1
CREOSOTE:
REVIEW
OF
WORKER
EXPOSURE
STUDY
1.0
INTRODUCTION
The
purpose
of
this
report
is
to
review
the
worker
exposure
study
submitted
to
the
U.
S.
Environmental
Protection
Agency
in
support
of
the
re­
registration
requirements
of
the
wood
preservative,
creosote.
The
creosote
worker
exposure
study
was
submitted
to
fulfill
agency
guideline
requirements
under
Series
875.1100
Dermal
Exposure­
Outdoor
1;
Series
875.1300
Inhalation
Exposure­
Outdoor
2;
and
Series
875­
Occupational
and
Residential
Exposure
Test
Guidelines,
Group
B
Post
application
Exposure
Monitoring
Test
Guidelines
3.
The
major
points
in
"
Checklist
for
Applicator
Monitoring
Data"
were
used
to
evaluate
compliance
with
Series
875.

The
following
information
can
be
used
to
identify
the
protocol:

Title
Formulation,
Active
Ingredient
Identifying
Codes
Corporate
Sponsor
Performing
Laboratory
Assessment
of
Potential
Creosote
Inhalation
and
Dermal
Exposure
Associated
with
Pressure­
Treatment
of
Wood
with
Creosote
(
1)
Koppers
Coal
Tar
Creosote
with
98.5%
active
ingredient
(
a.
i.)
creosote
(
AWPA
P1/
P13)

(
2)
VFT
Coal
Tar
Creosote
Wood
Preservative
with
100
%
a.
i.
creosote
(
P1/
P13)

(
3)
Koppers
Creosote
Solution
with
95%
a.
i.
creosote
(
AWPA
P2)
MRID
No.
453234­
01;
AASI
Study
No.
AA990308;
EN­
CAS
Analytical
Laboratories
Project
No.
98­
0079
Creosote
Council
II
John
H.
Butala,
DABT
7
Glasgow
Road
Gibsonia,
PA
15044
Phone:
(
724)
443­
0097
FAX:
(
724)
443­
0926
Field
Mark
G.
Bookbinder
(
Field
Investigator)
c/
o
American
Agricultural
Services,
Inc.
404
E.
Chatham
Street
Cary,
NC
27511
Phone/
FAX:
(
301)
540­
5622
Analytical
Bert
Clayton,
B.
S.
Stephanie
Guilyard
(
Dermal
Exposure
Support)
(
Inhalation
Exposure
Support)
EN­
CAS
Laboratories
USX
Engineers
and
("
ENCAS")
Consultants,
Inc.
(
UEC)
2359
Farrington
Point
Drive
4000
Tech
Ctr.
Dr.

Winston­
Salem,
NC
27107
Monroeville,
PA
15146
Phone:
(
336)
785­
3252
Phone:
(
412)
825­
2808
FAX:
(
336)
785­
3262
FAX:
(
412)
825­
2022
2.0
EXECUTIVE
SUMMARY
This
study
was
designed
to
estimate
the
exposure
to
creosote
of
individuals
performing
job
functions
involved
in
commercial
pressure
treatment
of
lumber,
utility
poles,
and
railroad
ties
at
four
typical
commercial
treatment
facilities
in
the
United
States
and
Canada
(
referred
to
as
Sites
A
through
D).
Three
end
use
products
for
coal
tar
creosote
were
used.
Twenty­
five
workers
and
11
job
functions
(
tasks)
were
monitored
for
up
to
4
or
5
consecutive
work
days
each
(
8
hour
shifts).
Many
of
the
job
functions
may
have
been
performed
by
one
or
more
worker(
s).
Where
a
single
worker
performed
the
duties
of
more
than
one
job
function,
the
title
of
the
job
function
which
represented
the
majority
of
their
work
efforts
was
used
to
identify
the
worker.
2
Dermal
and
inhalation
exposure
levels
were
estimated.
Dermal
exposure
levels
were
estimated
by
passive
dosimetry
using
whole
body
dosimeters
(
WBDs)
and
cloth
dosimeter
gloves.
The
WBDs
and
cloth
dosimeter
gloves
were
worn
under
the
workers'
protective
clothing
and
chemical
resistant
gloves.
Inhalation
exposure
levels
were
estimated
by
active
dosimetry
using
a
sampling
train
(
placed
in
the
worker's
breathing
zone)
that
consisted
of
a
PTFE
air
filter
upstream
from
two
in­
line
XAD­
2
resin
filled
air
sampling
tubes.
The
air
was
pulled
through
the
sampling
train
by
a
portable
air
sampling
pump.

Creosote
cannot
be
measured
directly
because
it
is
a
mixture
of
many
component
compounds.
Dermal
exposure
to
"
total
creosote"
was
estimated
by
measuring
the
levels
of
ten
individual
polynuclear
aromatic
hydrocarbon
(
PNA)
compounds.
Each
analyte
was
determined
in
each
WBD
and
glove
sample
as
if
it
represented
total
creosote.
Inhalation
exposure
was
estimated
for
11
individual
PNA
compounds
as
well
as
for
benzene­
soluble
PNAs
and
related
compounds
collectively
known
as
coal
tar
pitch
volatiles
(
CTPVs).
The
PTFE
filter
retained
the
CTPVs,
while
the
PNAs
were
retained
in
the
XAD­
2
resin
tubes.

Known
quantities
of
a
characterized
creosote
formulation
could
not
be
measured
because
the
study
was
set
up
in
a
continuously
operating
commercial
setting.
The
creosote
was
applied
in
closed
systems
where
excess
treatment
solution
from
the
wood
and
treatment
vessels
were
recovered
and
retained
while
sealed.
Therefore,
the
amount
of
product
or
active
ingredient
handled
by
each
worker
is
not
known.
According
to
the
Study
Report,
the
major
source
of
creosote
for
worker
exposure
in
this
type
of
facility
is
due
to
preservative
remaining
on
or
escaping
from
treated
wood
or
equipment
that
had
been
in
a
cylinder
during
treatment.
This
is
presumably
a
very
small
fraction
of
the
quantity
actually
applied
to
and
retained
by
the
charge.
The
treated
wood
retained
between
approximately
5794
pounds
(
Site
B)
and
53290
pounds
(
Site
C)
of
creosote
per
charge,
depending
on
treatment
parameters.
This
study
monitored
12
(
Site
A)
to
23
(
Site
D)
charges.

The
unadjusted
creosote
level
for
each
WBD
segment
and
glove
pair
from
each
worker
was
corrected
for
the
mean
field
fortification
recovery
of
the
appropriate
analytical
standard(
s)
from
samples
fortified
in
the
field
at
that
test
site.
The
analytical
method
was
subject
to
some
variability
at
levels
near
the
LOQ,
suggesting
that
recoveries
obtained
at
that
level
were
likely
to
be
less
reliable
than
those
at
the
higher
level.
Therefore,
the
field
fortification
recoveries
at
1,000
times
the
LOQ
were
used
to
make
the
corrections.
The
registrant
did
not
make
corrections
to
the
raw
data
when
field
fortification
recoveries
were
>
100%.
U.
S.
EPA
guidelines
state
that
corrections
are
not
needed
when
field
fortification
recoveries
are
above
90%.

Each
calculated
exposure
level
was
normalized
to

g/
kg
body
weight/
day,
normalizing
results
to
the
EPA
recommended
mean
adult
weight
of
71.8
kg
and
to
a
standard
work
day
length
of
8
hours.
The
"
total"
dermal
exposure
for
each
replicate
for
each
worker
was
calculated
by
summing
the
normalized
residue
levels
in
the
WBD
arms,
WBD
top,
WBD
bottom
(
torso
portion
and
legs,
cut
apart
at
EN­
CAS
and
analyzed
as
separate
samples),
and
all
glove
dosimeters
worn
during
that
replicate.
Geometric
mean
dermal
creosote
exposures
across
all
of
the
job
functions
at
all
four
sites
ranged
from
25
(
Load­
Out
Area
Helper)
to
901
(
Oil
Unloader)

g/
kg
bw/
day.
3
The
highest
individual
levels
were
found
for
the
Site
C
Treatment
Operator.
This
operator
also
performed
the
duties
of
the
Oil
Unloader
while
not
wearing
chemical­
resistant
gloves
on
at
least
one
monitored
occasion.
Within
each
job
class
monitored,
and
over
all
classes
at
each
site,
those
individuals
whose
activities
involved
the
greatest
proximity
to
creosote
sources
were
exposed
to
the
highest
levels
of
creosote.

No
useful
inhalation
data
were
generated
at
Site
A
due
to
problems
with
the
air
sampling
methodology.
The
methodology
was
changed
prior
to
sampling
at
Sites
B,
C,
and
D
(
added
second
XAD­
2
resin
tube
to
sampling
train).
The
unadjusted
inhalation
residue
level
for
each
air
sampler
from
each
worker
was
corrected
for
the
mean
field
fortification
recovery
of
the
appropriate
analytical
standard(
s)
from
samples
fortified
in
the
field
at
that
test
site.
Calculated
inhalation
exposure
levels
were
normalized
by
scaling
up
the
pump
flow
rate
of
1
L/
min
to
the
EPA
recommended
minute
ventilation
rate
of
1100
L/
hr
(
approximately
18.34
L/
min)
for
"
light
activities",
and
then
adjusting
for
the
standard
EPA­
recommended
adult
weight
of
71.8
kg.

Chrysene
and
benzo(
a)
pyrene
were
not
detected
in
worker
samplers.
Pyrene
and
anthracene
were
detected
in
1
and
2
sampler(
s),
respectively.
However,
naphthalene
was
detected
in
every
sampler,
and
2­
methylnaphthalene
was
detected
in
most
samplers,
suggesting
that
only
the
lower
molecular
weight
("
low­
boiling")
PNAs
are
commonly
volatilized
during
pressure
treatment,
or
are
able
to
remain
volatile
when
exposed
to
ambient
temperatures.
Naphthalene
represented
the
single
greatest
contribution
to
inhalation
exposure.
CTPVs
were
present
at
quantifiable
levels
in
only
one
sampler,
suggesting
that
this
class
of
compounds
may
be
a
minor
constituent
of
creosote
emissions.
Measured
aerial
concentrations
of
naphthalene
(
approximately
0.04
to
1.29
mg/
m3)
and
CTPVs
(
0.0003
to
0.0006
mg/
m3)
were
well
below
the
ACHIH
TLVs
of
52
mg/
m3
and
0.2
mg/
m3,
respectively,
for
these
materials
for
all
monitored
workers.
The
geometric
mean
daily
inhalation
exposure
was
greatest
in
worker
classes
performing
tasks
in
close
proximity
to
sources
of
creosote.

