Page
1
of
114
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY,
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
June
30,
2006
Memorandum
SUBJECT:
Triadimefon:
Occupational
and
Residential
Exposure
Assessment
for
the
Reregistration
Eligibility
Decision
Document.

FROM:
Shanna
Recore
Reregistration
Branch
2
Health
Effects
Division
(
7509P)

THROUGH:
Alan
Nielsen,
Branch
Senior
Scientist
Reregistration
Branch
2
Health
Effects
Division
(
7509P)

TO:
Richard
Griffin,
Risk
Assessor
Reregistration
Branch
2
Health
Effects
Division
(
7509P)

PC
Code:
109901
DP
Barcode:
314814
(
Occupational)
315040
(
Residential)

The
attached
assessment
is
the
occupational
and
non­
occupational
(
residential)
exposure
and
risk
estimates
for
triadimefon
to
support
HED's
reregistration
eligibility
decision
(
RED)
document.
The
data
analysis
included
in
this
assessment
was
prepared
by
Versar,
Inc
under
the
supervision
of
HED.
Page
2
of
114
Table
of
Contents
Executive
Summary.................................................................................................................................
3
1.0
Occupational
and
Residential
Exposure/
Risk
Assessment
............................................................
7
1.1
Purpose...................................................................................................................................
7
1.2
Criteria
for
Conducting
Exposure
Assessments
.......................................................................
7
1.3
Summary
of
Hazard
Concerns
for
Triadimefon
...................................................................
7
1.4
Incident
Reports....................................................................................................................
10
1.5
Summary
of
Physical
and
Chemical
Properties
of
Triadimefon..............................................
10
1.6
Summary
of
Use
Patterns
and
Formulations
..........................................................................
10
1.6.1
End­
Use
Products
.........................................................................................................
10
1.6.2
Registered
Use
Categories
and
Sites
.............................................................................
10
1.6.3
Application
Methods
....................................................................................................
13
2.0
Occupational
Exposures
and
Risks
............................................................................................
14
2.1
Occupational
Handler
Exposures
and
Risks...........................................................................
14
2.1.1
Data
and
Assumptions
for
Handler
Exposure
Scenarios
................................................
16
2.1.2
Noncancer
Triadimefon
Handler
Exposure
and
Assessment
..........................................
24
2.1.3
Cancer
Triadimefon
Handler
Exposure
and
Risk
Assessment
........................................
81
2.1.4
Summary
of
Risk
Concerns
and
Data
Gaps
for
Occupational
Handlers..........................
81
2.1.5
Recommendations
For
Refining
Occupational
Handler
Risk
Assessment
......................
81
2.2
Occupational
Postapplication
Exposures
and
Risks
...............................................................
82
2.2.1
Occupational
Postapplication
Exposure
Scenarios.........................................................
82
2.2.2
Data/
Assumptions
for
Postapplication
Exposure
Scenarios............................................
85
2.2.3
Occupational
Postapplication
Exposure
and
Noncancer
Risk
Estimates.........................
85
2.2.4
Occupational
Postapplication
Exposure
and
Risk
Estimates
for
Cancer
.........................
88
2.2.5
Summary
of
Occupational
Postapplication
Risk
Concerns
and
Data
Gaps
.....................
88
2.2.6
Recommendations
for
Refining
Occupational
Postapplication
Risk
Assessment
............
88
3.0
Residential
and
Other
Non­
Occupational
Exposures
and
Risks
..................................................
88
3.1
Residential
Handler
Exposures
and
Risks
..............................................................................
89
3.1.1
Handler
Exposure
Scenarios
.........................................................................................
89
3.1.2
Data
and
Assumptions
For
Handler
Exposure
Scenarios................................................
90
3.1.3
Residential
Handler
Exposure
and
Noncancer
Risk
Estimates
.......................................
93
3.1.4
Residential
Handler
Exposure
and
Risk
Estimates
for
Cancer......................................
100
3.1.5
Summary
of
Risk
Concerns
and
Data
Gaps
for
Handlers.............................................
100
3.1.6
Recommendations
for
Refining
Residential
Handler
Risk
Assessment
........................
101
3.2
Residential
Postapplication
Exposures
and
Risks.................................................................
101
3.2.1
Residential
Postapplication
Exposure
Scenarios
..........................................................
101
3.2.2
Data
and
Assumptions
for
Residential
Postapplication
Exposure
Scenarios
.................
103
3.2.3
Residential
Postapplication
Exposure
and
Noncancer
Risk
Estimates
..........................
106
3.2.4
Residential
Postapplication
Exposure
and
Risk
Estimates
for
Cancer
..........................
113
3.2.5
Summary
of
Residential
Postapplication
Risk
Concerns
and
Data
Gaps
....................
113
3.2.6
Recommendations
for
Refining
Residential
Postapplication
Risk
Assessments............
114
Page
3
of
114
Executive
Summary
Triadimefon
is
a
systemic
fungicide
used
in
agricultural,
commercial,
and
residential
settings
in
the
United
States.
It
is
formulated
as
an
emulsifiable
concentrate,
wettable
powder,
water
soluble
packet,
water
dispersible
granule
(
dry
flowable),
and
granular.

Hazard
Concerns:
The
toxicological
endpoints
used
to
complete
the
occupational
and
residential
risk
assessment
were
based
on
the
professional
judgment
of
HED
toxicologists.
Adverse
effects
were
identified
at
durations
of
exposure
ranging
from
short­
term
(
up
to
30
days)
to
intermediate­
term
durations
(>
30
days
up
to
6
months)
and
long­
term
durations
(>
6
months).
No
cancer
endpoint
was
identified;
therefore,
cancer
risks
are
not
assessed.

The
short­
and
intermediate­
term
dermal
risk
assessment
for
triadimefon
is
based
on
a
NOAEL
of
300
mg/
kg/
day
from
a
dermal
study.
The
short­
and
intermediate­
term
inhalation
risk
assessment
for
triadimefon
is
based
on
a
NOAEL
of
3.4
mg/
kg/
day,
which
is
based
on
an
oral
neurotoxicity
study.
Long­
term
exposure
to
triadimefon
is
not
expected
for
current
registered
uses.
HED's
level
of
concern
(
LOC)
for
occupational
triadimefon
dermal
and
inhalation
exposures
is
100
 
that
means
that
a
margin
of
exposure
(
MOE)
less
than
100
exceeds
HED's
level
of
concern.
The
level
of
concern
for
occupational
scenarios
is
based
on
10x
for
interspecies
extrapolation
and
10x
for
intraspecies
extrapolation.
HED's
level
of
concern
(
LOC)
for
nonoccupational
(
residential)
triadimefon
dermal
and
inhalation
exposures
are
1000
 
that
means
that
a
margin
of
exposure
(
MOE)
less
than
1000
exceeds
HED's
level
of
concern
for
residential
scenarios.
The
level
of
concern
for
residential
scenarios
is
based
on
10x
for
interspecies
extrapolation,
10x
for
intraspecies
extrapolation,
and
an
additional
10x
for
database
uncertainty.
The
dermal
endpoint
is
based
on
a
dermal
study;
therefore
no
dermal
absorption
adjustment
is
needed.
The
inhalation
endpoint
is
based
on
an
oral
neurotoxicity
study
and
100
percent
inhalation
absorption
is
assumed.
The
dermal
and
inhalation
margins
of
exposure
were
combined
for
the
triadimefon
risk
assessment
because
the
toxicity
endpoints
for
the
dermal
and
inhalation
routes
of
exposure
are
based
on
the
same
toxicological
effects.

Use
Patterns:
Large­
scale
applications
of
triadimefon
are
applied
with
several
types
of
application
equipment,
including
aircraft,
groundboom
sprayers,
airblast
sprayers,
tractor­
drawn
spreaders,
rights­
of­
way
sprayers,
and
chemigation.
Applications
to
smaller
areas
may
be
made
with
handheld
equipment,
including
low­
pressure
handwand
sprayers,
high­
pressure
handwand
sprayers,
handgun
sprayers,
push­
type
spreaders,
and
bellygrinders.
Triadimefon
is
also
applied
as
a
post­
harvest
spray
or
dip,
as
a
tree­
injection,
and
as
a
ready­
to­
use
briquette.
In
addition,
triadimefon
is
applied
to
seeds
using
both
on­
nursery
and
commercial
seed
treatment
equipment.

Occupational
Handler
Risks:
It
has
been
determined
that
exposure
to
pesticide
handlers
is
likely
during
the
occupational
use
of
triadimefon
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
triadimefon
applications.
In
most
non­
seed
treatment
scenarios,
dermal
and
inhalation
MOEs
met
or
exceeded
the
required
uncertainty
factor
of
100
at
some
level
of
risk
mitigation.
In
the
majority
of
scenarios
where
data
are
available,
inhalation
risks
were
not
a
concern
at
baseline
(
no
respirator)
and
dermal
risks
were
not
a
concern
at
baseline
or
baseline
plus
chemical­
resistant
Page
4
of
114
gloves.
However,
there
were
inhalation
concerns
for
several
of
the
scenarios
involving
mixing/
loading
wettable
powder
to
support
application
to
turf
unless
engineering
controls
(
water­
soluble
packaging)
are
used.
The
inhalation
risk
in
one
scenario
remains
a
concern
with
maximum
inhalation
risk
mitigation:

 
Mixing/
loading/
applying
wettable
powders
with
a
low
pressure
handwand
(
using
PHED
data)
to
turf
(
LCO
and
golf
course)
at
the
5.4
lb
ai/
A
(
CA
only)
application
rate
(
the
dermal
MOE
=
110
with
double
layer
and
gloves;
however
the
inhalation
MOE
=
80
with
a
90%
protection
factor
half­
face
respirator).

In
the
majority
of
scenarios
where
data
are
available,
total
risks
were
not
a
concern
at
baseline
(
long­
sleeve
shirt,
long
pants,
shoes,
socks,
no
respirator)
or
baseline
plus
chemical­
resistant
gloves.
However,
there
were
risk
concerns
for
several
of
the
scenarios
involving
mixing/
loading
wettable
powder
to
support
application
to
turf
unless
engineering
controls
(
water­
soluble
packaging)
are
used.
The
inhalation
risk
for
two
scenarios
remains
a
concern
with
maximum
inhalation
risk
mitigation:

 
Mixing/
loading/
applying
wettable
powders
with
a
low
pressure
handwand
(
using
PHED
data)
to
turf
(
LCO
and
golf
course)
at
the
5.4
lb
ai/
A
application
rate,
where
the
MOE
=
46
with
double
layer
and
gloves
and
a
90%
protection
factor
half­
face
respirator;
and
 
Mixing/
loading/
applying
wettable
powders
with
a
low
pressure
handwand
(
using
PHED
data)
to
turf
(
LCO
and
golf
course)
at
the
2.7
lb
ai/
A
application
rate,
where
the
MOE
=
92
with
double
layer
and
gloves
and
a
90%
protection
factor
half­
face
respirator.

There
are
no
data
to
assess
risks
to
pilots,
except
when
engineering
controls
(
enclosed
cockpits)
are
used.
Risks
are
not
of
concern
for
pilots
using
enclosed
cabs.

There
are
no
data
to
assess
mixing/
loading/
applying
liquids
with
a
tree
injector
or
mixing/
loading/
applying
ready­
to­
use
briquettes.
HED
recommends
that
handlers
in
these
scenarios
wear
baseline
attire
plus
chemical­
resistant
gloves.
There
also
are
no
data
to
assess
mixing/
loading/
applying
dips.
HED
recommends
that
handlers
involved
in
dip
applications
wear
baseline
attire
plus
chemical­
resistant
gloves
and
chemical­
resistant
apron.

In
all
the
on­
nursery
seed
treatment
scenarios
where
data
are
available,
inhalation
MOEs
exceeded
the
required
uncertainty
factor
of
100
at
baseline
(
no
respirator)
and
dermal
MOEs
exceeded
the
required
uncertainty
factor
of
100
at
baseline
(
long­
sleeve
shirt,
long
pants,
shoes,
and
socks)
or
baseline
plus
chemical­
resistant
gloves.
Additionally,
combined
dermal
and
inhalation
MOEs
met
or
exceeded
the
required
uncertainty
factor
of
100
at
some
level
of
risk
mitigation.

HED
has
no
data
to
assess
risks
to
handlers
participating
in
drying,
raking,
and
bagging
treated
seed;
however,
HED
expects
that
exposures
could
be
significant.
Therefore,
HED
recommends
that
these
handlers
wear
baseline
attire
plus
chemical­
resistant
gloves
and
chemical­
resistant
apron.
Page
5
of
114
For
commercial
seed
treatment,
all
dermal
MOEs
met
or
exceeded
the
required
uncertainty
factor
at
either
baseline
or
baseline
plus
chemical­
resistant
gloves.
However,
the
inhalation
and
total
risks
remain
a
concern
for
one
scenario
even
with
maximum
inhalation
risk
mitigation:
multiple
activities
for
ponderosa
pine
seed,
where
inhalation
MOE
=
92
with
a
90%
protection
factor
halfface
respirator.

Occupational
Postapplication
Risks:
Triadimefon
can
be
used
on
agricultural
(
including
ornamental)
crops.
As
a
result,
a
wide
array
of
individuals
can
potentially
be
exposed
by
working
in
areas
that
have
been
previously
treated.
To
develop
a
postapplication
assessment,
HED
considers
the
types
of
tasks
and
activities
that
individuals
are
likely
to
be
doing
in
areas
recently
treated
with
a
pesticide.
In
agricultural
crop
settings
(
including
ornamentals
grown
for
sale),
the
use
of
personal
protective
equipment
or
other
types
of
equipment
to
mitigate
postapplication
exposures
to
workers
is
not
considered
a
viable
alternative
for
the
regulatory
process.
Instead,
an
administrative
approach
 
a
Restricted
Entry
Interval
or
REI
 
is
used
to
mitigate
postapplication
risks
following
applications
to
crops.
The
REI
is
a
time
period
following
a
pesticide
application
during
which
entry
into
the
treated
area
is
restricted.
Postapplication
risk
levels
are
generally
calculated
in
the
risk
assessment
process
on
a
chemical­,
crop­,
and
activity­
specific
basis.
To
establish
REIs,
HED
considers
postapplication
risks
on
varying
days
after
application.
The
results
of
the
occupational
postapplication
exposure
and
risk
assessment
indicate
that
postapplication
risks
are
not
a
concern
on
day
0
(
12
hours
following
application)
for
all
crops.

Residential
Handler
Risks:
HED
determined
that
exposure
to
pesticide
handlers
is
likely
during
the
residential
use
of
triadimefon
in
a
variety
of
outdoor
environments,
including
on
lawns,
gardens,
and
ornamentals.
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
triadimefon
applications.
The
quantitative
exposure/
risk
assessment
developed
for
residential
handlers
is
based
on
these
scenarios.

Short­
term
risks
for
residential
handlers
were
estimated.
Intermediate­
term
exposures
are
not
likely
because
of
the
intermittent
nature
of
applications
by
homeowners.
Inhalation
risks
for
residential
handlers
are
not
a
concern
for
all
residential
uses
of
triadimefon.
Dermal
and
total
risks
for
residential
handlers
are
not
a
concern
for
most
scenarios;
however,
dermal
and
total
risks
remain
a
concern
(
MOEs
<
1000)
for:

 
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
(
using
ORETF
data)
to
greenhouse
ornamentals
(
trees
and
shrubs)
at
0.00938
lb
ai/
gal
(
MOE
=
490);
 
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
(
using
ORETF
data)
to
greenhouse
ornamentals
(
flowers)
at
0.00938
lb
ai/
gal
(
MOE
=
560);
 
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
(
using
ORETF
data)
to
turf
(
home
lawns)
(
MOE
=
440);
 
mixing/
loading/
applying
wettable
powders
with
hose­
end
sprayer
(
residential
ORETF
data
­­
liquid
concentrate
data)
to
greenhouse
ornamentals
(
trees
and
shrubs)
at
0.00625
lb
ai/
gal
(
MOE
=
740);
and
Page
6
of
114
 
mixing/
loading/
applying
wettable
powders
with
hose­
end
sprayer
(
residential
ORETF
data
­­
liquid
concentrate
data)
to
greenhouse
ornamentals
(
flowers)
at
0.00625
lb
ai/
gal
(
MOE
=
850).

Residential
Postapplication
Risks:
HED
determined
there
is
a
potential
for
exposure
from
entering
triadimefon­
treated
residential
areas,
such
as
lawns,
golf
courses,
and
home
gardens
that
could
lead
to
exposures
to
adults
and
children.
In
the
residential
postapplication
exposure
and
risk
assessment,
HED
has
a
number
of
risk
concerns
for
triadimefon.

Risks
were
calculated
for
adults
after
lawn
and
home
garden
applications
of
triadimefon.
For
the
residential
adult
scenarios,
short­
term
MOEs
are
>
1,000
on
the
day
of
application
for
all
scenarios,
except
mowing
at
the
5.4/
5.2
lb
ai/
A
(
CA
only)
application
rate
and
the
high
contact
turf
activities
at
the
5.4/
5.2
and
2.7
lb
ai/
A
application
rates.
Youths
were
considered
in
the
home
garden,
residential
turf/
mowing,
and
golfer
scenarios.
Short­
term
MOEs
for
these
youths
were
>
1,000
for
all
of
the
scenarios
considered
except
mowing
at
the
5.4/
5.2
(
CA
only)
application
rate.
Risks
(
MOEs)
to
toddlers
were
calculated
for
postapplication
risks
following
the
application
of
triadimefon
to
home
lawns.
Only
one
scenario,
incidental
soil
ingestion,
had
MOEs
>
1000.
Short­
term
MOEs
were
<
1000
for
residential
turf/
high
contact
activities,
hand­
tomouth
activities,
object­
to­
mouth
activities,
and
incidental
ingestion
of
granules/
pellets.

HED
combines
risk
values
resulting
from
separate
postapplication
exposure
scenarios
when
it
is
likely
they
can
occur
simultaneously
based
on
the
use­
pattern
and
the
behavior
associated
with
the
exposed
population.
The
combined
risk
assessment
for
exposures
to
toddlers
following
home
lawn
applications
was
calculated.
The
combined
risks
were
below
1000
for
all
application
rates.

An
additional
postapplication
assessment
was
performed
to
assess
the
potential
exposure
of
adults
and
toddlers
to
turf
transplanted
from
sod
farms
into
residential
areas.
Postapplication
risks
were
assessed
assuming
the
2.7
lb
ai/
A
rate
for
sod
farms,
and
attempting
to
estimate
the
number
of
days
prior
to
harvest
where
the
2.7
lb/
A
rate
could
be
applied
to
sodfarms
and
not
result
in
risks
of
concern
to
toddlers
at
residential
sites.
The
results
indicate
that
risks
are
not
a
concern
(
i.
e.,
the
MOEs
are
 
1000)
for
toddlers
at
day
5
for
dermal
exposures,
at
day
13
for
hand­
to­
mouth
exposures,
at
day
5
for
object­
to­
mouth
exposures,
and
at
day
0
for
soil
ingestion
exposures.
The
combined
risks
to
toddlers
are
not
a
concern
at
day
15
following
application
to
sodfarms
at
the
2.7
lb
ai/
A
rate.
Page
7
of
114
1.0
Occupational
and
Residential
Exposure/
Risk
Assessment
1.1
Purpose
This
document
is
the
occupational
and
residential
non­
dietary
exposure
and
risk
assessment
for
triadimefon
from
its
use
as
a
systemic
fungicide.
In
this
document,
which
is
for
use
in
EPA's
development
of
the
HED
chapter
of
the
triadimefon
RED
Document,
EPA
presents
the
results
of
its
review
of
the
potential
human
health
effects
of
occupational
and
residential/
nonoccupational
exposure
to
triadimefon.

1.2
Criteria
for
Conducting
Exposure
Assessments
An
occupational
and/
or
residential
exposure
assessment
is
required
for
an
active
ingredient
if
(
1)
certain
toxicological
criteria
are
triggered
and
(
2)
there
is
a
potential
for
exposure
to
handlers
(
mixers,
loaders,
applicators)
during
use
or
to
persons
entering
treated
sites
or
exposed
to
vapors
after
application
is
complete.
Toxicological
endpoints
were
selected
for
short­
and
intermediate­
term
dermal
and
inhalation
exposures
to
triadimefon.
There
is
a
significant
potential
for
exposure
in
a
variety
of
occupational
agricultural
and
commercial
settings
as
well
as
in
residential
settings.
Therefore,
risk
assessments
are
required
for
occupational
and
residential
handlers
as
well
as
for
occupational
and
residential
postapplication
exposures
that
can
occur
as
a
result
of
triadimefon
use.

1.3
Summary
of
Hazard
Concerns
for
Triadimefon
The
toxicological
endpoints
used
to
complete
the
occupational
and
residential
risk
assessment
were
based
on
the
best
professional
judgement
of
HED
toxicologists.
Adverse
effects
were
identified
at
durations
of
exposure
ranging
from
short­
term
(
up
to
30
days)
to
intermediate­
term
durations
(>
30
days
up
to
6
months)
and
long­
term
durations
(>
6
months).
No
cancer
endpoint
was
identified;
therefore,
cancer
risks
are
not
assessed.

Triadimefon
is
an
systemic
fungicide
where
the
use
patterns
can
vary
widely
ranging
from
short­
term
through
intermediate­
term
exposure
durations.
As
such,
when
the
HIARC
evaluated
the
triadimefon
hazard
database,
endpoints
were
selected
to
address
each
duration
of
exposure.
Triadimefon
exposures
are
expected
to
occur
to
both
occupational
and
residential
users.

Dermal
Route
The
short­
and
intermediate­
term
dermal
risk
assessment
for
triadimefon
is
based
on
an
NOAEL
of
300
mg/
kg/
day
from
a
dermal
study.
The
NOAEL
was
based
on
increased
reactivity
and
activity
in
the
females.
Long­
term
exposures
to
triadimefon
(
i.
e.,
greater
than
6
months)
are
not
expected
for
current
registered
uses.

Inhalation
Route
The
short­
and
intermediate­
term
inhalation
risk
assessment
for
triadimefon
is
based
on
Page
8
of
114
an
NOAEL
of
3.4
mg/
kg/
day,
which
is
based
on
a
subchronic
neurotoxicity
study.
The
NOAEL
was
based
largely
on
hyperactivity
in
both
males
and
females.
Long­
term
exposure
to
triadimefon
(
i.
e.,
greater
than
6
months)
is
not
expected
for
current
registered
uses.

Incidental
Oral
Route
The
short­
term
incidental
oral
risk
assessment
for
triadimefon
is
based
on
an
NOAEL
of
3.4
mg/
kg/
day,
which
is
based
on
a
subchronic
neurotoxicity
study.
The
NOAEL
was
based
largely
on
hyperactivity
in
both
males
and
females.

Level
of
Concern
(
LOC)

HED's
level
of
concern
(
LOC)
for
occupational
triadimefon
dermal
and
inhalation
exposures
is
100
(
i.
e.,
a
margin
of
exposure
(
MOE)
less
than
100
exceeds
HED's
level
of
concern).
The
level
of
concern
is
based
on
10x
for
interspecies
extrapolation,
and
10x
for
intraspecies
extrapolation.
HED's
level
of
concern
(
LOC)
for
nonoccupational
(
residential)
triadimefon
dermal
and
inhalation
exposures
is
1000
(
i.
e.,
a
margin
of
exposure
(
MOE)
less
than
1000
exceeds
HED's
level
of
concern).
The
level
of
concern
is
based
on
10x
for
interspecies
extrapolation,
10x
for
intraspecies
extrapolation,
and
10x
for
database
uncertainty.

Aggregation
The
dermal
and
inhalation
margins
of
exposure
were
combined
for
the
triadimefon
risk
assessment
because
the
toxicity
endpoints
for
the
dermal
and
inhalation
routes
of
exposure
are
based
on
the
similar
toxicological
effects.

Cancer
No
cancer
endpoint
was
identified.

Acute
Toxicity
Triadimefon
is
classified
as
category
III
for
acute
oral
and
acute
dermal
toxicity
and
category
IV
for
inhalation
toxicity.
It
is
classified
as
category
IV
for
eye
irritation
potential
and
for
skin
irritation
potential.
Results
were
positive
for
dermal
sensitization
in
guinea
pigs.
The
acute
toxicity
profile
for
triadimefon
is
presented
in
Table
1.

Body
Weight
The
adverse
effects
for
the
dermal
endpoint
were
observed
only
in
females.
Therefore,
the
body
weight
of
an
average
female
adult
(
i.
e.,
60
kg)
was
used
to
estimate
dermal
dose.
The
adverse
effects
for
the
inhalation
endpoint
are
observed
in
both
males
and
females.
Therefore,
the
body
weight
of
an
average
adult
(
i.
e.,
70
kg)
was
used
to
estimate
inhalation
dose.
Page
9
of
114
Table
1.
Acute
Toxicity
Profile
­
Triadimefon
Guideline
No.
Study
Type
MRID(
s)
Results
Toxicity
Category
870.1100
Acute
oral
­
rat
00264276
LD50
=
1470
mg/
kg
(
Males)
LD50
=
1090
mg/
kg
(
Females)
III
870.1200
Acute
dermal­
rabbit
00264276
LD50
>
2000
mg/
kg
III
870.1300
Acute
inhalation
­
rat
41616002
LC50
>
3.570
mg/
L
IV
870.2400
Acute
eye
irritation
­
rabbit
41782501
Slightly
irritating
IV
870.2500
Acute
dermal
irritation
­
rabbit
41616004
Not
an
irritant
IV
870.2600
Skin
sensitization
­
guinea
pig
41554001
Sensitizer
NA
Table
2.
Summary
of
Toxicological
Doses
and
Endpoints
for
Triadimefon
Exposure
Scenario
Dose
Used
in
Risk
Assessment,
UF
Special
FQPA
SF*
and
Level
of
Concern
for
Risk
Assessment
Study
and
Toxicological
Effects
Acute
Dietary
(
general
population)
NOAEL
=
3.4
mg/
kg/
day
UF
=
1000
Acute
RfD
=
0.0034
mg/
kg/
day
FQPA
SF
=
1X
aPAD
=
acute
RfD
FQPA
SF
aPAD
=
0.0034
mg/
kg/
day
Subchronic
neurotoxicity
study
in
rats.
LOAEL
=
54.6/
68.7
mg/
kg/
day
based
largely
on
hyperactivity.

Chronic
Dietary
(
all
populations)
NOAEL
=
3.4
mg/
kg/
day
UF
=
1000
Acute
RfD
=
0.0034
mg/
kg/
day
FQPA
SF
=
1X
PAD
=
chronic
RfD
FQPA
SF
cPAD
=
0.0034
mg/
kg/
day
Subchronic
neurotoxicity
study
in
rats.
LOAEL
=
54.6/
68.7
mg/
kg/
day
based
largely
on
hyperactivity.

Incidental
Oral
Short­
Term
(
1
­
30
days)
NOAEL
=
3.4
mg/
kg/
day
UF
=
1000
Residential
MOE
=
1000
Subchronic
neurotoxicity
study
in
rats.
LOAEL
=
54.6/
68.7
mg/
kg/
day
based
largely
on
hyperactivity.

Incidental
Oral
Intermediate­
Term
(
1
­
6
months)
NOAEL
=
3.4
mg/
kg/
day
UF
=
1000
Residential
MOE
=
1000
Subchronic
neurotoxicity
study
in
rats.
LOAEL
=
54.6/
68.7
mg/
kg/
day
based
largely
on
hyperactivity.

Dermal
Short­
Term
(
1
­
30
days)
Dermal
NOAEL
=
300
mg/
kg/
day
Residential
MOE
=
1000
Occupational
MOE
=
100
21
Day
Dermal
Toxicity
in
rabbits.
The
LOAEL=
1000
mg/
kg/
day
based
on
increased
reactivity
and
activity
in
the
females.

Dermal
Intermediate­
Term
(
1
­
6
months)
Dermal
NOAEL
=
300
mg/
kg/
day
Residential
MOE
=
1000
Occupational
MOE
=
100
21
Day
Dermal
Toxicity
in
rabbits.
The
LOAEL=
1000
mg/
kg/
day
based
on
increased
reactivity
and
activity
in
the
females.
Page
10
of
114
Table
2.
Summary
of
Toxicological
Doses
and
Endpoints
for
Triadimefon
Exposure
Scenario
Dose
Used
in
Risk
Assessment,
UF
Special
FQPA
SF*
and
Level
of
Concern
for
Risk
Assessment
Study
and
Toxicological
Effects
Dermal
Long­
Term
(>
6
months)
Not
Applicable
Not
Applicable
Quantitative
risk
assessment
is
not
required
since
no
long­
term
dermal
exposure
is
expected.

Inhalation
Short­
Term
(
1
­
30
days)
NOAEL
=
3.4
mg/
kg/
day
(
Inhalation
absorption
rate
=
100%)
Residential
MOE
=
1000
Occupational
MOE
=
100
Subchronic
neurotoxicity
study
in
rats.
LOAEL
=
54.6/
68.7
mg/
kg/
day
based
largely
on
hyperactivity.

