
Page
1
of
39
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
Memorandum
DATE:
March
10,
2006
SUBJECT:
MGK­
264:
REVISED
Occupational
and
Residential
Exposure
Assessment
for
the
Reregistration
Eligibility
Decision
Document
PC
Code:
057001
DP
Barcode:
D324674
FROM:
Steven
Weiss,
Industrial
Hygienist
Reregistration
Branch
3
Health
Effects
Division
(
7509C)

Thru:
William
Donovan,
Risk
Assessor
Reregistration
Branch
3
Health
Effects
Division
(
7509C)

TO:
Cathryn
OConnell,
Chemical
Review
Manager
Reregistration
Branch
2
Special
Review
and
Reregistration
Division
(
7508C)

The
attached
assessment
is
the
updated
occupational
and
residential
exposure
and
risk
estimates
for
MGK­
264
to
support
HED's
reregistration
eligibility
decision
(
RED)
document.
There
have
been
several
changes
have
been
made
since
the
October
1,
2004
version
of
this
assessment
which
include:

C
The
previous
versions
of
this
assessment
have
been
based
primarily
on
the
maximum
application
rates
listed
on
the
master
label
(
ML)
submitted
to
the
Agency
by
MGK
on
April
14,
2003.
On
November
21,
2005
MGK
has
formally
requested
the
following
changes
be
made
to
the
maximum
application
rates:

*
General
outdoor
spray
applications
from
2.2
lb
ai/
A
to
0.3
lb
ai/
A
*
General
crack
and
crevice
or
spot
spray
applications
from
1.6
to
0.05
lb
ai/
1000
ft2
*
Ready­
to­
use
trigger
pump
spray
applications
from
1.6
to
0.1
lb
ai/
1000
ft2
*
General
surface
spray
applications
from
0.4
to
0.01
lb
ai/
1000
ft2
*
Direct
applications
of
solution
to
livestock
from
0.2
lb
ai/
gal
to
2
oz
of
0.2%
Page
2
of
39
spray/
animal
(
0.00025
lb
ai/
animal)
*
Ready­
to­
use
wipe
applications
to
horses
from
0.00018
lb
ai/
wipe
to
0.0000826
lb
ai/
wipe
(~
37.5
mg
ai/
wipe)
*
Indoor
surface
spray
applications
from
0.4
to
0.01
lb
ai/
1000
ft2
*
Indoor
space
spray
applications
with
aerosol
can
from
0.006
to
0.001
lb
ai/
1000
ft3
*
Dust
application
of
pets
10%
to
0.33%
formulation
with
0.00248
lb
ai/
pet
*
Application
of
insect
repellants
from
8%
to
5%

C
The
following
maximum
rate
changes
have
also
been
made
based
on
clarification
by
MGK:

*
0.0022
lb
ai/
per
collar
for
ready­
to­
use
(
RTU)
pet
collars
*
0.0177
lb
ai/
16
oz
can
for
RTU
aerosol
spray
can
applications
*
5.35
grams
ai/
ft2
for
indoor
application
of
dust
formulation
*
0.0028
lb
ai/
pet
for
direct
application
to
pets
*
0.0056
lbs
ai
per
horse
for
RTU
paste
applications
to
horses
*
0.5%
is
the
maximum
concentration
for
RTU
residual
pump
spray
(
trigger
spray)
*
1.77
mg
ai/
spray
event
for
metered
release
products
*
0.011
lb
ai/
100
ft2
for
dust
applied
to
carpeted
and
other
indoor
surfaces
C
For
estimating
handler
exposure,
assumptions
for
area
treated
or
amount
handled
per
day
were
revised
to
the
following:

*
Livestock
application
from
400
animals/
day
to
25
animals/
day
for
occupational
*
Applications
to
carpet
with
dust
from
0.5
lbs
product/
day
to
256
ft2/
day
for
residential
*
Applications
to
indoor
areas
with
dust
from
2
lbs
product/
day
to
1,000
ft2/
day
for
occupational
*
Applications
with
RTU
residual
pump
spray
from
2
to
1
gallons/
day
for
occupational
*
Applications
with
RTU
residual
pump
spray
from
1000
ft2/
day
to
0.25
gallons/
day
for
residential
*
Indoor
applications
using
low
pressure
handwand,
backpack,
and
handgun
from
40,000
ft2/
day
to
11,200
ft2/
day
C
Residential
postapplication
oral
and
dermal
exposure
for
application
of
1.18%
dust
applied
to
carpeted
surfaces
at
a
rate
of
0.011
lb
ai/
100
ft2
was
estimated
C
Inhalation
risk
was
estimated
for
2
air
changes
per
hour
(
i.
e.
for
a
commercial
bldg)
in
addition
to
0.18
air
changes
per
hour
(
i.
e.
for
a
house).
Page
3
of
39
Table
of
Contents
Executive
Summary
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Page
4
of
38
1.0
Occupational
and
Residential
Exposure/
Risk
Assessment
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Page
5
of
38
1.1
Hazard
Concerns
for
MGK­
264
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Page
5
of
38
1.2
Physical
and
Chemical
Properties
of
MGK­
264
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Page
8
of
38
1.3
Use
Patterns
and
Formulations
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Page
9
of
38
2.0
Occupational
Exposures
and
Risks
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Page
10
of
38
2.1
Handlers
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Page
10
of
38
2.1.1
Data
Sources
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11
of
38
2.1.2
Assumptions
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Page
12
of
38
2.1.3
Exposure
Scenarios
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Page
14
of
38
2.1.4
Equations
for
Exposure/
Risk
Estimates
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Page
14
of
38
2.1.5
Risk
Summary
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16
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38
2.2.1
Data
and
Assumptions
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Page
18
of
38
2.2.2
Equations
for
Exposure/
Risk
Estimates
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Page
19
of
38
2.2.3
Risk
Summary
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Page
19
of
38
3.0
Non­
Occupational/
Residential
Exposures
and
Risks
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Page
21
of
38
3.1
Handlers
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21
of
38
3.1.1
Data
and
Assumptions
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Page
21
of
38
3.1.2
Exposure
Scenarios
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Page
23
of
38
3.1.3
Equations
for
Exposure/
Risk
Estimates
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23
of
38
3.2
Postapplication
Activities
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3.2.1
Data
Sources
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25
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38
3.2.2
Equations
for
Exposure/
Risk
Estimates
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Page
29
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38
3.2.3
Risk
Summary
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Page
35
of
38
Appendices
(
14
pages
of
Excel
Spread
Sheets)
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Page
38
of
38
Page
4
of
39
Executive
Summary
MGK­
264
is
an
insecticide
synergist.
Synergists
are
chemicals
that
lack
pesticidal
effects
of
their
own
but
enhance
the
pesticidal
properties
of
other
chemicals.
MGK­
264
is
usually
formulated
with
natural
pyrethrins,
piperonyl
butoxide
(
PBO),
or
synthetic
pyrethroids.
It
has
numerous
and
varied
commercial
and
residential
applications,
is
available
in
a
broad
range
of
formulations,
and
is
applied
by
wide
variety
of
application
methods.
Commercial
uses
include
application
non­
food
plants,
applications
in
food
and
non­
food
handling
commercial
and
agricultural
structures
and
outdoor
premises,
housing
for
veterinary
and
farm
animals,
and
direct
application
to
veterinary
and
non­
food
animals.
In
addition,
MGK­
264
is
currently
registered
for
use
in/
on
all
food
items
in
food
handling
establishments
where
food
and
food
products
are
held,
processed,
or
prepared
to
control
nuisance
and
food
product
contaminating
insects
such
as
ants,
cockroaches,
fleas
and
ticks.
For
residential
applications,
it
is
used
to
control
insects
both
inside
the
home,
and
outside
on
gardens,
lawns
and
ornamentals,
patios,
and
other
outdoor
structures,
and
is
directly
applied
to
pets.

HED's
Hazard
Identification
Assessment
Review
Committee
(
HIARC)
met
to
determine
appropriate
toxicological
endpoints
of
concern
for
MGK­
264.
The
toxicological
endpoints
used
to
complete
the
occupational
and
residential
risk
assessments
have
been
extracted
from
the
June
25,
2004
MGK­
264
HIARC
report.

The
short­
and
intermediate­
term
(
non­
cancer)
dermal
occupational
and
residential
risk
assessment
for
MGK­
264
is
based
on
a
LOAEL
of
61
mg/
kg/
day
from
a
multi­
generation
reproduction
study.
A
dermal
absorption
factor
of
10
percent
was
selected
based
on
a
study
using
human
volunteers.
The
incidental
oral
assessment
for
children
is
also
based
on
the
LOAEL
of
61
mg/
kg/
day.
The
short­
and
intermediate­
term
(
non­
cancer)
inhalation
occupational
and
residential
risk
assessment
for
MGK­
264
is
based
on
a
LOAEL
of
0.01
mg/
L
(
1.86
mg/
kg/
day),
which
was
defined
in
a
90­
day
inhalation
study
in
rats.
Long­
term
exposure
to
MGK­
264
are
not
expected
for
current
registered
uses.

For
MGK­
264
exposures
via
the
oral,
dermal
and
inhalation
routes,
MOEs
of
less
than
1,000
are
a
risk
concerns
for
occupational
and
residential
scenarios.
The
level
of
concern
is
based
on
10x
to
account
for
interspecies
extrapolation
to
humans
from
the
animal
test
species,
10x
to
account
for
intraspecies
sensitivity
and
10X
for
the
use
of
a
LOAEL,
rather
than
a
NOAEL.
The
dermal
and
inhalation
margins
of
exposure
were
not
combined
for
the
handler
assessment
because
the
toxicity
endpoints
for
the
dermal
and
inhalation
routes
of
exposure
are
based
on
different
toxicological
effects.
Toddler
dermal
and
oral
MOEs
are
based
on
the
same
NOAEL
and
will
be
combined
in
HED's
aggregate
risk
assessment
for
MGK­
264.

MGK­
264
is
applied
with
several
types
of
application
equipment
 
including
groundboom,
low­
pressure
handwand
sprayers,
high
pressure
handwand
sprayers,
handgun
sprayers,
hose­
end
sprayers,
and
thermal
misters/
foggers,
pump­
trigger
sprayers,
foggers,
aerosol
cans,
shampoos,
dips,
wipes,
roll­
ons,
impregnated
collars,
and
dust
(
puffer
or
shaker)
cans.

With
exception
of
a
dog
shampoo
study,
no
chemical­
specific
exposure
data
was
submitted
for
MGK­
264.
Occupational
and
residential
exposure
estimates
were
based
the
one
Page
5
of
39
study
with
best
available
surrogate
data
for
other
exposure
scenarios.
Handler
exposure
estimates
were
based
on
surrogate
data
from
EPA's
Pesticide
Handler
Exposure
Database
(
PHED)
Version
1.1
,
Outdoor
Residential
Exposure
Task
Force
(
ORETF),
Chemical
Manufacturers
Association
(
CMA)
Antimicrobial
Exposure
Assessment
Study,
and
two
proprietary
studies
(
trigger
pump
spraying
with
propoxur
and
shampoo
application
with
carbaryl).
For
re­
entry
dermal
exposure
to
treated
foliage,
default
values
for
residue
dissipation
were
used
with
proprietary
transfer
coefficient
data
from
the
Agricultural
Re­
entry
Task
Force
(
ARTF)
database.
For
postapplication
exposure
following
indoor
treatments
surrogate
data
from
the
Non­
Dietary
Exposure
Task
Force
(
NDETF)
was
used
for
the
percent
of
residue
that
can
be
transferred
for
dermal
and
oral
exposure
pathways.
Toddler's
oral
and
dermal
and
oral
exposure
from
dogs
treated
with
shampoo
were
estimated
using
a
study
that
measured
postapplication
exposure
to
MGK­
264.
Dermal
exposure
from
insect
repellents
applied
to
skin
were
estimated
based
on
data
from
the
Residential
Exposure
Joint
Venture
(
REJV),
National
Pesticide
Use
Survey.
Exposure
calculations
and
exposure
factor
inputs
were
based
on
HED's
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments
(
except
where
noted).

With
the
exception
of
3
occupational
handler
scenarios
assessed,
estimated
MOEs
were
not
a
risk
concern
for
all
scenarios
at
the
baseline
level
(
i.
e
single
layer
with
no
gloves,
and
no
respirator).
Dermal
MOEs
for
mixing
loading
and
applying
liquids
with
low
pressure
handwand,
high
pressure
handwand,
and
backpack
sprayers
are
not
a
risk
concern
if
gloves
are
worn.
For
residential
handlers,
none
of
the
scenarios
had
risks
of
concern
(
i.
e.
all
MOE
>
1,000)

For
occupational
dermal
contact
with
treated
foliage
during
re­
entry
activities,
MOEs
are
greater
than
1,000
on
the
day
of
application
for
all
of
the
crops
assessed.

