	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF           

PREVENTION, PESTICIDES

AND TOXIC SUBSTANCES

MEMORANDUM  

Date:		June 23, 2003

Subject:	Occupational and Residential Exposure/Risk Assessment for Use
of BAS 510F on Potatoes, Bulb Vegetables, Lettuce, Dry/Succulent Beans,
Fruiting Vegetables, Stone Fruits, Small Berries, Tree Nuts, Pistachio,
Grapes, Strawberries, Peanuts, Canola, Brassica Leafy Vegetables,
Cucurbits, Edible Peas, Mint, Root Vegetables, Sunflower, and Golf
Course Turfgrass. 

PC Code: 128008        	DP Barcode: D290072

    To:		Maria Rodriguez

Registration Division/Fungicide Branch (7505C)

From:		Shih-Chi Wang, Biologist 

                        Margarita Collantes, Biologist

                        Gary Bangs, Industrial Hygienist

Health Effects Division/Registration Action Branch 2 (7509C)

Thru:		Richard Loranger, Branch Senior Scientist

Health Effects Division/Registration Action Branch 2 (7509C)

The enclosed document is an assessment of potential occupational and
residential exposures/ risk to support the proposed Section 3
registration for a new chemical, BAS 510F.  The proposed registration
includes fungicidal uses on the following crops: potatoes, bulb
vegetables, lettuce, dry/succulent beans, fruiting vegetables, stone
fruits, small berries, tree nuts, pistachio, grapes, strawberries,
peanuts, canola, brassica leafy vegetables, cucurbits, edible peas,
mint, root vegetables, sunflower, and golf course turfgrass. 

	Table of Contents

 TOC \f 

1.0  Executive Summary	3

2.0  Hazard Information	4

Acute Toxicity of BAS 510F	4

Toxicological Endpoints Selected by the HIARC for BAS 510F	5

3.0  Product Use information/Application Timing	5

4.0  Non-Occupational Exposure 	6

5.0  Occupational Exposure	10

5.1 Handlers 	10

5.2 Post-Application 	16

 6.0  Appendix 	26

1.0  Executive Summary tc \l1 "1.0  Executive Summary 

This assessment addresses occupational/residential exposures and risk
for the use of a new fungicidal chemical, BAS 510F, on the following
crops:  potatoes, bulb vegetables, lettuce, dry/succulent beans,
fruiting vegetables, stone fruits, small berries, tree nuts, pistachio,
grapes, strawberries, peanuts, canola, brassica leafy vegetables,
cucurbits, edible peas, mint, root vegetables, sunflower, and golf
course turfgrass.

The number of exposure days per year was not provided.  Based on the
frequency of applications and application interval, EPA assumes that
both application handlers and post-application workers would be exposed
for less than 6 months per year (short- and intermediate-term
exposures).  Long-term exposure is not expected.

Since no chemical-specific data for assessing human exposures during
pesticide handling activities were submitted to the Agency in support of
the registration of BAS 510F, HED used surrogate data from the PHED
Version 1.1.  Defaults established by the HED Science Advisory Council
for Exposure were used for acres treated per day and body weight.  Four
chemical-specific dislodgeable foliar residue (DFR) and one turf
transferable residue (TTR) studies were submitted for the evaluation of
post-application exposures/risks. 

Toxicological endpoints from the Hazard Identification Assessment Review
Committee report (3/07/03) were used to assess dermal and inhalation
risks.  The oral NOAEL (21.8 mg/kg/day, all durations) is based on  the
liver/thyroid effects observed from the chronic toxicity rat,
carcinogenicity rat and 1-year dog studies.  The dermal and inhalation
absorption rates used were 15 and 100%.  Daily dermal and inhalation
doses were combined and then compared to the NOAEL to determine the
level of risks.  The target margin of exposure (MOE) is 100.  BAS 510F
is classified as “suggestive evidence of carcinogenicity, but not
sufficient to assess human carcinogenic potential”, and, therefore,
the human cancer risk was not evaluated.  

Occupational handler assessments were based primarily on surrogate unit
exposures from the PHED, as presented in the PHED Surrogate Exposure
Guide (8/98).  All MOEs for the handlers performing agricultural crop
uses were greater than the target of 100 at the baseline level (ranging
from 460 to 31,000).  All MOEs for the handlers performing golf course
turfgrass uses were also greater than the target of 100 at the baseline
level (ranging from 7,300 to 27,000).

The occupational post-application exposure/risk were calculated by
coupling crop specific DFR values with activity specific transfer
coefficient (Tc) values from the HED Science Advisory Council For
Exposure Policy Number 3.1.  Except for grapes with girdling, all
post-application MOEs were greater than the target MOE of 100.  The MOE
for grapes with girdling was 95 on the day of application.  Due to the
statistical uncertainty in estimating the MOE, 95 is considered
equivalent to the target of 100 for risk assessment in this case. 
Therefore, the WPS required 12 hour REI is appropriate for this
chemical.  However, HED does not concur with the proposed 4-hour REI
because the determination as to whether BAS 510F is or is not a dermal
sensitizer could not be made.   

The short-term residential dermal post-application exposure/risk for
golfing was calculated by coupling TTR values with activity specific Tc
values from the HED Science Advisory Council For Exposure Policy Number
3.1.  All MOEs for the residential dermal post-application exposure were
greater than the target MOE of 100. 

2.0  Hazard Information tc \l1 "2.0  Hazard Information 

On September 5, 2002 and January 23, 2003, the Health Effects Division
(HED) Hazard Identification Assessment Review Committee (HIARC) selected
endpoints for chronic dietary exposure (all populations), incidental
oral short- and intermediate-term residential only, dermal (all
durations) and inhalation (all durations).  There was no appropriate
endpoint identified for acute dietary.  A dermal toxicity study was
submitted and no endpoint was selected at the limit dose (1000
mg/kg/day).  For all of the endpoints selected, liver and thyroid
effects were chosen from the chronic toxicity study in rats, the
carcinogenicity study in rats and the 1-year study in dogs.  The NOAEL
was 21.8 mg/kg/day.  For the dermal route, the absorption rate was 15%. 
For the inhalation route, the absorption rate was assumed to be 100%.   

The potential for increased susceptibility of infants and children from
exposure to BAS 510F was also evaluated as required by the Food Quality
Protection Act (FQPA) of 1996.  The special FQPA safety factor is
reduced to 1X because the existing data indicate that there are no/low
concerns and no residual uncertainties with regard to pre- and/or
postnatal toxicity.  The Cancer Assessment Review Committee (CARC)
classified BAS 510 F as, “suggestive evidence of carcinogenicity, but
not sufficient to assess human carcinogenic potential”, and,
therefore, the quantification of human cancer risk is not recommended. 

 The acute toxicity categories for the technical material are summarized
in Table 1.  The HIARC’s conclusions, the doses and toxicological
endpoints for various exposure scenarios are summarized and presented in
Table 2 (from the HIARC document on BAS 510F 03/07/03). 

Table 1.  Acute Toxicity Profile - BAS 510 F Technical.

Test Material	

GDLN

	

Study Type	

MRID	

Results	

Tox

Category



Technical

	

870.1100	

Acute Oral - rat	

45404814

	

LD50 > 5000 mg/kg

	

IV





Technical	

870.1200	

Acute Dermal - rat	

45404815	

LD50 > 2000 mg/kg	

III



Technical	

870.1300	

Acute Inhalation	

45404816	

LC50 (M & F): > 6.7 mg/L	

IV



Technical	

870.2400	

Primary Eye Irritation	

45404817	

Not irritating to the eye	

IV



Technical

	

870.2500	

Primary Dermal Irritation	

45404818

	

Not irritating to the skin

	

IV



Technical

	

870.2600	

Dermal Sensitization	

45404819

	

Study unacceptable as challenge dose was inadequate

	

N/A



Table 2.  Summary of Toxicological Dose and Endpoints for BAS 510 F. 

Exposure

Scenario	

Dose Used in Risk Assessment, UF 	

Special FQPA SF and Level of Concern for Risk Assessment	

Study and Toxicological Effects



Acute Dietary

	

No appropriate endpoint identified	

NA	

NA



Chronic Dietary

(All populations)	

 NOAEL= 21.8

UF = 100

Chronic RfD = 0.218 mg/kg/day	

FQPA SF = 1

cPAD = 

chronic RfD

 FQPA SF

= 0.218 mg/kg/day	

Chronic rat, carcinogenicity rat and 1-year dog studies

LOAEL = 57-58 mg/kg/day based on liver and thyroid effects



Incidental Oral (Short and intermediate term residential only)

	

NOAEL= 21.8  mg/kg/day	

Residential LOC for MOE = 100

Occupational LOC for MOE = 100	

Chronic rat, carcinogenicity rat and 1-year dog studies

LOAEL = 57-58 mg/kg/day based on liver and thyroid effects



Dermal (All Durations)	

Oral study NOAEL=21.8 mg/kg/day

(dermal absorption rate = 15%)	

Residential LOC for MOE = 100

Occupational LOC for MOE = 100 	

Chronic rat, carcinogenicity rat and 1-year dog studies

LOAEL = 57-58 mg/kg/day based on liver and thyroid effects



Inhalation (All Durations)

	

Oral study NOAEL= 21.8 mg/kg/day

(inhalation absorption rate = 100%)	

Residential LOC for MOE = 100 

Occupational LOC for MOE = 100	

Chronic rat, carcinogenicity rat and 1-year dog studies

LOAEL = 57-58 mg/kg/day based on liver and thyroid effects 



Cancer (oral, dermal, inhalation)	

Classification: “Suggestive evidence of carcinogenicity, but not
sufficient to assess human carcinogenic potential.”

