UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
SUBJECT:
Review
of
Worker
Exposure
Study
for
Pentachlorophenol
From:
Siroos
Mostaghimi,
Ph.
D.,
Environmental
Engineer
Team
One
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

To:
Adam
Heyward
PM#
34
Regulatory
management
Branch
II
Antimicrobials
Division
(
7510C)

Thru:
Winston
Dang,
Team
Leader
Team
One
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

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

DP
Barcode:
D256806
Pesticide
Chemical
No.:
063001
EPA
MRID
No.:

Review
Time:
20
Days
PHED:
N/
A
1
of
25
2
of
23
Action
Request
The
risk
and
Science
Support
Branch
(
RASSB))
has
been
requested
to
review
the
PCP
biomonitoring
study.
The
following
information
has
been
provided:

Title:
Inhalation
Dosimetry
and
Biomonitoring
Assessment
of
Worker
Exposure
to
Pentachlorophenol
During
Pressure­
Treatment
of
Lumber,
321
pages
Sponsor:
Pentachlorophenol
Task
Force
E.
John
Wilkinson
Vulcan
Chemicals
1101
30th
Street,
NW,
Suite
500
Washington,
DC
20007
Testing
Facility:
American
Agricultural
Services,
Inc.
404
E.
Chatham
Street,
Cary,
NC
27511
Analytical
Laboratory
Frances
Brookey
Morse
Laboratories,
Inc.
1525
Fulton
Avenue
Sacramento,
CA
95825
Author:
Mark
G.
Bookbinder,
Ph.
D.

Report
Dates:
April
23,
1999
Identifying
Codes:
AASI
Study
No.
AA980307;
Morse
Labs.
Proj.
No.
ML98­
0734­
PTF
CONCLUSIONS
The
basic
premise
of
this
study
was
that
PCP
exposure
may
be
estimated
from
biological
and
personal
air
monitoring
data
alone.
The
study
sponsor
relied
on
an
assumption
that
PCP
residues
excreted
in
human
urine
would
have
attained
steady
state
before
collection
of
the
first
sample.
This
assumption
was,
in
turn,
rooted
in
a
requirement
of
the
Study
Protocol
which
specified
that
"
Each
monitored
worker
will
have
worked
a
full
shift
(
approximately
8
hours)
on
each
work
day
of
the
two
weeks
prior
to
his
first
day
of
3
of
23
monitoring"
(
see
page
98).
However,
the
study
report
does
not
present
an
exposure
history
for
subjects
prior
to
biomonitoring
which
verifies
that
this
aspect
of
the
protocol
was
in
fact
enforced.

The
study
reported
very
little
information
about
the
study
subjects
beyond
their
body
weight.
Furthermore,
the
data
indicate
that
in
eight
of
twenty­
one
subjects
monitored,
PCP
levels
rose
significantly
over
the
three
days
of
urine
sample
collection.

Even
if
the
protocol
requirement
that
subjects
work
a
minimum
of
10
full­
shift
days
prior
to
participation
was
attained,
this
may
not
have
been
a
long
enough
exposure
period.
The
author
states
that
reported
half­
lives
for
urinary
elimination
of
PCP
in
humans
range
from
33
hours
to
20
days,
citing
ATSDR's
Toxicology
Profile
for
Pentachlorophenol.
Only
one
of
the
two
studies
cited
in
the
ATSDR
review
were
referenced
(
and
that
incorrectly)
in
this
report.
The
first,
Braun
et
al.
(
1979),
actually
references
a
study
in
which
volunteers
ingested
0.1
mg
PCP/
kg.
This
study
found
a
urinary
excretion
half­
life
of
33
hours
for
PCP.
The
second
study
(
not
cited
by
the
authors)
refers
to
a
study
by
Begley
et
al.
(
1977)
related
to
inhalation
exposure
experienced
by
wood
treatment
workers
prior
to,
during,
and
after
vacation.
The
urinary
excretion
half­
life
for
PCP
reported
was
19­
20
days.
It
should
be
noted
that
the
ATSDR
review
also
references
other
studies
that
suggest
that
elimination
of
PCP
is
biphasic,
and
that
the
kinetics
are
different
depending
on
whether
occupationally
exposed
humans
encounter
a
single
high­
level
exposure
(
when
shorter
half­
lives
can
be
expected)
or
whether
chronic
low­
level
exposure
occurs,
in
which
case
half­
lives
are
longer.
This
tends
to
support
the
supposition
that
the
longer
half­
life
values
apply
to
these
study
subjects.

It
should
also
be
pointed
out
that
almost
all
(
61/
66)
personal
air
sampling
results
returned
values
below
the
method
LOD,
and
only
one
data­
point
exceeded
the
LOQ,
possibly
due
to
inadequate
sensitivity
of
the
method
used.
Without
supporting
inhalation
and
dermal
exposure
monitoring
data
(
the
latter
was
not
collected
at
all),
it
is
difficult
to
further
assess
the
biological
monitoring
data.
4
of
23
EXECUTIVE
SUMMARY
This
report
reviews
a
1999
worker
exposure
study
sponsored
by
the
Pentachlorophenol
(
PCP)
Task
Force
and
Vulcan
Chemicals,
intended
to
quantify
total
worker
exposure
to
PCP
during
pressure
treatment
of
wood
poles
at
five
commercial
facilities
in
the
U.
S.
and
Canada.
PCP
is
a
wood
preservative
pesticide
registered
for
control
and
prevention
of
insect
infestations
and
to
prevent
fungal
decay
in
wood.
Two
PCP
pressure­
treatment
product
formulations,
a
solid
block
and
a
liquid
formulation,
were
used.

The
field
portion
of
the
study
was
conducted
by
American
Agricultural
Services,
Inc.
between
August
25
and
October
21,
1998.
The
analytical
phase
was
conducted
by
Morse
Laboratories.
Twenty­
four
hour
urine
(
N=
63)
and
personal
air
samples
(
N=
66)
were
collected
over
three
consecutive
days
from
21
and
22
workers,
respectively.
These
workers,
distributed
between
the
five
test
sites,
were
categorizable
into
five
job
categories.
A
total
of
18
Treatment
Operator
work
shifts,
6
Treatment
Assistant
work
shifts,
15
Test
Borer
work
shifts,
15
Load
Operator
work
shifts,
and
9
General
Helper
work
shifts
were
monitored.
The
wood
treatment
process
involved
a
total
of
26
individual
tasks;
each
job
category
performed
some
subset
of
these
tasks.

The
study
was
generally
well­
written
and
fairly
well­
organized.
Key
findings
included:

(
1)
Virtually
all
the
inhalation
exposure
monitoring
data
were
below
the
limit
of
detection
(
LOD).
Only
two
positive
values
(
N=
66)
were
reported,
and
only
one
data
point
achieved
the
level
of
quantitation
(
LOQ).

