DRAFT
Didecyl
Dimethyl
Ammonium
Chloride
(
DDAC)

Preliminary
Risk
Assessment
(
DP
Barcode
069149)

Office
of
Pesticide
Programs
Antimicrobials
Division
U.
S.
Environmental
Protection
Agency
1801
South
Bell
St.
Arlington,
VA
22202
Date:
April
18,
2006
Page
2
of
52
TABLE
OF
CONTENTS
1.0
EXECUTIVE
SUMMARY
.........................................................................................................................
3
2.0
PHYSICAL
AND
CHEMICAL
PROPERTIES
......................................................................................
7
3.0
ENVIRONMENTAL
FATE........................................................................................................................
8
4.0
HAZARD
CHARACTERIZATION..........................................................................................................
9
4.1
HAZARD
PROFILE
........................................................................................................................................
9
4.2
FQPA
CONSIDERATIONS...........................................................................................................................
12
4.3
DOSE­
RESPONSE
ASSESSMENT
.................................................................................................................
12
4.4
ENDOCRINE
DISRUPTION
..........................................................................................................................
13
5.0
EXPOSURE
ASSESSMENT
AND
CHARACTERIZATION..............................................................
14
5.1
SUMMARY
OF
REGISTERED
USES..............................................................................................................
14
5.2
DIETARY
EXPOSURE
AND
RISK
.................................................................................................................
14
5.3
DRINKING
WATER
EXPOSURES
AND
RISKS...............................................................................................
16
5.4
RESIDENTIAL
EXPOSURE/
RISK
PATHWAY
................................................................................................
16
6.0
AGGREGATE
RISK
ASSESSMENT
AND
RISK
CHARACTERIZATION...................................
20
6.1
ACUTE
AND
CHRONIC
AGGREGATE
RISKS
...............................................................................................
20
6.2
SHORT­
AND
INTERMEDIATE­
TERM
AGGREGATE
EXPOSURES
AND
RISKS..............................................
21
7.0
CUMULATIVE
EXPOSURE
AND
RISK..............................................................................................
23
8.0
OCCUPATIONAL
EXPOSURE
ASSESSMENT
..................................................................................
24
8.1
OCCUPATIONAL
HANDLER
EXPOSURES....................................................................................................
24
8.2
OCCUPATIONAL
POST­
APPLICATION
EXPOSURES.....................................................................................
26
8.3
WOOD
PRESERVATION..............................................................................................................................
27
8.3.1
Non­
Pressure
Treatment
Scenarios
(
Handler
and
Post­
application)...............................................
27
8.3.2
Pressure
Treatment
Scenarios
(
Handler
and
Post­
Application).......................................................
30
8.4
DATA
LIMITATIONS/
UNCERTAINTIES
.......................................................................................................
31
9.0
INCIDENT
REPORTS
...............................................................................................................................
32
10.0
ENVIRONMENTAL
RISKS.....................................................................................................................
33
11.0
REFERENCES
............................................................................................................................................
36
APPENDIX
A:
MASTER
DDAC
LABEL..............................................................................................................
41
Page
3
of
52
1.0
EXECUTIVE
SUMMARY
This
document
provides
a
risk
assessment
for
the
Group
I
Quat
Cluster.
The
Group
I
Quat
Cluster
is
a
group
of
structurally
similar
quaternary
ammonium
compounds
("
quats")
that
are
characterized
by
having
a
positively
charged
nitrogen
covalently
bonded
to
two
alkyl
group
substituents
(
at
least
one
C8
or
longer)
and
two
methyl
substituents.
In
finished
form,
these
quats
are
salts
with
the
positively
charged
nitrogen
(
cation)
balanced
by
a
negatively
charged
molecule
(
anion).
The
anion
for
the
quats
in
this
cluster
is
chloride
or
bromide.
In
this
document,
the
Group
I
Quat
Cluster
will
be
referred
to
as
DDAC
(
didecyl
dimethyl
ammonium
chloride).

DDAC
is
the
active
ingredient
in
numerous
types
of
products.
The
products
are
mainly
disinfectants
and
deodorants
that
are
used
in
agricultural,
food
handling,
commercial/
institutional/
industrial,
residential
and
public
access,
and
medical
settings.
Examples
of
registered
uses
for
DDAC
in
these
settings
include
application
to
indoor
and
outdoor
hard
surfaces
(
e.
g.,
walls,
floors,
tables,
toilets,
and
fixtures),
eating
utensils,
laundry,
carpets,
agricultural
tools
and
vehicles,
egg
shells,
shoes,
milking
equipment
and
udders,
humidifiers,
medical
instruments,
human
remains,
ultrasonic
tanks,
reverse
osmosis
units,
and
water
storage
tanks.
There
are
also
DDAC­
containing
products
that
are
used
in
residential
and
commercial
swimming
pools,
in
aquatic
areas
such
as
decorative
ponds
and
decorative
fountains,
and
in
industrial
process
and
water
systems
such
as
re­
circulating
cooling
water
systems,
drilling
muds
and
packer
fluids,
oil
well
injection
and
wastewater
systems.
Additionally,
DDAC­
containing
products
are
used
for
wood
preservation
through
nonpressure
and
pressure­
treatment
methods.
There
are
registered
uses
for
fogging
in
occupational
settings.
Products
containing
DDAC
are
formulated
as
liquid
ready­
to­
use,
soluble
concentrate,
pressurized
liquid,
and
water
soluble
packaging.
The
percentage
of
DDAC
in
the
various
end­
use
products
ranges
from
0.08%
to
80%
DDAC.
Residential
products
such
as
EPA
Reg.
No.
10324­
69
range
up
to
50%
DDAC
for
swimming
pools
and
spas.

The
durations
and
routes
of
exposure
evaluated
in
this
assessment
include
short­
term
(
ST),
intermediate­
term
(
IT),
and
in
some
instances
long­
term
(
LT)
inhalation
exposures,
ST
dermal
exposures,
and
ST
oral
exposures.
The
ST
inhalation
endpoint
and
the
ST
oral
endpoint
are
based
on
a
NOAEL
of
10
mg/
kg/
day
from
a
prenatal
developmental
toxicity
study
in
rats.
The
LOAEL
(
20
mg/
kg/
day)
was
based
largely
on
increased
incidence
of
skeletal
variations
in
females.
This
developmental
study,
along
with
a
developmental
study
in
rabbits
do
not
indicate
increased
susceptibility
in
rats
or
rabbits
from
in
utero
and
postnatal
exposures
to
DDAC.
The
IT/
LT
inhalation
endpoint
is
also
based
on
a
NOAEL
of
10
mg/
kg/
day
but
from
a
chronic
toxicity
study
in
dogs.
No
short­
term
dermal
endpoint
for
systemic
effects
was
selected
for
DDAC,
since
no
systemic
effects
were
identified.
However,
a
short­
term
dermal
irritation
endpoint
was
identified.
The
short­
term
dermal
endpoint
for
the
technical
grade
active
ingredient
(
TGAI)
containing
80%
ai
diluted
to
0.1%
DDAC
(
2
mg/
kg/
day
which
is
equivalent
to
8
µ
g/
cm2)
was
determined
from
a
LOAEL
of
6
mg/
kg/
day
based
on
increased
clinical
and
gross
findings
(
erythema,
edema,
exfoliation,
excoriation,
and
ulceration).
A
21­
day
dermal
toxicity
study
was
also
conducted
using
a
0.13%
ai
formulation.
No
short­
term
dermal
endpoint
was
identified
for
this
formulation
because
no
irritation
or
systemic
effects
were
identified
up
to
and
including
the
limit
dose
of
1,000
mg/
kg/
day.
Intermediate­
or
long­
term
dermal
irritation
endpoints
were
not
identified
for
DDAC.
Because
the
effect
to
the
skin
is
localized
skin
irritation,
a
skin
concentration
(
µ
g/
cm2)
of
Page
4
of
52
exposure,
rather
then
a
dose
(
mg/
kg/
day)
was
used
to
assess
the
dermal
risk
concerns.
No
body
weight
is
needed
for
the
dermal
irritation
endpoint,
since
no
systemic
dose
is
calculated.
Since
the
toxicological
endpoint
for
inhalation
is
female­
specific,
a
body
weight
of
60
kilograms
is
used
in
the
assessment.
This
represents
the
body
weight
of
an
adult
female.
The
Agency's
level
of
concern
(
LOC)
for
occupational
and
residential
DDAC
dermal,
inhalation
and
oral
exposures
is
100
(
i.
e.,
a
margin
of
exposure
(
MOE)
less
than
100
exceeds
the
Agency's
level
of
concern).
The
level
of
concern
is
based
on
10x
for
interspecies
extrapolation
and
10x
for
intraspecies
extrapolation.

The
acute
toxicity
categories
(
Tox
Cat)
for
DDAC
include:
acute
oral
(
Tox
Category
II),
acute
dermal
(
Tox
Category
III),
acute
inhalation
(
Tox
Category
I
and
primary
eye
and
skin
irritation
(
Tox
Category
I).
DDAC
is
not
a
dermal
sensitizer.

Dietary
Risk
Summary
DDAC
can
be
used
as
a
disinfectant
or
sanitizer
on
counter
tops,
utensils,
appliances,
tables,
refrigerators,
on
animal
premises
and/
or
farms,
and
in
mushroom
premises.
The
use
of
DDAC
as
an
antimicrobial
product
on
food
or
feed
contact
surfaces,
agricultural
commodities,
and
poultry
premises
including
hatcheries
and
application
to
food­
grade
eggs
may
result
in
pesticide
residues
in
human
food.
Residues
from
treated
surfaces,
such
as
utensils,
countertops,
equipment,
and
appliances
can
migrate
to
food
coming
into
contact
with
the
treated
and
rinsed
surfaces
and
can
be
ingested
by
humans.

The
results
of
the
indirect
food
contact
(
i.
e.,
countertops
and
utensils)
assessment
indicate
no
risks
of
concern.
The
acute
and
chronic
dietary
risks
are
the
same
because
they
are
based
on
the
same
NOAEL.
For
indirect
food
contact
exposures,
the
percent
of
the
acute
and
chronic
population
adjusted
dose
occupied
(%
aPAD
or
cPAD)
is
3.3
percent
for
adults
and
13.3
percent
for
children.
For
direct
applications
to
food,
the
%
aPAD
and
cPAD
for
all
individual
uses
and
populations
is
less
than
or
equal
to
1.
For
the
direct
food
contact
as
well
as
the
indirect
food
contact
the
risks
are
not
of
concern.
The
drinking
water
exposures
from
DDAC
uses
are
negligible
and
are
not
quantifiable.

Residential
Risk
Summary
Dermal
For
the
residential
handler
dermal
exposure
and
risk
assessment,
dermal
risks
were
calculated
by
comparing
residues
on
the
surface
of
the
skin
to
the
short­
term
dermal
irritation
endpoints.
Dermal
residential
handler
exposures
were
not
assessed
for
products
containing
less
than
1%
DDAC.
Additional
dermal
toxicity
studies
could
provide
a
better
characterization
of
the
relationship
between
percent
DDAC
in
a
formulation
and
dermal
irritation.
Residues
on
the
surface
of
the
skin
(
dermal
irritation
exposure)
were
determined
using
hand
unit
exposures
from
CMA
and/
or
PHED
adjusted
for
the
surface
area
of
the
hand
(
mg/
lb
ai/
cm2),
application
rates,
and
use
amounts.
The
dermal
MOEs
were
above
the
target
MOE
of
100
for
all
scenarios
except
for
the
humidifier
and
swimming
pool
applications.

The
residential
post­
application
dermal
risks
were
assessed
by
comparing
the
surface
residue
on
the
skin
(
dermal
skin
irritation
exposure)
to
the
short­
term
dermal
endpoint.
It
was
assumed
that
during
the
exposure
period
the
skin
repeatedly
contacts
the
treated
surface
until
a
steady­
state
concentration
of
residues
is
achieved
on
the
skin.
For
residential
scenarios,
the
Page
5
of
52
post­
application
dermal
MOEs
were
above
the
target
MOE
of
100
for
the
laundered
clothing
(
assuming
1%
residue
transfer)
but
below
the
target
MOE
for
the
following:

 
Wearing
clothes
treated
with
a
fabric
spray:
ST
dermal
MOE
=
<
1
using
both
a
100%
clothing
to
skin
transfer
factor
and
a
5%
clothing
to
skin
transfer
factor.
 
Dermal
contact
on
floors
(
MOE
=
33)
and
carpets
(
MOE
=
45).
 
There
are
no
wipe
data
available
to
assess
the
children's
dermal
contact
to
treated
decks
and/
or
play
sets.
Based
on
hand
measurements
of
workers
at
the
treatment
plants,
dermal
risks
may
be
of
concern
and
therefore
a
wipe
study
is
warranted.

Inhalation
For
the
residential
handler
inhalation
assessment,
the
inhalation
risks
were
calculated
by
comparing
the
daily
doses
to
the
short­
term
inhalation
endpoint.
The
inhalation
MOEs
were
above
the
target
MOE
of
100
for
all
scenarios.

For
the
residential
post­
application
inhalation
exposure
and
risk
assessment,
the
MOEs
were
below
the
target
MOE
of
100
for
the
following
scenario:

 
Humidifier:
ST/
IT
8­
hr
Inhalation
MOE
=
27
for
adults
and
8
for
children;
ST/
IT
24­
hr
Inhalation
MOE
=
11
for
adults
and
5
for
children
Incidental
Oral
For
the
residential
post­
application
incidental
oral
assessment,
the
MOEs
were
above
the
target
MOE
of
100
for
all
scenarios
except
for
mouthing
of
clothes
treated
with
a
fabric
spray
where
the
oral
MOE
=
12.

Aggregate
Risk
Summary
The
acute
and
chronic
dietary
aggregate
risk
assessment
includes
direct
and
indirect
food
contact
uses.
There
are
no
drinking
water
exposures
as
a
result
of
DDAC
applications.
The
acute
and
chronic
endpoints
are
based
on
the
same
NOAEL
value.
Based
on
the
results
of
the
acute
and
chronic
aggregate
assessment,
the
%
aPAD
and
cPAD
for
adults
and
children
are
3.8%
and
14%,
respectively.
Therefore,
the
acute
and
chronic
dietary
aggregate
risks
are
not
of
concern
(
i.
e.,
less
then
100
%
of
aPAD
and/
or
cPAD).

The
DDAC
toxicity
endpoints
for
the
chronic
dietary
and
the
intermediate­
term
incidental
oral
are
based
on
the
same
toxic
effect
(
and
same
study),
and
therefore,
these
two
dietary
routes
of
exposure
are
aggregated.
On
the
other
hand,
the
dermal
and
inhalation
routes
of
exposure
are
based
on
different
toxic
effects,
and
therefore,
these
two
routes
of
exposure
are
not
aggregated.
However,
the
dermal
route
of
exposure
is
aggregated
among
those
dermal
exposure
scenarios
that
are
believed
to
co­
occur.
In
addition,
the
inhalation
route
of
exposure
is
also
aggregated
among
the
inhalation
exposure
scenarios
that
are
believed
to
co­
occur.
The
aggregate
risks
are
not
of
concern
for
adults
for
the
oral
and
inhalation
routes.
However,
the
adult
dermal
MOE
for
the
cleaning
products
are
all
of
concern
by
themselves.
As
an
aggregate,
the
adult
dermal
MOE
is
less
than
the
target
MOE
of
100.
For
children,
the
oral
aggregate
(
dietary
and
intermediate­
term
ingestion
for
children
at
day
care
centers)
is
270.
The
children
aggregate
MOE
for
the
dermal
route
is
42.
No
children
aggregate
inhalation
scenarios
were
determined
to
co­
occur.
It
is
important
to
note,
however,
that
some
of
the
individual
risks
for
scenarios
not
included
in
the
aggregate
are
of
concern
by
Page
6
of
52
themselves
(
e.
g.,
the
humidifier
use
and
the
fabric
spray
for
clothing).

Occupational
Risk
Summary
Dermal
DDAC
dermal
irritation
exposures
and
risks
were
not
estimated
for
occupational
handler
exposures.
Instead,
dermal
irritation
exposures
and
risks
will
be
mitigated
using
default
personal
protective
equipment
requirements
based
on
the
toxicity
of
the
end­
use
product.
To
minimize
dermal
exposures,
the
minimum
PPE
required
for
mixers,
loaders,
and
others
exposed
to
end­
use
products
containing
concentrations
of
DDAC
that
result
in
classification
of
category
I,
II,
or
III
for
skin
irritation
potential
will
be
long­
sleeve
shirt,
long
pants,
shoes,
socks,
chemical­
resistant
gloves,
and
chemical­
resistant
apron.
Once
diluted,
if
the
concentration
of
DDAC
in
the
diluted
solution
would
result
in
classification
of
toxicity
category
IV
for
skin
irritation
potential,
then
the
chemical­
resistant
gloves
and
chemicalresistant
apron
can
be
eliminated
for
applicators
and
others
exposed
to
the
dilute.
Note
that
chemical­
resistant
eyewear
will
be
required
if
the
end­
use
product
is
classified
as
category
I
or
II
for
eye
irritation
potential.

Dermal
irritation
exposures
are
assumed
to
be
negligible
for
all
post­
application
occupational
scenarios,
except
those
associated
with
wood
preservation.
As
with
occupational
handlers,
dermal
irritation
exposures
and
risks
from
post­
application
activities
in
a
wood
preservation
treatment
facility
will
be
mitigated
using
default
personal
protective
equipment
requirements
based
on
the
toxicity
of
the
end­
use
product.
For
construction
workers
handling
treated
wood
the
MOEs
are
potentially
of
concern.
A
wipe
study
on
treated
wood
will
be
needed
to
assess
the
potential
exposure
to
handling
treated
wood.

Inhalation
For
the
occupational
handler
inhalation
exposure
and
risk
assessment,
the
MOEs
were
above
the
target
MOE
of
100
for
all
scenarios.

For
the
occupational
inhalation
post­
application
exposure
and
risk
assessment,
the
MOEs
were
above
the
target
MOE
of
100
for
all
scenarios
except
for
fogging
in
a
food
processing
plant.
The
8­
hr
MOE
from
starting
2
hours
after
application
(
i.
e.,
2
hour
re­
entry
interval)
is
8.