UF = uncertainty factor, FQPA SF = Special FQPA safety factor, NOAEL =
no observed adverse effect level, LOAEL = lowest observed adverse effect
level, PAD = population adjusted dose (a = acute, c = chronic) RfD =
reference dose, MOE = margin of exposure, LOC = level of concern, NA =
Not Applicable

For the purpose of conducting risk assessments for occupational workers,
dermal and inhalation exposures may be combined because the same studies
(with the same endpoints) were used for each route of exposure for each
of the respective exposure scenarios.

3.0  Product Use information/Application Timing tc \l1 "3.0  Product Use
information/Application Timing 

Proposed use patterns for BAS 510F are summarized in Table 3.

Table 2.  Proposed Use Patterns for BAS 510F.

Crop 

 	

Product, Formulation	

Treatment Type	

Applications Per Season 1	

Maximum Application Rate2

(lb ai/acre)	

PHI3 

(days)







Per Application	

Per Season

	

Carrots	

BAS 510 02F, water-dispersible granule 

	

ground,

or aerial

	

5	

0.20	

1.00	

0



Stone Fruits

	

5	

0.23	

1.15	

0



Tree Nuts

	

4



0.92	

14



Pistachio

	

4



0.92	

14



Canola

	

2	

0.26	

0.52	

21



Bulb

Vegetables

	

6	

0.30	

1.80	

7



Cucurbits



ground	

4



1.20	

0



Root Vegetables

	

3	

0.34	

1.02	

0



Small Berries



ground,

or aerial	

4	

0.35	

1.40	

0



Grapes

	

3



1.05	

14



Strawberries

	

5



1.75	

0



Brassica Leafy Vegetables



ground	

2	

        

        0.40	

0.80	

14



 Mint

	

4



1.60	

15



Sunflower

	

2



0.80	

21



Peanuts



ground,

or aerial	

3	

0.44	

1.32	

14



Potatoes

	

2



0.88	

30



Dry/Succulent Beans

	

2	

0.48	

0.96	

21/7



Lettuce

	

2



0.96	

14



Edible Peas



ground	

2	

0.50	

1.00	

21



Turfgrass

	

6



3.00	

NA4



 Fruiting Vegetables



ground,

or aerial	

2	

0.55	

1.10	

0

1 Maximum number of applications allowed on label.

2 Rate = Maximum application rates specified on proposed labels.

3 PHI = Pre-harvest Interval

4 NA= Not Applicable

4.0 Non-Occupational Exposure

In the process of joint review with Health Canada, potential
non-occupational exposure scenarios were identified for golfers and
persons harvesting fruit at "U-pick" farms and orchards.  Residues may
be contacted from treated golf course turf or while picking
strawberries, caneberries, and tree fruit.  Based on low vapor pressure,
outdoor uses and the weight of evidence from many residue studies, no
post-application inhalation exposures are anticipated for BAS-510F. 
Because “U-pick” is a “one-time” event (duration<1-day) and the
HIARC found that the oral studies used to select endpoints were not
appropriate to quantitate acute risk, “U-pick” exposure/risk was not
evaluated.  Therefore, only the golfing scenario is evaluated in this
assessment with respect to non-occupational exposures.

4.1	Non-Occupational Handler tc \l2 "4.1	Non-Occupational Handler 

The BAS 510 02F label specifies that this product is intended for golf
course use only, and not for use on residential turfgrass or turfgrass
being grown for sale or other commercial use such as sod production. 
Although the label does not indicate that the product is applied by
licensed or commercial applicators, it is acknowledged that the
homeowner will not be applying the product to golf courses and
therefore, a risk assessment for handler exposure is not required.   BAS
510F is not packaged or marketed for home orchard use, and therefore
that use is not assessed.  Specific label language could be added to
exclude this use.

4.2	Non-Occupational Post-application	

The Agency uses the term “post-application” to describe exposures to
individuals that occur as a result of being in an environment that has
been previously treated with a pesticide.  It has been determined that
there is a potential for exposure from entering areas previously treated
with BAS 510F.  As indicated previously, there is only one potential
non-occupational post-application scenario associated with BAS 510F:
adults golfing (Table 4).  Duration of such exposure is anticipated to
be short-term.

Table 4: Non-Occupational Post-application Exposure Scenario for BAS
510F



Scenario, Product,

Formulation	

Method of Application	

Use Sites	

Application Rate



BAS 510 02F Turf Fungicide, EPA Reg No. 7969-Pending	

ground equipment only	

golf course use only	

0.5 lb ai/A

 	

4.2.1   Dermal Post-application Exposure tc \l3 "   Dermal
Post-application Exposure 

Turf Transferable Residue Data:

The Registrant, BASF Corporation submitted a turf transferable residue
(TTR) study using BAS 510F in support of this registration action.  The
Health Canada Pest Management Regulatory Agency (PMRA) performed primary
review on the study and HED performed secondary review.  HED concurred
with the TTR study review done by PMRA.  A summary of the study is
provided below.

BAS 510F UCF Turf Transferable Residue Study, D.W. Haughey and J. E.
Jones III, March 21, 2001, MRID# 45405301

The TTR study was designed to collect data to calculate dislodgeable
residue dissipation curves for BAS 510 F after application to turf at
three sites in the United States: Pennsylvania, Georgia and California. 
At each site, BAS 510 F was applied 3 times at a rate of 0.35 lb ai/A,
with a target spray interval of 14 days (± 1).  The interval between
the 2nd and 3rd applications at the Pennsylvania site was 24 days due to
rain and adverse weather conditions.  Dislodgeable residues were sampled
from turf using the modified California Roller Technique.  Cloth samples
were collected in triplicate from the treated plot before and after each
application, and at 1, 2, 3, 4, 7, 10, 14, 21, 28 and 35 (± 1) days
after the last application (DALA).  An additional sample was collected
at 84, 92, and 78 DALA for Pennsylvania, Georgia and California,
respectively, however, they were never analyzed.  In addition, samples
collected pre- and post-application 1 and 2 were not analyzed.  A
control plot at each site was used to sample untreated turf for field
recovery.  Except for minor limitations, the study design was considered
acceptable for regulatory use.

After 3 applications of BAS 510F, residues reached a peak at day 0 in
Georgia/California and at day 2 in Pennsylvania.  For all three sites,
Pennsylvania had the highest peak residue value of 0.1313 µg/cm2 2
DALA.  The residues in California and Georgia were considerably lower,
with peak residue levels of 0.039 µg/cm2 and 0.0172 µg/cm2,
respectively.  Regression lines were plotted using the natural log (ln)
of the residue values vs the days after the final application.  R2
values were 0.8763, 0.9261 and 0.8634 and the residue half lives were
2.2 days, 2.2 days and 0.64 days at the Pennsylvania, Georgia and
California sites, respectively.  Although samples were collected and
analyzed up to 35 DALA (±1), dissipation occurred rapidly and values
were below the LOQ at all three locations before the last sampling time
point.  Residues reached the LOQ by day-14 in Pennsylvania, day-10 in
Georgia, and day-4 in California. 

Assumptions:

adult transfer coefficient is 500 cm2/hr (based on HED SOP 3.1)

duration of exposure is estimated to be 4 hours (assuming chemical is
used on all parts of a course [greens, tees and fairways] and an adult
plays 18 holes of golf)

Equations and Calculations:

PDRo = TTRo x CF1 x Tc x ET x % DA

where

PDRo	=	potential dose rate on day 0 (mg/day)

TTRo	=	turf transferable residue on day 0 (ug/cm2); note highest TTR
used, which may have occurred on day of application

CF1	=	unit conversion factor to convert ug units in the TTR to mg for
daily exposure (0.001 mg/ug)

Tc	=	transfer coefficient (500 cm2/hr)

ET	=	exposure time (4 hr/day)

%DA	=	percent dermal absorption (15%)

4.2.2   Oral Post-application Exposure/Risk

There is the potential for oral exposure due to hand-to-mouth transfer
of pesticide residues from picking your own fruit.  However, HED does
not have an applicable database for estimating consumption of U-Pick
fruits in the field or hand-to-mouth activity during fruit picking.  In
addition, as noted previously, HIARC did not select an acute dietary
endpoint that would be appropriate for this type of exposure. 

4.2.3   Post-application Exposure/Risk and Characterization

The non-occupational dermal post-application exposure/risk were
calculated by coupling turf specific TTR values with activity specific
transfer coefficient (Tc) values from the HED Science Advisory Council
For Exposure Policy Number 3.1: Agricultural Transfer Coefficients, Aug.
2000.    

