	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

	WASHINGTON, D.C. 20460

Office Of

Prevention, Pesticides

And Toxic Substances

MEMORANDUM

Date:		April 21, 2006 

Subject:	Carbaryl:  Data Evaluation Record For MRID 466739-01; Sevin 2G
- Determination of Transferable Residues From Turf; PC Code 056801; DP
Barcode 323247

From:	Jeffrey L. Dawson, Chemist

Reregistration Branch 1 

Health Effects Division (MC 7509C)

Through:	Whang Phang, Branch Senior Scientist

Reregistration Branch 1 

Health Effects Division (MC 7509C)

To:		Christina Scheltema

		Chemical Review Manager

		Special Review & Reregistration Division

This document serves as the data evaluation record for the combined
carbaryl granular turf transferable residue (TTR) dissipation and hand
press study.  The primary review was conducted by Versar, Inc. under
task order 11.1399.1007.001 (TAF# 5-1-25).  The primary reviewers were
Teri Schaeffer and Susan Anderson, and the primary review was finalized
on April 4, 2006.  Some of the elements of the primary review were
modified during the secondary review completed at the Agency as
warranted.  The Agency concurs with the elements presented in the
attached primary review.  In this study, handpress sampling of residues
from treated turf were collected; these residue values can be used to
estimate exposures from the mouthing behaviors of children.  The hand
press method involves intentional human contact with treated residues
and, as such, the review process under the current Agency policy for
involving subjects in research was followed.  [See
http://www.epa.gov/osa/hsrb/ for further information.]  All results of
this process are addressed separately and should be referred to when the
results of the handpress elements of this study are considered for risk
assessment purposes.  

 

The results indicate that turf transferable levels on the day of
application ranged from 0.04 to 0.29 µg/cm2 when plots were irrigated
and from 0.16 to 0.55 µg/cm2 when plots were not irrigated.  TTR
samples were collected using the modified California roller technique. 
Trends in the handpress results were similar.  Handpress samples were
collected from irrigated and non-irrigated plots using wet or dry hands.
 For the irrigated plots, handpress-based transferable levels on the day
of application were 0.06 and 0.08 µg/cm2 for dry and wet hands,
respectively.  When plots were not irrigated, handpress-based
transferable levels on the day of application were 0.24 and 0.58 µg/cm2
for dry and wet hands, respectively.  The percent transferability for
all sites and methods on the day of application was less than 1 percent
of the application rate in all cases, regardless of sampling method
(i.e., 0.05 to 0.66 percent).  Residues also dissipated quickly in all
cases.  Half lives were calculated based on TTR data and ranged from
0.76 to 2.4 days for non-irrigated plots and 1.23 to 1.35 days for the
irrigated plots.  The key consideration in the interpretation of the
data from this study is that significant rainfall and also irrigation
water was added to the turf at various sites.  Irrigation water (i.e.,
between 0.30 and 0.50 inches) was applied immediately after application.
   Natural rainfall also occurred at the Kansas and Florida sites, none
was observed in California.  In Kansas, the first rainfall (0.35 inches)
occurred prior to the 24 hour sample and 3.46 inches total occurred over
the entire study.  In Florida, the first rainfall (0.16 inches) occurred
prior to the 3 day sample and 2.48 inches occurred in total.

		

Reviewer:   Teri Schaeffer /Susan Anderson                              
              Date   April, 4, 2006

STUDY TYPE: 	Determination of Transferable Turf Residue Dissipation from
Turf Treated with SEVIN® 2G 

  

TEST MATERIAL: 	SEVIN® 2G is a wettable granule formulation containing
2.0% (w/w) carbaryl as the formulated active ingredient.

SYNONYMS:    		The IUPAC and CAS chemical name for carbaryl is
1-Naphthylenyl methylcarbamate. The CAS number for carbaryl is 63-25-2.

CITATION: 	Author:			M.E. Krolski, Study Director

		Title:			SEVIN 2G - Determination of Transferable Residues on Turf

		Report Date:		September 30, 2005

		Testing Facility:		Bayer CropScience

					Environmental Research

					Bayer Research Park

					17745 South Metcalf Avenue

					Stilwell, KS 66085-9104

						and

					Grayson Research LLC

					10 Barkridge Ct.

					Durham, NC 27713

		Analytical Laboratory:	ABC Laboratories, Inc.

					7200 E. ABC Lane

					Columbia, MO 65202

		Identifying Codes:	Bayer Study Number CA25TF01; Bayer PSI/Report
Number RACAX015; MRID 46673901; Unpublished

	

SPONSOR:				Bayer CropScience

					2 T.W. Alexander Drive

					Research Triangle Park, NC 27709

EXECUTIVE SUMMARY: 

This study was designed to determine transferable residues of carbaryl
from both irrigated and non-irrigated turf treated with SEVIN® 2G at a
target application rate of  9 lb formulated product/1000ft2 (0.18 lb
ai/1000ft2), equating to or 392 lb formulated product per acre (7.84 lb
ai/A).  The field trials were conducted at three locations: Molino, FL
(EPA Region 3), Stilwell, KS (EPA Region 5), and Fresno, CA (EPA Region
10). SEVIN™ 2G, formulated as wettable granules containing 2.0% active
ingredient (ai) carbaryl, was applied once to each plot using a drop
spreader.  Transferable residues were measured using the modified
California roller method for turf transferable residues (TTR) and also a
hand press method in order to provide values which can be used to assess
exposures from the mouthing behaviors of children.  [Note:  The hand
press method involves human contact with treated residues and, as such,
the review process under the current Agency policy for involving
subjects in research was followed.  See http://www.epa.gov/osa/hsrb/ for
further information.]  TTR samples were collected at all sites while
hand press samples were collected only at the Kansas site.  Triplicate
TTR samples were collected prior to application, immediately after
application, 4 hours after, 10 hours after, and 1, 2, 3, 5 and 7 days
after treatment (DAT).  Dry and moist hand press samples were collected
from both the irrigated and non-irrigated plots at the Stilwell, KS test
site immediately after the application and 5 days after application to
measure the potential transfer of carbaryl residues via hand contact
with the treated turf.  Irrigation water (i.e., between 0.30 and 0.50
inches) was applied immediately after application was complete to the
appropriate sites.  Natural rainfall also occurred at the Kansas and
Florida sites, none was observed in California.  In Kansas, the first
rainfall (0.35 inches) occurred prior to the 24 hour sample and 3.46
inches total occurred over the entire study.  In Florida, the first
rainfall (0.16 inches) occurred prior to the 3 day sample and 2.48
inches total occurred over the entire study.  

Estimated half-life values were 0.836 days (R2=0.81) for carbaryl TTRs
from the non-irrigated Florida plot and 1.23 days (R2=0.61) from the
irrigated Florida plot.  At the Kansas site, the estimated TTR half-life
values were 0.764 days (R2=0.68) from the non-irrigated plot and 1.35
days (R2=0.54) from the irrigated plot.  At the California site,
estimated TTR half-life values were 1.23 days (R2=0.62) from the
non-irrigated plot and 2.40 days (R2=0.34) from the irrigated plot.  For
the irrigated plots, the percent of the  target application rate of
carbaryl transferred to the cloth dosimeters immediately after
application ranged from 0.05% to 0.33% with an average of 0.14%.  For
the non-irrigated plots, the percent of the target application rate of
carbaryl transferred to the cloth dosimeters immediately after
application ranged from 0.19% to 0.6% with an average of 0.44%. 
Initially, carbaryl TTRs were lower in samples from the irrigated plots
than from corresponding samples collected from the non-irrigated plots. 
Measured carbaryl residues rapidly declined over the first 4 hours and
then levelled off or rose slightly after 12 hours.  By the 24-hour
sampling interval, the residues declined to approximately 10 percent of
the corresponding 0-time residue value and then steadily dropped to
below 1.0 percent of the corresponding 0-time residue values by 3 to 5
days after treatment.

g/cm2).   At the first post application collection immediately after
application, the percent of the applied carbaryl (i.e., 88 ug/cm2) which
transferred to hand presses from the irrigated plot ranged from 0.07% to
0.09% for the dry and moist hand wipes, respectively.  Similarly, the
percent of the original applied carbaryl (i.e., 88 ug/cm2) which
transferred to hand presses from the non-irrigated plot ranged from
0.27% for dry hand presses to 0.66% for moist hand presses.    