The
concerns
related
to
requirements
under
the
Series
875
guidelines
are
as
follows:

(
1)
CTPV
inhalation
field
fortification
recoveries
and
some
dermal
field
fortification
recoveries
were
unacceptable;

(
2)
Unable
to
quantitate
the
total
amount
of
active
ingredient
handled
by
each
worker
monitored
in
the
study;
(
3)
There
were
not
enough
field
fortification
samples
and
field
blanks
collected;
and
(
4)
The
amount
of
product
applied
was
not
measured.

The
study
did
address
most
of
the
issues
in
Series
875
(
the
method
validation,
field
spikes,
and
QA/
QC
were
more
thorough
then
most
studies),
but
the
poor
recoveries
were
major
issues
that
did
not
meet
Series
875
guidelines.
The
calculation
of
inhalation
exposure
results
was
not
described
well.
The
raw
data
supplied
in
the
study
did
not
directly
match
up
with
the
bar
graphs
presented.
4
3.0
BACKGROUND
3.1
Introduction
Four
commercial
facilities
in
the
U.
S.
and
Canada
were
used
in
this
study
to
determine
the
dermal
and
inhalation
exposure
of
workers
applying
creosote
end
use
products
to
wood
poles
and/
or
railroad
ties
by
pressure
treatment
systems.
Three
of
the
facilities
(
referred
to
herein
as
Sites
A,
C,
and
D)
were
located
in
the
U.
S.
(
Florence,
South
Carolina;
Denver,
Colorado;
and
Somerville,
Texas).
The
fourth
facility
(
referred
to
herein
as
Site
B)
was
located
in
Delson,
Quebec,
Canada.
The
four
facilities
and
the
end
use
products
used
in
this
study
were
said
to
represent
a
range
of
geographic
locations,
formulations
used,
species
of
wood
products
treated,
and
application
parameters
used
for
treatment
of
wood
with
creosote.

At
each
site,
pressure
treatment
of
wood
products
was
performed
using
the
same
basic
process.
Workers
operating
self­
propelled
or
stationary
loaders
moved
untreated
poles
or
ties
from
holding
areas
and
stacked
them
onto
wheeled
metal
trams
on
a
railroad
track
leading
into
the
treatment
cylinder(
s).
When
enough
trams
were
loaded
to
fill
a
cylinder,
the
poles
or
ties
on
each
tram
were
tied
together
with
chains
of
metal
or
plastic
bands.
A
charge
cable
(
or
"
lead
cable")
was
connected
to
the
tram
farthest
from
the
cylinder
door,
and
laid
along
the
top
of
the
stacked
items
on
the
trams.
The
filled
trams
were
considered
a
"
charge"
of
wood
products.

The
cylinder
door
was
opened
and
its
drawbridge
was
positioned
so
that
it
connected
the
drip
pad
track
with
the
cylinder's
interior
rails.
The
charge
was
then
pushed
into
the
cylinder
by
a
self­
propelled
loader.
Workers
placed
the
free
end
of
the
lead
cable
into
the
cylinder,
closed
the
cylinder
door(
s),
and
started
the
treatment
process.
Treating
solution
(
P1
or
P2,
as
unloaded
from
tank
cars
in
which
it
was
delivered
to
the
plant)
was
heated
to
190
­
210
oF
and
pumped
from
storage
tanks
into
the
cylinder,
after
which
pressure
(
150
­
190
psi)
was
applied
to
the
cylinder
to
allow
the
preservative
to
permeate
the
wood
of
the
poles.

After
treatment,
excess
treating
solution
was
removed
from
the
cylinders
and
wood
products
by
maintaining
a
vacuum
in
the
cylinder
for
approximately
1
to
7
hours.
The
duration
of
a
treatment
cycle
ranged
from
approximately
7
to
80
hours,
depending
on
the
species
of
wood
treated
and
the
procedures
used
by
each
site.
At
the
end
of
treatment,
the
cylinder
was
opened,
and
excess
water
and
creosote
vapors
and
condensates
evolved
from
the
cooling
wood
products
(
charges
typically
generated
condensate
plumes
for
up
to
several
hours
after
treatment).

Workers
removed
the
charge
from
the
cylinder
by
removing
the
end
of
the
lead
cable
from
the
cylinder
and
attached
it
to
a
hook
on
a
self­
propelled
loader,
which
then
pulled
the
loaded
trams
out
of
the
cylinder.
At
Sites
A,
B,
and
C,
each
charge
was
pulled
onto
a
concrete
"
drip
pad,"
where
excess
treatment
solution
was
allowed
to
drip
from
the
wood
products
and
trams
onto
the
pad
for
up
to
several
hours.
After
site
personnel
removed
lead
cables
and
chains,
the
cooled
poles
were
pushed
by
loader
to
a
storage
area,
where
workers
using
hand­
or
electricpowered
drills
took
narrow
cores
of
wood
from
selected
poles
or
ties
to
determine
the
depth
of
5
penetration
of
the
preservative,
and
the
amount
of
preservative
that
actually
was
absorbed
by
the
wood.
Charges
that
did
not
contain
enough
creosote
or
did
not
penetrate
deep
enough
were
retreated
as
above.
At
Site
D,
ties
were
pushed
down
the
length
of
the
drip
pad
to
more
distant
areas
of
the
plant
for
stacking.
The
ties
were
immediately
transfered
to
rail
cars
following
their
withdrawal
from
the
cylinder.
Test
boring
was
not
routinely
performed
at
this
site,
per
customer
specifications.

Twenty­
five
workers
were
monitored
for
this
study.
The
11
treatment
plant
job
categories
monitored
in
this
study
include
treatment
operators,
treating
assistants,
loader
operators
(
cylinder
and
load­
out
areas),
cylinder­
area
helpers,
checker,
load­
out
area
helpers,
test
borers,
oil
unloaders,
drip
pad
laborer
and
water
treatment
system
operators.
Workers
performed
typical
tasks
related
to
these
activities
and
were
monitored
for
up
to
4­
5
consecutive
work
days
each.
Descriptions
of
the
tasks
monitored
are
bulleted
below
:

°
Treatment
operators
(
TOs)
­
TOs
operated
and
monitored
application
system
valves
and
controls,
they
sometimes
opened
and
closed
cylinder
doors,
and
they
supervised
the
insertion
and
removal
of
charges
(
loads
of
dried,
debarked
poles
or
untreated
ties)
of
poles
from
the
treatment
cylinders.

°
Treating
assistant
(
TA)
­
TAs
performed
many
of
the
same
functions
as
the
TOs
and
sometimes
assisted
the
TO
in
charge
preparation,
cylinder
cleaning
and
maintenance,
filter
cleaning,
mixing
of
treatment
solution,
and
also
participated
in
some
loader
operations
moving
charges.

°
Loader
operators
(
CLOs
in
the
cylinder
area,
and
LLOs
in
the
load­
out
areas)
­
LOs
stacked
untreated
wood
onto
charge
trams,
moved
charges
into
and
out
of
treatment
cylinders,
distributed
treated
wood
to
load­
out
area,
and
loaded
treated
wood
for
shipment.

°
Cylinder­
area
helpers
(
CHs
in
the
cylinder
area,
and
LHs
in
the
load­
out
areas)
­
CHs/
LHs
aided
the
LOs
by
opening/
closing
cylinder
door,
cleaning
door
debris
and
performing
door
maintenance,
handling
charge
leads
and
cables,
and
banding
stacked
wood.

°
Checker
(
CK)
­
CKs
performed
many
of
the
duties
of
a
CH.

°
Load­
out
area
helpers
(
LHs)
­
LHs
aided
their
LOs
by
banding
treated
wood
and
removing
culls.

°
Test
borers
(
TBs)
­
TBs
took
cores
from
freshly
treated
poles
or
ties
to
be
tested
for
creosote
content
and
penetration
depth.

°
Oil
unloaders
(
OUs)
­
OUs
operated
the
equipment
that
transferred
creosote
from
rail
tank
cars
to
treating
system
tanks.
6
°
Drip
pad
laborer
(
DP)_­
DPs
steam­
cleaned
drip
pads
and
tracks.
They
also
picked
up
and
disposed
of
treated
wood
waste
and
performed
various
labor
clean­
up
duties
in
treatment
areas.

°
Water
treatment
system
operators
(
WOs)
­
WOs
controlled
equipment
that
collected
drip­
pad
effluent
water,
and
removed
creosote
and
other
contaminants.

Creosote
is
a
complex
mixture
of
chemicals
and
therefore
can
not
be
measured
directly.
Dermal
exposure
levels
were
estimated
by
passive
dosimetry
using
whole
body
dosimeters
(
WBD)
which
were
worn
under
the
worker's
clothing
and
lightweight
cotton
glove
dosimeters
which
were
worn
under
work
gloves.
The
dermal
creosote
exposure
levels
were
estimated
by
measuring
the
levels
of
ten
individual
polynuclear
aromatic
hydrocarbon
(
PNA)
compounds.
Each
of
these
analytes
were
determined
in
each
WBD
and
glove
sample
as
if
it
represented
total
creosote.
The
levels
for
each
of
the
individual
analytes
were
then
averaged
together
to
estimate
the
level
of
total
creosote
present
in/
on
the
individual
sample.

Inhalation
exposures
for
each
worker
was
estimated
by
active
dosimetry.
Each
worker
wore
a
sampling
train
consisting
of
a
PTFE
filter
upstream
from
two
in­
line
XAD­
2
resin­
filled
air
sampling
tubes.
The
inhalation
exposure
levels
were
estimated
by
determining
the
presence
of
specific
individual
creosote
components
(
11
individual
PNAs
representing
the
boiling
point
ranges
of
known
creosote
components).
Inhalation
exposure
to
benzene­
soluble
PNAs
and
related
components
collectively
known
as
coal
tar
pitch
volatiles
(
CTPVs)
were
measured
as
well.
The
PTFE
filter
retained
the
CTPVs,
while
the
PNAs
were
retained
in
the
XAD­
2
resin
tubes.
A
more
complete
description
of
the
monitoring
techniques
used
in
this
study
is
described
in
Section
5.

