Page
1
of
36
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
DC
20460
OFFICE
OF
PREVENTION,
PESTICIDES,
AND
TOXIC
SUBSTANCES
March
23,
2006
MEMORANDUM
SUBJECT:
Occupational
and
Residential
Exposure
Assessment
of
Alkylbenzene
Sulfonates
for
the
Reregistration
Eligibility
Decision
Document
(
RED).

TO:
Heather
Garvie,
Chemical
Review
Manager,
Reregistration
Team
36
Regulatory
Management
Branch
II
Antimicrobials
Division
(
7510C)

And
Deborah
Smegal,
Risk
Assessor
Reregistration
Branch
I
Health
Effects
Division
(
7509C)

FROM:
Talia
Milano,
Chemist,
Team
II
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

THRU:
Norm
Cook,
Branch
Chief
Risk
Assessment
and
Science
Support
Branch
(
RASSB)
Antimicrobials
Division
(
7510C)

DP
Barcode:
327732
Case
No.:
4006
Chemical
Name
(
s)
CAS
#
1
PC
CODE1
Sodium
dodecylbenzene
sulfonate
25155­
30­
0
079010
Benzenesulfonic
acid,
C10­
16­
alkyl
derivatives
68584­
22­
5
190116
Dodecylbenzene
sulfonic
acid
27176­
87­
0
098002
1:
The
CAS
#
and
PC
Codes
listed
reflect
the
current
numbering
system.
However,
Dodecylbenzene
sulfonic
acid
is
not
a
pure
chemical,
and
is
considered
part
of
the
mixture
of
Benzenesulfonic
acid.
A
discussion
of
this
discrepancy
can
be
found
in
the
text
of
the
chapter
along
in
the
Preliminary
Risk
Assessment.
Page
2
of
36
OCCUPATIONAL
AND
RESIDENTIAL
EXPOSURE
ASSESSMENT
OF
ALKYLBENZENE
SULFONATES
IN
SUPPORT
OF
THE
REREGISTRATION
ELIGIBILITY
DECISION
DOCUMENT
(
RED)

REREGISTRATION
CASE
4006
3/
23/
06
Antimicrobials
Division
Office
of
Pesticide
Programs
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
Page
3
of
36
TABLE
OF
CONTENTS:

EXECUTIVE
SUMMARY................................................................................................
4
1.0
INTRODUCTION.......................................................................................................
6
1.1
Purpose..............................................................................................................
6
1.2
Criteria
for
Conducting
Exposure
Assessments................................................
7
1.3
Chemical
Identification.....................................................................................
7
1.4
Physical/
Chemical
Properties............................................................................
8
2.0
USE
INFORMATION...............................................................................................
8
2.1
Formulation
Types
and
Percent
Active
Ingredient.............................................
8
2.2
Summary
of
Use
Pattern
and
Formulations.......................................................
8
3.0
SUMMARY
OF
TOXICITY
DATA..........................................................................
10
3.1
Acute
Toxicity.....................................................................................................
10
3.2
Summary
of
Toxicity
Endpoints..........................................................................
10
3.3
FQPA
Considerations..........................................................................................
11
4.0
RESIDENTIAL
EXPOSURE
ASSESSMENT..........................................................
13
4.1
Residential
Exposure......................................................................................
13
5.0
OCCUPATIONAL
EXPOSURE
ASSESSMENT.................................................
14
5.1
Occupational
Handler
Exposures....................................................................
20
5.2
Occupational
Post­
application
Exposures.......................................................
27
5.3
Data
Limitations/
Uncertainties........................................................................
27
6.0
REFERENCES...........................................................................................................
..
29
APPENDIX
A
.......................................................................................................................
30
APPENDIX
B
........................................................................................................................
32
Page
4
of
36
EXECUTIVE
SUMMARY
This
document
is
the
Occupational
and
Residential
Exposure
Assessment
for
the
Reregistration
Eligibility
Decision
Document
(
RED)
for
alkylbenzene
sulfonates.
The
currently
listed
active
ingredients
that
are
included
under
this
decision
are
sodium
dodecylbenzene
sulfonate
(
CAS
#
25155­
30­
0),
dodecylbenzene
sulfonic
acid
(
CAS
#
27176­
87­
0),
and
benzenesulfonic
acid,
C10­
C16
alkyl
derivatives
(
CAS
#
68584­
22­
5).
To
date,
dodecylbenzene
sulfonic
acid
has
been
listed
separately
from
benzenesulfonic
acid,
C10­
C16
alkyl
derivatives,
and
identified
by
the
CAS
#
27176­
87­
0
on
numerous
labels
and
in
different
databases.
Dodecylbenzene
sulfonic
acid
is
not
considered
to
be
a
pure
compound,
and
is
included
in
the
mixture
of
benzenesulfonic
acid,
C10­
16
alkyl
derivatives.
For
future
references
of
this
chapter,
any
conclusions
that
are
made
specifically
about
benzenesulfonic
acid,
C10­
C16
alkyl
derivatives
will
be
representative
of
dodecylbenzene
sulfonic
acid.
For
this
specific
chapter,
the
chemicals
are
referred
to
as
they
are
identified
in
current
databases.

At
this
time
alkylbenzene
sulfonates
are
active
ingredients
in
twenty­
three
registered
end­
use
products
such
as
cleaners
and
sanitizers
that
are
designated
for
used
in
agricultural,
food
handling
and
commercial/
institutional/
industrial
settings
(
Use
Site
Categories
I,
II,
and
III
respectively).
These
products
have
not
been
identified
to
have
any
residential
use
sites,
and
therefore
a
residential
assessment
was
not
conducted
at
this
time.
In
addition,
a
majority
of
the
currently
registered
labels
require
the
use
of
gloves,
protective
clothing,
goggles,
and
a
face
shield.
Examples
of
registered
uses
for
alkylbenzene
sulfonates
include,
but
are
not
limited
to:
application
to
indoor
hard
surfaces
(
e.
g.
urinals,
shower
stalls,
toilet
bowls,
etc.),
food
dispensing
equipment
(
e.
g.
pre­
mix
and
post­
mix
vending
machines),
food
contact
surfaces
(
glasses,
dishes,
silverware,
countertops,
etc.),
agricultural
tools,
and
fruits
and
vegetables
(
post­
harvest).
This
assessment
contains
the
non­
dietary
occupational
exposure
assessment
for
alkylbenzene
sulfonates
when
they
are
listed
as
active
ingredients.
The
dietary
assessment
as
well
as
an
inert
assessment
for
the
uses
of
the
sulfonates
will
be
assessed
separately
in
supporting
documents
of
this
RED.
The
percentage
of
alkylbenzene
sulfonates
in
various
products
can
range
from
0.036%
to
25.6%.
Products
containing
alkylbenzene
sulfonates
are
formulated
as
soluble
concentrates,
flowable
concentrates,
ready­
to­
use
solutions,
or
water
soluble
packaging.

The
durations
and
routes
of
exposure
that
was
evaluated
in
this
assessment
include
short­
term
(
ST)
and
intermediate­
term
(
IT)
inhalation
exposures.
There
is
no
evidence
of
systemic
toxicity
via
the
dermal
route,
and
this
is
why
a
dermal
endpoint
was
not
provided,
and
thus,
no
dermal
assessment
has
been
conducted
at
this
time.
Alkylbenzene
sulfonates
are
considered
to
be
dermal
irritants
in
formulations
that
have
listed
amounts
of
active
ingredient
generally
greater
than
20%.
The
following
excerpt
is
reiterated
from
the
toxicological
endpoint
Table
4.

Quantification
of
dermal
risk
is
not
required
since:
1)
the
alkylbenzene
sulfonates
are
surfactants
that
are
dermal
irritants
at
concentrations
generally
greater
than
20%
solution
(
WHO
1996).
Thus,
dermal
exposure
would
be
self­
limiting
to
preclude
dermal
irritation.
Most
pesticide
formulations
have
less
than
5%
alkylbenzene
sulfonates
as
an
inert
ingredient,
with
the
vast
majority
of
household
products
containing
approximately
2%.
Additionally,
the
requirement
of
the
dermal
toxicity
studies
with
the
end­
use
product
will
determine
whether
personal
protective
clothing
would
be
necessary
to
protect
against
irritation
during
product
Page
5
of
36
use;
2)
no
systemic
toxicity
was
seen
following
repeated
dermal
applications
to
rabbits
at
200
mg/
kg/
day
(
with
an
end
use
product);
3)
no
developmental
toxicity
concerns
were
seen
following
repeated
dermal
applications
to
pregnant
mice,
rats
or
rabbits
(
developmental
effects
were
seen
either
in
the
presence
of
maternal
toxicity
or
at
doses
higher
than
those
that
caused
maternal
toxicity);
and
4)
there
is
no
residential
exposure
to
alkylbenzene
sulfonates
as
an
active
ingredient,
however,
residential
exposure
from
its
use
as
an
inert
ingredient
in
pesticide
formulations
is
expected
to
be
of
an
intermittent
nature
(
i.
e,
no
continuous,
constant
contact,
multi­
day
exposure)
from
household
products.

For
the
dose
calculations,
the
default
inhalation
absorption
factor
was
100%.
In
addition,
the
toxicological
report
is
important
to
review
for
a
more
detailed
explanation
of
the
endpoints
that
were
calculated.

The
use
sites
and
application
rates
were
examined
for
all
of
the
labels
that
included
the
one
of
the
three
sulfonates
as
the
active
ingredient.
From
this
examination,
the
representative
scenarios
were
chosen.
However,
even
though
the
toxicological
endpoints
selected
for
all
of
the
chemicals
represented
by
this
case
number
are
the
same,
the
labels
that
listed
sodium
dodecylbenzene
sulfonate
still
had
be
assessed
individually
if
they
were
not
chosen
to
be
the
representative
label.
The
reason
for
this
is
because
for
each
label
that
lists
sodium
dodecylbenzene
sulfonate
as
the
active
ingredient;
there
was
direction
for
a
handler
to
use
the
same
product
for
both
the
cleaning
and
sanitizing
steps
via
various
methods.
There
is
an
expected
risk
to
the
handler
that
performs
both
cleansing
and
sanitizing
in
the
same
time
frame,
and
this
risk
was
evaluated
by
calculating
the
total
MOE.

To
assess
the
handler
risks,
the
Agency
used
surrogate
unit
exposure
data
from
the
following
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
and
the
Pesticide
Handlers
Exposure
Database
(
PHED).

For
the
occupational
handler
inhalation
risk
assessment,
the
MOEs
were
greater
than
or
equal
to
the
target
MOE
of
100
for
all
scenarios
except
the
following:

Handler
Risk
Summary
for
alkylbenzene
sulfonates:

 
ST
and
IT
inhalation
exposure
from
cleaning
hard
surfaces
via
circulation/
flow/
flushing
in
the
agricultural
premises
and
equipment
category,
inhalation
MOE
=
0.27.
 
ST
and
IT
inhalation
exposure
from
application
to
hard
surfaces
via
circulation
systems/
flow
method
in
the
food
handling
category,
inhalation
MOE
=
0.16.
 
ST
and
IT
inhalation
exposure
from
cleaning
hard
surfaces
via
wiping
in
the
food
handling
category,
inhalation
MOE
=
93.
 
ST
and
IT
inhalation
exposure
from
application
to
hard
surfaces
via
CIP
(
Cleaning
in
Place)
in
the
food
handling
premises
category,
inhalation
MOE
=
0.14.
 
ST
and
IT
inhalation
exposure
from
cleaning
food
dispensing
equipment
via
circulation
systems/
flow
method
in
the
food
handling
category,
inhalation
MOE
=
0.16.
 
ST
and
IT
Inhalation
exposure
from
cleaning
shower
stalls
and
toilets
via
a
liquid
pour
application
in
the
commercial/
institutional
premises,
inhalation
MOE
=
13.
 
ST
and
IT
inhalation
exposure
from
cleaning
shower
stalls
and
toilets
via
wiping
in
the
commercial/
institutional
premises,
inhalation
MOE
=
0.38.
Page
6
of
36
Total
Exposure
Summary
for
sodium
dodecylbenzene
sulfonate
(
results
from
cleaning
and
sanitizing
with
the
same
product
in
the
same
time
frame)

 
ST
and
IT
inhalation
exposure
from
cleaning
indoor
hard
surfaces
via
wiping
and
then
following
with
sanitizing
via
immersion/
flooding
in
the
food
handling
premises
category,
inhalation
MOE
=
93.
 
