  SEQ CHAPTER \h \r 1 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460      

	OFFICE OF PREVENTION, PESTICIDESs

                                                                        
                   AND TOXIC SUBSTANCES

	

MEMORANDUM

Date:  		22 October 09  

SUBJECT:    Endothall: Chronic Aggregate Dietary (Food Only, Food plus
Drinking Water, and Drinking Water Only) Exposure and Risk Assessment
for the Section 3 Registration Action to Allow use of Endothall in
Moving Water Bodies.

PC Codes:  038901, 038904 and 038905	DP Barcode:  D370449

Decision No.:  399181	Registration Nos.:  70506-175 and 70506-176

Petition No.:  8E7419	Regulatory Action:  Section 3

Risk Assessment Type:  NA	Case No.:  2245

TXR No.:  NA	CAS Nos.:  145-73-3; 2164-07-0; 66330-88-9

MRID No.:  47520701 to 47520719	40 CFR:  §180.293 



FROM:	David Soderberg, Chemist

RAB5/Health Effects Division (7509P)

THROUGH:	David Hrdy, Senior Biologist

Debra Rate, Biologist

Dietary Exposure Science Advisory Council (DESAC)

Health Effects Division (7509P)

and

Jack Arthur, Branch Chief

RAB5/Health Effects Division (7509P)

TO:		Sidney Jackson, Product Manager  SEQ CHAPTER \h \r 1   SEQ CHAPTER
\h \r 1 

		Barbara Madden, Team Leader 

RD, Risk Integration, Minor Use and Emergency Response Branch,

Minor Use Team (7505P)

Executive Summary

Chronic, aggregate dietary (food only, food plus drinking water, and
drinking water only) exposure and risk assessments were conducted using
the Dietary Exposure Evaluation Model DEEM-FCID™, Version 2.03.  This
model uses food consumption data from the U.S. Department of
Agriculture’s Continuing Surveys of Food Intakes by Individuals
(CSFII) from 1994-1996 and 1998.  

These analyses were performed to support a section 3 request to use
endothall as an aquatic herbicide to clear weeds from irrigation canals
and other moving water bodies, with no holding times for the water
before it can be used to irrigate crops.  The absence of any holding
time on the water means that the endothall treatment can potentially
leave “inadvertent” residues on any and all food crops irrigated. 
This is because it is not considered possible to assure that such uses
will be known to farmers downstream from application sites.  These
farmers may irrigate their crops with treated water without knowing that
endothall residues are present in the water.  Therefore, an assessment
is needed that addresses exposure from these potential residues on all
possible crops, as well as from drinking water and from any potentially
exposed livestock, poultry, eggs and milk.

Acute and Cancer Dietary Exposure

No acute or cancer dietary exposure endpoints were determined, so no
acute or chronic exposure assessments have been performed.  

     

Chronic Dietary Exposure Results and Characterization

Based upon a DEEM based chronic exposure analysis for food plus water,
neither the general U.S. population nor any of its subgroups exceeded
the chronic population adjusted dose (cPAD).  In this assessment the
general U.S. population is estimated to be exposed at 32% of the cPAD. 
The most highly exposed population subgroup is children 1 – 2 years of
age, who are estimated to be exposed at 84% of the cPAD.  

The calculations for the above estimates have been refined as much as
possible, but the results remain conservative because the input
assumptions are conservative.  The input residue data for foods used
here are based upon a set of 18 field trials and 9 associated processing
studies that were performed by the United States department of
Agriculture’s Interregional Research Project Number 4 (IR-4) to
support this use.  The various crops tested in these trials were chosen
to represent the currently extant crop groups plus grapes and mint. 
These field trials were expressly designed to create maximum possible
residues for setting tolerances and so provided conservative information
when used for dietary exposure assessment.

Per previous consultation with HED, all of these field trials used
applications of endothall to the irrigation canals at the maximum
labeled rate (5 ppm in the water) and generally the maximum number of
times (6) per season.  All treatments were by overhead irrigation (i.e.
were sprayed directly onto the crops before dripping into the soil to
also be taken up by the roots).  This technique is assumed to yield
residues that are as high, or higher, than irrigating to roots only. 
The treated water was applied at one inch/acre of water - equivalent to
the watering effect of one inch of rainfall.  The treated irrigation
water was last applied on the same day as the crops were harvested. 
This approach to the field trials assured maximum residues for setting
tolerances.  

In addition, the exposures estimated here assumed that all irrigation
canals in the US are treated each season, and that treated water is
applied to all crops at the maximum rate to the extent that those crops
are irrigated, i.e., that all foods consumed in the US derive from areas
where endothall has been used.  It is further assumed that all meat,
milk, poultry, and eggs derive from livestock and poultry that have been
consuming both water and feeds containing endothall residues and that
all food fish have been swimming in endothall treated water.  Finally,
it is assumed that consumers are being exposed to residues from all of
these sources together, along with endothall residues in their drinking
water, on a chronic basis.  Although all of these conservatisms apply,
the extent of their effect on this assessment cannot be estimated.  

In order to refine the calculations average results from the field
trials were used, not the recommended tolerances, for this chronic
assessment.  It was not possible for BEAD to estimate percent of crops
treated for this assessment, but in lieu of these factors BEAD was able
to estimate the percents of harvested crops irrigated for some of the
crops.  Where such information was available, the assessment has been
refined by these percent irrigated factors.  Note that these estimates
needed to be in terms of the crop harvested, rather than acreage grown,
because the fact of irrigation itself could affect the yield per acre.  

A conservative estimate of an upper possible concentration of endothall
residues chronically possible in drinking water, at 31 ppb, was provided
by EFED for this assessment.  

Introduction

Dietary risk assessment incorporates both exposure and toxicity for any
given pesticide.  For acute and chronic assessments, the risk is
expressed as a percentage of a maximum acceptable dose (i.e., the dose
which HED has concluded will result in no unreasonable adverse health
effects).  This dose is referred to as the population adjusted dose
(PAD).  The PAD is equivalent to point of departure (POD, NOAEL, LOAEL,
e.g.) divided by the required uncertainty or safety factors.

For non-cancer chronic exposures, HED is concerned when estimated
dietary risk exceeds 100% of the cPAD.  References which discuss chronic
risk assessments in more detail are available on the EPA/pesticides web
site:  “Available Information on Assessing Exposure from Pesticides, A
User’s Guide,” 21-JUN-2000, web link:      HYPERLINK
"http://www.epa.gov/fedrgstr/EPA-PEST/2000/July/Day-12/6061.pdf" 
http://www.epa.gov/fedrgstr/EPA-PEST/2000/July/Day-12/6061.pdf   or see
SOP 99.6 (20-AUG-1999).

The most recent national dietary risk assessment for endothall was
conducted by Susan Stanton and Catherine Eiden (29 September 2005,
D322008).  More recently, an exposure assessment was performed to
address a local emergency use in Idaho by Breann Hanson in 2009 (24
February 2009, D361825).  The current assessment deviates from these
earlier assessments.  This difference is necessary because the amount of
endothall produced and used may increase significantly if this new use
is allowed; because entirely new residue data has been generated for
this new use; because BEAD has made new estimates of the percents of
some harvested crops that have been irrigated, and because EFED has
estimated new values for reasonably expected chronic residues in water.

II.	Residue Information

Endothall Use:

  SEQ CHAPTER \h \r 1 Endothall is a selective contact herbicide,
defoliant, desiccant, and aquatic algicide belonging to the dicarboxylic
acid chemical class.  The free acid of endothall and its dipotassium and
mono-N,N-dimethylalkyl-amine salts (monoalkylamine) are registered in
the United States primarily as aquatic herbicides for the control of a
variety of plants in water bodies.  This registration currently includes
application to irrigation canals, but only with required holding periods
of 7 to 25 days, depending upon the concentration applied.  Endothall is
also registered for desiccation/de-foliation of alfalfa/clover (grown
for seed only), cotton, and potatoes prior to harvest, and for reduction
of sucker branch growth in hops.  Permanent tolerances have been
established for the combined residues of endothall and its monomethyl
ester at 0.1 ppm in/on cotton seeds, fish, dried hops and potatoes, and
at 0.05 ppm in/on rice grain and straw [40 CFR §180.293(a)(1)].  An
interim tolerance of 0.2 ppm has also been established for endothall,
per se, in potable water resulting from the use of the monoalkylamine or
dipotassium salts of endothall for control of aquatic plants in canals,
lakes, ponds and other potential water sources; however HED has
recommended that, to be consistent with current policy, this tolerance
be removed (Registration Eligibility Document for Endothall, September
2005).  An interim tolerance has also been established for endothall on
sugar beet at 0.2 ppm [40 CFR §180.319].

There are currently three endothall end-use products registered to
United Phosphorus, Inc. (UPI) for control of algae and aquatic weeds in
drainage and irrigation canals, including two monoalkylamine salt
formulations and a dipotassium salt formulation.  The monoalkylamine
salt of endothall is formulated as either a 2 lb ae/gal SC/L formulation
(EPA Reg. No. 70506-175) or an 11% granular (G) formulation (EPA Reg.
No. 70506-174), containing 5% ae.  The dipotassium salt is formulated as
a 4.23 lb ai/gal SC/L (EPA Reg. No. 70506-176), which is equivalent to
3.0 lb ae/gal SC/L.  [In order to avoid the complications of different
molecular weights for different salts, endothall concentrations are
expressed as the free acid equivalents (ae).]  Labels for these products
allow for repeated broadcast applications to irrigation canals at rates
yielding endothall concentrations of up to 5 ppm ae for the
monoalkylamine salt and 3.5 ppm ae for the dipotassium salt.  The labels
do not currently specify a maximum number of applications per season or
a maximum seasonal use rate.  Depending on the concentration in the
treated water, the use directions specify minimum holding times of 7
days (0.3 ppm rate) to 25 days (5 ppm rate) prior to using the treated
water for irrigation of crops.

 

For this action Interregional Research Project No. 4 (IR-4) has proposed
that the use directions for the 2 lb ae/gal SC/L monoalkylamine salt and
the 3 lb ae/gal dipotassium salt of endothall be amended to remove the
holding times after water is treated with endothall before it can be
used to irrigate crops.  This amendment would enable use of endothall on
moving water in canals etc with no required holding times.  The amended
uses specify minimum retreatment interval (RTI) of 7 days for irrigation
canals and a maximum seasonal use rate of 30 ppm ae per season (6
applications at up to 5 ppm ae/application).  In conjunction with the
proposed amendments, IR-4 has submitted field trials and processing
studies to support tolerances for indirect or inadvertent residues of
endothall on all crops after irrigation with treated water.

The qualitative nature of endothall residues in plants is adequately
understood based upon the metabolism studies on alfalfa, cotton and
sugar beets.  The qualitative nature of endothall residues in livestock
is also understood based upon the adequate goat and poultry metabolism
studies.  The Agency has concluded that endothall and its monomethyl
ester are the residues of concern in both plant and animal commodities
for purposes of risk assessment.  The analyses in these submitted
studies includes a derivatization in strong phosphoric acid, which is
expected to hydrolyze any monomethyl esters that are present back to the
parent, so that both are ultimately measured as a common moiety.    SEQ
CHAPTER \h \r 1 The residue of concern in water is endothall only.  

Residue Data on Foods used for the Chronic Assessment:

The residue data used in this assessment are derived from a body of 18
new field trial studies and 9 new processing studies performed by
USDA’s IR-4 explicitly to support this registration action.  The field
trial studies provided residue results for from one to six individual
field trials for each of the established crop groups, and for grapes and
mint.  There were at least two trials per crop group, however only one
plot was tested per trial.  Each plot was sampled and tested twice.

These trials specifically tested for residues in/on these crops: Sugar
Beet – Tops and Roots; Carrot – Roots; Potato – Tuber; Green
Onion; Dry Bulb Onion; Leaf Lettuce; Head Lettuce; Cabbage; Succulent
Podded Beans; Succulent Limas; Dried Beans; Succulent Podded Peas;
Soybeans; Tomato; Cucumber; Orange; Apple; Peach; Blueberry; Blackberry;
Pecan – Nutmeat; Almond – Nutmeat and Hulls; Sweet Corn - K+CWHR,
Forage (w/o ears), Forage (w/ears), Stover (w/ears); Field Corn -
Forage, Grain, Stover; Sorghum – Forage, Grain, Stover; Winter Wheat,
Forage, Hay, Grain, Straw; Spring Wheat - Forage, Hay, Grain, Straw,
Grasses - Forage, Hay; Alfalfa – Forage and hay; Rice – Grain and
Straw; Grape; and Mint.

The results of these field trials and accompanying processing studies
are reported in the Summary of Analytical Chemistry and Residue Data
Memorandum (D356315.MEM) and its accompanying ders for MRIDs 47520701 to
47520718.  Reported field trial results and processing factors are
provided in Attachments 4 and 5.  A detailed list of DEEM inputs: foods,
residue values and processing factors is shown in Table 1.  

It should be noted that, with the concurrence of ChemSAC, for endothall
residues reported below the limit of quantification (LOQ) (0.05 ppm) in
these studies, the actual reported results were used in place of the
using ½ the LOQ.  In this case the limit of detection (LOD) was
generally much lower than the LOQ, often considerably less than 0.01
ppm, so there was a lot of room for visible results below the LOQ, and
while the reported results below the LOQ may have been less quantifiably
reliable than results above the LOQ, they generally were quite
repeatable, certainly could not be assumed to be unreliable, and were
the best available information.  Usually, at such low levels, deviations
from quantification in analyses are caused by background interference
which generally tends to boost the signal, so if these results are
biased at all, they should tend to be biased on the high side. 
Particularly in the case of the widely translated residues on apple,
using ½ LOQ would have led to an assessment using residue values below
those actually reported, and especially when making the broad
extrapolations used here, it is important to use the best available
numbers.  

Although results were reported for all of the crops after treatment of
irrigation water with 5 ppm ae of the alkylamine endothall, side by side
results were also reported for some of the crops after treatments of
irrigation water with 3.5 ppm ae of dipotassium endothall.  (This
accords with a different application rate on the label for the
dipotassium salt.)  For the current assessment only the 5 ppm alkylamine
results were used, however residues on crops after the side by side
treatment with the dipotassium salt were not higher than those for the
alkyl amine salt, so this assessment can also be considered to address
exposure to dipotassium endothall at the 3.5 ae rate.  

Even with all of the data from 18 sets of field trials for different
crops, in order to address inadvertent residues of endothall on all
possible crops it has been necessary to make broad translations from
these limited field trials to orphan crops outside of these crop groups
(and grapes or mint).  Regarding the general nature of these
translations outside of crop groups, residues reported for apples were
translated to all other tree crops outside of the established crop
groups – generally tropical fruits.  Residues in grass were
conservatively translated to related stem vegetables such as sugarcane
and bamboo.  Residues in mint were translated to all herbs and spices
and to strawberries.  Leaf lettuce residues were translated to all other
greens, and because residues in leaf lettuce were higher than in
cabbage, leaf lettuce residues were used in place of cabbage for the
leafy Brassica.  Leaf lettuce was also translated to cactus and a few
similar orphan crops.  Cucumber residues were translated to pineapples. 


Some translations were, of necessity, liberal and uncertain.  However,
an effort was made to keep these translations conservative, and while
that conservativeness cannot be guaranteed in each and every individual
case, when taken as a whole the extrapolated residues are based upon the
best available information and should err somewhat on the high side. 
Details of crop translations are shown in Table 1.  [Note that seaweed
was omitted from the assessment because endothall use and seaweed
culture are clearly incompatible.  This is mildly important because
seaweed does show up in infant formula; the nature of the use allowing
the clear inference that the use is in the form of an extracted gum,
such as agar or more probably carrageenan, that is used to stabilize the
formula and adjust viscosity.]

  

The submitted studies also provided processing factors for the more key
processed products from the following crops: sugar beets, soybeans,
tomatoes, oranges, apples, grapes, mint, rice and for corn, sorghum and
wheat.  Again, because there are a limited number of processing studies
to address all possible processed commodities from all crops, the
processing studies were sometimes extrapolated to both similar and
sometimes more distantly related processed products.  

For instance, the soybean oil processing factor was also applied to all
other vegetable oils.  This is very reasonable because endothall is
strongly hydrophilic and should not leave residues in fats and oils. 
The measured processing factors for orange juice and citrus oil were
applied to all similar citrus products with appropriate corrections for
each citrus fruit (per: Reviewer Aid - Hops/Tea/Juices - Processing
Factors in DEEM).  The processing factor for all citrus peels was left
at 1 because dried citrus pulp takes a 2.4 processing factor, while
citrus oils take a 0.2 processing factor, and peels should fall
somewhere in between.  [Please note that citrus oils, like the mint
oils, are “essential oils” (specifically monoterpenes) with a very
different chemistry than the ordinary vegetable oils.]  

The sugar beet processing study showed only a reduction factor of 0.1
for processing the beets into sugar, but the size of the factor was
experimentally limited because residues on the raw beet roots were
already close to the lower limit of the analytical method, with no room
for much reduction of the residues.  For that reason, and because sugar
is highly purified by recrystalizations, column absorption, and other
processes, with endothall being very water soluble, ChemSAC has
concluded that zero should be used as the processing factor for sugar
from both sugar beets and sugarcane.  The concentration factor for
producing molasses from sugar beets determined in the processing study
was also applied to the molasses from sugar cane.  

Where study data did not exist, or could not be readily translated, DEEM
default concentration factors were used if available.  For some of the
dried or juiced food forms of the less consumed crops, mostly tropical
fruits, no DEEM default concentration factors have ever been decided
upon.  In order to assure consistency with all other HED assessments, no
new maximum concentration factors were calculated or applied for these
minor commodities.

Meat, Milk, Poultry and Eggs

Residues were calculated for meat, milk, poultry and eggs (MMPE) based
upon calculated dietary burdens.  Because there is no adequate feeding
study, the total radioactive residue (TRR) from the appropriate
metabolism studies were used to estimate the residues incurred in the
food tissues as a result of these dietary intakes.  In addition, an
estimate of endothall residues that might be ingested by livestock from
drinking from endothall treated water bodies is also incorporated.  For
finfish, crustaceans, and mollusks, the recommended tolerances based
upon their being cultured in treated water, were used.  Residues in
honey were translated from milk as the most closely matched available
source of data.  

The detailed dietary burden calculations are provided in attachment 6.  

Summary of Dietary Exposure Input Data for Foods

The available processing studies are reported in D356315.MEM and the
accompanying ders for MRIDs 47520701 to 47520718.   A detailed list of
foods, residue values and processing factors used in this assessment is
shown in Table 1.  

BEAD has provided estimates of the extent to which some crops are
irrigated.  All irrigated water, however, is assumed to be treated with
endothall at the maximum rate.  No Projected market share data were used
for any irrigation systems or commodities.   BEAD’s memo (D369862,
D369863) is included as Attachment 7.

Table 1. 	Residue Summary for Endothall.

Commodity	Residues (ppm)	Percent Crop Treated	Processing Factor	Comments




Vegetable, root and tuber, group 1	0.33	100	1	Based on average residues
in sugar beets 

Carrots	0.08	100	1	carrots 

Potatoes	0.08	100	1	potatoes 

Potatoes, dry

100	6.5	Potatoes

Beet, sugar	0.33	37	1	Based on average residues in sugar beets

Beet, sugar. Sugar	0.33	37	0	Based on average residues in sugar beets,
and processing to zero residues

Beet, sugar, molasses	0.33	37	2.4	Average residues in sugar beet roots
and 2.4x processing factor. 

Ginger, dried	0.33	100	1	No default processing factor

Root crop Tops, Crop Group 2	1.3	100

From sugar beet tops

Vegetable, bulb, group 3A green onions	0.26	100	1	Based on average
residues in green onions 

Bulb onions	0.05	100	1	dry bulb onions (<0.05 ppm)

Bulb onion, dried	0.05	100	9.0	dry bulb onions (<0.05 ppm)

Vegetable, leafy, except head lettuce, endive, and other closed head
varieties of leafy vegetables   	0.71	100	1	Based on residues in leaf
lettuce (0.71 ppm) 

Head lettuce, endive and celery	0.32	100	1	Based on average residues in
head lettuce (0.32 ppm)

Vegetable, brassica, head and stem subgroup 5A	0.06	100	1	Based upon
Cabbage 0.06 ppm)

Vegetable, brassica, leafy, group 5B	0.71	100	1	Based upon residues in
leaf lettuce, which better represents residues on leafy Brassica than
does cabbage.

Vegetable, legume, group 6 Vegetable, legume, edible podded, subgroup 6A
	0.39	100	1	based on the average residues in succulent beans (0.39 ppm) 


Pea and bean, succulent shelled, subgroup 6B	0.73	100	1	Average residues
in succulent peas (0.73 ppm)

Pea and bean, dried shelled, subgroup 6C	0.11	32	1	dried beans (0.11
ppm)

Soybean seed	0.034	9	1	soybeans (0.034 ppm).

Soybean flour	0.034	9	1	soybeans (0.034 ppm).

Soybean milk	0.034	9	1	soybeans (0.034 ppm).

Soybean oil	0.034	9	0.005	soybeans (0.034 ppm).

Vegetable, fruiting, group 8	0.025	100	1	Based on average residues in
tomatoes (0.025 ppm), and factors from processing study.   DEEM default
factor for juice

Tomato Paste

100	3.3

	Tomato Puree

100	2.1

	Tomato Juice

100	1.5

	Dried tomato	0.025	100	14.3

	Okra	0.025	100	1	From Tomato (0.025 ppm)

Vegetable, cucurbit, group 9	0.5	100	1	Based on average residues in
cucumbers (0.74 ppm).