3.2
Physical
and
Chemical
Characteristics
of
Creosote
Coal­
tar
creosote
is
a
blend
of
over
200
compounds,
and
approximately
85%
of
it
is
composed
of
polynuclear
aromatic
hydrocarbons
(
PNAs).
Some
of
the
more
significant
compounds
in
creosote
are:
naphthalene,
acenaphthene,
fluorene,
phenanthrene,
fluoranthene,
and
pyrenes.
4
Vapor
pressures
for
naphthalene,
phenanthrene,
pyrene,
and
chrysene
are
8.7E­
02,
9.6E­
04,
6.8E­
07,
6.3E­
09
mm
Hg
respectively.
5
The
volatiles
are
the
single
ring
compounds
and
the
semi­
volatiles
are
the
two
to
six
ring
compounds.
6
The
vapor
pressure
tends
to
become
larger
as
aromatic
rings
are
added
to
the
compound.
The
more
soluble
compounds
of
creosote
include
phenols,
cresols,
and
N­
heterocyclics.
PNA
compounds
have
various
physical
and
chemical
characteristics.
The
lower
molecular
weight
PNAs
are
more
biodegradable,
volatile,
and
water­
soluble
than
the
heavier
compounds.
PNAs
are
biodegradable,
especially
under
aerobic
conditions
(
in
the
presence
of
oxygen).
The
high
molecular
weight
PNAs
tend
to
have
low
aqueous
solubilities.
Several
of
the
lower
molecular­
weight
PNAs
are
also
biodegradable
under
anaerobic
conditions
(
in
the
lack
of
oxygen).
7
3.3
Chemical
Structure,
Fate,
and
Dissipation
Chemical
Name:
Creosote
CAS:
8001­
58­
9
Structures
for
creosote
are
presented
below.

The
compounds
with
the
higher
molecular
weights
tend
to
be
more
persistent.
Water
solubility,
and
thus
bio­
availability
has
been
found
to
be
inversely
proportional
to
the
size
of
the
molecule.
PAHs
with
two
rings,
generally
have
half
lives
less
than
10
days.
Three
ring
PAHs
generally
exhibit
longer
half
lives
in
most
cases,
but
these
compounds
have
half
lives
of
less
than
100
days.
Four
or
five
ring
PAHs
have
half
lives
from
100
days
or
more.
However,
under
certain
conditions
this
group
has
exhibited
half
lives
under
10
days.
6
8
4.0
PURPOSE
This
study
was
conducted
to
estimate
the
exposure
to
creosote
of
individuals
performing
routine
tasks
involved
in
the
commercial
pressure
treatment
of
lumber,
utility
poles,
and
railroad
ties
at
four
typical
commercial
treatment
facilities
in
the
U.
S.
and
Canada,
per
the
requirements
of
the
U.
S.
Environmental
Protection
Agency,
California
Department
of
Pesticide
Regulation,
and
Health
Canada's
Pesticide
Management
Regulatory
Authority
regulations.
Dermal
and
inhalation
exposure
monitoring
data
were
gathered
for
each
job
function
of
interest.
This
study
review
will
provide
a
summary
of
the
procedures
used
in
the
study,
results
obtained
by
the
study,
a
review
based
on
Series
875
guidelines,
and
a
conclusion
indicating
identified
gaps.

5.0
PROCEDURE
5.1
Mixing/
Loading/
Application
Method
The
procedures
used
for
mixing
and
loading
the
product
were
not
discussed
in
detail
in
the
study.
The
study
reported
that
the
treating
solution
(
P1
or
P2)
was
unloaded
from
tank
cars
in
which
it
was
delivered
to
the
plant
and
was
heated
to
190
­
210
oF
and
pumped
from
storage
tanks
into
the
cylinder,
after
which
pressure
(
150
­
190
psi)
was
applied
to
the
cylinder
to
allow
the
preservative
to
permeate
the
wood
of
the
poles.

Known
quantities
of
the
creosote
formulations
used
at
each
of
the
sites
were
not
measurable
for
this
study
because
the
study
was
set
up
in
continuously
operating
commercial
settings.
The
creosote
was
applied
in
closed
systems
which
recovered
and
retained
excess
treatment
solution
from
the
wood
and
treatment
vessels
while
sealed.
Therefore,
the
amount
of
product
or
active
ingredient
handled
by
each
worker
is
not
known.

5.2.
Exposure
Monitoring
Dermal
The
creosote
dermal
exposure
to
each
worker
was
determined
using
a
whole­
body
dosimeter
(
WBD),
consisting
of
a
100%
cotton
thermal
shirt
and
long
pants.
Each
worker
at
Sites
A,
C,
or
D
wore
his
WBD
under
a
fresh
work
uniform
consisting
of
a
cotton
long­
sleeved
work
shirt
and
cotton
work
trousers
(
or
one­
piece
cotton
coverall)
provided
by
the
test
site.
The
workers
at
Site
B
were
not
provided
uniforms
therefore,
for
the
purpose
of
this
study,
each
worker
wore
a
WBD
under
a
fresh
lightweight
cotton/
polyester
sweat
shirt
and
pants
purchased
locally
by
study
personnel.
Each
worker
at
all
four
sites
wore
a
lightweight
100%
cotton
glove
dosimeter
on
each
hand
,
under
his
chemical­
resistant
or
work
gloves
as
appropriate.

At
the
beginning
of
each
work
cycle
(
or
8
hour
shift),
each
worker
washed
his
hands
with
a
detergent
and
then
put
on
his
WBD,
followed
by
his
fresh
uniform
and
other
work
clothes.
9
Once
the
worker
was
ready
to
start
his
work
cycle,
study
personnel
placed
his
glove
dosimeters
on
his
hands.
At
each
rest
or
other
break,
study
personnel
removed
the
worker's
glove
dosimeters,
wrapped
the
pair
in
aluminum
foil
(
except
for
certain
samples
from
Sites
A
and
B),
placed
them
in
a
locking
polyethylene
storage
bag
and
froze
them
on
dry
ice.
When
the
break
ended,
the
worker
put
on
a
fresh
pair
of
glove
dosimeters.
At
the
end
of
the
work
day,
study
personnel
collected
the
worker's
glove
dosimeters
and
handled
them
as
noted
above.
The
study
personnel
helped
each
worker
remove
his
outer
work
clothes
and
then
cut
the
WBD
from
him
in
sections,
including
paired
arms,
remainder
of
shirt
("
torso
top"),
briefs
and
paired
legs.
Each
section
was
packaged
as
described
above,
labeled,
and
placed
on
dry
ice
for
shipment
to
EN­
CAS
Laboratories.

Inhalation
Inhalation
exposure
monitoring
at
Site
A
was
unsuccessful
due
to
fact
that
a
single
XAD­
2
tube
was
used
along
with
a
non­
solvent­
resistant
filter
cassette.
Therefore,
the
sampling
methodology
was
changed
to
include
the
use
of
a
second
XAD­
2
resin
tube
in
the
sampling
train
prior
to
sampling
at
Sites
B,
C,
and
D.
Inhalation
exposure
monitoring
was
performed
successfully
at
these
sites.
Each
worker
at
Sites
B,
C,
and
D
was
equipped
with
an
air
sampling
train
consisting
of
a
PTFE
filter
in
an
opaque,
solvent­
resistant
plastic
cassette
connected
upstream
from
two
in­
line
XAD­
2
resin­
filled
air
sampling
tubes.
The
intake
orifice
of
the
filter
was
placed
in
the
worker's
breathing
zone,
directed
downward.
Air
was
pulled
through
the
sampling
train
by
a
portable
air
sampling
pump
which
was
attached
to
the
worker's
belt.
The
pump
drew
air
through
the
sampling
tube
at
approximately
1
L/
minute
while
the
worker
performed
his
tasks.
Pumps
were
calibrated
immediately
prior
to
and
after
each
monitoring
period
using
a
mass
flow
meter
or
bubble
calibrator.
The
pumps
were
turned
on
at
the
beginning
of
each
work
cycle
and
was
left
running
during
restroom,
coffee,
or
other
short
breaks
but
were
turned
off
or
set
on
"
hold"
during
lunch
breaks.
The
pumps
and
samplers
were
removed
from
the
worker
during
the
lunch
break.
At
the
conclusion
of
the
lunch
break,
the
pump
and
sampling
train
were
reinstalled
and
the
pump
was
restarted.
All
start
and
stop
times
were
recorded.

During
each
work
cycle,
start
times
and
end
times
of
each
task
performed
by
the
worker
were
recorded.
Pump
parameters
during
use
were
also
recorded.
At
the
end
of
each
work
cycle,
the
pumps
and
sample
trains
were
collected.
Each
filter
cassette
and
sampling
tube
were
capped,
labeled,
bagged,
and
placed
on
dry
ice
for
shipment
to
USX
Engineers
and
Consultants,
Inc.
(
UEC)
for
extraction
and
analysis.
After
the
collection
of
the
air
samples
the
air
sampling
pump
was
re­
calibrated.

5.3
Analytical
Methods
Dermal
Residues
of
creosote
components
in
dermal
exposure
monitoring
matrices
were
10
determined
by
the
validated
EN­
CAS
Method
ENC­
2/
99,
dated
04/
18/
00.
For
this
procedure,
a
dermal
sample
is
placed
into
glass
jar
(
size
of
jar
is
dependant
upon
the
size
of
the
sample).
The
dermal
sample
consists
of
either
(
1)
one
brief
with
the
elastic
waistband
removed
or
(
2)
two
leg
sections
cut
off
at
the
crotch,
or
(
3)
two
arm
sections,
or
(
4)
one
torso
section
or
(
5)
two
glove
liners.

An
appropriate
amount
(
depending
on
the
type
of
dermal
sample)
of
90:
10
acetonitrile
(
ACN):
dichloromethane
(
DCM)
extraction
solvent
was
added
to
the
jar.
The
jar
was
then
capped
and
shaken
for
30
minutes
at
250
rpm.
An
aliquot
of
the
extract
was
mixed
with
de­
ionized
water,
saturated
NaCl
solution,
and
hexane
in
a
separatory
funnel.
The
mixture
was
shaken
vigorously
for
approximately
30
seconds,
and
the
layers
were
allowed
to
separate
for
5­
10
minutes.
The
organic
layer
from
the
separatory
funnel
was
passed
through
a
rinsed
Na
2
SO
4
powder
funnel,
containing
a
glass
wool
plug,
into
a
clean
glass
flask.
The
aqueous
layer
was
partitioned
a
second
time
with
hexane.
The
hexane
layer
was
drained
through
the
funnel
into
the
same
glass
flask
and
aqueous
layer
was
discarded.
The
rinsate
was
reduced
in
volume
by
rotary
evaporation.
The
concentrated
sample
was
transferred
to
a
conditioned
cartridge
and
eluted
with
a
90:
10
solution
of
hexane:
diethyl
ether.

The
eluate
was
evaporated
to
approximately
1
mL
and
then
brought
to
9.0
mL
with
HPLC
grade
hexanes.
A
1.0
mL
aliquot
of
HPLC
grade
EtOAc
was
added
to
the
eluate
and
the
solution
was
capped
and
shaken
vigorously.
An
aliquot
of
the
shaken
solution
was
placed
in
a
2­
mL
GC
vial
for
GC/
MSD
analysis.

