ENVIRONMENT DIRECTORATE-GENERAL
Directorate B – Protecting the natural environment
B.4 – Biotechnology and Pesticides / ESSENTIAL USE APPLICATION FORM FOR BIOCIDES
1. MEMBERSTATE
Austria / Belgium / Cyprus / CzechRepublic / Denmark
Estonia / Finland / France / Germany / Greece
Hungary / Ireland / Italy / Latvia / Lithuania
Luxemburg / Malta / The Netherlands / Poland / X / Portugal
Slovenia / Slovakia / Spain / Sweden / United Kingdom
2. ACTIVE SUBSTANCE
2.1. Common name / Trichlorfon
2.2. EC and/or CAS N° / EC no: 015-021-00-0
CAS no: 52-68-6
2.3. Molecular and Structural formula (including details on isomeric composition) – molecular mass / Molecular formula: C4H8Cl3O4P
Molecular mass: 257,44
Structural formula:
2.4. Method of manufacture (in brief terms) / Trichlorfon (O,O-Dimethyl-1-hydroxy-2,2,2-trichloroethylphosphonate) is obtained by
reacting freshly distilled dimethyl hydrogen phosphite with chloral in the absence of anycatalyst. Chloral being obtained by distilling chloral hydrate over sulphuric acid.
The reactionis exothermic and takes placeovernight below 80oC.Microwave irradiation however reduces the reaction time to a dozen minutes.The crudeproduct should be crystallized several times from petroleum ether containing a traces of benzene.
2.5.Specification of purity in g/kg or g/l as appropriate / A typical level of purity fortechnical trichlofon is greater than 98% (998g/kg)
The main impurities are 2,2-dichlorovinyl dimethyl phosphate: dichlorvos (0-0.2%), trichloroacetaldehyde (0-0.05%), dichloroacetaldehyde (0-0.03%), methyl hydrogen 2,2,2-trichloro-1-hydroxyethylphosphonate; demethyl trichlorfon (0-0.3%), and water (less than 0.3%).
2.6. Identity of impurities and additives – including stabilisers / A typical composition of the biocide product for which essential use is claimed is:
Trichlorfon: 1%
Attractant (e.g. sugar): 99%
Denatonium benzoate: 0,001%
Pigment (e.g. Rodamine B) : 0,005%
Other common formulations include: wettable powders 50%; soluble powders 58,80 and 95%; soluble concentrate 50%; ULV at concentrations of 250, 500 and 750 g A.I./L; dust 5%
2.7. Origin of substance (in case of a natural substance) / Not applicable
2.8. Physical chemical properties in accordance with Annex IIA, Point III, to Directive 98/8/EC, as appropriate / Melting point: 75-79oC
Vapour pressure: 0,21 mPa (20oC)
Appearance: a pale clear, white, or yellow crystalline solid with an ethyl ether odour.,solid at room temperature
Solubility in water: 120 mg/L (20o)
Solubility in other solvents: s. in alcohols, ketones, dichloromethane, 2-propanol, methylene chloride, and toluene; s.s. in aromatic solvents; i.s. in n-hexane
Partion coefficient n-octanol/water: 0,57 log POW
Vapour pressure: 10-5 mbar (20oC)
Stability: stable in room temperature, is converted to dichlorvos in an alkaline medium; in an acid medium (pH 1-5), 50% is hydrolysed at 20oC in 526 days
Explosive properties: non-explosive
Oxidizing properties: non-oxidizing
2.9. A summary or toxicological and ecotoxicological information for the substance / Trichlorfon is moderately toxic by ingestion or dermal absorption. As with all organophosphates, trichlorfon is readily absorbed through the skin. Trichlorfon decreases activity of the cholinesterase enzyme which is necessary for normal function of the nervous system. Symptoms of acute exposure include headache, giddiness, nervousness, blurred vision, weakness, nausea, cramps, loss of muscle control or reflexes, convulsion, or coma.
Pure trichlorfon is reported to be less toxic than the technical material. The oral LD50 for trichlorfon is 450 to 650 mg/kg in rats and 300 to 860 mg/kg in mice. Other reported oral LD50 values are 94 mg/kg in cats, 400 mg/kg in dogs, 420 mg/kg in dogs, and 160 mg/kg in rabbits. The dermal LD50 is 2000 to 5000 mg/kg in rats, and 1500 to greater than 2100 mg/kg in rabbits. The 4-hour inhalation LC50 for trichlorfon in rats is greater than 0.5 mg/L.
