1 1UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES Date: July 15, 2004 MEMORANDUM SUBJECT: PENTACHLORONITROBENZENE ( PCNB): Revised Occupational and Residential Exposure Assessment for the Reregistration Eligibility Decision Document.

FROM: Seyed Tadayon, Chemist Reregistration Branch 3 Health Effects Division ( 7509C)

THRU: Al Nielsen, Branch Senior Scientist Reregistration Branch II Health Effects Division ( 7509C)

TO: Diana Lock, Risk Assessor Reregistration Branch II Health Effects Division ( 7509C)

Please find the review of pentachloronitrobenzene ( PCNB).

DP Barked: D305363 PC Codes: 056502 EPA Reg Nos: 10404 38, 100 792, 100 823, 10163 123, 10404 37,10404 38, 19713 312, 264 319, 264 475, 2935 208, 2935 357, 2935 362, 2935 419, 32802 36, 34704 287, 34704 44, 34704 679, 34704 680, 400 399, 400 400, 400 401, 400 402, 400 403, 400 404, 400 405, 400 406, 400 407, 400 408, 400 411, 400 412, 400 414, 400 453, 400 454, 400 455, 400 456, 400 457, 400 458, 400 475, 400 479, 48273 17, 51036 80, 38 096, 538 108, 538 116, 5481 197, 5481 211, 5481 212, 5481 214, 5481 215, 5481 279, 5481 308, 5481 311, 5481 415, 5481 419, 5481 441, 5481 442, 5481 443, 5481 444, 5481 445, 5481 450, 5481 453, 5481 457, 5481 464, 5481 465, 5481 471, 5481 472, 7401 163, 7401 197, 7401 389, 7401 42, 7401 84, 7501 111, 7501 126, 7501 131, 7501 139,7501 143,7501 145, 7501 148, 7501 153,7501 49, 7501 54, 7501 55, 7501 57, 7501 70, 7501 78, 501 139,7501 143,7501 145, 7501 148, 7501 153, 7501 49, 7501 54, 7501 55, 7501 57, 7501 70, 7501 78, 7501 87, 9198 152, AL 800010, GA 810003, GA 890003, GA 940007, ME 790001, OK 840009, OK 840011, OK 84008, OK 940001, PA 980001, TX 780043, TX 790017, TX 840015, TX 900010, TX 910007000, TX 940004 2 EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1.0 BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.1 Summary of Toxicity Concerns Relating to Agricultural and Residential Exposures 6 1.2 Summary of Use Pattern and Formulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 1.3 Method and Types of Equipment Used for Mixing/ Loading/ Applying . . . . . . . . . 12 1.4 Incident Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 2.0 SEED TREATMENT USES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.1 Occupational Seed Handler Exposures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 2.1.1 Summary Of Uncertainties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 2.1.2 Seed Handler Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 3.0 OCCUPATIONAL EXPOSURES( HANDLER AND POSTAPPLICATION) . . . . . . . 24 3.1 Occupational Handlers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 3.1.1 Handler Exposures Scenarios . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 3.1.2 Summary of Uncertainties . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 3.1.3 Handler Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 3.1.4 Risk Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 3.2 Postapplication Exposures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 3.2.1 Submitted Studies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45 3.2.2 Exposure and Risk Calculation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 46 4.0 RESIDENTIAL AND OTHER NON OCCUPATIONAL EXPOSURES AND RISKS 47 4.1 Residential Handler Exposures and Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47 4.1.1Residential Handler Exposure Scenarios, Data and Assumptions . . . . . . . . . 47 4.1.2Residential Handler Exposure and Risk Estimates . . . . . . . . . . . . . . . . . . . . 49 4.1.3 Summary of Risk Concerns for Residential Handlers and Data Gaps . . . . . 49 4.2 Non Occupational Post Application Exposure and Risk Estimates. . . . . . . . . . . . 50 4.2.1 Post Application Exposure Scenarios, Data, and Assumptions . . . . . . . . . . 50 4.2.2 Post Application Exposure and Risk Estimates . . . . . . . . . . . . . . . . . . . . . . 52 4.2.3 Summary of post Application Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58 Appendix A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59 Appendix B . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71 Appendix C . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 125 Appendix D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 130 3 EXECUTIVE SUMMARY This is a revision of the original Occupational and Residential Exposure Assessment and Recommendations Document for pentachloronitrobenzene ( PCNB), ( S. Tadayon August31, 2003). This chapter has been revised to address comments made by the registrants.

This document contains the occupational and residential exposure assessment for various uses of pentachloronitrobenzene ( PCNB). The document also considers potential risk mitigation measures such as personal protective equipment ( PPE) and engineering controls for handlers and proposed restricted entry intervals ( REIs) for postapplication activities. The scope of the document covers all registered PCNB uses.

PCNB, is an organochlorine fungicide used for seed and soil treatments at planting. Registered use sites include, beans, brassica crops, cotton, garlic, hot pepper, peanut, pepper, potato, tomatoes, seed treatment, ornamental plants, cut flowers, dormant roses and bulbs, magnolia tree, southern pine seedlings and turf.

Application techniques identified to apply PCNB are: fixed  wing aircraft ( potato only), tractor drawn equipment, dip tank, drencher, drill box, drip irrigation, duster, hand held sprayer, hose end sprayer, liquid seed treater, mechanical sprayer; mist sprayer, overhead sprinkler irrigation, planter/ seed box; seed treater, slurry type seed treater, and hand held equipment. PCNB is formulated as manufacturing products, emulsifiable concentrate liquids, dusts/ powders, water dispersible granules, flowable concentrate, ready to use liquid and wettable powders. The application rates used in the assessment are intended to reflect the upper range of rates on the labels. Examples of the application rates used in this assessment include, but are not limited to the following: for agricultural uses the maximum rates for brassica crops is 30.0 lb ai/ acre, potato rate is 25.0 lb ai/ acre, cotton is 2.0 lb ai/ acre pepper and tomato rates are 7.5 lb ai/ acre, outdoor ornamental rate is 0.015 lb ai/ gallon and turf is 43.6 lb ai/ acre.

The Hazard Identification Assessment Review Committee ( HIARC) selected the following endpoints for exposure risk assessment: short and intermediate term dermal NOAEL is 300 mg/ kg/ day short and intermediate term inhalation NOAEL is 1 mg/ kg/ day. based on liver and thyroid lesions seen in rats. An uncertainty factor or " target" margin of exposure ( MOE) of 100 is based on 10x for differences among humans ( intra species variability) and 10x for differences between the test animals and humans ( inter species extrapolation). Thus MOEs of greater than 100 do not exceed the Agency's level of concern for occupational uses. The residential use includes a 10x FQPA safety factor and the or target MOE is 1000.

HED's Carcinogenicity Peer Review Committee ( CARC) classified PCNB as a Group C  possible human carcinogen but not sufficient human carcinogenic potential, and therefore, the quantification of human cancer risk was not recommended For agricultural uses, HED relied almost completely on surrogate data from the Pesticide Handlers Exposure Database ( PHED) Version 1.1. For residential handler HED used the ORETF 4 study data and the Residential SOPs.

The results of the short and intermediate term seed handler assessments indicate that for all formulation the majority of the potential exposure scenarios provide total MOE( s) greater than or equal to 100 at the clothing attire of long pants, long sleeved shirts, gloves, and no respirator while using open systems. Seed handlers working in a smaller facility performing multiple activities might require respirator in order to have MOEs of greater than or equal to100. There is no separate measurement of exposure for various job function performed by seed handlers in a smaller facility, therefore it is not feasible to require respirator for workers treating seeds in a small operation to wear respirator as soon as they enter in to the facility.

The agricultural results of the short and intermediate term occupational handler assessments indicate that for the dry flowable formulation the majority of the potential exposure scenarios provide total MOE( s) greater than or equal to 100 at the baseline clothing. For the liquid formulation, the risks indicate that in order for the mixer/ loaders to achieve MOEs of 100 for all uses, the addition of chemical resistant gloves and dust mist respirator is required For the wettable powder formulation risks indicate that in order for the mixer/ loaders to achieve MOEs of 100 some uses should be packaged in water soluble packets. The risk for the majority of uses with wettable powder is acceptable.

Chemical specific post application exposure data have not been submitted by the registrant in support of reregistration of PCNB. However there is a low potential for occupational postapplication exposure when a pre plant or at planting fungicide is used. Many agricultural operations mechanically plant seeds early in the season, which minimizes the potential for contact. Significant exposure during harvesting or any other late season activities, is not likely since the chemical is applied pre plant or at planting. However the Agency has determined that there are potential postapplication exposures to individuals re entering PCNB treated areas for the purpose of mowing ( roadsides, rights of way, golf course) and harvesting ( sod farms).

The short and intermediate term risks to golf course workers or sod growers doing hand harvesting, transplanting, and hand weeding tasks does not exceed the level of concern on the day zero at the rate of 32.67 lbs ai/ acre or 43.56 lbs ai/ acre.

In residential settings, the Agency does not use personal protective equipment to limit exposures, because they are viewed as impractical and not enforceable. Risk estimates are based on handlers wearing short sleeve shirts, short pants, shoes, and socks. Residential risks are of concern for a few scenarios, ( i. e., MOE < 1000) for risk assessments. The scenarios where MOEs do not meet the Agency's target MOE include dermal and inhalation risk for mixing/ loading/ applying liquid with low pressure handwand and dermal and inhalation risk for garden hose end sprayer and belly grinder.

Postapplication residential risk estimates on the day of application are the key concern The Agency considered a number of residential postapplication dermal exposure scenarios 5 including toddlers, youth aged children, and adults. A postapplication oral risk assessment for incidental ingestion by toddlers was also conducted, considering an oral endpoint of 1 mg/ kg/ day. All assessed postapplication exposures to toddlers did not have MOEs greater than or equal to 1000.

EPA assessed postapplication risks to toddlers from incidental oral ingestion using a shortterm and intermediate term incidental oral endpoint ( 1 mg/ kg/ day) The results indicate that risks from short term and intermediate term exposures were a concern ( i. e., MOE < 1000) for toddlers.

Overall Risk Summary This risk assessment applied the latest exposure data, toxicology information, and use data. The overall results indicate that the Agency has risk concerns for some PCNB use patterns involving agricultural crops. Residential handler and postapplication risks are of concern for some use patterns and no practical risk mitigation measures are available to the Agency to reduce these risks. 6 1.0 BACKGROUND Purpose In this document, which is for use in EPA's development of the PCNB Reregistration Eligibility Decision Document ( RED), EPA presents the results of its review of the potential human health effects of occupational and residential exposure to PCNB.

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 potential exposure to handlers ( mixers, loaders, applicators, etc.) during use or to persons entering treated sites after application is complete. For PCNB, both criteria are met.

1.1 Summary of Toxicity Concerns Relating to Agricultural and Residential Exposures Acute Toxicology Categories Table 1 presents the acute toxicity categories as outlined in the Hazard Identification Document ( April 09, 2003).

Table 1: Acute Toxicity for PCNB UNIROYAL AMVAC G No. Study Type MRIDs # Results Toxicity Category MRIDs # Results Toxicity Category 81 1 Acute Oral 43198201 LD50 = > 5000 mg/ kg IV 41443101 LD50 = > 5050 mg/ kg IV 81 2 Acute Dermal 43198202 LD50 = > 5000 mg/ kg IV 41443102 LD50 = > 2020 mg/ kg III 81 3 Acute Inhalation 43118201 LC50 = > 1.7 mg/ L III 41443103 LC50 = > 6.49 mg/ L III 81 4 Primary Eye Irritation 43198203 Slight irritant III 41443109 Slight irritant III 81 5 Primary Skin Irritation 43198204 Non irritant IV 41443105 PII = 0.0175 IV 81 6 Dermal Sensitization 4060901 Weak sensitizer 45236401 Non sensitizer 7 Other Endpoints of Concern The report of the Hazard Identification Assessment Review Committee ( HIARC) for PCNB, dated April 9, 2003 identified toxicological endpoints of concern for PCNB. The endpoints and associated uncertainty factors used in assessing the risks for PCNB are presented in Table 2.

Table 2: Endpoints selected by HIARC for Assessing Occupational and Residential Risks for PCNB Exposure Scenario Dose Used in Risk Assessment, UF Special FQPA SF* and Level of Concern for Risk Assessment Study and Toxicological Effects Short Term Incidental Oral ( 1 30 days) NOAEL= 1.0 mg/ kg/ day Residential LOC for MOE = 1000 Occupational = NA 90 Day Subchronic  Rat LOAEL = 1.0 mg/ kg/ day based on no toxicity at 30 days Intermediate Term Incidental Oral ( 1 6 months) NOAEL= 1.0 mg/ kg/ day Residential LOC for MOE = 1000 Occupational = NA 90 Day Subchronic  Rat LOAEL = 1.0 mg/ kg/ day based on threshold effects ( liver and thyroid lesions) seen at the lowest dose tested Short ( 1 to 30 days) and Intermediate Term Dermal ( 1 to 6 months) Dermal NOAEL= 300 mg/ kg/ day Residential LOC for MOE = 1000 Occupational LOC for MOE = 100 21 Day Dermal  Rat LOAEL = 1000 mg/ kg/ day based on hypertrophy of the thyroid follicular epithelium and dilation of the thyroid follicles in males at 1000 mg/ kg/ day Long Term Dermal (> 6 months) Oral NOAEL= 1.0 mg/ kg/ day ( dermal absorption rate = 33% of oral) Residential LOC for MOE = 1000 Occupational LOC for MOE = 100 Chronic/ Oncogenicity Study  rat LOAEL = 150 mg/ kg/ day based on hepatocelluar hypertrophy, hepatocellular hyperplasia, and thyroid hypertrophy Short Term Inhalation ( 1 to 30 days) Oral NOAEL= 1.0 mg/ kg/ day ( inhalation absorption = 100% of oral) Residential LOC for MOE = 1000 Occupational LOC for MOE = 100 90 Day Subchronic  Rat LOAEL = 1.0 mg/ kg/ day based on no toxicity at 30 days Intermediate Term Inhalation ( 1 to 6 months) Oral NOAEL = 1.0 mg/ kg/ day ( inhalation absorption rate = 100% of oral) Residential LOC for MOE = 1000 Occupational LOC for MOE = 100 90 Day Subchronic  Rat LOAEL = 1.0 mg/ kg/ day based on threshold effects ( liver and thyroid lesions) seen at the lowest dose tested Long Term Inhalation (> 6 months) Oral NOAEL= 1.0 mg/ kg/ day ( inhalation absorption rate = 100% of oral) Residential LOC for MOE = 1000 Occupational LOC for MOE = 100 Chronic/ Oncogenicity Study  rat LOAEL = 150 mg/ kg/ day based on hepatocelluar hypertrophy, hepatocellular hyperplasia, and thyroid hypertrophy Table 2: Endpoints selected by HIARC for Assessing Occupational and Residential Risks for PCNB Exposure Scenario Dose Used in Risk Assessment, UF Special FQPA SF* and Level of Concern for Risk Assessment Study and Toxicological Effects 8 Cancer ( oral, dermal, inhalation) HED's Carcinogenicity Peer Review Committee ( CARC) classified PCNB as a Group C  possible human carcinogen.