This study met most of the Series 875, Group B:875.2100 Guidelines. 
None of the issues which were identified in this review preclude the use
of this study for risk assessment purposes.  However, some should be
considered as having a direct impact on measured results (e.g.,
rainfall) which should be carefully considered when using the results of
this study for assessment purposes.  The issues which were identified
include: 

(1) 	At the Kansas and Florida sites, significant rainfall was noted
throughout the course of the study (i.e., 2.48” total in Florida and
3.46” in Kansas with 0.35 inches of rain falling on the day of
application Kansas - but the Kansas rainfall did not impact residue
levels until the 24 hour sample), rain also prevented sampling at the 48
hour interval;

(2) 	Field fortification recoveries extracted using 100% acetonitrile
ranged from 41% to 42% with an overall average percent recovery of 42%
± 0.7% while field fortification recoveries extracted using 10%
MeOH/ACN ranged from 40% to 103% with an overall average percent
recovery of 79% ± 17.7%.  Samples analyzed with 100 percent
acetonitrile have more uncertainty associated with them than do samples
analyzed with the methanol mixture.  The generally accepted recovery
range is 70 to 120% with a standard deviation of less than 30%;  

(3) 	Meteorological conditions including temperature, wind speed, daily
rainfall, and humidity were not provided for the duration of the study; 

(4) 	No mention was made of calibrating the application equipment; and

(5) 	Actual application rates for plots 2GIR and 2G at the Kansas test
site were 122% and 125% of the target application rate, respectively.



COMPLIANCE:	Signed and dated GLP, Quality Assurance, and Data
Confidentiality statements were provided.  The study sponsor waived
claims of confidentiality within the scope of FIFRA Section 10 (d) (1)
(A), (B), or (C).  The Study Report indicated that the study was
conducted under EPA Good Laboratory Practice Standards (40 CFR Part
160), with the following exceptions: (1) weather data were not collected
according to GLP; (2) application of maintenance chemicals were not
performed under GLP; (3) pesticide history data were not collected
according to GLP; (4) irrigation records were not kept according to GLP;
and (5) cultural practices were not collected under GLP. According to
the study author, these GLP deviations did not compromise the scientific
integrity of the study.

CONCURRENT EXPOSURE  STUDY?: 			No

GUIDELINE OR PROTOCOL  FOLLOWED:		This study was conducted according to
Bayer CropScience’s approved protocol number CA25TF01 and OPPTS’
Series 875, Occupational and Residential Exposure Test Guidelines, Group
B: Post-application Exposure Monitoring Test Guidelines, 875.2100,
Transferable Residue Dissipation, Lawn and Turf. A compliance checklist
is provided in Appendix A – note that the major issues were described
above in the executive summary.

I.   MATERIALS AND METHODS

A.  MATERIALS

1.  Test Material: 

Formulation:			SEVIN® 2G is a wettable granule formulation containing
2.0% (w/w) carbaryl as the active ingredient.

Lot #:				A403107 and A404116 (formulated product)

				0725200203 (vial number for analytical standard)

Formulation guarantee:		The GLP analysis for the formulated test
products stated that the formulations contained 1.91% ai for lot number
A403107 (expiration date of 10/27/06) and 2.11% ai for lot number
A404116 (expiration date of 7/8/06). The GLP analysis of the analytical
standard reported a purity of 99.8% (expires 11/13/06).

CAS #(s):			63-25-2

		

2.  Relevance of Test Material to Proposed Formulation(s):

According to the Study Report, the test product sent to the field site
was SEVIN® 2G, containing 2% carbaryl as the active ingredient, and the
application rate for the formulated product was 9 lb/1000 ft2.  The
label which closest resembles the product name is for called SEVIN® 2%
Granular Insecticide (EPA Reg. Number 769-976).  The maximum label
recommended application rate for this product is 10.5 lbs/1000 ft2.  
The second applicable label is for a product called SEVIN® Grub Killer
Granules (2% SEVIN).  The EPA Reg. Number for this product is 432-1212. 
The maximum label recommended application rate for this product is 9
lb/1000 ft2.  

 



B.  STUDY DESIGN

The approved study protocol was provided in the study. The Study Report
lists two amendments to, and five deviations from the study protocol. 
The amendments involved: (1) termination of Trial CA002-03D due to an
application error (Trial CA002-03DA was the replacement trial) and (2)
providing information for the test site locations and identifying the
Principal Field Investigator’s for each location. The deviations
involved: (1) actual application rates for plots 2GIR and 2G at test
site CA002-03DA were 122% and 125% of the target application rate,
respectively; (2) Standard Masses were to be selected in the range of
the chemicals to be weighed but the largest Standard Mass available was
2 kg and the chemical was weighed out to 6.81 kg at the CA002-03DA
trial; (3) rain prevented sampling at the 48 hour sampling interval at
the CA002-03DA trial; (4) post application samples were to be collected
no later than 2 hours of the application, however at the CA002-03DA
trial the turf was very wet after irrigation.  The post application
samples were collected 2 hours and 45 minutes after the application; and
(5) at trial CA003-03D the post application samples for the 2GIR plot
were collected between 2 hours, 40 minutes and 2 hours, 50 minutes after
the application due to the turf being wet after irrigation. The study
author did not comment on the effects these deviations had on the study.

1.   Site Description

Test locations: 		The field portion of the study was conducted at three
locations:  Molino, FL (Trial CA001-03D, EPA Region 3), Stilwell, KS
(Trial CA002-3DA, EPA Region 5), and Fresno, CA (Trial CA003-03D, EPA
Region 10).  Trial CA002-3DA at the Stilwell, KS location is a
replacement for Trial CA002-03D, which was terminated due to application
rate errors.

Areas sprayed and sampled:	Two plots were established at each location
and each plot was divided into three subplots for sampling purposes. One
plot was used for the non-irrigated application (identified as plot 2G)
and the second plot was used for the irrigated application (identified
as plot 2GIR). The control samples were collected from each plot prior
to the application. 

				Florida -	Both the non-irrigated and irrigated test plots measured 3
ft wide by 98.4 ft long (0.0068 acres). 

				Kansas -	There were four established plots at this test site to
collect cloth dosimeters and hand press samples. Two plots were used for
the non-irrigated applications (identified as plots C2G and 2G) and the
remaining two plots were used for the irrigated applications (identified
as plots C2GIR and 2GIR). Each of the four test plots measured 12.1 ft
wide by 100 ft long (0.0278 acres).   

				California -	Both the non-irrigated and irrigated test plots
measured 8.99 ft wide by 115 ft long (0.0237 acres).

Meteorological Data: 		The Study Report provided limited meteorological
data for each of the test sites. The Report identified a range of
temperatures, total rainfall and total irrigation applied for the
interval from the application date out to the date of the last sampling
event.  The Study Report did not provide relative humidity, wind speed,
wind direction and daily rainfall measurements for any of the test
sites. It is not certain where the meteorological data provided in the
Study Report for each site were collected.  However, the Study Report
stated that the closest government weather station to the Florida site
was NOAA 086997 in Pensacola, Florida. The closest government weather
stations to the Kansas and California sites were NO 145972 in Olathe,
Kansas and NO 043257 at the Fresno Yosemite Intl. Airport in Fresno,
California, respectively.  The meteorological data collected during this
study period are provided in Table 1.