Inhalation
Intermediate­
Term
(
1
­
6
months)
NOAEL
=
3.4
mg/
kg/
day
(
Inhalation
absorption
rate
=
100%)
Residential
MOE
=
1000
Occupational
MOE
=
100
Subchronic
neurotoxicity
study
in
rats.
LOAEL
=
54.6/
68.7
mg/
kg/
day
based
largely
on
hyperactivity.

Inhalation
Long­
Term
(>
6
months)
Not
Applicable
Not
Applicable
Quantitative
risk
assessment
is
not
required
since
no
long­
term
exposure
is
expected.

Cancer
(
oral,
dermal,
inhalation)
Classification:
Category
C
"
possible
human
carcinogen"
based
on
statistically
significant
increase
in
thyroid
adenomas
in
male
Wistar
rats
and
statistically
significant
increases
in
hepatocellular
adenomas
in
both
sexes
of
the
NMRI
mouse.

1.4
Incident
Reports
An
analysis
of
incidence
reports
will
be
included
in
a
separate
memo.

1.5
Summary
of
Physical
and
Chemical
Properties
of
Triadimefon
Summary
of
physical
and
chemical
properties
for
triadimefon
are
included
in
a
separate
memo.

1.6
Summary
of
Use
Patterns
and
Formulations
1.6.1
End­
Use
Products
Triadimefon
is
a
systemic
fungicide
used
in
the
United
States.
It
is
used
in
agricultural,
commercial,
and
residential
settings.
Triadimefon
is
formulated
as
an
emulsifiable
concentrate,
wettable
powder,
water
soluble
packet,
water­
dispersible
granule
(
dry
flowable),
and
granular.

1.6.2
Registered
Use
Categories
and
Sites
Triadimefon
is
registered
for
use
in
a
variety
of
occupational
and
residential
scenarios
(
see
Tables
3
and
4)
and
thus
both
occupational
and
residential
populations
could
be
potentially
exposed
while
performing
triadimefon
applications.
It
is
also
possible
for
occupational
and
residential
populations
to
be
exposed
to
triadimefon
during
postapplication
time
periods.
Page
11
of
114
Table
3:
Summary
of
Maximum
Application
Rates
for
Registered
Triadimefon
Commercial
and
Agricultural
Uses
Crop
Target
Formulationa
Maximum
Application
Rate
Application
Equipment
(
Area
Treated
or
Amount
Handled
Daily)

aerial,
airblast
Apples,
Pears
(
noncommercial
Foliage
WSP,
WP
0.25
lb
ai/
acre
or
0.00062
lb
ai/
gal
low
pressure
handwand,
handgun
(
WP
only)

Azaleas
(
for
control
of
pine
twisting
rust
only)
Foliage
WDG,
WP,
WSP
0.005
lb
ai/
gal
chemigation,
groundboom,
low
pressure
handwand,
high
pressure
handwand
Christmas
trees
Foliage
WP
0.25
lb
ai/
acre
aerial,
airblast
L
0.125
lb
ai/
acre
airblast,
aerial,
groundboom,
low
pressure
handwand
WP
0.00094
lb
ai/
gal
low
pressure
handwand,
handgun
Grapes
Foliage
WP,
WSP
0.188
lb
ai/
acre
aerial,
airblast,
groundboom
WP
0.00625
lb
ai/
gal
low
pressure
handwand
WSP
0.00625
lb
ai/
gal
Non­
commercial
greenhouse
ornamentals
(
flowering,
shrubs,
trees)
Foliage
L
0.00938
lb
ai/
gal
low
pressure
handwand,
high
pressure
handwand,
handgun
L
0.0023
lb
ai/
gal
low
pressure
handwand,
high
pressure
handwand,
handgun
Ornamentals
(
flowering,
shrubs,
trees)
Foliage
WDG,
WP
0.0025
lb
ai/
gal
chemigation,
groundboom,
low
pressure
handwand,
high
pressure
handwand
0.000075
lb
ai/
inch
of
trunk
RTU
micro­
injection
unit
Ornamentals
(
shade
trees
and
wood
shrubs)
Trunk
L
0.000026
lb
ai/
inch
of
trunk
Injection
Pine
(
including
Christmas
trees)
Foliage
L
0.0023
lb
ai/
gal
handgun,
low
pressure
handwand
Soil
(
preplant
RTU
­
Briquette
0.00019
lb
ai/
seedling
(
1
briquette
per
seedling)
mechanical
equipment
Pine
(
seedlings)

Foliage
WP,
WSP
0.5
lb
ai/
acre
aerial,
airblast,
groundboom,
handgun,
low
pressure
handwand
0.0000625
lb
ai/
gal
soak/
dip
treatment
Pine
Seed
(
nurseries)
Seeds
WP
0.13
lb
ai/
100
lb
seeds
commercial
treater
Pineapple
(
post­
harvest
or
per­
plant
crown)
Fruit
or
Crown
WP
0.0028
lb
ai/
gal
dip
or
spray
Raspberries
(
only
in
CA)
Foliage
WP,
WSP
0.125
lb
ai/
acre
airblast,
groundboom
Roses
Foliage
L
0.00029
lb
ai/
gal
handgun,
low
pressure
handwand,
high
pressure
handwand
Page
12
of
114
Table
3:
Summary
of
Maximum
Application
Rates
for
Registered
Triadimefon
Commercial
and
Agricultural
Uses
Crop
Target
Formulationa
Maximum
Application
Rate
Application
Equipment
(
Area
Treated
or
Amount
Handled
Daily)
5.2
lb
ai/
acreb
(
CA
only)
2.6
lb
ai/
acreb
(
except
CA)
G
1.3
lb
ai/
acrec
aerial,
tractor­
drawn
spreader,
push­
type
spreader
5.4
lb
ai/
acreb
(
CA
only)

2.7
lb
ai/
acreb
(
except
CA)

1.3
lb
ai/
acrec
aerial,
chemigation,
groundboom,
low
pressure
handwand,
handgun,
rightsof
way
sprayer
Turf
(
including
sod
farms,
golf
courses,
commercial
turf,
&
residential
lawns)
Foliage
WDG
(
DF),
WP,
WSP,
L
0.64
lb
ai/
acred
groundboom,
low
pressure
handwand,
handgun,
a
WSP
=
water
soluble
packet;
WP
=
wettable
powder;
L
=
Liquid
concentrate;
G
=
granular;
WDG
=
water
dispersible
granule;
DF
=
dry
flowable
b
Maximum
application
rate
identified
from
product
label
review.
c
Maximum
application
rate
at
residential
sites
identified
by
Bayer
CropScience,
Inc.
in
a
April
13,
2006
memorandum.
d
Maximum
application
rate
identified
for
liquids
from
product
label
review.
However,
the
rates
identified
by
Bayer
CropScience,
Inc.
in
a
April
13,
2006
memorandum
do
not
identify
specific
formulations,
therefore
all
rates
are
assessed
for
liquid
formulations.

Table
4:
Summary
of
Maximum
Application
Rates
for
Registered
Triadimefon
Residential
Uses
Crop
Target
Formulationa
Maximum
Application
Rate
Application
Equipment
(
Area
Treated
or
Amount
Handled
Daily)

Apples,
Pears
Foliage
WP
0.00062
lb
ai/
gal
Azalea
(
for
control
of
pine
twisting
rust
only)
Foliage
WP
0.005
lb
ai/
gal
Grapes
Foliage
WP
0.00094
lb
ai/
gal
WP
0.00625
lb
ai/
gal
Greenhouse
ornamentals
(
flowering,
shrubs,
trees)
Foliage
L
0.00938
lb
ai/
gal
WP
0.0025
lb
ai/
gal
Ornamentals
(
flowering,
shrubs,
trees)
Foliage
L
0.0023
lb
ai/
gal
low
pressure
handwand,
hose­
end
sprayer
Ornamentals
(
shade
trees
and
woody
shrubs)
Foliage
L
0.000026
lb
ai/
inch
of
trunk
injection
Pines
Foliage
L
0.0023
lb
ai/
gal
Roses
Foliage
L
0.00029
lb
ai/
gal
low
pressure
handwand,
hose­
end
sprayer
Page
13
of
114
Table
4:
Summary
of
Maximum
Application
Rates
for
Registered
Triadimefon
Residential
Uses
Crop
Target
Formulationa
Maximum
Application
Rate
Application
Equipment
(
Area
Treated
or
Amount
Handled
Daily)

5.2
lb
ai/
acreb
2.7
lb
ai/
acreb
G
1.3
lb
ai/
acrec
push­
type
spreader,
belly
grinder
Turf
Foliage
L
0.033
lb
ai/
gal
low
pressure
handwand,
hose­
end
sprayer
a
WP
=
wettable
powder;
L
=
Liquid
concentrate;
G
=
granular
b
Maximum
application
rate
identified
from
product
label
review.
c
Maximum
application
rate
for
residential
sites
identified
by
Bayer
CropScience
in
response
to
comments
document
received
4/
13/
06.

1.6.3
Application
Methods
Large­
scale
applications
of
triadimefon
are
applied
with
several
types
of
application
equipment,
including
aircraft,
groundboom
sprayers,
airblast
sprayers,
tractor­
drawn
spreaders,
rights­
of­
way
sprayers,
and
chemigation.
Applications
to
smaller
areas
may
be
made
with
handheld
equipment,
including
low­
pressure
handwand
sprayers,
high­
pressure
handwand
sprayers,
handgun
sprayers,
push­
type
spreaders,
and
bellygrinders.
Triadimefon
is
also
applied
as
a
post­
harvest
spray
or
dip,
as
a
tree­
injection,
and
as
a
ready­
to­
use
briquette.

In
addition,
triadimefon
is
applied
to
seeds
during
both
on­
nursery
and
commercial
seed
treatment.
The
following
descriptions
of
seed
treatment
and
planting
methods
and
equipment
are
based
primarily
on
information
provided
in
HED's
seed
treatment
SOP
(
SOP
14),
which
was
developed
in
consultation
with
industry
specialists.

Commercial
Seed
Treatment:
Commercial
seed
treaters
are
designed
to
apply
accurately
measured
quantities
of
pesticides
to
a
given
weight
of
seed.
There
are
two
primary
methods
for
treating
seeds:
the
batch
system
and
the
continuous
flow
system.
The
batch
system
is
less
automated
and
generates
lower
production
volume
than
the
continuous
flow
system.
Seed
treatment
in
commercial
facilities
occurs
primarily
via
the
highly
automated
continuous
flow
system.
Treated
seed
is
bagged
by
a
machine
which
picks
up
a
bag,
opens
it,
and
lets
it
fill
to
a
predetermined
weight.
The
bagger
then
folds
the
top
of
the
bag,
and
attaches
the
seed
grade
certificates
and
treatment
tags.
The
sewer
then
sews
the
bag
shut
using
an
automated
sewing
machine.
The
bag
is
then
moved
by
a
conveyer
belt
to
a
pallet
area
where
it
is
stacked
for
shipping.
Seed
treatment
workers
may
rotate
duties
to
other
areas.
In
the
smaller,
less
automated
facilities
in
particular,
one
worker
will
often
have
multiple
duties
within
the
plant.

On­
Nursery
Seed
Treatment
&
Planting
of
Treated
Seed:
There
are
various
equipment
used
for
on­
nursery
seed
treatment,
such
as
drum
mixers,
homemade
devices
using
augers,
cement
mixers,
hand
cranked
revolving
drums,
and
gravity
feed
systems.
The
more
sophisticated
on­
nursery
treaters
are
essentially
miniature
versions
of
the
commercial
treaters.
Simpler
units
consist
of
reusable
chemical
containers,
a
power
source
(
vehicle
battery),
valve
Page
14
of
114
and
pump
or
compressed
air,
and
tubing
spray
nozzles.
These
units
are
mounted
directly
on
a
truck
box
or
wagon
to
dispense
seed
treatment
directly
into
an
auger
conveyance
system.
Seed
may
be
treated
as
it
is
augered
from
the
grower's
truck
to
the
storage
bin
or
seeder
or
from
the
storage
bin
to
the
farmer's
truck
or
seeder.
This
type
of
enclosed
on­
nursery
treatment
system
is
available
only
for
liquid
formulations.
Analogous
automated
systems
are
not
available
for
dust
formulations
based
on
information
provided
by
the
registrant.

On­
nursery
seed
treatments
may
also
be
made
by
hopper
box
or
planter
box.
These
systems
treat
the
seed
at
planting.

The
treated
seed
can
be
planted
with
a
wide
range
of
equipment.
Common
equipment
types
include:
specialized
drills
with
a
box
for
small
seeds
and
disk
openers
with
depth
bands
to
place
the
seeds
at
the
appropriate
depth
followed
by
packer
wheels
to
firm
soil
over
and
around
seeds;
double
corrugated
roller
seeders,
which
drop
the
seed
between
the
rollers
followed
by
a
second
roller,
which
covers
the
seed
and
firms
the
soil;
and
booms,
delivery
tubes,
and
air
pressure
that
blow
seed
onto
the
soil
at
properly
spaced
intervals
followed
by
light
packing,
dragging
a
chain
or
harrowing
to
cover
the
planted
seed.
Seeding
rate
is
determined
by
factors
such
as
machine
wear,
seed
size
and
shape,
and
crop
variety.

2.0
Occupational
Exposures
and
Risks
There
is
a
potential
for
exposure
to
triadimefon
in
occupational
scenarios
from
handling
triadimefon
products
during
the
application
process
(
i.
e.,
mixer/
loaders,
applicators,
flaggers,
and
mixer/
loader/
applicators)
and
a
potential
for
postapplication
worker
exposure
from
entering
into
areas
previously
treated
with
triadimefon.
In
addition,
there
is
potential
exposure
to
workers
who
treat
seed
with
triadimefon
in
both
commercial
and
on­
nursery
settings
and
to
persons
who
plant
treated
seed.
As
a
result,
risk
assessments
have
been
completed
for
occupational
handler
scenarios
as
well
as
occupational
postapplication
scenarios.

2.1
Occupational
Handler
Exposures
and
Risks
HED
uses
the
term
"
handlers"
to
describe
those
individuals
who
are
involved
in
the
pesticide
application
process.
HED
believes
that
there
are
distinct
job
functions
or
tasks
related
to
applications
and
that
exposures
can
vary
depending
on
the
specifics
of
each
task.
Job
requirements
(
e.
g.,
amount
of
chemical
to
be
used
in
an
application),
the
kinds
of
equipment
used,
the
target
being
treated,
and
the
level
of
protection
used
by
a
handler
can
cause
exposure
levels
to
differ
in
a
manner
specific
to
each
application
event.

HED
uses
exposure
scenarios
to
describe
the
various
types
of
handler
exposures
that
may
occur
for
a
specific
active
ingredient.
The
use
of
scenarios
as
a
basis
for
exposure
assessment
is
very
common
as
described
in
the
U.
S.
EPA
Guidelines
for
Exposure
Assessment
(
U.
S.
EPA;
Federal
Register
Volume
57,
Number
104;
May
29,
1992).
Information
from
the
current
labels,
use
and
usage
information,
toxicology
data,
and
exposure
data
were
all
key
components
in
the
development
of
the
exposure
scenarios.
HED
has
developed
a
series
of
general
descriptions
for
tasks
that
are
associated
with
pesticide
applications.
Tasks
associated
with
occupational
pesticide
handlers
are
categorized
using
one
of
the
following
terms:
Page
15
of
114
 
Mixers
and/
or
Loaders:
These
individuals
perform
tasks
in
preparation
for
an
application.
For
example,
prior
to
application,
mixer/
loaders
would
mix
the
triadimefon
and
load
it
into
the
holding
tank
of
the
airplane
or
groundboom.

 
Applicators:
These
individuals
operate
application
equipment
during
the
release
of
a
pesticide
product
into
the
environment.
These
individuals
can
make
applications
using
equipment
such
as
airplanes
or
groundboom.

 
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
triadimefon
into
the
application
equipment
and
then
also
apply
it.

 
Flaggers:
These
individuals
guide
aerial
applicators
during
the
release
of
a
pesticide
product
onto
an
intended
target.

 
On­
Nursery
Loader/
Applicator:
The
possible
points
of
operator
exposure
for
an
onnursery
treatment
are;
transport
of
pesticide
in
mobile
containers,
moving
pesticide
from
storage
in
to
seed
treatment
equipment,
introduction
of
pesticide
into
seed
treatment
equipment,
and
equipment
cleaning
and
maintenance.
On­
nursery
seed
treatment
with
liquid
formulations
is
generally
done
with
more
automated
equipment,
essentially
miniature
versions
of
commercial
treaters.
Seed
may
be
treated
as
it
is
augured
from
the
grower's
truck
to
the
storage
bin
(
at
the
farmstead),
or
from
the
truck
to
the
seeder
(
field)
or
from
the
grower's
storage
bin
into
either
a
truck
or
seeder.

 
On­
Nursery
Planting
of
Treated
Seed:
Planting
exposures
occur
during
both
the
loading
of
hoppers
and
driving
the
equipment.

 
Commercial
Mixer/
Loader/
Applicator
for
Seed
Treatments:
This
scenario
involves
loading/
applying
of
all
formulations
in
a
commercial
operation.

 
Commercial
Bagger
for
Seed
Treatments:
Seed
is
bagged
by
a
machine
which
picks
up
a
bag,
opens
it,
slips
it
over
a
spout
and
lets
it
fill
to
a
predetermined
weight.
The
bagger
then
folds
the
top
of
the
bag,
attaches
the
seed
grade
certificates
and
treatment
tags.

 
Commercial
Sewer
for
Seed
Treatments:
After
bagging
the
treated
seed
the
sewer
shuts
the
bag
using
an
automatic
sewing
machine.
The
bag
is
then
moved
by
a
conveyer
belt
to
a
pallet
area
where
it
is
stacked
for
shipping.

 
Multiple
Commercial
Activities
for
Seed
Treatments:
The
SOP
contains
a
scenario
labeled
"
Multiple
Activities"
to
address
the
potential
for
multiple
types
of
exposure
in
small
commercial
operations.

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
Page
16
of
114
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
triadimefon
exposures
may
occur
over
a
single
day
or
up
to
weeks
at
a
time
for
many
use­
patterns
and
that
intermittent
exposure
over
several
weeks
also
may
occur.
Some
applicators
may
apply
triadimefon
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
triadimefon.

Other
parameters
are
also
defined
from
use
and
usage
data
such
as
application
rates
and
application
frequency.
HED
always
completes
noncancer
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
and
Assumptions
for
Handler
Exposure
Scenarios
2.1.1.1
Assumptions
for
Handler
Exposure
Scenarios
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:

°
Occupational
handler
exposure
estimates
were
based
on
surrogate
data
from:
(
1)
the
Pesticide
Handlers
Exposure
Database
(
PHED),
(
2)
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF),
and
(
3)
HED's
SOPs
for
Seed
Treatment.

°
The
toxicological
endpoint
of
concern
for
dermal
risks
is
from
a
dermal
study;
with
the
effects
seen
in
females,
therefore,
the
average
body
weight
of
an
adult
female
handler
(
i.
e.,
60
kg)
is
used
to
complete
the
dermal
risk
assessment.
The
toxicological
endpoint
of
concern
for
inhalation
risks
is
from
a
neurotoxicity
study;
with
the
effects
seen
in
males
and
females,
therefore,
the
average
body
weight
of
an
adult
handler
(
i.
e.,
70
kg)
is
used
to
complete
the
inhalation
risk
assessment.

°
Generic
protection
factors
(
PFs)
were
used
to
calculate
exposures
when
data
were
not
Page
17
of
114
available.
For
example,
an
80
percent
protection
factor
was
assumed
for
the
use
of
a
respirator
equipped
with
a
quarter­
face
dust/
mist
filter.

°
On­
nursery
treaters
and
planters
are
expected
to
have
short­
term
exposure
duration
(
less
than
30
days)
for
all
seed
crops.

°
Personal
protective
equipment
for
on­
nursery
and
commercial
mixer/
loader/
applicators
and
planter
includes
a
single
layer
and
gloves.
Personal
protective
equipment
for
commercial
baggers
and
sewers
includes
baseline
attire
only
­
no
gloves.
Personal
protective
equipment
for
performing
multiple
activities
in
a
commercial
operation
includes
a
single
layer
of
clothing
and
gloves
°
For
seed
treatment,
it
was
assumed
that
14,170
pine
seeds
are
planted
per
acre
and
that
enough
seeds
for
10,000
acres
are
treated
per
day
using
commercial
seed
treatment
and
enough
seeds
for
80
acres
are
treated
per
day
using
on­
nursery
planter
box
or
hopper
box
seed
treatment.
The
weight
for
ponderosa
seeds
was
estimated
to
be
11,350
seeds
per
pound
(
Bernard
Schneider,
HED,
personal
communication).

°
For
on­
nursery
seed
treatment
using
a
cement
mixer,
it
was
assumed
that
500
pounds
of
seed
are
treated
per
day
(
Dr.
Scott
Enebak,
Associate
Professor/
Forest
Health
Dynamics
Laboratory,
Director
­
Southern
Forest
Nursery
Management
Cooperative,
Auburn
University,
School
Forestry
&
Wildlife
Sciences
in
a
memorandum
from
Bayer
CropSciences
dated
April
13,
2006).

°
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.

°
For
noncancer
assessments,
HED
assumes
the
maximum
application
rates
allowed
by
labels
in
its
risk
assessments
(
see
Tables
3
and
4).

°
The
average
occupational
workday
is
assumed
to
be
8
hours.

°
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,
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
#
9.1:
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,
which
was
revised
on
September
25,
2001.
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
(
see
tables
1
and
2).

There
are
data
gaps
that
have
been
identified
for
some
triadimefon
applications.
Each
is
identified
in
the
calculation
tables
and
is
also
noted
in
the
summary
of
risk
calculations.
Page
18
of
114
2.1.1.2
Exposure
Data
for
Handler
Exposure
Scenarios
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).

Pesticide
Handler
Exposure
Database
(
PHED)
Version
1.1
(
August
1998):
PHED
was
designed
by
a
task
force
of
representatives
from
the
U.
S.
EPA,
Health
Canada,
the
California
Department
of
Pesticide
regulation,
and
member
companies
of
the
American
Crop
Protection
Association.
PHED
is
a
software
system
consisting
of
two
parts
 
a
database
of
measured
exposures
for
workers
involved
in
the
handling
of
pesticides
under
actual
field
conditions
and
a
set
of
computer
algorithms
used
to
subset
and
statistically
summarize
the
selected
data.
Currently,
the
database
contains
values
for
over
1,700
monitored
individuals
(
i.
e.,
replicates).

Users
select
criteria
to
subset
the
PHED
database
to
reflect
the
exposure
scenario
being
evaluated.
The
subsetting
algorithms
in
PHED
are
based
on
the
central
assumption
that
the
magnitude
of
handler
exposures
to
pesticides
are
primarily
a
function
of
activity
(
e.
g.,
mixing/
loading,
applying),
formulation
type
(
e.
g.,
liquids,
granulars),
application
method
(
e.
g.,
aerial,
groundboom),
and
clothing
scenarios
(
e.
g.,
gloves,
double
layer
clothing).

Once
the
data
for
a
given
exposure
scenario
have
been
selected,
the
data
are
normalized
(
i.
e.,
divided
by)
by
the
amount
of
pesticide
handled
resulting
in
standard
unit
exposures
(
milligrams
of
exposure
per
pound
of
active
ingredient
handled).
Following
normalization,
the
data
are
statistically
summarized.
The
distribution
of
exposure
for
each
body
part
(
e.
g.,
chest,
upper
arm)
is
categorized
as
normal,
lognormal,
or
"
other"
(
i.
e.,
neither
normal
nor
lognormal).
A
central
tendency
value
is
then
selected
from
the
distribution
of
the
exposure
for
each
body
part.
These
values
are
the
arithmetic
mean
for
normal
distributions,
the
geometric
mean
for
lognormal
distributions,
and
the
median
for
all
"
other"
distributions.
Once
selected,
the
central
tendency
values
for
each
body
part
are
composited
into
a
"
best
fit"
exposure
value
representing
the
entire
body.

The
unit
exposures
calculated
by
PHED
generally
range
from
the
geometric
mean
to
the
median
of
the
selected
data
set.
To
add
consistency
and
quality
control
to
the
values
produced
from
this
system,
the
PHED
Task
Force
has
evaluated
all
data
within
the
system
and
has
developed
a
set
of
grading
criteria
to
characterize
the
quality
of
the
original
study
data.
The
assessment
of
data
quality
is
based
on
the
number
of
observations
and
the
available
quality
control
data.
While
data
from
PHED
provide
the
best
available
information
on
handler
exposures,
it
should
be
noted
that
some
aspects
of
the
included
studies
(
e.
g.,
duration,
acres
treated,
pounds
of
active
ingredient
handled)
may
not
accurately
represent
labeled
uses
in
all
Page
19
of
114
cases.
HED
has
developed
a
series
of
tables
of
standard
unit
exposure
for
many
occupational
scenarios
that
can
be
utilized
to
ensure
consistency
in
exposure
assessments.
Unit
exposures
are
used
which
represent
different
levels
of
personal
protection
as
described
above.
Protection
factors
were
used
to
calculate
unit
exposures
for
varying
levels
of
personal
protection
if
data
were
not
available.

ORETF
Handler
Studies
(
MRID
449722­
01):
A
report
was
submitted
by
the
ORETF
(
Outdoor
Residential
Exposure
Task
Force)
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
(
MRID
449722­
01,
ORETF
Study
OMA002)
is
summarized
below
as
is
the
study
that
monitored
homeowner
exposures
while
using
a
hose­
end
sprayer
(
MRID
449722­
01,
ORETF
Study
OMA004).

LCO
Handgun
Sprayer:
A
mixer/
loader/
applicator
study
was
performed
by
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF)
using
Dacthal
as
a
surrogate
compound
to
determine
"
generic"
exposures
to
individuals
applying
a
pesticide
to
turf
with
a
low­
pressure
"
nozzle
gun"
or
"
handgun"
sprayer.
Dermal
and
inhalation
exposures
were
estimated
using
whole­
body
passive
dosimeters
and
breathing­
zone
air
samples
on
OVS
tubes.
Inhalation
exposure
was
calculated
using
an
assumed
respiratory
rate
of
17
liters
per
minute
for
light
work
(
NAFTA,
1999),
the
actual
sampling
time
for
each
individual,
and
the
pump
flow
rate.
All
results
were
normalized
for
pounds
active
ingredient
handled.
A
total
of
90
replicates
were
monitored
using
17
different
subjects.
Four
different
formulations
of
dacthal
[
75%
wettable
powder
(
packaged
in
4
and
24
pound
bags),
75%
wettable
powder
in
water
soluble
bags
(
3
pound
bag),
75%
water
dispersable
granules
(
2
pound
bag)
and
55%
liquid
flowable
(
2.5
gallon
container)]
were
applied
by
five
different
LCOs
to
actual
residential
lawns
at
each
site
in
three
different
locations
(
Ohio,
Maryland,
and
Georgia)
for
a
total
of
fifteen
replicates
per
formulation.
An
additional
ten
replicates
at
each
site
were
monitored
while
they
performed
spray
application
using
only
the
75
percent
wettable
powder
formulation.
A
target
application
rate
of
2
pounds
active
ingredient
was
used
for
all
replicates
(
actual
rate
achieved
was
about
2.2
pounds
active
ingredient
per
acre).
Each
replicate
treated
a
varying
number
of
actual
client
lawns
to
attain
a
representative
target
of
2.5
acres
(
1
hectare)
of
turf.
The
exposure
periods
averaged
five
hours
twenty­
one
minutes,
five
hours
thirty­
nine
minutes,
and
six
hours
twenty­
four
minutes,
in
Ohio,
Maryland
and
Georgia,
respectively.
Average
time
spent
spraying
at
all
sites
was
about
two
hours.
All
mixing,
loading,
application,
adjusting,
calibrating,
and
spill
clean
up
procedures
were
monitored,
except
for
typical
end­
of­
day
clean­
up
activities,
e.
g.
rinsing
of
spray
tank,
etc.
Dermal
exposure
was
measured
using
inner
and
outer
whole
body
dosimeters,
hand
washes,
face/
neck
washes,
and
personal
air
monitoring
devices.
All
test
subjects
wore
one­
piece,
100
percent
cotton
inner
dosimeters
beneath
100
percent
cotton
long­
sleeved
shirt
and
long
pants,
rubber
boots
and
nitrile
gloves.
Gloves
are
typically
worn
by
most
LCOs,
and
required
by
many
pesticide
labels
for
mixing
and
loading.
Overall,
residues
were
highest
on
the
upper
and
lower
leg
portions
of
the
dosimeters.
In
general,
concurrent
lab
spikes
produced
mean
recoveries
in
the
range
of
78­
120
percent,
with
the
exception
of
OVS
sorbent
tube
sections
which
produced
mean
recoveries
as
low
as
65.8
percent.
Adjustment
for
recoveries
from
field
fortifications
were
performed
on
each
dosimeter
section
or
sample
matrix
for
each
study
participant,
using
the
mean
recovery
for
the
Page
20
of
114
closest
field
spike
level
for
each
matrix
and
correcting
the
value
to
100
percent.
The
unit
exposures
are
presented
below.
[
Note
the
data
were
found
to
be
lognormally
distributed.
As
a
result,
all
exposures
are
geometric
means.]