Several
of
the
residential
uses
have
risk
concerns
(
i.
e.
MOEs
<
1,000)
for
postapplication
exposure
including
indoor
surface
and
space
sprays,
dusts
applied
to
carpets,
and
insect
repellents
applied
to
the
skin.

Data
gaps
exist
for:
(
1)
Dermal
and
inhalation
handler
monitoring
for
mixing/
loading/
applying
liquids
for
fogger
applications;
(
2)
dermal
and
inhalation
handler
monitoring
for
mixing/
loading/
applying
liquids
for
dip
applications;
and
(
3)
air
monitoring
for
compact
metered
release
products;
and
(
4)
deposition
data
for
dusts
applied
to
carpets
(
followed
by
vacuuming.)

Print­
outs
of
Microsoft
Excel
Spreadsheets
used
to
estimate
all
occupational
and
residential
MOEs
in
this
assessment
are
included
in
the
appendices.

1.0
Occupational
and
Residential
Exposure/
Risk
Assessment
1.1
Hazard
Concerns
for
MGK­
264
HED's
Hazard
Identification
Assessment
Review
Committee
(
HIARC)
met
to
determine
appropriate
toxicological
endpoints
of
concern
for
MGK­
264.
The
toxicological
endpoints
that
were
used
to
complete
the
occupational
and
residential
risk
assessments
are
summarized
below,
which
have
been
extracted
from
the
MGK­
264
HIARC
report
(
June
25,
2004).
Page
6
of
39
Dermal
Route
(
non­
cancer)

The
short­,
intermediate­,
and
long­
term
(
non­
cancer)
dermal
risk
assessment
for
MGK­
264
is
based
on
a
LOAEL
of
61
mg/
kg/
day
from
a
multi­
generation
reproduction
study.
The
LOAEL
was
based
on
slight
decreases
in
maternal
body
weight.
Long­
term
exposures
to
MGK­
264
(
i.
e.,
greater
than
6
months)
are
not
expected
for
current
registered
uses.
A
dermal
absorption
factor
of
10
percent
was
selected
based
on
a
study
using
human
volunteers.

Inhalation
Route
(
non­
cancer)

The
short­,
intermediate­,
and
long­
term
(
non­
cancer)
inhalation
risk
assessment
for
MGK­
264
is
based
on
a
LOAEL
of
0.01
mg/
L
(
1.86
mg/
kg/
day),
which
was
defined
in
a
90­
day
inhalation
study
in
rats.
The
LOAEL
was
based
on
the
presence
of
hyperplasia
and
metaplasia
in
the
larynx.
Long­
term
exposure
to
MGK­
264
(
i.
e.,
greater
than
6
months)
are
not
expected
for
current
registered
uses.

Oral
Route
(
non­
cancer)

The
(
non­
cancer)
incidental
oral
risk
assessment
for
MGK­
264
is
based
on
a
LOAEL
of
61
mg/
kg/
day
from
a
multi­
generation
reproduction
study.
The
LOAEL
was
based
on
slight
decreases
in
maternal
body
weight.

Non­
cancer
Level
of
Concern
(
LOC)

HED's
level
of
concern
(
LOC)
for
MGK­
264
oral,
dermal
and
inhalation
exposures
is
1,000
(
i.
e.,
a
margin
of
exposure
(
MOE)
less
than
1,000
exceeds
HED's
level
of
concern)
for
occupational
and
residential
scenarios.
The
level
of
concern
is
based
on
10X
to
account
for
interspecies
extrapolation
to
humans
from
the
animal
test
species,
10X
to
account
for
intraspecies
sensitivity
and
10X
for
the
use
of
a
LOAEL,
rather
than
a
NOAEL.

Cancer
The
Carcinogenicity
Peer
Review
Committee
(
CPRC)
classified
MGK­
264
as
a
Group
C
­
Possible
Human
Carcinogen
based
on
statistically
significant
increases
mainly
in
benign
liver
adenomas
in
both
sexes
of
mice
at
doses
approaching
the
limit
dose
and
on
increases
in
benign
thyroid
follicular
tumors
in
male
rats
at
doses
considered
to
be
adequate
to
assess
carcinogenic
potential.
The
CPRC
determined
that
a
quantification
of
cancer
risk
is
not
required
because
of
the
Group
C
classification
and
the
lack
of
concern
for
mutagenicity
and
support
from
SAR
(
TXR
No.
0011577).

Acute
Toxicity
The
toxicology
data
base
is
adequate
to
characterize
the
toxicity
of
MGK­
264.
MGK­
264
is
placed
in
Toxicity
Category
IV
for
acute
oral
toxicity
and
dermal
irritation
and
in
Toxicity
Category
III
for
acute
dermal
toxicity
and
dermal
irritation.
An
acute
inhalation
toxicity
study
Page
7
of
39
and
a
dermal
sensitization
study
is
not
available.

Body
Weight
Since
the
adverse
effects
for
the
dermal
endpoint
are
based
on
a
reproductive
study,
the
body
weight
of
an
average
adult
female
(
i.
e.,
60
kg)
was
used
to
estimate
dermal
exposure.
The
adverse
effects
for
the
inhalation
endpoint
are
based
on
an
inhalation
study
where
the
effects
were
observed
in
males
and
females,
therefore,
the
body
weight
of
an
average
adult
(
i.
e.,
70
kg)
was
used
to
estimate
inhalation
exposure.
Page
8
of
39
CH
2
N
O
O
C8H17
1.2
Physical
and
Chemical
Properties
of
MGK­
264
Chemical
Structure
Empirical
Formula
C17H25NO2
Common
name
N­
octylbicycloheptene
dicarboximide
Company
experimental
name
MGK­
264
IUPAC
name
N­(
2­
ethylhexyl)­
8,9,10­
trinorborn­
5­
ene­
2,3­
dicarboximide
CAS
name
4,7­
Methano­
1H­
isoindole­
1,3(
2H)­
dione,
2­(
2­
ethylhexyl)­
3a,
4,7,7a­
tetrahydro­

CAS
Registry
Number
113­
48­
4
Chemical
Class
Insecticide
synergist
Known
Impurities
of
Concern
None
Melting
point/
range
N/
A
Molecular
Weight
275
Boiling
point/
range
155­
161
°
C
@
1
mm
Hg.

pH
6.9;
typical
range
of
6.8
to
7.2
Density
1.049
±
0.003
g/
mL
@
20
°
C
Water
solubility
15
±
3
µ
g/
mL
@
25
°
C
Solvent
solubility
Miscible
in:
Acetone,
Methanol,
Isopropanol,
Petroleum
Ether,
Concoco
LPA
(
petroleum
distillate),
Ethyl
Acetate,
Toluene,
Chloroform,
Acetonitrile,
Cyclo
Solv
53
(
aromatic
petroleum
distillate)
and
Isopar
M
(
petroleum
distillate)

Vapor
pressure
1.84
±
0.49
x
10­
5
mm
Hg
@
25
°
C
Dissociation
constant
(
pKa)
N/
A
Octanol/
water
partition
coefficient
Log(
KOW)
Log
P
=
3.61
&
3.80
for
isomers
1
&
2,
respectively,
at
24
°
C
UV/
visible
absorption
spectrum
Not
available
Page
9
of
39
1.3
Use
Patterns
and
Formulations
MGK­
264
is
used
in
agricultural,
commercial,
and
residential
settings.
MGK­
264
is
formulated
as
an
emulsifiable
concentrate,
as
well
as
a
number
of
ready
to
use
formulations
such
as
aerosol
cans,
foggers,
trigger
pump
sprayers,
shampoos,
pastes,
wipes,
dusts,
etc.

Table
1
summarizes
the
major
use
sites,
maximum
rates,
and
type
of
equipment
used
to
apply
MGK­
264
based
on
the
Master
Label
(
ML)
submitted
to
the
Agency
by
MGK
on
April
14,
2003
(
except
where
noted),
updated
November
21,
2005
MGK
submission,
and
subsequent
communications
with
MGK.

Table
1.
Summary
of
Maximum
Application
Rates
for
MGK­
264
Use
Site
and
Application
Equipment
Application
Rate
f
Outdoor
Groundboom
0.3
lb
ai/
acre
Handgun
Low
Pressure
Handwand
Backpack
Sprayer
High
Pressure
Handwand
Hose­
end
Sprayer
ULV
Fogger
for
Mosquito
Abatement
a
0.07
lb
ai/
acre
Indoor
Handgun
0.01
lb
ai/
1000ft2
Low
Pressure
Handwand
Backpack
Sprayer
Fogger
or
Mist
Generator
b
0.006
lb
ai/
1000ft3
Ready­
to­
use
Foggers
c
0.0064
lb
ai/
5000ft3
Shaker
Can
(
dust/
powder
formulation)
0.011
lb
ai/
100
ft2
Metered
Release
d
1.77
mg
ai/
spray
event
Crack
&
Crevice
or
Spot
Low
Pressure
Handwand
0.05
lb
ai/
1000ft2
Backpack
Sprayer
Handgun
Trigger­
pump
Sprayer
0.042
lb
ai/
gallon
Aerosol
Cans
0.0177
lb
ai/
16
oz
can
Livestock
Handgun
0.00025
lb
ai/
animal
Low
Pressure
Handwand
Backpack
Sprayer
Ready­
to­
use
Paste
0.056
lb
ai/
animal
Ready­
to­
use
Wipes
e
0.08
grams
ai/
wipe
Pets
Trigger­
pump
Sprayer
0.042
lb
ai/
gallon
Ready­
to­
use
Wipes
e
0.08
grams
ai/
wipe
Pour­
on
Or
Spot­
on
0.07
lb
ai/
gallon
Shaker
Can
(
dust/
powder
formulation)
0.00248
lb
ai/
pet
Dip
Applications
0.0021
lb
ai/
gallon
Mousse,
Soap,
Lotion,
Gel,
Comb,
or
Roll­
on
0.035
lb
ai/
gallon
Shampoo
0.07
lb
ai/
gallon
Ready­
to­
use
Collar
0.0022
lb
ai/
collar
Skin/
Clothing
Spray
or
Lotion
0.08
mg
ai/
mg
of
product
Foam
Injected
Into
Wall
Voids
5.8
g
ai/
3ft3
void
a.
MGK
reports
that
wide
area
mosquito
abatement
uses
will
no
longer
be
supported.
b.
MGK
reports
that
the
rate
of
0.5
lb
ai/
1000
ft3
for
space
spraying
pet
premises
is
listed
on
the
master
label
was
an
error.
The
maximum
rate
should
be
0.006
lb
ai/
1000
ft3
(
same
as
rate
that
is
listed
for
indoor
residential
spaces).
c.
Product
labels
say
each
one
6­
oz
fogger
containing
1.71%
ai
treats
5000
ft3
(
0.01
lb
ai/
1000ft2
for
treated
area
with
8
ft
ceilings
)
d.
MGK
reports
that
indoor
metered
release
products
dispense
1.77
mg
ai
every
15
minutes
e.
Rate
for
ready­
to­
use
wipes
based
on
information
provided
to
SRRD
from
MGK
Page
10
of
39
f.
Maximum
rates
are
listed.
Not
every
use
site
and
application
rate
from
ML
is
listed
2.0
Occupational
Exposures
and
Risks
There
is
a
potential
for
exposure
to
MGK­
264
in
occupational
scenarios
from
handling
MGK­
264
products
during
the
application
process
(
i.
e.,
mixer/
loaders,
applicators,
and
mixer/
loader/
applicators)
and
a
potential
for
postapplication
worker
exposure
from
entering
into
areas
previously
treated
with
MGK­
264.
As
a
result,
risk
assessments
have
been
completed
for
occupational
handler
scenarios
as
well
as
occupational
postapplication
scenarios.

2.1
Handlers
Tasks
associated
with
occupational
pesticide
handlers
are
categorized
using
one
of
the
following
terms:

C
Mixers
and/
or
Loaders:
these
individuals
perform
tasks
in
preparation
for
an
application.
For
example,
prior
to
application,
mixer/
loaders
would
mix
the
MGK­
264
and
load
it
into
the
holding
tank
of
the
groundboom
tractor.

C
Applicators:
these
individuals
operate
application
equipment
during
the
release
of
a
pesticide
product
into
the
environment.
These
individuals
can
make
applications
using
equipment
such
groundboom
tractors.

C
Mixer/
Loader/
Applicators
and
or
Loader/
Applicators:
these
individuals
are
involved
in
the
entire
pesticide
application
process
(
i.
e.,
they
do
all
job
functions
related
to
a
pesticide
application
event).
These
individuals
would
transfer
MGK­
264
into
the
application
equipment
and
then
also
apply
it.