Table 1. Meteorological Data at Study Sitesa

Test Site	Trial Number	Application Date	Temperature

Range

(oF)	Rainfall within 24 Hrs of Application

(inches)	Total Rainfall

(inches)	Total Irrigation

(inches)

Florida	CA001-03D	11/16/04	50 –79	0.0	2.48	0.5

Kansas	CA002-03DA	7/22/04	56 – 90	0.35	3.46	0.3

California	CA003-03D	8/17/04	63 - 102	0.0	0.0	0.48

a  Data is for interval from date of  application to last sampling.  The
amount of water on the treated plots is the key issue with
characterizing the residue levels from this study.  Irrigation water
(i.e., between 0.30 and 0.50 inches) was applied immediately after
application was complete to the appropriate sites.  Natural rainfall
also occurred at the Kansas and Florida sites, none was observed in
California.  In Kansas, the first rainfall (0.35 inches) occurred prior
to the 24 hour sample and 3.46 inches total occurred over the entire
study.  In Florida, the first rainfall (0.16 inches) occurred prior to
the 3 day sample and 2.48 inches total occurred over the entire study.

2.   Surface Monitored:

Turf Species:			Florida -		The turf variety used was St. Augustine. The
turf grass at this site was planted in March of 1999.  				

				Kansas -		The turf variety used was Fescue. The Study Report did not
provide information on when the turf grass was planted at this test
location.                  

	

				California -	The turf variety used was Bermuda. The turf grass at
this site was planted in March of 2004.  

		

Residential or Public Area:	All of the treated plots were located at
research facilities simulating residential use.  The formulation is
intended for use on residential turf.

Other relevant characteristics: 	According to the Study Report, all
three field trials were conducted on established turf mowed to a height
of approximately 2 inches (5 cm) at least 48 hours prior to the
application. The grass clippings were removed from the plots at the time
of the last mowing. The plots were not mowed again until after the last
sampling interval.  Immediately following application, the 2GIR and
C2GIR plots were irrigated with 0.25 to 0.50 inches of water. Typical
agronomic practices specific to the location of each test site were used
for growing and maintaining the turf.

Other products used on turf

(treated plot):		Florida -	No maintenance chemicals were applied to the
treated plots during the study period.  Fertilizer (27-3-14) was applied
to the test plots prior to study initiation on June 1, 2004 at an
application rate of 100 kg/ha.  Another fertilizer (30-3-4) was applied
at a rate of 100 kg/ha but the date of the application was not provided.
 Historical pesticide use data were provided on page 77 of the Study
Report for the year 2004.  A crop history for the test plots was not
provided in the Study Report.

			Kansas -	No maintenance chemicals or fertilizers were applied to the
treated plots during the study period.  Historical pesticide use data
were provided on page 83 of the Study Report for the years 2001 through
2003. A crop history for the test plots was not provided in the Study 
Report.

			California -	No maintenance chemicals or fertilizers were applied to
the treated plots during the study period.  Historical pesticide use
data were provided on page 87 of the Study Report for the years 1999
through 2003.  A crop history for the test plots was not provided in the
Study Report.

3.  Physical State of Formulation as Applied:

The physical state of the applied product was a wettable granular
formulation.

4.   Application Rates and Regimes:

Residential or Commercial Applicator:	The turf was cultured and
maintained according to accepted local residential practices.

Application rate:				A single application was performed on each test
plot at each test site. The target application rate was 0.18 lb ai/1000
ft2 or 8.8 kg ai/ha (9 lb ai/A) for each of the test plots.  Table 2
provides a summary of the actual application rates for each of the plots
at each location. The actual application rates for the three test sites
ranged from 91% to 123% of the target application rate.  

Table 2.  Actual Application Rates for Each Test Plot at Each Test
Location

Location	Plot ID	Actual Application Rate

(kg product/ha)	Actual Application Rate

(lb ai/A)	Percentage of Target Application Rate (%)

Florida	2G	428	7.64	97

	C2GIR	398	7.10	91

Kansas	2Ga	530	9.46	121

	C2GIRb	542	9.67	123

California	2G	440	7.85	100

	2GIR	449	8.01	102

		a Kansas plot ID 2G takes into account both non-irrigated plots (cloth
dosimeter and hand press samples)

		b Kansas plot ID C2GIR takes into account both irrigated plots (cloth
dosimeter and hand press samples)

Application Regime:	Florida -		Broadcast applications were made to both
the non-irrigated and irrigated plots on November 16, 2004.

			Kansas -		Broadcast applications were made to both the non-irrigated
and irrigated plots used for both the cloth dosimeter and hand press
studies on July 22, 2004.

			California -	Broadcast applications were made to both the
non-irrigated and irrigated plots on August 17, 2004.

					

Application Equipment:	Florida -		Applications were made using a Lesco
drop spreader.

			Kansas -		Applications were made using a Lesco 36 inch drop spreader.

			California -	Applications were made using a Gandy 36 inch adjustable
drop spreader.

Spray Volume:				Not applicable because the test product was applied as
a dry granule. 

Equipment Calibration Procedures:		The Study Report made no mention of
calibrating the application equipment.

Was application “watered in”?  		The Florida and California test
sites had two established turf plots. The application was watered in for
one plot and not for the second plot. The Kansas test site had two plots
with which the application was watered in and two plots with which the
application was not watered in.

Was total deposition measured?  		No 

5.  Transferable Residue Sampling Procedures:

Method and Equipment:	TTR:  Cloth dosimeter samples were collected from
both the non-irrigated and irrigated plots using the modified California
Roller Technique, which has been approved by the Outdoor Residential
Exposure Task Force (ORETF).  This technique involves the use of a 32 lb
roller and a cloth dosimeter backed by a heavy gauge plastic sheet
inside a rigid frame.  Nails were used to secure the frame to the turf
at all four corners.  The cloth media used in the study was 100% cotton
sheeting (200 thread count). 

			Hand Press Samples:  At the Kansas site dry and moist hand press
samples were also collected from both the non-irrigated and irrigated
plots (these two plots were set aside for just hand press sample
collections).  Hands were moistened using a spray bottle application of
0.3 mL of water to the palm.  A template with seven square cutouts (7 cm
x 7 cm) was placed to make sure that each hand press was done in a new
location.  Gauze pads moistened with 5 mL of 0.01% Aerosol OT were used
to wipe the residues from both the dry hand press and moist hand press
palms after they were in contact with the treated turf.      

Sampling Procedure:	TTR:    SEQ CHAPTER \h \r 1 Cloth samples cut into
27 x 39 inch pieces backed with a similar sized piece of plastic and
clamped into a modified California roller frame.  The frame was placed
on a plot section to be sampled and held in place with nails in the
corners of the frame.  A 32 lb roller was then pushed back and forth
five times over the plastic backing.

			Hand Press Samples:  Ten volunteers were used to collect the hand
press samples. The volunteers thoroughly washed his/her hands with soap
and water followed by thorough towel and air-drying immediately prior to
collection of the hand press samples. One set of hand presses was dry
and the other set was water-moistened with approximately 0.3 mL of water
applied from a spray bottle immediately prior to sampling. Each hand was
placed in contact with the turf seven times with a pressure of
approximately 17 lb for approximately 6 seconds each time. Each of the
seven hand presses was done in a new location on the turf plot, using a
template with seven square cutouts (7 cm x 7 cm), so that undisturbed
treated turf was contacted each time. The hand press contact area was 49
cm2.  Once the hand press was complete, any debris or granules seen
adhering to the hands was carefully removed using tweezers or forceps.
The test palm was then wiped twice in succession, each time with one
package of two gauze pads moistened with 5 mL of 0.01% Aerosol OT
solution. The four gauze pads were combined as one sample. 

Surface area(s) sampled:	The area of the cloth dosimeters which came in
contact with the treated turf when placed in the sampling frame was 24.5
inches by 36 inches (5,690 cm2).

