1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
Date:
April
30,
2002
MEMORANDUM
SUBJECT:
REVISED
OCCUPATIONAL
AND
RESIDENTIAL
EXPOSURE
ASSESSMENT
AND
RECOMMENDATIONS
FOR
THE
RE
REGISTRATION
ELIGIBILITY
DECISION
DOCUMENT
FOR
LINDANE
FROM
David
Jaquith
Reregistration
Action
Branch
4
Health
Effect
Division
(7509C)

TO:
Becky
Daiss
Reregistration
Branch
4
Health
Effect
Division
(7509C)

THRU
Susan
Hummel,
Senior
Scientist
Reregistration
Branch
4
Health
Effects
Division
(7509C)

Please
find
attached
the
occupational
and
residential
exposure
assessment
for
lindane
DP
BARCODE
D282648
Pesticide
Chemical
Codes:
009001
EPA
Reg
Nos:

EPA
MRID
Nos.:
452000­
02,
444058­
02,
422519­
01
PHED:
No
2
CONTENTS
EXECUTIVE
SUMMARY......................................................
3
1.0
BACKGROUND
........................................................
4
1.1
Summary
of
Toxicity
Concerns
Relating
to
Occupational
Exposures
.........
5
1.
2
Summary
of
Use
Pattern
and
Formulations..............................
7
1.3
Method
and
Types
of
Equipment
Used
for
Mixing/
Loading/
Applying
........
8
1.
4
Incident
Reports...................................................
8
2.0
OCCUPATIONAL
EXPOSURES
...........................................
8
2.1
Handler
Exposures
&
Assumptions
....................................
8
2.1.1
Submitted
Studies
...........................................
8
2.1.2
Summary
of
Occupational
Handler
Exposures
.....................
9
2.1.3
Summary
of
Uncertainties
.....................................
9
2.1.4
Calculations
of
Exposure
.....................................
11
2.2
Risk
From
Handler
Exposures
.......................................
12
2.2.1
Risk
From
Handler
Exposures
................................
12
2.2.2
Summary
of
MOEs
.........................................
13
2.2.3
Cancer
Risks
..............................................
13
2.2.3
Insufficient
Data
...........................................
13
REFERENCES
..................................................
16
Appendix
A
...........................................................
17
Appendix
B
...........................................................
22
Appendix
C
...........................................................
29
3
Executive
Summary
This
document
presents
the
occupational
exposure
assessment
for
use
of
lindane.
Lindane
is
the
gamma
isomer
of
1,2,3,4,5,6­
hexachlorocyclohexane,
an
insecticide
previously
used
in
many
situations
but
now
restricted
to
seed
treatment
only.
There
are
no
current
registered
uses
for
recreational,
residential
or
other
public
(non­
occupational)
settings.
All
uses
other
than
seed
treatment
have
been
cancelled.
Lice
and
scabies
treatment
is
considered
in
the
risk
assessment
document.

Acute
Toxicity
Categories
Acute
toxicity
categories
for
technical
grade
lindane
are
in
Toxicity
Category
II
for
oral,
Toxicity
Category
II
for
dermal,
and
Toxicity
Category
II
for
inhalation.
It
is
in
Toxicity
Category
III
for
primary
eye
irritation.

The
endpoints
used
in
this
document
to
assess
lindane
hazards
include
short­
term
and
intermediate­
term
dermal
and
inhalation
endpoints.
The
exposure
duration
for
short­
term
assessments
is
1
to30
days
or
up
to
1
month.
Intermediate­
term
duration
is
greater
than
1
month
to
six
months.
Although
there
is
little
information
to
determine
what
percentage
of
workers
apply
for
more
than
one
month,
it
is
reasonable
to
believe
that
typical
uses
of
lindane
by
commercial
seed
treatment
facilities
may
encompass
an
intermediate­
term
duration.
On
farm
treatments
are
more
likely
to
be
of
short­
term
duration.
An
oral
developmental
neurotoxicity
study
(MRID
45073501)
in
rats
was
selected
for
both
dermal
assessments.
A
90­
day
inhalation
toxicity
study
(MRID
00255003)
was
selected
for
inhalation
assessment
for
all
time
periods.

In
the
developmental
neurotoxicity
study
the
maternal
toxicity
NOAEL
is
50
ppm
(5.6
mg/
kg/
day)
based
on
reduced
pup
survival,
decreased
body
weights
and
body
weight
gains
during
lactation,
increased
motor
activity,
and
decreased
motor
activity
habituation.
The
offspring
toxicity
NOAEL
was
10
ppm
(1.2
mg/
kg/
day).

In
the
subchronic
inhalation
toxicity
study
(Accession
No.
255003)
Tte
systemic
toxicity
NOAELs
for
short
term
exposure
was
0.5
mg/
m
3
(0.13
mg/
kg/
day),
based
on
lesions
in
the
kidney
and
increased
kidney
weights.(
1).

Exposure
data
on
lindane
are
available
but
limited.
An
exposure
study
addressing
on
farm
seed
treatment
has
been
conducted
(MRID
444058­
02).
A
detailed
description
along
with
the
exposure
calculations
are
presented
in
Appendix
A.
Another
study
addressing
commercial
seed
treatment
with
another
chemical
has
been
reviewed
by
the
Agency.
The
an
excerpt
of
the
review
of
that
study
(MRID
452000­
02),
along
with
the
calculations
for
lindane
exposure
are
presented
in
Appendix
B.

The
results
of
the
handler
assessments
indicate
that
the
on
farm
seed
treatment
provide
dermal
MOEs
less
than
100
with
the
attire
worn
during
the
study
(long
pants,
long
sleeved
shirts,
gloves).
The
assessments,
both
dermal
and
inhalation,
yielded
MOEs
of
less
than
100
for
4
mixing/
loading/
application
and
bagging/
sewing/
stacking
during
commercial
seed
treatment
of
canola.
All
other
exposure
scenarios
provide
MOEs
greater
than
or
equal
to
100
when
wearing
the
clothing
used
in
the
study
(coveralls
over
single
layer
of
clothing,
gloves
for
commercial
other
seed
treatment
workers)
or
at
baseline
attire
(single
layer
of
clothing,
gloves
for
mixer/
loaders)
for
loading
seed
for
planting
or
for
planting
treated
seed.

Due
to
the
method
of
seed
treatment,
HED
has
determined
that
soil­
incorporated,
postapplication
agricultural
exposure
is
considered
to
be
negligible
as
long
as
the
soil
is
not
directly
contacted.
The
exception
is
farmers
handling
treated
seed.
An
estimate
of
the
inherent
risk
from
handling
treated
seed
was
conducted
using
relatively
conservative
assumptions.
There
are
no
study
data
available
on
exposure
to
lindane
from
handling
treated
seed
and
therefore
the
exposure
was
estimated
using
surrogate
data.
An
excerpt
of
that
review
of
that
study
(MRID
422519­
01)
and
exposure
calculations
are
presented
in
Appendix
C.

