Sulfuryl Fluoride
CAS No. 2699-79-8
March 4, 2005. Dow's petition for new food tolerances. Federal Register.
 
 

Return to Sulfuryl fluoride Index Page

FAN Notes:

• See FAN's summary of food tolerances for sulfuryl fluoride that have been approved and petitioned for.

• Methyl bromide, an ozone depleter, is the most frequently used fumigant used on food commodities in the US. The US is the only industrialialized country that has refused to ban the use of methyl bromide. While there are other fumigant alternatives, only sulfuryl fluoride would reap profits for Dow. See the many tolerances for Methyl bromide, the majority of which Dow and EPA want to replace with sulfuryl fluoride. Note that fumigants -used to kill insects, insect eggs, and microorganisms- are the most acutely toxic pesticides used in agriculture.

• Dow's March 4, 2005, petition for new tolerances appears below the followingTable.

FAN's summary of Dow's petition
Raw Agricultural Commodities 
Residues in or on the raw agricultural commodity:

FAN comments

-- Note that the US National Organic Program allows the use of all EPA List 4 Inerts for use in organic agriculture - see List 4A and List 4B

Fluoride
(ppm)
Sulfuryl fluoride (ppm) 
Grain, cereal, forage, fodder and straw group 16, post harvest
130
2.0
Group 16 includes 50 commodities.
Grass, forage, fodder and hay group 17, post harvest
130
2.0
Group 17 includes 360 commodities.
Herbs and spices group 19, post harvest
50
0.3
Group 19 includes 135 commodities.
Note: herbs and spices are included in the 4A Inert catetory: "Commonly consumed food commodities conforming to 40 CFR 180.950(a)"
Vegetable, legume, group 06, post harvest
6
0.02
Group 06 includes 57 commodities.
Animal feed
130
2.0
-
Beef, meat
40
0.01
-
Ham
20
0.01
-
Egg
850
0.7

The following are 4B Inerts:
• "Eggs (raw and processed forms)"
• "Egg white"

Dow states in this petition: "The highest fluoride levels were 754 ppm in powdered eggs."

Cottonseed, post harvest
13
0.2
"Cottonseed meal" is a 4A Inert
Peanut, post-harvest
13
0.2
The following are 4B Inerts:
• "Peanut meal"
• "Peanut shells"
• "Peanuts (raw and processed forms)"
Cocoa bean, post harvest
12
0.8
"Cocoa" is a 4A Inert
Coffee, post harvest
12
0.8
"Coffee grinds" is a 4A Inert
Cheese, post harvest
5
0.5
"Cheese" is a 4B Inert.
Milk
3
1.5
The following are 4B Inerts:
• "Milk (raw and processed forms)"
• "Milk, hydrolyzed"
Other processed food
70
1.2

An unknown number of processed foods would be included in the 4A Inert category:

"Commonly consumed food commodities conforming to 40 CFR 180.950(a)"

Rice flour, post harvest
98
0.08

Potential for inclusion in the List 4A Inert category:

"Commonly consumed food commodities conforming to 40 CFR 180.950(a)"

Need to confirm with US EPA if these commodities come under this 4A Inert category.

Flour, post harvest
98
1.2
Coconut, post harvest
40
1.0
Ginger, post harvest
13
0.2
Nut, pine, post harvest
10
3.0


http://www.epa.gov/fedrgstr/EPA-PEST/2005/March/Day-04/p4281.htm

[Federal Register: March 4, 2005 (Volume 70, Number 42)]
[Notices]
[Page 10621-10625]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr04mr05-55]
-----------------------------------------------------------------------

ENVIRONMENTAL PROTECTION AGENCY
[OPP-2005-0067; FRL-7701-8]

Sulfuryl Fluoride; Notice of Filing a Pesticide Petition to
Establish Tolerances for a Certain Pesticide Chemical in or on Food

AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
-----------------------------------------------------------------------

SUMMARY: This notice announces the initial filing of a pesticide
petition proposing the establishment of regulations for residues of a
certain pesticide chemical in or on various food commodities.

DATES: Comments, identified by docket identification (ID) number OPP-
2005-0067
, must be received on or before April 4, 2005.

ADDRESSES: Comments may be submitted electronically, by mail, or
through hand delivery/courier. Follow the detailed instructions as
provided in Unit I. of the SUPPLEMENTARY INFORMATION.

