UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
Date:
JUNE
13,
2005
Subj:
Inorganic
Chlorates:
Occupational
and
Residential
Exposure
Assessment
for
the
Reregistration
Eligibility
Decision
(
RED)
Document
(
Case
4049)

PC
Codes:
Sodium
Chlorate:
073301
Potassium
Chlorate:
073302
Calcium
Chlorate:
073303
Magnesium
Chlorate:
530200
DP
Barcode:
D307365
From:
Matthew
Crowley,
Environmental
Protection
Specialist
Health
Effects
Division/
Reregistration
Branch
4
(
7509C)

Through:
Susan
Hummel,
Branch
Senior
Scientist
Health
Effects
Division/
Reregistration
Branch
4
(
7509C)

To:
Bonnie
Cropp­
Kohlligian,
Risk
Assessor
Health
Effects
Division/
Reregistration
Branch
4
(
7509C)

Jacqueline
Guerry,
Chemical
Review
Manager
Special
Review
and
Reregistration
Division/
Reregistration
Branch
3
The
attached
document
is
the
occupational
and
non­
occupational
(
residential)
exposure
and
risk
assessment
for
inorganic
chlorates
to
support
the
Health
Effects
Division
(
HED)
reregistration
eligibility
decision
(
RED)
document.
This
document
addresses
only
the
exposures
and
risks
to
sodium
chlorate
as
it
is
the
only
inorganic
chlorate
as
an
active
ingredient
in
any
registered
products.
Occupational
and
residential
exposures
and
risks
to
inorganic
chlorates
as
inert
ingredients
in
registered
products
are
addressed
under
separate
cover
(
M.
Crowley,
6/
13/
05,
D318045).

The
assessment
was
reviewed
by
HED's
Science
Advisory
Council
for
Exposure
(
ExpoSAC)
to
ensure
compliance
with
current
HED
policy
as
well
as
ExpoSAC
standard
operating
procedures
(
SOPs)
for
conducting
occupational
and
residential
exposure
(
ORE)
assessments.
Table
of
Contents
Executive
Summary
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3
1.0
Occupational
and
Residential
Exposure/
Risk
Assessment
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5
1.1
Purpose
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5
1.2
Criteria
for
Conducting
Exposure
Assessments
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5
1.3
Summary
of
Hazard
Concerns
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5
1.3.1
Sodium
Chlorate
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5
1.4
Incident
Reports
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6
1.5
Summary
of
Physical
and
Chemical
Properties
of
Sodium
Chlorate
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7
1.6
Summary
of
Use
Patterns
and
Formulations
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7
1.6.1
End­
Use
Products
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7
1.6.2
Registered
Use
Categories
and
Sites
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7
1.6.3
Application
Methods
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9
2.0
Occupational
Exposures
and
Risks
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9
2.1
Occupational
Handler
Exposures
and
Risks
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9
2.1.1
Data
and
Assumptions
For
Handler
Exposure
Scenarios
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11
2.1.1.1
Assumptions
for
Handler
Exposure
Scenarios
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11
2.1.1.2
Exposure
Data
for
Handler
Exposure
Scenarios
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13
2.1.2
Sodium
Chlorate
Handler
Exposure
Scenarios
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16
2.1.3
Non­
cancer
Sodium
Chlorate
Handler
Exposure
and
Assessment
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17
2.1.3.1
Non­
cancer
Sodium
Chlorate
Handler
Exposure/
Risk
Calculations
.
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17
2.1.3.2
Sodium
Chlorate
Non­
cancer
Risk
Summary
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18
3.0
Residential
Exposures
and
Risks
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23
3.1
Residential
Handler
Exposures
and
Risks
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23
3.1.1
Handler
Exposure
Scenarios
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23
3.1.2
Data
and
Assumptions
For
Handler
Exposure
Scenarios
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24
3.1.3
Residential
Handler
Exposure
and
Non­
Cancer
Risk
Estimates
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27
4.0
Occupational
and
Residential
Handler
Exposure
and
Risk
Estimates
for
Cancer
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30
5.0
Summary
of
Risk
Concerns
and
Data
Gaps
for
Occupational
and
Residential
Handlers
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30
6.0
Occupational
and
Residential
Postapplication
Exposures
and
Risks
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30
APPENDIX
1
­
Label
Extraction
Tables
APPENDIX
2
­
Occupational
and
Residential
Risk
Calculations
3
Executive
Summary
This
document
contains
the
occupational
and
residential
exposure
assessment
for
agricultural,
commercial
(
non­
agricultural),
and
residential
uses
for
sodium
chlorate.
As
an
agricultural
defoliant/
desiccant,
it
is
mostly
used
on
cotton,
however
it
is
also
applied
to
a
wide
variety
of
other
crops
including,
but
not
limited
to,
rice,
corn,
soybeans,
dry
beans,
potatoes,
sunflowers,
flax,
safflower,
chili
peppers
(
for
processing
only),
grain
sorghum,
and
wheat.
Application
rates
range
from
6
to
12.5
lb
of
active
ingredient
(
ai)
sodium
chlorate
per
acre
and
is
applied
by
aerial
and
ground
equipment.
Agricultural
product
formulations
are
all
soluble
concentrates/
liquids.

As
a
non­
selective
herbicide
it
is
applied
to
industrial/
non­
crop
areas
such
as
rights­
ofways
building
perimeters,
ditch
banks,
bleachers,
airport
runways,
vacant
lots,
fire
hydrants,
or
as
a
pre­
paving
treatment
at
rates
ranging
from
0.76
lb
ai
per
250
ft2
(
132
lb
ai
per
acre)
[
EPA
Reg.
No.
9754­
1]
to
2.37
lb
ai
per
100
ft2
(
1032
lb
ai
per
acre)
[
EPA
Reg.
No.
77041­
34]
for
soluble
concentrate/
liquid
formulations,
and
0.37
lb
ai
per
100
ft2
(
161
lb
ai
per
acre)
[
EPA
Reg.
Nos.
53883­
97
and
66222­
23]
to
1.2
lb
ai
per
100
ft2
(
523
lb
ai
per
acre)
[
EPA
Reg.
Nos.
690­
48
and
33560­
48]
for
granular
or
pellet/
tablet
formulations.
Its
residential
use
is
similar
to
the
commercial
herbicidal
use,
however
is
applied
as
a
spot
treatment/
edging
treatment
to
driveway
cracks
and
crevices,
around
foundations,
and
underneath
or
around
wood
decks.
It
is
not
labeled
for
broadcast
on
residential
lawns
or
ornamentals.
As
an
herbicide
it
is
applied
using
handheld
equipment
(
i.
e.,
low
pressure
handwands
or
sprinkler
cans),
but
for
the
larger
industrial/
non­
crop
settings
a
rights­
of­
way
sprayer,
handgun
sprayer,
groundboom,
or
tractor­
drawn
spreader
may
be
applicable.

Sodium
chlorate
is
toxicity
category
IV
for
acute
dermal,
inhalation,
and
oral
toxicity
and
toxicity
category
III
for
skin
and
eye
irritation
potential.
Results
were
negative
for
dermal
sensitization.
The
only
endpoint
chosen
is
for
short­
and
intermediate­
term
inhalation
because
as
an
inorganic
salt,
significant
amounts
of
sodium
chlorate
are
not
expected
to
be
absorbed
through
the
skin.
The
inhalation
endpoint
chosen
for
use
in
this
assessment,
a
no
observed
adverse
effects
level
(
NOAEL)
of
30
mg/
kg/
day,
was
defined
in
a
90­
day
oral
study
in
rats.
The
level
of
concern
(
LOC)
for
the
margin
of
exposure
(
MOE)
is
100.
The
level
of
concern
is
based
on
10x
to
account
for
interspecies
extrapolation
to
humans
from
the
animal
test
species
and
10x
to
account
for
intraspecies
sensitivity.

An
occupational
and
residential
cancer
risk
assessment
was
not
conducted
for
sodium
chlorate.
The
exposure
durations
for
occupational
and
residential
handlers
are
inconsistent
with
the
mechanism
of
carcinogenicity.
A
2­
year
NTP
bioassay
to
determine
the
potential
of
sodium
chlorate
to
induce
thyroid
tumors
in
laboratory
animals
(
rats
and
mice)
has
been
recently
reported
in
a
draft
form
(
NTP,
2004).
A
final
report
of
this
study
is
expected
during
2005.
In
these
tests,
there
was
some
evidence
of
thyroid
gland
follicular
cell
carcinogenicity
in
male
rats
which
may
be
attributed
to
the
imbalance
of
thyroid
hormones
(
reduced
T
3
and
T
4
and
elevated
TSH)
seen
in
these
studies
as
a
result
of
exposure
to
high
doses
of
sodium
chlorate.
Current
EPA
HED
policy
4
states
that
"
nonmutagenic
pesticides
that
induce
elevated
levels
of
TSH
and
thyroid
follicular
cell
tumors
in
the
rat
should
be
classified
as
not
likely
to
be
carcinogenic
to
humans
at
doses
that
do
not
alter
rat
thyroid
hormone
homeostasis"
((
HED
hot
sheet
#
23).
In
female
mice
there
was
equivocal
and
marginal
evidence
of
increased
pancreatic
islet
carcinoma.

Risks
for
most
occupational
handler
baseline
(
without
a
respirator)
inhalation
exposure
scenarios
do
not
exceed
HED's
level
of
concern
of
100
for
the
MOE
(
i.
e,
most
scenarios
had
MOEs
>
100).
However,
risks
for
the
following
scenarios
exceeded
HED's
level
of
concern
at
baseline:

°
Mixing/
Loading
liquids
for
groundboom
application
to
industrial/
non­
crop
sites
at
1032
lb
ai
per
acre
(
MOE
=
42)
and
523
lb
ai
per
acre
(
MOE
=
84);
°
Loading
granules
for
tractor­
drawn
spreader
applications
to
industrial/
non­
crop
sites
at
523
lb
ai
per
acre
(
MOE
=
59);
°
Applying
sprays
to
industrial/
non­
crop
sites
using
groundboom
equipment
(
open
cab)
at
1032
lb
ai
per
acre
(
MOE
=
69);
°
Applying
granules
to
industrial/
non­
crop
sites
using
a
tractor­
drawn
spreader
(
open
cab)
at
523
lb
ai
per
acre
(
MOE
=
84);
°
Loading/
Applying
granules
to
industrial/
non­
crop
sites
using
a
belly
grinder
at
523
lb
ai
per
acre
(
MOE
=
65);
and
°
Mixing/
Loading/
Applying
liquids
for
low
pressure
handwand
applications
to
industrial/
non­
crop
sites
at
1032
lb
ai
per
acre
(
MOE
=
34)
and
523
lb
ai
per
acre
(
MOE
=
67).

With
the
addition
of
a
dust/
mist
respirator
(
with
an
80%
reduction
factor),
or,
for
certain
scenarios,
engineering
controls
(
enclosed
cockpits
or
cabs),
all
occupational
handler
scenarios
were
below
HED's
level
of
concern.
Additionally,
risks
were
mitigated
for
certain
scenarios,
without
the
application
of
a
respirator
or
engineering
controls,
by
using
lower
application
rates.
Risks
of
concern
were
at
the
higher
application
rates
(
1032
and
523
lb
ai
per
acre),
whereas
at
lower
rates
the
risk
were
not
of
concern
(
MOEs
>
100
at
lower
application
rates).

All
residential
handler
inhalation
exposure
scenarios
were
also
below
HED's
level
of
concern
(
i.
e,
all
scenarios
had
MOEs
>
100).
Postapplication
dermal
and
inhalation
exposures
are
negligible
due
to
its
physical
and
chemical
characteristics
as
an
inorganic
salt.
No
significant
amount
of
sodium
chlorate
is
expected
to
be
absorbed
through
the
skin
and
the
vapor
pressure
is
negligible.
5
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
sodium
chlorate
from
its
use
as
an
agricultural
defoliant/
desiccant
and
a
nonagricultural
non­
selective
herbicide.
In
this
document,
which
is
for
use
in
EPA's
development
of
the
HED
chapter
of
the
sodium
chlorate
RED
Document,
EPA
presents
the
results
of
its
review
of
the
potential
human
health
effects
of
occupational
and
residential/
non­
occupational
exposure
to
sodium
chlorate.

1.2
Criteria
for
Conducting
Exposure
Assessments
An
occupational
and/
or
residential
exposure
assessment
is
required
for
an
active
ingredient
if
(
1)
certain
toxicological
criteria
are
triggered
and
(
2)
there
is
a
potential
for
exposure
to
handlers
(
mixers,
loaders,
applicators)
during
use
or
to
persons
entering
treated
sites
or
exposed
to
vapors
after
application
is
complete.
A
toxicological
endpoint
was
selected
only
for
inhalation
exposures
to
sodium
chlorate.
There
is
potential
for
short­
and
intermediate­
term
inhalation
exposure
in
a
variety
of
agricultural
and
commercial
settings
as
well
as
in
residential
settings.
Therefore,
assessments
for
inhalation
exposures
to
sodium
chlorate
use
are
required
for
occupational
and
residential
handlers.

1.3
Summary
of
Hazard
Concerns
The
sodium
chlorate
risk
assessment
team
met
to
determine
appropriate
toxicological
endpoints
of
concern
for
sodium
chlorate.
The
toxicological
endpoints
extracted
from
the
Toxicology
Section
for
the
RED
document
(
A.
Khasawinah,
D307358)
that
were
used
to
complete
the
occupational
and
residential
risk
assessments
are
summarized
below.

1.3.1
Sodium
Chlorate
Sodium
chlorate
is
an
agricultural
defoliant/
desiccant
and
a
commercial/
residential
herbicide.
Use
patterns
can
vary
from
short­
term
to
intermediate­
term
exposure
durations.
Longterm
exposure
durations
are
not
expected.
Sodium
chlorate
exposures
are
expected
to
occur
to
both
occupational
and
residential
users.

Dermal
Route
(
non­
cancer)

Because
it
is
an
inorganic
salt,
significant
absorption
of
sodium
chlorate
through
the
skin
is
not
expected,
and
a
dermal
toxicological
endpoint
was
not
selected.
Therefore,
a
risk
assessment
for
dermal
exposure
(
handler
and
postapplication)
was
not
performed.
6
Inhalation
Route
(
non­
cancer)

The
short­
and
intermediate­
term
(
non­
cancer)
inhalation
risk
assessment
for
sodium
chlorate
is
based
on
a
NOAEL
of
30
mg/
kg/
day,
which
was
defined
in
a
90­
day
oral
study
in
rats.
The
lowest
observed
adverse
effects
level
(
LOAEL)
of
112
mg/
kg/
day
was
based
on
colloid
depletion
and
follicular
cell
hyperplasia.
Long­
term
exposures
to
sodium
chlorate
(
i.
e.
greater
than
6
months)
are
not
expected
for
current
registered
uses.
As
the
toxicological
endpoint
is
based
on
an
oral
study,
standard
HED
practice
calls
for
application
of
a
100%
inhalation
absorption
factor
to
be
used
in
exposure
calculations.

