UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
Date:
May
23,
2002
Memorandum
SUBJECT:
Addendum
to
EPA
March
8,
2002:
Pronamide.
Tolerance
Reassesment
Eligibility
Decision
(TRED).

FROM:
Gary
Bangs,
Risk
Assessor
Reregistration
Branch
3
Health
Effects
Division
(7509C)

THROUGH:
Steve
Knizner,
Chief
Reregistration
Branch
3
Health
Effects
Division
(7509C)

TO:
Cecelia
Watson,
Chemical
Review
Manager
Special
Review
and
Reregistration
Division
(7508C)

PC
Code:
Pronamide
101701.

DPBarcode:
D282842
PURPOSE:
Pronamide
Revised
Aggregate
Risk
Estimates
After
Application
of
Labeling
Changes
to
Eliminate
Use
on
Residential
Turf
2
Pronamide
Revised
Aggregate
Risk
Estimates
After
Application
of
Labeling
Changes
to
Eliminate
Use
on
Residential
Turf
Cancellation
of
the
single
label
allowing
application
of
pronamide
to
home
lawns
and
recreational
turf
will
make
children's
oral
non­
dietary
exposures
unlikely.
However,
since
the
registrant
wants
to
retain
use
on
golf
courses
and
athletic
fields,
the
potential
for
low
and
highcontact
exposures
for
adults
still
exists.
Based
on
the
use
pattern
of
pronamide
(the
elimination
of
selected
grasses
from
golf
course
and
professional
playing
field
turf)
it
is
anticipated
that
children
would
rarely
be
exposed
to
pronamide
residues.
Labels
should
strongly
encourage
watering­
in
to
reduce
residues,
and
management
practices
to
restrict
entry
until
the
pronamide
product
is
watered
into
the
turf.
Given
these
proposed
restrictions
on
the
use
of
pronamide
on
turf,
the
high­
contact
dermal
exposure
scenario
is
not
considered
likely
and
would
result
in
an
overestimate
of
player
exposure.

Short­
term
Aggregate
Risk
Estimates
The
short­
term
food,
water,
and
low­
contact
dermal
(golfing)
pronamide
exposures
were
aggregated
in
the
Risk
Assessment,
and
the
estimated
environmental
concentrations
(EECs)
modeled
using
Sci­
Grow
and
PRZM­
EXAMS
did
not
exceed
the
drinking
water
level
of
concern
(DWLOC)
.
Therefore,
risk
estimates
for
all
pathways
of
exposure
are
not
of
concern
for
pronamide
in
the
short­
term
when
pronamide
use
is
restricted
per
the
label
changes
cited
above.

Chronic
Aggregate
Risk
Estimates
The
chronic
risk
estimates
would
remain
the
same
for
all
populations
as
stated
in
the
Risk
Assessment,
as
there
are
no
anticipated
long­
term
non­
dietary
exposure
scenarios
for
pronamide.
All
aggregate
food
and
water
estimates
do
not
exceed
the
level
of
concern.

Cancer
Risk
Estimates
Aggregate
cancer
risk
estimates
will
be
reduced
by
restricting
non­
agricultural
uses
to
turf
for
sod
and
seed,
ornamental
landscaping,
industrial
sites,
professional
athletic
fields,
and
golf
courses.
Golfing
is
believed
to
be
a
representative
scenario
for
likely
exposures
to
the
public.
The
cancer
risk
estimate
for
golfing
a
single
day
per
year
is
about
the
same
as
the
dietary
cancer
risk
estimate,
or
1
x
10
­7
.
When
both
dietary
and
non­
dietary
risk
are
added,
the
cancer
risk
estimate
is
2.2
x
10
­7
.
The
DWLOC
for
the
aggregated
dietary
and
golfing
cancer
risks
is
1.06
ppb.
Without
golf
course
exposure
(i.
e.,
no
recreational
turf
uses
at
all),
the
cancer
DWLOC
of
1.2
ppb
is
based
on
dietary
exposure
alone.
The
Tier
2
PRZM­
EXAMS
37­
year
mean
EECs
are
0.535­
4.35
ppb.
This
modeling
was
based
on
the
maximum
label
rates
for
pronamide,
whereas
typical
rates
for
many
crops
are
25%­
50%
less.
No
targeted
water
monitoring
data
were
available,
but
USGS
water
monitoring
data
showed
maximum
pronamide
levels
of
0.82
ppb
in
ground
water
and
0.365
ppb
in
surface
water.
Further
refinement
of
drinking
water
modeling
estimates
and/
or
targeted
monitoring
of
water
sources
in
high
pronamide
use
areas
would
provide
more
confidence
in
the
risk
assessment.
3
Risk
Characterization
The
cancer
risk
estimate
for
playing
on
treated
turf
used
the
turf
residues
averaged
over
14
days,
which
is
how
long
pronamide
takes
to
dissipate
to
negligible
levels.
A
single
day's
exposure
was
used,
based
on
the
national
average
rate
of
golfing
of
18
times
per
year,
or
about
every
2
weeks.
The
residential/
recreational
exposure
estimates
are
based
on
a
default
dermal
absorption
value
of
100%,
therefore,
a
dermal
absorption
study
would
help
to
reduce
these
risk
estimates.
Additional
label
language
encouraging
prompt
watering­
in
of
the
product
would
help
to
reduce
available
residues
(as
shown
in
the
submitted
turf
residue
study)
and
thereby
also
reduce
risks.
