UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Worker
Exposure
Study
Review:
Assessment
of
Potential
Inhalation
and
Dermal
Exposure
Associated
with
Pressure­
Treatment
of
Wood
with
Arsenical
Products,
Submitted
September
24,
2001
by
the
American
Chemistry
Council's
Arsenical
Wood
Preservatives
Task
Force.

TO:
Connie
Welch,
Chief
Adam
Heyward,
Product
Manager,
Team
34
Bonaventure
Akinlosotu,
Reregistration
Team
36
Regulatory
Management
Branch
II
Antimicrobials
Division
(
7510C)

FROM:
Doreen
Aviado,
Biologist
Team
Two
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

THRU:
Nader
Elkassabany,
Team
Leader
Team
Two
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

Norm
Cook,
Chief
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

DP
Barcode:
D278302
(
S604391)

Pesticide
Chemical
Arsenic
Acid/
006801
Name/
No.:
Chromated
Copper
Arsenate
(
CCA)/
128977
Reregistration
Case/
No.:
Chromated
Arsenicals/
0132
MRID
No.:
455021­
01
1
INTRODUCTION:

A
primary
review
was
conducted
by
contractor
staff
at
Versar,
Inc.
on
a
study
submitted
September
24,
2001
by
the
Arsenical
Wood
Preservatives
Task
Force
of
the
American
Chemistry
Council
(
ACC)
in
support
of
reregistration
data
requirements
for
Chromated
Copper
Arsenate
(
CCA)
and
related
chromated
arsenicals.
The
study
entitled
Assessment
of
Potential
Inhalation
and
Dermal
Exposure
Associated
with
Pressure­
Treatment
of
Wood
with
Arsenical
Products
is
further
identified
as
follows:

Title
Formulation,
Active
Ingredient
Identifying
Codes
Corporate
Sponsor
Performing
Laboratory
Assessment
of
Potential
Inhalation
and
Dermal
Exposure
Associated
with
Pressure­
Treatment
of
Wood
with
Arsenical
Products
Womanac
®
Concentrate
60%
CCA­
C
used
at
Test
Site
A
Timber
Specialties
K­
33
 
(
C­
60)
CCA
used
at
Test
Site
B
Chemonite
Part
A,
B
and
C
were
used
to
prepared
ACZA
MRID
No.
455021­
01;
AASI
Study
No.
AA9903089
Enviro­
Bio­
Tech
Project
No.
AS­
01­
99
Arsenical
Wood
Preservatives
Task
Force
Hasmukh
C.
Shah,
Ph.
D.
American
Chemistry
Council
1300
Wilson
Blvd.
Arlington,
VA
22209
Field
Mark
G.
Bookbinder,
Ph.
D.
(
Field
Investigator)
11157
Yellow
Leaf
Way
Germantown,
MD
20876­
1377
Phone/
FAX:
(
301)
540­
5622
Analytical
Harpal
Singh,
Ph.
D.
Enviro­
Bio­
Tech
Ltd.
140
Shartlesville
Road
Bernville,
PA
19506
The
contractor
review
focused
on
evaluating
the
study
for
compliance
with
the
Series
875
­
Occupational
and
Residential
Exposure
Test
Guidelines;
the
ACC's
study
data
addresses
application
exposure
monitoring
data
guidelines
875.1100
Dermal
Exposure­
Outdoor/
875.1200
Dermal
Exposure­
Indoor,
and
875.1300
Inhalation
Exposure­
Outdoor/
875.1400
Inhalation
Exposure­
Indoor.
Included
in
the
review
is
a
"
Checklist
for
Applicator
Monitoring
Data"
addressing
the
major
points
used
in
evaluating
the
study's
compliance
with
Series
875.
AD/
RASSB
reviewed
ACC's
submission
and
conducted
a
secondary
review
of
the
contractor
findings.
A
detailed
study
review
is
presented
herein
which
presents
an
overview
of
the
study
procedures
and
resulting
data,
and
assesses
the
technical
merits
of
the
data
as
a
source
of
exposure
information
for
developing
the
occupational
exposure
estimates
for
the
Chromated
Copper
Arsenate
(
CCA)
RED.

EXECUTIVE
SUMMARY:

This
study
assessed
the
potential
dermal/
inhalation
exposures
of
pressure
treatment
plant
employees
involved
in
the
production
of
treated
wood
products.
This
study
was
designed
to
estimate
individual
worker
exposure
to
Chromated
Copper
Arsenate
(
CCA)
Type
C
and
Ammoniacal
Copper
Zinc
Arsenate
(
ACZA)
compounds
while
performing
the
typical
job
functions
involved
in
commercial
arsenical
pressure
treatment
of
lumber
at
three
commercial
treatment
facilities
located
in
the
United
States
and
Canada
(
referred
to
as
Sites
A
through
C).
Four
end
use
products
for
CCA
and
ACZA
were
used.
Sixty­
four
workers
performing
26
job
functions
(
tasks)
were
monitored
for
each
8­
hour
shift.
Many
of
the
job
functions
were
performed
by
one
or
more
worker(
s)
in
a
variety
of
indoor/
outdoor
work
settings.
These
job
functions
fell
within
up
to
eight
job
categories
across
the
three
test
sites.
Where
a
single
worker
2
performed
the
duties
of
more
than
one
job
function,
he
or
she
was
identified
by
the
title
of
the
job
function
which
represented
the
majority
of
their
work
efforts.

Both
dermal
and
inhalation
exposure
levels
were
estimated
for
monitored
workers.
The
dermal
exposure
levels
were
estimated
by
passive
dosimetry
using
whole
body
dosimeters
(
WBDs)
and
cloth
dosimeter
gloves
worn
under
the
workers'
protective
clothing
and
chemical
resistant
gloves.
The
inhalation
exposure
levels
were
estimated
by
active
dosimetry
using
a
sampling
train
placed
in
the
worker's
breathing
zone
which
collected
residues
onto
a
PVC
filter
cassette.
The
air
was
pulled
through
the
sampling
train
by
a
portable
air
sampling
pump.

In
lieu
of
applying
known
quantities
of
a
characterized
metal
oxide
formulation
to
each
charge
of
wood
products,
study
personnel
collected
data
generated
by
the
application
system
for
each
treatment
made
during
the
monitored
period
at
each
test
site.
This
information
was
not
however
used
to
calculate
an
inhalation
or
dermal
unit
exposure
(
e.
g.,
usually
measured
in
mg/
lb
ai
handled).
According
to
the
study,
the
major
source
of
CCA
or
ACZA
for
worker
exposure
in
these
types
of
facilities
is
preservative
remaining
on
or
escaping
from
treated
wood
or
equipment
that
had
been
in
a
cylinder
during
treatment.
This
is
presumably
a
very
small
fraction
of
the
quantity
actually
applied
to
and
retained
by
the
charge.

The
components
of
CCA
or
ACZA
(
e.
g.,
arsenic,
chromium,
copper,
or
zinc)
for
each
WBD
segment
and
glove
pair
from
each
worker
was
corrected
based
on
the
mean
field
fortification
recovery
of
the
appropriate
analytical
standard(
s)
from
samples
fortified
in
the
field
at
that
test
site.
WBD
segments
were
also
adjusted
based
on
background.
The
analytical
method
was
subject
to
some
variability
at
levels
near
the
LOQ,
suggesting
that
recoveries
obtained
at
that
level
were
likely
to
be
less
reliable
than
those
at
the
higher
level.
The
registrant
did
not
make
any
corrections
to
the
raw
data
when
field
fortification
recoveries
were
>
100%.

Each
calculated
exposure
level
was
normalized
to
an
exposure
dose
expressed
in

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

Geometric
mean
dermal
exposures
across
all
job
functions
at
all
of
the
three
sites
ranged
from
2.91
to
98

g/
kg
bw/
day
and
from
1.49
to
4.74

g/
kg
bw/
day
for
arsenic
and
chromium
VI,
respectively.
Total
chromium,
copper,
and
zinc
levels
were
also
reported.
The
highest
individual
CCA/
ACZA
components
(
e.
g.,
arsenic,
chromium
total,
chromium
VI,
copper
and
zinc)
were
found
for
the
Tram
Setter.
Exposure
levels
for
the
Treatment
Operator
and
Loader
Operator
at
Site
B
(
which
used
the
smallest
amount
of
arsenic,
copper
and
chromium)
were
notably
higher
than
those
calculated
for
the
same
positions
at
the
other
two
sites.
Within
each
job
class
monitored,
and
over
all
classes
at
each
site,
those
individuals
whose
activities
involved
the
greatest
proximity
to
CCA/
ACZA
component
sources
were
exposed
to
the
highest
levels
of
CCA/
ACZA.

