Human
Exposure
February
18,
2004
Risk
Assessment
Science
Support
Branch
U.
S.
Environmental
Protection
Agency
Office
of
Pesticide
Programs
Antimicrobials
Division
2
TABLE
OF
CONTENTS
1.0
EXECUTIVE
SUMMARY
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2
2.0
OCCUPATIONAL
EXPOSURE
AND
RISK
ASSESSMENT
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10
A.
Toxicological
Considerations
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10
(
1)
Criteria
for
Conducting
Exposure
Assessments
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10
(
2)
Summary
of
Toxicity
Concerns
Relating
to
Occupational
Exposures
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10
(
a)
Acute
Toxicology
Categories
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10
(
b)
Summary
of
Toxicological
Endpoint
Selection
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12
(
c)
Dermal
Absorption
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16
B.
Occupational
Exposures
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17
(
1)
Handler
Exposures
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17
(
a)
Occupational
Handlers
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17
(
2)
Handler
Exposure
Data
and
Assumptions
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17
(
a)
Handler
Exposure
Data
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17
(
b)
Chemical­
Specific
Handler
Exposure
Data
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18
(
3)
Handler
Risk
Assessment
and
Characterization
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28
(
a)
Handler
Exposure
and
Non­
Cancer
Risk
Calculations
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28
(
b)
Handler
Exposure
and
Cancer
Risk
Calculations
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33
(
c)
Occupational
Handler
Scenarios
with
Non­
Cancer
Dermal
Risk
Concerns
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34
(
d)
Occupational
Handler
Scenarios
with
Non­
Cancer
Inhalation
Risk
Concerns
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35
(
e)
Occupational
Handler
Scenarios
with
Cancer
Risk
Concerns
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35
(
4)
Postapplication
Exposures
and
Risks
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36
(
a)
Occupational
Postapplication
Exposure
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36
(
5)
Occupational
Postapplication
Data,
Assumptions,
Exposure,
and
Risk
Calculations
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37
(
a)
Postapplication
Data
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37
(
b)
Short­,
Intermediate­,
and
Long­
Term
Inhalation
Exposure
and
Non­
Cancer
Risks
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39
(
c)
Short­,
Intermediate­,
and
Long­
Term
Dermal
Exposure
and
Non­
Cancer
Risk
Calculations
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42
(
d)
Postapplication
Exposure
Cancer
Risk
Calculations
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42
(
6)
Occupational
Postapplication
Risk
Assessment
and
Characterization
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43
(
a)
Postapplication
Non­
Cancer
Risks
from
Dermal
Exposure
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43
(
b)
Postapplication
Non­
Cancer
Risks
from
Inhalation
Exposure
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43
(
c)
Postapplication
Dermal
and
Inhalation
Scenarios
with
Cancer
Risks
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44
(
7)
Data
Gaps,
Uncertainties,
and
Limitations
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45
(
8)
Results
Summary
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47
3
3.0
REFERENCES
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49
1.0
EXECUTIVE
SUMMARY
Background
Wood
preservative
pesticides
containing
inorganic
arsenicals
and/
or
chromium
compounds
are
registered
as
technical
source/
manufacturing­
use
products
or
industrial
end­
use
product
concentrates
to
formulate
Chromated
Copper
Arsenate
(
CCA),
Ammoniacal
Copper
Zinc
Arsenate
(
ACZA),
Ammoniacal
Copper
Arsenate
(
ACA)
and
Acid
Copper
Chromate
(
ACC)
aqueous
treatment
solutions
for
pressure
treatment
applications.

Waterborne
wood
preservatives
containing
arsenic
and/
or
chromium
in
a
mixture
with
copper
are
predominantly
formulated
as
Chromated
Copper
Arsenate
or
CCA.
Formulated
wood
preservative
products
containing
arsenic
and/
or
chromium
compounds
have
been
registered
since
the
1940'
s
when
pesticides
were
under
the
regulatory
purview
of
the
United
States
Department
of
Agriculture
(
USDA),
and
since
its'
inception
in
the
1970'
s,
regulated
under
FIFRA
with
the
U.
S.
EPA.

Presently,
products
are
registered
for
pressure
treatment
of
wood
intended
for
above
ground
and
ground
contact,
as
well
as
in
fresh
water
and
marine
environments.
Wood
treated
with
these
preservatives
are
specified
for
commercial,
institutional,
and
limited
residential/
farm
construction
uses
in
indoor
and
outdoor
sites.

All
products
are
Restricted
Use
Pesticides:
technical
grade/
manufacturing­
use
products
(
MUP's)

containing
sources
of
either
Arsenic
acid
(
2)
or
Chromic
acid
(
5);
and
16
are
industrial
end­
use
products
(
EUP's)

as
either
separate
chemical
sources
of
arsenic
(
3)
or
chromium
(
1),
or
as
chemical
mixtures
of
CCA
(
11)
or
ACC
(
1).
(
Refer
to
the
Case
Overview
section
of
this
RED
for
a
complete
profile
of
all
pesticide
active
ingredients
and
product
formulations/
use
patterns
covered
under
Reregistration
Case
0132).

.

All
non­
pressure
treatments
have
been
voluntarily
cancelled
by
the
registrants.
The
cancellation
letter
dated
May
28,
2003
removed
all
non­
pressure
treatment
arsenical
products
from
the
market:
EPA
Reg.
Nos.

3008­
21,
75341­
1
(
formerly
3008­
8),
and
75341­
7
(
formerly
3008­
68).
There
remain
no
other
arsenical
4
products
that
were
registered
for
non­
pressure
treatments.
The
ACC
label
(
EPA
Reg.
No
3008­
60)
specifically
states
"
For
Pressure
Plant
Use
Only".
The
labeling
for
component
products
used
to
make
ACZA
(
Parts
A,
B,

C
Reg.
Nos.
3098­
16,
­
17,
­
18,
respectively)
also
states
intended
use
for
pressure­
treated
wood
products.

Scope
of
Occupational
Assessment
for
Wood
Preservatives
Containing
Arsenic
and/
or
Chromium
Presented
herein
is
the
"
occupational"
exposure
and
risk
assessment
for
industrial
workers
involved
in
pressure­
treatment
applications
to
wood
using
preservatives
containing
inorganic
arsenicals
and/
or
chromium
compounds.
The
scope
of
EPA­
registered
preservative
chemicals
grouped
under
the
term
"
inorganic
arsenicals
and/
or
chromium
compounds"
includes:

°
Separate
chromium
(
Cr)
and
arsenic
(
As)
technical
source,
manufacturing­
use
products
registered
with
the
Agency
for
use
in
formulating
arsenical
and/
or
chromated
preservative
mixtures
for
wood
pressuretreatment
and
°
Registered
industrial
end­
use
product
concentrates
containing
sources
of
Cr
or
As,
or
mixtures
of
CCA
or
ACC,
intended
for
dilution
with
water
to
create
treatment
solutions
for
wood
pressure­
treatment
applications.

Note
that
certain
registered
arsenical
and/
or
chromated
preservative
products
are
mixtures
of
several
active
ingredients.
Some
active
ingredients
in
these
product
mixtures
are
not
covered
under
this
RED
for
Wood
Preservatives
Containing
Arsenic
and/
or
Chromium,
but
have
been
or
will
be
assessed
for
reregistration
eligibility
under
separate
RED
cases.
The
predominant
inorganic
arsenical
preservatives
used
by
the
wood
treatment
industry
are
mixtures
of
"
chromated
copper
arsenate"
or
more
commonly
referred
to
as
"
CCA".
CCA
preservatives
will
therefore
be
the
focus
of
the
Agency's
human
health
assessment
in
this
RED,
and
be
the
basis
for
conducting
the
occupational
exposure
and
risk
assessment
Other
registered
wood
preservatives
containing
sources
of
copper
in
combination
with
either
chromium
or
arsenic
compounds
include:
acid
copper
chromate
(
ACC),
ammoniacal
copper
arsenate
(
ACA),
and
ammoniacal
copper
zinc
arsenate
(
ACZA).

These
preservatives
are
used
for
specialized
applications
or
in
cases
where
wood
penetration
by
CCA
chemicals
can
not
be
achieved
(
e.
g.,
ACC
used
for
cooling
tower
applications,
ACA
and
ACZA
used
on
large
dimension
wood
products
made
from
hard
to
treat
wood
species
such
as
Douglas
Fir).

Cupric
Oxide,
the
form
of
copper
used
in
CCA
treatment
solutions,
is
not
included
as
an
active
ingredient
covered
under
this
RED.
Reregistration
requirements
for
Cupric
Oxide
will
be
addressed
separately
in
a
RED
document
for
Copper,
and
oxides,
Case
Number
4025,
slated
to
be
issued
at
a
future
date.
Also,
Zinc
Oxide,
the
5
zinc
component
of
ACZA,
has
already
been
assessed
by
the
Agency
for
the
wood
preservative
use
patterns
under
the
Zinc
Salts
RED,
Case
Number
4099,
dated
August,
1992.

Occupational
Exposures
to
Arsenical
and/
or
Chromated
Wood
Preservatives
The
Occupational
Exposure
Chapter
of
the
Wood
Preservatives
Containing
Arsenic
and/
or
Chromium
Re­
registration
Eligibility
Decision
Document
(
RED)
addresses
potential
exposures
and
risks
of
chromium
(
Cr)

and
arsenic
(
As)
to
humans
who
may
be
exposed
to
Chromated
Copper
Arsenate
(
CCA)
and
related
arsenicals
and
chromated
wood
preservatives
in
"
occupational
settings"
as:
(
1)
handlers
(
mixers,
loaders,
applicators)
of
CCA
and
related
pesticide
products;
and
(
2)
individuals
who
are
exposed
to
CCA
and
related
pesticides
through
postapplication
or
reentry
activities.
The
chromium
assessed
is
hexavalent.
The
trivalent
chromium
is
not
of
toxicological
significance.
Hexavalent
chromium
is
assessed
using
the
exposures
monitored
in
the
pressure
treatment
exposure
study
for
chromium
VI
coupled
with
the
toxicological
endpoints
for
chromium
VI.

The
occupational
settings
are
characterized
as
wood
treatment
plants
where
Southern
Yellow
Pine
dimensional
lumber
is
pressure
treated.
Therefore
representative
occupational
handler
exposure
scenarios
were
developed
for
treatment
plant
workers
only.

Potential
postapplication
exposures
may
occur
in
occupational
settings
such
as
wood
pressure
treatment
plants
where
treated
lumber
is
handled
for
QA/
QC
testing,
or
storage/
transport,
or
in
commercial,
institutional,

and
residential
outdoor
settings
where
the
wood
is
fabricated
into
structures
and
professionally
installed.

Occupational
postapplication
exposure
scenarios
were
developed
for
treatment
plant
workers
only,
since
it
is
anticipated
that
handling
freshly­
treated
wood
and
performing
postapplication
work
tasks
in
treatment
areas
constitutes
postapplication
scenarios
with
the
potential
for
maximum
exposures.
6
The
pressure
treatment
exposure
scenarios
developed
for
this
RED
Chapter
are
representative
of
potential
occupational
exposures
to
inorganic
arsenical
preservatives
over
short­
term
(
1
day
to
1
month),

intermediate­
term
(
1­
6
months),
and
long­
term
(
>
6
months)
exposure
durations.

Occupational
Handlers
Non­
cancer
and
cancer
dermal
and
inhalation
exposures
were
assessed
separately
for
arsenic
and
chromium
VI
for
pressure
treatment
scenarios.
The
Margins
of
Exposure
(
MOEs)
for
all
occupational
handler
scenarios
evaluated
are
presented
in
Table
15
of
this
report.

Dermal
Exposure:
Non­
Cancer
Arsenic:
All
the
scenarios
that
exceed
the
Agency's
level
of
concern
for
dermal
non­
cancer
exposure
for
arsenic
are
presented
below.
The
Agency's
level
of
concern
for
arsenic
from
dermal
exposure
is
as
follows:

short­
term
and
intermediate­
term
(
MOEs
<
30)
and
long­
term
(
MOEs
<
3).

Short­
Term
and
Intermediate­
Term
°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)]
(
MOE
of
concern;
MOE
=

16);

Long­
Term
°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)
and
treatment
assistant
(
TA)]
(
MOE
of
concern;
MOEs
=
0.3
for
TO,
and
0.8
for
TA);

Chromium
VI:
Since
dermal
irritation
and
dermal
sensitization
are
the
primary
exposure
concerns
through
the
dermal
route,
no
toxicological
endpoint
was
selected
for
use
in
assessing
dermal
exposure
risks
to
chromium
VI.
Risk
mitigation
will
continue
to
be
addressed
through
appropriate
precautionary
labeling
statements.

Inhalation
Exposure:
Non­
Cancer
7
Arsenic:
The
MOE's
for
the
inhalation
exposure
scenarios
presented
in
the
risk
assessment
do
not
exceed
the
Agency's
level
of
concern
for
short­,
intermediate­,
and
long­
term
exposures
to
arsenic.
8
Chromium
VI:
The
MOE's
for
the
inhalation
exposure
scenarios
that
exceed
the
Agency's
level
of
concern
(
i.
e.
MOEs
<
100)
for
short­
term,
intermediate­
term,
and
long­
term
inhalation
exposures
to
chromium
VI
are
presented
below.
Trivalent
chromium
is
not
of
toxicological
significance
and
is
therefore
not
assessed.
Chromium
VI
risks
are
based
on
the
registrant's
exposure
study
for
pressure
treatment
workers
(
note:
all
inhalation
samples
were
non
detect
and
½
LOD
was
used
in
assessing
the
risks).

Short­
Term,
Intermediate­
Term,
and
Long­
Term
°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)
and
treatment
assistant
(
TA)]
(
MOEs
of
concern,
MOEs
=
7
for
TO
and
TA
based
on
½
LOD);

Dermal
and
Inhalation
Exposure:
Cancer
Carcinogenic
endpoints
related
to
lifetime
dermal
and
inhalation
exposures
to
arsenic,
and
inhalation
exposure
to
chromium
VI
have
been
identified.
In
general,
the
Agency
is
concerned
when
occupational
cancer
risk
estimates
exceed
1
x
10­
4
(
E­
4)
.
The
Agency
will
seek
ways
to
mitigate
the
risks,
to
the
extent
that
it
is
practical
and
economically
feasible,
to
lower
the
risks
to
1
x
10­
6
(
E­
6)
or
less.
The
following
handler
scenarios
have
cancer
risks
between
1
x
10­
5
(
E­
5)
and
1
x
10­
2
(
E­
2)
at
the
assessed
level
of
mitigation.
Cancer
risks
for
each
scenario
are
presented
in
Table
16.

Arsenic:

Lifetime
Dermal
Cancer
Risk
(
>
E­
4
)

°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)
and
treatment
assistant
(
TA)]
(
risks
of
concern
=
4.1E­
3
for
TO,
and
1.4E­
3
for
TA
);
and
Lifetime
Inhalation
Cancer
Risk
(
>
E­
4
)

°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)
and
treatment
assistant
(
TA)]
(
risks
of
concern
=
2.0E­
4
for
TO,
and
1.2E­
4
for
TA);
and
Chromium
VI:

Lifetime
Inhalation
Cancer
Risk
(
>
E­
4
)

°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)
and
treatment
assistant
(
TA)]
(
risks
of
concern
using
½
LOD
as
all
samples
were
non
detect=
1.7E­
4
for
TO,
and
1.6E­
4
for
TA);
and
9
Occupational
Postapplication
Exposure
Non­
cancer
and
cancer
dermal
and
inhalation
postapplication
exposures
were
assessed
separately
for
arsenic
and
chromium
VI
for
pressure
treatment
scenarios.
Wood
treatment
plant
postapplication
job
functions
as
per
the
ACC
worker
exposure
study
(
MRID
455021­
01)
were
relied
upon
to
develop
the
postapplication
scenarios.
The
Margins
of
Exposure
(
MOEs)
for
all
occupational
postapplication
scenarios
evaluated
are
presented
in
Table
21
of
this
report.

Dermal
Exposure:
Non­
Cancer
Arsenic:
Acute,
subchronic,
and
chronic
toxicity
endpoints
related
to
dermal
exposures
to
arsenic
have
been
identified.
The
Agency's
level
of
concern
for
arsenic
from
dermal
exposure
is
as
follows:
short­
term
and
intermediate­
term
(
MOEs
<
30)
and
long­
term
(
MOEs
<
3).
All
the
scenarios
that
exceed
the
Agency's
level
of
concern
for
dermal
non­
cancer
exposure
for
arsenic
are
presented
below.

Short­
Term
and
Intermediate­
Term
°
Loader
Operator
(
MOE
of
concern,
MOEs
=
21);
°
Tram
Setter
(
MOE
of
concern,
MOEs
=
8);
°
Supervisor
(
MOE
of
concern,
MOEs
=
16);
°
Tally
Man
(
MOE
of
concern,
MOEs
=
18);
and,
°
Test
Borer
(
MOE
of
concern,
MOEs=
27).

