Alkyl Dimethyl Benzyl Ammonium Chloride (ADBAC)

Risk Assessment

Office of Pesticide Programs

Antimicrobials Division

U.S. Environmental Protection Agency

1801 South Bell St.

Arlington, VA 22202

Date: August 1, 2006

TABLE OF CONTENTS 

  TOC \o "1-5" \h \z \u    HYPERLINK \l "_Toc128908275"  1.0	EXECUTIVE
SUMMARY	  PAGEREF _Toc128908275 \h  3  

  HYPERLINK \l "_Toc128908276"  2.0	 PHYSICAL AND CHEMICAL PROPERTIES	 
PAGEREF _Toc128908276 \h  9  

  HYPERLINK \l "_Toc128908277"  3.0	ENVIRONMENTAL FATE	  PAGEREF
_Toc128908277 \h  12  

  HYPERLINK \l "_Toc128908278"  4.0	HAZARD CHARACTERIZATION	  PAGEREF
_Toc128908278 \h  13  

  HYPERLINK \l "_Toc128908279"  4.1 	Hazard Profile	  PAGEREF
_Toc128908279 \h  13  

  HYPERLINK \l "_Toc128908280"  4.2 	FQPA Considerations	  PAGEREF
_Toc128908280 \h  16  

  HYPERLINK \l "_Toc128908281"  4.3 	Dose-Response Assessment	  PAGEREF
_Toc128908281 \h  16  

  HYPERLINK \l "_Toc128908282"  4.4 	Endocrine Disruption	  PAGEREF
_Toc128908282 \h  17  

  HYPERLINK \l "_Toc128908283"  5.0	EXPOSURE ASSESSMENT AND
CHARACTERIZATION	  PAGEREF _Toc128908283 \h  18  

  HYPERLINK \l "_Toc128908284"  5.1	Summary of Registered Uses	  PAGEREF
_Toc128908284 \h  18  

  HYPERLINK \l "_Toc128908285"  5.2	Dietary Exposure and Risk	  PAGEREF
_Toc128908285 \h  18  

  HYPERLINK \l "_Toc128908286"  5.3	Drinking Water Exposures and Risks	 
PAGEREF _Toc128908286 \h  20  

  HYPERLINK \l "_Toc128908287"  5.4	Residential Exposure/Risk Pathway	 
PAGEREF _Toc128908287 \h  21  

  HYPERLINK \l "_Toc128908288"  6.0	AGGREGATE RISK ASSESSMENT AND RISK
CHARACTERIZATION	  PAGEREF _Toc128908288 \h  29  

  HYPERLINK \l "_Toc128908289"  6.1	Acute and Chronic Aggregate Risks	 
PAGEREF _Toc128908289 \h  30  

  HYPERLINK \l "_Toc128908290"  6.2	Short- and Intermediate-Term
Aggregate Exposures and Risks	  PAGEREF _Toc128908290 \h  31  

  HYPERLINK \l "_Toc128908291"  7.0	 CUMULATIVE EXPOSURE AND RISK	 
PAGEREF _Toc128908291 \h  33  

  HYPERLINK \l "_Toc128908292"  8.0	OCCUPATIONAL EXPOSURE ASSESSMENT	 
PAGEREF _Toc128908292 \h  34  

  HYPERLINK \l "_Toc128908293"  8.1 	Occupational Handler Exposures	 
PAGEREF _Toc128908293 \h  34  

  HYPERLINK \l "_Toc128908294"  8.2  	Occupational Post-application
Exposures	  PAGEREF _Toc128908294 \h  39  

  HYPERLINK \l "_Toc128908297"  8.3 	Wood Preservation	  PAGEREF
_Toc128908297 \h  41  

  HYPERLINK \l "_Toc128908298"  8.3.1 	Non-Pressure Treatment Scenarios
(Handler and Post-application)	  PAGEREF _Toc128908298 \h  41  

  HYPERLINK \l "_Toc128908299"  8.3.1.1	 Scenarios Assessed by Worker
Function	  PAGEREF _Toc128908299 \h  41  

  HYPERLINK \l "_Toc128908300"  8.3.1.2	Scenarios Assessed for Exposure
from Applications to  Existing Homes (Handler)	  PAGEREF _Toc128908300
\h  44  

  HYPERLINK \l "_Toc128908301"  8.3.2	Pressure Treatment Scenarios
(Handler and Post-Application)	  PAGEREF _Toc128908301 \h  45  

  HYPERLINK \l "_Toc128908302"  8.4	Data Limitations/Uncertainties	 
PAGEREF _Toc128908302 \h  45  

  HYPERLINK \l "_Toc128908303"  9.0	INCIDENT REPORTS	  PAGEREF
_Toc128908303 \h  47  

  HYPERLINK \l "_Toc128908304"  10.0	ENVIRONMENTAL RISK	  PAGEREF
_Toc128908304 \h  49  

  HYPERLINK \l "_Toc128908305"  11.0	REFERENCES	  PAGEREF _Toc128908305
\h  55  

  HYPERLINK \l "_Toc128908306"  Incidence Reports	  PAGEREF
_Toc128908306 \h  60  

  HYPERLINK \l "_Toc128908307"  APPENDIX A: Master ADBAC Label	  PAGEREF
_Toc128908307 \h  61  

 1.0	EXECUTIVE SUMMARY 

	This document provides a risk assessment of the Group II Quat Cluster. 
The Group II Quat Cluster group consists of structurally similar
quaternary ammonium compounds (“quats”) that are characterized by
having 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.  The group will be referred to
as ADBAC (alkyl dimethyl benzyl ammonium chloride) in this document. 

	ADBAC is the active ingredient in numerous types of products.  The
products are mainly disinfectants, sanitizers, and deodorants that are
used in agricultural, food handling, commercial/
institutional/industrial, residential and public access, and medical
settings. Examples of registered uses for ADBAC in these settings
include application to indoor and outdoor hard surfaces (e.g., walls,
floors, tables, toilets, and fixtures), eating utensils, laundry,
carpets, agricultural tools and vehicles, egg shells, hands and gloves,
shoes, milking equipment and udders, humidifiers, RV tanks, medical
instruments, human remains, ultrasonic tanks, reverse osmosis units, and
water storage tanks. There are also ADBAC-containing products that are
used in residential and commercial swimming pools, in aquatic areas such
as decorative ponds, decorative fountains, and agricultural watering
lines, and in industrial process and water systems such as once-through
and re-circulating cooling waters systems, cooling towers, evaporative
condensers, pasteurizers, drilling mud and packer fluids, oil well
injection and wastewater systems, and in pulp and paper products, water,
and chemicals. Additionally, ADBAC-containing products are used for wood
preservation through non-pressure and pressure-treatment treatments. 
There are registered uses for fogging and/or air deodorization in both
occupational and residential settings.  Products containing ADBAC are
formulated as liquid ready-to-use, soluble concentrate, pressurized
liquid, and water soluble packaging. The percentage of ADBAC in the
various end-use products ranges from 0.06% to 80% as reported in the
Master Label spreadsheet (Appendix A).   Residential products such as
EPA Reg. No. 10324-45 ranged up to 50% ADBAC for swimming pools and
spas. 

	The durations and routes of exposure evaluated in this assessment
include short-term (ST), intermediate-term (IT), and in some instances
long-term (LT) inhalation exposures, ST dermal exposures, and ST oral
exposures.  The inhalation endpoint (all durations) is based on an oral
NOAEL of 3 mg/kg/day from a developmental toxicity study in rabbits. 
The adverse effect for this endpoint is based on clinical signs of
toxicity in maternal rabbits. For the incidental oral exposures, the ST
and IT endpoints are based on adverse effects of decreased bodyweight
and food consumption in a developmental toxicity study in rats (NOAEL =
10 mg/kg/day). No short-term dermal endpoint for systemic effects was
selected for ADBAC, since no systemic effects were identified. However,
short- and intermediate-term dermal irritation endpoints were
identified. The short-term endpoint was determined from a 21-day dermal
toxicity in guinea pigs where a denuded non-vascularized epidermal layer
was observed at 40 mg ai/kg/day. The NOEAL from this study is 20 mg
ai/kg/day which is equivalent to 333 ug ai/cm2. The intermediate-term
dermal endpoint was determined from 90-day dermal toxicity in rats. The
NOAEL from this study is 20 mg ai/kg/day which is equivalent to 80 μg
ai/cm2.   The endpoint is the highest dose tested before irritation
became significant.  Because the effect is localized skin irritation, a
skin concentration (μg/cm2) of exposure, rather then a dose (mg/kg/day)
was used to assess the dermal risk concerns.  No body weight is needed
for the dermal irritation endpoint, since no systemic dose is
calculated. Note: Although the dose of 20 mg/kg/day is the same for both
dermal studies, the concentration of the skin of the animal was
different in each study because of the difference in the size of the
skin area dosed and the total amount of chemical applied (i.e., body
weights differed).  Because the toxicological endpoint for inhalation is
female-specific, a body weight of 60 kilograms is used in the
assessment.  The Agency’s level of concern (LOC) for occupational and
residential ADBAC inhalation and oral exposures is 100 (i.e., a margin
of exposure (MOE) less than 100 exceeds the Agency’s level of
concern). The level of concern is based on 10x for interspecies
extrapolation and 10x for intraspecies extrapolation.  The level of
concern for the dermal route of exposure for the irritation effect is a
target MOE of 10 (i.e., 3x for interspecies extrapolation and 3x for
intraspecies extrapolation).

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

Dietary Risk Summary

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

	Acute dietary risks were not assessed because an endpoint appropriate
for acute dietary assessment was not identified in the available
database for ADBAC.  For indirect and direct food contact along with
drinking water exposures, the percent of the chronic population adjusted
dose (% cPAD) is 3.5 percent for adults and 10.3 percent for children. 
Therefore, the dietary risks are not of concern for ADBAC.

Residential Risk Summary

Dermal

	

     For the residential handler dermal exposure and risk assessment,
dermal risks were calculated by comparing residues on the surface of the
skin to the short-term dermal irritation endpoint.  Residues on the
surface of the skin (dermal irritation exposure) were determined using
hand unit exposures from CMA/PHED adjusted for the surface area of the
hand (mg/lb ai/cm2), application rates, and use amounts. The dermal MOEs
were above the target MOE of 10 for all scenarios. Therefore, the risks
are not of concern.  

      The residential post-application dermal risks were assessed by
comparing the surface residue on the skin (dermal irritation exposure)
to the short-term dermal endpoint. It was assumed that during the
exposure period the skin repeatedly contacts the treated surface until a
steady-state concentration of residues is achieved on the skin. The
short-term endpoint was used because it was assumed that exposure does
not occur daily; for all of the residential scenarios, the
post-application dermal MOEs were above the target MOE of 10; therefore,
the risks do not exceed the level of concern.  

Inhalation

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

		For the residential post-application exposure and risk assessment, the
MOEs were above the target MOEs for all scenarios except for the
humidifier use.  This use is of concern. The MOEs for the humidifier use
are as follows: ST/IT 8-hr MOE = 71 for adults and 11 for children;
ST/IT 24-hr MOE = 10 for adults and 4 for children

Incidental Oral

		For the residential post-application incidental oral assessment, the
MOEs were above the target MOE of 100 for all scenarios; therefore, the
risks do not exceed AD’s level of concern.

Aggregate Risk Summary

	An acute dietary endpoint was not identified for ADBAC.  Therefore, an
acute dietary aggregate risk assessment was not conducted.  The chronic
dietary aggregate risk assessment includes direct and indirect food
contact uses as well as drinking water exposures. Based on the results
of the chronic aggregate assessment, the % cPAD for adults and children
are 3.5% and 10.3%, respectively.  Therefore, the chronic dietary
aggregate risks are not of concern (i.e., less then 100 % of cPAD).

	Since the ADBAC toxicity endpoints for the oral, dermal, and inhalation
routes of exposure are based on different toxic effects, these three
routes of exposure are not aggregated together for the short- and
intermediate-term aggregate assessment.  Instead, the short- and
intermediate-term aggregate assessment is based solely on the
co-occurrence of the same route of exposures.  Aggregate risks were
calculated using the total MOE approach.  Only the short-term aggregate
is presented because the endpoints for incidental oral as well as
inhalation are identical for the short- and intermediate-term durations.
 Moreover, only a short-term dermal exposure duration was identified.
The aggregate risks are not of concern for adults for any of the three
routes of exposure.  The aggregate adult MOE is 2,800 for oral, 42 for
dermal, and 630 for inhalation, which is greater than the target of 100
for the oral and inhalation routes, and a target MOE of 10 for the
dermal route.  For children, the aggregate risk estimate for each of the
routes of exposure are also above the target MOE of 100 for the oral and
inhalation routes, and a target MOE of 10 for the dermal route (MOE=220
for the oral route, 180 for the dermal route, and no co-occurrence for
the inhalation route);thus are not of concern.  It is important to note,
however, that some of the individual risks for scenarios not included in
the aggregate are of concern by themselves (e.g., the humidifier use). 

Occupational Risk Summary

Dermal

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

	Dermal irritation exposures are assumed to be negligible for all
post-application occupational scenarios, except those associated with
wood preservation. As with occupational handlers, dermal irritation
exposures and risks from post-application activities in a wood
preservation treatment facility will be mitigated using default personal
protective equipment requirements based on the toxicity of the end-use
product.  For construction workers handling treated wood, the calculated
MOEs are above the target MOE of 10, and therefore, not of concern.

Inhalation

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

  

Agricultural fogging (mixing and loading): ST/IT Inhalation MOE = 26

Medical premises, mopping: ST/IT Inhalation MOE = 95

Pulp and paper, liquid pump: ST/IT Inhalation MOE = 14

Once-through cooling water, metering pump: Using the average flow rate
for high flow streams (153 MGD) the ST Inhalation MOE = 50 for initial
applications and the IT MOE = 95 for maintenance applications; however,
using the average flow rate for low flow streams (5.9 MGD) the ST
Inhalation MOE = 1,300 for initial applications and the IT MOE = 2,500
for maintenance applications.

Small process water systems, liquid pour: ST/IT Inhalation MOE = 6

Wood Preservation (non-pressure treatment), blender/sprayer operator:
ST/IT/LT Inhalation MOE = 84

Wood Preservation (existing homes), airless sprayer: ST/IT/LT Inhalation
MOE = 17

	For the inhalation post-application exposure and risk assessment, the
MOEs were above the target MOE of 100 for all scenarios except for the
following scenarios listed below.

Fogging in a hatchery:	 The 8-hr MOE from 0 to 8 hours (immediately
after fogging) = 0.5; however, the 8-hr MOE from 2 to 10 hours (2 hour
re-entry interval) = 1,500.

Fogging in a food processing plant:  The 8-hr MOE from 2 to 10 hours (2
hour re-entry interval) = 1.  The difference in the MOEs for hatcheries
versus food processing plants is the assumed ventilation rate
(hatcheries assigned a higher rate; refinements could be made to the
food processing plants MOE if ventilation rates were provided).

Environmental Risk Summary

  SEQ CHAPTER \h \r 1 ADBAC is immobile and persistent; while it is not
likely to leach to groundwater, it may enter surface water through
sediment runoff.  The available soil mobility study shows that ADBAC has
a strong tendency to bind to sediment/soil with Freundlich Kads values
of 6,172 for sand soil, 10,797 for silt loam, 5,123 for sandy loam soil,
and 32,429 for clay loam. The corresponding Koc values are 6,171,657 for
sand soil, 2,159,346 for silt loam, 640,389 for sandy loam soil, and
1,663,039 for clay loam.  There are no guideline data for aerobic soil
degradation of ADBAC.  Because of its strong adsorption to soils, the
potential to reach aquatic water bodies via runoff or leaching is
limited.  ADBAC may, however, be transported off-site to aquatic water
bodies as entrained sediment or via spray drift during aerial or ground
spray applications.  ADBAC is hydrolytically stable under over the pH
5-9 range.  ADBAC is also stable to photodegradation.  Major degradates
were not identified in any of the available studies.

	Aquatic metabolism studies under aerobic and anaerobic conditions
indicate that ADBAC is stable to microbial degradation.  ADBAC did not
degrade in flooded sand loam soil that was incubated at 24-27°C in the
dark for up to 30 days in an aerobic aquatic metabolism study.  Under
anaerobic conditions, ADBAC was found to be very resistant to
degradation, with a calculated half-life of 1,815 days.      

	

	There is moderate potential for bioaccumulation of ADBAC in freshwater
fish.  Maximum bioconcentration factors (BCF) were 33X for edible
tissues (muscle, skin), 160X for nonedible tissues (viscera, head,
carcass), and 79X for whole fish tissues.  ADBAC is not expected to pose
a major concern for bioconcentration in aquatic organisms.	