Calculated
inhalation
exposure
levels
were
normalized
by
scaling
up
the
pump
flow
rate
of
1
L/
min
to
the
U.
S.
EPA
recommended
minute
ventilation
rate
of
1100
L/
hr
(
approximately
18.34
3
L/
min)
for
"
light
activities",
and
then
adjusting
for
the
standard
EPA­
recommended
adult
weight
of
71.8
kg.
Geometric
mean
inhalation
exposures
across
all
of
the
job
functions
at
all
three
sites
ranged
from
0.044
to
0.256
(
As)

g/
kg
bw/
day
for
arsenic
and
0.033
to
0.042

g/
kg
VI
bw/
day
for
Chromium.
The
Tram
Setter
and
the
Supervisor
were
the
highest
exposed
individuals.
Within
each
job
class
monitored,
and
over
all
classes
at
each
site,
those
individuals
whose
activities
involved
the
greatest
proximity
to
CCA/
ACZA
component
sources
were
exposed
to
the
highest
levels
of
CCA/
ACZA.
According
to
the
Study
Report,
due
to
the
fact
that
none
of
the
workers
monitored
in
this
study
performed
continuous
light
activity,
the
use
of
the
recommended
ventilation
rate
probably
resulted
in
a
notable
over
estimation
of
inhalation
exposure.
The
fact
that
values
were
generated
even
for
those
compounds
that
were
never
detected
or
quantifiable
in
field
samples
contributes
to
the
over
estimation
of
inhalation
exposures
as
well.

The
assessment
for
this
study
focused
on
Series
875
compliance
and
issues
of
technical
merit.
Based
upon
the
review,
this
study
does
meet
most
of
the
Series
875
guideline
requirements
(
the
method
validation,
field
spikes,
and
QA/
QC
were
thoroughly
explained);
however,
some
minor
issues
are
as
follows:(
1)
data
were
not
reported
as
unit
exposures
(
e.
g.,
mg/
lb
ai)
therefore
differences
in
CCA/
ACZA
chemical
usage,
versus
exposure
between
facilities
were
not
examined
thoroughly;
(
2)
data
were
corrected
based
on
field
recovery;
however,
only
the
corrected
data
were
presented
in
the
study
and
the
corrections
calculations
were
not
expressed;
and
(
3)
separate
field
fortification
samples
were
not
collected
for
each
worker
job
function;
only
triplicate
field
fortification
samples
were
collected
at
each
site.

In
spite
of
these
deficiencies,
the
Agency
considers
these
data
as
acceptable
in
satisfying
the
application
exposure
data
guideline
requirements
under
Series
875
for
both
dermal
and
inhalation
exposure
monitoring
(
guidelines
875.1100/
875.1200
for
dermal
and
875.1300/
875.1400
for
inhalation)
and
recommends
use
of
these
data,
where
appropriate,
in
developing
the
occupational
exposure
estimates
for
certain
handler
scenarios
in
the
CCA
RED
human
exposure
chapter.
It
is
also
recommended
that
data
from
monitored
workers
involved
with
tasks
that
are
done
after
the
wood
has
been
pressure
treated
(
e.
g.,
data
for
Test
Borer
and
Stacker
Operator
functions)
be
used
in
estimating
certain
post­
application
exposure
doses.

STUDY
OVERVIEW:

Background
Three
commercial
facilities
in
the
U.
S.
and
Canada
were
used
in
this
study
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.
Two
of
the
facilities
(
referred
to
herein
as
Sites
A
and
B)
were
located
in
the
U.
S.
(
Orangeburg,
South
Carolina;
and
Eugene,
Oregon).
The
third
facility
(
referred
to
herein
as
Site
C)
was
located
in
Delson,
Quebec,
Canada.
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.

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
4
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
cooled
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.
Descriptions
of
the
tasks
monitored
are
bulleted
below
:
5
°
Treatment
Operators
(
TOs)
­
At
Sites
A,
B,
and
C,
the
TOs
operated
and
monitored
application
system
valves
and
controls;
they
sometimes
opened
and
closed
cylinder
doors,
and
they
supervised
the
insertion
and
removal
of
charges
(
loads
of
dried,
debarked
poles
or
untreated
ties)
of
poles
from
the
treatment
cylinders.

°
Treating
Assistant
(
TA)
­
At
Sites
A,
and
C,
the
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)
­
At
Sites
A,
B,
and
C,
the
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.
One
Site
B
Supervisor
(
S)
performed
mainly
LO
tasks.

°
Test
Borers
(
TBs)
­
At
Site
C
the
TBs
cut
cores
from
freshly
treated
poles
or
ties
for
testing
for
CCA
preservative
penetration/
retention.
At
the
other
sites
this
function
was
performed
by
TO/
TA/
LO
personnel.

°
Tram
Setter
(
TS)­
At
Site
A
the
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.

°
Stacker
Operator
(
SO)­
At
Site
A
the
SO
operated
a
lumber
stacking
device
which
arranged
treated
boards
in
stacks
for
banding
and
shipment.
Worker
manually
positioned
ends
of
boards
being
fed
into
device.

°
Tally
Man
(
TM)­
At
Site
C
the
TM
primarily
counted
and
inspected
incoming
and
outgoing
truckloads
of
wood
products
and
supervised
loading/
unloading
of
lumber
trucks
at
the
drip
pad
and
adjacent
locations.

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.

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.

STUDY
PROCEDURES:
6
Mixing/
Loading/
Application
Method
Pressure
treatment
operations
were
conducted
at
three
sites
(
Sites
A­
C).
At
Site
A,
pressure
treatment
operations
were
conducted
in
a
fully
enclosed
Treatment
Control
Room
(
TCR)
which
includes
a
computerized
system
(
built
and
provided
by
the
plant's
CCA
supplier)
for
operating
and
monitoring
all
aspects
of
pressure
treatment.
CCA
concentrate
was
delivered
to
the
plant
by
truck,
and
unloaded
(
by
the
truck
driver,
using
a
closed
transfer
system)
into
a
storage
tank
at
a
covered
tank
farm.
All
treating
system
control
valves
were
operated
automatically
from
a
workstation.

At
site
B,
CCA
concentrate
and
polyethylene
glycol
concentrate
(
PEG)
were
delivered
to
the
plant
by
truck.
Deliveries
were
handled
by
the
truck
drivers,
using
a
completely
closed
system,
and
did
not
involve
plant
personnel,
except
for
power
washing
drip
pads
before
the
truck
arrives.
The
treatment
control
room,
tank
farm,
and
portions
of
the
water
recovery
system
for
the
cylinders
were
located
in
the
cylinder
room.
Each
cylinder's
treatment
system
was
controlled
from
a
bank
of
switches
located
alongside
the
cylinder.
These
switches
were
operated
manuallythere
is
no
computer
control
of
the
treatment
system
or
transfer
deck.

At
Site
C,
ACZA
treatment
solution
was
used.
The
ACZA
mixing
area
was
directly
to
the
west
of
the
treatment
building.
It
includes
a
warehouse
for
storage
of
the
dry
ingredients
used
to
prepare
the
application
solution,
and
an
adjacent
tank
farm.
A
small
adjacent
area
was
used
to
store
drums
of
powdered
copper
oxide.
Separate
tanks
were
used
to:
(
1)
store
arsenic
acid
arsenic
acid
solution
(
delivered
by
tank
truck
and
transferred
using
a
closed
system),
(
2)
mix
the
ACZA
concentrate,
and
(
3)
store
the
mixed
concentrate.

In
lieu
of
applying
known
quantities
of
a
characterized
metal
oxide
formulation
to
each
charge
of
wood
products,
study
personnel
collected
data
generated
by
the
application
system
for
each
treatment
made
during
the
monitored
period
at
each
test
site.
These
commercial
records
were
not
made
for
each
cycle
during
the
monitored
period
at
each
test
site.
The
treatment
parameters
for
each
charge
inserted
or
removed
from
a
cylinder,
or
in
process
during
monitored
work
cycles
are
presented
in
Table
1.
A
detailed
description
of
the
type
of
wood
treated,
amount
of
oxides
in
solution,
and
duration
of
the
treatments
is
presented
in
pages
88­
90
of
the
Study
Report
(
MRID
No.
455021­
01).