FOR FURTHER INFORMATION CONTACT: Suku Oonnithan, Registration Division
(7505C), Office of Pesticide Programs, Environmental Protection Agency,
1200 Pennsylvania Ave., NW., Washington, DC 20460-0001; telephone
number: 703-605-0368; e-mail address: oonnithan.suku@epa.gov .

SUPPLEMENTARY INFORMATION:

I. General Information

A. Does this Action Apply to Me?

You may be potentially affected by this action if you are an
agricultural producer, food manufacturer, or pesticide manufacturer.
Potentially affected entities may include, but are not limited to:

• Crop production (NAICS 111)
• Animal production (NAICS 112)
• Food manufacturing (NAICS 311)
• Pesticide manufacturing (NAICS 32532)

This listing is not intended to be exhaustive, but rather provides
a guide for readers regarding entities likely to be affected by this
action. Other types of entities not listed in this unit could also be
affected. The North American Industrial Classification System (NAICS)
codes have been provided to assist you and others in determining
whether this action might apply to certain entities. If you have any
questions regarding the applicability of this action to a particular
entity, consult the person listed under FOR FURTHER INFORMATION CONTACT.

[[Page 10622]]

B. How Can I Get Copies of this Document and Other Related Information?

1. Docket. EPA has established an official public docket for this
action under docket ID number OPP-2005-0067. The official public docket
consists of the documents specifically referenced in this action, any
public comments received, and other information related to this action.
Although a part of the official docket, the public docket does not
include Confidential Business Information (CBI) or other information
whose disclosure is restricted by statute. The official public docket
is the collection of materials that is available for public viewing at
the Public Information and Records Integrity Branch (PIRIB), Rm. 119,
Crystal Mall #2, 1801 S. Bell St., Arlington, VA. This docket
facility is open from 8:30 a.m. to 4 p.m., Monday through Friday,
excluding legal holidays. The docket telephone number is (703) 305-5805.

2. Electronic access. You may access this Federal Register document
electronically through the EPA Internet under the ``Federal Register''
listings at http://www.epa.gov/fedrgstr/ .

An electronic version of the public docket is available through
EPA's electronic public docket and comment system, EPA Dockets. You may
use EPA Dockets at http://www.epa.gov/edocket/ to submit or view public
comments, access the index listing of the contents of the official
public docket, and to access those documents in the public docket that
are available electronically. Although not all docket materials may be
available electronically, you may still access any of the publicly
available docket materials through the docket facility identified in
Unit I.B.1. Once in the system, select ``search,'' then key in the
appropriate docket ID number.

Certain types of information will not be placed in the EPA Dockets.
Information claimed as CBI and other information whose disclosure is
restricted by statute, which is not included in the official public
docket, will not be available for public viewing in EPA's electronic
public docket. EPA's policy is that copyrighted material will not be
placed in EPA's electronic public docket but will be available only in
printed, paper form in the official public docket. To the extent
feasible, publicly available docket materials will be made available in
EPA's electronic public docket. When a document is selected from the
index list in EPA Dockets, the system will identify whether the
document is available for viewing in EPA's electronic public docket.
Although not all docket materials may be available electronically, you
may still access any of the publicly available docket materials through
the docket facility identified in Unit I.B. EPA intends to work towards
providing electronic access to all of the publicly available docket
materials through EPA's electronic public docket.

For public commenters, it is important to note that EPA's policy is
that public comments, whether submitted electronically or in paper,
will be made available for public viewing in EPA's electronic public
docket as EPA receives them and without change, unless the comment
contains copyrighted material, CBI, or other information whose
disclosure is restricted by statute. When EPA identifies a comment
containing copyrighted material, EPA will provide a reference to that
material in the version of the comment that is placed in EPA's
electronic public docket. The entire printed comment, including the
copyrighted material, will be available in the public docket.
Public comments submitted on computer disks that are mailed or
delivered to the docket will be transferred to EPA's electronic public
docket. Public comments that are mailed or delivered to the docket will
be scanned and placed in EPA's electronic public docket. Where
practical, physical objects will be photographed, and the photograph
will be placed in EPA's electronic public docket along with a brief
description written by the docket staff.

C. How and To Whom Do I Submit Comments?

You may submit comments electronically, by mail, or through hand
delivery/courier. To ensure proper receipt by EPA, identify the
appropriate docket ID number in the subject line on the first page of
your comment. Please ensure that your comments are submitted within the
specified comment period. Comments received after the close of the
comment period will be marked ``late.'' EPA is not required to consider
these late comments. If you wish to submit CBI or information that is
otherwise protected by statute, please follow the instructions in Unit
I.D. Do not use EPA Dockets or e-mail to submit CBI or information
protected by statute.

