Page
1
of
46
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
February
27,
2006
Memorandum:

SUBJECT:
Alkyl
Dimethyl
Benzyl
Ammonium
Chloride
(
ADBAC):
Occupational
and
Residential
Exposure
Assessment
for
the
Reregistration
Eligibility
Decision
Document.

FROM:
Matthew
Lloyd,
Industrial
Hygienist
Reregistration
Branch
 
RRB1
Health
Effects
Division
(
7509C)

THROUGH:
Whang
Phang,
Branch
Senior
Scientist
Reregistration
Branch
 
RRB1
Health
Effects
Division
(
7509C)

TO:
Jacquie
McFarlane
Regulatory
Management
Branch
Antimicrobials
Division
(
7510C)

PC
Code:
069105
DP
Barcode:
D326917
The
attached
assessment
is
the
occupational
and
residential
exposure
and
risk
estimates
for
ADBAC
to
support
AD=
s
reregistration
eligibility
decision
(
RED)
document.
This
exposure
assessment
was
based
on
the
toxicity
endpoints
selected
by
AD.
The
data
analysis
included
in
this
assessment
was
prepared
by
Versar,
Inc.
under
the
supervision
of
HED.
Page
2
of
46
TABLE
OF
CONTENTS
Executive
Summary...................................................................................................................................................................................
3
1.0
Occupational
and
Residential
Exposure/
Risk
Assessment
............................................................................................................
7
1.1
Purpose......................................................................................................................................................................
7
1.2
Criteria
for
Conducting
Exposure
Assessments...................................................................................................
7
1.3
Summary
of
Hazard
Concerns
for
ADBAC
........................................................................................
7
1.4
Incident
Reports.....................................................................................................................................................
10
1.5
Summary
of
Use
Patterns
and
Formulations
.....................................................................................................
11
1.5.1
End­
Use
Products..................................................................................................................................
11
1.5.2
Registered
Use
Categories
and
Sites
...................................................................................................
11
1.5.3
Application
Methods.............................................................................................................................
15
2.0
Occupational
Exposures
and
Risks.................................................................................................................................................
15
2.1
Occupational
Handler
Exposures
and
Risks......................................................................................................
15
2.1.1
Data
and
Assumptions
for
Handler
Exposure
Scenarios.................................................................
16
2.1.1.1
Assumptions
for
Handler
Exposure
Scenarios
..................................................................................
16
2.1.1.2
Exposure
Data
for
Handler
Exposure
Scenarios
..............................................................................
17
2.1.1.3
ADBAC
Handler
Exposure
Scenarios................................................................................................
20
2.1.2
ADBAC
Handler
Exposure
and
Assessment
.....................................................................................
22
2.1.2.1
ADBAC
Handler
Exposure
and
Risk
Calculations
..........................................................................
22
2.1.2.2
ADBAC
Risk
Summary.......................................................................................................................
22
2.1.3
Cancer
ADBAC
Handler
Exposure
and
Risk
Assessment...............................................................
27
2.1.4
Summary
of
Risk
Concerns
and
Data
Gaps
for
Occupational
Handlers
......................................
27
2.1.4.1
Summary
of
Risk
Concerns..................................................................................................................
27
2.1.4.2
Summary
of
Data
Gaps
........................................................................................................................
28
2.1.5
Recommendations
for
Refining
Occupational
Handler
Risk
Assessment......................................
28
2.2
Occupational
Postapplication
Exposures
and
Risks
.........................................................................................
28
2.2.1
Occupational
Postapplication
Exposure
Scenarios...........................................................................
29
2.2.2
Data/
Assumptions
for
Postapplication
Exposure
Scenarios............................................................
30
2.2.3
Occupational
Postapplication
Exposure
and
Risk
Estimates
..........................................................
30
2.2.4
Occupational
Postapplication
Exposure
and
Risk
Estimates
for
Cancer......................................
31
2.2.5
Summary
of
Occupational
Postapplication
Risk
Concerns
and
Data
Gaps..................................
31
2.2.6
Recommendations
for
Refining
Occupational
Postapplication
Risk
Assessment
.........................
31
3.0
Residential
and
Other
Non­
Occupational
Exposures
and
Risks
................................................................................................
32
3.1
Residential
Handler
Exposures
and
Risks..........................................................................................................
32
3.1.1
Handler
Exposure
Scenarios................................................................................................................
32
3.1.2
Data
and
Assumptions
for
Handler
Exposure
Scenarios.................................................................
33
3.1.3
Residential
Handler
Exposure
and
Risk
Estimates
..........................................................................
34
3.1.4
Residential
Handler
Exposure
and
Risk
Estimates
for
Cancer
......................................................
38
3.1.5
Summary
of
Risk
Concerns
and
Data
Gaps
for
Handlers...............................................................
38
3.1.6
Recommendations
for
Refining
Residential
Handler
Risk
Assessment..........................................
39
3.2
Residential
Postapplication
Exposures
and
Risks
.............................................................................................
39
3.2.1
Residential
Postapplication
Exposure
Scenarios...............................................................................
39
3.2.2
Data
and
Assumptions
for
Residential
Postapplication
Exposure
Scenarios................................
41
3.2.3
Residential
Postapplication
Exposure
and
Risk
Estimates
..............................................................
42
3.2.4
Residential
Postapplication
Exposure
and
Risk
Estimates
for
Cancer..........................................
45
3.2.5
Summary
of
Residential
Postapplication
Risk
Concerns
and
Data................................................
45
Gaps..........................................................................................................................................................................................
45
3.2.6
Recommendations
for
Refining
Residential
Postapplication
Risk
Assessments............................
46
APPENDICES
Appendix
A
­
ADBAC
Occupational
Handler/
Postapplication
Risk
Calculations
Appendix
B
 
ADBAC
Agricultural
and
Residential
Handler
Risks
Page
3
of
46
Executive
Summary
ADBAC
(
Group
II
Quat
Cluster)
is
a
group
of
structurally
similar
quaternary
ammonium
compounds
("
quats").
Most
of
the
registered
uses
of
ADBAC
are
classified
as
antimicrobial
uses
and
will
be
assessed
by
the
Antimicrobial
Division
in
EPA=
s
Office
of
Pesticide
Programs.
This
document
is
the
occupational
and
residential
exposure
assessment
for
ADBAC
from
its
use
as
a
fungicide,
bactericide,
viricide,
algaecide
on
plants
and
as
an
insecticide
for
controlling
mosquitoes.
In
this
document,
the
Agency
presents
the
results
of
its
review
of
the
potential
human
health
effects
of
occupational
and
residential
(
non­
occupational)
exposure
to
ADBAC.

Toxicological
endpoints
were
selected
for
short­
term
dermal,
short­
and
intermediate­
term
inhalation,
and
incidental
oral
exposures
to
ADBAC.
There
is
a
significant
potential
for
exposure
in
occupational
agricultural
and
commercial
settings,
as
well
as
in
residential
settings.
Therefore,
risk
assessments
are
required
for
occupational
and
residential
handlers,
as
well
as
for
occupational
and
residential
postapplication
exposures
that
can
occur
as
a
result
of
ADBAC
use.

ADBAC
is
used
to
control
plant
diseases
and
to
treat
for
mosquito
larvae
in
water.
The
use
patterns
can
range
from
short­
term
through
intermediate­
term
exposure
durations.
Endpoints
were
selected
to
address
each
of
these
exposure
durations.
ADBAC
exposures
are
expected
to
occur
to
both
occupational
and
residential
users.
The
Agency
selected
a
short­
term
dermal
endpoint
for
ADBAC
based
on
adverse
dermal
effects
rather
than
systemic
toxicity.
The
shortterm
endpoint
for
a
formulated
product
(
NOAEL=
500
mg/
kg/
day
which
is
equivalent
to
7,750
µ
µ
g/
cm2)
was
determined
from
a
21­
day
dermal
toxicity
in
guinea
pigs
where
a
denuded
nonvascularized
epidermal
layer
was
observed
at
1,000
mg/
kg/
day.
The
short­
term
dermal
endpoint
for
the
technical
grade
active
ingredient
(
TGAI
 
80%
ai)
(
NOAEL=
20
mg/
kg/
day
which
is
equivalent
to
40
µ
g/
cm2)
was
determined
from
90­
day
dermal
toxicity
in
rats.

For
short­
and
intermediate­
term
inhalation
exposures
to
ADBAC,
a
NOAEL
of
3
mg/
kg/
day
was
selected
chosen
for
a
prenatal
developmental
toxicity
study
in
rabbits.
The
LOAEL
of
9
mg/
kg/
day
was
based
clinical
signs
of
toxicity
at
9
mg/
kg/
day
in
maternal
rabbits.
Long­
term
inhalation
exposure
to
ADBAC
(
i.
e.,
greater
than
6
months)
is
not
expected
for
current
registered
uses.
The
short­
term
incidental
oral
risk
assessment
for
ADBAC
was
based
on
a
NOAEL
of
10
mg/
kg/
day,
derived
from
a
prenatal
developmental
toxicity
study
in
rats.
The
LOAEL
of
(
100
mg/
kg/
day
was
based
decreased
body
weight
and
food
consumption.
No
cancer
endpoint
was
identified.

The
level
of
concern
(
LOC)
for
occupational
and
non­
occupational
ADBAC
dermal
and
inhalation
exposures
is
a
margin
of
exposure
(
MOE)
of
less
than
100.
The
MOE
was
based
on
10x
for
interspecies
extrapolation,
and
10x
for
intraspecies
variability.
Since
the
toxicological
endpoint
for
inhalation
is
female­
specific,
a
body
weight
of
60
kilograms
was
used
in
the
assessment.
This
value
represents
the
average
body
weight
of
an
adult
female.
For
calculating
dermal
exposure
risk,
the
unit
was
based
on
the
treatment
area
(
e.
g.­
µ
g/
cm2).

ADBAC
is
formulated
as
a
soluble
concentrate,
emulsifiable
concentrate,
ready­
to­
use
Page
4
of
46
solution,
pressurized
liquid,
wettable
powder,
water
soluble
packet,
flowable
concentrate,
microencapsulated
and
impregnated
material.
There
are
many
end­
use
products
that
contain
ADBAC
and
each
label
cannot
be
reviewed
to
determine
the
formulation­
type
and
the
registered
uses.
Also
note
that
the
Master
Label
does
not
indicate
the
formulation
types
that
have
been
registered
for
individual
use­
patterns.
Therefore,
as
a
conservative
approach,
this
chapter
will
assume
that
ADBAC
when
used
to
control
plant
diseases
may
be
formulated
as
a
liquid
concentrate,
a
dry
flowable,
and
a
wettable
powder.
For
mosquito
control,
it
is
assume
that
it
is
formulated
as
a
liquid
concentrate
only,
since
it
is
designed
to
be
poured
into
water
as
a
treatment
In
occupational
settings,
ADBAC
is
applied
with
several
types
of
application
equipment
including
groundboom
sprayers,
airblast
sprayers,
low­
pressure
handwand
sprayers,
high
pressure
handwand
sprayers,
handgun
sprayers,
dip
or
soak
tanks,
watering
cans,
and
pump­
trigger
sprayers.
ADBAC
dermal
exposures
and
risks
were
not
estimated
for
occupational
handler
exposures.
Instead,
dermal
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
ADBAC
that
result
in
classification
of
category
I
or
II
for
skin
irritation
potential
will
be
long­
sleeve
shirt,
long
pants,
shoes,
socks,
chemical­
resistant
gloves,
and
chemical­
resistant
apron.
The
minimum
PPE
required
for
mixers,
loaders,
and
others
exposed
to
end­
use
products
containing
concentrations
of
ADBAC
that
result
in
classification
of
category
III
for
skin
irritation
potential
will
be
long­
sleeve
shirt,
long
pants,
shoes,
socks,
and
chemical­
resistant
gloves.
Once
diluted,
if
the
concentration
of
ADBAC
in
the
diluted
solution
would
result
in
classification
of
toxicity
category
IV
for
skin
irritation
potential,
then
the
chemical­
resistant
gloves
and
chemical­
resistant
apron
can
be
eliminated
for
applicators
and
others
exposed
to
the
dilute.
Note
that
chemical­
resistant
eye
protection
will
be
required
if
the
end­
use
product
is
classified
as
category
I
or
II
for
eye
irritation
potential.

There
are
no
occupational
handler
scenarios
for
ADBAC
that
have
inhalation
risks
of
concern
for
occupational
exposures
at
the
maximum
level
of
risk
mitigation.
The
following
handler
inhalation
risks
are
of
concern
at
baseline
(
i.
e.,
no
respirator):
 
(
1a)
mixing/
loading
liquids
concentrates
for
groundboom
applications
for
drench
applications
to
carnations
(
256
lb
ai/
A)
 
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator,
 
(
2a)
mixing/
loading
wettable
powders
for
groundboom
applications
for
drench
applications
to
carnations
(
256
lb
ai/
A)
and
for
drench
applications
to
ornamental
plants
(
72
lb
ai/
A)
and
for
application
to
sodfarm
turf
(
0.9
lb
ai/
A)
 
risks
are
not
of
concern
with
engineering
controls
(
i.
e.,
water­
soluble
packaging)
for
the
drench
application,
and
risks
are
not
of
concern
for
application
to
sod
farms
with
the
addition
of
a
dust/
mist
respirator,
 
(
2b)
mixing/
loading
wettable
powders
support
LCO
handgun
applications
(
mixing/
loading
supports
20
LCOs)
for
applications
to
turf
(
7
lb
ai/
A
and
0.9
lb
ai/
A)
)
 
risks
are
not
of
concern
with
engineering
controls
(
i.
e.,
water­
soluble
packaging),
 
(
2b)
mixing/
loading
wettable
powders
support
LCO
handgun
applications
(
mixing/
loading
Page
5
of
46
supports
20
LCOs)
for
applications
to
turf
(
0.9
lb
ai/
A)
 
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator,
 
(
3a)
mixing/
loading
dry
flowables
for
groundboom
applications
for
drench
applications
to
carnations
(
256
lb
ai/
A)
 
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator,
 
(
4)
applying
sprays
via
groundboom
equipment
for
drench
applications
to
carnations
(
256
lb
ai/
A)
 
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator,
 
(
11)
mixing/
loading/
applying
liquid
concentrates
with
a
handgun
sprayer
applications
to
carnations
(
256
lb
ai/
A)
 
MOE
is
94
at
baseline
and
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator,
 
(
12)
mixing/
loading/
applying
wettable
powders
with
a
handgun
sprayer
for
drench
applications
to
carnations
(
256
lb
ai/
A)
and
for
drench
applications
to
ornamental
plants
(
72
lb
ai/
A)
 
risks
are
not
of
concern
with
engineering
controls
for
mixing/
loading
(
i.
e.,
water­
soluble
packaging)
and
the
addition
of
a
dust/
mist
respirator
for
application,
 
(
14)
mixing/
loading/
applying
dry
flowables
with
a
handgun
sprayer
for
drench
applications
to
carnations
(
256
lb
ai/
A)
 
risks
are
not
of
concern
with
engineering
controls
for
mixing/
loading
(
i.
e.,
water­
soluble
packaging)
and
the
addition
of
a
dust/
mist
respirator
for
application,
and
 
(
14)
mixing/
loading/
applying
dry
flowables
with
a
handgun
sprayer
for
drench
applications
to
ornamental
plants
(
72
lb
ai/
A)
 
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator.