Environmental
Fate
and
Ecological
Risk:
AD
Specific
Uses
The
results
of
the
dietary
avian
studies
indicate
that
DDAC
is
practically
non­
toxic
to
both
mallard
duck
and
bobwhite
quail.
In
the
Acute
oral
studies,
the
chemical
was
found
to
be
moderately
toxic
to
bobwhite
quail.
The
results
from
freshwater
fish
acute
toxicity
studies
demonstrated
that
DDAC
was
moderately
to
highly
toxic.
DDAC
is
very
highly
toxic
to
freshwater
aquatic
invertebrates.
DDAC
is
very
highly
toxic
to
mysid
shrimp
a
marine/
estuarine
invertebrate.
DDAC
is
toxic
to
freshwater
alga
at
microgram
concentrations.
Data
Gaps:
The
following
data
requirements
are
outstanding
for
the
currently
registered
uses
of
DDAC:
850.4225
­
Non­
target
plant
phytotoxicity
testing
(
seedling
emergence
test
using
rice).
850.1035
­
Acute
Sheepshead
minnow
testing
Page
7
of
52
850.1300
­
Acute
eastern
oyster
embryo
larvae
testing
850.1300
­
Chronic
Daphnis
magna
testing
Monitoring/
Tier
II
modeling
of
once­
through
cooling
tower
use
to
establish
EEC's
for
risk
assessment.

Environmental
Fate
and
Eco
Risks:
Agricultural
Premises:

The
Environmental
Fate
and
Effects
Division
(
EFED)
has
evaluated
the
outdoor
use
of
the
quaternary
ammonium
compounds,
didecyl
ammonium
chlorides
(
DDAC),
being
considered
for
reregistration
by
the
Antimicrobial
Division
(
AD)
(
DP
Barcode
D325481).
Although
primarily
used
as
antimicrobial
agents,
DDAC
is
labeled
for
use
in
puddles
and
decorative
pools
to
control
algae.
This
use
is
intended
for
waterbodies
generally
disconnected
from
the
greater
watershed
and
will
not
likely
result
in
exposure
to
nontarget
aquatic
species.
It
is
possible
these
uses
will
result
in
exposure
to
amphibians
utilizing
these
waterbodies
for
some
portion
of
their
lifecycle
(
e.
g.
reproduction)
and
to
birds
and
mammals
utilizing
these
waterbodies
for
drinking
water.
At
the
maximum
label
rate,
3
ppm
initially
followed
by
weekly
1.5
ppm
treatments,
there
are
no
LOC
exceedances,
assuming
the
toxicity
of
DDAC
is
similar
to
that
of
ADBAC.
However,
due
to
the
persistence
of
DDAC,
it
is
possible
that
concentrations
of
DDAC
in
some
waterbodies
treated
over
time
could
become
harmful
to
animals
utilizing
these
waterbodies.

2.0
PHYSICAL
AND
CHEMICAL
PROPERTIES
The
Group
I
Quat
Cluster
is
a
group
of
structurally
similar
quaternary
ammonium
compounds
("
quats")
that
are
characterized
by
having
a
positively
charged
nitrogen
covalently
bonded
to
two
alkyl
group
substituents
(
at
least
one
C8
or
longer)
and
two
methyl
substituents.
In
finished
form,
these
quats
are
salts
with
the
positively
charged
nitrogen
(
cation)
balanced
by
a
negatively
charged
molecule
(
anion).
The
anion
for
the
quats
in
this
cluster
is
chloride
or
bromide.
In
this
document,
the
Group
I
Quat
Cluster
will
be
referred
to
as
DDAC
(
didecyl
dimethyl
ammonium
chloride).

Currently,
there
are
4
active
ingredients
identified
by
the
Agency
that
are
registered
and
included
in
Case
Number
3003.
Table
2.1
below
provides
the
common
chemical
name,
active
ingredient
code,
CAS
number,
chemical
structure
and
number
of
registered
product
for
each
compound.

Table
2.1.
Active
Ingredients
in
the
Group
I
Quat
Cluster
Identified
by
the
AIJV
Prod
Code
CAS
RN
Name
Structure
Chain
Lengths
69149
7173­
51­
5
Didecyl
Dimethyl
Ammonium
Chloride
(
DDAC)
N+

CH3
CH3
R
Cl­
R
R
=
C10
69166
5538­
94­
3
Dioctyl
Dimethyl
Ammonium
Chloride
N+

CH3
CH3
R
Cl­
R
R
=
C8
69165
32426­
11­
2
Octyl
Decyl
Dimethyl
Ammonium
Chloride
N+

CH3
CH3
R1
Cl­
R2
R1
=
C8
(
variable
%)
R2
=
C10
(
variable
%)
Page
8
of
52
Table
2.1.
Active
Ingredients
in
the
Group
I
Quat
Cluster
Identified
by
the
AIJV
Prod
Code
CAS
RN
Name
Structure
Chain
Lengths
69146
84540­
07­
8
Alkyl
Dimethyl
Ethyl
Ammonium
Bromide
N+

CH3
CH3
R
Br­
H3C
R
=
C12
(
5%)
C14
(
90%)
C16
(
5%)

Table
2.2
provides
the
physical/
chemical
characteristics
that
have
been
reported
for
DDAC.

Table2.2.
Physical/
Chemical
Properties
of
DDAC
Parameter
DDAC
Molecular
Weight
362.08
Density
0.9216
g/
cm3
at
25
C
Boiling
Point
NA
Water
Solubility
Completely
soluble
Vapor
Pressure
2.33E­
11
mmHg
3.0
ENVIRONMENTAL
FATE
DDAC
is
used
primarily
as
a
disinfectant,
sanitizer,
or
as
a
microbiocide/
microbiostat.
It
also
serves
as
an
algaecide,
bacteriocide/
bacteriostat,
fungicide/
fungistat,
insecticide,
miticide,
virucide,
and
tuberculocide.
Use
sites
for
DDAC
include
agricultural
premises
and
equipment,
food
handling,
commercial,
industrial
and
institutional
settings,
residential
areas
or
areas
of
public
access,
pets
and
kennels,
medical
facilities,
swimming
pools,
aquatic
areas,
and
industrial
water
systems.
DDAC
is
also
used
as
a
wood
preservative.
As
an
agricultural
pesticide,
DDAC
is
used
for
ornamental
plants,
shrubs,
and
vines.
Some
of
the
required
guideline
studies
for
an
environmental
fate
assessment
have
been
submitted.
The
Agency
is
using
these
environmental
fate
studies
for
fate
assessment
of
DDAC
to
fulfill
the
reregistration
requirements.

DDAC
has
been
shown
to
be
hydrolytically
stable
under
abiotic
and
buffered
conditions
over
the
pH
5­
9
range.
The
calculated
half­
lives
for
DDAC
were
368
days
at
pH
5,
194
days
at
pH
7
(
TRIS),
175
days
at
pH
7
(
HEPES),
and
506
days
at
pH
9.
DDAC
is
stable
to
photodegradation
in
pH
7
buffered
aqueous
solutions;
even
in
the
presence
of
a
photosensitizer
(
acetone),
degradation
is
minimal
with
a
calculated
half­
life
of
227
days.
DDAC
is
photolytically
stable
in
soil
with
a
calculated
half­
life
of
132
days.

Aquatic
metabolism
studies
under
aerobic
and
anaerobic
conditions
indicate
that
DDAC
is
stable
to
microbial
degradation.
The
calculated
aerobic
and
anaerobic
half­
lives
of
14C­
DDAC
in
flooded
river
water
are
180
days
and
261
days,
respectively.
Similarly,
DDAC
was
found
to
be
stable
with
very
little
degradation
in
aerobic
soils
during
a
year­
long
metabolism
study.
The
calculated
half­
life
for
aerobic
soil
degradation
was
1,048
days.
However,
a
report
on
the
biodegradability
of
DDAC
prepared
by
the
Registrant
concluded
that
the
degree
of
DDAC
biodegradability
is
variable
and
is
influenced
by
the
chemical
Page
9
of
52
concentration,
alkyl
chain
length,
the
presence
of
anionic
moieties
and
the
quantity
and
characteristics
of
the
microbial
population.
According
to
this
report,
DDAC
is
biodegradable
and
environmentally
acceptable.
This
report
was
based
on
information
from
the
open
literature,
unpublished
sources,
and
meeting
proceedings
and
has
not
been
reviewed
by
the
Agency.

DDAC
is
immobile
in
soil.
A
soil
mobility
study
reviewed
by
the
Agency
shows
that
DDAC
has
a
strong
tendency
to
bind
to
sediment/
soil
with
Freundlich
Kads
values
of
1,095,
8,179,
3,279,
and
30,851
in
sand,
sandy
loam,
silty
clay
loam,
and
silt
loam
soils,
respectively.
Because
of
its
strong
adsorption
to
soils,
DDAC
is
not
expected
to
contaminate
surface
and
ground
waters.

Bioaccumulation
of
DDAC
in
freshwater
fish
is
not
likely
to
occur.
Mean
steady
state
bioconcentration
factors
for
DDAC
were
determined
to
be
38X,
140X,
and
81X
in
the
edible,
nonedible,
and
whole
body
fish
tissue,
respectively.
During
depuration,
57%,
67%,
and
71%
of
the
residues
that
accumulated
in
the
edible,
whole
body,
and
nonedible
tissues,
respectively,
were
eliminated.
DDAC
is
not
expected
to
pose
a
concern
for
bioconcentration
in
aquatic
organisms.

Information
on
the
aqueous
availability
of
DDAC
from
wood
indicates
that
the
use
of
DDAC
as
a
wood
preservative
may
result
in
minimal
releases
to
the
environment.

The
Environmental
Fate
and
Effects
Division
(
EFED)
has
evaluated
the
outdoor
use
of
the
quaternary
ammonium
compounds,
didecyl
ammonium
chlorides
(
DDAC),
being
considered
for
reregistration
by
the
Antimicrobial
Division
(
AD)
(
DP
Barcode
D325481).
Although
primarily
used
as
antimicrobial
agents,
DDAC
is
labeled
for
use
in
puddles
and
decorative
pools
to
control
algae.
This
use
is
intended
for
waterbodies
generally
disconnected
from
the
greater
watershed
and
will
not
likely
result
in
exposure
to
nontarget
aquatic
species.
It
is
possible
these
uses
will
result
in
exposure
to
amphibians
utilizing
these
waterbodies
for
some
portion
of
their
lifecycle
(
e.
g.
reproduction)
and
to
birds
and
mammals
utilizing
these
waterbodies
for
drinking
water.
At
the
maximum
label
rate,
3
ppm
initially
followed
by
weekly
1.5
ppm
treatments,
there
are
no
LOC
exceedances,
assuming
the
toxicity
of
DDAC
is
similar
to
that
of
ADBAC.
However,
due
to
the
persistence
of
DDAC,
it
is
possible
that
concentrations
of
DDAC
in
some
waterbodies
treated
over
time
could
become
harmful
to
animals
utilizing
these
waterbodies.

4.0
HAZARD
CHARACTERIZATION
4.1
Hazard
Profile
DDAC
was
assigned
a
Toxicity
Category
II
from
results
of
two
acute
oral
toxicity
studies
in
rats,
MRIDs
41394404
[
65%
a.
i.;
LD50
=
262
mg/
kg
(
combined)]
and
42296101
[
80%
a.
i.;
LD50
=
238
mg/
kg
(
combined)].
DDAC
was
assigned
Toxicity
Category
III
from
two
acute
dermal
toxicity
studies
in
rabbits,
MRIDs
42053801
[
65%
a.
i.;
LD50
=
2930
mg/
kg
(
combined)]
and
00071158
[
50%
a.
i.;
LD50
=
4350
mg/
kg
(
combined)].
For
acute
inhalation
toxicity
(
MRID
00145074;
TRID
455201010),
DDAC
(
purity
not
reported)
is
assigned
a
Toxicity
Category
I
(
LC50
=
0.07
mg/
L).
For
primary
eye
irritation,
DDAC
was
found
to
be
corrosive
(
Toxicity
Category
I)
in
two
primary
eye
irritation
studies
in
rabbits,
MRIDs
Page
10
of
52
41394404
[
65%
a.
i.]
and
42161602
[
80%
a.
i].
For
primary
dermal
irritation,
DDAC
(
80%
a.
i.)
was
found
to
be
corrosive
(
Toxicity
Category
I)
in
a
primary
dermal
irritation
study
in
rabbits
(
MRID
42161601).
For
dermal
sensitization,
DDAC
was
found
to
be
a
non­
sensitizer
in
two
dermal
sensitization
studies
in
guinea
pigs
(
MRID
42161603
[
80%
a.
i.])
(
MRID
46367601
[
purity
not
reported]).

For
subchronic
toxicity,
the
database
includes
a
90­
day
oral
toxicity
test
in
rats
(
MRID
40966302),
a
90­
day
oral
study
in
dogs
(
MRID
40262901),
and
a
90­
day
dermal
toxicity
study
in
rats
(
MRID
41305901).
In
the
90­
day
rat
oral
feeding
study
(
MRID
40966302),
incidence
of
gross
pathological
observations
and
non­
neoplastic
lesions,
including
a
higher
incidence
of
glycogen
depletion
in
the
liver
and
contracted
spleens
were
observed.
In
the
90­
day
dog
feeding
study
(
MRID
40269201),
no
treatment­
related
clinical
chemistry,
hematology,
urinalysis,
or
pathological
findings
were
observed.
In
the
90­
day
dermal
toxicity
test
in
rats
(
MRID
41305901),
systemic
toxicity
was
not
observed
and
clinical
and
gross
findings
(
erythema,
edema,
exfoliation,
excoriation
and
ulceration)
were
limited
to
the
treated
skins.

For
developmental
toxicity,
the
data
from
two
developmental
toxicity
studies,
one
in
the
rat
(
MRID
41886701,
range­
finder
MRID
42746901)
and
another
in
the
rabbit
(
MRID
41018701),
do
not
indicate
increased
susceptibility
in
rats
or
rabbits
from
in
utero
and
postnatal
exposure
to
DDAC.
In
the
rat
developmental
toxicity
study
(
MRID
41886701),
developmental
toxicity
(
skeleton
variations)
was
observed
only
at
treatment
levels
which
also
resulted
in
maternal
toxicity
(
audible
respiration).
In
the
rabbit
developmental
toxicity
study,
developmental
toxicity
(
decreased
fetal
body
weight
and
increased
number
of
dead
fetuses)
occurred
at
levels
which
also
resulted
in
maternal
toxicity
(
hypo
activity,
audible
respiration,
and
decreased
body
weight
gain).

For
reproductive
toxicity,
the
toxicity
database
for
DDAC
includes
a
2­
generational
reproductive
toxicity
study
in
rats
(
MRID
41804501).
In
this
study,
effects
in
offspring
(
decreased
pup
body
weight/
weight
gain)
occurred
at
the
same
dose
level
as
maternal
effects
(
decreased
maternal
body
weight/
weight
gain
and
food
consumption).

In
a
1­
year
dog
feeding
study
(
MRID
41970401),
beagle
dogs
were
given
doses
of
0,
3,
10,
or
20/
30
mg/
kg/
day
in
the
diet.
Treatment­
related
clinical
signs
(
soft/
mucoid
feces,
emesis)
were
observed
frequently
in
high­
dose
animals,
and
total
cholesterol
levels
were
significantly
decreased
in
high­
dose
females.

DDAC
was
not
carcinogenic
when
administered
in
the
diet
in
2­
year
chronic/
carcinogenicity
studies
in
rats
(
MRID
41965101)
and
mice
(
MRID
41802301).
In
the
rat
study,
an
increase
in
incidence
of
interstitial
cell
adenomas
in
the
testes
were
reported,
but
the
incidence
was
with
in
the
range
of
historical
controls.
In
the
mouse
study,
no
treatmentrelated
effects
were
noted
in
the
incidence
of
clinical
signs,
deaths,
and
gross
and
histopathological
observations.

For
mutagenicity,
DDAC
was
negative
in
a
battery
of
tests.
In
the
Ames
test
(
MRID
40282201,
supplemental
information
MRID
44005801);
DDAC
was
not
mutagenic
with
or
without
metabolic
activation.
In
a
forward
gene
mutation
test
(
MRID
93014008,
reformat
of
40895202),
DDAC
was
negative
for
induction
of
gene
mutations
in
CHO
cells
at
the
HGPRT
locus
with
and
without
metabolic
activation.
In
an
in
vitro
chromosome
aberration
test
Page
11
of
52
(
MRID
41252601),
DDAC
did
not
induce
chromosome
aberration
in
the
Chinese
hamster
ovary
(
CHO)
cells
with
or
without
metabolic
activation.
In
an
unscheduled
DNA
synthesis
(
UDS)
assay
(
MRID
93014007,
reformat
of
40895201),
DDAC
did
not
cause
UDS
in
primary
rat
hepatocytes.

Although
there
are
no
neurotoxicity
studies
available
in
the
database,
the
available
toxicity
for
DDAC
show
no
evidence
for
neurotoxic
effects.

In
a
rat
pharmacokinetics/
metabolism
study
(
MRID
41617101
and
addendum
MRID
41385101),
single
oral
doses
of
14C­
DDAC
(
5
or
50
mg/
kg)
or
repeated
doses
(
34
ppm
of
DDAC
in
the
diet
for
14
days
and
then
one
single
dose
of
5
mg/
kg
of
14C­
DDAC)
were
given
to
both
male
and
female
rats.
DDAC
was
mostly
excreted
in
the
feces
within
3
days
principally
as
parent
compound
and
metabolites.
The
elimination
pattern
and
metabolic
profile
was
not
substantially
altered
by
the
dose
or
exposure
duration.
Male
and
female
rats
showed
similar
elimination
patterns,
but
females
metabolized
DDAC
more
extensively
than
males.
Four
major
metabolites
were
identified
as
oxidation
products
with
oxidation
confined
to
the
decyl
side
chains.

The
acute
toxicity
data
for
DDAC
are
summarized
below
in
Table
4.1
(
USEPA,
2006).

