To
HSRB
Members
cc
Subject
Fw:
HSRB
review
of
agricultural
handler
task
force
protocol
AH
37
Dear
Board
members,

Following
the
June
2006
HSRB
meeting,
the
HSRB
Chair
requested
additional
information
concerning
agricultural
hand
task
force
protocol
AH
37.
Below
is
the
question
presented
to
EPA
and
their
response.

Paul
Paul
I.
Lewis,
Ph.
D.
Executive
Director
Human
Studies
Review
Board
United
States
Environmental
Protection
Agency
202
564
8381
lewis.
paul@
epa.
gov
­­­­­
Forwarded
by
Paul
Lewis/
DC/
USEPA/
US
on
08/
02/
2006
03:
27
PM
­­­­­

Jack
Housenger/
DC/
USEPA/
US
08/
02/
2006
03:
23
PM
To
Paul
Lewis/
DC/
USEPA/
US@
EPA
cc
fisher@
fordham.
edu
Subject
Re:
HSRB
review
of
agricultural
handler
task
force
protocol
AH
37
Paul,
Sorry
for
the
delay
in
responding
to
your
request.
This
is
in
response
to
your
question
as
to
whether
open
pour
a
application
using
an
open
cab
are
permitted
for
diazinon
to
treat
trellis
crops.
You
are
correct
in
pointing
out
that
the
Agency's
interim
reregistration
decision
on
diazinon
indicated
the
need
for
engineering
controls
for
both
mixing/
loading
and
application
activities
due
to
the
concerns
regarding
the
level
of
risk
without
such
controls.
This
decision
meant
tha
order
for
diazinon
to
be
considered
eligible
for
reregistration,
these
changes
would
have
to
be
made
to
current
registrations/
labels.

The
Board's
question
regarding
this
issue
raises
an
important
point
that
the
Agency
had
not
considered
in
its
review
of
protocol
submitted
by
the
Agricultural
Handlers
Exposure
Task
Force
i.
e.,
whether
diazinon
should
be
used
in
this
protocol
in
a
manner
that
is
not
consistent
with
our
decisions
in
the
IRED.
The
Agency
will
inform
the
Task
Force
of
th
concern
and
that
it
should
identify
another
pesticide
in
its
protocol
to
evaluate
exposures
associated
with
open
pour
activities
and
application
using
an
open
cab.
Additionally,
the
Task
Force
will
be
informed
that
whatever
pesticides
are
proposed
to
be
used
pursuant
to
any
of
the
protocols,
use
must
comply
with
the
most
current
risk
mitigation
measures
specified
in
IREDs
and
REDs.

Please
let
me
know
if
you
have
any
additional
questions.

Jack
E.
Housenger,
Associate
Director
Health
Effects
Division
Office
of
Pesticide
Programs
703­
308­
8163
Visit:
http://
www.
epa.
gov/
pesticides/
­­­­­
Forwarded
by
Jack
Housenger/
DC/
USEPA/
US
on
07/
26/
2006
08:
22
AM
­­­­­

Paul
Lewis/
DC/
USEPA/
US
07/
21/
2006
11:
37
AM
To
Jack
Housenger/
DC/
USEPA/
US@
EPA
cc
fisher@
fordham.
edu
Subject
HSRB
review
of
agricultural
handler
task
force
protoco
AH
37
Dear
Jack,

The
HSRB
Chair
has
requested
additional
information
concerning
the
Agricultural
Handlers
Exposure
Task
Force
protocol
AHE37.
As
you
know,
AHE37
involves
handling
a
wettable
powder
(
50WP)
formulation
of
diazinon.
Workers
will
be
monitored
during
open
cab
trellis
crop
airblast
applications
and
open
pour
mixing­
loading
operation
The
May
2004
IRED
for
diazinon
states
that
engineering
controls
are
required
during
handling.
Below
are
specific
excerpts
from
that
document:

1.
From
IRED
Facts
for
Diazinon,
p.
3
(
May
2004)
"
All
application
equipment
must
use
lock
and
load
engineering
controls.
All
wettable
powder
formulations
must
be
packaged
in
water­
soluble
bags.
Closed
cabs
are
required
all
ground
equipment,
except
for
applications
to
apples.

2.
From
Letter
to
Registrant,
May
13,
2004
"
The
requirement
of
closed
cab
equipment
for
application
of
diazinon
to
apples
is
being
waived;
instead,
applicato
will
be
required
to
wear
maximum
personal
protective
equipment.
Apples
are
a
high
benefit
use,
and
use
of
closed
cabs
is
infeasible
in
narrow
orchard
rows."

3.
From
Diazinon
IRED
Executive
Summary
(
May
2004)

"
Occupational
exposure
to
diazinon
is
of
concern
to
the
Agency.
For
agricultural
uses
of
diazinon,
most
mixer/
loader/
applicator
risk
scenarios
currently
exceed
the
Agency's
level
of
concern
(
i.
e.,
MOEs
are
less
than
100
dermal
exposure
and
MOEs
are
less
than
300
for
inhalation
exposure).
Taking
into
consideration
both
the
risks
an
benefits
of
these
uses,
EPA
has
determined
that
most
agricultural
uses
may
continue
with
the
adoption
of
the
following
mitigation
measures:
.
.
.
engineering
controls
for
mixers
and
loaders
and
closed
cabs
for
applicators
for
a
application
scenarios
.
.
.
"

The
above
statements
indicate
that
open
pouring
of
diazinon
is
not
permitted,
and
that
open
cab
airblast
applications
are
not
permitted
in
trellis
crops.
Please
indicate
whether
this
conclusion
is
correct.
We
would
appreciate
your
response
as
soon
possible
in
order
for
the
Board
to
complete
their
report
in
a
timely
fashion.
For
y
information,
I
will
share
your
response
with
the
HSRB
Chair,
HSRB
members
and
ORD
docket.
Thank
you.

Sincerely,

Paul
