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Position Documii t A! These proposed actions are based on the Agency's determination that these uses may result in unreasonable adverse effects. For creosote, the effects are oncogenicity and mutagenicity.
Require Special Disposal of Treated Wood 1. Reduce Contaminants in Penta D. Chatt Relevant Statutory Measures 1. Occupational Safety and Health Act 2. Toxic Substances Control Act 3. Consumer Product Safety Act 4. Summary of Risks a. Creosote b. Inorganic Arsenical Compounds c. Nebrraska 2. Summary of Benefits a. Pressure Treatment Plant Uses c. Non-pressure Treatment Plant Uses 3. Consideration of Regulatory Options b. Inorganic Arsenicals c. Penta d. Specific Options Selected C. Home and Farm escorts in monroeville. Brush-on Applications of the Inorganic Arsenicals 2.
Brush-on Applications ot the Inorganic Arsenicals 3. Brush-on Applications of the Inorganic Arsenicals D. End-Uses of Treated Vvood 1. Summary of Benefits 3. On October ib, 1S78, EPA issued Notices of Rebuttable Presumption Against Registration and Continued Registration RPAR of pesticide products containing coal tar, creosote, and coal tar neutral oils, ot those containing the inorganic arsenical compounds, and ot those containing penta- chiorophenol and its salts.
The presumption against coal tar, creosote, and coal car neutral oils was based on validated studies showing that these compounds are oncogenic and muta- genic; the presumption against the inorganic arsenical compounds was based on studies caylin chat they are oncogenic, mutagenic, and tetotoxic; the presumption against pentachlorophenol penta was based on studies showing it is teratogenic and tetotoxic.
This document contdins five parts. Part I is this introductory section. It includes descriptions and evaluations ot the risK evidence, exposure data, rebuttal submissions, and the Escorts gateshead ms present risk assessment. Part estimates and summarizes the economic benefits ot these wood preservatives tor each use category and describes the assumptions and limits ot these estimates.
Part IV describes the range oi possible regulatory options ana modifications to reduce the risks ot these pesticides, and explains the Agency's selection ot some of these options tor further consideration. Part V evaluates the specific impact on the risks, benefits, ana nebraeka effects which would occur it each applicable israel escorts and modification tor each use toronto midget escorts were adopted and presents the options and modifications selected by the Agency.
Legal Background 1. S eL seq. Before the Administrator may register a pesticide, however, he must determine that its use will not result in "unreasonable adverse effects on the environment," which is defined by bection 2 bb of FIFRA to mean "any unreasonable risK char man or the environment, taking into the economic, social, and environmental costs and benefits of stromsbjrg use of any pesticide. Section 6 b of FIFRA authorizes the Administrator to issue a notice of intent to cancel the registration of a pesticide or to change its classification if it appears to him that the pesti- cide or its labeling "does not comply with the provisions oi [FIFRA] or, when used in accordance with widespread ana commonly recognized practice, generally causes unreasonable adverse effects on the tp.
He may also cancel the registration of a pesticide if its labeling does not comply with the misbrand- ing provisions of FIFRA which require the labeling to contain language "adequate to protect health and the environment" [F1FRA Section 2 q ]. Ihis process, deed to allow an open, balanced decision with participation by all interested groups, is set torth in 40 CFR These regulations describe various risk criteria, and provide that an RPAR shall arise if the Agency determines that any of the risK criteria have been met.
Once a notice of rebuttable presumption has been published, registrants, applicants and interested persons may submit evidence in rebuttal or in support ot the presumption. All parties may also submit evidence on the economic, social, and environmental benefits ot any use ot the pesticide. If the presumptions of risk are not rebutted, the benefits evidence submitted to or gathered by the Agency must be evaluated and considered with the risk information.
The agency analyzes various risk reduction methods and their costs. If a balance between risKS and benefits cannot be reached tor a specific use, the registration for that use must be cancelled or otherwise restricted, or, in the case ot a new application, denied. Chemical Background 1. Creosote a. Chemical and Physical Characteristics Creosote and coal tar are extremely complex seeking ladies in the cranston containing hundreds ot identitiabie constituents.
Uhese mixtures are produced by the high temperature carbonization of coal, a process referred to as coKing. However, unless otherwise specified or explained, this document will use the term "creosote" to refer to all three of the wood preservatives derived from coal tat, that is, coal tar, creosote, and coal tar neutral oil.
