January
27,
1999
MEMORANDUM
SUBJECT:
REVISED
APPLICATOR
EXPOSURES
TO
DICHLORVOS
(
DDVP)
RESULTING
FROM
DAIRY
BARN
AND
ANIMAL
SPRAY
USES
(
PC
Code
084001,
Barcode
D251330)

FROM:
David
Jaquith
Chemistry
and
Exposure
Branch
2
Health
Effects
Division
(
7509C)

TO:
Jess
Rowland
Risk
Characterization
and
Analysis
Branch
Health
Effects
Division
(
7509C)

THRU:
Sue
Hummel,
Senior
Scientist
Chemistry
and
Exposure
Branch
2
Health
Effects
Division
(
7509C)

1.0
INTRODUCTION
In
August
1987,
HED
conducted
a
series
of
exposure
assessments
for
DDVP
addressing
a
number
of
scenarios
(
1).
Application
of
DDVP
to
dairy
barns
and
direct
applications
to
animals
were
included
in
this
document.
The
assessments
were
conducted
in
support
of
the
Registration
Standard
for
this
insecticide
(
2).
An
updated
assessment
was
conducted
in
1993
(
3)
in
support
of
the
PD
2/
3
for
this
chemical
(
4).
The
estimates
were
derived
from
surrogate
data
found
in
the
scientific
literature
and
from
proprietary
studies
submitted
by
other
registrants
and
provided
a
range
of
exposures
under
various
conditions.
The
assessment
attempted
to
account
for
the
myriad
of
possible
application
methods
that
might
be
used
for
this
material
and
provided
a
range
of
potential
exposures,
depending
on
application
equipment
and
protective
clothing
scenarios.
It
was
assumed
at
that
time
that
the
methods
of
application
for
animal
facilities
were
similar
to
those
used
for
application
of
DDVP
to
mushroom
houses
and
greenhouses.
Hand
held
fogger
uses,
previously
used
for
greenhouse/
mushroom
house
applications,
have
been
voluntarily
deleted
by
the
registrant
(
5).
Application
to
dairy
barns/
animal
facilities
and
direct
applications
to
animals
would
be
performed
using
low
or
high
pressure
sprayers.
D251330
­
Page
2
of
8
2.0
CONCLUSIONS
HED
has
provided
revised
estimates
of
the
dermal
and
inhalation
exposures
of
workers
applying
DDVP
for
direct
animal
treatment
(
non­
poultry)
and
for
animal
premise
treatment,
including
dairy
barns.
The
estimates
were
derived
from
examining
limited
studies
found
in
the
Pesticide
Handlers
Exposure
Database
(
PHED
V1.1).
Since
it
is
not
known
exactly
what
types
of
equipment
may
be
used
in
any
given
facility
three
different
handwand
types
were
examined,
hand
held
(
compressed
air
sprayer),
backpack
sprayer,
and
portable
sprayer
on
wheels.
It
was
assumed
that
workers
wear
long
sleeve
shirts,
long
pants
and
chemical
resistant
gloves.
It
must
be
noted
that
not
all
of
the
labels
were
clear
on
their
clothing
requirements.
Such
clothing
must
be
worn,
at
a
minimum,
for
this
assessment
to
be
valid.

The
estimated
daily
exposures
and
resulting
Margins
of
Exposure
(
MOEs)
are
presented
in
Table
1.
The
datasets
obtained
from
PHED,
described
in
section
3.2
contain
only
a
minimum
number
of
replicates
and
must
be
considered
to
be
low
confidence
data.
It
must
also
be
noted
that
in
the
case
of
3
of
the
4
datasets
selected
from
PHED
the
respiratory
exposures
are
based
completely
on
surrogate
data
from
a
different
compound.
As
such
there
is
a
large
artifactual
component
to
these
to
the
respiratory
estimates.
DDVP
is
a
much
more
volatile
chemical
(
vapor
pressure
=
10­
2
mm
Hg)
than
most
pesticides.
The
effect
that
this
could
have
on
respiratory
exposures
is
not
known
but
could
be
considerable.
D251330
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Page
3
of
8
Table
1.
Estimated
Dermal
Exposures,
Respiratory
Exposures,
and
Resulting
Margins
of
Exposure
(
MOEs)
for
70
kg
Workers
Applying
DDVP
Directly
to
Animals
(

Nonpoultry
and
Animal
Premises.
Workers
are
assumed
to
wear
long
sleeve
shirts,

long
pants,
and
gloves.
Dermal
absorption
is
assumed
to
be
11
percent.