UF = uncertainty factor, FQPA SF = Special FQPA safety factor, NOAEL = no observed adverse effect level, LOAEL = lowest observed adverse effect level, PAD = population adjusted dose ( a = acute, c = chronic) RfD = reference dose, MOE = margin of exposure, LOC = level of concern, NA = Not Applicable 1.2 Summary of Use Patterns and Formulations Products containing PCNB are used in both occupational and residential settings.

Type of pesticide/ target pests Pentachloronitrobenzene ( PCNB), is an organochlorine fungicide used for seed and soil treatments at planting. Registered use sites include, beans, brassica crops, cotton, garlic, hot pepper, peanut, pepper, potato, tomatoes, seed treatment, ornamental plants, cut flowers, dormant roses and bulbs, magnolia tree, southern pine seedlings and turf.

PCNB, has trade names including Terraclor, Terraclor Super X and Turfcide. The common fungi controlled by PCNB are, black root ( Corticium solani), black rot of bulbs ( Sclerotinia), Camellia flower blight ( Sclerotinia), club root ( Plasmodiophora), common bunt/ stinking smut ( Tilletia foetida/ T. caries) of wheat, leaf spots, loose smut of oat ( Ustilago avenae), melting out ( Drechslera poae), melting out ( Helminthosporium), neck rot ( Stromatinia/ sclerotinia) and needle blight ( Dothistroma).

Formulation types and percent active ingredient In addition to the technical grade manufacturing product ( 95.0  96.0 percent active ingredient), PCNB is available in the following formulations: 2 granular, twenty six emulsifiable concentrate liquids ( up to 24.0 percent active ingredient), nine dust powder ( up to 30 percent active ingredient), two water dispersable granules ( up to 75 percent active ingredient), fourteen flowable concentrates ( up to 53.5 percent active ingredient), two soluble concentrate ( up to 24 percent active ingredient), one ready to use liquid ( 20 percent active ingredient) and thirteen wettable powders ( up to 75 percent active ingredient). Table 3 contains the EPA registered products for PCNB. ( See table 3 for details) 9 Table 3: Summary of Active PCNB Products PRODUCT NAME % ACTIVE INGREDIENT EPA REG No. PRODUCT NAME % ACTIVE INGREDIENT EPA REG No.

Ridomil Gold PC GR 10 100 823 80% PCNB 80 5481 438 Gowan PCNB 10 G 10 10163 123 PCNB 75DG 75 5481 441 Lesco 10 3 23 + PCNB 12.5 10404 37 PCNB Flowable RTU Seed Protectant 21.6 5481 442 Lesco PCNB  10% 10 10404 38 Parflo 2F 21.6 5481 443 Drexel PCNB 2 E Liquid 24.0 19713 312 PCNB 10G 10 5481 444 Temik TSX 10 264 319 PCNB ST 20.0 5481 445 MOCAP PCNB 3 10 10 264 475 PCNB 20% WDG Soil Fungicide 20 5481 450 PCNB 2 Spray 24.0 2935 208 PCNB75 WSP 75 5481 453 PCNB10 Granular 10 2935 357 Turfpro WSP 75 5481 457 Disyston 6.5 + PCNB6.5 Soil Fung. 6.5 2935 362 Parflo 6F Turf Soil Fungicide 53.5 5481 464 PCNBSeed Coat 24.0 2935 419 Parflo 4F Turf Soil Fungicide 38.3 5481 465 Soil Fungicide 10 32802 36 Win Flo 6F 53.5 5481 471 Dot Son Brand Stand Aid 6.5 34704 287 Win Flo 4F4 lbs ai/ gal 38.3 5481 472 Clean Crop PCNBSeed Treater 25 34704 44 Ferti Lome A C G 12.5 7401 163 PCNB+ Liquid Seed Treater 23.2 34704 679 Ferti Lome 4.67 7401 197 PCNB2EC LF Liquid Seed Treater 24.0 34704 680 Hi Yield Terraclor Fungicide 4.67 7401 389 Terraclor 75 WP 75 400 399 Ferti Lome 24.0 7401 42 Terraclor 2LB Emulsifiable 23.8 400 400 Ferti Lome 24.0 7401 84 Terrachlor 10% G 10 400 402 Rival Flowable 8.4 7501 131 Greenback Lawn Fungicide 24.0 400 403 Vitavax PC Peanut Seed Treatment Fungicide 15 7501 139 Turfcide 2 Lb. Emulsifiable 24.0 400 404 PREVAIL: Apron Terraclor Vitavax 15 7501 145 Terraclor Super X Emulsifiable 23.2 400 405 Kodiak AT 16.67 7501 148 Terraclor Super X Granular 10 400 406 4 Way Peanut Seed Protectant 10 7501 153 Turfcide 10% Granular 10 400 407 Terraclor 80% Dust 80 7501 49 Terrachlor Super X With Dy Syston 6.5 400 408 Terraclor Super X 20 5 Dust c/ Graphite 20 7501 54 Terraclor 6.5% Plus Di Syston 6.5% 6.5 400 411 Terra Coat LT 2N 23.7 7501 55 Terraclor 6.5% Plus 6.5 400 412 Terra Coat L 2N 23.1 7501 57 Technical 90 400 414 RTU PCNBSeed Protectant 24.0 7501 70 Terraclor Flowable 40.0 400 453 Vitavax PCNBFlowable Fungicide 17.0 7501 87 Turfcide 4F 40.0 400 454 Andersons PCNBGranular Plus Fertilizer 15 9198 152 Terraclor Super X 23.2 400 455 Terraclor 2 LB Emulsifiable Soil Fungicide 24.0 AL 800010 Terraclor Super X 18.8G 15 00 456 Terraclor 2 LB Emulsifiable Soil Fungicide 10.0 GA 810003 Turfcide 15G 15 400 457 Terraclor 10% G 10 GA 890003 Terraclor 15G 15 400 458 Terraclor Flowable 40.0 GA 940007 Terraclor Super X plus DiSyston EC 17.5 400 475 Terraclor 75% WP75 75 ME7900010 Turfcide WDG 75 400 479 Terraclor 2 LB Emulsifiable Soil Fungicide 23.8 OK 840009 MARMAN PCNB75% WP 75 48273 17 Terraclor 10% G 10 OK 840011 PCNB M 10 3G 10 51036 80 Terraclor 75% WP 75 OK 84008 Scotts Lawn Disease Preventer 10 538 096 Terraclor Flowable 40 OK 940001 Scotts' Proturf 14 3 3 FFII 15.4 538 108 Terraclor 400 40 PA 980001 Scotts' Lawn Disease Preventer Y 9.95 538 116 Terraclor 10% G 10 TX 780043 Technical grade PCNB 95 5481 197 Terraclor 75% WP 75 TX 790017 PCNB10% Granules 10 5481 211 Terraclor 2 LB Emulsifiable Soil Fungicide 23.8 TX 840015 PCNB2 E Liquid EC 24.0 5481 212 PCNB2 E Liquid Emulsifiable Concentrate 24.0 TX 900010 PCNBSoil & Turf Liquid Drench 24.0 5481 214 TOPS PC Peanut Seed Treatment 15 TX 9100070 PCNB2 LF 20.0 5481 215 Terraclor Flowable 75.0 TX 940004 PCNB75% WP 75 5481 279 4 Way Seed Protectant 10 7501 111 PCNB Thiram 30: 30 Seed Treatment 30 5481 308 PCNB Thiram 10: 10 Seed Treatment 10 5481 311 PCNBDisulfoton 6.5: 6.5 Granules 6.5 5481 415 PCNB75W 75 5481 419 10 Registered use sites, application rates and frequency of application Table 4 represent summary information on registered use sites, application rates and frequency of application per growing season for PCNB. Application rate covers various type of equipment used to apply PCNB. Refer to appendix A for a comprehensive use information.

Table 4: Use Patterns, Application Rate, and Frequency of Application for PCNB Crops Application Rate lb ai/ acre Frequency of Timing of Application Agricultural Usage Patterns Beans: Bush Beans Dry/ green + bush/ pole Dry/ succulent/ snap Not specified Pole Beans Snap/ Dry + Bush Snap/ Dry + Pole 1.5 to 2.1 lbs ai/ A 1.1 1.1 to 1.5 1.36 to 1.5 1.5 to 2.1 1.5 to 2.1 1.7 to 2.1 At planting Brassica Crops: Broccoli, Brussels Sprouts, Cabbage, Cauliflower, Chinese Broccoli, Chinese Cabbage, Collards, Kale, Mustard Greens 30 lbs ai/ A ( Transplant solutions: 4.5 lbs ai/ A) Pre planting or at planting Cotton Cotton Seedling 0.93 to 2.1 lbs ai/ A 0.3 to 1.5 At planting Garlic ( in furrow and clove mist spray) 20 to 20.6 lbs ai/ A at planting Hot peppers 1.3 to 1.5 lbs ai/ A At planting Peanuts 2 to 10 lbs ai/ A ( plus: aircraft  10 lb ai/ A) At planting and early pegging Peppers 7.2 to 7.5 lbs ai/ A Transplant Solution: 3.5 lbs ai/ 100 gal At planting Potatoes 10 to 25 lbs ai/ A Preplant Tomatoes 7.2 to 21.78 lbs ai/ A Preplanting or at planting Seed Treatment 0.0375 to 0.253 lb ai/ 100 lbs seed Preplant Ornamental Usage Patterns Azalea/ Camellia Plants 217.8 to 290.4 lbs ai/ A Preplanting or at planting Bulbs Dutch Iris Easter Lily, Hyacinth, Iris, Narcissus, Tulip Gladiolus Lily  various 147 to 150 lbs ai/ A 196 to 212.4 98 to 185.1 212.4 [ Transplant solutions: 1.5 lb ai/ 100 gallons to 1.5 lb ai/ 3.2 gal] [ Bulb soak: 4.5 lb ai/ 100 gal] At planting Cut Flowers: spray/ dip 1.5 lb ai/ 100 gal Prior to storage 11 Dormant Roses & Bulbs: spray/ dip 4.5 lb ai/ 100 gal to 1.5 lbs ai/ 3.2 gal Pre plant or pre storage Magnolia Tree: Foliar spray 1.5 lb ai/ 100 gal/ or 6 lb ai/ A At least 4 sprays at 2 weeks intervals Southern Pine Seedlings 36.8 to 38.1 lbs ai/ A ( 37.5 typical) Pre plant Ornamental Plants: Bedding Plants Calendula/ Larkspur/ Snapdragon/ Sweet Peas Dutch Iris Easter Lily Flowering Bedding  broadcast  soil drench  bench soil Flower & Foliage Flower, Foliage, Shrub, Tree Flower/ Foliage/ Woody& Bedding Foliage Gladiolus Hyacinth/ Iris/ Narcissus/ Tulip Lilies Tropical Foliage Vegetable Bedding Woody & Herbaceous 40.8 lbs ai/ A 100 to 119.6 to 375 ( 1/ 10) 16.4 to 200 200 10.2 to 87.12 10.2 to 102.1 65.3 196.0 130.7 7.14 to 114.3 87.12 ( growing media mix) 120 212 212.4 40.8 40.84 40.8 to 87.1 Pre planting or at planting Turf: Turf Home Lawns Commercial Turf: Commercial & Home 32.7 to 43.1 lbs ai/ A 21.7 to 32.7 21.3 32.7 to 43.6 More reapplication at lower rate Reapplication at 3 to 4 weeks interval Table 5 represent information on registered use sites, application rates for seed treatment uses. Application rate covers various type of commercial seed treater and seed planters used to apply PCNB.

Table 5. Application Rate for seed, seed piece, and cloves Application Rate lbs ai/ 100 lbs seed ( Commercial) Application Rate lbs ai/ 100 lbs seed ( On Farm)

crop minimum typical maximum minimum typical maximum barley 0.0394 0.1045 0.1307 0.0390  0.0878 bean 0.0256 0.0523 0.0347 C 0.0750 corn 0.0523 0.0372  0.0558 cotton 0.0656 0.2526 0.0788 0.0750 0.0750 0.1250 0.0150 garlic C C  C C

oats 0.0394 0.0977 0.1045 0.1957 0.0302 C 0.0604 pea 0.0523 0.1045 0.0521 C 0.1042 peanut 0.0305 0.0375 0.0523 0.0610 0.0375 0.0375 0.0417 0.0750 potato C C  C C

rice C C  0.0417 C 0.0926 12 safflower C C  C C

sorghum C 0.0305  C C

soybean 0.0256 0.0256 0.0525 0.1045 0.0695 C 0.1044 sugar beet 0.0958 C 0.1873 0.0313 C 0.0625 wheat 0.0256 0.0256 0.0523 0.0525 0.0347 C 0.0521 1.3 Methods and Types of Equipment Used for Mixing/ Loading/ Applying HED determines potential exposures to pesticides handlers by identifying exposure scenarios from the various application equipment types that are recommended on PCNB labels. Based on reviewing pesticide labels and a use meeting with the registrants residential and agricultural use patterns specific to PCNB are associated with the following application equipment:

Agricultural Uses:

Chemigation

Ground boom sprayer

Airblast sprayer

Push type spreader

Tractor drawn spreader

Aerial application Seed Treatment Uses:

Commercial seed treater

On farm seed treatment

Planter/ seed box Residential Uses:

Push type spreader

Belly grinder,

Hose end sprayer

low pressure handwand 13 1.4 Incident reports According to the Recognition and Management of Pesticide Poisoning, 5 th edition, symptoms of prolonged exposure to PCNB can include: skin sensitization and irritation, conjunctivitis and keratitis following eye contamination. Systemic poisoning has not been reported. Clearance is chiefly via the liver and biliary excretion. For the reporting period 1993 1998, there were 41 cases reported in the AAPCC surveillance systems. There were 21 symptomatic cases, including 6 ranked moderate. Of the 41 cases, 15 were seen in a health care facility, and 1 was hospitalized.

