UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
October
15,
2004
Memorandum
SUBJECT:
Cypermethrin
and
Zeta­
Cypermethrin:
Occupational
and
Residential
Exposure
Assessment
for
the
Reregistration
Eligibility
Decision
Document
FROM:
Seyed
Tadayon,
Chemist
Reregistration
Branch
III
Health
Effects
Division
(
7509C)

THROUGH:
Danette
Drew,
Branch
Senior
Scientist
Reregistration
Branch
III
Health
Effects
Division
(
7509C)

TO:
William
Donovan,
Risk
Assessor
Reregistration
Branch
III
Health
Effects
Division
(
7509C)

PC
Code:
Cypermethrin:
109702;
Zeta­
Cypermethrin:
129064
DP
Barcode:
Cypermethrin:
D289426;
Zeta­
Cypermethrin:
293414
The
attached
assessment
is
the
occupational
and
non­
occupational
(
residential)
exposure
and
risk
estimates
for
cypermethrin
and
zeta­
cypermethrin
to
support
HED's
reregistration
eligibility
decision
(
RED)
document.
1
Table
of
Contents
Executive
Summary
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2
1.0
Occupational
and
Residential
Exposure/
Risk
Assessment
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8
1.1
Purpose
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8
1.2
Criteria
for
Conducting
Exposure
Assessments
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8
1.3
Summary
of
Hazard
Concerns
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8
1.4
Incident
Reports
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12
1.5
Summary
of
Use
Patterns
and
Formulations
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12
1.5.1
End­
Use
Products
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12
1.5.2
Mode
of
Action
and
Targets
Controlled
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13
1.5.3
Registered
Use
Categories
and
Sites
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13
1.5.4
Application
Parameters
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18
2.0
Occupational
Exposures
and
Risks
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19
2.1
Occupational
Handler
Exposures
and
Risks
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19
2.1.1
Handler
Exposure
Scenarios
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19
2.1.2
Data
and
Assumptions
For
Handler
Exposure
Scenarios
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22
2.1.3
Occupational
Handler
Exposure
and
Risk
Estimates
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31
2.1.4
Summary
of
Risk
Concerns
and
Data
Gaps
for
Handlers
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52
2.1.5
Recommendations
For
Refining
Occupational
Handler
Risk
Assessment
52
2.2.
Occupational
Postapplication
Exposures
and
Risks
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52
2.3
Occupational
Risk
Characterization
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52
2.3.1
Handler
Characterization
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52
3.0
Residential
and
Other
Non­
Occupational
Exposures
and
Risks
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53
3.1
Residential
Handler
Exposures
and
Risks
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53
3.1.1
Handler
Exposure
Scenarios
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53
3.1.2
Data
and
Assumptions
For
Handler
Exposure
Scenarios
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54
3.1.3
Residential
Handler
Exposure
and
Risk
Estimates
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55
3.1.4
Summary
of
Risk
Concerns
and
Data
Gaps
for
Handlers
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56
3.1.5
Recommendations
For
Refining
Residential
Handler
Risk
Assessment
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56
3.2
Residential
Postapplication
Exposures
and
Risks
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56
3.2.1
Residential
Postapplication
Exposure
Scenarios
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56
3.2.2
Data
&
Assumptions
for
Residential
Postapplication
Exposure
Scenarios
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57
3.2.3
Residential
Postapplication
Exposure
and
Risk
Estimates
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58
3.2.4
Recommendations:
Refining
Residential
Postapplication
Risk
Assessment
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65
3.3
Residential
Risk
Characterization
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65
3.3.1
Characterization
Of
Residential
Handler
Risks
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65
3.3.2
Characterization
Of
Residential
Postapplication
Risks
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66
Appendix
A
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67
Appendix
B
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106
2
Executive
Summary
Cypermethrin
[(
±
)
"
cyano­(
3­
phenoxyphenylmethyl)
(
±
)
cis/
trans
3­(
2,2­
dichloroethenyl)
2,2­
dimethylcyclopropane
carboxylate]
and
zeta­
cypermethrin
[(
±
)
S­
cyano­(
3­
phenoxyphenyl)
methyl)
(
±
)
cis/
trans
3­(
2,2­
dichloroethenyl)­
2,2­
dimethylcyclopropane
carboxylate]
are
type
II
pyrethroids.
They
have
a
cyano
group
at
the
"
carbon
position
of
the
alcohol
moiety
and
are
more
effective
when
the
ambient
temperature
is
raised.

While
cypermethrin
and
z­
cypermethrin
are
separate
active
ingredient,
each
registered
in
separate
end
use
products,
they
are
included
in
this
assessment
due
to
close
similarity
of
their
uses,
toxicity,
and
chemical
characteristics.

Cypermethrin
and
zeta­
cypermethrin
are
insecticides
used
on
agricultural
crops
and
animals,
residential
and
commercial
lawns,
and
in
and
around
industrial,
commercial,
and
residential
premises.
Cypermethrin
formulations
include
liquid
concentrates,
wettable
powders,
and
ready­
to­
use
aerosols,
foggers,
trigger­
pump
sprayers,
impregnated
wipes,
and
eartags.
Cypermethrin
can
be
used
by
homeowners
on
pet
horses
and
in
and
around
residential
premises.
Zeta­
cypermethrin
formulations
include
liquid
concentrates
and
ready­
to­
use
dusts
and
impregnated
tags.
Applications
to
agricultural
crops
can
be
made
with
aircraft,
chemigation,
groundboom,
airblast
and
various
handheld
equipment.
Applications
at
industrial,
commercial,
and
residential
sites
can
be
made
using
handheld
equipment
such
as
low­
pressure
handwand
sprayers,
handgun
sprayers,
paintbrushes,
and
termiticides
injectors,
in
addition
to
ready­
to­
use
(
RTU)
aerosol
cans,
indoor
foggers,
pump­
trigger
sprayers,
impregnated
wipes
and
eartags.

Exposure
Data
Used
In
Assessment
Occupational
and
residential
handler
exposure
was
addressed
using
the
Pesticide
Handlers
Exposure
Database
(
PHED
ver.
1.1),
data
from
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF),
data
from
the
Chemical
Manufacturers
Association,
and
data
from
a
proprietary
study.
No
handler
exposure
data
are
available
to
assess
exposures
to
indoor
foggers,
therefore,
PHED
data
for
applying
with
an
aerosol
can
are
used
as
a
reasonable
worse­
case
surrogate.
In
addition,
EPA
has
no
data
to
assess
inhalation
exposures
during
applications
of
impregnated
wipes
or
eartags
to
animals.
However,
these
exposures
are
expected
to
be
less
than
exposure
during
applications
using
a
ready­
to­
use
(
RTU)
aerosol
can.
Therefore,
exposure
assessments
for
the
RTU
aerosol
products
should
provide
risk
estimates
that
cover
these
other
uses.

No
occupational
postapplication
assessment
for
uses
on
agricultural
crops
was
completed,
since
no
short­
or
intermediate­
term
dermal
endpoint
was
identified
and
no
long­
term
exposures
are
anticipated.

The
residential
postapplication
assessment
was
completed
using
the
EPA's
draft
Standard
Operating
Procedures
for
Residential
Exposure
Assessments
(
R­
SOPs)
adopted
December
18,
1997
and
revised
on
February
22,
2001.
3
All
of
the
studies
used
by
the
Agency
to
assess
occupational
and
residential
risks
were
considered
to
be
the
best
source
of
data
available
for
the
scenario
where
it
was
used.

Hazard
Concerns
This
risk
assessment
incorporates
the
toxicological
endpoints
of
concern
for
cypermethrin
and
zeta­
cypermethrin
as
presented
in
the
Report
of
the
Hazard
Identification
Assessment
Review
Committee
(
HIARC)
February
19,
2003.
The
same
endpoints
were
selected
for
cypermethrin
and
zeta­
cypermethrin
for
each
route
of
exposure.
No
short­
or
intermediate­
term
occupational
or
residential
dermal
endpoint
of
concern
was
identified.
The
long­
term
occupational
and
residential
dermal
endpoint
of
concern
(
6
mg/
kg/
day)
is
based
on
an
oral
chronic
feeding
study
in
dogs.
The
occupational
and
residential
short­,
intermediate­,
and
long­
term
inhalation
endpoint
of
concern
(
0.01
mg/
L
or
2.7
mg/
kg/
day)
is
based
on
a
21­
day
inhalation
study
in
rats.
The
incidental
shortterm
oral
endpoint
(
10
mg/
kg/
day)
is
based
on
an
acute
mammalian
neurotoxicity
study.
The
intermediate­
term
incidental
oral
endpoint
(
5
mg/
kg/
day)
is
based
on
a
subchronic
developmental
neurotoxicity
study.
No
dermal
penetration/
absorption
studies
are
available
for
cypermethrin
or
zeta­
cypermethrin.
A
dermal
absorption
value
of
2.5%
may
be
estimated
by
comparing
the
maternal
LOAEL
of
25
mg/
kg/
day
from
the
developmental
study
in
the
rat
and
the
NOAEL
(
highest
dose
tested)
of
1000
mg/
kg/
day
from
the
21­
day
dermal
study
in
the
rat.
Since
there
was
no
common
endpoint
because
no
effects
were
observed
in
the
21­
day
dermal
study
in
the
rat,
this
is
considered
to
be
a
worst­
case
estimate.

Since
the
toxicological
endpoints
of
concern
for
long­
term
exposures
are
based
on
similar
adverse
effects,
long­
term
dermal
and
inhalation
risks
must
be
combined
for
occupational
scenarios
where
long­
term
exposures
are
anticipated.
The
target
MOEs
for
long­
term
occupational
workers
are
100
for
dermal
risk
and
300
inhalation
risk.
Therefore,
the
MOEs
were
combined
to
identify
an
aggregate
risk
index
(
ARI).
An
ARI
was
used
since
the
target
MOE
values
for
inhalation
and
dermal
exposure
were
different.
The
target
ARI
is
1,
therefore,
ARIs
of
less
than
1
indicate
risks
of
concern.

Cypermethrin
has
been
classified
as
Category
C,
possible
human
carcinogen,
based
on
an
increased
incidence
of
lung
adenomas
and
adenomas
plus
carcinomas
combined
in
female
mice.
The
evidence
was
not
considered
strong
enough
to
warrant
a
quantitative
estimation
of
human
risk.
Cypermethrin
has
not
been
classified
under
the
more
current,
Proposed
Guidelines
for
Carcinogen
Risk
Assessment
(
April
10,
1996).
Zeta­
Cypermethrin
is
considered
a
weak
mutagen
under
the
conditions
of
the
Salmonella
typhimurium
(
Ames)
assay;
however,
z­
cypermethrin
was
negative
in
all
mutagenicity
studies
available
to
the
Agency.
Structure­
activity
comparisons
with
the
other
pyrethroids
reveal
indications
of
lung
tumors
in
mice
with
3
other
pyrethroids.

The
Agency's
level
of
concern
for
risks
(
i.
e.,
target
level
for
MOEs
or
Margins
of
Exposure)
is
defined
by
the
uncertainty
factors
that
are
applied
to
the
assessment.
The
Agency
applies
a
factor
of
10
to
account
for
inter­
species
extrapolation
to
humans
from
the
animal
test
species
and
another
factor
of
10
to
account
for
intra­
species
sensitivity.
The
total
uncertainty
factors
that
have
been
applied
to
occupational
risk
assessments
are
100
for
long­
term
dermal
4
exposures,
and
short
and
intermediate­
term
inhalation
exposures.
However,
the
uncertainty
factor
is
300
for
long­
term
inhalation
exposures.
The
additional
3x
for
long­
term
exposure
is
for
the
lack
of
an
alternative
study
on
which
to
make
an
endpoint
selection.

Based
on
the
requirements
of
the
1996
Food
Quality
Protection
Act,
the
Agency
must
also
consider
sensitive
populations
in
its
non­
occupational
risk
assessments.
The
Agency
is
applying
a
safety
factor
of
10x
for
non­
occupational
exposures
to
cypermethrin
due
to
the
lack
of
a
developmental
neurotoxicity
study.
The
total
uncertainty
factors
that
have
been
applied
to
nonoccupational
risk
assessment
are
1000
for
short
and
intermediate­
term
incidental
oral
and
inhalation
exposures,
and
long­
term
dermal
exposures.
An
uncertainty
factor
of
3000
has
been
applied
to
long­
term
inhalation
exposures.
The
additional
3x
for
long­
term
exposure
is
for
the
lack
of
an
alternative
study
on
which
to
make
an
endpoint
selection.

Occupational
Handler
Risks
Cypermethrin
When
data
were
available
to
assess
risks,
short­
and
intermediate­
term
inhalation
risks
to
occupational
handlers
are
below
the
Agency's
level
of
concern
for
risk
assessments
(
i.
e.,
MOE
$

100)
at
baseline
(
i.
e.,
no
respirator)
for
all
the
formulations,
except
wettable
powder
formulations.
For
several
scenarios
involving
wettable
powder
formulation,
risks
are
above
HED's
level
of
concern
(
i.
e.,
MOEs
are
less
than
100)
at
baseline
(
i.
e.,
no
respirator).
The
addition
of
a
dust/
mist
filtering
respirator
reduces
the
risks
to
below
HED's
level
of
concern
for
all
these
scenarios,
except
mixing/
loading
to
support
aerial
or
groundboom
applications
to
agricultural
uncultivated
areas,
fencerows,
and
hedgerows
and
mixing/
loading
to
support
aerial
applications
to
sodfarms.
For
these
three
scenarios,
engineering
controls
(
i.
e.,
water­
soluble
packaging)
are
necessary
to
reduce
the
inhalation
risks
to
below
HED's
level
of
concern.
EPA
has
insufficient
data
to
assess
exposures
to
pilots
in
open
cockpits.
Inhalation
risks
to
pilots
in
enclosed
cockpits
(
engineering
control
scenario)
were
not
a
concern
for
all
agricultural
crop
scenarios.
No
data
are
available
to
assess
inhalation
risks
during
the
application
of
impregnated
eartags
to
horses,
however,
the
risks
are
expected
to
be
well
below
the
inhalation
risks
(
MOE=
15,000)
from
applications
using
a
readyto
use
aerosol
can
(
considered
to
represent
a
worst
case
exposure
scenario
for
applications
of
impregnated
eartags
to
horses).

Short­
and
intermediate­
term
dermal
risks
were
not
assessed
for
occupational
handlers,
since
no
short­
or
intermediate­
term
dermal
endpoint
was
identified.

A
few
occupational
handler
exposure
scenarios
may
be
considered
long­
term,
including
applications
to
residential,
commercial,
and
industrial
turf
by
commercial
lawn
care
operators
and
applications
in
and
around
residential,
commercial,
and
industrial
premises
by
commercial
pest
control
operators.
Aggregated
long­
term
dermal
and
inhalation
risks
are
below
HED's
level
of
concern
for
all
scenarios
involving
liquid
formulations
at
baseline
attire
or
with
the
addition
of
chemical­
resistant
gloves
to
baseline
attire.
Aggregated
long­
term
dermal
and
inhalation
risks
are
below
HED's
level
of
concern
for
all
scenarios
involving
wettable
powder
formulations
at
baseline
5
attire
or
with
the
addition
of
chemical­
resistant
gloves
to
baseline
attire,
except
mixing/
loading/
applying
wettable
powders
with
a
low­
pressure
handwand
sprayer.
Risks
were
reduced
to
below
HED's
level
of
concern
with
the
addition
of
a
dust/
mist
respirator
and
chemical­
resistant
gloves
to
baseline
attire
for
these
scenarios,
except
for
applications
to
residential,
commercial
and
industrial
lawns
(
0.6
lb
ai/
A).
Even
with
the
addition
of
maximum
personal
protection
equipment
(
PPE),
combined
long­
term
dermal
and
inhalation
risks
for
mixing/
loading/
applying
with
low
pressure
handwand
sprayer
to
residential,
commercial
and
industrial
lawns
were
still
above
the
HED's
level
of
concern
(
i.
e,
ARI
<
1).

Zeta­
Cypermethrin
When
data
were
available
to
assess
risks,
short­
and
intermediate­
term
inhalation
risks
to
occupational
handlers
are
below
the
Agency's
level
of
concern
for
risk
assessments
(
i.
e.,
MOE
$

100)
at
baseline
(
i.
e.,
no
respirator).
EPA
has
insufficient
data
to
assess
exposures
to
pilots
in
open
cockpits.
Inhalation
risks
to
pilots
in
enclosed
cockpits
(
engineering
control
scenario)
were
not
a
concern
for
all
agricultural
crop
scenarios.
No
data
are
available
to
assess
inhalation
risks
during
the
application
of
dusts
via
a
mechanical
duster
and
application
of
ready­
to­
use
eartags.

Short­
and
intermediate­
term
dermal
risks
were
not
assessed
for
occupational
handlers,
since
no
short­
or
intermediate­
term
dermal
endpoint
was
identified.

A
few
occupational
handler
exposure
scenarios
may
be
considered
long­
term,
including
applications
to
residential,
commercial,
and
industrial
turf
by
commercial
lawn
care
operators
and
applications
by
pest
control
operators.
When
data
were
available
to
assess
risks,
long­
term
risks
to
occupational
handlers
were
below
the
Agency's
level
of
concern
for
risks
(
i.
e,
ARI
<
1)
at
baseline
attire
(
i.
e.,
long­
sleeve
shirt,
long
pants,
shoes,
socks,
and
no
respirator).
For
mixing/
loading/
applying
liquid
concentrates
with
a
handgun
sprayer,
no
data
are
available
to
assess
dermal
exposures
at
baseline
attire.
However,
the
combined
long­
term
risks
were
below
HED's
level
of
concern
with
the
addition
of
chemical­
resistant
gloves
to
baseline
attire.

Occupational
Postapplication
Risks
EPA
did
not
assess
occupational
postapplication
risks
to
agricultural
workers
following
treatments
to
agricultural
crops,
since
no
short­
or
intermediate­
term
dermal
endpoints
of
concern
were
identified
and
long­
term
exposures
are
not
expected
for
tasks
involving
any
of
the
registered
crop
use
patterns.
In
lieu
of
a
postapplication
risk
assessment,
a
restricted­
entry
interval
of
12
hours
is
assumed,
unless
the
active
ingredient
and
formulation
meet
all
of
the
criteria
listed
in
PR
Notice
95­
3
for
low
risk
pesticides.
Due
to
the
lack
of
a
developmental
neurotoxicity
study,
cypermethrin
and
zeta­
cypermethrin
do
not
meet
the
criteria
in
PR
Notice
95­
3
for
low
risk
pesticides
at
this
time.

EPA
did
not
assess
occupational
postapplication
exposures
and
risks
following
applications
of
cypermethrin
and
zeta­
cypermethrin
to
residential
and
commercial
lawns,
and
in
and
around
industrial,
commercial,
and
residential
premises,
since
no
short­
or
intermediate­
term
6
dermal
endpoints
of
concern
were
identified
and
long­
term
exposures
are
not
expected
for
tasks
involving
any
of
the
registered
use
patterns.

Residential
Handler
Risks
In
residential
settings,
the
Agency
does
not
use
personal
protective
equipment
to
limit
exposures,
because
they
are
viewed
as
impractical
and
not
enforceable.
Risk
estimates
are
based
on
handlers
wearing
short­
sleeve
shirts,
short
pants,
shoes,
and
socks.

Cypermethrin
No
short­
or
intermediate­
term
dermal
exposures
or
risks
were
assessed
for
cypermethrin,
since
no
dermal
endpoints
of
concern
were
identified.
EPA
does
not
anticipate
that
residential
handlers
would
have
long­
term
exposures
to
cypermethrin
or
zeta­
cypermethrin.
Therefore,
no
long­
term
dermal
or
inhalation
exposures
or
risks
were
assessed.
EPA
did
assess
short­
and
intermediate­
term
inhalation
exposures
and
risks
to
residential
handlers.
Residential
inhalation
risks
are
below
HED's
level
of
concern
(
i.
e.,
MOE
<
1000)
for
all
non­
occupational
handler
scenarios.

Zeta­
Cypermethrin
There
are
no
residential
handler
scenarios
for
zeta­
cypermethrin.
All
registered
uses
of
zeta­
cypermethrin
are
for
occupational
use
only.

Residential
Postapplication
Risks
In
residential
settings,
the
Agency
does
not
use
Restricted
Entry
Intervals
(
REIs)
or
other
mitigation
approaches
to
limit
exposures,
as
it
might
in
commercial
settings,
because
they
are
viewed
as
impractical
and
not
enforceable.
As
such,
risk
estimates
on
the
day
of
application
are
the
key
concern
and
the
risk
estimates
are
based
on
persons
wearing
short­
sleeve
shirts,
short
pants,
shoes,
and
socks.
For
cypermethrin
and
zeta­
cypermethrin,
the
Agency
considered
a
number
of
residential
postapplication
exposure
scenarios
for
different
segments
of
the
population
including
toddlers,
youth­
aged
children,
and
adults.
Risks
were
calculated
for
only
a
few
scenarios,
since
no
short­
or
intermediate­
term
dermal
endpoint
of
concern
has
been
identified.
In
general,
postapplication
inhalation
risks
following
outdoor
applications
are
considered
negligible.
However,
postapplication
inhalation
risks
following
indoor
applications
at
residential
sites
may
pose
a
concern.
EPA
assessed
postapplication
inhalation
risks
following
indoor
fogger
applications
using
time­
weighted
averages
from
the
cyfluthrin
room
fogger
study.
EPA
assessed
postapplication
inhalation
risks
following
indoor
aerosol
applications
using
air
concentration
estimates
from
the
crack
and
crevice
subset
of
PHED
and
a
House
Model
to
estimate
an
emission
rate.

EPA
assessed
postapplication
risks
to
toddlers
from
incidental
ingestion
following
broadcast
applications
to
lawns
and
following
spot
or
crack
&
crevice
treatments
to
indoor
7
surfaces.
The
Agency
aggregates
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.
For
cypermethrin
and
zeta­
cypermethrin,
the
Agency
combined
risk
values
(
i.
e.,
MOEs)
for
postapplication
oral
exposures
to
toddlers
associated
with
turf
applications
by
combining
risks
from
oral
exposures
via
transfer
of
residues
from
turf
to
hands
to
mouth
with
risks
from
oral
exposures
via
transfer
from
turf
directly
to
mouth,
and
risks
from
oral
exposures
via
incidental
soil
ingestion.

Cypermethrin
EPA
assessed
postapplication
risks
to
toddlers
from
incidental
oral
ingestion
using
a
shortterm
incidental
oral
endpoint
(
10
mg/
kg/
day)
for
cypermethrin.
The
results
indicate
that
risks
from
short­
term
exposures
were
above
HED's
level
of
concern
(
i.
e.,
MOE
<
1000)
for
transfer
from
indoor
surfaces
to
hand
to
mouth
following
crack
&
crevice
applications
to
indoor
surfaces
(
MOE=
900).

When
the
postapplication
risks
to
toddlers
from
incidental
oral
ingestion
following
applications
to
lawns
were
combined,
the
results
indicate
that
the
combined
risks
were
above
HED's
level
of
concern
for
wettable
powder
applications
at
a
rate
of
0.6
pounds
active
ingredient
per
acre.
The
postapplication
oral
exposures
to
toddlers
following
liquid
concentrate
applications
to
lawns
were
below
HED's
level
of
concern
at
a
rate
of
0.44
pounds
active
ingredient
per
acre.

Zeta­
Cypermethrin
EPA
assessed
postapplication
risks
to
toddlers
from
incidental
oral
ingestion
using
a
shortterm
incidental
oral
endpoint
(
10
mg/
kg/
day)
for
zeta­
cypermethrin.
For
residential
postapplication
risks,
MOEs
are
not
a
concern
for
any
of
the
oral
non­
dietary
scenarios,
because
they
are
greater
than
1000
and
do
not
exceed
HED's
level
of
concern
(
i.
e.,
MOE
<
1000)
for
risk
assessments
in
nonoccupational
settings.

When
the
postapplication
risks
to
toddlers
from
incidental
oral
ingestion
following
applications
to
lawns
were
combined,
the
results
indicate
that
the
combined
risks
were
below
HED's
level
of
concern.
8
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
cypermethrin
and
zeta­
cypermethrin,
which
will
be
used
in
the
reregistration
process.

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,
flaggers,
etc.)
during
use
or
to
persons
entering
treated
sites
after
application
is
complete.
Toxicological
endpoints
were
selected
for
long­
term
dermal
exposures
(
NOAEL
is
6.0
mg/
kg/
day);
short­,
intermediate­,
and
long­
term
inhalation
exposures
(
NOAEL
for
all
is
2.7
mg/
kg/
day);
and
for
incidental
ingestion
(
NOAEL
for
short­
term
is
10.0
mg/
kg/
day
and
NOAEL
for
intermediate
term
is
5.0
mg/
kg/
day).
Cypermethrin
and
zetacypermethrin
have
been
classified
as
Category
C
possible
human
carcinogens,
based
on
an
increased
incidence
of
lung
adenomas
and
adenomas
plus
carcinomas
combined
in
female
mice.
However,
this
evidence
is
not
considered
strong
enough
to
warrant
quantitative
estimation
of
human
risk.
There
is
a
significant
potential
for
exposure
in
a
variety
of
agricultural,
commercial,
and
residential
settings.
Therefore,
risk
assessments
are
required
for
occupational
and
residential
handlers
and
for
occupational
and
residential
postapplication
exposures
that
can
occur
as
a
result
of
cypermethrin
and
zeta­
cypermethrin
use.

1.3
Summary
of
Hazard
Concerns
The
toxicological
endpoints
that
were
used
to
complete
the
occupational
and
residential
risk
assessments
are
summarized
below
and
in
Table
1,
which
has
been
extracted
from
the
latest
HIARC
document
dated
February
19,
2003.
Adverse
effects
were
identified
at
different
durations
of
exposure
ranging
from
short­
term
(
up
to
30
days)
to
chronic
durations
(
every
working
day).
Cancer
risks
were
not
calculated
for
cypermethrin
and
zeta­
cypermethrin.
Cypermethrin
and
zetacypermethrin
have
been
classified
as
Category
C
possible
human
carcinogens,
based
on
an
increased
incidence
of
lung
adenomas
and
adenomas
plus
carcinomas
combined
in
female
mice.
However,
the
evidence
(
common
tumor,
one
species
of
mice,
in
females
only,
plus
no
increase
in
the
proportion
of
malignant
tumors
or
decrease
in
the
time­
to­
tumor
occurrence,
and
lack
of
mutagenic
activity)
was
not
considered
strong
enough
to
warrant
a
quantitative
estimation
of
human
risk
Cypermethrin
and
zeta­
cypermethrin
are
type
II
pyrethroid
insecticides
where
the
use
patterns
can
vary
widely
ranging
from
shorter­
term
exposures
through
exposures
on
nearly
every
work
day.
As
such,
when
the
HIARC
evaluated
the
cypermethrin
and
zeta­
cypermethrin
hazard
database,
endpoints
were
selected
to
address
each
duration
of
exposure.
Exposures
can
occur
to
occupational
users
and
the
general
population,
so
both
were
considered
in
this
assessment.
9
No
short­
or
intermediate­
term
dermal
occupational
or
residential
endpoints
of
concern
were
identified.
The
long­
term
dermal
risk
assessment
for
cypermethrin
and
zeta­
cypermethrin
is
based
on
a
NOAEL
of
6
mg/
kg/
day
which
was
defined
in
a
chronic
feeding
study
in
dogs
(
an
oral
study­
MRID
44536801).
The
LOAEL
for
this
study
is
20.4
mg/
kg/
day.

The
short­,
intermediate­,
and
long­
term
inhalation
risk
assessments
for
cypermethrin
and
zeta­
cypermethrin
are
based
on
a
NOAEL
of
2.7
mg/
kg/
day
which
was
defined
in
a
21­
day
inhalation
study
in
rats
(
MRID
43507101).

The
short­
term
incidental
oral
risk
assessments
for
cypermethrin
and
zeta­
cypermethrin
are
based
on
a
NOAEL
of
10
mg/
kg/
day,
which
was
defined
in
an
acute
mammalian
neurotoxicity
study
(
MRID
44962201)
and
the
intermediate­
term
incidental
oral
risk
assessments
for
cypermethrin
are
based
on
a
NOAEL
of
5
mg/
kg/
day,
which
was
defined
in
a
subchronic
mammalian
neurotoxicity
study
(
MRID
44962202).

A
dermal
absorption
factor
of
2.5
percent
was
estimated
by
comparing
the
maternal
LOAEL
of
25
mg/
kg/
day
from
the
developmental
study
in
rats
and
the
NOAEL
(
highest
dose
tested)
of
1000
mg/
kg/
day
from
the
21­
day
dermal
study
in
rats.
Since
there
was
no
common
endpoint,
because
no
effects
were
observed
in
the
21­
day
dermal
study
in
the
rat,
this
is
considered
to
be
a
worst­
case
estimate
(
i.
e.
the
dose
level
of
1000
mg/
kg/
day
was
considered
to
be
the
NOAEL).

Since
the
long­
term
toxicological
endpoint
of
concern
is
based
on
the
same
adverse
effect,
long­
term
dermal
and
inhalation
exposures
and
risks
are
combined
for
occupational
scenarios.

The
Agency's
level
of
concern
for
risks
(
i.
e.,
target
level
for
MOEs
or
Margins
of
Exposure)
is
defined
by
the
uncertainty
factors
that
are
applied
to
the
assessment.
The
Agency
applies
a
factor
of
10
to
account
for
inter­
species
extrapolation
to
humans
from
the
animal
test
species
and
another
factor
of
10
to
account
for
intra­
species
sensitivity.
The
total
uncertainty
factors
that
have
been
applied
to
occupational
risk
assessments
are
100
for
short
and
intermediate­
term
inhalation
exposures,
100
for
long­
term
dermal
exposures,
and
300
for
longterm
inhalation
exposures.
The
additional
3x
for
long­
term
exposure
is
for
the
lack
of
an
alternative
study
on
which
to
make
an
endpoint
selection.

Based
on
the
requirements
of
the
1996
Food
Quality
Protection
Act,
the
Agency
must
also
consider
sensitive
populations
in
its
non­
occupational
risk
assessments.
The
Agency
is
applying
a
safety
factor
of
10x
for
non­
occupational
exposures
to
cypermethrin
and
zetacypermethrin
due
to
the
lack
of
a
developmental
neurotoxicity
study.
The
total
uncertainly
factors
that
have
been
applied
to
non­
occupational
risk
assessment
are
1000
for
short
and
intermediateterm
incidental
oral
and
inhalation
exposures,
and
long­
term
dermal
exposures.
An
uncertainty
factor
of
3000
has
been
applied
to
long­
term
inhalation
exposures.
The
additional
3x
for
longterm
exposure
is
for
the
lack
of
an
alternative
study
on
which
to
make
an
endpoint
selection.
10
Table
1:
Summary
of
Occupational
and
Residential
Toxicology
Endpoint
Selection
for
Cypermethrin
and
Zeta­
Cypermethrin
Exposure
Scenario
Dose
Used
in
Risk
Assessment,
UF
Special
FQPA
SF
and
Level
of
Concern
for
Risk
Assessment
Study
and
Toxicological
Effectsb
Short­
Term
Incidental
Oral
(
1
to
30
days)
NOAEL=
10
mg
a.
i./
kg/
day
Residential
LOC
for
MOE
=
1000
Occupational
LOC
for
MOE
=
N/
A
Acute
neurotoxicity
study
in
the
rat
(
zeta­
cypermethrin).
LOAEL
=
50
mg/
kg/
day
based
on
clinical
signs
of
neurotoxicity
and
changes
in
the
FOB
Intermediate­
Term
Incidental
Oral
(
1
­
6
months)
NOAEL=
5.0
mg
a.
i./
kg/
day
Residential
LOC
for
MOE
=
1000
Occupational
LOC
for
MOE
=
N/
A
Subchronic
neurotoxicity
study
in
the
rat
(
zeta­
cypermethrin).
LOAEL
=
26.3
mg/
kg/
day
based
on
decreased
motor
activity,
increased
landing
foot
splay,
and
decreased
body
weights,
body
weight
gains,
and
food
consumption
Short­
and
Intermediate­
Term
Dermal
(
1
day
to
6
months
None
Residential
LOC
for
MOE
=
N/
A
Occupational
LOC
for
MOE
=
N/
A
No
systemic
effects
in
21­
day
dermal
study
(
zeta­
cypermethrin)
up
to
1000
mg/
kg/
day&
no
developmental
concern.
No
hazard
identified
to
support
quantitation
of
risk.

Long­
Term
Dermal
(>
6
months)
Oral
NOAEL=
6
mg
a.
i./
kg/
day
(
dermal
absorption
factor
=
2.5%)
Residential
LOC
for
MOE
=
1000a
Occupational
LOC
for
MOE
=
100
Chronic
feeding
study
in
the
dog.
LOAEL
=
20.4/
18.1
mg/
kg/
day
based
on
clinical
signs
of
neurotoxicity
and
mortality
in
males,
and
decreased
body
weights
and
body
weight
gains
in
females.

Short­
and
Intermediate­
Term
Inhalation
(
1
day
to
6
months)
Inhalation
NOAEL=
0.01
mg
a.
i./
L/
day
(
2.7
mg/
kg/
day)
Residential
LOC
for
MOE
=
1000
Occupational
LOC
for
MOE
=
100
21­
day
inhalation
study
in
the
rat.
LOAEL
=
0.05
mg/
L/
day
(
13.5
mg/
kg/
day)
based
on
decrease
in
body
weight
and
salivation.

Long­
Term
Inhalation
(>
6
months)
Inhalation
NOAEL=
0.01
mg
a.
i./
L
(
2.7
mg/
kg/
day)
Residential
LOC
MOE
=
3000
Occupational
LOC
MOE
=
300
for
the
lack
of
alternative
study.
Route­
toroute
estimation
would
result
in
less
protective
endpoint.
21­
day
inhalation
study
in
the
rat.
LOAEL
=
0.05
mg/
L/
day
(
13.5
mg/
kg/
day)
based
on
decrease
in
body
weight
and
salivation.

