Chlorine
Dioxide
Dietary
Risk
Assessment
Case
4023
A.
Najm
Shamim,
Ph.
D.
Office
of
Pesticide
Programs
Antimicrobials
Division
U.
S.
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
April
6,
2006
Page
2
of
18
Executive
Summary
The
Antimicrobials
Division
has
determined
that
dietary
exposures
from
chlorine
dioxide/
sodium
chlorite
use
on
direct
and
indirect
food­
contact
surfaces,
disinfectant
use
in
drinking
water,
slimcide
use
in
paper/
pulp,
washes
for
fruits
and
vegetables,
and
postharvest
treatment
for
potatoes.
AD
has
determined
that
there
are
chronic
risks
concerns
for
infants
less
than
one
year
old
(%
cPAD
=
145.1%)
and
non­
nursing
infants
(%
cPAD
=
179.8%)
from
chlorine
dioxide­
treated
drinking
water.

Background:

In
this
document,
the
Antimicrobials
Division
has
assessed
the
dietary
exposure
and
risks
due
to
the
uses
of
chlorine
dioxide
and
sodium
chlorite
in
the
residential
scenarios;
the
exposure
and
risks
also
include
those
from
uses
on
direct
or
indirect
food­
contact
hard
surfaces,
paper/
pulp
slimicide
use,
and
chlorine
dioxide
treated
drinking
water
exposure
and
risks.

Table
1
summarizes
the
use/
site/
application
rates
for
chlorine
dioxide
and
sodium
chlorite.

Table
1
Use
Sites
and
Application
Rates
for
Chlorine
Dioxide
and
Sodium
Chlorite
Use
Site
EPA
Reg.
No.
Method
of
Application
Application
Rates
Mushroom
facilities
(
food
contact)
74602­
2,
9150­
2,
9150­
3,
9804­
1
Flush
equipment
with
sanitizing
solution
100­
200
ppm
total
available
chlorine
dioxide
Potato
storage:
Potato
rinse
and
humidification
9804­
5,
5335­
20,
21164
Spray,
mist
and
fogger
200­
400
ppm
Poultry
house
disinfection:
poultry
chiller
water/
carcass
spray
74602­
2,
74602­
3,
9150­
2,
9150­
3,
9150­
7,
9150­
8
Dip
carcass
For
chiller
water:
50­
150
ppm;
For
carcass
spray:
500­
1200
ppm
Egg
room/
hatching
area,
incubator
room,
tray
washing
room
and
loading
platform
9150­
2,
9150­
3,
74602­
2
High
pressure
spray
20
ppm
for
pre
wash
with
sprayer
Chick
room,
chick
grading
box
and
sex
room
9150­
2,
9150­
3,
74602­
2,
Fogger,
mop
1000
ppm
with
fogger
Food
processing
plants
(
poultry,
meat,
fish)
Food
contact
surfaces
9150­
2,
9150­
3,
9150­
7,
9804­
1,
9804­
9
53345­
14,
53345­
19,
53345­
20,
70060­
6
1
minute
contact
time
200
ppm
total
available
chlorine
dioxide
Page
3
of
18
Dairies,
breweries,
and
bottling
plants
Food
contact
surface
sanitizer
9150­
2,
9150­
3,
9150­
7,
9150­
8,
53345­
14,19,
20,
21,
21164­
6,8,9,
9804­
9,
74602­
2,
5382­
46,
74517­
1,
1
minute
contact
time
200
ppm
total
available
chlorine
dioxide
Fruits,
vegetables
9150­
8
Spray
or
dip
500­
1200
ppm
Fruits
and
vegetable
rinses
9150­
2,
9150­
3,
9804­
1,
9150­
7,
9150­
8,
45631­
22,
45631­
19,
53345­
20,
Immersion,
spray
3
ppm
Pulp/
paper
mills
9150­
2,
9150­
3,
9804­
1,
9804­
9,
53345­
22,
69151­
3,
4,
21164,
6,8,
9,
21
None
stated
4.5
gallons
product
per
100
tons
of
paper:
1.25­
5
ppm
(
3.2
12.8
fluid
ounces
per
1000
gallons
of
water)
Potable
drinking
water
69151­
3,5,
21164­
6,8,9,21
Metering
pump:
1
mg/
L
(
1
ppm)
or
less
1
gallon
per
100,000
of
treated
water
None
stated
1
mg/
l
or
less
5
ppm
1.
Mushroom
House
Treatment
A
number
of
AD
use
labels
(
EPA
Reg.
Nos.
74602­
2,
9150­
2,
9150­
3,
9804­
1)
indicate
the
application
of
chlorine
dioxide
in
mushroom
facilities
(
application
rate
varies
between
100­
200
ppm
and
the
method
of
application
is
flush
equipment);
however,
residue
level
is
not
indicated.
The
Agency,
at
this
time,
has
not
established
any
tolerances
or
exemptions
from
the
requirement
of
tolerance
for
chlorine
dioxide
on
mushroom
uses.
The
Agency
has
not,
at
this
time,
conducted
any
dietary
risk
assessment
for
chlorine
dioxide
use
for
mushrooms.

2.
Fruits
and
Vegetable
Washes
A
chlorine
dioxide/
sodium
chlorite
chronic
dietary
exposure
assessment
on
fruit
and
vegetable
washes
was
conducted
using
the
DEEM­
FCID
 
,
Version
2.0
software
(
EPA,
2000),
which
incorporates
consumption
data
from
USDA's
CSFII,
1994­
1996
and
1998.
The
1994­
96,
98
data
are
based
on
the
reported
consumption
of
more
than
20,000
individuals
over
two
non­
consecutive
survey
days.
Foods
"
as
consumed"
(
e.
g.,
apple
pie)
are
linked
to
EPA­
defined
food
commodities
(
e.
g.
apples,
peeled
fruit
­
cooked;
fresh
or
N/
S;
baked;
or
wheat
flour
­
cooked;
fresh
or
N/
S,
baked)
using
publicly
available
recipe
translation
files
developed
jointly
by
USDA/
ARS
and
EPA.
For
chronic
exposure
assessment,
consumption
data
are
averaged
for
the
entire
U.
S.
population
and
within
population
subgroups.
Based
on
analysis
of
the
1994­
96,
98
CSFII
consumption
data,
which
took
into
account
dietary
patterns
and
survey
respondents,
HED
(
OPP's
Health
Effects
Division)
concluded
that
it
is
most
appropriate
to
report
risk
for
the
following
Page
4
of
18
population
subgroups:
the
general
U.
S.
population,
all
infants
(<
1
year
old),
children
1­
2,
children
3­
5,
children
6­
12,
youth
13­
19,
adults
20­
49,
females
13­
49,
and
adults
50+
years
old.