Each
of
the
ten
individual
creosote
components
was
quantitated
as
if
it
expressed
the
total
amount
of
creosote
in
the
sample.
The
normalized
residues
for
each
of
the
individual
creosote
components
were
averaged
together
to
represent
"
total
creosote"
for
that
particular
dermal
sample.
The
"
total"
dermal
exposure
for
each
replicate
for
each
worker
was
calculated
by
summing
the
normalized
residue
levels
in
his
WBD
arms,
WBD
top,
WBD
bottom
(
torso
portion
and
legs,
cut
apart
at
EN­
CAS
and
analyzed
as
separate
samples),
and
all
glove
dosimeters
worn
during
that
replicate.

Inhalation
The
benzene­
soluble
creosote
fractions
(
coal
tar
pitch
volatiles,
or
CTPVs)
in/
on
the
PTFE
air
sampling
filters
were
determined
using
the
validated
UEC
SOP
#
02­
006,
dated
3/
18/
99.
The
eleven
individual
creosote
components
(
PNAs)
were
determined
in
the
XAD­
2
resin
air
sampling
tubes
using
the
validated
UEC
SOP
#
04­
022,
dated
10/
9/
98.

Each
PTFE
filter
was
transferred
from
its
cassette
to
a
beaker.
Benzene
was
added
to
the
beaker
and
the
beaker
was
sonicated
for
20
minutes.
The
extract
was
decanted
through
a
benzene­
rinsed
glass­
fiber
filter
in
a
sintered
glass
funnel,
and
vacuum
filtered
into
a
concentrator
tube.
Additional
benzene
was
added
to
the
beaker,
swirled,
and
added
to
the
concentrator
tube.
Additional
benzene
was
also
added
to
rinse
the
funnel,
and
was
collected
int
concentrator
tube.
The
extract
was
reduced
to
<
3.0
mL
with
nitrogen,
and
made
up
to
3.0
mL
with
benzene.
The
11
extract
was
then
drawn
into
a
syringe
and
used
to
rinse
the
sides
of
the
concentrator
tube,
to
recover
any
creosote
on
the
sides
of
the
tube.
One
half
of
the
extract
was
transferred
to
a
preweighed
cup.
The
cup
was
retained
in
a
desiccator
overnight,
and
then
re­
weighed.
The
other
half
of
the
extract
was
placed
in
a
vial
and
capped
to
be
used
for
the
determination
of
the
11
individual
PNAs.

For
each
XAD­
2
resin
tube,
the
plastic
cap
was
removed
from
the
rear
end
of
the
tube.
The
rear
glass
wool
plug
was
then
removed
and
discarded.
The
rear­
section
XAD­
2
resin
and
the
middle
glass
wool
plug
were
transferred
to
an
amber
vial
and
capped.
The
front­
section
XAD­
2
resin
and
the
front
glass­
wool
plug
were
transferred
to
another
amber
vial
and
capped.
Toluene
was
added
to
each
vial.
The
vial
was
immediately
screw­
capped,
and
placed
into
an
ultrasonic
bath
for
30
to
60
minutes.
The
PTFE
filters
subjected
to
SOP
#
02­
006,
described
above,
were
diluted
with
toluene
and
sonicated.
A
portion
of
each
of
these
sonicated
samples
was
pipetted
into
an
amber
glass
vial
for
analysis
using
an
HP
GC
with
a
flame
ionization
detector.

6.0
RESULTS
6.1
Method
Validation
6.1.1
EN­
CAS
Method
ENC­
2/
99
­
(
determination
of
creosote
in
fabrics)

This
method
was
validated
by
fortifying
sets
of
7
control
WBD
sections
and
glove
pairs
with
reference
standard
creosote
at
each
of
the
following
concentrations:
60

g/
sample,
6000

g/
sample,
60000

g/
sample,
and
0

g/
sample
(
control).
The
limit
of
quantitation
(
LOQ)
for
total
creosote
in
cotton
WBD
fabric
samples
and
glove
pairs
was
60

g/
sample.
The
limit
of
detection
was
set
at
50%
the
LOQ
(
30

g/
sample).
Recoveries
for
the
control
samples
were
below
the
LOQ.
Table
1
shows
a
summary
of
the
total
creosote
recoveries
from
these
fortified
samples.

Table
1.
Method
Validation
Results
for
Total
Creosote
Detection
in
Fabrics
Matrix
Fortified
Level
(

g/
sample)
%
Recovery
of
Total
Creosote
Mean
S.
D.
%
cv
WBD
Sections
60
83
(
n=
7)
8.9
10.70
6000
78
(
n=
7)
3.6
4.62
60000
75
(
n=
7)
4.5
6.00
Glove
Pairs
60
101
(
n=
7)
6.8
6.73
6000
86
(
n=
7)
7.0
8.14
60000
85
(
n=
7)
10.6
12.4
12
n
=
number
of
replicates
per
fortification
level.

6.1.2
UEC
SOP
#
02­
006
­
(
determination
of
CTPVs
in/
on
PTFE
air
sampling
filters)

This
method
was
validated
by
fortifying
sets
of
7
control
filters
with
reference
standard
creosote
(
in
benzene)
at
each
of
the
following
concentrations:
79

g/
sample,
793

g/
sample,
7930

g/
sample,
and
0

g/
sample
(
control).
The
LOQ
for
CTPVs
in
air
sampling
filters
was
79

g/
sample.
The
LOD
was
calculated
as
20

g/
sample.
Recoveries
of
benzene­
soluble
fraction
from
fortified
samples
are
summarized
in
Table
2.
Recoveries
of
CTPVs
from
all
control
samples
were
less
than
the
LOQ.

Table
2.
Method
Validation
Recoveries
for
CTPVs
in/
on
PTFE
Air
Filters
Fortified
Level
(

g/
sample)
%
Recovery
of
CTPVs
Mean
S.
D.
%
cv
79
116.8
(
n=
7)
6.40
5.48
793
103.1
(
n=
7)
3.14
3.05
7930
90.1
(
n=
7)
1.97
2.18
n
=
number
of
replicates
per
fortification
level.

6.1.3
UEC
SOP
#
04­
022
­
(
determination
of
individual
creosote
components
in
XAD­
2
resin
air
sampling
tubes
and
PTFE
air
sampling
filters)

This
method
was
validated
for
determination
of
specific
target
PNAs
in
XAD­
2
resin
tubes
by
fortifying
sets
of
7
unexposed
samples
of
XAD­
2
resin
tubes
extracted
from
single
sections
of
unexposed
sampling
tubes
with
mixed
reference
standard
PNAs
(
in
toluene)
at
each
of
the
following
concentrations:
the
LOQ
of
each
compound,
5
times
the
LOQ
of
each
compound
(
the
highest
concentrations
that
could
be
prepared
without
precipitation),
and
at
0

g/
sample
(
control).
Table
3
summarizes
the
LODs,
LOQs,
and
method
validation
percent
recoveries
for
the
specific
target
PNAs
in
XAD­
2
resin
tubes.
Recoveries
from
all
control
samples
were
below
the
LOQ.

This
method
was
also
validated
for
determination
of
specific
target
PNAs
in
or
on
PTFE
air
sampling
filters
by
fortifying
sets
of
7
unexposed
filters
with
mixed
reference
standard
PNAs
(
in
toluene)
at
each
of
the
following
concentrations:
the
LOQ
of
each
compound,
5
times
the
LOQ
of
each
compound,
and
0

g/
sample
(
control).
Table
4
summarizes
the
LODs,
LOQs,
and
method
validation
percent
recoveries
for
the
specific
target
PNAs
in/
on
PTFE
air
sampling
filters.
13
Recoveries
of
all
the
control
samples
were
below
the
LOQ.
The
results
from
this
method
validation
demonstrated
the
adequacy
of
the
method
for
determining
all
analytes
in/
on
PTFE
air
sampling
filters
at
the
5
times
the
LOQ
fortification
level.
Recoveries
of
naphthalene,
1­
and
2­
methylnaphthalenes,
dibenzofuran,
and
to
a
lesser
extent
acenaphthene,
were
unacceptable
at
the
lower
(
LOQ)
fortification
level,
presumably
due
to
their
lower
molecular
weights
and
resulting
increased
volatility.
(
The
other
analytes
were
recovered
at
acceptable
levels
from
samples
spiked
at
both
levels.)

Table
3.
Method
Validation
Recoveries
for
PNAs
in
XAD­
2
Resin
Tubes
PNAs
LOD
(

g)
LOQ
(

g)
Fortification
Levels
(

g/
sample)
%
Recoveries
of
PNAs
Mean
S.
D.
%
cv
Naphthalene
0.41
20.5
20.5
100.0
(
n=
7)
0.745
0.742
102.5
99.0
(
n=
7)
2.29
2.31
2­
Methylnaphthalene
0.47
22.1
22.1
99.8
(
n=
7)
0.684
0.692
110.5
98.3
(
n=
7)
2.15
2.19
1­
Methylnaphthalene
0.53
20.1
20.1
100.0
(
n=
7)
0.882
0.881
100.5
99.0
(
n=
7)
2.21
2.23
Acenaphthene
0.47
22.7
22.7
101.0
(
n=
7)
0.751
0.747
113.5
99.0
(
n=
7)
2.12
2.14
Dibenzofuran
0.69
21.2
21.2
97.8
(
n=
7)
0.977
0.998
106.0
98.9
(
n=
7)
2.07
2.09
Fluorene
0.48
20.9
20.9
99.7
(
n=
7)
0.716
0.718
104.5
98.2
(
n=
7)
2.10
2.14
Phenanthrene
0.36
21.0
21.0
100.0
(
n=
7)
0.530
0.529
104.5
99.4
(
n=
7)
2.05
2.06
Anthracene
0.51
20.0
19.2
99.8
(
n=
7)
0.895
0.897
96.0
98.9
(
n=
7)
2.04
2.07
Pyrene
0.47
21.0
21.0
101.0
(
n=
7)
0.673
0.664
105.0
99.1
(
n=
7)
1.86
1.88
Chrysene
0.36
23.4
19.1
101.0
(
n=
7)
0.676
0.672
95.5
99.3
(
n=
7)
1.90
1.91
Benzo(
a)
pyrene
0.51
25.8
25.8
102.0
(
n=
7)
0.687
0.676
129.0
99.2
(
n=
7)
1.97
1.99
n
=
number
of
replicates
per
fortification
level.
14
15
Table
4.
Method
Validation
Recoveries
for
PNAs
in/
on
PTFE
Air
Filters
PNAs
LOD
(

g)
LOQ
(

g)
Fortification
Levels
(

g/
sample)
%
Recoveries
of
PNAs
Mean
S.
D.
%
cv
Naphthalene
0.41
20.5
20.5
2.58
(
n=
7)
6.82
265
103
0.7
(
n=
7)
15.90
2.98
2­
Methylnaphthalene
0.47
22.1
22.1
28.4
(
n=
7)
10.0
35.4
111
2.7
(
n=
7)
9.75
3.31
1­
Methylnaphthalene
0.53
20.1
20.1
24.8
(
n=
7)
12.0
48.4
101
3.1
(
n=
7)
12.03
3.54
Acenaphthene
0.47
22.7
22.7
62.4
(
n=
7)
6.17
9.88
114
61.9
(
n=
7)
2.27
3.67
Dibenzofuran
0.69
21.2
21.2
72.1
(
n=
7)
3.06
4.25
106
70.8
(
n=
7)
2.04
2.88
Fluorene
0.48
20.9
20.9
79.6
(
n=
7)
2.47
3.10
105
79.5
(
n=
7)
2.70
3.39
Phenanthrene
0.36
21.0
21.0
90.2
(
n=
7)
2.95
3.27
105
88.8
(
n=
7)
2.80
3.16
Anthracene
0.51
20.0
19.2
89.5
(
n=
7)
3.42
3.82
96
90.4
(
n=
7)
2.78
3.08
Pyrene
0.47
21.0
21.0
98.0
(
n=
7)
3.71
3.79
105
95.1
(
n=
7)
2.83
2.98
Chrysene
0.36
23.4
21
93.3
(
n=
7)
4.48
4.80
105
92.6
(
n=
7)
3.07
3.31
Benzo(
a)
pyrene
0.51
25.8
25.8
89.3
(
n=
7)
2.64
2.95
129
91.5
(
n=
7)
3.24
3.54
n
=
number
of
replicates
per
fortification
level.