1.0
BACKGROUND
Purpose
This
document
is
for
use
in
development
of
the
Reregistration
Eligibility
Decision
Document
(RED)
for
the
insecticide
lindane
and
presents
a
review
of
the
potential
human
health
effects
of
occupational
exposure
to
lindane.

Criteria
for
Conducting
Exposure
Assessments
An
occupational
and/
or
residential
exposure
assessment
is
required
for
an
active
ingredient
if
(1)
certain
toxicological
criteria
are
triggered
and
(2)
there
is
potential
exposure
to
handlers
(mixers,
loaders,
applicators,
etc.)
during
use
or
to
persons
entering
treated
sites
after
application
is
complete.
For
lindane,
both
of
these
criteria
are
met.
5
1.1
Summary
of
Toxicity
Concerns
Relating
To
Occupational
Exposures
Acute
Toxicology
Categories
Table
1
presents
the
acute
toxicity
categories
as
outlined
in
the
Report
of
the
Hazard
Identification
Assessment
Review
Committee
(1).

Table
1:
Acute
Toxicity
Categories
for
Lindane
(Technical)

STUDY
TYPE
MRID
CATEGORY
RESULT
81­
1
Acute
oral
00049330
II
LD50
88
mg/
kg
­
males
91
mg/
kg
­
females
81­
2
Acute
dermal
00109141
II
LD50
1000
mg/
kg
­
males
900
mg/
kg
­
females
81­
3
Acute
inhalation
Acc.
263946
III
LC50
1.56
mg/
L
both
sexes
81­
4
Eye
irritation
Acc.
263946
III
PIS
=
0.6
no
corneal
involvement
irritation
cleared
after
24
hours
81­
5
Dermal
irritation
Acc.
263946
IV
PIS
=
0
not
an
irritant
81­
6
Dermal
sensitization
Acc.
263946
NA
not
a
sensitizer
Other
Endpoints
of
Concern
The
Report
of
the
Hazard
Identification
Assessment
Review
Committee
(HIARC)
for
lindane,
(1)
indicates
that
there
are
toxicological
endpoints
of
concern
for
lindane.
The
endpoints
used
in
assessing
the
risks
for
lindane
are
presented
in
Table
2.
6
Table
2.
Doses
and
Toxicological
Endpoints
Selected
for
Risk
Assessment
of
Lindane
EXPOSURE
SCENARIO
DOSE
(mg/
kg/
day)
ENDPOINT
STUDY
TYPE/
MRID
Acute
Dietary­
general
population
NOAEL=
6
mg/
kg
UF
=
100
LOAEL
is
20
mg/
kg
based
on
increased
grip
strength,
increased
motor
activity
Acute
Neurotoxicity
in
Rats/
44769201
Acute
RfD
=
0.06
mg/
kg/
day
aPAD
=
0.02
mg/
kg/
day
Chronic
Dietary
NOAEL=
0.47
mg/
kg/
day
UF
=
300
LOAEL
is
100
ppm
(4.81
mg/
kg/
day)
periacinar
hepatocyte
hypertrophy,
increased
liver/
spleen
weight,
decreased
platelets
Chronic
Feeding
and
Carcinogenicity
in
Rats
41094101,
41853701
42891201
Chronic
RfD
=
0.0047
mg/
kg/
day
cPAD
=
0.0016
mg/
kg/
day
Short­
Term
1
(Dermal)
NOAEL=
1.2
mg/
kg/
day
LOAEL
is
50
ppm
based
on
reduced
pup
survival,
decreased
body
weights
and
body
weight
gains
during
lactation,
increased
motor
activity,
and
decreased
motor
activity
habituation.
Developmental
Neurotoxicity
Study
in
Rats
(oral)
45073501
Intermediate­
Term
1
(Dermal)
NOAEL=
1.2
mg/
kg/
day
LOAEL
is
50
ppm
based
on
reduced
pup
survival,
decreased
body
weights
and
body
weight
gains
during
lactation,
increased
motor
activity,
and
decreased
motor
activity
habituation.
Developmental
Neurotoxicity
Study
in
Rats
(oral)
45073501
Long­
Term
1
(Dermal)
NOAEL=
0.47
mg/
kg/
day
LOAEL
is
100
ppm
(4.81
mg/
kg/
day)
periacinar
hepatocyte
hypertrophy,
increased
liver/
spleen
weight,
decreased
platelets
Chronic
Feeding
and
Carcinogenicity
in
Rats
41094101,
41853701
42891201
Dermal
Absorption
Factor
=
10%

Short
Term
1
(Inhalation)
0.13
mg/
kg/
day
(0.5
mg/
m
3
)
based
on
clinical
signs
(diarrhea,
piloerection)
seen
at
day
14
and
continuing
for
20
days
90­
Day
Inhalation
Toxicity
/
00255003
Intermediate
Term
1
(Inhalation)
0.13
mg/
kg/
day
(0.5
mg/
m
3
)
LOAEL
is
5.0
mg/
m
3
based
on
increased
kidney
weights
of
female
rats
and
bone
marrow
effects.
90­
Day
Inhalation
Toxicity
/
00255003
Long
Term
2
(Inhalation)
N/
A
N/
A
N/
A
1
Since
an
oral
NOAEL
was
selected,
the
dermal
absorption
factor
(10%)
should
be
used
in
route­
to­
route
extrapolation.
2
Exposure
thru
this
route
for
this
duration
is
not
expected
7
1.2
Summary
of
Use
Patterns
and
Formulations
The
only
use
remaining
for
lindane
is
for
seed
treatment.
The
use
closure
memorandum
(4)
allows
the
seed
treatment
of
the
following
crops:
barley,
broccoli,
Brussels
sprouts,
cabbage,
cauliflower,
corn,
lettuce,
oats,
radishes,
rye,
sorghum,
spinach,
and
wheat.
The
crops
and
application
rates
are
presented
in
Table
3.
Wheat
and
canola
were
used
as
a
representative
crops
for
all
other
seeds
treated
with
lindane
because
of
the
relatively
large
farm
size,
application
rate,
and
nature
of
the
product
treated.

Table
3.
Summary
of
Application
Rates
for
Seed
Treatment
Using
Lindane
on
Various
Crops.