Long­
Term
°
Loader
Operator
(
MOE
of
concern,
MOE
=
0.3);
°
Test
Borer
(
MOE
of
concern,
MOE
=
4);
°
Tram
Setter
(
MOE
of
concern,
MOE
=
0.1);
°
Supervisor
(
MOE
of
concern,
MOE
=
0.3);
°
Tally
Man
(
MOE
of
concern,
MOE
=
0.3);
and,
°
Stacker
Operator
(
MOE
of
concern,
MOE
=
0.6).

Chromium
VI:
Since
dermal
irritation
and
dermal
sensitization
are
the
primary
exposure
concerns
through
the
dermal
route,
no
toxicological
endpoint
was
selected
for
use
in
assessing
dermal
postapplication
exposure
risks
to
chromium
VI.
Risk
mitigation
will
continue
to
be
addressed
through
appropriate
precautionary
labeling
statements.

Inhalation
Exposure:
Non­
Cancer
Arsenic:
Acute,
sub­
chronic,
and
chronic
toxicity
endpoints
related
to
inhalation
exposures
to
arsenic
have
been
identified.
The
Agency's
level
of
concern
for
arsenic
from
inhalation
exposure
is
as
follows:
shortterm
and
intermediate­
term
(
MOEs
<
100)
and
long­
term
(
MOEs
<
3).
The
MOEs
for
the
inhalation
exposure
scenarios
presented
in
the
risk
assessment
do
not
exceed
the
Agency's
level
of
concern.
10
Chromium
VI:
The
MOEs
for
the
inhalation
exposure
scenarios
presented
in
the
risk
assessment
exceed
the
Agency's
level
of
concern
for
short­
term,
intermediate­
term,
and
long­
term
inhalation
exposures
to
chromium
VI
(
i.
e.,
MOEs
<
100)
based
on
the
toxicological
information
for
Chromium
(
VI).
Even
though
all
inhalation
samples
were
below
the
detection
limit,
inhalation
MOEs
are
exceeded
for
all
postapplication
exposure
scenarios
as
follows:

Short­
Term,
Intermediate­
Term,
and
Long­
Term
°
Loader
Operator
(
MOE
of
concern,
MOE
=
6);
°
Test
Borer
(
scenario
not
assessed
for
chromium);
°
Tram
Setter
(
MOE
of
concern,
MOE
=
6);
°
Supervisor
(
MOE
of
concern,
MOE
=
6);
°
Tally
Man
(
scenario
not
assessed
for
chromium);
and,
°
Stacker
Operator
(
MOE
of
concern,
MOE
=
6).

Dermal
and
Inhalation
Exposure:
Cancer
Carcinogenic
endpoints
related
to
lifetime
dermal
and
inhalation
exposures
to
arsenic,
and
inhalation
exposure
to
chromium
VI
have
been
identified.
In
general,
the
Agency
is
concerned
when
occupational
cancer
risk
estimates
exceed
1
x
10­
4
(
E­
4)
.
The
Agency
will
seek
ways
to
mitigate
the
risks,
to
the
extent
that
it
is
practical
and
economically
feasible,
to
lower
the
risks
to
1
x
10­
6
(
E­
6)
or
less.
The
following
worker
scenarios
have
cancer
risks
between
1
x
10­
5
(
E­
5)
and
1
x
10­
2
(
E­
2)
at
the
assessed
level
of
mitigation.
Occupational
postapplication
cancer
risks
for
each
scenario
are
presented
in
Table
21.

Arsenic:

Lifetime
Dermal
Cancer
Risk
(
>
E­
4
)

°
Loader
Operator
(
risk
of
concern
=
3.3E­
3
);
°
Test
Borer
(
risk
of
concern
=
2.5E­
4);
°
Tram
Setter
(
risk
of
concern
=
8.4E­
3);
°
Supervisor
(
risk
of
concern
=
4.1E­
3);
°
Tally
Man
(
risk
of
concern
=
3.8E­
3);
and,
°
Stacker
Operator
(
risk
of
concern
=
1.8E­
3).
11
Lifetime
Inhalation
Cancer
Risk
(
>
E­
4
)

°
Loader
Operator
(
risk
of
concern
=
1.6E­
4
);
°
Test
Borer
(
risk
of
concern
=
6.3E­
5
);
°
Tram
Setter
(
risk
of
concern
=
4.7E­
4);
°
Supervisor
(
risk
of
concern
=
2.8E­
4);
°
Tally
Man
(
risk
of
concern
=
8.0E­
5);
and,
°
Stacker
Operator
(
risk
of
concern
=
6.0E­
5).

Chromium
VI:

Lifetime
Inhalation
Cancer
Risk
(
>
E­
4
)

°
Loader
Operator
(
risk
of
concern
=
2.0E­
4
);
°
Test
Borer
(
scenario
not
assessed
for
chromium
);
°
Tram
Setter
(
risk
of
concern
=
2.0E­
4);
°
Supervisor
(
risk
of
concern=
2.1E­
4).
°
Tally
Man
(
scenario
not
assessed
for
chromium);
and,
°
Stacker
Operator
(
risk
of
concern
=
1.6E­
4).

Occupational
Risk
Characterization
Summary
The
exposure
and
risk
assessment
conducted
for
occupational
populations
involved
with
pressure
treatments
using
inorganic
arsenicals
indicated
the
following:

°
Occupational
handlers
of
registered
inorganic
arsenical
pesticides
for
pressure
treatments
are
best
protected
under
conditions
where
appropriate
dermal
and
inhalation
personal
protective
equipment
(
PPE)
is
worn.

°
Handler
exposure
estimates
based
on
chemical­
specific
monitoring
data
collected
for
pressure
treatment
workers
indicate
that
additional
risk
mitigation
is
warranted
especially
for
individuals
directly
involved
with
work
tasks
requiring
contact
with
the
treatment
cylinder/
retort
(
i.
e.,
treatment
operator/
treatment
assistant).

°
Postapplication
exposures
are
a
concern
for
industrial
workers
in
wood
pressure
treatment
plants
across
most
all
postapplication
scenarios
assessed
(
dermal
exposure
concerns
for
arsenic
and
inhalation
concerns
for
chromium
VI)
based
on
chemical­
specific
monitoring
data
collected
for
pressure
treatment
workers.
Additional
risk
mitigation
is
warranted
during
postapplication
work
tasks
involving
contact
with
treatment
equipment
and
treated
wood.

°
The
risks
presented
for
hexavalent
chromium
are
based
on
inhalation
samples
that
were
all
non
detect.
The
risks
are
estimated
using
½
the
limit
of
detection
(
LOD).
A
lower
detection
limit
is
needed
based
on
the
sensitivity
of
the
toxicological
endpoints
for
chromium
VI.
12
2.0
OCCUPATIONAL
EXPOSURE
AND
RISK
ASSESSMENT
A.
Toxicological
Considerations
(
1)
Criteria
for
Conducting
Exposure
Assessments
An
occupational
exposure
and
risk
assessment
is
required
for
an
active
ingredient
if
(
1)
certain
toxicological
criteria
are
triggered
and
(
2)
there
is
potential
exposure
to
handlers
(
e.
g.,
mixers,
loaders,
applicators,
etc.)
during
pesticide
product
use,
or
during
postapplication:
to
persons
entering
treated
sites
after
application
is
complete,
or
when
exposures
are
anticipated
from
handling
pesticide­
treated
articles.
For
the
Inorganic
Arsenical
Wood
Preservatives
containing
arsenic
and
chromium
as
active
ingredients,
both
criteria
are
met.

(
2)
Summary
of
Toxicity
Concerns
Relating
to
Occupational
Exposures
(
a)
Acute
Toxicology
Categories
The
toxicological
data
base
for
the
arsenic
and
chromium
compounds
found
in
inorganic
arsenicals
is
adequate
and
will
support
re­
registration
eligibility
for
CCA
and
related
wood
preservative
pesticides.
Toxicity
categories
for
Arsenic
(
V)
are
shown
in
Table
1a.
Toxicity
categories
for
Chromium
(
VI)
are
shown
in
Table
1b.
Tables
1a
and
1b
summarize
these
toxicity
findings
of
OPP's
HIARC
Reports
(
U.
S.
EPA,
2002).
13
Table
1a.
Acute
Toxicity
Summary
of
Arsenic
Acid
(
75%)

Guideline
Reference
No.
Study
Type
MRID/
Data
Accession
No.
Results
Toxicity
Category
81­
1
(
OPPTS
870.1100)
Acute
Oral
404090­
01
Mouse
LD50
=

141
mg/
kg
=

160
mg/
kg
M+
F
=
150
mg/
kg
II
26356
Rat
LD50
=

76
mg/
kg
=

37
mg/
kg
M+
F
=
52
mg/
kg
I
81­
2
(
OPPTS
870.1200)
Acute
Dermal
26356
Rabbit
LD50
=

1750
mg/
kg
=

2300
mg/
kg
II
81­
3
(
OPPTS
870.1300)
Acute
Inhalation
404639­
02
Mouse
LC50
=

1.153
mg/
L
=

0.79
mg/
L
M+
F
=
1.040
mg/
L
II
81­
4
(
OPPTS
870.2400)
Primary
Eye
Irritation
26356
Rabbit
3/
6
animals
died
by
day
7.
The
3
surviving
animals
were
sacrificed
on
day
9
because
of
severe
ocular
irritation
and
corrosion.
I
81­
5
(
OPPTS
870.2500)
Primary
Skin
Irritation
26356
Rabbit
At
30
minutes,
all
animals
showed
moderate
to
severe
erythema
and
slight
to
severe
edema.
All
animals
died
prior
to
the
24
hour
observation.
I
81­
6
(
OPPTS
870.2600)
Dermal
Sensitization
406462­
01
Guinea
Pig
Not
a
Sensitizer
14
Table
1b.
Acute
Toxicity
Summary
of
Cr(
VI)

Guideline
Reference
No.
Study
Type
[
Substance]
MRID/
Literature
Results
Toxicity
Category
81­
1
(
OPPTS
870.1100)
Acute
Oral/
Rat
[
Chromic
Acid,
100%
a.
i.]
434294­
01
LD50
=

56
mg/
kg
=

48
mg/
kg
M+
F
=
52
mg/
kg
I
81­
2
(
OPPTS
870.1200)
Acute
Dermal/
Rabbit
[
Chromic
Acid,
100%
a.
i.]
434294­
02
LD50
=

>
48
mg/
kg
=

48
mg/
kg
M+
F
=
57
mg/
kg
I
81­
3
(
OPPTS
870.1300)
Acute
Inhalation/
Rat
[
Chromic
Acid,
100%
a.
i.]
434294­
03
LC50
=

0.263
mg/
L
=

0.167
mg/
L
M+
F
=
0.217
mg/
L
I
81­
4
(
OPPTS
870.2400)
Primary
Eye
Irritation
[
Various
Cr(
VI)
compounds]
Literature
Waiver
Corrosive
I
81­
5
(
OPPTS
870.2500)
Primary
Dermal
Irritation
[
Various
Cr(
VI)
compounds]
Literature
Waiver
Corrosive
I
81­
6
(
OPPTS
870.2600)
Dermal
Sensitization
/
Guinea
Pig
[
Various
Cr(
VI)
compounds]
Literature
Strong
sensitizer
(
b)
Summary
of
Toxicological
Endpoint
Selection
The
OPP
Hazard
Identification
Assessment
Review
Committee
(
HIARC)
reports
for
Arsenic
and
Chromium,
both
dated
April
15,
2002,
indicate
that
there
are
toxicological
endpoints
of
concern
for
arsenic
as
As
(
V)
and
chromium
as
Cr
(
VI)
(
U.
S.
EPA,
2002).
Dermal
and
inhalation
endpoints
of
concern
have
been
identified
for
characterizing
short­
term,
intermediate­
term,
and
long­
term
exposures
for
arsenic
and
chromium
VI.
15
Arsenic
The
lowest­
observed­
adverse­
effect
level
(
LOAEL)
selected
for
short­
and
intermediate­
term
dermal
exposures
for
arsenic
(
0.05
mg/
kg/
day)
is
based
on
toxic
effects
including
edema
of
the
face;
gastrointestinal,
upper
respiratory,
skin,
peripheral
and
neuropathy
symptoms.
The
LOAEL
comes
from
the
work
of
Franzblau
et
al.
(
1989)
and
Mizuta
et
al.
(
1956)
who
examined
oral
exposure
to
individuals
exposed
during
a
reported
poisoning
incident
involving
the
presence
of
arsenic
[
probably
calcium
arsenate]
contained
in
soy­
sauce.
The
NOAEL
(
0.0008
mg/
kg/
day)
selected
for
long­
term
dermal
exposures
for
arsenic
was
based
on
toxic
effects
from
an
oral
epidemiology
study
performed
by
Tseng
et
al.
(
1968)
and
Tseng
(
1977).
Each
endpoint
was
established
using
an
oral
toxicity
study.
Therefore,
for
purposes
of
the
risk
assessment,
a
dermal
absorption
factor
of
6.4
percent
may
be
needed
to
correct
the
oral
dose
to
a
dermal
dose.
For
short­,
intermediate­
and
long­
term
endpoints,
the
body
weight
of
an
adult
male
(
70
kg)
was
used
to
assess
intermediate­
and
long­
term
dermal
handler
and
postapplication
risks.
The
HIARC
report
recommended
a
margin
of
exposure
(
MOE)
of
30
for
the
short­
and
intermediate­
term
dermal
risk
(
10x
intraspecies
variation
and
3x
for
the
use
of
the
LOAEL),
and
an
MOE
of
3
for
the
long­
term
dermal
risk
(
Table
2a)
(
3x
rather
than
10x
because
of
the
large
sample
size
(>
40,000)).

Short­,
intermediate­,
and
long­
term
endpoints
were
not
identified
in
the
HIARC
report
for
inhalation
exposures
to
arsenic.
Since
no
inhalation
studies
are
available,
committee
selected
the
same
studies
and
uncertainty
factors
as
for
the
dermal
risk
assessments.
Since
the
dose
identified
for
inhalation
risk
assessments
are
from
oral
studies,
route­
to­
route
extrapolation
should
be
as
follows:

Step
I:
The
inhalation
exposure
component
(
i.
e.,
µ
g
a.
i./
day)
using
a
100%
(
default)
absorption
rate
and
application
rate
should
be
converted
to
an
equivalent
oral
dose
(
mg/
kg/
day);

Step
II:
The
dermal
exposure
component
(
i.
e.,
mg/
kg/
day)
using
6.4
%
absorption
factor
and
application
rate
should
be
converted
to
an
equivalent
oral
dose.
The
dose
should
be
combined
with
the
converted
oral
dose
in
Step
I.

Step
III:
To
calculate
the
MOE's,
the
combined
dose
from
Step
I
and
II
should
then
be
compared
to
the
oral
LOAEL
of
0.05
mg/
kg/
day
for
short
and
intermediate
term
exposure
and
the
oral
NOAEL
of
0.0008
mg/
kg/
day
for
long­
term
exposure.

The
cancer
endpoint
from
oral
exposure
is
classified
as
group
A
(
known
human
carcinogen)
with
a
cancer
slope
factor
of
3.67
(
mg/
kg/
day)­
1
(
Table
2a).
The
inhalation
unit
risk
(
IUR)
for
a
continuous
24­
hour
exposure
is
4.3
x
10­
3
(

g/
m3)­
1
which
is
equivalent
to
a
cancer
slope
factor
of
15.1
(
mg/
kg/
day)­
1
for
the
general
population.
To
assess
inhalation
cancer
risks
from
an
8­
hour
work
day,
the
24­
hour
derived
CSF
is
adjusted
to
an
8­
hour
exposure
representing
a
typical
work
day
(
i.
e.,
24­
hour
CSF
x
(
8­
hr/
24­
hr)).
16
Table
2a.
Toxicological
Endpoints
for
Assessing
Occupational
Exposures/
Risks
to
Arsenic
(
V)

EXPOSURE
SCENARIO
DOSE
(
mg/
kg/
day)
ENDPOINT
STUDY
Acute
Dietary
This
risk
assessment
is
not
required.

Chronic
Dietary
This
risk
assessment
is
not
required.