ADBAC
can
be
used
on
ornamental
crops
in
greenhouse
and
outdoor
occupational
settings
and
on
also
on
turfgrass.
As
a
result,
individuals
can
potentially
be
exposed
by
working
in
areas
that
have
been
previously
treated.
The
occupational
postapplication
exposure
and
risk
assessment
for
ornamental
crop
uses
of
ADBAC
indicates
that
dermal
risks
are
of
concern
following
applications
applied
as
a
spray
for
the
three
application
rates.
When
applied
as
a
spray
for
ornamental
crops
uses,
dermal
risks
remain
of
concern
for
3
days
until
after
application
for
turf
application
at
the
lower
application
rate,
7
days
until
after
application
for
the
higher
rate
and
for
13
days
until
after
application
for
treating
plants.
Dermal
risks
also
remain
of
concern
following
applications
applied
as
a
drench
to
carnations
until
69
days
after
application
and
applied
as
a
drench
to
herbaceous
ornamentals
until
57
days
after
application.

$
Inhalation
exposures
are
thought
to
be
negligible
in
outdoor
postapplication
scenarios,
since
ADBAC
has
low
vapor
pressure
and
the
dilution
factor
in
an
outdoor
environment
is
considered
infinite.
In
addition,
under
the
Worker
Protection
Standard
for
Agricultural
Pesticides
B
WPS
B
(
40
CFR
170)
greenhouses
must
be
appropriately
ventilated
(
ventilation
criteria
are
provided)
following
pesticide
applications
so
that
postapplication
inhalation
exposures
are
minimal.
As
such,
inhalation
postapplication
exposures
are
not
considered
in
this
assessment.

It
has
been
determined
that
there
is
a
potential
for
exposure
in
residential
settings
during
the
application
process
for
homeowners
who
use
products
containing
ADBAC.
There
is
also
a
Page
6
of
46
potential
for
exposure
from
entering
ADBAC­
treated
areas,
such
as
residential
turfgrass,
home
gardens
and
greenhouses
that
could
lead
to
exposures
to
adults
and
children.
Risk
assessments
have
been
completed
for
both
residential
handler
and
postapplication
scenarios.

Risks
for
all
inhalation
scenarios
were
not
of
concern
for
residential
handlers.
One
dermal
scenario
for
residential
handlers
was
of
concern
when
the
end­
use
product
formulation
was
less
than
10
percent;
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
on
residential
turf
at
the
7
lb
ai/
A
rate
had
an
MOE
of
66.
When
the
end­
use
product
is
formulated
with
more
than
10%
ADBAC,
the
dermal
risks
for
residential
handlers
are
of
concern
for
ADBAC
residential
handler
scenarios
where
data
are
available
(
MOEs
range
from
4
to
55)
except
mixing/
loading/
applying
liquids
for
seedlings,
seeds
&
cuttings
with
watering
cans
(
MOE
­
280).

Short­
term
MOEs
were
calculated
for
adults
performing
tasks
in
home
greenhouses,
gardens
and
residential
turfgrass
following
applications
of
ADBAC,
and
for
toddlers
entering
treated
turfgrass.
Cancer
risks
were
not
calculated,
since
no
toxicological
endpoint
for
cancer
was
identified.
In
residential
settings,
the
Agency
does
not
use
restricted­
entry
intervals
or
other
mitigation
approaches
to
limit
postapplication
exposures,
because
they
are
viewed
as
impractical
and
not
enforceable.
As
such,
risk
estimates
on
the
day
of
application
are
the
key
concern.
Dermal
risks
were
calculated
for
adults
performing
tasks
in
home
greenhouses
and
gardens
and
on
home
lawns
following
applications
of
ADBAC.
The
dermal
MOEs
are
of
concern
(
i.
e.,
MOEs
 
100)
on
the
day
of
application
for
these
scenarios.
MOEs
range
from
41
to
79,
depending
on
the
application
rate.
Incidental
oral
ingestion
risks
were
calculated
for
toddlers
playing
on
treated
turf.
Only
one
scenario
­­
hand­
to­
mouth
activity
at
the
higher
application
rate
­­
had
MOEs
<
100.
Short­
term
MOEs
were
>
100
for
object­
to­
mouth
activities
and
incidental
soil
ingestion
and
for
hand­
to­
mouth
activity
at
the
lower
application
rate.
The
combined
risk
from
incidental
oral
ingestion
by
toddlers
following
applications
to
home
lawns
is
of
concern
with
an
MOE
of
76
for
the
higher
application
rate
on
treated
turf
(
7
lb
ai/
A),
but
not
a
concern
for
the
lower
application
rate
on
treated
turf
(
0.9
lb
ai/
A)
(
MOE
 
590).
Page
7
of
46
1.0
Occupational
and
Residential
Exposure/
Risk
Assessment
1.1
Purpose
ADBAC
(
Group
II
Quat
Cluster)
is
a
group
of
structurally
similar
quaternary
ammonium
compounds
("
quats")
that
are
characterized
by
having
a
positively
charged
nitrogen
covalently
bonded
to
three
alkyl
group
substituents
and
a
benzyl
substituent.
In
finished
form,
these
quats
are
salts
with
the
positively
charged
nitrogen
(
cation)
balanced
by
a
negatively
charged
molecule
(
anion).
The
most
common
anion
for
the
quats
in
this
cluster
is
chloride.
However,
other
anions,
such
as
saccharinate
and
bromide
are
also
used.
Most
of
the
registered
uses
of
ADBAC
are
classified
as
antimicrobial
uses
and
will
be
assessed
by
the
Antimicrobial
Division
in
EPA=
s
Office
of
Pesticide
Programs.

This
document
is
the
occupational
and
residential
exposure
assessment
for
ADBAC
from
its
use
to
control
plant
diseases
and
to
control
mosquito
larvae
in
standing
water.
In
this
document,
the
Agency
presents
the
results
of
its
review
of
the
potential
human
health
effects
of
occupational
and
residential/
nonoccupational
exposure
to
ADBAC.

1.2
Criteria
for
Conducting
Exposure
Assessments
An
occupational
and/
or
residential
exposure
assessment
is
required
for
an
active
ingredient
if
(
1)
certain
toxicological
criteria
are
triggered
and
(
2)
there
is
a
potential
for
exposure
to
handlers
(
mixers,
loaders,
applicators)
during
use
or
to
persons
entering
treated
sites
or
exposed
to
vapors
after
application
is
complete.
Toxicological
endpoints
were
selected
for
short­
term
dermal,
short­
and
intermediate­
term
inhalation,
and
incidental
oral
exposures
to
ADBAC.
There
is
a
significant
potential
for
exposure
in
a
variety
of
occupational
agricultural
and
commercial
settings
as
well
as
in
residential
settings.
Therefore,
risk
assessments
are
required
for
occupational
and
residential
handlers
as
well
as
for
occupational
and
residential
postapplication
exposures
that
can
occur
as
a
result
of
ADBAC
use.

1.3
Summary
of
Hazard
Concerns
for
ADBAC
The
toxicological
endpoints
used
to
complete
the
occupational
and
residential
risk
assessment
were
based
on
the
best
professional
judgment
of
EPA
toxicologists.
Adverse
effects
were
identified
at
durations
of
exposure
ranging
from
short­
term
(
up
to
30
days)
to
intermediateterm
durations
(
30
days
up
to
6
months)
and
long­
term
durations
(
greater
than
6
months).
No
cancer
endpoint
was
identified;
therefore,
cancer
risks
were
not
assessed.

ADBAC
is
used
to
control
plant
diseases
and
mosquito
larvae
where
the
use
patterns
can
range
from
short­
term
through
intermediate­
term
exposure
durations.
Endpoints
were
selected
from
the
ADBAC
hazard
database
to
address
each
of
these
durations
of
exposure.
ADBAC
exposures
are
expected
to
occur
to
both
occupational
and
residential
users.
Page
8
of
46
Dermal
Route:

No
short­
or
intermediate­
term
dermal
endpoint
for
systemic
effects
was
selected
for
ADBAC,
since
no
systemic
effects
were
identified
up
to
20
mg/
kg/
day,
which
is
the
highest
dose
tested
before
irritation
became
significant.
However,
short­
term
dermal
irritation
endpoints
were
identified
for
ADBAC.
The
short­
term
endpoint
for
a
formulated
product
(
500
mg/
kg/
day
which
is
equivalent
to
7,750
µ
g/
cm2)
was
determined
from
a
21­
day
dermal
toxicity
in
guinea
pigs
where
a
denuded
non­
vascularized
epidermal
layer
was
observed
at
1,000
mg/
kg/
day.
The
short­
term
dermal
endpoint
for
the
technical
grade
active
ingredient
(
TGAI
 
80%
ai)
(
20
mg/
kg/
day
which
is
equivalent
to
40
µ
g/
cm2)
was
determined
from
90­
day
dermal
toxicity
in
rats.
No
intermediateor
long­
term
dermal
irritation
endpoints
were
identified
for
ADBAC.
.
Inhalation
Route:

For
short­
and
intermediate­
term
inhalation
exposures
to
ADBAC,
a
NOAEL
of
3
mg/
kg/
day
was
derived
from
a
prenatal
developmental
toxicity
study
in
rabbits.
The
LOAEL
of
9
mg/
kg/
day
was
based
clinical
signs
of
toxicity
at
9
mg/
kg/
day
in
maternal
rabbits.
Long­
term
inhalation
exposure
to
ADBAC
(
i.
e.,
greater
than
6
months)
is
not
expected
for
current
registered
uses.
It
was
assumed
that
inhalation
absorption
is
equivalent
to
oral
absorption
(
i.
e.­
100%).

Incidental
Oral
Route:

The
short­
term
incidental
oral
risk
assessment
for
ADBAC
is
based
on
a
NOAEL
of
10
mg/
kg/
day,
derived
a
prenatal
developmental
toxicity
study
in
rats.
The
LOAEL
(
100
mg/
kg/
day)
was
based
decreased
body
weight
and
food
consumption.

Level
of
Concern
(
LOC)

The
level
of
concern
(
LOC)
for
occupational
and
residential
ADBAC
dermal,
inhalation,
and
incidental
oral
exposures
was
an
MOE
of
less
than
100.
The
level
of
concern
is
based
on
10x
for
interspecies
extrapolation,
and
10x
for
intraspecies
variation.

Body
Weight
Since
the
toxicological
endpoint
for
inhalation
is
female­
specific,
a
body
weight
of
60
kilograms
was
used
in
the
assessment.
This
value
represents
the
average
body
weight
of
an
adult
female.
For
calculating
dermal
exposure
risk,
the
unit
was
based
on
the
treatment
area
(
e.
g.­
µ
g/
cm2).
For
incidental
oral
assessments,
15
kilograms
is
used
to
represent
a
toddler's
body
weight.

Aggregation
The
dermal
and
inhalation
margins
of
exposure
were
not
combined
for
the
ADBAC
risk
assessment
because
the
toxicity
endpoints
for
the
dermal
and
inhalation
routes
of
exposure
were
Page
9
of
46
based
on
different
toxicological
effects.
The
incidental
oral
risks
for
hand­
to­
mouth,
object­
tomouth
and
soil
ingestion
were
combined,
because
the
same
endpoint
is
used
for
each
of
these
assessments.

Cancer
No
cancer
endpoint
was
identified.

Acute
Toxicity
ADBAC
has
a
low
order
of
acute
oral
toxicity
(
Toxicity
Category
III
and
IV),
dermal
toxicity
(
Toxicity
Category
III
and
IV),
and
inhalation
toxicity
(
Toxicity
Category
III
and
IV).
However,
it
is
severely
irritating
to
the
skin
and
eyes
(
Toxicity
Category
I
labeling
is
routinely
applied
to
products
containing
ADBAC.
ADBAC
is
not
known
to
be
a
dermal
sensitizer.
The
acute
toxicity
profile
for
ADBAC
is
presented
in
Table
1.

Table
1.
Acute
Toxicity
Profile
­
ADBAC
Guideline
No.
Study
Type
MRID(
s)
Results
Toxicity
Category
870.1100
Acute
oral,
rat
BQ451­
8
Biocide
(
Purity
82.26%)
45109204
LD50
=
304.5
mg/
kg
(
combined)
LD50
=
510.9
mg/
kg
(
males)
LD50
=
280.8
mg/
kg
(
females)
II
870.1200
Acute
dermal,
rat
BQ451­
8
Biocide
(
Purity
82.26%)
45109202
LD50
=
930
mg/
kg
(
combined)
LD50
=
1100
mg/
kg
(
males)
LD50
=
704
mg/
kg
(
females)
III
870.1300
Acute
inhalation,
rat
(
Purity
82.26%)
44885201
0.054
<
LC50
<
0.51
mg/
L
II
870.2400
Primary
Eye
Irritation
Waived
N/
A
I
870.2500
Primary
Dermal
Irritation,
,
rabbit
BQ451­
8
Biocide
(
Purity
82.26%)
45109201
Corrosive
I
870.2600
Dermal
sensitization,
guinea
pigs
BQ451­
8
Biocide
(
Purity
82.26%)
45109201
Not
a
dermal
sensitizer
N/
A
Page
10
of
46
TABLE
2.
Summary
of
Toxicological
Endpoints
­
ADBAC
Exposure
Scenario
Dose
Used
in
Risk
Assessment
(
mg/
kg/
day)
Endpoint
Study
Acute
Dietary
An
acute
dietary
endpoint
was
not
identified
in
the
database.
This
risk
assessment
is
not
required.

Decreased
body
weight
and
weight
gain
at
88
mg/
kg/
day.
Chronic
toxicity/
carcinogenicity
­
rat
Chronic
Dietary
NOAEL
=
44
mg/
kg/
day
UF
=
100
Chronic
RfD
=
0.44
mg/
kg/
day
Incidental
Oral
(
short­
term)
NOAEL
=
10
mg/
kg/
day
MOE
=
100
Decreased
body
weight
and
food
consumption
at
100
mg/
kg/
day
Developmental
Toxicity
­
Rat
Incidental
Oral
(
intermediate­
term)
NOAEL
=
44
mg/
kg/
day
MOE
=
100
Decreased
body
weight
and
weight
gain
at
88
mg/
kg/
day
Chronic
toxicity/
carcinogenicity
­
rat
Short­
Term
Dermal­
formulated
product
NOAEL=
500
mg/
kg/
day
(
7750
µ
g/
cm2)
a
MOE
=
100
Denuded
non­
vascularized
epidermal
layer
observed
at
1000
mg/
kg/
day.
21­
day
dermal
toxicity­
guinea
pigs
(
MRID
41105801)

Short­
term
dermal
technical
grade
a.
i.
NOAEL
=
20
mg/
kg/
day
(
40
µ
g/
cm2)
b
MOE
=
100
20
mg/
kg/
day
is
the
highest
dose
tested
before
irritation
became
significant.
90­
day
dermal
toxicity
in
rats
(
MRID
41499601)

Intermediate­
Term
(
Dermal)
No
appropriate
endpoint
identified.
No
systemic
effects
observed
up
to
20
mg/
kg/
day,
highest
dose
of
technical
grade
that
could
be
tested
without
irritation
effects.

Long­
Term
(
Dermal)
No
appropriate
endpoint
identified.
No
systemic
effects
observed
up
to
20
mg/
kg/
day,
highest
dose
of
technical
grade
that
could
be
tested
without
irritation
effects.