Cancer
(
oral,
dermal,
inhalation)
Classification:
Category
C
(
possible
human
carcinogen).
No
quantitation
required.

(
a)
Use
a
2.5%
dermal
absorption
factor
for
route
to
route
extrapolation.
UF
=
Uncertainty
factor,
FQPA
SF
=
Food
Quality
Protection
Act
Safety
Factor,
NOAEL
=
No
observed
adverse
effect
level,
LOAEL
=
Lowest
observed
adverse
effect
level,
PAD
=
Population
adjusted
dose
(
a=
acute,
c=
chronic),
RfD
=
reference
dose,
MOE
=
margin
of
exposure,
LOC
=
Level
of
concern
11
A
series
of
acute
toxicity
tests
were
also
conducted
using
cypermethrin
and
zetacypermethrin
 
an
isomeric
enriched
technical
grade
of
cypermethrin
(
see
table
2).
The
results
indicate
that
cypermethrin
is
category
II
for
acute
oral
toxicity,
category
III
for
acute
dermal
toxicity
and
primary
eye
irritation
effects,
and
category
IV
for
acute
inhalation
toxicity
and
primary
skin
irritation
effects.
Results
were
negative
for
dermal
sensitization.
However,
the
HIARC
document
notes
that
cypermethrin
and
zeta­
cypermethrin
can
cause
the
"
pyrethroid
reaction"
or
a
local
site
of
contact
sensation
that
is
indicated
by
tingling
and
other
signs
and
can
result
in
scratching
and
secondary
infections.
The
only
study
currently
available
for
zetacypermethrin
indicates
that
it
is
category
II
for
acute
oral
toxicity.

Table
2:
Acute
Toxicity
of
Cypermethrin
and
Zeta­
Cypermethrin
Guideline
No.
Study
Type
Toxicity
Category
870.1000
Acute
Oral
­
zeta­
Cypermethrin
II
870.1000
Acute
Oral
­
Cypermethrin
II
870.1100
Acute
Dermal
Rats
­
Cypermethrin
Rabbits
­
Cypermethrin
III
III
870.1200
Acute
Inhalation
­
Cypermethrin
IV
870.2400
Primary
Eye
Irritation
­
Cypermethrin
III
870.2500
Primary
Skin
Irritation
­
Cypermethrin
IV
870.2600
Dermal
Sensitization
­
Cypermethrin
N/
A
*
Cypermethrin
and
other
type
II
pyrethroids
cause
a
special
type
of
dermal
irritation
on
contact
that
is
indicated
by
tingling
and
other
signs.

1.4
Incident
Reports
Incident
reports
are
addressed
in
a
separate
memo.(
J.
Blondell,
August
26,
2003).

1.5
Summary
of
Use
Patterns
and
Formulations
1.5.1
End­
Use
Products
Cypermethrin
and
zeta­
cypermethrin
are
broad­
spectrum
pyrethroid
insecticides
marketed
in
a
variety
of
end­
use
products
for
both
occupational
and
homeowner
use.

Table
3
summarizes
the
technical
and
manufacturing
products
with
their
respective
EPA
registration
numbers.
12
Table
3:
Technical
and
Manufacturing
Cypermethrin
and
zeta­
Cypermethrin
Products
Formulation
EPA
Reg.
No.
(%
active
ingredient)

Cypermethrin
Technical
100­
989
(
90%);
279­
3026
(
88.00%);
279­
3275
(
88%);
53883­
89
(
96.70%);
70506­
10
(
96.70%);
73049­
385
(
90%);
73049­
386
(
88%)

Cypermethrin
Manufacturing
Product
100­
1018
(
70.00%);
279­
3026
(
88.00%)

z­
Cypermethrin
Technical
279­
3124
(
88%)

z­
Cypermethrin
Manufacturing
Product
279­
3250
(
36%);
279­
3256
(
17.1%);
279­
3260
(
18.1%)

Based
on
a
review
by
the
Office
of
Pesticide
Programs
 
Pesticide
Product
Label
System
(
PPLS)
and
registrant
input,
cypermethrin
formulations
include
liquid
concentrates,
wettable
powders,
wettable
powders
in
water­
soluble
packaging,
ready­
to­
use
aerosol
sprays;
ready­
to­
use
trigger­
pump
sprayers,
ready­
to­
use
indoor
foggers,
ready­
to­
use
wipes,
and
ready­
to­
use
ear
tags.
Zeta­
cypermethrin
formulations
include
liquid
concentrates
and
ready­
to­
use
dusts
and
impregnated
tags.
Tables
4a
and
4b
outline
the
formulations
and
EPA
registration
numbers
for
labels
of
cypermethrin
and
zeta­
cypermethrin
end­
use
products
according
to
PPLS
and
the
registrant.
Many
of
the
products
described
in
Tables
4a
and
4b
can
be
used
in
a
variety
of
settings
ranging
from
agriculture
crops
to
commercial,
industrial,
and
residential
premises.

Table
4a:
Cypermethrin
End­
Use
Product
Formulations
and
EPA
Reg.
Number
Formulation
EPA
Reg.
No.
(%
active
ingredient)

Concentrates
4­
427
(
26.00%);
100­
1004
(
25.30%);
100­
1006
(
25.3%);
100­
1109
(
25.3%)
270­
250
(
0.60%);
279­
3027
(
30.60%);
279­
3044
(
30.60%);
279­
3046
(
30.60%);
279­
3081
(
24.80%);
279­
3082
(
24.80%);
279­
3118(
43.20%);
279­
3120
(
27.90%);
279­
3209
(
30.60%);
279­
3131
(
30.60%);
28293­
284
(
26.00%);
45385­
94
(
26.00%)
53883­
27
(
25.30%);
53883­
92
(
25.30%);
53883­
104
(
30.60%);
70506­
19
(
24.8%);
70506­
20
(
30.6%);
70506­
21
(
30.6%);
73049­
154
(
26.00%);
73049­
317
(
24.8%)

Wettable
Powders
100­
990
(
40.00%);
279­
3070
(
40.00%);
279­
3109
(
50.00%);
432758
(
40.00%);
53883­
29
(
40.00%)

Wettable
Powders
in
water
soluble
Bags
100­
1000
(
40.00%)
279­
3084
(
38.70%);
279­
3085
(
35.60%);
2793117
(
50.00%);
282­
3084
(
38.70%)
73049­
318
(
35.6%)

Ready­
to­
Use
270­
251
(
0.15%);
270­
253
(
0.15%);
270­
316
(
0.50%);
498­
190
(
1.716%);
39039­
2
(
7.0%);
4822­
389
(
0.15%);
4822­
436
(
0.15%);
4822­
447
(
0.10%);
4822­
452
(
1.716%);
9444­
182
(
0.10%);
9444128
(
0.10%);
39039­
21
(
7.00%)
53883­
94
(
0.15%);
73049­
157
(
0.05%)

Table
4b:
Zeta­
cypermethrin
End­
Use
Product
Formulations
and
EPA
Reg.
Number
Formulation
EPA
Reg.
No.
(%
active
ingredient)

Liquid
Concentrates
279­
3125
(
18.1%);
279­
3126
(
17.1%);
279­
3242
(
17.1%);
279
3248
(
9.2%);
279­
3249
(
9.60%)

Ready­
to­
Use
39039­
4
(
10%);
39039­
9
(
0.075%);
39039­
11
(
10%)
13
1.5.2
Mode
of
Action
and
Targets
Controlled
Cypermethrin
and
zeta­
cypermethrin
are
type
II
pyrethroids.
The
type
II
pyrethroids
produce
a
characteristic
toxicity
response
in
both
insects
and
mammals
that
is
distinct
from
the
type
I
pyrethroids.
The
Type
II
pyrethroids
produce
responses
that
include
choreoathetosis
writhing
in
mammals.

1.5.3
Registered
Use
Categories
and
Sites
An
analysis
of
the
current
labeling
and
available
use
information
was
completed.
Cypermethrin
is
registered
for
use
in
a
variety
of
occupational
and
homeowner/
residential
scenarios.
Zeta­
cypermethrin
is
registered
for
use
in
a
variety
of
occupational
scenarios.
Residential
handler
use
scenarios
are
not
expected
for
zeta­
cypermethrin,
however,
there
is
a
potential
for
postapplication
exposure
to
treated
turf/
lawns.
For
reasons
of
clarity
in
the
risk
assessment
process,
the
use
patterns
have
been
described
in
a
manner
that
delineates
occupational
from
homeowner/
residential
uses.
Use
sites,
maximum
applications
rates,
and
area
treated
are
provided
in
Tables
5a
and
5b
for
cypermethrin.
Use
sites,
maximum
applications
rates,
and
area
treated
are
provided
in
Tables
6a
and
6b
for
zeta­
cypermethrin.

Cypermethrin
Occupational
Use
Sites
Occupational
populations
are
potentially
exposed
while
making
cypermethrin
applications
to
the
following
targets
or
after
contact
with
the
treated
targets
after
previous
cypermethrin
applications.
The
following
list
is
a
summary
of
occupational
use
sites.

Table
5a:
Summary
of
Maximum
Application
Rates
for
Registered
Cypermethrin
Agricultural
Crop
Uses
Crop
or
Target
Maximum
Application
Rate
(
lb
ai/
acre)
Application
Equipment
Area
Treated
or
Amount
Handled
Daily
(
acres)

Cotton
0.1
aerial
1200
chemigation
350
groundboom
200
Broccoli,
Broccoli
Raab,
Brussel
Sprouts,
Bok
Choy,
Cabbage,
Cauliflower,
Cavalo
Broccolo,
Chinese
Broccoli,
Chinese
Cabbage,
Collards,
Head
Lettuce,
Kale,
kohlrabi
Mizuna,
Mustard
Greens,
Mustard
Spinach,
Pecans,
Rape
Greens
0.1
aerial
350
chemigation
350
groundboom
80
Pecans
0.1
aerial
350
chemigation
350
Table
5a:
Summary
of
Maximum
Application
Rates
for
Registered
Cypermethrin
Agricultural
Crop
Uses
Crop
or
Target
Maximum
Application
Rate
(
lb
ai/
acre)
Application
Equipment
Area
Treated
or
Amount
Handled
Daily
(
acres)

14
airblast
40
Sodfarms
0.74
aerial
350
groundboom
80
Agricultural
Uncultivated
Areas,
Fencerows,
Hedgerows
3.4
aerial
350
airblast
80
handgun
5
Ornamental
Plants
3.4
groundboom
40
airblast
20
handgun
5
0.008
lb
ai/
gal
low
pressure
handwand
sprayer
40
gallons
Top
Soil,
Potting
Soil
3.4
handgun
5
Table
5b:
Summary
of
Maximum
Application
Rates
for
Registered
Cypermethrin
Occupational
(
not
Agricultural
Crop)
Uses
Crop
or
Target
Maximum
Application
Rate
Application
Equipment
Area
Treated
or
Amount
Handled
Daily
Residential,
Commercial
and
Industrial
Lawns
0.6
lb
ai/
A
(
wettable
powders)
0.44
lb
ai/
A
(
liquid
concentrate)
low
pressure
handwand
sprayer
5
acres
handgun
sprayer
5
acres
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,
and
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.05
lb
ai/
gallon
low
pressure
handwand
sprayer
40
gallons
paint
brush
5
gallons
Termites
applications
to
preconstruction
lumber
and
logs,
and
to
soil
under
firewood
0.041
lb
ai/
gallon
low
pressure
handwand
40
gallons
paint
brush
5
gallons
Crop
or
Target
Maximum
Application
Rate
Application
Equipment
Area
Treated
or
Amount
Handled
Daily
15
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,
commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
0.017
lb
ai/
gallon
(
crack
&
crevice)
low
pressure
handwand
40
gallons
paint
brush
5
gallons
0.005
lb
ai/
16
oz
can
aerosol
can
Two
16­
ounce
cans
0.0014
lb
ai/
fogger
(
broadcast)
indoor
fogger
Four
1.5­
ounce
foggers
Termite
Applications
to
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.008
lb
ai/
gallon
low
pressure
handwand
40
gallons
Termites:
trees,
utility
poles,
fenceposts,
building
voids
0.05
lb
ai/
gallon
termiticide
injector
500
gallons
Cattle
0.003
lb
ai/
2
ear
tags
ear
tag
100
and
1000
cattle
Horses
0.017
lb
ai/
gallon
low
pressure
handwand
40
gallons
ready
to
use
pump
trigger
1
gallon
0.00041
lb
ai/
wipe
ready
to
use
wipe
50
and
500
horses
Table
5b:
Summary
of
Maximum
Application
Rates
for
Registered
Cypermethrin
Residential
Uses
Crop
or
Target
Maximum
Application
Rate
Application
Equipment
Area
Treated
or
Amount
Handled
Daily
Indoor
Spaces
0.0014
lb
ai/
fogger
ready­
to­
use
fogger
Two
1.5
ounce
foggers
Indoor
surfaces
0.005
lb
ai/
sixteen
ounce
can
aerosol
can
One
16­
ounce
can
Horses
0.017
lb
ai/
gallon
low
pressure
handwand
5
gallons
ready
to
use
pump
trigger
0.1
gallon
mix
and
wipe
0.1
gallon
0.00041
lb
ai/
wipe
ready
to
use
wipe
1
horse
16
Zeta­
Cypermethrin
Table
6a:
Summary
of
Maximum
Application
Rates
for
Registered
Zeta­
Cypermethrin
Agricultural
Uses
Crop
or
Target
Maximum
Application
Rate
(
lb
ai/
acre)
Application
Equipment
Area
Treated
or
Amount
Handled
Daily
(
acres)

Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,
and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,
Soybeans,
Wheat,
and
Triticale
0.05
aerial
1200
chemigation
350
groundboom
200
Bulb
Vegetables
include
garlic,
great­
headed
garlic,
green
eschalots,
Japanese
bunching
onions,
leeks,
dry
bulb
and
green
onion,
welch
onion,
dry
bulb
and
green
shallots,
and
scallions;
Fruiting
Vegetables
(
except
cucurbits)
include
eggplant,
ground
cherry,
pepino,
tomatillo,
tomato,
and
peppers
 
bell,
chili,
cooking,
sweet
pepper,
pimento;
Grain
Sorghum
and
Millet;
Head/
Stem
Brassica
Vegetables
include
broccoli,
Chinese
broccoli,
Brussels
sprouts,
cauliflower,
cavalo
broccolo,
kohlrabi,
cabbage,
and
Chinese
cabbage;
Head
Lettuce;
Leafy
Brassica
Greens
include
broccoli
raab,
bok
choy,
Chinese
mustard
cabbage,
collards,
kale,
mizuna,
mustard
greens,
mustard
spinach,
and
rape
greens;
Leafy
Vegetables
(
except
Brassica)
include
leafy
amaranth,
Chinese
spinach,
tambala
roquette,
cardoon,
celery,
Chinese
celery,
celtuce,
chervil,
edible
leaf
and
garland
chrysanthemum,
corn
salad,
upland
&
garden
cress,
dandelion,
dock,
endive,
escarole,
fennel,
Florence,
head
and
leaf
lettuce,
orach,
parsley,
garden
and
winter
purslane,
radiccio,
rhubarb,
spinach,
and
Swiss
chard;
Succulent
Edible
Podded
Beans
include
wax
bean,
asparagus
bean,
Chinese
longbean,
moth
bean,
yardlong
bean,
Jackbean,
immature
soybean
seed,
sword
bean,
lima
bean,
broad
been,
black­
eyed
pea,
southern
pea,
grain
lupin,
sweet
lupin,
white
lupin,
white
sweet
lupin,
field
bean,
kidney
bean,
navy
bean,
pinto
bean,
tepary
bean,
adzuki
bean,
catjang,
crowder
pea,
moth
bean,
mung
bean
rice
bean,
curd
bean,
chickpea,
guar,
and
lablab
bean;
Succulent
Edible
Podded
Peas
include
dwarf
pea,
edible­
pod
pea,
snow
pea,
sugar
snap
pea,
pigeon
pea,
English
pea,
garden
pea,
green
pea,
and
lentil;
Sugarbeet;
Sugarcane
0.05
aerial
350
chemigation
350
groundboom
80
Pecans
0.05
aerial
350
chemigation
350
airblast
40
17
Table
6b:
Summary
of
Maximum
Application
Rates
for
Registered
Zeta­
Cypermethrin
Commercial
Uses
Crop
or
Target
Maximum
Application
Rate
Application
Equipment
Area
Treated
or
Amount
Handled
Daily
Livestock
(
beef
and
dairy
cattle,
sheep,
goats,
horses)
0.00094
lb
ai/
animal
mechanical
duster
1000
animals
shaker
can
100
animals
Livestock
(
cattle)
0.004
lb
ai/
2
ear
tags/
cattle
ready­
to­
use
ear
tags
100
and
1000
cattle
0.003
lb
ai/
1
ear
tag/
cattle
Indoor
surfaces
0.003
lb
ai/
gallon
low
pressure
handwand
40
gallons
Residential
lawns
and
Turfgrass
at
Commercial
Sites
1
lb
ai/
acre
low
pressure
handwand
2
acres
Residential
lawns
1
lb
ai/
acre
handgun
sprayer
5
acres
Outdoor
surfaces
0.001
lb
ai/
gallon
low
pressure
handwand
40
gallons
paintbrush
5
gallons
Outdoor
surfaces
(
ant
mounds)
0.006
lb
ai/
mound
watering
can
40
mounds
Outdoor
surfaces:
vegetation,
refuse
dumps,
garages,
and
other
outdoor
surfaces,
Turfgrass:
adjacent
to
or
around
private
homes,
duplexes,
townhouses,
condominiums,
house
trailers
apartment
complexes,
carports,
garages,
fence
lines,
storage
sheds,
barns,
and
other
residential
structures
plus
commercial,
industrial,
institutional
buildings,
Surfaces
of
buildings:
porches,
screens,
window
frames,
eaves,
patios,
lawn
area
adjacent
to
or
around
private
homes,
duplexes,
townhouses,
condominiums,
house
trailers
apartment
complexes,
carports,
garages,
fence
lines,
storage
sheds,
barns,
and
other
residential
structures
plus
commercial,
industrial,
institutional
buildings
0.4356
lb
ai/
acre
handgun
sprayer
5
acres
1.5.4
Application
Parameters
Application
parameters
are
generally
defined
by
the
physical
nature
of
the
use
site,
the
physical
nature
of
the
formulation
(
e.
g.,
formula
and
packaging),
by
the
equipment
required
to
deliver
the
chemical
to
the
use
site,
and
by
the
application
rate
required
to
achieve
an
efficacious
dose.
18
2.0
Occupational
Exposures
and
Risks
It
has
been
determined
there
is
a
potential
for
occupational
exposure
from
handling
cypermethrin
and
zeta­
cypermethrin
products
during
the
application
process
(
i.
e.,
mixer/
loaders,
applicators,
flaggers
and
mixer/
loader/
applicators)
and
from
entering
areas
previously
treated
with
cypermethrin
and
zeta­
cypermethrin
(
e.
g.,
postapplication
worker
exposure).
As
a
result,
risk
assessments
have
been
completed
for
occupational
handler
and
postapplication
scenarios.

2.1
Occupational
Handler
Exposures
and
Risks
There
are
distinct
job
functions
or
tasks
related
to
pesticide
applications
and
exposures
that
can
vary
depending
on
the
specifics
of
each
task.
Job
requirements
(
e.
g.,
amount
of
chemical
to
be
used
in
an
application),
formulation,
the
kinds
of
equipment
used,
the
target
being
treated,
and
the
circumstances
of
the
user
(
e.
g.,
the
level
of
protection
used
by
an
applicator)
can
cause
exposure
levels
to
differ
in
a
manner
specific
to
each
application
event.

2.1.1
Handler
Exposure
Scenarios
The
purpose
of
this
section
is
to
describe
the
exposure
scenarios
that
were
used
by
the
Agency
in
the
assessment
for
cypermethrin
and
zeta­
cypermethrin
handlers.
Information
from
the
current
labels;
use
and
usage
information;
toxicology
data;
and
exposure
data
were
all
key
components
in
developing
the
exposure
scenarios.

Tasks
associated
with
occupational
pesticide
use
(
i.
e.,
for
"
handlers")
can
generally
be
categorized
using
one
of
the
following
terms:

C
Occupational
Mixers
and/
or
Loaders:
these
individuals
perform
tasks
in
preparation
for
an
application.

C
Occupational
Applicators:
these
individuals
operate
application
equipment
during
the
release
of
a
pesticide
product
on
to
the
intended
target.

C
Occupational
Mixer/
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).

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

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
to
make
cypermethrin
and
zeta­
cypermethrin
applications.
The
quantitative
exposure/
risk
assessment
developed
for
occupational
handlers
is
based
on
these
scenarios.
[
Note:
The
scenario
numbers
correspond
to
the
tables
of
risk
calculations
included
in
the
occupational
risk
calculation
aspects
19
of
the
Appendix
A.]

Cypermethrin
Short­
and
Intermediate­
term
Scenarios
(
Inhalation
Exposure
only):

Mixer/
Loader:

(
1a)
Liquid
Formulations:
Mixing/
Loading
to
support
Aerial
Applications
(
1b)
Liquid
Formulations:
Mixing/
Loading
to
support
Chemigation
Applications
(
1c)
Liquid
Formulations:
Mixing/
Loading
to
support
Groundboom
Applications
(
1d)
Liquid
Formulations:
Mixing/
Loading
to
support
Airblast
Applications
(
2a)
Wettable
Powder
Formulations:
Mixing/
Loading
to
support
Aerial
Applications
(
2b)
Wettable
Powder
Formulations:
Mixing/
Loading
to
support
Chemigation
Applications
(
2c)
Wettable
Powder
Formulations:
Mixing/
Loading
to
support
Groundboom
Applications
(
2d)
Wettable
Powder
Formulations:
Mixing/
Loading
to
support
Airblast
Applications
Applicator:
(
3)
Applying
with
Sprays
with
Aircraft
(
4)
Applying
with
Groundboom
Equipment
(
5)
Applying
with
Airblast
Equipment
Flagger:
(
6)
Flagging
to
support
Aerial
Spray
Applications
Mixer/
Loader/
Applicator:

(
7)
Liquid
Formulations:
Low
Pressure
Handwand
Sprayer
(
8)
Liquid
Formulations:
Paint
Brush
(
9)
Liquid
Formulations:
Low
Pressure/
High
Volume
Turf/
Handgun
Sprayer
(
10)
Liquid
Formulations:
Termiticide
Injector
(
11)
Wettable
Powder
Formulations:
Low
Pressure
Handwand
Sprayer
(
12)
Wettable
Powder
Formulations:
Paint
Brush
(
13)
Wettable
Powder
Formulations:
Low
Pressure/
High
Volume
Turf/
Handgun
Sprayer
(
14)
Water
Soluble
Bag
Formulations:
Low
Pressure/
High
Volume
Turf/
Handgun
Sprayer
(
15)
Ready­
to­
Use
Ear
Tag
(
16)
Ready­
to­
Use
Trigger
Pump
Sprayer
(
17)
Ready­
to­
Use
Wipes
(
18)
Ready­
to­
Use
Aerosol
Can
(
19)
Ready­
to­
Use
Fogger
20
Cypermethrin
Long­
term
Scenarios
(
Dermal
and
Inhalation
Exposure):

Mixer/
Loader/
Applicator:

(
1)
Liquid
Formulations:
Low
Pressure
Handwand
Sprayer
(
2)
Liquid
Formulations:
Paint
Brush
(
3)
Liquid
Formulations:
Low
Pressure/
High
Volume
Turf/
Handgun
Sprayer
(
4)
Wettable
Powder
Formulations:
Low
Pressure
Handwand
Sprayer
(
5)
Wettable
Powder
Formulations:
Paint
Brush
(
6)
Wettable
Powder
Formulations:
Low
Pressure/
High
Volume
Turf/
Handgun
Sprayer
(
7)
Water
Soluble
Bag
Formulations:
Low
Pressure/
High
Volume
Turf/
Handgun
Sprayer
Zeta­
Cypermethrin
Short­
and
Intermediate­
term
Scenarios
(
Inhalation
Exposure
only):

Mixer/
Loader:

(
1a)
Liquid
Formulations:
Mixing/
Loading
to
support
Aerial
Applications
(
1b)
Liquid
Formulations:
Mixing/
Loading
to
support
Chemigation
Applications
(
1c)
Liquid
Formulations:
Mixing/
Loading
to
support
Groundboom
Applications
(
1d)
Liquid
Formulations:
Mixing/
Loading
to
support
Airblast
Applications
(
2)
Loading
Dusts
into
Mechanical
Duster
(
using
PHED
wettable
powders
data)

Applicator:
(
3)
Applying
with
Sprays
with
Aircraft
(
4)
Applying
with
Groundboom
Equipment
(
5)
Applying
with
Airblast
Equipment
(
6)
Applying
Dusts
via
Mechanical
Duster
Flagger:
(
7)
Flagging
to
support
Aerial
Spray
Applications
Mixer/
Loader/
Applicator:
(
8)
Liquid
Formulations:
Low
Pressure
Handwand
Sprayer
(
9)
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
(
10)
Applying
Dusts
via
Shaker
Can
(
MRID
444598­
01)
(
11)
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Watering
Can
(
using
ORETF
residential
hose­
end
data)
(
12)
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Paint
Brush
(
13)
Applying
Ready
to
Use
Ear­
Tags
(
14)
Loading
Dusts
into
Self­
Applying
Dust
Bags
(
using
PHED
mixing/
loading
wettable
powders
data)
21
Zeta­
Cypermethrin
Long­
term
Scenarios
(
Dermal
and
Inhalation
Exposure):

Mixer/
Loader/
Applicator:

(
1)
Mixing/
Loading/
Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
PHED)
(
2)
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
(
3)
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Watering
Can
(
using
ORETF
residential
hose­
end
data)
(
4)
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Paint
Brush
2.1.2
Data
and
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:

C
Average
body
weight
of
an
adult
handler
is
70
kg.

C
Handler
assessments
were
completed
using
PHED,
ORETF,
and
proprietary
data.
Some
of
the
PHED
data
were
"
low
quality"
but
were
used
because
of
the
lack
of
a
more
acceptable
dataset.
The
PHED
unit
exposure
values
range
between
the
geometric
mean
and
the
median
of
the
available
exposure
data.
The
ORETF
data
were
high
quality
and
geometric
mean
values
were
used.
Proprietary
data
were
used
to
assess
the
pump­
trigger
sprayer
scenario.
No
chemical­
specific
or
reasonable
surrogate
data
were
available
to
assess
the
ready­
to­
use
wipe
and
eartag
scenarios.
This
represents
a
data
gap.
However,
it
is
assumed
that
short­
and
intermediate­
term
inhalation
exposures
and
risks
to
handlers
in
these
scenarios
would
be
lower
than
exposures
and
risks
from
applying
with
a
ready­
touse
aerosol
can.

C
Short­
term,
intermediate­
term,
and
long­
term
risk
assessments
were
completed
based
on
the
toxicity
endpoints
that
were
identified.
HED
only
anticipates
a
limited
number
of
scenarios
that
are
long­
term
in
nature,
including
pest
control
operators
and
lawn
care
operators.

C
For
risk
assessments,
HED
always
considers
the
maximum
application
rates
allowed
by
labels
in
its
risk
assessments
in
order
to
be
able
to
consider
what
is
legally
possible
based
on
the
label.
The
maximum
application
rates
for
cypermethrin
are
listed
in
Tables
5a
and
5b
and
those
for
zeta­
cypermethrin
are
listed
in
Tables
6a
and
6b.

C
The
average
occupational
workday
is
assumed
to
be
8
hours.
22
C
The
daily
areas
to
be
treated
were
defined
for
each
handler
scenario
(
in
appropriate
units)
by
determining
the
amount
that
can
be
reasonably
treated
in
a
single
day
(
e.
g.
acres,
square
feet,
cubic
feet,
gallons,
animals).
When
possible,
the
assumptions
for
daily
areas
treated
is
taken
from
the
Health
Effects
Division
Science
Advisory
Committee
on
Exposure
Policy
9:
Standard
Values
for
Daily
Acres
Treated
in
Agriculture
which
was
revised
on
July
5,
2000.
However,
no
standard
values
are
available
for
scenarios
involving
livestock
treatments,
or
applications
using
aerosol
cans,
ready­
to­
use
foggers,
or
termiticide
injection
equipment.
Assumptions
for
these
scenarios
are
based
on
Health
Effects
Division
estimates
and
could
be
further
refined
from
input
from
affected
sectors.
The
daily
areas
treated
for
cypermethrin
are
listed
in
Tables
5a
and
5b
and
those
for
zetacypermethrin
are
listed
in
Tables
6a
and
6b.

C
Unit
exposure
values
were
used
to
estimate
exposures
to
handlers.
These
unit
exposure
values
were
from
the
Pesticide
Handlers
Exposure
Database
(
PHED),
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF),
the
Chemical
Manufacturers
Association
studies,
and
a
proprietary
study.

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

Chemical­
specific
data
for
assessing
human
exposures
during
pesticide
handling
activities
were
submitted
to
the
Agency
in
support
of
one
occupational
exposure
scenario
for
the
reregistration
of
cypermethrin.
It
is
the
policy
of
HED
to
combine
submitted
chemical­
specific
data
with
that
from
the
Pesticide
Handlers
Exposure
Database
(
PHED)
Version
1.1
when
appropriate
to
assess
handler
exposures
for
regulatory
actions.
The
scenario/
chemical­
specific
study
submitted
has
no
corresponding
scenario
in
PHED,
therefore,
unit
exposure
values
from
the
study
are
used
to
calculate
exposure
and
risk
for
the
use
pattern.
For
all
other
remaining
scenarios,
data
from
PHED
were
used
to
complete
the
assessment.

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
exposure
values
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.,
wettable
powders,
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
23
(
milligrams
of
exposure
per
pound
of
active
ingredient
handled).
Following
normalization,
the
data
are
statistically
summarized.
The
distribution
of
exposure
values
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
values
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
exposure
values
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.
These
evaluation
criteria
and
the
caveats
specific
to
each
exposure
scenario
are
summarized
in
Appendix
A.
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
cases.
HED
has
developed
a
series
of
tables
of
standard
unit
exposure
values
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
exposure
values
for
varying
levels
of
personal
protection
if
data
were
not
available.

ORETF
Handler
Studies
(
EPA
MRID
449722­
01)

A
report
was
submitted
by
the
ORETF
(
Outdoor
Residential
Exposure
Task
Force)
that
presented
exposure
data
in
which
the
application
of
various
products
used
on
turf
by
homeowners
and
lawncare
operators
(
LCOs)
was
monitored.

Handgun
Studies
(
OMA002):
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.
24
An
additional
ten
replicates
at
each
site
were
monitored
while
they
performed
spray
application
only
using
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
closest
field
spike
level
for
each
matrix
and
correcting
the
value
to
100
percent.
The
unit
exposure
values
are
presented
below.
[
Note
the
data
were
found
to
be
lognormally
distributed.
As
a
result,
all
exposure
values
are
geometric
means.]

Table
7:
ORETF
LCO
Exposure
Study
Data
(
MRID
449722­
01):
Handgun
Sprayer
Application
Method/
Job
Function
Study
Number
Statistic
Total
Dermal
Unit
Exposure
(
mg/
lb
ai)

Statistic
Inhalation
Unit
Exposure
(
µ
g/
lb
ai)
1
Single
Layer,
No
Gloves
Single
Layer,
Gloves
Double
Layer,
Gloves
2
LCO
Handgun
Spray
Mixer/
Loader
Applicator
OMA002
Liquid
Flowable3
[
15
replicates]
Geomean
No
Data
0.45
0.25
Arithmetic
1.8
LCO
Handgun
Spray
Mixer/
Loader
Applicator
OMA002
Wettable
Powder
3
[
15
replicates]
Geomean
No
Data
0.80
0.43
Geomean
64
Table
7:
ORETF
LCO
Exposure
Study
Data
(
MRID
449722­
01):
Handgun
Sprayer
Application
Method/
Job
Function
Study
Number
Statistic
Total
Dermal
Unit
Exposure
(
mg/
lb
ai)

Statistic
Inhalation
Unit
Exposure
(
µ
g/
lb
ai)
1
Single
Layer,
No
Gloves
Single
Layer,
Gloves
Double
Layer,
Gloves
2
25
LCO
Handgun
Spray
Mixer/
Loader
Applicator
OMA002
Wettable
Powder
in
Water
Soluble
Bags
3
[
15
replicates]
Median
No
Data
0.64
0.37
Geomean
7.2
1Air
concentration
(
mg/
m3/
lb
ai)
calculated
using
NAFTA
`
99
standard
breathing
rate
of
17
lpm
(
1
m3/
hr)
2Exposure
calculated
using
OPP/
HED
50%
protection
factor
(
PF)
for
cotton
coveralls
on
torso,
arms,
legs.
3All
commercial
handlers
wore
long
pants,
long­
sleeved
shirt,
nitrile
gloves
and
shoes.

Hose
End
Sprayer
Study
(
OMA004):
A
mixer/
loader/
applicator
study
was
performed
by
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF)
using
Diazinon
as
a
surrogate
compound
to
determine
"
generic"
exposures
to
individuals
applying
a
pesticide
to
turf
with
a
dial
type
hose
end
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
30
replicates
were
monitored
throughout
the
study.
Diazinon
(
25%
emulsifiable
concentrate)
was
applied
by
homeowners
to
actual
residential
lawns
at
a
site
in
Maryland.
A
target
application
rate
of
4
pounds
active
ingredient
was
used
for
all
replicates.
Each
replicate
monitored
the
test
subject
treating
5,000
ft2
of
turf
and
handling
a
total
of
0.5
lb
ai/
replicate.
The
exposure
periods
(
mixing/
loading/
applying)
averaged
seventy­
five
minutes.
Dermal
exposure
was
measured
using
inner
and
outer
whole
body
dosimeters,
hand
washes,
face/
neck
washes,
and
personal
air
monitoring
devices.
In
general,
concurrent
lab
spikes
produced
mean
recoveries
in
the
range
of
87­
103
percent.
Adjustment
for
recoveries
from
field
fortifications
(
79­
104
%)
were
performed
on
each
dosimeter
section
or
sample
matrix
for
each
study
participant,
using
the
mean
recovery
for
the
closest
field
spike
level
for
each
matrix
and
correcting
the
value
to
100
percent.
The
unit
exposure
values
are
presented
below.
[
Note
the
data
were
found
to
be
lognormally
distributed.
As
a
result,
all
exposure
values
are
geometric
means.]