Incidental
Short­
and
Intermediate­
Term
Oral
LOAEL=
0.05
MOE
=
30
Based
on
edema
of
the
face,
gastrointestinal,
upper
respiratory,
skin,
peripheral
and
neuropathy
symptoms
Franzblau
et
al.(
1989)
and
Mizuta
et
al.
(
1956)

Dermal
Short­
and
Intermediate­
Term
(
a)
(
b)
LOAEL=
0.05
MOE
=
30
Based
on
edema
of
the
face,
gastrointestinal,
upper
respiratory,
skin,
peripheral
and
neuropathy
symptoms
Franzblau
et
al.(
1989)
and
Mizuta
et
al.
(
1956)

Dermal
Long­
Term
(
a)
(
b)
NOAEL=
0.0008
MOE
=
3
Based
on
hyperpigmentation,
keratosis
and
possible
vascular
complications.
Tseng
et
al.
(
1968)
and
Tseng
(
1977)

Inhalation
Short­
and
Intermediate­
Term(
c)
LOAEL=
0.05
MOE
=
30
Based
on
edema
of
the
face,
gastrointestinal,
upper
respiratory,
skin,
peripheral
and
neuropathy
symptoms
Franzblau
et
al.(
1989)
and
Mizuta
et
al.
(
1956)

Inhalation,
Long­
Term
NOAEL=
0.0008
MOE
=
3
Based
on
hyperpigmentation,
keratosis
and
possible
vascular
complications.
Tseng
et
al.
(
1968)
and
Tseng
(
1977)

Carcinogenicity
­
Inhalation
(
Inhalation
Risk)
CSF=
15.1
(
d)
(
mg/
kg/
day)­
1
(
For
general
Population)
Lung
cancer
Chronic
epidemiological
inhalation
study
on
humans
CSF=
5.0
(
e)
(
mg/
kg/
day)­
1
(
For
8
hour
working
day)

Carcinogenicity
­
Oral
Ingestion
(
Oral
and
Dermal
Risks)
CSF
=
3.67
(
f)
(
mg/
kg/
day)­
1
Internal
organ
cancer
(
liver,
kidney,
lung
and
bladder)
and
skin
cancer
Chronic
epidemiological
oral
study
on
humans
Note:
(
a).
MOE
=
Margin
of
Exposure;
NOAEL
=
No
observed
adverse
effect
level;
and
LOAEL
=
Lowest
observed
adverse
effect
level.
(
b).
The
dermal
absorption
factor
=
6.4%.
(
Note:
The
FIFRA
Scientific
Advisory
Panel
recommended
use
of
a
lower
value
of
2­
3%.
The
occupational
assessment
in
the
risk
assessment
uses
6.4
percent
dermal
absorption
because
the
handlers
and
workers
are
exposed
to
the
arsenic
residue
from
the
aqueous
solution
during
mixing,
loading,
and
handling
or
are
exposed
to
newly
treated,
or
"
wet'
wood
which
has
arsenic
residues
on
the
surface
of
the
wood).
(
c).
For
inhalation
exposure,
a
default
absorption
factor
of
100%
is
used.
Route­
to­
route
extrapolation
is
used
to
estimate
the
exposed
dose.
(
d).
Inhalation
unit
risk
(
IUR)
is
derived
from
a
24
hour
exposure
inhalation
unit
risk
with
a
value
of
4.3
x
10­
3
(
µ
g/
m3)­
1.
To
convert
the
IUR
to
a
cancer
slope
factor
in
units
of
(
mg/
kg/
day)
­
1
for
the
general
population
=
IUR
(
µ
g/
m3)­
1
x
1/
70
kg
x
20
m3/
day
x
1
mg/
1,000
µ
g
(
EPA,
1989).
(
e).
For
workers
working
8
hour
per
day,
the
inhalation
cancer
slope
factor
(
CSF)
derived
from
the
24
hour
IUR
for
general
population,
is
adjusted
for
an
8
hour
work
day.
CSF
for
8­
hr
work
day
=
general
population
CSF
of
15.1
(
mg/
kg/
day)­
1
x
(
8hrs/
24
hrs)
=
5.0
(
mg/
kg/
day)­
1.
(
f).
CSF
is
derived
from
the
risk
assessment
associated
with
inorganic
in
drinking
water
are
presented
in
2000.
The
2001
National
Research
Council
(
NRC)
update
made
specific
recommendation
with
respect
to
the
overall
cancer
risk
estimates.
The
Agency
is
currently
considering
these
recommendations
and
their
potential
impact
on
the
cancer
potency
estimate.
Based
on
the
Agency's
considerations
of
these
recommendations,
the
current
proposed
cancer
potency
number
may
change
in
the
final
version
of
this
risk
assessment.
17
Chromium
VI
Hexavalent
chromium,
or
Cr(
VI),
is
a
strong
skin
irritant.
In
addition,
Cr(
VI)
is
a
strong
skin
allergen.
The
potent
skin
allergenicity
of
chromium(
VI)
has
been
well
documented
in
the
literature,
and
chromium(
VI)
compounds
have
been
reported
to
be
the
most
frequent
sensitizing
agent
in
man.
Most
of
the
occurrences
of
contact
dermatitis
cited
are
the
results
of
occupational
exposures.
For
previously
sensitized
individuals,
very
low
dosage
of
Cr(
VI)
can
elicit
allergic
contact
dermatitis.
In
addition,
a
variety
of
animal
models
including
guinea
pigs
and
mice
have
conclusively
demonstrated
that
hexavalent
chromium
is
a
potent
skin
sensitizer.
Therefore,
the
Committee
concluded
that
the
skin
irritation
and
the
skin
allergenicity
effects
are
the
primary
concern
for
Cr(
VI)
through
the
dermal
exposure
route.
No
end
point
will
be
selected
for
risk
assessment.
The
risk
concern
of
the
dermal
contact
of
Cr(
VI)
should
be
addressed
through
precautionary
labeling
statements.

Consistent
with
Agency
practice,
the
endpoint
for
the
inhalation
risk
assessment
is
taken
from
the
1998
IRIS
update
for
chromium
VI
and
applies
to
all
durations
of
inhalation
exposure.
The
epidemiological
study
of
workers
in
the
chrome
plating
industry
by
Linberg
and
Hedenstierna,
1983
was
selected
for
the
LOAEL.
The
authors
concluded
that
8
hour
exposure
to
chromic
acid
above
the
LOAEL
value
of
0.002
mg/
m3
can
be
identified
for
incidence
of
nasal
septum
atrophy
following
exposure
to
chromic
acid
mists
in
chrome
plating
facilities.
At
TWA
exposures
greater
than
0.002
mg/
m3,
nasal
septum
ulcerations
and
perforations
occurred
in
addition
to
the
atrophy
reported
at
lower
concentrations.
A
LOAEL
of
0.002
mg/
m3
is
based
on
an
8
hour
TWA
occupational
exposure.
No
one
exposed
to
levels
below
0.001
mg/
m3
complained
of
subjective
symptoms.

The
ambient
air
concentration
of
0.002
mg/
m3
was
then
converted
to
a
dose
in
units
of
mg/
kg/
day
for
comparison
with
inhalation
doses
estimated
in
this
exposure
assessment.
Therefore,
the
air
concentration
in
the
epidemiological
study
was
multiplied
by
an
inhalation
rate
of
8
m3/
workday
(
light
activity
of
16.7
L/
min
or
1
m3/
hour)
and
divided
by
a
body
weight
of
70
kg
to
arrive
at
a
LOAEL
of
2.3
x
10­
4
mg/
kg/
day.
The
EPA
recommended
target
MOE
of
100
is
used
for
this
risk
assessment
for
all
durations
(
i.
e.,
10x
intra
variability
for
human
study,
3x
for
lack
of
a
NOAEL,
and
3x
modifying
factor
for
epidemiological
study
and
to
convert
to
a
long­
term
or
"
lifetime"
duration).

The
cancer
endpoint
for
inhalation
exposure
is
classified
as
group
A
(
known
human
carcinogen)
with
an
24­
hour
continuous
inhalation
unit
risk
(
IUR)
of
1.2x10­
2
(

g/
m3)­
1
(
Table
2b).
The
24­
hour
inhalation
unit
risk
was
adjusted
for
an
8­
hour
work
day
for
assessing
cancer
risks
to
workers
(
i.
e.,
adjustment
is
8­
hr
work
day
/
24­
hr
day).
Human
carcinogenicity
by
the
oral
route
of
exposure
cannot
be
determined
and
chromium
is
classified
as
group
D.
18
Table
2b.
Toxicological
Endpoints
for
Assessing
Occupational
Exposures/
Risks
to
Chromium
(
VI)

EXPOSURE
SCENARIO
DOSE
(
mg/
kg/
day)
ENDPOINT
STUDY
Acute
Dietary
This
risk
assessment
is
not
required.

Chronic
Dietary
This
risk
assessment
is
not
required.

Incidental
Shortand
Intermediate­
Term
Oral
(
a)
NOAEL=
0.5of
chromic
acid
[
0.12
of
Cr(
VI)]

MOE
=
100
based
on
the
increased
incidence
of
maternal
mortality
and
decreased
body
weight
gain
at
LOAEL
of
2.0
[
0.48
of
Cr
(
VI)]
Developmental/
Rabbit
Tyl,
1991
Dermal
Exposure
(
b)

(
All
Durations)
Because
dermal
irritation
and
dermal
sensitization
are
the
primary
concern
through
the
dermal
exposure
route,
no
toxicological
end­
point
is
selected
for
use
in
assessing
dermal
exposure
risks
to
chromium.

Inhalation
Exposure
(
All
Durations)
(
a)
LOAEL=
0.002
mg/
m3;
(
or
2.3
x
10­
4
mg/
kg/
day)
MOE
=
100
nose
and
throat
symptoms
observed
at
the
0.002
mg/
m3
level
Linberg
and
Hedenstierna,
1983.

Carcinogenicity
­
Inhalation
(
Inhalation
Risk)
CSF=
40.6
(
c)(
mg/
kg/
day)­
1
(
For
general
Population)
Lung
tumors
IRIS
CSF=
13.5
(
d)(
mg/
kg/
day)­
1
(
For
8
hour
working
day)

Note:
(
a).
MOE
=
Margin
of
Exposure;
NOAEL
=
No
observed
adverse
effect
level;
and
LOAEL
=
Lowest
observed
adverse
effect
level.
(
b).
The
dermal
absorption
factor
for
Cr(
VI)
=
1.3%
for
handler
dermal
contact
with
chromated
arsenical
pesticides.
(
c)
The
24
hours
inhalation
unit
risk
is
1.16
x
10­
2
(
µ
g/
m3)­
1
which
can
also
be
expressed
as
0.0116
m3/

g.
To
convert
the
air
concentration
to
a
dose
to
yield
units
of
kg­
day/
mg
or
(
mg/
kg/
day)­
1
the
unit
risk
is
expressed
mathematically
as
0.0116
m3/

g
x
day/
20
m3
x
1000

g/
mg
x
70
kg
=
40.6
(
mg/
kg/
day)­
1
(
EPA,
1989).
(
d)
For
workers
working
8
hour
per
day,
the
inhalation
cancer
slope
factor
(
CSF)
derived
from
the
24
hour
CSF
for
the
general
population,
is
adjusted
for
an
8
hour
work
day
.
CSF
for
8­
hr
work
day
=
general
population
CSF
of
40.6
(
mg/
kg/
day)­
1
x
(
8hrs/
24
hrs)
=
13.5
(
mg/
kg/
day)­
1.

(
c)
Dermal
Absorption
Arsenic:
For
arsenic
(
V),
the
short­,
intermediate­,
and
long­
term
dermal
and
oral
cancer
endpoints
are
based
on
toxicity
endpoints
from
oral
studies.
A
dermal
absorption
rate
of
6.4
percent
was
applied
to
oral
exposure
estimates
to
establish
risks
reflective
of
a
dermal
endpoint,
as
recommended
in
the
HIARC
report.
(
It
should
be
noted
that
in
Agency
discussions
held
with
the
FIFRA
Scientific
Advisory
Panel
on
October
23­
25,
2001,
the
panel
recommended
use
of
a
lower
value
of
2­
3
percent.
However,
the
occupational
assessment
in
the
PRA
uses
6.4
percent
dermal
absorption
because
the
handlers
and
workers
are
exposed
to
the
arsenic
residue
from
the
aqueous
solution
during
mixing,
loading,
and
handling
or
are
exposed
to
newly
treated,
or
"
wet'
wood
which
has
arsenic
residues
on
the
surface
of
the
wood
)

Chromium
VI:
A
dermal
exposure
risk
assessment
was
not
conducted
for
chromium
due
to
the
lack
of
toxicological
endpoint
selection.
However,
dermal
absorption
factors
were
established
(
U.
S.
EPA,
2002).
A
19
dermal
absorption
value
for
chromium
(
VI)
of
1.3
percent
is
to
be
used
for
handler
dermal
contact
with
chromated
arsenical
wood
preservative
pesticides.
CCA­
treated
wood
contains
mainly
Cr
(
III)
after
fixation
has
occurred.

B.
Occupational
Exposures
(
1)
Handler
Exposures
EPA
has
determined
that
there
are
potential
exposures
to
mixers,
loaders,
applicators,
and
other
handlers
during
typical
use­
patterns
associated
with
CCA
and
related
pesticides.
The
inorganic
arsenicals
(
CCA)
are
restricted­
use
chemicals
which
can
only
be
applied
by
certified
applicators,
primarily
in
commercial
and
industrial
settings
for
pressure
wood
preservative
treatments.

(
a)
Occupational
Handlers
One
scenario
was
developed
to
best
represent
the
pressure
treatment
use
pattern.
A
brief
description
of
the
scenario
that
describes
exposure
to
occupational
handlers
is
presented
in
Table
3.

(
2)
Handler
Exposure
Data
and
Assumptions
(
a)
Handler
Exposure
Data
In
the
course
of
the
occupational
exposure
chapter
development
for
this
RED,
chemical­
specific
handler
data
submitted
by
industry
and
identified
from
pertinent
literature
sources
were
reviewed
for
use
in
developing
exposure
estimates
for
worker
populations.
Certain
studies
are
presented
in
this
section
as
an
overview
of
the
available
data,
yet
only
data
from
the
ACC
Worker
Exposure
Study
(
MRID
455021­
01)
(
ACC,
2001)
were
used
in
developing
appropriate
occupational
scenarios
for
wood
treatment
plant
workers
involved
with
pressure
treatments.
20
Table
3.
Exposure
Scenarios
for
Occupational
Handlers
Exposure
Scenarios
Scenario
Descriptions
Data
Source
Pressure
Treatmentsa
(
1)
Applying
diluted
chromated
arsenical
liquid
treatment
solutions
at
a
pressure
treatment
plant
using
an
automated/
closed
delivery
system.
Scenario
involves
using
an
automated/
closed
delivery
system
to
mechanically
pump
a
1­
2%
CCA­
C
treatment
solution
from
the
"
work
tank"
to
the
pressure
treatment
cylinder
(
i.
e.,
retort)
to
pressure
treat
a
charge
of
wood.
Exposure
may
occur
to
treatment
operators
and
treatment
assistants
while
handling
leads
and
charge
chains,
opening
and
closing
retort
doors,
cleaning
and
maintenance
of
systems.
Treatment
operators
operate
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
American
Chemistry
Council
(
ACC,
2001).

a
Representative
handler
scenarios
related
to
applications
of
CCA­
C
chromated
arsenical
products
at
wood
pressure
treatment
plants.
b
Representative
handler
scenarios
related
to
remedial
applications
of
chromated
or
chromated
arsenical
products
to
pressure
treated
wooden
poles,
posts,
lumber,
or
other
timbers.

Legend:
CCA
­
C
=
Chromated
Copper
Arsenate,
Type
C
with
the
following
composition
on
a
100%
oxide
basis:
47.5%
Hexavalent
Chromium,
as
CrO3;
18.5%
Copper,
as
CuO;
34.0%
Arsenic,
as
As2O5.

(
b)
Chemical­
Specific
Handler
Exposure
Data
ACC's
Worker
Exposure
Study
(
MRID
455021­
01)

The
handler
exposure
assessments
for
pressure
treatment
scenarios
were
completed
by
EPA
using
the
data
from
the
study
titled
"
Assessment
of
Potential
Inhalation
and
Dermal
Exposure
Associated
with
Pressure
Treatment
of
Wood
with
Arsenical
Products"
(
MRID
455021­
01).
In
this
study
three
commercial
facilities
in
the
U.
S.
and
Canada
were
examined
to
determine
the
dermal
and
inhalation
exposure
of
workers
applying
CCA
and
ACZA
end
use
products
to
dimensional
lumber,
outdoor
furniture
components,
utility
poles
and/
or
posts
by
pressure
treatment
systems.
The
three
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
CCA..
21
The
CCA
study
measured
both
handlers
and
post
application
activities.
Although
there
is
overlap
in
job
functions,
the
handlers
are
defined
as
the
treating
operators
(
TO)
and
treating
assistants
(
TA).
Three
sites
were
monitored
in
the
CCA
study:
(
1)
Site
A
South
Carolina,
(
2)
Site
B
Ontario,
and
(
3)
Site
C
Oregon.
The
TO
were
monitored
at
Sites
A,
B,
C
using
5
replicates
at
each
site.
The
TA
were
monitored
at
Sites
A
and
C
using
5
replicates
at
each
site.
The
post
application
activities
included:
tram
setter
(
TS)
at
Site
A
(
n=
5);
stacker
operator
(
SO)
at
Site
A
(
n=
4);
loader
operator
(
LO)
at
Sites
A,
B,
C
(
n=
15);
supervisor
(
S)
at
Site
B
(
n=
5);
test
borer
(
TB)
at
Site
C
(
n=
5);
and
the
tallyman
(
TM)
at
Site
C
(
n=
5).

