Page 1 of 16
3.3.2 Residential Handler Exposures
Residential handler exposures are not expected based on the labeled use patterns;
therefore, a residential assessment is not anticipated as needed for this registration
review.
Page 22 of 63
3.3.3 Residential Post-Application Exposures
Population-based biological monitoring data from the NHANES data are available to
assess the exposure of the general population to PCP. The NHANES data provides an
encompassing review of all PCP exposures. Because NHANES does not include
exposures to children under the age of 6 years old, the CTEPP study will also be used
to include estimates of exposures to children under 6 years old. EPA will base the
residential exposures based on NHANES and CTEPP data and calculate non-cancer
and cancer risks. The amount of HCB and the toxicity equivalents (TEQ) of the
CDDs/CDFs in the PCP during manufacturing are used to extrapolate equivalent HCB
and dioxin exposures for PCP in treated wood.
Page 2 of 16
A potential degradate/metabolite of PCP and other compounds has been identified as
pentachloroanisole (PCA), Mol For: C7H3Cl5O; Mol.wt: 280.37, CAS# 1825-21-4. PCA
is a derivative of PCP and other chlorinated phenols found in the environmental media
(such as pentachloronitrobenzene).
The Agency has noted that the Stockholm Convention’s Persistent Organic
Pollutants Review Committee (POPRC) decided in October 2014 to recommend to
its Conference of Parties (COP) to list PCP and its salts and ester in Annex A to
the Convention with specific exemptions for the production and use of PCP for
utility poles and cross-arms. The POPRC considered PCA together with PCP in
making this determination. The COP has not yet met to decide on this
recommendation.
Page 3 of 16
1.4 PCP and Contaminants
There are three general types of contaminants in PCP. Two types are chlorinated
dioxins (CDDs)/chlorofurans (CDFs) compounds: 2, 3, 7, 8-tetrachlorodibenzo-p-dixoin
(2,3,7,8 TCDD) and generic HxCDD. The third type of contaminant is
hexachlorobenzene (HCB). In the past, the Agency has referred to these as
“microcontaminants.” For every pesticide product registered at EPA, a confidential
statement of formula (CSF) is required to report all the components and their
percentage by weight in the product. Contaminants below 0.1% are not reported on the
CSF, hence the term microcontaminants - contaminants below the 0.1% reporting limit
present at ppm levels (micro levels). These microcontaminants are herein referred to as
contaminants.
PCP registrants provide monthly reports of analytical data which inform the levels of
contaminants in the technical PCP. The samples of PCP are provided from a
manufacturing plant currently in use. Table 5 lists measured value of concentrations
in PCP products. The data are presented with written consent from the registrant for the
PCP case to demonstrate the extent to which contaminants have decreased from 1986
to 2013.
1.5 Use/Usage Description
1.5.1 Registrations
There are four EPA-registered products that contain PCP as an active ingredient (a.i.).
One of these products is a technical/formulation intermediate product, and the other
three products are end-use products. The formulations include ready-to-use solutions
and soluble concentrates. The technical/manufacturing use product contains a nominal
concentration of 86 percent PCP (other chlorophenols listed as an additional 10
percent). The nominal concentrations of the three endues products range from 4.3
percent (other chlorophenols listed as an additional 0.5 percent) to 86 percent (other
chlorophenols listed as an additional 10 percent).
Page 13 of 63
PCP is classified as a restricted use pesticide (RUP) for sale and use by certified
applicators only. Indoor applications of PCP are prohibited as well as application
to wood intended for use in interiors (with certain exceptions) or for use in
contact with food, feed, or drinking water. These restrictions were imposed on PCP
registrations as part of the Agency’s Special Review process as indicated in the
U.S.EPA Position Document 4 for Wood Preservative Pesticides: Creosote,
Pentachlorophenol and Inorganic Arsenicals (1984, amended 1986).
1.5.3 Usage Information
According to the Kline Biocides Report for 2004/2005, PCP is one of the leading wood
Page 4 of 16
preservatives for poles and is preferred by many utility companies. In 2004, U.S.
consumption of PCP was estimated at 24.5 million pounds, and was forecasted to grow
at an average volume rate of 1.6 percent. In 2004, there were only two major suppliers
of PCP (Kline, 2005).
1.6 Regulatory History
PCP has been used as a wood preservative since 1936; however, the first pesticidal
product containing PCP was registered by the United Sates Department of Agriculture
(USDA) on December 1, 1950. In 1970, EPA was established and was charged with