ST
and
IT
inhalation
exposure
from
cleaning
indoor
hard
surfaces
via
wiping
and
then
following
with
sanitizing
via
low
pressure
spray
in
the
food
handling
premises
category,
inhalation
MOE
=
90.
 
ST
and
IT
inhalation
exposure
from
cleaning
indoor
hard
surfaces
via
sponge/
mesh/
wiping
and
then
sanitizing
via
immersion/
flooding
in
the
food
handling
premises
category,
inhalation
MOE
=
90.
 
ST
and
IT
inhalation
exposure
from
cleaning
and
sanitizing
steps
to
be
conducted
through
CIP
(
Cleaning
in
Place)
in
the
food
handling
premises
category,
inhalation
MOE
=
<
1.

Data
Limitations
and
Uncertainties:

There
are
a
number
of
uncertainties
associated
with
this
assessment
and
these
have
been
reiterated
from
Section
6.3.

 
Surrogate
inhalation
unit
exposure
values
were
taken
from
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999:
DP
Barcode
D247642)
or
from
the
Pesticide
Handler
Exposure
Database
(
USEPA,
1998)
(
See
Appendix
A
for
summaries
of
these
data
sources).
Most
of
the
CMA
data
are
of
poor
quality;
therefore,
AD
requests
that
confirmatory
monitoring
data
be
generated
to
support
the
values
used
in
these
assessments.
 
The
quantity
handled/
treated
were
estimated
based
on
information
from
various
sources,
and
in
certain
cases,
no
standard
values
were
available
for
some
scenarios.
Assumptions
and
groupings
for
these
scenarios
were
based
on
Agency
estimates
and
could
be
further
refined
with
input
from
registrants.
 
The
quantity
handled
for
cleaning
in
place
systems
was
estimated
based
on
the
size
of
tunnel
pasteurization
systems.
The
labels
for
CIP
systems
indicate
that
small
amounts
of
the
product
could
be
introduced
into
the
system
for
cleansing
whereas
other
labels
direct
for
the
system
to
be
filled
to
its
maximum
capacity.
This
maximum
capacity
was
not
listed
on
the
label,
so
this
is
why
the
value
for
tunnel
pasteurization
was
used
as
a
conservative
size
estimate.
This
can
be
further
refined
with
input
from
the
registrants.
Page
7
of
36
1.0
INTRODUCTION
1.1
Purpose
In
this
document,
the
Agency
presents
the
results
of
its
review
of
the
potential
effects
of
occupational
exposure
to
the
alkylbenzene
sulfonates
when
they
are
listed
as
active
ingredients
in
registered
products.
This
information
is
for
use
in
EPA's
development
of
the
alkylbenzene
sulfonates
Reregistration
Eligibility
Decision
Document
(
RED).

1.2
Criteria
for
Conducting
Exposure
Assessments
An
occupational
exposure
assessment
is
required
for
an
active
ingredient
if
(
1)
certain
toxicological
criteria
are
triggered
and
(
2)
there
is
potential
exposure
to
handlers
(
mixers,
loaders,
applicators,
etc.)
during
use
or
to
persons
entering
treated
sites
after
application
is
complete.
For
alkylbenzene
sulfonates,
both
criteria
are
met.

Using
surrogate
unit
exposure
data,
maximum
application
rates
from
labels,
and
EPA
estimates
of
daily
amount
handled,
exposures
and
risks
to
handlers
were
calculated
and
assessed.
Appendix
A
includes
all
of
the
equations
utilized
and
is
supplemented
with
some
definitions.
Also,
in
lieu
of
registrant
submitted
data,
the
proprietary
unit
exposure
data
that
was
used
for
this
assessment
are
discussed
in
Appendix
B.

In
addition
to
the
target
MOEs
from
Section
3.2
that
were
used
for
the
analysis,
a
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
handler
risk
assessment.
Each
general
assumption
and
factor
for
the
occupational
assessment
is
detailed
below.
Assumptions
specific
to
the
use
site
category
are
listed
in
each
separate
section
of
this
document.
The
general
assumptions
and
factors
include:

 
The
Agency
has
patterned
this
risk
assessment
on
a
series
of
likely
representative
scenarios
for
each
use
site
that
are
believed
by
the
Agency
to
represent
the
vast
majority
of
alkylbenzene
sulfonate
uses.
 
Based
on
the
adverse
effects
for
the
endpoints,
the
average
body
weight
of
an
adult
handler
of
70
kg
was
used
to
complete
the
non­
cancer
risk
assessment.
 
Exposure
factors
used
to
calculate
daily
exposures
to
handlers
were
based
on
applicable
data,
if
available.
When
appropriate
data
were
lacking,
values
from
a
scenario
deemed
similar
were
used.
 
The
maximum
application
rates
allowed
by
labels
were
assumed.

1.3
Chemical
Identification
Three
chemical
names
are
considered
in
this
document:
1)
sodium
dodecylbenzene
sulfonate,
2)
dodecylbenzene
sulfonic
acid,
and
3)
benzenesulfonic
acid,
C10­
C16
alkyl
derivatives.
Dodecylbenzene
sulfonic
acid
is
not
a
pure
compound,
and
for
future
references
will
be
addressed
jointly
with
benzenesulfonic
acid,
C10­
C16
alkyl
derivatives.
However,
as
previously
stated,
this
document
follows
the
current
nomenclature
that
is
found
in
databases,
in
which
dodecylbenzene
sulfonic
acid
is
listed
and
identified
separately.
These
chemical
properties
have
been
extracted
from
the
"
Product
Chemistry
Science
Chapter"
of
this
RED.
Page
8
of
36
Table
1
Chemical
Identification
Information
for
Alkylbenzene
Sulfonates
Parameter
Sodium
Dodecylbenzene
Sulfonate
Benzene
Sulfonic
Acid,
C10­
16­
alkyl
derivatives
Dodecylbenzene
Sulfonic
Acid
CAS
Number
25155­
30­
0
68584­
22­
5
27176­
87­
0
Molecular
Formula
C18H29O3S
Na
C16H26O3S
C18H30O3S
1.4
Physical/
Chemical
Properties
Table
2
displays
the
physical/
chemical
characteristics
that
have
been
reported
for
the
alkylbenzene
sulfonates.
As
previously
stated,
the
product
chemistry
chapter
provides
a
comprehensive
list
of
the
different
physical/
chemical
properties.

Table
2
Physical/
Chemical
Properties
of
Alkylbenzene
Sulfonates
Parameter
Sodium
Dodecylbenzene
Sulfonate
Benzene
Sulfonic
Acid,
C10­
16­
alkyl
derivatives
Dodecylbenzene
Sulfonic
Acid
Molecular
Weight
348.48
g/
mol
298.44
g/
mol
326.50
g/
mol
Henry
Law
Constant
6.02
x
10­
17
atm.­
m3/
mol
2.8
x
10­
11
atm­
m3/
mol
4.8
x
10­
11
atm­
m3/
mol
Melting
Point
287.6OC
167.7
O
C
178
OC
Boiling
Point
660OC
437
OC
460
OC
Water
Solubility
800
mg/
L
7.1
mg/
L
(
25
O
C)
0.7
mg/
L
log
Kow
1.96
3.80
4.78
Vapor
Pressure
6.02
x
10­
15
mm
Hg
5.1
x
10­
10
mm
Hg
(
25o
C)
7.9
x
10­
11
mm
Hg
(
25o
C)

2.0
USE
INFORMATION
2.1
Formulation
Types
and
Percent
Active
Ingredient
The
twenty­
three
EPA
registered
products
that
contain
alkylbenzene
sulfonates
as
the
active
ingredients
(
a.
i.)
are
formulated
as
soluble
concentrates,
flowable
concentrates,
readyto
use
solutions,
and
water
soluble
packaging.
Concentrations
of
alkylbenzene
sulfonates
in
these
products
range
from
0.036%
to
25.6%.

2.2
Summary
of
Use
Pattern
and
Formulations
Alkylbenzene
sulfonates
are
active
ingredients
in
numerous
sanitizing
and
cleaning
products.
The
Agency
recognizes
that
the
alkylbenzene
sulfonates
are
also
used
extensively
as
inerts
in
several
products
such
as
formulated
detergents,
cleaners,
and
other
consumer
products.
The
inert
uses
will
be
assessed
under
a
separate
review
document
as
a
part
of
the
RED
process.
The
Agency
determines
potential
exposures
to
handlers
of
the
product
by
identifying
exposure
scenarios
from
the
various
application
methods
that
are
plausible,
given
the
label
uses.
These
scenarios
are
identified
in
Table
3,
and
are
listed
separately
by
each
active
ingredient
that
is
currently
listed
on
the
labels
and
in
databases.
Based
on
a
review
of
labels,
products
containing
alkylbenzene
sulfonates
are
intended
for
use
in
agricultural,
food
handling
and
commercial/
institutional/
industrial
settings
(
Use
Site
Categories
I,
II,
and
III
respectively).
Page
9
of
36
Examples
of
registered
uses
for
alkylbenzene
sulfonates
include
application
to
indoor
hard
surfaces
(
e.
g.
urinals,
shower
stalls,
toilet
bowls,
equipment,
etc.),
food
dispensing
equipment
(
e.
g.
pre­
mix
and
post­
mix
vending
machines),
food
contact
surfaces
(
glasses,
dishes,
silverware,
countertops,
etc.),
agricultural
tools,
and
fruits
and
vegetables
(
post­
harvest).
As
previously
stated,
the
dietary
assessment
will
also
be
conducted
in
a
separate
review
document
as
a
part
of
the
RED
process.

Table
3
Potential
Use
Scenarios
Based
on
Product
Labels
for
Alkylbenzene
Sulfonates
Use
Site
Category
Example
Use
Sites
Scenarios
Sodium
dodecylbenzene
sulfonate
(
CAS
No.
25155­
30­
0)

Use
Site
Category
II
Food
Handling/
Storage
Establishments
Premises
and
Equipment
Dairy
and
food
processing
plants;
meat
and
poultry
plants;
and
other
eating
establishments
 
Application
to
hard
surfaces
and
equipment
through
brush,
low
pressure
spray,
high
pressure
spray,
mopping,
wiping,
foam,
flooding,
immersion,
CIP.

 
Application
to
dishes
and
silverware
by
brush,
foam,
wiping,
low
pressure
spray,
and
immersion.

 
Application
to
fruits
and
vegetables
by
immersion
and
spray.

 
Application
to
food
dispensing
equipment
through
circulation
cleaning
system.

Dodecylbenzene
Sulfonic
Acid
(
CAS
No.
68584­
22­
5)

Use
Site
Category
I
Agricultural
Premises
and
Equipment
Dairy
Farms
 
Application
to
hard
surfaces
and
equipment
through
brush,
low
pressure
spray,
high
pressure
spray,
foam,
flooding,
circulation/
recirculation
systems,
flushing,
immersion,
flow
method,
CIP.
Use
Site
Category
II
Food
Handling/
Storage
Establishments
Premises
and
Equipment
Dairy
and
food
processing
plants;
food
service
industry;
carbonated
beverage
industry;
meat
and
poultry
plants;
food
service
areas
of
public
eating
places,
schools,
and
bars
 
Application
to
hard
surfaces
and
equipment
through
brush,
low
pressure
spray,
high
pressure
sprayer,
foam,
pump
or
trigger
sprayer,
circulation/
recirculation
systems,
flushing,
flooding,
immersion,
mopping,
wiping,
CIP,
flow
method.

 
Application
to
glasses,
dishes,
stoves,
countertops,
and
silverware
by
brush,
foam,
wiping,
low
pressure
spray,
trigger
sprayer,
and
immersion.

 
Application
to
fruits
and
vegetables
by
immersion.

 
Application
to
food
dispensing
equipment
through
circulation
cleaning
system.
Use
Site
Category
III
Commercial/
Institutional
and
Industrial
Premises
and
Equipment
Toilet
bowls,
urinals,
shower
stalls;
institutional
premises1,2
 
Application
to
hard
surfaces
through
cloth,
sponge,
bowl
mop,
liquid
pour,
or
immersion.