Fruit, citrus, group 10	0.024	100	1	Based on average residues in oranges
(<0.05 ppm).

Citrus Fruit Oil	0.024	100	0.2	Citrus oil factor

Citrus Fruit Juices - all	0.024	100	0.7	From OJ factor, using DESAC
adjustment factors

Citrus Peels	0.024	100	1.0	Between oil factor and pulp factor

Fruit, pome, group 11	0.041	100	1	Based on average residues in apples
(0.041 ppm).

Dried apple 	0.041	100	8.0	Processing Study

Apple sauce	0.041	100	1	No Factor

Apple and pear juices	0.041	100	1.2	Processing Study

Dried pear	0.041	100	6.25	Default Factor

Fruit, stone, group 12	0.098	100	1	Based on average residues in peaches
(0.15 ppm).

Dried Peach	0.098	100	7.0	Default factor

Dried Plum (Prune)	0.098	100	5.0	Default factor

Prune Juice	0.098	100	1.4	Default factor

Cherry Juice	0.098	100	1.5	Default factor

Caneberry subgroup 13A	0.18	100	1	Based on residues in blueberries (0.18
ppm)

                                                                        
                       Bushberry subgroup 13B	0.33	100	1	blackberries
(0.33 ppm).

Current, dried	0.33	100	4.4	Raisin drying factor

Grape	0.52	97	1	Based upon average residues on grapes ( 0.52 ppm).

Grape Juice	0.52	97	1.0	Residues on grapes, Default Factor

Grape, raisin	0.52	97	4.4	Average residues of 0.52 ppm in grapes and a
4.4x processing factor. 

Grape Leaves	0.52	97	1	Based upon average residues on grapes

Grape wine and sherry	0.52	97	1.2	Based upon average residues on grapes,
and default juice processing factor

Nut, tree, group 14	0.031	100	1	Based on average residues in almond 
nutmeats (0.031 ppm).

Pecans	0.024	100	1	Pecan Study

Tree nut oils	0.031	100	0.005	Processing factor from soybean oil factor

Grain, cereal, group 15	0.71	100	1	Cereal Grain – corn, sorghum and
wheat field trials

Wheat	0.71	14	1	Wheat field studies

Wheat flour	0.71	14	0.6	Wheat Processing Study

Wheat germ	0.71	14	2.6	processing factor of 2.6x for germ, 

Wheat Bran	0.71	14	2.3	PF 2.3x for bran, 

Barley, grain	0.71	36	1	From wheat

Barley, flour	0.71	36	1	Wheat residues corn flour processing

Barley, bran	0.71	36	2.3	Wheat processing study

Sorghum, grain	1.0	15	1.0	Percent irrigated for grain only

Sorghum, syrup	1.0	100	1.0	Percent irrigated for grain only

Oats	0.71	7	1.0	Residues from wheat

Corn, sweet, kernel plus cob with husks removed	0.11	100	1	Tolerance
based on average residues in sweet corn K+CWHR (0.11 ppm)

Corn, field, grain	0.05	19	1	Tolerance based on average residues found
in field corn grain (0.05 ppm)

Corn meal and flour	0.05	19	1.0	Corn Processing Study

Corn, field, bran	0.05	19	2.3	Corn Processing Study

Corn, field, starch	0.05	19	1.0	Corn Processing Study

Corn, field, syrup	0.05	19	1.5	Corn Processing Study

Corn, field, oil	0.05	19	1	Corn Processing Study

Corn, pop, grain	0.05	19	1	Tolerance based on average residues found in
field corn grain (0.05 ppm)

Herb and spice, group 19

100	1	Based upon Mint Study

Rice, grain	1.05	100	1	Average residues in Rice

White Rice	1.05	100	0.1	Rice Processing Study 

Rice Bran	1.05	100	2.3	Rice Processing Study

Rice flour	1.05	100	0.1	Rice Processing Study for white rice

Alfalfa	0.11	92	1	From Alfalfa trials

Acerola	0.041	100	1	Translated from apple residues

Amaranth	0.71	100	1	Translated from leaf lettuce

Artichoke	0.71	100	1	Translated from leaf lettuce

Asparagus	0.32	100	1	Translated from head lettuce

Avocado	0.041	100	1	Translated from apple residues

Bamboo	2.2	100	1	From average grass residues

Banana	0.041	100	1	Translated from apple residues

Dried Banana	0.041	100	3.9	Translated from apple residues

Belgium endive	0.32	100	1	Translated from head lettuce

Breadfruit	0.041	100	1	Translated from apple residues

Cactus	0.71	100	1	Translated from leaf lettuce

Canistel	0.041	100	1	Translated from apple residues

Carob	0.041	100	1	Translated from apple residues

Cherimoya	0.041	100	1	Translated from apple residues

Cocoa bean	0.041	100	1	Translated from apple residues

Cocoa bean powder	0.041	100	1 	Translated from apple residues

Coconut meat	0.041	100	1	Translated from apple residues

Dried coconut meat	0.041	100	2.1	Translated from apple residues

Coconut milk	0.041	100	1	Translated from apple residues

Coconut oil	0.041	100	0.005	Translated from apple residues

Coffee, roasted bean	0.041	100	1	Translated from apple residues

Coffee, Instant	0.041	100	1	Translated from apple residues

Cottonseed oil	0.1	100	0.001	Regular Cotton residues and processing
factor

Cranberry	0.33	100	1	From blackberries

Cranberry, Dried	0.33	100	1	From blackberries

Cranberry, Juice	0.33	100	1.1	From blackberries

Date	0.041	100	1	Translated from apple residues

Feijoa	0.041	100	1	Translated from apple residues

Fig	0.041	100	1	Translated from apple residues

Dried fig	0.041	100	1	Translated from apple residues

Flaxseed Oil	0.034	100	0.005	From soybeans and the soy oil PF

Guava	0.041	100	1	Translated from apple residues

Honey	0.003	100	1	Use milk residues

Hop	0.1	100	1	Tolerance from Terrestrial use

Jaboticaba	0.041	100	1	Translated from apple residues

Jack fruit	0.041	100	1	Translated from apple residues

Kiwi fruit	0.52	100	1	From grapes

Longan	0.041	100	1	Translated from apple residues

Lychee	0.041	100	1	Translated from apple residues

Mamey apple	0.041	100	1	Translated from apple residues

Mango	0.041	100	1	Translated from apple residues

Dried mango	0.041	100	1	Translated from apple residues

Mango juice	0.041	100	1	Translated from apple residues

Maple sugar	0.041	100	1	Translated from apple residues

Maple syrup	0.041	100	1	Translated from apple residues

Mulberry	0.041	100	1	Translated from apple residues

Mushroom	0.71	100	1	Translated from leaf lettuce

Olive	0.041	100	1	Translated from apple residues

Olive oil	0.041	100	0.005	Translated from apple residues

Palm heart	2.2	100	1	Translated from grass residues

Plam oil	2.2	100	0.005	Translated from grass residues

Papaya	0.041	100	1	Translated from apple residues

Dried papaya	0.041	100	1.8	Translated from apple residues

Papaya juice	0.041	100	1.5	Translated from apple residues

Passionfruit	0.041	100	1	Translated from apple residues

Passionfruit juice	0.041	100	1	Translated from apple residues

Pawpaw	0.041	100	1	Translated from apple residues

Peanut	0.08	42	1	From potato residues

Peanut butter	0.08	42	1.89	From potato residues

Peanut oil	0.08	100	0.005	From potato residues, with soy oil processing
factor

Peppermint	2.14	100	1	From Mint Study 

Peppermint oil	2.14	100	0.01	From Mint Study

Persimmon	0.041	100	1	Translated from apple residues

Pine nut	0.041	100	1	Translated from apple residues

Pineapple	0.5	100	1	From curcubits

Dried pineapple	0.5	100	5.0	From curcubits

Pineapple juice	0.5	100	1.7	From curcubits

Plantain	0.041	100	1	Translated from apple residues

Dried plantain	0.041	100	3.9	Translated from apple residues

Pomegranate	0.041	100	1	Translated from apple residues

Psyllium seed	0.71	100	1	Translated from leaf lettuce

Quinoa gra oilin	0.71	100	1	Translated from leaf lettuce

Rapeseed	0.034	100	0.005	From Soybeans and soybean oil PF

Safflower seed oil	0.034	100	0.005	From Soybeans and soybean oil PF

Sapote	0.041	100	1	Translated from apple residues

Sesame seed	0.71	100	1	Translated from leaf lettuce

Sesame seed oil	0.71	100	0.005	Translated from leaf lettuce

Soursop	0.041	100	1	Translated from apple residues

Spanish lime	0.041	100	1	Translated from apple residues

Spearmint	2.14	100	1	From Mint Study

Sunflower	0.034	100	0.005	From Soybeans and soybean oil PF

Spearmint oil	2.14	100	0.01	From Mint Study

Starfruit	0.041	100	1	Translated from apple residues

Strawberry	0.52	100	1	Translated from grapes

Strawberry juice	0.52	100	1	Translated from grapes

Sugar apple	0.041	100	1	Translated from apple residues

Sugarcane	2.2	100	1	From grass

Sugarcane sugar	2.2	54	0	From grass, processed to zero residues 

Sugarcane molasses	2.2	54	2.4	From grass, sugar beet to molasses
processing factor

Tamarind	0.041	100	1	Translated from apple residues

Tea, dried	0.33	100	1	Translated from blackberry residues

Instant  tea	0.33	100	1	Translated from blackberry residues

Tomato tree	0.041	100	1	Translated from apple residues

Vinegar	0.025	100	1	Translated from apple residues

Water chestnut	5.0	100	1	Aquatic plant, highest residue value in water

Watercress	5.0	100	1	Aquatic plant, highest residue value in water

Cattle, muscle	0.0025	100	1	Based upon calculations for Dairy Cattle
using metabolism data.

Cattle, meat byproducts	0.023	100	1	Based upon calculations for Dairy
Cattle using metabolism data.

Cattle, kidney	0.023	100	1	Based upon calculations for Dairy Cattle
using metabolism data.

Cattle, liver	0.010	100	1	Based upon calculations for Dairy Cattle using
metabolism data.

Cattle, fat	0.001	100	1	Based upon calculations for Dairy Cattle using
metabolism data.

Milk	0.003	100	1	Based upon calculations for Dairy Cattle using
metabolism data.

Sheep, muscle	0.002	100	1	Based upon calculations for Beef Cattle using
metabolism data.

Sheep, kidney	0.014	100	1	Based upon calculations for Beef Cattle using
metabolism data.

Sheep, liver	0..006	100	1	Based upon calculations for Beef Cattle using
metabolism data.

Sheep, fat	0.0006	100	1	Based upon calculations for Beef Cattle using
metabolism data.

Goat, muscle	0.0015	100	1	Based upon calculations for Beef Cattle using
metabolism data.

Goat, kidney	0.014	100	1	Based upon calculations for Beef Cattle using
metabolism data.

Goat, liver	0.006	100	1	Based upon calculations for Beef Cattle using
metabolism data.

Goat, fat	0.0006	100	1	Based upon calculations for Beef Cattle using
metabolism data.

Hog, muscle	0.0007	100	1	Based upon calculations using metabolism data.

Hog, Skin	0.0065	100	1	Based upon calculations using metabolism data.

Hog, kidney	0.0065	100	1	Based upon calculations using metabolism data.

Hog, liver	0.0028	100	1	Based upon calculations using metabolism data.

Hog, fat	0.0003	100	1	Based upon calculations using metabolism data.

Poultry, muscle	0.001	100	1	Based upon calculations using metabolism
data.

Poultry, liver	0.003	100	1	Based upon calculations using metabolism
data.

Poultry, fat	0.001	100	1	Based upon calculations using metabolism data.

Poultry, skin and meat byproducts	0.014	100	1	Based upon calculations
using metabolism data.

Egg, whole	0.0037	100	1	Based upon calculations using metabolism data.

Egg, white	0.0003	100	1	Based upon calculations using metabolism data.

Egg, yolk	0.0037	100	1	Based upon calculations using metabolism data.

Finfish	0.1	100	1	Tolerance

Crustaceans	1	100	1	Recommended Tolerance

Mollusks	4	100	1	Recommended Tolerance



 Drinking Water Data

The value for drinking water residues, at 31 ppm, that was used in the
dietary risk assessment was provided by the Environmental Fate and
Effects Division (EFED).  A copy of the memo is provided as attachment
8.   Water residues were incorporated in the DEEM-FCID into the food
categories “water, direct, all sources” and “water, indirect, all
sources.”   

As explained by EFED, “the maximum potential exposure of endothall in
drinking water sources is expected to result from the direct application
of endothall to drinking water reservoirs to control aquatic weeds. 
EFED assumed that the entire reservoir would be treated at the maximum
rates, with no more than 10% of the reservoir treated at one time as
stated on the label, so that 10 treatments were applied 7 days apart to
get the entire reservoir.  Since the label specified that the community
water system (CWS) could not supply treated drinking water unless the
residues were below 0.1 ppm (100 µg/L), EFED assumed 100 µg/L (0.1
ppm) as the acute (peak) exposure and the constant exposure during the
treatment period and then modeled residue decline by degradation after
the final treatment.  This resulted in a chronic (annual average)
concentration of 31 µg/L (0.031 ppm) for endothall.  This represents
the likely high-end chronic exposure from endothall from the use most
likely to generate the highest exposures (treatment of a reservoir).” 


IV.	DEEM-FCID™ Program and Consumption Information

A chronic dietary exposure assessment for endothall was conducted using
the Dietary Exposure Evaluation Model software with the Food Commodity
Intake Database DEEM-FCID™, Version 2.03 which incorporates
consumption data from USDA’s Continuing Surveys of Food Intakes by
Individuals (CSFII), 1994-1996 and 1998.  The 1994-96, 98 data are based
on the reported consumption of more than 20,000 individuals over two
non-consecutive survey days.  Foods “as consumed” (e.g., apple pie)
are linked to EPA-defined food commodities (e.g. apples, peeled fruit -
cooked; fresh or N/S; baked; or wheat flour - cooked; fresh or N/S,
baked) using publicly available recipe translation files developed
jointly by USDA/ARS and EPA.  For chronic exposure assessment,
consumption data are averaged for the entire U.S. population and within
population subgroups.  Based on analysis of the 1994-96, 98 CSFII
consumption data, which took into account dietary patterns and survey
respondents, HED concluded that it is most appropriate to report risk
for the following population subgroups: the general U.S. population, all
infants (<1 year old), children 1-2, children 3-5, children 6-12, youth
13-19, adults 20-49, females 13-49, and adults 50+ years old.

For chronic dietary exposure assessments, an estimate of the residue
level in each food or food-form (e.g., orange or orange juice) on the
food commodity residue list is multiplied by the average daily
consumption estimate for that food/food form to produce a residue intake
estimate.  The resulting residue intake estimate for each food/food form
is summed with the residue intake estimates for all other food/food
forms on the commodity residue list to arrive at the total average
estimated exposure.  Exposure is expressed in mg/kg body weight/day and
as a percent of the cPAD.  This procedure is performed for each
population subgroup.

V.	Toxicological Information

The HIARC discussed endothall on 18 May 2004.  This discussion resulted
in the following table of toxicological endpoints for endothall.  These
endpoints were reviewed by the current assessment team and no revisions
were considered necessary.

Table 2.  Summary of Toxicological Doses and Endpoints for Endothall for
Use in Dietary Exposure Assessment



Exposure

Scenario	Point of Departure	Uncertainty/FQPA Safety Factors	RfD, PAD,
Level of Concern 	Study and Toxicological Effects



Acute Dietary

	

An appropriate endpoint attributable to a single dose was not available
from any study, including the prenatal developmental toxicity study in
rats. An acute RfD was not established.



Chronic Dietary

(All populations)	

LOAEL= 2 mg/kg/day

	

UFA = 10

UFH = 10

UFDB = 3

UFtotal = 300

	Chronic RfD = 

0.007 mg/kg/day

cPAD = 0.007 mg/kg/day	2-generation reproduction study in rats; LOAEL =
2 mg/kg/day based on proliferative lesions of the gastric epithelium in
both sexes



Cancer (oral, dermal, inhalation)	

Not likely to be carcinogenic to humans

Point of Departure (POD) = A data point or an estimated point that is
derived from observed dose-response data and  used to mark the beginning
of extrapolation to determine risk associated with lower environmentally
relevant human exposures.  LOAEL = lowest observed adverse effect level.
 UF = uncertainty factor.  UFA = extrapolation from animal to human
(intraspecies).  UFH = potential variation in sensitivity among members
of the human population (interspecies).  UFDB = to account for the
absence of key data (i.e., lack of a critical study).  PAD = population
adjusted dose (a = acute, c = chronic).  RfD = reference dose.  

These endpoints have been reviewed by the team for this registration
action.  The database uncertainty factor is for lack of a neurotoxicity
study.  The team has concluded that these endpoints remain appropriate.

VI.	Results/Discussion 

As stated above, for chronic assessments, HED is concerned when dietary
risk exceeds 100% of the cPAD.  The DEEM-FCID™ analyses estimate the
dietary exposure of the U.S. population and various population
subgroups.  The results reported in Table 3 are for the general U.S.
Population, all infants (<1 year old), non-nursing infants (<1 year
old), children 1-2, children 3-5, children 6-12, youth 13-19, females
13-49, adults 20-49, and adults 50+ years.  

Results of Chronic Dietary (Food Only, Food and Drinking Water, and
Drinking Water Only) Exposure Analysis

The results of the chronic dietary exposure analysis are reported in the
summary table (Table 3) below.  We again note that these estimates are
expected to be very conservative, but that data is not available to
provide specific, quantifiable refinement below these levels of
exposure.

Table 3.  Summary of Chronic Dietary (Food Only,  Food and Drinking
Water, or Drinking Water Only) Exposure and Risk for Endothall

Population Subgroup	Chronic Dietary

	Food Only	Water Only	Food Plus Water

	Dietary Exposure (mg/kg/day)	% cPAD	Dietary Exposure

(mg/kg/day)	% cPAD	Dietary Exposure

(mg/kg/day)	% cPAD

General U.S. Population	0.001614	23	0.000653	9	0.002268	32

All Infants (< 1 year old)	0.002320	33	0.002142	31	0.004462	64

Children 1-2 years old	0.004912	70	0.000970	14	0.005882	84

Children 3-5 years old	0.003609	52	0.000908	13	0.004517	65

Children 6-12 years old	0.001997	29	0.000627	9	0.002624	38

Youth 13-19 years old	0.001144	16	0.000472	7	0.001616	23

Adults 20-49 years old	0.001308	19	0.000610	9	0.001918	27

Adults 50+ years old	0.001367	20	0.000642	9	0.002009	29

Females 13-49 years old	0.001276	28	0.000608	9	0.001884	27



VII.	Characterization of Inputs/Outputs

In the course of conducting a dietary exposure analysis, decisions are
made regarding the residue data used in the analysis (e.g., field
trials, monitoring data, etc.), refinements incorporated into the
analysis (such as percent crop treated and processing factors), and
perhaps other issues.  The following is a description of the most
important aspects of these uncertainties.  

Level of Refinement

Residue and processing data are all from residue field trials designed
to produce maximum residues for the purpose of setting tolerances.  The
assessment has been refined as possible given the nature of the
information available.  Average residue values, not tolerances, have
been used for the crops.  Where information was available to BEAD,
percents of the harvested crop that have been irrigated (in lieu of
percent crop treated values) have also been incorporated.  For
estimating residues in MMPE, average residues in feeds and chronically
available residues in the livestock water were also used.  But although
the assessment may be considered to have been refined, the conditions
under which the field trials were performed, and other assumptions
implicit in the assessment make the results very conservative.  

Residue Issues

The estimate of endothall residues in drinking water is conservative and
is expected to represent the high end of reasonably possible,
chronically available residues in drinking water.  The assessment
incorporates the assumption that all drinking water consumed by all
exposed individuals chronically contains residues at this concentration.
 We note that this kind of assumption is implicit in all current dietary
exposure assessments.  

The estimated exposures through food incorporate the conservative
assumptions that all irrigation systems are treated with endothall; that
the treatments are always at the maximum rate and are applied the
maximum number of times per season.  It appears that very many, if not
all, irrigation channels do require some form of treatment to remove
aquatic weeds every year, but it is not now known to what extent
endothall may find future use to address these problems.  

The field trials all used applications of water containing 5 ppm of
endothall applied at 1 inch per acre of water.  Generally the maximum
number of applications (6) per season were made.  While 5 ppm is the
maximum application rate, rates above 3.5 ppm are not usually
recommended, and replicated applications are used only as needed.  

All treatments in the field trials are by overhead irrigation (i.e. are
sprayed on the crops).  This method delivers the treated water directly
to the surfaces of the crops as well as to the roots compared to other
irrigation methods that deliver water only to the roots but it is
unclear to what extent overhead irrigation may be conservative.  

It is known that grapes, one of the drivers of exposure in this
assessment for young children, are not normally irrigated by overhead
spray once the vines have fruited.  Overhead irrigation is avoided to
prevent development of diseases on the fruit.  So to the (unknown)
extent that the use of overhead irrigation may be conservative compared
to root irrigation of grapes, overhead irrigation may have introduced a
significant conservatism.]   [We also note that the exposure through
grapes derives mostly from grape juice, which is made mostly from grapes
grown in the East, where irrigation is less common than in the West.] 
Similarly, it is unclear to what extent various fruit trees and berries
are overhead irrigated once they are fruiting, and especially near
harvest.