Table
8
reports
the
dermal
unit
exposures
for
the
various
clothing
scenarios
and
the
inhalation
unit
exposure
at
baseline
(
no
respirator).
26
Table
8:
ORETF
Resident­
Applicator
Exposure
Study
Data
(
MRID
449722­
01)

Application
Method/
Job
Function
Study
Number
Statistic
Total
Dermal
Unit
Exposure
(
mg/
lb
ai)

Statistic
Inhalation
Unit
Exposure
(
µ
g/
lb
ai)
1
Short
Pants,
Short
Sleeves
Long
Pants,
Short
Sleeves
Long
Pants,
Long
Sleeves
Resident
Mixer/
loader/
applicator
Hose­
end
Sprayer:
"
Mix
your
own"
3
OMA004
[
30
replicates]
Geomean
11
6.2
5.6
Geomean
17
1Air
concentration
(
mg/
m3/
lb
ai)
calculated
using
NAFTA
`
99
standard
breathing
rate
of
17
lpm
(
1
m3/
hr).
2
Shorts
and
short­
sleeved
shirt
worn.
3
Long
pants,
long
sleeve
shirt,
no
gloves
worn.
Short
sleeves
calculated
from
dosimeter.

Low
Pressure
Handwand
Study
(
OMA005):
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
handheld
pump
sprayers
(
low
pressure
handwands).

Each
replicate
opened
the
end­
use
product,
added
it
to
the
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
27
µ
g/
sample.

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
9
below.

Table
9:
Unit
Exposure
Values
From
ORETF
Homeowner
Low
Pressure
Handwand
Studies
(
MRID
445185­
01)

Type
Dermal:
Long
Pants,
Long
Sleeves
(
mg
ai/
lb
handled)
Inhalation
(
µ
g
ai/
lb
handled)

Low
Pressure
Handwand
30.0
3.8
All
unit
exposure
values
are
geometric
means.

Dust
Study
(
OMA007):
The
data
collected
reflect
the
dermal
and
respiratory
exposure
of
homeowners
mixing,
loading
and
applying
Sevin
®
10
Dust,
a
carbaryl
end­
use
product.
Applications
were
made
by
volunteers
to
two
18
foot
rows
of
tomatoes
and
one
18
foot
row
of
cucumber.
The
only
test
field
was
located
in
Florida.
Exposure
for
each
was
monitored
using
20
replicates
which
consisted
of
loading
the
dusters
and
applying
the
dust
without
gloves.

Each
replicate
opened
the
end­
use
product,
added
it
to
the
application
implement,
adjusted
the
setting
and
applied
it
to
the
vegetable
rows.
After
application
to
the
vegetable
rows,
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,
face/
neck
wipes,
and
glove
and
hand
washes.
The
inner
and
outer
dosimeters
were
segmented
into:
lower
and
upper
arms,
lower
and
upper
legs,
front
and
back
torso.

Field
fortification
recoveries
for
passive
dosimeters
averaged
84.3
percent
for
inner
and
77.7
percent
for
outer
dosimeters.
Face
and
neck
wipe
fortifications
average
84.8
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.

Dermal
exposure
was
determined
by
adding
the
values
from
the
bare
hand
rinses,
28
face/
neck
wipes
to
the
outer
dosimeter
lower
legs
and
lower
arms
plus
the
inner
dosimeter
front
and
rear
torso,
upper
legs,
lower
legs,
lower
arms,
and
upper
arms.
This
accounts
for
the
residential
handlers
with
bare
hands
wearing
short­
sleeved
shirt
and
short
pants.
Unit
exposures
for
this
scenario
are
presented
below
in
Table
10.
[
Note:
The
geometric
mean
values
were
used
for
risk
assessment
purposes.]

Table
10:
Unit
Exposure
Values
Obtained
From
ORETF
Homeowner
Duster
Studies
(
MRID
444598­
01)

Type
Dermal:
Long
Pants,
Long
Sleeves
(
mg
ai/
lb
handled)
Inhalation
(
µ
g
ai/
lb
handled)

Duster
76
620
All
unit
exposure
values
are
geometric
means.

Chemical
Manufacturers
Association
(
CMA)
Antimicrobial
Exposure
Assessment
Study:

The
CMA
exposure
study
(
December
1992)
was
a
response
to
March
4,
1987
data
call­
in
notice
by
EPA.

CMA
is
a
generic
biocide
exposure
assessment
protocol
used
to
assess
potential
dermal
and/
or
inhalation
exposure
from
the
application
of
antimicrobial
pesticide
products
in
multiple
settings
using
various
application
methods.
The
study
examined
nine
separate
antimicrobial
pesticides
and
variety
of
application
methods
for
a
total
number
of
88
replicates.
Dermal
exposure
was
measured
with
the
use
of
pads
attached
to
the
inside
and
the
outside
of
the
applicators
clothing.
Inhalation
exposure
was
monitored
continuously
by
chemical
specific
collection
media
using
a
personal
sampling
pump.

The
CMA
exposure
study
assessed
exposures
to
individuals
who
used
wipes
to
apply
antimicrobial
pesticides.
There
were
six
wipe
replicates
(
no
gloves)
in
the
study.
Unit
exposures
for
this
scenario
are
presented
below
in
Table
11.
While
the
wipe
data
from
CMA
provide
the
best
available
information
on
handler
exposures
for
the
wipe
and
sponge
scenarios,
it
should
be
noted
that
some
aspects
of
the
study
are
issues
such
as:
good
labor
practices
were
not
closely
followed,
extraction
efficiencies
were
below
the
minimum
level
suggested
in
the
guidelines,
calibration
of
the
air
monitoring
equipment
resulted
in
much
of
the
data
being
less
than
detection,
and
the
limited
number
of
replicates
(
the
guidelines
recommend
15
replicates).

Table
11:
Unit
Exposure
Values
Obtained
From
CMA
Exposure
Assessment
Study
Type
Dermal:
No
gloves
(
mg
ai/
lb
handled)
Inhalation
(
µ
g
ai/
lb
handled)

Wipe
2870
0.067
All
unit
exposure
values
are
arithmetic
means.
29
Proprietary
Data
Trigger
Sprayer
Study
(
EPA
MRID
410547­
01)
A
total
of
15
applicator
events
during
residential
applications
using
a
hand­
operated
trigger
pump
sprayer,
attached
with
an
18
inch
hose
to
half
gallon
cans
containing
0.95
percent
propoxur,
were
completed
in
this
study.
The
study
was
completed
between
October
26
and
November
1,
1988
in
the
Kansas
City
Missouri
metro
area.
Each
person
monitored
in
the
study
was
a
Bayer
(
the
sponsor
corporation)
employee.
Three
employees
were
used
to
complete
all
replicates.
In
each
replicate,
"
each
applicator
used
a
separate
one­
half
gallon
can
of
Raid
for
each
house.
The
cap
was
removed
from
the
top
of
the
can
and
the
hose
sprayer
was
attached
by
inserting
the
dip
tube
into
the
can
and
tightening
the
screw
cap.
The
sprayer
was
primed
by
pumping
the
trigger.
The
applicator
treated
the
outside
of
the
home
in
areas
where
pests
were
likely
to
be
found,
such
as
screens,
door
and
window
frames,
foundation
walls,
patios,
porches,
stoops,
and
decks.
When
the
application
was
completed,
the
hose
sprayer
was
secured
under
the
handle
of
the
can."
The
data
included
in
the
study
indicate
that
exposure
durations
ranged
from
9
to
21
minutes
per
replicate
and
the
amount
of
active
ingredient
handled
ranged
from
0.16
to
0.4
oz
(
i.
e.,
0.01
to
0.025
lb
ai).
Dermal
(
nonhand)
exposure
monitoring
during
each
replicate
was
completed
using
gauze
sponges
held
in
"
aluminized
paper
holders"
with
an
open
sampling
surface
area
of
24.6
cm2
while
hand
exposures
were
quantified
with
the
handwash
technique
(
2
­
200
mL
aliquots
of
ethanol
per
hand
for
a
total
volume
of
800
mL
per
person).
Inhalation
exposures
were
monitored
using
standard
personal
sampling
pumps
operating
a
1
liter
per
minute
with
quartz
microfiber
filters.
Samples
were
collected
in
this
study
to
represent
exposures
when
a
person
was
wearing
normal
work
clothing
(
i.
e.,
long
pants
and
long­
sleeved
shirts)
and
chemical­
resistant
gloves.

Analysis
of
propoxur
residues
was
completed
with
high
performance
liquid
chromatography,
post­
column
derivatization,
and
fluorescence
detection.
The
limits
of
quantification
(
LOQ)
were
10
µ
g
per
sample
for
the
handwash
solutions,
0.1
µ
g/
sample
for
the
inhalation
filters,
and
0.03
µ
g/
cm2
for
the
dermal
patch
samples.
Field
and
laboratory
recovery
data
were
generated
for
all
media.
This
study
was
reviewed
in
September
1989
under
EPA
contract
68­
02­
4254
by
Versar.
The
values
used
for
regulatory
purposes
have
been
excerpted
from
that
review
(
including
recovery
results).
Average
laboratory
recovery
for
all
media
ranged
from
99.2
to
109
percent
while
the
coefficients
of
variation
for
each
media
were
generally
less
than
5
(
i.
e.,
for
the
patches,
the
CV
=
16.5).
Patches
and
filters
were
fortified
at
1
µ
g/
sample
while
hand
rinses
were
fortified
at
either
200
or
1000
µ
g/
sample.
Average
field
recovery
results
ranged
from
90.3
to
102.2
percent
while
coefficients
of
variation
also
were
generally
less
than
5
(
i.
e.,
inside
patch
CV=
6.9).
Patches
were
fortified
at
levels
from
1
to
50
µ
g/
sample,
hand
rinses
were
fortified
at
200
µ
g/
sample,
and
filters
were
fortified
at
0.2
µ
g/
sample.
Unit
exposures
for
this
scenario
in
each
are
presented
below
in
Table
12.
30
Table
12:
Unit
Exposure
Values
Obtained
From
Propoxur
Trigger
Pump
Sprayer
Study
(
MRID
410547­
01)

Type
Dermal
(
mg
ai/
lb
handled)
Inhalation
(
µ
g
ai/
lb
handled)

Trigger
Pump
Sprayer
76
1.9
2.1.3
Occupational
Handler
Exposure
and
Risk
Estimates
The
occupational
handler
exposure
and
risk
calculations
are
presented
in
this
section.
Risks
were
calculated
using
the
Margin
of
Exposure
(
MOE),
which
is
a
ratio
of
the
body
burden
to
the
toxicological
endpoint
of
concern.
Body
burden
values
are
calculated
by
first
calculating
exposures
by
considering
application
parameters
(
i.
e.,
rate
and
area
treated)
along
with
unit
exposure
levels.
Exposures
were
then
normalized
by
body
weight
and
adjusted
for
absorption
factors
as
appropriate
to
calculate
dose
levels
(
i.
e.,
body
burdens).
MOEs
were
then
calculated.

Daily
Exposure:
The
daily
exposure,
daily
dose
and
hence
the
risks
to
handlers
were
calculated
as
described
below.
The
first
step
was
to
calculate
daily
exposure
(
dermal
or
inhalation)
using
the
following
formula:

Daily
Exposure
(
mg
ai/
day)
=

Unit
Exposure
x
Application
Rate
x
Daily
amount
Treated
Where:

Daily
Exposure
=
Amount
deposited
on
the
surface
of
the
skin
that
is
available
for
dermal
absorption
or
amount
that
is
inhaled,
also
referred
to
as
potential
dose
(
mg
ai/
day);
Unit
Exposure
=
Normalized
exposure
value
derived
from
August
1998
PHED
Surrogate
Exposure
Table
and
various
referenced
exposure
studies
noted
above
(
mg/
lb
ai
or
:
g/
lb
ai);
Application
Rate
=
Normalized
application
rate
based
on
a
logical
unit
treatment,
such
as
acres,
square
feet,
gallons,
or
cubic
feet.
Maximum
values
are
generally
used
(
lb
ai/
A,
lb
ai/
sq
ft,
lb
ai/
gal,
lb
ai/
cu
ft);
and
Daily
Area
Treated
=
Normalized
application
area
based
on
a
logical
unit
treatment
such
as
acres
(
A/
day),
square
feet
(
sq
ft/
day),
gallons
per
day
(
gal/
day),
or
cubic
feet
(
cu
ft/
day).

Daily
Dose:
Daily
dose
(
inhalation
or
dermal)
was
calculated
by
normalizing
the
daily
dermal
or
inhalation
exposure
value
by
body
weight
and
accounting
for
an
inhalation
or
dermal
absorption
(
i.
e.,
a
biologically
available
dose
resulting
from
dermal
or
inhalation
exposure
was
then
calculated).
For
adult
handlers
using
cypermethrin
or
zeta­
cypermethrin,
an
average
adult
body
weight
of
70
kg
was
used
for
all
exposure
scenarios
because
the
endpoints
were
not
sexspecific
No
dermal
penetration/
absorption
studies
are
available
for
cypermethrin
or
zetacypermethrin
A
dermal
absorption
value
of
2.5%
may
be
estimated
by
comparing
the
maternal
31
LOAEL
of
25
mg/
kg/
day
from
the
developmental
study
in
the
rat
and
the
NOAEL
(
highest
dose
tested)
of
1000
mg/
kg/
day
from
the
21­
day
dermal
study
in
the
rat.
Since
there
was
no
common
endpoint
because
no
effects
were
observed
in
the
21­
day
dermal
study
in
the
rat,
this
is
considered
to
be
a
worst­
case
estimate.
No
inhalation
absorption
factor
is
necessary,
since
the
inhalation
endpoints
are
based
on
an
inhalation
study.
Daily
dose
was
calculated
using
the
following
formula:

Daily
dermal
or
inhalation
dose
(
mg/
kg/
day)
=

daily
exposure
/
body
weight
x
absorption
factor
(
if
needed)

Where:

Average
Daily
Dose
=
The
amount
as
absorbed
dose
received
from
exposure
to
a
pesticide
in
a
given
scenario
(
mg
pesticide
active
ingredient
per
kg
body
weight
per
day,
also
referred
to
as
ADD);
Daily
Exposure
=
Amount
deposited
on
the
surface
of
the
skin
that
is
available
for
dermal
absorption
or
amount
that
is
inhaled,
also
referred
to
as
potential
dose
(
mg
ai/
day);
Absorption
Factor
=
A
measure
of
the
flux
or
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:
Finally,
the
calculations
of
daily
dermal
dose
and
daily
inhalation
dose
received
by
handlers
were
then
compared
to
the
appropriate
endpoint
(
i.
e.,
NOAEL)
to
assess
the
total
risk
to
handlers
for
each
exposure
route
within
the
scenarios.
Long­
term
dermal
MOEs
were
calculated
using
a
NOAEL
of
6
mg/
kg/
day
and
inhalation
MOEs
for
all
durations
were
calculated
using
a
NOAEL
of
2.7
mg/
kg/
day
(
Table
1).
All
MOE
values
were
calculated
separately
for
dermal
and
inhalation
exposure
levels
using
the
formula
below:

Dermal
or
Inhalation
MOE
=
Daily
Dose
(
mg/
kg/
day)
/
NOAEL(
mg/
kg/
day)

Where:

MOE
=
Margin
of
exposure,
value
used
by
the
Agency
to
represent
risk
or
how
close
a
chemical
exposure
is
to
being
a
concern
(
unitless);
ADD
=
(
Average
Daily
Dose)
or
the
amount
as
absorbed
dose
received
from
exposure
to
a
pesticide
in
a
given
scenario
(
mg
pesticide
active
ingredient
per
kg
body
weight
per
day);
and
NOAEL
=
Dose
level
in
a
toxicity
study,
where
no
observed
adverse
effects
occurred
(
NOAEL)
in
the
study
or
the
lowest
dose
level
where
an
adverse
effect
occurred.

The
target
MOEs
for
long­
term
occupational
workers
are
100
for
dermal
and
300
for
inhalation
risk.
The
adverse
effects
seen
in
both
the
dermal
and
inhalation
studies
were
loss
of
body
weight;
therefore,
the
MOEs
were
combined
to
identify
a
total
aggregated
risk
index
(
ARI).
32
An
ARI
was
used
since
the
target
MOE
values
for
inhalation
and
dermal
exposure
were
different.
The
target
ARI
is
1,
therefore,
ARIs
of
less
than
1
are
risks
of
concern.

Long­
term
aggregate
risk
index
(
ARI)
=
1/((
1/(
calculated
dermal
MOE/
target
MOE
(
100))
+
(
1/(
calculated
inhalation
MOE/
target
MOE
(
300))).
The
target
level
is
1.

Risk
Summary:

All
of
the
risk
calculations
for
occupational
cypermethrin
and
zeta­
cypermethrin
handlers
completed
in
this
assessment
are
included
in
Appendix
A.

Occupational
Risk
Summary:

Short­
and
Intermediate­
term
Risk
Summary
Short­
and
intermediate­
term
dermal
exposures
and
risks
were
not
assessed
for
cypermethrin
and
zeta­
cypermethrin,
since
no
short­
or
intermediate­
term
dermal
endpoint
was
identified.

Cypermethrin
Cypermethrin
inhalation
risks
are
summarized
in
Table
13
below.

When
data
were
available
to
assess
risks,
short­
and
intermediate­
term
inhalation
risks
to
occupational
handlers
are
below
the
Agency's
level
of
concern
for
risk
assessments
(
i.
e.,
MOE
$

100)
at
baseline
(
i.
e.,
no
respirator)
for
all
the
formulations,
except
wettable
powder
formulations.
For
several
scenarios
involving
wettable
powder
formulation,
risks
are
above
HED's
level
of
concern
(
i.
e.,
MOEs
are
less
than
100)
at
baseline
(
i.
e.,
no
respirator).
The
addition
of
a
dust/
mist
filtering
respirator
reduces
the
risks
to
below
HED's
level
of
concern
for
all
these
scenarios,
except
mixing/
loading
to
support
aerial
or
groundboom
applications
to
agricultural
uncultivated
areas,
fencerows,
and
hedgerows
and
mixing/
loading
to
support
aerial
applications
to
sodfarms.
For
these
three
scenarios,
engineering
controls
(
i.
e.,
water­
soluble
packaging)
are
necessary
to
reduce
the
inhalation
risks
to
below
HED's
level
of
concern.
EPA
has
insufficient
data
to
assess
exposures
to
pilots
in
open
cockpits.
Inhalation
risks
to
pilots
in
enclosed
cockpits
(
engineering
control
scenario)
were
not
a
concern
for
all
agricultural
crop
scenarios.
No
data
are
available
to
assess
inhalation
risks
during
the
application
of
impregnated
eartags
to
horses,
however,
the
risks
are
expected
to
be
well
below
the
inhalation
risks
(
MOE
=
15,000)
from
applications
using
a
ready­
to­
use
aerosol
can
(
considered
to
represent
a
worst
case
exposure
scenario
for
applications
of
impregnated
eartags
to
horses).

Short­
and
intermediate­
term
dermal
risks
were
not
assessed
for
occupational
handlers,
since
no
short­
or
intermediate­
term
dermal
endpoint
was
identified.

Zeta­
Cypermethrin
33
Zeta­
cypermethrin
inhalation
risks
are
summarized
in
Table
14
below.

When
data
were
available
to
assess
risks,
short­
and
intermediate­
term
inhalation
risks
to
occupational
handlers
are
below
the
Agency's
level
of
concern
for
risk
assessments
(
i.
e.,
MOE
$

100)
at
baseline
(
i.
e.,
no
respirator).
EPA
has
insufficient
data
to
assess
exposures
to
pilots
in
open
cockpits.
Inhalation
risks
to
pilots
in
enclosed
cockpits
(
engineering
control
scenario)
were
not
a
concern
for
all
agricultural
crop
scenarios.
No
data
are
available
to
assess
inhalation
risks
during
the
application
of
dusts
via
a
mechanical
duster
and
application
of
ready­
to­
use
eartags.

Short­
and
intermediate­
term
dermal
risks
were
not
assessed
for
occupational
handlers,
since
no
short­
or
intermediate­
term
dermal
endpoint
was
identified.
34
Table
13:
Cypermethrin
Occupational
Handler
Short­
and
Intermediate­
Term
Inhalation
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
MOEc
Dust/
Mist
Respirator
Inhalation
MOEd
Engineering
Control
Inhalation
MOEe
Mixer/
Loader
Mixing/
Loading
Liquid
Concentrates
for
Aerial
Application
(
1a)
agricultural
uncultivated
areas;
fencerows,
hedgerows
3.4
lb
ai/
acre
350
acres
130
660
1,900
cotton
0.1
lb
ai/
acre
1200
acres
1,300
6,600
19,000
broccoli,
broccoli
raab,
brussel
sprouts,
bok
choy,
cabbage,

cauliflower,
cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,
kale,
kohlrabi
mizuna,
mustard
greens,

mustard
spinach,
pecans,
rape
greens
0.1
lb
ai/
acre
350
acres
4,500
23,000
65,000
Mixing/
Loading
Liquid
Concentrates
for
Chemigation
Application
(
1b)
broccoli,
broccoli
raab,
brussel
sprouts,
bok
choy,
cabbage,

cauliflower,
cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
cotton,
head
lettuce,
kale,
kohlrabi
mizuna,
mustard
greens,
mustard
spinach,
pecans,
rape
greens
0.1
lb
ai/
acre
350
acres
4,500
23,000
65,000
Mixing/
Loading
Liquid
Concentrates
for
Groundboom
Application
(
1c)
agricultural
uncultivated
areas;
fencerows,
hedgerows
3.4
lb
ai/
acre
80
acres
580
2,900
8,400
ornamental
plants
3.4
lb
ai/
acre
40
acres
1,200
5,800
17,000
cotton
0.1
lb
ai/
acre
200
acres
7,900
39,000
110,000
broccoli,
broccoli
raab,
brussel
sprouts,
bok
choy,
cabbage,

cauliflower,
cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,
kale,
kohlrabi
mizuna,
mustard
greens,

mustard
spinach,
pecans,
rape
greens
0.1
lb
ai/
acre
80
acres
20,000
98,000
280,000
Mixing/
Loading
Liquid
Concentrates
for
Airblast
Application
(
1d)
pecans
0.1
lb
ai/
acre
40
acres
39,000
200,000
570,000
ornamental
plants
3.4
lb
ai/
acre
20
acres
2,300
12,000
33,000
Mixing/
Loading
Wettable
Powders
for
Aerial
Application
(
2a)
agricultural
uncultivated
areas;
fencerows,
hedgerows
3.4
lb
ai/
acre
350
acres
4
18
660
sodfarms
0.74
lb
ai/
acre
350
acres
17
85
3,000
cotton
0.1
lb
ai/
acre
1200
acres
37
180
6,600
Table
13:
Cypermethrin
Occupational
Handler
Short­
and
Intermediate­
Term
Inhalation
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
MOEc
Dust/
Mist
Respirator
Inhalation
MOEd
Engineering
Control
Inhalation
MOEe
35
Mixing/
Loading
Wettable
Powders
for
Aerial
Application
(
2a)
(
cont.)
broccoli,
broccoli
raab,
brussel
sprouts,
bok
choy,
cabbage,

cauliflower,
cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,
kale,
kohlrabi
mizuna,
mustard
greens,

mustard
spinach,
pecans,
rape
greens,
0.1
lb
ai/
acre
350
acres
130
630
23,000
Mixing/
Loading
Wettable
Powders
for
Chemigation
Application
(
2b)
broccoli,
broccoli
raab,
brussel
sprouts,
bok
choy,
cabbage,

cauliflower,
cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
cotton,
head
lettuce,
kale,
kohlrabi
mizuna,
mustard
greens,
mustard
spinach,
pecans,
rape
greens,
0.1
lb
ai/
acre
350
acres
130
630
23,000
Mixing/
Loading
Wettable
Powders
for
Groundboom
Application
(
2c)
agricultural
uncultivated
areas;
fencerows,
hedgerows
3.4
lb
ai/
acre
80
acres
16
81
2,900
ornamental
plants
3.4
lb
ai/
acre
40
acres
32
160
5,800
sodfarms
0.74
lb
ai/
acre
80
acres
74
370
13,000
cotton
0.1
lb
ai/
acre
200
acres
220
1,100
39,000
broccoli,
broccoli
raab,
brussel
sprouts,
bok
choy,
cabbage,

cauliflower,
cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,
kale,
kohlrabi
mizuna,
mustard
greens,

mustard
spinach,
rape
greens
0.1
lb
ai/
acre
80
acres
550
2,700
98,000
Mixing/
Loading
Wettable
Powders
for
Airblast
Application
(
2d)
ornamental
plants
3.4
lb
ai/
acre
20
acres
65
320
12,000
pecans
0.1
lb
ai/
acre
40
acres
1,100
5,500
200,000
Applicator
Applying
Sprays
with
an
Airplane
(
3)
agricultural
uncultivated
areas;
fencerows,
hedgerows
3.4
lb
ai/
acre
350
acres
see
Eng.
Controls
see
Eng.
Controls
2,300
sodfarms
0.74
lb
ai/
acre
350
acres
see
Eng.
Controls
see
Eng.
Controls
11,000
cotton
0.1
lb
ai/
acre
1200
acres
see
Eng.
Controls
see
Eng.
Controls
23,000
Table
13:
Cypermethrin
Occupational
Handler
Short­
and
Intermediate­
Term
Inhalation
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
MOEc
Dust/
Mist
Respirator
Inhalation
MOEd
Engineering
Control
Inhalation
MOEe
36
Applying
Sprays
with
an
Airplane
(
3)

(
cont.)
broccoli,
broccoli
raab,
brussel
sprouts,
bok
choy,
cabbage,

cauliflower,
cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,
kale,
kohlrabi
mizuna,
mustard
greens,

mustard
spinach,
pecans,
rape
greens
0.1
lb
ai/
acre
350
acres
see
Eng.
Controls
see
Eng.
Controls
79,000
Applying
Sprays
with
Groundboom
Application
(
4)
agricultural
uncultivated
areas;
fencerows,
hedgerows
3.4
lb
ai/
acre
80
acres
940
4,600
16,000
ornamental
plants
3.4
lb
ai/
acre
40
acres
1,900
9,300
32,000
sodfarms
0.74
lb
ai/
acre
80
acres
4,300
21,000
74,000
cotton
0.1
lb
ai/
acre
200
acres
13,000
63,000
220,000
broccoli,
broccoli
raab,
brussel
sprouts,
bok
choy,
cabbage,

cauliflower,
cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,
kale,
kohlrabi
mizuna,
mustard
greens,

mustard
spinach,
rape
greens
0.1
lb
ai/
acre
80
acres
32,000
160,000
550,000
Applying
Sprays
with
an
Airblast
(
5)
ornamental
plants
3.4
lb
ai/
acre
20
acres
620
3,100
6,200
pecans
0.1
lb
ai/
acre
40
acres
11,000
53,000
110,000
Flagger
Flagging
for
Aerial
Sprays
(
6)
agricultural
uncultivated
areas;
fencerows,
hedgerows
3.4
lb
ai/
acre
350
acres
450
2,300
23,000
sodfarms
0.74
lb
ai/
acre
350
acres
2,100
10,000
100,000
broccoli,
broccoli
raab,
brussel
sprouts,
bok
choy,
cabbage,

cauliflower,
cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
cotton,
head
lettuce,
kale,
kohlrabi
mizuna,
mustard
greens,
mustard
spinach,
pecans,
rape
greens
0.1
lb
ai/
acre
350
acres
15,000
77,000
770,000
Mixer/
Loader/
Applicator
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Low
Pressure
Handwand
(
7)
residential,
commercial
and
industrial
lawns
0.44
lb
ai/
acre
5
acres
2,900
14,000
Not
Feasible
Table
13:
Cypermethrin
Occupational
Handler
Short­
and
Intermediate­
Term
Inhalation
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
MOEc
Dust/
Mist
Respirator
Inhalation
MOEd
Engineering
Control
Inhalation
MOEe
37
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Low
Pressure
Handwand
(
7)
(
cont.)
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,

building
perimeters,
masonry
voids,
and
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.05
lb
ai/
gallon
40
gallons
3,200
16,000
Not
Feasible
Termites
applications
to
preconstruction
lumber
and
logs,
and
to
soil
under
firewood
0.041
lb
ai/
gallon
40
gallons
3,800
19,000
Not
Feasible
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,
commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
applications
to
horses
0.017
lb
ai/
gallon
40
gallons
9,300
46,000
Not
Feasible
ornamental
plants;
termite
applications
to
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.008
lb
ai/
gallon
40
gallons
20,000
98,000
Not
Feasible
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Paintbrush
(
8)
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,

building
perimeters,
masonry
voids,
and
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.05
lb
ai/
gallon
5
gallons
2,700
14,000
Not
Feasible
Termites
applications
to
preconstruction
lumber
and
logs,
and
to
soil
under
firewood
0.041
lb
ai/
gallon
5
gallons
3,300
16,000
Not
Feasible
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,
commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
0.017
lb
ai/
gallon
5
gallons
7,900
40,000
Not
Feasible
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Handheld
Handgun
(
ORETF)
(
9)
agricultural
uncultivated
areas;
fencerows,
hedgerows;
ornamental
plants;
potting
soil,
topsoil
3.4
lb
ai/
acre
5
acres
6,200
31,000
Not
Feasible
residential,
commercial
and
industrial
lawns
0.44
lb
ai/
acre
5
acres
48,000
240,000
Not
Feasible
Mixing/
Loading/
Applying
Liquid
Concentrates
with
an
Termiticide
Injector
(
10)
Termites:
trees,
utility
poles,
fenceposts,
building
voids
0.05
lb
ai/
gallon
500
gallons
3,400
17,000
Not
Feasible
Mixing/
Loading/
Applying
Wettable
Powders
with
a
Low
Pressure
Handwand
(
11)
residential,
commercial
and
industrial
lawns
0.6
lb
ai/
acre
5
acres
57
290
Not
Feasible
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,

building
perimeters,
masonry
voids,
and
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.05
lb
ai/
gallon
40
gallons
86
430
Not
Feasible
fire
ant
mounds
0.033
lb
ai/
gallon
40
gallons
130
650
Not
Feasible
Table
13:
Cypermethrin
Occupational
Handler
Short­
and
Intermediate­
Term
Inhalation
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
MOEc
Dust/
Mist
Respirator
Inhalation
MOEd
Engineering
Control
Inhalation
MOEe
38
Mixing/
Loading/
Applying
Wettable
Powders
with
a
Low
Pressure
Handwand
(
11)
(
cont.)
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,
commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
applications
to
horses
0.017
lb
ai/
gallon
40
gallons
250
1,300
Not
Feasible
ornamental
plants;
termite
applications
to
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.008
lb
ai/
gallon
40
gallons
540
2,700
Not
Feasible
Mixing/
Loading/
Applying
Wettable
Powders
with
a
Paintbrush
(
using
PHED
liquid
paintbrush)
(
12)
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,

building
perimeters,
masonry
voids,
and
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.05
lb
ai/
gallon
5
gallons
2,700
14,000
Not
Feasible
Termites
applications
to
preconstruction
lumber
and
logs,
and
to
soil
under
firewood
0.041
lb
ai/
gallon
5
gallons
3,300
16,000
Not
Feasible
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,
commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
0.017
lb
ai/
gallon
5
gallons
7,900
40,000
Not
Feasible
Mixing/
Loading/
Applying
Wettable
Powders
Formulations
with
a
Handheld
Handgun
(
ORETF)
(
13)
agricultural
uncultivated
areas;
fencerows,
hedgerows;
ornamental
plants;
potting
soil,
topsoil
3.4
lb
ai/
acre
5
acres
170
870
Not
Feasible
residential,
commercial
and
industrial
lawns
0.6
lb
ai/
acre
5
acres
980
4,900
Not
Feasible
Mixing/
Loading/
Applying
Wettable
Powders
in
Water
Soluble
Packaging
with
a
Handheld
Handgun
(
ORETF)
(
14)
agricultural
uncultivated
areas;
fencerows,
hedgerows;
ornamental
plants;
potting
soil,
topsoil
3.4
lb
ai/
acre
5
acres
1,500
7,700
Not
Feasible
residential,
commercial
and
industrial
lawns
0.6
lb
ai/
acre
5
acres
8,800
44,000
Not
Feasible
Applying
Ready
to
Use
Formulations
via
RTU
Tag
(
15)
cattle
0.003
lb
ai/
2
ear
tags
100
and
1000
cattle
No
Data
No
Data
Not
Feasible
Applying
Ready
to
Use
Formulations
with
Pump
Trigger
Sprayers
(
16)
horses
0.017
lb
ai/
gallon
1
gallon
90,000
450,000
Not
Feasible
Applying
Ready
to
Use
Formulations
with
Wipes
(
17)
horses
0.00041
lb
ai/
wipe
500
horses
14,000,000
69,000,000
Not
Feasible
50
horses
140,000,00
0
690,000,000
Not
Feasible
Applying
Ready
to
Use
Formulations
with
Aerosol
Cans
(
18)
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,
commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
0.005
lb
ai/
16
oz
can
2
cans
15,000
73,000
Not
Feasible
Table
13:
Cypermethrin
Occupational
Handler
Short­
and
Intermediate­
Term
Inhalation
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
MOEc
Dust/
Mist
Respirator
Inhalation
MOEd
Engineering
Control
Inhalation
MOEe
39
Applying
Ready
to
Use
Formulations
with
Fogger
(
19)
Non­
termite
applications
to
indoor
spaces
at
residential,
commercial
and
industrial
sites,
animal
premises,
and
greenhouses
0.0014
lb
ai/
fogger
4
foggers
26,000
130,000
Not
Feasible
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
cypermethrin.

b
Amount
handled
per
day
values
are
EPA
estimates
of
acreage
treated
or
gallons
applied
based
on
Exposure
SAC
Policy
#
9
"
Standard
Values
for
Daily
Acres
Treated
in
Agriculture".

c
Baseline
inhalation
MOE
=
short­
and
intermediate­
term
NOAEL
(
2.7
mg/
kg/
day)
/
baseline
inhalation
dose
(
mg/
kg/
day)
and
represents
no
respiratory
protection.

d
80%
PPE­
R
inhalation
MOE
=
short­
and
intermediate­
term
NOAEL
(
2.7
mg/
kg/
day)
/
80
percent
PPE­
R
inhalation
dose
(
mg/
kg/
day)
and
represents
use
of
a
dust
mist
respirator.