For
chronic
dietary
exposure
assessment,
an
estimate
of
the
residue
level
in
each
food
or
food­
form
(
e.
g.,
orange
or
orange
juice)
on
the
food
commodity
residue
list
is
multiplied
by
the
average
daily
consumption
estimate
for
that
food/
food
form.
The
resulting
residue
consumption
estimate
for
each
food/
food
form
is
summed
with
the
residue
consumption
estimates
for
all
other
food/
food
forms
on
the
commodity
residue
list
to
arrive
at
the
total
average
estimated
exposure.
Exposure
is
expressed
in
mg/
kg
body
weight/
day
and
as
a
percent
of
the
cPAD
(
chronic
population
adjusted
dose).
This
procedure
is
performed
for
each
population
subgroup.

AD
conducted
a
chronic
risk
assessment
for
the
fruit
and
vegetable
washes
(
post­
harvest)
with
chlorine
dioxide
and
sodium
chlorite
using
1
ppm
as
the
input
level
for
DEEM.
Although
label
rates
are
allow
use
up
to
5
ppm,
AD
believes
that
significant
degradation
of
the
sodium
chlorite
will
occur
by
the
time
the
fruits
and
vegetables
reach
the
consumers
and
that
1
ppm
is
sufficiently
conservative.
The
model
parameters
included
all
fresh
fruits
and
vegetables,
as
well
as
juices.
Chronic
risks
based
on
the
DEEM
exposure
values
are
below
the
Agency's
level
of
concerns.
The
highest
risks
were
for
children
ages
one
to
two
years
old
(
42.4%
of
the
cPAD).

Table
II
Fruit
and
Vegetable
Wash
Exposures
and
Risks
Population
Subgroup
Total
exposure
(
mg/
kg
body
wt./
day)
%
cPAD
U.
S.
Population
0.003292
11
Infants
<
1
year
0.003493
12
Children
1­
6
years
0.009933
33
Children
7­
12
years
0.004208
14
Females
13­
50
0.002689
9
3.
Drinking
Water
Exposures
and
Risks
In
a
memo
from
Pat
Fair
of
the
EPA's
Office
of
Water,
exposure
to
chlorine
dioxide
from
drinking
water
was
characterized.
Chlorine
dioxide
is
used
as
a
disinfectant
in
water
treatment
plants
in
the
USA.
Chlorite
ion
(
ClO2
­)
is
present
in
drinking
water,
and
there
are
two
possible
ways
it
ends
up
in
the
drinking
water:
First,
chlorine
dioxide
is
produced
via
sodium
chlorite
used
as
a
starting
material
and
incomplete
conversion
of
sodium
chlorite
into
chlorine
dioxide
leaves
residual
chlorite
ion
in
water,
and
second,
a
major
breakdown
product
of
chlorine
dioxide
in
water
is
chlorite
ion.
Because
of
the
health
concerns
of
the
presence
of
chlorite
ion
and
its
subsequent
conversion
to
chlorate
ion,
the
Agency
wanted
to
make
sure
that
the
presence
of
chlorite
ion
did
not
exceed
certain
limits.
In
1996,
EPA
instituted
the
Information
Collection
Rule
(
ICR),
and
the
most
Page
5
of
18
extensive
monitoring
data
on
the
occurrence
of
chlorite
ion
in
drinking
water
was
collected
between
July
1997
and
December
1998.

Public
Water
Systems
(
PWSs)
serving
a
population
of
at
least
100,000
report,
under
the
ICR,
treatment
plant
design
and
operational
data
and
to
conduct
monitoring
for
specific
microbial
contaminants
and
disinfection
byproducts,
like
chlorite
ion.
Chlorine
dioxide
treating
plants
conducted
monthly
monitoring
for
chlorite
ion
concentration
in
samples
of
finished
water
leaving
the
plant,
as
well
as
three
sample
points
in
the
distribution
system:
near
the
first
customer,
an
average
residence
time
and
a
maximum
residence
time.

Monitoring
data
were
collected
from
22
water
systems
using
chlorine
dioxide
treatment
(
29
treatment
plants).
The
minimum
reporting
level
(
MRL)
was
established
at
20
µ
g/
L.
All
samples
below
this
value
were
considered
zero.
Data
from
418
samples
(
point
of
entry
to
the
distribution)
showed
chlorite
ion
concentrations
ranged
from
20
µ
g/
L
to
2,029
µ
g/
L.
Data
from
1,115
samples
(
collected
from
within
the
distribution
system)
showed
the
concentration
of
chlorite
ion
between
20
µ
g/
L
to
1,850
µ
g/
L.
The
average
concentration
of
chlorite
ion
from
27/
29
treatment
plants,
when
averaged
from
the
three
distribution
system
sample
points
(
first
customer,
average
residence
time
and
maximum
residence
time),
ranged
from
20
µ
g/
L
to
801
µ
g/
L.

Based
on
the
results
from
this
ICR
monitoring
data,
the
Agency
in
1998
established
a
Stage
1
Disinfectants
and
Disinfection
Byproduct
Rule
(
Stage
1
DBPR),
which
established
a
maximum
contaminant
level
goal
(
MCLG)
and
maximum
contaminant
level
(
MCL)
for
chlorite
ion:
0.8
mg/
L
and
1.0
mg/
L
respectively.

Based
on
the
ICR
Rule
for
the
MCL
of
chlorite
ion,
treatment
plants
using
chlorine
dioxide
as
the
disinfectant
treatment
are
required
to:
1)
conduct
monthly
monitoring
at
three
sample
points
in
the
distribution
system.
Compliance
is
met
if
the
average
chlorite
ion
concentration
does
not
exceed
1.0
mg/
L.
Compliance
is
determined
monthly.
2)
Water
plants,
in
addition
to
monthly
monitoring,
must
also
analyze
daily
samples
of
water
entering
the
distribution
system.
Chlorite
ion
concentration
must
not
exceed
1.0
mg/
L.
If
the
entry
point
data
shows
an
exceedence
over
1.0
mg/
L,
the
water
treatment
system
must
sample
at
three
distribution
system
sample
points
within
24
hours
and
verify
that
the
chlorite
ion
concentration
has
not
exceeded
1.0
mg/
L.