Equipment
Unit
Exposure
(
mg/
kg/
lb
ai)
Amount
Handled
(
lb
ai/
day)
Exposure
(
mg/
kg/
day)
MOE
Dermal
Resp.
Dermal
Resp.
Dermal
Resp.
Total
Direct
Animal
Treatment
(
Intermediate
Term
Exposure):

Hand
Held
0.0024
0.0004
0.092
0.000024
0.000037
4200
2700
4100
Backpack
0.037
0.0004
0.092
0.00037
0.000037
270
2700
270
Backpack
0.0039
0.0009
0.092
0.000039
0.000083
2600
1200
2500
Portable
Sprayer
on
Wheels
0.0099
0.0011
0.092
0.000100
0.000101
1000
1000
1000
Space
Spray
(
Short
Term
Exposure):

Hand
Held
0.0024
0.0004
0.033
0.000009
0.000013
56000
38000
23000
Backpack
0.037
0.0004
0.033
0.00013
0.000013
3800
38000
3800
Backpack
0.0039
0.0009
0.033
0.000014
0.000030
35000
17000
11000
Portable
Sprayer
on
Wheels
0.0099
0.0011
0.033
0.000036
0.000036
14000
14000
6900
Short
Term
Dermal
and
Inhalation
NOAEL
=
0.5
mg/
kg/
day
(
Appendix
B.);
Target
MOE
=
10
Intermediate
Dermal
and
Inhalation
NOAEL
=
0.1
mg/
kg/
day
(
Appendix
B.);
Target
MOE
=
10
D251330
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Page
4
of
8
3.0
CALCULATION
OF
EXPOSURES
3.1
Assumptions
The
following
assumptions
were
used
to
estimate
the
exposures
of
workers
applying
DDVP
to
cattle
and
animal
facilities:

a)
An
average
worker
weighs
70
kg
and
has
a
respiratory
volume
of
1.5
m3
per
hour.
NOTE:
This
is
the
respiratory
default
value
for
PHED,
the
data
system
used
for
these
analyses.

b)
A
1.0
percent
solution
of
DDVP
is
applied
using
a
mist
sprayer
at
a
rate
of
2
fluid
ounces
of
spray
per
animal
per
day.
The
total
amount
applied
per
animal
is
estimated
to
be
approximately
2.3
­
4.5
g
DDVP
per
animal
per
week
or
0.33
­
0.64
g
per
day
(
6).

c)
A
typical
farm
consists
of
65
head
of
cattle
(
6).

d)
The
clothing
worn
consists
of
gloves,
long
sleeve
shirt
with
long
pants.
NOTE:
Gloves
are
NOT
required
by
most
of
the
labels
submitted
to
HED.
Such
language
MUST
be
added
to
the
labels
for
this
exposure
assessment
to
be
valid.

e)
While
some
labels
indicate
that
daily
application
(
probably
for
direct
application
to
cattle)
is
allowable,
The
use
assessment
(
3)
indicates
that
the
material
is
applied
at
2
week
intervals
for
22
weeks
(
June
through
October
or
11
applications
per
year)
(
3).
This
is
considered
to
be
a
short
term
exposure
scenario
with
a
NOAEL
of
0.1
mg/
kg/
day.
Application
to
animal
facilities
is
considered
to
be
a
short
term
exposure
scenario
with
a
NOAEL
of
0.5
mg/
kg/
day
(
4).

f)
Dermal
absorption
is
assumed
to
be
11
percent
(
4).
Respiratory
values
are
not
corrected
for
absorption.

The
average
amount
applied
per
day
for
direct
application
to
cattle
would
be:

Amount
Handled
(
lb
ai/
day)
=
65
head/
day
x
0.64
g
ai/
head
x
1
lb
ai/
454
g
ai
=
0.092
lb
ai/
day
HED
realizes
that
there
are
facilities
containing
more
than
65
head
of
cattle.
However,
it
is
likely
that
these
establishments
would
use
automatic
systems
such
as
treadle
sprayers
or
rubbing
equipment
rather
than
hand
spraying,
because
of
economic
D251330
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Page
5
of
8
considerations.
There
are
no
data
with
which
to
evaluate
worker
exposure
under
these
conditions.

g)
An
average
dairy
barn
has
the
dimensions
30
ft
x
100
ft
x
9
ft
(
total
area
covered
by
spray
is
estimated
to
be
is
5340
ft2).
One
such
barn
is
treated
per
day.
The
total
volume
would
be
27,000
ft
³
for
space
spray
treatment.