A
chemical
can
produce
different
effects
based
on
how
long
a
person
is
exposed,
how
frequently
exposures
occur,
and
the
level
of
exposure.
HED
classifies
exposures
up
to
30
days
as
short­
term
and
exposures
greater
than
30
days
up
to
several
months
as
intermediate­
term.
HED
completes
both
short­
and
intermediate­
term
assessments
for
occupational
scenarios
in
essentially
all
cases,
because
these
kinds
of
exposures
are
likely
and
acceptable
use/
usage
data
are
not
available
to
justify
deleting
intermediate­
term
scenarios.
Based
on
use
data
and
label
instructions,
HED
believes
that
occupational
MGK­
264
exposures
may
occur
over
a
single
day
or
up
to
weeks
at
a
time
for
many
use­
patterns
and
that
intermittent
exposures
over
several
weeks
also
may
occur.
Some
applicators
may
apply
MGK­
264
over
a
period
of
weeks,
because
they
are
custom
or
commercial
applicators
who
are
completing
a
number
of
applications
for
a
number
of
different
clients.
Long­
term
handler
exposures
are
not
expected
to
occur
for
MGK­
264.
Note
that
the
same
toxicological
endpoint
of
concern
(
from
an
oral
study)
was
selected
for
short­,
intermediate­
,
and
long­
term
dermal
MGK­
264
exposures,
therefore,
the
risk
estimates
for
all
dermal
durations
of
exposure
are
numerically
identical.
The
same
toxicological
endpoint
of
concern
(
from
an
inhalation
study)
has
been
selected
for
short­,
intermediate­
and
long­
term
inhalation
exposures
to
MGK­
264,
therefore,
the
risk
estimates
for
all
inhalation
durations
of
exposure
also
are
numerically
identical.
Page
11
of
39
Other
parameters
are
also
defined
from
use
and
usage
data
such
as
application
rates
and
application
frequency.
HED
always
completes
non­
cancer
risk
assessments
using
maximum
application
rates
for
each
in
order
to
ensure
there
are
no
concerns
for
each
specific
use.

Occupational
handler
exposure
assessments
are
completed
by
HED
using
different
levels
of
risk
mitigation.
Typically,
HED
uses
a
tiered
approach.
The
lowest
tier
is
designated
as
the
baseline
exposure
scenario
(
i.
e.,
long­
sleeve
shirt,
long
pants,
shoes,
socks,
and
no
respirator).
If
risks
are
of
concern
at
baseline
attire,
then
increasing
levels
of
personal
protective
equipment
or
PPE
(
e.
g.,
gloves,
double­
layer
body
protection,
and
respirators)
are
evaluated.
If
risks
remain
a
concern
with
maximum
PPE,
then
engineering
controls
(
e.
g.,
enclosed
cabs
or
cockpits,
watersoluble
packaging,
and
closed
mixing/
loading
systems)
are
evaluated.
This
approach
is
used
to
ensure
that
the
lowest
level
of
risk
mitigation
that
provides
adequate
protection
is
selected,
since
the
addition
of
PPE
and
engineering
controls
involves
an
additional
expense
to
the
user
and
 
in
the
case
of
PPE
 
also
involves
an
additional
burden
to
the
user
due
to
decreased
comfort
and
dexterity
and
increased
heat
stress
and
respiratory
stress.

2.1.1
Data
Sources
No
chemical­
specific
exposure
data
was
available
for
MGK­
264.
Handler
exposure
estimates
were
based
on
the
best
available
surrogate
data.

HED
uses
unit
exposure
to
assess
handler
exposures
to
pesticides.
Unit
exposures
are
estimates
of
the
amount
of
exposure
to
an
active
ingredient
a
handler
receives
while
performing
various
handler
tasks
and
are
expressed
in
terms
of
micrograms
or
milligrams
of
active
ingredient
per
pounds
of
active
ingredient
handled.
HED
has
developed
a
series
of
unit
exposures
that
are
unique
for
each
scenario
typically
considered
in
our
assessments
(
i.
e.,
there
are
different
unit
exposures
for
different
types
of
application
equipment,
job
functions,
and
levels
of
protection).
The
unit
exposure
concept
has
been
established
in
the
scientific
literature
and
also
through
various
exposure
monitoring
guidelines
published
by
the
U.
S.
EPA
and
international
organizations
such
as
Health
Canada
and
OECD
(
Organization
For
Economic
Cooperation
and
Development).

Occupational
Handler
unit
exposures
for
MGK­
264
were
based
on
the
following
sources:

C
Pesticide
Handler
Exposure
Database
(
PHED)
Version
1.1
(
August
1998)

C
MRID
449722­
01.
A
report
was
submitted
by
the
ORETF
that
presented
data
in
which
the
application
of
various
products
used
on
turf
by
homeowners
and
lawncare
operators
(
LCOs)
was
monitored.
All
of
the
data
submitted
in
this
report
were
completed
in
a
series
of
studies.
The
study
that
monitored
LCO
exposure
scenarios
using
a
low
pressure,
high
volume
turf
handgun
is
ORETF
Study
OMA002.
The
study
that
monitored
homeowner
exposures
while
using
a
hose­
end
sprayer
is
ORETF
Study
OMA004.

C
MRID
444598­
01.
A
report
was
submitted
by
the
ORETF
that
presented
data
in
which
the
application
of
various
products
used
on
vegetable
gardens
by
homeowners
was
monitored.
The
study
that
monitored
homeowner
exposure
scenarios
using
a
duster
was
ORETF
Study
OMA007.
Page
12
of
39
C
Chemical
Manufacturers
Association
(
CMA)
Antimicrobial
Exposure
Assessment
Study
(
December
1992):
The
CMA
exposure
study
was
a
response
to
March
4,
1987
data
call­
in
notice
by
EPA.
CMA
is
a
generic
biocide
exposure
assessment
protocol
used
to
assess
potential
dermal
and/
or
inhalation
exposure
from
the
application
of
antimicrobial
pesticide
products
in
multiple
settings
using
various
application
methods.

°
MRID
410547­
01.
Exposure
of
Applicators
to
Propoxur
During
Trigger­
Pump
Spray
Applications
of
a
Liquid
Product,
November
1,
1988.
(
proprietary
data)

°
MRID
446584­
01,
Dermal
Exposure
and
Inhalation
Exposure
to
Carbaryl
by
Commercial
Pet
Groomers
During
Applications
of
Adams
Carbaryl
Shampoo,
September
1998.
(
proprietary
data)

Currently,
EPA
has
no
exposure
data
for
mixing/
loading/
applying
liquids
for
fogger
and
dip
applications.

2.1.2
Assumptions
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
occupational
handler
risk
assessments.
Each
assumption
and
factor
is
detailed
below
on
an
individual
basis.
The
assumptions
and
factors
used
in
the
risk
calculations
include:

C
MGK­
264
has
a
large
number
of
use
patterns
that
are
difficult
to
completely
capture
in
this
document.
As
such,
HED
has
patterned
this
risk
assessment
on
a
series
of
likely
representative
scenarios
that
are
believed
by
HED
to
represent
the
vast
majority
of
MGK­
264
uses.

C
Generic
protection
factors
(
PFs)
were
used
to
calculate
exposures
when
data
were
not
available.
For
example,
a
filtering
facepiece
dustmask
is
assumed
to
have
a
protection
factor
(
PF)
of
5
(
i.
e.
reduces
inhalation
exposure
by
80%).

C
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
an
example,
for
MGK­
264
handler
exposures,
PHED
data
for
backpack
sprayer
equipment
were
used
to
assess
applications
using
an
ULV
backpack
fogger.
The
nature
of
these
application
methods
are
believed
to
be
similar
enough
to
bridge
the
data.

C
The
daily
areas
treated
were
defined
for
each
handler
scenario
(
in
appropriate
units)
by
determining
the
amount
that
can
be
reasonably
treated
in
a
single
day
(
e.
g.,
acres,
square
feet,
cubic
feet,
or
gallons
per
day).
When
possible,
the
assumptions
for
daily
areas
treated
are
taken
from
the
Health
Effects
Division
Science
Advisory
Committee
on
Exposure
SOP
#
9:
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,
which
was
completed
on
July
5,
2000.
However,
no
standard
values
are
available
for
numerous
scenarios.
Assumptions
for
these
scenarios
are
based
on
HED
estimates
and
could
be
further
refined
from
input
from
affected
sectors.
Table
2
summarizes
the
daily
areas
treated
assumptions
used
in
Page
13
of
39
this
assessment.

Table
2.
Assumptions
for
Occupational
Daily
Areas
Treated
Application
Equipment
Exposure
Scenario
Area
Treated
Daily
Low
Pressure
Handwand,
Outdoor
1
acres
Livestock
25
animals
C&
C
or
Spot
a
11,200
ft2
Backpack
Sprayer
Outdoor
1
acre
Livestock
25
animals
C&
C
or
Spot
a
11,200
ft2
Handgun
Outdoor
5
acres
C&
C
or
Spot
b
11,200
ft2
Livestock
b
25
animals
High
Pressure
Handwand
Outdoor
1
acre
Aerosol
Cans
C&
C
or
Spot
2
16­
oz
cans
Mousse,
Soap,
Lotion,
Gel,
Comb,
or
Roll­
on
Pets
c
0.2
gallons
Pour­
on
or
Spot­
on
Pets
d
8
gallons
Ready­
to­
use
Paste
Livestock
2
gallons
Ready­
to­
use
Wipes
Pets
e
8
wipes
Livestock
f
25
wipes
Ready­
to­
use
Foggers
Indoor
g
6
6­
oz
cans
Shaker
Can
Pets
h
8
pets
Shampoo
Pets
c
0.2
gallons
Trigger­
pump
Sprayer
Pets/
indoor
1
gallon
a.
Based
on
BEAD's
review
of
the
National
Pest
Management
Association
(
NPMA)
sponsored
Pest
Control
Operators
(
PCO)
Product
Use
and
Usage
Information
Survey.
b.
25
animals
treated
per
day
is
based
on
10/
21/
05
survey
provided
by
MGK
c.
10%
of
16
ounce
container
per
animal
and
assumes
16
animals
per
day
d.
1
gallon
per
pet
and
8
pets
treated
per
day
e.
1
wipe
per
animal
(
8
pets
treated
per
day
is
based
on
ORE
chapter
for
permethrin
RED)
f.
1
wipe
per
animal
g.
assume
handler
will
use
six
6­
oz
cans
(
3
cans
come
in
package,
each
can
treats
up
to
5,000
ft3)
h.
8
pets
treated
per
day
i.
0.25
gallon
per
pet
and
8
pets
treated
per
day
Page
14
of
39
2.1.3
Exposure
Scenarios
It
has
been
determined
that
exposure
to
pesticide
handlers
is
likely
during
the
occupational
use
of
MGK­
264
in
a
variety
of
occupational
environments.
The
anticipated
use
patterns
and
current
labeling
indicate
several
occupational
exposure
scenarios
based
on
the
types
of
equipment
and
techniques
that
can
potentially
be
used
for
MGK­
264
applications.
The
quantitative
exposure/
risk
assessment
developed
for
occupational
handlers
is
based
on
the
following
scenarios:

Mixing/
Loading
(
M/
L):
M/
L
Liquids
for
Groundboom
M/
L
Liquids
for
Dips
Mixer/
Loader/
Applying
(
M/
L/
A):
M/
L/
A
Liquids
with
Low
Pressure
M/
L/
A
Liquids
with
Backpack
M/
L/
A
Liquids
with
ULV
Fogger
M/
L/
A
Liquid
with
Handgun
M/
L/
A
Liquids
with
High
Pressure
Handwand
Applying:
Applying
RTU
Paste
Applying
RTU
Wipes
Applying
Pour­
on
or
Spot­
on
Applying
RTU
Formulations
via
Trigger­
Pump
Sprayer
Applying
RTU
Formulations
via
Mousse,
Soap,
Lotion,
Gel,
Comb,
or
Roll­
On
Applying
RTU
Shampoo
Applying
RTU
Formulations
with
Aerosol
Cans
Applying
RTU
Formulations
with
Fogger
Cans
2.1.4
Equations
for
Exposure/
Risk
Estimates
Daily
Exposure:
Daily
dermal
or
inhalation
handler
exposures
are
estimated
for
each
applicable
handler
task
(
except
applying
impregnated
collars)
with
the
application
rate,
the
area
treated
in
a
day,
and
the
applicable
dermal
or
inhalation
unit
exposure
using
the
following
formula:

Where:

Daily
Exposure
=
Amount
(
mg
or
µ
g
ai/
day)
deposited
on
the
surface
of
the
skin
that
is
available
for
dermal
absorption
or
amount
inhaled
that
is
available
for
inhalation
absorption;
Unit
Exposure
=
Unit
exposure
value
(
mg
or
µ
g
ai/
lb
ai)
derived
from
August
1998
PHED
data,
from
ORETF
data,
from
CMA
data,
and
from
Proprietary
data;
Page
15
of
39
Application
Rate
=
Normalized
application
rate
based
on
a
logical
unit
treatment,
such
as
acres,
square
feet,
gallons,
or
cubic
feet.
Maximum
values
are
generally
used
(
lb
ai/
A,
lb
ai/
ft2,
lb
ai/
gal,
lb
ai/
cu
ft);
and
Daily
Area
Treated
=
Normalized
application
area
based
on
a
logical
unit
treatment
such
as
acres
(
A/
day),
square
feet
(
ft2/
day),
gallons
per
day
(
gal/
day),
or
cubic
feet
(
cu
ft/
day).