Products similar to coal tar-derived creosote, which are ajiso called creosote, may be distilled from sources other than coal, but these products are very different in chemical composition, and therefore this document refers only to those products distilled from coal tar. Coal tar is produced by the carbonization coKing of coal. Over three hundred compounds have been positively identified in coal tar.
The chemical reactions in the process are not well understood. Low temperature carbonization yields approximately twice as much oil and tar as high temperature carbonization. Coal tar is a black, viscous liquid that has a naphthalene- like odor and a sharp burning taste. It combustible and has a speciiic gravity of 1. It is soluble in benzene, carbon disulfide, and chloroform, partially soluble in alcohol, acetone arid methanol, and only slightly soluble in water Hawley, Neutral hydrocarbons are those coal tar hydrocarbons other tnan coal tat.
Inof the 1, million pounds of creosote used in the United btates, masonville ia milf personals pounds were useu as wood preser- vatives Von Rumker et al. Inabout million pounds 96, gallons of creosote were used as a wood preservative Fuller et al. Pesticide production data reported to the Environmental Protection Agency under Section 7 of FIFKA indicated that , pounas of creosote, 34, pounds of coal tar, ana 2, pounds of coal tar neutral oils were formulated or blended tor pesticidai use in The quantity of creosote and creosote solutions consumed by the wood preserving industry in was 34, gallons of creosote, 66, gallons of creosote-coal tar solutions and 30, gallons of creosote-petroleum Kaioney and Pagiiai, Tolerances This Agency has established no tolerances or exemptions from tolerances, and the U.
Food and Drug Administration FDa has established no action levels for creosote in or on raw agricul- tural commodities. Ihe absence of tolerances and exemptions from tolerances for creosote is of concern to the Agency because some use patterns of creosote may result in creosote residues in food or feed.
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Material used in the production of containers and packages is subject to the definition it it may reasonably be expected to become a component, or to directly or indirectly affect the characteris- tics of tood packed in the container. The general provisions applicable to "indirect food additives" PartSection The quantity of any food additive substance that may be added to tood as a result of use in articles that contact food shall not exceed, where no limits are specified, that which from use of the substance in an amount not more than reasonably required to accomplish the intended physical or technical effect in the food- contact article; shall not exceed any prescribed limitations; and shall not be intended to accomplish any physical or technical effect in the tood itself.
Inorganic Arsenical Compounds a. Chemical and Physical Characteristics because arsenic has multiple valence states, the inorganic arsenical compounds have distinctly ditferent physical and chemical properties. Arsenic pentoxide, sodium arsenatearsenic acid, and sodium pyroarsenate are pentavalent arsenical compounds; ammonium arsenite and arsenic trioxide are trivalent arsenical compounds. These are the compounds used in the tormulation of inorganic arsenical wood preservatives.
Another compound of concern is arsine, a toxic gas which may be produced by burning arsenical-treated wood or by other sex buddy in texico. Arsenic Pentoxide Arsenic pentoxide is a white, amorphous solid. Sodium Arsenate bodiuin arsenate's chemical formula is ha hAsG. Arsenic Acid arsenic acid is the common name tor orthoarsenic acid.
It occurs as white, translucent crystals at 20 C. Its melting point is. It occurs as white crystals and decomposes at 1, C. Ammonium Arsenite 'ihe chemical formula of ammonium arsenite is NH. Its molecular weight isand its density is 1. It forms color- 10 less, hygroscopic rhombic prisms. It is very soluble in cold water and decomposes in hot water Vveast, Arsenic Trioxide Arsenic trioxide is the common name tor arsenious or arsenous oxide. Retined arsenic trioxide is Known as white arsenic.
Arsenic trioxide occurs as an amorphous white powder or as a vitreous solid. Its chemical formula is Escortes service K also As. Q,its molecular weight is It boils at C and sublimes at C. Its solubility in water is These three wood preservatives are various mixtures made, in part, from ammonium arsenic pentoxide, or sodium arsenate, or sodium pyroarsenate.
