UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
October
15,
20004
MEMORANDUM
SUBJECT:
Summary
and
Response
to
Comments
on,
"
Cypermethrin:
Occupational
and
Residential
Exposure
and
Risk
Assessment
for
the
Reregistration
Elegibility
Decision
(
RED)
Document."
(
DP
Barcode:
298692;
Chemical
No.
109702)

FROM:
Seyed
Tadayon,
Chemist
Reregistration
Branch
III
Health
Effects
Division
(
7509C)

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

TO:
Cathryn
O'Connell
Chemical
Review
Manager
Special
Review
and
Reregistration
Division
(
7508W)

This
document
contains
a
response
to
comments
submitted
in
a
memorandum,
"
Cypermethrin
RED:
from
FMC,
Syngenta,
United
Phosphorus,
Inc.,
and
Valent
Biosciences
Corporation
to
Mark
Seaton
(
SRRD),
dated
October
22,
2003.
Only
comments
regarding
occupational
and
residential
exposure
(
ORE)
to
cypermethrin
are
addressed
in
this
document.
Comments
relevant
to
the
ORE
assessment
are
presented
below,
followed
by
a
description
of
the
action
or
approach
taken
in
response
by
the
Agency.
FMC,
Syngenta,
United
Phosphorus,
Inc.,
and
Valent
BioSciences
Corporation
Error­
Only
Comments
Cypermethrin
Occupational
and
Residential
Exposure
Assessment
(
Oct.
22,
2003)

Location
in
Document
(
comment
#)
Comment
HED
Response
General
Comments
(
1)
The
occupational
and
residential
use
of
zetacypermethrin
was
not
included
in
this
document.
Since
exposure
to
zeta­
cypermethrin
could
cooccur
with
exposure
to
cypermethrin,
both
sets
of
risks
should
be
examined
in
this
document.
Please
ensure
that
zeta­
cypermethrin
uses
are
included
in
the
appropriate
discussions,
risk
assessments,
and
tables
throughout
the
Occupational
and
Residential
Assessment
document.
Zeta­
cypermethrin
was
included
in
the
document
(
2)
In
order
to
avoid
confusion,
the
indoor
use
patterns
for
cypermethrin
products
must
be
clearly
identified
throughout
this
document.
For
dilutable
(
EC)
or
WP/
WSB
formulations,
there
are
no
indoor
broadcast
scenarios
allowed
in
inhabitable
areas.
In
these
areas,
only
crack
and
crevice
or
spot
treatments
can
be
made
with
these
formulations.
In
addition
to
the
EC
and
WP/
WSB
formulations,
there
are
two
distinct
types
of
aerosol
products:
RTU
Total
Release
Aerosols
(
TRA)
and
RTU
aerosol
space
sprays
(
used
for
flying
insects,
crawling
insects,
crack
&
crevice/
spot).
The
distinction
between
TRAs
and
aerosol
space
sprays
should
be
maintained
throughout
the
document.
HED
has
distinguished
between
aerosol
can
applications
and
indoor
fogger
applications
in
this
document.

(
3)
This
should
be
revised
to
show
that
zetacypermethrin
also
is
included
in
the
assessment
Zeta­
cypermethrin
was
included
in
the
document
(
4)
This
should
be
revised
to
show
that
zetacypermethrin
also
is
included
in
this
process.
Zeta­
cypermethrin
was
included
in
the
document
(
5)
General
Revise
to
include
zeta­
cypermethrin
Zeta­
cypermethrin
was
included
in
the
document
(
6)
Paragraph
1
The
correct
chemical
name
contains
 
3­
phenoxyphenylmethyl 
Cypermethrin
formulations
include
liquid
and
wettable
powder
concentrates 
We
are
unaware
of
any
hose­
end
sprayer
uses
for
cypermethrin.
The
risk
assessment
does
not
seem
to
include
any
such
uses.
HED
corrected
the
spelling
of
the
chemical
name.

HED
added
the
word
"
powder"
to
the
document.

HED
removed
the
reference
to
hose­
end
sprayer
uses.
Location
in
Document
(
comment
#)
Comment
(
7)
Exposure
Data
Used
in
Assessment,
paragraph
1
"
No
handler
exposure
data
are
available
to
assess
exposures
to
ready­
to­
use
pump­
trigger
sprayers
or
indoor
foggers,
therefore
PHED
data
for
applying
with
an
aerosol
can
is
used
as
a
reasonable
worsecase
surrogate."
If
better
data
is
needed,
a
proprietary
study
(
MRID
44739301)
was
used
in
a
recent
bifenthrin
TRED
to
give
RTU
spray
bottle
dermal
and
inhalation
unit
exposure
numbers.
The
inhalation
unit
exposure
was
53.6
µ
g/
lb
ai.
HED
used
the
unit
exposure
values
from
the
proprietary
propoxur
study
for
this
assessment.
The
inhalation
unit
exposure
is
123
µ
g/
lb
ai
(
8)
Hazard
concerns,
paragraph
1
Typographical
error:
"
long­
term
inhalation
endpoint
of
concern
(
0.1
mg/
L "
should
read
" 
0.01
mg/
L "
Typographical
error:
"
neuratoxicity"
should
be
"
neurotoxicity"
HED
fixed
these
typographical
errors.

(
9)
Hazard
concerns,
paragraph
2
The
target
ARI
is
1,
therefore
ARIs
of
less
than
1
indicate 
HED
fixed
this
typographical
error.

(
10)
Hazard
concerns,
paragraph
3
The
document
states,
"
The
Agency
is
applying
an
FQPA
safety
factor
of
10X
for
non­
occupational
exposures
to
cypermethrin
due
to
the
lack
of
a
developmental
neurotoxicity
study".
This
is
a
contradiction
to
the
statement
in
Section
6,
Subsection
C.
of
the
HIARC
report
that
indicates
"
the
special
FQPA
safety
factor
should
be
1X
since
there
are
no
residual
uncertainties
for
pre
and/
or
post
natal
toxicity".
Please
indicate
which
statement
is
correct.
CHANGE
WAS
MADE
(
11)
Hazard
concerns,
paragraph
4
The
cypermethrin
HIARC
does
not
identify
a
developmental
neurotoxicity
datagap
for
cypermethrin.
While
the
Agency
apparently
has
required
a
DNT
study
on
zeta­
cypermethrin
from
one
registrant
and
apparently
has
told
that
one
registrant
that
the
zeta­
cypermethrin
study
will
also
apply
to
cypermethrin,
that
position
has
not
been
publicly
stated
or
communicated
to
any
other
registrants.
The
wording
in
this
sentence
needs
to
be
revised
to
correctly
reflect
the
requirement.
CHANGE
WAS
MADE
(
12)
Hazard
concerns,
paragraph
5
The
document
states
relative
to
non­
occupational
uncertainty
factors
that,
"
an
uncertainty
factor
of
3000
has
been
applied
to
long­
term
inhalation
exposures."
The
appropriate
long­
term
inhalation
uncertainty
factor
for
non­
occupational
exposures
is
defined
in
the
HIARC
report
(
pg
21
and
30)
to
be
1,000.
Please
clarify
which
uncertainty
factor
should
be
applied
for
the
long­
term
inhalation
risk
evaluations.
HED
has
re­
affirmed
that
the
uncertainty
factor
of
3000
applies
to
non­
occupational
long­
term
inhalation
exposures.
(
13)
Occupational
Handler
Risks,
paragraph
1
The
last
sentence
is
a
fragment,
perhaps
intended
to
part
of
the
preceding
sentence.
Please
reword
for
clarity.