h)
Information
provided
by
BUD
in
October
1985
(
3)
indicated
that
4.5
grams
of
DDVP
(
0.0099
lb
ai)
would
be
applied
per
8000
ft3
or
1000
ft2
(
3).
If
one
barn
is
treated
per
day,
the
total
amount
applied
per
day
would
be:

Amount
Applied
=
0.0099
lb
ai
x
27,000
ft3
x
1
treatment
(
lb
ai/
day)
8000
ft3
treatment
day
=
0.033
lb
ai
per
day
for
space
spray
uses
i)
A
1.0
percent
solution
of
DDVP
is
applied
using
a
low
pressure
hand
sprayer
at
a
rate
of
1
pint
per
1000
ft2
for
coarse
spray
applications
to
barns
and
other
facilities.

k)
HED
has
no
data
addressing
the
sizes
of
other
types
of
animal
facilities
and
assumes
that
none
of
these
would
result
in
exposures
exceeding
those
from
dairy
barn
treatment.

3.2Calculation
of
Exposures
for
Direct
Application
to
Animals
and
to
Animal
Facilities
The
assessment
conducted
in
1993
included
a
number
of
coarse
spray
scenarios
using
different
types
of
equipment
using
studies
from
the
scientific
literature
and
registrant
generated
surrogate
data.
Some
of
the
studies
that
were
used
in
the
1993
assessment
have
been
included
in
the
Pesticide
Handlers
Exposure
Database
(
PHED).
Revised
estimates
using
PHED
have
replaced
these
studies
whenever
possible.
It
is
not
certain
exactly
what
type
of
coarse
spray
equipment
would
be
used
in
any
particular
facility.
The
equipment
used
could
vary
from
a
hose
end
sprayer
to
backpack
to
a
pinpoint
compressed
air
apparatus
depending
on
applicator
needs.

HED
has
reassessed
these
exposure
estimates
using
the
Pesticide
Handlers
Exposure
Database
(
PHED
V1.1).
Both
the
applicator
file
(
APPL.
FILE)
and
mixer/
loader/
applicator
file
were
examined.
There
are
minimal
data
regarding
this
application
scenario.
Four
studies
(
or
subsets)
were
selected
manually
from
the
master
files
in
order
to
closely
match
the
specific
parameters
for
DDVP
applications
to
these
types
of
facilities.
Both
low
pressure
hand
wand
and
high
pressure
hand
wand
data
are
considered
to
be
low
confidence
data
(
7).
The
application
methods,
clothing
scenarios,
estimated
unit
exposures
(
not
adjusted
for
dermal
absorption)
of
workers
using
spray
equipment
for
direct
treatment
of
animals
are
presented
in
Table
2.
Data
subsets
are
also
included.
The
summary
statistics
for
each
PHED
analysis
are
presented
in
Appendix
A.
D251330
­
Page
6
of
8
The
daily
exposures
and
resulting
MOEs
estimated
for
these
workers
to
DDVP,
adjusted
for
use
information
and
dermal
absorption
are
presented
in
Table
3.
It
must
be
noted
that
the
respiratory
measurements
for
three
of
these
studies
are
based
entirely
on
non­
detect
samples
and
therefore
have
an
artifactual
component,
possibly
an
appreciable
one.

Table
2.
Estimates
of
Unit
Exposures
of
Workers
Applying
Pesticides
Using
Various
Types
of
Equipment
That
Might
Be
Used
for
Coarse
Spray
Application
to
Animals
or
Use
in
an
Animal
Facility.
These
values
are
NOT
corrected
for
dermal
absorption.
Numbers
in
parentheses
are
in
mg/
kg,
adjusted
for
a
70
kg
worker.

Equipment
Used
Clothing
Scenario
Unit
Exposure
­
mg/
lb
ai
(
mg/
kg/
lb
ai)
No.
Of
Reps
Reference
Dermal
Respiratory
Hand
Held
Sprayer
Long
Pants,
Long
Sleeves,
Gloves
0.17
(
0.0024)
0.0261
(
0.0004)
9
PHED
471LPHW.
MLAP
Backpack
Sprayer
Long
Pants,
Long
Sleeves,
Gloves
2.6
(
0.037)
0.0261
(
0.0004)
9
PHED
471PKPK.
MLAP
Backpack
Sprayer
Long
Pants,
Long
Sleeves,
Gloves
0.27
(
0.0039)
0.062
(
0.0009)
4
PHED
416.
APPL.
APPL
Portable
Sprayer
on
Wheels
Long
Pants,
Long
Sleeves,
Gloves
0.69
(
0.0099)
0.0781
(
0.0011)
9
PHED
471.
APPL
1
All
values
were
non­
detect
samples
D251330
­
Page
7
of
8
Table
3.
Estimated
Dermal
Exposures
and
Respiratory
Exposures
for
Workers
Applying
DDVP
Directly
to
Animals
(
Non­
poultry)
and
Animal
Premises.
Workers
are
assumed
to
wear
long
sleeve
shirts,
long
pants,
and
gloves.

