Page 1 of 91 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES November 17, 2005 Memorandum SUBJECT: Triadimefon: Occupational and Residential Exposure Assessment for the Reregistration Eligibility Decision Document.

FROM: Shanna Recore, Industrial Hygienist Reregistration Branch 2 Health Effects Division ( 7509C)

THROUGH: Alan Nielsen, Senior Scientist Reregistration Branch 2 Health Effects Division ( 7509C)

TO: Richard Griffin, Biologist Reregistration Branch 2 Health Effects Division ( 7509C)

PC Code: 109901 DP Barcode: 314814 ( Occupational) 315040 ( Residential)

The attached assessment is the occupational and non occupational ( residential) exposure and risk estimates for triadimefon to support HED's reregistration eligibility decision ( RED) document. The data analysis included in this assessment was prepared by Versar, Inc under the supervision of HED. The assessment was reviewed by HED's Science Council for Exposure ( ExpoSAC) to ensure compliance with current HED policy as well as ExpoSAC standard operating procedures ( SOPs) for conducting occupational and residential exposure ( ORE) Page 2 of 91 assessments. Page 3 of 91 Table of Contents Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1.0 Occupational and Residential Exposure/ Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . 6 1.1 Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.2 Criteria for Conducting Exposure Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.3 Summary of Hazard Concerns for Triadimefon . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.4 Incident Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 1.5 Summary of Physical and Chemical Properties of Triadimefon . . . . . . . . . . . . . . 9 1.6 Summary of Use Patterns and Formulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 1.6.1 End Use Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 1.6.2 Registered Use Categories and Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 1.6.3 Application Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 2.0 Occupational Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.1 Occupational Handler Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.1.1 Data and Assumptions for Handler Exposure Scenarios . . . . . . . . . . . . . 16 <IP_ADDRESS>Assumptions for Handler Exposure Scenarios . . . . . . . . . . . . . . 16 <IP_ADDRESS>Exposure Data for Handler Exposure Scenarios . . . . . . . . . . . . . 17 Triadimefon Handler Exposure Scenarios . . . . . . . . . . . . . . . . . . . . . . . 23 2.1.3 Noncancer Triadimefon Handler Exposure and Assessment . . . . . . . . . . 24 <IP_ADDRESS> Noncancer Triadimefon Handler Exposure and Risk Calculations 24 <IP_ADDRESS> Triadimefon Noncancer Risk Summary ( using PHED, ORETF, and proprietary data) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 2.1.4 Cancer Triadimefon Handler Exposure and Risk Assessment . . . . . . . . . 62 2.1.5 Summary of Risk Concerns and Data Gaps for Occupational Handlers . 62 <IP_ADDRESS> Summary of Risk Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 <IP_ADDRESS> Summary of Data Gaps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 62 2.1.6 Recommendations For Refining Occupational Handler Risk Assessment 62 2.2 Occupational Postapplication Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . 62 2.2.1 Occupational Postapplication Exposure Scenarios . . . . . . . . . . . . . . . . . 63 2.2.2 Data/ Assumptions for Postapplication Exposure Scenarios . . . . . . . . . . 66 2.2.3 Occupational Postapplication Exposure and Noncancer Risk Estimates . 66 2.2.3 Noncancer Risk Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67 2.2.4 Occupational Postapplication Exposure and Risk Estimates for Cancer . 69 2.2.5 Summary of Occupational Postapplication Risk Concerns and Data Gaps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69 2.2.6 Recommendations for Refining Occupational Postapplication Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 3.0 Residential and Other Non Occupational Exposures and Risks . . . . . . . . . . . . . . . . . . . 70 3.1 Residential Handler Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 3.1.1 Handler Exposure Scenarios . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 70 Page 4 of 91 3.1.2 Data and Assumptions For Handler Exposure Scenarios . . . . . . . . . . . . 71 3.1.3 Residential Handler Exposure and Noncancer Risk Estimates . . . . . . . . 75 3.1.4 Residential Handler Exposure and Risk Estimates for Cancer . . . . . . . . 79 3.1.5 Summary of Risk Concerns and Data Gaps for Handlers . . . . . . . . . . . . 79 3.1.6 Recommendations for Refining Residential Handler Risk Assessment . . 80 3.2 Residential Postapplication Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . . 80 3.2.1 Residential Postapplication Exposure Scenarios . . . . . . . . . . . . . . . . . . 80 3.2.2 Data and Assumptions for Residential Postapplication Exposure Scenarios . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 83 3.2.3 Residential Postapplication Exposure and Noncancer Risk Estimates . . . 85 3.2.4 Residential Postapplication Exposure and Risk Estimates for Cancer . . . 92 3.2.5 Summary of Residential Postapplication Risk Concerns and Data Gaps 93 3.2.6 Recommendations for Refining Residential Postapplication Risk Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 93 Page 5 of 91 Executive Summary Triadimefon is an systemic fungicide used in agricultural, commercial, and residential settings in the United States. It is formulated as an emulsifiable concentrate, wettable powder, water soluble packet, water dispersible granule ( dry flowable), and granular.

Hazard Concerns: The toxicological endpoints used to complete the occupational and residential risk assessment were based on the best professional judgement of HED toxicologists. Adverse effects were identified at durations of exposure ranging from short term ( up to 30 days) to intermediate term durations (> 30 days up to 6 months) and long term durations (> 6 months). No cancer endpoint was identified, therefore, cancer risks are not assessed.

The short and intermediate term ( noncancer) dermal risk assessment for triadimefon is based on a NOAEL of 300 mg/ kg/ day from a dermal study. The short and intermediate term ( noncancer) inhalation risk assessment for triadimefon is based on a NOAEL of 3.4 mg/ kg/ day, which is based on an oral neurotoxicity study. Long term exposure to triadimefon is not expected for current registered uses. HED's level of concern ( LOC) for occupational triadimefon dermal and inhalation exposures is 100   that means that a margin of exposure ( MOE) less than 100 exceeds HED's level of concern. The level of concern for occupational scenarios is based on 10x for interspecies extrapolation and 10x for intraspecies extrapolation. HED's level of concern ( LOC) for nonoccupational ( residential) triadimefon dermal and inhalation exposures is 1000   that means that a margin of exposure ( MOE) less than 1000 exceeds HED's level of concern for residential scenarios. The level of concern for residential scenarios is based on 10x for interspecies extrapolation, 10x for intraspecies extrapolation, and an additional 10x for database uncertainty. The dermal endpoint is based on a dermal study, therefore no dermal absorption adjustment is needed. The toxicological effects that are the basis of the dermal endpoint were observed only in females. Therefore, the body weight of an average female adult ( i. e., 60 kg) was used to estimate dermal dose. The inhalation endpoint is based on an oral neurotoxicity study and 100 percent inhalation absorption is assumed. The toxicological effects that are the basis of the inhalation endpoint were observed both in males and females. Therefore, the body weight of an average adult ( i. e., 70 kg) was used to estimate inhalation dose. The dermal and inhalation margins of exposure were combined for the triadimefon risk assessment because the toxicity endpoints for the dermal and inhalation routes of exposure are based on the same toxicological effects.

Use Patterns: Large scale applications of triadimefon are applied with several types of application equipment, including aircraft, groundboom sprayers, airblast sprayers, tractor drawn spreaders, and chemigaton. Applications to smaller areas may be made with handheld equipment, including low pressure handwand sprayers, handgun sprayers, and push type spreaders. In addition, triadimefon is applied to seeds using both on nursery and commercial seed treatment equipment.

Occupational Handler Risks: It has been determined that exposure to pesticide handlers is likely during the occupational use of triadimefon in a variety of occupational environments. The Page 6 of 91 anticipated use patterns and current labeling indicate several occupational exposure scenarios based on the types of equipment and techniques that can potentially be used for triadimefon applications. In most non seed treatment scenarios, risks were not a concern for dermal or inhalation exposures using some level of risk mitigation. However, one scenario remained a concern with maximum dermal and/ or inhalation risk mitigation: mixing/ loading/ applying wettable powders with a low pressure handwand for applications to turf ( LCO and golf course).

In all the on nursery seed treatment scenarios, dermal and inhalation MOEs met or exceeded the required uncertainty factor of 100 at some level of risk mitigation. For commercial seed treatment, all dermal MOEs met or exceeded the required uncertainty factor at some level of mitigation, and most inhalation MOEs met or exceeded the required uncertainty factor. However, risks remained a concern at the highest level of risk mitigation for treatment of ponderosa pine seed for mixers/ loaders/ applicators and for persons performing multiple seed treatment activities.

Occupational Postapplication Risks: Triadimefon can be used on agricultural ( including ornamental) crops. As a result, a wide array of individuals can potentially be exposed by working in areas that have been previously treated. To develop a postapplication assessment, HED considers the types of tasks and activities that individuals are likely to be doing in areas recently treated with a pesticide. In agricultural crop settings ( including ornamentals grown for sale), the use of personal protective equipment or other types of equipment to mitigate postapplication exposures to workers is not considered a viable alternative for the regulatory process. Instead, an administrative approach   a Restricted Entry Interval or REI   is used to mitigate postapplication risks following applications to crops. The REI is a time period following a pesticide application during which entry into the treated area is restricted. Postapplication risk levels are generally calculated in the risk assessment process on a chemical, crop, and activity specific basis. To establish REIs, HED considers postapplication risks on varying days after application. The results of the occupational postapplication exposure and risk assessment indicates that postapplication risks are not a concern on day 0 ( 12 hours following application) for all crops.

Residential Handler Risks: HED determined that exposure to pesticide handlers is likely during the residential use of triadimefon in a variety of outdoor environments, including on lawns, gardens, and ornamentals. The anticipated use patterns and current labeling indicate several residential handler exposure scenarios based on the types of equipment and techniques that can potentially be used to make triadimefon applications. The quantitative exposure/ risk assessment developed for residential handlers is based on these scenarios. Dermal risks for residential handlers are not a concern for all, except one, triadimefon residential handler scenarios Dermal risks were a concern for mixing/ loading/ applying liquid concentrates with a hose end sprayer to home lawns. The inhalation risks for residential handlers are not a concern for all residential uses of triadimefon.

Residential Postapplication Risks: HED determined there is a potential for exposure from entering triadimefon treated residential areas, such as lawns, golf courses, and home gardens that could lead to exposures to adults and children. In the residential postapplication exposure and risk assessment, HED has a number of risk concerns for triadimefon. Page 7 of 91 1.0 Occupational and Residential Exposure/ Risk Assessment 1.1 Purpose This document is the occupational and residential non dietary exposure and risk assessment for triadimefon from its use as a systemic fungicide. In this document, which is for use in EPA's development of the HED chapter of the triadimefon RED Document, EPA presents the results of its review of the potential human health effects of occupational and residential/ nonoccupational exposure to triadimefon.

1.2 Criteria for Conducting Exposure Assessments An occupational and/ or residential exposure assessment is required for an active ingredient if ( 1) certain toxicological criteria are triggered and ( 2) there is a potential for exposure to handlers ( mixers, loaders, applicators) during use or to persons entering treated sites or exposed to vapors after application is complete. Toxicological endpoints were selected for short and intermediate term dermal and inhalation exposures to triadimefon. There is a significant potential for exposure in a variety of occupational agricultural and commercial settings as well as in residential settings. Therefore, risk assessments are required for occupational and residential handlers as well as for occupational and residential postapplication exposures that can occur as a result of triadimefon use.

1.3 Summary of Hazard Concerns for Triadimefon The toxicological endpoints used to complete the occupational and residential risk assessment were based on the best professional judgement of HED toxicologists. Adverse effects were identified at durations of exposure ranging from short term ( up to 30 days) to intermediate term durations (> 30 days up to 6 months) and long term durations (> 6 months). No cancer endpoint was identified, therefore, cancer risks are not assessed.

Triadimefon is an systemic fungicide where the use patterns can vary widely ranging from short term through intermediate term exposure durations. As such, when the HIARC evaluated the triadimefon hazard database, endpoints were selected to address each duration of exposure. Triadimefon exposures are expected to occur to both occupational and residential users.

Dermal Route ( noncancer)

The short and intermediate term ( noncancer) dermal risk assessment for triadimefon is based on an NOAEL of 300 mg/ kg/ day from a dermal study. The NOAEL was based on increased reactivity and activity in the females. Long term exposures to triadimefon ( i. e., greater than 6 months) are not expected for current registered uses.

Inhalation Route ( noncancer) Page 8 of 91 The short and intermediate term ( noncancer) inhalation risk assessment for triadimefon is based on an NOAEL of 3.4 mg/ kg/ day, which is based on a subchronic neurotoxicity study. The NOAEL was based largely on hyperactivity in both males and females. Long term exposure to triadimefon ( i. e., greater than 6 months) is not expected for current registered uses.

Incidental Oral Route ( noncancer)

The short term ( noncancer) incidental oral risk assessment for triadimefon is based on an NOAEL of 3.4 mg/ kg/ day, which is based on a subchronic neurotoxicity study. The NOAEL was based largely on hyperactivity in both males and females.

Noncancer Level of Concern ( LOC)

HED's level of concern ( LOC) for occupational triadimefon dermal and inhalation exposures is 100 ( i. e., a margin of exposure ( MOE) less than 100 exceeds HED's level of concern). The level of concern is based on 10x for interspecies extrapolation, and 10x for intraspecies extrapolation. HED's level of concern ( LOC) for nonoccupational ( residential) triadimefon dermal and inhalation exposures is 1000 ( i. e., a margin of exposure ( MOE) less than 1000 exceeds HED's level of concern). The level of concern is based on 10x for interspecies extrapolation, 10x for intraspecies extrapolation, and 10x for database uncertainty.

Aggregation The dermal and inhalation margins of exposure were combined for the triadimefon risk assessment because the toxicity endpoints for the dermal and inhalation routes of exposure are based on the same toxicological effects.