In
the
fragment
sentence,
the
implication
is
that
the
ready
to
use
(
RTU)
scenario
presented
in
the
preceding
sentence
is
considered
to
represent
the
worst
case.
As
per
comment
2,
please
specify
what
type
of
aerosol
(
TRA
or
space
spray)
is
being
used
for
the
comparison.
HED
reworded
this
sentence.

HED
has
clarified
in
the
document
between
aerosol
spray
can
applications
and
ready­
touse
indoor
fogger
applications.

(
14)
Occupational
Handler
Risks,
paragraph
3
In
the
3rd
sentence,
the
statement
about
mixing/
loading/
applying
EC
formulations
for
termiticide
applications
with
baseline
PPE
is
moot
as
Pesticide
Regulation
Notice
96­
7
directs
that
"
chemical
resistant
gloves
shall
be
included
in
the
PPE
statement
for
all
termiticide
products"
(
i.
e.
is
a
PPE
requirement
for
each
Toxicity
category).
All
current
labels
already
require
the
use
of
chemicalresistant
gloves
for
this
activity,
with
waterproof
gloves
after
dilution
therefore,
it
is
not
necessary
to
access
termiticide
handlers
at
baseline
PPE
(
without
gloves).
HED
removed
the
exposure
values
for
"
no
gloves"
in
the
termiticide
injector
assessment.

(
15)
"
commercial
pest
control
officials"
should
be
"
commercial
pest
control
operators"
This
typographical
error
was
fixed.

(
16)
Some
of
the
MOEs
will
change
due
to
changes
in
the
appendices.
When
MOEs
changed,
these
are
reflected
in
the
text.
(
17)
Occupational
Handler
Risks,
paragraph
4
In
the
fourth
paragraph,
which
starts,
"
Aggregated
long­
term "
it
is
stated
that
the
long­
term
risks
were
below
the
Agency's
level
of
concern
was
for
all
scenarios,
except
mixing/
loading/
applying
wettable
powders
as
termiticides
with
a
low
pressure
handwand
sprayer
to
lawns.

The
WP
labels
do
have
use
patterns
where
termites
are
controlled
with
a
spray
mostly
via
injection
techniques
into
wall
voids
or
trees.
The
termite
control
uses
on
these
labels
restrict
applications
to
above
ground
uses
only
and
also
indicate
that
these
treatments
are
not
to
be
used
as
a
substitute
for
soil
treatment.
It
should
be
noted
that
the
traditional
soil
residual
termiticide
label
uses
are
covered
by
the
labeling
guidance
in
Pesticide
Regulation
Notice
96­
7
where
both
pre
and
post
construction
application
techniques
are
covered
by
either
a
broadcast
spray
or
trenching
and
rodding
techniques
(
soil
treatment
techniques).
These
use
patterns
cover
large
volume
application
scenarios.

No
cypermethrin
WP
labels
have
typical
soil
residual
application
use
directions
and
accordingly,
these
applications
would
not
use
the
high
volumes
(
e.
g.
500
gallon)
associated
with
soil
applications.
The
WP
use
volumes
for
lawn
applications
would
therefore
be
consistent
with
low
pressure
handwand/
backpack
(
40
gal),
or
spot
treatment
scenarios
(
1,000
ft2).

Please
revise
assessment
accordingly.
HED
changed
the
assessment
to
40
gallons
for
low­
pressure
handwand
equipment.

(
18)
Residential
Postapplication
Risk,
paragraph
1
The
document
states,
"
Postapplication
inhalation
risks
following
indoor
applications
at
residential
sites
may
pose
a
concern,
however,
these
risks
were
not
assessed
at
this
time
due
to
lack
of
exposure
data."
However,
a
postapplication
inhalation
risk
scenario
was
evaluated
and
was
not
of
concern.
See
section
3.2.3,
Residential
Postapplication
Exposure
and
Risk
Estimates,
Residential
Postapplication
Risk,
and
Table
9.
HED
changed
this
language
to
indicate
that
indoor
postapplication
inhalation
risks
were
evaluated
(
19)
Residential
Postapplication
Risk,
paragraph
2
The
document
indicates
the
turf
to
hand
to
mouth
risks
from
Wettable
powder
applications
were
not
acceptable
(
MOE
=
900).
This
value
is
based
upon
an
application
rate
of
0.74
lbs
ai/
A.
Syngenta,
FMC,
and
United
Phosphorous
Inc,
have
communicated
(
letter
to
LCDR
Mark
J.
Seaton
dated
May
29,
2003)
to
the
agency
that
the
residential
lawn
labels
should
be
capped
at
a
maximum
application
rate
of
0.0138
lbs
ai/
1000
ft2
HED
revised
the
risk
assessment
to
reflect
the
reduced
rate
for
wettable
powder
applications
to
residential
lawns.
(
0.60
lbs
ai/
A).
The
Revised
cypermethrin
use
closure
memo
(
June
2,
2003)
acknowledges
the
agreed
upon
capped
maximum
rate
to
be
submitted
by
Registrants
during
Phase
5
of
the
RED
processes.
Please
revise
to
the
agreed
upon
maximum
rate.
(
20)
 
and
paragraph
5
Paragraphs
2
and
5
will
change
based
on
assumptions
present
later
in
this
document.
HED
has
made
these
changes.

(
21)
Overall
Risk
Summary
The
document
states,
"
Residential
handler
and
postapplication
risks
are
of
concern
for
some
use­
patterns
and
no
practical
risk
mitigation
measures
are
available
to
the
Agency
to
reduce
these
risks."
This
should
be
changed
to:
Residential
handler
and
postapplication
risks
are
of
concern
may
be
mitigated
through
label
language
clarifying
uses
rates
and
application
methods.
HED
has
revised
this
language.

(
22)
The
document
states
"
The
Agency
is
applying
an
FQPA
safety
factor
of
10X
for
nonoccupational
risk
exposures
to
cypermethrin
due
to
a
lack
of
a
developmental
neurotoxicity
study."
As
indicated
in
point
1
above,
this
statement
is
not
consistent
with
HIARC
report.
NO
CHANGES
MADE
(
23)
Next
to
last
sentence:
The
cypermethrin
HIARC
does
not
identify
a
developmental
neurotoxicity
datagap
for
cypermethrin.
While
the
Agency
apparently
has
required
a
DNT
study
on
zeta­
cypermethrin
from
one
registrant
and
apparently
has
told
that
one
registrant
that
the
zeta­
cypermethrin
study
will
also
apply
to
cypermethrin,
that
position
has
not
been
publicly
stated
or
communicated
to
any
other
registrants.
The
wording
in
this
sentence
needs
to
be
revised
to
correctly
reflect
the
requirement.
NO
CHANGES
MADE
(
24)
Section
1.3,
paragraph
6
It
is
stated,
"
The
total
uncertainty
factors
that
have
been
applied
to
risk
assessments
is
100
for
occupational
scenarios
and
1000
for
nonoccupational
assessments."
However,
for
occupational
assessments
this
is
true
only
for
short
and
intermediate­
term
assessments.
For
long
term
occupational
assessments,
the
uncertainty
factor
should
be
300
per
HIARC.
HED
has
corrected
this
statement.

(
25)
Section
1.3,
Table
1
Under
long­
term
inhalation,
the
LOC
for
MOE
for
residential
is
incorrect.
The
MOE
of
3000
should
be
1000,
per
HIARC
NO
CHANGE
MADE
(
26)
Footnote
"
a"
is
incorrectly
listed
on
the
shortand
intermediate
and
the
long­
term
inhalation
residential
MOE
HED
fixed
the
footnote.