Commodity
Formulation/
Reg.
No.
Use
Rate
barley
0.0375
lb
ai/
100
pound
seed
corn
dust
(19713­
262)
EC
(71096­
2)
0.125
lb
ai/
bushel
seed
0.125
lb
ai/
100
pound
seed
oats
7501­
38,
10107­
121
0.03125
lb
ai/
100
pound
seed
rye
19713­
401
554­
144
19713­
387
0.032813
lb
ai/
100
pound
seed
sorghum
42056­
15
0.0628
lb
ai/
100
pound
seed
spinach
dust
(7501­
38,
34704­
653,
34704­
658,
19713­
262,
34704­
658,
42056­
14,
10107­
121,
66330­
19)
0.0625
lb
ai/
100
pound
seed
wheat
dust,
2935­
492
0.042578
lb
ai/
100
pound
seed
canola
Not
currently
registered
1.5
lb
ai/
100
pounds
seed
(a
rate
of
0.75
lb/
100
lbs
seed
has
been
proposed)

1.3
Method
and
Type
of
Equipment
Used
for
Mixing/
Loading/
Applying
The
flowable
concentrate,
and
emulsifiable
concentrate
formulations
for
commercial
application
all
require
mixing
with
water
to
the
label­
specified
dilution.
This
is
usually
performed
by
scooping
or
pouring
the
formulation
into
a
mixing
tank,
often
of
100
gallons
or
more
in
capacity,
with
mechanical
agitation
to
keep
the
resulting
emulsion
homogenized
and
prevent
variations
in
application
strength.
Smaller
amounts
may
be
handled
using
a
tiller­
planter
(or
seed
drill)­
mounted
system.
Large
commercial
operations,
may
have
mechanical,
automated,
8
metered
pumps
which
require
only
connecting
the
formulation
to
the
pump.
Again,
small
seed
treatment
operations,
such
as
seed
box
(or
"hopper
box")
mixing,
may
be
done
by
pouring
small
amounts
in
to
a
mixing
device
before
planting
the
seeds
in
to
the
soil.
Dry
formulations
may
also
be
used,
particularly
for
on
farm
treatment.

Timing
and
Frequency
of
Application
Generally,
seed
will
be
treated
on
an
as
needed
basis.
However,
it
is
industry
practice
only
to
treat
enough
seeds
as
are
needed
to
be
used
that
season.

1.4
Incident
Data
No
information
regarding
seed
treatment
incidents
is
available
at
this
time.

2.0
OCCUPATIONAL
EXPOSURES
2.1
Handler
Exposures
&
Assumptions
HED
has
determined
that
there
are
potential
exposures
to
mixers,
loaders,
applicators,
or
other
handlers
during
usual
use­
patterns
associated
with
lindane.
Based
on
the
use
patterns
and
potential
exposures
described
above,
5
major
exposure
scenarios
were
identified
to
represent
the
extent
of
lindane
uses:
(1)
mixing/
loading/
application
of
formulations
for
on­
farm
seed
treatment,
(2)
mixing/
loading
and
applying
liquid
with
commercial
seed­
treatment
equipment,
(3)
bagging
and
otherwise
handling
treated
seeds,
(5)
forklift
operation,
(6)
cleaning
seed
treatment
equipment,
(7)
mixing/
loading/
planting
of
treated
seed
for
planting.

2.1.1
Submitted
Studies
Mixer/
loader/
applicator
exposure
data
for
lindane
were
required
since
one
or
more
toxicological
criteria
had
been
triggered.
Requirements
for
applicator
exposure
studies
are
addressed
by
Series
875
Group
A
(formerly
Subdivision
U
of
the
Pesticide
Assessment
Guidelines).
Three
exposure
studies,
one
addressing
on­
farm
treatment
have
been
provided
(Appendix
A),
another
addressing
commercial
seed
treatment
(Appendix
B),
a
third
addressing
planting
of
treated
seed
(Appendix
C)

2.1.2
Summary
of
Occupational
Handler
Exposures
Table
5
presents
the
exposure
scenarios,
application
rates,
and
amount
potentially
handled
that
have
been
used
for
the
exposure
calculations.
These
are
restricted
to
canola
and
wheat
for
commercial
seed
treatment
and
wheat
for
on­
farm
treatments
as
representative
of
typical
applications.
Exposures
for
handling
treated
seed
before
planting
and
planting
treated
seed
use
parameters
for
wheat
and
canola
as
representative
crops.
Therefore,
the
rates/
seed
types
presented
in
Table
5
are
not
all
conclusive
and
no
attempt
has
been
made
to
assess
a
range
of
application
rates
to
ensure
that
all
use
rates
and
exposure
scenarios
are
represented.
9
2.1.3
Summary
of
Uncertainties
The
assumptions
and
uncertainties
are
identified
below
to
be
used
in
risk
management
decisions:

C
Application
Rates:
Based
on
wheat
for
on
farm
treatment
and
canola
for
commercial
seed
treatment.
Other
types
of
seed
may
have
slightly
different
rates
but
these
differences
are
unlikely
to
appreciably
alter
the
exposure/
risk
assessment.

C
Amount
Handled:
For
commercial
seed
treatment
the
amounts
handled
are
assumed
to
be
equal
to
the
amounts
handled
at
the
facilities
used
in
the
study
described
in
the
Appendices.
On
farm
treatment
exposures
were
estimated
assuming
that
enough
wheat
seed
could
be
treated
and
planted
for
100
acres
per
day
at
a
rate
of
120
pounds
of
seed
per
acre.

