
Page
1
of
9
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
November
23,
2004
MEMORANDUM
SUBJECT:
Evaluation
of
the
Potential
Exposure
of
Workers
to
Propanil
During
Mixing/
Loading
and
Aerial
Application
to
Rice
Fields
Using
Simultaneous
Dermal
Dosimetry
and
Biological
Monitoring
Techniques,
MRID
No.
46147801
and
46075501,
DP
Bar
Code:
D310487
FROM:
Alan
Nielsen,
Branch
Senior
Scientist
Reregistration
Branch
II
Health
Effects
Division
(
7509C)

TO:
Carmen
Rodia,
Chemical
Review
Manager
Reregistration
Branch
II
Special
Review
and
Reregistration
Division
(
7508W)

The
following
is
HED's
response
to
the
document
submitted
by
the
Propanil
Task
Force
II
which
responded
to
HED's
review
of
the
"
Evaluation
of
the
Potential
Exposure
of
Workers
to
Propanil
During
Mixing/
Loading
and
Aerial
Application
to
Rice
Fields
Using
Simultaneous
Dermal
Dosimetry
and
Biological
Monitoring
Techniques"
and
the
"
Propanil
Exposures
and
Risk
Assessment
Based
on
Data
From
an
Aerial
Application
Study
in
Rice
with
Liquid
Formulations."

The
Propanil
Task
Force
II
(
PTF
II)
responded
to
the
review
by
the
U.
S.
Environmental
Protection
Agency
("
EPA"
or
"
Agency")
of
the
final
reports
from
the
"
Evaluation
of
the
Potential
Exposure
of
Workers
to
Propanil
During
Mixing/
Loading
and
Aerial
Application
to
Rice
Fields
Using
Simultaneous
Dermal
Dosimetry
and
Biological
Monitoring
Techniques"
and
the
"
Propanil
Exposures
and
Risk
Assessment
Based
on
Data
From
an
Aerial
Application
Study
in
Rice
with
Liquid
Formulations."
This
document
is
the
response
to
the
latest
PTF
II
document.
Page
2
of
9
1.
PTF
II
states:
A
quantitative
risk
assessment
based
on
the
urine
data
from
workers
is
not
reliable
or
appropriate
.
.
.
Available
data
are
not
sufficient
to
quantify
propanil
exposure
to
humans
based
on
urine
levels
of
3,4­
DCA.
Human
pharmacokinetics
data
are
necessary
to
provide
a
valid
approach
for
quantification.
[
M]
ost
of
the
workers
handled
propanil
on
the
days
prior
to
the
study
application
day,
the
days
following
the
study
application
or
in
some
cases
both
time
periods.
These
exposures,
coupled
with
the
lack
of
human
pharmacokinetic
data,
make
it
impossible
to
validly
use
the
urine
DCA
concentrations
seen
in
the
worker
study
for
assessing
the
risk
of
propanil
to
workers.

HED
response:
The
burden
is
on
the
registrant
to
determine
the
suitability
of
biomarkers
and
the
appropriate
pharmacokinetics.
HED
concurs
that
accurate
documentation
of
propanil
exposures
to
the
handlers
on
the
days
prior
to
the
study
application
day,
the
days
following
the
study
application
or
in
some
cases
both
time
periods
 
in
addition
to
the
lack
of
precise
pharmacokinetic
data
 
make
the
use
of
the
biomonitoring
data
problematic.

2.
PTF
II
states:
The
objective
of
the
Task
Force
study
was
to
measure
potential
exposure
to
mixer/
loaders
and
pilots
from
propanil
that
was
mixed/
loaded
and
applied
in
a
realistic
and
routine
fashion.
Achieving
this
objective
allows
exposure
assessments
to
be
performed
in
a
way
that
determines
an
accurate
risk
to
mixer/
loaders
and
pilots
handling
propanil.

HED
response:
The
PTF
II
submitted
to
EPA
a
proposed
protocol
for
conducting
the
handler
monitoring
study
and
EPA
approved
the
protocol.
However,
when
the
actual
study
was
conducted,
there
were
thirteen
amendments
and
forty
deviations
to
the
study
protocol.
This
contributed
to
the
Agency's
difficulty
in
determining
whether
the
study
was
performed
in
a
manner
that
would
allow
an
accurate
risk
to
be
estimated
for
mixers/
loaders
and
pilots
handling
propanil.

