Page
1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
Date:
May
15,
2002
SUBJECT:
BEAD
Review
of
Korpalski
Handler
Exposure
Assessment
for
Lindane
Use
as
a
Seed
Treatment
in
the
U.
S.

FROM:
David
W.
Brassard,
Senior
Entomologist
Herbicide
and
Insecticide
Branch
Biological
and
Economic
Analysis
Division
(7503C)

THRU:
Arnet
Jones,
Chief
Herbicide
and
Insecticide
Branch
Biological
and
Economic
Analysis
Division
(7503C)

TO:
Mark
Howard,
Chemical
Review
Manager
Reregistration
Branch
III
Special
Review
and
Reregistration
Division
(7508C)

Peer
Review
Date:
May
8,
2002
SUMMARY
In
response
to
a
request
from
SRRD,
BEAD
reviewed
the
"Handler
Exposure
Assessment
for
Lindane
Use
as
a
Seed
Treatment
in
the
United
States"
submitted
by
Uniroyal
Chemical
Company.
BEAD
believes
that
the
application
rates
and
seed
planting
rates
used
in
Uniroyal's
assessment
are
reasonable
but
disagrees
with
Uniroyal's
estimate
of
80
acres
planted
per
day
for
corn,
wheat,
and
canola.
Based
on
the
Science
Advisory
Council
for
Exposure
Policy
Number:
9.1,
BEAD
believes
that
200
acres
planted
per
day
is
a
more
reasonable
upper
bound
estimate.
BEAD
also
disagreed
with
Uniroyal's
seed
treatment
equipment
throughput
assumptions
for
wheat
of
165,000
pounds
of
wheat
seed
per
day.
Based
on
personal
communications
with
seed
treaters
in
the
field
and
review
of
seed
treatment
equipment
technical
specifications,
BEAD
believes
that
commercial
seed
treaters
commonly
use
equipment
which
treats
480,000
pounds
of
wheat
seed
per
day.

BACKGROUND
1
BEAD
estimate
based
on
the
percentage
of
growers
using
4
to
20
row
planters
on
farm
sizes
less
than
500
acres
as
discussed
in
Brassard
and
Ng
(1993).

Page
2
In
response
to
a
request
from
SRRD,
BEAD
reviewed
the
"Handler
Exposure
Assessment
for
Lindane
Use
as
a
Seed
Treatment
in
the
United
States"
submitted
by
Uniroyal
Chemical
Company
and
Authored
by
Stefan
J.
Korpalski.
In
their
request,
SRRD
asked
BEAD
to
review
throughput
assumptions
and
lindane
handling
scenarios
made
by
the
registrant
in
their
risk
assessment
of
occupational
exposures
to
lindane.

BEAD's
REVIEW
OF
LINDANE
HANDLING
SCENARIOS
AND
THROUGHPUT
ASSUMPTIONS
The
application
rates
and
seed
planting
rate
used
in
the
Korpalski
study
appear
to
be
reasonable
(Table
1).
In
BEAD's
opinion,
Korpalski's
estimate
of
acres
planted
per
day
are
too
low.
Korpalski
assumed
an
80
acre
per
day
planting
rate
for
corn,
wheat,
and
canola.
Their
basis
was
that
this
is
the
standard
EPA
assumption
(Policy
009,
4/
1/
99).
EPA's
current
policy
(Science
Advisory
Council
for
Exposure
Policy
Number:
9.1,
revised
4/
25/
01)
for
granular
applications
to
corn
and
wheat
are
200
acres
per
day.
The
EPA
policy
estimates
are
based
(in
part)
on
an
analysis
by
Brassard
and
Ng
(1993)
which
assumed
the
use
of
20
row
(or
50
foot
wide)
planters
and
an
eight
hour
work
day.
These
estimates
should
be
considered
as
reasonable
upper
bound
(95
th
percentile)
1
.
BEAD
is
aware
of
situations
in
which
growers
working
long
hours
on
24
row
(60
foot
wide)
planters
have
planted
300
to
400
acres
in
a
day.
(Muggeridge,
1997).