In the field trials the treated irrigation water was last applied on the
very same day that the crops were harvested.  This is expected to have
been a very conservative condition because it seems unlikely that
treatment of canals to remove aquatic weeds will be done near crop
harvesting times in most of the U.S.   Even if the treatment is done
near harvest, the odds are against the residues occurring at the maximum
allowed concentration on the same day as harvest, or of all plants being
deliberately irrigated on a day when heavy harvest equipment must be
moved onto the fields.   

It is assumed that all crops bear residues of endothall, that all derive
from areas where endothall will be used.  This assumption that all
crops, domestic and foreign, are grown in treated areas is a customary
assumption in current assessments, but given the extensive international
trade in food crops and commodities in today’s world, this should be a
conservative assumption.  

It is assumed that all meat, milk, poultry, and eggs derive from
livestock and poultry that have been consuming both water and feeds that
contain the maximum possible endothall residues and that fish consumed
have been swimming in endothall treated water and have incurred
tolerance level residues.  Residues are also postulated to be present in
honey at the concentrations found in cow’s milk.  [Milk is the best
available surrogate for honey in the submitted studies.]  The
conservatism of estimating exposure through all of these foods all
together should be apparent, but cannot be quantified.  

Thus it is again summarized that these estimates are expected to be
conservative, but the extent of these conservatisms cannot be
quantified.  

Translation of Residue Data

As previously stated, because residues must be assumed for all possible
crops in the 

USA, residues have been widely translated between crops both inside and
outside of crop groups because only a few more representative crops were
tested in the field trials.  The data for each of the tested crops was
very limited as well.  The limited crop processing data have also been
extrapolated to other crops.  Although it is certainly possible to
question individual translations, and values for each crop are
uncertain, it is believed that, when averaged over the total, the
results are less uncertain because there is a fairly large amount of
reasonably consistent data overall.  Therefore, these translations
should provide reasonable but conservative estimates of the chronic
exposure to residues.

Processing Factors

As also previously stated, the limited processing data from these
studies were translated to the important processed commodities of all
crops.  Where data was not available, DEEM default factors were used if
they were available.  For processed commodities where even DEEM default
factors were not available, the factors were generally set to 1. 
Attachment 5 shows the processing factors that were used and how they
were translated between crop commodities.  No washing, peeling or
cooking data were available and none were incorporated into this
assessment.  

Adequacy of %CT data

There is no way to establish ordinary percent crop treated values for
this use.  In lieu of that information BEAD has provided percent of the
harvested crop that has been irrigated, assuming that all irrigation
water is treated.  The assessment is conservative to the extent that
endothall will only be used on some irrigation canals some of the time. 
However, at this time it has not been possible to estimate the
proportion of canals that will be treated, and this new use does have
the potential to become extensive.   

Sensitivity Analyses

Experimental residues on all tree crops, except peaches, after overhead
irrigation were below the LOQ, albeit not below the LOD.  Because
overhead irrigation was used on the day of harvest it can be speculated
that the residues on peaches derive from retention of water by the peach
fuzz.  Since such overhead irrigation tree crops seems unlikely near
harvest, a sensitivity analysis was performed to determine what effect
an assumption of no residues on any tree crops would have on the
assessment.  Results showed the exposure for the general population to
be reduced to 31% of the cPAD; infants at 59%; children 1-2 at 77%;
children 3-5 at 60%.   

Because grapes are a driver of exposure, and because grapes are
ordinarily irrigated only by drip irrigation once they are fruiting, not
by overhead irrigation, it is possible that in addition to tree crops,
grape residues might be zero or near zero.  To characterize the possible
extent of this effect, a sensitivity analysis with grapes and all
fruiting tree crops set to zero was also performed.  This analysis puts
the exposure of the general population at 26% of the cPAD; infants at
51%; children 1-2 at 51%; and children 3-5 at 44%.  

Significant Risk Contributors ("Risk Drivers")

The most significant risk drivers for children are commodities from
grapes – table grapes, grape juice and raisins.  The largest
proportion of this exposure is from grape juice.  Exposure through
drinking water is very important for infants, and especially for
non-nursing infants.  Potential residues in milk were also a possible
driver of exposure for infants.  For older children, wheat, oats,
strawberries and pineapple juice become notable sources of potential
residues.  Pineapples are not grown in the continental U.S., but the use
was retained in this exposure assessment to avoid unnecessarily limiting
the potential use of endothall.  (Note also that residues were not
measured on pineapples.  These residues were translated from cucurbits.)
 Many other tropical fruits are also grown in the continental U.S. to
only a very limited extent, but were retained in the assessment because
small acreages of many of these crops are grown along the southernmost
regions and so could not be removed.  Thus this assessment also does not
assume that use will be restricted from any of the tropical islands of
the U.S.

  

Additional Information for Risk Managers

Once endothall has moved into a relatively stabilized usage, if usage
can be recorded as best as possible with regard to actual percentage of
the various crops irrigated with endothall containing water, usages at
or near harvest, etcetera, any new exposure estimate will be greatly
improved.  Likewise, if actual endothall residues on various crops can
be monitored, this will definitely improve later exposure assessment. 
In particular, monitoring of drinking water, of grapes and grape
products, and of milk would be especially valuable.

VIII.	Conclusions

HED has no toxic endpoints for acute or cancer exposures to endothall. 
In a conservative chronic DEEM assessment, it has been shown that
exposures to endothall from use on irrigation canals are below the cPAD,
HED’s level of concern, for the general U.S. population and for all of
its subgroups.  The general U.S. population is estimated to be exposed
at not more than 32 % of the cPAD.  The most highly exposed population
subgroup is children 1 – 2, who may be exposed at not more than 84% of
the cPAD 

The uncertainty and conservativeness of these estimates cannot be
quantified, but can be qualitatively characterized in some detail as
discussed above.  The assessment is conservative on many counts and
actual exposures are expected to be below those calculated.  However,
although the various factors discussed are expected to be conservative,
OPP has no way to quantify the extent to which they are conservative,
individually or combined.

List of Attachments

Chronic Food Plus Water Residue Input file.

 Chronic Results files:  Food Only, Water Only, Food Plus Water

 Results Files for Sensitivity Analyses:  All Tree Crops Set to Zero,
All Grapes Set to Zero

Residues in Field Trials

Processing Study results

Dietary Burden Calculations

Percent Crop Treated Memo from BEAD

Water Residues Memo from EFED 

cc:	David Soderberg (22 October 2009); Jack Arthur (22 October 2009);
David Hrdy (22 October 2009); Debra Rate (22 October 2009).

 

Attachment 1.  Chronic Food Plus Water Input File

U.S. Environmental Protection Agency                                
Ver. 2.00

DEEM-FCID Chronic analysis for ENDOTHALL                         
1994-98 data

Residue file: C:\Documents and Settings\dsoderbe\My
Documents\Endo2newDE\endothallreverseO19CTlastIhope.R98

                                                               Adjust.
#2 used

Analysis Date 10-21-2009             Residue file dated:
10-20-2009/15:32:24/8

Reference dose (RfD) = 0.007 mg/kg bw/day

------------------------------------------------------------------------
--------

Food Crop                                       Residue      
Adj.Factors      Comment

EPA Code  Grp  Food Name                          (ppm)       

                                                             #1        
#2 

-------- ---- -------------------------------   ---------- ------    
------   -------

95000010 O    Acerola                            0.041000   1.000     
1.000   from a

  Full comment: from apples

18000020 18   Alfalfa, seed                      0.110000   1.000     
0.920   

14000030 14   Almond                             0.031000   1.000     
1.000   almond

  Full comment: almond field trial

14000031 14   Almond-babyfood                    0.031000   1.000     
1.000   almond

  Full comment: almond field trial

14000040 14   Almond, oil                        0.031000   0.005     
1.000   soy oi

  Full comment: soy oil factor

14000041 14   Almond, oil-babyfood               0.031000   0.005     
1.000   soy oi

  Full comment: soy oil factor

04010050 4A   Amaranth, leafy                    0.710000   1.000     
1.000   

95000060 O    Amaranth, grain                    0.710000   1.000     
1.000   from w

  Full comment: from wheat grain

11000070 11   Apple, fruit with peel             0.041000   1.000     
0.780   

11000080 11   Apple, peeled fruit                0.041000   1.000     
0.780   

11000081 11   Apple, peeled fruit-babyfood       0.041000   1.000     
0.780   

11000090 11   Apple, dried                       0.041000   8.000     
0.440   

11000091 11   Apple, dried-babyfood              0.041000   8.000     
0.440   

11000100 11   Apple, juice                       0.041000   1.200     
0.490   juice 

  Full comment: juice factor

11000101 11   Apple, juice-babyfood              0.041000   1.200     
0.490   juice 

  Full comment: juice factor

11000110 11   Apple, sauce                       0.041000   1.000     
0.140   

11000111 11   Apple, sauce-babyfood              0.041000   1.000     
0.140   

12000120 12   Apricot                            0.098000   1.000     
1.000   

12000121 12   Apricot-babyfood                   0.098000   1.000     
1.000   

12000130 12   Apricot, dried                     0.098000   6.000     
1.000   DEEM d

  Full comment: DEEM default proc factor

12000140 12   Apricot, juice                     0.098000   1.000     
1.000   

12000141 12   Apricot, juice-babyfood            0.098000   1.000     
1.000   

01030150 1CD  Arrowroot, flour                   0.330000   6.500     
1.000   PF fro

  Full comment: PF from potato

01030151 1CD  Arrowroot, flour-babyfood          0.330000   6.500     
1.000   PF fro

  Full comment: PF from potato

95000160 O    Artichoke, globe                   0.710000   1.000     
1.000   from l

  Full comment: from leafy greens

01030170 1CD  Artichoke, Jerusalem               0.330000   1.000     
1.000   

04010180 4A   Arugula                            0.710000   1.000     
1.000   

95000190 O    Asparagus                          0.320000   1.000     
1.000   from h

  Full comment: from head lettuce

95000200 O    Avocado                            0.041000   1.000     
1.000   from a

  Full comment: from apples

09020210 9B   Balsam pear                        0.500000   1.000     
1.000   

95000220 O    Bamboo, shoots                     2.200000   1.000     
1.000   from g

  Full comment: from grass

95000230 O    Banana                             0.041000   1.000     
1.000   from a

  Full comment: from apples

95000231 O    Banana-babyfood                    0.041000   1.000     
1.000   from a

  Full comment: from apples

95000240 O    Banana, dried                      0.041000   3.900     
1.000   from a

  Full comment: from apples

95000241 O    Banana, dried-babyfood             0.041000   3.900     
1.000   from a

  Full comment: from apples

15000250 15   Barley, pearled barley             0.710000   1.000     
0.360   from w

  Full comment: from wheat

15000251 15   Barley, pearled barley-babyfood    0.710000   1.000     
0.360   from w

  Full comment: from wheat

15000260 15   Barley, flour                      0.710000   1.000     
0.360   from w

  Full comment: from wheat

15000261 15   Barley, flour-babyfood             0.710000   1.000     
0.360   from w

  Full comment: from wheat

15000270 15   Barley, bran                       0.710000   2.300     
0.360   wheat 

  Full comment: wheat and rice bran factor

19010280 19A  Basil, fresh leaves                2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

19010281 19A  Basil, fresh leaves-babyfood       2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

19010290 19A  Basil, dried leaves                2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

19010291 19A  Basil, dried leaves-babyfood       2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

06030300 6C   Bean, black, seed                  0.110000   1.000     
0.320   

06020310 6B   Bean, broad, succulent             0.390000   1.000     
1.000   

06030320 6C   Bean, broad, seed                  0.110000   1.000     
0.320   

06020330 6B   Bean, cowpea, succulent            0.390000   1.000     
1.000   

06030340 6C   Bean, cowpea, seed                 0.110000   1.000     
0.320   

06030350 6C   Bean,  great northern, seed        0.110000   1.000     
0.320   

06030360 6C   Bean, kidney, seed                 0.110000   1.000     
0.320   

06020370 6B   Bean, lima, succulent              0.390000   1.000     
1.000   

06030380 6C   Bean, lima, seed                   0.110000   1.000     
1.000   

06030390 6C   Bean, mung, seed                   0.110000   1.000     
0.320   

06030400 6C   Bean, navy, seed                   0.110000   1.000     
0.320   

06030410 6C   Bean, pink, seed                   0.110000   1.000     
0.320   

06030420 6C   Bean, pinto, seed                  0.110000   1.000     
0.320   

06010430 6A   Bean, snap, succulent              0.390000   1.000     
1.000   

06010431 6A   Bean, snap, succulent-babyfood     0.390000   1.000     
1.000   

21000440 M    Beef, meat                         0.002500   1.000     
1.000   from d

  Full comment: from dairy cattle

21000441 M    Beef, meat-babyfood                0.002500   1.000     
1.000   from d

  Full comment: from dairy cattle

21000450 M    Beef, meat, dried                  0.002500   1.920     
1.000   from d

  Full comment: from dairy cattle

21000460 M    Beef, meat byproducts              0.023000   1.000     
1.000   from d

  Full comment: from dairy cattle

21000461 M    Beef, meat byproducts-babyfood     0.023000   1.000     
1.000   from d

  Full comment: from dairy cattle

21000470 M    Beef, fat                          0.001000   1.000     
1.000   from d

  Full comment: from dairy cattle

21000471 M    Beef,fat-babyfood                  0.001000   1.000     
1.000   from d

  Full comment: from dairy cattle

21000480 M    Beef, kidney                       0.023000   1.000     
1.000   from d

  Full comment: from dairy cattle

21000490 M    Beef, liver                        0.010000   1.000     
1.000   from d

  Full comment: from dairy cattle

21000491 M    Beef, liver-babyfood               0.010000   1.000     
1.000   from d

  Full comment: from dairy cattle

01010500 1AB  Beet, garden, roots                0.330000   1.000     
1.000   

01010501 1AB  Beet, garden, roots-babyfood       0.330000   1.000     
1.000   

02000510 2    Beet, garden, tops                 1.300000   1.000     
1.000   

01010530 1A   Beet, sugar, molasses              0.330000   2.400     
0.370   

01010531 1A   Beet, sugar, molasses-babyfood     0.330000   2.400     
0.370   

95000540 O    Belgium endive                     0.320000   1.000     
1.000   from h

  Full comment: from head lettuce

13010550 13A  Blackberry                         0.330000   1.000     
1.000   

13010560 13A  Blackberry, juice                  0.330000   1.000     
1.000   

13010561 13A  Blackberry, juice-babyfood         0.330000   1.000     
1.000   

13020570 13B  Blueberry                          0.180000   1.000     
1.000   

13020571 13B  Blueberry-babyfood                 0.180000   1.000     
1.000   

13010580 13A  Boysenberry                        0.330000   1.000     
1.000   

14000590 14   Brazil nut                         0.031000   1.000     
1.000   almond

  Full comment: almond field trial

95000600 O    Breadfruit                         0.041000   1.000     
1.000   from a

  Full comment: from apples

05010610 5A   Broccoli                           0.060000   1.000     
1.000   from c

  Full comment: from cabbage

05010611 5A   Broccoli-babyfood                  0.060000   1.000     
1.000   from c

  Full comment: from cabbage

05010620 5A   Broccoli, Chinese                  0.060000   1.000     
1.000   from c

  Full comment: from cabbage

05020630 5B   Broccoli raab                      0.710000   1.000     
1.000   from l

  Full comment: from leaf lettuce

05010640 5A   Brussels sprouts                   0.060000   1.000     
1.000   from c

  Full comment: from cabbage

15000650 15   Buckwheat                          0.710000   1.000     
1.000   from w

  Full comment: from wheat

15000660 15   Buckwheat, flour                   0.710000   0.600     
1.000   from w

  Full comment: from wheat and wheat flour

01010670 1AB  Burdock                            0.330000   1.000     
1.000   

14000680 14   Butternut                          0.031000   1.000     
1.000   almond

  Full comment: almond field trial

05010690 5A   Cabbage                            0.060000   1.000     
1.000   

05020700 5B   Cabbage, Chinese, bok choy         0.710000   1.000     
1.000   from l

  Full comment: from leaf lettuce

05010710 5A   Cabbage, Chinese, napa             0.060000   1.000     
1.000   from c

  Full comment: from cabbage

05010720 5A   Cabbage, Chinese, mustard          0.060000   1.000     
1.000   from c

  Full comment: from cabbage

95000730 O    Cactus                             0.710000   1.000     
1.000   from l

  Full comment: from leafy greens

95000740 O    Canistel                           0.041000   1.000     
1.000   from a

  Full comment: from apples

09010750 9A   Cantaloupe                         0.500000   1.000     
1.000   

04020760 4B   Cardoon                            0.710000   1.000     
1.000   

95000770 O    Carob                              0.041000   1.000     
1.000   from a

  Full comment: from apples

01010780 1AB  Carrot                             0.080000   1.000     
1.000   

01010781 1AB  Carrot-babyfood                    0.080000   1.000     
1.000   

01010790 1AB  Carrot, juice                      0.080000   1.000     
1.000   

09010800 9A   Casaba                             0.500000   1.000     
1.000   

14000810 14   Cashew                             0.031000   1.000     
1.000   almond

  Full comment: almond field trial

01030820 1CD  Cassava                            0.330000   1.000     
1.000   

01030821 1CD  Cassava-babyfood                   0.330000   1.000     
1.000   

05010830 5A   Cauliflower                        0.060000   1.000     
1.000   from c

  Full comment: from cabbage

01010840 1AB  Celeriac                           0.330000   1.000     
1.000   

04020850 4B   Celery                             0.320000   1.000     
1.000   from h

  Full comment: from head lettuce

04020851 4B   Celery-babyfood                    0.320000   1.000     
1.000   from h

  Full comment: from head lettuce

04020860 4B   Celery, juice                      0.320000   1.000     
1.000   from h

  Full comment: from head lettuce

04020870 4B   Celtuce                            0.710000   1.000     
1.000   

09020880 9B   Chayote, fruit                     0.500000   1.000     
1.000   

95000890 O    Cherimoya                          0.041000   1.000     
1.000   from a

  Full comment: from apples

12000900 12   Cherry                             0.098000   1.000     
1.000   

12000901 12   Cherry-babyfood                    0.098000   1.000     
1.000   

12000910 12   Cherry, juice                      0.098000   1.500     
1.000   

12000911 12   Cherry, juice-babyfood             0.098000   1.500     
1.000   

14000920 14   Chestnut                           0.031000   1.000     
1.000   almond

  Full comment: almond field trial

40000930 P    Chicken, meat                      0.001000   1.000     
1.000   

40000931 P    Chicken, meat-babyfood             0.001000   1.000     
1.000   

40000940 P    Chicken, liver                     0.003000   1.000     
1.000   

40000950 P    Chicken, meat byproducts           0.014000   1.000     
1.000   

40000951 P    Chicken, meat byproducts-babyfoo   0.014000   1.000     
1.000   

40000960 P    Chicken, fat                       0.001000   1.000     
1.000   

40000961 P    Chicken, fat-babyfood              0.001000   1.000     
1.000   

40000970 P    Chicken, skin                      0.014000   1.000     
1.000   

40000971 P    Chicken, skin-babyfood             0.014000   1.000     
1.000   

06030980 6C   Chickpea, seed                     0.110000   1.000     
0.320   

06030981 6C   Chickpea, seed-babyfood            0.110000   1.000     
0.320   

06030990 6C   Chickpea, flour                    0.110000   1.000     
0.320   

01011000 1AB  Chicory, roots                     0.330000   1.000     
1.000   

02001010 2    Chicory, tops                      1.300000   1.000     
1.000   

09021020 9B   Chinese waxgourd                   0.500000   1.000     
1.000   

19011030 19A  Chive                              2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

04011040 4A   Chrysanthemum, garland             0.710000   1.000     
1.000   

19021050 19B  Cinnamon                           2.140000   1.000     
1.000   from m

  Full comment: from mint

19021051 19B  Cinnamon-babyfood                  2.140000   1.000     
1.000   from m

  Full comment: from mint

10001060 10   Citrus citron                      0.024000   1.000     
1.000   

10001070 10   Citrus hybrids                     0.024000   1.000     
1.000   

10001080 10   Citrus, oil                        0.024000   0.200     
1.000   citrus

  Full comment: citrus oil factor

95001090 O    Cocoa bean, chocolate              0.041000   1.000     
1.000   from a

  Full comment: from apples

95001100 O    Cocoa bean, powder                 0.041000   1.000     
1.000   from a

  Full comment: from apples

95001110 O    Coconut, meat                      0.041000   1.000     
1.000   from a

  Full comment: from apples

95001111 O    Coconut- meat-babyfood             0.041000   1.000     
1.000   from a

  Full comment: from apples

95001120 O    Coconut, dried                     0.041000   2.100     
1.000   from a

  Full comment: from apples

95001130 O    Coconut, milk                      0.041000   1.000     
1.000   from a

  Full comment: from apples

95001140 O    Coconut, oil                       0.041000   0.005     
1.000   from a

  Full comment: from apples and soy oil factor

95001141 O    Coconut, oil-babyfood              0.041000   0.005     
1.000   from a

  Full comment: from apples and soy oil factor

95001150 O    Coffee, roasted bean               0.041000   1.000     
1.000   from a

  Full comment: from apples

95001160 O    Coffee, instant                    0.041000   1.000     
1.000   from a

  Full comment: from apples

05021170 5B   Collards                           0.710000   1.000     
1.000   from l

  Full comment: from leaf lettuce

19011180 19A  Coriander, leaves                  2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

19011181 19A  Coriander, leaves-babyfood         2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

19021190 19B  Coriander, seed                    2.140000   1.000     
1.000   from m

  Full comment: from mint

19021191 19B  Coriander, seed-babyfood           2.140000   1.000     
1.000   from m