The
U.
S.
and
Canadian
sites
indicate
a
difference
in
the
mean
dermal
exposures.
Upon
further
analysis
by
Health
Canada
it
was
determined
that
the
final
vacuum
for
the
pressure
treatment
process
was
not
performed
at
site
B.
The
final
vacuum
is
used
to
remove
excess
CCA.
The
final
vacuum
process
was
performed
for
1
to
5
hours
at
site
A
and
2
to
3
hours
at
site
C.
According
to
the
AWPA
standard,
the
final
vacuum
procedure
is
a
recommended
practice
and
this
practice
appears
to
reduce
the
potential
for
dermal
and
inhalation
exposures
as
indicated
in
Table
3a.
These
data
will
be
considered
during
the
risk
mitigation
phase
of
the
RED
process.
22
Table
3a.
Pressure
Treatment
CCA
Unit
Exposures
Normalized
to
the
Treatment
Solution
Concentration
for
Comparison
Among
Sites.

Site
Treatment
Solution
Statistic
Dermal
UE
(

g
As/
ppm)
Inhalation
UE
(

g
As/
m3/
ppm)
%
ppm
All
sites
(
A,
B,
C)
­
Handler
Treatment
Operator
(
n
=
15)
0.438
to
0.595
4380
to
5950
Average
±
std
2.04
±
2.68
0.00032
±
0.00038
Median
0.37
0.00013
90th
percentile
5.39
0.00092
Maximum
7.74
0.0011
US
sites
(
A
and
C)
­

Handler
Treatment
Operator
(
n
=
10)
0.544
and
0.595
5440
and
5950
Average
±
std
0.27
±
0.16
0.00008
±
0.00004
Median
0.23
0.00005
90th
percentile
0.45
0.00013
Maximum
0.60
0.00013
Canadian
site
(
B)
­
Handler
Treatment
Operator
(
n
=
5)
0.438
4380
Average
±
std
5.6
±
1.2
0.00077
±
0.00026
Median
5.2
0.00084
90th
percentile
6.9
0.0010
Maximum
7.7
0.0011
US
sites
(
A
and
C)
­

Handler
Treatment
Assistant
(
n
=
10)
0.544
and
0.595
5440
and
5950
Average
±
std
0.24
±
0.14
0.0001
±
0.00004
Median
0.23
0.00013
90th
percentile
0.40
0.00013
Maximum
0.52
0.00014
Canadian
site
(
B)
­
Handler
Treatment
Assistant
(
n
=
0)
The
treatment
assistant
(
TA)
was
not
monitored
at
site
B
All
sites
(
A,
B,
C)
­

Postapplication
All
job
functions
(
TS,
SO,
LO,
S,
TB,
TM)

(
n
=
39)
0.438
to
0.595
4380
to
5950
Average
±
std
0.74
±
0.73
0.00020
±
0.00025
Median
0.42
0.00013
90th
percentile
1.81
0.00050
Maximum
3.11
0.0011
US
sites
(
A
and
C)
­

Postapplication
All
job
functions
(
TS,
SO,
LO,
TB,
TM)

(
n
=
29)
0.544
and
0.595
5440
and
5950
Average
±
std
0.49
±
0.51
0.00013
±
0.00015
Median
0.35
0.00005
90th
percentile
1.2
0.00039
Maximum
2.0
0.00055
Canadian
sites
(
B)
­

Postapplication
All
job
functions
(
LO
and
S)

(
n
=
10)
0.438
4380
Average
±
std
1.5
±
0.80
0.00039
±
0.00039
Median
1.4
0.00017
90th
percentile
2.2
0.00096
Maximum
3.1
0.0010
ppm
=
(%
treatment
solution)
*
(
10,000)
Air
concentration
was
calculated
as

g
collected
per
sample
per
ppm
/
(
480
min
per
day
x
2
L/
min)
23
At
each
site,
pressure
treatment
of
wood
products
was
performed
using
the
same
basic
process.
Workers
operated
self­
propelled
or
stationary
loaders
which
moved
untreated
poles
or
dimensional
lumber
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
load
of
wood
products
farthest
from
the
cylinder
door,
and
was
laid
along
the
top
of
the
stacked
items
on
the
trams.
The
filled
trams
made
up
a
"
charge"
of
wood
products.

The
cylinder
door
was
opened
either
hydraulically
or
manually
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
or
a
self
pulled
into
the
cylinder
by
an
automated
transfer
deck.
Workers
placed
the
free
end
of
the
lead
cable
into
the
cylinder,
closed
the
cylinder
door(
s),
and
started
the
treatment
process.
Treating
solution
was
then
pumped
from
storage
tanks
into
the
cylinder,
after
which
pressure
(
120
­
180
psi)
was
applied
to
the
cylinder
to
allow
the
preservative
to
permeate
the
wood
of
the
poles.
CCA
solutions
were
used
unheated,
while
ACZA
solutions
were
heated
to
120­
140

F
during
treatment.

After
treatment,
excess
treating
solution
was
removed
from
the
cylinders
and
wood
products
by
maintaining
a
vacuum
in
the
cylinder
for
approximately
1
to
5
hours.
The
duration
of
a
treatment
cycle
ranged
from
approximately
2
to
340
hours,
depending
on
the
species
of
wood
treated,
the
procedures
used
by
each
site,
and
whether
CCA
or
ACZA
was
being
used.
At
the
end
of
treatment,
the
cylinder
was
opened,
and
a
mist
containing
water
and
some
preservative
was
observed.

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
poles
were
pushed
by
the
loader
to
a
storage
area,
where
workers
using
hand­
or
electric­
powered
drills
took
narrow
cores
of
wood
from
selected
poles
or
ties
to
determine
the
depth
of
penetration
of
the
preservative,
and
the
amount
of
preservative
that
was
actually
absorbed
by
the
wood.
Charges
that
did
not
contain
enough
CCA
or
did
not
penetrate
deep
enough
were
retreated
as
above.

Sixteen
workers
were
monitored
for
this
study
for
4­
5
consecutive
work
days
each.
On
each
day
of
monitoring,
one
or
more
loads
of
dried,
debarked
poles
or
posts,
or
cut
dimensional
lumber
or
other
wood
products
were
stacked
on
moveable
trams,
and
pushed
into
horizontal
cylinders.
Each
cylinder
was
filled
with
a
mixture
containing
arsenic
pentoxide,
copper
oxide,
and
either
chromium
oxide
or
zinc
oxide
wood.
The
treated
wood
absorbed
between
approximately
41
lbs
and
1,011
lbs
of
total
metal
oxides
per
charge,
depending
on
the
charge
volume
and
treatment
parameters.

The
treatment
plant
job
categories
monitored
in
this
study
include
treatment
operators,
treating
assistants,
loader
operators,
test
borers,
tram
setter,
tally
man,
and
stacker
operator.
Workers
performed
typical
tasks
related
to
these
activities
and
were
monitored
for
up
to
4­
5
consecutive
work
days
each.
24
Descriptions
of
the
tasks
monitored
are
bulleted
below
:


Treatment
operators
(
TOs)
­
TOs
operate
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,
distribute
treated
wood
to
load­
out
area,
and
loaded
treated
wood
for
shipment.


Test
borers
(
TBs)
­
TBs
cut
cores
from
freshly
treated
poles
or
ties
for
testing
for
CCA.


Tram
setter
(
TS)­
At
Site
A
TS
steam­
cleaned
drip
pads
and
tracks,
Operated
cylinder
door
controls,
cleaned
cylinders,
handled
hazardous
waste,
and
manually
moved
trams
and
placed
drawbridges
for
treatments.

Dermal
exposure
levels
were
estimated
by
passive
dosimetry
using
whole
body
dosimeters
(
WBD)
worn
under
the
worker's
clothing
and
lightweight
cotton
glove
dosimeters
worn
under
work
gloves.
The
dermal
exposure
levels
to
CCA
and
ACZA
were
estimated
by
measuring
the
levels
of
arsenic,
chromium,
copper,
and
zinc
compounds.
Each
analyte
was
determined
in
all
WBD
and
glove
samples.
Dermal
exposure
to
arsenic
and
Cr
are
depicted
in
Tables
4
and
5.

Table
4.
Geometric
Mean
Daily
Dermal
Exposure
Levels
for
Monitored
Workers
at
all
Sites
for
Arsenic
Parameter
Dermal
Exposure
(

g/
kg
bw/
day)
to
Arsenic
a
TO
TA
TB
TS
TM
LO
S
SO
No.
Replicates
15
10
5
5
5
15
5
4
Minimum
4.02
6.24
1.59
69.1
26.8
10.0
20.4
13.8
Maximum
472
39.2
8.29
148
151
190
86.8
29.0
Mean
128
19.1
3.51
102
56.8
56.9
57.0
21.3
S.
D.
161
11.1
2.74
30.7
53.2
53.6
31.9
6.23
G.
M.
47.9
16.3
2.91
98.0
44.3
38.0
48.3
20.6
Median
30.4
18.2
2.46
89.8
32.2
35.0
66.5
21.1
*
Abbreviations:
LO
=
Loader
operator;
S=
supervisor,
SO=
stacker
operator,
TA
=
treating
assistant,
TB=
test
borer,
TM=
tally
man,
TO=
treating
operator,
and
TS=
tram
setter.
25
Table
5.
Geometric
Mean
Daily
Dermal
Exposures
for
Monitored
Workers
at
all
Sites
for
Chromium
(
VI)

Parameter
Dermal
Exposure
(

g/
kg
bw/
day)
to
Hexavalent
Chromium
a
TO
TA
TS
LO
S
SO
No.
Replicates
10
5
5
10
5
4
Minimum
2.02
1.43
1.75
1.48
1.78
1.41
Maximum
10.3
12.9
11.8
4.01
3.84
1.58
Mean
4.83
4.00
5.74
2.45
2.60
1.49
S.
D.
3.04
5.00
3.82
0.91
0.893
0.068
G.
M.
4.07
2.61
4.74
2.31
2.49
1.49
Median
3.40
1.80
5.83
2.1
2.15
1.48
a
Abbreviations:
LO
=
Loader
operator,
TA
=
treating
assistant,
TB=
test
borer,
TM=
tally
man,
and
TO=
treating
operator.

Inhalation
exposures
for
each
worker
were
estimated
by
active
dosimetry.
Each
worker
wore
a
sampling
train
consisting
of
a
37mm
polyvinyl
chloride
(
PVC)
filter
in
a
plastic
cassette,
attached
to
the
front
of
the
work
shirt
with
the
intake
orifice
in
the
breathing
zone.
The
intake
orifice
was
oriented
downward
and
connected
by
Tygon
®
tubing
to
a
second
cassette,
attached
to
a
Buck
S.
S.
Pump
on
the
work
belt.
The
pump
drew
air
through
the
sampling
filter
at
approximately
2
L/
min
while
the
subject
performed
the
tasks.
Pumps
were
calibrated
immediately
prior
to
and
after
each
monitoring
period
using
a
NIST­
traceable­
calibrated
Sierra
®
Top­
Trak
 
mass
flow
meter.
The
results
of
the
sampling
are
presented
in
Tables
6,
7,
and
8.

Table
6.
8­
Hour
Inhalation
Air
Concentrations
(
µ
g/
m3)

Test
Site
Job
Class
Total
As
Total
Cu
Total
Cr
Hex
Cr
Total
Zn
A
TA
0.803
1.001
1.41
0.268
­­­

TS
2.09
2.37
2.87
0.330
­­­

TO
0.648
0.980
1.45
0.269
­­­

LO
0.527
1.011
1.36
0.340
­­­

SO
0.267
1.08
0.508
0.267
­­­

B
LO
2.25
4.58
3.31
0.309
­­­

S
1.26
2.82
2.84
0.342
­­­

TO
3.85
5.24
3.88
0.298
­­­

C
TB
0.279
0.347
­­­
­­­
0.279
TO
0.287
0.862
­­­
­­­
0.358
LO
0.270
0.810
­­­
­­­
0.419
TM
0.362
0.561
­­­
­­­
0.362
26
TA
0.347
0.835
­­­
­­­
0.538
Table
7.
Geometric
Mean
Daily
Inhalation
Exposure
Levels
for
Monitored
Workers
at
all
Sites
for
Arsenic
Parameter
Inhalation
Exposure
(

g/
kg
bw/
day)
to
Arsenic
a
TO
TA
TB
TS
TM
LO
S
SO
No.
Replicates
15
10
5
5
5
15
5
4
Minimum
0.031
0.032
0.033
0.101
0.033
0.032
0.113
0.032
Maximum
0.709
0.102
0.035
0.434
0.104
0.676
0.319
0.033
Mean
0.205
0.073
0.034
0.282
0.049
0.157
0.167
0.033
S.
D.
0.233
0.033
0.001
0.119
0.031
0.213
0.086
0.000
G.
M.
0.107
0.065
0.034
0.256
0.044
0.086
0.154
0.033
Median
0.098
0.095
0.034
0.298
0.038
0.092
0.138
0.033
a
Abbreviations:
LO
=
Loader
operator;
S=
supervisor,
SO=
stacker
operator,
TA
=
treating
assistant,
TB=
test
borer,
TM=
tally
man,
TO=
treating
operator,
and
TS=
tram
setter.

Table
8.
Geometric
Mean
Daily
Inhalation
Exposure
Levels
for
Monitored
Workers
at
all
Sites
for
Hexavalent
Chromium
Parameter
Inhalation
Exposure
(

g/
kg
bw/
day)
to
Hexavalent
Chromium
a
TO
TA
TS
LO
S
SO
No.
Replicates
10
5
5
10
5
4
Minimum
0.033
0.032
0.031
0.031
0.038
0.032
Maximum
0.037
0.034
0.101
0.098
0.049
0.033
Mean
0.0
35
0.033
0.046
0.042
0.042
0.033
S.
D.
0.002
0.001
0.031
0.020
0.005
0.000
G.
M.
0.035
0.033
0.040
0.040
0.042
0.033
Median
0.035
0.033
0.033
0.038
0.040
0.033
a
Abbreviations:
LO
=
Loader
operator;
S=
supervisor,
SO=
stacker
operator,
TA
=
treating
assistant,
TB=
test
borer,
TO=
treating
operator,
and
TS=
tram
setter.

PEL
Monitoring
Data
A
study
by
the
former
Chemical
Manufacturer's
Association
(
CMA)
entitled
the
"
Report
on
Monitoring
of
Workers
in
Wood
Treating
Plants
Using
Arsenical
Pressure
Treatment
Wood
Preservatives
under
RPAR
PEL
Requirements"
was
submitted
to
EPA
for
review
and
as
part
of
the
ongoing
registration
requirements
for
industrial
air
monitoring
reporting.
The
CMA
inhalation
exposure
study
summarized
monitoring
data
for
airborne
arsenic
in
wood
treating
plants
that
used
CCA
and
AZCA.
The
monitoring
data
were
collected
from
220
wood
treating
plants
in
the
United
States
between
1991
and
1999
under
the
Rebuttable
Presumption
Against
the
Registration
(
RPAR)
PEL
monitoring
program.
In
27
addition,
two
studies
originally
conducted
for
the
National
Institute
for
Occupational
Safety
and
Health
(
NIOSH)
were
also
submitted
by
the
registrant
to
EPA
(
MRID
426337­
11
and
426337­
13).

In
1984,
EPA
issued
a
position
document
requiring
certain
changes
in
the
terms
and
conditions
for
registration
of
wood
preservative
uses
of
inorganic
arsenicals
as
part
of
the
RPAR
(
U.
S.
EPA,
1984).
Under
this
notice,
wood
treating
plants
are
required
to
either
provide
employees
with
respirators
or
to
implement
a
PEL
monitoring
program.
Under
the
PEL
monitoring
program,
if
the
airborne
concentration
of
arsenic
is
above
10
µ
g/
m3,
employees
are
required
to
wear
respirators.
If
the
airborne
concentration
is
between
5
µ
g/
m3
and
10
µ
g/
m3,
air
monitoring
is
required
every
six
months
until
at
least
two
consecutive
measurements
taken
at
least
seven
days
apart,
are
below
5
µ
g/
m3.
Once
levels
are
below
5
µ
g/
m3
when
this
criteria
is
met,
the
wood
treating
plant
can
discontinue
monitoring.
The
wood
treating
plants
are
also
required
to
submit
the
air
monitoring
data
to
EPA
on
an
annual
basis.
The
wood
treating
plants
are
required
to
submit
the
air
monitoring
data
to
the
registrants.
The
results
of
the
PEL
monitoring
study
are
displayed
in
Table
9.