Non­
cancer
Level
of
Concern
(
LOC)

HED's
level
of
concern
for
sodium
chlorate
is
100
(
i.
e.
MOEs
less
than
100
exceed
HED's
level
of
concern)
for
both
occupational
and
residential
scenarios.
The
level
of
concern
is
based
on
10x
to
account
for
interspecies
extrapolation
to
humans
from
the
animal
test
species
and
10X
to
account
for
intraspecies
sensitivity.

Cancer
A
2­
year
NTP
bioassay
to
determine
the
potential
of
sodium
chlorate
to
induce
thyroid
tumors
in
laboratory
animals
(
rats
and
mice)
has
been
recently
reported
in
a
draft
form
(
NTP,
2004).
A
final
report
of
this
study
is
expected
during
2005.
In
these
test,
there
was
some
evidence
of
thyroid
gland
follicular
cell
carcinogenicity
in
male
rats
which
may
be
attributed
to
the
imbalance
of
thyroid
hormones
(
reduced
T
3
and
T
4
and
elevated
TSH)
seen
in
these
studies
as
a
result
of
exposure
to
high
doses
of
sodium
chlorate.
Current
EPA
HED
policy
states
that
"
nonmutagenic
pesticides
that
induce
elevated
levels
of
TSH
and
thyroid
follicular
cell
tumors
in
the
rat
should
be
classified
as
not
likely
to
be
carcinogenic
to
humans
at
doses
that
do
not
alter
rat
thyroid
hormone
homeostasis"
((
HED
hot
sheet
#
23).
In
female
mice
there
was
equivocal
and
marginal
evidence
of
increased
pancreatic
islet
carcinomas.

Acute
Toxicity
Sodium
chlorate
is
classified
as
category
IV
for
acute
oral,
dermal,
and
inhalation
toxicity.
It
is
classified
as
category
III
for
both
eye
irritation
potential
skin
irritation
potential.
Results
were
negative
for
dermal
sensitization.

Body
Weight
Since
the
adverse
effects
for
all
studies
utilized
in
the
sodium
chlorate
inhalation
risk
assessments
are
not
gender­
specific,
the
average
weight
of
an
adult
(
i.
e.,
70
kg)
was
used
to
estimate
exposure.
7
1.4
Incident
Reports
An
analysis
of
incident
reports
will
be
included
in
a
separate
memo
by
Jerome
Blondell.

1.5
Summary
of
Physical
and
Chemical
Properties
of
Sodium
Chlorate
Sodium
chlorate
(
CAS
registry
number
7775­
09­
9)
is
an
odorless,
water­
soluble,
nonvolatile
white
crystalline
solid
(
like
common
table
salt)
with
a
molecular
formula
of
NaClO
3
and
a
molecular
weight
of
106.44
g/
mole.
Its
vapor
pressure
is
listed
as
"
NA",
not
applicable,
and
is
considered
negligible
(
D303554,
Appendix
C).

1.6
Summary
of
Use
Patterns
and
Formulations
Sodium
chlorate
products
are
described
in
this
section.

1.6.1
End­
Use
Products
Sodium
chlorate
is
used
in
agricultural,
commercial,
and
residential
settings.
End­
use
product
formulations
for
sodium
chlorate
include
liquids
(
soluble
concentrate
and
ready­
to­
use
­
RTU)
and
solids
(
granular
and
pellet/
tablet).

1.6.2
Registered
Use
Categories
and
Sites
Sodium
chlorate
is
registered
for
use
in
occupational
and
residential
scenarios
(
see
Tables
1
through
3).
As
a
defoliant/
desiccant,
professional
agricultural
uses
include:
cotton,
corn,
rice,
dry
beans,
grain
sorghum,
flax,
safflower,
sunflower,
soybeans,
guar
beans,
southern
peas,
chili
peppers
(
for
processing
only),
potatoes,
ornamental
gourds,
cucurbits
(
grown
for
seed),
wheat,
and
fallow
land.
Labels
indicate
a
restricted
entry
interval
(
REI)
of
12
hours
which
is
the
Worker
Protection
Standard
(
WPS)
requirement
for
active
ingredients
in
toxicity
category
III
for
acute
skin
irritation
potential.

As
a
non­
selective
herbicide
it
is
used
to
kill
grasses
and
weeds
in
industrial
and
non­
crop
sites
such
as:
rights­
of­
way
areas,
building
perimeters,
driveways,
parking
lots,
fence
rows,
tennis
courts,
ditch
banks,
picnic
areas,
bleachers,
cemeteries,
fuel
tank
farms,
airport
runways,
helo
pads,
wood
decks,
guard
rails,
highway
medians,
sidewalks/
walkways,
vacant
lots,
fire
hydrants,
recreational
areas,
pipelines,
railroads,
lumberyards,
and
other
similar
areas.
As
a
residential
herbicide
it
is
applied
as
a
spot
treatment
or
edging
treatment
around
patios,
along
fence
lines,
lawn
edges,
around
foundations,
underneath
or
around
wood
decks,
and
in
cracks
and
crevices
of
driveways.
Product
labels
indicate
that
it
is
not
for
use
on
lawns/
turf,
ornamental
plants,
and
desirable
shrubs
and
trees.
(
See
Appendix
1
for
label
extraction
and
additional
usage
descriptions.)
8
Table
1:
Summary
of
Application
Rates
for
Sodium
Chlorate
Agricultural
Uses
(
Defoliant/
Desiccant)

Crop
Type/
Use
Site
Application
Equipment
Application
Rates
Cotton,
corn,
rice,
dry
beans,
sorghum,
flax,
safflower,
sunflower,
soybeans,
guar
beans,
southern
peas
aerial,
groundboom
7.5
lb
ai/
A
Chili
peppers
(
processing
only),
potatoes
aerial,
groundboom
12.5
lb
ai/
A
Ornamental
gourds,
cucurbits
(
grown
for
seed),
fallow
land,
wheat
aerial,
groundboom
6
lb
ai/
A
Table
2:
Summary
of
Application
Rates
for
Sodium
Chlorate
 
Industrial
and
Other
Non­
Crop
Uses
Crop
Type/
Use
Site
Application
Equipment
Application
Rates1,2
Industrial/
Non­
Crop
sites
rights­
of­
way
sprayer,
handgun
sprayer,
groundboom,
low­
pressure
handwand
1032
lb
ai/
A
523
lb
ai/
A
132
lb
ai/
A
belly
grinder,
push­
type
spreader,
tractor­
drawn
spreaders
523
lb
ai/
A
240
lb
ai/
A
161
lb
ai/
A
Table
3:
Summary
of
Application
Rates
for
Registered
Sodium
Chlorate
 
Residential
Herbicidal
Uses
Crop
Type/
Use
Site
Application
Equipment
Application
Rates
Spot
treatment/
edging
treatment
RTU
sprinkler
can
0.27
lb
ai/
gallon
low­
pressure
handwand,
sprinkler
can
23.7
lb
ai/
1000
ft2
trigger­
pump
sprayer
0.196
lb
ai/
gallon
belly
grinder,
push­
type
spreader,
hand
12
lb
ai/
1000
ft2
1
The
extrapolation
of
the
application
rate
into
acres
(
from
a
square
foot­
based
application
rate)
is
presented
to
reflect
the
potential
in
occupational/
commercial
settings
to
deal
in
acres
treated
per
day
as
seen
in
the
ExpoSAC
SOP
#
9:
Standard
Values
for
Daily
Acres
Treated
in
Agriculture
which
was
completed
on
July
5,
2000.
See
Appendix
1
for
label­
specific
rates.
2
Application
rates
are
presented
to
show
upper
and
lower
ranges
as
seen
on
different
product
labels
as
seen
in
Appendix
1.
9
1.6.3
Application
Methods
Sodium
chlorate
as
a
defoliant/
desiccant
in
agricultural
settings
is
applied
using
aerial
and
groundboom
equipment.
As
a
herbicide
it
is
applied
using
handheld
equipment
such
as
a
lowpressure
handwand,
sprinkling
cans,
and
also,
rights­
of­
way,
groundboom,
and
handgun
sprayers
for
larger
commercial
scenarios.
Granular
formulations
can
be
applied
using
belly
grinders,
pushtype
spreaders,
tractor­
drawn
spreaders,
or
by
hand.

2.0
Occupational
Exposures
and
Risks
Although
potential
for
both
dermal
and
inhalation
exposure
exists
in
occupational
scenarios
(
agricultural
and
non­
agricultural)
from
handling
sodium
chlorate
products
during
the
application
process
(
i.
e.,
mixer/
loaders,
applicators,
flaggers,
and
mixer/
loader/
applicators),
only
risks
for
inhalation
exposures
are
assessed
as
discussed
in
Section
1.3.1.

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

Exposure
scenarios
can
be
thought
of
as
ways
of
categorizing
the
kinds
of
exposures
that
occur
related
to
the
use
of
a
chemical.
The
use
of
scenarios
as
a
basis
for
exposure
assessment
is
very
common
as
described
in
the
U.
S.
EPA
Guidelines
For
Exposure
Assessment
(
U.
S.
EPA;
Federal
Register
Volume
57,
Number
104;
May
29,
1992).
Information
from
the
current
labels,
use
and
usage
information,
toxicology
data,
and
exposure
data
were
all
key
components
in
developing
the
exposure
scenarios.

The
first
step
in
the
handler
risk
assessment
process
is
to
identify
the
kinds
of
individuals
that
are
likely
to
be
exposed
to
sodium
chlorate
during
the
application
process.
In
order
to
do
this
in
a
consistent
manner,
HED
has
developed
a
series
of
general
descriptions
for
tasks
that
are
associated
with
pesticide
applications.
Tasks
associated
with
occupational
pesticide
use
(
i.
e.,
for
"
handlers")
can
generally
be
categorized
using
one
of
the
following
terms:

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

C
Applicators:
these
individuals
operate
application
equipment
during
the
release
of
a
pesticide
product
into
the
environment.
These
individuals
can
make
applications
using
10
equipment
such
as
airplanes
or
groundboom.

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

Most
exposure
scenarios
for
handheld
equipment
(
such
as
handwands,
backpack
sprayers,
and
push­
type
spreaders)
are
assessed
as
a
combined
job
function.
With
these
types
of
handheld
operations,
all
handling
activities
are
assumed
to
be
carried
out
by
the
same
individual.
The
available
monitoring
data
support
this
and
HED
presents
them
this
way
in
risk
assessments.
Conversely,
for
equipment
types
such
as
fixed­
wing
aircraft,
and
groundboom
tractors,
the
applicator
exposures
are
assessed
and
presented
separately
from
those
for
the
mixer/
loaders.
By
separating
the
two
job
functions,
HED
determines
the
most
appropriate
levels
of
personal
protective
equipment
(
PPE)
for
each
aspect
of
the
job
without
requiring
the
applicator
to
wear
unnecessary
PPE
that
may
be
required
for
the
mixer/
loaders
(
e.
g.,
chemical
resistant
gloves
may
only
be
necessary
during
the
pouring
of
a
liquid
formulation).

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

Next,
assessors
must
understand
how
exposures
to
sodium
chlorate
occur
(
i.
e.,
frequency
and
duration)
and
how
the
patterns
of
these
occurrences
can
cause
the
effects
of
the
chemical
to
differ
(
referred
to
as
dose
response).
Wherever
possible,
use
and
usage
data
determine
the
appropriateness
of
certain
types
of
risk
assessments
(
e.
g.,
a
chronic
risk
assessment
is
not
warranted
because
chronic
duration
exposure
patterns
to
sodium
chlorate
are
not
expected
to
occur).
Other
parameters
are
also
defined
from
use
and
usage
data
such
as
application
rates
and
application
frequency.
HED
always
completes
non­
cancer
risk
assessments
using
maximum
application
rates
for
each
scenario
because
what
is
possible
under
the
label
(
the
legal
means
of
controlling
pesticide
use)
must
be
evaluated
in
order
to
ensure
there
are
no
concerns
for
each
specific
use.

A
chemical
can
produce
different
effects
based
on
how
long
a
person
is
exposed,
how
frequently
exposures
occur,
and
the
level
of
exposure.
It
is
likely
that
sodium
chlorate
exposures
can
occur
in
a
variety
of
patterns.
HED
believes
that
occupational
sodium
chlorate
exposures
can
occur
over
a
single
day
or
up
to
weeks
at
a
time
for
many
use­
patterns
and
intermittent
exposures
over
several
weeks
are
also
anticipated.
Some
applicators
may
apply
sodium
chlorate
over
a
period
of
weeks
because
they
are
custom
or
commercial
applicators
who
are
completing
applications
for
a
number
of
different
clients.
HED
classifies
exposures
up
to
30
days
as
shortterm
and
exposures
greater
than
30
days
up
to
several
months
as
intermediate­
term.
HED
completes
both
short­
and
intermediate­
term
assessments
for
occupational
scenarios
in
essentially
all
cases,
because
these
kinds
of
exposures
are
likely
and
acceptable
use/
usage
data
are
not
11
available
to
justify
deleting
intermediate­
term
scenarios.
Long­
term
handler
exposures
are
not
expected
to
occur
for
sodium
chlorate.
The
same
toxicological
endpoint
(
from
an
oral
study)
of
concern
was
selected
for
short­,
and
intermediate­
term
inhalation
sodium
chlorate
exposures,
therefore
the
risk
results
for
both
inhalation
exposure
durations
are
numerically
identical.

Occupational
handler
exposure
assessments
are
completed
by
HED
using
different
levels
of
personal
protection.
HED
typically
evaluates
all
exposures
with
a
tiered
approach.
The
lowest
tier
is
represented
by
the
baseline
exposure
scenario
(
i.
e.,
long­
sleeve
shirt,
long
pants,
shoes,
socks,
and
no
respirator)
followed
by
increasing
the
levels
of
personal
protective
equipment
(
PPE)
(
e.
g.,
gloves,
double­
layer
body
protection,
and
respirators)
and
engineering
controls
(
e.
g.,
enclosed
cabs
or
cockpits
and
closed
mixing/
loading
systems).
This
approach
is
always
used
by
HED
in
order
to
be
able
to
define
label
language
using
a
risk­
based
approach.
In
addition,
the
minimal
level
of
adequate
protection
for
a
chemical
is
generally
considered
by
HED
to
be
the
most
practical
option
for
risk
reduction
(
i.
e.,
over­
burdensome
risk
mitigation
measures
are
not
considered
a
practical
alternative).