  Full comment: from mint

15001200 15   Corn, field, flour                 0.050000   1.000     
0.190   corn f

  Full comment: corn flour 1x

15001201 15   Corn, field, flour-babyfood        0.050000   1.000     
0.190   corn f

  Full comment: corn flour 1x

15001210 15   Corn, field, meal                  0.050000   1.000     
0.190   corn m

  Full comment: corn meal 1x

15001211 15   Corn, field, meal-babyfood         0.050000   1.000     
0.190   corn m

  Full comment: corn meal 1x

15001220 15   Corn, field, bran                  0.050000   2.300     
0.190   wheat 

  Full comment: wheat and rice bran factor

15001230 15   Corn, field, starch                0.050000   1.000     
0.190   corn s

  Full comment: corn starch 1x

15001231 15   Corn, field, starch-babyfood       0.050000   1.000     
0.190   corn s

  Full comment: corn starch 1x

15001240 15   Corn, field, syrup                 0.050000   1.500     
0.190   corn s

  Full comment: corn starch 1x

15001241 15   Corn, field, syrup-babyfood        0.050000   1.500     
0.190   corn s

  Full comment: corn starch 1x

15001250 15   Corn, field, oil                   0.050000   1.000     
0.190   corn o

  Full comment: corn oil 1x

15001251 15   Corn, field, oil-babyfood          0.050000   1.000     
0.190   corn o

  Full comment: corn oil 1x

15001260 15   Corn, pop                          0.050000   1.000     
0.190   

15001270 15   Corn, sweet                        0.110000   1.000     
1.000   

15001271 15   Corn, sweet-babyfood               0.110000   1.000     
1.000   

95001280 O    Cottonseed, oil                    0.100000   0.005     
1.000   soy oi

  Full comment: soy oil factor

95001281 O    Cottonseed, oil-babyfood           0.100000   0.005     
1.000   soy oi

  Full comment: soy oil factor

11001290 11   Crabapple                          0.041000   1.000     
1.000   

95001300 O    Cranberry                          0.330000   1.000     
1.000   from c

  Full comment: from cane berries

95001301 O    Cranberry-babyfood                 0.330000   1.000     
1.000   from c

  Full comment: from cane berries

95001310 O    Cranberry, dried                   0.330000   1.000     
1.000   from c

  Full comment: from cane berries

95001320 O    Cranberry, juice                   0.330000   1.100     
1.000   from c

  Full comment: from cane berries

95001321 O    Cranberry, juice-babyfood          0.330000   1.100     
1.000   from c

  Full comment: from cane berries

04011330 4A   Cress, garden                      0.710000   1.000     
1.000   

04011340 4A   Cress, upland                      0.710000   1.000     
1.000   

09021350 9B   Cucumber                           0.500000   1.000     
1.000   

13021360 13B  Currant                            0.180000   1.000     
1.000   

13021370 13B  Currant, dried                     0.180000   1.000     
1.000   

04011380 4A   Dandelion, leaves                  0.710000   1.000     
1.000   

01031390 1CD  Dasheen, corm                      0.330000   1.000     
1.000   

02001400 2    Dasheen, leaves                    1.300000   1.000     
1.000   

95001410 O    Date                               0.041000   1.000     
1.000   from a

  Full comment: from apples

13011420 13A  Dewberry                           0.330000   1.000     
1.000   

19021430 19B  Dill, seed                         2.140000   1.000     
1.000   from m

  Full comment: from mint

19011440 19A  Dillweed                           2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

70001450 P    Egg, whole                         0.003700   1.000     
1.000   

70001451 P    Egg, whole-babyfood                0.003700   1.000     
1.000   

70001460 P    Egg, white                         0.000300   1.000     
1.000   

70001461 P    Egg, white (solids)-babyfood       0.000300   1.000     
1.000   

70001470 P    Egg, yolk                          0.003700   1.000     
1.000   

70001471 P    Egg, yolk-babyfood                 0.003700   1.000     
1.000   

08001480 8    Eggplant                           0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

13021490 13B  Elderberry                         0.180000   1.000     
1.000   

04011500 4A   Endive                             0.320000   1.000     
1.000   from h

  Full comment: from head lettuce

95001510 O    Feijoa                             0.041000   1.000     
1.000   from a

  Full comment: from apples

04021520 4B   Fennel, Florence                   0.710000   1.000     
1.000   

95001530 O    Fig                                0.041000   1.000     
1.000   from a

  Full comment: from apples

95001540 O    Fig, dried                         0.041000   1.000     
1.000   from a

  Full comment: from apples

14001550 14   Filbert                            0.031000   1.000     
1.000   almond

  Full comment: almond field trial

14001560 14   Filbert, oil                       0.031000   0.005     
1.000   soy oi

  Full comment: soy oil factor

80001570 F    Fish-freshwater finfish            0.100000   1.000     
1.000   

80001580 F    Fish-freshwater finfish, farm ra   0.100000   1.000     
1.000   

80001610 F    Fish-shellfish, crustacean         1.000000   1.000     
1.000   

80001620 F    Fish-shellfish, mollusc            4.000000   1.000     
1.000   

20001630 20   Flaxseed, oil                      0.034000   0.005     
1.000   from s

  Full comment: from soybeans +soy oil factor

03001640 3    Garlic                             0.050000   1.000     
1.000   

03001650 3    Garlic, dried                      0.050000   1.000     
1.000   

03001651 3    Garlic, dried-babyfood             0.050000   1.000     
1.000   

01031660 1CD  Ginger                             0.330000   1.000     
1.000   

01031661 1CD  Ginger-babyfood                    0.330000   1.000     
1.000   

01031670 1CD  Ginger, dried                      0.330000   1.000     
1.000   

01011680 1AB  Ginseng, dried                     0.330000   1.000     
1.000   

23001690 M    Goat, meat                         0.001500   1.000     
1.000   from b

  Full comment: from beef cattle

23001700 M    Goat, meat byproducts              0.001500   1.000     
1.000   from b

  Full comment: from beef cattle

23001710 M    Goat, fat                          0.000600   1.000     
1.000   from b

  Full comment: from beef cattle

23001720 M    Goat, kidney                       0.014000   1.000     
1.000   from b

  Full comment: from beef cattle

23001730 M    Goat, liver                        0.006000   1.000     
1.000   from b

  Full comment: from beef cattle

13021740 13B  Gooseberry                         0.180000   1.000     
1.000   

95001750 O    Grape                              0.520000   1.000     
0.990   

95001760 O    Grape, juice                       0.520000   1.200     
0.940   maximu

  Full comment: maximum conc factor

95001761 O    Grape, juice-babyfood              0.520000   1.200     
0.940   maximu

  Full comment: maximum conc factor

95001770 O    Grape, leaves                      0.520000   1.000     
0.990   

95001780 O    Grape, raisin                      0.520000   4.400     
0.940   

95001790 O    Grape, wine and sherry             0.520000   1.000     
0.940   

10001800 10   Grapefruit                         0.024000   1.000     
1.000   

10001810 10   Grapefruit, juice                  0.024000   0.820     
1.000   adjust

  Full comment: adjusted OJ factor

06031820 6C   Guar, seed                         0.110000   2.100     
0.320   

06031821 6C   Guar, seed-babyfood                0.110000   2.100     
0.320   

95001830 O    Guava                              0.041000   1.000     
1.000   from a

  Full comment: from apples

95001831 O    Guava-babyfood                     0.041000   1.000     
1.000   from a

  Full comment: from apples

19011840 19A  Herbs, other                       2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

19011841 19A  Herbs, other-babyfood              2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

14001850 14   Hickory nut                        0.031000   1.000     
1.000   almond

  Full comment: almond field trial

95001860 O    Honey                              0.003000   1.000     
1.000   from m

  Full comment: from milk

95001861 O    Honey-babyfood                     0.003000   1.000     
1.000   from m

  Full comment: from milk

09011870 9A   Honeydew melon                     0.500000   1.000     
1.000   

95001880 O    Hop                                0.100000   1.000     
1.000   

24001890 M    Horse, meat                        0.001500   1.000     
1.000   from b

  Full comment: from beef cattle

01011900 1AB  Horseradish                        0.330000   1.000     
1.000   

13021910 13B  Huckleberry                        0.180000   1.000     
1.000   

95001920 O    Jaboticaba                         0.041000   1.000     
1.000   from a

  Full comment: from apples

95001930 O    Jackfruit                          0.041000   1.000     
1.000   from a

  Full comment: from apples

05021940 5B   Kale                               0.710000   1.000     
1.000   from l

  Full comment: from leaf lettuce

95001950 O    Kiwifruit                          0.520000   1.000     
1.000   from g

  Full comment: from grapes

05011960 5A   Kohlrabi                           0.060000   1.000     
1.000   from c

  Full comment: from cabbage

10001970 10   Kumquat                            0.024000   1.000     
1.000   

03001980 3    Leek                               0.260000   1.000     
1.000   from g

  Full comment: from green onion

10001990 10   Lemon                              0.024000   1.000     
1.000   

10002000 10   Lemon, juice                       0.024000   0.780     
1.000   adjust

  Full comment: adjusted OJ factor

10002001 10   Lemon, juice-babyfood              0.024000   0.780     
1.000   adjust

  Full comment: adjusted OJ factor

10002010 10   Lemon, peel                        0.024000   2.200     
1.000   dried 

  Full comment: dried pulp factor

19012020 19A  Lemongrass                         2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

06032030 6C   Lentil, seed                       0.110000   1.000     
1.000   

04012040 4A   Lettuce, head                      0.320000   1.000     
1.000   from h

  Full comment: from head lettuce

04012050 4A   Lettuce, leaf                      0.710000   1.000     
1.000   

10002060 10   Lime                               0.024000   1.000     
1.000   

10002070 10   Lime, juice                        0.024000   0.780     
1.000   adjust

  Full comment: adjusted OJ factor

10002071 10   Lime, juice-babyfood               0.024000   0.780     
1.000   adjust

  Full comment: adjusted OJ factor

13012080 13A  Loganberry                         0.330000   1.000     
1.000   

95002090 O    Longan                             0.041000   1.000     
1.000   from a

  Full comment: from apples

11002100 11   Loquat                             0.041000   1.000     
1.000   

95002110 O    Lychee                             0.041000   1.000     
1.000   from a

  Full comment: from apples

95002120 O    Lychee, dried                      0.041000   1.850     
1.000   from a

  Full comment: from apples

14002130 14   Macadamia nut                      0.031000   1.000     
1.000   almond

  Full comment: almond field trial

95002140 O    Mamey apple                        0.041000   1.000     
1.000   from a

  Full comment: from apples

95002150 O    Mango                              0.041000   1.000     
1.000   from a

  Full comment: from apples

95002151 O    Mango-babyfood                     0.041000   1.000     
1.000   from a

  Full comment: from apples

95002160 O    Mango, dried                       0.041000   1.000     
1.000   from a

  Full comment: from apples

95002170 O    Mango, juice                       0.041000   1.000     
1.000   from a

  Full comment: from apples

95002171 O    Mango, juice-babyfood              0.041000   1.000     
1.000   from a

  Full comment: from apples

95002180 O    Maple, sugar                       0.041000   1.000     
1.000   from a

  Full comment: from apples

95002190 O    Maple syrup                        0.041000   1.000     
1.000   from a

  Full comment: from apples

19012200 19A  Marjoram                           2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

19012201 19A  Marjoram-babyfood                  2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

28002210 M    Meat, game                         0.001500   1.000     
1.000   from b

  Full comment: from beef cattle

27002220 D    Milk, fat                          0.003000   1.000     
1.000   

27002221 D    Milk, fat - baby food/infant for   0.003000   1.000     
1.000   

27012230 D    Milk, nonfat solids                0.003000   1.000     
1.000   

27012231 D    Milk, nonfat solids-baby food/in   0.003000   1.000     
1.000   

27022240 D    Milk, water                        0.003000   1.000     
1.000   

27022241 D    Milk, water-babyfood/infant form   0.003000   1.000     
1.000   

27032251 D    Milk, sugar (lactose)-baby food/   0.003000   1.000     
1.000   

15002260 15   Millet, grain                      0.710000   1.000     
1.000   from w

  Full comment: from wheat

95002270 O    Mulberry                           0.041000   1.000     
1.000   from a

  Full comment: from apples

95002280 O    Mushroom                           0.710000   1.000     
1.000   from l

  Full comment: from leafy greens

05022290 5B   Mustard greens                     0.710000   1.000     
1.000   from l

  Full comment: from leaf lettuce

12002300 12   Nectarine                          0.098000   1.000     
1.000   

15002310 15   Oat, bran                          0.710000   2.300     
0.070   wheat 

  Full comment: wheat and rice bran factor

15002320 15   Oat, flour                         0.710000   1.000     
0.070   from w

  Full comment: from wheat

15002321 15   Oat, flour-babyfood                0.710000   1.000     
0.070   from w

  Full comment: from wheat

15002330 15   Oat, groats/rolled oats            0.710000   1.000     
0.070   from w

  Full comment: from wheat

15002331 15   Oat, groats/rolled oats-babyfood   0.710000   1.000     
0.070   from w

  Full comment: from wheat

08002340 8    Okra                               0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

95002350 O    Olive                              0.041000   1.000     
1.000   from a

  Full comment: from apples

95002360 O    Olive, oil                         0.041000   0.005     
1.000   from a

  Full comment: from apples +soy oil factor

03002370 3    Onion, dry bulb                    0.050000   1.000     
1.000   

03002371 3    Onion, dry bulb-babyfood           0.050000   1.000     
1.000   

03002380 3    Onion, dry bulb, dried             0.050000   9.000     
1.000   

03002381 3    Onion, dry bulb, dried-babyfood    0.050000   9.000     
1.000   

03002390 3    Onion, green                       0.260000   1.000     
1.000   

10002400 10   Orange                             0.024000   1.000     
1.000   

10002410 10   Orange, juice                      0.024000   0.700     
1.000   O J fa

  Full comment: O J factor

10002411 10   Orange, juice-babyfood             0.024000   0.700     
1.000   O J fa

  Full comment: O J factor

10002420 10   Orange, peel                       0.024000   2.200     
1.000   dried 

  Full comment: dried pulp factor

95002430 O    Palm heart, leaves                 2.200000   1.000     
1.000   from g

  Full comment: from grass

95002440 O    Palm, oil                          2.200000   0.005     
1.000   from g

  Full comment: from grass + soy oil factor

95002441 O    Palm, oil-babyfood                 2.200000   0.005     
1.000   from g

  Full comment: from grass + soy oil factor

95002450 O    Papaya                             0.041000   1.000     
1.000   from a

  Full comment: from apples

95002451 O    Papaya-babyfood                    0.041000   1.000     
1.000   from a

  Full comment: from apples

95002460 O    Papaya, dried                      0.041000   1.800     
1.000   from a

  Full comment: from apples

95002470 O    Papaya, juice                      0.041000   1.500     
1.000   from a

  Full comment: from apples

04012480 4A   Parsley, leaves                    0.710000   1.000     
1.000   

19012490 19A  Parsley, dried leaves              2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

19012491 19A  Parsley, dried leaves-babyfood     2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

01012500 1AB  Parsley, turnip rooted             0.330000   1.000     
1.000   

01012510 1AB  Parsnip                            0.330000   1.000     
1.000   

01012511 1AB  Parsnip-babyfood                   0.330000   1.000     
1.000   

95002520 O    Passionfruit                       0.041000   1.000     
1.000   from a

  Full comment: from apples

95002521 O    Passionfruit-babyfood              0.041000   1.000     
1.000   from a

  Full comment: from apples

95002530 O    Passionfruit, juice                0.041000   1.000     
1.000   from a

  Full comment: from apples

95002531 O    Passionfruit, juice-babyfood       0.041000   1.000     
1.000   from a

  Full comment: from apples

95002540 O    Pawpaw                             0.041000   1.000     
1.000   from a

  Full comment: from apples

06022550 6B   Pea, succulent                     0.730000   1.000     
0.110   

06022551 6B   Pea, succulent-babyfood            0.730000   1.000     
0.110   

06032560 6C   Pea, dry                           0.110000   1.000     
1.000   

06032561 6C   Pea, dry-babyfood                  0.110000   1.000     
1.000   

06012570 6A   Pea, edible podded, succulent      0.730000   1.000     
1.000   

06032580 6C   Pea, pigeon, seed                  0.110000   1.000     
1.000   

06022590 6B   Pea, pigeon, succulent             0.390000   1.000     
0.110   

12002600 12   Peach                              0.098000   1.000     
1.000   

12002601 12   Peach-babyfood                     0.098000   1.000     
1.000   

12002610 12   Peach, dried                       0.098000   7.000     
1.000   

12002611 12   Peach, dried-babyfood              0.098000   7.000     
1.000   

12002620 12   Peach, juice                       0.098000   1.000     
1.000   

12002621 12   Peach, juice-babyfood              0.098000   1.000     
1.000   

95002630 O    Peanut                             0.080000   1.000     
0.420   from p

  Full comment: from potato

95002640 O    Peanut, butter                     0.080000   1.890     
0.420   from p

  Full comment: from potato

95002650 O    Peanut, oil                        0.080000   0.005     
0.420   from p

  Full comment: from potato + soy oil factor

11002660 11   Pear                               0.041000   1.000     
1.000   

11002661 11   Pear-babyfood                      0.041000   1.000     
1.000   

11002670 11   Pear, dried                        0.041000   6.250     
1.000   DEEM d

  Full comment: DEEM default proc factor

11002680 11   Pear, juice                        0.041000   1.200     
1.000   

11002681 11   Pear, juice-babyfood               0.041000   1.200     
1.000   

14002690 14   Pecan                              0.024000   1.000     
1.000   pecan 

  Full comment: pecan field trial

08002700 8    Pepper, bell                       0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

08002701 8    Pepper, bell-babyfood              0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

08002710 8    Pepper, bell, dried                0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

08002711 8    Pepper, bell, dried-babyfood       0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

08002720 8    Pepper, nonbell                    0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

08002721 8    Pepper, nonbell-babyfood           0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

08002730 8    Pepper, nonbell, dried             0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

19022740 19B  Pepper, black and white            2.140000   1.000     
1.000   from m

  Full comment: from mint

19022741 19B  Pepper, black and white-babyfood   2.140000   1.000     
1.000   from m

  Full comment: from mint

95002750 O    Peppermint                         2.140000   1.000     
1.000   

95002760 O    Peppermint, oil                    2.140000   0.010     
1.000   

95002770 O    Persimmon                          0.041000   1.000     
1.000   from a

  Full comment: from apples

95002780 O    Pine nut                           0.041000   1.000     
1.000   from a

  Full comment: from apples

95002790 O    Pineapple                          0.500000   1.000     
1.000   from c

  Full comment: from cucurbits

95002791 O    Pineapple-babyfood                 0.500000   1.000     
1.000   from c

  Full comment: from cucurbits

95002800 O    Pineapple, dried                   0.500000   5.000     
1.000   from c

  Full comment: from cucurbits

95002810 O    Pineapple, juice                   0.500000   1.700     
1.000   from c

  Full comment: from cucurbits

95002811 O    Pineapple, juice-babyfood          0.500000   1.700     
1.000   from c

  Full comment: from cucurbits

14002820 14   Pistachio                          0.031000   1.000     
1.000   almond

  Full comment: almond field trial

95002830 O    Plantain                           0.041000   1.000     
1.000   from a

  Full comment: from apples

95002840 O    Plantain, dried                    0.041000   3.900     
1.000   from a

  Full comment: from apples

12002850 12   Plum                               0.098000   1.000     
1.000   

12002851 12   Plum-babyfood                      0.098000   1.000     
1.000   

12002860 12   Plum, prune, fresh                 0.098000   1.000     
1.000   

12002861 12   Plum, prune, fresh-babyfood        0.098000   1.000     
1.000   

12002870 12   Plum, prune, dried                 0.098000   5.000     
1.000   

12002871 12   Plum, prune, dried-babyfood        0.098000   5.000     
1.000   

12002880 12   Plum, prune, juice                 0.098000   1.400     
1.000   

12002881 12   Plum, prune, juice-babyfood        0.098000   1.400     
1.000   

95002890 O    Pomegranate                        0.041000   1.000     
1.000   from a

  Full comment: from apples

25002900 M    Pork, meat                         0.000700   1.000     
1.000   

25002901 M    Pork, meat-babyfood                0.000700   1.000     
1.000   

25002910 M    Pork, skin                         0.006500   1.000     
1.000   

25002920 M    Pork, meat byproducts              0.006500   1.000     
1.000   

25002921 M    Pork, meat byproducts-babyfood     0.006500   1.000     
1.000   

25002930 M    Pork, fat                          0.000300   1.000     
1.000   

25002931 M    Pork, fat-babyfood                 0.000300   1.000     
1.000   

25002940 M    Pork, kidney                       0.006500   1.000     
1.000   

25002950 M    Pork, liver                        0.002800   1.000     
1.000   

01032960 1C   Potato, chips                      0.080000   1.000     
1.000   

01032970 1C   Potato, dry (granules/ flakes)     0.080000   6.500     
1.000   

01032971 1C   Potato, dry (granules/ flakes)-b   0.080000   6.500     
1.000   

01032980 1C   Potato, flour                      0.080000   6.500     
1.000   

01032981 1C   Potato, flour-babyfood             0.080000   6.500     
1.000   

01032990 1C   Potato, tuber, w/peel              0.080000   1.000     
1.000   

01032991 1C   Potato, tuber, w/peel-babyfood     0.080000   1.000     
1.000   

01033000 1C   Potato, tuber, w/o peel            0.080000   1.000     
1.000   

01033001 1C   Potato, tuber, w/o peel-babyfood   0.080000   1.000     
1.000   

60003010 P    Poultry, other, meat               0.001000   1.000     
1.000   

60003020 P    Poultry, other, liver              0.003000   1.000     
1.000   

60003030 P    Poultry, other, meat byproducts    0.014000   1.000     
1.000   

60003040 P    Poultry, other, fat                0.001000   1.000     
1.000   

60003050 P    Poultry, other, skin               0.014000   1.000     
1.000   

95003060 O    Psyllium, seed                     0.710000   1.000     
1.000   from w

  Full comment: from wheat grain

10003070 10   Pummelo                            0.024000   1.000     
1.000   

09023080 9B   Pumpkin                            0.500000   1.000     
1.000   

09023090 9B   Pumpkin, seed                      0.500000   1.000     
1.000   

11003100 11   Quince                             0.041000   1.000     
1.000   

95003110 O    Quinoa, grain                      0.710000   1.000     
1.000   from w

  Full comment: from wheat grain

29003120 M    Rabbit, meat                       0.001500   1.000     
1.000   from b

  Full comment: from beef cattle

04013130 4A   Radicchio                          0.710000   1.000     
1.000   

01013140 1AB  Radish, roots                      0.330000   1.000     
1.000   

02003150 2    Radish, tops                       1.300000   1.000     
1.000   

01013160 1AB  Radish, Oriental, roots            0.330000   1.000     
1.000   

02003170 2    Radish, Oriental, tops             1.300000   1.000     
1.000   

05023180 5B   Rape greens                        0.710000   1.000     
1.000   from l