In
the
original
ICR
monitoring
data
a
number
of
samples
and
distribution
systems
showed
large
exceedences
based
on
the
MCL
and
MCLG.
At
present,
water
systems
have
indicated
that
treatment
is
generally
designed
to
meet
a
level
of
at
least
20%
below
the
MCL
in
order
to
ensure
compliance.
Based
on
this
assumption,
the
Agency
has
readjusted
all
reported
concentrations
over
1000
µ
g/
L
to
800
µ
g/
L
and
recalculated
the
data.
Table
1
shows
the
adjusted
values
of
chlorite
concentrations.
Page
6
of
18
Table
III
Chlorite
Concentrations1
(
µ
g/
L)
­
ICR
Data
Adjusted
for
MCL
Compliance
Chlorine
Dioxide
Water
Treatment
Plants
(
WTPs)

Distribution
System
Entry
Point
Near
First
Customer
Average
Residence
Time
Maximum
Residence
Time
Distribution
System
Average2
10th
Percentile
60
52
58
30
45
20th
Percentile
99
79
87
81
84
50th
Percentile
440
380
360
310
390
80th
Percentile
590
580
600
510
550
90th
Percentile
660
660
640
650
630
Maximum
800
740
680
680
700
#
WTPs
29
27
27
27
27
#
PWSs
22
21
21
21
21
1The
average
chlorite
concentration
was
calculated
for
each
sample
point
at
each
WTP
over
the
entire
ICR
monitoring
program.
The
distribution
of
these
averages
is
presented
in
this
table.
2The
distribution
system
average
chlorite
concentration
was
calculated
for
each
WTP
using
the
three
distribution
system
sample
points.
The
distribution
of
these
averages
is
presented
in
this
column.

The
Agency
conducted
a
drinking
water
risk
assessment
using
the
maximum,
90th
percentile,
and
median
annual
averages
of
chlorite
concentrations
of
0.700,
0.630,
and
0.390
mg/
L,
respectively.
The
DEEM
Model
was
again
used
to
determine
the
exposure
values
(
Memo
from
David
Hrdy,
HED,
to
Jennifer
Slotnick,
AD).
Table
IV
presents
the
exposures
and
corresponding
risks.
The
90th
percentile
exposure
values
will
be
used
in
the
aggregate
risk
assessments.
Children
will
be
represented
by
the
1­
6
year
old
age
category.
The
only
subpopulation
that
Agency
has
concerns
for
is
infants
(
less
than
one
year
old)
when
exposed
to
chlorine
dioxide
treated
water.
All
other
subpopulations
and
the
general
population
have
risks
below
the
Agency's
level
of
concern.

Table
IV
Drinking
Water
Exposure
and
Risks
Maximum
Concentration
90th
Percentile
Concentration
Median
Concentration
Population
subgroup
Total
exposure
(
mg/
kg/
day)
%
cPAD
Total
exposure
(
mg/
kg/
day)
%
cPAD
Total
exposure
(
mg/
kg/
day)
%
cPAD
U.
S.
Population
0.014754
49
0.013279
44
0.008220
27
Infants
<
1
year
0.048372
161
0.043535
145
0.026950
90
Children
1­
6
years
0.020613
69
0.018552
62
0.011485
38
Children
7
­
12
years
0.013402
45
0.012062
40
0.007467
25
Females
13­
50
0.014274
48
0.012846
43
0.007952
27
Page
7
of
18
4.
Poultry
Hatcheries:

AD
label
searches
(
EPA
Reg.
Nos.
9150­
2,
9150­
3)
indicate
that
chlorine
dioxide
is
used
in
poultry
hatching
areas,
incubator
rooms,
tray
washing
room
and
loading
platforms
as
a
disinfectant.
A
high
pressure
sprayer
is
used
to
deliver
the
chemical
at
the
rate
of
20
ppm.

In
these
poultry
hatcheries,
eggs
are
produced
for
the
production
of
chicks
and
not
for
human
consumption.
Although
it
is
likely
that
some
sanitizer/
disinfectant
chemicals
may
penetrate
the
egg
shells
and
bioaccummulate
in
the
developing
chicks,
at
this
time,
the
Agency
believes
that
the
amount
of
the
chemical
transferred
to
the
developing
chicks
is
not
likely
to
adversely
affect
the
development
of
chicks
and
will
have
an
even
smaller
transfer
into
humans.

A
similar
label
search
(
EPA
Reg
No.
74602­
2)
indicates
the
same
uses
for
sodium
chlorite
at
the
same
application
rate.
The
Agency
has
no
concerns
for
this
use.

The
use
of
chlorine
dioxide
and
sodium
chlorite
in
poultry
hatcheries
can
be
classified
as
non­
food
use.
Agency
has
no
dietary
risk
concerns
at
this
time
for
this
use.

5.
Food
Handling
Establishments
(
Hard
Surface
Indirect
Food
Contact
Surfaces):

Use
of
chlorine
dioxide
and
sodium
chlorite
on
sites
where
there
is
a
likelihood
of
exposure
(
and
migration)
of
these
chemicals
into
food
is
being
assessed.
An
example
of
direct
food
contact
would
be
post­
harvest
treatment
of
fruits
and
vegetables.
Sanitizing
and
or
disinfecting
use
of
antimicrobials
on
hard
non­
porous
surfaces
which
come
into
contact
with
food
are
classified
as
indirect
food­
contact
surfaces.
Eating
establishments
(
food
tables),
kitchen
counter
tops,
etc.
fall
in
this
category.