Benzenesulfonic
Acid,
C10­
C16
alkyl
derivatives
(
CAS
No.
68584­
22­
5)

Use
Site
Category
I
Agricultural
Premises
and
Equipment
Dairy
farms
 
Application
to
hard
surfaces
through
foam,
brush,
immersion,
low
pressure
spray.
Page
10
of
36
Table
3
Potential
Use
Scenarios
Based
on
Product
Labels
for
Alkylbenzene
Sulfonates
Use
Site
Category
Example
Use
Sites
Scenarios
Use
Site
Category
II
Food
Handling/
Storage
Establishments
Premises
and
Equipment
Dairy
and
food
processing
plants;
restaurants;
beverage
plants;
meat
and
poultry
plants
 
Application
to
hard
surfaces
and
equipment
through
brush,
immersion,
low
pressure
spray,
foam,
and
CIP.

 
Application
to
glasses,
stoves,
countertops,
dishes
and
silverware
by
brush,
foam,
wiping,
low
pressure
spray,
trigger
sprayer,
and
immersion.

 
Application
to
food
dispensing
equipment
through
circulation
cleaning
system.
Use
Site
Category
III
Commercial/
Institutional
and
Industrial
Premises
and
Equipment
Institutional
establishments2
 
Application
to
hard
surfaces
and
equipment
through
brush,
immersion,
low
pressure
spray,
and
foam.

1:
These
bathroom
sites,
on
label
Reg.
#
3635­
279,
are
assumed
to
be
in
industrial,
institutional,
and
commercial
premises,
not
residential.
A
complete
discussion
of
the
label
terminology
leading
to
the
Agency's
decision
not
to
assess
residential
exposure
is
included
in
Section
4.1,
Residential
Exposure.
2:
Institutional
premises
can
include
daycare
centers
in
which
there
is
potential
exposure
to
children.
However,
hard
surfaces
that
are
treated
with
this
product
do
not
include
floors.
For
example,
Reg.
#
74210­
1
lists,
"
plates,
utensils,
cups,
[
and]
glasses,"
as
the
use
sites
for
institutional
premises.
As
mentioned
in
footnote
number
1,
a
more
elaborate
discussion
on
label
terminology
leading
to
the
conclusion
that
a
residential
exposure
assessment
is
not
warranted
(
handler
or
post
application)
is
included
in
Section
4.1.

From
Table
3,
the
Agency
selected
representative
exposure
scenarios
to
assess
for
the
occupational
inhalation
exposure
assessment.
The
selections
were
based
on
the
product
usage
patterns
and
are
believed
to
provide
high­
end
degrees
of
dermal,
inhalation,
or
incidental
ingestion
exposure.
The
representative
scenarios
assessed
in
this
document
are
shown
in
Table
5.

3.0
SUMMARY
OF
TOXICITY
DATA
3.1
Acute
Toxicity
The
acute
toxicity
is
also
presented
in
the
toxicological
chapter
of
this
RED.
The
data
base
for
acute
toxicity
is
considered
complete.
No
additional
studies
are
required
at
this
time.
The
acute
toxicity
data
on
the
Linear
alkylbenzene
Sulfonate
(
LAS)
Technical
is
summarized
below
in
Table
3.1.
Page
11
of
36
Table
3.1.
Acute
Toxicity
Data
on
Linear
alkylbenzene
Sulfonate
(
LAS):

Guideline
No./
Study
Type
MRID
No.
Results
Toxicity
Category
870.1100
Acute
oral
toxicity
Multiple
LD50
=
range
from
404
to
over
5000
mg/
kg
III­
IV
870.1200
Acute
dermal
toxicity
94032006
LD50
=
1200
mg/
kg
II
870.1300
Acute
inhalation
toxicity
003442*
LC50
=
200
mg/
L
IV
870.2400
Acute
eye
irritation
0033443*
Corneal
opacity
not
reversed
at
72
hours.
I
870.2500
Acute
dermal
irritation
003444*
Severe
irritation
at
72
hours
II
870.2600
Skin
sensitization
Open
Literature
{
Nusair
TL,
PJ
Danneman,
J
Stotte,
PHS
Bay
(
1988)
Consumer
Products:
Risk
Assessment
Process
for
Contact
Sensitization,
Toxicologist
8:
258.
(
HERA)}
Weak
to
moderate
sensitization
*
Tox
record
No.

3.2
Summary
of
Toxicity
Endpoints
Table
4
indicates
the
toxicological
endpoints
that
were
developed
for
the
assessment
of
the
alkylbenzene
sulfonates.
The
complete
discussion
is
included
in
the
toxicological
chapter
of
the
alkylbenzene
sulfonate
RED.
Page
12
of
36
Table
4.
Summary
of
Toxicological
Dose
and
Endpoints
for
Alkylbenzene
Sulfonates
Exposure
Scenario
Dose
Used
in
Risk
Assessment,
UF
Special
FQPA
SF*,
endpoint
and
Level
of
Concern
for
Risk
Assessment
Study
and
Toxicological
Effects
Acute
Dietary
(
All
populations)
No
endpoint
was
selected.
No
effects
are
attributable
to
a
single
dose.

Chronic
Dietary
(
All
populations)
Systemic/
Reproductive
NOAEL=
50
mg/
kg/
day
UF
=
100
Chronic
RfD
=
0.5
mg/
kg/
day
FQPA
SF
=
1X
cPAD
=
chronic
RfD
FQPA
SF
=
0.5
mg/
kg/
day
Systemic/
Reproductive
LOAEL
=
250
mg/
kg/
day
based
on
decreased
Day
21
female
pup
body
weight
(
Buehler,
E.
et
al.
1971.
Tox.
Appl.
Pharmacol.
18:
83­
91)

plus
LOAEL=
145
mg/
kg/
day
from
9
month
drinking
water
rat
study
based
on
decreased
body
weight
gain,
and
serum/
biochemical
and
enzymatic
changes
in
the
liver
and
kidney
(
Yoneyama
et
al.
1976
Ann.
Rep.
Tokyo
Metrop.
Res.
Lab.
Public
Health
27(
2):
105­
112)

plus
LOAEL=
114
mg/
kg/
day
(
0.2%)
based
on
increased
caecum
weight
and
slight
kidney
damage
in
a
6
month
rat
dietary
study
(
Yoneyama
et
al
1972
Ann.
Rep.
Tokyo
Metrop.
Res.
Lab.
Public
Health
24:
409­
440)

Short­
Term
Incidental
Oral
(
1­
30
days)
Oral
NOAEL=
50
mg/
kg/
day
Residential
LOC
for
MOE
=
100
Systemic/
Reproductive
LOAEL
=
250
mg/
kg/
day
based
on
decreased
Day
21
female
pup
body
weight
(
Buehler,
E.
et
al.
1971.
Tox.
Appl.
Pharmacol.
18:
83­
91)

plus
LOAEL=
145
mg/
kg/
day
from
9
month
drinking
water
rat
study
based
on
decreased
body
weight
gain,
and
serum/
biochemical
and
enzymatic
changes
in
the
liver
and
kidney
(
Yoneyama
et
al.
1976
Ann.
Rep.
Tokyo
Metrop.
Res.
Lab.
Public
Health
27(
2):
105­
112)

plus
LOAEL=
114
mg/
kg/
day
(
0.2%)
based
on
increased
caecum
weight
and
slight
kidney
damage
in
a
6
month
rat
dietary
study
(
Yoneyama
et
al
1972
Ann.
Rep.
Tokyo
Metrop.
Res.
Lab.
Public
Health
24:
409­
440)
Page
13
of
36
Table
4.
Summary
of
Toxicological
Dose
and
Endpoints
for
Alkylbenzene
Sulfonates
Exposure
Scenario
Dose
Used
in
Risk
Assessment,
UF
Special
FQPA
SF*,
endpoint
and
Level
of
Concern
for
Risk
Assessment
Study
and
Toxicological
Effects
Short­,
intermediateand
Long­
Term
Inhalation
(
1
to
30
days,
1­
6
months,
>
6
months)
Inhalation
study
NOAEL=
1mg/
m3
detergent
dust
combined
with
up
to
0.1
mg/
m3
enzyme
dust
Equivalent
to
approximately
0.14
mg/
kg/
day
(
a)
(
inhalation
absorption
rate
=
100%)
purity=
13%
active
ingredient
Residential
LOC
for
MOE
=
100
Occupational
LOC
for
MOE
=
100
Subchronic
Inhalation
Monkey
Study
LOAEL
=
10
mg/
m3
detergent
combined
with
0.1
mg/
m3
enzyme
dust
based
on
weight
loss
and
decreased
weight
gain
(
W.
Coates,
et
al
1978.
Tox.
Appl.
Pharmacol.
45:
477­
496)
This
air
concentration
is
equivalent
to
approximately
1.4
mg/
kg/
day
(
a)

Dermal
Endpoint
Quantification
of
dermal
risk
is
not
required
since:
1)
the
alkylbenzene
sulfonates
are
surfactants
that
are
dermal
irritants
at
concentrations
generally
greater
than
20%
solution
(
WHO
1996).
Thus,
dermal
exposure
would
be
self­
limiting
to
preclude
dermal
irritation.
Most
pesticide
formulations
have
less
than
5%
alkylbenzene
sulfonates
as
an
inert
ingredient,
with
the
vast
majority
of
household
products
containing
approximately
2%.
Additionally,
the
requirement
of
the
dermal
toxicity
studies
with
the
end­
use
product
will
determine
whether
personal
protective
clothing
would
be
necessary
to
protect
against
irritation
during
product
use;
2)
no
systemic
toxicity
was
seen
following
repeated
dermal
applications
to
rabbits
at
200
mg/
kg/
day
(
with
an
end
use
product);
3)
no
developmental
toxicity
concerns
were
seen
following
repeated
dermal
applications
to
pregnant
mice,
rats
or
rabbits
(
developmental
effects
were
seen
either
in
the
presence
of
maternal
toxicity
or
at
doses
higher
than
those
that
caused
maternal
toxicity);
and
4)
there
is
no
residential
exposure
to
alkylbenzene
sulfonates
as
an
active
ingredient,
however,
residential
exposure
from
its
use
as
an
inert
ingredient
in
pesticide
formulations
is
expected
to
be
of
an
intermittent
nature
(
i.
e,
no
continuous,
constant
contact,
multi­
day
exposure)
from
household
products.

Cancer
(
oral,
dermal,
inhalation)
No
evidence
of
carcinogenicity
in
reported
studies
in
rats
done
before
1980
GLPs
UF
=
uncertainty
factor,
FQPA
SF
=
Special
FQPA
safety
factor,
NOAEL
=
no
observed
adverse
effect
level,
LOAEL
=
lowest
observed
adverse
effect
level,
PAD
=
population
adjusted
dose
(
a
=
acute,
c
=
chronic)
RfD
=
reference
dose,
MOE
=
margin
of
exposure,
LOC
=
level
of
concern,
NA
=
Not
Applicable
NOTE:
No
Special
FQPA
Safety
Factor
recommended
because
it
is
assumed
that
the
exposure
databases
(
dietary
food,
drinking
water,
and
residential)
are
complete
and
that
the
risk
assessment
for
each
potential
exposure
scenario
includes
all
metabolites
and/
or
degradates
of
concern
and
does
not
underestimate
the
potential
risk
for
infants
and
children.
(
a)
Equation
used
to
convert
inhalation
air
concentration
to
a
dose=
mg/
L*
absorption*
respiratory
volume
(
L/
hr)*
duration
(
hrs)
*
activity
factor
/
body
weight.
Thus,
0.001
mg/
L
*
1*
67.94
L/
hr
(
based
on
default
respiratory
volumes
for
a
New
Zealand
Rabbit
which
is
used
as
a
surrogate
for
a
cynomolgus
monkey)
*
6
hrs
*
1
/
2.98
kg
(
body
weight
for
New
Zealand
Rabbit
used
as
a
surrogate
for
cynomolgus
monkey,
study
reports
monkey
body
weight
ranges
from
1.6
to
3.7
kg).
Page
14
of
36
3.3
FQPA
Considerations
These
considerations
are
also
presented
in
the
toxicological
chapter
for
this
RED.

Special
Sensitivity
to
Infants
and
Children
Based
on
the
available
hazard
data,
it
doesn't
appear
that
LAS
exposure
in
laboratory
animal
studies
results
in
any
special
sensitivity
to
the
young.
Therefore,
the
FQPA
factor
may
be
reduced
to
1X.