Equipment
Unit
Exposure
(
mg/
kg/
lb
ai)
Amount
Handled
(
lb
ai/
day)
Exposure
(
mg/
kg/
day)

Dermal
Resp.
Dermal
Resp.

Direct
Animal
Treatment
(
Intermediate
Term
Exposure):

Hand
Held
0.0024
0.0004
0.092
0.000024
0.000037
Backpack
0.037
0.0004
0.092
0.00037
0.000037
Backpack
0.0039
0.0009
0.092
0.000039
0.000083
Portable
Sprayer
on
Wheels
0.0099
0.0011
0.092
0.000100
0.000101
Space
Spray
(
Short
Term
Exposure):

Hand
Held
0.0024
0.0004
0.033
0.000009
0.000013
Backpack
0.037
0.0004
0.033
0.00013
0.000013
Backpack
0.0039
0.0009
0.033
0.000014
0.000030
Portable
Sprayer
on
Wheels
0.0099
0.0011
0.033
0.000036
0.000036
Short
Term
Dermal
NOAEL
=
0.5
mg/
kg/
day;
Target
MOE
=
10
Intermediate
Dermal
NOAEL
=
0.1
mg/
kg/
day;
Target
MOE
=
10
Inhalation
NOAEL
=
0.05
mg/
kg/
day;
Target
MOE
=
100
D251330
­
Page
8
of
8
REFERENCES
1)
Memorandum
from
D.
Jaquith
(
EAB)
to
C.
Monroe
(
SIS)
titled
"
Exposure
Assessment
for
DDVP",
dated
August
4,
1987.

2)
EPA
(
1987)
Guidance
for
the
Registration
of
Pesticide
Products
Containing
DDVP
as
the
Active
Ingredient.

3)
Memorandum
from
D.
Jaquith
(
OREB)
to
D.
Utterback
(
SRRD),
titled
"
Revisions
to
Exposure
Assessment
for
DDVP",
dated
April
15,
1993.

4)
Federal
Register
Notice,
September
28,
1995,
Dichlorvos;
Notice
of
Preliminary
Determination
to
Cancel
Certain
Registrations
and
Draft
Notice
of
Intent
to
Cancel;
Page
50352.

5)
Facsimile
Message
from
Ann
Manley,
Director
of
Toxicology,
AMVAC
Chemical
Corporation
to
D.
Utterback
(
SRB)
dated
August
19,
1998.

6)
Memorandum
from
M.
Dow
(
BUD)
to
D.
Pilitt
(
RD)
titled
"
DDVP
(
Vapona)
QUA",
dated
October
2,
1985.

7)
PHED
Surrogate
Exposure
Guide,
May
1997.

cc:
DDVP
File
Correspondence
file
D.
Utterback
(
SRB/
7508W)
S.
Hummel
(
CEB2/
7509C
DDVP
Dairy/
Animal
Exposure
Assessment
­
Appendices
Appendix
A.
Summary
Statistics
for
Studies
Selected
from
PHED
to
Address
the
Exposures
of
Workers
to
DDVP
Applied
Directly
to
Animals
or
to
Animal
Facilities.

471
­
Low
Pressure
Hand
Wand
SUMMARY
STATISTICS
FOR
CALCULATED
DERMAL
EXPOSURES
SCENARIO:
Long
pants,
long
sleeves,
gloves
PATCH
DISTRIB.
MICROGRAMS
PER
LB
AI
SPRAYED
LOCATION
TYPE
Median
Mean
Coef
of
Var
Geo.
Mean
Obs.