The TTR study provided two residue values, both from Pennsylvania, which
were selected to estimate high end exposure from turf. The highest turf
average daily residue value (0.1313 ug/cm2) was collected from a
sampling site when the turf was wet, which is assumed to have resulted
in higher than normal transferable residues.  The other turf residue
value (0.048 ug/cm2) was collected when the turf was dry and resulted in
lower transferable residues.  It should be noted that the Tc used to
estimate dermal exposure to turf is based on samples collected on dry
surfaces.  However, golf courses are often automatically sprayed by
built in sprinkler systems in the morning.  Therefore, HED deemed it
appropriate to assess dermal exposure in both dry and wet conditions. 
The TTR values were normalized (adjusted) to the maximum label
application rate.	

Table 5 provides a summary of short-term dermal post-application
exposure and risk for golfing adults.  All MOEs were above the target
MOE of 100 and therefore did not exceed HED’s level of concern. 
Although specific MOEs were not calculated for youth playing golf, the
adult MOEs are considered representative since the body surface area to
weight ratios do not vary significantly between adolescents and adults.

	Table 5: Short-term Dermal  Post-application Exposure for Adults 



Scenario & Product	

DFR/TTR 1 (ug/cm2)	

CF1 (mg/ug)	

Tc (cm2/hr)	

ET (hr/day)	

% DA	

BW (kg)	

Daily Dose 2

(mg/kg/day)	

Dermal MOE 3



Golfing



BAS 510 02F Turf Fungicide

TTR Study MRID# 45405301	

0.069 a	

0.001

	

500	

4	

15	

70	

0.000295	

74000

	

0.188 b







0.0008	

27000

1a.  The highest daily average Transferable Turf Residue for dry turf
resulting from Pennsylvania TTR study data (Adjusted for difference in
application rate from 0.35 to 0.5 lb ai/A max rate)

1b.  The highest daily average Transferable Turf Residue for wet turf
resulting from Pennsylvania TTR study data (Adjusted for difference in
application rate from 0.35 to 0.5 lb ai/A max rate)

2.    DD (mg/kg/day)  = DFR x CF1 x Tc x ET x %DA/BW

3.    Dermal MOE = NOAEL (21.8 mg/kg/day)/ Daily Dose (mg/kg/day)

4.3	Spray Drift

Spray drift is always a potential source of exposure to residents nearby
to spraying operations.  This is particularly the case with aerial
application, but, to a lesser extent, could also be a potential source
of exposure from the ground application method employed for BAS 510F. 
The Agency has been working with the Spray Drift Task Force, EPA
Regional Offices and State Lead Agencies for pesticide regulation and
other parties to develop the best spray drift management practices.  The
Agency is now requiring interim mitigation measures for aerial
applications that must be placed on product labels/labeling.  The Agency
has completed its evaluation of the new data base submitted by the Spray
Drift Task Force, a membership of U.S. pesticide registrants, and is
developing a policy on how to appropriately apply the data and the
AgDRIFT computer model to its risk assessments for pesticides applied by
air, orchard airblast and ground hydraulic methods.  After the policy is
in place, the Agency may impose further refinements in spray drift
management practices to reduce off-target drift and risks associated
with aerial as well as other application types where appropriate.  

5.0   Occupational Exposure tc \l1 "5.0   Occupational Exposure 

5.1   Handlers  tc \l2 "5.1   Handlers  

Equations/Calculations

The following equations were used to calculate handler exposure and
risk:

Dermal Dose (mg/kg/day) 	=	Rate (lb ai/A) x UE (mg/lb ai) x DA x Acres
Treated (A/day)

BW (kg)

Inhalation Dose (mg/kg/day)	=	 Rate (lb ai/acre) x UE (mg/lb ai) x Acres
Treated (A/day)

        BW (kg)

Where:

Rate (Application Rate)		=	Maximum application rate on product label (lb
ai/acre)

UE (Unit Exposure)		=	Exposure value derived from August 1998 PHED
Surrogate Exposure Table (mg/lb ai handled)

DA (dermal absorption factor)	=	Factor to account for dermal absorption
(15%) when endpoint is selected from an oral study.

Acres Treated			=	Maximum number of acres treated per day (acres/day)

             BW				=	Body weight (kg)

Combined Daily Dose (mg/kg/day) 	=	Dermal Dose (mg/kg/day)+Inhalation
Dose (mg/kg/day)

MOE		=	NOAEL (21.8 mg/kg/day)               

                                    Combined Daily Dose (mg/kg/day)

Exposure Scenarios

There are 7 handler scenarios that are expected to result in the highest
exposure for the proposed uses:

Mixing/Loading Dry Flowable for Ground-boom Applications (Scenario 1)

Mixing/Loading Dry Flowable for Air Blast Applications (Scenario 2) 

Mixing/Loading Dry Flowable for Aerial Applications (Scenario 3)

Applying Sprays with Ground-boom Equipment (Scenario 4)

Applying Sprays with Air Blast Equipment (Scenario 5)

Applying Sprays with a Fixed Wing Aircraft (Scenario 6)

Flagging during Aerial Applications (Scenario 7)

Application Rate

The maximum application rates listed on the proposed labels provided by
the Registration Division were used for all exposure assessments.  The
maximum rates are 0.20 lb ai/A for carrots, 0.23 lb ai/A for stone
fruits/tree nuts/pistachio, 0.26 lb ai/A for canola, 0.30 lb ai/A for
bulb vegetables/cucurbits, 0.34 lb ai/A for root vegetables, 0.35 lb
ai/A for small berries/grapes/ strawberries, 0.40 lb ai/A for brassica
leafy vegetables/mint/sunflower, 0.44 lb ai/A for peanuts/potatoes, 0.48
lb ai/A for dry & succulent beans/lettuce, 0.50 lb ai/A for edible
peas/turfgrass, and 0.55 lb ai/A for fruiting vegetables.

Area or the Amount Treated

Based on HED’s Exposure Science Advisory Council Policy Number 9.1,
the following acres per day treated, or gallons of spray solution per
day treated were assumed:

1200 acres/day for applications on canola/sunflower using aerial
equipment & flagging;

350 acres/day for applications on other ag. crops using aerial equipment
& flagging;

200 acres/day for applications on canola/sunflower using ground-boom
equipment;

80 acres/day for applications on other ag. crops using ground-boom
equipment;

40 acres/day for applications on tree crops using air blast equipment;

40 acres/day for application on turfgrass using ground-boom equipment.

Body Weight									

The average body weight for general population (70 kg) was used for all
assessments.

Exposure Frequency

No data on the number of exposure days per year was provided   For this
risk assessment,  it was assumed that handlers would be exposed for less
than 6 months per year.  Long-term exposure is not expected.  

Unit Exposures

The unit exposures used for assessments to plant protection uses are
based on the PHED Version 1.1 as presented in the August 1998 PHED
Surrogate Exposure Guide.  PHED was designed by a task force of
representatives from the U.S. EPA, Health Canada, the California
Department of Pesticide Regulation, and member companies of the American
Crop Protection Association.  PHED is a software system consisting of
two parts–a database of measured exposure values for workers involved
in the handling of pesticides under actual field conditions and a set of
computer algorithms used to subset and statistically summarize the
selected data.  Currently, the database contains values for over 1,700
monitored individuals (i.e., replicates).

Users select criteria to subset the PHED database to reflect the
exposure scenario being evaluated.  The subsetting algorithms in PHED
are based on the central assumption that the magnitude of handler
exposures to pesticides is primarily a function of activity (e.g.,
mixing/loading, applying), formulation type (e.g., wettable powders,
granulars), application method (e.g., aerial, groundboom), and clothing
scenarios (e.g., gloves, double layer clothing).

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

There are three basic risk mitigation approaches considered appropriate
for controlling occupational exposures.  These include administrative
controls, the use of personal protective equipment or PPE, and the use
of engineering controls.  Occupational handler exposure assessments were
completed by HED using baseline, PPE, and engineering controls. [Note:
Administrative controls available generally involve altering application
rates for handler exposure scenarios.  These are typically not utilized
for completing handler exposure assessments.] The baseline clothing
level scenario for occupational exposure scenarios is generally an
individual wearing long pants, a long-sleeved shirt, no chemical
resistant gloves, and no respirator.  The first level of mitigation
generally applied is PPE.  As reflected in the calculations included
herein, PPE may involve the use of an additional layer of clothing,
chemical-resistant gloves, and a respirator.  The next level of
mitigation considered in the risk assessment process is the use of
appropriate engineering controls which, by design, attempt to eliminate
the possibility of human exposure.  Examples of commonly used
engineering controls include enclosed tractor cabs and cockpits, closed
mixing/loading/transfer systems, and water-soluble packets.

Handlers’ Exposure and Risk

All MOEs for the handlers performing agricultural crop uses were greater
than the target of 100 at the baseline level (ranging from 460 to
31,000).  All MOEs for the handlers performing golf course turfgrass
uses were also greater than the target of 100 at the baseline level
(ranging from 7,300 to 27,000).  Summaries of the risks for handlers are
presented in Table 6.  