Several
reproduction
and
many
developmental
studies
have
been
performed
with
LAS
in
a
number
of
animal
species.
In
the
developmental
studies,
whenever
toxicity
was
observed
in
adults,
it
was
generally
for
mild
effects
(
slight
body
weight
changes,
intestinal
disturbances)
except
for
severe
dermal
irritation
effects
in
dermal
developmental
studies.
Any
developmental
toxicity
observed
in
these
same
studies
included
minor
increases
in
visceral/
skeletal
anomalies
and
some
fetal
losses;
but
only
at
maternally
toxic
doses.

In
one
reproduction
study
(
Buehler
et
al.,
1971),
there
were
slight
changes
in
hematology
and
histopathology
(
both
within
historical
control
ranges)
and
slight
decreases
in
body
weight
in
the
offspring
at
the
highest
dose
of
250
mg/
kg/
d
(
at
which
there
were
no
effects
on
the
parental
generation).
There
were
no
effects
in
either
the
parental
or
offspring
in
the
other
two
reproductive
toxicity
studies
(
see
Toxicity
Profile
Table)
 
high
doses
of
70
or
170
mg/
kg/
d.

There's
no
evidence
in
the
literature
to
indicate
any
neurotoxic
effects
of
LAS
in
humans
or
laboratory
animal.

There
is
no
need
for
a
special
FQPA
factor
because
the
mid­
dose
level
of
50
mg/
kg/
d
(
NOAEL
for
offspring
effects)
in
the
Buehler
study
is
the
basis
for
the
chronic
RfD
of
50
mg/
kg/
d.
Thus,
the
chronic
hazard
value
is
based
on
slight
pup
effects
and
is
protective
of
laboratory
animals
of
all
ages
in
this
hazard
assessment.

Recommendation
for
a
Developmental
Neurotoxicity
Study
A
DNT
is
not
required
because
there
is
no
evidence
of
either
neurotoxicity
or
susceptibility
to
the
young
following
LAS
exposure
to
laboratory
animals.

4.0
RESIDENTIAL
EXPOSURE
ASSESSMENT
4.1
Residential
Exposure
Based
on
the
Agency's
professional
judgment,
there
is
no
residential
exposure
to
assess
at
this
time
for
products
that
contain
the
alkylbenzene
sulfonates
as
the
active
ingredient.
The
Agency
acknowledges
that
there
are
labels
with
language
which
initially
appear
to
warrant
a
residential
assessment,
and
these
specific
labels
are
discussed
below
along
with
justification
for
not
conducting
the
residential
risk
assessment.
Again,
to
reiterate,
there
is
a
separate
dietary
chapter
that
will
be
provided
for
the
dietary
risks
that
stem
from
the
use
of
products
containing
alkylbenzene
sulfonates.
There
will
also
be
a
separate
inert
chapter
to
assess
the
exposure
to
products
that
contain
alkylbenzene
sulfonates
as
the
inert
ingredient.
Page
15
of
36
 
Reg.
#
71094­
1
(
PRO­
SAN),
and
#
71094­
2
(
PRO­
SAN
L)
direct
use
on
but
not
limited
to
the
following
food
preparation
areas:
countertops,
cutting
boards,
dishes
and
utensils
that
are
found
in
kitchens,
restaurants,
and
other
eating
establishments
along
with
dairies
and
food
processing
plants.
The
method
of
application
for
these
surfaces
includes
brush,
wiping,
foam,
sponge,
or
low­
pressure
spray.
These
labels
also
include
directions
for
fruit
and
vegetable
washing
via
immersion,
spraying,
scrubbing
(
with
a
mesh
pad,
brush,
or
by
mechanical
agitation).
There
is
also
a
use
for
circulation
cleaning
and
sanitizing
of
equipment
(
such
as
soft
ice
cream,
juice,
and
vending
machines).

Based
on
the
titles
of
these
products
indicating
"
professional
sanitation"
along
with
the
use
patterns
and
use
rates
on
these
labels,
it
is
assumed
that
these
products
are
distributed
to
commercial
or
industrial
users,
and
not
to
residential
handlers.
There
is
no
indication
that
excludes
residential
use
sites,
and
it
is
suggested
that
language
is
included
on
these
labels
to
restrict
the
use
sites
so
that
there
is
no
risk
of
these
products
ending
up
in
the
hands
of
residential
homeowners.

Several
of
the
labels
also
restrict
label
use
to
industry
only
but
there
are
some
exceptions
in
which
a
label
was
not
exclusive
to
industrial
applications.
In
these
cases,
label
language
and
use
sites
were
used
to
justify
that
a
residential
risk
assessment
is
not
warranted
at
this
time.

 
Some
of
the
labels
that
did
not
restrict
product
usage
to
industrial
applications.
These
labels
include
but
are
not
limited
to
the
following
use
sites:
food­
processing
equipment
in
dairies,
beverage,
and
food
processing
plants
(
Reg.
Numbers
associated
with
this
statement
include:
#
1670­
150,
#
1270­
254,
#
4959­
29,
#
9152­
18,
#
150­
61,
and
#
2686­
10).
Due
to
the
use
sites
that
were
directed
on
these
labels,
there
appears
to
be
no
residential
risk.
 
This
group
of
labels
does
not
restrict
product
use
to
industrial
applications
and
there
is
the
use
site
category
of,
"
institutional
premises."
The
Agency
includes
daycares
as
a
potential
facility
included
in
the
institutional
category.
Based
on
the
language
of
these
labels,
there
appears
to
be
no
risk
to
children
in
daycares
(
post
application
exposure
to
treated
floors)
because
of
the
specific
surfaces
that
the
products
are
applied
to.
These
include
but
are
not
limited
to
food
serving
equipment,
dishes,
utensils,
pots,
and
pans
(
Reg.
Numbers
associated
with
this
statement
include:
#
74210­
1,
#
875­
85,
#
875­
185,
#
1677­
56,
#
5389­
12,
#
5174­
11,
#
65001­
1).
 
Label
Reg.
#
3635­
279
includes
the
cleaning
of
toilets
and
shower
stalls,
but
the
label
restricts
the
use
of
the
product
to
industrial,
institutional,
and
commercial
premises.
In
addition,
the
surfaces
to
be
cleaned
are
restricted
to
toilets
and
shower
stalls
so
that
there
is
no
expected
post
application
exposure
risk
for
children's
exposure
to
treated
floors
in
daycares.
 
Label
Reg.
#
7546­
4
has
language
that
specifies
that
institutional
and
commercial
premises
are
the
use
sites,
but
does
restrict
use
of
the
product
to:
food
service
areas
of
public
eating
places,
healthcare
facilities,
schools,
and
bars
for
the
purpose
of
sanitizing
glassware
and
other
utensils.
Again,
it
is
assumed
that
there
is
no
post
application
exposure
risk
for
children
on
treated
floors
in
daycares.
Page
16
of
36
5.0
OCCUPATIONAL
EXPOSURE
ASSESSMENT
The
exposure
scenarios
that
are
assessed
in
this
document
for
the
representative
uses
for
sodium
dodecylbenzene
sulfonate,
dodecylbenzene
sulfonic
acid,
and
benzenesulfonic
acid,
C10­
C16
alkyl
derivatives
are
shown
in
Tables
5.
The
table
shows
the
maximum
application
rate
associated
with
the
representative
use
and
the
appropriate
EPA
Registration
number
for
the
product
label.
Potential
occupational
handler
exposure
can
occur
in
various
use
sites,
which
include;
agricultural
premises,
food
handling
premises,
and
commercial/
institutional/
industrial
premises.
It
should
be
noted
that
for
the
calculation
of
application
rates
in
which
8.34
lb
a.
i./
gal
is
noted,
the
product
is
assumed
to
have
the
density
of
water
because
it
is
diluted
with
water.

However,
it
will
be
apparent
that
throughout
Table
5,
that
some
of
the
application
methods
are
repeated.
This
is
because
when
the
labels
that
contain
sodium
dodecylbenzene
sulfonate
as
the
active
ingredient
were
not
chosen
to
be
the
representative
label
for
all
of
the
sulfonates
(
e.
g.
highest
application
rate),
they
still
had
to
be
included
so
that
the
total
MOE
assessment
could
be
conducted.
This
was
necessary
because
all
of
the
products
that
contain
sodium
dodecylbenzene
sulfonate
as
the
active
ingredient
have
label
direction
for
the
product
to
be
used
for
both
cleaning
and
sanitizing
in
the
same
time
frame.
For
this
reason,
the
risks
resulting
from
the
use
of
the
products
that
contain
sodium
dodecylbenzene
sulfonate
were
assessed
individually,
even
if
they
were
not
chosen
as
the
representative
scenarios.
Subsequently,
these
handful
of
labels
were
then
assessed
jointly
to
generate
a
total
exposure
assessment
(
combined
scenarios
are
identified
in
Table
6).

There
are
also
some
application
methods
that
are
assumed
to
be
similar,
but
are
only
different
in
wording.
The
CIP
(
Cleaning
in
Place),
circulation,
flow
method,
and
flushing
methods
are
all
assumed
to
be
the
same
in
terms
of
quantity
handled
and
unit
exposure
values.
For
example,
label
Reg.
#
5389­
12
states,
"
For
closed
CIP
systems,
fill
the
system
with
fresh
sanitizer
solution
and
allow
the
solution
to
stay
in
contact
with
internal
parts
for
10
minutes
before
draining
the
system.
For
circulating
CIP
dairy
dispensing
systems,
circulate
a
fresh
sanitizer
solution
through
the
dairy
dispensing
machine
for
10
minutes
before
draining
the
machine."
Label
Reg.
#
9152­
18
states,
"
To
sanitize
by
flow
method:
add
1oz.
[
product]
to
2
gallons
water.
Pump
through
the
system..."
These
specific
examples
support
that
these
methods
can
be
assessed
as
one
group
when
they
are
applied
to
the
same
use
site.
Also,
these
methods
of
application
are
via
closed
systems.
So
any
potential
human
exposure
is
expected
to
occur
when
the
solution
to
be
placed
in
the
system
is
prepared
or
for
the
process
of
loading
the
solution
into
the
system
to
be
cleaned.
Page
17
of
36
Table
5:
Representative
Exposure
Scenarios
Associated
with
Occupational
Exposures
to
Alkylbenzene
Sulfonates
Representative
Use
Method
of
Application
Exposure
Scenario
Registration
#
Application
Rate1
Agricultural
Premises
and
Equipment
(
Use
Site
Category
I)

 
Brush
 
Mechanical
Foam
ST
and
IT
Handler:
inhalation
74210­
12
0.0667
lb
ai/
gal
(
25.6%
ai
x
4
oz
product/
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
Flooding
ST
and
IT
Handler:
inhalation
875­
185
0.00183
lb
ai/
gal
(
4.5%
ai
x
2.5
oz
product/
4
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
Flushing3
 
Circulation/
recirculation
system3
 
Flow
method3
ST
and
IT
Handler:
inhalation
4959­
29
0.00195
lb
ai/
gal
(
15%
ai
x
1
oz
product/
5
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
High
pressure
spray4
ST
and
IT
Handler:
inhalation
875­
85
0.00326
lb
ai/
gal
(
5%
ai
x
2
oz
product/
2
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)
Indoor
Hard
Surfaces
(
includes
stainless
steel,
plastic,
tiles)

 
Immersion
 
Low
pressure
spray
 
Trigger
pump
spray
ST
and
IT
Handler:
inhalation
74210­
12
0.00334
lb
ai/
gal
(
25.6%
ai
x
2
oz
product/
10
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

Food
Handling
(
Use
Site
Category
II)

 
Brush5
 
Mechanical
foam6
ST
and
IT
Handler:
inhalation
74210­
12
0.0667
lb
ai/
gal
(
25.6%
ai
x
4
oz
product/
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
Brush
(
sanitize)
ST
and
IT
Handler:
inhalation
0.0115
lb
ai/
gal
(
2.75%
ai
x
5%
solution
x
8.34
lb/
gal)

 
Brush
(
cleaning)
ST
and
IT
Handler:
inhalation
1020­
132,7
0.0018
lb
ai/
gal
(
2.75%
ai
x
1oz.
product/
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
Brush
(
cleaning)
ST
and
IT
Handler:
inhalation
71094­
12,8
(
WSP)
9
0.00603
lb
ai/
gal
(
3.6%
ai
x
0.67
lb
product/
4
gal
water)

