THE CHLOROPICRIN MANUFACTURERS' TASK FORCE

c/o Niklor Chemical Co., Inc., 1667 Purdy Avenue, Mojave, CA 93501

Telephone (661) 824-2494 Fax (661) 824-2904

November 16, 2012

VIA ELECTRONIC MAIL

Ms. Andrea Mojica, PRD

Office of Pesticide Programs (7508P)

U.S. Environmental Protection Agency

Room S-4900, One Potomac Yard

2777 South Crystal Drive

Arlington, VA 22202

Re: Emergency Medical Treatment Guide - Chloropicrin

Dear Ms. Mojica:

I am writing to follow up on Kevin Costello’s letter of October 18, 2012, and your 

subsequent telephone conversation with Sara Beth Watson regarding EPA’s comments on the 

Draft Emergency Medical Treatment Guide for Chloropicrin. In the letter EPA asked for 

changes to the Treatment section and the Human Subject Testing section.

In the Treatment section EPA asked that we add the following phrase at end of the 

paragraph: “If necessary, remove person to fresh air and provide ventilator support.” We are 

adding that phrase as shown on page 3 of the attached revised Draft Emergency Medical

Treatment Guide – Chloropicrin.

In the Human Subject Testing section EPA asked us to revise the statement, “. . . the 

population more sensitive to sensory irritant effects than the general population including 

asthmatics and children . . .” to read, “. . . a population shown to be equally sensitive to sensory 

irritant effects as the general population including asthmatics and children . . ..” EPA’s 

requested change references the test population for the Human Sensory Irritation Testing for 

Chloropicrin Study. The study population included only normal healthy male and female adults, 

eighteen to thirty-five years of age because that segment of the general population is considered 

to have the greatest sensitivity to sensory irritants since sensory irritation potential is known to 

decline with age. Citations for the sensitivity of this group are included in the study report. 

Moreover, EPA’s May 2009 Amended Registration Eligibility Decision (RED) for chloropicrin 

states on page 21 that the study evaluated “the most sensitive human sub-population to sensory 

irritants (young adults, average twenty-three).” To make the change suggested in the October 18 

letter would be inconsistent with the science behind the design of the Human Sensory Irritation 

Testing for Chloropicrin Study as well as the EPA Amended Chloropicrin RED. We believe it is 

important to keep the original language, which is consistent with the sensory irritation research, 

the study design, and the EPA RED. 
Ms. Andrea Mojica, PRD

November 16, 2012

Page 2 of 2

We have attached to this letter the Revised Draft Emergency Medical Treatment Guide 

which makes the requested change in the Treatment section. It does not make the change in the 

Human Subject Testing section for the reasons discussed above.

If you would like to discuss this in more detail, we would be happy to set up a conference 

call or meeting at your convenience. 

Please contact Sara Beth Watson if you have any questions. Her number is (202) 429-6460.

Sincerely,

Stephen Wilhelm

Chairman, Chloropicrin Manufacturers’ Task Force

Enclosure

cc: Sara Beth Watson