Table
4.1
Acute
Toxicity
Data
for
DDAC
Guideline
No.
Study
Type
MRID
#(
S).
Results
Toxicity
Category
81­
1
Acute
Oral
42296101
41394404
LD50
(
combined)
=
238
mg/
kg
LD50
(
combined)
=
262
mg/
kg
II
81­
2
Acute
Dermal
42053801
LD50
(
 
)
=
3140mg/
kg;
LD50
(
 
)
=
2730mg/
kg;
LD50
(
combined)
=
2930
mg/
kg
III
81­
3
Acute
Inhalation
00145074
LC50
=
0.07mg/
L
I
81­
4
Primary
Eye
Irritation
42161602
41394404
Severe
eye
irritant
I
81­
5
Primary
Skin
Irritation
42160601
Severe
dermal
irritant
I
81­
6
Dermal
Sensitization
46367601
Not
a
sensitizer
Page
12
of
52
4.2
FQPA
Considerations
Under
the
Food
Quality
Protection
Act
(
FQPA),
P.
L.
104­
170,
which
was
promulgated
in
1996
as
an
amendment
to
the
Federal
Insecticide,
Fungicide,
and
Rodenticide
Act
(
FIFRA)
and
the
Federal
Food,
Drug
and
Cosmetic
Act
(
FFDCA),
the
Agency
was
directed
to
"
ensure
that
there
is
a
reasonable
certainty
that
no
harm
will
result
to
infants
and
children"
from
aggregate
exposure
to
a
pesticide
chemical
residue.
The
law
further
states
that
in
the
case
of
threshold
effects,
for
purposes
of
providing
this
reasonable
certainty
of
no
harm,
"
an
additional
tenfold
margin
of
safety
for
the
pesticide
chemical
residue
and
other
sources
of
exposure
shall
be
applied
for
infants
and
children
to
take
into
account
potential
pre­
and
postnatal
toxicity
and
completeness
of
the
data
with
respect
to
exposure
and
toxicity
to
infants
and
children.
Notwithstanding
such
requirement
for
an
additional
margin
of
safety,
the
Administrator
may
use
a
different
margin
of
safety
for
the
pesticide
residue
only
if,
on
the
basis
of
reliable
data,
such
margin
will
be
safe
for
infants
and
children."

The
Agency
(
USEPA,
2006)
has
decided
that
the
FQPA
safety
factor
be
removed
for
DDAC,
based
upon
the
existence
of
a
complete
developmental
and
reproductive
toxicity
database
and
the
lack
of
evidence
for
increased
susceptibility
in
these
data.

4.3
Dose­
Response
Assessment
Table
4.2
summarizes
the
toxicological
endpoints
for
DDAC
(
USEPA,
2006).

Table
4.2
Summary
of
Toxicological
Endpoints
for
DDAC
Exposure
Scenario
Dose
Used
in
Risk
Assessment
(
mg/
kg/
day)
Target
MOE/
UF,
Special
FQPA
SF
for
Risk
Assessment
Study
and
Toxicological
Effects
NOAEL(
developmental)
=
10
mg/
kg/
day
FQPA
SF
=
1
UF
=
100
(
10x
inter­
species
extrapolation,
10x
intra­
species
variation)
Prenatal
Developmental
Toxicity
­
Rat
MRID
41886701
LOAEL
=
20
mg/
kg/
day
based
on
increased
incidence
of
skeletal
variations.
Acute
Dietary
(
Females
13­
50)

Acute
RfD
=
0.1
mg/
kg/
day
(
for
Females
age
13­
50)

Acute
Dietary
(
general
population)
An
acute
dietary
endpoint
was
not
identified
in
the
data
base.
This
risk
assessment
is
not
required
NOAEL
=
10
mg/
kg/
day
FQPA
SF
=
1
UF
=
100
(
10x
inter­
species
extrapolation,
10x
intra­
species
variation
Chronic
Toxicity
Study
­
Dog
MRID
41970401
LOAEL
=
20
mg/
kg/
day
based
on
increased
incidence
of
clinical
signs
in
males
and
females
and
decreased
total
cholesterol
levels
in
females.
Chronic
Dietary
(
general
population)

Chronic
RfD
=
0.1
mg/
kg/
day
Non­
Dietary
Exposures
Page
13
of
52
Table
4.2
Summary
of
Toxicological
Endpoints
for
DDAC
Exposure
Scenario
Dose
Used
in
Risk
Assessment
(
mg/
kg/
day)
Target
MOE/
UF,
Special
FQPA
SF
for
Risk
Assessment
Study
and
Toxicological
Effects
Incidental
Oral
Short­
Term
NOAEL
(
developmental)
=
10
mg/
kg/
day
Target
MOE
=
100
(
10x
interspecies
extrapolation,
10x
intraspecies
variation)
FQPA
SF
=
1
Prenatal
Developmental
Toxicity
­
Rat
MRID
41886701
LOAEL
=
20
mg/
kg/
day
based
on
increased
incidence
of
skeletal
variations.

Incidental
Oral
Intermediate­
Term
NOAEL
=
10
mg/
kg/
day
Target
MOE
=
100
(
10x
interspecies
extrapolation,
10x
intraspecies
variation)
FQPA
SF
=
1
Chronic
Toxicity
Study
­
Dog
MRID
41970401
LOAEL
=
20
mg/
kg/
day
based
on
increased
incidence
of
clinical
signs
in
males
and
females
and
decreased
total
cholesterol
levels
in
females.

Dermal,
Short­
term
(
formulated
product,
0.13%
a.
i.)
No
endpoint
identified.
No
dermal
or
systemic
effects
identified
in
the
21­
day
dermal
toxicity
study
(
MRID
45656601)
up
to
and
including
the
limit
dose
of
1000
mg/
kg/
day
Dermal,
Short­
term
(
TGAI
80%
diluted
to
0.1%)
NOAEL(
dermal)
=
2
mg/
kg/
day
(
8
µ
g/
cm2)
b
Target
MOE
=
100
(
10x
interspecies
extrapolation,
10x
intraspecies
variation)
90­
day
Dermal
Toxicity
­
Rat
MRID
41305901
LOAEL
=
6
mg/
kg/
day
based
on
increased
clinical
and
gross
findings
(
erythema,
edema,
exfoliation,
excoriation,
and
ulceration)

Dermal,
Intermediateand
Long­
term
(
formulated
product)
No
appropriate
endpoint
identified.

Inhalation,
Short­
Term
NOAEL
b
=
10
mg/
kg/
day
Target
MOE
=
100
(
10x
interspecies
extrapolation,
10x
intraspecies
variation)
FQPA
SF
=
1
Prenatal
Developmental
Toxicity
­
Rat
MRID
41886701
LOAEL
=
20
mg/
kg/
day
based
on
increased
incidence
of
skeletal
variations.

Inhalation,
Intermediate­
and
Long­
Term
NOAEL
c
=
10
mg/
kg/
day
Target
MOE
=
100
(
10x
interspecies
extrapolation,
10x
intraspecies
variation)
FQPA
SF
=
1
Chronic
Toxicity
Study
­
Dog
MRID
41970401
LOAEL
=
20
mg/
kg/
day
based
on
decreased
total
cholesterol
levels
in
females.

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.
ashort­
term
dermal
endpoint
=
(
2
mg/
kg
rat
x
0.2
kg
rat
x
1000
ug/
mg)
/
50cm2
area
of
rat
dosed
=
8
µ
g/
cm2
.
b
an
additional
UF
of
10x
is
used
for
route
extrapolation
from
an
oral
endpoint
to
determine
if
a
confirmatory
study
is
warranted.

4.4
Endocrine
Disruption
Page
14
of
52
EPA
is
required
under
the
FFDCA,
as
amended
by
FQPA,
to
develop
a
screening
program
to
determine
whether
certain
substances
(
including
all
pesticide
active
and
other
ingredients)
"
may
have
an
effect
in
humans
that
is
similar
to
an
effect
produced
by
a
naturally
occurring
estrogen,
or
other
such
endocrine
effects
as
the
Administrator
may
designate."
Following
recommendations
of
its
Endocrine
Disruptor
and
Testing
Advisory
Committee
(
EDSTAC),
EPA
determined
that
there
was
a
scientific
basis
for
including,
as
part
of
the
program,
the
androgen
and
thyroid
hormone
systems,
in
addition
to
the
estrogen
hormone
system.
EPA
also
adopted
EDSTAC's
recommendation
that
the
Program
include
evaluations
of
potential
effects
in
wildlife.
For
pesticide
chemicals,
EPA
will
use
FIFRA
and,
to
the
extent
that
effects
in
wildlife
may
help
determine
whether
a
substance
may
have
an
effect
in
humans,
FFDCA
authority
to
require
the
wildlife
evaluations.
As
the
science
develops
and
resources
allow,
screening
of
additional
hormone
systems
may
be
added
to
the
Endocrine
Disruptor
Screening
Program
(
EDSP).

5.0
EXPOSURE
ASSESSMENT
AND
CHARACTERIZATION
5.1
Summary
of
Registered
Uses
For
dietary
uses,
DDAC
can
be
used
as
a
disinfectant
or
sanitizer
on
counter
tops,
utensils,
appliances,
tables,
refrigerators,
on
animal
premises
and/
or
farms,
and
in
mushroom
premises.
The
use
of
DDAC
as
an
antimicrobial
product
on
food
or
feed
contact
surfaces,
agricultural
commodities,
and
poultry
premises
including
hatcheries
and
application
to
foodgrade
eggs
may
result
in
pesticide
residues
in
human
food.
Residues
from
treated
surfaces,
such
as
utensils,
countertops,
equipment,
and
appliances
can
migrate
to
food
coming
into
contact
with
the
treated
and
rinsed
surfaces
and
can
be
ingested
by
humans.

Products
containing
DDAC
can
be
used
as
general
cleaners,
disinfectants,
and
deodorizers.
These
products
are
primarily
for
use
on
indoor
surfaces
such
as
hard
floors,
carpets,
walls,
bathroom
fixtures,
trash
cans,
toilet
bowls,
and
household
contents.
Additionally,
other
uses
in
the
home
include
liquid
laundry
deodorizers
that
are
added
to
the
final
rinse
of
the
wash
cycle,
algaecide/
bactericides
that
are
added
to
portable
humidifiers
and
swimming
pools,
and
deodorizers
that
are
sprayed
on
fabric.
Residents
may
also
be
exposed
to
items
that
have
been
treated
with
DDAC
in
occupational
settings,
such
as
dimensional
lumber
for
decks
and
play
sets.
Appendix
A
presents
a
summary
of
all
exposure
scenarios
that
may
occur
in
residential
settings
based
on
examination
of
product
labels.

The
non
antimicrobial
uses
of
DDAC
are
assessed
separately
by
the
Health
Effects
Division
(
DP
Barcode:
D
326896).

5.2
Dietary
Exposure
and
Risk
In
the
absence
of
data
on
DDAC
residues
on
treated
food
contact
surfaces,
the
Agency
estimated
residue
levels
that
may
occur
in
food
from
the
application
rates
on
food
contact
surfaces.
Dietary
exposures
from
poultry
hatcheries,
mushroom
houses
and
hydroponic
uses
are
expected
to
be
much
lower
than
the
dietary
exposures
resulting
from
the
surface
disinfectant
and
sanitizing
uses;
therefore,
these
uses
were
not
assessed
separately.

To
estimate
the
Estimated
Daily
Intake
(
EDI)
to
treated
food
contact
surfaces
and
Page
15
of
52
food
utensils,
an
FDA
(
FDA,
2003)
model
was
used
in
lieu
of
residue
data.
The
maximum
application
rate
for
DDAC
in
food
handling
establishments
from
the
various
labeled
ready­
touse
products
is
0.0043
pounds
per
gallon
of
treatment
solution.
The
EDI
calculations
presented
in
this
assessment
assumes
that
food
can
contact
2,000
cm2
or
4,000
cm2
(
50%
and
100%
of
the
FDA
worst
case
scenario)
of
treated
surfaces,
and
that
10%
of
the
pesticide
migrate
to
food.
The
use
of
the
10%
transfer
rate,
instead
of
the
use
of
a
100%
transfer
rate
that
is
used
in
the
FDA
Sanitizer
Solution
Guidelines,
requires
the
submission
of
confirmatory
data
to
establish
the
reliability
of
the
use
of
the10%
transfer
rate.
These
daily
estimates
were
conservatively
used
to
assess
both
acute
and
chronic
dietary
risks.
None
of
the
calculated
percent
acute
population
adjusted
dose
(%
aPAD)
or
chronic
(%
cPAD)
estimates
exceeded
100%.
The
estimated
EDI,
%
aPAD,
and
%
cPAD
for
food
contact
surfaces
are
presented
in
Table
5.1.
Note:
The
NOAEL
for
both
the
acute
and
chronic
dietary
endpoints
are
the
same
so
only
one
%
PAD
is
reported
(
i.
e.,
aPAD
and
cPAD
are
identical).
The
results
indicate
that
for
the
aggregate
risks
the
adult
%
aPAD
and
%
cPAD
is
2.8%
for
males
and
3.3%
for
females,
and
for
children
13.3%.

For
DDAC
treatments
of
food
processing
plants,
the
application
rates
are
similar
to
food
handling
establishments
presented
in
Table
5.1,
and
hence
the
exposure,
EDIs,
DDDs,
and
%
aPAD
and
cPADs
are
also
similar.

Table
5.1:
Calculated
EDIs,
aPAD,
and
cPAD
for
Utensils
and
Countertops
Utensils
Countertops
Aggregate
Exposure
Group
EDI
(
mg/
day)
DDD
(
mg/
kg/
d)
%
PADa
EDI
(
mg/
day)
DDD
(
mg/
kg/
d)
%
PADa
EDI
(
mg/
p/
d)
DDD
(
mg/
kg/
d)
%
PADa
(
mg/
kg/
d)

Adult
males
0.0959
0.00137
1.37
0.103
0.00147
1.47
0.199
0.00284
2.84
Adult
females
0.0959
0.00160
1.60
0.103
0.00172
1.72
0.199
0.00332
3.32
Children
0.0959
0.00639
6.39
0.103
0.00687
6.87
0.199
0.0133
13.3
a.
%
PAD
=
exposure
(
DDD)
/(
aPAD
or
cPAD)
x
100.
The
acute
and
chronic
population
average
dose
is
the
same;
therefore
the
%
PADs
are
the
same.
EDI
is
the
estimated
daily
intake
(
mg/
day).
DDD
is
the
dietary
daily
dose
(
mg/
kg/
day).

The
maximum
application
rate
for
DDAC
for
bottling/
packing
of
food
is
0.0020
lbs
a.
i
per
gallons
of
treatment
solution.
EDI
values
were
calculated
using
an
approach
similar
to
that
used
for
treated
food­
contact
surfaces
and
food
utensils.
Exposure
was
assumed
to
occur
through
the
ingestion
of
three
food
products
that
might
be
packaged
with
treated
material:
milk,
egg
products,
and
beverages
(
alcoholic
and
non­
alcoholic).
The
calculated
%
aPAD
and
%
cPAD
did
not
exceed
100%.
The
results
of
the
EDI
and
%
cPAD
are
presented
in
Table
%.
2.
Page
16
of
52
Table
5.2:
Calculated
EDIs,
aPAD,
and
cPAD
for
Representative
Dairy
and
Beverage
Consumption
Food
Type
Exposure
Group
EDI
(
mg/
p/
d)
DDD
(
mg/
kg/
d)
%
PAD
(
aPAD
&
cPAD)

Adult
Male
6.44x10­
5
0.0644
Adult
Female
0.00451
7.52x10­
5
0.0752
Milk
Childa
0.00290
1.94x10­
4
0.194
Adult
Male
1.16x10­
10
1.16x10­
7
Adult
Female
8.10x10­
9
1.35x10­
10
1.35x10­
7
Egg
product
Child
a
5.22x10­
9
3.48x10­
10
3.48x10­
7
Adult
Male
3.29x10­
4
0.329
Adult
Female
0.0230
3.84x10­
4
0.384
Beverages,
non­
alcoholic
Childa
0.0148
9.90x10­
4
0.990
Adult
Male
4.16x10­
6
0.00416
Beverages,
alcoholic,
beer
Adult
Female
2.91x10­
4
4.85x10­
6
0.00485
5.3
Drinking
Water
Exposures
and
Risks
The
only
DDAC
outdoor
uses
are
as
an
algaecide
in
decorative
pools
and
for
oil
field
operations
which
are
considered
to
be
contained.
Therefore,
the
DDAC
contributions
to
drinking
water
exposure
are
considered
to
be
negligible
and
are
not
quantified.

5.4
Residential
Exposure/
Risk
Pathway
The
exposure
scenarios
assessed
in
this
document
for
the
representative
antimicrobial
uses
selected
by
the
Agency
to
represent
the
residential
risks
include:

 
Indoor
hard
surfaces
(
e.
g.,
mopping,
wiping,
trigger
pump
sprays);
 
Carpets;
 
Swimming
pools;
 
Wood
preservative;
 
Textiles
(
e.
g.,
diapers
treated
during
washing
and
clothes
treated
with
fabric
spray);
and
 
Humidifiers.

Exposure
Data
and
Assumptions
The
residential
handler
scenarios
were
assessed
to
determine
dermal
and
inhalation
exposures.
The
scenarios
were
assessed
using
PHED
and
CMA
data.
Specific
surrogate
data
used
in
determining
the
dermal
and
inhalation
exposures
are
reported
below:

$
For
the
mopping,
wiping,
low
pressure
hand
wand,
and
liquid
pour
in
swimming
pool
the
CMA
data
were
used;
and
$
For
aerosol
spray
and
trigger
pump
scenarios
the
PHED
data
were
used.

The
quantities
handled/
treated
were
estimated
based
on
information
from
various
sources,
including
the
Antimicrobial
Division's
estimates.
Page
17
of
52
$
For
mopping
scenarios,
it
is
assumed
that
1
gallon
of
diluted
solution
is
used.

$
For
wiping
and
trigger
pump
spray
scenarios,
it
is
assumed
that
0.5
liter
(
0.13
gal)
of
diluted
solution
is
used.

$
For
low
pressure
hand
wand,
it
was
assumed
that
2
gallons
are
used
in
all
indoor
applications.

$
For
liquid
pour
in
swimming
pool
scenario,
it
was
assumed
that
a
residential
pool
contains
20,000
gallons
of
water.