Table
5:
Unit
Exposure
Values
Obtained
for
LCO
Liquid
Applications
with
a
Low
Pressure
Handgun
from
ORETF
Handgun
Studies
(
MRID
449722­
01)

Total
Dermal
Unit
Exposure1
(
mg/
lb
ai)

Application
Method4
Single
Layer,
No
Gloves
Single
Layer,
Gloves
Double
Layer,
Gloves
3
Inhalation
Unit
Exposure1,2
(
µ
g/
lb
ai)

LCO
Handgun
Spray
Mixer/
Loader/
Applicator
Liquid
Flowable
No
Data
0.45
0.245
1.5
LCO
Handgun
Spray
Mixer/
Loader/
Applicator
Water
Dispersable
Granule
No
Data
0.68
0.37
22
LCO
Handgun
Spray
Mixer/
Loader/
Applicator
Wettable
Powder
in
Water
Soluble
Bags
No
Data
0.68
0.37
7.2
LCO
Handgun
Spray
Mixer/
Loader/
Applicator
Wettable
Powder
No
Data
0.80
0.43
64
LCO
Handgun
Spray
Applicator
Only
Wettable
Powder
No
Data
0.74
0.40
1.0
1
Unit
exposure
values
reported
are
geometric
means.
2
Air
concentration
(
mg/
m3/
lb
ai)
calculated
using
NAFTA
`
99
standard
breathing
rate
of
17
lpm
(
1
m3/
hr).
3
Exposure
calculated
using
OPP/
HED
50%
protection
factor
(
PF)
for
cotton
coveralls
on
torso,
arms,
and
legs.
4
All
commercial
handlers
wore
long
pants,
long­
sleeved
shirt,
nitrile
gloves
and
shoes.

Homeowner
Granular
Applications
with
a
Rotary
(
Push­
type)
Spreader
(
MRID
449722­
01):
A
mixer/
loader/
applicator
study
was
performed
by
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF)
using
Dacthal
(
active
ingredient
DCPA,
dimethyl
tetrachloroterephthalate)
as
a
surrogate
compound
to
determine
"
generic"
exposures
of
individuals
applying
a
granular
pesticide
formulation
to
residential
lawns.
A
total
of
30
volunteers
were
monitored
using
passive
dosimetry
(
inner
and
outer
whole
body
dosimeters,
hand
washes,
face/
neck
wipes,
and
personal
inhalation
monitors).
Each
volunteer
carried,
loaded,
and
applied
two
25­
lb
bags
of
fertilizer
(
0.89%
active
ingredient)
with
a
rotary
type
spreader
to
a
lawn
covering
10,000
ft2.
The
target
application
rate
was
2
lb
ai/
acre
(
actual
rate
achieved
was
about
1.9
lbs
ai/
acre).
The
average
application
time
was
22
minutes,
including
loading
the
rotary
push
spreader
and
disposing
of
the
empty
bags.
Each
replicate
handled
approximately
0.45
lbs
ai.
Dermal
exposure
was
measured
using
inner
and
outer
whole
body
dosimeters,
hand
washes,
face/
neck
washes,
and
personal
air
monitoring
devices
with
OVS
tubes.

Table
6:
Unit
Exposure
Values
for
Homeowner
Granular
Applications
with
a
Rotary
(
Push­
type)
Spreader
Obtained
From
ORETF
Study
(
MRID
449722­
01)

Unit
Exposures1
Dermal
(
mg
ai/
lb
handled)
Scenario
Monitored
Short
Pants,
Short
Sleeves
Long
Pants,
Short
Sleeves
Long
Pants,
Long
Sleeves
Inhalation
(
µ
g
ai/
lb
handled)

Homeowner
Granular
Applications
with
a
Push­
type
Spreader
0.67
0.09
0.07
0.88
1
All
unit
exposure
values
are
geometric
means.
Page
21
of
114
Seed
Treatment
and
Planting:
Exposure
data
used
for
the
triadimefon
seed
treatment
assessment
are
taken
primarily
from
HED's
recently
developed
seed
treatment
standard
operating
procedure
(
SOPs
for
Seed
Treatment,
6/
1/
03)
and
also
are
based
on
professional
judgement.
The
seed
treatment
SOP
contains
representative
scenarios
for
worker
exposure
associated
with
seed
treatment
facilities
and
planting
treated
seed.
The
data
contained
in
the
SOP
are
mostly
generated
by
industry
sources.
Exposure
estimates
are
from
actual
seed
treatment
studies
and
are
based
on
exposure
factors
associated
with
occupational
handler
scenarios
(
i.
e.,
commercial
seed
treatment,
on­
nursery
seed
treatment,
planting
of
treated
seed).
Eight
seed
treatment
studies
were
used
in
developing
the
SOP.
Given
the
high
level
of
variance
in
the
data,
multiple
statistical
analyses
were
undertaken
to
help
ensure
derivation
of
a
statistically
sound
exposure
value
for
the
different
scenarios
evaluated.
For
all
selected
seed
treatment
studies,
replicates
were
combined
into
sets
of
equivalent
job
functions.
This
process
resulted
in
four
categories
of
commercial
seed
treatment
activities
(
loader/
applicator,
sewer,
bagger,
and
multiple
activities),
and
two
categories
for
on­
nursery
activities
(
treater
and
planter).

On­
Nursery
Loader/
Applicator:
Only
one
study
was
available
to
address
exposure
in
an
on­
nursery
facility.
In
that
study,
the
seed
treatment
formulation
was
dust.
Exposure
estimates
for
on­
nursery
treatment
with
dust
formulations
are
based
on
1
exposure
study
(
MRID
#
44031611).
In
this
study
four
workers
(
twelve
replicates)
mixed
and
applied
dust
formulations
to
winter
wheat
in
grain
drills
at
an
application
rate
of
2
oz.
per
120
lbs.
of
seed.
Each
replicate
lasted
between
19
and
33
minutes
and
each
worker
handled
22.5
ounces
of
active
ingredient
per
work
period.
Workers
loaded
seed
drill
hoppers
with
wheat
seed
and
a
lindane/
maneb
dust
formulation.
Dermal
exposures
were
measured
with
patches
and
handwash.
Inhalation
exposures
were
measured
with
glass
fiber
filters.

On­
Nursery
Planting
of
Treated
Seed:
Exposure
estimates
for
loading
and
planting
of
treated
seed
are
based
on
2
exposure
studies
(
MRID
#
42251901,
45654503).
In
one
study,
workers
loaded
and
drilled
seed
treated
with
Baytan
at
13
different
sites
in
the
UK.
The
seed
was
loaded
into
the
drill
hoppers
from
0.5
or
1
ton
super
sacks
or
50
kg
bags.
The
amount
of
seed
handled
ranged
from
1100
to
12,100
lbs
and
the
amount
of
ai
handled
ranged
from
0.35
to
4.72
lbs.
The
loading
time
ranged
from
19
to
83
minutes,
while
the
planting
time
ranged
from
155
to
487
minutes.
The
seed
planting
rate
per
acre
was
not
given.
The
same
worker
performed
both
the
loading
and
planting.
Dermal
exposure
was
measured
with
inner
and
outer
whole
body
dosimeters
which
included
a
cap,
a
jacket
and
trousers
over
a
long
sleeve
T­
shirt
and
long
johns
and
two
sets
of
cotton
gloves.
The
gloves
were
changed
at
the
end
of
loading.
Inhalation
exposures
were
measured
with
37
mm
glass
fiber
filters
and
the
filters
were
changed
after
loading.
The
dermal
results
were
adjusted
by
a
clothing
protection
factor
to
account
for
the
fact
that
5%
of
the
outer
residues
was
found
on
the
inner
dosimeters.

In
the
second
study
workers
loaded
and
drilled
canola
seed
treated
with
Oftanol,
which
forms
a
hard
shell
coating.
The
13
replicates
for
this
study
were
located
at
one
site
in
Manitoba
using
four
different
planting
rigs.
Four
workers
participated
in
the
study
and
the
replicates
averaged
3.2
hours
in
duration.
The
seed
was
loaded
into
the
drill
hoppers
from
25
kg
bags.
The
amount
of
seed
handled
per
replicate
averaged
360
pounds
and
the
amount
of
ai
handled
averaged
4.33
lbs.
The
seed
was
planted
at
a
rate
of
6
to
8
pounds
per
acre.
The
same
worker
performed
both
the
loading
and
planting.
Dermal
exposure
was
measured
with
patches
located
Page
22
of
114
both
inside
and
outside
the
worker's
coverall.
Hand
exposures
were
measured
by
hand
rinse.
Inhalation
exposures
were
measured
with
37
mm
quartz
microfiber
filters.

For
assessing
exposures
to
on­
nursery
seed
treatments
using
a
cement
mixer
as
application
equipment,
no
data
are
available.
Unit
exposure
values
from
PHED
open
mixing/
loading
using
wettable
powders
using
dry
flowables
were
used
as
reasonable
surrogates.
No
data
are
available
for
handlers
who
remove
the
treated
seed,
spread
it
on
drying
racks,
rake
it,
and
bag
it.
HED
recommends
that
such
handlers
wear
baseline
attire
plus
chemical­
resistant
gloves
and
a
chemical­
resistant
apron.

Commercial
Loader/
Applicator:
Exposure
estimates
are
based
on
a
subset
of
3
exposure
studies
(
MRID
Nos.
43080049,
42251902,
44904526).
The
loader/
applicator
activities
in
these
3
exposure
studies
encompass
a
wide
range
of
seed
treaters,
amounts
of
seed
and
amounts
of
pesticides
handled
for
seed
treatment
scenarios.
The
three
studies
monitored
an
open
loading/
applying
activity
for
various
seed
treatment
facilities.
There
is
an
average
of
9
replicates
per
study
(
ranging
from
1
to
20
replicates
per
study).
Two
of
the
three
studies
monitored
dermal
exposures
with
patch
dosimetry,
hand
rinses,
and
face
wipes.
The
methodology
in
the
third
study
was
whole
body
dosimetry,
hand
rinses
and
face
wipes.

Commercial
Bagger:
Exposure
estimates
for
bagging
activities
for
all
formulations
are
based
on
data
from
3
exposure
studies
(
MRID
Nos.
43080049,
42251902,
and
44904526).
The
studies
monitored
bagging
treated
seed
in
various
seed
treatment
facilities
and
encompassed
a
wide
range
of
bagging
equipment,
and
amount
of
seed
and
pesticides
handled.
The
number
of
replicates
ranged
from
1
to
20
per
study.
Two
of
the
studies
monitored
dermal
exposures
with
whole
body
dosimeters,
and
face,
neck
and
hand
rinses.
The
third
used
dermal
patches
and
hand
rinses
to
monitor
exposure.

Commercial
Sewer:
Exposure
estimates
for
sewing
activities
for
all
formulations
are
based
on
data
from
2
exposure
studies
(
MRID
#
430800­
49,
and449045­
26).
The
two
studies
monitored
sewing
various
bags
of
treated
seed
in
a
number
of
seed
treatment
facilities.
The
number
of
replicates
ranges
from
1
to
20
per
study.
Both
of
the
studies
monitored
dermal
exposures
with
whole
body
dosimeters,
and
face,
neck
and
hand
rinses.

Multiple
Commercial
Activities:
Exposure
estimates
for
multiple
activities
for
all
formulation
are
based
on
data
from
4
exposure
studies
(
MRID
#
s,
454427­
01,
422519­
02,
449045­
26
and
447315­
01).
These
studies
encompass
a
variety
of
seed
treatment
activity
and
a
wide
range
of
amount
of
seed
pesticides
handled.
The
four
studies
in
this
scenario
monitored
multiple
activities
for
various
seed
treatment
facilities.
The
number
of
replicates
ranges
from
3
to
45
per
study.
Three
of
the
five
studies
monitored
dermal
exposures
with
whole
body
dosimeter,
face
and
neck
and
hand
rinses.
The
methodology
in
the
other
studies
was
dermal
patches
and
hand
rinses.
Page
23
of
114
Triadimefon
Handler
Exposure
Scenarios
It
has
been
determined
that
exposure
to
pesticide
handlers
is
likely
during
the
occupational
use
of
triadimefon
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
triadimefon
applications.
The
quantitative
exposure/
risk
assessment
developed
for
occupational
handlers
is
based
on
the
following
scenarios.

Twenty­
seven
exposure
scenarios
were
identified
as
representative
of
triadimefon
nonseed
treatment:
Mixer/
Loaders:
(
1a)
Liquid
Formulations
to
support
Aerial
Applications
(
PHED)
(
1b)
Liquid
Formulations
to
support
Groundboom
Applications
(
PHED)
(
1c)
Liquid
Formulations
to
support
LCO
Handgun
Applications
(
PHED)
(
1d)
Liquid
Formulations
to
support
Airblast
Applications
(
PHED)
(
2a)
Wettable
Powders
to
support
Aerial
Applications
(
PHED)
(
2b)
Wettable
Powders
to
support
Chemigation
Applications
(
PHED)
(
2c)
Wettable
Powders
to
support
Groundboom
Applications
(
PHED)
(
2d)
Wettable
Powders
to
support
LCO
Handgun
Applications
(
PHED)
(
2e)
Wettable
Powders
to
support
Airblast
Applications
(
PHED)
(
2f)
Wettable
Powders
to
support
Rights­
of­
Way
Applications
(
PHED)
(
3a)
Water
Dispersible
Granules
to
support
Aerial
Applications
(
PHED)
(
3b)
Water
Dispersible
Granules
to
support
Chemigation
Applications
(
PHED)
(
3c)
Water
Dispersible
Granules
to
support
Groundboom
Applications
(
PHED)
(
3d)
Water
Dispersible
Granules
to
support
LCO
Handgun
Applications
(
PHED)
(
4a)
Loading
Granulars
to
support
Aerial
Applications
(
PHED)
(
4b)
Loading
Granulars
to
support
Tractor
Drawn
Spreader
Applications
(
PHED)

Applicators:
(
5)
Aerial
Spray
Applications
(
PHED)
(
6)
Aerial
Granular
Applications
(
PHED)
(
7)
Groundboom
Spray
Applications
(
PHED)
(
8)
Airblast
Spray
Applications
(
PHED)
(
9)
Handgun
Spray
Applications
(
PHED)
(
10)
Rights
of
Way
Spray
Applications
(
PHED)
(
11)
Tractor­
Drawn
Spreader
Granule
Applications
(
PHED)

Flaggers:
(
12)
Flagging
for
Aerial
Spray
Applications
(
PHED)
(
13)
Flagging
for
Aerial
Granular
Applications
(
PHED)

Mixer/
Loader/
Applicators:
(
14)
Liquid
Formulations:
Low
Pressure
Handwand
Sprayer
(
ORETF)
(
15)
Wettable
Powder
Formulations:
Low
Pressure
Handwand
Sprayer
(
PHED)
(
16)
Water
Dispersible
Granules
with
Low
Pressure
Handwand
(
using
ORETF
data
for
Page
24
of
114
liquid
formulations
as
a
surrogate)
(
17)
Liquid
Formulations:
Handgun
Sprayer
(
ORETF)
(
18)
Wettable
Powders
with
a
Handgun
Sprayer
(
ORETF)
(
19)
Water
Soluble
Bags
with
Handgun
Sprayer
(
ORETF)
(
20)
Dry
Flowables
Concentrates
with
a
Handgun
Sprayer
(
ORETF)
(
21)
Liquid
Formulations:
High
Pressure
Sprayer
(
PHED)
(
22)
Water
Dispersible
Granules:
High
Pressure
Handwand
(
PHED:
liquid
concentrates)
(
23)
Wettable
Powders:
High
Pressure
Handwand
(
PHED:
liquid
concentrates)
(
24)
Liquids
with
an
Tree
Injector
(
no
data)
(
25)
RTU:
Briquette
(
no
data)
(
26)
Liquid
Formulations:
Dip
(
no
data)
(
27)
Loading/
Applying
Granulars
via
Push
Type
Spreader
(
ORETF)

Nine
major
exposure
scenarios
were
identified
as
representative
of
triadimefon
pine
seed
treatment:
(
S­
1)
on­
nursery
loading/
applying
with
hopper
or
planter
box
seed
treatment,
(
S­
2)
on­
nursery
loading/
planting
previously
treated
seeds,
(
S­
3)
on­
nursery
loading/
applying
wettable
powders
using
cement
mixer
equipment
(
using
PHED
mixing/
loading
WP
data),
(
S­
4)
on­
nursery
loading/
applying
dry
flowables
using
cement
mixer
equipment
(
using
PHED
mixing/
loading
DF
data),
(
S­
5)
on­
nursery
drying/
raking/
bagging
treated
seed,
(
S­
6)
loading
and
applying
wettable
powder
formulations
with
commercial
seedtreatment
equipment,
(
S­
7)
commercial
sewer
stitching
bags
of
seed,
(
S­
8)
bagging
and
otherwise
handling
treated
seeds
with
commercial
equipment,
and
(
S­
9)
multiple
commercial
seed
treatment
activities.

2.1.2
Noncancer
Triadimefon
Handler
Exposure
and
Assessment
2.1.2.1
Triadimefon
Handler
Exposure
and
Risk
Calculations
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:

Daily
Exposure
(
mg
ai/
day)
=
Unit
Exposure
(
mg
ai/
lb
ai
handled)
*
Application
Rate
(
lbs
ai/
area)
*
Daily
Area
Treated
(
area/
day)

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/
day);
Application
Rate
=
Normalized
application
rate
based
on
a
logical
unit
treatment,
such
as
acres,
Page
25
of
114
square
feet,
or
gallons.
Maximum
values
are
generally
used
(
lb
ai/
A,
lb
ai/
sq
ft,
lb
ai/
gal);
and
Daily
Area
Treated
=
Normalized
application
area
based
on
a
logical
unit
treatment
such
as
acres
(
A/
day),
square
feet
(
sq
ft/
day),
or
gallons
per
day
(
gal/
day).

Daily
Dose:
The
daily
dermal
or
inhalation
dose
is
calculated
by
normalizing
the
daily
exposure
by
body
weight
and
adjusting,
if
necessary,
with
an
appropriate
dermal
or
inhalation
absorption
factor.
For
all
dermal
exposure
scenarios
for
triadimefon,
an
average
female
adult
body
weight
of
60
kilograms
was
used,
since
the
toxicological
endpoint
of
concern
was
genderspecific
For
dermal
exposures,
an
absorption
factor
of
100%
was
used,
since
the
toxicological
endpoint
is
from
a
dermal
study.
For
all
inhalation
exposure
scenarios
for
triadimefon,
an
average
adult
body
weight
of
70
kilograms
was
used,
since
the
toxicological
endpoint
of
concern
was
not
gender­
specific.
For
inhalation
exposures,
an
absorption
factor
of
100%
was
assumed.
Daily
dose
was
calculated
using
the
following
formula:

Average
Daily
Dose
(
mg/
kg/
day)
=
(
Daily
Exposure
(
mg
ai/
day)
*
(
Absorption
Factor
(
100%)
/
Body
Weight
(
kg)

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).

Margins
of
Exposure:
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:

MOE
=
NOAEL
(
mg/
kg/
day)
/
ADD
(
mg/
kg/
day)

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
=
Dose
level
in
a
toxicity
study,
where
no
observed
adverse
effects
(
NOAEL)
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
also
calculated
because
the
dermal
and
inhalation
toxicological
endpoints
of
concern
are
based
on
the
same
adverse
effects.
The
total
MOE
values
were
calculated
using
the
formula
below:

Total
MOE
=
(
1/
(
1/
Dermal
MOE)
+
(
1/
Inhalation
MOE))
Page
26
of
114
2.1.2.2
Triadimefon
Risk
Summary
(
using
PHED,
ORETF,
and
proprietary
data)

A
summary
of
the
short­
and
intermediate­
term
risks
for
each
exposure
scenario
are
presented
below
in
Tables
7a
and
7b.
Handler
risks
from
on­
nursery
and
commercial
seed
treatment
are
presented
in
Tables
8a,
8b,
9,
10a,
and
10b.

Short­
and
Intermediate­
term
Dermal
and
Inhalation
Risks
In
most
non­
seed
treatment
scenarios,
dermal
and
inhalation
MOEs
met
or
exceeded
the
required
uncertainty
factor
of
100
at
some
level
of
risk
mitigation.
In
the
majority
of
scenarios
where
data
are
available,
inhalation
risks
were
not
a
concern
at
baseline
(
no
respirator)
and
dermal
risks
were
not
a
concern
at
baseline
or
baseline
plus
chemical­
resistant
gloves.
However,
there
were
inhalation
concerns
for
several
of
the
scenarios
involving
mixing/
loading
wettable
powder
to
support
application
to
turf
unless
engineering
controls
(
water­
soluble
packaging)
are
used.
The
inhalation
risk
in
one
scenario
remains
a
concern
with
maximum
inhalation
risk
mitigation:

 
Mixing/
loading/
applying
wettable
powders
with
a
low
pressure
handwand
(
using
PHED
data)
to
turf
(
LCO
and
golf
course)
at
the
5.4
lb
ai/
A
(
CA
only)
application
rate
(
the
dermal
MOE
=
110
with
double
layer
and
gloves;
however
the
inhalation
MOE
=
80
with
a
90%
protection
factor
half­
face
respirator).

In
all
the
on­
nursery
seed
treatment
scenarios
where
data
are
available,
inhalation
MOEs
exceeded
the
required
uncertainty
factor
of
100
at
baseline
(
no
respirator)
and
dermal
MOEs
exceeded
the
required
uncertainty
factor
of
100
at
baseline
(
long­
sleeve
shirt,
long
pants,
shoes,
and
socks)
or
baseline
plus
chemical­
resistant
gloves.
For
commercial
seed
treatment,
all
dermal
MOEs
met
or
exceeded
the
required
uncertainty
factor
at
baseline
or
baseline
plus
chemicalresistant
gloves.
However,
the
inhalation
risks
remain
a
concern
for
one
scenario
even
with
maximum
inhalation
risk
mitigation:
multiple
activities
for
ponderosa
pine
seed,
where
inhalation
MOE
=
92
with
a
90%
protection
factor
half­
face
respirator).

Short­
and
Intermediate­
term
Total
Risks
In
most
non­
seed
treatment
scenarios,
dermal
plus
inhalation
MOEs
met
or
exceeded
the
required
uncertainty
factor
of
100
at
some
level
of
risk
mitigation.
In
the
majority
of
scenarios
where
data
are
available,
total
risks
were
not
a
concern
at
baseline
(
long­
sleeve
shirt,
long
pants,
shoes,
socks,
no
respirator)
or
baseline
plus
chemical­
resistant
gloves.
However,
there
were
risk
concerns
for
several
of
the
scenarios
involving
mixing/
loading
wettable
powder
to
support
application
to
turf
unless
engineering
controls
(
water­
soluble
packaging)
are
used.
The
inhalation
risks
for
two
scenarios
remain
a
concern
with
maximum
inhalation
risk
mitigation:


Mixing/
loading/
applying
wettable
powders
with
a
low
pressure
handwand
(
using
PHED
data)
to
turf
(
LCO
and
golf
course)
at
the
5.4
lb
ai/
A
application
rate,
where
the
MOE
=
Page
27
of
114
46
with
double
layer
and
gloves
and
a
90%
protection
factor
half­
face
respirator;
and

Mixing/
loading/
applying
wettable
powders
with
a
low
pressure
handwand
(
using
PHED
data)
to
turf
(
LCO
and
golf
course)
at
the
2.7
lb
ai/
A
application
rate,
where
the
MOE
=
92
with
double
layer
and
gloves
and
a
90%
protection
factor
half­
face
respirator.

In
all
the
on­
nursery
seed
treatment
scenarios,
combined
dermal
and
inhalation
MOEs
met
or
exceeded
the
required
uncertainty
factor
of
100
at
some
level
of
risk
mitigation.
For
commercial
seed
treatment,
all
of
the
combined
MOEs
met
or
exceeded
the
required
uncertainty
factor
at
the
maximum
level
of
mitigation,
except
for
multiple
activities
for
ponderosa
pine
seed,
where
the
combined
MOE
=
91
with
single
layer/
gloves
and
a
90%
protection
factor
half­
face
respirator.

Data
Gaps
There
are
no
data
to
assess
risks
to
pilots,
except
when
engineering
controls
(
enclosed
cockpits)
are
used.
Risks
are
not
of
concern
for
pilots
using
enclosed
cabs.

There
are
no
data
to
assess
mixing/
loading/
applying
liquids
with
a
tree
injector
or
mixing/
loading/
applying
ready­
to­
use
briquettes.
HED
recommends
that
handlers
in
these
scenarios
wear
baseline
attire
plus
chemical­
resistant
gloves.
There
also
are
no
data
to
assess
mixing/
loading/
applying
dips.
HED
recommends
that
handlers
involved
in
dip
applications
wear
baseline
attire
plus
chemical­
resistant
gloves
and
chemical­
resistant
apron.