2.1.1
Data
and
Assumptions
For
Handler
Exposure
Scenarios
2.1.1.1
Assumptions
for
Handler
Exposure
Scenarios
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
occupational
handler
risk
assessments.
Each
assumption
and
factor
is
detailed
below
on
an
individual
basis.
The
assumptions
and
factors
used
in
the
risk
calculations
include:

C
Occupational
handler
exposure
estimates
were
based
on
surrogate
data
from:
(
1)
the
Pesticide
Handlers
Exposure
Database
(
PHED),
and
(
2)
Outdoor
Residential
Exposure
Task
Force
(
ORETF).

C
Average
body
weight
of
an
adult
handler
is
70
kg
because
the
toxicity
endpoint
values
used
for
the
assessments
are
appropriate
for
average
adult
body
weight
representing
the
general
population.
This
is
the
case
because
none
of
the
effects
identified
in
the
selected
toxicity
studies
were
sex
specific.

C
Exposure
factors
used
to
calculate
daily
exposures
to
handlers
are
based
on
applicable
data
if
available.
For
lack
of
appropriate
data,
values
from
a
scenario
deemed
similar
enough
by
the
assessor
might
be
used.
As
an
example,
for
sodium
chlorate
handler
exposures,
ORETF
data
for
hose­
end
sprayer
equipment
were
used
to
assess
sprinkling
can
applications.
The
nature
of
these
application
methods
are
believed
to
be
similar
enough
to
bridge
the
data.

C
HED
always
considers
the
maximum
application
rates
allowed
by
labels
in
its
risk
assessments.
If
additional
information
such
as
a
different
range
of
rates
are
available,
these
values
also
may
be
used
to
allow
risk
managers
to
make
a
more
informed
risk
12
management
decision.

C
The
typical
occupational
workday
is
assumed
to
be
8
hours.

C
The
daily
area
treated
was
defined
for
each
handler
scenario
(
in
appropriate
units)
by
determining
the
amount
that
can
be
reasonably
treated
in
a
single
day
(
e.
g.
acres,
square
feet,
or
gallons
per
day).
When
possible,
the
assumptions
for
daily
areas
treated
is
taken
from
ExpoSAC
SOP
#
9:
Standard
Values
for
Daily
Acres
Treated
in
Agriculture
which
was
completed
on
July
5,
2000.
Assumptions
for
these
scenarios,
including
further
refinements
based
on
HED
estimates,
are
listed
below.

Agricultural
Scenarios
S
Aerial
applications:
350
acres
(
typical
field
crop
assumption)
for
guar
beans,
southern
peas,
chili
peppers
(
for
processing
only),
potatoes,
ornamental
gourds,
and
cucurbits
(
grown
for
seed);
1200
acres
(
high
acreage
crop
assumption)
for
cotton,
corn,
rice,
dry
beans,
sorghum,
flax,
safflower,
sunflower,
soybeans,
wheat,
and
fallow
land.

S
Groundboom:
80
acres
(
typical
field
crop
assumption)
for
guar
beans,
southern
peas,
chili
peppers
(
for
processing
only),
potatoes,
ornamental
gourds,
and
cucurbits
(
grown
for
seeds);
200
acres
(
high
acreage
crop
assumption)
for
cotton,
corn,
rice,
dry
beans,
sorghum,
flax,
safflower,
sunflower,
soybeans,
wheat
and
fallow
land.

S
Flaggers:
350
acres.

Refinements
into
"
typical
field"
and
"
high
acreage"
crops
was
performed
with
help
from
HED
crop
expert
Bernard
Schneider
(
email
from
B.
Schneider,
5/
24/
04).

Industrial/
Non­
Crop
Sites
S
Rights­
of­
Way
Sprayer
and
Handgun
Sprayer:
5
acres
per
day;

S
Low
Pressure
Handwand
Sprayer:
2
acres
per
day;

Note:
Although
assessments
for
applications
involving
rights­
of­
way
sprayers
and
low
pressure
handwands
typically
use
a
volume­
based
approach
for
amount
handled/
treated
per
day
(
1000
gallons
and
40
gallons,
respectively,
from
ExpoSAC
Policy
#
9),
label­
specific
application
rates
and
their
respective
dilution
factors
for
larger
application
settings
are
better
represented
by
a
daily
unit
area
treated
than
a
volume
based
approach.
For
example,
the
label­
specific
application
of
8
pints
per
100
square
feet
[
EPA
Reg.
No.
7701­
34]
yields
the
application
rate
of
1032
lb
ai
in
2196
gallons
of
solution
per
acre.
At
this
rate,
the
volume­
based
approach
of
1000
gallons
per
day
would
have
a
worker
treating
approximately
½
acres
per
day.
Because
a
rights­
of­
way
sprayer
would
likely
treat
more
than
½
acre
per
day,
a
daily
unit
area
of
5
acres
was
used
as
a
more
appropriate
estimate.
13
S
Belly
grinder:
1
acre
per
day.

S
Push­
type
spreader:
5
acres
per
day
S
Groundboom
and
Tractor­
drawn
Spreader:
40
acres
per
day.

2.1.1.2
Exposure
Data
for
Handler
Exposure
Scenarios
For
sodium
chlorate
handler
exposure
assessments,
all
analyses
were
completed
using
data
that
were
deemed
to
be
a
source
of
acceptable
surrogate
exposure
data
for
the
scenario
in
question.

HED
uses
a
concept
known
as
unit
exposure
as
the
basis
for
the
scenarios
used
to
assess
handler
exposures
to
pesticides.
Unit
exposures
numerically
represent
the
exposures
one
would
receive
related
to
an
application.
They
are
generally
presented
as
(
mg
active
ingredient
exposure/
pounds
of
active
ingredient
handled).
HED
has
developed
a
series
of
unit
exposures
that
are
unique
for
each
scenario
typically
considered
in
our
assessments
(
i.
e.,
there
are
different
unit
exposures
for
different
types
of
application
equipment;
job
functions;
and
levels
of
protection).
The
unit
exposure
concept
has
been
established
in
the
scientific
literature
and
also
through
various
exposure
monitoring
guidelines
published
by
the
U.
S.
EPA
and
international
organizations
such
as
Health
Canada
and
OECD
(
Organization
For
Economic
Cooperation
and
Development).
The
concept
of
using
unit
exposures
as
surrogate
data
for
different
chemicals
can
be
illustrated
by
the
following
example.
If
an
individual
makes
an
application
using
a
lowpressure
sprayer
with
either
10
pounds
of
chemical
A
or
10
pounds
of
chemical
B
using
the
same
clothing
and
personal
protective
equipment,
the
exposures
to
chemicals
A
and
B
would
be
similar.

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

Users
select
criteria
to
subset
the
PHED
database
to
reflect
the
exposure
scenario
being
evaluated.
The
subsetting
algorithms
in
PHED
are
based
on
the
central
assumption
that
the
magnitude
of
handler
exposures
to
pesticides
are
primarily
a
function
of
activity
(
e.
g.,
mixing/
loading,
applying),
formulation
type
(
e.
g.,
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
(
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
14
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
exposures
calculated
by
PHED
generally
range
from
the
geometric
mean
to
the
median
of
the
selected
data
set.
To
add
consistency
and
quality
control
to
the
values
produced
from
this
system,
the
PHED
Task
Force
has
evaluated
all
data
within
the
system
and
has
developed
a
set
of
grading
criteria
to
characterize
the
quality
of
the
original
study
data.
The
assessment
of
data
quality
is
based
on
the
number
of
observations
and
the
available
quality
control
data.
While
data
from
PHED
provide
the
best
available
information
on
handler
exposures,
it
should
be
noted
that
some
aspects
of
the
included
studies
(
e.
g.,
duration,
acres
treated,
pounds
of
active
ingredient
handled)
may
not
accurately
represent
labeled
uses
in
all
cases.
HED
has
developed
the
PHED
Surrogate
Exposure
Guide
which
is
a
series
of
tables
of
standard
unit
exposures
for
many
occupational
scenarios
that
can
be
utilized
to
ensure
consistency
in
exposure
assessments.
Unit
exposures
are
used
which
represent
different
levels
of
personal
protection
as
described
above.
Protection
factors
were
used
to
calculate
unit
exposures
for
varying
levels
of
personal
protection
if
data
were
not
available.

ORETF
Handler
Studies
(
MRID
44972201):
A
report
was
submitted
by
the
ORETF
that
presented
data
in
which
the
application
of
various
products
used
on
turf
by
homeowners
and
lawncare
operators
(
LCOs)
was
monitored.
All
of
the
data
submitted
in
this
report
were
completed
in
a
series
of
studies.
The
study
that
monitored
LCO
exposure
using
a
low
pressure,
high
volume
turf
handgun
(
ORETF
Study
OMA002)
is
summarized
below
as
is
the
study
that
monitored
LCO
exposure
scenarios
using
a
push
cyclone
granular
spreader
(
ORETF
Study
OMA001).

LCO
Handgun
Sprayer:
A
mixer/
loader/
applicator
study
was
performed
by
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF)
using
Dacthal
as
a
surrogate
compound
to
determine
"
generic"
exposures
to
individuals
applying
a
pesticide
to
turf
with
a
low­
pressure
"
nozzle
gun"
or
"
handgun"
sprayer.
Dermal
and
inhalation
exposures
were
estimated
using
whole­
body
passive
dosimeters
and
breathing­
zone
air
samples
on
OVS
tubes.
Inhalation
exposure
was
calculated
using
an
assumed
respiratory
rate
of
17
liters
per
minute
for
light
work
(
NAFTA,
1999),
the
actual
sampling
time
for
each
individual,
and
the
pump
flow
rate.
All
results
were
normalized
for
pounds
active
ingredient
handled.
A
total
of
90
replicates
were
monitored
using
17
different
subjects.
Four
different
formulations
of
dacthal
[
75%
wettable
powder
(
packaged
in
4
and
24
pound
bags),
75%
wettable
powder
in
water
soluble
bags
(
3
pound
bag),
75%
water
dispersable
granules
(
2
pound
bag)
and
55%
liquid
flowable
(
2.5
gallon
container)]
were
applied
by
five
different
LCOs
to
actual
residential
lawns
at
each
site
in
three
different
locations
(
Ohio,
Maryland,
and
Georgia)
for
a
total
of
fifteen
replicates
per
formulation.
An
additional
ten
replicates
at
each
site
were
monitored
while
they
performed
spray
application
only
using
the
75
percent
wettable
powder
formulation.
A
target
application
rate
of
2
pounds
active
ingredient
was
used
for
all
15
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
thirtynine
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
exposures
are
presented
in
Table
4
below.

Table
4:
ORETF
LCO
Exposure
Study
Data
Summary
(
MRID
44972201):
Handgun
Sprayer
Application
Method
Inhalation
Unit
Exposure
(
µ
g/
lb
ai)
1
LCO
Handgun
Spray
Mixer/
Loader/
Applicator
Liquid
Flowable
1.8
1Air
concentration
(
mg/
m3/
lb
ai)
calculated
using
NAFTA
`
99
standard
breathing
rate
of
17
lpm
(
1
m3/
hr)

LCO
Push
Cyclone
Granular
Spreader:
A
loader/
applicator
study
was
performed
by
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF)
using
Dacthal
(
active
ingredient
DCPA,
dimethyl
tetrachloroterephthalate)
as
a
surrogate
compound
to
determine
"
generic"
exposures
of
lawn
care
operators
(
LCOs)
applying
a
granular
pesticide
formulation
to
residential
lawns.
Surrogate
chemicals
were
chosen
by
the
Task
Force
for
their
representativeness
based
on
physical
chemical
properties
and
other
factors.
Dacthal,
which
was
the
surrogate
chemical
used
for
the
granular
spreader
and
low­
pressure
hand
gun
sprayer
studies,
has
a
molecular
weight
of
331.97
and
a
vapor
pressure
of
1.6
x
10­
6
mm
Hg,
and
is
believed
to
be
an
appropriate
surrogate
for
many
relatively
nonvolatile
pesticides.
The
study
was
designed
to
simulate
a
typical
work
day
for
a
LCO
applying
granular
pesticide
formulation
to
home
lawns.
Each
LCO
replicate
loaded
and
applied
approximately
3.3
lb
ai
(
360
lb
formulated
product)
over
a
period
of
about
4
hours
to
15
simulated
residential
lawns
(
6480
ft2
each)
with
a
rotary
type
spreader.
The
average
industry
application
rate
of
2
lb
ai/
acre
was
simulated
(
actual
rate
achieved
was
about
1.9
lb
ai/
acre).
The
monitoring
period
included
simulated
driving,
placing
the
spreader
onto
and
off
of
the
truck,
carrying
and
loading
the
formulation
in
the
spreader,
and
the
actual
application.
Incidental
activities
such
as
repairs,
cleaning
up
spills,
and
disposing
of
empty
bags
were
monitored.
16
A
total
of
40
replicates
(
individual
test
subjects)
were
monitored
using
passive
dosimetry
(
inner
and
outer
whole
body
dosimeters,
hand
washes,
face/
neck
wipes,
and
personal
inhalation
monitors
with
OVS
tubes).
Inhalation
exposure
was
calculated
using
an
assumed
respiratory
rate
of
17
Lpm
(
1
m3/
hr)
for
light
work
(
NAFTA,
1999),
the
actual
sampling
time
for
each
individual,
and
the
pump
flow
rate.
All
results
were
normalized
for
lb
ai
handled.
Twelve
professional
lawn
care
operators
(
LCO)
participated
in
the
study.
Ten
individuals
per
day
(
20
per
site)
were
monitored
over
4
days
at
2
different
sod
farms
near
Columbus,
Ohio.
Each
replicate
consisted
of
a
LCO
loading
and
applying
approximately
3.3
lb
ai
/
360
lb
formulated
product
(
1.5
kg
ai/
163
kg
formulated
product)
to
15
simulated
residential
lawns,
for
an
approximate
total
duration
of
4
hours
and
total
area
of
2.2
acres
(
0.9
ha).
Twenty
test
subjects
wore
chemical­
resistant
gloves
during
all
loading
and
application
activities
and
moving
the
spreader
on
and
off
the
truck,
then
removed
and
place
the
gloves
in
the
truck
during
simulated
driving
time.
The
other
twenty
test
subjects
did
not
wear
gloves
during
any
activity.
Each
test
subject
wore
long
sleeve
cotton
shirts
and
pants
over
one­
piece
cotton
inner
dosimeters.
Both
outer
and
inner
dosimeters
were
analyzed
to
estimate
potential
exposure
for
a
number
of
clothing
scenarios.
Unit
exposures
for
the
granular
push
spreader
are
presented
in
Table
5
below.