$
For
liquid
pour
in
humidifier
scenario,
it
was
assumed
that
a
humidifier
with
a
11
gallon
tank
would
be
treated,
based
on
Holmes
Model#
HM4600­
U­
11.
This
humidifier
releases
11
gallons/
1,700
ft2/
24
hours
(
http://
www.
holmesproducts.
com/
estore/
product.
aspx?
CatalogId=
3&
CategoryId=
112
0&
ProductId=
582).

Post­
application
scenarios
have
been
developed
that
encompass
multiple
products,
but
still
represent
a
high
end
exposure
scenario
for
all
products
represented.
Post­
application
scenarios
assessed
include
crawling
on
treated
hard
surfaces,
carpets,
and
treated
lumber
such
as
decks/
play
sets
(
dermal
and
incidental
oral
exposure
to
children),
wearing
treated
clothing
from
wash
treatment
and
from
a
direct
clothing
spray
treatment
(
dermal
exposure
to
adults
and
children
and
incidental
oral
exposure
to
children),
using
portable
humidifiers
(
adult
and
child
inhalation
exposure),
and
swimming
in
treated
pools
(
adult
and
child
incidental
ingestion).

Since
no
toxicological
endpoint
of
concern
was
identified
for
dermal
systemic
adverse
effects,
post­
application
dermal
risks
were
assessed
using
the
toxicological
endpoint
of
concern
for
dermal
irritation.
Note:
Products
containing
less
then
1
percent
were
not
assessed
as
no
dermal
endpoint
was
identified.
The
residential
post­
application
dermal
risks
were
assessed
by
comparing
the
surface
residue
on
the
skin
(
dermal
skin
irritation
exposure)
to
the
short­
term
dermal
irritation
endpoint.
It
was
assumed
that
during
the
exposure
period,
the
skin
repeatedly
contacts
the
treated
surface
until
a
steady­
state
concentration
of
residues
is
achieved
on
the
skin.

The
duration
of
exposure
for
most
homeowner
exposures
is
believed
to
be
best
represented
by
the
short­
term
duration
(
1
to
30
days).
The
reason
that
short­
term
duration
was
chosen
to
be
assessed
is
because
the
different
handler
and
post­
application
scenarios
are
assumed
to
be
episodic,
not
daily.
In
addition,
homeowners
are
assumed
to
use
different
products
with
varying
activities,
not
exclusively
DDAC
treated
products.

Risk
Characterization
A
summary
of
the
residential
handler
inhalation
risks
are
presented
in
Table
5.3.
Although
the
inhalation
endpoint
represents
short­,
intermediate­,
and
long­
term
durations,
the
exposure
duration
of
most
homeowner
applications
of
cleaning
products
is
believed
to
be
best
represented
by
the
short­
term
duration.
The
inhalation
toxicological
endpoint
is
based
on
an
oral
study
because
a
route­
specific
inhalation
study
is
not
available.
The
calculated
inhalation
MOEs
are
above
the
target
MOE
of
100.
The
dermal
MOEs
are
presented
in
Table
5.4.
The
dermal
MOEs
were
below
the
target
MOE
of
100
for
all
scenarios
evaluated
except
for
applications
to
humidifiers
and
swimming
pools
.
Page
18
of
52
Table
5.3
Short­
Term
Residential
Handler
Inhalation
Exposures
and
MOEs
Exposure
Scenario
Application
Method
Application
Method
Application
Ratea
(
lb
ai/
gallon)
Quantity
Handled/
Treated
per
dayb
(
gallons)
Unit
Exposure
(
mg/
lb
a.
i.)
Daily
Dose
(
mg/
kg/
day)
c
MOE
d
(
Target
MOE
=
100)

Mopping
0.020
1
2.38
0.00079
13,000
Wiping
0.020
0.13
67.3
0.0029
3,400
Application
to
indoor
hard
surfaces
Trigger
Spray
0.020
0.13
2.4
0.00010
96,000
Application
to
Carpets
Low
Pressure
Spray
0.0088
2
0.681
0.012
50,000
Application
to
Swimming
Pools
Liquid
Pour
0.0000244
20,000
0.00346
0.00002
510,000
Application
to
Humidifiers
Liquid
Pour
0.0043
11
1.89
0.0015
6,700
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
DDAC.
b
Amount
handled
per
day
values
are
estimates
or
label
instructions.
c
Daily
dose
(
mg/
kg/
day)
=
[
unit
exposure
(
mg/
lb
a.
i.)
x
application
rate
(
lb
ai/
gal)
x
quantity
treated
(
gal/
day)
x
absorption
factor
(
1.0
for
inhalation)]/
Body
weight
(
60
kg
for
inhalation).
d
MOE
=
NOAEL
/
Absorbed
Daily
Dose.
[
Where
short­
term
NOAEL
=
10
mg/
kg/
day
for
inhalation].
Target
MOE
=
100.

Table
5.4
Short­
Term
Residential
Handler
Dermal
Risks
Exposure
Scenario
Application
Method
Application
Ratea
(
lb
ai/
gal)
Quantity
Handled/
Treated
per
dayb
(
gallon)
Hand
Unit
Exposure
Adjusted
for
Surface
Area
(
mg/
lb
ai/
cm2)
c
Dermal
Skin
Irritation
Exposure
d
(:
g/
cm2)
MOE
e
(
Target
MOE
=
100)

Products
with
<
1%
DDAC
No
dermal
endpoint
identified
for
products
with
<
1%
DDAC
Products
with
1
to
10%
DDAC
(
NOAEL=
8
µ
g/
cm3)

Mopping
0.0043
1
0.063
0.273
29
Wiping
0.0043
0.13
1.341
0.750
11
Application
to
indoor
hard
surfaces
Trigger
Spray
0.0043
0.13
0.129
0.072
110
Application
to
Carpets
Low
Pressure
Spray
0.0088
2
0.161
2.832
3
Humidifier
Liquid
Pour
0.0043
11
0.000239
0.011
710
Application
to
swimming
pools
Liquid
Pour
0.000017
20,000
0.000239
0.080
98
Products
with
>
10%
DDAC
(
NOAEL=
8
µ
g/
cm3)

Mopping
0.020
1
0.063
1.27
6
Wiping
0.020
0.13
1.341
3.49
2
Application
to
indoor
hard
surfaces
Trigger
Spray
0.020
0.13
0.129
0.34
24
Application
to
Carpets
Low
Pressure
Spray
0.0085
2
0.161
2.731
3
Application
to
swimming
pools
Liquid
Pour
0.000017
20,000
0.000239
0.08
98
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
DDAC.
b
Amount
handled
per
day
values
are
estimates
or
label
instructions.
c
Unit
Exposure
(
mg/
lb
ai/
cm2)
=
Hand
unit
exposure
from
PHED
or
CMA
(
mg/
lb
ai)
/
surface
area
of
hand
(
820
cm2).
d
Dermal
Skin
Irritation
Exposure
(:
g/
lb
ai/
cm2)
=
Unit
Exposure
(
mg/
lb
ai/
cm2)
x
Application
Rate
(
lb
ai/
gal)
x
Quantity
Treated
(
gal/
day)
x
1,000
:
g/
mg
e
MOE
=
NOAEL
(:
g/
cm2)/
Dermal
Skin
Irritation
Exposure
(:
g/
cm2).
[
Where
short­
term
dermal
NOAEL
=
8
µ
g/
cm2.
Target
MOE
=
100.
Page
19
of
52
A
summary
of
the
residential
post
application
are
presented
in
Table
5.5.
Although
the
inhalation
endpoint
represents
short­,
intermediate­,
and
long­
term
durations,
the
exposure
duration
of
most
homeowner
applications
of
cleaning
products
is
believed
to
be
best
represented
by
the
short­
term
duration.
The
inhalation
toxicological
endpoint
is
based
on
an
oral
study
because
a
route­
specific
inhalation
study
is
not
available.
The
calculated
incidental
oral
MOEs
are
above
the
target
MOE
of
100.
The
dermal
MOEs
are
below
the
target
MOE
for
all
scenarios
except
for
the
laundered
clothing.
The
inhalation
MOEs
are
above
the
target
MOE
of
100
for
all
scenarios,
except
the
humidifier.
The
24­
hour
inhalation
MOEs
for
adults
and
children
are
10
and
4,
respectively.

Table
5.5.
Short­
term
Residential
Post
Application
Risks
for
Adults
and
Children.
Exposure
Scenario
Dermal
MOE
Incidental
Ingestion
MOE
Inhalation
MOE
Child
playing
on
floor
33
760
NA
Child
playing
on
carpet
45
520
NA
Clothing
(
Laundered
 
1%
transfer)
690
adults
and
children
2,600
NA
Clothing
(
Fabric
spray
 
5%
transfer)
1
12
6
average
Child
playing
on
decks/
play
sets
3
max
360
NA
Swimming
NA
Ranges
from
330
to
4,000
for
adults
and
children
NA
Adult
11
(
24­
hrs)
Humidifiers
NA
NA
Child
5
(
24­
hrs)
NA
=
not
assessed
because
negligible
exposure
is
assumed
by
that
route
for
the
exposure
scenario
of
concern.
Page
20
of
52
6.0
AGGREGATE
RISK
ASSESSMENT
AND
RISK
CHARACTERIZATION
In
order
for
a
pesticide
registration
to
continue,
it
must
be
shown
that
the
use
does
not
result
in
"
unreasonable
adverse
effects
on
the
environment".
Section
2
(
bb)
of
FIFRA
defines
this
term
to
include
"
a
human
dietary
risk
from
residues
that
result
from
a
use
of
a
pesticide
in
or
on
any
food
inconsistent
with
standard
under
section
408..."
of
FFDCA.
Consequently,
even
though
no
pesticide
tolerances
have
been
established
for
DDAC,
the
standards
of
FQPA
must
still
be
met,
including
"
that
there
is
reasonable
certainty
that
no
harm
will
result
from
aggregate
exposure
to
pesticide
chemical
residue,
including
all
anticipated
dietary
exposures
and
other
exposures
for
which
there
are
reliable
information."
Aggregate
exposure
is
the
total
exposure
to
a
single
chemical
(
or
its
residues)
that
may
occur
from
dietary
(
i.
e.,
food
and
drinking
water),
residential,
and
other
non­
occupational
sources,
and
from
all
known
or
plausible
exposure
routes
(
oral,
dermal,
and
inhalation).
Aggregate
risk
assessment
were
conducted
for
short­
term
(
1­
30
days),
intermediate­
term
(
1­
6
months)
and
chronic
(
several
months
to
lifetime)
exposures.

In
performing
aggregate
exposure
and
risk
assessments,
the
Office
of
Pesticide
Programs
has
published
guidance
outlining
the
necessary
steps
to
perform
such
assessments
(
General
Principles
for
Performing
Aggregate
Exposure
and
Risk
Assessments,
November
28,
2001;
available
at
http://
www.
epa.
gov/
pesticides/
trac/
science/
aggregate.
pdf).
Steps
for
deciding
whether
to
perform
aggregate
exposure
and
risk
assessments
are
listed,
which
include:
identification
of
toxicological
endpoints
for
each
exposure
route
and
duration;
identification
of
potential
exposures
for
each
pathway
(
food,
water,
and/
or
residential);
reconciliation
of
durations
and
pathways
of
exposure
with
durations
and
pathways
of
health
effects;
determination
of
which
possible
residential
exposure
scenarios
are
likely
to
occur
together
within
a
given
time
frame;
determination
of
magnitude
and
duration
of
exposure
for
all
exposure
combinations;
determination
of
the
appropriate
technique
(
deterministic
or
probabilistic)
for
exposure
assessment;
and
determination
of
the
appropriate
risk
metric
to
estimate
aggregate
risk.

6.1
Acute
and
Chronic
Aggregate
Risks
The
acute
and
chronic
aggregate
risk
assessment
includes
dietary
and
drinking
water
exposures.
No
drinking
water
exposures
were
identified
for
DDAC.
Acute
and
chronic
dietary
risk
estimates
from
direct
and
indirect
food
uses
are
presented
in
Section
5.2.
Table
6­
1
presents
a
summary
of
these
exposures,
including
the
aggregate
indirect
and
direct
dietary
exposure
(
all
direct
and
indirect
food
contact
exposures).
Based
on
the
results
of
the
acute
and
chronic
aggregate
assessment,
the
%
aPAD
and
%
cPAD
for
adults
and
children
are
3.8%
and
14%,
respectively.
Therefore,
the
acute
and
chronic
dietary
risks
are
not
of
concern
(
i.
e.,
less
then
100
%
of
aPAD
and
cPAD).
Page
21
of
52
Table
6­
1.
DDAC
Acute
and
Chronic
Aggregate
Exposures
and
Risks
(
aPAD
and
cPAD)

Acute
and
Chronic
Dietary
Exposures
(
mg/
kg/
day)

Exposure
Routes
Indirect
Dietary
Exposuresa
Direct
Food
Contact
Dietary
Exposuresa
Drinking
Water
Exposures
Aggregate
Dietary
Exposuresb
%
aPAD
and
cPAD
(
MOE)

Adults
Oral
Ingestion
0.0033
0.00046
None
0.00376
3.8
(
2,700)
Children
Oral
Ingestion
0.013
0.0012
None
0.0142
14
(
700)
a
Dietary
(
indirect
+
direct
food
contact)
exposures
are
presented
in
Tables
5.1
and
5.2.
b
Aggregate
Dietary
Exposures
=
indirect
dietary
+
direct
food
contact
+
drinking
water
exposures.
c
%
aPAD
and
cPAD
(
percent
acute
or
chronic
population
adjusted
dose)
=
aggregate
exposures
/
(
a
PAD
or
cPAD)
x
100.
Where
aPAD
and
cPAD
=
NOAEL
10
mg/
kg/
day
/
100x
uncertainty
factor
=
0.1
mg/
kg/
day.
MOE
=
NOAEL
of
10
mg/
kg/
day
/
aggregate
dietary
exposures
mg/
kg/
day.

6.2
Short­
and
Intermediate­
Term
Aggregate
Exposures
and
Risks
Short­
and
intermediate­
term
aggregate
exposures
and
risks
were
assessed
for
adults
and
children
that
could
be
exposed
to
DDAC
residues
from
the
use
of
products
in
nonoccupational
environments.
The
short­
and
intermediate­
term
aggregate
risks
account
for
pesticide
exposures
from
the
diet,
drinking
water,
and
residential
uses.
The
following
list
summarizes
all
of
the
potential
sources
of
DDAC
exposures
for
adults
and
children.

Adult
DDAC
exposure
sources:


handling
of
cleaning
products
containing
DDAC
as
an
active
ingredient
during
wiping,
mopping,
and
spraying
activities;


applying
products
containing
DDAC
to
lawns/
ornamentals;


applying
DDAC
as
an
air
deodorizer
using
an
aerosol
spray;


applying
DDAC
to
carpets
using
a
low
pressure
sprayer;


applying
DDAC
to
swimming
pools
via
open
pouring;


applying
DDAC
to
humidifiers
via
open
pouring;


contacting
pressure
treated
wood;


wearing
treated
clothing;


use
of
DDAC
in
humidifiers;
and

eating
food
having
DDAC
residues
from
indirect
or
direct
food
contact.

Child
DDAC
exposure
sources:


post­
application
exposures
to
cleaning
product
residues
containing
DDAC
that
are
used
on
hard
surfaces
(
e.
g,
floors/
carpets);


breathing
air
treated
with
a
humidifier;


swimming
in
treated
pools;


contacting
pressure
treated
wood;


wearing
treated
clothing/
diapers;


eating
food
having
DDAC
residues
from
indirect
or
direct
food
contact.

The
use
patterns
of
the
products
and
probability
of
co­
occurrence
must
be
considered
Page
22
of
52
when
selecting
scenarios
for
incorporation
in
the
aggregate
assessment.
Table
6­
2
summarizes
the
scenarios
included
in
the
short­
and
intermediate­
term
aggregate
assessments.

Table
6­
2.
Exposure
Scenarios
Included
in
the
Aggregate
Assessments
Short­
term
(
ST)
Aggregate
Intermediate­
Term
(
IT)
Aggregate
Adults

chronic
dietary
(
direct
and
indirect)


handling
cleaning
products
(
wipe
+
trigger
pump
spray)


wearing
treated
clothing

humidifier
Oral:
ST
and
IT
endpoints
are
the
same
for
both
durations.

Dermal:
ST
endpoint
only.

Inhalation:
All
durations
same
endpoint.

Children

chronic
dietary
 
(
direct
and
indirect)


post­
application
to
cleaning
product
on
carpets
(
dermal
and
oral)


wearing
treated
clothing

humidifier
Oral:
ST
and
IT
endpoints
are
the
same
for
both
durations.

Dermal:
ST
endpoint
only.

Inhalation:
All
durations
same
endpoint.

The
chronic
dietary
exposures
were
used
in
both
the
short­
and
intermediate­
term
aggregate
assessment
because
chronic
dietary
exposures
occur
nearly
every
day
(
as
opposed
to
acute
dietary
exposures
occurring
on
a
one­
time
basis).
Therefore,
short­
or
intermediateterm
non­
dietary
exposures
have
a
much
higher
probability
to
co­
occur
with
the
chronic
dietary
intake.

Cleaning
activities
in
a
residential
setting
occur
on
a
short­
term
basis.
However,
the
DDAC­
containing
cleaning
products
are
also
labeled
for
use
in
institutional
settings
such
as
day­
care
facilities
where
cleaning
activities
can
occur
on
an
intermediate­
term
basis.
Therefore,
children
could
have
exposure
to
cleaning
product
residues
on
a
more
continuous
basis
in
a
day
care
facility,
thus,
these
post­
application
scenarios
were
included
in
the
intermediate­
term
aggregate
assessment.