Using
FDA
methodology,
EPA
has
calculated
the
Estimated
Daily
Intake
(
EDI)
of
a
chemical
by
using
the
relationship:

EDI
(
mg/
kg/
day)
=
AR
x
SA
x
F/
BW       ..(
1)

Where:
SA
=
Surface
area
of
the
treated
hard
surface
which
comes
into
contact
with
food
(
fruits,
vegetables,
meats)
=
2000
cm2
AR
=
1
mg/
cm2
of
dilute
product
x
a.
i.
(
active
ingredient)
=
application
rate
F
=
Fraction
of
the
pesticide
transferred
or
migrated
from
the
treated
surface
into
food.
It
is
assumed
to
be
100%
as
there
is
no
residue
data
to
indicate
otherwise
and
risks
from
this
conservative
screening­
level
assessment
are
not
of
concern.
If
refinements
are
necessary,
a
10%
factor
may
be
assumed
while
the
Agency
calls
in
confirmatory
data
from
the
registrants.
BW
=
Body
weight:
adult
=
70
kg;
child
=
15
kg.
Page
8
of
18
Maximum
application
rate
(
EPA
Reg.
Nos.
9150­
2,
9150­
3,
53345­
14,
53345­
19,
and
53345­
20)
=
200
ppm
of
chlorine
dioxide
or
sodium
chlorite
=
200
µ
g/
1000
mg
(
ppm)

Using
eq.
1:

EDI
=
200
µ
g/
1000mg(
ppm)
x
0.10
mg/
cm2
x
2000
cm2/
BW
=
40
µ
g
a.
i.
/
BW
Estimated
Daily
Dietary
Dose
for
an
adult
=
40
µ
g/
70kg
x
1mg/
1000
µ
g
=
0.000571
mg/
kg/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
(
1)

Estimated
Daily
Dietary
Dose
for
a
child
=
40
µ
g/
15kg
x
1mg/
1000
µ
g
=
0.00266
mg/
kg/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
(
2)

The
cPAD
for
chlorine
dioxide
and
sodium
chlorite
is
0.03
mg/
kg/
day.

%
PAD
=
exposure
/
cPAD
x
100%
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
3)

For
an
adult,
the
%
cPAD
=
0.000571
mg/
kg/
day
/
0.03
mg/
kg/
day
x
100%
=
1.90%

For
a
child,
the
%
cPAD
=
0.00266
mg/
kg/
day
/
0.03mg/
kg/
day
x
100%
=
11.1%

The
Agency
does
not
have
any
concerns
from
this
exposure,
as
the
%
cPAD
is
below
100%
for
both
age
groups.

6.
Post
 
Harvest
Potato
Treatment:

The
Agency
has
allowed
the
use
of
chlorine
dioxide
in
the
form
of
a
spray,
mist
and
fogger
with
the
application
rate
limit
of
200­
400
ppm
in
the
post­
harvest
treatment
of
potatoes
in
the
storage
area
before
they
are
sent
out
for
retail
market
(
EPA
Reg.
No.
9804­
5).
AD
had
asked
the
States
of
Idaho
and
Washington
to
collect
the
analytical
data
on
the
residues
on
the
chlorine
dioxide
treated
post­
harvest
potatoes
(
AD
Memo
by
Tim
McMahon,
and
A.
Najm
Shamim,
March,
1998).

A
six
month
residue
monitoring
study
from
chlorine
dioxide
treatment
on
stored
potatoes
(
February
through
July
1999)
was
submitted
in
August/
September,
1999
by
Analytical
Sciences
Laboratory,
a
contracting
lab.
42
samples
(
duplicate)
were
analyzed:
1)
All
42
samples
showed
chlorite
to
be
non­
detect
(
at
the
practical
quantitation
limit
of
0.1
ppm
level);
and
2)
39/
42
samples
showed
the
presence
of
chlorate
below
the
quantitation
limit
of
0.1
ppm
and
only
three
samples
showed
the
chlorate
level
between
0.97
and
1.1
µ
g/
g.
Both
chlorate
and
chlorite
are
considered
the
breakdown
products
of
chlorine
dioxide.
The
Agency
did
not
see
any
concerns
for
the
presence
of
chlorate
at
these
levels
in
a
few
samples.
Page
9
of
18
A
memo
by
the
Health
Effects
Division
(
Christina
Swartz,
1994)
noted:
"
Residue
Chemistry
data
reviews
of
data
submitted
in
support
of
existing
tolerance
exemptions
concluded
that
there
is
no
likelihood
of
transfer
of
residues
(
of
sodium
chlorate)
to
meat/
milk/
poultry/
eggs)."
It
also
noted
that
"
based
on
the
likelihood
of
reduction
of
sodium
chlorate
residues
through
hydrolysis
on
cooking,
and
based
on
a
lack
of
toxicity
concern,
and
residue
levels
found
on
crops
during
field
trials,
CBRS
(
HED's
Branch),
continues
to
support
the
existing
tolerance
exemption."

The
Agency
has
no
concerns
at
this
time
for
use
of
chlorine
dioxide
and
sodium
chlorite
for
stored
potato
treatment
and
subsequent
interstate
commerce
of
this
commodity.

7.
Poultry
House
Disinfection,
Poultry
Chiller
Water/
Carcass
Spray
or
Dip
Several
AD
products
(
EPA
Reg
Nos.
74602­
2,
74602­
3,
9150­
7,
9150­
8)
are
used
in
carcass
sprays
or
dips
with
application
rates
from
500­
1200
ppm
and
poultry
chiller
water
with
application
rates
from
50­
150
ppm.
The
same
application
rate
and
method
of
application
was
submitted
to
FDA
for
risk
assessment.
FDA
did
assess
the
risks
involved
for
this
use
(
FDA
Memo:
FAP:
4A4433,
1994).
FDA
extensively
reviewed
the
efficacy
and
analytical
chemistry
data
on
the
residues
of
chlorate/
chlorite
or
possibly
chlorine
dioxide
for
the
scenarios
listed.
Residues
of
chlorite
and
chlorates
were
measured
on
poultry
carcasses
after
pre­
chiller
and
chiller
water
treatments.
Acidified
sodium
chlorite,
with
pH
maintained
between
2.4­
2.9
(
at
which
condition,
HClO2
is
formed
and
slowly
released
to
the
treating
system).
The
duration
of
exposure
was
between
5
seconds
and
5
minutes.
After
the
pre­
chiller
treatment
the
carcasses
were
dipped
in
water
for
rinsing
at
temperature
 
5
o
C.
Neither
chlorite
nor
chlorate
was
detected
between
0.009
ppm
and
0.011
ppm
levels
of
detection.