(
27)
Footnote
"
b"
appears
to
be
in
error
as
it
contradicts
footnote
"
a"
and
the
determined
dermal
absorption
factor
HED
fixed
the
footnote.
(
28)
Section
1.3,
paragraph
7
The
document
states,
"
However,
the
HIARC
document
notes
that
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
document
recommends
that
dermal
exposure
to
cypermethrin
should
be
minimized
and
the
products
labeled
to
provide
instructions
to
avoid
contact
with
skin."
To
which
HIARC
document
is
this
quote
referring?
It
is
not
the
February
2003
HIARC
document
included
with
this
package.
NO
CHANGE
MADE
(
29)
Section
1.4,
paragraph
1
The
referenced
report
by
J.
Blondell
does
not
include
any
suggestions
that
cypermethrin
can
cause
asthma
or
asthma­
like
symptoms.
NO
CHANGE
MADE
(
30)
Section
1.5.1
Table
3
The
table
does
not
include
any
zetacypermethrin
products,
please
ensure
zetacypermethrin
products
are
included.

Reg.
No.
279­
3026
is
the
technical,
not
a
manufacturing
product.
See
the
following
corrected
tables.
Zeta­
cypermethrin
has
been
incorporated
into
th
The
tables
have
been
adjusted
to
match
the
table
(
31)
Please
include
products
for
z­
cypermethrin.
These
formulations
include
liquid
concentrates
and
ready­
to­
use
eartags.
Table
4A
outlines
the
formulations
and
the
EPA
registrations
numbers
for
labels
of
zcypermethrin
end­
use
products
according
to
PPLS.
Many
of
the
products
described
in
Table
4A
can
be
used
in
a
variety
of
settings
ranging
from
agriculture
crops
to
commercial,
industrial,
and
residential
premises.
Zeta­
cypermethrin
has
been
incorporated
into
t
assessment.

(
32)
Section
1.5.3,
Occupati
onal
Use
Sites
and
The
registered
uses
for
zeta­
cypermethrin
need
to
be
added
to
the
appropriate
sections.
These
are
summarized
in
appendix
1.
Please
revise
this
section
accordingly.
Zeta­
cypermethrin
has
been
incorporated
into
the
assessment.

(
33)
Homeow
ne
ential
Use
Sites
Occupational
Use
Si
tes
Terrestrial
Food
Crop
Head
and
Stem
Brassica
Vegetables
do
not
include
broccoli
raab,
but
do
include
Chinese
(
napa)
cabbage
and
Chinese
mustard
cabbage.
Brassica
Leafy
vegetables
include
broccoli
raab
but
do
not
include
lettuce.
Chinese
cabbage
is
the
same
as
bok
choy.
Cypermethrin
is
not
registered
on
fruiting
vegetables.
HED
made
these
changes.

(
34)
Section
1.5.3,
paragraph
3
Under
Homeowner/
Residential
Use
Sites:
"
commercial
pest
control
officials"
should
be
"
commercial
pest
control
operators"
HED
fixed
this
typographical
error.
(
35)
Under
Homeowner/
Residential
Use
Sites:

As
stated
in
comment
2,
the
indoor
use
patterns
for
cypermethrin
products
must
be
clearly
identified
throughout
this
document.
For
dilutable
(
EC)
or
WP/
WSB
formulations,
there
are
no
indoor
broadcast
scenarios
allowed
in
inhabitable
areas.
Please
clarify
what
is
being
considered
as
"
broadcast"
for
indoor
residential
scenarios.

Also,
the
aerosol
products
are
not
included
in
this
section.
Please
include
both
types
of
aerosol
treatment
(
TRA
and
space
spray).
If
the
broadcast
scenario
is
related
to
an
aerosol
application,
please
specify
the
type
of
aerosol
product
this
is
related
to.
HED
clarified
these
use
patterns
in
the
text
(
36)
Please
add
"
s"
to
premise.
(
Indoor
and
Outdoor
Permises
)
HED
fixed
this
typographical
error
(
37)
Section
2.1,
paragraph
1
There
are
distinct
job
functions
or
tasks
related
to
pesticide
applications
and
exposures
that
can
vary
depending
on
the
specifics
of
each
task.
HED
fixed
this
typographical
error
(
38)
Section
2.1.1
Short
and
Intermediate­
term
Scenarios
Scenario
16,
Wettable
powder
formulations:
termiticide
injector
should
be
removed.
This
scenario
assessed
is
for
termite
control
in
trees,
utility
poles,
fence
posts
and
building
voids.
As
currently
assessed,
the
amount
handled
per
day
is
500
gallons
which
is
not
logical
for
the
type
of
application
being
assessed.

The
500
gallon
volume
is
reasonable
for
the
higher
volume
soil
residual
applications
(
e.
g.
rodding
/
trenching)
but
these
do
not
apply
in
this
case,
as
the
WP
labels
only
allow
for
above
ground
uses.

Further,
while
the
application
equipment
is
listed
as
an
injector
on
some
of
the
product
labels,
the
type
of
injection
tool
is
an
attachment
used
with
low
pressure
handwands,
or
backpack
sprayers
to
allow
delivery
into
the
area
being
treated.
As
such,
this
scenario
is
already
covered
by
scenarios
11
and
12.
Accordingly,
please
remove
Scenario
16.

It
would
be
appropriate
to
have
Mixer/
Loader/
Applicator
scenario
for
liquid
products
(
e.
g.
EC
used
as
a
soil
residual
termiticide).

Also,
some
liquid
product
labels
with
termite
and
other
wood
infesting
insects
allow
for
broadcast
application
indoors.
However,
these
broadcast
applications
are
limited
to
attics,
crawl
spaces,
unfinished
basements
and
similar
unfinished
unoccupied
areas.

Based
upon
the
comments
above,
please
revise
this
section
to
more
accurately
reflect
use
rates
for
occupational
handler
scenarios.
HED
removed
the
termiticide
injector
scenario
for
wettable
powder
formulations
and
added
it
to
the
liquid
formulations
in
the
assessment.

HED
altered
the
postapplication
risk
assessment
to
reflect
the
fact
that
broadcast
application
indoors
with
liquid
(
nonaerosol
and
non­
fogger)
formulations
are
spot
and
crack/
crevice
only.

(
39)
Section
2.1.2,
Bullet
4
The
product
labels
used
to
determine
the
application
use
rates
presented
in
this
section
should
be
specified
for
each
scenario.
HED
did
not
list
the
registration
numbers
of
specific
labels,
but
did
include
the
application
rates
from
the
use­
closure
memo
whenever
appropriate.

(
40)
Section
2.1.2,
paragraph
2,
Bullet
4,
subbullet
7
For
turfgrass
treatments
at
residential,
commercial
and
industrial
sites,
the
maximum
application
rate
is
listed
as
0.74
pounds
active
ingredient
per
gallon
acre.
As
acknowledged
by
the
Agency
in
the
Revised
Cypermethrin
Use
Closure
Memo
(
June
2,
2003),
the
maximum
lawn
application
rate
being
supported
by
the
registrants
is
0.6
lbs
ai
per
acre.
This
application
rate
is
for
WP
formulations
only.
The
maximum
EC
turf
rate
is
0.44
lbs
ai
per
acre.
Please
correct
the
maximum
turfgrass
WP
rate
to
0.6
lbs
ai
per
acre
as
per
comment
19.
This
change
should
also
be
reflected
in
the
relevant
summary
tables
in
the
document.
HED
altered
the
risk
assessment
to
reflect
the
new
maximum
application
rate
for
wettable
powders
on
residential
lawns.
41
Section
2.1.2,
paragraph
2,
Bullet
4,
subbullet
8
As
per
comment
2,
please
consistently
distinguish
the
type
of
aerosol
(
RTU
or
surface
spray)
throughout
the
document
in
order
to
ensure
clarity
about
the
type
of
product
being
evaluated.