Trichlorfon is moderately to highly toxic to birds. The acute oral LD50 for trichlorfon is 36.8 mg/kg in mallards, 22.4 mg/kg in bobwhite quail, 59.3 in California quail, 95.9 mg/kg in male pheasant, and 23 mg/kg in rock doves.
Trichlorfon, in both technical and formulated forms, is very highly toxic to many aquatic species such as Daphnia, stoneflies, crayfish, and several freshwater fish species. Reported LC50 (96-hour) values are 0.18 mg/L (48-hour) in Daphnia, 0.01 mg/L in stoneflies, 7.8 mg/L in crayfish, 1.4 mg/L in rainbow trout, 2.5 mg/L in brook trout, 0.88 mg/L in channel catfish and 0.26 mg/L in bluegill. Toxicity in the field can be affected by many factors including temperature, pH, and water hardness, which may have different effects across species. Generally, toxicity increased (i.e., observed LC50 was lower) with higher temperature and higher pH. Studies did not show a potential for trichlorfon to accumulate in fish.
Trichlorfon has moderate to high acute toxicity toward certain beneficial or non-target insects. This pesticide may be toxic to other wildlife. Data indicate that trichlorfon has a low toxicity to bees; it can be used around bees with minimum injury.
Trichlorfon breaks down, or degrades, rapidly in aerobic soils, with a half-life rangingbetween 3 and 27 days. An average half-life of 10 days has been reported. Trichlorfon is of low persistence in soil environments. Trichlorfon does not adsorb strongly to soil particles, is readily soluble in water, and is very mobile in soils of varying textures and organic contents. Trichlorfon degrades rapidly in alkaline pond water (pH 8.5). Approximately 99% of applied trichlorfon was broken down within 2 hours. It was stable in the same pond water kept under acidic (pH 5.0) conditions for 2 hours.
3. AVAILABLE INFORMATION ON THE ESSENTIAL USE
3.1. Product type and use(s) for which the derogation is required / Trichlorfon is well known as an organophosphate insecticide within Product type 18.
Essential use is claimed for Mrówkofon, which consist approximately 1% (w/w) of the active substances. The biocide is formulated as a ready-to-use granular preparation. The product is claimed to be an essential insecticide for control and eradications of ants at houses, around houses and other buildings.
3.2. Method(s) of application / For both interior and exterior use the biocide will be:
-sprinkled at arate of 10g on surface areas where ants my hide or live
-applied to refillable/serviceable bait stations.
3.3. Number and timing of applications / Usually one or two applications are efficacious. In case of failure to eradicate the target organisms, repeated treatment may become necessary.
3.4. Classification & Labelling / According to Directive 67/548/EEC
Class of danger: Xn, N
R phrases: R22; R43; R50/53
S phrases: S2; S24; S37; S60; S61
1% C < 25%
Class of danger: Xi, N
R phrases: R43; R50/53
S phrases: S2; S24; S37; S60; S61
3.5. Available data on effects on human or animal health and the environment (including exposure and risk assessment and proposals for risk mitigation) from the use / Chronic toxity: Repeated or prolonged exposure to organophosphates may result in the same effects as acute exposure. Other effects reported in workers repeatedly exposed include impaired memory and concentration, disorientation, severe depression, irritability, confusion, headache, speech difficulties, delayed reaction times, nightmares, sleepwalking, and drowsiness or insomnia. An influenza-like condition with headache, nausea, weakness, loss of appetite, and malaise has also been reported.
Reproductive effects: Trichlorfon is suspected of having negative reproductive effects. During a three-generation study of the effect of trichlorfon on rat reproduction, a dose of about 150 mg/kg/day resulted in a marked decrease in the rate of pregnancy, and underdeveloped rat pups at birth, none of which survived to weaning. A dose of 50 mg/kg/day reduced the number of pups per litter, as well as the weight of individual pups. Doses of 15 mg/kg/day had no detectable effect on reproduction. Once in the bloodstream, trichlorfon may cross the placenta. It is however unlikely that reproductive effects will occur in humans at expected exposure levels.