	ADBAC Ecotox Summary for Agricultural Specific Uses:

	ADBAC is categorized as highly toxic to fish (LC50 = 280 μg ai/L) and
very highly toxic to aquatic invertebrates  (LC50 = 5.9 μg ai/L) on an
acute exposure basis.  Chronic effects were seen in fish at a
concentration of 32.2 μg ai/L and a no observable adverse effect
concentration (NOAEC) of 4.15 μg ai/L was established for aquatic
invertebrates.  Estimated environmental concentrations (EECs) for
aquatic ecosystems were calculated using the aquatic exposure model
PRZM/EXAMS (    HYPERLINK
"http://www.epa.gov/oppefed1/models/water/index.htm" 
http://www.epa.gov/oppefed1/models/water/index.htm ).  For the use of
ADBAC on nursery ornamentals, risk quotients (RQs) for freshwater fish
ranged from 1.99 to 5.26, exceeding the acute risk level of concern
(LOC) of 0.5 by up to ten-fold.  RQs for freshwater invertebrates range
from 94.41 to 249.66, exceeding the acute risk LOC by greater than
180-fold.  The chronic risk LOC (1.0) is exceeded many-fold for
freshwater fish (RQs 10-28) and for freshwater invertebrates (RQs
87-222).  For the turf and golf course uses, acute risk RQs for
freshwater fish range from 0.06 to 0.91, exceeding at least the
endangered species LOC (0.05) and the acute risk LOC in some scenarios. 
Acute risk RQs for freshwater invertebrates range from 2.3 to 10.6,
exceeding the acute risk LOC.  The other uses (ornamental ponds, pools
and puddles) of ADBAC are not thought to result in appreciable exposure
to aquatic ecosystems.

	ADBAC is categorized as moderately toxic to birds on an acute basis
(LC50 = 136 mg/kg-bw, with no chronic data available.  ADBAC is
categorized as slightly toxic to mammals on an acute basis (LD50 = 430
mg/kg-bw) and a chronic NOAEC of 44 mg/kg/day was established. 
Terrestrial EECs for animal exposure for the nursery ornamental and
turf/golf course uses were calculated with the TREX terrestrial exposure
model (  HYPERLINK
"http://www.epa.gov/oppefed1/models/terrestrial/index.htm" 
http://www.epa.gov/oppefed1/models/terrestrial/index.htm ).  The acute
risk LOC for terrestrial animals is 0.5 and the endangered species LOC
is 0.1.  The chronic LOC for terrestrial animals is 1.0.  For nursery
ornamentals, acute avian RQs ranged from 19 to 2101, exceeding the acute
LOC up to 4000-fold.  Chronic avian RQs could not be calculated to the
lack of toxicity data, but chronic risk is presumed.  Mammalian acute
RQs for the nursery use range from 1.2 to 182 and chronic RQs range from
11 to 1782.  For the turf and golf course use, acute avian RQs range
from 0.11 to 12.35, exceeding at least the endangered species LOC for
all size classes and forage items.  Again, chronic RQs cannot be
calculated, but chronic risk to avian species is presumed.  Acute risk
mammalian RQs from the turf/golf course use ranged from 0.01 to 7.9,
with exceedance of at least the endangered species LOC for all mammal
size classes foraging on short grass, tall grass and broadleaf plants
and small insects.  Chronic RQs for mammals are range from 0.07 to 77.2,
but exceed the LOC for all mammal size classes foraging on short grass,
tall grass and broadleaf plants and small insects.

	Although the algae control and mosquitocide uses are intended for
waterbodies that are disconnected from the larger watershed, making
exposure to fish and nontarget invertebrates unlikely, these uses result
in potential exposure to amphibians utilizing these waterbodies for some
portion of their lifecycle and to birds and mammals utilizing these
waterbodies as a source of drinking water.    The mosquito control use,
with an initial concentration of 200 ppm in the target waterbody
represents the greatest risk to terrestrial animals (algal control
initial target concentration is 5 ppm).  At this concentration, RQs for
amphibians are 0.71 for acute risk and 6.2 for chronic risk, both of
which exceed the LOC.  RQs for birds using these waterbodies for
drinking water range from 0.09 to 0.32, based on size class.  Smaller
birds face greater acute risk.  Chronic risk to birds is presumed. 
Neither acute nor chronic mammalian acute RQs exceed the LOCs at the 200
ppm initial concentration.  However, due to the persistence of ADBAC,
the concentrations in the target waterbodies could become much higher
than the initial concentrations, leading to exposure beyond that
accounted for in the risk assessment.

ADBAC Ecotox Summary For Antimicrobial-Specific Uses:

ADBAC is registered as an antimicrobial for several indoor use patterns
and for uses having potential for environmental exposure such as
once-through cooling towers and antisapstain wood preservation.   

	Only minimal environmental exposure is expected to occur from routine
use of ADBAC for indoor uses to control microorganisms.  The breakdown 
of ADBAC via sewage treatment is rapid and well documented in the
literature. 

	Tier I modeling for the once-through cooling tower use indicates that
ADBAC will result in acute and chronic risk to non-endangered and
endangered/threatened and freshwater fish, and acute risk to other
aquatic animals at all 3 dosages modeled (2.0 to 10.0 ppm).  This model
does not account for degradation making a final risk assessment
difficult without confirmatory data or higher tier modeling.

	An antisapstain wood preservation model was used to predict
environmental concentrations of ADBAC following application.  Fish and
algae are not expected to be impacted, however, non-endangered and
endangered/threatened aquatic invertebrates are expected to be adversely
affected by surface runoff.  The use of impervious barriers under and on
top of treated wood, and the installation of berms to prevent surface
water runoff from the storage area are recommended to mitigate aquatic
organism exposure.

	

2.0	 PHYSICAL AND CHEMICAL PROPERTIES

	The Group II Quat Cluster (ADBAC), is comprised of a group of
structurally similar quaternary ammonium compounds (“quats”) that
are characterized by having 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.  

	Currently, there are 21 active ingredients included in the group. 
Table 2.1 below provides the common chemical name, active ingredient
code, CAS number, chemical structure and number of registered product
for each compound. 

 



	R = C12 (5%)

C14 (60%)

C16 (30%)

	R = C12 (40%)

C14 (50%)

	R = C12 (50%)

C14 (30%)

C16 (17%)

	R = C12 (1%)

C14 (98%)

 	R = C12 (5%)

C14 (60%)

C16 (30%)

	R = C12 (25%)

C14 (60%)

	R = C8-10 (2.5%)

C14 (61%)

C16 (23%)

	R = C12 (14%)

C14 (58%)

	R = C12 (65%)

C14 (25%)

	R = C12 (67%)

C14 (25%)

C16 (7%)

	R = C12 (61%)

C14 (23%)

C16 (11%)

	R = C12 (3%)

C14 (95%)

	R = C12 (70%)

	R = C12 (5%)

C14 (90%)

	R = C8   – Not specified

C10 – Not specified

C12 (67%)

C14 (25%)

C16 (7%)

 	R = C12 (40%)

C14 (50%)

 	R = C12 (68%)

 	R = C12 (50%)

C14 (30%)

C16 (17%)

C18 (3%)

069112

n-Alkyl dimethyl 1-naphtylmethyl ammonium chloride

R=C12 (98%)

C14 (2%)

069125

Dodecyl benzyl trimethyl ammonium chloride



169159

n-alkyl dimethyl dimethyl ammonium chloride

R= C12 (68%)

 

69129	1399-80-0	Methyl dodecyl benzyl tri methyl ammonium chloride  -
80%

 



		Table 2.2 shows physical/chemical characteristics that have been
reported for ADBAC.

Table 2.2.  Physical/Chemical Properties of ADBAC





Parameter	

ADBAC



Molecular Weight	377.83



Density	0.9429 g/cm3 at 25 C



Boiling Point	Could not be established



Water Solubility	Completely soluble



Vapor Pressure	3.53E-12 mmHg



3.0	ENVIRONMENTAL FATE

	ADBAC is used primarily as a disinfectant, a sanitizer, or as a
microbicide/microbiostat.  It also serves as an algaecide,
bactericide/bacteriostat, fungicide/fungistat, insecticide, miticide,
virucide, defoliant, feeding depressant, repellent and tuberculocide. 
Use sites for ADBAC include agricultural premises and equipment, food
handling, commercial, industrial and institutional settings, residential
areas or areas of public access, pets and kennels, medical facilities,
swimming pools, aquatic areas, and industrial water systems.   ADBAC is
also used as a wood preservative.  As an agricultural pesticide, ADBAC
is used for ornamental plants, shrubs, and vines.  Some of the required
guideline studies for an environmental fate assessment have been
submitted.  The Agency is using the available environmental fate studies
for fate assessment of ADBAC to fulfill the reregistration requirements.
 Because of its use as a wood preservative, an aqueous availability
study evaluating the leachability of ADBAC from treated wood is
required.  However, no data have been submitted to the Agency.

	ADBAC is hydrolytically stable under abiotic and buffered conditions
over the pH 5-9 range.  The calculated half-lives for ADBAC were 379
days at pH 9, 150-183 days at pH 5 and pH 7.  ADBAC is also stable to
photodegradation in pH 7 buffered aqueous solutions.  However, in the
presence of a photosensitizer (e.g., acetone), ADBAC has been shown to
degrade with an estimated half-life of 7.1 days.

	Aquatic metabolism studies under aerobic and anaerobic conditions
indicate that ADBAC is stable to microbial degradation.  ADBAC did not
degrade in flooded sand loam soil that was incubated at 24-27C in the
dark for up to 30 days in an aerobic aquatic metabolism study.  Under
anaerobic conditions, ADBAC was found to be very resistant to
degradation with a calculated half-life of 1,815 days.  However, a
report on the biodegradability of ADBAC prepared by the Registrant
concluded that the degree of ADBAC biodegradability is variable and is
influenced by the chemical concentration, alkyl chain length, the
presence of anionic moieties and the quantity and characteristics of the
microbial population.   According to this report, ADBAC is biodegradable
and environmentally acceptable.  This report was based on information
from the open literature, unpublished sources, and meeting proceedings
and has not been reviewed by the Agency.    

	ADBAC is immobile in soil. The available soil mobility study shows that
ADBAC has a strong tendency to bind to sediment/soil with Freundlich
Kads values were 6,172 for the sand soil, 10,797 for the silt loam,
5,123 for the sandy loam soil, and 32,429 for the clay loam and the
corresponding Koc values were 6,171,657 for the sand soil, 2,159,346 for
the silt loam, 640,389 for the sandy loam soil, and 1,663,039 for the
clay loam.  Because of its strong adsorption to soils, ADBAC is not
expected to contaminate surface and ground waters.

	Bioaccumulation of ADBAC in freshwater fish is not likely to occur. 
Maximum bioconcentration factors (BCF) were 33X for edible tissues
(muscle, skin), 160X for nonedible tissues (viscera, head, carcass), and
79X for whole fish tissues.  During depuration, ADBAC residues were 2.4
ppm in edible tissues, 3.7 ppm in whole fish tissues, and 5.3 ppm in
nonedible tissues.  ADBAC is not expected to pose a concern for
bioconcentration in aquatic organisms.

4.0	HAZARD CHARACTERIZATION

4.1 	Hazard Profile  tc "3.1 Hazard Profile " \l 2 

In an acute oral toxicity study (MRID 45109204), the acute oral LD50 of
ADBAC (82.26% a.i.) was determined to be 304.5 mg/kg (both sexes
combined) and was assigned  Toxicity Category II.  In an acute dermal
toxicity study (MRID 45109202), the acute dermal LD50 of  ADBAC (82.26%
a.i.) was determined to be  930 mg/kg (both sexes combined) and was
assigned Toxicity Category II.  In an acute inhalation toxicity study
(MRID 44885201), the acute LC50 of ADBAC (82.26% a.i.) was determined to
be 0.054 < LC50 < 0.51 mg/L and was assigned a  Toxicity Category II. 
The primary eye irritation study was waived and assigned a Toxcity
Category I for technical grade ADBAC (80% a.i).   For primary dermal
irritation (MRID 45109201), ADBAC (82.26% a.i.) was corrosive to rabbits
(Toxicity Category I).  In a dermal sensitization study (MRID 45109203),
ADBAC (82.26% a.i.) was not a sensitizer to guinea pigs.  In a
photoallergy (light) sensitization study (MRID 40958501 and MRID
44825002), ADBAC (80% a.i.) was not a photosensitizer.

In a subchronic oral toxicity study in rats (MRID 40746601), ADBAC is
found to also have a low order of toxicity, in that manifestations of
toxicity are non-specific (decreased body weight gain, food
consumption), and occur at relatively high doses (greater than 50
mg/kg/day in males, greater than 300 mg/kg/day in females). This result
is also obtained from chronic toxicity studies in rats and mice, where
effects were also non -specific (decreased body weight gain and food
consumption), and occurred at relatively high doses.  In a 21-day dermal
toxicity study in guinea pigs (MRID 41105801), no significant systemic
effects were observed using a chemical mixture of 4% ADBAC/6% DDAC, but
denuding of the epidermal layer was observed at the highest tested, 1000
mg/kg/day.  In a 90-day dermal toxicity study in rats (MRID 41499601)
using technical grade ADBAC , dermal applications of ADBAC (81.09% a.i.)
to rats did not elicit systemic or dermal toxicity up to the highest
dose tested, 20 mg/kg/day, before dermal irritation became significant. 


ADBAC has been examined for effects on development of the mammalian
fetus and effects on reproductive function.  In developmental studies
with rats (range-finding MRID 42645101 and main study MRID 42351501) and
rabbits (range-finding MRID 42734401 and main study MRID 42392801),
developing fetuses showed no increased sensitivity to the toxicity of
ADBAC in relation to adult animals.  In a 2-generation reproductive
toxicity study (MRID 41385001), effects on rat pups were observed in the
absence of maternal toxicity, raising some concern for the effects of
ADBAC on reproductive function.  However, the effects observed were
non-specific (decreased pup body weight and weight gain during
lactation), and there were no effects of ADBAC on reproductive indices. 

In a chronic toxicity study in dogs (MRID 43221101), groups of 4 male
and female beagle dogs per group received either 0, 120, 400, or 1200
ppm (0, 3.79, 13.1, or 33.8 mg/kg/day in males and 0, 3.67, 14.6, or
38.6 mg/kg/day in females) alkyl dimethyl benzyl ammonium chloride
[ADBAC, 80% a.i.] as a direct dietary admix for one year.  Systemic
toxicity was observed at 400 ppm and above in female dogs and at 1200
ppm in males as reduced body weight gain (approximately 10% reduction)
after 52 weeks of exposure. Food consumption was decreased in the 1200
ppm males and females for the entire study period (approximately 15%
reduction in males and 5% reduction in females).  Based on the data in
this study, the Systemic Toxicity NOAEL was 120 ppm (3.79 mg/kg/day in
males, 3.67 mg/kg/day in females) and the LOAEL was 400 ppm (13.1
mg/kg/day in males, 14.6 mg/kg/day in females) based on reduced body
weight gain.

ADBAC has been tested for carcinogenicity in long term studies with both
rats (MRID 41947501) and mice (MRID 41765201).  In both studies, tested
to adequate dose levels, ADBAC was negative for induction of tumors in
both species.  This result is supported by results of testing in a
battery of mutagenicity studies, including an HGPRT/CHO for ward
mutation assay (MRID 42290801, reformat of MRID 41012701), an in vivo
bone marrow chromosome aberration assay (MRID 40311101, supplement MRID
43037701), and an unscheduled DNA synthesis (UDS) assay (MRID 42290802,
reformat of 41012601), which show ADBAC to be negative for mutagenic
effects.

The metabolism of ADBAC was investigated in MRID 41087701. The majority
of administered radioactive ADBAC is eliminated in feces from oral
administration.  Intravenous administration also shows elimination of a
significant proportion of ADBAC in feces, indicating elimination through
the bile. Tissue retention of orally administered radioactivity is
negligible. 

 tc \l2 "3.1	Acute Toxicity 

Acute toxicity data for ADBAC are summarized below (Table 4.1)

Table 4.1.  Acute Toxicity of ADBAC.

Guideline Number	

Test Substance	

MRID	

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)

	

II



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



4.2 	FQPA Considerations  tc "3.2   FQPA Considerations " \l 2  

	Under the Food Quality Protection Act (FQPA), P.L. 104-170, which was
promulgated in 1996 as an amendment to the Federal Insecticide,
Fungicide, and Rodenticide Act (FIFRA) and the Federal Food, Drug and
Cosmetic Act (FFDCA), the Agency was directed to "ensure that there is a
reasonable certainty that no harm will result to infants and children"
from aggregate exposure to a pesticide chemical residue.  The law
further states that in the case of threshold effects, for purposes of
providing this reasonable certainty of no harm, "an additional tenfold
margin of safety for the pesticide chemical residue and other sources of
exposure shall be applied for infants and children to take into account
potential pre- and post-natal toxicity and completeness of the data with
respect to exposure and toxicity to infants and children. 
Notwithstanding such requirement for an additional margin of safety, the
Administrator may use a different margin of safety for the pesticide
residue only if, on the basis of reliable data, such margin will be safe
for infants and children."

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

4.3 	Dose-Response Assessment  tc "3.3 Dose-Response Assessment " \l 2  

	Table 4.2 summarizes the toxicological endpoints for ADBAC (USEPA,
2006).  

