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Consumer Product Safety

Incident Report

Subform I: General Information

1. Report Type.

New incident report

Incident Report Number: 2014-3804

2. Registrant Information.

Registrant Reference Number: 2014-09-15

Registrant Name (Full Legal Name no abbreviations): AMVAC Chemical Corporation

Address: 4695 MacArthur Court, Suite 1200

City: Newport Beach

Prov / State: California

Country: USA

Postal Code: 92660

3. Select the appropriate subform(s) for the incident.

Environment

4. Date registrant was first informed of the incident.

26-AUG-14

5. Location of incident.

Country: CANADA

Prov / State: PRINCE EDWARD ISLAND

6. Date incident was first observed.

17-JAN-14

Product Description

7. a) Provide the active ingredient and, if available, the registration number and product name (include all tank mixes). If the product is not registered provide a submission number.

Active(s)

PMRA Registration No. 10532      PMRA Submission No.       EPA Registration No. 5481-527

Product Name: Thimet 15G Lock'n Load

  • Active Ingredient(s)
    • PHORATE
    • SULFOTEP PLUS RELATED ACTIVE COMPOUNDS

7. b) Type of formulation.

Application Information

8. Product was applied?

Yes

9. Application Rate.

Unknown

10. Site pesticide was applied to (select all that apply).

Site: Agricultural-Outdoor/Agricole-extérieur

Préciser le type: Potato

11. Provide any additional information regarding application (how it was applied, amount applied, the size of the area treated etc).

9. Report AMVAC received from PMRA says product was applied according to label directions.11. AMVAC does not have a record of the application. Application details provided are based on information from (name), Manager - Pesticide Regulatory Program, PEI Department of Environment, Labour and Justice; Phone (ph#)

To be determined by Registrant

12. In your opinion, was the product used according to the label instructions?

Unknown

Subform IV: Environment (includes plants insects and wildlife)

1. Type of organism affected

Bird - Flocking/Oiseau-Vivant en colonie

2. Common name(s)

American Black Duck (12), Mallard Duck (1)

3. Scientific name(s)

Unknown, Anas platyrhynchos

4. Number of organisms affected

13

5. Description of site where incident was observed

Fresh water

Terrestrial

Agricultural

Salt Water

6. Check all symptoms that apply

Death

7. Describe symptoms and outcome (died, recovered, etc.).

The following information was provided to AMVAC via email by (name): On January 17, 2014, our enforcement staff responded to a call of dead and dying ducks in a harvested potato field in eastern (province). The officer collected 12 American Black Ducks and 1 female Mallard Duck. The ducks were found in a puddle, there had been a thaw and the field contained an open water source. Toxicology testing confirmed organophosphate toxicity with the organophosphate insecticide phorate being found in the samples submitted. Use records for that potato field indicated that Thimet had been used during the growing season. The investigation is on-going. We have also notified local PMRA staff. If you have any questions, please let me know. Thanks, (name), Manager - Pesticide Regulatory Program PEI Department of Environment, Labour and Justice (ph#) A wildlife diagnostic report on the 13 ducks was prepared by the Canadian Cooperative Wildlife Health Centre at the Atlantic Veterinary College, University of Prince Edward Island. They conducted a necropsy on each duck. Toxicology services were contracted to the Animal Health Laboratory at the University of Guelph. A summary of the necropsy and toxicology are provided in the attached report. The toxicology analysis included an organophosphate screen conducted by GC/MS. This is an open screen which compares the mass spectrum determined with a NIST library. Two compounds were detected; phorate and sulfotep. I have attached the spectrum for the sample, including a full scale chromatograph showing phorate peak, mass spectrum and Library match. The investigation at this time is still ongoing and we cannot release the specific location or the grower's name at this time. (name) Manager, tel: (ph#) email: (email name)

8. a) Was the incident a result of (select all that apply)

Application

N/A

8. b) i) How many times has the product been applied this year?

Unknown

8. b) ii) What was the date of the last application?

Unknown

9. Did it rain

9. a) During application?

Unknown

9. b) Up to 3 days after application?

Unknown

10. a) Was there a buffer zone?

Unknown

10. b) What type?

10. c) What was the size of the buffer zone?

11. a) Were environmental samples collected and analysed?

Yes

To be determined by Registrant

12. Severity classification (if there is more than one possible classification, select the most severe)

Minor

13. Please provide supplemental information here

AMVAC has not had the opportunity yet to review all details of what occurred since the investigation has not been finalized. Based on the information available to us today, the most plausible explanation due to the long length of time between likely application and event (over 3-4 months) is that some granules were not incorporated, either left on the surface at the end of the rows, or some sort of spill in the field. Granules that would have been incorporated would have been 6-8 inches below the soil and not available to the ducks to consume. This is supported by the reports that show possible granules in the ducks stomachs. Birds tend to feed at the end of rows so the most likely scenario seems the equipment was not stopped as the turn was made at the end of rows and some granules remained on the surface of soil and were not incorporated.