The handler exposure estimates in this assessment are based on a central
tendency estimate of unit exposure and an upper-percentile assumptions
for the application rate and acres treated, and are assumed to be
representative of high-end exposures.  The uncertainties associated with
this assessment stem from the use of surrogate exposure data (e.g.,
differences in use scenario and data confidence), and assumptions
regarding that amount of chemical handled.  The estimated exposures are
believed to be reasonable high-end estimates based on observations from
field studies and professional judgement.

Table 6.  Non-Cancer Short- and Intermediate-Term Risk for BAS 510 F
Handlers.

Exposure Scenario (Scenario #)	

Mitigation Levela	

Dermal Unit Exposureb (mg/lb ai)	

Inhalation Unit Exposurec   (ug/lb ai)	

Crop	

Application Rate

(lb ai/A)	

Amount Treatedd

(A/day)	

Daily

Dermal

Dosee (mg/kg/day)	

Daily

Inhalation

Dosef (mg/kg/day)	

Combined

Daily Doseg (mg/kg/day)	

MOEh  



Mixer/Loader



Dry Flowables for Ground-boom application (1)	

Baseline	

0.066	

0.77	

Carrots	

0.20	

80	

0.0023	

0.0002	

0.0025	

8,700







Bulb Vegs,

Cucurbits	

0.30



0.0034	

0.0003	

0.0037	

5,900







Root Vegs	

0.34



0.0039	

0.0003	

0.0042	

5,200







Sm. Berries,

Grapes,

Strawberries	

0.35



0.0040	

0.0003	

0.0043	

5,100







Brassica Leafy Vegs.,

Mint	

0.40



0.0045	

0.0004	

0.0049	

4,500







Peanuts,

Potatoes	

0.44



0.0050	

0.0004	

0.0054	

4,000







Dry/Succul.

Beans,

Lettuce	

0.48



0.0054	

0.0004	

0.0058	

3,800







Edible Peas	

0.50



0.0057	

0.0004	

0.0061	

3,600







Turfgrass



40	

0.0028	

0.0002	

0.0030	

7,300







Fruit. Vegs	

0.55	

80	

0.0062	

0.0005	

0.0067	

3,300







Canola	

0.26	

200	

0.0074	

0.0006	

0.0080	

2,700







Sunflower	

0.40



0.0113	

0.0009	

0.0122	

1,800



Dry Flowables for 

Air Blast 

application (2)	

Baseline	

0.066	

0.77	

Stone Fruits,

Tree Nuts,

Pistachio	

0.23	

40	

0.0013	

0.0001	

0.0014	

15,600



Dry Flowables for Aerial application (3)	

Baseline

	

0.066	

0.77	

Carrots	

0.20	

350	

0.0099	

0.0008	

0.0107	

2,000







Stone Fruits,

Tree Nuts,

Pistachio	

0.23



0.0114	

0.0009	

0.0123	

1,800







Bulb Veg.	

0.30



0.0149	

0.0012	

0.0161	

1,400







Sm. Berries,

Grapes,

Strawberries	

0.35



0.0173	

0.0014	

0.0187	

1,200







Peanuts,

Potatoes	

0.44



0.0218	

0.0017	

0.0235	

930







Dry/Succul.

Beans,

Lettuce	

0.48



0.0238	

0.0019	

0.0257	

850







Fruit. Vegs	

0.55



0.0272	

0.0021	

0.0293	

740







Canola	

0.26	

1,200	

0.0441	

0.0034	

0.0475	

460



Applicator



Sprays with 

Ground-boom (4)

	

Baseline	

0.014	

0.74	

Carrots	

0.20	

80	

0.0005	

0.0002	

0.0007	

31,000







Bulb Vegs,

Cucurbits	

0.30



0.0007	

0.0003	

0.0010	

22,000







Root Vegs	

0.34



0.0008	

0.0003	

0.0011	

20,000







Sm. Berries,

Grapes,

Strawberries	

0.35



0.0008	

0.0003	

0.0011	

20,000







Brassica Leafy Vegs.,

Mint	

0.40



0.0010	

0.0003	

0.0013	

17,000







Peanuts,

Potatoes	

0.44



0.0011	

0.0004	

0.0015	

15,000







Dry/Succul.

Beans,

Lettuce	

0.48



0.0012	

0.0004	

0.0016	

14,000







Edible Peas	

0.50



0.0012	

0.0004	

0.0016	

14,000







Turfgrass



40	

0.0006	

0.0002	

0.0008	

27,000







Fruit. Vegs	

0.55	

80	

0.0013	

0.0005	

0.0018	

12,000







Canala	

0.26	

200	

0.0016	

0.0006	

0.0022	

9,900







Sunflower	

0.40



0.0024	

0.0008	

0.0032	

6,800



Sprays with 

Air Blast (5)	

Baseline	

0.36	

4.5	

Stone Fruits,

Tree Nuts,

Pistachio	

0.23	

40	

0.0071	

0.0006	

0.0077	

2,800



Sprays with fixed wing Aircraft (6)

	

Engineer. Control

	

0.0050

	

0.068

	

Carrots	

0.20	

350	

0.0008	

0.0001	

0.0009	

24,000







Stone Fruits,

Tree Nuts,

Pistachio	

0.23



0.0009	

0.0001	

0.0010	

21,800







Bulb Veg.	

0.30



0.0011	

0.0001	

0.0012	

18,000







Sm. Berries,

Grapes,

Strawberries	

0.35



0.0013	

0.0001	

0.0014	

16,000







Peanuts,

Potatoes	

0.44



0.0017	

0.0002	

0.0019	

12,000







Dry/Succul.

Beans,

Lettuce	

0.48



0.0018	

0.0002	

0.0020	

11,000







Fruit. Vegs	

0.55



0.0021	

0.0002	

0.0023	

9,500







Canola	

0.26	

1,200	

0.0033	

0.0003	

0.0036	

6,100



Flagger



Flagging for 

Aerial Application (7)

	

Baseline

	

0.011	

0.35	

Carrots	

0.20	

350

	

0.0017	

0.0004	

0.0021	

10,000







Stone Fruits,

Tree Nuts,

Pistachio	

0.23



0.0019	

0.0004	

0.0023	

9,500







Bulb Veg.	

0.30



0.0025	

0.0005	

0.0030	

7,300







Sm. Berries,

Grapes,

Strawberries	

0.35



0.0029	

0.0006	

0.0035	

6,200







Peanuts,

Potatoes	

0.44



0.0036	

0.0008	

0.0044	

5,000







Dry/Succul.

Beans,

Lettuce	

0.48



0.0040	

0.0008	

0.0048	

4,500







Fruit. Vegs	

0.55



0.0045	

0.0010	

0.0055	

4,000







Canola	

0.26	

1,200	

0.0074	

0.0016	

0.0090	

2,400



a	Baseline consists of long-sleeve shirt, long pants, shoes, and socks
and no respirator.  PPE consists of long-sleeve shirt, long pants,
shoes, socks, chemical-resistant gloves, and no respirator.

b	Baseline Dermal Unit Exposure represents long pants, long sleeved
shirt, no gloves, open mixing/loading, and open cab tractors, as
appropriate.  

c	Baseline Inhalation Exposure represents no respiratory protection,
open mixing/loading, and open cab tractors, as appropriate.  

d	Daily acres treated values are from EPA estimates of acreage that
could be treated or volume handled in a single day for each exposure
scenario of concern, based on the application method and
formulation/packaging type.

e	Daily dermal dose (mg/kg/d) =  [unit dermal exposure (mg/lb ai) *
dermal absorption (0.15) * application rate (lb ai/acre) * daily acres
treated /  body weight (70 kg).

f	Daily inhalation dose (mg/kg/d) = (unit exposure (µg/lb ai) *
(1mg/1000 µg) conversion * appl. rate (lb ai/acre) * daily acres
treated / body weight (70 kg).

g	Combined daily dose = daily dermal dose + daily inhalation dose.

h	MOE = NOAEL (21.8 mg/kg/d) / combined daily dose.  UF = 100.

5.2   Post-application  tc \l2 "5.2   Post-application  

It has been determined that there is a potential for occupational
exposure from entering areas previously treated with BAS 510 F.  Table 7
summarizes the post-application exposure scenarios associated with BAS
510F.  The residue transfer coefficients (TCs) used in this assessment
are from an interim TC policy developed by HED Science Advisory Council
(SAC) for Exposure using proprietary data from the Agricultural Re-entry
Task Force (ARTF) database (Exposure SAC Policy No. 3.1).  It is the
intention of HED Exposure SAC that this policy will be periodically
updated to incorporate additional information about agricultural
practices in crops and new data on transfer coefficients.  Much of this
information will originate from exposure studies currently being
conducted by the ARTF, from further analysis of studies already
submitted to the Agency, and from studies in the published scientific
literature.  Occupational post-application exposure is expected to be
short- and intermediate-term in duration.