From 1982 1997, there are a total of thirty PCNB case reports in the California Pesticide Illness Surveillance Program. Many of these include PCNBin mixtures with other pesticides. Of the seven case reports that are for PCNB alone, most are older cases and related to eye contamination. In the 1984 1991 inclusive NPTN ranking of the top 200 active ingredients, PCNBis164 ( Ruth H. Allen. February 4, 2003). 14 2.0 SEED TREATMENT USES There are a number of methods that can be used to treat seeds both commercially and onfarm On farm seed treatment methods include concrete tumbler, drill box, duster, in furrow, mist type seed treater, planter/ seed box, seed treater and slurry type seed treater. Commercial seed treatment equipment produced by Gustafson include computerized seed and chemical Proportioner, Gustafson Accu Treat Treater, Gustafson S Series and SS Series, Gustafson SSAMP Treater, and Triple Treat Seed Treater.

On farm seed treatment is considered, by most sources, to represent a relatively small proportion of the total use of treated seed in the U. S. This may be due, in large part, to the greater time investment, labor and equipment commitment required for on farm seed treatment compared to buying the treated. However, some seed crops record a sizable percentage of onfarm seed treatment. A risk assessment for on farm seed treatment ( planter box) is completed in this document using a dust formulation study. The dust formulation study is the only on farm seed treatment study available, and is used as a surrogate for planter box seed treatment with liquid formulation. The planter box seed treatment with liquid formulation risk assessment for liquid is considered conservative since treatment with dust formulations usually present a higher risks than liquids. There are no data for other seed treatments done on farm.

There is a significant exposure to the workers planting treated seed. An Exposure assessment is presented for workers loading treated seed into plant hoppers and driving a closed cab tractor to pull the planter around the field.

Exposure Data Used In Seed Treatment Assessment Commercial, on farm seed treatment and planters exposure was addressed using Science Advisory Council Exposure Policy 14 ( May, 2003), seed treatment Standard Operating Procedure ( SOP). This database was created by U. S. EPA, and measures exposure values for seed treaters and planters under actual field conditions.

Commercial Seed Treatment For commercial assessment four standard scenarios were assessed.

1) Loader/ Applicator The loading/ applying of all formulation ( except liquid closed system and wettable powder) is comprised of 3 exposure studies ( MRID # 43080049, 42251902, 44731501). The loader/ applicator activities in these 3 exposure studies encompass a wide range of seed treater, amount of seed and amounts of pesticides handled for seed treatment scenarios.

The three studies in this scenario monitored an open loading/ applying activity for various 15 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 for hand rinses and face wipes. The methodology in the third study was whole body dosimetry, hand rinses and face wipes.

In the study with MRID # 430800 49, 20 replicates were monitored. Each replicate was a minimum of 3.5 hours. This study involved the treating of soybean seed with Apron using a Gustafson seed treaters at two facilities in the Midwest. The chemical was manually added to the mix tanks from 1 gallon jugs ( 15 replicates) or 3 lb water soluble bags ( 5 replicates). 12500 lbs of seed were treated per hour. Dermal exposure was measured using whole body dosimeters, handwashes and face wipes. Inhalation exposures were measured with glass fiber filters and XAD tubes. Field recovery was grade A for the handwashes and air filters and grade AB for the face wipe and whole body dosimeters.

In the study with MRID # 422519 02, 6 replicates were monitored. The average duration of each replicate was 7.4 hours. This study involved the treating of canola with Oftanol technical at one facility in Canada with a 150 kg batch blending machine. The chemical was pumped to the mixing tank from a 55 GA drum. Each batch took five minutes. Dermal exposure was measured using patches and handwash. Inhalation exposures were measured using quartz microfiber filters. Field fortification recovery was grade A for all media.

In the study with MRID # 447315 01, 2 replicates were monitored ( only 1 replicate was included in the data base due to inadequate lab recovery). This study involved the treating of canola with Vivavax RS flowable at one facility in Canada with a Gustafson Accu treat film coater. The chemical was transferred to the mixing tank from a tote. Dermal exposure was measured using patches, handwashes, glove washes and face washes. Inhalation exposures were measured with glass fiber filters and XAD tubes. Field fortification recovery was grade AB for dermal media. The field recovery for the inhalation media was 220 percent. The laboratory recovery was grade A for both the dermal and inhalation all media.

2) Bagger The bagging system for all formulation ( except liquid closed system and wettable powder) is comprised of 3 exposure studies ( MRID # 43080049, 42251902, and 44731501) for the dermal and inhalation. The bagging in these studies encompass a wide range of bagging equipment, amount of seed and amounts of pesticides handled for seed treatment scenarios.

The three studies in this scenario monitored bagging treated seed in various seed treatment facilities. The number of replicate ranges from 1 to 20 per study. Two of the three studies monitored dermal exposures with whole body dosimeter, face and neck and hand rinses. The methodology in the other three studies was dermal patches and hand rinses.

In the study with MRID # 430800 49, 20 replicates were monitored The same bagging method was used at both facilities. The bagger clamped an empty bag to the bagging machine and 16 the treated seed dropped into the bag. The seed flow stopped automatically and the filled bag dropped onto a conveyor belt.

In the study with MRID # 422519 02, 3 replicates were monitored The treated seed was transferred to a bagging hopper after passing through a compactor and shaker screen. The bagger attached a bag to the hopper and filled the bag. The bagger then removed the bag, carried it to a sewing station and sewed it with a hand held sewer.

In the study with MRID # 447315 01, 1 replicate was monitored This replicate was sampled during bag filling. Methods were the same as for the loader/ applicator with the exception that a full body dosimeter was used instead of patches.

3) Sewers The sewing system for seed treated with all formulation ( except liquid closed system and wettable powder) is comprised of 2 exposure studies ( MRID # 430800 49, and 447315 01) for the dermal and inhalation.

The two studies in this scenario monitored sewing various bags of treated seed in a number of seed treatment facilities. The number of replicate ranges from 1 to 20 per study. All of the studies monitored dermal exposures with whole body dosimeter, face and neck and hand rinses.

In the study with MRID# 430800 49, 20 replicates were monitored. The same sewing method was used at both facilities. The sewer grabbed the bag, attached ID tags and guided it through the sewing and stamping machines.

In the study with the MRID # 447315 01 one replicate was monitored. This replicate was sampled during bag filling. Methods were the same as for the loader/ applicator with the exception that a full body dosimeter was used instead of patches 4) Multiple Activities ( e. g., loader/ applicator, bagger, sewer, cleaner, calibrator, repair, forklift driver, etc).

In the smaller, less automated facilities, one worker will often have multiple duties within the plant. Therefore, seed treatment SOP contains a scenario labeled " Multiple Activities" in order to address this aspect of small commercial operations.

The multiple activities for all formulation ( except liquid closed system and wettable powder) is comprised of 4 exposure studies ( MRID # s, 454427 01, 422519 02, 449045 26 and 447315 01) for the dermal and inhalation. The multiple activities in these studies encompass a wide range of seed treater, amount of seed and amounts of pesticides handled for seed treatment scenarios. 17 The 4 studies in this scenario monitored multiple activities for various seed treatment facilities. The number of replicates ranges from 3 to 45per study). Three of the four studies monitored dermal exposures with whole body dosimeter, face and neck and hand rinses. The methodology in the other study was dermal patches and hand rinses.

In the study with MRID # 454427 01, 20 replicates were monitored. This study involved the treating of rice at three sites in the south with ICON 6.2 FS aqueous flowable using Gustafson PSD50 D3 treaters. A total of 45 workers were monitored with an average replicate time of 6.3 hours. These worker performed mixing/ loading, bagging and clean up. The product was added to the mix tanks from a 30 gallon containers. The rice seed was dumped through the seed treater and stored in a bin until bagged. Dermal exposure was measured with whole body dosimeters, handwash and face/ neck wipes. Inhalation exposures were measured with 37 mm filters and adsorption tubes. Dermal field recoveries were grade AB. Inhalation recoveries were grade A.

In the study with MRID # 422519 02, 3 replicates were monitored. The shift foreman supervised the process and assisted with various tasks as necessary.

In the study with the MRID # MRID 449045 26, 12 replicates were monitored This study involved the treating of wheat, barley, oats and peas at two sites in Canada using Vitaflow 280 packaged in 1000 liter totes or Vivavax Single packaged in a 200 liter drums. The replicates were one half day in length and involved a total of 5 workers. Workers loaded the formulation into the seed treater, operated the seed treater, bagged treated seed, transferred treated seed to storage bins or trucks, cleaned up the seed treatment area and cleaned up treated seed storage bins or the bagging area. Dermal exposure was measured with whole body dosimeters and cotton gloves. Inhalation exposures were measured with millipore filters. The dermal field fortification samples had highly variable recoveries possibly due to contamination.

In the study with MRID 447315 01, 6 replicates were monitored. 2 replicates stacked bags, 3 replicates did all tasks and 1 replicate did all tasks except loading.

On Farm Seed Treatment The on farm system for dust formulation subset is comprised of 1 exposure study ( MRID # 44031611) for the dermal and inhalation.

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. The field recovery was grade A for all media. 18 Planters The planters system for all treated seed is comprised of 2 exposure studies ( MRID # 42251901, 45654503) for dermal and inhalation.

In the study with the MRID # 456545 03, 13 replicates were monitored. Workers involved in the loading and drilling of seed treated with Baytan. The replicates were all located at different sites in the UK. The seed was loaded into the drill hoppers from 0.5 or 1 ton supersacks or 50 kg bags. The amount of seed 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 in the review. 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. Dermal and inhalation field recoveries were grade A.

In the study with the MRID # 422519 01, 13 replicates were monitored. Workers involved in the loading and drilling of canola seed treated with Oftanol which forms a hard shell coating. The replicates 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 handrinse. Inhalation exposures were measured with 37 mm quartz microfiber filters. Dermal and inhalation field recoveries were grade A.

2.1 Occupational Seed Handler Exposures There are potential exposures to loader/ applicator, baggers, sewers, workers performing multiple activities, on farm treatment with planter box and seed planters during usual use patterns associated with PCNB. Based on the use patterns and potential exposures described above, 6 exposure scenarios are identified to represent the extent of PCNB seed treatment uses.

The potential seed treatment handler exposures to 6 exposure scenarios are assessed in this RED chapter using the toxicological endpoints and uncertainty factors associated with the active ingredient. 19 2.1.1 Summary of Uncertainties The seed handler exposure assessments encompass all of the major seed treatment uses of PCNB throughout the country. The assumptions and uncertainties are identified below to be used in risk management decisions:

Application Rates: The application rates are the maximum allowable that were identified on the available product labels.

Amount Handled: The daily lbs treated or the daily lbs/ A planted are provided to HED by BEAD and registrant.

Unit Exposures: The unit exposure values in seed treatment SOP generally range from the geometric mean to the median for the selected data set. The caveats specific to each exposure scenario are summarized in Appendix D, Table D3. While data from seed treatment SOP provides the best available information on seed handler exposures, it should be noted that some aspects of the included studies ( e. g., duration, lbs of seed treated, pounds of active ingredient handled) may not accurately represent labeled uses in all cases.

2.1.2 Seed Handler Risks Table 6 presents the exposure scenarios, amount treated and amount planted ( i. e., lbs of seed or lbs/ A planted) that have been used in the exposure calculations. PCNB labels include a multitude of uses and a wide range of application rates. Therefore, the rates presented in Table 6 are not all inclusive and an attempt has been made to assess a range of application rates to capture exposure associated within each scenario.

Seed treatment data base consists of 6 exposure scenarios. The assumptions in this data base are based on the fact that the magnitude of handler exposures to pesticides are primarily a function of activity ( e. g., loader/ applicator, baggers, sewers), and clothing scenarios ( e. g., gloves, double layer clothing). Data are selected for a given scenario and normalized ( i. e., divided by) by the amount of pesticide handled resulting in standard unit exposures ( milligrams of exposure per pound of active ingredient handled). Following normalization, the data are statistically summarized. The distribution of exposure values is categorized as normal, lognormal, or " other" ( i. e., neither normal nor lognormal). A central tendency value is then selected from the distribution of the exposure values for each activity. These values are the geometric mean for lognormal distributions, and the median for all " other" distributions and are presented in table 7. 20 Table 6: Amount of seed treated or planted with PCNB Seed Type Application rate lb ai/ lb seed Commercial * Applicati on rate lb ai/ lb seed onfarm Amount Treated/ day for Commercial seed Treatment1 Amount Treated/ day for on farm Treatment4 ( planter box) Amount of seed planted lb/ acre2 Acres planted / day3 amount of seed planted per day ( lbs)

barley 0.001307 0.000878 718000 7200 90 200 18000 bean 0.000523 0.000750 575000 4000 50 200 10000 corn 0.000523 0.000558 550000 1440 18 200 3600 cotton 0.000788 0.000150 160000 1200 15 ( adl) 200 3000 3200 40 ( rg) 8000 oats 0.001957 0.000604 718000 7200 90 200 18000 pea 0.001045 0.001042 575000 6400 80 80 6400 peanut 0.000610 0.000750 120000 9280 116 80 9280 rice 0.001391 0.000926 718000 12000 150 200 30000 safflower 0.00061 NA 718000 2400 30 80 2400 sorghum 0.000305 NA 718000 640 8 80 640 soybean 0.001045 0.001044 575000 4800 60 200 12000 sugar beet 0.001873 0.000625 120000 400 5 80 400 wheat 0.000525 0.000521 718000 9600 120 200 24000 * Liquid formulation only ** Dust formulation only 1: Derived from the Gustafson Efficiency Guide. Values are for the Accu Treat Treater for small grains, cotton and corn and the AMPD Treater for peanuts. 2: Maximum values provided by Dr. Bernard Schneider of EPA. 3: Based upon ExpoSAC Policy 9 " Standard Values for Daily Acres Treated in Agriculture". 4: Amount of seed planted per acre times acres planted per day ( 80 acres assumed for all crops) .

Calculations of Exposure Potential daily dermal exposure is calculated using the following formula:

Daily Dermal Exposure ( mg ai/ day) =

Dermal Unit Exposure ( mg ai/ lb ai) x Application Rate ( lb ai/ lb of seed ) x Daily amount Treated ( lbs)

Potential daily inhalation exposure is calculated using the following formula: 21 Daily Inhalation Exposure ( mg ai/ day) =

Inhalation Unit Exposure ( mg ai/ lb ai) x Application Rate ( lb ai/ lb of seed) x Daily amount Treated ( lbs)

These calculations of potential daily exposure to PCNB by seed treatment handlers are used to calculate the absorbed doses and total risk to those handlers.

Calculation OF Risk Using the daily dermal exposure scenarios identified in the exposure section, HED calculated the potential risk to persons from handler exposures.