 
Brush
(
cleaning)
ST
and
IT
Handler:
inhalation
71094­
22,10
(
RTU)
9
0.00300
lb
ai/
gal
(
0.036%
ai
x
8.34
lb/
gal)
Indoor
Hard
Surfaces
(
includes
dishes
and
silverware)

 
Foaming
(
cleaning)
ST
and
IT
Handler:
inhalation
71094­
12,8
(
WSP)
9
0.00603
lb
ai/
gal
(
3.6%
ai
x
0.67
lb
product/
4
gal
water)
Page
18
of
36
Table
5:
Representative
Exposure
Scenarios
Associated
with
Occupational
Exposures
to
Alkylbenzene
Sulfonates
Representative
Use
Method
of
Application
Exposure
Scenario
Registration
#
Application
Rate1
 
Circulation
system11
 
Flushing11
 
Flow
method11
 
Immersion
 
Trigger
pump
sprayer
ST
and
IT
Handler:
inhalation
74210­
12
0.00334
lb
ai/
gal
(
25.6%
ai
x
2
oz
product/
10
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
Low
pressure
spray
(
cleaning)
0.00603
lb
ai/
gal
(
3.6%
ai
x
0.67
lb
product/
4
gal
water)

 
Low
pressure
spray
(
sanitizing)
ST
and
IT
Handler:
inhalation
71094­
12,8
(
WSP)
9
0.00302
lb
ai/
gal
(
3.6%
ai
x
0.67
lb
product/
8
gal
water)

 
Low
Pressure
Spray
(
cleaning)

 
Trigger
pump
(
sanitize)
ST
and
IT
Handler:
inhalation
71094­
22,10
(
RTU)
9
0.00300
lb
ai/
gal
(
0.036%
ai
x
8.34
lb/
gal)

 
High
pressure
spray
(
sanitize)
12
0.0115
lb
ai/
gal
(
2.75%
ai
x
5%
solution
x
8.34
lb/
gal)

 
High
pressure
spray
(
cleaning)
ST
and
IT
Handler:
inhalation
1020­
132,7
0.0018
lb
ai/
gal
(
2.75%
ai
x
1oz.
product/
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
Immersion
(
sanitizing)

 
Flooding
(
sanitizing)
ST
and
IT
Handler:
inhalation
71094­
12,8
(
WSP)
9
0.00302
lb
ai/
gal
(
3.6%
ai
x
0.67
lb
product/
8
gal
water)

 
Immersion
(
sanitizing)

 
Flooding
(
sanitizing)
ST
and
IT
Handler:
inhalation
71094­
22,10
(
RTU)
9
0.00300
lb
ai/
gal
(
0.036%
ai
x
8.34
lb/
gal)

 
Mop
ST
and
IT
Handler:
inhalation
65001­
113
0.00244
lb
ai/
gal
(
15%
ai
x
1
oz/
4
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
Wiping
surfaces
(
cleaning)
ST
and
IT
Handler:
inhalation
71094­
12,8
(
WSP)
9
0.00603
lb
ai/
gal
(
3.6%
ai
x
0.67
lb
product/
4
gal
water)

 
Sponge/
Mesh/
Wiping
(
cleaning)
ST
and
IT
Handler:
inhalation
71094­
22,10
(
RTU)
9
0.00300
lb
ai/
gal
(
0.036%
ai
x
8.34
lb/
gal)

CIP
(
cleaning)
14
ST
and
IT
Handler:
inhalation
1020­
13
0.00358
lb
ai/
gal
(
2.75%
ai
x
2
oz
product/
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)
Page
19
of
36
Table
5:
Representative
Exposure
Scenarios
Associated
with
Occupational
Exposures
to
Alkylbenzene
Sulfonates
Representative
Use
Method
of
Application
Exposure
Scenario
Registration
#
Application
Rate1
 
Circulation
systems/
flow
method
ST
and
IT
Handler:
inhalation
74210­
1
0.00334
lb
a.
i./
gal
(
25.6%
a.
i.
x
2
oz
product/
10
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
Circulations
systems
(
cleaning)
0.00603
lb
ai/
gal
(
3.6%
ai
x
0.67
lb
product/
4
gal
water)
Food
dispensing
equipment
 
Circulations
systems
(
sanitize)
ST
and
IT
Handler:
inhalation
71094­
1
0.00302
lb
ai/
gal
(
3.6%
ai
x
0.67
lb
product/
8
gal
water)

 
Immersion
ST
and
IT
Handler:
inhalation
71695­
1
0.00455
lb
a.
i./
gal
(
17.46
%
a.
i.
x
2
oz/
5
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
Immersion
ST
and
IT
Handler:
inhalation
71094­
1
0.00603
lb
ai/
gal
(
3.6%
ai
x
0.67
lb
product/
4
gal
water)
Fruit
and
Vegetable
washing
 
Trigger
pump
spray
ST
and
IT
Handler:
inhalation
71094­
2
0.00300
lb
ai/
gal
(
0.036%
ai
x
8.34
lb/
gal)
Commercial/
Institutional
and
Industrial
Premises
and
Equipment
(
Use
Site
Category
III)

 
Brush
 
Mechanical
foam6
ST
and
IT
Handler:
inhalation
74210­
12
0.0667
lb
ai/
gal
(
25.6%
ai
x
4
oz
product/
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)
Indoor
Hard
Surfaces
(
includes
dishes
and
silverware)

 
Immersion
 
Low
pressure
sprayer
 
Trigger
pump
sprayer
ST
and
IT
Handler:
inhalation
74210­
12
0.00334
lb
ai/
gal
(
25.6%
ai
x
2
oz
product/
10
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)

 
Mopping
ST
and
IT
Handler:
inhalation
3635­
279
0.0177
lb
ai/
gal
(
15.52%
ai
x
1.75
oz/
gal
water
x
1
gal/
128
oz
x
8.34
lb/
gal)
Shower
Stalls/
toilets
 
Liquid
pour
 
Wiping
ST
and
IT
Handler:
inhalation
3635­
279
1.49
lb
ai/
gal
(
15.52%
ai
x
9.61
lb/
gal)
15
1.
All
application
rates
for
the
soluble
concentrate
and
ready­
to­
use
liquid
products
were
calculated
assuming
the
product
has
the
same
density
as
water
(
8.34
lb/
gal).
2.
This
product
can
be
used
on
food
contact
surfaces
in
industrial
premises.
3.
Flushing,
circulation
and
flow
method
are
considered
to
be
the
same
application
method.
Flow
method,
as
described
on
label
#
9152­
18
is
" 
pump[
ing]
through
system
until
full
flow
is
obtained 
close
drain
valves 
drain
solution,
and
air
dry."
4.
High
pressure
spray
is
assumed
to
be
representative
of
a
"
coarse
droplet
spray"
per
label
#
833­
75
and
#
875­
184
which
both
state
"
high
pressure
spray
cleaning
using
a
coarse
droplet".
5.
Label
Reg.
#
74210­
1
has
language
that
states
for
manual
cleaning
(
brush
or
scrub),
1­
2
ounces
of
product
should
be
diluted
with
a
gallon
of
water.
The
label
also
has
a
general
direction
that
the
product
is
to
be
used
on
all
hard
nonporous
surfaces
in
industrial
use
sites.
The
label
also
has
the
direction
for
mechanical
foam
application
listed
as
4
ounces
product/
gallon
of
water
is
to
be
applied,
"
to
surfaces
by
manual
procedures
or
by
mechanical
foam."
It
is
assumed
Page
20
of
36
that
"
manual
procedures"
is
indicative
of
brush
applications.
6.
Mechanical
foam
is
listed
for
mineral
film
removal
and
regular
foaming
is
listed
as
a
general
cleaning
instruction.
These
methods
are
listed
on
the
same
label
with
application
specific
use
rates,
which
is
why
they
are
both
listed
in
the
table.
However,
for
assessment
purposes,
mechanical
foam
and
regular
foaming
share
the
same
unit
exposure
values.
Also,
the
application
rate
for
mechanical
foam
is
higher
than
that
for
regular
foaming,
so
the
mechanical
foaming
application
is
assumed
representative
for
the
foaming
application.
7.
Label
Reg.
#
1020­
13
states
that
there
is
a
cleaning
step
and
a
sanitizing
step,
and
there
are
different
application
rates
for
each
of
these
steps.
The
label
does
not
specify
which
method
of
application
for
cleaning
and
sanitizing
should
follow
each
other
(
i.
e.
coarse
spray
sanitizing
followed
by
either
coarse
spray
rinse
or
brush
rinse).
Because
the
cleaning
and
sanitizing
step
occur
in
the
same
time
frame,
a
total
exposure
effect
will
result.
8.
Label
Reg.
#
71094­
1
states
that
there
is
a
cleaning
step
and
a
sanitizing
step.
According
to
label
#
71094­
1,
the
cleaning
step
involves
application
of
the
product
through
brush,
foam,
wipe
or
low
pressure
spray
and
the
sanitizing
step
involves
application
of
the
product
through
immersion,
flooding,
or
spraying.
The
label
does
not
specify
which
methods
of
cleaning
and
sanitizing
steps
should
be
used
jointly.
Because
the
cleaning
and
sanitizing
step
occur
in
the
same
time
frame,
a
total
exposure
effect
will
result.
9.
Exposure
to
both
the
water
soluble
packing
and
ready­
to­
use
formulation
were
assessed.
Even
though
the
water
soluble
packaging
(
0.67
lbs)
has
a
higher
application
rate,
the
unit
exposure
values
for
ready­
to­
use
products
(
liquid
pour
data)
are
higher.
10.
Label
Reg.
#
71094­
2
states
that
there
is
a
cleaning
step
and
a
sanitizing
step.
According
to
label
#
71094­
2,
the
cleaning
step
involves
application
of
the
product
through
sponge,
brush,
mesh,
wipe
or
low
pressure
spray
and
the
sanitizing
step
involves
application
of
the
product
through
immersion,
flooding,
or
spraying.
The
label
does
not
specify
which
methods
of
cleaning
and
sanitizing
steps
should
be
used
jointly.
Because
the
cleaning
and
sanitizing
step
occur
in
the
same
time
frame,
a
total
exposure
effect
will
result.
11.
CIP,
circulation
system,
flushing
and
flow
method
are
all
considered
to
be
the
same
application
method
in
terms
of
potential
exposure.
12.
Coarse
spraying,
as
directed
on
label
#
1020­
13
is
assumed
to
be
analogous
with
"
coarse
droplet
spray"
per
labels
#
833­
75
and#
875­
184
which
states
"
high
pressure
spray
cleaning
using
a
coarse
droplet".
As
a
result,
unit
exposures
for
this
scenario
use
those
developed
for
high
pressure
spray.
13.
The
label
Reg.
#
65001­
1
lists
1
ounce
per
4
gallons
of
water
for
the
directed
dilution.
This
is
equivalent
to
200ppm.
The
label
states
the
ppm
concentration
that
can
be
allowed
for
the
product
to
be
300
ppm.
This
value
is
equivalent
to
1
ounce
of
product
per
4
gallons
of
water
dilution,
and
this
is
the
value
that
was
used
in
the
assessment.
14.
CIP
=
cleaning
in
place;
metered/
closed
system
application
15.
Because
the
product
is
applied
directly
as
a
concentrate
to
clean
and
disinfect,
the
density
of
the
product
itself,
not
water,
was
used
in
the
calculation
Page
21
of
36
Table
6
Representative
Exposure
Scenarios
Assessed
for
the
Products
that
Contain
Sodium
Dodecylbenzene
Sulfonate
as
the
Active
Ingredient
Representative
Use
Registration
#
Method
of
CLEANING
Application
Method
of
SANITIZING
Application
Groups
assessed
1
Food
Handling/
Storage
Establishments
Premises
and
Equipment
(
Use
Site
Category
II)

1020­
13
High
Pressure
spray
Brush
High
Pressure
spray
Brush
High
pressure
spray
with
high
pressure
spray
or
brush
Brush
with
high
pressure
spray
or
brush
71094­
1
Low
pressure
spray
Wiping
Foam
Brush
Immersion
Flooding
Low
pressure
spray
Low
pressure
spray
with
immersion/
flooding,
or
low
pressure
spray
Wiping
with
immersion/
flooding,
or
low
pressure
spray
Foam
with
immersion/
flooding,
or
low
pressure
spray
Brush
with
immersion/
flooding,
or
low
pressure
spray
71094­
2
Sponge/
Mesh/
Wip
ing
Low
Pressure
Spray
Brush
Immersion
Flooding
Trigger
Pump
Sponge
with
immersion/
flooding,
or
spraying
Low
pressure
spray
with
immersion/
flooding,
or
spraying
Brush
with
immersion/
flooding,
or
spraying
Indoor
Hard
Surfaces
(
includes
dishes
and
silverware)

1020­
13
CIP
(
liquid
pour)
CIP
(
liquid
pour)
Liquid
pour
for
both
the
cleaning
and
sanitizing
steps
Food
dispensing
equipment
71094­
1
Circulation
system
(
solid
place)
Circulation
system
(
solid
place
)
Solid
place
for
both
the
cleaning
and
sanitizing
steps
Fruit
and
Vegetable
Washing
There
are
no
separate
steps
for
cleaning
and
sanitizing
for
this
use
site,
it
only
involves
cleaning.

