UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
December
16,
2003
MEMORANDUM
SUBJECT:
THIRAM
­
Revised
HED
Chapter
of
the
Reregistration
Eligibility
Decision
Document
(
RED)

PC
Code:
079801
Case
#
819239
DP
Barcode:
D293295
FROM:
Felecia
A.
Fort,
Risk
Assessor
Reregistration
Branch
I/
HED
(
7509C)

THROUGH:
Whang
Phang,
Ph.
D.,
Branch
Senior
Scientist
Reregistration
Branch
I/
HED
(
7509C)

TO:
Craig
Doty,
Chemical
Review
Manager
Special
Review
Branch/
SRRD
The
Health
Effects
Division
(
HED)
has
conducted
a
revised
risk
assessment
for
thiram.
This
assessment
supercedes
the
HED
chapter
of
the
Reregistration
Eligibility
Decision
Document
(
RED)
dated
June
24,
2003
(
F.
Fort,
D291237).
This
assessment
has
been
revised
to
incorporate
changes
to
the
Environmental
Fate
and
Ecological
Effects
Assessment
and
Characterization
which
included
revised
drinking
water
EECs.
A
cumulative
risk
assessment
considering
risks
from
other
pesticides
or
chemical
compounds
having
a
common
mechanism
of
toxicity
is
not
included
in
this
assessment.
Supporting
information
for
this
risk
assessment
included
the
following
documents:

Thiram
­
Use
Closure
Memo.
K.
Rothwell;
3/
20/
00
Thiram
­
Product
and
Residue
Chemistry
Chapter.
F.
Fort;
4/
17/
00
D264769
Thiram
­
Report
of
the
Hazard
Identification
Assessment
Review
Committee.
E.
Méndez
4/
14/
03
Thiram
­
Cancer
Considerations
Memorandum.
W.
Burnam;
4/
7/
00
Thiram
­
Dermal
Absorption
Factor;
Report
of
the
Hazard
Identification
Assessment
Review
Committee.
E.
Méndez;
1/
18/
00
Thiram
­
Toxicology
Disciplinary
Chapter
for
the
Reregistration
Eligibility
Decision;
E.
Mendez;
3/
5/
00;
D263948
Thiram
­
Dietary
Exposure
Analysis
for
the
HED
Preliminary
Human
Health
Risk
Assessment.
F.
Fort;
4/
30/
03;
D289657
Thiram
­
Environmental
Fate
and
Ecological
Effects
Assessment
and
Characterization.
J.
Carleton
and
F.
Jenkins;
12/
11/
03
Thiram
­
Revised
Phase
5
Occupational
and
Residential
Exposure
Assessment
and
Recommendations
for
the
Reregistration
Eligibility
Decision
Document.
J.
Dawson;
4/
24/
03;
D289601.
Thiram
­
Review
of
Incident
Reports.
J.
Blondell
and
M.
Spann;
3/
29/
00;
D264598
Thiram
­
OREDCI
Waiver
Memorandum.
T.
F.
Moriarty;
3/
24/
97
THIRAM
HED
Human
Health
Risk
Assessment
December
16,
2003
TABLE
OF
CONTENTS
INTRODUCTION
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3
1.0
EXECUTIVE
SUMMARY
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4
2.0
PHYSICAL/
CHEMICAL
PROPERTIES
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8
3.0
HAZARD
CHARACTERIZATION
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9
3.1
Hazard
Profile
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9
3.2
FQPA
Safety
Factor
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12
3.3
Dose
Response
and
Hazard
Endpoint
Selection
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14
Table
1.
Acute
Toxicity
Data
on
Thiram
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16
Table
2.
Summary
of
Toxicological
Dose
and
Endpoints
for
Thiram
for
Use
in
Human
Risk
Assessment.
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17
4.0
DIETARY
EXPOSURE
AND
RISK
ASSESSMENT
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18
4.1
Summary
of
Registered
Uses
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18
4.2
Dietary
Exposure
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19
4.2.1
Acute
Dietary
Exposure
Assessment.
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21
Table
3.
Summary
of
Thiram
Acute
Dietary
Exposure
and
Risk
Estimates.
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21
4.2.2
Chronic
Dietary
Exposure
Assessment.
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22
Table
4.
Summary
of
Thiram
Chronic
Dietary
Exposure
and
Risk
Estimates.
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22
Table
5.
Acute
Dietary
Exposure
Sensitivity
Analysis
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23
4.3
Drinking
Water
Sources
of
Dietary
Exposure
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24
Surface
and
Groundwater
Monitoring
Data
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24
Groundwater
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24
Surface
Water
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25
Table
6.
EECs
for
use
in
the
human
health
risk
assessment
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25
5.0
OCCUPATIONAL/
RESIDENTIAL
EXPOSURE
AND
RISK
ASSESSMENT
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25
5.1
Non­
Occupational
(
Residential
and
Recreational)
Risk
Assessments
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26
5.1.1
Residential
Postapplication
Risk
Assessment
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27
Table
7.
Summary
of
Postapplication
Residential
Risks
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32
Table
8.
Summary
of
Postapplication
Residential
Aggregate
MOEs
for
Toddlers
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32
5.1.2
Residential
Risk
Characterization
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33
5.2
Occupational
Risk
Assessment
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34
5.2.1
Occupational
Handler
Risk
Assessment
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34
5.2.2
Occupational
Handler
Non­
Cancer
Risks
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41
Table
11.
Summary
of
Occupational
Handler
Risks
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42
5.2.3
Postapplication
Exposure
Risk
Assessment
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44
5.2.4
Occupational
Postapplication
Non­
Cancer
Risks
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47
Table
12.
Summary
of
Postapplication
Worker
Risks
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47
5.2.5
Occupational
Risk
Characterization
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48
5.2.5.1
Occupational
Handler
Risk
Characterization
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48
5.2.5.2
Occupational
Postapplication
Risk
Characterization
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50
5.3
Incident
Report
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52
5.4
Additional
Data
Requested
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53
6.0
AGGREGATE
EXPOSURE
AND
RISK
ASSESSMENT
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54
6.1
Acute
Aggregate
Exposure
and
Risk
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55
Table
13.
Acute
DWLOC
Comparison
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55
6.2
Short/
Intermediate
Term
Aggregate
Exposure
and
Risk
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55
Table
14.
Short/
Intermediate
Term
DWLOCs
Comparison
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56
6.3
Chronic
Aggregate
Risk
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56
Table
15.
Chronic
DWLOCs
Comparison
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56
7.0
CUMULATIVE
EXPOSURE
AND
RISK
ASSESSMENT
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57
8.0
ENDOCRINE
DISRUPTORS
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57
9.0
DATA
NEEDS
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57
9.1
Toxicology
Data
Needs
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57
9.2
Product
Chemistry
Data
Needs
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57
9.3
Residue
Chemistry
Data
Needs
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59
9.4
Occupational/
Residential
Exposure
Data
Needs
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59
10.0
BIBLIOGRAPHY
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60
3
INTRODUCTION
This
revised
human
health
risk
assessment
for
thiram
incorporates
the
most
recent
deliberations
on
the
hazard
components
of
risk
including
review
of
a
new
acute
neurotoxicity
study
in
rats,
and
endpoints
for
incidental
oral
exposure
risk
assessments.
The
potential
for
increased
susceptibility
of
infants
and
children
from
exposure
to
Thiram
was
also
evaluated
as
required
by
the
Food
Quality
Protection
Act
(
FQPA)
of
1996
taking
into
consideration
the
submission
of
a
new
Multigeneration
Reproduction
Toxicity
study
and
the
2002
OPP
10X
Guidance.
This
assessment
also
includes
the
incorporation
of
new
percent
crop
treated
information,
the
results
of
strawberry
washing
and
apple
processing
studies,
revised
transfer
coefficients,
a
strawberry
dislodgeable
foliar
residue
study,
revised
use/
usage
information,
and
revised
application
rates.
An
acute
dietary
risk
assessment
has
been
conducted
using
a
probabilistic
approach
and
DEEM­
FCID
 
Software,
up­
to­
date
usage
(
percent
crop
treated)
data,
and
the
hazard
endpoint
and
dose
derived
from
an
Acute
Neurotoxicity
Study
in
the
Rat.
Chronic
dietary
risks
were
calculated
using
the
dose
and
endpoints
selected
from
a
Combined
Chronic
Toxicity/
Carcinogenicity
Study
in
rats
and
the
Chronic
Oral
Toxicity
Study
in
Dogs
and
a
DEEM
­
FCID
 
Software,
and
percent
crop
treated
data.
Thiram
has
been
classified
as
"
Not
Likely
To
Be
Carcinogenic
to
Humans."
Occupational
risks
were
calculated
to
reflect
potential
human
exposure
via
the
dermal
and
inhalation
routes.
The
endpoint
and
dose
selected
for
short/
intermediate
term
dermal
exposure
were
derived
from
a
21­
Day
Dermal
Toxicity
Study
in
Rabbits
which
reflects
the
most
relevant
route
and
duration
of
exposure.
The
endpoint
and
dose
identified
in
the
Multigeneration
Reproduction
Toxicity
Study,
the
Combined
Chronic
Toxicity/
Carcinogenicity
study
in
rats
and
the
Chronic
Oral
Toxicity
study
in
Dogs
were
used
for
short­
and
intermediate­
term
incidental
oral
exposures,
while
the
endpoint
and
dose
from
the
Chronic
Oral
Toxicity
Study
in
Dogs
and
the
Combined
Chronic
Toxicity/
Carcinogenicity
study
in
rats
were
selected
for
use
in
the
longterm
dermal
and
all
inhalation
exposure
assessments.
Given
the
current
use
patterns
for
thiram,
no
long­
term
occupational/
residential
exposure
risks
are
anticipated.
Private
homeowners
will
no
longer
be
able
to
purchase
and
handle
thiram
products.
It
has
been
determined,
however,
that
certain
turf
and
animal
repellency
uses
may
result
in
residential/
recreational
exposure
thereby
making
it
necessary
to
conduct
a
residential
post­
application
risk
assessment.
An
assessment
for
the
potential
exposure
to
thiram
via
drinking
water
was
also
conducted.
Aggregate
chronic
risks
resulting
from
chronic
exposure
to
thiram
via
the
diet
(
food
and
drinking
water
only)
were
assessed
since
the
current
use
patterns
indicate
no
chronic
residential
exposures
scenarios.
are
anticipated.
An
aggregate
risk
assessment
for
acute
dietary
exposures
was
not
conducted
since
the
potential
risks
from
food
exposure
alone
are
of
concern.
As
a
result,
any
aggregation
of
drinking
water
exposure
levels
would
only
serve
to
increase
the
reported
risks.
Short­
term
aggregate
exposure
risk
assessments
were
also
conducted.
4
1.0
EXECUTIVE
SUMMARY
The
database
for
thiram
has
been
evaluated
by
the
Health
Effects
Division
(
HED)
in
the
Office
of
Pesticide
Programs
(
OPP)
and
a
human
health
risk
assessment
has
been
conducted.
This
assessment
supersedes
any
previous
assessments.

Thiram
is
a
dimethyl
dithiocarbamate
compound
used
as
a
fungicide
to
prevent
crop
damage
in
the
field
and
to
protect
harvested
crops
(
apples,
peaches,
and
strawberries)
from
deterioration
in
storage
or
transport.
It
is
also
used
as
a
seed
protectant
(
e.
g.
small
seeded
vegetables,
large
seeded
vegetables,
cereal
grains,
other
seeds,
coniferous
seeds,
cotton
seed,
ornamental
seeds,
and
soybeans)
and
to
protect
turf
from
fungal
diseases.
In
addition,
thiram
is
used
as
an
animal
repellent
to
protect
crops
from
damage
by
rabbits,
rodents,
and
deer.
This
chemical
is
registered
as
a
General
Use
Pesticide
(
GUP)
by
the
U.
S.
Environmental
Protection
Agency
(
EPA).
Tolerances
for
residues
in/
on
food
and
feed
commodities
are
currently
expressed
in
terms
of
residues
of
thiram
(
CFR
§
180.132)
per
se
and
are
established
at
7
ppm
for
apples,
peaches,
and
strawberries.
Seed
treatments
are
considered
to
be
nonfood
uses
and
therefore
do
not
require
a
tolerance.

Thiram
is
available
as
dust,
dry
flowable,
wettable
powder,
flowable
concentrate,
soluble
concentrate,
and
liquid
(
ready
to
use)
formulations.
It
may
be
applied
to
peaches,
strawberries,
and
apples
using
ground
and
aerial
equipment.
For
other
specialty
uses
(
i.
e.
animal
repellent)
as
well
as
seed
treatment,
applications
may
be
made
using
hand
held
equipment.
Thiram
may
be
applied
1
­
7
days
before
harvest
depending
on
the
crop,
geographic
location
and
pest.
Recreational
exposure
to
thiram
is
expected
as
a
result
of
the
use
on
golf
course
fairways,
greens,
and
tees.
The
only
registered
residential
use
is
as
an
animal
repellent.
(
Memorandum
from
Kylie
Rothwell
3/
20/
00;
Appendix
II).

Thiram
has
a
low
to
moderate
acute
toxicity
profile
(
generally
Toxicity
Category
IV
to
II).
The
currently
available
toxicological
database
for
thiram
suggests
that
this
chemical
has
the
potential
to
be
a
significant
neurotoxicant
(
in
adults
and
children)
as
well
as
a
developmental
and
reproductive
toxicant.
A
1976
study
in
rats
by
Lee
and
Peters,
supports
the
idea
that
thiram
is
a
significant
neurotoxicant.
In
that
study,
Charles
River
CD
rats
exposed
to
thiram
in
their
diet,
showed
significant
signs
of
neurotoxicity
such
as
ataxia
and
paralysis
of
the
hind
legs
along
with
histopathology
changes
in
the
nervous
system
(
demyelination,
macrophage
infiltration
of
the
nerve
bundle
in
the
sciatic
nerve,
etc.).
The
neurotoxic
effects
of
thiram
reported
in
other
studies
submitted
to
the
Agency
by
the
registrant
include
lethargy,
reduced
tail
pinch
response,
no
tail
pinch
response,
reduced
brain
weights,
and
reduced
motor
activity.
Severe
fetal
malformations
including
CNS
defects
(
anophthalmia,
microphthalmia,
and
hydrocephalus),
as
well
as
protruding
tongues,
unilateral
renal
agenesis,
cleft
palate,
and
reduced
ossifications
have
been
reported
after
in
utero
exposure
to
thiram
at
dose
levels
that
did
not
cause
maternal
toxicity.
Finally,
the
chronic
toxicity
profile
indicates
that
hematology
and
clinical
chemistry
parameters
as
well
as
the
liver,
and
kidneys
are
affected
after
prolonged
exposure
to
this
compound.
However,
after
careful
consideration
and
analysis
of
the
currently
available
toxicity
data,
it
has
been
determined
that
thiram
can
be
classified
as
"
Not
Likely
To
Be
Carcinogenic
to
Humans".
5
Based
on
the
toxicity
profile,
the
Health
Effects
Division
(
HED)
has
selected
an
endpoint
based
on
neurotoxicity
obtained
from
the
Acute
Neurotoxicity
Study
in
Rats
for
use
in
the
acute
risk
assessment.
The
endpoint
selected
for
chronic
risk
assessment
is
based
on
changes
in
hematology,
clinical
chemistry,
incidences
fo
bile
duct
hyperplasia
and
reduction
in
body
weight
seen
in
a
Combined
Chronic
Toxicity/
Carcinogenicity
study
in
Rats
in
conjunction
with
elevated
cholesterol
levels
and
increased
relative
liver
weight
reported
in
the
Chronic
Oral
Toxicity
Study
in
Dogs.
Since
thiram
has
been
classified
as
a
chemical
"
not
likely
to
be
carcinogenic
to
humans",
no
cancer
risk
assessment
has
been
conducted.
In
the
case
of
short/
intermediate­
term
dermal
exposure,
a
21­
Day
Dermal
Toxicity
Study
was
used
to
obtain
the
endpoint
(
changes
in
clinical
chemistry,
decreased
body
weight
gain,
and
decreased
food
consumption)
and
dose
(
300
mg/
kg/
day)
to
be
used
in
the
risk
assessment.
Given
that
the
thiram
database
does
not
contain
any
inhalation
studies,
the
endpoint
selected
for
inhalation
exposure
(
all
durations)
is
based
on
the
same
endpoints
selected
for
the
chronic
risk
assessment.
These
studies
were
also
used
in
selecting
the
endpoint
and
dose
for
the
long­
term
dermal
exposure.
The
current
use
pattern
and
registered
uses
for
thiram
do
not
indicate
long­
term
occupational/
residential
exposure
risks.
Consequently,
long­
term
risk
assessments
via
the
dermal
and/
or
inhalation
routes
were
not
conducted.
HED
also
selected
endpoints
for
short­
and
intermediate­
term
incidental
oral
exposure.
The
endpoints
were
based
on
decreased
pup
weight
and
pup
weight
gain
seen
in
a
Multigeneration
Reproduction
Toxicity
study
that
is
supported
by
data
from
the
Combined
Chronic
Toxicity/
Carcinogenicity
study
in
Rats
and
the
Chronic
Oral
Toxicity
Study
in
Dogs
Dietary
analyses
were
done
using
the
DEEM­
FCID
 
software
reflecting
the
use
of
anticipated
residues
based
on
field
trial
data
and
percent
crop
treated
information.
Since
field
trial
data
were
used,
these
assessment
are
considered
to
be
somewhat
conservative.
These
assessments
could
be
further
refined
by
using
monitoring
data
if
sufficient
monitoring
data
were
available.
Washing,
cooking,
and
other
processing
factors
were
incorporated
into
the
dietary
assessment
and
provide
another
level
of
refinement.

A
Tier
3
probabilistic
acute
dietary
risk
assessment
was
conducted
using
an
aPAD
(
acute
Population
Adjusted
Dose)
of
0.005
mg/
kg/
day.
For
all
supported
registered
commodities,
the
acute
risk
estimates
are
above
the
Agency's
level
of
concern
at
the
99.9th
exposure
percentile
for
the
general
U.
S.
population
(
380%
of
the
aPAD)
and
all
population
subgroups.
The
acute
dietary
exposure
estimate
for
children
1­
2
years
old,
the
highest
exposed
population
subgroup,
is
1005%
of
the
aPAD.

When
chronic
dietary
risk
assessments
were
performed,
the
risks
for
children
1­
2
years
of
age
(
the
most
highly
exposed
population
subgroup)
were
28%
of
the
cPAD
which
is
below
the
Agency's
level
of
concern.
Exposure
to
the
U.
S.
General
Population
was
8%
of
the
cPAD.

Thiram
is
not
available
for
sale
or
use
by
homeowner
applicators.
As
such,
all
residential
risks
were
calculated
related
to
the
non­
residential
turf
uses
that
include
golfing
for
adults
and
toddler
exposures
in
areas
that
can
be
treated
such
as
parks
and
playgrounds.
In
residential
settings,
the
Agency
does
not
use
REIs
or
other
mitigation
approaches
to
limit
exposures
because
they
are
viewed
as
impractical
and
not
enforceable.
Risk
estimates
on
the
day
of
application
are,
therefore,
6
the
key
concern.
It
should
also
be
noted
that
for
thiram,
short­
term
calculations
are
protective
since
the
exposure
and
hazard
inputs
are
the
same
for
intermediate­
term
exposures
but
these
exposures
would
also
involve
an
amortization
step.
For
golfers,
MOEs
were
<
1000,
the
level
of
concern,
on
the
day
of
application
but
exceeded
1000
within
3
days
after
application
depending
upon
the
data
used
for
the
assessment.
For
toddlers,
MOEs
on
the
day
of
application
were
all
<
10
regardless
of
the
application
rate
considered
or
the
source
of
the
residue
dissipation
data.

The
residential
risk
assessment
for
thiram
was
based
on
both
Agency
inputs
that
are
typically
used
in
lieu
of
data
and
also
on
the
strawberry
dislodgeable
foliar
residue
study
that
was
conducted
in
California
and
Florida.
The
Agency
felt
that
the
strawberry
DFR
data
were
appropriate
to
use
for
defining
decay
rates
for
residues
over
time
and
also
to
establish
initial
concentrations
of
residues
for
the
toddler
object­
to­
mouth
assessment.
In
the
strawberry
study
at
both
sites,
the
initial
percent
dislodgeability
was
very
high
(
i.
e.,
~
35%)
so
these
data
were
not
used
for
anything
except
the
object­
to­
mouth
assessment
where
exposures
are
thought
to
be
more
similar
to
the
aqueous
wash
technique
than
others.
It
is
clear
that
additional
data
could
be
used
to
refine
the
residential
risk
assessment,
especially
for
toddlers,
and
that
these
data
could
include
a
thiram­
specific
turf
transferable
residue
study
and
a
study
that
could
better
define
doses
received
from
hand­
to­
mouth
exposures.

In
examining
aggregate
exposure,
EPA
takes
into
account
the
available
and
reliable
information
concerning
exposures
from
pesticide
residues
in
food
and
other
exposures
including
drinking
water
and
non­
occupational
exposures,
e.
g.,
exposure
to
pesticides
used
in
and
around
the
home
(
residential).
Risk
assessments
for
aggregate
exposure
consider
short­,
intermediate­
and
long
term
(
chronic)
exposure
scenarios
considering
the
toxic
effects
which
would
likely
be
associated
with
each
exposure
duration.
There
are
residential
uses
of
thiram;
therefore,
the
considerations
for
aggregate
exposure
are
those
from
food,
water,
and
residential
uses.
Since
conservative
modeling
was
done
to
estimate
concentrations
in
drinking
water,
Drinking
Water
Levels
of
Comparison
(
DWLOCs)
were
calculated.
A
DWLOC
is
a
theoretical
upper
concentration
limit
for
a
pesticide
in
drinking
water
based
on
how
much
of
the
PAD
remains
once
exposures
in
food
and
in
the
home
have
been
estimated
and
subtracted.

Aggregate
chronic
risks
resulting
from
chronic
exposure
to
thiram
via
dietary
(
food
and
drinking
water)
exposures
were
assessed
(
given
the
current
use
patterns,
no
chronic
residential
exposure
scenarios
are
anticipated).
To
determine
the
maximum
contribution
of
thiram
residues
in
the
drinking
water
to
the
aggregate
risk
that
would
not
exceed
the
Agency's
level
of
concern,
Drinking
Water
Levels
of
Comparison
(
DWLOCs)
are
calculated.
A
comparison
of
the
DWLOC
and
the
EECs
(
Estimated
Environmental
Concentration)
obtained
from
the
PRZM/
EXAMS
(
surface
water)
and
SCIGROW
(
ground
water)
models
indicate
that
the
drinking
water
residue
contribution
to
the
chronic
aggregate
risk
is
not
of
concern..
A
short/
intermediate
term
aggregate
risk
assessment
was
also
conducted.
Short­
term
DWLOCs
were
calculated
based
upon
average
food
residues
and
residential
post­
application
exposure
to
golfing
adults
who
are
exposed
to
thiram
after
application
to
turf.
These
calculations
were
done
using
the
lower
bound
application
rate
of
16.3
lb
ai/
A.
The
registrants
have
indicated
the
lower
rate
is
the
rate
that
will
be
supported.
A
short/
intermediate
term
aggregate
risk
assessment
for
children
and
for
adults
using
7
the
highest
application
rate
of
24.5
lbs
ai/
A
have
not
been
calculated
since
the
MOEs
derived
from
the
residential/
recreational
risk
assessment
alone
exceed
the
Agency's
level
of
concern.
Consequently
any
aggregation
would
only
serve
to
increase
the
reported
risk.
Surface
and
ground
water
concentrations
estimated
using
modeling
are
at
or
below
the
short­
term
DWLOC
for
thiram.
Consequently,
there
is
no
short­
term
exposure
concern
for
drinking
water
from
groundwater
or
surface
water
sources.

An
aggregate
risk
assessment
for
acute
dietary
exposure
was
not
conducted
at
this
time
since
the
potential
risks
from
food
exposure
alone
are
of
concern.
Any
aggregation
of
drinking
water
exposure
levels
would
only
serve
to
increase
the
reported
risks.
However,
an
acute
DWLOC
was
calculated
assuming
no
food
contribution
to
the
exposure.
The
results
indicated
that
water
alone
will
not
consume
the
entire
risk
cup
and
is
not
of
concern.

Occupational
exposure
assessments
were
also
conducted
for
thiram.
Since
chemical­
specific
handler
exposure
data
are
not
available,
the
majority
of
analyses
for
short/
intermediate­
term
exposure
were
performed
using
the
Pesticide
Handlers
Exposure
Database
(
PHED).

Generally,
most
scenarios
have
risks
associated
with
them
that
meet
or
exceed
the
Agency's
uncertainty
factors
for
noncancer
risk
assessments
at
some
level
of
personal
protection.
Current
thiram
labels
typically
require
that
handlers
wear
long
pants,
long­
sleeved
shirts,
and
gloves.
Respirators
are
generally
not
required.
For
approximately
one
half
of
the
scenarios,
risks
for
this
personal
protection
ensemble
do
not
meet
Agency
risk
requirements
and
additional
levels
of
personal
protection
are
required
to
achieve
Agency
risk
targets.
In
fact,
in
some
cases
engineering
controls
such
as
closed
loading
systems
are
needed.
Risks
can
be
reduced
to
target
levels
for
most
scenarios
that
do
not
meet
risk
targets
with
the
use
of
a
protection
factor
5
respirator
(
e.
g.,
a
disposable
dust/
mist
type
device).
As
would
be
expected,
the
scenarios
with
the
highest
associated
risk
also
have
application
rates,
high
acreages/
amounts
treated,
and/
or
the
exposures
for
the
scenarios
in
question
are
relatively
high.
Generally,
the
areas
that
appear
to
be
problematic
include:
some
loading
scenarios
for
aerial
applications,
aerial
granular
application,
some
handheld
equipment
use,
and
a
few
commercial
and
on­
farm
seed
treatment
scenarios.
Several
data
gaps
were
also
identified
in
many
different
use
areas
that
include:
in­
furrow/
at­
plant
applications;
repellent
paint­
on
applications;
powered
backpack;
engineering
control
data
for
seed
treatment;
on­
farm
seed
treatment
data
with
different
application
methods
(
e.
g.,
admixture);
sprinkler
can;
and
bulb
dip
applications.

The
Agency
has
determined
that
workers
may
be
exposed
to
thiram
upon
entering
occupational
areas
which
have
been
previously
treated
with
thiram
to
perform
specific
work
activities
in
these
areas
(
e.
g.,
scouting,
staking/
tying,
irrigating,
harvesting);
consequently,
an
occupational
postapplication
risk
assessment
was
conducted.
Current
label
requirements
specify
24
hour
REIs.
For
all
but
the
highest
exposure
scenarios,
risks
are
not
of
concern
(
i.
e.,
MOEs>
100)
at
the
current
REI.
The
high
exposure
tasks
that
are
of
concern
include
apple
thinning
(
MOEs
>
100
at
6­
7
days),
peach
thinning
on
the
east
coast
(
MOE>
100
at
2
days),
and
high
contact
turf
activities
such
as
sod
harvest
or
golf
course
maintenance
(
MOEs>
100
at
12­
21
days).
The
uncertainties
associated
with
this
assessment
should
also
be
considered
including
strawberry
data
were
used
for
8
all
assessments,
the
repellency
use
pattern
is
not
well
defined,
and
no
turf
specific
data
were
available.

2.0
PHYSICAL/
CHEMICAL
PROPERTIES
Thiram
(
tetramethylthiuram
disulfide)
is
a
dimethyl
dithiocarbamate
used
as
a
fungicide
to
prevent
crop
damage
in
the
field
and
to
protect
harvested
crops
(
apples,
peaches,
and
strawberries)
from
deterioration
in
storage
or
transport.
It
is
also
used
as
a
seed
protectant
and
to
protect
turf
from
fungal
diseases.
In
addition,
thiram
is
used
as
an
animal
repellent
to
protect
crops
from
damage
by
rabbits,
rodents,
and
deer.

Empirical
Formula:
C
6
H
12
N
2
S
4
Molecular
Weight:
240.44
CAS
Number:
137­
26­
8
PC
Code:
079801
Thiram
is
a
crystalline
solid
with
a
melting
point
of
142­
150

C,
bulk
density
of
0.32­
0.35
g/
mL,
octanol/
water
partition
coefficient
(
P
ow)
of
39.5­
54.1,
and
vapor
pressure
of
1.6­
1.8
x
10­
5
Torr
at
25

C.
Thiram
is
slightly
soluble
in
water
(
0.00165
g/
100
mL),
petroleum
ether
(
0.0005
g/
100
mL),
benzene
(
4.12
g/
100
mL),
acetone
(
6.97
g/
100
mL),
xylene
(
0.91
g/
100
mL),
and
methanol
(
0.184
g/
100
mL)
at
20­
25

C.

