Page 1 of 177 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES June 21, 2006 MEMORANDUM SUBJECT: Arsenic: Final Occupational and Residential Exposure Assessment for the Reregistration Eligibility Decision Document for DMA, CAMA, MSMA, and DSMA.

FROM: Charles Smith, Environmental Scientist Reregistration Branch 2 Health Effects Division ( 7509P)

TO: Charles Smith, Risk Assessor/ Environmental Scientist Reregistration Branch 2 Health Effects Division ( 7509P)

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

DP Barcode: D329696 Pesticide Chemical Codes: DMA: 012501 CAMA: 013806 MSMA: 013803 DSMA: 013802 The attached review of the Human Health Assessment for the organic arsenic RED document was generated as part of Phase 4 of the public participation process. The Health Effects Division's ( HED) Final chapter reflects the comments received during the Phase 3 public comment period. This occupational and residential exposure assessment document includes the potential individual chemical contributions to human health risk of cacodylic acid and its salt, monosodium methanearsonate ( MSMA), disodium methanearsonate ( DSMA), and calcium acid methanearsonate ( CAMA).

This assessment relies in part on data from studies in which adult human subjects were intentionally exposed to a pesticide. These studies, listed below, have been determined to Page 2 of 177 require a review of their ethical conduct. The listed studies have either received the appropriate review or are in the process of being ethically reviewed.

Carbaryl Mixer/ Loader/ Applicator Exposure Study During Application of RP 2 Liquid ( 21%), Sevin Ready to Use Insect Spray or Sevin 10 Dust to Home Garden Vegetables. MRID 444598 01 D. Merricks. ( 1997).

Integrated Report for Evaluation of Potential Exposures to Homeowners and Professional Lawn Care Operators Mixing, Loading, and Applying Granular and Liquid Pesticides to Residential Lawns. MRID 449722 01. D. Klonne. ( 1999).

The PHED Task Force, 1995. The Pesticide Handler Exposure Database ( PHED), Version 1.1. Task Force members Health Canada, U. S. Environmental Protection Agency, and the National Agricultural Chemicals Association, released February 1995. Page 3 of 177 Preface The Food Quality Protection Act of 1996 requires that EPA's Office of Pesticide Programs review the safety of all existing pesticide tolerances ( the legal limit set on the maximum amount of pesticides that may remain in or on foods) by August 2006. As part of this reassessment process, the risk assessment on the organic arsenical pesticides is being updated. There are four registered organic arsenical pesticides: cacodylic acid ( dimethylarsinic acid, DMA) and its sodium salt ( sodium cacodylate); monosodium methanearsonate ( MSMA); disodium methanearsonate ( DSMA); and calcium acid methanearsonate ( CAMA). One other organic arsenical, arsanilic acid ( PC 129005), is not included in this assessment. Arsanilic acid is a plant growth regulator with a registration ( expiration 02/ 28/ 2001) for experimental use ( 180.550) in Florida on grapefruit. For ease of discussion the sodium salt of cacodylic acid and cacodylic acid are treated as one and will be referred to as dimethylarsonic acid ( DMA), and MSMA, DSMA, and CAMA will be referred to as monomethylarsonic acid ( MMA). Some of the reference materials also refer to MMA as methylarsonic acid ( MAA). In cases where chemical specific uses, risks, or other issues are being discussed, the specific pesticide name ( MSMA, DSMA, and CAMA) will be used. DMA and MMA can occur as two different valence states. Unless noted, DMA and MMA refer to the + 5 valence state ( e. g., DMAV, MMAV). Page 4 of 177 OCCUPATIONAL AND RESIDENTIAL EXPOSURE/ RISK ASSESSMENT AND CHARACTERIZATION Executive Summary Cacodylic acid or dimethylarsenic acid ( DMA) is a cotton defoliant and is also an herbicide used in agricultural, commercial, and residential settings for the postemergent control of annual grasses and broadleaf weeds. It is registered as a liquid concentrate, a pressurized liquid, and a ready to use solution; and is applied using: aircraft, groundboom sprayer, rights ofway sprayer, handgun sprayer, low pressure handwand sprayer, ready to use " trigger pump" sprayer, garden hose end sprayer, and sprinkling can.

Calcium acid methanearsonate ( CAMA) is an organic arsenical herbicide registered for postemergent weed control on lawns and turfgrass. CAMA is formulated as a liquid concentrate and a ready to use solution. CAMA is applied by commercial applicators using a low pressure handwand sprayer or handgun sprayer. It is applied by homeowner applicators using a low pressure handwand sprayer, hose end sprayer, and ready to use " trigger pump" sprayer.