C
Unit
Exposures:
The
unit
exposure
values
for
commercial
seed
treatment
and
planting
of
treated
seed
were
derived
from
surrogate
studies.
The
median
exposure
value
was
used
for
commercial
seed
treatment
(Appendix
B)
and
the
arithmetic
mean
was
used
for
the
loading/
planting
task
(Appendix
C).
10
Table
4:
Exposure
Variables
for
Uses
of
Lindane
Exposure
Scenario
(Scenario
#)
Are
Chemical
Specific
Monitoring
Data
Available
Are
PHED
Data
Available?
Application
Rates
(lb
ai/
amt
of
seed)
Daily
lb
Seed
Treated/
Handled
Lb
ai
Handled/
day
Applicator/
Handler
Exposure
(1)
mixing/
loading/
planting
of
dry
formulations
for
on
farm
treatment
Yes
MRID
#44440585­
02
No
0.023
lb
ai/
bushel
(60
lbs
seed)
for
wheat
12000
lbs
seed,
see
Appendix
A)
4.7
a
(2)
mixing/
loading
and
applying
liquid
with
a
commercial
seedtreatment
equipment
No
MRID
#45200002
No
Wheat:
0.043lb
ai/
100
lb
seed
treated
176000
76
Canola
(low­
end):
0.75
lb
ai/
100
lb
seed
treated
176000
1320
Canola
(high­
end):
1.5
lb
ai/
100
lb
seed
treated
176000
2640
(3)
handler
for
commercial
seedtreatment
equipment
(i.
e.
bagging,
sewing,
stacking)
with
chemical
resistant
coveralls
over
long
sleeve
shirt
long
pants,
chemical
resistant
gloves
No
MRID
#45200002
No
Wheat:
0.043lb
ai/
100
lb
seed
treated
176000
76
Canola
(low­
end):
0.75
lb
ai/
100
lb
seed
treated
176000
1320
Canola
(high­
end):
1.5
lb
ai/
100
lb
seed
treated
176000
2640
(4)
handler
for
commercial
seedtreatment
equipment
(i.
e.
bagging,
sewing,
stacking)
with
cotton/
polyester
coveralls
over
long
sleeve
shirt
long
pants,
chemical
resistant
gloves
No
MRID
#45200002
No
Wheat:
0.043lb
ai/
100
lb
seed
treated
176000
76
Canola
(low­
end):
0.75
lb
ai/
100
lb
seed
treated
176000
1320
Canola
(high­
end):
1.5
lb
ai/
100
lb
seed
treated
176000
2640
(5)
Forklift
operator
­
chemical
resistant
coveralls
over
long
sleeve
shirt
long
pants,
chemical
resistant
gloves
No
MRID
#45200002
No
Wheat:
0.043lb
ai/
100
lb
seed
treated
176000
76
Canola
(low­
end):
0.75
lb
ai/
100
lb
seed
treated
176000
1320
Canola
(high­
end):
1.5
lb
ai/
100
lb
seed
treated
176000
2640
(6)
Worker
Cleaning
seed
treatment
equipment
­
chemical
resistant
coveralls
over
long
sleeve
shirt
long
pants,
chemical
resistant
gloves
No
MRID
#45200002
No
Wheat:
0.043lb
ai/
100
lb
seed
treated
NA
NA
Canola
(low­
end):
0.75
lb
ai/
100
lb
seed
treated
NA
NA
Table
4:
Exposure
Variables
for
Uses
of
Lindane
Exposure
Scenario
(Scenario
#)
Are
Chemical
Specific
Monitoring
Data
Available
Are
PHED
Data
Available?
Application
Rates
(lb
ai/
amt
of
seed)
Daily
lb
Seed
Treated/
Handled
Lb
ai
Handled/
day
11
Canola
(high­
end):
1.5
lb
ai/
100
lb
seed
treated
NA
NA
(7)
Planting
treated
seed
Enclosed
cab
No
MRID
#42251901
No
Wheat:
0.043lb
ai/
100
lb
seed
treated
3000
12.9
Canola
(low­
end):
0.75
lb
ai/
100
lb
seed
treated
1000
7.5
Canola
(high­
end):
1.5
lb
ai/
100
lb
seed
treated
1000
15
a
Data
are
available
from
on
farm
treatment
study
(Appendix
A)
c
Daily
amount
treated
based
on
HEDs
estimates
of
acreage
that
would
be
reasonably
expected
to
be
planted
in
a
day
for
commercially
treated
seed.
The
acres
per
day
assumed
120
lbs.
of
wheat
per
acre,
planting
an
average
of
250
acres
per
day
(2).

2.2
Risk
From
Handler
Exposures
EPA
calculated
the
potential
risk
to
persons
from
handler
exposures
and
planting
of
treated
seed
using
the
daily
dermal
exposure
scenarios
identified
in
the
exposure
section.

Potential
dermal
and
inhalation
daily
exposures
for
occupational
handlers
were
calculated
using
the
following
formulas
(10
percent
dermal
absorption
was
assumed):

The
inhalation
and
dermal
daily
doses
were
calculated
using
the
following
formulas:
12
2.2.1
Risk
From
Handler
Exposures
Margins
of
Exposure
(MOEs)
were
calculated
for
handlers
for
short­
term
(one
to
seven
days)
and
intermediate­
term
(one
week
to
several
months)
durations
for
both
dermal
and
inhalation
exposures.

The
MOEs
were
calculated
using
the
following
formulas:
13
2.2.2
Summary
of
MOEs
The
daily
exposures,
resulting
short
and
intermediate
term
MOEs
are
presented
in
Table
7.
The
exposure
scenario
descriptions
are
presented
in
Table
8.
The
results
of
the
short­
term
dermal
exposure
duration
indicate
that
the
MOEs
range
from
5.2
for
on
farm
seed
treatment
to
34000
for
the
planting
of
treated
seed
.
A
total
of
9
dermal
and
inhalation
MOEs
were
calculated
for
the
various
scenarios.
Based
on
the
level
of
protection
used
in
the
studies,
all
of
the
MOEs
for
the
application
portion
of
seed
treatment
were
less
than
100.
All
other
dermal
MOEs
were
above
100.
Inhalation
MOEs
for
workers
other
than
applicators
for
commercial
treatment
and
seed
handlers
at
large
facilities
are
greater
than
100.

2.2.3
Cancer
Risks
The
OPP/
Cancer
Assessment
Review
Committee
(CARC)
has
completed
the
review
of
newly
submitted
carcinogenicity
study
in
CD­
1
mice
along
with
other
data.
In
accordance
with
the
EPA
Draft
Guidelines
for
Carcinogen
Risk
Assessment
(July,
1999),
the
CARC
has
classified
lindane
into
the
category
"Suggestive
evidence
of
carcinogenicity,
but
not
sufficient
to
assess
human
carcinogenic
potential"
based
on
an
increased
incidence
of
benign
lung
tumors
in
female
mice
only.
The
Committee,
therefore,
recommended
that
the
quantification
of
human
cancer
risk
is
not
required.