Dose
is
calculated
using
an
80
percent
protection
factor
applied
to
baseline
inhalation
exposure
values
found
in
the
PHED
Surrogate
Exposure
Guide.

e
Engineering
control
inhalation
MOE
=
short­
and
intermediate­
term
NOAEL
(
2.7
mg/
kg/
day)
/
engineering
control
inhalation
dose
(
mg/
kg/
day)
and
represents:

1a,
1b,
1c,
1d:
closed
mixing
and
loading
2a,
2b,
2c,
2d:
water
soluble
packaging
3:
enclosed
cockpit
4,
5,
6:
enclosed
cab
40
Table
14:
Zeta­
Cypermethrin
Occupational
Handler
Short­
and
Intermediate­
Term
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Baseline
Inhalation
MOEc
Dust/
Mist
Respirator
Inhalation
MOEd
Engineering
Control
Inhalation
MOEe
Mixer/
Loader
Mixing/
Loading
Liquid
Concentrates
for
Aerial
Applications
(
1a)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,
and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,
Soybeans,

Wheat,
and
Triticale
0.05
lb
ai/
acre
1200
acres
2,600
13,000
38,000
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,

Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),
Succulent
Edible
Podded
Peas,

Succulent
Edible
Podded
Beans,
Head
Lettuce,
Pecans,
Grain
Sorghum
and
Millet,
Sugarbeets,
Sugarcane
0.05
lb
ai/
acre
350
acres
9,000
45,000
130,000
Mixing/
Loading
Liquid
Concentrates
for
Chemigation
Applications
(
1b)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,
and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,
Soybeans,

Wheat,
and
Triticale
0.05
lb
ai/
acre
350
acres
9,000
45,000
130,000
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,

Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),
Succulent
Edible
Podded
Peas,

Succulent
Edible
Podded
Beans,
Head
Lettuce,
Pecans,
Grain
Sorghum
and
Millet,
Sugarbeets,
Sugarcane
0.05
lb
ai/
acre
350
acres
9,000
45,000
130,000
Mixing/
Loading
Liquid
Concentrates
for
Groundboom
Applications
(
1c)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,
and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,
Soybeans,

Wheat,
and
Triticale
0.05
lb
ai/
acre
200
acres
16,000
79,000
230,000
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,

Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),
Succulent
Edible
Podded
Peas,

Succulent
Edible
Podded
Beans,
Head
Lettuce,
Grain
Sorghum
and
Millet,
Sugarbeet,
Sugarcane
0.05
lb
ai/
acre
80
acres
39,000
200,000
570,000
Mixing/
Loading
Liquid
Concentrates
for
Airblast
Applications
(
1d)
Pecans
0.05
lb
ai/
acre
40
acres
79,000
390,000
1,100,000
Table
14:
Zeta­
Cypermethrin
Occupational
Handler
Short­
and
Intermediate­
Term
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Baseline
Inhalation
MOEc
Dust/
Mist
Respirator
Inhalation
MOEd
Engineering
Control
Inhalation
MOEe
41
Loading
Dusts
into
Mechanical
Duster
or
Dust
Bags
(
using
PHED
mixing/
loading
wettable
powders
data)
(
2)
Livestock
(
beef
&
dairy
cattle,
sheep,
goats,
horses)
0.00094
lb
ai/
animal
1000
animals
4,700
23,000
Not
Feasible
Applicator
Applying
Sprays
via
Aerial
Equipment
(
3)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,
and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,
Soybeans,

Wheat,
and
Triticale
0.05
lb
ai/
acre
1200
acres
No
Data
No
Data
46,000
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,

Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),
Succulent
Edible
Podded
Peas,

Succulent
Edible
Podded
Beans,
Head
Lettuce,
Pecans,
Grain
Sorghum
and
Millet,
Sugarbeet,
Sugarcane
0.05
lb
ai/
acre
350
acres
No
Data
No
Data
160,000
Applying
Sprays
via
Groundboom
Equipment
(
4)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,
and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,
Soybeans,

Wheat,
and
Triticale
0.05
lb
ai/
acre
200
acres
26,000
130,000
440,000
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,

Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),
Succulent
Edible
Podded
Peas,

Succulent
Edible
Podded
Beans,
Head
Lettuce,
Grain
Sorghum
and
Millet,
Sugarbeet,
Sugarcane
0.05
lb
ai/
acre
80
acres
64,000
320,000
1,100,000
Applying
Sprays
via
Airblast
Equipment
(
5)
Pecans
0.05
lb
ai/
acre
40
acres
21,000
110,000
210,000
Applying
Dusts
via
Mechanical
Duster
(
6)
Livestock
(
beef
&
dairy
cattle,
sheep,
goats,
horses)
0.00094
lb
ai/
animal
1000
animals
No
Data
No
Data
No
Data
Table
14:
Zeta­
Cypermethrin
Occupational
Handler
Short­
and
Intermediate­
Term
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Baseline
Inhalation
MOEc
Dust/
Mist
Respirator
Inhalation
MOEd
Engineering
Control
Inhalation
MOEe
42
Flagger
Flagging
for
Aerial
Spray
Applications
(
7)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,
and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,
Soybeans,

Wheat,
Triticale,
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,
Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),

Succulent
Edible
Podded
Peas,
Succulent
Edible
Podded
Beans,

Head
Lettuce,
Pecans,
Grain
Sorghum
and
Millet,
Sugarbeet,

Sugarcane
0.05
lb
ai/
acre
350
acres
31,000
150,000
1,500,000
Mixer/
Loader/
Applicator
Mixing/
Loading/
Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
PHED)
(
8)
Indoor
surfaces
0.0044
lb
ai/
gallon
40
gallons
36,000
180,000
Not
Feasible
Residential
Lawns
and
Turfgrass
at
Commercial
Sites
0.3
lb
ai/
acre
5
acres
4,200
21,000
Not
Feasible
Outdoor
surfaces
0.001
lb
ai/
gallon
40
gallons
160,000
790,000
Not
Feasible
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
(
9)
residential
lawns
0.3
lb
ai/
acre
5
acres
70,000
350,000
Not
Feasible
outdoor
surfaces,
surfaces
of
buildings,
porches,
screens,

window
frames,
eaves,
patios,
lawn
area
adjacent
to
or
around
private
homes,
duplexes,
townhouses,
condominiums,
house
trailers
apartment
complexes,
carports,
garages,
fence
lines,

storage
sheds,
barns,
and
other
residential
structures
plus
commercial,
industrial,
institutional
buildings,
vegetation,

refuse
dumps,
garages,
and
other
outdoor
surfaces
0.4356
lb
ai/
acre
5
acres
48,000
240,000
Not
Feasible
Applying
Dusts
via
Shaker
Can
(
MRID
444598­
01)
(
10)
Livestock
(
beef
&
dairy
cattle,
sheep,
goats,
horses)
0.00094
lb
ai/
animal
100
animals
3,200
16,000
Not
Feasible
Table
14:
Zeta­
Cypermethrin
Occupational
Handler
Short­
and
Intermediate­
Term
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Baseline
Inhalation
MOEc
Dust/
Mist
Respirator
Inhalation
MOEd
Engineering
Control
Inhalation
MOEe
43
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Watering
Can
(
using
ORETF
residential
hose­
end
data)
(
12)
outdoor
surfaces
(
ant
mounds)
0.006
lb
ai/
mound
40
mounds
46,000
230,000
Not
Feasible
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Paint
Brush
(
13)
outdoor
surfaces
(
general)
0.001
lb
ai/
gallon
5
gallons
140,000
680,000
Not
Feasible
Applying
Ready
to
Use
Ear­
Tags
(
14)
livestock
(
cattle)
0.004
lb
ai/
2
ear
tags/
cattle
100
&

1000
cattle
No
Data
No
Data
Not
Feasible
livestock
(
cattle)
0.003
lb
ai/
1
ear
tag/
cattle
100
&

1000
cattle
No
Data
No
Data
Not
Feasible
Loading
Dusts
into
Self­

Applying
Dust
Bags
(
using
PHED
mixing/
loading
wettable
powders
data)
(
15)
Livestock
(
beef
&
dairy
cattle,
sheep,
goats,
horses)
0.00094
lb
ai/
animal
1000
animals
4,700
23,000
Not
Feasible
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
Zeta­
Cypermethrin.

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
inhalation:
no
respirator.

d
PPE
inhalation:
assumes
a
dust/
mist
removing
quarter­
face
style
respirator
providing
an
80%
protection
factor
(
PF5)

e
Eng
Controls
Inhalation:
Closed
mixing/
loading
system,
enclosed
cab,
or
enclosed
cockpit.
44
Chronic
Risk
Summary
Cypermethrin
A
few
occupational
handler
exposure
scenarios
may
be
considered
long­
term,
including
applications
to
residential,
commercial,
and
industrial
turf
by
commercial
lawn
care
operators
and
applications
in
and
around
residential,
commercial,
and
industrial
premises
by
commercial
pest
control
operators.
Aggregated
long­
term
dermal
and
inhalation
risks
are
below
HED's
level
of
concern
for
all
scenarios
involving
liquid
formulations
at
baseline
attire
or
with
the
addition
of
chemical­
resistant
gloves
to
baseline
attire.
Aggregated
long­
term
dermal
and
inhalation
risks
are
below
HED's
level
of
concern
for
all
scenarios
involving
wettable
powder
formulations
at
baseline
attire
or
with
the
addition
of
chemical­
resistant
gloves
to
baseline
attire,
except
mixing/
loading/
applying
wettable
powders
with
a
low­
pressure
handwand
sprayer.
Risks
were
reduced
to
below
HED's
level
of
concern
with
the
addition
of
a
dust/
mist
respirator
and
chemical­
resistant
gloves
to
baseline
attire
for
these
scenarios,
except
for
applications
to
residential,
commercial
and
industrial
lawns
(
0.6
lb
ai/
A).
Even
with
the
addition
of
maximum
personal
protection
equipment
(
PPE),
combined
long­
term
dermal
and
inhalation
risks
for
mixing/
loading/
applying
with
low
pressure
handwand
sprayer
to
residential,
commercial
and
industrial
lawns
were
still
above
the
HED's
level
of
concern
(
i.
e,
ARI
<
1).

Zeta­
Cypermethrin
A
few
occupational
handler
exposure
scenarios
may
be
considered
long­
term,
including
applications
to
residential,
commercial,
and
industrial
turf
by
commercial
lawn
care
operators
and
applications
by
pest
control
operators.
When
data
were
available
to
assess
risks,
long­
term
risks
to
occupational
handlers
were
below
the
Agency's
level
of
concern
for
risks
(
i.
e,
ARI
<
1)
at
baseline
attire
(
i.
e.,
long­
sleeve
shirt,
long
pants,
shoes,
socks,
and
no
respirator).
For
mixing/
loading/
applying
liquid
concentrates
with
a
handgun
sprayer,
no
data
are
available
to
assess
dermal
exposures
at
baseline
attire.
However,
the
combined
long­
term
risks
were
below
HED's
level
of
concern
with
the
addition
of
chemical­
resistant
gloves
to
baseline
attire.
45
Table
15:
Cypermethrin
Long­
Term
Occupational
Handler
Summary
Exposure
Scenario
Crop
or
Target
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Long­
Term
Baseline
Dermal
+

Baseline
Inhalation
ARIc
Long­
Term
PPEGloves
Dermal
+

Baseline
Inhalation
ARId
Long­
Term
PPEGloves
Dermal
+

Dust/
Mist
Respirator
Inhalation
ARIe
Mixer/
Loader/
Applicator
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Low
Pressure
Handwand
(
1)
residential,
commercial
and
industrial
lawns
0.44
lb
ai/
acre
5
acre
0.71
9.1
38
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,

and
standing
wood
in
uninhabited
areas
at
residential,

commercial
and
industrial
sites
0.05
lb
ai/
gallon
40
gallons
0.78
10
41
Termites
applications
to
preconstruction
lumber
and
logs,
and
to
soil
under
firewood
0.041
lb
ai/
gallon
40
gallons
0.95
12
50
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,
commercial
and
industrial
sites,

animal
premises,
and
greenhouses;
0.017
lb
ai/
gallon
40
gallons
2.3
29
120
ornamental
plants;
termite
applications
to
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.008
lb
ai/
gallon
40
gallons
4.9
62
260
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Paintbrush
(
2)
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,

and
standing
wood
in
uninhabited
areas
at
residential,

commercial
and
industrial
sites
0.05
lb
ai/
gallon
5
gallons
2.6
6.8
17
Termites:
preconstruction
lumber
and
logs,
soil
under
firewood
0.041
lb
ai/
gallon
5
gallons
3.2
8.3
21
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,
commercial
and
industrial
sites,

animal
premises,
and
greenhouses;
0.017
lb
ai/
gallon
5
gallons
7.8
20
51
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Handheld
Handgun
(
ORETF)

(
3)
agricultural
uncultivated
areas;
fencerows,
hedgerows;

ornamental
plants;
potting
soil,
topsoil
3.4
lb
ai/
acre
5
acres
no
baseline
dermal
data
11
18
residential,
commercial
and
industrial
lawns
0.44
lb
ai/
acre
5
acres
no
baseline
dermal
data
82
140
Table
15:
Cypermethrin
Long­
Term
Occupational
Handler
Summary
Exposure
Scenario
Crop
or
Target
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Long­
Term
Baseline
Dermal
+

Baseline
Inhalation
ARIc
Long­
Term
PPEGloves
Dermal
+

Baseline
Inhalation
ARId
Long­
Term
PPEGloves
Dermal
+

Dust/
Mist
Respirator
Inhalation
ARIe
46
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Termiticide
Injector
(
4)
Termites:
trees,
utility
poles,
fenceposts,
building
voids
0.05
lb
ai/
gallon
500
gallons
no
baseline
dermal
data
7.1
18
Mixing/
Loading/
Applying
Wettable
Powders
with
a
Low
Pressure
Handwand
(
5)
residential,
commercial
and
industrial
lawns
0.6
lb
ai/
acre
5
acres
no
baseline
dermal
data
0.19
0.83
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,

and
standing
wood
in
uninhabited
areas
at
residential,

commercial
and
industrial
sites
0.05
lb
ai/
gallon
40
gallons
no
baseline
dermal
data
0.28
1.2
fire
ant
mounds
0.033
lb
ai/
gallon
40
gallons
no
baseline
dermal
data
0.42
1.9
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,
commercial
and
industrial
sites,

animal
premises,
and
greenhouses;
applications
to
horses
0.017
lb
ai/
gallon
40
gallons
no
baseline
dermal
data
0.82
3.7
ornamental
plants;
termite
applications
to
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.008
lb
ai/
gallon
40
gallons
no
baseline
dermal
data
1.7
7.8
Mixing/
Loading/
Applying
Wettable
Powders
with
a
Paintbrush
(
using
PHED
liquid
paintbrush
data)
(
6)
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,

and
standing
wood
in
uninhabited
areas
at
residential,

commercial
and
industrial
sites
0.05
lb
ai/
gallon
5
gallons
2.6
6.8
17
Termites:
preconstruction
lumber
and
logs,
soil
under
firewood
0.041
lb
ai/
gallon
5
gallons
3.2
8.3
21
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,
commercial
and
industrial
sites,

animal
premises,
and
greenhouses;
0.017
lb
ai/
gallon
5
gallons
7.8
20
51
Table
15:
Cypermethrin
Long­
Term
Occupational
Handler
Summary
Exposure
Scenario
Crop
or
Target
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Long­
Term
Baseline
Dermal
+

Baseline
Inhalation
ARIc
Long­
Term
PPEGloves
Dermal
+

Baseline
Inhalation
ARId
Long­
Term
PPEGloves
Dermal
+

Dust/
Mist
Respirator
Inhalation
ARIe
47
Mixing/
Loading/
Applying
Wettable
Powders
with
a
Handheld
Handgun
(
ORETF)
(
7)
agricultural
uncultivated
areas;
fencerows,
hedgerows;

ornamental
plants;
potting
soil,
topsoil
3.4
lb
ai/
acre
5
acres
no
baseline
dermal
data
0.55
2.3
residential,
commercial
and
industrial
lawns
0.6
lb
ai/
acre
5
acres
no
baseline
dermal
data
3.1
13
Mixing/
Loading/
Applying
WSB
Formulations
with
a
Handheld
Handgun
(
ORETF)
(
8)
agricultural
uncultivated
areas;
fencerows,
hedgerows;

ornamental
plants;
potting
soil,
topsoil
3.4
lb
ai/
acre
5
acres
no
baseline
dermal
data
3.9
9.7
residential,
commercial
and
industrial
lawns
0.6
lb
ai/
acre
5
acres
no
baseline
dermal
data
22
55
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
Cypermethrin.

b
Amount
handled
per
day
values
are
EPA
estimates
of
acreage
treated
or
gallons
applied
based
on
Exposure
SAC
Policy
#
9
"
Standard
Values
for
Daily
Acres
Treated
in
Agriculture".

c
Aggregate
Risk
Index
=
1/{[
1/(
Baseline
Dermal
MOE/
Dermal
UF­
100)]
+
[
1/(
Baseline
Inhalation
MOE/
Inhalation
UF­
300)]}
where
an
ARI
greater
than
1
is
considered
acceptable
d
Aggregate
Risk
Index
=
1/{[
1/(
PPE­
gloves
Dermal
MOE/
Dermal
UF­
100)]
+
[
1/(
Baseline
Inhalation
MOE/
Inhalation
UF­
300)]}
where
an
ARI
greater
than
1
is
considered
acceptable.

e
Aggregate
Risk
Index
=
1/{[
1/(
PPE­
gloves
Dermal
MOE/
Dermal
UF­
100)]
+
[
1/(
Dust/
Mist
Respirator
Inhalation
MOE/
Inhalation
UF
­
300)]}
where
an
ARI
greater
than
1
is
considered
acceptable.
48
Table
16:
Z­
cypermethrin
Long­
Term
Occupational
Handler
Summary
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Long
term
Baseline
Dermal
+

Baseline
Inhalation
ARIc
Long
term
PPE­
Gloves
Dermal
+

Baseline
Inhalation
ARId
Long
term
PPEGloves
Dermal
+

Dust/
Mist
Respirator
Inhalation
ARIe
Mixer/
Loader/
Applicator
Mixing/
Loading/
Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
PHED)
Indoor
surfaces
and
Outdoor
surfaces
(
outdoor
rate
supplied
by
Registrant)
0.0044
lb
ai/
gallon
40
gallons
0.095
110
470
Residential
Lawns
and
Turfgrass
at
Commercial
Sites
(
Rate
supplied
by
Registrant)
0.3
lb
ai/
acre
5
acres
0.011
13
55
Outdoor
surfaces
(
rate
from
label)
0.001
lb
ai/
gallon
40
gallons
0.42
500
2100
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
residential
lawns
0.3
lb
ai/
acre
5
acres
No
Baseline
Dermal
Data
120
210
outdoor
surfaces,
surfaces
of
buildings,
porches,

screens,
window
frames,
eaves,
patios,
lawn
area
adjacent
to
or
around
private
homes,
duplexes,

townhouses,
condominiums,
house
trailers
apartment
complexes,
carports,
garages,
fence
lines,
storage
sheds,
barns,
and
other
residential
structures
plus
commercial,
industrial,
institutional
buildings,

vegetation,
refuse
dumps,
garages,
and
other
outdoor
surfaces
0.4356
lb
ai/
acre
5
acres
No
Baseline
Dermal
Data
83
140
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Watering
Can
(
using
ORETF
residential
hose­
end
data)
outdoor
surfaces
(
ant
mounds)
0.006
lb
ai/
mound
40
mounds
1.2
No
PPE
Dermal
Data
No
PPE
Dermal
Data
Table
16:
Z­
cypermethrin
Long­
Term
Occupational
Handler
Summary
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Long
term
Baseline
Dermal
+

Baseline
Inhalation
ARIc
Long
term
PPE­
Gloves
Dermal
+

Baseline
Inhalation
ARId
Long
term
PPEGloves
Dermal
+

Dust/
Mist
Respirator
Inhalation
ARIe
49
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Paint
Brush
outdoor
surfaces
(
general)
(
rate
from
label)
0.001
lb
ai/
gallon
5
gallons
1.9
340
860
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
zeta­
cypermethrin.

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
inhalation:
no
respirator.

d
PPE
inhalation:
assumes
a
dust/
mist
removing
quarter­
face
style
respirator
providing
an
80%
protection
factor
e
Eng
Controls
Inhalation:
Closed
mixing/
loading
system,
enclosed
cab,
or
enclosed
cockpit.
50
2.1.4
Summary
of
Risk
Concerns
and
Data
Gaps
for
Handlers
Most
occupational
handler
scenarios
have
risks
associated
with
them
that
are
below
the
Agency's
level
of
concern
at
some
level
of
risk
mitigation.
There
are
data
gaps
for
evaluating
exposures
and
risks
for
the
following
scenarios:

°
applying
cypermethrin
or
zeta­
cypermethrin
using
ready­
to­
use
ear
tags,
and
°
for
applying
zeta­
cypermethrin
dust
formulation
using
mechanical
dusters.

No
reasonable
surrogate
data
are
available
to
evaluate
risks
from
these
exposures.

2.1.5
Recommendations
For
Refining
Occupational
Handler
Risk
Assessment
To
refine
this
occupational
risk
assessment,
data
on
actual
use
patterns
including
rates,
timing,
and
area
treated
would
better
characterize
cypermethrin
and
zeta­
cypermethrin
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.

2.2.
Occupational
Postapplication
Exposures
and
Risks
EPA
did
not
assess
occupational
postapplication
risks
to
agricultural
workers
following
treatments
to
agricultural
crops,
since
no
short­
or
intermediate­
term
dermal
endpoints
of
concern
were
identified
and
long­
term
exposures
are
not
expected
for
tasks
involving
any
of
the
registered
crop
use
patterns.
In
lieu
of
a
postapplication
risk
assessment,
a
restricted­
entry
interval
of
12
hours
is
assumed,
unless
the
active
ingredient
and
formulation
meet
all
of
the
criteria
listed
in
PR
Notice
95­
3
for
low
risk
pesticides.
Due
to
the
lack
of
a
developmental
neurotoxicity
study,
cypermethrin
and
zeta­
cypermethrin
do
not
meet
the
criteria
in
PR
Notice
95­
3
for
low
risk
pesticides
at
this
time.

EPA
did
not
assess
occupational
postapplication
exposures
and
risks
following
applications
of
cypermethrin
and
zeta­
cypermethrin
to
residential
and
commercial
lawns,
and
in
and
around
industrial,
commercial,
and
residential
premises,
since
no
short­
or
intermediate­
term
dermal
endpoints
of
concern
were
identified
and
long­
term
exposures
are
not
expected
for
tasks
involving
any
of
the
registered
use
patterns.

2.3
Occupational
Risk
Characterization
2.3.1
Handler
Characterization
HED
believes
that
the
risk
values
presented
in
this
occupational
assessment
represent
the
best
quality
results
that
could
be
produced
given
the
exposure,
use,
and
toxicology
data
that
are
available.
HED
also
believes
that
the
risks
represent
reasonable
worse­
case
estimates
of
exposure
because
maximum
application
rates
are
coupled
with
medium­
to
high­
end
estimates
of
area
treated
daily
to
define
risk
estimates
that
likely
fall
in
the
upper
percentiles
of
the
actual
51
exposure
distributions.

3.0
Residential
and
Other
Non­
Occupational
Exposures
and
Risks
There
is
a
potential
for
exposure
in
residential
settings
during
the
application
process
for
homeowners
who
use
products
containing
cypermethrin.
There
are
no
products
registered
for
homeowner
use
containing
zeta­
cypermethrin
as
the
active
ingredient.
There
is
a
potential
for
exposure
in
residential
settings
from
entering
areas
treated
with
cypermethrin
and
zetacypermethrin
such
as
residential
lawns,
indoor
surfaces
and
spaces,
outdoor
surfaces,
and
animal
premises
that
could
lead
to
nonoccupational
exposures
to
adults
and
children.
As
a
result,
risk
assessments
have
been
completed
for
residential
handler
scenarios
only
for
cypermethrin,
and
have
been
completed
for
postapplication
scenarios
for
cypermethrin
and
zeta­
cypermethrin.

3.1
Residential
Handler
Exposures
and
Risks
The
Agency
uses
the
term
"
handlers"
to
describe
those
individuals
who
are
involved
in
the
pesticide
application
process.
The
agency
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.
Residential
handlers
are
addressed
somewhat
differently
by
the
Agency
as
homeowners
are
assumed
to
complete
all
elements
of
an
application
without
the
use
of
protective
equipment.

3.1.1
Handler
Exposure
Scenarios
The
purpose
of
this
section
is
to
describe
how
the
exposure
scenarios
are
defined.
Much
of
the
process
for
residential
uses
is
identical
to
that
considered
for
the
occupational
assessment
with
a
few
notable
exceptions
that
include:

°
Residential
handler
exposure
scenarios
are
only
considered
to
be
short­
term
in
nature
due
to
the
episodic
uses
associated
with
homeowner
products;

°
Homeowner
handler
assessments
are
completed
based
on
individuals
wearing
shorts
and
short­
sleeved
shirts;

°
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
as
opposed
to
the
rates
used
in
the
occupational
assessment;
and
°
Area/
volumes
of
spray
or
chemical
used
in
the
risk
assessment
are
based
on
HED
guidance
specific
to
residential
use
patterns.

Exposure
to
pesticide
handlers
is
likely
during
the
residential
use
of
cypermethrin
in
a
variety
of
environments
including
on
animals,
animal
premises,
and
treatments
in
and
around
homes.
The
anticipated
use
patterns
and
current
labeling
indicate
several
major
residential
exposure
scenarios
based
on
the
types
of
equipment
and
techniques
that
can
potentially
be
used
to
52
make
cypermethrin
applications.
The
quantitative
exposure/
risk
assessment
developed
for
residential
handlers
is
based
on
these
scenarios.
[
Note:
The
scenario
numbers
correspond
to
the
tables
of
risk
calculations
included
in
the
occupational
risk
calculation
aspects
of
the
appendices.]

(
1)
Liquid
concentrates:
mixing/
loading/
applying
with
low­
pressure
handwand
sprayer,
(
2)
Liquid
concentrates:
mixing/
loading/
applying
with
wipe,
(
3)
Liquid
ready­
to­
use:
applying
with
trigger
pump
sprayer,
(
4)
Liquid
ready­
to­
use:
applying
with
aerosol
can,
(
5)
Liquid
ready­
to­
use:
indoor
fogger,
and
(
6)
Liquid
ready­
to­
use:
applying
with
wipe.

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.
These
unit
exposure
values
were
taken
from
the
Pesticide
Handlers
Exposure
Database
(
PHED)
or
from
Outdoor
Residential
Exposure
Task
Force
(
ORETF)
data.

The
assumptions
and
factors
used
in
the
risk
calculations
include:

C
Exposure
factors
used
to
calculate
daily
exposures
to
handlers
were
based
on
applicable
data
if
available.
For
lack
of
appropriate
data,
values
from
a
scenario
deemed
similar
enough
by
the
assessor
might
be
used.
In
this
assessment
PHED
mixer/
loader/
applicator
data
for
aerosol
can
application
is
used
to
assess
indoor
fogger
applications.
The
nature
of
these
application
methods
are
believed
to
be
similar
enough
to
bridge
the
data.

C
The
Agency
always
considers
the
maximum
application
rates
allowed
by
labels
in
its
risk
assessments
to
consider
what
is
legally
possible
based
on
the
label.

C
Residential
risk
assessments
were
not
based
on
what
could
be
applied
in
a
typical
workday
like
with
the
occupational
risk
assessments
presented
above.
Instead,
the
HED
based
calculations
on
what
would
reasonably
be
treated
by
homeowners
such
as
the
size
of
a
lawn,
or
the
size
of
a
garden.
This
information
was
used
by
the
HED
to
define
chemical
use
values
for
handlers
which
in
turn
were
coupled
with
unit
exposure
values
to
calculate
risks.
The
factors
used
for
the
cypermethrin
assessment
were
those
presented
in
the
Health
Effects
Division
Science
Advisory
Committee
Policy
12:
Recommended
Revisions
To
The
Standard
Operating
Procedures
For
Residential
Exposure
Assessment
which
was
completed
on
February
22,
2001.
The
following
daily
volumes
handled
and
area
treated,
excerpted
from
the
policy
and
used
in
each
residential
scenario,
include:

°
1
sixteen­
ounce
ready­
to­
use
aerosol
can;
°
2
foggers;
°
1
one­
gallon
pump
trigger
sprayer
container;
°
5
gallons
when
mixing/
loading/
applying
liquids
outdoors
with
a
low
pressure
handwand
sprayer;
and
°
1
animal
when
applying
applications
to
pet
horses.
53
Residential
Handler
Exposure
Studies:
The
unit
exposure
values
that
were
used
in
this
assessment
were
based
on
studies
included
in
the
Pesticide
Handler
Exposure
Database
(
PHED,
Version
1.1
August
1998),
data
provided
by
the
Outdoor
Residential
Exposure
Task
Force,
and
data
from
the
Chemical
Manufacturers
Association
(
CMA)
Antimicrobial
Exposure
Assessment
Study.
See
the
discussion
in
2.1.2
for
details.

3.1.3
Residential
Handler
Exposure
and
Risk
Estimates
The
residential
handler
exposure
and
risk
calculations
are
presented
in
this
section.
Risks
were
calculated
using
the
Margin
of
Exposure
(
MOE)
as
described
in
Section
2.1.3.
Much
of
the
process
for
residential
uses
is
identical
to
that
considered
for
the
occupational
assessment
with
a
few
notable
exceptions
as
described
above
in
Section
3.1.1
(
e.
g.,
all
are
short­
term
exposures
and
people
wear
shorts
and
short­
sleeved
shirts
with
no
gloves).
The
other
major
difference
with
residential
risk
assessments
is
that
the
uncertainty
factor
which
defines
the
level
of
risk
concern
also
has
the
additional
FQPA
safety
factor
applied.
In
the
case
of
cypermethrin,
the
overall
uncertainty
factor
applied
to
residential
handler
risk
assessments
is
1000,
due
to
the
lack
of
a
developmental
neurotoxicity
study
with
a
special
protocol
for
pyrethroids.

Summary:
The
risk
calculations
for
residential
cypermethrin
handlers
are
included
in
Appendix
A
(
Table
A6)
and
summarized
below.

Table
17:
Cypermethrin
Residential
Handler
Risks
Exposure
Scenario
Crop
or
Target
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Daily
b
Inhalation
MOEc
Mixer/
Loader/
Applicator
Mixing/
Loading/
Applying
Liquid
concentrates
with
Low
Pressure
Handwand
(
1)
horses
0.017
lbs
ai/
gallon
5
gallons
590,000
Mixing/
Loading/
Applying
Liquid
concentrates
with
Wipes
(
2)
horses
0.017
lbs
ai/
gallon
0.1
gallon
900,000
Applying
Ready
to
Use
Formulations
with
a
Pump
Sprayer
(
PHED
aerosol
can
data)
(
3)
horses
0.017
lbs
ai/
gallon
0.11
gallon
900,000
Applying
Ready
to
Use
Formulations
with
Aerosol
Cans
(
4)
indoor
surfaces,
outdoor
surfaces,
and
animal
premises
0.005
lb
ai/
sixteen
ounce
can
1
can
16,000
Applying
Ready
to
Use
Formulations
with
Fogger
(
5)
indoor
surfaces,
outdoor
surfaces,
and
animal
premises
0.0014
lb
ai/
fogger
2
foggers
28,000
Applying
Ready
to
Use
Formulations
with
Wipes
(
6)
horses
0.00041
lb
ai/
animal
1
animal
6.9E+
09
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
cypermethrin.
b
Amount
handled
per
day
values
are
EPA
estimates
of
amount
treated
based
on
revised
Residential
SOPs
(
2/
01).
c
Baseline
inhalation
MOE
=
NOAEL
(
2.7
mg/
kg/
day)
/
inhalation
daily
dose
(
mg/
kg/
day),
where
inhalation
dose
=
daily
unit
exposure
(
µ
g/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
conversion
factor
(
1mg/
1,000
µ
g
/
body
weight
(
70
kg
adult).

In
residential
settings,
the
Agency
does
not
use
personal
protective
equipment
to
limit
exposures,
because
they
are
viewed
as
impractical
and
not
enforceable.
Risk
estimates
are
based
54
on
handlers
wearing
short­
sleeve
shirts,
short
pants,
shoes,
and
socks.
Risks
do
not
exceed
the
HED's
level
of
concern
for
cypermethrin
for
any
of
the
residential
handler
scenarios.