HEAD
(
ALL)
Lognormal
13.52
95.9689
161.5896
37.513
9
NECK.
FRONT
Lognormal
4.065
7.3967
116.9075
4.327
9
NECK.
BACK
Normal
1.144
2.7243
101.6775
1.9155
9
UPPER
ARMS
Normal
15.132
29.9407
99.9395
22.7111
9
CHEST
Other
18.46
146.26
242.8398
34.8928
9
BACK
Other
18.46
66.9372
201.2858
29.0838
9
FOREARMS
Other
6.292
6.292
0
6.292
9
THIGHS
Other
19.864
37.9878
115.1859
27.6737
9
LOWER
LEGS
Lognormal
12.376
66.9309
164.3135
30.0241
9
FEET
0
HANDS
Other
2.0833
2.0833
0
2.0834
9
TOTAL
DERM:
169.6884
111.3963
462.5218
196.5164
INHALATION:
Other
26.0417
26.0417
0
26.0429
9
COMBINED:
195.7301
137.438
488.5635
222.5593
95%
C.
I.
on
Mean:
Dermal:
[­
8383.8174,
9308.861]

95%
C.
I.
on
Geo.
Mean:
Inhalation:
[
26.0429,
26.0429]

Inhalation
Rate
:
25
Liters/
Minute
Number
of
Records:
9
Data
File:
MIXER/
LOADER/
APPLICATOR
Subset
Name:
471LPHW.
MLAP
Subset
Specifications
for
471LPHW.
MLAP
With
Application
Method
Equal
to
7
Subset
originated
from
471.
MLAP
With
Study
Code
Equal
to
471
Subset
originated
from
MLAP.
FILE
DDVP
Dairy/
Animal
Exposure
Assessment
­
Appendices
471
­
High
Pressure
SUMMARY
STATISTICS
FOR
CALCULATED
DERMAL
EXPOSURES
SCENARIO:
Long
pants,
long
sleeves,
gloves
PATCH
DISTRIB.
MICROGRAMS
PER
LB
AI
SPRAYED
LOCATION
TYPE
Median
Mean
Coef
of
Var
Geo.
Mean
Obs.

HEAD
(
ALL)
Lognormal
105.69
140.8333
77.4664
105.262
9
NECK.
FRONT
Lognormal
12.195
22.0817
96.0397
13.4678
9
NECK.
BACK
Lognormal
8.943
31.548
152.5041
12.9288
9
UPPER
ARMS
Other
45.396
47.918
15.7895
47.4874
9
CHEST
Other
55.38
55.38
0
55.3791
9
BACK
Other
55.38
55.38
0
55.3791
9
FOREARMS
Lognormal
18.876
255.0142
248.3883
47.5413
9
THIGHS
Lognormal
59.592
4954.0307
291.5219
186.603
9
LOWER
LEGS
Lognormal
37.128
3474.1124
283.7355
159.2327
9
FEET
0
HANDS
Other
6.25
110.8403
266.2583
13.8807
9
TOTAL
DERM:
687.4416
404.83
9147.1386
697.1619
INHALATION:
Other
78.125
78.125
0
78.1277
9
COMBINED:
765.5666
482.955
9225.2636
775.2896
95%
C.
I.
on
Mean:
Dermal:
[­
352402.5151,
370696.7923]

95%
C.
I.
on
Geo.
Mean:
Inhalation:
[
78.1277,
78.1277]

Inhalation
Rate
:
25
Liters/
Minute
Number
of
Records:
9
Data
File:
APPLICATOR
Subset
Name:
471.
APPL
Subset
Specifications
for
471.
APPL
With
Study
Code
Equal
to
471
Subset
originated
from
APPL.
FILE
DDVP
Dairy/
Animal
Exposure
Assessment
­
Appendices
SUMMARY
STATISTICS
FOR
CALCULATED
DERMAL
EXPOSURES
SCENARIO:
Long
pants,
long
sleeves,
gloves
PATCH
DISTRIB.
MICROGRAMS
PER
LB
AI
SPRAYED
LOCATION
TYPE
Median
Mean
Coef
of
Var
Geo.
Mean
Obs.