(
2)
Urinary
PCP
levels
measured
in
this
study
ranged
between
0.056
µ
moles/
L
(
the
lowest
detectable
level)
to
3.378
µ
moles/
L
(
N=
63).
For
purposes
of
comparison,
Versar
notes
the
following:

­
Published
Unexposed
Levels:
Analyses
of
urine
samples
from
unexposed
individuals
(
i.
e.
26
males
and
43
females,
ranging
in
age
from
6
to
87
years)
found
PCP
concentrations
ranging
from
0.05
to
3.6
µ
g/
L
(
Treble
&
Thompson,
1996).
This
is
0.187
nanomoles/
L
to
0.0135
micromoles/
L
in
urine;

­
Published
Exposed
Worker
Levels:
Maximal
urinary
concentrations
found
in
seven
sawmill
workers
where
PCP
was
used
to
treat
wood
during
a
7­
month
treatment
season
ranged
from
0.2
to
0.9
µ
moles/
L
(
Pekari
et
al.,
1991).

(
3)
The
biomonitoring
data
indicate
that
PCP
levels
were
highest
in
the
Treatment
Assistant
job
category,
followed
by
Treatment
Operators;
Load
Operators;
Test
Borers;
and
General
Helpers.
This
sequence
was
consistent
with
the
PCP
exposure
potential
of
the
tasks
each
group
of
workers
performed
and
the
number
of
the
tasks
the
worker
performed
in
the
wood
treatment
areas.
5
of
23
(
4)
For
eight
of
the
twenty­
one
workers
monitored,
PCP
levels
increased
significantly
with
time
over
the
three
consecutive
monitored
days,
suggesting
that
steady
state
levels
had
not
been
reached
in
these
workers.
Exposure
estimates
based
on
an
average
24
hour
urine
concentration
value
might
underestimate
the
total
PCP
exposure
for
these
workers.

(
5)
Twenty
three
urinary
creatinine
values
were
below,
and
five
urinary
creatinine
values
exceeded
the
normal
range
reported
in
the
literature
(
i.
e.
15
to
25
mg/
day,
Merck
Manual).
Individual
sample
coefficients
of
variation
(
i.
e.
three
samples
per
worker)
ranged
between
4.09
percent
and
32.12
percent.

(
6)
QA/
QC:
Field
fortified
sample
recoveries
ranged
between
73.6
percent
to
94.3
percent
for
urine
samples
and
between
85.2
percent
to
93.3
percent
for
air
samples.
These
values
were
used
to
correct
field
sample
data
for
sample
handling
and
storage
losses.
Laboratory
fortified
urine
sample
recoveries
ranged
between
101
percent
to
107
percent,
with
a
CV
of
5.5
percent
to
6.7
percent.
The
limit
of
detection
for
PCP
in
urine
samples
was
10
µ
g/
L
and
the
limit
of
quantitation
was
set
at
30
µ
g/
L
because
of
the
ubiquitous
presence
of
PCP
in
human
urine.
The
laboratory
fortified
air
sampling
tube
sample
recoveries
ranged
between
105
percent
and
110
percent,
with
a
CV
of
1
percent
to
5.9
percent.
The
limit
of
detection
and
limit
of
quantitation
were
2.0
µ
g/
section
and
6.0
µ
g/
section,
respectively.

This
exposure
study
met
most,
but
not
all,
of
the
requirements
specified
in
OPPTS
guidelines
875.1000,
875.1300,
and
875.1500.
Key
non­
compliance
and
other
issues
identified
included:

(
1)
It
is
not
clear
whether
the
air
sampling
methodology
used
was
sensitive
enough
to
successfully
detect
the
very
low
levels
to
be
expected
in
(
largely)
outdoor
exposure
situations.
The
protocol
(
see
page
118)
specified
that
the
method
validation
target
LOQ
would
be
1
ng/
L
or
300
ng
for
a
5
hour
sampling
cycle.
(
Note:
The
LOQ
actually
achieved
was
6
µ
g/
372
L
air,
or
16
ng/
L
air).
Very
little
discussion
regarding
the
validation
of
the
method
was
provided
(
see
page
216).
A
working
range
(
i.
e.
range
of
air
volumes
required
at
specific
air
concentrations
of
PCP)
for
the
method
used
was
not
given
in
the
text.
On
page
146,
a
table
of
desorption
efficiencies
is
given
for
the
method
at
0.5,
1.0
or
2.0
mg/
m3
PCP
in
air,
however,
these
air
concentrations
are
much
higher
than
those
measured
in
this
study.

For
comparison,
the
NIOSH
Method
#
5512
recommends
use
of
a
mixed
cellulose
ester
filter
and
a
25
mL
bubbler
containing
ethylene
glycol,
and
has
a
working
range
of
130
µ
g
to
1,130
µ
g/
m3
in
180
L
air
samples.
[
The
NIOSH
method
is
intended
for
use
at
higher
air
levels
of
PCP,
such
as
those
in
the
general
range
of
the
OSHA
PEL
(
i.
e.
500
µ
g/
m3),
and
these
methods
are
best
applied
in
high
exposure
indoor
venues.]
6
of
23
(
2)
No
dermal
exposure
monitoring
was
performed.
Guideline
875.1500
specifically
requires
that
both
dermal
and
inhalation
exposure
studies
be
conducted
along
with
biological
monitoring.
Without
supporting
inhalation
and
dermal
exposure
monitoring
data,
it
is
difficult
to
assess
the
biological
monitoring
data.

(
3)
The
basic
premise
of
the
study
was
that
"
total
exposure"
could
be
determined
by
measuring
a
three­
day
average,
steady­
state
PCP
concentration
in
human
urine.
It
could
not
be
confirmed
that
all
study
subjects
steady
state
had
been
reached
prior
to
biomonitoring.
According
to
the
protocol,
study
subjects
were
qualified
for
participation
only
if
they
had
worked
"
full
shift
(
approximately
8
hours)
on
each
work
day
of
the
two
weeks
prior
to..."
study
initiation.
No
work
exposure
history
was
provided,
so
that
this
key
issue
could
not
be
verified.

(
4)
Pharmacokinetic
data
for
PCP
were
not
presented
or
reviewed
in
any
detail,
and
published
data
were
not
well
described
when
cited.
The
author
cites
urinary
elimination
half­
lives
for
PCP
ranging
between
33
hours
and
20
days
(
ATSDR,
1997)
Further
examination
of
these
values
finds
that
the
former
value
relates
to
oral
administration
of
PCP
to
a
small
number
of
fasting
subjects,
and
the
latter
value
relates
to
inhalation
exposure.
It
is
likely
that
the
longer
half­
life
value
is
more
relevant
to
the
exposures
described
in
this
study.

(
5)
Little
information
beyond
body
weight
was
available
about
the
study
subjects
(
e.
g.,
exposure
history,
sex,
etc.).
Very
little
information
was
available
on
personal
protective
equipment
(
PPE)
worn
by
workers;
footnotes
in
data
tables
contain
the
only
description
of
PPE
worn
by
workers,
and
only
at
two
of
the
test
sites.

(
6)
According
to
a
1984
study
conducted
by
U.
S.
EPA
OPTS
(
cited
in
the
study
report),
a
typical
87
kg
wood
treatment
worker
would
be
expected
to
adsorb
between
112
and
293
µ
g
PCP/
kg
body
weight/
day
by
all
routes.
This
range
of
PCP
exposure
was
much
higher
than
the
highest
total
absorption
of
15.3
µ
g
PCP/
kg
body
weight/
day
reported
in
this
study.
The
discrepancy
was
not
explained
in
the
study
report.