In
the
chiller
water
treatment,
poultry
carcasses
were
chilled
an
hour
( 
5
o
C)
at
the
application
rate
of
150
ppm
with
acidified
sodium
chlorite
solution.
Samples
were
allowed
to
drip
for
minutes.
Drip
samples
were
analyzed
at
time,
0,
10
minutes,
1
hour,
2,
4
and
20
hours.
Chlorite
detection
was
at
0.54
ppm
at
time
zero,
0.09
ppm
at
10
minutes
and
at
0.021
ppm
after
one
hour.
LOD
was
set
at
0.016
ppm.
Chlorite
was
non­
detect
after
2
hours.
Chlorate
was
non­
detect
even
at
time
zero.
It
is
likely
that
the
residual
chlorate/
chlorite
on
the
poultry
may
be
going
through
oxidative
processes
to
form
chlorinated
organics.
FDA
asked
and
industry
conducted
the
studies
on
the
formation
of
chlorinated
organics;
no
evidence
was
found
for
the
formation
of
chlorinated
organics.
However,
some
PCBs
were
detected
at
the
background
levels.
Open
literature
studies
support
the
results
that
with
acidified
sodium
chlorate
treatment
of
poultry
no
chlorinated
organics
are
formed.
FDA
accepted
the
studies
and
concurred
with
the
results.
AD
concurs
with
FDA.
At
this
time,
the
Agency
does
not
have
any
concerns
with
the
use
of
acidified
sodium
chlorite
solution
on
carcasses.
Page
10
of
18
8.
Food­
Contact
Surface
Sanitizer
Use
of
Chlorine
Dioxide
and
Sodium
Chlorite:
Food
Processing
Plants
(
Meat,
Fish)

Several
AD
products
(
EPA
Reg.
Nos.
74602­
2,
53345­
14,
53345­
19,
53345­
20,
21164­
3,
9150­
7)
are
used
as
food­
contact
surface
sanitizers
in
food
processing
plants
at
application
rates
of
200
ppm.
For
the
application
method
of
a
fogger,
1
minute
of
contact
time
is
required.

As
the
application
rates
are
similar
to
the
section
7
scenario
above,
exposure
would
also
be
similar.
Therefore,
the
Agency
does
not
currently
have
any
dietary
risk
concerns
for
this
use.

9.
Dairies,
Breweries,
Bottling
Plants,
Food
Contact
Surfaces:

The
use
scenario
for
this
application
(
on
labels
for
EPA
Reg.
Nos.
53345­
14,
19,
20,
21;
9150­
7,
8;
21164­
6,
8,
9;
74602­
2;
5382­
46;
74517­
1;
73139­
1)
includes
sanitizing
foodcontact
surfaces;
processing
equipments;
and
utensils
in
dairies,
breweries,
canning
operations,
and
meat
and
vegetable
processing
plants
at
application
rates
of
200
ppm.
FDA
reviewed
a
similar
application
and
made
a
few
assumptions
(
FDA
Memo
by
Susan
Carberry,
Ph.
D:
HFS­
247,
Chemistry
Review
Branch,
Document
Number
2B4334,
1993).
We
have
used
the
FDA
assumptions
for
residues
and
also
calculated
the
EDI,
DDDs,
and
percent
cPADs
based
on
our
toxicity
numbers.

FDA
Assumptions:
1)
residue
exposure
=
1
mg/
cm2;
2)
major
exposure
scenarios
and
foods
from
this
application
are:
brewery,
beverage,
egg/
mayonnaise
industries;
3)
at
consumers
level,
the
following
foods
will
have
the
residues:
beer,
beverages,
egg/
mayonnaise
products,
and
milk.
Weight
of
food/
surface
area
ratios
(
in
g/
cm2)
for
some
foods
are
as
follows:
Milk
(
dairy):
6.6
Egg/
mayonnaise:
64
Beer,
beverages:
150;
4)
FDA
used
the
intake
data
[
14
day
average
from
MRCA
(
1982­
87)
menu
census
survey
and
USDA/
NFCS
survey
data
(
1987­
1988)]
for
portion
sizes.
The
following
represents
the
average
eaters
only
food
category
and
food
intake
averages
(
in
grams/
person/
day):
Beverages,
alcoholic/
beer:
182
g/
p/
d
Beverages,
non­
alcoholic:
240
g/
p/
d
Egg
products:
9
g/
p/
d
Salad
dressing/
mayonnaise:
6
g/
p/
d
Milk:
124
g/
p/
d;
5)
FDA
also
assumed
that
there
is
no
loss
of
chlorine
dioxide
as
a
gas,
and
the
treatment
is
100%
with
the
product
present
in
the
formulation.

Calculations:

Using
the
maximum
application
rate
of
200
ppm:
Page
11
of
18
200ppm
=
200
mg/
kg
x
1
kg/
1000g
x
200
µ
g/
1
mg
=
1000
µ
g/
g
=
200
µ
g/
1000
mg.
Using
assumptions
1
through
4
and
data
inputs
from
above:

a.
Beverages,
alcoholic
,
beer:
Estimated
Daily
Intake
(
EDI)
=
1000
µ
g/
1000mg
x
1
mg/
cm2
x
182
g/
person/
day
x
1
cm2/
150
g
=
0.24
µ
g/
person/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
1)
b.
Beverages,
non­
alcoholic:
EDI
=
0.32
µ
g/
person/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
2)
c.
Egg
products,
salad
dressing,
mayonnaise:
EDI
=
0.28
µ
g/
person/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
3)
d.
Milk:
EDI
=
3.76
µ
g/
person/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
4)

From
(
1):
Adult
Daily
Dietary
Dose
=
0.24
µ
g/
person/
day
x
mg/
1000
µ
g
=
2.4
x
10­
4
mg/
person/
day
x
person/
70
kg
=
3.4
x
10­
6
mg/
kg/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
1a)
Child
DDD
is
not
calculated,
as
children
are
not
expected
to
consume
alcoholic
beverages
From
(
2)
Adult
Daily
Dietary
Dose
=
0.32
µ
g/
person/
day
x
mg/
1000
µ
g
=
3.2x
10­
4mg/
person/
day
x
person/
70
kg
=
4.57x
10­
6
mg/
kg/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
(
2a)
Child
DDD
=
3.1x
10­
5
mg/
kg/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
2b)

From
(
3)
Adult
Daily
Dietary
Dose
=
0.028
µ
g/
person/
day
x
mg/
1000
µ
g
=
2.8x10­
5
mg/
person/
day
x
person/
70
kg
=
4.0
x
10­
7
mg/
kg/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
3a)
Child
DDD
=
1.86
x
10­
7
mg/
kg/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
3b)

From
(
4)
Adult
Daily
Dietary
Dose
=
3.76
µ
g/
person/
day
x
mg/
1000
µ
g
=
3.76
x
10­
3
mg/
person/
day
x
person/
70
kg
=
5.37
x
10­
5
mg/
kg/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­
(
4a)
Child
DDD
=
2.5
x
10­
4
mg/
kg/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
4b)

For
chlorine
dioxide
and
sodium
chlorite
the
cPAD
is
0.03
mg/
kg/
day.
The
values
are
presented
in
Table
V.
None
of
the
%
cPADs
exceed
100,
and
hence,
the
Agency
does
not
have
any
concern
for
uses
at
these
sites
at
the
current
application
rates.