Inhalationa
(
All
exposure
durations)
NOAEL=
3
mg/
kg/
day
MOE
=
100
Clinical
signs
of
toxicity
at
9
mg/
kg/
day
in
maternal
rabbits.
(
10x
inter­
species
extrapolation,
10x
intra­
species
variation)
c
Developmental
toxicity
­
rabbit
a
Formulated­
based
dermal
endpoint
=
(
500
mg/
kg
guinea
pig
x
0.4
kg
guinea
pig
x
1000
ug/
mg)
/
25.8
cm2
treated
area
=
7,750
µ
g/
cm2
.
b
TGAI­
based
dermal
endpoint
=
(
20
mg/
kg
rat
x
0.2
kg
rat
x
1000
ug/
mg)
/
100
cm2
treated
area
=
40
µ
g/
cm2
.
C
an
additional
uncertainty
factor
of
10x
is
used
for
route
extrapolation
from
an
oral
endpoint.

1.4
Incident
Reports
The
incident
report
is
being
prepared
under
a
separate
memo
by
Jonathan
Chen,
of
the
Office
of
Pesticide
Programs.
Page
11
of
46
1.5
Summary
of
Use
Patterns
and
Formulations
1.5.1
End­
Use
Products
ADBAC
(
Group
II
Quat
Cluster)
is
a
group
of
structurally
similar
quaternary
ammonium
compounds
("
quats").
It
is
used
in
agricultural,
commercial,
and
residential
settings.
ADBAC
is
formulated
as
a
soluble
concentrate,
emulsifiable
concentrate,
ready­
to­
use
solution,
pressurized
liquid,
wettable
powder,
water
soluble
packet,
flowable
concentrate,
microencapsulated
and
impregnated
material.
Note
that
there
are
many
end­
use
products
that
contain
ADBAC
and
each
label
could
not
be
reviewed
to
determine
the
formulation­
type
and
the
registered
uses.
Also
note
that
the
Master
Label
does
not
indicate
the
formulation
types
that
were
registered
for
individual
use­
patterns.
Therefore,
as
a
conservative
approach,
this
chapter
will
assume
that
ADBAC
when
used
to
control
plant
diseases
may
be
formulated
as
a
liquid
concentrate,
a
dry
flowable,
and
a
wettable
powder.
For
mosquito
control,
it
is
assume
that
it
is
formulated
as
a
liquid
concentrate
only,
since
it
is
designed
to
be
poured
into
the
water
to
be
treated.

1.5.2
Registered
Use
Categories
and
Sites
An
analysis
of
the
current
labeling
and
available
use
information
was
completed
by
the
Antimicrobial
Division.
ADBAC
is
registered
for
use
in
a
variety
of
occupational
and
residential
scenarios
and
thus
both
occupational
and
residential
populations
could
be
potentially
exposed
while
performing
ADBAC
applications.
It
is
also
possible
for
occupational
and
residential
populations
to
be
exposed
to
ADBAC
during
postapplication
scenarios.
Tables
3a
and
3b
provide
a
summary
of
the
maximum
application
rates,
equipment,
and
amounts
handled
daily
for
registered
ADBAC
uses.
Page
12
of
46
Table
3a:
Occupational
Uses
of
ADBAC
Target
Formulation
Type
Application
Rate
Application
Equipment
Area
Treated
or
Amount
Applied
0.9
lb
ai/
A
Groundboom
80
acres
Sodfarm
turf
LC,
WP,
DF
7
lb
ai/
A
Low
pressure
handwand
sprayer,
Handgun
sprayer
5
acres
0.9
lb
ai/
A
Groundboom
80
acres
Low
pressure
handwand
sprayer,
40
gallons
Golf
Course,
Residential,
and
Commercial
Turf
LC,
WP,
DF
0.0065
lb
ai/
A
&
7
lb
ai/
A
Handgun
sprayer
5
acres
Handgun
sprayer
5
acres
Low­
pressure
handwand
sprayer
40
gallons
0.0065
lb
ai/
gal
&
(
assume
0.65
lb
ai/
A)
High­
pressure
handwand
sprayer
1000
gallons
Low­
pressure
handwand,
40
gallons
Handgun
5
acres
0.0065
lb
ai/
gal
&
72
lb
ai/
A
(
drench)
Groundboom
20
acres
Ornamental
herbaceous
plants
LC,
WP,
DF
0.0065
lb
ai/
gal
Dip
or
Soak
100
gallons
Trigger
pump
sprayer
1
gallon
Low­
pressure
handwand
sprayer
40
gallons
Ornamental
Shrubs
LC,
WP,
DF
0.0043
lb
ai/
gal
(
assume
0.43
lb
ai/
A)
Handgun
sprayer,
Highpressure
handwand
sprayer
1000
gallons
Low­
pressure
handwand
sprayer
40
gallons
Handgun
sprayer,
5
acres
High­
pressure
handwand
sprayer
1000
gallons
Ornamental
Trees
LC,
WP,
DF
0.0065
lb
ai/
gal
(
assume
0.65
lb
ai/
A)

Airblast
sprayer
20
acres
Low­
pressure
handwand
sprayer
40
gallons
Handgun
sprayer
5
acres
Seedlings
(
planted
in
field)
LC,
WP,
DF
0.0043
lb
ai/
gal
(
assume
0.43
lb
ai/
A)
Groundboom
20
acres
Seedlings,
Seeds,
Cuttings
(
preplant
LC,
WP,
DF
0.0043
lb
ai/
gal
Low­
pressure
handwand
sprayer
40
gallons
Page
13
of
46
Table
3a:
Occupational
Uses
of
ADBAC
Target
Formulation
Type
Application
Rate
Application
Equipment
Area
Treated
or
Amount
Applied
Dip
or
Soak
100
gallons
Sprinkling
can
5
gallons
or
at
plant)

Trigger­
pump
sprayer
1
gallons
Ornamental
Palms
LC,
WP,
DF
0.013
lb
ai/
gal
Sprinkling
can
5
gallons
Low­
pressure
handwand,
40
gallons
Handgun
5
acres
Carnations
(
drench)
LC,
WP,
DF
0.0235
lb
ai/
gal
&
256
lb
ai/
A
(
drench)
Groundboom
20
acres
Sprinkling
can
5
gallons
of
enduse
product
(
20%
ai)

Handgun
sprayer
1000
gallons
of
end­
use
product
(
20%
ai)
Mosquito
control
in
fountains,
water
displays,
decorative
pools,
decorative
ponds,
sewage
treatment
systems,
spas,
hot
tubs,
swimming
pools
and
standing
water
LC
0.0017
lb
ai/
gal
of
water
to
be
treated;

Pools
=
20,000
gal
Hot
tubs
=
1000
gal
Boom
sprayer
over
pond
(
groundboom
sprayer
as
surrogate)
800,000
gallons
100,000
gallons
and
20,000
gallons
LC
=
liquid
concentrate,
WP
=
wettable
powder
,
DF
=
dry
flowable.
Page
14
of
46
Table
3b:
Residential
Uses
of
ADBAC
Target
Formulation
Type
Application
Rate
Application
Equipment
Area
Treated
or
Amount
Applied
Low
pressure
handwand
sprayer
5
gallons
Residential
Turf
LC,
WP,
DF
0.0065
lb
ai/
gal
&
7
lb
ai/
A
Hose­
end
sprayer
0.5
acres
Low
pressure
handwand
sprayer
5
gallons
Ornamental
Bulbs
&
Orchids
LC,
WP,
DF
0.0065
lb
ai/
gal
&
(
assume
0.43
lb
ai/
A)
Dip
or
Soak
5
gallons
Low
pressure
handwand
sprayer
5
gallons
Hose­
end
sprayer
¼
acre
Ornamental
Herbaceous
Plants
LC,
WP,
DF
0.0043
lb
ai/
gal
&
(
assume
0.43
lb
ai/
A)
Dip
or
Soak
5
gallons
Trigger
pump
sprayer
1
gallon
Low­
pressure
handwand
sprayer
5
gallons
Ornamental
Shrubs
LC,
WP,
DF
0.0043
lb
ai/
gal
(
assume
0.43
lb
ai/
A)
Hose­
end
sprayer
¼
acre
Low­
pressure
handwand
sprayer
5
gallons
Ornamental
Trees
LC,
WP,
DF
0.0043
lb
ai/
gal
(
assume
0.43
lb
ai/
A)
Hose­
end
sprayer
¼
acre
Low­
pressure
handwand
sprayer
5
gallons
Seedlings
(
planted
in
garden)
LC,
WP,
DF
0.0043
lb
ai/
gal
(
assume
0.43
lb
ai/
A)
Hose­
end
sprayer
¼
acre
Low­
pressure
handwand
sprayer
5
gallons
Dip
or
Soak
5
gallons
Sprinkling
can
5
gallons
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
LC,
WP,
DF
0.0043
lb
ai/
gal
Trigger­
pump
sprayer
1
gallons
Ornamental
Palms
LC,
WP,
DF
0.013
lb
ai/
gal
Sprinkling
can
5
gallons
Mosquito
control
in
fountains,
water
displays,
decorative
pools,
decorative
ponds,
sewage
treatment
systems,
spas,
hot
tubs,
swimming
pools
and
standing
water
LC
0.0017
lb
ai/
gal
of
water
to
be
treated;

Pools
=
20,000
gal
Hot
tubs
=
1000
gal
Sprinkling
can
5
gallons
of
enduse
product
(
20%
ai)

LC
=
liquid
concentrate,
WP
=
wettable
powder
,
DF
=
dry
flowable.
Page
15
of
46
1.5.3
Application
Methods
ADBAC
is
applied
with
several
types
of
application
equipment
including
groundboom
sprayers,
airblast
sprayers,
low­
pressure
and
high­
pressure
handwand
sprayers,
handgun
sprayers,
hose­
end
sprayers,
watering
cans,
pump­
trigger
sprayers,
and
by
dipping
or
soaking
plants
or
plant
parts.

2.0
Occupational
Exposures
and
Risks
There
is
a
potential
for
exposure
to
ADBAC
in
occupational
scenarios
from
handling
ADBAC
products
during
the
application
process
(
i.
e.,
mixer/
loaders,
applicators,
and
mixer/
loader/
applicators)
and
a
potential
for
postapplication
worker
exposure
from
entering
into
areas
previously
treated
with
ADBAC.
As
a
result,
exposure
scenarios
have
been
completed
for
occupational
handler
scenarios
as
well
as
occupational
postapplication
scenarios.

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

The
Agency
uses
exposure
scenarios
to
describe
the
various
types
of
handler
exposures
that
may
occur
for
a
specific
active
ingredient.
The
use
of
scenarios
as
a
basis
for
exposure
assessment
is
very
common
as
described
in
the
U.
S.
EPA
Guidelines
for
Exposure
Assessment
(
U.
S.
EPA;
Federal
Register
Volume
57,
Number
104;
May
29,
1992).
Information
from
the
current
labels,
use
and
usage
information,
toxicology
data,
and
exposure
data
were
all
key
components
in
the
development
of
the
exposure
scenarios.
The
Agency
has
developed
a
series
of
general
descriptions
for
tasks
that
are
associated
with
pesticide
applications.
Tasks
associated
with
occupational
pesticide
handlers
are
categorized
using
one
of
the
following
terms:

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

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

$
Mixer/
Loader/
Applicators
and
or
Loader/
Applicators:
These
individuals
are
involved
in
the
entire
pesticide
application
process
(
i.
e.,
they
do
all
job
functions
related
to
a
pesticide
Page
16
of
46
application
event).
These
individuals
would
transfer
ADBAC
into
the
application
equipment
and
then
also
apply
it.

A
chemical
can
produce
different
effects
based
on
how
long
a
person
is
exposed,
how
frequently
exposures
occur,
and
the
level
of
exposure.
The
Agency
classifies
exposures
up
to
30
days
as
short­
term
and
exposures
greater
than
30
days
up
to
several
months
as
intermediate­
term.
The
Agency
completes
both
short­
and
intermediate­
term
assessments
for
occupational
scenarios
in
essentially
all
cases,
because
these
kinds
of
exposures
are
likely
and
acceptable
use/
usage
data
are
not
available
to
justify
deleting
intermediate­
term
scenarios.
Based
on
use
data
and
label
instructions,
the
Agency
believes
that
occupational
ADBAC
exposures
may
occur
over
a
single
day
or
up
to
weeks
at
a
time
for
many
use­
patterns
and
that
intermittent
exposure
over
several
weeks
also
may
occur.
Some
applicators
may
apply
ADBAC
over
a
period
of
weeks,
because
they
are
custom
or
commercial
applicators
who
are
completing
a
number
of
applications
for
a
number
of
different
clients.
Long­
term
handler
exposures
are
not
expected
to
occur
for
ADBAC.

Other
parameters
are
also
defined
from
use
and
usage
data
such
as
application
rates
and
application
frequency.
The
Agency
typically
completes
exposure
assessments
using
maximum
application
rates
for
each
scenario
to
ensure
there
are
no
concerns
for
each
specific
use.

Occupational
handler
exposure
assessments
are
completed
by
the
Agency
using
different
levels
of
risk
mitigation.
Typically,
the
Agency
uses
a
tiered
approach.
The
lowest
tier
is
designated
as
the
baseline
exposure
scenario
(
i.
e.,
no
respirator).
If
risks
are
of
concern
at
baseline
attire,
then
increasing
levels
of
personal
protective
equipment
or
PPE
(
e.
g.,
respirators)
are
evaluated.
If
risks
remain
of
concern
with
maximum
PPE,
then
engineering
controls
(
e.
g.,
enclosed
cabs,
water­
soluble
packaging,
and
closed
mixing/
loading
systems)
are
evaluated.
This
approach
is
used
to
ensure
that
the
lowest
level
of
risk
mitigation
that
provides
adequate
protection
is
selected,
since
the
addition
of
PPE
and
engineering
controls
involves
an
additional
expense
to
the
user
and
B
in
the
case
of
PPE
B
also
involves
an
additional
burden
to
the
user
due
to
decreased
comfort
and
dexterity
and
increased
heat
stress
and
respiratory
stress.

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

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

$
The
toxicological
endpoint
of
concern
for
dermal
risks
is
from
a
dermal
study;
with
the
effects
being
irritation
(
no
systemic
effects
were
observed).
Therefore,
no
dose
is
Page
17
of
46
calculated
and
no
body
weight
is
used
to
complete
the
dermal
exposure
assessment.
The
toxicological
endpoint
of
concern
for
inhalation
risks
is
from
a
prenatal
developmental
toxicity
study;
with
the
effects
seen
in
females;
therefore,
the
average
body
weight
of
an
adult
female
(
i.
e.,
60
kg)
is
used
to
complete
the
inhalation
risk
assessment.

$
Generic
protection
factors
(
PFs)
were
used
to
calculate
exposures
when
data
were
not
available.
For
example,
an
80
percent
protection
factor
was
assumed
for
the
use
of
a
respirator
equipped
with
a
quarter­
face
dust/
mist
filter.

$
Exposure
factors
used
to
calculate
daily
exposures
to
handlers
are
based
on
applicable
data,
if
available.
For
lack
of
appropriate
data,
values
from
a
scenario
deemed
similar
enough
by
the
assessor
might
be
used.
For
example,
ORETF
data
for
hose­
end
sprayers
is
used
as
a
surrogate
for
inhalation
unit
exposures
for
mixing/
loading/
applying
with
a
sprinkling
can.

$
The
Agency
typically
assumes
the
maximum
application
rates
allowed
by
labels
in
its
risk
assessments
(
see
Table
3a/
b).

$
The
average
occupational
workday
is
assumed
to
be
8
hours.