Table 4.2  Summary of Toxicological Endpoints for ADBAC

Exposure

Scenario	Dose Used in Risk Assessment

(mg/kg/day)	Target MOE or UF,

Special FQPA SF

for Risk Assessment	Study and Toxicological Effects

Acute Dietary

(general population; females 13+)	An acute dietary endpoint was not
identified in the data base.  This risk assessment is not required

Chronic Dietary	

NOAEL =44 mg/kg/day

	FQPA SF = 1

UF = 100 (10x inter-species extrapolation, 10x intra-species variation)
Chronic toxicity/carcinogenicity –rat MRID 41947501

LOAEL = 88 mg/kg/day, based on decreased body weight and weight gain  



Chronic RfD = 0.44 mg/kg/day

Incidental Oral (short-term)	NOAEL = 10 mg/kg/day

	FQPA SF = 1

UF = 100 (10x inter-species extrapolation, 10x intra-species variation)
Developmental Toxicity – Rat, 

MRID 42351501

LOAEL = 30 mg/kg/day, based on decreased body weight and food
consumption 

Incidental Oral (intermediate-term)	NOAEL = 10 mg/kg/day

	FQPA SF = 1

UF = 100 (10x inter-species extrapolation, 10x intra-species variation)
Developmental Toxicity – Rat, 

MRID 42351501

LOAEL = 30 mg/kg/day, based on decreased body weight and food
consumption

Short-Term

Dermal 	NOAEL= 20 mg a.i./kg/day

(333 µg/cm2)a	FQPA SF = 1

UF = 10 (3x inter-species extrapolation, 3x intra-species variation)
21-day dermal toxicity- guinea pigs MRID 41105801

LOAEL = 40 mg a.i./kg/day, based on denuded non-vascularized epidermal
layer 

Short-Term dermal 	NOAEL = 20 mg ai/kg/day

 (80 µg ai/cm2) b	UF = 10 (3x inter-species extrapolation, 3x
intra-species variation)	21-day dermal toxicity in rats MRID 41499601

20 mg ai/kg/day is the highest dose tested before irritation became
significant at day 43.

Short-Term Dermal (technical grade a.i.)

	No endpoint identified from the available data on dermal irritation.
Dermal irritation in the 90-day dermal toxicity study was not evident
until day 43 (MRID 41499601).  

Long-Term Dermal (TGAI)	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.

Inhalationc

(Any time point)	NOAEL= 3 mg/kg/day

MOE = 100c

	UF = 100 (10x inter-species extrapolation, 10x intra-species variation)

Note:  an additional 10x is used for route extrapolation to determine if
a confirmatory study is needed	Developmental Toxicity – rabbit, MRID
42392801

LOAEL = 9 mg/kg/day, based on clinical signs of toxicity in maternal
rabbits

UF = uncertainty factor, FQPA SF = FQPA safety factor, NOAEL = no
observed adverse effect level, LOAEL = lowest observed adverse effect
level, RfD = reference dose, MOE = margin of exposure, LOC = Level of
concern, NA = Not Applicable.

a  Formulated-based dermal endpoint = (20 mg a.i./kg guinea pig x 0.43
kg guinea pig x 1000 ug/mg) / 25.8cm2  area of guinea pig dosed = 333
µg ai/cm2 .

b  TGAI-based dermal endpoint = (20 mg ai/kg rat x 0.2 kg rat x 1000
ug/mg) / 50cm2  area of rat dosed = 80 µg ai/cm2  .

c  SEQ CHAPTER \h \r 1 aAn additional uncertainty factor of 10x is
applied for use of an oral endpoint for route-to-route extrapolation to
determine if a confirmatory inhalation toxicity study is warranted.

4.4 	Endocrine Disruption

	  SEQ CHAPTER \h \r 1 EPA is required under the FFDCA, as amended by
FQPA, to develop a screening program to determine whether certain
substances (including all pesticide active and other ingredients) “may
have an effect in humans that is similar to an effect produced by a
naturally occurring estrogen, or other such endocrine effects as the
Administrator may designate.”  Following recommendations of its
Endocrine Disruptor and Testing Advisory Committee (EDSTAC), EPA
determined that there was a scientific basis for including, as part of
the program, the androgen and thyroid hormone systems, in addition to
the estrogen hormone system.  EPA also adopted EDSTAC’s recommendation
that the Program include evaluations of potential effects in wildlife. 
For pesticide chemicals, EPA will use FIFRA and, to the extent that
effects in wildlife may help determine whether a substance may have an
effect in humans, FFDCA authority to require the wildlife evaluations. 
As the science develops and resources allow, screening of additional
hormone systems may be added to the Endocrine Disruptor Screening
Program (EDSP).

5.0	EXPOSURE ASSESSMENT AND CHARACTERIZATION  tc \l1 "4.0	RESIDENTIAL
EXPOSURE ASSESSMENT 

	5.1	Summary of Registered Uses tc \l2 "4.1	Summary of Registered Uses 

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

	Products containing ADBAC can be used as general cleaners,
disinfectants, and deodorizers in the home. These products are primarily
for use on indoor surfaces such as hard floors, carpets, walls, bathroom
fixtures, trash cans, toilet bowls, and household contents. 
Additionally, other uses in the home include aerosol air deodorizing
products, liquid laundry deodorizers that are added to the final rinse
of the wash cycle, algaecide/bactericides that are added to portable
humidifiers and RV holding tanks, disinfectants for musical instrument
mouthpieces and reeds, swimming pools, and decorative ponds and
fountains.  Residents may also be exposed to items that have been
treated with ADBAC in occupational settings, such as dimensional lumber
for decks and play sets. Appendix A presents the master label summary of
representative uses for ADBAC.

	The non antimicrobial uses of ADBAC are assessed in a separate
memorandum by the Health Effects Division (USEPA 2006a).  The uses
include agricultural and homeowner uses on lawns, ornamentals, etc.   

	5.2	Dietary Exposure and Risk  tc "4.2 	Dietary Exposure and Risk " \l
2   tc "5.2	Dietary Exposure for Active Ingredient Uses " \l 2 

	In the absence of data for residues of ADBAC on treated food contact
surfaces, the Agency estimated residue levels that may occur in food
from the application rates on food contact surfaces.  In addition, the
food and bottling and packaging uses are also included.

Dietary exposures from poultry hatcheries, mushroom houses and
hydroponic uses are expected to be much lower than the dietary exposures
resulting from the surface disinfectant and sanitizing uses; therefore,
these uses were not assessed separately.  

	To estimate the Estimated Daily Intake (EDI) to treated surfaces, an
FDA (FDA, 2003) model was used in lieu of residue data.  The maximum
application rate for ADBAC in food handling establishments from the
various labeled ready-to-use products is 0.0017 pounds per gallon of
treatment solution.  The results of the EDI calculations presented in
this assessment are based on food contacting 2,000 cm2 or 4,000 cm2 (50%
and 100% of the FDA worst case scenario, for countertops and utensils,
respectively) of treated surfaces, and that 10% of the pesticide migrate
to food.  The use of the 10% transfer rate, instead of the use of a 100%
transfer rate that is used in the FDA Sanitizer Solution Guidelines,
requires the submission of confirmatory data to establish the
reliability of the use of the 10% transfer rate.  These daily estimates
were conservatively used to assess chronic dietary risks (i.e., percent
chronic population adjusted dose or %cPAD).  Acute dietary risks were
not assessed because an acute toxicity value was not identified.  The %
cPAD does not exceed 100%.  The estimated EDI and % cPAD for food
contact surfaces are presented in Table 5.1.

Table 5.1: Calculated EDIs and cPAD for Utensils and Countertops

Exposure Group	Utensils	Countertops	Aggregate

	EDI (mg/day)	DDD (mg/kg/d)	% cPADa	EDI (mg/day)	DDD (mg/kg/d)	% cPADa
EDI (mg/day)	DDD (mg/kg/d)	% cPADa

Adult males	0.0815	0.00116	0.265	0.0815	0.00243	0.265	0.252	0.00359
0.530

Adult females	0.0815	0.00136	0.309	0.0815	0.00284	0.309	0.252	0.00419
0.680

Children	0.0815	0.00543	1.23	0.170	0.0113	1.23	0.252	0.0168	2.46

a  % PAD = exposure (DDD) /(cPAD) x 100. 

EDI is the estimated daily intake (mg/day).

DDD is the dietary daily dose (mg/kg/day).

	The maximum application rate for ADBAC for bottling/packing of food is
0.0103 lbs a.i per gallons of solution.  EDI estimates were calculated
using an approach similar to that used for treated food-contact surfaces
and food utensils.  Exposure was assumed to occur through the ingestion
of three food products that might be packaged with treated material:
milk, egg products, and beverages (alcoholic and non-alcoholic).  The
calculated %cPAD did not exceed 100%.  The results of the EDI and % cPAD
are presented in Table 5.2.

Table 5.2:  Calculated EDIs and cPAD for Representative Dairy and
Beverage Consumption

Food Type	Exposure Group	EDI (mg/day)	DDD (mg/kg/d)	% cPAD

Milk	Adult Male	3.8 x 10-3	5.37 x 10-5	1.2 x 10-2

	Adult Female

3.86 x 10-4	1.4 x 10-2

	Childa	2.4 x 10-3	1.66 x 10-4	3.6 x 10-2

Egg product	Adult Male	2.8 x 10-5	4.06 x 10-7	9.1 x 10-5

	Adult Female

4.69 x 10-7	1.1 x 10-4

	Child a	1.58 x 10-5	1.20 x 10-6	2.7 x 10-4

Beverages, non-alcoholic	Adult Male	3.2 x 10-4	4.57 x 10-6	1.0 x 10-3

	Adult Female

1.96 x 10-6	1.2 x 10-3

	Childa	2.0 x 10-4	1.37 x 10-5	3.1 x 10-3

Beverages, alcoholic, beer	Adult Male	2.4 x 10-5	3.47 x 10-6	7.9 x 10-4

	Adult Female

4.04 x 10-6	9.0 x 10-4

a Child EDI values are multiplied by a modification factor of 0.644	

	5.3	Drinking Water Exposures and Risks  tc "5.4	Drinking Water
Exposures and Risks " \l 2 

	As an outdoor pesticide, ADBAC is used on nursery ornamentals, turf,
and for mosquito control in ponds and puddles and as an algaecide in
decorative pools.  For the mosquito control use and the algaecide use on
decorative pools, the labels suggest that the use sites (water bodies)
are ornamental and periodic in nature and as such disconnected from the
larger watershed.  Therefore, for the purposes of this assessment these
uses were not considered potential sources of drinking water exposure. 
This assessment only considered the labeled turf and nursery uses for
ADBAC.  Foliar spray, drench and “dribble” applications are allowed.
 

	Tier 1 surface water and groundwater modeling was conducted for the
labeled nursery ornamental use (EPA Reg. No. 58044-3, 53642-1), which
represents the highest use rate of all labeled uses with an application
rate of 302 lbs. a.i./A and a maximum of 3 applications per year.  Since
the tier I models are not dependent on “crop” type, the EDWCs
determined for the nursery ornamental use are also protective of all
other uses with lower application rates.  The recommended estimated
drinking water concentrations (EDWCs) for the human health risk
assessment are in Table 5.3 and are based on the nursery ornamental use
pattern.  There were no major degradates of ADBAC in the laboratory
studies.  (EFED Memo, 2006 by Marietta Echeverria to Jacqueline
Campbell-McFarlane: Tier I Drinking Water Assessment for alkyl*dimehtyl
benzyl ammonium chloride (50%C14, 40%C12, 10%C10) (ADBAC) and Didecyl
dimethyl ammonium chloride, (DDAC))

	An acute oral toxicological endpoint was not established for ADBAC. 
Therefore, only the chronic drinking water exposure is calculated.  The
adult chronic drinking water dose is 0.009 mg/kg/day (i.e., average EDWC
331 ug/L x 2 L/day consumption x 1/70 kg BW).  The children chronic
drinking water dose is 0.022 mg/kg/day (i.e., average EDWC 331 ug/L x 1
L/day consumption x 1/15 kg BW). There are no drinking water concerns
with ADBAC as the concentrations are much lower than LOC.

Table 5.3. Tier I Estimated Drinking Water Concentrations (EDWCs) Based
on Aerial Application of ADBAC on Nursery Ornamentals

Drinking Water Source (Model)	Use rate (lbs ai/A/year)	EDWC (ppb)

Surface water (FIRST)

Acute (peak)

Chronic (annual average)	906	

13,129

331

Groundwater (SCIGROW)	906	5.4



	5.4	Residential Exposure/Risk Pathway tc \l2 "4.4	Residential
Exposure/Risk Pathway 

	The exposure scenarios assessed in this document for the representative
antimicrobial uses selected by the Agency to represent the residential
risks include:

Indoor hard surfaces (e.g., mopping, wiping, trigger pump sprays);

Air deodorizer;

Carpets;

Swimming pools;

RV holding tanks;

Wood preservative;

Textiles (e.g., diapers treated during washing);

Musical instrument mouthpieces; 

Humidifiers;

Ornamental Plants; and

Artificial Turf

Exposure Data and Assumptions

	The residential handler scenarios were assessed to determine dermal and
inhalation exposures.  Surrogate dermal and inhalation unit exposure
values were taken from the PHED data presented in HED’s Residential
SOPs (USEPA, 1997) and from the CMA data from the EPA memorandum
Evaluation of Chemical Manufacturers Association Antimicrobial Exposure
Assessment Study (USEPA, 1999).  Specific surrogate data used in
determining the dermal and inhalation exposures are reported below:

    

For the mopping, wiping, low pressure hand wand, liquid pour in swimming
pool and RV holding tank scenarios the CMA data were used; and

For aerosol spray and trigger pump scenarios the PHED data were used.

	The quantities handled/treated for the handler scenarios were estimated
based on information from various sources, including Antimicrobial
Division estimates. 

For mopping scenarios, it is assumed that 1 gallon of diluted solution
is used.

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

For aerosol sprays, it is assumed that one can is used. The net weight
of the can was not provided on the label; therefore, it was assumed that
the can contained 16-oz of product.

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

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

For liquid pour in RV holding tank scenario, it was assumed that one
tank would be treated.  The product label states a maximum application
rate of 4 oz (0.031 gallons) product per tank.

                        For agricultural exposures, residential
exposures may occur during the application of ADBAC to ornamental
plants, shrubs, trees as well as seedlings, seeds, and cuttings,
residential/commercial turf, golf courses, and fountains/water displays,
sewage treatment systems, standing water for mosquito control. As with
the antimicrobial use, homeowners are assumed to complete elements of an
application (mix/load/apply) without the use of personal protective
equipment. 

            	The quantitative exposure/risk assessment developed for
residential handlers is based on these scenarios.

Mixer/Loader/Applicators:	

(1)	Liquid Formulations: Low Pressure Handwand (PHED data for dermal and
ORETF data for inhalation)

 (2)	Dry Flowable Formulations: Low Pressure Handwand (using liquid
concentrate PHED data for dermal and liquid concentrate ORETF data for
inhalation)

(3)	Liquid Concentrates: Hose-End Sprayer (PHED data for dermal and
ORETF data for inhalation)

(4) 	Dry Flowable Formulations: Hose-End Sprayer (no data)

(5) 	Ready-to-Use Formulations: Hose-End Sprayer (no data) 

(6) 	Liquid Concentrates: Watering Can (using PHED hose-end sprayer data
for dermal and ORETF hose-end data for inhalation)

(7) 	Ready to Use Formulations via Trigger-Pump Sprayer (PHED data for
aerosol can for dermal and ORETF data for inhalation), and

(8) 	Dip or Soak Applications (no data)

	Post-application scenarios have been developed that encompass multiple
products, but still represent a high end exposure scenario for all
products represented.  Representative post-application scenarios
assessed include crawling on treated hard surfaces, carpets, and treated
lumber such as decks/play sets (dermal and incidental oral exposure to
children), wearing treated clothing (dermal exposure to adults and
children and incidental oral exposure to children), using air
deodorizers (adult and child inhalation exposure), using portable
humidifiers (adult and child inhalation exposure), swimming in treated
pools (adult and child incidental ingestion), and using treated
instrument mouthpieces and reeds (child and adult incidental exposure. 
Representative post-application scenarios for agricultural uses assessed
include adults contacting treated lawns and ornamental plants (adult
derma exposure) and children’s incidental oral activities on treated
lawns such as hand-to-mouth activity, object to mouth, and soil
ingestion.  Data sources and methodologies include the HED Residential
SOPs (USEPA 2000, 2001), Human and Environmental Risk Assessment (HERA)
Guidance Document (2003 and 2005), the DDAC wood preservative task force
study (MRID 455243-04), the Multi-Chamber Concentration and Exposure
Model (MCCEM), the SWIMODEL, Pesticide Handlers Exposure Database
(PHED), and Outdoor Residential Exposure Task Force (ORETF) studies.

Since no toxicological endpoint of concern was identified for dermal
systemic adverse effects, both the handler and the post-application
dermal risks were assessed using the short-term toxicological endpoint
for dermal irritation.  The duration of exposure for most homeowner
handler exposures is believed to be best represented by the short-term
duration (1 to 30 days).  The reason that short term duration was chosen
to be assessed is because the different handler and post-application
scenarios are assumed to be episodic, not daily.  