Since
there
is
no
unit
exposure
values
for
applying
impregnated
collars
to
pets,
the
default
values
in
the
Standard
Operating
Procedures
for
Residential
Exposure
Assessments
(
R­
SOPs)
is
used
to
assess
daily
dermal
exposure.
The
R­
SOPs
indicate
that
daily
dermal
exposure
is
estimated
for
impregnated
pet
collars
by
assuming
that
one
percent
of
the
active
ingredient
in
the
collar
is
transferred
to
the
person
placing
the
collar
onto
a
pet.

Daily
dermal
handler
exposures
were
estimated
for
handlers
applying
impregnated
collars
with
the
application
rate,
number
of
collars
handled
per
day,
and
the
assumption
that
1
percent
of
the
active
ingredient
transfers
from
the
collar
to
the
person
using
the
following
formula:

Where:

Daily
Exposure
=
Amount
(
mg
ai/
day)
deposited
on
the
surface
of
the
skin
that
is
available
for
dermal
absorption;
Application
Rate
=
Application
rate
(
active
ingredient
in
each
collar)
converted
to
milligrams
active
ingredient
per
collar.
Maximum
values
are
used
(
mg
ai/
collar);
Number
of
Collars
Applied
=
Assumption
regarding
the
number
of
impregnated
collars
placed
on
a
pet
per
day
in
an
occupational
setting,
such
as
a
veterinary
clinic;
and
Percent
Transferred
=
Percent
active
ingredient
transferred
from
the
pet
collar
to
the
person
putting
it
on
the
pet.
Assumption
from
R­
SOPs
is
that
1%
transfers.

The
average
daily
dose
was
calculated
using
the
following
formula:

Where:

Average
Daily
Dose
=
Absorbed
dose
received
from
exposure
to
a
pesticide
in
a
given
scenario
(
mg
pesticide
active
ingredient/
kg
body
weight/
day);
Daily
Exposure
=
Amount
(
mg
ai/
day)
deposited
on
the
surface
of
the
skin
that
is
available
for
dermal
absorption
or
amount
inhaled
that
is
available
for
inhalation
absorption;
Absorption
Factor
=
A
measure
of
the
amount
of
chemical
that
crosses
a
biological
boundary
such
as
the
skin
or
lungs
(%
of
the
total
available
absorbed);
and
Body
Weight
=
Body
weight
determined
to
represent
the
population
of
interest
in
a
risk
assessment
(
kg).
Page
16
of
39
Margins
of
Exposure:
Non­
cancer
dermal
and
inhalation
risks
for
each
applicable
handler
scenario
are
calculated
using
a
Margin
of
Exposure
(
MOE),
which
is
a
ratio
of
the
daily
dose
to
the
toxicological
endpoint
of
concern.
All
MOE
values
were
calculated
separately
for
dermal
and
inhalation
exposure
levels
using
the
formula
below:

Where:

MOE
=
Margin
of
Exposure,
value
used
by
HED
to
represent
risk
or
how
close
a
chemical
exposure
is
to
being
a
concern
(
unitless);
ADD
=
Average
Daily
Dose
or
the
absorbed
dose
received
from
exposure
to
a
pesticide
in
a
given
scenario
(
mg
pesticide
active
ingredient/
kg
body
weight/
day);
and
NOAEL
or
LOAEL
=
Dose
level
in
a
toxicity
study,
where
no
observed
adverse
effects
(
NOAEL)
or
where
the
lowest
observed
adverse
effects
(
LOAEL)
occurred
in
the
study
Risk
values
are
presented
for
each
route
of
exposure
(
i.
e.,
dermal
or
inhalation)
in
each
scenario,
because
risk
mitigation
measures
are
specific
to
the
route
of
exposure.
A
total
MOE
was
not
calculated
for
MGK­
264
because
the
dermal
and
inhalation
toxicological
endpoints
of
concern
are
based
on
different
adverse
effects.

2.1.5
Risk
Summary
Handler
data
gaps
exist
for:
(
1)
Dermal
and
inhalation
handler
monitoring
for
mixing/
loading/
applying
liquids
for
fogger
applications
and
(
2)
dermal
and
inhalation
handler
monitoring
for
mixing/
loading/
applying
liquids
for
dip
applications.

A
summary
of
the
short­
and
intermediate­
term
risks
for
each
exposure
scenario
are
presented
in
Table
4.
With
the
exception
of
3
occupational
handler
scenarios
assessed,
estimated
MOEs
were
not
a
risk
concern
for
all
scenarios
at
the
baseline
level
(
i.
e
single
layer
with
no
gloves,
and
no
respirator).
Dermal
MOEs
for
mixing
loading
and
applying
liquids
with
low
pressure
handwand,
high
pressure
handwand,
and
backpack
sprayers
are
not
a
risk
concern
if
gloves
are
worn.
Page
17
of
39
Table
4.
Summary
of
MOEs
for
Occupational
Handlers
Exposure
Scenario
(
Data
Source)
Application
Rate
Area
Treated
Baseline
Dermal
MOE
Baseline
Inhalation
MOE
PPE­
Gloves
Dermal
MOE
PPE­
Gloves
+
Coveralls
Dermal
MOE
PPE­
PF5
Respirator
Inhalation
MOE
PPE­
PF10
Respirator
Inhalation
MOE
M/
L
Liquids
for
Dips
(
PHED)
0.00005
lb
ai/
gal
0.5
gal
5.0E+
08
4.3E+
09
6.4E+
10
8.6E+
10
2.2E+
10
4.3E+
10
M/
L/
A
Liquids
w\
LPH
(
PHED)
0.00005
lb
ai/
ft2
11200
ft2
654
7,750
151,993
176,641
38,750
77,500
0.00025
lb
ai/
animal
25
animals
58,560
694,400
1.4E+
07
1.6E+
07
3,472,000
6,944,000
M/
L/
A
Liquids
w\
Backpack
(
PHED)
0.00005
lb
ai/
ft2
11200
ft2
ND
7,750
26,143
40,848
38,750
77,500
0.3
lb
ai/
A
1
A
ND
14,467
48,800
76,250
72,333
144,667
0.00025
lb
ai/
animal
25
animals
ND
694,400
2,342,400
3,660,000
3,472,000
6,944,000
M/
L/
A
Liquids
w\
Backpack
(
PHED
for
ULV
Fogger)
0.07
lb
ai/
A
5
A
ND
12,400
41,829
65,357
62,000
124,000
M/
L/
A
Liquid
w\
Handgun
(
MRID
44972201,
ORETF)
0.3
lb
ai/
A
5
A
ND
45,684
48,800
90,370
228,421
456,842
0.00005
lb
ai/
ft2
11200
ft2
ND
122,368
130,714
242,063
611,842
1,223,684
0.00025
lb
ai/
animal
25
animals
ND
1.1E+
07
1.2E+
07
2.2E+
07
5.5E+
07
1.1E+
08
M/
L/
A
Liquids
w\
HPH
(
PHED)
0.3
lb
ai/
A
1
A
ND
3,617
48,800
76,250
18,083
36,167
Applying
RTU
Paste
(
PHED
for
paint
brush)
0.0056
lb
ai/
animal
25
animals
1,452
3,321
10,893
11,883
16,607
33,214
Applying
RTU
Wipe
to
Livestock
(
CMA)
0.0000826
lb
ai/
wipe
25
wipes
6,176
2,276
ND
ND
11,381
22,762
Applying
RTU
Wipe
to
Pets
(
CMA)
0.0001764
lb
ai/
wipe
8
wipes
9,038
3,331
ND
ND
16,657
33,313
Applying
Pour­
on
or
Spot­
on
(
MRID
44972201,
Hose­
end
ORETF)
0.07
lb
ai/
gal
8
gal
11,671
14,531
ND
ND
72,656
145,313
Applying
RTU
Formulations
via
Trigger­
Pump
Sprayer
(
MRID
410547­
01,
Propoxur)
0.042
lb
ai/
gal
1
gal
64,550
25,203
ND
ND
126,016
252,033
Applying
RTU
Formulations
via
Mousse,
Soap,
Lotion,
Gel,
Comb,
or
Roll­
On
(
MRID
446584­
01,
Carbaryl)
0.035
lb
ai/
gal
0.2
gal
2,905
1.6E+
11
ND
ND
7.8E+
11
1.6E+
12
Applying
RTU
Shampoo
(
MRID
446584­
01,
Carbaryl)
0.07
lb
ai/
gal
0.2
gal
1,452
7.8E+
10
ND
ND
3.9E+
11
7.8E+
11
Applying
RTU
Formulations
w\

Aerosol
Cans
(
PHED
aerosol)
0.0177
lb
ai/
16oz
can
2
16oz
cans
5,442
2,829
12,764
16,155
14,146
28,292
Applying
RTU
Formulations
w\

Foggers
(
PHED
aerosol)
0.0064125
lb
ai/
6oz
can
3
6oz
cans
10,013
5,206
23,488
29,727
26,031
52,062
0.0064125
lb
ai/
6oz
can
6
6oz
cans
5,007
2,603
11,744
14,864
13,015
26,031
Applying
Dusts
via
Shaker
Can
(
MRID
444598­
01)
0.00011
lb
ai/
ft2
1000
ft2
4,378
1,909
ND
ND
9,545
19,091
0.00248
lb
ai/
pet
8
pets
24,273
10,585
ND
ND
52,923
105,847
Page
18
of
39
ND
=
No
data,
NF
=
Not
Feasible
MOEs
of
less
than
1,000
are
a
risk
concern
Page
19
of
39
2.2
Postapplication
Activities
HED
uses
the
term
"
postapplication"
to
describe
exposures
to
individuals
that
occur
as
a
result
of
being
in
an
environment
that
has
been
previously
treated
with
a
pesticide.
MGK­
264
uses
that
may
result
in
foliar
contact
were
identified
in
the
following
crop
groupings
based
on
HED's
Science
Advisory
Council
For
Exposure
Policy
3.1:

C
Floriculture
crops
grown
for
cutting;

C
Floriculture
crops
not
grown
for
cutting;

C
Trees/
fruit,
evergreen
(
Christmas
trees);

C
Turf/
sod
(
e.
g.,
golf
courses,
sod
farms);
and
C
Nursery
crops
(
e.
g.,
container
and
balled
and
burlapped
ornamentals).

For
MGK­
264,
the
exposure
durations
for
noncancer
postapplication
risk
assessment
were
short­
term
(#
30
days)
and
intermediate­
term
(
greater
than
30
days
up
to
several
months).
However,
since
the
dermal
toxicological
endpoint
of
concern
is
the
same
for
short­
and
intermediate­
term
exposures,
the
short­
and
intermediate­
term
postapplication
risks
are
numerically
identical.

Inhalation
exposures
are
thought
to
be
negligible
in
outdoor
postapplication
scenarios,
since
MGK­
264
has
low
vapor
pressure
and
the
dilution
factor
outdoors
is
considered
infinite.
In
addition,
under
the
Worker
Protection
Standard
for
Agricultural
Pesticides
 
WPS
 
(
40
CFR
170)
greenhouses
must
be
appropriately
ventilated
(
ventilation
criteria
are
provided)
following
pesticide
applications
so
that
postapplication
inhalation
exposures
are
minimal.
As
such,
inhalation
postapplication
exposures
from
outdoor
applications
are
not
considered
in
this
assessment.
See
Section
3.2
for
postaplication
postapplication
exposure
from
indoor
applications.

2.2.1
Data
and
Assumptions
The
assumptions
and
factors
used
in
the
risk
calculations
include:

C
Transfer
Coefficients
(
TCs):
Turf
TCs
were
based
on
the
latest
ARTF
studies.
The
other
TCs
used
were
taken
from
HED's
revised
policy
entitled
Policy
003.1
Science
Advisory
Council
For
Exposure
Policy
Regarding
Agricultural
Transfer
Coefficients
(
August
7,
2000).

C
Turf
Transferrable
Residues
(
TTRs):
No
MGK­
264­
specific
turf
transferrable
residue
(
TTR)
data
were
available.
Therefore,
this
assessment
uses
HED's
default
assumption
that
5
percent
of
the
application
rate
is
available
on
day
0
(
i.
e.,
12
hours
after
application)
and
the
residue
dissipates
at
a
rate
of
10
percent
per
day.

C
Dislodgeable
Foliar
Residues
(
DFRs):
No
MGK­
264­
specific
dislodgeable
foliar
residue
Page
20
of
39
(
DFR)
data
were
available.
Therefore,
this
assessment
uses
HED's
default
assumption
that
20
percent
of
the
application
rate
is
available
on
day
0
(
i.
e.,
12
hours
after
application)
and
the
residue
dissipates
at
a
rate
of
10
percent
per
day.