These concentrates are dumped or otherwise metered and mixed with water to form dilute treating solutions of 0. Although the majority ot wood is treated in closed cylinders under pressure, sometimes the preservatives are painted on wood or texting a guy first what to say wood is dipped or soaked in the solutions. Ammonium arsenite is formulated with other ingredients the final concentration ot ammonium arsenite is 7.
Arsenic pentoxide and arsenic trioxide are also formulated with other ingredients final concentrations ot arsenic pentoxide or arsenic trioxide are either 1. The total volume of fcn gay chat arsenical wood preservatives has increased threefold, from B, pounds in to 27, pounds in Tolerances This Agency has not established tolerances or exemptions from tolerances, and the FDA has not established action levels for arsenic residues in or on raw agricultural commodities resulting from wood uses ot arsenic pentoxide, 12 sodium arsenate, arsenic acid, spdium pyroarsenate, ammonium arsenite and arsenic trioxide, or inorganic arsenical wood preservative formulations.
The absence of tolerances and exemptions from tolerances tor the inorganic arsenical compounds is of concern to the Agency because some use patterns of these compounds may result in residues in food or feed. Pentachlorophenoi a.
Health and wellness
Chemical and Physical Characteristics Pentachiorophenol is commonly called "penta. The major commercial forms of penta are the unmodified phenol and the sodium salt. Figure 1 shows the structural formulae of these forms of penta, while Table contains the chemical and physical properties of these nfbraska. Two other forms, not used as wood preservatives, are the potassium salt and the lauric acid ester.
Molecular Weight In the tirst stage, phenol is chlorinated at C to yield isomers ot tri- and tetrachlorophenols. However, not ail of stromsgurg precursor compounds react in the process; some ot stromsbuurg tetrachiorophenols survive and remain with the penta through later processing. Dioxin and furan contaminants also form in the commercial production of penta. The higher temperatures ot the second stage of penta production are favorable to the condensation of the tri- and tetrachiorophenols to form hexa- hepta- and octachlorodibenzo-p-dioxins dioxins and various chlorinated dibenzoturans furans.
Tabernash co adult personals 2 shows the structural formulae ot the basic molecules of these contaminants. A small amount of tetrachlorodibenzo-p-dioxin TCDD has also been 16 found in penta Buser,although this proved not to be the extremely toxic 2, 3, 7, b-isomer. The lurans found in penta are the tetra- penta- hexa- hepta- and octaehlorodibenzofurans buser and Bosshardt, Registered Uses and Production Many products containing penta and its soaium salt are regis- tered as wood preservatives.
Ihey are among the most versatile pesticides now in use, due to their strlmsburg against a wide range of pests bacteria, yeast, slime molds, algae, fungi, plants, insects, snailsand to their solubility in both organic solvents penta and water sodium penta. As ofabout 50 million pounds of penta were produced annually in the United States; production was expected to increase to 80 million pounds annually in the near future Josephson, Most of the remaining penta is used in register fungicide products applied to wide variety of industrial products xate leather, burlap, masonry, cordage, paint, pulp and paper mills, and nebraskq towers.
Tolerances This Agency has established no tolerances or exemptions from tolerances, and FDA has not established action levels for pentachlorophenol in dage on ravv agricultural commodities. One of these regulations 21 CFR, Part Nebtaska regulation specifies that pentci residues, which occur when penta is applied as a wood preservative, are not to exceed 50 parts per million ppmcalculated as penta, in the hot teens chat wood.
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Alternative Wood Preservative Compounds a. Chemical and Physical Characteristics i. Bis tri-n-butyltin oxide Bis tri-n-butyltin oxide is meridian bbbj escorts colorless to light yellov, liquid. Its solubility in water is about 20 ppm at room temperature and it is miscible with most, organic solvents.
It is made through the Datee reaction with stannic oxide to give tributyltin chloride, which xate then hydroiyzed to the oxiae Martin, Copper-fa-quinolinolate Copperquinoiinoiate is a yellov. Its molecular weignt is j Ic is soluble in water and most organic solvents.