protecting human health and the environment, and assumed all pesticide registrations
from USDA. In October 1978, an administrative review process was initiated to consider
whether the pesticide registration of the three heavy duty wood preservative uses
(including PCP) should be canceled or modified. The Federal Register (Vol.49, No.139)
of July 13, 1984 concluded that process and announced that certain changes in the
terms and conditions of registration were required if registrants and applicants wished to
avoid cancellation.
After evaluating the risks to public health posed by these three heavy duty wood
preservative chemicals (including PCP) along with the significant economic benefits
resulting from their use, the Agency determined that the use of PCP as a wood
preservative chemical in accordance with certain modifications to terms of registration
would satisfy the statutory standard for registration. These modifications (classification
as restricted use pesticide, worker protection/protective clothing and equipment label
requirements, restricted to non-residential uses, etc.) are identified and described in the
Federal Register of January 13, 1986 (Vol.51, No. 7). Additionally, all nonpressure
treatment and non-thermal treatments for PCP products have been voluntarily deleted.
The Agency completed a Reregistration Eligibility Decision (RED) for PCP in 2008. EPA
determined that PCP products contribute benefits to society and are eligible for
reregistration provided the mitigation measures and associated label changes identified
in the 2008 RED are implemented and required data are submitted. A post-RED
Generic-Data Call-In (GDCI) and Product-Specific-Data-Call-In (PDCI) were issued on
September 21, 2011.
1.7 Incidents
1.7.1 Human Health
Based on a search conducted on October 29, 2014, covering the period from January,
1905 to January, 2008, over 300 incident reports exist in the EPA’s Incident Data
System (IDS) associated with human PCP exposures. No PCP incidents have been
reported after this time period. In addition, the number of incidents and epidemiological
studies published in scientific literature addressing possible associations between
exposure to PCP and subsequent development of disease is large. The associated
concerns include chloracne, tremors, allergies, insomnia, twitching, diarrhea, dizziness,
soft tissue sarcoma, non-Hodgkin’s lymphoma and possibly abnormal births. Whether
these deleterious health effects result from exposure to PCP
Page 5 of 16
specifically, or to one or more other chemicals typically found as contaminants, is not
clear.
3 Human Health Risk Assessment
The Agency anticipates the need to conduct an updated human health risk assessment for PCP
based upon the updated exposure study data from the 2011 post-RED DCI. PCP contains CDDs,
CDFs, and HCB as contaminants formed during the manufacturing process. Direct
measurements of CDDs/CDFs and HCBs for the general population attributed to pressure treated
wood are not available for this assessment. Therefore, to be inclusive of determining potential
exposures to PCP contaminants, the amount of HCB and the toxicity equivalents (TEQ) of the
CDDs/CDFs in the PCP during manufacturing will be used to extrapolate equivalent HCB and
dioxin exposures for PCP in treated wood. The Agency will use the latest manufacturing
reporting information about how much HCB and dioxin are present in PCP samples from the
PCP task force, which was created to respond to data requirements and other reevaluation
information for the PCP case.
Population-based biological monitoring data from the National Health and Nutrition Surveys
(NHANES) are available to assess the exposure of the general population to PCP. The NHANES
data provides an encompassing review of all PCP exposures; the specific PCP treated wood
contribution to total PCP exposure cannot be differentiated. The Agency used 2001–2002
NHANES data to inform the 2008 RED and will update the registration review risk assessment
with the latest available NHANES data from 2003-2004 or a more recent NHANES dataset
should one become available at the time of risk assessment. Because NHANES does not include
exposures to children under the age of 6 years old, the Children’s Total Exposure to Persistent
Pesticides and Other Persistent Organic Pollutants (CTEPP) study (Wilson, et al. 2007) will be
used to include estimates of exposures to children under 6 years old.
CDD and CDFs
Acute and Chronic Toxicity
The concept of toxic equivalency factors (TEFs) has been developed to facilitate risk assessment
of exposure to chemical mixtures of CDDs and CDFs. In this procedure, individual TEFs are
assigned to the various congeners of CDDs and CDFs. These values have been published by both
the USEPA and the World Health Organization (Younes, 1998) and are based on assigning