The
DDAC
toxicity
endpoints
for
the
chronic
dietary
and
the
intermediate­
term
incidental
oral
are
based
on
the
same
toxic
effect
(
and
same
study),
and
therefore,
these
two
dietary
routes
of
exposure
are
aggregated.
On
the
other
hand,
the
dermal
and
inhalation
routes
of
exposure
are
based
on
different
toxic
effects,
and
therefore,
these
two
routes
of
exposure
are
not
aggregated.
However,
the
dermal
route
of
exposure
is
aggregated
among
those
dermal
exposure
scenarios
that
are
believed
to
co­
occur.
In
addition,
the
inhalation
route
of
exposure
is
also
aggregated
among
the
inhalation
exposure
scenarios
that
are
believed
to
co­
occur.
Aggregate
risks
were
calculated
using
the
total
MOE
approach
outlined
in
OPP
guidance
for
aggregate
risk
assessment
(
August
1,
1999,
Updated
"
Interim
Guidance
for
Incorporating
Drinking
Water
Exposure
into
Aggregate
Risk
Assessments").
Table
6­
3
presents
a
summary
of
the
short­
term
aggregate
risks
(
i.
e.,
MOEs).
Only
the
short­
term
aggregate
is
presented
because
the
endpoints
for
incidental
oral
as
well
as
inhalation
are
identical
for
the
short­
and
intermediate­
term
durations.
Only
a
short­
term
dermal
endpoint
was
identified
(
i.
e.,
no
intermediate­
and/
or
long­
term
dermal
endpoints
were
identified).

The
aggregate
risks
are
not
of
concern
for
adults
for
any
of
the
three
routes
of
exposure
except
for
the
dermal
exposure.
The
adult
dermal
MOE
for
the
cleaning
products
indicate
that
the
MOEs
are
less
than
the
target
MOE
of
100.
For
children,
the
oral
aggregate
Page
23
of
52
(
dietary
and
intermediate­
term
ingestion
for
children
at
day
care
centers)
is
270.
The
children
aggregate
MOE
for
the
dermal
route
is
42.
No
children
aggregate
inhalation
scenarios
were
determined
to
co­
occur.
It
is
important
to
note,
however,
that
some
of
the
individual
risks
for
scenarios
not
included
in
the
aggregate
are
of
concern
by
themselves
(
e.
g.,
the
humidifier
use
and
the
fabric
spray
for
clothing).

Table
6­
3.
Short­
and
Intermediate­
term
Aggregate
Risk
(
MOE)
Assessment
for
DDAC
Exposure
Routes
Chronic
Dietary
MOE
Cleaning
Product
MOEs
(
Adult
Applicators
&
Children
Playing)
Humidifier
MOE
Wearing
Treated
Clothing
MOE
Route­
Specific
Aggregate
MOE
Adults
Oral
Ingestion
2,700
NA
NA
NA
2,700
Dermal
(
1
to
10%
ai)
29
(
mop)
11
(
wipe)
110
(
spray)
7
Dermal
(>
10%
ai)
NA
3
(
mop)
1
(
wipe)
12
(
spray)
NA
690
1
Inhalation
NA
13,000
(
mop)
3,400
(
wipe)
96,000
(
spray)
Not
included,
risk
of
concern
NA
2,600
Children
Oral
Ingestion
700
520
(
IT
hand­
to­
mouth
carpets)
NA
2,600
(
IT
Laundered)
270
Dermal
NA
45
(
playing
on
carpets,
5%
residue
transfer)
NA
690
(
Laundered)
42
Inhalation
NA
NA
Not
included,
risk
of
concern
NA
No
cooccurrence
Aggregate
MOE
=
1/((
1/
MOEsame
route)
+
(
1/
MOE
same
route)
+
etc)

7.0
CUMULATIVE
EXPOSURE
AND
RISK
Another
standard
of
section
408
of
the
FFDCA
which
must
be
considered
in
making
an
unreasonable
adverse
effect
determination
is
that
the
Agency
considers
"
available
information"
concerning
the
cumulative
effects
of
a
particular
pesticide's
residues
and
"
other
substances
that
have
a
common
mechanism
of
toxicity."

Unlike
other
pesticides
for
which
EPA
has
followed
a
cumulative
risk
approach
based
on
a
common
mechanism
of
toxicity,
EPA
has
not
made
a
common
mechanism
of
toxicity
finding
as
to
DDAC
and
any
other
substances
and
DDAC
does
not
appear
to
produce
a
toxic
metabolite
produced
by
other
substances.
For
the
purposes
of
this
tolerance
action,
therefore,
EPA
has
not
assumed
that
DDACs
has
a
common
mechanism
of
toxicity
with
other
substances.
For
information
regarding
EPA's
efforts
to
determine
which
chemicals
have
a
common
mechanism
of
toxicity
and
to
evaluate
the
cumulative
effects
of
such
chemicals,
see
the
policy
statements
released
by
EPA's
Office
of
Pesticide
Programs
concerning
common
mechanism
determinations
and
procedures
for
cumulating
effects
from
substances
found
to
have
a
common
mechanism
on
EPA's
website
at
http://
www.
epa.
gov/
pesticides/
cumulative/.
Page
24
of
52
8.0
OCCUPATIONAL
EXPOSURE
ASSESSMENT
Potential
occupational
handler
exposure
can
occur
in
various
use
sites,
which
include:
agricultural
premises,
industrial
processes
and
water
systems,
food
handling
premises,
commercial/
institutional/
industrial
premises,
medical
premises,
swimming
pools,
and
aquatic
areas.
Additionally,
occupational
exposure
can
occur
during
the
preservation
of
wood.
For
the
preservation
of
wood,
the
procedure
for
treatment
can
occur
in
different
ways,
such
that
multiple
worker
functions
were
analyzed.
Due
to
the
complexity
of
the
wood
preservative
analysis,
the
results
for
handler
and
post­
application
exposures
are
presented
separately
in
Section
8.3.

8.1
Occupational
Handler
Exposures
DDAC
dermal
irritation
exposures
and
risks
were
not
estimated
for
occupational
handler
exposures.
Instead,
dermal
irritation
exposures
and
risks
will
be
mitigated
using
default
personal
protective
equipment
requirements
based
on
the
toxicity
of
the
end­
use
product.
To
minimize
dermal
exposures,
the
minimum
PPE
required
for
mixers,
loaders,
and
others
exposed
to
end­
use
products
containing
concentrations
of
DDAC
that
result
in
classification
of
category
I,
II,
or
III
for
skin
irritation
potential
will
be
long­
sleeve
shirt,
long
pants,
shoes,
socks,
chemical­
resistant
gloves,
and
chemical­
resistant
apron.
Once
diluted,
if
the
concentration
of
DDAC
in
the
diluted
solution
would
result
in
classification
of
toxicity
category
IV
for
skin
irritation
potential,
then
the
chemical­
resistant
gloves
and
chemicalresistant
apron
can
be
eliminated
for
applicators
and
others
exposed
to
the
dilute.
Note
that
chemical­
resistant
eyewear
will
be
required
if
the
end­
use
product
is
classified
as
category
I
or
II
for
eye
irritation
potential.

Inhalation
exposures
and
risks
were
presented
based
on
the
oral
toxicity
endpoint
(
i.
e.,
route­
specific
inhalation
study
not
available).
The
surrogate
unit
exposure
values
were
taken
from
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999b:
DP
Barcode
D247642)
or
from
the
Pesticide
Handler
Exposure
Database
(
USEPA,
1998).
The
specific
inhalation
unit
exposures
and
quantity
of
DDAC
handled
are
provided
in
the
Occupational
and
Residential
Exposure
chapter
for
DDAC.

The
inhalation
MOEs
were
calculated
for
the
short­
and
intermediate­
term
durations
for
occupational
handlers
using
the
oral
endpoint.

Risk
Characterization
The
resulting
inhalation
exposures
and
MOEs
for
the
representative
occupational
handler
scenarios
are
presented
in
Table
8.1.
The
calculated
MOEs
were
above
the
target
MOE
of
100
for
all
scenarios.
Page
25
of
52
Table
8.1
Short­
,
Intermediate­
and
Long­
Term
Inhalation
Risks
Associated
with
Occupational
Handlers
Exposure
Scenario
Method
of
Application
Inhalation
Unit
Exposure
(
mg/
lb
a.
i.)
Application
Rate
Quantity
Handled/
Treated
per
day
Inhalation
Absorbed
Daily
Dose
(
mg/
kg/
day)
a
Inhalation
MOEb,
c
(
Target
MOE
=
100)

Agricultural
Premises
and
Equipment
(
Use
Site
Category
I)

Mop
2.38
0.0094
lb
ai/
gal
2
gallons
0.0075
13,000
High
pressure/
high
volume
spray
0.12
0.0094
lb
ai/
gal
40
gallons
0.00075
13,000
Low
pressure
hand
wand
0.681
0.0094
lb
ai/
gal
40
gallons
0.0043
2,300
Trigger
pump
sprayer
1.3
0.0094
lb
ai/
gal
0.26
gallons
0.000052
190,000
Application
to
hard
surfaces,
equipment,
and
vehicles
Wipe
67.3
0.0094
lb
ai/
gal
0.26
gallons
0.0027
3,600
Fogging
(
mix/
load
only)
Liquid
pour
1.89
1.88E­
05
lb/
ft3
150,000
ft3
0.089
110
Food
Handling/
Storage
Establishments
Premises
And
Equipment
(
Use
Site
Category
II)

Low
pressure
hand
wand
0.681
0.0200
lb
ai/
gal
2
gallons
0.00045
22,000
Mop
2.38
0.0200
lb
ai/
gal
2
gallons
0.0016
6,300
Wipe
67.3
0.0200
lb
ai/
gal
0.26
gallons
0.0058
1,700
Trigger
pump
sprayer
1.3
0.0200
lb
ai/
gal
0.26
gallons
0.00011
89,000
Application
to
indoor
hard
surfaces
Immersion,
Flooding,
Circulation
1.89
0.00196
lb
ai/
gal
2
gallons
0.00012
81,000
Commercial,
Institutional
and
Industrial
Premises
and
Equipment
(
Use
Site
Category
III
)

Low
pressure
hand
wand
0.681
0.0200
lb
ai/
gal
2
gallons
0.00045
22,000
Mop
2.38
0.0200
lb
ai/
gal
2
gallons
0.0016
6,300
Wipe
67.3
0.0200
lb
ai/
gal
0.26
gallons
0.0058
1,700
Trigger
pump
sprayer
1.3
0.0200
lb
ai/
gal
0.26
gallons
0.00011
89,000
Application
to
indoor
hard
surfaces
Liquid
pour
1.89
0.0043
lb
ai/
gal
2
gallons
0.00027
37,000
Application
to
carpets
Liquid
pour
0.00346
0.102
lb
ai/
gal
32
gallons
0.00019
53,000
Medical
Premises
and
Equipment
(
Use
Site
Category
V)

Application
to
hard
surfaces
Mop
2.38
0.0200
lb
ai/
gal
45
gallons
0.036
280
Industrial
Processes
and
Water
Systems
(
Use
Site
Category
VIII)

Liquid
pour
0.45
4.17
lb
ai/
gal
product
2.5
gallons
0.078
130
Initial
Dose
(
ST):
1.50E­
03lb
ai/
gal
water
20,000
gallons
0.0022
ST
=
4,600
Small
process
water
systems:
Recirculating
cooling
tower
Metering
pump
0.00432
Maintenance
Dose
(
IT):
1.50E­
04lb
ai/
gal
water
20,000
gallons
0.00022
IT
=
46,000
5.6
gallons
0.00048
ST
=
21,000
Oil
field
operations
­
drilling
mud
and
packing
fluids
Liquid
pour
0.00346
1.50
lb
ai/
gal
product
2.8
gallons
0.00024
IT
=
41,000
Swimming
Pools
(
Use
Site
Category
X)
d
Application
to
swimming
pools
Liquid
pour
0.00346
Heavy
algae
Dose
(
ST):

0.000017
lb
ai/
gal
200,000
gallons
0.0002
ST=
15,000
Page
26
of
52
Table
8.1
Short­
,
Intermediate­
and
Long­
Term
Inhalation
Risks
Associated
with
Occupational
Handlers
Exposure
Scenario
Method
of
Application
Inhalation
Unit
Exposure
(
mg/
lb
a.
i.)
Application
Rate
Quantity
Handled/
Treated
per
day
Inhalation
Absorbed
Daily
Dose
(
mg/
kg/
day)
a
Inhalation
MOEb,
c
(
Target
MOE
=
100)

Maintenance
Dose
(
IT/
LT):

0.00000417
lb
ai/
gal
200,000
gallons
0.000048
IT=
210,000
ST
=
short­
term,
IT
=
intermediate­
term,
LT
=
long­
term,
N/
A=
No
data
available
a
Absorbed
Daily
dose
(
mg/
kg/
day)
=
[
unit
exposure
(
mg/
lb
a.
i.)
x
absorption
factor
(
1.0
for
inhalation)
x
application
rate
x
quantity
treated
/
Body
weight
(
60
kg
for
inhalation).
b
MOE
=
NOAEL
(
mg/
kg/
day)
/
Absorbed
Daily
Dose
[
Where
NOAEL
=
10
mg/
kg/
day
for
all
inhalation
exposure
durations].
Target
MOE
=
100.
c
The
MOEs
refer
to
short­
term
and
intermediate­
term
duration
unless
indicated
otherwise.
d.
The
swimming
pool
scenario
also
represents
the
decorative
pond/
fountain
scenario
in
the
aquatic
area
use
site
category
because
the
application
rates
are
very
similar.

8.2
Occupational
Post­
application
Exposures
Except
for
the
post­
application
scenarios
assessed
for
fogging
wood
preservatives
(
Section
8.3),
occupational
post­
application
dermal
and
inhalation
exposures
are
assumed
to
be
negligible.

Fogging
(
Food
Processing
Plant
and
Hatchery)
Post­
application
inhalation
exposures
only
were
assessed
for
entry
into
a
building
(
hatchery
and
food
processing
plant)
after
a
fogging
application,
because
dermal
post
application
is
presumed
to
be
negligible.
The
inhalation
exposure
assessment
was
conducted
using
the
Multi­
Chamber
Concentration
and
Exposure
Model
(
MCCEM
v1.2).
MCCEM
estimates
average
and
peak
indoor
air
concentrations
of
chemicals
released
from
products
or
materials
in
houses,
apartments,
townhouses,
or
other
residences.
Although
the
data
libraries
contained
in
MCCEM
are
limited
to
residential
settings,
the
model
can
be
used
to
assess
other
indoor
environments.
MCCEM
has
the
capability
to
estimate
inhalation
exposures
to
chemicals,
calculated
as
single
day
doses,
chronic
average
daily
doses,
or
lifetime
average
daily
doses.
(
All
dose
estimates
are
potential
doses;
they
do
not
account
for
actual
absorption
into
the
body.)

The
product,
EPA
Reg
#
10324­
80
(
3.3%
ai)
with
a
maximum
application
rate
of
0.0065
lb
ai/
gal,
was
assessed
for
fogging
use
in
a
food
processing
plant.
The
label
states
to
fog
one
quart
of
the
diluted
product
per
1,000
cubic
feet.
All
labels
which
can
be
used
for
fogging
in
food
processing
areas
indicate
that
all
personnel
must
vacate
the
room
during
fogging
and
for
a
minimum
of
2
hours
after
fogging.
Therefore,
exposure
was
calculated
for
a
person
entering
the
food
processing
plant
2
hours
after
all
the
applied
fogger
has
been
deployed.

The
MOE
for
fogging
in
the
food
processing
plant
(
2­
hr
re­
entry
interval)
was
below
the
target
MOE
of
100.
For
fogging
in
hatcheries,
the
8­
hr
MOE
is
120
immediately
after
fogging
and
6,600
after
a
2
hour
REI.
The
risks
of
concern
for
the
food
processing
plant
are
attributed
to
the
low
air
changes
per
hour
assumed
(
i.
e.,
0.18
ACH
as
a
default
parameter
in
MCCEM
to
represent
low
air
flow)
in
the
assessment.
This
assessment
can
be
refined
with
additional
information
on
air
flows
in
food
processing
plants.
For
the
poultry
barn,
ventilation
Page
27
of
52
rate
was
obtained
from
Jacobson
(
2005).
The
assessment
for
food
processing
plants
could
be
refined
if
a
more
accurate
ventilation
rate
could
be
obtained.
Additional
suggested
label
language
to
assure
proper
ventilation
includes:

­­
ten
air
exchanges,
or
­­
2
hours
of
mechanical
ventilation
(
i.
e.,
fans),
or
­­
4
hours
of
passive
ventilation
(
i.
e.,
windows,
vents),
or
­­
11
hours
of
no
ventilation
followed
by
1
hour
of
mechanical
ventilation,
or
­­
11
hours
of
no
ventilation
followed
by
2
hours
of
passive
ventilation,
or
­­
24
hours
of
no
ventilation
8.3
Wood
Preservation
DDAC
is
used
in
products
that
are
intended
to
preserve
wood
through
both
nonpressure
treatment
methods
and
pressure
treatment
methods.
Section
8.3.1
presents
the
exposure
analysis
for
the
handler
and
post­
application
scenarios
for
non­
pressure
treatment
scenarios
and
Section
8.3.2
presents
the
exposure
analysis
for
the
handler
and
post­
application
scenarios
for
pressure
treatment
scenarios.

Dermal
irritation
exposures
from
post­
application
activities
in
the
wood
preservation
treatment
facility
will
be
mitigated
using
default
personal
protective
equipment
requirements
based
on
the
toxicity
of
the
end­
use
product.
Therefore,
only
inhalation
exposures
and
risks
are
presented.

8.3.1
Non­
Pressure
Treatment
Scenarios
(
Handler
and
Post­
application)

The
proprietary
study,
"
Measurement
and
Assessment
of
Dermal
and
Inhalation
Exposures
to
Didecyl
Dimethyl
Ammonium
Chloride
(
DDAC)
Used
in
the
Protection
of
Cut
Lumber
(
Phase
III)"
(
Bestari
et
al.,
1999,
MRID
455243­
04)
identified
various
worker
functions/
positions
for
individuals
that
handle
DDAC­
containing
wood
preservatives
for
nonpressure
treatment
application
methods
and
for
individuals
that
could
then
come
into
contact
with
the
preserved
wood.
The
worker
functions/
positions
identified
in
the
DDAC
study
are
presented
below.

Handler:
 
Blender/
spray
operators
are
workers
that
add
the
wood
preservative
into
a
blender/
sprayer
system
for
composite
wood
via
closed­
liquid
pumping.
 
Diptank
Operators
can
be
in
reference
to
wood
being
lowered
into
the
treating
solution
through
an
automated
process
(
i.
e.,
elevator
diptank,
forklift
diptank).
This
scenario
can
also
occur
in
a
smaller
scale
treatment
facility
in
which
the
worker
can
manually
dip
the
wood
into
the
treatment
solution.
 