Table
1.
Application
of
Test
Substances
Test
Site
Test
Days
No.
Charges
Monitored
Total
cu
ft
of
Wood
Treated
Total
lbs
Oxides
Used
As
Cu
Cr
Zn
Mean
Charge
Duration
A
5
34
39,702
13,426
5,008
2,667
6,993
­­­
01:
54
B
5
16
28,191
5,363
1,802
944
2,620
­­­
02:
51
C
5
7
7,948
2,928
772
1,433
­­­
723
23:
07
Exposure
Monitoring
7
Dermal
The
CCA
dermal
exposure
to
each
worker
was
determined
using
a
whole­
body
dosimeter
(
WBD),
consisting
of
a
100%
polyester
thermal
shirt
and
long
pants.
All
worker
at
Sites
A,
B,
and
C
wore
their
WBD
under
a
fresh
work
uniform
consisting
of
a
cotton
long­
sleeved
work
shirt
and
cotton
work
trousers
(
or
one­
piece
cotton
coverall)
provided
by
the
test
site.
The
workers
at
Site
B
wore
a
cotton
long­
sleeved
work
shirt
and
cotton
work
trousers
provided
by
the
test
site
Each
worker
at
all
four
sites
wore
a
lightweight
100%
cotton
glove
dosimeter
on
each
hand,
under
his
chemical­
resistant
or
work
gloves,
as
appropriate.

At
the
beginning
of
each
work
cycle
(
or
8
hour
shift),
the
workers
washed
their
hands
with
detergent
and
water,
put
on
the
WBD,
followed
by
a
fresh
uniform
and
other
work
clothes.
Once
the
worker
was
ready
to
start
the
work
cycle,
study
personnel
placed
the
glove
dosimeters
on
the
hands.
At
the
end
of
the
work
day,
study
personnel
removed
the
worker's
glove
dosimeters,
placed
the
pair
in
a
locking
polyethylene
storage
bag
and
froze
them
on
dry
ice.
When
the
break
ended,
the
worker
put
on
a
fresh
pair
of
glove
dosimeters.
At
the
end
of
the
work
day,
study
personnel
collected
the
worker's
glove
dosimeters
and
handled
them
as
noted
above.
The
study
personnel
helped
each
worker
remove
the
outer
work
clothes
and
then
cut
the
WBD
in
sections,
including
paired
arms,
remainder
of
shirt
("
torso
top"),
briefs
and
paired
legs.
Each
section
was
packaged
as
described
above,
labeled,
and
placed
on
dry
ice
for
shipment
to
Enviro­
Bio­
Tech,
Ltd.
(
EBT).

Inhalation
Inhalation
exposures
for
each
worker
was
estimated
by
active
dosimetry.
Each
worker
wore
a
sampling
train
consisting
of
a
37­
mm
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
orifice
was
oriented
downward,
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
an
NIST­
traceable­
calibrated
Sierra
®
Top­
Trak
 
mass
flow
meter.
The
pumps
were
turned
on
at
the
beginning
of
each
work
cycle
and
was
left
running
during
restroom,
coffee,
or
other
short
breaks.
They
were
turned
off
or
set
on
"
hold"
during
lunch
breaks.
The
pumps
and
samplers
were
removed
from
the
workers
during
the
lunch
break.
At
the
conclusion
of
the
lunch
break,
the
pump
and
sampling
train
were
reinstalled
and
the
pump
was
restarted.
All
start
and
stop
times
were
recorded.

Analytical
Methods
Dermal
Recovery
testing
of
residues
of
CCA
and
ACZA
components
in
dermal
exposure
monitoring
matrices
were
determined
using
Standard
Operating
Procedure
288.01
For
The
Determination
of
Copper,
Arsenic,
Chromium,
and
Zinc
in
PVC
filters,
Gloves,
and
Work
Clothes
By
Atomic
Absorption
Spectrophotometry,
Dated
12/
2/
99.
For
this
procedure,
a
dermal
sample
was
placed
into
glass
jar
(
size
of
jar
was
dependant
upon
the
size
of
the
sample).
For
each
WBD
section,
890
mL
of
0.05M
(
NH
4)
2
SO
4/
0.05M
NH
4
OH
extraction
solvent
was
8
added
to
the
sample
jar.
The
jar
was
then
sonicated
for
20
minutes
and
shaken
mechanically
for
60
minutes.
A
10­
mL
aliquot
of
the
extract
was
removed
for
determination
of
Cr+
6,
and
the
remaining
sample
was
acidified
by
addition
of
50
mL
of
concentrated
HNO
3
and
shaken
for
another
90
minutes.

For
each
pair
of
gloves,
190
mL
of
0.05M
(
NH
4)
2
SO
4/
0.05M
NH
4
OH
extraction
solvent
was
added
to
the
sample
jar.
The
jar
was
then
sonicated
for
15
minutes
and
shaken
mechanically
for
30
minutes.
A
10­
mL
aliquot
of
the
extract
was
removed
for
determination
of
Cr+
6,
and
the
remaining
sample
was
acidified
by
addition
of
15
mL
of
concentrated
HNO
3
and
shaken
for
another
90
minutes.

For
each
filter,
20
mL
of
0.05M
(
NH
4)
2
SO
4/
0.05M
NH
4
OH
extraction
solvent
was
added
to
the
sample
jar.
The
jar
was
then
sonicated
for
10
minutes
and
shaken
mechanically
for
30
minutes.
A
5­
mL
aliquot
of
the
extract
was
removed
for
determination
of
Cr+
6,
and
the
remaining
sample
was
acidified
by
addition
of
1
mL
of
70%
aqueous
HNO
3
and
shaken
for
another
30
minutes.

Cr+
6
was
determined
separately
from
other
compounds
using
different
methods.
Cr+
6
was
determined
colorimetrically
in
the
alkaline
extract
of
each
sample.
A
3­
mL
aliquot
was
passed
through
a
solid
phase
extraction
(
SPE)
cartridge
that
has
been
preconditioned
with
2
mL
of
methanol
followed
by
3
mL
of
de­
ionized
water.
The
flow
rate
was
2
mL/
minute
under
slight
vacuum.
The
cartridge
was
rinsed
with
3
mL
water
and
Cr+
6
was
eluted
with
9
mL
of
0.5M
(
NH
4)
2
SO
4/
0.1
M
NH
4
OH
buffer
in
three
3­
mL
aliquots.
The
eluate
was
acidified
with
100
µ
L
of
37%
aqueous
HCL.
Two
mL
of
a
solution
of
250
mg
of
1,5­
diphenylcarbazide
in
50
mL
acetone
was
added,
and
the
solution
was
mixed
and
allowed
to
stand
for
10
minutes
for
maximum
color
development.
An
aliquot
was
transferred
to
a
1­
cm
cell,
and
its
absorbance
was
determined
in
a
Milton
Roy
Spectronic
501
Spectrophotometer.

The
limit
of
quantitation
(
LOQ)
for
Cr+
6
for
each
monitoring
matrix
and
the
calculated
corresponding
limit
of
detection
(
LOD)
was
as
follows
in

g
of
analyte
per
sample:

LOD
LOQ
S
Gloves
10
30
S
Airfilter
0.5
1.5
S
WBD
Part
50
150
Determination
of
total
metals
(
total
arsenic,
copper,
chromium,
and
zinc)
in
the
acidified
extract
of
each
sample
was
performed
by
atomic
absorption
spectrophotometry
per
EBT
SOP
288.01.
A
small
aliquot
of
each
extract
was
transferred
to
a
glass
tube
and
inspected
visually.
If
any
suspended
material
was
visible,
the
sample
was
centrifuged
for
about
5
minutes
at
~
2,000
rpm.
An
aliquot
of
each
extract
was
transferred
to
a
2.5
mL
autosampler
vial
using
a
disposable
Pasteur
pipette,
along
with
an
appropriate
quantity
of
matrix
modifer:

°
For
Cr
analysis:
One
mL
of
a
solution
of
11.8
g.
Ca(
NO
3)
2
*
4H
2
O
diluted
to
100
mL
with
HPLC
grade
water
was
added
to
every
100
mL
of
sample
to
be
analyzed.