	The hand press contact area was 49 cm2, and the cumulative turf contact
area for the seven hand presses was 343 cm2.  The value of 49 cm2 was
used to normalize all results.

Replicates per surface:

-  Replicates per sampling time: 	Triplicate cloth dosimeter samples
were collected from each plot at each sampling interval.

				Ten dry and ten moist hand press samples were collected from each
plot at each sampling interval.

	-  Number of sampling times:	There were 8 cloth dosimeter sampling
intervals (7 sampling intervals occurred after the application) for each
plot (non-irrigated and irrigated). 

					There were three hand press sampling intervals for each type of
hand press (dry and moist) and each treated plot (non-irrigated and
irrigated).  Samples were collected at the Kansas site.  

Times of sampling after application: 	Cloth dosimeter sampling for the
non-irrigated plots occurred at the following sampling intervals:
pre-application (control samples), immediately after application
(0-time), and 4, 12, and 24 hours, and 2, 3, 5, and 7 days after
application.  Cloth dosimeter sampling intervals for the irrigated plots
occurred as follows: pre-application (control samples), as soon as the
turf surface was dry following post-application irrigation (0-time), and
4, 12, 24 hours and 2, 3, 5, and 7 days after application. No samples
were collected at the Kansas test site for the 48-hour sampling interval
due to inclement weather.

					Dry and moist hand press samples were collected from the
non-irrigated and irrigated plots pre-application (control samples),
immediately after application (0-time) and 120 hours (5 days) after
application.

6.  Sample Handling:

After sampling, the cotton sheeting samples were shaken to remove any
pieces of grass or other debris and then folded so that the side exposed
to the turf during sampling was folded inward. The folded cotton samples
were then placed into two nestled ziplock bags. The labeled bags were
placed either into a cooler with dry ice for temporary storage or
directly transferred into a freezer. Each gauze pad sample for the hand
press samples was placed in a pre-labeled amber glass jar with a
Teflon-coated lid.  The lid was closed and sealed with electrical tape
and the sealed jar was immediately placed in a cooler with dry ice for
temporary storage. All of the samples (cloth dosimeters and gauze pads)
were stored frozen within 4 hours after collection and remained in
frozen storage until analyzed. The samples were shipped to Analytical
Bio-Chemistry Laboratories, Inc. (ABC Labs) in Columbia, MO to be
analyzed. The field portion of the study was conducted between July 22,
2004 and November 23, 2004.  All analyses were conducted at ABC Labs
between November 17, 2004 and January 19, 2005.



7.  Analytical Methodology:

Extraction method:	Residues of carbaryl were extracted from cloth
samples by shaking the dosimeter in a one-gallon glass jar with 1000 mL
of acetonitrile or in later extraction sets a 10% methanol / 90%
acetonitrile extraction solvent was used.  Following 30 minutes of
shaking, a 250 mL aliquot was removed and transferred to a flat bottom
flask where the extraction solvent was evaporated to dryness using a
warm water bath set at 35 to 40 oC.  The residue was reconstituted using
a 60% methanol / 40% water solution with 2 mL/L of 10% phosphoric acid
added.  Carbaryl was quantitated by high-performance liquid
chromatography (HPLC) analysis with post-column hydrolysis and
fluorescence detection. 

			Residues of carbaryl were extracted from hand wipe (gauze pads) by
shaking twice with 100 mL of acetone.  The extracts were combined after
passing through a funnel of sodium sulfate.  The acetone extract was
evaporated to dryness using rotary evaporation on a warm water bath set
at 30 to 35 oC.  The final extract was reconstituted in methanol with
sonication and swirling.  Sufficient water was added to the methanolic
solution to yield a solution that was 60% methanol and 40% water. 
Carbaryl was quantitated by high-performance liquid chromatography
(HPLC) analysis with post-column hydrolysis and fluorescence detection. 

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Phenomenex Luna 3 μ Phenyl Hexyl   100 x 4.6 mm (hand wipes)

Column Temperature	40oC

Mobile Phase	60% MeOH / 40% Water

Start Time: 0.01 min

Stop Time: 12 min 

Flow Rate	1 mL/min

Injection Volume	70 L

Post Column Reaction System	Pump: Shimadzu SPD-6A

Flow Rate: 0.1 mL/min

Solution: 0.5 N NaOH

Column Heater: Timberline HPLC Column Oven

Temperature: 100 oC

Fluorescence Detector	Shimadzu RF-10AXL

Ex λ = 330 nm         Em λ = 465



Method validation:	The method for determining carbaryl residue on the
cloth dosimeters was validated by measuring the carbaryl residue
recoveries from control samples fortified in the laboratory with 1 μg,
5 μg, and 50 μg carbaryl using 100% acetonitrile as the extraction
solvent.  The carbaryl recoveries with this extraction solvent ranged
from 72.4% to 85.6% with an overall average recovery of 80.8% ± 3.30%. 
Additional cloth dosimeter control samples were fortified in the
laboratory with 1 μg, 50 μg, 500 μg, and 6,500 μg carbaryl using 10%
methanol / 90% acetonitrile as the extraction solvent.   Carbaryl
recoveries with this extraction solvent ranged from 75.8% to 109% with
an overall average recovery of 90.7% ± 7.77%. 

recoveries from control samples fortified in the laboratory with 0.1
μg, 5 μg, and 50 μg carbaryl. Carbaryl recoveries the hand press
samples ranged from 83.0% to 103% with an overall average recovery of
90.0% ± 5.85%. 

Instrument performance and calibration:	Six calibration standards
ranging from 0.01 g/mL to 0.50 g/mL were used to generate a
calibration curve for the cloth dosimeters and the hand press samples. 
The correlation coefficients were greater than 0.999 for both the cloth
dosimeter and hand wipe samples.

g/sample (0.00018 g/cm2).  The limit of quantitation (LOQ) for
carbaryl extracted from hand press samples (gauze pads) was 0.10
g/sample (0.00204 g/cm2). The limit of detection (LOD) values for
carbaryl residues in cloth dosimeters and hand wipes were 0.106 g
(0.00002 g/cm2) and 0.007 g (0.00014 g/cm2), respectively.

8.  Quality Control:	

Lab Recovery:	Laboratory fortification samples for both the cloth
dosimeters and hand press samples were measured during sample analysis
to verify method performance. In the first set of cloth dosimeters one
dosimeter was fortified in the laboratory with 1 g and a second cloth
dosimeter was fortified with 50 g using 100% ACN as the solvent.
Another set of cloth dosimeters were fortified in the laboratory with 1
g, 5 g, 50 g and 500 g carbaryl in a 10% MeOH/ACN solution.
Laboratory recovery values for the cloth dosimeters ranged from 72.1% to
105%. The overall mean recovery for the 10% MeOH/ACN fortification
solution was 87.4% ± 8.99% (n=15). The hand press samples were
fortified in the laboratory with 0.1 g, 5 g and 50 g carbaryl.
Laboratory recovery values for the moist hand press samples ranged from
80.9% to 97.4%.  The overall mean recovery was 88.0% ± 7.32% (n=6).
Laboratory recovery values for the dry hand press samples ranged from
88.8% to 107%.  The overall mean recovery was 96.3% ± 6.23% (n=6).
There were no residues above the LOQ (0.00204 g/cm2) in the
laboratory control samples.  A summary of the data is provided in Table
4.

Table 4.  Summary of Concurrent Laboratory Recoveries

Matrix	Fortification Level                (μg)	Avg Recovery

(%) 	Overall Avg      (%)	Std. Dev.	n

Cloth Dosimeters (100% ACN)	1.00	77.7a	74.9	NA	2

	50.0	72.1 a



	Cloth Dosimeters (10% MeOH/ACN)	1.00	84.1	87.4	8.99	15

	50.0	90.2



	Hand Wipes 

(moist)	0.100	88.1	88.0	7.32	6

	5.00	90.2





50.0	85.7



	Hand Wipes 

(dry)	0.100	100	96.3	6.23	6

	5.00	92.9





50.0	95.4



				a   Only one fortified sample was prepared at each level.