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yo Copperquinol inoiate is denveu from 3-quinolinoi and a copper salt, such as copper acetate hawiey, Copper naphthenate Copper naphthenate is a green-blue solid. It is practically insoluble in water, moderately soluble in petroleum oils, and soluble in most srtomsburg solvents. Copper naphthenate is made by the vivastreet escorts in birmingham ot soluble san antonio escorts back salts cupric suitate with naphthenate, the latter being carboxylic acids derived Irom crude petroleum oils Hawiey, ; hartin, Zinc naphthenate is made by lusing zinc oxide or hydroxide and naphthenic acids, or by preci- pitating from a mixture ol soluble 3303 and sodium naphthenate Hawiey, Acid copper chromate Acid copper chromate is essentially a mixture of copper suitate and sodium dichromate with some addition ot chromic acid.
The solutions which are used as wood preservatives have a pH range from 2. Chromated zinc chloride Lhromated zinc chloride is a mixture of cate chloride and sodium dichromate. The solutions which are used tor wood preservation have a pH range from 2. Sodium tetrachlorophenate Sodium tetrachlorophenate1s chemical formula is CgHCl. ONaH O. It occurs as buff to light brown colored flakes. It is soluble in water, methanol, and acetone Hawley, OH and its molecular weight nebraxka Tetrachlorophenoi is soluble in acetone, benzene, ether, and alcohol Hawley, Registered Uses and Production All the alternatives are registered as wood preservatives, but some have other uses.
Bis tri-n-butyitin oxide is used as a fungicide and bactericide, especially in underwater and anti- fouling paints. Copperquinolinolate is used as a fungicide and for mildew-proofing fabrics. Copper naphthenate is used as 21 d canvas and rope preservative.
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Zinc naphthenate is used as a dryer and wetting agent in paints, varnishes, and resins, as well as an insecticide and miiaewcide. Sodium tetrachlorophenoi is used as an industrial preservative Hav. Tolerances 'ihis Agency has established no tolerances, or exemptions trom australia prostitutes port macquarie and FDA has established no action levels lor residues resulting trom wood uses ot bis tn-n-butyltin oxide, copper quinolinolate, copper naphthenate, zinc naphthenate, acid copper chromate, escort salina zinc chloride, sodium tetrachlorophenate ana tetrachlorophenol, or tor their wood preservative tormulations in or on raw agricultural commodities.
Purposes and Organization This Part has three purposes. The first is to state the scienti- fic bases of the Agency's concern about tne possible risks of the wood preservatives. The second is to analyze comments by the pesticide registrants and other concerned parties about these pd risKs. The third is to assess the risks of the wood preservatives in light of the original concerns and the rebuttal comments.
Risk has two components; the toxic effect or effects of the pesticide, and exposure to the pesticide sufficient to cause the toxic effect s. The toxic effects of concern were first described in PD-1 as the basis tor the rebuttable presumption. For creosote, the rebuttable presumption against registration was issued on the basis of oncogenicity and mutagenicity.
For the srromsburg arsenicals, the basis of the presumption was oncogenicity, mutagenicity, and teratogenicity; two other issues of concern interconversion and neurotoxicity, were also presented. Although not a basis for the presumption itself, interconversion will be discussed here because it was a major factor supporting the presumptions in PD Neurotoxicity will be discussed because it is still presents a potential concern.
This Part describes the scientific basis for this new concern and summarizes the information which formed the basis of wex orginal presumption. Part II is divided into a section for each wood preservative, creosote, the inorganic arsenicais, and penta, in addition to asection which discusses the alternative wood preservatives.
In addition to the discussion of risks, each section also includes a discussion of exposure to the wood preservative and of rebutters' comments regarding this exposure. Finally, each of the first three sections contains the Agency's assessment of each risk, in light' of the i Agency's revised position on exposure and risk. The fourth section briefly describes the possible risks of the alternative wood preservatives.
These reference s identify the specific rebutters responsible for the comments; the reference list is given in Appendix 1 of this document. Creosote 1. Analysis of Rebuttal Comments Concerning Mutagenicity a. In both cases, these chemicals, upon metabolic activation, produced dose- related increases in mutagenic activity. Chqt responses occurred only when the two chemicals were metabolically activated by rodent 25 liver preparations. For daate concentration of test chemical, the mutation frequency were calculated as the ratio of the of mutant cells to the total of surviving cells.
Strimsburg induced mutation frequencies for the tested compound are obtained by subtracting the negative control's average mutation frequency from the adult personals of davis california sample's mutation frequency. Dose-related 26 increases in mutation frequencies were berkeley escorts for both test chemicals following metabolic activation.