The
application
rate
and
type
of
aerosol
application
that
the
corresponding
rate
applies
to
is
not
identified
and
cannot
be
readily
reproduced.
As
written,
the
ready­
to­
use
surface
treatment
maximum
application
rates
is
described
as
0.09
lbs
active/
16
oz
aerosol
can.
This
rate
is
equivalent
to
a
9%
(
w/
w)
cypermethrin
RTU
aerosol.
We
are
not
aware
of
any
RTU
aerosol
label
with
this
high
rate.
For
crack
&
crevice/
spot
aerosols,
the
highest
RTU
spray
we
are
aware
of
is
0.15%
cypermethrin.
The
highest
Total
Release
Aerosol
(
room
fogger)
that
we
are
aware
of
is
1.7%
(
in
1.5
oz
cans).
Given
these
percentages,
the
application
rate
for
an
aerosol
spray
could
be
no
more
than
0.0015
lbs
ai/
16
oz
can
for
the
crack
&
crevice,
and
not
more
than
0.0032
lbs
ai
for
a
TRA.
Further,
it
should
be
noted
that
for
TRA
applications,
the
applicator
does
not
stay
in
the
room.
Please
identify
which
use
label
has
this
concentration
for
aerosols
sprays
in
a
RTU
form.
Note:
One
potential
explanation
for
the
rate
in
question
(
0.09
lbs
active/
16
oz
aerosol
can)
is
the
possibility
that
the
Agency
has
confused
one
of
the
RTU
Ear
Tag
labels
as
an
aerosol.
HED
added
text
to
the
document
to
clarify
between
the
aerosol
spray
can
and
indoor
fogger
scenarios.

HED
adjusted
the
assessment
to
reflect
a
maximum
application
rate
for
RTU
aerosol
as
0.15%
active
ingredient.

(
42)
Section
2.1.2,
paragraph
2,
Bullet
6
"
However,
no
standard
values
are
available
for
scenarios
involving
livestock
treatments,
aerosol
cans
or
termiticide
treatments
in
and
around
premises.
HED
altered
the
text
to
reflect
the
wording
change.

(
43)
Section
2.1.2,
paragraph
2,
Bullet
6,
subbullet
4
Some
of
the
usage
assumptions
described
in
this
sub­
bullet
do
not
agree
with
the
parameters
specified
in
the
revised
Science
Advisory
Council
for
Exposure
Policy
9.
This
section
should
be
corrected
as
shown
below
to
include
the
correct
use
assumptions.

"
For
premises
treatments,
40
gallons
per
day
is
used
for
low­
pressure
handwand
and
backpack
scenarios,
500
gallons
5
acres
per
day
is
used
for
handgun
sprayer
applications,
and
500
gallons
per
day
is
used
for
termiticides
injection
applications
(
liquid
formulations
only),
and
5
gallons
per
day
is
used
for
paint
brush
applications."
HED
made
these
changes
in
the
text
and
in
the
assessment.

(
44)
Section
2.1.2,
paragraph
2,
Bullet
6,
subbullet
6
For
ready­
to­
use
applications,
EPA
assumes
that
professionals
use
four
8­
two
16­
ounce
aerosol
cans
or
one
1­
gallon
pump­
trigger
sprayer.
HED
made
these
changes
in
the
text
and
in
the
assessment.
(
45)
Section
2.1.2,
Table
5
The
Unit
Exposure
Values
for
LCO
Turfgun
application
based
upon
ORETF
studies
are
presented.
The
values
do
not
match
those
in
MRID
449722­
01
(
ORETF
report
OMA002).
It
is
not
clear
where
the
cited
unit
exposure
values
are
found
in
the
referenced
ORETF
document.
Please
clarify
how
the
unit
exposure
values
were
determined.
Additionally,
the
EC
and
WSB
data
were
also
used
in
this
risk
assessment,
but
not
included
in
Table
5.
This
data
should
be
added.
Also,
the
table
says
"
no
glove
data
were
not
back
calculated,"
but
this
is
included
in
the
table.
The
unit
exposures
for
the
ORETF
studies
reflect
the
most
recent
decisions
on
the
values
for
this
study.

HED
made
these
changes
in
the
text
and
in
the
assessment.

(
46)
Section
2.1.3,
paragraph
2
(
daily
exposure)
Where:
Daily
Dermal
Exposure
(
mg
ai/
day)
=
Unit
Exposure(
mg
ai/
lb
ai)
x
Application
Rate
(
lb
ai/
lb
of
seed
)

x
Daily
amount
Treated
(
lbs)
HED
made
these
changes
in
the
text.

(
47)
Section
2.1.3,
paragraph
3
(
daily
dose)
The
3rd
and
2nd
to
last
sentences
of
the
paragraph
are
misleading.
Please
rephrase
the
sentences
to
state
that
no
absorption
factor
is
needed
for
inhalation
based
on
the
identified
NOAEL
of
2.7
mg/
kg/
day
from
the
study.
HED
made
these
changes
in
the
text.

(
48)
After
the
formula,
it
is
suggested
to
add
"
Inhalation
daily
doses
were
calculated
in
a
similar
manner."
HED
made
these
changes
in
the
text.

(
49)
The
equation
that
describes
the
process
for
calculating
the
Daily
dermal
or
inhalation
dose
needs
to
be
corrected
as
follows:
Where:
Daily
dermal
or
inhalation
dose
(
mg/
kg/
day)
=
daily
dermal
HED
made
these
changes
in
the
text.

(
50)
Section
2.1.3,
Margins
of
Exposure
heading
The
equation
that
describes
the
process
for
calculating
the
dermal
or
inhalation
MOE
needs
to
be
corrected
as
follows:

Where:
Dermal
or
inhalation
MOE=
Daily
Dermal
Dose
(
mg/
kg/
day)/
Dermal
NOAEL(
mg/
kg/
day)
HED
made
these
changes
in
the
text.

(
51)
Section
2.1.3,
Margins
of
Exposure
heading
Paragraph
2
"
The
target
MOEs
for
long­
term
occupational
workers
are
100
for
dermal
and
300
for
inhalation
risk.
The
following
sentence
is
not
clear
as
it
is
written:
"
The
effects
seen
at
both
dermal
and
inhalation
by
loss
of
body
weight "
Please
reword
this
sentence
to
make
it
clear
what
is
intended.
HED
made
these
changes
in
the
text.

HED
reworded
this
section.
(
52)
Section
2.1.3,
(
Occupational
Risk
Summary)
Table
6
general
comments
The
uses
for
zeta­
cypermethrin
need
to
be
added
to
table
6.
These
data
are
presented
in
Appendix
2.
Many
of
the
application
use
parameters
presented
in
this
table
are
inconsistent
with
those
presented
in
section
2.1.2,
4th
main
bullet
(
reference
comment
43).
Further,
the
sources
of
the
application
rates
are
unknown
and
for
some
scenarios
are
not
consistent
with
those
presented
in
section
2.1.2.
Please
identify
the
labels
used
as
sources
of
application
rates.
Also,
the
turf
grass
application
rate
should
be
capped
at
0.6
lbs
ai
per
acre,
as
per
comments
19
and
40.
Zeta­
Cypermethrin
has
been
added
to
this
document
HED
has
altered
certain
text
and
application
rates
in
this
document
to
reflect
the
use­
closure
memo
and
to
make
section
consistent
with
one
another.