Cloth dosimeter control interferences ranged from less than the limit of
quantitation (1.0 μg/sample) to 1.86 μg/sample.  Hand wipe control
interferences ranged from less than the LOQ to 0.382 μg/sample. 

  

Field recovery:	Each trial included cloth dosimeter field fortification
samples prepared at two concentrations (5 g/sample and 500
g/sample).  The field fortified samples were prepared from control
cloth samples that were in contact with the plot prior to the day of
application.  Field fortification recoveries extracted using 100%
acetonitrile (4 KS samples) fortified at 5 g and 500 g ranged from
41% to 42% with an overall average percent recovery of 42% ± 0.7%. 
Field fortification recoveries extracted using 9:1 acetonitrile/methanol
(10% MeOH/ACN) fortified at 5 g and 500 g ranged from 40% to 103%
with an overall average percent recovery of 79% ± 17.7%.  The generally
accepted recovery range is 70 to 120% with a standard deviation of less
than 30%.  

The Kansas trial included hand press field fortification samples
prepared at two concentrations (5 g /sample and 50.0 g /sample). 
Hand press field fortification recoveries ranged from 73.0% to 104% with
an overall average percent recovery of 93.7% + 11.5%.

The Registrant corrected the field fortification recoveries for control
interferences.  At least one field fortification sample was extracted
with each analytical set to allow correction for field recovery.  Table
5 provides the average recoveries and standard deviation for each field
site.  

Table 5.  Summary of Cloth Dosimeter (TTR) Field Fortification
Recoveries

Concentration (μg)	Average Percent Recovery

(%)	Overall Average Percent Recovery 

(%)	Std. Dev.	(n)

FL	10% MeOH/ACN	5	90.0	91.9	7.27	12



500	93.8



	KS	100% ACN	5	41.5	43.7	2.54	4



500	45.9



	KS	10% MeOH/ACN	5	74.5	69.7	8.78	6



500	64.9



	CA	10% MeOH/ACN	5	67.1	70.8	15.8	12



500	74.6



	

Formulation:	The test product used in this study was a wettable granular
product containing 2.0% active ingredient (ai) carbaryl.  According to
the GLP analysis, the test product contained between 1.91% and 2.11%
(w/w) active ingredient.  The Analytical Report stated that the
analytical standard of carbaryl had a purity of 99.8% (expires
11/13/06).

Tank mix:	Not applicable

Travel Recovery:	Travel recovery was not discussed in the Study Report.

Storage Stability:	The field fortification samples were used to
determine the stability of carbaryl in the cloth dosimeter and hand
press sample in frozen storage.  According to the Study Report, since
the field fortification samples were maintained under the same
conditions as samples collected from the field sites, no additional
storage stability data was required. 

Cloth dosimeter field samples from Florida were stored from 52 to 58
days prior to extraction for analysis.  Field fortification samples from
Florida were extracted 58 to 60 days after fortification and had an
average recovery of 91.9% ( 7.27%.  Cloth dosimeter field samples from
Kansas were stored from 144 to 157 days prior to extraction for
analysis.  Field fortification samples from Kansas were extracted 145 to
161 days after fortification and had an average recovery of 59.3% ( 15%
(average includes 100% ACN and 10% MeOH/ACN results).  Cloth dosimeter
field samples from California were stored from 136 to 140 days prior to
extraction for analysis.  Field fortification samples from California
were extracted 140 to 144 days after fortification and had an average
recovery of 70.8% ( 15%.  A summary of the results is presented in Table
5 above. According to the Study Report, the residues for this study were
considered stable for the duration of the study.

Hand press field samples from Kansas were stored from 119 to 130 days
prior to extraction for analysis.  Field fortification samples from
Kansas were extracted 124 to 132 days after fortification and had an
average recovery of 93.7% + 11.5%. 

II.   RESULTS AND CALCULATIONS:

g/cm2.  The Registrant did not conduct a regression analysis.  

The TTR levels and corresponding statistical summaries are shown in
Tables 6 through 11 and in Figures 1 through 3. At the Florida site, the
average TTRs from the non-irrigated plot immediately following the
application were 0.5477 g/cm2 (maximum average), declined rapidly in
four hours to 0.0593 g/cm2, rose to 0.2668 g/cm2 by 12 hours and
declined steadily to 0.0009 g/cm2 by 5DAT before climbing up to
0.0023 g/cm2 by 7DAT.  The average residues from Florida site’s
irrigated plot approximately 2 hours following the application were
0.2878 g/cm2 (maximum average), declined rapidly to 0.0196 g/cm2
in 4 hours, then rose and fell slightly before reaching an average
residue value of 0.0009 g/cm2 by 7DAT.  At the Kansas site, TTRs from
the first three post-application sampling intervals from the
non-irrigated plot and the samples from the first two post-application
sampling intervals from the irrigated plot were extracted using 100%
ACN.  All of the samples collected from the remaining sampling intervals
for both plots were extracted using 10% MeOH/ACN.  The 2DAT sampling
interval for both plots was cancelled due to rain.  The average TTRs
from the non-irrigated plot immediately following the application were
0.1662 g/cm2 (maximum average), declined to below the LOQ (0.00018
g/cm2) by 3DAT before increasing slightly to 0.0006 g/cm2 by 5DAT
and dropping to 0.0003 g/cm2 by 7DAT.  The average residues from the
Kansas site’s irrigated plot approximately 2 hours following the
application were 0.0476 g/cm2 and then declined steadily to 0.0003
g/cm2 by 5DAT before increasing slightly to 0.0007 g/cm2 by 7DAT. 
At the California site, the average TTRs taken from the non-irrigated
plot immediately following the application were 0.4503 g/cm2 (maximum
average), declined rapidly in 12 hours to 0.0140 g/cm2, rose to
0.0470 g/cm2 by 24 hours and then declined steadily to 0.0016
g/cm2 by 7DAT.  The average residues from California site’s
irrigated plot approximately 2 hours following the application were
0.0402 g/cm2 (maximum average), declined rapidly to 0.0029 g/cm2
in 12 hours, rose to 0.0246 g/cm2 by 24 hours and then declined
steadily to 0.0012 g/cm2 by 7DAT.  

The Registrant did not perform regression analysis with the data
presented in this Study Report. First-order dissipation kinetics were
assumed by Versar in generating dissipation curves. However, the results
did not fit the regression curve closely as exemplified with R2 values
ranging from 0.34 to 0.81.  Versar used the Registrant’s residue data
collected immediately after the application through the last day where
residues were detected (7DAT for all test sites).  For values <LOQ,
Versar used a value of ½ the LOQ.  Versar conducted a linear regression
analysis for each test plot (non-irrigated and irrigated) using the
natural logarithm of the individual TTR values from the cloth
dosimeters.  

Versar's estimated half-life values were 0.836 days (R2=0.81) for
carbaryl residues from the non-irrigated plot and 1.23 days (R2=0.61)
for carbaryl residues from the irrigated plot at the Florida site.  At
the Kansas site, the estimated half-life values were 0.764 days
(R2=0.68) for carbaryl residues from the non-irrigated plot and 1.35
days (R2=0.54) for carbaryl residues from the irrigated plot and 1.23
days (R2=0.62) for carbaryl residues from the non-irrigated plot and
2.40 days (R2=0.34) for carbaryl residues from the irrigated plot at the
California site.