Risk Characterization of Antimicrobial Uses

	A summary of the residential handler inhalation risks are presented in
Table 5.4.  Although the inhalation endpoint represents short-,
intermediate-, and long-term durations, the exposure duration of most
homeowner applications of cleaning products is believed to be best
represented by the short-term duration.  The inhalation toxicological
endpoint is based on an oral study because a route-specific inhalation
study is not available.  The calculated inhalation MOEs are above the
target MOE of 100.  The dermal MOEs are presented in Table 5.5.  The
dermal MOEs are above the target MOE of 10.

Table 5.4 Short-Term Residential Handler Inhalation Exposures and MOEs

Exposure Scenario

Application Method	Application Method	Application Ratea	Quantity
Handled/ Treated per dayb	MOE c 

(Target MOE = 100)

Application to indoor hard surfaces	Mopping	0.025 lb ai/gal	1 gallon
3,000

	Wiping	0.025 lb ai/gal	0.13 gallon	820

	Trigger Spray	0.025 lb ai/gal	0.13 gallon	23,000



Air deodorization	

Aerosol Spray	0.2% ai by weight	1 can (1 lb)	38,000

Application to Carpets	Low Pressure Spray	0.014 lb ai/gal	2 gallons
9,200

Application to Swimming Pools	Liquid Pour	0.000052 lb ai/gal	20,000
gallons	50,000

Application to RV holding tanks	Liquid Pour	0.834 lb ai/gal	0.031 gal (1
tank at 4 oz product/tank)	3,700

a	Application rates are the maximum application rates determined from
EPA registered labels for ADBAC.

b	Amount handled per day values are estimates  or label instructions.	

c	MOE = NOAEL / Absorbed Daily Dose.  [Where short-term NOAEL = 3
mg/kg/day for inhalation]. Target MOE = 100.

Table 4.3 ADBAC Short-Term Residential Handler Dermal Risks

Exposure Scenario	Application Method	Application Ratea 

(lb ai/gal)	Quantity Handled/ Treated per dayb	Hand Unit Exposure
Adjusted for Surface Area

(mg/lb ai/cm2)c	

Dermal Skin Irritation Exposure d

(µg/cm2)	MOE e

(Target MOE = 10)

Application to indoor hard surfaces	Mopping	0.025 lb ai/gal	1 gallon
0.063	1.587	210



0.0070 lb ai/gal

	0.44	760

	Wiping	0.025 lb ai/gal	0.13 gallon	1.341	4.363	76



0.0070 lb ai/gal

	1.22	270

	Trigger Spray	0.025 lb ai/gal	0.13 gallon	0.129	0.420	790



0.014 lb ai/gal

	0.24	1,400



Air deodorization	

Aerosol Spray	0.2% ai by weight	1 can (1 lb)	0.129	0.259	1,300

Application to Carpets	Low Pressure Spray	0.014 lb ai/gal	2 gallons
0.161	4.615	72

Application to RV holding tanks	Liquid Pour	0.834 lb ai/gal	0.031 gal (1
tank at 4 oz product/tank)	0.000239	0.0062	54,000

Application to swimming pools	Liquid Pour	0.000052 lb ai/gal	20,000
gallons	0.000239	0.25	1,300

a	Application rates are the maximum application rates determined from
EPA registered labels for ADBAC.

b	Amount handled per day values are estimates  or label instructions.

c	Unit Exposure (mg/lb ai/cm2) = Unit Exposure from PHED or CMA (mg/lb
ai) / surface area of hand (820 cm2).

d	Dermal Skin Irritation Exposure (µg /lb ai/cm2) = Unit Exposure
(mg/lb ai/cm2) x Application Rate (lb ai/gal) x Quantity Treated
(gal/day) x 1,000 (g/mg

e 	MOE = NOAEL (µg /cm2)/ Surface Residue on Skin (µg/cm2).  [Where
short-term dermal formulated-based NOAEL = 333 µg/cm2]. Target MOE =
10.

	

	A summary of the residential post application risks are presented in
Table 5.6.  Although the inhalation endpoint represents short-,
intermediate-, and long-term durations, the exposure duration of most
homeowner applications of cleaning products is believed to be best
represented by the short-term duration.  The inhalation toxicological
endpoint is based on an oral study because a route-specific inhalation
study is not available.  The calculated dermal and incidental oral MOEs
are above the target MOE of 10 and 100, respectively. The inhalation
MOEs are above the target MOE of 100 for all scenarios, except the
humidifier.  The 24-hour inhalation MOEs for adults and children are 10
and 4, respectively.  

Table 5.6.  Short-term Residential Post Application Risks for Adults and
Children.

Exposure Scenario	Dermal MOE	Incidental Ingestion MOE	Inhalation MOE

Child playing on floor	1,100	610	NA

Child playing on carpet	1,200	330	NA

Clothing

(100% residue transfer)	210 adults and children	1900	NA

Child playing on decks/play sets	110 max	360	NA

Air deodorizer	NA	NA	5,700 adults



	1,800 children

Swimming	NA	Ranges from 400 to 4,800 for adults and children	NA

Humidifiers	NA	NA	Adult 10 (24-hrs)



	Child 4 (24-hrs)

Instrument mouthpiece/reed	NA	No data	NA

NA = not assessed because negligible exposure is assumed by that route
for the exposure for the scenario of concern.

Risk Characterization of Agricultural Uses

A summary of the residential handler inhalation risks are presented in
Table 5.7.  Although the inhalation endpoint represents short-,
intermediate-, and long-term durations, the exposure duration while
treating turf and ornamental plants is believed to be best represented
by the short-term duration due to the infrequent use patterns associated
with these products.  The inhalation toxicological endpoint is based on
an oral study because a route-specific inhalation study is not
available.  The calculated inhalation MOEs are above the target MOE of
100.  The dermal MOEs are presented in Table 5.8.  The dermal MOEs are
above the target MOE of 10.

Table 5.7.  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 

M/L/A Liquid Concentrates with LP Handwand (1)	Residential Turf,
Ornamental Bulbs and Orchids	0.0065 lb ai/gal water	5 gal/day	30
0.000975	0.000016	180,000

	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

M/L/A DF with Low Pressure Handwand (liquid concentrate PHED data as
surrogate) (3)

 	Residential Turf, Ornamental Bulbs and Orchids	0.0065 lb ai/gal water
5 gal/day	30	0.000975	0.000016	180,000

	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

M/L/A Liquid Concentrates with a Hose-end Sprayer (4)

 	Residential Turf	7 lb ai/A	0.5 acres/day	17	0.06	0.00099	3,000

	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

M/L/A Liquids with a Watering Can (PHED residential hose-end data as
surrogate) (8)

 	Ornamental Palms	0.013 lb ai/gal water	5 gal/day	1.6	0.001	1.7E-6
1,700,000

	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 based on Exposure SAC SOP #12, 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 inhalation unit exposure (μg/lb
ai) x conversion factor from μg 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 ( 3 mg/kg/day) / inhalation dose
(mg/kg/day)

Table 5.8.  ADBAC Short-term Dermal Risks to Residential Handlers 

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 = 10)e

M/L/A Liquid Concentrates with LP  Handwand (1)	Residential Turf,
Ornamental Bulbs and Orchids	0.0065 lb ai/gal water	5 gal/day	102	4.0	82

	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	120

M/L/A DF with LP Handwand (liquid concentrate PHED data as surrogate)
(3)

 	Residential Turf, Ornamental Bulbs and Orchids	0.0065 lb ai/gal water
5 gal/day	102	4.0	82

	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	120

M/L/A Liquid Concentrates with a Hose-end Sprayer (4)

 	Residential Turf	0.0063 lb ai/gal water	100 gal/day	27.5	21	16

	Ornamental Herbaceous Plants, Ornamental Shrubs, Ornamental Trees,
Seedlings (planted in garden) 	0.0043 lb ai/gal water	100 gal/day	27.5
14	23

M/L/A Liquids with a Watering Can (PHED residential hose-end data as
surrogate) (8)

 	Ornamental Palms	0.013 lb ai/gal water	5 gal/day	27.5	0.7	460

	Seedlings, Seeds, Cuttins (preplant or at plant) 	0.0043 lb ai/gal
water	5 gal/day	27.5	0.1	2,300

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	120

a	Application rates are the maximum application rates determined from
EPA registered labels for ADBAC

b	Amount handled per day values are based on Exposure SAC SOP #12 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 μg
(1000) / surface area of adult hands  (820 cm2 ) from Exposure Factors
Handbook.

f	Dermal MOE = Estimated Residue transferred to Skin of Hands
(μg/cm2/day)/ Dermal Endpoint (333 μg/cm2/day)

Inhalation exposures are thought to be negligible in outdoor
postapplication scenarios, since ADBAC has low vapor pressure and the
dilution factor for the outdoor environment is considered infinite.   

Table 5.9 represents the post-application dermal MOE values calculated
for adults after home greenhouse, garden, or turf applications of ADBAC
for short-term exposure duration. The calculated dermal MOEs were above
the target MOE of 10 on the day of application for any of the three
scenarios with the different application rates. An MOE of less than 10
represents a risk of concern to the Agency.

Table 5.9.  ADBAC:  Adult Residential Short-Term Dermal Risks for Post
Application Exposure 

Exposure Scenario	Route of Exposure	Formulation	Application Ratea

(lb ai/acre)	Residue on Skinb	MOEc 

at Day 0

Exposure To Treated Ornamental Plants 	Dermal	Spray	0.43	0.96	350

Exposure to Treated Turf 

	7	3.9	85



	0.9	0.5	660

a	Maximum application rate on label (lb ai/A).

 = application rate in μg/cm2 (lb ai/gal * conversion factors (lb to
μg and A to cm2) * fraction of DFR or TTR available on day 0 * percent
of DFR or transferrable to skin (100%).

c	Short-term Dermal MOE = dermal endpoint (333 ug/cm2)/ residue
concentration on skin

	Table 5.10 summarizes the post application risks to toddlers following
application of ADBAC to home lawns.  Short-term MOEs were above the
target 100 for object-to-mouth activities and incidental soil ingestion
as well as for hand-to-mouth activity at the lower application rate, 0.9
lb ai/A.  However, the MOE for hand to mouth activity at the higher
application rate, 0.7 lb ai/A, was below the target MOE at 96.  A MOE of
less than 100 represents a risk of concern to the Agency.

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	Oral	Spray	7	96

Object to Mouth Activity on Turf



380

Incidental Soil Ingestion



29,000

Hand to Mouth Activity on Turf	Oral	Spray	0.9	740

Object to Mouth Activity on Turf



3,000

Incidental Soil Ingestion



220,000

a	Maximum application rate on label (lb ai/A).

b	Residue concentration available to be transferred on day 0 =
application rate in μg/cm2 (lb ai/gal * conversion factors (lb to μg
and A to cm2) * fraction of DFR or TTR available on day 0 * percent of
DFR or transferrable to skin (100%).

c	Short-term Dermal MOE = dermal endpoint (333 ug/cm2)/ residue
concentration on skin

	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 5.11 represents a summary of the combined risk from
incidental oral ingestion by toddlers following applications to home
lawns.  The MOE for the lower application rate (0.9 lb ai/A) was not of
concern; however, the MOE for the maximum label application rate (7 lb
ai/A), is 76.  A MOE of less than 100 represents a risk of concern to
the Agency.

Table 5.11.  ADBAC:  Combined Incidental Oral Risk Estimates - Toddlers

Postapplication Exposure Scenario	Margins of Exposure (MOEs)

(UF=100)

	Short-Term Oral

(Non-Dietary)	Short-Term Oral: Combined

(Non-Dietary)

Turf  application at 7 lb ai/acre

	Hand to Mouth	96	76

	Object to Mouth	380



Incidental Soil Ingestion	29,000

	Turf  application at 0.9 lb ai/acre

	Hand to Mouth	740	590

	Object to Mouth	3,000



Incidental Soil 

Ingestion	220,000

	

6.0	AGGREGATE RISK ASSESSMENT AND RISK CHARACTERIZATION tc \l1 "5.0
RESIDENTIAL AGGREGATE RISK ASSESSMENTS AND RISK CHARACTERIZATION 

	In order for a pesticide registration to continue, it must be shown
that the use does not result in “unreasonable adverse effects on the
environment”. Section 2 (bb) of FIFRA defines this term to include
“a human dietary risk from residues that result from a use of a
pesticide in or on any food inconsistent with standard under section
408...” of FFDCA.  Consequently, even though no pesticide tolerances
have been established for ADBAC, the standards of FQPA must still be
met, including “that there is reasonable certainty that no harm will
result from aggregate exposure to pesticide chemical residue, including
all anticipated dietary exposures and other exposures for which there
are reliable information.”   Aggregate exposure is the total exposure
to a single chemical (or its residues) that may occur from dietary
(i.e., food and drinking water), residential, and other non-occupational
sources, and from all known or plausible exposure routes (oral, dermal,
and inhalation).  Aggregate risk assessment were conducted for
short-term (1-30 days), intermediate-term (1-6 months) and chronic
(several months to lifetime) exposures.  An acute endpoint was not
identified for ADBAC, and therefore, an acute aggregate dietary
assessment was not necessary.

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

	6.1	Acute and Chronic Aggregate Risks  tc "6.1	Acute and Chronic
Aggregate Risks " \l 2 

	An acute toxicological endpoint was not identified for ADBAC. 
Therefore, an acute aggregate risk assessment was not conducted.  The
chronic aggregate risk assessment includes dietary and drinking water
exposures.  Chronic dietary risk estimates from direct and indirect food
uses are presented in Section 5.2.  Drinking water exposure estimates
are presented in Section 5.3.  Table 6-1 presents a summary of these
exposures, including the aggregate indirect and direct dietary exposure
(i.e., all direct and indirect food contact exposures) as well as a
total dietary aggregate exposure estimate (i.e., drinking water plus
direct/indirect dietary exposures).  Based on the results of the chronic
aggregate assessment, the % cPAD for adults and children are 3.5% and
10.3%, respectively.  Therefore, the chronic dietary risks are not of
concern (i.e., less then 100 % of cPAD).

Table 6-1.  ADBAC Chronic Aggregate Exposures and Risks (cPAD)

Exposure Routes	Chronic Dietary Exposures (mg/kg/day)

	Indirect Dietary  Exposuresa	Direct Food Contact Dietary Exposuresa
Drinking Water Exposures 	Aggregate Dietary Exposuresb	% cPAD

(MOE)

Adults

Oral Ingestion	0.0042	0.0024	0.009	0.0066	3.5%

(2,800)

Children

Oral Ingestion	0.017	0.0061	0.022	0.023	10.3

(980)

a Dietary (indirect + direct food contact) exposures are presented in
Tables 5.1 and 5.2.

b Aggregate Dietary Exposures = indirect dietary + direct food contact +
drinking water exposures.

c %cPAD (percent chronic population adjusted dose) = (aggregate
exposures / cPAD) x 100.  Where cPAD = NOAEL 44 mg/kg/day / 100x
uncertainty factor = 0.44 mg/kg/day.  MOE = NOAEL of 44 mg/kg/day /
aggregate dietary exposures mg/kg/day.

 	6.2	Short- and Intermediate-Term Aggregate Exposures and Risks  tc
"6.2	Short- and Intermediate-Term Aggregate Exposures and Risks " \l 2 

	Short- and intermediate-term aggregate exposures and risks were
assessed for adults and children that could be exposed to ADBAC residues
from the use of products in non-occupational environments.  The short-
and intermediate-term aggregate risks account for pesticide exposures
from the diet, drinking water, and residential uses.  The following list
summarizes all of the potential sources of ADBAC exposures for adults
and children.

Adult ADBAC exposure sources:

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

applying products containing ADBAC to lawns/ornamentals;

applying ADBAC as an air deodorizer using an aerosol spray;

applying ADBAC to carpets using a low pressure sprayer;

applying ADBAC to swimming pools via open pouring;

applying ADBAC to RV holding tanks via open pouring;

contacting pressure treated wood;

wearing treated clothing;

use of ADBAC in humidifiers; and

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

	

Child ADBAC exposure sources:

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

breathing air treated with an air deodorizer or humidifier;

swimming in treated pools;

contacting pressure treated wood;

wearing treated clothing/diapers;

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

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

Table 6-2. Exposure Scenarios Included in the Aggregate Assessments

	Short-term (ST) Aggregate	Intermediate-Term (IT) Aggregate

Adults	chronic dietary (direct and indirect)

handling cleaning products (wipe + trigger pump spray) 

wearing treated clothing

humidifier	

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

Dermal:  ST endpoint only.

Inhalation:  All durations same endpoint.

Children	chronic dietary – (direct and indirect)

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

wearing treated clothing

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

Dermal:  ST endpoint only.

Inhalation:  All durations same endpoint.