Chemical
operators
for
a
spray
box
system
consist
of
chemical
operators,
chemical
assistants,
chemical
supervisors,
and
chemical
captains.
These
individuals
maintain
a
chemical
supply
balance
along
with
flushing
and
cleaning
spray
nozzles.
Page
28
of
52
Post­
application:
 
Graders,
positioned
right
after
the
spray
box,
grade
dry
lumber
by
hand
(
i.
e.
detect
faults).
In
the
DDAC
study,
graders
graded
wet
lumber;
therefore,
the
exposures
to
graders
using
DDAC
are
worst­
case
scenarios.
 
Millwrights
repair
all
conveyer
chains
and
general
up­
keep
of
the
mill.
 
Clean­
up
crews
perform
general
cleaning
duties
at
the
mill.
 
Trim
saw
operators
operate
the
hula
trim
saw
and
consist
of
operators
and
strappers.
In
the
DDAC
study,
hula
trim
saw
operators
handled
dry
lumber.
 
Construction
workers
install
treated
plywood,
oriented
strand
board,
medium
density
fiberboard,
and
others.

The
blender/
spray
operator
position
was
assessed
using
CMA
unit
exposure
data
and
the
remaining
handler
and
post­
application
positions
were
assessed
using
data
from
the
DDAC
study
(
Bestari
et
al.,
1999).

Blender/
Spray
Operators
Table
8.2
provides
the
inhalation
doses
and
MOEs
for
the
workers
adding
the
preservative
to
the
wood
slurry.
The
inhalation
MOE
is
above
the
target
MOE
of
100
for
short­,
intermediate­,
and
long­
term
inhalation
exposures
(
MOE
=
280).

Table
8.2.
Short­,
Intermediate­,
and
Long­
Term
Inhalation
Exposures
and
MOEs
for
Blender/
Spray
Operator
Exposure
Scenario
Inhalation
Unit
Exposurea
(
mg/
lb
ai)
Application
Rate
(%
ai
in
solution/

day)
Wood
Slurry
Treatedb
(
lb/
day)
Daily
Dosec
(
mg/
kg/
day)
ST/
IT/
LT
MOEd
(
Target
MOE
=
100)
Occupational
Handler
Blender/
spray
operator
0.000403
3
178,000
0.036
280
ST
=
Short­
term
duration;
IT
=
Intermediate­
term
duration;
and
LT
=
long­
term.
a.
Inhalation
unit
exposure:
Baseline.
b.
Wood
slurry
treated
=
(
8
batches/
day
x
7,000
gallons/
batch
x
0.003785
m3/
gallon
x
380
kg/
m3
x
2.2
lb/
kg)
c.
Daily
Dose
=
unit
exposure
(
mg/
lb
ai)
x
App
Rate
(%
ai/
day)
x
Quantity
treated
(
lb/
day)
x
absorption
factor
(
100%
for
inhalation)
/
BW
(
60
kg)
d.
MOE
=
NOAEL
(
mg/
kg/
day)/
Daily
dose
[
Where
ST/
IT/
LT
NOAEL
=
10
mg/
kg/
day
for
inhalation.
Target
MOE
=
100.

Chemical
Operators,
Graders,
Millwrights,
Clean­
up
Crews,
and
Trim
Saw
Operators
Table
8.3
provides
the
short­,
intermediate­,
and
long­
term
inhalation
doses
and
MOEs
for
chemical
operators,
graders,
millwrights,
clean­
up
crews,
and
trim
saw
operators.
The
inhalation
MOEs
are
above
the
target
MOE
of
100
for
all
worker
functions.
Any
dermal
irritation
exposures
from
post­
application
activities
will
be
mitigated
using
default
personal
protective
equipment
requirements
based
on
the
toxicity
of
the
end­
use
product.

Table
8.3.
Short­,
Intermediate,
and
Long­
Term
Inhalation
Exposures
and
MOEs
for
Wood
Preservative
Chemical
Operators,
Graders,
Trim
Saw
Operators,
and
Clean­
Up
Crews
(
Handler
and
Post­
application
Activities)

Exposure
Scenarioa
(
number
of
volunteers)
Inhalation
UEb
(
mg/
day)
Conversion
Ratioc
Daily
Dosed
(
mg/
kg/
day)
MOEe
(
Target
MOE
=
100)
Page
29
of
52
Table
8.3.
Short­,
Intermediate,
and
Long­
Term
Inhalation
Exposures
and
MOEs
for
Wood
Preservative
Chemical
Operators,
Graders,
Trim
Saw
Operators,
and
Clean­
Up
Crews
(
Handler
and
Post­
application
Activities)

Exposure
Scenarioa
(
number
of
volunteers)
Inhalation
UEb
(
mg/
day)
Conversion
Ratioc
Daily
Dosed
(
mg/
kg/
day)
MOEe
(
Target
MOE
=
100)

Occupational
Handlers
Chemical
Operator
(
n=
11)
0.0281
NA
0.000468
21,000
Occupational
Post­
Application
Grader
(
n=
13)
0.0295
NA
0.000491
20,000
Trim
Saw
(
n=
2)
0.061
NA
0.00101
9,900
Millwright
(
n=
3)
0.057
NA
0.00095
11,000
Clean­
Up
(
n=
6)
0.60
NA
0.0101
990
ST
=
Short­
term
duration,
IT
=
Intermediate­
term
duration,
LT
=
Long­
term
duration
a.
The
exposure
scenario
represents
a
worker
wearing
short­
sleeved
shirts,
cotton
work
trousers,
and
cotton
glove
dosimeter
gloves
under
chemical
resistant
gloves.
Volunteers
were
grouped
according
to
tasks
they
conducted
at
the
mill.
b.
Inhalation
unit
exposures
are
from
Bestari
et.
al.
(
1999).
Refer
to
Table
E­
1
in
Appendix
E
for
the
calculation
of
the
inhalation
exposures.
Inhalation
exposure
(
mg/
day)
was
calculated
using
the
following
equation:
Air
concentration
(
µ
g/
m3)
x
Inhalation
rate
(
1.0
m3/
hr)
x
Sample
duration
(
8
hr/
day)
x
Unit
conversion
(
1
mg/
1000
µ
g).
The
inhalation
rate
is
from
USEPA,
1997.
c.
A
conversion
ratio
is
not
needed
because
the
maximum
%
active
ingredient
in
the
product
is
the
same
as
the
%
active
ingredient
in
the
DDAC
study.
d.
Daily
dose
(
mg/
kg/
day)
=
exposure
(
mg/
day)
x
absorption
factor
(
100%
for
inhalation)/
body
weight
(
60
kg).
e.
MOE
=
NOAEL
(
mg/
kg/
day)/
Daily
dose
[
Where
inhalation
NOAEL
=
10
mg/
kg/
day].
Target
MOE
=
100.

Diptank
Operators
Exposures
to
diptank
operators
were
also
assessed
using
the
data
from
the
DDAC
study
(
Bestari
et
al.,
1999).
The
diptank
scenario
assessment
was
conducted
differently
than
for
the
other
job
functions
because
the
concentration
of
DDAC
in
the
diptank
solution
was
provided.
The
exposure
data
for
diptank
operators
were
converted
into
A
unit
exposures
@

in
terms
of
mg
a.
i.
for
each
1%
of
concentration
of
the
product.
Table
8.4
provides
the
short­,
intermediate­
and
long­
term
inhalation
dose
and
MOEs
for
diptank
operators.
The
inhalation
MOE
is
above
the
target
MOE
of
100
and,
therefore,
is
not
of
concern.

Table
8.4.
Short­,
Intermediate­,
and
Long­
Term
Inhalation
Exposures
and
MOEs
for
Diptank
Operator
(
Handler
Activity)

Exposure
Scenarioa
(
number
of
replicates)
Inhalation
Unit
Exposureb
(
mg
DDAC/
1%
solution)
App
Rate
(%
a.
i.
in
solution/
day)
Daily
Dosec
(
mg/
kg/
day)
MOEd
Occupational
Handler
Dipping,
with
gloves
(
n=
7)
0.046
3
0.0023
4,300
a
The
exposure
scenario
represents
a
worker
not
wearing
a
respirator.
b
Inhalation
unit
exposures
are
from
DDAC
study
(
MRID
455243­
04).
Refer
to
Table
E­
2
in
Appendix
E
for
inhalation
unit
exposure
calculations.
Inhalation
exposure
(
mg)
was
calculated
using
the
following
equation:
Air
concentration
(
mg/
m3)
x
Inhalation
rate
(
1.0
m3/
hr)
x
Sample
Duration
(
8
hr).
The
inhalation
rate
is
from
USEPA,
1997.
c
Daily
dose
(
mg/
kg/
day)
=
unit
exposure
(
mg/
1%
ai
solution)
x
percent
active
ingredient
in
solution
(
3%
ai)
x
absorption
factor
(
100%
for
inhalation)
/
body
weight
(
60
kg).
Page
30
of
52
d
MOE
=
NOAEL
(
mg/
kg/
day)
/
Daily
dose
[
Where
inhalation
NOAEL
=
10
mg/
kg/
day.
Target
MOE
=
100.

Construction
workers
Potential
risks
resulting
from
construction
worker
dermal
contact
with
DDAC­
treated
wood
are
assessed
in
the
same
manner
as
potential
risks
resulting
from
children's
dermal
contact
with
DDAC­
treated
play
sets
and
decks.
The
risks
were
calculated
using
average
worker
residue
data
for
hands
available
in
the
DDAC
exposure
study.
Hand
residue
data
from
the
end
stacker,
stickman,
and
tallyman
workers
were
used
because
of
the
possibility
of
the
contact
with
dry
treated
wood.
The
maximum
and
average
values
of
these
data
(
3.0
and1.4
:
g/
cm2,
respectively)
were
assumed
to
be
the
dermal
skin
irritation
exposure.
The
dermal
MOE
are
less
than
or
equal
to1
for
maximum
and
average
hand
residues.
A
wood
wipe
study
is
needed
to
refine
the
risk
estimates.

8.3.2
Pressure
Treatment
Scenarios
(
Handler
and
Post­
Application)

DDAC
may
be
used
to
treat
wood
and
wood
products
using
pressurized
application
methods
such
as
double
vacuum.
According
to
the
product
labels,
the
maximum
retention
rate
is
0.6
lb/
ft3.
An
application
rate
was
not
provided
on
the
product
labels;
therefore,
an
application
rate
of
3%
ai
solution
was
used
in
this
assessment,
based
on
the
master
label.
DDAC­
specific
exposure
data
are
not
available
for
assessment
of
pressure
treatment
exposure.
Therefore,
the
assessment
relies
on
surrogate
chromated
copper
arsenate
(
CCA)
data
(
ACC,
2002b)
and
was
based
on
the
approach
used
in
a
previous
exposure
assessment
(
USEPA,
2003b).

The
estimated
inhalation
exposures
and
risks
for
DDAC
are
presented
in
Table
8.5.
The
calculated
inhalation
MOEs
are
above
the
target
MOE
of
100
for
all
scenarios.

Table
8.5.
Short­,
Intermediate­,
and
Long­
Term
Inhalation
Exposures
and
MOEs
for
Pressure
Treatment
Handler
and
Post­
application
Scenarios
Exposure
Scenario
Inhalation
Unit
Exposurea
(
µ
g
As/
ppm)
Application
Rate
(%
ai
solution)
Absorbed
Daily
Dosesb
(
mg/
kg/
day)
Inhalation
MOEsc
(
Target
MOE
=
100)
Occupational
Handler
Treatment
Operator
(
TO)
0.00257
3
0.0013
7,800
Treatment
Assistant
(
TA)
0.000802
3
0.00040
25,000
Occupational
Post­
application
All
(
Tram
setter,
stacker
operator,
loader
operator,
supervisor,
test
borer,
and
tallyman)
0.00160
3
0.00080
13,000
a.
Unit
exposure
values
taken
from
CCA
study
and
are
shown
in
Table
6.11.
b.
Absorbed
Daily
Dose
(
mg/
kg/
day)
=
Unit
Exposure
(
µ
g
As/
ppm)
x
[%
DDAC
in
solution
(
3)
x
10,000
(
parts
per
million
conversion)]
x
(
0.001
mg/
µ
g)
x
absorption
factor
(
100%
for
inhalation)
/
Body
weight
(
60
kg).
c.
MOE
=
NOAEL
(
mg/
kg/
day)
/
Daily
dose
[
Where
inhalation
NOAEL
=
10
mg/
kg/
day
for
all
durations.
Target
MOE
=
100.
Page
31
of
52
8.4
Data
Limitations/
Uncertainties
There
are
several
data
limitations
and
uncertainties
associated
with
the
occupational
handler
and
post­
application
exposure
assessments.
These
include:

 
Surrogate
dermal
and
inhalation
unit
exposure
values
were
taken
from
the
proprietary
Chemical
Manufacturers
Association
(
CMA)
antimicrobial
exposure
study
(
USEPA,
1999b:
DP
Barcode
D247642)
or
from
the
Pesticide
Handler
Exposure
Database
(
USEPA,
1998).
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.
 
Unit
exposures
are
not
available
for
some
of
the
specific
scenarios
that
are
prescribed
for
DDAC
including
open
loading
into
oil­
well/
field
environments
o
The
CMA
data
used
for
oil­
well
uses
are
based
on
open
pouring
of
a
material
preservative.
Although
these
data
are
only
represented
by
2
replicates
each,
the
exposure
values
are
similar
to
open
loading
of
pesticides
in
PHED.
Furthermore,
there
are
no
representative
unit
exposure
data
for
chemical
metering
into
secondary
recovery
oil
operations.
Since
the
volume
of
water
being
treated
in
secondary
recovery
operations
is
so
large,
the
available
CMA
data
can
not
be
reliably
extrapolated
because
they
are
based
on
activities
that
handle
much
lower
volumes
and
possibly
different
techniques.
Therefore,
it
was
assumed
that
if
the
open
pour
handling
activities
for
the
other
oil
well
operations
resulted
in
MOEs
that
are
not
of
concern,
then
the
MOEs
for
the
closed
system
chemical
metering
into
secondary
recovery
operations
would
also
be
not
of
concern.
The
Agency
requests
that
confirmatory
data
be
conducted
to
show
that
this
is
accurate.
 
For
the
wood
preservative
pressure
treatment
scenarios,
CCA
exposure
data
were
used
for
lack
of
DDAC­
specific
exposure
data.
Limitations
and
uncertainties
associated
with
the
use
of
these
data
include:
o
The
assumption
was
made
that
exposure
patterns
for
workers
at
treatment
facilities
using
CCA
and
DDAC
would
be
similar
to
exposure
patterns
for
workers
at
treatment
facilities
using
DDAC,
and
therefore
the
exposures
could
be
used
as
surrogate
data
for
workers
that
treat
wood
with
DDAC.
o
For
environmental
modeling,
it
was
assumed
that
the
leaching
process
from
the
DDAC
treated
wood
would
be
similar
to
that
of
CCA
and
DDAC.
However,
due
to
the
lack
of
real
data
for
DDAC
­
treated
wood,
it
is
not
possible
to
verify
this
assumption.
 
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
personal
communication
with
experts.
In
particular,
the
use
information
for
oil­
well
uses
and
cooling
water
tower
uses
are
based
on
personal
communication
with
biocide
manufacturers
for
these
types
of
uses.
The
individuals
contacted
have
experience
in
these
operations
and
their
estimates
are
believed
to
be
the
best
available
without
undertaking
a
statistical
survey
of
the
uses.
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
from
input
from
registrants.
Page
32
of
52
 
The
percent
active
ingredient
in
solution
for
the
pressure
treatment
of
lumber
needs
to
be
refined
by
the
registrant.
The
labels
only
provided
a
retention
rate.
For
this
assessment,
the
application
rate
on
the
master
label
was
used,
which
is
the
same
as
the
application
rate
for
non­
pressure
treatment
of
lumber.

9.0
INCIDENT
REPORTS
To
review
the
evidence
of
health
effects
in
humans
resulting
from
exposure
to
QAC
as
stated
in
the
PR
Notice
88­
1
(
February
26,
1988),
the
Agency
has
clustered
Quats
into
four
categories:

Group
I.
Alkyl
or
hydroxyalkyl
(
straight
chain)
substituted
quats;
Group
II
Non­
halogenated
benzyl
substituted
quats;
Group
III.
Di­
and
tri­
chlorobenzyl
substituted
quats;
and
Group
IV.
Quats
with
unusual
substituents
However
for
the
available
incident
information,
it
is
difficult
to
differentiate
the
specific
members
of
the
Quats
involved
in
each
incident.
Therefore,
all
the
Quats
are
discussed
together.

The
Agency
consulted
the
following
databases
for
poisoning
incident
data
for
DDAC:

(
1)
OPP
Incident
Data
System
(
IDS)
­
The
Incident
Data
System
of
The
Office
of
Pesticide
Programs
(
OPP)
of
the
Environmental
Protection
Agency
(
EPA)
contains
reports
of
incidents
from
various
sources,
including
registrants,
other
federal
and
state
health
and
environmental
agencies
and
individual
consumers,
submitted
to
OPP
since
1992.
Reports
submitted
to
the
Incident
Data
System
represent
anecdotal
reports
or
allegations
only,
unless
otherwise
stated.
Typically
no
conclusions
can
be
drawn
implicating
the
pesticide
as
a
cause
of
any
of
the
reported
health
effects.
Nevertheless,
sometimes
with
enough
cases
and/
or
enough
documentation
risk
mitigation
measures
may
be
suggested.
(
2)
California
Department
of
Pesticide
Regulation
(
1982­
2004)
­
California
has
collected
uniform
data
on
suspected
pesticide
poisonings
since
1982.
Physicians
are
required,
by
statute,
to
report
to
their
local
health
officer
all
occurrences
of
illness
suspected
of
being
related
to
exposure
to
pesticides.
The
majority
of
the
incidents
involve
workers.
Information
on
exposure
(
worker
activity),
type
of
illness
(
systemic,
eye,
skin,
eye/
skin
and
respiratory),
likelihood
of
a
causal
relationship,
and
number
of
days
off
work
and
in
the
hospital
are
provided.
(
3)
National
Pesticide
Telecommunications
Network
(
NPTN)
­
NPTN
is
a
toll­
free
information
service
supported
by
OPP.
A
ranking
of
the
top
200
active
ingredients
for
which
telephone
calls
were
received
during
calendar
years
1984­
1991,
inclusive,
has
been
prepared.
The
total
number
of
calls
was
tabulated
for
the
categories
human
incidents,
animal
incidents,
calls
for
information,
and
others
(
4)
Published
Incident
Reports
­
Some
incident
reports
associated
with
Quats
related
human
health
hazard
are
published
in
the
scientific
literature.

