Return to Chlorfenapyr
Index Page
ACTIVITY: Acaricide,
Insecticide (pyrrole)
Structure:
Note
that both bromine and fluorine are in this pesticide. |
Adverse
Effects:
Anemia
Body Weight Decrease
Bone
Brain
Cancer: Suggestive - LIVER, TESTES, UTERINE
Cholesterol
CNS
Dermal
Endocrine: Testicular
Endocrine: Uterine
Liver
Spinal Cord
Environmental
Excerpt
from a March 16, 2000, press release from the American Bird
Conservancy:
An impending Environmental Protection Agency (EPA) decision
to deny the cotton registration for chlorfenapyr forced
American Cyanamid to withdraw their application early this
week. The withdrawal comes after an intense year-long campaign
led by the American Bird Conservancy (ABC) that brought
numerous conservation groups, the U. S. Fish and Wildlife
Service, scientists, and the public together in opposition
to the controversial pesticide. "An incredible array of
organizations and people came together to halt - for the
first time - a pesticide registration based solely on its
threat to birds" said Kelley R. Tucker, Director of ABC's
Pesticides and Birds Campaign. "Testing and close scientific
evaluation by EPA and independent scientists clearly revealed
the persistence of this pesticide and its chronic and reproductive
risks to birds," she explained. Laboratory studies of chlorfenapyr
showed declines in test birds of close to 50% in number
of eggs laid, number of viable embryos, and number of normal
hatchlings, leading EPA science staff to label chlorfenapyr
as "one of the most reproductively
toxic pesticides to avian species [the Division] has evaluated."
It was also found to persist in soils for over a
year, leading many to question its hidden, long-term effects
on the environment.
Ref: http://www.fluorideaction.org/pesticides/chlorfenapyr.abc.mar.2000.htm
US
FINAL RULE, January 26, 2005:
A tolerance of 0.01 ppm was
established January
2005 for residues of chlorfenapyr in
or on all food commodities as
a result of application of chlorfenapyr to crack,
crevice and spot applications in
food/feed handling areas where food/feed products
are prepared, held, processed, or served .
US
FINAL RULE, Sept 26, 2003:
1 ppm in or on raw agricultural commodities - vegetables,
fruiting, group 8, which include: chili,
postharvest; pepper, nonbell; tomato, paste; eggplant;
pepper, nonbell; sweet tomato, puree; groundcherry;
tomatillo; tomato,
wet, pomace; pepino; tomato; vegetable, fruiting;
pepper; tomato, concentrated products; vegetable,
fruiting; grouppepper, bell; tomato, dried pomace
|
|
Anemia
(click on for all fluorinated pesticides)
-- MRID No. 42770219
(1993)-- 90-Day oral toxicity rats.
NOAEL = 24.1 mg/kg/day. LOAEL = 48.4, based on spongiform myelopathy
in the brain and spinal cord of male rats,
decreased body weight gain and increased relative liver weight
in males and females, increased absolute liver weight in females,
and decreased hemoglobin in females.
-- MRID No. 43492837 (1994). Combined chronic/ carcinogenicity
in rat. NOAEL = 15 mg/kg/day, males.
LOAEL = 30.8 mg/kg/day, males, based on
anemia. NOAEL = 3.6 mg/kg/day, females LOAEL = 18.6 mg/kg/day,
females, based on decreased body weight/
body weight gain.
Ref:
Federal Register: September 26, 2003. Chlorfenapyr; Pesticide
Tolerance. Final Rule.
http://www.fluorideaction.org/pesticides/chlorfenapyr.fr.sept26.2003.htm
Body
Weight Decrease (click
on for all fluorinated pesticides)
-- MRID No. 42770219
(1993)-- 90-Day oral toxicity rats.
NOAEL = 24.1 mg/kg/day. LOAEL = 48.4, based on spongiform myelopathy
in the brain and spinal cord of male rats, decreased
body weight gain and increased relative liver weight in
males and females, increased absolute liver
weight in females, and decreased hemoglobin in females.
-- MRID No. 43492830 (1994). 90-Day oral toxicity mouse.
NOAEL = 27.6/40, M/F. LOAEL = 62.6/78, M/F, based on reduced
body weights/body weight gains, and spongiform encephalopathy
in both sexes.
-- MRID No. 42770220 (1993). 90-Day oral toxicity dog.
NOAEL = 3.9/4.5 mg/kg/ day, M/F. LOAEL = 6.7/6.8 mg/kg/ day, M/Fbased
on emaciation, decreased body weight gains,
and decreased food efficiency.
-- MRID No. 42884202 (1993). Prenatal developmental rat.
Maternal NOAEL = 25 mg/kg/day, based on decreased
body weight gain and relative food consumption during treatment
Developmental NOAEL >=225 mg/kg/day. Developmental LOAEL = not
identified.
-- MRID No. 42770222 (1993). Prenatal developmental rabbit.
Maternal NOAEL = 5 mg/kg/day. Maternal LOAEL = 15 mg/ kg/day,
based on decreased body weight gain
during treatment Developmental NOAEL = 15 mg/kg/day Developmental
LOAEL = 30 mg/kg/day, based on increased post implantation loss.
-- MRID No. 43492836 (1994). 2-Generation reproduction and fertility
effects rat. Parental systemic NOAEL
= 4.4-4.5 mg/kg/day, M. Parental systemic LOAEL = 22.2-22.5 mg/kg/day,
M, based on decreased absolute body weight/body
weight gains of P1 males during premating. Offspring systemic
NOAEL = 4.4-5.1 mg/kg/day. Offspring systemic LOAEL = 22.2-25.6
mg/kg/day, based on decreased pup weights
at weaning. Reproductive NOAEL >=44- 50.7 mg/kg/day. Reproductive
LOAEL: not identified.
-- MRID No. 43492834 (1994). Chronic toxicity dog.
NOAEL = 4.0/4.5 mg/kg/day, M/F. LOAEL = 8.7/10.1 mg/kg/ day, M/F,
based on decreased body weight/body weight
gains.
-- MRID No. 43492838 (1994). Carcinogenicity mouse.
NOAEL = 2.8/3.7 mg/kg/day, M/F. LOAEL = 16.6/21.9 mg/kg/day, M/F,
based on decreased body weight gains,
brain vacuolation, and scabbing of the skin (males)
No evidence of carcinogenicity.
-- MRID No. 43492837 (1994). Combined chronic/ carcinogenicity
in rat. NOAEL = 15 mg/kg/day, males.
LOAEL = 30.8 mg/kg/day, males, based on
anemia. NOAEL = 3.6 mg/kg/day, females LOAEL = 18.6 mg/kg/day,
females, based on decreased body weight/
body weight gain.
-- MRID No. 43492833 (1994). Chronic neurotoxicity rat.
NOAEL = 2.6/3.4 mg/kg/day, M/F. LOAEL = 13.6/18 mg/kg/ day, M/F,
based on the presence of myelinopathic alterations
in the central nervous system (CNS) in male rats and decreased
average body weights/body weight gains, food efficiency,
absolute food consumption (females) and water consumption (males)
-- Chronic neurotoxicity study - rat.