3.
PTF
II
states:
Propanil
is
most
commonly
applied
at
3
to
4
lbs
ai/
Acre
when
grasses
are
actively
growing
in
the
3­
4­
leaf
stage
approximately
15­
25
days
after
planting.
Higher
rates
of
propanil
at
4­
6
lbs
ai/
Acre
are
sometimes
used
when
grasses
are
in
the
4­
6­
leaf
stage
about
20­
30
days
after
planting
or
for
emergency
or
"
rescue"
operations
for
older
tillering
grasses
about
30­
40
days
from
planting.

HED
response:
The
protocol
submitted
by
the
PTF
II
and
approved
by
EPA
stated
that
the
maximum
labeled
rate
of
6
pounds
active
ingredient
per
acre
would
be
applied.
HED
is
concerned
that
the
lower
application
rate
factor
would
be
expected
to
result
in
less
residue
being
deposited
on
the
outer
dosimeter,
thus
likely
underestimating
exposure
and
risk.
Page
3
of
9
4.
PTF
II
states:
The
loading
of
propanil
products
into
a
spray
tank
of
an
airplane
occurs
in
two
stages.
Propanil
is
removed
from
the
product
drum
using
a
siphoning
device
commonly
called
a
"
STAM"
pipe.
This
is
similar
methodology
to
that
represented
by
the
data
in
PHED.
Propanil
is
mixed
with
other
products
and
water
in
the
mix
tank
and
the
mixture
is
transferred
to
the
airplane
spray
tank
via
a
dry­
lock
connector
that
attaches
to
the
airplane
tank
from
the
mix
tank.

HED
response:
HED
concurs
that
the
mixing/
loading
methodology
described
by
the
PTF
II
is
similar
to
the
methodology
represented
in
PHED
for
mixing/
loading
liquid
formulations
using
closed
systems.

5.
PTF
II
states:
[
U]
nder
realistic
conditions,
it
is
not
unusual
for
pilots
to
only
apply
propanil
and
mixer/
loaders
will
only
load
propanil
for
an
average
of
about
2
hours
per
day.

HED
response:
The
protocol
submitted
by
the
PTF
II
and
approved
by
EPA
stated
that
"
all
workers
will
perform
their
work
tasks
for
a
typical
amount
of
time
that
represents
an
entire
workday.
One
replicate
will
be
an
entire
workday
for
each
test
subject.
.
.
.
The
air
sampling
pump
will
operate
for
the
entire
monitoring
replicate
(
estimated
to
be
6­
12
hours)."
However,
the
average
duration
of
actual
handling
for
each
replicate
in
the
study
was
only
2.2
hours
for
mixers/
loaders
and
only
1.7
hours
for
pilots.
HED
is
concerned
that
the
reduced
handling
time
would
be
expected
to
result
in
less
time
for
the
residue
to
penetrate
the
outer
dosimeter,
thus
likely
underestimating
exposure
and
risk..

6.
PTF
II
states:
Early
season
application
of
propanil
was
chosen
in
order
to
meet
the
protocol
requirement
of
finding
mixer/
loaders
and
pilots
who
did
not
have
previous
exposure
to
propanil
in
2003.

HED
response:
See
#
4
for
HED
comments
regarding
use
of
maximum
application
rate.
HED
also
notes
the
study
did
not
meet
the
protocol
requirement
of
finding
mixer/
loaders
and
pilots
who
did
not
have
previous
exposure
to
propanil
in
2003
(
see
#
2).

7.
PTF
II
states:
Field
scientists
waited
for
propanil
orders
from
growers
and
for
wind
conditions
to
be
favorable
before
performing
each
replicate
of
the
study.

HED
response:
HED
has
no
concerns
with
this
approach.
Page
4
of
9
8.
PTF
II
states:
The
"
outer
dosimeter"
worn
by
mixer/
loaders
and
pilots
was
a
100%
cotton
long
sleeve
shirt
and
100%
cotton
long
pants.

HED
response:
HED
agrees
that
the
"
outer
dosimeter"
was
a
cotton
long
sleeve
shirt
and
100%
cotton
long
pants,
and
not
a
cotton
coverall.

9.
PTF
II
states:
The
Task
Force
proposes
an
alternative
method
to
calculate
the
potential
dermal
exposure
to
the
mixer/
loaders
wearing
the
chemical­
resistant
apron.
The
proposed
method
to
recalculate
the
dermal
exposure
to
propanil
mixer/
loaders
uses
a
penetration
factor
of
10%.
Average
penetration
factors
ranging
from
2­
27%
percent
have
been
observed
in
studies
since
1981
(
References
1­
4).
Thus,
a
reasonable
average
penetration
factor
to
use
for
subsequent
calculations
would
be
10%
for
the
upper
and
lower
arms
as
well
as
the
back
of
the
legs
of
the
mixer/
loader.