°
For
As
determination:
One
mL
of
a
solution
of
1%
nickel
nitrate
in
HPLC
grade
water
was
added
to
9
mL
of
sample
to
be
analyzed.
9
°
For
Cu
analysis:
no
matrix
modifier
was
required.

For
As,
Cr,
or
Cu
determination,
a
20­
µ
L
aliquot
of
the
mixture
was
analyzed
by
atomic
absorption
spectrophotometry,
using
a
Buck
Scientific
Model
210VGP
AA
Spectrophotometer
with
a
Buck
Model
220GF
Graphite
Furnace
and
a
Buck
Model
220AS
Autosampler.
The
following
monochromator
wavelengths
were
used:
193.7
nm
(
for
As),
357.9
nm
(
for
Cr),
324.7
nm
(
for
Cu),
and
213.9
nm
(
for
Zn).

For
Zn
determination,
a
20
µ
L
aliquot
of
the
extract
was
analyzed
by
direct
aspiration
AA
using
a
Buck
Scientific
Model
200­
A
Spectrophotometer,
with
the
monochromator
set
at
213.9
nm.
Sample
absorbance
was
recorded
while
the
sample
was
aspirated
into
the
flame.
Absorbance
data
for
initial
sample
sets
were
automatically
printed
out
by
the
equipment.

The
limits
of
quantitation
(
LOQ)
determined
for
each
target
analyte
in/
on
each
matrix
analyzed
by
this
method
(
and
the
limits
of
detection
calculated
for
each)
are
shown
below:

LOD
LOQ
Analyte
Matrix
(

g/
sample)
(

g/
sample)

As
Glove
pair
2.50
7.50
Filter
0.500
1.50
WBD
section
16.0
48.0
Cu
Glove
pair
2.50
7.50
Filter
0.500
1.50
WBD
section
16.0
48.0
Total
Glove
pair
2.00
6.00
Cr
Filter
0.250
0.750
WBD
section
5.00
15.0
Zn
Glove
pair
3.75
7.5
Filter
0.50
1.50
WBD
section
16.0
48.0
STUDY
RESULTS:

Method
Validation
Pre­
field
recovery
tests
were
performed
at
the
AASI
Field
Research
Facility
at
Lucama,
NC
in
order
to
determine
the
recovery
of
metals
applied
to
exposure­
monitoring
matrices.
Sets
of
triplicate
samples
of
WBD
sections,
paired
glove
dosimeters
and
single
PVC
air
filters
were
fortified
with
reference
standard
metal
ions
or
reference
standard
hexavalent
chromium,
at
LOQ,
10
x
LOQ,
100
x
LOQ,
and
at
the
control.
Samples
were
set
on
tables
and
exposed
to
ambient
conditions
for
8
hours,
to
simulate
field
sampling
conditions.
Air
sampling
trains
were
run
during
the
exposure
period
at
a
flow
rate
of
2
L/
min.
At
the
end
of
the
exposure
period,
each
WBD
and
filter
cassette
sample
was
placed
in
a
labeled
locking
polyethylene
storage
bag,
and
placed
on
dry
ice
for
shipment
to
EBT.
Glove
bottles
were
capped,
labeled,
sealed,
and
placed
on
dry
ice.
The
method
validation
results
are
summarized
below
in
Table
2.
10
Table
2.
Method
Validation
Results
for
CCA
in
WBD
Sections,
Glove
Pairs,
and
Filters
Analyte
Matrix
Spike
Level
(

g)
%
Recovery
Mean
S.
D.
%
cv
Cr+
6
WBD
150­
15,000
92.8
(
n=
7)
4.91
5.29
Gloves
30­
3,000
97.2
(
n=
7)
1.89
1.94
Filters
1.5­
150
96.8
(
n=
7)
3.31
3.42
Total
Cr
WBD
15­
1,500
94.9
(
n=
7)
11.9
12.5
Gloves
6­
600
89.6
(
n=
7)
6.66
7.44
Filters
0.75­
75
107
(
n=
7)
6.57
6.14
Total
Cu
WBD
48­
4,800
96.8
(
n=
7)
7.70
7.95
Gloves
7.5­
750
87.5
(
n=
7)
12.4
14.1
Filters
1.5­
150
103
(
n=
7)
8.57
8.36
Total
As
WBD
48­
4800
101
(
n=
7)
9.38
9.26
Gloves
7.5­
750
100
(
n=
7)
9.00
8.99
Filters
1.5­
150
103
(
n=
7)
6.48
6.30
Total
Zn
WBD
48­
4800
106
(
n=
7)
7.61
7.19
Gloves
7.5­
750
106
(
n=
7)
9.14
8.62
Filters
1.5­
150
95.4
(
n=
7)
14.5
15.2
Breakthrough/
Retention
Testing
Breakthrough/
retention
testing
was
performed
in
order
to
insure
that
CCA
components
would
not
migrate
from
one
to
the
other
cassette.
Mean
percent
recovery
of
metals
from
the
front
filters
were
as
follows:
113%
­
total
Cr;
94%
­
Cr+
6;
103%
­
Cu;
114%
­
As;
and
94%
­
Zn.
All
control
recoveries
for
all
analytes
from
the
rear
filters
were
below
the
LOQ
for
this
test.
The
results
demonstrate
that
all
analytes
were
retained
in
the
fortified
filters
and
breakthrough
did
not
occur.

Pre­
field
Recovery
of
CCA
in
Whole
Body
Dosimeters,
Gloves
and
Filters
A
pre­
field
recovery
study
of
CCA
in
whole
body
dosimeters
(
WBD),
gloves
and
filters
was
performed
in
order
to
determine
that
CCA
applied
to
these
matrices
would
be
retained
during
field
sampling
and
transport.
The
mean
percent
recoveries
showed
some
loss
of
Cr+
6
on
WBD
(
73.1%)
and
gloves
(
66.2%)
and
loss
of
total
Cr
to
gloves
(
78%)
during
exposure
to
ambient
conditions.
For
the
other
samples
(
including
total
Cr,
Cu,
As,
and
Zn)
the
recovery
ranged
from
88
Percent
to
112
Percent.

Laboratory
Spikes
Laboratory
fortified
samples
of
each
matrix
used
in
the
study
were
analyzed
concurrently
with
11
field
samples
to
monitor
procedural
recoveries.
The
mean
recovery
of
total
arsenic,
chromium,
chromium
VI,
copper,
and
zinc
from
laboratory
fortified
glove
and
WBD
samples
is
summarized
in
Table
3.
The
mean
recoveries
laboratory
spike
recoveries
were
well
within
the
acceptable
range.

Field
Spikes
Samples
of
exposure­
monitoring
matrices
were
shipped
on
dry
ice,
as
soon
as
possible
after
collection,
by
overnight
courier
to
EBT's
facility
in
Bernville,
PA.
Samples
were
stored
at
room
temperature
prior
to
analysis.
Control
samples
included
all
sampling
media,
i.
e.,
gloves
in
pairs,
single
air
filters,
and
representative
WBD
sections
(
single
torso
top
fronts
or
backs,
single
bottoms,
single
arms
or
legs).
Field
Fortification
recoveries
are
shown
in
Table
4.

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

Dermal
Field
Fortification
Samples
On
at
least
one
day
of
monitoring,
two
sets
of
12
samples
of
each
matrix
was
randomly
selected
from
those
being
used
for
worker
monitoring.
In
each
set,
three
of
each
matrix
were
blank
controls,
and
three
were
fortified
("
spiked")
with
a
solution
of
standard
As,
Cu,
Zn,
Cr,
or
Cr+
6
at
each
of
two
levels,
LOQ,
and
100xLOQ.