1. Electronically. If you submit an electronic comment as
prescribed in this unit, EPA recommends that you include your name,
mailing address, and an e-mail address or other contact information in
the body of your comment. Also include this contact information on the
outside of any disk or CD ROM you submit, and in any cover letter
accompanying the disk or CD ROM. This ensures that you can be
identified as the submitter of the comment and allows EPA to contact
you in case EPA cannot read your comment due to technical difficulties
or needs further information on the substance of your comment. EPA's
policy is that EPA will not edit your comment, and any identifying or
contact information provided in the body of a comment will be included
as part of the comment that is placed in the official public docket,
and made available in EPA's electronic public docket. If EPA cannot
read your comment due to technical difficulties and cannot contact you
for clarification, EPA may not be able to consider your comment.

i. EPA Dockets. Your use of EPA's electronic public docket to
submit comments to EPA electronically is EPA's preferred method for
receiving comments. Go directly to EPA Dockets at http://www.epa.gov/
edocket/ , and follow the online instructions for submitting comments.
Once in the system, select ``search,'' and then key in docket ID number
OPP-2005-0067. The system is an ``anonymous access'' system, which
means EPA will not know your identity, e-mail address, or other contact
information unless you provide it in the body of your comment.

ii. E-mail. Comments may be sent by e-mail to opp-docket@epa.gov ,
Attention: Docket ID Number OPP-2005-0067. In contrast to EPA's
electronic public docket, EPA's e-mail system is not an ``anonymous
access'' system. If you send an e-mail comment directly to the docket
without going through EPA's electronic public docket, EPA's e-mail
system automatically captures your e-mail address. E-mail addresses
that are automatically captured by EPA's e-mail system are included as
part of the comment that is placed in the official public docket, and
made available in EPA's electronic public docket.

iii. Disk or CD ROM. You may submit comments on a disk or CD ROM
that you mail to the mailing address identified in Unit I.C.2. These
electronic submissions will be accepted in WordPerfect or ASCII file
format. Avoid the use of special characters and any form of encryption.

2. By mail. Send your comments to: Public Information and Records
Integrity Branch (PIRIB) (7502C), Office of Pesticide Programs (OPP),
Environmental Protection Agency, 1200 Pennsylvania Ave., NW.,
Washington, DC 20460-0001, Attention: Docket ID Number OPP-2005-0067.

3. By hand delivery or courier. Deliver your comments to: Public
Information

[[Page 10623]]

and Records Integrity Branch (PIRIB), Office of Pesticide Programs
(OPP), Environmental Protection Agency, Rm. 119, Crystal Mall
#2, 1801 S. Bell St., Arlington, VA, Attention: Docket ID
Number OPP-2005-0067. Such deliveries are only accepted during the
docket's normal hours of operation as identified in Unit I.B.1.
D. How Should I Submit CBI to the Agency?
Do not submit information that you consider to be CBI
electronically through EPA's electronic public docket or by e-mail. You
may claim information that you submit to EPA as CBI by marking any part
or all of that information as CBI (if you submit CBI on disk or CD ROM,
mark the outside of the disk or CD ROM as CBI and then identify
electronically within the disk or CD ROM the specific information that
is CBI). Information so marked will not be disclosed except in
accordance with procedures set forth in 40 CFR part 2.

In addition to one complete version of the comment that includes
any information claimed as CBI, a copy of the comment that does not
contain the information claimed as CBI must be submitted for inclusion
in the public docket and EPA's electronic public docket. If you submit
the copy that does not contain CBI on disk or CD ROM, mark the outside
of the disk or CD ROM clearly that it does not contain CBI. Information
not marked as CBI will be included in the public docket and EPA's
electronic public docket without prior notice. If you have any
questions about CBI or the procedures for claiming CBI, please consult
the person listed under FOR FURTHER INFORMATION CONTACT.