Cancer No cancer endpoint was identified.

Acute Toxicity Triadimefon is classified as category III for acute oral and acute dermal toxicity and category IV for inhalation toxicity. It is classified as category IV for eye irritation potential and for skin irritation potential. Results were positive for dermal sensitization in guinea pigs. The acute toxicity profile for triadimefon is presented in Table 1.

Body Weight The adverse effects for the dermal endpoint are observed only in females. Therefore, the body weight of an average female adult ( i. e., 60 kg) was used to estimate dermal dose. The adverse effects for the inhalation endpoint are observed in both males and females. Therefore, the body weight of an average adult ( i. e., 70 kg) was used to estimate inhalation dose. Page 9 of 91 Table 1. Acute Toxicity Profile  Triadimefon Guideline No. Study Type MRID( s) Results Toxicity Category 870.1100 Acute oral  rat 00264276 LD50 = 1470 mg/ kg ( Males) LD50 = 1090 mg/ kg ( Females) III 870.1200 Acute dermal rabbit 00264276 LD50 > 2000 mg/ kg III 870.1300 Acute inhalation  rat 41616002 LC50 > 3.570 mg/ L IV 870.2400 Acute eye irritation  rabbit 41782501 Slightly irritating IV 870.2500 Acute dermal irritation  rabbit 41616004 Not an irritant IV 870.2600 Skin sensitization  guinea pig 41554001 Sensitizer NA Table 2. Summary of Toxicological Doses and Endpoints for Triadimefon Exposure Scenario Dose Used in Risk Assessment, UF Special FQPA SF* and Level of Concern for Risk Assessment Study and Toxicological Effects Acute Dietary ( general population) NOAEL = 3.4 mg/ kg/ day UF = 1000 Acute RfD = 0.0034 mg/ kg/ day FQPA SF = 1X aPAD = acute RfD FQPA SF aPAD = 0.0034 mg/ kg/ day Subchronic neurotoxicity study in rats. LOAEL = 54.6/ 68.7 mg/ kg/ day based largely on hyperactivity.

Chronic Dietary ( all populations) NOAEL = 3.4 mg/ kg/ day UF = 1000 Acute RfD = 0.0034 mg/ kg/ day FQPA SF = 1X PAD = chronic RfD FQPA SF cPAD = 0.0034 mg/ kg/ day Subchronic neurotoxicity study in rats. LOAEL = 54.6/ 68.7 mg/ kg/ day based largely on hyperactivity.

Incidental Oral Short Term ( 1  30 days) NOAEL = 3.4 mg/ kg/ day UF = 1000 Residential MOE = 1000 Subchronic neurotoxicity study in rats. LOAEL = 54.6/ 68.7 mg/ kg/ day based largely on hyperactivity.

Incidental Oral Intermediate Term ( 1  6 months) NOAEL = 3.4 mg/ kg/ day UF = 1000 Residential MOE = 1000 Subchronic neurotoxicity study in rats. LOAEL = 54.6/ 68.7 mg/ kg/ day based largely on hyperactivity. Table 2. Summary of Toxicological Doses and Endpoints for Triadimefon Exposure Scenario Dose Used in Risk Assessment, UF Special FQPA SF* and Level of Concern for Risk Assessment Study and Toxicological Effects Page 10 of 91 Dermal Short Term ( 1  30 days) Dermal NOAEL = 300 mg/ kg/ day Residential MOE = 1000 Occupational MOE = 100 21 Day Dermal Toxicity in rabbits. The LOAEL= 1000 mg/ kg/ day based on increased reactivity and activity in the females.

Dermal Intermediate Term ( 1  6 months) Dermal NOAEL = 300 mg/ kg/ day Residential MOE = 1000 Occupational MOE = 100 21 Day Dermal Toxicity in rabbits. The LOAEL= 1000 mg/ kg/ day based on increased reactivity and activity in the females.

Dermal Long Term (> 6 months) Not Applicable Not Applicable Quantitative risk assessment is not required since no long term dermal exposure is expected.

Inhalation Short Term ( 1  30 days) NOAEL = 3.4 mg/ kg/ day ( Inhalation absorption rate = 100%) Residential MOE = 1000 Occupational MOE = 100 Subchronic neurotoxicity study in rats. LOAEL = 54.6/ 68.7 mg/ kg/ day based largely on hyperactivity.

Inhalation Intermediate Term ( 1  6 months) NOAEL = 3.4 mg/ kg/ day ( Inhalation absorption rate = 100%) Residential MOE = 1000 Occupational MOE = 100 Subchronic neurotoxicity study in rats. LOAEL = 54.6/ 68.7 mg/ kg/ day based largely on hyperactivity.

Inhalation Long Term (> 6 months) Not Applicable Not Applicable Quantitative risk assessment is not required since no long term exposure is expected.

Cancer ( oral, dermal, inhalation) Classification: Category C " possible human carcinogen" based on statistically significant increase in thyroid adenomas in male Wistar rats and statistically significant increases in hepatocellular adenomas in both sexes of the NMRI mouse.

1.4 Incident Reports An analysis of incidence reports will be included in a separate memo by Jerome Blondell.

1.5 Summary of Physical and Chemical Properties of Triadimefon Summary of physical and chemical properties for triadimefon will be included in ta separate memo by Yvonne Barnes.

1.6 Summary of Use Patterns and Formulations Page 11 of 91 1.6.1 End Use Products Triadimefon is a widely used systemic fungicide in the United States. It is used in agricultural, commercial, and residential settings. Triadimefon is formulated as an emulsifiable concentrate, wettable powder, water soluble packet, water dispersible granule ( dry flowable), and granular.

1.6.2 Registered Use Categories and Sites An analysis of the current labeling and available use information was completed by Special Review and Reregistration Division. Triadimefon is registered for use in a variety of occupational and residential scenarios ( see Tables 3 and 4) and thus both occupational and residential populations could be potentially exposed while performing triadimefon applications. It is also possible for occupational and residential populations to be exposed to triadimefon during postapplication time periods.

Table 3: Summary of Maximum Application Rates for Registered Triadimefon Commercial and Agricultural Uses Crop Target Formulationa Maximum Application Rate Application Equipment ( Area Treated or Amount Handled Daily)

Apples, Pears ( noncommercial Foliage WSP, WP 0.25 lb ai/ acre or 0.00062 lb ai/ gal aerial, airblast low pressure handwand, handgun ( WP only)

Azaleas ( for control of pine twisting rust only) Foliage WDG, WP, WSP 0.005 lb ai/ gal chemigation, groundboom, low pressure handwand, high pressure handwand Christmas trees Foliage WP 0.25 lb ai/ acre aerial, airblast Grapes Foliage L 0.125 lb ai/ acre airblast, aerial, groundboom, low pressure handwand WP 0.00094 lb ai/ gal low pressure handwand, handgun Grapes Foliage WP, WSP 0.188 lb ai/ acre aerial, airblast, groundboom Non commercial greenhouse ornamentals ( flowering, shrubs, trees) WP 0.00625 lb ai/ gal low pressure handwand WSP 0.00625 lb ai/ gal low pressure handwand, high pressure handwand, handgun L 0.00938 lb ai/ gal Table 3: Summary of Maximum Application Rates for Registered Triadimefon Commercial and Agricultural Uses Crop Target Formulationa Maximum Application Rate Application Equipment ( Area Treated or Amount Handled Daily)

Page 12 of 91 Ornamentals ( flowering, shrubs, trees) Foliage L 0.0023 lb ai/ gal low pressure handwand, high pressure handwand, handgun WDG, WP 0.0025 lb ai/ gal chemigation, groundboom, low pressure handwand, high pressure handwand Ornamentals ( shade trees and wood shrubs) Trunk L 0.000075 lb ai/ inch of trunk RTU micro injection unit 0.000026 lb ai/ inch of trunk Injection Pine ( including Christmas trees) Foliage L 0.0023 lb ai/ gal handgun, low pressure handwand Pine ( seedlings) Soil ( preplant RTU  Briquette 0.00019 lb ai/ seedling ( 1 briquette per seedling) mechanical equipment Foliage WP, WSP 0.5 lb ai/ acre aerial, airblast, groundboom, handgun, low pressure handwand Pine Seed ( nurseries) Seeds WP 0.0000625 lb ai/ gal soak/ dip treatment 0.13 lb ai/ 100 lb seeds commercial treater Pineapple ( post harvest or per plant crown) Fruit or Crown WP 0.0028 lb ai/ gal dip or spray Raspberries ( only in CA) Foliage WP, WSP 0.125 lb ai/ acre airblast, groundboom Roses Foliage L 0.00029 lb ai/ gal handgun, low pressure handwand, high pressure handwand Turf Foliage G 2.6 lb ai/ acre aerial, tractor drawn spreader L 0.64 lb ai/ acre groundboom, low pressure handwand Turf Foliage WDG 2.7 lb ai/ acre aerial, chemigation, groundboom, low pressure handwand, handgun, rights of way sprayer ( WP and WSP only) Table 3: Summary of Maximum Application Rates for Registered Triadimefon Commercial and Agricultural Uses Crop Target Formulationa Maximum Application Rate Application Equipment ( Area Treated or Amount Handled Daily)

Page 13 of 91 WP, WSP 5.4 lb ai/ acre aerial, chemigation, groundboom, low pressure handwand, handgun, rights of way sprayer ( WP and WSP only)

Turf ( golf course) G 1.36 lb ai/ acre tractor drawn spreader, push type spreader a WSP = water soluble packet; WP = wettable powder; L = Liquid concentrate; G = granular; WDG = water dispersible granule; RTU = ready to use liquid Table 4: Summary of Maximum Application Rates for Registered Triadimefon Residential Uses Crop Target Formulationa Maximum Application Rate Application Equipment ( Area Treated or Amount Handled Daily)

Apples, Pears Foliage WP 0.00062 lb ai/ gal low pressure handwand, hose end sprayer Azalea ( for control of pine twisting rust only) Foliage WP 0.005 lb ai/ gal Grapes Foliage WP 0.00094 lb ai/ gal Greenhouse ornamentals ( flowering, shrubs, trees) Foliage WP 0.00625 lb ai/ gal L 0.00938 lb ai/ gal Ornamentals ( flowering, shrubs, trees) Foliage WP 0.0025 lb ai/ gal L 0.0023 lb ai/ gal Ornamentals ( shade trees and woody shrubs) Foliage L 0.000026 lb ai/ inch of trunk injection Pines Foliage L 0.0023 lb ai/ gal low pressure handwand, hose end sprayer Roses Foliage L 0.00029 lb ai/ gal Table 4: Summary of Maximum Application Rates for Registered Triadimefon Residential Uses Crop Target Formulationa Maximum Application Rate Application Equipment ( Area Treated or Amount Handled Daily)

Page 14 of 91 Turf Foliage G 5.2 lb ai/ acre push type spreader, belly grinder L 0.033 lb ai/ gal low pressure handwand, hose end sprayer a WP = wettable powder; L = Liquid concentrate; G = granular 1.6.3 Application Methods Triadimefon is applied with several types of application equipment   including aerial, groundboom, tractor drawn spreaders and chemigaton. Applications to smaller areas may be made with handheld equipment, including low pressure handwand sprayers, airblast sprayers, handgun sprayers, and push type spreaders.

In addition, triadimefon is applied to seeds during both on nursery and commercial seed treatment. The following descriptions of seed treatment and planting methods and equipment are based primarily on information provided in HED's seed treatment SOP ( SOP 14), which was developed in consultation with industry specialists.

Commercial Seed Treatment: Commercial seed treaters are designed to apply accurately measured quantities of pesticides to a given weight of seed. There are two primary methods for treating seeds: the batch system and the continuous flow system. The batch system is less automated and generates lower production volume than the continuous flow system. Seed treatment in commercial facilities occurs primarily via the highly automated continuous flow system. Treated seed is bagged by a machine which picks up a bag, opens it, and lets it fill to a predetermined weight. The bagger then folds the top of the bag, and attaches the seed grade certificates and treatment tags. The sewer then sews the bag shut using an automated sewing machine. The bag is then moved by a conveyer belt to a pallet area where it is stacked for shipping. Seed treatment workers may rotate duties to other areas. In the smaller, less automated facilities in particular, one worker will often have multiple duties within the plant.

On Nursery Seed Treatment & Planting of Treated Seed: There are various equipment used for on nursery seed treatment, such as drum mixers, homemade devices using augers, cement mixers, hand cranked revolving drums, and gravity feed systems. The more sophisticated on nursery treaters are essentially miniature versions of the commercial treaters. Simpler units consist of reusable chemical containers, a power source ( vehicle battery), valve and pump or compressed air, and tubing spray nozzles. These units are mounted directly on a truck box or wagon to dispense seed treatment directly into an auger conveyance system. Seed may be treated Page 15 of 91 as it is augered from the grower's truck to the storage bin or seeder or from the storage bin to the farmers truck or seeder. This type of enclosed on nursery treatment system is available only for liquid formulations. Analogous automated systems are not available for dust formulations based on information provided by the registrant.

The treated seed can be planted with a wide range of equipment. Common equipment types include: specialized drills with a box for small seeds and disk openers with depth bands to place the seeds at the appropriate depth followed by packer wheels to firm soil over and around seeds; double corrugated roller seeders, which drop the seed between the rollers followed by a second roller, which covers the seed and firms the soil; and booms, delivery tubes, and air pressure that blow seed onto the soil at properly spaced intervals followed by light packing, dragging a chain or harrowing to cover the planted seed. Seeding rate is determined by factors such as machine wear, seed size and shape, and crop variety.