The inhalation and dermal daily doses were calculated using the following formulas:

Daily dermal dose ( mg/ kg/ day) = daily dermal exposure( mg ai/ day)/ body weight( kg) x dermal absorption factor( 100%)

Daily Inhalation dose ( mg/ kg/ day) = daily Inhalation exposure( mg ai/ day)/ body weight( kg) x 100%

The MOEs were calculated using the following formulas:

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

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

Margins of exposure ( MOEs) were calculated for handlers for short term ( up to 1 month) and intermediate term ( 1 to 6 months) durations. The assessment includes MOE calculations for the surrogate data from seed treatment SOP. The short term duration is believed to be most representative of on farm seed treaters and the intermediate term duration represents commercial seed treaters who may repeatedly apply PCNB for 1 to 6 months.

HED calculated the baseline, minimum PPE, maximum PPE MOEs for each occupational exposure scenario using the following assumptions:

All Scenarios: All occupational handlers are wearing footwear ( socks plus shoes or boots), foot exposure is not traditionally monitored, and therefore, a 100 percent protection factor is implied.

Baseline Attire: Seed treaters using on farm, bagging, sewing techniques and are wearing long sleeved shirts, long pants, no gloves, and no respirator. 22 Minimum PPE Seed treaters using on farm, loading/ applying techniques and are wearing long sleeved shirts, long pants, gloves, and no respirator.

Maximum PPE Seed treaters loading/ applying techniques and are wearing long sleeved shirts, long pants, gloves, coveralls and no respirator.

Table 7 Summary of Exposure Data Used for PCNB Seed Treatment Risk Assessment Exposure Scenarios Baseline Dermal ( mg/ lb ai) Baseline Inhalation ( ug/ lb ai) Single Layer Dermal ( mg/ lb ai) Double Layer Dermal ( mg/ lb ai)

Loader/ Applicator ( 1) ND 0.34 0.023 0.018 Bagger ( 2) 0.0091 0.16 ND ND Sewer ( 3) 0.0062 0.23 ND ND Multiple Activities ( 4) ND 1.6 0.042 ND On Farm Planter Box Treatment ( 5) 13 1.2 12.6 ( glove) ND Load and Plant Treated Seed ( 6) ND 3.4 0.25 ND The results of the seed treatment risk assessment for both the short and intermediate term exposure durations presented in appendix B ( table B9) and are summarized in Table 8. Margins of exposure ( MOEs) were calculated for seed treatment handlers and planters for short term ( up to 1 month) and intermediate term ( 1 to 6 months) durations. The assessment includes MOE calculations for various feasible levels of personal protective equipment ( PPE) using the surrogate data from seed treatment SOP.

The results of the short and intermediate term seed handler assessments indicate that for all formulations the majority of the potential exposure scenarios provide total MOE( s) greater than or equal to 100 at the clothing attire of long pants, long sleeved shirts, gloves, and no respirator while using open systems.). Seed handlers working in a smaller facility performing multiple activities might require respirator in order to have MOEs of greater than or equal to100. There is no separate measurement of exposure for various job function in a smaller facility, therefore it is not feasible to require respirator for workers treating seeds in a small operation. they enter in to the facility. 23 Table 8: Summary of Short and Intermediate term Dermal and Inhalation Risk from Seed Treatment for PCNB ( MOEs )

Crops Loader/ applicator Bagger Sewer Multiple activities On Farm ( planter box) Planters Dermal Inh Derma l Inh Derma l Inh Derma l Inh Derma l Inh Derma l Inh Barley 1000 200 2500 500 3600 350 550 50 300 9000 3600 900 Bean 3000 700 8000 1500 11000 1000 1500 150 550 20000 16000 4000 Corn 3200 700 8000 1500 12000 1100 1800 150 2100 73000 45000 11000 Cotton 7000 1650 18000 3500 27000 2400 4000 350 9300 33000 0 36000 8700 NA NA NA NA NA NA NA NA 3500 12000 0 13000 3300 Oats 650 150 1700 300 2400 200 360 300 400 13000 2400 600 Pea 1500 350 4000 730 5700 500 800 75 250 9000 13000 3000 Peanut 12500 2800 31500 6000 46000 4200 6800 600 240 8400 14500 0 3600 Rice 900 200 2300 400 3400 300 500 50 150 5300 2000 500 Safflower 2100 470 5300 1000 7700 700 1100 100 NA NA 57000 14000 Sorghum 4200 940 11000 2000 15000 1400 2300 200 NA NA 43000 0 110000 Soybeans 1500 350 3900 700 5700 500 800 75 3300 12000 0 7000 1600 Sugar beet 4100 900 10000 2000 15000 1300 2000 200 7000 23000 0 11000 0 27000 Wheat 2400 600 6000 1100 9000 800 1300 120 340 12000 7000 1600 24 3.0 OCCUPATIONAL EXPOSURES ( HANDLER and POSTAPPLICATION)

3.1 Occupational Handlers 3.1.1 Handler Exposures Scenarios HED has determined that there are potential exposures to mixers, loaders, applicators, or other handlers during usual use patterns associated with PCNB. Based on the use patterns and potential exposures described in Section 1.3, 103 agricultural and ornamental exposure scenarios are identified to represent the extent of PCNB uses.

The potential handler exposures to the 103 exposure scenarios are assessed in this RED chapter using the toxicological endpoints and uncertainty factors associated with the active ingredient. Therefore, the level of personal protective equipment ( PPE) is determined by the assessment of the active ingredient independently from the currently required risk mitigation measures on PCNB labels. This distinction of determining risk mitigation measures based on the active ingredient instead of the label required PPE is important because of the nature of the enduse products. For example, some end use products may require additional PPE because of the end use product's potential for eye and/ or skin irritation . Conversely, HED does not want to mandate additional PPE ( e. g., heat stress issues) if it is not required based on the endpoint and uncertainty factors. There are some PPE, such as chemical resistant aprons and/ or head gear, that the HED uses as qualitative measures because there are no recognized protection factors ( PF) to assess their effectiveness. The Agency's risk managers require these types of PPE as additional mitigation of risk. For example, chemical resistant aprons are often required to protect mixer/ loaders from accidental spills. .

For occupational RED chapters process, HED presents the risks separately for some scenarios and combines others. Most of the hand held equipment such as push type granular spreaders are assessed as mixer/ loader/ applicators, a combined function. With these types of small operations the mixing, loading, and applying are almost always carried out by the same individual. There are data available to estimate exposure from these small area activities. For equipment such as groundboom tractors, or airblast sprayers the tasks are assessed separately for mixer/ loaders and applicators. By separating the two job functions, HED can determine the most appropriate PPE or engineering control without requiring the handler to wear PPE throughout the entire workday or engineering controls that are not needed.

3.1.2 Summary of Uncertainties The handler exposure assessments encompass all of the major uses of PCNB throughout the country. It is difficult to assess all of the " typical" agricultural uses ( i. e., actual or predominate application rates and farm sizes), and therefore, an assessment has been developed that believed to be realistic and yet provides a reasonable certainty that the exposures are not underestimated. The assumptions and uncertainties are identified below to be used in risk 25 management decisions:

Application Rates: The application rates are the maximum allowable that were identified on the available product labels.

Acres Treated: The daily acres treated are HED standard values ( EXPO SAC policy 9.1).

Unit Exposures: The unit exposure values 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 D, Table D1. While data from PHED provides 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 cases.

Amount Handled: The daily acres treated are HED standard values ( see Table 9). Deviations from these standard values include the airblast acreage for magnolia tree. The acreage is assessed at 20 acres because magnolia trees are grown in smaller plots.

3.1.3 Handler Risks Table 9 presents the exposure scenarios, application rates, and amount treated ( i. e., acres or gallons ) that have been used in the exposure calculations. PCNB labels include a multitude of uses and a wide range of application rates. Therefore, the rates presented in Table 6 are not all inclusive and an attempt has been made to assess a range of application rates to capture exposure associated within each scenario.

PHED V1.1 has been used to assess the exposure scenarios for PCNB. PHED was designed by a Task Force of representatives from the U. S. EPA, Health Canada, the California Department of Pesticide Regulation, and member companies of the American Crop Protection Association. PHED is a software system consisting of two parts  a database of measured exposure values for workers involved in the handling of pesticides under actual field conditions and a set of computer algorithms used to subset and statistically summarize the selected data. Currently, the database contains values for over 1,700 monitored individuals ( i. e., replicates).

Users select criteria to subset the PHED database to reflect the exposure scenario being 26 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., wettable powders, granulars), application method ( e. g., aerial, groundboom), and clothing scenarios ( e. g., gloves, double layer clothing). Once the data for a given exposure scenario has been selected, the data are normalized ( i. e., divided by) by the amount of pesticide handled resulting in standard unit exposures ( milligrams of exposure per pound of active ingredient handled). Following normalization, the data are statistically summarized. The distribution of exposure values for each body part ( e. g., chest, upper arm) is categorized as normal, lognormal, or " other" ( i. e., neither normal nor lognormal). A central tendency value is then selected from the distribution of the exposure values for each body part. These values are the arithmetic mean for normal distributions, the geometric mean for lognormal distributions, and the median for all " other" distributions. Once selected, the central tendency values for each body part are composited into a " best fit" exposure value representing the entire body.