Table
9.
Statistical
Summary
of
Inhalation
Exposure
Levels
of
Airborne
Arsenic
in
Wood
Treating
Plants
Using
Chromated
Copper
Arsenate
(
CCA),
As
Collected
under
the
PEL
Program
Job
Categories
Number
of
Replicates
Inhalation
Exposure
Levels
of
Airborne
Arsenic
(
µ
g/
m3)

Mean
Standard
Deviation
Geometric
Mean
Maximum
Minimum
Treating
Operator
458
2.89
6.33
0.44
55
0.007
Forklift
Operator
215
2.56
5.22
0.52
47.7
0.01
Drip
Pad
Worker
127
2.76
5.32
0.41
37.8
0.002
Lumber
Stacker
17
0.67
1.31
0.25
5.3
0.03
Lumber
Tagger
14
1.27
1.74
0.19
4.7
0.01
Maintenance
6
3.53
3.85
0.86
10.51
0.03
The
PEL
monitoring
data
for
airborne
arsenic
in
pressure
treatment
plants
only
partially
met
the
requirements
specified
in
the
Occupational
and
Residential
Test
Guideline
875.1400­
Indoor
Inhalation
Exposure.
Note
that
there
are
few
deficiencies
in
this
study
with
respect
to
data
quality
(
see
Data
Gaps,
Uncertainties
and
Limitations
Section
7).
28
NIOSH
Studies
(
MRID
426337­
11
and
426337­
13)

Two
CCA
inhalation
exposure
studies
were
conducted
by
NIOSH
and
were
submitted
by
the
registrant
to
EPA
(
MRID
426337­
11
and
426337­
13).
These
studies
examined
the
specific
exposure
using
a
50
percent
and
60
percent
CCA
Type
C
(
CCA­
C)
product.
These
studies
examined
the
inhalation
exposure
of
both
arsenic
and
chromium,
but
are
not
compliant
to
the
Series
875
Occupational
and
Residential
Test
Guidelines.
A
few
of
these
deficiencies
are
described
in
the
Uncertainties
and
Limitations
Section
of
this
report.

The
study
entitled
"
Review
of
Industrial
Hygiene
Report,
Comprehensive
Survey
of
Wood
Preservative
Treatment
Facility
at
Cascade
Pole
Company
McFarland
Cascade,
Tacoma
Washington"
(
MRID
426337­
13)
was
conducted
to
quantify
the
exposure
to
chromated
copper
arsenate
(
CCA)
[
as
well
as
other
wood
preservative
chemicals:
pentachlorophenol
(
PCP),
creosote
and
ammoniacal
copper
arsenate
(
ACA)]
and
to
evaluate
potential
health
risks
under
typical
operating
conditions.
This
site
was
selected
as
best
representing
a
large
diversified
wood
treating
facility
which
uses
CCA.
The
survey
also
included
a
medical
industrial
hygiene
and
safety
program
at
the
facility.
The
study
was
completed
in
1980
as
an
Industrial
Hygiene
report
and
is
not
FIFRA
compliant.
Only
the
information
relevant
to
CCA
will
be
included
in
this
review.

The
employees
with
the
most
potential
exposure
are
the
six
treatment
plant
operators
(
two
per
shift),
six
pettibone
and
two
fork
lift
operators,
in
addition
to
two
to
four
yard
crew.
Wood
treated
with
CCA
is
kiln
dried
or
steam
processed
prior
to
pressure
treatment.
The
CCA
lumber
is
treated
with
CCAC
CCA
Type
C
50
percent
concentrate
is
diluted
with
water
to
a
1­
2
percent
treatment
solution,
which
is
used
to
pressure
treat
the
wood.
The
concentrate
is
pumped
from
a
tanker
truck
where
it
is
diluted
in
a
10,000
gallon
work
tank.
The
wood
treated
in
this
manner
is
usually
dimensional
lumber.
It
is
dried,
incised
and
treated
for
4­
5
hours
under
pressure
at
ambient
temperatures.

The
industrial
hygiene
survey
included
personal
air
sampling,
area
air
sampling
and
wipe/
touch
samples
on
semi­
dry
CCA
treated
wood
before
and
after
flushing
with
water.
Integrated
breathing
zone
and
area
sampling
was
conducted
using
Bendix
BDX­
41
air
sampling
pumps.
The
pumps
were
pre­
and
post­
calibrated
using
a
Universal
Pump
calibrator
(
Model
302)
and
the
appropriate
collection
devices.
The
CCA
treatment
process
was
evaluated
using
the
NIOSH
P&
CAM
#
173
air
sampling
method
for
Copper
and
Chromium
and
S­
309
for
arsenic.
The
sampling
train
consisted
of
a
8
micron
millipore
AA
filter
with
a
cellulose
back­
up
pad
in
a
37
mm
3­
piece
closed
faces
cassette
at
a
collection
rate
of
1.8­
2.0
liters
per
minute.
The
samples
were
analyzed
by
Atomic
Absorption
(
AA)
Spectroscopy.

Treatment
helper
and
treatment
operator
exposures
were
monitored
for
one
18
minute
cylinder
opening
exposure
period.
In
addition,
exposure
was
monitored
for
a
treatment
operator
during
a
series
of
4
cylinder
openings,
which
lasted
a
total
of
72
minutes
and
exposure
for
treatment
helper
during
a
series
of
three
cylinder
openings
lasting
80
minutes.
The
results
are
summarized
in
Table
10.
29
Table
10:
Personal
Air
Sampling
Information
for
CCA
(
MRID
426337­
13)

Operation
Chromium
(

g/
m3)
Arsenic
(

g/
m3)

Treatment
Helper
­
cylinder
opening
&
discharging
(
18
min.)
<
27.8
<
8.3
Treatment
Operator
­
cylinder
opening
&
discharging
(
18
min.)
<
31.2
<
9.4
Treatment
Operator
­
cylinder
opening
&
discharging
(
72
min.)
Series
of
4
cylinder
openings
6.8
3265.3
Treatment
Helper
­
cylinder
opening
&
discharging
(
80
min.)
Series
of
3
cylinder
openings
6.3
4.5
1980
Occupational
exposure
limits:
Chromic
Acid
100

g/
m3,
Arsenic
500

g/
m3.

An
additional
NIOSH
study
entitled
"
Industrial
Hygiene
Surveys
of
Occupational
Exposures
to
Wood
Preservative
Chemicals"
(
MRID
426337­
11)
also
quantified
the
occupational
exposure
to
workers
during
pressure
treatment
using
chromated
copper
arsenate
(
CCA)
as
well
as
pentachlorophenol
(
PCP),
creosote
and
ammoniacal
copper
arsenate
(
ACA).
Although
the
survey
was
conducted
at
eleven
wood
treatment
plants
and
two
manufacturing
operations
in
1981
as
part
of
an
industry
wide
evaluation
of
worker
exposure
to
wood
preservative
chemicals,
personal
air
sampling
and
wipe/
touch
samples
were
conducted
at
only
one
site.
For
this
site,
the
treatment
process
was
similar
to
the
previous
NIOSH
study,
and
sampling
methodologies
used
were
not
adequately
explained.
The
results
are
summarized
in
Tables
11
and
12.

Table
11:
Personal
Air
Sampling
Information
for
CCA
(
MRID
426337­
11)

Operation
Chromium
(

g/
m3)
Arsenic
(

g/
m3)

Treatment
Helper
­
cylinder
opening
&
discharging
(
18
min.)
<
31
<
9
Treatment
Operator
­
cylinder
opening
&
discharging
(
18
min.)
<
28
<
8
Treatment
Operator
­
cylinder
opening
&
discharging
(
72
min.)
<
7
3265
Treatment
Helper
­
cylinder
opening
&
discharging
(
80
min.)
6
4
1980
Occupational
exposure
limits:
Chromic
Acid
100

g/
m3,
Arsenic
500

g/
m3.

Table
12:
Personal
Air
Sampling
Information
for
CCA
(
MRID
426337­
11)

Operation
Hexavalent
Chromium
(

g/
m3)
Chromium
(

g/
m3)
Arsenic
(

g/
m3)

Treatment
building
adjacent
concentrate
mix
tank
0.3
<
1.9
0.9
Adjacent
cylinder
door
opening
<
0.2
<
3.1
<
0.6
Top
of
freshly
treated
wood
<
0.3
<
3.3
<
0.7
30
Table
13:
Exposure
Assumptions
for
Amount
of
Chromated
Arsenical
Wood
Preservatives
Handled
Per
Day
Exposure
Scenarios
for
Non­
Pressure
Treatments
Pounds
ai
used
(
1)
Applying
diluted
chromated
arsenical
liquid
treatment
solutions
at
a
pressure
treatment
plant
using
an
automated/
closed
delivery
system.
Not
Applicable
to
calculate
for
this
scenario.
Based
on
ACC
Worker
Exposure
Study
Data
(
MRID
455021­
01)

(
3)
Handler
Risk
Assessment
and
Characterization
(
a)
Handler
Exposure
and
Non­
Cancer
Risk
Calculations
Exposure
to
occupational
handler
exposures
are
presented
in
Table
14.
For
Scenario
(
1),
dermal
and
inhalation
exposures
were
developed
using
geometric
mean
values
from
chemical­
specific
worker
exposure
study
data
for
treatment
operators
and
treatment
assistants
at
pressure
treatment
plants
(
ACC,
2001).
The
occupational
handler
daily
dose
and
lifetime
average
daily
dose
(
LADD)
are
presented
in
Table
14.
The
associated
occupational
handler
noncancer
MOE's
and
cancer
risks
based
on
the
registrant's
pressure
treatment
study
are
presented
in
Table
15.
31
Table
14.
Occupational
Short­,
Intermediate­,
and
Long­
term
Handler
Doses
to
CCA
Dermal
Inhalation
Exposure
Scenario
(
Scen.
#)
Dermal
Unit
Exposure
(
mg/
lb
ai)
a
Inhalation
Unit
Exposure
(
µ
g/
lb
ai)
b
Chemical
of
Concern
%
CCA
in
End
Use
Product
Amount
Ingredient
Handled
per
Dayc
Short­,
Intermediate­
and
Long
Term
Daily
Dosed
Lifetime
Average
Daily
Dosee
Short­,
Intermediate­,
and
Long­
term
Daily
Dosef
Lifetime
Average
Daily
Dosee
(
1)
Treatment
Operator
(
TO)
and
Treatment
Assistant
(
TA)
­

Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
ACC
Study
Data
Used
(
See
Table
4)
ACC
Study
Data
Used
(
See
Tables
7
&
8)
Arsenic
(
As)
2%
N/
A
3.07E­
3
(
TO)
1.12E­
3
(
TO)
1.07E­
4
(
TO)
3.9E­
5
(
TO)

Chromium
g
(
Cr+
6)
N/
A
NA
NA
3.5E­
5
(
TO)
1.3E­
5
(
TO)

Arsenic
(
As)
2%
N/
A
1.04E­
3
(
TA)
3.8E­
4
(
TA)
6.5E­
5
(
TA)
2.4E­
5
(
TA)

Chromiumg
(
Cr+
6)
N/
A
NA
NA
3.3E­
5
(
TA)
1.2E­
5
(
TA)

Footnotes:

a
For
Scenario
(
1)
ACC
Worker
Exposure
Study
Data,
geometric
mean
value
for
As
in
Table
4
used
for
Treatment
Operator
(
TO)
and
Treatment
Assistant
(
TA)
(
MRID
455021­
01).

b
For
Scenario
(
1)
ACC
Worker
Exposure
Study
Data,
geometric
mean
values
for
As
and
Cr+
6
in
Tables
7
&
8,
used
for
TO
and
TA
(
MRID
455021­
01).

c
Amounts
handled
per
day
are
based
on
the
CCA
worker
exposure
study
for
pressure
treatments.

d
Short­,
intermediate­,
and
long­
term
daily
dermal
dose
(
mg/
kg/
day)
=
geo
mean
daily
dermal
dose
for
As
in
Table
4
in
units
of

g/
kg
x
0.001
mg/

g
unit
conversion
x
(
ABS/
100).
ABS
is
6.4%
for
arsenic.

e
Lifetime
average
daily
dose,
LADD
(
mg/
kg/
day)
=
geo
mean
daily
dermal
or
inhalation
dose
from
Tables
4,
7,
8
in
units
of

g/
kg
x
0.001
mg/

g
unit
conversion
x
dermal
ABS/
100
x
(
250
days
worked
per
yr/
365
days
per
year)
x
(
40
working
years/
75
yr
lifetime).

f
Short­,
Intermediate­,
and
long­
term
daily
inhalation
dose
(
mg/
kg/
day)
=
geo
mean
daily
inhalation
dose
for
As
or
Cr+
6
from
Tables
7
and
8
in
units
of

g/
kg
x
0.001
mg/

g
unit
conversion.

g
Represents
the
hexavalent
portion
of
chromium.

NA
Not
applicable
32
Table
15.
Occupational
Short­,
Intermediate­,
and
Long­
term
Handler
Risks
to
CCA
Exposure
Scenario
(
Scen.
#)
Chemical
of
Concern
Risk
Mitigation
Amount
Ingredient
Handled
per
Daya
Dermal
Inhalation
Short­,
and
Intermediateterm
MOEb
Long­
term
MOEc
Cancer
Riskd
Short­,
and
Intermediateterm
MOEe
Long­
term
MOE
f
Cancer
Riskg
(
1)
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)

(
treatment
operator­
TO)
Arsenic
(
As)
Engineering
Controls
N/
A
16
0.3
4.1E­
3
467
7
2.0E­
4
Chromium
(
Cr
+
6)
N/
A
N/
A
N/
A
NA
7
(
Target
MOE
30)
7
(
Target
MOE
100)
1.7E­
4
(
treatment
assistant­
TA)
Arsenic
(
As)
Engineering
Controls
N/
A
48
0.8
1.4E­
3
769
12
1.2E­
4
Chromium
(
Cr+
6)
N/
A
N/
A
N/
A
NA
7
(
Target
MOE
30)
7
(
Target
MOE
100)
1.6E­
4
Footnotes:

a
Amount
handled
per
day
based
on
the
CCA
worker
exposure
study
for
pressure
treatments.

b
MOE
=
dermal
LOAEL
/
short­
term,
intermediate­
term
dermal
daily
dose.
Where
As
LOAEL
=
0.05
mg/
kg/
day.

c
MOE
=
dermal
NOAEL
/
long­
term
dermal
daily
dose.
Where
As
NOAEL
=
0.0008
mg/
kg/
day.

d
Dermal
Cancer
Risk
=
cancer
slope
factor
(
CSF)
x
dermal
LADD.
Where
arsenic
CSF
=
3.67
(
mg/
kg/
day)­
1
.

e
MOE
=
inhalation
LOAEL
/
short­
term,
intermediate­
term
inhalation
daily
dose.
Where
As
LOAEL
=
0.05
mg/
kg/
day
and
Cr+
6
LOAEL
=
2.3
x
10­
4
mg/
kg/
day
(
derived
from
a
LOAEL
=
0.002
mg/
m3).

f
MOE
=
inhalation
NOAEL
or
LOAEL
/
long­
term
inhalation
dose.
Where
As
NOAEL
=
0.0008
mg/
kg/
day
and
Cr+
6
LOAEL
=
2.3
x
10­
4
mg/
kg/
day
(
derived
from
a
LOAEL
=
0.002
mg/
m3).

g
Inhalation
Cancer
Risk
=
Cancer
slope
factor
(
CSF)
x
inhalation
LADD.
Where
arsenic
CSF
for
an
8­
hour
work
day
=
5
(
mg/
kg/
day)­
1
and
Cr+
6
inhalation
CSF
=
13.5
(
mg/
kg/
day)­­
1.

NA
Not
applicable
NOTE:
Recommended
Dermal
MOE
for
Arsenic:
short­
and
intermediate­
term
=
30
(
10x
intraspecies
variation
and
3x
for
the
use
of
the
LOAEL);
long­
term
=
3
(
3x
rather
than
10x
because
of
the
large
sample
size
in
the
toxicity
study
(>
40,000)).

Recommended
Inhalation
MOE
for
Arsenic:
short­
and
intermediate­
term
=
100
(
10x
intraspecies
variation
and
3x
for
the
use
of
the
LOAEL),
long­
term
=
3
(
3x
rather
than
10x
because
of
the
large
sample
size
in
the
toxicity
study
(>
40,000)).

Recommended
Inhalation
MOE
for
Chromium
VI:
all
durations
=
100
(
10x
intraspecies
variation,
3x
for
use
of
a
LOAEL,
and
3x
modifying
factor
for
epidemiological
study
and
to
convert
to
a
long­
term
or
"
lifetime"
duration).
33
Daily
Inh.
Exposure
mg
ai
day

Air
Concentration

g
m3
x
CF
mg

g
x
IR
m3
hr
x
ED
hr
day
Daily
Inhalation
Dose
mg
ai
kg/
day

Daily
Inhalation
Exposure.
mg
day
1
Body
Weight
(
kg)
(
i)
Inhalation
Exposure
Chemical­
specific
inhalation
data
from
the
ACC
Worker
Exposure
Study
were
available
for
Scenario
(
1).
The
daily
inhalation
exposure
from
air
concentration
was
calculated
as
follows:

Air
Concentration
=
Values
obtained
from
ACC
study
CF
(
0.001
mg/
µ
g)
=
conversion
factor
ED
(
hr/
day)
=
exposure
duration
IR
(
m3/
hr)
=
inhalation
rate
Where:

IR
(
inhalation
rate)
=
1.25
m3/
hr
(
EPA,
1997)

ED
(
exposure
duration)
=
8
hrs/
day
(
ii)
Inhalation
Dose
Short­,
intermediate­,
and
long­
term
inhalation
doses
were
calculated
where
data
were
available
for
arsenic
and
chromium
VI.
Inhalation
doses
were
calculated
using
a
body
weight
of
70
kilograms,

because
the
endpoint
is
not
sex­
specific.
Daily
inhalation
dose
is
calculated
as
follows:

Daily
Inhalation
Exposure
(
mg
ai/
day)
=
calculated
from
CCA
exposure
study
(
½
LOD)

Body
Weight
(
kg)
=
70
For
Scenario
(
1),
the
ACC
Study
Data,
calculated
geometric
mean
values
in
Tables
7
&
8
were
used
directly
after
a
CF
(
0.001
mg/
µ
g)
was
applied.
34
Inhalation
MOE

LOAEL
(
mg/
kg/
day)
Inhalation
Dose
(
mg/
kg/
day)

Daily
Dermal
Dose
mg
ai
Kg/
Day

Daily
Dermal
Exposure
mg
ai
day
x
1
Body
Weight
(
Kg)
x
ABS
(%)
(
iii)
Inhalation
Risk
Inhalation
risks
from
short­,
intermediate­,
and
long­
term
exposures
to
arsenic
and
chromium
VI
were
calculated
where
applicable.
The
following
formula
describes
the
calculation
of
an
inhalation
MOE:

For
the
arsenic
assessment
a
LOAEL
of
0.05
mg/
kg/
day
was
used
for
the
short­
term
and
intermediate­
term
exposures
(
uncertainty
factor
of
100),
and
a
NOAEL
of
0.0008
mg/
kg/
day
was
used
for
long­
term
arsenic
inhalation
estimates
(
uncertainty
factor
of
3
applied).