5.2.1   Post-application Data, Assumptions and Calculations		

Dislodgeable Residue Data:

Four dislodgeable foliar residue (DFR) studies were submitted in support
of this registration action.  The Health Canada Pest Management
Regulatory Agency (PMRA) performed primary reviews on the studies and
HED performed secondary reviews.  HED concurred with the DFR study
reviews done by PMRA.  A summary of each study and the assumptions used
to estimate post-application exposure for these crops are provided
below.  The DFR values selected and dissipation rate calculations are
detailed in the appended REI estimation summaries.

BAS 510F UCF Dislodgeable Foliar Residue Study in Tomatoes, D.W. Haughey
and J. E. Jones III, March 9, 2001, MRID# 45405302

This study shows a dissipation curve for BAS 510F after application to
tomatoes at Pennsylvania/Georgia/California.  At each site, BAS 510F was
applied 2 times at 0.55 lba.i./A using ground boom with a 7-day interval
between applications.  Dislodgeable residues were sampled from the
leaves using a Birkestrand leaf puncher.  Each sample consisted of 40
leaf punches, and was taken in triplicate.  Samples were taken before
and after each application, and at 1, 3, 4, 7, 10, 14, 21, 28, and 35
days after the last application (DALA) at the Georgia/California sites. 
At the Pennsylvania site, samples were taken before and after each
application and at 1, 2, 3, 6, 9, 13, 20, 27 and 34 DALA.  Analyses were
not performed  for the samples taken before and after the first
application at the Georgia and California sites.  A control plot at each
site was used to sample untreated leaves for field recovery.  Except for
minor limitations, the study design was considered acceptable.

After 2 BAS 510F applications, the peak residue value was observed on
day 0, immediately after the final application at
Pennsylvania/California, and on day 3 post-application at Georgia. 
Residues did not reach the LOQ by 35 days post-application at
Pennsylvania or Georgia.  At the California site, values of two
replicates were below the LOQ on days 14, 28 and 35.  Peak values were
1.06 µg/cm2 in Pennsylvania, 0.71 µg/cm2 in Georgia, and 0.66 µg/cm2
in California.

California had the most rapid decline with rep. values below the LOQ by
day 14 followed by Pennsylvania/Georgia.  Precipitation records showed
that dry weather prevailed at California during the monitoring period
and the irrigation systems did not result in any foliar contact.  No
rationale or explanation was given in the study report for these
results. 

Regression lines were plotted using the natural log (ln) of the residue
values vs the days after the final application.  R2 values were 0.9149,
0.6585 and 0.7647 and the half life (t½) was 9.4 days at the
Pennsylvania site.  As R2 were low at the Georgia and California sites,
half lives could not be determined.

BAS 510F UCF Dislodge able Foliar Residue Study in Grapes, D.W. Haughey
and J. E. Jones III, March 16, 2001, MRID# 45405303

This study shows a dissipation curve for BAS 510F after application to
grape at Pennsylvania/California/Washington.  At each site, BAS 510F was
applied 3 times at 0.37 lba.i./A, with a 14-day interval between
applications.  Dislodgeable residues were sampled from the grape leaves
using a Birkestrand leaf puncher.  Each sample consisted of 40 leaf
punches, and was taken in triplicate.  Samples were taken before and
after each application, and as follows: at 1, 3, 4, 7, 11, 14, 21, 28,
35 and 89 days after the last application (DALA) in Pennsylvania; at 1,
3, 4, 7, 10, 14, 21, 28, 35 and 88 DALA in California; and at 1, 3, 4,
7, 10, 14, 21 and 28 DALA in Washington.  In Washington, an early season
killing frost prohibited sampling after the 28 DALA time point. 
Analyses were performed only for the samples taken prior to the last
application, and at the time intervals after the last application.  A
control plot at each site was used to sample untreated leaves for field
recovery.  Except for minor limitations, the study design was considered
acceptable.

After 3 applications of BAS 510 F, residues reached a peak on day 1 in
Pennsylvania and Washington.  Residues in California reached a peak 10
DALA.   Peak values were 0.72 µg/cm2 in Pennsylvania, 1.17 µg/cm2 in
California and 1.42 µg/cm2 in Washington.  Residues did not reach the
LOQ by 89, 88 and 28 days post-application at Pennsylvania, California
and Washington.  Residues declined to 0.26 µg/cm2 in Pennsylvania, 0.23
µg/cm2 in California, and 1.13 µg/cm2 in Washington.  Regression lines
were plotted using the natural log (ln) of the residue values vs the
days after the final application.  R2 values were all below 0.53, thus
residue half lives could not be determined. 

BAS 510F UCF Dislodge able Foliar Residue Study in Peaches, D.W. Haughey
and J. E. Jones III, January 5, 2001, MRID# 45405304

This study shows a dissipation curve for BAS 510F after application to
peach at California/Georgia/Pennsylvania.  At each site, BAS 510F was
applied 5 times at 0.23 lba.i./A using airblast with a 7-day interval
between applications.  Dislodgeable residues were sampled from the peach
tree leaves using a Birkestrand leaf puncher.  Each sample consisted of
40 leaf punches, and was taken in triplicate.  Samples were taken before
and after each application, and at 1, 2, 3, 4, 5, 7, 10, 14, 21, 28, and
35 days after the last application; however, analyses were not performed
for the samples taken before and after the first 4 applications.  A
control plot at each site was used to sample untreated leaves for field
recovery.  Except for minor limitations, the study design was considered
acceptable.

Peak residues were measured 2, 3 or 14 days after the last application. 
The highest peak residue was 1.3 µg/cm2 in Pennsylvania (day 3),
followed by 1.19 µg/cm2 in California (day 14), and 0.58 µg/cm2 in
Georgia (day 2).  A gradual decline in dislodgeable residues was
observed in California/Georgia/Pennsylvania after the peak value, with
residue values of 0.66, 0.21, and 0.26 µg/cm2 after 35 days,
respectively.  Regression lines were plotted using the natural log (ln)
of the residue values vs the days after the final application.  R2
values were 0.1417, 0.8312, and 0.8684 for
California/Georgia/Pennsylvania sites.  The half life (t½ ) was 14.5
days for Pennsylvania but could not be determined for California or
Georgia due to low R2 values.  The limitations of the study were not
significant enough to affect the overall outcome.

BAS 510F UCF Dislodge able Foliar Residue Study in Strawberries, D.W.
Haughey and J. E. Jones III, January 5, 2001, MRID# 45405305.

This study shows a dissipation curve for BAS510F after application to
strawberries at N. Carolina/California/Oregon.  At each site, BAS 510F
was applied 5 times at 0.37 lba.i./A using ground boom with a 7-day
interval between applications.  Dislodgeable residues were sampled from
the leaves using a Birkestrand leaf puncher.  Each sample consisted of
40 leaf punches, and was taken in triplicate.  Samples were taken before
and after each application, and at 1, 2, 3, 4, 5, 6, 7, 10, 14, 21, 28,
and 35 days after the last application; however, analyses were not
performed for the samples taken before and after the first 4
applications.  A control plot at each site was used to sample untreated
leaves for field recovery.  Except for minor limitations, the study
design was considered acceptable.

After 5 applications of BAS 510F, the peak residue value was observed on
day 0, immediately after the final application at N. Carolina/Oregon,
and on days 2 and 3 post-application at California.  Peak values were
1.63 µg/cm2 in N. Carolina, 1.83 µg/cm2 in California, and only 0.76
µg/cm2 in Oregon.  In N. Carolina, the peak value was followed by a
rapid decrease (from 1.63 µg/cm2 to 0.86  µg/cm2) on day 1.  Residues
did not reach the LOQ by 35 days post-application at any of the three
sites.  Regression lines were plotted using the natural log (ln) of the
residue values vs the days after the final application.  R2 values were
0.8958, 0.8434, and 0.8665 and half lives (t½) were 5.7 days, 21.9
days, and 8.7 days at N. Carolina/California/Oregon sites, respectively.




Table 7.  Anticipated Post-application Activities and Dermal Transfer
Coefficients for BAS 510 F



Proposed Crops	

Policy Crop Group Category	

Application Rate

 (lb ai/A)	

Exposure Potential	

Transfer Coefficients (cm2/hr)	

Activities	

Reference  



strawberry

	

low berries	

0.35	

low	

400	

hand weeding, harvesting and pruning, scouting, irrigation, mulching,
thinning	

DFR Strawberry Study MRID# 45405305



	

high	

1500	

hand harvesting, and pruning, pinching, and training

	

peas and beans (dry & succulent), canola, mint, peanuts	

field row low/medium	

0.48	

low	

100	

irrigation, scouting, thinning, hand weeding	

Central value from MRID 426891 - hoeing in cotton and beans 



	

medium	

1500	

irrigation, scouting, hand weeding,	

Central value from ARF021 - scouting dry peas



	

high	

2500	

hand harvesting	

high end value from ARF021 - scouting dry peas



Tall field row (sunflower seeds) crop	

field row

crop, tall	

0.40	

low	

400	

scouting	

low value from ARF009- scouting sweet corn



	

high	

1000	

 scouting	

central value from ARF009- scouting sweet corn



stone fruits (apricot, cherry, nectarine, peach, plum & prune)	

trees, fruit, deciduous	

0.23	

very low	

100	

propping	

Peach DFR Study (MRID#4540304)



