTARGET PLANTS ~ 

Due to its use pattern, chemical charact ristics, and low volume, no studies were required 

under this topic. C 
EFFECTS 

(M-44) 

ECOLOGI AL EFFECTS PROFILE 

No 

BIRDS 

avian toxicity studies were 

C 

wed. The Avian acute oral toxicity studies were 

waived because of low volume and the known characteristics of Sodium 

cyanide. Cyanide was toxic to birds on an acute oral basis. 

Because of its use (rapid degradation) the Avian 

dietary studies were waived. 

AQUATIC ORGANISMS 

One study done by EPA's Anima Biology Laboratory in 1977 was accepted as 

supplemental. All other aquatic studi s were waived. Sodium cyanide was characterized 

as "Very highly toxic" to aquatic or 1 anisms. 

Because of its low volume f production and since the Merck Index (1987) 

characterized Sodium cyanide as a Violent poison," we waived the avian studies. 

Therefore, the usual methods of calcu ating "Risk Quotients" cannot be used, because we 

lack the basic toxicity data. Howeve , we categorized it as "Very highly toxic" to birds 

based upon the known nature of the i oison. 

NONTARGET PLANTS 

Due to its use pattern and low volume, 

Any animal that device's release catch will get a dose of Sodium 

cyanide in the mouth'and die. though the standard Risk Quotient calculations 

cannot be made, Sodium cyanide nsidered to be a high acute risk pesticide for terrestrial vertebrates. This exceeds of Concern" for nontarget and endangered 

birds and mammals. (If the this categorization, they may do the avian 

studies and present the results). 

no studies are required under this topic. 

AQUATIC RISK CHARACTERIZA ION I 

One study was done by EPA's Anim Biology Laboratory in 1977. The chemical was 

categorized as "Highly toxic" to inbow trout, but, since it was categorized as 
ECOLOGICAL EFFECTS BRANCH DISCIPLINARY R E VIEW SODIUM CYANLDE (M-44) 

"Supplemental," it only partly fulfills t reregistration requirements. A waiver has been 

granted for the remaining studies. A Quotient for aquatic organisms is considered 

irrelevant due to the nature of the product and its use. 

MITIGATION 

APHIS has submitted a list of 26 "Use Restrictions." Some of these restrictions serve 

to mitigate the environmental risk of S dium cyanide. Other restrictions address other 

concerns. The restrictions will redu e the risk to nontarget terrestrial and aquatic 

animals and to endangered species. I 

The use restrictions do not addre s the problem of protecting endangered species 

adequately. The registrant should add r strictions that will implement the U.S. Fish and 

Wildlife Service Biological Opinion (U S. D. I., 1993). These restrictions should be on 

the label even if APHIS does not curr ntly use the M-44 in those areas, because the 

Coyote is expanding its range rapidly. i 

Even given these restrictions, M-44 will kill nontarget animals. APHIS has 

supplied a table of the number of reported taken by the M-44 in the Federal 

Cooperative ADC program from through September 1986. The list includes 

2071 skunks, 1191 opossums, 257 Kit foxes, 158 Swift foxes, and 412 

"other." The table does not that, at other times and places, would be 

considered targets, e. g., for coyotes. These kills have not been 

reported to EPA for " Since APHIS is the registrant, 

they should provide 

DATA GAPS 

It is recommended that USDA HIS be required to supply nontarget kill data 

(and all other adverse data) for Sodium as the monitoring component for reregistration of the M-44. The methods that they use in their usual annual 

report will be sufficient, except include the wild canids that are 

killed while they are attempting and the occurrence of more 

than one kill at a single station. 

It is recommended that USDA AP data using EEB's computerized incident data base. This kill will be used to judge the relative 

magnitude of nontarget mortalities. Th and manual have already been 

sent to them. 
ECOLOGZCXL EF~CTS BRANCH DISCIPLINARY REVIEW SODIUM CYANLDE (M-44) 

"This pesticide is TOXIC TO E. Keep out of lakes, ponds, or streams, Do not 

contaminate water by or disposal of wastes." M-44 Use 

Restrictions as per their 

Li erature Cited \ 

U.S.D.I. 1993. Effects of 16 verteb control agents on threatened and endangered 

species. U.S. Fish and Wildlife Biological Opinion, March, 1993. 
ECOLOGICXL EFFECTS BRANCH DISCIPLIWRY REVIEW SODlUM CYANLDE (M-44) 

TABLE A 

Generic Data Requirements for Alachlor 

1. TGAI = Technical grade of the active ingredient. 

2. The use patterns are coded as follows: A = Terrestrial, feed crop; B = Terrestrial, noncrop; 

3. Based on known the characteristics of Sodium cyanide and its demonstrated high toxicity, guidelines studies are waived.