LOAEL = 13.6/18 mg/kg/ day, M/F, based on the presence of
myelinopathic alterations in the CNS in male rats and
decreased average body weights, body weigh gains, food
efficiency, absolute food consumption (F), and water consumption
(M). Supporting this endpoint are similar
CNS lesions and skin lesions observed in the mouse carcinogenicity
study (NOAEL = 2.8).
Ref:
Federal Register: September 26, 2003. Chlorfenapyr; Pesticide
Tolerance. Final Rule.
http://www.fluorideaction.org/pesticides/chlorfenapyr.fr.sept26.2003.htm
-- CHRONIC TOXICITY,
DOG ** 062; 147071; "One Year Dietary
Toxicity Study with AC 303,630 in Purebred Beagle Dogs"; (Kelly,
C.M.; Pharmaco LSR Inc., East Millstone, NJ; Study No. 92-3107;
8/31/94); AC 303,630 Technical (purity: 94.5%) was administered
in the diet to 5 dogs/sex/group at doses of 0, 60 and 120 ppm
and to 6 dogs/sex at 240 ppm for 12 months (M-0, 2.1, 4.0, 8.7
mg/kg/day, F-0, 2.3, 4.5, 10.1 mg/kg/day).
Reduced body weight gain was evident in the high dose animals.
The relative mean liver weights were slightly increased in the
high dose group. No treatment-related effects were noted for hematology
or clinical chemistry. No treatment-related lesions were evident.
No adverse effects were indicated. NOEL:
120 ppm (M/F) (based on increase in relative mean liver weight
and reduced body weight gain of animals in the 240 ppm treatment
group); NOAEL: 240 ppm; Study acceptable. (Moore, 7/15/96)
-- REPRODUCTION, RAT
** 063; 147072; "A Pilot Dietary Reproduction Study in Rats with
AC 303,630", (R.E. Schroeder; Pharmaco LSR Inc., East Millstone,
NJ; Study No. 91-3755; 7/20/94); AC 303,630 Technical (purity:
94.5%) was administered to 10 animals/sex/group in the diet at
doses of 0, 60, 300 and 600 ppm for 10 weeks during a premating
period, a 10 day mating period and the ensuing gestation and lactation
periods. Reduced body weight gain was noted
in the females of the 300 and 600 ppm groups during the premating
period. Pup survival was reduced in the 600 ppm treatment
group during the 0 to 4 day post-natal period. Pup
weight gain was reduced in the high dose group over the lactation
period. No adverse effect indicated. Parental
NOEL: 60 ppm (based upon reduced body weight gain in the 300 ppm
treatment group), Reproductive/Developmental NOEL: 300 ppm (based
upon the reduced pup survival and body weight gain in the 600
ppm treatment group), NOAEL: 600 ppm; Study supplemental.
(Moore, 7/29/96)
-- REPRODUCTION, RAT
** 064; 147073; "A Two-Generation (One-Litter) Reproduction Study
with AC 303,630 in Rats"; (R.E. Schroeder, Pharmaco LSR Inc.,
East Millstone, NJ; Study No. 90-3638; 8/8/94); AC 303,630 technical
(purity 94.5%) was administered in the feed of 30 animals/sex/group
for two generations at doses of 0, 60, 300, and 600 ppm (P1 (M)
0, 4.2, 20.9, 41.1 mg/kg/day, (F) 0, 6.0, 29.3, 57.2 mg/kg/day,
F1 (M) 0, 3.7, 19.0, 38.3 mg/kg/day, (F) 0, 6.0, 29.5, 58.7 mg/kg/day).
Reduced body weight gain was noted for both
the adult males and females in the 300 and 600 ppm treatment groups
of the F1 generation. This reduced weight gain was apparent in
these animals during the lactation period and continued during
the premating period. Reproductive parameters were not affected
by treatment. No adverse effects indicated. Parental NOEL: 60
ppm (based upon reduced body weight gain in the 300 and 600 ppm
F1 generation males and females); Reproductive NOEL: 600 ppm;
Developmental NOEL: 60 ppm (based upon reduced body weight gain
of pups during lactation period). Study acceptable. (Moore,
8/1/96)
Ref:
August
24, 2001 - Summary
of Toxicological Data. California EPA.
Department of Pesticide Regulation. Medical Toxicology Branch.
Also available at:
http://www.cdpr.ca.gov/docs/toxsums/pdfs/3938.pdf
Bone
(click
on for all fluorinated pesticides)
TERATOLOGY, RAT **
012; 125176; "An Oral Developmental Toxicity (Embryo-Fetal Toxicity/Teratogenicity)
Definitive Study with AC 303,630 in Rats", T. Martin; 833; Rat;
Argus Research Laboratories, Inc., Horsham, PA; Report No. 101-015;
7/22/93; AC 303,630 Technical (purity: 94.5%); 25 females/group;
Doses: 0, 25, 75 and 225 mg/kg/day, by gavage, in aqueous 0.5%
(w/w) carboxymethyl cellulose, from day 6 through day 15 of gestation;
Maternal: no mortality; Clinical Observations: reduced food consumption
during dosing period (75, 225 mg/kg/day); Necropsy: no treatment-related
lesions; Development: increased incidence
of unossified sternabrae (225 mg/kg/day), no treatment-related
effects upon number of live fetuses, fetal weight, and number
of resorptions; No adverse effect indicated; NOEL: Maternal-25
mg/kg/day (based upon reduced food consumption in 75 and 225 mg/kg/day
treatment groups), Developmental: 75 mg/kg/day
(based upon incidence of unossified sternabrae in the 225 mg/kg/day
treatment group); Study acceptable. (Moore, 2/6/95)
Ref: August
24, 2001 - Summary
of Toxicological Data. California EPA.
Department of Pesticide Regulation. Medical Toxicology Branch.
Also available at:
http://www.cdpr.ca.gov/docs/toxsums/pdfs/3938.pdf
Brain (click
on for all fluorinated pesticides)
ii. Subchronic Oral
Toxicity in Mice... Spongiform encephalopathy
was noted in the brain and myelin of the spinal
cord of both males and females receiving the 320 ppm treatment
level. The LEL is 14.8 mg/kg/day (80 ppm) for male mice
and 40.0 mg/kg/day (160 ppm) for female mice, based on hepatic
cell hypertrophy in 20% of the test animals at this treatment
level. The NOEL is 7.1 mg/kg/day (40 ppm)... The RfD Committee
also recommended that a special developmental neurotoxicity study
be conducted based upon the effects of a spongyform
myelopathy and/or
vacuolation seen in the brain and spinal cord
of treated rats and mice. They concluded that the registrant should
also conduct a mechanistic study to determine the cause/relationship
of CNS/myelinopathic alterations to neurotoxicity (including developmental)...