(
7)
Guideline
875.1500
specifically
requires
that
15
replicates
be
evaluated
for
each
exposure
scenario.
Six
Treatment
Assistant
replicates
and
nine
General
Helper
replicates
were
used
to
evaluate
PCP
exposures
in
the
study.

(
8)
Guideline
875.1300
for
inhalation
exposure­­
outdoor
requires
that
inhalation
absorption
be
normalized
from
the
pump
rate
of
1.0
L/
min
to
an
inhalation
rate
of
1,740
L
per
minute
for
light
work.
In
this
study,
the
inhalation
absorption
was
normalized
to
1,000
L
per
minute.
7
of
23
STUDY
REVIEW
Background
Pentachlorophenol
(
PCP)
is
a
wood
preservative
pesticide
registered
for
the
pressure
treatment
of
certain
wood
products
to
control
and
prevent
insect
infestation
and
prevent
fungal
decay
in
wood.
The
stated
purpose
of
this
study
was
to
quantify
the
total
worker
exposure
to
PCP
during
pressure
treatment
and
butt­
treatment
of
wood
poles
at
five
commercial
facilities.
Results
are
to
be
used
in
support
of
reregistration
of
pentachlorophenol.

This
study
was
sponsored
by
the
Pentachlorophenol
Task
Force
and
Vulcan
Chemicals.
The
field
portion
of
the
study
was
conducted
by
American
Agricultural
Services,
Inc.
between
August
25
and
October
21,
1998.
The
analytical
phase
was
conducted
by
Morse
Laboratories.
Field
trial
notebooks
and
raw
data
are
to
be
archived
at
the
Crystal
City,
VA
facility
of
SRA
International,
Inc.

Study
Setting
This
exposure
study
was
conducted
at
five
facilities:
three
pressure
treatment
facilities
in
the
U.
S.
(
i.
e.
Bay
Minette,
Alabama;
New
Brighton,
Minnesota;
Arlington,
Washington)
and
two
facilities
in
Canada
(
i.
e.
New
Westminster
and
Prince
George,
British
Columbia),
designated
as
Facilities
A,
B,
C,
D,
and
E,
respectively.
These
facilities
were
selected
to
represent
the
spectrum
of
treatment
processes
currently
practiced
in
North
America.

Urine
(
N=
63)
and
personal
air
samples
(
N=
66)
were
collected
over
three
consecutive
days
from
21
and
22
workers,
respectively.
Urine
PCP
levels
and
inhalation
exposure
was
calculated
for
each
job
category
of
workers,
statistically
analyzed
and
ranked
to
profile
PCP
exposure
scenarios
at
the
wood
treatment
facilities.

Wood
Treatment
Process
Table
I
of
the
study
report
profiles
PCP
formulations
and
equipment
used,
and
treatment
practices
at
each
pressure
treatment
facility.
Two
formulations
were
used
in
this
study.
The
first
was
a
1­
ton
solid
product
containing
86%
active
ingredient
(
a.
i.)
PCP
(
Vulcan
Block
Penta
®
)
and
the
second
was
a
liquid
formulation
containing
34.4
percent
a.
i.
PCP
(
Pentacon­
40
Liquid).
The
former
was
diluted
in
either
P­
9
oil
or
Number
2
Oil,
while
the
latter
was
diluted
in
Number
2
Oil
only.
The
final
PCP
content
of
the
treatment
solutions
"
varied
with
the
facility
and
the
species
of
wood
treated,
and
ranged
between
5.00
percent
and
7.48
percent."

At
each
site,
pressure
treatment
of
poles
was
performed
by
the
same
basic
process.
Workers
stacked
untreated
poles
onto
wheeled
metal
trams
on
railroad
tracks
leading
into
the
treatment
cylinders
.
The
8
of
23
trams
were
then
pulled
into
the
cylinders
and
the
cylinder
doors
closed.
Treating
solution
was
pumped
from
storage
tanks
into
the
cylinder
at
high
pressure
(
85­
175
PSI),
and
allowed
to
permeate
the
wood
of
the
poles
for
4­
24
hours
at
elevated
temperatures
(
180­
220
0F)
or
at
ambient
temperature.
After
treatment,
excess
treating
solution
was
removed
from
the
cylinders
and
poles
by
maintaining
vacuum
in
the
cylinder
for
several
hours.
The
treated
poles
on
trams
were
then
pulled
onto
a
concrete
drip
pad,
where
excess
treating
solution
was
allowed
to
drip
from
the
poles
and
trams.
After
the
treated
poles
cooled,
the
treated
poles
were
transported
to
the
storage
area.
To
determine
the
content
and
depth
of
penetration
of
PCP,
workers
collected
wood­
core
samples
from
selected
poles
using
electrically
powered
drills.
If
the
treatment
did
not
meet
specifications,
the
wood
poles
were
retreated.
The
treatment
parameters
for
each
charge
of
wood
poles
in
five
facilities
are
provided
in
Table
II
of
the
study
report.

The
number
of
charges
of
wood
poles
treated
at
each
site
and
the
quantity
of
PCP
retained
by
wood
poles
in
each
site
during
the
monitoring
period
are
summarized
in
Table
1,
below.

Table
1.
Number
of
Charges
Treated
and
Quantity
of
PCP
Retained
by
Wood
Poles
in
Each
Facility
During
the
Monitoring
Period
Test
Site
Charges
fully
or
Partially
Monitored
Total
lb
treatment
solution
retained
Total
lb
PCP
retained
Mean
lb
PCP
retained/
charge
A
8
5697
303
37.9
B
4
38610
1931
483
C
5
64592
4775
955
D
3
20047
1243
414
E
14
27728
1525
109
Study
Demographics
The
pressure
treatment
process
consisted
of
26
specific
tasks,
each
having
different
worker
exposure.
Twenty­
two
workers
were
sorted
into
five
job
categories
(
see
Table
2,
below)
at
five
commercial
facilities.
Job
categories
were:
Treatment
Operator;
Treatment
Assistant;
Loader
Operator;
Test
Borer;
and
General
Helper.
[
The
suite
of
work
tasks
performed
by
each
worker
at
all
five
facilities
were
recorded
by
study
personnel;
see
Tables
III
to
Tables
VII
of
the
study
report].
The
main
tasks
performed
by
each
job
category
of
workers
and
the
number
of
worker
cycles
monitored
are
summarized
in
Table
3,
below.
Based
on
the
nature
and
number
of
work
tasks
performed,
Treatment
Operators
and
Treatment
Assistants
were
most
likely
to
experience
the
highest
exposures
to
PCP.
9
of
23
PCP
exposure
was
monitored
during
a
total
of
20
Treatment
Operator
work
shifts,
6
Treatment
Assistant
work
shifts,
15
Test
Borer
work
shifts,
15
Load
Operator
work
shifts,
and
9
General
Helper
work
shifts.
Details
on
all
work
shifts
monitored
are
summarized
in
Table
XIV
of
the
study
report.