There
are
many
incident
reported
associated
with
exposure
to
end­
use
products
containing
Quats.
Dermal,
ocular
and
inhalation
are
the
primary
routes
of
exposure.
Most
of
the
incidences
are
related
to
irritation.
Allergic
type
reaction
is
also
been
reported
in
some
Page
33
of
52
incidents.
Although
risk
associated
with
eye
exposure
is
not
assessed
in
the
risk
assessment
process,
symptoms
associated
with
eye
are
most
commonly
reported
associated
with
Quats
exposure.
The
most
common
symptoms
reported
for
cases
of
ocular
exposure
were
eye
irritation/
burning,
eye
pain,
conjunctivitis,
swelling
eye
and
swelling
of
eyelid.

The
most
common
symptoms
reported
for
cases
of
inhalation
exposure
were
respiratory
irritation/
burning,
irritation
to
mouth/
throat/
nose,
coughing/
choking,
chest
pain,
disorientation,
dizziness,
shortness
of
breath.

The
most
common
symptoms
reported
for
cases
of
dermal
exposure
were
skin
irritation/
burning,
rash,
itching,
and
blistering.
Allergic
type
reactions
including
hives
and
allergic
contact
dermatitis,
have
also
been
reported..

Although
oral
exposure
is
considered
a
minor
route
of
exposure
for
Quats
use,
irritation
to
mouth/
throat/
nose,
vomiting/
nausea/
abdominal
pain,
dizziness,
and
headache
have
been
reported
in
the
cases
of
ingestion.

10.0
ENVIRONMENTAL
RISKS
The
results
of
the
dietary
avian
studies
indicate
that
DDAC
is
practically
non­
toxic
to
both
mallard
duck
and
bobwhite
quail.
In
the
Acute
oral
studies,
the
chemical
was
found
to
be
moderately
toxic
to
bobwhite
quail.
The
results
from
freshwater
fish
acute
toxicity
studies
demonstrated
that
DDAC
was
moderately
to
highly
toxic.
DDAC
is
very
highly
toxic
to
freshwater
aquatic
invertebrates.
DDAC
is
very
highly
toxic
to
mysid
shrimp
a
marine/
estuarine
invertebrate.
DDAC
is
toxic
to
freshwater
alga
at
microgram
concentrations.
Data
Gaps:
The
following
data
requirements
are
outstanding
for
the
currently
registered
uses
of
DDAC:
850.4225
­
Non­
target
plant
phytotoxicity
testing
(
seedling
emergence
test
using
rice).
850.1035
­
Acute
Sheepshead
minnow
testing
850.1300
­
Acute
eastern
oyster
embryo
larvae
testing
850.1300
­
Chronic
Daphnis
magna
testing
Monitoring/
Tier
II
modeling
of
once­
through
cooling
tower
use
to
establish
EEC's
for
risk
assessment.

Tier
I
once­
through
cooling
tower
modeling
indicates
that
DDAC
use
will
result
in
acute
and
chronic
risk
to
all
non­
endangered
and
endangered/
threatened
aquatic
organisms
at
all
dosages
modeled:
32
ppm
and
63
ppm
for
continuous
dosing
and
1000
ppm
and
1800
ppm
for
intermittent
dosing.
The
high
vs
medium
vs
low
water
flow
rate
is
based
on
size
of
the
facility.
Generally,
higher
flow
(
e.
g.,
>
1000
MGD)
would
use
more
chemical
than
smaller
facilities,
but
the
pattern
does
not
hold
true
across
the
board,
probably
because
model
input
values
are
based
on
different
receiving
water
("
reach")
data
for
individual
facilities.
This
model
uses
7Q10
rainfall
conditions,
which
is
essentially
the
worst­
case
drought
of
a
10
year
period.
Variables
such
as
stream
flow
rate
and
DDAC
dissipation,
degradation,
and
1/
2
life
were
not
considered
in
this
Tier
I
model
but
should
be
considered
in
higher
tier
modeling.
Field
monitoring
is
suggested
in
the
absence
of
higher
Tier
modeling.
Risk
mitigation
recommendations
should
be
based
on
dosing
method
(
e.
g.
intermittent
vs
continuous)
and
application
rate
instead
of
facility
size,
Page
34
of
52
however,
risk
mitigation
is
not
recommended
at
this
time.

Wood
Treatment
Use:
The
maximum
amount
of
leachate
from
treated
wood
per
the
Krahn
and
Strub,
1990
model
totaled
18.97
ppb.
The
lowest
predicted
amount
of
leachate
was
4.7
ppb
and
the
highest
amount
was
113.8
ppb.
Non­
endangered/
threatened
aquatic
species
(
fish
and
invertebrates)
are
not
expected
to
be
adversely
affected
­
acute
or
chronic
toxicity
­
based
on
LOCs
above.
Endangered/
threatened
fish
(
freshwater
warm
water
species)
are
not
expected
to
be
adversely
affected
by
the
wood
treatment
use.
However,
green
alga
non­
endangered/
threatened
species,
and
freshwater
fish
coldwater
species,
freshwater
and
marine
aquatic
invertebrates,
and
green
algae
endangered/
threatened
species
are
at
risk
from
the
wood
treatment
use.

Due
to
the
extreme
sensitivity
of
freshwater
and
marine
aquatic
invertebrates
to
DDAC,
methods
such
as
indoor
or
covered
wood
storage
and/
or
containment
of
runoff
water
via
berms
or
plastic
barriers
in
outdoor
storage
areas
are
suggested.
DDAC
is
tightly
adsorbed
to
clay
and
organic
matter
which
greatly
reduces
potential
for
DDAC
to
leach
downward
through
soil
to
groundwater,
and
will
serve
to
reduce
surface
runoff
as
well.

Endangered
Species
Concerns:
DDAC
uses
that
have
potential
for
direct
release
into
the
environment
or
runoff
to
surface
waters
include
once­
through
cooling
tower
and
wood
treatment
uses
respectively.
These
uses
are
considered
to
be
representative
of
having
worst­
case
potential
for
impacting
the
environment.
Therefore,
these
sites
were
modeled.
The
"
best
case"
once­
through
cooling
tower
scenario
using
1/
2
the
maximum
recommended
label
dosage
intermittently
applied
in
a
low
water
flow
resulted
in
LOC
exceedances
for
all
aquatic
organisms
used
in
the
model,
including
freshwater
fish,
green
alga,
freshwater
invertebrates,
and
marine
invertebrates.
The
agency
is
not
aware
of
any
endangered
or
threatened
green
algae.
Because
DDAC
is
rapidly
adsorbed
to
organic
materials
and
clay,
impacts
to
aquatic
organisms
may
be
less
than
modeled.
Aerobic
aquatic
metabolism
study
on
DDAC
(
MRID#
422538­
03)
provides
a
sediment
half­
life
of
60
years.
There
is
a
potential
for
sediment
concentrations
to
reach
toxic
levels
over
time
(
aerobic
soil
metabolism
half­
life
of
2.8
years,
MRID#
422538­
01).
The
once­
through
cooling
tower
model
does
not
account
for
degradation
and
therefore,
further
assessment
is
required
prior
to
making
an
agency
endangered
species
determination.
Endangered/
threatened
coldwater
fish
species,
marine
and
freshwater
invertebrates,
and
green
algae
species
are
expected
to
be
adversely
affected
by
the
wood
treatment
use.
Impacts
from
the
wood
treatment
use
are
not
expected
to
occur
as
long
as
precautions
are
taken
to
prevent
leaching
when
wood
is
stored
outdoors.

The
Environmental
Fate
and
Effects
Division
(
EFED)
has
evaluated
the
outdoor
use
of
the
quaternary
ammonium
compounds,
didecyl
ammonium
chlorides
(
DDAC),
being
considered
for
reregistration
by
the
Antimicrobial
Division
(
AD)
(
DP
Barcode
D325481).
Although
primarily
used
as
antimicrobial
agents,
DDAC
is
labeled
for
use
in
puddles
and
decorative
pools
to
control
algae.
This
use
is
intended
for
waterbodies
generally
disconnected
from
the
greater
watershed
and
will
not
likely
result
in
exposure
to
nontarget
aquatic
species.
It
is
possible
these
uses
will
result
in
exposure
to
amphibians
utilizing
these
waterbodies
for
some
portion
of
their
lifecycle
(
e.
g.
reproduction)
and
to
birds
and
mammals
utilizing
these
waterbodies
for
drinking
water.
At
the
maximum
label
rate,
3
ppm
initially
followed
by
Page
35
of
52
weekly
1.5
ppm
treatments,
there
are
no
LOC
exceedances,
assuming
the
toxicity
of
DDAC
is
similar
to
that
of
ADBAC.
However,
due
to
the
persistence
of
DDAC,
it
is
possible
that
concentrations
of
DDAC
in
some
waterbodies
treated
over
time
could
become
harmful
to
animals
utilizing
these
waterbodies.
Page
36
of
52
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Residential
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EPA
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USEPA.
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HED
Science
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Recommended
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SOPs)
for
Residential
Exposure
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February
22,
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USEPA.
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42161602
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42161601
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282
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41018701
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164
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41804501
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Two­
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758
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41970401
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41802301
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Chronic
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prepared
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Bushy
Run
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1006
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40282201
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MRID)
Friederich,
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Salmonella/
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Federal
Page
40
of
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18
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44005801
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"
Salmonella/
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22."
Unpublished
study
prepared
by
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of
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Swiss
Federal
Institute
of
Technology
and
University
of
Zurich.
14
p.

93014007
(
MRID)
Schoenig,
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Lonza
Inc
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40895201.
Mutagenicity
Test
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Unscheduled
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10141­
0­
447.
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14
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40895202
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MRID)
Young,
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CHO/
HGPRT
Forward
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HLA
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10141­
0­
435.
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study
prepared
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Hazleton
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America,
Inc.
68
p.

41252601
(
MRID)
Holmstrom,
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1986)
PO151:
Chromosomal
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Chinese
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735717.
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study
prepared
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36
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93014008
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MRID)
Schoenig,
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(
1990)
Lonza
Inc
Phase
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Summary
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Mutagenicity
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Didecyldimethylammoniumchloride
in
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CHO/
HGPRT
Forward
Mutation
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No.
10141­
0­
435.
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Hazleton
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Inc.
17
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40895201
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MRID)
Cifone,
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1988)
Mutagenicity
Test
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Didecyldimethylammonium
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in
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Rat
Primary
Hepatocyte
Unscheduled
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Assay:
HLA
Study
No.
10141­
0­
447.
Unpublished
study
prepared
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Hazleton
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60
p.

