December
31,
1998
MEMORANDUM
SUBJECT:
RESPONSE
TO
EXPOSAC
COMMENTS
ON
EXPOSURE
ASSESSMENT
FOR
TOTAL
RELEASE
FOGGERS
CONTAINING
DICHLORVOS
(
DDVP)
(
Barcode
D251333,
PC
Code
084001).

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

TO:
Christina
Scheltema
Risk
Characterization
and
Analysis
Branch
Health
Effects
Division
(
7509C)

THRU:
Sue
Hummel,
Senior
Scientist
Chemical
Exposure
Branch
II
Health
Effects
Division
(
7509C)

1.0
INTRODUCTION
In
May
1993
HED
reviewed
a
study
monitoring
the
exposures
of
individuals
performing
a
prescribed
exercise
routine
(
JAZZERCISE
®
)
following
treatment
of
rooms
with
a
total
release
fogger
containing
DDVP
as
the
active
ingredient
(
1).
The
multi­
phase
study
was
conducted
in
hotel
rooms
in
British
Columbia.
One
phase
measured
the
amounts
of
material
that
were
transferred
to
various
portions
of
whole
body
dosimeters.
Another
phase
used
biomonitoring
to
determine
the
amount
of
DDVP
that
would
be
absorbed
into
the
body
following
these
exercise
activities
The
estimated
exposure
of
individuals
to
DDVP
following
these
activities
was
14
:
g
per
kg,
based
on
this
biomonitoring.
In
lieu
of
age
specific
data
it
was
assumed
that
the
exposures
of
children
on
a
mg
per
kg
basis
were
the
same
as
those
of
an
adult
performing
the
same
activities.
This
was
considered
to
be
a
short
term
exposure
scenario
with
a
NOAEL
of
0.5
mg/
kg/
day
(
500
:
g/
kg/
day)
(
2).
D251333
Page
2
2.0
CONCLUSIONS
The
exposure
estimate
for
reentry
into
a
room
following
actuation
of
a
total
release
fogger
has
been
revised
incorporating
comments
from
the
Health
Effects
Division
Exposure
Science
Advisory
Council
(
EXPOSAC).
The
revised
estimate
pools
the
biomonitoring
value
from
the
previous
assessment
for
this
scenario
(
1)
of
14
:
g/
kg
with
an
estimate
of
potential
oral
exposure
from
the
hands.
This
value
was
obtained
from
a
passive
dosimetry
phase
of
the
study
reviewed
in
reference
1
and
was
equal
to
0.61
:
g/
kg.
It
was
assumed
that
all
of
the
residues
found
on
the
hands
were
available
for
subsequent
oral
exposure.
The
resulting
estimate
of
exposure
changed
from
14
:
g/
kg
to
15
:
g/
kg
when
the
potential
oral
component
was
included.

3.0
COMMENTS/
RECOMMENDATIONS
FROM
THE
EXPOSAC
The
EXPOSAC
had
several
comments
regarding
the
assessment
for
post­
application
exposure
to
DDVP
from
the
use
of
a
total
release
fogger
(
3).

Rationale
for
the
assumption
that
a
child
would
have
the
same
exposure
on
a
mg/
kg
basis
while
performing
JAZZERCISE
®
.

There
has
been
some
criticism
of
the
assumption
that
on
a
mg/
kg
basis
the
exposure
of
adults
and
children
performing
the
same
activities.
There
are
differences
in
the
relative
percentage
of
surface
area
that
change
with
age.
The
head
is
relatively
larger
in
infants
and
children
than
adults.
The
trunk
remains
fairly
stable
whereas
the
arms
and
legs
contribute
a
higher
percentage
of
the
total
surface
area
as
the
child
reaches
adulthood.
However
these
differences,
considered
along
with
their
uncertainties
and
the
pattern
of
exposure
presented
in
Figure
1
indicate
that
the
assessment
would
not
be
substantively
changed
by
attempting
to
correct
for
surface
area
differences.
Since
the
areas
most
exposed
during
the
Jazzercise
routine
were
the
legs
(
51.1%)
and
trunk
and
arms
(
30.5%)
it
was
judged
that
a
child
performing
the
same
activities
would
receive
about
the
same
dosage
as
an
adult
on
a
mg
per
kg
basis
The
EXPOSAC
agreed
that
the
Jazzercise
®
routine
is
an
acceptable
method
for
estimating
dermal
exposure
to
carpet
following
treatment
by
a
total
release
fogger.
They
further
recommended
that
the
reasons
why
this
is
considered
to
be
conservative
be
included
In
order
to
create
a
consistent
exposure
assessment
between
chemicals
it
is
necessary
to
establish
a
uniform
activity
pattern
to
reflect
a
given
scenario.
Such
standardization
has
been
used
for
several
years
for
agricultural
reentry
exposure
assessments.
The
establishment
of
Jazzercise
®
as
an
activity
pattern
was
developed
by
the
California
Environmental
Protection
Agency
and
has
been
used
for
a
number
of
assessments
as
well
as
that
conducted
by
the
registrant.
In
lieu
of
more
definitive
activity
pattern
information,
Jazzercise
®
remains
a
reasonable,
fairly
intense
activity
pattern
that
can
be
used
for
estimation
of
residential
exposures.
D251333
Page
3
The
EXPOSAC
reaffirmed
the
policy
that
biomonitoring
data
are
more
desirable
than
passive
dosimetry
data,
all
else
being
equal,
and
therefore
agreed
with
the
use
of
biomonitoring
data
for
this
assessment.