E. What Should I Consider as I Prepare My Comments for EPA?

You may find the following suggestions helpful for preparing your
comments:

1. Explain your views as clearly as possible.
2. Describe any assumptions that you used.
3. Provide copies of any technical information and/or data you used
that support your views.
4. If you estimate potential burden or costs, explain how you
arrived at the estimate that you provide.
5. Provide specific examples to illustrate your concerns.
6. Make sure to submit your comments by the deadline in this notice.
7. To ensure proper receipt by EPA, be sure to identify the docket
ID number assigned to this action in the subject line on the first page
of your response. You may also provide the name, date, and Federal
Register citation.

II. What Action is the Agency Taking?

EPA has received a pesticide petition as follows proposing the
establishment and/or amendment of regulations for residues of a certain
pesticide chemical in or on various food commodities under section 408
of the Federal Food, Drug, and Cosmetic Act (FFDCA), 21 U.S.C. 346a.
EPA has determined that this petition contains data or information
regarding the elements set forth in FFDCA section 408(d)(2); however,
EPA has not fully evaluated the sufficiency of the submitted data at
this time or whether the data support granting of the petition.
Additional data may be needed before EPA rules on the petition.

List of Subjects

Environmental protection, Agricultural commodities, Feed additives,
Food additives, Pesticides and pests, Reporting and recordkeeping
requirements.

Dated: February 25, 2005.
Lois Rossi,
Director, Registration Division, Office of Pesticide Programs.

Summary of Petition

PP 3F6573

The petitioner summary of the pesticide petition is printed below
as required by FFDCA section 408(d)(3). The summary of the petition was
prepared by the petitioner and represents the view of the petitioner.

The petition summary announces the availability of a description of the
analytical methods available to EPA for the detection and measurement
of the pesticide chemical residues or an explanation of why no such
method is needed.

EPA has received a pesticide petition (PP 3F6573) from Dow
AgroSciences LLC
, 9330 Zionsville Road, Indianapolis, IN 46268
proposing, pursuant to section 408(d) of the Federal Food, Drug, and
Cosmetic Act (FFDCA), 21 U.S.C. 346a(d), to amend 40 CFR part 180 by
establishing tolerances for residues of:

1. Fluoride in or on the following raw agricultural commodities:
Animal feed at 130 parts per million (ppm), beef, meat at 40 ppm;
cheese, post harvest at 5 ppm; cocoa bean, post harvest at 12 ppm;
coconut, post harvest at 40 ppm; coffee, post harvest at 12 ppm;
cottonseed, post harvest at 13 ppm; egg at 850 ppm; ginger, post
harvest at 13 ppm; grain, cereal, forage, fodder and straw group 16,
post harvest at 130 ppm; grass, forage, fodder and hay group 17, post
harvest at 130 ppm; ham at 20 ppm; herbs and spices group 19, post
harvest at 50 ppm; milk at 3 ppm; nut, pine, post harvest at 10 ppm;
other processed food at 70 ppm; peanut, post-harvest at 13 ppm; rice
flour, post harvest at 98 ppm; and vegetable, legume, group 06, post
harvest at 6 ppm.

2. Sulfuryl fluoride in or on the following raw agricultural
commodities: Animal feed at 2.0 ppm; beef, meat at 0.01 ppm; cheese,
post harvest at 0.5 ppm; cocoa bean, post harvest at 0.8 ppm; coconut,
post harvest at 1.0 ppm; coffee, post harvest at 0.8 ppm; cottonseed,
post harvest at 0.2 ppm; egg at 0.7 ppm; ginger, post harvest at 0.2
ppm; grain, cereal, forage, fodder and straw group 16, post harvest at
2.0 ppm; grass, forage, fodder and hay group 17, post harvest at 2.0
ppm; ham at 0.01 ppm; herbs and spices group 19, post harvest at 0.3
ppm; milk at 1.5 ppm; nut, pine, post harvest at 3.0 ppm; other
processed food at 1.2 ppm; peanut, post-harvest at 0.2 ppm; rice flour,
post harvest at 0.08 ppm; and vegetable, legume, group 06, post harvest
at 0.02 ppm.

EPA has determined that the petition contains data or information
regarding the elements set forth in section 408(d)(2) of the FFDCA;
however, EPA has not fully evaluated the sufficiency of the submitted
data at this time or whether the data supports granting of the
petition. Additional data may be needed before EPA rules on the petition.