Chronic-Term (greater than several months) Occupational/Residential
Dermal NOEL: 3 mg/kg/day (decreased body weight gains brain
lesions (vacuolation) and/or
scabbing of the skin in a 1 year neurotoxicity study in rats and
a chronic/carcinogenicity study in mice) Acceptable MOE = 1000
(includes FQPA Factor)
Ref: US EPA, Feb 12, 1998: Chlorfenapyr
- 129093: Health Effects Division Risk Characterization for Use
of the Chemical Chlorfenapyr.
http://www.epa.gov/opprd001/chlorfenapyr/memohed2.pdf
Note:
Page 19-20: "Other chronic effects. For other chronic effects,
a Reference Dose (RfD) has been established at 0.003 mg/kg/day
based on decreased body weight gains and brain
lesions (vacuolation) observed in the 1-year rat neurotoxicity
study. An uncertainty factor (UF) of 1000 was applied to account
for interspecies extrapolation, intraspecies variability and
the additional FQPA Factor of 10. The FQPA factor has been retained
because chlorfenapyr has produced central nervous system lesions
in several studies in both rats and mice. It will be reevaluated
after the developmental neurotoxicity study has been submitted."
Ref: US EPA. March 13, 2000. "Denial of
Registration of Chlorfenapyr for Use on Cotton."
http://www.epa.gov/opprd001/chlorfenapyr/chlorfenapyr.pdf
Note:
In a search of EPA's OPP database <http://www.epa.gov/pesticides/search.htm>
for "spongiform encephalopathy" - "spongyform
myelopathy" and "spongyform" - , the only
substance cited was Chlorfenapyr. Mad Cow Disease is also called
Bovine spongiform encephalopathy (BSE) which is a chronic, degenerative
disorder affecting the central nervous system of cattle. In
the US, up until 2002, there were 19 tolerances for residues
of Chlorfenapyr in or on: Cotton,
Milk, Cattle, Hog, Sheep, Horse, and Goat - see:
http://www.fluorideaction.org/pesticides/chlorfenapyr.us.residuefood.htm
ONCOGENICITY, MOUSE
. 066; 147076; "A Chronic Dietary Toxicity
and Oncogenicity Study with AC 303,630 in Mice" (L. Bernier,
Bio-Research Lab., Ltd., Quebec, Canada, Project # 84580, 8/22/94).
AC 303,630 (Batch AC-7504-59A, 94.5% purity) administered orally
in the diet to 65 CD-1 mice/sex/dose for 80 weeks at 0, 20, 120,
or 240 ppm (Males: 0, 2.8, 16.6, or 34.5 mg/kg/day; Females: 0,
3.7, 21.9, or 44.5 mg/kg/day). Reduced survival rate was noted
in high dose females (60% vs. 80%, p < 0.05). However, overall
survival rate of this group was more comparable to that of the
historical controls. Treatment with AC 303,630 resulted in reduced
mean body weight gain in high dose males and females and in mid
dose females (Males: 70% of control, p < 0.01, Females: 86% of
control, p < 0.05 for mid and high dose groups). Food consumption
was also reduced in mid and high dose animals. Histopathology
revealed vacuolation of the white matter of the brain in animals
treated at mid and high dose levels. Also, vacuolation was detected
in spinal cord sections as well as optic nerve tissues in mice
at 240 ppm. There was no evidence of carcinogenicity. NOAEL
(M/F) = 240 ppm [No adverse effect]. NOEL (M/F) = 20 ppm (2.8
and 3.7 mg/kg/day for males and females, respectively; based on
histopathological changes in the brain, optic nerve and spinal
cord). acceptable (Leung, 7/24/96)
Ref: August
24, 2001 - Summary
of Toxicological Data. California EPA.
Department of Pesticide Regulation. Medical Toxicology Branch.
Also available at:
http://www.cdpr.ca.gov/docs/toxsums/pdfs/3938.pdf
NEUROTOXICITY ** 061;
147070; "A One-Year Dietary Neurotoxicity
Study with AC 303,630 in Rats"; (J.A. Foss; Argus Research
Laboratories, Inc., Horsham, PA; Study No. 101-019; 5/10/94);
AC 303,630 technical (purity: 94.5%) was administered in the diet
to 25 animals/sex/group at doses of 0, 60, 300, and 600 ppm for
up to 52 weeks ((M)-0, 2.6, 13.6, 28.2 mg/kg/day, (F)-0, 3.4,
18.0, 37.4 mg/kg/day). Surviving animals were observed for an
additional 16 weeks of a recovery phase. No treatment-related
effects were noted in the functional observational battery or
the motor activity evaluation. In the neurohistopathology,
myelin sheath swelling of the spinal nerve roots was evident in
the males of the 600 ppm treatment group after 13 and 52
weeks of treatment. Extensive vacuolar myelinopathy
was noted in the brain and spinal cord of the 300 and 600 ppm
males after 52 weeks of treatment. These effects were no
longer present after the 16 week recovery period. No treatment-related
lesions were noted in the females. No adverse effects were evident.
NOEL: (M) 60 ppm (based upon the incidence of extensive vacuolar
myelinopathy in the central nervous system); (F) 600 ppm;
NOAEL: 600 ppm (based on recovery). Study acceptable. (Moore,
7/29/96)
Ref:
August
24, 2001 - Summary
of Toxicological Data. California EPA.
Department of Pesticide Regulation. Medical Toxicology Branch.
Also available at: http://www.cdpr.ca.gov/docs/toxsums/pdfs/3938.pdf
SUBCHRONIC STUDIES
** 010, 031; 125163; "AC 303,630: A 13 Week
Dietary Toxicity Study in the Albino Rat", J.E. Fischer;
821; Rat; American Cyanamid Co., Agricultural Research Division,
Toxicology Department, Princeton, NJ; Study No. T-0316; 4/8/93;
AC 303,630 Technical (purity: 93.6%); 20 animals/sex/group; Doses:
0, 150, 300, 600, 900, 1200 ppm (M: 0, 10.9, 22.0, 44.9, 69.5,
92.2 mg/kg/day, F: 0 11.7, 24.1, 48.4, 72.5, 97.5 mg/kg/day),
in the diet, 13 weeks; No treatment-related mortality; Clinical
Observations: red. body wgt. gain (M,F-900, 1200 ppm), red. food
consumption (M-600 ppm and up); Ophthalmology, Urinalysis: no
treatment-related effects; Hematology: red. hematocrit (M,F-1200,
F-900 ppm), red. hemoglobin (M,F-1200, F-600, 900 ppm), red blood
cells (M,F-1200, F-900 ppm), Clinical Chemistry: incr. BUN (M,F-1200
ppm, week 6, M-1200 ppm, week 13), incr. alk. phosphatase activity
(M,F-900, 1200 ppm, week 13); Necropsy: incr. mean abs. liver
wgt. (F-600 ppm and up), red. abs. kidney wgt (M,F-900, 1200 ppm),
incr. abs. spleen wgt. (M,F-900, 1200 ppm), incr. rel. liver wgt.