$
The
daily
areas
treated
were
defined
for
each
handler
scenario
(
in
appropriate
units)
by
determining
the
amount
that
can
be
reasonably
treated
in
a
single
day
(
e.
g.,
acres
or
gallons
per
day).
When
possible,
the
assumptions
for
daily
areas
treated
are
taken
from
the
Health
Effects
Division
Science
Advisory
Committee
on
Exposure
SOP
#
9:
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,
which
was
completed
on
July
5,
2000.
However,
no
standard
values
are
available
for
numerous
scenarios.
Assumptions
for
these
scenarios
are
based
on
the
Agency
estimates
and
could
be
further
refined
from
input
from
affected
sectors.

$
For
mosquito
larvae
uses
in
standing
water,
application
rates
are
provided
on
the
label
only
in
terms
of
pounds
active
ingredient
per
gallon
of
water
to
be
treated.
The
Agency
has
no
specific
information
about
the
gallons
of
water
likely
in
a
decorative
pond
or
sewage
treatment
system.
Risks
were
assessed
based
on
a
rangefinder
of
gallons
of
treated
water
that
might
be
applied
per
day.
The
rangefinder
includes:
800,000
gallons,
100,000
gallons,
and
20,000
gallons.

There
are
data
gaps
that
have
been
identified
for
some
ADBAC
applications.
Each
is
identified
in
the
calculation
tables
and
is
also
noted
in
the
summary
of
risk
calculations.

2.1.1.2
Exposure
Data
for
Handler
Exposure
Scenarios
The
Agency
uses
unit
exposure
to
assess
handler
exposures
to
pesticides.
Unit
exposures
Page
18
of
46
are
estimates
of
the
amount
of
exposure
to
an
active
ingredient
a
handler
receives
while
performing
various
handler
tasks
and
are
expressed
in
terms
of
micrograms
or
milligrams
of
active
ingredient
per
pounds
of
active
ingredient
handled.
The
Agency
has
developed
a
series
of
unit
exposures
that
are
unique
for
each
scenario
typically
considered
in
our
assessments
(
i.
e.,
there
are
different
unit
exposures
for
different
types
of
application
equipment,
job
functions,
and
levels
of
protection).
The
unit
exposure
concept
has
been
established
in
the
scientific
literature
and
also
through
various
exposure
monitoring
guidelines
published
by
the
U.
S.
EPA
and
international
organizations
such
as
Health
Canada
and
OECD
(
Organization
for
Economic
Cooperation
and
Development).

Unit
exposures
values
have
been
taken
from
both
the
Pesticide
Handler
Exposure
Database
(
PHED)
and
studies
provided
by
the
Outdoor
Residential
Exposure
Task
Force
(
ORETF)
where
the
scenario
unit
exposure
values
are
more
applicable.
Appendix
A
contains
background
information
on
PHED
and
ORETF.

Once
the
data
for
a
given
exposure
scenario
have
been
selected,
the
data
are
normalized
(
i.
e.,
divided
by)
by
the
amount
of
pesticide
handled
resulting
in
standard
unit
exposures
(
milligrams
of
exposure
per
pound
of
active
ingredient
handled).
Following
normalization,
the
data
are
statistically
summarized.
The
distribution
of
exposure
for
each
body
part
(
e.
g.,
chest,
upper
arm)
is
categorized
as
normal,
lognormal,
or
"
other"
(
i.
e.,
neither
normal
nor
lognormal).
A
central
tendency
value
is
then
selected
from
the
distribution
of
the
exposure
for
each
body
part.
These
values
are
the
arithmetic
mean
for
normal
distributions,
the
geometric
mean
for
lognormal
distributions,
and
the
median
for
all
"
other"
distributions.
Once
selected,
the
central
tendency
values
for
each
body
part
are
composited
into
a
Abest
fit@
exposure
value
representing
the
entire
body.

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

A
report
was
submitted
by
the
ORETF
(
Outdoor
Residential
Exposure
Task
Force)
that
presented
data
in
which
the
application
of
various
products
used
on
turf
by
homeowners
and
lawncare
operators
(
LCOs)
was
monitored.
All
of
the
data
submitted
in
this
report
were
completed
in
a
series
of
studies.
ORETF
conducted
a
mixer/
loader/
applicator
study
applying
a
pesticide
to
turf
with
a
low
pressure
handgun
sprayer.
The
unit
exposures
relevant
to
the
Page
19
of
46
residential
assessment
are
summarized
below
in
Table
4.
The
unit
exposures
relevant
to
the
residential
assessment
from
the
LCO
exposure
scenarios
using
a
low
pressure,
high
volume
turf
handgun
(
ORETF
Study
OMA002)
are
summarized
below
(
Table
5)
as
is
the
study
(
ORETF
Study
OMA004)
that
monitored
homeowner
exposures
while
using
a
hose­
end
sprayer
(
Table
6).

Table
4:
Unit
Exposure
Values
Obtained
for
LCO
Liquid
Applications
with
a
Low
Pressure
Handgun
from
ORETF
Handgun
Studies
(
MRID
449722­
01)

Application
Method3
Inhalation
Unit
Exposure1,2
(
Fg/
lb
ai)

LCO
Handgun
Spray
Mixer/
Loader/
Applicator
Liquid
Flowable
1.5
LCO
Handgun
Spray
Mixer/
Loader/
Applicator
Water
Dispersable
Granule
22
LCO
Handgun
Spray
Mixer/
Loader/
Applicator
Wettable
Powder
in
Water
Soluble
Bags
7.2
LCO
Handgun
Spray
Mixer/
Loader/
Applicator
Wettable
Powder
64
LCO
Handgun
Spray
Applicator
Only
Wettable
Powder
1.0
1
Unit
exposure
values
reported
are
geometric
means.
2
Air
concentrations
(
mg/
m3/
lb
ai)
calculated
using
NAFTA
>

99
standard
breathing
rate
of
17
lpm
(
1
m3/
hr).
3
All
commercial
handlers
wore
long
pants,
long­
sleeved
shirt,
nitrile
gloves
and
shoes.

Table
5.
Unit
Exposure
Values
for
Homeowner
Liquid
Applications
with
a
Ready­
touse
Hose­
end
Sprayer
and
a
Dial
Type
Hose­
end
Sprayer
Obtained
From
ORETF
Study
(
MRID
449722­
01)

Scenario
Monitored
Inhalation
Unit
Exposure1,2
(
Fg/
lb
ai)

Homeowner
Liquid
Applications
with
a
Ready­
to­
use
Hose­
end
Sprayer
11
Homeowner
Liquid
Applications
with
a
Dial
Type
Hose­
end
Sprayer
(
Mixyour
own)
17
1
Unit
exposure
values
reported
are
geometric
means.
2
Air
concentrations
(
mg/
m3/
lb
ai)
calculated
using
NAFTA
99
standard
breathing
rate
of
17
lpm
(
1
m3/
hr).
Page
20
of
46
Table
6.
Unit
Exposure
Values
for
Homeowner
Liquid
Application
to
Garden
with
a
Dial
type
Sprayer,
a
Low
Pressure
Handwand
and
a
Ready­
to­
use
Bottle
Obtained
From
ORETF
Study
(
MRID
444598­
01)

Scenario
Monitored
Inhalation
Unit
Exposure1
(
Fg/
lb
ai)

Homeowner
Liquid
Applications
with
a
Low
Pressure
Handwand
Sprayer
2.7
Homeowner
Liquid
Applications
with
a
Ready­
to­
Use
Sprayer
19
Homeowner
Liquid
Applications
with
a
Hose­
end
Sprayer
0.82
1
Unit
exposure
values
reported
are
geometric
means.

2.1.1.3
ADBAC
Handler
Exposure
Scenarios
It
has
been
determined
that
exposure
to
pesticide
handlers
is
likely
during
the
occupational
use
of
ADBAC
in
a
variety
of
occupational
environments.
The
anticipated
use
patterns
and
current
labeling
indicate
several
occupational
exposure
scenarios
based
on
the
types
of
equipment
and
techniques
that
can
potentially
be
used
for
ADBAC
applications.

ADBAC
inhalation
exposure
was
estimated
using
PHED
or
ORETF
data.
Risks
were
calculated
by
comparing
the
inhalation
dose
to
the
short­
and
intermediate­
term
NOAEL
to
determine
the
margin
of
exposure
(
MOE).

ADBAC
dermal
exposures
and
risks
were
not
estimated
for
occupational
handler
exposures.
Instead,
dermal
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
ADBAC
that
result
in
classification
of
category
I
or
II
for
skin
irritation
potential
will
be
long­
sleeve
shirt,
long
pants,
shoes,
socks,
chemical­
resistant
gloves,
and
chemical­
resistant
apron.
The
minimum
PPE
required
for
mixers,
loaders,
and
others
exposed
to
end­
use
products
containing
concentrations
of
ADBAC
that
result
in
classification
of
category
III
for
skin
irritation
potential
will
be
long­
sleeve
shirt,
long
pants,
shoes,
socks,
and
chemical­
resistant
gloves.
Once
diluted,
if
the
concentration
of
ADBAC
in
the
diluted
solution
would
result
in
classification
of
toxicity
category
IV
for
skin
irritation
potential,
then
the
chemical­
resistant
gloves
and
chemical­
resistant
apron
can
be
eliminated
for
applicators
and
others
exposed
to
the
dilute.
Note
that
chemical­
resistant
eye
protection
will
be
required
if
the
end­
use
product
is
classified
as
category
I
or
II
for
eye
irritation
potential.

The
quantitative
inhalation
exposure
and
risk
assessment
developed
for
occupational
handlers
is
based
on
the
following
scenarios.
[
Note:
The
scenario
numbers
correspond
to
the
Page
21
of
46
tables
of
risk
calculations
included
in
the
occupational
risk
calculation
aspects
of
the
appendices.]

Mixer/
Loader/
Applicators:
 
Mixing/
Loading
Liquids
Concentrates
for
Groundboom
Applications
(
PHED)
(
1a)
 
Mixing/
Loading
Liquid
Concentrates
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
(
PHED)
(
1b)
 
Mixing/
Loading
Liquids
Concentrates
for
Airblast
Applications
(
PHED)
(
1c)
 
Mixing/
Loading
Liquid
Concentrates
via
Dip
or
Soak
(
PHED)
(
1d)
 
Mixing/
Loading
Wettable
Powders
for
Groundboom
Applications
(
PHED)
(
2a)
 
Mixing/
Loading
Wettable
Powders
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
(
PHED)
(
2b)
 
Mixing/
Loading
Wettable
Powders
for
Airblast
Applications
(
PHED)
(
2c)
 
Mixing/
Loading
Wettable
Powders
via
Dip
or
Soak
(
PHED)
(
2d)
 
Mixing/
Loading
Dry
Flowables
for
Groundboom
Applications
(
PHED)
(
3a)
 
Mixing/
Loading
Dry
Flowables
for
Airblast
Applications
(
PHED)
(
3b)
 
Mixing/
Loading
Dry
Flowables
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
(
PHED)
(
3c)
 
Mixing/
Loading
Dry
Flowables
via
Dip
or
Soak
(
PHED)
(
3d)
 
Applying
Sprays
via
Groundboom
Equipment
(
PHED)
(
4)
 
Applying
Sprays
via
Airblast
Equipment
(
PHED)
(
5)
 
Applying
Sprays
via
Handgun
Equipment
(
PHED)
(
6)
 
Applying
as
a
Soak
or
Dip
(
no
data)
(
7)
 
Mixing/
Loading/
Applying
Liquid
Concentrates
with
Low
Pressure
Handwand
(
ORETF
data)
(
8)
 
Mixing/
Loading/
Applying
Wettable
Powders
with
Low
Pressure
Handwand
(
PHED
data)
(
9)
 
Mixing/
Loading/
Applying
Dry
Flowables
with
Low
Pressure
Handwand
(
using
liquid
concentrate
ORETF
data)
(
10)
 
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
(
11)
 
Mixing/
Loading/
Applying
Wettable
Powders
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
(
12)
 
Mixing/
Loading/
Applying
Water
Soluble
Bags
with
Handgun
Sprayer
(
LCO
ORETF
data)
(
13)
 
Mixing/
Loading/
Applying
Dry
Flowables
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
(
14)
 
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
High
Pressure
Handwand
(
PHED)
(
15)
 
Applying
Ready
to
Use
Formulations
via
Trigger­
Pump
Sprayer
(
ORETF)
(
16)
 
Mixing/
Loading/
Applying
Liquids
with
a
Watering
Can
(
using
ORETF
residential
hoseend
data)
(
17)
 
Mixing/
Loading/
Applying
Dip
or
Soak
(
no
data)
(
18)
Page
22
of
46
2.1.2
ADBAC
Handler
Exposure
and
Assessment
2.1.2.1
ADBAC
Handler
Exposure
and
Risk
Calculations
Handler
risks
(
i.
e.
MOEs)
were
calculated
as
described
in
Appendix
A.
The
basic
rationale
for
these
calculations
is
that
the
daily
exposure
is
the
product
of
the
amount
of
ai
handled
per
day
times
a
unit
exposure
value.
The
MOEs
were
calculated
for
short/
intermediate
term
dermal
and
inhalation
exposures.
These
MOEs
were
calculated
separately
because
the
dermal
and
inhalation
endpoints
were
based
upon
different
effects.
A
MOE
greater
than
100
indicates
the
risk
is
not
of
concern
for
that
scenario.

2.1.2.2
ADBAC
Risk
Summary
The
short­
and
intermediate­
term
risks
for
each
inhalation
exposure
scenario
are
presented
in
Table
7
and
details
are
presented
in
Appendix
B.

Short­
and
Intermediate­
term
Inhalation
Risks
In
all
occupational
handler
scenarios,
inhalation
MOEs
are
above
the
level
of
concern
of
100
at
baseline
(
i.
e.,
no
respirator),
except
for
those
identified
in
Section
2.1.4.1.
In
the
case
that
the
MOE
is
below
1000,
the
Agency
may
request
a
confirmatory
inhalation
toxicity
study
inhalation
toxicity
study
according
to
AD's
policy
(
oral
communication
from
Tim
Leighton).