2.2.2
Equations
for
Exposure/
Risk
Estimates
Occupational
non­
cancer
risks
were
calculated
using
a
Margin
of
Exposure
(
MOE),
which
is
a
ratio
of
the
daily
dose
to
the
toxicological
endpoint
of
concern.
Postapplication
risks
diminish
over
time
because
MGK­
264
residues
eventually
dissipate
in
the
environment.
As
a
result,
risks
were
calculated
over
time
based
on
changing
residue
levels.

Daily
Exposure:
Daily
dermal
exposures
were
calculated
on
each
postapplication
day
after
application
using
the
following
equation
(
see
equation
D2­
20
from
Series
875­
Occupational
and
Residential
Test
Guidelines:
Group
B­
Postapplication
Exposure
Monitoring
Test
Guidelines
and
Residential
SOP
3.2:
Postapplication
Dermal
Potential
Doses
From
Pesticide
Residues
On
Gardens):

DE(
t)
(
mg/
day)
=
(
TR(
t)
(
µ
g/
cm2)
x
TC
(
cm2/
hr)
x
Hr/
Day)/
1000
(
µ
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
that
can
either
be
dislodgeable
foliar
or
turf
transferable
residue
at
time
"
t"
(
µ
g/
cm2);
TC
=
Transfer
Coefficient
(
cm2/
hour);
and
Hr/
day
=
Exposure
duration
meant
to
represent
a
typical
workday
(
hours).

Note
that
the
(
TR
(
t))
input
may
represent
levels
on
the
day
of
application
in
the
case
of
short­
term
risk
calculations.

Daily
Dose
and
Margins
of
Exposure:
The
use
of
dissipation
data
and
the
manner
in
which
daily
postapplication
dermal
exposures
were
calculated
are
inherently
different
than
with
handler
exposures.
However,
once
daily
exposures
are
calculated,
the
calculation
of
daily
absorbed
dose
and
the
resulting
Margin
of
Exposures
use
the
same
algorithms
that
are
described
above
for
the
handler
exposures.
These
calculations
are
completed
for
each
day
or
appropriate
block
of
time
after
application.

2.2.3
Risk
Summary
A
summary
of
MOEs
estimated
for
occupational
postapplication
activities
are
provided
in
Table
5.
None
of
the
crops
have
a
risk
concern
on
day
0
(
i.
e.,
12
hours
after
application).
Page
21
of
39
Table
5.
Summary
of
MOEs
for
Postapplication
Activities
Crop
Maximum
Application
Rate
(
lb
ai/
A)
Activity
TC
cm2/
hr
Short/
Intermediate­
Term
MOE
DAT
(
days)

field
grown­
Christmas
trees
0.3
hand
harvesting,
thinning
3000
2300
0
hand­
pruning
1500
4500
0
hand­
weeding,
scouting,
irrigating
1000
6800
0
ornamentals
­
nursery
grown
0.3
irrigating,
scouting
(
all
at
medium
development)
500
14000
0
ornamentals
­
floriculture
0.3
hand­
pruning
400
17000
0
hand­
pinching
175
39000
cut
roses
2600
2600
0
all
other
cut
flowers
500
14000
0
turfgrass
0.3
transplanting,
hand
weeding,
hand
or
mechanical
harvesting
16,500
*
1600
0
mowing,
scouting,
irrigating
500
54000
0
golf
course
maintenance
(
mowing)
3,400
*
8000
0
sod
harvesting
6,800
*
4000
0
*
TCs
of
16,500
cm2/
hr
for
turf
is
from
the
policy
3.1.
This
value
has
been
replaced
with
the
values
from
the
latest
ARTF
studies
and
is
shown
for
comparative
purposes.

It
should
be
noted
that
there
were
a
few
scenarios
for
which
no
appropriate
exposure
data
are
known
to
exist
or
ongoing
transfer
coefficient
studies
have
not
yet
been
submitted
(
e.
g.,
ARTF
nursery
and
ornamental
data).
The
scope
of
HED's
revised
policy
3.1
for
transfer
coefficients
should
also
be
considered,
as
it
only
quantitatively
addresses
risks
where
the
transfer
coefficient
model
is
appropriate
(
i.
e.,
where
foliar
contact
is
known
to
exist).
There
are
many
kinds
of
potential
exposure
pathways
that
do
not
involve
foliar
contact
that
have
not
been
addressed
in
this
risk
assessment
(
as
defined
in
policy
3.1,
refer
to
that
document
for
a
complete
list).
The
scenarios
include:
Page
22
of
39
C
Transplanting
many
crops,
including
in
the
ornamental
and
forestry
industry;
and
C
Various
operations
with
Christmas
trees,
such
as
pruning
or
balling.

3.0
Non­
Occupational/
Residential
Exposures
and
Risks
There
is
a
potential
for
non­
occupational
exposure
during
the
application
process
and
for
persons
entering
MGK­
264­
treated
areas,
such
as
lawns,
golf
courses,
home
gardens,
and
indoor
surfaces
(
carpets
and
flooring).
Risk
assessments
have
been
completed
for
both
residential
handler
and
postapplication
scenarios.

In
addition
to
homeowner
uses
in
residential
settings,
MGK­
264
is
labeled
for
wide­
area
broadcast
use
for
insect
control,
which
would
be
applied
by
occupational
applicators,
but
may
result
in
postapplication
exposures
in
residential
settings.
MGK
reports
that
this
use
will
no
longer
be
supported.
Therefore,
exposure
for
this
use
was
not
assessed.

Residential
handler
and
postapplication
exposures
were
estimated
based
on
current
Standard
Operating
Procedures
(
SOPs)
for
Exposure
Assessments
except
where
noted.
The
exposure
estimates
based
on
the
SOPs
are
considered
to
be
high­
end
estimates.

3.1
Handlers
HED
uses
the
term
"
handlers"
to
describe
those
individuals
who
are
involved
in
the
pesticide
application
process.
HED
believes
that
there
are
distinct
tasks
related
to
applications
and
that
exposures
can
vary
depending
on
the
specifics
of
each
task
as
was
described
above
for
occupational
handlers
3.1.1
Data
and
Assumptions
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
residential
handler
risk
assessments.
Each
assumption
and
factor
is
detailed
below.
In
addition
to
these
factors,
unit
exposure
values
were
used
to
calculate
risk
estimates.
Mostly,
these
unit
exposure
values
were
taken
from
the
Pesticide
Handlers
Exposure
Database
(
PHED)
and
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF)
studies.
In
other
cases,
chemical­
specific
exposure
data
were
submitted
to
support
the
reregistration
of
MGK­
264.
Both
PHED
and
the
individual
studies
are
presented
below.
[
Note:
Several
of
the
assumptions
and
factors
used
for
the
assessment
are
similar
to
those
used
in
the
occupational
assessment
presented
above.
As
such,
only
factors
that
are
unique
to
the
residential
scenarios
are
presented
below.]

The
assumptions
and
factors
used
in
the
risk
calculations
include:

C
Residential
handler
exposure
scenarios
are
considered
to
be
short­
term
only,
due
to
the
infrequent
use
patterns
associated
with
homeowner
products.
Page
23
of
39
C
A
tiered
approach
for
personal
protection
using
increasing
levels
of
PPE
is
not
used
in
residential
handler
risk
assessments.
Homeowner
handler
assessments
are
based
on
the
assumption
that
individuals
are
wearing
shorts,
short­
sleeved
shirts,
socks,
and
shoes.

C
Homeowner
handlers
are
expected
to
complete
all
tasks
associated
with
the
use
of
a
pesticide
product
including
mixing/
loading
if
needed
as
well
as
the
application.

C
MGK­
264
is
a
widely
used
pesticide
active
ingredient.
It
has
many
use
patterns
that
would
be
difficult
to
completely
capture
in
this
document.
As
such,
HED
has
developed
this
risk
assessment
on
a
series
of
representative
scenarios
that
are
believed
to
represent
the
majority
of
MGK­
264
uses.
Refinements
to
the
assessment
will
be
made
as
more
detailed
information
about
MGK­
264
use­
patterns
become
available.

C
Maximum
application
rates
allowed
by
labels
were
assumed
for
all
exposure
scenarios.

C
Residential
risk
assessments
are
based
on
estimates
of
what
homeowners
would
typically
treat,
such
as
the
size
of
a
lawn
or
the
size
of
a
garden.
The
factors
used
for
the
MGK­
264
assessment
were
from
the
Health
Effects
Division
Science
Advisory
Committee
Policy
12:
Recommended
Revisions
To
The
Standard
Operating
Procedures
For
Residential
Exposure
Assessment
which
was
completed
on
February
22,
2001,
and
on
professional
judgement.

C
Residential
handler
unit
exposures
for
MGK­
264
were
based
on
the
same
studies
previous
mentioned
in
the
occupational
handler
assessment.
The
only
study
used
for
residential
handlers
that
was
not
mentioned
in
the
occupational
section
was
a
carbaryl
homeowner
dog
dusting
study
(
MRID
444399­
01,
Carbaryl
Applicator
Exposure
Study
During
Application
of
Sevin
Dust
to
Dogs
By
the
Non­
Professional,
August
22,
1997).
Page
24
of
39
3.1.2
Exposure
Scenarios
The
anticipated
use
patterns
and
current
labeling
indicate
several
residential
handler
exposure
scenarios
based
on
the
types
of
equipment
and
techniques
that
can
potentially
be
used
to
make
MGK­
264
applications.
The
quantitative
exposure/
risk
assessment
developed
for
residential
handlers
is
based
on
the
following
scenarios:

Mixing/
Loading/
Applying
Liquid
Formulations
with
Low
Pressure
Handwand
(
LPH)
Mixing/
Loading/
Applying
Formulations
with
Hose­
End
Sprayer
Mixing/
Loading/
Applying
Formulations
with
Foggers
Applying
Ready­
to­
use
Dusts
with
Shaker
Can
Applying
Ready­
to­
use
Shampoos
Applying
Ready­
to­
use
Mousse,
Soap,
Lotion,
Gel,
Comb,
or
Roll­
On
Products
Applying
Ready­
to­
use
Wipes
Applying
Ready­
to­
use
Formulations
Using
Trigger
Pump
Sprayer
Applying
Ready­
to­
use
Aerosol
Cans
Applying
Ready­
to­
use
Foggers
Applying
Ready­
to­
use
Impregnated
Collars
on
Dogs
3.1.3
Equations
for
Exposure/
Risk
Estimates
The
data
used
by
HED
have
provided
a
basic
broad
overview
of
the
uses
of
MGK­
264
around
a
residential
environment.
However,
it
is
likely
that
MGK­
264
can
be
used
in
a
myriad
of
ways
that
have
not
specifically
been
identified
in
this
assessment.
HED
believes
that
the
scenarios
assessed
in
this
document
represent
worse­
case
exposures
and
risks
resulting
from
use
of
MGK­
264
in
residential
environments.