Table
V
Dietary
Doses
and
Risks
from
Food
Consumption
following
use
of
Chlorine
Dioxide/
Sodium
Chlorite
in
Food
and
Beverage
Processing
Plants
Food
Type
Daily
Dietary
Dose
(
DDD)
(
mg/
kg/
day)
%
cPAD
=
Exposure
(
DDD)
/
cPAD
x
100%
Beverages,
alcoholic,
beer
Adult:
3.4x10­
6
Child:
Not
Applicable
Adult:
0.11%
Child:
Not
Applicable
Beverages,
nonalcoholic
Adult:
4.0x10­
6
Child:
2.0x10­
5
Adult:
0.016%
Child:
0.066%
Egg
products,
mayonnaise
Adult:
4.0x10­
5
Child:
2.6x10­
4
Adult:
0.00177%
Child:
0.0062%
Page
12
of
18
Milk
Adult:
5.4x10­
5
Child:
2.6x10­
5
Adult:
0.132%
Child:
0.84%
10.
Dietary
Exposures
and
Risks
Resulting
From
Use
of
Chlorine
Dioxide/
Sodium
Chlorite
as
Slimicides
in
Paper/
Pulp
Products
(
Indirect
Food
Additives).

Chlorine
dioxide
and
sodium
chlorite's
antimicrobials
uses
include
slimicide
use
in
paper/
pulp,
paper
coatings,
polymer
slurries
(
as
a
filler
in
paper),
and
paper
adhesives.
AD
has,
therefore,
assessed
the
potential
dietary
exposure
to
such
uses
applying
the
FDA
methodologies.

AD's
label
searches
identified
a
number
of
chlorine
dioxide
and/
or
sodium
chlorite
products
use
as
slimicides
in
the
manufacture
of
pulp/
paper
products.
The
label
of
SLEME­
TROL
RX­
33
(
EPA
Reg.
No.
74655­
2)
showed
the
highest
concentration
of
sodium
chlorite
(
25%)
at
use
level.
The
application
rate
is
2
lbs/
ton
of
finished
paper.
The
same
label
shows
that
in
polymer
slurries
preservative
in
paper
coatings
and
as
adhesives
in
paper
products,
the
maximum
amount
of
chlorine
dioxide
/
sodium
chlorite
is
1000
ppm
of
the
active.
The
Agency
has
noted
that
at
the
use
sight,
sodium
chlorite
generates
chlorine
dioxide.
Hence,
whether
the
label
is
that
of
chlorine
dioxide
or
sodium
chlorite,
these
are
treated
as
one
and
the
same.

The
FDA
methodology
makes
a
number
of
assumptions
for
calculating
migration
of
active
ingredients
(
chlorine
dioxide/
sodium
chlorite)
from
food­
contact
surfaces
(
paper):
1)
Food
contact
surface
(
paper)
can
be
a
one
time
use/
day
or
a
repeat
use
material;
2)
Consumption
factor
(
CF)
or
fraction
of
daily
food
which
comes
in
to
contact
with
the
packaging
surface
(
paper)
represents
the
actual
weight
of
food
that
comes
into
contact
with
the
paper
to
the
weight
of
all
food
packaged
with
paper;
3)
The
CF
varies
from
one
type
of
packaging
(
type
of
paper)
to
another
(
type
of
paper).
FDA
methodology
of
migration
of
active
assumes
a
100%
migration
to
the
food
commodities.
This
represents
a
worst
case
scenario.

Data
Input
Parameters
for
Chlorine
Dioxide
and
Sodium
Chlorite
Used
as
Paper
Slimicide:

1.
Rate
of
Application
of
Active:
Maximum
of
2
lbs
of
product/
ton
of
paper
(
=
1.0
kg/
1000
kg
of
paper)
2.
Paper
slurry:
Prior
to
entering
paper
manufacturing
machine:
1%
(
99%
water
and
1%
pulp)
(
FDA
assumption)
3.
Concentration
of
Slurries
Entering
Driers:
33%
pulp
and
67%
water
(
FDA
Assumption)
4.
Standard
Paper
Weight:
50
mg/
in2
(
FDA
Assumption)
5.
Finished
Paper:
8%
water
and
92%
pulp
(
RASSB
Memo
by
Bob
Quick,
based
on
FDA
Assumption)
6.
Mass
of
Food
in
Contact
with
Surface
Area
of
Treated
Paper:
10
g/
in2
(
FDA
Assumption)
7.
Consumption
Factor
(
CF)
for
Treated
Paper:
0.10
(
FDA
Assumption)
8.
Daily
Average
Food
Intake
(
Adult)
=
3000
g
Page
13
of
18
9.
Daily
Average
Food
Intake
(
Child)
=
1500
g
Calculations:

a.
As
the
active
is
only
25%,
from
parameters
1
&
2
above,
2
lb/
ton
paper
=
0.25
lbs/
1000
lbs
paper
or
1
lb
active
=
4000
lbs
paper
=
400,000
lb
slurry
x
1%
paper
slurry
=
1
lb/
4000
lbs
of
finished
paper
=
2.5
ppm
of
active
in
the
paper
slurry.
(
This
is
derived
from
FDA
assumption).
b.
From
in
put
parameter
3,
the
concentration
of
the
active
(
Chlorine
dioxide/
sodium
chlorite)
present
in
the
pulp
prior
to
entering
the
driers:
Application
Rate
x
%
water/
%
pulp
=
2.5
ppm
active
=
2.
5
:
g
active/
g
pulp
slurry
x
0.67
water/
0.33
g
pulp
=
5
µ
g
active/
g
pulp.