2.2.4
Insufficient
Data
Other
studies
are
undergoing
review
by
HED
personnel
at
this
time
and
may
alter
our
estimate
of
exposure.
14
Table
5­
Daily
Exposures
and
MOEs
for
Commercial
Seed
Treatment
Plant
Worker
Exposure
Exposure
Scenario
(Scenario
#)
Application
Rates
(
lb
ai/
100
lbs
seed
or
Lb/
A)
Amount
Handled
per
Day
(lbs
a.
i.)
Unit
Exposure
(mg/
lb
ai)
a
Daily
Exposure
(mg/
kg/
day)
Short­
Term
MOEs
&

Intermediate
Term
MOES
Dermal
Inhalation
Dermal
b
Inhalation
s
Dermal
c
Inhalation
e
Mixing/
loading
/planting
dry
formulation
for
on
farm
seed
treatment
(1)
0.043
4.7
9.4
0.
0016
0.074
0.00011
16
1200
Treater
­
Closed
Transfer


chemical
resistant
coveralls
over
long­
sleeved
shirt,
long
pants,
chemical
resistant
gloves
(2)
1.5
(canola
high­
end)
76
0.00083
0.00012
0.036
0.0053
329
25
0.75
(canola
low­
end)
1320
0.00083
0.00012
0.018
0.0026
657
49
0.043
(wheat)
2640
0.00083
0.00012
0.0010
0.00015
11462
859
Bagger/
Sewer
/Stacker


chemical
resistant
coveralls
over
long­
sleeved
shirt,

longpants,
chemical
resistant
gloves
­
(3)
1.5
(canola
high­
end)
76
0.00026
0.00006
0.011
0.0026
1049
49
0.75
(canola
low­
end)
1320
0.00026
0.00006
0.0057
0.0013
2098
98
0.043
(wheat)
2640
0.00026
0.00006
0.00033
0.000076
36591
1718
Bagger/
Sewer
/Stacker
cotten/
polyester
coveralls
over
long­
sleeved
shirt,

longpants,
chemical
resistant
gloves
(4)
1.5
(canola
high­
end)
76
0.0003
0.00006
0.013
0.00264
909
49
0.75
(canola
low­
end)
1320
0.0003
0.00006
0.0066
0.0013
1818
98
0.043
(wheat)
2640
0.0003
0.00006
0.00038
0.000076
31712
1718
Forklift
Operator
­
chemical
resistant
coveralls
over
long

sleeved
shirt,
longpants,

chemical
resistant
gloves
(5)
1.5
(canola
high­
end)
76
0.00008
7.7E­
06
0.
0035
0.00034
34091
384
0.75
(canola
low­
end)
1320
0.00008
7.7E­
06
0.
0018
0.00017
6818
767
0.043
(wheat)
2640
0.00008
7.7E­
06
0.
00010
9.7E­
06
118922
13385
Cleaner
­
chemical
resistant
coveralls
over
long­
sleeved
shirt,
longpants,
chemical
resistant
gloves
(6)
1.5
(canola
high­
end)
76
0.00669
0.00119
0.00011
1.98E­
05
107623
6555
0.75
(canola
low­
end)
1320
0.00669
0.00119
0.00011
1.98E­
05
107623
6555
0.043
(wheat)
2640
0.00669
0.00119
0.00011
1.98E­
05
107623.3
6555
a
Median
unit
dermal
and
arithmetic
mean
inhaltion
unit
exposures
b
Dermal
Exposure
(mg/
kg/
day)
=
unit
exposure
(mg/
lb
ai)
x
amount
handled
per
day
(lbs
a.
i.)
/
bw
(60
kg).

c
Dermal
MOE
=
Dermal
NOAEL
(1.
2
mg/
kg)
/
[daily
exposure
(mg/
kg/
day)
x
dermal
absorption
factor
(10%)].

d
Inhalation
Exposure
(mg/
kg/
day)
=
inhalation
unit
exposure
(mg/
lb
ai)
x
amount
handled
per
day
(lbs
a.
i.)
/
body
weight
(70
kg).

e
Inhalation
MOE
=
NOAEL
(0.
13
mg/
kg/
day)
/
daily
exposure
(mg/
kg/
day).
15
Table
6.
Exposure
Scenario
Descriptions
for
the
Use
of
Lindane.

Exposure
Scenario
(Scenario
#)
Data
Source
Standard
Assumptions
a
Comments
b
Mixing/
loading
/planting
dry
formulation
for
on
farm
seed
treatment
(1)
Rhone­
Poulenc
Data
MRID
#
444058­
02
Assumes
enough
seed
treated
and
planted
for
100
Acres
per
day
All
data
were
for
gloved
hands;
(see
study,

Appendix
A.
)

Mixing/
loading/
application
of
liquid
formulation
for
commercial
seed
treatment
(2)
Uniroyal
Data
MRID
#
447305­
01
176000
lbs
of
seed
per
day
See
study
review;
based
on
geometric
mean
of
data
and
amounts
of
seed
from
study
data
Seed
Handler
for
commercial
seed
treatment
(3,

4,5,6)
Uniroyal
Data
MRID
#
447305­
01
176000
lbs
of
seed
per
day
See
study
review;
based
on
geometric
mean
of
data
and
amounts
of
seed
from
study
data
Loading
and
planting
treated
seed
for
planting
(7)
MRID
422519­
01
Assumes
250
acres
are
planted
per
day
at
120
lbs
of
seed
per
acre
for
wheat;
4
lbs
per
acre
for
canola,
commercially
treated
seed
Appendix
C
a
All
Standard
Assumptions
are
based
on
an
8­
hour
work
day
as
estimated
by
HED.
16
REFERENCES
1)
Lindane
­
Report
of
the
Hazard
Identification
Assessment
Review
Committee,
July
27,
2000.

2)
Memorandum
from
S.
Tadayon
(CEB1)
to
A.
Khasawinah
(RRB4)
titled
"Occupational
and
Residential
Exposure
Assessment
and
Recommendations
for
the
Registration
Eligibility
Decision
Document
for
Imazalil",
dated
April
15,
2,000.

3)
EPA
(1998)
Surrogate
Exposure
Guide,
Estimates
of
Worker
Exposure
from
the
Pesticide
Handler
Exposure
Database
Version
1.1
4)
Memorandum
from
M.
Howard
(SRRD)
to
Lindane
RED
Team
Members
titled
"Final
Lindane
Use
Closure
Memo"
dated
May
17,
2000
(EMAIL).

cc:
Lindane
file
(009001)
Correspondence
file
R.
Kent
(RRB4/
7509C)
D.
Jaquith
(RRB4/
7509C)
17
APPENDIX
A.
MANUAL
SEED
TREATMENT
(at
farm):

CITATION:
Fenske,
R.
A.,
A.
M.
Blacker,
S.
J.
Hamburger,
and
G.
S.
Simon
(1990)
Worker
Exposure
and
Protective
Clothing
Performance
During
Manual
Seed
Treatment
with
Lindane.
Arch.
Environ.
Contam.
Toxicol.
19,
190­
196.