HED
has
no
data
to
assess
risks
to
handlers
participating
in
drying,
raking,
and
bagging
treated
seed;
however,
HED
expects
that
exposures
could
be
significant.
Therefore,
HED
recommends
that
these
handlers
wear
baseline
attire
plus
chemical­
resistant
gloves
and
chemical­
resistant
apron
Page
28
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
Mixer/
Loader
Mixing/
Loading
Liquid
Concentrates
for
Aerial
Applications
grapes
0.125
350
140
4500
18000
24000
23000
45000
48000
66000
grapes
0.125
80
620
20000
78000
110000
99000
200000
210000
290000
turf
(
sod
farm)
5.4
(
CA
only)
80
14
460
1800
2500
2300
4600
4800
6600
turf
(
golf
course)
5.4
(
CA
only)
40
29
920
3600
4900
4600
9200
9700
13000
turf
(
sod
farm)
2.7
(
except
CA)
80
29
920
3600
4900
4600
9200
9700
13000
turf
(
golf
course)
2.7
(
except
CA)
40
57
1800
7200
9800
9200
18000
19000
27000
Mixing/
Loading
Liquids
Concentrates
for
Groundboom
Applications
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
80
60
1900
7500
10000
9500
19000
20000
28000
Page
29
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(
golf
course)
1.3
(
Bayer:

max
residential)
40
120
3800
15000
20000
19000
38000
40000
55000
turf
(
sod
farm)
0.64
80
120
3900
15000
21000
19000
39000
41000
56000
Mixing/
Loading
Liquids
Concentrates
for
Groundboom
Applications
(
cont.)
turf
(
golf
course)
0.64
40
240
7700
31000
41000
39000
77000
82000
110000
5.4
(
CA
only)
100
11
370
1400
2000
1800
3700
3900
5300
2.7
(
except
CA)
100
23
730
2900
3900
3700
7300
7800
11000
1.3
(
Bayer:

max
residential)
100
48
1500
6000
8100
7600
15000
16000
22000
Mixing/
Loading
Liquid
Concentrates
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
turf
(
LCO)
0.64
100
97
3100
12000
17000
15000
31000
33000
45000
Page
30
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
Mixing/
Loading
Liquids
Concentrates
for
Airblast
Applications
grapes
0.125
40
1200
40000
160000
210000
200000
400000
420000
570000
Mixing/
Loading
Liquid
Concentrates
for
Injection
ornamentals
(
shade
trees,

woody
shrubs)
0.000026
lb
ai/
inch
of
trunk
inch
of
trunk
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
apples,
Christmas
trees,
pears
0.25
350
56
63
1200
1600
320
630
21000
11000
grapes
0.188
350
74
84
1600
2100
420
840
28000
15000
turf
(
sod
farm)
5.4
(
CA
only)
350
2.6
2.9
56
73
15
29
970
520
turf
(
sod
farm)
2.7
(
except
CA)
350
5.1
5.9
110
150
29
59
1900
1000
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
11
12
230
300
61
120
4000
2200
Mixing/
Loading
Wettable
Powders
for
Aerial
Applications
pine
seedlings
0.5
350
28
32
610
790
160
320
10000
5700
Page
31
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
azaleas
0.005
lb
ai/
gallon
2400
gallons
410
460
8800
12000
2300
4600
150000
83000
Mixing/
Loading
Wettable
Powders
for
Chemigation
Applications
turf
(
sod
farm)
5.4
(
CA
only)
350
2.6
2.9
56
73
15
29
970
520
turf
(
sod
farm)
2.7
(
except
CA)
350
5.1
5.9
110
150
29
59
1900
1000
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
11
12
230
300
61
120
4000
2200
Mixing/
Loading
Wettable
Powders
for
Chemigation
Applications
(
cont.)
ornamentals
(
flowering,

shrubs,
trees)
0.25
60
320
370
7100
9200
1800
3700
120000
66000
azaleas
0.005
lb
ai/
gallon
16000
gallons
61
69
1300
1700
350
690
23000
12000
grapes
0.188
80
320
370
7000
9200
1800
3700
120000
66000
ornamentals
(
flowering,

shrubs,
trees)
0.25
40
490
550
11000
14000
2800
5500
180000
99000
Mixing/
Loading
Wettable
Powders
for
Groundboom
Applications
pine
seedlings
0.5
80
120
140
2600
3500
690
1400
46000
25000
Page
32
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(
sod
farm)
5.4
(
CA
only)
80
11
13
250
320
64
130
4300
2300
turf
(
golf
course)
5.4
(
CA
only)
40
23
26
490
640
130
260
8500
4600
turf
(
sod
farm)
2.7
(
except
CA)
80
23
26
490
640
130
260
8500
4600
turf
(
golf
course)
2.7
(
except
CA)
40
45
51
980
1300
260
510
17000
9200
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
80
47
53
1000
1300
270
530
18000
9500
turf
(
golf
course)
1.3
(
Bayer:

max
residential)
40
94
110
2000
2700
530
1100
35000
19000
turf
(
sod
farm)
0.64
80
95
110
2100
2700
540
1100
36000
19000
turf
(
golf
course)
0.64
40
190
220
4100
5400
1100
2200
72000
39000
Mixing/
Loading
Wettable
Powders
for
Groundboom
Applications
(
cont.)
raspberries
0.125
80
490
550
11000
14000
2800
5500
180000
99000
Page
33
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(
LCO)
5.4
(
CA
only)
100
9
10
200
260
51
100
3400
1800
Mixing/
Loading
Wettable
Powders
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
turf
(
LCO)
2.7
(
except
CA)
100
18
20
390
510
100
200
6800
3700
turf
(
LCO)
1.3
(
Bayer:

max
residential)
100
37
43
810
1100
210
430
14000
7600
Mixing/
Loading
Wettable
Powders
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)

(
cont.)
turf
(
LCO)
0.64
100
76
86
1700
2200
430
860
29000
15000
apples,
Christmas
trees,
pears
0.25
40
490
550
11000
14000
2800
5500
180000
99000
grapes
0.188
40
650
740
14000
18000
3700
7400
240000
130000
pine
seedlings
0.5
40
240
280
5300
6900
1400
2800
92000
50000
Mixing/
Loading
Wettable
Powders
for
Airblast
Applications
raspberries
0.125
40
970
1100
21000
28000
5500
11000
370000
200000
Page
34
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(

rightsof
way)
5.4
(
CA
only)
80
11
13
250
320
64
130
4300
2300
turf
(

rightsof
way)
2.7
(
except
CA)
80
23
26
490
640
130
260
8500
4600
turf
(

rightsof
way)
1.3
(
Bayer:

max
residential)
80
47
53
1000
1300
270
530
18000
9500
Mixing/
Loading
Wettable
Powders
to
Support
Rights­

ofway
turf
(

rightsof
way)
0.64
80
95
110
2100
2700
540
1100
36000
19000
turf
(
sod
farm)
5.4
(
CA
only)
350
140
160
140
200
820
1600
970
520
turf
(
sod
farm)
2.7
(
except
CA)
350
290
330
290
410
1600
3300
1900
1000
Mixing/
Loading
Dry
Flowables
for
Aerial
Applications
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
600
680
600
840
3400
6800
4000
2200
Page
35
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
azaleas
0.005
lb
ai/
gallon
2400
gallons
23000
26000
23000
32000
130000
260000
150000
83000
turf
(
sod
farm)
5.4
(
CA
only)
350
140
160
140
200
820
1600
970
520
turf
(
sod
farm)
2.7
(
except
CA)
350
290
330
290
410
1600
3300
1900
1000
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
600
680
600
840
3400
6800
4000
2200
Mixing/
Loading
Dry
Flowables
for
Chemigation
Applications
ornamentals
(
flowering,

shrubs,
trees)
0.25
60
18000
21000
18000
26000
100000
210000
120000
66000
azaleas
0.005
lb
ai/
gallon
16000
gallons
3400
3900
3400
4800
19000
39000
23000
12000
turf
(
sod
farm)
5.4
(
CA
only)
80
630
720
630
890
3600
7200
4300
2300
turf
(
golf
course)
5.4
(
CA
only)
40
1300
1400
1300
1800
7200
14000
8500
4600
turf
(
sod
farm)
2.7
(
except
CA)
80
1300
1400
1300
1800
7200
14000
8500
4600
turf
(
golf
course)
2.7
(
except
CA)
40
2500
2900
2500
3500
14000
29000
17000
9200
Mixing/
Loading
Dry
Flowables
for
Groundboom
Applications
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
80
2600
3000
2600
3700
15000
30000
18000
9500
Page
36
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(
golf
course)
1.3
(
Bayer:

max
residential)
40
5200
5900
5200
7400
30000
59000
35000
19000
turf
(
sod
farm)
0.64
80
5300
6000
5300
7500
30000
60000
36000
19000
turf
(
golf
course)
0.64
40
11000
12000
11000
15000
60000
120000
72000
39000
Mixing/
Loading
Dry
Flowables
for
Groundboom
Applications
(
cont.)
ornamentals
(
flowering,

shrubs,
trees)
0.25
40
27000
31000
27000
38000
150000
310000
180000
99000
turf
(
LCO)
5.4
(
CA
only)
5
10000
11000
10000
14000
57000
110000
68000
37000
turf
(
LCO)
2.7
(
except
CA)
5
20000
23000
20000
28000
110000
230000
140000
73000
turf
(
LCO)
1.3
(
Bayer:

max
residential)
5
42000
48000
42000
59000
240000
480000
280000
150000
Mixing/
Loading
Dry
Flowables
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
turf
(
LCO)
0.64
5
85000
97000
85000
120000
480000
970000
570000
310000
turf
(
sod
farm)
5.2
(
CA
only)
350
1200
77
1400
2900
380
770
58000
3800
Loading
Granulars
for
Aerial
Applications
turf
(
sod
farm)
2.6
(
except
CA)
350
2400
150
2900
5800
770
1500
120000
7700
Page
37
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
Loading
Granulars
for
Aerial
Applications
(
cont.)
turf
(
sod
farm)
1.36
(
Bayer:

max
residential)
350
4500
290
5500
11000
1500
2900
220000
15000
turf
(
sod
farm)
5.2
(
CA
only)
80
5200
340
6300
13000
1700
3400
250000
17000
turf
(
sod
farm)
2.6
(
except
CA)
80
10000
670
13000
25000
3400
6700
510000
34000
turf
(
sod
farm)
1.36
(
Bayer:

max
residential)
80
20000
1300
24000
49000
6400
13000
970000
64000
turf
(
golf
course)
5.2
(
CA
only)
40
10000
670
13000
25000
3400
6700
510000
34000
turf
(
golf
course)
2.6
(
except
CA)
40
21000
1300
25000
51000
6700
13000
1000000
67000
Loading
Granulars
for
Tractor
Drawn
Spreader
Applications
turf
(
golf
course)
1.36
(
Bayer:

max
residential)
40
39000
2600
48000
97000
13000
26000
1900000
130000
Page
38
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
Applicator
apples,
Christmas
trees,
pears
0.25
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
41000
40000
grapes
0.188
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
55000
53000
turf
(
sod
farm)
5.4
(
CA
only)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
1900
1900
turf
(
sod
farm)
2.7
(
except
CA)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
3800
3700
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
7900
7700
pine
seedlings
0.5
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
21000
20000
Applying
Sprays
via
Aerial
Equipment
grapes
0.125
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
82000
80000
Page
39
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(
sod
farm)
5.2
(
CA
only)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
5800
100
turf
(
sod
farm)
2.6
(
except
CA)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
12000
200
Applying
Granulars
via
Aerial
Equipment
turf
(
sod
farm)
1.36
(
Bayer:

max
residential)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
22000
380
azaleas
0.005
lb
ai/
gallon
16000
gallons
16000
4000
16000
20000
20000
40000
45000
69000
grapes
0.125
80
130000
32000
130000
160000
160000
320000
360000
550000
grapes
0.188
80
85000
21000
85000
110000
110000
210000
240000
370000
turf
(
sod
farm)
5.4
(
CA
only)
80
3000
740
3000
3800
3700
7400
8300
13000
turf
(
golf
course)
5.4
(
CA
only)
40
6000
1500
6000
7600
7400
15000
17000
26000
Applying
Sprays
via
Groundboom
Equipment
turf
(
sod
farm)
2.7
(
except
CA)
80
6000
1500
6000
7600
7400
15000
17000
26000
Page
40
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(
golf
course)
2.7
(
except
CA)
40
12000
3000
12000
15000
15000
30000
33000
51000
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
80
12000
3100
12000
16000
15000
31000
35000
53000
turf
(
golf
course)
1.3
(
Bayer:

max
residential)
40
25000
6200
25000
31000
31000
62000
69000
110000
raspberries
0.125
80
130000
32000
130000
160000
160000
320000
360000
550000
pine
seedlings
0.5
80
32000
8000
32000
41000
40000
80000
90000
140000
ornamentals
(
flowering,

shrubs,
trees)
0.25
40
130000
32000
130000
160000
160000
320000
360000
550000
turf
(
sod
farm)
0.64
80
25000
6300
25000
32000
31000
63000
70000
110000
Applying
Sprays
via
Groundboom
Equipment
(
cont.)
turf
(
golf
course)
0.64
40
50000
13000
50000
64000
63000
130000
140000
220000
Page
41
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
apples,
Christmas
trees,
pears
0.25
40
5000
5300
7500
8200
(
11000)
26000
53000
95000
53000
pine
seedlings
0.5
40
2500
2600
3800
4100
(
5300)
13000
26000
47000
26000
grapes
0.188
40
6600
7000
10000
11000
(
14000)
35000
70000
130000
70000
Applying
Sprays
via
Airblast
Equipment
grapes,
raspberries
0.125
40
10000
11000
15000
16000
(
21000)
53000
110000
190000
110000
turf
(
LCO)
5.4
(
CA
only)
5
No
Data
6300
2000
3500
31000
63000
No
Data
No
Data
turf
(
LCO)
2.7
(
except
CA)
5
No
Data
13000
3900
7000
63000
130000
No
Data
No
Data
turf
(
LCO)
1.3
(
Bayer:

max
residential)
5
No
Data
26000
8100
15000
130000
260000
No
Data
No
Data
Applying
Sprays
via
Handgun
Equipment
turf
(
LCO)
0.64
5
No
Data
53000
17000
30000
270000
530000
No
Data
No
Data
Page
42
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(

rightsof
way)
5.4
(
CA
only)
80
32
140
110
140
710
1400
No
Data
No
Data
turf
(

rightsof
way)
2.7
(
except
CA)
80
64
280
210
290
1400
2800
No
Data
No
Data
turf
(

rightsof
way)
1.3
(
Bayer:

max
residential)
80
130
590
440
600
2900
5900
No
Data
No
Data
Applying
Sprays
via
Rights
of
Way
Equipment
turf
(

rightsof
way)
0.64
80
270
1200
900
1200
6000
12000
No
Data
No
Data
turf
(
sod
farm)
5.2
(
CA
only)
80
4400
480
6000
10000
2400
4800
21000
2600
turf
(
sod
farm)
2.6
(
except
CA)
80
8700
950
12000
21000
4800
9500
41000
5200
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)

6
80
17000
1800
23000
39000
9100
18000
79000
9900
Applying
Granulars
via
Tractor
Drawn
Spreader
turf
(
golf
course)
5.2
(
CA
only)
40
8700
950
12000
21000
4800
9500
41000
5200
Page
43
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(
golf
course)
2.6
(
except
CA)
40
17000
1900
24000
41000
9500
19000
82000
10000
Applying
Granulars
via
Tractor
Drawn
Spreader
(
cont.)
turf
(
golf
course)
1.36
(
Bayer:

max
residential)
40
33000
3600
46000
79000
18000
36000
160000
20000
Flagger
apples,
Christmas
trees,
pears
0.25
350
19000
7800
No
Data
21000
39000
78000
940000
390000
grapes
0.125
350
37000
16000
No
Data
41000
78000
160000
1900000
780000
Flagging
for
Aerial
Sprays
Applications
grapes
0.188
350
25000
10000
No
Data
27000
52000
100000
1200000
520000
turf
(
sod
farm)
5.4
(
CA
only)
350
870
360
No
Data
950
1800
3600
43000
18000
turf
(
sod
farm)
2.7
(
except
CA)
350
1700
720
No
Data
1900
3600
7200
87000
36000
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
3600
1500
No
Data
4000
7500
15000
180000
75000
Flagging
for
Aerial
Sprays
Applications
(
cont.)
pine
seedlings
0.5
350
9400
3900
No
Data
10000
19000
39000
470000
190000
Page
44
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(
sod
farm)
5.2
(
CA
only)
350
3500
870
No
Data
6200
4400
8700
180000
44000
turf
(
sod
farm)
2.6
(
except
CA)
350
7100
1700
No
Data
12000
8700
17000
350000
87000
Flagging
for
Aerial
Granular
Applications
turf
(
sod
farm)
1.36
(
Bayer:

max
residential)
350
14000
3300
No
Data
24000
17000
33000
680000
170000
Mixer/
Loader/
Applicator
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00938
lb
ai/
gallon
40
gallons
3200
230000
150000
No
Data
1200000
2300000
Not
Feasible
Not
Feasible
ornamentals
(
flowering,

shrubs,
trees);

Pines
(
Christmas
trees)
0.0023
lb
ai/
gallon
40
gallons
13000
960000
590000
No
Data
4800000
9600000
Not
Feasible
Not
Feasible
roses
0.00029
lb
ai/
gallon
40
gallons
100000
7600000
4700000
No
Data
38000000
76000000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
5.4
(
CA
only)
5
44
3300
2000
No
Data
16000
33000
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
ORETF)
turf
(
LCO
&

golf
course)
2.7
(
except
CA)
5
89
6500
4000
No
Data
33000
65000
Not
Feasible
Not
Feasible
Page
45
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(
LCO
&

golf
course)
1.3
(
Bayer:

max
residential)
5
180
14000
8400
No
Data
68000
140000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
0.64
5
380
28000
17000
No
Data
140000
280000
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
ORETF)

(
cont.)
grapes
0.125
lb
ai/
gallon
40
gallons
240
18000
11000
No
Data
88000
180000
Not
Feasible
Not
Feasible
apples
0.00062
lb
ai/
gallon
40
gallons
No
Data
8700
84000
120000
44000
87000
Not
Feasible
Not
Feasible
azaleas
0.005
lb
ai/
gallon
40
gallons
No
Data
1100
10000
15000
5400
11000
Not
Feasible
Not
Feasible
grapes
0.00094
lb
ai/
gallon
40
gallons
No
Data
5800
56000
77000
29000
58000
Not
Feasible
Not
Feasible
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00625
lb
ai/
gallon
40
gallons
No
Data
870
8400
12000
4300
8700
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
5.4
(
CA
only)
5
No
Data
8
78
110
40
80
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
2.7
(
except
CA)
5
No
Data
16
160
220
80
160
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
1.3
(
Bayer:

max
residential)
5
No
Data
33
320
450
170
330
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Wettable
Powders
with
Low
Pressure
Handwand
(
PHED)
turf
(
LCO
&

golf
course)
0.64
5
No
Data
68
650
910
340
680
Not
Feasible
Not
Feasible
Page
46
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
ornamentals
(
flowering,

shrubs,
trees)
0.0025
lb
ai/
gallon
40
gallons
No
Data
2200
21000
29000
11000
22000
Not
Feasible
Not
Feasible
pears
0.00062
lb
ai/
gallon
40
gallons
No
Data
8700
84000
120000
44000
87000
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Wettable
Powders
with
Low
Pressure
Handwand
(
PHED)
(
cont.)
pine
seedlings
0.5
5
No
Data
87
840
1200
430
870
Not
Feasible
Not
Feasible
azaleas
0.005
lb
ai/
gallon
40
gallons
6000
440000
270000
Data
available
2200000
4400000
Not
Feasible
Not
Feasible
ornamentals
(
flowering,

shrubs,
trees)
0.0025
lb
ai/
gallon
40
gallons
12000
880000
550000
Data
available
4400000
8800000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
5.4
(
CA
only)
5
44
3300
2000
Data
available
16000
33000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
2.7
(
except
CA)
5
89
6500
4000
Data
available
33000
65000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
1.3
(
Bayer:

max
residential)
5
180
14000
8400
Data
available
68000
140000
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Dry
Flowables
with
Low
Pressure
Handwand
(
using
liquids
ORETF
data)
turf
(
LCO
&

golf
course)
0.64
5
380
28000
17000
Data
available
140000
280000
Not
Feasible
Not
Feasible
Page
47
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00938
lb
ai/
gallon
1000
gallons
No
Data
17000
4300
7800
70000
170000
Not
Feasible
Not
Feasible
ornamentals
(
flowering,

shrubs,
trees);

Pines
(
Christmas
trees)
0.0023
lb
ai/
gallon
1000
gallons
No
Data
69000
17000
32000
290000
690000
Not
Feasible
Not
Feasible
roses
0.00029
lb
ai/
gallon
1000
gallons
No
Data
550000
140000
250000
2300000
5500000
Not
Feasible
Not
Feasible
turf
5.4
(
CA
only)
5
No
Data
5900
1500
2700
24000
59000
Not
Feasible
Not
Feasible
turf
2.7
(
except
CA)
5
No
Data
12000
3000
5400
49000
120000
Not
Feasible
Not
Feasible
turf
1.3
(
Bayer:

max
residential)
5
No
Data
24000
6200
11000
100000
240000
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
turf
0.64
5
No
Data
50000
13000
23000
210000
500000
Not
Feasible
Not
Feasible
apples
0.00062
lb
ai/
gallon
1000
gallons
No
Data
6000
36000
68000
30000
60000
Not
Feasible
Not
Feasible
grapes
0.00094
lb
ai/
gallon
1000
gallons
No
Data
4000
24000
45000
20000
40000
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Wettable
Powders
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
pine
seedlings
0.5
5
No
Data
1500
9000
17000
7400
15000
Not
Feasible
Not
Feasible
Page
48
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
5.4
(
CA
only)
5
No
Data
140
830
1600
690
1400
Not
Feasible
Not
Feasible
turf
2.7
(
except
CA)
5
No
Data
280
1700
3100
1400
2800
Not
Feasible
Not
Feasible
turf
1.3
(
Bayer:

max
residential)
5
No
Data
570
3500
6400
2900
5700
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Wettable
Powders
with
a
Handgun
Sprayer
(
LCO
ORETF
data)

(
cont.)
turf
0.64
5
No
Data
1200
7000
13000
5800
12000
Not
Feasible
Not
Feasible
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00625
lb
ai/
gallon
1000
gallons
No
Data
5300
4500
7800
26000
53000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
5.4
(
CA
only)
5
No
Data
1200
1000
1800
6100
12000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
2.7
(
except
CA)
5
No
Data
2400
2100
3600
12000
24000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
1.3
(
Bayer:

max
residential)
5
No
Data
5100
4300
7500
25000
51000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
0.64
5
No
Data
10000
8800
15000
52000
100000
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Water
Soluble
Bags
with
Handgun
Sprayer
(
LCO
ORETF
data)
pine
seedlings
0.5
5
No
Data
13000
11000
19000
66000
130000
Not
Feasible
Not
Feasible
Page
49
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
turf
(
LCO
&

golf
course)
5.4
(
CA
only)
5
No
Data
400
1100
2000
2000
4000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
2.7
(
except
CA)
5
No
Data
800
2300
4000
4000
8000
Not
Feasible
Not
Feasible
turf
(
LCO
&

golf
course)
1.3
(
Bayer:

max
residential)
5
No
Data
1700
4800
8400
8300
17000
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Dry
Flowables
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
turf
(
LCO
&

golf
course)
0.64
5
No
Data
3400
9700
17000
17000
34000
Not
Feasible
Not
Feasible
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00938
lb
ai/
gallon
1000
gallons
No
Data
210
770
1200
1100
2100
Not
Feasible
Not
Feasible
ornamentals
(
flowering,

shrubs,
trees)
0.0023
lb
ai/
gallon
1000
gallons
No
Data
860
3100
4900
4300
8600
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
High
Pressure
Handwand
(
only
study
in
PHED
is
for
greenhouse
use)
roses
0.00029
lb
ai/
gallon
1000
gallons
No
Data
6800
25000
39000
34000
68000
Not
Feasible
Not
Feasible
azaleas
0.005
lb
ai/
gallon
1000
gallons
No
Data
400
1400
2300
2000
4000
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Dry
Flowables
with
a
High
Pressure
Handwand
(
only
study
in
PHED
is
for
greenhouse
use
for
liquid
concentrates)
ornamentals
(
flowering,

shrubs,
trees)
0.0025
lb
ai/
gallon
1000
gallons
No
Data
790
2900
4500
4000
7900
Not
Feasible
Not
Feasible
Page
50
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
ornamentals
(
flowering,

shrubs,
trees)
0.0025
lb
ai/
gallon
1000
gallons
No
Data
790
2900
4500
4000
7900
Not
Feasible
Not
Feasible
azaleas
0.005
lb
ai/
gallon
1000
gallons
No
Data
400
1400
2300
2000
4000
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Wettable
Powders
with
a
High
Pressure
Handwand
(
only
study
in
PHED
is
for
greenhouse
use
for
liquid
concentrates)
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00625
lb
ai/
gallon
1000
gallons
No
Data
320
1200
1800
1600
3200
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
Liquids
with
an
Injector
ornamentals
(
shade
trees,

woody
shrubs)
0.000075
lb
ai/
1
inch
of
trunk
inch
of
trunk
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
Not
Feasible
Not
Feasible
Mixing/
Loading/

Applying
RTU
Briquette
pine
seedlings
0.00019
lb
ai/
seedling
seedlings
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
Not
Feasible
Not
Feasible
pine
seed
(
nurseries)
0.0000625
lb
ai/
gallon
100
gallons
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
Mixing/
Loading/

Applying
Dip
pineapple
(
post­
harvest)
0.0028
lb
ai/
gallon
100
gallons
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
turf
(
golf
course)
5.2
(
CA
only)
5
2000
1300
3100
6300
6300
13000
Not
Feasible
Not
Feasible
Loading/
Applying
Granulars
via
Push
Type
Spreader
(
ORETF)
turf
(
golf
course)
2.6
(
except
CA)
5
4000
2500
6300
13000
13000
25000
Not
Feasible
Not
Feasible
Page
51
of
114
Table
7a.
Triadimefon
Occupational
Handler
Exposure
and
Risk
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
MOEs
Personal
Protective
Equipment
Baseline
Dermal
Inhalation
Engineering
Control
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
SL
w/
glovese
DL
w/
gloves
(
with
HG)
f
80%
Rg
90%
Rh
Dermali
Inhalationj
Loading/
Applying
Granulars
via
Push
Type
Spreader
(
ORETF)
(
cont.)
turf
(
golf
course)
1.36
(
Bayer:

max
residential)
5
7600
4800
12000
24000
24000
48000
Not
Feasible
Not
Feasible
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
triadimefon
b
Amount
handled
per
day
values
are
HED
estimates
of
acres,
square
feet,
or
cubic
feet
treated
or
gallons
applied
based
on
Exposure
SAC
SOP
#
9
"
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,"
industry
sources,
and
HED
estimates.

c
Baseline
Dermal:
Long­
sleeve
shirt,
long
pants,
no
gloves.

d
Baseline
Inhalation:
no
respirator.

e
PPE
Dermal
SL
with
gloves:
Single
layer
plus
chemical­
resistant
gloves.

f
PPE
Dermal
DL
and
gloves
(
with
headgear):
Coveralls
worn
over
long­
sleeve
shirt
and
long
pants
plus
chemical­
resistant
gloves
(
and
with
headgear).

g
PPE
80%
R
inhalation:
assumes
a
dust/
mist
removing
quarter­
face
style
respirator
providing
an
80%
protection
factor.

h
PPE
90%
R
inhalation:
assumes
a
dust/
mist
removing
half­
face
style
respirator
providing
a
90%
protection
factor.

i
Eng
Controls
Dermal:
Closed
mixing/
loading
system,
enclosed
cab,
or
enclosed
cockpit.

j
Eng
Controls
Inhalation:
Closed
mixing/
loading
system,
enclosed
cab,
or
enclosed
cockpit.
Page
52
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
Mixer/
Loader
Mixing/
Loading
Liquid
Concentrates
for
Aerial
Applications
grapes
0.125
350
140
3600
3800
10000
13000
12000
16000
28000
grapes
0.125
80
600
16000
17000
44000
56000
51000
69000
120000
turf
(
sod
farm)
5.4
(
CA
only)
80
14
370
390
1000
1300
1200
1600
2800
turf
(
golf
course)
5.4
(
CA
only)
40
28
730
770
2000
2600
2400
3200
5600
turf
(
sod
farm)
2.7
(
except
CA)
80
28
730
770
2000
2600
2400
3200
5600
turf
(
golf
course)
2.7
(
except
CA)
40
56
1500
1500
4100
5200
4700
6400
11000
Mixing/
Loading
Liquids
Concentrates
for
Groundboom
Applications
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
80
58
1500
1600
4200
5400
4900
6600
12000
Page
53
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
(
golf
course)
1.3
(
Bayer:

max
residential)
40
120
3000
3200
8400
11000
9800
13000
23000
turf
(
sod
farm)
0.64
80
120
3100
3300
8500
11000
10000
13000
24000
Mixing/
Loading
Liquids
Concentrates
for
Groundboom
Applications
(
cont.)
turf
(
golf
course)
0.64
40
240
6200
6500
17000
22000
20000
27000
47000
5.4
(
CA
only)
100
11
290
310
810
950
No
Data
1000
2200
2.7
(
except
CA)
100
22
590
620
1600
1900
No
Data
2100
4500
1.3
(
Bayer:

max
residential)
100
46
1200
1300
3400
3900
No
Data
4300
9300
Mixing/
Loading
Liquid
Concentrates
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
turf
(
LCO)
0.64
100
94
2500
2600
6800
8000
No
Data
8800
19000
Page
54
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
Mixing/
Loading
Liquids
Concentrates
for
Airblast
Applications
grapes
0.125
40
1200
32000
33000
87000
110000
100000
140000
240000
Mixing/
Loading
Liquid
Concentrates
for
Injection
ornamentals
(
shade
trees,

woody
shrubs)
0.000026
lb
ai/
inch
of
trunk
inch
of
trunk
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
apples,
Christmas
trees,
pears
0.25
350
30
60
61
250
420
260
450
7400
grapes
0.188
350
39
80
81
330
550
350
600
9800
turf
(
sod
farm)
5.4
(
CA
only)
350
1.4
2.8
2.8
12
19
12
21
340
turf
(
sod
farm)
2.7
(
except
CA)
350
2.7
5.6
5.6
23
38
24
42
680
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
5.7
12
12
48
80
51
87
1400
Mixing/
Loading
Wettable
Powders
for
Aerial
Applications
pine
seedlings
0.5
350
15
30
30
130
210
130
230
3700
Page
55
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
azaleas
0.005
lb
ai/
gallon
2400
gallons
220
440
440
1800
3000
1900
3300
54000
turf
(
sod
farm)
5.4
(
CA
only)
350
1.4
2.8
2.8
12
19
12
21
340
turf
(
sod
farm)
2.7
(
except
CA)
350
2.7
5.6
5.6
23
38
24
42
680
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
5.7
12
12
48
80
51
87
1400
Mixing/
Loading
Wettable
Powders
for
Chemigation
Applications
ornamentals
(
flowering,

shrubs,
trees)
0.25
60
170
350
350
1500
2400
1500
2600
43000
azaleas
0.005
lb
ai/
gallon
16000
gallons
32
66
67
270
450
290
490
8000
grapes
0.188
80
170
350
350
1500
2400
1500
2600
43000
ornamentals
(
flowering,

shrubs,
trees)
0.25
40
260
530
530
2200
3600
2300
4000
64000
Mixing/
Loading
Wettable
Powders
for
Groundboom
Applications
pine
seedlings
0.5
80
65
130
130
550
910
580
990
16000
Page
56
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
(
sod
farm)
5.4
(
CA
only)
80
6
12
12
51
84
53
92
1500
turf
(
golf
course)
5.4
(
CA
only)
40
12
24
25
100
170
110
180
3000
turf
(
sod
farm)
2.7
(
except
CA)
80
12
24
25
100
170
110
180
3000
turf
(
golf
course)
2.7
(
except
CA)
40
24
49
49
200
340
210
370
6000
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
80
25
51
51
210
350
220
380
6200
turf
(
golf
course)
1.3
(
Bayer:

max
residential)
40
50
100
100
420
700
440
760
12000
turf
(
sod
farm)
0.64
80
51
100
100
430
710
450
770
13000
turf
(
golf
course)
0.64
40
100
210
210
860
1400
900
1500
25000
Mixing/
Loading
Wettable
Powders
for
Groundboom
Applications
(
cont.)
raspberries
0.125
80
260
530
530
2200
3600
2300
4000
64000
Page
57
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
(
LCO)
5.4
(
CA
only)
100
4.8
9.7
9.9
41
67
43
73
1200
turf
(
LCO)
2.7
(
except
CA)
100
9.6
19
20
81
130
85
150
2400
turf
(
LCO)
1.3
(
Bayer:

max
residential)
100
20
40
41
170
280
180
300
5000
Mixing/
Loading
Wettable
Powders
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
turf
(
LCO)
0.64
100
40
82
83
340
570
360
620
10000
apples,
Christmas
trees,
pears
0.25
40
260
530
530
2200
3600
2300
4000
64000
grapes
0.188
40
340
700
710
2900
4800
3100
5300
86000
pine
seedlings
0.5
40
130
260
270
1100
1800
1200
2000
32000
Mixing/
Loading
Wettable
Powders
for
Airblast
Applications
raspberries
0.125
40
520
1100
1100
4400
7300
4600
7900
130000
Mixing/
Loading
Wettable
Powders
to
Support
Rightsof
way
turf
(

rightsof
way)
5.4
(
CA
only)
80
6
12
12
51
84
53
92
1500
Page
58
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
(

rightsof
way)
2.7
(
except
CA)
80
12
24
25
100
170
110
180
3000
turf
(

rightsof
way)
1.3
(
Bayer:

max
residential)
80
25
51
51
210
350
220
380
6200
Mixing/
Loading
Wettable
Powders
to
Support
Rightsof
way
(
cont.)
turf
(

rightsof
way)
0.64
80
51
100
100
430
710
450
770
13000
turf
(
sod
farm)
5.4
(
CA
only)
350
77
77
91
120
130
160
180
340
turf
(
sod
farm)
2.7
(
except
CA)
350
150
150
180
250
270
320
360
680
Mixing/
Loading
Dry
Flowables
for
Aerial
Applications
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
320
320
380
510
550
670
750
1400
azaleas
0.005
lb
ai/
gallon
2400
gallons
12000
12000
14000
19000
21000
26000
28000
54000
turf
(
sod
farm)
5.4
(
CA
only)
350
77
77
91
120
130
160
180
340
Mixing/
Loading
Dry
Flowables
for
Chemigation
Applications
turf
(
sod
farm)
2.7
(
except
CA)
350
150
150
180
250
270
320
360
680
Page
59
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
320
320
380
510
550
670
750
1400
Mixing/
Loading
Dry
Flowables
for
Chemigation
Applications
(
cont.)
ornamentals
(
flowering,

shrubs,
trees)
0.25
60
9700
9700
11000
15000
17000
20000
23000
43000
azaleas
0.005
lb
ai/
gallon
16000
gallons
1800
1800
2100
2900
3100
3800
4300
8000
turf
(
sod
farm)
5.4
(
CA
only)
80
340
340
400
540
580
710
790
1500
turf
(
golf
course)
5.4
(
CA
only)
40
670
670
790
1100
1200
1400
1600
3000
turf
(
sod
farm)
2.7
(
except
CA)
80
670
670
790
1100
1200
1400
1600
3000
turf
(
golf
course)
2.7
(
except
CA)
40
1300
1300
1600
2100
2300
2800
3200
6000
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
80
1400
1400
1600
2200
2400
3000
3300
6200
turf
(
golf
course)
1.3
(
Bayer:

max
residential)
40
2800
2800
3300
4500
4800
5900
6600
12000
turf
(
sod
farm)
0.64
80
2800
2800
3300
4500
4900
6000
6700
13000
Mixing/
Loading
Dry
Flowables
for
Groundboom
Applications
turf
(
golf
course)
0.64
40
5700
5700
6700
9100
9800
12000
13000
25000
Page
60
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
Mixing/
Loading
Dry
Flowables
for
Groundboom
Applications
(
cont)
ornamentals
(
flowering,

shrubs,
trees)
0.25
40
14000
14000
17000
23000
25000
31000
34000
64000
turf
(
LCO)
5.4
(
CA
only)
5
5400
5400
6300
8600
9300
11000
13000
24000
turf
(
LCO)
2.7
(
except
CA)
5
11000
11000
13000
17000
19000
23000
25000
48000
turf
(
LCO)
1.3
(
Bayer:

max
residential)
5
22000
22000
26000
36000
39000
47000
52000
99000
Mixing/
Loading
Dry
Flowables
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
turf
(
LCO)
0.64
5
45000
45000
53000
72000
78000
96000
110000
200000
turf
(
sod
farm)
5.2
(
CA
only)
350
72
73
75
300
500
340
610
3600
turf
(
sod
farm)
2.6
(
except
CA)
350
140
150
150
610
1000
680
1200
7200
Loading
Granulars
for
Aerial
Applications
turf
(
sod
farm)
1.36
(
Bayer:

max
residential)
350
280
280
290
1200
1900
1300
2300
14000
Page
61
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
(
sod
farm)
5.2
(
CA
only)
80
320
320
330
1300
2200
1500
2700
16000
turf
(
sod
farm)
2.6
(
except
CA)
80
630
640
660
2700
4400
3000
5300
32000
Loading
Granulars
for
Tractor
Drawn
Spreader
Applications
turf
(
sod
farm)
1.36
(
Bayer:

max
residential)
80
1200
1200
1300
5100
8400
5700
10000
60000
turf
(
golf
course)
5.2
(
CA
only)
40
630
640
660
2700
4400
3000
5300
32000
turf
(
golf
course)
2.6
(
except
CA)
40
1300
1300
1300
5300
8800
5900
11000
63000
Loading
Granulars
for
Tractor
Drawn
Spreader
Applications
(
cont.)
turf
(
golf
course)
1.36
(
Bayer:

max
residential)
40
2400
2400
2500
10000
17000
11000
20000
120000
Applicator
apples,
Christmas
trees,
pears
0.25
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
20000
Applying
Sprays
via
Aerial
Equipment
grapes
0.188
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
27000
Page
62
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
(
sod
farm)
5.4
(
CA
only)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
940
turf
(
sod
farm)
2.7
(
except
CA)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
1900
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
3900
pine
seedlings
0.5
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
10000
Applying
Sprays
via
Aerial
Equipment
(
cont.)
grapes
0.125
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
41000
turf
(
sod
farm)
5.2
(
CA
only)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
99
turf
(
sod
farm)
2.6
(
except
CA)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
200
Applying
Granulars
via
Aerial
Equipment
turf
(
sod
farm)
1.36
(
Bayer:

max
residential)
350
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
380
Page
63
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
azaleas
0.005
lb
ai/
gallon
16000
gallons
3200
3200
3400
8900
11000
10000
14000
27000
grapes
0.125
80
26000
26000
27000
71000
92000
81000
110000
220000
grapes
0.188
80
17000
17000
18000
48000
61000
54000
72000
150000
turf
(
sod
farm)
5.4
(
CA
only)
80
600
600
620
1700
2100
1900
2500
5000
turf
(
golf
course)
5.4
(
CA
only)
40
1200
1200
1200
3300
4300
3800
5000
10000
turf
(
sod
farm)
2.7
(
except
CA)
80
1200
1200
1200
3300
4300
3800
5000
10000
turf
(
golf
course)
2.7
(
except
CA)
40
2400
2400
2500
6600
8500
7500
10000
20000
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
80
2500
2500
2600
6900
8800
7800
10000
21000
Applying
Sprays
via
Groundboom
Equipment
turf
(
golf
course)
1.3
(
Bayer:

max
residential)
40
4900
4900
5200
14000
18000
16000
21000
42000
Page
64
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
raspberries
0.125
80
26000
26000
27000
71000
92000
81000
110000
220000
pine
seedlings
0.5
80
6400
6400
6700
18000
23000
20000
27000
55000
ornamentals
(
flowering,

shrubs,
trees)
0.25
40
26000
26000
27000
71000
92000
81000
110000
220000
turf
(
sod
farm)
0.64
80
5000
5000
5200
14000
18000
16000
21000
43000
Applying
Sprays
via
Groundboom
Equipment
(
cont.)
turf
(
golf
course)
0.64
40
10000
10000
10000
28000
36000
32000
42000
85000
apples,
Christmas
trees,
pears
0.25
40
2600
3100
3200
5800
6600
6200
7100
34000
pine
seedlings
0.5
40
1300
1600
1600
2900
3300
3100
3500
17000
grapes
0.188
40
3400
4100
4300
7800
8700
8300
9400
45000
Applying
Sprays
via
Airblast
Equipment
grapes,
raspberries
0.125
40
5100
6200
6400
12000
13000
12000
14000
68000
Page
65
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
(
LCO)
5.4
(
CA
only)
5
No
Data
1500
2300
1800
1900
3200
3300
No
Data
turf
(
LCO)
2.7
(
except
CA)
5
No
Data
3000
4500
3700
3800
6300
6600
No
Data
turf
(
LCO)
1.3
(
Bayer:

max
residential)
5
No
Data
6200
9400
7700
7900
13000
14000
No
Data
Applying
Sprays
via
Handgun
Equipment
turf
(
LCO)
0.64
5
No
Data
13000
19000
16000
16000
27000
28000
No
Data
turf
(

rightsof
way)
5.4
(
CA
only)
80
26
61
71
93
99
120
130
No
Data
turf
(

rightsof
way)
2.7
(
except
CA)
80
52
120
140
190
200
240
260
No
Data
turf
(

rightsof
way)
1.3
(
Bayer:

max
residential)
80
110
250
300
390
410
500
540
No
Data
Applying
Sprays
via
Rights
of
Way
Equipment
turf
(

rightsof
way)
0.64
80
220
510
600
780
840
1000
1100
No
Data
Page
66
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
(
sod
farm)
5.2
(
CA
only)
80
430
440
460
1700
2700
1900
3300
2300
turf
(
sod
farm)
2.6
(
except
CA)
80
860
880
910
3400
5300
3900
6500
4600
turf
(
sod
farm)
1.36
(
Bayer:

max
residential)
80
1600
1700
1700
6500
10000
7400
12000
8800
turf
(
golf
course)
5.2
(
CA
only)
40
860
880
910
3400
5300
3900
6500
4600
turf
(
golf
course)
2.6
(
except
CA)
40
1700
1800
1800
6800
11000
7700
13000
9200
Applying
Granulars
via
Tractor
Drawn
Spreader
turf
(
golf
course)
1.36
(
Bayer:

max
residential)
40
3300
3400
3500
13000
20000
15000
25000
18000
Page
67
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
Flagger
apples,
Christmas
trees,
pears
0.25
350
5500
No
Data
5600
No
Data
No
Data
13000
16000
270000
grapes
0.125
350
11000
No
Data
11000
No
Data
No
Data
27000
33000
550000
grapes
0.188
350
7300
No
Data
7500
No
Data
No
Data
18000
22000
370000
turf
(
sod
farm)
5.4
(
CA
only)
350
250
No
Data
260
No
Data
No
Data
620
750
13000
turf
(
sod
farm)
2.7
(
except
CA)
350
510
No
Data
520
No
Data
No
Data
1200
1500
25000
turf
(
sod
farm)
1.3
(
Bayer:

max
residential)
350
1100
No
Data
1100
No
Data
No
Data
2600
3100
53000
Flagging
for
Aerial
Sprays
Applications
pine
seedlings
0.5
350
2700
No
Data
2800
No
Data
No
Data
6700
8100
140000
turf
(
sod
farm)
5.2
(
CA
only)
350
700
No
Data
760
No
Data
No
Data
2600
3600
35000
turf
(
sod
farm)
2.6
(
except
CA)
350
1400
No
Data
1500
No
Data
No
Data
5100
7200
70000
Flagging
for
Aerial
Granular
Applications
turf
(
sod
farm)
1.36
(
Bayer:

max
residential)
350
2700
No
Data
2900
No
Data
No
Data
9800
14000
130000
Page
68
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
Mixer/
Loader/
Applicator
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00938
lb
ai/
gallon
40
gallons
3200
90000
No
Data
130000
140000
No
Data
No
Data
Not
Feasible
ornamentals
(
flowering,

shrubs,
trees);

Pines
(
Christmas
trees)
0.0023
lb
ai/
gallon
40
gallons
13000
370000
No
Data
530000
560000
No
Data
No
Data
Not
Feasible
roses
0.00029
lb
ai/
gallon
40
gallons
100000
2900000
No
Data
4200000
4400000
No
Data
No
Data
Not
Feasible
turf
(
LCO
&

golf
course)
5.4
(
CA
only)
5
44
1200
No
Data
1800
1900
No
Data
No
Data
Not
Feasible
turf
(
LCO
&

golf
course)
2.7
(
except
CA)
5
88
2500
No
Data
3600
3800
No
Data
No
Data
Not
Feasible
turf
(
LCO
&

golf
course)
1.3
(
Bayer:

max
residential)
5
180
5200
No
Data
7500
7900
No
Data
No
Data
Not
Feasible
turf
(
LCO
&

golf
course)
0.64
5
370
11000
No
Data
15000
16000
No
Data
No
Data
Not
Feasible
Mixing/
Loading
/
Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
ORETF)
grapes
0.125
lb
ai/
gallon
40
gallons
240
6700
No
Data
9700
10000
No
Data
No
Data
Not
Feasible
Page
69
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
apples
0.00062
lb
ai/
gallon
40
gallons
No
Data
7900
8100
29000
43000
32000
50000
Not
Feasible
azaleas
0.005
lb
ai/
gallon
40
gallons
No
Data
980
1000
3600
5300
3900
6200
Not
Feasible
grapes
0.00094
lb
ai/
gallon
40
gallons
No
Data
5200
5400
19000
28000
21000
33000
Not
Feasible
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00625
lb
ai/
gallon
40
gallons
No
Data
780
810
2900
4300
3200
5000
Not
Feasible
turf
(
LCO
&

golf
course)
5.4
(
CA
only)
5
No
Data
7.3
7.5
26
39
29
46
Not
Feasible
turf
(
LCO
&

golf
course)
2.7
(
except
CA)
5
No
Data
15
15
53
79
58
92
Not
Feasible
turf
(
LCO
&

golf
course)
1.3
(
Bayer:

max
residential)
5
No
Data
30
31
110
160
120
190
Not
Feasible
turf
(
LCO
&

golf
course)
0.64
5
No
Data
61
63
220
330
250
390
Not
Feasible
ornamentals
(
flowering,

shrubs,
trees)
0.0025
lb
ai/
gallon
40
gallons
No
Data
2000
2000
7100
11000
7900
12000
Not
Feasible
pears
0.00062
lb
ai/
gallon
40
gallons
No
Data
7900
8100
29000
43000
32000
50000
Not
Feasible
Mixing/
Loading
/
Applying
Wettable
Powders
with
Low
Pressure
Handwand
(
PHED)
pine
seedlings
0.5
5
No
Data
78
81
290
430
320
500
Not
Feasible
Page
70
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
azaleas
0.005
lb
ai/
gallon
40
gallons
5900
170000
No
Data
240000
260000
No
Data
No
Data
Not
Feasible
ornamentals
(
flowering,

shrubs,
trees)
0.0025
lb
ai/
gallon
40
gallons
12000
340000
No
Data
490000
510000
No
Data
No
Data
Not
Feasible
turf
(
LCO
&

golf
course)
5.4
(
CA
only)
5
44
1200
No
Data
1800
1900
No
Data
No
Data
Not
Feasible
turf
(
LCO
&

golf
course)
2.7
(
except
CA)
5
88
2500
No
Data
3600
3800
No
Data
No
Data
Not
Feasible
turf
(
LCO
&

golf
course)
1.3
(
Bayer:

max
residential)
5
180
5200
No
Data
7500
7900
No
Data
No
Data
Not
Feasible
Mixing/
Loading
/
Applying
Dry
Flowables
with
Low
Pressure
Handwand
(
using
liquids
ORETF
data)
turf
(
LCO
&

golf
course)
0.64
5
370
11000
No
Data
15000
16000
No
Data
No
Data
Not
Feasible
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00938
lb
ai/
gallon
1000
gallons
No
Data
3400
5400
4000
4200
7000
7500
Not
Feasible
ornamentals
(
flowering,

shrubs,
trees);

Pines
(
Christmas
trees)
0.0023
lb
ai/
gallon
1000
gallons
No
Data
14000
22000
16000
17000
29000
31000
Not
Feasible
Mixing/
Loading
/
Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
roses
0.00029
lb
ai/
gallon
1000
gallons
No
Data
110000
170000
130000
130000
230000
240000
Not
Feasible
Page
71
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
5.4
(
CA
only)
5
No
Data
1200
1900
1400
1400
2400
2600
Not
Feasible
turf
2.7
(
except
CA)
5
No
Data
2400
3700
2800
2900
4900
5200
Not
Feasible
turf
1.3
(
Bayer:

max
residential)
5
No
Data
4900
7700
5800
6000
10000
11000
Not
Feasible
Mixing/
Loading
/
Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)

(
cont)
turf
0.64
5
No
Data
10000
16000
12000
12000
21000
22000
Not
Feasible
apples
0.00062
lb
ai/
gallon
1000
gallons
No
Data
5100
5500
16000
23000
21000
32000
Not
Feasible
grapes
0.00094
lb
ai/
gallon
1000
gallons
No
Data
3400
3600
11000
15000
14000
21000
Not
Feasible
pine
seedlings
0.5
5
No
Data
1300
1400
4100
5600
5100
7900
Not
Feasible
turf
5.4
(
CA
only)
5
No
Data
120
130
380
520
480
730
Not
Feasible
turf
2.7
(
except
CA)
5
No
Data
240
250
750
1000
950
1500
Not
Feasible
turf
1.3
(
Bayer:

max
residential)
5
No
Data
490
530
1600
2200
2000
3000
Not
Feasible
Mixing/
Loading
/
Applying
Wettable
Powders
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
turf
0.64
5
No
Data
1000
1100
3200
4400
4000
6200
Not
Feasible
Page
72
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00625
lb
ai/
gallon
1000
gallons
No
Data
2400
3100
3800
4100
6000
6800
Not
Feasible
turf
(
LCO
&

golf
course)
5.4
(
CA
only)
5
No
Data
560
730
890
960
1400
1600
Not
Feasible
turf
(
LCO
&

golf
course)
2.7
(
except
CA)
5
No
Data
1100
1500
1800
1900
2800
3100
Not
Feasible
turf
(
LCO
&

golf
course)
1.3
(
Bayer:

max
residential)
5
No
Data
2300
3000
3700
4000
5800
6500
Not
Feasible
turf
(
LCO
&

golf
course)
0.64
5
No
Data
4700
6200
7500
8100
12000
13000
Not
Feasible
Mixing/
Loading
/
Applying
Water
Soluble
Bags
with
Handgun
Sprayer
(
LCO
ORETF
data)
pine
seedlings
0.5
5
No
Data
6100
7900
9600
10000
15000
17000
Not
Feasible
turf
(
LCO
&

golf
course)
5.4
(
CA
only)
5
No
Data
300
330
730
890
1000
1300
Not
Feasible
turf
(
LCO
&

golf
course)
2.7
(
except
CA)
5
No
Data
590
670
1500
1800
2000
2700
Not
Feasible
turf
(
LCO
&

golf
course)
1.3
(
Bayer:

max
residential)
5
No
Data
1200
1400
3000
3700
4200
5600
Not
Feasible
Mixing/
Loading
/
Applying
Dry
Flowables
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
turf
(
LCO
&

golf
course)
0.64
5
No
Data
2500
2800
6200
7500
8500
11000
Not
Feasible
Page
73
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00938
lb
ai/
gallon
1000
gallons
No
Data
170
180
440
560
560
770
Not
Feasible
ornamentals
(
flowering,

shrubs,
trees)
0.0023
lb
ai/
gallon
1000
gallons
No
Data
680
730
1800
2300
2300
3100
Not
Feasible
Mixing/
Loading
/
Applying
Liquid
Concentrates
with
a
High
Pressure
Handwand
(
only
study
in
PHED
is
for
greenhouse
use)
roses
0.00029
lb
ai/
gallon
1000
gallons
No
Data
5400
5800
14000
18000
18000
25000
Not
Feasible
azaleas
0.005
lb
ai/
gallon
1000
gallons
No
Data
310
340
830
1100
1100
1400
Not
Feasible
Mixing/
Loading
/
Applying
Dry
Flowables
with
a
High
Pressure
Handwand
(
only
study
in
PHED
is
for
greenhouse
use
for
liquid
concentrates)
ornamentals
(
flowering,

shrubs,
trees)
0.0025
lb
ai/
gallon
1000
gallons
No
Data
620
670
1700
2100
2100
2900
Not
Feasible
Page
74
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
ornamentals
(
flowering,

shrubs,
trees)
0.0025
lb
ai/
gallon
1000
gallons
No
Data
620
670
1700
2100
2100
2900
Not
Feasible
azaleas
0.005
lb
ai/
gallon
1000
gallons
No
Data
310
340
830
1100
1100
1400
Not
Feasible
Mixing/
Loading
/
Applying
Wettable
Powders
with
a
High
Pressure
Handwand
(
only
study
in
PHED
is
for
greenhouse
use
for
liquid
concentrates)
greenhouse
ornamentals
(
flowering,

shrubs,
trees)

(
non­
WPS)
0.00625
lb
ai/
gallon
1000
gallons
No
Data
250
270
670
850
840
1100
Not
Feasible
Mixing/
Loading
/
Applying
Liquids
with
an
Injector
ornamentals
(
shade
trees,

woody
shrubs)
0.000075
lb
ai/
1
inch
of
trunk
circumfere
nce
inch
of
trunk
circumfe
rence
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
Not
Feasible
Mixing/
Loading
/
Applying
RTU
Briquette
pine
seedlings
0.00019
lb
ai/
seedling
seedlings
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
Not
Feasible
pine
seed
(
nurseries)
0.0000625
lb
ai/
gallon
100
gallons
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
Mixing/
Loading
/
Applying
Dip
pineapple
(
post­
harvest)
0.0028
lb
ai/
gallon
100
gallons
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
Page
75
of
114
Table
7b.
Combined
Dermal
plus
Inhalation
Handler
Risks
for
Agricultural
and
Commercial
Uses
(
other
than
Seed
Treatment
Uses)
Combined
MOEsi
Exposure
Scenario
Crop
or
Target
App
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acre)
b
Baselinec
Dermal
+
Baseline
Inh
Single
layer
w/

glovesd
Dermal
+

Baseline
Inh
Double
layer
w/

glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Single
layer
w/

gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/

gloves
Dermal
+

80%
R
Inh
Double
layer
w/

gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+
Inh
turf
(
golf
course)
5.2
(
CA
only)
5
770
900
1000
2100
2500
3100
4200
Not
Feasible
turf
(
golf
course)
2.6
(
except
CA)
5
1500
1800
2100
4200
5000
6300
8400
Not
Feasible
Loading/
Applying
Granulars
via
Push
Type
Spreader
(
ORETF)
turf
(
golf
course)
1.36
(
Bayer:

max
residential)
5
2900
3400
4000
8000
9600
12000
16000
Not
Feasible
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
triadimefon.

b
Amount
handled
per
day
values
are
HED
estimates
of
acres
treated
per
day
based
on
Exposure
SAC
SOP
#
9
"
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,"
industry
sources,
and
HED
estimates.

c
Baseline
=
No
gloves
and
no
respirator
d
Single
layer
w/
gloves
is
baseline
attire
plus
chemical­
resistant
gloves.

e
Double
layer
w/
gloves
is
coveralls
worn
over
long­
sleeve
shirt
and
long
pants,
plus
chemical­
resistant
gloves
(
with
headgear).

f
80%
Respirator
is
quarter­
face
dust/
mist
respirator
(
that
provides
an
80%
protection
factor).

g
90%
Respirator
is
half­
face
dust/
mist
respirator
(
that
provides
a
90%
protection
factor).

h
Engineering
control
is
closed
mixing/
loading
system,
enclosed
cab,
or
enclosed
cockpit.

i
Combined
MOEs
=
1/[(
1/
Dermal
MOE)
+
(/
Inhalation
MOE)]
Page
76
of
114
Table
8a.
Handler
Exposures
and
Risks
from
On­
Nursery
Seed
Planter
Box/
Hopper
Box
Treatments
Unit
Exposures
MOEs
Baseline
Personal
Protective
Equipment
Engineering
Controls
Baseline
Personal
Protective
Equipment
Dermal
(
mg/
lb
ai)
Inhalation
(
µ
g/
lb
ai)
Dermal
Inhalation
Crop
Acres
treated/

day
App
Rate
(
lb
ai/

100
lb)
a
Amount
Handled
per
dayb
(
lb
ai/
day)
Dermalc
(
mg/
lb
ai)
Inhalationd
(
µ
g/
lb
ai)
SL
w/
glovese
80%
Rf
90%
Rg
Dermalh
(
mg/
lb
ai)
Inhalationi
(
µ
g/
lb
ai)
Inhalation
SL
w/
gloves
80%
R
90%
R
LOADING/
APPLYING
WITH
HOPPER
OR
PLANTER
BOX
SEED
TREATMENT
Pinej
Seed
(
WP)

(
S­
1)
80
0.0013
0.13
No
Data
1.2
12.6
0.24
0.12
No
Data
No
Data
1500
11000
7600
15000
LOADING/
PLANTING
PREVIOUSLY
TREATED
SEEDS
Pine
Seed
(
WP)

(
S­
2)
80
0.0013
0.13
No
Data
3.4
0.25
0.68
0.34
No
Data
No
Data
540
550000
2700
5400
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
triadimefon
b
Amount
handled
per
day
calculated
from
the
acres
treated/
day
and
the
maximum
lb
of
seed
planted
per
acre:
for
ponderosa
seed
­
1.25
lb/
A.

c
Baseline
Dermal:
Long­
sleeve
shirt,
long
pants,
no
gloves.

d
Baseline
Inhalation:
no
respirator.

e
PPE
Dermal
SL
with
gloves:
Single
layer
plus
chemical­
resistant
gloves.

f
PPE
80%
R
inhalation:
assumes
a
dust/
mist
removing
quarter­
face
style
respirator
providing
an
80%
protection
factor.

g
PPE
90%
R
inhalation:
assumes
a
dust/
mist
removing
half­
face
style
respirator
providing
a
90%
protection
factor.

h
Eng
Controls
Dermal:
Closed
System.

i
Eng
Controls
Inhalation:
Closed
System.

j
Ponderosa
pine
seeds
used.
Page
77
of
114
Table
8b.
Combined
Handler
Risks
from
On­
Nursery
Seed
Planter
Box/
Hopper
Box
Treatments
Combined
MOEsi
Crop
Acres
treated/

day
App
Ratea
(
lb
ai/
lb)
Amount
Handled
per
dayb
(
lb
ai/
day)
Baselinec
Dermal
+

Baseline
Inh
Single
layer
w/
glovesd
Dermal
+

Baseline
Inh
Double
layer
w/
glovese
Dermal
+

Baseline
Inh
Single
layer
w/
gloves
Dermal
+

80%
Rf
Inh
Double
layer
w/
gloves
Dermal
+

80%
R
Inh
Single
layer
w/
gloves
Dermal
+

90%
Rg
Inh
Double
layer
w/
gloves
Dermal
+

90%
R
Inh
Eng
Controlh
Dermal
+

Inh
LOADING/
APPLYING
WITH
HOPPER
OR
PLANTER
BOX
SEED
TREATMENT
Pine
Seedj
(
S­
1)
80
0.0013
0.129840019
No
Data
1300
No
Data
4500
No
Data
6400
No
Data
No
Data
LOADING/
PLANTING
PREVIOUSLY
TREATED
SEEDS
Pine
Seedj
(
S­
2)
80
0.0013
0.129840019
No
Data
540
No
Data
2700
No
Data
5300
No
Data
No
Data
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
triadimefon
b
Amount
handled
per
day
calculated
from
the
acres
treated/
day
and
the
maximum
lb
of
seed
planted
per
acre:
for
ponderosa
seed
­
1.25
lb/
A.

c
Baseline
=
No
gloves
and
no
respirator
d
Single
layer
w/
gloves
is
baseline
attire
plus
chemical­
resistant
gloves.

e
Double
layer
w/
gloves
is
coveralls
worn
over
long­
sleeve
shirt
and
long
pants,
plus
chemical­
resistant
gloves.

f
80%
Respirator
is
quarter­
face
dust/
mist
respirator
(
that
provides
an
80%
protection
factor).

g
90%
Respirator
is
half­
face
dust/
mist
respirator
(
that
provides
a
90%
protection
factor).

h
Engineering
control
is
closed
mixing/
loading
system,
enclosed
cab,
or
enclosed
cockpit.