2.0 Occupational Exposures and Risks There is a potential for exposure to triadimefon in occupational scenarios from handling triadimefon products during the application process ( i. e., mixer/ loaders, applicators, flaggers, and mixer/ loader/ applicators) and a potential for postapplication worker exposure from entering into areas previously treated with triadimefon. In addition, there is potential exposure to workers who treat seed with triadimefon in both commercial and on nursery settings and to persons who plant treated seed. As a result, risk assessments have been completed for occupational handler scenarios as well as occupational postapplication scenarios.

2.1 Occupational Handler Exposures and Risks HED uses the term " handlers" to describe those individuals who are involved in the pesticide application process. HED believes that there are distinct job functions or tasks related to applications and that exposures can vary depending on the specifics of each task. Job requirements ( e. g., amount of chemical to be used in an application), the kinds of equipment used, the target being treated, and the level of protection used by a handler can cause exposure levels to differ in a manner specific to each application event.

HED uses exposure scenarios to describe the various types of handler exposures that may occur for a specific active ingredient. The use of scenarios as a basis for exposure assessment is very common as described in the U. S. EPA Guidelines for Exposure Assessment ( U. S. EPA; Federal Register Volume 57, Number 104; May 29, 1992). Information from the current labels, use and usage information, toxicology data, and exposure data were all key components in the development of the exposure scenarios. HED has developed a series of general descriptions for tasks that are associated with pesticide applications. Tasks associated with occupational pesticide handlers are categorized using one of the following terms:

° Mixers and/ or Loaders: These individuals perform tasks in preparation for an application. For example, prior to application, mixer/ loaders would mix the triadimefon and load it into Page 16 of 91 the holding tank of the airplane or groundboom.

° Applicators: These individuals operate application equipment during the release of a pesticide product into the environment. These individuals can make applications using equipment such as airplanes or groundboom.

° Mixer/ Loader/ Applicators and or Loader/ Applicators: These individuals are involved in the entire pesticide application process ( i. e., they do all job functions related to a pesticide application event). These individuals would transfer triadimefon into the application equipment and then also apply it.

° Flaggers: These individuals guide aerial applicators during the release of a pesticide product onto an intended target.

° On Nursery Loader/ Applicator: The possible points of operator exposure for an onnursery treatment are; transport of pesticide in mobile containers, moving pesticide from storage in to seed treatment equipment, introduction of pesticide into seed treatment equipment, and equipment cleaning and maintenance. On nursery seed treatment with liquid formulations is generally done with more automated equipment, essentially miniature versions of commercial treaters. Seed may be treated as it is augured from the grower's truck to the storage bin ( at the farmstead), or from the truck to the seeder ( field) or from the grower's storage bin into either a truck or seeder.

° On Nursery Planting of Treated Seed: Planting exposures occur during both the loading of hoppers and driving the equipment.

° Commercial Mixer/ Loader/ Applicator for Seed Treatments: This scenario involves loading/ applying of all formulations in a commercial operation.

° Commercial Bagger for Seed Treatments: Seed is bagged by a machine which picks up a bag, opens it, slips it over a spout and lets it fill to a predetermined weight. The bagger then folds the top of the bag, attaches the seed grade certificates and treatment tags.

° Commercial Sewer for Seed Treatments: After bagging the treated seed the sewer shuts the bag using an automatic sewing machine. The bag is then moved by a conveyer belt to a pallet area where it is stacked for shipping.

° Multiple Commercial Activities for Seed Treatments: The SOP contains a scenario labeled " Multiple Activities" to address the potential for multiple types of exposure in small commercial operations.

A chemical can produce different effects based on how long a person is exposed, how frequently exposures occur, and the level of exposure. HED classifies exposures up to 30 days as short term and exposures greater than 30 days up to several months as intermediate term. HED Page 17 of 91 completes both short and intermediate term assessments for occupational scenarios in essentially all cases, because these kinds of exposures are likely and acceptable use/ usage data are not available to justify deleting intermediate term scenarios. Based on use data and label instructions, HED believes that occupational triadimefon exposures may occur over a single day or up to weeks at a time for many use patterns and that intermittent exposure over several weeks also may occur. Some applicators may apply triadimefon over a period of weeks, because they are custom or commercial applicators who are completing a number of applications for a number of different clients. Long term handler exposures are not expected to occur for triadimefon.

Other parameters are also defined from use and usage data such as application rates and application frequency. HED always completes noncancer risk assessments using maximum application rates for each in order to ensure there are no concerns for each specific use.

Occupational handler exposure assessments are completed by HED using different levels of risk mitigation. Typically, HED uses a tiered approach. The lowest tier is designated as the baseline exposure scenario ( i. e., long sleeve shirt, long pants, shoes, socks, and no respirator). If risks are of concern at baseline attire, then increasing levels of personal protective equipment or PPE ( e. g., gloves, double layer body protection, and respirators) are evaluated. If risks remain a concern with maximum PPE, then engineering controls ( e. g., enclosed cabs or cockpits, watersoluble packaging, and closed mixing/ loading systems) are evaluated. This approach is used to ensure that the lowest level of risk mitigation that provides adequate protection is selected, since the addition of PPE and engineering controls involves an additional expense to the user and   in the case of PPE   also involves an additional burden to the user due to decreased comfort and dexterity and increased heat stress and respiratory stress.

2.1.1 Data and Assumptions for Handler Exposure Scenarios <IP_ADDRESS> Assumptions for Handler Exposure Scenarios A series of assumptions and exposure factors served as the basis for completing the occupational handler risk assessments. Each assumption and factor is detailed below on an individual basis. The assumptions and factors used in the risk calculations include:

° Occupational handler exposure estimates were based on surrogate data from: ( 1) the Pesticide Handlers Exposure Database ( PHED), ( 2) the Outdoor Residential Exposure Task Force ( ORETF), and ( 3) HED's SOPs for Seed Treatment.

° The toxicological endpoint of concern for dermal risks is from a dermal study; with the effects seen in females, therefore, the average body weight of an adult female handler ( i. e., 60 kg) is used to complete the dermal noncancer risk assessment. The toxicological endpoint of concern for inhalation risks is from a neurotoxicity study; with the effects seen in males and females, therefore, the average body weight of an adult handler ( i. e., 70 kg) is used to complete the inhalation noncancer risk assessment. Page 18 of 91 ° Generic protection factors ( PFs) were used to calculate exposures when data were not available. For example, an 80 percent protection factor was assumed for the use of a respirator equipped with a quarter face dust/ mist filter.

° On nursery treaters and planters are expected to have a short term exposure duration ( less than 30 days) for all seed crops.

° Personal protective equipment for on nursery and commercial mixer/ loader/ applicators and planter includes a single layer and gloves. Personal protective equipment for commercial baggers and sewers includes baseline attire only  no gloves. Personal protective equipment for performing multiple activities in a commercial operation includes a single layer of clothing and gloves ° For seed treatment, it was assumed that 14,170 pine seeds are planted per acre and that enough seeds for 10,000 acres are treated per day using commercial seed treatment and enough seeds for 80 acres are treated per day using on nursery seed treatment ( Bernard Schneider, HED, personal communication).

° The weight for ponderosa seeds was estimated to be 11,350 seeds per pound ( Bernard Schneider, HED, personal communication).

° Exposure factors used to calculate daily exposures to handlers are based on applicable data, if available. For lack of appropriate data, values from a scenario deemed similar enough by the assessor might be used.

° For noncancer assessments, HED assumes the maximum application rates allowed by labels in its risk assessments ( see Tables 3 and 4).

° The average occupational workday is assumed to be 8 hours.

° The daily areas treated were defined for each handler scenario ( in appropriate units) by determining the amount that can be reasonably treated in a single day ( e. g., acres, square feet, or gallons per day). When possible, the assumptions for daily areas treated are taken from the Health Effects Division Science Advisory Committee on Exposure SOP # 9: Standard Values for Daily Acres Treated in Agriculture, which was completed on July 5, 2000. However, no standard values are available for numerous scenarios. Assumptions for these scenarios are based on HED estimates and could be further refined from input from affected sectors ( see tables 1 and 2).

There are data gaps that have been identified for some triadimefon applications. Each is identified in the calculation tables and is also noted in the summary of risk calculations.

<IP_ADDRESS> Exposure Data for Handler Exposure Scenarios Page 19 of 91 HED uses unit exposure to assess handler exposures to pesticides. Unit exposures are estimates of the amount of exposure to an active ingredient a handler receives while performing various handler tasks and are expressed in terms of micrograms or milligrams of active ingredient per pounds of active ingredient handled. HED has developed a series of unit exposures that are unique for each scenario typically considered in our assessments ( i. e., there are different unit exposures for different types of application equipment, job functions, and levels of protection). The unit exposure concept has been established in the scientific literature and also through various exposure monitoring guidelines published by the U. S. EPA and international organizations such as Health Canada and OECD ( Organization for Economic Cooperation and Development).

Pesticide Handler Exposure Database ( PHED) Version 1.1 ( August 1998): PHED was designed by a task force of representatives from the U. S. EPA, Health Canada, the California Department of Pesticide regulation, and member companies of the American Crop Protection Association. PHED is a software system consisting of two parts   a database of measured exposures for workers involved in the handling of pesticides under actual field conditions and a set of computer algorithms used to subset and statistically summarize the selected data. Currently, the database contains values for over 1,700 monitored individuals ( i. e., replicates).

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

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

The unit exposures calculated by PHED generally range from the geometric mean to the median of the selected data set. To add consistency and quality control to the values produced from this system, the PHED Task Force has evaluated all data within the system and has developed a set of grading criteria to characterize the quality of the original study data. The assessment of data quality is based on the number of observations and the available quality control data. These evaluation criteria and the caveats specific to each exposure scenario are summarized in Appendix A, Table A1. While data from PHED provide the best available information on handler exposures, it should be noted that some aspects of the included studies ( e. g., duration, acres treated, pounds of active ingredient handled) may not accurately represent labeled uses in all Page 20 of 91 cases. HED has developed a series of tables of standard unit exposure for many occupational scenarios that can be utilized to ensure consistency in exposure assessments. Unit exposures are used which represent different levels of personal protection as described above. Protection factors were used to calculate unit exposures for varying levels of personal protection if data were not available.

ORETF Handler Studies ( MRID 449722 01): A report was submitted by the ORETF ( Outdoor Residential Exposure Task Force) that presented data in which the application of various products used on turf by homeowners and lawncare operators ( LCOs) was monitored. All of the data submitted in this report were completed in a series of studies. The study that monitored LCO exposure scenarios using a low pressure, high volume turf handgun ( ORETF Study OMA002) is summarized below as is the study that monitored homeowner exposures while using a hose end sprayer ( ORETF Study OMA004).

LCO Handgun Sprayer: A mixer/ loader/ applicator study was performed by the Outdoor Residential Exposure Task Force ( ORETF) using Dacthal as a surrogate compound to determine " generic" exposures to individuals applying a pesticide to turf with a low pressure " nozzle gun" or " handgun" sprayer. Dermal and inhalation exposures were estimated using whole body passive dosimeters and breathing zone air samples on OVS tubes. Inhalation exposure was calculated using an assumed respiratory rate of 17 liters per minute for light work ( NAFTA, 1999), the actual sampling time for each individual, and the pump flow rate. All results were normalized for pounds active ingredient handled. A total of 90 replicates were monitored using 17 different subjects. Four different formulations of dacthal [ 75% wettable powder ( packaged in 4 and 24 pound bags), 75% wettable powder in water soluble bags ( 3 pound bag), 75% water dispersable granules ( 2 pound bag) and 55% liquid flowable ( 2.5 gallon container)] were applied by five different LCOs to actual residential lawns at each site in three different locations ( Ohio, Maryland, and Georgia) for a total of fifteen replicates per formulation. An additional ten replicates at each site were monitored while they performed spray application using only the 75 percent wettable powder formulation. A target application rate of 2 pounds active ingredient was used for all replicates ( actual rate achieved was about 2.2 pounds active ingredient per acre). Each replicate treated a varying number of actual client lawns to attain a representative target of 2.5 acres ( 1 hectare) of turf. The exposure periods averaged five hours twenty one minutes, five hours thirtynine minutes, and six hours twenty four minutes, in Ohio, Maryland and Georgia, respectively. Average time spent spraying at all sites was about two hours. All mixing, loading, application, adjusting, calibrating, and spill clean up procedures were monitored, except for typical end of day clean up activities, e. g. rinsing of spray tank, etc. Dermal exposure was measured using inner and outer whole body dosimeters, hand washes, face/ neck washes, and personal air monitoring devices. All test subjects wore one piece, 100 percent cotton inner dosimeters beneath 100 percent cotton long sleeved shirt and long pants, rubber boots and nitrile gloves. Gloves are typically worn by most LCOs, and required by many pesticide labels for mixing and loading. Overall, residues were highest on the upper and lower leg portions of the dosimeters. In general, concurrent lab spikes produced mean recoveries in the range of 78 120 percent, with the exception of OVS sorbent tube sections which produced mean recoveries as low as 65.8 percent. Adjustment for recoveries from field fortifications were performed on each dosimeter section or Page 21 of 91 sample matrix for each study participant, using the mean recovery for the closest field spike level for each matrix and correcting the value to 100 percent. The unit exposures are presented below. [ Note the data were found to be lognormally distributed. As a result, all exposures are geometric means.]

