UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

MEMORANDUM 

Date: March 21,2013 

SUBJECT: Sulfur: Updated Review of Human Incidents 

PC Code: 07750 I DP Barcode: D41 0259 

Decision No.: 470688 

Petition No.: NA 

Risk Assessment Type: NA 

TXRNo.: NA 

MRIDNo.: NA 

Registration No.: NA 

Regulatory Action: NA 

Case No.: NA 

CAS No.: 7704-34-9 

40CFR: NA 

FROM: Shanna Recore, Industrial Hygienist fa 

Toxicology and Epidemiology Branch ~~~ Health Effects Division (7509P) 

and 

Elizabeth Evans, Environmental Protection Specialist 

Toxicology and Epidemiology Branch 

Health Effects Division (7509P) 

Ver.Apr.08 

THROUGH: David Miller, Acting Branch Chief -/~) fifi( ~I-IJ'hV-liJ!J Toxicology and Epidemiology Bran~<h Health Effects Division (7509P) 

TO: Kelly O'Rourke, Risk Assessor 

Risk Assessment Branch IV 

Health Effects Division (7509P) 

and 

Jose Gayoso, Chemical Review Manager 

Risk Management & Implementation Branch II 

Pesticide Re-evaluation Division (7508P) 

Summary and Conclusions 

Sulfur incidents were previously analyzed in 2009 (S. Winfield and M. Hawkins, 1/28/2009, 

Sulfur; Updated Incident Report, D346953). In this review, there were 10 single chemical 

incidents identified in Incident Data System (IDS) from 2000 to 2008; there were 958 incidents 

identified in Poison Control Center Data from 1993 to 2005; there were 63 incidents identified in 

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CA PISP data from 2002-2006; and 189 incidents were reported to Centers for Disease Control 

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

Event Notification System for Occupational Risk-Pesticides (SENSOR) data from 1998 to 2005. 

Winfield and Hawkins concluded that “based on review of incident data from the IDS, AAPCC, 

PISP and SENSOR databases, the risk posed to human health by sulfur appears low. Across the 

databases, the relative number of reported incidents was low, the severity of reported health 

effects was low, and for most databases the dermal, ocular and respiratory symptoms/health 

effects were reflective of the known irritating properties of sulfur. The incident information 

supports the risk conclusions in the RED and the EPA poisoning manual, which states that sulfur 

has irritating properties but it is a relatively low mammalian toxicity pesticide.” 

This updated incident report includes analyses of incidents reported to the Main and Aggregate 

IDS from January 1, 2009, to January 24, 2013 and from incidents reported to NIOSH 

SENSOR-Pesticides database from 2006-2009. The results are consistent with the previous 

analyses. The results are as follows: 

 For the Main IDS, from January 1, 2007 to September 4, 2012, there was 1 incident 

reported for single chemical only in the database and 16 additional incidents reported 

involving more than one chemical. The single chemical incident was classified as 

moderate severity. 

 In Aggregate IDS, from January 1, 2007 to September 4, 2012, there were 43 reported 

incidents involving sulfur. These incidents were classified as minor severity. 

 A query of the SENSOR-Pesticides dataset from 2006-2009 (years of additional data 

subsequent to the previous analysis) identified a total of 50 reported cases involving 

the single active ingredient sulfur; 40 additional cases involved multiple active 

ingredients. Of the 50 single AI cases, 33 were low in severity, 16 were moderate in 

severity and 1 case was high in severity. 

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

associated with the human health effect associated with certain pesticides. Sulfur is 

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

this report. 

In summary, based on the continued low frequency and severity of incident cases reported for 

sulfur, HED concurs with the previous conclusion and 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. 

Detailed Review
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I. ACTION REQUESTED 

Sulfur is a pesticide 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. This review is intended to provide an 

update to the previously prepared incident report (S. Winfield and M. Hawkins, 1/28/2009, 

Sulfur; Updated Incident Report, D346953). 

II. BACKGROUND 

 

The element sulfur is a ubiquitous, natural component of the environment. Currently, sulfur is 

registered by EPA for use as an insecticide, fungicide and rodenticide on several hundred food 

and feed crop, ornamental, turf and residential sites. It is also used as a fertilizer or soil 

amendment for reclaiming alkaline soils. Sulfur is applied in dust, granular or liquid form. 

For this evaluation, both the OPP IDS and NIOSH SENSOR databases were consulted for 

pesticide incident data on the active ingredient sulfur (PC Code 077501). The purpose of the 

database search is to identify potential patterns in the frequency and severity of the health effects 

attributed to sulfur exposure. 

III. RESULTS/DISCUSSION 

a. IDS 

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. 

 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. 

 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. 
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For the Main IDS, from January 1, 2007 to September 4, 2012, there was 1 incident reported for 

single chemical only in the database and 16 additional incidents reported involving more than 

one chemical. The single chemical incident was classified as moderate severity and is described 

further in table 1. 