i
Combined
MOEs
=
1/[(
1/
Dermal
MOE)
+
(/
Inhalation
MOE)]

j
Ponderosa
pine
seeds
used.
Page
78
of
114
Table
9.
Handler
Exposure
and
Risk
from
On­
Nursery
Cement
Mixer
Seed
Treatments
Baseline
MOEs
Exposure
Scenario
Crop
or
Target
Application
Rate
(
lb
ai/
acre)
a
Area
Treated
Daily
(
acres)
b
Dermalc
Inhalationd
Baseline
Dermal
+
Baseline
Inhalation
e
500
7500
8500
4000
Loading/
applying
wettable
powders
using
cement
mixer
equipment
(
PHED)
(
S­
3)
1000
3700
4300
2000
500
420000
480000
220000
Loading/
applying
dry
flowables
using
cement
mixer
equipment
(
PHED)
(
S­
4)
1000
210000
240000
110000
Drying/
raking/
bagging
treated
seed
(
S­
5)
ponderosa
seed
0.0013
1000
No
Data
No
Data
No
data
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
triadimefon
b
Amount
handled
per
day
values
are
the
range
of
acres
treated
daily
provided
by
Bayer
CropScience
in
a
memo
to
EPA
dated
4/
13/
06.
c
Baseline
Dermal:
Long­
sleeve
shirt,
long
pants,
no
gloves.
d
Baseline
Inhalation:
no
respirator.
e
Combined
MOEs
=
1/[(
1/
Dermal
MOE)
+
(/
Inhalation
MOE)]
Page
79
of
114
Table
10a.
Handler
Exposure
and
Risk
from
Commercial
Seed
Treatments
Unit
Exposures
MOEs
Baseline
Personal
Protective
Equipment
Engineering
Controls
Baseline
Personal
Protective
Equipment
Engineering
Controls
Dermal
(
mg/
lb
ai)
Inhalation
(
µ
g/
lb
ai)
Dermal
Inhalation
Crop
Exposure
Scenario
AR
(
lb
ai/
100
lb)
a
Amount
Handled
per
day
(
lb
ai/
day)
b
Dermalc
(
mg/
lb
ai)
Inhd
(
µ
g/
lb
ai)
SL
w/
glovese
DL
w/
glovesf
80%
Rg
90%
Rh
Dermali
(
mg/
lb
ai)
Inhj
(
µ
g/
lb
ai)
Dermal
Inh
SL
w/
gloves
DL
w/
gloves
80%
R
90%
R
Dermal
Inh
Loader/
Applicator
(
S­
6)
0.13
16.23
No
Data
0.34
0.023
0.18
0.068
0.034
No
Data
No
Data
No
Data
43
48,000
62,000
220
430
No
Data
No
Data
Sewer
(
S­
7)
0.13
16.23
0.0062
0.23
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
180000
64
No
Data
No
Data
320
640
No
Data
No
Data
Bagger
(
S­
8)
0.13
16.23
0.0091
0.16
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
120000
92
No
Data
No
Data
460
920
No
Data
No
Data
Pinek
Seeds
Multiple
Activitiesl
(
S­
9)
0.13
16.23
No
Data
1.6
0.042
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
9.2
26000
No
Data
46
92
No
Data
No
Data
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
triadimefon
b
Amount
handled
per
day
calculated
from
the
maximum
application
rate
and
the
lbs
of
seed
treated
or
planted/
day
and:
for
ponderosa
seed
­
12485
lb/
day.

c
Baseline
Dermal:
Long­
sleeve
shirt,
long
pants,
no
gloves.

d
Baseline
Inhalation:
no
respirator.

e
PPE
Dermal
SL
with
gloves:
Single
layer
plus
chemical­
resistant
gloves.

f
PPE
Dermal
DL
and
gloves:
Coveralls
worn
over
long­
sleeve
shirt
and
long
pants
plus
chemical­
resistant
gloves.

g
PPE
80%
R
inhalation:
assumes
a
dust/
mist
removing
quarter­
face
style
respirator
providing
an
80%
protection
factor.

h
PPE
90%
R
inhalation:
assumes
a
dust/
mist
removing
half­
face
style
respirator
providing
a
90%
protection
factor.

i
Eng
Controls
Dermal:
Closed
System
j
Eng
Controls
Inhalation:
Closed
System.

k
Ponderosa
pine
seeds
used.
Page
80
of
114
Table
10b.
Combined
Handler
Dermal
and
Inhalation
Risk
from
Commercial
Seed
Treatments
Combined
MOEsi
Pine
Seed
Exposure
Scenario
App
Ratea
(
lb
ai/
lb)
Amount
Handled
per
day
b
(
lb
ai/
day)
Baselinec
Dermal
+

Baseline
Inh
Single
layer
w/
glovesd
Dermal
+

Baseline
Inh
Double
layer
w/
glovese
Dermal
+

Baseline
Inh
Baseline
Dermal
+

80%
Rf
Inh
Single
layer
w/
gloves
Dermal+

80%
R
Inh
Baseline
Dermal
+

90%
Rf
Inh
Single
layer
w/
gloves
Dermal
+

90%
Rg
Inh
Eng
Controlh
Dermal
+

Inh
Loader/
Applicator
(
S­
6)
0.0013
16.23
No
Data
43
43
No
Data
220
No
Data
430
No
Data
Sewer
(
S­
7)
0.0013
16.23
64
No
Data
No
Data
320
No
Data
640
No
Data
No
Data
Bagger
(
S­
8)
0.0013
16.23
92
No
Data
No
Data
460
No
Data
910
No
Data
No
Data
Ponderosa
Seedj
Multiple
Activitiesl
(
S­
9)
0.0013
16.23
No
Data
9.2
No
Data
No
Data
46
No
Data
91
No
Data
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
triadimefon
b
Amount
handled
per
day
calculated
from
the
maximum
application
rate
and
the
lbs
of
seed
treated
or
planted/
day
and:
for
ponderosa
seed
­
12485
lb/
day.

c
Baseline
=
No
gloves
and
no
respirator
d
Single
layer
w/
gloves
is
baseline
attire
plus
chemical­
resistant
gloves.

e
Double
layer
w/
gloves
is
coveralls
worn
over
long­
sleeve
shirt
and
long
pants,
plus
chemical­
resistant
gloves.

f
80%
Respirator
is
quarter­
face
dust/
mist
respirator
(
that
provides
an
80%
protection
factor).

g
90%
Respirator
is
half­
face
dust/
mist
respirator
(
that
provides
a
90%
protection
factor).

h
Engineering
control
is
closed
mixing/
loading
system,
enclosed
cab,
or
enclosed
cockpit.

i
Combined
MOEs
=
1/[(
1/
Dermal
MOE)
+
(/
Inhalation
MOE)]

j
Ponderosa
pine
seeds
used.
Page
81
of
114
2.1.3
Cancer
Triadimefon
Handler
Exposure
and
Risk
Assessment
No
cancer
endpoints
of
concern
for
triadimefon
were
identified;
therefore,
cancer
risks
to
handlers
were
not
assessed.

2.1.4
Summary
of
Risk
Concerns
and
Data
Gaps
for
Occupational
Handlers
There
are
several
occupational
handler
scenarios
for
triadimefon
that
have
risks
associated
with
them
that
are
above
HED's
level
of
concern
for
risk
assessments,
even
at
the
highest
level
of
risk
mitigation.
However,
there
are
also
some
occupational
handler
scenarios
for
triadimefon
that
have
data
gaps.

2.1.4.1
Summary
of
Risk
Concerns
The
short­
and
intermediate­
term
dermal
plus
inhalation
handler
risk
assessment
for
triadimefon
indicates
risk
concerns
for
a
few
handler
scenarios,
even
with
maximum
risk
mitigation.
See
Section
2.1.2.2
for
a
detailed
summary.

2.1.4.2
Summary
of
Data
Gaps
Several
data
gaps
were
identified
for
triadimefon
in
many
different
use
areas
that
include:

 
mixing/
loading/
applying
dry
flowables
using
a
low­
pressure
handwand
sprayer
(
data
for
liquid
formulations
was
used
as
a
surrogate),
 
mixing/
loading/
applying
wettable
powders
using
a
high­
pressure
handwand
sprayer
(
data
for
liquid
formulations
was
used
as
a
surrogate),
 
mixing/
loading/
applying
dry
flowables
using
a
high­
pressure
handwand
sprayer
(
data
for
liquid
formulations
was
used
as
a
surrogate),
 
mixing/
loading/
applying
liquid
concentrates
for
tree
injection
(
no
surrogate
available),
 
mixing/
loading/
applying
ready­
to­
use
briquettes
for
pine
seedlings
(
no
surrogate
available),
and
 
mixing/
loading/
applying
dip
to
pine
seeds
and
postharvest
pineapples
(
no
surrogate
available).

2.1.5
Recommendations
for
Refining
Occupational
Handler
Risk
Assessment
In
order
to
refine
this
occupational
risk
assessment,
data
on
actual
use
patterns
including
rates,
timing,
and
areas
treated
would
better
characterize
triadimefon
risks.
Exposure
studies
for
many
equipment
types
that
lack
data
or
that
are
not
well
represented
in
PHED
(
e.
g.,
because
of
low
replicate
numbers
or
data
quality)
should
also
be
considered
based
on
the
data
gaps
identified
above
and
based
on
a
review
of
the
quality
of
the
data
used
in
this
assessment.
Page
82
of
114
2.2
Occupational
Postapplication
Exposures
and
Risks
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
(
also
referred
to
as
reentry
exposure).
HED
believes
that
there
are
distinct
job
functions
or
tasks
related
to
the
kinds
of
activities
that
occur
in
previously
treated
areas.
Job
requirements
(
e.
g.,
the
kinds
of
jobs
to
cultivate
a
crop),
the
nature
of
the
crop
or
target
that
was
treated,
and
how
the
chemical
residues
degrade
in
the
environment
can
cause
exposure
levels
to
differ
over
time.
Each
factor
has
been
considered
in
this
assessment.

2.2.1
Occupational
Postapplication
Exposure
Scenarios
Triadimefon
can
be
used
on
agricultural
crops
(
ornamental,
and
turf)
and
in
outdoor
occupational
settings.
As
a
result,
a
wide
array
of
individuals
can
potentially
be
exposed
by
working
in
areas
that
have
been
previously
treated.
HED
is
concerned
about
the
kinds
of
exposures
one
could
receive
in
the
workplace.
Triadimefon
is
applied
to
the
following
crops
that
are
subject
to
the
Worker
Protection
Standard
for
Agricultural
Pesticides:

 
grapes,
 
turf,
including
sod
farm
turf
 
ornamentals,
 
apples,
 
pears,
 
Christmas
trees,
and
 
raspberries.

HED
uses
a
concept
known
as
the
transfer
coefficient
to
numerically
represent
the
postapplication
exposures
one
would
receive
(
generally
presented
as
cm2/
hour).
The
transfer
coefficient
concept
has
been
established
in
the
scientific
literature
and
through
various
exposure
monitoring
guidelines
published
by
the
U.
S.
EPA
and
international
organizations
such
as
Health
Canada
and
the
Organization
for
Economic
Cooperation
and
Development.
The
establishment
of
transfer
coefficients
also
forms
the
basis
of
the
work
of
the
Agricultural
Reentry
Task
Force.
A
transfer
coefficient
is
a
measure
of
the
residue
transferred
from
a
treated
surface
to
a
person
who
is
doing
a
task
or
activity
in
a
treated
area.
These
values
are
the
ratio
of
an
exposure
for
a
given
task
or
activity
to
the
amount
of
pesticide
residue
on
treated
surfaces
available
for
transfer.
HED
has
developed
a
series
of
standard
transfer
coefficients
that
are
unique
for
variety
of
job
tasks
or
activities
that
are
used
in
lieu
of
chemical­
and
scenario­
specific
data.

To
develop
a
postapplication
assessment,
HED
considers
the
types
of
tasks
and
activities
that
individuals
are
likely
to
be
doing
in
areas
recently
treated
with
a
pesticide.
For
consistency
within
postapplication
assessments,
HED
has
developed
a
list
of
tasks
commonly
associated
with
specific
crops
or
use­
patterns,
which
are
likely
to
result
in
postapplication
exposures.
Postapplication
pesticide
exposures
that
result
from
an
individual's
employment
are
considered
occupational
exposures.
Common
examples
include:
crop
harvesting
tasks
(
e.
g.,
harvesting
treated
turf),
crop
maintenance
tasks
(
e.
g.,
irrigating,
weeding,
and
mowing),
and
crop
advisor
tasks
(
e.
g.,
scouting).
Page
83
of
114
HED
considers
how
and
when
a
pesticide
is
applied
to
estimate
the
level
of
transferable
residues
to
which
individuals
could
be
exposed
over
time.
Label
directions
and
other
use
data
are
considered
to
determine
application
rates
and
application
frequency.
HED
completes
postapplication
risk
assessments
using
maximum
application
rates
for
each
scenario.
When
postapplication
risks
are
a
concern
using
maximum
application
rates,
HED
may
also
consider
typical
application
rates
or
application
frequency,
to
further
evaluate
the
overall
risks
associated
with
the
use
of
the
pesticide.
To
estimate
the
amount
of
transferable
residues
on
a
treated
surface,
HED
uses,
when
possible,
chemical­
and
crop­
specific
studies
as
described
in
HED
guidelines
for
exposure
data
collection
(
Series
875,
Occupational
and
Residential
Exposure
Test
Guidelines:
Group
B
­
Postapplication
Exposure
Monitoring
Test
Guidelines).
For
postapplication
exposures,
unique
techniques
are
used
to
measure
the
amount
of
pesticide
residue
on
a
treated
surface
available
for
possible
transfer.
These
techniques
are
distinct
from
those
which
measure
total
pesticide
residue
on
a
treated
surface
and
absorbed
into
a
treated
entity.
When
appropriate
chemical­
and
crop­
specific
transferable
residue
data
are
unavailable,
HED
also
has
developed
a
standard
modeling
approach
to
predict
transferable
residues
over
time
(
best
described
in
HED's
SOPs
for
Residential
Exposure
Assessment).
All
triadimefon
agricultural
occupational
postapplication
scenarios
were
evaluated
using
HED's
default
assumptions
that
20
percent
of
the
initial
application
is
available
for
transfer
on
day
0
(
i.
e.,
12
hours
after
application)
and
that
the
residue
dissipates
at
a
rate
of
10
percent
per
day.
All
lawn
and
turf
occupational
postapplication
scenarios
were
evaluated
using
HED's
default
assumptions
that
5
percent
of
the
initial
application
is
available
for
transfer
on
day
0
(
i.
e.,
12
hours
after
application)
and
that
the
residue
dissipates
at
a
rate
of
10
percent
per
day.

HED
also
must
consider
the
likely
frequency
and
duration
of
postapplication
occupational
exposures
to
triadimefon.
Short­
term
(<
30
days)
always
are
considered
in
these
assessments.
Intermediate­
term
(
greater
than
30
days
to
several
months)
exposure
durations
are
appropriate
for
postapplication
occupational
exposures
scenarios
where
the
pesticide
is
reapplied
several
times
over
a
growing
season,
or
the
pesticide
residues
persist
for
relatively
long
periods
of
time,
or
the
crop
or
use­
pattern
is
such
that
occupational
postapplication
workers
may
be
exposed
to
several
different
treated
areas
in
the
course
of
their
work.
For
example,
migrant
and
seasonal
workers
may
move
from
farm
to
farm
and
be
exposed
several
weeks
to
several
months
or
different
fields
or
greenhouses
on
an
individual
establishment
may
be
treated
over
a
period
of
weeks
due
to
differing
levels
of
infestation
or
staggered
crop
cycles.
For
triadimefon,
the
exposure
durations
for
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
triadimefon
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
are
not
considered
in
this
assessment.
Page
84
of
114
In
agricultural
crop
settings,
the
use
of
personal
protective
equipment
or
other
types
of
equipment
to
mitigate
postapplication
exposures
to
workers
is
not
considered
a
viable
alternative
for
the
regulatory
process.
This
is
described
in
some
detail
in
the
WPS.
Instead,
an
administrative
approach
 
a
Restricted
Entry
Interval
or
REI
 
is
used
to
mitigate
postapplication
risks
following
applications
to
crops.
The
REI
is
time
period
following
a
pesticide
application
during
which
entry
into
the
treated
area
is
restricted.
Postapplication
risk
levels
are
generally
calculated
in
the
risk
assessment
process
on
a
chemical­,
crop­,
and
activity­
specific
basis.
To
establish
REIs,
HED
considers
postapplication
risks
on
varying
days
after
application.

HED
has
used
the
basic
approach
described
above
since
the
mid
1980s
for
calculating
postapplication
risks
to
pesticides.
From
that
time
to
the
present,
several
revisions
and
modifications
were
made
to
Agency
policies
as
data,
which
warranted
such
changes,
became
available.
In
1995,
the
Agency
issued
a
Data
Call­
In
for
postapplication
agricultural
data
that
prompted
the
formation
of
the
Agricultural
Reentry
Task
Force
(
ARTF).
This
task
force
has
generated
a
number
of
exposure
studies
and
associated
documents
that
are
currently
under
review.
The
work
of
the
ARTF
is
not
yet
complete;
however,
sufficient
data
were
available
from
the
group
that
warranted
a
significant
interim
change
in
Agency
policy
related
to
the
data
which
were
already
available
as
the
efforts
of
the
ARTF
paralleled
a
push
for
tolerance
reassessment
stipulated
by
the
timelines
established
by
FQPA.
As
a
result
of
the
need
for
the
revision
and
using
the
latest
data,
the
Agency
developed
a
revised
policy
on
August
7,
2000
entitled
Policy
003.1
Science
Advisory
Council
for
Exposure
Policy
Regarding
Agricultural
Transfer
Coefficients.
The
revision
to
this
policy
entailed
linking
worker
activities
to
more
specific
crop/
agronomic
groupings
and
making
better
use
of
the
available
occupational
postapplication
exposure
data.
In
the
new
policy,
transfer
coefficients
were
selected
to
represent
the
activities
associated
with
18
distinct
crop/
agronomic
groupings
based
on
different
types
of
vegetables,
trees,
berries,
vine/
trellis
crops,
turf,
field
crops,
and
bunch/
bundle
crops
(
e.
g.,
tobacco).
Triadimefon
uses
were
identified
in
the
following
crop
groupings
from
the
policy:

 
Flowers,
cut
(
ornamental),
 
Tree,
fruit,
evergreen,
 
Tree,
fruit,
deciduous,
 
Turf/
sod,
and
 
Vine/
trellis
(
with
and
without
girdling).

Within
each
agronomic
group,
a
variety
of
cultural
practices
are
required
to
maintain
the
included
crops.
These
practices
are
varied
and
typically
involve
light
to
heavy
contact
with
immature
plants
as
well
as
with
more
mature
plants.
HED
selected
transfer
coefficient
values
in
its
revision
of
Policy
003
to
represent
this
range
of
exposures
within
each
agronomic
group.
In
the
policy,
transfer
coefficients
were
placed
in
1
of
5
generic
categories
based
on
the
exposures
relative
to
that
group.
These
5
categories
include:
very
low
exposure,
low
exposure,
medium
exposure,
high
exposure,
and
very
high
exposure.
Numerical
values
were
not
necessarily
assigned
to
each
category
for
each
crop
group.
Selections
depended
upon
the
actual
agronomic
practices
that
were
identified
for
each
group
(
i.
e.,
some
groups
had
2
assigned
transfer
coefficients
while
others
had
5).
The
transfer
coefficient
values
which
have
been
used
are
excerpted
directly
from
Agency
policy
003.
[
The
nursery
crop
group
data
have
not
yet
been
Page
85
of
114
formally
included
in
EPA
Policy
3.
However,
the
studies
in
this
area
submitted
by
ARTF
have
been
reviewed
and
used
since
they
will
be
integrated
into
Policy
3.]

2.2.2
Data/
Assumptions
for
Postapplication
Exposure
Scenarios
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
occupational
postapplication
worker
risk
assessments.
Each
assumption
and
factor
is
detailed
below
on
an
individual
basis.
In
addition
to
these
values,
transfer
coefficient
values
were
used
to
calculate
risk
estimates.
The
transfer
coefficients
were
taken
from
HED's
revised
policy
entitled
Policy
003.1
Science
Advisory
Council
for
Exposure
Policy
Regarding
Agricultural
Transfer
Coefficients
(
August
7,
2000).
The
assumptions
and
factors
used
in
the
risk
calculations
are
presented
below:

 
There
are
many
factors
that
are
common
to
handler
and
postapplication
risk
assessments
such
as
body
weights,
duration,
and
application
rates.
See
Section
2.1.1.1
for
these
values.
In
the
postapplication
risk
assessment,
maximum
application
rates
were
considered.

 
Levels
of
Concern:
HED
has
established
levels
of
concern
(
LOC)
for
occupational
postapplication
risks
 
margins
of
exposure
of
less
than
1000
for
occupational
dermal
and
inhalation
risks
are
a
concern.

 
Turf
Transferable
Residues:
Triadimefon­
specific
turf
transferable
residue
(
TTR)
data
were
available;
however,
the
TTR
data
were
developed
concurrently
with
transfer
coefficients
for
high­
contact
dermal
activities.
The
TTR
data
could
not
be
used
with
HED's
default
transfer
coefficients
for
postapplication
occupational
exposures
to
treated
turf,
since
at
one
of
the
sites
the
day
zero
TTR
values
were
below
the
required
one
to
five
percent
necessary
for
use
with
current
transfer
coefficients.
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.

 
Dislodgeable
Foliar
Residues:
No
triadimefon­
specific
dislodgeable
foliar
residue
(
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.

 
Exposures
were
calculated
to
reflect
default
TTR
and
DFR
values
over
time
coupled
with
surrogate
transfer
coefficients
as
outlined
in
HED's
revised
policy.

2.2.3
Occupational
Postapplication
Exposure
and
Noncancer
Risk
Estimates
Occupational
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
triadimefon
residues
eventually
dissipate
in
the
environment.
As
a
result,
risks
Page
86
of
114
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
(
See
Section
2.1.3).
These
calculations
are
completed
for
each
day
or
appropriate
block
of
time
after
application.

Risk
Summary
A
summary
of
the
postapplication
risks
are
provided
in
Table
11.
The
occupational
postapplication
exposure
and
risk
assessment
for
agricultural
crop
uses
of
triadimefon
indicates
that
risks
are
not
a
concern
at
day
0
(
i.
e.,
12
hours
after
application)
for
all
crops
and
all
postapplication
activities.

Table
11.
Summary
of
Triadimefon
Occupational
Postapplication
Risks
Crop
Crop
Grouping
Application
rate
(
lb
ai/
acre)
Transfer
Coefficient
DAT
a
MOE
at
Day
0
3000
(
Thinning)
12
hours
1300
1500
(
Harvest
(
hand),
Propping,
Pruning
(
hand),
Training,
Tying)
12
hours
2700
Apples
Tree,
fruit,
deciduous
0.25
1000
(
Scouting,
Weeding
(
hand),
Irrigation)
12
hours
4000
Page
87
of
114
Table
11.
Summary
of
Triadimefon
Occupational
Postapplication
Risks
Crop
Crop
Grouping
Application
rate
(
lb
ai/
acre)
Transfer
Coefficient
DAT
a
MOE
at
Day
0
Apples
(
cont.)
Tree,
fruit,
deciduous
0.25
100
(
Propping)
12
hours
40000
8000
(
Hand
Labor
(
misc.),
Harvest
(
hand),
Staking,
Training,
Thinning,
Tying)
12
hours
500
3000
(
Pruning
(
cones),
Pruning
(
hand),
Thinning,
Seed
Cone
Harvesting)
12
hours
1300
1000
(
Irrigation,
Scouting,
Weeding
(
hand),
Thinning)
12
hours
4000
Christmas
trees
Tree,
fruit,
evergreen
0.25
100
(
Propping)
12
hours
40000
5000
(
Harvest
(
hand),
Pruning
(
hand),
Training,
Tying,
Thinning,
Leaf
Pulling)
12
hours
1100
1000
(
Scouting,
Training,
Tying)
12
hours
5300
Grapes
(
juice
and
wine)
0.188
500
(
Irrigation,
Weeding
(
hand),
Scouting,
Hedging)
12
hours
11000
10000
(
Girdling,
Cane
turning),
Cane
Tying
12
hours
530
5000
(
Harvest
(
hand),
Pruning
(
hand),
Training,
Tying,
Thinning,
Leaf
Pulling)
12
hours
1100
1000
(
Scouting,
Training,
Tying)
12
hours
5300
Grapes
(
table
and
raisin)
Vine/
trellis
(
with
and
without
girdling)

0.188
500
(
Irrigation,
Weeding
(
hand),
Scouting,
Hedging)
12
hours
11000
5100
(
cut
flowers
and
foliage)
12
hours
790
Ornamental
flowers
Flowers,
cut
(
ornamental)
0.25
400
(
all
other
nursery
crops)
12
hours
10000
3000
(
Thinning)
12
hours
1300
1500
(
Harvest
(
hand),
Propping,
Pruning
(
hand),
Training,
Tying)
12
hours
2700
1000
(
Scouting,
Weeding
(
hand),
Irrigation)
12
hours
4000
Pears
Tree,
fruit,
deciduous
0.25
100
(
Propping)
12
hours
40000
Page
88
of
114
Table
11.
Summary
of
Triadimefon
Occupational
Postapplication
Risks
Crop
Crop
Grouping
Application
rate
(
lb
ai/
acre)
Transfer
Coefficient
DAT
a
MOE
at
Day
0
5000
(
Harvest
(
hand),
Pruning
(
hand),
Training,
Tying,
Thinning,
Leaf
Pulling)
12
hours
1600
1000
(
Scouting,
Training,
Tying)
12
hours
8000
Raspberries
Vine/
trellis
(
with
and
without
girdling).
0.125
500
(
Irrigation,
Weeding
(
hand),
Scouting,
Hedging)
12
hours
16000
6800
(
Transplanting,
Weeding
(
hand),
Harvest
(
hand),
Harvest
(
mechanical))
12
hours
110
5.4
(
CA
only)
3800
(
Mowing)
12
hours
200
6800
(
Transplanting,
Weeding
(
hand),
Harvest
(
hand),
Harvest
(
mechanical))
12
hours
220
Sod
Farms
and
Golf
Course
Turf
Turf/
sod
2.7
(
other
than
CA)
3800
(
Mowing)
12
hours
390
a
DAT
is
"
days
after
treatment"

2.2.4
Occupational
Postapplication
Exposure
and
Risk
Estimates
for
Cancer
Since
no
toxicological
endpoint
of
concern
was
identified
for
cancer,
cancer
risks
from
occupational
postapplication
exposures
were
not
assessed.

2.2.5
Summary
of
Occupational
Postapplication
Risk
Concerns
and
Data
Gaps
HED
has
used
the
most
up­
to­
date
information
available
to
complete
this
postapplication
risk
assessment
for
triadimefon.
Several
data
gaps
exist,
such
as
a
lack
of
triadimefon­
specific
postapplication
studies
and
lack
of
transfer
coefficients
for
certain
crop
activities.

2.2.6
Recommendations
for
Refining
Occupational
Postapplication
Risk
Assessment
To
refine
this
occupational
risk
assessment,
data
on
actual
use
patterns
including
rates,
timing,
and
the
kinds
of
tasks
that
are
required
to
produce
agricultural
commodities
and
other
products
would
better
characterize
triadimefon
risks.
In
addition,
triadimefon­
specific
TTR
or
DFR
data
could
refine
exposure
and
risk
estimates.
Exposure
studies
for
many
cultural
practices
that
lack
data
or
that
are
not
well
represented
in
the
revised
transfer
coefficient
policy
should
also
be
considered
based
on
the
data
gaps
identified
above.

3.0
Residential
and
Other
Non­
Occupational
Exposures
and
Risks
Page
89
of
114
It
has
been
determined
there
is
a
potential
for
exposure
in
residential
settings
during
the
application
process
for
homeowners
who
use
products
containing
triadimefon.
There
is
also
a
potential
for
exposure
from
entering
triadimefon­
treated
areas,
such
as
lawns,
golf
courses,
and
home
gardens
that
could
lead
to
exposures
to
adults
and
children.
Risk
assessments
have
been
completed
for
both
residential
handler
and
postapplication
scenarios.

3.1
Residential
Handler
Exposures
and
Risks
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
Handler
Exposure
Scenarios
Scenarios
are
used
to
define
risks
based
on
the
U.
S.
EPA
Guidelines
for
Exposure
Assessment
(
U.
S.
EPA;
Federal
Register
Volume
57,
Number
104;
May
29,
1992).
Assessing
exposures
and
risks
resulting
from
residential
uses
is
very
similar
to
assessing
occupational
exposures
and
risks,
with
the
following
exceptions:

 
Residential
handler
exposure
scenarios
are
considered
to
be
short­
term
only,
due
to
the
infrequent
use
patterns
associated
with
homeowner
products.

 
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.

 
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.

 
Label
use­
rates
and
use­
information
specific
to
residential
products
serve
as
the
basis
for
the
risk
calculations.

 
Area/
volumes
of
spray
or
chemical
used
in
the
risk
assessment
are
based
on
HED's
guidance
specific
to
residential
use­
patterns.

