UNITEDSTATES ENVI ONMENTAL PROTECTIONAGENCY WASH NGTON, D.C. 20460 

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OFFEOF PREVENTION,PESTICIDESAND 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 PrintedwithSoyICanda Inkonpaperthat wntalnsatleast5(r#recydedfiberEFFECTS 

### SODIUM CYANIDE (M44) 

### TOPIC 

# AL 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 1990BEAD 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." Wewaived the acute avian studies because Sodium cyanide is a well known toxicant in the human conducting a study with it poses a hazard tothe 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 arerequired. PRECAUTIONARY LABELING 

# 1 "Thispesticide is TOXIC TO WILDLIF 

### ." M-44 Use Restrictions as per their list of July 15, 1993. 

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EFFECTS ON FRESHWATER FISH 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" toRainbow of information abouttheconditions of the study, itwas 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 knownSODIUM CYAN E (M-44) TOPICALSUMMARY 

# 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 theuse of theM-44 Sodium cyanide device. Sodium dyanide is alow 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


### . 

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EFFECTS ONNONTARGET PLANTS

# ~ Due to its use pattern, chemical charact ristics, and low volume, no studies were required under this topic. 

# CEFFECTS 

### (M-44)

ECOLOGI AL EFFECTS PROFILE BIRDS 

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No avian toxicity studies were 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 werewaived. Sodium cyanidewas 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, theusual methods ofcalcu ating "Risk Quotients" cannot be used, becausewe lack the basic toxicity data. Howeve 

### ,we categorized it as "Veryhighly toxic" tobirds based upon the known nature of the oison. 

# i 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 andmammals. (Ifthe this categorization, they may dothe 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 asECOLOGICAL EFFECTS BRANCHDISCIPLINARYR VIEW 

# E SODIUM CYANLDE (M-44) "Supplemental,"it only partly fulfillst reregistrationrequirements. 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

Theuse restrictions do not addre s the problem of protecting endangered species adequately. Theregistrant should add r strictionsthat will implementthe 

### 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 killshavenotbeen reported toEPA for " SinceAPHIS is the registrant, they should provide
DATA GAPS It is recommended that USDA HIS be required to supply nontarget kill data (and allother adversedata) for Sodium as the monitoring componentforreregistration 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 BRANCHDISCIPLINARY

# REVIEW SODIUM CYANLDE (M-44)
"This pesticide isTOXICTO 

### 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 16verteb control agents 

### on threatened and endangered 

### species. 

### U.S.Fish and Wildlife Biological Opinion, March, 1993.ECOLOGICXL EFFECTSBRANCHDISCIPLIWRYREVIEW SODlUM CYANLDE (M-44)



### TABLE A Generic Data Requirements for Alachlor

1. TGAI = Technicalgrade ofthe active ingredient. 2. The usepatterns are coded as follows:A = Terrestrial,feed crop; B = Terrestrial, noncrop; 3. Based onknownthe characteristics ofSodium cyanide and its demonstratedhigh toxicity, guidelines studies are waived.