  Full comment: from leaf lettuce

20003190 20   Rapeseed, oil                      0.034000   0.005     
1.000   from s

  Full comment: from soybeans +soy oil factor

20003191 20   Rapeseed, oil-babyfood             0.034000   0.005     
1.000   from s

  Full comment: from soybeans +soy oil factor

13013200 13A  Raspberry                          0.330000   1.000     
1.000   

13013201 13A  Raspberry-babyfood                 0.330000   1.000     
1.000   

13013210 13A  Raspberry, juice                   0.330000   1.000     
1.000   

13013211 13A  Raspberry, juice-babyfood          0.330000   1.000     
1.000   

04023220 4B   Rhubarb                            0.320000   1.000     
1.000   from h

  Full comment: from head lettuce

15003230 15   Rice, white                        1.050000   0.100     
1.000   

15003231 15   Rice, white-babyfood               1.050000   0.100     
1.000   

15003240 15   Rice, brown                        1.050000   1.000     
1.000   

15003241 15   Rice, brown-babyfood               1.050000   1.000     
1.000   

15003250 15   Rice, flour                        1.050000   0.100     
1.000   

15003251 15   Rice, flour-babyfood               1.050000   0.100     
1.000   

15003260 15   Rice, bran                         1.050000   2.300     
1.000   

15003261 15   Rice, bran-babyfood                1.050000   2.300     
1.000   from w

  Full comment: from wheat

01013270 1AB  Rutabaga                           0.330000   1.000     
1.000   

15003280 15   Rye, grain                         0.710000   1.000     
1.000   from w

  Full comment: from wheat

15003290 15   Rye, flour                         0.710000   1.000     
1.000   from w

  Full comment: from wheat

20003300 20   Safflower, oil                     0.034000   0.005     
1.000   from s

  Full comment: from soybeans +soy oil factor

20003301 20   Safflower, oil-babyfood            0.034000   0.005     
1.000   from s

  Full comment: from soybeans +soy oil factor

01013310 1AB  Salsify, roots                     0.330000   1.000     
1.000   

02003320 2    Salsify, tops                      1.300000   1.000     
1.000   

95003330 O    Sapote, Mamey                      0.041000   1.000     
1.000   from a

  Full comment: from apples

19013340 19A  Savory                             2.140000   1.000     
1.000   from m

  Full comment: from mint per ChemSAC

95003360 O    Sesame, seed                       0.710000   1.000     
1.000   from w

  Full comment: from wheat grain

95003361 O    Sesame, seed-babyfood              0.710000   1.000     
1.000   from w

  Full comment: from wheat grain

95003370 O    Sesame, oil                        0.710000   0.005     
1.000   from w

  Full comment: from wheat grain + soy oil factor

95003371 O    Sesame, oil-babyfood               0.710000   0.005     
1.000   from w

  Full comment: from wheat grain + soy oil factor

03003380 3    Shallot                            0.050000   1.000     
1.000   

26003390 M    Sheep, meat                        0.001500   1.000     
1.000   from b

  Full comment: from beef cattle

26003391 M    Sheep, meat-babyfood               0.001500   1.000     
1.000   from b

  Full comment: from beef cattle

26003400 M    Sheep, meat byproducts             0.014000   1.000     
1.000   from b

  Full comment: from beef cattle

26003410 M    Sheep, fat                         0.000600   1.000     
1.000   from b

  Full comment: from beef cattle

26003411 M    Sheep, fat-babyfood                0.000600   1.000     
1.000   from b

  Full comment: from beef cattle

26003420 M    Sheep, kidney                      0.014000   1.000     
1.000   from b

  Full comment: from beef cattle

26003430 M    Sheep, liver                       0.006000   1.000     
1.000   from b

  Full comment: from beef cattle

15003440 15   Sorghum, grain                     1.000000   1.000     
0.150   from c

  Full comment: from corn

15003450 15   Sorghum, syrup                     1.000000   1.000     
1.000   from c

  Full comment: from corn

95003460 O    Soursop                            0.041000   1.000     
1.000   from a

  Full comment: from apples

06003470 6    Soybean, seed                      0.034000   1.000     
0.090   

06003480 6    Soybean, flour                     0.034000   1.000     
0.090   

06003481 6    Soybean, flour-babyfood            0.034000   1.000     
0.090   

06003490 6    Soybean, soy milk                  0.034000   1.000     
0.090   

06003491 6    Soybean, soy milk-babyfood or in   0.034000   1.000     
0.090   

06003500 6    Soybean, oil                       0.034000   0.005     
0.090   

06003501 6    Soybean, oil-babyfood              0.034000   0.005     
0.090   

95003510 O    Spanish lime                       0.041000   1.000     
1.000   from a

  Full comment: from apples

95003520 O    Spearmint                          2.140000   1.000     
1.000   

95003530 O    Spearmint, oil                     2.140000   0.010     
1.000   

19023540 19B  Spices, other                      2.140000   1.000     
1.000   from m

  Full comment: from mint

19023541 19B  Spices, other-babyfood             2.140000   1.000     
1.000   from m

  Full comment: from mint

04013550 4A   Spinach                            0.710000   1.000     
1.000   

04013551 4A   Spinach-babyfood                   0.710000   1.000     
1.000   

09023560 9B   Squash, summer                     0.500000   1.000     
1.000   

09023561 9B   Squash, summer-babyfood            0.500000   1.000     
1.000   

09023570 9B   Squash, winter                     0.500000   1.000     
1.000   

09023571 9B   Squash, winter-babyfood            0.500000   1.000     
1.000   

95003580 O    Starfruit                          0.041000   1.000     
1.000   from a

  Full comment: from apples

95003590 O    Strawberry                         0.520000   1.000     
0.890   from l

  Full comment: from leafy greens

95003591 O    Strawberry-babyfood                0.520000   1.000     
0.890   from l

  Full comment: from leafy greens

95003600 O    Strawberry, juice                  0.520000   1.000     
1.000   from l

  Full comment: from leafy greens

95003601 O    Strawberry, juice-babyfood         0.520000   1.000     
1.000   from l

  Full comment: from leafy greens

95003610 O    Sugar apple                        0.041000   1.000     
1.000   from a

  Full comment: from apples

95003630 O    Sugarcane, molasses                2.200000   2.400     
0.540   grass 

  Full comment: grass + sugar beet molasses factor

95003631 O    Sugarcane, molasses-babyfood       2.200000   2.400     
0.540   grass 

  Full comment: grass + sugar beet molasses factor

20003640 20   Sunflower, seed                    0.034000   1.000     
1.000   from s

  Full comment: from soybeans

20003650 20   Sunflower, oil                     0.034000   0.005     
1.000   from s

  Full comment: from soybeans +soy oil factor

20003651 20   Sunflower, oil-babyfood            0.034000   0.005     
1.000   from s

  Full comment: from soybeans +soy oil factor

01033660 1CD  Sweet potato                       0.330000   1.000     
1.000   

01033661 1CD  Sweet potato-babyfood              0.330000   1.000     
1.000   

04023670 4B   Swiss chard                        0.710000   1.000     
1.000   

95003680 O    Tamarind                           0.041000   1.000     
1.000   from p

  Full comment: from peaches (high tree fruit)

10003690 10   Tangerine                          0.024000   1.000     
1.000   

10003700 10   Tangerine, juice                   0.024000   0.900     
1.000   adjust

  Full comment: adjusted OJ factor

01033710 1CD  Tanier, corm                       0.330000   1.000     
1.000   

95003720 O    Tea, dried                         0.330000   1.000     
1.000   from c

  Full comment: from cane berries

95003730 O    Tea, instant                       0.330000   1.000     
1.000   from c

  Full comment: from cane berries

08003740 8    Tomatillo                          0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

08003750 8    Tomato                             0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

08003751 8    Tomato-babyfood                    0.025000   1.000     
1.000   from t

  Full comment: from tomato 1/2 LOD

08003760 8    Tomato, paste                      0.025000   3.300     
1.000   from t

  Full comment: from tomato 1/2 LOD

08003761 8    Tomato, paste-babyfood             0.025000   3.300     
1.000   from t

  Full comment: from tomato 1/2 LOD

08003770 8    Tomato, puree                      0.025000   2.100     
1.000   from t

  Full comment: from tomato 1/2 LOD

08003771 8    Tomato, puree-babyfood             0.025000   2.100     
1.000   from t

  Full comment: from tomato 1/2 LOD

08003780 8    Tomato, dried                      0.025000  14.300     
1.000   from t

  Full comment: from tomato 1/2 LOD

08003781 8    Tomato, dried-babyfood             0.025000  14.300     
1.000   from t

  Full comment: from tomato 1/2 LOD

08003790 8    Tomato, juice                      0.025000   1.500     
1.000   from t

  Full comment: from tomato 1/2 LOD

95003800 O    Tomato, Tree                       0.041000   1.000     
1.000   from a

  Full comment: from apples

15003810 15   Triticale, flour                   0.710000   0.600     
1.000   from w

  Full comment: from wheat and wheat flour

15003811 15   Triticale, flour-babyfood          0.710000   0.600     
1.000   from w

  Full comment: from wheat and wheat flour

50003820 P    Turkey, meat                       0.001000   1.000     
1.000   

50003821 P    Turkey, meat-babyfood              0.001000   1.000     
1.000   

50003830 P    Turkey, liver                      0.003000   1.000     
1.000   

50003831 P    Turkey, liver-babyfood             0.003000   1.000     
1.000   

50003840 P    Turkey, meat byproducts            0.014000   1.000     
1.000   

50003841 P    Turkey, meat byproducts-babyfood   0.014000   1.000     
1.000   

50003850 P    Turkey, fat                        0.001000   1.000     
1.000   

50003851 P    Turkey, fat-babyfood               0.001000   1.000     
1.000   

50003860 P    Turkey, skin                       0.014000   1.000     
1.000   

50003861 P    Turkey, skin-babyfood              0.014000   1.000     
1.000   

01033870 1CD  Turmeric                           0.330000   1.000     
1.000   

01013880 1AB  Turnip, roots                      0.330000   1.000     
1.000   

05023890 5B   Turnip, greens                     0.710000   1.000     
1.000   from l

  Full comment: from leaf lettuce

95003900 O    Vinegar                            0.025000   1.000     
1.000   from a

  Full comment: from apples

14003910 14   Walnut                             0.031000   1.000     
1.000   almond

  Full comment: almond field trial

86010000 O    Water, direct, all sources         0.031000   1.000     
1.000   

86020000 O    Water, indirect, all sources       0.031000   1.000     
1.000   

95003970 O    Water chestnut                     5.000000   1.000     
1.000   from w

  Full comment: from water

95003980 O    Watercress                         5.000000   1.000     
1.000   from w

  Full comment: from water

09013990 9A   Watermelon                         0.500000   1.000     
0.390   

09014000 9A   Watermelon, juice                  0.500000   1.000     
0.390   

15004010 15   Wheat, grain                       0.710000   1.000     
0.140   

15004011 15   Wheat, grain-babyfood              0.710000   1.000     
0.140   

15004020 15   Wheat, flour                       0.710000   0.600     
0.140   

15004021 15   Wheat, flour-babyfood              0.710000   0.600     
0.140   

15004030 15   Wheat, germ                        0.710000   2.600     
0.140   

15004040 15   Wheat, bran                        0.710000   2.300     
0.140   

15004050 15   Wild rice                          1.050000   1.000     
1.000   

01034060 1CD  Yam, true                          0.330000   1.000     
1.000   

01034070 1CD  Yam bean                           0.330000   1.000     
1.000   

Attachment 2. A. Chronic Food Plus Water Output File

U.S. Environmental Protection Agency                                
Ver. 2.00

DEEM-FCID Chronic analysis for ENDOTHALL                        (1994-98
data)

Residue file name: C:\Documents and Settings\dsoderbe\My
Documents\Endo2newDE\endothallreverseO19CTlastIhope.R98

                                                     Adjustment factor
#2 used.

Analysis Date 10-20-2009/15:49:41     Residue file dated:
10-20-2009/15:32:24/8

Reference dose (RfD, Chronic) = .007 mg/kg bw/day

========================================================================
=======

                    Total exposure by population subgroup

------------------------------------------------------------------------
-------

                                                    Total Exposure

                                        
-----------------------------------

          Population                         mg/kg             Percent
of   

           Subgroup                       body wt/day             Rfd   
   

--------------------------------------   -------------      
---------------

U.S. Population (total)                     0.002268               
32.4%

U.S. Population (spring season)             0.002286               
32.7%

U.S. Population (summer season)             0.002433               
34.8%

U.S. Population (autumn season)             0.002160               
30.9%

U.S. Population (winter season)             0.002191               
31.3%

Northeast region                            0.002412               
34.5%

Midwest region                              0.002223               
31.8%

Southern region                             0.002055               
29.4%

Western region                              0.002524               
36.1%

Hispanics                                   0.002223               
31.8%

Non-hispanic whites                         0.002259               
32.3%

Non-hispanic blacks                         0.002107               
30.1%

Non-hisp/non-white/non-black                0.002984               
42.6%

All infants (< 1 year)                      0.004462               
63.7%

Nursing infants                             0.002129               
30.4%

Non-nursing infants                         0.005347               
76.4%

Children 1-6  yrs                           0.004777               
68.2%

Children 7-12 yrs                           0.002494               
35.6%

Females 13-19 (not preg or nursing)         0.001524               
21.8%

Females 20+ (not preg or nursing)           0.001990               
28.4%

Females 13-50 yrs                           0.001953               
27.9%

Females 13+ (preg/not nursing)              0.002005               
28.6%

Females 13+ (nursing)                       0.002563               
36.6%

Males 13-19 yrs                             0.001698               
24.3%

Males 20+ yrs                               0.001900               
27.1%

Seniors 55+                                 0.002020               
28.9%

Children 1-2 yrs                            0.005882               
84.0%

Children 3-5 yrs                            0.004517               
64.5%

Children 6-12 yrs                           0.002624               
37.5%

Youth 13-19 yrs                             0.001616               
23.1%

Adults 20-49 yrs                            0.001918               
27.4%

Adults 50+ yrs                              0.002009               
28.7%

Females 13-49 yrs                           0.001884               
26.9%

------------------------------------------------------------------------
-------

Attachment 2. B. Food Only

U.S. Environmental Protection Agency                                
Ver. 2.00

DEEM-FCID Chronic analysis for ENDOTHALL                        (1994-98
data)

Residue file name: C:\Documents and Settings\dsoderbe\My
Documents\Endo2newDE\endothallreverseO19CTlastIhopenowater.R98

                                                     Adjustment factor
#2 used.

Analysis Date 10-20-2009/15:51:34     Residue file dated:
10-20-2009/15:31:23/8

Reference dose (RfD, Chronic) = .007 mg/kg bw/day

========================================================================
=======

                    Total exposure by population subgroup

------------------------------------------------------------------------
-------

                                                    Total Exposure

                                        
-----------------------------------

          Population                         mg/kg             Percent
of   

           Subgroup                       body wt/day             Rfd   
   

--------------------------------------   -------------      
---------------

U.S. Population (total)                     0.001614               
23.1%

U.S. Population (spring season)             0.001639               
23.4%

U.S. Population (summer season)             0.001731               
24.7%

U.S. Population (autumn season)             0.001528               
21.8%

U.S. Population (winter season)             0.001560               
22.3%

Northeast region                            0.001816               
25.9%

Midwest region                              0.001562               
22.3%

Southern region                             0.001434               
20.5%

Western region                              0.001775               
25.4%

Hispanics                                   0.001481               
21.2%

Non-hispanic whites                         0.001621               
23.2%

Non-hispanic blacks                         0.001486               
21.2%

Non-hisp/non-white/non-black                0.002183               
31.2%

All infants (< 1 year)                      0.002320               
33.1%

Nursing infants                             0.001334               
19.1%

Non-nursing infants                         0.002694               
38.5%

Children 1-6  yrs                           0.003864               
55.2%

Children 7-12 yrs                           0.001901               
27.2%

Females 13-19 (not preg or nursing)         0.001065               
15.2%

Females 20+ (not preg or nursing)           0.001338               
19.1%

Females 13-50 yrs                           0.001321               
18.9%

Females 13+ (preg/not nursing)              0.001369               
19.6%

Females 13+ (nursing)                       0.001657               
23.7%

Males 13-19 yrs                             0.001217               
17.4%

Males 20+ yrs                               0.001315               
18.8%

Seniors 55+                                 0.001379               
19.7%

Children 1-2 yrs                            0.004912               
70.2%

Children 3-5 yrs                            0.003609               
51.6%

Children 6-12 yrs                           0.001997               
28.5%

Youth 13-19 yrs                             0.001144               
16.3%

Adults 20-49 yrs                            0.001308               
18.7%

Adults 50+ yrs                              0.001367               
19.5%

Females 13-49 yrs                           0.001276               
18.2%

------------------------------------------------------------------------
-------



Attachment 2. C..  Water Only

U.S. Environmental Protection Agency                                
Ver. 2.00

DEEM-FCID Chronic analysis for ENDOTHALL                        (1994-98
data)

Residue file name: C:\Documents and Settings\dsoderbe\My
Documents\endothnewDE\endowateronly31ppb.R98

                                                     Adjustment factor
#2 used.

Analysis Date 09-21-2009/16:34:11     Residue file dated:
08-28-2009/15:32:42/8

Reference dose (RfD, Chronic) = .007 mg/kg bw/day

========================================================================
=======

                    Total exposure by population subgroup

------------------------------------------------------------------------
-------

                                                    Total Exposure

                                        
-----------------------------------

          Population                         mg/kg             Percent
of   

           Subgroup                       body wt/day             Rfd   
   

--------------------------------------   -------------      
---------------

U.S. Population (total)                     0.000653                
9.3%

U.S. Population (spring season)             0.000648                
9.3%

U.S. Population (summer season)             0.000702               
10.0%

U.S. Population (autumn season)             0.000632                
9.0%

U.S. Population (winter season)             0.000632                
9.0%

Northeast region                            0.000596                
8.5%

Midwest region                              0.000661                
9.4%

Southern region                             0.000621                
8.9%

Western region                              0.000749               
10.7%

Hispanics                                   0.000742               
10.6%

Non-hispanic whites                         0.000637                
9.1%

Non-hispanic blacks                         0.000620                
8.9%

Non-hisp/non-white/non-black                0.000801               
11.4%

All infants (< 1 year)                      0.002142               
30.6%

Nursing infants                             0.000795               
11.4%

Non-nursing infants                         0.002654               
37.9%

Children 1-6  yrs                           0.000913               
13.0%

Children 7-12 yrs                           0.000594                
8.5%

Females 13-19 (not preg or nursing)         0.000460                
6.6%

Females 20+ (not preg or nursing)           0.000652                
9.3%

Females 13-50 yrs                           0.000632                
9.0%

Females 13+ (preg/not nursing)              0.000635                
9.1%

Females 13+ (nursing)                       0.000905               
12.9%

Males 13-19 yrs                             0.000481                
6.9%

Males 20+ yrs                               0.000585                
8.4%

Seniors 55+                                 0.000641                
9.2%

Children 1-2 yrs                            0.000970               
13.9%

Children 3-5 yrs                            0.000908               
13.0%

Children 6-12 yrs                           0.000627                
9.0%

Youth 13-19 yrs                             0.000472                
6.7%

Adults 20-49 yrs                            0.000610                
8.7%

Adults 50+ yrs                              0.000642                
9.2%

Females 13-49 yrs                           0.000608                
8.7%

------------------------------------------------------------------------
-------

Attachment 3.  Sensitivity Analyses A.  All Tree residues removed

U.S. Environmental Protection Agency                                
Ver. 2.00

DEEM-FCID Chronic analysis for ENDOTHALL                        (1994-98
data)

Residue file name: C:\Documents and Settings\dsoderbe\My
Documents\Endo2newDE\endothallreverseO19CTlastIhopefoodnotrees.R98

                                                     Adjustment factor
#2 used.