OUTPUT:

Based
on
input
parameters
1
through
7
and
calculations
a
and
b,
the
outputs
are:

1a.
Concentration
of
chlorine
dioxide/
sodium
chlorite
in
food:
µ
g
of
chlorine
dioxide/
sodium
chlorite/
mass
of
pulp
x
mass
of
pulp/
mass
of
paper
x
standard
mass
of
paper
x
mass
of
food/
surface
area
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
i)

5
µ
g
chlorine
dioxide/
sodium
chlorite/
mass
of
pulp
x
0.92
g
pulp/
g
of
paper
x
0.05
g/
in2
x
1
in2
/
10
g
food
=
0.023
µ
g
of
chlorine
dioxide/
sodium
chlorite/
g
food
Taking
into
account
of
CF
of
0.10,
the
actual
dietary
concentration
of
chlorine
dioxide/
sodium
chlorite
in
daily
diet
would
be:
0.023
µ
g
chlorine
dioxide/
sodium
chlorite/
g
food
x
0.10
=
0.0023
µ
g
of
active/
g
food
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
ii)

1b.
Estimated
Daily
Intake
(
EDI)
for
an
Adult
=
0.0023
µ
g
of
chlorine
dioxide/
sodium
chlorite/
g
food
x
3000
g
food
=
6.9
µ
g
chlorine
dioxide/
sodium
chlorite/
person/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
iii)

1c.
Estimated
Daily
Intake
(
EDI)
for
a
Child
=
0.0023
µ
g
of
chlorine
dioxide
/
sodium
chlorite/
g
food
x
1500
g
food
=
3.45
µ
g
chlorine
dioxide/
sodium
chlorite/
person/
day
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
iv)

Estimated
Daily
Dietary
Dose
=
EDI/
Body
Weight:
Adult:
6.9
µ
g
x
mg/
1000
µ
g
/
70
kg/
day
=
9.8
x
10­
5
mg/
kg/
day
Child:
3.45
µ
g
x
mg/
1000
µ
g
/
15
kg
/
day
=
2.3
x
10­
4
mg/
kg/
day
11.
Chlorine
Dioxide
and
Sodium
Chlorite
Use
in
Polymer
Slurries
As
a
Filler
in
Paper
The
label
(
EPA
Reg
No.
74655­
2)
indicates
that
no
higher
than
1000
ppm
of
the
product
be
used
for
polymer
slurries
for
preservation
of
paper.
Since
the
active
is
only
25%,
the
active
concentration
=
250
ppm.
Page
14
of
18
Data
Input
Parameters
for
Chlorine
Dioxide
and
Sodium
Chlorite
as
a
Preservative
in
Paper,
with
Polymers
Slurries
as
Fillers:

1.
Rate
of
Application
of
the
Active:
250
ppm
2.
Standard
Paper
Weight:
50
mg/
in2
(
FDA
Assumption)
3.
Mass
of
Food
in
Contact
With
Surface
Area
of
Paper
Treated
with
Preservative
(
chlorine
dioxide/
sodium
chlorite)
=
10
g
food/
in2
4.
Consumption
Factor
(
CF)
for
Paper
Treated
With
Preservative
(
chlorine
dioxide/
sodium
chlorite)
=
0.10
5.
Finished
Preservative
(
chlorine
dioxide/
sodium
chlorite)
Treated
Paper
=
8%
Water
and
92%
Pulp
(
FDA
Assumption)
6.
Daily
Average
Food
Intake
(
Adult)
=
3,000
g
7.
Daily
Average
Food
Intake
(
Child)
=
1,500
g
Calculations:

a.
Concentration
of
chlorine
dioxide/
sodium
chlorite
in
paper/
pulp
FDA
assumes
that
0.1lbs
of
polymer
slurries
=
1
lb
of
paper,
that
is
polymer
slurry
represents
10%
as
fillers
Rate
of
Application
x
10%
filler
=
250
ppm
x
0.10
=
25
ppm
­­­­­­­­­­­­­­­­­­­­(
i)

If
the
pulp
is
5%
in
the
slurry
water
(
FDA
assumption),
the
amount
of
chlorine
dioxide/
sodium
chlorite
is:
0.05
x
25
=
1.25
ppm
of
chlorine
dioxide/
sodium
chlorite
in
slurry
water
­­­­­­­(
ii)

If
mass
of
water
to
mass
of
pulp
is
67%/
33%
(
2:
1),
the
amount
of
chlorine
dioxide/
sodium
chlorite/
g
pulp
is:
1.25
ppm
x
2
=
2.50
ppm
=
2.5
µ
g
chlorine
dioxide/
sodium
chlorite/
g
pulp
­­­­(
iii)

b.
Concentration
of
chlorine
dioxide/
sodium
chlorite
in
food:

Mass
of
chlorine
dioxide/
sodium
chlorite/
g
paper
x
mass
of
pulp/
g
paper
x
standard
mass
of
paper/
in2
paper
x
mass
of
food/
in2
paper:

2.5
µ
g
chlorine
dioxide/
sodium
chlorite/
g
paper
x
0.92
g
pulp/
g
paper
x
0.05
g
paper/
in2
paper
x
1
in2
paper/
10
g
food
=
0.0115
µ
g
chlorine
dioxide/
sodium
chlorite/
g
food
=
0.0115
ppm
of
chlorine
dioxide/
sodium
chlorite
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­(
iv)

If
CF
factor
=
0.10,
amount
of
chlorine
dioxide/
sodium
chlorite
in
food
=
0.10
x
0.0115
µ
g
chlorine
dioxide/
sodium
chlorite/
g
food
=
0.00115
µ
g
/
g
food
­­­­­­(
v)

Estimated
Daily
Intake
(
EDI)
for
an
Adult:
0.00115
µ
g/
g
food
x
3000
g
food
=
3.45
µ
g
food/
person/
day
­­­­­­­­­­­­­­­­­­­­­(
vi)
Page
15
of
18
Estimated
Daily
Intake
(
EDI)
for
a
Child:
0.000115
µ
g/
g
food
x
1500
g
of
food
=
1.725
µ
g/
person/
day
­­­­­­­­­­­­­­­­­­­­(
vii)

Estimated
Daily
Dietary
dose
=
EDI/
Body
Weight:
Adult:
3.45
µ
g
x
mg/
1000
µ
g
/
70
kg
BW/
day
=
4.9
x
10­
5
mg/
kg/
day
Child:
1.75
µ
g
mg/
1000
µ
g
/
15
kg
BW/
day
=
1.16
x
10­
4
mg/
kg/
day
12.
Chlorine
Dioxide
and
Sodium
Chlorite
as
Paper
Adhesive
Preservative
Use
Some
AD
labels
claim
FDA
clearance
for
use
as
preservative
use
in
paper
adhesives
in
accordance
with
the
limitations
of
21CFR
175.105,
which
states:
"
migration
levels
for
the
substance
generally
will
be
assumed
to
be
no
greater
than
50
ppb".
Applying
a
consumption
factor
(
CF)
of
0.14
for
adhesives
gives
a
dietary
concentration
of
7
ppb.
It
should
be
noted
that
FDA
derives
the
consumption
factor
(
CF)
from
the
possible
percentage
of
daily
diet
expected
to
contact
the
paper
adhesives.