Inhalation
Field
Fortification
Samples
On
each
day
of
fortification,
two
sets
of
twelve
samples
of
each
matrix
were
randomly
selected
from
those
being
used
for
worker
monitoring.
In
each
set,
three
of
each
matrix
were
blank
controls,
and
three
were
fortified
with
a
solution
of
standard
As,
Cu,
Zn
and
total
Cr
or
Cr6+
at
each
of
two
levels
LOQ
and
100x
LOQ.
A
fresh
spike
solution
were
used
for
each
spike
day.
The
air
samplers
will
be
attached
to
calibrated
air
pumps
running
at
the
rate
established
for
field
sampling.
12
Table
3.
Recovery
of
Total
CCA/
ACZA
from
Laboratory
Fortified
WBD
Sections,
Glove
Pairs,
and
Filters
Analyte
Test
Site
Matrix
Spike
Level
(

g)
%
Recovery
Mean
S.
D.
%
cv
Cr+
6
A
WBD
240­
4800
90.8(
n=
26)
4.55
5
B
WBD
48­
4800
90.4
(
n=
19)
5.39
6
A
Gloves
7.5­
750
87.3
(
n=
10)
6.45
7.4
B
Gloves
7.5­
6000
89.7
(
n=
17)
6.71
7.5
A
Filters
1.5­
150
93.7
(
n=
5)
3.41
3.6
B
Filters
1.5­
150
91.2
(
n=
8)
4.99
5.5
Total
Cr
A
WBD
150­
15000
92.4
(
n=
26)
11.1
12
B
WBD
165­
16500
100
(
n=
19)
5.93
5.9
A
Gloves
30­
3000
92.6
(
n=
10)
11.1
12
B
Gloves
36­
3600
101
(
n=
17)
15.4
15.2
A
Filters
1.5­
150
93.9
(
n=
5)
7.68
8.2
B
Filters
2.3­
225
104
(
n=
8)
7.16
6.9
Total
Cu
A
WBD
48­
4800
86
(
n=
26)
11.79
13.7
B
WBD
48­
4800
94.5
(
n=
19)
11.2
11.9
C
WBD
48­
4800
93.9
(
n=
26)
6.61
7.0
A
Gloves
7.5­
750
98.3
(
n=
10)
10.8
11
B
Gloves
7.5­
753
97.3
(
n=
17)
11.4
11.7
C
Gloves
7.5­
750
95.3
(
n=
16)
11.0
11.5
A
Filters
1.5­
150
103
(
n=
5)
9.38
9.1
B
Filters
1.5­
150
106
(
n=
8)
12.3
11.6
C
Filters
1.5­
150
92.2
(
n=
9)
6.13
6.6
Total
As
A
WBD
48­
4800
86
(
n=
26)
9.38
10.9
B
WBD
48­
4800
94.5
(
n=
19)
11.2
11.9
C
WBD
48­
4800
103
(
n=
26)
6.24
6.1
A
Gloves
7.5­
750
102
(
n=
10)
8.88
8.7
B
Gloves
7.5­
750
97.3
(
n=
17)
13.27
13.6
C
Gloves
7.5­
750
95.3
(
n=
16)
6.61
6.9
A
Filters
1.5­
150
100
(
n=
5)
15.3
15.3
B
Filters
1.5­
150
95.7
(
n=
8)
6.62
6.9
C
Filters
1.5­
150
102
(
n=
9)
8.88
8.7
Total
Zn
C
WBD
48­
4800
98
(
n=
9)
12.8
13
C
Gloves
7.5­
750
103
(
n=
16)
4.78
4.6
C
Filters
1.5­
150
104
(
n=
26)
8.95
8.6
13
Table
4.
Recovery
of
Total
CCA/
ACZA
from
Field
Fortified
WBD
Sections,
Glove
Pairs
and
Filters
Analyte
Test
Site
Matrix
Spike
Level
(

g)
%
Recovery
Mean
S.
D.
%
cv
Cr+
6
A
WBD
750­
15000
88.8(
n=
18)
4.3
4.8
B
WBD
750­
15000
91.6(
n=
30)
3.0
3.3
A
Gloves
150­
3000
76.7
(
n=
18)
5.9
7.7
B
Gloves
150­
3000
89.2
(
n=
30)
5.4
6.1
A
Filters
7.5­
150
91.4
(
n=
18)
3.5
3.8
B
Filters
7.5­
150
90.9
(
n=
30)
3.9
4.3
Total
Cr
A
WBD
750­
15000
93.0
(
n=
18)
10
10.8
B
WBD
825­
16500
95.7
(
n=
30)
6.4
6.7
A
Gloves
150­
3000
100
(
n=
17)
13.1
13.1
B
Gloves
180­
3598
95.9
(
n=
30)
11.9
12.4
A
Filters
7.5­
150
106.5
(
n=
18)
13.4
12.6
B
Filters
11.3­
225
113.3
(
n=
30)
6.6
5.8
Total
Cu
A
WBD
240­
4800
95.5
(
n=
12)
16.8
17.6
B
WBD
240­
4800
89
(
n=
30)
10.3
11.6
C
WBD
240­
4800
92.4
(
n=
30)
8.4
9.1
A
Gloves
37.5­
750
98.0
(
n=
17)
15.5
15.8
B
Gloves
37.5­
750
104
(
n=
30)
11.7
11.3
C
Gloves
37.5­
750
97.4
(
n=
24)
7.8
8
A
Filters
7.5­
150
95.8
(
n=
18)
19.7
20.6
B
Filters
7.5­
150
106.4
(
n=
30)
15.3
14.4
C
Filters
7.5­
150
92.4
8.4
9.1
Total
As
A
WBD
240­
4800
95.5
16.8
17.6
B
WBD
240­
4800
100.9
18.9
18.7
C
WBD
240­
4800
103.3
6.5
6.3
A
Gloves
37.5­
750
101.7
(
n=
17)
17
16.7
B
Gloves
37.5­
6000
98.8
(
n=
30)
10.8
10.9
C
Gloves
37.5­
5250
92.9
(
n=
24)
12.6
13.6
A
Filters
7.5­
150
109
(
n=
18)
12.7
11.7
B
Filters
7.5­
150
103(
n=
30)
7.2
7.0
C
Filters
7.5­
150
107.9
(
n=
30)
7.7
7.1
Total
Zn
C
WBD
240­
4800
98.4
(
n=
30)
4.6
4.6
C
Gloves
37.5­
750
100.4
(
n=
24)
5.7
5.7
C
Filters
7.5­
150
95.4
(
n=
24)
5.4
5.7
14
Formulation
Testing
The
field
phase
of
this
study
was
performed
using
lots
of
CCA
or
ACZA
that
were
already
onsite
at
the
time
the
field
study
phase
was
conducted.
Analysis
and
expiration
dates
were
not
provided
for
those
commercial
lots.
Tank
mixes
were
analyzed
by
on­
site
QC
personnel:
copies
of
relevant
analysis
results
are
archived
with
the
raw
data
from
each
test
site.
Study
personnel
collected
at
least
one
sample
of
each
separate
batch
of
CCA
or
ACZA
used
to
treat
lumber
products
during
monitoring
at
each
site.
Each
sample
was
placed
in
a
polyethylene
or
glass
container
and
stored
on
dry
ice
and
shipped
to
EBT
for
archival
storage.
At
least
one
sample
was
analyzed
per
test
site.

Storage
Stability
The
stability
of
arsenic,
chromium,
chromium
(
VI),
copper,
and
zinc
was
determined
in
WBD
sections,
glove
pairs,
and
air
filters
and
stored
frozen
(<­
15

V)
by
EBT
at
several
different
fortification
levels
(
1x
or
10
x
LOQ)
for
up
to
20,
60,
or
90
days
prior
to
extraction.
The
results
are
summarized
in
Table
5.
Residue
levels
declined
by
less
than
5%
for
all
media
demonstrating
that
these
materials
were
stable.
It
should
be
noted
that
target
metal
levels
in
field
samples
were
adjusted
for
recoveries
from
field­
fortified
controls
that
were
collected,
shipped,
stored,
extracted,
and
analyzed
concurrently
with
those
field
samples,
and
thus
incorporated
any
necessary
adjustment
for
storage
effects.