Table
5:
ORETF
LCO
Exposure
Study
Data
Summary
(
MRID
44972201):
Granular
Spreader
Application
Method
Inhalation
Unit
Exposure
(
µ
g/
lb
ai)
1
LCO
Push
Cyclone
Granular
Spreader
7.3
1Air
concentration
(
mg/
m3/
lb
ai)
calculated
using
NAFTA
`
99
standard
breathing
rate
of
17
lpm
(
1
m3/
hr)

2.1.2
Sodium
Chlorate
Handler
Exposure
Scenarios
It
has
been
determined
that
exposure
to
pesticide
handlers
is
likely
during
the
occupational
use
of
sodium
chlorate
in
a
variety
of
occupational
environments.
The
anticipated
use
patterns
and
current
labeling
indicate
several
occupational
exposure
scenarios
based
on
the
types
of
equipment
and
techniques
that
can
potentially
be
used
for
sodium
chlorate
applications.
The
quantitative
exposure/
risk
assessment
developed
for
occupational
handlers
is
based
on
the
following
scenarios.
[
Note:
The
scenario
numbers
correspond
to
Table
6:
Sodium
Chlorate
­
Short
and
Intermediate
Term
Occupational
Inhalation
Exposure.]

Mixer/
Loaders:
(
1a)
Liquids
for
Aerial
Applications;
(
1b)
Liquids
for
Groundboom
Applications;
(
1c)
Liquids
for
Rights­
of­
Way
Sprayer
Applications;
(
2)
Granules
for
Tractor­
drawn
Broadcast
Spreader
Applications;

Applicators:
(
3a)
Sprays
via
aerial
equipment
(
Enclosed
cockpit);
(
3b)
Sprays
via
Groundboom
(
Open
cab);
17
(
3c)
Sprays
via
Rights­
of­
Way
Sprayer;
(
4)
Granules
via
Tractor­
drawn
Broadcast
Spreader
(
Open
cab);

Flaggers:
(
5)
Flagging
for
Aerial­
Sprays;

Mixer/
Loader/
Applicators
&
Loader/
Applicators:
(
6)
Liquid:
Low
Pressure
Handwand
Sprayer;
(
7)
Liquid:
Handgun
Sprayer;
(
8)
Granulars:
Belly
Grinder;
(
9)
Granulars:
Push­
type
Spreader.

2.1.3
Non­
cancer
Sodium
Chlorate
Handler
Exposure
and
Assessment
The
occupational
handler
exposure
and
non­
cancer
risk
calculations
are
presented
in
this
section.
(
See
Appendix
2
for
sodium
chlorate
exposure
calculation
spreadsheets.)

2.1.3.1
Non­
cancer
Sodium
Chlorate
Handler
Exposure
and
Risk
Calculations
Non­
cancer
risks
were
calculated
using
the
Margin
of
Exposure
(
MOE)
which
is
a
ratio
of
the
daily
dose
to
the
toxicological
endpoint
of
concern.
Daily
dose
values
are
calculated
by
first
calculating
exposures
by
considering
application
parameters
(
i.
e.,
rate
and
area
treated)
along
with
unit
exposures.
Exposures
were
then
normalized
by
body
weight
and
adjusted
for
absorption
factors
as
appropriate
to
calculate
dose
levels.
Then
MOEs
were
calculated.

Daily
Exposure:
The
daily
exposure
and
daily
dose
to
handlers
were
calculated
as
described
below.
The
first
step
was
to
calculate
daily
inhalation
exposure
using
the
following
formula:

Where:

Daily
Exposure
=
Amount
(
mg
ai/
day)
inhaled
that
is
available
for
inhalation
absorption;
Unit
Exposure
=
Unit
exposure
value
(
mg
ai/
lb
ai)
derived
from
August
1998
PHED
data
or
ORETF
data
Application
Rate
=
Normalized
application
rate
based
on
a
logical
unit
treatment,
such
as
acres,
square
feet,
or
gallons.
Maximum
values
are
generally
used
(
lb
ai/
A,
lb
ai/
sq
ft,
lb
ai/
gal);
and
Daily
Area
Treated
=
Normalized
application
area
based
on
a
logical
unit
treatment
such
as
acres
(
A/
day),
square
feet
(
sq
ft/
day),
or
gallons
per
day
(
gal/
day).

Daily
Dose:
Daily
dose
(
inhalation)
was
calculated
by
normalizing
the
daily
inhalation
exposure
value
by
body
weight
and
accounting
for
inhalation
absorption.
For
adult
handlers
using
18
sodium
chlorate,
an
average
body
weight
of
70
kilograms
was
used
for
all
exposure
scenarios.
Since
the
inhalation
toxicological
endpoint
of
concern
is
based
on
an
oral
study,
the
inhalation
absorption
factor
is
100%
(
HED
assumption).
Daily
dose
was
calculated
using
the
following
formula:

Where:

Average
Daily
Dose
=
Absorbed
dose
received
from
exposure
to
a
pesticide
in
a
given
scenario
(
mg
pesticide
active
ingredient/
kg
body
weight/
day);
Daily
Exposure
=
Amount
(
mg
ai/
day)
inhaled
that
is
available
for
inhalation
absorption;
Absorption
Factor
=
A
measure
of
the
amount
of
chemical
that
crosses
a
biological
boundary
such
as
the
skin
or
lungs
(%
of
the
total
available
absorbed);
and
Body
Weight
=
Body
weight
determined
to
represent
the
population
of
interest
in
a
risk
assessment
(
kg).

Margins
of
Exposure:
Finally,
the
calculations
of
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.
All
MOEs
were
calculated
for
inhalation
exposure
levels
using
the
formula
below:

Where:

MOE
=
Margin
of
exposure,
value
used
by
HED
to
represent
risk
or
how
close
a
chemical
exposure
is
to
being
a
concern
(
unitless);
ADD
=
(
Average
Daily
Dose)
or
the
amount
as
absorbed
dose
received
from
exposure
to
a
pesticide
in
a
given
scenario
(
mg
pesticide
active
ingredient/
kg
body
weight/
day);
and
NOAEL
=
Dose
level
in
a
toxicity
study,
where
no
observed
adverse
effects
occurred
(
NOAEL)
in
the
study
2.1.3.2
Sodium
Chlorate
Non­
cancer
Risk
Summary
All
of
the
non­
cancer
risk
calculations
for
occupational
sodium
chlorate
handlers
completed
in
this
assessment
are
included
in
Appendix
2.
A
summary
of
the
short­
and
intermediate­
term
risks
for
each
exposure
scenario
are
presented
in
Table
6.

Short­
and
Intermediate­
term
Inhalation
Risks
Risk
for
most
occupational
handler
baseline
(
without
a
respirator)
inhalation
exposure
19
scenarios
do
not
exceed
HED's
level
of
concern
of
100
(
i.
e,
most
scenarios
had
MOEs
>
100)
at
the
baseline
level
of
worker
protection.
However,
risks
for
the
following
occupational
scenarios
did
exceed
HED's
level
of
concern
at
baseline.

°
Mixing/
Loading
liquids
for
groundboom
application
to
industrial/
non­
crop
sites
at
1032
lb
ai
per
acre
(
MOE
=
42)
and
523
lb
ai
per
acre
(
MOE
=
84);
°
Loading
granules
for
tractor­
drawn
spreader
applications
to
industrial/
non­
crop
sites
at
523
lb
ai
per
acre
(
MOE
=
59);
°
Applying
sprays
to
industrial/
non­
crop
sites
using
groundboom
equipment
(
open
cab)
at
1032
lb
ai
per
acre
(
MOE
=
69);
°
Applying
granules
to
industrial/
non­
crop
sites
using
a
tractor­
drawn
spreader
(
open
cab)
at
523
lb
ai
per
acre
(
MOE
=
84);
°
Loading/
Applying
granules
to
industrial/
non­
crop
sites
using
a
belly
grinder
at
523
lb
ai
per
acre
(
MOE
=
65);
and
°
Mixing/
Loading/
Applying
liquids
for
low
pressure
handwand
applications
to
industrial/
non­
crop
sites
at
1032
lb
ai
per
acre
(
MOE
=
34)
and
523
lb
ai
per
acre
(
MOE
=
67).

Risk
mitigation
for
these
scenarios
was
accomplished
with
the
addition
of
a
dust/
mist
respirator
(
with
an
80%
reduction
factor),
or,
for
certain
scenarios,
with
engineering
controls
(
enclosed
cabs
or
cockpits).
Additionally,
risks
were
mitigated
for
certain
scenarios,
without
the
application
of
PPE
or
engineering
controls,
by
using
the
lower
application
rates.
Most
risks
of
concern
were
at
the
high
end
of
application
rate
ranges
(
1032
and
523
lb
ai
per
acre),
whereas
at
lower
rates
the
risks
were
not
of
concern
(
MOEs
>
100
at
lower
application
rates).
20
Table
6:
Sodium
Chlorate:
Short­
and
Intermediate­
Term
Occupational
Inhalation
Exposure
Exposure
Scenario
(
Scenario
#)
Daily
Area
Treated1
Crop/
Target2
Application
Rate3
Inhalation
MOE4
Mitigation
Level5
Mixer/
Loader
Mixing/
Loading
liquids
for
Aerial
application
(
1a)
1200
Cotton,
Corn,
Rice,
Dry
Beans,
Grain
Sorghum,
Flax,

Safflower,
Sunflower,
Soybeans
7.5
190
Baseline
Fallow
Land,
Wheat
6
240
Baseline
350
Chili
Peppers
(
for
processing
only),
Potatoes
12.5
400
Baseline
Ornamental
Gourds,
Cucurbits
(
grown
for
seed)
6
830
Baseline
Guar
Beans,
Southern
Peas
7.5
670
Baseline
Mixing/
Loading
liquids
for
Groundboom
application
(
1b)
200
Cotton,
Corn,
Rice,
Dry
Beans,
Grain
Sorghum,
Flax,

Safflower,
Sunflower,
Soybeans
7.5
1200
Baseline
Fallow
Land,
Wheat
6
1500
Baseline
80
Chili
Peppers
(
for
processing
only),
Potatoes
12.5
1800
Baseline
Ornamental
Gourds,
Cucurbits
(
grown
for
seed)
6
3600
Baseline
Guar
Beans,
Southern
Peas
7.5
2900
Baseline
40
Industrial/
Non­
Crop
Sites
1032
210
PPE
­
80%
R
523
420
PPE
­
80%
R
132
330
Baseline
Mixing/
Loading
liquids
for
Rights­
of­

Way
Sprayer
application
(
1c)
5
Rights­
of­
Way
&
Industrial/
Non­
Crop
Sites
1032
340
Baseline
523
670
Baseline
132
2700
Baseline
Loading
granules
for
Tractor­
drawn
Spreader
application
(
2)
40
Industrial/
Non­
Crop
Sites
523
300
PPE
­
80%
R
240
130
Baseline
161
190
Baseline
Applicator
Aerial
spray
applications
(
3a)
1200
Cotton,
Corn,
Rice,
Dry
Beans,
Grain
Sorghum,
Flax,

Safflower,
Sunflower,
Soybeans
7.50
3400
Engineering
Control
Exposure
Scenario
(
Scenario
#)
Daily
Area
Treated1
Crop/
Target2
Application
Rate3
Inhalation
MOE4
Mitigation
Level5
21
Fallow
Land,
Wheat
6
4300
Engineering
Control
350
Guar
Beans,
Southern
Peas
7.5
12000
Engineering
Control
Chili
Peppers
(
for
processing
only),
Potatoes
12.5
7100
Engineering
Control
Ornamental
Gourds,
Cucurbits
(
grown
for
seed)
6
15000
Engineering
Control
Groundboom
spray
applications
(
3b)
1200
Cotton,
Corn,
Rice,
Dry
Beans,
Grain
Sorghum,
Flax,

Safflower,
Sunflower,
Soybeans
7.5
1900
Baseline
Fallow
Land,
Wheat
6
2400
Baseline
350
Guar
Beans,
Southern
Peas
7.5
4700
Baseline
Chili
Peppers
(
for
processing
only),
Potatoes
12.5
2800
Baseline
Ornamental
Gourds,
Cucurbits
(
grown
for
seed)
6
5900
Baseline
40
Industrial/
Non­
Crop
Sites
1032
350
PPE
­
80%
R
1200
Engineering
Control
523
140
Baseline
2300
Engineering
Control
132
540
Baseline
9200
Engineering
Control
Rights­
of­
Way
Sprayer
Applications
(
3c)
5
Rights­
of­
Way
&
Industrial/
Non­
Crop
Sites
1032
110
Baseline
523
210
Baseline
132
820
Baseline
Tractor­
drawn
Spreader
Applications
(
4)
40
Industrial/
Non­
Crop
Sites
523
420
PPE
­
80%
R
460
Engineering
Control
240
180
Baseline
990
Engineering
Control
161
270
Baseline
Exposure
Scenario
(
Scenario
#)
Daily
Area
Treated1
Crop/
Target2
Application
Rate3
Inhalation
MOE4
Mitigation
Level5
22
1500
Engineering
Control
Flagger
Flagging
for
Aerial
Spray
applications
(
5)
350
Various
Agricultural
Crops
12.5
1400
Baseline
Mixer/
Loader/
Applicators
&
Loader/
Applicators
M/
L/
A
liquids
with
a
Low
Pressure
Handwand
Sprayer
(
6)
2
Industrial/
Non­
Crop
Sites
1032
170
PPE
­
80%
R
523
330
PPE
­
80%
R
132
270
Baseline
M/
L/
A
liquids
with
a
Handgun
Sprayer
(
7)
5
Industrial/
Non­
Crop
Sites
1032
230
Baseline
523
450
Baseline
132
1800
Baseline
L/
A
granules
with
a
Belly
Grinder
(
8)
1
Industrial/
Non­
Crop
Sites
523
320
PPE
­
80%
R
240
140
Baseline
161
210
Baseline
L/
A
granules
with
a
Push­
type
Spreader
(
9)
5
Industrial/
Non­
Crop
Sites
523
110
Baseline
240
240
Baseline
161
360
Baseline
1
Amount
treated
is
presented
in
acres/
day.
(
Standard
EPA/
OPP/
HED
values).

2
Crops
and
use
patterns
are
from
label
extractions
(
Appendix
1),
BEAD's
LUIS
reports,
and
the
Sodium
Chlorate
Use
Closure
Memo
(
J.
Guerry,
8/
5/
04;
10/
13/
04;
11/
15/
04).

3
Ranges
of
application
rates
are
based
on
values
from
label
extractions
(
Appendix
1),
BEAD's
LUIS
reports,
and
the
Sodium
Chlorate
Use
Closure
Memo
(
J.
Guerry,
8/
5/
04;
10/
13/
04;

11/
15/
04).
Application
rates
upon
which
the
analysis
is
based
are
presented
as
lb
ai/
acre.