3.1.4
Summary
of
Risk
Concerns
and
Data
Gaps
for
Handlers
Cypermethrin
No
short­
or
intermediate­
term
dermal
exposures
or
risks
were
assessed
for
cypermethrin,
since
no
dermal
endpoints
of
concern
were
identified.
EPA
does
not
anticipate
that
residential
handlers
would
have
long­
term
exposures
to
cypermethrin
or
zeta­
cypermethrin.
Therefore,
no
long­
term
dermal
or
inhalation
exposures
or
risks
were
assessed.
EPA
did
assess
short­
and
intermediate­
term
inhalation
exposures
and
risks
to
residential
handlers.
Residential
inhalation
risks
are
below
HED's
level
of
concern
(
i.
e.,
MOE
<
1000)
for
all
nonoccupational
handler
scenarios.

Zeta­
Cypermethrin
There
are
no
residential
handler
scenarios
for
zeta­
cypermethrin.
All
registered
uses
of
zeta­
cypermethrin
are
for
occupational
use
only.

3.1.5
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
cypermethrin
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
3.2.1
Residential
Postapplication
Exposure
Scenarios
Cypermethrin
and
zeta­
cypermethrin
uses
are
varied
and
include
animals
as
well
as
indoor
and
outdoor
premises
treatments.
As
a
result,
a
wide
array
of
individuals
of
varying
ages
can
potentially
be
exposed
when
they
are
engaged
in
activities
in
areas
that
have
been
previously
treated
(
i.
e.,
turfgrass
or
indoor
surfaces)
or
have
contact
with
treated
companion
animals.

There
are
a
number
of
residential
postapplication
exposure
scenarios
for
different
segments
of
the
population
including
toddlers,
youth­
aged
children,
and
adults.
Risks
were
calculated
for
only
a
few
scenarios,
since
no
short­
or
intermediate­
term
dermal
endpoint
of
concern
has
been
identified
and
long­
term
exposures
are
not
expected.
In
general,
postapplication
inhalation
risks
following
outdoor
applications
are
considered
negligible.
However,
postapplication
inhalation
risks
following
indoor
applications
at
residential
sites
may
pose
a
concern.
EPA
assessed
postapplication
inhalation
risks
following
indoor
fogger
applications
using
time­
weighted
averages
from
the
cyfluthrin
room
fogger
study.
EPA
assessed
postapplication
inhalation
risks
following
indoor
aerosol
applications
using
air
concentration
estimates
from
the
55
crack
and
crevice
subset
of
PHED
and
a
House
Model
to
estimate
an
emission
rate.
EPA
assessed
postapplication
risks
to
toddlers
from
incidental
ingestion
following
broadcast
applications
to
lawns
and
following
spot
or
crack
&
crevice
treatments
to
indoor
surfaces.

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/
approaches
described
above.
The
Agency
used
this
guidance
to
define
the
exposure
scenarios
that
essentially
included
only
toddler
exposure
on
treated
lawns
(
only
nondietary
ingestion
considered).
The
SOPs
and
the
associated
scenarios
are
presented
below:

C
Dose
from
hand­
to­
mouth
activity
from
treated
turf
calculated
using
SOP
2.3.2:
Postapplication
dose
among
toddlers
from
incidental
nondietary
ingestion
of
pesticide
residues
on
treated
turf
from
hand­
to­
mouth
transfer.

C
Dose
from
object­
to­
mouth
activity
from
treated
turf
calculated
using
SOP
2.3.3:
Postapplication
dose
among
toddlers
from
incidental
nondietary
ingestion
of
pesticide
residues
on
treated
turf
from
object­
to­
mouth
transfer.

C
Dose
from
soil
ingestion
activity
from
treated
turf
calculated
using
SOP
2.3.4:
Postapplication
dose
among
toddlers
from
incidental
nondietary
ingestion
of
pesticide
residues
from
ingesting
soil
in
a
treated
turf
area.

C
Dose
from
hand­
to­
mouth
activity
from
treated
indoor
surfaces
calculated
using
SOP
8.4
Postapplication
dose
among
toddlers
from
incidental
nondietary
ingestion
of
pesticide
residues
on
treated
indoor
surfaces
from
hand­
to­
mouth
transfer.

The
detailed
residential
postapplication
calculations
are
presented
in
Appendix
B
of
this
document.

3.2.2
Data
&
Assumptions
for
Residential
Postapplication
Exposure
Scenarios
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
residential
postapplication
risk
assessments.
Each
assumption
and
factor
is
detailed
below.

<
The
Agency
combines
or
aggregates
risks
resulting
from
exposures
to
individual
chemicals
when
it
is
likely
they
can
occur
simultaneously
based
on
the
use
pattern
and
the
behavior
associated
with
the
exposed
population.
For
cypermethrin
and
zeta­
cypermethrin,
the
Agency
has
combined
risks
(
i.
e.,
MOEs)
for
different
kinds
of
exposures
within
the
turf
(
hand­
to­
mouth,
object­
to­
mouth,
and
soil
ingestion)
exposure
scenario.
These
represent
the
standard
set
of
exposures
that
are
typically
added
together
when
chemicals
are
used
on
turf,
because
it
is
logical
they
can
co­
occur.

C
Exposures
to
children
playing
on
treated
turf
have
been
addressed
using
the
latest
Agency
approaches
for
this
scenario
including:
56
<
5
percent
of
the
application
rate
has
been
used
to
calculate
the
0­
day
residue
levels
used
for
defining
risks
from
hand­
to­
mouth
behaviors;

<
20
percent
of
the
application
rate
has
been
used
to
calculate
the
0­
day
residue
levels
used
for
defining
risks
from
object­
to­
mouth
behaviors;

<
3
year
old
toddlers
are
expected
to
weigh
15
kg;

<
short­
term
hand­
to­
mouth
exposures
are
based
on
a
frequency
of
20
events/
hour,

<
a
surface
area
per
event
of
20
cm2
representing
the
palmar
surfaces
of
three
fingers
is
used;

<
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;

<
object­
to­
mouth
exposures
are
based
on
a
25
cm2/
day
surface
area;

<
exposure
durations
are
expected
to
be
2
hours
based
on
information
in
the
Agency's
Exposure
Factors
Handbook;

<
soil
residues
are
contained
in
the
top
centimeter
and
soil
density
is
0.67
mL/
gram;
and
<
hand­
and
object­
to­
mouth
and
soil
ingestion
are
added
together
to
represent
an
overall
risk
from
exposure
to
turf.

C
Exposures
to
children
playing
on
treated
indoor
surfaces
have
been
addressed
using
the
latest
Agency
approaches
for
this
scenario
including:

<
5
percent
of
the
application
rate
has
been
used
to
calculate
the
0­
day
residue
levels
used
for
defining
risks
from
hand­
to­
mouth
behaviors;

<
3
year
old
toddlers
are
expected
to
weigh
15
kg;

<
short­
term
hand­
to­
mouth
exposures
are
based
on
a
frequency
of
20
events/
hour,

<
a
surface
area
per
event
of
20
cm2
representing
the
palmar
surfaces
of
three
fingers
is
used;

<
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;

<
an
adjustment
factor
of
50%
is
used
to
account
for
the
application
as
a
spot
or
crack
and
crevice
treatment,
rather
than
a
broadcast
treatment;

<
exposure
durations
are
expected
to
be
2
hours
based
on
information
in
the
Agency's
Exposure
Factors
Handbook;

C
Postapplication
residential
risks
are
based
generally
on
maximum
application
rates
or
values
specified
in
the
SOPs
For
Residential
Exposure
Assessment.

3.2.3
Residential
Postapplication
Exposure
and
Risk
Estimates
The
residential
postapplication
exposure
and
risk
calculations
are
presented
in
this
section.
Risks
were
calculated
using
the
Margin
of
Exposure
(
MOE).
The
major
difference
with
residential
risk
assessments
is
that
the
uncertainty
factor
which
defines
the
level
of
risk
concern
also
has
to
consider
application
of
the
additional
FQPA
safety
factor
specified
by
the
legislation.
The
overall
uncertainty
factor
applied
to
cypermethrin
and
zeta­
cypermethrin
for
residential
postapplication
risk
assessments
is
1000.
57
Nondietary
Ingestion
Exposure
From
Treated
Turf:
Nondietary
ingestion
exposure
levels
from
turf
were
calculated
using
the
following
equations.
These
values
were
then
used
to
calculate
MOEs
as
illustrated
above.
The
following
illustrates
the
approach
used
to
calculate
the
nondietary
ingestion
exposures
that
are
attributable
to
hand­
to­
mouth
behavior
on
treated
turf
(
SOP
2.3.2):

Hand
to
Mouth
from
Treated
Turfgrass
Oral
Dose
(
mg/
kg/
day)
=
AR
(
lb
ai/
A)
x
CF
x
F
x
SA
(
cm2)
x
EXT
x
FQ
(
events/
hr)
x
ET(
hrs/
day)
x
(
0.001mg/
µ
g)
BW
(
kg)
Where:

Dose
=
oral
dose
on
day
of
application
(
mg/
kg/
day)
AR
=
application
rate
(
lb
ai/
A)
CF
=
conversion
factors
to
convert
lb
ai
to
:
g
ai
(
4.54E+
8
µ
g/
lb)
and
to
convert
acres
to
cm2
(
2.47E­
8
A/
cm2)
F
=
fraction
of
residue
dislodgeable
to
wet
hands
(
unitless)
SA
=
surface
area
of
1
to
3
fingers
(
cm2)
EXT
=
extraction
rate
by
saliva
(
unitless)
FQ
=
frequency
of
hand­
to­
mouth
events
(
events/
hour)
ET
=
exposure
duration
(
hours/
day)
BW
=
body
weight
(
15
kg)

Assumptions:
SA
­
The
surface
area
of
1
to
3
finger
is
20
cm2
FQ
­
The
frequency
of
hand­
to­
mouth
events
is
20
events
per
hour
for
short­
term
F
­
The
fraction
of
dislodgeable
residue
to
wet
hands
is
5%
EXT
­
The
extraction
rate
by
saliva
is
50%.
ET
­
The
time
spent
outdoors
is
2
hours/
day
The
following
illustrates
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
(
SOP
2.3.3):

Object
to
Mouth
from
Treated
Turfgrass
Oral
Dose
(
mg/
kg/
day)
=
AR
(
lb
ai/
A)
x
CF
x
F
x
SA
(
cm2)
x
(
0.001mg/
µ
g)
BW
(
kg)
Where:

Dose
=
oral
dose
on
day
of
application
(
mg/
kg/
day)
AR
=
application
rate
(
lb
ai/
A)
CF
=
conversion
factors
to
convert
lb
ai
to
:
g
ai
(
4.54E+
8
µ
g/
lb)
and
to
convert
acres
to
cm2
(
2.47E­
8
A/
cm2)
F
=
The
fraction
of
dislodgeable
residue
is
20%
SA
=
surface
area
(
cm2/
day)
BW
=
body
weight
(
15
kg)

Assumptions:
SA
­
The
surface
area
is
25
cm2/
day
F
­
The
fraction
of
dislodgeable
residue
is
20%

The
following
illustrates
the
basics
of
the
approach,
used
to
calculate
exposures
that
are
58
attributable
to
soil
ingestion
(
SOP
2.3.4):

Soil
Ingestion
from
Treated
Turfgrass
Oral
Dose
(
mg/
kg/
day)
=
{
AR
(
lb
ai/
A)
x
F(
1.0/
cm)
x
IgR
(
mg/
day)
x
(
4.54E+
8
µ
g/
lb)
x
(
2.47E+
8
A/
cm2)
x
(
0.67
cm3/
g)
x(
1E­
6
g/
µ
g)}/
BW
(
kg)

Where:

Dose
=
oral
dose
on
day
of
application
(
mg/
kg/
day)
AR
=
application
rate
(
lb
ai/
A)
F
=
fraction
or
residue
retained
on
uppermost
1
cm
of
soil
IgR
=
ingestion
rate
of
soil
(
mg/
day)
CF1
=
weight
unit
conversion
factor
to
convert
the
lbs
ai
in
the
application
rate
to
µ
g
for
the
soil
residue
value
(
4.54
x
108
µ
g/
lb)
CF2
=
area
unit
conversion
factor
to
convert
the
surface
area
units
(
ft2)
in
the
application
rate
to
cm2
for
the
SR
value
(
2.47
x
10­
8
acre/
cm2)
CF3
=
volume
to
weight
unit
conversion
factor
to
convert
the
volume
units
(
cm3)
to
weight
units
for
the
soil
residue
value
(
0.67
cm3/
g
soil)
CF4
=
weight
unit
conversion
factor
to
convert
the
µ
g
of
residues
on
the
soil
to
grams
to
provide
units
of
mg/
day
(
1E­
6
g/
µ
g)
BW
=
body
weight
(
15
kg)

Assumptions:
F
­
The
fraction
or
residue
retained
on
uppermost
1
cm
of
soil
is
100
percent
based
on
soil
incorporation
into
top
1
cm
of
soil
after
application
(
1.0/
cm)
IgR
­
The
ingestion
rate
of
soil
is
100
mg/
day
Oral
exposure
from
hand­
to­
mouth
activity
on
treated
indoor
hard
surfaces
and
carpet:
The
following
demonstrates
the
method
used
to
calculate
exposures
that
are
attributable
to
a
child
touching
treated
carpet
or
a
hard
surface
and
then
putting
their
hands
in
their
mouth
(
SOP
8.4):

Hand
to
Mouth
Indoor
Surfaces
Oral
Dose
(
mg/
kg/
day)
=
{
AR
(
lb
ai/
square
foot)
x
CF
x
F
x
SA
(
cm2)
x
EXT
x
ADJ
x
FQ
(
events/
hr)
x
ET(
hrs/
day)
x
(
0.001mg/
µ
g)}/
BW
(
kg)

Where:

Dose
=
oral
dose
on
day
of
application
(
mg/
kg/
day)
AR
=
application
rate
(
lb
ai/
square
foot)
CF
=
conversion
factors
to
convert
lb
ai
to
:
g
ai
(
4.54E­
8
µ
g/
lb)
and
to
convert
square
feet
to
cm2
(
1.08E­
03
sq
ft/
cm2)
F
=
fraction
of
dislodgeable
residue
(
unitless)
SA
=
surface
area
of
1
to
3
fingers
(
cm2)
EXT
=
extraction
rate
by
saliva
(
unitless)
ADJ
=
adjustment
factor
for
spot
or
crack
&
crevice
treatments,
rather
than
broadcast
applications
FQ
=
frequency
of
hand­
to­
mouth
events
(
events/
hour)
ET
=
exposure
duration
(
hours/
day)
BW
=
body
weight
(
15
kg)
59
Assumptions:

F
­
The
fraction
of
dislodgeable
=
residue
is
5%
for
carpet
and
10%
for
hard
surfaces
SA
­
The
surface
area
of
1
to
3
fingers
is
20
cm2
EXT
­
The
extraction
rate
by
saliva
is
50%
ADJ
­
The
adjustment
factor
for
spot
or
crack
&
crevice
treatments
is
50%
FQ
­
The
frequency
of
hand­
to­
mouth
events
is
20
events
per
hour
ET
­
The
exposure
duration
is
2
hours/
day
for
hard
surfaces
and
4
hours/
day
for
carpet
Residential
Postapplication
Risk
Calculations:
For
postapplication
exposure,
the
margin
of
exposure
(
MOE)
was
calculated
as
follows:

Short­
term
Inhalation
MOE
=
Short­
term
Inhalation
NOAEL
(
2.7
mg/
kg/
day)
Short­
term
Inhalation
Exposure
Dose
Short­
term
Oral
MOE
=
Short­
term
Incidental
Oral
NOAEL
(
10
mg/
kg/
day)
Short­
term
Oral
Exposure
Dose
Post­
application
short­
term
inhalation
exposures
for
the
indoor
fogger
treatment,
were
assessed
using
time­
weighted
averages
from
the
cyfluthrin
room
fogger
study
(
Eberhart,
1987).
The
TWA's
cover
the
period
following
2.5
hours
of
ventilation
as
per
label
recommendations.
Post­
application
inhalation
exposure
for
the
use
of
aerosol
spray
treatments
to
carpets
use
air
concentrations
taken
from
the
crack
and
crevice
subset
of
PHED.
A
House
Model
was
then
used
to
estimate
an
emission
rate
based
on
the
dilution
features
of
the
model.

The
data
mentioned
above
will
serve
as
appropriate
surrogate
for
cypermethrin
since
all
synthetic
pyrethroids
have
similar
physical
and
chemical
properties.
Furthermore,
the
vapor
pressure
for
cypermethrin
is
lower
than
most
of
the
other
synthetic
pyrethroids.
Therefore
this
data
should
provide
conservative
estimations
for
indoor
exposures.
The
above
data
are
also
utilized
in
the
assessment
of
Zeta­
cypermethrin
(
M.
Collantes,
12/
04/
2001).

Table
18:
Residential
Risk
Estimates
for
Postapplication
from
Inhalation
Exposure
to
Cypermethrin
Exposure
Scenario
Route
of
Exposure
Population
Application
Rate
Daily
Dose
(
mg/
kg/
day)
MOEb
Indoor
surface
Inhalation
Adult
0.000017
lb
ai/
ft2
1.25E­
05
216000
Inhalation
Child
(
1­
6)
3.15E­
05
86000
Inhalation
Infant
(<
1)
3.81E­
05
71000
a
Application
rates
represent
maximum
label
rates
from
current
EPA
registered
labels
(
0.000017
lb
ai/
ft2
)
b
Inhalation
MOE
=
Inhalation
NOAEL
(
2.7
mg/
kg/
day
for
short­
term
)/
Daily
Dose
(
mg/
jg/
day).
Target
MOE
is
1,000.

Risk
Summary:

All
of
the
risk
calculations
for
the
various
residential
cypermethrin
and
zeta­
cypermethrin
assessments
are
included
in
Appendix
B
for
the
turf
and
indoor
surface
scenarios.
The
Agency
60
has
addressed
residential
postapplication
exposures
to
cypermethrin
and
zeta­
cypermethrin
using
the
standard
set
of
scenarios
that
are
prescribed
in
current
guidance.
The
uncertainty
factors
are
similar
to
those
applied
to
the
residential
handler
assessments
described
above
(
i.
e.,
1000
for
all
duration
exposures).

Table
19:
Residential
Risk
Estimates
for
Postapplication
from
Oral
Exposure
to
Cypermethrin
Exposure
Scenario
Route
of
Exposure
Population
Application
Ratea
MOEb
Short­
term
Postapplication
Exposures
Outdoors
Hand
to
Mouth
Activity
on
Turfc
Oral
Toddler
0.600
lb
ai/
acre
1,100
0.440
lb
ai/
acre
1,500
Object
to
Mouth
Activity
on
Turfd
Oral
Toddler
0.600
lb
ai/
acre
4,500
0.440
lb
ai/
acre
6,100
Incidental
Soil
Ingestione
Oral
Toddler
0.600
lb
ai/
acre
330,000
0.440
lb
ai/
acre
450,000
Indoors
Hand
to
Mouth
Activity
from
Indoor
Surfaces
Following
Crack
&
Crevice
Treatmentf
Oral
Toddler
0.000017
lb
ai/
sq
ft
900
Hand
to
Mouth
Activity
from
Indoor
Surfaces
Following
Broadcast
with
Foggerg
Oral
Toddler
0.00035
lb
ai/
1000
cubic
ft
1,400
Footnotes:
a
Application
rates
represent
maximum
label
rates
from
current
EPA
registered
labels
(
Wettable
Powder
rate
is
0.6
lb
ai/
acre,
emulsifiable
concentrate
rate
is
0.44
lb
ai/
acre).
b
MOEs
calculated
using
residues
which
would
be
found
on
day
of
treatment.
Oral
MOE
=
Oral
NOAEL
(
10
mg/
kg/
day
for
short­
term
and
5
mg/
kg/
day
for
intermediate­
term/
Oral
Dose
(
mg/
kg/
day).
Target
MOE
is
1,000.
c
Hand­
to­
mouth
Dose
Calculation:
oral
dose
to
child
(
1­
6
year
old)
on
the
day
of
treatment
(
mg/
kg/
day)
=
[
application
rate
(
lb
ai/
acre)
x
fraction
of
residue
dislodgeable
from
potentially
wet
hands
(
5%)
x
11.2
(
conversion
factor
to
convert
lb
ai/
acre
to
µ
g/
cm2)]
x
median
surface
area
for
1­
3
fingers
(
20
cm2/
event)
x
hand­
to­
mouth
rate
(
20
events/
hour)
x
exp.
time
(
2
hr/
day)
x
50%
saliva
extraction
factor
x
0.001
mg/:
g]
/
bw
(
15
kg
child).
d
Object
to
Mouth
Activity
on
­
Turf
Dose
Calculation:
oral
dose
to
child
(
1­
6
year
old)
on
the
day
of
treatment
=
[
application
rate
(
lb
ai/
acre)
x
fraction
of
residue
dislodgeable
(
5%)
x
11.2
(
conversion
factor
to
convert
lb
ai/
acre
to
µ
g/
cm2)]
x
median
surface
area
for
1­
3
fingers
(
25
cm2/
event)
x
hand­
to­
mouth
rate
(
20
events/
hour)
x
0.001
mg/:
g]]
/
bw
(
15
kg
child).
e
Incidental
Soil
ingestion
­
Dose
Calculation:
oral
dose
to
child
(
1­
6
year
old)
on
the
day
of
treatment
(
mg/
kg/
day)
=
[(
application
rate
(
lb
ai/
acre)
x
fraction
of
residue
retained
on
uppermost
1
cm
of
soil
(
100%
or
1.0/
cm)
x
4.54E+
08
µ
g/
lb
conversion
factor
x
2.47E­
08
acre/
cm2
conversion
factor
x
0.67
cm3/
g
soil
conversion
factor)
x
100
mg/
day
ingestion
rate
x
1.0E­
06
g/
µ
g
conversion
factor]
/
bw
(
15
kg).
f
Hand
to
Mouth
Activity
from
Indoor
Surfaces
­
Dose
Calculation:
oral
dose
to
child
(
1­
6
year
old)
on
the
day
of
treatment
(
mg/
kg/
day)
=
[
application
rate
(
lb
ai/
sq
ft)
x
fraction
of
residue
dislodgeable
(
5%)
x
4.95E+
5
(
conversion
factor
to
convert
lb
ai/
square
feet
to
µ
g/
cm2)]
x
median
surface
area
for
1­
3
fingers
(
20
cm2/
event)
x
hand­
to­
mouth
rate
(
20
events/
hour)
x
exp.
time
(
4
hr/
day)
x
50%
saliva
extraction
factor
x
50%
crack
&
crevice
factor
x
0.001
mg/:
g]
/
bw
(
15
kg
child).
g
Hand
to
Mouth
Activity
from
Indoor
Surfaces
(
Fogger)
­
Dose
Calculation:
oral
dose
to
child
(
1­
6
year
old)
on
the
day
of
treatment
(
mg/
kg/
day)
=
[
fogger
deposition
(
µ
g/
cm2)
x
fraction
of
residue
dislodgeable
(
5%)
x
median
surface
area
for
1­
3
fingers
(
20
cm2/
event)
x
hand­
to­
mouth
rate
(
20
events/
hour)
x
exp.
time
(
4
hr/
day)
x
50%
saliva
extraction
factor
x
0.001
mg/:
g]
/
bw
(
15
kg
child).
Fogger
deposition
=
lb
ai/
fogger
(
0.0014
lb/
ft3)
x
4.5E+
08
µ
g/
lb
conversion
factor
x
0.001
mg/:
g
conversion
factor
/
room
area
(
256
ft2)

Note:
Assumptions
used
in
dose
calculations
are
from
Residential
SOPs
(
revised
2/
01).
61
Table
20:
Residential
Risk
Estimates
for
Postapplication
from
Exposure
to
Zeta­
Cypermethrin
Exposure
Scenario
Route
of
Exposure
Population
Application
Ratea
MOEb
Short­
term
Postapplication
Exposures
Outdoors
Hand
to
Mouth
Activity
on
Turf
Oral
Toddler
0.3
lb
ai/
acre
2,200
Object
to
Mouth
Activity
on
Turf
Oral
Toddler
0.3
lb
ai/
acre
8,900
Incidental
Soil
Ingestion
Oral
Toddler
0.3
lb
ai/
acre
670,000
Indoors
Hand
to
Mouth
Activity
from
Indoor
Surfaces
(
carpet
and
hard
floor)
Oral
Toddler
0.000004
lb
ai/
sq
ft
3,500
Footnotes:
a
Application
rates
represent
maximum
label
rates
from
current
EPA
registered
labels
is
0.30
lb
ai/
acre.
b
MOEs
calculated
using
residues
which
would
be
found
on
day
of
treatment.
Oral
MOE
=
Oral
NOAEL
(
10
mg/
kg/
day
for
short­
term
and
5
mg/
kg/
day
for
intermediate­
term/
Oral
Dose
(
mg/
kg/
day).
Target
MOE
is
1,000.
c
Hand­
to­
mouth
Dose
Calculation:
oral
dose
to
child
(
1­
6
year
old)
on
the
day
of
treatment
(
mg/
kg/
day)
=
[
application
rate
(
lb
ai/
acre)
x
fraction
of
residue
dislodgeable
from
potentially
wet
hands
(
5%)
x
11.2
(
conversion
factor
to
convert
lb
ai/
acre
to
µ
g/
cm2)]
x
median
surface
area
for
1­
3
fingers
(
20
cm2/
event)
x
hand­
to­
mouth
rate
(
20
events/
hour)
x
exp.
time
(
2
hr/
day)
x
50%
saliva
extraction
factor
x
0.001
mg/:
g]
/
bw
(
15
kg
child).
d
Object
to
Mouth
Activity
on
­
Turf
Dose
Calculation:
oral
dose
to
child
(
1­
6
year
old)
on
the
day
of
treatment
=
[
application
rate
(
lb
ai/
acre)
x
fraction
of
residue
dislodgeable
(
5%)
x
11.2
(
conversion
factor
to
convert
lb
ai/
acre
to
µ
g/
cm2)]
x
median
surface
area
for
1­
3
fingers
(
25
cm2/
event)
x
hand­
to­
mouth
rate
(
20
events/
hour)
x
0.001
mg/:
g]]
/
bw
(
15
kg
child).
e
Incidental
Soil
ingestion
­
Dose
Calculation:
oral
dose
to
child
(
1­
6
year
old)
on
the
day
of
treatment
(
mg/
kg/
day)
=
[(
application
rate
(
lb
ai/
acre)
x
fraction
of
residue
retained
on
uppermost
1
cm
of
soil
(
100%
or
1.0/
cm)
x
4.54E+
08
µ
g/
lb
conversion
factor
x
2.47E­
08
acre/
cm2
conversion
factor
x
0.67
cm3/
g
soil
conversion
factor)
x
100
mg/
day
ingestion
rate
x
1.0E­
06
g/
µ
g
conversion
factor]
/
bw
(
15
kg).
f
Hand
to
Mouth
Activity
from
Indoor
Surfaces
­
Dose
Calculation:
oral
dose
to
child
(
1­
6
year
old)
on
the
day
of
treatment
(
mg/
kg/
day)
=
[
application
rate
(
lb
ai/
sq
ft)
x
fraction
of
residue
dislodgeable
(
5%)
x
4.95E+
5
(
conversion
factor
to
convert
lb
ai/
square
feet
to
µ
g/
cm2)]
x
median
surface
area
for
1­
3
fingers
(
20
cm2/
event)
x
hand­
to­
mouth
rate
(
20
events/
hour)
x
exp.
time
(
4
hr/
day)
x
50%
saliva
extraction
factor
x
0.001
mg/:
g]
/
bw
(
15
kg
child).

Note:
Assumptions
used
in
dose
calculations
(
e.
g.,
transfer
coefficients)
are
from
Residential
SOPs
(
revised
2/
01).

Table
21:
Combined
Short­
Term
Cypermethrin
Residential
Scenarios
for
Postapplication
Risk
Estimates
Exposure
Scenario
Margins
of
Exposure
(
MOEs)
(
UF=
1000)

Dermal
Oral
(
Non­
Dietary)
Total
Non­
Dietary
Riska
Short­
term
Exposures
Toddler
Turf:
wettable
powder
formulation
(
0.600
lb
ai/
acre)
on
turf
Postapp
Hand
to
Mouth
N/
A
1,100
890
Object
to
Mouth
N/
A
4,500
Incidental
Soil
Ingestion
N/
A
330,000
Toddler
Turf:
liquid
formulation
(
0.440
lb
ai/
acre)
on
turf
Postapp
Hand
to
Mouth
N/
A
1,500
1,200
Object
to
Mouth
N/
A
6,100
Incidental
Soil
Ingestion
N/
A
450,000
a
The
following
formula
is
used
to
calculate
total
MOE
values
by
combining
the
route­
specific
MOEs:
MOE
total
=
1/((
1/
MOE
a)
+
(
1/
MOE
b)
+....
(
1/
MOE
n)).
Where:
MOE
a,
MOE
b,
and
MOE
n
represent
MOEs
for
each
exposure
route
of
concern.
62
Table
22:
Combined
Short­
Term
Zeta­
Cypermethrin
Residential
Scenarios
for
Postapplication
Risk
Estimates
Exposure
Scenario
Margins
of
Exposure
(
MOEs)
(
UF=
1000)

Dermal
Oral
(
Non­
Dietary)
Total
Non­
Dietary
Riska
Toddler
Turf
(
0.3
lb
ai/
acre)
Postapp
Hand
to
Mouth
N/
A
2,200
1,800
Object
to
Mouth
N/
A
8,900
Incidental
Soil
Ingestion
N/
A
670,000
a
The
following
formula
is
used
to
calculate
total
MOE
values
by
combining
the
route­
specific
MOEs:
MOE
total
=
1/((
1/
MOE
a)
+
(
1/
MOE
b)
+....
(
1/
MOE
n)).
Where:
MOE
a,
MOE
b,
and
MOE
n
represent
MOEs
for
each
exposure
route
of
concern.

Risk
Summary:

Cypermethrin
EPA
assessed
postapplication
risks
to
toddlers
from
incidental
oral
ingestion
using
a
shortterm
incidental
oral
endpoint
(
10
mg/
kg/
day)
for
cypermethrin.
The
results
indicate
that
risks
from
short­
term
exposures
were
above
HED's
level
of
concern
(
i.
e.,
MOE
<
1000)
for
hand
to
mouth
transfer
of
residues
following
crack
&
crevice
applications
to
indoor
surfaces
(
MOE
=
900).

When
the
postapplication
risks
to
toddlers
from
incidental
oral
ingestion
following
applications
to
lawns
were
combined,
the
results
indicate
that
the
combined
risks
were
above
HED's
level
of
concern
for
wettable
powder
applications
at
a
rate
of
0.6
pounds
active
ingredient
per
acre.
The
postapplication
oral
exposures
to
toddlers
following
liquid
concentrate
applications
to
lawns
were
below
HED's
level
of
concern
at
a
rate
of
0.44
pounds
active
ingredient
per
acre.

Zeta­
Cypermethrin
EPA
assessed
postapplication
risks
to
toddlers
from
incidental
oral
ingestion
using
a
shortterm
incidental
oral
endpoint
(
10
mg/
kg/
day)
for
zeta­
cypermethrin.
For
residential
postapplication
risks,
MOEs
are
of
not
a
concern
for
any
of
the
oral
non­
dietary
scenarios,
because
they
are
greater
than
1000
and
do
not
exceed
HED's
level
of
concern
(
i.
e.,
MOE
<
1000)
for
risk
assessments
in
nonoccupational
settings.

When
the
postapplication
risks
to
toddlers
from
incidental
oral
ingestion
following
applications
to
lawns
were
combined,
the
results
indicate
that
the
combined
risks
were
below
HED's
level
of
concern.

3.2.4
Recommendations:
Refining
Residential
Postapplication
Risk
Assessment
The
residential
postapplication
residential
assessment
for
cypermethrin
and
zetacypermethrin
is
not
based
on
any
chemical­
specific
studies.
3.3
Residential
Risk
Characterization
63
Characterization
of
the
residential
risks
included
in
this
document
must
consider
each
of
the
approaches
used
to
calculate
risks
in
this
document
as
well
as
the
information
that
could
be
forthcoming
in
any
probabilistic
assessment
that
is
submitted
for
cypermethrin
and
zetacypermethrin

3.3.1
Characterization
Of
Residential
Handler
Risks
The
residential
handler
assessment
for
cypermethrin
is
complex
in
that
calculations
were
completed
for
different
equipment
and
application
rate
scenarios.
The
data
that
were
used
in
the
cypermethrin
residential
handler
assessment
represent
the
best
data
and
approaches
that
are
currently
available.
For
all
of
the
use
patterns,
the
Pesticide
Handlers
Exposure
Database
(
PHED)
was
used
to
develop
the
unit
exposure
values.
The
quality
of
the
data
included
in
PHED
vary
widely
from
scenarios
that
meet
guideline
requirements
for
studies
to
others
where
a
limited
number
of
poor
quality
datapoints
are
available.
All
data
that
have
been
used
may
not
be
of
optimal
quality
but
represent
the
best
available
data.

The
inputs
for
application
rate
and
other
use/
usage
information
(
e.
g.,
area
treated
and
frequency
of
use)
used
by
the
Agency
were
supported
by
the
available
cypermethrin
labels.
The
uncertainties
in
the
occupational
assessment
and
their
impacts
on
the
results
should
be
considered
as
well
in
the
interpretation
of
the
results
for
residential
handlers.
Section
2.3.1
provides
a
summary
of
these
issues.

In
summary,
with
respect
to
residential
handler
risks,
the
Agency
believes
that
the
values
presented
in
this
assessment
represent
the
highest
quality
results
that
could
be
produced
given
the
exposure,
use,
and
toxicology
data
that
are
available.