Most
pertinent
product
chemistry
data
requirements
have
been
satisfied
for
the
UCB
98.5%
T
and
the
Gustafson
97.5%
T;
additional
data
are
required
for
OPPTS
830.8314
and
7050
for
the
UCB
98.5%
T,
and
for
OPPTS
830.6314,
6317,
6320,
and
7050
for
the
Gustafson
97.5%
T.
All
data
requirements
for
the
Prochimie
98.5%
T
produced
by
an
unidentified
Spanish
source
remain
unfulfilled.
The
Agency
has
determined
that
data
for
certain
physical/
chemical
data
requirements
(
OPPTS
830.7370,
7550,
7840,
and
7950)
may
be
shared
among
Thiram
Task
Force
members;
however,
Prochimie
must
demonstrate
that
the
new
source
product
is
substantially
similar
to
thiram
products
registered
by
the
other
Task
Force
members.
Provided
that
the
registrants
submit
the
data
required
in
the
attached
data
summary
tables
(
refer
to
the
Product
Chemistry
Chapter)
for
the
98.5%
and
97.5%
MPs,
and
either
certify
that
the
suppliers
of
beginning
materials
and
the
manufacturing
processes
for
the
thiram
MPs
have
not
changed
since
the
last
comprehensive
product
chemistry
reviews
or
submit
complete
updated
product
chemistry
data
packages,
CBRS
has
no
objections
to
the
reregistration
of
thiram
with
respect
to
product
chemistry
data
requirements.

For
further
details,
refer
to
the
Product
and
Residue
Chemistry
Chapters
for
the
Thiram
Reregistration
Eligibility
Decision
Document
(
Memorandum
by
F.
Fort
4/
17/
00;
Appendix
III).

3.0
HAZARD
CHARACTERIZATION
9
3.1
HAZARD
PROFILE
The
toxicology
data
for
thiram
is
considered
to
be
adequate
to
support
the
current
Reregistration
Eligibility
Decision
(
RED)
and
has
been
evaluated
by
the
Health
Effects
Division
(
HED)
in
the
Office
of
Pesticide
Programs
(
OPP).
Thiram
is
a
neurotoxicant
which
can
also
act
as
a
developmental
toxicant.
The
neurotoxic
effects
of
thiram
include
lethargy,
reduced
tail
pinch
response,
no
tail
pinch
response,
reduced
brain
weights,
and
reduced
motor
activity.
Severe
fetal
malformations
including
CNS
defects
(
anophthalmia,
microphthalmia,
and
hydrocephalus),
as
well
as
protruding
tongues,
unilateral
renal
agenesis,
cleft
palate,
and
reduced
ossifications
have
been
reported
after
in
utero
exposure
to
thiram
at
dose
levels
that
did
not
cause
maternal
toxicity.

A
Developmental
Neuroxicity
Study
has
been
recommended
by
the
Hazard
Identification
Assessment
Review
Committee
(
HIARC)
to
provide
further
understanding
of
the
impact
thiram
exposure
may
have
on
the
developing
nervous
system
(
Report
of
the
Hazard
Identification
Assessment
Review
Committee;
3/
4/
99;
and
4/
14/
03.)
The
HIARC
has
also
recommended
submission
of
a
Cholinesterase
Activity
Assessment
Screening
Assay
based
on
concerns
for
potential
cholinesterase
activity
inhibition
by
thiram
as
was
seen
in
a
structurally
related
dithiocarbamate.
Also,
given
the
expected
use
patterns
for
this
compound
and
the
lack
of
inhalation
studies
appropriate
for
risk
assessments,
a
28­
day
inhalation
Toxicity
Study
including
appropriate
assessments
of
neurotoxicity
potential
is
required.

Thiram
has
a
low
to
moderate
acute
toxicity
profile;
the
acute
oral
LD
50
=
2.6
g/
kg
b.
w.
and
the
acute
dermal
LD
50

2.0
g/
kg
b.
w
(
Toxicity
Category
III).
In
an
acute
inhalation
study,
the
LC
50
for
thiram
was
established
at

0.1
mg/
L
(
the
most
concentrated
suspension
that
could
be
nebulized).
As
a
result,
thiram
is
considered
to
be
a
Toxicity
Category
II
chemical
via
the
inhalation
route
(
i.
e.
moderately
toxic).
Thiram
is
a
moderate
eye
irritant
(
Toxicity
Category
II),
a
slight
dermal
irritant
(
Toxicity
Category
IV),
and
a
moderate
skin
sensitizer.

The
subchronic
toxicity
profile
for
thiram
indicates
that
hematology,
clinical
chemistry
and
body
weight
are
the
parameters
affected
after
subchronic
exposure
to
the
compound
for
all
species
evaluated.

The
chronic
toxicity
profile
for
thiram
indicates
that
the
liver,
blood
and
urinary
system
are
the
target
organs
for
this
chemical.
In
a
Combined
Chronic/
Oncogenicity
Study
in
Rats,
effects
were
seen
at
a
dose
level
of
7.3
and
8.9
mg/
kg/
day
for
males
and
females,
respectively.
The
effects
described
at
these
dose
levels
included
changes
in
hematology
parameters,
increased
incidence
of
bile
duct
hyperplasia,
and
reduction
in
body
weight
gain.
At
higher
doses
in
this
study,
the
severity
of
the
toxicity
described
above
was
increased
and
other
signs
of
toxicity
such
as
an
increased
incidence
in
extramedullary
hematopoiesis
of
the
liver,
and
changes
in
clinical
chemistry
parameters
were
reported.
In
10
a
Chronic
Oral
Toxicity
Study
in
Dogs,
effects
were
seen
at
doses
>
2.61
mg/
kg/
day.
Toxicity
at
this
dose
level
was
manifested
as
elevated
cholesterol
levels
and
increases
in
liver­
to­
body
weight
ratio.
At
higher
dose
levels,
the
signs
of
toxicity
were
more
severe.
Signs
of
toxicity
in
a
carcinogenicity
study
in
mice
were
first
reported
at
a
dose
level
of
24
mg/
kg/
day
for
males
and
included
decreases
in
body
weight
gain,
anemia,
as
well
as
nonneoplastic
lesions
in
the
eyes,
non­
glandular
stomach
and
urinary
bladder.
At
higher
doses,
the
severity
of
these
signs
of
toxicity
was
greater.
In
addition,
decreases
in
RBC
counts,
hemoglobin,
and
hematocrit
levels
as
well
as
increased
hemosiderin
in
the
spleen
were
seen
at
the
higher
doses.

The
severity
of
developmental
toxicity
in
the
Thiram
database
varied
considerably.
In
one
Developmental
Toxicity
Study
using
Wistar
rats,
severe
fetal
malformations
including
CNS
defects
(
anophthalmia,
microphthalmia,
and
hydrocephalus)
as
well
as
protruding
tongues,
unilateral
renal
agenesis,
cleft
palate,
and
reduced
ossification
were
reported
at
doses
as
low
as
12.5
mg/
kg/
day
which
was
the
NOAEL
for
maternal
toxicity.
In
a
subsequent
Developmental
Toxicity
Study
using
Sprague­
Dawley
rats,
the
evidence
of
developmental
toxicity
was
not
as
severe
(
retarded
growth,
reduced
ossification,
and
a
rudimentary
13th
rib).
Furthermore,
a
developmental
NOAEL
of
7.5
mg/
kg/
day
was
established
in
this
latter
study.
The
potential
impact
of
thiram
exposure
on
development
in
rabbits
was
examined
in
three
studies
[
1
Range
Finding
Study,
2
Definitive
Studies].
Independently,
none
of
these
studies
is
acceptable
for
regulatory
purposes.
However,
when
considered
as
a
group,
they
provide
sufficient
information
to
assess
the
potential
developmental
toxicity
of
the
test
substance
in
rabbits.
The
results
of
these
studies
showed
no
developmental
toxicity
in
rabbits
in
the
absence
of
maternal
toxicity.
While
maternal
weight
loss
and
decreased
fetal
weights
were
reported
at
the
10
mg/
kg/
day
dose
in
the
range­
finding
study,
in
the
definitive
study
no
maternal
or
developmental
effects
were
noted
at
this
dose
level
(
highest
dose
tested).
However,
at
the
highest
dose
tested
in
the
range­
finding
study
(
20
mg/
kg/
day),
maternal
death
and
complete
litter
loss
were
seen.

In
addition
to
the
studies
submitted
to
the
Agency,
the
IARC
profile
for
thiram
(
1991)
provides
further
evidence
of
thiram's
potential
to
act
as
a
developmental
toxicant.
This
report
cites
embryolethality
and
embryotoxicity
in
rats
and
hamsters
and
malformations
in
mice
and
hamsters.
Furthermore,
in
a
developmental
toxicity
study
by
Robens
(
1969),
treatment
at
a
dose
level
of
100
mg/
kg
resulted
in
CNS
malformations
(
exencephaly)
thus
providing
additional
evidence
of
thiram's
potential
for
developmental
toxicity.

While
severe
developmental
effects
were
noted
in
a
guideline,
albeit
unacceptable,
study
in
rats
and
in
the
published
literature,
effects
noted
in
the
acceptable/
guideline
studies
were
less
severe
(
reduced
ossification
and
rudimentary
13th
rib),
occurred
at
doses
where
maternal
toxicity
was
evident,
or
in
the
case
of
rabbits
occurred
at
maternally
lethal
doses.
11
Consequently,
no
quantitative
or
qualitative
susceptibility
was
noted
in
the
acceptable/
guideline
Developmental
Toxicity
Studies
submitted
to
the
Agency
for
review.

Similarly,
the
results
of
two
Multigeneration
Reproduction
Toxicity
Studies
in
rats
did
not
reveal
increased
susceptibility
of
the
young
after
in
utero
and
perinatal
exposure
to
Thiram.
In
both
studies,
the
effects
noted
at
the
LOAEL
in
the
offspring
and
parental
animals
were
limited
to
decreases
in
body
weight
and/
or
body
weight
gain.
It
is
noteworthy,
however,
that
although
reproductive
parameters
were
not
affected
in
the
two
guideline
Multigeneration
Reproduction
Toxicity
Studies
in
rats,
a
1996
study
by
Stoker
et
al.
suggests
that
thiram
may
act
as
an
endocrine
disruptor
by
interfering
with
the
proestrus
surge
of
lutenizing
hormone.
Consequently,
the
possible
impact
of
thiram
in
disturbing
the
lutenizing
hormone
surge
has
not
been
thoroughly
explored,
and
the
current
design
of
the
guideline
studies
could
not
detect
this
effect.

The
mutagenicity
database
for
thiram
suggests
that
this
chemical
is
a
clastogen.
It
does
not,
however,
induce
unscheduled
DNA
synthesis
nor
does
it
increase
the
mutation
frequency
at
the
HPRT
locus.

The
thiram
database
contains
two
Acute
Neurotoxicity
Studies
and
one
Subchronic
Neurotoxicity
Study.
All
three
of
these
studies
provide
evidence
that
this
chemical
has
the
potential
to
be
a
significant
neurotoxicant
in
adults.
In
the
Acute
Neurotoxicity
Studies
in
Rats,
Functional
Observational
Battery
(
FOB)
effects
such
as
lethargy,
lower
temperature,
reduced
startle
response
and
no
tail
pinch
response
were
reported
as
well
as
reduced
motor
activity,
and
decreased
brain
weights.
Reduced
motor
activity
was
observed
at
3
½
hours,
and
7
and
14
days
after
treatment
with
the
test
article
suggesting
that
thiram's
effects
on
the
nervous
system
were
not
readily
reversed.
In
the
Subchronic
Neurotoxicity
Study,
rats
exposed
to
thiram
in
their
diet
exhibited
a
statistically
significant
increase
in
the
incidence
of
rearing
events
and
hyperactivity
in
females
and
males;
with
the
females
being
affected
at
a
lower
dose
level
than
males.
A
statistically
significant
decrease
in
body
weight
in
both
males
and
females
was
also
observed.
Further
evidence
of
the
potential
neurotoxicant
properties
of
thiram
is
provided
in
the
open
literature.
A
1976
study
in
rats
by
Lee
and
Peters
supports
the
idea
that
thiram
is
a
significant
neurotoxicant.
In
that
study,
Charles
River
CD
rats
exposed
to
thiram
in
their
diet,
showed
significant
signs
of
neurotoxicity
such
as
ataxia
and
paralysis
of
the
hind
legs
along
with
histopathology
changes
in
the
nervous
system
(
demyelination,
macrophage
infiltration
of
the
nerve
bundle
in
the
sciatic
nerve
etc.).

In
a
report
dated
June
10,
1997
the
RfD
Committee
recommended
that
a
Developmental
Neurotoxicity
Study
be
conducted
and
submitted
for
consideration
by
the
Agency.
That
recommendation
was
based
on
the
weight
of
the
evidence
including:
1)
findings
of
CNS
defects
(
anophthalmia,
microphthalmia,
and
hydrocephalus)
in
the
Developmental
Study
in
rats
(
MRID
00259810);
and
2)
neurotoxic
effects
in
the
Acute
and
Subchronic
Neurotoxicity
Study
(
MRID
42912401
and
43012701,
respectively).
This
study
has
not
12
been
submitted
to
the
Agency
for
review
and
is,
therefore,
still
outstanding.
In
addition,
the
Hazard
Identification
Assessment
Review
Committee
(
HIARC)
has
recommended
submission
of
a
Cholinesterase
Activity
Assessment
Screening
Assay
based
on
concerns
for
potential
cholinesterase
activity
inhibition
by
thiram
as
was
seen
in
ziram,
a
structurally
related
dithiocarbamate.

Thiram
is
readily
absorbed
(
via
the
oral
route),
distributed,
extensively
metabolized
and
eliminated
primarily
in
the
expired
air
and
urine
of
rats
following
single
or
repeated
oral
administrations.
Within
24
hours
of
administration
of
the
compound,
a
high
amount
of
radioactivity
was
eliminated
as
expired
air
(
14CO
2,
carbamyl
sulfide,
and
carbon
disulfide).
Identification
of
the
parent
compound
was
not
detected
in
the
urine.
Fecal
metabolites
were
not
evaluated
due
to
the
low
recovery
of
radioactivity
in
the
feces.
There
is
no
apparent
sex­
or
dose­
related
difference
in
the
distribution,
metabolism
or
excretion
of
14C­
thiram.
Bioaccumulation
of
14C­
thiram
in
tissues
was
low
(
1.54
­
4.24%
of
the
administered
dose).
Therefore,
an
appreciable
accumulation
of
thiram
is
not
anticipated
after
repeated
exposures.

The
dermal
absorption
factor
was
calculated
to
be
1%
based
on
the
LOAELs
(
Lowest
Observed
Adverse
Effect
Levels)
in
a
Range­
Finding
Study
for
the
Developmental
Toxicity
Study
in
rabbits
and
the
21­
day
Dermal
Toxicity
Study
in
rabbits.
The
Range­
Finding
Study
was
used
in
conjunction
with
two
definitive
studies
to
establish
the
developmental
rabbit
LOAEL
since
no
LOAEL
could
be
established
in
either
of
the
definitive
studies.
The
LOAEL
for
the
Range­
Finding
Study
was
established
at
10
mg/
kg/
day
based
on
maternal
weight
loss
coupled
with
a
marked
decrease
in
fetal
weight.
Thus,
the
LOAEL
for
the
Developmental
Range­
Finding
Study
in
rabbits
(
10
mg/
kg/
day)
and
the
LOAEL
for
the
21­
Day
Dermal
Toxicity
Study
in
Rabbits
(
1000
mg/
kg/
day)
are
based
on
decreased
body
weight
gain
(
common
endpoint)
(
Dermal
Absorption
Factor;
Report
of
the
Hazard
Identification
Assessment
Review
Committee;
1/
18/
00;
Appendix
VI).

It
should
be
noted
that
intolerance
to
alcohol
has
been
reported
in
workers
exposed
to
thiram
(
e.
g.
dizziness,
hypotension,
palpitations,
etc.).
This
effect
may
be
due
to
blocking
of
the
oxidation
of
acetaldehyde
(
caused
by
the
inhibition
of
the
enzyme
acetaldehyde
dehydrogenase).
Interestingly,
this
is
the
mode
of
action
of
the
drug
Antabuse
(
a
diethyl
homologue
of
thiram)
which
is
used
in
aversion
therapy
to
treat
alcoholism.

For
further
details
of
the
hazard
component
for
the
thiram
risk
assessment,
refer
to
the
Thiram
Toxicology
Disciplinary
Chapter
for
the
Reregistration
Eligibility
Decision
Document
by
E.
Mendez
dated
3/
5/
00
(
Appendix
VII).

3.2
FQPA
SAFETY
FACTOR
Database
Uncertainty
Factor
13
In
accordance
with
the
2002,
OPP
Guidance
Document
on
Determination
of
the
Appropriate
FQPA
Safety
Factor(
s)
in
Tolerance
Assessment,
the
HIARC
determined
that
a
10X
database
uncertainty
factor
(
UF
DB)
is
required.
After
careful
consideration
of
the
thiram
toxicological
database,
the
HIARC
concluded
that
there
was
insufficient
evidence
to
support
the
reduction
or
removal
of
the
default
10X
factor.
The
following
issues
were
considered
by
the
committee
during
its
deliberation:

°
It
is
assumed
that
the
DNT
study
will
be
conducted
at
dose
levels
similar
to
those
used
in
the
Reproduction
Toxicity
Study
in
rats
(
1.4,
4.2,
and
12.2
mg/
kg/
day)
in
which
the
offspring
NOAEL
is
1.4
mg/
kg/
day
and
the
LOAEL
is
4.2
mg/
kg/
day
based
on
decreases
in
pup
weight
and
pup
weight
gain.
°
It
is
possible
that
the
results
of
the
DNT
study
could
impact
the
doses
currently
used
for
regulatory
purposes
since
the
NOAELs
used
for
risk
assessment
(
5
mg/
kg/
day
for
acute
and
1.5
mg/
kg/
day
for
short,
intermediate,
and
chronic
assessments)
are
comparable
to
or
higher
than
the
offspring
NOAEL
in
the
rat
reproduction
study
conducted
with
thiram
(
1.4
mg/
kg/
day).
°
In
light
of
the
available
information,
HIARC
does
not
have
sufficient
reliable
data
justifying
selection
of
a
safety
factor
for
the
protection
of
infants
and
children
lower
than
the
default
value
of
10X.
Consequently,
a
UF
DB
of
10X
will
be
applied
to
all
dietary
and
residential
exposure
scenarios
to
account
for
the
lack
of
a
DNT
study
in
the
thiram
database.

Degree
of
Concern
Analysis
and
Residual
Uncertainties
Since
there
is
quantitative
evidence
of
increased
susceptibility
of
the
young
following
exposure
to
Thiram
in
the
(
unacceptable)
prenatal
developmental
study
in
rats
and
reported
in
the
open
literature,
HIARC
performed
a
Degree
of
Concern
Analysis
to:
1)
determine
the
level
of
concern
for
the
effects
observed
when
considered
in
the
context
of
all
available
toxicity
data;
and
2)
identify
any
residual
uncertainties
after
establishing
toxicity
endpoints
and
traditional
uncertainty
factors
to
be
used
in
the
risk
assessment
of
this
chemical.
If
residual
uncertainties
are
identified,
HIARC
examines
whether
these
residual
uncertainties
can
be
addressed
by
a
special
FQPA
safety
factor
and,
if
so,
the
size
of
the
factor
needed.
The
results
of
the
HIARC
Degree
of
Concern
analysis
for
Thiram
follow.

Although
there
is
a
high
degree
of
concern
for
the
quantitative
susceptibility
seen
in
the
unacceptable
Developmental
Toxicity
Study
in
rats,
there
is
no
residual
uncertainty
since
the
results
were
not
replicated
in
a
subsequent
acceptable
developmental
study
in
rats
and
when
doses
are
used
for
regulatory
purposes
are
taken
into
consideration.
Concern
for
the
potential
developmental
toxicity
of
thiram
is
also
raised
by
reports
in
the
published
literature.
However,
the
level
of
concern
is
low
when
the
doses
and
endpoints
selected
for
regulatory
purposes
are
taken
into
consideration.
This
determination
was
based
on
a
weight
of
the
evidence
analysis
that
takes
into
consideration
the
following
factors:
14

No
evidence
of
increased
quantitative/
qualitative
susceptibility
in
the
available
acceptable/
guideline
studies
.


Clear
NOAELs/
LOAELs
have
been
identified
for
the
effects
of
concern.


Dose­
response
relationships
for
the
effects
of
concern
are
well­
characterized.


The
doses
used
for
regulatory
purposes
are
at
least
10X
lower
than
the
doses
where
developmental
and
reproductive
toxicity
effects
were
reported
in
the
published
literature.

Special
FQPA
Safety
Factor(
s):

The
HIARC
concluded
that
the
Special
FQPA
Factor
could
be
reduced
to
1X.
This
conclusion
is
based
on
the
outcome
of
the
degree
of
concern
analysis
that
failed
to
identify
any
residual
uncertainties.

The
Special
FQPA
Safety
Factor
recommended
by
the
HIARC
assumes
that
the
exposure
databases
(
dietary
food,
drinking
water,
and
residential)
are
complete
and
that
the
risk
assessment
for
each
potential
exposure
scenario
includes
all
metabolites
and/
or
degradates
of
concern
and
does
not
underestimate
the
potential
risk
for
infants
and
children.

3.3
DOSE
RESPONSE
AND
HAZARD
ENDPOINT
SELECTION
The
endpoints
and
doses
selected
to
conduct
various
risk
assessments
are
described
below.
The
acute
toxicity
endpoints,
utilized
to
establish
the
appropriate
labeling
parameters,
are
summarized
in
Table
1.
Table
2
summarizes
the
doses
and
endpoints
selected
for
use
in
this
human
health
risk
assessment.


Acute
Toxicity.
Thiram
has
a
low
to
moderate
acute
toxicity
profile;
the
acute
oral
LD
50
=
2.6
g/
kg
b.
w.
and
the
acute
dermal
LD
50

2.0
g/
kg
b.
w
(
Toxicity
Category
III).
The
LC
50
for
thiram
was
established
at

0.1
mg/
L
(
the
most
concentrated
suspension
that
could
be
nebulized)
(
Toxicity
Category
II).
Thiram
is
a
moderate
eye
irritant
(
Toxicity
Category
II),
a
slight
dermal
irritant
(
Toxicity
Category
IV),
and
a
moderate
skin
sensitizer.


A
No
Observed
Adverse
Effect
Level
(
NOAEL)
of
5
mg/
kg
b.
w.
from
an
Acute
Neurotoxicity
Study
was
selected
for
acute
dietary
risk
assessment.
Lethargy,
reduced
tail
pinch
response,
reduced
brain
weights,
and
reduced
motor
activity
were
the
effects
seen
at
the
Lowest
Observed
Adverse
Effect
Level
(
LOAEL)
of
150
mg/
kg
b.
w.
Acute
dietary
risk
assessments
have
been
conducted
using
this
study.
The
uncertainty
factors
(
UF)
applied
were
10x
for
intraspecies
variation
and
10x
for
interspecies
extrapolation
and
10X
for
database
UF
due
to
lack
of
a
DNT
study
which
result
in
a
hazard­
based
UF
of
1000x.
Consequently,
the
calculated
acute
RfD
is
0.005
mg/
kg
b.
w.


Chronic
Dietary.
A
Combined
Chronic
Toxicity/
Carcinogenicity
Study
in
rats
15
and
Chronic
Oral
Toxicity
Study
in
dogs
were
used
to
conduct
this
risk
assessment.
These
studies
are
considered
to
be
co­
critical
studies
for
this
risk
assessment.
Although
the
Chronic
Oral
Toxicity
Study
in
dogs
has
a
lower
NOAEL
(
0.84
mg/
kg/
day)
than
the
Combined
Chronic/
Carcinogenicity
Study
in
rats
(
1.5
mg/
kg/
day),
the
use
of
the
dose
in
the
rat
study
would
address
the
effects
of
concern
seen
in
the
dog
study
(
elevated
cholesterol
levels
and
increased
liver
weights)
since
they
were
noted
at
a
higher
dose
(
2.6
mg/
kg/
day)
than
the
one
selected
for
regulatory
purposes
(
1.5
mg/
kg/
day).

Similarly,
use
of
these
studies
to
establish
the
cRfD
would
address
the
effects
of
concern
noted
in
the
developmental
and
reproduction
toxicity
studies.
While
the
NOAELs
for
all
acceptable/
guideline
developmental
studies
are
higher
than
the
NOAEL
selected
for
this
risk
assessment,
the
lowest
NOAEL
(
1.4
mg/
kg/
day)
for
a
Multigeneration
Reproduction
Toxicity
Study
in
rats
is
equivalent
to
the
1.5
mg/
kg/
day
in
the
Combined
Chronic
Toxicity/
Carcinogenicity
Study
(
the
difference
of
0.1
mg/
kg/
day
in
these
studies
is
within
the
margin
of
error
for
the
estimation
of
compound
intake
from
dietary
administration).

In
addition
to
the
10X
factor
for
interspecies
extrapolation
and
10X
factor
for
intraspecies
variation,
a
10X
UF
DB
factor
is
applied
to
this
risk
assessment
to
account
for
the
lack
of
a
DNT
study
as
discussed
earlier
in
this
assessment.


Carcinogenicity.
Thiram
is
not
considered
to
be
carcinogenic.
The
incidence
of
combined
hepatocellular
adenomas
and/
or
carcinomas
revealed
that
there
was
no
significant
pairwise
(
p=
0.05)
increases
in
these
tumors
at
any
dose.
In
addition,
although
there
were
no
historical
control
information
from
the
laboratory
on
combined
liver
adenomas
and
carcinomas,
the
high
dose
males
were
at
the
high
end
of
the
adenoma
historical
controls,
while
the
high
dose
females
were
slightly
outside.
Similarly,
the
thyroid
c­
cell
combined
adenomas
and/
or
carcinomas
showed
no
significant
trends
or
pairwise
increases
(
p=
0.05)
in
either
sex
and
the
incidences
for
all
doses
were
within
the
historical
controls.
Generally,
for
commonly
occurring
tumors
such
as
these,
pairwise
significance
between
the
controls
and
treated
groups
are
necessary
before
a
pesticide
needs
to
go
to
the
CARC.
(
Cancer
Assessment
Review
Committee).
Consequently,
it
has
been
determined
that
thiram
does
not
need
to
go
to
the
CARC
and
that
it
can
be
classified
as
"
Not
Likely
To
Be
Carcinogenic
to
Humans".
Consequently,
a
cancer
risk
assessment
was
not
conducted.


Incidental
Oral
Exposure:
Short/
Intermediate
Term.
Three
studies,
Chronic
Oral
Toxicity/
Carcinogenicity
in
rats,
Chronic
Oral
Toxicity
Study
in
dogs,
and
the
Multigeneration
Reproduction
Toxicity
Study
in
rats
were
considered
when
determining
the
dose
and
endpoint
for
these
risk
assessments.
The
NOAEL
of
1.5
mg/
kg/
day
is
based
on
changes
in
hematology,
clinical
chemistry
,
incidences
of
bile
duct
hyperplasia,
and
reduction
in
mean
body
weight
gain
seen
at
7.9
mg/
kg/
day
in
conjunction
with
decreases
in
pup
weight
and
pup
weight
gain
noted
16
in
the
Multigeneration
Reproduction
Toxicity
Study
at
4.2
mg/
kg/
day.
The
dose
and
endpoint
selected
for
this
risk
assessment
are
relevant
since
they
evaluate
potential
effects
of
thiram
exposure
on
the
population
of
concern
(
toddlers)
during
the
appropriate
time
of
exposure.
Although
the
Combined
Chronic
Toxicity/
Carcinogenicity
Study
in
rats
and
Chronic
Oral
Toxicity
Study
in
dogs
are
of
a
longer
duration
than
the
duration
of
exposure
in
this
risk
assessment,
the
NOAEL
in
the
Chronic
Rat
Study
(
1.5
mg/
kg/
day)
is
equivalent
to
the
offspring
NOAEL
(
1.4
mg/
kg/
day)
which
evaluates
the
population
of
concern
(
toddlers)
during
the
appropriate
time
of
exposure.
The
NOAELs
in
these
studies
are
equivalent
since
the
difference
of
0.1
mg/
kg/
day
is
within
the
margin
of
error
for
the
estimation
of
compound
intake
after
dietary
administration.
Use
of
the
Combined
Chronic
Toxicity/
Carcinogenicity
Study
in
rats
addresses
the
effects
of
concern
reported
in
the
Chronic
Oral
Toxicity
Study
in
dogs.