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

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

	Since the ADBAC toxicity endpoints for the oral, dermal, and inhalation
routes of exposure are based on different toxic effects, these three
routes of exposure are not aggregated together.  Instead, the aggregate
assessment is based solely on the co-occurrence of the same route of
exposures.  Aggregate risks were calculated using the total MOE approach
outlined in OPP guidance for aggregate risk assessment (August 1, 1999,
Updated “Interim Guidance for Incorporating Drinking Water Exposure
into Aggregate Risk Assessments”).  Table 6-3 presents a summary of
the short- and intermediate-term aggregate risks (i.e., MOEs).  The
short- and intermediate-term aggregate is identical because the
endpoints for incidental oral as well as inhalation are identical for
the short- and intermediate-term durations.  Only a short-term dermal
duration was assessed. The aggregate risks are not of concern for adults
for any of the three routes of exposure.  The aggregate MOE is 2,800 for
oral, 42 for dermal, and 630 for inhalation, which is greater than the
target of 100 for oral and inhalation, and a target MOE of 10 for
dermal.  For children, the aggregate risk estimate for each of the
routes of exposure are also above the target MOE of 100 for oral and
inhalation, and a target MOE of 10 for dermal (MOE=220 for the oral
route, 180 for the dermal route, and no co-occurrence for the inhalation
route); thus are not of concern.  It is important to note, however, that
some of the individual risks for scenarios not included in the aggregate
are of concern by themselves (e.g., the humidifier use).   

Table 6-3.  Short- and Intermediate-term Aggregate Risk (MOE) Assessment

Exposure Routes	Chronic Dietary 

MOE	Cleaning Product MOEs

(Adult Applicators & Children Playing)	Humidifier

MOE	Wearing Treated Clothing

MOE	Route-Specific

Aggregate

MOE

Adults

Oral Ingestion	2,800	NA	NA	NA	2,800

Dermal 

	NA	210 (mop)

	76 (wipe)

	790 (spray)

	NA	210	42

Inhalation	NA	3,000

(mop)	820 (wipe)	23,000 (spray)	Not included, risk of concern	NA	630

Children

Oral Ingestion	980	330 (hand-to-mouth carpets)	NA	1,900	220

Dermal

(ST only)	NA	1,200 (playing on carpets)	NA	210

(100% residue transfer)	180

Inhalation	NA	NA	Not included, risk of concern	NA	No co-occurrence

Aggregate MOE = 1/((1/MOEsame route) + (1/MOE same route) + etc)

7.0		CUMULATIVE EXPOSURE AND RISK tc "6.0	CUMULATIVE EXPOSURE AND RISK" 

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

		Unlike other pesticides for which EPA has followed a cumulative risk
approach based on a common mechanism of toxicity, EPA has not made a
common mechanism of toxicity finding as to ADBAC and any other
substances and ADBAC does not appear to produce a toxic metabolite
produced by other substances.  For the purposes of this tolerance
action, therefore, EPA has not assumed that ADBACs has a common
mechanism of toxicity with other substances.  For information regarding
EPA’s efforts to determine which chemicals have a common mechanism of
toxicity and to evaluate the cumulative effects of such chemicals, see
the policy statements released by EPA’s Office of Pesticide Programs
concerning common mechanism determinations and procedures for cumulating
effects from substances found to have a common mechanism on EPA’s
website at   HYPERLINK "http://www.epa.gov/pesticides/cumulative/" 
http://www.epa.gov/pesticides/cumulative/ .

8.0	OCCUPATIONAL EXPOSURE ASSESSMENT tc \l1 "6.0	OCCUPATIONAL EXPOSURE
AND RISK 

	Potential occupational handler exposure can occur in various use sites,
which include: agricultural premises, industrial processes and water
systems, food handling premises, commercial/institutional/industrial
premises, medical premises, swimming pools, and aquatic areas.  In
addition to the “antimicrobial” exposures scenarios, ADBAC is used
to treat ornamental plants in nurseries and greenhouses, commercial turf
and golf courses which are assessed as “agricultural” exposure
scenarios.  Also, occupational exposure can occur during the
preservation of wood. For the preservation of wood, the procedure for
treatment can occur in different ways, such that multiple worker
functions were analyzed. Due to the complexity of the wood preservative
analysis, the results for handler and post-application exposures are
presented separately in Section 7.3.

8.1 	Occupational Handler Exposures

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

	

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

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

 Risk Characterization for Antimicroibal Uses

	The resulting inhalation exposures and MOEs for the representative
occupational handler scenarios are presented in Table 8.1. The
calculated MOEs were above the target MOE of 100 for all scenarios,
except those listed below. 

Agricultural fogging (mixing and loading): ST/IT Inhalation MOE = 26

Medical premises, mopping: ST/IT Inhalation MOE = 95

Pulp and paper, liquid pump: ST/IT Inhalation MOE = 33

Once-through cooling water, metering pump: Using the average flow rate
for high flow streams (153 MGD) the ST Inhalation MOE = 50 for initial
applications and the IT MOE = 95 for maintenance applications; however,
using the average flow rate for low flow streams (5.9 MGD) the ST
Inhalation MOE = 1,300 for initial applications and the IT MOE = 2,500
for maintenance applications.

Small process water systems, liquid pour: ST/IT Inhalation MOE = 6.

Table 8.1 Short- , Intermediate- and Long-Term Inhalation Risks
Associated with Occupational Handlers



Exposure Scenario	

Method of Application	

Inhalation Unit Exposure

(mg/lb a.i.) 	Application Rate	Quantity Handled/ Treated per day	

Inhalation  Daily Dose (mg/kg/day)a	

Inhalation 

MOEb, c 

(Target MOE = 100)



Agricultural Premises and Equipment (Use Site Category I)

Application to hard surfaces, equipment, and vehicles 	Mop	2.38	0.012 lb
ai/gal	2 gallons	0.00091	3,300

	High pressure/high volume spray	0.12	0.017 lb ai/gal	40 gallons	0.0014
2,200

	Low pressure hand wand	0.681	0.017 lb ai/gal	10 gallons	0.002	1,500

	Trigger pump sprayer	1.3	0.017 lb ai/gal	0.26 gallons	0.000098	31,000

	Wipe	67.3	0.017 lb ai/gal	0.26 gallons	0.0051	590

Fogging (mix/load only)	Liquid pour	1.89	2.46E-05 lb/ft3	150,000 ft3
0.12	26



  SEQ CHAPTER \h \r 1 Food Handling/Storage Establishments Premises And
Equipment	 (Use Site Category II)

Application to indoor hard surfaces (including dishes, utensils,
equipment)	Low pressure hand wand	0.681	0.0176 lb ai/gal	2 gallons
0.0004	7,500

	Mop	2.38	0.0176 lb ai/gal	2 gallons	0.0014	2,100

	Wipe	67.3	0.0176 lb ai/gal	0.26 gallons	0.0051	580

	Trigger pump sprayer	1.3	0.025 lb ai/gal	0.26 gallons	0.00014	21,000

	Immersion, Flooding, Circulation	1.89	0.00325 lb ai/gal	2 gallons
0.0002	15,000



  SEQ CHAPTER \h \r 1 Commercial, Institutional and Industrial Premises
and Equipment (Use Site Category III )

Application to indoor hard surfaces	Low pressure hand wand	0.681	0.0283
lb ai/gal	2 gallons	0.00064	4,700

	Mop	2.38	0.0283 lb ai/gal	2 gallons	0.0022	1,300

	Wipe	67.3	0.0283 lb ai/gal	0.26 gallons	0.0083	360

	Trigger pump sprayer	1.3	0.0283 lb ai/gal	0.26 gallons	0.00016	19,000

	Immersion	1.89	0.025 lb ai/gal	2 gallons	0.0016	1,900

Air deodorization	Aerosol spray	1.3	0.20% a.i. by weight	3.0 lbs	0.00013
23,000

Application to carpets	Liquid pour	0.00346	0.141 lb ai/gal	32 gallons
0.00026	12,000



Medical Premises and Equipment (Use Site Category V)

Application to hard surfaces	Mop	2.38	0.0176 lb ai/gal	45 gallons	0.031
95

Application to dental instruments	Immersion

(Liquid pour)	1.89	0.0209 lb ai/gal	2 gallons	0.0013	2,300

Industrial Processes and Water Systems (Use Site Category VIII)

Pulp and Paper	Metering pump	0.000265	41.7 lb ai/ton paper	500 tons
0.092	33

Papermaking Chemicals	Metering pump	0.000265	0.0019 lb ai/gal additive
1,000 gallons	8.5E-6	350,000

Once-through Cooling Water System - Power plant	Metering pump 	0.000265
Initial Dose (ST): 8.86E-5 lb ai/gal water	5,900,000 gallons	0.0023
ST=1300



	Maintenance Dose (IT): 4.69E-5 lb ai/gal	5,900,000 gallons	0.0012
IT=2,500



	Initial Dose (ST): 8.86E-5 lb ai/gal water	153,000,000 gallons	0.06	ST
=50



	Maintenance Dose (IT): 4.69E-5 lb ai/gal	153,000,000 gallons	0.032
IT=95

Small process water systems: Recirculating cooling tower/evaporative
condenser/pasteurizers	Liquid pour	0.45	6.67 lb ai/gal product	10
gallons	0.5	6

	Metering pump	 0.00432	Initial Dose (ST): 3.34E-4 lb ai/gal water
20,000 gallons	0.00048	ST=6,200



	Maintenance Dose (IT): 1.25E-4 lb ai/gal water	20,000 gallons	0.00018
IT=17,000

Oil field operations - drilling mud and packing fluids	Liquid pour
0.00346	1.00 lb ai/gal product	5.6 gallons	ST = 0.00032	ST = 9,300





2.8 gallons	IT = 0.00016	IT = 19,000

Metal/wood cooling tower surface spray	High Pressure Sprayer	0.12
0.00084 lb ai/gal water	100 gallons	0.00017	18,000





1,000 gallons	0.0017	1,800



Swimming Pools (Use Site Category X)

Application to swimming pools	Liquid pour	0.00346	Winterizing Dose (ST):

0.000052 lb ai/gal	200,000 gallons	0.0006	ST =5,000



	Maintenance Dose (IT/LT):

0.0000098 lb ai/gal	200,000 gallons	0.00011	IT/LT =27,000

	ST = short-term,  IT = intermediate-term, LT = long-term, N/A= No data
available

a	Daily dose (mg/kg/day) = [unit exposure (mg/lb a.i.) x absorption
factor (1.0 for inhalation) x application rate x quantity treated / Body
weight (60 kg for inhalation).

	b	MOE = NOAEL  (mg/kg/day) / Absorbed Daily Dose [Where NOAEL = 3
mg/kg/day for all inhalation exposure durations].  Target MOE = 100.

	c	The MOEs refer to short-term and intermediate-term duration unless
indicated otherwise.

	Risk Characterization for Agricultural Uses

In all occupational handler scenarios, the inhalation MOEs are above the
level of concern of 100 at baseline PPE (i.e., no respirator). 

TABLE 8.2.  ADBAC:  Occupational Handler Inhalation Risks

Exposure Scenario	Crop or Target	Application Rate a	Area Treated Daily b
Inhalation MOEsc





Baseline 

Mixer/Loader

Mixing/Loading (M/L) Liquids for Groundboom Applications (1a)

	Carnations (drench)	256 lb ai/acre	1 acres	590

	Ornamental Herbaceous Plants (drench)	72 lb ai/acre	1 acres	2100

	Sodfarm Turf	0.9 lb ai/acre	1 acres	170,000

	Seedlings (planted in field)	0.43 lb ai/acre	1 acres	350,000

	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

	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

	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

ML Liquid to Support LCO Handgun Applications (mixing/loading supports
20 LCOs) (1b)

 	Residential & Commercial Turf 	7 lb ai/acre	1 acres	21,000

	Residential & Commercial Turf 	0.9 lb ai/acre	1 acres	170,000

M/L Liquids for Airblast  (1c)	Ornamental Trees 	0.65 lb ai/acre	2 acres
120,000

M/L Liquid  via Dip or Soak  (1d)

 	Ornamental Herbaceous Plants, 	0.0065 lb ai/gal	100 gallons	230,000

	Seedlings, Seeds, Cuttings (preplant or at plant) 	0.0043 lb ai/gal	100
gallons	350,000

M/L DF for Groundboom   (2a)

	Carnations (drench)	256 lb ai/acre	1 acres	910

	Ornamental Herbaceous Plants (drench)	72 lb ai/acre	1 acres	3,200

	Sodfarm Turf	0.9 lb ai/acre	1 acres	260,000

	Seedlings (planted in field)	0.43 lb ai/acre	1 acres	540,000

M/L DF for Airblast  (2b)	Ornamental Trees 	0.65 lb ai/acre	1 acres
360,000

M/L DF to Support LCO Handgun Applications (mixing/loading supports 20
LCOs)  (2c)

 	Residential & Commercial Turf 	7 lb ai/acre	1 acres	33,000

	Residential & Commercial Turf 	0.9 lb ai/acre	1 acres	260,000

M/L DF via Dip or Soak  (2d)

 	Ornamental Herbaceous Plants, 	0.0065 lb ai/gal	100 gallons	360,000

	Seedlings, Seeds, Cuttings (preplant or at plant) 	0.0043 lb ai/gal	100
gallons	540,000

Applicator

Applying Sprays via Groundboom Equipment  (3)

 	Carnations (drench)	256 lb ai/acre	1 acres	950

	Ornamental Herbaceous Plants (drench)	72 lb ai/acre	1 acres	3,400

	Sodfarm Turf	0.9 lb ai/acre	1 acres	270,000

	Seedlings (planted in field)	0.43 lb ai/acre	1 acres	570,000

	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

	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

	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

Applying Sprays via Airblast Equipment  (4)	Ornamental Trees 	0.65 lb
ai/acre	1 acres	62,000

Applying Sprays via Handgun (5)	Residential and Commercial Turf	7 lb
ai/acre	0.05 acres	370,000



0.9 lb ai/acre	0.05 acres	2,900,000

Mixer/Loader/Applicator

Mixing/Loading/Applying Liquid Concentrates with a Handgun Sprayer (LCO
ORETF data) (10)

	Carnations (drench)	256 lb ai/acre	0.05 acres	2,000

	Ornamental Herbaceous Plants (drench)	72 lb ai/acre	0.05 acres	6,900

	Ornamental Trees and Ornamental Herbaceous Plants	0.65 lb ai/acre	0.05
acres	770,000

	Ornamental Shrubs, Seedlings (planted in field)	0.43 lb ai/acre	0.05
acres	1,200,000

Mixing/Loading/Applying Liquid Concentrates with a Handgun Sprayer (LCO
ORETF data) (7)

	Carnations (drench)	0.0235 lb ai/gallon	0.04 acres	71,000,000

	Ornamental Trees and Ornamental Herbaceous Plants	0.0065 lb ai/gallon
0.04 acres	260,000,000

	Ornamental Shrubs, Seedlings (planted in field)	0.0043 lb ai/acre	0.04
acres	390,000,000

Mixing/Loading/Applying Water Soluble Bags with Handgun Sprayer (LCO
ORETF data) (10)	Carnations (drench)	256 lb ai/acre	0.05 acres	2,000

	Ornamental Herbaceous Plants (drench)	72 lb ai/acre	0.05 acres	6,900

	Ornamental Trees and Ornamental Herbaceous Plants	0.65 lb ai/acre	0.05
acres	770,000

	Ornamental Shrubs, Seedlings (planted in field)	0.43 lb ai/acre	0.05
acres	1,200,000

Mixing/Loading/Applying Dry Flowables Concentrates with a Handgun
Sprayer (LCO ORETF data) (11)

  	Carnations (drench)	256 lb ai/acre	0.05 acres	640

	Ornamental Herbaceous Plants (drench)	72 lb ai/acre	0.05 acres	2,300

	Ornamental Trees and Ornamental Herbaceous Plants	0.65 lb ai/acre	0.05
acres	250,000

	Ornamental Shrubs, Seedlings (planted in field)	0.43 lb ai/acre	0.05
acres	380,000

Mixing/Loading/Applying Liquid Concentrates with a High Pressure
Handwand (PHED) (12)

 	Ornamental Herbaceous Plants and Ornamental Trees	0.0065 lb ai/gallon
1,000 gallons	230

	Ornamental Shrubs	0.0043 lb ai/gallon	1,000 gallons	350

Applying  Ready to Use Formulations via Trigger-Pump Sprayer (ORETF)
(13)	Ornamental Shrubs, Seedlings, Seeds, Cuttins (preplant or at plant)
0.0043 lb ai/gallon	1 gallons	2,200,000

Mixing/Loading/Applying Liquids with a Watering Can (using ORETF
residential hose-end data) (14)

	Ornamental Palms	0.013 lb ai/gallon	5 gallons	160,000

	Seedlings, Seeds, Cuttins (preplant or at plant)	0.0043 lb ai/gallon	5
gallons	490,000

	Mosquito Control in Decorative Ponds, Sewage Treatment Systems,
Swimming Pools, and Standing Water	0.0017 lb ai/gallon of water to be
treated	20,000 gallons to be treated	310

	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

	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 Standard Values for Daily Acres Treated
in Agriculture, industry sources, and HED estimates.

line inhalation unit exposure (μg/lb ai) x conversion factor from μg
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)

	8.2  	Occupational Post-application Exposures

Antimicrobial Uses

	Except for the post-application scenarios assessed for fogging and wood
preservatives in occupational post-application dermal and inhalation
exposures are assumed to be negligible.   