(M,F-600, 900, 1200, M-300 ppm), increased relative spleen weight
(M,F-900, 1200 ppm); Histopathology: spongiform
myelopathy in brain, spinal cord (M-(2/20), 1200, 900 ppm, (1/20),
600 ppm), lesion present in sciatic nerve (M-(1/20), 1200
ppm), lymphoid cell infiltrate in kidneys (M,F-900, 1200 ppm);
Target organ: central nervous system;
Adverse Effect: spongiform myelopathy in
the nervous system; NOEL: (M) 300 ppm (occurance of spongiform
myelopathy in the nervous system of the 600 ppm group) (F)
300 ppm (based on increased mean abs. liver wgt. in 600 ppm group);
(Study previously unacceptable, possibly upgradeable with submission
of GLP compliance and QA audit statements (Moore, 2/1/95)) requested
information submitted; Study acceptable. (Moore, 8/9/95)
Ref: August
24, 2001 - Summary
of Toxicological Data. California EPA.
Department of Pesticide Regulation. Medical Toxicology Branch.
Also available at: http://www.cdpr.ca.gov/docs/toxsums/pdfs/3938.pdf
-- MRID No. 42770219
(1993)-- 90-Day oral toxicity rats.
NOAEL = 24.1 mg/kg/day. LOAEL = 48.4, based on spongiform
myelopathy in the brain and spinal cord of male
rats, decreased body weight
gain and increased relative liver weight in males and females,
increased absolute liver weight in females, and decreased hemoglobin
in females.
-- MRID No. 43492830 (1994). 90-Day oral toxicity mouse
. NOAEL = 27.6/40, M/F. LOAEL = 62.6/78, M/F, based on reduced
body weights/body weightgains, and spongiform
encephalopathy in both sexes.
-- MRID No. 43492838 (1994). Carcinogenicity mouse.
NOAEL = 2.8/3.7 mg/kg/day, M/F. LOAEL = 16.6/21.9 mg/kg/day, M/F,
based on decreased body weight gains,
brain vacuolation, and scabbing of the skin
(males) No evidence of carcinogenicity.
-- MRID No. 43492833 (1994). Chronic neurotoxicity rat.
NOAEL = 2.6/3.4 mg/kg/day, M/F. LOAEL = 13.6/18 mg/kg/ day, M/F,
based on the presence of myelinopathic alterations
in the central nervous system (CNS) in male rats and
decreased average body weights/body weight gains,
food efficiency, absolute food consumption (females) and water
consumption (males)
-- Chronic neurotoxicity study - rat.
LOAEL = 13.6/18 mg/kg/ day, M/F, based on the presence of myelinopathic
alterations in the CNS in male rats
and decreased average body weights, body
weigh gains, food efficiency,
absolute food consumption
(F), and water
consumption (M). Supporting this endpoint are similar CNS
lesions and skin lesions observed in the
mouse carcinogenicity study (NOAEL = 2.8).
-- Conditions: A developmental neurotoxicity study to determine
the cause/relationship of potential central
nervous system/myelinopathic alterations to neurotoxicity in the
developing young.
Ref:
Federal Register: September 26, 2003. Chlorfenapyr; Pesticide
Tolerance. Final Rule.
http://www.fluorideaction.org/pesticides/chlorfenapyr.fr.sept26.2003.htm
Also
see the following.
•
December
22, 2004, US EPA's response to FAN's Comments on Chlorfenapyr
effects on brain - see
http://www.fluorideaction.org/pesticides/chlorfenapyr.2005.epa.response.pdf
-
(Online at US EPA Docket OPP-2004-0362-0002)
•
August
11, 2003, comments submitted to US EPA by FAN's Pesticide
Project on the pesticide petition from BASF Corporation
to establish a tolerance for residues of chlorfenapyr on
all food items in food handling establishments where food
products are held, processed, and/or prepared at 0.01 parts
per million (ppm).
http://www.fluorideaction.org/pesticides/chlorfenapyr.comments.aug03.htm
-
(Online
at US EPA Docket OPP-2003-0205)
•
September
17, 2003, reply to comments from FAN's Pesticide Project,
from Daniel J. O'Byrne, Product Registrations Manager, BASF
Corporation. http://www.fluorideaction.org/pesticides/chlorfenapyr.basf.sept.2003.pdf
-
(Online
at US EPA Docket OPP-2003-0205) |
Cancer
- Suggestive (click
on for all fluorinated pesticides)
-- Classification:
``Suggestive Evidence of Carcinogenicity,
but Not Sufficient to Assess Human Carcinogenic Potential''
based on significant trends in liver tumors
(adenomas and combined adenomas/ carcinomas), malignant histiocytic
sarcomas, and testicular cell tumors in male rats and uterine
polyps in female rats seen at the highest dose.
Ref:
Federal Register: September 26, 2003. Chlorfenapyr; Pesticide
Tolerance. Final Rule.
http://www.fluorideaction.org/pesticides/chlorfenapyr.fr.sept26.2003.htm
Suggestive
Evidence of Carcinogenicity, but Not Sufficient to Assess Human
Carcinogenic Potential. The
overall evidence in animals was Not persuasive, but could not
be dismissed. Increase in tumors in rats occurred with significant
positive trends only, and mainly at the highest dose.
Ref: April
26, 2006 . Chemicals Evaluated for Carcinogenic Potential by the
Office of Pesticide Programs. From: Jess Rowland, Chief Science
Information Management Branch Health Effect Division (7509C) Office
of Pesticide Programs, USEPA.
http://www.fluorideaction.org/pesticides/pesticides.cancer.potential.2006.pdf
page 3: ... BASF Corporation submitted a comprehensive weight-ofevidence
analysis to argue that the USEPA classification of chlorfenapyr
as “suggestive evidence of carcinogenicity, but not sufficient
to assess human carcinogenic potential” should be modified
to “not likely to be a human carcinogen.” When we
compared the registrant’s weight-of-evidence analysis with
the carcinogenicity study data reviewed by the USEPA’s Cancer
Peer Review Committee (Memorandum, January 9, 1997: Carcinogenicity
Peer Review of Chlorfenapyr), we found that
overall the registrant’s argument is not sufficiently persuasive
that chlorfenapyr should be classified as “not likely to
be a human carcinogen.” The main thrust of the registrant’s
argument is that overall there is no increase in liver adenomas/carcinomas,
malignant histiocytic sarcomas, testicular interstitial cell tumors
and uterine endometrial stromal polyps by pair-wise comparisons
between groups of rats fed different doses of chlorfenapyr. The
registrant further argues that the positive trends in tumor incidence
resulting from oral exposure to increasing doses of chlorfenapyr
are not significant when compared to the tumor incidence in historical
controls. To support their argument, the registrant cites only
maximum percent control tumor incidence values instead of the
mean values and ranges which would better illustrate background
tumor incidence. Furthermore, the registrant dismisses the experimental
control values obtained from the rat carcinogenicity study on
chlorfenapyr, by stating that these values are “...uniquely
and abnormally low.” While we acknowledge that the registrant
makes some valid points in their analysis, we believe that the
USEPA’s classification of the carcinogenic potential of
chlorfenapyr as “suggestive evidence of carcinogenicity,
but not sufficient to assess human carcinogenic potential”
is appropriate and should not be reclassified to “not likely
to be a human carcinogen.” In addition, the registrant’s
focus on specific carcinogenicity issues to the exclusion of the
other issues raised in our initial review (i.e., the comparative
risks posed by this product and the need for use on fruiting vegetables)
does not address the overall concerns for registering this product.