Table
5.
Storage
Stability
Results
Analyte
Matrix
Spike
Level
(

g)
%
Recovery
0
days
30
days
60
days
90
days
Cr+
6
WBD
480­
4800
100
99.4
99.3
NA
Gloves
30­
3,000
96.8
100
100
NA
Filters
1.5­
150
100
99.4
99.3
NA
Total
Cr
WBD
15­
1500
101
99.3
113
96.3%

Gloves
7.5­
750
101
106
108
NA
Filters
0.75­
75
102
97.2
107
NA
Total
Cu
WBD
48­
4800
97.9
108
102
111%

Gloves
7.5­
777.25
103
116
100
NA
Filters
1.5­
150
99.8
92.2
101
NA
Total
As
WBD
48­
4800
98
100
102
94.9%

Gloves
7.5­
750
105
100
99.1
NA
Filters
1.5­
150
98.2
97.6
98.2
NA
Total
Zn
WBD
48­
4800
102
102
104
102%

Gloves
7.5­
750
99.4
102
98.6
NA
Filters
1.5­
150
100
100
98.5
NA
15
Exposures
In
lieu
of
applying
known
quantities
of
a
characterized
metal
oxide
formulation
to
each
charge
of
wood
products,
study
personnel
collected
data
generated
by
the
application
system
for
each
treatment
made
during
the
monitored
period
at
each
test
site.
These
commercial
records
were
not
made
during
the
monitored
period
at
each
test
site.
The
treatment
parameters
for
each
charge
inserted
or
removed
from
a
cylinder,
or
in
process
during
monitored
work
cycles
were
already
presented
in
Table
1.

Dermal
Results
Dermal
worker
exposure
were
measured
for
each
worker
task
identified
in
Section
3.1.
It
appears
that
workers
placed
in
the
closest
proximity
of
exposure
(
e.
g.,
TS,
TM,
TO,
LO)
were
exposed
to
the
highest
quantities
of
target
analytes.
During
each
replicate
of
monitoring,
dermal
exposure
of
the
subject's
body
to
ACZA/
CCA
components
was
determined
by
collection
of
material
in/
on
the
cotton
WBD.
Exposure
of
the
hands
was
determined
from
material
collected
in/
on
the
cotton
glove
dosimeters
(
worn
under
chemical­
resistant
gloves,
as
appropriate).

Exposure
levels
for
the
TO
and
LO
at
site
B
which
used
the
smallest
amount
of
arsenic,
copper
and
chromium
were
notably
higher
than
those
calculated
for
the
same
positions
at
the
other
two
sites
(
see
page
66
in
the
Study
Report).
The
differences
may
have
been
due
to
the
following
reasons:
1)
an
increased
potential
for
exposure
of
each
worker
resulting
from
having
fewer
workers
performing
all
treatment­
related
tasks
at
this
site,
2)
the
dispersal
of
target
metals
from
the
surfaces
of
treated
wood
into
the
drip
pad
area
resulting
from
application
of
jets
of
pressurized
water
directed
from
the
ring
washer
onto
charges
emerging
from
cylinders,
3)
differences
in
treatment
processing
at
this
site,
4)
the
enclosed
drip
pad
and
the
cylinder
area
are
likely
to
retain
some
of
these
dispersed
materials,
increasing
their
availability
for
worker
contact,
and
5)
the
presence
of
open
channels
in
the
floor
of
the
cylinder
room
and
drip
pad
room
for
returning
used
treating
solution
and
contaminated
wash
water
to
work
tanks
for
reuse.

Overall
exposures
for
the
Site
A
TO
were
higher
than
those
of
the
Site
C
TO.
Copper
exposures
for
the
TA
and
LO
at
Site
C
were
higher
than
those
of
their
counterparts
at
Site
A,
as
would
be
expected
based
on
usage,
roughly
reflecting
the
relative
level
of
use
of
the
two
metals
at
those
facilities.
However,
arsenic
exposures
for
those
positions
were
similar
in
magnitude
at
both
sites.
Calculated
levels
of
exposure
to
Cr6+
were
far
smaller
than
those
calculated
for
Crtotal
for
all
positions
at
Site
A
(
where
calculated
Cr6+
was
3.8­
16.2%
of
Crtotal
levels)
and
site
B
(
where
calculated
Cr6+
was
3.5­
6.3%
of
Crtotal
levels).
These
results
demonstrate
that
much
of
the
Cr6+
is
reduced
to
Cr3+.
Also
it
should
bet
noted
that
the
calculated
levels
of
Cr6+
are
overestimates
of
actual
levels,
resulting
from
the
effect
of
assigning
values
to
nondetectable
and
nonquantifiable
levels
in
samples.

Corrections
to
each
WBD
segment
and
glove
pair
were
made
for
the
mean
recovery
of
the
appropriate
analytical
standard
from
samples
of
the
appropriate
matrix
fortified
in
the
field
on
the
same
day
or
the
spike
day
at
the
site
with
ambient
conditions
most
similar
to
the
monitoring
day.
Adjustments
were
made
even
when
recoveries
from
field
control
samples
were
>
100%.
The
generally
used
convention
for
samples
containing
very
low
levels
of
analyte
was
applied:
for
any
sample
in
which
the
level
of
any
analyte
was
below
its
LOQ
but
above
the
LOD,
½
of
the
LOQ
was
used
as
an
upper­
bound
estimate
of
the
residue
in
the
sample
for
calculation
of
exposure
to
that
analyte.
In
addition,
for
any
sample
where
the
level
of
any
analyte
was
below
the
LOD,
½
of
the
LOD
was
used
as
the
upper­
bound
estimate
for
calculation
of
exposure
to
that
analyte.
16
Exposure
levels
were
also
adjusted
based
on
background
levels.
The
background
levels
were
identified
based
on
pre­
test
WBDs.
Background
testing
was
performed
by
wearing
a
fresh
WBD
at
home
under
normal
clothing,
for
approximately
8
hours
during
one
non­
work
day
prior
to
participation
in
the
study.
Appendix
D
in
the
Study
Report
(
MRID
No.
455021­
01)
presents
WBD
data
that
was
corrected
by
subtracting
raw
data
minus
background
data.
Background
data
were
obtained
by
measuring
the
residue
on
WBDs
when
a
worker
was
at
home.
In
some
cases
the
background
data
was
actually
higher
than
the
raw
data
therefore
concentrations
were
listed
as
negative
number
(
e.
g.,
Site
A
Job
Class
TA,
Rep
1,
Body
Part
Arms
­
1.82
µ
g
per
8­
hour
day).
The
negative
number
was
added
into
the
total
residue.
Series
875
does
not
give
guidance
to
handle
background
data
and
does
not
specify
if
it
is
appropriate
to
correct
WBD
residues
based
on
background
data.

Each
calculated
exposure
level
was
normalized
to

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

The
levels
of
residue
found
in
worker
gloves
and
WBDs
(
combined)
are
shown
in
Tables
XIV,
XV,
and
XVI
(
pages
155
through
186)
in
the
Study
Report
(
MRID
No.
455021­
01).
The
registrant
indicated
the
data
were
lognormal
and
calculated
geometric
mean
daily
dermal
exposure
levels
of
monitored
workers
at
all
sites.
The
exposure
data
for
all
sites
are
summarized
in
Tables
6
­
10.

Table
6.
Geometric
Mean
Daily
Dermal
Exposure
Levels
of
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.
17
Table
7.
Geometric
Mean
Daily
Dermal
Exposure
Levels
of
Monitored
Workers
at
all
Sites
for
Copper
Parameter
Dermal
Exposure
(

g/
kg
bw/
day)
to
Copper
a
TO
TA
TB
TS
TM
LO
S
SO
No.
Replicates
15
10
5
5
5
15
5
4
Minimum
12.3
4.46
6.45
24.0
52.6
7.53
24.5
7.63
Maximum
356
67
14.0
49.9
242
110
59
24
Mean
100
28.5
10.8
37.4
98.1
43.5
40.7
17.8
S.
D.
111
19.4
3.25
9.36
81.0
31.5
17.1
7.19
G.
M.
56.2
22.0
10.4
36.4
80.7
32.3
37.8
16.4
Median
44.0
27.8
11.0
39.0
58.9
38.0
37.4
20.0
aAbbreviations:
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
Dermal
Exposure
Levels
of
Monitored
Workers
at
all
Sites
for
Total
Chromium
Parameter
Dermal
Exposure
(

g/
kg
bw/
day)
to
Total
Chromium
a
TO
TA
TS
LO
S
SO
No.
Replicates
15
10
5
15
5
4
Minimum
14.5
6.18
73.8
10.0
11.9
27.0
Maximum
233
34.7
103
109
63.2
52.8
Mean
110
19.9
87.8
46.2
46.0
40.1
S.
D.
91.8
13.3
12.9
30.7
21.1
11.3
G.
M.
68.5
16.1
87.0
37.1
39.7
38.9
Median
92.5
15.6
93.3
45.3
53.6
40.4
a
Abbreviations:
LO
=
Loader
operator;
S=
supervisor,
SO=
stacker
operator,
TA
=
treating
assistant,
TO=
treating
operator,
and
TS=
tram
setter.
18
Table
9.
Geometric
Mean
Daily
Dermal
Exposure
Levels
of
Monitored
Workers
at
all
Sites
for
hex.
Chromium
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.