These
results
demonstrated
that
the
proposed
combination
of
filter
and
resin
tube
filter
train
would
be
necessary
for
adequate
retention
of
all
selected
analytes
during
field
sampling.
16
6.2
Breakthrough/
Retention
Testing
Breakthrough/
retention
testing
was
performed
in
order
to
insure
that
creosote
components
would
not
migrate
from
the
XAD­
2
resin
particles.
All
of
the
control
recoveries
of
all
analytes
were
below
the
LOD
for
this
test.
At
the
LOQ
spike
level,
all
of
the
analytes
were
retained
in
the
filters
or
front
tubes.
Very
low
levels
of
naphthalene
were
found
in
one
of
the
high­
level
spiked
rear
tube
but
no
other
creosote
component
was
detected.
This
naphthalene
recovery
was
thought
to
possibly
be
due
to
contamination
during
handling
in
the
analytical
laboratory.

6.3
Pre­
field
Recovery
of
Creosote
in
Dermal
Matrices
A
pre­
field
recovery
study
of
creosote
in
dermal
matrices
was
performed
in
order
to
determine
that
creosote
applied
to
glove
dosimeters
and
WBD
fabric
would
be
retained
by
those
matrices
during
field
sampling
and
transport.
The
mean
percent
recoveries
showed
some
loss
of
creosote
compontents
on
full­
day
exposure
to
ambient
conditions.
However,
according
to
the
Study
Report,
the
results
were
within
the
range
generally
considered
acceptable
for
field
samples.
The
average
recovery
for
the
WBDs
exposed
to
ambient
conditions
for
8
hours
was
69.2%
+
9.1%.
The
average
recovery
for
the
WBDs
which
were
spiked
but
not
exposed
to
ambient
conditions
was
87.6%
+
10.3%.
The
average
recovery
for
the
gloves
exposed
to
ambient
conditions
for
8
hours
was
63.4%
+
9.4%.
The
average
recovery
for
the
gloves
which
were
spiked
but
not
exposed
to
ambient
conditions
was
85%
+
3.23%.

6.4
Laboratory
Spikes
Laboratory
fortified
samples
of
each
matrix
used
in
the
study
were
analyzed
concurrently
with
field
samples
to
monitor
procedural
recoveries.
The
mean
recovery
of
total
creosote
from
laboratory
fortified
glove
and
WBD
samples
is
summarized
in
Table
5.
The
mean
recoveries
of
total
creosote
ranged
from
85.4%
to
89.3%.
These
recoveries
were
well
within
the
acceptable
range.

Table
5.
Recovery
of
Total
Creosote
from
Laboratory
Fortified
Dermal
Matrices
Matrix
Mean
%
S.
D.
No.
of
Reps.

Glove
(
2)
89.1
11.7
69
Whole
Body
Dosimeter
(
WBD):

arm(
2)
89.3
7.47
28
top
85.4
8.08
30
brief
88.2
7.03
24
leg
(
2)
86.0
7.09
24
17
The
mean
recoveries
of
creosote
components
from
laboratory
fortified
XAD­
2
resin
tubes
are
summarized
in
Table
6.
The
laboratory
fortification
levels
were
at
the
LOQ
and
5
times
the
LOQ
for
each
component.
The
mean
recoveries
at
the
LOQ
level
ranged
from
76
to
98.7%.
The
mean
recoveries
at
5
times
the
LOQ
level
ranged
from
72.7
to
87%.
The
overall
mean
recoveries
for
both
fortification
levels
ranged
from
74.3
to
92.8%.
All
of
the
mean
recoveries
for
the
creosote
components
are
within
the
acceptable
range.
Chrysene
had
the
lowest
recovery
at
both
fortification
levels.

The
mean
recovery
from
12
samples
fortified
in
the
laboratory
at
10
times
the
LOQ
(
0.790
mg)
of
CTPVs
in
PTFE
air
sampling
filters
was
84.0
+
7.3%.
According
to
the
registrant,
the
results
from
all
of
these
laboratory
fortified
recoveries
agree
favorably
with
the
method
validation
recoveries.

6.5
Field
Spikes
Field
fortification
samples
were
prepared
once
at
each
facility.
Unexposed
WBD
sections,
paired
glove
dosimeters,
single
air
sampling
filters,
and
complete
air
sampling
trains
were
fortified
in
the
field
to
assess
potential
degradation
or
reduced
extractability
of
residues
due
to
exposure
to
environmental
conditions,
handling,
packaging,
shipping,
and
frozen
storage.

Dermal
Field
Fortification
Samples
Field
fortified
sets
of
3control
WBD
sections
and
glove
pairs
with
reference
standard
creosote
were
prepared
at
each
site
at
each
of
the
following
concentrations:
60

g/
sample,
60000

g/
sample,
and
0

g/
sample
(
control).
Results
from
dermal
field
fortification
samples
are
presented
below
in
Table
7.
Overall
field
fortification
recoveries
at
Site
A
for
whole
body
dosimeters
(
WBD's)
and
gloves
were
68
and
78%,
respectively.
Overall
field
fortification
recoveries
at
Site
B
for
whole
body
dosimeters
(
WBD's)
and
gloves
were
96
and
62
%,
respectively.
Overall
field
fortification
recoveries
at
Site
C
for
whole
body
dosimeters
(
WBD's)
and
gloves
were
72
and
69
%,
respectively.
Overall
field
fortification
recoveries
at
Site
D
for
whole
body
dosimeters
(
WBD's)
and
gloves
were
71
and
66
%,
respectively.
There
were
however
some
fortification
levels
which
yielded
extremely
high
recoveries
for
WBD's
and
some
low
recoveries
for
gloves.
For
example,
at
a
60
µ
g/
sample
"
total
creosote"
fortification
for
Site
B,
there
were
recoveries
for
the
WBD's
as
high
as
150%
and
recoveries
for
the
gloves
as
low
as
52.3%.
There
were
measurable
amounts
of
total
creosote
found
in
each
of
the
control
samples
prepared
at
each
facility.
The
field
fortification
values
were
corrected
based
on
these
control
samples.
Therefore,
the
field
fortification
recovery
value
is
minus
the
amount
of
total
creosote
found
in
the
control
samples.
18
Table
6.
Recovery
of
PNAs
from
Laboratory
Fortified
XAD­
2
Resin
Tubes
Fortification
level
%
Recoveries
of:
*

N
2­
MN
1­
MN
AC
DBF
F
PH
AN
PY
CH
BAP
LOQ
Mean
(
n=
22)
89.3
86.1
86.0
86.0
98.7
84.0
81.0
82.0
85.0
76.0
81.9
SD
21.1
20.5
20.4
20.1
33.3
20.5
19.8
19.7
18.5
16.4
20.0
5
x
LOQ
Mean
(
n=
22)
83.8
82.6
82.4
82.2
87.0
80.4
72.9
80.5
77.4
72.7
75.9
SD
25.4
25.2
25.5
25.9
25.4
25.1
25.7
26.2
25.2
24.5
24.6
Overall
Mean
Recovery
86.5
84.3
84.2
84.1
92.8
82.2
76.9
81.2
81.2
74.3
78.9
*
N=
naphthalene;
2­
MN
=
2­
methylnaphthalene;
1­
MN
=
1­
methylnaphthalene;
AC=
acenaphthene;
DBF
=
dibenzofuran;
F
=
fluorene;
PH
=
phenanthrene;
AN
=
anthracene;

PY
=
pyrene;
CH
=
chrysene;
and
BAP
=
Benzo(
a)
pyrene.

(
n)=
number
of
replicates
19
Table
7.
Field
Fortification
Recoveries
for
Total
Creosote
Detection
in
Fabrics
Matrix
Fortified
Level
(

g/
sample)
%
Recovery
of
Total
Creosote
Mean
S.
D.
Overall
Site
A
WBD
Sections
60
65.8
1.7
67.6
(
n=
6)
60000
69.4
1.0
Glove
Pairs
60
68.7
11.1
78.4
(
n=
6)
60000
88.2
1.1
Site
B
WBD
Sections
60
122
24.3
96.3
(
n=
6)
60000
70.6
2.8
Glove
Pairs
60
54.5
2.6
62.4
(
n=
6)
60000
70.4
1.9
Site
C
WBD
Sections
60
66.8
4.0
71.8
(
n=
6)
60000
76.9
3.9
Glove
Pairs
60
63.8
10.5
69.1
(
n=
6)
60000
74.4
6.1
Site
D
WBD
Sections
60
74.3
5.8
71.5
(
n=
6)
60000
68.8
6.5
Glove
Pairs
60
61.1
11.0
66.5
(
n=
6)
60000
72.0
5.5
Inhalation
Field
Fortification
Samples
At
Sites
B
through
D,
triplicate
XAD­
2
resin
tubes
were
fortified
with
a
solution
of
mixed
PNAs
(
in
toluene)
at
0
ppm
(
control),
the
LOQ
of
each
compound,
and
5
times
the
LOQ
of
each
compound.
Each
sampling
tube
was
connected
to
a
Buck
S.
S.
pump
that
then
ran
for
8
hours
at
20
approximately
1
L/
minute.
Results
from
inhalation
field
fortification
XAD­
2
resin­
filled
sampling
tubes
are
presented
below
in
Table
8.
Overall
field
fortification
recoveries
for
all
of
the
polynuclear
aromatic
hydrocarbons
(
PNAs)
ranged
from
78
to
180%
at
Site
B,
from
62
to
96%
at
Site
C,
and
from
69
to
124%
at
Site
D.
At
Site
B,
the
high
recovery
was
for
dibenzofuran.
At
Site
C,
the
lowest
recoveries
were
for
fluorene
and
phenanthrene.
At
Site
D,
the
high
recoveries
were
for
chrysene.