Table
2.
Workers
Monitored
in
Each
Wood
Treatment
Facility
Workers
Monitored
on
Each
Site
Facilit
y
ID
Treatment
Operator
Treatment
Assistant
Tester
Borers
Loader
Operator
General
Helpers
Total
Number
of
Workers
A
1
1
1
1
1
5
B
1
­­
1
1
2
5
C
1
­­
1
1
1
4
D
1
­­
1
1
­­
3
E
2
1
1
1
­­
5
Engineering
Controls
and
Personal
Protective
Equipment
The
author
stated
(
see
pg.
12):
"...
each
subject
wore
the
work
clothing
and
protective
clothing
and
equipment
that
he/
she
would
normally
wear
while
working..."
Footnotes
on
Tables
III
to
VII
state
that:
1)
At
Site
A:
Treatment
Operators
and
Treatment
Assistants
wore
uniforms,
rubber
gloves
and
goggles
when
close
to
PCP,
and
Test
Borers
wore
rubber
gloves
to
take
cores;
2)
At
Site
E:
Treatment
Operators,
Treatment
Assistants
and
Test
Borers
wore
short­
sleeved
shirts,
Treatment
Assistants
wore
leather
gloves
to
handle
cylinder
doors
and
leads,
and
Test
Borers
did
not
wear
gloves
to
take
sample
cores.
No
further
information
was
provided
concerning
protective
clothing
worn
or
equipment
used
by
the
workers.

It
should
be
noted
that
all
of
the
Facilities
were
either
entirely
open
or
roofed,
except
for
Facility
C,
where
the
treatment
process
was
housed
in
a
totally
enclosed
building.

Meteorology
The
study
authors
provided
three
such
data­
sets.
The
first
was
on­
site
ambient
weather
data,
including:
minimum/
maximum/
mean
insolation,
windspeed
(
range
=
3.1
to
12.8
mph)
and
direction;
air
temperature
(
range
=
39
to
78.6
F.);
and
relative
humidity
(
range
=
53.8
percent
to
97
percent).
The
second
data­
set
10
of
23
reflected
data
from
test­
site
vicinity
airports,
including:
miles
to
weather
station,
air
temperature,
percent
relative
humidity,
windspeed
and
direction.
Finally,
minimum
and
maximum
air
temperature
and
relative
humidity
were
measured
at
three
locations
inside
the
Facility
C
enclosed
building.
11
of
23
Table
3
Job
Categories
Monitored
during
the
Study
Period
Job
Category
Tasks
Performed
Potential
for
Exposure
Replicates
Analyzed
Work
Cycles
Monitored
Treatment
Operator
Open/
close
cylinder
doors
High
urine
=
18
air
=
19
20
­
all
sites
Clean
PCP
residues
from
cylinders
High
Open
valves
to
transfer
PCP
treating
solution
between
tanks
and
cylinders
Low
Perform
tram
maintenance/
positioning
High
Move
lumber
between
treatment
cylinders
and
drip
pads
High
Treatment
Assistant
Perform
many
work
tasks
also
performed
by
Treatment
Operators
High
6
6
­
sites
A
&
E
Mix
treating
solutions
High
Filter
cleaning
and
drip
pad
cleaning
high
Load
Operator
Operate
self­
propelled
vehicles
to
move
poles
onto
and
off
the
trams
Low
15
15
­
all
sites
Move
charges
into
and
out
of
the
treatment
cylinders
using
self­
propelled
loaders.
Low
Perform
certain
out­
of­
cab
tasks
such
as
handling
chains
and
tram
placements
High
Test
Borer
Take
pole
cores
to
test
for
PCP
penetration
High
15
15
­
all
sites
12
of
23
Routinely
test
PCP
samples
in
labs
Low
Perform
other
laboratory
&
QC
duties
Low
General
Helpers
Occasional
­
perform
various
labor
and
cleanup
duties
in
treatment
areas
High
9
9
­
sites
A
&
B
Routinely
­
Perform
labor
and
cleanup
duties
in
areas
other
than
the
treatment
areas
Low
TOTAL:
work
shifts
monitored;
samples
urine
=
63
air
=
64
65
Exposure
Monitoring
Procedures
1.
Biological
Monitoring
On
each
monitoring
day,
individual
workers
were
provided
with
a
Urisafe
®
urine
collection
container
and
a
storage
cooler
stocked
with
blue
ice.
All
the
urine
voided
within
24
hours
was
collected
and
stored
in
the
coolers.
The
study
personnel
collected
all
urine
samples
from
workers
the
following
day
and
measured
the
volume
of
urine
samples.
Urine
samples
were
acidified
by
adding
3
drops
of
37%
aqueous
HCl
per
100
mL
of
urine
and
then
frozen.

2.
Air
Monitoring
While
performing
his/
her
tasks,
each
worker
was
equipped
with
an
air
sampling
device
consisting
of
a
silica
gel
air
sampling
tube
(
SKC#
226­
22)
and
an
air
pump.
The
inlet
of
the
air
sampling
device
was
attached
to
the
worker's
collar
and
positioned
downward,
and
the
pump
was
attached
to
the
worker's
belt.
Air
sampling
was
conducted
at
a
flow
rate
of
1.0
L
per
minute.
Study
personnel
calibrated
and
started
air
pumps
at
the
beginning
of
a
day
and
recorded
the
air
sampling
time
at
the
end
of
the
day.

QA/
QC
Sample
Handling
&
Storage
Urine
samples
were
stored
on
blue
ice
in
coolers.
Field
study
staff
received
the
samples
in
coolers
from
workers.
Urine
samples
were
then
refrigerated,
acidified,
labeled,
caps
sealed,
and
placed
inside
locking
polyethylene
bags.
Aliquots
were
stored
in
Qorpak
#
7892T
fluorinated
high­
density
polyethylene
bottles,
also
on
ice.
Air
samples
and
urine
samples
were
then
frozen
in
a
cooler
containing
dry
ice
and
shipped
on
13
of
23
dry
ice
to
Morse
Laboratories,
Inc.
for
extraction
and
analysis.
Samples
were
stored
at
­
15
C.
to
­
25
C.
and
extracted
within
27
days
of
collection.
Creatinine
levels
in
worker
urine
samples
were
determined
as
a
QC
procedure
to
gauge
whether
all
urine
voided
within
24
hours
were
collected.

Sample
History
Table
VIII
of
the
study
report
chronicles
sample
collection
dates,
shipment
dates,
dates
received
at
the
laboratory,
extraction
and
analysis
dates.
Most
samples
were
analyzed
within
two
to
three
weeks.

Test
Product
Analysis
The
protocol
required
that
samples
of
the
test
substance
and
finished
application
mixture
(
50­
100
mls)
be
collected
at
each
test
site
from
each
lot
of
test
substance
used.
Analytical
results
were
not
available
for
review.

Trapping
Efficiency
­
Air
Sampling
Tubes
Trapping
efficiency
was
determined
by
connecting
two
silica
gel
tubes
in
series.
The
front
tube
was
spiked
with
either
60
or
6000
µ
g/
section
levels
of
PCP
and
then
connected
in
series
to
the
rear
tube.
The
tubes
were
then
attached
to
an
air
sampling
pump,
which
was
operated
for
five
hours
at
a
flow
rate
of
1
L
per
minute.
The
percent
of
PCP
migrating
into
the
rear
air
sampling
tubes
was
determined.
The
results
(
see
Table
XI
of
the
study
report)
suggest
that
100
percent
of
airborne
PCP
residues
were
trapped
by
the
front
air
sampling
tube.