41617101
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MRID)
Selim,
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197
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41385101
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APPENDIX
A:
Master
DDAC
Label
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
Industrial
processes
and
water
systems
1839­
129
Industrial
Recirc
Water
Systems
Cooling
Towers
(
including
evaporative
condensers,
dairy
sweetwater
systems,
cooling
canals,
pasteurizers,
tunnel
coolers
and
warmers)
Pour/
metered
1839­
129
(
50%
ai)
Weekly
10707­
46
cooling
water,
disposal
water,
oil
field
operations
slug
treatment
1839­
151
Oil
Field
water
flood
or
salt
water
disposal
oil
field
water
disposal
systems
pour/
metered
1839­
151
As
needed
1839­
179
Oil
Field
injection
and
wastewater
continuous
injection
Blend
with
ADBAC
As
needed
1839­
179
Oil
Field
injection
and
wastewater
batch
treatment
Blend
with
ADBAC
As
needed
1839­
179
Oil
Field
packer
fluids
Blend
with
ADBAC
As
needed
1839­
179
Oil
Field
drilling
muds
Blend
with
ADBAC
As
needed
Swimming
Pools
10324­
69
Swimming
Pool
pour
Once
weekly
1839­
133
Outside
Spas/
Whirlpools/
Hot
Tub
Bath
pour
Weekly
Aquatic
Areas
499­
482
greenhouse/
nurseries,
golf
courses,
recreational
parks,
amusement
parks,
universities,
cemeteries
decorative
fountains,
decorative
pools,
ponds,
water
displays,
standing
waters
dribble,
spray
ring
Blend
with
ADBAC
As
needed
499­
482
greenhouse/
nurseries
irrigation
system,
watering
lines,
drip
lines,
emitters,
watering
nozzles,
and
hoses
immersing
or
running
thru
system
Blend
with
ADBAC
As
needed
Page
42
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
Wood
Treatment
6836­
212
Pressure
Treatment
3%
ai
soln
As
needed
6836­
212
Double
vacuum
3%
ai
soln
As
needed
6836­
212
Dip/
Spray
surface
treatment
3%
ai
soln
As
needed
Agricultural
Premises
and
Equipment
10324­
80
hatcheries,
swine/
poultry/
turkey
farms,
egg
receiving
area,
egg
holding
area,
setter
room,
tray
dumping
area,
chick
holding
room,
poultry
buildings,
dressing
plants,
farrowing
barns
and
areas,
blocks,
creep
areas,
chick
holding
area,
hatchery
room,
chick
processing
area,
and
chick
loading
area
toilets,
urinals,
portable
toilets,
floors,
walls,
ceilings,
feed
racks,
mangers,
troughs,
automatic
feeders/
fountains/
wa
terers,
other
feeding
and
watering
appliances,
halters,
ropes
and
other
types
of
equipment
used
in
handling
and
restraining
animals,
as
well
as
forks,
shovels,
and
scrapers
used
for
removing
litter
and
manure,
blocks,
chutes,
incubators,
hatchers,
glazed
porcelain,
glazed
ceramic
tile,
glass
mop,
wipe,
spray,
immersion
As
needed
10324­
81
hatchery
rooms
fogging
Blend
with
ADBAC
As
needed
10324­
81
incubators
and
hatchers
fogging
Blend
with
ADBAC
Every
12
hrs
10324­
108
Mushroom
Farm
breezeways
and
track
alleys
before
spawning,
inside
and
outside
walls
of
mushroom
houses,
lofts,
floors,
storage
sheds
and
casing
rings
mop,
wipe
Blend
with
ADBAC
As
needed
1839­
167
Mushroom
Farm
breezeways
and
track
alleys
before
spawning,
inside
and
outside
walls
of
mushroom
houses,
lofts,
floors,
storage
sheds
and
casing
rings
cloth,
mop,
sponge,
spray,
immersion
Blend
with
ADBAC
As
needed
1839­
167
Mushroom
Farm
waterproof
footwear
immersion
(
shoe
bath)
Blend
with
ADBAC
As
needed
1839­
167
Citrus
Farm
trucks,
vehicles,
equipment,
trailers,
field
harvesting
equipment,
cargo
area,
wheels,
tires,
under
carriage,
hood,
roof,
fenders
spray,
dip,
brush
Citrus
canker,
Blend
with
ADBAC
As
needed
10324­
117
Animal
housing
facilities
boots
and
shoes
immersion
Blend
with
ADBAC
As
needed
Page
43
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
1839­
167
Florists/
flower
shops,
greenhouses,
shippers,
packing
areas
flower
buckets,
coolers,
floors
and
walls
of
coolers,
design
and
packing
benches,
garbage
pails
Mop/
wipe,
cloth,
brush,
sponge,
sprayer
Blend
with
ADBAC
As
needed
241­
74
Greenhouses
ornamental
plants
­
plant
regulator
spray,
drench
499­
482
greenhouse/
nursuries
work
tables,
benches,
pots,
flats,
knives,
pruning
tools,
floors,
plant
containers,
carts,
transplant
trays,
hanging
baskets,
tray/
pot
holders,
water
collectors,
walkways,
windows
immersion,
spray,
brush
Blend
with
ADBAC
As
needed
48815­
1
Farms
fish
aquariums,
tanks,
fish
handling
equipment,
nets,
seines,
traps,
filter
boxes,
pumps,
air
diffusers,
shipping
boxes,
feeding
equipment,
floors,
countertops,
raceways,
garbage
pails,
other
hard
nonporous
surfaces,
holding
tanks,
lavatories.
immersion,
brush,
mop
or
cloth
As
needed
Residential
and
Public
Access
Premises
10324­
134
Homes
floors,
walls,
windows,
toilets,
bathtubs,
shower
stalls,
shower
door/
curtain,
sinks,
mirrors,
restroom
fixtures,
cabinets,
tables,
chairs,
desks,
bed
frames,
doorknobs,
garbage
cans/
pails,
outdoor
furniture,
telephones,
glazed
porcelain,
glazed
ceramic
tile,
glass,
Countertops
(
kitchen/
food
prep);
Internal
(
external)
surfaces
of
appliances
(
refrigerator,
microwave,
freezer);
stovetop;
table
surfaces;
sinks,
shelves,
racks
mop,
wipe,
(
cloth),
spray
Disinfect
Heavy
Duty
Cleaning
As
needed
1839­
175
Home
floors,
walls,
metal
surfaces,
stainless
steel,
glazed
porcelain,
glazed
ceramic
tile,
shower
stalls,
bathtubs,
cabinets,
plastic
surfaces
RTU
wipe/
spray
Blend
with
ADBAC
As
needed
Page
44
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
10324­
108
Homes
Carpets
Rotary
Floor
Machine
Blend
with
ADBAC
300­
500
sq
ft/
gal
3573­
69
Home
Furniture
upholstery,
window
treatments,
clothing,
plush
toys,
shoes/
sneakers,
children
mattresses,
pet
bed,
sports
bag/
equipment,
carpet
Spray
(
fabric
sanitizer)
As
Needed
3573­
69
homes,
mobile
home,
car,
campgrounds,
trailer,
camper,
boat
floors,
walls,
toilets,
urinals,
bathrooms,
bathtubs,
sinks,
countertops,
shower
doors/
curtains,
toilet
seats,
shower
stalls,
tables,
chairs,
shelves,
telephones,
cabinets,
desks,
bed
springs,
door
knobs,
linen
carts,
hampers,
exercise
equipment,
cat
litter
boxes,
bidets,
diaper
changing
tables,
toys,
high
chairs,
fountains,
synthetic
marbel,
vinyl,
linoleum
,
sealed
granite,
glazed
porcelain,
microwave
oven
exteriors,
marlite,
plastic,
outdoor
furniture,
laundry
hampers,
spray
(
disinfect)
potable
rinse
for
chidren
toys
and
food
contact
10324­
117
Homes
cooking
utensils;
coolers/
ice
chest;
cups;
cutlery;
dishes;
eating
utensils;
glassware
Immersion
Blend
with
ADBAC
As
needed
Page
45
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
1836­
167
campgrounds,
playgrounds,
Public
facilites,
mobile
homes,
cars,
campers,
trailers,
trucks
floors,
walls,
toilets,
urinals,
bathrooms,
bathtubs,
sinks,
countertops,
shower
doors/
curtains,
toilet
seats,
shower
stalls,
tables,
chairs,
shelves,
telephones,
cabinets,
desks,
bed
springs,
door
knobs,
linen
carts,
hampers,
exercise
equipment,
automobile/
truck
interiors,
garbage
cans/
pails,
fixtures,
metal,
stainless
steel.
glazed
porcelain,
glazed
ceramic
tile,
plastic,
granite,
marble,
chrome,
vinyl,
glass,
enameled
surfaces,
painted
wood
work,
Formica,
vinyl
and
plastic
upholstery,
chrome
plated
fixtures
cloth,
mop,
sponge,
spray
Blend
with
ADBAC
As
needed
10324­
117
Homes
water
softners
and
reverse
osmosis
units
pour
As
needed
6718­
24
Homes
bedframes,
tables,
sinks,
walls,
countertops,
chairs,
other
hard
nonporous
surfaces
cloth,
mop,
spray
As
needed
1839­
178
Homes
counters,
stovetops,
sinks,
outside
microwaves,
refrigerator
exteriors,
walls,
appliances,
finished
wood,
cabinets,
floors,
exterior
toilet
bowl
surfaces,
trash
cans,
tubs,
shower
walls,
bathrooms,
door
knobs,
closets,
phones,
car
interiors,
computers,
hand
rails,
switch
plates,
door
frames,
urinals,
desks,
cribs,
changing
tables,
patio
furniture,
dining
room
surfaces
RTU
wipe/
spray
Blend
with
ADBAC
As
needed
Page
46
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
48815­
1
Homes
fish
aquariums,
tanks,
fish
handling
equipment,
nets,
seines,
traps,
filter
boxes,
pumps,
air
diffusers,
shipping
boxes,
feeding
equipment,
floors,
countertops,
raceways,
garbage
pails,
other
hard
nonporous
surfaces,
holding
tanks,
lavatories.
immersion,
brush,
mop
or
cloth
As
needed
10324­
80
Homes
air
ducts
spray,
brush,
mop,
wipe,
ULV
or
mist
generating,
automated
spray
odor
causing
bacteria,
fungi
6
months
Medical
Premises
and
Equipment
1839­
167
Hospitals,
Health
Care
facilities,
Medical/
Dental
offices,
Nursing
homes,
operating
rooms,
patient
care
facilities,
clinics,
isolation
wards,
medical
research
facilities,
autopsy
rooms,
ICU
areas,
recovery
anesthesia,
emergency
rooms,
X­
ray
cat
labs,
newborn
nurseries,
orthopedics,
respiratory
therapy,
acute
care
institutions,
alternate
care
institutions,
healthcare
institutions,
Funeral
Homes,
mortuaries
floors,
walls,
toilets,
urinals,
lavatories,
bathrooms,
bathing
areas,
bathtubs,
sinks,
sink
tops,
shower
stalls,
shower
doors/
curtains,
mirrors,
ultrasonic
bath,
whirlpools,
foot
baths,
countertops,
cabinets,
tables,
chairs,
desks,
hospital
beds,
bed
springs,
bed
frames,
traction
devices,
MRI,
CAT,
examining
tables,
scales,
paddles,
wheelchairs,
lifts,
door
knobs,
wheel
chairs,
telephones,
garbage
pails/
cans,
fixtures,
metal,
stainless
steel.
glazed
porcelain,
glazed
ceramic
tile,
plastic,
granite,
marble,
chrome,
vinyl,
glass,
enameled
surfaces,
painted
wood
work,
Wipe,
mop,
(
cloth),
swab,
brush,
spray
Blend
with
ADBAC
As
needed
10324­
81
Nurseries
Floors,
walls,
countertops
(
nonkitchen
sinks
(
bathroom),
toilets,
external
surfaces
of
appliances
mop,
wipe
(
cloth)
Blend
with
ADBAC
As
needed
1839­
175
Medical
Institutions,
Hospitals,
and
Nursing
Homes
floors,
walls,
metal
surfaces,
stainless
steel,
glazed
porcelain,
glazed
ceramic
tile,
shower
stalls,
bathtubs,
cabinets,
plastic
surfaces
RTU
wipe/
spray
Blend
with
ADBAC
As
needed
Page
47
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
10324­
134
hospitals,
medical/
dental
offices,
nursing
homes
floors,
walls,
windows,
toilets,
bathtubs,
shower
stalls,
shower
door/
curtain,
sinks,
mirrors,
restroom
fixtures,
cabinets,
tables,
chairs,
desks,
bed
frames,
doorknobs,
garbage
cans/
pails,
telephones,
glass,
glazed
porcelain,
glazed
ceramic
tile,
table
surfaces;
sinks,
shelves,
racks
mop,
wipe,
(
cloth),
spray
Disinfect
Heavy
Duty
Cleaning
As
needed
1839­
167
nursing
homes
and
hospitals
floors,
walls,
windows,
toilets,
bathtubs,
shower
stalls,
shower
door/
curtain,
sinks,
mirrors,
restroom
fixtures,
cabinets,
tables,
chairs,
desks,
bed
frames,
doorknobs,
garbage
cans/
pails,
telephones,
glass,
glazed
porcelain,
glazed
ceramic
tile,
enameled
surfaces,
countertops
(
kitchen/
food
prep);
Internal
external
surfaces
of
appliances
(
refrigerator,
microwave,
freezer);
stovetop,
shelves,
racks
portable
extraction
units,
truck
mounted
extraction
machines,
rotary
floor
machines,
metered,
spray
Blend
with
ADBAC
As
needed
6718­
24
hospitals,
nursing
homes
bedframes,
tables,
sinks,
walls,
countertops,
chairs,
other
hard
nonporous
surfaces
cloth,
mop,
spray
As
needed
1839­
178
hospitals,
day­
care
facilities,
sick
rooms
counters,
stovetops,
sinks,
outside
microwaves,
refrigerator
exteriors,
walls,
appliances,
finished
wood,
cabinets,
floors,
exterior
toilet
bowl
surfaces,
trash
cans,
tubs,
shower
walls,
bathrooms,
door
knobs,
closets,
phones,
car
interiors,
computers,
hand
rails,
switch
plates,
door
frames,
urinals,
desks,
cribs,
changing
tables
RTU
wipe
Blend
with
ADBAC
As
needed
1839­
173
Morgues
and
Funeral
homes
human
remains
sponge,
wash
cloth,
soft
brush
Blend
with
ADBAC
As
needed
Page
48
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
10324­
80
hospitals,
nursing
homes
air
ducts
spray,
brush,
mop,
wipe,
ULV
or
mist
generating,
automated
spray
odor
causing
bacteria,
fungi
6
months
Commercial,
Institutional,
and
Industrial
premises
and
equipment
10324­
134
Athletic/
recreational
facilities,
exercise
facilities,
schools,
colleges,
dressing
rooms,
transportation
terminals,
institutions
floors,
walls,
windows,
toilets,
bathtubs,
shower
stalls,
shower
door/
curtain,
sinks,
mirrors,
restroom
fixtures,
cabinets,
tables,
chairs,
desks,
bed
frames,
doorknobs,
garbage
cans/
pails,
outdoor
furniture,
telephones,
glass,
glazed
porcelain,
glazed
ceramic
tile,
chrome
plated
intakes,
enameled
surfaces,
countertops
(
kitchen/
food
prep);
Internal
(
external)
surfaces
of
appliances
(
refrigerator,
microwave,
freezer);
stovetop;
table
surfaces;
sinks,
shelves,
racks
mop,
wipe,
(
cloth),
spray
Disinfect
Heavy
Duty
Cleaning
As
needed
1839­
167
Athletic/
recreational
facilities,
exercise
facilites,
locker
rooms,
dressing
rooms,
schools,
colleges,
transportation
terminals,
floors,
walls,
toilets,
urinals,
bathrooms,
bathtubs,
sinks,
countertops,
shower
doors/
curtains,
toilet
seats,
shower
stalls,
tables,
chairs,
shelves,
telephones,
cabinets,
desks,
bed
springs,
door
knobs,
garbage
cans/
pails,
fixtures,
metal,
stainless
steel.
glazed
porcelain,
glazed
ceramic
tile,
plastic,
granite,
marble,
chrome,
vinyl,
glass,
enameled
surfaces,
painted
wood
work,
cloth,
mop,
sponge,
spray
Blend
with
ADBAC
As
needed
1839­
167
Motels,
hotels,
schools
carpets
portable
extraction
units,
truck
mounted
extraction
machines,
rotary
floor
machines,
metered,
spray
Cleaning
Claim
Blend
with
ADBAC
As
needed
Page
49
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
1839­
175
Hotels
and
schools
floors,
walls,
metal
surfaces,
stainless
steel,
glazed
porcelain,
glazed
ceramic
tile,
shower
stalls,
bathtubs,
cabinets,
plastic
surfaces
RTU
wipe/
spray
Blend
with
ADBAC
As
needed
6836­
78
Barber
and
Beauty
Salons
Barber/
Beauty
Instruments
and
Tools
immersion
Blend
with
ADBAC
As
needed
1839­
178
Barber
and
Beauty
Salons,
Health
clubs,
hotels,
motels,
emergency
vehicles,
transportation
terminals,
correctional
facilities,
factories,
counters,
sinks,
walls,
finished
wood,
cabinets,
floors,
exterior
toilet
bowl
surfaces,
trash
cans,
tubs,
shower
walls,
bathrooms,
door
knobs,
closets,
phones,
car
interiors,
computers,
hand
rails,
switch
plates,
door
frames,
urinals,
desks,
RTU
wipe
Blend
with
ADBAC
As
needed
1839­
167
commercial
florists
flower
buckets,
coolers,
floors
and
walls
of
coolers,
design
and
packing
benches,
garbage
pails
cloth,
mop,
sponge,
spray
Blend
with
ADBAC
As
needed
3573­
69
Hotels,
dorms,
convenience
stores,
recreational
centers,
offices,
motels,
floors,
walls,
toilets,
urinals,
bathrooms,
bathtubs,
sinks,
countertops,
shower
doors/
curtains,
toilet
seats,
shower
stalls,
tables,
chairs,
shelves,
telephones,
cabinets,
desks,
bed
springs,
door
knobs,
linen
carts,
hampers,
exercise
equipment,
bidets,
fountains,
synthetic
marble,
vinyl,
linoleum
,
sealed
granite,
glazed
porcelain,
microwave
oven
exteriors,
marlite,
plastic,
outdoor
furniture,
laundry
hampers,
spray
(
disinfect)
potable
rinse
for
chidren's
toys
and
food
contact
surfaces
1677­
109
Commercial
and
institutional
laundry
mats
clothing
pour
at
final
rinse
or
sour
to
washweel
per
100lbs
fabric
dry
wt
2wk
protect
3wk
protect
30dy
protect
6718­
24
industry
and
schools
bedframes,
tables,
sinks,
walls,
countertops,
chairs,
other
hard
nonporous
surfaces
cloth,
mop,
spray
As
needed
Page
50
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
48815­
1
Schools,
Institutional,
and
Industrial
fish
aquariums,
tanks,
fish
handling
equipment,
nets,
seines,
traps,
filter
boxes,
pumps,
air
diffusers,
shipping
boxes,
feeding
equipment,
floors,
countertops,
raceways,
garbage
pails,
other
hard
nonporous
surfaces,
holding
tanks,
lavatories.
immersion,
brush,
mop
or
cloth
As
needed
10324­
80
Institutional,
Industrial
premise,
school,
restaurant
air
ducts
spray,
brush,
mop,
wipe,
ULV
or
mist
generating,
automated
spray
odor
causing
bacteria,
fungi
6
months
Food
Handling/
Storage
Establishments
premises
and
equipment
1839­
152
Restaurants,
food
service
establishments,
food
processing
plants/
facilities,
beverage
processing
plants,
Bars,
Cafeterias,
Convenience
stores,
supermarkets,
Dairies,
Egg
Processing
plants,
Federally
inspected
meat
and
poultry
plants
,
Food
Handling
areas,
Food
preparation
areas,
Food
storage
areas,
Institutional
kitchens,
USDA
inspected
food
processing
facilities,
breweries,
fast
food
operations
floors,
walls,
countertops,
appliances
(
microwaves,
refrigerators,
stove
tops,
freezers,
coolers),
chairs,
tables,
shelves,
picnic
tables,
outdoor
furniture,
racks,
carts,
telephones,
door
knobs,
storage
areas,
potato
storage
areas,
food
storage
areas,
garbage
storage
areas,
cutting
boards,
tanks,
exhaust
fans,
refrigerator
bins,
refrigerated
storage/
display
equipment,
coils
and
drain
pans
of
air
conditioning/
refriger
ation
equipment,
heat
pumps,
storage
tanks,
coolers,
ice
chests,
garbage
cans/
pails
cloth,
mop,
spray,
flood,
immersion,
As
needed
1839­
175
Restaurants
floors,
walls,
tables,
shelves,
garbage
disposal
areas,
metal
surfaces,
stainless
steel,
glazed
porcelain,
glazed
ceramic
tile,
shower
stalls,
bathtubs,
cabinets,
plastic
surfaces
RTU
spray/
wipe
Blend
with
ADBAC
As
needed
10324­
81
Dairies
and
Food
Processing
Facilities
floors,
walls,
metal
surfaces,
stainless
steel,
glazed
porcelain,
glazed
ceramic
tile,
shower
stalls,
bathtubs,
cabinets,
plastic
surfaces
fogging
Blend
with
ADBAC
As
needed
Page
51
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
10324­
134
bottling
and
beverage
plants,
breweries,
tobacco,
egg
processing
plants,
meat/
poultry
processing
plants,
rendering
plants,
fishery/
milk/
citrus/
wine/
ice
cream/
potato
processing
plants,
restaurants
floors,
walls,
tables,
shelves,
garbage
cans,
garbage
disposal
areas,
glazed
porcelain,
glazed
ceramic
tile,
glass
mop,
wipe,
(
cloth),
spray
As
needed
1839­
178
Restaurants
counters,
stovetops,
sinks,
outside
microwaves,
refrigerators
exteriors,
walls,
appliances,
finished
wood,
cabinets,
floors,
exterior
toilet
bowl
surfaces,
trash
cans,
tubs,
shower
walls,
bathrooms,
door
knobs,
closets,
phones,
computers,
hand
rails,
switch
plates,
door
frames,
urinals,
desks,
dining
room
surfaces
RTU
wipe
Blend
with
ADBAC
As
needed
10324­
117
bottling
and
beverage
plants,
breweries,
tobacco,
egg
processing
plants,
meat/
poultry
processing
plants,
rendering
plants,
fishery/
milk/
citrus/
wine/
ice
cream/
potato
processing
plants,
restaurants
ice
machines,
water
coolers,
counters,
tables,
food
processing
equipment,
food
utensils,
dairy
equipment,
dishes,
silverware,
eating
utensils,
glasses,
sinks,
counters,
refrigerated/
storage
display
equipment
spray,
wipe,
sponge,
immersion
As
needed
10324­
117
bottling
and
beverage
plants,
breweries,
tobacco,
egg
processing
plants,
meat/
poultry
processing
plants,
rendering
plants,
fishery/
milk/
citrus/
wine/
ice
cream/
potato
processing
plants,
water
softners
and
reverse
osmosis
units
pour
As
needed
10324­
117
bottling
and
beverage
plants,
breweries,
tobacco,
egg
processing
plants,
meat/
poultry
processing
plants,
rendering
plants,
fishery/
milk/
citrus/
wine/
ice
cream/
potato
processing
plants,
boots
and
shoes
immersion
Blend
with
ADBAC
As
needed
Page
52
of
52
EPA
Reg
Number
used
for
Max.
Appl.
Rate
Use
Site
Treatment
Site/
Surfaces
Method
of
Application
Notes
Freq
of
Application
1839­
173
dairies,
beverage,
and
food
processing
plants
floors,
walls,
countertops,
appliances
(
microwaves,
refrigerators,
stove
tops,
freezers,
coolers),
chairs,
tables,
shelves,
racks,
carts,
telephones,
door
knobs,
storage
areas,
potato
storage
areas,
food
storage
areas,
garbage
storage
areas,
cutting
boards,
tanks,
exhaust
fans,
refrigerator
bins,
refrigerated
storage/
display
equipment,
storage
tanks,
coolers,
ice
chests,
garbage
cans/
pails
fogging
Blend
with
ADBAC
As
needed
10324­
80
food
processing
plants,
food
service
areas,
institutional
kitchens,
industrial/
hospital
caferias,
school
lunchrooms,
dairies,
and
packing
plants
air
ducts
spray,
brush,
mop,
wipe,
ULV
or
mist
generating,
automated
spray
odor
causing
bacteria,
fungi
6
months
Clean/
Deodorization
1839­
167
Water/
Smoke
restoration
(
institutional,
industrial,
hospital)
carpets,
carpet
cushion,
sub
floors,
drywall,
trim,
farm
lumber,
tackless
strip
and
paneling
Pour,
brush,
spray
Blend
with
ADBAC
As
needed
1839­
167
Sewer
backup/
river
flood
cleanup,
(
clean
water
source)
carpets,
carpet
cushion,
sub
floors,
drywall,
trim,
farm
lumber,
tackless
strip
and
paneling
spray
Blend
with
ADBAC
As
needed
1839­
167
garbage
storage
areas,
pet
areas,
garbage
bins
&
cans
Blend
with
ADBAC
As
needed
71814­
1
hospitals
Medical
waste
pour
blend
w/
ADBAC
Poured
into
machine