Calculations:

Estimated
Daily
Intake
(
EDI):
(
Dietary
conc.
X
Daily
food
consumption)
Adult:
(
0.007
µ
g
ai/
g
food)
x
(
3000
g
food/
day)
=
21
µ
g
ai/
person/
day
Child:
(
0.007
µ
g
ai/
g
food)
x
(
1500
g
food/
day)
=
10.
5
µ
g
ai/
person/
day
Estimated
Daily
Dietary
Dose
=
EDI/
Body
Weight:
Adult:
(
21
µ
g
ai/
day)
x
(
mg/
1000
µ
g)/(
70
kg)
=
0.00030
mg/
kg/
day
Child:
(
10.5
µ
g
ai/
day)
x
(
mg/
1000
µ
g)/(
15
kg)
=
0.0007
mg/
kg/
day
13.
Chlorine
Dioxide
and
Sodium
Chlorite
as
a
Paper
Coating
Preservative
Use:

As
indicated
by
various
labels
for
chlorine
dioxide/
sodium
chlorite
as
actives,
they
are
added
as
preservatives
to
paper
coating
formulations
at
a
maximum
application
rate
of
1000
ppm,
and
as
the
active
is
25%,
the
actual
application
rate
is
250
ppm.

Assumptions:
1.
The
resulting
paper
coating
is
approximately
10%
by
weight
of
the
paper.
2.
The
standard
basis
weight
of
paper
is
50
mg/
in2.
3.
The
amount
of
food
contacting
the
coated
paper
packaging
is
10
g
of
food/
in2.
4.
The
standard
consumption
factor
(
CF)
for
coated
paper
is
0.20
(
fraction
of
daily
diet
expected
to
contact
paper
coatings).
5.
A
100%
migration
of
chlorine
dioxide/
sodium
chlorite
is
assumed
from
the
coated
paper
to
the
food.
6.
Standard
adult
food
consumption
is
3
kg/
day
and
for
a
child
it
is
1.5
kg/
day.
7.
Adult
body
weight
is
70
kg
and
child
body
weight
is
15
kg.
Page
16
of
18
Output:

Using
the
equation:
Application
Rate
x
%
of
paper
coated
x
basis
paper
wt.
x
surface
area
in
contact
with
food
x
CF
x
%
migration
250
µ
g
ai/
g
coating
x
0.10
g
coating/
g
paper
x
0.05
g
paper/
in2
x
in2
paper
/
10
g
food
x
0.2
x
100%
=
0.025
µ
g
ai/
g
food
or
25
ppb
Estimated
Daily
Intake
(
EDI)
=
Dietary
Conc.
x
Daily
food
consumption:
Adult:
0.025
µ
g
/
g
food
x
3000
g
food/
day
=
75
µ
g
ai/
person/
day
Child:
0.025
µ
g/
g
food
x
1500
g
food/
day
=
37.5
µ
g
ai/
person/
day
Estimation
of
Daily
Dietary
Dose
=
EDI/
Body
Weight:
Adult:
(
75
µ
g
ai/
day)
x
mg/
1000)
/
70
kg
=
0.0011
mg
ai/
kg/
day
Child:
(
37.5
µ
g
ai/
day)
x
mg/
1000
µ
g
/
15
kg
=
0.0025
mg
ai/
kg/
day
From
toxicological
data,
AD
has
determined
that
the
chronic
PAD
from
antimicrobials
uses
for
chlorine
dioxide/
sodium
chlorite
is
0.030
mg/
kg/
day.
%
cPAD
=
exposure
/
cPAD
x
100%.
From
data
above,
the
%
PADs
are
calculated.
None
of
the
chronic
PADs
exceed
the
Agency
level
of
concern.

Table
VI
Cumulative
(
Paper/
Pulp
Uses
10­
13)
Estimated
Dietary
Intake
of
Chlorine
Dioxide
and
Sodium
Chlorite
Use
EDI
(
µ
g/
person/
day)
Daily
Dietary
Dose(
mg/
kg
BW/
day)
Paper
Slimicide
6.9
Adult
3.45
Child
9.8
x
10­
5
Adult
2.3
x
10­
4
Child
Aqueous
Mineral
Slurries
3.45
Adult
1.75
Child
4.9
x
10
­
5
Adult
1.2
x
10­
4
Child
Paper
Adhesive
Preservative
21.0
Adult
10.5
Child
3
x
10­
4
Adult
7
x
10­
4
Child
Paper
Coating
Preservative
75
Adult
37.5
Child
1.1
x
10­
3
Adult
2.5
x
10­
3
Child
Cumulative
106.25
Adult
53.20
Child
1.54
x
10­
3
Adult
3.55
x
10­
3
Child
Page
17
of
18
Table
VII
Dietary
Risks
of
Chlorine
Dioxide
and
Sodium
Chlorite
from
Paper/
Pulp
Uses
(
Sections
10­
13)
Use
Daily
Dietary
Dose
(
mg/
kg
BW
/
day)
%
PAD
Pulp/
Paper
Slimicide
9.8
x
10­
5
Adult
2.3
x
10­
4
Child
0.33
Adult
0.77
Child
Aqueous
Mineral
/
Slurries
4.9
x
10­
5
Adult
1.2
x
10­
4
Child
0.16
Adult
0.40
Child
Paper
Adhesive
Preservative
3
x
10­
4
Adult
7
x
10­
4
Child
1.00
Adult
2.33
Child
Paper
Coating
Preservative
1.1
x
10­
3
Adult
2.5
x
10­
3
Child
3.67
Adult
8.33
Child
Cumulative
1.54
x
10­
3
Adult
3.55
x
10­
3
Child
5.13
Adult
11.83
Child
BIBLIOGRAPHY
1.
AD
Memo
by
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