A. Residue Chemistry

1. Plant metabolism. The metabolism of sulfuryl fluoride is
adequately understood for the purposes of this tolerance. Potential
residues of sulfuryl fluoride and its degradation product fluoride and
sulfate were investigated. Residues of sulfuryl fluoride in treated
commodities are transient and rapidly decrease to very low (parts per
billion (ppb)) or non-detectable levels. Residues of fluoride and
sulfate resulting from the fumigation of commodities with sulfuryl
fluoride were measurable and predictable. Sulfate as a terminal residue
of sulfuryl fluoride is not considered of toxicological significance
due to its natural abundance and pervasiveness in living systems.

2. Analytical method. Analytical methods have been developed and
validated to determine the residues of sulfuryl fluoride and fluoride
in the listed commodities. The sulfuryl fluoride method is based on gas
chromatography/electron capture detector (GC-ECD) with a limit of
quantitation (LOQ) of 8.0 ppb in grains and grain processed products
and 4.0

[[Page 10624]]

ppb in all other commodities. The fluoride method utilizes a fluoride
ion specific electrode. The fluoride ion method was validated with an
LOQ of 0.5 ppm in grains and grain processed products and 1.0 ppm in
all other commodities.

3. Magnitude of residues. Cereal and small grains and their
processed products were treated with sulfuryl fluoride at target doses
ranging from 200 mg hr/L to 1500 mg hr/L. Sulfuryl fluoride dissipated
rapidly with residues at less than the LOQ (with one exception),
immediately following the 24-hr aeration. One sample (white corn) at
the 1,500 mg hr/L dose showed a residue of 0.019 ppm after the 24-hr
aeration interval. Fluoride ion residues measured in whole grains
following the fumigations ranged from less than the LOQ to 1.8 ppm (200
mg hr/L dose level) and from 1.0 to 7.5 ppm (1,500 mg hr/L dose level).
The processing of sulfuryl fluoride-fumigated whole grain wheat
containing fluoride ion at 1.19 ppm yielded flour, shorts, bran,
middlings, impurities, and germ containing fluoride ion at 0.446 ppm,
1.50 ppm, 3.05 ppm, 0.718 ppm, 1.07 ppm, and 5.74 ppm, respectively.
The processing of fumigated whole grain corn containing fluoride ion at
1.76 ppm produced flour, meal, grits, impurities, containing fluoride
ion at 1.29 ppm, 1.37 ppm, 0.826 ppm, and 9.67 ppm. Fluoride ion was
below the LOQ (0.3 ppm) in corn oil (dry- and wet-milled) and wet-
milled starch. Fluoride ion residues were consistently higher in
processed products than in the whole grains. Fluoride ion residues in
mill-fumigated processed products (germ, flour, meal) ranged from 7 to
90 ppm, with residues generally following the order of wheat germ being
greater than wheat flour, being greater than corn flour, being greater
than corn meal. Finished food products and key ingredients were
fumigated with sulfuryl fluoride (SF) in controlled exposures to
determine the magnitude of sulfuryl fluoride and terminal fluoride
anion. Most of the finished food products were fumigated in their
retail packaging and also in open configuration (removed from packages)
to compare residue levels resulting from those two packaging
configurations. Portions (typically 200 - 2,000g) of each commodity
were exposed in single, 24-hr fumigations to a SF concentration of 62.5
mg/L (CT Product of 1,500 mg hr/L), at an exposure temperature of 30 C.
Following fumigation and aeration, the commodities were analyzed to
determine residue levels of sulfuryl fluoride and fluoride anion. The
tested food commodities were exposed in a combination of packaged and
open configuration. Sulfuryl fluoride was not present above the limit
of quantitation (4 ppb) in twelve commodities fumigated in open
configuration, nor in three commodities fumigated in packaged
configuration. Only five of the fumigated commodities had SF residue
levels that exceeded 1,000 ppb with the highest level being 1,864 ppb.
The SF concentrations rapidly decayed in the tested commodities between
post-fumigation Day 1 and Day 2. Fluoride ion was not present above the
LOQ (1 ppm) in four commodities fumigated in open configuration, nor in
seven commodities fumigated in packaged configuration. Thirty-five (of
the 39) commodities fumigated with SF in the open configuration had
quantifiable levels of fluoride which ranged from 1.03 to 754 ppm. The
highest fluoride levels were 754 ppm in powdered eggs.
Of the 20
commodities fumigated in packaged configuration, 13 had quantifiable
fluoride levels, but the fluoride concentrations were less than 12 ppm
for all package-fumigated commodities with one exception. The
comparative results of fluoride residues in commodities fumigated under
packaged versus open fumigation conditions indicate that the packaging
in most cases does function as a barrier that isolates the contents of
the package from external SF atmospheres or at least attenuates the
inner-package concentration of SF to which the commodities are exposed.