Dry and moist hand press samples were collected at the Kansas site from
both non-irrigated and irrigated plots at two sampling intervals.  The
carbaryl residue levels and corresponding statistical summaries are
shown in Tables 12 through 15.  The average carbaryl residues for the
dry hand press samples from the non-irrigated plot immediately following
the application were 0.24 g/cm2 and dropped to below the LOQ (0.00204
g/cm2) by 5DAT.  The average carbaryl residues for the dry hand press
samples from the irrigated plot 2 hours after the application were 0.06
g/cm2 and dropped to below the LOQ by 5DAT.  The average carbaryl
residues for the moist hand press samples from the non-irrigated plot
immediately following the application were 0.58 g/cm2 and dropped to
below the LOQ (0.00204 g/cm2) by 5DAT.  The average carbaryl residues
for the moist hand press samples from the irrigated plot 2 hours after
the application were 0.08 g/cm2 and dropped to below the LOQ by 5DAT.
 At the first post application collection immediately after application,
the percent of the original applied carbaryl (i.e., 88 ug/cm2) which
transferred to hand presses from the irrigated plot ranged from 0.07% to
0.09% of the theoretical amount of residue available for dry and moist
hand wipes, respectively.  The percent of the original applied carbaryl
(i.e., 88 ug/cm2 ) which transferred to hand presses from the
non-irrigated plot ranged from 0.27% for dry hand presses to 0.66% for
moist hand presses.    



III   DISCUSSION

A.   LIMITATIONS OF THE STUDY:

This study met most of the Series 875, Group B:875.2100 Guidelines.  The
issues which were identified include: 

(1) 	At the Kansas and Florida sites, significant rainfall was noted
throughout the course of the study (i.e., 2.48” total in Florida and
3.46” in Kansas with 0.35" of rain falling on the day of application
Kansas -  but the Kansas rainfall did not impact residue levels until
the 24 hour sample), rain also prevented sampling at the 48 hour
interval;

(2) 	Field fortification recoveries extracted using 100% acetonitrile
ranged from 41% to 42% with an overall average percent recovery of 42%
± 0.7% while field fortification recoveries extracted using 10%
MeOH/ACN ranged from 40% to 103% with an overall average percent
recovery of 79% ± 17.7%.  Samples analyzed with 100 percent
acetonitrile have more uncertainty associated with them than do samples
analyzed with the methanol mixture.  The generally accepted recovery
range is 70 to 120% with a standard deviation of less than 30%;  

(3) 	Meteorological conditions including temperature, wind speed, daily
rainfall, and humidity were not provided for the duration of the study; 

(4) 	No mention was made of calibrating the application equipment; and

(5) 	Actual application rates for plots 2GIR and 2G at the Kansas test
site were 122% and 125% of the target application rate, respectively.

B.   CONCLUSIONS:

Turf transferable residues (TTRs) were initially lower (averaging 65%
lower) on irrigated plots than the corresponding non-irrigated plots. 
Measured carbaryl residues rapidly declined over the first 4 hours and
then levelled off or rose slightly after 12 hours  By the 24-hour
sampling interval, the residues declined to approximately 10% of the
corresponding 0-time residue value and then steadily dropped to below
1.0% of the corresponding 0-time residue values by 3 to 5DAT.  Percent
transferability was below 1 percent of the application rate at all
sites.

Similarly, the initial carbaryl residues from both the dry and moist
hand press samples were considerably lower in the hand press samples
collected from the irrigated plot compared to the hand press samples
collected from the non-irrigated plot.  For both non-irrigated and
irrigated plots, hand wipes from moist hand presses had approximately
twice the carbaryl residues as that from the corresponding dry hand
presses.  On the day of collection 0.35 inches of rain fell at the test
site but apparently after the Day 0 samples were collected.   All hand
press samples collected at the 5DAT sampling interval demonstrated
residues below the LOQ (0.00204 g/cm2).   Percent transferability was
below 1percent for all samples.

In general the study is acceptable for risk assessment purposes.  A
couple of potentially key issues, however, should be considered when
these results are used for assessment purposes.  The first is that a
significant amount of either natural rainfall or irrigation water
occurred at both the Kansas and Florida sites (3.46 and 2.48 inches of
rain and from 0.3 to ~0.5 inches of irrigation water).  Additionally,
field recovery values were low when 100 percent acetonitrile was used
for extraction purposes which was remedied later with the use of a
methanol/acetonitrile mixture.

Table 6. Carbaryl Residues from Cloth Dosimeters 

Florida - SEVIN 2G – Non-Irrigated Plot

Sampling Interval          (Days After Last Treatment)	Corrected Residue
 (g/cm2)	Arithmetic Mean

 (g/cm2)	Standard Deviation (g/cm2)	Coefficient of Variance

(%)	Geometric Mean (g/cm2)	% of Original Application Rate Transferred


0	0.3868	0.5477

	0.4711

	86.0

	0.4204

	0.62



0	0.1782





	0	1.0782





	0.167	0.0712	0.0593

	0.0147

	24.7

	0.0579

	0.07



0.167	0.0429





	0.167	0.0636





	0.5	0.2584	0.2668

	0.1029

	38.6

	0.2533

	0.30



0.5	0.1683





	0.5	0.3737





	1	0.0609	0.0728

	0.0304

	41.7

	0.0690

	0.08



1	0.0503





	1	0.1073





	2	0.0658	0.0816

	0.0499

	61.2

	0.0722

	0.09



2	0.0416





	2	0.1376





	3	0.0200	0.0191

	0.0009

	4.96

	0.0191

	0.02



3	0.0193





	3	0.0181





	5	0.0008	0.0009

	0.0001

	9.81

	0.0009

	0.001



5	0.0010





	5	0.0009





	7	0.0053	0.0023	0.0026	114	0.0013	0.003

7	0.0013





	7	0.0003





	

LOD =  0.00002 μg/cm2

LOQ = 0.00018 μg/cm2

Target Application Rate = 88 μg/cm2

Table 7. Carbaryl Residues from Cloth Dosimeters

Florida - SEVIN 2G – Irrigated Plot

Sampling Interval          (Days After Last Treatment)	Corrected Residue
 (g/cm2)	Arithmetic Mean

 (g/cm2)	Standard Deviation (g/cm2)	Coefficient of Variance

(%)	Geometric Mean (g/cm2))	% of Original Application Rate
Transferred

0.083	0.0361	0.2878

	0.3049

	105.9

	0.1655

	0.33



0.083	0.6269





	0.083	0.2005





	0.167	0.0252	0.0196

	0.0119

	60.5

	0.0161

	0.02



0.167	0.0277





	0.167	0.0060





	0.5	0.0181	0.0398

	0.0458

	114.8

	0.0247

	0.05



0.5	0.0924





	0.5	0.0090





	1	0.0064	0.0111

	0.0106

	94.9

	0.0082

	0.01



1	0.0232





	1	0.0038





	2	0.0219	0.0190

	0.0042

	22.2

	0.0187

	0.02



2	0.0210





	2	0.0142





	3	0.0234	0.0197

	0.0049

	24.9

	0.0192

	0.02



3	0.0141





	3	0.0215





	5	0.0034	0.0025

	0.0008

	34.1

	0.0024

	0.003



5	0.0019





	5	0.0020





	7	0.0005	0.0009	0.0008	92.6	0.0007	0.001

7	0.0004





	7	0.0018





	

LOD =  0.00002 μg/cm2

LOQ = 0.00018 μg/cm2

	    Target Application Rate = 88 μg/cm2

Table 8. Carbaryl Residues from Cloth Dosimeters

Kansas - SEVIN 2G – Non-Irrigated Plot

Sampling Interval          (Days After Last Treatment)	Corrected Residue
 (g/cm2)	Arithmetic Mean

 (g/cm2)	Standard Deviation (g/cm2)	Coefficient of Variance

(%)	Geometric Mean (g/cm2)	% of Original Application Rate Transferred

0	0.1727	0.1662

	0.0339

	20.4

	0.1638

	0.1889



0	0.1295





	0	0.1964





	0.167	0.0474	0.0621

	0.0240

	38.5

	0.0594

	0.0706



0.167	0.0493





	0.167	0.0898





	0.5	0.0432	0.0495

	0.0097

	19.7

	0.0489

	0.0563



0.5	0.0447





	0.5	0.0607





	1	0.0131	0.0085	0.0040	46.2	0.0080	0.0097

1	0.0063





	1	0.0063





	2	NS	NS	NA	NA	NS	NS

2	NS





	2	NS





	3	<LOQ	<LOQ	NA	NA	NA	NA

3	<LOQ





	3	<LOQ





	5	0.0004	0.0006

	0.0003

	42.6

	0.0006

	0.0007



5	0.0006





	5	0.0009





	7	0.0004	0.0003	0.0001	41.9	0.0003	0.0003

7	0.0002





	7	0.0002





	

LOD =  0.00002 μg/cm2

LOQ = 0.00018 μg/cm2

Samples from sampling intervals 0 thru 12 hours were extracted with 100%
ACN. All other samples were extracted with 10% MeOH/ACN.