Table 5: Unit Exposure Values Obtained for LCO Liquid Applications with a Low Pressure Handgun from ORETF Handgun Studies ( MRID 449722 01)

Application Method4 Total Dermal Unit Exposure1 ( mg/ lb ai) Inhalation Unit Exposure1,2 ( µ g/ lb ai) Single Layer, No Gloves Single Layer, Gloves Double Layer, Gloves 3 LCO Handgun Spray Mixer/ Loader/ Applicator Liquid Flowable No Data 0.45 0.245 1.5 LCO Handgun Spray Mixer/ Loader/ Applicator Water Dispersable Granule No Data 0.68 0.37 22 LCO Handgun Spray Mixer/ Loader/ Applicator Wettable Powder in Water Soluble Bags No Data 0.68 0.37 7.2 LCO Handgun Spray Mixer/ Loader/ Applicator Wettable Powder No Data 0.80 0.43 64 LCO Handgun Spray Applicator Only Wettable Powder No Data 0.74 0.40 1.0 1 Unit exposure values reported are geometric means. 2 Air concentration ( mg/ m3/ lb ai) calculated using NAFTA ` 99 standard breathing rate of 17 lpm ( 1 m3/ hr). 3 Exposure calculated using OPP/ HED 50% protection factor ( PF) for cotton coveralls on torso, arms, legs. 4 All commercial handlers wore long pants, long sleeved shirt, nitrile gloves and shoes.

Homeowner Granular Applications with a Rotary ( Push type) Spreader ( MRID 449722 01): A mixer/ loader/ applicator study was performed by the Outdoor Residential Exposure Task Force ( ORETF) using Dacthal ( active ingredient DCPA, dimethyl tetrachloroterephthalate) as a surrogate compound to determine " generic" exposures of individuals applying a granular pesticide formulation to residential lawns. A total of 30 volunteers were monitored using passive dosimetry ( inner and outer whole body dosimeters, hand washes, face/ neck wipes, and personal inhalation monitors). Each volunteer carried, loaded, and applied two 25 lb bags of fertilizer ( 0.89% active ingredient) with a rotary type spreader to a lawn covering 10,000 ft2. The target application rate was 2 lb ai/ acre ( actual rate achieved was about 1.9 lbs ai/ acre). The average application time was 22 minutes, including loading the rotary push spreader and disposing of the empty bags. Each replicate handled approximately 0.45 lbs ai. Dermal exposure was measured using inner and outer whole body dosimeters, hand washes, face/ neck washes, and personal air monitoring devices with OVS tubes. Page 22 of 91 Table 6: Unit Exposure Values for Homeowner Granular Applications with a Rotary ( Push type) Spreader Obtained From ORETF Study ( MRID 449722 01)

Scenario Monitored Unit Exposures Dermal ( mg ai/ lb handled) Inhalation ( µ g ai/ lb handled)

Short Pants, Short Sleeves Long Pants, Short Sleeves Long Pants, Long Sleeves Homeowner Granular Applications with a Push type Spreader 0.67 0.09 0.07 0.88 1 All unit exposure values are geometric means.

Exposure data used for the triadimefon seed treatment assessment are taken primarily from HED's recently developed seed treatment standard operating procedure ( SOPs for Seed Treatment, 6/ 1/ 03) and also are based on professional judgement. The seed treatment SOP contains representative scenarios for worker exposure associated with seed treatment facilities and planting treated seed. The data contained in the SOP are mostly generated by industry sources. Exposure estimates are from actual seed treatment studies and are based on exposure factors associated with occupational handler scenarios ( i. e., commercial seed treatment, onnursery seed treatment, planting of treated seed). Eight seed treatment studies were used in developing the SOP. Given the high level of variance in the data, multiple statistical analyses were undertaken to help ensure derivation of a statistically sound exposure value for the different scenarios evaluated. For all selected seed treatment studies, replicates were combined into sets of equivalent job functions. This process resulted in four categories of commercial seed treatment activities ( loader/ applicator, sewer, bagger, and multiple activities), and two categories for onnursery activities ( treater and planter).

On Nursery Seed Treatment and Planting On Nursery Loader/ Applicator: Only one study was available to address exposure in an on nursery facility. In that study, the seed treatment formulation was dust. Exposure estimates for on nursery treatment with dust formulations are based on 1 exposure study ( MRID # 44031611). In this study four workers ( twelve replicates) mixed and applied dust formulations to winter wheat in grain drills at an application rate of 2 oz. per 120 lbs. of seed. Each replicate lasted between 19 and 33 minutes and each worker handled 22.5 ounces of active ingredient per work period. Workers loaded seed drill hoppers with wheat seed and a lindane/ maneb dust formulation. Dermal exposures were measured with patches and handwash. Inhalation exposures were measured with glass fiber filters.

On Nursery Planting of Treated Seed: Exposure estimates for loading and planting of treated seed are based on 2 exposure studies ( MRID # 42251901, 45654503). In one study, workers loaded and drilled seed treated with Baytan at 13 different sites in the UK. The seed was loaded into the drill hoppers from 0.5 or 1 ton super sacks or 50 kg bags. The amount of seed Page 23 of 91 handled ranged from 1100 to 12,100 lbs and the amount of ai handled ranged from 0.35 to 4.72 lbs. The loading time ranged from 19 to 83 minutes, while the planting time ranged from 155 to 487 minutes. The seed planting rate per acre was not given. The same worker performed both the loading and planting. Dermal exposure was measured with inner and outer whole body dosimeters which included a cap, a jacket and trousers over a long sleeve T shirt and long johns and two sets of cotton gloves. The gloves were changed at the end of loading. Inhalation exposures were measured with 37 mm glass fiber filters and the filters were changed after loading. The dermal results were adjusted by a clothing protection factor to account for the fact that 5% of the outer residues was found on the inner dosimeters.

In the second study workers loaded and drilled canola seed treated with Oftanol, which forms a hard shell coating. The 13 replicates for this study were located at one site in Manitoba using four different planting rigs. Four workers participated in the study and the replicates averaged 3.2 hours in duration. The seed was loaded into the drill hoppers from 25 kg bags. The amount of seed handled per replicate averaged 360 pounds and the amount of ai handled averaged 4.33 lbs. The seed was planted at a rate of 6 to 8 pounds per acre. The same worker performed both the loading and planting. Dermal exposure was measured with patches located both inside and outside the worker's coverall. Hand exposures were measured by hand rinse. Inhalation exposures were measured with 37 mm quartz microfiber filters.

Commercial Seed Treatment Commercial Loader/ Applicator: Exposure estimates are based on a subset of 3 exposure studies ( MRID Nos. 43080049, 42251902, 44904526). The loader/ applicator activities in these 3 exposure studies encompass a wide range of seed treaters, amounts of seed and amounts of pesticides handled for seed treatment scenarios. The three studies monitored an open loading/ applying activity for various seed treatment facilities. There are an average of 9 replicates per study ( ranging from 1 to 20 replicates per study). Two of the three studies monitored dermal exposures with patch dosimetry, hand rinses, and face wipes. The methodology in the third study was whole body dosimetry, hand rinses and face wipes.

Commercial Bagger: Exposure estimates for bagging activities for all formulations are based on data from 3 exposure studies ( MRID Nos. 43080049, 42251902, and 44904526). The studies monitored bagging treated seed in various seed treatment facilities and encompassed a wide range of bagging equipment, and amount of seed and pesticides handled. The number of replicates ranged from 1 to 20 per study. Two of the studies monitored dermal exposures with whole body dosimeters, and face, neck and hand rinses. The third used dermal patches and hand rinses to monitor exposure.

Commercial Sewer: Exposure estimates for sewing activities for all formulations are based on data from 2 exposure studies ( MRID # 430800 49, and449045 26). The two studies monitored sewing various bags of treated seed in a number of seed treatment facilities. The number of replicates ranges from 1 to 20 per study. Both of the studies monitored dermal exposures with whole body dosimeters, and face, neck and hand rinses. Page 24 of 91 Multiple Commercial Activities: Exposure estimates for multiple activities for all formulation are based on data from 4 exposure studies ( MRID # s, 454427 01, 422519 02, 449045 26 and 447315 01). These studies encompass a variety of seed treatment activity and a wide range of amount of seed pesticides handled. The four studies in this scenario monitored multiple activities for various seed treatment facilities. The number of replicates ranges from 3 to 45 per study. Three of the five studies monitored dermal exposures with whole body dosimeter, face and neck and hand rinses. The methodology in the other studies was dermal patches and hand rinses.

Triadimefon Handler Exposure Scenarios It has been determined that exposure to pesticide handlers is likely during the occupational use of triadimefon in a variety of occupational environments. The anticipated use patterns and current labeling indicate several occupational exposure scenarios based on the types of equipment and techniques that can potentially be used for triadimefon applications. The quantitative exposure/ risk assessment developed for occupational handlers is based on the following scenarios. [ Note: The scenario numbers correspond to the tables of risk calculations included in the occupational risk calculation aspects of the appendices. Triadimefon dermal and inhalation exposure was estimated using PHED or ORETF data.]

Mixer/ Loaders: ( 1a) Liquid Formulations to support Aerial Applications ( 1b) Liquid Formulations to support Groundboom Applications ( 1c) Liquid Formulations to support Airblast Applications ( 2a) Wettable Powders to support Aerial Applications ( 2b) Wettable Powders to support Chemigation Applications ( 2c) Wettable Powders to support Groundboom Applications ( 2d) Wettable Powders to support LCO Handgun Applications ( 2e) Wettable Powders to support Airblast Applications ( 2f) Wettable Powders to support Rights of Way Applications ( 3a) Water Dispersible Granules to support Aerial Applications ( 3b) Water Dispersible Granules to support Chemigation Applications ( 3c) Water Dispersible Granules to support Groundboom Applications ( 3d) Water Dispersible Granules to support LCO Handgun Applications ( 4a) Loading Granulars to support Aerial Applications ( 4b) Loading Granulars to support Tractor Drawn Spreader Applications Applicators: ( 5) Aerial Spray Applications ( 6) Aerial Granular Applications ( 7) Groundboom Spray Applications ( 8) Airblast Spray Applications ( 9) Handgun Spray Applications ( 10) Rights of Way Spray Applications Page 25 of 91 ( 11) Tractor Drawn Spreader Granule Applications Flaggers: ( 12) Flagging for Aerial Spray Applications ( 13) Flagging for Aerial Granular Applications Mixer/ Loader/ Applicators: ( 14) Liquid Formulations: Low Pressure Handwand Sprayer ( ORETF) ( 15) Wettable Powder Formulations: Low Pressure Handwand Sprayer ( PHED) ( 16) Water Dispersible Granules with Low Pressure Handwand ( using liquids ORETF data) ( 17) Liquid Formulations: Handgun Sprayer ( ORETF) ( 18) Wettable Powders with a Handgun Sprayer ( ORETF data) ( 19) Water Soluble Bags with Handgun Sprayer ( ORETF data) ( 20) Dry Flowables Concentrates with a Handgun Sprayer ( ORETF data) ( 21) Liquid Formulations: High Pressure Sprayer ( PHED) ( 22) Water Dispersible Granules: High Pressure Handwand ( PHED: liquid concentrates) ( 23) Wettable Powders: High Pressure Handwand ( PHED: liquid concentrates) ( 24) Liquids with an Tree Injector ( 25) RTU: Briquette ( 26) Liquid Formulations: Dip ( 27) Loading/ Applying Granulars via Push Type Spreader ( ORETF)

Six major exposure scenarios were identified as representative of triadimefon pine seed treatment: ( S 1) loading and applying wettable powder formulations with commercial seed treatment equipment, ( S 2) commercial sewer stitching bags of seed, ( S 3) bagging and otherwise handling treated seeds with commercial equipment, ( S 4) multiple commercial seed treatment activities, ( S 5) on nursery loading/ applying with hopper or planter box seed treatment, and ( S 6) on nursery loading/ planting previously treated seeds.

2.1.3 Noncancer Triadimefon Handler Exposure and Assessment <IP_ADDRESS> Noncancer Triadimefon Handler Exposure and Risk Calculations Daily Exposure: Daily dermal or inhalation handler exposures are estimated for each applicable handler task ( except applying impregnated collars) with the application rate, the area treated in a day, and the applicable dermal or inhalation unit exposure using the following formula: Page 26 of 91 Daily Exposure ( mg ai/ day) = Unit Exposure ( mg ai/ lb ai handled) * Application Rate ( lbs ai/ area) * Daily Area Treated ( area/ day)

Where:

Daily Exposure = Amount ( mg or ìg ai/ day) deposited on the surface of the skin that is available for dermal absorption or amount inhaled that is available for inhalation absorption; Unit Exposure = Unit exposure value ( mg or ìg ai/ day) derived from August 1998 PHED data, from ORETF data; Application Rate = Normalized application rate based on a logical unit treatment, such as acres, square feet, or gallons. Maximum values are generally used ( lb ai/ A, lb ai/ sq ft, lb ai/ gal); and Daily Area Treated = Normalized application area based on a logical unit treatment such as acres ( A/ day), square feet ( sq ft/ day), or gallons per day ( gal/ day).

Daily Dose: The daily dermal or inhalation dose is calculated by normalizing the daily exposure by body weight and adjusting, if necessary, with an appropriate dermal or inhalation absorption factor. For all dermal exposure scenarios for triadimefon, an average female adult body weight of 60 kilograms was used, since the toxicological endpoint of concern was genderspecific For dermal exposures, an absorption factor of 100% was used, since the toxicological endpoint is from a dermal study. For all inhalation exposure scenarios for triadimefon, an average adult body weight of 70 kilograms was used, since the toxicological endpoint of concern was not gender specific. For inhalation exposures, an absorption factor of 100% was assumed. Daily dose was calculated using the following formula:

Average Daily Dose ( mg/ kg/ day) = ( Daily Exposure ( mg ai/ day) * ( Absorption Factor ( 100%) / Body Weight ( kg)

Where:

Average Daily Dose = Absorbed dose received from exposure to a pesticide in a given scenario ( mg pesticide active ingredient/ kg body weight/ day); Daily Exposure = Amount ( mg ai/ day) deposited on the surface of the skin that is available for dermal absorption or amount inhaled that is available for inhalation absorption; Absorption Factor = A measure of the amount of chemical that crosses a biological boundary such as the skin or lungs (% of the total available absorbed); and Body Weight = Body weight determined to represent the population of interest in a risk assessment ( kg).