HEAD
(
ALL)
Lognormal
70.46
383.0956
194.8378
79.1674
9
NECK.
FRONT
Lognormal
15.93
119.965
155.5213
26.7717
9
NECK.
BACK
Lognormal
663.894
1349.5607
97.8202
849.1595
9
UPPER
ARMS
Lognormal
27.354
12277.5487
216.2146
234.3196
9
CHEST
Other
18.46
230.4739
223.1428
42.3181
9
BACK
Lognormal
3272.745
10793.8144
149.0355
1242.0996
9
FOREARMS
Other
6.292
151.5323
208.7399
20.6347
9
THIGHS
Lognormal
19.864
597.2782
282.8189
49.147
9
LOWER
LEGS
Lognormal
32.13
425.8878
230.6324
64.6874
9
FEET
0
HANDS
Lognormal
2.0833
4.9821
130.0415
3.3199
9
TOTAL
DERM:
2573.4241
4129.2123
26334.1387
2611.6249
INHALATION:
Other
26.0417
26.0417
0
26.0429
9
COMBINED:
2599.4658
4155.254
26360.1804
2637.6678
95%
C.
I.
on
Mean:
Dermal:
[­
617117.5802,
669785.8576]

95%
C.
I.
on
Geo.
Mean:
Inhalation:
[
26.0429,
26.0429]

Inhalation
Rate
:
25
Liters/
Minute
Number
of
Records:
9
Data
File:
MIXER/
LOADER/
APPLICATOR
Subset
Name:
471BKPK.
MLAP
Subset
Specifications
for
471BKPK.
MLAP
With
Application
Method
Equal
to
9
Subset
originated
from
471.
MLAP
With
Study
Code
Equal
to
471
Subset
originated
from
MLAP.
FILE
DDVP
Dairy/
Animal
Exposure
Assessment
­
Appendices
416
Greenhouse
backpack
SUMMARY
STATISTICS
FOR
CALCULATED
DERMAL
EXPOSURES
SCENARIO:
Long
pants,
long
sleeves,
gloves
PATCH
DISTRIB.
MICROGRAMS
PER
LB
AI
SPRAYED
LOCATION
TYPE
Median
Mean
Coef
of
Var
Geo.
Mean
Obs.

HEAD
(
ALL)
Lognormal
16.25
27.0725
95.3133
20.1332
4
NECK.
FRONT
Lognormal
4.995
5.31
48.4614
4.8351
4
NECK.
BACK
Lognormal
4.5815
14.4348
154.0181
5.4415
4
UPPER
ARMS
Lognormal
42.9225
42.9225
50.4938
38.6002
4
CHEST
Other
29.465
29.465
0
29.465
4
BACK
Lognormal
44.375
44.375
38.798
41.7961
4
FOREARMS
Lognormal
52.151
107.5992
134.3206
41.6344
4
THIGHS
Lognormal
53.289
58.828
55.412
51.985
4
LOWER
LEGS
Lognormal
19.754
22.253
22.4599
21.8835
4
FEET
0
HANDS
Lognormal
10.5833
25.5625
123.344
15.957
4
TOTAL
DERM:
271.731
278.3663
377.8225
271.731
INHALATION:
Lognormal
31.25
31.8742
62.4728
26.7416
4
COMBINED:
298.4726
309.6163
409.6967
298.4726
95%
C.
I.
on
Mean:
Dermal:
[­
4512.6214,
5268.2664]

95%
C.
I.
on
Geo.
Mean:
Inhalation:
[
6.6448,
107.6198]

Inhalation
Rate
:
25
Liters/
Minute
Number
of
Records:
4
Data
File:
APPLICATOR
Subset
Name:
416.
APPL.
APPL
Subset
Specifications
for
416.
APPL.
APPL
With
Study
Code
Equal
to
416
Subset
originated
from
APPL.
FILE
DDVP
Dairy/
Animal
Exposure
Assessment
­
Appendices
Appendix
B.
Text
from
Email
Message
from
R.
Kent
(
CEB1)
to
D.
Jaquith
(
CEB1)
and
C.
Scheltema
(
RCAB)
dated
11/
20/
98.

A
number
of
BC's
met
on
11/
19/
98
to
consider
the
application
of
the
chronic
rat
inhalation
bioassay
to
short
and
intermediate
term
exposure
scenarios.
Their
decision
was
not
to
use
the
inhalation
study
except
for
long
term
inhalation
scenarios
such
as
resin
strips.
For
short
and
intermediate
term
scenarios,
doses
from
inhalation
exposure
should
be
combined
with
doses
from
dermal
exposure
and
compared
to
either
the
acute
human
NOAEL
of
0.5
mg/
kg/
day
(
short
term
scenarios),
or
to
the
repeated
dose
human
LOAEL
of
0.1
mg/
kg/
day
(
intermediate
term
scenarios).

BC's
participating
in
the
consensus
decision
were:
Pauline
Wagner,
Jess
Rowland,
Bill
Burnam,
Clark
Swentzel,
Mike
Ioannou
and
myself.
Also
in
attendance
were
PV
Shah
and
Kit
Farwell.