NS = Not Sampled (2DAT sampling interval was cancelled due to rain)

NA = Not Applicable

	    Target Application Rate = 88 μg/cm2

Table 9. Carbaryl Residues from Cloth Dosimeters 

Kansas - SEVIN 2G – Irrigated Plot

Sampling Interval          (Days After Last Treatment)	Corrected Residue
 (g/cm2)	Arithmetic Mean

 (g/cm2)	Standard Deviation (g/cm2)	Coefficient of Variance

(%)	Geometric Mean (g/cm2)	% of Original Application Rate Transferred

0.083	0.0391	0.0476

	0.0246

	51.7

	0.0437

	0.0541



0.083	0.0753





	0.083	0.0283





	0.167	0.0065	0.0059

	0.0018

	30.1

	0.0057

	0.0067



0.167	0.0073





	0.167	0.0039





	0.5	0.0051	0.0035

	0.0014

	40.3

	0.0033

	0.0040



0.5	0.0026





	0.5	0.0028





	1	0.0034	0.0038	0.0022	57.6	0.0034	0.0044

1	0.0019





	1	0.0062





	2	NS	NS	NA	NA	NS	NS

2	NS





	2	NS





	3	0.0006	0.0004

	0.0003

	72.9

	0.0003

	0.0004



3	0.0004





	3	<LOQ





	5	0.0003	0.0003

	0.0000

	8.30

	0.0003

	0.0004



5	0.0003





	5	0.0003





	7	0.0005	0.0007	0.0005	69.9	0.0006	0.0008

7	0.0004





	7	0.0013





	

LOD = 0.00002 μg/cm2

LOQ = 0.00018 μg/cm2

Samples from sampling intervals 2 hours and 4 hours were extracted with
100% ACN. All other samples were extracted with 10% MeOH/ACN.

NS = Not Sampled (2DAT sampling interval was cancelled due to rain)

NA = Not Applicable

Residues <LOQ were used as ½ LOQ for calculations

		Target Application Rate = 88 μg/cm2

	

Table 10. Carbaryl Residues from Cloth Dosimeters

California - SEVIN 2G – Non-Irrigated Plot

Sampling Interval          (Days After Last Treatment)	Corrected Residue
 (g/cm2)	Arithmetic Mean

 (g/cm2)	Standard Deviation (g/cm2)	Coefficient of Variance

(%)	Geometric Mean (g/cm2)	% of Original Application Rate Transferred

0	0.1680	0.4503

	0.2982

	66.2

	0.3777

	0.5117



0	0.7621





	0	0.4207





	0.167	0.0223	0.0251

	0.0085

	34.0

	0.0242

	0.0286



0.167	0.0347





	0.167	0.0184





	0.5	0.0109	0.0140

	0.0043

	30.5

	0.0136

	0.0159



0.5	0.0189





	0.5	0.0123





	1	0.0512	0.0470

	0.0357

	76.0

	0.0338

	0.0534



1	0.0804





	1	0.0094





	2	0.0082	0.0164

	0.0080

	48.4

	0.0150

	0.0187



2	0.0172





	2	0.0240





	3	0.0037	0.0035

	0.0002

	6.30

	0.0035

	0.0039



3	0.0034





	3	0.0033





	5	0.0044	0.0035

	0.0015

	42.4

	0.0032

	0.0040



5	0.0043





	5	0.0018





	7	0.0019	0.0016	0.0004	23.4	0.0016	0.0018

7	0.0016





	7	0.0012





	

LOD = 0.00002 μg/cm2

LOQ = 0.00018 μg/cm2

		Target Application Rate = 88 μg/cm2

Table 11. Carbaryl Residues from Cloth Dosimeters 

California - SEVIN 2G – Irrigated Plot

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fter Last Treatment)	Corrected Residue  (g/cm2)	Arithmetic Mean

 (g/cm2)	Standard Deviation (g/cm2)	Coefficient of Variance

(%)	Geometric Mean (g/cm2)	% of Original Application Rate Transferred

0.083	0.0414	0.0402

	0.0331

	82.4

	0.0269

	0.0456



0.083	0.0727





	0.083	0.0065





	0.167	0.0122	0.0079

	0.0050

	63.4

	0.0064

	0.0090



0.167	0.0091





	0.167	0.0024





	0.5	0.0026	0.0029

	0.0005

	18.5

	0.0028

	0.0033



0.5	0.0025





	0.5	0.0035





	1	0.0249	0.0246

	0.0128

	51.9

	0.0222

	0.0280



1	0.0373





	1	0.0117





	2	0.0214	0.0171

	0.0039

	23.0

	0.0168

	0.0194



2	0.0137





	2	0.0161





	3	0.0035	0.0103

	0.0080

	77.8

	0.0082

	0.0117



3	0.0084





	3	0.0192





	5	0.0026	0.0040

	0.0012

	30.2

	0.0038

	0.0045



5	0.0047





	5	0.0046





	7	0.0016	0.0012	0.0003	28.6	0.0012	0.0014

7	0.0009





	7	0.0011





	

LOD = 0.00002 μg/cm2

LOQ = 0.00018 μg/cm2

		Target Application Rate = 88 μg/cm2

Table 12.  Carbaryl Residues from Dry Hand Press Samples

Kansas - SEVIN 2G – Non-Irrigated Plot

Sampling Interval          (Days After Last Treatment)	Measured Residue 

(μg /sample)	Corrected Residue 

(μg /sample)	Corrected Residue  (μg/cm2)	Arithmetic Mean (μg/cm2)
Standard Deviation (μg/cm2)	Coefficient of Variance (%)	Geomean
(μg/cm2)	% of original application rate transferred

0	7.40	7.40	0.1510	0.2419	0.1174	48.6	0.2180	0.27

0	6.67	6.67	0.1361





	0	18.2	18.2	0.3714





	0	8.95	8.95	0.1827





	0	6.77	6.77	0.1382





	0	21.7	21.7	0.4429





	0	11.3	11.3	0.2306





	0	13.0	13.0	0.2653





	0	18.5	18.5	0.3776





	0	6.02	6.02	0.1229





	5	<LOQ	<LOQ	<LOQ	NA	NA	NA	NA	NA

5	<LOQ	<LOQ	<LOQ





	5	<LOD	<LOD	<LOD





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	

LOD = 0.00014 μg/cm2

LOQ = 0.00204 μg/cm2

Surface area of palm (cm2 /sample) = 49cm2

Target Application rate = 88 μg/cm2

Table 13.  Carbaryl Residues from Dry Hand Press Samples

Kansas - SEVIN 2G – Irrigated Plot

Sampling Interval          (Days After Last Treatment)	Measured Residue 

(μg /sample)	Corrected Residue 

(μg /sample)	Corrected Residue  (μg/cm2)	Arithmetic Mean (μg/cm2)
Standard Deviation (μg/cm2)	Coefficient of Variance (%)	Geomean
(μg/cm2)	% of original application rate transferred