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

	The product, EPA Reg # 10324-118 (21.7% ai) with a maximum application
rate of 0.011 lb ai/gal, was assessed for fogging use in a food
processing plant. The label states to fog one quart of the diluted
product per 1,000 cubic feet. All labels which can be used for fogging
in food processing areas indicate that all personnel must vacate the
room during fogging and for a minimum of 2 hours after fogging.
Therefore, exposure was calculated for a person entering the food
processing plant 2 hours after all the applied fogger has been deployed.

	The product, EPA Reg # 10324-118 (21.7% ai) with a maximum application
rate of 0.27 lb ai/gal, was assessed for fogging use in hatcheries and
incubators. After fogging, the label states that the building should be
well ventilated, but does not indicate that personnel should vacate the
room.  The only label with agricultural fogging uses which indicates
that personnel should vacate the room after fogging is EPA Reg#
10324-111 (maximum application rate of 0.192 lb ai/gal).  This label
states to “well” ventilate the room after fogging and not to enter
until 2 hours after fogging.  Therefore, exposure was calculated for a
person entering the building immediately after all the applied fogger
has been deployed and 2 hours after all the applied fogger has been
deployed.

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

	--ten air exchanges, or

--2 hours of mechanical ventilation (i.e., fans), or

--4 hours of passive ventilation (i.e., windows, vents), or

--11 hours of no ventilation followed by 1 hour of mechanical
ventilation, or

--11 hours of no ventilation followed by 2 hours of passive ventilation,
or 

	--24 hours of no ventilation

Agricultural Uses

	The occupational postapplication MOEs for the turf and ornamental crop
uses of ADBAC indicate that dermal risks are not of concern (>100) when
applied as a spray. Inhalation exposures are thought to be negligible in
outdoor postapplication scenarios, since ADBAC has low vapor pressure
and the dilution factor for the outdoor environment is considered
infinite.

8.3 	Wood Preservation

	ADBAC is used in products that are intended to preserve wood through
both non-pressure treatment methods and pressure treatment methods.  It
is also intended for use on existing homes (wood shingles or shake roofs
and siding) by spray or brush.  Section 8.3.1 presents the exposure
analysis for the handler and post-application scenarios for non-pressure
treatment scenarios and Section 8.3.2 presents the exposure analysis for
the handler and post-application scenarios for pressure treatment
scenarios.  Dermal irritation exposures from post-application activities
in the wood preservation treatment facility will be mitigated using
default personal protective equipment requirements based on the toxicity
of the end-use product.  Therefore, only inhalation exposures and risks
are presented.

	8.3.1 	Non-Pressure Treatment Scenarios (Handler and Post-application)

		8.3.1.1		Scenarios Assessed by Worker Function 

	The proprietary study, “Measurement and Assessment of Dermal and
Inhalation Exposures to Didecyl Dimethyl Ammonium Chloride (DDAC) Used
in the Protection of Cut Lumber (Phase III)” (Bestari et al., 1999,
MRID 455243-04) identified various worker functions/positions for
individuals that handle DDAC-containing wood preservatives for
non-pressure treatment application methods and for individuals that
could then come into contact with the preserved wood. The worker
functions/positions identified in the DDAC study are presented below. 
It was assumed that similar tasks are performed when handling ADBAC
products and ADBAC treated-wood, therefore, these same functions were
assessed for ADBAC.

Handler:

Blender/spray operators are workers that add the wood preservative into
a blender/sprayer system for composite wood via closed-liquid pumping.

Diptank Operators can be in reference to wood being lowered into the
treating solution through an automated process (i.e., elevator diptank,
forklift diptank).  This scenario can also occur in a smaller scale
treatment facility in which the worker can manually dip the wood into
the treatment solution.

Chemical operators for a spray box system consist of chemical operators,
chemical assistants, chemical supervisors, and chemical captains.  These
individuals maintain a chemical supply balance along with flushing and
cleaning spray nozzles. 

Post-application: 

Graders, positioned right after the spray box, grade dry lumber by hand
(i.e. detect faults).  In the DDAC study, graders graded wet lumber;
therefore, the exposures to graders using ADBAC are worst-case
scenarios.    

Millwrights repair all conveyer chains and general up-keep of the mill. 


Clean-up crews perform general cleaning duties at the mill.

Trim saw operators operate the hula trim saw and consist of operators
and strappers. In the DDAC study, hula trim saw operators handled dry
lumber. 

Construction workers install treated plywood, oriented strand board,
medium density fiberboard, and others.  

	As very little chemical specific data were available regarding typical
exposures to ADBAC as a wood preservative, surrogate data were used to
estimate exposure risks. The blender/spray operator position was
assessed using CMA unit exposure data and the remaining handler and
post-application positions were assessed using data from the DDAC study
(Bestari et al., 1999). This study is proprietary; therefore, data
compensation needs to be addressed for use of these data in this
exposure assessment.  

Blender/Spray Operators

	The inhalation exposures and risks to the composite wood blender/spray
operators are reported in Table 8.6.  The inhalation MOE is below the
target MOE of 100 for short-, intermediate-, and long-term inhalation
exposures (MOE = 84).  

Table 8.6.  Short-, Intermediate-, and Long-Term Inhalation Exposures
and MOEs for Blender/Spray Operator

Exposure Scenario

	Inhalation Unit Exposurea

(mg/lb ai)	Application Rate

(% ai in solution/

day)	Wood Slurry Treatedb

(lb/day)	Daily Dosec (mg/kg/day)	ST/IT/LT 

MOEd 

(Target MOE = 100)

Occupational Handler



Blender/spray operator	0.000403	3	178,000	0.036	84

ST =	Short-term duration; IT =	Intermediate-term duration; and LT =
long-term.

Inhalation unit exposure: Baseline.	

b.	Wood slurry treated = (8 batches/day x 7,000 gallons/batch x 0.003785
m3/gallon x 380 kg/m3 x 2.2 lb/kg)	

c.	Daily Dose = unit exposure (mg/lb ai) x App Rate (% ai/day) x
Quantity treated (lb/day) x absorption factor (100% for inhalation) / BW
(60 kg)

d.	MOE = NOAEL (mg/kg/day)/ Daily dose [Where ST/IT/LT NOAEL = 3
mg/kg/day for inhalation. Target MOE = 100.

Chemical Operators, Graders, Millwrights, Clean-up Crews, and Trim Saw
Operators

	The inhalation exposures (all durations) to chemical operators,
graders, millwrights, trim saw operators, and clean-up crews are
presented in Table 8.7.  The inhalation MOEs are above the target MOE of
100 for all worker functions. Any dermal irritation exposures from
post-application activities will be mitigated using default personal
protective equipment requirements based on the toxicity of the end-use
product.  

Table 8.7.  Short-, Intermediate, and Long-Term Inhalation Exposures and
MOEs for Wood Preservative Chemical Operators, Graders, Trim Saw
Operators, and Clean-Up Crews (Handler and Post-application Activities)

Exposure Scenarioa 

(number of volunteers)	Inhalation UEb 

(mg/day)	Conversion Ratioc	Daily Dosed

(mg/kg/day)	MOEe (Target MOE = 100)

Occupational Handlers



Chemical Operator (n=11)	0.0281	0.625	0.000292	10,000

Occupational Post-Application



Grader (n=13)	0.0295	0.625	0.000307	9,800



Trim Saw (n=2)	0.061	0.625	0.00063	4,800



Millwright (n=3)	0.057	0.625	0.00059	5,100



Clean-Up (n=6)	0.60	0.625	0.0063	480

ST = 	Short-term duration, IT = Intermediate-term duration, LT =
Long-term duration

a.	The exposure scenario represents a worker wearing short-sleeved
shirts, cotton work trousers, and cotton glove dosimeter gloves under
chemical resistant gloves. Volunteers were grouped according to tasks
they conducted at the mill.

b.	Inhalation unit exposures are from Bestari et. al. (1999).  Refer to
Table E-1 in Appendix E for the calculation of the dermal and inhalation
exposures. Inhalation exposure (mg/day) was calculated using the
following equation: Air concentration (μg/m3) x Inhalation rate (1.0
m3/hr) x Sample duration (8 hr/day) x Unit conversion (1 mg/1000 μg). 
The inhalation rate is from USEPA, 1997.

c.	Conversion Ratio = 50% ADBAC / 80% DDAC

d.	Daily dose (mg/kg/day) = exposure (mg/day) x conversion ratio (0.625)
x absorption factor (100% for inhalation)/body weight (60 kg). 

e.			MOE = NOAEL (mg/kg/day)/ Daily dose [Where inhalation NOAEL = 3
mg/kg/day]. Target MOE = 100.

Diptank Operators

	Exposures to diptank operators were also assessed using surrogate data
from the DDAC study (Bestari et al., 1999). The diptank scenario
assessment was conducted differently than for the other job functions
because the concentration of DDAC in the diptank solution was provided. 
The exposure data for diptank operators were converted into (unit
exposures( in terms of mg a.i. for each 1% of concentration of the
product.  Table 8.8 provides the short-, intermediate- and long-term
inhalation dose and MOEs for diptank operators. The inhalation MOE is
above the target MOE of 100 and, therefore, is not of concern.

Table 8.8.  Short-, Intermediate-, and Long-Term Inhalation Exposures
and MOEs for Diptank Operator (Handler Activity)

Exposure Scenarioa

(number of replicates)	Inhalation Unit Exposureb

(mg DDAC/1% solution)	App Rate

(% a.i. in solution/ day)	Daily Dosec

(mg/kg/day)	MOEd







Occupational Handler

Dipping, with gloves (n=7)	0.046	3	0.0023	1,300

a 	The exposure scenario represents a worker not wearing a respirator.

b	Inhalation unit exposures are from DDAC study (MRID 455243-04). Refer
to Table E-2 in Appendix E for the inhalation unit exposure
calculations. Inhalation exposure (mg) was calculated using the
following equation: Air concentration (mg/m3) x Inhalation rate (1.0
m3/hr) x Sample Duration (8 hr).  The inhalation rate is from USEPA,
1997.

c	Daily dose (mg/kg/day) = unit exposure (mg/1% ai solution) x percent
active ingredient in solution  (3% ai) x absorption factor (100% for
inhalation) / body weight (60 kg).

d			MOE = NOAEL (mg/kg/day) / Daily dose [Where inhalation NOAEL = 3
mg/kg/day. Target MOE = 100.

Construction workers

	Potential risks resulting from construction worker dermal contact with
ADBAC-treated wood are assessed in the same manner as potential risks
resulting from children’s dermal contact with ADBAC-treated play sets
and decks (Section 4.2.2.3). The risks were calculated using a range of
worker residue data for hands available in the DDAC study for contacting
dry lumber. Hand residue data from the end stacker, stickman, and
tallyman workers were used because of the possibility of the contact
with dry treated wood. The range of hand residue values from these data
(0.6 up to3 ug/cm2) was assumed to be the dermal skin irritation
exposure. The dermal MOEs for the range of hand residues are 110 to 560,
which are all above the target MOE of 10.  

8.3.1.2	Scenarios Assessed for Exposure from Applications to 	Existing
Homes (Handler)

	Applications to wood roofs, shingles, and siding of existing homes can
be made by brush and spray methods.  The airless spray method was
assessed because it represents high-end exposure.  The inhalation unit
exposure value was taken from PHED (0.83 mg/lb a.i.) and the amount of
treatment solution used was assumed to be 50 gallons (EPA/AD assumption
for painting).  The calculated inhalation MOE is shown in Table 8.9 for
all durations of exposure.  The MOE is below the target MOE of 100 (MOE
= 17).

Table 8.9. Short-, Intermediate, and Long-Term Inhalation Exposures and
MOEs for Spray and Brush Preservative Treatment to Exterior of Existing
Homes

Exposure Site	Application Equipment	App.  Rate 

(lb ai/dilute gallon)	Quantity Handled/ Treated per day (gallons)
Baseline Inhalation Unit Exposure 

(mg/lb ai)	Daily Dosesa

(mg/kg/day)	MOEb

(Target MOE =100)

















Exterior of Existing Homes	Airless Spray	0.25	50	0.83	10	17

a	Daily dose (mg/kg/day) = unit exposure (mg/lb ai) x quantity handled
(gallons) x absorption factor (100% for inhalation) / body weight (60
kg).

b			MOE = NOAEL (mg/kg/day) / Daily dose [Where inhalation NOAEL = 3
mg/kg/day for all durations]. Target MOE = 100.

8.3.2	Pressure Treatment Scenarios (Handler and Post-Application)

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

	The estimated inhalation exposures and risks for ADBAC are presented in
Table 8.10.  The calculated inhalation MOEs are above the target MOE of
100 for all scenarios. 

Table 8.10.  Short-, Intermediate-, and Long-Term Inhalation Exposures
and MOEs for Pressure Treatment Handler and Post-application Scenarios

Exposure Scenario	Inhalation Unit Exposurea

(μg As/ppm) 	Application Rate 

(% ai solution)	Daily Dosesb 

(mg/kg/day)	Inhalation MOEsc

(Target MOE = 100)

Occupational Handler

Treatment Operator (TO)	0.00257	3	0.0013	2,300

Treatment Assistant (TA)	0.000802	3	0.00040	7,500

Occupational Post-application

All (Tram setter, stacker operator, loader operator, supervisor, test
borer, and tallyman) 	0.00160	3	0.00080	3,800

a. 	Unit exposure values taken from CCA study and are shown in Table
6.11.

b. 	Daily Dose (mg/kg/day) = Unit Exposure (μg As/ppm) x [% ADBAC in
solution (3) x 10,000 (parts per million conversion)] x (0.001 mg/μg) x
absorption factor (100% for inhalation) / Body weight (60 kg).

c.			MOE = NOAEL (mg/kg/day) / Daily dose [Where inhalation NOAEL = 3
mg/kg/day for all durations. Target MOE = 100.

8.4	Data Limitations/Uncertainties tc \l2 "6.3	Data
Limitations/Uncertainties 

	There are several data limitations and uncertainties associated with
the occupational handler and post application exposure assessments. 
These include:

Surrogate dermal and inhalation unit exposure values were taken from the
proprietary Chemical Manufacturers Association (CMA) antimicrobial
exposure study (USEPA, 1999: DP Barcode D247642) or from the Pesticide
Handler Exposure Database (USEPA, 1998).  Since the CMA data are of poor
quality, the Agency requests that confirmatory data be submitted to
support the occupational scenarios assessed in this document.

  SEQ CHAPTER \h \r 1 Unit exposures are not available for some of the
specific scenarios that are prescribed for ADBAC.  These scenarios
include the following: open loading into oil-well/field environments and
metering into once-through cooling water systems at power plants. 

The CMA data used for oil-well uses are based on open pouring of a
material preservative.  Although these data are only represented by 2
replicates each, the exposure values are similar to open loading of
pesticides in PHED. Furthermore, there are no representative unit
exposure data for chemical metering into secondary recovery oil
operations.  Since the volume of water being treated in secondary
recovery operations is so large, the available CMA data can not be
reliably extrapolated because they are based on activities that handle
much lower volumes and possibly different techniques.  Therefore, it was
assumed that if the open pour handling activities for the other oil well
operations resulted in MOEs that are not of concern, then the MOEs for
the closed system chemical metering into secondary recovery operations
would also be not of concern.  The Agency requests that confirmatory
data be conducted to show that this is accurate.

The CMA data used for once-through cooling water systems at power plants
are based on closed metering for pulp and paper.  The pulp and paper
unit exposures were deemed more appropriate than the cooling water tower
data because of the large volume of water treated in once-through
cooling water systems at power plants.  However, the CMA data for pulp
and paper still does not reliably represent the large volume of water
treated in a once-through cooling water system and the possibly
different techniques used to treat the water.  

For the wood preservative pressure treatment scenarios, CCA exposure
data were used for lack of ADBAC-specific exposure data and for the wood
preservative non-pressure treatment scenarios, DDAC exposure data were
used for the lack of ADBAC-specific exposure data.  Limitations and
uncertainties associated with the use of these data include:

The assumption was made that exposure patterns for workers at treatment
facilities using CCA and DDAC would be similar to exposure patterns for
workers at treatment facilities using ADBAC, and therefore the exposures
could be used as surrogate data for workers that treat wood with ADBAC. 

For environmental modeling, it was assumed that the leaching process
from the ADBAC treated wood would be similar to that of CCA and DDAC. 
However, due to the lack of real data for ADBAC -treated wood, it is not
possible to verify this assumption. 

The quantities handled/treated were estimated based on information from
various sources, including HED’s Standard Operating Procedures (SOPs)
for Residential Exposure Assessments (USEPA, 2000 and 2001),  and
personal communication with experts.  In particular,   SEQ CHAPTER \h \r
1 the use information for the pulp and paper processing, oil-well uses,
and cooling water tower uses are based on personal communication with
biocide manufacturers for these types of uses.  The individuals
contacted have experience in these operations and their estimates are
believed to be the best available without undertaking a statistical
survey of the uses.  In certain cases, no standard values were available
for some scenarios.  Assumptions for these scenarios were based on AD
estimates and could be further refined from input from registrants.  For
example, the quantities handled/treated for the application of ADBAC to
the surface of metal/wood cooling towers could be refined.