Page 6 of 16
relative values in relation to 2,3,7,8-TCDD, which is assigned a TEF value of 1.0, it being the
most potent congener. Multiplying the exposure concentration of individual congeners by their
respective TEFs yields a toxic equivalency, which, when summed for all the components of the
mixture, gives the TEQ for that mixture and is an indication of the additional exposure from the
PCP contaminants. Recent developments in science policy in the Agency have resulted in a shift
towards calculation of non-cancer risk from dioxins and furans using a body burden approach
rather than a dose or intake approach. This is appropriate for dioxin/furan contaminants of PCP
due to the long half-life of these chemicals. The Agency’s Office of Research and Development
(ORD) has led the effort in characterizing hazards and risks from exposure to dioxins and
dioxinlike compounds, and OPP, in its assessment of non-cancer risks posed by the dioxin/furan
contaminants in PCP, is working with ORD to express these risks using the methodologies
developed in ORD for calculation of body burdens from exposure to the contaminants in PCP
treated wood.
3.3.1 Occupational Exposure
The Agency conducted an occupational assessment for the RED for PCP on September 8, 2008
(U.S. EPA, 2008e). The occupational assessment was based on absorbed doses for occupational
workers using chemical-specific biological monitoring data submitted by the PCP Task Force
(MRID 44813701) and the biological monitoring data for electrical utility linemen (Thind et al.
1991).
The Agency anticipates receiving new occupational studies for the wood preservative use
(exposure studies to monitor work exposure at pressure treatment plant) in order to conduct new
occupational risk assessments to assess the dermal and inhalation routes of exposure from
pressure treatment exposure and pole lineman during registration review. The scenarios outlined
in Table 12 are the typical worker exposure scenarios for a variety of exposures. Studies
accounting for these exposure scenarios were required by the 2011 post-RED DCI (see Table 9).
For example, for pressure treatment facilities, workers operate and monitor application system
valves and controls, open and close cylinder doors (automated), and supervise the insertion and
removal of charges (loads of dried or debarked poles) of timber from the treatment cylinders.
Workers operate forklifts used to load untreated wood onto charge trams; move charges into and
out of treatment cylinders; remove charge leads and bands from treated wood; distribute treated
wood to load-out area, and load treated wood for shipment. Workers perform various labor and
cleanup duties in treatment and drip pad area including: sweeping and pressure-washing drip pad
and tracks; removing and shredding all bands from treated stacks of lumber; picking up and
disposing treated wood waste; cleaning cylinders; and, handling hazardous waste.
Page 7 of 16
3.2.2 Drinking Water
No separate human drinking water exposure assessment is expected for PCP. As
discussed above, the NHANES biomonitoring data will include any human exposures
from drinking water.
4.2 Environmental Exposure Pathways
Leachate from treated wood is likely to be the primary source of environmental
exposure to nontarget organisms. PCP and its degradates and impurities may leach into
the soil surrounding treated utility poles, fences, timbers, and other treated wood. PCP,
CDDs/CFDs, and HCB might be transported into the aquatic environment via various
environmental pathways, including runoff and leaching. PCP-treated wood used directly
in the aquatic environment will leach PCP and its’ degradates and impurities directly into
surface waters and sediments. Most material reaching the aquatic environments is
expected to bind to organic matter and sediments and expose benthic invertebrates. A
soluble fraction of the leachate also will be present in the water column and may expose
fish, aquatic invertebrates, and aquatic plants. In the water column, exposure is
expected to be acute, whereas chronic exposure is expected in aquatic sediments.
Bioconcentration in fish and aquatic invertebrates may result in exposure and
bioaccumulation in predators, such as fish-eating birds and mammals, larger fish, and
reptiles.
1
http://iaspub.epa.gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_gr
oup_id=885
2http://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_
group_id=885&p_pollutant_
group_name=PESTICIDES
3 http://www.epa.gov/owow/tmdl/
Terrestrial organisms also may be exposed via various environmental pathways. Invertebrates in
and around treated wood structures may be exposed from contaminated soil. Contaminated
invertebrates may be eaten by other terrestrial animals, including small mammals, birds, and