Table 9: Exposure Variables for Agricultural Uses ( Including Non WPS Ornamental Uses) of PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Mixer/ Loader Dry Flowables for High Pressure HandWand application ( 1) Containerized nursery stock, soil drench ( beans, brussels sprouts, cabbage, cauliflower) 0.00375 1000 gals Dry Flowables for Chemigation application ( 2) Commercial/ industrial lawns 32.67 10 Dry Flowables for High Pressure HandWand application ( 3) Commercial/ industrial lawns, residential lawn 0.04 1000 gals Dry Flowables for Chemigation application ( 4) Golf course turf ( tees/ greens) 32.67 10 Dry Flowables for Chemigation application ( 5) Golf course turf ( fairways) 32.67 40 Dry Flowables for Chemigation application ( 6) Sod farms 32.67 350 Dry Flowables for High Pressure HandWand application ( 7) Ornamentals ( herbaceous plants, woody shrubs and vines) 1.50 1000gals Dry Flowables for High Pressure HandWand application ( 8) Containerized nursery stock, soil drench ( pepper, tomato) 0.00375 1000 gals Dry Flowables for Groundboom application ( 9) Soil band treatment ( broccoli, brussels sprouts, cabbage, cauliflower) 30 80 Dry Flowables for Groundboom application ( 10) Cotton 2 200 Dry Flowables for Groundboom application ( 11) Peanuts 11.59 80 Mixing/ Loading Liquids for Groundboom application ( 12) Band treatment ( dried beans, succulent beans, lima) 2 80 Mixing/ Loading Liquids for Groundboom application ( 13) Band treatment, soil treatment ( garlic) 20 80 Mixing/ Loading Liquids for Chemigation application ( 14) Ornamental lawn and turf 32.67 5 Mixing/ Loading Liquids for Chemigation application ( 15) Commercial/ industrial lawns 32.67 10 Table 9: Exposure Variables for Agricultural Uses ( Including Non WPS Ornamental Uses) of PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals 27 Mixing/ Loading Liquids for Chemigation application ( 16) Sod farms 32.67 350 Mixing/ Loading Liquids for Groundboom application ( 16a) Sod farms 32.67 80 Mixing/ Loading Liquids for Chemigation application ( 17) Golf course turf 32.67 10 Mixing/ Loading Liquids for Chemigation application ( 18) Golf course turf ( fairways) 32.67 40 Mixing/ Loading Liquids for High Pressure HandWand application ( 19) Commercial industrial lawn 0.15 1000 gals Mixing/ Loading Liquids for Groundboom application ( 20) Cotton 2 200 Mixing/ Loading Liquids for Groundboom application ( 21) Garlic 20 80 Mixing/ Loading Liquids for Groundboom application ( 22) Peanuts 10 80 Mixing/ Loading Liquids for Groundboom application ( 23) Potato 25 80 Mixing/ Loading Liquids for Chemigation application ( 24) Potato 25 350 Mixing/ Loading Liquids for Aerial application ( 25) Potato 25 350 Mixing/ Loading Liquids for Groundboom application ( 26) Soil band treatment ( broccoli, Chinese broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 30 80 Mixing/ Loading Liquids for High Pressure HandWand application ( 27) Containerized stock ( broccoli, Chinese broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 0.015 1000 gals Mixing/ Loading Liquids for Airblast application ( 28) Foliar spray ( magnolia tree) 6 20 Mixing/ Loading Liquids for Groundboom application ( 29) Tomato, pepper 7.50 80 Mixing/ Loading Liquids for Groundboom application ( 30) Southern pine ( seed orchard) 42.50 10 Mixing/ Loading Liquids for Dip tank application ( 31) Ornamental bulb soak and cut flowers 0.015 100 gals Loading Granulars for Tractor Drawn Spreaders application ( 32) Beans 1.50 80 Loading Granulars for Tractor Drawn Spreaders application ( 33) Soil band treatment ( broccoli, brussels sprouts, cabbage, cauliflower, collards, kale, mustard) 30 80 Loading Granulars for Tractor Drawn Spreaders application ( 34) Golf course turf ( tees/ greens) 43.56 10 Loading Granulars for Tractor Drawn Spreaders application ( 35) Golf course turf ( fairways) 43.56 40 Loading Granulars for Tractor Drawn Spreaders application ( 36) Sod farms 43.56 80 Loading Granulars for Tractor Drawn Spreaders application ( 37) Cotton 2 200 Loading Granulars for Tractor Drawn Spreaders application ( 38) Pepper 1.35 80 Table 9: Exposure Variables for Agricultural Uses ( Including Non WPS Ornamental Uses) of PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals 28 Loading Granulars for Tractor Drawn Spreaders application ( 39) Potato 25 80 Wettable Powders for Groundboom application ( 40) beans( lima, snap, dried) 1.50 80 Wettable Powders for Chemigation application ( 41) beans( lima, snap, dried) 1.50 350 Wettable Powders for Chemigation application ( 42) soil band treatment ( broccoli, Chinese, broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 30 350 Wettable Powders for Groundboom application ( 43) soil band treatment ( broccoli, Chinese, broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 30 80 Wettable Powders for Chemigation application ( 44) commercial/ industrial lawns 40.80 10 Wettable Powders for High Pressure HandWand application ( 45) commercial/ industrial lawns 0.50 1000 gals Wettable Powders for Groundboom application ( 46) cotton 2 200 Wettable Powders for Chemigation application ( 47) cotton 2 350 Wettable Powders for Chemigation application ( 48) golf course turf ( tees and greens) 40.80 10 Wettable Powders for Chemigation application ( 49) golf course turf ( fairways) 40.80 40 Wettable Powders for Chemigation application ( 50) sod farms 40.80 350 Wettable Powders for Groundboom application ( 51) sod farms 40.80 80 Wettable Powders for Groundboom application ( 52) Peanuts 2 80 Wettable Powders for Chemigation application ( 53) peanuts 2 350 Wettable Powders for Groundboom application ( 54) pepper, tomato 7.50 80 Wettable Powders for Groundboom application ( 55) pine ( seed orchard) 37.50 10 Applicator Sprays for High Pressure HandWand application ( 56) containerized nursery stock, soil drench ( beans, brussels sprouts, cabbage, cauliflower) 0.00375 1000 gals Sprays for High Pressure HandWand application ( 57) commercial/ industrial lawns, residential lawn 0.04 1000 gals Sprays for High Pressure HandWand application ( 58) ornamentals ( foliar application only) 1.50 1000 gals Sprays for High Pressure HandWand application ( 59) containerized nursery stock, soil drench ( pepper, tomato) 0.0038 1000 gals Sprays for Groundboom application ( 60) Soil band treatment ( broccoli, brussels sprouts, cabbage, cauliflower) 30 80 Sprays for Groundboom application ( 61) Cotton 2 200 Sprays for Groundboom application ( 62) Peanuts 11.59 80 Table 9: Exposure Variables for Agricultural Uses ( Including Non WPS Ornamental Uses) of PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals 29 Sprays for Groundboom application ( 63) Band treatment ( dried beans, succulent beans, lima) 2 80 Sprays for Groundboom application ( 64) Band treatment, soil treatment ( garlic) 20 80 Sprays for High Pressure HandWand application ( 65) commercial industrial lawn 0.15 1000 gals Sprays for Groundboom application ( 66) Cotton 2 200 Sprays for Groundboom application ( 67) Garlic 20 80 Sprays for Groundboom application ( 68) Peanuts 10 80 Sprays for Groundboom application ( 69) Potato 25 80 Sprays for Aerial application ( 70) potato 25 350 Sprays for Groundboom application ( 71) Soil band treatment ( broccoli, Chinese broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 30 80 Sprays for High Pressure HandWand application ( 72) containerized stock ( broccoli, Chinese broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 0.015 1000 gals Sprays for Airblast application ( 73) Foliar spray ( magnolia tree) 6 20 Sprays for Groundboom application ( 74) Tomato, pepper 7.50 80 Sprays for Groundboom application ( 75) Southern pine ( seed orchard) 42.50 10 Applying Granulars for Tractor Drawn Spreaders application ( 76) Beans 1.50 80 Applying Granulars for Tractor Drawn Spreaders application ( 77) Soil band treatment ( broccoli, brussels sprouts, cabbage, cauliflower, collards, kale, mustard) 30 80 Applying Granulars for Tractor Drawn Spreaders application ( 78) Golf course turf ( tees/ greens) 43.56 10 Applying Granulars for Tractor Drawn Spreaders application ( 79) Golf course turf ( fairways) 43.56 40 Applying Granulars for Tractor Drawn Spreaders application ( 80) Sod farms 43.56 80 Applying Granulars for Tractor Drawn Spreaders application ( 81) Cotton 2 200 Applying Granulars for Tractor Drawn Spreaders application ( 82) Peanuts 2 80 Applying Granulars for Tractor Drawn Spreaders application ( 83) Pepper 1.35 80 Applying Granulars for Tractor Drawn Spreaders application ( 84) Potato 25 80 Sprays for Groundboom application ( 85) Beans( lima, snap, dried) 1.50 80 Table 9: Exposure Variables for Agricultural Uses ( Including Non WPS Ornamental Uses) of PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals 30 Sprays for Groundboom application ( 86) Soil band treatment ( broccoli, Chinese, broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 30 80 Sprays for High Pressure HandWand application ( 87) commercial/ industrial lawns 0.50 1000 gals Sprays for Groundboom application ( 88) Cotton 2 200 Sprays for Groundboom application ( 89) Sod farms 40.80 80 Sprays for Groundboom application ( 89a) Sod farms 32.67 80 Sprays for Groundboom application ( 90) Peanuts 2 80 Sprays for Groundboom application ( 91) Pepper, tomato 7.50 80 Sprays for Groundboom application ( 92) Pine ( seed orchard) 37.50 10 Flagger Flagging for Sprays application ( 93) Potato 25 350 Mixer/ Loader/ App Mixing/ Loading/ Applying Liquids for Handgun ( lawn) Sprayer ( ORETF) application ( 94) Ornamentals ( herbaceous plants, woody shrubs and vines) 218 5 Mixing/ Loading/ Applying Liquids for Handgun ( lawn) Sprayer ( ORETF) application ( 95) Ornamental and Lawn turf 32.67 5 Loading/ Applying Granulars for Push type spreader ( ORETF) application ( 96) Commercial industrial lawns 43.56 5 Loading/ Applying Granulars for Belly Grinder application ( 97) ornamental lawns and turf 43.56 0.5 Loading/ Applying Granulars for Belly Grinder application ( 98) ornamentals ( shade trees, herbaceous, woody shrubs and vines) 217.80 0.5 Loading/ Applying Granulars for Push type spreader ( ORETF) application ( 99) Ornamentals ( shade trees, herbaceous, woody shrubs and vines) 217.80 0.5 Mixing/ Loading/ Applying Wet Powders for Low Pressure Handwand application ( 100) ornamental ( woody shrubs and vines, herbaceous plants) 217.80 5 Mixing/ Loading/ Applying Wet Powders for Low Pressure Handwand application ( 101) ornamental ( shade trees) 37.50 5 Calculations of Exposure Potential daily dermal exposure is calculated using the following formula:

Daily Dermal Exposure ( mg ai/ day) =

Dermal Unit Exposure ( mg ai/ lb ai) x Application Rate ( lb ai/ A or gal) x Daily Acres or gallons Treated ( A or gal/ day) 31 Potential daily inhalation exposure is calculated using the following formula:

Daily Inhalation Exposure ( mg ai/ day) =

Inhalation Unit Exposure ( mg ai/ lb ai) x Application Rate ( lb ai/ A or gal) x Daily Acres or gallons Treated ( A or gal/ day)

Calculation Of Risk Using the daily dermal exposure scenarios identified in the exposure section, HED calculated the potential risk to persons from handler exposures.

The inhalation and dermal daily doses were calculated using the following formulas:

Daily dermal dose ( mg/ kg/ day) = daily dermal exposure( mg ai/ day)/ body weight( kg) x dermal absorption factor( 100%)

Daily Inhalation dose ( mg/ kg/ day) = daily Inhalation exposure( mg ai/ day)/ body weight( kg) x 100%

The MOEs were calculated using the following formulas:

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

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

3.1.4 Risks Summary Margins of exposure ( MOEs) were calculated for handlers for short term ( up to 1 month) and intermediate term ( 1 to 6 months) durations. The assessment includes MOE calculations for various levels of personal protective equipment ( PPE) using the surrogate data from PHED. The short term duration is believed to be most representative of private growers and the intermediateterm duration represents commercial applicators who may repeatedly apply PCNB for 1 to 6 months.

HED calculated the baseline, minimum PPE ( labeled PPE1, PPE2, PPE3), maximum PPE ( labeled PPE4, PPE5, PPE6), and engineering control MOEs for each occupational exposure scenario using the following assumptions:

All Scenarios: All occupational handlers are wearing footwear ( socks plus shoes or boots), foot exposure is not traditionally monitored, and therefore, a 100 percent protection factor is implied.

Baseline Attire: Occupational handlers using open mixing techniques and open cab tractors are wearing longsleeved shirts, long pants, no gloves, and no respirator. 32 Minimum PPE ( PPE1) Attire: Occupational handlers using open mixing techniques and open cab tractors are wearing longsleeved shirts, long pants, chemical resistant gloves, and a no respirator.

Minimum PPE ( PPE2) Attire: Occupational handlers using open mixing techniques and open cab tractors are wearing longsleeved shirts, long pants, chemical resistant gloves, and a dust/ mist ( 5 fold PF) respirator.

Minimum PPE ( PPE3) Attire: Occupational handlers using open mixing techniques and open cab tractors are wearing longsleeved shirts, long pants, chemical resistant gloves, and an air purifying ( 10 fold PF) respirator.

Maximum PPE ( PPE4) Attire: Occupational handlers using open mixing techniques and open cab tractors are wearing coveralls over long sleeved shirts, long pants, chemical resistant gloves, and no respirator.

Maximum PPE ( PPE5) Attire: Occupational handlers using open mixing techniques and open cab tractors are wearing coveralls over long sleeved shirts, long pants, chemical resistant gloves, and a PF 5 ( 5 fold PF) respirator.

Maximum PPE ( PPE6) Attire: Occupational handlers using open mixing techniques and open cab tractors are wearing coveralls over long sleeved shirts, long pants, chemical resistant gloves, and an PF 10 ( 10 fold PF) respirator.

Engineering Controls: Occupational handlers using closed mixing techniques and enclosed cab tractors or cockpits while wearing long sleeved shirts, long pants, chemical resistant gloves, and no respiratory protection.

The results of the dermal handler risk assessment for both the short and intermediate term exposure durations are summarized in Table 10.

The risk calculations for dermal short and intermediate term exposure risk calculations resulted largely in MOEs greater than or equal to 100, with use of PPE or engineering controls. The following scenarios did not have MOEs greater than or equal to 100 at any mitigation level:

The agricultural results of the short and intermediate term occupational handler assessments indicate that for the dry flowable formulation the majority of the potential exposure scenarios provide total MOE( s) greater than or equal to 100 at the baseline clothing attire of long pants, long sleeved shirts, no gloves, and no respirator while using open systems. For the liquid formulation, the risks indicate that in order for the mixer/ loaders to achieve MOEs of 100 for all uses at both the short and intermediate term exposure durations that minimum PPE clothing attire be required ( i. e., long pants, long sleeved shirts, chemical resistant gloves, and a dust/ mist 33 respirator while using open systems). For the wettable powder formulation risks indicate that in order for the mixer/ loaders to achieve MOEs of 100 for all uses at both the short and intermediate term durations that some uses should be packaged in water soluble packets ( clothing attire of long pants, long sleeved shirts, chemical resistant gloves, and no respirator). The risk for the majority of uses with wettable powder is acceptable. Dust formulation was only used for seed treatment and have acceptable risk.

Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C Mixer/ Loader Dry Flowables for High Pressure HandWand application ( 1) Containerized nursery stock, soil drench ( beans, brussels sprouts, cabbage, cauliflower) 0.0038 1000 gals 85000 85000 120000 No Data 24000 120000 240000 No Data Dry Flowables for Chemigation application ( 2) Commercial/ industrial lawns 32.67 10 970 970 1400 No Data 280 1400 2800 No Data Dry Flowables for High Pressure HandWand application ( 3) Commercial/ industrial lawns, residential lawn 0.04 1000 gals 8500 8500 12000 No Data 2400 12000 24000 No Data Dry Flowables for Chemigation application ( 4) Golf course turf ( tees/ greens) 32.67 10 970 970 1400 No Data 280 1400 2800 No Data Dry Flowables for Chemigation application ( 5) Golf course turf ( fairways) 32.67 40 240 240 340 No Data 70 360 700 No Data Dry Flowables for Chemigation application ( 6) Sod farms 32.67 350 28 28 39 No Data 8 41 80 No Data Dry Flowables for High Pressure HandWand application ( 7) Ornamentals ( herbaceous plants, woody shrubs and vines) 1.50 1000gals 210 210 300 No Data 61 310 610 No Data Dry Flowables for High Pressure HandWand application ( 8) Containerized nursery stock, soil drench ( pepper, tomato) 0.0038 1000 gals 85000 85000 120000 No Data 24000 120000 240000 No Data Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 34 Dry Flowables for Groundboom application ( 9) Soil band treatment ( broccoli, brussels sprouts, cabbage, cauliflower) 30 80 130 130 190 No Data 38 190 380 No Data Dry Flowables for Groundboom application ( 10) Cotton 2 200 800 800 1100 No Data 230 1200 2300 No Data Dry Flowables for Groundboom application ( 11) Peanuts 11.59 80 340 340 480 No Data 98 500 980 No Data Mixing/ Loadin g Liquids for Groundboom application ( 12) Band treatment ( dried beans, succulent beans, lima) 2 80 45 5700 7700 15000 360 1800 3600 5300 Mixing/ Loadin g Liquids for Groundboom application ( 13) Band treatment, soil treatment ( garlic) 20 80 4.5 570 770 1500 36 180 360 530 Mixing/ Loadin g Liquids for Chemigation application ( 14) Ornamental lawn and turf 32.67 5 44 5600 7600 15000 360 1800 3600 5200 Mixing/ Loadin g Liquids for Chemigation application ( 15) Commercial/ in dustrial lawns 32.67 10 22 2800 3800 7500 180 890 1800 2600 Mixing/ Loadin g Liquids for Chemigation application ( 16) Sod farms 32.67 350 0.63 80 110 210 5.1 26 51 74 Mixing/ Loadin g Liquids for Grounfboom application ( 16a) Sod farms 32.67 80 2.8 350 470 930 22 110 220 320 Mixing/ Loadin g Liquids for Chemigation application ( 17) Golf course turf 32.67 10 22 2800 3800 7500 180 890 1800 2600 Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 35 Mixing/ Loadin g Liquids for Chemigation application ( 18) Golf course turf ( fairways) 32.67 40 5.5 700 950 1900 45 220 450 650 Mixing/ Loadin g Liquids for High Pressure HandWand application ( 19) Commercial industrial lawn 0.15 1000 gals 48 6100 8200 16000 390 1900 3900 5600 Mixing/ Loadin g Liquids for Groundboom application ( 20) Cotton 2 200 18 2300 3100 6100 150 730 1500 2100 Mixing/ Loadin g Liquids for Groundboom application ( 21) Garlic 20 80 4.5 570 770 1500 36 180 360 530 Mixing/ Loadin g Liquids for Groundboom application ( 22) Peanuts 10 80 9.1 1100 1500 3100 73 360 730 1100 Mixing/ Loadin g Liquids for Groundboom application ( 23) Potato 25 80 3.6 460 620 1200 29 150 290 420 Mixing/ Loadin g Liquids for Chemigation application ( 24) Potato 25 350 0.83 100 140 280 6.7 33 67 96 Mixing/ Loadin g Liquids for Aerial application ( 25) Potato 25 350 0.83 100 140 280 6.7 33 67 96 Mixing/ Loadin g Liquids for Groundboom application ( 26) Soil band treatment ( broccoli, Chinese broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 30 80 3 380 510 1000 24 120 240 350 Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 36 Mixing/ Loadin g Liquids for High Pressure HandWand application ( 27) Containerized stock ( broccoli, Chinese broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 0.02 1000 gals 480 6100 82000 160000 3900 19000 39000 56000 Mixing/ Loadin g Liquids for Airblast application ( 28) Foliar spray ( magnolia tree) 6 20 60 7600 10000 20000 490 2400 4900 7000 Mixing/ Loadin g Liquids for Groundboom application ( 29) Tomato, pepper 7.50 80 12 1500 2100 4100 97 490 970 1400 Mixing/ Loadin g Liquids for Groundboom application ( 30) Southern pine ( seed orchard) 42.50 10 17 2100 2900 5700 140 690 1400 2000 Mixing/ Loadin g Liquids for Dip tank application ( 31) Ornamental bulb soak and cut flowers 0.02 100 gals 4800 61000 0 820000 1600000 39000 190000 390000 56000 0 Loading Granulars for Tractor Drawn Spreaders application ( 32) Beans 1.50 80 21000 25000 51000 1000000 340 1700 3400 17000 Loading Granulars for Tractor Drawn Spreaders application ( 33) Soil band treatment ( broccoli, brussels sprouts, cabbage, cauliflower, collards, kale, mustard) 30 80 1000 1300 2600 51000 17 86 170 860 Loading Granulars for Tractor Drawn Spreaders application ( 34) Golf course turf ( tees/ greens) 43.56 10 5700 7000 14000 280000 95 470 950 4700 Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 37 Loading Granulars for Tractor Drawn Spreaders application ( 35) Golf course turf ( fairways) 43.56 40 1400 1700 3500 71000 24 120 240 1200 Loading Granulars for Tractor Drawn Spreaders application ( 36) Sod farms 43.56 80 720 870 1800 35000 12 59 120 590 Loading Granulars for Tractor Drawn Spreaders application ( 37) Cotton 2 200 6300 7600 15000 310000 100 510 1000 5100 Loading Granulars for Tractor Drawn Spreaders application ( 38) Pepper 1.35 80 23000 28000 57000 1100000 380 1900 3800 19000 Loading Granulars for Tractor Drawn Spreaders application ( 39) Potato 25 80 1300 1500 3100 62000 21 100 210 1000 Wettable Powders for Groundboom application ( 40) beans( lima, snap, dried) 1.50 80 47 1000 1300 18000 14 68 140 2400 Wettable Powders for Chemigation application ( 41) beans( lima, snap, dried) 1.50 350 11 240 310 4100 3.1 16 31 560 Wettable Powders for Chemigation application ( 42) soil band treatment ( broccoli, Chinese, broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 30 350 0.54 12 15 200 0.16 0.78 1.6 28 Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 38 Wettable Powders for Groundboom application ( 43) soil band treatment ( broccoli, Chinese, broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 30 80 2.4 51 67 890 0.68 3.4 6.8 120 Wettable Powders for Chemigation application ( 44) commercial/ in dustrial lawns 40.80 10 14 300 400 5300 4 20 40 710 Wettable Powders for High Pressure HandWand application ( 45) commercial/ in dustrial lawns 0.50 1000 gals 11 250 320 4300 3.3 16 33 580 Wettable Powders for Groundboom application ( 46) cotton 2 200 14 310 400 5400 4.1 20 41 730 Wettable Powders for Chemigation application ( 47) cotton 2 350 8.1 180 230 3100 2.3 12 23 420 Wettable Powders for Chemigation application ( 48) golf course turf ( tees and greens) 40.80 10 14 300 400 5300 4 20 40 710 Wettable Powders for Chemigation application ( 49) golf course turf ( fairways) 40.80 40 3.5 76 99 1300 0.100 5 1.00 180 Wettable Powders for Chemigation application ( 50) sod farms 40.80 350 0.4 8.7 11 150 0.11 0.57 1.1 20 Wettable Powders for Groundboom application ( 51) sod farms 40.80 80 1.7 38 49 660 0.50 2.5 5 89 Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 39 Wettable Powders for Groundboom application ( 52) Peanuts 2 80 35 770 1000 13000 10 51 100 1800 Wettable Powders for Chemigation application ( 53) peanuts 2 350 8.1 180 230 3100 2.3 12 23 420 Wettable Powders for Groundboom application ( 54) pepper, tomato 7.50 80 9.5 210 270 3600 2.7 14 27 490 Wettable Powders for Groundboom application ( 55) pine ( seed orchard) 37.50 10 15 330 430 5700 4.3 22 43 780 Applicator Sprays for High Pressure HandWand application ( 56) containerized nursery stock, soil drench ( beans, brussels sprouts, cabbage, cauliflower) 0.0038 1000 gals 3100 8800 16000 No Data 240 1200 2400 No Data Sprays for High Pressure HandWand application ( 57) commercial/ in dustrial lawns, residential lawn 0.04 1000 gals 310 880 1600 No Data 24 120 240 No Data Sprays for High Pressure HandWand application ( 58) ornamentals ( foliar application only) 1.50 1000 gals 7.8 22 39 No Data 0.59 2.9 5.9 No Data Sprays for High Pressure HandWand application ( 59) containerized nursery stock, soil drench ( pepper, tomato) 0.0038 1000 gals 3100 8800 16000 No Data 240 1200 2400 No Data Sprays for Groundboom application ( 60) Soil band treatment ( broccoli, brussels sprouts, cabbage, cauliflower) 30 80 630 630 800 1800 39 190 390 680 Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 40 Sprays for Groundboom application ( 61) Cotton 2 200 3800 3800 4800 11000 240 1200 2400 4100 Sprays for Groundboom application ( 62) Peanuts 11.59 80 1600 1600 2100 4500 100 500 1000 1800 Sprays for Groundboom application ( 63) Band treatment ( dried beans, succulent beans, lima) 2 80 9400 9400 12000 26000 590 2900 5900 10000 Sprays for Groundboom application ( 64) Band treatment, soil treatment ( garlic) 20 80 940 940 1200 2600 59 290 590 1000 Sprays for High Pressure HandWand application ( 65) commercial industrial lawn 0.15 1000 gals 78 220 390 No Data 5.9 29 59 No Data Sprays for Groundboom application ( 66) Cotton 2 200 3800 3800 4800 11000 240 1200 2400 4100 Sprays for Groundboom application ( 67) Garlic 20 80 940 940 1200 2600 59 290 590 1000 Sprays for Groundboom application ( 68) Peanuts 10 80 1900 1900 2400 5300 120 580 1200 2000 Sprays for Groundboom application ( 69) Potato 25 80 750 750 950 2100 47 230 470 810 Sprays for Aerial application ( 70) potato 25 350 No Data No Data No Data 480 No Data No Data No Data 120 Sprays for Groundboom application ( 71) Soil band treatment ( broccoli, Chinese broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 30 80 630 630 800 1800 39 190 390 680 Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 41 Sprays for High Pressure HandWand application ( 72) containerized stock ( broccoli, Chinese broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 0.02 1000 gals 780 2200 3900 No Data 59 290 590 No Data Sprays for Airblast application ( 73) Foliar spray ( magnolia tree) 6 20 490 730 800 9200 130 650 1300 1300 Sprays for Groundboom application ( 74) Tomato, pepper 7.50 80 2500 2500 3200 7000 160 780 1600 2700 Sprays for Groundboom application ( 75) Southern pine ( seed orchard) 42.50 10 3500 3500 4500 9900 220 1100 2200 3800 Applying Granulars for Tractor Drawn Spreaders application ( 76) Beans 1.50 80 18000 24000 42000 83000 490 2400 4900 2700 Applying Granulars for Tractor Drawn Spreaders application ( 77) Soil band treatment ( broccoli, brussels sprouts, cabbage, cauliflower, collards, kale, mustard) 30 80 880 1200 2100 4200 24 120 240 130 Applying Granulars for Tractor Drawn Spreaders application ( 78) Golf course turf ( tees/ greens) 43.56 10 4900 6700 11000 23000 130 670 1300 730 Applying Granulars for Tractor Drawn Spreaders application ( 79) Golf course turf ( fairways) 43.56 40 1200 1700 2900 5700 33 170 330 180 Applying Granulars for Tractor Drawn Spreaders application ( 80) Sod farms 43.56 80 610 840 1400 2900 17 84 170 91 Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 42 Applying Granulars for Tractor Drawn Spreaders application ( 81) Cotton 2 200 5300 7300 13000 25000 150 730 1500 800 Applying Granulars for Tractor Drawn Spreaders application ( 82) Peanuts 2 80 13000 18000 31000 63000 360 1800 3600 2000 Applying Granulars for Tractor Drawn Spreaders application ( 83) Pepper 1.35 80 20000 27000 46000 93000 540 2700 5400 2900 Applying Granulars for Tractor Drawn Spreaders application ( 84) Potato 25 80 1100 1500 2500 5000 29 150 290 160 Sprays for Groundboom application ( 85) Beans( lima, snap, dried) 1.50 80 13000 13000 16000 35000 790 3900 7900 14000 Sprays for Groundboom application ( 86) Soil band treatment ( broccoli, Chinese, broccoli, brussels sprouts, cabbage, Chinese cabbage, cauliflower, collards, kale, mustard) 30 80 630 630 800 1800 39 190 390 680 Sprays for High Pressure HandWand application ( 87) commercial/ in dustrial lawns 0.50 1000 gals 23 66 120 No Data 1.8 8.8 18 No Data Sprays for Groundboom application ( 88) Cotton 2 200 3800 3800 4800 11000 240 1200 2400 4100 Sprays for Groundboom application ( 89) Sod farms 40.80 80 460 460 580 1300 29 140 290 500 Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 43 Sprays for Groundboom application ( 89a) Sod farms 32.67 80 570 570 730 1600 36 180 360 620 Sprays for Groundboom application ( 90) Peanuts 2 80 9400 9400 12000 26000 590 2900 5900 10000 Sprays for Groundboom application ( 91) Pepper, tomato 7.50 80 2500 2500 3200 7000 160 780 1600 2700 Sprays for Groundboom application ( 92) Pine ( seed orchard) 37.50 10 4000 4000 5100 11000 250 1200 2500 4300 Flagger Flagging for Sprays application ( 93) Potato 25 350 220 240 240 11000 23 110 230 1100 Mixer/ Loader/ App Mixing/ Loadin g/ Applying Liquids for Handgun ( lawn) Sprayer ( ORETF) application ( 94) Ornamentals ( herbaceous plants, woody shrubs and vines) 218 5 No Data No Data 77 No Data 36 No Data No Data No Data Mixing/ Loadin g/ Applying Liquids for Handgun ( lawn) Sprayer ( ORETF) application ( 95) Ornamental andLawn turf 32.67 5 No Data No Data 510 No Data 240 No Data No Data No Data Loading/ Apply ing Granulars for Push type spreader ( ORETF) application ( 96) Commercial industrial lawns 43.56 5 280 440 880 No Data 44 No Data No Data No Data Loading/ Apply ing Granulars for Belly Grinder application ( 97) ornamental lawns and turf 43.56 0.5 96 100 No Data No Data 52 270 520 No Data Table 10; Summary of Short and Intermediate Term Occupational Risk for PCNB Exposure Scenario ( Scenario #) Crop App Rate4 lbai/ A or lb ai/ gal Daily Area Treated A or gals Dermal MOE Inhalation MOE9 Baseline PPE1 PPE2 PPE3 PPE4 PPE5 PPE6 Eng. C Baseline PPE1 PPE4 PPE2 PPE5 PPE3 PPE6 Eng. C 44 Loading/ Apply ing Granulars for Belly Grinder application ( 98) ornamentals ( shade trees, herbaceous, woody shrubs and vines) 217.80 0.5 19 21 No Data No Data 10 54 100 No Data Loading/ Apply ing Granulars for Push type spreader ( ORETF) application ( 99) Ornamentals ( shade trees, herbaceous, woody shrubs and vines) 217.80 0.5 550 880 1800 No Data 88 No Data No Data No Data Mixing/ Loadin g/ Applying Wet Powders for Low Pressure Handwand application ( 100) ornamental ( woody shrubs and vines, herbaceous plants) 217.80 5 2.2 2.2 3.1 No Data 0.058 0.29 0.58 No Data Mixing/ Loadin g/ Applying Wet Powders for Low Pressure Handwand application ( 101) ornamental ( shade trees) 37.50 5 13 13 18 No Data 0.34 1.7 3.4 No Data Baseline : Occupational handlers using open mixing techniques and open cab tractors are wearing long sleeved shirts, long pants, no gloves, and no respirator. PPE1: Occupational handlers using open mixing techniques and open cab tractors are wearing long sleeved shirts, long pants, chemical resistant gloves, and a no respirator. PPE2: Occupational handlers using open mixing techniques and open cab tractors are wearing long sleeved shirts, long pants, chemical resistant gloves, and a dust/ mist ( 5 fold PF) respirator. PPE3: Occupational handlers using open mixing techniques and open cab tractors are wearing long sleeved shirts, long pants, chemical resistant gloves, and an air purifying ( 10 fold PF) respirator. PPE4: Occupational handlers using open mixing techniques and open cab tractors are wearing coveralls over long sleeved shirts, long pants, chemical resistant gloves, and no respirator. PPE5: Occupational handlers using open mixing techniques and open cab tractors are wearing coveralls over long sleeved shirts, long pants, chemical resistant gloves, and a dust/ mist ( 5 fold PF) respirator. PPE6: Occupational handlers using open mixing techniques and open cab tractors are wearing coveralls over long sleeved shirts, long pants, chemical resistant gloves, and an air purifying ( 10 fold PF) respirator. Engineering Controls: Occupational handlers using closed mixing techniques and enclosed cab tractors or cockpits while wearing long sleeved shirts, long pants, chemical resistant gloves, and no respiratory protection. 45 3.2 Postapplication Exposure Chemical specific post application exposure data have not been submitted by the registrant in support of reregistration of PCNB. There is a low potential for occupational post application exposure when a pre plant or at planting fungicide is used. PCNB is applied to the soil directly and is soil incorporated well before the plants are mature. Further, the timing of the application greatly reduces the potential for post application exposure to treated foliage and/ or soil. Also, many agricultural operations mechanically plant seeds early in the season, which minimizes the potential for contact. Significant exposure during harvesting or any other late season activities, is not likely since the chemical is applied pre plant. Therefore, HED does not require a post application assessment for seed treatment or agricultural uses. However the Agency has determined that there are potential postapplication exposures to individuals re entering PCNB treated areas for the purpose of:

Roadsides: mowing; Bermuda grass rights of way: mowing; Sod farms: mowing and harvesting; Golf course turfgrass: mowing;

3.2.1 Submitted Studies Data Source and Assumptions for Scenario Considered MRID 446871 01. Dissipation of transferable turf residues ( TTR) of TURFCIDE ® 400 ( 40.2 percent PCNB) were quantified using the Modified California Roller technique for collecting residues. A cotton sheet and a plastic sheet are attached to a sampling frame, and placed on the turf test area, cotton side down; then a weighted, foam covered roller is rolled over the sheet five times, the sheet is collected and analyzed for residues. The study called for two turf applications of 12 oz product ( 0.75 lb a. i.) per 1000 ft2 to be made on different varieties of grass in California ( CA), Oregon ( OR), and Missouri ( MO) using ground application equipment. Two applications were made 3 weeks apart at all sites.