1:
The
groups
that
are
listed
are
the
different
combinations
of
cleaning
and
sanitizing
methodologies
that
can
subsequently
occur.
These
are
the
combinations
that
are
assessed
in
Table
8.
Page
22
of
36
5.1
Occupational
Handler
Exposures
The
occupational
handler
scenarios
included
in
Tables
5
and
6
were
assessed
to
determine
baseline
inhalation
exposures.
The
general
assumptions
and
equations
that
were
used
to
calculate
occupational
handler
risks
are
provided
in
Appendix
A.
The
majority
of
the
scenarios
were
assessed
using
CMA
data
and
Equations
1­
3
in
Appendix
A.
However,
for
the
occupational
scenarios
in
which
CMA
data
were
insufficient,
other
data
and
methods
were
applied.
The
majority
of
the
labels
assessed
for
this
chapter
indicate
that
PPE
(
gloves,
protective
clothing,
and
goggles/
face
shield)
are
to
be
used.
At
this
time,
there
is
no
dermal
endpoint
that
has
been
calculated
for
this
chemical.
Because
of
this,
there
was
no
dermal
assessment
conducted.

There
are
also
total
MOEs
that
are
presented
in
Table
8,
which
were
calculated
because
of
the
use
direction
found
on
the
labels
that
contain
sodium
dodecylbenzene
sulfonate
as
the
active
ingredient.
The
scenarios
that
are
assessed
in
this
table
were
extracted
from
Table
6.
The
total
MOE
was
calculated
using
the
following
equation:

Total
MOE
=
1
/
((
1/
MOEsanitizing)
+
(
1/
MOEcleaning))

Unit
Exposure
Values
(
UE):
Inhalation
unit
exposure
values
were
taken
from
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999:
DP
Barcode
D247642)
or
from
the
Pesticide
Handler
Exposure
Database
(
USEPA,
1998).

 
For
the
low
pressure
handwand
scenarios,
the
CMA
inhalation
unit
exposure
value
for
the
use
of
a
low
pressure
spray
was
used,
0.681
mg/
lb
a.
i.
This
value
is
based
on
data
collected
from
eight
replicates
in
which
the
applicator
hand
sprayed
carpet
using
200
psi,
then
used
a
push
broom
rake
to
raise
the
carpet
nap.
 
For
the
high­
pressure
spray
scenario,
the
occupational
PHED
inhalation
unit
exposure
value
for
liquid/
open
pour/
high
pressure
spray
were
used.
The
inhalation
unit
exposure
value
is
0.12
mg/
lb
a.
i.
 
For
the
mopping
scenarios,
the
CMA
inhalation
unit
exposure
value
for
mopping
was
used,
2.38
mg/
lb
a.
i.
This
value
is
based
on
data
collected
from
six
replicates
in
which
the
applicator
mopped
the
floor
and
received
exposure
via
contact
with
the
mop
or
with
the
bucket.
 
For
the
wiping
scenario,
the
CMA
inhalation
unit
exposure
value
for
wiping
was
used,
67.3
mg/
lb
a.
i.
This
value
is
based
on
data
collected
from
six
replicates
(
dental
technicians)
who
used
a
finger
pump
sprayer
to
apply
the
product
and
then
wiped
the
surfaces
with
a
paper
towel.
 
For
the
liquid
pour
scenario
CMA
disinfectant
liquid
pour
inhalation
unit
exposure
value
was
used.
The
inhalation
unit
exposure
value
is
1.89
mg/
lb
a.
i.
This
value
is
based
on
data
collected
from
two
replicates
involving
pouring
a
disinfectant
product
from
a
jug
into
sterilization
trays
designed
for
dental
instruments,
adding
water
and
instruments
to
the
tray,
removing
the
instruments,
and
discarding
the
old
solution.
 
For
the
brush
scenario,
the
occupational
PHED
inhalation
unit
exposure
value
for
paintbrush
applications
was
used.
The
inhalation
exposure
value
is
0.28
mg/
lb
a.
i.
 
For
the
trigger
pump
spray,
foam,
and
mechanical
foam
scenarios,
the
PHED
inhalation
unit
exposure
value
for
aerosol
applications
(
PHED
scenario
10)
was
used.
The
inhalation
unit
exposure
is
1.3
mg/
lb
a.
i.
Page
23
of
36
 
For
CIP
(
Cleaning
in
Place),
immersion,
and
flooding
for
the
label
that
indicates
that
the
product
is
a
water
soluble
packaging
(
Reg.
#
71094­
1),
the
PHED
data
for
use
of
a
wettable
powder/
water
soluble
bag
was
used,
and
the
value
is,
0.00024
mg/
lb
a.
i.
 
For
CIP
(
Cleaning
in
Place),
immersion,
flooding,
flow
method,
circulation,
and
flushing,
in
which
soluble
concentrate
formulations
were
used,
For
soluble
concentrate
formulations,
the
CMA
disinfectant
liquid
pour
for
disinfectants
inhalation
unit
exposure
value
was
used.
The
inhalation
unit
exposure
value
is
1.89
mg/
lb
a.
i.
This
value
is
based
on
data
collected
from
two
replicates
pouring
a
disinfectant
product
from
a
jug
into
sterilization
trays
designed
for
dental
instruments,
adding
water
and
instruments
to
the
tray,
removing
the
instruments,
and
discarding
the
old
solution.

Quantity
handled/
treated:
The
quantity
handled/
treated
values
were
estimated
based
on
information
from
various
sources.
The
following
assumptions
were
made:

 
For
the
low­
pressure
handwand
scenario,
10
gallons
of
solution
are
used
for
agricultural
uses
(
Exposure
Policy
#
009)
and
AD's
standard
assumption
is
that
2
gallons
are
used
in
all
other
applications.
 
For
the
high­
pressure
spray
scenario,
it
was
assumed
that
40
gallons
of
solution
are
used
(
Exposure
Policy
#
009).
 
For
the
mopping
scenario,
AD's
standard
assumption
is
that
2
gallons
of
solution
are
used
in
the
food
handling
and
commercial/
institutional/
industrial
setting.
 
For
the
wiping,
brush,
trigger
pump
spray,
liquid
pour,
foam
and
mechanical
foam
scenarios
AD's
standard
assumption
is
that
1
L
(
0.26
gallons)
is
used.
 
For
the
immersion
and
flooding
scenarios,
the
quantities
listed
on
the
label
range
from
1
gallon
(
i.
e.
label
Reg.
#
5389­
12)
up
to
10
gallons
and
appear
to
be
either
for
fruit
or
vegetable
cleaning/
sanitizing
These
application
methods
are
used
interchangeably,
such
as
on
Reg.
#
875­
185,
"
To
sanitize
[
e.
g.:
utensils]...
by
immersion,
flooding,
or
spraying..."
AD's
standard
assumption
is
that
10
gallons
is
the
amount
used,
and
assumes
that
the
quantities
handled
for
immersion
and
flooding
are
the
same.
The
way
that
the
term
"
flooding"
is
used
on
labels
does
not
appear
to
indicate
the
flooding
of
large
hard
surfaces
in
industrial
plants.
 
For
the
CIP,
circulation/
recirculation,
flow
method,
and
flushing
scenarios,
the
labels
indicate
that
CIP
lines
can
be
filled
to
its
capacity
so
the
product
can
circulate/
flush
the
system
and
then
be
drained.
However,
labels
do
not
specify
the
size
of
a
CIP
system.
AD's
standard
assumption
is
that
that
10,000
gallons
is
the
capacity
of
the
CIP
line,
and
10,000
gallons
is
the
value
that
was
used
for
conducting
the
assessment.

Duration
of
Exposure:
Potential
doses
were
calculated
for
the
short­
and
intermediate­
term
durations
for
occupational
handlers.
The
alkylbenzene
sulfonates
have
a
low
vapor
pressure
as
indicated
in
Table
2,
Physical/
Chemical
Properties
of
Alkylbenzene
Sulfonates
(
less
than
10­
9),
so
that
any
standing
solutions
that
may
result
in
post
application
exposure
were
deemed
negligible.
Page
24
of
36
Exposure
Calculations
and
Results
The
calculated
baseline
inhalation
doses
and
baseline
MOEs
for
the
alkylbenzene
sulfonates
are
shown
in
Table
7,
and
the
total
MOE
calculations
for
the
labels
that
contain
sodium
dodecylbenzene
sulfonate
are
listed
in
Table
8.
The
reason
that
a
baseline
inhalation
assessment
was
conducted
was
because
of
the
use
sites
of
the
labels.
The
Agency
believes
it
is
not
practicable,
based
on
the
product
usage,
that
a
respirator
can
be
required
on
the
handler
(
e.
g.
janitorial
services).
In
addition,
engineering
controls
are
not
feasible
for
the
current
use
patterns
on
the
labels.
All
of
MOEs
in
the
occupational
setting
were
above
the
target
MOE
of
100
for
inhalation
and
total
exposures,
except
for
the
following
scenarios:

Handler
Risk
Summary
for
alkylbenzene
sulfonates:

 
ST
and
IT
inhalation
exposure
from
cleaning
hard
surfaces
via
circulation/
flow/
flushing
in
the
agricultural
premises
and
equipment
category,
inhalation
MOE
=
0.27.
 
ST
and
IT
inhalation
exposure
from
application
to
hard
surfaces
via
circulation
systems/
flow
method
in
the
food
handling
category,
inhalation
MOE
=
0.16.
 
ST
and
IT
inhalation
exposure
from
cleaning
hard
surfaces
via
wiping
in
the
food
handling
category,
inhalation
MOE
=
93.
 
ST
and
IT
inhalation
exposure
from
application
to
hard
surfaces
via
CIP
(
Cleaning
in
Place)
in
the
food
handling
premises
category,
inhalation
MOE
=
0.14.
 
ST
and
IT
inhalation
exposure
from
cleaning
food
dispensing
equipment
via
circulation
systems/
flow
method
in
the
food
handling
category,
inhalation
MOE
=
0.16.
 
ST
and
IT
Inhalation
exposure
from
cleaning
shower
stalls
and
toilets
via
a
liquid
pour
application
in
the
commercial/
institutional
premises,
inhalation
MOE
=
13.
 
ST
and
IT
inhalation
exposure
from
cleaning
shower
stalls
and
toilets
via
wiping
in
the
commercial/
institutional
premises,
inhalation
MOE
=
0.38.

Total
Exposure
Summary
for
sodium
dodecylbenzene
sulfonate
(
results
from
cleaning
and
sanitizing
with
the
same
product
in
the
same
time
frame)

 
ST
and
IT
inhalation
exposure
from
cleaning
indoor
hard
surfaces
via
wiping
and
then
following
with
sanitizing
via
immersion/
flooding
in
the
food
handling
premises
category,
inhalation
MOE
=
93.
 
ST
and
IT
inhalation
exposure
from
cleaning
indoor
hard
surfaces
via
wiping
and
then
following
with
sanitizing
via
low
pressure
spray
in
the
food
handling
premises
category,
inhalation
MOE
=
90.
 
ST
and
IT
inhalation
exposure
from
cleaning
indoor
hard
surfaces
via
sponge/
mesh/
wiping
and
then
sanitizing
via
immersion/
flooding
in
the
food
handling
premises
category,
inhalation
MOE
=
90.
 