Teratogenic effects: Trichlorfon caused inability to walk and tremors in pig offspring if administered at day 55 at a dose of 55 mg/kg. There was no evidence of teratogenesis in a three-generation study with rats fed dietary dose of as high as 150 mg/kg/day, or in a metabolite study of rabbits at doses of 50 to 75 mg/kg/day. Thus the evidence suggests that reproductive effects occur only at high doses and are unlikely in humans at the expected exposure levels.
Mutagenic effects: Studies indicate that trichlorfon, or its degradation products, can be mutagenic in bacterial and mammalian cells. The insecticide produced mutations in mice when it was given atthe highest tolerable single dose and in smaller, repeated doses.
Carcinogenic effects: One study suggests that oral doses of 37.5 to 75 mg/kg/day of trichlorfon contribute to the production of tumors in rats. However, no evidence of carcinogenicity was found in rats given the insecticide orally or intraperitoneally for 90 weeks. In addition, no evidence of carcinogenicity was observed when trichlorfon was administered orally, intraperitoneally, or dermally to mice. Thus, the carcinogenic data are inconclusive.
3.6. Information on efficacy / Trichlorfon is now well recognisedas a high efficacious insecticide and is used to control a variety of indoor and outdoor insect pests in agricultural, residential and commercial sites ranging from chicken coupes and golf courses to residential homes. The US Department of Agriculture was the first to register this pesticide in 1955.
Trichlorfon is used to control ants, cockroaches, crickets, silverfish, bedbugs, fleas, cattle grubs, flies, ticks, leafminers, and leaf-hoppers. It is applied to vegetable, fruit, and field crops; livestock; ornamental and forestry plantings; in agricultural premises and domestic settings; in greenhouses, and for control of parasites of fish in designated aquatic environments. It is also used for treating domestic animals for control of internal parasites.
4 - JUSTIFICATION OF THE ESSENTIAL USE
4.1. Significance of the harmful organism
Ants have become a serious nuisance pest in hospitals, rest homes, apartment dwellings, hotels, grocery stores, food establishments and other buildings. They feed on a wide variety of foods including jellies, honey, shortening, peanut butter, corn syrup, fruit juices, baked goods, soft drinks, greases, dead insects and even shoe polish. Also, these ants gnaw holes in silk, rayon and rubber goods. In hospitals, foraging ants have been found in surgical wounds, I.V. glucose solutions, sealed packs of sterile dressing, soft drinks, water in flower displays and water pitchers. Ants are capable of mechanically transmitting diseases and contaminating sterile materials. It is considered by some that Staphylococcus and Psuedomonas infections, occurring from time to time in hospitals, are associated with these ants.
Besides being a nuisance, ants contaminate foods, cause structural damage by hollowing out wood for nesting and species such as fire ants inflict painful stings, which can be life-threatening to hypersensitive individuals.
4.2. Importance of the intended use and estimated scale of use - maximum quantity of active substance per year
The quantities needed for ant control is highly variable from one year to another. The estimated maximum quantity needed for essential use in a single application ranges from 300 to 500 kg of trichlorfon active substance, with an average annual use of 400 kg.
4.3. If the essential use is not permitted, what would be the consequences for health, safety, protection of cultural heritage or the functioning of society (including cultural and intellectual aspects)?
Proper ants control is essential for keeping a high level of hygiene in hospitals, rest homes, apartment dwellings, hotels, grocery stores, food establishments and other buildings. Trichlorfon formulated as powder or granule is the main active substance used in Poland to control and eradicate ants. Most of those products are recommended for both professional and commercial use.
The lack of efficient products in an appropriateformulation would have negative affects on efforts of ants control and consequently of the hygiene level.
4.4. Need for the biocidal product / active substance in resistance or other pest management programmes (for example integrated pest management)
In Poland no biocides-resistant ant species have been identified. However ant eradication is very often abig problem due to their life cycle and habits.
5 - WHY THE USE OF THIS ACTIVE SUBSTANCE IS ESSENTIAL
5.1. Active substances currently used [elsewhere in the EU/worldwide) to control the problem described in 4.1. and their approval/authorisation status
The other active substances used in Poland for ant control are:
-boric acid
-methoprene
-hydramethylnon
-sulfuramid.
The EU also uses
-fipronil.