In
BEAD's
opinion,
Korpalski's
seed
treatment
equipment
throughput
assumptions
are
reasonable
for
canola
but
on
the
low
side
for
wheat.
For
canola,
Korpalski
estimated
that
92,000
pounds
of
seed
could
be
treated
per
day
with
a
Gustafson®
continuous
batch
coater,
model
CBT50.
The
manufacturers
specifications
for
this
piece
of
equipment
state
that
it
is
capable
of
treating
up
to
13,000
lbs
of
seed
per
hour
or
104,000
pounds
of
seed
per
day
(Gustafson,
2002).
I
spoke
to
Roger
Weinlaeder
(of
Weinlaeder
Seeds
in
Drayton,
ND)
and
he
uses
a
Cerguard®
seed
treater
which
treats
an
average
of
5,000
pounds
of
canola
seeds
hour
and
can
treat
up
to
7,000
or
8,000
pounds
of
seed
per
hour
under
ideal
conditions
(equivalent
to
40,000
to
64,000
pounds
of
canola
seed
per
day
(Weinlaeder,
2002).

For
wheat,
the
Korpalski
assessment
assumed
that
wheat
seed
is
treated
with
equipment
such
as
the
Gustafson
S­
100,
which
can
treat
about
165,000
lbs
of
wheat
seed
per
day.
Roger
Weinlaeder
treats
wheat
seed
with
a
Boss®
seed
treater
that
can
treat
60,000
pounds
of
seed
per
hour
or
480,000
pounds
of
seed
per
day
(Weinlaeder,
2002).
There
are
several
other
large
seed
treaters
commercially
available
that
can
treat
this
volume
(i.
e.
480,000
lbs
of
seed
per
day)
of
wheat
including
the
Petkus®
CTD
and
the
Niklas®
W.
N.
36
S
(Niklas,
2002,
Petkus,
2002)..

Table
1.
Comparison
of
Korpalski
and
BEAD
Estimates
Page
3
Crop
Application
Rate
(lbs
ai/
cwt)
Seed
Planting
Rate
(lbs/
acre)
Acres
Planted/
Treated
per
day
Seed
Treatment
Equipment
Throughput
Assumptions
(Pounds
of
seed
treated
per
day)

Korpalski
BEAD
Korpalski
BEAD
corn
0.056
14
80
200
­­

wheat
0.031
120
80
200
165,000
480,000
canola
0.
75
5.
36
80
200
92,000
40,000­
104,000
References
Brassard,
D.
W.
and
Y.
Ng.
1993.
Transmittal
of
Corn
Cluster
Exposure
Parameters.
Internal
Memorandum
Larry
Dorsey
(HED).
12
pp.

Gustafson,
2002.
Technical
Specifications
for
the
Gustafson
Continuous
Batch
Coater,
Model
CBT50,
http://
www.
gustafson.
com/
gustafson_
equipment/
id69.htm
Korpalski,
S.
J.
2002.
Handler
Exposure
Assessment
for
Lindane
Use
as
a
Seed
Treatment
in
the
United
States.
Exposure
study
submitted
to
EPA
by
Uniroyal
Chemical
Company,
Bethany,
CT
06524,
13
pp.

Muggeridge,
J.
M.
1997.
Up
to
400
acres
a
day.
Farm
&
Country
Magazine,
February
1997
issue,
Agricultural
Publishing
Company
Ltd.,
Ottawa,
Ontario,
Canada.

Niklas,
2002.
Technical
Specifications
for
the
Niklas
liquid
seed
treaters
type
W.
N.
36
S.
http://
www.
niklas­
beizgeraete.
de/
English/
Conti_
Units/
Tech­
Data/
tech­
data.
html
Petkus,
2002.
Technical
Specifications
for
the
Petkus
CTD.
Seed
Treater.
http://
www.
petkus.
net/
treater.
htm#
THE
CTD­
SERIES
Weinlaeder,
Roger.
2002.
Personal
Communication
with
David
W.
Brassard
on
4/
26/
02.
ND
Weinlaeder
Seeds,
Drayton,
ND.
701­
454­
6427