(
53)
Section
2.1.3,
(
Occupational
Risk
Summary),
Table
6
Scenarios
7
and
8
Lawn
uses:
Please
clarify
how
the
lawn
application
rate
was
determined.

As
per
comment
2,
dilutable
(
EC)
or
WP/
WSB
formulations,
allow
for
no
indoor
broadcast
scenarios
in
inhabitable
areas.
These
products
are
limited
to
crack
and
crevice
or
spot
treatments
only
in
inhabitable
indoor
areas.
HED
has
altered
the
lawn
use
rate
as
reflected
in
the
use
closure
memo.

HED
made
these
changes
in
the
text
and
in
the
assessment.

(
54)
Section
2.1.3,
(
Occupational
Risk
Summary)
Table
6
Scenario
10
The
use
rate
is
correctly
identified.
However,
the
amount
handled
per
day
is
incorrectly
identified
and
should
be
corrected
to
state
5
acres,
not
5
gallons.
HED
made
this
change
in
the
text.

(
55)
Section
2.1.3,
(
Chronic
Risk
Summary)
Chemical­
resistant
gloves
already
are
required
for
all
mixing/
loading/
application
of
EC
formulations
on
all
labels,
with
waterproof
gloves
after
dilution
or
with
closed
systems.
Additionally
as
stated
in
comment
14,
PRN
96­
7
mandates
that
"
chemical
resistant
gloves
shall
be
included
in
the
PPE
statement
for
all
termiticide
products".
With
the
requirement
to
wear
gloves
already
present
on
the
EC/
TC
labels,
an
assessment
with
baseline
PPE
is
not
appropriate.
HED
removed
the
baseline
"
no
glove"
scenario
for
those
scenarios
for
which
the
"
no
glove"
unit
exposure
had
to
be
backcalculated
since
no
data
existed
for
a
baseline
scenario.
Otherwise,
HED
left
in
the
baseline
scenario
as
is
consistent
with
other
assessments.

(
56)
Section
2.1.3,
(
Chronic
Risk
Summary),
paragraph
1
When
data
were
available
to
assess
risks,
risks
to
occupational
handlers
are
below
the
Agency's
level
are
not
below
the
Agency's
level
of
concern
for
risk
assessments
(
i.
e.,
ARI>
1)
at
either
baseline
attire
(
i.
e.,
long­
sleeve
shirt,
long
pants,
shoes,
and
socks),
or
with
the
addition
of
personal
protective
equipment
for
dermal
protection
(
i.
e.,
chemical­
resistant
gloves).
HED
made
these
changes
in
the
text.
(
57)
Section
2.1.3,
(
Chronic
Risk
Summary),
Table
7,
Scenario
1
and
2
Baseline
dermal
MOE
values
should
be
shown
as
"
N/
A"
since
all
labels
require
the
used
of
chemical
resistant
gloves
for
these
applications,
with
waterproof
gloves
after
dilution
or
with
closed
systems.

Many
of
the
application
use
parameters
presented
in
this
table
are
inconsistent
with
those
presented
in
section
2.1.2,
4th
main
bullet
(
as
per
comment
43).
Further,
the
sources
of
the
application
rates
are
unknown
and
for
some
scenarios
are
not
consistent
with
those
presented
in
section
2.1.2.
Please
identify
the
labels
used
as
sources
of
application
rates.
Also,
the
turf
grass
application
rate
should
be
capped
at
0.6
lbs
ai
per
acre,
as
per
comments
19
and
40
HED
removed
the
baseline
"
no
glove"
scenario
for
those
scenarios
for
which
the
"
no
glove"
unit
exposure
had
to
be
backcalculated
since
no
data
existed
for
a
baseline
scenario.
Otherwise,
HED
left
in
the
baseline
scenario
as
is
consistent
with
other
assessments.

HED
altered
these
sections
to
make
them
consistent
with
one
another.
HED
also,
when
appropriate,
altered
the
maximum
use
rates
to
reflect
the
use
closure
memo.

(
58)
Section
3.1.2,
Bullet
3,
subbullet
4
Consistent
with
SAP
12,
the
number
of
animals
to
be
treated
when
applying
to
pet
horses
is
one
not
two.
HED
altered
the
assessment
to
reflect
one
horse.

(
59)
Section
3.1.3,
Table
8
Scenario
5
The
ready­
to­
use
surface
treatment
maximum
application
rates
is
described
as
0.09
lbs
active/
16
oz
aerosol
can.
This
rate
is
equivalent
to
a
9%
(
w/
w)
cypermethrin
RTU
aerosol.
We
are
not
aware
of
any
RTU
label
with
this
high
rate.
The
highest
RTU
aerosol
we
are
aware
of
is
0.15%
cypermethrin.
Please
indicate
what
label
has
this
concentration
in
a
RTU
form.
HED
altered
the
assessment
to
reflect
a
0.15%
aerosol
can.

(
60)
Section
3.1.3,
paragraph
4
It
should
read
MOE's,
not
MOE,
s.
HED
fixed
this
typographical
error.

(
61)
Section
3.1.4,
Paragraph
1
If
required,
there
is
proprietary
unit
exposure
data
for
trigger­
pump
sprayers
that
was
used
for
a
bifenthrin
TRED;
MRID
44739301.
See
comment
(
6).
HED
used
the
proprietary
data
for
propoxur
to
assess
exposure
to
pump­
trigger
sprayers.

(
62)
Section
3.2.1,
paragraph
2
The
document
states,
"
Postapplication
inhalation
risks
following
indoor
applications
at
residential
sites
may
pose
a
concern,
however,
these
risks
were
not
assessed
at
this
time
due
to
lack
of
exposure
data."
A
postapplication
inhalation
risk
scenario
was
evaluated
and
was
not
of
concern.
(
See
section
3.2.3,
Residential
Postapplication
Exposure
and
Risk
Estimates,
Residential
Postapplication
Risk,
and
Table
9.)
HED
altered
the
text
to
reflect
this
comment.
(
63)
Section
3.2.2,
Bullet
1,
subbullets
1
&
2,
and
subullet
6
The
document
states
that,
"
measured
TTR
values
 
even
if
available
 
are
not
used
because
of
differences
in
Transferability
versus
what
would
be
expected
during
hand­
tomouth
behaviors."
A
similar
statement
is
included
for
object­
to­
mouth
behaviors.
Section
3.2.4
however
recommends
additional
data,
"
such
as
TTR
data
which
are
more
appropriate
for
handto
mouth
and
object­
to­
mouth
exposures".
These
two
statements
should
be
harmonized,
as
they
are
contradictory.

subbullet
6
 
please
correct:
object­
to­
mouth
exposures
are
based
upon
25
cm2
/
day
surface
area
HED
altered
the
text
to
reflect
this
comment.

HED
altered
the
text
to
reflect
this
comment.

(
64)
Section
3.2.3,
paragraph
2,
hand­
to­
mouth
and
object
to
mouth
calculations
based
upon
contact
with
treated
turf:
For
all
equations:
The
application
rates
(
AR)
in
the
equations
should
be
in
units
of
lb
ai/
A
For
the
conversion
factor
(
CF)
of
11.2
see
following
corrections.
CF
=
conversion
factor
(
11.2)
to
convert
lb
ai/
A
to
µ
g/
cm2
should
be
calculated
as
follows:
(
1
lb
ai/
A
x
­
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
to
wet
hands
(
unitless)
BW
=
70
kg
HED
altered
the
text
to
reflect
this
comment.