It
has
been
determined
that
exposure
to
pesticide
handlers
is
likely
during
the
residential
use
of
triadimefon
in
a
variety
of
outdoor
environments,
including
on
lawns,
gardens,
and
ornamentals.
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
triadimefon
applications.
The
quantitative
exposure/
risk
assessment
developed
for
residential
handlers
is
based
on
these
scenarios.
Page
90
of
114
Mixer/
Loader/
Applicators:
(
1)
Liquid
Formulations:
Low
Pressure
Handwand
(
ORETF
data
for
fruit
trees
and
ornamentals)
(
2)
Wettable
Powder
Formulations:
Low
Pressure
Handwand
(
PHED
data)
(
3)
Liquid
Concentrates
with
Hose­
End
Sprayer
(
Residential
ORETF
data
­­
fruit
trees
and
ornamental
shrubs)
(
4)
Liquid
Concentrates
with
Hose­
End
Sprayer
(
Residential
ORETF
data
 
gardens)
(
5)
Liquid
Concentrates
with
Hose­
End
Sprayer
(
Residential
ORETF
data
 
turf)
(
6)
Wettable
Powders
with
Hose­
End
Sprayer
(
Residential
ORETF
data
­­
liquid
concentrate
application
to
fruit
trees
and
ornamentals)
(
7)
Wettable
Powders
with
Hose­
End
Sprayer
(
Residential
ORETF
data
­
liquid
concentrates
application)
(
8)
Liquid
Concentrates
with
a
Tree
Injector
(
no
data)
(
9)
Loading/
Applying
Granulars
via
Push
Type
Spreader
(
ORETF
data)
(
10)
Loading/
Applying
Granulars
via
Belly
Grinder
(
PHED
data)

3.1.2
Data
and
Assumptions
for
Handler
Exposure
Scenarios
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
triadimefon.
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.]

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

 
Exposure
factors
used
to
calculate
daily
exposures
to
handlers
were
based
on
applicable
data
if
available.
When
appropriate
data
is
unavailable,
values
from
a
scenario
deemed
similar
might
be
used.

 
HED
always
considers
the
maximum
application
rates
allowed
by
labels
in
its
risk
assessments.
If
additional
information
such
as
average
or
typical
rates
are
available,
these
values
also
may
be
used
to
allow
risk
managers
to
make
a
more
informed
risk
management
decision.
Average/
typical
application
rates
were
not
available
for
residential
scenarios.

 
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
triadimefon
assessment
were
from
the
Health
Effects
Division
Science
Advisory
Committee
Policy
12:
Recommended
Revisions
to
the
Standard
Operating
Procedures
for
Page
91
of
114
Residential
Exposure
Assessment
which
was
completed
on
February
22,
2001,
and
on
professional
judgement.
The
daily
volumes
handled
and
area
treated
used
in
each
residential
scenario
are
provided
in
Table
4.

Residential
Handler
Exposure
Studies:
The
unit
exposure
values
that
were
used
in
this
assessment
were
based
on
the
Outdoor
Residential
Exposure
Task
Force
studies
and
the
Pesticide
Handler
Exposure
Database
(
PHED,
Version
1.1
August
1998)
[
Note:
PHED
and
some
ORETF
studies
are
described
above
in
Section
2.1.1.]

ORETF
Handler
Studies
­­
OMA001­
OMA004
(
MRID
449722­
01)
A
report
was
submitted
by
the
ORETF
(
Outdoor
Residential
Exposure
Task
Force)
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.

Homeowner
Liquid
Applications
with
a
Ready­
to­
use
Hose­
end
Sprayer
and
a
Dial
Type
Hoseend
Sprayer
(
MRID
449722­
01):
A
mixer/
loader/
applicator
study
was
performed
by
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF)
using
diazinon
(
25%
EC)
as
a
surrogate
compound
to
determine
"
generic"
exposures
to
individuals
applying
a
pesticide
to
turf
with
a
garden
hose­
end
sprayer.
Surrogate
chemicals
were
chosen
by
the
Task
Force
for
their
representativeness
based
on
physical
chemical
properties
and
other
factors.
The
study
was
designed
to
simulate
a
typical
application
event
for
a
homeowner
applying
pesticides
to
home
lawns
via
a
hose­
end
sprayer.
Each
replicate
monitored
the
test
subject
treating
5,000
square
feet
of
turf
at
a
nominal
application
rate
of
4
pounds
active
ingredient
per
acre
and
handling
a
total
of
0.5
pounds
active
ingredient
per
replicate.
The
average
time
per
replicate
was
75
minutes.
A
total
of
60
replicates
were
monitored
using
30
test
subjects
(
two
replicates
each).
Thirty
applicator
replicates
were
monitored
using
a
ready­
to­
use
(
RTU)
product
(
Bug­
B­
Gon)
packaged
in
a
32
fl.
oz.
screw­
on
container.
These
containers
were
attached
to
garden
hose­
ends.
An
additional
30
mixer/
loader/
applicator
replicates
were
monitored
using
Diazinon
Plus
also
packaged
in
32
fl.
oz.
plastic
bottles.
This
product
required
the
test
subjects
to
pour
the
product
into
dial­
type
sprayers
(
DTS)
that
were
attached
to
garden
hose­
ends.

Dermal
and
inhalation
exposures
were
monitored
using
passive
dosimetry
(
inner
and
outer
whole
body
dosimeters,
hand
washes,
face/
neck
wipes,
and
personal
inhalation
monitors
with
OVS
tubes).
The
inner
samples
represent
a
single
layer
of
clothing.
Inhalation
exposure
was
calculated
using
an
assumed
respiratory
rate
of
17
liters
per
minute
for
light
work
(
NAFTA,
1999),
the
actual
sampling
time
for
each
individual,
and
the
pump
flow
rate.
No
gloves
were
worn
in
any
replicate.
All
results
were
normalized
for
the
amount
of
active
ingredient
handled.
The
QA/
QC
data
are
within
an
acceptable
range
and
the
study
results
are
corrected
for
field
recoveries.
The
unit
exposure
values
are
presented
below.
[
Note:
All
values
are
geometric
means
as
the
data
were
lognormally
distributed.]
Page
92
of
114
Table
12:
Unit
Exposure
Values
for
Homeowner
Liquid
Applications
with
a
Ready­
touse
Hose­
end
Sprayer
and
a
Dial
Type
Hose­
end
Sprayer
Obtained
From
ORETF
Study
(
MRID
449722­
01)
Total
Dermal
Unit
Exposure1
(
mg/
lb
ai)
Scenario
Monitored
Short
Pants,
Short
Sleeves
Long
Pants,
Short
Sleeves
Long
Pants,
Long
Sleeves
Inhalation
Unit
Exposure1,2
(
µ
g/
lb
ai)
Homeowner
Liquid
Applications
with
a
Dial
Type
Hose­
end
Sprayer
(
Mix­
your­
own)
(
home
lawns)
11
6.2
5.6
17
1
Unit
exposure
values
reported
are
geometric
means.
2
Air
concentration
(
mg/
m3/
lb
ai)
calculated
using
NAFTA
`
99
standard
breathing
rate
of
17
lpm
(
1
m3/
hr).

ORETF
Handler
Studies
­­
OMA005
(
MRID
445185­
01)
A
report
was
submitted
by
the
ORETF
(
Outdoor
Residential
Exposure
Task
Force)
that
presented
data
in
which
the
application
of
various
products
used
on
fruit
trees
and
ornamentals
by
homeowners
was
monitored.
All
of
the
data
submitted
in
this
report
were
completed
in
a
series
of
studies.

Homeowner
Liquid
Applications
to
Fruit
Trees
and
Ornamental
Plants
with
a
Hose­
end
Sprayer
and
a
Low
Pressure
Handwand
(
MRID
445185­
01):
Applications
of
Sevin
Liquid
®
Carbaryl
insecticide
[
RP­
2
liquid
(
21%)]
were
made
by
volunteers
to
two
young
citrus
trees
and
two
shrubs
in
each
replicate
that
was
monitored
in
the
study.
The
test
field
was
located
only
in
Florida.
Twenty
(
20)
replicates
were
monitored
using
hose­
end
sprayer
(
Ortho
®
DIAL
or
Spray
®
hose
end
sprayer),
and
20
replicates
were
monitored
using
hand
held
pump
sprayers
(
low
pressure
handwands).

Each
replicate
opened
the
end­
use
product,
added
it
to
the
hose­
end
sprayer
or
hand
held
pump
and
then
applied
it
to
the
trees
and
shrubs.
After
application
to
two
trees
and
two
shrubs
dosimeters
were
collected.
Inhalation
exposure
was
monitored
with
personal
air
sampling
pumps
with
OVS
tubes
attached
to
the
shirt
collar
in
the
breathing
zone.
Dermal
exposure
was
assessed
by
extraction
of
carbaryl
from
inner
and
outer
100
percent
cotton
dosimeters.
The
inner
and
outer
dosimeters
were
segmented
into:
lower
and
upper
arms,
lower
and
upper
legs,
front
and
back
torso.
No
gloves
were
worn
therefore
hand
exposure
was
assessed
with
400
ml
handwash
with
0.01
percent
Aerosol
OT­
75
sodium
dioctyl
sulfosuccinate
(
OTS).
One
hundred
percent
cotton
handkerchiefs
wetted
with
25
ml
OTS
were
used
to
wipe
face
and
neck
to
determine
exposure.

Field
fortification
recoveries
for
passive
dosimeters
averaged
88.3
percent
for
inner
and
76.2
percent
for
outer
dosimeters.
Face
and
neck
wipe
fortifications
average
82.5
percent.
Handwash
and
inhalation
OVS
tube
field
fortification
averaged
>
90
percent.
Inner
and
outer
dosimeter
and
face
and
neck
wipe
residues
were
adjusted
for
field
fortification
results.
Handwash
and
inhalation
residues
were
not
adjusted.

Laboratory
method
validation
for
each
matrix
fell
within
the
acceptable
range
of
70
to
120
percent.
The
limit
of
quantitation
(
LOQ)
was
1.0
µ
g/
sample
for
all
media
except
the
inhalation
monitors
where
the
LOQ
was
0.01
µ
g/
sample.
The
limit
of
detection
(
LOD)
was
0.5
µ
g/
sample
for
all
media
except
the
inhalation
monitors
where
the
LOQ
was
0.005
µ
g/
sample.
Page
93
of
114
For
use
in
reregistration
documents,
the
dermal
exposure
was
calculated
by
adding
the
values
from
the
hand
rinses,
face/
neck
wipes
to
the
outer
dosimeter
lower
legs
and
lower
arms
plus
the
inner
dosimeter
front
and
rear
torso,
upper
legs
and
upper
arms.
This
accounts
for
the
residential
handler
wearing
short­
sleeved
shirt
and
short
pants.
The
results
for
the
low
pressure
handwand
are
summarized
in
Table
13
below.

The
distribution
of
the
unit
exposure
values
is
categorized
as
normal,
lognormal,
or
"
other"
(
i.
e.,
neither
normal
nor
lognormal).
A
central
tendency
value
is
selected
from
the
distribution
of
the
exposure
values.
These
values
are
the
arithmetic
mean
for
normal
distributions,
the
geometric
mean
for
lognormal
distributions,
and
the
median
for
all
"
other"
distributions.
The
dermal
exposure
had
a
lognormal
distribution
so
the
geometric
mean
value
was
used
to
determine
dermal
exposure.
The
inhalation
exposure
had
neither
a
normal
or
lognormal
distribution
so
the
median
was
used
to
determine
inhalation
exposure.

Table
13:
Unit
Exposure
Values
for
Homeowner
Liquid
Applications
to
Fruit
Trees
and
Ornamental
Plants
with
a
Hose­
end
Sprayer
and
a
Low
Pressure
Handwand
Obtained
From
ORETF
Study
(
MRID
445185­
01)
Total
Dermal
Unit
Exposure1
(
mg/
lb
ai)
Scenario
Monitored
Short
Pants,
Short
Sleeves
Long
Pants,
Short
Sleeves
Long
Pants,
Long
Sleeves
Inhalation
Unit
Exposure2
(
µ
g/
lb
ai)
Homeowner
Liquid
Applications
with
a
Hoseend
Sprayer
39
27
23
1.6
Homeowner
Liquid
Applications
with
a
Hand
Held
Sprayer
(
Low
Pressure
Handwand)
56
36
30
2.6
1
Dermal
unit
exposure
values
reported
are
the
geometric
means.
2
Inhalation
unit
exposure
values
reported
are
the
median
values.

3.1.3
Residential
Handler
Exposure
and
Noncancer
Risk
Estimates
Risks
were
calculated
using
the
Margin
of
Exposure
(
MOE)
as
described
in
Section
2.1.3.
Assessing
exposures
and
risks
resulting
from
residential
uses
is
very
similar
to
assessing
occupational
exposures
and
risks,
except
as
described
in
Section
3.1.1.

Risk
Summary:
The
data
used
by
HED
have
provided
a
basic
broad
overview
of
the
uses
of
triadimefon
around
a
residential
environment
(
i.
e.,
the
database
is
fairly
complete).
As
indicated
above,
however,
it
is
likely
that
triadimefon
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
triadimefon
in
residential
environments.
It
should
also
be
noted
that
there
were
many
other
scenarios
where
medium
to
low
PHED
quality
data
were
used
to
complete
the
assessment.
Data
quality
should
be
considered
in
the
interpretation
of
the
uncertainties
associated
with
each
risk
value
presented.

Short­
term
risks
for
residential
handlers
are
presented
in
Table
14.
Intermediate­
term
exposures
are
not
likely
because
of
the
intermittent
nature
of
applications
by
homeowners.
Inhalation
risks
for
residential
handlers
are
not
a
concern
for
all
residential
uses
of
triadimefon.
Dermal
and
total
risks
for
residential
handlers
are
not
a
concern
for
most
triadimefon
residential
handler
scenarios.
Dermal
and
total
risks
remain
a
concern
(
MOEs
<
1000)
for:
Page
94
of
114
 
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
(
using
ORETF
data)
to
greenhouse
ornamentals
(
trees
and
shrubs)
at
0.00938
lb
ai/
gal
(
MOE
=
490);
 
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
(
using
ORETF
data)
to
greenhouse
ornamentals
(
flowers)
at
0.00938
lb
ai/
gal
(
MOE
=
560);
 
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
(
using
ORETF
data)
to
turf
(
home
lawns)
(
MOE
=
440);
 
mixing/
loading/
applying
wettable
powders
with
hose­
end
sprayer
(
residential
ORETF
data
­­
liquid
concentrate
data)
to
greenhouse
ornamentals
(
trees
and
shrubs)
at
0.00625
lb
ai/
gal
(
MOE
=
740);
and
 
mixing/
loading/
applying
wettable
powders
with
hose­
end
sprayer
(
residential
ORETF
data
­­
liquid
concentrate
data)
to
greenhouse
ornamentals
(
flowers)
at
0.00625
lb
ai/
gal
(
MOE
=
850).
Page
95
of
114
Table
14.
Triadimefon
Residential
Handler
Risks
Baseline
Unit
Exposure
MOEs
Exposure
Scenario
Crop
or
Target
App
Ratea
(
lb
ai/
gallon)
Area
Treated
Dailyb
(
gallons)
Dermalc
(
mg/
lb
ai)
Inhalationd
(
µ
g/
lb
ai)
Baseline
Dermal
Baseline
Inhalation
Baseline
Dermal
+

Baseline
Inhalation
MOE
Mixer/
Loader/
Applicator
greenhouse
ornamentals
(
flowering,

shrubs,
trees)
0.00938
5
56
2.6
6900
2000000
6800
roses
0.00029
5
56
2.6
220000
63000000
220000
turf
(
home
lawns)
0.033
5
56
2.6
1900
550000
1900
Mixing/
Loading/
Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
ORETF­­
fruit
trees
and
ornamentals)
ornamentals
(
flowering,

shrubs,
trees)
0.0023
5
56
2.6
28000
8000000
28000
Mixing/
Loading/
Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
ORETF­­
ground­
directed)
turf
(
home
lawns)
0.033
5
38
2.7
2900
530000
2900
apples,
pears
0.00062
5
250
1063
23000
72000
18000
Mixing/
Loading/
Applying
Wettable
Powders
with
Low
Pressure
Handwand
(
PHED)
azaleas
0.005
5
250
1063
2900
9000
2200
Page
96
of
114
Table
14.
Triadimefon
Residential
Handler
Risks
Baseline
Unit
Exposure
MOEs
Exposure
Scenario
Crop
or
Target
App
Ratea
(
lb
ai/
gallon)
Area
Treated
Dailyb
(
gallons)
Dermalc
(
mg/
lb
ai)
Inhalationd
(
µ
g/
lb
ai)
Baseline
Dermal
Baseline
Inhalation
Baseline
Dermal
+

Baseline
Inhalation
MOE
grapes
0.00094
5
250
1063
15000
48000
12000
greenhouse
ornamentals
(
flowering,

shrubs,
trees)
0.00625
5
250
1063
2300
7200
1700
Mixing/
Loading/
Applying
Wettable
Powders
with
Low
Pressure
Handwand
(
PHED)
(
cont.)
ornamentals
(
flowering,

shrubs,
trees)
0.0025
5
250
1063
5800
18000
4400
greenhouse
ornamentals
(
shrubs,
trees)
0.00938
100
39
1.6
490
160000
490
ornamentals
(
shrubs,
trees)
0.0023
100
39
1.6
2000
650000
2000
pines
0.0023
100
39
1.6
2000
650000
2000
Mixing/
Loading/
Applying
Liquid
Concentrates
with
Hose­
End
Sprayer
(
Residential
ORETF
data
­­

fruit
trees
and
ornamental
shrubs)
roses
0.00029
100
39
1.6
16000
5100000
16000
Page
97
of
114
Table
14.
Triadimefon
Residential
Handler
Risks
Baseline
Unit
Exposure
MOEs
Exposure
Scenario
Crop
or
Target
App
Ratea
(
lb
ai/
gallon)
Area
Treated
Dailyb
(
gallons)
Dermalc
(
mg/
lb
ai)
Inhalationd
(
µ
g/
lb
ai)
Baseline
Dermal
Baseline
Inhalation
Baseline
Dermal
+

Baseline
Inhalation
MOE
greenhouse
ornamentals
(
flowering)
0.00938
100
34
0.82
560
310000
560
Mixing/
Loading/
Applying
Liquid
Concentrates
with
Hose­
End
Sprayer
(
Residential
ORETF
data
for
gardens)
ornamentals
(
flowering)
0.0023
100
34
0.82
2300
1300000
2300
Mixing/
Loading/
Applying
Liquid
Concentrates
with
Hose­
End
Sprayer
(
Residential
ORETF
data
for
home
lawns)
turf
(
home
lawns)
0.033
100
11
17
500
4200
440
apples,
pears
0.00062
100
39
1.6
7400
2400000
7400
grapes
0.00094
100
39
1.6
4900
1600000
4900
Mixing/
Loading/
Applying
Wettable
Powders
with
Hose­
End
Sprayer
(
Residential
ORETF
data
­­

liquid
concentrate
application
to
fruit
trees
and
ornamentals)
greenhouse
ornamentals
(
shrubs,
trees)
0.00625
100
39
1.6
740
240000
740
Page
98
of
114
Table
14.
Triadimefon
Residential
Handler
Risks
Baseline
Unit
Exposure
MOEs
Exposure
Scenario
Crop
or
Target
App
Ratea
(
lb
ai/
gallon)
Area
Treated
Dailyb
(
gallons)
Dermalc
(
mg/
lb
ai)
Inhalationd
(
µ
g/
lb
ai)
Baseline
Dermal
Baseline
Inhalation
Baseline
Dermal
+

Baseline
Inhalation
MOE
Mixing/
Loading/
Applying
Wettable
Powders
with
Hose­
End
Sprayer
(
Residential
ORETF
data
­­

liquid
concentrate
application
to
fruit
trees
and
ornamentals)
(
cont.)
ornamentals
(
shrubs,
trees)
0.0025
100
39
1.6
1800
600000
1800
azaleas
0.005
100
34
0.82
1100
580000
1100
greenhouse
ornamentals
(
flowering)
0.00625
100
34
0.82
850
460000
850
Mixing/
Loading/
Applying
Wettable
Powders
with
Hose­
End
Sprayer
(
Residential
ORETF
data
liquid
concentrate
for
gardens)
ornamentals
(
flowering)
0.0025
100
34
0.82
2100
1200000
2100
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Tree
Injector
(
no
data)
Ornamentals
(
shade
trees,

woody
shrubs)
0.000026
lb
ai/
inch
of
trunk
inches
of
trunk
No
Data
No
Data
No
Data
No
Data
No
Data
Page
99
of
114
Table
14.
Triadimefon
Residential
Handler
Risks
Baseline
Unit
Exposure
MOEs
Exposure
Scenario
Crop
or
Target
App
Ratea
(
lb
ai/
gallon)
Area
Treated
Dailyb
(
gallons)
Dermalc
(
mg/
lb
ai)
Inhalationd
(
µ
g/
lb
ai)
Baseline
Dermal
Baseline
Inhalation
Baseline
Dermal
+

Baseline
Inhalation
MOE
turf
5.2
lb
ai/
acre
(
CA
only)
0.5
acres
0.67
0.88
10000
100000
9400
turf
2.7
lb
ai/
acre
(
except
CA)
0.5
acres
0.67
0.88
20000
200000
18000
Loading/
Applying
Granulars
via
Push
Type
Spreader
(
ORETF
data)
turf
1.3
lb
ai/
acre
(
Bayer
max
residential
rate)
0.5
acres
0.67
0.88
41000
420000
38000
turf
0.00012
lb
ai/
ft2
(
CA
only)
1000
ft2
110
62
1400
32000
1300
turf
0.00006
lb
ai/
ft2
(
except
CA)
1000
ft2
110
62
2600
62000
2500
Loading/
Applying
Granulars
via
Belly
Grinder
(
PHED
data)
turf
0.00003
lb
ai/
ft2
(
Bayer
max
residential
rate)
1000
ft2
110
62
5500
130000
5300
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
triadimefon
b
Amount
handled
per
day
values
are
HED
estimates
of
acres,
square
feet,
or
cubic
feet
treated
or
gallons
applied
based
on
Exposure
SAC
SOP
#
9
"
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,"
industry
sources,
and
HED
estimates.

c
Baseline
Dermal:
Long­
sleeve
shirt,
long
pants,
no
gloves.

d
Baseline
Inhalation:
no
respirator.
Page
100
of
114
3.1.4
Residential
Handler
Exposure
and
Risk
Estimates
for
Cancer
Residential
handler
cancer
risks
are
not
assessed,
since
no
toxicological
endpoint
of
concern
for
cancer
was
selected.

3.1.5
Summary
of
Risk
Concerns
and
Data
Gaps
for
Handlers
Generally,
risks
(
i.
e.,
MOEs)
associated
with
most
scenarios
are
not
of
concern,
because
they
exceed
HED's
uncertainty
factor
of
1000.
Inhalation
risks
for
residential
handlers
are
not
a
concern
for
all
residential
uses
of
triadimefon.
Dermal
and
total
risks
for
residential
handlers
are
not
a
concern
for
most
triadimefon
residential
handler
scenarios.
Dermal
and
total
risks
remain
a
concern
(
MOEs
<
1000)
for:

 
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
(
using
ORETF
data)
to
greenhouse
ornamentals
(
trees
and
shrubs)
at
0.00938
lb
ai/
gal
(
MOE
=
490);
 
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
(
using
ORETF
data)
to
greenhouse
ornamentals
(
flowers)
)
at
0.00938
lb
ai/
gal
(
MOE
=
560);
 
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
(
using
ORETF
data)
to
turf
(
home
lawns)
(
MOE
=
440);
 
mixing/
loading/
applying
wettable
powders
with
hose­
end
sprayer
(
residential
ORETF
data
­­
liquid
concentrate
data)
to
greenhouse
ornamentals
(
trees
and
shrubs)
at
0.00625
lb
ai/
gal
(
MOE
=
740);
and
 
mixing/
loading/
applying
wettable
powders
with
hose­
end
sprayer
(
residential
ORETF
data
­­
liquid
concentrate
data)
to
greenhouse
ornamentals
(
flowers)
at
0.00625
lb
ai/
gal
(
MOE
=
850).
Page
101
of
114
The
key
data
gaps
identified
by
HED
for
residential
handlers
are:
 
mixing/
loading/
applying
liquids
with
an
injector
­­
HED
has
no
data
for
this
scenario
and
is
not
aware
of
any
surrogate
data
that
could
be
applied
to
this
scenario;
and
 
mixing/
loading/
applying
wettable
powders
with
hose­
end
sprayer
 
HED
used
data
for
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
(
ORETF
data)
as
a
surrogate;
however
this
likely
underestimates
risks.

3.1.6
Recommendations
for
Refining
Residential
Handler
Risk
Assessment
In
order
to
refine
this
residential
risk
assessment,
more
data
on
actual
use
patterns
including
rates,
timing,
and
areas
treated
would
better
characterize
triadimefon
risks.
Exposure
studies
for
many
equipment
types
that
lack
data
or
that
are
not
well
represented
in
PHED
(
e.
g.,
because
of
low
replicate
numbers
or
data
quality)
should
also
be
considered
based
on
the
data
gaps
identified
above
and
based
on
a
review
of
the
quality
of
the
data
used
in
this
assessment.

3.2
Residential
Postapplication
Exposures
and
Risks
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.
Triadimefon
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.

3.2.1
Residential
Postapplication
Exposure
Scenarios
A
wide
array
of
individuals
of
varying
ages
can
potentially
be
exposed
to
triadimefon
when
they
are
in
areas
that
have
been
previously
treated.
Postapplication
exposure
scenarios
were
developed
for
each
residential
setting
where
triadimefon
can
be
used.
Assessing
postapplication
exposures
and
risks
resulting
from
residential
uses
is
very
similar
to
assessing
occupational
postapplication
exposures
and
risks
(
Section
2.2),
except
in
residential
assessments:

 
exposures
were
calculated
for
children
of
differing
ages
as
well
as
adults
and
 
non­
dietary
ingestion
exposures
to
toddlers
were
calculated
(
i.
e.,
soil
ingestion,
hand­
/
object­
to­
mouth).

HED
relies
on
a
standardized
approach
for
completing
residential
risk
assessments
that
is
based
on
current
triadimefon
labels
and
guidance
contained
in
the
following
five
documents:

 
Series
875,
Residential
and
Residential
Exposure
Test
Guidelines:
Group
B
­
Postapplication
Exposure
Monitoring
Test
Guidelines
(
V
5.4,
Feb.
1998):
This
document
provides
general
risk
assessment
guidance
and
criteria
for
analysis
of
residue
dissipation
data.

 
Standard
Operating
Procedures
for
Residential
Exposure
Assessment
(
Dec.
1997):
This
document
provides
the
overarching
guidance
for
developing
residential
risk
assessments
Page
102
of
114
including
scenario
development,
algorithms,
and
values
for
inputs.

 
Science
Advisory
Council
for
Exposure
Policy
003.1
(
Aug.
2000):
Agricultural
Transfer
Coefficients:
This
document
provides
transfer
coefficients
which
have
been
used
to
assess
exposures
in
home
gardens.

 
Science
Advisory
Council
for
Exposure
Policy
12
(
Feb.
2001):
Recommended
Revisions
To
The
Standard
Operating
Procedures
(
SOPs)
For
Residential
Exposure
Assessment:
This
document
provides
additional,
revised
guidance
for
completing
residential
exposure
assessments.

 
Overview
of
Issues
Related
to
the
Standard
Operating
Procedures
for
Residential
Exposure
Assessment
(
August
1999
Presentation
To
The
FIFRA
SAP):
This
document
provides
rationale
for
Agency
changes
in
SOPs.

When
the
guidance
in
current
labels
and
these
documents
is
considered,
it
is
clear
that
HED
should
consider
children
of
differing
ages
as
well
as
adults
in
its
assessments.
It
is
also
clear
that
different
age
groups
should
be
considered
in
different
situations.
The
populations
that
were
considered
in
the
assessment
include:

 
Residential
Adults:
these
individuals
are
members
of
the
general
population
that
are
exposed
to
chemicals
by
engaging
in
activities
at
their
residences
(
e.
g.,
in
their
lawns
or
gardens)
and
also
in
areas
not
limited
to
their
residence
(
e.
g.,
golf
courses
or
parks)
previously
treated
with
a
pesticide.
These
kinds
of
exposures
are
attributable
to
a
variety
of
activities
and
are
usually
addressed
by
HED
in
risk
assessments
by
considering
a
representative
activity
as
the
basis
for
the
exposure
calculation.