Field fortification recoveries averaged over 92% at CA, 92% at OR, and 78 % at MO sites. Most EPA Series 875 Study Guidelines were met by the studies. There was a wide range of variance in daily field data at each site, from as little as 5.94% to 29%, although most were less than 30%. There are no strict guidelines for acceptability of field variance, but high levels decrease confidence in the data.

The data were adjusted for field recoveries below the 90% guideline criterion. The data were then analyzed by HED, using semi log regression of the PCNB residues for each site separately. The predicted initial TTR for the CA site was 0.53 µ g/ cm2 ( R2 = 0.95) with a half life of 1.7 days. The predicted half life for the OR site was 2.0 days, with an initial residue of 0.22 µ g/ cm2 ( R2 = 0.78). The predicted half life for the MO site was 1.7 days, with an initial residue of 46 0.59 µ g/ cm2 ( R2 = 0.86). The analysis shows an initial deposition of about 0.13% of the active ingredient applied.

3.2.2 Exposure and Risk Calculations Short and intermediate term daily absorbed doses and MOEs were calculated as follows:

Daily Dose ( mg/ kg/ day) = TTR (  g/ cm2) x TC ( cm2/ hr) x conversion factor ( 1 mg/ 1,000  g) x exposure time ( 8hrs/ day) x dermal absorption ( 100 %) / body weight ( 70 kg; adult).

Where: TTR = Turf Transferable Residue at time ( t) where the longest duration ( t) is dictated by the kinetics observed in the TTR study Tc = transfer coefficient; CF = conversion factor ( i. e., 1 mg/ 1,000  g) Abs = dermal absorption ( 100%) ED = exposure duration; 8 hours worked per day BW = body weight ( 70 kg)

Dermal MOEs were calculated as follows: NOAEL ( 300 mg/ kg/ day; based on an dermal study) / dermal dose For golf course maintenance or sod harvesting, transfer coefficients of 3400 and 6800 cm2/ hr were used, based on the ARTF data ( see HED Exposure SAC Policy guidance 3.1, 8/ 00). The risk for these activities is presented in Table 11.

Table 11: Days After Treatment Target MOE Achieved ( Target MOE = 100)

Crop/ Use Pattern Application Rate ( lb ai/ acre) Postapplication Activity TTR ( sites)

g/ cm2 DAT 0a Transfer Coefficientb MOEc REI ( days)

Golf Course Turf 32.67 Mow, seed, mechanical weed, aerate, fertilize, prune 0.366 3400 2100 0 43.56 0.488 1580 0 Sod Farms 32.67 Mow, scout, mechanical weed, irrigate 0.366 6800 1120 0 43.56 0.488 790 0 a TTR source: MRID # 446871 01 turf transferable residue study. DAT 0 residue values were used for the short term assessments and DAT 7 residue values were used for the intermediate term assessments. The study was conducted in CA, OR, MO using an average application rate of 32.67lb ai/ acre for each sites. When assessing activities involving a different application rate than was used in the study, the TTR values were adjusted proportionately to reflect the different application rates. For example for an application rate of 43.56 lb ai/ acre : normalized ( adjusted) TTR = Turf study TTR x 43.56 lb ai/ A assessed rate / 32.67 lb ai/ A study rate. b Transfer coefficient from : Policy Memo # 003 .1 " Agricultural Transfer Coefficients," Revised  August 7, 2000. C MOE = NOAEL ( 300 mg/ kg/ day; based on a dermal study) / dermal dose Note: TTR = turf transferable residue DAT = days after treatment The short and intermediate term risks to golf course workers or sod growers doing hand harvesting on day zero does not exceed level of concern at the rate of 32.67 and 43.56 lb ai/ A. 47 4.0 Residential and Other Non Occupational Exposures and Risks There is a potential for exposure in residential settings during the application process for homeowners who use products containing PCNB. There is also a potential for exposure from entering areas treated with PCNB, such as entering treated lawn that could lead to exposures for adults and children. As a result, risk assessments have been completed for both residential handler and postapplication scenarios.

4.1 Residential Handler Exposures and Risks The Agency uses the term " handlers" to describe those individuals who are involved in the pesticide application process. Residential handlers are addressed somewhat differently by the Agency as homeowners are assumed to complete all elements of an application with little use of any protective equipment.

4.1.1 Residential Handler Exposure Scenarios, Data and Assumptions Much of the process for residential uses is identical to that considered for the occupational assessment with a few notable exceptions that include:

° Residential handler exposure scenarios are only considered to be short term in nature due to the episodic uses associated with homeowner products;

° Homeowner handler assessments are completed based on individuals wearing shorts and short sleeved shirts;

° Homeowner handlers are expected to complete all tasks associated with the use of a pesticide product including mixing/ loading if needed as well as the application;

° Label use rates and use information specific to residential products serve as the basis for the risk calculations as opposed to the rates used in the occupational assessment; and ° Area/ volumes of spray or chemical used in the risk assessment are based on HED guidance specific to residential use patterns.

Exposure to pesticide handlers is likely during the residential use of PCNB in a variety of environments including on turf. The anticipated use patterns and current labeling indicate several major residential exposure scenarios based on the types of equipment and techniques that can potentially be used to make PCNB applications. The quantitative exposure/ risk assessment developed for residential handlers is based on these scenarios.

1. Applying Granulars for Hand application 2. Mixing/ Loading/ Applying Liquids for Low Pressure Handwand application 48 3. Mixing/ Loading/ Applying Liquids for Backpack sprayer application 4. Mixing/ Loading/ Applying Liquids for Garden hose end sprayer( ORETF  RTU) application 5. Mixing/ Loading/ Applying Liquids for Garden hose end sprayer( ORETF  conventional) application 6. Loading/ Applying Granulars for Belly Grinder application 7. Loading/ Applying Granulars for Push type spreader ( ORETF) application 8. Loading/ Applying Granulars for Push type spreader ( ORETF) application Data and Assumptions For Handler Exposure Scenarios A series of assumptions and exposure factors served as the basis for completing the residential handler risk assessments. Each assumption and factor is detailed below. In addition to these factors, unit exposure values were used to calculate risk estimates. These unit exposure values were taken from the Pesticide Handlers Exposure Database ( PHED) or from Outdoor Residential Exposure Task Force ( ORETF) data.

The assumptions and factors used in the risk calculations include:

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

The Agency always considers the maximum application rates allowed by labels in its risk assessments to consider what is legally possible based on the label.

Residential risk assessments were not based on what could be applied in a typical workday like with the occupational risk assessments presented above. Instead, the HED based calculations on what would reasonably be treated by homeowners such as the size of a lawn, or the size of a garden. This information was used by the HED to define chemical use values for handlers which in turn were coupled with unit exposure values to calculate risks. The factors used for the PCNB assessment were those presented in the Health Effects Division Science Advisory Committee Policy 12: Recommended Revisions To The Standard Operating Procedures For Residential Exposure Assessment which was completed on February 22, 2001. The following daily volumes handled and area treated, excerpted from the policy and used in each residential scenario, include:

S Low pressure handwand 5 gals;

S Backpack sprayer application 0.5 and 5 gals;

S Garden hose end sprayer 0.5acre;

S Belly Grinder application 0.5 acre;

S Push type spreader 0.5 acre;

S Hand application 0.023 acre. 49 4.1.2 Residential Handler Exposure and Risk Estimates The residential handler exposure and risk calculations are presented in this section. Risks were calculated using the Margin of Exposure ( MOE). The major difference with residential risk assessments is that the uncertainty factor which defines the level of risk concern also has the additional FQPA safety factor applied. In the case of PCNB, the overall uncertainty factor applied to residential handler risk assessments is 1000.

In residential settings, the Agency does not use personal protective equipment to limit exposures, because they are viewed as impractical and not enforceable. Risk estimates are based on handlers wearing short sleeve shirts, short pants, shoes, and socks. Residential risks are of concern for a few scenarios, ( i. e., MOE < 1000) for non cancer risk assessments in non occupational settings. The scenarios where MOEs do not meet the Agency's target MOE uncertainty factor for non cancer risk assessments include dermal risk for mixing/ loading/ applying liquid with low pressure handwand and dermal and inhalation risk for garden hose end sprayer and belly grinder.

The residential handler scenarios that are not of concern ( i. e., MOE  1000) for shortand intermediate term dermal and inhalation risks are backpack sprayer application and push type spreader.

4.1.3 Summary of Risk for Residential Handlers The non cancer risk calculations for residential PCNB handlers are included in Appendix B ( Table B10) and summarized below in Table 12.

Table 12: Summary Short Term Residential handler Risk for PCNB Exposure Scenario ( Scenario #) Crop3 Application Rate Daily Area Treated/ day Dermal MOE7 Inhalation MOE Applicator Applying Granulars for Hand application ( 1) Turf 32.67 lb ai / A 0.023 A 65 200 Mixer/ Loader/ App Mixing/ Loading/ Applying Liquids for Low Pressure Handwand application ( 2) Turf 0.15 lb ai / gal 5 gal 280 3100 Mixing/ Loading/ Applying Liquids for Backpack sprayer application ( 3) 0.15 lb ai / gal 5 gal 5500 3100 Mixing/ Loading/ Applying Liquids for Garden hose end sprayer( ORETF application ( 4) 32.67 lb ai / A 0.5 A 490 390 Mixing/ Loading/ Applying Liquids for Garden hose end sprayer( ORETF  conventional) application ( 5) 32.67 lb ai / A 0.5 A 120 250 Loading/ Applying Granulars for Belly Grinder application ( 6) 32.67 lb ai / A 0.5 A 12 69 Table 12: Summary Short Term Residential handler Risk for PCNB Exposure Scenario ( Scenario #) Crop3 Application Rate Daily Area Treated/ day Dermal MOE7 Inhalation MOE 50 Loading/ Applying Granulars for Push type spreader ( ORETF) application ( 7) 32.67 lb ai / A 0.5 A 1900 4900 Loading/ Applying Granulars for Push type spreader ( ORETF) application ( 8) 43.56 lb ai / A 0.5 A 1400 3700 4.2 NON OCCUPATIONAL POST APPLICATION EXPOSURE AND RISK ESTIMATES 4.2.1 Post Application Exposure Scenarios, Data, and Assumptions Adults and children, are potentially exposed to residues after application of PCNB products in residential settings. After application to turf, short to intermediate term dermal exposures are anticipated for adults and children. Incidental oral exposure is also expected to occur for small children and is combined with their dermal exposures, where applicable ( i. e., playing on turf). The physical and behavioral differences between adults and children are continuously being studied by the Agency, and the current standard assumptions set forth by the HED and the Science Advisory Panel ( SAP) are contained in the Residential SOPs. The SOPs were updated in February, 2001.

HED always completes short and intermediate term risk assessments using maximum application rates for each scenario because what is possible under the label must be evaluated for complete stewardship in order to ensure HED has no concern for the specific use.

The scenarios likely to result in postapplication exposures are presented below. Because the label prohibits application more than 2 times per year, and even with the slow dissipation rates, it is not expected that individual residential exposure duration would exceed 30 days in duration. Exposure on a residential lawn would diminish continuously with time, while exposure through recreation turf contact would be more like random intermittent events of varying doses, all less than the dose predicted in this assessment. Residential postapplication exposure assessments assumed residents wear the following attire: short sleeved shirt, short pants, shoes and socks, and no gloves or respirator. As stated in the occupational postapplication risk section of this document, negligible PCNB inhalation exposure is anticipated for non handlers, due to low chemical vapor pressure and dilution of vapor outdoors. The scenarios likely to result in postapplication exposures are as follows:

° dermal postapplication risks to adults and toddlers when entering PCNB treated turf and lawns;

° oral postapplication risks to toddlers from " hand to mouth" ( i. e., ingestion of grass, soil, or hand to mouth contact) exposure when reentering lawns treated with granular liquid 51 and wettable powder formulations.

Representative turf reentry activities include, but are not limited to:

( 1) Adults involved in a low exposure activity, such as golfing or walking on treated turf. ( 2) Toddlers involved in a low exposure activity, such as walking on treated turf. ( 3) Adults mowing or other moderate contact activity, for 1 2 hours. ( 4) Adults involved in a high exposure activity, such as heavy yard work ( doses similar to occupational scenarios for cutting and harvesting sod). ( 5) Toddlers involved in high exposure activities on turf.

Although a Turf Transferable Residue ( TTR) study ( MRID# 44687101) was submitted in support of the reregistration of PCNB but, it was found to be not acceptable for this assessment. The TTR study was reviewed and found to have TTR transfer efficiencies of less than1% ( transfer efficiency = % of the application rate). TTR data generated by ORETF members rely on a modified version of the California roller ( ORETF roller) that appears to have a much lower transfer efficiency ( percent of application rate) than the original version. Many TTR data submitted by ORETF members show percent transferabilities of less than 1% of the application rate for sprayable formulations and less than 0.5% of the application rate for granular formulations. ORD has conducted a round robin test of TTR methods that included the ORETF roller ( Fortune 1997). While ORD concluded that the ORETF roller performed the best of all methods, transfer efficiency for three liquid herbicide formulations indicated a transfer efficiency of ~ 0.5%. The ORETF data was not used with the revised Transfer Coefficients referenced in current residential SOP since these revised TCs are based on TTR transfer efficiencies of ~ 1 5% ( transfer efficiency = % of the application rate). Therefore the TTR values from this study is not included in this assessment.