The percent active ingredient in solution for the pressure treatment of
lumber needs to be refined by the Registrant.  The labels only provided
a retention rate.  For this assessment, the application rate on the
master label was used, which is the same as the application rate for
non-pressure treatment of lumber. 

The type of spray equipment to be used was not specifically mentioned on
the labels for some scenarios, such as for surface sprays to metal and
wood cooling water towers.  Therefore, these scenarios were assessed
using the PHED airless spray unit exposures, which represents high-end
exposure.  In these cases, the appropriate application equipment could
be further refined.

9.0	INCIDENT REPORTS

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

Group I.  	Alkyl or hydroxyalkyl (straight chain) substituted quats;

Group II	Non-halogenated benzyl substituted quats;

Group III. 	Di- and tri-chlorobenzyl substituted quats; and

Group IV.	Quats with unusual substituents 

However for the available incident information, it is difficult to
differentiate the specific members of the Quats involved in each
incident.  Therefore, all the Quats are discussed together.	

 tc "8.0	INCIDENTS"   SEQ CHAPTER \h \r 1 The Agency consulted the
following databases for poisoning incident data for ADBAC:

OPP Incident Data System (IDS) - The Incident Data System of The Office
of Pesticide Programs (OPP) of the Environmental Protection Agency (EPA)
contains reports of incidents from various sources, including
registrants, other federal and state health and environmental agencies
and individual consumers, submitted to OPP since 1992.  Reports
submitted to the Incident Data System represent anecdotal reports or
allegations only, unless otherwise stated.  Typically no conclusions can
be drawn implicating the pesticide as a cause of any of the reported
health effects.  Nevertheless, sometimes with enough cases and/or enough
documentation risk mitigation measures may be suggested. 

  SEQ CHAPTER \h \r 1 California Department of Pesticide Regulation
(1982-2004) - California has collected uniform data on suspected
pesticide poisonings since 1982.  Physicians are required, by statute,
to report to their local health officer all occurrences of illness
suspected of being related to exposure to pesticides.  The majority of
the incidents involve workers.  Information on exposure (worker
activity), type of illness (systemic, eye, skin, eye/skin and
respiratory), likelihood of a causal relationship, and number of days
off work and in the hospital are provided.

  SEQ CHAPTER \h \r 1 National Pesticide Telecommunications Network
(NPTN) - NPTN is a toll-free information service supported by OPP.  A
ranking of the top 200 active ingredients for which telephone calls were
received during calendar years 1984-1991, inclusive, has been prepared. 
The total number of calls was tabulated for the categories human
incidents, animal incidents, calls for information, and others 

 Published Incident Reports - Some incident reports associated with
Quats related human health hazard are published in the scientific
literature.

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

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

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

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

10.0	ENVIRONMENTAL RISK

	ADBAC is categorized as highly toxic to fish (LC50 = 280 μg ai/L) and
very highly toxic to aquatic invertebrates (LC50 = 5.9 μg ai/L) on an
acute exposure basis.  Chronic effects were seen in fish at a
concentration of 32.2 μg ai/L and a no observable adverse effect
concentration (NOAEC) of 4.15 μg ai/L was established for aquatic
invertebrates.  The results of the dietary avian studies categorized
ADBAC as moderately toxic to birds on an acute basis (LC50 = 136
mg/kg-bw, with no chronic data available.  ADBAC is categorized as
slightly toxic to mammals on an acute basis (LD50 = 430 mg/kg-bw) and a
chronic NOAEC of 44 mg/kg/day was established.  

Data Gaps:

The following data requirements were outstanding for the currently
registered used of ADBAC:

850.4225 - Seedling emergence using rice

850.4250- Vegetative vigor using rice

850.4400 - Lemna gibba

850.5400 - Algal toxicity, 4 species:  green alga Selenastrum
capricornutum or 	      Pseudokirshneriella subcapitata, blue-green
cyanobacteria  Anabeana flos-aquae,                         freshwater
diatom Navicula pelliculosa, marine diatom Skeletonema costatum).

850.1055 - Acute Eastern Oyster embryo larvae testing

850.1300- Chronic Daphnia magna testing

Monitoring and/or Tier II modeling of once-through cooling tower and 	  
                          antisapstain uses to establish EEC's for risk
assessment.  

ADBAC INDOOR USES

For certain use categories, the Agency assumes there will be minimal
environmental exposure, and only a minimal toxicity data set is required
(Overview of the Ecological Risk Assessment Process in the Office of
Pesticide Programs U.S. Environmental Protection Agency - Endangered and
Threatened Species Effects Determinations, 1/23/04, Appendix A, Section
IIB, pg.81).  The majority of ADBAC uses are spray applications to
indoor surfaces, truck interiors, kennels, institutional areas,
household areas, recirculating cooling towers, evaporative condensers,
pulp/paper mills, swimming pools and spas, and oil field mud treatments
that fall into this category for the following reasons:

The amount that will actually reach the environment is very small based
on usage data and use patterns (no homeowner/residential use for
bathrooms) and containment methods (retaining ponds, recirculation, low
residual upon release).  

Breakdown in the environment and via sewage treatment is rapid and well
documented in the literature (See Environmental Fate Chapter for more
detail).  The agency requires the following label statement:  "Do not
discharge effluent containing this product into lakes, streams, ponds,
estuaries, oceans, or other waters unless in accordance with the
requirements of a National Pollutant Discharge Elimination System
(NPDES) permit and the permitting authorities are notified in writing
prior to discharge.  Do not discharge effluent containing this product
to sewer systems without previously notifying the local sewage treatment
plant authority.  For guidance contact your State Water Board or
Regional Office of the EPA."

Chemicals in these categories, therefore, do not undergo a full
screening-level risk assessment and are considered to fall under a (no
effect( determination (NE) for endangered species.	

	For indoor uses identified above, the agency requires three acute
ecotoxicity tests for hazard labeling purposes.  These studies include:
one acute bird, one acute fish, and one acute invertebrate.  The
Bobwhite quail LD50 was >100 mg/Kg, therefore, no environmental hazard
statement for protection of birds or mammals is necessary for indoor use
labels.  ADBAC is "very highly toxic" to freshwater and estuarine/marine
aquatic invertebrates, oysters, and shrimp; and "highly toxic" to
freshwater and estuarine/marine fish.  Therefore, the following
environmental hazard statement is required on indoor use labels: "This
pesticide is toxic to fish, aquatic invertebrates, oysters, and shrimp."
 This statement is required as a precaution in the event that a spill
occurs.  

ADBAC USES HAVING POTENTIAL FOR ENVIRONMENTAL EXPOSURE

Ornamental Nursery Plants

 	Expected environmental concentrations (EECs) of ADBAC resulting from
runoff following application to ornamentals in nurseries were calculated
using available ecotoxicity data and the EPA aquatic exposure model
PRZM/EXAMS.  Risk quotients (RQs) for freshwater fish ranged from 1.99
to 5.26, exceeding the acute risk level of concern (LOC) of 0.5 by up to
ten-fold.  RQs for freshwater invertebrates ranged from 94.41 to 249.66,
exceeding the acute risk LOC by greater than 180-fold.  The chronic risk
LOC (1.0) is exceeded many-fold for freshwater fish (RQs 10-28) and for
freshwater invertebrates (RQs 87-222).  Using the EPA terrestrial animal
exposure model (TERX), acute avian RQs ranged from 19 to 2101, exceeding
the acute LOC up to 4000-fold.  Chronic avian RQs could not be
calculated due to the lack of toxicity data, but chronic risk is
presumed.  Mammalian acute RQs for the nursery use range from 1.2 to 182
and chronic RQs range from 11 to 1782.  

Turf and Golf Courses

	Expected EECs of ADBAC resulting from runoff following application to
turf and golf courses were calculated using available ecotoxicity data
and the EPA aquatic exposure model PRZM/EXAMS.  Risk quotients for
freshwater fish range from 0.06 to 0.91, exceeding the endangered
species and acute risk LOCs.  Acute risk RQs for freshwater
invertebrates range from 2.3 to 10.6, exceeding the acute risk LOC. 
Using the EPA terrestrial animal exposure model (TERX), acute avian RQs
range from 0.11 to 12.35, exceeding the endangered species LOC for all
size classes and forage items. Chronic RQs cannot be calculated, but
chronic risk to avian species is presumed.  Acute risk mammalian RQs
from the turf/golf course use ranged from 0.01 to 7.9, with exceedance
of the endangered species LOC for all mammal size classes foraging on
short grass, tall grass, broadleaf plants and small insects.  Chronic
RQs for mammals range from 0.07 to 77.2, and exceed the LOC for all
mammal size classes foraging on short grass, tall grass, broadleaf
plants and small insects. (  HYPERLINK
"http://www.epa.gov/oppefed1/models/terrestrial/index.htm" 
http://www.epa.gov/oppefed1/models/terrestrial/index.htm ).

Ornamental Ponds, Pools, and Puddles

	Other outdoor uses of ADBAC on ornamental ponds, pools and puddles are
not expected to result in appreciable exposure to aquatic ecosystems due
to their limited size and containment of ADBAC within the structure
through use of impermeable materials. (    HYPERLINK
"http://www.epa.gov/oppefed1/models/water/index.htm" 
http://www.epa.gov/oppefed1/models/water/index.htm ).

	

Algae Control and Mosquitocide

	Although the algae control and mosquitocide uses are intended for
waterbodies that are disconnected from the larger watershed to reduce
nontarget environmental exposure, these uses result in potential
exposure to amphibians in treated water for a portion of their lifecycle
and to birds and mammals utilizing treated waterbodies for drinking
water.  The mosquito control use having an initial concentration of 200
ppm ADBAC represents the greatest risk to terrestrial animals.  The
algal control initial target concentration is 5 ppm ADBAC.  At 200 ppm,
RQs for amphibians are 0.71 for acute risk and 6.2 for chronic risk,
both of which exceed the LOCs for acute high risk, endangered species,
and chronic risk.  RQs for birds drinking treated water range from 0.09
to 0.32.  Smaller birds face greater acute risk.  Chronic risk to birds
is presumed.  Neither acute nor chronic mammalian acute RQs exceed the
LOCs at the 200 ppm initial concentration.  

Once-through Cooling Tower Use

Tier I once-through cooling tower modeling indicates that ADBAC use will
result in acute and chronic risk to non-endangered and
endangered/threatened freshwater fish and acute risk to other aquatic
animals at all 3 dosages modeled: 2.0 ppm, 5.0 ppm, and 10.0ppm.  High
water flow, intermittent dosing at 10.0 ppm had less acute and chronic
impact on non-endangered freshwater fish than medium to low stream flow.
 However, LOC's for all aquatic animals were triggered at the 2.0 ppm
dosage using continuous dosing regardless of high, medium, or low stream
flow.  Green algae were not adversely affected except from use of
continuous dosing in combination with low stream flow conditions.  The
continuous dosing, low flow nontarget plant LOC is triggered at all 3
dosages modeled.  The aquatic plant risk assessment is incomplete due to
a number of outstanding studies.  The agency is not aware of any
endangered or threatened green algae.  Direct ADBAC exposure to
terrestrial animals is not expected to occur from the once-through
cooling tower use.

The high vs medium vs low water flow rate is based on size of the
facility.  Generally, higher flow (e.g., > 1000 MGD) facilities would
use more ADBAC than smaller facilities, however, the receiving water
(“reach”) data varies for each facility.  Other model uncertainties
include the use of 7Q10 rainfall conditions (the worst-case drought of a
10 year period), stream flow rate and ADBAC fate properties
(dissipation, degradation, and 1/2 life were not considered in this Tier
I model but should be considered in higher tier modeling).  Field
monitoring is suggested in the absence of a higher Tier model.  Further
assessment is required prior to making an agency endangered species
determination or proposing risk mitigation measures.

Antisapstain Wood Treatment Use

	The maximum amount of leachate from antisapstain treated wood per the
Krahn and Strub, 1990 model totaled 3.92 ppb.  The lowest predicted
amount of leachate was 1.02 ppb and the typical amount was 1.57 ppb. 
LC50 values for fish range from 280 to 860 ppb, and for estuarine
invertebrates range from 55 to 92 ppb.  Freshwater invertebrates are the
most sensitive aquatic animals to ADBAC with an acute EC50 of 5.9 ppb,
and a chronic NOAEC of 4.1 ppb.  Terrestrial animal species are not
expected to be directly impacted by this ADBAC use. Nontarget aquatic
species (fish, invertebrates, green algae) are not expected to be at
risk (acute or chronic) based on LOCs.  Endangered/threatened fish and
green algae species are not expected to be at risk from ADBAC
antisapstain use.  However, freshwater and marine aquatic invertebrates
are expected to be at risk from ADBAC antisapstain use unless methods
are used to prevent runoff from the treatment site (Ex. store treated
wood indoors, cover treated wood and use berms or plastic barriers in
outdoor storage areas).  ADBAC is tightly adsorbed to clay and organic
matter which greatly reduces potential for ADBAC to leach downward
through soil to groundwater or move via surface runoff.  The Tier I
screening model is only intended as a screening-level model, and, as
such, has inherent uncertainties and limitations which may result in
inaccurate exposure estimations.  Further refinements to the model are
recommended before any regulatory action is taken regarding the
antisapstain uses of ADBAC.  An environmental monitoring study of runoff
from antisapstain treatment facilities is needed to address the
potential risks and to provide EECs for use in a refined risk
assessment.  The Agency defers making an endangered species
determination for the antisapstain uses of ADBAC until after
environmental monitoring data and/or model refinements are completed.  

Endangered Species Considerations

Section 7 of the Endangered Species Act, 16 U.S.C. Section 1536(a)(2),
requires all federal agencies to consult with the National Marine
Fisheries Service (NMFS) for marine and andronomus listed species, or
the United States Fish and Wildlife Services (FWS) for listed wildlife
and freshwater organisms, if they are proposing an "action" that may
affect listed species or their designated habitat.  Each federal agency
is required under the Act to insure that any action they authorize,
fund, or carry out is not likely to jeopardize the continued existence
of a listed species or result in the destruction or adverse modification
of designated critical habitat.  To jeopardize the continued existence
of a listed species means "to engage in an action that reasonably would
be expected, directly or indirectly, to reduce appreciably the
likelihood of both the survival and recovery of a listed species in the
wild by reducing the reproduction, numbers, or distribution of the
species." 50 C.F.R. ( 402.02.

To facilitate compliance with the requirements of the Endangered Species
Act subsection (a)(2) the Environmental Protection Agency, Office of
Pesticide Programs has established procedures to evaluate whether a
proposed registration action may directly or indirectly reduce
appreciably the likelihood of both the survival and recovery of a listed
species in the wild by reducing the reproduction, numbers, or
distribution of any listed species (U.S. EPA 2004).  After the Agency(s
screening-level risk assessment is performed, if any of the Agency(s
Listed Species LOC Criteria are exceeded for either direct or indirect
effects, a determination is made to identify if any listed or candidate
species may co-occur in the area of the proposed pesticide use.  If
determined that listed or candidate species may be present in the
proposed use areas, further biological assessment is undertaken.  The
extent to which listed species may be at risk then determines the need
for the development of a more comprehensive consultation package as
required by the Endangered Species Act.

The endangered species Alternative Consultation Agreement (ACA) with
NMFS, and FWS will take time to implement fully, depending on available
resources.  The Agency is currently preparing risk assessments with the
services on 9 high priority agricultural pesticides.  Endangered species
assessments of antimicrobial and additional agricultural pesticides will
commence in 2008 under the Registration Review program.

.

11.0	REFERENCES tc \l1 "7.0	REFERENCES 

American Chemistry Council (ACC). 2002a.  Assessment of Potential
Inhalation and Dermal Exposure Associated With Pressure Treatment of
Wood with Arsenical Wood Products.  MRID 4550211-01.

American Chemistry Council (ACC). 2002b.  An Analysis of the Training
Patterns and Practices of Competitive Swimmers.  Prepared by Richard
Reiss.  Sciences International, Inc. Alexandria, Virginia.  December 9,
2002.

American Chemical Council (ACC), 2005.  Slimicide Use in Papermaking
(Powerpoint Presentation).  ACC Biocides Council, September 17, 2003.

  SEQ CHAPTER \h \r 1 Bestari KT, Macey K, Soloman KR, Tower N. 1999. 
Measurement and Assessment of Dermal and Inhalation Exposures to Didecyl
Dimethyl Ammonium Chloride (DDAC) Used in the Protection of Cut Lumber
(Phase III). MRID 455243-04.

Bryan, Elizabeth. 1988. Methods for Estimating Retention of Liquid on
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  SEQ CHAPTER \h \r 1 CEC, 2001.  Residential Manual for Compliance with
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http://www.energy.ca.gov/title24/residential_manual/index.html, viewed
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DOE.  1997.  Energy Information Administration: Profile of Commercial
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FDA. 2003.  “Sanitizing Solutions:	Chemistry Guidelines for Food
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Helwig, D. (2003) Personal Communication between D. Helwig (Johnson
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HERA, 2003.  Human and Environmental Risk Assessment, Guidance Document
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(http://www.heraproject.com/files/Guidancedocument.pdf).

