UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460      

	OFFICE OF PREVENTION, PESTICIDE

	AND TOXIC SUBSTANCES

	

  SEQ CHAPTER \h \r 1 MEMORANDUM

Date: February 06, 2009

SUBJECT:	Dicloran: HED’s ORE Response to Gowan Company’s October 30,
2008 Letter to the Agency on the Dicloran (DCNA) Generic Data Call-In;
D358358.

PC Code: 031301	DP Barcode:   D358358

Decision No.: 334070	Registration No.: N/A

Petition No.: NA	Regulatory Action: N/A

Risk Assessment Type: 	Case No.: 0113

TXR No.: NA	CAS No.: NA

MRID No.: 47573501	40 CFR: NA

		              								

          	

FROM:	Matthew Lloyd

		Risk Assessment Branch 7

		Health Effects Division (7509P)  SEQ CHAPTER \h \r 1 

		

THROUGH:	Michael Metzger

		Risk Assessment Branch 7

		Health Effects Division (7509P)  SEQ CHAPTER \h \r 1 

TO:		James Parker

		Reregistration Branch 1

	Special Review and Registration Division (7508P)

This document serves as HED’s Response to occupational exposure issues
raised by Gowan Company’s letter to the Agency on Dicloran (DCNA)
generic Data Call-In (DCI) issues [October 30, 2008].

 



875.1100 - Dermal Exposure

875.1300 - Inhalation Exposure 

875.1600 - Application Exposure Monitoring

Gowan Company is no longer supporting the various dust dicloran products
and is now supporting only two products; Botran 75-W and Botran 5F. As
such, HED no longer has the need to review data on the dermal or
inhalation exposure to dicloran dust products to assess occupational
handler exposures or the dislodgeable foliar residue (DFR) data for
dusts to assess occupational post-application exposures. 

HED recommends that SRRD accept the waiver request pertaining to
dicloran dust products by Gowan Company.

875.2100 - Foliar Dislodgeable Residue

Gowan Company is no longer supporting the various dust dicloran products
and is now supporting only two products; Botran 75-W and Botran 5F. As
such, HED no longer has the need to review data on the dermal or
inhalation exposure to dicloran dust products to assess occupational
postapplication exposures. 

HED recommends that SRRD accept the waiver request pertaining to
dicloran dust products by Gowan Company.

875.2800 - Description of Human Activity

HED notes that Gowan Company is no longer supporting the various dust
dicloran products and is now supporting only two products; Botran 75-W
and Botran 5F. Description of human activity data is no longer necessary
on activities relating to dust products (i.e., the handheld power
duster, and flaggers from dust applications). 

HED has no information to characterize the prevalence of the labeled
uses of the remaining (flowable and wettable powder) dicloran products
through hand-held or backpack equipment on greenhouse seed potatoes.
OPPTS 875.2800 was designed to have registrants submit specific
information on the processes and work activities around a given
operation. 

HED believes the data is relevant to assess dicloran occupational
handler exposures for the wettable powder mix/load/apply scenarios for
backpack sprayer and handwand sprayers; HED cannot complete and
occupational risk assessment until that information is available. 

This information should include the description of activities including,
but not limited to:

Nature of human activity

Principal source of exposure

Usual environmental conditions of exposure

Level of physical exertion

Expected frequency and duration of activity

 

HED recognizes Gowan Company’s membership in the Agricultural Handler
Exposure Task Force (AHETF).  Gowan Company makes note of the AHETF’s
intention to develop unit exposure data specific to the scenarios where
data is needed (specifically, AHETF Scenario 18, 19, 34, and 45). HED
has received information that the AHETF does not plan to proceed with
the development of scenario 45 – backpack mist blower (email
communication with Dave Johnson, 1/27/09) that Gowan Company concurs is
important for the occupational exposure assessment. The remaining
hand-held equipment AHETF scenarios (18, 19, 34) are tentatively
scheduled to have HSRB review in January of 2012. 

HED recommends that SRRD accept the waiver request pertaining to
dicloran exposure scenarios listed above the receipt and review of the
data by the Agency.  Once HED receives and reviews all the data in the
monograph scenarios mentioned above and HSRB study review is complete,
HED can make a determination as to whether the AHETF scenarios are of
appropriate data quality for risk assessment purposes. 

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