For
the
chromium
VI
assessment
a
LOAEL
of
0.002
mg/
m3
was
used
for
all
durations.
The
ambient
air
concentration
of
the
LOAEL
was
then
converted
to
a
dose
in
units
of
mg/
kg/
day
for
comparison
with
inhalation
doses
estimated
in
this
exposure
assessment.
Therefore,
the
air
concentration
of
the
LOAEL
was
multiplied
by
the
inhalation
rate
of
8
m3/
workday
and
divided
by
a
body
weight
of
70
kg
to
arrive
at
a
LOAEL
of
2.3
x
10­
4
mg/
kg/
day.
The
EPA
recommended
target
MOE
of
100
is
used
for
this
risk
assessment
for
all
durations
(
i.
e.,
10x
intra
variability
for
human
study,
3x
for
lack
of
a
NOAEL,
and
3x
modifying
factor
for
epidemiological
study
and
to
convert
to
a
long­
term
or
"
lifetime"

duration).

(
iv)
Dermal
Exposure
For
Scenario
(
1),
the
ACC
Study
Data,
calculated
geometric
mean
values
in
Tables
4
&
5
were
used
directly
after
a
CF
(
0.001
mg/
µ
g)
and
dermal
absorption
values
were
applied.

(
v)
Dermal
Dose
A
body
weight
of
70
kilograms
was
used
to
calculate
the
daily
dermal
dose
for
short­,

intermediate­
and
long­
term
exposures
to
arsenic.

Body
Weight
(
kg)
=
70
for
short­,
intermediate­
and
long­
term
exposures
to
arsenic
and
short­,

intermediate­,
and
long­
term
exposures
to
chromium
ABS
=
6.4
percent
absorption
for
arsenic
35
Dermal
MOE

NOAEL
(
mg/
kg/
day)
Dermal
Dose
(
mg/
kg/
day)

LADD
mg
ai
kg/
day

[
Chronic
Dermal
Dose
(
mg/
kg/
day)
or
Chronic
Inhalation
Dose
(
mg/
kg/
day)]
x
EF
(
days/
yr)
x
ED
(
yrs)
365
days/
yr
x
Lifetime
(
yrs)

Risk

LADD
mg
ai
kg/
day
x
Cancer
Slope
Factor
1
(
mg/
kg/
day)
(
vi)
Dermal
Risk
To
calculate
risks
to
handlers,
the
daily
dermal
doses
of
arsenic
and
chromium
received
by
handlers
were
compared
to
the
dermal
endpoints
of
concern.
The
following
formula
describes
the
calculation
of
a
dermal
MOE:

The
following
endpoints
were
used
to
assess
dermal
risks
from
exposures
to
arsenic:


NOAEL
=
0.05
mg/
kg/
day
for
short­
and
intermediate­
term
dermal
exposures
with
an
uncertainty
factor
of
30;
and

NOAEL
=
0.0008
mg/
kg/
day
for
long­
term
dermal
exposures
with
an
uncertainty
factor
of
3.

(
b)
Handler
Exposure
and
Cancer
Risk
Calculations
For
assessing
the
cancer
risks,
the
lifetime
average
daily
dermal
dose
was
calculated
using
the
chronic
(
long­
term)
dose
(
dermal
or
inhalation,
whichever
is
applicable),
and
accounting
for
exposure
frequency
(
EF),
exposure
duration
(
ED),
and
average
length
of
lifetime.
Exposure
duration
was
assumed
to
be
40
years
and
is
the
standard
value
used
by
OPP
to
represent
a
working
lifetime.
This
is
assumed
to
be
a
conservative
value.
Lifetime
is
assumed
to
be
75
years,
the
recommended
value
for
the
U.
S.

population,
as
cited
in
EPA's
Exposure
Factors
Handbook
(
U.
S.
EPA,
1997).
Exposure
frequency
is
scenario­
specific.
Table
16
details
the
exposure
frequency
values
and
handler
cancer
risk
estimates.
All
handler
scenarios
assume
an
exposure
frequency
of
250
days
per
year
(
i.
e.,
5
days
per
week,
50
days
per
year).
This
is
a
standard
Agency
assumption
for
days
worked
per
year.
The
following
formula
describes
the
calculation
of
the
lifetime
average
daily
dose
(
LADD):

When
a
cancer
slope
factor
is
the
cancer
endpoint
selected,
cancer
risk
is
calculated
by
multiplying
the
lifetime
average
daily
dose
times
the
cancer
slope
factor
using
the
following
formula:
36
Arsenic
Cancer
Risk:
For
assessing
the
cancer
risks
from
exposures
to
arsenic
based
on
the
oral
ingestion
cancer
endpoint,
the
LADD
was
calculated
using
the
chronic
(
long­
term)
dermal
dose.

Exposure
frequency,
exposure
duration,
and
average
length
of
lifetime
were
also
accounted
for
in
the
calculation.
A
cancer
slope
factor
of
3.67
(
mg/
kg/
day)­
1
was
the
endpoint
selected
for
the
oral
ingestion
cancer
endpoint.

The
inhalation
cancer
slope
factor
of
15.1
(
mg/
kg/
day)­
1
is
for
the
general
population
and
was
derived
from
a
continuous
24­
hour
exposure
inhalation
unit
risk
value
of
4.3
x
10­
3
(
µ
g/
m3)­
1
or
0.0043
m3/

g.
To
convert
the
air
concentration
to
a
dose
to
yield
units
of
kg­
day/
mg
or
(
mg/
kg/
day)­
1
the
unit
risk
is
expressed
mathematically
as
0.0043
m3/

g
x
day/
20
m3
x
1000

g/
mg
x
70
kg
=
15.1
(
mg/
kg/
day)­

1.
To
adjust
for
an
8­
hour
work
day,
the
general
population,
continuous
24­
hour
exposure
CSF
of
15.1
(
mg/
kg/
day)­
1
is
multiplied
by
8­
hr/
24­
hr
yielding
a
CSF
of
5
(
mg/
kg/
day)­
1
for
worker
exposure.

Chromium
VI
Cancer
Risk:
For
assessing
the
cancer
risks
from
exposures
to
chromium
VI
based
on
the
inhalation
cancer
endpoint,
the
lifetime
average
daily
inhalation
dose
was
calculated
using
the
chronic
(
long­
term)
inhalation
dose.
Exposure
frequency,
exposure
duration,
and
average
length
of
lifetime
were
also
accounted
for
in
the
calculation.
The
general
population,
continuous
24­
hour
cancer
slope
factor
of
40.6
(
mg/
kg/
day)­
1
was
derived
from
an
inhalation
unit
risk
of
1.2
x
10­
2
(

g/
m3)­
1.
To
adjust
for
an
8­
hour
work
day,
the
general
population,
continuous
24­
hour
exposure
CSF
of
40.6
(
mg/
kg/
day)­
1
is
multiplied
by
8­
hr/
24­
hr
yielding
a
CSF
of
13.5
(
mg/
kg/
day)­
1
for
worker
exposure.

(
c)
Occupational
Handler
Scenarios
with
Non­
Cancer
Dermal
Risk
Concerns
Some
of
the
MOE's
for
the
dermal
exposure
scenarios
presented
in
the
risk
assessment
exceed
the
Agency's
level
of
concern
for
short­,
intermediate­
and
long­
term
dermal
exposures
to
arsenic.
Dermal
exposures
that
exceed
the
Agency's
level
of
concern
for
short­
and
intermediate
(
i.
e.,
MOEs
<
30)
and
long­
term
(
i.
e.,
MOEs
<
3)
for
arsenic
and
chromium
are
presented
below.
37
Arsenic
Short­
Term
and
Intermediate­
Term
°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)]
(
MOE
of
concern,
MOE
=
16);

Long­
Term
°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)
and
treatment
assistant
(
TA)]
(
MOEs
of
concern,
MOEs
=
0.3
for
TO,
and
0.8
for
TA);

Chromium
VI:
Since
dermal
irritation
and
dermal
sensitization
are
the
primary
exposure
concerns
through
the
dermal
route,
no
toxicological
endpoint
was
selected
for
use
in
assessing
dermal
exposure
risks
to
chromium.
Risk
mitigation
will
continue
to
be
addressed
through
appropriate
precautionary
labeling
statements.

(
d)
Occupational
Handler
Scenarios
with
Non­
Cancer
Inhalation
Risk
Concerns
Arsenic:
The
MOEs
for
the
inhalation
exposure
scenarios
presented
in
the
risk
assessment
do
not
exceed
the
Agency's
level
of
concern
(
i.
e.,
MOEs
<
100)
for
short­
term
and
intermediate­
term
exposures
to
arsenic.

Chromium
VI:
Although
all
of
the
inhalation
exposure
samples
were
below
the
limit
of
detection,
the
MOEs
for
the
inhalation
exposure
using
½
LOD
still
exceed
the
Agency's
level
of
concern
(
i.
e.
MOEs
<
100)
for
short­
term,
intermediate­
term,
and
long­
term
durations.
Inhalation
MOEs
for
chromium
are
presented
below.

Short­
Term,
Intermediate­
Term,
and
Long­
Term
°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)
and
treatment
assistant
(
TA)]
(
MOEs
of
concern,
MOEs
=
7
for
TO,
and
7
for
TA);

(
e)
Occupational
Handler
Scenarios
with
Cancer
Risk
Concerns
Dermal
and
Inhalation
Exposure:
Cancer
Carcinogenic
endpoints
related
to
lifetime
dermal
and
inhalation
exposures
to
arsenic,
and
inhalation
exposure
to
chromium
VI
have
been
identified.
In
general,
the
Agency
is
concerned
when
occupational
cancer
risk
estimates
exceed
1
x
10­
4
(
E­
4)
.
The
Agency
will
seek
ways
to
mitigate
the
38
risks,
to
the
extent
that
it
is
practical
and
economically
feasible,
to
lower
the
risks
to
1
x
10­
6
(
E­
6)
or
less.
The
following
handler
scenarios
have
cancer
risks
between
1
x
10­
5
(
E­
5)
and
1
x
10­
2
(
E­
2)
at
the
assessed
level
of
mitigation.
Cancer
risks
for
each
scenario
are
presented
in
Table
16.

Arsenic:

Lifetime
Dermal
Cancer
Risk
(
>
E­
4
)

°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)
and
treatment
assistant
(
TA)]
(
risks
of
concern
=
4.1E­
3
for
TO,
and
1.4E­
3
for
TA
);
and
Lifetime
Inhalation
Cancer
Risk
(
>
E­
4
)

°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)
and
treatment
assistant
(
TA)]
(
risks
of
concern
=
2.0E­
4
for
TO,
and
1.2E­
4
for
TA);
and
Chromium
VI:

Lifetime
Inhalation
Cancer
Risk
(
>
E­
4
)

°
Applying
Liquid
Formulations
at
Pressure
Treatment
Plants
Using
an
Automatic/
Closed
Delivery
System
(
Opening
and
Closing
the
Retort)
[
treatment
operator
(
TO)
and
treatment
assistant
(
TA)]
(
risks
of
concern
=
1.7E­
4
for
TO,
and
1.6E­
4
for
TA);
and
(
4)
Postapplication
Exposures
and
Risks
The
Agency
has
determined
that
there
are
potential
exposure
concerns
relating
to
postapplication
exposure
to
CCA.
There
are
potential
exposures
following
applications
of
concentrated
chromated
arsenical
preservatives
in
industrial
settings
and
chromated
arsenical
end
use
products
manufactured
for
commercial,
industrial,
and
residential
use
sites.
The
potential
individual
postapplication
exposures
are
outlined
below
in
the
occupational
postapplication
sections.

(
a)
Occupational
Postapplication
Exposure
Postapplication
exposure
occurs
following
the
application
of
a
pesticide
product.
In
the
wood
pressure
treatment
plants,
postapplication
occurs
when
job
functions
require
that
there
be
contact
with
freshly
treated
wood
and
pressure
treatment
machinery
(
e.
g.
retort
door)
or
pipes.
Or
when
occupying
treatment
areas
directly
after
pesticide
applications.
A
brief
description
of
the
worker
job
functions/
activities
for
treatment
plant
workers
used
in
developing
the
occupational
postapplication
scenarios
is
presented
in
Table
16.
Postapplication
exposures
attributed
to
workers
involved
with
nonpressure
treatment
use
patterns
were
not
assessed
in
this
document.
.
39
Table
16.
Exposure
Scenarios
for
Occupational
Postapplication
Exposures
Exposure
Scenario
Scenario
Description
Pressure
Treatment
Activities
(
1)
Loader
Operator
Scenario
pertains
to
a
formulating
facility
or
wood
pressure
treatment
facility.
Worker
operates
self­
propelled
vehicles
that
are
used
to
load
wood
products
onto
and
off
of
trams,
and
to
move
charges
into
and
out
of
treatment
cylinders
and
to
and
from
load
out
areas.
Worker
may
perform
certain
out­
of­
cab
tasks
such
as
collect
tank
samples,
perform
test
boring
and
lab
analysis
of
treatment
solutions
of
wood.

(
2)
Test
Borer
Scenario
pertains
to
a
wood
pressure
treatment
facility.
Worker
takes
pole
cores
to
test
for
CCA
penetration.
May
also
test
concentration
of
lots
of
CCA,
and
perform
other
QC
laboratory
duties.

(
3)
Tram
Setter
Positions
trams
for
loading,
places
wood
spacers
on
trams
where
needed
to
elevate
wood
to
be
treated.
Does
all
lead
and
chain
handling
for
that
site.
Removes
and
shreds
all
bands
from
treated
stacks
of
lumber.
Sweeps
and
pressure­
washes
pad
areas.
Picks
up
and
disposes
of
treated
wood
waste.
May
also
perform
various
labor
and
cleanup
duties
in
drip
pad
area.

(
4)
Supervisor
Supervisor
duties
were
not
fully
described
in
the
study
report.

(
5)
Tally
Man
Main
duties
include
counting
and
inspection
of
incoming
and
outgoing
truckloads
of
wood
products,
and
supervision
of
loading
and
unloading
of
lumber
trucks
at
drip
pad
and
elsewhere.
May
also
perform
some
treatment­
related
duties,
such
as
end­
marking
of
treated
items
or
chaining
of
charges
for
treatment.
His
office
was
located
immediately
adjacent
to
the
drip
pad.

(
6)
Stacker
Operator
Operates
a
lumber
stacking
device,
which
arranges
treated
boards
in
stacks
for
banding
and
shipment
to
customers,
and
removes
wood
spacer
sticks
from
bundles
of
treated
boards.
This
worker
manually
positions
ends
of
all
treated
boards
moving
through
device
so
they
are
evenly
positioned.

(
5)
Occupational
Postapplication
Data,
Assumptions,
Exposure,
and
Risk
Calculations
(
a)
Postapplication
Data
"
Assessment
of
Potential
Inhalation
and
Dermal
Exposure
Associated
with
Pressure
Treatment
of
Wood
with
Arsenical
Products"
(
MRID
455021­
01)
submitted
by
the
American
Chemistry
Council
(
ACC,
2001).
This
study
was
described
in
more
detail
in
section
B.
2.
a
(
Handler
Exposure
Data
section).
Postapplication
exposure
was
assessed
using
the
results
of
the
ACC
study
based
on
the
exposure
analyses
for
the
Loader
Operator,
Test
Borer,
Tram
Setter,
Stacker
Operator,
and
Tally
Man.
Note
that
these
job
functions
represent
the
bulk
of
the
monitored
worker
tasks
which
included
postapplication
activities.
The
data
for
these
studies
were
presented
in
Tables
4,
5,
7
and
8
in
Section
B.
2.
a
and
were
used
to
establish
exposure
doses
and
risks
for
this
assessment.
In
addition
to
the
ACC
study
which
was
used
to
develop
the
human
exposure
chapter,
two
CCA­
specific
inhalation
studies
were
also
submitted
to
EPA
for
review
(
MRID
447595­
02
and
the
PEL
RPAR
study).