Margins of Exposure: Noncancer dermal and inhalation risks for each applicable handler scenario are calculated using a Margin of Exposure ( MOE), which is a ratio of the daily dose to the toxicological endpoint of concern. All MOE values were calculated separately for dermal and inhalation exposure levels using the formula below:

MOE = ( NOAEL ( mg/ kg/ day) / Average Daily Dose ( mg/ kg/ day)

Where: Page 27 of 91 MOE = Margin of Exposure, value used by HED to represent risk or how close a chemical exposure is to being a concern ( unitless); ADD = Average Daily Dose or the absorbed dose received from exposure to a pesticide in a given scenario ( mg pesticide active ingredient/ kg body weight/ day); and NOAEL = Dose level in a toxicity study, where no observed adverse effects ( NOAEL) occurred in the study Risk values are presented for each route of exposure ( i. e., dermal or inhalation) in each scenario, because risk mitigation measures are specific to the route of exposure.

<IP_ADDRESS> Triadimefon Noncancer Risk Summary ( using PHED, ORETF, and proprietary data)

All of the noncancer risk calculations for occupational triadimefon handlers completed in this assessment are included in the appendices. A summary of the short and intermediate term risks for each exposure scenario are presented below in Table 7. Handler risks from on nursery and commercial seed treatment are presented in Table 8 and 9, respectively.

Short and Intermediate term Dermal and Inhalation Risks In all, except one, non seed treatment scenarios, dermal and inhalation MOEs met or exceeded the required uncertainty factor of 100 at some level of risk mitigation. The inhalation risk in following scenario remains a concern with maximum inhalation risk mitigation:

° Mixing/ loading/ applying wettable powders with a low pressure handwand ( using PHED data) to turf ( LCO and golf course) ( the dermal MOE = 110 with double layer and gloves; however the inhalation MOE = 80 with a 90% protection factor half face respirator);.

In all the on nursery seed treatment scenarios, dermal and inhalation MOEs met or exceeded the required uncertainty factor of 100 at some level of risk mitigation. For commercial seed treatment, all dermal MOEs met or exceeded the required uncertainty factor at some level of mitigation. However, the inhalation risks remain a concern for two scenarios even with maximum inhalation risk mitigation:

° Loader/ applicator for ponderosa pine seed, where inhalation MOE = 43 with engineering controls); and ° Multiple activities for ponderosa pine seed, where inhalation MOE = 92 with a 90% protection factor half face respirator).

Short and Intermediate term Total Risks In all, except one, non seed treatment scenario, combined dermal and inhalation risks met or exceeded the required uncertainty factor of 100 at some level of risk mitigation. The following Page 28 of 91 scenario remains a concern with maximum dermal and inhalation risk mitigation:

° Mixing/ loading/ applying wettable powders with a low pressure handwand ( using PHED data) to turf ( LCO and golf course) where the MOE = 46 with double layer and gloves and a 90% protection factor half face respirator;

In all the on nursery seed treatment scenarios, combined dermal and inhalation MOEs met or exceeded the required uncertainty factor of 100 at some level of risk mitigation. For commercial seed treatment, none of the combined MOEs met or exceeded the required uncertainty factor at the maximum level of mitigation. Page 29 of 91 Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Mixer/ Loader Mixing/ Loading Liquid Concentrates for Aerial Applications ( 1a) grapes 0.125 350 140 4500 18000 24000 23000 45000 48000 66000 Mixing/ Loading Liquids Concentrates for Groundboom Applications ( 1b) grapes 0.125 80 620 20000 78000 110000 99000 200000 210000 290000 turf ( sod farm) 0.64 80 120 3900 15000 21000 19000 39000 41000 56000 turf ( golf course) 0.64 80 120 3900 15000 21000 19000 39000 41000 56000 Mixing/ Loading Liquids Concentrates for Airblast Applications ( 1c) grapes 0.125 40 1200 40000 160000 210000 200000 400000 420000 570000 Mixing/ Loading Wettable Powders for Aerial Applications ( 2a) apples, Christmas trees, pears 0.25 350 56 63 1200 1600 320 630 21000 11000 grapes 0.188 350 74 84 1600 2100 420 840 28000 15000 turf ( sod farm) 5.4 350 2.6 2.9 56 73 15 29 970 520 pine seedlings 0.5 350 28 32 610 790 160 320 10000 5700 Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 30 of 91 Mixing/ Loading Wettable Powders for Chemigation Applications ( 2b) azaleas 0.005 lb ai/ gallon 2400 gallons 410 460 8800 12000 2300 4600 150000 83000 turf ( sod farm) 5.4 350 2.6 2.9 56 73 15 29 970 520 ornamentals ( flowering,

shrubs,

trees) 0.25 60 320 370 7100 9200 1800 3700 120000 66000 Mixing/ Loading Wettable Powders for Groundboom Applications ( 2c) azaleas 0.005 lb ai/ gallon 16000 gallons 61 69 1300 1700 350 690 23000 12000 grapes 0.188 80 320 370 7000 9200 1800 3700 120000 66000 ornamentals ( flowering,

shrubs,

trees) 0.25 40 490 550 11000 14000 2800 5500 180000 99000 pine seedlings 0.5 80 120 140 2600 3500 690 1400 46000 25000 turf ( sod farm) 5.4 80 11 13 250 320 64 130 4300 2300 turf ( golf course) 5.4 40 23 26 490 640 130 260 8500 4600 raspberries 0.125 80 490 550 11000 14000 2800 5500 180000 99000 Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 31 of 91 Mixing/ Loading Wettable Powders to Support LCO Handgun Applications ( mixing/ loading supports 20 LCOs)

( 2d) turf ( LCO) 5.4 100 9 10 200 260 51 100 3400 1800 Mixing/ Loading Wettable Powders for Airblast Applications ( 2e) apples, Christmas trees, pears 0.25 40 490 550 11000 14000 2800 5500 180000 99000 grapes 0.188 40 650 740 14000 18000 3700 7400 240000 130000 pine seedlings 0.5 40 240 280 5300 6900 1400 2800 92000 50000 raspberries 0.125 40 970 1100 21000 28000 5500 11000 370000 200000 Mixing/ Loading Wettable Powders to Support Rights

ofway ( 2f) turf (

rightsof way) 5.4 80 11 13 250 320 64 130 4300 2300 Mixing/ Loading Dry Flowables for Aerial Applications ( 3a) turf ( sod farm) 2.7 350 290 330 290 410 1600 3300 1900 1000 Mixing/ Loading Dry Flowables for Chemigation Applications ( 3b) azaleas 0.005 lb ai/ gallon 2400 gallons 23000 26000 23000 32000 130000 260000 150000 83000 Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 32 of 91 Mixing/ Loading Dry Flowables for Chemigation Applications ( 3b)

( cont.) turf ( sod farm) 2.7 350 290 330 290 410 1600 3300 1900 1000 ornamentals ( flowering,

shrubs,

trees) 0.25 60 18000 21000 18000 26000 100000 210000 120000 66000 Mixing/ Loading Dry Flowables for Groundboom Applications ( 3c) azaleas 0.005 lb ai/ gallon 16000 gallons 3400 3900 3400 4800 19000 39000 23000 12000 turf ( sod farm) 2.7 80 1300 1400 1300 1800 7200 14000 8500 4600 turf ( golf course) 2.7 40 2500 2900 2500 3500 14000 29000 17000 9200 ornamentals ( flowering,

shrubs,

trees) 0.25 40 27000 31000 27000 38000 150000 310000 180000 99000 Mixing/ Loading Dry Flowables to Support LCO Handgun Applications ( mixing/ loading supports 20 LCOs)

( 3d) turf ( LCO) 2.7 5 20000 23000 20000 28000 110000 230000 140000 73000 Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 33 of 91 Loading Granulars for Aerial Applications ( 4a) turf ( sod farm) 2.6 350 2400 150 2900 5800 770 1500 120000 7700 Loading Granulars for Tractor Drawn Spreader Applications ( 4b) turf ( sod farm) 2.6 80 10000 670 13000 25000 3400 6700 510000 34000 turf ( golf course) 1.36 40 39000 2600 48000 97000 13000 26000 1900000 130000 Applicator Applying Sprays via Aerial Equipment ( 5) apples, Christmas trees, pears 0.25 350 No Data No Data No Data No Data No Data No Data 41000 40000 grapes 0.188 350 No Data No Data No Data No Data No Data No Data 55000 53000 turf ( sod farm) 5.4 350 No Data No Data No Data No Data No Data No Data 1900 1900 pine seedlings 0.5 350 No Data No Data No Data No Data No Data No Data 21000 20000 Applying Sprays via Aerial Equipment ( cont.) ( 5) turf ( sod farm) 2.7 350 No Data No Data No Data No Data No Data No Data 3800 3700 grapes 0.125 350 No Data No Data No Data No Data No Data No Data 82000 80000 Applying Granulars via Aerial Equipment ( 6) turf ( sod farm) 2.6 350 No Data No Data No Data No Data No Data No Data 12000 200 Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 34 of 91 Applying Sprays via Groundboom Equipment ( 7) azaleas 0.005 lb ai/ gallon 16000 gallons 16000 4000 16000 20000 20000 40000 45000 69000 grapes 0.125 80 130000 32000 130000 160000 160000 320000 360000 550000 grapes 0.188 80 85000 21000 85000 110000 110000 210000 240000 370000 turf ( sod farm) 5.4 80 3000 740 3000 3800 3700 7400 8300 13000 turf ( golf course) 5.4 40 6000 1500 6000 7600 7400 15000 17000 26000 turf ( sod farm) 2.7 80 6000 1500 6000 7600 7400 15000 17000 26000 turf ( golf course) 2.7 40 12000 3000 12000 15000 15000 30000 33000 51000 raspberries 0.125 80 130000 32000 130000 160000 160000 320000 360000 550000 pine seedlings 0.5 80 32000 8000 32000 41000 40000 80000 90000 140000 ornamentals ( flowering,

shrubs,

trees) 0.25 40 130000 32000 130000 160000 160000 320000 360000 550000 turf ( sod farm) 0.64 80 25000 6300 25000 32000 31000 63000 70000 110000 turf ( golf course) 0.64 40 50000 13000 50000 64000 63000 130000 140000 220000 Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 35 of 91 Applying Sprays via Airblast Equipment ( 8) apples, Christmas trees, pears 0.25 40 5000 5300 7500 8200 ( 11000

HGg) 26000 53000 95000 53000 pine seedlings 0.5 40 2500 2600 3800 4100 ( 5300  HG) 13000 26000 47000 26000 grapes 0.188 40 6600 7000 10000 11000 ( 14000  HG) 35000 70000 130000 70000 grapes, raspberries 0.125 40 10000 11000 15000 16000 ( 21000  HG) 53000 110000 190000 110000 Applying Sprays via Handgun Equipment ( 9) turf ( LCO) 5.4 5 No Data 6300 2000 3500 31000 63000 No Data No Data turf ( LCO) 2.7 5 No Data 13000 3900 7000 63000 130000 No Data No Data Applying Sprays via Rights of Way Equipment ( 10) turf (

rightsof way) 5.4 80 32 140 110 140 710 1400 No Data No Data Applying Granulars via Tractor Drawn Spreader ( 11) turf ( sod farm) 2.6 80 8700 950 12000 21000 4800 9500 41000 5200 turf ( golf course) 1.36 40 33000 3600 46000 79000 18000 36000 160000 20000 Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 36 of 91 Flagger Flagging for Aerial Sprays Applications ( 12) apples, Christmas trees, pears 0.25 350 19000 7800 No Data 21000 39000 78000 940000 390000 grapes 0.125 350 37000 16000 No Data 41000 78000 160000 1900000 780000 grapes 0.188 350 25000 10000 No Data 27000 52000 100000 1200000 520000 turf ( sod farm) 5.4 350 870 360 No Data 950 1800 3600 43000 18000 turf ( sod farm) 2.7 350 1700 720 No Data 1900 3600 7200 87000 36000 pine seedlings 0.5 350 9400 3900 No Data 10000 19000 39000 470000 190000 Flagging for Aerial Granular Applications ( 13) turf ( sod farm) 2.6 350 7100 1700 No Data 12000 8700 17000 350000 87000 Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 37 of 91 Mixer/ Loader/ Applicator Mixing/ Loading/

Applying Liquid Concentrates with Low Pressure Handwand ( ORETF)

( 14) greenhouse ornamentals ( flowering,

shrubs,

trees) ( non

WPS) 0.00938 lb ai/ gallon 40 gallons 3200 230000 150000 No Data 1200000 2300000 Not Feasible Not Feasible ornamentals ( flowering,

shrubs,

trees); Pine ( Christmas tree?) 0.0023 lb ai/ gallon 40 gallons 13000 960000 590000 No Data 4800000 9600000 Not Feasible Not Feasible roses 0.00029 lb ai/ gallon 40 gallons 100000 7600000 4700000 No Data 38000000 76000000 Not Feasible Not Feasible turf ( LCO &

golf course) 0.64 5 380 28000 17000 No Data 140000 280000 Not Feasible Not Feasible grapes 0.125 lb ai/ gallon 40 gallons 240 18000 11000 No Data 88000 180000 Not Feasible Not Feasible Mixing/ Loading/

Applying Wettable Powders with Low Pressure Handwand ( PHED) ( 15) apples 0.00062 lb ai/ gallon 40 gallons No Data 8700 84000 120000 44000 87000 Not Feasible Not Feasible azaleas 0.005 lb ai/ gallon 40 gallons No Data 1100 10000 15000 5400 11000 Not Feasible Not Feasible grapes 0.00094 lb ai/ gallon 40 gallons No Data 5800 56000 77000 29000 58000 Not Feasible Not Feasible Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 38 of 91 Mixing/ Loading/