reptiles. Bioaccumulation may lead to higher trophic levels being exposed as PCP, CDDs/CDFs,
Page 8 of 16
and/or HCB move through the food chain.
Likely pathways for exposure of nontarget organisms are summarized below. All relevant routes
of environmental exposure will be considered in the risk assessment.
Terrestrial Organisms
• Dietary exposure of small mammals and birds to leachate in soil and food sources (e.g.,
invertebrates, seeds) on and in the soil surrounding treated wood structures.
• Dermal contact of beneficial insects, birds, and small mammals with treated wood surfaces.
• Dietary exposure of predatory mammals, birds, and reptiles to contaminated prey;
bioaccumulation may lead to exposure at higher trophic levels in the food chain.
• Ingestion of residues through drinking water sources such as puddles or roadside ditches at
the use site.
Aquatic or Semi Aquatic Organisms
• Exposure via contaminated surface waters.
• Exposure via contaminated aquatic sediments.
• Dietary exposure of predatory and herbivorous fish and reptiles to contaminated prey and
aquatic plants; bioaccumulation may lead to exposure at higher trophic levels in the food
chain.
• Uptake of residue in surface waters by aquatic plants.
• Uptake of residue in surface waters and sediments by rooted semi-aquatic plants.
A conceptual model diagram (CMD) also is available for wood preservative uses. Based on
antimicrobial use patterns, the Agency developed conceptual models for potential routes of
environmental exposure to terrestrial and aquatic receptor groups. The “Conceptual Models for
Environmental Exposure Pathways of Antimicrobial Pesticides” are located in the docket at
www.regulations.gov (EPA-HQ-OPP-2014-0638-0002). For In‐Use Service of Wood Treated
Wood Products, see page 29 in that document.
7.1.3 Environmental Justice
EPA seeks to achieve environmental justice, the fair treatment and meaningful involvement of all
people, regardless of race, color, national origin, or income, in the development, implementation,
and enforcement of environmental laws, regulations, and policies. To help address potential
environmental justice issues, the Agency seeks information on any groups or segments of the
population who, as a result of their location, cultural practices, or other factors, may have
atypical, unusually high exposure to PCP compared to the general population. Please comment
if you are aware of any sub-populations that may have atypical, unusually high exposure
compared to the general population.
7.1.4 Additional Information
Stakeholders are also specifically asked to provide available information and data that will assist
the Agency in refining its risk assessments, including any species-specific ecological effects
determinations. As mentioned in Section 1.6, the Agency determined in the 2008 RED that PCP
products contribute benefits to society and were eligible for reregistration. In registration review,
EPA plans to update the benefits and alternatives assessments for PCP. Stakeholders are
encouraged to provide updated information on benefits and alternatives during the PWP
Page 9 of 16
comment period. EPA is seeking additional information on PCA, particularly any pertinent
monitoring data.
Additionally, the Agency is interested in receiving the following information:
1. Confirmation on the following label information:
A. Sites of application
B. Geographic limitations on use
2. Use or potential use distribution
3. State or local use restrictions
4. Ecological incidents (non-target plant damage and avian, fish, reptilian, amphibian and
mammalian mortalities) not already reported to the Agency
5. Monitoring data
General Comments
http://www.niehs.nih.gov/news/newsroom/releases/2014/october2/index.cfm
Pentachlorophenol and by-products of its synthesis are complex mixtures of chemicals used as wood
preservatives. Because virtually everyone who is exposed to pentachlorophenol is also exposed to its
synthesis by-products, they were evaluated together. In the United States, pentachlorophenol has been
regulated since the 1980s as a restricted-use pesticide. It is used industrially for treating utility poles,
wood pilings, fence posts, and lumber or timber for construction. Most exposure has occurred in settings
where workers treat lumber or come in contact with treated lumber. People may also be exposed to this
mixture from breathing contaminated air or dust, or from contact with contaminated soil. Exposure to this
mixture was associated with an increased risk of non-Hodgkin lymphoma in studies in humans.
Page 10 of 16
THE HEALTH IMPACTS OF PENTACHLOROPHENOL EXPOSURE:
Penta-treated wood is the largest source of dioxins. It and its accompanying
contaminants are persistent organic pollutants (POPs). It contains several
carcinogens including tri- and tetrachlorophenol and hexachlorobenzene, dioxins and