HED
altered
the
text
to
reflect
this
comment.

(
65)
Section
3.2.3,
oral
exposure
from
hand
to
mouth
activity
upon
treated
indoor
hard
surfaces
and
carpet
The
units
in
the
equation
should
be
based
on
surface
residue
(
SR)
in
µ
g/
cm2
and
not
the
application
rate
(
AR)
in
lb/
1000
ft2.
There
is
no
conversion
factor
included
to
give
the
proper
units.
Thus
the
assumption
should
be
that
an
application
rate
of
0.000017
lb
ai/
ft2
equals
8.31
µ
g/
cm2.

Further,
the
SR
(
surface
residue
component)
used
in
this
section
appears
to
be
from
a
general
broadcast
application.
However,
the
current
use
labels
only
allow
for
crack
&
crevice/
spot
treatments
in
living
areas.
As
per
comment
2,
please
identify
what
is
meant
by
broadcast
and
how
the
application
rate
used
in
the
calculations
were
determined.
HED
altered
the
text
to
reflect
this
comment.

HED
adjusted
the
assessment
by
applying
a
50%
adjustment
factor
for
the
application
to
crack
and
crevices
rather
than
as
a
broadcast
treatment
and
altered
the
text
to
reflect
this
comment.

(
66)
Section
3.2.3,
paragraph
3,
object­
to­
mouth
The
equation
for
object­
to­
mouth
exposure
includes
exposure
time
(
ET)
in
the
assumptions
section.
This
term
not
utilized
in
object
to
mouth
calculations
as
the
temporal
component
is
covered
by
the
SA
term
(
cm2/
day).
Please
correct.

Please
also
correct
the
SA
term
to
be
25
cm2/
day
not
20
cm2/
day,
as
per
Science
Advisory
Council
on
Exposure
policy
#
12.
HED
altered
the
text
to
reflect
this
comment.

HED
altered
the
text
to
reflect
this
comment.
(
67)
Section
3.2.3,
paragraph
7,
(
Residential
Postapplicati
on
Risk)
The
reference
to
M.
Collantes,
12/
04/
2001
is
unclear.
No
document
form
M.
Collantes
on
that
date
could
be
located.
Perhaps
the
reference
is
to
the
12/
04/
01
document
"
PP#
0F06207
FQPA
Human
Health
Risk
Assessment
for
the
Use
of
Z­
Cypermethrin
on
Sorghum,
Wheat,
Soybean,
Legumes
and
Fruiting
Vegetables,"
DP
Barcode:
D279025
by
Y.
Donovan.
Please
indicate
which
document
is
being
referenced.
The
indoor
inhalation
assessment
done
using
a
study
titled
Exposure
Evaluation
during
homeowner
use
of
laser
products.
The
pyrethroid
group
are
well
aware
of
this
study
and
is
used
in
several
pyretheroid
risk
assessment.
This
study
is
conducted
using
cyfluthrin.

(
68)
Section
3.2.3,
paragraph
7,
8,
9
(
Residential
Postapplicati
on
Risk)
In
the
3
paragraphs
preceding
Table
9,
the
text
indicates
that
Post­
application
short­
term
inhalation
exposures
from
an
indoor
fogger
treatments
were
assessed
based
upon
a
cyfluthrin
fogger
study.
Additionally
it
is
stated
that
a
"
house
model"
was
used
to
estimate
the
emission
rate
based
upon
dilution
features
of
the
model.
At
two
earlier
points
in
the
document
(
Executive
summary
(
residential
post
application
section
and
section
3.2.1),
it
is
stated
that
indoor
exposures
and
postapplication
exposures
were
not
being
assessed
due
to
a
lack
of
data.
If
the
post­
application
inhalation
risks
were
assessed,
then
the
previous
two
points
are
incorrect.
If
the
data
were
subjected
to
a
"
house
model",
the
model
utilized
should
be
identified.
Multi
Chamber
Consumer
Exposure
Model
(
MCCEM)
was
used
by
the
pyretheroid
group
to
estimate
an
emission
rate
which
was
based
on
the
dilution
features
of
the
model.

(
69)
Section
3.2.3,
paragraph
9
(
Residential
Postapplicati
on
Risk)
In
the
paragraph
immediately
preceding
Table
9,
it
is
stated
that
ALL
of
the
risk
calculations
for
the
various
cypermethrin
assessments
are
included
in
appendix
B
for
the
turf
and
indoor
scenarios.
Appendix
B
only
contains
post
application
risk
data
for
oral
exposures
(
toddler)
and
not
all
of
the
risk
calculations
in
particular
the
calculations
cited
in
Table
9.
HED
has
added
all
scenarios
to
the
appendices
.

(
70)
There
is
a
typographical
error
in
footnote
"
b"
 
daily
dose
should
be
mg/
kg/
day
rather
than
mg/
jg/
day.
Please
correct.
HED
fixed
this
typographical
error.

(
71)
Section
3.2.3,
Table
9
The
application
rate
used
in
this
section
appears
to
be
from
a
general
broadcast
application.
However,
the
current
use
labels
contain
a
crack
&
crevice/
spot
use
pattern
in
living
areas.
As
per
comments
2,
41,
and
65,
please
indicate
what
is
meant
by
broadcast
and
how
the
application
rate
was
determined.
HED
altered
the
assessment
to
reflect
the
crack
and
crevice
use
pattern,
rather
than
the
broadcast
spray.

(
72)
Section
3.2.3,
Tables
9&
10
Hand
to
mouth
from
indoor
surfaces,
The
source
of
the
application
rate
(
0.000017
lb
ai/
sqft)
is
unclear.
Please
clarify
how
this
rate
was
determined.
Also
please
indicate
if
application
was
made
as
general
broadcast,
what
type
of
product
is
being
assessed
(
reference
comment
2).
HED
altered
the
assessment
to
reflect
the
crack
and
crevice
use
pattern,
rather
than
the
broadcast
spray.

(
73)
Section
3.2.3,
Table
10
The
residential
lawn
application
rate
for
the
WP
formulation
is
indicated
as
0.74
lbs
ai/
A.
The
registrants
have
agreed
to
an
application
rate
cap
of
0.60
lbs
ai/
A
as
discussed
in
comment
19.
Please
correct
to
the
cap
rate
and
modify
tables
and
appendices
as
appropriate.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
74)
Section
3.2.3,
Table
10
Turf
uses:
The
maximum
WP
application
rate
to
turf
per
the
Use
Closure
Memo
is
0.6
lb
ai/
A
(
comment
19),
which
yields
an
MOE
of
1100.
Please
revise
accordingly.

As
per
comments
2,
41,
and
65,
please
explain
HED
made
this
change
in
the
text
and
in
the
assessment.

HED
made
alterations
in
the
text
to
explain
this
as
a
(
75)
Section
3.2.3,
Table
11
The
second
and
fourth
rows
under
both
shortterm
and
intermediate­
term
exposures
need
to
be
clarified
to
show
that
these
refer
to
EC
uses
(
table
currently
says
"
spray",
even
though
both
WP
and
EC
formulations
are
sprayed)

The
indoor
surface
spray
component
needs
to
be
revised
as
discussed
in
comment
2,
41,
and
65
as
there
are
no
registered
indoor
broadcast
applications
for
cypermethrin.
Please
revise
as
appropriate.
HED
made
this
change
in
the
text.

HED
made
this
change
in
the
text
and
in
the
assessment.