Handler
data
gaps
exist
for:
(
1)
Dermal
and
inhalation
handler
monitoring
for
mixing/
loading/
applying
liquids
for
fogger
applications
and
(
2)
dermal
and
inhalation
handler
monitoring
for
mixing/
loading/
applying
liquids
for
dip
applications.
MOEs
estimated
for
residential
handlers
are
presented
in
Table
6.
MOEs
for
all
of
the
scenarios
assessed
were
greater
than
1,000
and
therefore
not
risk
a
concern.
Page
25
of
39
Table
6.
Residential
Handler
MOEs
Exposure
Scenario
Crop
or
Target
Application
Rate
Area
Treated
Daily
MOEs
Dermal
Inhalation
M/
L/
A
Liquids
with
LPH
(
PHED)
Indoor/
Outdoor
Spaces
0.00005
lb
ai/
ft2
1000
ft2
13071
6.9e+
05
M/
L/
A
Liquids
with
Hose­
End
Sprayer
(
MRID,

44972201,
ORETF)
Outdoors
0.3
lb
ai/
A
0.5
A
22182
5.1e+
04
M/
L/
A
Dusts
via
Shaker
Can
(
MRID
444598­
01,

Carbaryl)
Indoor
Surfaces
0.00011
lb
ai/
sq
ft
256
ft2
8724
7.5e+
03
M/
L/
A
Dusts
to
Pets
(
MRID
444399­
01,
Carbaryl)
Pets
0.00248
lb
ai/
pet
1
pet
4472
2.1e+
06
Applying
RTU
Formulations
via
Shampoo
(
MRID
446584­
01,
Carbaryl)
Pets
0.0088
lb
ai/
16
oz
can
0.1
16
oz
can
23106
1.2e+
12
Applying
RTU
Formulations
via
Mousse,
Soap,

Lotion,
Gel,
Comb,
or
Roll­
On
(
MRID
446584­
01,

Carbaryl)
Pets
0.0044
lb
ai/
16
oz
can
0.1
16
oz
can
46212
2.5e+
12
Applying
RTU
Formulations
via
RTU
Wipe
(
CMA
data)
Pets
0.00018
lb
ai/
wipe
1
wipes
72306
2.7e+
04
Applying
RTU
Formulations
via
Trigger­
Pump
Sprayer
(
MRID
410547­
01,
Propoxur)
Pets
0.022
lb
ai/
16­
oz
container
0.5
16­
oz
container
246465
9.6e+
04
Applying
RTU
Formulations
via
Trigger­
Pump
Sprayer
(
MRID
410547­
01,
Propoxur)
Indoor/
Outdoor
Spaces
0.042
lb
ai/
gal
0.25
gal
258201
1.0e+
05
Applying
RTU
Formulations
with
Aerosol
Cans
(
PHED
Data)
Indoor/
Outdoor
Surfaces
&
Spaces
0.0177
lb
ai/
16oz
can
1
16­
oz
aerosol
can
9399
3.1e+
03
Applying
RTU
Formulations
with
Aerosol
Cans
(
PHED
Data)
Indoor
Total
Release
Foggers
0.0064
lb
ai/
6­
oz
can
3
6­
oz
cans
8648
2.8e+
03
Applying
RTU
Pet
Collars
(
R­
SOPs)
Pets
998
mg
ai/
collar
2
collars
1834
no
data
Page
26
of
39
3.2
Postapplication
Activities
HED
uses
the
term
"
postapplication"
to
describe
exposures
to
individuals
that
occur
as
a
result
of
being
in
an
environment
that
has
been
previously
treated
with
a
pesticide.
MGK­
264
can
be
used
in
many
areas
that
can
be
frequented
by
the
general
population
including
residential
areas
(
e.
g.,
home
lawns
and
gardens).
As
a
result,
individuals
can
be
exposed
by
entering
these
areas
if
they
have
been
previously
treated.
MGK­
264
can
also
be
used
on
pets,
which
can
lead
to
exposures
by
contact
with
the
treated
animal.

3.2.1
Data
Sources
(
not
included
in
updated
Residential
SOPs)

Non­
Dietary
Exposure
Task
Force
(
NDETF)
Studies
­
Data
regarding
surface
residue
deposition
and
air
concentrations
from
application
to
foggers
and
aerosols
in
indoor
residential
settings
were
based
on
studies
submitted
by
the
Non­
Dietary
Exposure
Task
Force
(
NDETF).

Oral
Exposures
Since
MGK­
264
was
not
one
of
the
active
ingredients
considered
in
the
study,
mean
values
from
all
of
the
applicable
studies
were
used
in
this
assessment.
Hand
transfer
data
used
in
this
assessment
comes
from
the
bare
wetted
hand
scenarios
that
were
performed
in
some
of
the
NDETF
studies.
Transfer
of
MGK­
264
to
bare
hands
from
fogger
treated
carpet
was
assumed
to
be
9.1
percent
of
deposition
based
on
data
from
Project
ID
98­
031­
PY01
(
Volume
5)
and
Project
ID
01­
017­
PY01
(
Volume
25)
of
the
NDETF
studies.
Transfer
of
MGK­
264
to
bare
hands
from
fogger
treated
vinyl
flooring
was
assumed
to
be
5.8
percent
of
deposition
based
on
data
from
Project
ID
98­
031­
PY01
(
Volume
5)
and
Project
ID
01­
017­
PY01
(
Volume
25)
of
the
NDETF
studies.
These
data
were
used
to
assess
the
toddler
incidental
oral
ingestion
hand­
tomouth
from
indoor
surfaces
scenario.

Dermal
Exposures
Roller
and
drag
sled
transfer
data
were
averaged
together
for
use
in
this
assessment
as
there
was
little
difference
between
the
data
sets.
Transfer
of
MGK­
264
to
rollers
from
fogger
treated
carpet
was
assumed
to
be
4.5
percent
of
deposition
based
on
data
from
Project
ID
98­
031­
PY01
(
Volume
5)
and
Project
ID
01­
017­
PY01
(
Volume
25)
of
the
NDETF
studies.
Transfer
of
MGK­
264
to
rollers/
drag
sleds
from
fogger
treated
vinyl
flooring
was
assumed
to
be
2.3
percent
of
deposition
based
on
data
from
Project
ID
98­
031­
PY01
(
Volume
5)
and
Project
ID
01­
017­
PY01
(
Volume
25)
of
the
NDETF
studies.
These
data
was
used
to
assess
the
adult
and
toddler
dermal
exposure
from
indoor
surfaces
scenarios.

Inhalation
Exposures
The
MGK­
264
Indoor
air
concentration
for
the
period
during
and
after
aerosol
space
spray
application
was
assumed
to
be
0.38
mg/
m3
based
on
data
from
Volume
18
of
the
NDETF
Page
27
of
39
Study,
"
Measurement
of
Air
Concentration,
Dermal
Exposure,
and
Deposition
of
Pyrethrin
and
Piperonyl
Butoxide
Following
the
Use
of
an
Aerosol
Spray".
The
measured
two
hour
time
weighted
average
air
concentration
of
pyrethrin
at
the
5
foot
level
(
air
samples
were
also
collected
at
the
one
foot
level)
was
0.019
:
g/
L
(
0.019
mg/
m3
)
following
aerosol
application
of
9.3
grams
of
a
0.5%
pyrethrin
formulation.
This
application
was
made
to
a
simulated
residential
room
that
had
an
interior
volume
of
2048
ft3.
The
theoretical
concentration
is
1.6
mg
ai/
m3
(
0.000051
lb
ai/
1000
ft3)
based
upon
the
above
parameters
and
assuming
no
deposition
(
the
room
was
not
ventilated
during
the
two
time
period).
The
measured
pyrethrin
air
concentration
of
0.019
mg/
m3
was
then
adjusted
by
a
factor
of
20
(
rate
of
0.001
lb
ai/
1000ft3
divided
by
study
application
rate
of
0.00005
lb
ai/
1000ft3)
to
reflect
the
revised
application
rate
of
0.001
lb
ai/
1000
ft3
proposed
by
MGK.

It
should
be
noted
that
the
label
for
EPA
Reg
No
1021­
1710
(
label
that
MGK
cites
as
basis
for
revised
rate
of
0.001
lb
ai/
1000
ft3)
includes
the
following
instructions:
"
Point
valve
away
from
face
and
push
button,
holding
container
upright.
When
using
indoors,
do
not
remain
in
treated
area.
Ventilate
the
area
for
15
minutes
following
treatment.
Allow
treated
surfaces
to
thoroughly
dry
before
use."

MRID
466010­
01,
Human
Exposure
During
and
Following
Use
of
a
Pyrethrins/
Piperonyl
Butoxide/
MGK
264
Shampoo
Formulation
on
Dogs.
Data
from
this
study
was
used
to
assess
toddler
dermal
and
incidental
oral
exposure
to
MGK­
264
following
its
use
as
a
dog
shampoo.
The
study
measured
dermal
postapplication
exposure
of
a
person
petting
and
hugging
a
dog
after
the
dog
was
bathed
with
a
shampoo
containing
pyrethrin,
piperonyl
butoxide,
and
MGK­
264.
Each
postapplication
exposure
session
was
30
minutes
in
duration
and
consisted
of
20
minutes
of
petting
and
10
minutes
of
hugging.
Dermal
exposure
to
hands
and
to
a
tee­
shirt
dosimeter
was
measured
following
each
30
minute
session.
The
postapplication
exposure
to
the
adult
petter/
hugger
was
measured
on
the
day
of
treatment
at
4
hours
following
application
and
then
at
1
day,
3
days,
7
days,
and
14
days
following
treatment.

Dermal
Exposures
For
assessing
dermal
postapplication
exposure
to
MGK­
264
following
treatment
to
a
dog
with
a
pesticide
shampoo,
the
total
MGK­
264
residue
(:
g)
found
on
the
study
subjects'
t­
shirt
and
hands
were
combined.
The
total
exposure
was
divided
by
the
pounds
of
active
ingredient
applied
to
the
dog
(
lb
ai/
animal)
to
provide
a
dermal
unit
exposure
value
(
mg/
lb
ai
applied/
animal)
for
the
30
minute
exposure
period
on
each
day
that
samples
were
taken.
The
dermal
unit
exposure
value
(
mg/
lb
ai
applied/
animal)
for
4
hours,
1
day,
3
days,
7
days,
and
14
days
following
treatment
were
205,
120,
61,
28,
10,
respectively.
The
4
hour
value
was
used
for
short­
term
exposure
estimates.

Oral
Exposures
Page
28
of
39
For
assessing
incidental
oral
ingestion
(
hand­
to­
mouth
activity)
to
MGK­
264
following
treatment
to
a
dog
with
a
pesticide
shampoo,
postapplication
exposure
was
determined
using
the
MGK­
264
residue
(:
g)
found
on
the
study
subjects'
hands.
The
residue
on
hands
was
divided
by
the
average
palmar
surface
area
of
the
study
subjects'
hands
(
145.24
cm2/
hand
x
2
hands
=
290.48
cm2)
to
obtain
the
:
g
ai/
cm2
hand
surface.
This
value
was
divided
by
the
pounds
of
active
ingredient
applied
to
the
dog
(
lb
ai/
animal)
to
provide
a
unit
exposure
value
for
hands
(:
g/
cm2/
lb
ai
applied/
animal)
for
the
30
minute
exposure
period
on
each
day
that
samples
were
taken.
The
unit
exposure
value
for
hands
(:
g/
cm2/
lb
ai
applied/
animal)
for
4
hours,
1
day,
3
days,
7
days,
and
14
days
following
treatment
were
806,
508,
256,
133,
44,
respectively.
The
4
hour
value
was
used
for
short­
term
exposure
estimates
(
assuming
30
minutes
of
exposure
and
no
salvia
extraction).
The
approach
used
to
estimate
dermal
and
oral
exposures
is
believed
to
represent
the
high­
end
of
toddler's
potential
exposures
from
treated
dogs.
The
results
of
study
were
not
used
for
dusts
applied
to
dogs
based
on
the
major
differences
in
formulation
and
rate
(
i.
e.
0.0008
lb
ai/
dog
versus
0.05
lb
ai/
dog).
Exposures
from
dusts
application
were
estimated
using
R­
SOPs
(
20%
transferable
residue).

Single
Chamber
Modeling
Approach
for
Metered
Release
Units
­
Indoor
air
concentrations
resulting
from
the
use
of
the
compact
metered
release
units
in
homes
were
modeled
using
a
single
chamber
modeling
approach.
This
approach
is
intended
for
vapors
and
is
considered
to
be
a
conservative
screen
for
assessing
aerosols.
Time­
weight
average
concentrations
of
MGK­
264
for
estimated
using
the
equation,

Air
concentration
at
time
t
=
Initial
air
concentration
*
0.5
(
t/
0.693*
Q/
V)

Assuming
each
spray
contains
55
mg
of
product
with
3.21%
and
a
170
ft3
room,
the
initial
air
concentration
was
assumed
to
be
0.01
mg/
m3.
It
was
assumed
that
there
are
0.18
air
changes
per
hour
which
is
the
recommended
in
the
R­
SOPs
for
air
exchange
rate
for
a
typical
house
in
the
summer
time.
Air
concentrations
were
estimated
every
minute
using
the
above
equation
assuming
that
a
new
spray
occurred
ever
15
minutes
(
1.77
mg
ai/
spray
event).
The
air
concentration
reached
a
steady
state
after
approximately
24
hours.
The
average
concentration
after
24
hours
was
estimated
to
be
0.25
mg/
m3
and
assumed
to
remain
somewhat
constant
for
several
weeks.
This
estimate
is
assumed
to
be
the
worst
case
for
registered
use
sites
since
air
exchange
rates
in
homes
are
usually
less
than
what
is
expected
for
other
registered
use
sites
(
e.
g.
food
handling
establishments,
barns,
day
care,
and
other
commercial
sites).

The
same
single
chamber
modeling
approach
was
used
by
the
Agency
to
assess
pyrethrin.
MGK
submitted
an
assessment
using
the
same
approach
for
PBO
and
pyrethrin
to
evaluate
a
metered
release
scenario
in
a
food
handling
establishment
(
MRID
466275­
01).
In
MGK's
assessment
2
air
changes
per
hour
were
assumed.

On
2/
10/
05
MGK
stated
that
`
There
are
EPA
registered
products
bearing
the
label
claim
"
Homes"
on
the
label,
however
we
are
advised
that
products
are
not
being
sold
for
use
in
Page
29
of
39
homes,
that
the
claim
was
established
for
"
homes"
to
be
sold
in
countries
other
than
the
USA,
where
sanitation
is
poor
and
the
units
are
used
in
residences
to
control
flies,
mosquitoes
and
the
other
listed
pests.
We
have
submitted
data
and
several
papers
to
the
Agency
concerning
long­
term
exposure
and
we
have
not
had
any
response
back
from
the
Agency.
We
believe
that
our
full
support
of
all
existing
uses
depends
upon
the
Agency's
response
to
our
submission'.