A
study
by
the
Chemical
Manufacturer's
Association
(
CMA)
entitled
the
"
Report
on
Monitoring
of
Workers
in
Wood
Treating
Plants
Using
Arsenical
Pressure
Treatment
Wood
Preservatives
under
RPAR
PEL
Requirements"
was
submitted
to
EPA
as
part
of
the
reregistration
requirements.
This
study
40
summarized
monitoring
data
for
airborne
arsenic
in
wood
treating
plants
using
CCA
and
AZCA.
The
monitoring
data
were
collected
between
1991
and
1999
from
220
wood
treating
plants
in
the
United
States,
under
the
RPAR
PEL
monitoring
program.
Table
17
provides
the
airborne
arsenic
levels
of
the
PEL
study.
Chromium
exposure
data
were
not
presented
in
the
PEL
RPAR
study.

Another
worker
inhalation
study
(
MRID
447595­
02)
that
assessed
exposures
to
CCA,
creosote,
and
pentachlorophenol
was
completed
in
1982
by
Koppers
Company,
Inc.
and
was
submitted
to
EPA
via
the
CMA
Biocides
Panel,
Arsenic
Acid
Task
Force
on
February
4,
1999.
This
study
assessed
the
exposures
of
pressure
treatment
plant
employees
involved
in
the
production
of
treated
wood
products
in
five
pressure
treatment
facilities.
Limited
information
was
provided
regarding
the
sampling
methods
and
the
quality
assurance
(
QA)
and
quality
control
(
QC)
of
the
study.
Although
this
study
did
not
provide
QA/
QC
information
and
is
not
current,
it
presents
chromium
exposure
information.
Study
results
are
presented
in
Table
18.
Because
the
the
CMA
studies
did
not
fully
meet
Series
875
guidelines,
the
ACC
study
was
used
exclusively
to
evaluate
occupational
postapplication
exposure.

Table
17.
Statistical
Summary
of
Inhalation
Exposure
Levels
of
Airborne
Arsenic
in
Wood
Treating
Plants
Using
CCA
Collected
under
the
PEL
Program
Job
Categories
Number
of
Replicates
Inhalation
Exposure
Levels
of
Airborne
Arsenic
(
µ
g/
m3)

Mean
Standard
Deviation
Geometric
Mean
Maximum
Minimum
Forklift
Operator
215
2.56
5.22
0.52
47.7
0.01
Drip
Pad
Worker
127
2.76
5.32
0.41
37.8
0.002
Lumber
Stacker
17
0.67
1.31
0.25
5.3
0.03
Lumber
Tagger
14
1.27
1.74
0.19
4.7
0.01
Maintenance
6
3.53
3.85
0.86
10.51
0.03
41
Inhalation
MOE

Inhalation
LOAEL
(
mg/
kg/
day)
Inhalation
Dose
(
mg/
kg/
day)
Table
18.
Inhalation
Exposure
to
CCA
in
a
Pressure
Treatment
Process
using
8­
hour
Time­
Weighted
Averages
(
TWAs)

Job
Classification
#
of
Workers
Monitored
Chromium
(
Cra)
Arsenic
(
As)

Lift
Truck
Operator
29
GM
<
5.6
±
3.0
Range
<
0.9­
27
GM
1.4
±
3.5
Range
0.03­
15
Stacker
24
GM
<
2.1
±
2.2
Range
<
1.2­
7
GM
1.0
±
2.5
Range
0.05­
7
Striker
5
GM
<
4
±
2.0
Range
<
1.2­
7
GM
2.2
±
6.5
Range
0.03­
3
Maintenance
3
GM
8.7
±
1.4
Range
6­
12
GM
2.2
±
3.9
Range
0.6­
9
Plant
Office
3
GM
0.3
±
3.2
Range
0.1­
1
GM
0.1
±
1.5
Range
0.1­<
0.2
All
Exposures
70
GM
3.2
±
3.1
Range
0.1­
27
GM
1.1
±
3.1
Range
0.03­
15
a
GM­
geometric
mean
and
geometric
standard
deviation
Range­
minimum
and
maximum
concentrations
(
b)
Short­,
Intermediate­,
and
Long­
Term
Inhalation
Exposure
and
Non­
Cancer
Risk
Calculations
The
postapplication
inhalation
exposure
assessments
were
completed
by
EPA
using
the
chemicalspecific
data
from
MRID
455021­
01
which
examined
postapplication
exposures
to
workers
in
CCA
pressure
treatment
facilities.
For
these
scenarios,
the
doses
were
already
presented
in
the
study
report
(
see
Tables
7
and
8).
Geometric
mean
doses
were
used
in
the
MRTD
455021­
01
study
and
are
presented
in
Table
19.
Occupational
postapplication
non­
cancer
MOE's
and
cancer
risks
are
presented
in
Table
20.

(
i)
Inhalation
Dose
Inhalation
doses
were
already
presented
in
the
ACC
study
(
MRID
455021­
01).
The
results
of
this
study
were
used
directly
in
this
report.

(
ii)
Inhalation
Risk
Inhalation
risks
from
short­,
intermediate­,
and
long­
term
exposures
to
arsenic
and
chromium
have
been
identified.
The
following
formula
describes
the
calculation
of
an
inhalation
MOE:
42
For
the
arsenic
assessment
a
LOAEL
of
0.05
mg/
kg/
day
was
used
for
the
short­
term
and
intermediate­
term
exposures
(
uncertainty
factor
of
100),
and
a
NOAEL
of
0.0008
mg/
kg/
day
was
used
for
long­
term
arsenic
inhalation
estimates
(
uncertainty
factor
of
3
applied).

For
the
chromium
VI
assessment
a
LOAEL
of
0.002
mg/
m3
was
used
for
all
durations.
The
ambient
air
concentration
of
the
LOAEL
was
then
converted
to
a
dose
in
units
of
mg/
kg/
day
for
comparison
with
inhalation
doses
estimated
in
this
exposure
assessment.
Therefore,
the
air
concentration
of
the
LOAEL
was
multiplied
by
the
inhalation
rate
of
8
m3/
workday
and
divided
by
a
body
weight
of
70
kg
to
arrive
at
a
LOAEL
of
2.3
x
10­
4
mg/
kg/
day.
The
EPA
recommended
target
MOE
of
100
is
used
for
this
risk
assessment
(
i.
e.,
10x
intra
variability
for
human
study,
3x
for
lack
of
a
NOAEL,
and
3x
modifying
factor
for
epidemiological
study
and
to
convert
to
a
long­
term
or
"
lifetime"
duration).
43
Table
19.
Occupational
Short­,
Intermediate­,
and
Long­
term
Postapplication
Doses
to
CCA
Dermal
a
Inhalation
b
Exposure
Scenario
(
Scen.
#)
Chemical
of
Concern
Short­,
Intermediate­,

and
Long­
Term
Daily
Dose
(
mg/
kg/
day)
c
Lifetime
Average
Daily
Dose
(
mg/
kg/
day)
e
Short­,
Intermediate­,

and
Long­
term
Daily
Dose
(
mg/
kg/
day)
d
Lifetime
Average
Daily
Dose
(
mg/
kg/
day)
e
(
1)
Loader
Operator
(
LO)
Arsenic
(
As)
0.0024
0.00089
8.6E­
5
3.1E­
5
Chromium
(
Cr+
6)
NA
NA
4.0E­
5
1.5E­
5
(
2)
Test
Borer
(
TB)
Arsenic
(
As)
0.00019
6.8E­
5
3.4E­
5
1.2E­
5
Chromium
(
Cr+
6)
NA
NA
NA
NA
(
3)
Tram
Setter
(
TS)
Arsenic
(
As)
0.0063
0.0023
2.56E­
4
9.4E­
5
Chromium
(
Cr+
6)
NA
NA
4.0E­
5
1.5E­
5
(
4)
Supervisor
(
S)
Arsenic
(
As)
0.0031
0.0011
1.54E­
4
5.6E­
5
Chromium
(
Cr+
6)
NA
NA
4.2E­
5
1.5E­
5
(
5)
Tally
Man
(
TM)
Arsenic
(
As)
0.0028
0.0010
4.4E­
5
1.6E­
5
Chromium
(
Cr+
6)
NA
NA
NA
NA
(
6)
Stacker
Operator
(
SO)
Arsenic
(
As)
0.0013
0.00048
3.3E­
5
1.2E­
5
Chromium
(
Cr+
6)
NA
NA
3.3E­
5
1.2E­
5
Footnotes:

a
Dermal
exposure
is
based
on
MRID
455021­
01.
See
Table
4
for
geometric
mean
dermal
exposure
for
As.

b
Inhalation
exposure
is
based
on
MRID
455021­
01.
See
Tables
7
&
8
for
geometric
mean
inhalation
exposures
for
As
and
Cr+
6.

c
Calculations
for
short­,
intermediate­,
and
long­
term
dermal
daily
dose
(
mg/
kg/
day)
=
geo
mean
daily
dermal
dose
for
As
in
Table
4
in
units
of

g/
kg
x
0.001
mg/

g
unit
conversion
x
(
ABS/
100).
ABS
is
6.4%
for
arsenic.

d
Calculations
for
short­,
intermediate­,
and
long­
term
inhalation
daily
dose
(
mg/
kg/
day)
=
geo
mean
daily
inhalation
dose
for
As
or
Cr+
6
from
Tables
7
and
8
in
units
of

g/
kg
x
0.001
mg/

g
unit
conversion..

e
Lifetime
Average
Daily
Dose,
LADD
(
mg/
kg/
day)
=
geo
mean
daily
dermal
or
inhalation
dose
from
Tables
4,
7,
8
in
units
of

g/
kg
x
0.001
mg/

g
unit
conversion
x
dermal
ABS/
100
x
(
250
days
worked
per
yr/
365
days
per
year)
x
(
40
working
years/
75
yr
lifetime).

NA
Not
applicable
44
Table
20.
Occupational
Short­,
Intermediate­,
and
Long­
term
Postapplication
Risks
to
CCA
Exposure
Scenario
(
Scen.
#)
Chemical
of
Concern
Dermal
Inhalation
Short­,

and
Intermediateterm
MOEa
Long­
term
MOEb
Cancer
Riskc
Short­,

and
Intermediateterm
MOEd
Long­
term
MOEe
Cancer
Riskf
(
1)
Loader
Operator
(
LO)
Arsenic
(
As)
21
0.3
3.3E­
3
581
9
1.6E­
4
Chromium
(
Cr+
6)
NA
NA
NA
6
6
2.0E­
4
(
2)
Test
Borer
(
TB)
Arsenic
(
As)
27
4
2.5E­
4
1471
24
6.3E­
5
Chromium
(
Cr+
6)
NA
NA
NA
NA
NA
NA
(
3)
Tram
Setter
(
TS)
Arsenic
(
As)
8
0.1
8.4E­
3
195
3
4.7E­
4
Chromium
(
Cr+
6)
NA
NA
NA
6
6
2.0E­
4
(
4)
Supervisor
(
S)
Arsenic
(
As)
16
0.3
4.1E­
3
325
5
2.8E­
4
Chromium
(
Cr+
6)
NA
NA
NA
6
6
2.1E­
4
(
5)
Tally
Man
(
TM)
Arsenic
(
As)
18
0.3
3.8E­
3
1136
18
8.0E­
5
Chromium
(
Cr+
6)
NA
NA
NA
NA
NA
NA
(
6)
Stacker
Operator
(
SO)
Arsenic
(
As)
38
0.6
1.8E­
3
1515
24
6.0E­
5
Chromium
(
Cr+
6)
NA
NA
NA
6
6
1.6E­
4
Footnotes:

a
Short­
and
Intermediate­
term
dermal
MOE
=
dermal
NOAEL
/
Short­
and
Intermediate­
term
dermal
daily
dose
(
mg/
kg/
day).
Where
As
LOAEL
=
0.05
mg/
kg/
day.

b
Long­
term
MOE
=
dermal
NOAEL/
Long­
term
dermal
daily
dose
(
mg/
kg/
day).
Where
As
NOAEL
=
0.0008
mg/
kg/
day.

c
Dermal
Cancer
Risk
=
slope
factor
x
dermal
LADD.
Where
arsenic
cancer
slope
factor
=
3.67
(
mg/
kg/
day)­
1
.

d
Short­,
Intermediate­
term
inhalation
MOE
=
inhalation
NOAEL
/
Short­,
Intermediate­
term
inhalation
dose
(
mg/
kg/
day).
Where
As
LOAEL
=
0.05
mg/
kg/
day,
and
Cr
+
6
LOAEL
=
2.3
x
10­
4
mg/
kg/
day
(
derived
from
a
LOAEL
=
0.002
mg/
m3).

e
Long­
term
inhalation
MOE
=
inhalation
NOAEL
or
LOAEL
/
long­
term
inhalation
dose.
Where
As
NOAEL
=
0.0008
mg/
kg/
day
and
Cr+
6
LOAEL
=
2.3
x
10­
4
mg/
kg/
day
(
derived
from
a
LOAEL
=
0.002
mg/
m3).

f
Inhalation
Cancer
Risk
=
cancer
slope
factor
x
inhalation
LADD.
Where
arsenic
cancer
slope
factor
for
an
8­
hour
work
day
=
5
(
mg/
kg/
day)­
1
and
Cr+
6
inhalation
cancer
slope
factor
=
13.5
(
mg/
kg/
day)­­
1.

NA
Not
applicable
NOTE:
Recommended
Dermal
MOE
for
Arsenic:
short­
and
intermediate­
term
=
30
(
10x
intraspecies
variation
and
3x
for
the
use
of
the
LOAEL);
long­
term
=
3
(
3x
rather
than
10x
because
of
the
large
sample
size
in
the
toxicity
study
(>
40,000)).

Recommended
Inhalation
MOE
for
Arsenic:
short­
and
intermediate­
term
=
100
(
10x
intraspecies
variation
and
3x
for
the
use
of
the
LOAEL),
long­
term
=
3
(
3x
rather
than
10x
because
of
the
large
sample
size
in
the
toxicity
study
(>
40,000)).

Recommended
Inhalation
MOE
for
Chromium
VI:
All
durations
=
100
(
10x
intraspecies
variation,
3x
for
use
of
a
LOAEL,
and
3x
modifying
factor
for
epidemiological
study
and
to
convert
to
a
long­
term
or
"
lifetime"
duration).
45
Dermal
MOE

Dermal
NOAEL
(
mg/
kg/
day)
Dermal
Dose
(
mg/
kg/
day)

Lifetime
Average
Daily
Dose
mg
ai
kg/
day

[
Chronic
Dose
(
mg/
kg/
day)]
x
EF
(
days/
yr)
x
ED
(
yrs)
365
days/
yr
x
Lifetime
(
yrs)
(
c)
Short­,
Intermediate­,
and
Long­
Term
Dermal
Exposure
and
Non­
Cancer
Risk
Calculations
The
postapplication
dermal
exposure
assessments
were
completed
by
EPA
using
the
chemicalspecific
data
from
ACC's
MRID
455021­
01
which
examined
postapplication
exposures
to
workers
in
CCA
pressure
treatment
facilities.
For
these
scenarios,
the
doses
were
already
presented
in
the
study
report
(
see
Tables
4
and
5).
Geometric
mean
doses
were
used
in
the
study
and
are
presented
in
Table
19.
Note
that
the
dermal
doses
were
adjusted
by
the
appropriate
dermal
absorption
factor
to
calculate
an
absorbed
dose.
This
is
done
because
the
toxicity
value
is
based
on
oral
absorbed
doses.
Occupational
postapplication
non­
cancer
MOE's
and
cancer
risks
are
presented
in
Table
20.

(
i)
Dermal
Dose
Dermal
doses
were
already
presented
in
the
ACC
study
(
MRID
455021­
01).
The
doses
used
in
this
study
were
used
directly
in
this
report
with
the
exception
that
the
dermal
doses
were
adjusted
by
the
dermal
absorption
factor
because
the
dermal
toxicity
information
used
is
based
on
oral
toxicity
data.

(
ii)
Dermal
Risk
Dermal
risks
from
short­,
intermediate­,
and
long­
term
exposures
to
arsenic
and
chromium
have
been
identified.
The
following
formula
describes
the
calculation
of
an
inhalation
MOE:

The
short­
and
intermediate­
term
LOAEL
for
arsenic
is
0.05
mg/
kg/
day
and
the
long­
term
LOAEL
for
arsenic
is
0.0008
mg/
kg/
day
.
The
uncertainty
factor
used
is
30
for
short­
and
intermediate
term
endpoints
and
3
for
long­
term
endpoints.
Because
the
dermal
irritation
and
dermal
sensitization
of
chromium
are
the
primary
concern
through
the
dermal
exposure
route,
no
toxic
endpoint
is
selected.
The
risk
concern
should
be
addressed
through
labeling.