Short/
Intermediate
Term
Dermal.
The
rabbit
21­
Day
Dermal
Toxicity
Study
NOAEL
of
300
mg/
kg/
day
has
been
selected
for
these
risk
assessments.
In
this
study,
changes
in
clinical
chemistry
and
decreases
in
body
weight
gain
and
food
consumption
were
reported
at
the
LOAEL
of
1000
mg/
kg/
day.
MOEs
less
than
1000
are
of
concern
for
residential
assessments
based
on
intraspecies
variability
(
10x),
interspecies
extrapolation
(
10x)
and
the
database
uncertainty
factor
(
10x).
No
database
uncetainty
factor
is
applied
for
occupational
assessment;
therefore,
the
MOEs
less
than100
are
of
concern.


Long
Term
Dermal
and
Inhalation
(
All
Durations)
The
Chronic
Oral
Toxicity
Study
in
Dogs
and
the
Combined
Chronic
Toxicity/
Carcinogenicity
Study
in
Rats
were
selected
as
co­
critical
studies
for
use
in
this
risk
assessment.
The
LOAEL
of
7.3
mg/
kg/
day
was
based
changes
in
hematology,
clinical
chemistry
,
incidences
of
bile
duct
hyperplasia,
and
reduction
in
mean
body
weight
gain
seen
at
7.9
mg/
kg/
day
in
conjunction
with
elevated
cholesterol
levels
and
increased
liver
weights
reported
in
the
Chronic
Oral
Toxicity
Study
in
Dogs
at
2.6
mg/
kg/
day.
A
default
inhalation
absorption
factor
of
100%
was
assumed.

Table
1.
Acute
Toxicity
Data
on
Thiram
Guideline
No./
Study
Type
MRID
No.
Results
Toxicity
Category
870.1100
Acute
oral
toxicity
00163854
LD50
=
2.6
g/
kg/
day
III
870.1200
Acute
dermal
toxicity
00259250
LD50

2.0
g/
kg/
day
III
870.1300
Acute
inhalation
toxicity
00165855
LC50

0.1
mg/
L
II
870.2400
Acute
eye
irritation
00259250
Moderate
eye
irritant
II
870.2500
Acute
dermal
irritation
00259250
Very
slight
dermal
irritant
IV
870.2600
Skin
sensitization
00153068
Moderate
skin
sensitizer
17
Table
2.
Summary
of
Toxicological
Dose
and
Endpoints
for
Thiram
Exposure
Scenario
Dose
Used
in
Risk
Assessment,
UF
Special
FQPA
Safety
Factor*
and
Level
of
Concern
for
Risk
Assessment
Study
and
Toxicological
Effects
Acute
Dietary
(
All
Populations)
NOAEL
=
5
mg/
kg/
day
UF
=
1000*
Acute
RfD
=
0.005
mg/
kg/
day
FQPA
SF
=
1
aPAD
=
acute
RfD
FQPA
SF
=
0.005
mg/
kg/
day
Acute
Neurotoxicity
Study
­
Rat
LOAEL
=
150
mg/
kg/
day
based
on
FOB
effects
(
lethargy,
lower
temperature,
reduced
startle
response,
no
tail
pinch
response),
reduced
motor
activity,
and
reduced
brain
weights
Chronic
Dietary
(
All
populations)
NOAEL=
1.5
mg/
kg/
day
UF
=
1000
Chronic
RfD
=
0.0015
mg/
kg/
day
FQPA
SF
=
1
cPAD
=
chronic
RfD
FQPA
SF
=
0.0015
mg/
kg/
day
Combined
Chronic
Toxicity/
Carcinogenicity
Study
­
RAT
&
Chronic
Oral
Toxicity
Study
­
DOG
LOAEL
=
7.3
based
on
changes
in
hematology,
clinical
chemistry
,
incidences
of
bile
duct
hyperplasia,
and
reduction
in
mean
body
weight
gain
seen
at
7.9
mg/
kg/
day
in
conjunction
with
elevated
cholesterol
levels
and
increased
liver
weights
reported
in
the
Chronic
Oral
Toxicity
Study
in
Dogs
at
2.6
mg/
kg/
day
Short­
Term
Incidental
Oral
(
1­
30
days)
NOAEL=
1.5
mg/
kg/
day
Residential
LOC
for
MOE
=
1000
Occupational
=
NA
Multigeneration
Reproduction
Toxicity
Study
and
Combined
Chronic
Toxicity/
Carcinogenicity
Study
­
RAT
&
Chronic
Oral
Toxicity
Study
­
DOG
LOAEL
=
4.7
mg/
kg/
day
based
on
decreased
pup
weight/
pup
weight
gain.

Intermediate­
Term
Incidental
Oral
(
1­
6
months)
NOAEL=
1.5
mg/
kg/
day
Residential
LOC
for
MOE
=
1000
Occupational
=
NA
Multigeneration
Reproduction
Toxicity
Study
and
Combined
Chronic
Toxicity/
Carcinogenicity
Study
­
RAT
&
Chronic
Oral
Toxicity
Study
­
DOG
LOAEL
=
4.7
mg/
kg/
day
based
on
decreased
pup
weight/
pup
weight
gain.

Short­
Term
Dermal
(
1
to
30
days)
Dermal
(
or
oral)
study
NOAEL=
300
mg/
kg/
day
Residential
LOC
for
MOE
=
1000
Occupational
LOC
for
MOE
=
100
21­
Day
Dermal
Toxicity/
Rabbit
LOAEL
=
1000
mg/
kg/
day
based
on
decreases
in
body
weight
and
food
consumption
as
well
as
alterations
in
clinical
chemistry.
Exposure
Scenario
Dose
Used
in
Risk
Assessment,
UF
Special
FQPA
Safety
Factor*
and
Level
of
Concern
for
Risk
Assessment
Study
and
Toxicological
Effects
18
Intermediate­
Term
Dermal
(
1
to
6
months)
Dermal
(
or
oral)
study
NOAEL=
300
mg/
kg/
day
Residential
LOC
for
MOE
=
1000
Occupational
LOC
for
MOE
=
100
21­
Day
Dermal
Toxicity/
Rabbit
LOAEL
=
1000
mg/
kg/
day
based
on
decreases
in
body
weight
and
food
consumption
as
well
as
alterations
in
clinical
chemistry.

Long­
Term
Dermal
(>
6
months)
Dermal
(
or
oral)
study
NOAEL=
1.5
mg/
kg/
day
(
dermal
absorption
rate
=
1%
when
appropriate)
Residential
LOC
for
MOE
=
1000
Occupational
LOC
for
MOE
=
100
Combined
Chronic
Toxicity/
Carcinogenicity
Study
­
RAT
&
Chronic
Oral
Toxicity
Study
­
DOG
LOAEL
=
7.3
based
on
changes
in
hematology,
clinical
chemistry
,
incidences
of
bile
duct
hyperplasia,
and
reduction
in
mean
body
weight
gain
seen
at
7.9
mg/
kg/
day
in
conjunction
with
elevated
cholesterol
levels
and
increased
liver
weights
reported
in
the
Chronic
Oral
Toxicity
Study
in
Dogs
at
2.6
mg/
kg/
day
Inhalation
(
All
durations)
Inhalation
(
or
oral)
study
NOAEL=
1.5
mg/
kg/
day
(
inhalation
absorption
rate
=
100%)
Residential
LOC
for
MOE
=
1000
Occupational
LOC
for
MOE
=
100
Combined
Chronic
Toxicity/
Carcinogenicity
Study
­
RAT
&
Chronic
Oral
Toxicity
Study
­
DOG
LOAEL
=
7.3
based
on
changes
in
hematology,
clinical
chemistry
,
incidences
of
bile
duct
hyperplasia,
and
reduction
in
mean
body
weight
gain
seen
at
7.9
mg/
kg/
day
in
conjunction
with
elevated
cholesterol
levels
and
increased
liver
weights
reported
in
the
Chronic
Oral
Toxicity
Study
in
Dogs
at
2.6
mg/
kg/
day.

Cancer
(
oral,
dermal,
inhalation)
NOT
LIKELY
TO
BE
CARCINOGENIC
TO
HUMANS
*
A
database
uncertainty
factor
of
10X
was
applied
in
addition
to
the
usual
inter­
and
intraspecies
safety
factor.
UF
=
uncertainty
factor,
FQPA
SF
=
Special
FQPA
safety
factor,
NOAEL
=
no
observed
adverse
effect
level,
LOAEL
=
lowest
observed
adverse
effect
level,
PAD
=
population
adjusted
dose
(
a
=
acute,
c
=
chronic)
RfD
=
reference
dose,
MOE
=
margin
of
exposure,
LOC
=
level
of
concern,
NA
=
Not
Applicable
4.0
DIETARY
EXPOSURE
AND
RISK
ASSESSMENT
4.1
Summary
of
Registered
Uses
Thiram
[
tetramethyl
thiuram
disulfide]
is
a
fungicide
registered
for
foliar
treatments
of
apples,
peaches,
and
strawberries
and
for
seed
treatment
prior
to
planting
of
numerous
vegetable
and
field
crops.
Foliar
treatments
with
thiram
on
apples,
peaches,
and
strawberries
are
the
only
food/
feed
uses
being
supported
for
reregistration.
Seed
treatment
uses
of
thiram
have
been
determined
to
be
a
nonfood
use
based
on
metabolism
19
studies
reflecting
this
type
of
treatment
on
three
diverse
crop
groups.

The
reregistration
of
thiram
is
being
supported
by
the
Thiram
Task
Force,
with
members
consisting
of
Gustafson,
Inc.,
Prochimie,
and
UCB
Chemicals
Corporation.
The
Task
Force
intends
to
support
seed
treatment
uses
only.
UCB
Chemical
Corporation
intends
to
support
foliar
uses
on
apples,
peaches,
and
strawberries.
Thiram
formulations
registered
to
UCB
Chemicals
for
foliar
treatments
include
the
dry
flowable
(
DF)
and
wettable
powder
(
WP).
Thiram
formulations
registered
to
the
Thiram
Task
Force
for
seed
treatments
include
dust
(
D),
wettable
powder/
dust
(
WP/
D),
dry
flowable
(
DF),
flowable
concentrate
(
FlC),
soluble
concentrate
(
SC),
and
liquid
ready
to
use
(
RTU).

4.2
Dietary
Exposure
Tolerances
for
residues
in/
on
food
and
feed
commodities
are
currently
expressed
in
terms
of
residues
of
thiram
(
tetramethyl
thiuram
disulfide)
per
se
[
CFR
§
180.132]
and
are
established
at
7
ppm
for
apples,
strawberries,
and
peaches
(
the
only
feed/
food
crops
being
supported
for
reregistration).
There
are
no
established
or
proposed
Codex
MRLs
for
thiram
residues;
therefore,
there
are
no
issues
of
compatibility
with
respect
to
current
U.
S.
tolerances
and
Codex
MRLs.
Tolerances
have
been
reassessed
for
the
HED
Chapter
of
the
RED.
Adequate
residue
data
have
been
submitted
and
evaluated
to
support
the
proposed
uses
of
thiram
on
apples
and
strawberries,
and
no
additional
field
trials
are
required
for
reregistration.
The
residue
data
suggest
that
a
higher
tolerance
for
residues
of
thiram
in/
on
apples
and
strawberries
may
be
required
for
reregistration.
The
available
data
indicate
that
a
tolerance
of
9
ppm
would
be
adequate.

For
apples,
the
product
label
for
the
65%
WP
formulation
(
EPA
Reg.
No.
45728­
24)
must
be
modified
to
specify
PHIs
of
14
and
7
days
for
apples
grown
East
and
West
of
the
Rockies,
respectively.
In
the
case
of
strawberries,
there
are
discrepancies
that
must
be
clarified.
The
proposed
65%
WP
label
shows
a
rate
that
is
exclusive
to
Santa
Maria
and
Fallbrook
counties;
however,
our
research
has
found
that
these
are
cities,
not
counties
in
California
(
Santa
Barbara
and
San
Diego
counties,
respectively).
Additionally,
the
registrant
must
submit
additional
data
to
support
their
claim
that
there
is
no
accumulation
of
residues
between
crop
cycles.
Finally,
the
available
residue
data
for
peaches
are
inadequate
to
satisfy
reregistration
requirements
because
of
insufficient
geographic
representation.
Three
additional
field
trials
are
required,
and
these
trials
must
be
conducted
in
Regions
2
(
1
trials)
and
10
(
2
trials).
The
required
trials
should
depict
residues
of
thiram
in/
on
peaches
according
to
the
maximum
use
pattern
being
considered
for
reregistration.

Residue
analytical
methods
for
the
determination
of
thiram
residues
of
concern
in
animal
commodities
are
not
available
because
tolerances
for
animal
commodities
have
not
been
established.
If
the
requested
ruminant
feeding
study
suggests
that
tolerances
in
milk
and
edible
tissues
of
ruminants
are
needed
(
due
to
the
feeding
of
apple
pomace),
the
registrant
will
be
required
to
develop
enforcement
and
data­
collection
methods
capable
of
determining
thiram
residues
of
concern.
20
The
Agency
has
issued
several
documents
summarizing
the
status
of
available
thiram
residue
chemistry
data
for
the
purpose
of
reregistration.
They
include
the
Reregistration
Standard
Guidance
Document
dated
6/
29/
84,
the
Residue
Chemistry
Science
Chapter
of
the
Guidance
Document
dated
3/
2/
84,
and
the
Update
to
the
Residue
Chemistry
Chapter
21
of
the
Thiram
Reregistration
Standard
dated
7/
25/
91.
These
documents
summarized
the
regulatory
conclusions
based
on
available
residue
chemistry
data,
and
specified
the
additional
data
required
for
reregistration.
Several
data
submissions
have
been
received
and
evaluated
since
the
Update;
a
few
submissions
are
still
under
review
by
the
Agency.
Although
the
qualitative
nature
of
the
residue
in
plants
and
animals
remains
inadequately
understood,
HED
has
no
objection
to
proceeding
with
the
subject
Thiram
RED
and
with
risk
assessments
given
that
the
current
common
moiety
plant
method
would
likely
include
the
residues
of
toxicological
concern.
Though
the
currently
available
methodology
cannot
detect
thiram­
specific
metabolites,
it
does
detect
CS
2,
­
a
common
metabolite
for
thiram
and
other
dithiocarbamates.
As
a
result,
the
dietary
risk
estimates
are
considered
conservative
since
they
may
include
CS
2
from
chemicals
or
sources
other
than
thiram.

The
Pesticide
Analytical
Manual
(
PAM)
Vol.
II
lists
a
colorimetric
method
for
plant
commodities
(
Method
I)
and
additional
methods
(
Methods
II­
IV
and
Method
A
for
dithiocarbamates)
based
on
the
decomposition
of
dithiocarbamates
with
release
of
carbon
disulfide
and
the
corresponding
amine.
Consequently,
there
are
no
FDA
or
PDP
monitoring
data
available
for
thiram.
Field
trial
data
are
available
on
all
crops.
Therefore,
field
trial
data
were
used
to
calculate
the
anticipated
residue
(
AR)
values
for
refinement
of
dietary
exposure
scenarios.
Still,
the
dietary
analyses
conducted
for
thiram
are
considered
to
be
conservative.
These
assessments
were
conducted
based
solely
on
field
trial
data
and
could
be
substantially
refined
if
monitoring
data
were
available.
Some
refinement
was
accomplished
by
the
submission
of
strawberry
washing
and
apple
processing/
washing
studies.

OPP's
Biological
and
Economic
Analysis
Division
(
BEAD)
provided
information
(
F.
Hernandez
memorandum,
10/
15/
02)
on
the
percent
of
crop
treated
(%
CT).
For
the
chronic
analysis,
the
weighted
average
%
CT
was
incorporated;
for
the
acute
analysis,
the
estimated
maximum
%
CT
was
used.
In
acute
analyses
the
adjustment
for
%
CT
is
incorporated
in
the
residue
distribution
files
(
RDFs)
via
addition
of
zero
residue
values
corresponding
to
the
%
crop
not
treated.
For
blended
commodities,
the
%
CT
is
incorporated
into
an
average
residue
value.
For
the
chronic
analyses,
%
CT
is
entered
as
adjustment
factor
#
2
in
DEEM­
FCID
 
.

HED
conducts
dietary
risk
assessments
using
the
Dietary
Exposure
Evaluation
Model
(
DEEM­
FCID
 
)
Software,
which
incorporates
consumption
data
generated
in
USDA's
Continuing
Surveys
of
Food
Intakes
by
Individuals
(
CSFII),
1994­
1996
and
1998.
For
acute
dietary
risk
assessments,
the
entire
distribution
of
consumption
events
for
individuals
is
multiplied
by
a
distribution
of
residues
(
probabilistic
analysis,
referred
to
as
"
Monte
Carlo"
)
to
obtain
a
distribution
of
exposures
in
mg/
kg/
day.
For
chronic
dietary
risk
assessments,
the
three­
day
average
of
consumption
for
each
sub­
population
is
combined
with
average
residues
in
commodities
to
determine
average
exposures
in
mg/
kg/
day.
All
commodities
(
strawberries,
peaches,
apples)
are
considered
high
consumption
food
items
for
infants
and
children.
There
are
no
established
or
proposed
Codex
MRLs
for
thiram
residues;
therefore,
there
are
no
issues
of
compatibility
with
22
respect
to
current
U.
S.
tolerances
and
Codex
MRLs.

For
the
probabilistic
acute
dietary
exposure
analysis,
the
entire
distribution
of
field
trial
data
was
used
to
generate
residue
distribution
files
(
RDFs)
for
commodities
that
are
considered
to
be
not
blended
or
partially
blended.
For
blended
commodities,
the
average
field
trial
residues
incorporating
the
likely
maximum
%
CT
were
used
as
point
estimates.
Chronic
anticipated
residues
(
ARs)
were
also
calculated
from
field
trial
data.
An
average
of
the
field
trial
residues
was
used.

Detailed
information
regarding
how
the
ARs
were
calculated
can
be
found
in
the
F.
Fort
memorandum
dated
4/
17/
00
(
Appendix
III).
The
details
of
the
DEEM­
FCIDTM
analyses
can
be
found
in
the
F.
Fort
memorandum
dated
4/
30/
03
(
IX).

4.2.1
Acute
Dietary
Exposure
Assessment.

The
refined
(
Tier
3)
acute
probabilistic
dietary
exposure
and
risk
estimates
at
the
99.9th
percentile
of
exposure
are
of
concern
for
the
general
U.
S.
population
(
380%
of
the
aPAD)
and
all
population
subgroups.
The
acute
dietary
exposure
estimate
for
children
1­
2
years
old,
the
highest
exposed
population
subgroup,
is
1005%
of
the
aPAD
at
the
99.9th
percentile.
(
Table
3).
Additional
analyses
were
conducted
to
determine
the
contribution
of
each
commodity
to
the
dietary
risk.
These
sensitivity
analyses
indicate
that
both
strawberries
(
uncooked)
and
apples
(
uncooked)
are
significant
contributors
to
the
dietary
risk
for
children
1
­
2
years
old
(
Table
5).

Table
3.
Results
of
Acute
Dietary
Exposure
Analysis
Population
Subgroup
aPAD
(
mg/
kg/
day)
95th
Percentile
99th
Percentile
99.9th
Percentile
Exposure
(
mg/
kg/
day)
%
aPAD
Exposure
(
mg/
kg/
day)
%
aPAD
Exposure
(
mg/
kg/
day)
%
aPAD
General
U.
S.
Population
0.005
0.000339
7
0.004210
84
0.019022
380
All
Infants
(<
1
year
old)
0.005
0.000060
1
0.004246
85
0.021088
420
Children
1­
2
years
old
0.005
0.001310
26
0.016274
330
0.050268
1000
Children
3­
5
years
old
0.005
0.001134
23
0.012079
240
0.043316
870
Children
6­
12
years
old
0.005
0.000584
12
0.007214
140
0.030360
610
Youth
13­
19
years
old
0.005
0.000173
3
0.003464
69
0.013902
280
Adults
20­
49
years
old
0.005
0.000150
3
0.003120
62
0.012330
250
Females
13­
49
years
old
0.005
0.000193
4
0.003776
76
0.014078
280
Adults
50+
years
old
0.005
0.000415
8
0003583.
72
0.011278
230
4.2.2
Chronic
Dietary
Exposure
Assessment
23
Estimated
chronic
dietary
exposure
and
risk
are
below
the
Agency's
level
of
concern,
with

28%
of
the
chronic
Population
Adjusted
Dose
(
cPAD)
consumed
for
all
population
subgroups.
The
most
highly
exposed
population
subgroup
was
children
1­
2
years
old,
with
28
%
cPAD
consumed.
Exposure
to
the
U.
S.
General
Population
was
8%
cPAD
(
Table
4).

Table
4.
Results
of
Chronic
Dietary
Exposure
Analysis
Population
Subgroup
cPAD
(
mg/
kg/
day)
Exposure
(
mg/
kg/
day)
%
cPAD
General
U.
S.
Population
0.0015
0.000121
8
All
Infants
(<
1
year
old)
0.0015
0.000102
7
Children
1­
2
years
old
0.0015
0.000422
28
Children
3­
5
years
old
0.0015
0.000336
22
Children
6­
12
years
old
0.0015
0.000205
14
Youth
13­
19
years
old
0.0015
0.000087
6
Adults
20­
49
years
old
0.0015
0.000079
5
Females
13­
49
years
old
0.0015
0.000095
6
Adults
50+
years
old
0.0015
0.000099
7
The
dietary
analyses
conducted
for
thiram
are
considered
to
be
conservative.
These
assessments
were
conducted
based
solely
on
field
trial
data
and
could
be
substantially
refined
if
monitoring
data
were
available.
24
Table
5.
Acute
Sensitivity
Analyses
(
99.9%
ile)

Population
Subgroup
All
commodities
Excluding
Apple
(
Strawberries
and
Peaches
Only)
Excluding
Strawberry
(
Apples
and
Peaches
Only)
Excluding
Apple
and
Strawberries
(
Peaches
Only)
Excluding
Apples
and
Peaches
(
Strawberries
Only)
Excluding
Strawberries
and
Peaches
(
Apples
Only)

Dietary
Exposure
(
mg/
kg/
day)
%
aPAD
Dietary
Exposure
(
mg/
kg/
day)
%
aPAD
Dietary
Exposure
(
mg/
kg/
day)
%
aPAD
Dietary
Exposure
(
mg/
kg/
day)
%
aPAD
Dietary
Exposure
(
mg/
kg/
day)
%
aPAD
Dietary
Exposure
(
mg/
kg/
day)
%
aPAD
General
U.
S.

Population
0.019022
380
0.014792
296
0.011123
222
0.000063
1
0.014626
292
0.010841
217
All
Infants
(<
1
year
old)
0.021088
422
0.008407
168
0.019577
392
0.001280
26
0.007302
146
0.019630
393
Children
1­
2
years
old
0.050268
1005
0.041105
822
0.036368
727
0.000621
12
0.040380
808
0.036228
725
Children
3­
5
years
old
0.043316
866
0.030811
616
0.033877
678
0.000238
5
0.030420
608
0.033545
671
Children
6­
12
years
old
0.030360
607
0.024356
487
0.018807
376
0.000129
3
0.024158
483
0.018479
370
Youth
13­
19
years
old
0.013902
278
0.011049
221
0.007772
155
0.000014
<
1
0.011196
224
0.007248
145
Adults
20­
49
years
old
0.012330
246
0.010700
214
0.007033
141
0.000014
<
1
0.010573
211
0.006827
137
Females
13­
49
years
old
0.014078
282
0.012392
248
0.007768
155
0.000035
<
1
0.012238
245
0.007520
150
Adults
50+
years
old
0.011278
226
0.009207
184
0.007673
153
0.000118
2
0.009135
182
0.007470
149
25
26
4.3
Drinking
Water
Sources
of
Dietary
Exposure
The
Environmental
Fate
and
Ecological
Effects
Division
(
EFED)
has
performed
modeling
to
assess
thiram
estimated
environmental
concentrations
(
EECs)
in
surface
water
and
groundwater.
Tier
II
surface
water
EECs
for
thiram
were
calculated
using
PRZM/
EXAMS
(
surface
water)
and
SCIGROW
(
ground
water)
for
apples,
turf,
golf
courses,
and
cottonseed.
PRZM/
EXAMS
scenarios
were
run
using
the
Index
Reservoir
(
IR)
scenario
and
a
Percent
Crop
Area
(
PCA)
adjustment
to
generate
surface
water
EECs.

Hydrolysis,
photodegradation,
and
aerobic
soil
metabolism
are
the
main
degradative
processes
for
thiram.
Observed
half­
lives
are
generally
less
than
18
days
under
the
nominal
or
expected
use
conditions,
producing
the
volatile
degradates
COS
and
CS
2
(
carbon
disulfide)
from
hydrolysis
and
photodegradation,
and
CO
2
(
carbon
dioxide)
from
aerobic
metabolism.
Nonvolatile
degradates
are
formed
at
less
than
10%
of
the
applied.

Based
on
supplemental
information,
the
hydrolysis
half­
life
for
thiram
(
MRID
41840601)
was
68.5
days
in
pH
5
buffer,
3.5
days
in
pH
7
buffer,
and
6.9
hours
in
pH
9
buffer,
and
the
aqueous
photolysis
half­
life
(
MRID
41753801)
was
10.4
hours
in
pH
5
buffer
(
no
degradation
was
observed
in
dark
controls).

Thiram
residues
appear
to
have
low
mobility
in
the
environment.
In
a
supplemental
laboratory
study
(
MRID
43787501),
thiram,
at
concentrations
of
0.01,
0.04,
0.20,
and
1.07
mg/
L,
was
determined
to
be
essentially
immobile
in
sandy
loam
and
silt
loam
soils,
and
to
have
low
mobility
in
loam
and
loamy
sand
soils
that
were
equilibrated
for
4
hours
at
20
oC
(
a
4
hour
equilibration
period
was
first
determined
to
be
adequate).
Freundlich
K
ads
values
were
54
for
the
sandy
loam
soil
(
pH=
6.7),
150
for
the
loamy
sand
soil
(
pH=
4.8),
67
for
the
silt
loam
soil
(
pH=
6.7),
and
263
for
the
loam
soil
(
pH=
7.3);
corresponding
K
oc
values
were
2245,
24526,
6359,
and
12899
mL/
g.
Respective
1/
N
values
were
1.04,
1.15,
1.10,
and
1.13
for
adsorption.
The
degree
of
sorption
of
thiram
to
these
soils
was
found
not
to
be
a
function
of
the
amount
of
organic
matter
present.

Surface
and
Groundwater
Monitoring
Data
At
this
time,
there
are
limited
monitoring
data
available
for
thiram
in
either
ground
or
surface
water,
with
no
reported
detections.
The
Pesticides
in
Ground
Water
Database
(
1991)
contains
no
records
for
thiram;
STORET
contains
no
detections
of
thiram.
No
detections
of
thiram
have
been
reported
to
the
Agency
under
6(
a)
2.
The
US
Geological
Survey
National
Water
Quality
Assessment
program
(
NAWQA)
is
not
currently
analyzing
for
thiram
in
their
samples,
and
they
do
not
have
analytical
methods
in
place
for
this
chemical.

Groundwater
Groundwater
calculations
for
thiram
were
based
on
the
SCI­
GROW
model
(
Screening
Concentrations
in
Ground
Water,
version
dated
11/
12/
97),
which
is
a
model
for
estimating
concentrations
of
pesticides
in
groundwater
under
conditions
of
maximum
exposure.
27
SCI­
GROW
provides
a
screening
concentration
or
an
estimate
of
likely
ground
water
concentration
if
the
pesticide
is
used
at
the
maximum
allowed
label
rate
in
areas
with
ground
water
that
is
exceptionally
vulnerable
to
contamination.
In
most
cases,
a
majority
of
the
use
area
will
have
ground
water
that
is
less
vulnerable
to
contamination
than
the
areas
used
to
derive
the
SCI­
GROW
estimate.

The
SCI­
GROW
model
is
based
on
normalized
ground
water
concentrations
from
ground
water
monitoring
studies,
environmental
fate
properties
(
aerobic
soil
half­
lives
and
organic
carbon
partitioning
coefficients­
K
oc's)
and
application
rates.
The
model
is
based
on
permeable
soils
that
are
vulnerable
to
leaching
and
that
overlie
shallow
ground
water
(
10­
30
feet).
Based
on
the
information
provided
by
the
groundwater
monitoring
studies,
the
model
has
a
lower
limit
of
reliability
of
0.006

g/
mL.
Refer
to
Table
6
for
thiram
EECs
used
for
dietary
risk
assessment
purposes.