MOEs
were
estimated
for
the
same
inputs
above
with
2
air
changes
per
hour
for
comparative
purposes.

Insect
repellents
applied
directly
to
skin
­
The
master
label
indicates
that
products
containing
up
to
8%
MGK­
264
are
registered
for
direct
application
to
skin.
MGK's
11/
21/
05
submission
indicates
that
they
are
reducing
the
maximum
to
5%.
HED
assumed
that
these
products
may
include
lotions,
aerosol
cans,
pump
sprays,
and
pre­
treated
wipes.
No
chemical
specific
exposure
or
use
data
were
submitted
in
support
of
these
uses.
Currently,
HED's
SOPs
for
Residential
Exposure
Assessments
(
12/
18/
97)
contain
no
method
for
estimating
exposure
to
repellents
that
are
applied
to
the
skin.
Dermal
and
Oral
exposure
was
calculated
based
a
conservative
method
used
in
HED
November
16,
2001
memo,
"
Human
Health
Risk
Assessment
for
KBR
3023
All
Family
Insect
Repellent
Spray
&
Cream"
(
D279006).
Dermal
exposure
was
also
estimated
based
on
data
from
the
Residential
Exposure
Joint
Venture
(
REJV),
National
Pesticide
Use
Survey.
HED
conducted
an
analyses
of
the
survey
for
MGK­
326
in
2003
(
D292906).

Dermal
Exposures
Exposure
was
first
estimated
using
default
assumptions
for
body
surface
area,
body
weight,
the
percent
of
the
body
area
that
a
repellent
product
is
applied
to,
and
the
rate
of
application
(
1
mg
product/
cm2
of
skin).

The
REJV
survey
data
was
also
used
to
estimate
dermal
exposures.
In
the
survey
it
was
reported
that
the
mean
amount
of
product
applied
to
the
skin
and
clothes
of
adult
males
and
children
12
years
and
under
was
5.2
and
4.8
grams,
respectively.
These
values
were
assumed
to
be
the
amount
of
dermal
exposure
that
adults
and
toddlers
would
receive
from
each
application.

Both
methods
produced
similar
estimates
for
dermal
exposure.

Oral
Exposures
Although
the
proposed
label
instructions
prohibit
direct
application
to
the
hands
of
small
children,
it
was
determined
that
some
of
the
product
from
treated
areas
of
the
skin
may
be
transferred
to
the
hands
of
the
children
and
subsequent
hand­
to­
mouth
ingestion
may
occur.

It
was
assumed
that
both
hands
of
a
child
are
covered
with
product
at
the
rate
of
1
mg
formulation/
cm2.
This
rate
is
a
standard
value
that
has
been
used
in
other
OPP
assessments
for
Page
30
of
39
insect
cream/
lotion
repellents
applied
directly
to
the
skin.
There
are
no
adequate
data
on
the
frequency
and
rate
of
transfer
from
treated
skin
to
untreated
hands
of
children.
The
assumption
that
the
hands
are
covered
at
the
same
rate
as
the
treated
skin
is
considered
a
high­
end
value.

It
was
assumed
that
each
single
oral
exposure
event
involves
the
child
placing
the
palmar
surface
of
3
fingers
of
one
hand
(
20
cm2)
into
their
mouth.
A
saliva
extraction
factor
of
0.5
was
applied
to
determine
the
quantity
of
product
ingested.
The
use
of
the
palmar
surface
area
and
50%
saliva
extraction
is
consistent
with
current
standard
operating
procedures
for
assessing
handto
mouth
contact
with
residues
on
turf­
grass.
Removal
of
product
from
wiping
hands
on
clothes
or
surfaces
or
from
washing
hands
was
not
considered.

Dust
Applied
to
Indoor
Carpets
­
The
instructions
on
label
for
EPA
2596­
132
say
to:
(
1)
keep
children
and
pets
out
of
the
room;
(
2)
apply
at
rate
of
20
oz
of
product
per
135
square
feet
of
carpet
(
i.
e.
0.011
lb
ai/
100
ft2);
(
3)
leave
on
for
2
hours,
then
vacuum;
(
4)
remove
vacuum
bag
and
discard
in
trash.
There
was
no
data
available
to
quantify
the
deposition
of
MKG­
264
following
vacuuming.
Therefore,
deposition
rates
of
100%,
50%,
and
25%
of
the
application
label
rate
were
assumed.
The
submission
of
data
with
deposition
rates
following
vacuuming
could
be
used
to
refine
risk
estimates
(
provided
it
meets
Agency
guidelines).

3.2.2
Equations
for
Exposure/
Risk
Estimates
Non­
cancer
risks
were
calculated
using
the
Margin
of
Exposure
(
MOE)
approach,
which
is
a
ratio
of
the
body
burden
to
the
toxicological
endpoint
of
concern.
The
following
equations
were
used
to
calculate
the
average
daily
dose
(
ADD)
for
each
residential
exposure
scenario
in
accordance
with
current
HED
SOPs:

Dermal
Exposure
from
Treated
Lawns
ADD
=
(
TTR0
*
ET
*
TC
*
DA
*
CF1)
/
BW
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
TTRt
=
turf
transferable
residue
on
day
"
0"
(
µ
g/
cm2);
ET
=
exposure
time
(
2
hr/
day);
TC
=
transfer
coefficient
(
14,500
cm2/
hr
for
adults
and
5,200
cm2/
hr
for
toddlers);
DA
=
dermal
absorption
factor
(
10%);
CF1
=
weight
unit
conversion
factor
to
convert
µ
g
units
to
mg
for
the
daily
exposure
(
0.001
mg/
µ
g);
and
BW
=
body
weight
(
60
kg
for
adults
and
15
kg
for
toddlers).

Hand­
to­
mouth
Transfer
from
Treated
Lawns
ADD
=
(
TTR0
*
SA
*
FQ
*
ET
*
SE
*
CF1)
/
BW
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
TTRt
=
turf
transferable
residue
on
day
"
0"
(
µ
g/
cm2
);
Page
31
of
39
SA
=
surface
area
of
the
hands
(
20
cm2/
event);
FQ
=
frequency
of
hand­
to­
mouth
activity
(
20
events/
hr);
ET
=
exposure
time
(
2
hr/
day);
SE
=
extraction
by
saliva
(
50%);
CF1
=
weight
unit
conversion
factor
to
convert
µ
g
units
in
the
DFR
value
to
mg
for
the
daily
exposure
(
0.001
mg/
µ
g);
and
BW
=
body
weight
(
15
kg).

Object­
to­
mouth
Transfer
from
Treated
Lawns
ADD
=
(
TTR0
*
IgR*
CF1)
/
BW
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
TTRt
=
turf
transferable
residue
on
day
"
0"
(
µ
g/
cm2);
IgR
=
ingestion
rate
of
grass
(
25c
cm2/
day);
CF1
=
weight
unit
conversion
factor
to
convert
the
µ
g
of
residues
on
the
grass
to
mg
to
provide
units
of
mg/
day
(
1E­
3
mg/
µ
g);
and
BW
=
body
weight
(
15
kg).

Incidental
Ingestion
of
Treated
Soil
ADD
=
(
SR0
*
IgR
*
CF1)
/
BW
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
SR0t
=
soil
residue
on
day
"
0"
(
0.0022
µ
g/
g);
IgR
=
ingestion
rate
of
soil
(
100
mg/
day);
CF1
=
weight
unit
conversion
factor
to
convert
the
µ
g
of
residues
on
the
soil
to
grams
to
provide
units
of
mg/
day
(
1E­
6
g/
µ
g);
and
BW
=
body
weight
(
15
kg).

and
SRt
=
TTRt
*
F
*
CF2
Where:
TTRt
=
turf
transferable
residue
on
day
"
0"
(
µ
g/
cm2);
F
=
fraction
of
ai
available
in
uppermost
cm
of
soil
(
1
fraction/
cm);
and
CF2
=
volume
to
weight
unit
conversion
factor
to
convert
the
volume
units
(
cm3)
to
weight
units
for
the
SR
value
(
U.
S.
EPA,
1992)
(
0.67
cm3/
g
soil).

Dermal
Exposure
From
Treated
Pets
(
based
on
R­
SOPs)

D
=
{((
AR*
FAR)/
SApet)
*
(
1­
DR)
t
*
SAhug
*
DA}/
BW
Where:
ADD
=
average
daily
dose
via
dermal
pet
contact
(
mg/
kg/
day);
AR
=
application
rate
or
amount
applied
to
animal
in
a
single
treatment
(
mg
ai/
animal);
FAR
=
fraction
of
the
application
rate
available
for
dermal
contact
as
transferable
residue
(
20%);
SApet
=
surface
area
of
a
treated
30
lb
dog
(
5,986cm2/
animal);
t
=
time
after
application
(
days);
Page
32
of
39
DR
=
fractional
dissipation
rate
per
day
(
5%
per
day);
SA
hug
=
surface
area
of
a
child
hug
(
1,875cm2
contact/
hug);
DA
=
dermal
absorption
factor
(
10%);
and
BW
=
body
weight
(
15
kg).

Hand­
to­
mouth
Transfer
From
Treated
Pets
(
based
on
R­
SOPs)

D
=
{((
AR*
FAR)/
SApet)
*
(
1­
DR)
t
*
SE
*
SAhands
*
FQ
*
ET
*
DA}/
BW
Where:
D
=
nondietary
ingestion
dose
from
with
treated
pets
(
mg/
day);
AR
=
application
rate
or
amount
applied
to
animal
in
a
single
treatment
(
mg
ai/
animal);
FAR
=
fraction
of
the
application
rate
available
for
dermal
contact
as
transferable
residue
(
20%/
100);
SApet
=
surface
area
of
a
treated
dog
(
5,986
cm2/
animal);
t
=
time
after
application
(
days);
DR
=
fractional
dissipation
rate
per
day
(
5%
per
day/
100);
SE
=
saliva
extraction
factor
(
50%
extractability);
SAhands
=
surface
area
of
the
hands
(
20
cm2);
FQ
=
frequency
of
hand­
to­
mouth
activity
(
20
events/
hr);
ET
=
exposure
time
(
2
hr/
day);
DA
=
dermal
absorption
factor
(
10%);
and
BW
=
body
weight
(
15
kg).

Dermal
Exposure
From
Treated
Pets
(
based
on
MGK­
264
shampoo
study)

ADD
=
AR
*
UE
*
DA
/
BW
Where
ADD
=
Average
Daily
Dose
(
mg/
kg/
day),
AR
=
Application
rate
(
lb
ai/
animal),
UE
=
Postapplication
exposure
(
205
mg/
lb
ai
applied/
animal),
DA
=
Dermal
absorption
(
10%),
and
BW
=
Body
weight
(
15
kg).

Hand­
to­
mouth
Transfer
From
Treated
Pets
(
based
on
MGK­
264
shampoo
study)

ADD
=
AR
*
UE
*
CF1
*
SA
*
FQ
*
ET
/
BW
Where:
ADD
=
Average
Daily
Dose
(
mg/
kg/
day),
AR
=
Application
rate
(
lb
ai/
animal),
UE
=
Postapplication
dermal
unit
exposure
to
hands
(
806
ug/
cm2/
lb
ai
applied/
animal),
CF1
=
Conversion
factor
(
0.001
mg/
ug),
SA
=
Surface
area
of
a
toddler's
fingers
(
20
cm2/
event),
FQ
=
Exposure
frequency
(
20
events/
hour),
ET
=
Exposure
time(
0.5
hours/
day),
BW
=
Body
weight
(
15kg).

Dermal
Exposure
from
Indoor
Surfaces
after
Spray
Treatment
Page
33
of
39
ADD
=
(
AR
*
TR
*
ET
*
TC
*
CF1
*
CF2)
/
BW
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
AR
=
application
rate;
(
lb
ai/
ft2)
TR
=
transferable
residue
available
(
5%
for
carpets
and
10%
for
vinyl
flooring,
calculated
from
NDETF
studies);
ET
=
exposure
time
(
8
hr/
day
for
carpets
and
4
hr/
day
for
vinyl
flooring);
TC
=
transfer
coefficient
(
16,700
cm2/
hr
for
adults
and
6,000
cm2/
hr
for
toddlers);
CF1
=
weight
unit
conversion
factor
to
convert
lb
units
to
mg
for
the
daily
exposure
(
4.54E5
mg/
lb)
CF2
=
area
unit
conversion
factor
to
convert
ft2
units
to
cm2
for
the
daily
exposure
(
1.08E­
3
ft2/
cm2);
and
BW
=
body
weight
(
60
kg
for
adults
and
15
kg
for
toddlers).