polychlorinated dibenzofurans. Ranked among some of the most noxious chemicals
ever created, penta and its sister chemicals are endocrine disrupting compounds
(EDCs) that mimic estrogen and cause mal-formed reproductive organs in wildlife
and humans, hence, the name gender benders. EDCs make people with such
abnormalities prone to reproductive cancers later in life. Elevated levels of endocrine
disruptors are found in the blood of women who have experienced spontaneous
abortions, infertility and menstrual disorders. They also cause immune system
dysfunction. Evidence of endocrine disruption is rarely as strong as it is for penta.
With EDCs such as penta it is not the amount one has in one’s system, it is the timing
of the exposure since they affect fetal and early childhood development as well as
visit their deadly mutagenic effects upon the victim later in life. The synergistic
interactions of the many compounds that now, unfortunately, make up our chemical
body burden also have a detrimental effect. A PETROLEUM DERIVATIVE: Penta is also
a chlorinated hydrocarbon derived from petroleum. The deadly toxicity of oil-derived
pesticides is just one more reason to leave the oil in the ground where Mother
Nature put it. We need to end our addiction to oil in more ways than one.
Dermal exposure to pentachlorophenol was associated with
non-Hodgkin's lymphoma, multiple myeloma, and kidney cancer,
http://www.ncbi.nlm.nih.gov/pubmed/16783603
http://www.ncbi.nlm.nih.gov/pubmed/18709150
The pentachlorophenol studies presented considerable evidence pertaining to
hematopoietic cancers, with strong associations seen in multiple studies, in different
locations, and using different designs. There is little evidence of an association between
these cancers and chlorophenols that contain fewer than four chlorines. The extension
of a large cohort study of sawmill workers, with follow-up to 1995, provided information
about risks of relatively rare cancers (e.g., non-Hodgkin lymphoma, multiple myeloma),
using a validated exposure assessment procedure that distinguishes between
exposures to pentachlorophenol and tetrachlorophenol. In contrast with dioxin,
pentachlorophenol exposure has not been associated with total cancer incidence or
mortality.
Page 11 of 16
http://ntp.niehs.nih.gov/ntp/roc/content/profiles/pentachlorophenol.pdf
Pentachlorophenol and by-products of its synthesis are complex mixtures of chemicals
used as wood preservatives. Because virtually everyone who is exposed to
pentachlorophenol is also exposed to its synthesis by-products, they were evaluated
together. In the United States, pentachlorophenol has been regulated since the 1980s
as a restricted-use pesticide. It is used industrially for treating utility poles, wood pilings,
fence posts, and lumber or timber for construction. Most exposure has occurred in
settings where workers treat lumber or come in contact with treated lumber. People may
also be exposed to this mixture from breathing contaminated air or dust, or from contact
with contaminated soil. Exposure to this mixture was associated with an increased risk
of non-Hodgkin lymphoma in studies in humans.
Department of Home Land Security Report
http://www.dhs.gov/xlibrary/assets/DHS_Daily_Report_2012-04-27.pdf
LINKS TO MATERIAL ON PENTA
Wikipedia
http://en.wikipedia.org/wiki/Pentachlorophenol
http://en.wikipedia.org/wiki/Toxicity_Class
http://en.wikipedia.org/wiki/Federal_Insecticide,_Fungicide,_and_Rodenticide_Act
http://en.wikipedia.org/wiki/Federal_Insecticide_Act
http://en.wikipedia.org/wiki/Toxic_Substances_Control_Act_of_1976
http://en.wikipedia.org/wiki/Polychlorinated_biphenyl
http://www.imm.ki.se/Datavard/Rapporter/Rapport%20till%20Milj%C3%B6%C3%B6ve
rv.pdf
http://www.frtr.gov/matrix2/section2/2_6_1.html
http://watoxics.org/files/penta
http://www.fws.gov/pacific/ecoservices/envicon/pim/reports/contaminantinfo/contaminants.
html
CDC
http://www.atsdr.cdc.gov/ToxProfiles/tp51.pdf
http://www.atsdr.cdc.gov/toxprofiles/pentachlorophenol_addendum.pdf
http://www.atsdr.cdc.gov/tfacts51.pdf
NIH
Page 12 of 16
http://ntp.niehs.nih.gov/ntp/htdocs/chem_background/exsumpdf/pentachlorophenol_508.p
df
http://toxnet.nlm.nih.gov/cgi-bin/sis/search/r?dbs+hsdb:@term+@DOCNO+761 (
DATABASE)
http://www.ncbi.nlm.nih.gov/pubmed/21208638
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2908650/
TOXICOLOGICAL PROFILE FOR PENTACHLOROPHENOL
http://ntp.niehs.nih.gov/ntp/roc/thirteenth/webinars/2013/abstractspcp20130411_508.pdf
EPA
http://www.epa.gov/osw/hazard/testmethods/sw846/pdfs/8540.pdf
http://www.ncbi.nlm.nih.gov/pubmed/21208638
http://www.epa.gov/region2/superfund/npl/newcassel/pdf/ground_water_contamination_ou
1_rodfinal.pdf
http://www.epa.gov/iris/toxreviews/0086tr.pdf#page=197
http://ntp.niehs.nih.gov/ntp/roc/thirteenth/webinars/2013/abstractspcp20130411_508.pdf
MISC:

http://esrd.alberta.ca/air/objectives-directives-policies-and-standards/documents/6652.pdf

http://msdssearch.dow.com/PublishedLiteratureDOWCOM/dh_0081/0901b80380081aec.
pdf?filepath=dioxin/pdfs/noreg/737-00170.pdf&fromPage=GetDoc

http://www.unece.org/fileadmin/DAM/env/lrtap/TaskForce/popsxg/2008/Pentachlorophe
nol_RA dossier_proposal for submission to UNECE POP protocol.pdf

http://esrd.alberta.ca/air/objectives-directives-policies-andstandards/documents/Final_AAAQO_For_Pentachlorophenol.pdf

http://www.euro.who.int/__data/assets/pdf_file/0009/78660/e78963.pdf

http://pubchem.ncbi.nlm.nih.gov/toc/summary_toc.cgi?tocid=50&cid=21013

http://www.imm.ki.se/Datavard/Rapporter/Rapport%20till%20Milj%C3%B6%C3%B6ve
rv.pdf

http://www.frtr.gov/matrix2/section2/2_6_1.html

http://watoxics.org/files/penta
Page 13 of 16

http://www.fws.gov/pacific/ecoservices/envicon/pim/reports/contaminantinfo/contaminan
ts.html
The Law

http://www.law.cornell.edu/cfr/text/40/264.231?qt-cfr_tabs=2#qt-cfr_tabs

http://www.ecfr.gov/cgi-bin/textidx?SID=797a2fd9d9dc30596cca056e40d4c124&node=40:27.0.1.1.5&rgn=div5