Short­
and
Intermediate­
term
Total
Risks
Since
no
dermal
endpoint
for
systemic
toxicological
effects
was
selected,
no
dermal
doses
were
estimated.
Therefore,
no
combined
dermal
and
inhalation
risks
were
calculated.
Page
23
of
46
TABLE
7.
ADBAC:
Occupational
Handler
Inhalation
Risks
Inhalation
MOEsc
Exposure
Scenario
Crop
or
Target
Application
Rate
a
Area
Treated
Daily
b
Baseline
80%
PPER
Eng
Cont
Mixer/
Loader
Carnations
(
drench)
256
lb
ai/
acre
20
acres
29
150
420
Ornamental
Herbaceous
Plants
(
drench)
72
lb
ai/
acre
20
acres
100
520
1,500
Sodfarm
Turf
0.9
lb
ai/
acre
80
acres
2,100
10,000
30,000
Seedlings
(
planted
in
field)
0.43
lb
ai/
acre
20
acres
17,000
87,000
250,000
Mosquito
Control
in
Decorative
Ponds,
Sewage
Treatment
Systems,
and
Standing
Water
0.0017
lb
ai/
gal
of
water
to
be
treated
800,000
gallons
of
water
110
550
1,600
Mosquito
Control
in
Decorative
Ponds,
Sewage
Treatment
Systems,
and
Standing
Water
0.0017
lb
ai/
gal
of
water
to
be
treated
100,000
gallons
of
water
880
4,400
13,000
Mixing/
Loading
(
M/
L)
Liquids
for
Groundboom
Applications
(
1a)

Mosquito
Control
in
Decorative
Ponds,
Sewage
Treatment
Systems,
and
Standing
Water
0.0017
lb
ai/
gal
of
water
to
be
treated
20,000
gallons
of
water
4,400
22,000
64,000
Residential
&
Commercial
Turf
7
lb
ai/
acre
100
acres
210
1,100
3,100
ML
Liquid
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
(
1b)
Residential
&
Commercial
Turf
0.9
lb
ai/
acre
100
acres
1,700
8,300
24,000
M/
L
Liquids
for
Airblast
(
1c)
Ornamental
Trees
0.65
lb
ai/
acre
20
acres
12,000
58,000
170,000
Ornamental
Herbaceous
Plants,
0.0065
lb
ai/
gal
100
gallons
230,000
1,200,000
3,300,000
M/
L
Liquid
via
Dip
or
Soak
(
1d)
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
100
gallons
350,000
1,700,000
5,000,000
Carnations
(
drench)
256
lb
ai/
acre
20
acres
1
4
150
Ornamental
Herbaceous
Plants
(
drench)
72
lb
ai/
acre
20
acres
3
15
520
Sodfarm
Turf
0.9
lb
ai/
acre
80
acres
58
290
10,000
M/
L
WP
for
Groundboom
(
2a)

Seedlings
(
planted
in
field)
0.43
lb
ai/
acre
20
acres
490
2,400
87,000
Residential
&
Commercial
Turf
7
lb
ai/
acre
100
acres
6
30
1,100
M/
L
WP
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
(
2b)
Residential
&
Commercial
Turf
0.9
lb
ai/
acre
100
acres
47
230
8,300
M/
L
WP
for
Airblast
(
2c)
Ornamental
Trees
0.65
lb
ai/
acre
20
acres
320
1,600
58,000
M/
L
WP
via
Dip
or
Soak
(
2d)
Ornamental
0.0065
lb
100
gallons
6,400
32,000
1,200,000
Page
24
of
46
TABLE
7.
ADBAC:
Occupational
Handler
Inhalation
Risks
Inhalation
MOEsc
Exposure
Scenario
Crop
or
Target
Application
Rate
a
Area
Treated
Daily
b
Baseline
80%
PPER
Eng
Cont
Herbaceous
Plants,
ai/
gal
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
100
gallons
9,700
49,000
1,700,000
Carnations
(
drench)
256
lb
ai/
acre
20
acres
46
230
460
Ornamental
Herbaceous
Plants
(
drench)
72
lb
ai/
acre
20
acres
160
810
1,600
Sodfarm
Turf
0.9
lb
ai/
acre
80
acres
3,200
16,000
32,000
M/
L
DF
for
Groundboom
(
3a)

Seedlings
(
planted
in
field)
0.43
lb
ai/
acre
20
acres
27,000
140,000
270,000
M/
L
DF
for
Airblast
(
3b)
Ornamental
Trees
0.65
lb
ai/
acre
20
acres
18,000
90,000
58,000
Residential
&
Commercial
Turf
7
lb
ai/
acre
100
acres
330
1,700
1,100
M/
L
DF
to
Support
LCO
Handgun
Applications
(
mixing/
loading
supports
20
LCOs)
(
3c)
Residential
&
Commercial
Turf
0.9
lb
ai/
acre
100
acres
2,600
13,000
8,300
Ornamental
Herbaceous
Plants,
0.0065
lb
ai/
gal
100
gallons
360,000
1,800,000
1,200,000
M/
L
DF
via
Dip
or
Soak
(
3d)
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
100
gallons
540,000
2,700,000
1,700,000
Applicator
Carnations
(
drench)
256
lb
ai/
acre
20
acres
48
240
820
Ornamental
Herbaceous
Plants
(
drench)
72
lb
ai/
acre
20
acres
170
840
2,900
Sodfarm
Turf
0.9
lb
ai/
acre
80
acres
3,400
17,000
58,000
Seedlings
(
planted
in
field)
0.43
lb
ai/
acre
20
acres
28,000
140,000
490,000
Mosquito
Control
in
Decorative
Ponds,
Sewage
Treatment
Systems,
Swimming
Pools
and
Standing
Water
0.0017
lb
ai/
gal
of
water
to
be
treated
800,000
gallons
of
water
to
be
treated
180
890
3,100
Applying
Sprays
via
Groundboom
Equipment
(
4)

Mosquito
Control
in
Decorative
Ponds,
Sewage
Treatment
Systems,
Swimming
Pools
and
Standing
Water
0.0017
lb
ai/
gal
of
water
to
be
treated
100,000
gallons
of
water
to
be
treated
1,400
7,200
25,000
Mosquito
Control
in
Decorative
Ponds,
Sewage
Treatment
Systems,
Swimming
Pools
and
Standing
Water
0.0017
lb
ai/
gal
of
water
to
be
treated
20,000
gallons
of
water
to
be
treated
7,200
36,000
120,000
Page
25
of
46
TABLE
7.
ADBAC:
Occupational
Handler
Inhalation
Risks
Inhalation
MOEsc
Exposure
Scenario
Crop
or
Target
Application
Rate
a
Area
Treated
Daily
b
Baseline
80%
PPER
Eng
Cont
Applying
Sprays
via
Airblast
Equipment
(
5)
Ornamental
Trees
0.65
lb
ai/
acre
20
acres
3,100
15,000
31,000
Mixer/
Loader/
Applicator
Carnations
(
drench)
256
lb
ai/
acre
5
acres
94
390
Not
Feasible
Ornamental
Herbaceous
Plants
(
drench)
72
lb
ai/
acre
5
acres
330
1,400
Not
Feasible
Ornamental
Trees
and
Ornamental
Herbaceous
Plants
0.65
lb
ai/
acre
5
acres
37,000
150,000
Not
Feasible
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
(
11)

Ornamental
Shrubs,
Seedlings
(
planted
in
field)
0.43
lb
ai/
acre
5
acres
56,000
230,000
Not
Feasible
Carnations
(
drench)
256
lb
ai/
acre
5
acres
2
11
Not
Feasible
Ornamental
Herbaceous
Plants
(
drench)
72
lb
ai/
acre
5
acres
8
39
Not
Feasible
Ornamental
Trees
and
Ornamental
Herbaceous
Plants
0.65
lb
ai/
acre
5
acres
870
4,300
Not
Feasible
Mixing/
Loading/
Applying
Wettable
Powders
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
(
12)

Ornamental
Shrubs,
Seedlings
(
planted
in
field)
0.43
lb
ai/
acre
5
acres
1,300
6,500
Not
Feasible
Carnations
(
drench)
256
lb
ai/
acre
5
acres
6
32
Not
Feasible
Ornamental
Herbaceous
Plants
(
drench)
72
lb
ai/
acre
5
acres
23
110
Not
Feasible
Ornamental
Trees
and
Ornamental
Herbaceous
Plants
0.65
lb
ai/
acre
5
acres
2,500
13,000
Not
Feasible
Mixing/
Loading/
Applying
Dry
Flowables
Concentrates
with
a
Handgun
Sprayer
(
LCO
ORETF
data)
(
14)

Ornamental
Shrubs,
Seedlings
(
planted
in
field)
0.43
lb
ai/
acre
5
acres
3,800
19,000
Not
Feasible
Ornamental
Herbaceous
Plants
and
Ornamental
Trees
0.0065
lb
ai/
gallon
1,000
gallons
230
1,200
Not
Feasible
Mixing/
Loading/
Applying
Liquid
Concentrates
with
a
High
Pressure
Handwand
(
PHED)
(
15)
Ornamental
Shrubs
0.0043
lb
ai/
gallon
1,000
gallons
350
1,700
Not
Feasible
Applying
Ready
to
Use
Formulations
via
Trigger­
Pump
Sprayer
(
ORETF)
(
16)
Ornamental
Shrubs,
Seedlings,
Seeds,
Cuttins
(
preplant
or
at
plant)
0.0043
lb
ai/
gallon
1
gallons
2,200,000
11,000,000
Not
Feasible
Ornamental
Palms
0.013
lb
ai/
gallon
5
gallons
160,000
810,000
Not
Feasible
Seedlings,
Seeds,
Cuttins
(
preplant
or
at
plant)
0.0043
lb
ai/
gallon
5
gallons
490,000
2,500,000
Not
Feasible
Mixing/
Loading/
Applying
Liquids
with
a
Watering
Can
(
using
ORETF
residential
hoseend
data)
(
17)

Mosquito
Control
in
0.0017
lb
20,000
310
1,600
Not
Feasible
Page
26
of
46
TABLE
7.
ADBAC:
Occupational
Handler
Inhalation
Risks
Inhalation
MOEsc
Exposure
Scenario
Crop
or
Target
Application
Rate
a
Area
Treated
Daily
b
Baseline
80%
PPER
Eng
Cont
Decorative
Ponds,
Sewage
Treatment
Systems,
Swimming
Pools,
and
Standing
Water
ai/
gallon
of
water
to
be
treated
gallons
to
be
treated
Mosquito
Control
in
Fountains,
Water
Displays,
Decorative
Pools
0.0017
lb
ai/
gallon
of
water
to
be
treated
1,000
gallons
to
be
treated
6,200
31,000
Not
Feasible
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
ADBAC
b
Amount
handled
per
day
values
are
HED
estimates
of
gallons
applied
per
day
based
on
Exposure
SAC
SOP
#
9
A
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,@
industry
sources,
and
HED
estimates.
c
Inhalation
MOE
=
inhalation
NOAEL
(
mg/
kg/
day)
/
baseline
inhalation
dose
(
mg/
kg/
day),
where
baseline
inhalation
exposure
(
mg/
day)
=
application
rate
(
lb
ai/
gal
)
x
amount
handled
per
day
(
gal/
day)
x
baseline
inhalation
unit
exposure
(
µ
g/
lb
ai)
x
conversion
factor
from
µ
g
to
mg
(
0.001)
and
the
baseline
inhalation
dose
(
mg/
kg/
day)
=
baseline
inhalation
exposure
(
mg/
day)
x
inhalation
absorption
factor
(
100%)
/
female
bodyweight
(
60
kg)
Page
27
of
46
2.1.3
Cancer
ADBAC
Handler
Exposure
and
Risk
Assessment
No
cancer
endpoints
were
identified
for
ADBAC;
therefore,
cancer
risks
to
handlers
were
not
assessed.

2.1.4
Summary
of
Risk
Concerns
and
Data
Gaps
for
Occupational
Handlers
2.1.4.1
Summary
of
Risk
Concerns
Three
scenarios
fall
below
an
MOE
of
1000
at
the
maximum
level
of
protection
(
engineering
controls),
and
the
Agency
may
request
a
confirmatory
inhalation
toxicity
study:
 
Mixing/
Loading
liquid
concentrations
via
groundboom
application
(
carnations
 
drench)
at
256
lb
ai/
gal
[
MOE
=
420
]
 
Mixing/
Loading
dry
flowables
via
groundboom
application
(
carnations
 
drench)
at
256
lb
ai/
gal
[
MOE
=
460]
 
Applying
sprays
via
groundboom
application
(
carnations
 
drench)
at
256
lb
ai/
gal
[
MOE
=
820]
 
Mixing/
Loading
wettable
powders
for
groundboom
application
(
ornamental
herbaceous
plants
 
drench)
at
72
lb
ai/
gal
[
MOE=
520]
 
Mixing/
Loading
wettable
powders
for
groundboom
application
(
carnations
 
drench)
at
256
lb/
ai
gal
There
are
no
occupational
handler
scenarios
for
ADBAC
that
have
inhalation
risks
associated
with
them
that
are
above
the
level
of
concern
for
exposure
assessments
at
the
maximum
level
of
risk
mitigation.
Most
handler
inhalation
risks
assessed
are
not
of
concern
at
baseline
(
i.
e.,
no
respirator),
except:
 
(
1a)
mixing/
loading
liquids
concentrates
for
groundboom
applications
for
drench
applications
to
carnations
(
256
lb
ai/
A)
 
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator,
 
(
2a)
mixing/
loading
wettable
powders
for
groundboom
applications
for
drench
applications
to
carnations
(
256
lb
ai/
A)
and
for
drench
applications
to
ornamental
plants
(
72
lb
ai/
A)
and
for
application
to
sodfarm
turf
(
0.9
lb
ai/
A)
 
risks
are
not
of
concern
with
engineering
controls
(
i.
e.,
water­
soluble
packaging)
for
the
drench
applications,
and
risks
are
not
of
concern
for
application
to
sod
farms
with
the
addition
of
a
dust/
mist
respirator,
 
(
2b)
mixing/
loading
wettable
powders
support
LCO
handgun
applications
(
mixing/
loading
supports
20
LCOs)
for
applications
to
turf
(
7
lb
ai/
A)
 
risks
are
not
of
concern
with
engineering
controls
(
i.
e.,
water­
soluble
packaging),
 
(
2b)
mixing/
loading
wettable
powders
support
LCO
handgun
applications
(
mixing/
loading
supports
20
LCOs)
for
applications
to
turf
(
0.9
lb
ai/
A)
 
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator,
 
(
3a)
mixing/
loading
dry
flowables
for
groundboom
applications
for
drench
applications
to
Page
28
of
46
carnations
(
256
lb
ai/
A)
 
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator,
 
(
4)
applying
sprays
via
groundboom
equipment
for
drench
applications
to
carnations
(
256
lb
ai/
A)
 
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator,
 
(
11)
mixing/
loading/
applying
liquid
concentrates
with
a
handgun
sprayer
applications
to
carnations
(
256
lb
ai/
A)
 
MOE
is
94
at
baseline
and
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator,
 
(
12)
mixing/
loading/
applying
wettable
powders
with
a
handgun
sprayer
for
drench
applications
to
carnations
(
256
lb
ai/
A)
and
for
drench
applications
to
ornamental
plants
(
72
lb
ai/
A)
 
risks
are
not
of
concern
with
engineering
controls
for
mixing/
loading
(
i.
e.,
water­
soluble
packaging)
and
the
addition
of
a
dust/
mist
respirator
for
application,
 
(
14)
mixing/
loading/
applying
dry
flowables
with
a
handgun
sprayer
for
drench
applications
to
carnations
(
256
lb
ai/
A)
 
risks
are
not
of
concern
with
engineering
controls
for
mixing/
loading
(
i.
e.,
water­
soluble
packaging)
and
the
addition
of
a
dust/
mist
respirator
for
application.
 
(
14)
mixing/
loading/
applying
dry
flowables
with
a
handgun
sprayer
for
drench
applications
to
ornamental
plants
(
72
lb
ai/
A)
 
risks
are
not
of
concern
with
the
addition
of
a
dust/
mist
respirator.

2.1.4.2
Summary
of
Data
Gaps
There
are
the
data
gaps
for
the
occupational
handler
scenarios:
 
mixing/
loading/
applying
dip
or
soak
(
no
surrogate
data
are
available
for
this
scenario),
 
mixing/
loading/
applying
dry
flowables
using
a
low­
pressure
handwand
sprayer
(
data
for
liquid
formulations
was
used
as
a
surrogate),
 
mixing/
loading/
applying
liquid
concentrates
for
sprinkling
can
(
ORETF
data
for
hose­
end
sprayers
was
used
as
a
surrogate),
and
 
mixing/
loading/
applying
dip
or
soak
(
no
surrogate
data
are
available
for
this
scenario).