Additional
triplicate
sampling
trains,
each
consisting
of
two
air
sampling
filters
in
in­
line
cassettes,
were
spiked
with
a
solution
of
standard
creosote
(
in
benzene)
at
0
ppm,
the
LOQ,
or
10
times
the
LOQ.
Each
train
was
connected
to
a
Buck
S.
S.
pump
that
then
ran
for
8
hours
at
approximately
1.0
L/
minute.
Results
from
these
field
fortification
recoveries
for
CTPV
in/
on
the
PTFE
filters
which
were
attached
to
sampling
tubes
are
presented
in
Table
9.
The
Overall
percent
recoveries
for
the
coal
tar
pitch
volatiles
(
CTPVs)
were
poor.
The
overall
recovery
for
Site
B
was
57%.
The
overall
recoveries
for
Sites
C
and
D
were
51
and
57%,
respectively.
The
registrant
did
not
address
these
poor
inhalation
field
fortification
results.

6.6
Formulation
Testing
The
field
phase
of
this
study
was
performed
using
commercial
wood
treatment
systems
that
could
not
economically
be
shut
down,
solvent­
cleaned,
and
filled
with
analyzed
lots
of
test
substances
for
this
study.
Instead,
study
personnel
collected
100
to
200
mL
sample
aliquots
of
the
mixed
application
solutions
which
were
used
during
the
monitored
work
cycles,
and
shipped
them
to
EN­
CAS
for
later
analysis.
Study
personnel
and/
or
test
site
personnel
collected
at
least
one
sample
of
the
on­
site
product
used
to
treat
lumber
products
during
monitoring
at
each
site.
Four
such
samples
were
subjected
to
GLP­
compliant
compositional
analysis
(
results
were
provided
in
the
study
raw
data).
The
creosote
used
at
each
test
site
was
analyzed
by
the
producer
for
compliance
with
AWPA
specifications,
and
was
determined
to
be
within
those
specifications,
as
noted
on
the
certificates
of
analysis
supplied
with
the
creosote.

The
Koppers
Creosote
Solution
("
P2")
used
for
application
to
railroad
ties
as
Sites
A,
C,
and
D
had
a
purity
of
nominally
95%
AWPA
P2
creosote.
The
Koppers
Coal
Tar
Creosote
("
P1")
used
at
Site
C
for
application
to
utility
poles
had
a
purity
of
nominally
98.5%
AWPA
P1/
P13
creosote.
The
Coal
Tar
Creosote
(
P­
1/
P13)
Wood
Preservative
used
for
application
to
wood
at
Site
B
had
a
purity
of
nominally
100%
P1/
P13
creosote.
21
Table
8.
Field
Fortification
Recoveries
for
PNAs
in
XAD­
2
Resin
Tubes
Fortificatio
n
level
%
Recoveries
of:
*

N
2­
MN
1­
MN
AC
DBF
F
PH
AN
PY
CH
BAP
Site
B
Average
Recovery
LOQ
(
n=
3)
104
94.9
100
87.3
221.8
74.1
73
81.1
89.4
91
96.1
5
x
LOQ
(
n=
3)
130
122
126
112
139
88.3
83.9
74.5
80.4
83.7
88.2
Overall
Recovery
117
109
113
100
180
81
78
78
85
87
92
S.
D.
42.8
39.3
40.7
35.1
60.9
21.1
10.8
6.0
7.0
5.8
6.7
Site
C
Average
Recovery
LOQ
(
n=
3)
97.7
83.6
82.2
69.5
67.5
58.3
59.2
71.6
79.2
93.5
101
5
x
LOQ
(
n=
3)
90.1
81.9
81.4
72.1
70.4
65.3
68.5
80.0
80.8
86.2
91
Overall
Recovery
94
83
82
71
69
62
64
76
80
90
96
S.
D.
8.1
5.1
5.3
5.6
5.3
5.8
7.0
7.2
5.8
5.7
7.9
Site
D
Average
Recovery
LOQ
(
n=
3)
74.6
85.6
82.4
79.3
78.1
72.7
61.4
68.7
77.5
123
107
5
x
LOQ
(
n=
3)
106
102
100
92.6
87.6
82.7
76.8
84.9
84.4
126
110
Overall
Recovery
91
94
91
86
83
78
69
77
81
124
109
S.
D.
22.6
18.7
18.5
17.9
16.8
15.8
15.1
11.6
7.4
2.9
2.6
*
N=
naphthalene;
2­
MN
=
2­
methylnaphthalene;
1­
MN
=
1­
methylnaphthalene;
AC=
acenaphthene;
DBF
=
dibenzofuran;
F
=
fluorene;
PH
=
phenanthrene;
AN
=
anthracene;

PY
=
pyrene;
CH
=
chrysene;
and
BAP
=
Benzo(
a)
pyrene.
22
Table
9.
Field
Fortification
Recoveries
for
CTPV
in/
on
PTFE
Filters
Attached
to
Air
Sampling
Tubes
Test
Site
Fortification
Level
Average
Recovery
(%)
S.
D.
Overall
Recovery
(%)

B
LOQ
52.3
(
n=
3)
8.2
57
10
x
LOQ
61.5
(
n=
3)
1.7
C
LOQ
51
(
n=
3)
3.9
51
10
x
LOQ
50.9
(
n=
3)
0.9
D
LOQ
52.3
(
n=
3)
8.2
57
10
x
LOQ
61.5
(
n=
3)
1.7
6.7
Storage
Stability
Dermal
The
stability
of
total
creosote
was
determined
in
WBD
sections
(
arm
pairs)
and
pairs
of
glove
dosimeters
stored
frozen
after
fortification
with
3,000

g/
sample
(
50
times
the
LOQ).
Five
sets
of
WBD
sections
and
glove
pairs
were
stored
frozen
by
EN­
CAS
for
up
to
329
days,
respectively,
at
<
­
11.1
oC
prior
to
residue
extraction
at
the
following
storage
intervals:
0,
10,
30,
90,
and
329
days.
Each
set
consisted
of
one
control,
2
WBD
sections
and
glove
pairs
exposed
at
the
time
of
setup,
and
2
WBD
sections
and
glove
pairs
exposed
just
prior
to
residue
extraction.
The
mean
creosote
recoveries
for
the
WBD
sections
and
glove
pairs
ranged
from
87.6
to
97.4%
through
out
the
stability
study
period
(
0
to
329
days).
Mean
creosote
levels
in
WBD
samples
and
glove
pairs
stored
at
<
­
11.1
oC
for
90
and
329
days
declined
by
approximately
5%
and
approximately
10%,
respectively.
WBD
and
glove
pair
samples
collected
from
the
field
were
stored
frozen
at
EN­
CAS
for
up
to
161
days
and
92
days,
respectively,
at
<
­
11.1
oC
prior
to
residue
extraction.
According
to
the
registrant,
the
results
from
the
dermal
media
storage
stability
study
demonstrate
the
stability
of
creosote
residues
in
frozen
dermal
exposure
monitoring
media.

Inhalation
The
stability
of
creosote
components
was
determined
in
XAD­
2
resin
tubes
and
PTFE
air
sampling
filters
stored
frozen
after
fortification
with
5
times
the
LOQ
of
each
component.
Five
sets
of
resin
tubes
and
air
filters
were
stored
frozen
by
UEC
for
up
to
60
days,
at
<
­
17
oC,
prior
to
residue
extraction
at
the
following
storage
intervals:
0,
10,
30,
and
60
days.
Each
set
consisted
of
one
control,
2
resin
tubes
(
or
2
air
filters)
exposed
at
the
time
of
setup,
and
2
resin
23
tubes
(
or
2
air
filters)
exposed
just
prior
to
residue
extraction.

The
average
percent
recoveries
for
the
individual
creosote
components
in
the
XAD­
2
resin
tubes
ranged
from
92.1
to
98.5%
after
30
days
of
frozen
storage.
The
average
percent
recoveries
for
the
individual
PNAs
ranged
from
79.3
to
86.6%
after
60
days
of
frozen
storage.
The
average
percent
recovery
of
each
of
the
PNAs
in
the
XAD­
2
resin
tubes
showed
that
PNA
levels
in
XAD­
2
resin
declined
<
10%
after
30
days,
and
(
with
the
exception
of
benzo(
a)
pyrene)
,
20%
after
60
days
of
frozen
storage.
Values
for
worker
samples
stored
over
30
days
were
corrected
for
the
results
of
this
test.

The
average
percent
recoveries
for
the
individual
PNAs
in
the
PTFE
air
filters
ranged
from
0.0
to
145%
after
30
days
of
frozen
storage.
After
60
days
of
frozen
storage,
the
average
percent
recoveries
for
the
individual
PNAs
ranged
from
2.4
to
142%.
On
the
PTFE
air
sampling
filters,
anthracene,
pyrene,
chrysene,
and
benzo(
a)
pyrene
showed
no
decline
over
60
days.
Phenanthrene
declined
by
<
10%
over
60
days.
The
lighter
molecular
weight
PNAs
declined
markedly
during
frozen
storage;
however,
because
the
air
filters
used
were
expected
to
pass
volatile
PNAs
during
exposure,
and
because
PNAs
were
not
present
at
>
LOQ
in
any
samples
collected,
worker
sample
values
were
not
corrected
for
these
results.

In
preliminary
testing,
reference
standard
creosote
was
applied
to
PTFE
air
sampling
filters
at
3
times
the
LOQ
and
5
times
the
LOQ.
After
15,
30,
and
60
days
of
storage
at
<
­
17
oC,
recoveries
of
CTPVs
from
fortified
filters
were
75.1%,
75.8%,
and
66.1%,
respectively,
of
the
original
fortification
level.
Again,
because
CTPVs
were
>
LOQ
in
only
two
samples
collected,
worker
sample
values
were
not
corrected
for
these
results.

XAD­
2
resin
tubes
and
PTFE
air
filters
collected
in
the
field
were
stored
frozen
by
UEC
for
up
to
51
days,
at
<
­
17
oC,
prior
to
residue
extraction.

