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 1 8, 2012, and y our subsequent telephone conversation with Sara Beth Watson regarding EPA’s comments on the Draft Emergency Medical Treatment Guide for Chloropicrin. In the letter EPA ask ed 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.

I n 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 sinc e sensory irritation potential is known to

decli ne 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 th e 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 Irri tation Testing for Chloropicrin Study as well as the EPA Amended Chloropicrin RED. We believe it is important to keep the original language, which i s 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 h ave 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

Ch airman, Chloropicrin Manufacture rs’ Task Force

Enclosure

cc: Sara Beth Watson