HED
response:
The
standard
operating
procedure
in
HED
is
to
use
a
penetration
factor
of
50%
when
estimating
the
reduction
in
exposure
provided
by
an
additional
layer
of
protections.
HED
routinely
applies
this
50%
penetration
factor
to
PHED
data
to
estimate
the
additional
protection
offered
by
wearing
coveralls
over
a
long­
sleeve
shirt
and
long
pants.
HED
notes
that
the
Guidance
Manual
for
Selecting
Protective
Clothing
for
Agricultural
Pesticide
Operations
(
EPA
publication
number
736­
B­
94­
001)
that
summarizes
literature
on
personal
protective
equipment,
including
body
protection
states:
"
The
amount
of
penetration
was
not
linear
with
applied
volume,
rather
the
percent
penetration
increased
with
the
amount
applied.
A
fabric
that
provided
relatively
high
penetration
resistance
at
one
volume
did
not
necessarily
provide
a
relatively
high
resistance
at
a
different
volume.
There
seems
to
be
an
absorbency
capacity
threshold
beyond
which
the
penetration
resistance
of
some
fabrics
drops
off
dramatically.
This
behavior
must
be
borne
in
mind
when
reviewing
penetration
data
in
which
different
volumes
are
applied.
The
capacity
threshold
may
account
for
apparent
discrepancies
in
data
reported
from
different
researchers
(
p.
70)."

10.
PTF
II
states:
This
10%
penetration
factor
is
a
conservative
estimate
of
penetration
since
the
front
top
of
the
thighs
down
to
the
ankle
of
the
mixer/
loader
were
covered
by
the
chemical
resistant
apron
worn
by
the
mixer/
loader
test
subjects
in
this
study.
This
covered
area
of
the
body
would
result
in
much
less
than
10%
penetration
through
the
front
thigh
and
calf
areas
of
the
legs.

HED
response:
Even
though
the
apron
worn
in
the
study
apparently
covered
the
mixer/
loader
down
to
his/
her
ankles,
the
Worker
Protection
Standard
for
Agricultural
Pesticides
(
40
CFR
Part
170)
defines
a
chemical­
resistant
apron
as
"
an
apron
that
is
made
Page
5
of
9
of
chemical­
resistant
material
and
that
covers
the
front
of
the
body
from
mid­
chest
to
the
knees."
Therefore,
HED
cannot
assume
that
a
mixer/
loader
would
be
completely
covered
in
the
front
down
to
the
ankles.
Furthermore,
the
measured
residues
on
the
lower
leg
were
likely
reduced
since
the
mixers/
loaders
wore
"
full
rubber
boots"
in
the
study.

11.
PTF
II
states:
The
Task
Force's
proposed
method
of
calculation
of
exposure
to
the
mixer/
loaders
in
this
study
is
as
follows:

a.
The
residues
of
propanil
on
the
legs
and
arms
of
the
outer
dosimeter
long­
sleeved
cotton
shirt
and
long
cotton
pants
are
summed.
The
sum
is
then
multiplied
by
0.1
to
achieve
the
residue
amounts
given
a
10%
penetration
factor
for
the
cotton
garments.

b.
The
corrected
residue
on
the
arms
and
legs
of
the
mixer/
loader
are
then
added
to
the
residues
of
propanil
on
the
t­
shirt
and
brief
as
well
as
to
the
residues
in
the
handwash.
This
sum
is
then
added
to
the
head,
face
and
neck
residues
derived
from
the
head
patch
data
to
provide
a
total
dermal
body
exposure
for
the
worker.

HED
response:
HED
concurs
with
the
Propanil
Task
Force
II's
proposed
method
of
calculation
of
exposure
to
mixers/
loaders,
except
HED
applied
a
0.5
(
i.
e.,
50%)
factor
to
the
summed
residues
on
the
legs
and
arms
of
the
outer
dosimeter.

12.
PTF
II
states:
Only
workers
wearing
chemical­
resistant
aprons
are
considered
when
using
this
alternative
method
of
calculating
exposure.
The
four
workers
wearing
the
Tyvek
coverall
were
excluded
from
the
data
set
since
the
Tyvek
coverall
would
produce
in
theory
an
artificially
low
residue
on
the
outer
dosimeter
shirt
and
pants,
rendering
the
arms
and
leg
data
from
the
shirt
and
pants
outer
dosimeter
useless.