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Assessment in support of the Antimicrobials Division’s Reregistration
of ADBAC and DDAC. DP Barcodes: D322872 and D325481

MCCEM V 1.2  The Multi-Chamber Concentration and Exposure Model (MCCEM)
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Jacobson, Larry. 2005.  Professor and Extension Engineer at University
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SIMetric. 2005.    HYPERLINK
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"http://www.usaid.gov/our_work/humanitarian_assistance/ffp/crg/annex-3.h
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http://www.usaid.gov/our_work/humanitarian_assistance/ffp/crg/annex-3.ht
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(NHAPS) Data; EPA/600/R-96/148, July 1996.   Data Collection Period
October 1992 - September 1994 . 

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

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

  SEQ CHAPTER \h \r 1 USEPA. 1999.  Evaluation of Chemical Manufacturers
Association Antimicrobial Exposure Assessment Study (Amended on 8
December 1992).  Memorandum from Siroos Mostaghimi, PH.D., USEPA to
Julie Fairfax, USEPA. Dated November, 4 1999.  DP Barcode D247642.

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

USEPA.  2001.  HED Science Advisory Council for Exposure. Policy Update,
November 12.  Recommended Revisions to the Standard Operating Procedures
(SOPs) for Residential Exposure Assessment, February 22, 2001. 

USEPA. 2003.  Assessment of the Proposed Bardac Wood Preservative
Pressure Treatment Use.  Memorandum from Tim Leighton and Siroos
Mostaghimi.  February 11, 2003.

USEPA. 2004.  Occupational and Residential Exposure Assessment for
Carboquat WP-50.  Memorandum from Siroos Mostaghimi, USEPA to Welma
Noble, USEPA.   Dated November 4, 2004. DP Barcodes D303714 and D303938.

USEPA. 2005. Dietary Assessment of Chlorine Dioxide, Sodium Chlorite
From Their Use As Indirect Food Contact Sanitizers/Disinfectants (Hard
Surface Sanitizers). Memorandum from Najm Shamim, USEPA to Melba Morrow
and Jennifer Slotnick, USEPA. Dates August 15, 2005.  

USEPA. 2006.  Alkyl dimethyl benzyl ammonium chloride (ADBAC) – Report
of the Antimicrobials Division Toxicity Endpoint Committee (ADTC) and
the Hazard Identification Assessment Review Committee (HIARC).  January
9, 2006.

USEPA 2006.  Alkyl dimethyl benzyl ammonium chloride (ADBAC): 
Occupational and Residential Exposure Assessment for the Reregistration
Eligibility Decision Document.  DP Barcode D326917.  Dated February 27,
2006.

Toxicology References

45109204 (MRID) Bonnette, K. (1998) An Acute Oral Toxicity Study in Rats
with BQ 451-8: Lab Project Number: 3192.32. Unpublished study prepared
by Springborn Laboratories. 90 p.

45109202 (MRID) Moore, G. (1999) Acute Dermal Toxicity Study in Rats:
Albemarle BQ451-8 Biocide: Lab Project Number: 7466: P322. Unpublished
study prepared by Product Safety Labs. 25 p.

44885201 (MRID) Wnorowski, G. (1999) Acute Inhalation Toxicity Study in
Rats: Albemarle BQ451-8 Biocide: Lab Project Number: 7467: P330.
Unpublished study prepared by Product Safety Labs. 30 p.

40919701 (MRID) Kreuzmann, J. (1988) Repeated Eye Instillation Study in
Rabbits: Alkyl dimethyl benzyl ammonium chloride (ADBAC): Study No.: 88-
3336-21. Unpublished study prepared by Hill Top Biolabs, Inc. 20 p.

44825001 (MRID) Kreuzmann, J. (1999) Repeated Eye Instillation Study in
Rabbits of Alkyl Dimethyl Benzyl Ammonium Chloride (ADBAC): Report
Amendment: Lab Project Number: 88-3336-21. Unpublished study prepared by
Hill Top Research, Inc. 4 p.

45109201 (MRID) Moore, G. (1999) Primary Skin Irritation Study in
Rabbits: Albemarle BQ451-8 Biocide: Lab Project Number: 7468: P326.
Unpublished study prepared by Product Safety Labs. 15 p.

45109203 (MRID) Moore, G. (1999) Dermal Sensitization Study in Guinea
Pigs (Buehler Method): Albemarle BQ451-8 Biocide: Lab Project Number:
7469: P328. Unpublished study prepared by Product Safety Labs. 24 p.

40958501 (MRID) Kreuzmann, J. (1989) Photoallergy Study in Guinea Pigs:
Study No. 88-3226-21. Unpublished study prepared by Hill Top Biolabs,
Inc. 63 p.

44825002 (MRID) Kreuzmann, J. (1999) Photoallergy Study in Guinea Pigs
with: Alkyl Dimethyl Benzyl Ammonium Chloride (ADBAC): Report Amendment:
Lab Project Number: 88-3226-21. Unpublished study prepared by Hill Top
Research, Inc. 4 p.

40746601 (MRID) Van Miller, J.; Weaver, E. (1988) Ninety-day Dietary
Toxicity Study with Alkyl Dimethyl Benzyl Ammonium Chloride (ADBAC) in
Rats: Project ID: 51-503. Unpublished study prepared by Bushy Run Re-
search Center. 300 p.

41105801 (MRID) Rose, G. (1989) Acute Toxicology (EP): HS-Sanitizing
Carpet Shampoo: Project ID: B6-27. Unpublished study prepared by
Envirocon. 36 p.

41499601 (MRID) Gill, M.; Wagner, C. (1990) Ninety-day Subchronic Dermal
Toxicity Study with Alkyl Dimethyl Benzyl Ammonium Chloride (ABDAC) in
Rats: Lab Project I.D.: 52-623. Unpublished study prepared by Union
Carbide Bushy Run Research Center. 264 p.

42645101 (MRID) Chun, J.; Fisher, L. (1993) Developmental Toxicity Dose
Rang-Finding Study of Alkyl Dimethyl Benzyl Ammonium Chloride (ADBAC)
Administered by Gavage to CD Rats: Lab Project Number: 54-613.
Unpublished study prepared by Bushy Run Research Center (BRRC). 104 p.

42351501 (MRID) Neeper-Bradley, T. (1992) Developmental Toxicity
Evaluation II of Alkyl Dimethyl Benzyl Ammonium Chloride (ADBAC)
Administered by Gavage to CD Rats: Lab Project Number: 91N0031.
Unpublished study prepared by Union Carbide Chemicals and Plastics Co.,
Inc. Bushy Run Research Center. 281 p.

42734401 (MRID) Chun, J.; Neeper-Bradley, T. (1993) Developmental
Toxicity Dose Range-Finding Study of ADBAC Administered by Gavage to New
Zealand White Rabbits: Lab Project Number: 54-603. Unpublished study
prepared by Union Carbide. 118 p.

42392801 (MRID) Neeper-Bradley, T.; Kubena, M. (1992) Developmental
Toxicity Evaluation of Alkyl Dimethyl Benzyl Ammonium Chloride (ADBAC)
Administered by Gavage to New Zealand White Rabbits: Lab Project Number:
91N0032. Unpublished study prepared by Union Carbide. 179 p.

41385001 (MRID) Neeper-Bradley, T. (1990) Two-generation Reproduction
Study in Sprague-Dawley (CD) Rats with Alkyl Dimethyl Benzyl Ammonium
Chloride (ADBAC) Administered in the Diet: Project Report 52- 52-254:
Project Nos. 87-37-97105; 87-37-97109. Unpublished study prepared by
Bushy Run Research Center. 492 p.

43221101 (MRID) Goldenthal, E. (1994) Evaluation of ADBAC in a One-Year
Chronic Dietary Toxicity Study in Dogs: Lab Project Number: 638-004.
Unpublished study prepared by International Research and Development
Corp. 355 p.

41765201 (MRID) Gill, M.; Hermansky, S.; Wagner, C. (1991) Chronic
Dietary Oncogenicity Study with Alkyl Dimethyl Benzyl Ammonium Chloride
(ADBAC) in Mice: Lab Project Number: 53-515. Unpublished study prepared
by Bushy Run Research Center. 1083 p.

41947501 (MRID) Gill, M.; Hermansky, S.; Wagner, C. (1991) Chronic
Dietary Toxicity/Oncogenicity Study with Alkyl Dimethyl Benzyl Ammonium
Chloride (ADBAC) in Rats: Lab Project Number: 53-543. Unpublished Study
prepared by Bushy Run Research Center. 1671 p.

42290801 (MRID) McKeon, M. (1992) Genotoxicity Test on Alkyl Dimethyl
Benzyl Ammonium Chloride (ADBAC) in the Assay for Unscheduled DNA
Synthesis in Rat Liver Primary Cell Cultures: Lab Project Number:
14778-0-447. Unpublished study prepared by Hazleton Washington, Inc. 51
p.

41012701 (MRID) Young, R. (1989) Mutagenicity Test on Alkyl Dimethyl
Benzyl Ammonium Chloride: In the CHO/HGPRT Forward Mutation Assay: HLA
Study No. 10238-0-435. Unpublished study prepared by Hazleton
Laboratories America, Inc. 67 p.

40311101 (MRID) Kallersen, T. (1985) Assessment of the Mutagenic
Activity of Hya- mine 3500 in the Mouse Micronucleus Test: Lab. No.
10753. Un- published study prepared by Scantox Labs Ltd. 17 p.

43037701 (MRID) Schoenig, G. (1993) Response to EPA Data Evaluation
Review for Study Entitled: "Chromosome Aberrations in vivo--Mouse
Micronucleus Test": Lab Project Number: 10753. Unpublished study
prepared by SCANTOX Biologisk Laboratorium A/S. 7 p.

42290802 (MRID) McKeon, M. (1989) Alkyl Dimethyl Benzyl Ammonium
Chloride (ADBAC) in the Rat Primary Hepatocyte Unscheduled DNA Synthesis
Assay: An Addendum: Lab Project Number: 10238-0-447. Unpublished study
prepared by Hazleton Laboratories America, Inc. 11 p.

41012601 (MRID) Cifone, M. (1989) Mutagenicity Test on Alkyl Dimethyl
Benzyl Ammonium Chloride: In the Rat Primary Hepatocyte Unscheduled DNA
Synthesis Assay: HLA Study No. 10238-0-447. Unpublished study prepared
by Hazleton Laboratories America, Inc. 56 p.

40990701 (MRID) Selim, S. (1989) Absorption, Distribution, Metabolism
and Excretion Studies of Alkyl Dimethyl Benzyl Ammonium Chloride (ADBAC)
in the Rat: BTC Study No. P01359. Unpublished study prepared by
Biological Test Center. 247 p.

41087701 (MRID) Lin, P.; Selim, S. (1989) Addendum to Report Entitled
"Absorption, Distribution, Metabolism and Excretion Studies of Alkyl
Dimethyl Benzyl Ammonium Chloride (ADBAC) in the Rat" MRID 40990701:
Study No. P01359. Unpublished study prepared by Biological Test Center.
44 p.

44783401 (MRID) Mazur, P. (1999) Absorption, Distribution, Metabolism
and Excretion (ADME) Studies of Alkyl Dimethyl Benzyl Ammonium Chloride
(ADBAC) in the Rat and Addendum: Lab Project Number: P01359. Unpublished
study prepared by ADBAC Quat Joint Venture/Chemical Specialities
Manufacturers Assoc. 4 p.

USEPA (1999): Alkyl dimethylbenzyl ammonium chloride (ADBAC) – Report
of the Hazard Identification Assessment Review Committee, Office of
Prevention, Pesticides, and Toxic Substances.

USEPA (2000): Memorandum on Sterilex ® Ultra-Kleen for Dental Unit
Water lines:  Request for Risk Assessment.  Submission S572183.

Incidence Reports

Dibo, M.  and Brasch, J.  2001.  Occupational allergic contact
dermatitis from N,N-bis93-aminoprpyl)dodecylamine and
dimethyldidecylammonium chloride in two hospital staff.  Contact
Dermatitis.  45(1):40.

Mehler, L. 2005.  Personal Communication.  California Department of
Pesticide Regulation

Oriandini, A.; Viotti, G.  Martinoli, C; and Magno, L.  1990.  Allergic
Contact Conjunctivities from synthetic detergenets in nurse.  Contact
Dermatitis.  23:  376-377.

Preller, L.; Doekers, G.; Heederik, D.; Vermulen, R.; Vogelzang, P.F.J,
and Boleij, J. S.M.  1996. Disinfinfectant use as a risk factor for
atopic sensitization and symptoms consistent with asthma: an
epidemiological study.  European Respiratory Journal: 9 (7) 1407-1413.

Shmunes, E. and Levy, E.J.  1972.  Quaternary ammonium compound contact
dermatitis from deodorant.  Arch Dermatol.  105(1) 91-93.

.

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nspected food processing facilities, breweries, fast food operations
floors, walls, countertops, appliances (microwaves, refrigerators, stove
tops, freezers, coolers), chairs, tables, shelves, picnic tables,
outdoor furniture, racks, carts, telephones, door knobs, storage areas,
potato storage areas, food storage areas, garbage storage areas, cutting
boards, tanks, exhaust fans, refrigerator bins, refrigerated
storage/display equipment, coils and drain pans of air
conditioning/refrigeration equipment, heat pumps, storage tanks,
coolers, ice chests, garbage cans/pails metal, stainless steel, glazed
porcelain, glazed ceramic tile, plastic, granite, marble, chrome, vinyl,
glass, chrome plated intakes, enameled surfaces, painted woodwork,
Formica, vinyl and plastic upholstery	RTU Spray/wipe

As needed

1839-155  (FCS)	restaurants, food service establishments,  Bars,
Cafeteria, convenience stores, dairies, food handling areas, food
preparation areas, food storage areas institutional kitchens, fast food
operations	dairy equipment, dairy farm bulk milk tanks, milking
equipment, tanks, piping, pasteurizers, cow udders, dairy product
dispensing equipment, drinking glasses, eating utensils, cooking
utensils, silverware, glassware, dishes, ice machines, beverage
dispensing equipment, counters, tables, cutting boards, Slurrpy
machines, ice cream dispensing equipment, food dispensing equipment,
utensils and other food contact articles	spray, flood, immersion,
brushing, RTU wipe/spray

As needed

1839-51	Food processing plants/facilities (including beverage, meat,
poultry, egg, seafood, fisheries, milk, citrus, potato, ice cream), Egg
Processing plants,  Federally inspected meat and poultry plants,  Food
Handling areas, Food preparation areas,  Food storage areas,   USDA
inspected food processing facilities, breweries	storage tanks, meat/
poultry/ fruit/ vegetable conveyers, tanks, chopping block, countertops,
sinks, sink tops, utensils, knives, grinders, shredders, cleavers,
ladles, food grade eggs, ice machines, water coolers, water holding
tanks, pressure tanks, refrigerated storage/display equipment, exhaust
fans, coils and drain pans of air conditioning/refrigeration equipment,
heat pumps, storage tanks, beer fermentation equipment and holding
tanks, blenders, food processors, bottling or pre-mix dispensing
equipment, citrus processing equipment (holding tanks, bottles, cans),
cutting boards, coolers, ice chests, ice machines, refrigerator bins,
beer fermentation and storage tanks	spray, flood, immersion, brushing,
RTU wipe/spray

As needed

1839-155

water softeners and reverse osmosis units

	As needed

1839-81	dairies, beverage and food processing plants	room surfaces
fogging

As needed

1020-1	food and bottling plant, dairy farms, egg product processing
plants and milk plants	walls, floors, equipment, other hard nonporous
surfaces	mop, brush, cloth or sponge



1203-41	food processing plants, food service areas, institutional
kitchens, industrial/hospital cafeterials, school lunchrooms, canning
plants, dairies, and packing plants	tables,walls, ceramic tiles, metal
surfaces, plastic, asphalt, finished/painted wood and glass	spray, mop,
sponge

As needed

10324-80	food processing plants, food service areas, institutional
kitchens, industrial/hospital cafeterials, school lunchrooms, dairies,
and packing plants	air ducts	spray, brush, mop, wipe,ULV or mist
generating, automated spray	odor causing bacteria, fungi,	6 months

Cleaning/ Deodorizing

10324-118	residential, commercial, institutional, industrial,	garbage
cans, garbage trucks, industrial waste receptacles, garbage handling
equipment	sprayer, sponge, cloth,	Cleaning/ Deodorizing	As needed

1839-81	Water/Smoke restoration (institutional, industrial, hospital,
nursing home)	carpets, carpet cushion, sub floors, drywall, trim, farm
lumber, tackless strip and paneling	Mop/wipe, cloth, brush, sponge,
sprayer	Cleaning/ Deodorizing	As needed

10324-118	Sewer backup/river flood cleanup/clean water source	carpets,
carpet cushion, sub floors, drywall, trim, farm lumber, tackless strip
and paneling	spray	Cleaning/ Deodorizing	As needed

5174-22	schools, day care centers, restaurants, cafeterias, convenience
stores, kennels, restrooms, hospitals, nursing homes	hard non-porous
surfaces	mop, sponge, or spray	Cleaning/ Deodorizing	As needed



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