Surface
Water
Tier
II
surface
water
EECs
were
generated
using
PRZM/
EXAMS.
EECs
are
presented
in
Table
6.
A
Tier
II
EEC
for
a
particular
crop
or
use
is
based
on
a
single
site
that
represents
a
high
exposure
scenario
for
the
crop
or
use.
Weather
and
agricultural
practices
are
simulated
at
the
site
for
36
years
to
estimate
the
probability
of
exceeding
a
given
concentration
(
maximum
concentration
or
average
concentration)
in
a
single
year.
Maximum
EECs
are
calculated
so
that
there
is
a
10%
probability
that
the
maximum
concentration
in
a
given
year
will
exceed
the
EEC
at
the
site;
peak
and
chronic
EECs
were
calculated
so
that
there
is
a
10%
probability
that
the
maximum
average
concentration
for
a
given
duration
(
4­
day,
21­
day,
etc.)
will
equal
or
exceed
the
EEC
at
the
site.
This
can
also
be
expressed
as
an
expectation
that
water
concentrations
will
exceed
EECs
once
every
10
years.

Table
6.
EECs
for
use
in
the
human
health
risk
assessment
Crop
Annual
App
Rate
(
lbs
ai/
acre/
yr)
SCIGROW
concentration
(
ppb)
PRZM/
EXAM
S*
Acute
EEC
(
ppb)
PRZM/
EXAMS*
non­
cancer
chronic
EEC
(
ppb)
PRZM/
EXAMS*
cancer
chronic
EEC
(
ppb)

Turf
farm
146.6
0.84
47.8
2.5
2.2
Golf
course
146.6
0.84
14.8
0.78
0.67
Apples
22.5
0.13
16.3
1.2
1.1
Cotton
seed
0.01
0.00006
0.006
0.0002
0.00007
*
Index
Reservoir
environment
For
further
details,
refer
to
the
Environmental
Fate
and
Ecological
Effects
Assessment
and
Characterization
Chapter
for
the
Thiram
Reregistration
Eligibility
Decision
Document
(
J.
Carleton
and
F.
Jenkins
memorandum;
12/
11/
03).

5.0
Occupational/
Residential
Exposure
and
Risk
The
Occupational
and
Residential
Exposure
Assessment
(
D289601)
was
prepared
by
Jeff
Dawson.
28
The
document
D289601
contains
detailed
descriptions
of
the
data
used,
methods,
and
risks
calculated
for
each
scenario.
Please
refer
to
that
document
for
more
specific
information.

There
are
registered,
supported
products
of
thiram
intended
for
both
occupational
and
nonoccupational
site
applications.
The
major
uses
include
thiram
applications
to
seeds,
terrestrial
food
and
feed
crops,
terrestrial
non­
food
crops,
nursery/
greenhouse
crops,
field­
grown/
residential­
grown
ornamentals
(
i.
e.,
trees,
shrubs,
vines),
and
commercial
turfgrass
(
i.
e.,
sod
farms,
golf
courses,
schools,
parks,
athletic
fields,
and
rights­
of­
way).
Thiram
is
registered
for
foliar
application
on
the
following
crops:
apples,
peaches,
and
strawberries.
According
to
the
Thiram
Use
Closure
Memo,
thiram
may
be
applied
to
residential
ornamentals
(
i.
e.,
trees,
shrubs,
vines)
by
professional
pesticide
applicators
only
and
will
no
longer
be
available
as
residential
products
for
application
by
private
homeowners.
In
addition,
seeds
treated
with
thiram
will
not
be
available
for
purchase
by
private
homeowners.

Thiram
is
applied
as
a
seed
treatment
to:
small
seeded
vegetables
(
e.
g.
broccoli,
carrots,
lettuce,
peppers,
etc.),
large
seeded
vegetables
(
e.
g.
beans,
cantaloupe,
corn,
cucumbers,
peas,
etc.),
cereal
grains
(
barley,
oats,
rice,
rye,
and
wheat),
other
seeds
(
including
beets,
peanuts,
sesame,
sorghum,
sunflower,
etc),
coniferous
seeds,
cotton
seed,
ornamental
seeds
(
gladiolus
bulbs,
ornamental
flowers,
ornamental
bulbs
and
tubers,
etc.),
and
soybeans.

EPA
estimates
that
the
total
annual
domestic
usage
for
foliar
applications
of
thiram
is
approximately
200,000
pounds
active
ingredient
(
ai)
for
about
50,000
acres
treated.
Thiram
has
its
largest
foliar
markets,
in
terms
of
total
pounds
active
ingredient,
allocated
to
strawberries
(
65%),
apples
(
20%),
and
peaches
(
3%).
The
Thiram
Task
Force
II
consortium
reports
that
approximately
1.3
billion
pounds
of
seed
were
treated
with
thiram
in
the
U.
S.
in
1998
for
both
domestic
and
export
use.
Approximately
600,000
pounds
active
ingredient
of
thiram
were
used
to
treat
the
approximate
1.3
billion
pounds
of
seed.
It
is
estimated
that
approximately
29
million
acres
are
planted
annually
in
the
U.
S.
with
thiramtreated
seed
and
that
approximately
16%
of
overall
acreage
planted
in
the
U.
S.
use
seeds
treated
with
thiram.

There
are
numerous
methods
for
occupational
applications
of
thiram
products.
Occupational
applications
to
apples,
peaches
and/
or
strawberries
can
be
made
by
the
following
methods:
aerial,
airblast
sprayer,
groundboom
(
only
strawberries),
high
pressure
handwand,
and
low
pressure
handwand.
Commercial
turfgrass
(
e.
g.,
sod
farms,
golf
courses,
parks
and
athletic
fields)
may
be
treated
by
the
following
methods:
aerial,
backpack
sprayer,
groundboom,
high
pressure
handwand,
low
pressure
handwand,
push­
type
granular
spreader,
and
tractor­
drawn
drop­
type
spreader.
Seeds
may
be
treated
by
numerous
methods
which
include:
by
hand,
concrete
tumbler
(
conifer
seeds),
drill
box,
duster,
in­
furrow
application,
mist­
type
seed
treater,
paper
bag,
planter
box,
seed
box,
shaker
can,
and
slurry­
type
seed
treater.
Ornamental
bulbs
may
be
treated
by
dip
tank
application,
drill
box,
duster,
and
paper
bag.
Finally,
animal
repellency
treatment
of
golf
courses,
rights­
of­
way,
residential
sites,
parks
and
athletic
fields
may
be
performed
by
backpack
sprayer,
low
pressure
handwand,
high
pressure
handwand,
handgun,
rights­
of­
way
sprayer,
paintbrush,
and
sprinkler
can.

5.1
Non­
Occupational
(
Residential
and
Recreational)
Risk
Assessments
As
indicated
in
the
Thiram
Use
Closure
Memo
(
K.
Rothwell
memorandum;
3/
20/
00),
private
29
homeowners
will
no
longer
be
permitted
to
purchase
and
apply
thiram
products
in
the
residential
environment.
However,
professional
pesticide
applicators
may
continue
to
make
thiram
applications
in
the
residential
environment
for
animal
repellency
and
in
recreational
environments
(
e.
g.,
golf
courses,
parks,
athletic
fields)
on
turfgrass
and
for
animal
repellency.
As
a
result,
the
public
may
still
be
exposed
to
thiram
following
application
of
thiram
products
in
residential
and
recreational
environments.

5.1.1
Residential
Postapplication
Risk
Assessment
Thiram
uses
that
are
believed
to
contribute
to
residential
exposures
are
limited
in
nature.
Products
are
not
available
for
sale
to
or
use
by
homeowners
but
there
can
be
uses
on
turf
in
parks,
golf
courses,
and
athletic
fields
where
exposures
can
occur.
In
order
to
complete
a
comprehensive
assessment,
the
Agency
considered
individuals
of
varying
ages
and
how
they
can
potentially
be
exposed
when
they
do
activities
in
areas
that
have
been
previously
treated.
The
residential
postapplication
risk
assessment
addresses
these
types
of
exposures.

The
risks
from
postapplication
exposure
to
thiram
residues
were
determined
for
the
following
populations:


Residential
(
homeowner)
Adults:
these
individuals
are
members
of
the
general
population
that
are
exposed
to
chemicals
by
engaging
in
activities
in
areas
previously
treated
with
a
pesticide
(
e.
g.,
golf
courses
or
parks
for
thiram).
These
kinds
of
exposures
are
attributable
to
a
variety
of
activities
and
usually
addressed
by
the
Agency
in
risk
assessments
by
considering
a
representative
activity
as
the
basis
for
the
exposure
calculation.
In
this
case,
golfing
is
the
predominant
activity
considered
by
the
Agency.


Residential
Children:
children
are
members
of
the
general
population
that
can
also
be
exposed
from
their
presence
in
areas
previously
treated
with
a
pesticide
(
e.
g.,
playing
on
grass
in
parks).
Toddlers
have
been
selected
as
a
sentinel
(
or
representative)
population
for
evaluating
the
risks
from
the
turf
uses
of
thiram.
Children
are
addressed
by
the
Agency
in
risk
assessments
by
considering
a
representative
activity
in
an
exposure
calculation
(
e.
g.,
for
toddlers
on
turf,
an
intense
contact
play
activity
is
the
basis
for
the
assessment).

Data
and
Assumptions:
A
series
of
data,
assumptions,
and
exposure
factors
served
as
the
basis
for
completing
the
residential
handler
risk
assessments,
as
described
below.
The
assumptions
and
factors
used
in
the
risk
calculations
are
consistent
with
current
Agency
policy
for
completing
residential
exposure
assessments
(
i.
e.,
SOPs
For
Residential
Exposure
Assessment
and
related
documents).

°
The
only
thiram­
specific
data
that
were
used
by
the
Agency
in
this
assessment
were
the
dislodgeable
foliar
residue
data
from
strawberries
contained
in
MRID
30
455603­
01
that
was
conducted
in
California
and
Florida.
These
data
have
been
used
to
complete
the
residential
assessment
which
is
based
on
exposures
to
turf.
This
extrapolation
for
using
strawberry
data
for
turf
was
completed
because
these
data
were
the
only
available.
These
thiram
DFR
estimates
had
a
very
high
percent
transferability
so
use
of
the
data
would
actually
result
in
risks
that
are
extraordinarily
higher
than
would
occur
if
the
standard
Agency
method
was
used.
As
a
result,
the
Agency
only
used
the
decay
rates
from
the
study
and
coupled
this
with
initial
concentration
estimates
calculated
using
the
5
percent
of
the
application
rate
factor
for
the
dermal
and
hand­
to
mouth
assessments.
For
the
object
to
mouth
calculations,
the
data
were
directly
scaled
based
on
application
rate
because
the
sampling
method
is
believed
to
be
similar
to
the
types
of
extraction
associated
with
mouthing.


The
Agency
combines
or
aggregates
risks
resulting
from
exposures
to
individual
chemicals
when
it
is
likely
they
can
occur
simultaneously
based
on
the
use
pattern
and
the
behavior
associated
with
the
exposed
population.
Within
a
residential
assessment,
this
can
take
two
forms.
The
first
is
to
add
together
risks
for
individual
exposure
scenarios
from
all
likely
sources
of
exposure
such
as
after
an
application
to
turf.
For
thiram,
the
Agency
has
added
together
risk
values
(
i.
e.,
MOEs)
for
different
kinds
of
toddler
exposures
from
treated
turf
(
dermal,
hand­
to­
mouth,
object­
to­
mouth,
and
soil
ingestion).
These
represent
the
standard
set
of
exposures
that
are
typically
added
together
when
chemicals
are
used
on
turf
because
it
is
logical
they
can
co­
occur.
For
adults,
only
dermal
exposures
were
considered
from
golfing.
The
second
would
be
to
potentially
add
handler
and
postapplication
risks
together
but
the
Agency
typically
does
not
do
this
because
of
low
likelihoods
of
co­
occurrence.
Additionally,
for
thiram
it
would
be
inappropriate
because
there
are
no
labeled
homeowner
handler
uses.


Exposures
to
children
playing
on
treated
turf
as
well
as
adults
on
turf
(
lawncare
and
golfing)
have
been
addressed
using
the
latest
Agency
approaches
for
this
scenario
including:

$
5
percent
of
the
application
rate
has
been
used
to
calculate
the
0­
day
TTR
(
turf
transferable
residue)
levels
which
were
used
for
calculating
dermal
and
hand­
tomouth
exposures,
this
approach
was
taken
rather
than
extrapolating
directly
from
the
strawberry
DFR
data
because
the
DFR
sampling
technique
is
thought
to
lead
to
a
gross
overestimate
of
exposure
when
coupled
with
the
transfer
coefficient;
the
decay
rate
from
the
strawberry
DFR
study
(
i.
e.,
the
slope
of
the
dissipation
curve)
was
used
to
estimate
residue
decline
over
time
rather
than
the
Agency
standard
value
of
10
percent/
day
which
would
be
used
in
lieu
of
data
because
it
provides
a
chemical­
specific
basis
for
this
factor;

$
20
percent
of
the
application
rate
is
normally
used
to
calculate
the
0­
day
residue
levels
for
assessing
object­
to­
mouth
behaviors,
however,
the
percent
dislodgability
of
thiram
observed
in
the
strawberry
DFR
study
was
much
higher
(
i.
e.,
~
35%)
so
the
Agency
used
the
day
0
DFR
concentrations
from
the
DFR
31
study
instead
and
extrapolated
the
value
based
on
application
rate
differences
to
define
0­
day
residue
concentrations;

$
the
transfer
coefficients
used,
except
golfing,
are
those
presented
at
the
1999
Agency
presentation
before
the
FIFRA
Science
Advisory
Panel
that
have
been
adopted
in
routine
practice
by
the
Agency;

$
adult
golfers
have
been
assessed
using
a
transfer
coefficient
of
500
cm2/
hour
[
Note:
The
Agency
is
currently
developing
a
policy
on
golfer
exposures
and
has
used
this
value
in
other
assessments];

$
3
year
old
toddlers
are
expected
to
weigh
15
kg;

$
hand­
to­
mouth
exposures
are
based
on
a
frequency
of
20
events/
hour
and
a
surface
area
per
event
of
20
cm2
representing
the
palmar
surfaces
of
three
fingers;

$
saliva
extraction
efficiency
is
50
percent
meaning
that
every
time
the
hand
goes
in
the
mouth
approximately
½
of
the
residues
on
the
hand
are
removed;

$
object­
to­
mouth
exposures
are
based
on
a
25
cm2
surface
area;

$
exposure
durations
are
expected
to
be
2
hours
based
on
information
in
the
Agency's
Exposure
Factors
Handbook
except
for
golfers
where
the
exposure
duration
for
an
18
hole
round
of
golf
is
4
hours
based
on
a
1992
report
(
Golf
Course
Operations,
Cost
of
Doing
Business/
Profitability
by
the
Center
For
Golf
Course
Management);

$
soil
residues
are
contained
in
the
top
centimeter
and
soil
density
is
0.67
mL/
gram;

$
dermal,
hand­
and
object­
to­
mouth,
and
soil
ingestion
are
added
together
to
represent
an
overall
risk
from
exposure
to
turf
while
granular
ingestion
is
considered
to
be
a
much
more
episodic
behavior
and
is
considered
separately
by
the
Agency;
and
$
children
of
various
ages
down
to
the
very
young
(
e.
g.,
4
or
5
years
old)
are
currently
playing
golf,
the
Agency
recognizes
that
age
may
impact
exposures
because
of
changes
in
behavior
and
skin
surface
area
to
body
weight
ratios
but
has
not
yet
developed
a
quantitative
approach
for
calculating
their
risks.


The
hazard
inputs
are
identical
for
both
short­
and
intermediate­
term
exposures
but
intermediate­
term
exposures,
in
comparison,
would
be
lower
than
the
32

corresponding
short­
term
estimates
because
they
would
be
amortized
over
time,
hence
the
Agency
has
completed
only
short­
term
calculations
for
the
scenarios
included
in
this
assessment
as
they
are
protective
for
that
duration
as
well
as
extended
periods
of
exposure.

The
Agency
calculated
short­
term
risk
estimates
for
thiram
and
did
not
calculate
intermediate­
term
risks
because
that
would
involve
an
additional
amortization
step
which
would
reduce
the
exposures
and
provide
lower
risk
estimates
which
is
counter
intuitive.
In
effect,
short­
term
estimates
for
thiram
are
protective
for
all
durations
of
exposure
that
would
be
anticipated
for
thiram.
Noncancer
risks
were
calculated
using
the
MOE
approach
which
is
essentially
a
ratio
of
the
NOAEL
compared
to
a
dose
estimate
for
a
particular
exposure
pattern.
MOEs
are
then
added
together
if
appropriate,
for
example,
for
children
playing
on
treated
turf
(
i.
e.,
dermal
and
mouthing
behaviors
would
be
added).
Risks
from
dermal
exposures
were
assessed
based
on
a
NOAEL
of
300
mg/
kg/
day
from
a
21­
day
dermal
rabbit
study
where
the
effects
seen
were
decreases
in
body
weight
and
food
consumption
as
well
as
alterations
in
clinical
chemistry.
Risks
from
the
mouthing
behaviors
of
children
were
also
assessed
based
on
similar
endpoints
which
were
defined
based
on
a
number
of
studies
(
i.
e.,
chronic
dog,
rat
repro.,
and
chronic
rat
studies
were
predominant)
with
a
NOAEL
of
1.5
mg/
kg/
day.
The
Agency
establishes
the
level
of
concern
for
these
calculations
through
uncertainty
factors
which
account
for
intra­
species
sensitivity
and
inter­
species
variability
(
i.
e.,
10x10
=
100).
The
FQPA
statute
also
requires
that
the
Agency
consider
special
sensitivities
of
various
populations
(
e.
g.,
infants
and
children)
through
the
application
of
an
additional
factor
which
was
retained
(
i.
e.,
FQPA
SF
=
10)
because
of
the
lack
of
a
developmental
neurotoxicity
study
making
the
overall
safety
factor
1000
for
residential
risks.
As
such,
MOEs
(
or
the
ratio
of
a
NOAEL
to
a
dose
for
a
particular
activity)
must
exceed
1000
for
the
Agency
not
to
have
a
risk
concern
for
the
particular
activity.

Several
different
types
of
calculations
were
used
in
this
assessment
to
reflect
the
varying
age
groups,
behaviors,
data,
and
activities
that
were
considered.
In
essence,
all
can
be
summarized
by
saying
that
a
source
of
some
sort
(
e.
g.,
turf
residues)
comes
in
contact
with
a
person
as
they
are
doing
an
activity
(
e.
g.,
kids
playing
or
golfers).
Exposures
were
then
calculated
by
multiplying
the
source
concentration
by
some
factor
(
e.
g.,
transfer
coefficient
for
golfing)
and
the
duration
of
time
people
are
engaged
in
that
activity.
All
of
the
calculations
are
explained
in
detail
in
the
Occupational
and
Residential
Exposure
Chapter
(
D289601).
Two
of
the
key
algorithms
are
presented
below
for
informational
purposes.
These
represent
the
predominant
types
of
exposures
considered
in
the
postapplication
assessment
(
i.
e.,
dermal
and
hand­
to­
mouth).

Dermal
exposures
were
calculated
by
considering
the
potential
sources
of
exposure
in
the
environment
(
i.
e.,
TTRs
on
turf)
using
the
following
equation.
It
should
also
be
noted
that
there
are
distinct
transfer
coefficients
for
different
activities
(
e.
g.,
kids
at
play
versus
golfing).
33
D

(
TR

(
SE/
100)

SA

Freq

Hr

(
1mg/
1000

g))
DE(
t)
(
mg/
day)
=
(
TR(
t)
(

g/
cm2)
x
TC
(
cm2/
hr)
x
Hr/
Day)/
1000
(

g/
mg)

Where:

DE(
t)
=
Daily
exposure
or
amount
deposited
on
the
surface
of
the
skin
at
time
(
t)
attributable
for
activity
in
a
previously
treated
area,
also
referred
to
as
potential
dose
(
mg
ai/
day);
TR(
t)
=
Transferable
residues,
in
this
case
turf
transferable
residues
at
time
(
t)
where
the
longest
duration
is
dictated
by
the
decay
time
observed
in
the
studies
(

g/
cm2);
TC
=
Transfer
Coefficient
(
cm2/
hour);
and
Hr/
day
=
Exposure
duration
meant
to
represent
a
typical
workday
(
hours).

Likewise,
nondietary
ingestion
from
hand­
to­
mouth
behaviors
also
consider
the
environmental
concentrations
and
the
mouthing
behaviors
of
children.
The
following
equation
describes
how
these
exposures
have
been
calculated.

Where:

D
=
Dose
from
hand­
to­
mouth
activity
(
mg/
day);
TR
=
Transferable
residues,
in
this
case
turf
transferable
residues
at
time
(
t)
where
the
longest
duration
is
dictated
by
the
decay
time
observed
in
the
studies
(

g/
cm2);
SE
=
Saliva
extraction
factor
(%);
SA
=
Surface
area
of
the
hands
(
cm2);
Freq
=
Frequency
of
hand­
to­
mouth
events
(
events/
hour);
and
Hr
=
Exposure
duration
(
hours).

Adult
MOEs
for
golfing
exceed
the
Agency's
level
of
concern
on
the
day
of
application
(
i.
e.,
764)
at
the
highest
application
rate
of
24.5
lb
ai/
A.
Risks
are
not
of
concern
3
days
after
the
application
(
i.
e.,
MOE
=
1043)
using
California
data
and
2
days
after
the
application
(
MOE
=
1029)
using
Florida
data.
If
the
application
rate
is
16.3
lb
ai/
A,
then
MOEs
exceed
the
Agency's
target
of
1000
on
the
day
of
application
(
MOE
=
1148).
These
results
should
be
put
in
context
in
that
the
approach
used
by
the
Agency
is
based
on
an
entire
course
being
treated
and
an
individual
being
exposed
on
the
day
of
application.
It
should
also
be
pointed
out
that
a
turf­
specific
residue
dissipation
study
was
not
available
and
that
the
Agency
used
strawberry
DFR
estimates
and
standard
inputs
to
complete
the
assessment.
Regional
impacts
where
small
but
did
allow
for
1
day
quicker
exceedence
of
the
Agency's
target
risk
level
based
on
Florida
data.
Table
7
presents
the
postapplication
MOE
values
calculated
for
adults
while
golfing
after
applications
of
thiram.
34
Table
7:
Summary
of
Thiram
Noncancer
Postapplication
Residential
MOEs
For
Adults
Scenario
Descriptor
Results
MOE
on
Day
0
Days
MOE

UF
Golfing
16.3
lb
ai/
A
­
California
Data
1148
0
24.5
lb
ai/
A
­
California
Data
764
3
16.3
lb
ai/
A
­
Florida
Data
1148
0
24.5
lb
ai/
A
­
Florida
Data
764
2
Toddler
(
3
year
old)
MOEs
were
calculated
for
toddlers
after
exposure
to
treated
turf.
Table
8
presents
a
summary
of
these
risk
estimates
based
using
both
California
and
Florida
data.
MOEs
from
exposure
to
treated
turf
were
<
1000
on
the
day
of
application
for
both
rates
considered
(
i.
e.,
16.3
and
24.5
lb
ai/
acre)
regardless
of
the
data
used
for
the
assessment
(
i.
e.,
California
or
Florida).
In
fact,
MOEs
from
individual
pathways
were
not

1000
for
any
turf
scenario
considered
on
the
day
of
application
except
for
the
soil
ingestion
component
of
the
turf
assessment
which
is
a
very
minor
contributor
to
overall
exposures.
As
a
reminder,
dermal,
hand­
to­
mouth,
and
object­
to­
mouth
exposure
pathways
were
also
considered.
Finally,
it
should
be
pointed
out
that
MOEs
(
all
pathways)
were
never

1000
even
at
30
days
after
application.
The
highest
MOEs
achieved
were
based
on
the
Florida
data
where,
30
days
after
application,
they
were
337
(
16.3
lb
ai/
A)
and
224
(
24.5
lb
ai/
A).
In
contrast,
the
highest
MOEs
achieved
based
on
the
California
data,
also
at
30
days
after
application,
were
89
(
16.3
lb
ai/
A)
and
59
(
24.5
lb
ai/
A).
Dermal
and
hand­
to­
mouth
exposures
were
the
key
contributors
while
soil
ingestion
was
a
minor
contributor
to
the
total
MOE
estimates.

Table
8:
Summary
of
Thiram
Noncancer
Postapplication
Residential
Aggregate
MOEs
For
Toddlers
Scenario
Descriptor
Results
MOE
on
Day
0
Days
For
MOE

UF
Residential
Turf
(
High
Activity)
16.3
lb
ai/
A
­
California
Data
4.0
>
30
24.5
lb
ai/
A
­
California
Data
2.6
>
30
16.3
lb
ai/
A
­
Florida
Data
3.9
>
30
24.5
lb
ai/
A
­
Florida
Data
2.6
>
30
Ingestion
of
thiram
granules
is
also
a
potential
source
of
exposure
because
children
can
eat
them
if
they
are
found
in
treated
lawns
or
gardens.
This
scenario
is
considered
an
episodic
scenario
by
the
Agency
(
i.
e.,
acute
dietary
endpoints
are
always
used).
The
concentration
in
granular
products
ranges
generally
from
1
to
10
percent.
If
this
information
is
coupled
with
the
body
weight
of
a
toddler
(
15
kg),
the
endpoint
of
5
mg/
kg/
day
which
is
the
same
value
used
for
the
APAD,
and
the
uncertainty
factor
of
1000
the
amount
of
formulation
that
can
be
consumed
at
the
uncertainty
factor
MOE
35
level
can
be
calculated.
The
Agency
generally
presents
these
results
based
on
the
number
of
granules
that
can
be
ingested.
However,
this
is
difficult
without
specific
information
pertaining
to
the
formulations
that
are
available.
If
a
1
percent
formulation
is
ingested,
7.5
mg
represents
exposure
at
an
MOE
of
1000
(
i.
e.,
1.6
x
10­
5
lb).
For
illustrative
purposes,
if
one
considers
a
1
percent
formulation
and
the
density
of
soil
(
0.67
mL/
gram,
many
granulars
are
clay
based),
only
0.005
mL
of
formulation
would
need
to
be
ingested
to
have
a
risk
concern
(
i.
e.,
7.5
mg
*
1g/
1000mg
*
0.67
mL/
gram).
Note
that
this
volume
is
orders
of
magnitude
less
than
a
teaspoon
of
granular
formulation
(
i.
e.,
0.1%
of
a
teaspoon
where
a
tsp.
=
5
mL).

5.1.2
Residential
Risk
Characterization
The
Agency
considered
exposure
scenarios
that
were
appropriate
to
address
the
potential
for
nonoccupational
exposures
to
thiram
from
treated
turf.
These
assessments
considered
toddlers
and
adults
playing
on
treated
lawns
or
golfing.
In
residential
settings,
the
Agency
does
not
use
REIs
or
other
mitigation
approaches
to
limit
exposures
because
they
are
viewed
as
impractical
and
not
enforceable.
As
such,
risk
estimates
on
the
day
of
application
are
the
key
concern.
It
should
also
be
noted
that
for
thiram
that
short­
term
calculations
are
protective
for
thiram
since
the
exposure
and
hazard
inputs
are
the
same
for
intermediate­
term
exposures
but
these
exposures
would
also
involve
an
amortization
step.

Characterization
of
the
residential
risks
included
in
this
document
must
consider
the
approaches
used
to
calculate
risks
as
well
as
the
data
that
were
available.
The
general
population
can
be
exposed
essentially
from
uses
on
turf
which
are
probably
sporadic
for
thiram
given
that
a
majority
of
it
is
used
in
the
seed
treatment
market
and
by
all
accounts
the
turf/
repellency
market
is
very
small.
For
turf
uses,
the
Agency
considered
adults
and
toddlers
(
3
year
olds)
in
the
assessments
which
is
the
standard
practice.
For
thiram,
this
meant
addressing
exposures
to
adult
golfers
and
for
toddlers
playing
on
turf
which
included
dermal
exposures
(
using
exposure
data
from
the
Jazzercize
model)
and
exposures
from
nondietary
ingestion
(
hand­/
object­
to­
mouth
and
soil
ingestion).