On the basis of the residues of fluoride and sulfuryl fluoride that
were evaluated, the tolerances identified are supported for the listed
commodities.

B. Toxicological Profile

1. Acute toxicity. The acute LC50 for sulfuryl fluoride is 642 ppm
1,088 milligram/kilogram body weight (mg/kg/bwt) for CD-1 mice exposed
for four hours.

2. Genotoxicity. Genetic toxicity did not occur when sulfuryl
fluoride was tested in multiple in vivo and in vitro tests.

3. Reproductive and developmental toxicity. Sulfuryl fluoride did
not have any effects on reproductive parameters at dose levels that
induced treatment related effects in parental rats and rabbits. In
addition, a teratogenic potential for sulfuryl fluoride was not
demonstrated in either rats or rabbits at dose levels that induced
maternal toxicity.

4. Subchronic toxicity. Several 2-week repeated dose inhalation
studies indicate for mice a no observed adverse effect level (NOEL) of
30 ppm; for rat, rabbit, and beagle dog a NOEL of 100 ppm.

5. Chronic toxicity. The lowest reported chronic NOEL for sulfuryl
fluoride is 5 ppm based on a 2-year inhalation study with Fischer 344
rats and the parental NOEL in a two-generation rat reproduction study.
There was no evidence of carcinogenicity in 2-year rat and 18-month
mouse studies.

6. Animal metabolism. Rats fed a diet that had been fumigated by
sulfuryl fluoride at a rate of 2 lb/1,000 cu ft (containing fluoride
levels of 19 ppm above the control level of 36 ppm) for 66 days
experienced an increase in the fluoride content of their bones.
The
National Research Council in their 1993 report on fluoride concluded
that fluoride is readily absorbed by the gut and rapidly becomes
associated with teeth and bones. The remaining fluoride is eliminated
almost exclusively by the kidneys with the rate of renal clearance
related directly to urinary pH.

7. Metabolite toxicology. Clinical symptoms of acute fluoride
poisoning in humans are characterized by nausea, vomiting, diarrhea,
abdominal pain, and paresthesia. The frequently cited ``probably toxic
dose,'' the dose which should trigger therapeutic intervention and
hospitalization, is 5 mg/kg/bwt calculated for the lowest third
percentile of the infant population. Five to 10 grams of sodium
fluoride (NaF) is considered the certainly lethal dose (CLD) for a 70
kg adult (32 to 64 mg fluoride per kg body weight). One-quarter of the
CLD can be ingested without producing serious acute toxicity and is
known as the safely tolerated dose, i.e., 8 to 16 mg of fluoride per kg
of body weight.
The Council on Dental Therapeutics of the American
Dental Association recommends that ``no more than 264 mg of NaF (120 mg
F) be dispensed at any one time'' in dental treatments to prevent the
accidental poisoning of an infant weighing as little as 10 kilograms.

The U.S. EPA (Cryolite Reregistration Eligibility Decision [RED], 8/96)
determined a Maximum Concentration Limit Goal (MCLG) of 0.114 mg/kg/day
for fluoride which provides protection from any known or anticipated
adverse health effects
. The MCLG has been reviewed and supported by the
Surgeon General.
The National Toxicology Program (NTP) has concluded
that there was ``no evidence'' of carcinogenic activity in male or
female mice administered sodium fluoride in drinking water for 2 years.

8. Endocrine disruption. There is no evidence from any studies to
suggest that sulfuryl fluoride or fluoride are endocrine disrupters.

[[Page 10625]]

C. Aggregate Exposure

1. Dietary exposure. The Dietary Exposure Evaluation Model (DEEM),
version 7.76, of Novigen Sciences, Inc. was used to estimate the
dietary exposure to the U.S. population and critical sub-populations
resulting from the use of sulfuryl fluoride under the conditions
proposed. The highest potential chronic exposures to sulfuryl fluoride
was to children ages 1 to 6 years resulting from the consumption of
treated commodities totaling 0.00009 mg/kg/bwt/day. Likewise, the
highest potential chronic exposure to fluoride was to children ages 1
to 6 years with a highest estimated exposure of 0.005 mg/kg/bwt/day.