Applying Wettable Powders with Low Pressure Handwand ( PHED) ( cont) ( 15) greenhouse ornamentals ( flowering,

shrubs,

trees) ( non

WPS) 0.00625 lb ai/ gallon 40 gallons No Data 870 8400 12000 4300 8700 Not Feasible Not Feasible turf ( LCO &

golf course) 5.4 5 No Data 8 78 110 40 80 Not Feasible Not Feasible ornamentals ( flowering,

shrubs,

trees) 0.0025 lb ai/ gallon 40 gallons No Data 2200 21000 29000 11000 22000 Not Feasible Not Feasible pears 0.00062 lb ai/ gallon 40 gallons No Data 8700 84000 120000 44000 87000 Not Feasible Not Feasible pine seedlings 0.5 5 No Data 87 840 1200 430 870 Not Feasible Not Feasible Mixing/ Loading/

Applying Dry Flowables with Low Pressure Handwand ( using liquids ORETF data) ( 16) azaleas 0.005 lb ai/ gallon 40 gallons 6000 440000 270000 Data unavailable 2200000 4400000 Not Feasible Not Feasible ornamentals ( flowering,

shrubs,

trees) 0.0025 lb ai/ gallon 40 gallons 12000 880000 550000 Data unavailable 4400000 8800000 Not Feasible Not Feasible turf ( LCO &

golf course) 2.7 5 89 6500 4000 Data unavailable 33000 65000 Not Feasible Not Feasible Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 39 of 91 Mixing/ Loading/

Applying Liquid Concentrates with a Handgun Sprayer ( LCO ORETF data)

( 17) greenhouse ornamentals ( flowering,

shrubs,

trees) ( non

WPS) 0.00938 lb ai/ gallon 1000 gallons No Data 17000 4300 7800 70000 170000 Not Feasible Not Feasible ornamentals ( flowering,

shrubs,

trees); Pine ( Christmas tree?) 0.0023 lb ai/ gallon 1000 gallons No Data 69000 17000 32000 290000 690000 Not Feasible Not Feasible roses 0.00029 lb ai/ gallon 1000 gallons No Data 550000 140000 250000 2300000 5500000 Not Feasible Not Feasible Mixing/ Loading/

Applying Wettable Powders with a Handgun Sprayer ( LCO ORETF data)

( 18) apples 0.00062 lb ai/ gallon 1000 gallons No Data 6000 36000 68000 30000 60000 Not Feasible Not Feasible grapes 0.00094 lb ai/ gallon 1000 gallons No Data 4000 24000 45000 20000 40000 Not Feasible Not Feasible pine seedlings 0.5 5 No Data 1500 9000 17000 7400 15000 Not Feasible Not Feasible Mixing/ Loading/ Appl ying Water Soluble Bags with Handgun Sprayer ( LCO ORETF data) ( 19) greenhouse ornamentals ( flowering,

shrubs,

trees) ( non

WPS) 0.00625 lb ai/ gallon 1000 gallons No Data 5300 4500 7800 26000 53000 Not Feasible Not Feasible Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 40 of 91 Mixing/ Loading/

Applying Water Soluble Bags with Handgun Sprayer ( LCO ORETF data)

( cont) ( 19) turf ( LCO &

golf course) 5.4 5 No Data 1200 1000 1800 6100 12000 Not Feasible Not Feasible pine seedlings 0.5 5 No Data 13000 11000 19000 66000 130000 Not Feasible Not Feasible Mixing/ Loading/

Applying Dry Flowables Concentrates with a Handgun Sprayer ( LCO ORETF data)

( 20) turf ( LCO &

golf course) 2.7 5 No Data 800 2300 4000 4000 8000 Not Feasible Not Feasible Mixing/ Loading/

Applying Liquid Concentrates with a High Pressure Handwand ( only study in PHED is for greenhouse use) ( 21) greenhouse ornamentals ( flowering,

shrubs,

trees) ( non

WPS) 0.00938 lb ai/ gallon 1000 gallons No Data 210 770 1200 1100 2100 Not Feasible Not Feasible ornamentals ( flowering,

shrubs,

trees) 0.0023 lb ai/ gallon 1000 gallons No Data 860 3100 4900 4300 8600 Not Feasible Not Feasible roses 0.00029 lb ai/ gallon 1000 gallons No Data 6800 25000 39000 34000 68000 Not Feasible Not Feasible Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 41 of 91 Mixing/ Loading/

Applying Dry Flowables with a High Pressure Handwand ( only study in PHED is for greenhouse use for liquid concentrates)

( 22) azaleas 0.005 lb ai/ gallon 1000 gallons No Data 400 1400 2300 2000 4000 Not Feasible Not Feasible ornamentals ( flowering,

shrubs,

trees) 0.0025 lb ai/ gallon 1000 gallons No Data 790 2900 4500 4000 7900 Not Feasible Not Feasible Mixing/ Loading/

Applying Wettable Powders with a High Pressure Handwand ( only study in PHED is for greenhouse use for liquid concentrates) ( 23) ornamentals ( flowering,

shrubs,

trees) 0.0025 lb ai/ gallon 1000 gallons No Data 790 2900 4500 4000 7900 Not Feasible Not Feasible azaleas 0.005 lb ai/ gallon 1000 gallons No Data 400 1400 2300 2000 4000 Not Feasible Not Feasible greenhouse ornamentals ( flowering,

shrubs,

trees) ( non

WPS) 0.00625 lb ai/ gallon 1000 gallons No Data 320 1200 1800 1600 3200 Not Feasible Not Feasible Mixing/ Loading/

Applying Liquids with an Injector ( 24) ornamentals ( shade trees,

woody shrubs) 0.000075 lb ai/ 1 inch of trunk inch of trunk No Data No Data No Data No Data No Data No Data No Data No Data Table 7. Triadimefon Occupational Handler Exposure and Risk Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b MOEs Baseline Personal Protective Equipment Engineering Controls Dermalc ( Inhalationd Dermal Inhalation Dermalj Inhalationk SL w/ glovese DL w/ glovesf 80% Rh 90% Ri Page 42 of 91 Mixing/ Loading/

Applying RTU Briquette ( 25) pine seedlings 0.00019 lb ai/ seedling seedlings No Data No Data No Data No Data No Data No Data No Data No Data Mixing/ Loading/

Applying Dip ( 26) pine seed ( nurseries) 0.0000625 lb ai/ gallon gallons No Data No Data No Data No Data No Data No Data No Data No Data pineapple ( postharvest 0.0028 lb ai/ gallon gallons No Data No Data No Data No Data No Data No Data No Data No Data Loading/ Applying Granulars via Push Type Spreader ( ORETF) ( 27) turf ( golf course) 1.36 5 7600 4800 12000 24000 24000 48000 Not Feasible Not Feasible a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day values are HED estimates of acres, square feet, or cubic feet treated or gallons applied based on Exposure SAC SOP # 9 " Standard Values for Daily Acres Treated in Agriculture," industry sources, and HED estimates.

c Baseline Dermal: Long sleeve shirt, long pants, no gloves.

d Baseline Inhalation: no respirator.

e PPE Dermal SL with gloves: Single layer plus chemical resistant gloves.

f PPE Dermal DL and gloves: Coveralls worn over long sleeve shirt and long pants plus chemical resistant gloves.

g PPE Dermal DL and gloves and HG: Coverall worn over long sleeve shirt and long pants plus chemical resistant gloves and headgear.

h PPE 80% R inhalation: assumes a dust/ mist removing quarter face style respirator providing an 80% protection factor.

i PPE 90% R inhalation: assumes a dust/ mist removing half face style respirator providing a 90% protection factor.

j Eng Controls Dermal: Closed mixing/ loading system, enclosed cab, or enclosed cockpit.

k Eng Controls Inhalation: Closed mixing/ loading system, enclosed cab, or enclosed cockpit. Page 43 of 91 Table 8. Estimated Worker Exposure and Risk from On Nursery Seed Treatment Crop Acres treated/

day App Rate ( lb ai/

100 lb) a Amount Handled per dayb ( lb ai/ day) Unit Exposures MOEs Baseline Personal Protective Equipment Engineering Controls Baseline Personal Protective Equipment Dermalc ( mg/ lb ai) Inhalationd ( µ g/ lb ai) Dermal ( mg/ lb ai) Inhalation ( µ g/ lb ai) Dermalh ( mg/ lb ai) Inhalationi ( µ g/ lb ai) Inhalation Dermal Inhalation SL w/ glovese 80% Rf 90% Rg SL w/ gloves 80% R 90% R LOADING/ APPLYING WITH HOPPER OR PLANTER BOX SEED TREATMENT Pinej Seed ( WP) 80 0.0013 0.13 No Data 1.2 12.6 0.24 0.12 No Data No Data 1500 11000 7600 15000 LOADING/ PLANTING PREVIOUSLY TREATED SEEDS Pine Seed ( WP) 80 0.0013 0.13 No Data 3.4 0.25 0.68 0.34 No Data No Data 540 550000 2700 5400 a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day calculated from the acres treated/ day and the maximum lb of seed planted per acre: for ponderosa seed  1.25 lb/ A.

c Baseline Dermal: Long sleeve shirt, long pants, no gloves.

d Baseline Inhalation: no respirator.

e PPE Dermal SL with gloves: Single layer plus chemical resistant gloves.

f PPE 80% R inhalation: assumes a dust/ mist removing quarter face style respirator providing an 80% protection factor.

g PPE 90% R inhalation: assumes a dust/ mist removing half face style respirator providing a 90% protection factor.

h Eng Controls Dermal: Closed System.

i Eng Controls Inhalation: Closed System.

j Ponderosa pine seeds used. Page 44 of 91 Table 9. Estimated Worker Exposure and Risk from Commercial Seed Treatment Crop Exposure Scenario AR ( lb ai/ 100 lb) a Amount Handled per day ( lb ai/ day) b Unit Exposures MOEs Baseline Personal Protective Equipment Engineering Controls Baseline Personal Protective Equipment Engineering Controls Dermal c ( mg/ lb ai) Inhd ( µ g/ lb ai) Dermal ( mg/ lb ai) Inhalation ( µ g/ lb ai) Dermal i ( mg/ lb ai) Inhj ( µ g/ lb ai) Dermal Inh Dermal Inhalation Dermal Inh SL w/ glovese DL w/ glovesf 80%

Rg 90%

Rh SL w/ gloves DL w/ gloves 80%

R 90% R Pinek Seeds Loader/ Applicator 0.13 16.23 3.7 43 0.17 0.13 8.6 4.3 0.023 0.34 300 0.34 6500 8500 1.7 3.4 48000 43 Sewer 0.13 16.23 0.0062 0.23 No Data No Data No Data No Data No Data No Data 180000 64 No Data No Data 320 640 No Data No Data Bagger 0.13 16.23 0.0091 0.16 No Data No Data No Data No Data No Data No Data 120000 92 No Data No Data 460 920 No Data No Data Multiple Activities 0.13 16.23 No Data 1.6 0.042 No Data No Data No Data No Data No Data No Data 9.2 26000 No Data 46 92 No Data No Data a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day calculated from the maximum application rate and the lbs of seed treated or planted/ day and: for ponderosa seed  12485 lb/ day.

c Baseline Dermal: Long sleeve shirt, long pants, no gloves.

d Baseline Inhalation: no respirator.

e PPE Dermal SL with gloves: Single layer plus chemical resistant gloves.

f PPE Dermal DL and gloves: Coveralls worn over long sleeve shirt and long pants plus chemical resistant gloves.

g PPE 80% R inhalation: assumes a dust/ mist removing quarter face style respirator providing an 80% protection factor.

h PPE 90% R inhalation: assumes a dust/ mist removing half face style respirator providing a 90% protection factor.

i Eng Controls Dermal: Closed System j Eng Controls Inhalation: Closed Systesm.

k Ponderosa pine seeds used. Page 45 of 91 Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Mixer/ Loader Mixing/

Loading Liquid Concentrates for Aerial Applications ( 1a) grapes 0.125 350 140 3600 3800 10000 13000 12000 16000 28000 Mixing/

Loading Liquids Concentrates for Groundboom Applications ( 1b) grapes 0.125 80 600 16000 17000 44000 56000 51000 69000 120000 turf ( sod farm) 0.64 80 120 3100 3300 8500 11000 10000 13000 24000 turf ( golf course) 0.64 80 120 3100 3300 8500 11000 10000 13000 24000 Mixing/

Loading Liquids Concentrates for Airblast Applications ( 1c) grapes 0.125 40 1200 32000 33000 87000 110000 100000 140000 240000 Mixing/

Loading Wettable Powders for Aerial Applications ( 2a) apples, Christmas trees, pears 0.25 350 30 60 61 250 420 260 450 7400 grapes 0.188 350 39 80 81 330 550 350 600 9800 turf ( sod farm) 5.4 350 1.4 2.8 2.8 12 19 12 21 340 Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 46 of 91 Mixing/

Loading Wettable Powders for Aerial Applications ( 2a)

( cont.) pine seedlings 0.5 350 15 30 30 130 210 130 230 3700 Mixing/

Loading Wettable Powders for Chemigation Applications ( 2b) azaleas 0.005 lb ai/ gallon 2400 gallons 220 440 440 1800 3000 1900 3300 54000 turf ( sod farm) 5.4 350 1.4 2.8 2.8 12 19 12 21 340 ornamentals ( flowering,

shrubs, trees) 0.25 60 170 350 350 1500 2400 1500 2600 43000 Mixing/

Loading Wettable Powders for Groundboom Applications ( 2c) azaleas 0.005 lb ai/ gallon 16000 gallons 32 66 67 270 450 290 490 8000 grapes 0.188 80 170 350 350 1500 2400 1500 2600 43000 ornamentals ( flowering,

shrubs, trees) 0.25 40 260 530 530 2200 3600 2300 4000 64000 pine seedlings 0.5 80 65 130 130 550 910 580 990 16000 turf ( sod farm) 5.4 80 6 12 12 51 84 53 92 1500 Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 47 of 91 Mixing/