Analytical
Methodology
The
method
used
to
analyze
the
urine
samples
was
proprietary
(
i.
e.
Morse
Method
Meth­
113,
Rev.
2,
dated
July,
1998,
see
page
137),
as
was
the
air
sample
analysis
method
(
i.
e.
Morse
Method
Meth­
114,
dated
July,
1998,
see
page
262).
The
latter
method
was
based
on
an
older
method
(
Vulcan
Materials
Co.,
Determination
of
Pentachlorophenol
in
Ambient
Air,
Method:
PENTA­
90,
File
#
903.18,
March
1,
1982).

1.
Urine
Samples:
A
300
uL
aliquot
of
each
urine
sample
was
mixed
with
sodium
bisulfite,
acidified
and
digested
under
heat
with
concentrated
HCL
(
to
hydrolyze
PCP
conjugates),
extracted
with
benzene,
and
an
aliquot
of
the
organic
layer
was
transferred
to
a
solid
phase
extraction
column.
The
column
was
eluted
with
benzene/
ethyl
acetate,
and
evaporated
to
dryness,
300
uL
of
MTBSTFA
was
added
to
the
solution
to
convert
PCP
to
its
t­
butyldimethylsilyl
derivative.
The
derivative
was
quantified
via
gas
chromatography
and
mass
selective
detection.

2.
Air
Samples:
PCP
residues
(
vapor
and
particulate)
were
extracted
from
silica
gel
sorbent
by
sonicating
in
25
mL
of
acetonitrile
for
20
minutes.
An
aliquot
of
the
extract
was
then
analyzed
by
a
high
performance
liquid
chromatography
(
HPLC)
with
using
a
3
cm
X
4.6
mm
Brownlee
Spheri­
5
Amino
column
and
UV
detection
at
254
nm.
14
of
23
Limits
of
Detection
(
LOD)
and
Quantitation
(
LOQ)

1.
Urine
Samples:
The
LOD
for
PCP
in
urine
samples
was
10
µ
g/
L.
Because
PCP
is
ubiquitous
in
the
environment,
and
background
levels
of
PCP
were
present
in
all
urine
samples
during
method
development,
the
LOQ
was
set
at
30
µ
g/
L.

2.
Air
Samples:
The
LOD
was
2.0
µ
g/
section.
The
LOQ
was
6.0
µ
g/
section.

Laboratory
Recovery
1.
Urine
Samples:
The
analytical
method
for
PCP
in
urine
samples
was
validated
by
fortifying
sets
of
seven
unexposed
urine
samples
at
levels
of
0,
30,
60,
and
600
µ
g/
L
(
see
Table
IX
of
the
study
report).
Laboratory
fortification
recoveries
are
summarized
in
Table
4,
below.

2.
Air
Samples:
The
analytical
method
for
PCP
in
air
sampling
tubes
was
validated
by
spiking
sets
of
seven
silica
gel
filled
air
sampling
tubes
at
levels
of
0,
6,
60,
600
µ
g/
section.
The
laboratory
fortification
air
sample
recoveries
can
be
found
in
Table
X
of
the
study
report
and
are
also
summarized
in
Table
4,
below.

Table
4.
Laboratory
Fortification
Sample
Recoveries
­
Urine
and
Air
Samples
Amount
Added
(
µ
g/
L)
Percent
Recovery
of
PCP
from
Urine
Samples
Amount
Added
(
µ
g/
L)
Percent
Recovery
of
PCP
from
Air
Sampling
Tubes
Mean
Std.
Deviation
%
CV
Mean
Std.
Deviation
%
CV
0
<
LOQ
n/
a
n/
a
0
<
LOQ
n/
a
n/
a
30
106
6.96
6.6
6
107
1.11
1
60
107
5.88
5.5
60
105
1.72
1.6
600
101
6.74
6.7
600
110
6.74
5.9
Field
Fortification
Recovery
Recovery
values
obtained
for
both
field
fortified
urine
samples
and
air
sampling
tubes
from
four
of
the
five
facilities
were
reported
in
Table
XVIII
and
Table
XIX
of
the
study
report.
The
data
are
summarized
in
Table
5,
below.
Note:
There
were
no
fortified
field
recovery
samples
collected
from
Facility
D
because
urine
samples
and
spiking
solutions
were
delivered
too
late
to
the
site
(
due
to
a
shipping
problem).
15
of
23
In
these
tables,
"
Field
Controls"
were
fortified
in
the
field,
held
on
blue
ice
for
24
hours,
then
frozen.
"
Traveling
Controls"
were
fortified
and
immediately
frozen.

Recovery
values
for
both
fortified
urine
and
air
sampling
tubes
were
all
within
the
allowable
tolerance
(
i.
e.
75
percent
to
125
percent)
specified
by
OPPTS
guidelines.
The
mean
recoveries
for
each
site
were
used
to
correct
urine
samples
or
air
inhalation
samples
for
losses
of
PCP
during
sample
handling.

1.
Urine
Samples:
Field
fortified
samples
(
i.
e.
0,
30,
60,
and
600
µ
g/
L)
were
prepared
in
100
mL
of
control
urine
from
unexposed
subjects.

2.
Air
Samples:
Field
fortified
samples
were
spiked
with
0,
60,
or
3,000
µ
g
PCP
per
tube.
The
fortified
air
sampling
tubes
were
connected
to
an
air
sampling
pump
and
purged
with
air
for
5
hours
at
a
flow
rate
of
1
Liter
per
minute
before
shipment
to
the
laboratory
along
with
field
samples.

Storage
Stability
Recovery
The
stability
of
PCP
in
urine
samples
and
air
sampling
tubes
within
the
sample
storage
period
of
30
days
was
tested.
The
results
shown
in
Table
XIII
of
the
study
report
suggested
that
PCP
was
stable
within
30
days.

Table
5
Field
Fortification
Sample
Recoveries
­
Urine
and
Air
Samples
Test
Site
Percent
Recovery
of
PCP
from
Urine
Samples
Percent
Recovery
of
PCP
from
Air
Sampling
Tubes
Mean
Standard
Deviation
Mean
Standard
Deviation
A
84.8
7.2
93.3
7.8
B
73.6
5.5
85.2
3.74
C
87.3
7.7
85.7
24.8
E
94.3
11.2
87.2
15.9
Calculations
"
Total
PCP
exposure"
was
estimated
from
steady­
state
PCP
residues
measured
in
urine
samples
(
see
Table
XXII
in
the
study
report).
Raw
PCP
urinary
levels
were
divided
by
the
daily
urinary
output
(
Liters/
day).
The
PCP
concentration
values
were
corrected
for
field
fortification
recovery.
Dividing
by
the
individual
subject's
body
weight
(
kg)
yielded
a
"
total
exposure"
value.
The
urine
concentration
values
were
adjusted
with
an
86
percent
factor
to
account
for
the
fraction
of
the
dose
excreted.
[
The
origin
of
the
latter
value
was
not
fully
discussed
in
the
study
report
and
an
incorrect
citation
was
given
16
of
23
(
Braun,
et
al.
(
1978)
should
be
Braun,
et
al.
(
1979)).]
In
the
Braun
et
al.
(
1979)
study,
fasting
volunteers
ingested
0.1
mg/
kg
sodium
pentachlorophenate.
Residues
appeared
in
the
urine
(
74
percent
as
pentachlorophenol,
12
percent
as
a
PCP­
glucuronide
conjugate)
and
4
percent
in
feces.
Note:
This
value
may
not
be
appropriate
where
residues
are
primarily
dermally
absorbed
as
in
this
study.]