Table 1: Main IDS Incidents Involving the Single Chemical Sulfur 

Human Incidents Chemical: Sulfur PC Code: 077501 

Incident 

Package 

Report

Incident 

Date Location

Registration 

Number Product Name

Exposure 

Severity* Incident Description

022249 - 

00001 6/5/2010 CA 000802-

00016 

LILLY 

MILLER 

SULFUR 

DUST 1 LB 

HC 

Unknown age adult female 

used product on roses. It 

was windy and she may 

have inhaled some 

product. Within 8 hours she 

experienced a chest cold, 

dry nose, scratchy throat 

and loss of sense of smell. 

Two months later she 

reports that all the 

symptoms are improving 

except for her sense of 

smell. She went to MD who 

does not know the cause of 

her symptoms. 

* Severity Categories 

H-C Human Moderate Moderate (if the person alleged or exhibited symptoms more pronounced, more prolonged 

or of a more systemic nature than minor symptoms; and involved some form of treatment, 

even though symptoms were not life threatening and the person returned to his/her preexposure state of health with no additional residual disability) 

from 40 CFR § 159.184 

In Aggregate IDS, from January 1, 2007 to September 4, 2012, there were 43 reported incidents 

involving sulfur. These incidents were classified as minor severity. 

b. NIOSH SENSOR 

The NIOSH-led 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. 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 
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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. 

A query of the SENSOR-Pesticides dataset from 2006 to 2009 identifies 90 cases involving 

sulfur (PC Code 077501); 40 of which involve multiple active ingredients (AI) and 50 involve 

single AI cases. The 50 single AI cases will be analyzed in this section. Of these 50 cases, 47 

were work-related. Ten of the 50 cases are attributable to drift from sulfur applications. At least 

9 cases, up to 17 cases, involved grape/vineyard workers in California. 

Of the 50 single AI cases, 33 were low in severity, 16 were moderate in severity and one was 

high in severity. The high and moderate severity case descriptions from 2006-2009 are provided 

in Table 2. The high severity case mixed mothballs and sulfur powder in the residence. 

Table 2. SENSOR-Pesticides 2006-2009: High/Moderate Severity Sulfur Case Descriptions 

ID Year High Severity Case Description 

FL02347 2007 Female mixed mothballs and sulfur powder and spread around house to kill snakes. 

ID Year Moderate Severity Case Descriptions 

CA14574 2006 While driving an open cab onion harvester, she was exposed to a cloud of sulfur dust 

from an application to a nearby field. 

CA14699 2006 Patient was cutting liquid sulfur and with safety glass it still splashed into both eyes 

CA15136 2007 Developed pain in his eye after spraying barrels with sulfur 

CA15145 2007 Working in field and felt something in his eyes 

CA15228 2006 Entered field after REI had expired but still got sick 

CA15235 2006 Drift from helicopter application. Workers at children's camp exposed 

CA15243 2007 Line ruptured, burning him with steam and sulfur 

CA15382 2007 Loading a truck and sulfur blew into eyes 

CA15610 2007 Exposed to sulfur fumes at work 

CA15611 2008 Spilled bucket of liquid sulfur on head while spraying on tractor 

CA15634 2008 Mixing wettable sulfur, powder flew up into his eyes 

CA15853 2006 Was trimming vines, was exposed to sulfur 

CA16032 2008 Opened a vat to check on grapes, inhaled sulfur 

CA16829 2009 Tying a wire around grape vines when the wind blew powder off the leaves into his 

face and eye 

CA17778 2009 Exposed to burning sulfur while loading a duster plane 

WA02421 2007 A 22 y/o farmworker felt drift from a pesticide application to apples as he dug a 

well. An hour later he experienced gastrointestinal symptoms. 

The high severity case experienced a burning sensation to the skin and face while mixing the 

products, then burning to the eyes and throat after spreading the products around the home. 

Twenty cases experienced ocular exposures (splash, spray, or dust in the eye). Among all cases, 

eye pain/irritation/ inflammation was the most commonly reported symptom. A breakdown of 

symptoms reported by cases is provided in Table 3. 
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Table 3. SENSOR-Pesticides 2006-2009: 

Reported Health Effects for single AI (n=50) 

Sulfur Cases* 

Dermal 21 

Ocular 24 

Respiratory 18 

Gastrointestinal 9 

Renal 0 

Nervous System 17 

Cardiovascular 5 

Misc. 3 

* Cases may report multiple health effects 

c. 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 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. 

Sulfur is not included in the AHS, and therefore this study does not provide information for this 

report. 

IV. CONCLUSION 

Updated incident analyses of the Main and Aggregate Incident Data System (IDS) and NIOSH 

SENSOR are consistent with the previous analyses that based on review of incident data “the 

risk posed to human health by sulfur appears low.” 

Based on the continued low frequency and severity of incident cases reported for sulfur, HED 

concurs with the previous conclusion and 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.