(
d)
Postapplication
Exposure
Cancer
Risk
Calculations
The
following
formula
describes
the
calculation
of
the
lifetime
average
daily
dose:
46
Risk

LADD
mg
ai
kg/
day
x
Cancer
Slope
Factor
1
(
mg/
kg/
day)
Risk
was
calculated
by
multiplying
the
lifetime
average
daily
dose
times
the
cancer
slope
factor
using
the
following
formula:

(
6)
Occupational
Postapplication
Risk
Assessment
and
Characterization
(
a)
Postapplication
Non­
Cancer
Risks
from
Dermal
Exposure
Arsenic:
Acute,
subchronic,
and
chronic
toxicity
endpoints
related
to
dermal
exposures
to
arsenic
have
been
identified.
The
Agency's
level
of
concern
for
arsenic
from
dermal
exposure
is
as
follows:
short­
term
and
intermediate­
term
(
MOEs
<
30)
and
long­
term
(
MOEs
<
3).
All
the
scenarios
that
exceed
the
Agency's
level
of
concern
for
dermal
non­
cancer
exposure
for
arsenic
are
presented
below.

Short­
Term
and
Intermediate­
Term
°
Loader
Operator
(
MOE
of
concern,
MOE
=
21);
°
Tram
Setter
(
MOE
of
concern,
MOE
=
8);
°
Supervisor
(
MOE
of
concern,
MOE
=
16);
°
Tally
Man
(
MOE
of
concern,
MOE
=
18);
and
°
Test
Borer
(
MOE
of
concern,
MOE
=
27).

Long­
Term
°
Loader
Operator
(
MOE
of
concern,
MOE
=
0.3);
°
Test
Borer
(
MOE
of
concern,
MOE
=
4);
°
Tram
Setter
MOE
of
concern,
(
MOE
=
0.1);
°
Supervisor
(
MOE
of
concern,
MOE
=
0.3);
°
Tally
Man
(
MOE
of
concern,
MOE
=
0.3);
and,
°
Stacker
Operator
(
MOE
of
concern,
MOE
=
0.6).

Chromium
VI:
Since
dermal
irritation
and
dermal
sensitization
are
the
primary
exposure
concerns
through
the
dermal
route,
no
toxicological
endpoint
was
selected
for
use
in
assessing
dermal
postapplication
exposure
risks
to
chromium.
Risk
mitigation
will
continue
to
be
addressed
through
appropriate
precautionary
labeling
statements.

(
b)
Postapplication
Non­
Cancer
Risks
from
Inhalation
Exposure
Arsenic:
Acute,
sub­
chronic,
and
chronic
toxicity
endpoints
related
to
inhalation
exposures
to
arsenic
have
been
identified.
The
Agency's
level
of
concern
for
arsenic
from
inhalation
exposure
is
as
follows:
short­
term
and
intermediate­
term
(
MOEs
<
100)
and
long­
term
(
MOEs
<
3).
The
MOEs
for
the
inhalation
exposure
scenarios
presented
in
the
risk
assessment
do
not
exceed
the
Agency's
level
of
concern.
47
Chromium
VI:
The
MOEs
for
the
inhalation
exposure
scenarios
presented
in
the
risk
assessment
exceed
the
Agency's
level
of
concern
for
short­
term,
intermediate­
term,
and
long­
term
inhalation
exposures
to
chromium
VI
(
i.
e.,
MOEs
<
100)
based
on
the
toxicological
information
for
Chromium
(
VI).
Inhalation
exposures
at
½
LOD
(
all
samples
non
detect)
are
exceeded
for
all
assessed
postapplication
exposure
scenarios
as
follows:

Short­
Term,
Intermediate­
Term,
and
Long­
Term
°
Loader
Operator
(
MOE
of
concern,
MOE
=
6);
°
Test
Borer
(
scenario
not
assessed
for
chromium);
°
Tram
Setter
(
MOE
of
concern,
MOE
=
6);
°
Supervisor
(
MOE
of
concern,
MOE
=
6);
°
Tally
Man
(
scenario
not
assessed
for
chromium);
and,
°
Stacker
Operator
(
MOE
of
concern,
MOE
=
6).

(
c)
Postapplication
Dermal
and
Inhalation
Scenarios
with
Cancer
Risks
Dermal
and
Inhalation
Exposure:
Cancer
Carcinogenic
endpoints
related
to
lifetime
dermal
and
inhalation
exposures
to
arsenic,
and
inhalation
exposure
to
chromium
VI
have
been
identified.
In
general,
the
Agency
is
concerned
when
occupational
cancer
risk
estimates
exceed
1
x
10­
4
(
E­
4)
.
The
Agency
will
seek
ways
to
mitigate
the
risks,
to
the
extent
that
it
is
practical
and
economically
feasible,
to
lower
the
risks
to
1
x
10­
6
(
E­
6)
or
less.
The
following
worker
scenarios
have
cancer
risks
between
1
x
10­
5
(
E­
5)
and
1
x
10­
2
(
E­
2)
at
the
assessed
level
of
mitigation.
Occupational
postapplication
cancer
risks
for
each
scenario
are
presented
in
Table
20.

Arsenic:

Lifetime
Dermal
Cancer
Risk
(
>
E­
4
)

°
Loader
Operator
(
risk
of
concern
=
3.3E­
3);
°
Test
Borer
(
risk
of
concern
=
2.5E­
4);
°
Tram
Setter
(
risk
of
concern
=
8.4E­
3);
°
Supervisor
(
risk
of
concern
=
4.1E­
3);
°
Tally
Man
(
risk
of
concern
=
3.8E­
3);
and,
°
Stacker
Operator
(
risk
of
concern
=
1.8E­
3).

Lifetime
Inhalation
Cancer
Risk
(
>
E­
4
)

°
Loader
Operator
(
risk
of
concern
=
1.6E­
4);
°
Test
Borer
(
risk
of
concern
=
6.3E­
5);
°
Tram
Setter
(
risk
of
concern
=
4.7E­
4);
°
Supervisor
(
risk
of
concern
=
2.8E­
4);
°
Tally
Man
(
risk
of
concern
=
8.0E­
5);
and,
°
Stacker
Operator
(
risk
of
concern
=
6.0E­
5).
48
Chromium
VI:

Lifetime
Inhalation
Cancer
Risk
(
>
E­
4
)

°
Loader
Operator
(
risk
of
concern
=
2.0E­
4);
°
Test
Borer
(
scenario
not
assessed
for
chromium);
°
Tram
Setter
(
risk
of
concern
=
2.0E­
4);
°
Supervisor
(
risk
of
concern
=
2.1E­
4).
°
Tally
Man
(
scenario
not
assessed
for
chromium);
and,
°
Stacker
Operator
(
risk
of
concern
=
1.6E­
4).

(
7)
Data
Gaps,
Uncertainties,
and
Limitations
ACC's
Worker
Exposure
Study
(
MRID
455021­
01)

The
study
met
most
of
Series
875
guideline
requirements.
The
method
validation,
field
fortifications,
and
QA/
QC
were
thoroughly
explained;
however,
some
minor
issues
are
as
follows:
(
1)
differences
in
chemical
usage
versus
exposure
along
with
work
practices
among
facilities
were
not
examined
thoroughly
by
EPA
at
this
time;
(
2)
data
were
corrected
based
on
field
recovery;
however,
only
the
corrected
data
were
presented
in
the
study;
(
3)
the
limit
of
detection
for
chromium
VI
was
not
sensitive
enough
based
on
the
endpoints
selected
for
the
risk
assessment;
and
(
4)
separate
field
fortifications
were
not
collected
for
each
worker.
The
CCA
worker
exposure
study
is
currently
under
going
additional
analysis
to
determine
the
differences
among
the
sites
and
to
determine
potential
mitigation
measures.
Preliminary
results
indicate
higher
exposures
at
the
Canadian
site
that
are
attributed
to
the
lack
of
the
final
vacuum
procedure
during
the
pressure
treatment
process.

PEL
Study
A
study
by
the
Chemical
Manufacturer's
Association
(
CMA)
study
entitled
the
"
Report
on
Monitoring
of
Workers
in
Wood
Treating
Plants
Using
Arsenical
Pressure
Treatment
Wood
Preservatives
under
RPAR
PEL
Requirements"
was
submitted
to
EPA
as
part
of
the
PEL
monitoring
program.
Although
these
data
were
not
used
to
calculate
handler
or
postapplication
inhalation
exposures
to
arsenic
or
chromium,
the
major
issues
of
concern
with
the
PEL
inhalation
monitoring
data
are
identified
as
follows:

°
Guideline
875.1400
requires
that
five
replicates
each
at
a
minimum
of
three
representative
indoor
sites
(
i.
e.,
a
total
of
15
replicates)
should
be
evaluated
for
each
job
category.
In
this
study,
for
CCA,
the
number
of
replicates
for
job
categories
of
lumber
tagger
and
maintenance
workers
is
less
than
15.

°
It
could
not
be
determined
from
the
study
report
if
QA/
QC
samples
required
by
Guideline
875.1400
were
analyzed
under
the
PEL
monitoring
program.
These
QA/
QC
samples
include
field
blanks,
laboratory­
fortified
samples,
and
field
fortified
samples.

°
It
could
not
be
determined
from
the
study
report
if
the
trapping
efficiency
for
arsenic
on
the
trapping
medium
was
tested.
49
°
PEL
data
presents
data
only
for
inhalation
exposure
of
arsenic
and
not
inhalation
exposure
of
chromium
VI.

NIOSH
studies
Two
CCA
inhalation
exposure
studies
were
conducted
by
the
National
Institute
for
Occupational
Safety
and
Health
(
NIOSH)
and
were
submitted
by
industry
to
EPA
(
MRID
426337­
11
and
426337­
13).
These
data
were
not
used
to
calculate
handler
exposures
to
arsenic
or
chromium
for
this
RED
chapter.
No
postapplication
exposures
were
examined
in
this
study.
The
major
issues
of
concern
with
the
NIOSH
inhalation
monitoring
data
are
identified
as
follows:

°
The
study
was
conducted
in
1980
as
a
Industrial
Hygiene
Report
and
was
not
meant
to
be
a
FIFRA
compliant
study
under
875­
Subdivision
U
requirements.

°
The
study
was
conducted
at
only
one
facility
where
a
maximum
of
three
air
sampling
replicates
were
collected.
FIFRA
requirements
stipulate
at
least
five
replicates
at
each
of
at
least
three
test
sites
for
each
job
function.

°
Information
was
not
provided
on
the
amount
of
each
active
ingredient
handled
by
the
test
subjects.

°
Insufficient
data
were
provided
on
the
sample
storage
stability
and
extraction
efficiency.

°
Quality
control
procedures
for
this
study
were
unacceptable.
The
study
did
not
include
any
field
blanks.
Both
reagent
and
method
blanks
should
have
been
prepared.

°
There
were
no
field
or
laboratory
spikes
for
the
air
sampling
trains
to
check
the
recoveries
of
the
method,
nor
any
quantification
limits
provided.

°
This
study
should
have
also
included
dosimeter
sampling
on
the
workers
to
determined
actual
dermal
exposure
while
working.

°
Exposure
to
arsenic
for
the
treatment
operator
and
treatment
helper
during
retort
opening
varied
by
three
orders
of
magnitude.

°
A
FIFRA
compliant
study
would
need
to
be
conducted
in
order
to
adequately
evaluate
the
risk
at
these
type
of
facilities.

Another
study
(
MRID
447595­
02)
of
worker
inhalation
exposure
to
CCA,
Creosote,
and
Pentachlorophenol
was
completed
in
1982
by
Koppers
Company,
Inc.
and
was
submitted
to
EPA
via
the
CMA
Biocides
Panel,
Arsenic
Acid
Task
Force
on
February
4,
1999.
This
study
assessed
the
postapplication
exposures
of
pressure
treatment
plant
employees
involved
in
the
production
of
treated
wood
products
in
five
pressure
treatment
facilities.
Limited
information
was
provided
regarding
the
sampling
methods
and
the
quality
assurance
(
QA)
and
quality
control
(
QC)
of
the
study.
This
study
does
not
provide
QA/
QC
information
and
is
not
current
and
has
not
been
used
in
this
risk
assessment.
50
(
8)
Results
Summary
Handler
The
results
of
the
handler
exposure
and
risk
assessment
indicate
that
short­,
intermediate­,
and
longterm
risks
for
dermal
and
inhalation
exposures
exceed
the
level
of
concern
for
arsenic
for
some
of
the
handler
scenarios.
For
arsenic,
a
margin
of
exposure
(
MOE)
of
30
or
more
for
short­
and
intermediateterm
dermal
risk
is
considered
acceptable
and
an
MOE
of
3
or
more
is
considered
acceptable
for
longterm
risks.
Handler
risks
for
dermal
exposure
of
arsenic
are
exceeded
for
some
scenarios.

The
MOEs
for
the
inhalation
exposure
scenarios
presented
in
the
risk
assessment
do
not
exceed
the
Agency's
level
of
concern
for
short­,
and
intermediate­
iterm
inhalation
exposures
to
arsenic
(
i.
e.,
MOEs
<
100)
based
on
the
toxicological
information
for
arsenic.
However,
an
assessed
scenario
exceeded
the
Agency's
level
of
concern
for
long­
term
inhalation
exposures
to
arsenic
(
i.
e.,
MOE
<
3).

The
MOEs
for
the
inhalation
exposure
scenarios
presented
in
the
risk
assessment
exceed
the
Agency's
level
of
concern
for
short­,
intermediate­
and
long­
term
inhalation
exposures
to
chromium
VI
(
i.
e.
MOEs
<
100)
for
some
of
the
handler
scenarios
based
on
the
toxicological
information
for
Chromium
(
VI).

In
addition,
cancer
risks
for
all
handler
dermal
and
inhalation
scenarios
exceed
the
level
of
concern
(
1E­
04)
for
occupational
handlers.
A
summary
table
is
presented
later
in
this
section
that
provides
each
exposure
pathway
in
the
RED;
the
overall
results
of
the
MOE
and
cancer
risk
evaluations;
and
identification
of
any
additional
data
that
would
prove
useful
in
reducing
the
uncertainties
of
the
MOE
and
cancer
risks.

Postapplication
Many
of
the
MOEs
for
the
dermal
exposure
scenarios
presented
in
the
risk
assessment
exceed
the
Agency's
level
of
concern
for
short­,
intermediate­
and
long­
term
dermal
exposures
to
arsenic.

The
MOEs
for
the
inhalation
exposure
scenarios
presented
in
the
risk
assessment
do
not
exceed
the
Agency's
level
of
concern
for
short­,
and
intermediate­
inhalation
exposures
to
arsenic
(
i.
e.,
MOEs<
100)
based
on
the
toxicological
information
for
arsenic.

The
MOEs
for
the
inhalation
exposure
scenarios
presented
in
the
risk
assessment
exceed
the
Agency's
level
of
concern
for
short­,
intermediate­
and
long­
term
inhalation
exposures
to
chromium
VI
(
i.
e.
MOEs
<
30)
for
some
of
the
postapplication
scenarios
based
on
the
toxicological
information
for
Chromium
(
VI).

In
addition,
cancer
risks
for
all
handler
dermal
and
inhalation
scenarios
exceed
the
level
of
concern
(
1E­
04)
for
postapplication.
A
summary
table
of
each
exposure
pathway
in
the
RED;
the
overall
results
of
the
MOE
and
cancer
risk
evaluations;
and
identification
of
any
additional
data
that
would
prove
useful
in
reducing
the
uncertainties
of
the
MOE
and
cancer
risks
is
presented
as
follows:
51
(
i)
Summary
Table
Table
21
summarizes
all
the
exposure
scenarios
and
the
sources
of
data
used
in
developing
this
RED
chapter.

Table
21.
Summary
of
the
Occupational
Exposure
Scenarios
Data
Exposure
Scenario
Source
of
Data
Occupational
Handler
Pressure
Treatments
(
1)
Applying
diluted
chromated
arsenical
liquid
treatment
solutions
at
a
pressure
treatment
plant
using
an
automated/
closed
delivery
system
(
opening
and
closing
the
retort).
ACC
Worker
Exposure
Study
Data
(
e.
g.
data
for
treatment
operator
and
treatment
assistant)
(
ACC,
2001)

Occupational
Postapplication
Pressure
Treatments
(
1)
Loader
Operator
ACC
Worker
Exposure
Study
Data
(
ACC,
2001)
(
2)
Test
Borer
(
3)
Tram
Setter
(
4)
Supervisor
(
5)
Tally
Man
(
6)
Stacker
Operator
Non­
Pressure
Treatments
(
1)
Pole
Installers
No
data.
Scenario
not
assessed.

(
ii)
Noncancer
MOEs
and
Cancer
Risks
Occupational
Handler
°
Scenario
1
exceeds
all
arsenic
dermal
MOEs
for
treatment
operator
and
long­
term
MOEs
for
treatment
assistant,
and
exceeds
all
chromium
inhalation
MOEs
and
all
cancer
risk
criteria.

Occupational
Postapplication
52
°
Scenario
6
exceeds
(
iii)
Data
Gaps
and
Limitations
The
following
is
a
summary
of
basic
data
gaps
and
limitations.

°
Chromium
inhalation
exposure
data
were
not
available
for
postapplication
exposure
for
scenarios
3
and
5.
53
3.0
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