Table
10.
Geometric
Mean
Daily
Dermal
Exposure
Levels
of
Monitored
Workers
at
all
Sites
for
Zinc
Parameter
Dermal
Exposure
(

g/
kg
bw/
day)
to
Zinc
a
TO
TA
TB
TM
LO
No.
Replicates
5
10
5
5
5
Minimum
77.4
83.0
83.6
91.5
68.4
Maximum
118
156
137
147
121
Mean
95.3
113
11
114
92.6
S.
D.
14.5
32.3
19.4
20.3
22.2
G.
M.
94.4
110
109
113
90.5
Median
93.8
96.2
108
109
82.7
a
Abbreviations:
LO
=
Loader
operator,
TA
=
treating
assistant,
TB=
test
borer,
TM=
tally
man,
and
TO=
treating
operator.

Inhalation
Results
Inhalation
results
were
measured
for
each
task
identified
in
Section
3.1
for
Sites
A,
B,
and
C.
As
noted
for
dermal
exposure,
the
TS
had
the
highest
level
of
inhalation
exposure,
and
had
the
most
contact
with
the
test
materials.
It
appears
that
workers
placed
in
the
closest
proximity
of
exposure
(
e.
g.,
TS,
TM,
TO,
LO)
were
exposed
to
the
highest
quantities
of
target
analytes.
Air
sampling
parameters
for
all
monitoring
periods
at
Sites
A,
B,
and
C
are
shown
in
Tables
XVIIXIX
the
Study
Report
(
MRID
No.
455021­
01).

The
unadjusted
residue
level
for
each
air
sampler
from
each
worker
was
corrected
for
the
field
control
recovery
efficiency,
or
for
LOD/
LOQ
adjustment
(
if
<
LOQ).
Inhalation
exposure
for
each
target
compound
was
calculated
from
material
found
in
the
entire
sampling
train
(
filter
+
front
tube
+
rear
tube).
Calculated
inhalation
exposure
levels
were
normalized
by
scaling
up
the
pump
flow
rate
which
was
approximately
2
L/
minute
(
see
Table
XVII
of
the
Study
Report
for
19
Inhalation
Exposure
(
µ
g/
kg/
day)

Residue
(
µ
g/
day)
x
BR
(
L/
hr)
60
min/
hr
x
WD
x
FR
(
L/
min)
x
BW
(
kg)

Inhalation
Concentration
(
µ
g/
m)
3

Residue
(
µ
g/
day)
FR
(
L/
min)
x
Exposure
(
min/
day)
x
WD
x
1000
L/
m3
actual
pump
flows)
to
the
EPA
recommended
minute
ventilation
rate
of
approximately
1100
L/
hour
for
"
light
activities".
Then
an
adjustment
was
made
for
the
standard
EPA
recommended
adult
weight
of
71.8
kg.
According
to
the
Study
Report
(
MRID
No.
455021­
01),
due
to
the
fact
that
none
of
the
workers
monitored
in
this
study
performed
continuous
light
activity,
the
use
of
the
recommended
ventilation
rate
probably
resulted
in
a
notable
over
estimation
of
exposure.
The
fact
that
values
were
generated
even
for
those
compounds
that
were
never
detected
or
quantifiable
in
field
samples
contributes
to
the
over
estimation
of
inhalation
exposures
as
well.
The
equation
for
determining
inhalation
exposure
is
depicted
Equation
1
below.
The
equation
for
determining
inhalation
concentrations
are
presented
in
Equation
2.

Equation
1:

Where:

Residue
=
Residue
found
on
sampling
filter
(
µ
g/
day);
BR=
Breathing
rate
of
individual
(
1100
liters/
hour
for
light
activities);
WD=
fraction
of
standard
8­
hr
day
monitored;
FR=
Flow
rate
of
calibrated
pump
(
L/
min);
and
BW=
Body
weight
of
individual
(
71.8
kg).

Equation
2:

Where:

Residue
=
Residue
found
on
sampling
filter
(
µ
g/
day);
Exposure=
Minutes
worker
is
exposed
per
day
(
min/
day);
WD=
fraction
of
standard
8­
hr
day
monitored;
and,
FR=
Flow
rate
of
calibrated
pump
(
L/
min).

The
calculated
levels
of
inhalation
exposures
are
summarized
in
Tables
11­
15.
The
8­
hour
inhalation
concentrations
are
presented
in
Table
16.
The
inhalation
exposures
for
each
replicate
at
each
site
are
presented
in
Table
XX­
XXII
(
see
pages
189­
191
of
the
MRID
No.
455021­
01
Study
Report).
The
levels
of
each
analyte
in
the
air
sampled
during
each
monitored
work
cycle,
expressed
as

g/
m3
of
air,
are
presented
in
Table
XXIII
(
pages
192
to
194)
in
the
Study
Report
(
MRID
No.
455021­
01).
20
Table
11.
Geometric
Mean
Daily
Inhalation
Exposure
Levels
of
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
12.
Geometric
Mean
Daily
Inhalation
Exposure
Levels
of
Monitored
Workers
at
all
Sites
for
Copper
Parameter
Inhalation
Exposure
(

g/
kg
bw/
day)
to
Copper
a
TO
TA
TB
TS
TM
LO
S
SO
No.
Replicates
15
10
5
5
5
15
5
4
Minimum
0.094
0.095
0.033
0.097
0.033
0.092
0.119
0.033
Maximum
0.778
0.297
0.101
0.971
0.113
0.656
0.595
0.967
Mean
0.293
0.12
0.048
0.455
0.078
0.27
0.397
0.299
S.
D.
0.268
0.062
0.030
0.423
0.039
0.227
0.198
0.447
G.
M.
0.197
0.112
0.043
0.291
0.069
0.194
0.345
0.132
Median
0.101
0.099
0.035
0.258
0.103
0.117
0.378
0.097
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.
21
Table
13.
Geometric
Mean
Daily
Inhalation
Exposure
Levels
of
Monitored
Workers
at
all
Sites
for
Total
Chromium
Parameter
Inhalation
Exposure
(

g/
kg
bw/
day)
to
Total
Chromium
a
TO
TA
TS
LO
S
SO
No.
Replicates
10
5
5
15
5
4
Minimum
0.125
0.142
0.223
0.142
0.222
0.049
Maximum
0.611
0.251
0.510
0.644
0.491
0.128
Mean
0.332
0.177
0.367
0.306
0.361
0.069
S.
D.
0.171
0.045
0.117
0.194
0.108
0.039
G.
M.
0.291
0.173
0.352
0.260
0.348
0.062
Median
0.307
0.168
0.322
0.259
0.404
0.049
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
14.
Geometric
Mean
Daily
Inhalation
Exposure
Levels
of
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
0.035
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.
22
Table
15.
Geometric
Mean
Daily
Inhalation
Exposure
Levels
of
Monitored
Workers
at
all
Sites
for
Zinc
Parameter
Inhalation
Exposure
(

g/
kg
bw/
day)
to
Zinc
a
TO
TA
TB
TM
LO
No.
Replicates
5
5
5
5
5
Minimum
0.031
0.032
0.033
0.033
0.034
Maximum
0.113
0.114
0.035
0.104
0.101
Mean
0.061
0.077
0.034
0.049
0.049
S.
D.
0.040
0.042
0.001
0.031
0.029
G.
M.
0.051
0.066
0.034
0.044
0.044
Median
0.034
0.098
0.034
0.038
0.035
a
Abbreviations:
TO=
treating
operator,
TA
=
treating
assistant,
TB=
test
borer,
TM=
tallyman,
and
LO=
loader
operator.