"
Daily
inhalation
exposure"
data
may
be
found
in
Table
XXV
in
the
study
report.
The
author
states
that
"...
values
less
than
the
LOD
(
i.
e.
2
µ
g/
section)
are
expressed
as
1
µ
g
for
calculation
purposes.
Values
less
than
the
LOQ
(
i.
e.
6
µ
g/
section)
are
expressed
as
3
µ
g/
section
for
calculation
purposes.
If
all
tubes
in
a
monitoring
period
contained
residues
less
than
the
LOD,
the
entire
period
was
assigned
a
value
of
1
µ
g
for
calculation."
Air
concentrations
of
PCP
were
normalized
over
an
8­
hour
workday,
and
worker
exposure
values
were
calculated
by
dividing
by
the
individual
worker's
body
weight,
and
by
scaling
up
the
pump
rate
of
1
liter/
minute
(
60
liters/
hour)
to
an
inhalation
rate
of
1,000
L
per
hour
for
light
work.
It
should
be
noted
that
OPPTS
guideline
875.1300
requires
that
normalization
calculations
employ
a
standard
breathing
rate
of
1,740
L
per
hour
for
light
work.

RESULTS
Biological
Monitoring
PCP
residues
in
three
consecutive
24­
hour
urine
samples
from
21
workers
(
i.
e.
63
samples)
were
quantified,
and
a
PCP
exposure
value
was
calculated
for
each
worker
(
see
Table
XXII
of
the
study
report).
The
author
identified
this
value
as
"
Total
PCP
Exposure."
Values
for
each
job
category
of
workers
are
summarized
in
Table
6,
below.

°
Urinary
PCP
levels
measured
in
this
study
ranged
between
0.056
umoles/
L
(
the
lowest
detectable
level)
to
3.378
umoles/
L
(
N=
63).
For
purposes
of
comparison,
Versar
notes
the
following:

­
Published
Unexposed
Levels:
Urine
samples
from
unexposed
individuals
(
i.
e.
26
males
and
43
females,
ranging
in
age
from
6
to
87
years)
found
PCP
concentrations
ranging
from
0.05
to
3.6
µ
g/
L
(
Treble
&
Thompson,
1996).
This
is
0.187
nmoles/
L
to
0.0135
umoles/
L
in
urine;

­
Published
Exposed
Worker
Levels:
Maximal
urinary
concentrations
found
in
seven
sawmill
workers
where
PCP
was
used
to
treat
wood
during
a
7­
month
treatment
season
ranged
from
0.2
to
0.9
µ
moles/
L
(
Pekari
et
al.,
1991).

°
PCP
levels
in
urine
were
highest
in
Treatment
Assistants,
followed
by
Treatment
Operators;
Load
Operators;
Test
Borers;
and
General
Helpers.
This
sequence
was
consistent
with
the
PCP
exposure
potential
of
the
tasks
each
group
of
workers
performed
and
the
number
of
the
tasks
the
worker
performed
in
the
wood
treatment
areas.

°
Table
XXII
of
the
study
report
indicates
that
for
eight
of
twenty­
one
workers
monitored,
PCP
levels
increased
significantly
with
time
over
the
three
consecutive
monitored
days,
suggesting
that
steady
state
levels
had
not
been
reached
in
these
workers.
Exposure
estimates
based
on
an
average
24
hour
17
of
23
urine
concentration
value
might
underestimate
the
total
PCP
exposure
for
these
workers.

°
Creatinine
levels
in
each
urine
sample
are
provided
in
Table
XXIII
of
the
study
report.
The
author
did
not
interpret
these
data.
However,
according
to
the
Merck
Manual,
the
normal
range
for
urinary
creatinine
values
is
15
to
25
mg/
day.
Five
values
were
found
below
the
lower
limit
of
this
range.
Twenty­
three
values
were
found
below
the
upper
limit
of
this
range.
Individual
sample
coefficients
of
variation
(
i.
e.
three
samples
per
worker)
ranged
between
4.09
percent
and
32.12
percent.

Table
6.
"
Total"
PCP
Exposure
as
Estimated
from
Biomonitoring
Results
In
Five
Job
Categories
at
Wood
Treatment
Facilities
Parameters
"
Total"
PCP
Exposure1
(
µ
g/
kg/
day)

Treatment
Assistant
Treatment
Operator
Load
Operator
Test
Borers
General
Helpers
#
Replicates
6
18
15
15
9
Minimum
3.78
1.45
0.2
0.42
0.58
Maximum
24.5
12
8.4
5.27
2.16
Arith.
Mean
15.3
4.81
2.69
2.39
1.39
Std
Deviation
6.83
3.68
2.8
1.65
0.531
1.
Corrected
for
field
spike
recovery
and
86%
absorption
rate
value
Personal
Air
Monitoring
Tables
XXIV
and
XXV
of
the
study
report
summarize
personal
air
sampling
data
collected.
PCP
inhalation
exposure
data
are
summarized
below
in
Table
7.

PCP
residues
in
air
sampling
tubes
were
below
LOD
(
2
µ
g/
section)
for
all
workers
except
for
two
Treatment
Operators
(
one
at
Facility
A
and
the
other
at
Facility
C),
for
whom
the
residue
levels
in
air
sampling
tubes
were
above
the
LOD
but
at
or
below
the
LOQ.
This
is
consistent
with
the
fact
that
Treatment
Operators
and
Treatment
Assistants
were
the
workers
closest
to
the
PCP
sources
while
performing
their
tasks.
18
of
23
Table
7.
Inhalation
Exposures
to
PCP
among
Five
Wood
Treatment
Job
Categories
Parameter
s
Inhalation
Exposure
(
µ
g/
kg
body
weight/
day)

Treatment
Operator
Treatment
Assistant
Test
Borers
Load
Operator
General
Helpers
#
Replicates
19
6
15
15
9
Arith.
Mean
0.3
0.215
0.173
0.162
0.185
Std
Deviation
0.336
0.047
0.041
0.036
0.03
It
should
be
noted
that
the
maximum
inhalation
exposure
was
1.62
µ
g/
kg­
day,
measured
in
a
single
day's
sample
from
a
Treatment
Operator
at
Facility
A.
This
was
also
the
only
value
(
1/
66)
that
reached
the
limit
of
quantitation
for
PCP
in
an
air
sample.

COMPLIANCE
Compliance
with
OPPTS
Series
875,
Occupational
and
Residential
Exposure
Test
Guidelines,
Group
A:
Applicator
Exposure
Monitoring
Test
Guidelines
(
i.
e.
Subdivision
U);
Guidelines,
875.1000,
875.1300,
and
875.1500,
is
critical
for
determining
whether
a
study
is
acceptable
to
the
Agency.
The
itemized
checklist
below
describes
compliance
with
the
major
technical
aspects
of
these
guidelines
875.1000
"
Background
for
Application
Exposure
Monitoring
Test
Guidelines
°
Informed
consent
is
required.
This
criterion
was
met.
Twenty
two
workers
who
participated
in
this
study
were
provided
with
a
consent
form
which
detailed
the
nature
of
the
study.
A
copy
of
a
(
nonexecuted
example
form
was
available
for
review.