4
Inhalation
MOE
=
Oral
NOAEL
(
30
mg/
kg/
day)
/
Daily
Inhalation
Dose.
HED
LOC
for
MOE
is
100.

5
Mitigation
Levels
Baseline:
No
respirator
PPE
­
80%
R:
Dust/
mist
respirator
with
an
80%
reduction
factor
Engineering
Control:
Closed
cockpit
or
cab
23
3.0
Residential
Exposures
and
Risks
It
has
been
determined
there
is
a
potential
for
exposure
in
residential
settings
during
the
application
process
for
homeowners
who
use
products
containing
sodium
chlorate,
however
a
postapplication
exposure
assessment
was
not
performed.
This
risk
assessment
was
only
completed
for
residential
handlers.

3.1
Residential
Handler
Exposures
and
Risks
HED
uses
the
term
"
handlers"
to
describe
those
individuals
who
are
involved
in
the
pesticide
application
process.
HED
believes
that
there
are
distinct
tasks
related
to
applications
and
that
exposures
can
vary
depending
on
the
specifics
of
each
task
as
was
described
above
for
occupational
handlers.
Residential
handlers
are
addressed
somewhat
differently
by
HED
as
homeowners
are
assumed
to
complete
all
elements
of
an
application
without
use
of
any
protective
equipment.

3.1.1
Handler
Exposure
Scenarios
Scenarios
are
used
to
define
risks
based
on
the
U.
S.
EPA
Guidelines
For
Exposure
Assessment
(
U.
S.
EPA;
Federal
Register
Volume
57,
Number
104;
May
29,
1992).
Assessing
exposures
and
risks
resulting
from
residential
uses
is
very
similar
to
assessing
occupational
exposures
and
risks,
with
the
following
exceptions:

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

C
A
tiered
approach
for
personal
protection
using
increasing
levels
of
PPE
is
not
used
in
residential
handler
risk
assessments.
Homeowner
handler
assessments
are
based
on
the
assumption
that
individuals
are
wearing
shorts,
short­
sleeved
shirts,
socks,
and
shoes;

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

C
Label
use­
rates
and
use­
information
specific
to
residential
products
serve
as
the
basis
for
the
risk
calculations;
and
C
Area/
volumes
of
spray
or
chemical
used
in
the
risk
assessment
are
based
on
HED's
guidance
specific
to
residential
use­
patterns.

It
has
been
determined
that
exposure
to
pesticide
handlers
is
likely
during
the
residential
use
of
sodium
chlorate
in
outdoor
environments
as
a
spot
treatment
or
edging
treatment
around
patios,
along
fence
lines,
lawn
edges,
around
foundations,
underneath
or
around
wood
decks,
and
in
cracks
and
crevices
of
driveways.
The
anticipated
use
patterns
and
current
labeling
indicate
24
seven
major
residential
exposure
scenarios
based
on
the
types
of
equipment
and
techniques
that
can
potentially
be
used
to
make
sodium
chlorate
applications.
The
quantitative
exposure/
risk
assessment
developed
for
residential
handlers
is
based
on
these
scenarios.
[
Note:
The
scenario
numbers
correspond
to
Table
10:
Sodium
Chlorate
­
Short
Term
Residential
Inhalation
Exposure.]

Mixer/
Loader/
Applicators,
Loader/
Applicators,
&
Applicators:
(
1)
Liquid:
Low
Pressure
Handwand;
(
2)
RTU
Liquid:
Trigger
Pump
Sprayer;
(
3)
Liquid:
Sprinkler
Can;
(
4)
RTU
One­
gallon,
Pre­
packaged
Sprinkler
Can;
(
5)
Granulars:
Hand;
(
6)
Granulars:
Belly
Grinder;
(
7)
Granulars:
Push­
type
Spreader.

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
exposures
were
used
to
calculate
risk
estimates.
Unit
exposures
were
taken
from
PHED,
ORETF
studies,
and
one
proprietary
study.
The
ORETF
studies
and
the
proprietary
study
are
presented
below.
[
Note:
Several
of
the
assumptions
and
factors
used
for
the
assessment
are
similar
to
those
used
in
the
occupational
assessment
presented
above.
As
such,
only
factors
that
are
unique
to
the
residential
scenarios
are
presented
below.]

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

C
Due
to
the
lack
of
chemical
specific
data,
exposures
from
a
scenario
deemed
similar
might
be
used.
As
an
example,
mixer/
loader/
applicator
data
for
hose­
end
sprayers
were
used
to
assess
sprinkler
can
applications.
These
application
methods
are
believed
to
be
similar
enough
to
bridge
the
data.

C
HED
always
considers
the
maximum
application
rates
allowed
by
labels
in
its
risk
assessments.
If
additional
information
such
as
average
or
typical
rates
are
available,
these
values
also
may
be
used
to
allow
risk
managers
to
make
a
more
informed
risk
management
decision.

C
Residential
risk
assessments
are
based
on
estimates
of
what
homeowners
would
typically
treat,
such
as
the
size
of
a
lawn,
or
the
size
of
a
garden.
The
factors
used
for
the
sodium
chlorate
assessment
were
from
the
Health
Effects
Division
Science
Advisory
Council
for
Exposure
Policy
12:
Recommended
Revisions
To
The
Standard
Operating
Procedures
For
Residential
Exposure
Assessment
which
was
completed
on
February
22,
2001
and
on
25
professional
judgement.
The
daily
volumes
handled
and
area
treated,
used
in
each
residential
scenario,
include:

C
1000
square
feet
when
mixing/
loading/
applying
liquids
as
a
spot
treatment
with
a
low­
pressure
handwand
and
sprinkler
cans;

C
1
gallon
when
applying
with
a
RTU
sprinkler
can
and
trigger
pump
sprayer;
and,

C
1000
square
feet
for
granular
formulation
spot
treatments.

Residential
Handler
Exposure
Studies:
The
unit
exposures
that
were
used
in
this
assessment
were
based
on
PHED,
ORETF
studies,
and
one
proprietary
study.

ORETF
Handler
Studies
(
MRID
44972201):
A
report
was
submitted
by
the
ORETF
that
presented
data
in
which
the
application
of
various
products
used
on
turf
by
homeowners
and
LCOs
was
monitored.
All
of
the
data
submitted
in
this
report
were
completed
in
a
series
of
studies.

Homeowner
Hose
End
Sprayer:
A
mixer/
loader/
applicator
study
was
performed
by
the
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
exposures
are
presented
below.
[
Note
the
data
were
found
to
be
lognormally
distributed.
As
a
result,
all
exposure
values
are
geometric
means.]

Table
7:
ORETF
Resident­
Applicator
Exposure
Study
Data
Summary
(
MRID
44972201)
­
Hose­
end
Sprayer
Type
Inhalation
(
µ
g/
lb
ai
handled)
1
Hose­
end
Sprayer
(
Mix­
your­
own)
17
Hose­
end
Sprayer
11
Table
7:
ORETF
Resident­
Applicator
Exposure
Study
Data
Summary
(
MRID
44972201)
­
Hose­
end
Sprayer
Type
Inhalation
(
µ
g/
lb
ai
handled)
1
26
(
ready­
to­
use)

All
unit
exposures
are
geometric
means.

1Air
concentration
(
mg/
lb
ai)
calculated
using
NAFTA
`
99
standard
breathing
rate
of
17
lpm
(
1
m3/
hr).

Homeowner
Push­
Type
Spreader
(
OMA003):
A
mixer/
loader/
applicator
study
was
performed
by
the
ORETF
using
Dacthal
(
active
ingredient
DCPA,
dimethyl
tetrachloroterephthalate)
as
a
surrogate
compound
to
determine
"
generic"
exposures
of
individuals
applying
a
granular
pesticide
formulation
to
residential
lawns.
A
total
of
30
volunteers
were
monitored
using
passive
dosimetry
(
inner
and
outer
whole
body
dosimeters,
hand
washes,
face/
neck
wipes,
and
personal
inhalation
monitors).
Each
volunteer
carried,
loaded,
and
applied
two
25­
lb
bags
of
fertilizer
and
pesticide
granules
(
0.89%
active
ingredient)
with
a
rotary
type
spreader
to
a
lawn
covering
10,000
ft2.
The
target
application
rate
was
2
lb
ai/
acre
(
actual
rate
achieved
was
about
1.9
lb
ai/
acre).
The
average
application
time
was
22
minutes,
including
loading
the
rotary
push
spreader
and
disposing
of
the
empty
bags.
Each
replicate
handled
approximately
0.45
lb
ai.
The
study
results
are
normalized
to
kg
ai
handled.
The
US
EPA
HED
typically
assumes
that
residential
applicators
wear
short
pants
and
short­
sleeved
shirts,
as
described
in
the
Residential
SOPs
(
1997).
Therefore,
the
table
reports
the
dermal
exposures
for
the
short
pants
and
short­
sleeve
shirt
clothing
scenario
only.

Table
8:
ORETF
Resident­
Applicator
Exposure
Study
Data
Summary
(
MRID
44972201)
­
Push
Spreader
Type
Inhalation
(
µ
g
ai/
lb
handled)

Push­
Type
Spreader
0.88
Proprietary
Studies
One
proprietary
study
was
used
to
obtain
unit
exposures
for
handlers
applying
ready­
touse
liquid
formulations
via
trigger
pump
sprayer.
This
study
is
summarized
below:

EPA
MRID
41054701
(
Propoxur
trigger
pump
sprayer
study):
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
27
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
are
presented
below
in
Table
8.

Table
9:
Propoxur
Trigger
Pump
Sprayer
Study
(
MRID
41054701)

Type
Inhalation
(
µ
g
ai/
lb
handled)

Trigger
Pump
Sprayer
123
3.1.3
Residential
Handler
Exposure
and
Non­
Cancer
Risk
Estimates
The
residential
handler
exposure
and
non­
cancer
risk
calculations
are
presented
in
this
section.
Noncancer
risks
were
calculated
using
the
Margin
of
Exposure
(
MOE)
as
described
in
Section
2.1.3.
Assessing
exposures
and
risks
resulting
from
residential
uses
is
very
similar
to
assessing
occupational
exposures
and
risks,
except
as
described
above
in
Section
3.1.1.
The
other
major
difference
with
residential
risk
assessments
is
that
the
uncertainty
factor
which
defines
the
level
of
risk
concern
has
the
additional
FQPA
safety
factor
applied.
In
the
case
of
sodium
chlorate,
it
was
decided
that
the
factor
should
be
1X
based
on
the
recently
revised
FQPA
SFC
standard
operating
procedures.
Therefore,
the
overall
uncertainty
factor
applied
to
sodium
28
chlorate
for
residential
handler
risk
assessments
is
100
which
is
based
on
the
FQPA
safety
factor
of
1X
along
with
the
10x
for
inter­
species
extrapolation
and
10x
for
intra­
species
sensitivity.

Noncancer
Risk
Summary:
All
of
the
noncancer
risk
calculations
for
residential
sodium
chlorate
handlers
completed
in
this
assessment
are
included
in
Appendix
2.

HED
believes
that
the
scenarios
assessed
in
this
document
represent
worse­
case
exposures
and
risks
resulting
from
use
of
sodium
chlorate
in
residential
environments.
It
should
also
be
noted
that
there
were
many
other
scenarios
where
medium
to
low
PHED
quality
data
were
used
to
complete
the
assessment.
Data
quality
should
be
considered
in
the
interpretation
of
the
uncertainties
associated
with
each
risk
value
presented.

Short­
term
risks
for
residential
handlers
(
intermediate­
term
exposures
are
not
likely,
because
of
the
sporadic
nature
of
applications
by
homeowners)
are
presented
below
in
Table
10.
All
risks
are
not
of
concern
because
all
MOEs
are
greater
than
the
level
of
concern
of
100.
29
Table
10:
Sodium
Chlorate
­
Short
Term
Residential
Inhalation
Exposure1
Exposure
Scenario
(
Scenario
#)
Daily
Area
Treated2
Crop/
Target3
Application
Rate4
Inhalation
MOE5
Mixer/
Loader/
Applicators,
Loader/
Applicators,
&
Applicators
M/
L/
A
liquids
with
a
Low
Pressure
Handwand
Sprayer
(
1)
1000
Spot/
edging
treatment
23.7
3000
L/
A
RTU
liquid
with
a
Trigger
Pump
Sprayer
(
2)
1
Spot/
edging
treatment
0.196
87000
M/
L/
A
liquids
with
a
Sprinkler
Can
(
3)
1000
Spot/
edging
treatment
23.7
5200
Applying
liquid
with
a
RTU
Sprinkler
Can
(
4)
1
Spot/
edging
treatment
0.27
710000
Applying
granules
by
Hand
(
5)
1000
Spot/
edging
treatment
12
370
L/
A
granules
with
a
Belly
Grinder
(
6)
1000
Spot/
edging
treatment
12
2800
L/
A
granules
with
a
Push­
type
Spreader
(
7)
1000
Spot/
edging
treatment
12
200000
1
Residential
exposures
assessments
do
not
include
PPE.

2
Amount
treated
is
presented
in
ft2/
day,
except
for
Scenario
#
s
2
and
4
which
are
presented
in
gallons/
day.
(
Standard
EPA/
OPP/
HED
values).

3
Crops
and
use
patterns
are
from
label
extractions
(
Appendix
1),
BEAD's
LUIS
reports,
and
the
Sodium
Chlorate
Use
Closure
Memo
(
J.
Guerry,
8/
5/
04;
10/
13/
04;
11/
15/
04).

4
Ranges
of
application
rates
are
based
on
values
from
label
extractions
(
Appendix
1),
BEAD's
LUIS
reports,
and
the
Sodium
Chlorate
Use
Closure
Memo
(
J.
Guerry,
8/
5/
04;
10/
13/
04;

11/
15/
04).
Application
rates
upon
which
the
analysis
is
based
are
presented
as
lb
ai/
1000
ft2,
except
for
Scenario
#
s
2
and
4
which
are
presented
in
lb
ai/
gallon.

5
Inhalation
MOE
=
Oral
NOAEL
(
30
mg/
kg/
day)
/
Daily
Inhalation
Dose.
HED
LOC
for
MOE
is
100.
30
4.0
Occupational
and
Residential
Handler
Exposure
and
Risk
Estimates
for
Cancer
An
occupational
and
residential
cancer
risk
assessment
was
not
conducted
for
sodium
chlorate.
The
exposure
durations
for
occupational
and
residential
handlers
are
inconsistent
with
the
mechanism
of
carcinogenicity.
A
2­
year
NTP
bioassay
to
determine
the
potential
of
sodium
chlorate
to
induce
thyroid
tumors
in
laboratory
animals
(
rats
and
mice)
has
been
recently
reported
in
a
draft
form
(
NTP,
2004).
A
final
report
of
this
study
is
expected
during
2005.
In
these
tests,
there
was
some
evidence
of
thyroid
gland
follicular
cell
carcinogenicity
in
male
rats
which
may
be
attributed
to
the
imbalance
of
thyroid
hormones
(
reduced
T
3
and
T
4
and
elevated
TSH)
seen
in
these
studies
as
a
result
of
exposure
to
high
doses
of
sodium
chlorate.
Current
EPA
HED
policy
states
that
"
nonmutagenic
pesticides
that
induce
elevated
levels
of
TSH
and
thyroid
follicular
cell
tumors
in
the
rat
should
be
classified
as
not
likely
to
be
carcinogenic
to
humans
at
doses
that
do
not
alter
rat
thyroid
hormone
homeostasis"
((
HED
hot
sheet
#
23).
In
female
mice
there
was
equivocal
and
marginal
evidence
of
increased
pancreatic
islet
carcinoma.