	

low	

1000	

scouting, irrigation, hand weeding







high	

1500	

hand harvesting &pruning, propping, training, tying







very high	

3000	

thinning

	

Tree Nuts (almond, pecan, walnut, pistachio	

tree, nuts	

0.23	

low	

500	

scouting, thinning, irrigation, hand weeding	

Peach DFR Study (MRID#4540304)



	

high	

2500	

hand pruning, harvesting, netting, and thinning

	

cucurbit vegetables	

cucurbit vegetables	

0.31	

low	

500	

irrigation, scouting, thinning, hand weeding 	

1. DFR Tomato Study MRID# 45405302

2.  HED default DFR and dissipation rates



	

medium	

1500	

irrigation, scouting, hand weeding







high	

2500	

hand harvesting and  pruning, thinning, turning, leaf pulling

	

tomato, bell pepper, chilli pepper, eggplant	

fruiting vegetables	

0.55	

low	

500	

hand weeding, scouting, thinning, irrigation	

DFR Tomato Study MRID# 45405302



	

medium	

700	

irrigating, scouting, hand pruning, staking, tying







high	

1000	

hand harvest & pruning, staking, tying, thinning, training

	

cole crops	

head and stem brassica 	

0.42	

low	

2000	

irrigation, scouting, thinning, weeding immature plants	

1.  DFR Tomato Study MRID# 45405302

2.  HED default DFR and dissipation rates



	

medium	

4000	

scouting mature plants







high	

5000	

hand harvesting, irrigation, pruning, topping, tying mature plants

	

Lettuce	

leafy vegetables	

0.48	

low	

500	

hand weeding, irrigation, scouting, thinning	

1.  DFR Tomato Study MRID# 45405302

2.   HED default DFR and dissipation rates



	

medium	

1500	

irrigation, scouting







high	

2500	

hand harvesting & pruning, thinning

	

carrots, potatoes, onions, garlic and leeks 	

vegetable, root	

0.44	

low	

300	

irrigation, scouting, thinning, hand weeding and pruning	

1.  DFR Tomato Study MRID# 45405302

2.   HED default DFR and dissipation rates



	

medium	

1500	

irrigation and scouting







high	

2500	

hand harvest, thinning

	

grapes

blueberry, caneberry, raspberry	

vine/trellis (w/ and w/o girdling)	

0.35	

low	

500	

irrigation, hand weeding, scouting, hedging	

DFR Grape Study MRID#5405303





	

medium	

1000	

training, scouting, tying







high	

5000	

hand harvesting & pruning, training, tying, thinning, leaf pulling





(w/girdling)



very high	

10,000	

cane turning & tying, and girdling

	

Turf	

mowing	

0.5	

low	

500	

mowing, irrigation	

Turf TTR Study MRID# 45405301

	

jazzercise



high	

16,500	

hand weeding, transplanting

	The information in the table is based on  proprietary and
non-proprietary data.

Equations/Calculations:

The following equations were used to calculate risks for workers
performing post-application activities:

DFRt (ug/cm2)	=	Application Rate (lb ai/acre) x F x (1-D)t x 4.54E8
µg/lb x 24.7E-9 acre/cm2

Where:	

DFRt 	=	dislodgeable foliage residue on day "t" (ug/cm2)

          	Rate	=	application rate (lb ai/acre)

F	=	fraction of ai retained on foliage (unitless)

D	=	fraction of residue that dissipates daily (unitless)

 

Note that DFR and TTR (transferable turf residue) may be used
interchangeably in this equation to determine exposure to residues on
crop foliage or turf leaves, respectively.  

Daily dermal dose t  =  DFRt (µg/cm2) x 1E-3 mg/µg x Tc (cm2/hr) x DA
x ET (hrs)								BW (kg)				

             Where,

t	= 	number of days after application day (days)

DFRt 	=	dislodgeable foliage residue on day "t" (ug/cm2)

Tc	=	transfer coefficient (cm2/hr)					

     	DA	=     	dermal absorption factor (0.15)

ET	=	exposure time ( 8 hr/day)

BW	=	body weight (70 kg)

MOE = 	NOAEL (21.8 mg/kg/day)

Dermal Daily Dose (mg/kg/day)

5.2.2   Post-application Exposure, Risk and Characterization

The occupational dermal post-application exposure and risk were
calculated by coupling crop specific DFR values or turf TTR values with
activity specific transfer coefficient (Tc) values from the HED Science
Advisory Council For Exposure Policy Number 3.1: Agricultural Transfer
Coefficients, August 2000. 

For each DFR/TTR study, the site with the highest residue was selected
for use in the risk assessment. The DFR studies were used to assess both
crop specific as well as chemical specific surrogate data for
determining post-application exposure for various other crops (i.e.
leafy and root vegetables, cole crops and cucurbits).  Table 8
summarizes the post-application exposure estimates for all crops. 
Post-application exposure estimates except for one, grapes with
girdling, were all greater than the target MOE of 100 and therefore did
not exceed HED’s level of concern.  The MOE for grapes with girdling
was 95 on the day of application.  The MOE did not reach the target MOE
of 100 till day 9. 



TABLE 8: Post-application Exposure and Risk for BAS 510 F Using DFR
Study Data



Crops	

DAT	

DFR 1 (ug/cm2)	

Daily Dose 2 (mg/kg/day)	

MOE 3	

Pre-harvest Interval





	

low	

high	

low	

high

	

strawberry, blueberry, caneberry, rasberry	

0	

1.731 *	

0.012	

0.045	

1800	

490	

0-days



Low/medium field row crops (peas, beans, canola, mint, and peanuts)	

0	

0.925 *	

0.0016	

0.040	

14000	

550	

6-8 days - succulent peas

7-days - succulent beans

14 days - peanuts, mint

21 days - dry beans & peas, and canola,



Tall row crop (sunflower seeds)	

0	

0.920	

0.0016	

0.016	

14000	

1400	

20-21 days





Deciduous fruit trees (stone fruits)	

0	

1.3	

0.0022	

0.067	

9800	

330	

0-days



tree nuts

	

0	

1.3	

0.011	

0.056	

2000	

390	

14-days 





cucurbits	

0	

0.597 *	

0.0051	

0.026	

4300	

850	

0-days



fruiting vegetables	

0	

1.06	

0.0091	

0.018	

2400	

1200	

0-days



cole crops	

0	

0.809 *	

0.028	

0.069	

790	

310	

0-days

14-days



leafy vegetables	

0	

0.925 *	

0.0079	

0.04	

2700	

550	

14-days



root vegetables	

0	

0.848 *	

0.0044	

0.036	

5000	

600	

0-days - carrots and immature plants







	

7-days - onions, garlic, leeks

30-days - potatoes



grapes w/girdling	

0	

1.343 *	

0.012	

0.23

	

1900

	

95	

14-days

	

2	

1.327 *	

0.011

	

96





4	

1.31 *



0.22



97





5	

1.3    *

	

2000	

98





7	

1.286 *





99





9	

1.27    *





100

	

blueberry, caneberry, rasberry;  grapes w/o girdling	

0	

1.343 *	

0.012	

0.12	

1900	

190

	

golf course turf	

0	

0.188	

0.0016	

0.053	

14,000	

410	

N/A

1. * The highest daily average Dislodgeable Foliar Residues were
adjusted for differences in application rates between the DFR studies
and the proposed label rates 

2.  Daily dermal dose t  =  DFRt (µg/cm2) x 1E-3 mg/µg x Tc (cm2/hr) x
DA x ET (hrs)								                                              BW
(kg)				

3.  MOE =	NOAEL (21.8 mg/kg/day)

Dermal Daily Dose (mg/kg/day)

Re-Entry Interval (REI)

 Due to the statistical uncertainty in estimating the MOE, 95 is
considered equivalent to the target of 100 for risk assessment in this
case.  Therefore, the Restricted Entry Interval (REI) may be based on
acute toxicity of the active ingredient.

A 4-hour REI is proposed on the BAS 510 02F label.  In accordance with
the Federal Register Notice: Worker Protection Standard (WPS), Reduced
REIs for Certain Pesticides (May 3, 1995), 4-hour REI active ingredients
cannot be dermal sensitizers.  The submitted dermal sensitization study
on guinea pigs (MRID# 45404819) was considered unacceptable and
therefore the determination as to whether BAS 510F is or is not a dermal
sensitizer could not be made.  In addition, the data demonstrate that
residues are highly persistent, dissipate slowly, and, for grape
girdling, result in a MOE close to the level of concern.  The technical
material has a Toxicity Category III or IV.  Per the WPS, a 12-hr REI is
required. Therefore, HED recommends use of the WPS required 12 hour REI
based on acute toxicity categories and does not concur with the proposed
4-hour REI.  Should an acceptable dermal sensitizer study be submitted
in the future, HED will revisit the REI issue.       