i. Food. Food tolerances as inorganic fluorine compounds exist to
support the uses of Cryolite (insecticide) and ProFume on various food
and feed commodities in the United States. The U.S. EPA, in the 2004
ProFume registration decision, conservatively estimates that the
dietary exposures to fluoride due to all sources and routes (including
the fluorination of water and the potential for fluoride residues
resulting from the uses of Cryolite) could be as high as 0.0397 mg/kg/
bwt/day. No toxicological endpoint attributable to a single exposure
was identified in the available toxicology studies on sulfuryl fluoride
or inorganic fluoride that would be applicable for an acute dietary
exposure.

ii. Drinking water. There is no anticipated exposure of sulfuryl
fluoride to drinking water. As a public health tool to aid in the
prevention of dental caries, fluoride is added to some domestic water
supplies at generally 0.8 to 1.0 ppm.

2. Non-dietary exposure. Sulfuryl fluoride (as Vikane specialty gas
fumigant) is presently used to fumigate homes and other structures to
control wood infesting insects. The existing Vikane use patterns and
exposed populations are not expected to overlap with the intended post-
harvest uses of ProFume.

D. Cumulative Effects

The primary degradation product of sulfuryl fluoride is fluoride.
The toxicity of fluoride in various forms has been extensively reviewed
and is used as an additive in treated water supplies, toothpastes,
mouth rinses, and other treatments for the prevention of dental caries.
It is also prescribed in therapeutic amounts for the treatment of
osteoporosis. Fluoride is naturally present in both food and water in
varying amounts, and has been added to public water supplies to fight
dental caries. The recommended concentration of fluoride (usually as
fluorosilicic acid) in treated water supplies is 0.8 to 1.0 ppm. The
Third Report on Nutrition Monitoring in the United States says that
``Food contributes only small amounts of fluoride and monitoring the
diet for fluoride intake is not very useful for current public health
concerns. The sub-population most susceptible to fluoride is children.
For this reason a number of studies have attempted to quantify the
fluoride intake from a variety of sources. The total daily intake of
fluoride from water (used to prepare formula, juices, and other foods)
for infants ages birth to 9 months ranged to 1.73 mg with means from
0.29 to 0.38 mg. Assuming a body weight of 10 kg, these amounts are
equivalent to 0.03 to 0.04 mg/kg/day. These levels of dietary exposure
in combination with the potential dietary exposures that the proposed
uses of ProFume would represent (chronic dietary exposures of 0.005 mg/
kg/bwt/day) are considerably lower than the U.S. EPA MCLG for fluoride
of 0.114 mg/kg/bwt/day.

E. Safety Determination

1. U.S. population. Aggregate risk from exposure to sulfuryl
fluoride would be minimal because of its rapid dissipation from any
fumigated commodity and because it is not expected to be present at the
time of food consumption. The sulfuryl fluoride residues in fumigated
foods are expected to be non-detectable at the point of food
consumption. Furthermore, if residues were considered as high as what
is found immediately following the 24 hour aeration period, the Margin
of Exposure to the most sensitive population (children) is estimated to
be greater than 150,000-fold for chronic exposures. Exposure to
fluoride, the residue of interest for sulfuryl fluoride, can occur from
foods, water, and dental treatments. The additional fluoride residues
in some commodities fumigated with sulfuryl fluoride are
indistinguishable from the natural levels of fluoride already present
and would therefore also fall within the U.S. EPA Threshold of
Regulation Policy. Alternatively, fluoride in other commodities are
expected to contribute to the fluoride that is ingested, but at levels
far below other sources, especially treated water and dentrifices.

Chronic exposure to fluoride resulting from the proposed uses of
ProFume (0.005 mg/kg/day) is much lower than the U.S. EPA's MCLG of
0.114 mg/kg/bwt/day calculated for exposure to fluorinated water. In
addition, there is no directly applicable scientific documentation of
adverse medical effects at levels of fluorine below 0.23 mg/kg/day.

2. Infants and children. Chronic exposure to fluoride from the
consumption of ProFume treated commodities would be approximately 0.005
mg/kg/day for a child age 1 to 6 years. This value is much lower than
the U.S. EPA MCLG of 0.114 mg/kg/bwt/day calculated for exposure to
fluorinated water.

F. International Tolerances

There is no Codex maximum residue level established for residues of
fluoride on any food or feed crop.
[FR Doc. 05-4281 Filed 3-3-05; 8:45 am
BILLING CODE 6560-50-S

 
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