5.0
Summary
of
Risk
Concerns
and
Data
Gaps
for
Occupational
and
Residential
Handlers
The
occupational
and
residential
exposure
assessment
conducted
for
sodium
chlorate
is
a
highly
conservative
assessment
intended
to
encompass
all
of
the
major
uses.
Chemical
specific
exposure
studies
are
unavailable
for
handler
scenarios
so
HED
default
exposure
values
and
assumptions
were
used.
HED
exposure
values
and
assumptions
are
selected
to
be
realistic
and
yet
provide
a
reasonable
certainty
that
the
exposures
are
not
underestimated.
High­
end
assumptions
were
used
for
areas
treated
for
handlers.
Application
rates
used
in
handler
assessments
are
presented
as
ranges
(
from
low­
end
to
high­
end
application
rates)
to
reflect
different
product
labels.
It
should
be
noted
that
the
extrapolation
from
label­
specific
square­
foot
based
application
rates
to
acreage­
based
rates
(
necessary
to
represent
the
possibility
of
professional
applicators
to
treat
more
than
one
acre
of
crop/
non­
crop
area
per
day)
resulted
in
considerably
large
amounts
of
active
ingredient
handled
per
day,
not
to
mention
the
corresponding
diluted
solution
volumes
(
i.
e,
1032
lbs
ai/
2196
gallons
solution/
acre).
Though
these
may
well
be
exorbitant
amounts,
due
to
label
deficiencies
and
lack
of
chemical­
specific
information
regarding
amount
handled/
treated
per
day,
use
of
HED
standard
defaults
and
assumptions
was
necessary
until
further
information
is
available.

There
were
no
risks
of
concern
for
residential
handler
exposure
scenarios.
Risks
of
concern
for
occupational
scenarios,
as
outlined
in
Section
2.1.3.2,
were
mitigated
using
a
dust/
mist
respirator
with
an
80%
reduction
factor
or
engineering
controls.
Using
low­
end
application
rates
also
mitigated
risks
of
concern
without
the
application
of
a
respirator
or
engineering
controls.
No
handler
scenarios
have
data
gaps.

6.0
Occupational
and
Residential
Postapplication
Exposures
and
Risks
HED
uses
the
term
"
postapplication"
to
describe
exposures
to
individuals
that
occur
as
a
31
result
of
being
in
an
environment
that
has
been
previously
treated
with
a
pesticide
(
also
referred
to
as
reentry
exposure).
HED
believes
that
there
are
distinct
job
functions
or
tasks
related
to
the
kinds
of
activities
that
occur
in
previously
treated
areas.
Job
requirements
(
e.
g.,
the
kinds
of
jobs
to
cultivate
a
crop),
the
nature
of
the
crop
or
target
that
was
treated,
and
the
how
chemical
residues
degrade
in
the
environment
can
cause
exposure
levels
to
differ
over
time.

A
postapplication
exposure
assessment
was
not
conducted
for
the
following
reasons:

1)
Although
potential
for
postapplication
dermal
exposure
in
residential
and
occupational
settings
exists,
sodium
chlorate
is
an
inorganic
salt,
therefore
significant
absorption
of
sodium
chlorate
through
the
skin
is
not
expected.
2)
Postapplication
inhalation
exposure
is
not
expected
due
to
a
negligible
vapor
pressure.
3)
Postapplication
exposure
assessments
for
residential
settings
(
dermal
and
incidental
oral)
are
not
typically
performed
for
spot
treatments/
edging
treatments.
32
APPENDIX
1
Sodium
Chlorate
Label
Extraction
Tables
Table
A:
Agricultural
Defoliants/
Desiccants
Registered
Product
Crop/
Use
App
Equipment
Max
App
Rate
(
ai)
Comments/
Description
Helena
2
lb.
Sodium
Chlorate
Defoliant­
Desiccant
Reg
No.
5905­
87
Cotton
Ground
5
lb/
A
Liquid
(
SC)

Baseline
PPE
No
chemigation/
irrigation
12
hour
REI
7
day
PHI
(
cotton,
grain
sorghum)

No
grazing
(
cotton)

Aerial
Grain
Sorghum
Ground
6
lb/
A
Aerial
Helena
3
lb.
Chlorate
Defoliant
Desiccant
Reg
No.
5905­
118
Chili
Peppers
(
processing
only)
Ground
7.5
lb/
A
Liquid
(
SC)

Baseline
PPE
No
chemigation/
irrigation
12
hour
REI
7
day
PHI
(
dry
beans,
flax,
grain
sorghum,
guar
beans,
rice,
safflower,

soybeans,
sunflower)

10
day
PHI
(
chilipeppers,
corn)

14
day
PGI
(
corn,
flax,
rice,
sunflower)

No
grazing
(
dry
beans,
guar
beans,

soybeans,
sunflower)

Aerial
Corn
Ground
6
lb/
A
Aerial
Cotton
Ground
4.5
lb/
A
Aerial
Dry
Beans
Ground
6
lb/
A
Aerial
Flax
Ground
6
lb/
A
Aerial
Grain
Sorghum
Ground
6
lb/
A
33
Aerial
Guar
Beans
Ground
6
lb/
A
Aerial
Rice
Ground
6
lb/
A
Aerial
Safflowers
Ground
6
lb/
A
Aerial
Southern
peas
Ground
6
lb/
A
Aerial
Soybeans
Ground
6
lb/
A
Aerial
Sunflower
Ground
6
lb/
A
Aerial
34
Helena
6
lb.
Sodium
Chlorate
Defoliant­
Desiccant
Reg
No.
5905­
461
Dry
Beans
Ground
6
lb/
A
Liquid
(
SC)

PPE
=
Coveralls
(
over
short
shirt/
pants),

chem­
resistant
gloves,
chem­
resistant
footwear,
protective
eyewear,

chemresistant
headwear,
chem­
resistant
apron.

No
chemigation/
irrigation
12
hour
REI
California
restriction
(
dry
beans,
chili
peppers,
guar
beans,
flax,
corn,

safflower,
soybeans,
sunflower)

7
day
PHI
(
dry
beans,
guar
beans,

cotton,
flax,
grain
sorghum,
rice,

safflower,
soybeans,
sunflower)

14
day
PGI
(
corn,
rice)

No
grazing
(
dry
beans,
guar
beans,

cotton,
safflower,
soybeans,
sunflower)

10
day
PHI
(
chilipeppers,

14
day
PHI
(
corn)

Aerial
Chili
Peppers
(
processing
only)
Ground
7.5
lb/
A
Aerial
Guar
Beans
Ground
6
lb/
A
Aerial
Cotton
Ground
4.5
lb/
A
Aerial
Flax
Ground
6
lb/
A
Aerial
Grain
Sorghum
Ground
4.5
lb/
A
Aerial
Corn
Ground
6
lb/
A
Aerial
Rice
Ground
6
lb/
A
Aerial
Safflower
Ground
6
lb/
A
Aerial
Soybeans
Ground
6
lb/
A
Aerial
35
Sunflower
Ground
6
lb/
A
Aerial
LEAFEX
2
Defoliant­
Desiccant
Reg
No.
7001­
46
Cotton
Ground
5.28
lb/
A
(
AZ
only)

4.69
lb/
A
(
all
other
states)
Liquid
(
SC)

PPE
=
Coveralls
(
over
short
shirt/
pants),

dust/
mist
filtering
respirator,

chemresistant
footwear,
chem­
resistant
gloves,
protective
eyewear,

chemresistant
headwear,
chem­
resistant
apron
7
day
PHI
12
hour
REI
No
more
than
two
apps.

No
chemigation/
irrigation
No
grazing
Use
of
NIS
or
COC
Aerial
LEAFEX
3
Defoliant­
Desiccant
Reg
No.
7001­
335
Cotton
Ground
5.25
lb/
A
(
AZ
only)

4
lb/
A
(
all
other
states)
Liquid
(
SC)

PPE
=
Coveralls
(
over
short
shirt/
pants),

dust/
mist
filtering
respirator,

chemresistant
footwear,
chem­
resistant
gloves,
protective
eyewear,

chemresistant
headwear,
chem­
resistant
apron
Use
of
NIS
or
COC
No
chemigation/
irrigation
7
day
PHI
(
cotton,
grain
sorghum,
rice,

soybeans,
sunflower)

14
day
PGI
(
grain
sorghum,
corn,
rice,

sunflower)

14
day
PHI
(
corn)

No
grazing
(
cotton,
soybeans)

12
hour
REI
No
more
than
two
apps.

Aerial
Grain
Sorghum
and
Milo
Ground
6
lb/
A
Aerial
Corn
Aerial
6
lb/
A
Rice
Aerial
6
lb/
A
Soybean
Aerial
6
lb/
A
Sunflower
Aerial
6
lb/
A
36
SHED­
A­
LEAF
"
L"

Reg
No.
8867­
39
Cotton
Ground
3.75
lb/
A
Liquid
(
SC)

PPE
=
Baseline
plus
gloves
12
hour
REI
14
day
PHI
(
cotton)

No
grazing
(
cotton,
soybean
­
MS)

14
day
PGI
(
rice
­
MS)

7
day
PHI
(
rice
­
MS,
soybean
­
MS)

Aerial
Rice
(
MS
only)
Aerial
4.5
lb/
A
Soybean
(
MS
only)
Ground
6
lb/
A
Aerial
Riverside
Sodium
Chlorate
Reg
No.
9779­
142
Corn
Aerial
6
lb/
A
Liquid
(
SC)

PPE
=
Baseline
plus
gloves,
protective
eyewear
12
hour
REI
14
day
PHI
(
corn)

14
day
PGI
(
corn,
rice)

7
day
PHI
(
cotton,
dry
beans,
grain
sorghum,
rice,
safflower,
southern
peas,

soybeans,
sunflower)

No
grazing
(
cotton,
dry
beans,
safflower,

southern
peas,
soybeans,
sunflower)

Cotton
Ground
3.75
lb/
A
Aerial
Dry
beans
Ground
6
lb/
A
Aerial
Grain
Sorghum
Ground
6
lb/
A
Aerial
Rice
Aerial
6
lb/
A
Safflower
Ground
6
lb/
A
Aerial
Southern
peas
Ground
6
lb/
A
Aerial
Soybeans
Ground
6
lb/
A
Aerial
37
Sunflower
Ground
6
lb/
A
Aerial
Sodium
Chlorate
6
Reg
No.
9779­
305
Dry
beans
Ground
6
lb/
A
Liquid
(
SC)

PPE
=
Baseline
No
chemigation/
irrigation
12
hour
REI
7­
10
day
PHI
(
dry
beans,
chilipeppers,

cotton,
flax,
grain
sorghum,
guar
beans,

rice,
safflower,
southern
peas,
soybeans,

sunflower)

14
day
PGI/
PHI
(
corn,
flax,
rice)

No
grazing
(
cotton,
guar
beans,

safflower,
soybeans,
sunflower)

Aerial
Chili
Peppers
(
processing
only)
Ground
7.5
lb/
A
Aerial
Corn
Aerial
6
lb/
A
Cotton
Ground
4.5
lb/
A
Aerial
Flax
Aerial
6
lb/
A
Grain
Sorghum
Ground
6
lb/
A
Aerial
Guar
beans
Ground
6
lb/
A
Aerial
Rice
Aerial
6
lb/
A
Safflower
Ground
6
lb/
A
Aerial
Southern
peas
Ground
6
lb/
A
Aerial
Soybeans
Ground
6
lb/
A
38
Aerial
Sunflower
Ground
6
lb/
A
Aerial
D­
LEAF­
M
Cotton
Defoliant
Reg
No.
10163­
122
Cotton
Ground
4
lb/
A
Liquid
(
SC)

No
statement
of
PPE
No
chemigation/
irrigation
No
grazing
7
day
PHI
Aerial
Britz
Cotton
Defoliant
concentrate
Reg
No.
10951­
7
Cotton
Ground
4.58
lb/
A
Liquid
(
SC)

Baseline
PPE
plus
gloves
12
hour
REI
7
day
PHI
No
grazing
Aerial
First
Choice
Cotton
Defoliant
Concentrate
Reg
No.
11656­
90
Cotton
Ground
5.52
lb/
A
Liquid
(
SC)

Baseline
PPE
plus
gloves
12
hour
REI
No
chemigation/
irrigation
7
day
PHI
(
cotton)

10
day
PHI
(
chilipeppers,
grain
sorghum)

No
grazing
(
cotton)

14
day
PGI
(
grain
sorghum)

Aerial
Chili
Peppers
(
processing
only)
Ground
9.2
lb/
A
Aerial
Grain
Sorghum
Ground
4.97
lb/
A
Aerial
39
Drexel
Defol
Reg
No.
19173­
12
&

GA890007
(
Ornamental
Gourds)
Chili
Peppers
(
processing
only)
Ground
7.5
lb/
A
Liquid
(
SC)

PPE
=
Coveralls
(
over
short
shirt/
pants),

dust/
mist
filtering
respirator,

chemresistant
footwear,
chem­
resistant
gloves,
protective
eyewear,

chemresistant
headwear,
chem­
resistant
apron
12
hour
REI
Use
of
NIS
or
COC
10
day
PHI
(
chilipeppers,
potatoes)

14
day
PHI
(
corn)

14
day
PGI
(
corn,
flax,
rice,
sunflower)

7
day
PHI
(
dry
beans,
flax,
grain
sorghum,
guar
beans,
rice,
safflower,

southern
peas,
soybeans,
sunflower,

ornamental
gourds­
GA
only)

No
grazing
(
cotton,
dry
beans,
guar
beans,
potatoes,
safflower,
southern
peas,
soybeans,
ornamental
gourds­
GA
only)