°
The
product
must
be
handled
and
applied
using
recommended
equipment,
application
rates,
and
typical
work
practices,
as
specified
on
the
label.
This
criterion
was
met.
One
of
two
formulations,
either
the
solid
block
PCP
formulation
(
Vulcan
Block
Penta
®
)
or
the
liquid
formulation
(
Pentacon­
40
®
)
,
was
mixed
with
light
oil
and
applied
onto
wood
poles
according
to
the
instructions
on
the
labels.
The
labels
for
both
PCP
formulations
were
provided
in
the
study
report.

°
Study
conditions
must
be
consistent
with
typical
use
of
the
product.
This
criterion
was
met.
The
study
was
conducted
with
liquid
and
solid
block
PCP
formulations
at
commercial
facilities
under
the
normal
conditions
specified
in
the
labels.
19
of
23
°
The
monitoring
period
must
be
appropriate
for
the
substance
tested
­
sufficient
to
collect
measurable
residues
but
not
excessive
so
that
residue
loss
occurs.
This
criterion
was
met.
Biological
monitoring
was
conducted
over
three
consecutive
24­
hour
days.
Inhalation
exposure
monitoring
periods
ranged
between
323
and
553
liters
of
air
(
target
air
flow
rate
was
60
liters/
hour).

°
Exposure
should
be
measured
for
each
different
activity,
whenever
possible.
This
criterion
was
partially
met.
The
pressure
treatment
of
wood
poles
with
PCP
involves
a
combination
of
26
types
of
tasks
with
differing
potential
for
PCP
exposure.
These
tasks
were
performed
by
five
job
categories
of
worker
performing
various
combinations
of
some
subset
of
these
26
tasks.

°
For
outdoor
exposure
monitoring,
at
least
five
replicates
from
each
of
at
least
three
sites
for
each
job
function
....
should
be
monitored......
Each
exposure
situation
must
be
evaluated
using
at
least
15
replicates.
This
criterion
was
partially
met.
Five
workers
were
monitored
at
three
of
five
sites;
at
two
others
only
three
or
four
subjects
were
monitored.

875.1300
"
Inhalation
Exposure
­
Outdoor"

°
The
analytical
procedure
must
be
capable
of
measuring
exposure
to
1
µ
g/
hr.
This
criterion
was
met.
The
limit
of
quantitation
for
air
sampling
tubes
was
6
µ
g/
section.
The
tubes
were
used
for
a
8­
hour
period.
Thus,
the
analytical
method
used
in
this
study
was
capable
of
measuring
exposure
of
0.75
µ
g
per
hour.

°
Trapping
efficiency
for
monitoring
media
must
be
documented.
This
criterion
was
met.
The
trapping
efficiency
study
was
documented
in
section
2.3.2
(
Method
Validation)
of
this
study
report.

°
Air
sampler
should
be
tested
for
breakthrough.
This
criterion
was
met.
The
breakthrough
study
for
PCP
in
silica
gel
air
sampling
tubes
was
conducted.
The
results
indicate
that
100
percent
of
PCP
collected
on
the
front
section
of
the
air
sampler
did
not
escape
to
the
rear
section
of
the
air
sampler.

°
Extraction
efficiency
is
considered
acceptable
if
the
lower
limit
of
the
95%
confidence
interval
is
greater
than
75
percent,
based
on
a
minimum
of
seven
replications
per
fortification
level,
used
to
calculate
the
mean
and
standard
deviation
for
recovery.
This
criterion
was
met.
The
lower
limit
of
the
95
percent
confidence
interval
developed
from
seven
replicates
per
fortification
level
was
greater
than
75
percent
for
all
three
fortification
levels
of
6,
60,
600
µ
g/
section.

°
If
trapping
media
are
to
be
stored
after
exposure,
a
stability
test
for
PCP
must
be
documented.
Media
must
be
stored
under
the
same
conditions
as
field
samples.
Replicate
samples
should
be
extracted
and
analyzed
immediately
before
and
at
appropriate
periods
during
storage.
This
criterion
was
probably
met.
A
stability
test
for
PCP
residues
in
urine
samples
and
air
sampling
tubes
was
conducted
under
the
same
conditions
as
field
samples
and
documented
in
the
study
report.
However,
the
data
were
not
available
for
review.
20
of
23
°
If
extracts
from
field
samples
are
to
be
stored
prior
to
analysis,
a
stability
test
must
be
conducted.
Extracts
of
fortified
samples
are
stored
under
the
same
conditions
as
the
extracts
from
field
samples.
Each
sample
should
be
analyzed
immediately
before
and
at
appropriate
times
during
storage.
This
criterion
was
probably
satisfied.
Extracts
were
stored
for
anywhere
between
1
day
and
11
days
(
see
page
58
of
the
study).

°
Appropriate
air
sampling
media
should
be
selected.
This
criterion
was
partially
met.
A
proprietary
sampling
and
analytical
method
was
used
which
specified
use
of
silica
gel
sorbent
tubes.
This
medium
has
been
used
to
collect
PCP.
NIOSH
Method
5512
notes,
without
comment,
that
such
media
"
was
used
by
a
NIOSH
contractor
for
analyzing
samples
containing
pentachlorophenol."
However,
it
is
questionable
whether
the
method
was
adequately
sensitive
under
the
conditions
of
the
study.

°
Personal
monitors
should
be
arranged
with
the
intake
tube
positioned
downward,
near
the
nose
level
of
the
subject.
This
criterion
was
met.

°
Field
calibration
of
personal
monitors
should
be
performed
at
the
beginning
and
the
end
of
the
exposure
period.
This
criterion
was
met.
Air
sampling
pumps
were
pre­
and
post­
calibrated.

°
Field
fortification
samples
and
blanks
are
analyzed
for
correction
of
residue
losses
occurring
during
the
exposure
period.
Fortified
samples
and
blanks
should
be
fortified
at
the
expected
residue
level
of
the
actual
field
samples.
Fortified
blanks
should
be
exposed
to
the
same
weather
conditions,
but
in
a
clean
environment.
This
criterion
was
partially
met.
Field
fortified
urine
and
air
sampling
tube
samples
were
prepared
and
exposed
to
the
simulated
field
conditions.
The
field
fortification
recoveries
were
used
to
correct
for
residue
losses
during
the
exposure
period.
However,
most
of
the
data
were
non­
detect
and
fortification
levels
were
much
higher
than
in
the
few
positive
samples.

°
Field
data
should
be
documented,
including
chemical
information,
area
description,
weather
conditions,
application
data,
equipment
information,
information
on
work
monitored,
sample
numbers,
exposure
time,
and
any
other
observations.
These
criteria
were
met.

°
A
sample
history
sheet
must
be
prepared
by
the
laboratory
upon
receipt
of
samples.
This
criterion
was
met.

°
The
analytical
method
should
be
documented
and
appropriate.
This
criterion
was
partially
met.
The
analytical
method
was
documented,
and
reportedly,
validated
before
the
initiation
of
the
study.
However,
when
it
was
validated,
and
what
the
results
were,
was
not
clear.
The
validation
data
were
not
available
for
review.