APPENDIX

Post-application Worker Exposure & Risk Estimates

Using BAS 510F DFR/TTR Study Data

Appendix 1. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—1

Chemical:				BAS510 wet turf

Date:					5/16/03

Assessor:				M Collantes

Transfer Coefficient Group:		Turf / sod

Specific Crop Considered:		Golf courses

Application Rate of Crop (lb ai/A):		0.5

DFR Data Summary		

Source:					TTR Study

Slope of Semilog Regression:		-0.3188

Day 0 Concentration (ug/cm):		0.048

Study Application Rate (lb ai/A):		0.35

Limit of Quantification (ug/cm2):		0.00179

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)	

Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

500	

N/A	

Mowing



Medium	

N/A	

N/A	

N/A



High	

16500	

N/A	

Transplanting, Weeding (hand), Harvest (hand), Harvest (mechanical)



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)	

DOSE (mg/kg/day) (4)	

MOEs (5)

	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

0.048	

0.069	

N/A	

0.00059	

N/A	

0.019	

N/A	

N/A	

37000	

N/A	

1100	

N/A



Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', 8/17/00.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 2. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—2

Chemical:				BAS510 dry turf

Date:					

Assessor:				

Transfer Coefficient Group:		Turf / sod

Specific Crop Considered:		Golf courses

Application Rate of Crop (lb ai/A):		0.5

DFR Data Summary		

Source:					TTR study

Slope of Semilog Regression:		-0.3188

Day 0 Concentration (ug/cm):		0.1313

Study Application Rate (lb ai/A):		0.35

Limit of Quantification (ug/cm2):		0.00179

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)	

Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

500	

N/A	

Mowing



Medium	

N/A	

N/A	

N/A



High	

16500	

N/A	

Transplanting, Weeding (hand), Harvest (hand), Harvest (mechanical)



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)	

DOSE (mg/kg/day) (4)	

MOEs (5)

	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

0.131	

0.188	

N/A	

0.0016	

N/A	

0.053	

N/A	

N/A	

14000	

N/A	

410	

N/A



Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 3. BAS 510 Agricultural Crop Reentry Crop Groupings, Selected
Transfer Coefficients, Treated Crops, and Rates

Transfer Coefficient Group (1)	

Specific Transfer Coefficient (cm2/hr) (1)	

BAS510 Specific Crops (2)	

Max Foliar Rate (lb ai/acre)

	

High end activities	

Low end activities





Berry, low	

1500

400 - 1,800	

400

400 - 1,800	

Berry, low	

0.35



Field / row crops, low / medium	

2500

486 - 2,760	

100

TBD	

Field / row crops, low / medium	

0.48



Field / row crops, tall	

1000

418 - 1,980	

100

TBD	

Field / row crops, tall	

0.41



Trees, fruit, deciduous	

1500

1,421 - 4,393	

1000

197 - 2,302	

Trees, fruit, deciduous	

0.23



Trees, nut	

2500

1,121 - 4,929	

500

197 - 2,302	

Trees, nut	

0.23



Vegetable, cucurbit	

2500

486 - 2,760	

500

486 - 2,760	

Vegetable, cucurbit	

0.31



Vegetable, fruiting	

1000

364 - 1,908	

500

486 - 2,760	

Vegetable, fruiting	

0.55



Vegetable, head and stem Brassica	

5000

2,862 - 7,584	

2000

1,672 - 8,147	

Vegetable, head and stem Brassica	

0.42



Vegetable, leafy	

2500

486 - 2,760	

500

486 - 2,760	

Vegetable, leafy	

0.48



Vegetable, root	

2500

486 - 2,760	

300

140 - 290	

Vegetable, root	

0.44



Vine / trellis (w/ girdling)	

5000

TBD	

500

197 - 2,302	

Vine / trellis (w/ girdling)	

0.35



Vine / trellis (w/o girdling)	

5000

TBD	

500

197 - 2,302	

Vine / trellis (w/o girdling)	

0.35



Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

Appendix 4. Summary of 'Days After Treatment' to Reach the Target MOE
for Short-term Exposure

Crop Grouping (1)	

BAS510 Specific Crops (2)	

Max Foliar Rate (lb ai/acre) (2)	

Days After Treatment Target MOE Achieved (Target MOE = 100)



	

Exposure Activity Levels (3,4)



	

Very Low	

Low	

Medium	

High	

Very High



Berry, low	

Berry, low	

0.35	

N/A	

0	

N/A	

0	

N/A



Field / row crops, low / medium	

Field / row crops, low / medium	

0.48	

N/A	

0	

0	

0	

N/A



Field / row crops, tall	

Field / row crops, tall	

0.41	

N/A	

0	

0	

0	

2



Trees, fruit, deciduous	

Trees, fruit, deciduous	

0.23	

0	

0	

N/A	

0	

0



Trees, nut	

Trees, nut	

0.23	

N/A	

0	

N/A	

0	

N/A



Vegetable, cucurbit	

Vegetable, cucurbit	

0.31	

N/A	

0	

0	

0	

N/A



Vegetable, fruiting	

Vegetable, fruiting	

0.55	

N/A	

0	

0	

0	

N/A



Vegetable, head and stem Brassica	

Vegetable, head and stem Brassica	

0.42	

N/A	

0	

0	

0	

N/A



Vegetable, leafy	

Vegetable, leafy	

0.48	

N/A	

0	

0	

0	

N/A



Vegetable, root	

Vegetable, root	

0.44	

N/A	

0	

0	

0	

N/A



Vine / trellis (w/ girdling)	

Vine / trellis (w/ girdling)	

0.35	

N/A	

0	

0	

0	

9



Vine / trellis (w/o girdling)	

Vine / trellis (w/o girdling)	

0.35	

N/A	

0	

0	

0	

N/A



Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d) where the absorbed dose = DFR (ug/cm2) x TC (cm2/hr) x
conversion factor (1 mg/1,000 ug) x exposure time (hrs) x dermal
absorption / body weight (kg).

Appendix 5. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—3

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Berry, low

Specific Crop Considered:		Berry, low

Application Rate of Crop (lb ai/A):		0.35

DFR Data Summary		

Source:					strawberry study

Slope of Semilog Regression:		-0.0317

Day 0 Concentration (ug/cm):		1.83

Study Application Rate (lb ai/A):		0.37

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)	

Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

400	

400 - 1,800	

Scouting, Weeding (hand), Irrigation, Pruning (hand), Thinning, Harvest
(hand) (raking), Pruning (hand) (shears), Mulching



Medium	

N/A	

N/A	

N/A



High	

1500	

400 - 1,800	

Harvest (hand), Pruning (hand), Pinching, Training



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)	

DOSE (mg/kg/day) (4)	

MOEs (5)

	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.830	

1.731	

N/A	

0.012	

N/A	

0.045	

N/A	

N/A	

1800	

N/A	

490	

N/A

Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', 8/17/00.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 6.   Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results-4

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Field / row crops, low / medium

Specific Crop Considered:		Field / row crops, low / medium

Application Rate of Crop (lb ai/A):		0.48

DFR Data Summary		

Source:					tomato study

Slope of Semilog Regression:		-0.0739

Day 0 Concentration (ug/cm):		1.06

Study Application Rate (lb ai/A):		0.55

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

100	

TBD	

Irrigation, Scouting, Weeding (hand), Thinning



Medium	

1500	

486 - 2,760	

Irrigation, Scouting, Weeding (hand)



High	

2500	

486 - 2,760	

Harvest (hand)



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.060	

0.925	

N/A	

0.0016	

0.024	

0.040	

N/A	

N/A	

14000	

920	

550	

N/A

Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 7.   Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results-5

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Field / row crops, tall

Specific Crop Considered:		Field / row crops, tall

Application Rate of Crop (lb ai/A):		0.41

DFR Data Summary		

Source:					tomato study

Slope of Semilog Regression:		-0.0739

Day 0 Concentration (ug/cm):		1.06

Study Application Rate (lb ai/A):		0.55

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

100	

TBD	

Scouting, Weeding (hand)



Medium	

400	

418 - 1,980	

Scouting



High	

1000	

418 - 1,980	

Irrigation, Scouting, Weeding (hand)



Very High	

17000	

6,748 - 25,254	

Detasseling, Harvest (hand)



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.060	

0.790	

N/A	

0.0014	

0.0054	

0.014	

0.23	

N/A	

16000	

4000	

1600	

95



1	

0.984	

0.734	

N/A	

0.0013	

0.0050	

0.013	

0.21	

N/A	

17000	

4300	

1700	

100

Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 8. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—6

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Trees, fruit, deciduous

Specific Crop Considered:		Trees, fruit, deciduous

Application Rate of Crop (lb ai/A):		0.23

DFR Data Summary		

Source:					strawberry study

Slope of Semilog Regression:		-0.0317

Day 0 Concentration (ug/cm):		1.83

Study Application Rate (lb ai/A):		0.37

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

100	

TBD	

Propping



Low	

1000	

197 - 2,302	

Scouting, Weeding (hand), Irrigation



Medium	

N/A	

N/A	

N/A



High	

1500	

1,421 - 4,393	

Harvest (hand), Propping, Pruning (hand), Training, Tying



Very High	

3000	

2,177 - 3,688	

Thinning



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.830	

1.138	

0.0020	

0.020	

N/A	

0.029	

0.059	

11000	

1100	

N/A	

750	

370



Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 9. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—7