(
76)
Section
3.2.3,
Table
11
Please
add
the
zeta­
cypermethrin
uses
to
Tables
10
and
11.
These
are
summarized
and
presented
in
Appendix
2
of
this
errors
only
document.
Zeta­
cypermethrin
was
added
to
this
document.

(
77)
Section
3.2.3,
Statements
following
Table
11
Conclusions
about
aggregate
risk
estimates
for
MOEs
<
1000
should
be
revised
following
correction
of
risk
assessments
for
the
lack
of
broadcast
indoor
surface
spray
treatments.
All
indoor
treatments
are
crack
&
crevice/
spot
uses.
Please
revise
per
comments
2,
41,
and
65
HED
made
this
change
in
the
text
and
in
the
assessment.

(
78)
Appendix
A/
Table
A1
The
table
includes
both
dermal
and
inhalation
exposure
information,
however,
dermal
exposure
was
not
considered
for
short
and
intermediate­
term
risk.
The
data
source
is
listed
as
PHED
V1.1
In
addition,
the
EPA
SAC
Policy
9.1
was
used
to
obtain
the
standard
assumptions.
This
change
was
not
made.

(
79)
Appendix
A/
Table
A1
Scenarios
The
respirator
protection
factor
of
10
was
not
used.
HED
made
this
change
in
the
text.

(
80)
Appendix
A/
Table
A1
Scenarios
7­
13
and
16
Under
PPE
it
states
that
"
Respiratory
protection
not
required
for
this
assessment,"
yet
the
assessment
was
done
with
the
respirator
protection
factor
of
5,
and
in
some
cases
was
required.
The
same
statement
used
under
scenarios
1­
6
should
be
included.
HED
made
this
change
in
the
text.

(
81)
Appendix
A/
Table
A1
Scenarios
10,
14,
The
amount
handled
daily
should
be
5
acres
and
not
500
gallons
for
lawn
handgun
applications
in
accordance
with
SAP
9.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
82)
Appendix
A/
Table
A1
Scenario
Although
no
data
was
available,
paintbrush
data
was
used
in
Table
A2.
HED
made
this
change
in
the
text.
(
83)
Appendix
A/
Table
A2
The
zeta­
cypermethrin
uses
need
to
be
included
in
this
table.
Zeta­
cypermethrin
was
added
to
this
document
(
84)
Appendix
A/
Table
A2
Scenario
1d
The
MOE
for
baseline
inhalation
should
be
corrected
to
39,000.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
85)
Appendix
A/
Table
A2
Scenario
2a­
d
The
unit
exposure
for
the
engineering
control
is
the
same
as
the
liquid.
Instead,
the
WSB
unit
exposure
data
should
be
used,
which
gives
a
value
of
0.24
ug/
lb
ai
handled.
All
engineering
control
MOEs
should
be
amended.
HED
made
these
changes
in
the
text
and
in
the
assessment.

(
86)
Appendix
A/
Table
A2
Scenario
4
The
unit
exposure
value
for
the
engineering
control
should
be
0.43
ug/
lb
ai.
All
engineering
control
MOEs
should
be
amended.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
87)
Appendix
A/
Table
A2
Scenario
7
Lawn
Uses:
The
basis
for
the
lawn
use
rate
at
0.0034
lb
ai/
gal
cannot
be
identified.
As
stated
previously
(
comment
19)
the
maximum
lawn
application
rate
being
supported
by
the
registrants
is
0.6
lbs
ai
per
acre
for
the
WP
formulations
and
0.44
lbs
ai
per
acre
for
the
EC
formulations.
Please
correct
the
maximum
WP
turfgrass
rate
to
0.6
lbs
ai
per
acre
for
risk
assessments
and
modify
report/
tables
as
needed.

Non­
termite
indoor:
please
revise
per
comment
2
to
reflect
that
EC
and
WP
formulations
can
only
be
applied
indoors
as
crack
&
crevice
or
spot
treatments.
They
are
not
labeled
for
indoor
applications
as
general
broadcast
sprays.
HED
made
this
change
in
the
text
and
in
the
assessment.

HED
made
this
change
in
the
text
and
in
the
assessment.

(
88)
Appendix
A/
Table
A2
Scenario
7
and
8
We
were
unsure
how
the
agency
arrived
at
the
use
rates
for
the
horse
and
soil
applications.
These
values
are
do
not
reflect
realistic
use
rates.
As
an
example,
the
rate
quoted
for
horse
would
be
equivalent
to
treating
100
horses
per
day
(
label
rate
2
oz/
animal),
which
for
one
individual
is
logistically
impossible.
Please
explain
the
source
for
these
rates.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
89)
In
the
Termites:
building
perimeter
section,
the
application
rate
is
0.08
lbs
ai
per
gallon
(
equivalent
to
1%).
This
rate
is
not
correct,
the
correct
application
rate
is
0.1%
(
0.008
lbs/
gal)
for
EC/
TC
formulations
on
Outdoor
surfaces
and
around
buildings.
Voids
may
be
treated
at
1%
for
certain
pests
but
this
would
be
done
using
injection
equipment
and
not
low­
pressure
handwand.
Please
revise
as
needed.
HED
made
this
change
in
the
text
and
in
the
assessment.
(
90)
Appendix
A/
Table
A2
Scenario
8
The
basis
for
the
lawn
use
rate
at
0.0034
lb
ai/
gal
cannot
be
identified.
As
stated
previously
(
comment
18)
the
maximum
lawn
application
rate
agreed
upon
by
EPA
and
the
registrants
is
0.6
lbs
ai
per
acre
for
the
WP
formulations
and
0.44
lbs
ai
per
acre
for
the
EC
formulations.
Please
correct
the
maximum
turfgrass
rate
to
0.6
lbs
ai
per
acre
for
risk
assessments
and
modify
report/
tables
as
needed.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
91)
Appendix
A/
Table
A2
Scenario
9
The
crop
or
target
of
"
lawns"
with
application
directed
at
"
outside
surfaces"
is
inconsistent;
outside
surfaces
of
structures
are
not
lawns.
Please
ensure
that
this
use
rate
is
not
used
for
"
lawn"
application
exposure
assessments.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
92)
The
unit
exposure
values
should
be
280
ug/
lb
ai
for
baseline
and
56
ug/
lb
ai
for
PPE.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
93)
Appendix
A/
Table
A2
Scenario
10
Since
the
lawn
use
rate
is
correctly
given
in
lb
ai/
acre,
the
amount
handled
daily
also
should
be
in
acres
(
5
acres,
not
5
gallons).
HED
made
this
change
in
the
text
and
in
the
assessment.

(
94)
Appendix
A/
Table
A2
Scenario
11
The
lawn
MOEs
should
be
corrected
to
290
and
1400
for
baseline
and
PPE,
respectively.
These
rates
will
be
changed
additionally
with
the
incorporation
of
the
WP
0.6
lbs
ai/
A
maximum
ca
p
r
at
e.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
95)
Appendix
A/
Table
A2
Scenario
13
The
unit
exposures
for
paintbrush
applications
should
be
280
and
56
ug/
lb
ai
for
baseline
and
PPE,
respectively.
The
MOEs
should
be
amended.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
96)
The
unit
exposure
value
is
listed
as
323
µ
g/
lb
ai
and
attributed
to
the
PHED
database.
The
inhalation
unit
exposure
value
in
PHED
for
paint­
brush
applications
(
PHED
Scenario
22)
is
280
µ
g/
lb
ai.
Please
correct
as
necessary.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
97)
The
"
Amount
Handled"
should
be
5
Acres.
The
unit
exposures
could
not
be
verified
based
on
the
ORETF
study.
HED
made
this
change
in
the
text
and
in
the
assessment.