HED
response:
HED
concurs
in
excluding
the
four
mixers/
loaders
wearing
Tyvek
coveralls
over
the
outer
dosimeter
from
the
calculations
of
dermal
exposure.
However,
HED
included
the
measured
inhalation
exposures
of
those
four
handlers,
since
the
Tyvek
coverall
should
have
no
effect
on
the
inhalation
exposures.

13.
PTF
II
states:
When
total
dermal
and
inhalation
exposures
are
normalized
against
pounds
handled
the
resultant
geometric
means
are:
1.30
ug/
lb
ai
for
dermal
and
0.0065
ug/
lb
ai
for
inhalation.
Page
6
of
9
HED
response:
Using
the
same
dermal
and
inhalation
exposure
values
presented
in
the
table
in
the
PTF
II
response,
HED
calculates
a
dermal
exposure
(
geometric
mean)
of
1.2
:
g
per
pound
active
ingredient
handled
and
an
inhalation
exposure
(
geometric
mean)
of
0.0054
:
g
per
pound
active
ingredient
handled.

14.
PTF
II
states:
Exposure
and
risk
for
mixer/
loaders
was
recalculated
based
on
the
proposed
method
using
a
default
penetration
factor
rather
than
a
calculated
one
and
only
those
workers
who
did
not
wear
Tyvek.
MOEs
are
acceptable
for
mixer/
loaders
who
load
for
as
many
as
1200
acres
a
day.

HED
response:
HED
also
calculated
exposures
and
risks
to
mixers/
loaders
using
the
same
methodology
as
the
Propanil
Task
Force
II,
but
using
a
dermal
penetration
value
of
50%,
rather
than
10%,
and
also
using
slightly
different
data.
The
dermal
data
differed
between
HED
and
the
PTF
II
in
several
ways:

°
HED
included
mixer/
loader
replicate
21
in
the
calculations,
but
PTF
II
did
not,

°
the
Head
Patch
data
differed
because
HED
adjusted
for
a
field
recovery
of
73%
versus
the
83%
field
recovery
adjustment
used
by
the
PTF
II,
and
°
for
replicate
27,
HED
used
576
pounds
active
ingredient
handled
per
day
as
listed
in
the
study
(
page
69),
however
PTF
II
used
1676
pounds
active
ingredient
handled
per
day.

The
inhalation
data
differed
between
HED
and
the
PTF
II,
since
HED
used
all
the
inhalation
exposure
values
for
the
mixers/
loaders
(
including
those
wearing
Tyvek
suits),
whereas
the
PTF
II
used
the
inhalation
exposure
values
for
the
mixers/
loaders
who
were
not
wearing
Tyvek
suits.

Using
HED's
calculations
and
normalizing
exposure
by
pounds
active
ingredient
handled,
the
unit
exposure
value
for
dermal
is
2.89
:
g/
lb
ai
handled
and
for
inhalation
is
0.0061
:
g/
lb
ai
handled.

HED
used
the
propanil­
specific
unit
exposure
values
from
the
PTF
II
study
to
estimate
exposure
and
risks
to
mixers/
loaders
supporting
aerial
applications
to
rice
(
see
Table
1).
At
the
6
lb
ai/
A
application
rate,
the
risks
exceeded
HED's
level
of
concern
(
i.
e.,
the
MOEs
were
less
than
300)
when
treating
1200
and
3200
acres
per
day.
Risks
were
below
HED's
level
of
concern
(
i.
e.,
the
MOEs
were
greater
than
300)
when
treating
500
and
350
acres
per
day.
At
the
3
lb
ai/
A
application
rate,
the
risks
exceeded
HED's
level
of
concern
(
i.
e.,
the
MOEs
were
less
than
300)
when
treating
3200
acres
per
day.
Risks
at
the
3
lb
ai/
A
rate
were
below
HED's
level
of
concern
(
i.
e.,
the
MOEs
were
greater
than
300)
when
treating
1200,
500,
and
350
acres
per
day.
Page
7
of
9
15.
PTF
II
states:
The
workers
monitored
in
this
study
did
work
appropriate
times
and
handled
appropriate
amounts
of
material.
Recreating
Scenarios
6
[
closed
mixing/
loading
liquid
formulations]
and
7
[
applying
sprays
with
enclosed
cockpits]
from
the
"
PHED
SURROGATE
EXPOSURE
GUIDE"
(
August,
1998)
allows
one
to
look
at
the
amounts
of
material
handled
for
both
the
mixer/
loader
and
the
pilot
as
well
as
the
acres
treated
by
the
pilot.
As
can
be
seen
from
the
.
.
.
data,
the
Geometric
Mean,
Average,
Median
and
Minimum
Pounds
Handled
for
the
propanil
study
all
exceed
those
same
values
for
the
data
in
PHED.