Fenske,
R.
A.
Reregistration
of
Lindane
Technical
Case
No.
0315,
Chemical
No.
9001.
Worker
Exposure
to
Lindane
During
Manual
Seed
Treatment.
MRID
No.
444058­
02
Dermal
and
respiratory
exposures
of
4
male
workers
with
prior
experience
were
monitored
during
the
manual
treatment
of
winter
wheat
at
a
commercial
wheat
farm
in
South
Dakota.
The
operations
are
considered
to
be
representative
of
manual
seed
treatments
in
the
midwest.
A
dust
formulation
containing
18.75
percent
lindane,
packaged
in
10
lb
bags
was
applied
at
the
label
rate
of
2
ounces
per
bushel
of
seed.
A
total
of
720
bushels
of
seed
were
treated.
The
treatment
procedure
involved
the
addition
of
grain
to
a
4
compartment,
12
bushel
grain
drill.
The
label
instructions
indicate
the
user
is
to
fill
the
drill
box
half
full
of
seed
and
add
half
of
the
formulation.
The
seed
and
formulation
are
then
mixed
with
a
stick.
The
rest
of
the
grain
is
then
added
and
the
procedure
repeated.
After
thorough
mixing
the
seed
was
removed
by
a
vacuum.
Workers
monitored
in
this
study
did
not
participate
in
the
vacuuming
procedure.

Each
mixing
consisted
of
the
application
of
24
oz
(680
g)
of
the
formulation
to
12
bushels
of
grain.
A
plastic
scoop,
cut
from
a
plastic
bottle
and
determined
to
hold
12
oz
of
formulation,
was
used
to
remove
the
powder
from
the
bag.
The
scoop
was
used
to
spread
the
formulation
evenly
over
the
seed.

Each
replicate
consisted
of
five
mixings
conducted
by
each
of
the
four
workers,
the
mixing
activity
lasting
4­
6
minutes.
The
mixing
periods
averaged
24
minutes
and
were
separated
by
10­
20
minute
breaks.
This
was
considered
to
be
equal
to
one
"work
period".
During
this
time
a
worker
handled
120
oz
of
formulation
or
1.4
lb
of
active
ingredient.
Each
volunteer
performed
the
tasks
three
times
(total
of
60
mixings),
yielding
a
total
of
12
work
periods.
During
treatments
the
workers
wore
the
label
required
long
sleeve
shirt,
long
pants,
Nitrile
gloves,
a
baseball
cap,
and
a
pesticide
respirator.
All
clothing
was
new
and/
or
prewashed
to
avoid
confounding
analytical
problems.
The
workers
did
not
remove
their
gloves
during
the
procedure
but
did
during
breaks.

Dermal
exposures
were
monitored
using
gauze
dosimeters
encased
in
an
envelope
with
a
5.6
cm
diameter
circle
exposed
to
the
environment
(25
cm²
total
area).
Dosimeters
were
either
attached
to
the
clothing
or
taped
to
the
skin
on
the
chest,
back,
shoulders,
forearms,
upper
legs,
or
lower
legs.
Two
sets
of
dosimeters
were
used,
one
outside
the
clothing
and
the
other
inside
the
work
garments.
Care
was
taken
to
avoid
overlap
of
the
dosimeters,
which
could
confound
the
results
of
the
inner
monitors.
Surface
areas
were
assumed
to
be
those
outlined
in
the
Agency's
Guidance
(OPPTS
875
Group
A
test
guidelines,
formerly
Subdivision
U).

Dermal
exposure
of
the
hands
was
monitored
by
hand
wash
with
250
mL
of
10
percent
isopropanol
in
distilled
water.
A
plastic
bag
was
wrapped
around
the
wrist
and
the
bag
shaken
for
about
30
seconds.
This
procedure
was
repeated
3
times,
resulting
in
a
pooled
volume
of
750
mL
for
each
hand.
Hand
rinses
were
conducted
for
each
hand
immediately
prior
to
the
exposure
period
and
again
18
immediately
after.
Approximately
75
mL
was
transferred
to
a
glass
jar
for
storage.

Respiratory
exposure
was
monitored
using
calibrated
battery
powered
pumps
attached
to
the
belt
with
a
37
mm
fiberglass
filter
attached
to
the
collar
in
the
breathing
zone.
The
flow
rate
was
approximately
2
liters
per
minute.

Dermal
dosimeters
and
air
filter
cassettes
were
removed
immediately
after
the
exposure
period.
Gauze
pads
were
removed
from
their
holders
with
solvent
rinsed
tweezers
and
placed
in
individual
4
ounce
glass
jars.
Filter
were
sealed
and
replaced
in
their
original
packing
containers.
All
samples
were
maintained
at
4°
C
during
shipment
and
storage.
Samples
arrived
at
the
analytical
laboratory
within
6
days
of
collection
and
analyzed
within
the
next
2
months.

Fifty
mL
of
hexane/
acetone
(1/
1,
v/
v)
was
added
to
the
dermal
dosimeters
jars
and
the
jars
shaken
for
1
hour.
A
100
:
L
aliquot
of
the
extract
was
added
to
a
10
mL
volumetric
flask
and
2
:
L
of
internal
standard/
surrogate
chemical
(aldrin
and
heptachlor,
respectively).
The
resulting
solution
was
brought
to
volume
with
hexane
The
results
of
exposure
monitoring
are
presented
in
Table
A1.
19
Table
A1.
Exposures
of
Workers
Applying
Lindane
as
a
Seed
Treatment
at
a
Rate
of
1.4
lb
ai)
Pounds
of
Active
Ingredient
per
60
Bushels
of
Grain
(3600
lbs
of
seed,
total.
Values
used
for
exposure
estimation
are
in
boldface.

Body
Region
Monitor
Location
Exposure
(mg)
Exposure
(mg/
lb
ai)

Mean
Median
Range
Mean
Median
Chest
Outer
3.21
2.43
0.92­
7.84
2.3
1.7
Back
Outer
2.48
2.48
0.85­
4.58
1.8
1.8
Forearms
Outer
17.75
15.25
5.57­
51.79
13.0
11.0
Upper
arms
Outer
4.43
3.88
0.99­
10.10
3.2
2.7
Upper
legs
Outer
33.96
20.46
2.90­
132.55
24.0
15
Lower
legs
Outer
1.34
9.64
0.43­
5.95
0.96
6.9
Chest
Inner
0.45
0.44
0.07­
0.71
0.32
0.31
Back
Inner
0.71
0.52
0.11­
2.59
0.51
0.37
Forearms
Inner
5.43
3.46
1.31­
16.70
3.9
2.5
Upper
arms
Inner
1.12
0.79
0.12­
2.91
0.80
0.56
Upper
legs
Inner
2.88
2.18
0.08­
9.32
2.1
1.6
Lower
legs
Inner
0.16
0.12
0­
0.33
0.11
0.086
Hands
0.74
0.71
0.4­
1.27
0.53
0.51
Head/
Neck
1.72
1.47
0.7­
3.58
1.2
1.1
Total
Dermal
13.21
9.69
9.4
7.1
Respiratory
0.0022
0
0­
0.016
0.0016
0
mg/
lb
ai
=
Exposure
(mg)
÷
1.4
lb
ai
20
Calculation
of
Daily
Exposures:

Assumptions:

1)
An
average
worker
weighs
60
kg
for
dermal
risk
assessment
and
70
kg
for
inhalation
exposure
and
has
standard
body
surface
areas
and
respiration
rates
as
presented
in
the
Pesticide
Assessment
Guidelines
(OPPTS
875
Group
A
test
guidelines).