Ref: October 3, 2005, letter to BASF from
New York State Bureau of Pesticides Management.
http://www.fluorideaction.org/pesticides/chlorfenapyr.pylon.nys.reg.2005.pdf
Cholesterol
(click
on for all fluorinated pesticides)
The 100-fold margin
of safety is adequate to assure a reasonable certainty of no harm
to infants and children from the proposed use. As stated earlier,
the NOAEL is based on the effects observed in the rat and mouse
chronic oncogenicity studies, (reduced bwt gains,
increased globulin and cholesterol
values and increased liver weights in the rat and reduced bwt
gains and vacuolation of white matter of the mouse brain), the
1-year neurotoxicity study in the rat, (reduced bwt gains and
vacuolar myelinopathy of [[Page 46680]] the brain and spinal cord
that is completely reversible following termination of treatment
and is not associated with any damage to neuronal cell bodies
or axons; vacuolation of the white matter is a consequence of
edema (water) formation between the myelin layers which result
from the unrestricted movement of ions across the cell membranes)
and the 2-generation rat reproduction study, (reduced bwt gains
for parental animals and reduced pup body weights for the F1 and
F2 litters; however no behavioral changes were observed in either
F1 or F2 offsprings in the 2-generation reproduction study)...
Ref: Federal Register: August 26, 1999 [Page
46677-46680]. Notice of Filing; Pesticide Petition.
http://www.fluoridealert.org/pesticides/Chlorfenapyr.FR.Aug.26.1999.htm
CNS
(click on for all fluorinated
pesticides)
-- MRID No. 43492833
(1994). Chronic neurotoxicity rat.
NOAEL = 2.6/3.4 mg/kg/day, M/F. LOAEL = 13.6/18 mg/kg/ day, M/F,
based on the presence of myelinopathic alterations
in the central nervous system (CNS) in male rats and
decreased average body weights/body weight gains,
food efficiency,
absolute food consumption (females) and water consumption (males)
-- Chronic neurotoxicity study - rat.
LOAEL = 13.6/18 mg/kg/ day, M/F, based on the presence of myelinopathic
alterations in the CNS in male rats and
decreased average body weights, body weigh gains,
food efficiency, absolute food consumption
(F), and water
consumption (M). Supporting this endpoint are similar CNS
lesions and skin lesions observed
in the mouse carcinogenicity study (NOAEL = 2.8).
-- Conditions: A developmental neurotoxicity study to determine
the cause/relationship of potential central
nervous system/myelinopathic alterations to neurotoxicity in the
developing young.
Ref:
Federal Register: September 26, 2003. Chlorfenapyr; Pesticide
Tolerance. Final Rule.
http://www.fluorideaction.org/pesticides/chlorfenapyr.fr.sept26.2003.htm
Dermal
(click
on for all fluorinated pesticides)
-- MRID No. 43492838
(1994). Carcinogenicity mouse. NOAEL
= 2.8/3.7 mg/kg/day, M/F. LOAEL = 16.6/21.9 mg/kg/day, M/F, based
on decreased body weight gains, brain vacuolation,
and scabbing of the skin (males)
No evidence of carcinogenicity.
-- Chronic neurotoxicity study - rat.
LOAEL = 13.6/18 mg/kg/ day, M/F, based on the presence of myelinopathic
alterations in the CNS in male rats and
decreased average body weights, body weigh gains, food
efficiency, absolute food consumption
(F), and water
consumption (M). Supporting this endpoint are similar CNS
lesions and skin lesions observed
in the mouse carcinogenicity study
(NOAEL = 2.8).
Ref:
Federal Register: September 26, 2003. Chlorfenapyr; Pesticide
Tolerance. Final Rule.
http://www.fluorideaction.org/pesticides/chlorfenapyr.fr.sept26.2003.htm
Endocrine:
Testicular (click
on for all fluorinated pesticides)
-- Classification:
``Suggestive Evidence
of Carcinogenicity, but Not Sufficient to Assess Human
Carcinogenic Potential'' based on significant
trends in liver tumors (adenomas and combined adenomas/ carcinomas),
malignant histiocytic sarcomas, and
testicular cell tumors in male rats and
uterine polyps in female rats seen at the highest dose.
Ref:
Federal Register: September 26, 2003. Chlorfenapyr; Pesticide
Tolerance. Final Rule.
http://www.fluorideaction.org/pesticides/chlorfenapyr.fr.sept26.2003.htm
August
11, 2003, comments submitted to US EPA by FAN's Pesticide
Project on the pesticide petition from BASF Corporation
to establish a tolerance for residues of chlorfenapyr
on all food items in food handling establishments where
food products are held, processed, and/or prepared at
0.01 parts per million (ppm).
http://www.fluorideaction.org/pesticides/chlorfenapyr.comments.aug03.htm
- Also Online
at US EPA Docket OPP-2003-0205.
5.
Endocrine Disruption. In the petition, BASF states:
... There is no information available which suggests
that chlorfenapyr would be associated with endocrine
effects.
5.1 However, US EPA noted endocrine effects in the following
study: In the rat chronic toxicity/carcinogenicity study
(MRID 43492837), there were increased trends in the
incidence of hepatocellular adenomas, hepatocellular
adenomas and/or carcinomas combined, malignant histiocytic
sarcomas and testicular interstitial cell tumors in
males rats. In female rats there were significant increasing
trends in endometrial stromal polyps. Significant difference
in pair-wise comparison of fibroadenomas at the low
dose and carcinomas at the mid-dose existed for female
rats. There was no evidence of tumorigenic potential
in mice....
Ref: US EPA OPPT. February 12,
1998. SUBJECT: Chlorfenapyr - 129093: Health Effects
Division Risk Characterization for Use of the Chemical
Chlorfenapyr (Alert, EPA File Symbol 5905-GAI) in/on
Citrus (6F04623). Case: 287132. Barcode: D221320-
http://www.epa.gov/opprd001/chlorfenapyr/memohed2.pdf
September
17, 2003, reply to comments from FAN's Pesticide Project,
from Daniel J. OÕByrne, Product Registrations Manager,
BASF Corporation. http://www.fluorideaction.org/pesticides/chlorfenapyr.basf.sept.2003.pdf
- Also
online
at US EPA Docket OPP-2003-0205.
Regarding
Point 5: Endocrine Effects This comment addresses
findings of endometrial stromal polyps and testicular
interstitial cell tumours
The
occurrence of benign interstitial cell tumors in male
rats was 3/65, 1/65, 3/65 and 7/65 (4.6, 1.5, 4.6, 10.8%)
in the control and the low-, mid- and high dose, respectively.
There was no statistically significant increase in either
group when compared to the control group and no clear
dose-response relationship. Moreover the incidence of
7/65 was at the upper limit of the historical control
range (10.0%). Therefore, the occurrence of this benign
proliferative lesion in males of the high-dose group
is not considered treatment related.. Overall,
there is no indication of an endocrine effect of chlorphenapyr
in any of the studies, including the two-generation
study in rats and the oncogenicity studies in rats and
mice.
|
Endocrine:
Uterine (click
on for all fluorinated pesticides)
-- Classification:
``Suggestive Evidence
of Carcinogenicity, but Not Sufficient to Assess Human
Carcinogenic Potential'' based on significant
trends in liver tumors (adenomas and combined adenomas/ carcinomas),
malignant histiocytic sarcomas, and testicular cell tumors in
male rats and uterine polyps in female
rats seen at the highest dose.