HED
response:
HED
believes
it
is
irrelevant
that
the
mixer/
loader
replicates
for
closed
mixing/
loading
of
liquid
formulations
in
PHED
involved
handling
of
less
active
ingredient
than
in
the
propanil­
specific
study.
The
maximum
number
of
pounds
active
ingredient
applied
to
an
acre
varies
widely
among
pesticide
active
ingredients
and,
as
long
as
the
studies
in
PHED
reflect
the
maximum
label
application
rate
for
that
active
ingredient,
the
results
would
appropriately
reflect
mixer/
loader
exposure.
HED's
position
is
that
the
PTF
II
propanil
study
could
underestimate
exposure
to
propanil
due
to
the
relatively
short
exposure
times
and
the
use
of
a
maximum
application
rate
that
averaged
slightly
less
than
half
of
the
maximum
labeled
application
rate.

16.
PTF
II
states:
Further,
the
hours
worked
[
in
the
PTF
II
propanil­
specific
study]
is
consistent
with
PHED
and
likewise
supports
that
the
propanil
data
from
the
Study
are
superior
to
PHED
with
its
pounds
handled.

HED
response:
HED
notes
that
the
mixer/
loader
(
without
Tyvek)
hours
worked
in
the
PFT
II
study
are
significantly
lower
than
mixer/
loader
hours
worked
in
PHED.
Using
the
geometric
mean,
the
study
hours
represent
only
approximately
3/
4
of
the
PHED
hours
and
using
the
average,
the
study
hours
represent
only
approximately
2/
3
of
the
PHED
hours.
Furthermore,
HED
notes
that
the
acres
treated
in
the
PTF
II
study
is
consistently
lower
using
the
geometric
mean,
average,
and
median
acres
treated.
Furthermore,
PHED
is
a
database
made
up
of
replicates
of
individual
workcycles
across
studies
and
is
not
intended
to
represent
the
duration
of
a
typical
workday.
The
PTF
II
propanil­
specific
study
protocol
specified
that
the
study
would
represent
a
typical
work
day.

17.
PTF
II
states:
Data
from
the
National
Agricultural
Aviation
Association's
survey
in
2004
show
that
the
average
flying
time
for
airplanes
in
aerial
application
scenarios
on
a
given
day
is
3­
4
hours.
In
the
present
study,
mixing
loading
times
ranged
from
0.37
to
5.3
hours
(
median
=
2.33
hours)
and
application
times
ranged
from
0.68
to
3.82
hours
(
median
=
1.59
hours).
These
mixer/
loader
and
pilot
replicate
times
are
not
extremely
Page
8
of
9
different
from
the
data
gathered
by
the
National
Agricultural
Aviation
Association
in
a
survey
performed
in
2004
with
aerial
applicators
throughout
the
US
(
Reference
5).
It
is
concluded
that
the
times
that
workers
handled
propanil
during
this
study
were
realistic
and
routine.

HED
response:
HED
notes
that
in
the
PTF
II
study,
the
mixer/
loader
times
and
the
application
times
were
both
significantly
less
than
the
average
flying
time
for
aerial
applications
found
in
the
NAAA
survey.
HED
further
notes
that
the
PTF
II
study,
which
is
supposed
to
represent
realistic
and
routine
exposure
times
for
aerial
applications
to
rice,
resulted
in
application
to
a
maximum
of
480
acres
per
day.

18.
PTF
II
states:
The
worker
exposure
study
with
propanil
involving
passive
dosimetry
was
conducted
according
to
typical
current
use
practices
followed
in
the
rice
industry.
The
amounts
of
product
mixed
and
applied
and
the
exposure
times
for
mixer/
loaders
and
pilots
were
typical
of
propanil
uses
and
more
representative
of
propanil
uses
than
the
data
currently
in
PHED
for
the
liquid
mixer/
loader
and
aerial
applicator
scenarios.
There
were
no
special
considerations
made
regarding
either
the
clothing
or
PPE
worn
by
mixer/
loaders
or
pilots
and
the
procedures
for
mixing
and
transferal
of
propanil
to
and
from
mixing
tanks
and
to
airplanes
were
consistent
with
industry
standards.
Because
of
the
consistency
in
rice
industry
procedures
and
practices,
the
dosimetry
data
are
considered
valid
measures
of
worker
exposure.