Loading Wettable Powders for Groundboom Applications ( 2c)

( cont.) turf ( golf course) 5.4 40 12 24 25 100 170 110 180 3000 raspberries 0.125 80 260 530 530 2200 3600 2300 4000 64000 Mixing/

Loading Wettable Powders to Support LCO Handgun Applications ( mixing/ loading supports 20 LCOs)

( 2d) turf ( LCO) 5.4 100 4.8 9.7 9.9 41 67 43 73 1200 Mixing/

Loading Wettable Powders for Airblast Applications ( 2e) apples, Christmas trees, pears 0.25 40 260 530 530 2200 3600 2300 4000 64000 grapes 0.188 40 340 700 710 2900 4800 3100 5300 86000 pine seedlings 0.5 40 130 260 270 1100 1800 1200 2000 32000 raspberries 0.125 40 520 1100 1100 4400 7300 4600 7900 130000 Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 48 of 91 Mixing/

Loading Wettable Powders to Support Rights of way ( 2f) turf (

rightsof way) 5.4 80 6 12 12 51 84 53 92 1500 Mixing/

Loading Dry Flowables for Aerial Applications ( 3a) turf ( sod farm) 2.7 350 150 150 180 250 270 320 360 680 Mixing/

Loading Dry Flowables for Chemigation Applications ( 3b) azaleas 0.005 lb ai/ gallon 2400 gallons 12000 12000 14000 19000 21000 26000 28000 54000 turf ( sod farm) 2.7 350 150 150 180 250 270 320 360 680 ornamentals ( flowering,

shrubs, trees) 0.25 60 9700 9700 11000 15000 17000 20000 23000 43000 Mixing/

Loading Dry Flowables for Groundboom Applications ( 3c) azaleas 0.005 lb ai/ gallon 16000 gallons 1800 1800 2100 2900 3100 3800 4300 8000 turf ( sod farm) 2.7 80 670 670 790 1100 1200 1400 1600 3000 Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 49 of 91 Mixing/

Loading Dry Flowables for Groundboom Applications ( 3c)

( cont.) turf ( golf course) 2.7 40 1300 1300 1600 2100 2300 2800 3200 6000 ornamentals ( flowering,

shrubs, trees) 0.25 40 14000 14000 17000 23000 25000 31000 34000 64000 Mixing/

Loading Dry Flowables to Support LCO Handgun Applications ( mixing/ loading supports 20 LCOs)

( 3d) turf ( LCO) 2.7 5 11000 11000 13000 17000 19000 23000 25000 48000 Loading Granulars for Aerial Applications ( 4a) turf ( sod farm) 2.6 350 140 150 150 610 1000 680 1200 7200 Loading Granulars for Tractor Drawn Spreader Applications ( 4b) turf ( sod farm) 2.6 80 630 640 660 2700 4400 3000 5300 32000 turf ( golf course) 1.36 40 2400 2400 2500 10000 17000 11000 20000 120000 Applicator Applying Sprays via Aerial Equipment ( 5) apples, Christmas trees, pears 0.25 350 No Data No Data No Data No Data No Data No Data No Data 20000 Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 50 of 91 grapes 0.188 350 No Data No Data No Data No Data No Data No Data No Data 27000 turf ( sod farm) 5.4 350 No Data No Data No Data No Data No Data No Data No Data 940 pine seedlings 0.5 350 No Data No Data No Data No Data No Data No Data No Data 10000 Applying Sprays via Aerial Equipment ( 5)

( cont.) turf ( sod farm) 2.7 350 No Data No Data No Data No Data No Data No Data No Data 1900 grapes 0.125 350 No Data No Data No Data No Data No Data No Data No Data 41000 Applying Granulars via Aerial Equipment ( 6) turf ( sod farm) 2.6 350 No Data No Data No Data No Data No Data No Data No Data 200 Applying Sprays via Groundboom Equipment ( 7) azaleas 0.005 lb ai/ gallon 16000 gallons 3200 3200 3400 8900 11000 10000 14000 27000 grapes 0.125 80 26000 26000 27000 71000 92000 81000 110000 220000 grapes 0.188 80 17000 17000 18000 48000 61000 54000 72000 150000 turf ( sod farm) 5.4 80 600 600 620 1700 2100 1900 2500 5000 turf ( golf 5.4 40 1200 1200 1200 3300 4300 3800 5000 10000 Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 51 of 91 course)

turf ( sod farm) 2.7 80 1200 1200 1200 3300 4300 3800 5000 10000 turf ( golf course) 2.7 40 2400 2400 2500 6600 8500 7500 10000 20000 raspberries 0.125 80 26000 26000 27000 71000 92000 81000 110000 220000 Applying Sprays via Groundboom Equipment ( 7)

( cont.) pine seedlings 0.5 80 6400 6400 6700 18000 23000 20000 27000 55000 ornamentals ( flowering,

shrubs, trees) 0.25 40 26000 26000 27000 71000 92000 81000 110000 220000 turf ( sod farm) 0.64 80 5000 5000 5200 14000 18000 16000 21000 43000 turf ( golf course) 0.64 40 10000 10000 10000 28000 36000 32000 42000 85000 Applying Sprays via Airblast Equipment ( 8) apples, Christmas trees, pears 0.25 40 2600 3100 3200 ( 3500

HGh) 5800 6600 6200 ( 7600  HG) 7100 ( 8800  HG) 34000 pine seedlings 0.5 40 1300 1600 1600 ( 1600  HG) 2900 3300 3100 ( 3800  HG) 3500 ( 4400  HG) 17000 grapes 0.188 40 3400 4100 4300 ( 4700  HG) 7800 8700 8300 ( 10000

HG) 9400 ( 12000

HG) 45000 Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 52 of 91 Applying Sprays via Airblast Equipment ( 8)

( cont.) grapes, raspberries 0.125 40 5100 6200 6400 ( 7100  HG) 12000 13000 12000 ( 15000

HG) 14000 ( 18000

HG) 68000 Applying Sprays via Handgun Equipment ( 9) turf ( LCO) 5.4 5 No Data 1500 2300 1800 1900 3200 3300 No Data turf ( LCO) 2.7 5 No Data 3000 4500 3700 3800 6300 6600 No Data Applying Sprays via Rights of Way Equipment ( 10) turf (

rightsof way) 5.4 80 26 61 71 93 99 120 130 No Data Applying Granulars via Tractor Drawn Spreader ( 11) turf ( sod farm) 2.6 80 860 880 910 3400 5300 3900 6500 4600 turf ( golf course) 1.36 40 3300 3400 3500 13000 20000 15000 25000 18000 Flagger Flagging for Aerial Sprays Applications ( 12) apples, Christmas trees, pears 0.25 350 5500 No Data 5600 No Data No Data 13000 16000 270000 grapes 0.125 350 11000 No Data 11000 No Data No Data 27000 33000 550000 grapes 0.188 350 7300 No Data 7500 No Data No Data 18000 22000 370000 turf ( sod farm) 5.4 350 250 No Data 260 No Data No Data 620 750 13000 Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 53 of 91 turf ( sod farm) 2.7 350 510 No Data 520 No Data No Data 1200 1500 25000 pine seedlings 0.5 350 2700 No Data 2800 No Data No Data 6700 8100 140000 Flagging for Aerial Granular Applications ( 13) turf ( sod farm) 2.6 350 1400 No Data 1500 No Data No Data 5100 7200 70000 Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 54 of 91 Mixer/ Loader/ Applicator Mixing/ Loading/

Applying Liquid Concentrates with Low Pressure Handwand ( ORETF) ( 14) greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00938 lb ai/ gallon 40 gallons 3200 90000 No Data 130000 140000 No Data No Data Not Feasible ornamentals ( flowering,

shrubs,

trees); Pine ( Christmas tree?) 0.0023 lb ai/ gallon 40 gallons 13000 370000 No Data 530000 560000 No Data No Data Not Feasible roses 0.00029 lb ai/ gallon 40 gallons 100000 2900000 No Data 4200000 4400000 No Data No Data Not Feasible turf ( LCO &

golf course) 0.64 5 370 11000 No Data 15000 16000 No Data No Data Not Feasible grapes 0.125 lb ai/ gallon 40 gallons 240 6700 No Data 9700 10000 No Data No Data Not Feasible Mixing/ Loading/

Applying Wettable Powders with Low Pressure Handwand ( PHED) ( 15) apples 0.00062 lb ai/ gallon 40 gallons No Data 7900 8100 29000 43000 32000 50000 Not Feasible Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 55 of 91 Mixing/ Loading/

Applying Wettable Powders with Low Pressure Handwand ( PHED) ( 15)

( cont.) azaleas 0.005 lb ai/ gallon 40 gallons No Data 980 1000 3600 5300 3900 6200 Not Feasible grapes 0.00094 lb ai/ gallon 40 gallons No Data 5200 5400 19000 28000 21000 33000 Not Feasible greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00625 lb ai/ gallon 40 gallons No Data 780 810 2900 4300 3200 5000 Not Feasible turf ( LCO &

golf course) 5.4 5 No Data 7.3 7.5 26 39 29 46 Not Feasible ornamentals ( flowering,

shrubs, trees) 0.0025 lb ai/ gallon 40 gallons No Data 2000 2000 7100 11000 7900 12000 Not Feasible pears 0.00062 lb ai/ gallon 40 gallons No Data 7900 8100 29000 43000 32000 50000 Not Feasible pine seedlings 0.5 5 No Data 78 81 290 430 320 500 Not Feasible Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 56 of 91 Mixing/ Loading/

Applying Dry Flowables with Low Pressure Handwand ( using liquids ORETF data) ( 16) azaleas 0.005 lb ai/ gallon 40 gallons 5900 170000 No Data 240000 260000 No Data No Data Not Feasible ornamentals ( flowering,

shrubs, trees) 0.0025 lb ai/ gallon 40 gallons 12000 340000 No Data 490000 510000 No Data No Data Not Feasible turf ( LCO &

golf course) 2.7 5 88 2500 No Data 3600 3800 No Data No Data Not Feasible Mixing/ Loading/

Applying Liquid Concentrates with a Handgun Sprayer ( LCO ORETF data)

( 17) greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00938 lb ai/ gallon 1000 gallons No Data 3400 5400 4000 4200 7000 7500 Not Feasible ornamentals ( flowering,

shrubs,

trees); Pine ( Christmas tree?) 0.0023 lb ai/ gallon 1000 gallons No Data 14000 22000 16000 17000 29000 31000 Not Feasible roses 0.00029 lb ai/ gallon 1000 gallons No Data 110000 170000 130000 130000 230000 240000 Not Feasible Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 57 of 91 Mixing/ Loading/

Applying Wettable Powders with a Handgun Sprayer ( LCO ORETF data)

( 18) apples 0.00062 lb ai/ gallon 1000 gallons No Data 5100 5500 16000 23000 21000 32000 Not Feasible grapes 0.00094 lb ai/ gallon 1000 gallons No Data 3400 3600 11000 15000 14000 21000 Not Feasible pine seedlings 0.5 5 No Data 1300 1400 4100 5600 5100 7900 Not Feasible Mixing/ Loading/

Applying Water Soluble Bags with Handgun Sprayer ( LCO ORETF data)

( 19) greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00625 lb ai/ gallon 1000 gallons No Data 2400 3100 3800 4100 6000 6800 Not Feasible turf ( LCO &

golf course) 5.4 5 No Data 560 730 890 960 1400 1600 Not Feasible pine seedlings 0.5 5 No Data 6100 7900 9600 10000 15000 17000 Not Feasible Mixing/ Loading/

Applying Dry Flowables Concentrates with a Handgun Sprayer ( LCO ORETF data)

( 20) turf ( LCO &

golf course) 2.7 5 No Data 590 670 1500 1800 2000 2700 Not Feasible Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 58 of 91 Mixing/ Loading/

Applying Liquid Concentrates with a High Pressure Handwand ( only study in PHED is for greenhouse use)

( 21) greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00938 lb ai/ gallon 1000 gallons No Data 170 180 440 560 560 770 Not Feasible ornamentals ( flowering,

shrubs, trees) 0.0023 lb ai/ gallon 1000 gallons No Data 680 730 1800 2300 2300 3100 Not Feasible roses 0.00029 lb ai/ gallon 1000 gallons No Data 5400 5800 14000 18000 18000 25000 Not Feasible Mixing/ Loading/

Applying Dry Flowables with a High Pressure Handwand ( only study in PHED is for greenhouse use for liquid concentrates) ( 22) azaleas 0.005 lb ai/ gallon 1000 gallons No Data 310 340 830 1100 1100 1400 Not Feasible ornamentals ( flowering,

shrubs, trees) 0.0025 lb ai/ gallon 1000 gallons No Data 620 670 1700 2100 2100 2900 Not Feasible Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 59 of 91 Mixing/ Loading/

Applying Wettable Powders with a High Pressure Handwand ( only study in PHED is for greenhouse use for liquid concentrates) ( 23) ornamentals ( flowering,

shrubs, trees) 0.0025 lb ai/ gallon 1000 gallons No Data 620 670 1700 2100 2100 2900 Not Feasible Mixing/ Loading/

Applying Wettable Powders with a High Pressure Handwand ( only study in PHED is for greenhouse use for liquid concentrates) ( 23)

( cont.) azaleas 0.005 lb ai/ gallon 1000 gallons No Data 310 340 830 1100 1100 1400 Not Feasible greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00625 lb ai/ gallon 1000 gallons No Data 250 270 670 850 840 1100 Not Feasible Mixing/ Loading/