0.0833	6.06	6.06	0.1237	0.0573	0.0615	107.2	0.0209	0.07

0.0833	0.1250	0.1276	0.0026





	0.0833	0.2700	0.2755	0.0056





	0.0833	0.3450	0.3520	0.0072





	0.0833	0.8250	0.8418	0.0172





	0.0833	<LOQ	NA	0.0010 a





	0.0833	1.69	1.72	0.0352





	0.0833	6.09	6.09	0.1243





	0.0833	4.90	4.90	0.1000





	0.0833	7.67	7.67	0.1565





	5	<LOQ	<LOQ	<LOQ	NA	NA	NA	NA	NA

5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	

a     value was <LOQ (0.1 μg/sample) therefore, ½ LOQ was used in
calculations

LOD = 0.00014 μg/cm2

LOQ = 0.00204 μg/cm2

Surface area of palm (cm2 /sample) = 49cm2

Target Application rate = 88 μg/cm2

Table 14.  Carbaryl Residues from Moist Hand Press Samples

Kansas - SEVIN 2G – Non-Irrigated Plot

Sampling Interval          (Days After Last Treatment)	Measured Residue 

(μg /sample)	Corrected Residue 

μg/cm2

LOQ = 0.00204 μg/cm2

Surface area of palm (cm2 /sample) = 49cm2

Target Application rate = 88 μg/cm2

Table 15.  Carbaryl Residues from Moist Hand Press Samples

Kansas - SEVIN 2G – Irrigated Plot

Sampling Interval          (Days After Last Treatment)	Measured Residue 

(μg /sample)	Corrected Residue 

(μg /sample)	Corrected Residue  (μg/cm2)	Arithmetic Mean (μg/cm2)
Standard Deviation (μg/cm2)	Coefficient of Variance (%)	Geomean
(μg/cm2)	% of original application rate transferred 

0.0833	9.32	12.8	0.2606	0.0833	0.0978	117.4	0.0408	0.09

0.0833	0.4280	0.5632	0.0115





	0.0833	0.4020	0.5289	0.0108





	0.0833	1.43	1.88	0.0384





	0.0833	1.80	2.37	0.0483





	0.0833	0.3750	0.4934	0.0101





	0.0833	0.4380	0.5763	0.0118





	0.0833	5.45	7.47	0.1524





	0.0833	8.59	11.8	0.2401





	0.0833	1.83	2.41	0.0491





	5	<LOQ	<LOQ	<LOQ	NA	NA	NA	NA	NA

5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	5	<LOQ	<LOQ	<LOQ





	

LOD = 0.00014 μg/cm2

LOQ = 0.00204 μg/cm2 or 0.10 μg

Surface area of palm (cm2 /sample) = 49cm2

Target Application rate = 88 μg/cm2



Figure 1. Carbaryl Residues on Cloth Dosimeters from Non-irrigated Plots



Figure 2. Carbaryl Residues on Cloth Dosimeters from Irrigated Plots



APPENDIX A

Compliance Checklist for “Transferable 

Residues of Carbaryl on Turf”

Compliance Checklist

Compliance with OPPTS Series 875, Occupational and Residential Exposure
Test Guidelines, Group B: Post-application Exposure Monitoring Test
Guidelines, 875.2100, Transferable Residue Dissipation, Lawn and Turf,
is critical.  The itemized checklist below describes compliance with the
major technical aspects of OPPTS 875.2100. 

	

	The test substance must be the typical end use product of the active
ingredient.  This criterion was met. 

	The production of metabolites, breakdown products, or the presence
of contaminants of potential toxicologic concern, should be considered
on a case-by-case basis.  It is not certain if this criterion was met. 
The study did not discuss metabolites or breakdown products of carbaryl.


	Applications should occur at the time of season that the end-use
product is normally applied to achieve intended pest control.  This
criterion was met.  

	Initiating testing immediately before a precipitation event should
be avoided.  Applications should be made after mowing and watering. 
These criteria were met except for the Kansas site. Rainfall occurred
within 24 hours of the application at the Kansas site and impacted the
24 hour samples but not earlier time periods.  All of the applications
took place after mowing. 

	The end use product should be applied by the application method
recommended.  Formulations which can be applied in a minimal amount of
water and do not require "watering in" should be used.  Information that
verifies that the application equipment (e.g., sprayer) was properly
calibrated should be included.  These criteria were mostly met. The test
product was applied to two test plots at each test location.  The test
product application for one plot was “watered in” and the second
plot was not irrigated.  There was no mention in the Study Report about
calibrating the drop spreader.

	The application rate used in the study should be provided and should
be the maximum rate specified on the label.  However, monitoring
following application at a typical application rate is more appropriate
in certain cases. It is not certain if this criterion was met.  A label
for the test product used in the study was not provided in the Study
Report. 

	If multiple applications are made, the minimum allowable interval
between applications should be used.  This criterion does not apply. 
Only one application was made for each test plot.

Opes) where the chemical is used.  This criterion was met.  TTR residue
data were collected from three geographically distinct locations
(Florida, Kansas, and California).  

	The site(s) treated should be representative of reasonable
worst-case climatic conditions expected in intended use areas. 
Meteorological conditions including temperature, wind speed, daily
rainfall, and humidity should be provided for the duration of the study.
These criteria were not met.  It is uncertain if the locations used were
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	Sampling should be sufficient to characterize the dissipation
mechanisms of the compound (e.g., three half-lives or 72 hours after
application, unless the compound has been found to fully dissipate in
less time; for more persistent pesticides, longer sampling periods may
be necessary). Sampling intervals may be relatively short in the
beginning and lengthen as the study progresses.  Background samples
should be collected before application of the test substance occurs. 
These criteria were met. 

	Triplicate, randomly collected samples should be collected at each
sampling interval.  This criterion was met.  Triplicate turf sample
replicates and 10 hand press samples were collected at each sampling
interval. 

	Samples should be collected using a suitable methodology (e.g.,
California Cloth Roller, Polyurethane Roller, Drag Sled, etc.) for turf.
 This criterion was met.  Turf residue samples were collected using the
modified California Cloth Roller methodology and hand press methodology.

	Control plots should be established from which sufficient control
samples can be collected.  Control sites should be upwind and a
reasonable distance from the treatment site.  These criteria were not
met. A separate control plot was not used at any of the test sites. 
Control samples were collected from each plot prior to the application. 

	Residues should be dislodged from turf within a reasonable time
period (i.e., EPA recommends that dislodging occur within 4 hours). 
Other transferable method samples should be handled in a manner that is
appropriate to the method used.  This criterion was met.  The modified
California cloth roller was used for the cloth dosimeters and a hand
press method was used for gauze pad samples.  Extraction of the residues
from the cloth sample occurred just prior to analysis of the samples.

tored in a manner that will minimize deterioration and loss of analytes
between collection and analysis.  Information on storage stability
should be provided.   This criterion was met. Results from the analyses
of the field fortification samples were used to verify the stability of
carbaryl residues on cloth dosimeters and hand press samples kept in
storage.

	Validated analytical methods of sufficient sensitivity are needed. 
Information on method efficiency (residue recovery), and limit of
quantitation (LOQ) should be provided.  These criteria were met.  The
analytical method was validated prior to the start of the study and
information on method efficiency was provided with the Study Report. 
The limits of quantitation (LOQ) for carbaryl residues on cotton percale
cloth and hand wipes were 1.0 g/sample and 0.10 g/sample,
respectively.

	Information on recovery samples must be included in the study
report.  A complete set of field recoveries should consist of at least
one blank control sample and three or more each of a low-level and
high-level fortification.  These fortifications should be in the range
of anticipated residue levels in the field study.  These criteria were
met.  

	Raw residue data must be corrected if appropriate recovery values
are less than 90 percent.  Distributional data should be reported, to
the extent possible.  This criterion was met. The Registrant corrected
all of the raw residue data for the corresponding field fortification
sample(s) analyzed with each set of field samples. 

	Residue data expressed as ug/cm2.  This criterion was met. 

  PAGE   1 