HED
response:
HED's
long
standing
policy
is
that
chemical­
specific
data
can
be
used
instead
of
PHED
data,
provided
that
the
chemical­
specific
data
are
equal
to
or
higher
quality
than
the
PHED
data.
HED
has
many
concerns
with
the
PTF
II
study,
including
the
use
of
the
typical
application
rate,
rather
than
maximum
and
the
relatively
short
exposure
times.
In
addition,
OPPTS
Series
875,
Occupational
and
Residential
Exposure
Test
Guidelines,
Group
A:
875.1200
(
dermal
exposure­
indoor
handler),
and
875.1400
(
inhalation
exposure­
indoor
handler)
clearly
require
a
minimum
of
15
replicates
for
each
exposure
scenario.
The
PTF
II
is
proposing
to
eliminate
4
mixer/
loader
replicates
(
due
to
wearing
Tyvek
suits
over
the
"
outer"
dosimeter)
and
another
replicate
was
eliminated
(
because
the
handler
mixed/
loaded
and
applied).
That
leaves
only
10
replicates
for
the
mixer/
loader
exposure
scenario.
PHED
scenario
6
(
closed
system
mixing/
loading
using
liquid
formulations)
has
16
to
22
replicates
for
the
dermal
(
non­
hands)
data,
31
replicates
for
the
hands
data,
and
27
replicates
for
the
inhalation
data.
This
PHED
scenario
is
rated
as
High
Confidence.
The
PTF
II
study
would
be
rated
as
low
confidence
for
the
dermal
data
due
to
the
lack
of
replicates.
Page
9
of
9
Table
1.
Propanil
Mixer/
Loader
Engineering
Control
Exposures
and
Risk
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
Area
Treated
Daily
(
acres)
Engineering
Control
Unit
Exposures
Engineering
Control
Dose
(
mg/
kg/
day)
Engineering
Control
MOE
(
Level
of
Concern
=
300)

Dermal
(
mg/
lb
ai)
Inhalation
(
µ
g/
lb
ai)
Dermal
Inhalation
Dermal
Inhalation
Combined
Dermal
+
Inhalation
Mixing/
Loading
Liquid
Concentrates
for
Aerial
Applications
Rice
(
PHED
data)
6
3200
0.0086
0.083
0.47
0.023
19
400
18
Rice
(
Propanil
Dosimetry
Data)
3200
0.0029
0.0061
0.18
0.0017
50
5400
56
Rice
(
PHED
data)
1200
0.0086
0.083
0.18
0.0085
51
1100
49
Rice
(
Propanil
Dosimetry
Data)
1200
0.0029
0.0061
0.068
0.00063
130
14000
150
Rice
(
PHED
data)
500
0.0086
0.083
0.074
0.0036
120
2500
110
Rice
(
Propanil
Dosimetry
Data)
500
0.0020
0.0061
0.028
0.00026
320
35000
360
Rice
(
PHED
data)
350
0.0086
0.083
0.052
0.0025
170
3600
160
Rice
(
Propanil
Dosimetry
Data)
350
0.0029
0.0061
0.02
0.00018
460
49000
510
Mixing/
Loading
Liquid
Concentrates
for
Aerial
Applications
Rice
(
PHED
data)
3
3200
0.0086
0.083
0.24
0.011
38
790
36
Rice
(
Propanil
Dosimetry
Data)
3200
0.0029
0.0061
0.09
0.00083
100
11000
110
Rice
(
PHED
data)
1200
0.0086
0.083
0.088
0.0043
100
2100
95
Rice
(
Propanil
Dosimetry
Data)
1200
0.0029
0.0061
0.034
0.00031
270
29000
300
Rice
(
PHED
data)
500
0.0086
0.083
0.037
0.0018
240
5100
230
Rice
(
Propanil
Dosimetry
Data)
500
0.0029
0.0061
0.014
0.00013
640
69000
720
Rice
(
PHED
data)
350
0.0086
0.083
0.026
0.0012
350
7200
330
Rice
(
Propanil
Dosimetry
Data)
350
0.0029
0.0061
0.0099
0.000091
910
99000
990
cc:
Margaret
Rice
Tom
Myers