Applying Liquids with an Injector ( 24) ornamentals ( shade trees,

woody shrubs) 0.00007 5 lb ai/ 1 inch of trunk inch of trunk No Data No Data No Data No Data No Data No Data No Data Not Feasible Table 10. Combined Dermal plus Inhalation Handler Risks Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Combined MOEsj Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controli Dermal +

Inh Page 60 of 91 Mixing/ Loading/

Applying RTU Briquette ( 25) pine seedlings 0.00019 lb ai/ seedling seedlin gs No Data No Data No Data No Data No Data No Data No Data No Data Mixing/ Loading/

Applying Dip ( 26) pine seed ( nurseries) 0.00006 25 lb ai/ gallon gallons No Data No Data No Data No Data No Data No Data No Data No Data pineapple ( postharvest 0.0028 lb ai/ gallon gallons No Data No Data No Data No Data No Data No Data No Data No Data Loading/

Applying Granulars via Push Type Spreader ( ORETF)

( 27) turf ( golf course) 1.36 5 2900 3400 4000 8000 9600 12000 16000 Not Feasible a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day values are HED estimates of acres treated per day based on Exposure SAC SOP # 9 " Standard Values for Daily Acres Treated in Agriculture," industry sources, and HED estimates.

c Baseline = No gloves and no respirator d Single layer w/ gloves is baseline attire plus chemical resistant gloves.

e Double layer w/ gloves is coveralls worn over long sleeve shirt and long pants, plus chemical resistant gloves.

f 80% Respirator is quarter face dust/ mist respirator ( that provides an 80% protection factor).

g 90% Respirator is half face dust/ mist respirator ( that provides a 90% protection factor).

h Double layer w/ gloves and headgear: Coverall worn over long sleeve shirt and long pants plus chemical resistant gloves and headgear.

i Engineering control is closed mixing/ loading system, enclosed cab, or enclosed cockpit.

j Combined MOEs = 1/[( 1/ Dermal MOE) + (/ Inhalation MOE)] Page 61 of 91 Table 11. Combined Estimated Worker Dermal and Inhalation Risk from Commercial Seed Treatment Pine Seed Exposure Scenario App Ratea ( lb ai/ lb) Amount Handled per day b ( lb ai/ day) Combined MOEsi Baselinec Dermal +

Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Baseline Dermal +

80% Rf Inh Single layer w/

gloves Dermal+

80% R Inh Baseline Dermal +

90% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Eng Controlh Dermal +

Inh Ponderosa Seedj Loader/ Applicator 0.0013 16.23 0.34 0.34 0.34 1.7 1.7 3.4 3.4 43 Sewer 0.0013 16.23 64 No Data No Data 320 No Data 640 No Data No Data Bagger 0.0013 16.23 92 No Data No Data 460 No Data 910 No Data No Data Multiple Activies 0.0013 16.23 No Data 9.2 No Data No Data 46 No Data 91 No Data a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day calculated from the maximum application rate and the lbs of seed treated or planted/ day and: for ponderosa seed  12485 lb/ day.

c Baseline = No gloves and no respirator d Single layer w/ gloves is baseline attire plus chemical resistant gloves.

e Double layer w/ gloves is coveralls worn over long sleeve shirt and long pants, plus chemical resistant gloves.

f 80% Respirator is quarter face dust/ mist respirator ( that provides an 80% protection factor).

g 90% Respirator is half face dust/ mist respirator ( that provides a 90% protection factor).

h Engineering control is closed mixing/ loading system, enclosed cab, or enclosed cockpit.

i Combined MOEs = 1/[( 1/ Dermal MOE) + (/ Inhalation MOE)]

j Ponderosa pine seeds used. Page 62 of 91 Table 12. Combined Estimated Worker Dermal and Inhalation Risk from On Nursery Seed Treatment Crop Acres treated/

day App Ratea ( lb ai/ lb) Amount Handled per dayb ( lb ai/ day) Combined MOEsi Baselinec Dermal +

Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Double layer w/

gloves Dermal +

80% R Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal +

Inh LOADING/ APPLYING WITH HOPPER OR PLANTER BOX SEED TREATMENT Pine Seedj 80 0.0013 0.129840019 No Data 1300 No Data 4500 No Data 6400 No Data No Data LOADING/ PLANTING PREVIOUSLY TREATED SEEDS Pine Seedj 80 0.0013 0.129840019 No Data 540 No Data 2700 No Data 5300 No Data No Data a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day calculated from the acres treated/ day and the maximum lb of seed planted per acre: for ponderosa seed  1.25 lb/ A.

c Baseline = No gloves and no respirator d Single layer w/ gloves is baseline attire plus chemical resistant gloves.

e Double layer w/ gloves is coveralls worn over long sleeve shirt and long pants, plus chemical resistant gloves.

f 80% Respirator is quarter face dust/ mist respirator ( that provides an 80% protection factor).

g 90% Respirator is half face dust/ mist respirator ( that provides a 90% protection factor).

h Engineering control is closed mixing/ loading system, enclosed cab, or enclosed cockpit.

i Combined MOEs = 1/[( 1/ Dermal MOE) + (/ Inhalation MOE)]

j Ponderosa pine seeds used. Page 63 of 91 2.1.4 Cancer Triadimefon Handler Exposure and Risk Assessment No cancer endpoints of concern for triadimefon were identified; therefore, cancer risks to handlers were not assessed.

2.1.5 Summary of Risk Concerns and Data Gaps for Occupational Handlers There are several occupational handler scenarios for triadimefon that have risks associated with them that are above HED's level of concern for noncancer risk assessments, even at the highest level of risk mitigation. However, there are also some occupational handler scenarios for triadimefon that have data gaps.

<IP_ADDRESS> Summary of Risk Concerns The short and intermediate term dermal and inhalation handler risk assessment for triadimefon indicates risk concerns for a three handler scenarios, even with maximum risk mitigation. See Section <IP_ADDRESS> for a detailed summary.

<IP_ADDRESS> Summary of Data Gaps Several data gaps were identified for triadimefon in many different use areas that include: ° mixing/ loading/ applying dry flowables using a low pressure handwand sprayer ( data for liquid formulations was used as a surrogate), ° mixing/ loading/ applying wettable powders using a high pressure handwand sprayer ( data for liquid formulations was used as a surrogate), ° mixing/ loading/ applying dry flowables using a high pressure handwand sprayer ( data for liquid formulations was used as a surrogate), ° mixing/ loading/ applying liquid concentrates for tree injection ( no surrogate available), ° mixing/ loading/ applying ready to use briquettes for pine seedlings ( no surrogate available), and ° mixing/ loading/ applying dip to pine seeds and postharvest pineapples ( no surrogate available).

2.1.6 Recommendations For Refining Occupational Handler Risk Assessment In order to refine this occupational risk assessment, data on actual use patterns including rates, timing, and areas treated would better characterize triadimefon risks. Exposure studies for many equipment types that lack data or that are not well represented in PHED ( e. g., because of low replicate numbers or data quality) should also be considered based on the data gaps identified above and based on a review of the quality of the data used in this assessment.

2.2 Occupational Postapplication Exposures and Risks Page 64 of 91 HED uses the term " postapplication" to describe exposures to individuals that occur as a result of being in an environment that has been previously treated with a pesticide ( also referred to as reentry exposure). HED believes that there are distinct job functions or tasks related to the kinds of activities that occur in previously treated areas. Job requirements ( e. g., the kinds of jobs to cultivate a crop), the nature of the crop or target that was treated, and how the chemical residues degrade in the environment can cause exposure levels to differ over time. Each factor has been considered in this assessment.

2.2.1 Occupational Postapplication Exposure Scenarios Triadimefon can be used on agricultural crops ( ornamental, and turf) and in outdoor occupational settings. As a result, a wide array of individuals can potentially be exposed by working in areas that have been previously treated. HED is concerned about the kinds of exposures one could receive in the workplace. Triadimefon is applied to:

° grapes, ° turf, including sod farm turf ° ornamentals, ° apples, ° pears, ° Christmas trees, and ° raspberries.

HED uses a concept known as the transfer coefficient to numerically represent the postapplication exposures one would receive ( generally presented as cm2/ hour). The transfer coefficient concept has been established in the scientific literature and through various exposure monitoring guidelines published by the U. S. EPA and international organizations such as Health Canada and the Organization for Economic Cooperation and Development. The establishment of transfer coefficients also forms the basis of the work of the Agricultural Reentry Task Force. A transfer coefficient is a measure of the residue transferred from a treated surface to a person who is doing a task or activity in a treated area. These values are the ratio of an exposure for a given task or activity to the amount of pesticide residue on treated surfaces available for transfer. HED has developed a series of standard transfer coefficients that are unique for variety of job tasks or activities that are used in lieu of chemical and scenario specific data.

To develop a postapplication assessment, HED considers the types of tasks and activities that individuals are likely to be doing in areas recently treated with a pesticide. For consistency within postapplication assessments, HED has developed a list of tasks commonly associated with specific crops or use patterns, which are likely to result in postapplication exposures. Postapplication pesticide exposures that result from an individual's employment are considered occupational exposures. Common examples include: crop harvesting tasks ( e. g., harvesting treated turf), crop maintenance tasks ( e. g., irrigating, weeding, and mowing), and crop advisor tasks ( e. g., scouting). Page 65 of 91 HED considers how and when a pesticide is applied to estimate the level of transferable residues to which individuals could be exposed over time. Label directions and other use data are considered to determine application rates and application frequency. HED completes noncancer postapplication risk assessments using maximum application rates for each scenario. When postapplication noncancer risks are a concern using maximum application rates, HED may also consider typical application rates or application frequency, to further evaluate the overall risks associated with the use of the pesticide. To estimate the amount of transferable residues on a treated surface, HED uses, when possible, chemical and crop specific studies as described in HED guidelines for exposure data collection ( Series 875, Occupational and Residential Exposure Test Guidelines: Group B  Postapplication Exposure Monitoring Test Guidelines). For postapplication exposures, unique techniques are used to measure the amount of pesticide residue on a treated surface available for possible transfer. These techniques are distinct from those which measure total pesticide residue on a treated surface and absorbed into a treated entity. When appropriate chemical and crop specific transferable residue data are unavailable, HED also has developed a standard modeling approach to predict transferable residues over time ( best described in HED's SOPs for Residential Exposure Assessment). All triadimefon occupational postapplication scenarios were evaluated using HED's default assumptions that 20 percent of the initial application is available for transfer on day 0 ( i. e., 12 hours after application) and that the residue dissipates at a rate of 10 percent per day.

HED also must consider the likely frequency and duration of postapplication occupational exposures to triadimefon. Short term (< 30 days) always are considered in these assessments. Intermediate term ( greater than 30 days to several months) exposure durations are appropriate for postapplication occupational exposures scenarios where the pesticide is reapplied several times over a growing season, or the pesticide residues persist for relatively long periods of time, or the crop or use pattern is such that occupational postapplication workers may be exposed to several different treated areas in the course of their work. For example, migrant and seasonal workers may move from farm to farm and be exposed several weeks to several months or different fields or greenhouses on an individual establishment may be treated over a period of weeks due to differing levels of infestation or staggered crop cycles. For triadimefon, the exposure durations for noncancer postapplication risk assessment were short term (< 30 days) and intermediate term ( greater than 30 days up to several months). However, since the dermal toxicological endpoint of concern is the same for short and intermediate term exposures, the short and intermediate term postapplication risks are numerically identical.

Inhalation exposures are thought to be negligible in outdoor postapplication scenarios, since triadimefon has low vapor pressure and the dilution factor outdoors is considered infinite. In addition, under the Worker Protection Standard for Agricultural Pesticides   WPS   ( 40 CFR 170) greenhouses must be appropriately ventilated ( ventilation criteria are provided) following pesticide applications so that postapplication inhalation exposures are minimal. As such, inhalation postapplication exposures are not considered in this assessment.

In agricultural crop settings, the use of personal protective equipment or other types of equipment to mitigate postapplication exposures to workers is not considered a viable alternative Page 66 of 91 for the regulatory process. This is described in some detail in the WPS. Instead, an administrative approach   a Restricted Entry Interval or REI   is used to mitigate postapplication risks following applications to crops. The REI is time period following a pesticide application during which entry into the treated area is restricted. Postapplication risk levels are generally calculated in the risk assessment process on a chemical, crop, and activity specific basis. To establish REIs, HED considers postapplication risks on varying days after application.

HED has used the basic approach described above since the mid 1980s for calculating postapplication risks to pesticides. From that time to the present, several revisions and modifications were made to Agency policies as data, which warranted such changes, became available. In 1995, the Agency issued a Data Call In for postapplication agricultural data that prompted the formation of the Agricultural Reentry Task Force ( ARTF). This task force has generated a number of exposure studies and associated documents that are currently under review. The work of the ARTF is not yet complete, however, sufficient data were available from the group that warranted a significant interim change in Agency policy related to the data which were already available as the efforts of the ARTF paralleled a push for tolerance reassessment stipulated by the timelines established by FQPA. As a result of the need for the revision and using the latest data, the Agency developed a revised policy on August 7, 2000 entitled Policy 003.1 Science Advisory Council For Exposure Policy Regarding Agricultural Transfer Coefficients. The revision to this policy entailed linking worker activities to more specific crop/ agronomic groupings and making better use of the available occupational postapplication exposure data. In the new policy, transfer coefficients were selected to represent the activities associated with 18 distinct crop/ agronomic groupings based on different types of vegetables, trees, berries, vine/ trellis crops, turf, field crops, and bunch/ bundle crops ( e. g., tobacco). Triadimefon uses were identified in the following crop groupings from the policy:

° Flowers, cut ( ornamental), ° Tree, fruit, evergreen, ° Tree, fruit, deciduous, ° Turf/ sod, and ° Vine/ trellis ( with and without girdling).