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Trees, nut

Specific Crop Considered:		Trees, nut

Application Rate of Crop (lb ai/A):		0.23

DFR Data Summary		

Source:					peach data

Slope of Semilog Regression:		-0.0477

Day 0 Concentration (ug/cm):		1.3

Study Application Rate (lb ai/A):		0.23

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

500	

197 - 2,302	

Scouting, Thinning, Irrigation, Weeding (hand)



Medium	

N/A	

N/A	

N/A



High	

2500	

1,121 - 4,929	

Harvest (hand), Pruning (hand), Thinning, Harvest (hand) (net)



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.300	

1.300	

N/A	

0.011	

N/A	

0.056	

N/A	

N/A	

2000	

N/A	

390	

N/A

Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 10. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—8

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Vegetable, cucurbit

Specific Crop Considered:		Vegetable, cucurbit

Application Rate of Crop (lb ai/A):		0.31

DFR Data Summary		

Source:					tomato study

Slope of Semilog Regression:		-0.0739

Day 0 Concentration (ug/cm):		1.06

Study Application Rate (lb ai/A):		0.55

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

500	

486 - 2,760	

Irrigation, Scouting, Thinning, Weeding (hand)



Medium	

1500	

486 - 2,760	

Irrigation, Scouting, Weeding (hand)



High	

2500	

486 - 2,760	

Harvest (hand), Leaf Pulling, Pruning (hand), Thinning, Turning



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.060	

0.597	

N/A	

0.0051	

0.015	

0.026	

N/A	

N/A	

4300	

1400	

850	

N/A

Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 11. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—9

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Vegetable, fruiting

Specific Crop Considered:		Vegetable, fruiting

Application Rate of Crop (lb ai/A):		0.55

DFR Data Summary		

Source:					tomato study

Slope of Semilog Regression:		-0.0739

Day 0 Concentration (ug/cm):		1.06

Study Application Rate (lb ai/A):		0.55

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

500	

486 - 2,760	

Weeding (hand), Irrigation, Scouting, Thinning



Medium	

700	

TBD	

Irrigation, Scouting, Pruning (hand), Staking, Tying



High	

1000	

364 - 1,908	

Harvest (hand), Pruning (hand), Staking, Thinning, Training, Tying



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.060	

1.060	

N/A	

0.0091	

0.013	

0.018	

N/A	

N/A	

2400	

1700	

1200	

N/A

Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 12. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—10

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Vegetable, head and stem Brassica

Specific Crop Considered:		Vegetable, head and stem Brassica

Application Rate of Crop (lb ai/A):		0.42

DFR Data Summary		

Source:					tomato study

Slope of Semilog Regression:		-0.0739

Day 0 Concentration (ug/cm):		1.06

Study Application Rate (lb ai/A):		0.55

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

2000	

1,672 - 8,147	

Weeding (hand), Scouting, Thinning, Irrigation, Pruning (hand)



Medium	

4000	

1,672 - 8,147	

Scouting



High	

5000	

2,862 - 7,584	

Harvest (hand), Irrigation, Pruning (hand), Thinning, Topping, Tying



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.060	

0.809	

N/A	

0.028	

0.056	

0.069	

N/A	

N/A	

790	

390	

310	

N/A

Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', 8/17/00.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 13. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—11

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Vegetable, leafy

Specific Crop Considered:		Vegetable, leafy

Application Rate of Crop (lb ai/A):		0.48

DFR Data Summary		

Source:					tomato study

Slope of Semilog Regression:		-0.0739

Day 0 Concentration (ug/cm):		1.06

Study Application Rate (lb ai/A):		0.55

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

500	

486 - 2,760	

Weeding (hand), Irrigation, Scouting, Thinning



Medium	

1500	

486 - 2,760	

Irrigation, Scouting



High	

2500	

486 - 2,760	

Harvest (hand), Pruning (hand), Thinning



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.060	

0.925	

N/A	

0.0079	

0.024	

0.040	

N/A	

N/A	

2700	

920	

550	

N/A

Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 14. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—12

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Vegetable, root

Specific Crop Considered:		Vegetable, root

Application Rate of Crop (lb ai/A):		0.44

DFR Data Summary		

Source:					tomato study

Slope of Semilog Regression:		-0.0739

Day 0 Concentration (ug/cm):		1.06

Study Application Rate (lb ai/A):		0.55

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

300	

140 - 290	

Irrigation, Scouting, Thinning, Weeding (hand), Pruning (hand)



Medium	

1500	

486 - 2,760	

Irrigation, Scouting



High	

2500	

486 - 2,760	

Harvest (hand), Thinning



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.060	

0.848	

N/A	

0.0044	

0.022	

0.036	

N/A	

N/A	

5000	

1000	

600	

N/A



Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 15. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—13

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Vine / trellis (w/ girdling)

Specific Crop Considered:		Vine / trellis (w/ girdling)

Application Rate of Crop (lb ai/A):		0.35

DFR Data Summary		

Source:					grape study

Slope of Semilog Regression:		-0.0062

Day 0 Concentration (ug/cm):		1.42

Study Application Rate (lb ai/A):		0.37

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

500	

197 - 2,302	

Irrigation, Weeding (hand), Scouting, Hedging



Medium	

1000	

197 - 2,302	

Scouting, Training, Tying



High	

5000	

TBD	

Harvest (hand), Pruning (hand), Training, Tying, Thinning, Leaf Pulling



Very High	

10000	

TBD	

Girdling, Turning (Cane turning), Tying (Cane turning)



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.420	

1.343	

N/A	

0.012	

0.023	

0.12	

0.23	

N/A	

1900	

950	

190	

95



1	

1.411	

1.335	

N/A	

0.011	

0.023	

0.11	

0.23	

N/A	

1900	

950	

190	

95



2	

1.403	

1.327	

N/A	

0.011	

0.023	

0.11	

0.23	

N/A	

1900	

960	

190	

96



3	

1.394	

1.318	

N/A	

0.011	

0.023	

0.11	

0.23	

N/A	

1900	

960	

190	

96



4	

1.385	

1.310	

N/A	

0.011	

0.022	

0.11	

0.22	

N/A	

1900	

970	

190	

97



5	

1.377	

1.302	

N/A	

0.011	

0.022	

0.11	

0.22	

N/A	

2000	

980	

200	

98



6	

1.368	

1.294	

N/A	

0.011	

0.022	

0.11	

0.22	

N/A	

2000	

980	

200	

98



7	

1.360	

1.286	

N/A	

0.011	

0.022	

0.11	

0.22	

N/A	

2000	

990	

200	

99



8	

1.351	

1.278	

N/A	

0.011	

0.022	

0.11	

0.22	

N/A	

2000	

990	

200	

99



9	

1.343	

1.270	

N/A	

0.011	

0.022	

0.11	

0.22	

N/A	

2000	

1000	

200	

100



Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).

Appendix 16. Occupational Post-Application Risk Assessment Calculator
(12/7/01) Short-term Results—14

Chemical:				BAS510

Date:					050803

Assessor:				Margarita Collantes

Transfer Coefficient Group:		Vine / trellis (w/o girdling)

Specific Crop Considered:		Vine / trellis (w/o girdling)

Application Rate of Crop (lb ai/A):		0.35

DFR Data Summary		

Source:					grape study

Slope of Semilog Regression:		-0.0062

Day 0 Concentration (ug/cm):		1.42

Study Application Rate (lb ai/A):		0.37

Limit of Quantification (ug/cm2):		0.0125

Exposure Inputs Summary

Exposure Potential	

Transfer Coefficients (cm2/hr) (1)



Activities (1)

	

Used for RA	

Range

	

Very Low	

N/A	

N/A	

N/A



Low	

500	

197 - 2,302	

Irrigation, Weeding (hand), Scouting, Hedging



Medium	

1000	

197 - 2,302	

Scouting, Training, Tying



High	

5000	

TBD	

Harvest (hand), Pruning (hand), Training, Tying, Thinning, Leaf Pulling



Very High	

N/A	

N/A	

N/A



DAT (3)	

DFR LEVELS (ug/cm2)



DOSE (mg/kg/day) (4)



	

MOEs (5)





	

Not Adjusted	

Adjusted for Rate	

Very Low	

Low	

Medium	

High	

Very High	

Very Low	

Low	

Medium	

High	

Very High



0	

1.420	

1.343	

N/A	

0.012	

0.023	

0.12	

N/A	

N/A	

1900	

950	

190	

N/A



Footnote:

  1. Crop groupings and transfer coefficients from Science Advisory
Council for Exposure: Policy Memo #003.1 'Agricultural Transfer
Coefficients', August 17, 2000.

  2. Maximum label rates from end use product labels.

  3. DAT = Days after treatment; DAT0 = On the day of treatment, after
sprays have dried; assumed approximately 12 hours.

  4. The absorbed dermal dose = DFR (ug/cm2) x TC (cm2/hr) x conversion
factor (1 mg/1,000 ug) x exposure time (hrs) x dermal absorption / body
weight (kg).

  5. MOE = Dermal toxicity endpoint (mg/kg-day)/absorbed dermal dose
(mg/kg-d).



CC:   RAB2 RF, M. Collantes, G. Bangs, S. Wang

 PAGE  31 