Hand­
to­
mouth
Transfer
from
Indoor
Surfaces
after
Spray
Treatment
ADD
=
(
AR
*
%
D
*
SA
*
FQ
*
ET
*
SE
*
CF1
*
CF2)
/
BW
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
AR
=
application
rate;
%
D
=
percent
active
ingredient
dislodgeable
(
5%
for
carpets
and
10%
for
vinyl
flooring,
calculated
from
NDETF
studies);
SA
=
surface
area
of
the
hands
(
20
cm2/
event);
FQ
=
frequency
of
hand­
to­
mouth
activity
(
20
events/
hr);
ET
=
exposure
time
(
2
hr/
day);
SE
=
extraction
by
saliva
(
50%);
CF1
=
weight
unit
conversion
factor
to
convert
lb
units
to
mg
for
the
daily
exposure
(
4.54E5
mg/
lb)
CF2
=
area
unit
conversion
factor
to
convert
ft2
units
to
cm2
for
the
daily
exposure
(
1.08E­
3
ft2/
cm2);
and
BW
=
body
weight
(
15
kg).

Dermal
Exposure
from
Indoor
Surfaces
after
Fogger
Treatment
ADD
=
(
AR
*
TR
*
ET
*
TC
*
CF1
*
CF2)
/
(
BW
*
RS)
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
AR
=
application
rate
(
lb
ai/
fogger);
TR
=
transferable
residue
available
(
4.5%
for
carpets
and
2.3%
for
vinyl
flooring,
calculated
from
NDETF
studies);
ET
=
exposure
time
(
8
hr/
day
for
carpets
and
4
hr/
day
for
vinyl
flooring);
TC
=
transfer
coefficient
(
16,700
cm2/
hr
for
adults
and
6,000
cm2/
hr
for
toddlers)
CF1
=
weight
unit
conversion
factor
to
convert
lb
units
to
mg
for
the
daily
exposure
(
4.54E8
mg/
lb)
CF2
=
area
unit
conversion
factor
to
convert
ft2
units
to
cm2
for
the
daily
exposure
(
1.08E­
3
ft2/
cm2);
BW
=
body
weight
(
60
kg
for
adults
and
15
kg
for
toddlers);
and
RS
=
room
size
in
square
feet
(
264
sq
feet
based
on
NDETF
studies).
Page
34
of
39
Hand­
to­
mouth
Transfer
from
Indoor
Surfaces
after
Fogger
Treatment
ADD
=
(
AR
*
%
D
*
SA
*
FQ
*
ET
*
SE
*
CF1
*
CF2)
/
BW
*
RS
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
AR
=
application
rate(
lb
ai/
fogger);
%
D
=
percent
active
ingredient
dislodgeable
(
9.1%
for
carpets
and
5.8%
for
vinyl
flooring,
calculated
from
NDETF
studies);
SA
=
surface
area
of
the
hands
(
20
cm2/
event);
FQ
=
frequency
of
hand­
to­
mouth
activity
(
20
events/
hr);
ET
=
exposure
time
(
2
hr/
day);
SE
=
extraction
by
saliva
(
50%);
CF1
=
weight
unit
conversion
factor
to
convert
lb
units
to
mg
for
the
daily
exposure
(
4.54E5
mg/
lb)
CF2
=
area
unit
conversion
factor
to
convert
ft2
units
to
cm2
for
the
daily
exposure
(
1.08E­
3
ft2/
cm2);
BW
=
body
weight
(
15
kg);
and
RS
=
room
size
in
square
feet
(
264
sq
feet
based
on
NDETF
studies).

Inhalation
Exposure
from
Space
Spray
Applications
ADD
=
(
BZC
*
BR
*
ET)
/
BW
Where:
BZC
=
Breathing
zone
concentration
in
mg/
m3
(
for
aerosol
sprays
the
measured
air
concentration
from
NDETF
study
adjusted
to
reflect
the
application
rate
the
BZC
is
2.28
mg/
m3,
for
metered
release
in
homes
the
24
hr
BZC
is
0.23
mg/
m3)
BR
=
Breathing
rate
for
adult
or
child
in
m3/
hr
or
m3/
day
(
adult
is
13.3
m3/
day
or
1.0
m3/
hr,
child
is
8.7
m3/
day
or
0.7
m3/
hr);
BW
=
body
weight
(
70
kg
for
adults
and
15
kg
for
toddlers);
and
ET
=
exposure
time
(
hrs/
day);

Dermal
Exposure
from
Insect
Repellents
Applied
to
Skin
ADD
=
(
AR
*
%
ai
*
SA
*
DA*
FQ)/
BW
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
AR
=
application
rate(
mg
product/
cm2
of
skin);
%
ai
=
percent
active
ingredient
in
formulation
(
8%)
SA
=
surface
area
of
the
body
(
cm2);
%
SA
=
percent
of
SA
treated
(
25%);
DA
=
dermal
absorption
factor
(
10%);
and
FQ
=
frequency
of
application
(
1
per
day);
and
BW
=
body
weight
(
70
kg
for
adults
and
15
kg
for
toddlers)

Oral
Exposure
from
Insect
Repellents
applied
to
Skin
ADD
=
(
AR
*
%
ai
*
SA
*
SE*
FQ)/
BW
Where:
Page
35
of
39
ADD
=
average
daily
dose
(
mg/
kg/
day);
AR
=
application
rate(
mg
product/
cm2
of
skin);
%
ai
=
percent
active
ingredient
in
formulation
(
8%)
SA
=
surface
area
of
the
hands
(
20
cm2/
event);
FQ
=
frequency
of
hand­
to­
mouth
activity
(
1
event/
day);
SE
=
extraction
by
saliva
(
50%);
FQ
=
frequency
of
application
(
1
per
day);
and
BW
=
body
weight
(
15
kg
for
toddlers)
Page
36
of
39
3.2.3
Risk
Summary
Estimated
MOEs
for
adults
and
toddlers
were
calculated
for
postapplication
risks
following
the
application
of
MGK­
264
to
home
lawns,
indoor
spaces/
surfaces,
and
pets
and
summarized
in
Table
7.
MOEs
of
less
than
1,000
were
estimated
for
the
following
scenarios:

Toddlers
C
Dermal
exposure
for
indoor
spray
applications
to
hard
and
carpeted
surfaces
(
MOE=
80)

C
Dermal
exposure
for
indoor
fogger
applications
to
carpeted
surfaces
(
MOE=
840)

C
Oral
exposure
to
indoor
dust
applications
to
carpeted
surfaces
(
MOE
=
850
for
50%
deposition)

C
Dermal
exposure
to
indoor
dust
applications
to
carpeted
surfaces
(
MOE
=
410
for
25%
deposition)

C
Inhalation
exposure
to
indoor
space
applications
done
with
an
aerosol
can
(
MOE
=
52)

C
Inhalation
exposure
to
indoor
metered
release
applications
(
MOE
=
13
for
0.18
ACH
and
MOE=
140
for
2
ACH)

C
Dermal
exposure
to
5%
insect
repellants
applied
to
skin
(
MOE
=
38
for
one
application)

C
Oral
exposure
to
5%
insect
repellants
applied
to
skin
(
MOE
=
38
to
110
for
one
application)

Adults
C
Dermal
exposure
to
indoor
dust
applications
to
carpeted
surfaces
(
MOE
=
290
for
25%
deposition)

C
Inhalation
exposure
to
indoor
space
applications
done
with
an
aerosol
can
(
MOE
=
170)

C
Inhalation
exposure
to
indoor
metered
release
applications
(
MOE
=
40
for
0.18
ACH
and
MOE
=
440
for
2
ACH)

C
Dermal
exposure
to
5%
insect
repellants
applied
to
skin
(
MOE
=
140
to
160
for
one
application)
Page
37
of
39
Table
7.
Residential
Postapplication
MOEs
Exposure
Scenario
Route
of
Exposure
Application
Rate
MOEs1
Adults
Toddlers
Outdoors
Residential
Turf
(
High
Contact
Activities)
Dermal
0.3
lb
ai/
acre
7,500
5,231
Residential
Turf
(
Mowing)
Dermal
0.3
lb
ai/
acre
30,000
NA
Hand
to
Mouth
Activity
on
Turf
Oral
0.3
lb
ai/
acre
NA
14,000
Object
to
Mouth
Activity
on
Turf
Oral
0.3
lb
ai/
acre
NA
54,400
Incidental
Soil
Ingestion
Oral
0.3
lb
ai/
acre
NA
4,100,000
Indoors
Hand
to
Mouth
Activity
on
Indoor
Surfaces
(
Spray
applications
to
carpeted
surfaces)
Oral
0.01
lb
ai/
1000
ft2
NA
4,700
Hand
to
Mouth
Activity
on
Indoor
Surfaces
(
Fogger
applications
to
carpeted
surfaces)
Oral
0.01
lb
ai/
1000
ft2
NA
2,500
Hand
to
Mouth
Activity
on
Indoor
Surfaces
(
Fogger
applications
to
hard
surfaces)
Oral
0.01
lb
ai/
1000
ft2
NA
7,900
Hand
to
Mouth
Activity
on
Indoor
Surfaces
(
dust
applications
to
carpeted
surfaces)
100%
of
surface
residue
available
Oral
0.011
lb
ai/
100
ft2
NA
430
Hand
to
Mouth
Activity
on
Indoor
Surfaces
(
dust
applications
to
carpeted
surfaces)
50%
of
surface
residue
available
Oral
0.011
lb
ai/
100
ft2
NA
850
Hand
to
Mouth
Activity
on
Indoor
Surfaces
(
dust
applications
to
carpeted
surfaces)
25%
of
surface
residue
available
Oral
0.011
lb
ai/
100
ft2
NA
1700
Indoor
Surfaces
(
Spray
applications
to
carpeted/
hard
surfaces)
Dermal
0.01
lb
ai/
1000
ft2
1,000
780
Indoor
Surfaces
(
Fogger
applications
to
carpeted
surfaces)
Dermal
0.01
lb
ai/
1000
ft2
1,200
840
Indoor
Surfaces
(
Fogger
applications
to
hard
surfaces)
Dermal
0.01
lb
ai/
1000
ft2
4,700
3,300
Indoor
Surfaces
(
dust
applications
to
carpeted
surfaces)
100%
of
surface
residue
available
Dermal
0.011
lb
ai/
100
ft2
100
70
(
dust
applications
to
carpeted
surfaces)
50%
of
surface
residue
available
Dermal
0.011
lb
ai/
100
ft2
210
140
(
dust
applications
to
carpeted
surfaces)
25%
of
surface
residue
available
Dermal
0.011
lb
ai/
100
ft2
290
410
Inhalation
Exposure
from
Space
Sprays
(
aerosol
cans)
Inhalation
0.001
lb
ai/
1000
ft3
170
52
Inhalation
Exposure
from
Space
Sprays
in
homes
(
metered
release
with
0.18
air
changes
per
hour)
Inhalation
1.77
mg
ai/
spray
event
40
13
Inhalation
Exposure
from
Space
Sprays
(
metered
release
with
2
air
changes
per
hour)
Inhalation
1.77
mg
ai/
spray
event
440
140
Table
7.
Residential
Postapplication
MOEs
Exposure
Scenario
Route
of
Exposure
Application
Rate
MOEs1
Adults
Toddlers
Page
38
of
39
Pets
Hand
to
Mouth
Activity
Following
Pet
Contact
(
Dust
using
R­
SOPs)
Oral
0.00248
lb
ai/
animal
NA
130
Pet
Contact
(
Dust
using
R­
SOPs)
Dermal
0.05lb
ai/
animal
NA
61
Hand
to
Mouth
Activity
Following
Pet
Contact
(
Shampoo
using
MGK­
264
data)
Oral
0.00088
lb
ai/
animal
NA
6,500
Hand
to
Mouth
Activity
Following
Pet
Contact
(
Mousse,
Soap,
Gel,
Comb
or
roll­
on
using
MGK­
264
data)
Oral
0.00044
lb
ai/
animal
NA
13,000
Pet
Contact
(
Shampoo
using
MGK­
264
data)
Dermal
0.00088
lb
ai/
animal
NA
100,000
Pet
Contact
(
Mousse,
Soap,
Gel,
Comb
or
roll­
on
using
MGK­
264
data)
Dermal
0.00044lb
ai/
animal
NA
50,000
Insect
Repellents
Applied
to
Skin
One
Application
to
25%
of
Body
Surface
Area
Using
1
mg
product
per
cm2
of
skin
Dermal
8%
ai
formulation
100
70
Oral
NA
1,100
One
Application
Based
on
REJV
Survey
Data
Dermal
88
24
One
Application
to
25%
of
Body
Surface
Area
Using
1
mg
product
per
cm2
of
skin
Dermal
5%
ai
formulation
160
110
Oral
NA
1,830
One
Application
Based
on
REJV
Survey
Data
Dermal
140
38
1
MOEs
of
less
than
1,000
are
a
risk
concern
Page
39
of
39
Appendices
(
14
pages
of
Excel
Spread
Sheets)