Ref:
Federal Register: September 26, 2003. Chlorfenapyr; Pesticide
Tolerance. Final Rule.
http://www.fluorideaction.org/pesticides/chlorfenapyr.fr.sept26.2003.htm
August
11, 2003, comments submitted to US EPA by FAN's Pesticide
Project on the pesticide petition from BASF Corporation
to establish a tolerance for residues of chlorfenapyr
on all food items in food handling establishments where
food products are held, processed, and/or prepared at
0.01 parts per million (ppm).
http://www.fluorideaction.org/pesticides/chlorfenapyr.comments.aug03.htm
- Also Online
at US EPA Docket OPP-2003-0205.
5.
Endocrine Disruption. In the petition, BASF states:
... There is no information available which suggests
that chlorfenapyr would be associated with endocrine
effects.
5.1 However, US EPA noted endocrine effects in the following
study: In the rat chronic toxicity/carcinogenicity study
(MRID 43492837), there were increased trends in the
incidence of hepatocellular adenomas, hepatocellular
adenomas and/or carcinomas combined, malignant histiocytic
sarcomas and testicular interstitial cell tumors in
males rats. In female rats there were significant increasing
trends in endometrial stromal polyps. Significant difference
in pair-wise comparison of fibroadenomas at the low
dose and carcinomas at the mid-dose existed for female
rats. There was no evidence of tumorigenic potential
in mice....
Ref: US EPA OPPT. February 12,
1998. SUBJECT: Chlorfenapyr - 129093: Health Effects
Division Risk Characterization for Use of the Chemical
Chlorfenapyr (Alert, EPA File Symbol 5905-GAI) in/on
Citrus (6F04623). Case: 287132. Barcode: D221320-
http://www.epa.gov/opprd001/chlorfenapyr/memohed2.pdf
September
17, 2003, reply to comments from FAN's Pesticide Project,
from Daniel J. OÕByrne, Product Registrations Manager,
BASF Corporation. http://www.fluorideaction.org/pesticides/chlorfenapyr.basf.sept.2003.pdf
- Also
online
at US EPA Docket OPP-2003-0205.
Regarding
Point 5: Endocrine Effects This comment addresses
findings of endometrial stromal polyps and testicular
interstitial cell tumours
The
occurrence of endometrial stromal
polyps in the uterus was slightly increased in
high-dose females, as compared to controls. Although
the incidence of endometrial stromal
polyps in high-dose females (5/65 or 7.7%) is statistically
different from the concurrent control females
(0/65) by the Fisher Exact Test (p< 0.05), the incidences
are not statistically different using the exact prevalence
method. This is the more appropriate method to compare
two groups with heterogeneous survival rates (survival
was significantly increased in high-dose females). All
five females with stromal polyps were sacrificed at
termination. Furthermore, the incidence (0/65) of these
benign polyps in the control females was unusually low
for this commonly occurring proliferative lesion that
may represent an aging, hormonal-type response. Moreover,
the incidence in high-dose females is only slightly
above the overall total mean historical rate (35/727
or 4.8%), and well below the maximal spontaneous incidence
(8/60 or 13.3%). Therefore, the occurrence of this benign
proliferative lesion in females of the high-dose group
is not considered treatment related... Overall,
there is no indication of an endocrine effect of chlorphenapyr
in any of the studies, including the two-generation
study in rats and the oncogenicity studies in rats and
mice.
|
Liver
(click
on for all fluorinated pesticides)
The 100-fold margin
of safety is adequate to assure a reasonable certainty of no harm
to infants and children from the proposed use. As stated earlier,
the NOAEL is based on the effects observed in the rat
and mouse chronic oncogenicity studies, (reduced bwt gains,
increased globulin and cholesterol values and
increased liver weights in the rat and reduced bwt gains
and vacuolation of white matter of the mouse brain)...
Ref: Federal Register: August 26, 1999 [Page
46677-46680]. Notice of Filing; Pesticide Petition.
http://www.fluoridealert.org/pesticides/Chlorfenapyr.FR.Aug.26.1999.htm
-- The no observed
adverse effect level from the 28-day dermal toxicity study of
100 mg/kg/day for short- and intermediate-term occupational or
residential risk assessments is based on increased cholesterol,
relative liver weights and cytoplasmic
vacuolation of the liver in male and females
rabbits at the lowest observed
adverse effect level of 400 mg/kg.
Ref: US EPA. Summary of Chlorfenapyr Risk
Benefit Assessment.
http://www.fluorideaction.org/chlor-summ.pdf
-- Subchronic Studies...
A 28-Day Rat Feeding Study", J.E.
Fischer; Non-guideline; Rat; American Cyanamid Company, Toxicology
Department, Princeton, NJ; Report No. T-0221; 8/30/91; AC 303,630
Technical (purity: 98.4%); 5 animals/sex/group; Doses: 0, 600,
900, 1200, 1600, 2000 ppm (males-0, 68.3, 106.3, 134.2, 176.8,
243.0 mg/kg/day, females-0, 71.6, 108.4, 138.5, 184.8, 245.5 mg/kg/day),
in the diet, 4 weeks... Necropsy: increased
absolute liver weight (M-1600, F-900, 1200,
1600, 2000 ppm)... Target organ: liver; NOEL: (M/F)
1200 ppm (based on increased SGPT activity, incidence of hepatocellular
hypertrophy and increased relative liver weight in 1600 ppm treatment
group); Study supplemental. (Moore, 1/30/95)
Ref: Summary of Toxicological Data for Chlorfenapyr.
California EPA. Department of Pesticide Regulation. Medical Toxicology
Branch. August 24, 2001.
http://www.fluorideaction.org/pesticides/chlorfenapyr.ca.epa.aug2001.pdf
-- MRID No. 42770219
(1993)-- 90-Day oral toxicity rats.
NOAEL = 24.1 mg/kg/day. LOAEL = 48.4, based on spongiform myelopathy
in the brain and spinal cord of male rats,
decreased body weight gain and increased relative liver weight
in males and females, increased
absolute liver weight in females, and
decreased hemoglobin in females.
- MRID No. 43492831 (1993). 21/28-Day dermal toxicity rabbit.
NOAEL = 100 mg/kg/day. LOAEL = 400 mg/kg/day, for both sexes,
based on changes in liver chemistry and
morphology.
-- Classification: ``Suggestive Evidence
of Carcinogenicity, but Not Sufficient to Assess Human Carcinogenic
Potential'' based on significant
trends in liver tumors (adenomas and combined adenomas/ carcinomas),
malignant histiocytic sarcomas, and testicular cell tumors in
male rats and uterine polyps in female rats seen at the highest
dose.