2.1.5
Recommendations
for
Refining
Occupational
Handler
Risk
Assessment
In
order
to
refine
this
occupational
risk
assessment,
data
on
actual
use
patterns
including
rates,
timing,
and
areas
treated
would
better
characterize
ADBAC
risks.
Exposure
studies
for
many
equipment
types
that
lack
data
or
that
are
not
well
represented
in
PHED
(
e.
g.,
because
of
low
replicate
numbers
or
data
quality)
should
also
be
considered
based
on
the
data
gaps
identified
above
and
based
on
a
review
of
the
quality
of
the
data
used
in
this
assessment.

2.2
Occupational
Postapplication
Exposures
and
Risks
The
Agency
uses
the
term
"
postapplication"
to
describe
exposures
to
individuals
that
occur
as
a
result
of
being
in
an
environment
that
has
been
previously
treated
with
a
pesticide
(
also
referred
to
as
reentry
exposure).
The
Agency
believes
that
there
are
distinct
job
functions
or
tasks
Page
29
of
46
related
to
the
kinds
of
activities
that
occur
in
previously
treated
areas.
Job
requirements
(
e.
g.,
the
kinds
of
jobs
to
cultivate
a
crop),
the
nature
of
the
crop
or
target
that
was
treated,
and
how
the
chemical
residues
degrade
in
the
environment
can
cause
exposure
levels
to
differ
over
time.
Each
factor
has
been
considered
in
this
assessment.

2.2.1
Occupational
Postapplication
Exposure
Scenarios
ADBAC
can
be
used
on
ornamental
crops
in
greenhouse
and
outdoor
occupational
settings.
As
a
result,
individuals
can
potentially
be
exposed
by
working
in
areas
that
have
been
previously
treated.
The
Agency
is
concerned
about
the
kinds
of
exposures
one
could
receive
in
the
workplace
after
ADBAC
is
applied
to
ornamentals.

Since
no
toxicological
endpoint
of
concern
was
identified
for
dermal
systemic
adverse
effects,
no
postapplication
occupational
exposures
and
risks
were
assessed
using
the
traditional
method
of
transfer
coefficients
specific
to
activities
performed.
Instead,
a
dermal
endpoint
was
identified
and
expressed
as
µ
g/
cm2.
Postapplication
dermal
risks
were
assessed
by:

$
converting
the
application
rate
from
lb
ai/
A
to
µ
g/
cm2;

$
using
the
Agency=
s
default
assumption
that
20
percent
of
the
initial
application
is
available
for
transfer
on
day
0
(
i.
e.,
12
hours
after
application);

$
using
the
Agency=
s
default
assumption
that
the
residue
dissipates
at
a
rate
of
10
percent
per
day;

$
assuming
that
during
the
exposure
period
the
skin
repeatedly
contacts
foliar
surfaces
until
a
concentration
of
residues
on
the
hand
is
equal
to
the
concentration
of
residues
on
foliar
surfaces,
and
thereafter,
a
steady­
state
is
achieved
whereby
the
concentration
on
the
hands
remains
the
same
as
the
concentration
on
the
foliar
surfaces..

Inhalation
exposures
are
thought
to
be
negligible
in
outdoor
postapplication
scenarios,
since
ADBAC
has
low
vapor
pressure
and
the
dilution
factor
the
outdoor
environment
is
considered
infinite.
In
addition,
under
the
Worker
Protection
Standard
for
Agricultural
Pesticides
B
WPS
B
(
40
CFR
170)
greenhouses
must
be
appropriately
ventilated
(
ventilation
criteria
are
provided)
following
pesticide
applications
so
that
postapplication
inhalation
exposures
are
minimal.
As
such,
inhalation
postapplication
exposures
are
not
considered
in
this
assessment.
The
Agency
recommends
that
WPS
ventilation
criteria
be
imposed
on
non­
WPS
applications
indoors
in
settings
such
as
an
atrium,
interiorscape,
or
other
commercial
plant
setting.
The
WPS
ventilation
requirements
are:

$
10
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
Page
30
of
46
In
agricultural
crop
settings,
the
use
of
personal
protective
equipment
or
other
types
of
equipment
to
mitigate
postapplication
exposures
to
workers
is
not
considered
a
viable
alternative
for
the
regulatory
process.
This
is
described
in
some
detail
in
the
WPS.
Instead,
an
administrative
approach
B
a
Restricted
Entry
Interval
or
REI
B
is
used
to
mitigate
postapplication
risks
following
applications
to
crops.
The
REI
is
time
period
following
a
pesticide
application
during
which
entry
into
the
treated
area
is
restricted.
Postapplication
risk
levels
are
generally
calculated
in
the
risk
assessment
process
on
a
chemical­,
crop­,
and
activity­
specific
basis.
To
establish
REIs,
the
Agency
considers
postapplication
risks
on
varying
days
after
application.

2.2.2
Data/
Assumptions
for
Postapplication
Exposure
Scenarios
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
occupational
postapplication
worker
risk
assessments.
Each
assumption
and
factor
is
detailed
below
on
an
individual
basis.

$
Maximum
application
rates
were
considered.

$
Levels
of
Concern:
the
Agency
has
established
levels
of
concern
(
LOC)
for
occupational
postapplication
risks
B
margins
of
exposure
of
less
than
100
for
occupational
dermal
risks
are
of
concern.

$
Dislodgeable
Foliar
Residues:
No
ADBAC­
specific
dislodgeable
foliar
residue
(
DFR)
data
were
available.
Therefore,
this
assessment
uses
the
Agency=
s
default
assumption
that
20
percent
of
the
application
rate
is
available
on
day
0
(
i.
e.,
12
hours
after
application)
and
the
residue
dissipates
at
a
rate
of
10
percent
per
day.

$
Turf
Transferable
Residues:
No
ADBAC­
specific
turf
transferable
residue
(
TTR)
data
were
available.
Therefore,
this
assessment
uses
the
Agency=
s
default
assumption
that
5
percent
of
the
application
rate
is
available
on
day
0
(
i.
e.,
12
hours
after
application)
and
the
residue
dissipates
at
a
rate
of
10
percent
per
day.

2.2.3
Occupational
Postapplication
Exposure
and
Risk
Estimates
Occupational
risks
were
calculated
using
a
Margin
of
Exposure
(
MOE),
which
is
a
ratio
of
the
daily
exposure
to
the
toxicological
endpoint
of
concern.
Postapplication
risks
diminish
over
time
because
ADBAC
residues
eventually
dissipate
in
the
environment.
As
a
result,
risks
were
calculated
over
time
based
on
changing
residue
levels.
Postapplication
exposure
(
i.
e.
MOEs)
were
calculated
as
described
in
Appendix
A.

Post
Application
Risk
Summary
A
summary
of
the
postapplication
risks
are
provided
in
Table
8.
The
occupational
postapplication
exposure
and
risk
assessment
for
ornamental
crop
uses
of
ADBAC
indicates
that
Page
31
of
46
dermal
risks
are
of
concern
following
applications
applied
as
a
spray
for
the
three
application
rates.
When
applied
as
a
spray
for
ornamental
crops
uses,
dermal
risks
remain
of
concern
for
3
days
until
after
application
for
turf
application
at
the
lower
application
rate,
7
days
until
after
application
for
the
higher
rate
and
for
13
days
until
after
application
for
treating
plants.
Dermal
risks
also
remain
of
concern
following
applications
applied
as
a
drench
to
carnations
until
69
days
after
application
and
applied
as
a
drench
to
herbaceous
ornamentals
until
57
days
after
application.

Table
8.
Summary
of
Dermal
Risks
to
Occupational
Postapplication
Workers
Crop
Grouping
Application
type
Application
ratea
(
lb
ai/
acre)
Day
after
Treatment
when
MOE
 

100
MOE
at
Day
0
Dermal
Exposure
to
Treated
Carnations
Drench
256
69
days
<
1
Dermal
Exposure
to
Treated
Herbaceous
Ornamentals
Drench
72
57
days
<
1
Dermal
Exposure
to
Treated
Plants
Spray
0.65
13
days
27
7
22
days
10
Dermal
Exposure
to
Treated
Turf
Spray
0.9
3
days
79
Dermal
endpoint:
(
Short­
term
technical
grade
a.
i.)
­
40
ug/
cm2
2.2.4
Occupational
Postapplication
Exposure
and
Risk
Estimates
for
Cancer
Since
no
toxicological
endpoint
of
concern
was
identified
for
cancer,
cancer
risks
from
occupational
postapplication
exposures
were
not
assessed.

2.2.5
Summary
of
Occupational
Postapplication
Risk
Concerns
and
Data
Gaps
The
Agency
has
used
the
most
up­
to­
date
information
available
to
complete
this
postapplication
risk
assessment
for
ADBAC.
A
summary
of
the
postapplication
risks
are
provided
in
Table
8.
The
occupational
postapplication
exposure
and
risk
assessment
for
ornamental
crop
uses
of
ADBAC
indicates
that
dermal
risks
are
of
concern
on
all
occupational
postapplication
scenarios.

2.2.6
Recommendations
for
Refining
Occupational
Postapplication
Risk
Assessment
To
refine
this
occupational
risk
assessment,
data
on
actual
use
patterns
including
rates,
timing,
and
the
gallons
per
acre
that
are
required
to
apply
ADBAC
to
control
plant
diseases
or
and
the
gallons
of
water
treated
daily
to
control
mosquito
larvae
in
standing
water
would
better
characterize
ADBAC
risks.
In
addition,
ADBAC­
specific
DFR
or
TTR
data
could
refine
Page
32
of
46
exposure
and
risk
estimates.

3.0
Residential
and
Other
Non­
Occupational
Exposures
and
Risks
It
has
been
determined
there
is
a
potential
for
exposure
in
residential
settings
during
the
application
process
for
homeowners
who
use
products
containing
ADBAC.
There
is
also
a
potential
for
exposure
from
entering
ADBAC­
treated
areas,
such
as
home
lawns,
gardens
and
greenhouses
that
could
lead
to
exposures
to
adults.
Risk
assessments
have
been
completed
for
both
residential
handler
and
postapplication
scenarios.

3.1
Residential
Handler
Exposures
and
Risks
The
Agency
uses
the
term
Ahandlers@
to
describe
those
individuals
who
are
involved
in
the
pesticide
application
process.
The
Agency
believes
that
there
are
distinct
tasks
related
to
applications
and
that
exposures
can
vary
depending
on
the
specifics
of
each
task
as
was
described
above
for
occupational
handlers.

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

$
Residential
handler
exposure
scenarios
are
considered
to
be
short­
term
only,
due
to
the
infrequent
use
patterns
associated
with
homeowner
products.

$
Homeowner
handler
assessments
are
based
on
the
assumption
that
individuals
experience
irritation
based
on
hand
contact
with
ADBAC.

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

$
Master
Label
use­
rates
and
use­
information
specific
to
residential
products
serve
as
the
basis
for
the
risk
calculations.

$
Area/
volumes
of
spray
or
chemical
used
in
the
risk
assessment
are
based
on
the
Agency=
s
guidance
specific
to
residential
use­
patterns.

Since
requiring
personal
protective
equipment
is
not
considered
by
EPA
as
a
feasible
means
of
reducing
exposure
and
risk
for
residential
handlers,
dermal
risks
were
estimated
for
residential
handlers
to
determine
if
dermal
irritation
would
be
of
concern.
Dermal
risks
were
estimated
by
using
the
dermal
unit
exposure
for
hands
from
Pthe
Agency
for
the
application
equipment/
method
being
assessed
divided
by
the
surface
area
of
adult
hands
and
then
normalizing
Page
33
of
46
for
the
amount
handled
per
day
(
application
rate
in
pounds
active
ingredient
per
gallon
times
the
gallons
handled
per
day).
The
residue
concentration
on
skin
(
µ
g/
cm2)
was
then
compared
directly
to
the
dermal
endpoint
(
µ
g/
cm2).
The
margin
of
exposure
(
MOE)
for
the
dermal
assessment
is
100.

It
has
been
determined
that
exposure
to
pesticide
handlers
is
likely
during
the
residential
use
of
ADBAC
in
indoor
(
greenhouse)
and
outdoor
while
treating
turf
and
ornamentals.
The
anticipated
use
patterns
and
current
labeling
indicate
several
residential
handler
exposure
scenarios
based
on
the
types
of
equipment
and
techniques
that
can
potentially
be
used
to
make
ADBAC
applications.
The
quantitative
exposure/
risk
assessment
developed
for
residential
handlers
is
based
on
these
scenarios.
[
Note:
The
scenario
numbers
correspond
to
the
tables
of
risk
calculations
included
in
the
residential
risk
calculations
in
the
appendices.]

Mixer/
Loader/
Applicators:
(
1)
Liquid
Formulations:
Low
Pressure
Handwand
(
PHED
data
for
dermal
and
ORETF
data
for
inhalation)
(
2)
Wettable
Powder
Formulations:
Low
Pressure
Handwand
(
PHED
data
for
dermal
and
inhalation)
(
3)
Dry
Flowable
Formulations:
Low
Pressure
Handwand
(
using
liquid
concentrate
PHED
data
for
dermal
and
liquid
concentrate
ORETF
data
for
inhalation)
(
4)
Liquid
Concentrates:
Hose­
End
Sprayer
(
PHED
data
for
dermal
and
ORETF
data
for
inhalation)
(
5)
Wettable
Powder
Formulations:
Hose­
End
Sprayer
(
no
data)
(
6)
Dry
Flowable
Formulations:
Hose­
End
Sprayer
(
no
data)
(
7)
Ready­
to­
Use
Formulations:
Hose­
End
Sprayer
(
no
data)
(
8)
Liquid
Concentrates:
Watering
Can
(
using
PHED
hose­
end
sprayer
data
for
dermal
and
ORETF
hose­
end
data
for
inhalation)
(
9)
Ready
to
Use
Formulations
via
Trigger­
Pump
Sprayer
(
PHED
data
for
aerosol
can
for
dermal
and
ORETF
data
for
inhalation),
and
10)
Dip
or
Soak
Applications
(
no
data)

3.1.2
Data
and
Assumptions
for
Handler
Exposure
Scenarios
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
residential
handler
risk
assessments.
Each
assumption
and
factor
is
detailed
below.
In
addition
to
these
factors,
unit
exposure
values
were
used
to
calculate
risk
estimates.
Dermal
unit
exposure
values
were
taken
from
the
Pesticide
Handlers
Exposure
Database
(
PHED).
Both
PHED
and
the
individual
studies
are
presented
below.
[
Note:
Several
of
the
assumptions
and
factors
used
for
the
assessment
are
similar
to
those
used
in
the
occupational
assessment
presented
above.
As
such,
only
factors
that
are
unique
to
the
residential
scenarios
are
presented
below.]
Assumptions
and
Factors:
The
assumptions
and
factors
used
in
the
risk
calculations
include:

$
Exposure
factors
used
to
calculate
daily
exposures
to
handlers
were
based
on
applicable
data
if
available.
When
appropriate
data
is
unavailable,
values
from
a
scenario
deemed
Page
34
of
46
similar
might
be
used.

$
The
Agency
typically
considers
the
maximum
application
rates
allowed
by
labels
in
its
risk
assessments.
If
additional
information
such
as
average
or
typical
rates
is
available,
these
values
also
may
be
used
to
allow
risk
managers
to
make
a
more
informed
risk
management
decision.
Average/
typical
application
rates
were
not
available
for
residential
scenarios.

$
Residential
risk
assessments
are
based
on
estimates
of
what
homeowners
would
typically
treat,
such
as
the
size
of
a
lawn
or
the
size
of
a
garden.
The
factors
used
for
the
ADBAC
assessment
were
from
the
Health
Effects
Division
Science
Advisory
Committee
Policy
12:
Recommended
Revisions
to
the
Standard
Operating
Procedures
for
Residential
Exposure
Assessment
which
was
completed
on
February
22,
2001,
and
on
professional
judgment.
The
daily
volumes
handled
for
each
residential
scenario
are
provided
in
Table
3b.