2)
Examination
of
the
Census
of
Agriculture
data
for
Kansas
yielded
a
median
farm
sizes
of
in
the
100
to
249
acre
range.
Three
other
wheat
producing
states
(North
Dakota,
Washington,
and
Montana)
had
median
farm
sizes
in
the
250
to
499
acre
range.
A
farm
size
of
500
acres
was
assumed.
Workers
were
assumed
to
treat
and
plant
enough
seed
for
250
Acres
per
day,
yielding
a
short
term
exposure
scenario.

3)
Workers
are
assumed
to
wear
the
same
clothing
as
those
participating
in
the
study.
Typical
clothing
consists
of
a
long
sleeved
shirt,
long
pants,
and
chemical
resistant
gloves.

4)
Wheat
is
planted
at
a
rate
of
120
pounds
of
seed
per
acre
and
each
bushel
of
seed
weighs
60
pounds
(Hanson,
A.
A.
(Ed)
(1989)
Practical
Handbook
of
Agricultural
Science.
CRC
Press,
Inc.,
Boca
Raton,
FLA.)
and
BEAD
report.

5)
While
the
application
rate
varies
somewhat
for
various
types
of
seeds,
the
application
rate/
farm
size
is
considered
typical
for
lindane
seed
treatment
products.

Amount
of
seed
treated
per
8
hour
day:

Seed
treated
(lbs)
=
100
A/
day
x
120
lbs
seed/
A
l
=
12000
lb
seed/
day
Amount
of
lindane
handled
per
day:

Lbs
ai
handled
per
day
=
2
oz/
bushel
x
0.1875
x
200
bushels
seed/
day
x
1
lb/
16
oz
=
4.7
lbs
ai/
day
21
Estimation
of
Exposure
(manual
seed
treatment):

Dermal:

Dermal
Exposure
(mg/
kg/
day)
=
9.4
mg/
lb
ai
x
4.7
lbs
ai/
day
÷
60
kg
x
0.1
=
0.074
mg/
kg/
day
Respiratory:

Respiratory
Exposure
(mg/
kg/
day)
=
0.0016
mg/
lb
ai
x
12
lbs
ai/
day
÷
70
kg
=
0.00011
mg/
kg/
day
The
resulting
Dermal
MOE
is:

MOED
=
1.2
mg/
kg/
day
÷
0.074
mg/
kg/
day
=
16
The
resulting
Inhalation
MOE
is:

MOEI
=
0.13
mg/
kg/
day
÷
0.00011
mg/
kg/
day
=
1200
22
APPENDIX
B
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
Date:
April
23,
2002
MEMORANDUM
SUBJECT:
LINDANE:
REVISION
OF
EXPOSURE
ASSESSMENT
FOR
COMMERCIAL
SEED
TREATMENT
PLANT
WORKER
(MRID
45200002,
DP
Barcode
D282419)
(Excerpt)

FROM
David
Jaquith
Reregistration
Action
Branch
4
Health
Effect
Division
(7509C)

TO:
Rebecca
Daiss
Reregistration
Branch
4
Health
Effect
Division
(7509C)

2.2
Revised
Exposure
and
Risk
Estimates
HED
has
reevaluated
the
estimates
of
exposure
and
risk
from
treatment
of
wheat
and
canola
seed
with
lindane
using
median
unit
dermal
and
inhalation
exposures
provided
in
the
HELIX
289FS
Study.
Unit
exposures
used
for
this
assessment
are
summarized
in
Table
2.
Unit
exposure
data
from
the
HELIX
study
are
presented
in
detail
in
Appendix
A.

Table
2.
Unit
Dermal
and
Inhalation
Exposures
of
Workers
During
Seed
Treatment
and
Handling
of
Treated
Seed
1
Median
Unit
Dermal
and
Inhalation
Exposures
Treater
­
Closed
Transfer
­
Chemical­
Resistant
coveralls
over
long­
sleeve
shirt,
long
pants;
chemical
resistant
gloves
Dermal
(n=
17)
0.83
:
g/
lb/
ai
Inhalation
(n=
17)
0.12
:
g/
lb/
ai
Cleaner
­
Chemical­
Resistant
coveralls
over
long­
sleeve
shirt,
long
pants;
chemical
resistant
gloves
Dermal
(n=
7)
6.70
:
g/
kg
bw
Inhalation
(n=
7)
1.20
:
g/
kg
bw
Bagger/
Sewer/
Stacker
­
Chemical­
Resistant
coveralls
over
long­
sleeve
shirt,
long
pants;
chemical
resistant
gloves
Dermal
­
chemical
resistant
coveralls
(n=
34)
0.26
:
g/
lb/
ai
Dermal
­
Cotton/
polyester
coveralls
(n=
19)
0.30
:
g/
lb/
ai
Table
2.
Unit
Dermal
and
Inhalation
Exposures
of
Workers
During
Seed
Treatment
and
Handling
of
Treated
Seed
1
Median
Unit
Dermal
and
Inhalation
Exposures
23
Inhalation
(n=
53)
0.06
:
g/
lb/
ai
Forklift
Operator
­
cotton/
polyester
coveralls
over
long­
sleeve
shirt,
long
pants;
chemical
resistant
gloves
Dermal
(n=
12)
0.08
:
g/
lb/
ai
Inhalation
(n=
12)
0.008
:
g/
lb/
ai
1
Commercial
Seed
Treatment
Plant
Worker
Exposure
Study
with
Helix
289FS
Seed
Treatment
on
Canola
(MRID
452000­
02)

The
application
rate
in
the
HELIX
study
was
400
gm
thiamethoxam/
100
kg
seed
(0.88
lb/
220000
lb
seed).
The
throughput
of
seed
of
7000
kg/
hr
(15400
lb/
hr),
6800
kg
/hr(
14960
lb/
hr),
5000
kg/
hr
(11000
lb/
hr),
5000
kg/
hr
(11000
lb/
hr),
10000
kg/
hr
(22000
lb/
hr)
for
sites
1
to
5,
respectively.
The
following
assumptions
were
used
to
estimate
exposure:

6)
The
throughput
of
seed
for
both
wheat
and
canola
is
22000
lb/
per
hour
or
176000
lbs
per
8
hour
day.

7)
The
application
rate
for
wheat
is
0.043
lb
ai
per
hundred
weight
of
seed.
The
application
rate
for
canola
is
1.5
lb
(high­
end)
and
0.75
lb
(low­
end)
ai
per
hundredweight
of
seed.