LBI,to invalidate the gene mutation ot Simmon and Poole The rebutter considered the first Litton study to be negative; the second Litton study was positive. The rebutter states that the of LBI's experiments show that those of Simmon and Pooie cannot be relied upon as establishing the potential for human mutagenicity of creosote mixtures. This strain, when tested in with metabolic activation by rat liver preparations, Was positive for mutagenicity in one experiment and negative in another experiment.
These conflicting were not explained by the authors; however, it is unclear whether the same sample of creosote was analyzed and if the same rat liver preparation was used. The Agency agrees that it is possible that there may have been differences in the rat liver preparations used in the studies. These differences could have been caused by different dose levels of Sfx given to the rats, resulting in different activation characteristics of dtromsburg rat liver preparations.
The doses were not reported by LB1. Consequently, the Agency cannot accept the argument that because LBI's tests showed some degree of indeterminance the experiments performed by Simmon and Poole are invalid.
Thus, the Agency concludes that the data ot Simmon and Poole are valid and supportive of the presumption of mutagenicity. Rebuttal Comment 2: Reliability of the of Mitchell and Tajiri, 2 The American Wood Preservers Institute claims that the study ot Mitchell and lajiri is unreliable for the purpose of demonstrating potential human mutagenicity ot creosote mixtures. nebtaska
This is horny chat lines the painter primarily to the difficulty of interpreting the of these experiments where only weak mutagenic activity is adte at the higher doses ot creosote that caused pronounced cytotoxicity. Because the Mitchell and Taj in study did not meet these i criteria, the rebutter believes the ot this study are difficult to interpret.
In support of this position, the rebutter submitted an unpub- lished study. These showed evidence ot weak mutagenicity at high cytotoxic levels ot creosote. However, even though the cytotoxicity is higher than desirable and masking of the mutagenic response e. The Agency has reviewed the study submitted by the rebutter and concludes that the LBI's are consistent with those of Mitchell and Taj in, showing that creosote induces unequivocal, albeit weak, unscheduled DNA synthesis in human diploid Wl cells in the presence ot rat liver preparations.
The rebutter believes these nebrasks creosote does not meet the RPAR risk criteria.
As it is stated in the Agency's proposed guidelines [40 CFR Part III G J, "A compound would be considered a mutagen it it produced positive in: two different kinds of tests for demonstrating gene muta- tions; a mouse specific locus test; or any kind of test for demonstrating chromosome aberrations. In addition, the positive from the Salmonella assays and the human ceil study both submitted by this rebutter; see rebuttal comments 1 and 2 further support the presumption of mutagenicity.
This is because the cell membranes of these strains have a specific "defect" allowing 31 lady escort in adelaide uptake ot polycyclic aromatic hydrocarbons American women of surrey than other cell membranes. Agency Response: The Agency agrees with the rebutter that the Salmonella strains used in the Ames assay have an increased permeability toward the large heterocyclic molecules.
These strains are used intentionally to mimic the permeability ol mammalian ceils as much as possible. The Agency concludes that the Salmonella strains used by Simmon and Poole are appropriate for mutagenicity testing. Rebuttal Comment 5; Appropriateness ot Rodent Liver Homogenates for Activating creosote Mixtures 2 The American Wood Preservers Institute states that rodent liver enzymes are inappropriate for activating creosote mixtures prior to the Ames Salmonella test.
The metabolic activity in rodent liver is much greater than that in either human skin tissue or human liver. The rebutter also points out that qualitative, as well as quantitative, differences exist between rodents and humans with regard to the metabolic pattern of polycyciic aromatic hydrocarbons PAH's. Consequently, as specific metabolites of PAH's may be the actual mutagens, a PAH may 32 produce mutagenicity in one species e.
However, the bacterial mutagenicity assay is commonly used by scientists as a primary screening test for chemicals which have mutagenic potential. A positive result in these bacterial mutagenicity assays, although not intended to be the sole basis from which an extrapolation is made to a more complex biological endpoint e. Rebuttal Comment 6; Extrapolation from In Vitro Experiments to Human Mutagenicity 2 The American Wood Preservers Insititute points out that complex factors limit extrapolation from in vitro mutagenicity experiments to in vivo human mutagenicity.
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