3.1.3
Residential
Handler
Exposure
and
Risk
Estimates
Risks
were
calculated
using
the
margin
of
exposure
(
MOE)
as
described
in
Section
2.1.3.
Assessing
exposures
and
risks
resulting
from
residential
uses
is
very
similar
to
assessing
occupational
exposures
and
risks,
except
as
described
in
Section
3.1.1.

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

Short­
term
dermal
and
inhalation
unit
exposures
and
risks
for
residential
handlers
(
intermediate­
term
exposures
are
not
likely
because
of
the
intermittent
nature
of
applications
by
homeowners)
are
presented
in
Tables
11,
12,
and
13.
One
dermal
scenario
was
of
concern
when
the
end­
use
product
formulation
was
less
than
10
percent;
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
on
residential
turf
at
the
7
lb
ai/
A
rate.
When
the
end­
use
product
is
formulated
with
more
than
10%
ADBAC,
the
dermal
risks
for
residential
handlers
are
of
concern
for
ten
of
the
eleven
ADBAC
residential
handler
scenarios,
where
data
are
available.
The
inhalation
risks
for
residential
handlers
are
not
of
concern
for
any
residential
uses
of
ADBAC.

Table
11:
Short­
term
Dermal
Risks
to
Residential
Handlers
Using
Formulations
with
10%
or
Less
ADBAC
Page
35
of
46
Scenario
Crop/
Target
Application
Ratea
Quantity
Handled
Per
Dayb
Unit
Exposure
for
Handsc
(
mg/
lb
ai)
Estimated
Residue
Transferred
to
Skin
on
Hands
(
ug
ai/
cm2/
day)
d
Dermal
MOE
(
UF
=
100)
e
Residential
Turf,
Ornamental
Bulbs
and
Orchids
0.0065
lb
ai/
gal
water
5
gal/
day
102
4.0
1,900
M/
L/
A
Liquid
Concentrates
with
LP
Handwand
(
1)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden),
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
102
2.7
2,900
Residential
Turf,
Ornamental
Bulbs
and
Orchids
0.0065
lb
ai/
gal
water
5
gal/
day
229
9.1
850
M/
L/
A
WP
LP
Handwand
(
2)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden),
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
229
6.0
1,300
Residential
Turf,
Ornamental
Bulbs
and
Orchids
0.0065
lb
ai/
gal
water
5
gal/
day
102
4.0
1,900
M/
L/
A
DF
with
LP
Handwand
(
liquid
concentrate
PHED
data
as
surrogate)
(
3)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden),
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
102
2.7
2,900
Residential
Turf
7
lb
ai/
A
0.5
acres/
day
27.5
120.0
66
M/
L/
A
Liquid
Concentrates
with
a
Hose­
end
Sprayer
(
4)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden)
0.43
lb
ai/
A
0.25
acres/
day
27.5
3.6
2,100
Ornamental
Palms
0.013
lb
ai/
gal
water
5
gal/
day
27.5
0.7
11,000
M/
L/
A
Liquids
with
a
Watering
Can
(
PHED
residential
hose­
end
data
as
surrogate)
(
8)
Seedlings,
Seeds,
Cuttins
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
27.5
0.1
54,000
Applying
Ready
to
Use
Formulations
via
Trigger­
Pump
Sprayer
(
PHED
data
for
aerosol
can
used
as
surrogate)
(
9)
Ornamental
Shrubs,
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gallon
1
gal/
day
106
2.8
2,800
Footnotes:
Page
36
of
46
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
ADBAC
b
Amount
handled
per
day
values
are
HED
estimates
of
acres
treated
or
gallons
applied
based
on
Exposure
SAC
SOP
#
9
A
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,@
industry
sources,
and
HED
estimates.
c
From
residential
PHED
unit
exposures
values
for
hands
for
the
scenarios
listed.
d
Application
rate
(
lb
ai/
gal)
*
amount
handled
per
day
(
gal/
day)
*
dermal
unit
exposures
value
(
mg/
lb
ai)
*
conversion
factor
mg
to
µ
g
(
1000)
/
surface
area
of
adult
hands
(
cm2)
820
cm2
from
Exposure
Factors
Handbook.
f
Dermal
MOE
=
Estimated
Residue
transferred
to
Skin
of
Hands
(
µ
g/
cm2/
day)/
Dermal
Endpoint
(
7750
µ
g/
cm2/
day)

Table
12:
Short­
term
Dermal
Risks
to
Residential
Handlers
Using
Formulations
With
More
Than
10%
ADBAC
Scenario
Crop/
Target
Applicatio
n
Ratea
Quantity
Handled
Per
Dayb
Unit
Exposure
for
Handsc
(
mg/
lb
ai)
Estimated
Residue
Transferred
to
Skin
on
Hands
(
ug
ai/
cm2/
day)
d
Dermal
MOE
(
UF
=
100)
e
Residential
Turf,
Ornamental
Bulbs
and
Orchids
0.0065
lb
ai/
gal
water
5
gal/
day
102
4.0
10
M/
L/
A
Liquid
Concentrates
with
LP
Handwand
(
1)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden),
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
102
2.7
15
Residential
Turf,
Ornamental
Bulbs
and
Orchids
0.0065
lb
ai/
gal
water
5
gal/
day
229
9.1
4
M/
L/
A
WP
with
LP
Handwand
(
2)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden),
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
229
6.0
7
Residential
Turf,
Ornamental
Bulbs
and
Orchids
0.0065
lb
ai/
gal
water
5
gal/
day
102
4.0
10
M/
L/
A
DF
with
LP
Handwand
(
liquid
concentrate
PHED
data
as
surrogate)
(
3)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden),
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
102
2.7
15
Residential
Turf
7
lb
ai/
A
0.5
acres/
day
27.5
120.0
<
1
M/
L/
A
Liquid
Concentrates
with
a
Hose­
end
Sprayer
(
4)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden)
0.43
lb
ai/
A
0.25
acres/
day
27.5
3.6
11
Page
37
of
46
Table
12:
Short­
term
Dermal
Risks
to
Residential
Handlers
Using
Formulations
With
More
Than
10%
ADBAC
Scenario
Crop/
Target
Applicatio
n
Ratea
Quantity
Handled
Per
Dayb
Unit
Exposure
for
Handsc
(
mg/
lb
ai)
Estimated
Residue
Transferred
to
Skin
on
Hands
(
ug
ai/
cm2/
day)
d
Dermal
MOE
(
UF
=
100)
e
Ornamental
Palms
0.013
lb
ai/
gal
water
5
gal/
day
27.5
0.7
55
M/
L/
A
Liquids
with
a
Watering
Can
(
PHED
residential
hose­
end
data
as
surrogate)
(
8)
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
27.5
0.1
280
Applying
Ready
to
Use
Formulations
via
Trigger­
Pump
Sprayer
(
PHED
data
for
aerosol
can
used
as
surrogate)
(
9)
Ornamental
Shrubs,
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gallon
1
gal/
day
106
2.8
14
Footnotes:
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
ADBAC
b
Amount
handled
per
day
values
are
HED
estimates
of
acres
treated
or
gallons
applied
based
on
Exposure
SAC
SOP
#
9
A
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,@
industry
sources,
and
HED
estimates.
c
From
residential
PHED
unit
exposures
values
for
hands
for
the
scenarios
listed.
d
Application
rate
(
lb
ai/
gal)
*
amount
handled
per
day
(
gal/
day)
*
dermal
unit
exposures
value
(
mg/
lb
ai)
*
conversion
factor
mg
to
µ
g
(
1000)
/
surface
area
of
adult
hands
(
cm2)
820
cm2
from
Exposure
Factors
Handbook.
f
Dermal
MOE
=
Estimated
Residue
transferred
to
Skin
of
Hands
(
µ
g/
cm2/
day)/
Dermal
Endpoint
(
40
µ
g/
cm2/
day)

Table
13:
Short­
term
Inhalation
Risks
to
Residential
Handlers
Scenario
Crop/
Target
Application
Rate
a
Quantity
Handled/
Treated
per
days
Inhalation
Unit
Exposure
(
ug/
lb
ai)
c
Inhalation
Exposured
Inhalation
Dosee
Inhalation
MOEf
Residential
Turf,
Ornamental
Bulbs
and
Orchids
0.0065
lb
ai/
gal
water
5
gal/
day
30
0.000975
0.000016
180,000
M/
L/
A
Liquid
Concentrates
with
LP
Handwand
(
1)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden),
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
30
0.00065
0.000011
280,000
Residential
Turf,
Ornamental
Bulbs
and
Orchids
0.0065
lb
ai/
gal
water
5
gal/
day
1063
0.035
0.0058
5,200
M/
L/
A
WP
with
LP
Handwand
(
2)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden),
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
1063
0.023
0.00038
7,900
M/
L/
A
DF
with
Low
Residential
Turf,
0.0065
lb
5
gal/
day
30
0.000975
0.000016
180,000
Page
38
of
46
Table
13:
Short­
term
Inhalation
Risks
to
Residential
Handlers
Scenario
Crop/
Target
Application
Rate
a
Quantity
Handled/
Treated
per
days
Inhalation
Unit
Exposure
(
ug/
lb
ai)
c
Inhalation
Exposured
Inhalation
Dosee
Inhalation
MOEf
Ornamental
Bulbs
and
Orchids
ai/
gal
water
Pressure
Handwand
(
liquid
concentrate
PHED
data
as
surrogate)
(
3)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden),
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
30
0.00065
0.000011
280,000
Residential
Turf
7
lb
ai/
A
0.5
acres/
day
17
0.06
0.00099
3,000
M/
L/
A
Liquid
Concentrates
with
a
Hose­
end
Sprayer
(
4)
Ornamental
Herbaceous
Plants,
Ornamental
Shrubs,
Ornamental
Trees,
Seedlings
(
planted
in
garden)
0.43
lb
ai/
A
0.25
acres/
day
1.6
0.00017
2.9E­
6
1,000,000
Ornamental
Palms
0.013
lb
ai/
gal
water
5
gal/
day
1.6
0.001
1.7E­
6
1,700,000
M/
L/
A
Liquids
with
a
Watering
Can
(
PHED
residential
hose­
end
data
as
surrogate)
(
8)
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gal
water
5
gal/
day
1.6
0.000034
5.7E­
7
5,200,000
Applying
Ready
to
Use
Formulations
via
Trigger­
Pump
Sprayer
(
9)
Ornamental
Shrubs,
Seedlings,
Seeds,
Cuttings
(
preplant
or
at
plant)
0.0043
lb
ai/
gallon
1
gal/
day
19
0.000082
1.4E­
6
2,200,000
a
Application
rates
are
the
maximum
application
rates
determined
from
EPA
registered
labels
for
ADBAC
b
Amount
handled
per
day
values
are
HED
estimates
of
gallons
applied
per
day
based
on
Exposure
SAC
SOP
#
9
A
Standard
Values
for
Daily
Acres
Treated
in
Agriculture,@
industry
sources,
and
HED
estimates.
c
Baseline
Inhalation:
no
respirator.
d
Baseline
inhalation
exposure
(
mg/
day)
=
application
rate
(
lb
ai/
gal
)
x
amount
handled
per
day
(
gal/
day)
x
baseline
inhalation
unit
exposure
(
µ
g/
lb
ai)
x
conversion
factor
from
µ
g
to
mg
(
0.001)
e
Baseline
inhalation
dose
(
mg/
kg/
day)
=
baseline
inhalation
exposure
(
mg/
day)
x
inhalation
absorption
factor
(
100%)
/
female
bodyweight
(
kg)
f
Inhalation
MOE
=
inhalation
NOAEL
(
mg/
kg/
day)
/
baseline
inhalation
dose
(
mg/
kg/
day)

3.1.4
Residential
Handler
Exposure
and
Risk
Estimates
for
Cancer
Residential
handler
cancer
risks
are
not
assessed,
since
no
toxicological
endpoint
of
concern
for
cancer
was
selected.

3.1.5
Summary
of
Risk
Concerns
and
Data
Gaps
for
Handlers
Risks
for
all
inhalation
scenarios
were
not
of
concern
for
residential
handlers.
One
dermal
scenario
was
of
concern
when
the
end­
use
product
formulation
was
less
than
10
percent;
mixing/
loading/
applying
liquid
concentrates
with
a
hose­
end
sprayer
on
residential
turf
at
the
7
lb
ai/
A
rate
had
an
MOE
of
66.
Ten
of
the
eleven
dermal
scenarios
were
of
concern
when
the
end
Page
39
of
46
use
product
was
10
percent
or
more.

There
are
several
data
gaps
identified
by
the
Agency
for
residential
handlers
including:

$
mixing/
loading/
applying
dry
flowables
with
low­
pressure
handwand
sprayers
and
with
hose­
end
sprayers
(
no
data
are
available
as
a
reasonable
surrogate),

$
mixing/
loading/
applying
wettable
powders
with
hose­
end
sprayers
(
no
data
are
available
as
a
reasonable
surrogate),

$
mixing/
loading/
applying
liquid
concentrates
with
a
sprinkling
can
(
data
from
hose­
end
sprayers
was
used
as
a
surrogate),
and
$
applying
as
a
dip
or
soak
(
no
data
are
available
as
a
reasonable
surrogate).

$
Mixing/
loading/
applying
with
a
trigger
pump
sprayer
(
used
PHED
data
from
aerosol
can
application
for
dermal
exposure
to
hands
as
a
reasonable
surrogate).

3.1.6
Recommendations
for
Refining
Residential
Handler
Risk
Assessment
In
order
to
refine
this
residential
risk
assessment,
more
data
on
actual
use
patterns
including
rates,
timing,
and
areas
treated
would
better
characterize
ADBAC
risks.
In
addition,
if
ORETF
hand
data
are
available
separately
from
other
dermal
data,
then
ORETF
hand
data
could
be
used
to
refine
the
dermal
exposures
and
risks.
Exposure
studies
for
many
equipment
types
that
lack
data
or
that
are
not
well
represented
in
PHED
(
e.
g.,
because
of
low
replicate
numbers
or
data
quality)
should
also
be
considered
based
on
the
data
gaps
identified
above
and
based
on
a
review
of
the
quality
of
the
data
used
in
this
assessment.

3.2
Residential
Postapplication
Exposures
and
Risks
The
Agency
uses
the
term
Apostapplication@
to
describe
exposures
to
individuals
that
occur
as
a
result
of
being
in
an
environment
that
has
been
previously
treated
with
a
pesticide.
ADBAC
can
be
used
in
many
areas
that
can
be
frequented
by
the
general
population
including
residential
areas
(
e.
g.,
home
greenhouses,
gardens,
and
residential
turfgrass).
As
a
result,
individuals
can
be
exposed
by
entering
these
areas
if
they
have
been
previously
treated.

3.2.1
Residential
Postapplication
Exposure
Scenarios
Postapplication
exposure
scenarios
were
developed
for
each
residential
setting
where
ADBAC
can
be
used.
Assessing
postapplication
exposures
and
risks
resulting
from
residential
uses
is
very
similar
to
assessing
occupational
postapplication
exposures
and
risks
(
Section
2.2),
except
in
residential
assessments
the
risks
must
not
be
of
concern
on
day
0.