The
data
that
were
used
in
the
thiram
residential
postapplication
assessment
are
minimal
but
represent
the
best
data
and
approaches
that
are
currently
available.
To
the
extent
possible,
the
Agency
has
attempted
to
use
thiram­
specific
strawberry
dislodgeable
foliar
residue
(
DFR)
data
for
the
turf
scenarios.
However,
due
to
the
high
percent
transferability
and
the
extrapolation
from
strawberry
to
turf,
it
is
recommended
that
this
approach
be
considered
as
a
rangefinder
by
nature.
When
chemical­
specific
data
were
unavailable,
the
Agency
used
the
current
approaches
for
residential
assessment,
many
of
which
include
recent
upgrades
to
the
SOPs.
There
are
also
many
embedded
uncertainties
that
should
be
considered
in
the
interpretation
of
this
assessment
such
as
those
associated
with
the
use
of
Jazzercize
and
with
the
nondietary
ingestion
calculations.
Readers
should
consider
these
in
the
interpretation
of
the
overall
36
risk
estimates.
Readers
should
also
consider
the
screening
nature
of
the
SOPs
For
Residential
Exposure
Assessment
and
how
additional
data
could
refine
the
results.

Finally,
the
Agency
believes
that
the
values
presented
in
this
assessment
represent
the
highest
quality
results
that
could
be
produced
based
on
the
currently
available
data.
Readers
of
this
document
should
consider
the
quality
of
individual
inputs
when
interpreting
the
results
and
make
decisions
accordingly.
It
is
difficult
to
ascertain
where,
on
a
distribution,
the
calculated
values
fall
because
the
distributional
data
for
exposure,
residue
dissipation
and
many
other
parameters
are
unrefined.
The
Agency
does
believe,
however,
that
the
risks
represent
conservative
estimates
of
exposure
because
maximum
application
rates
are
used
to
define
residue
levels
upon
which
the
calculations
are
based.
Additionally,
estimates
are
thought
to
be
conservative
even
when
measures
of
central
tendency
(
e.
g.,
most
transfer
coefficients
are
thought
to
be
central
tendency)
are
used
because
values
that
would
be
considered
to
be
in
the
lower
percentile
aspect
of
any
input
parameter
have
not
been
used
in
the
calculations.

5.2
Occupational
Risk
Assessment
This
section
of
the
risk
assessment
addresses
exposures
to
individuals
who
are
exposed
as
part
of
their
employment.
These
exposures
can
occur
because
people
have
contact
with
thiram
residues
while
using
commercial
products
containing
thiram
(
i.
e.,
handlers)
or
by
being
in
areas
that
have
been
previously
treated
(
postapplication
workers).

5.2.1
Occupational
Handler
Risk
Assessment
The
Agency
completes
occupational
handler
risk
assessments
using
scenarios
as
the
basis
for
the
calculations
as
described
in
the
U.
S.
EPA
Guidelines
For
Exposure
Assessment.
For
commercial
pesticide
products,
the
Agency
categorizes
handler
exposures
based
on
the
kinds
of
formulations
(
e.
g.,
liquids
or
various
solids),
the
kinds
of
equipment
used
to
make
applications
(
e.
g.,
groundboom,
aerial,
or
airblast),
the
nature
of
the
task
(
e.
g.,
mixing/
loading,
applying,
or
both
combined),
and
the
level
of
personal
protection
used.
Identifying
the
duration
of
exposure
is
also
a
critical
element
in
the
development
of
a
risk
assessment
to
ensure
that
the
proper
hazard
component
is
used.

For
thiram
uses,
the
Agency
identified
28
major
occupational
exposure
scenarios
based
on
the
types
of
equipment
and
techniques
that
potentially
can
be
used
for
thiram
applications.
Most
of
the
scenarios
were
classified
as
having
short­
term
and
intermediate­
term
exposures
(
up
to
30
days
and
30
days
to
several
months,
respectively).
For
handlers
the
exposures
and
hazard
components
are
identical
so
the
calculated
results
reflect
the
risks
associated
with
all
appropriate
durations
of
exposure.

The
quantitative
exposure/
risk
assessment
developed
for
occupational
handlers
was
based
on
the
following
scenarios.
[
Note:
The
numbers
correspond
to
the
tracking
system
included
in
D289601.]
37
Mixing/
Loading:
(
1a)
Dry
Flowable
for
Aerial;
(
1b)
Dry
Flowable
for
Airblast;
(
1c)
Dry
Flowable
for
Groundboom
(
including
in­
furrow
uses
at
plant);
(
1d)
Dry
Flowable
for
High
Pressure
Handwand;
(
1e)
Dry
Flowable
for
Right­
of­
Way;
(
1f)
Dry
Flowable
for
Paint­
on
Applications;
(
2)
Granular
for
Turf
Uses
(
sod
farm
and
golf
courses);
(
3a)
Wettable
Powder
for
Aerial;
(
3b)
Wettable
Powder
for
Airblast;
(
3c)
Wettable
Powder
for
Groundboom
(
including
in­
furrow
uses
at
plant);
(
3d)
Wettable
Powder
for
High
Pressure
Handwand;
(
3e)
Wettable
Powder
for
Right­
of­
Way;
(
3f)
Wettable
Powder
for
Paint­
on
Applications;
(
4a)
Liquid
for
Aerial;
(
4b)
Liquid
for
Airblast;
(
4c)
Liquid
for
Groundboom
(
including
in­
furrow
uses
at
plant);
(
4d)
Liquid
for
High
Pressure
Handwand;
(
4e)
Liquid
for
Right­
of­
Way;
(
4f)
Liquid
for
Paint­
on
Applications;
(
4g)
Liquid
for
Bulb
Dip
Tank
Applications;

Applicator:
(
5a)
Liquid
Spray
Aerial
Application;
(
5b)
Granular
Aerial
Application;
(
6)
Airblast
Application;
(
7)
Groundboom
Application
(
includes
in­
furrow
application);
(
8)
Solid
Broadcast
Spreader
Application;
(
9)
Right­
of­
Way
Sprayer
Application;
(
10)
High
Pressure
Handwand
Application;
(
11)
Repellent
Use
Paint
Brush
Applications
(
both
liquids
&
slurries);
(
12)
Dip
Tank
Application;
(
13)
Granular
Application
By
Hand;
(
14)
Granular
Application
By
Spoon;

Mixer/
Loader/
Applicator:
(
15)
High
Volume/
Low
Pressure
Turfgun;
(
16a)
Low
pressure
handwand
­
Liquid
Formulation;
(
16b)
Low
pressure
handwand
­
Wettable
Powder
Formulation;
(
17)
Liquid
Backpack;
(
18)
Push­
type
Granular
Spreader;
(
19)
Powered
Backpack;
(
20)
Sprinkler
Can;
38
Flaggers:
(
21)
Flagging
For
Liquid
Sprays;
(
22)
Flagging
For
Granular
Applications;

Seed
Treatment
Scenarios:
(
23)
Mixing/
Loading
For
Seed
Treatment
In
A
Commercial
Facility;
(
24)
Bagging
Treated
Seed
In
A
Commercial
Facility;
(
25)
Sewing
Bags
of
Treated
Seed
In
A
Commercial
Facility;
(
26)
Combined
Tasks
Required
To
Operate
A
Commercial
Seed
Treatment
Facility;
(
27)
Loading/
Planting
Treated
Seed;
and
(
28)
On­
farm
Seed
Treatment.

For
each
of
these
scenarios,
risk
calculations
were
completed
based
on
eight
levels
of
personal
protection,
as
appropriate,
that
were
defined
based
on
different
combinations
of
the
following:

1)
Baseline
Protection
(
typical
work
clothing
or
a
long­
sleeved
shirt
and
long
pants,
no
respiratory
protection
and
no
chemical­
resistant
gloves);

2)
Minimum
Personal
Protective
Equipment
(
baseline
scenario
with
the
use
of
chemical­
resistant
gloves
and
a
dust/
mist
respirator
with
a
protection
factor
of
5);

3)
Maximum
Personal
Protective
Equipment
(
baseline
scenario
with
the
use
of
an
additional
layer
of
clothing
(
e.
g.,
a
pair
of
coveralls),
chemical­
resistant
gloves,
and
an
air
purifying
respirator
with
a
protection
factor
of
10);

4)
Engineering
Controls
(
use
of
an
appropriate
engineering
control
such
as
a
closed
tractor
cab
or
closed
loading
system
for
granulars
or
liquids).

[
Note:
Current
labels
mostly
require
single
layer
clothing,
chemical­
resistant
gloves,
and
no
respirator.]

Data
and
Assumptions:
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
occupational
handler
risk
assessments.
The
inputs
are
consistent
with
current
Agency
policy
for
completing
occupational
exposure
assessments
(
e.
g.,
PHED
Surrogate
Exposure
Guide
and
Exposac
Policy
9:
Standard
Values
For
Daily
Acres
Treated
In
Agriculture).
[
Note:
PHED
is
a
database
that
contains
monitored
field
data
used
for
assessments.
See
the
occupational
and
residential
exposure
assessment
document
for
further
information
(
D289601).]

The
assumptions
and
factors
used
in
the
risk
calculations
include:


Average
body
weight
of
an
adult
handler
is
70
kg
because
the
toxicity
endpoint
values
used
for
the
assessments
are
appropriate
for
average
adult
body
weight
representing
the
general
population.
This
is
the
case
because
none
of
the
effects
39

identified
in
the
selected
toxicity
studies
were
sex
specific
(
i.
e.,
NOAELs
selected
by
HIARC
were
the
same
for
males
and
females).


All
analyses
were
completed
using
scenario­
specific
exposure
data
or
data
that
were
deemed
to
be
a
source
of
acceptable
surrogate
exposure
data
for
the
scenario
in
question.
Most
scenarios
were
addressed
using
exposure
estimates
based
on
the
Pesticide
Handler
Exposure
Database
(
PHED).
Several
handler
assessments
were
completed
using
"
low
quality"
PHED
data
due
to
the
lack
of
a
more
acceptable
dataset.
The
PHED
unit
exposure
values
range
between
the
geometric
mean
and
the
median
of
the
available
exposure
data.
When
data
from
other
studies
were
used,
the
appropriate
statistical
measure
of
central
tendency
was
used
(
see
each
study
summary
below
for
data
descriptor).


Several
generic
protection
factors
were
used
to
calculate
handler
exposures.
The
protection
factors
used
for
clothing
layers
(
i.
e.,
50%)
and
gloves
(
90%)
have
not
been
completely
evaluated
by
the
Agency.
Additionally,
the
Agency
uses
a
98%
reduction
factor
to
estimate
exposures
that
involve
the
use
of
engineering
controls.
There
is
an
ongoing
project
through
NAFTA
to
address
the
issue
of
protection
factors
(
a
draft
document
assessing
protection
factors
using
PHED
has
been
completed).
The
results
of
this
effort
show
that
the
protection
factors
being
currently
used
by
the
Agency
are
within
those
predicted
in
the
analysis.
The
values
used
for
respiratory
protection
(
i.
e.,
PF
5
or
PF
10)
are
based
on
the
NIOSH
Respirator
Decision
Logic.


Exposure
factors
used
to
calculate
daily
exposures
to
handlers
are
based
on
applicable
data
if
available.
For
lack
of
appropriate
data,
values
from
a
scenario
deemed
similar
enough
by
the
assessor
might
be
used.
As
a
example,
mixer/
loader/
applicator
data
for
hose­
end
sprayers
were
used
to
assess
sprinkler
can
applications.
The
nature
of
these
application
methods
are
believed
to
be
similar
enough
to
bridge
the
data.
There
are
other
instances
where
the
Agency
has
bridged
specific
data
to
represent
other
scenarios.


In
many
scenarios
it
is
likely
that
a
grower
would
mix,
load,
and
apply
chemicals
all
in
one
day
because
of
limited
labor,
efficiency,
or
many
other
reasons.
In
most
cases,
however,
the
Agency
considers
mixing/
loading,
and
application
as
separate
job
functions.
This
is
done
primarily
due
to
a
lack
of
data
that
allows
additivity
between
tasks
to
be
appropriately
assessed.
Also,
this
approach
allows
for
more
flexibility
in
the
risk
management
process.
For
example,
if
a
closed
loading
system
might
be
required
for
mixer/
loaders
but
engineering
controls
might
not
be
required
to
reduce
applicator
exposures.
If
combined
exposure
estimates
were
considered,
engineering
controls
might
have
been
required
for
both
tasks.


The
Agency
has
evaluated
scenarios
that
may
be
limited
in
nature
such
as
flagging
during
aerial
applications
because
engineering
controls
(
i.
e.,
Global
Positioning
Satellite
technology)
are
now
predominantly
used
as
indicated
by
the
40
1998
National
Agricultural
Aviation
Association
(
NAAA)
survey
of
their
membership.
It
appears,
however,
flaggers
are
still
used
in
approximately
10
to
15
percent
of
aerial
application
operations.
In
cases
like
these,
the
Agency
strongly
encourages
the
use
of
the
engineering
control
system
but
will
continue
to
evaluate
risks
for
flaggers
and
any
other
population
where
a
clear
exposure
pathway
exists
until
the
potential
for
exposure
is
eliminated.
The
Agency
is
aware
that
NAAA
is
conducting
another
survey
of
its
membership
on
exposure
issues
and
will
consider
those
results
as
is
timely
and
appropriate.


The
Agency
always
considers
the
maximum
application
rates
allowed
by
labels
in
its
risk
assessments
in
order
to
be
able
to
consider
what
is
legally
possible
based
on
the
label.
If
additional
information
such
as
average
or
typical
rates
are
available,
these
values
were
used
as
well
in
order
to
allow
risk
managers
to
make
a
more
informed
risk
management
decision.


The
average
occupational
workday
is
assumed
to
be
8
hours.
The
daily
areas
to
be
treated
were
defined
for
each
handler
scenario
(
in
appropriate
units)
by
determining
the
amount
that
can
be
reasonably
treated
in
a
single
day.
The
factors
used
for
the
thiram
assessment
are
the
same
as
those
detailed
in
the
Health
Effects
Division
Science
Advisory
Committee
on
Exposure
Policy
9:
Standard
Values
for
Daily
Acres
Treated
in
Agriculture
which
was
completed
on
July
5,
2000.
The
following
daily
volumes
handled
and
acres,
excerpted
from
the
policy,
to
be
treated
in
each
occupational
scenario
include:


Aerial
applications:
350
acres
for
agricultural
crops
and
80
acres
for
sod
farms;


Groundboom:
80
acres
treated
for
strawberries
and
sod
farm
turf,
and
40
acres
on
golf
course
turf;


Airblast:
40
acres
treated
for
agricultural
applications;

°
1000
gallons
of
spray
solution
prepared
when
mixing/
loading
liquids
for
high
pressure
handwand
application
or
making
the
application
with
a
right­
of­
way
sprayer;

°
40
gallons
when
mixing/
loading/
applying
liquids
with
a
backpack
sprayer
or
a
low
pressure
handwand
sprayer;

°
Low
pressure/
high
volume
turfgun:
5
acres
for
golf
course
and
other
(
nonresidential)
turf;

°
Paint
brush
repellent
uses:
1
gallon
of
liquid
or
slurry
for
use
as
a
repellent;

°
Dip
tank
applications:
(
no
data
to
complete
the
assessment);
41
°
Solid
broadcast
spreader
applications:
80
acres
on
sod
farm
turf
and
40
acres
on
golf
course
turf;

°
Low
pressure
handwand
and
backpack
liquid
sprayers:
40
gallons
of
spray
solution;
°
Push­
type
spreaders
and
granular
backpack
applicators:
5
acres
of
treated
turf;
and
°
Sprinkler
can
application:
10
gallons
of
spray
for
repellent
uses.


The
Agency
received
information
on
the
amount
of
seed
treated
in
a
day
from
a
variety
of
sources.
These
included
information
from
Gustafson
(
email
from
Dave
Vossen
to
Jeff
Dawson
dated
6/
24/
01)
that
pertained
to
the
amount
of
seed
that
could
be
treated
in
a
day,
the
thiram
task
force
also
provided
information
concerning
the
daily
amounts
that
could
be
treated
in
a
day,
and
information
concerning
how
much
seed
is
treated
in
a
day
from
the
survey
conducted
of
thiram
seed
treaters
was
summarized
and
considered.
The
Agency
used
values
of
330,000
and
800,000
lb
seed
treated
per
day
in
the
previous
assessment.
To
allow
for
a
more
informed
risk
management
decision,
the
Agency
has
considered
these
estimates
(
which
are
supported
by
the
data
from
Gustafson
as
shown
in
Table
9
as
well
as
the
additional
information
provided
from
the
thiram
task
force
and
the
survey
of
seed
treaters
(
Table
8).
This
information
is
presented
below:

Table
9:
Small
Grain
Capacity
For
Various
Gustafson
Seed
Treatment
Equipment
Model
Minimum
Rate
Needed
For
Operation
Maximum
Throughput
of
Equipment
(
metric
tons/
hr)
(
lb
/
hour)
(
metric
tons/
hr)
(
lb
/
hour)

SS­
1
3.4
7480
7.5
16500
SS­
6
6.8
14960
12.3
27060
S­
100SS
3.4
7480
7.5
16500
S­
600SS
6.8
14960
12.3
27060
S­
800SS
16.0
35200
27.0
59400
S­
1000SS
19.0
41800
40.8
89760
Accu­
Treat
6x10
19.0
41800
40.8
89760
Accu­
Treat
8x12
16.0
35200
27.0
59400
Average
NA
24860
NA
78555
Values
over
an
8
hour
workday
are:
Lowest
production
model
(
SS­
1):
59840
lb
seed/
day
Highest
production
model
(
S­
1000SS):
718080
lb
seed/
day
Minimum
average:
198880
lb
seed/
day
Maximum
Average:
628440
lb
seed/
day
(
Source:
Dave
Vossen,
Gustafson
Inc.)
42
The
information
provided
by
the
thiram
task
force
in
their
comments
on
the
Phase
3
risk
assessment
is
provided
below
(
i.
e.,
seed
types
and
lb
seed
treated/
day
are
presented):

°
Corn
193,600
°
Cottonseed.
160,160
°
Small
grains
718,080
°
Peanuts
119,680
°
Soybeans
211,200
°
Vegetables
(
small
seed)
88,000
°
Vegetables
(
large
seed)
193,600
°
Sweet
corn
193,600
Table
10:
Amount
Of
Seed
Treated
Per
Day
For
Thiram
Applicator
Crews
Seed
Type
Avg.
#
in
Crew
Seed
Treated/
Day
(
lb/
day)
Average
Hours/
Crew
N
Per
day
Per
Year
Small
Vegetable
2.7
16250
5
192
15
Large
Vegetable
3.1
84140
7
364
20
Cereal
Grains
(
slurry
­
major
method)
1.8
78962
7
241
82
Cotton
2.2
81192
8
834
14
Soybeans
2.5
61065
6
78
51
(
Source:
Survey
of
Thiram
using
seed
treaters)


The
Agency
received
information
on
the
amount
of
seed
treated
in
a
day
from
a
variety
of
sources.
It
was
decided,
however,
to
base
the
inputs
used
in
the
assessment
on
information
provided
by
Drs.
B.
Schneider
and
Yuen­
Shaung,
NG
(
4/
3/
03
memo).
This
includes
the
following:

°
Small
Seeded
Vegetables:
Tomato
­
1
Lb/
a;
Broccoli
­
1
to
2
lb/
a;
Cabbage
­
0.15
to
1
lb/
a;
Cauliflower
­
1
to
2
lb/
a;
Carrot
­
2
to
4
lb/
a;
Dry
Bulb
Onions
­
1
to
4
lb/
a;
Green
Onions
­
5
to
15
lb/
a;
and
Lettuce
­
1
to
3
lb/
a.

°
Large
Seeded
Vegetables:
Lima
Beans
­
40
to
60
lb/
a;
Snapbeans
­
60
to
100
lb/
a;
Field
Corn
­
4
to
18
lb/
a;
Sweetcorn
­
10
to
15
lb/
a;
English
Pea
­
80
to
120
lb/
a;
and
Watermelon
1
to
3
lb/
a.

°
Cereals:
Winter
Barley
­
60
to
90
lb/
a;
Spring
Barley
­
30
to
50
lb/
a;
Oats
­
50
to
90
lb/
a;
Rice
­
100
to
150
lb/
a;
Wheat
­
60
to
120
lb/
a.

°
Other
Crops:
Alfalfa
&
Fescue
­
15
to
20
lb/
A;
Red
Clover
­
8
to
10
lb/
A;
43
°
Peanut
­
60
to
140
lb/
A;
Cotton
­
10
to
15
lb/
A;
Soybeans
­
45
to
60
lb/
A;
Sunflower
­
3
to
7
lb/
A;
and
Bluegrass
­
10
to
15
lb/
A.

[
Note:
Selected
crops
from
this
list
were
used
to
complete
assessments
for
the
planting
of
treated
seed.]

The
Pesticide
Handler
Exposure
Database
(
PHED)
Version
1.1
August
1998,
was
used
to
address
most
non­
seed
treatment
exposure
scenarios.
For
seed
treatment
and
other
scenarios
(
e.
g.,
some
lawncare
applications),
unit
exposure
values
were
from
studies
not
using
thiram
but
that
were
pertinent
to
specific
exposure
scenarios
associated
with
thiram.
There
are
may
be
data
compensation
issues
under
FIFRA
associated
with
the
use
of
data
contained
in
the
non­
PHED.
Please
refer
to
the
description
of
each
contained
in
the
occupational
and
residential
exposure
assessment
chapter
(
D289601)
in
order
to
ascertain
if
the
registrants
of
thiram
maintain
ownership
of
any
of
these
data.

5.2.2
Occupational
Handler
Non­
Cancer
Risks
Noncancer
risks
were
calculated
using
the
MOE
approach,
as
described
above
in
the
residential
assessment
(
see
5.1).
Risk
estimates
for
short­
and
intermediate­
term
exposures
are
similar
because
all
numerical
inputs
for
both
durations
and
the
target
MOEs
were
identical.
A
NOAEL
from
the
21­
day
dermal
toxicity
study
in
rabbits
using
technical
grade
thiram
was
used
to
calculate
results
for
both
durations
(
i.
e.,
300
mg/
kg/
day).
A
NOAEL
based
on
a
reproduction
study
in
rats,
a
chronic
study
in
rats,
and
a
chronic
study
in
dogs
(
i.
e.,
1.5
mg/
kg/
day),
was
used
to
calculate
inhalation
risks.
The
target
MOE
was
100
for
all
assessments.

Short­
term
and
Intermediate­
term
Risk
Summary:
Short­
term
and
intermediate­
term
risks
were
calculated
for
different
exposure
scenarios
at
different
levels
of
personal
protection
as
illustrated
in
Table
11.
The
results
represent
both
short­
and
intermediateterm
risks
because
the
exposure
factors
used
to
calculate
each
are
identical
as
are
the
hazard
inputs
(
e.
g.,
NOAELs).

In
most
scenarios,
MOEs
meet
or
exceed
the
required
uncertainty
factor
of
100
at
some
level
of
personal
protection.
For
the
most
part,
current
label
requirements
(
for
personal
protection
single
layer
clothing,
gloves,
and
no
respirator)
appear
to
be
generally
inadequate
for
most
scenarios
except
for
operations
where
exposures
and/
or
the
amount
of
chemical
used
is
low.
Scenarios
where
MOEs
do
not
exceed
100
at
any
level
of
personal
protection
include
some
loading
scenarios
for
aerial
applications,
aerial
granular
application,
some
handheld
equipment
use,
and
a
few
commercial
and
on­
farm
seed
treatment
scenarios.
[
Note:
Scenarios
of
concern
(
i.
e.,
MOEs<
100)
and
the
required
PPE
is
also
highlighted
where
risks
exceed
current
label
requirements.]
Several
data
gaps
were
also
identified
in
many
different
use
areas
that
include:
in­
furrow/
at­
plant
applications;
repellent
paint­
on
applications;
powered
backpack;
engineering
control
data
for
seed
treatment;
on­
farm
seed
treatment
data
with
different
application
methods
(
e.
g.,
admixture);
sprinkler
can;
and
bulb
dip
applications.
44
Table
11:
Summary
of
Short­/
Intermediate­
Term
Occupational
Handler
Noncancer
Risks
Scenario
Rate
(
lb
ai/
acre)

[
unless
noted]
Area
Treated
(
acres/
day)

[
unless
noted]
Risk
Summary
MOEs
Min.
Req.
PPE
Mixer/
Loaders
1a
Dry
Flowable:
Aerial
2.6
(
peaches)
3.3­
4.5
(
apples/
strawberries)
16.3­
24.5
(
turf
­
sodfarm)
350
350
80
105
138­
188
111­
166
Baseline
SL/
GL/
PF5
SL/
GL/
PF5
1b
Dry
Flowable:
Airblast
2.6­
4.5
(
apples/
peaches)
40
530­
917
Baseline
1c
Dry
Flowable:
Groundboom
(
incl.
In­
furrow)
3.3
(
strawberries)
16.3­
24.5
(
sodfarm
turf)
16.3
(
golf
course
turf)
24.5
(
golf
course
turf)
0.0025­
0.35
(
SSV/
LSV/
cereals/
others)
80
80
40
40
80
362
111­
166
221
146
3409­
477273
Baseline
SL/
GL/
PF5
SL/
GL/
PF5
Baseline
Baseline
1d
Dry
Flowable:
High
Press
HW
Sprayer
1.3
lb
ai/
gal
(
repellency)
1000
gal.
167
SL/
GL/
PF5
1e
Dry
Flowable:
Right
of
Way
Sprayer
1.3
lb
ai/
gal
(
repellency)
1000
gal.
167
SL/
GL/
PF5
1f
Dry
Flowable:
Paint­
on
1.3
lb
ai/
gal
(
repellency)
1
gal.
73427
Baseline
2
Granular:
Aerial
&
Ground
Applications
16.3­
24.5
(
sodfarm)
16.3­
24.5
(
golf
course)
80
40
143­
215
286­
430
SL/
GL/
PF5
SL/
GL/
PF5
3a
Wettable
Powder:
Aerial
2.6­
4.5
(
apples/
peaches/
strawberries)
16.3­
24.5
(
sodfarms/
golf
courses)
350
80
231­
399
185­
279
EC
EC
3b
Wettable
Powder:
Airblast
2.6
(
peaches)
4.5
(
apples)
40
40
107
113
SL/
GL/
PF5
SL/
GL/
PF10
3c
Wettable
Powder:
Groundboom
(
Incl.
In­
furrow)
3.3
(
strawberry)
16.3­
24.5
(
sodfarm
&
golf
course
turf)
0.0025­
0.21
(
SSV/
LSV/
cereals/
others)
0.35
(
others­
peanuts)
80
40­
80
80
80
1376
185­
557
102­
8537
397
EC
EC
Baseline
SL/
GL/
PF5
3d
Wettable
Powder:
High
pressure
handwand
sprayer
1.3
lb
ai/
gal.
(
repellency)
1000
gal.
280
EC
3e
Wettable
Powder:
Right­
of­
way
sprayer
1.3
lb
ai/
gal.
(
repellency)
1000
gal.
280
EC
3f
Wettable
Powder:
Paint­
On
1.3
lb
ai/
gal.
(
repellency)
1
gal.
1313
Baseline
4a
Liquids:
Aerial
2.6­
4.5
(
apples/
peaches/
strawberries)
16.3­
24.5
(
sodfarm
turf)
350
80
188­
325
151­
227
SL/
GL/
PF5
SL/
GL/
PF5
4b
Liquids:
Airblast
2.6­
4.5
(
apples/
peaches)
40
444­
768
SL/
GL/
NR
4c
Liquids:
Groundboom
(
incl.
In­
furrow)
3.3
(
strawberries)
16.3­
24.5
(
sodfarm
turf)
16.3
(
golf
course
turf)
24.5
(
golf
course
turf)
0.0025­
0.35
(
SSV/
LSV/
cereals/
others)
80
80
40
40
80
303
151­
227
123
302
239­
33440
SL/
GL/
NR
SL/
GL/
PF5
SL/
GL/
NR
SL/
GL/
PF5
Baseline
4d
Liquids:
High
pressure
handwand
sprayer
1.3
lb
ai/
gal.
(
repellency)
1000
gal.
228
SL/
GL/
PF5
4e
Liquids:
Right­
of­
way
sprayer
1.3
lb
ai/
gal.
(
repellency)
1000
gal.
228
SL/
GL/
PF5
4f
Liquids:
Paint­
On
1.3
lb
ai/
gal.
(
repellency)
1
gal.
5145
Baseline
4g
Liquids:
Bulb
dip
No
Data
No
Data
No
Data
No
Data
Table
11:
Summary
of
Short­/
Intermediate­
Term
Occupational
Handler
Noncancer
Risks
Scenario
Rate
(
lb
ai/
acre)

[
unless
noted]
Area
Treated
(
acres/
day)