3)
Pounds
handled
per
day
for
wheat:

lbs
handled
per
day
wheat
=
176000
lbs/
day
x
0.043
÷
100
lbs
=
76
lbs/
day
lbs
handled
per
day
canola
(high­
end)
=
176000
lbs/
day
x
1.5
÷
100
lbs
=
2640
lbs/
day
lbs
handled
per
day
canola
(low­
end)
=
176000
lbs/
day
x
0.75
÷
100
lbs
=
1320
lbs/
day
4)
Median
unit
dermal
and
inhalation
exposures
were
used
based
on
data
distribution.

5)
Worker
body
weight
for
dermal
exposure
=
60
kg
(female
body
weight
used
for
developmental
endpoint)
Worker
body
weight
for
inhalation
exposure
=
70
kg
24
APPENDIX
C
Date:
April
24,
2002
MEMORANDUM
SUBJECT:
REVISION
OF
EXPOSURE
ASSESSMENT
FOR
PLANTING
OF
SEED
TREATED
WITH
LINDANE
DP
BARCODE
D282418,
MRID
42251901
(Excerpt)

FROM
David
Jaquith
Reregistration
Action
Branch
4
Health
Effect
Division
(7509C)

TO:
Becky
Daiss
Reregistration
Branch
4
Health
Effect
Division
(7509C)

THRU
Susan
Hummel,
Senior
Scientist
Reregistration
Branch
4
Health
Effects
Division
(7509C)

2.0
CONCLUSIONS
HED
has
reevaluated
the
estimates
of
exposure
and
risk
from
planting
of
wheat
and
canola
seed
with
lindane
using
a
study
specifically
addressing
this
scenario
rather
than
using
PHED
as
a
model
for
planting
seeds.
Using
an
oral
NOAEL
of
1.2
mg/
kg/
day
to
assess
dermal
risk
and
an
inhalation
NOAEL
of
0.13
mg/
kg/
day
the
MOEs
are
:
25
Estimation
of
Dermal
and
Respiratory
Exposures
or
Risksof
Workers
Planting
Wheat
and
Canola
Seed
Treated
with
Lindane
Dermal
Exposure
(mg/
kg/
day)
Respiratory
Exposure
(mg/
kg/
day)
MOE
Dermal
Respiratory
Wheat
0.0013
0.00011
920
1200
Canola
0.0015
0.00013
800
1000
Examination
of
the
data
from
the
revised
assessment,
derived
from
a
planting
study
(not
included
in
PHED)
and
the
previous
assessment
from
PHED
indicates
that
there
are
a
large
number
of
non
detect
samples
in
both
of
the
data
sets.
Since
the
original
PHED­
derived
estimates,
which
separated
loading
from
planting
showed
large
numbers
of
non
detects
for
the
planting
function,
it
is
evident
that
the
loading
contributes
the
majority
of
the
exposure
and
that
the
actual
planting
task
contributes
relatively
little
to
the
total
exposure.

3.0
CALCULATION
OF
EXPOSURES
In
order
to
estimate
the
exposures
of
workers
planting
seed
treated
with
lindane
a
number
of
assumptions
regarding
amount
of
seed
planted
and
other
parameters
were
required.

6)
It
is
assumed
that
250
acres
of
wheat
or
canola
can
be
planted
in
a
day
(2).

7)
An
average
worker
has
a
body
weight
of
60
kg
(a
change
from
the
previous
assessment
due
to
changes
in
the
toxicological
parameters)
for
dermal
assessment.
A
weight
of
70
kg
is
used
for
inhalation
assessments.

8)
Wheat
is
planted
at
a
rate
of
120
lbs
of
seed
per
acre.
Canola
is
planted
at
a
rate
of
4
lbs
seed
per
acre.

9)
The
application
rate
of
lindane
on
wheat
seed
is
0.68
oz/
cwt
(0.043
lb/
cwt).
For
canola
the
rate
is
23.3
oz/
cwt
(1.5
lb
ai/
cwt).
See
Appendix
B.

10)
The
dermal
absorption
of
lindane
is
10
percent
(1).

3.1
Exposure
Assessment
for
Wheat
Amount
of
lindane
handled
per
day:
26
Lbs
ai/
day
=
250
A/
day
x
120
lb
seed/
A
x
0.043
lb
ai/
100
lbs
seed
=
12.9
lb
ai/
day
The
resulting
dermal
exposure
using
arithmetic
mean
values
from
Appendix
A
is:

Dermal
Exposure
(mg/
kg/
day)
=
0.0597
mg/
lb
ai
x
12.9
lb
ai/
day
x
0.1
(abs)
÷
60
kg
bw
=
0.0013
mg/
kg/
day
The
resulting
dermal
MOE
using
a
NOAEL
of
1.2
mg/
kg/
day
is:

MOE
=
1.2
mg/
kg/
day/
0.0013
mg/
kg/
day
=
920
The
respiratory
exposure
is:

Respiratory
Exposure
(mg/
kg/
day)
=
12.9
lb
ai/
day
x
0.0006
mg/
lb
ai
÷
70
kg
=
0.00011
mg/
kg/
day
The
resulting
respiratory
MOE
using
a
NOAEL
of
0.13
mg/
kg/
day
is:

MOE
=
0.13
mg/
kg/
day/
0.00011
mg/
kg/
day
=
1200
3.1
Exposure
Assessment
for
Canola
Amount
of
lindane
handled
per
day:

Lbs
ai/
day
=
250
A/
day
x
4
lb
seed/
A
x
1.5
lb
ai/
100
lbs
seed
=
15
lb
ai/
day
The
resulting
dermal
exposure
using
arithmetic
mean
values
from
Appendix
A
is:

Dermal
Exposure
(mg/
kg/
day)
=
0.0597
mg/
lb
ai
x
15
lb
ai/
day
x
0.1
(abs)
÷
60
kg
bw
=
0.0015
mg/
kg/
day
The
resulting
dermal
MOE
using
a
NOAEL
of
1.2
mg/
kg/
day
is:

MOE
=
1.2
mg/
kg/
day/
0.0015
mg/
kg/
day
=
800
The
respiratory
exposure
is:

Respiratory
Exposure
(mg/
kg/
day)
=
15
lb
ai/
day
x
0.0006
mg/
lb
ai
÷
70
kg
=
0.00013
mg/
kg/
day
The
resulting
respiratory
MOE
using
a
NOAEL
of
0.13
mg/
kg/
day
is:
27
MOE
=
0.13
mg/
kg/
day/
0.00013
mg/
kg/
day
=
1000
28