The
Agency
relies
on
a
standardized
approach
for
completing
residential
risk
assessments
that
is
based
on
current
ADBAC
labels
and
guidance
contained
in
the
following
five
documents:

$
Series
875,
Residential
and
Residential
Exposure
Test
Guidelines:
Group
B
­
Postapplication
Exposure
Monitoring
Test
Guidelines
(
V
5.4,
Feb.
1998):
This
document
Page
40
of
46
provides
general
risk
assessment
guidance
and
criteria
for
analysis
of
residue
dissipation
data.

$
Standard
Operating
Procedures
for
Residential
Exposure
Assessment
(
Dec.
1997):
This
document
provides
the
overarching
guidance
for
developing
residential
risk
assessments
including
scenario
development,
algorithms,
and
values
for
inputs.

$
Science
Advisory
Council
for
Exposure
Policy
12
(
Feb.
2001):
Recommended
Revisions
To
The
Standard
Operating
Procedures
(
SOPs)
For
Residential
Exposure
Assessment:
This
document
provides
additional,
revised
guidance
for
completing
residential
exposure
assessments.

$
Overview
of
Issues
Related
to
the
Standard
Operating
Procedures
for
Residential
Exposure
Assessment
(
August
1999
Presentation
To
The
FIFRA
SAP):
This
document
provides
rationale
for
Agency
changes
in
SOPs.

Usually
the
Agency
considers
children
of
differing
ages
as
well
as
adults
in
its
postapplication
residential
exposure
and
risk
assessments.
However,
since
the
dermal
endpoint
is
for
skin
irritation
potential,
only
adults
were
considered
in
the
assessment.
The
sole
postapplication
residential
scenario
assessed
is
for
residential
adults.
These
individuals
are
members
of
the
general
population
that
are
exposed
to
chemicals
by
engaging
in
activities
at
their
residences
(
e.
g.,
in
home
greenhouses
or
gardens
and
residential
turfgrass)
previously
treated
with
a
pesticide.
These
kinds
of
exposures
are
attributable
to
a
variety
of
activities
and
are
usually
addressed
by
the
Agency
in
risk
assessments
by
considering
a
representative
activity
as
the
basis
for
the
exposure
calculation.

The
SOPs
for
Residential
Exposure
Assessment
define
several
scenarios
that
apply
to
uses
specified
in
current
labels.
These
scenarios
served
as
the
basis
for
the
residential
postapplication
assessment
along
with
the
modifications
to
them
and
the
additional
data
and
approaches
described
above.
The
Agency
used
this
guidance
to
define
the
exposure
scenarios
that
essentially
include
dermal
exposure
to
adults
in
treated
greenhouses
and
gardens
and
residential
turfgrass.
The
SOPs
and
the
associated
scenarios
are
presented
below:

 
Dose
from
dermal
exposure
on
treated
lawns:
Postapplication
dermal
irritation
to
adults
contacting
treated
turf;

 
Dose
from
hand­
to­
mouth
activity
from
treated
turf:
Postapplication
dose
calculations
for
toddlers
from
incidental
nondietary
ingestion
of
pesticide
residues
on
treated
turf
from
hand­
to­
mouth
transfer
(
i.
e.,
those
residues
that
are
swallowed
when
toddlers
get
pesticide
residues
on
their
hands
from
touching
treated
turf
and
then
put
their
hands
in
their
mouth);

 
Dose
from
object­
to­
mouth
activity
from
treated
turf:
Postapplication
dose
calculations
for
toddlers
from
incidental
nondietary
ingestion
of
pesticide
residues
on
treated
turf
from
Page
41
of
46
object­
to­
mouth
transfer
(
i.
e.,
those
residues
that
are
swallowed
when
toddlers
put
treated
turf
in
their
mouths);

 
Dose
from
soil
ingestion
activity
from
treated
turf:
Postapplication
dose
calculations
for
toddlers
from
incidental
nondietary
ingestion
of
pesticide
residues
from
ingesting
soil
in
a
treated
turf
area
(
i.
e.,
those
soil
residues
that
are
swallowed
when
toddlers
get
pesticide
residues
on
their
hands
from
touching
treated
soil
and
then
put
their
hands
in
their
mouth);

$
Dose
from
dermal
exposure
on
treated
foliage
in
greenhouses
or
gardens.

3.2.2
Data
and
Assumptions
for
Residential
Postapplication
Exposure
Scenarios
Assumptions
and
Exposure
Factors
A
series
of
assumptions
and
exposure
factors
served
as
the
basis
for
completing
the
residential
postapplication
risk
assessments.
The
assumptions
and
factors
used
in
the
risk
calculations
are
consistent
with
current
Agency
policy
for
completing
residential
exposure
assessments
(
i.
e.,
SOPs
for
Residential
Exposure
Assessment).
The
values
used
in
this
assessment
include:

$
There
are
many
factors
that
are
common
to
the
occupational
and
residential
postapplication
risk
assessments,
such
as
body
weights
for
adults
and
analysis
of
residue
dissipation
data,
Please
refer
to
the
assumptions
and
factors
in
Section
2.1.2
for
further
information
concerning
these
common
values.

$
The
Agency
combines
risks
resulting
from
exposures
to
individual
applications
when
it
is
likely
they
can
occur
simultaneously
based
on
the
use
pattern
and
the
behavior
associated
with
the
exposed
population.
For
ADBAC,
the
Agency
has
combined
risks
(
i.
e.,
MOEs)
for
different
kinds
of
exposures
for
one
scenario:
for
turf
scenarios
 
hand­
to­
mouth
plus
object­
to­
mouth
plus
soil
ingestion.

 
Exposures
to
adults
and
children
on
treated
turf
have
been
addressed
using
the
latest
the
Agency
standard
operating
procedures
for
this
scenario
including:


5
percent
of
the
application
rate
has
been
used
to
calculate
the
day­
zero
TTR
residue
levels
used
for
assessing
risks
from
dermal
and
hand­
to­
mouth
exposures,
since
ADBAC­
specific
turf
transferable
residue
study
data
are
not
available;


20
percent
of
the
application
rate
has
been
used
to
calculate
the
day­
zero
residue
levels
used
for
assessing
risks
from
object­
to­
mouth
behaviors
(
a
higher
percent
transfer
has
been
used
for
object­
to­
mouth
behaviors,
because
it
Page
42
of
46
involves
a
teething
action
believed
to
be
more
analogous
to
DFR/
leaf
wash
sample
collection
where
20
percent
is
also
used);


3
year
old
toddlers
are
expected
to
weigh
15
kilograms
(
representing
an
average
weight
from
years
one
to
six);


hand­
to­
mouth
exposures
are
based
on
a
frequency
of
20
events/
hour
and
a
surface
area
per
event
of
20
cm2,
representing
the
palmar
surfaces
of
three
fingers;


saliva
extraction
efficiency
is
50
percent
meaning
that
every
time
the
hand
goes
in
the
mouth
approximately
½
of
the
residues
on
the
hand
are
removed;


object­
to­
mouth
exposures
are
based
on
a
25
cm2
surface
area;


exposure
durations
for
turfgrass
scenarios
are
estimated
to
be
2
hours
based
on
information
in
the
Agency's
Exposure
Factors
Handbook;


soil
residues
are
contained
in
the
top
centimeter
and
soil
density
is
0.67
mL/
gram;
and

hand­
and
object­
to­
mouth,
and
soil
ingestion
are
combined
to
represent
an
overall
incidental
oral
risk
from
exposure
to
turf.

$
Exposures
to
adults
working
in
home
greenhouses
and
gardens
have
been
addressed
using
the
latest
the
Agency
approaches
for
this
scenario
including:
the
DFR
data
used
for
the
assessments
are
the
default
assumption
that
20
percent
of
the
application
rate
is
available
for
transfer,
since
no
ADBAC­
specific
DFR
data
are
available.

$
Postapplication
residential
risks
are
based
on
maximum
application
rates
or
values
specified
in
the
SOPs
for
Residential
Exposure
Assessment.

3.2.3
Residential
Postapplication
Exposure
and
Risk
Estimates
Incidental
oral
risks
were
calculated
using
the
Margin
of
Exposure
(
MOE)
approach,
which
is
a
ratio
of
the
body
burden
to
the
toxicological
endpoint
of
concern.
Dermal
risks
were
calculated
using
the
MOE
approach
but
using
a
ratio
of
residue
on
the
skin
to
the
toxicological
endpoint
of
concern.
Exposures
were
estimated
by
considering
the
potential
sources
of
exposure
(
i.
e.,
DFRs
on
ornamental
plants
and
TTRs
on
treated
turf),
then
calculating
dermal
exposures.

Dermal
exposures
and
risks
from
lawn
and
garden
uses
were
calculated
in
the
same
manner
as
described
above
in
Section
2.2.3.
Along
with
calculating
these
dermal
exposures,
other
aspects
of
the
turf
exposure
scenario
involved
calculating
dose
from
non­
dietary
ingestion.
The
algorithms
used
for
each
type
of
calculation
are
presented
below
which
have
not
been
previously
addressed
in
Section
2.2.3.

Risk
Summary:

Adults
Page
43
of
46
Table
14
presents
the
postapplication
MOE
values
calculated
for
adults
after
home
greenhouse,
garden
or
turfglass
applications
of
ADBAC.
The
dermal
MOEs
were
of
concern
(
i.
e.,
MOEs
<
100)
on
the
day
of
application
for
the
three
scenarios
with
different
application
rates.

Table
14:
ADBAC:
Adult
Residential
Dermal
Risks
for
Postapplication
Exposure
Exposure
Scenario
Route
of
Exposure
Formulation
Application
Ratea
(
lb
ai/
acre)
Residue
on
Skinb
MOEc
at
Day
0
Exposure
To
Treated
Ornamental
Plants
0.43
0.96
41
7
3.9
10
Exposure
to
Treated
Turf
Dermal
Spray
0.9
0.5
79
a
Maximum
application
rate
on
label
(
lb
ai/
A).
b
Residue
concentration
available
to
be
transferred
on
day
A
t
@

=
application
rate
in
µ
g/
cm2
(
lb
ai/
gal
*
conversion
factors
(
lb
to
µ
g
and
A
to
cm2)
*
fraction
of
DFR
or
TTR
available
on
day
0
*
percent
of
DFR
or
transferrable
to
skin
(
100%).
c
Dermal
MOE
=
dermal
endpoint
(
40
ug/
cm2)/
residue
concentration
on
skin
Toddler
(
3
year
old)

Risks
(
MOEs)
to
toddlers
were
calculated
for
postapplication
risks
following
the
application
of
ADBAC
to
home
lawns.
Table
15
summarizes
the
risk
assessment
for
toddlers.
One
scenario
­­
hand­
to­
mouth
activity
at
the
higher
application
rate
­­
had
MOEs
less
than
100.
Short­
term
MOEs
were
greater
than
100
for
object­
to­
mouth
activities
and
incidental
soil
ingestion
and
for
hand­
to­
mouth
activity
at
the
lower
application
rate.

Table
15.
ADBAC:
Toddler
Residential
Risk
Estimates
for
Postapplication
Exposure
Exposure
Scenario
Route
of
Exposure
Formulation
Application
Ratea
(
lb
ai/
A)
MOE
 
Day
0b
Hand
to
Mouth
Activity
on
Turf
96
Object
to
Mouth
Activity
on
Turf
380
Incidental
Soil
Ingestion
Oral
Spray
7
29,000
Hand
to
Mouth
Activity
on
Turf
740
Object
to
Mouth
Activity
on
Turf
3,000
Incidental
Soil
Ingestion
Oral
Spray
0.9
220,000
Page
44
of
46
a
Maximum
application
rate
on
label
(
lb
ai/
A).
b
Incidental
Oral
MOE
=
incidental
oral
endpoint
/
average
daily
dose
from
incidental
ingestion
exposure
Combined
Risk
Assessment
for
Residential
Scenarios
The
Agency
combines
risk
values
resulting
from
separate
postapplication
exposure
scenarios
when
it
is
likely
they
can
occur
simultaneously
based
on
the
use­
pattern
and
the
behavior
associated
with
the
exposed
population.
Table
16
presents
a
summary
of
the
combined
MOE
estimates.
The
combined
risk
assessment
for
exposures
to
toddlers
following
home
lawn
applications
was
calculated:

Combined
MOE
=
NOAEL
/
(
ADDhand­
to­
mouth
+
ADDobject­
to­
mouth
+
ADDincidental
soil
ingestion)

The
combined
risk
from
incidental
oral
ingestion
by
toddlers
following
applications
to
home
lawns
is
of
concern
with
an
MOE
of
76
for
the
higher
application
rate
on
treated
turf
(
7
lb
ai/
A),
but
were
not
of
concern
for
the
lower
application
rate
on
treated
turf
(
0.9
lb
ai/
A).
Page
45
of
46
Table
16:
ADBAC:
Combined
Incidental
Oral
Risk
Estimates
­
Toddlers
Margins
of
Exposure
(
MOEs)
(
UF=
100)
Postapplication
Exposure
Scenario
Short­
Term
Oral
(
Non­
Dietary)
Short­
Term
Oral
(
Non­
Dietary)
Hand
to
Mouth
96
Object
to
Mouth
380
Turf
application
at
7
lb
ai/
acre
Incidental
Soil
Ingestion
29,000
76
Hand
to
Mouth
740
Object
to
Mouth
3,000
Toddler
Turf
application
at
0.9
lb
ai/
acre
Incidental
Soil
Ingestion
220,000
590
3.2.4
Residential
Postapplication
Exposure
and
Risk
Estimates
for
Cancer
Residential
postapplication
cancer
risks
were
not
assessed
for
ADBAC,
since
no
toxicological
endpoint
of
concern
was
identified
for
cancer.

3.2.5
Summary
of
Residential
Postapplication
Risk
Concerns
and
Data
Gaps
In
residential
settings,
the
Agency
does
not
use
restricted­
entry
intervals
or
other
mitigation
approaches
to
limit
postapplication
exposures,
because
they
are
viewed
as
impractical
and
not
enforceable.
As
such,
risk
estimates
on
the
day
of
application
are
the
key
concern.

Dermal
risks
were
calculated
for
adults
performing
tasks
in
home
greenhouses
and
gardens
and
on
home
lawns
following
applications
of
ADBAC.
The
dermal
MOEs
were
of
concern
(
i.
e.,
MOEs
<
100)
on
the
day
of
application
for
the
three
scenarios.

Incidental
oral
ingestion
risks
were
calculated
for
toddlers
playing
on
treated
turf.
Only
one
scenario
­­
hand­
to­
mouth
activity
at
the
higher
application
rate
­­
had
MOEs
<
100.
Shortterm
MOEs
were
>
100
for
object­
to­
mouth
activities
and
incidental
soil
ingestion
and
for
handto
mouth
activity
at
the
lower
application
rate.
The
combined
risk
from
incidental
oral
ingestion
by
toddlers
following
applications
to
home
lawns
is
of
concern
with
an
MOE
of
76
for
the
higher
application
rate
on
treated
turf
(
7
lb
ai/
A),
but
with
the
lower
application
rate
(
0.9
lb/
ai/
A).
The
combined
MOE
was
590
and
was
not
of
concern.

Cancer
risks
were
not
calculated,
since
no
toxicological
endpoint
for
cancer
was
identified.
Page
46
of
46
3.2.6
Recommendations
for
Refining
Residential
Postapplication
Risk
Assessments
In
order
to
refine
this
residential
assessment,
data
on
actual
use
patterns
including
rates,
timing,
and
the
kinds
of
tasks
performed
are
required
to
better
characterize
ADBAC
risks.