3.3.2
Characterization
Of
Residential
Postapplication
Risks
Like
the
residential
handler
assessment
discussed
above,
the
postapplication
residential
assessment
for
cypermethrin
and
zeta­
cypermethrin
is
complex.
The
general
population
can
be
exposed
through
many
different
pathways
that
result
from
uses
on
lawns
and
from
indoor
surface
treatments.
To
represent
the
wide
array
of
possible
exposures,
the
Agency
relies
on
the
scenarios
that
have
been
defined
in
the
SOPs
For
Residential
Exposure
Assessment
and
accompanying
documents
such
as
the
overview
presented
to
the
FIFRA
Science
Advisory
Panel.
For
turf
uses,
the
Agency
considered
only
toddlers
(
3
year
olds)
in
the
assessments.
Toddler
MOEs
were
calculated
for
nondietary
ingestion
(
hand­/
object­
to­
mouth
and
soil
ingestion).
MOEs
from
treated
indoor
surfaces
were
also
evaluated
for
toddlers
for
whom
exposures
may
occur
from
hand­
to­
mouth
behavior.

The
data
that
were
used
in
the
cypermethrin
and
zeta­
cypermethrin
residential
postapplication
assessment
represent
the
best
data
and
approaches
that
are
currently
available.
To
the
extent
possible,
the
Agency
has
attempted
to
use
cypermethrin­
and
zeta­
cypermethrinspecific
data.
When
chemical­
specific
data
were
unavailable,
the
Agency
used
the
current
approaches
for
residential
assessment,
many
of
which
include
recent
upgrades
to
the
SOPs.
For
example,
for
the
toddler
hand­
to­
mouth
calculations,
no
TTR
data
were
available
but
a
5percent
transferability
factor
was
applied
to
calculate
residue
levels
appropriate
for
this
exposure
pathway.
Finally,
the
Agency
believes
that
the
values
presented
in
this
assessment
represent
the
highest
64
quality
results
that
could
be
produced
based
on
the
currently
available
postapplication
exposure
data.
The
Agency
believes
that
the
risks
represent
reasonable
worse­
case
estimates
of
exposure
because
maximum
application
rates
are
used
to
define
residue
levels
upon
which
the
calculations
are
based.
MOEs
of
900
is
only
of
marginal
concern
given
the
conservative
assumptions
used
in
the
exposure
assessment.
65
Appendix
A:
Occupational
and
Residential
Handler
Assumptions
and
Exposures
Risks
66
Appendix
A/
Table
A1:
Sources
of
Exposure
Data
Used
In
The
Short­
and
Intermediate­
Term
Occupational
Cypermethrin
and
Zeta­
Cypermethrin
Handler
Exposure
And
Risk
Calculations
Exposure
Scenario
(
Number)
Data
Source
Standard
Assumptions
(
8­
hr
work
day)
Comments
Mixer/
Loader
Descriptors
Mixing/
Loading
Liquid
Formulations
(
Cypermethrin
and
Zeta­

Cypermethrin:
1a
through
1d)
PHED
V1.1
Aerial:
1200
acres
for
high
acreage
agricultural
crops
and
350
acres
for
all
other
crops;
Chemigation:
350
acres
for
agricultural
crops;

Groundboom:
200
acres
for
high
acreage
agricultural
crops,
40
acres
for
ornamental
plants,
and
80
acres
for
all
other
crops;
Airblast:
20
acres
for
ornamental
crops,
and
40
acres
for
other
agricultural
crops
Baseline:
Hands,
dermal,
and
inhalation
=
acceptable
grades.
Hands
=
53
replicates;
Dermal
=
72
to
122
replicates;
and
Inhalation
=
85
replicates.
High
confidence
in
hand,
dermal,
and
inhalation
data.
No
protection
factor
was
needed
to
define
the
unit
exposures.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hands
=
acceptable
grades.
Hands
=
59
replicates.
High
confidence
in
hand
data.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only)

Engineering
Controls:
Hands
and
dermal,
and
inhalation
=
acceptable
grades.
Hands
=
31
replicates;
Dermal
=
16
to
22
replicates;
and
Inhalation
=
27
replicates.
High
confidence
in
hand,
dermal,
and
inhalation
data.
Gloves
were
used
coupled
with
engineering
controls
since
empirical
data
without
gloves
were
not
available
and
back
calculation
of
gloves
to
a
no
glove
scenario
is
believed
to
give
erroneously
high
estimates.

Mixing/
Loading
Wettable
Powder
Formulations
(
Cypermethrin:
2a
through
2d)
PHED
V1.1
Aerial:
1200
acres
for
high
acreage
agricultural
crops
and
350
acres
for
all
other
crops;
Chemigation:
350
acres
for
agricultural
crops;

Groundboom:
200
acres
for
high
acreage
agricultural
crops,
40
acres
for
ornamental
plants,
and
80
acres
for
all
other
crops;
Airblast:
20
acres
for
ornamental
crops,
and
40
acres
for
other
agricultural
crops
Baseline:
Hands,
dermal,
and
inhalation
=
ABC
grades.
Hands
=
7
replicates;
Dermal
=
22
to
45
replicates;
and
Inhalation
=
44
replicates.
Low
confidence
in
hand
and
dermal
data.
Medium
confidence
in
inhalation
data.
No
protection
factor
was
needed
to
define
the
unit
exposures.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hands
=
ABC
grades.
Hands
=
24
replicates.
Medium
confidence
in
hand
data.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only)

Engineering
Controls:
Dermal
=
ABC
grades.
Hands
and
inhalation
=
all
grades.
Hands
=
5
replicates;
Dermal
=
6
to
15
replicates;
and
Inhalation
=
15
replicates.
Low
confidence
in
hand,
dermal,
and
inhalation
data.
Gloves
were
used
coupled
with
engineering
controls
since
empirical
data
without
gloves
were
not
available
and
back
calculation
of
gloves
to
a
no
glove
scenario
is
believed
to
give
erroneously
high
estimates.

Loading
Dust
Formulations
(
Zeta­
cypermethrin:
2)
PHED
V1.1
Mechanical
Duster
and/
or
Dust
Bag:

1000
animals
PHED
exposure
data
for
wettable
powder
mixing/
loading
(
scenarios
2a
­
2c)
was
used
as
a
surrogate
for
dust
loading.

Applying
Descriptors
Applying
Sprays
with
a
Fixed­
wing
Aircraft
(
Cypermethrin
and
Zetacypermethrin
3)
PHED
V1.1
1200
acres
for
high
acreage
agricultural
crops
and
350
acres
for
all
other
crops
Engineering
Controls:
Hands
=
ABC
grade,
dermal
and
inhalation
=
ABC
grade.
Hands=
34
replicates,
dermal
=
24
to
48
replicates,
and
inhalation
=
23
replicates.
Medium
confidence
in
dermal,
hand,
and
inhalation
data.
No
protection
factor
was
needed
to
define
the
unit
exposure
value.

EPA
has
no
data
for
this
scenario,
other
than
enclosed
cockpits
 
the
engineering
control.
Appendix
A/
Table
A1:
Sources
of
Exposure
Data
Used
In
The
Short­
and
Intermediate­
Term
Occupational
Cypermethrin
and
Zeta­
Cypermethrin
Handler
Exposure
And
Risk
Calculations
Exposure
Scenario
(
Number)
Data
Source
Standard
Assumptions
(
8­
hr
work
day)
Comments
67
Applying
Sprays
with
a
Groundboom
Sprayer
(
Cypermethrin
and
Zetacypermethrin
4)
PHED
V1.1
200
acres
for
high
acreage
agricultural
crops
and
80
acres
for
all
other
crops
Baseline:
Hand,
dermal,
and
inhalation
=
acceptable
grades.
Hands
=
29
replicates,
dermal
=
23
to
42
replicates,
and
inhalation
=
22
replicates.
High
confidence
in
hand,
dermal,
and
inhalation
data.
No
protection
factors
were
needed
to
define
the
unit
exposure
values.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hands
=
ABC
grades.
Hands
=
21
replicates.
Medium
confidence
in
hand
data.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Engineering
Controls:
Hand
and
dermal
=
ABC
grade.
Inhalation
=
acceptable
grades.
Hands
=
16
replicates;
dermal
=

20
to
31
replicates;
and
inhalation
=
16
replicates.
Medium
confidence
in
the
hand
and
dermal
data.
High
confidence
in
inhalation
data.
No
protection
factor
needed
to
define
the
unit
exposure
value.
Protective
gloves
not
used.

Applying
Sprays
with
an
Airblast
Sprayer
(
Cypermethrin
and
Zetacypermethrin
5)
PHED
V1.1
40
acres
for
agricultural
crops
Baseline:
Dermal,
hand,
and
inhalation
=
acceptable
grades.
Hands
=
22
replicates,
dermal
=
32
to
49
replicates,
and
inhalation
=
47
replicates.
High
confidence
in
all
data.
No
protection
factor
was
needed
to
define
the
unit
exposure
value.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hands
=
acceptable
grades.
Hands
=
18
replicates.
High
confidence
in
hand
data.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Engineering
Controls:
Hands
and
dermal
=
acceptable
grade,
and
inhalation
=
ABC
grade.
Hands=
20
replicates;

dermal
=
20
to
30
replicates;
and
inhalation
=
9
replicates.
High
confidence
in
hand
and
dermal
data.
Low
confidence
for
inhalation
data.
Gloves
were
used
coupled
with
engineering
controls
since
empirical
data
without
gloves
were
not
available
and
back
calculation
of
gloves
to
a
no
glove
scenario
is
believed
to
give
erroneously
high
(
130:
g/
lb
ai)

estimates
for
a
closed
cab
scenarios.

Applying
Dusts
via
Mechanical
Duster
(

Zetacypermethrin
6)
No
Data
1000
animals
There
is
no
PHED
general
or
chemical
specific
data
for
this
scenario.

Flagging
Descriptors
Flagging
Aerial
Spray
Applications
(
Cypermethrin:

6;
Zeta­
cypermethrin:
7)
PHED
V1.1
350
acres
Baseline:
Hands,
dermal,
and
inhalation
=
acceptable
grades.
Dermal
=
18
to
28
replicates;
hands
=
30
replicates;
and
inhalation
=
28
replicates.
High
confidence
in
dermal,
hand,
and
inhalation
data.
No
protection
factor
was
required
to
calculate
unit
exposures.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hand
=
acceptable
grades.
Hands=
6
replicates.
Low
confidence
in
hand
data.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Engineering
Controls:
The
same
data
are
used
as
for
baseline
coupled
with
a
98%
protection
factor
to
account
for
the
use
of
an
engineering
control
(
e.
g.,
sitting
in
a
vehicle).

Mixing/
Loading/
Applying
Descriptors
Appendix
A/
Table
A1:
Sources
of
Exposure
Data
Used
In
The
Short­
and
Intermediate­
Term
Occupational
Cypermethrin
and
Zeta­
Cypermethrin
Handler
Exposure
And
Risk
Calculations
Exposure
Scenario
(
Number)
Data
Source
Standard
Assumptions
(
8­
hr
work
day)
Comments
68
Mixing/
Loading/
Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
Cypermethrin:
7;

Zetacypermethrin
8)
PHED
V1.1
(
August
1998)
40
gallons
or
5
acres
Baseline:
Hands
=
all
grades;
dermal
and
inhalation
=
ABC
grades.
Dermal
=
9
to
80
replicates;
hands
=
70
replicates;
and
inhalation
=
80
replicates.
Medium
confidence
in
inhalation
data.
Low
confidence
in
dermal
and
hand
data.
No
protection
factor
was
needed
to
define
the
unit
exposure
values.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hand
=
10
replicates.
Hands=
ABC
grades
Low
confidence
in
hand
data..
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Applying
Liquid
Concentrates
with
a
Paint
Brush
(
Cypermethrin:
8;

Zeta­
cypermethrin:
12)
PHED
V1.1
(
August
1998)
5
gallons
Baseline:
Hands
=
AB
grades.
Dermal
and
inhalation
=
C
grades.
Low
confidence
in
dermal
and
hand
data.
Hand
=
15
replicates.
Dermal
=
14
to
15
replicates
and
inhalation
=
15
replicates.
Medium
confidence
in
inhalation
data.

PPE:
Dermal
=
C
grades.
Low
confidence
in
dermal
data.
The
same
hand
data
are
used
as
for
baseline
coupled
with
a
90%
protection
factor
to
account
for
a
gloves.
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%

protection
factor
to
account
for
an
additional
layer
of
clothing.
.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
ORETF
data)
(
Cypermethrin:
9;

Zetacypermethrin
9)
ORETF
Study
(
October
22,

2000)

OMA
002
5
acres
for
turf
Baseline:
Dermal
data
=
B
grade
and
15
replicates.
The
only
empirical
data
available
are
based
on
the
use
of
chemical­
resistant
gloves.
It
is
generally
not
appropriate
to
back­
calculate
a
non­
glove
hand
exposure
levels,
an
extrapolation
has
been
completed
for
this
scenario
(
90
percent
protection
factor
),
however,
because
the
empirical
data
indicate
that
hands
are
a
minor
contributor
to
overall
exposure
levels.
Inhalation
=
B
grade
and
15
replicates.
Moderate
to
high
confidence
in
inhalation
data.

PPE:.
Dermal
data
=
15
replicates
and
high
confidence,
grade
B.
A
50
percent
protection
factor
was
added
to
account
for
the
use
of
an
additional
layer
of
clothing.
Gloved
hand
=
60
replicates.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Mixing/
Loading/
Applying
Liquid
Concentrates
with
an
Injector
(
Cypermethrin:
10)
PHED
V1.1
(
August
1998)
500
gallons
Baseline:
Dermal
and
inhalation
=
AB
grades.
Dermal
=
17
replicates
and
inhalation
=
17
replicates.
The
only
empirical
data
that
are
available
are
based
on
the
use
of
chemical­
resistant
gloves.
It
is
generally
not
appropriate
to
backcalculate
a
non­
glove
hand
exposure
levels.
High
confidence
in
inhalation
data.
Low
confidence
in
dermal
data.

PPE:
Dermal
and
Hands=
AB
grades,
17
replicates
and
high
confidence.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.
Appendix
A/
Table
A1:
Sources
of
Exposure
Data
Used
In
The
Short­
and
Intermediate­
Term
Occupational
Cypermethrin
and
Zeta­
Cypermethrin
Handler
Exposure
And
Risk
Calculations
Exposure
Scenario
(
Number)
Data
Source
Standard
Assumptions
(
8­
hr
work
day)
Comments
69
Mixing/
Loading/
Applying
Wettable
Powders
with
Low
Pressure
Handwand
(
Cypermethrin:
11)
PHED
V1.1
(
August
1998)
40
gallons
Baseline:
Glove
data
was
utilized
to
calculate
no
glove
data
for
hand
scenarios.
Dermal
and
inhalation
=
ABC
grades.

Dermal
=
16
replicates
and
inhalation
=
16
replicates.
Medium
confidence
in
inhalation
data.
Low
confidence
in
dermal
data.
PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hand
=
15
replicates.
Hands=
AB
grades.
Medium
confidence
in
hand
data..
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Applying
Wettable
Powders
with
a
Paint
Brush
(
Cypermethrin:
12)
PHED
V1.1
(
August
1998)
5
gallons
Baseline:
Hands
=
AB
grades.
Dermal
and
inhalation
=
C
grades.
Low
confidence
in
dermal
and
hand
data.
Hand
=
15
replicates.
Dermal
=
14
to
15
replicates
and
inhalation
=
15
replicates.
Medium
confidence
in
inhalation
data.

PPE:
Dermal
=
C
grades.
Low
confidence
in
dermal
data.
The
same
hand
data
are
used
as
for
baseline
coupled
with
a
90%
protection
factor
to
account
for
a
gloves.
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%

protection
factor
to
account
for
an
additional
layer
of
clothing.
.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Mixing/
Loading/
Applying
Wettable
Powders
with
a
Handgun
Sprayer
(
ORETF
data)
(
Cypermethrin:
13)
ORETF
Study
(
October
22,

2000)

OMA
002
5
acres
for
turf
Baseline:
No
dermal
data
for
this
scenario.
Non­
glove
hand
exposure
levels,
were
back­
calculated
for
this
scenario
(
90
percent
protection
factor
),
however,
because
the
empirical
data
indicate
that
hands
are
a
minor
contributor
to
overall
exposure
levels.
Inhalation
=
B
grade
and
15
replicates.
Moderate
to
high
confidence
in
inhalation
data.

PPE:.
Dermal
data
=
15
replicates
and
high
confidence,
grade
B.
Gloved
hand
=
60
replicates.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Mixing/
Loading/
Applying
Water
soluble
Bags
with
a
Handgun
Sprayer
(
ORETF
data)
(
Cypermethrin:
14)
ORETF
Study
(
October
22,

2000)

OMA
002
5
acres
for
turf
Baseline:
No
dermal
data
for
this
scenario.
Non­
glove
hand
exposure
levels,
were
back­
calculated
for
this
scenario
(
90
percent
protection
factor
),
however,
because
the
empirical
data
indicate
that
hands
are
a
minor
contributor
to
overall
exposure
levels.
Inhalation
=
B
grade
and
15
replicates.
Moderate
to
high
confidence
in
inhalation
data.

PPE:
Dermal
(
15
replicates)
and
inhalation
(
15
replicates)
data
of
high
confidence,
grade
B
or
better,
were
used
to
establish
exposure
values
for
each
of
the
scenarios.
Gloved
hand
(
60
replicates)
data
were
used
to
establish
an
exposure
value.
.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).
Engineering
Controls:
Water
soluble
bags
are
considered
an
engineering
control
for
wettable
powder
formulations.
Data
for
mixing/
loading/
applicator
exposure
based
on
commercial
systems
with
some
exposure
controls
during
mixing/
loading.

No
fully
closed
system
available
for
this
scenario.

Applying
Ready
to
Use
Formulations
via
RTU
Ear
Tag
(
Cypermethrin:
15;

Zeta­
cypermethrin:
13)
SOPs
for
Residential
Exposure
Assessments
(
12/
97)
100
and
1000
animals
(
cattle)
Agency
policy
outlined
in
the
Residential
SOPs,
was
utilized
to
define
the
exposure
level
associated
with
putting
a
pet
collar
on
an
animal.
The
SOPs
specify
1
percent
of
the
total
active
ingredient
in
a
pet
collar
is
considered
equal
to
exposure.
It
was
assumed
that
application
of
an
ear
tag
was
similar
to
application
of
a
pet
collar.

A
rangefinder
of
100
to
1000
cattle
(
livestock)
was
utilized
from
Cuomaphos.
Appendix
A/
Table
A1:
Sources
of
Exposure
Data
Used
In
The
Short­
and
Intermediate­
Term
Occupational
Cypermethrin
and
Zeta­
Cypermethrin
Handler
Exposure
And
Risk
Calculations
Exposure
Scenario
(
Number)
Data
Source
Standard
Assumptions
(
8­
hr
work
day)
Comments
70
Applying
Ready
to
Use
Formulations
with
Trigger
Pump
Sprayer
(
Cypermethrin:
16)
PHED
V1.1
(
August
1998)
1
gallon
PHED
exposure
data
for
aerosol
can
application
(
scenario
20)
was
used
as
a
surrogate
for
pump
sprayer
application.

Applying
Ready
to
Use
Formulations
with
Wipes
(
Cypermethrin:
17)
CMA
(
November
1999)
50
to
500
horses
Chemical
Manufacturers
Association
Data
 
6
replicates
Applying
Ready
to
Use
Formulations
with
Aerosol
Cans
(
Cypermethrin:
18)
PHED
V1.1
(
August
1998)
2
cans
Baseline:
Dermal
and
inhalation
=
AB
grade.
Hands
=
A
grade.
Hands
=
15
replicates;
dermal
=
15
replicates;
and
inhalation
=
15
replicates.
High
confidence
in
all
data.
No
protection
factor
was
needed
to
define
the
unit
exposure
values.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hands
=
A
grade.
Hands
=
15
replicates.
High
confidence
in
hand
data.

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Applying
Ready
to
Use
Formulations
with
Ready­
to­

Use
Fogger
(
Cypermethrin:

19)
(
using
PHED
aerosol
can
data)
PHED
V1.1
(
August
1998)
2
cans
Baseline:
Dermal
and
inhalation
=
AB
grade.
Hands
=
A
grade.
Hands
=
15
replicates;
dermal
=
15
replicates;
and
inhalation
=
15
replicates.
High
confidence
in
all
data.
No
protection
factor
was
needed
to
define
the
unit
exposure
values.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hands
=
A
grade.
Hands
=
15
replicates.
High
confidence
in
hand
data.

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Loading/
applying
dusts
via
shaker
can
(
Zetacypermethrin
10)
MRID
444598­
01
100
animals
Baseline:
The
only
empirical
data
that
are
available
are
based
on
the
use
of
no
protective
clothing.
A
total
of
20
replicates
were
monitored
in
this
study.
No
individuals
wore
gloves.
The
clothing
scenario
represents
short­
sleeved
shirt,

short
pants,
and
no
gloves.
The
data
are
considered
high
quality
by
the
Agency.

Mixing/
Loading/
Applying
Liquid
concentrates
with
a
Watering
Can
(

Zetacypermethrin
11)
ORETF
Chemical
Handler
Exposure
Studies
40
ant
mounds
Baseline:
The
only
empirical
data
that
are
available
are
based
on
the
use
of
no
protective
clothing.
Dermal
and
inhalation
=
60
replicates.

Loading
Dusts
into
Self­
Applying
Dust
Bags
(
using
PHED
mixing/
loading
wettable
powders
data)
(

Zetacypermethrin
14)
PHED
V1.1
(
August
1998)
1000
animals
Baseline:
Hands,
dermal,
and
inhalation
=
ABC
grades.
Hands
=
7
replicates;
Dermal
=
22
to
45
replicates;
and
Inhalation
=
44
replicates.
Low
confidence
in
hand
and
dermal
data.
Medium
confidence
in
inhalation
data.
No
protection
factor
was
needed
to
define
the
unit
exposures.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hands
=
ABC
grades.
Hands
=
24
replicates.
Medium
confidence
in
hand
data.
A
respirator
protection
factor
of
5
is
applied
to
estimate
the
use
of
a
quarter­
face
respirator
(
dust/
mist
filtering
only).

Engineering
Controls:
Dermal
=
ABC
grades.
Hands
and
inhalation
=
all
grades.
Hands
=
5
replicates;
Dermal
=
6
to
15
replicates;
and
Inhalation
=
15
replicates.
Low
confidence
in
hand,
dermal,
and
inhalation
data.
Gloves
were
used
coupled
with
engineering
controls
since
empirical
data
without
gloves
were
not
available
and
back
calculation
of
gloves
to
a
no
glove
scenario
is
believed
to
give
erroneously
high
estimates.
71
°
All
Standard
Assumptions
are
based
on
an
8­
hour
work
day
as
estimated
by
the
Agency.

°
All
handler
exposure
assessments
in
this
document
are
based
on
the
"
Best
Available"
data
as
defined
by
the
HED
SOP
for
meeting
Subdivision
U
Guidelines
(
i.
e.,
completing
exposure
assessments).
Best
available
grades
are
assigned
to
data
as
follows:
matrices
with
A
and
B
grade
data
(
i.
e.,
Acceptable
Grade
Data)
and
a
minimum
of
15
replicates;
if
not
available,
then
grades
A,
B
and
C
data
and
a
minimum
of
15
replicates;
if
not
available,
then
all
data
regardless
of
the
quality
(
i.
e.,
All
Grade
Data)
and
number
of
replicates.
High
quality
data
with
a
protection
factor
take
precedence
over
low
quality
data
with
no
protection
factor.
Generic
data
confidence
categories
are
assigned
as
follows:

High
=
grades
A
and
B
and
15
or
more
replicates
per
body
part
Medium
=
grades
A,
B,
and
C
and
15
or
more
replicates
per
body
part
Low
=
grades
A,
B,
C,
D
and
E
or
any
combination
of
grades
with
less
than
15
replicates.

°
PHED
grading
criteria
do
not
reflect
overall
quality
of
the
reliability
of
the
assessment.
Sources
of
the
exposure
factors
should
also
be
considered
in
the
risk
management
decision.
72
Appendix
A
Table
A2:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Applicatio
n
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
80%
PPE­
R
Inhalation
Unit
Exposured
(
ug/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
ug/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
Mixer/
Loader
Mixing/
Loading
Liquid
concentrates
for
Aerial
Application
(
1a)
agricultural
uncultivated
areas;
fencerows,

hedgerows
foliar
3.4
lb
ai/
acre
350
acres
1.2
0.24
0.083
130
660
1,900
cotton
foliar
0.1
lb
ai/
acre
1200
acres
1.2
0.24
0.083
1,300
6,600
19,000
broccoli,
broccoli
raab,

brussel
sprouts,
bok
choy,

cabbage,
cauliflower,

cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,

kale,
kohlrabi,
mizuna,

mustard
greens,
mustard
spinach,
pecans,
rape
greens
foliar
0.1
lb
ai/
acre
350
acres
1.2
0.24
0.083
4,500
23,000
65,000
Mixing/
Loading
Liquid
concentrates
for
Chemigation
Application
(
1b)
broccoli,
broccoli
raab,

brussel
sprouts,
bok
choy,

cabbage,
cauliflower,

cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
cotton,
head
lettuce,
kale,
kohlrabi,

mizuna,
mustard
greens,

mustard
spinach,
pecans,

rape
greens,
foliar
0.1
lb
ai/
acre
350
acres
1.2
0.24
0.083
4,500
23,000
65,000
Mixing/
Loading
Liquid
concentrates
for
Groundboom
Application
(
1c)
agricultural
uncultivated
areas;
fencerows,

hedgerows
foliar
3.4
lb
ai/
acre
80
acres
1.2
0.24
0.083
580
2,900
8,400
ornamental
plants
foliar
3.4
lb
ai/
acre
40
acres
1.2
0.24
0.083
1,200
5,800
17,000
cotton
foliar
0.1
lb
ai/
acre
200
acres
1.2
0.24
0.083
7,900
39,000
110,000
Appendix
A
Table
A2:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Applicatio
n
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
80%
PPE­
R
Inhalation
Unit
Exposured
(
ug/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
ug/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
73
broccoli,
broccoli
raab,

brussel
sprouts,
bok
choy,

cabbage,
cauliflower,

cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,

kale,
kohlrabi,
mizuna,

mustard
greens,
mustard
spinach,
rape
greens
foliar
0.1
lb
ai/
acre
80
acres
1.2
0.24
0.083
20,000
98,000
280,000
Mixing/
Loading
Liquid
concentrates
for
Airblast
Application
(
1d)
pecans
foliar
0.1
lb
ai/
acre
40
acres
1.2
0.24
0.083
39,000
200,000
570,000
ornamental
plants
foliar
3.4
lb
ai/
acre
20
acres
1.2
0.24
0.083
2,300
12,000
33,000
Mixing/
Loading
Wettable
Powders
for
Aerial
Application
(
2a)
agricultural
uncultivated
areas;
fencerows,

hedgerows
foliar
3.4
lb
ai/
acre
350
acres
43
8.6
0.24
4
18
660
sodfarms
foliar
0.74
lb
ai/
acre
350
acres
43
8.6
0.24
17
85
3,000
cotton
foliar
0.1
lb
ai/
acre
1200
acres
43
8.6
0.24
37
180
6,600
broccoli,
broccoli
raab,

brussel
sprouts,
bok
choy,

cabbage,
cauliflower,

cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,

kale,
kohlrabi,
mizuna,

mustard
greens,
mustard
spinach,
pecans,
rape
greens,
foliar
0.1
lb
ai/
acre
350
acres
43
8.6
0.24
130
630
23,000
Appendix
A
Table
A2:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Applicatio
n
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
80%
PPE­
R
Inhalation
Unit
Exposured
(
ug/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
ug/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
74
Mixing/
Loading
Wettable
Powders
for
Chemigation
Application
(
2b)
broccoli,
broccoli
raab,

brussel
sprouts,
bok
choy,

cabbage,
cauliflower,

cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
cotton,
head
lettuce,
kale,
kohlrabi,

mizuna,
mustard
greens,

mustard
spinach,
pecans,

rape
greens,
foliar
0.1
lb
ai/
acre
350
acres
43
8.6
0.24
130
630
23,000
Mixing/
Loading
Wettable
Powders
for
Groundboom
Application
(
2c)
agricultural
uncultivated
areas;
fencerows,

hedgerows
foliar
3.4
lb
ai/
acre
80
acres
43
8.6
0.24
16
81
2,900
ornamental
plants
foliar
3.4
lb
ai/
acre
40
acres
43
8.6
0.24
32
160
5,800
sodfarms
foliar
0.74
lb
ai/
acre
80
acres
43
8.6
0.24
74
370
13,000
cotton
foliar
0.1
lb
ai/
acre
200
acres
43
8.6
0.24
220
1,100
39,000
broccoli,
broccoli
raab,

brussel
sprouts,
bok
choy,

cabbage,
cauliflower,

cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,

kale,
kohlrabi,
mizuna,

mustard
greens,
mustard
spinach,
rape
greens
foliar
0.1
lb
ai/
acre
80
acres
43
8.6
0.24
550
2,700
98,000
Mixing/
Loading
Wettable
Powders
for
Airblast
Application
(
2d)
ornamental
plants
foliar
3.4
lb
ai/
acre
20
acres
43
8.6
0.24
65
320
12,000
pecans
foliar
0.1
lb
ai/
acre
40
acres
43
8.6
0.24
1,100
5,500
200,000
Appendix
A
Table
A2:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Applicatio
n
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
80%
PPE­
R
Inhalation
Unit
Exposured
(
ug/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
ug/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
75
Applicator
Applying
Sprays
with
an
Airplane
(
3)
agricultural
uncultivated
areas;
fencerows,

hedgerows
foliar
3.4
lb
ai/
acre
350
acres
see
Eng.
Controls
see
Eng.
Controls
0.068
see
Eng.
Controls
see
Eng.
Controls
2,300
sodfarms
foliar
0.74
lb
ai/
acre
350
acres
see
Eng.
Controls
see
Eng.
Controls
0.068
see
Eng.
Controls
see
Eng.
Controls
11,000
cotton
foliar
0.1
lb
ai/
acre
1200
acres
see
Eng.
Controls
see
Eng.
Controls
0.068
see
Eng.
Controls
see
Eng.
Controls
23,000
broccoli,
broccoli
raab,

brussel
sprouts,
bok
choy,

cabbage,
cauliflower,

cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,

kale,
kohlrabi,
mizuna,

mustard
greens,
mustard
spinach,
pecans,
rape
greens,
foliar
0.1
lb
ai/
acre
350
acres
see
Eng.
Controls
see
Eng.
Controls
0.068
see
Eng.
Controls
see
Eng.
Controls
79,000
Applying
Sprays
with
Groundboom
Application
(
4)
agricultural
uncultivated
areas;
fencerows,

hedgerows
foliar
3.4
lb
ai/
acre
80
acres
0.74
0.15
0.043
940
4,600
16,000
ornamental
plants
foliar
3.4
lb
ai/
acre
40
acres
0.74
0.15
0.043
1,900
9,300
32,000
sodfarms
foliar
0.74
lb
ai/
acre
80
acres
0.74
0.15
0.043
4,300
21,000
74,000
cotton
foliar
0.1
lb
ai/
acre
200
acres
0.74
0.15
0.043
13,000
63,000
220,000
Appendix
A
Table
A2:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Applicatio
n
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
80%
PPE­
R
Inhalation
Unit
Exposured
(
ug/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
ug/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
76
broccoli,
broccoli
raab,

brussel
sprouts,
bok
choy,

cabbage,
cauliflower,

cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
head
lettuce,

kale,
kohlrabi,
mizuna,

mustard
greens,
mustard
spinach,
rape
greens
foliar
0.1
lb
ai/
acre
80
acres
0.74
0.15
0.043
32,000
160,000
550,000
Applying
Sprays
with
an
Airblast
(
5)
ornamental
plants
foliar
3.4
lb
ai/
acre
20
acres
4.5
0.9
0.45
620
3,100
6,200
pecans
foliar
0.1
lb
ai/
acre
40
acres
4.5
0.9
0.45
11,000
53,000
110,000
Flagger
Flagging
for
Aerial
Sprays
(
6)
agricultural
uncultivated
areas;
fencerows,

hedgerows
foliar
3.4
lb
ai/
acre
350
acres
0.35
0.07
0.007
450
2,300
23,000
sodfarms
foliar
0.74
lb
ai/
acre
350
acres
0.35
0.07
0.007
2,100
10,000
100,000
broccoli,
broccoli
raab,

brussel
sprouts,
bok
choy,

cabbage,
cauliflower,

cavalo
broccolo,
Chinese
broccoli,
Chinese
cabbage,

collards,
cotton,
head
lettuce,
kale,
kohlrabi,

mizuna,
mustard
greens,

mustard
spinach,
pecans,

rape
greens
foliar
0.1
lb
ai/
acre
350
acres
0.35
0.07
0.007
15,000
77,000
770,000
Mixer/
Loader/
Applicator
Appendix
A
Table
A2:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Applicatio
n
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
80%
PPE­
R
Inhalation
Unit
Exposured
(
ug/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
ug/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
77
Mixing/
Loading/

Applying
Emulsifiable
Concentrate
with
a
Low
Pressure
Handwand
(
7)
residential,
commercial
and
industrial
lawns
foliar
0.44
lb
ai/
acre
5
acres
30
6
Not
Feasible
2,900
14,000
Not
Feasible
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,

and
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
Termites:

building
perimeter,

masonry
voids,
standing
wood
0.05
lb
ai/
gallon
40
gallons
30
6
Not
Feasible
3,200
16,000
Not
Feasible
Termites:
preconstruction
lumber
and
logs,
soil
under
firewood
Termites:
preconstru
ction
lumber
and
logs,
soil
under
firewood
0.041
lb
ai/
gallon
40
gallons
30
6
Not
Feasible
3,800
19,000
Not
Feasible
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,

commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
applications
to
horses
0.017
lb
ai/
gallon
40
gallons
30
6
Not
Feasible
9,300
46,000
Not
Feasible
ornamental
plants;
termite
applications
to
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
foliar
0.008
lb
ai/
gallon
40
gallons
30
6
Not
Feasible
20,000
98,000
Not
Feasible
Mixing/
Loading/