Aerial
Corn
Aerial
6
lb/
A
Cotton
Ground
4.5
lb/
A
Aerial
Dry
beans
Ground
6
lb/
A
Aerial
Flax
Ground
6
lb/
A
Aerial
Grain
Sorghum
Ground
6
lb/
A
Aerial
Guar
beans
Ground
6
lb/
A
Aerial
Potatoes
Ground
6
lb/
A
Aerial
Rice
Aerial
6
lb/
A
Safflowers
Ground
6
lb/
A
Aerial
Southern
peas
Ground
6
lb/
A
Aerial
40
Soybeans
Ground
6
lb/
A
Aerial
Sunflower
Ground
6
lb/
A
Aerial
Ornamental
Gourds
(
GA
only)
Ground
6
lb/
A
Aerial
Drexel
Defol
6
Reg
No.
19173­
85
Chili
Peppers
(
processing
only)
Ground
7.5
lb/
A
Liquid
(
SC)

PPE
=
Coveralls
(
over
short
shirt/
pants),

dust/
mist
filtering
respirator,

chemresistant
footwear,
chem­
resistant
gloves,
protective
eyewear,

chemresistant
headwear,
chem­
resistant
apron
12
hour
REI
Use
of
NIS
or
COC
10
day
PHI
(
chilipeppers,
potatoes)

14
day
PHI
(
corn)

14
day
PGI
(
corn,
flax,
rice,
sunflower,

cucurbits)

7
day
PHI
(
dry
beans,
flax,
grain
sorghum,
guar
beans,
rice,
safflower,

southern
peas,
soybeans,
sunflower)

No
grazing
(
cotton,
dry
beans,
guar
beans,
potatoes,
safflower,
southern
peas,
soybeans)

Aerial
Corn
Aerial
6
lb/
A
Cotton
Ground
4.5
lb/
A
Aerial
Cucurbits
(
grown
for
seed)
Ground
6
lb/
A
Aerial
Dry
beans
Ground
6
lb/
A
Aerial
Flax
Ground
6
lb/
A
Aerial
Grain
Sorghum
Ground
6
lb/
A
Aerial
Guar
beans
Ground
6
lb/
A
41
Aerial
Potatoes
Ground
6
lb/
A
Aerial
Rice
Aerial
6
lb/
A
Safflowers
Ground
6
lb/
A
Aerial
Southern
peas
Ground
6
lb/
A
Aerial
Soybeans
Ground
6
lb/
A
Aerial
Sunflower
Ground
6
lb/
A
Aerial
42
Drexel
Defol
6W
Reg
No.
19173­
265
&

CA920017
(
Fallow
Land)
Chili
Peppers
(
processing
only)
Ground
7.5
lb/
A
Liquid
(
SC)

PPE
=
Coveralls
(
over
short
shirt/
pants),

dust/
mist
filtering
respirator,

chemresistant
footwear,
chem­
resistant
gloves,
protective
eyewear,

chemresistant
headwear,
chem­
resistant
apron
12
hour
REI
Use
of
NIS
or
COC
10
day
PHI
(
chilipeppers,
potatoes)

14
day
PHI
(
corn)

14
day
PGI
(
corn,
flax,
rice,
sunflower,

cucurbits)

7
day
PHI
(
dry
beans,
flax,
grain
sorghum,
guar
beans,
rice,
safflower,

southern
peas,
soybeans,
sunflower)

No
grazing
(
cotton,
dry
beans,
guar
beans,
potatoes,
safflower,
southern
peas,
soybeans)

Aerial
Corn
Aerial
6
lb/
A
Cotton
Ground
4.5
lb/
A
Aerial
Cucurbits
(
grown
for
seed)
Ground
6
lb/
A
Aerial
Dry
beans
Ground
6
lb/
A
Aerial
Flax
Ground
6
lb/
A
Aerial
Grain
Sorghum
Ground
6
lb/
A
Aerial
Guar
beans
Ground
6
lb/
A
Aerial
Potatoes
(
CA
restriction)
Ground
6
lb/
A
Aerial
Rice
Aerial
6
lb/
A
Safflowers
Ground
6
lb/
A
Aerial
43
Southern
peas
Ground
6
lb/
A
Aerial
Soybeans
Ground
6
lb/
A
Aerial
Sunflower
Ground
6
lb/
A
Aerial
Fallow
Ground
Ground
6
lb/
A
Aerial
Drexel
Defol
5
Reg
No.
19173­
388
Chili
Peppers
(
processing
only)
Ground
7.5
lb/
A
Liquid
(
SC)

PPE
=
Coveralls
(
over
short
shirt/
pants),

dust/
mist
filtering
respirator,

chemresistant
footwear,
chem­
resistant
gloves,
protective
eyewear,

chemresistant
headwear,
chem­
resistant
apron
12
hour
REI
Use
of
NIS
or
COC
10
day
PHI
(
chilipeppers,
potatoes)

14
day
PHI
(
corn)

14
day
PGI
(
corn,
flax,
rice,
sunflower,

cucurbits)

7
day
PHI
(
dry
beans,
flax,
grain
sorghum,
guar
beans,
rice,
safflower,

southern
peas,
soybeans,
sunflower)

No
grazing
(
cotton,
dry
beans,
guar
beans,
potatoes,
safflower,
southern
peas,
soybeans)

Aerial
Corn
Aerial
6
lb/
A
Cotton
Ground
4.5
lb/
A
Aerial
Cucurbits
(
grown
for
seed)
Ground
6
lb/
A
Aerial
Dry
beans
Ground
6
lb/
A
Aerial
Flax
Ground
6
lb/
A
Aerial
Grain
Sorghum
Ground
6
lb/
A
44
Aerial
Guar
beans
Ground
6
lb/
A
Aerial
Potatoes
Ground
6
lb/
A
Aerial
Rice
Aerial
6
lb/
A
Safflowers
Ground
6
lb/
A
Aerial
Southern
peas
Ground
6
lb/
A
Aerial
Soybeans
Ground
6
lb/
A
Aerial
Sunflower
Ground
6
lb/
A
Aerial
45
Drexel
Defol
750
Reg
No.
19173­
486
Chili
Peppers
(
processing
only)
Ground
7.5
lb/
A
Liquid
(
SC)

PPE
=
Coveralls
(
over
short
shirt/
pants),

dust/
mist
filtering
respirator,

chemresistant
footwear,
chem­
resistant
gloves,
protective
eyewear,

chemresistant
headwear,
chem­
resistant
apron
12
hour
REI
Use
of
NIS
or
COC
10
day
PHI
(
chilipeppers,
potatoes)

14
day
PHI
(
corn)

14
day
PGI
(
corn,
flax,
rice,
sunflower,

cucurbits)

7
day
PHI
(
dry
beans,
flax,
grain
sorghum,
guar
beans,
rice,
safflower,

southern
peas,
soybeans,
sunflower)

No
grazing
(
cotton,
dry
beans,
guar
beans,
potatoes,
safflower,
southern
peas,
soybeans)

Aerial
Corn
Aerial
6
lb/
A
Cotton
Ground
4.5
lb/
A
Aerial
Cucurbits
(
grown
for
seed)
Ground
6
lb/
A
Aerial
Dry
beans
Ground
6
lb/
A
Aerial
Flax
Ground
6
lb/
A
Aerial
Grain
Sorghum
Ground
6
lb/
A
Aerial
Guar
beans
Ground
6
lb/
A
Aerial
Potatoes
Ground
6
lb/
A
Aerial
Rice
Aerial
6
lb/
A
Safflowers
Ground
6
lb/
A
Aerial
46
Southern
peas
Ground
6
lb/
A
Aerial
Soybeans
Ground
6
lb/
A
Aerial
Sunflower
Ground
6
lb/
A
Aerial
Clean
Crop
Sodium
Chlorate
Reg
No.
34704­
695
Cotton
Ground
4.5
lb/
A
Liquid
(
SC)

Baseline
PPE
No
chemigation/
irrigation
7
day
PHI
(
cotton,
grain
sorghum,
rice,

safflower,
soybeans,
sunflower)

No
grazing
(
cotton,
safflower,
soybeans,

sunflower)

14
day
PGI
(
rice)

Aerial
Grain
Sorghum
Ground
6
lb/
A
Aerial
Rice
Aerial
6
lb/
A
Safflower
(
CA
restriction)
Ground
6
lb/
A
Aerial
Soybeans
(
CA
restriction)
Ground
6
lb/
A
Aerial
Sunflower
(
CA
restriction)
Ground
6
lb/
A
Aerial
MAPCO
Brand
Poly­
Foliant
Liquid
Defoliant
Reg
No.
49517­
1
Cotton
Ground
5.76
lb/
A
Liquid
(
SC)

Baseline
PPE
plus
gloves
No
chemigation/
irrigation
12
hour
REI
7
day
PHI
No
grazing
47
Aerial
Moore
AG
Brand
Poly­
Foliant
V
Defoliant
Desiccant
Reg
No.
49517­
3
Dry
beans
Ground
7.5
lb/
A
Liquid
(
SC)

PPE
=
Coveralls
(
over
long
shirt/
pants),

gloves,
chem­
resistant
footwear,

protective
eyewear,
chem­
resistant
apron
12
hour
REI
No
chemigation/
irriation
7
day
PHI
(
dry
beans,
guar
beans,

cotton,
flax,
grain
sorghum,
rice,

safflower,
soybeans,
sunflower,
southern
peas,
potatoes)

No
grazing
(
dry
beans,
guar
beans,

cotton,
safflower,
soybeans,
sunflower,

southern
peas,
potatoes)

10
day
PHI
(
chilipeppers)

14
day
PGI
(
corn,
rice)

14
day
PHI
(
corn)

Aerial
Chili
Peppers
(
processing
only)
Ground
12.5
lb/
A
Aerial
Guar
beans
Ground
7.5
lb/
A
Aerial
Cotton
Ground
7.5
lb/
A
Aerial
Flax
Aerial
7.5
lb/
A
Grain
Sorghum
Ground
7.5
lb/
A
Aerial
Corn
Aerial
7.5
lb/
A
Rice
Aerial
7.5
lb/
A
Safflower
Ground
7.5
lb/
A
Aerial
Soybean
Ground
7.5
lb/
A
Aerial
Sunflower
Ground
7.5
lb/
A
48
Aerial
Southern
peas
Ground
7.5
lb/
A
Aerial
Potatoes
Ground
12.5
lb/
A
Aerial
Pick­
Mor
Reg
No.
49517­
5
Cotton
Aerial
4.7
lb/
A
Liquid
(
SC)

PPE
=
baseline,
gloves,
protective
eyewear,
dust/
mist
respirator
(
outdoors),

organic
vapor
respirator
(
enclosed
areas)

4
hour
REI
No
chemigation/
irrigation
7
day
PHI
Ground
49
Table
B:
Commercial/
Residential
Herbicides
Registered
Product
App
Equipment
Max
App
Rate
(
ai)
Comments/
Description/
Uses
Riverdale
Killsall
Liquid
Reg
No.
228­
133
Commercial
M/
L/
A
­
LPHW,
Handgun
Sprayer
Product
conc
=
18.5%
ai
=
2
lb
ai/
gal
prod
Dilute
conc:
0.25
gal
prod/
2
gal
H20
=
0.25
gal
prod/
2.25
gal
soln
=
0.11
gal
prod/
gal
soln
=
0.22
lb
ai/
gal
soln
Treatment:
5
gal
prod/
3000
SF
=
10
lb
ai/
3000
SF
=
653
gal
soln/
A
=
144
lb
ai/
A
Liquid
(
SC)

No
PPE
statement
Fall
application
(
may
require
additional
app
in
following
spring)

Commercial
Label:
general
use
on
driveways,
parking
lots,
walks,
around
fences,
curbs,
similar
areas.
Not
for
use
on
lawns.
Residential
Label:
same
as
commercial
label.

App/
Equip:
"
coarse
spray"

Residential
M/
L/
A
­
LPHW,
Sprinkler
can
Riverdale
Killsall
II
Ready­
to­

Use
Liquid
Reg
No.
228­
201
Residential
L/
A
­
Trigger­
pump
Sprayer
Product
conc
=
2.3%
ai
=
0.196
lb
ai/
gal
RTU
soln
Treatment:
1
gal
RTU
soln/
60
SF
=

0.196
lb
ai/
60
SF
=
142.3
lb
ai/
A
Ready­
to­
Use
Solution
(
RTU)

No
PPE
statement
One
time
fall
app.

Use:
For
general
use
on
walks,

driveways,
parking
lots,
around
fences,

curbs,
patios,
buildings,
and
similar
noncrop
areas.
Not
for
use
in
veg
gardens,

flower
bed,
or
around
shrubs
or
ornamental
plants;
do
not
allow
on
or
near
desirable
turf.

App/
Equip:
"
spot
treatment"
­
"
edging
liquid"
­
"
trigger
spray
nozzle"
50
Perkerson's
Tri­
Chlor
Weed
Killer
Reg
No.
690­
44
Commercial
M/
L/
A
­
LPHW,
Handgun
Sprayer
Product
conc
=
26.18%
ai
=
2.8
lb
ai/
gal
prod
Sprinkler
can:

Dilute
conc:
1
gal
prod/
9
gal
H20
=
1
gal
prod/
10
gal
soln
=
0.10
gal
prod/
gal
soln
=
0.28
lb
ai/
gal
soln
Pressure
sprayer:

Dilute
conc:
1
gal
prod/
4
gal
H20
=
1
gal
prod/
5
gal
soln
=
0.2
gal
prod/
gal
soln
=
0.56
lb
ai/
gal
soln
Treatment:
1
gal
prod/
500
SF
=
2.8
lb
ai/
500
SF
=
871
gal
soln/
A
=
244
lb
ai/
A
(
sprinkler
can)
=
488
lb
ai/
A
(
pressure
sprayer)
Liquid
(
SC)

No
PPE
statement
Use:
Industrial
sites
such
as
driveways,

paths,
brick
walks,
cobble
gutters,
tennis
courts.

App/
Equip:
"
ordinary
sprinkler
can"
­

"
pressure
sprayer"

Residential
M/
L/
A
­
LPHW,
Sprinkler
can
51
Perkerson's
Tri­
Ate
Weed
Killer
Reg
No.
690­
48
Commercial
Loading
­
Granules
Applicator
­
Tractor­
drawn
spreader
L/
A
­
Belly
grinder,
Push
spreader
M/
L/
A
­
LPHW,
Handgun
Sprayer
Product
conc
=
30%
ai
Granular
treatment:
4
lb
prod/
100
SF
=
1.2
lb
ai/
100
SF
=
523
lb
ai/
A
Dilute
conc
(
under
asphalt):
2
lb
prod/
1
gal
H20
=
0.6
lb
ai/
gal
soln
Treatment:
2
gal
soln/
100
SF
=
1.2
lb
ai/
100
SF
=
871
gal
soln/
A
=
523
lb
ai/
A
Granular
(
also
dissolve
in
water
for
spray)

PPE
=
Baseline
plus
gloves,
protective
eyewear
Use:
Driveways,
paths,
brick
walks,

cobble
gutters,
tennis
courts,
porches,

patios,
parking
lots,
under
asphalt
paving,
fence
lines,
building
perimeters,

ditch
banks,
picnic
areas,
vacant
lots,

wood
decks,
bleachers,
cemetaries,
fuel
tanks,
runways,
helo
pads,
etc.