Analysis Date 10-21-2009/11:14:16     Residue file dated:
10-21-2009/11:13:02/8

Reference dose (RfD, Chronic) = .007 mg/kg bw/day

========================================================================
=======

                    Total exposure by population subgroup

------------------------------------------------------------------------
-------

                                                    Total Exposure

                                        
-----------------------------------

          Population                         mg/kg             Percent
of   

           Subgroup                       body wt/day             Rfd   
   

--------------------------------------   -------------      
---------------

U.S. Population (total)                     0.002166               
30.9%

U.S. Population (spring season)             0.002186               
31.2%

U.S. Population (summer season)             0.002330               
33.3%

U.S. Population (autumn season)             0.002060               
29.4%

U.S. Population (winter season)             0.002087               
29.8%

Northeast region                            0.002295               
32.8%

Midwest region                              0.002124               
30.3%

Southern region                             0.001968               
28.1%

Western region                              0.002409               
34.4%

Hispanics                                   0.002097               
30.0%

Non-hispanic whites                         0.002161               
30.9%

Non-hispanic blacks                         0.002012               
28.7%

Non-hisp/non-white/non-black                0.002858               
40.8%

All infants (< 1 year)                      0.004093               
58.5%

Nursing infants                             0.001907               
27.2%

Non-nursing infants                         0.004922               
70.3%

Children 1-6  yrs                           0.004433               
63.3%

Children 7-12 yrs                           0.002365               
33.8%

Females 13-19 (not preg or nursing)         0.001460               
20.9%

Females 20+ (not preg or nursing)           0.001921               
27.4%

Females 13-50 yrs                           0.001880               
26.9%

Females 13+ (preg/not nursing)              0.001892               
27.0%

Females 13+ (nursing)                       0.002468               
35.3%

Males 13-19 yrs                             0.001635               
23.4%

Males 20+ yrs                               0.001840               
26.3%

Seniors 55+                                 0.001938               
27.7%

Children 1-2 yrs                            0.005410               
77.3%

Children 3-5 yrs                            0.004217               
60.2%

Children 6-12 yrs                           0.002482               
35.5%

Youth 13-19 yrs                             0.001552               
22.2%

Adults 20-49 yrs                            0.001860               
26.6%

Adults 50+ yrs                              0.001930               
27.6%

Females 13-49 yrs                           0.001821               
26.0%

------------------------------------------------------------------------
-------



Attachment 3.  Sensitivity Analysis B.  All Tree crops and all Grapes
Removed

U.S. Environmental Protection Agency                                
Ver. 2.00

DEEM-FCID Chronic analysis for ENDOTHALL                        (1994-98
data)

Residue file name: C:\Documents and Settings\dsoderbe\My
Documents\Endo2newDE\endothallreverseO19CTlastIhopefoodnograpes.R98

                                                     Adjustment factor
#2 used.

Analysis Date 10-21-2009/11:15:17     Residue file dated:
10-21-2009/11:13:44/8

Reference dose (RfD, Chronic) = .007 mg/kg bw/day

========================================================================
=======

                    Total exposure by population subgroup

------------------------------------------------------------------------
-------

                                                    Total Exposure

                                        
-----------------------------------

          Population                         mg/kg             Percent
of   

           Subgroup                       body wt/day             Rfd   
   

--------------------------------------   -------------      
---------------

U.S. Population (total)                     0.001844               
26.3%

U.S. Population (spring season)             0.001877               
26.8%

U.S. Population (summer season)             0.001984               
28.3%

U.S. Population (autumn season)             0.001752               
25.0%

U.S. Population (winter season)             0.001760               
25.1%

Northeast region                            0.001913               
27.3%

Midwest region                              0.001803               
25.8%

Southern region                             0.001689               
24.1%

Western region                              0.002071               
29.6%

Hispanics                                   0.001845               
26.4%

Non-hispanic whites                         0.001815               
25.9%

Non-hispanic blacks                         0.001729               
24.7%

Non-hisp/non-white/non-black                0.002634               
37.6%

All infants (< 1 year)                      0.003580               
51.1%

Nursing infants                             0.001713               
24.5%

Non-nursing infants                         0.004289               
61.3%

Children 1-6  yrs                           0.003157               
45.1%

Children 7-12 yrs                           0.001964               
28.1%

Females 13-19 (not preg or nursing)         0.001281               
18.3%

Females 20+ (not preg or nursing)           0.001697               
24.2%

Females 13-50 yrs                           0.001665               
23.8%

Females 13+ (preg/not nursing)              0.001757               
25.1%

Females 13+ (nursing)                       0.002266               
32.4%

Males 13-19 yrs                             0.001507               
21.5%

Males 20+ yrs                               0.001653               
23.6%

Seniors 55+                                 0.001705               
24.4%

Children 1-2 yrs                            0.003550               
50.7%

Children 3-5 yrs                            0.003089               
44.1%

Children 6-12 yrs                           0.002057               
29.4%

Youth 13-19 yrs                             0.001399               
20.0%

Adults 20-49 yrs                            0.001668               
23.8%

Adults 50+ yrs                              0.001702               
24.3%

Females 13-49 yrs                           0.001615               
23.1%

------------------------------------------------------------------------
-------

Attachment 4.  Residue Data from IR-4 Field trials

Residue Data for Endothall

Trial ID

(City, State; Year)	Zone	Crop; Variety	Matrix	Total Rate4	PHI

(days)	Residues (ppm)5,6





ppm	lb ae/A



	Residue Data from Root and Tuber Vegetable Field Trials with Endothall.

Sugar Beets

Conklin, MI 2007

MI$19	5	Sugar beet; Beta 5451	Tops	5.0	6.77	0	1.256	1.374





3.5	4.80	0	0.523	0.531



	Roots	5.0	6.77	0	0.199	0.136





3.5	4.80	0	0.120	0.115

Arroyo Grande, CA  2007

CA$22	10	Sugar beet; Alpine Medium Quickprime	Tops	5.0	6.79	0	1.618
1.105





3.5	4.88	0	1.279	0.948



	Roots	5.0	6.79	0	0.591	0.395





3.5	4.88	0	0.345	0.316

Carrot

Ravenna, MI  2007

MI$20	5	Carrot; Recoleta	Root	5.0	6.77	0	0.075	0.062

Arroyo Grande, CA 2006

CA$06	10	Carrot; Nantes	Root	5.0	6.79	0	0.088	0.088

Potato

Conklin, MI  2007

MI$21	5	Potato; Dark Red Norland	Tuber	5.0	6.77	0	0.072	0.103

Payette, ID  2007

ID$23	11	Potato; Ranger Russet	Tuber	5.0	6.83	0	0.067	0.078

	Residue Data from Onion Field Trials with Endothall (SC/L).

East Bernard, TX 2007

TX$07	6	Green Onion; Evergreen Hardy White	Whole plant without roots	5.0
6.75	0	0.284	0.234

Arroyo Grande, CA  2007

CA$18	10	Dry Bulb Onion; Onion Yellow Granex F1	Dry Bulb	5.0	6.76	0
0.0231	0.0231

	Residue Data from Lettuce Field Trials with Endothall Salts (SC/L).

Leaf Lettuce

Arroyo Grande, CA 2006

CA$04	10	Leaf lettuce; Greenstar	Leaves 	5.0	6.76	0	0.743	1.240





3.5	4.81	0	0.582	1.013

North Rose, NY 2007

NY$28	1	Leaf Lettuce; Green salad bowl	Leaves	5.0	6.73	0	0.462	0.410





3.5	4.67	0	0.255	0.241

Head Lettuce

Arroyo Grande, CA 2006

CA$05	10	Head Lettuce; Snaiper	Heads, 

w/wrapper leaves	5.0	6.76	0	0.092	0.081





3.5	4.81	0	0.0321	0.082

Lyons, NY 2007

NY$31	1	Head Lettuce; Ithaca MTO	Heads, 

w/wrapper leaves	5.0	7.17	0	0.604	0.491





3.5	5.07	0	0.582	0.436

	Residue Data from Cabbage Field Trials with Endothall (SC/L).

North Rose, NY 2006

NY$23	1	Matsumo	Head with wrapper leaves	5.0	7.00	0	0.0251	0.075

Baptistown, NJ  2006

NJ$08	1	Blue Lagoon	Head with wrapper leaves	5.0	5.64	0	0.065	0.058

	Residue Data from Legume Field Trials with Endothall Monoamine Salt
(SC/L).

Succulent Podded Beans

Arroyo Grande, CA 2007

CA$26	10	Succulent Lima /speckled	Succulent seed w/pod	5.0	9.02	0	0.414
0.521

Baptistown, NJ 2006

NJ$24	1	Succulent Lima/ Burpee’s Improved Bush	Succulent seed w/pod
5.0	6.75	0	0.291	0.324

Dried Beans

Delavan, WI 2007

WI$13	5	Dry bean/

Pinto	Dried seed	5.0	6.77	0	0.134	0.070

Richland, IA 2007

IA$14	5	Dry bean/

Great Northern	Dried seed	5.0	6.77	0	0.109	0.123

Succulent Podded Peas

Ephrata, WA 2007

WA$17	12	Succulent pea/

Tonic	Succulent seed w/pod	5.0	6.74	0	0.878	1.00

Delavan, WI 2007

WI$12	5	Succulent pea/

Wanto	Succulent seed w/pod	5.0	6.74	0	0.537	0.522

Soybean

Baptistown, NJ 2006

NJ$25	1	Soybean/

93244449	Dried seed	5.0	6.75	1	0.072	0.068

Newport, AR 2007

AR$16	4	Soybean/

BPR 5423 nRR	Dried seed	5.0	6.76	0	0.0171	ND2

Richland, IA 2007

IA$15	5	Soybean/

93M42	Dried seed	5.0	6.77	0	0.0201	0.0171

Sparta, IL 2007

IL$11	5	Soybean/

Asgrow AG 3905	Dried seed	5.0	6.77	0	0.0381	0.0261

TABLE C.3.	Residue Data from Tomato Field Trials with Endothall
Monoamine Salt (SC/L).

Grande Arroyo, CA 20006

CA$28	10	Tomato/ Organic Yaqui	Fruit	5.0	6.74	0	NR3 	NR3 

Oviedo, FL 2006

FL$27	3	Tomato/ Celebrity	Fruit	5.0	6.77	0	0.0271	0.0301

	Residue Data from Cucumber Field Trials with Endothall Salts (SC/L).

Baptistown, NJ 2006

NJ$02	1	Burpless bush	Fruit	5.0	6.75	0	0.738	0.738





3.5	4.80	0	0.406	0.459

Conklin, MI 2007

MI$42	5	Fancipack	Fruit	5.0	6.77	0	0.234	0.284





3.5	4.81	0	0.337	0.310

	Residue Data from Orange Field Trials with Endothall Monoamine Salt
(SC/L).

Dinuba, CA 2006

CA$11	10	Rush Thompson Improved	Fruit	5.0	6.78	0	0.0241	0.0281

Oviedo, FL 2006

FL$10	3	Hamlin	Fruit	5.0	6.63	0	0.0221	0.0211

	Residue Data from Apple Field Trials with Endothall Monoamine Salt
(SC/L).

North Rose, NY 2006

NY$29	1	Empire	Fruit	5.0	6.79	0	0.0311	0.0471

Ephrata, WA 2006

WA$16	11	Braeburn	Fruit	5.0	6.64	0	ND2	0.0431

	Residue Data from Peach Field Trials with Endothall Salts (SC/L).

Morven, GA 2007

GA$01	2	White	Fruit	5.0	7.08	0	0.0451	0.0431





3.5	5.05	0	0.0431	0.0461

Dinuba, CA 2007

CA$02	10	Snow Princess	Fruit	5.0	6.78	0	0.144	0.160





3.5	4.82	0	0.118	0.136

	Residue Data from Crop Field Trials with Endothall Monoamine Salt
(SC/L).

Conklin, MI 2007

MI$32	5	Blueberry: Blue Ray (Highbush)	Fruit	5.0	6.77	0	0.158	0.197

Hillsboro, OR 2007

OR$41	12	Blackberry (Boysen)	Fruit	5.0	6.73	0	0.311	0.346

	Residue Data from Tree Nut Field Trials with Endothall Monoamine Salt
(SC/L).



Irwinville, GA 

2006

GA$22	2	Pecan; summer	Nutmeat	5.0	7.01

	0	ND2	0.0241

Coalinga, CA 2007

CA$40	10	Almond; nonpariel	Nutmeat	5.0	6.80	0	0.0361	0.0371



	Hulls 



6.91	8.20

TABLE C.3.	Residue Data from Cereal Crop Field Trials with Endothall.

Sweet Corn

Sodus, NY 2006

NY$17	1	Sweet corn; Speedy Sweet	K+CWHR	5.0	6.75	0	0.05	NR3 



	Forage (w/o ears)



0.52	0.65



	Forage (w/ears)



0.49	0.40



	Stover (w/ears)



0.69	0.58

Campbell. MN 2007

MN$10	5	Sweet corn: Vitality	K+CWHR	5.0	6.91	0	0.17	0.17



	Forage (w/o ears)



1.18	1.28



	Forage (w/ears)



0.88	1.06





	Stover (w/ears)



4.70	5.06

Field Corn

Baptistown, NJ 2006

NJ$18	2	Field corn; 

TA 3892	Forage	5.0	3.38 4	0	0.40	0.28



	Grain

6.75

0.0411	0.0391



	Stover



3.48	2.89

Sparta, IL 2007

IL$09	5	Field Corn DK61-73	Forage	5.0	6.77	0	0.31	0.34



	Grain



NR3	NR3



	Stover



1.56	1.39

Richland, IA 2007

IA$06	5	Field Corn 34A16	Forage	5.0	2.26 3	0	0.35	0.42



	Grain

6.77

NR3	NR3



	Stover



2.07	2.37

Centerville, SD 2007

SD$05	5	Field Corn DKC 54-46	Forage	5.0	2.40 3	0	0.36	0.21



	Grain

7.10

NR3	NR3



	Stover



1.07	1.81

Sorghum

Sparta, IL 2007

IL$08	5	Sorghum Dekalb 44	Forage	5.0	3.38 4	0	3.05	2.29



	Grain

6.77

1.41	0.91



	Stover



2.60	7.19

Richland, IA 2007

IA$07	5	Sorghum 85G01	Forage	5.0	3.38 4	0	0.96	0.57



	Grain

6.77

0.49	0.80



	Stover



1.11	0.81

Larned, KS 2007

KS$03	7	Sorghum Pioneer 87G57	Forage	5.0	2.26 3	0	0.29	0.41



	Grain

6.77

1.23	1.18



	Stover



3.10	2.65



Wheat 



Ephrata, WA 2007

WA$20	11	Winter Wheat; Stevens	Forage	5.0	2.21 3	0	0.74	0.63



	Hay



1.00	1.11



	Grain

6.64

0.20	0.25



	Straw



2.20	1.93

Bernard, TX 2007

TX$19	6	Winter wheat; Fannin	Forage	5.0	2.24 3	0	1.99	2.27



	Hay



3.09	3.09



	Grain

6.71	1	2.01	1.80



	Straw



2.72	2.76

St, Johns, KS 2007

KS$21	5	Winter Wheat; Jagger	Forage	5.0	2.26 3	0	0.84	0.89



	Hay

3.39 4

1.31	1.62



	Grain

6.77

0.32	0.32



	Straw



1.49	1.38

Velva, ND 2007

ND$04	7	Spring Wheat; Glenn	Forage	5.0	2.19 3	0	0.89	0.94



	Hay

3.29 4

2.24	2.09



	Grain

6.58

0.30	0.47



	Straw



1.52	0.61

	Residue Data from Grass Feed Crop Field Trials with Endothall Monoamine
Salt (SC/L).

Lecompte, LA 2006

LA$12	4	Bermuda grass;  Russell	Forage	5.0	7.02	1	2.08	2.23



	Hay



9.80	12.40

East Bernard, TX 2006

TX$14	6	Bermuda grass; Coastal	Forage	5.0	6.75	1	1.85	2.03



	Hay



13.1	14.2

Ephrata, WA 2006

WA$15	11	Bluegrass; Kentucky	Forage	5.0	6.64	1	1.82	1.85



	Hay



7.17	8.91

Newport, SR 2007

AR$37	4	Bluegrass; Kentucky	Forage	5.0	6.76	2	2.65	2.81



	Hay



6.51	6.78

Alexandria, LA 2006

LA$13	4	Fescue;

 not available	Forage	5.0	7.00	0	1.70	2.86



	Hay



5.89	5.84

Hillsboro, OR 2007

OR$38	12	Fescue; 

Pure Gold	Forage	5.0	6.73	0	2.65	1.99



	Hay



5.34	9.24

	Residue Data from Non Grass Crop Field Trials with Endothall Monoamine
Salt (SC/L).

Velva, ND 2007

ND$20	7	Alfalfa; NK919	Forage	5.0	6.58	0	2.13	1.41



	Hay



4.98	4.87

Tilden, IL 2007

IL$30	5	Alfalfa; cattleman’s	Forage	5.0	5.94	0	2.24	1.99



	Hay



5.31	3.09

	Residue Data from Crop Field Trials with Endothall Monoamine Salt
(SC/L).

Velva, ND 2007

ND$20	7	Alfalfa; NK919	Forage	5.0	6.58	0	2.13	1.41



	Hay



4.98	4.87

Tilden, IL 2007

IL$30	5	Alfalfa; cattleman’s	Forage	5.0	5.94	0	2.24	1.99



	Hay



5.31	3.09

	Residue Data from Grape Field Trials with Endothall (2 lb ae/gal SC/L).

North Rose, NY 2006

NY$01	1	Elvira	Fruit	4.98	6.73	0	0.433	0.376

San Luis Obispo, CA 2007

CA$31	10	Pinot 155	Fruit	4.98	6.76	0	0.588	0.449

Ephrata, WA 2006

WA$02	11	Riesling	Fruit	4.97	6.64	0	0.587	0.696

	Residue Data from Rice Field Trials with Endothall Monoamine Salt
(SC/L).

East Bernard, TX 2007

TX$24	6	Rice; Cocodrie	Grain	5.0	6.75	1	1.22	1.14



	Straw



1.99	2.24

Cheneyville, LA 2007

LA$25	4	Rice; Clearfield 161	Grain	5.0	6.77	0	1.16	1.19



	Straw



1.09	0.94

Newport, AR 2007

AR$26	4	Rice; Wells	Grain	5.0	6.76	0	0.818 3	0.694 3



	Straw



1.90	1.86

Biggs, CA 2007

CA$27	10	Rice; M-205	Grain	5.0	6.76	0	0.802 3	1.08



	Straw



2.59	2.61

	Residue Data from Mint Field Trials with Endothall Monoamine Salt
(SC/L).

Ephrata, WA 2006

WA$09	11	Mint (Todd’s Mitchem)	Tops	5.0	6.64	0	2.89	2.70

Elkhorn, WI 2007

WI$39	5	Mint (Black Mitchem)	Tops	5.0	6.77	0	1.67	1.31

Residues below LLMV, but above LOD.

Non Detect – no residues seen

No Reportable Residues – no residues below the 0.05 ppm LLMV were
reported

The rate is expressed both in terms of the concentration in the
irrigation water (ppm and the total amount (lbs ae/A) applied.

Expressed in acid equivalents.  The LLMV is 0.05 ppm and the LOD is
below 0.001 ppm.

The two results for each field trial represent two samples taken from a
single plot, not two plots.  

Attachment 5.  Processing Factors from IR-4 Processing studies

	Summary of Processing Factors for Endothall from Crops Irrigated with
Endothall-treated water.

RAC	Processed Commodity	Application Rate 1	PHI

(days)	Processing Factor



ppm	lb ae/A



Apple 2	Juice	5.0	6.79	0	1.2x

	Wet pomace



2.8x

Field Corn	Grits	5.0	6.77	0	NC 3

	Meal



NC 3

	Flour



NC 3

	Refined oil (dry milling)



NC 3

	Starch



NC 3

	Refined oil (wet milling)



NC 3

Grape	Juice	5.0	6.73	0	1.2x5

	Raisins



4.4x

Mint	Oil	5.0	6.64	0	<0.001x

Orange 2	Dried pulp	5.0	6.63	0	2.2x

	Juice



0.7x

	Oil



<0.2x

Rice	Hulls	5.0	6.75	1	3.9x

	Bran



2.3x

	Polished rice



0.07x

Sorghum	Flour	5.0	6.77	0	0.7x

Soybean 2	Hulls	5.0	6.77	0	3.9x

	Meal



0.8x

	Refined oil



<0.005x

Sugar beet	Dried pulp	5.0	6.79	0	1.1x

	Molasses



2.4x

	Refine sugar



<0.1x

Tomato 2	Puree	5.0	6.77	0	2.1x4

	Paste



3.3x4

Wheat	Aspirated grain fractions (AGF)	5.0	6.71	0	15x

	Germ



2.6x

	Bran



2.3x

	Middlings



0.9x

	Flour



0.6x

	Shorts



1.4x

1	The rate is expressed both in terms of the concentration in the
irrigation water (ppm) and the total amount (lb ae/A) applied.

2	Residue values <LLMV but ≥LOD were used for calculating processing
factors.

3	Residues were <LLMV and <LOD in/on field corn grain and each processed
fraction.  NC = not calculated.

4	Residues were below the LLMV (<0.05 ppm) in both fruit and puree
samples, but were well above the LOD at 0.002 ppm) 

5  1.2x is the Maximum Theoretical Processing Factor for grape juice

\

Attachment 6.  Calculation of Dietary Burdens

The MMPE dietary burden for chronic exposure assessment was calculated
as in the accompanying Summary of  Analytical Chemistry and Residue
Data, except that the intake of residues in the livestock water was
taken to be 0.2 ppm, the potable water tolerance, instead of 5 ppm, the
maximum treatment rate used for tolerance estimation.  The conclusion
that chronic residues in livestock water are below 0.2 ppm was supported
by estimates from EFED (attachment 2).  