The
previous
assessment
did
not
quantify
the
potential
exposure
of
children
from
hand
to
mouth
activity
due
to
lack
of
data.
FQPA
requires
consideration
of
all
significant
routes
of
exposure.
The
EXPOSAC
recommended
to
use
the
glove
dosimeter
data
and
the
dermal
absorption
factor
to
estimate
exposure
to
children
from
hand­
to­
mouth
activity,
but
not
to
aggregate
this
exposure
with
others
at
this
time.

It
was
recommended
that
the
values
for
total
transfer
to
the
hands
be
considered
to
be
available
for
ingestion
and
that
this
value
be
added
to
the
dose
estimated
by
biomonitoring.
The
passive
dosimetry
phase
of
the
monitoring
study
measured
the
potential
exposures
to
various
parts
of
the
body
during
Jazzercise
®
conducted
3
hours
after
actuation
of
the
fogger.
The
data
are
represented
graphically
in
Figure
1.
The
mean
total
potential
exposure
to
individuals
performing
the
exercise
routine
was
776
:
g.
Of
this,
5.5
percent
was
due
to
exposure
of
the
hands,
or
43
:
g
(
0.61
:
g/
kg).
The
total
exposure
then
becomes:

Total
Exposure
(:
g/
kg/
day)
=
Biomonitoring
Exposure
(:
g/
kg/
day)
+
Hand
Exposure
(:
g/
kg)

=
14
:
g/
kg/
day
+
0.61
:
g/
kg
=
15
:
g/
kg
The
resulting
Margin
of
Exposure
(
MOE)
would
be:

MOE
=
(
500
:
g/
kg/
day)/
15
:
g/
kg/
day
=
33
D251333
Page
4
Exposure
of
Body
Areas
to
DDVP
During
Activity
Performed
3
Hours
After
Use
of
a
Total
Release
Fogger
NOTE:
Mean
Total
Dermal
Exposure
as
measured
by
Whole
Body
Dosimeters
was
776
µ
g.
Underpants
Tights
Gloves
Shirt
Socks
1.5%

51.1%

5.5%
30.5%
11.4%
D251333
Page
5
REFERENCES
1)
Memorandum
from
D.
Jaquith
(
OREB)
to
D.
Utterback
(
SRB)
titled
"
Assessment
of
Exposures
of
Residents
to
DDVP
Applied
as
a
Total
Release
Fogger",
dated
May
10,
1993.

2)
Federal
Register
Notice,
September
28,
1995,
Dichlorvos;
Notice
of
Preliminary
Determination
to
Cancel
Certain
Registrations
and
Draft
Notice
of
Intent
to
Cancel;
Notice.
Page
50352.

3)
Memorandum
from
J.
Arthur
(
EXPOSAC
Chair)
to
D.
Jaquith
(
CEB2)
titled
"
Review
of
DDVP
Exposure
Assessment
for
Scenarios:
Total
Release
Fogger;
Turf;
Aerosol
Crack/
Crevice
Treatment,
and
Pet
Collars",
dated
August
31,
1998.

4)
EPA
1997
Exposure
Factors
Handbook
Volume
1
­
General
Factors.
EPA/
600/
P­
95/
002Fa.

cc:
DDVP
File
(
084001)
Correspondence
file