Ref:
Federal Register: September 26, 2003. Chlorfenapyr; Pesticide
Tolerance. Final Rule.
http://www.fluorideaction.org/pesticides/chlorfenapyr.fr.sept26.2003.htm
Spinal
Cord (click
on for all fluorinated pesticides)
-- MRID No. 42770219
(1993)-- 90-Day oral toxicity rats.
NOAEL = 24.1 mg/kg/day. LOAEL = 48.4, based on
spongiform myelopathy in the brain and spinal
cord of male rats, decreased body
weight gain and increased relative liver weight in males and females,
increased absolute liver weight in females, and decreased hemoglobin
in females.
Ref:
Federal Register: September 26, 2003. Chlorfenapyr; Pesticide
Tolerance. Final Rule.
http://www.fluorideaction.org/pesticides/chlorfenapyr.fr.sept26.2003.htm
ii. Subchronic Oral
Toxicity in Mice... Spongiform encephalopathy
was noted in the brain and myelin of the spinal
cord of both males and females receiving the 320 ppm treatment
level. The LEL is 14.8 mg/kg/day (80 ppm) for male mice and 40.0
mg/kg/day (160 ppm) for female mice, based on hepatic cell hypertrophy
in 20% of the test animals at this treatment level. The NOEL
is 7.1 mg/kg/day (40 ppm)... The RfD Committee also recommended
that a special developmental neurotoxicity study be conducted
based upon the effects of a spongyform myelopathy
and/or
vacuolation seen in the brain and spinal cord
of treated rats and mice. They concluded that the registrant should
also conduct a mechanistic study to determine the cause/relationship
of CNS/myelinopathic alterations to neurotoxicity (including developmental)...
Chronic-Term (greater than several months) Occupational/Residential
Dermal NOEL: 3 mg/kg/day (decreased body weight gains brain
lesions (vacuolation) and/or
scabbing of the skin in a 1 year neurotoxicity study in rats and
a chronic/carcinogenicity study in mice) Acceptable MOE = 1000
(includes FQPA Factor)
Ref: US EPA, Feb 12, 1998: Chlorfenapyr
- 129093: Health Effects Division Risk Characterization for Use
of the Chemical Chlorfenapyr.
http://www.epa.gov/opprd001/chlorfenapyr/memohed2.pdf
Note:
Page 19-20: "Other chronic effects. For other chronic effects,
a Reference Dose (RfD) has been established at 0.003 mg/kg/day
based on decreased body weight gains and brain
lesions (vacuolation) observed in the 1-year rat neurotoxicity
study. An uncertainty factor (UF) of 1000 was applied to account
for interspecies extrapolation, intraspecies variability and
the additional FQPA Factor of 10. The FQPA factor has been retained
because chlorfenapyr has produced central nervous system lesions
in several studies in both rats and mice. It will be reevaluated
after the developmental neurotoxicity study has been submitted."
Ref: US EPA. March 13, 2000. "Denial of
Registration of Chlorfenapyr for Use on Cotton."
http://www.epa.gov/opprd001/chlorfenapyr/chlorfenapyr.pdf
Note:
In a search of EPA's OPP database <http://www.epa.gov/pesticides/search.htm>
for "spongiform encephalopathy" - "spongyform
myelopathy" and "spongyform" - , the only
substance cited was Chlorfenapyr. Mad Cow Disease is also called
Bovine spongiform encephalopathy (BSE) which is a chronic, degenerative
disorder affecting the central nervous system of cattle. In
the US, up until 2002, there were 19 tolerances for residues
of Chlorfenapyr in or on: Cotton,
Milk, Cattle, Hog, Sheep, Horse, and Goat - see:
http://www.fluorideaction.org/pesticides/chlorfenapyr.us.residuefood.htm
ONCOGENICITY, MOUSE
. 066; 147076; "A Chronic Dietary Toxicity
and Oncogenicity Study with AC 303,630 in Mice" (L. Bernier,
Bio-Research Lab., Ltd., Quebec, Canada, Project # 84580, 8/22/94).
AC 303,630 (Batch AC-7504-59A, 94.5% purity) administered orally
in the diet to 65 CD-1 mice/sex/dose for 80 weeks at 0, 20, 120,
or 240 ppm (Males: 0, 2.8, 16.6, or 34.5 mg/kg/day; Females: 0,
3.7, 21.9, or 44.5 mg/kg/day). Reduced survival rate was noted
in high dose females (60% vs. 80%, p < 0.05). However, overall
survival rate of this group was more comparable to that of the
historical controls. Treatment with AC 303,630 resulted in reduced
mean body weight gain in high dose males and females and in mid
dose females (Males: 70% of control, p < 0.01, Females: 86% of
control, p < 0.05 for mid and high dose groups). Food consumption
was also reduced in mid and high dose animals.
Histopathology revealed vacuolation of the white matter of the
brain in animals treated at mid and high dose levels. Also, vacuolation
was detected in spinal cord sections
as well as optic nerve tissues in mice at
240 ppm. There was no evidence
of carcinogenicity. NOAEL (M/F) = 240 ppm [No adverse effect].
NOEL (M/F) = 20 ppm (2.8 and 3.7 mg/kg/day for males and
females, respectively; based on histopathological changes in the
brain, optic nerve and spinal cord). acceptable (Leung, 7/24/96)
-- NEUROTOXICITY ** 061; 147070; "A One-Year
Dietary Neurotoxicity Study with AC 303,630 in Rats"; (J.A.
Foss; Argus Research Laboratories, Inc., Horsham, PA; Study No.
101-019; 5/10/94); AC 303,630 technical (purity: 94.5%) was administered
in the diet to 25 animals/sex/group at doses of 0, 60, 300, and
600 ppm for up to 52 weeks ((M)-0, 2.6, 13.6, 28.2 mg/kg/day,
(F)-0, 3.4, 18.0, 37.4 mg/kg/day). Surviving animals were observed
for an additional 16 weeks of a recovery phase. No treatment-related
effects were noted in the functional observational battery or
the motor activity evaluation. In the neurohistopathology,
myelin sheath swelling of the spinal nerve roots was evident in
the males of the 600 ppm treatment group after 13 and 52
weeks of treatment. Extensive vacuolar myelinopathy
was noted in the brain and spinal cord of the 300 and 600 ppm
males after 52 weeks of treatment. These effects were no
longer present after the 16 week recovery period. No treatment-related
lesions were noted in the females. No adverse effects were evident.