Using the average residue values from the fields trials and the recent
changes in calculating dietary burdens (Revisions of Table 1 Feedstuffs,
June 2008), the dietary burdens for livestock to endothall residues were
calculated to be 2.8 ppm for beef cattle, 4.1 ppm for dairy cattle, 1.0
ppm for poultry and 1.0 ppm for swine (Table 8.1) based upon residues in
the feeds.

For purposes of dietary exposure assessment it was considered that
livestock may be chronically exposed to water at the potable water
tolerance of 0.2 ppm.  The potential contribution of endothall residues
in water to the dietary exposure of livestock was calculated following
the procedures described in PP#1F3991/1F3935 (G. Okatie, 9/4/92), based
on the concentration of endothall in the drinking water, the daily water
consumption, and the daily feed intake.  The estimated values for daily
water consumption and food intake (dry wt. basis) are presented in Table
2, along with the calculated contribution of the treated water to the
dietary burden.  When expressed on the basis of the dry feed intake, the
contribution of endothall-treated water to the dietary burden would be
0.77 ppm for beef cattle, 1.82 ppm for dairy cattle, 0.54 ppm for
poultry, and 0.65 ppm for swine (Table 8.2).  When combined with the
exposure to endothall residues in feedstuffs, the total dietary exposure
of livestock to endothall residues would be 3.6 ppm for beef cattle, 5.9
ppm for dairy cattle, 1.5 ppm for poultry, and 1.7 ppm for swine (Table
8.3).  

Anticipated Residues based upon these dietary burdens for meat, milk,
poultry and eggs are subsequently calculated and presented in Table 1 in
the Assessment.

Attachment 6.  Table 1.	Calculation of Dietary Burdens of Endothall
Residues for Livestock.

Feedstuff	Type 1	% Dry Matter2	% Diet 2	Average Residues (ppm)	Percent
Crop Treated	Dietary Contribution (ppm) 3

Beef Cattle

Grass hay	R	88	15	8.77	100	1.49

Grain aspirated fractions	CC	85	5	15	100	0.88

Wheat milled byproducts	CC	88	40	1	14	0.06

Grain, Cereal, group 15	CC	88	30	1	100	0.34

Sugar beet, molasses	CC	75	5	0.80	37	0.02

Soybean meal	PC	92	5	0.027	9	0.0001

TOTAL BURDEN	--	--	100	--	100	2.79

Dairy Cattle

Grass hay	R	88	20	8.77	100	1.99

Almond Hulls	R	90	5	7.6	100	0.42

Animal  Feed, Nongrass, group 18, forage	R	35	20	2.0	100	1.14

Grain, Cereal, group 15	CC	86	45	1	100	0.52

Sugar Beet, Molasses	CC	75	5	0.80	37	0.02

Soybean meal	PC	92	10	0.027	9	0.003

TOTAL BURDEN	--	--	100	--	100	4.09

Poultry

Grain, Cereal, group 15	CC	88	75	1	100	0.75

Alfalfa, Meal, Animal feed, Nongrass, group 18, hay	PC	89	5	5.1	100	0.29

Soybean Meal	PC	92	20	0.027	9	0.0005

TOTAL BURDEN	--	--	100	--	100	1.04

Swine

Grain, Cereal, group 15	CC	88	85	1	100	0.97

Alfalfa, Meal, Animal feed, Nongrass, group 18, hay	CC	89	5	5.1	48	0.024

Soybean Meal	PC	92	10	0.027	9	0.0003

TOTAL BURDEN	--	--	100	--	100	0.99

1  R:  Roughage; CC:  Carbohydrate concentrate; PC:  Protein
concentrate.

2  OPPTS 860.1000 Table 1 Feedstuffs (June 2008).  

3  Contribution = ([tolerance /% DM] X % diet) for beef and dairy
cattle; contribution = ([tolerance] X % diet) for poultry and swine. 

4 The tolerance for soybean seeds was used for soybean meal.

Attachment 6.  Table 2.	Calculation of Dietary Burdens of Endothall
Residues to Livestock from Consumption of Water at the Pre-existing
Potable Water Tolerance of 0.2 ppm.

Feedstuff	Endothall concentration in water (ppm)	Water  consumption
(kg/day)	Feed consumption (kg dry wt./day) 1	Dietary Contribution from
water (ppm) 2

Beef cattle (feedlot cattle)	0.2	35	9.1	0.77

Dairy cattle (lactating cows)	0.2	218	24	1.82

Poultry (laying hens)	0.2	0.14	0.052	0.54

Swine (finishing hogs)	0.2	10	3.1	0.65

1	Feed consumption from ChemSAC Memo, 6/30/2008.

2	 Contribution = (endothall concentration X water consumption/day) ÷
feed consumption/day. 

Attachment 6.  Table 3.	Calculation of Total (Feed Plus Water) Dietary
Burdens of Endothall Residues to Livestock 

Feedstuff	Feed	Water	Total

Beef cattle (feedlot cattle)	2.8	0.77	3.6

Dairy cattle (lactating cows)	4.1	1.82	5.9

Poultry (laying hens)	1.0	0.54	1.5

Swine (finishing hogs)	1.0	0.65	1.7



Attachment 6,  Table 4.  Calculation of estimated Residues in Livestock
Tissues Based upon the TRR in the Metabolism Studies and Considering
Water Residues at 0.2 ppm.





Residues of Endothall in Beef Cattle Tissues Based upon the Goat
Metabolism Study



Tissue	

Total Radioactive Residues (ppm) after Feeding at 12.0 ppm	

Anticipated Residues (ppm) after Feeding at 3.6 ppm  (all assume the
higher dairy cattle diet)



Milk.	

0.006	0.002



Kidney	

0.046	0.014



Liver	

0.020	0.006



Muscle 	

0.005	0.0015



Fat	

0.002	0.0006



Residues of Endothall in Dairy Cattle Tissues Based upon the Goat
Metabolism Study



Tissue	

Total Radioactive Residues (ppm) after Feeding at 12.0 ppm	

Anticipated Residues (ppm) after Feeding at 5.9 ppm  (all assume the
higher dairy cattle diet)



Milk.	

0.006	0.003



Kidney	

0.046	0.023



Liver	

0.020	0.010



Muscle 	

0.005	0.0025



Fat	

0.002	0.001



Residues of Endothall in Swine Tissues Based upon the Goat Metabolism
Study



Tissue

	

Total Radioactive Residues (ppm) after Feeding at 12.0 ppm	

Anticipated Residues (ppm) after Feeding at 1.7 ppm

Kidney

	

0.046	0.0065



Liver	

0.020	0.0028

Muscle 

	

0.005	0.0007

Fat	

0.002	0.0003

Residues of Endothall in Poultry Tissues Based upon the Chicken
Metabolism Study



Tissue	

Total Radioactive Residues (ppm) after feeding at 9.7 ppm	

Anticipated Residues (ppm) after feeding at 1.5 ppm



Eggs	

0.024	0.0037



    Yolk	

0.024	0.0037



    White	

0.002	0.0003



Kidney and Other Meat Byproducts	

0.088	0.014



Liver	

0.021	0.003



Muscle 	

0.008	0.001



Fat	

0.007	0.001





Attachment 7.  Percent Crop Treated memo from BEAD

  SEQ CHAPTER \h \r 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460



OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES

MEMORANDUM	

SUBJECT:	Estimates of Crop Irrigation for Endothall Registration (DP#
369862, 369863)

FROM:	Bill Phillips, II, Ph.D., Agronomist

Biological Analysis Branch 

Derek Berwald, Economist

		Economic Analysis Branch

		Biological and Economic Analysis Division (7503P)

THRU:	Timothy Kiely, Chief

		Economic Analysis Branch

		Arnet Jones, Chief

		Biological Analysis Branch

Biological and Economic Analysis Division (7503P)

TO:		Sidney Jackson, Risk Manager Reviewer

		Barbara Madden, Risk Manager

		Risk Integration Minor Use Emergency Response Branch 

		Registration Division (7505P)

Product Review Panel:  October 7, 2009   

Summary

EPA is evaluating a proposed use of the aquatic herbicide endothall for
weed control in irrigation canals.  This memo provides estimates for the
percentage of crops that may be exposed to endothall  that EPA is
reasonably certain will not be exceeded. Crops will be exposed to
endothall by irrigation water, so the maximum percent that could be
exposed is the share of production from irrigated land.  

Estimates, summarized in Table 1, are derived using two methods.  Where
data on irrigated and dryland production are available, the estimates
are based on the share of production from irrigated land, which is the
maximum percent of the crop that could be exposed to endothall. 
Estimates using the share of production that is irrigated are provided
for barley, corn, dry edible beans, peanuts, oats, rice, sorghum,
soybeans, sugarbeets, sugarcane, and wheat.  For crops of concern that
do not have available data on irrigated and dryland production, BEAD
uses the share of production grown in 17 western states where irrigation
is used extensively and endothall use will be concentrated. Estimates
based on production in the 17 western states are provided for apples,
grapes, oats, green peas, wheat, watermelon, and strawberries.  

In addition, BEAD reviewed the protocol for the residue trials and
concludes that the resulting data are conservative.  The trials used
applications of treated irrigation water applied through overhead
sprinklers, which would result in high exposure to the edible portion of
the crop.  Many fields are irrigated with drip lines or a flood system,
which would result in less of the treated water, and thus less
pesticide, deposited on the crop.  In the registrant’s field trials
plant samples were taken for residue testing from crops irrigated
overhead using water that was treated the day of harvest; this is not
common practice under actual production conditions.  



Table 1.  Estimated Percent Crop Treated with Endothall for Dietary Risk
Assessment

	Share of Irrigated

Production	Share of 

Production

 in West 1	Estimated Percent Crop Treated for Dietary Risk Assessment

Apple	n/a	65	65

	Fresh market	n/a	78	78

	Processing	n/a	44	44

	Juice	n/a	49	49

	Canned	n/a	14	14

Barley for grain	36	-	36

Corn for grain	19	-	19

Dry Beans 2	32	-	32

Grape	n/a	94	94

	Fresh market	n/a	99	99

	Processing	n/a	94	94

Green Peas	n/a	11	11

Oats for grain	7	37	7

Peanut for nuts	42	-	42

Rice	100	-	100

Sorghum for grain	15	-	15

Soybean for beans	9	-	9

Strawberry	n/a	91	91

	Fresh market	n/a	89	89

	Processing	n/a	100	100

Sugarbeet for sugar	37	-	37

Sugarcane for sugar	54	-	54

Watermelon	n/a	39	39

Wheat for grain	14	70	14

Source:	USDA 2009a, 2009b, 2009c, 2009d, EPA calculations.

1	Arizona, California, Colorado, Idaho, Kansas, Montana, Nebraska,
Nevada, New Mexico, North Dakota, Oklahoma, Oregon, South Dakota, Texas,
Utah, Washington, and Wyoming.  Estimates are only provided for certain
crops.



Background

Endothall is an herbicide registered for control of plants in water
bodies.  It is currently registered for weed control in irrigation
canals, but with the requirement that water cannot be released from the
system or applied to crops for seven days after treatment.  

The Agency is currently evaluating a petition for tolerances on many
irrigated crops to allow registration of endothall for use in irrigation
canals to control aquatic weeds without the requirement that the treated
water be held or contained prior to being used to irrigate a crop. 
Because this is a new use pattern for endothall, dietary risks must be
estimated and analyzed.  Normal methods for estimating the percent crop
treated for a new pesticide are inappropriate in this case, because the
pesticide is not directly applied to the crop.  Exposure occurs via
irrigation water.    

Endothall will be used to control weeds in irrigation systems, not as
treatment for the water in the systems.  Most of the water that goes
through a canal to irrigate crops will not be treated.  Instead,
endothall will be periodically injected into irrigation water to keep
weed populations down.  Because the water in the canal is rapidly turned
over, after several hours most if not all of the endothall will no
longer be in the canal systems.  In addition, the use directions for
endothall restrict applications to irrigation canals to once every seven
days, and a maximum of six times per year.  

Due to the rate of endothall used, the number of applications, and the
timing of applications the residue trials for endothall seem to be
conservative to BEAD.  This supposition is supported given the protocol
used where crops were overhead irrigated six times with an inch of water
containing the maximum concentration of endothall.   After the final
treatment the crop was harvested the same day, resulting in maximum
endothall residue concentrations on the crop.  From one of the
registrants field protocols:  

“[d]uplicate control and treated samples of each commodity were
harvested from the respective tests.  Samples of field corn forage,
sorghum forage and wheat forage and hay were harvested 0 days after the
second or third application (0 DAT).  Samples of sweet corn forage,
kennels plus cob with husks removed (K+CWHR) and stover, field corn
grain and stover, sorghum grain and stover, and wheat grain and straw
were harvested following the sixth application at 0 DAT (or at 1 DAT in
one wheat test).” 

Under actual field production conditions, crop harvest is conducted only
after a specified number of days after treatment. Due to standard
agronomic practices this duration is extended when, for example, wheat
is left to dry in the fields for some time before harvest, to reduce the
moisture content.  While in other cases crops such as grapes are not
overhead irrigated when fruit are present, because additional moisture
on the bunch can lead to fungal diseases.  There is an additional
consideration that should be given here and that is that much of the
crops irrigated from surface water sources are done so by using some
type of delivery system other than overhead sprinklers, systems such as
flood or drip irrigation.

Method for Estimating Percent Crop Treated

For some crops, the estimates in this memo are based on yield and
acreage data for irrigated and non-irrigated crops from the 2007 Census
of Agriculture (USDA 2009d).  The estimates provided will be an upper
bound on the percentage of crops that may have been irrigated with water
from canals that were treated with endothall, because some of the
irrigated crops are not grown in areas where endothall will be used.  

Other crops that are important to the dietary risk assessment do not
have data on irrigated and non-irrigated production available.  For
these crops, this memo provides estimates of the amount of the crop
grown in 17 western states where endothall use is expected.  These are
states where substantial amounts of water are transported through open
canal systems to be used for irrigation.  It is these systems where weed
control is important, and endothall is likely to be used.      

Estimates from the 2007 Census of Agriculture

For select crops, the 2007 Census of Agriculture (USDA 2009d) provides
estimates of the acres and yield from farms with irrigation, farms
without irrigation, and farms where some of the crop is irrigated. 
Using this information we provide estimates of the share of production
irrigated for those crops where the data are available. These crops are
barley, corn, dry edible beans, oats, peanuts for nuts, rice, sorghum,
soybeans, sugarbeets, sugarcane, and wheat.   

Table 2 shows the estimated percent of the crop that has been irrigated
for the food crops for which data are available.  To estimate the
production from the irrigated acres, the first step is to estimate the
crop production from irrigated land.  Using the data in Table 2, we
multiply the irrigated yield by the irrigated acreage, which is the
acreage from farms where the entire crop is irrigated plus the irrigated
acreage from partially irrigated farms.  To get an estimate of the share
of the crop irrigated, we divide this by an estimate of total
production.  To estimate total production from the information in Table
2, we multiply the yield by the acreage for each type of farm, and add
these together.  Taking wheat as an example, estimated production from
irrigated farmland is (1,806,902 + 1,557,177) × 80.3 = 270,135,544
bushels, which is the numerator for our percentage calculation.  Total
estimated production is 1,806,902 × 80.3 + (1,557,177 + 3,703,599) ×
42.7 + 43,865,291 × 37.0 = 1,992,745,133 bushels.  Dividing estimates
for production from irrigated land by the estimate of total production
yields an estimate of the share of production that has been irrigated,
in this case 14%.  The estimates for all the food crops with available
data in the census are in the last column of Table 2.  

Note that the data available in the Census of Agriculture only provides
overall yields for farms where only part of the crop is irrigated,
although it does provide total production and irrigated and dryland
acreage data.  For this analysis, BEAD assumed the yield from the
irrigated acreage on partially irrigated farms to be equal to the
average yield per acre from irrigated farms.  This is a conservative
assumption, because the implied non-irrigated yield is substantially
lower than from dryland farms in all but one case, which tends to
inflate the estimates of the share of crop irrigated.  

These estimates are based on only one year of data.  However, it is
unlikely that the amount of acreage irrigated will change a large amount
from one year to the next, because irrigation equipment is an expensive
capital investment.  

Note that these are estimates of the amount of the crop irrigated, not
the amount of the crop that may have endothall residues.  Not all of the
crop that is irrigated will be grown in areas where endothall is likely
to be used, and even in the West, where endothall use for irrigation is
expected, not all systems will necessarily be using endothall, a new
method of control.  Therefore, the share of crops that are actually
exposed to endothall are likely to be lower than the estimates of
irrigated acreage in Table 2.    



Table 2.  Share of Crop Production Irrigated	 	 	 	 	 	 	 	 	 
 	 	 

	Entire crop irrigated

Part of crop irrigated

None of crop irrigated

EPA Estimated Share of Production Irrigateda

	 	 	Average Yield Per Acre

 	Acres	Acres not	Average Yield Per Acre



Average Yield Per Acre



Crop	Farms	Acres

	Farms	irrigated	irrigated

	Farms	Acres



	Barley for grain (bushels)	3,566	605,340	100.0

675	136,135	155,262	53.3

15,607	2,625,220	49.9

36%

Corn for grain (bushels)	17,927	6,103,769	180.0

20,984	7,053,000	6,435,486	150.0

308,849	66,656,287	144.3

19%

Dry edible beans, excluding limas (cwt)	2,275	317,193	22.6

181	36,310	50,432	16.5

3,780	1,051,614	15.9

32%

Oats for grain (bushels)	1,304	67,948	83.7

316	10,266	15,560	63.4

40,938	1,415,375	58.1

7%

Peanuts for nuts (pounds)	1,301	251,564	3722.5

1,080	167,225	186,723	3234.1

3,801	595,052	2725.8

42%

Rice (cwt)	6,084	2,758,792	72.0

-	-	-	-

-	-	-

100%

Sorghum for grain (bushels)	2,092	443,599	86.9

2,391	401,615	670,030	74.7

21,759	5,254,590	69.2

15%

Soybeans for beans (bushels)	7,007	2,175,069	45.3

13,326	3,062,006	3,396,716	40.8

258,777	55,282,030	40.2

9%

Sugarbeets for sugar (tons)	1,535	387,224	30.0

60	7,451	20,424	24.2

2,427	838,718	23.4

37%

Sugarcane for sugar (tons)	210	431,796	38.7

9	3,409	3,373	33.3

473	408,088	34.7

54%

Wheat for grain, all (bushels)	7,695	1,806,902	80.3	 	7,518	1,557,177
3,703,599	42.7	 	145,597	43,865,291	37.0	 	14%

Source:  USDA 2009d and EPA Calculations

a Assumes irrigated acres on farms where only part of the crop is
irrigated obtain the same yield as acres on farms where the entire crop
is irrigated





Crop Estimates 

Endothall residues on some crops are of particular concern to EPA based
on residue trials and dietary habits.  These crops are peas, watermelon,
strawberries, apples, oats, grapes and wheat.  For these crops BEAD
provides estimates of the proportion of the crop that is grown in the 17
western states, which are the states expected to be users of endothall
in irrigation water.  According to the Farm and Ranch Irrigation Survey
(USDA 2004), almost 70% of the irrigated acreage in the United States is
in the 17 western states, and about 87% of the irrigation water applied
to crops is in these western states, which correspond to the states
served by Bureau of Reclamation water projects.  

The share of the crop grown in the 17 western states can be used as a
crude measure of the share of the crop that may have come in contact
with endothall.  These estimates are the best that can be made with the
available data, and they likely overestimate the crop that will
encounter endothall treated water, because not all production in the
western states will be irrigated with water from canals that have been
treated with endothall. Not all irrigation systems will use endothall,
some crop production is irrigated with wells that do not require weed
control, and some crops such as wheat and oats may be farmed without
irrigation, even in the arid West.   When possible (wheat and oats), the
estimates provided  in Table 2 above, based on the 2007 Census of
Agriculture, are preferable.  

The 17 western states are Arizona, California, Colorado, Idaho, Kansas,
Montana, Nebraska, Nevada, New Mexico, North Dakota, Oklahoma, Oregon,
South Dakota, Texas, Utah, Washington, and Wyoming.  It is in the West
that large scale water delivery systems are important to agriculture;
these are the systems that will use endothall for irrigation, as they
are the systems that currently use acrolein or xylene, aquatic
herbicides for which endothall may substitute.  Agriculture in the East,
where it is less arid, does not require large scale water transfers. 
BEAD does expect to see endothall use in the East, but primarily for
drainage systems rather than irrigation water delivery systems where
water will be applied to crops. 

Where available, estimates of the crop grown in the 17 western states
are provided for different end-uses of the particular crop.  This
information can be useful for dietary risk estimates, which are based on
consumption of specific food products.  The estimates of the amount
grown in the 17 western states are provided in Table 3.   

Peas

Only two western states are important producers of green peas for
processing, which can appear in baby foods.  In 2008, about 103,000 tons
were produced in Washington State, and about 33,000 tons in Oregon. 
Production in these two states was about 11% of US production of almost
412,000 tons (USDA 2009a).  

Watermelon

Four western states produce enough watermelon to show up in the USDA
data, Arizona, California, Oklahoma, and Texas.  California and Texas
produced about 6,100,000 cwt. and 6,000,000 cwt. in 2008, respectively. 
Arizona produced almost 2,900,000 cwt., and Oklahoma only produced about
360,000 cwt.  Together, the almost 15,400,000 cwt. of watermelon
represented about 39% of US production of about 39,600,000 cwt. in 2008
(USDA 2009a).  