The USA uses
-boric acid
-hydramethylnon
-methoprene
-bendiocarb
-propoxur
-sulfuramid.
5.2. Evidence that there are no available technically and economically feasible alternatives or substitutes that could be acceptable from the standpoint of environment and health
-Trichlorfon has proven its efficacy as insecticide and more than 60-70% products for ant control on the Polish market contain trichlorfon. Apart from the active substance notified for PT 18, there are very few that could be used for ants control – a delayed action stomach poisons are recommended.
-Boric acid and methoprene are efficacious but work slowly, sometimes taking 15 to 40 weeks or more to eradicate ants. Hydramethylnon gives a quicker result of 1 to 4 weeks, but is more expensive than trichlorfon.In many postcommunist countries such Poland, the price is still the most important factor for both commercial and professional users. Products containing hydramethylnon are about eight times more expensive than biocides containing trichlorfon or boric acids. It could therefore be a big barrier for users and could limit access to efficient and cheap products.
-Conventional pesticide (e.g. bendiocarb, propoxur) kills only 10 percent of an ant’s colony and repellent insecticides such as pyrethrins may spread infestations to new areas with multiple colonies blossoming within the structure.
-It is absolutely necessary to keep a broad panel of insecticide products to overcome potential resistance problems.
6 - PROPOSED PLAN FOR A MORE PERMANENT SOLUTION
6.1. Evidence of a plan to submit a dossier for the evaluation and inclusion of the active substance in one of the annexes to Directive 98/8/EC
No such evidence can be provided.
6.2. Any outline of work carried out to develop an alternative or substitute to the active substance
We plan to gradually replace trichlorfon with a new product which will be both highly active and safer for the environment. On-going research and development lookspromising however more time is required. We are especially focused on successfully combining safe active substance (placed in annex II to Directive 98/8/EC) with efficient attractants. However this phase of products development and testing are particularly time-consuming.
7- OTHER INFORMATION
E.g.: - Steps that are being taken to minimise the proposed uses
- Steps to minimise the emissions and human exposure associated with the proposed uses and waste management related to the biocidal product
- Acceptability of the active substance in light of the criteria in Annex VI of Directive 98/8/EC
The essential use which is claimed (for ants control only) reduces the emission of trichlorfon to the environment and minimizesitseffects on human and other organisms. The application to bait stations (about 3 g product per station) additionally avoids contamination of the environment – soil, surface waters ant others wildlife animals – birds, fishes, beneficial insects.
Trichlorfon is of low persistency; under normal conditions of use the general population should not be exposed to levels of any toxicological significance. Residues found in food usually disappear during processing or cooking. The estimate of the temporary acceptable daily intake for man is from 0-0.01 mg/kg per day.
References
EXTOXNET (1993) Pesticide Information Profile Trichlorfon. Available at
EXTOXNET PIP – Trichlorfon (1996), Available at
EPA: Trichlorfon Facts,
EPA: Trichlorfon Summary;
IPSC INCHEM (INTERNATIONAL PROGRAMME ON CHEMICAL SAFETY); Trichlorfon,
International Agency for Research on Cancer (IARC) - Summaries & Evaluations TRICHLORFON
VOL.: 30 (1983) (p. 207),
INTERNATIONAL PROGRAMME ON CHEMICAL SAFETY & WORLD HEALTH ORGANIZATION, Prepared by the Fifty-fourth meeting of the Joint FAO/WHO Expert Committee on Food Additives (JECFA), Geneva 2000,
IPCS INTERNATIONAL PROGRAMME ON CHEMICAL SAFETY, Health and Safety Guide No. 66
TRICHLORFON - HEALTH AND SAFETY GUIDE,
WHO/SIT/13.R5, TECHNICAL TRICHLORFON, Full specification WHO/SIT/13.R5, Revised 10 December 1999,
Abdollah Javidan and A. R. Banan, microwave synthesis of trichlorfonand its analogues, Phosphorus, Sulfur, and Silicon, 179:2253–2258, 2004
W.P. Barthel, P.A. Gianga, S.A. Hall, Dialkyl a-Hydroxyphosphonates Derived from Chloral‘, RECEIVEDM ARCH 20 , 1954
OhioStateUniversityExtension Facts Sheet - Entomology – Pharaoh Ant;
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