 
Residential
Children:
children
are
members
of
the
general
population
that
can
also
be
exposed
in
their
residences
(
e.
g.,
on
lawns
and
other
residential
turfgrass
areas,
in
gardens,
on
carpets
and
hard
flooring,
or
from
contact
with
treated
pets).
These
kinds
of
exposures
are
attributable
to
a
variety
of
activities
such
as
playing
outside,
home
gardening,
playing
on
carpeting
or
hard
flooring,
and
playing
with
a
companion
animal.
Toddlers
have
been
selected
as
the
sentinel
(
representative)
population
for
turf,
indoor
flooring,
and
companion
animal
assessments.
Youth­
aged
children
(
ages
10
to
12)
are
considered
the
sentinel
population
for
a
gardening
assessment,
because
it
is
likely
that
children
of
this
age
would
help
with
garden
maintenance.
Children
are
addressed
by
HED
in
risk
assessments
by
considering
representative
activities
for
each
age
group
in
an
exposure
calculation.

The
SOPs
for
Residential
Exposure
Assessment
define
several
scenarios
that
apply
to
uses
specified
in
current
labels.
These
scenarios
served
as
the
basis
for
the
residential
postapplication
assessment
along
with
the
modifications
to
them
and
the
additional
data
and
approaches
described
above.
HED
used
this
guidance
to
define
the
exposure
scenarios
that
essentially
include
dermal
and
nondietary
ingestion
exposure
to
toddlers
on
treated
lawns,
dermal
and
nondietary
ingestion
exposure
to
toddlers
on
treated
flooring,
dermal
exposure
to
Page
103
of
114
youths
in
treated
gardens,
dermal
and
nondietary
ingestion
exposure
to
children
from
treated
companion
animals,
and
dermal
exposure
to
adults
in
treated
gardens
and
on
treated
lawns.
The
SOPs
and
the
associated
scenarios
are
presented
below:

 
Dose
from
dermal
exposure
on
treated
lawns:
Postapplication
dermal
dose
calculations
for
toddlers
from
playing
on
treated
turf
and
for
adults
mowing
and
exercising
on
treated
turf;

 
Dose
from
hand­
to­
mouth
activity
from
treated
turf:
Postapplication
dose
calculations
for
toddlers
from
incidental
nondietary
ingestion
of
pesticide
residues
on
treated
turf
from
hand­
to­
mouth
transfer
(
i.
e.,
those
residues
that
are
swallowed
when
toddlers
get
pesticide
residues
on
their
hands
from
touching
treated
turf
and
then
put
their
hands
in
their
mouth);

 
Dose
from
object­
to­
mouth
activity
from
treated
turf:
Postapplication
dose
calculations
for
toddlers
from
incidental
nondietary
ingestion
of
pesticide
residues
on
treated
turf
from
object­
to­
mouth
transfer
(
i.
e.,
those
residues
that
are
swallowed
when
toddlers
put
treated
turf
in
their
mouths);

 
Dose
from
soil
ingestion
activity
from
treated
turf:
Postapplication
dose
calculations
for
toddlers
from
incidental
nondietary
ingestion
of
pesticide
residues
from
ingesting
soil
in
a
treated
turf
area
(
i.
e.,
those
soil
residues
that
are
swallowed
when
toddlers
get
pesticide
residues
on
their
hands
from
touching
treated
soil
and
then
put
their
hands
in
their
mouth);

 
Dose
from
ingestion
of
triadimefon
granules
from
treated
turf:
Postapplication
dose
calculations
for
toddlers
from
episodic
nondietary
ingestion
of
pesticide
granules
picked
up
from
treated
turf
(
i.
e.,
those
residues
that
are
swallowed
when
toddlers
pick
up
granules
from
treated
turf
and
put
the
granules
in
their
mouth);

 
Dose
from
dermal
exposure
while
golfing:
Postapplication
dermal
dose
calculations
for
adults
and
youth­
aged
children
(
ages
10
to
12)
while
golfing.

3.2.2
Data
and
Assumptions
for
Residential
Postapplication
Exposure
Scenarios
Assumptions
and
Exposure
Factors
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
residential
postapplication
risk
assessments.
The
assumptions
and
factors
used
in
the
risk
calculations
are
consistent
with
current
Agency
policy
for
completing
residential
exposure
assessments
(
i.
e.,
SOPs
for
Residential
Exposure
Assessment).
The
values
used
in
this
assessment
include:

 
There
are
many
factors
that
are
common
to
the
occupational
and
residential
Page
104
of
114
postapplication
risk
assessments,
such
as
body
weights
for
adults,
analysis
of
residue
dissipation
data,
and
transfer
coefficients
used
for
the
garden
exposure
scenarios.
Please
refer
to
the
assumptions
and
factors
in
Section
2.1.2
for
further
information
concerning
these
common
values.
 
HED
combines
risks
resulting
from
exposures
to
individual
applications
when
it
is
likely
they
can
occur
simultaneously
based
on
the
use
pattern
and
the
behavior
associated
with
the
exposed
population.
For
triadimefon,
HED
has
combined
risks
(
i.
e.,
MOEs)
for
different
kinds
of
exposures
for
one
scenario:
o
for
turf
scenarios
 
dermal
plus
hand­
to­
mouth
plus
object­
to­
mouth
plus
soil
ingestion
 
Exposures
to
adults
and
children
on
treated
turf
have
been
addressed
using
the
latest
HED
standard
operating
procedures
for
this
scenario
including:
o
For
high­
contact
activities,
TTR
values
for
dermal
exposures
are
from
a
triadimefon­
specific
turf
transferable
residue
study
(
note
the
study
estimated
both
TTR
values
and
transfer
coefficients
for
adults
and
5
year
olds);
o
Dermal
exposures
for
all
remaining
activities
use
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.
o
5
percent
of
the
application
rate
has
been
used
to
calculate
the
day­
zero
TTR
residue
levels
used
for
assessing
risks
from
hand­
to­
mouth
exposures,
since
even
though
triadimefon­
specific
turf
transferable
residue
study
data
are
available,
the
residential
SOPs
indicate
that
the
5
percent
default
should
be
used;
o
20
percent
of
the
application
rate
has
been
used
to
calculate
the
day­
zero
residue
levels
used
for
assessing
risks
from
object­
to­
mouth
behaviors
(
a
higher
percent
transfer
has
been
used
for
object­
to­
mouth
behaviors,
because
it
involves
a
teething
action
believed
to
be
more
analogous
to
DFR/
leaf
wash
sample
collection
where
20
percent
is
also
used);
o
the
transfer
coefficients
used
are
those
presented
during
the
1999
Agency
presentation
before
the
FIFRA
Science
Advisory
Panel
that
have
been
adopted
in
routine
practice
by
HED,
except
the
transfer
coefficient
from
the
triadimefon­
specific
TTR
study
was
used
for
high
contact
dermal
exposures
on
turf;
o
3
year
old
toddlers
are
expected
to
weigh
15
kilograms
(
representing
an
average
weight
from
years
one
to
six);
o
hand­
to­
mouth
exposures
are
based
on
a
frequency
of
20
events/
hour
and
a
surface
area
per
event
of
20
cm2,
representing
the
palmar
surfaces
of
three
fingers;
o
saliva
extraction
efficiency
is
50
percent
meaning
that
every
time
the
hand
goes
in
the
mouth
approximately
½
of
the
residues
on
the
hand
are
removed;
o
object­
to­
mouth
exposures
are
based
on
a
25
cm2
surface
area;
o
exposure
durations
for
turfgrass
scenarios
are
estimated
to
be
2
hours
based
on
information
in
HED's
Exposure
Factors
Handbook;
o
soil
residues
are
contained
in
the
top
centimeter
and
soil
density
is
0.67
mL/
gram;
and
o
dermal,
hand­
and
object­
to­
mouth,
and
soil
ingestion
are
combined
to
Page
105
of
114
represent
an
overall
risk
from
exposure
to
turf,
while
granular
ingestion
is
considered
to
be
a
much
more
episodic
behavior
and
is
considered
separately
by
HED.
 
Exposures
to
children
and
adults
working
in
home
gardens
have
been
addressed
using
the
latest
HED
approaches
for
this
scenario
including:
o
youth­
aged
children
are
considered
along
with
adults;
o
12
year
old
youth
are
expected
to
weigh
39.1
kilograms;
o
exposure
durations
are
expected
to
be
40
minutes
for
adults
and
20
minutes
for
youths;
o
transfer
coefficients
for
youths
were
calculated
by
adjusting
the
appropriate
adult
transfer
coefficients
by
a
50%
factor
as
has
been
done
by
HED
since
the
inception
of
the
SOPs
For
Residential
Exposure
Assessment;
o
transfer
coefficients
for
adults
and
youths
are
from
the
R­
SOPs;
o
the
combination
of
adjusting
transfer
coefficients
for
youth­
aged
children
and
using
appropriate
body
weights
for
the
age
group
results
in
dose
levels
that
are
slightly
lower
than
that
of
adults
in
the
same
activity
(
the
transfer
coefficient
reduction
and
body
weight
reduction
is
essentially
a
1:
1
ratio);
and
o
the
DFR
data
used
for
the
assessments
are
the
default
assumption
that
20
percent
of
the
application
rate
is
available
for
transfer,
since
no
triadimefonspecific
DFR
data
are
available.
 
Postapplication
residential
risks
are
based
on
maximum
application
rates
or
values
specified
in
the
SOPs
for
Residential
Exposure
Assessment.
 
The
Jazzercize
approach
is
the
basis
for
the
dermal
transfer
coefficients
as
described
in
HED's
Series
875
guidelines,
SOPs
for
Residential
Exposure
Assessment,
and
the
1999
FIFRA
SAP
Overview
document.

The
registrant
has
submitted
one
turf
transferable
residue
study
in
support
of
the
reregistration
of
triadimefon,
titled
Evaluation
of
Potential
Exposure
Resulting
from
Contact
with
Bayleton­
Treated
Turf
(
MRID
No.
431254­
01).
This
study
will
be
used
to
assess
postapplication
exposure
and
risk
from
treated
turfgrass
for
high­
contact
activities.
The
study
provides
dermal
exposure
values,
turf
transferable
residue
(
TTR)
values
and
dermal
transfer
factors
measured
and/
or
calculated
after
the
application
of
Bayleton
25
Turf
and
Ornamental
Fungicide
to
turf.
Adult
volunteers
performed
a
20­
minute
Jazzercise
routine
on
the
treated
turf,
after
which
dermal
exposures
were
measured,
and
the
data
also
were
adjusted
to
obtain
surrogate
values
for
10­
year
old
and
5­
year
old
children.
Using
the
dermal
exposures
and
the
TTR
values
measured,
dermal
transfer
factors
(
cm2/
hr)
were
obtained
for
each
population.
The
TTR
value
measured
in
the
study,
as
well
as
the
calculated
dermal
transfer
factors
calculated
for
adults
and
5­
year
olds,
were
used
in
the
assessment
of
postapplication
exposures
from
turf
due
to
high
contact
lawn
activities.
The
TTR
value
provided
in
the
study
was
0.502
ug/
cm2.
This
value
was
adjusted
for
the
difference
in
the
study's
application
rate
(
2.25
lb
ai/
acre)
and
the
maximum
application
rates
in
the
ORE
assessment.
The
dermal
transfer
factors
(
adults:
29,125
cm2/
hr;
toddlers
(
5­
year­
olds):
12,274
cm2/
hr)
calculated
in
the
study
were
used
in
place
of
the
default
Residential
SOP
values
(
adults:
14,500
cm2/
hr;
toddlers:
5,200
cm2/
hr)
for
high
contact
lawn
activities.
The
TTR
study
assumed
that
a
typical
5­
year­
old
child
would
weigh
18.7
kilograms.
In
order
to
combine
incidental
oral
and
dermal
risks
to
toddlers,
the
incidental
oral
risks
were
calculated
using
the
18.7
kilograms
for
a
5­
year­
old
child,
rather
than
the
usual
15
kilograms
for
a
3­
year­
old
child
as
Page
106
of
114
assumed
in
the
Standard
Operating
Procedures
for
Residential
Assessments.

3.2.3
Residential
Postapplication
Exposure
and
Noncancer
Risk
Estimates
Risks
were
calculated
using
the
Margin
of
Exposure
(
MOE)
approach,
which
is
a
ratio
of
the
body
burden
to
the
toxicological
endpoint
of
concern.
Exposures
were
calculated
by
considering
the
potential
sources
of
exposure
(
i.
e.,
DFRs
on
ornamental
plants
and
TTRs
on
lawns),
then
calculating
dermal
and
nondietary
ingestion
exposures.

Dermal
exposures
and
risks
from
lawn,
garden,
and
golf
course
turfgrass
uses
were
calculated
in
the
same
manner
as
described
above
in
Section
2.2.3.
Along
with
calculating
these
dermal
exposures,
other
aspects
of
the
turf
exposure
scenario
involved
calculating
dose
from
non­
dietary
ingestion.
The
algorithms
used
for
each
type
of
calculation
are
presented
below
which
have
not
been
previously
addressed
in
Section
2.2.3.

Dermal
Exposure
from
Treated
Lawns
(
adult
and
toddler)

The
approach
used
to
calculate
the
dermal
exposures
that
are
attributable
to
exposure
from
contacting
treated
lawns
is:

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;
DA
=
dermal
absorption
factor
(
100%);
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
(
70
kg
for
adults
and
18.7
kg
for
toddlers).

Hand­
to­
mouth
Transfer
of
Pesticide
Residues
on
Lawns
(
toddler)

The
approach
used
to
calculate
the
nondietary
ingestion
exposures
that
are
attributable
to
handto
mouth
behavior
on
treated
turf
is:

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);
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
Page
107
of
114
exposure
(
0.001
mg/
µ
g);
and
BW
=
body
weight
(
18.7
kg).

Object­
to­
mouth
Transfer
of
Pesticide
Residues
on
Lawns
(
toddler)

The
approach
used
to
calculate
exposures
that
are
attributable
to
object­
to­
mouth
behavior
on
treated
turf
that
is
represented
by
a
child
mouthing
on
a
handful
of
turf
is:

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
(
25
cm2/
day);
CF1
=
weight
unit
conversion
factor
to
convert
the
ug
of
residues
on
the
grass
to
mg
to
provide
units
of
mg/
day
(
1E­
3
mg/
ug);
and
BW
=
body
weight
(
18.7
kg).

Incidental
Ingestion
of
Soil
from
Pesticide­
Treated
Residential
Areas
(
toddler)

The
approach
used
to
calculate
exposures
that
are
attributable
to
soil
ingestion
is:

ADD
=
(
SR0
*
IgR
*
CF1)
/
BW
Where:

ADD
=
average
daily
dose
(
mg/
kg/
day);
SR0
=
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
ug
of
residues
on
the
soil
to
grams
to
provide
units
of
mg/
day
(
1E­
6
g/
µ
g);
and
BW
=
body
weight
(
18.7
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).

Incidental
Ingestion
of
Granules
from
Pesticide­
Treated
Residential
Areas
(
toddler)

The
approach
used
to
calculate
exposures
that
are
attributable
to
granule
ingestion
is:

ADD
=
(
IgR
*
F
*
CF1)/
BW
Where:
Page
108
of
114
ADD
=
average
daily
dose
(
mg/
kg/
day);
IgR
=
ingestion
rate
of
soil
(
0.3
g/
day);
F
=
fraction
of
ai
in
dry
formulation
(
unitless);
CF1
=
weight
unit
conversion
factor
to
convert
the
g
units
in
the
ingestion
rate
value
to
mg
for
the
daily
exposure
(
1000
mg/
g);
and
BW
=
body
weight
(
18.7
kg).

Dermal
Exposure
from
Treated
Ornamental
Gardens
(
adult
and
youth)

The
approach
used
to
calculate
the
dermal
exposures
that
are
attributable
to
exposure
from
contacting
treated
gardens
is:

ADD
=
(
DFR0
*
ET
*
TC
*
CF1)
/
BW
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
DFRt
=
dislodgeable
foliar
residue
on
day
"
0"
ug/
cm2);
ET
=
exposure
time
(
0.67
hr/
day
for
adults
and
0.33
hr/
day
for
youths);
TC
=
transfer
coefficient
(
10,000
cm2/
hr
for
adults
and
5,000
cm2/
hr
for
toddlers);
CF1
=
weight
unit
conversion
factor
to
convert
ug
units
to
mg
for
the
daily
exposure
(
0.001
mg/
ug)
BW
=
body
weight
(
70
kg
for
adults
and
39
kg
for
youths).

Dermal
Exposure
from
Golfing
on
Treated
Golf
Course
Turf
(
adult
and
youth)

The
approach
used
to
calculate
the
dermal
exposures
that
are
attributable
to
exposure
from
contacting
treated
golf
course
turf
is:

ADD
=
(
DFR0
*
ET
*
TC
*
CF1)
/
BW
Where:
ADD
=
average
daily
dose
(
mg/
kg/
day);
DFRt
=
dislodgeable
foliar
residue
on
day
"
0"
(
ug/
cm2);
ET
=
exposure
time
(
4
hr/
day
for
adults
and
youths);
TC
=
transfer
coefficient
(
500
cm2/
hr
for
adults
and
youths);
CF1
=
weight
unit
conversion
factor
to
convert
ug
units
to
mg
for
the
daily
exposure
(
0.001
mg/
ug)
BW
=
body
weight
(
70
kg
for
adults
and
39
kg
for
youths).

Risk
Summary:
HED
has
addressed
residential
postapplication
exposures
to
triadimefon
using
the
standard
set
of
scenarios
that
are
prescribed
in
current
guidance.
There
are
many
issues
associated
with
the
development
of
these
scenarios
and,
in
general,
residential
exposure
methods.
Readers
should
refer
to
the
guidance
documents
that
are
presented
above
for
further
information
concerning
the
development
of
scenarios
for
residential
exposure
assessment
purposes.
The
uncertainty
factors
are
similar
to
those
applied
to
the
residential
handler
assessments
described
above
(
i.
e.,
1,000
for
short­
term
and
intermediate­
term
exposures).

Risk
Summary:
Page
109
of
114
Adults
Table
15
presents
the
postapplication
MOE
values
calculated
for
adults
after
lawn
and
home
garden
applications
of
triadimefon.
For
the
residential
adult
scenarios,
short­
term
MOEs
are
>
1,000
on
the
day
of
application
for
all
scenarios,
except
mowing
at
the
5.4/
5.2
lb
ai/
A
(
CA
only)
application
rate
and
the
high
contact
turf
activities
at
the
5.4/
5.2
and
2.7
lb
ai/
A
application
rates.

Table
15:
Adult
Residential
Risk
Estimates
for
Postapplication
Exposure
to
Triadimefon
Exposure
Scenario
Route
of
Exposure
Formulation
Application
Rate
(
lb
ai/
acre)
MOE
at
Day
0
Outdoors
 
with
default
transferable
residues
5.4/
5.2
(
CA
only)
870/
910
2.7
(
Other
than
CA)
1,700
Residential
Turf
(
Mowing)
Dermal
Spray/
Granular
1.3
(
Bayer
max
residential)
3,600
Home
Garden
(
Ornamentals)
Dermal
Spray
0.25
4,800
5.4/
5.2
(
CA
only)
3,000/
3,100
2.7
(
Other
than
CA)
5,900
Golfer
Dermal
Spray/
Granular
1.3
(
Bayer
max
residential)
12,000
Outdoors
 
with
actual
transferable
residues
(
TTR
data)

5.4/
5.2
(
CA
only)
310/
320
2.7
(
Other
than
CA)
620
Residential
Turf
(
High
Contact
Activities)
Dermal
Spray/
Granular
1.3
(
Bayer
max
residential)
1,300
Youth­
aged
children
(
10
to
12
years
old)

Youths
were
considered
in
the
home
garden,
residential
turf/
mowing,
and
golfer
scenarios.
Short­
term
MOEs
for
these
youths
were
>
1,000
for
all
of
the
scenarios
considered
except
mowing
at
the
5.4/
5.2
(
CA
only)
application
rate.
Table
16
below
summarizes
the
postapplication
MOE
values
calculated
for
youths
after
applications
of
triadimefon.
Page
110
of
114
Table
16:
Youth
Residential
Risk
Estimates
for
Postapplication
Exposure
to
Triadimefon
Exposure
Scenario
Route
of
Exposure
Formulation
Application
Rate
(
lb
ai/
acre)
MOE
at
Day
0
Outdoors
 
with
default
transferable
residues
5.4/
5.2
(
CA
only)
570/
590
2.7
(
Other
than
CA)
1,100
Residential
Turf
(
Mowing)
Dermal
Spray/
Granular
1.3
(
Bayer
max
residential)
2,400
Home
Garden
(
Ornamentals)
Dermal
Spray/
Granular
0.25
13,000
5.4/
5.2
(
CA
only)
1,900/
2,000
2.7
(
Other
than
CA)
3,900
Golfer
Dermal
Spray/
Granular
1.3
(
Bayer
max
residential)
8,000
Toddler
(
3
year
old)

Risks
(
MOEs)
to
toddlers
were
calculated
for
postapplication
risks
following
the
application
of
triadimefon
to
home
lawns.
Table
17
summarizes
the
risk
assessment
for
toddlers.
Only
one
scenario,
incidental
soil
ingestion,
had
MOEs
>
1000.
Short­
term
MOEs
were
<
1000
for
residential
turf/
high
contact
activities,
hand­
to­
mouth
activities,
object­
to­
mouth
activities,
and
incidental
ingestion
of
granules/
pellets.

Table
17:
Toddler
Residential
Risk
Estimates
for
Postapplication
Exposure
to
Triadimefon
Exposure
Scenario
Route
of
Exposure
Formulation
Application
Rate
(
lb
ai/
A)
MOE
­­
Day
0b
Outdoors
5.4/
5.2
(
CA
only)
230/
240
2.7
(
Other
than
CA)
460
Residential
Turf
(
High
Contact
Activities)
Dermal
­
with
actual
transferable
residues
(
TTR
data)
Residential
Turf
(
High
Contact
Activities)
1.3
(
Bayer
max
residential)
950
5.4/
5.2
(
CA
only)
52/
55
2.7
(
Other
than
CA)
100
Hand
to
Mouth
Activity
on
Turf
Oral
Spray/
Granular
1.3
(
Bayer
max
residential)
220
Page
111
of
114
Table
17:
Toddler
Residential
Risk
Estimates
for
Postapplication
Exposure
to
Triadimefon
Exposure
Scenario
Route
of
Exposure
Formulation
Application
Rate
(
lb
ai/
A)
MOE
­­
Day
0b
5.4/
5.2
(
CA
only)
210/
220
2.7
(
Other
than
CA)
420
Object
to
Mouth
Activity
on
Turf
Oral
Spray/
Granular
1.3
(
Bayer
max
residential)
870
5.4/
5.2
(
CA
only)
16,000
2.7
(
Other
than
CA)
31,000
Incidental
Soil
Ingestion
Oral
Spray/
Granular
1.3
(
Bayer
max
residential)
65,000
Incidental
Ingestion
of
Granules
or
Pellets
Oral
Granular
1%
ai
in
formulation
62
Combined
Risk
Assessment
for
Residential
Toddler
Postapplication
Scenarios
HED
combines
risk
values
resulting
from
separate
postapplication
exposure
scenarios
when
it
is
likely
they
can
occur
simultaneously
based
on
the
use­
pattern
and
the
behavior
associated
with
the
exposed
population.
Table
18
presents
a
summary
of
the
combined
MOE
estimates.

The
combined
risk
assessment
for
exposures
to
toddlers
following
home
lawn
applications
was
calculated:

Combined
MOE
=
NOAEL
/
(
ADDhand­
to­
mouth
+
ADDobject­
to­
mouth
+
ADDincidental
soil
ingestion
+
ADDdermal)

The
combined
risks
were
below
1000
for
all
application
rates.
Page
112
of
114
Table
18:
Triadimefon
Residential
Scenarios
for
Combined
Risk
Estimates
Margins
of
Exposure
(
MOEs)
(
UF=
1000)
Postapplication
Exposure
Scenario
Short­
Term
MOE
Combined
MOE
Turf
­­
with
actual
transferable
residues
(
TTR
data)

Hand
to
Mouth
52/
55
Object
to
Mouth
210/
220
Incidental
Soil
Ingestion
16,000
Sprays/
Granulars
at
5.4/
5.2
lb
ai/
acre
(
CA
only)

Dermal
230/
240
35/
37
Hand
to
Mouth
100
Object
to
Mouth
420
Incidental
Soil
Ingestion
31,000
Sprays/
Granulars
at
2.7
lb
ai/
acre
(
except
CA)

Dermal
460
71
Hand
to
Mouth
220
Object
to
Mouth
870
Incidental
Soil
Ingestion
65,000
Toddler
Sprays/
Granulars
1.3
lb
ai/
acre
(
Bayer
max
residential)

Dermal
950
150
Residential
Postapplication
Exposure
to
Turfgrass
from
Sod
Farms
An
additional
postapplication
assessment
was
performed
to
assess
the
potential
exposure
of
adults
and
toddlers
to
turf
transplanted
from
sod
farms
into
residential
areas.
Postapplication
risks
were
assessed
assuming
the
2.7
lb
ai/
A
rate
for
sod
farms,
and
attempting
to
estimate
the
number
of
days
prior
to
harvest
where
the
2.7
lb/
A
rate
could
be
applied
to
sodfarms
and
not
result
in
risks
of
concern
to
toddlers
at
residential
sites.
For
dermal
risks
to
toddlers,
HED
used
the
triadimefon­
specific
turf
transferable
residue
values
and
the
triadimefon­
specific
transfer
coefficient
for
high
contact
dermal
activities.
For
hand­
to­
mouth
incidental
oral
ingestion
risks
to
toddlers,
HED
assumed
that
day
0
residues
were
5
percent
of
the
application
rate
(
as
specified
in
the
Standard
Operating
Procedures
for
Residential
Assessments)
and
used
the
dissipation
slope
from
the
triadimefon­
specific
TTR
study
to
estimate
TTRs
from
day
1
and
beyond.
For
object­
to­
mouth
incidental
oral
ingestion
risks
to
toddlers,
HED
assumed
that
day
0
residues
were
20
percent
of
the
application
rate
(
as
specified
in
the
Standard
Operating
Procedures
for
Residential
Assessments)
and
used
the
dissipation
slope
from
the
triadimefon­
specific
TTR
study
to
estimate
TTRs
from
day
1
and
beyond.
The
results
indicate
that
risks
are
not
a
concern
(
i.
e.,
the
MOEs
are
 
1000)
for
toddlers
at
day
5
for
dermal
exposures,
at
day
13
for
hand­
to­
mouth
exposures,
at
day
5
for
object­
to­
mouth
exposures,
and
at
day
0
for
soil
ingestion
exposures.
The
combined
risks
to
toddlers
are
not
a
concern
at
day
15
following
application
to
sodfarms
at
the
2.7
lb
ai/
A
rate.
A
summary
of
the
risks
are
provided
in
Table
19.
Page
113
of
114
Table
19.
Residential
Risk
Estimates
for
Postapplication
Exposure
to
Triadimefon
Exposure
Scenario
Population
Route
of
Exposure
Formulation
Application
Rate
(
lb
ai/
A)
Days
after
treatment
when
MOE
 

1000
MOE
Adults
1,600
Residential
Turf
(
High
Contact
Activities)
Toddlers
Dermal
Spray/
Granular
2.7
Day
5
1,200
Hand
to
Mouth
Activity
on
Turf
Toddlers
Oral
Spray/
Granular
2.7
Day
13
1,200
Object
to
Mouth
Activity
on
Turf
Toddlers
Oral
Spray/
Granular
2.7
Day
5
1,100
Incidental
Soil
Ingestion
Toddlers
Oral
Spray/
Granular
2.7
Day
0
31,000
Aggregate
exposure
(
Dermal
+
Hand­
to­
mouth
+
Objectto
Mouth
+
Soil
Ingestion)
Spray/
Granular
2.7
Day
15
1,100
3.2.4
Residential
Postapplication
Exposure
and
Risk
Estimates
for
Cancer
Residential
postapplication
cancer
risks
were
not
assessed
for
triadimefon,
since
no
toxicological
endpoint
of
concern
was
selected
for
cancer.

3.2.5
Summary
of
Residential
Postapplication
Risk
Concerns
and
Data
Gaps
HED
considered
a
number
of
exposure
scenarios
for
products
that
can
be
used
in
the
residential
environment
representing
different
segments
of
the
population
including
toddlers,
youth­
aged
children,
and
adults.
Short­
term
MOEs
were
calculated
for
all
scenarios.
Cancer
risks
were
not
calculated,
since
no
toxicological
endpoint
for
cancer
was
selected.
In
residential
settings,
HED
does
not
use
restricted­
entry
intervals
or
other
mitigation
approaches
to
limit
postapplication
exposures,
because
they
are
viewed
as
impractical
and
not
enforceable.
As
such,
Page
114
of
114
risk
estimates
on
the
day
of
application
are
the
key
concern.

In
the
assessment
for
residential
postapplication
exposure
and
risk,
there
are
a
number
of
risk
concerns
for
triadimefon
as
it
is
currently
used
in
a
residential
environment.

3.2.6
Recommendations
for
Refining
Residential
Postapplication
Risk
Assessments
In
order
to
refine
this
residential
assessment,
data
on
actual
use
patterns
including
rates,
timing,
and
the
kinds
of
tasks
performed
are
required
to
better
characterize
triadimefon
risks.