NOEL: (M) 60 ppm (based upon the incidence of extensive vacuolar
myelinopathy in the central nervous system); (F) 600 ppm;
NOAEL: 600 ppm (based on recovery). Study acceptable. (Moore,
7/29/96)
-- SUBCHRONIC STUDIES
** 010, 031; 125163; "AC 303,630: A 13 Week
Dietary Toxicity Study in the Albino Rat", J.E. Fischer;
821; Rat; American Cyanamid Co., Agricultural Research Division,
Toxicology Department, Princeton, NJ; Study No. T-0316; 4/8/93;
AC 303,630 Technical (purity: 93.6%); 20 animals/sex/group; Doses:
0, 150, 300, 600, 900, 1200 ppm (M: 0, 10.9, 22.0, 44.9, 69.5,
92.2 mg/kg/day, F: 0 11.7, 24.1, 48.4, 72.5, 97.5 mg/kg/day),
in the diet, 13 weeks; No treatment-related mortality; Clinical
Observations: red. body wgt. gain (M,F-900, 1200 ppm), red. food
consumption (M-600 ppm and up); Ophthalmology, Urinalysis: no
treatment-related effects; Hematology: red. hematocrit (M,F-1200,
F-900 ppm), red. hemoglobin (M,F-1200, F-600, 900 ppm), red blood
cells (M,F-1200, F-900 ppm), Clinical Chemistry: incr. BUN (M,F-1200
ppm, week 6, M-1200 ppm, week 13), incr. alk. phosphatase activity
(M,F-900, 1200 ppm, week 13); Necropsy: incr. mean abs. liver
wgt. (F-600 ppm and up), red. abs. kidney wgt (M,F-900, 1200 ppm),
incr. abs. spleen wgt. (M,F-900, 1200 ppm), incr. rel. liver wgt.
(M,F-600, 900, 1200, M-300 ppm), increased relative spleen weight
(M,F-900, 1200 ppm); Histopathology: spongiform
myelopathy in brain, spinal cord (M-(2/20), 1200, 900 ppm, (1/20),
600 ppm), lesion present in sciatic nerve (M-(1/20), 1200
ppm), lymphoid cell infiltrate in kidneys (M,F-900, 1200 ppm);
Target organ: central nervous system;
Adverse Effect: spongiform myelopathy in
the nervous system; NOEL: (M) 300 ppm (occurance of spongiform
myelopathy in the nervous system of the 600 ppm group) (F)
300 ppm (based on increased mean abs. liver wgt. in 600 ppm group);
(Study previously unacceptable, possibly upgradeable with submission
of GLP compliance and QA audit statements (Moore, 2/1/95)) requested
information submitted; Study acceptable. (Moore, 8/9/95)
Ref: August
24, 2001 - Summary
of Toxicological Data. California EPA.
Department of Pesticide Regulation. Medical Toxicology Branch.
Also available at: http://www.cdpr.ca.gov/docs/toxsums/pdfs/3938.pdf
Environmental (click
on for all fluorinated pesticides)
According
to Kelley R. Tucker, Director of the
American Bird Conservancy's Pesticides and Birds
Campaign: "Testing and close scientific evaluation by EPA
and independent scientists clearly revealed the persistence
of this pesticide and its chronic and reproductive risks
to birds," she explained. Laboratory studies of chlorfenapyr
showed declines in test birds of close to 50% in number
of eggs laid, number of viable embryos, and number of normal
hatchlings, leading EPA science staff
to label chlorfenapyr as "one of the most reproductively
toxic pesticides to avian species [the Division] has evaluated."
It was also found to persist in soils for over a year,
leading many to question its hidden, long-term effects on
the environment.
Ref:
March 16, 2000, press release from the American Bird Conservancy.
"EPA Decision Prevents Pesticide Threat to Birds Successful
campaign, led by the American Bird Conservancy, halts hazardous
pesticide."
http://www.fluorideaction.org/pesticides/chlorfenapyr.abc.mar.2000.htm
---
Long-term exposure to chlorfenapyr leads to reduced egg
production, reduced hatching success and reduced nestling
survival in the avian species tested. The fact that these
effects occur at a chlorfenapyr doses above 0.059 mg/kg-bw/day
(NOEL) active ingredient in the diet make
chlorfenapyr one of the most reproductively toxic pesticides
to avian species that EFED has evaluated. (page 13)
-- Freshwater Fish. Acute and chronic risk quotients for
freshwater fish are listed in Table 47. The results indicate
that acute high risk, restricted use, and endangered species
LOCs are exceeded for freshwater fish for aerial applications
in regions 3, 4, and 7. The chronic risk LOC is not exceeded
for freshwater fish when the 60-day EEC is employed. However,
the finding that chronic risks are not anticipated is of
low confidence because of the limited availability of chronic
effects testing data in freshwater fish, and the
persistence of the compound. (page 9)
-- Chlorfenapyr Stability in Soil
and Its Implications for Risks From Repeated Annual Use.
Laboratory aerobic soil and field dissipation studies for
chlorfenapyr show that the compound
is very stable. Indeed, chlorfenapyr’s persistence
in soil from annual treatment to annual treatment would
contribute to increasing soil residues with time.
Multiple-year applications of chlorfenapyr to cotton fields
would therefore result in asymptotic increases in soil concentrations.
As discussed for multiple-year uniform applications in the
environmental fate section, the 90 percent upper bound for
aerobic soil metabolism half-life (1.4 years, approximately
the same as the 1.3 year field disipation half-life), yields
a calculated asymptotic first-order value approaching 2.5
times the annual application amount (1.5 leftover from previous
applications plus 1.0 from the current year application).
Using the average aerobic soil half-life of 0.96 year, rather
than the upper 90% limit of 1.4 years, the asymptotic value
becomes 2.0 times the annual amount (1.0 residual plus 1.0
current). Under the assumption of minimal incidental soil
ingestion, the effects of chlorfenapyr accumulation in soil
to approximately 1.7 to 2.5 times the first year soil residue
are essentially negligible, and do not alter the outcome
of the risk assessment. However, if higher incidental soil
ingestion rates are assumed (e.g., Bier et al. (1994) suggests
soil incidental ingestion rates as high as 30% for some
probing birds), then accumulation
in soil may influence the outcome of the risk assessment
to a greater extent. In addition, if other routes
of exposure were to be considered (e.g., dermal), accumulation
of chlorfenapyr from multiple years of use would serve to
increase the exposure of chlorfenapyr in birds in any given
year. (page 15)
--
Aquatic. At the time EPA requested sediment toxicity testing,
the only protocol which had been fully developed was a 10-day
acute sediment toxicity test. However, at this time EPA
has developed a provisional guideline protocol for a 28-day
chronic sediment test. Although specific criteria for requiring
a chronic toxicity test have yet to be published, one criterion
will include the persistence of the compound. Since chlorfenapyr
has been characterized as a persistent compound, EFED
will require a chronic sediment toxicity test. In the case
of marine sediment toxicity, a chronic test is clearly justified
because the LOCs appear to be exceeded by the results of
the acute study submitted by the registrant. Because of
the recent development of protocols for chronic sediment
toxicity testing, EFED recommends that any study protocols
(including the selection of test species) developed by the
registrant to address these data requirements be submitted
to the Agency for approval prior to test initiation. (page
18)
Ref: Calculating Avian and Mammalian
Dietary Exposure Levels. . US EPA.
http://www.epa.gov/opprd001/chlorfenapyr/memoeco2.pdf
Environmental
Toxicity Data: Based on standard laboratory tests on this
formulation and the active ingredient chlorfenapyr, this
product is very toxic to fish, aquatic
invertebrates, and honeybees, and toxic to algae.
Ref: Pylon miticide. Material Safety
Data Sheet. February 13, 2001.
http://www.fluorideaction.org/pesticides/chlorfenapyr.msds.2001.pdf
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