Applying
Emulsifiable
Concentrate
with
a
Paintbrush
(
8)
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,

and
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
standing
wood
(
termites)
0.05
lb
ai/
gallon
5
gallons
280
56
Not
Feasible
2,700
14,000
Not
Feasible
Appendix
A
Table
A2:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Applicatio
n
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
80%
PPE­
R
Inhalation
Unit
Exposured
(
ug/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
ug/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
78
Termites:
preconstruction
lumber
and
logs,
soil
under
firewood
lumber
and
logs
0.041
lb
ai/
gallon
5
gallons
280
56
Not
Feasible
3,300
16,000
Not
Feasible
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,

commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
outdoor
surfaces
0.017
lb
ai/
gallon
5
gallons
280
56
Not
Feasible
7,900
40,000
Not
Feasible
Mixing/
Loading/

Applying
Emulsifiable
Concentrate
with
a
Handheld
Handgun
(
ORETF)
(
9)
agricultural
uncultivated
areas;
fencerows,

hedgerows;
ornamental
plants;
potting
soil,
topsoil
foliar
3.4
lb
ai/
acre
5
acres
1.8
0.36
Not
Feasible
6,200
31,000
Not
Feasible
residential,
commercial
and
industrial
lawns
foliar
0.44
lb
ai/
acre
5
acres
1.8
0.36
Not
Feasible
48,000
240,000
Not
Feasible
Mixing/
Loading/

Applying
Liquid
Concentrates
with
an
Termiticide
Injector
(
10)
Termites:
trees,
utility
poles,
fenceposts,
building
voids
Termites:

trees,
utility
poles,
fenceposts,

building
voids
0.05
lb
ai/
gallon
500
gallons
2.2
0.44
Not
Feasible
3,400
17,000
Not
Feasible
Mixing/
Loading/

Applying
Wettable
Powders
with
a
Low
Pressure
Handwand
(
11)
residential,
commercial
and
industrial
lawns
foliar
0.6
lb
ai/
acre
5
acres
1100
220
Not
Feasible
57
290
Not
Feasible
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,
and
standing
wood
in
uninhabited
areas
at
residential,

commercial
and
industrial
sites
0.05
lb
ai/
gallon
40
gallons
1100
220
Not
Feasible
86
430
Not
Feasible
fire
ant
mounds
mounds
0.033
lb
ai/
gallon
40
gallons
1100
220
Not
Feasible
130
650
Not
Feasible
Appendix
A
Table
A2:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Applicatio
n
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
80%
PPE­
R
Inhalation
Unit
Exposured
(
ug/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
ug/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
79
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,

commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
applications
to
horses
Non­
Termites:

indoor
surfaces,

outdoor
surfaces,

building
perimeters
0.017
lb
ai/
gallon
40
gallons
1100
220
Not
Feasible
250
1,300
Not
Feasible
ornamental
plants;
termite
applications
to
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
foliar
0.008
lb
ai/
gallon
40
gallons
1100
220
Not
Feasible
540
2,700
Not
Feasible
Mixing/
Loading/

Applying
Wettable
Powders
with
a
Paintbrush
(
12)
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,

and
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
standing
wood
(
termites)
0.05
lb
ai/
gallon
5
gallons
280
56
Not
Feasible
2,700
14,000
Not
Feasible
Termites:
preconstruction
lumber
and
logs,
soil
under
firewood
lumber
and
logs
0.041
lb
ai/
gallon
5
gallons
280
56
Not
Feasible
3,300
16,000
Not
Feasible
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,

commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
outdoor
surfaces
0.017
lb
ai/
gallon
5
gallons
280
56
Not
Feasible
7,900
40,000
Not
Feasible
Appendix
A
Table
A2:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Applicatio
n
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
80%
PPE­
R
Inhalation
Unit
Exposured
(
ug/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
ug/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
80
Mixing/
Loading/

Applying
Wettable
Powders
with
a
Handheld
Handgun
(
ORETF)
(
13)
agricultural
uncultivated
areas;
fencerows,

hedgerows;
ornamental
plants;
potting
soil,
topsoil
foliar
3.4
lb
ai/
acre
5
acres
64
12.8
Not
Feasible
170
870
Not
Feasible
residential,
commercial
and
industrial
lawns
foliar
0.6
lb
ai/
acre
5
acres
64
12.8
Not
Feasible
980
4,900
Not
Feasible
Mixing/
Loading/

Applying
Wettable
Powders
in
WSP
with
a
Handheld
Handgun
(
ORETF)
(
14)
agricultural
uncultivated
areas;
fencerows,

hedgerows;
ornamental
plants;
potting
soil,
topsoil
foliar
3.4
lb
ai/
acre
5
acres
7.2
1.44
Not
Feasible
1,500
7,700
Not
Feasible
residential,
commercial
and
industrial
lawns
foliar
0.6
lb
ai/
acre
5
acres
7.2
1.44
Not
Feasible
8,800
44,000
Not
Feasible
Applying
Ready
to
Use
Formulations
via
RTU
Tag
(
15)
cattle
cattle
ear
0.003
lb
ai/
2
ear
tags
1000
cattle
No
Data
No
Data
Not
Feasible
No
Data
No
Data
Not
Feasible
Applying
Ready
to
Use
Formulations
with
Pump
Trigger
Sprayers
(
16)
horses
horses
0.017
lb
ai/
gallon
1
gallon
123
24.6
Not
Feasible
90,000
450,000
Not
Feasible
Applying
Ready
to
Use
Formulations
with
Wipes
(
17)
horses
horses
0.00041
lb
ai/
wipe
500
horses
0.067
0.0134
Not
Feasible
14,000,000
69,000,00
0
Not
Feasible
horses
horses
0.00041
lb
ai/
wipe
50
horses
0.067
0.0134
Not
Feasible
140,000,00
0
690,000,0
00
Not
Feasible
Applying
Ready
to
Use
Formulations
with
Aerosol
Cans
(
18)
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,

commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
Non­
Termite:

indoor
surfaces,

outdoor
surfaces,

horse
barns
0.005
lb
ai/
16
oz
can
2
cans
1300
260
Not
Feasible
15,000
73,000
Not
Feasible
Appendix
A
Table
A2:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Applicatio
n
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
80%
PPE­
R
Inhalation
Unit
Exposured
(
ug/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
ug/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
81
Applying
Ready
to
Use
Formulations
with
Fogger
(
19)
Non­
termite
applications
to
indoor
spaces
at
residential,
commercial
and
industrial
sites,
animal
premises,
and
greenhouses
Non­
Termite:

indoor
surfaces,

outdoor
surfaces,

horse
barns
0.0014
lb
ai/
fogger
4
foggers
1300
260
Not
Feasible
26,000
130,000
Not
Feasible
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
cypermethrin.

b
Amount
handled
per
day
values
are
EPA
estimates
of
acreage
treated
or
gallons
applied
based
on
Exposure
SAC
Policy
#
9
"
Standard
Values
for
Daily
Acres
Treated
in
Agriculture".

c
Baseline
inhalation
unit
exposure
values
from
PHED
Surrogate
Exposure
Guide
and
represent
no
respiratory
protection.

d
80%
PPE­
R
inhalation
unit
exposure
values
from
PHED
Surrogate
Exposure
Guide
and
represent
use
of
a
dust
mist
respirator
(
80
percent
protection
factor
over
baseline).

e
Engineering
control
inhalation
unit
exposure
values
from
PHED
Surrogate
Exposure
Guide
and
represent
:

1a,
1b,
1c,
1d:
closed
mixing
2a,
2b,
2c,
2d:
water
soluble
packets
3:
enclosed
cockpit
4,
5,
6:
enclosed
cab
f
Baseline
inhalation
MOE
=
short­
and
intermediate­
term
NOAEL
(
2.7
mg/
kg/
day)
/
baseline
inhalation
dose
(
mg/
kg/
day),
where
baseline
inhalation
dose
=
baseline
inhalation
unit
exposure
(
µ
g/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
1mg
/
1000
µ
g)
/
body
weight
(
70
kg).

g
80%
PPE­
R
inhalation
MOE
=
short­
and
intermediate­
term
NOAEL
(
2.7
mg/
kg/
day)
/
80
percent
PPE­
R
inhalation
dose
(
mg/
kg/
day),
where
80
percent
PPE­
R
inhalation
dose
=
80
percent
PPE­
R
inhalation
unit
exposure
(
µ
g/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
1mg
/
1000
µ
g)
/
body
weight
(
70
kg).

h
Engineering
Control
inhalation
MOE
=
short­
and
intermediate­
term
NOAEL
(
2.7
mg/
kg/
day)
/
engineering
control
inhalation
dose
(
mg/
kg/
day)
where
engineering
control
inhalation
dose
=
engineering
control
inhalation
unit
exposure
(
µ
g/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
1mg
/
1000
µ
g)
/
body
weight
(
70
kg).
82
Appendix
A
Table
A3:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Zeta­
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
µ
g/
lb
ai)
80%

PPE­
R
Inhalation
Unit
Exposured
(
µ
g/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
µ
g/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
Mixer/
Loader
Mixing/
Loading
Liquid
Concentrates
for
Aerial
Applications
(
1a)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,

and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,

Soybeans,
Wheat,
and
Triticale
0.05
lb
ai/
acre
1200
acres
1.2
0.24
0.083
2600
13000
38000
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,
Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),

Succulent
Edible
Podded
Peas,
Succulent
Edible
Podded
Beans,
Head
Lettuce,
Pecans,
Grain
Sorghum
and
Millet,
Sugarbeet,
Sugarcane
0.05
lb
ai/
acre
350
acres
1.2
0.24
0.083
9000
45000
130000
Mixing/
Loading
Liquid
Concentrates
for
Chemigation
Applications
(
1b)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,

and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,

Soybeans,
Wheat,
and
Triticale
0.05
lb
ai/
acre
350
acres
1.2
0.24
0.083
9000
45000
130000
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,
Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),

Succulent
Edible
Podded
Peas,
Succulent
Edible
Podded
Beans,
Head
Lettuce,
Pecans,
Grain
Sorghum
and
Millet,
Sugarbeet,
Sugarcane
0.05
lb
ai/
acre
350
acres
1.2
0.24
0.083
9000
45000
130000
Mixing/
Loading
Liquid
Concentrates
for
Groundboom
Applications
(
1c)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,

and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,

Soybeans,
Wheat,
and
Triticale
0.05
lb
ai/
acre
200
acres
1.2
0.24
0.083
16000
79000
230000
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,
Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),

Succulent
Edible
Podded
Peas,
Succulent
Edible
Podded
Beans,
Head
Lettuce,
Grain
Sorghum
and
Millet,

Sugarbeet,
Sugarcane
0.05
lb
ai/
acre
80
acres
1.2
0.24
0.083
39000
200000
570000
Mixing/
Loading
Liquid
Concentrates
for
Airblast
Applications
(
1d)
Pecans
0.05
lb
ai/
acre
40
acres
1.2
0.24
0.083
79000
390000
1100000
Loading
Dusts
into
Livestock
(
beef
&
dairy
cattle,
sheep,
goats,
horses)
0.00094
1000
43
8.6
NF
4700
23000
Not
Appendix
A
Table
A3:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Zeta­
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
µ
g/
lb
ai)
80%

PPE­
R
Inhalation
Unit
Exposured
(
µ
g/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
µ
g/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
83
Mechanical
Duster
or
Dust
Bags
(
using
PHED
wettable
powders
data)
(
2)
lb
ai/
animal
animals
Feasible
Applicator
Applying
Sprays
via
Aerial
Equipment
(
3)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,

and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,

Soybeans,
Wheat,
and
Triticale
0.05
lb
ai/
acre
1200
acres
No
Data
No
Data
0.068
No
Data
No
Data
46000
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,
Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),

Succulent
Edible
Podded
Peas,
Succulent
Edible
Podded
Beans,
Head
Lettuce,
Pecans,
Grain
Sorghum
and
Millet,
Sugarbeet,
Sugarcane
0.05
lb
ai/
acre
350
acres
No
Data
No
Data
0.068
No
Data
No
Data
160000
Applying
Sprays
via
Groundboom
Equipment
(
4)
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,

and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,

Soybeans,
Wheat,
and
Triticale
0.05
lb
ai/
acre
200
acres
0.74
0.148
0.043
26000
130000
440000
Leafy
Brassica
Greens,
Head
and
Stem
Brassica
Vegetables,
Bulb
Vegetables,
Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),

Succulent
Edible
Podded
Peas,
Succulent
Edible
Podded
Beans,
Head
Lettuce,
Grain
Sorghum
and
Millet,

Sugarbeet,
Sugarcane
0.05
lb
ai/
acre
80
acres
0.74
0.148
0.043
64000
320000
1100000
Applying
Sprays
via
Airblast
Equipment
(
5)
Pecans
0.05
lb
ai/
acre
40
acres
4.5
0.9
0.45
21000
110000
210000
Applying
Dusts
via
Mechanical
Duster
(
6)
Livestock
(
beef
&
dairy
cattle,
sheep,
goats,
horses)
0.00094
lb
ai/
animal
1000
animals
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
Applying
Dusts
via
Dust
Bag
(
7)
Livestock
(
beef
&
dairy
cattle,
sheep,
goats,
horses)
0.00094
lb
ai/
animal
1000
animals
No
Data
No
Data
No
Data
No
Data
No
Data
No
Data
Flagger
Flagging
for
Aerial
Alfalfa,
Alfalfa
grown
for
seed,
Corn,
sweet,
field,
pop,
0.05
350
0.35
0.07
0.007
31000
150000
1,500,000
Appendix
A
Table
A3:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Zeta­
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
µ
g/
lb
ai)
80%

PPE­
R
Inhalation
Unit
Exposured
(
µ
g/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
µ
g/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
84
Spray
Applications
(
8)
and
field
grown
for
seed;
Cotton
(
foliar
use),
Rice,

Soybeans,
Wheat,
Triticale,
Leafy
Brassica
Greens,

Head
and
Stem
Brassica
Vegetables,
Bulb
Vegetables,

Fruiting
Vegetables
(
except
cucurbits),
Leafy
Vegetables
(
except
Brassica),
Succulent
Edible
Podded
Peas,
Succulent
Edible
Podded
Beans,
Head
Lettuce,

Pecans,
Grain
Sorghum
and
Millet,
Sugarbeet,

Sugarcane
lb
ai/
acre
acres
Mixer/
Loader/
Applicator
Mixing/
Loading/

Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
PHED)

(
9)
Indoor
surfaces
and
Outdoor
surfaces
(
outdoor
rate
supplied
by
Registrant)
0.0044
lb
ai/
gallon
40
gallons
30
6
Not
Feasible
36000
180000
Not
Feasible
Residential
Lawns
and
Turfgrass
at
Commercial
Sites
(
Rate
supplied
by
Registrant)
0.3
lb
ai/
acre
2
acres
30
6
Not
Feasible
11000
53000
Not
Feasible
Outdoor
surfaces
(
rate
from
label)
0.001
lb
ai/
gallon
40
gallons
30
6
Not
Feasible
160000
790000
Not
Feasible
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)

(
10)
residential
lawns
(
Rate
supplied
by
Registrant)
0.3
lb
ai/
acre
5
acres
1.5
0.3
Not
Feasible
84000
420000
Not
Feasible
outdoor
surfaces,
surfaces
of
buildings,
porches,

screens,
window
frames,
eaves,
patios,
lawn
area
adjacent
to
or
around
private
homes,
duplexes,

townhouses,
condominiums,
house
trailers
apartment
complexes,
carports,
garages,
fence
lines,
storage
sheds,

barns,
and
other
residential
structures
plus
commercial,

industrial,
institutional
buildings,
vegetation,
refuse
dumps,
garages,
and
other
outdoor
surfaces
(
label)
0.4356
lb
ai/
acre
5
acres
1.5
0.3
Not
Feasible
58000
290000
Not
Feasible
Applying
Dusts
via
Shaker
Can
(
MRID
444598­
01)
(
11)
Livestock
(
beef
&
dairy
cattle,
sheep,
goats,
horses)
0.00094
lb
ai
/
animal
100
animals
870
174
Not
Feasible
2300
No
Data
Not
Feasible
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Watering
Can
(
using
ORETF
residential
outdoor
surfaces
(
ant
mounds)
0.006
lb
ai/
mound
40
mound
s
16
3.2
Not
Feasible
49000
No
Data
Not
Feasible
Appendix
A
Table
A3:
Margins
of
Exposure
For
Short­
and
Intermediate­
term
Zeta­
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
µ
g/
lb
ai)
80%

PPE­
R
Inhalation
Unit
Exposured
(
µ
g/
lb
ai)
Eng
Con
Inhalation
Unit
Exposuree
(
µ
g/
lb
ai)
Baseline
Inhalation
MOEf
80%

PPE­
R
Inhalation
MOEg
Eng
Cont
Inhalation
MOEh
85
hose­
end
data)
(
12)

Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Paint
Brush
(
13)
outdoor
surfaces
(
general)
(
rate
from
label)
0.001
lb
ai/
gallon
5
gallons
280
56
Not
Feasible
140000
680000
Not
Feasible
Applying
Ready
to
Use
Ear­
Tags
(
14)
livestock
(
cattle)
0.004
lb
ai/
2
ear
tags/
cattle
400
cattle
No
Data
No
Data
Not
Feasible
No
Data
No
Data
Not
Feasible
livestock
(
cattle)
0.003
lb
ai/
1
ear
tag/
cattle
400
cattle
No
Data
No
Data
Not
Feasible
No
Data
No
Data
Not
Feasible
Loading
Dusts
into
Self­
Applying
Dust
Bags
(
using
PHED
mixing/
loading
wettable
powders
data)
(
15)
Livestock
(
beef
&
dairy
cattle,
sheep,
goats,
horses)
0.00094
lb
ai/
animal
1000
animals
43
8.6
Not
Feasible
4700
23000
Not
Feasible
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
cypermethrin.

b
Amount
handled
per
day
values
are
EPA
estimates
of
acreage
treated
or
gallons
applied
based
on
Exposure
SAC
Policy
#
9
"
Standard
Values
for
Daily
Acres
Treated
in
Agriculture".

c
Baseline
inhalation
unit
exposure
values
from
PHED
Surrogate
Exposure
Guide
and
represent
no
respiratory
protection.

d
80%
PPE­
R
inhalation
unit
exposure
values
from
PHED
Surrogate
Exposure
Guide
and
represent
use
of
a
dust
mist
respirator
(
80
percent
protection
factor
over
baseline).

e
Eng
Controls
Inhalation:
Closed
mixing/
loading
system,
enclosed
cab,
or
enclosed
cockpit.

f
Baseline
inhalation
MOE
=
short­
and
intermediate­
term
NOAEL
(
2.7
mg/
kg/
day)
/
baseline
inhalation
dose
(
mg/
kg/
day),
where
baseline
inhalation
dose
=
baseline
inhalation
unit
exposure
(
µ
g/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
1mg
/
1000
µ
g)
/
body
weight
(
70
kg).

g
80%
PPE­
R
inhalation
MOE
=
short­
and
intermediate­
term
NOAEL
(
2.7
mg/
kg/
day)
/
80
percent
PPE­
R
inhalation
dose
(
mg/
kg/
day),
where
80
percent
PPE­
R
inhalation
dose
=
80
percent
PPE­
R
inhalation
unit
exposure
(
µ
g/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
1mg
/
1000
µ
g)
/
body
weight
(
70
kg).

h
Engineering
Control
inhalation
MOE
=
short­
and
intermediate­
term
NOAEL
(
2.7
mg/
kg/
day)
/
engineering
control
inhalation
dose
(
mg/
kg/
day)
where
engineering
control
inhalation
dose
=
engineering
control
inhalation
unit
exposure
(
µ
g/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
1mg
/
1000
µ
g)
/
body
weight
(
70
kg).
86
Appendix
A/
Table
A4:
Sources
of
Exposure
Data
Used
in
the
Long­
Term
Occupational
Cypermethrin
and
Zeta­
Cypermethrin
Handler
Exposure
and
Risk
Calculations
Exposure
Scenario
(
Number)
Data
Source
Standard
Assumptions
(
8­
hr
work
day)
Comments
Mixing/
Loading/
Applying
Descriptors
Mixing/
Loading/
Applying
Liquid
concentrates
with
Low
Pressure
Handwand
(
Cypermethrin
and
Zeta­
Cypermethrin:
1)
PHED
V1.1
(
August
1998)
40
gallons
or
2
acres
Baseline:
Hands
=
all
grades;
dermal
and
inhalation
=
ABC
grades.
Dermal
=
9
to
80
replicates;
hands
=
70
replicates;

and
inhalation
=
80
replicates.
Medium
confidence
in
inhalation
data.
Low
confidence
in
dermal
and
hand
data.
No
protection
factor
was
needed
to
define
the
unit
exposure
values.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hand
=
10
replicates.
Hands=
ABC
grades
Low
confidence
in
hand
data.
Respiratory
protection
not
required
for
this
assessment.

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Mixing/
Loading/
Applying
Liquid
concentrates
with
a
Paint
Brush
(
Cypermethrin:
2;

Zetacypermethrin
4)
PHED
V1.1
(
August
1998)
5
gallons
Baseline:
Hands
=
AB
grades.
Dermal
and
inhalation
=
C
grades.
Low
confidence
in
dermal
and
hand
data.
Hand
=

15
replicates.
Dermal
=
14
to
15
replicates
and
inhalation
=
15
replicates.
Medium
confidence
in
inhalation
data.

PPE:
Dermal
=
C
grades.
Low
confidence
in
dermal
data.
The
same
hand
data
are
used
as
for
baseline
coupled
with
a
90%
protection
factor
to
account
for
a
gloves.
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%

protection
factor
to
account
for
an
additional
layer
of
clothing.
Respiratory
protection
not
required
for
this
assessment.

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Mixing/
Loading/
Applying
Liquid
concentrates
with
a
Handgun
Sprayer
(
ORETF
data)

(
Cypermethrin:
3;

Zetacypermethrin
2)
ORETF
Study
(
October
22,
2000)

OMA
002
5
acres
for
turf
Baseline:
Dermal
data
=
B
grade
and
15
replicates.
The
only
empirical
data
available
are
based
on
the
use
of
chemical­
resistant
gloves.
It
is
generally
not
appropriate
to
back­
calculate
a
non­
glove
hand
exposure
levels,
an
extrapolation
has
been
completed
for
this
scenario
(
90
percent
protection
factor
),
however,
because
the
empirical
data
indicate
that
hands
are
a
minor
contributor
to
overall
exposure
levels.
Inhalation
=
B
grade
and
15
replicates.
Moderate
to
high
confidence
in
inhalation
data.

PPE:.
Dermal
data
=
15
replicates
and
high
confidence,
grade
B.
A
50
percent
protection
factor
was
added
to
account
for
the
use
of
an
additional
layer
of
clothing.
Gloved
hand
=
60
replicates.
Respiratory
protection
not
required
for
this
assessment.
Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Mixing/
Loading/
Applying
Liquid
concentrates
with
a
Watering
Can
(
Zeta­
cypermethrin:
3)
ORETF
Chemical
Handler
Exposure
Studies
40
ant
mounds
Baseline:
The
only
empirical
data
that
are
available
are
based
on
the
use
of
no
protective
clothing.
Dermal
and
inhalation
=
60
replicates.

Mixing/
Loading/
Applying
Wettable
Powders
with
Low
Pressure
Handwand
(
Cypermethrin:
5)
PHED
V1.1
(
August
1998)
40
gallons
Baseline:
Glove
data
was
utilized
to
calculate
no
glove
data
for
hand
scenarios.
Dermal
and
inhalation
=
ABC
grades.
Dermal
=
16
replicates
and
inhalation
=
16
replicates.
Medium
confidence
in
inhalation
data.
Low
confidence
in
dermal
data.

PPE:
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%
protection
factor
to
account
for
an
additional
layer
of
clothing.
Hand
=
15
replicates.
Hands=
AB
grades.
Medium
confidence
in
hand
data.
Respiratory
protection
not
required
for
this
assessment.

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.
Appendix
A/
Table
A4:
Sources
of
Exposure
Data
Used
in
the
Long­
Term
Occupational
Cypermethrin
and
Zeta­
Cypermethrin
Handler
Exposure
and
Risk
Calculations
Exposure
Scenario
(
Number)
Data
Source
Standard
Assumptions
(
8­
hr
work
day)
Comments
87
Applying
Wettable
Powders
with
a
Paint
Brush
(
Cypermethrin:
6)
PHED
V1.1
(
August
1998)
5
gallons
Baseline:
Hands
=
AB
grades.
Dermal
and
inhalation
=
C
grades.
Low
confidence
in
dermal
and
hand
data.
Hand
=

15
replicates.
Dermal
=
14
to
15
replicates
and
inhalation
=
15
replicates.
Medium
confidence
in
inhalation
data.

PPE:
Dermal
=
C
grades.
Low
confidence
in
dermal
data.
The
same
hand
data
are
used
as
for
baseline
coupled
with
a
90%
protection
factor
to
account
for
a
gloves.
The
same
dermal
data
are
used
as
for
baseline
coupled
with
a
50%

protection
factor
to
account
for
an
additional
layer
of
clothing.
Respiratory
protection
not
required
for
this
assessment.

Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Mixing/
Loading/
Applying
Wettable
Powders
with
a
Handgun
Sprayer
(
ORETF
data)

(
Cypermethrin:
7)
ORETF
Study
(
October
22,
2000)

OMA
002
5
acres
for
turf
and
500
gallons
for
turf
and
soil
Baseline:
Dermal
data
=
B
grade
and
15
replicates.
The
only
empirical
data
available
are
based
on
the
use
of
chemical­
resistant
gloves.
It
is
generally
not
appropriate
to
back­
calculate
a
non­
glove
hand
exposure
levels,
an
extrapolation
has
been
completed
for
this
scenario
(
90
percent
protection
factor
),
however,
because
the
empirical
data
indicate
that
hands
are
a
minor
contributor
to
overall
exposure
levels.
Inhalation
=
B
grade
and
15
replicates.
Moderate
to
high
confidence
in
inhalation
data.

PPE:.
Dermal
data
=
15
replicates
and
high
confidence,
grade
B.
A
50
percent
protection
factor
was
added
to
account
for
the
use
of
an
additional
layer
of
clothing.
Gloved
hand
=
60
replicates.
Respiratory
protection
not
required
for
this
assessment.
Engineering
Controls:
Not
considered
feasible
for
this
exposure
scenario.

Mixing/
Loading/
Applying
Water
soluble
Bags
with
a
Handgun
Sprayer
(
ORETF
data)

(
Cypermethrin:
8)
ORETF
Study
(
October
22,
2000)

OMA
002
5
acres
for
turf
and
500
gallons
for
turf
and
soil
Baseline:
No
dermal
data
for
this
scenario.
Non­
glove
hand
exposure
levels,
were
back­
calculated
for
this
scenario
(
90
percent
protection
factor
),
however,
because
the
empirical
data
indicate
that
hands
are
a
minor
contributor
to
overall
exposure
levels.
Inhalation
=
B
grade
and
15
replicates.
Moderate
to
high
confidence
in
inhalation
data.

PPE:
Dermal
(
15
replicates)
and
inhalation
(
15
replicates)
data
of
high
confidence,
grade
B
or
better,
were
used
to
establish
exposure
values
for
each
of
the
scenarios.
Gloved
hand
(
60
replicates)
data
were
used
to
establish
an
exposure
value.
An
80
percent
protection
factor
was
applied
to
inhalation
data
to
account
for
the
use
of
a
dust/
mist
respirator.

Engineering
Controls:
Water
soluble
bags
are
considered
an
engineering
control
for
wettable
powder
formulations.

Data
for
mixing/
loading/
applicator
exposure
based
on
commercial
systems
with
some
exposure
controls
during
mixing/
loading.
No
fully
closed
system
available
for
this
scenario.

C
All
Standard
Assumptions
are
based
on
an
8­
hour
work
day
as
estimated
by
the
Agency.

C
All
handler
exposure
assessments
in
this
document
are
based
on
the
"
Best
Available"
data
as
defined
by
the
HED
SOP
for
meeting
Subdivision
U
Guidelines
(
i.
e.,
completing
exposure
assessments).
Best
available
grades
are
assigned
to
data
as
follows:
matrices
with
A
and
B
grade
data
(
i.
e.,
Acceptable
Grade
Data)
and
a
minimum
of
15
replicates;
if
not
available,
then
grades
A,
B
and
C
data
and
a
minimum
of
15
replicates;
if
not
available,
then
all
data
regardless
of
the
quality
(
i.
e.,
All
Grade
Data)
and
number
of
replicates.
High
quality
data
with
a
protection
factor
take
precedence
over
low
quality
data
with
no
protection
factor.
Generic
data
confidence
categories
are
assigned
as
follows:

High
=
grades
A
and
B
and
15
or
more
replicates
per
body
part
Medium
=
grades
A,
B,
and
C
and
15
or
more
replicates
per
body
part
Low
=
grades
A,
B,
C,
D
and
E
or
any
combination
of
grades
with
less
than
15
replicates.