The
ORETF
values
reflect
the
most
recent
decisions
by
HED.
(
98)
Appendix
A/
Table
A2
Scenario
14
The
unit
exposure
value
is
listed
as
62
µ
g/
lb
ai
and
attributed
to
the
ORETF.
The
inhalation
unit
exposure
value
for
handgun
with
WP
in
the
ORETF
summary
document
(
0MA005)
is
65.4
µ
g/
lb
ai.
The
ORETF
values
reflect
the
most
recent
decisions
by
HED.

(
99)
Appendix
A/
Table
A2
Scenario
15
The
maximum
WP
allowable
use
rate
on
lawns
per
the
use
closure
memo
is
0.6
lb
ai/
A.
The
"
Amount
Handled"
should
be
5
Acres.
The
unit
exposures
could
not
be
verified
based
on
the
ORETF
study
report.
HED
made
this
change
in
the
text
and
in
the
assessment.

The
ORETF
values
reflect
the
most
recent
decisions
by
HED.

(
100)
Appendix
A/
Table
A2
Scenario
20
The
application
rate
and
type
of
aerosol
application
that
the
corresponding
rate
applies
to
is
not
identified
and
cannot
be
reproduced.
As
per
comments
2
and
41,
please
clarify
how
the
application
rate
was
determined
and
what
type
of
product
is
being
assessed
(
e.
g.
TRA
or
space
spray).
HED
made
this
change
in
the
text
and
in
the
assessment.
(
101)
The
basis
for
the
lawn
use
rate
at
0.0034
lb
ai/
gal
cannot
be
identified.
Please
clarify
where
this
rate
is
derived
from.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
102)
Appendix
A/
Table
A4
Scenario
1
The
preconstruction
wood
baseline
dermal
+
inhalation
MOE
is
97.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
103)
Appendix
A/
Table
A4
Scenario
2
The
basis
for
the
lawn
use
rate
at
0.0034
lb
ai/
gal
cannot
be
identified.
Please
clarify
where
this
rate
is
derived
from.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
104)
Appendix
A/
Table
A4
Scenario
3
The
unit
exposures
should
be
180,
280
and
21
ug/
lb
ai
for
baseline
dermal,
baseline
inhalation
and
PPE
dermal
exposures,
respectively.
Some
MOEs
should
be
adjusted
based
on
this
change.

It
is
unclear
why
the
application
rate
for
the
preconstruction
wood
scenario
lists
"
treats
10
sq
ft."
Please
clarify.
HED
made
this
change
in
the
text
and
in
the
assessment.

HED
made
this
change
in
the
text.

(
105)
Appendix
A/
Table
A4
Scenario
7
The
unit
exposures
should
be
180,
280
and
21
ug/
lb
ai
for
baseline
dermal,
baseline
inhalation
and
PPE
dermal
exposures,
respectively.
Some
MOEs
should
be
adjusted
based
on
this
change.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
106)
Appendix
A/
Table
A4
Scenario
8
and
9
As
discussed
in
comment
18,
the
maximum
allowable
cypermethrin
use
rate
on
lawns
for
WP
formulations
per
the
use
closure
memo
is
0.6
lb
ai/
A.
Also,
the
unit
exposures
could
not
be
verified
based
on
the
ORETF
study
report.
Please
confirm.
HED
made
this
change
in
the
text
and
in
the
assessment.

The
ORETF
values
reflect
the
most
recent
decisions
by
HED.

(
107)
Appendix
A/
Table
A5
The
table
includes
both
dermal
and
inhalation
exposure
information.
However,
dermal
exposure
was
not
considered
for
short
and
intermediate­
term
risk.

The
data
source
is
listed
as
SOPs
for
Residential
Exposure
Assessments
(
12/
97).
In
addition,
PHED
V1.1
was
used
to
obtain
unit
exposure
data.
HED
did
not
alter
this
table.

(
108)
Appendix
A/
Table
A6
Scenarios
4­
6
The
inhalation
Unit
Exposure
value
for
aerosol
can
applicators
was
taken
from
PHED
and
is
incorrectly
listed
as
2,400
µ
g/
lb
ai.
The
correct
inhalation
unit
exposure
value
from
PHED
for
aerosol
applicators
is
1,300
µ
g/
day.
Please
correct
as
necessary.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
109)
Appendix
A/
Table
A6
Scenario
5
Comment
same
as
comment
for
100.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
110)
Appendix
B/
Table
B1
The
application
rate
of
0.000017
lb
ai/
ft2
is
equivalent
to
a
1.5%
RTU
aerosol
product,
which
does
not
exist.
As
per
comments
2,
41,
and
65,
please
clarify
how
the
application
rate
was
determined.
HED
made
this
change
in
the
text
and
in
the
assessment.
(
111)
Appendix
B/
Table
B2
The
maximum
allowable
WP
use
rate
on
lawns
per
the
use
closure
memo
is
0.6
lb
ai/
A.
The
MOEs
should
be
adjusted
accordingly.

The
equation
should
have
AR
in
lb
ai/
A.

For
the
conversion
factor
(
CF),
there
should
be
no
1
lb
ai/
A
included
to
allow
the
units
to
cancel
in
the
Oral
Dose
equation.
It
should
be
4.54E+
8
ug/
lb,
and
the
units
are
11.2
ug
A/
lb
cm2.

Should
F
be
the
fraction
of
residue
dislodgeable
from
turf
to
wet
hands?
HED
made
this
change
in
the
text
and
in
the
assessment.

HED
fixed
this
typographical
error.

HED
fixed
this
typographical
error.

HED
made
this
change
in
the
text.

112
Appendix
B/
Table
B3
The
maximum
allowable
WP
use
rate
on
lawns
per
the
use
closure
memo
is
0.6
lb
ai/
A
(
see
comment
18).
The
MOEs
should
be
adjusted
accordingly.

The
equation
should
have
AR
in
lb
ai/
A.
FQ
is
not
included
in
this
equation.
SA
is
in
cm2/
day.
For
the
conversion
factor
(
CF),
there
should
be
no
1
lb
ai/
A
included
to
allow
the
units
to
cancel
in
the
Oral
Dose
equation.
It
should
be
4.54E+
8
ug/
lb,
and
the
units
are
11.2
ug
A/
lb
cm2.
F
is
the
fraction
of
residue
dislodgeable
from
the
turf.
SA
is
the
surface
area
of
turf
mouthed
per
day.

Assumptions
SA
is
the
approximate
surface
area
from
which
a
child
may
grasp
a
handful
of
grass,
25
cm2.
F
is
the
fraction
of
residue
dislodgeable
for
the
grass,
20%.
HED
made
this
change
in
the
text
and
in
the
assessment.

(
1
1
3
)
Remove
the
exposure
time
(
ET)
from
the
assumptions
section
as
the
temporal
component
is
covered
by
SA
(
cm2/
day)
term.

Please
correct
surface
area
to
25
cm2
per
day
not
20
cm2/
day.
(
note
25
cm2
was
apparently
correctly
used
in
the
actual
calculation)
HED
made
this
change
in
the
text.

(
114)
Appendix
B/
Table
The
maximum
WP
allowable
use
rate
on
lawns
per
the
use
HED
made
this
change
in
the
text
and
in
the
assessment.

B4
closure
memo
is
0.6
lb
ai/
A.
The
MOEs
should
be
adjusted
accordingly.
The
equation
should
include
4.54E+
8
ug/
lb.
CF2
is
to
convert
surface
area
units
from
Acres
to
cm2.