[
unless
noted]
Risk
Summary
MOEs
Min.
Req.
PPE
45
Applicators
5a
Aerial:
liquid
sprays
2.6­
4.5
(
apples/
peaches/
strawberries)
16.3­
24.5
(
turf
­
sodfarm)
350
80
698­
1208
561­
843
EC
EC
5b
Aerial:
granular
applications
16.3­
24.5
(
turf
­
sodfarm)
80
41­
62
MOE<
100
6
Airblast:
Agricultural
uses
2.6
(
peaches)
4.5
(
apples)
40
40
160
102
Baseline
SL/
GL/
NR
7
Groundboom
3.3
(
strawberries)
16.3­
24.5
(
sodfarm
turf)
16.3­
24.5
(
golf
course
turf)
0.0025­
0.35
(
SSV/
LSV/
cereals/
others)
80
80
40
80
491
248­
369
132­
199
4930­
648148
Baseline
SL/
GL/
PF5
Baseline
Baseline
8
Solid
broadcast
spreader
(
granular)
16.3­
24.5
(
sodfarm
turf)
16.3
(
golf
course
turf)
24.5
(
golf
course
turf)
80
40
40
194­
292
129
388
SL/
GL/
PF5
Baseline
SL/
GL/
PF5
9
Right
of
way
sprayer
1.3
lb
ai/
gal.
(
repellency)
1000
gal.
44
MOE<
100
10
High
pressure
handwand
1.3
lb
ai/
gal.
(
repellency)
1000
gal.
8
MOE<
100
11
Paint­
on
1.3
lb
ai/
gal.
(
repellency)
1
gal.
202
SL/
GL/
NR
12
Dip
tank
No
Data
No
Data
No
Data
No
Data
13
Granulars
&
baits
applied
by
hand
16.3
(
golf
course
turf)
24.5
(
golf
course
turf)
1
1
26
17
MOE<
100
MOE<
100
14
Granulars
&
baits
applied
by
spoon
16.3
(
golf
course
turf)
24.5
(
golf
course
turf)
1
1
117
227
SL/
GL/
NR
SL/
GL/
PF5
Mixer/
Loader/
Applicators
15
Low
pressure,
high
volume
turfgun
(
ORETF
Data)
16.3
(
golf
course
turf)
24.5
(
golf
course
turf)
5
5
131
188
SL/
GL/
NR
SL/
GL/
PF5
16a
Wettable
powder,
low
pressure
handwand
1.3
lb
ai/
gallon
(
repellency)
40
14.3
MOE<
100
16b
Liquids,
low
pressure
handwand
1.3
lb
ai/
gallon
(
repellency)
40
248
SL/
GL/
PF5
17
Backpack
sprayer
1.3
lb
ai/
gallon
(
repellency)
40
109
SL/
GL/
PF5
18
Granular,
push­
type
spreader
16.3
(
golf
course
turf)
24.5
(
golf
course
turf)
5
5
139
330
Baseline
SL/
GL/
PF5
19
Power
backpack
No
Data
No
Data
No
Data
No
Data
20
Sprinkler
can
1.3
lb
ai/
gallon
(
repellency)
10
204
SL/
GL/
NR
Flaggers
21
Flagger:
liquid
sprays
2.6­
4.5
(
apples/
peaches/
strawberries)
16.3­
24.5
(
turf
­
sodfarm)
350
80
165­
285
132­
199
Baseline
Baseline
22
Flagger:
granular
applications
16.3­
24.5
(
turf
­
sodfarm)
80
327­
491
Baseline
Seed
Treatment
23
Mixing/
loading
for
commercial
seed
treatment
0.031­
0.25
lb
ai/
cwt
(
various)
1.5
lb
ai/
cwt
(
onions)
1.5
lb
ai/
cwt
(
onions)
0.094­
0.25
lb
ai/
cwt
(
corn
/
cereals/
LSV/
SSV/
cotton/
peanuts)
0.10­
0.25
lb
ai/
cwt
(
cotton/
cereals/
soybean/
SSV/
LSV)
330000­
800000
(
Agency)
330000
(
Agency)
800000
(
Agency)
88000­
718080
(
Thiram
Task
Force)
16250­
81192
(
Doane
Survey)
105­
167164
111
69
291­
1247
993­
5144
SL/
GL/
NR
SL/
GL/
PF5
MOE<
100
SL/
GL/
NR
SL/
GL/
NR
Table
11:
Summary
of
Short­/
Intermediate­
Term
Occupational
Handler
Noncancer
Risks
Scenario
Rate
(
lb
ai/
acre)

[
unless
noted]
Area
Treated
(
acres/
day)

[
unless
noted]
Risk
Summary
MOEs
Min.
Req.
PPE
46
24
Bagging
commercially
treated
seed
0.031­
1.5
lb
ai/
cwt
(
various)
1.5
lb
ai/
cwt
(
onions)
0.094­
0.25
lb
ai/
cwt
(
corn
/
cereals/
LSV/
SSV/
cotton/
peanuts)
0.10­
0.25
lb
ai/
cwt
(
cotton/
cereals/
soybeans/
SSV/
LSV)
330000­
800000
(
Agency)
800000
(
Agency)
88000­
718080
(
Thiram
Task
Force)
16250­
81192
(
Doane
Survey)
103­
408759
43
711­
2419
2429­
12577
Baseline
MOE<
100
Baseline
Baseline
25
Sewing
bags
of
commercially
treated
seed
0.031­
0.25
lb
ai/
cwt
(
various)
1.5
lb
ai/
cwt
(
onions)
0.094­
0.25
lb
ai/
cwt
(
corn
/
cereals/
LSV/
SSV/
cotton/
peanuts)
0.10­
0.25
lb
ai/
cwt
(
cotton/
cereals/
soybeans/
SSV/
LSV)
330000­
800000
(
Agency)
330000­
800000
(
Agency)
88000­
718080
(
Thiram
Task
Force)
16250­
81192
(
Doane
Survey)
201­
321839
34­
81
560­
2401
1913­
9903
Baseline
MOE<
100
Baseline
Baseline
26
Commercially
treated
seed:
combined
tasks
0.031­
0.25
lb
ai/
cwt
(
various)
0.12­
0.25
lb
ai/
cwt
(
various)
1.5­
2.0
lb
ai/
cwt
(
onions
&
conifers)
0.094­
0.25
lb
ai/
cwt
(
corn
/
LSV/
SSV/
cotton/
peanuts)
0.10
lb
ai/
cwt
(
cereals)
0.10­
0.25
lb
ai/
cwt
(
cotton/
cereals/
soybeans/
SSV/
LSV)
330000­
800000
(
Agency)
330000­
800000
(
Agency)
1769­
800000
(
Agency)
88000­
193600
(
Thiram
Task
Force)
718080
(
TTF)
16250­
81192
(
Doane
Survey)
126­
567
177­
240
24­
80
120­
346
276
276­
1428
SL/
GL/
NR
SL/
GL/
PF5
MOE<
100
SL/
GL/
NR
SL/
GL/
PF5
SL/
GL/
NR
27
Loading/
planting
treated
seed
0.0025­
1.22
lb
ai/
A
(
SSV/
LSV/
cereals/
others/
conifers/
ornam.)
80
638­
112903
SL/
GL/
NR
28
On­
farm
seed
treatment
0.0025­
0.168
lb
ai/
A
(
SSV/
LSV/
cereals/
others/
ornam.)
0.21lb
ai/
A
(
cereals­
rice)
0.35­
1.22
lb
ai/
A
(
peanuts
&
conifers)
80
80
80
122­
8179
103
50­
63
Baseline
SL/
GL/
NR
MOE<
100
Baseline
=
Long
pants,
long­
sleeved
shirts,
no
gloves
SL
=
Single
layer
clothing
with
or
without
gloves
(
GL
or
NG)
DL
=
Double
layer
clothing
(
i.
e.,
coveralls
over
SL)
with
or
without
gloves
(
GL
or
NG)
EC
=
Engineering
controls
NR
=
No
respirator
PF5
=
Protection
factor
5
respirator
PF10
=
Protection
factor
10
respirator
Current
label
=
SL/
GL/
NR
Min.
Req.
PPE
=
level
of
PPE
where
MOEs
>
100,
where
current
label
is
exceeded
or
no
adequate
PPE
is
found,
results
are
bold.
MOEs
which
never
exceed
100
are
for
highest
feasible
type
of
mitigation
(
e.
g.,
engineering
control
in
most
cases).

5.2.3
Postapplication
Exposure
Risks
Assessment
Workers
can
be
exposed
to
thiram
residues
by
entering
previously
treated
areas
to
perform
activities.
Exposure
varies
with
the
specific
tasks
(
i.
e.,
transfer
coefficient),
the
level
of
thiram
residue
in
the
environment
(
i.
e.,
DFR
or
TTR
depending
upon
crop),
and
the
duration
of
the
activity.
Calculations
were
completed
using
the
same
approaches
as
already
outlined
above
for
the
residential
postapplication
risk
assessments.

An
administrative
approach,
the
Restricted
Entry
Interval
(
REI),
is
used
by
the
Agency
to
manage
risks
for
postapplication
workers
doing
hand
labor
activities
that
require
direct
contact
with
treated
plants.
The
REI
is
the
amount
of
time
required
between
application
of
a
pesticide
and
engaging
in
a
task
or
activity
in
a
treated
field
that
it
takes
for
residues
to
dissipate
to
an
appropriate
level.
Current
labels
for
thiram
specify
REIs
of
24
hours
after
application
for
all
crop/
cultural
practice
combinations.
In
other
cases
(
e.
g.,
use
of
a
combine
or
other
mechanical
harvesting)
such
as
those
specified
in
the
47
Agency's
Worker
Protection
Standard
(
40CFR170)
where
no
contact
will
occur,
the
Agency
does
not
rely
on
the
REI
approach
but
adheres
to
the
guidance
included
in
§
170.110.(
c)(
3)
that
allows
for
entry
if
the
criteria
are
met.
The
Agency
also
considers
short­
term
excursions
for
people
for
such
activities
as
unclogging
machinery
as
stipulated
in
the
guidance
included
in
§
170.112.(
c).
The
Agency
encourages
the
use
of
viable
engineering
controls
and
other
means
to
reduce
exposures
provided
they
are
not
overly
burdensome
for
actual
workers.
Generally,
it
should
also
be
noted
that
the
use
of
personal
protective
equipment
or
other
types
of
equipment
to
reduce
exposures
for
postapplication
workers
is
not
considered
a
viable
alternative
for
the
regulatory
process
except
in
specialized
situations
(
e.
g.,
a
rice
scout
will
wear
rubber
boots
in
flooded
paddies).

As
with
the
occupational
handlers,
a
scenario­
driven
approach
is
used
to
assess
risks
for
reentry
workers.
The
Agency's
Policy
003.1
Science
Advisory
Council
For
Exposure
Policy
Regarding
Agricultural
Transfer
Coefficients
is
used
to
define
the
scenarios.
This
policy
presents
various
transfer
coefficients
which
represent
the
range
of
activities
associated
with
distinct
crop/
agronomic
groupings
based
on
different
types
of
job
tasks
or
activities
needed
to
produce
fruits,
vegetables,
grains,
and
other
crops.
In
this
scheme,
thiram
uses
were
identified
in
the
following
crop
groupings
from
the
policy
described
below.


Low
Berry
(
e.
g.,
strawberries);


Trees/
fruit,
deciduous
(
e.
g.,
apples,
peaches);


Turf/
sod
(
e.
g.,
golf
courses,
sod
farms);
and

Nursery
crops
(
e.
g.,
container
and
B&
B
ornamentals).

[
Note:
This
assessment
includes
the
latest
transfer
coefficients
for
nursery
crops
which
have
been
recently
submitted
by
ARTF
and
reviewed
by
the
Agency.
Additionally,
the
transfer
coefficient
for
fruit
tree
hand
thinning
has
been
reduced
from
original
policy
estimates
based
on
a
reinterpretation
by
the
Agency
of
the
dataset
upon
which
it
was
based.
The
transfer
coefficient
for
fruit
tree
hand
harvesting
(
and
for
all
related
activities
based
on
this
value)
has
also
been
reduced
based
on
an
analysis
of
the
data
from
a
number
of
ARTF
studies
within
this
cluster.]

Data
and
Assumptions:
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
occupational
postapplication
risk
assessments,
as
described
below.
The
assumptions
and
factors
used
in
the
risk
calculations
are
consistent
with
current
Agency
policy
for
completing
occupational
exposure
assessments
(
e.
g.,
Exposac
Policy
3
and
guidelines
for
handling
DFR
data).
The
assumptions
and
factors
used
in
the
risk
calculations
include:


The
transfer
coefficient
in
Policy
003
for
tree
fruit
thinning
has
been
reduced
since
the
issuance
of
the
policy
from
8000
cm2/
hour
to
3000
cm2/
hour
based
on
a
re­
evaluation
of
the
data
from
the
cited
study
(
i.
e.,
the
change
is
based
on
an
altered
analytical
recovery
correction
factor
that
was
erroneously
used
by
Bayer
in
the
initial
study
report).
This
modification
has
been
made
in
the
tree
fruit
48
group
and
any
other
scenarios
which
have
used
this
value.
Additionally,
preliminary
data
from
a
biomonitoring
study
of
tree
fruit
thinning
presented
at
the
International
Society
of
Exposure
Analysis
meeting
in
August
2002,
conducted
by
Krieger
et
al
from
the
University
of
California
Riverside,
also
supports
use
of
a
transfer
coefficient
of
3000
cm2/
hr
for
tree
fruit
thinners.


The
tree
fruit
harvester
transfer
coefficient
used
in
this
assessment
of
1500
cm2/
hr
was
reduced
in
this
assessment
from
a
value
of
3000
cm2/
hr.
This
modification
was
discussed
at
the
Agency's
Science
Advisory
Council
For
Exposure
(
i.
e.,
EXPOSAC)
and
has
been
permanently
incorporated
into
its
Policy
003
for
agricultural
transfer
coefficients.
This
modification
was
made
by
considering
the
results
of
six
different
tree
harvester
studies
conducted/
owned
by
the
Agricultural
Reentry
Task
Force,
two
of
which
evaluated
exposure
to
thiram.
A
range
of
crops
was
represented
in
these
data
including
pome
fruit
(
apples),
stone
fruit
(
peaches),
and
citrus.
Other
chemistries
which
were
considered
include:
an
organophosphate
insecticide,
a
pyrethroid
insecticide,
and
a
fungicide.


The
only
available
residue
dissipation
study
was
for
foliar
dislodgeable
residues
on
strawberries
(
MRID
45560301).
These
data
were
used
to
complete
the
assessments
for
all
crops
(
including
for
the
repellent
uses
which
are
considered
to
be
rangefinder
by
nature).
The
Agency
used
the
residue
decay
rates
from
this
study
in
the
turf
assessment.
For
the
repellent
uses,
label
rates
were
indeterminate
if
normalized
by
area
so
the
Agency
used
the
same
DFR
concentrations
that
were
used
for
apples
which
are
thought
to
be
a
reasonable
approximation
for
the
repellent
use.
As
such,
the
nursery
assessment
should
be
considered
as
rangefinder
in
nature.


A
pseudo­
first
order
kinetics
analysis
was
used
to
analyze
thiram
residue
dissipation
over
time
as
outlined
in
the
Agency's
draft
Series
875
Postapplication
Exposure
Monitoring
Guidelines.
A
more
sophisticated
curvefitting
approach
was
not
warranted
because
the
correlation
coefficients
in
the
analysis
were
appropriate
and
the
data
have
been
used
generically
to
extrapolate
to
a
variety
of
other
crops
where
decay
rates
and
mechanisms
may
differ
(
i.
e.,
any
sophistication
gained
with
a
curve
fitting
technique
would
be
lost
in
an
extrapolation
to
another
crop).


When
the
Agency
extrapolated
the
available
DFR
data
to
other
crops,
it
adjusted
the
data
for
differences
in
application
rate
using
a
simple
proportional
approach.
This
approach
seems
to
be
the
most
appropriate
given
the
data
which
are
49
available.
This
approach
is
commonly
used
in
Agency
postapplication
risk
assessments.
When
the
Agency
defined
the
TTR
concentrations
for
turf,
the
Agency
standard
value
of
5
percent
of
the
application
rate
was
used
to
determine
the
initial
concentrations
and
then
the
decay
rate
functions
specific
to
the
strawberry
study
(
at
both
locations)
were
used
to
determine
TTR
residues
over
time.

5.2.4
Occupational
Postapplication
Noncancer
Risks
Short­
term
risks
were
calculated
for
different
crop
groups
as
described
above.
Table
12
below
provides
a
summary
of
these
risks
for
each
crop/
activity
combination
considered.
For
each
crop
group/
activity
combination,
the
MOEs
on
the
day
of
application
and
at
the
current
REI
of
24
hours
are
presented
(
i.
e.,
the
Day
1
MOE).
The
number
of
days
required
for
MOEs
to
reach
the
Agency's
uncertainty
factor
of
100
is
also
presented.
The
uncertainty
factor
is
100
for
these
scenarios.

Table
12:
Summary
of
Thiram
Postapplication
Worker
Risks
(
MOEs)

Crop
Group
Appl.
Rate
(
lb
ai/
A)
Region
Result
Type
Exposure
Descriptor
(
See
Appendix
D)

Very
Low
Low
Medium
High
Very
High
Low
Berry
(
Strawberry)
3.3
West
(
CA
DFRs)
Day
0
MOE
NA
535
NA
143
NA
Day
1
MOE
(
cur.
REI)
NA
594
NA
158
NA
Days
At
MOE
>
UF
NA
0
NA
0
NA
3.3
East
(
FL
DFRs)
Day
0
MOE
NA
477
NA
127
NA
Day
1
MOE
(
cur.
REI)
NA
554
NA
148
NA
Days
At
MOE
>
UF
NA
0
NA
0
NA
Decid.
Fruit
Trees
(
Apples)
4.5
West
(
CA
DFRs)
Day
0
MOE
1571
157
NA
105
52
Day
1
MOE
(
cur.
REI)
1742
174
NA
116
58
Days
At
MOE
>
UF
0
0
NA
0
7
4.5
East
(
FL
DFRs)
Day
0
MOE
1400
140
NA
93
47
Day
1
MOE
(
cur.
REI)
1625
163
NA
180
54
Days
At
MOE
>
UF
0
0
NA
1
6
Decid.
Fruit
Trees
(
Peaches)
2.6
West
(
CA
DFRs)
Day
0
MOE
2718
272
NA
181
91
Day
1
MOE
(
cur.
REI)
3015
302
NA
201
101
Days
At
MOE
>
UF
0
0
NA
0
1
2.6
East
(
FL
DFRs)
Day
0
MOE
2423
242
NA
162
81
Day
1
MOE
(
cur.
REI)
2812
281
NA
188
94
Days
At
MOE
>
UF
0
0
NA
0
2
Turf/
Sod
(
Lower
rate)
16.3
West
(
CA
DFRs)
Day
0
MOE
NA
574
NA
17
NA
Day
1
MOE
(
cur.
REI)
NA
637
NA
19
NA
Table
12:
Summary
of
Thiram
Postapplication
Worker
Risks
(
MOEs)

Crop
Group
Appl.
Rate
(
lb
ai/
A)
Region
Result
Type
Exposure
Descriptor
(
See
Appendix
D)

Very
Low
Low
Medium
High
Very
High
50
Days
At
MOE
>
UF
NA
0
NA
17
NA
16.3
East
(
FL
DFRs)
Day
0
MOE
NA
559
NA
17
NA
Day
1
MOE
(
cur.
REI)
NA
648
NA
20
NA
Days
At
MOE
>
UF
NA
0
NA
12
NA
Turf/
Sod
(
Higher
rate)
24.5
West
(
CA
DFRs)
Day
0
MOE
NA
383
NA
12
NA
Day
1
MOE
(
cur.
REI)
NA
425
NA
13
NA
Days
At
MOE
>
UF
NA
0
NA
21
NA
24.5
East
(
FL
DFRs)
Day
0
MOE
NA
383
NA
12
NA
Day
1
MOE
(
cur.
REI)
NA
445
NA
14
NA
Days
At
MOE
>
UF
NA
0
NA
15
NA
Nursery/
Ornamentals
4.5
West
(
CA
DFRs)
Day
0
MOE
NA
1428
NA
393
NA
Day
1
MOE
(
cur.
REI)
NA
1584
NA
436
NA
Days
At
MOE
>
UF
NA
0
NA
0
NA
4.5
East
(
FL
DFRs)
Day
0
MOE
NA
1273
NA
350
NA
Day
1
MOE
(
cur.
REI)
NA
1477
NA
406
NA
Days
At
MOE
>
UF
NA
0
NA
0
NA
NA
=
Exposure
descriptor
not
applicable
for
that
crop
group.
UF
=
uncertainty
factor
or
target
MOE
of
100.
Days
that
exceed
the
current
REI
are
highlighted
with
bolding.

Current
label
requirements
specify
24
hour
REIs.
For
all
but
the
highest
exposure
scenarios,
risks
are
not
of
concern
(
i.
e.,
MOEs>
100)
at
the
current
REI.
The
high
exposure
tasks
that
are
of
concern
include
apple
thinning
(
MOEs
>
100
at
6­
7
days),
peach
thinning
on
the
east
coast
(
MOE>
100
at
2
days),
and
high
contact
turf
activities
(
MOEs>
100
at
12­
21
days).
The
uncertainties
associated
with
this
assessment
should
also
be
considered
including
strawberry
data
were
used
for
all
assessments,
the
repellency
use
pattern
is
not
well
defined,
and
no
turf
specific
data
were
available.

5.2.5
Occupational
Risk
Characterization
Characterization
of
the
occupational
risks
is
included
below
for
both
handlers
and
for
postapplication
exposures.

5.2.5.1
Occupational
Handler
Risk
Characterization
The
hazard
and
exposure
databases
for
thiram
indicate
that
short­
term
and
intermediate­
term
calculations
would
provide
identical
results
because
the
inputs
51
are
the
same
for
both.
The
occupational
handler
assessment
for
thiram
is
complex
in
that
the
Agency
identified
exposures
that
fit
into
28
different
scenarios
which
are
defined
based
on
the
equipment
used
to
make
applications,
treat
seed,
or
the
type
of
formulation
used.
Within
each
of
these
categories,
different
application
rates,
amount
of
seed
treated,
and
acres
treated
values
were
considered
to
evaluate
the
broad
range
of
applications
that
may
occur
with
each
kind
of
equipment
(
e.
g.,
a
groundboom
may
be
used
for
turf
or
agriculture).
All
totaled,
347
different
crop/
rate/
acres
combinations
were
considered
within
the
28
scenarios.
It
should
be
noted
that
each
calculation
was
completed
at
different
levels
of
personal
protection
to
allow
for
a
more
informed
risk
management
decision.

The
data
that
were
used
in
the
thiram
occupational
handler
risk
assessment
represent
the
best
data
and
approaches
that
are
currently
available.
While
some
of
the
data
which
have
been
used
may
not
be
of
optimal
quality,
they
represent
the
best
available
data
for
the
scenario
in
question.
In
many
cases,
the
Pesticide
Handlers
Exposure
Database
(
PHED)
was
used
to
develop
the
unit
exposure
values.
The
quality
of
the
data
included
in
PHED
vary
widely
from
scenarios
that
meet
guideline
requirements
for
studies
to
others
where
a
limited
number
of
poor
quality
datapoints
are
available.
The
results
for
each
scenario
should
be
reviewed
in
the
context
of
the
quality
of
these
data.
In
addition
to
PHED,
the
Agency
used
a
number
of
studies
to
define
unit
exposure
values.
Generally,
the
quality
of
these
studies
is
adequate
for
risk
assessment
purposes.
PHED
unit
exposure
values
represent
a
central
tendency
of
the
data
(
i.
e.,
geometric
mean,
median
or
arithmetic
mean
depending
upon
the
distribution
of
the
data).
As
such,
the
values
based
on
the
recent
studies
also
are
measures
of
central
tendency
(
i.
e.,
distributional
analyses
were
completed
and
the
proper
statistical
measure
selected).
Along
with
the
unit
exposure
values
used
in
the
assessment,
other
inputs
include
application
rates
and
daily
acres/
seed
treated
values.
Selected
application
rates
represent
a
range
for
each
major
market
in
which
thiram
is
used.
Where
available,
average
use
rates
were
also
used
to
provide
for
a
more
informed
risk
management
decision.
The
application
rates
that
were
selected
for
use
in
the
risk
assessment
were
defined
based
on
labels,
information
provided
by
the
UCB
Chemicals
Corporation
at
the
SMART
Meeting
for
thiram,
comments
provided
by
the
thiram
task
force,
a
Doane
survey
of
seed
treaters
specific
for
thiram,
and
the
use
closure
memo.
The
other
key
input
for
completing
handler
risk
assessments
used
for
defining
how
much
chemical
can
be
used
in
a
day
is
how
much
can
be
treated
in
a
day
which
is
generally
expressed
as
the
number
of
acres
treated
per
day
or
the
amount
of
seed
treated
in
a
day.
The
values
that
were
used
for
this
parameter
represent
the
latest
Agency
thinking
on
this
issue.
In
fact,
the
Science
Advisory
Council
For
Exposure
recently
updated
the
policy
for
these
inputs
(
July
2000
Exposure
SAC
Policy
9:
Standard
Values
for
Daily
Acres
Treated
in
Agriculture).
These
values
have
been
used
for
the
calculations.
Additionally,
data
from
the
thiram
task
force,
the
thiram­
specific
use
survey
completed
by
Doane,
and
Gustafson
(
which
manufacturers
a
large
majority
of
seed
treatment
equipment)
were
used
to
develop
the
values
which
52
quantified
the
amount
of
seed
treated
per
day.

In
addition
to
the
key
sources
of
information
considered
above,
there
are
many
underlying
factors
that
may
impact
the
overall
results
of
a
risk
assessment.
For
example,
the
protection
factors
used
for
adding
additional
levels
of
dermal
and
respiratory
protection
may
impact
the
overall
risk
picture.
The
factors
used
in
this
assessment
by
the
Agency
are
the
ones
that
have
been
used
for
several
years.
Other
such
factors
may
include
the
fact
that
average
application
rates
have
been
generally
used
to
represent
typical
application
rates
to
calculate
ranges
of
risks
when
it
is
clear
that
the
two
values
could
differ
greatly.
The
Agency
has
taken
this
approach
because
the
data
required
to
define
typical
application
rates
within
each
crop
are
generally
unavailable.
There
are
also
exposure
monitoring
issues
that
should
be
considered.
For
example,
in
many
cases
the
data
included
in
PHED
are
based
on
the
use
of
cotton
gloves
for
hand
exposure
monitoring
which
are
thought
by
many
to
overestimate
exposure
because
they
potentially
retain
residues
more
than
human
skin
would
over
time
(
i.
e.,
they
may
act
like
a
sponge
compared
to
the
actual
hand).
These
intangible
elements
of
the
risk
assessment
reflect
many
of
the
hidden
uncertainties
associated
with
exposure
data.
The
overall
impacts
of
these
uncertainties
is
hard
to
quantify.
The
factor
to
again
consider
is
that
the
Agency
used
the
best
available
data
to
complete
the
risk
assessment
for
thiram.

In
summary,
the
Agency
believes
that
the
risk
values
presented
in
this
occupational
assessment
represent
the
highest
quality
results
that
could
be
produced
given
the
exposure,
use,
and
toxicology
data
that
are
available.
Certainly
risk
managers
and
other
interested
parties
should
consider
the
quality
of
individual
inputs
when
interpreting
the
results
and
make
decisions
accordingly.
It
is
difficult
to
ascertain
where
on
a
distribution
the
values
which
have
been
calculated
fall
because
the
distributional
data
for
exposure,
application
rates,
acres
treated
and
many
other
parameters
are
unrefined.
The
Agency
does
believe,
however,
that
the
risks
represent
conservative
estimates
of
exposure
because
maximum
application
rates
are
coupled
with
large
acreage
estimates
to
define
risk
estimates
that
likely
fall
in
the
upper
percentiles
of
the
actual
exposure
distributions.
Additionally,
risk
estimates
are
thought
to
be
conservative
even
when
measures
of
central
tendency
are
combined
because
values
that
would
be
considered
to
be
in
the
lower
percentile
aspect
of
any
input
parameter
have
not
been
used
in
the
calculations.

5.2.5.2
Occupational
Postapplication
Risk
Characterization
The
Agency
identified
exposures
that
fit
into
4
different
crop
groups
which
are
defined
essentially
based
on
the
nature
of
the
crop
where
a
work
activity
would
take
place.
Within
each
of
these
crop
groups,
ranges
of
transfer
coefficients
were
considered
to
reflect
differences
in
exposures
that
would
be
associated
with
the
variety
of
cultural
practices
that
are
required
to
produce
the
crop/
product.
All
totaled,
10
different
cultural
practices
were
considered
within
the
4
crop
53
groups.
It
should
also
be
noted
that
each
calculation
was
completed
at
different
days
after
application
to
reflect
residue
dissipation
over
time
in
the
environment
and
to
allow
for
a
more
informed
risk
management
decision.