 
Table
16.
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
TA
0.347
0.835
­­­
­­­
0.538
23
STUDY
DATA
REVIEW
FOR
COMPLIANCE
WITH
SERIES
875
GUIDELINES:

Compliance
with
Series
875­
Occupational
and
Residential
Exposure
Test
Guidelines
of
the
Pesticide
Assessment
Guidelines
(
U.
S.
EPA,
1998)
is
critical
if
a
study
is
to
be
considered
acceptable
to
the
Agency.
Table
17
presents
a
"
Checklist
for
Applicator
Monitoring
Data"
used
in
reviewing
studies
based
on
Series
875
guidelines.
This
table
is
designed
to
summarize
important
factors
of
Series
875
guidelines,
identify
whether
the
study
addresses
these
issues,
is
compliant
with
the
guidelines,
and
where
applicable,
presents
comments
on
how
the
study
was
not
in
compliance.
24
Table
17.
Compliance
with
Series
875
Guidelines
FIFRA
Compliance
Checklist
Does
the
Study
Address
This
Compliance
Issue?
Does
the
Study
Comply
With
This
Part
of
Series
875?
Comments
Prior
"
informed
consent"
must
be
obtained
in
writing
from
all
subjects
who
will
be
exposed
in
the
study.
yes
yes
Informed
consent
was
presented
in
Appendix
2
of
this
report.

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

Respirators
were
not
required
however
because
inorganic
arsenic
levels
in
the
plant
were
less
than
10
µ
g/
m3.

Studies
must
be
designed
so
that
an
exposure
is
measured
separately
for
each
activity
associated
with
an
application.
yes
yes
7
job
categories
were
monitored.

Data
collection
in
accordance
with
40
CFR
160,
Good
Laboratory
Practice
Standards.
yes
mostly
Page
3
in
the
study
report
indicates
where
GLPs
could
not
be
followed.

Typical
end
use
product
of
the
active
ingredient
used.
yes
yes
The
study
identifies
3
end
use
products
used
in
this
study.
They
are
Wolmanac
®
Concentrate,

Timber
Specialties
K­
33
 
,
Chemolite
Part
A
and
Part
B
Solution.
Labels
for
all
four
end
use
products
were
provided.

End
use
product
handled
and
applied
using
recommend
equipment,
application
rates,

and
typical
work
practices.
yes
yes
Typical
wood
treatment
process
assessed.
Table
17:
Compliance
with
Series
875
Guidelines
FIFRA
Compliance
Checklist
Does
the
Study
Address
This
Compliance
Issue?
Does
the
Study
Comply
With
This
Part
of
Series
875?
Comments
25
For
exposure
monitoring
at
least
five
replicates
(
e.
g,
individuals)
at
each
of
at
least
three
sites
for
each
job
function
should
be
monitored.
yes
mostly
There
were
25
workers
total
(
for
all
four
sites)

monitored
for
up
to
3
consecutive
work
days.

There
were
7
job
categories
monitored.
For
each
job
category
there
were
4
to
15
replicates
per
site.

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

Dermal
and/
or
inhalation
exposure
must
be
monitored
by
validated
methodologies.

Biological
monitoring
is
consistent
with
and
supported
by
pharmacokinetic
data
accepted
by
the
Agency.
yes
yes
Dermal
and
inhalation
methods
used
were
identified
in
Series
875
regulations.

Quantity
of
active
ingredient
handled
and
duration
of
monitoring
period
reported
for
each
replication
yes
partly
Quantity
of
active
ingredient
handled
was
described.
Duration
of
exposure
was
identified
for
both
dermal
and
inhalation
exposures.
The
test
substances
used
at
the
facilities
was
used
in
a
continuous
system.
However,
exposure
was
not
related
in
unit
exposures
like
mg/
lb
ai.

Quantitation
level
of
detection
is
at
least
1
µ
g/
cm2
not
applicable
not
applicable
This
LOQ
is
used
only
for
dermal
patch
studies.

Clothing
worn
by
each
study
participant
and
location
of
dosimeters
reported.
yes
yes
Study
used
whole
body
dosimeters
(
cotton
thermal
shirts,
pants,
and
gloves).
Sections
(
gloves,
arms,
bottoms)
were
measured
appropriately.
Table
17:
Compliance
with
Series
875
Guidelines
FIFRA
Compliance
Checklist
Does
the
Study
Address
This
Compliance
Issue?
Does
the
Study
Comply
With
This
Part
of
Series
875?
Comments
26
Storage
of
samples
consistent
with
storage
stability
data.
yes
yes
Storage
of
samples
and
storage
stability
are
addressed
in
the
study.
Correction
based
on
storage
stability
results
was
not
necessary.

Efficiency
of
extraction
in
laboratory
provided
as
mean
plus
or
minus
one
standard
deviation.
Lower
95
percent
confidence
limit
is
not
less
than
70
percent
based
on
a
minimum
of
seven
replications
per
fortification
level
or
prior
Agency
approval
of
extraction
methodology
provided.
yes
yes
Method
validation
testing
appeared
to
be
in
the
acceptable
range.

At
least
one
field
fortification
sample
per
worker
per
monitoring
period
per
fortification
level
for
each
matrix.
At
least
one
field
blank
per
worker
per
monitoring
period
for
each
matrix.
yes
mostly
Triplicate
field
fortifications
were
provided
on
three
separate
days
at
two
fortification
levels
at
all
three
sites.
However,
separate
samples
were
not
identified
for
each
worker.

When
collecting
urine
for
biological
monitoring,
collection
should
involve
24
hour
urine
samples.
A
minimum
of
one
baseline,
pre­
exposure
24
hour
sample
must
be
collected.
Twenty­
four
hour
samples
must
be
collected
for
the
day
of
application
and
for
sufficient
days
postapplication
as
determined
by
the
excretion
profile
of
the
pesticide.
not
applicable
not
applicable
27
SUMMARY
OF
DATA
GAPS
WITH
RESPECT
TO
SERIES
875
GUIDELINES:

Pertinent
items
in
regards
to
scientific
validity
and
Series
875
compliance,
not
addressed
previously,
are
described
below.
The
following
issues
were
noted:

°
The
amount
of
product
applied
and
the
amount
of
active
ingredient
handled
by
each
worker
was
calculated;
however
exposure
was
not
presented
as
a
unit
exposure
(
mg/
lb
ai).

°
Triplicate
field
fortifications
were
provided
on
three
separate
days
at
two
fortification
levels
at
all
three
sites.
However,
separate
samples
were
not
identified
for
each
worker.
There
were
more
workers
monitored
than
were
field
fortification
and
field
blank
samples
collected.

°
Data
were
corrected
for
field
recovery;
however,
only
the
corrected
data
were
presented
in
the
report.
Data
before
correction
were
not
reported.

CONCLUSIONS
AND
RECOMMENDATIONS:

The
assessment
for
this
study
focused
on
Series
875
compliance
and
issues
of
technical
merit.
As
indicated
in
the
review
findings
cited
above,
the
study
does
meet
most
of
Series
875
guideline
requirements
(
the
method
validation,
field
spikes,
and
QA/
QC
were
thoroughly
explained);
however,
some
minor
issues
are
as
follows:(
1)
data
were
not
reported
as
unit
exposures
(
e.
g.,
mg/
lb
ai)
therefore
differences
in
CCA/
ACZA
chemical
usage,
versus
exposure
between
facilities
were
not
examined
thoroughly;
(
2)
data
were
corrected
based
on
field
recovery;
however,
only
the
corrected
data
were
presented
in
the
study
and
the
corrections
calculations
were
not
expressed;
and
(
3)
separate
field
fortification
samples
were
not
collected
for
each
worker
job
function;
only
triplicate
field
fortification
samples
were
collected
at
each
site.

In
spite
of
these
deficiencies,
the
Agency
considers
these
data
as
acceptable
in
satisfying
the
application
exposure
data
guideline
requirements
under
Series
875
for
both
dermal
and
inhalation
exposure
monitoring
(
guidelines
875.1100/
875.1200
for
dermal
and
875.1300/
875.1400
for
inhalation)
and
recommends
use
of
these
data,
where
appropriate,
in
developing
the
occupational
exposure
estimates
for
certain
handler
scenarios
in
the
CCA
RED
human
exposure
chapter.
It
is
also
recommended
that
data
from
monitored
workers
involved
with
tasks
that
are
done
after
the
wood
has
been
pressure
treated
(
e.
g.,
data
for
Test
Borer
and
Stacker
Operator
functions)
be
used
in
estimating
certain
post­
application
exposure
doses.

cc:
Doreen
Aviado/
RASSB/
AD(
7510C)
Chemical
File
Circulation