°
For
outdoor
exposure
monitoring,
at
least
five
replicates
at
each
of
at
least
three
sites
for
each
job
function
should
be
monitored.
This
criterion
was
partially
met.
Five
subjects
were
monitored
over
three
days
at
three
of
the
five
sites.
Three
and
four
subjects
were
monitored
at
the
other
two
sites.
21
of
23
875.1500
"
Biological
Monitoring"

°
Study
feasibility
should
be
based
on
information
on
chemical
profiles
such
as
metabolism
and
excretion.
This
criterion
was
partially
met.
The
author
did
not
thoroughly
review
PCP
metabolism
and
excretion,
and
some
information
cited
was
not
accurately
represented.
No
data
relating
to
dermal
absorption
were
presented.

°
Pharmacokinetics
testing
is
necessary
before
field
studies
are
initiated.
This
criterion
was
not
met.

°
Biomonitoring
data
must
be
supported
by
dermal
and
inhalation
exposure
data.
This
criterion
was
not
met.

°
The
potential
for
adsorption
of
the
test
substance
or
urinary
metabolites
to
the
collection
bottles,
stability,
and
recovery
from
the
sampling
medium,
and
possible
breakdown
during
storage
should
be
considered.
This
criterion
was
met.
Field
fortified
urine
samples
were
prepared
and
the
recoveries
were
used
to
correct
for
any
possible
losses
during
handling,
shipping,
and
storage
of
urine
samples.

°
Urine
collection
should
continue
for
a
full
24
hour
period.
At
least
one
baseline
pre­
exposure
24
hour
urine
sample
should
be
collected.
Sample
completeness
can
be
determined
by
measuring
creatinine
levels
in
urine
samples.
This
criterion
was
partially
met.
No
baseline
pre­
exposure
24
hour
urine
samples
were
collected
from
the
workers
in
this
study.
Creatinine
levels
in
urine
samples
were
determined,
but
not
interpreted.

°
For
outdoor
exposure
monitoring,
at
least
five
replicates
at
each
of
at
least
three
sites
for
each
job
function
...
should
be
monitored.
Each
exposure
situation
must
be
evaluated
using
at
least
15
replicates.
This
criterion
was
partially
met.
Five
subjects
were
monitored
over
three
days
at
three
of
the
five
sites.
Three
subjects
each
were
monitored
at
the
other
two
sites.

DATA
GAPS
AND
OTHER
ISSUES
Additional
issues
and
concerns
not
mentioned
above
are
summarized
below:

°
The
basic
premise
of
the
study
was
that
"
total
exposure"
could
be
determined
by
measuring
a
threeday
average,
steady­
state
PCP
concentration
in
human
urine.
According
to
the
protocol,
study
subjects
were
qualified
for
participation
only
if
they
had
worked
"
full
shift
(
approximately
8
hours)
on
each
work
day
of
the
two
weeks
prior
to..."
study
initiation.
It
is
probable
that
for
at
least
eight
of
twenty­
two
subjects,
steady
state
had
not
been
reached
prior
to
biomonitoring.
No
work
exposure
history
was
provided,
so
that
this
key
issue
could
not
be
verified.
Since
the
reported
half­
lives
for
urinary
elimination
of
PCP
in
human
range
from
33
hours
to
20
days
(
ATSDR,
1997),
if
steady
state
had
not
been
achieved,
PCP
exposure
may
have
been
underestimated.

°
References
cited
in
this
report
were
few
and
those
cited
were
not
extremely
helpful
in
interpreting
the
22
of
23
data.
This
is
surprising
given
the
wealth
of
information
on
biological
monitoring
for
pentachlorophenol.

°
Background
information
about
the
urinary
elimination
rate
of
PCP
(
86
percent)
used
to
correct
the
raw
data
was
not
fully
described
in
the
study
report.
It
appears
that
this
value
relates
to
an
oral
administration
of
PCP
to
fasting
subjects.
Dermal
exposure
may
have
been
a
more
important
route
of
exposure
for
study
subjects.

°
Guideline
875.1500
specifically
requires
that
15
replicates
be
evaluated
for
each
exposure
scenario.
Six
Treatment
Assistant
replicates
and
nine
General
Helper
replicates
were
used
to
evaluate
PCP
exposures.

°
It
is
not
clear
whether
the
air
sampling
methodology
used
was
sensitive
enough
to
successfully
detect
the
very
low
levels
to
be
expected
in
a
(
largely)
outdoor
exposure
situation.
The
protocol
(
see
page
118)
specified
that
the
method
validation
target
LOQ
would
be
1
ng/
L
or
300
ng
for
a
5
hour
sampling
cycle.
(
Note:
The
LOQ
actually
achieved
was
6
µ
g/
372
L
air,
or
16
ng/
L
air).
Very
little
discussion
regarding
the
validation
of
the
method
was
provided
(
see
page
216).
A
working
range
(
i.
e.
range
of
air
volumes
required
at
specific
air
concentrations
of
PCP)
for
the
method
used
was
not
given
in
the
text.
On
page
146,
a
table
of
desorption
efficiencies
is
given
for
the
method
at
0.5,
1.0
or
2.0
mg/
m3
PCP
in
air,
however,
these
air
concentrations
are
much
higher
than
those
measured
in
this
study.

For
comparison,
the
NIOSH
Method
#
5512,
which
recommends
use
of
a
mixed
cellulose
ester
filter
and
a
25
mL
bubbler
containing
ethylene
glycol,
has
a
working
range
of
130
µ
g
to
1,130
µ
g/
m3
in
180
L
air
samples.
The
NIOSH
method
is
intended
for
use
at
higher
air
levels
of
PCP,
such
as
those
in
the
general
range
of
the
OSHA
PEL,
which
is
500
µ
g/
m3.
The
NIOSH
methods
are
best
applied
in
high
exposure,
indoor,
venues.

In
this
study,
only
one
of
64
samples
was
quantifiable
at
the
LOQ
(~
16
µ
g/
m3).

°
Guideline
875.1300
for
inhalation
exposure­­
outdoor
requires
that
inhalation
absorption
be
normalized
from
the
pump
rate
of
1
L/
min
to
an
inhalation
rate
of
1,740
L
per
minute
for
light
work.
In
this
study,
the
inhalation
absorption
was
normalized
to
1,000
L
per
minute.

REFERENCES
ATSDR.
(
1994).
Toxicological
Profile:
Pentachlorophenol
(
update).
Department
of
Health
&
Human
Services,
Atlanta,
GA.

Begley
J,
Reichert
AW,
Siesmen
AW,
et
al.
1977.
Association
between
renal
function
tests
and
pentachlorophenol
exposure.
Clin
Toxicol
11:
97­
106.

The
Merck
Manual
of
Diagnosis
and
Therapy.
(
1977).
Eds:
Berkow
R.
and
Talbott
JH.
Rahway,
NJ:
23
of
23
Merck,
Sharp
and
Dohme
Research
Laboratories.

Pekari
K;
Luotamo
M;
Jarvisalo
J,
Lindroos
L,
Aitio
A.
(
1991).
Urinary
excretion
of
chlorinated
phenols
in
saw­
mill
workers.
Int.
Arch.
Occup.
Environ.
Health
63(
1):
57­
62.

Treble
RG,
Thompson
TS.
(
1996).
Normal
values
for
pentachlorophenol
in
urine
samples
collected
from
a
general
population.
J.
Anal.
Toxicol.
20(
5):
313­
317.

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