The
data
that
were
used
in
the
thiram
postapplication
worker
risk
assessment
represent
the
best
data
and
approaches
that
are
currently
available.
The
latest
Agency
transfer
coefficient
values
have
been
used
to
complete
this
assessment
including
the
recently
submitted
ARTF
studies
on
greenhouse
workers.
Most
of
the
values
in
the
current
Agency
policy
are
based
on
the
work
of
the
Agricultural
Reentry
Task
Force
(
ARTF)
of
which,
UCB
Chemicals
is
a
member.
The
current
Agency
policy
is
interim
in
nature
but
represents
all
of
the
data
that
have
been
submitted
by
the
ARTF
and
evaluated
by
the
Agency.
The
work
of
the
ARTF
is
still
ongoing
so
additional
data
may
become
available
to
refine
the
exposure
estimates
as
more
data
are
submitted
to
the
Agency.
In
addition
to
the
exposure
inputs
for
specific
activities
(
i.
e.,
transfer
coefficients),
the
Agency
used
a
thiram­
specific
DFR
(
Dislodgeable
Foliar
Residue)
dissipation
study
to
calculate
risks
for
all
postapplication
workers
in
every
region
in
the
country.
It
is
standard
practice
for
the
Agency
to
use
these
kinds
of
studies
in
this
manner
but
it
is
likely
that
additional
crop­
and
region­
specific
data
could
be
used
to
further
refine
the
risk
assessment.

In
addition
to
the
key
sources
of
information
considered
above,
there
are
many
underlying
factors
that
may
impact
the
overall
results
of
a
risk
assessment.
For
example,
subtle
differences
between
activities
in
similar
crops
within
each
of
the
4
agronomic
groups
considered
in
the
assessment
may
not
be
accurately
reflected
in
the
current
transfer
coefficient
values.
The
use
of
a
single
DFR
study
to
represent
all
crops
and
all
regions
within
the
country
could
lead
to
results
that
do
not
reflect
actual
use
practices
and
conditions.
As
with
the
handler
assessment
above,
the
intangible
elements
reflect
many
of
the
hidden
uncertainties
associated
with
exposure
data.
The
overall
impacts
of
these
uncertainties
is
hard
to
quantify.
The
factor
to
again
consider
is
that
the
Agency
used
the
best
available
data
to
complete
the
risk
assessment
for
thiram.

In
summary,
the
Agency
believes
that
the
risk
values
presented
in
this
postapplication
assessment
represent
the
highest
quality
results
that
could
be
produced
given
the
exposure,
use,
and
toxicology
data
that
are
available.
Certainly
risk
managers
and
other
interested
parties
should
consider
the
quality
of
individual
inputs
when
interpreting
the
results
and
make
decisions
accordingly.
It
is
difficult
to
ascertain
where
on
a
distribution
the
values
which
have
been
calculated
fall
because
the
distributional
data
for
exposure,
residue
dissipation
and
many
other
parameters
are
unrefined.
The
Agency
does
believe,
however,
that
the
risks
represent
conservative
estimates
of
exposure
because
maximum
application
rates
are
used
to
define
residue
levels
upon
which
the
risk
calculations
are
based.
Additionally,
risk
estimates
are
thought
to
be
1
Refer
to
Hazard
Characterization
section
of
this
document
for
further
information
regarding
thiram
and
potential
alcohol
intolerance.

54
conservative
even
when
measures
of
central
tendency
(
e.
g.,
most
transfer
coefficients
are
thought
to
be
central
tendency)
are
used
because
values
that
would
be
considered
to
be
in
the
lower
percentile
aspect
of
any
input
parameter
have
not
been
used
in
the
calculations.

5.3
Incident
Report
There
were
17
cases
reported
from
the
Incident
Data
System
since
1992.
Although
all
of
the
reported
cases
occurred
since
1995,
approximately
half
of
these
cases
(
8
of
17)
were
reported
in
1998.
Three
of
the
cases
reported
affected
adults
following
the
occupational
handling
or
cleanup
of
thiram
products.
Thirteen
of
the
cases
reported
affected
the
general
public
(
3
children
and
10
adults)
following
the
non­
occupational
handling
of
thiram
products.
One
serious
incident
(
a
seizure
episode)
occurred
following
the
use
of
thiram
after
2
beers
had
been
consumed
the
evening
prior
to
exposure.
It
was
unclear
if
this
was
an
occupational
or
non­
occupational
incident.
1
Recorded
dermal
effects
for
the
reported
cases
were
skin
rashes,
skin
reddening,
itching
and
tingling
of
the
hands,
thickened
skin
on
the
palms
and
blisters
under
the
skin,
small
bumps
on
the
hands
and
other
parts
of
the
body,
and
burning
and
redness
on
the
face.
One
case
recorded
a
dry
cough
following
an
inhalation
exposure
while
a
splash
incident
to
the
face
resulted
in
burning
of
the
eyes.

During
the
period
1982­
1996,
15
cases
involving
the
sole
use
of
thiram
were
reported.
Thiram
ranked
122nd
as
a
cause
of
systemic
poisoning
in
California.
A
total
of
4
persons
had
systemic
illnesses
from
thiram
exposure,
4
experienced
eye
illnesses,
6
experienced
skin
illnesses,
and
1
person
experienced
a
combination
of
these
illnesses.
Of
the
15
cases,
two
persons
were
disabled
for
one
day.
The
15
persons
were
exposed
to
thiram
in
the
following
manner:
8
of
the
persons
affected
were
applicators;
1
was
cleaning
or
repairing
pesticide
contaminated
equipment;
1
experienced
exposure
coincidentally;
2
were
exposed
during
the
shipping,
warehousing
or
retailing
of
thiram;
2
were
packing,
processing
or
retailing
thiram;
and
1
worker
was
exposed
to
thiram
residue
which
was
neither
agricultural
or
structural.
According
to
these
statistics,
applicators'
exposures
accounted
for
the
majority
of
the
recorded
illnesses.
The
illnesses
included
symptoms
of
rashes,
dermatitis,
and
itchy,
watery
or
burning
eyes.

On
the
list
of
the
top
200
chemicals
for
which
NPTN
received
calls
from
1984­
1991
inclusively,
thiram
ranked
number
101
and
was
reported
to
be
involved
in
33
human
incidents
and
6
animal
incidents
(
mostly
pets).

For
further
details
on
the
incident
reports
refer
to
the
Review
of
Incident
Reports
(
J.
Blondell
and
M.
Spann
memorandum;
3/
30/
00;
Appendix
XII).
55
5.4
Additional
Data
Requested
Several
areas
of
the
risk
assessment
and
characterization
would
improve
with
more
data.
Areas
of
data
needs
include:

°
Chemical­
specific
exposure
studies
for
occupational
and
non­
occupational
exposures.
The
Agency
encourages
submission
of
occupational
handler
exposure
monitoring
studies.
In
particular,
the
data
and
information
currently
available
related
to
both
onfarm
and
commercial
seed
treatment
are
extremely
limited
(
see
below).
A
realistic,
representative
sampling
of
these
methods
needs
to
be
evaluated.
In
addition,
postapplication
residue
studies
for
commercially
or
on­
farm
treated
seeds
which
have
been
bagged
and
transported
and/
or
stored
on­
farm
for
a
period
of
time
would
improve
the
risk
assessment
for
planting
of
seeds
which
have
been
previously
treated.


Chemical­
specific
DFR
and
TTR
studies
are
also
encouraged
for
apples,
peaches,
strawberries
and
turfgrass.
Additional
data
and/
or
foliar
and
soil
studies
are
needed
to
evaluate
animal
repellency
applications
to
ornamentals
(
e.
g.,
trees,
shrubs,
vines)
in
nonoccupational
settings
(
e.
g.,
residences,
golf
courses,
parks,
athletic
fields).
Evaluation
of
the
registrant's
recommendation
to
add
latex
based
sticker
to
thiram
products
during
animal
repellency
applications
is
also
needed.
[
Please
note
that
the
current
product
labels
claim
the
addition
of
a
latex
based
sticker
extends
the
efficacy
of
thiram
to
3­
6
months
for
animal
repellency.]
All
exposure
monitoring
and
transferable
residue
studies
should
be
conducted
according
to
Agency
protocols,
and
the
Agency
would
welcome
involvement
in
the
planning
process/
protocol
review
of
future
studies.


Specific
data
on
typical
and
agreed­
upon
maximum
use
rates,
types
of
mixing
and
loading
completed
for
each
specific
application
equipment,
types
of
potential
product
packaging
available
to
individual
and
professional
pesticide
applicators,
types
of
potential
engineering
controls,
and
information
on
post­
application
techniques
and
activities
for
all
crops
(
particularly
relating
to
harvesting
methods
and
related
hand
activities).

In
addition,
specific
data
gaps
have
been
identified
for
the
following
individual
and
professional
pesticide
applicator
scenarios:

(
1i)
mixing/
loading
dry
flowable
for
in­
furrow
application
­­
coniferous
seed
(
3h)
mixing/
loading
wettable
powder
for
in­
furrow
application
­­
coniferous
seed
(
4d)
mixing/
loading
liquids
for
dip
tank
application
­­
ornamental
bulbs
(
4f)
mixing/
loading
liquids
for
in­
furrow
application
­­
coniferous
seed
(
4g)
mixing/
loading
liquids
for
on­
farm
seed
treatment
­­
coniferous
and
ornamental
flower
seed
(
14)
applying
liquids
for
dip
tank
application
­­
ornamental
bulbs
(
15)
applying
liquids
in­
furrow
to
soil
(
groundboom
surrogate)
­­
coniferous
seed
(
21)
mixing/
loading/
applying
as
a
seed
treatment
in
planter
box
(
Fenske
study)
­­
ornamental
flower
56
(
22)
loading/
applying
granules
by
hand
(
surrogate
for
planting
treated
seeds
by
hand)
­­
coniferous
and
ornamental
flower
seed
Numerous
methods
can
be
used
to
treat
seeds
both
commercially
and
on­
farm.
On­
farm
seed
treatment
methods
include:
by
hand,
concrete
tumbler,
drill
box,
duster,
in­
furrow,
mist­
type
seed
treater,
planter/
seed
box,
paper
bag,
seed
treater,
shaker
can,
slurry­
type
seed
treater
as
well
as
specific
systems
manufactured
by
Gustafson
(
Farmer
Applied
Seed
Treater
[
FAST],
Micromatic
Air
Pressure
System,
Total
Slurry
Treater
with
SHURflo
Pump,
Gustafson
SS­
LA,
SS­
LAD,
S­
100,
S­
100
LAD,
and
Batch
Lab
Treater,
CF­
80).
Commercial
seed
treatment
equipment
produced
by
Gustafson
include:
Computerized
Seed
and
Chemical
Proportioner,
Gustafson
Accu­
Treat
Treater,
Gustafson
S­
Series
and
SS­
Series,
Gustafson
SS­
AMP
Treater,
and
Triple
Treat
Seed
Treater.
Gustafson
also
manufactures
Premix
Tanks
and
Pumping
Systems­­
PSD
Series
and
P4
Premix
Tank
and
Blending
Chambers
­­
Hex
Polishing
Drums,
Coating
Chambers.
Clearly,
additional
information
and
exposure
monitoring
data
are
needed
to
assess
both
on­
farm
and
commercial
seed
treatment
methods
appropriately.

Thiram
was
amongst
the
chemicals
subject
to
the
Data
Call­
In
Notice
dated
3/
5/
95
(
OREDCI).
The
OREDCI
required
data
necessary
to
estimate
exposure
to
pesticide
products
used
on
home
or
residential
lawn
and
grass.
The
registrant,
Gustafson,
Inc.,
requested
and
was
granted
a
data
waiver
since
the
labels
containing
this
active
ingredient
(
thiram)
indicate
that
use
on
lawn
or
turf
settings
is
not
permitted.
This
waiver,
however,
does
not
preclude
the
Agency
from
requiring
exposure
data,
including
guidelines
875.2100,
875.2400,
875.2500,
875.1100
or
875.1300
to
support
the
continued
registration
or
reregistration
of
this
product
for
use
on
other
sites
(
T.
F.
Moriarty
Memorandum;
3/
24/
97;
Appendix
XIII).

6.0
AGGREGATE
EXPOSURE
AND
RISK
ASSESSMENT
In
examining
aggregate
exposure,
FQPA
directs
EPA
to
take
into
account
available
information
concerning
exposures
from
pesticide
residues
in
food
and
other
exposures
for
which
there
is
reliable
information.
These
other
exposures
include
drinking
water
and
non­
occupational
exposures,
e.
g.,
to
pesticides
used
in
and
around
the
home.
Risk
assessments
for
aggregate
exposure
consider
both
short­,
intermediate­
and
long­
term
(
chronic)
exposure
scenarios
considering
the
toxic
effects
which
would
likely
be
seen
for
each
exposure
duration.

Thiram
is
a
food
use
chemical.
Drinking
Water
Levels
of
Comparison
(
DWLOC)
have
been
calculated
for
thiram.
There
are
residential
(
non­
occupational)
uses
of
thiram;
therefore,
the
considerations
for
aggregate
exposure
are
those
from
food,
drinking
water
and
residential
exposure.

Drinking
Water
Levels
of
Comparison
(
DWLOCs)

A
Drinking
Water
Level
of
Comparison
(
DWLOC)
is
a
theoretical
upper
limit
on
a
pesticide's
concentration
in
drinking
water
in
light
of
total
aggregate
exposure
to
a
pesticide
in
food,
drinking
water,
and
through
residential
uses.
A
DWLOC
will
vary
depending
on
the
toxic
endpoint,
with
drinking
water
consumption,
and
body
weights.
Different
populations
will
have
different
DWLOCs.
57
HED
uses
DWLOCs
internally
in
the
risk
assessment
process
as
a
surrogate
measure
of
potential
exposure
associated
with
pesticide
exposure
through
drinking
water.
In
the
absence
of
monitoring
data
for
pesticides,
it
is
used
as
a
point
of
comparison
against
conservative
model
estimates
of
a
pesticide's
concentration
in
water.
DWLOCs
are
not
regulatory
standards
for
drinking
water;
however,
they
do
have
an
indirect
regulatory
impact
through
aggregate
exposure
and
risk
assessments.
DWLOCs
for
thiram
were
calculated
using
the
dietary
food
exposure
and
default
body
weight
and
water
consumption
figures.
For
adult
males,
the
default
body
weight
is
70
kg,
and
water
consumption
is
2
L;
for
females,
the
body
weight
default
is
60
kg
with
a
2
L
water
consumption
default;
and
for
infants
and
children,
the
defaults
are
set
at
10
kg
for
body
weight
and
1
L
for
water
consumption.

DWLOC(

g/
L)
=
[
maximum
water
exposure
(
mg/
kg/
day)
x
body
weight
(
kg)]
[
water
consumption
(
L)
x
10­
3
mg/

g]

where
maximum
water
exposure
(
mg/
kg/
day)
=
Target
Maximum
Exposure
­
(
Food
Exposure
+
Residential
Exposure)

6.1
Acute
Aggregate
Exposure
and
Risk
Since
the
estimated
exposures
to
thiram
in
food
alone
exceed
HED's
levels
of
concern,
any
exposure
in
drinking
water
would
only
add
to
a
dietary
exposure
that
already
exceeds
HED's
levels
of
concern.
Effectively,
the
DWLOC
for
the
acute
dietary
risk
estimates
are
zero
until
dietary
exposure
estimates
can
be
refined
and
the
dietary
risk
estimates
reduced.
Therefore,
an
acute
DWLOC
was
not
calculated
for
these
groups.
However,
as
a
tool
for
the
risk
managers,
a
DWLOC
calculation
was
done
assuming
no
exposure
from
food.
Comparisons
between
the
DWLOC
and
the
highest
EECs
of
47.8
ppb
(
in
surface
water)
and
0.84
ppb
(
in
groundwater)
indicate
that
drinking
water
alone
does
not
exceed
the
Agency's
level
of
concern
(
Table
13).

Table
13.
Acute
DWLOC
Comparison
Population
Groups
aPAD
(
mg/
kg/
day)
Maximum
Allowable
Drinking
Water
Exposure
(
mg/
kg/
day)
DWLOCacute
(

g/
L)
PRZM/
EXAMS
Peak
EECs
(
ppb)
SCIGROW
concentration
(
ppb)

U.
S.
General
Population
0.05
0.05
1750
47.8
0.84
Females
13­
49
0.05
0.05
1500
47.8
0.84
Infants
and
Children
0.05
0.05
500
47.8
0.84
6.2
Short/
Intermediate
Term
Aggregate
Exposure
and
Risk
DWLOCs
were
calculated
for
adults
who
golf
after
application
of
thiram
to
turf.
These
calculations
were
done
using
the
lower
bound
application
rate
of
16.3
lb
ai/
A.
A
short/
intermediate
term
aggregate
risk
for
children
and
adults
using
the
highest
application
rate
of
24.5
lbs
ai/
A
have
not
been
calculated
since
the
MOEs
derived
from
the
residential/
recreational
risk
assessment
alone
exceed
the
58
Agency's
level
of
concern.
Consequently
any
aggregation
would
only
serve
to
increase
the
reported
risk.
Short­
term
DWLOCs
were
calculated
based
upon
average
food
residues
and
residential
postapplication
exposure.

Surface
and
ground
water
concentrations
estimated
using
modeling
are
at
or
below
the
short­
term
DWLOC
for
thiram
(
Table
14).
Consequently,
there
is
no
short­
term
exposure
concern
for
drinking
water
from
groundwater
or
surface
water
sources.

Table
14.
Short­
Term
Aggregate
Risk
and
DWLOC
Calculations
(
Inhalation/
Dermal
Endpoints
and
NOAELs
the
Same)

Population
Short
­
Term
Scenario
NOAEL
mg/
kg/
day
Target
MOE1
Max
Exposure2
mg/
kg/
day
Average
Food
Exposure
mg/
kg/
day
Residential
Exposure3
mg/
kg/
day
Aggregate
MOE
(
food
and
residential)
4
Max
Water
Exposure5
mg/
kg/
day
Surface
Water
EEC6
(
ppb)
Ground
Water
EEC6
(
ppb)
Short­
Term
DWLOC7
(

g/
L)

Adult
Male
1.5
1000
0.0015
0.0.000121
0.001307
1050
0.00007
2.50
0.84
2.52
Adult
Female
1.5
1000
0.0015
0.000095
0.001307
1050
0.00007
2.50
0.84
2.16
1
Short­
term
dermal
and
inhalation
NOAEL
=
30
from
a
developmental
rabbit
study.
2
Maximum
Exposure
(
mg/
kg/
day)
=
NOAEL/
Target
MOE
3
Residential
Exposure
=
[
Oral
exposure
+
Dermal
exposure
+
Inhalation
Exposure]
4
Aggregate
MOE
=
[
NOAEL
÷
(
Avg
Food
Exposure
+
Residential
Exposure)]
5
Maximum
Water
Exposure
(
mg/
kg/
day)
=
Target
Maximum
Exposure
­
(
Food
Exposure
+
Residential
Exposure)
6
The
crop
producing
the
highest
level
was
used.
7
DWLOC(

g/
L)
=
[
maximum
water
exposure
(
mg/
kg/
day)
x
body
weight
(
kg)]
[
water
consumption
(
L)
x
10­
3
mg/

g]

6.3
Chronic
Aggregate
Risk
Chronic
DWLOCs
for
thiram
were
calculated
using
the
chronic
dietary
food
exposure
and
default
body
weight
and
water
consumption
figures.
Comparisons
between
the
DWLOCs
and
the
highest
EECs
of
2.5
ppb(
in
surface
water)
and
0.84
ppb
(
in
groundwater)
indicate
that
the
level
of
concern
for
thiram
residues
in
drinking
water
has
not
been
exceeded
when
assessing
chronic
dietary
risk
(
Table
15).
DWLOC
calculations
were
performed
for
the
infant
or
children
subgroup
which
had
the
highest
exposure.

Table
15.
Chronic
DWLOCs
Comparison
Population
Groups
Chronic
Drinking
Water
Exposure
Dietary
Exposure
from
DEEM
analysis
(
mg/
kg/
day)
cPAD
(
mg/
kg/
day)
Maximum
Allowable
Drinking
Water
Exposure
(
mg/
kg/
day)
DWLOCchronic
PRZM/
EXAMS
365
day
EECs
(
ppb)
SCIGROW
concentration
(
ppb)

U.
S.
General
Population
0.00012
0.0015
0.0014
48.30
2.5
0.84
Females
(
13­
49
years)
0.000095
0.0015
0.0014
42.15
2.5
0.84
Population
Groups
Chronic
Drinking
Water
Exposure
Dietary
Exposure
from
DEEM
analysis
(
mg/
kg/
day)
cPAD
(
mg/
kg/
day)
Maximum
Allowable
Drinking
Water
Exposure
(
mg/
kg/
day)
DWLOCchronic
PRZM/
EXAMS
365
day
EECs
(
ppb)
SCIGROW
concentration
(
ppb)

59
Children
(
1­
2
years)
0.00042
0.0015
0.0011
10.80
2.5
0.84
7.0
CUMULATIVE
EXPOSURE
AND
RISK
ASSESSMENT
Section
408(
b)(
2)(
D)(
v)
of
the
FFDCA
requires
that,
when
considering
whether
to
establish,
modify,
or
revoke
a
tolerance,
the
Agency
consider
"
available
information"
concerning
the
cumulative
effects
of
a
particular
pesticide's
residues
and
"
other
substances
that
have
a
common
mechanism
of
toxicity."

EPA
does
not
have,
at
this
time,
available
data
to
determine
whether
thiram
has
a
common
mechanism
of
toxicity
with
other
substances.
Unlike
other
pesticides
for
which
EPA
has
followed
a
cumulative
risk
approach
based
on
a
common
mechanism
of
toxicity,
EPA
has
not
made
a
common
mechanism
of
toxicity
finding
as
to
thiram
and
any
other
substances
and
thiram
does
not
appear
to
produce
a
toxic
metabolite
produced
by
other
substances.
For
the
purposes
of
this
tolerance
action,
therefore,
EPA
has
not
assumed
that
thiram
has
a
common
mechanism
of
toxicity
with
other
substances.
For
information
regarding
EPA's
efforts
to
determine
which
chemicals
have
a
common
mechanism
of
toxicity
and
to
evaluate
the
cumulative
effects
of
such
chemicals,
see
the
policy
statements
released
by
EPA's
Office
of
Pesticide
Programs
concerning
common
mechanism
determinations
and
procedures
for
cumulating
effects
from
substances
found
to
have
a
common
mechanism
on
EPA's
website
at
http://
www.
epa.
gov/
pesticides/
cumulative/.

8.0
ENDOCRINE
DISRUPTORS
EPA
is
required
to
develop
a
screening
program
to
determine
whether
certain
substances
(
including
all
pesticides
and
inerts)
"
may
have
an
effect
in
humans
that
is
similar
to
an
effect
produced
by
a
naturally
occurring
estrogen,
or
such
other
endocrine
effect..."
The
Agency
is
currently
working
with
interested
stakeholders,
including
other
government
agencies,
public
interest
groups,
industry
and
research
scientists
in
developing
a
screening
and
testing
program
and
a
priority
setting
scheme
to
implement
this
program.
Upon
development,
the
Agency
will
implement
this
program.
At
that
time,
EPA
may
require
further
testing
of
thiram
for
endocrine
effects.

9.0
DATA
NEEDS
9.1
Toxicology
Data
Needs
870.6300
Developmental
Neurotoxicity
Study
Cholinesterase
Activity
Assessment
Screening
Assay
9.2
Product
Chemistry
Data
Needs
830.1550
Product
identity
and
composition
$
Prochimie
98.5%
T
830.1600
Description
of
materials
used
to
produce
the
product
60
$
Prochimie
98.5%
T
830.1620
Description
of
production
process
$
Prochimie
98.5%
T
830.1670
Discussion
of
formation
of
impurities
$
Prochimie
98.5%
T
61
830.1700
Preliminary
analysis
$
Prochimie
98.5%
T
830.1750
Certified
limits
$
Prochimie
98.5%
T
830.1800
Enforcement
analytical
method
$
Prochimie
98.5%
T
830.6302
Color
$
Prochimie
98.5%
T
830.6303
Physical
state
$
Prochimie
98.5%
T
830.6304
Odor
$
Prochimie
98.5%
T
830.6313
Stability
to
normal
and
elevated
temperatures,
metals,
and
metal
ions
$
Prochimie
98.5%
T
830.6314
Oxidation/
reduction:
chemical
incompatibility
$
Prochimie
98.5%
T
°
UCB
98.5%
T
°
Gustafson
97.5%
T
830.6315
Flammability
$
Prochimie
98.5%
T
830.6316
Explodability
$
Prochimie
98.5%
T
830.6317
Storage
stability
$
Prochimie
98.5%
T
°
Gustafson
97.5%
T
830.6319
Miscibility
$
Prochimie
98.5%
T
830.6320
Corrosion
characteristics
$
Prochimie
98.5%
T
°
Gustafson
97.5%
T
830.7000
pH
°
Prochimie
98.5%
T
830.7050
UV/
Visible
absorption
°
Prochimie
98.5%
T
°
Gustafson
97.5%
T
830.7100
Viscosity
$
Prochimie
98.5%
T
830.7200
Melting
point/
melting
range
$
Prochimie
98.5%
T
830.7220
Boiling
point/
boiling
range
$
Prochimie
98.5%
T
830.7300
Density/
relative
density/
bulk
density
$
Prochimie
98.5%
T
830.7370
Dissociation
constants
in
water

Prochimie
98.5%
T
62
830.7550
Partition
coefficient
(
n­
octanol/
water),
shake
flask
method
$
Prochimie
98.5%
T
830.7840
Water
solubility:
column
elution
method;
shake
flask
method
$
Prochimie
98.5%
T
830.7950
Vapor
pressure
$
Prochimie
98.5%
T
9.3
Residue
Chemistry
Data
Needs
860.1200
Directions
for
Use
860.1300
Plant
Metabolism
860.1300
Animal
Metabolism
860.1360
Multiple
Residue
Methods
860.1380
Storage
Stability
Data
°
Plant
Commodities

Animal
Commodities
860.1400
Residue
Analytical
Methods

Plant
Commodities
°
Animal
Commodities
­
RESERVED
860.1480
Meat,
Milk,
Poultry,
Eggs
°
Milk,
fat,
meat,
and
meat
byproducts
of
cattle,
goats,
horses,
and
sheep
860.1500
Crop
Field
Trials
°
Pome
Fruits
Group
­
Apple
°
Stone
Fruits
Group
­
Peach
9.4
Occupational/
Residential
Exposure
Data
Needs
875.2400
Dermal
Exposure
Study
875.2500
Inhalation
Exposure
Study
63
10.0
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Toxicology
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MRID
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Primary
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NOTOX,
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0174/
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December
1985.
MRID
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of
TMTD
technical
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the
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The
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MRID
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M.
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UCB­
Pharmaceutical
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December
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Thiram
Effects
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Rabbit
­
Preliminary
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Life
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87/
TRK003/
112.
August
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MRID
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Unpublished.

40510901
Debets,
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the
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Technical
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in
Cultured
Chinese
Hamster
Ovary
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using
Multiple
Fixation
Times.
NOTOX,
The
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December
1985.
MRID:
40510901.
Unpublished.

40534101
Tesh,
J.
M.,
McAnulty,
P.
A.
et
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(
1988)
Thiram:
Teratology
Study
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the
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No.
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TRK002/
179.
January
28,
1988.
MRID
No.
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and
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Unpublished.

40577301
Tesh,
J.
M.
et
al.
(
1988)
Thiram:
Teratology
Study
in
the
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Life
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Research.
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No.
87/
TRK004/
541.
March
28,
1988.
MRID
No.
40577301.
Unpublished.
40773601
D.
F.
Kehoe
(
1988)
Thirteen­
Week
Toxicity
Study
with
Thiram
in
Rats.
HLA
6111­
110.
64
March
23,
1988.
MRID
No.
40773601.
Unpublished.

41503608
D.
F.
Kehoe
(
1990)
13­
Week
Toxicity
Study
with
Thiram
in
Dogs.
Hazleton
Labs.,
Madison,
Wisconsin.
Study
No.
HLA
6111­
121.
March
26,
1990.
MRID
No.
41503608.
Unpublished.