Avoid
contact
with
lawns,
trees,
shrubs,

crops
and
other
desirables.

App/
Equip:
"
hand­
operated
spreader"
­

"
conventional
cyclone
type
spreader"
­

"
power
spreader
for
larger
areas"
­

"
spray
application"

Residential
L/
A
­
Belly
grinder,
Push
spreader
M/
L/
A
­
LPHW
Applicator
­
Hand
AllPro
Baracide
5PS
Pelleted
Herbicide
Reg
No.
769­
978
Commercial
Loading
­
Granules
Applicator
­
Tractor­
drawn
spreader
L/
A
­
Belly
grinder,
Push
spreader
Product
conc
=
39.80%
ai
Treatment:
0.92
lb
prod/
100
SF
=

0.37
lb
ai/
100
SF
=
400
lb
ai/
A
Pelleted/
Tableted
No
PPE
statement
(
except
for
eyewear)

Use:
Around
buildings,
storage
areas,

fences,
recreational
areas,
guard
rails,

highway
medians,
industrial
sites.

Avoid
desirable
trees,
shrubs,
etc.
Not
for
greenhouse
use.

App/
Equip:
no
statement
52
Grass,
Weed
and
Vegetation
Killer
Reg
No.
5887­
46
Commercial
M/
L/
A
­
LPHW,
Handgun
Sprayer
Product
conc
=
18.5%
=
2
lb
ai/
gal
prod
Dilute
conc:
0.25
gal
prod/
2
gal
H20
=
0.25
gal
prod/
2.25
gal
soln
=
0.11
gal
prod/
gal
soln
=
0.22
lb
ai/
gal
soln
Treatment:
0.25
gal
prod/
100
SF
=

0.5
lb
ai/
100
SF
=
980
gal
soln/
A
=

216
lb
ai/
A
Liquid
(
SC)

No
PPE
statement
Use:
Driveways,
walks,
patios,
tennis
courts,
curbs,
garages,
etc.
Not
for
use
on
turf,
gardens,
valuable
trees,
or
near
other
desirables.

App/
Equip:
"
hand
or
power
sprayer"

Residential
M/
L/
A
­
LPHW,
Sprinkler
can
Ferti­
lome
Liquid
Vegetation
Killer
Reg
No.
7401­
87
Commercial
M/
L/
A
­
LPHW,
Handgun
Sprayer
Product
conc
=
2.7
lb
ai/
gal
prod
Typical
dilute
conc:
0.25
gal
prod/
1
gal
H20
=
0.25
gal
prod/
1.25
gal
soln
=
0.2
gal
prod/
gal
soln
=
0.54
lb
ai/
gal
soln
Dilute
conc
(
under
asphalt):
0.5
gal
prod/
0.5
gal
H20
=
0.5
gal
prod/
gal
soln
=
1.35
lb
ai/
gal
soln
Typical
treatment:
0.25
gal
prod/
100
SF
=
0.675
lb
ai/
100
SF
=
545
gal
soln/
A
=
294
lb
ai/
A
Treatment
(
under
asphalt):
0.5
gal
prod/
100
SF
=
1.35
lb
ai/
100
SF
=

436
gal
soln/
A
=
588
lb
ai/
A
Liquid
(
SC)

No
PPE
statement
Use:
Brick
walks,
patios,
parking
areas,

along
fences,
curbs,
gutters,
around
building,
graveled
pathways,
driveways,

under
asphalt
paving.

Avoid
lawn/
desirable
plant
contact.

App/
Equip:
"
sprinkler
can
or
power
sprayer"

Residential
M/
L/
A
­
LPHW,
Sprinkler
can
Ferti­
Lome
Ready­
to­
Use
Liquid
Weed
&
Wild
Grass
Killer
Reg
No.
7401­
85
Residential
Applicator
­
RTU
Sprinkler
can
Product
conc
=
0.27
lb
ai/
gal
RTU
soln
(
1
gallon
pre­
packaged
container)
Ready­
to­
Use
Solution
(
RTU)

Use:
driveways,
in
sidewalk
cracks,

around
patio
stones,
along
fence
lines,

lawn
edges,
around
fence
posts,
around
foundations,
around
garbage
cans
App/
Equip:
RTU
sprinkler
can
53
Ferti­
Lome
Special
Vegetation
Killer
Reg
No.
7401­
173
Commercial
M/
L/
A
­
LPHW,
Handgun
Sprayer
Product
conc
=
18%
ai
=
2
lb
ai/
gal
prod
Typical
dilute
conc:
0.25
gal
prod/
1
gal
H20
=
0.25
gal
prod/
1.25
gal
soln
=
0.2
gal
prod/
gal
soln
=
0.4
lb
ai/
gal
soln
Dilute
conc
(
under
asphalt)
=
0.75
gal
prod/
0.5
gal
H20
=
0.75
gal
prod/
1.25
gal
soln
=
0.6
gal
prod/
gal
soln
=
1.2
lb
ai/
gal
soln
Typical
treatment:
0.25
gal
prod/
67
SF
=
0.5
lb
ai/
67
SF
=
813
gal
soln/
A
=
325
lb
ai/
A
Treatment
(
under
asphalt):
0.75
gal
prod/
100
SF
=
1.5
lb
ai/
100
SF
=
545
gal
soln/
A
=
653
lb
ai/
A
Liquid
(
SC)

No
PPE
statement
Use:
Brick
walks,
patios,
parking
areas,

along
fences,
curbs,
gutters,
around
building,
graveled
pathways,
driveways,

under
asphalt
paving.

Avoid
lawn/
desirable
plant
contact.

App/
Equip:
"
sprinkler
can
or
power
sprayer"

Residential
M/
L/
A
­
LPHW,
Sprinkler
can
Lanscaper
Weed
Killer
and
Prepaving
Preparation
Reg
No.
7701­
34
Commercial
M/
L
­
Liquid
Applicator
­
Groundboom
M/
L/
A
­
LPHW,
Handgun
Sprayer
Product
conc
=
22.15%
ai
=
2.37
lb
ai/
gal
prod
Dilute
conc:
1
gal
prod/
4
gal
H20
=
1
gal
prod/
5
gal
soln
=
0.2
gal
prod/
gal
soln
=
0.47
lb
ai/
gal
soln
Treatment:
8
pints
prod/
100
SF
=
1
gal
prod/
100
SF
=
2.37
lb
ai/
100
SF
=
2196
gal
soln/
A
=
1032
lb
ai/
A
Liquid
(
SC)

No
PPE
statement
Use:
non­
agricultural
land;
pre­
paving.

App/
Equip:
"
low
pressure
sprayer"

Residential
M/
L/
A
­
LPHW
Tri­
Kil
Nonselective
Weed
and
Grass
Killer
Reg
No.
9754­
1
Commercial
M/
L
­
Liquid
Applicator
­
ROW
sprayer,

Groundboom
M/
L/
A
­
LPHW,
Handgun
Sprayer
Product
conc
=
7%
ai
=
0.76
lb
ai/
gal
prod
Dilute
conc:
1
gal
prod/
10
gal
H20
=

1
gal
prod/
11
gal
soln
=
0.09
gal
prod/
gal
soln
=
0.07
lb
ai/
gal
soln
Treatment:
1
gal
prod/
250
SF
=
0.76
lb
ai/
250
SF
=
1891
gal
soln/
A
=
132
lb
ai/
A
Liquid
(
SC)

Baseline
PPE
plus
gloves
Use:
Fence
rows,
rights­
of­
way,
similar
areas.
Avoid
desirable
trees/
shrubs.
CA
only
­
do
not
apply
to
more
than
one
A/
day.

App/
Equip:
none
54
Lane
Weedkill
­
N.
S.
#
3
Reg
No.
11440­
3
Commercial
M/
L
­
Liquid
Applicator
­
ROW
sprayer,

Groundboom
M/
L/
A
­
LPHW,
Handgun
Sprayer
Product
conc
=
18%
ai
=
2
lb
ai/
gal
prod
Dilute
conc:
2
gal
prod/
10
gal
H20
=

2
gal
prod/
12
gal
soln
=
0.17
gal
prod/
gal
soln
=
0.34
lb
ai/
gal
soln
Treatment:
2
gal
prod/
200
SF
=
4
lb
ai/
200
SF
=
2562
gal
soln/
A
=
871
lb
ai/
A
Liquid
(
SC)

PPE
=
Baseline
plus
gloves
Use:
Fence
rows,
ditch
banks,
around
buildings,
along
roadways,
power
lines
right
of
ways,
similar
areas.
CA
only
­

only
one
acre
per
day
per
applicator.

Prevent
killing
lawns/
trees/
shrubs.

App/
Equip:
no
statement
Bareground
BD
Reg
No.
33560­
43
Commercial
Loading
­
Granules
Applicator
­
Tractor­
drawn
spreader
L/
A
­
Belly
grinder,
Push
spreader
Product
conc
=
40%
ai
Treatment:
1.37
lb
prod/
100
SF
=

0.55
lb
ai/
100
SF
=
240
lb
ai/
A
Pelleted/
Tableted
PPE
=
Coveralls
(
over
long
shirt/
pants),

chem­
resistant
footwear,
chem­
resistant
gloves,
goggles/
faceshield
Use:
Industrial
sites,
rights­
of­
way,

lumberyards,
petroleum
tank
farms,

around
farm
buildings,
along
fence
lines
and
similar
areas.

Not
for
use
in
recreational
areas
or
in/
around
homes.

App/
Equip:
no
statement
55
Barespot
Weed
&
Grass
Reg
No.
33560­
46
Commercial
Loading
­
Granules
Applicator
­
Tractor­
drawn
spreader
L/
A
­
Belly
grinder,
Push
spreader
Product
conc
=
30%
ai
Treatment:
3
lb
prod/
100
SF
=
0.9
lb
ai/
100
SF
=
392
lb
ai/
A
Granular
PPE
=
Baseline
plus
gloves,
protective
eyewear
Use:
Bleachers,
bridge
abutments,

buildings,
bunkers,
guard
rails,
helo
pads,
etc.
Under
asphalt,
concrete,

gravel,
driveways,
sidewalks/
walkways,

wood
decks.
Avoid
contact
with
lawns,

trees,
shrubs,
and
other
desirables.

For
sale
and
use
for
professional
turf
maintenance,
landscaping
or
commercial
applicators.
(
20
lb
product)

App/
Equip:
"
hand­
operated
spreader"
­

"
conventional
cyclone
spreader"
­

"
power
spreader
for
larger
areas"

Barespot
Ureabor
Reg
No.
33560­
47
Commercial
Loading
­
Granules
Applicator
­
Tractor­
drawn
spreader
L/
A
­
Belly
grinder,
Push
spreader
Product
conc
=
30%
ai
Treatment:
1.8
lb
prod/
100
SF
=
0.54
lb
ai/
100
SF
=
235
lb
ai/
A
Granular
PPE
=
Baseline
plus
gloves,
protective
eyewear
Use:
Bleachers,
fence
lines,
fire
hydrants,
helo
pads,
parking
lots,

runways,
vacant
lots,
etc.
Not
for
use
in/
around
homes
or
in
recreational
areas.

App/
Equip:
"
hand­
operated
spreader"
­

"
conventional
cyclone
spreader"
­

"
power
spreader
for
larger
areas"
56
Barespot
Monobor
Chlorate
Reg
No.
33560­
48
Commercial
Loading
­
Granules
Applicator
­
Tractor­
drawn
spreader
L/
A
­
Belly
grinder,
Push
spreader
M/
L/
A
­
LPHW,
Handgun
Sprayer
Product
conc
=
30%
ai
Granular
treatment:
4
lb
prod/
100
SF
=
1.2
lb
ai/
100
SF
=
523
lb
ai/
A
Dilute
conc
(
under
asphalt):
2
lb
prod/
1
gal
H20
=
0.6
lb
ai/
gal
soln
Treatment:
2
gal
soln/
100
SF
=
1.2
lb
ai/
100
SF
=
871
gal
soln/
A
=
523
lb
ai/
A
Granular
(
also
dissolve
in
water
for
spray
app)

PPE
=
Baseline
plus
gloves,
protective
eyewear
For
use
in
greenhouses
(
12
hour
REI)

Use:
Bleachers,
fence
lines,
fire
hydrants,
guard
rails,
parking
lots,
etc.

Under
asphalt,
concrete,
driveways,

sidewalks/
walkways.
Avoid
lawn/
shrub/
tree/
desirable
plant
contact
App/
Equip:
"
hand­
operated
spreader"
­

"
conventional
cyclone
spreader"
­

"
power
spreader
for
larger
areas"

Residential
M/
L/
A
­
LPHW
L/
A
­
Belly
grinder,
Push
spreader
Applicator
­
Hand
Prometon
5PS
Reg
No.
53883­
97
Commercial
Loading
­
Granules
Applicator
­
Tractor­
drawn
spreader
L/
A
­
Belly
grinder,
Push
spreader
Product
conc
=
39.8%
ai
Treatment:
0.92
lb
prod/
100
SF
=

0.37
lb
ai/
100
SF
=
161
lb
ai/
A
Pelleted/
Tableted
PPE
­
only
mentions
eyewear
Use:
Around
buildings,
storage
areas,

fences,
pumps,
machinery,
fuel
tanks,

recreational
areas,
roadways,
guard
rails,

airports,
rights­
of­
way,
etc.
Not
for
use
in
greenhouses.

Do
not
apply
where
chemical
may
contact
desirable
trees/
shrubs/
plants.

App/
Equip:
no
statement
57
Pramitol
5PS
Reg
No.
66222­
23
Commercial
Loading
­
Granules
Applicator
­
Tractor­
drawn
spreader
L/
A
­
Belly
grinder,
Push
spreader
Product
conc
=
39.8%
ai
Treatment:
0.92
lb
prod/
100
SF
=

0.37
lb
ai/
100
SF
=
161
lb
ai/
A
Pelleted/
Tableted
PPE
­
only
mentions
eyewear
Not
for
use
in
greenhouses
Use:
Around
buildings,
storage
areas,

fences,
pumps,
machinery,
fuel
tanks,

recreational
areas,
roadways,
guard
rails,

airports,
rights­
of­
way,
etc.
Not
for
use
in
greenhouses.

Do
not
apply
where
chemical
may
contact
desirable
trees/
shrubs/
plants.

App/
Equip:
no
statement
APPENDIX
2
OCCUPATIONAL
AND
RESIDENTIAL
RISK
CALCULATIONS