6.8
Exposures
Known
quantities
of
a
characterized
creosote
formulation
was
not
measurable
for
this
study
because
the
study
was
set
up
in
a
continuously
operating
commercial
setting.
The
creosote
was
applied
in
closed
systems
which
recovered
and
retained
excess
treatment
solution
from
the
wood
and
treatment
vessels
while
sealed.
Therefore,
the
amount
of
product
or
active
ingredient
handled
by
each
worker
is
not
known.
According
to
the
study,
the
major
source
of
creosote
for
worker
exposure
in
these
types
of
facilities
is
preservative
remaining
on
or
escaping
from
treated
wood
or
equipment
that
had
been
in
a
cylinder
during
treatment.
This
is
presumably
a
very
small
fraction
of
the
quantity
actually
applied
to
and
retained
by
the
charge.
The
mean
pounds
of
creosote
retained
per
charge
per
site
are
as
follows:

Site
A
19004
lbs
Site
B
11289
lbs
Site
C
25999
lbs
Site
D
25978
lbs
24
Sites
A
and
B
had
shortened
monitoring
periods
due
to
weather
and
maintenance
related
facility
closures.
Differences
among
Sites
B,
C,
and
D
in
the
amount
of
creosote
applied
per
charge
were
largely
due
to
differences
in
the
available
cylinder
volume
at
each
site.

Dermal
Results
Dermal
worker
exposure
was
measured
for
each
of
the
workers'
tasks
identified
in
section
3.1.
During
each
replicate
of
monitoring,
exposure
of
the
subject's
body
(
excluding
that
of
the
face,
neck,
and
hands)
to
creosote
components
was
determined
by
collection
of
material
in/
on
his
cotton
WBD.
Exposure
of
his
hands
was
determined
from
material
collected
in/
on
his
cotton
glove
dosimeters
(
worn
under
his
chemical­
resistant
gloves
if
appropriate).

The
unadjusted
creosote
level
for
each
WBD
segment
and
glove
pair
from
each
worker
was
corrected
for
the
mean
recovery
of
the
appropriate
analytical
standard(
s)
from
samples
of
the
appropriate
matrix
fortified
in
the
field
at
that
test
site.
The
analytical
method
was
subject
to
some
variability
at
levels
near
the
LOQ,
suggesting
that
recoveries
obtained
at
that
level
were
likely
to
be
less
reliable
than
those
at
the
higher
level.
Therefore,
the
field
fortification
recoveries
at
1,000
times
the
LOQ
were
used
to
make
the
adjustment.
The
registrant
did
not
make
any
adjustments
when
field
fortification
recoveries
were
>
100%.
U.
S.
EPA
guidelines
state
that
corrections
are
not
needed
when
field
fortification
recoveries
are
above
90%.
For
any
sample
in
which
the
"
total
creosote"
level
was
below
the
LOQ
but
above
the
LOD,
½
the
LOQ
was
used
as
an
upper­
bound
estimate
of
the
residue
in
the
sample
for
calculation
of
calculated
exposure.
In
addition,
for
any
sample
in
which
the
"
total
creosote"
level
was
below
the
LOD,
½
the
LOD
was
used
as
the
upper­
bound
estimate
for
calculation.
The
use
of
½
LOD
and
½
LOQ
values
was
the
same
for
the
inhalation
data.

Each
calculated
exposure
level
was
normalized
to

g/
kg
worker
body
weight/
day,
normalizing
results
to
the
U.
S.
EPA's
recommended
mean
adult
weight
of
71.8
kg
and
to
a
standard
work
day
length
of
8
hours.
The
"
total"
dermal
exposure
for
each
replicate
for
each
worker
was
calculated
by
summing
the
normalized
residue
levels
in
his
WBD
arms,
WBD
top,
WBD
bottom
(
torso
portion
and
legs,
cut
apart
at
EN­
CAS
and
analyzed
as
separate
samples),
and
all
glove
dosimeters
worn
during
that
replicate.

The
levels
of
total
creosote
found
in
workers'
gloves
and
WBDs
(
combined)
are
shown
in
Tables
XIX,
XX,
XX1,
and
XXII
(
pages
126
through
140)
in
the
Study
Report.
The
calculated
geometric
mean
daily
dermal
exposure
levels
of
monitored
workers
at
all
sites
are
summarized
in
Table
10,
below.
Geometric
mean
dermal
exposures
across
all
of
the
job
functions
at
all
four
sites
ranged
from
25
(
Load­
Out
Area
Helper)
to
901
(
Oil
Unloader)

g/
kg
bw/
day.
The
highest
individual
levels
were
found
in
the
Site
C
TO,
who
was
also
performing
the
duties
of
the
OU
while
not
wearing
chemical­
resistant
gloves
on
at
least
one
monitored
occasion.
Within
each
job
class
monitored,
and
over
all
classes
at
each
site,
those
individuals
whose
activities
involved
the
greatest
proximity
to
creosote
sources
were
exposed
to
the
highest
levels
of
creosote.

Differences
in
exposures
were
pronounced
from
site
to
site,
with
the
smallest
exposure
25
levels
observed
at
Site
B,
which
applied
the
smallest
amount
of
creosote,
and
which
included
an
air­
handling
system
to
remove
creosote
vapors
from
the
cylinder
door
area.
The
highest
exposures
were
found
at
Site
C,
which
was
the
site
which
used
the
second­
highest
quantity
of
creosote
and
where
the
CHs
regularly
contacted
and
handled
freshly
treated
ties.
26
Table
10.
Geometric
Mean
Daily
Dermal
Exposure
Levels
of
Monitored
Workers
at
all
Sites
Parameter
Dermal
Exposure
(

g/
kg
bw/
day)
to
Creosote
of
:
*

TO
TA
TB
WO
OU
CLO
CH
LLO
LLO
(
F)
LH
DP
CK
#
Replicates
18
4
9
8
9
18
10
14
5
4
4
5
Minimum
15.1
20.8
94.9
27.1
349.4
45.9
40.1
14.1
102.4
18.8
213.2
269.1
Maximum
49573
33
3118
377
2560
3987
3446
591
771
37
395
2341
Mean
5051
27
759
170
1203
773
1190
119
278
26
280
877
S.
D.
12877
6
1005
152
943
1115
1075
149
278
8
86
850
G.
M.
360
27
385
108
901
313
626
69
208
25
271
638
Median
369
28
365
107
680
191
1213
60
169
25
257
586
*
Abbreviations:
CH
=
cylinder
area
loader
helper;
CK
=
checker;
CLO
=
cylinder
area
loader
operator;
DP
=
drip
pad
labor;
LLO
=
load­
out
area
loader
operator;
LLO(
F)
=
load­
out
area
forklift
operator;
OU
=
oil
unloader;
TA
=
treating
assistant;
TB
=
test
borer;
TO
=
treating
operator;
WO
=
water
treatment
system
operator;
LH
=
load­
out
area
loader
helper.
27
Inhalation
Results
Inhalation
to
monitored
workers
was
measured
for
each
of
the
tasks
identified
in
section
3.1
at
Sites
B,
C,
and
D.
No
useful
inhalation
data
were
generated
at
Site
A
due
to
problems
with
the
air
sampling
methodology.
The
methodology
was
changed
prior
to
sampling
at
Sites
B,
C,
and
D.
The
unadjusted
residue
level
for
each
air
sampler
from
each
worker
was
corrected
for
the
mean
recovery
of
the
appropriate
analytical
standard(
s)
from
samples
of
the
appropriate
matrix
fortified
in
the
field
at
that
test
site.
Inhalation
exposure
for
each
target
compound
was
calculated
from
material
found
in
the
entire
sampling
train
(
filter
+
front
tube
+
rear
tube).
Calculated
inhalation
exposure
levels
were
normalized
by
scaling
up
the
pump
flow
rate
of
1
L/
minute
to
the
U.
S.
EPA's
recommended
minute
ventilation
rate
of
approximately
18.34
L/
minute
for
"
light
activities".
Then
an
adjustment
was
made
for
the
standard
EPA­
recommended
adult
weight
of
71.8
kg.
According
to
the
Study
Report,
due
to
the
fact
that
none
of
the
workers
monitored
in
this
study
performed
continuous
light
activity,
the
use
of
the
recommended
ventilation
rate
probably
resulted
in
a
notable
over
estimation
of
exposure.
The
fact
that
values
were
generated
even
for
those
compounds
that
were
never
detected
or
quantifiable
in
field
samples
contributes
to
the
over
estimation
of
inhalation
exposures
as
well.

No
air
samplers
showed
quantifiable
levels
of
most
of
the
PNAs
monitored.
Chrysene
and
benzo(
a)
pyrene
was
not
detected
in
worker
samplers.
Pyrene
and
anthracene
were
detected
in
1
and
2
samples,
respectively.
However,
naphthalene
was
detected
by
every
sampler,
and
2­
methylnaphthalene
was
detected
in
most
samplers,
suggesting
that
only
the
lower
molecular
weight
("
low­
boiling")
PNAs
are
commonly
volatilized
during
pressure
treatment,
or
are
able
to
remain
volatile
when
exposed
to
ambient
temperatures.
These
results
suggest
that
the
highest
molecular
weight
PNAs
did
not
volatilized
during
the
treatment
process,
and
may
have
continued
to
be
emitted
from
treated
materials
during
cooling,
increasing
their
availability
for
worker
exposure.
Naphthalene
was
the
single
greatest
contributor
to
inhalation
exposure
measurement.
CTPVs
were
present
at
quantifiable
levels
in
only
one
sampler,
suggesting
that
this
class
of
compounds
may
be
a
minor
constituent
of
creosote
emissions.
Measured
aerial
concentrations
of
naphthalene
(
approximately
0.04
to
1.29
mg/
m3)
and
CTPVs
(
0.0003
to
0.0006
mg/
m3)
were
well
below
the
ACHIH
TLVs
of
52
mg/
m3
and
0.2
mg/
m3,
respectively,
for
these
materials
for
all
monitored
workers.
As
noted
for
dermal
exposure,
geometric
mean
daily
inhalation
exposure
was
greatest
in
those
worker
classes
who
performed
those
tasks
most
likely
to
put
them
in
close
proximity
to
sources
of
creosote.

The
calculated
levels
of
inhalation
exposure
to
creosote
components
by
monitored
workers
at
each
site
are
presented
in
Tables
XXVI,
XXVII,
and
XXVIII
(
pages
144
through
146)
in
the
Study
Report.
The
levels
of
each
analyte
in
the
air
sampled
during
each
monitored
work
cycle,
expressed
as

g/
m3
of
air,
are
presented
in
Table
XXIX
(
pages
147
to
149)
in
the
Study
Report.
28
7.0
REVIEW
OF
THE
STUDIES
COMPLIANCE
WITH
SERIES
875
Compliance
with
Series
875­
Occupational
and
Residential
Exposure
Test
Guidelines
of
the
Pesticide
Assessment
Guidelines
(
U.
S.
EPA,
1998)
is
critical
if
a
study
is
to
be
considered
acceptable
to
the
Agency.
Table
11
is
based
on
the
"
Checklist
for
Applicator
Monitoring
Data"
used
by
the
U.
S.
EPA/
OPP/
HED
in
reviewing
Series
studies.
This
table
is
designed
to
summarize
Series
875
guidelines,
identify
whether
the
study
addresses
these
issues,
and
is
compliant
with
these
guidelines
and
it
also
present
comments
on
how
to
bring
the
study
into
compliance.