http://www.gpo.gov/fdsys/pkg/USCODE-2010-title42/pdf/USCODE-2010-title42chap82-subchapIII-sec6925.pdf

http://www.cga.ct.gov/2009/rpt/2009-R-0251.htm
Preventative Measures

SRP: The scientific literature for the use of contact lenses in industry is conflicting. The
benefit or detrimental effects of wearing contact lenses depend not only upon the
substance, but also on factors including the form of the substance, characteristics and
duration of the exposure, the uses of other eye protection equipment, and the hygiene of
the lenses. However, there may be individual substances whose irritating or corrosive
properties are such that the wearing of contact lenses would be harmful to the eye. In
those specific cases, contact lenses should not be worn. In any event, the usual eye
protection equipment should be worn even when contact lenses are in place.

Avoid breathing vapors. Keep upwind. Wear boots, protective gloves, and goggles. Wash
away any material which may have contacted the body with copious amounts of water or
soap and water. /Pentachlorophenol/

Wear appropriate equipment to prevent: Any possibility of skin contact.
/Pentachlorophenol/

Wear eye protection to prevent: Any possibility of eye contact. /Pentachlorophenol/

Workers should wash: Immediately when skin becomes contaminated.
/Pentachlorophenol/

Work clothing should be changed daily: If there is any possibility that the clothing may
be contaminated. /Pentachlorophenol/

Remove clothing: Immediately if it is non-impervious clothing that becomes
contaminated. /Pentachlorophenol/

The following equipment should be available: Eyewash. Quick drench.
/Pentachlorophenol/
Page 14 of 16
from HSDB
BANNING PENTA:



http://www.ci.berkeley.ca.us/citycouncil/2002citycouncil/packet/072302/200
2-07-23%20Item%2058.pdf
http://www.nassaucountyny.gov/agencies/DPW/Docs/PDF/Groundwater03R
eportSection6Appx.pdf (Water Standard)
http://www.dec.ny.gov/docs/remediation_hudson_pdf/130041fer.pdf
IMPACT TO CHILDREN
http://www.nrdc.org/health/kids/ocar/chap5.asp
"Because of their higher rate of breathing, children are more highly exposed to
pesticides that remain in indoor air. Compared to their parents, children living in homes
with indoor air contaminated with the pesticide pentachlorophenol (PCP), were found
to have close to twice as much PCP in their blood as their parents. [19] Children also
spend a lot of time closer to the ground than adults thus they are more likely to come
into contact with pesticides that concentrate in this breathing zone. Children also have
greater hand-to-mouth activity, increasing opportunities for direct ingestion of pesticide
residues in dirt or dust."
SMALL TOWN IMPACT

http://www.epa.gov/region5/cleanup/stregis/pdfs/stregis_slides_20110623.p
df

https://www.youtube.com/watch?v=1FkXUoUYWp4

http://www.epa.gov/Region5/superfund/npl/minnesota/MND057597940.ht
ml
Search N.Y. PBH. LAW § 3380 : NY Code - Section 3380: Inhalation of certain toxic vapors or fumes,
and certain hazardous inhalants; sale of glue and hazardous inhalants in certain cases
1. (a) As used in this section the phrase "glue containing a solvent having the property of releasing
toxic vapors or fumes" shall mean and include any glue, cement, or other adhesive containing one
or more of the following chemical compounds: acetone, cellulose acetate, benzene, butyl alcohol,
ethyl alcohol, ethylene dichloride, ethylene trichloride, isopropyl alcohol, methyl alcohol, methyl
Page 15 of 16
ethyl ketone, pentachlorophenol, petroleum ether, toluene or such other similar material as the
commissioner shall by regulation prescribe. (b) As used in this section hazardous inhalants shall
mean and include any of the preparations of compounds containing one or more of the chemical
compounds; amyl nitrite, isoamyl nitrite, butyl nitrite, isobutyl nitrite, pentyl nitrite or any other
akyl nitrite compound that is either designed to be used, or commonly used, as an inhalant.
Page 16 of 16