Dermal Exposure to Golf Course Turfgrass According to a 1992 report from The Center For Golf Course Management, 12.2 percent of the population are golfers ( i. e., 28.5 million people). Golfing is considered a lifetime sport so individuals of all ages, excluding very small children, routinely play. Children who are 12 years of age or older are likely to represent the vast majority of the youth that play golf on any sort of routine basis. However, the popularity of golf as a recreational pastime has increased steadily over the last few years which has resulted in more and more young children ( i. e., less than 12 years old for this discussion) becoming involved in the sport. Risk assessments for these age children are more difficult to complete because of the increased uncertainties associated with any extrapolations using adult dermal exposure data and because of the increased likelihood that other behaviors that might contribute to exposure such as mouthing contaminated hands or golf balls. 52 4.2.2 Post Application Exposure and Risk Estimates Dermal exposures are calculated using the standard transfer coefficient approach that is used for postapplication exposure assessments. ADD( t) ( mg/ kg/ day) = (( TTR( t) (  g/ cm2) x TC ( cm2/ hr) x ET( hr/ day) x ( 1 mg/ 1000  g) )/( BW ( kg))

Where: ADD = average daily dose ( mg/ kg/ day) at time ( t) attributable to golfing on previously treated turf ( mg/ kg/ day); TTR( t) = turf transferable residue at time ( t) (  g/ cm2); TC = transfer coefficient ( cm2/ hour); ET = exposure duration ( hours); and BW = body weight ( kg).

° Duration is 4 hours for a chemical that can be used on all parts of a course ( greens, tees, and fairways). This estimate of the average time it takes to play a round of golf which is based on the report completed by the Center For Golf Course Management [ 1992 Golf Course Operations: Cost of Doing Business/ Profitability. Library of Congress GV975. G56 1992].

° The dose levels calculated for adult golfers can be considered upper level estimates of exposure because of several reasons including the clothing scenario considered ( i. e., shorts and short sleeved shirts are not worn by all golfers), combining average values across several input parameters mathematically results in an upper percentile calculated product.

° Children of various ages down to the very young ( e. g., 4 or 5 years old) are currently playing golf, the agency recognize this but has not yet developed a quantitative approach for calculating their risk.

Dermal Exposure values on each day after application were calculated based on the following equation.

DE( t) ( mg/ day) = ( TTR( t) (  g/ cm2) x TC ( cm2/ hr) x Hr/ Day)/ 1000 (  g/ mg)

Where:

DE = Dermal exposure at time ( t) attributable for activity in a previously treated area ( mg/ day); TTR = Turf Transferable Residue at time ( t) where the longest duration ( t) is dictated by the kinetics observed in the TTR study; TC = Transfer Coefficient; and Hr = Exposure duration in hours.

The activities that were selected as the basis for the risk assessment are represented by the following transfer coefficients ( for short term and intermediate term endpoints): 53 ° Transfer Coefficient = 500 cm2/ hour for adults involved in a low exposure activity on turf such as golfing or light work activities; based on Policy Memo # 003 .1 " Agricultural Transfer Coefficients," Revised  August 7, 2000.. ° Transfer Coefficient = 14,500 cm2/ hour for adults involved in a high exposure activity on turf such as heavy yard work; Based on the revised residential SOP  February 2001 ° Transfer Coefficient = 5200 cm2/ hour for toddler involved in a high exposure activity on turf; Based on the revised residential SOP  February 2001 The dermal risk estimates for adults and children exposed to PCNB while doing activities on turf are shown in Tables 13.

Table 13 : Summary of Risk for Residential Postapplication Activities on Treated Turf with PCNB Activity Application Rate ( lb ai/ acre) TTR 5% of application ratea Transfer Coefficient ( cm2/ hr) b Dermal Dose ( mg/ kg/ day) c MOEd ( day 0)

high contact lawn activities: adults 32.67 7.09 14500 2.939 40 43.56 6.89 2.856 30 high contact lawn activities: toddler 32.67 18.3 5200 2.720 110 43.56 19.77 2.938 80 mowing turf: adults 32.67 18.3 500 0.262 1145 43.56 24.4 0.349 860 golf course reentry: adult 32.67 18.3 500 0.523 575 43.57 24.4 0.698 430 a TTR source: 5% of application rate, " Residential SOP Revised February 2001 " was used for determination of MOE's. b Transfer coefficient from the Residential SOP's ( 02/ 01). c Dermal dose = normalized TTR (

g/ cm2) x TC ( cm2/ hr) x conversion factor ( 1 mg/ 1,000

g) x exposure time ( 2 hrs/ day playing or mowing; 4 hrs golfing) / body weight ( 70 kg adult or 15 kg child 1 6 yrs). d MOE = NOAEL ( 300 mg/ kg/ day; based on a dermal study) / dermal dose Note: TTR = turf transferable residue DAT = days after treatment The oral non dietary risk estimates for small children from hand to mouth and ingestion exposure while playing on PCNB treated turf are contained in Table 14. Risk estimates were combined where applicable for PCNB ° Dose from hand to mouth activity calculated using Residential SOP 2.3.2: Postapplication potential dose among toddlers from incidental nondietary ingestion of pesticide residues on residential lawns from hand to mouth transfer. ° Dose from mouthing treated turf calculated using Residential SOP 2.3.3: Postapplication potential dose among toddlers from the ingestion of pesticide treated turfgrass; and ° Dose from incidental ingestion of soil calculated using Residential SOP 2.3.4: Postapplication potential dose among toddlers from the ingestion of soil in pesticide treated areas. 54 The results of the residential post application exposure and risk estimates are presented in Tables 13 and 14. The dermal risk estimates for adults and children exposed to PCNB while doing activities on turf are shown in Tables 13. The oral non dietary risk estimates for small children from hand to mouth and ingestion exposure while playing on PCNB treated turf are contained in Table 14. Risk estimates were combined where applicable for PCNB.

Once granules have broken down to PCNB soil residues, the exposure is considered using one of the following scenarios.

Hand to Mouth Transfer The following demonstrates the method used to calculate exposures that are attributable to a child touching treated turf and then putting their hands in their mouth ( SOP 2.3.2):

PDR = ( AR * F DR * CF * SA * EXT * Freq * Hr * ( 1 mg/ 1000

g)

where: PDR = potential dose rate ( mg/ day) AR = application rate ( lb ai/ A) F DR = fraction of residue dislodgeable from wet hands ( 5%) CF = conversion factor to convert lb ai/ A to

g/ cm2 ( 11.2) SA = surface area of 1 to 3 fingers ( 20 cm2); EXT = extraction rate by saliva ( 50%) Freq = frequency of hand to mouth events ( 20 events/ hour); and Hr = exposure duration ( 2 hours)

As indicated above, the dislodgeable foliar residue represents the amount of pesticide that can be removed from turf by the ( potentially wet) hands of a child, while the turf transferable residue represents the amount of chemical on the surfaces of treated leaves that can rub off on dry skin or clothing. These observations are based on empirical data, and therefore the Residential SOP standard 5% of the amount ai applied is used, rather than the data from the TTR study. The surface area for 1 3 fingers used ( 20 cm2) is the median surface area for a toddler ( age 3 years) as updated by the SAP in 12/ 99. The frequency of hand to mouth events is 20 events per hour as updated in 12/ 99. The 2 hour duration value is a recommended value from the U. S. EPA Exposure Factors Handbook. This model for hand to mouth dose is based on the premise that a child puts 2 3 fingers in their mouths, 50% of the residues on the hands are transferred from the hands to the mouth, and that all of the dislodgeable residues available on the treated turf transfer to the child's hand each time they exhibit this behavior.

The following illustrates the approach used to calculate exposures that are attributable to a child mouthing treated turf ( SOP 2.3.3): where: 55 PDR = ( AR * F DR * CF * IgR * ( 1 mg/ 1000

g)

where: PDR = potential dose rate ( mg/ day); AR = application rate F DR = fraction of residue dislodgeable from contaminated object ( 20%) CF = conversion factor to convert lb ai/ A to

g/ cm2 ( 11.2) IgR = ingestion rate for mouthing of grass per day ( 25 cm2/ day)

The ingestion rate used ( 25 cm2/ day) assumes that a child will grab a handful of turf or contaminated object, mouth it and remove all PCNB residues, and then remove it from their mouth. The surface area of ( 25 cm2/ day) is thought to approximate a handful of turf that is mouthed.

Incidental Soil Ingestion The following is the formula used to estimate exposure from incidental ingestion of soil treated with PCNB:

PDR = ( AP * ( 1 D) t * IgR * CF1 * CF2 * CF3 * CF4)

where: PDR = potential dose rate ( mg/ kg/ day) AP = application rate ( lb ai/ A) ( 1 D) = fraction or residue retained on uppermost 1 cm of soil, assumed to be 100 percent based on soil incorporation into top 1 cm of soil after application ( 1.0/ cm) t = postapplication day on which exposure is being assessed, assumed to be day zero IgR = ingestion rate of soil ( 100 mg/ day) CF1 = weight unit conversion factor to convert the lbs ai in the application rate to

g for the soil residue value ( 4.54 x 108

g/ lb) CF2 = area unit conversion factor to convert the surface area units ( ft2) in the application rate to cm2 for the SR value ( 2.47 x 10 8 acre/ cm2 if the application rate is per acre) CF3 = volume to weight unit conversion factor to convert the volume units ( cm3) to weight units for the SR value ( 0.67 cm3/ g soil) CF4 = weight unit conversion factor to convert the

g of residues on the soil to grams to provide units of mg/ day ( 1E 6 g/

g)

The estimated exposure from ingestion of soil from an area treated with pesticide is a minor contributor to the total incidental oral dose. Table 14: Residential Oral Non dietary Short term Postapplication Risks for PCNB Exposure Scenario Route of Exposure Population Application Ratea MOEb 56 Short term Postapplication Exposures Hand to Mouth Activity on Turf Oral Toddler 32.67 2 43.56 2 Object to Mouth Activity on Turf Oral Toddler 32.67 8 43.56 6 Incidental Soil Ingestion Oral Toddler 32.67 612 43.56 460 Intermediate term Postapplication Exposures Hand to Mouth Activity on Turf Oral Toddler 32.67 1 43.56 1 Object to Mouth Activity on Turf Oral Toddler 32.67 8 43.56 6 Incidental Soil Ingestion Oral Toddler 32.67 612 43.56 460 a Application rates represent a range of label rates of 32.67 43.56 lb ai/ acre for all liquid and granular products which may be applied to residential and recreational lawns either professionally or by a consumer. Incidental oral doses were calculated using formulas presented in the Residential SOPs ( updated 1999 2000). Short term doses were calculated using the following formulas: b MOE = NOAEL ( 1 mg/ kg/ day for both short and intermediate term assessments) / Oral Dose ( mg/ kg/ day). Aggregate MOEs = NOAEL / [ sum of incidental oral doses] with an target MOE of 1000. Hand to mouth oral dose to children on the day of treatment ( mg/ kg/ day) = [ application rate ( lb ai/ acre) x fraction of residue dislodgeable from potentially wet hands ( 5%) x 11.2 ( conversion factor to convert lb ai/ acre to

g/ cm2)] x median surface area for 1 3 fingers ( 20 cm2/ event) x hand to mouth rate ( 20 events/ hour) x exposure time ( 2 hr/ day) x 0.001 mg/ µ g] x 50% extraction by saliva / bw ( 15 kg child 1 6 yrs). This formula is based on proposed changes to the December 1999 Residential SOPs. Turf mouthing oral dose to child on the day of treatment ( mg/ kg/ day) = [ application rate ( lb ai/ acre) x fraction of residue dislodgeable from potentially wet hands ( 20%) x 11.2 ( conversion factor to convert lb ai/ acre to

g/ cm2) x ingestion rate of grass ( 25 cm2/ day) x .001 mg/ µ g] / bw ( 15 kg child 1 6 yrs). Soil ingestion oral dose to child on the day of treatment ( mg/ kg/ day) = [( application rate ( lb ai/ acre) x fraction of residue retained on uppermost 1 cm of soil ( 100% or 1.0/ cm) x 4.54e+ 08

g/ lb conversion factor x 2.47e 08 acre/ cm2 conversion factor x 0.67 cm3/ g soil conversion factor) x 100 mg/ day ingestion rate x 1.0e 06 g/

g conversion factor] / bw ( 15 kg; child 1 6 yrs). Short term dose based residue on the soil on day of application.

The following specific assumptions and factors were used in order to complete this exposure assessment:

 These assessments were based on the guidance provided in the Residential SOPs and updated in Revisions to the SOPs ( February 2001) based on the 1999 SAP comments. Several of the assumptions and factors used in the exposure assessment are described in that document.

 Calculations for short term risks are based on the maximum application rate for turf,

 Due to a lack of chemical specific exposure data, HED has calculated exposure values for adults using surrogate dermal transfer coefficients that represent activities such as mowing, golfing, and yard work.

For PCNB, a 70 kg median body weight for dermal exposures for all adults was used. The average body weight used in all assessments for 3 year old children is 15 kg based on the SOPs For Residential Exposure Assessment. For oral exposures for children, the oral NOAEL of 1 mg/ kg/ day for general population is used. 57 The NOAELs and the uncertainty factors that apply to all PCNB risk estimates are listed in Section 1.1 above. The non occupational target MOE is 1000 for PCNB. MOEs were calculated using the following formula:

Where: MOE = ADD/ NOAEL MOE= margin of exposure or ratio of chemical exposure to the endpoint of concern;

Absorbed Daily Dose ( ADD)= the absorbed dose received from exposure to a pesticide in a given scenario ( mg pesticide active ingredient/ kg body weight/ day); and NOAEL= the highest dose level in a toxicity study where no observed adverse effects occur ( mg pesticide active ingredient/ kg body weight/ day). 58 4.2.3 Summary of Postapplication Risks Short term PCNB risk estimates resulting from dermal contact with treated turf during high contact lawn activities at applications rate of 32.67 lbs ai/ A and 43.560 lbs ai/ A did exceed the level of concern for adults ( MOE 30 40) or for children ( MOE 82 110). Activities such as golfing and mowing lawns treated with PCNB at applications rate of 32.67 lbs ai/ A resulted in MOEs of 860 1145 and 575 430, respectively, and exceeds HED's level of concern.

The risk calculations for small children's non dietary ingestion of PCNB on treated turf indicate that risks exceed the level of concern for hand to mouth transfer ( MOE= 2). Incidental turfgrass mouthing ( MOEs 6 8) and incidental ingestion of soil ( 460 612).

Potential residential exposures are anticipated as a result of resident application and professional lawn care operator application. Risk estimates were performed for potential contact with lawn and soil treated with PCNB, using residential SOP.

The target non occupational MOE was 1000 for PCNB. The resulting surrogate residential postapplication assessment indicates that dermal contact after lawn is sprayed at typical application rates would result in PCNB MOEs of concern ( i. e., under the target of 1000). Aggregating, or adding residential handler exposure and postapplication exposure also results in MOEs below 1000. .