8.0
SUMMARY
OF
DATA
GAPS
WITH
RESPECT
TO
SERIES
875
Pertinent
items
with
regard
to
scientific
validity
and
Series
875
compliance,
not
addressed
above,
are
discussed
below.
The
following
issues
were
noted:

°
The
amount
of
product
applied
and
the
amount
of
active
ingredient
handled
by
each
worker
was
not
calculated
because
the
creosote
was
applied
in
a
closed
system
which
recovered
and
retained
excess
treatment
solution
from
the
wood
and
treatment
vessel
while
sealed.

°
The
number
of
field
fortification
samples
collected
at
the
sites
were
not
enough
to
satisfy
the
Series
875
guidelines.
According
to
the
guidelines,
there
should
have
been
field
at
least
one
fortification
sample
per
worker
per
monitoring
period
(
8
hour
shift)
per
fortification
level
(
three
levels)
for
each
matrix
and
at
least
one
field
blank
per
worker
per
monitoring
period
for
each
matrix.
There
were
more
workers
monitored
than
there
were
field
fortification
and
field
blank
samples
collected.

°
There
were
some
dermal
fortification
levels
which
yielded
extremely
high
recoveries
for
WBD's
and
some
with
unacceptably
low
recoveries
for
gloves.
For
example,
at
a
60
µ
g/
sample
"
total
creosote"
fortification
for
Site
B,
there
were
recoveries
for
the
WBD's
as
high
as
150%
and
recoveries
for
the
gloves
as
low
as
52.3%.
There
were
measurable
amounts
of
total
creosote
found
in
each
of
the
control
samples
prepared
at
each
facility.
All
dermal
fortification
recoveries
above
120%
and
below
70%
should
be
considered
unacceptable
according
to
Series
875
guidelines
and
undermine
the
validity
of
the
results.

°
The
inhalation
exposure
data
was
summarized
in
the
form
of
bar
graphs
in
the
Study
Report.
However,
data
points
used
for
the
graphs
were
not
provided.
The
raw
data
was
provided
but
the
raw
data
tables
did
not
reflect
the
data
presented
in
the
bar
graphs.
Therefore,
it
was
difficult
to
validate
the
conclusions
made
in
Study
Report.

°
The
Overall
inhalation
field
fortification
percent
recoveries
for
the
coal
tar
pitch
volatiles
(
CTPVS)
were
poor.
The
overall
recovery
for
Site
B
was
57%.
The
overall
recoveries
for
Sites
C
and
D
were
51%
and
57%,
respectively.
All
inhalation
fortification
recoveries
below
70%
should
be
considered
unacceptable
according
to
Series
875
guidelines
and
undermine
the
validity
of
the
results.
29
Table
11.
Compliance
with
Series
875
FIFRA
Compliance
Checklist
Does
the
study
address
this
compliance
issue?
Does
the
study
comply
with
this
part
of
Series
875?
Comments
Prior
"
informed
consent"
must
be
obtained
in
writing
from
all
subjects
who
will
be
exposed
in
the
study.
yes
yes
Informed
consent
was
obtained
in
writing
from
each
of
the
workers
monitored
in
the
study.

All
conditions
specified
on
the
product
label
must
be
observed,
including
whatever
protective
clothing
is
specified
for
workers
to
wear.
yes
mostly
Each
worker
was
supplied
with
protective
clothing,

gloves,
respirators
as
needed.
However,
according
to
the
study,
not
all
workers
wore
the
proper
protective
gloves
while
working.

Studies
must
be
designed
so
that
an
exposure
is
measured
separately
for
each
activity
associated
with
an
application.
yes
yes
10
job
categories
were
monitored.

Data
collection
in
accordance
with
40
CFR
160,

Good
Laboratory
Practice
Standards.
yes
partly
The
creosote
used
at
each
test
site
was
analyzed
for
compliance
with
AWPA
specifications,
and
these
analyses
were
not
performed
per
FIFRA
GLPs.

Characterization
of
reference
standards
were
not
done
per
FIFRA
GLPs.
GLP­
compliant
calibration
of
creosote
storage
and
application
equipment
was
not
configured.
Corrections
to
field
data
were
not
done
per
FIFRA
GLPs.

Typical
end
use
product
of
the
active
ingredient
used.
yes
yes
The
study
identifies
3
end
use
products
used
in
this
study.
They
are
Koppers
Coal
Tar
Creosote
(
P1/
P13),
VFT
Coal
Tar
Creosote
(
P1/
P13)
Wood
Preservative,
and
Koppers
Creosote
Solution.

Labels
for
all
three
end
use
products
were
provided.

End
use
product
handled
and
applied
using
recommend
equipment,
application
rates,
and
typical
work
practices.
yes
yes
Typical
wood
treatment
process
assessed.
Table
11:
Compliance
with
Series
875
(
Continued)

FIFRA
Compliance
Checklist
Does
the
study
address
this
compliance
issue?
Does
the
study
comply
with
this
part
of
Series
875?
Comments
30
For
exposure
monitoring
at
least
five
replicates
(
e.
g,
individuals)
at
each
of
at
least
three
sites
for
each
job
function
should
be
monitored.
yes
mostly
There
were
25
workers
total
(
for
all
four
sites)

monitored
for
up
to
4
­
5
consecutive
work
days.

There
were
10
job
categories
monitored.
For
each
job
category
there
were
4
to
19
replicates
per
site.

Monitoring
period
is
sufficient
to
collect
measurable
residues
but
not
excessive
so
that
residue
loss
occurs.
yes
yes
Exposure
periods
seemed
long
enough
for
the
tasks
required.

Dermal
and/
or
inhalation
exposure
must
be
monitored
by
validated
methodologies.
Biological
monitoring
is
consistent
with
and
supported
by
pharmacokinetic
data
accepted
by
the
Agency.
yes
yes
Dermal
and
inhalation
methods
used
were
identified
in
Series
875
regulations.

Quantity
of
active
ingredient
handled
and
duration
of
monitoring
period
reported
for
each
replication
no
partly
Quantity
of
active
ingredient
handled
was
not
described.
Duration
of
exposure
was
identified
for
both
dermal
and
inhalation
exposures.

Quantitation
level
of
detection
is
at
least
1
µ
g/
cm2
not
applicable
not
applicable
Since
whole
body
dosimeters
and
inhalation
samples
were
used
this
is
not
applicable.
This
LOQ
is
used
only
for
dermal
patch
studies.

Clothing
worn
by
each
study
participant
and
location
of
dosimeters
reported.
yes
yes
Study
used
whole
body
dosimeters
(
cotton
thermal
shirts,
pants,
and
gloves).
Sections
(
gloves,
arms,

bottoms)
were
measured
appropriately.

Storage
of
samples
consistent
with
storage
stability
data.
yes
yes
Storage
of
samples
and
storage
stability
are
addressed
in
the
study
and
samples
were
corrected
when
appropriate
according
to
storage
stability
results.
Table
11:
Compliance
with
Series
875
(
Continued)

FIFRA
Compliance
Checklist
Does
the
study
address
this
compliance
issue?
Does
the
study
comply
with
this
part
of
Series
875?
Comments
31
Efficiency
of
extraction
in
laboratory
provided
as
mean
plus
or
minus
one
standard
deviation.
Lower
95
percent
confidence
limit
is
not
less
than
70
percent
based
on
a
minimum
of
seven
replications
per
fortification
level
or
prior
Agency
approval
of
extraction
methodology
provided.
yes
yes
Method
validation
testing
appeared
to
be
in
the
acceptable
range.

At
least
one
field
fortification
sample
per
worker
per
monitoring
period
per
fortification
level
for
each
matrix.
At
least
one
field
blank
per
worker
per
monitoring
period
for
each
matrix.
no
no
This
study
did
not
provide
for
at
least
one
field
fortification
sample
per
worker
monitored
per
fortification
level
for
each
matrix.
There
were
only
three
fortification
samples
per
fortification
level.

The
field
fortification
samples
were
only
prepared
once.

When
collecting
urine
for
biological
monitoring,

collection
should
involve
24
hour
urine
samples.
A
minimum
of
one
baseline,
pre­
exposure
24
hour
sample
must
be
collected.
Twenty­
four
hour
samples
must
be
collected
for
the
day
of
application
and
for
sufficient
days
postapplication
as
determined
by
the
excretion
profile
of
the
pesticide.
not
applicable
not
applicable
32
9.0
REFERENCES
1.
U.
S.
Environmental
Protection
Agency,
1995.
Occupational
and
Residential
Exposure
Test
Guidelines.
OPPTS
875.1100
Dermal
Exposure­
Outdoor.
Washington
DC.
May
1995.
EPA
712­
C­
95­
262.

2.
U.
S.
Environmental
Protection
Agency,
1995.
Occupational
and
Residential
Exposure
Test
Guidelines.
OPPTS
875.1300
Inhalation
Exposure­
Outdoor.
Washington
DC.
May
1995.
EPA
712­
C­
95­
263.

3.
U.
S.
Environmental
Protection
Agency,
1998.
Series
875­
Occupational
and
Residential
Exposure
Test
Guidelines.
Group
B­
Post­
application
Exposure
Monitoring
Test
Guidelines.
Version
5.4.
Washington
DC.
February
1998.

4.
"
The
Chemistry,
Toxicity,
and
Biodegradation
of
Creosote",
1998.
http://
inweh1.
uwaterloo.
ca/
biol447new/
assignments/
creosote.
html.

5.
U.
S.
Environmental
Protection
Agency,
1987.
Processes,
Coefficients,
and
Models
for
Stimulating
Toxic
Organics
and
Heavy
Metals
in
Surface
Waters.
Office
of
Research
and
Development.
Athens,
Georgia.
June
1987.
EPA/
600/
3­
87/
015.

6.
"
The
Environmental
Degradation
of
Creosote",
1998.
http://
inweh1.
uwaterloo.
ca/
biol447new/
assignments/
creo2.
html.

7.
James,
J.
W.,
1996.
"
Method
Validation
Study
for
the
Determination
of
Creosote
Residue
on
Cotton
Undergarments,"
EN­
CAS
Project
96­
0074,
for
the
Creosote
Council
II,
November,
1996.