C
PHED
grading
criteria
do
not
reflect
overall
quality
of
the
reliability
of
the
assessment.
Sources
of
the
exposure
factors
should
also
be
considered
in
the
risk
management
decision.
88
Appendix
A/
Table
A5:
Margins
of
Exposure
For
Long­
Term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Dermal
Unit
Exposurec
(
mg/
lb
ai)
Baseline
Inhalation
Unit
Exposured
(
ug/
lb
ai)
PPE­
G
Dermal
Unit
Exposuree
(
mg/
lb
ai)
Baseline
Dermal
MOEf
Baseline
Inhalation
MOEg
Long­

Term
Baseline
Dermal
+

Long­

Term
Baseline
Inhalation
MOEh
PPE­
G
Dermal
MOEi
Long­
Term
PPE­
G
Dermal
+

Long­
Term
Baseline
Inhalation
MOEj
Mixer/
Loader/
Applicator
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Low
Pressure
Handwand
(
1)
residential,

commercial
and
industrial
lawns
foliar
0.44
lb
ai/
acre
5
acres
100
30
0.43
76
2,900
0.71
18,000
9.1
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,
and
standing
wood
in
uninhabited
areas
at
residential,

commercial
and
industrial
sites
Termites:

building
perimeter,

masonry
voids,
standing
wood
0.05
lb
ai/
gal
40
gallons
100
30
0.43
84
3,200
0.78
20,000
10
Termites:
preconstruction
lumber
and
logs,
soil
under
firewood
Termites:
preconstructi
on
lumber
and
logs,
soil
under
firewood
0.041
lb
ai/
gal
40
gallons
100
30
0.43
100
3,800
0.95
24,000
12
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,

commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
Non­
Termites:

indoor
&

outdoor
surfaces,

building
perimeters
0.017
lb
ai/
gallon
40
gallons
100
30
0.43
250
9,300
2.3
57,000
29
Appendix
A/
Table
A5:
Margins
of
Exposure
For
Long­
Term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Dermal
Unit
Exposurec
(
mg/
lb
ai)
Baseline
Inhalation
Unit
Exposured
(
ug/
lb
ai)
PPE­
G
Dermal
Unit
Exposuree
(
mg/
lb
ai)
Baseline
Dermal
MOEf
Baseline
Inhalation
MOEg
Long­

Term
Baseline
Dermal
+

Long­

Term
Baseline
Inhalation
MOEh
PPE­
G
Dermal
MOEi
Long­
Term
PPE­
G
Dermal
+

Long­
Term
Baseline
Inhalation
MOEj
89
ornamental
plants;

termite
applications
to
standing
wood
in
uninhabited
areas
at
residential,

commercial
and
industrial
sites
foliar
0.008
lb
ai/
gallon
40
gallons
100
30
0.43
530
20,000
4.9
120,000
62
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Paintbrush
(
2)
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,
and
standing
wood
in
uninhabited
areas
at
residential,

commercial
and
industrial
sites
standing
wood
(
termites)
0.05
lb
ai/
gal
5
gallons
180
280
24
370
2,700
2.6
2,800
6.8
Termites:
preconstruction
lumber
and
logs,
soil
under
firewood
lumber
and
logs
0.041
lb
ai/
gal
5
gallons
180
280
24
460
3,300
3.2
3,400
8.3
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,

commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
outdoor
surfaces
0.017
lb
ai/
gallon
5
gallons
180
280
24
1,100
7,900
7.8
8,200
20
Appendix
A/
Table
A5:
Margins
of
Exposure
For
Long­
Term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Dermal
Unit
Exposurec
(
mg/
lb
ai)
Baseline
Inhalation
Unit
Exposured
(
ug/
lb
ai)
PPE­
G
Dermal
Unit
Exposuree
(
mg/
lb
ai)
Baseline
Dermal
MOEf
Baseline
Inhalation
MOEg
Long­

Term
Baseline
Dermal
+

Long­

Term
Baseline
Inhalation
MOEh
PPE­
G
Dermal
MOEi
Long­
Term
PPE­
G
Dermal
+

Long­
Term
Baseline
Inhalation
MOEj
90
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Handheld
Handgun
(
ORETF)
(
3)
agricultural
uncultivated
areas;

fencerows,
hedgerows;

ornamental
plants;

potting
soil,
topsoil
foliar
3.4
lb
ai/
acre
5
acres
no
data
1.8
0.45
no
data
6,200
no
baseline
dermal
data
2,200
11
residential,

commercial
and
industrial
lawns
foliar
0.44
lb
ai/
acre
5
acres
no
data
1.8
0.45
no
data
48,000
no
baseline
dermal
data
17,000
82
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Termiticide
Injector
(
4)
Termites:
trees,
utility
poles,
fenceposts,

building
voids
Termites:

trees,
utility
poles,
fenceposts,

building
voids
0.05
lb
ai/
gallon
500
gallons
no
data
2.2
0.36
no
data
3,400
no
baseline
dermal
data
1,900
7.1
Mixing/
Loading/

Applying
Wettable
Powders
with
a
Low
Pressure
Handwand
(
5)
residential,

commercial
and
industrial
lawns
foliar
0.6
lb
ai/
acre
5
acres
no
data
1100
8.6
no
data
57
no
baseline
dermal
data
650
0.19
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,
and
standing
wood
in
uninhabited
areas
at
residential,
commercial
and
industrial
sites
0.05
lb
ai/
gallon
40
gallons
no
data
1100
8.6
no
data
86
no
baseline
dermal
data
980
0.28
fire
ant
mounds
mounds
0.033
lb
ai/
gallon
40
gallons
no
data
1100
8.6
no
data
130
no
baseline
dermal
data
1,500
0.42
Appendix
A/
Table
A5:
Margins
of
Exposure
For
Long­
Term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Dermal
Unit
Exposurec
(
mg/
lb
ai)
Baseline
Inhalation
Unit
Exposured
(
ug/
lb
ai)
PPE­
G
Dermal
Unit
Exposuree
(
mg/
lb
ai)
Baseline
Dermal
MOEf
Baseline
Inhalation
MOEg
Long­

Term
Baseline
Dermal
+

Long­

Term
Baseline
Inhalation
MOEh
PPE­
G
Dermal
MOEi
Long­
Term
PPE­
G
Dermal
+

Long­
Term
Baseline
Inhalation
MOEj
91
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,

commercial
and
industrial
sites,
animal
premises,
and
greenhouses;

applications
to
horses
Non­
Termites:

indoor
surfaces,

outdoor
surfaces,

building
perimeters
0.017
lb
ai/
gallon
40
gallons
no
data
1100
8.6
no
data
250
no
baseline
dermal
data
2,900
0.82
ornamental
plants;

termite
applications
to
standing
wood
in
uninhabited
areas
at
residential,

commercial
and
industrial
sites
foliar
0.008
lb
ai/
gallon
40
gallons
no
data
1100
8.6
no
data
540
no
baseline
dermal
data
6,100
1.7
Mixing/
Loading/

Applying
Wettable
Powders
with
a
Paintbrush
(
6)
Termites
applications
to
soil
and
sides
of
buildings
near
to
ground,
building
perimeters,
masonry
voids,
and
standing
wood
in
uninhabited
areas
at
residential,

commercial
and
industrial
sites
standing
wood
(
termites)
0.05
lb
ai/
gal
5
gallons
180
280
24
370
2,700
2.6
2,800
6.8
Termites:
preconstruction
lumber
and
logs,
soil
under
firewood
lumber
and
logs
0.041
lb
ai/
gal
5
gallons
180
280
24
460
3,300
3.2
3,400
8.3
Appendix
A/
Table
A5:
Margins
of
Exposure
For
Long­
Term
Cypermethrin
Occupational
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Dermal
Unit
Exposurec
(
mg/
lb
ai)
Baseline
Inhalation
Unit
Exposured
(
ug/
lb
ai)
PPE­
G
Dermal
Unit
Exposuree
(
mg/
lb
ai)
Baseline
Dermal
MOEf
Baseline
Inhalation
MOEg
Long­

Term
Baseline
Dermal
+

Long­

Term
Baseline
Inhalation
MOEh
PPE­
G
Dermal
MOEi
Long­
Term
PPE­
G
Dermal
+

Long­
Term
Baseline
Inhalation
MOEj
92
Non­
termite
applications
to
indoor
and
outdoor
surfaces
at
residential,

commercial
and
industrial
sites,
animal
premises,
and
greenhouses;
outdoor
surfaces
0.017
lb
ai/
gallon
5
gallons
180
280
24
1,100
7,900
7.8
8,200
20
Mixing/
Loading/

Applying
Wettable
Powders
with
a
Handheld
Handgun
(
ORETF)
(
7)
agricultural
uncultivated
areas;

fencerows,
hedgerows;

ornamental
plants;

potting
soil,
topsoil
foliar
3.4
lb
ai/
acre
5
acres
no
data
64
0.8
no
data
170
no
baseline
dermal
data
1,200
0.55
residential,

commercial
and
industrial
lawns
foliar
0.6
lb
ai/
acre
5
acres
no
data
64
0.8
no
data
980
no
baseline
dermal
data
7,000
3.1
Mixing/
Loading/

Applying
WSB
Formulations
with
a
Handheld
Handgun
(
ORETF)
(
8)
agricultural
uncultivated
areas;

fencerows,
hedgerows;

ornamental
plants;

potting
soil,
topsoil
foliar
3.4
lb
ai/
acre
5
acres
no
data
7.2
0.64
no
data
1,500
no
baseline
dermal
data
1,500
3.9
residential,

commercial
and
industrial
lawns
foliar
0.6
lb
ai/
acre
5
acres
no
data
7.2
0.64
no
data
8,800
no
baseline
dermal
data
8,800
22
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
Cypermethrin.

b
Amount
handled
per
day
values
are
EPA
estimates
of
acreage
treated
or
gallons
applied
based
on
Exposure
SAC
Policy
#
9
"
Standard
Values
for
Daily
Acres
Treated
in
Agriculture".

c
Baseline
dermal
unit
exposure
values
from
PHED
Surrogate
Exposure
Guide
unless
otherwise
noted
and
represent
baseline
clothing
attire
of
long
sleeve
shirt
and
long
pants.

d
Baseline
inhalation
unit
exposure
values
from
PHED
Surrogate
Exposure
Guide
unless
otherwise
noted
and
no
respiratory
protection.
93
e
PPE­
G
dermal
unit
exposure
values
from
PHED
Surrogate
Exposure
Guide
unless
otherwise
noted
and
represent
baseline
clothing
attire
and
use
of
chemical
resistant
gloves.:

f
Baseline
chronic
dermal
MOE
=
chronic
NOAEL
(
6
mg/
kg/
day)
/
baseline
absorbed
dermal
dose
(
mg/
kg/
day),
where
baseline
absorbed
dermal
dose
=
baseline
dermal
unit
exposure
(
mg/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
dermal
absorption
factor
(
0.025)
/
body
weight
(
70
kg).

g
Baseline
chronic
inhalation
MOE
=
chronic
NOAEL
(
2.7
mg/
kg/
day)
/
baseline
inhalation
dose
(
mg/
kg/
day),
where
baseline
inhalation
dose
=
baseline
inhalation
unit
exposure
(
µ
g/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
1mg
/
1000
µ
g
/
body
weight
(
70
kg).

h
Combined
chronic
baseline
dermal
and
chronic
baseline
inhalation
MOE
=
1
/[
(
1/
chronic
baseline
dermal
MOE)
+
(
1/
chronic
baseline
inhalation
MOE)].
Target
MOE
is
100.

i
PPE­
G
chronic
dermal
MOE
=
chronic
NOAEL
(
6
mg/
kg/
day)
/
PPE­
G
absorbed
dermal
dose
(
mg/
kg/
day),
where
PPE­
G
absorbed
dermal
dose
=
PPE­
G
dermal
unit
exposure
(
mg/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
dermal
absorption
factor
(
0.025)
/
body
weight
(
70
kg).

j
Combined
long­
term
dermal
with
gloves
plus
long­
term
baseline
inhalation
MOE
=
1
/[
(
1/
long­
term
dermal
with
PPE­
gloves
MOE/
UF100
+
(
1/
long­
term
baseline
inhalation­
baseline
MOE/
UF300)]
Target
MOE
is
100.
94
Appendix
A/
Table
A6:
Margins
of
Exposure
For
Long­
Term
Zeta­
Cypermethrin
Occupational
Handler
Dermal
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Unit
Exposures
(
mg/
lb
ai)
MOEg
Baselinec
PPE­
Single
layer
w/
glovesd
PPE
­
Double
layer
w/
glovese
Eng
Controlf
Baseline
PPESingle
layer
w/
gloves
PPE
­
Double
layer
w/
gloves
Eng
Control
Mixer/
Loader/
Applicator
Mixing/
Loading/

Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
PHED)
Indoor
surfaces
and
Outdoor
surfaces
(
outdoor
rate
supplied
by
Registrant)
0.0044
lb
ai/
gallon
40
gallons
100
0.43
0.37
Not
Feasible
950
220000
260000
Not
Feasibl
e
Residential
Lawns
and
Turfgrass
at
Commercial
Sites
(
Rate
supplied
by
Registrant)
0.3
lb
ai/
acre
2
acres
100
0.43
0.37
Not
Feasible
280
65000
76000
Not
Feasibl
e
Outdoor
surfaces
(
rate
from
label)
0.001
lb
ai/
gallon
40
gallons
100
0.43
0.37
Not
Feasible
4200
980000
1100000
Not
Feasibl
e
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
residential
lawns
0.3
lb
ai/
acre
5
acres
0.69
0.48
0.25
Not
Feasible
16000
23000
45000
Not
Feasibl
e
outdoor
surfaces,
surfaces
of
buildings,
porches,
screens,

window
frames,
eaves,
patios,
lawn
area
adjacent
to
or
around
private
homes,
duplexes,
townhouses,

condominiums,
house
trailers
apartment
complexes,
carports,

garages,
fence
lines,
storage
sheds,

barns,
and
other
residential
structures
plus
commercial,

industrial,
institutional
buildings,

vegetation,
refuse
dumps,
garages,

and
other
outdoor
surfaces
0.4356
lb
ai/
acre
5
acres
0.69
0.48
0.25
Not
Feasible
11000
16000
31000
Not
Feasibl
e
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Watering
Can
(
using
ORETF
residential
hoseend
data)
outdoor
surfaces
(
ant
mounds)
0.006
lb
ai/
mound
40
mounds
11
No
Data
No
Data
Not
Feasible
6400
No
Data
No
Data
Not
Feasibl
e
Mixing/
Loading/
outdoor
surfaces
(
general)
(
rate
0.001
5
180
24
22
Not
19000
140000
150000
Not
Appendix
A/
Table
A6:
Margins
of
Exposure
For
Long­
Term
Zeta­
Cypermethrin
Occupational
Handler
Dermal
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Unit
Exposures
(
mg/
lb
ai)
MOEg
Baselinec
PPE­
Single
layer
w/
glovesd
PPE
­
Double
layer
w/
glovese
Eng
Controlf
Baseline
PPESingle
layer
w/
gloves
PPE
­
Double
layer
w/
gloves
Eng
Control
95
Applying
Liquid
Concentrates
with
a
Paint
Brush
from
label)
lb
ai/
gallon
gallons
Feasible
Feasibl
e
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
endothall.

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
attire
is
long­
sleeve
shirt,
long
pants,
and
no
gloves
and
no
respirator.

d
PPE­
single
layer
plus
gloves
is
baseline
attire
plus
chemical­
resistant
gloves.

e
PPE­
double
layer
plus
gloves
is
coveralls
worn
over
long­
sleeve
shirt
and
long
pants,
plus
chemical­
resistant
gloves.

f
Engineering
Controls
is
closed
mixing/
loading
system,
enclosed
cab,
or
enclosed
cockpit.

g
Dermal
MOE
=
NOAEL
(
6.0
mg/
kg/
day)
/
dermal
daily
dose
(
mg/
kg/
day),
where
dermal
dose
=
daily
unit
exposure
(
mg/
lb
ai)
x
application
rate
x
amount
handled
per
day
/
body
weight
(
70
kg
adult).
96
Appendix
A/
Table
A7:
Margins
of
Exposure
For
Long­
Term
Zeta­
Cypermethrin
Occupational
Handler
Inhalation
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Unit
Exposures
(
µ
g/
lb
ai)
MOEsf
Baselinec
80%

PPE­
Rd
Eng
Cone
Baseline
80%

PPE­
R
Eng
Cont
Mixer/
Loader/
Applicator
Mixing/
Loading/

Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
PHED)
Indoor
surfaces
and
Outdoor
surfaces
(
outdoor
rate
supplied
by
Registrant)
0.0044
lb
ai/
gallon
40
gallons
30
6
Not
Feasible
36000
180000
Not
Feasible
Residential
Lawns
and
Turfgrass
at
Commercial
Sites
(
Rate
supplied
by
Registrant)
0.3
lb
ai/
acre
2
acres
30
6
Not
Feasible
11000
53000
Not
Feasible
Outdoor
surfaces
(
rate
from
label)
0.001
lb
ai/
gallon
40
gallons
30
6
Not
Feasible
160000
790000
Not
Feasible
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
residential
lawns
0.3
lb
ai/
acre
5
acres
1.5
0.3
Not
Feasible
84000
420000
Not
Feasible
outdoor
surfaces,
surfaces
of
buildings,
porches,
screens,

window
frames,
eaves,
patios,

lawn
area
adjacent
to
or
around
private
homes,
duplexes,

townhouses,
condominiums,

house
trailers
apartment
complexes,
carports,
garages,

fence
lines,
storage
sheds,
barns,

and
other
residential
structures
plus
commercial,
industrial,

institutional
buildings,

vegetation,
refuse
dumps,

garages,
and
other
outdoor
surfaces
0.4356
lb
ai/
acre
5
acres
1.5
0.3
Not
Feasible
58000
290000
Not
Feasible
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Watering
Can
(
using
ORETF
residential
hose­
end
data)
outdoor
surfaces
(
ant
mounds)
0.006
lb
ai/
mound
40
mounds
16
3.2
Not
Feasible
49000
250000
Not
Feasible
Appendix
A/
Table
A7:
Margins
of
Exposure
For
Long­
Term
Zeta­
Cypermethrin
Occupational
Handler
Inhalation
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Ratea
Area
Treated
Dailyb
Unit
Exposures
(
µ
g/
lb
ai)
MOEsf
Baselinec
80%

PPE­
Rd
Eng
Cone
Baseline
80%

PPE­
R
Eng
Cont
97
Mixing/
Loading/

Applying
Liquid
Concentrates
with
a
Paint
Brush
outdoor
surfaces
(
general)
(
rate
from
label)
0.001
lb
ai/
gallon
5
gallons
280
56
Not
Feasible
140000
680000
Not
Feasible
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
endothall.

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
attire
is
long­
sleeve
shirt,
long
pants,
and
no
gloves
and
no
respirator.

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

e
Engineering
Controls
is
closed
mixing/
loading
system,
enclosed
cab,
or
enclosed
cockpit.

f
Inhalation
MOE
=
NOAEL
(
2.7mg/
kg/
day)
/
inhalation
daily
dose
(
mg/
kg/
day),
where
inhalation
dose
=
daily
unit
exposure
(
µ
g/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
conversion
factor
(
1mg/
1,000
µ
g
/
body
weight
(
70
kg
adult
female).
98
Appendix
A/
Table
A8:
Sources
of
Exposure
Data
Used
In
The
Residential
Cypermethrin
Handler
Exposure
And
Risk
Calculations
Exposure
Scenario
(
Number)
Data
Source
Standard
Assumptions
a
Commentsb
Mixer/
Loader/
Applicator
Descriptors
Mixing/
Loading/
Applying
Liquid
concentrates
with
Low
Pressure
Handwand
(
1)
SOPs
for
Residential
Exposure
Assessments
(
12/
97)
5
gallons
for
outdoor
applications,
0.5
gallons
for
indoor
applications
Baseline:
Hands
=
all
grades;
dermal
and
inhalation
=
ABC
grades.
Dermal
=
9
to
80
replicates;
hands
=
70
replicates;
and
inhalation
=
80
replicates.
Medium
confidence
in
inhalation
data.
Low
confidence
in
dermal
and
hand
data.
No
protection
factor
was
needed
to
define
the
unit
exposure
values.

Mixing/
Loading/
Applying
Liquid
concentrates
with
Wipes
(
2)
No
Data
No
Data
No
Data
Applying
Ready
to
Use
Formulations
with
Trigger
Pump
Sprayer
(
using
PHED
aerosol
can
data)
(
3)
SOPs
for
Residential
Exposure
Assessments
(
12/
97)
1
gallon
PHED
exposure
data
for
aerosol
can
application
(
scenario
5)
was
used
as
a
surrogate
for
pump
sprayer
application.

Applying
Ready
to
Use
Formulations
with
Aerosol
Cans
(
4)
SOPs
for
Residential
Exposure
Assessments
(
12/
97)
1
(
16
ounce
can)
can
or
2
(
8
ounce)
cans
Baseline:
Hands
=
A
grades;
dermal
=
ABC
grades;
and
inhalation
=
ABC
grades.

Dermal
=
30
replicates;
hands
=
15
replicates;
and
inhalation
=
30
replicates.

Medium
confidence
in
dermal,
inhalation,
and
hand
data.
There
was
adequate
replicates
to
base
this
study
on
only
AB
grades
but
this
would
have
resulted
in
only
1
study
being
used
to
estimate
exposure.
No
protection
factor
was
needed
to
define
the
unit
exposure
values.

Applying
Ready
to
Use
Formulations
with
Ready­
to­
Use
Foggers
(
5)
(
using
PHED
aerosol
can
data)
SOPs
for
Residential
Exposure
Assessments
(
12/
97)
1
(
16
ounce
can)
can
or
2
(
8
ounce)
cans
Baseline:
Hands
=
A
grades;
dermal
=
ABC
grades;
and
inhalation
=
ABC
grades.

Dermal
=
30
replicates;
hands
=
15
replicates;
and
inhalation
=
30
replicates.

Medium
confidence
in
dermal,
inhalation,
and
hand
data.
There
was
adequate
replicates
to
base
this
study
on
only
AB
grades
but
this
would
have
resulted
in
only
1
study
being
used
to
estimate
exposure.
No
protection
factor
was
needed
to
define
the
unit
exposure
values.

Applying
Ready
to
Use
Formulations
with
Wipes
(
6)
No
Data
No
Data
No
Data
a
Standard
assumptions
based
on
Residential
SOPs
and
HED
estimates.

b
All
handler
exposure
assessments
in
this
document
are
based
on
the
"
Best
Available"
data
as
defined
by
the
PHED
SOP
for
meeting
Subdivision
U
Guidelines
(
i.
e.,
completing
exposure
assessments).
Best
available
grades
are
assigned
to
data
as
follows:
matrices
with
A
and
B
grade
data
(
i.
e.,
Acceptable
Grade
Data)
and
a
minimum
of
15
replicates;
if
not
available,
then
grades
A,

B
and
C
data
and
a
minimum
of
15
replicates;
if
not
available,
then
all
data
regardless
of
the
quality
(
i.
e.,
All
Grade
Data)
and
number
of
replicates.
Generic
data
confidence
categories
are
assigned
as
follows:

High
=
gradesA
and
B
and
15
or
more
replicates
per
body
part
Medium
=
grades
A,
B,
and
C
and
15
or
more
replicates
per
body
part
Low
=
grades
A,
B,
C,
D
and
E
or
any
combination
of
grades
with
less
than
15
replicates
c
PHED
grading
criteria
do
not
reflect
overall
quality
of
the
reliability
of
the
assessment.
Sources
of
the
exposure
factors
should
also
be
considered
in
the
risk
management
decision.
99
Appendix
A/
Table
A9:
Margins
of
Exposure
For
Cypermethrin
Residential
Handler
Risk
Assessment
Exposure
Scenario
Crop
or
Target
Application
Directed
At
Application
Ratea
(
lb
ai/
unit)
Amount
Handled
Dailyb
Baseline
Inhalation
Unit
Exposurec
(
ug/
lb
ai)
Baseline
Inhalation
MOEd
Mixer/
Loader/
Applicator
Mixing/
Loading/
Applyi
ng
Liquid
concentrates
with
Low
Pressure
Handwand
(
1)
animals:
horses
body
0.017
lbs
ai/
gallon
5
gallons
3.8
590,000
Mixing/
Loading/
Applyi
ng
Liquid
concentrates
with
Wipes
(
2)
animals:
horses
body
0.017
lbs
ai/
gallon
0.1
gallon
123
900,000
Applying
Ready
to
Use
Formulations
with
a
Pump
Sprayer
(
3)
animals:
horses
body
0.017
lbs
ai/
gallon
0.1
gallon
123
900,000
Applying
Ready
to
Use
Formulations
with
Aerosol
Cans
(
4)
animal
premises,

indoor
surfaces,

outdoor
surfaces
indoor
surfaces
0.005
lb
ai/
sixteen
ounce
can
1
sixteen­
ounce
can
2400
16,000
Applying
Ready
to
Use
Formulations
with
Foggers
(
5)
indoor
spaces
indoor
spaces
0.0014
lb
ai/
fogger
2
foggers
2400
28,000
Applying
Ready
to
Use
Formulations
with
Wipes
(
6)
horses
indoor
surfaces
0.00041
lb
ai/
animal
1
animals
0.067
6.9E+
09
Footnotes
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
cypermethrin.

b
Amount
handled
per
day
values
are
EPA
estimates
of
acreage
treated
or
gallons
applied
based
on
Residential
SOPs,
revised
2/
01.

c
Baseline
inhalation
unit
exposure
values
from
Residential
SOPs
and
represent
short
sleeve
shirt,
short
pants
clothing
attire.

d
Baseline
inhalation
MOE
=
NOAEL
(
2.7
mg/
kg/
day)
/
inhalation
daily
dose
(
mg/
kg/
day),
where
inhalation
dose
=
daily
unit
exposure
(
µ
g/
lb
ai)
x
application
rate
x
amount
handled
per
day
x
conversion
factor
(
1mg/
1,000
µ
g
/
body
weight
(
70
kg
adult).
100
Appendix
B:
Residential
Postapplication
Risk
Calculations
101
Appendix
B
Table
B1­
Oral
Exposure
from
Hand­
to­
Mouth
Activity
on
Cypermethrin
and
Zeta­
Cypermethrin
Treated
Indoor
Surfaces
Exposure
Scenario
Application
Rate
Deposition
(:
g
ai/
cm2)
Percent
Active
Ingredient
Dislodgeab
le
Exposure
Time
(
hours)
Surface
Area
(
cm2)
Hand
to
Mouth
(
events/

hr)
Extraction
by
Saliva
Adjustment
Factor
for
Spot
or
Crack
&

Crevice
Treatments
Body
Weight
(
kg)
Average
Daily
Dose
(
mg/
kg/

day)
Oral
MOE
(
UF=
1000)

Short­
term
Exposures
Cypermethrin
­­

Hand
to
Mouth
Transfer
from
Indoor
Surfaces
(
crack
&
crevice)
0.000017
(
lb
ai/
sq
ft)
not
applicable
5%
(
carpet)
4
20
20
50%
50%
15
0.011114
900
10%
(
hard
floor)
2
Cypermethrin
 

Hand
to
Mouth
(
fogger)
0.0014
(
lb
ai/
fogger)
2.7
5%
(
carpet)
4
20
20
50%
not
applicable
15
0.00720
1,400
10%
(
hard
floor)
2
Zeta­
Cypermethrin
­­

Hand
to
Mouth
Transfer
from
Indoor
Surfaces
(
crack
&
crevice)
0.000004
(
lb
ai/
sq
ft)
not
applicable
5%
(
carpet)
4
20
20
50%
50%
15
0.0029
3,500
10%
(
hard
floor)
2
Oral
Dose
(
mg/
kg/
day)
=
AR
(
lb
ai/
1000
sq
ft)
x
CF
x
F
x
SA
(
cm2)
x
EXT
x
FQ
(
events/
hr)
x
ET
(
hrs/
day)

BW
(
kg)

Where:

Dose
=
oral
dose
on
day
of
application
(
mg/
kg/
day)

AR
=
application
rate
(
lb
ai/
1000
sq
ft)

F
=
Fraction
of
residue
dislodgeable
from
wet
hands
CF
=
conversion
factor
to
convert
µ
g
to
mg
(
0.001)

SA
=
surface
area
of
1
to
3
fingers
(
cm2)

EXT
=
extraction
rate
by
saliva
(
unitless)

FQ
=
frequency
of
hand­
to­
mouth
events
(
events/
hour)

ET
=
exposure
duration
(
hours/
day)

BW
=
body
weight
(
kg)
102
Assumptions:

F
­
The
fraction
of
residue
dislodgeable
from
wet
hands
is
5%
for
carpets
and
10%
for
hard
flooring.

SA
­
The
surface
area
of
1
to
3
fingers
is
20
cm2
EXT
­
The
extraction
rate
by
saliva
is
50%

ET
­
The
exposure
duration
is
4
hours/
day
for
carpets
and
2
hours/
day
for
hard
flooring.

Fogger
Oral
Dose
(
mg/
kg/
day)
=
[
D
x
F
x
SA
x
FQ
x
ET)
x
EXT
x
0.001
mg/:
g]
/
BW
Where:

Dose
=
oral
dose
on
day
of
application
(
mg/
kg/
day)

D
=
deposition
(
µ
g/
cm2)
=
lb
ai/
fogger
(
0.0014
lb/
ft3)
x
4.5E+
08
µ
g/
lb
conversion
factor
x
0.001
mg/:
g
conversion
factor
/
room
area
(
256
ft2)

F
=
fraction
of
residue
dislodgeable
from
wet
hands
(
unitless)

SA
=
surface
area
of
1
to
3
fingers
(
cm2)

EXT
=
extraction
rate
by
saliva
(
unitless)

FQ
=
frequency
of
hand­
to­
mouth
events
(
events/
hour)

ET
=
exposure
duration
(
hours/
day)

BW
=
body
weight
(
kg)

Assumptions:

SA
­
The
surface
area
of
1
to
3
finger
is
20
cm2
FQ
­
The
frequency
of
hand­
to­
mouth
events
is
20
events
per
hour
for
short­
term
and
9.5
events
per
hour
for
intermediate­
term
F
­
The
fraction
of
residue
dislodgeable
from
wet
hands
is
5%

EXT
­
The
extraction
rate
by
saliva
is
50%.

ET
­
The
time
spent
outdoors
is
4
hours/
day
103
Appendix
B
Table
B2
­
Oral
Exposure
from
Hand­
to­
Mouth
Activity
on
Cypermethrin
and
Zeta­
Cypermethrin
Treated
Turf
Exposure
Scenario
Application
Rate
(
lb
ai/
acre)
or
Deposition
(
µ
g/
cm2)
Percent
Active
Ingredient
Dislodgeable
Surface
Area
(
cm2)
Hand
to
Mouth
(
events/
hr)
Extraction
by
Saliva
Exposure
Time
(
hours)
Body
Weight
(
kg)
Average
Daily
Dose
(
mg/
kg/
day)
Oral
MOE
(
UF=
1000)

Short­
term
Exposures
Cypermethrin
­­

Hand
to
Mouth
(
turf)
0.600
(
WP)
5%
20
20
50%
2
15
0.008971
1,100
0.440
(
EC)
0.0065788
1,500
Zeta­
Cypermethrin
­­
Hand
to
Mouth
(
turf)
0.3
5%
20
20
50%
2
15
0.004486
2,200
Oral
Dose
(
mg/
kg/
day)
=
AR
(
lb
ai)
x
CF
x
F
x
SA
(
cm2)
x
EXT
x
FQ
(
events/
hr)
x
ET(
hrs/
day)
x
(
0.001mg/
µ
g)

BW
(
kg)

Where:

Dose
=
oral
dose
on
day
of
application
(
mg/
kg/
day)

AR
=
application
rate
(
lb
ai/
A)

CF
=
conversion
factor
(
11.2)
to
convert
lb
ai/
A
to
µ
g/
cm2
(
1
lb
ai/
A
x
4.54E+
8
µ
g/
lb
x
2.47E­
8
A/
cm2
=
11.2
µ
g/
cm2)

F
=
fraction
of
residue
dislodgeable
from
wet
hands
(
unitless)

SA
=
surface
area
of
1
to
3
fingers
(
cm2)

EXT
=
extraction
rate
by
saliva
(
unitless)

FQ
=
frequency
of
hand­
to­
mouth
events
(
events/
hour)

ET
=
exposure
duration
(
hours/
day)

BW
=
body
weight
(
kg)

Assumptions:

SA
­
The
surface
area
of
1
to
3
finger
is
20
cm2
FQ
­
The
frequency
of
hand­
to­
mouth
events
is
20
events
per
hour
for
short­
term
F
­
The
fraction
of
residue
dislodgeable
from
wet
hands
is
5%

EXT
­
The
extraction
rate
by
saliva
is
50%.

ET
­
The
time
spent
outdoors
is
2
hours/
day
Fogger
Oral
Dose
(
mg/
kg/
day)
=
[
D
x
F
x
SA
x
FQ
x
ET)
x
EXT
x
0.001
mg/:
g]
/
BW
Where:
104
Dose
=
oral
dose
on
day
of
application
(
mg/
kg/
day)

D
=
deposition
(
µ
g/
cm2)
=
lb
ai/
fogger
(
0.0014
lb/
ft3)
x
4.5E+
08
µ
g/
lb
conversion
factor
x
0.001
mg/:
g
conversion
factor
/
room
area
(
256
ft2)

F
=
fraction
of
residue
dislodgeable
from
turf
to
wet
hands
(
unitless)

SA
=
surface
area
of
1
to
3
fingers
(
cm2)

EXT
=
extraction
rate
by
saliva
(
unitless)

FQ
=
frequency
of
hand­
to­
mouth
events
(
events/
hour)

ET
=
exposure
duration
(
hours/
day)

BW
=
body
weight
(
kg)

Assumptions:

SA
­
The
surface
area
of
1
to
3
finger
is
20
cm2
FQ
­
The
frequency
of
hand­
to­
mouth
events
is
20
events
per
hour
for
short­
term
and
9.5
events
per
hour
for
intermediate­
term
F
­
The
fraction
of
residue
dislodgeable
from
turf
to
wet
hands
is
5%

EXT
­
The
extraction
rate
by
saliva
is
50%.

ET
­
The
time
spent
outdoors
is
4
hours/
day
105
Appendix
B
Table
B3
­
Oral
Exposure
from
Mouthing
Cypermethrin
and
Zeta­
Cypermethrin
Treated
Turf
Exposure
Scenario
Application
Rate
lb
ai/
acre
Percent
Active
Ingredient
Dislodgeable
Surface
Area
(
cm2)
Body
Weight
(
kg)
Average
Daily
Dose
(
mg/
kg/
day)
Oral
MOE
(
UF=
1000)

Short­
term
Exposures
Cypermethrin
­­
Object
(
turf)
to
Mouth
(
Tier
One)
0.600
(
WP)
20%
25
15
0.002243
4,500
0.440
(
EC)
0.0016447
6,100
Zeta­
Cypermethrin
­­
Object
(
turf)
to
Mouth
(
Tier
One)
0.3
20%
25
15
0.001121
8,900
Oral
Dose
(
mg/
kg/
day)
=
AR
(
lb
ai/
A)
x
CF
x
F
x
SA
(
cm2)
x
(
0.001mg/
µ
g)

BW
(
kg)

Where:

Dose
=
oral
dose
on
day
of
application
(
mg/
kg/
day)

AR
=
application
rate
(
lb
ai/
A)

CF
=
conversion
factor
(
11.2)
to
convert
lb
ai/
A
to
µ
g/
cm2
(
4.54E+
8
µ
g/
lb
x
2.47E­
8
A/
cm2
=
11.2
µ
g
A/
lb
cm2)

F
=
fraction
of
residue
dislodgeable
from
turf
(
unitless)

SA
=
turf
surface
area
a
toddler
might
grasp
(
cm2/
day)

BW
=
body
weight
(
kg)

Assumptions:

SA
­
turf
surface
area
a
toddler
might
grasp
is
25
cm2/
day
F
­
The
fraction
of
residue
dislodgeable
from
turf
is
20%
106
Appendix
B
Table
B4
­
Oral
Exposure
to
Cypermethrin
and
Zeta­
Cypermethrin
from
Incidental
Soil
Ingestion
Exposure
Scenario
Application
Rate
(
lb
ai/
acre)
%
of
Application
Rate
in
Uppermost
1
cm
of
Soil
(
fraction/
cm)
Ingestion
Rate
(
IgR)

mg/
day
Body
Weight
(
kg)
Average
Daily
Dose
(
mg/
kg/
day)
Oral
MOE
(
UF=
1000)

Short­
term
Exposures
Cypermethrin
­­
Incidental
Soil
Ingestion
0.600
(
WP)
100%
100
15
0.000030
330,000
0.440
(
EC)
0.000022
450,000
Zeta­
Cypermethrin
­­
Incidental
Soil
Ingestion
0.3
100%
100
15
0.000015
670,000
Oral
Dose
=
AR(
lb
ai/
A)
x
F(
1.0/
cm)
x
IgR
(
mg/
day)
x
(
4.54E­
8
µ
g/
lb)
x
(
2.47E­
8
A/
cm2)
x
(
0.67
cm3/
g)
x
(
1E­
6
g/
µ
g)

BW
(
kg)

Where:

Dose
=
oral
dose
on
day
of
application
(
mg/
kg/
day)

AR
=
application
rate
(
lb
ai/
A)

F
=
fraction
or
residue
retained
on
uppermost
1
cm
of
soil
IgR
=
ingestion
rate
of
soil
(
mg/
day)

CF1
=
weight
unit
conversion
factor
to
convert
the
lbs
ai
in
the
application
rate
to
µ
g
for
the
soil
residue
value
(
4.54
x
108
µ
g/
lb)

CF2
=
area
unit
conversion
factor
to
convert
the
surface
area
units
(
ft2)
in
the
application
rate
to
cm2
for
the
SR
value
(
2.47
x
10­
8
acre/
cm2)

CF3
=
volume
to
weight
unit
conversion
factor
to
convert
the
volume
units
(
cm3)
to
weight
units
for
the
soil
residue
value
(
0.67
cm3/
g
soil)

CF4
=
weight
unit
conversion
factor
to
convert
the
µ
g
of
residues
on
the
soil
to
grams
to
provide
units
of
mg/
day
(
1E­
6
g/
µ
g)

BW
=
body
weight
(
kg)

Assumptions:

F
­
The
fraction
or
residue
retained
on
uppermost
1
cm
of
soil
is
100
percent
based
on
soil
incorporation
into
top
1
cm
of
soil
after
application
(
1.0/
cm)

IgR
­
The
ingestion
rate
of
soil
is
100
mg/
day