ST
and
IT
inhalation
exposure
from
cleaning
and
sanitizing
steps
to
be
conducted
through
CIP
(
Cleaning
in
Place)
in
the
food
handling
premises
category,
inhalation
MOE
=
<
1.
Page
25
of
36
Table
7:
Short
and
Intermediate
Term
Risks
Associated
with
Occupational
Handlers
Using
Products
Containing
Alkylbenzene
Sulfonates
Unit
Exposure
(
mg/
lb
a.
i.)
Daily
Dose
(
mg/
kg/
day)
a
Baseline
MOEb
Exposure
Scenario
Method
of
Application
Inhalation
App.
Rate
(
lb
ai/
gal)
Quantity
Handled/

Treated
per
day
(
gal)
Inhalation
Inhalation
(
Target
MOE
=
100)

Agricultural
Premises
and
Equipment
(
Use
Site
Category
I)

Brush
0.28
0.0667
0.26
6.9x10­
5
2,000
Mechanical
Foamc
1.3
0.0667
0.26
0.00032
430
Flooding
1.89
0.00183
10
0.00049
280
Circulation,
flow,

flushing
1.89
0.00195
10,000
0.53
0.27j
High
Pressure
spray
0.12
0.00326
40
0.00022
630
Immersion
1.89
0.00334
10
0.0009
160
Low
pressure
spray
0.681
0.00334
10
0.00032
430
Application
to
hard
surfaces
Trigger
Pump
Spray
1.3
0.00334
0.26
1.6x10­
5
8,700
Food
Handling
(
Use
Site
Category
II)

Brush
0.28
0.0667
0.26
6.9x10­
5
2,000
Mechanical
Foam
c
1.3
0.0667
0.26
0.00032
430
Brush
(
sanitize)
d
0.28
0.0115
0.26
1.2x10­
5
12,000
Brush
(
Clean)
d
0.28
0.0018
0.26
1.8x10­
6
75,000
Brush
(
clean)
e
0.28
0.00603
0.26
6.3x10­
6
22,000
Brush
(
clean)
f
0.28
0.003
0.26
3.1x10­
6
45,000
Foam
(
clean)
e
1.3
0.00603
0.26
2.9x10­
5
4,800
circulation,
flushing,

flow
method
1.89
0.00334
10,000
0.9
0.16j
Immersion
1.89
0.00334
10
0.0009
160
Trigger
Pump
Spray
1.3
0.00334
0.26
1.6x10­
5
8,700
Application
to
hard
surfaces
Low
pressure
handwand(
clean)
e
0.681
0.00603
2
0.00012
1,200
Page
26
of
36
Table
7:
Short
and
Intermediate
Term
Risks
Associated
with
Occupational
Handlers
Using
Products
Containing
Alkylbenzene
Sulfonates
Unit
Exposure
(
mg/
lb
a.
i.)
Daily
Dose
(
mg/
kg/
day)
a
Baseline
MOEb
Exposure
Scenario
Method
of
Application
Inhalation
App.
Rate
(
lb
ai/
gal)
Quantity
Handled/

Treated
per
day
(
gal)
Inhalation
Inhalation
(
Target
MOE
=
100)

Low
pressure
handwand
(
sanitize)
e
0.681
0.00302
2
5.9x10
­
5
2,400
Low
pressure
spray
(
clean)
f
0.681
0.003
2
5.8x10­
5
2,400
Trigger
pump
(
sanitize)
f
1.3
0.003
0.26
1.4x10­
5
9,700
High
pressure
spray
(
sanitize)
d
0.12
0.0115
40
0.00079
180
High
pressure
spray
(
Clean)
d
0.12
0.0018
40
0.00012
1,100
Immersion,
flooding
for
WSP
(
sanitize)
e,
g
0.00024
0.00302
10
1.0x10­
7
1.4x106
Immersion,
flooding
for
RTU
(
sanitize)
f,
g
1.89
0.0030
10
0.00081
170
Mopping
2.38
0.00244
2
0.00017
840
Wiping
(
clean)
e
67.3
0.00603
0.26
0.0015
93
Sponge/
mesh
wipe
(
clean)
f
67.3
0.003
0.26
0.00075
190
CIP
(
clean
and
sanitize)
d,
h
1.89
0.00358
10,000
0.97
0.14j
Circulation
systems,

Flow
method
1.89
0.00334
10,000
0.9
0.16j
Circulation
system
(
clean)
e
0.00024
0.00603
10,000
0.00021
680
Food
dispensing
equipment
Circulation
system
(
santiize)
e
0.00024
0.00302
10,000
0.0001
1,400
Immersion
1.89
0.00455
10
0.0012
110
Fruits
and
vegetables
Immersion
(
clean)
i
0.00024
0.00603
10
2.0x10­
7
6.8x105
Page
27
of
36
Table
7:
Short
and
Intermediate
Term
Risks
Associated
with
Occupational
Handlers
Using
Products
Containing
Alkylbenzene
Sulfonates
Unit
Exposure
(
mg/
lb
a.
i.)
Daily
Dose
(
mg/
kg/
day)
a
Baseline
MOEb
Exposure
Scenario
Method
of
Application
Inhalation
App.
Rate
(
lb
ai/
gal)
Quantity
Handled/

Treated
per
day
(
gal)
Inhalation
Inhalation
(
Target
MOE
=
100)

Trigger
pump
spray
(
clean)
i
1.3
0.003
0.26
1.4x10­
5
9,700
Commercial/
Institutional
Premises
(
Use
Site
Category
III
)

Brush
0.28
0.0667
0.26
6.9x10­
5
2,000
Mechanical
Foamc
1.3
0.0667
0.26
0.00032
430
Immersion
1.89
0.00334
10
0.0009
160
Low
Pressure
Handwand
0.681
0.00334
2
6.5x10
­
5
2,200
Application
to
hard
surfaces
(
includes
utensils
and
silverware)
Trigger
Pump
Spray
1.3
0.00334
0.26
1.6x10­
5
8,700
Mopping
2.38
0.0177
2
0.0012
120
Liquid
pour
1.89
1.49
0.26
0.01
13
Shower
stalls
and
toilets
Wiping
67.3
1.49
0.26
0.37
0.38
ST
=
short­
term,
IT
=
intermediate­
term
a
Daily
dose
(
mg/
kg/
day)
=
[
unit
exposure
(
mg/
lb
ai)
*
absorption
(
1.0
for
ST/
IT
inhalation)
*
application
rate
(
lb
ai/
gal)
*
quantity
treated
(
gal)
/
Body
weight
(
70
kg).

b
MOE
=
NOAEL
(
mg/
kg/
day)
/
Daily
Dose,
where
NOAEL
=
0.14
mg/
kg/
day.

c
Represents
foam
and
mechanical
foam
because
it
has
the
highest
application
rate
of
the
two.
Foam
and
mechanical
foaming
are
assumed
to
share
the
same
unit
exposure
values.

d
These
uses
are
assessed
based
on
the
rates
found
on
label
Reg.
#
1020­
13,
and
the
active
ingredient
is
sodium
dodecylbenzene
sulfonate.

e
These
uses
are
assessed
based
on
the
rates
found
on
label
Reg.
#
71094­
1
(
WSP),
and
the
active
ingredient
is
sodium
dodecylbenzene
sulfonate.

f
These
uses
are
assessed
based
on
the
rates
found
on
label
Reg.
#
71094­
2
and
the
active
ingredient
is
sodium
dodecylbenzene
sulfonate.

g
Exposure
to
both
the
water
soluble
packing
(
WSP)
and
ready­
to­
use
(
RTU)
formulation
were
assessed.
Even
though
the
water
soluble
packaging
has
a
higher
application
rate,
the
unit
exposure
values
for
ready­
to­
use,
which
is
represented
by
liquid
pour,
are
higher.

h
This
method
is
done
twice
in
a
row,
so
this
CIP
method
is
carried
out
twice,
and
each
step
is
considered
a
cleaning
and
then
sanitizing
step.

i
These
methods
of
application
at
these
use
sites
only
involve
cleaning
steps
and
no
other
subsequent
sanitizing
steps.

j
The
daily
doses
are
most
likely
over
calculated
due
to
the
assumption
that
such
a
large
quantity
is
being
handled
for
CIP
systems,
and
as
a
result,
the
MOEs
are
extremely
low.

This
is
further
elaborated
on
in
the
Data
Uncertainties.
Page
28
of
36
Table
8
(
derived
from
the
combinations
of
cleaning
and
sanitizing
steps
outlined
in
Table
6)
presents
the
total
baseline
MOE
calculations,
which
presents
the
risk
to
occupational
handlers
that
use
products
that
contain
sodium
dodecylbenzene
sulfonate
as
the
active
ingredient.
These
handful
of
labels
that
contain
this
active
ingredient
are
unique
to
this
RED
because
they
direct
the
user
to
both
clean
and
sanitize
in
the
same
time
frame
with
the
same
product.
The
parenthetical
numbers
are
a
reiteration
of
the
MOEs
calculated
and
then
presented
in
Table
7,
and
then
the
total
MOE
was
calculated
using
the
following
equation:

Total
MOE
=
1
/
((
1/
MOEsanitizing)
+
(
1/
MOEcleaning))

Table
8
Short
and
Intermediate
Term
Inhalation
Risks
to
Occupational
Handlers
Cleaning
and
Sanitizing
with
Products
That
Contain
Sodium
Dodecylbenzene
Sulfonate
Representative
Use
Registration
#
Method
of
CLEANING
Application
Method
of
SANITIZING
Application
Total
Baseline
Inhalation
MOE
(
Target
MOE
=
100)

Food
Handling/
Storage
Establishments
Premises
and
Equipment
(
Use
Site
Category
II)

High
pressure
spray
(
180)
150
High
pressure
spray
(
1,100)

Brush
(
12,000)
1,000
High
pressure
spray
(
180)
180
1020­
13
Brush
(
75,000)

Brush
(
12,000)
10,000
Immersion/
Flooding
(
1.4X106)
1,200
Low
pressure
spray
(
1,200)

Low
pressure
spray
(
2,400)
800
Immersion/
Flooding
(
1.4X106)
93
Wiping
(
93)

Low
pressure
spray
(
2,400)
90
Immersion/
Flooding
(
1.4X106)
4,800
Foam
(
4,800)

Low
pressure
spray
(
2,400)
1,600
Immersion/
Flooding
(
1.4X106)
22,000
71094­
1
Brush
(
22,000)

Low
pressure
spray
(
2,400)
2,200
Immersion/
Flooding
(
170)
90
Sponge/
Mesh/
Wiping
(
190)

Trigger
Pump
(
9,700)
190
Immersion/
Flooding
(
170)
160
Low
Pressure
Spray
(
2,400)
Trigger
Pump
(
9,700)
1,900
Indoor
Hard
Surfaces
(
includes
dishes
and
silverware)

71094­
2
Brush
(
45,000)
Immersion/
Flooding
(
170)
170
Page
29
of
36
Table
8
Short
and
Intermediate
Term
Inhalation
Risks
to
Occupational
Handlers
Cleaning
and
Sanitizing
with
Products
That
Contain
Sodium
Dodecylbenzene
Sulfonate
Representative
Use
Registration
#
Method
of
CLEANING
Application
Method
of
SANITIZING
Application
Total
Baseline
Inhalation
MOE
(
Target
MOE
=
100)

Trigger
Pump
(
9,700)
8,000
1020­
13
CIP
(
0.14)
CIP
(
0.14)
<
1
Food
dispensing
equipment
71094­
1
Circulation
system
(
680)
Circulation
system
(
1,400)
450
5.2
Occupational
Post­
application
Exposures
Occupational
inhalation
post­
application
exposures
are
presumed
to
be
negligible
because
of
the
low
vapor
pressure
of
the
alkylbenzene
sulfonates.

5.3
Data
Limitations/
Uncertainties
There
are
several
data
limitations
and
uncertainties
associated
with
the
occupational
handler
exposure
assessment.
These
include:

 
Surrogate
dermal
and
inhalation
unit
exposure
values
were
taken
from
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999:
DP
Barcode
D247642)
or
from
the
Pesticide
Handler
Exposure
Database
(
USEPA,
1998)
(
See
Appendix
A
for
summaries
of
these
data
sources).
Since
the
CMA
data
are
of
poor
quality,
the
Agency
requests
that
confirmatory
data
be
submitted
to
support
the
occupational
scenarios
assessed
in
this
document.
 