Strawberries

California is the major strawberry producing state in the United States.
 In 2008, California produced almost 23,000 cwt. of strawberries, and
Oregon another 238 cwt., the two together totaling about 91% of the
total US production.  About 89% of the fresh market strawberries come
from the western states of California, Washington and Oregon, and almost
all the processing strawberries come from the same three states,
accounting for almost all strawberries used for processing (USDA 2009b).
 

Apple

Available data on apple production covers the production for the western
states of Arizona, California, Idaho, Oregon, Utah, and Washington, with
Washington being by far the largest producer.  Combined these states
accounted for about 65% of total US apple production in 2008, with over
59% of the total coming from Washington alone (USDA 2009b).  

Oats

Data on oat production is available for 13 of the seventeen western
states, with South Dakota being the largest producer in the West, and
3rd in the country, with about 8.8 million bushels.  In all, the western
states produce about 37% of the nation’s oats (USDA 2009c).  

Grapes

California was the largest producer of grapes in 2008, accounting for
over 89% of total production.  The 17 western states combined accounted
for about 94% of total production.  Looking at the end uses of these
grapes, the picture is similar.  About 99% of fresh grapes were from the
western states in 2008, and about 94% of the processed grapes.  Of the
grapes used for processing, California was the most important producer
of wine grapes (about 99%) and seems to account for all dried grapes
(USDA 2009b). 

Wheat

Wheat is widely grown in western states, with all 17 states appearing in
the available production data.  Together, the 17 western states account
for about 70% of the total wheat production.  

Table 3.  Share of Production of Specific Crops in the 17 Western
States, 2007

	US Production	Western States Production	Western States Share

Green Peas (Tons)	411,780	43,666	11%

Watermelon (1,000 cwt.)	39,551	15,387	39%

Strawberries (1,000 cwt.)	25,317	22,913	91%

Fresh Market 	20,911	18,653	89%

Processing 	4,406	4,404	100%

Apple (Million Pounds)	9,769	6,394	65%

Fresh Market 	6,304	4,911	78%

Processing 	3,372	1,500	44%

Juice 	1,534	750	49%

Canned 	1,191	170	14%

Oats (1,000 Bushels)	88,635	32,565	37%

Grapes (Tons)	7,303,260	6,887,000	94%

Fresh Market 	985,200	976,050	99%

Processing 	6,304,350	5,944,650	94%

Wheat (1,000 Bushels)	2,499,524	1,752,810	70%

Source:  USDA 2009a, 2009b, 2009c, EPA Calculations

The 17 Western states are Arizona, California, Colorado, Idaho, Kansas,
Montana, Nebraska, Nevada, New Mexico, North Dakota, Oklahoma, Oregon,
South Dakota, Texas, Utah, Washington, and Wyoming.



Suggested Federal Register Language 

EPA is establishing tolerances on multiple commodities to support the
application of the aquatic herbicide endothall to be used in irrigation
canals without a holding period.    

For a new agricultural pesticide use, EPA typically estimates percent
crop treated by comparison with the amount of use of other pesticides
for the same crop or site.  That approach is inappropriate for the new
use for endothall, because the use is on irrigation canals rather than
crops and EPA does not have data on the frequency of use of aquatic
herbicides on irrigation canals.    

Instead, EPA has estimated percent crop treated for endothall by
estimating the percent crop irrigated which serves as an upperbound for
crops that may be exposed to endothall in irrigation water.  EPA used
two methods to estimate percent crop irrigated.  The preferred method,
used where data on irrigated production are available, is an estimate of
the share of total production that is irrigated.  Estimates from this
method are provided for barley, corn, dry edible beans, oats, peanuts,
rice, sorghum, soybeans, sugarbeets, sugarcane, and wheat. Where data on
irrigated production are not available, EPA estimated the percent crop
irrigated by determining the percentage of United States production of a
crop that is grown in 17 western states where endothall may be used. 
The 17 western states are Arizona, California, Colorado, Idaho, Kansas,
Montana, Nebraska, Nevada, New Mexico, North Dakota, Oklahoma, Oregon,
South Dakota, Texas, Utah, Washington, and Wyoming.  These states are
the states where large scale water projects predominate, and where other
chemicals are used in canals for weed control.  These types of
irrigation projects are relatively rare in other parts of the country.

Use of these estimates in the exposure assessment is conservative,
because it is the equivalent of assuming 100% of irrigated crops have
irrigated with water from endothall-treated canals.

In fact, even in areas with surface water delivery systems, all
irrigation canals may not be treated with endothall.  Additionally, some
crops, even in the heavily irrigated areas of the West, are not
irrigated, such as dryland grain production.   

References

USDA 2004.   US Department of Agriculture, National Agricultural
Statistics Service, The Census of Agriculture, Farm and Ranch Irrigation
Survey (2003) Volume 3, Special Studies Part 1.  November 2009.  
Available here:
http://www.agcensus.usda.gov/Publications/2002/FRIS/index.asp

USDA 2009a.  US Department of Agriculture, National Agricultural
Statistics Service, Vegetables 2008 Summary.  January 2009.  Available
here:   HYPERLINK
"http://usda.mannlib.cornell.edu/usda/current/VegeSumm/VegeSumm-01-28-20
09.txt"
http://usda.mannlib.cornell.edu/usda/current/VegeSumm/VegeSumm-01-28-200
9.txt 

USDA 2009b.  US Department of Agriculture, National Agricultural
Statistics Service, Noncitrus Fruits and Nuts 2008 Summary.  July 2009. 
Available here:   HYPERLINK
"http://usda.mannlib.cornell.edu/usda/current/NoncFruiNu/NoncFruiNu-07-0
8-2009.pdf"
http://usda.mannlib.cornell.edu/usda/current/NoncFruiNu/NoncFruiNu-07-08
-2009.pdf 

USDA 2009c.  US Department of Agriculture, National Agricultural
Statistics Service, Crop Production 2008 Summary.  January 2009. 
Available here:   HYPERLINK
"http://usda.mannlib.cornell.edu/usda/current/CropProdSu/CropProdSu-01-1
2-2009.txt"
http://usda.mannlib.cornell.edu/usda/current/CropProdSu/CropProdSu-01-12
-2009.txt 

USDA 2009d.   US Department of Agriculture, 2007 Census of Agriculture
United States Summary and State Data Volume 1, Geographic Area Series,
Part 51.   February 2009, updated September 2009.   Available here:
http://www.agcensus.usda.gov/Publications/2007/Full_Report/Volume_1,_Cha
pter_2_US_State_Level/st99_2_032_032.pdf

Attachment 8.  Water Memo from EFED.

PC Code: 038901, 038903, 038904, 038905 

DP Barcode: 356316

	

September 9, 2009

MEMORANDUM

SUBJECT:	Drinking Water Assessment for the IR-4 Tolerance Petition for
the Use of Endothall-treated Irrigation Water on a Variety of Crops

TO:		Sidney Jackson, Risk Manager

		Barbara Madden, Risk Manager

Registration Division (7505P)

FROM:	Nelson Thurman, Senior Environmental Scientist

		Environmental Risk Branch 2

		Environmental Fate and Effects Division (7507P)

THROUGH:	Tom Bailey, Branch Chief

		Environmental Risk Branch II

		Environmental Fate and Effects Division (7507P)

Summary

A drinking water exposure assessment has been conducted to support the
human health risk assessment for the proposed use of endothall-treated
irrigation water on a variety of crops.  

The maximum potential exposure of endothall in drinking water sources is
expected to result from the direct application of endothall to drinking
water reservoirs to control aquatic weeds.  EFED assumed that the entire
reservoir would be treated at the maximum rates, with no more than 10%
of the reservoir treated at one time as stated on the label, so that 10
treatments were applied 7 days apart to get the entire reservoir.  Since
the label specified that the community water system (CWS) could not
supply treated drinking water unless the residues were below 0.1 ppm
(100 µg/L), EFED assumed 100 µg/L (0.1 ppm) as the acute (peak)
exposure and the constant exposure during the treatment period and then
modeled residue decline by degradation after the final treatment.  This
resulted in a chronic (annual average) concentration of 31 µg/L (0.031
ppm) for endothall.  This represents the likely high-end chronic
exposure from endothall from the use most likely to generate the highest
exposures (treatment of a reservoir).  

Nature of Action

Endothall is an herbicide with both terrestrial and aquatic uses. 
Interregional Research Project No. 4 (IR-4) submitted field trial data
to support the use of endothall as an algaecide and aquatic herbicide in
irrigation and drainage canals.  The irrigation water would subsequently
be applied to a variety of vegetables, berries, grains, nuts, grapes,
and feed crops.  With no geographic limitations, potentially all
irrigated crops could be subject to endothall residues from treated
irrigation waters.  Endothall may be applied to irrigation canals at a
maximum single rate of 5 ppm (as endothall acid), with a maximum of 30
ppm during the growing season, with a minimum 7-day application interval
(based on both the Hydrothol 191 and Aquathol® K labels). Based on the
maximum seasonal rate, EFED assumed a maximum exposure from 6
applications at 5 ppm with 7-day intervals between applications or 10
applications at 3 ppm for the 3 ppm maximum on one label.

Endothall may also be applied to lakes, ponds, and impoundments,
including drinking water reservoirs, at rates of up to 3 ppm (Hydrothol)
to 5 ppm (Aquathol).  For submerged aquatics in lakes or ponds, no more
than 1/10 of the impounded water may be treated at one time.  The labels
state that consumption of water by the public is allowed only when the
concentration of endothall in water is less than the Maximum Contaminant
Level (MCL) of 100 µg/L (0.1 ppm).

Previous Drinking Water Exposure Assessment

In May, 2004, EFED conducted a drinking water assessment for endothall
uses on terrestrial crops in the western US (potatoes, cotton, clover,
alfalfa for seed, hops) and direct aquatic applications.  The estimated
maximum 1-in-10-year exposures from terrestrial uses were:

7.1 µg /L for the 1 in 10 year annual peak concentration (acute)  

2.5 µg /L for the 1 in 10 year annual mean concentration (non-cancer
chronic) and  

2.4 µg /L for the 36 year annual mean concentration (cancer chronic).  


Maximum ground water concentrations were less than 0.1 µg /L.

The greatest potential exposures from endothall use, however, come from
direct application to drinking water reservoirs.  Assuming 100% of the
reservoir is treated at the maximum rate, the maximum peak (single-day)
exposure could be as high as 5000 µg/l (5 ppm), based on the maximum
application rate to the reservoir. However, Endothall has a Maximum
Contaminant Level (MCL) of 100 µg/L (0.1 ppm); therefore, EPA used the
MCL as the maximum exposure level expected from direct application of
endothall to reservoirs.  Although the MCL is likely to overestimate
average (i.e., chronic) residues of endothall in drinking water, EPA
believes it provides a reasonable high-end estimate of potential acute
drinking water concentrations from the aquatic uses of endothall. For a
screening approach, EFED used the MCL of 100 µg/L (0.1 ppm) for both
the acute and chronic exposures in the dietary risk assessments.  The
2005 Revised Human Health Risk Assessment for the RED indicated that
chronic dietary exposure assuming an average 100 ppb concentration for
endothall accounted for 99% of the cPAD for infants <1 yr old and 45% of
the cPAD for children 1-2. 

Summary of Environmental Fate Properties of Endothall

The environmental fate and transport properties of endothall are
described in the 2005 EFED environmental fate and ecological risk
assessment.  This section briefly summarizes the RED characterization.
Endothall exists in three forms in the environment: endothall
dipotassium, endothall potassium cation, and endothall acid.  These
chemical forms are highly soluble and mobile in the environment. 
Exposure is expressed in terms of endothall acid equivalents. 

Endothall degrades by biotic processes such as aerobic metabolism. 
Single laboratory studies measured first-order degradation half-lives of
14.5 days for aerobic soil metabolism, 10 days for aerobic aquatic
metabolism, and 9 days for anaerobic soil metabolism.  Terrestrial
dissipation studies measured dissipation half-lives from the soil
surface of 13 to 19 days.  Dissipation/disappearance half-lives in
aquatic dissipation studies ranged from 4 to 30 days (median 8.5 days)
in lab studies, and 0.5 to 20 days (median 4 days) in ponds and lakes. 
As noted in Table 1, EFED multiplied the single half-life measurement by
3 to reflect the uncertainty in the range of potential half-life values
in the field. The resultant 3X value for aquatic metabolism is within
the range of dissipation half-lives reported for the aquatic dissipation
studies while the single value is closer to the median dissipation
half-lives from the studies.  

Table 1.  Endothall Inputs Used for Drinking Water Exposure Modeling.

MODEL INPUT VARIABLE	

INPUT VALUE	

COMMENTS



Molecular Weight, g/Mol	

186.2	

2005 RED



Vapor pressure (Torr at 24.3 oC)	

 ADVANCE \d4 2.2e-10	

2005 RED



Solubility (mg/L)	

100,000	

2005 RED



Kd (ml/g)	

2.4	

Average of values in MRID 41616404



Aerobic Soil Metabolic Half-life (days)	

43.5

	

3X 14.5 day half-life based on extractable residues in MRID 44949401



Aerobic Aquatic Metabolic Half-life (days)	

30	

3X 10 day half-life based on extractable residues in MRID 42618901



Anaerobic Aquatic Metabolism half-life (days)	

27	

3X 9 day half-life based on extractable residues in MRID 42903901



Drinking Water Exposure Assessment for the Proposed Use

For chronic drinking water exposures, the 100 µg/L (0.1 ppm) MCL is the
presumable maximum threshold for surface water sources of drinking
water.  That threshold assumes that the CWS downstream of the
agricultural areas that are releasing treated irrigation canal water
into the larger water bodies are aware of the applications so they can
ensure that endothall levels stay below that threshold in the water they
release to the public.  In the event that the CWS is not aware of what's
going on upstream, it is possible that short-term exposures from
endothall may exceed the MCL because of the high rates used in treating
the waters.  For flowing water bodies, the endothall residues would
quickly dissipate downstream so that elevated exposures would only be
expected for short periods after endothall-treated irrigation water is
released to the water body. 

 

Application of endothall-treated irrigation water to crops would result
in lower exposure concentrations released to surface water sources of
drinking water due to (a) filtration of irrigation water through the
crops and soil and (b) increased time for degradation from the time of
treatment.  Estimated 1-in-10-year peak and average annual
concentrations from irrigation applications of endothall are expected to
be in the same range as those estimated for endothall applications to
terrestrial crops in the 2005 RED (up to 39 µg /L peak and 10 µg /L
annual). 

The maximum potential drinking water exposures are expected to result
from the direct application of endothall as an aquatic herbicide in a
drinking water reservoir.  In a maximum potential exposure scenario, the
entire reservoir is treated at maximum rates (3 to 5 ppm, depending on
the label), with no more than 10% of the reservoir treated at one time. 
This would result in 10 treatments of 3 ppm applied 7 days apart to get
the entire reservoir (assuming a 30 ppm maximum seasonal rate).  The
labels state that consumption of water by the public is allowed only
when the concentration of endothall in water is less than the MCL of 100
µg/L (0.1 ppm).  At the maximum rates, even with a 600-foot setback
from the drinking water intake, endothall residues may exceed the MCL
for one or a few days after application. However, based on the label
specifications, the water cannot be released for public consumption
until the concentration is less than the MCL. Thus, the maximum peak
concentration of endothall residues would be 100 µg/L (0.1 ppm).

Given the degradation/dissipation rates of endothall, the concentrations
will likely decline fairly quickly once treatments have ended, even in
the most static of reservoirs.  So longer-term average exposures will
likely be well below the MCL. 

For chronic exposures, EFED used the following estimates:

an assumed 100 µg/L (0.1 ppm) concentration during the 70-day treatment
window

first-order degradation, based on a 30-day aquatic metabolism half-life
(3X the single measured value provided by the registrant), using the 

			Ct = C0e-kt   

where Co = initial concentration, k =  first-order degradation rate
(hr-1), and  t = time.

The calculated daily concentrations were averaged over the year to
generate a chronic (annual average) concentration of 31 µg /L (0.031
ppm) for endothall.  This would represent the likely high-end chronic
exposure from endothall from the use that is most likely to generate the
highest exposures (treatment of a drinking water reservoir).  

To characterize the range in potential exposures, EFED varied the
degradation/ dissipation half-life (30 days vs 10 days) and included an
estimate of reservoir flow-through rates, similar to the approach in the
2004 EFED drinking water assessment.  These are summarized in Table 2. 
The FL reservoir had the greatest flow-through rates (see the 2004 EFED
drinking water assessment for details).

Table 2: Range in estimated annual average concentrations of endothall
residues based on varying degradation rates and reservoir flow-through
rates.

Exposure Scenario	Annual average (chronic) concentration 

(µg /L)

Endothall degradation half life (da) / rate (da-1)	Flow-through (m3/hr)
/ equiv turnover rate (da-1)	Effective dissipation rate (da-1)

	Static reservoir (no water flow-through)

30 da / 0.0231	0	0.0231	31 (0.031 ppm)

10 da / 0.0693	0	0.0693	23 (0.023 ppm)

FL reservoir (FL sugarcane scenario)

30 da / 0.0231	121 m3/hr / 0.0201	0.0432	25 (0.025 ppm)

10 da / 0.0693	121 m3/hr / 0.0201	0.0894	22 (0.022 ppm)



Livestock Drinking Water Exposure Assessment

To evaluate potential endothall residues in milk/dairy products, HED
asked EFED for an estimate of potential endothall residues in
livestock/animal drinking water.  The highest exposures would come from
a static pond with no water flow-through.  Endothall would soon be
diluted out of any water body with flow in it (canals, etc) and, even
with multiple applications, the higher concentrations would soon be
moving away from the source.

The labels have certain waiting periods before treated water could be
used for animal consumption depending on the application rate:

Applied 0.3 ppm – 7 days after application

Applied 3.0 ppm – 14 days after application

Applied 5.0 ppm – 25 days after application

The estimated concentrations use the simple first-order degradation
model, assuming either static (no flow) or varying water turnover rates
in the farm water body.  Endothall concentrations degraded with a
first-order model starting immediately after application. No water was
consumed during the specified waiting periods; annual average
concentrations reflect daily concentrations beginning after the waiting
period.  The uncertainty in the estimates is bound by the range in
potential degradation rates of endothall and the potential water
turnover rates for the water body.  At the high end of the half-life
range in water (30 days), average annual water exposures in static water
bodies are 0.26 and 0.35 ppm, for the 3 and 5 ppm treatments
respectively; at the low-end (10 days) of the half-life range, average
water exposures are below 0.1 ppm.  

Table 3: Range in estimated annual average concentrations of endothall
residues in livestock water ponds based on varying degradation rates and
flow-through rates.

Exposure Scenario	Annual average concentration,

mg /L (ppm)

Endothall degradation half life (da)	Pond turnover rate (% daily
turnover)	Effective dissipation rate (da-1)	0.3 ppm applied	3 ppm
applied	5 ppm applied

Single application

30 da 	0%	0.0231	0.03	0.26	0.35

	1%	0.0331	0.02	0.16	0.19

	5%	0.0731	0.007	0.04	0.03

10 da	0%	0.0693	0.007	0.04	0.04

	1%	0.0793	0.006	0.03	0.02

	5%	0.1193	0.003	0.01	0.006

3 applications spread throughout the year (1, 123, 245 days)

30 da	0%	0.0231	0.09	0.82	0.78

	1%	0.0331	0.06	0.51	0.44

	5%	0.0731	0.02	0.13	0.07

10 da	0%	0.0693	0.02	0.15	0.08

	1%	0.0793	0.02	0.11	0.06

	5%	0.1193	0.009	0.04	0.01

6 applications at 7-day treatment intervals w/ no consumption during
treatment

30 da	0%	0.0231	0.12	1.06	1.42

	10%	0.1231	0.002	0.01	0.004

10 da	0%	0.0693	0.01	0.08	0.06

	10%	0.1693	0.001	0.002	0.001



In most instances, some water turnover/exchange (replenishment with rain
and/or runoff) occurs in a farm pond over time.  Ranges of 1 to 5%
turnover on a daily basis is not uncommon.  At a 5% water exchange rate
for a pond, the year-long average concentrations for the 3 rate/waiting
period combinations were below 0.2 ppm.  Table 3 also provides average
annual concentration estimates for a variety of multiple application
scenarios.  Each of the scenarios assume that the waiting period is
enforced between trea

 Registrant submission: 47520713.  Arsenovic, M. (2008) Endothall
(Hydrothol 191): Magnitude of the Residue on Grain Cereal Group (Except
Rice): Lab Project Number: Z9768. Unpublished study prepared by
Interregional Research Project No. 4.  590 pages.  

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e the implied yield estimate is slightly higher than the dryland yield. 
The difference is less than 3%.  

 “Drinking Water Assessment for Endothall for both Terrestrial and
Aquatic Uses”.  Memorandum from James Breithaupt, EFED, to Susan Lewis
and Pat Dobak, SRRD, May 5, 2004.

 “Endothall: Revised Human Health Risk Assessment. HED Chapter of the
Reregistration Eligibility Decision Document (RED)”. Memorandum from
Zendzian et al, HED, to Mika Hunter, SRRD, 09/30/05.

 “Environmental Fate and Ecological Risk Assessment of Endothall -
Revised”. Memorandum from Embry et al, EFED, to Mika Hunter, SRRD,
April 22, 2005.

Endothall	Dietary Exposure and Risk Assessment	DP Number: 370449	

PC Codes:  038901, 038904 and 038905		

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