41967901
D.
Kehoe
(
1991)
52­
Week
Dietary
Chronic
Toxicity
Study
with
Thiram
in
Dogs.
Hazleton
Labs.,
Madison,
Wisconsin.
Study
No.
HLA
6111­
112.
June
28,
1991.
MRID
No.
41967901.
Unpublished.

42095901
R.
G.
York
(
1991)
Two­
Generation
Reproduction
Study
in
Rats.
International
Research
and
Development
Corp.,
Michigan.
Study
No.
399­
104.
October
16,
1991.
MRID
No.
42095901.

42235701
and
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Gay,
M.
H.
et
al.
(
1991)
Metabolism
of
Orally
Administered
14C­
Thiram
in
Rats.
Biotek,
Inc.,
Woburn.
MA.
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87003B.
December
19,
1991.
MRID
No.
42235701
­
2.

42223601
Raymond
G.
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(
1992)
Developmental
Toxicity
Study
in
New
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White
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International
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and
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IRDC
399­
121.
February
18,
1992.
MRID
No.
42223601.

42313401
J.
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(
1992)
Oncogenicity
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with
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Hazleton
Washington,
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No.
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223.
March,
13
1992.
MRID
No.
42313401.
Unpublished.

42642501
Edwards,
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A.
et
al.
(
1992).
Thiram
Technical
Twenty­
One
Day
Dermal
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in
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Huntingdon
Research
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England.
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UCB
421/
920767.
November
12,
1992.
MRID
No.
42642501.

43012701
Driscoll,
C.
D.
and
J.
M.
Hurley
(
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Thiram:
Ninety­
Day
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in
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Bushy
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Research
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Export,
PA.
Study
No.
91N0127.
October
30,
1993.
MRID
No.
43012701.
Unpublished.

Residue
Chemistry
00002931
Keppel,
G.
E.
(
1971)
Collaborative
study
of
the
determination
of
Dithiocarbamate
residues
by
a
modified
Carbon
disulfide
evolution
method.
Journal
of
the
AOAC
[
Association
of
Official
Analytical
Chemists]
54(
3):
528­
531.
(
Also~
In~
unpublished
submission
received
on
unknown
date
under
0F0939;
submitted
by
Uniroyal
Chemical,
Bethany,
Conn.;
CDL:
094582­
G)

00041997
Ryker,
T.
C.
(
1970)
Letter
sent
to
C.
C.
Compton
dated
Jun
26,
1970
(
Thiram
residues
in
onions).
(
Unpublished
study
received
Nov
1,
1970
under
1E1123;
prepared
by
E.
I.
du
Pont
de
Nemours
&
Co.,
submitted
by
Interregional
Research
Project
No.
4,
New
Brunswick,
N.
J.;
CDL:
090898­
A)
65
00045165
E.
I.
du
Pont
de
Nemours
&
Company,
Incorporated
(
1957)
Results
of
Tests
on
the
Amount
of
Residue
Remaining
on
Food
Crops:
[
Thiram].
(
Unpublished
study
prepared
by
Gustafson
InternationalBram].
(
Unpublished
study
received
Aug
4,
1957
under
PP0144;
CDL:
092424­
F)

00047581
E.
I.
du
Pont
de
Nemours
&
Company,
Incorporated
(
1968)
Residue
Data
Thiram­­
Bananas.
(
Unpublished
study
received
Sep
10,
1968
under
9F0758;
CDL:
093070­
B)

00072406
Keppel,
G.
E.
(
1971)
Collaborative
study
of
the
determination
of
dithiocarbamate
residues
by
a
modified
carbon
disulfide
evolution
method.
Journal
of
the
Association
of
Official
Analytical
Chemists
54(
3):
528­
532.
(
Also
in
unpublished
submission
received
Apr
15,
1981
under
100­
607;
submitted
by
Ciba­
Geigy
Corp.,
Greensboro,
N.
C.;
CDL:
070023­
A)

00075880
E.
I.
du
Pont
de
Nemours
&
Company
(
1955)
Results
of
Tests
on
the
Amount
of
Residue
Remaining
on
Apples:
[
Thiram].
(
Unpublished
study
received
Nov
5,
1955
under
PP0052;
CDL:
090050­
B)

00085531
Lacy,
M.
L.
(
1970)
Letter
sent
to
C.
C.
Compton
dated
Nov
30,
1970
(
Determination
of
Thiram
residues
in
onions).
(
Unpublished
study
received
Nov
1,
1970
under
1E1123;
prepared
by
Michigan
State
Univ.,
Dept.
of
Botany
and
Plant
Pathology,
submitted
by
interregional
Research
Project
No.
4,
New
Brunswick,
N.
J.;
CDL:
090898­
B)

00089408
E.
I.
du
Pont
de
Nemours
&
Company
(
1958)
Results
of
Tests
on
the
Amount
of
Residue
Remaining
on
Food
Crops:
[
Thiram].
(
Unpublished
study
received
Dec
15,
1958
under
PP0204;
CDL:
090232­
A)

00089610
E.
I.
du
Pont
de
Nemours
&
Company,
Incorporated
(
1955)
Results
of
Tests
on
the
Amount
of
Residue
Remaining
on
Apples:
[
Thiram].
Includes
method
dated
Dec
5
under
PP0052;
CDL:
092333­
B)
Includes
method
dated
Dec
9,
1954.
(
Unpublished
study
received
Feb
25,
1955
under
PP0009;
CDL:
090009­
D)

00090157
E.
I.
du
Pont
de
Nemours
&
Company,
Incorporated
(
1960)
Results
of
Tests
on
the
Amount
of
Residue
Remaining
on
Celery:
[
Thiram].
(
Unpublished
study
received
Oct
20,
1960
under
PP0278;
CDL:
090300­
A)

00090174
Pease,
H.
L.
(
1957)
Determination
of
dithiocarbamate
fungicide
residues.
Journal
of
the
Association
of
Official
Agricultural
Chemists
40(
4):
1113­
1118.
(
Also~
In~
unpublished
submission
received
Oct
20,
1960
under
PP0278;
submitted
by
E.
I.
du
Pont
de
Nemours
&
Co.,
Inc.,
Wilmington,
Del.;
CDL:
090300­
C)

00098132
E.
I.
du
Pont
de
Nemours
&
Company,
Incorporated
(
1956)
Results
of
Tests
on
the
Amount
of
Residue
Remaining
on
Peaches:
[
Thiram].
(
Unpublished
study
received;
CDL:
124402­
A)
(
Unpublished
study
received
Sep
1,
1956
under
PP0091;
CDL:
090121­
A)

00098135
Breault,
E.
A.
(
1960)
Letter
sent
to
H.
W.
Gerritz
dated
Dec
13,
1960:
Thiram
(
tetramethyl
thiuram
disulfide)
on
celery.
(
U.
S.
Government;
unpublished
study;
CDL:
092556­
A)
66
00098137
Rosen,
D.
E.
(
1962)
Letter
sent
to
William
Stokes
dated
May
22,
1962
[
Thiram
fungicide
residues
in
bananas].
(
Unpublished
study
received
on
unknown
date
under
PP0359;
submitted
by
E.
I.
du
Pont
de
Nemours
&
Co.,
Inc.,
Wilmington,
Del.;
CDL:
092643­
A)

00098140
E.
I.
du
Pont
de
Nemours
and
Company,
Incorporated
(
1955)
Results
of
Tests
on
the
Amount
of
Residue
Remaining
on
Apples:
[
Thiram].
(
Unpublished
study
received
Feb
25,
1955
under
PP0052;
CDL:
098736­
B;
098154)

00098143
E.
I.
du
Pont
de
Nemours
&
Company,
Incorporated
(
19??)
Residue
(
ppm):
Thiram:
[
Whole
Fruit].
(
Unpublished
study
received
on
unknown
date
under
PP0359;
CDL:
098907­
A)

00098150
E.
I.
du
Pont
de
Nemours
&
Company,
Incorporated
(
19??)
[
Thiram
Fungicide
Residues
in
Peaches
and
Strawberries].
(
Compilation;
unpublished
study
received
Jan
19,
1959
under
PP0204;
CDL:
126219­
A)

00098190
E.
I.
du
Pont
de
Nemours
&
Company,
Incorporated
(
1957)
Results
of
Tests
on
Amount
of
Residue
Remaining
on
Food
Crops:
[
Thiram].
Includes
undated
method
entitled:
Determination
of
dithiocarbamate
fungicide
residues.
(
Compilation;
unpublished
study
received
Aug
4,
1957
under
PP0144;
CDL:
090172­
C)

00098644
Cullen,
T.
E.
(
1964)
Spectrophotometric
determination
of
dithiocarbamate
residues
on
food
crops.
Analytical
Chemistry
36(
1):
221­
224.
(
Also
In
unpublished
submission
received
Nov
16,
1965
under
unknown
admin.
no.;
submitted
by
FMC
Corp.,
Philadelphia,
Pa.;
CDL:
120299­
A)

00162142
Harned,
W.;
Tortora,
N.
(
1986)
Uptake
and
Distribution
of
Carbon­
14
Thiram
in
Cotton,
Soybean
and
Wheat:
Project
No.
8565­
A.
Unpublished
study
prepared
by
Uniroyal
Chemical.
25
p.

40216502
Nowakowski,
M.
(
1987)
Identification
of
Metabolites
in
Cotton,
Wheat
and
Soybean
Seedlings
Grown
from
Carbon
14
Thiram
Treated
Seeds:
Uniroyal
Project
ID
by
Gustafson
International
Research
Seeds:
Uniroyal
Project
ID
No.
8565­
C.
Unpublished
study
prepared
by
Uniroyal
Chemical
Co.,
Inc.
47
p.

40495201­
Duplicate
of
MRID
00072406
41006201
Norris,
K.
(
1989)
Determination
of
the
Metabolic
Fate
of
[
Carbon]­
Thiram
Orally
Administered
to
Lactating
Goats:
ADC
Project
No.
1057.
Unpublished
study
prepared
by
Analytical
Development
Corporation
in
cooperation
with
Colorado
State
Univ.,
Metabolic
Laboratory.
56
p.

41006202
Norris,
K.
(
1989)
Determination
of
the
Metabolic
Fate
of
[
Carbon]­
Thiram
Orally
Administered
to
Laying
Hens:
ADC
Project
No.
1058.
Unpublished
study
prepared
by
Analytical
Development
Corp.
in
cooperation
with
Colorado
State
Univ.,
Metabolic
Laboratory.
42
p.

41065001
Ball,
J.
(
1988)
Residue
of
Thiram
and
its
Monothioglucoside
and
Dithioglucoside
in
Cotton:
Project
ID:
01483;
6111­
126J.
Unpublished
study
prepared
by
Gustafson
International
Laboratory
in
cooperation
with
Hazelton
Laboratories.
262
p.
67
41065002
Ball,
J.
(
1988)
Residue
of
Thiram
and
its
Monothioglucoside
and
Dithioglucoside
in
Field
Corn:
Project
ID:
01486;
6111­
126B.
Unpublished
study
prepared
by
Gustafson
International
Research
Laboratory
in
cooperation
with
Hazelton
Laboratories.
374
p.

41065003
Ball,
J.
(
1988)
Residue
of
Thiram
and
its
Monothioglucoside
and
Dithioglucoside
in
Sweet
Corn:
Project
ID:
01487;
6111­
126A.
Unpublished
study
prepared
by
Gustafson
International
Research
Laboratories.
282
p.

41065004
Ball,
J.
(
1988)
Residue
of
Thiram
and
its
Monothioglucoside
and
Dithioglucoside
in
Succulent
Beans:
Project
ID:
01484;
6111­
126E.
Unpublished
study
prepared
by
Gustafson
International
Research
Laboratory
in
cooperation
with
Hazelton
Laboratories.
249
p.

41065005
Ball,
J.
(
1988)
Residue
of
Thiram
and
its
Monothioglucoside
and
Dithioglucoside
in
Dry
Beans:
Project
ID:
01493;
6111­
126F.
Unpublished
study
prepared
by
Gustafson
International
Research
Laboratory
in
cooperation
with
Hazelton
Laboratories.
244
p.

41065006
Ball,
J.
(
1988)
Residue
of
Thiram
and
its
Monothioglucoside
and
Dithioglucoside
in
Soybeans:
Project
ID:
01494;
6111­
126C.
Unpublished
study
prepared
by
Gustafson
International
Research
Laboratory
in
cooperation
with
Hazelton
Laboratories.
384
p.

41065007
Ball,
J.
(
1988)
Residue
of
Thiram
and
its
Monothioglucoside
and
Dithioglucoside
in
Wheat:
Project
ID:
01492;
6111­
126D.
Unpublished
study
prepared
by
Gustafson
International
Research
Laboratory
in
cooperation
with
Hazleton
Laboratories.
608
p.

41503601
Rockwell,
J.
(
1990)
Residues
of
Thiram
and
its
Metabolites
in
Lettuce:
Lab
Project
Number:
HLA
6111­
126K:
01488:
90­
007.
Unpublished
study
prepared
by
Gustafson
International
Research
Laboratory
in
association
with
Hazleton
Laboratories
America,
Inc.
141
p.

41503602
Rockwell,
J.
(
1989)
Residues
of
Thiram
and
its
Metabolites
in
Peas:
Lab
Project
Number:
90­
008:
HLA
6111­
126G:
01489.
Unpublished
study
prepared
by
Gustafson
International
Laboratories
in
association
with
Hazleton
Laboratories,
Inc.
213
p.

41503603
Rockwell,
J.
(
1989)
Residues
of
Thiram
and
its
Metabolites
in
Safflower:
Lab
Project
Number:
90­
009:
HLA
6111­
126L:
01490.
Unpublished
study
prepared
by
Gustafson
International
Laboratory
in
association
with
Hazleton
Laboratories
America,
Inc.
137
p.

41503604
Rockwell,
J.
(
1990)
Residues
of
Thiram
and
its
Metabolites
in
Sugar
Beets:
Lab
Project
Number:
90­
010:
HLA
6111­
126H:
01491.
Unpublished
study
prepared
by
Gustafson
International
Research
Laboratory
in
association
with
Hazleton
Laboratories,
America,
Inc.
181
p.

41503605
Rockwell,
J.
(
1989)
Residues
of
Thiram
and
its
Metabolites
in
Table
Beets:
Lab
Project
Number:
90­
011:
HLA
6111­
126I:
01485.
Unpublished
study
prepared
by
Gustafson
International
Research
Laboratory
in
association
with
Hazleton
Laboratories
America,
Inc.
184
p.
68
42399601
Christman,
P.
(
1992)
Determination
of
Thiram
and
Its
Metabolites
in
Crops
[
Addendum
to
Final
Report]:
Lab
Project
Number:
HLA
6111­
126
A­
L;
92­
011.
Unpublished
study
prepared
by
Hazleton
Labs
America,
Inc.;
Gustafson,
Inc.
and
Uniroyal
Chem.
Co.
76
p.

42399602
Rockwell,
J.
(
1992)
Residues
of
Thiram
and
Its
Metabolite
in
Alfalfa:
Lab
Project
Number:
HLA
6111­
134A;
01777;
92­
012.
Unpublished
study
prepared
by
Hazleton
Labs
America,
Inc.;
Gustafson
Intl.
Res.
Lab
;
Uniroyal
Chem.
Co.
and
others.
97
p.

42399603
Rockwell,
J.
(
1992)
Residues
of
Thiram
and
Its
Metabolite
in
Cabbage:
Lab
Project
Number:
HLA
6111­
134C;
017773;
92­
013.
Unpublished
study
prepared
by
Hazleton
Labs
America,
Inc.;
Gustafson,
Inc.;
Uniroyal
Chem.
Co.
and
others.
127
p.

42399604
Rockwell,
J.
(
1992)
Residues
of
Thiram
and
Its
Metabolite
in
Cucumbers:
Lab
Project
Number:
HLA
6111­
134D;
01774;
92­
014.
Unpublished
study
prepared
by
Hazleton
Labs
America,
Inc.;
Gustafson
Intl.
Res.
Lab;
Uniroyal
Chemical
Co.
and
others.
141
p.

42399605
Rockwell,
J.
(
1992)
Residues
of
Thiram
and
Its
Metabolite
in
Fresh
and
Processing
Tomatoes:
Lab
Project
Number:
HLA
6111­
134F;
01775;
92­
015.
Unpublished
study
prepared
by
Hazleton
Labs
America,
Inc.;
Gustafson
Intl.
Res.
Lab;
Uniroyal
Chemical
Co.
and
others.
145
p.

42677501
Norris,
K.
(
1993)
Determination
of
the
Metabolic
Fate
of
(
carbon
14)­
Thiram
Orally
Administered
to
Lactating
Goats:
Revised
Final
Report:
Lab
Project
Number:
1057:
1057­
1.
Unpublished
study
prepared
by
Analytical
Development
Corp.
and
Colorado
State
Univ.
94
p.

42943701
Norris,
K.
(
1993)
Determination
of
the
Metabolic
Fate
of
(
Carbon­
14)
Thiram
Orally
Administered
to
Laying
Hens:
Final
Report:
Lab
Project
Number:
1058:
1058­
1.
Unpublished
study
prepared
by
Analytical
Development
Corporation
(
ADC);
Colorado
State
University
(
CSU)
Metabolic
Lab.
80
p.

42954201
Norris,
K.
(
1993)
Determination
of
the
Metabolic
Fate
of
(
Carbon
14)­
Thiram
Orally
Administered
to
Laying
Hens:
Addendum
No.
1
to
Final
Report:
Lab
Project
Number:
1058:
1058­
1.
Unpublished
study
prepared
by
Analytical
Development
Corp.
and
Colorado
State
University
Metabolic
Lab.
8
p.

43757401
Leppert,
B.
(
1995)
Magnitude
of
Thiram
Residues
in
Apples:
Final
Report:
Lab
Project
Number:
SARS­
94­
31:
ML94­
0458­
UCB:
SARS­
94­
CA­
31A.
Unpublished
study
prepared
by
Stewart
Agricultural
Research
Services,
Inc.
and
Morse
Labs,
Inc.
441p.

43759101
Leppert,
B.
(
1995)
Magnitude
of
Thiram
Residues
in
Peaches:
Final
Report:
Lab
Project
Number:
UCB
1994­
32:
ML94­
0459­
UCB:
SARS­
94­
GA­
32.
Unpublished
study
prepared
by
Stewart
Agricultural
Research
Services,
Inc.
and
Morse
Labs,
Inc.
208
p.

43762601
Leppert,
B.
(
1995)
Magnitude
of
Thiram
Residues
in
Strawberries:
Final
Report:
Lab
Project
Number:
UCB
1993­
02:
SARS­
93­
MI­
52:
SARS­
93­
NY­
52.
Unpublished
study
prepared
by
Stewart
Agricultural
Research
Services,
Inc.
and
Morse
Labs,
Inc.
430
p.
69
43762602
Leppert,
B.
(
1995)
Magnitude
of
Thiram
Residues
in
Strawberries:
Final
Report:
Lab
Project
Number:
UCB
1994­
30:
SARS­
94­
CA­
30A:
SARS­
94­
CA­
30B.
Unpublished
study
prepared
by
Stewart
Agricultural
Services,
Inc.
and
Morse
Labs,
Inc.
424
p.

43813101
Leppert,
B.
(
1995)
Magnitude
of
Thiram
Residues
in
Apples:
Final
Report:
Lab
Project
Number:
ML93­
0437­
UCB:
SARS­
93­
50:
UCB
1993­
01.
Unpublished
study
prepared
by
Stewart
Agricultural
Research
Services,
Inc.
and
Morse
Labs,
Inc.
554
43835201
Shen,
S.
(
1995)
Determination
of
the
Residues
of
Thiram
and
Its
Metabolite
in
Dry
Beans:
Lab
Project
Number:
94­
016:
943G8:
HWI
6456­
113.
Unpublished
study
prepared
by
Corning
Hazleton,
Inc.
and
Gustafson,
Inc.
261
p.

43835202
Shen,
S.
(
1995)
Determination
of
the
Residues
of
Thiram
and
Its
Metabolite
in
Sweet
Corn:
Lab
Project
Number:
94­
015:
943G7:
HWI
6456­
112.
Unpublished
study
prepared
by
Corning
Hazleton,
Inc.
and
Gustafson,
Inc.
198
p.

43835203
Shen,
S.
(
1995)
Determination
of
the
Residues
of
Thiram
and
Its
Metabolite
in
Green
Onions:
Lab
Project
Number:
94­
009:
94130:
HWI
6456­
105.
Unpublished
study
prepared
by
Corning
Hazleton,
Inc.
and
Gustafson,
Inc.
358
p.

43835204
Shen,
S.
(
1995)
Determination
of
the
Residues
of
Thiram
and
Its
Metabolite
in
Bulb
Onions:
Lab
Project
Number:
94­
001:
94129:
HWI
6456­
104.
Unpublished
study
prepared
by
Corning
Hazleton,
Inc.
and
Gustafson,
Inc.
385
p.

43835205
Shen,
S.
(
1995)
Determination
of
the
Residues
of
Thiram
and
Its
Metabolite
in
Processed
Cotton
Fractions:
Lab
Project
Number:
HWI
6456­
107:
94123:
94­
002.
Unpublished
study
prepared
by
Corning
Hazleton,
Inc.
and
Gustafson,
Inc.
223
p.

43835206
Shen,
S.
(
1995)
Determination
of
the
Residues
of
Thiram
and
Its
Metabolite
in
Processed
Field
Corn
Fractions:
Lab
Project
Number:
HWI
6456­
110:
94124:
94­
003.
Unpublished
study
prepared
by
Corning
Hazleton,
Inc.
and
Gustafson,
Inc.
202
p.

43835207
Shen,
S.
(
1995)
Determination
of
the
Residues
of
Thiram
and
Its
Metabolite
in
Processed
Safflower
Fractions:
Lab
Project
Number:
HWI
6456­
106:
94125:
94­
004.
Unpublished
study
prepared
by
Corning
Hazleton,
Inc.
and
Gustafson,
Inc.
231
p.

43835208
Shen,
S.
(
1995)
Determination
of
the
Residues
of
Thiram
and
Its
Metabolite
in
Processed
Soybean
Fractions:
Lab
Project
Number:
HWI
6456­
108:
94127:
94­
005.
Unpublished
study
prepared
by
Corning
Hazleton,
Inc.
and
Gustafson,
Inc.
201
p.

43835209
Shen,
S.
(
1995)
Determination
of
the
Residues
of
Thiram
and
Its
Metabolite
in
Processed
Sugar
Beet
Fractions:
Lab
Project
Number:
HWI
6456­
109:
94126:
94­
006.
Unpublished
study
prepared
by
Corning
Hazleton,
Inc.
and
Gustafson,
Inc.
213
p.
70
43835210
Shen,
S.
(
1995)
Determination
of
the
Residues
of
Thiram
and
Its
Metabolite
in
Processed
Wheat
Fractions:
Lab
Project
Number:
HWI
6456­
111:
94128:
94­
007.
Unpublished
study
prepared
by
Corning
Hazleton,
Inc.
and
Gustafson,
Inc.
248
p.

43846301
Leppert,
B.
(
1995)
Magnitude
of
Thiram
Residues
in
Apples,
A
Processing
Study:
Final
Report:
Lab
Project
Number:
UCB
1993­
003:
SARS­
93­
NY­
51:
93405.
Unpublished
study
prepared
by
Stewart
Agricultural
Research
Services,
Inc.
326
p.

44550814
Kliskey,
E.
(
1997)
Determination
of
the
Magnitude
of
Residues
of
Thiram
in
Peach
RAC's
From
Trees
Treated
with
a
Thiram
75%
96004:
GL­
13B:
ML96­
0597­
UCB.
Unpublished
study
prepared
by
Compliance
Services
International.
235
p.

44550816
Kemman,
R.
(
1997)
Determination
of
the
Magnitude
of
Residues
of
Thiram
in
Strawberry
RAC's
From
Plants
Treated
with
a
Thiram
75%
Water­
Dispersible
Granule
Formulation:
Lab
Project
Number:
96008:
ML96­
0601­
UCB:
METH­
7.
Unpublished
study
prepared
by
Compliance
Services
International.
310
p.

44724503
Kemman,
R.
(
1998)
Determination
of
the
Magnitude
of
Residues
of
Thiram
in
Peach
RAC's
from
Trees
Treated
with
a
Thiram
75%
97003:
ML97­
0682­
UCB:
97003­
LA1.
Unpublished
study
prepared
by
Compliance
Services
International.
239
p.
{
OPPTS
860.1500}

44724504
Kemman,
R.
(
1998)
Determination
of
the
Magnitude
of
Residues
of
Thiram
in
Strawberry
RAC's
from
Plants
Treated
with
a
Thiram
75%
Water­
Dispersible
Granule
Formulation
and
Selectively
with
a
Thiram
65%
Wettable
Powder
Formulation:
Lab
Project
Number:
97006:
ML97­
0685­
UCB:
97006­
CA1.
Unpublished
study
prepared
by
Compliance
Services
International.
451
p.
{
OPPTS
860.1500}

44724505
Kemman,
R.
(
1998)
Determination
of
the
Magnitude
of
Residues
of
Thiram
in
Apple
RAC's
from
Trees
Treated
with
a
Thiram
75%
Water­
Dispersible
Granule
Formulation:
Lab
Project
Number:
97001:
ML97­
0680­
UCB:
96001.
Unpublished
study
prepared
by
Compliance
Services
International.
249
p.
{
OPPTS
860.1500}

44992501
Kang,
H.;
Robinson,
R.
(
1999)
Metabolic
Fate
and
Distribution
of
(
carbon­
14)
Thiram
in
Apple:
Lab
Project
Number:
R369801:
XBL98041:
RPT00519.
Unpublished
study
prepared
by
Xenobiotic
Labs,
Inc.
427
p.
{
OPPTS
860.1300}

Occupational
Assessment
45250702
P.
G.
Pontal;
(
1996)
Worker
Exposure
Study
During
Application
Of
Regent
20GR
In
Banana
Plantation,
(
RP
Study
94/
136
­
Amended,
Vol.
4
of
4,
Analytical
Lab.
CP/
Man/
ENH/
338/
95/
0072).
Unpublished
study
prepared
by
Bayer
Crop
Protection.

44972201
Klonne,
D.
(
1999)
Integrated
Report
For
Evaluation
of
Potential
Exposures
To
Homeowners
and
Professional
Lawncare
Operators
Mixing,
Loading,
and
Applying
Granular
And
71
Liquid
Pesticides
To
Residential
Lawns.
Unpublished
study
prepared
by
Outdoor
Residential
Exposure
Task
Force.

43080049
Rosenheck;
Schuster
(
1993)
Worker
Exposure
To
Apron
Flowable
While
Treating
Seed
Commercially.
Unpublished
study
prepared
by
Ciba
Plant
Protection.

No
MRID
Fenske,
R.
(
1986)
Review
of
Worker
Exposure
to
Lindane
During
Manual
Seed
Treatment
Unpublished
study
prepared
by
Rutgers
University.

449045­
26
Urtizberea,
Bruns,
and
Nelson
(
1998)
Carbathiin
Operator
Exposure
Study
During
Seed
Treatment
With
Vitavax
Single
or
Vitaflo
280
in
Canola.
Unpublished
study
prepared
by
Rhone
Poulenc.

42251902
Knarr,
D
(
1989)
Exposures
of
Seed
Treatment
Workers
to
Isofenphos
During
Application
of
Oftanol
Containing
Seed
Coating
to
Canola
Seed.
Unpublished
study
prepared
by
Mobay
(
now
Bayer
AG).

422519­
01
Dean,
V
(
1990)
Exposures
of
Workers
to
Isofenphos
During
Planting
of
Oftanol
Treated
Canola
Seeds
Unpublished
study
prepared
by
Mobay
(
now
Bayer
AG).

456545­
01
Leplay,
M.
A
(
1995)
Worker
Exposure
During
Drilling
of
Wheat
Seed
Treated
With
Germinate
Double.
Unpublished
study
prepared
by
Sponsor:
Rhone
Poulenc.

454427­
01
Honeycutt,
Kennedy,
and
Honeycutt
(
2001)
Determination
of
Inhalation
and
Dermal
Exposure
To
Mixer/
Loaders,
Baggers,
and
Clean­
up
Workers
to
Fipronil
During
and
After
the
Application
of
ICON
6.2FS
Insecticide
to
Rice
Seed.
Unpublished
study
prepared
by
Aventis.

No
MRID
Avakian,
M.
D.
(
1995)
Assessment
of
Worker
Exposure
to
a
Commercial
Seed
Treatment
in
Seed­
treating
Plants
(
Vitavax
RS
Flowable
­
Canola
­
Alberta
Canada).
Unpublished
study
prepared
by
Uniroyal.