The
quantities
handled/
treated
were
estimated
based
on
information
from
various
sources,
including
HED's
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments
(
USEPA
2000,
and
2001)
and
the
AD
Draft
SOP
use
table.
In
certain
cases,
no
standard
values
were
available
for
some
scenarios.
Assumptions
for
these
scenarios
were
based
on
AD
estimates
and
could
be
further
refined
with
input
from
registrants.
 
The
aerosol
can
unit
exposure
data
from
PHED
were
used
to
assess
application
to
hard
surfaces
by
foam.
The
aerosol
can
scenario
may
not
be
representative
of
foam
application,
however,
for
lack
of
better
data,
these
values
were
used.
 
It
was
assumed
that
most
of
the
exposure
to
the
handler
stemming
from
the
use
of
the
product
for
CIP
(
Cleaning
in
Place),
immersion,
flooding,
flow
method,
circulation,
and
flushing,
will
result
from
preparation
of
the
treatment
solution
and
then
pouring
it
into
the
corresponding
system
to
be
treated.
It
is
also
assumed
that
there
is
minimal
contact
with
the
solution
during
the
treatment
process.
 
It
was
assumed
that
for
the
CIP
systems,
that
the
quantity
handled
is
the
same
what
is
assumed
for
food
pasteurization
systems
since
CIP
systems
can
be
filled
to
its
capacity
so
the
product
can
circulate/
flush
the
system
and
then
be
drained.
However,
labels
do
not
specify
the
size
of
a
CIP
system.
The
Agency
assessed
the
scenario
with
the
assumption
that
10,000
gallons
is
the
capacity
of
the
CIP
line.
This
is
most
probable
the
reason
for
the
extremely
low
MOEs
for
this
use
site.
This
value
can
be
further
refined
with
input
from
the
registrants.
Page
30
of
36
Page
31
of
36
6.0
REFERENCES
USEPA.
1997.
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessments.
EPA
Office
of
Pesticide
ProgramsBHuman
Health
Effects
Division
(
HED).
Dated
December
18,
1997.

USEPA.
1997a.
Exposure
Factors
Handbook.
Volume
I­
II.
Office
of
Research
and
Development.
Washington,
D.
C.
EPA/
600/
P­
95/
002Fa.

USEPA.
1998.
PHED
Surrogate
Exposure
Guide.
Estimates
of
Worker
Exposure
from
the
Pesticide
Handler
Exposure
Database
Version
1.1.
Washington,
DC:
U.
S.
Environmental
Protection
Agency.

USEPA.
1999.
Evaluation
of
Chemical
Manufacturers
Association
Antimicrobial
Exposure
Assessment
Study.
Memorandum
from
Siroos
Mostaghimi,
Ph.
D.,
USEPA,
to
Julie
Fairfax,

USEPA.
2000.
Residential
SOPs.
EPA
Office
of
Pesticide
ProgramsBHuman
Health
Effects
Division.
Dated
April
5,
2000.

USEPA.
2001.
HED
Science
Advisory
Council
for
Exposure.
Policy
Update,
November
12.
Recommended
Revisions
to
the
Standard
Operating
Procedures
(
SOPs)
for
Residential
Exposure
Assessment,
February
22,
2001.
Page
32
of
36
APPENDIX
A:
EQUATIONS
AND
DEFNITIONS
FOR
CALCULATING
MOES
Page
33
of
36
Daily
Exposure:
Daily
dermal
or
inhalation
handler
exposures
are
estimated
for
each
applicable
handler
task
with
the
application
rate,
quantity
treated/
handled
in
a
day,
and
the
applicable
dermal
or
inhalation
unit
exposure
using
the
following
formula:

Daily
Exposure:
E
=
UE
x
AR
x
AT
(
Eq.
1)

Where:
E
=
Amount
(
mg
ai/
day)
deposited
on
the
surface
of
the
skin
that
is
available
for
dermal
absorption
or
amount
inhaled
that
is
available
for
inhalation
absorption;
UE
=
Unit
exposure
value
(
mg
ai/
lb
ai)
derived
from
August
1998
PHED
data
or
from
1992
CMA
data;
AR
=
Maximum
application
rate
based
on
a
logical
unit
treatment,
such
as
acres
(
A),
square
feet
(
sq.
ft.),
gallons
(
gal),
or
cubic
feet
(
cu.
ft).
Maximum
values
are
generally
used
(
lb
ai/
A,
lb
ai/
sq
ft,
lb
ai/
gal,
lb
ai/
cu
ft);
and
AT
=
Normalized
application
area
based
on
a
logical
unit
treatment
such
as
acres
(
A/
day),
square
feet
(
sq
ft/
day),
gallons
(
gal/
day),
or
cubic
feet
(
cu
ft/
day).

Daily
Dose:
The
daily
dermal
or
inhalation
dose
is
calculated
by
normalizing
the
daily
exposure
by
body
weight
and
adjusting,
if
necessary,
with
an
appropriate
absorption
factor.
An
absorption
factor
of
100%
was
used
for
both
dermal
and
inhalation
exposures.
Daily
dose
was
calculated
using
the
following
formula:

Daily
Dose:
ADD
=
E
x
ABS
(
Eq.
2)
BW
Where:
ADD
=
Absorbed
dose
received
from
exposure
to
a
chemical
in
a
given
scenario
(
mg
active
ingredient/
kg
body
weight/
day);
E
=
Amount
(
mg
ai/
day)
deposited
on
the
surface
of
the
skin
that
is
available
for
dermal
absorption
or
amount
inhaled
that
is
available
for
inhalation
absorption;
ABS
=
A
measure
of
the
amount
of
chemical
that
crosses
a
biological
boundary
such
as
lungs
(%
of
the
total
available
absorbed);
and
BW
=
Body
weight
determined
to
represent
the
population
of
interest
in
a
risk
assessment
(
kg).

Margins
of
Exposure:
Non­
cancer
inhalation
and
dermal
risks
for
each
applicable
handler
scenario
are
calculated
using
a
Margin
of
Exposure
(
MOE),
which
is
a
ratio
of
the
daily
dose
to
the
toxicological
endpoint
of
concern.

Margins
of
Exposure:
MOE
=
NOAEL
or
LOAEL
(
Eq.
3)
ADD
Where:
MOE
=
Margin
of
exposure,
value
used
to
represent
risk
or
how
close
a
chemical
exposure
is
to
being
a
concern
(
unitless);
NOAEL
or
LOAEL
=
Dose
level
in
a
toxicity
study,
where
no
observed
adverse
effects
(
NOAEL)
or
where
the
lowest
observed
adverse
effects
(
LOAEL)
occurred
in
the
study;
and
ADD
=
Average
daily
dose
or
the
absorbed
dose
received
from
exposure
to
a
chemical
in
a
given
scenario
(
mg
ai/
kg
body
weight/
day).
Page
34
of
36
APPENDIX
B:
Summary
of
CMA
and
PHED
Data
Page
35
of
36
The
scenarios
were
assessed
by
using
unit
exposure
data
to
estimate
occupational
handlers'
exposures.
Unit
exposures
are
estimates
of
the
amount
of
exposure
to
an
active
ingredient
a
handler
receives
while
performing
various
handler
tasks
and
are
expressed
in
terms
of
micrograms
or
milligrams
(
1mg
=
1,000
µ
g)
of
active
ingredient
per
pounds
of
active
ingredient
handled.
A
series
of
unit
exposures
have
been
developed
that
are
unique
for
each
scenario
typically
considered
in
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
USEPA
and
international
organizations
such
as
Health
Canada
and
OECD
(
Organization
for
Economic
Cooperation
and
Development).

Chemical
Manufacturers
Association
(
CMA)
Data:
In
response
to
an
EPA
Data
Call­
In
Notice,
a
study
was
undertaken
by
the
Institute
of
Agricultural
Medicine
and
Occupational
Health
of
The
University
of
Iowa
under
contract
to
the
Chemical
Manufacturers
Association.
In
order
to
meet
the
requirements
of
Subdivision
U
of
the
Pesticide
Assessment
Guidelines
(
superseded
by
Series
875.1000­
875.1600
of
the
Pesticide
Assessment
Guidelines),
handler
exposure
data
are
required
from
the
chemical
manufacturer
specifically
registering
the
antimicrobial
pesticide.
The
applicator
exposure
study
must
comply
with
the
assessment
guidelines
for
AApplicator
Exposure
Monitoring@
in
Subdivision
U
and
the
AOccupational
and
Residential
Exposure
Test
Guidelines@
in
Series
875.
For
this
purpose,
CMA
submitted
a
study
on
28
February,
1990,
entitled
"
Antimicrobial
Exposure
Assessment
Study
(
amended
on
December
8,
1992)"
which
was
conducted
by
William
Popendorf,
et
al.
It
was
evaluated
and
accepted
by
Occupational
and
Residential
Exposure
Branch
(
OREB)
of
Health
Effect
Division
(
HED),
Office
of
Pesticides
Program
(
OPP)
of
EPA
in
1990.
The
purpose
of
this
CMA
study
was
to
characterize
exposure
to
antimicrobial
chemicals
in
order
to
support
pesticide
reregistrations
(
CMA,
1992).
The
unit
exposures
presented
in
the
most
recent
EPA
evaluation
of
the
CMA
database
(
USEPA,
1999)
were
used
in
this
assessment.

The
Agency
determined
that
the
CMA
study
had
fulfilled
the
basic
requirements
of
Subdivision
U
­
Applicator
Exposure
Monitoring.
The
advantages
of
CMA
data
over
other
Asurrogate
data
sets@
is
that
the
chemicals
and
the
job
functions
of
mixer/
loader/
applicator
were
defined
based
on
common
application
methods
used
for
antimicrobial
pesticides.
A
few
of
the
deficiencies
in
the
CMA
data
are
noted
below:

 
The
inhalation
concentrations
were
typically
below
the
detection
limits,
so
the
unit
exposures
for
the
inhalation
exposure
route
could
not
be
accurately
calculated.
 
QA/
QC
problems
including
lack
of
either/
or
field
fortification,
laboratory
recoveries,
and
storage
stability
information.
 
Data
have
an
insufficient
amount
of
replicates.

The
Pesticide
Handlers
Exposure
Database
(
PHED):
The
Pesticide
Handlers
Exposure
Database
(
PHED)
has
been
developed
by
a
Task
Force
consisting
of
representatives
from
Health
Canada,
the
U.
S.
Environmental
Protection
Agency
(
EPA),
and
the
American
Crop
Protection
Association
(
ACPA).
PHED
provides
generic
pesticide
worker
(
i.
e.,
mixer/
loader
and
applicator)
exposure
estimates.
The
dermal
and
inhalation
exposure
estimates
generated
by
PHED
are
based
on
actual
field
monitoring
data,
which
are
reported
generically
(
i.
e.,
chemical
specific
names
not
reported)
in
PHED.
It
has
Page
36
of
36
been
the
Agency=
s
policy
to
use
Asurrogate@
or
Ageneric@
exposure
data
for
pesticide
applicators
in
certain
circumstances
because
it
is
believed
that
the
physical
parameters
(
e.
g.,
packaging
type)
or
application
technique
(
e.
g.,
aerosol
can),
not
the
chemical
properties
of
the
pesticide,
attribute
to
exposure
levels.
[
Note:
Vapor
pressures
for
the
chemicals
in
PHED
are
in
the
range
of
E­
5
to
E­
7
mm
Hg.]
Chemical
specific
properties
are
accounted
for
by
correcting
the
exposure
data
for
study
specific
field
and
laboratory
recovery
values
as
specified
by
the
PHED
grading
criteria.

PHED
handler
exposure
data
are
generally
provided
on
a
normalized
basis
for
use
in
exposure
assessments.
The
most
common
method
for
normalizing
exposure
is
by
pounds
of
active
ingredient
(
ai)
handled
per
replicate
(
i.
e.,
exposure
in
mg
per
replicate
is
divided
by
the
amount
of
ai
handled
in
that
particular
replicate).
These
unit
exposures
are
expressed
as
mg/
lb
ai
handled.
This
normalization
method
presumes
that
dermal
and
inhalation
exposures
are
linear
based
on
the
amount
of
active
ingredient
handled.