Monosodium methanearsonate ( MSMA) is an organic arsenical herbicide registered for weed control on cotton, under trees, vines and shrubs, and for lawn care. MSMA technical is formulated as a liquid concentrate, and a ready to use liquid. MSMA is applied by aircraft, groundboom, rights of way sprayer, turf handgun sprayer, and low pressure handwand sprayer.

Disodium methanearsonate ( DSMA) is an organic arsenical herbicide registered for weed control on cotton, under trees, vines and shrubs, and for lawn care. DSMA is formulated as a liquid concentrate, and a wettable powder. DSMA is applied by aircraft, groundboom, rights ofway sprayer, turf handgun sprayer, and low pressure handwand sprayer.

The toxicity endpoints for methanearsonic acid ( MMA) were selected for assessing risks from exposures following applications of CAMA, MSMA, and DSMA. This was based on the knowledge that the calcium and sodium ions disassociate once the calcium salt and sodium salts are dissolved in water and CAMA, MSMA and DSMA become MMA as soon as dissolved in water. DMA has separate toxicity endpoints from MMA, except the inhalation endpoint selected for both DMA and MMA is the same. Since there was no inhalation endpoint available for MMA, the inhalation endpoint for DMA was used as a conservative surrogate.

HED has determined that there are potential exposures to mixers, loaders, applicators, and other handlers during the usual use patterns associated with DMA, CAMA, MSMA, and DSMA. Based on the use patterns, 10 occupational exposure scenarios were identified for DMA, four occupational exposure scenarios were identified for CAMA, 8 occupational exposure scenarios were identified for DSMA, and 8 occupational exposure scenarios were identified for MSMA. Calculations of non cancer risk based on dermal and inhalation exposure indicate that the dermal and inhalation MOEs are more than 100 with maximum risk reduction measures for all of the short and intermediate term occupational exposure scenarios listed above. Page 5 of 177 HED has determined that there are potential exposures to postapplication occupational workers during usual use patterns associated with DMA. For lawn applications using DMA, the calculated MOE ranges from 22 to 47 on day 0 ( 12 hours following application), and the target MOE is not reached until a week to two weeks after application ( depending on the postapplication activity). All other postapplication scenarios ( for CAMA, DSMA, MSMA, and DMA) have risks below HED's level of concern on day 0 ( 12 hours following application).

HED has determined that there are potential exposures to residential mixer, loader, and applicators during the usual use patterns associated with DMA, CAMA, MSMA and DSMA. Based on the use patterns, five residential exposure scenarios were identified for DMA, three residential exposure scenarios were identified for CAMA, three residential exposures were identified for DSMA, and three residential handler exposure scenarios were identified for MSMA. For residential handlers, all non cancer risks are not of concern.

The following residential postapplication scenarios were identified: dermal exposure from residue on lawns ( adult and toddler), hand to mouth transfer of residues on lawns ( toddler), ingestion of pesticide residue on treated grass ( toddler), and incidental ingestion of soil from pesticide treated residential areas ( toddler). There are a few risk concerns for DMA, CAMA, MSMA and DSMA as they are currently used in the residential environment. The target level of concern for DMA incidental oral scenarios is 30 ( i. e., MOEs   30 is not of concern to HED), since the endpoint is an BMDL10. Short term incidental oral MOEs for DMA for toddlers were < 30 for the hand to mouth activity and object to mouth activities on turf. The endpoint used to assess these incidental oral exposures ( BMDL10) comes from data measured at 10 weeks of DMA exposure in the feed to female rats ( Arnold et al, 1999). However, Cohen et al, ( 2001) shows that regenerative proliferation occurred as early as 1 week into the DMA exposure. HED believes that using the Arnold ( 1999) study ( with the Cohen 2001 study as characterization) in conjunction with Day 0 DMA residues ( calculated from the labeled application rates), constitutes the use of the best available data and that the results can be considered conservative for risk assessment purposes.

Calculated aggregated risks to toddlers ( i. e., hand to mouth activity, object to mouth activity on treated turf plus incidental soil ingestion of pesticide residue from treated turf areas) are of concern for applications of DMA at both assessed application rates and for CAMA at the highest assessed application rate of 4.4 lb ai/ acre. The target level of concern for DMA incidental oral scenarios is 30 ( i. e., MOE   30 is not of concern to HED), since the endpoint is a BMDL10. The aggregated risks from DMA treatment at both application rates are of concern, with MOEs of 3 for both use rates. The target level of concern for incidental ingestion scenarios for CAMA, DSMA, and MSMA is 100 ( i. e., MOE   100 is not of concern to HED.) A postapplication aggregated MOE of 85 was determined when assessing risks following treatment with CAMA at 4.4 lb ai/ acre. Application at the two lower use rates for CAMA resulted in MOEs which were above the level of concern. Aggregate MOEs calculated for DSMA and MSMA were above the target level of 100. Page 6 of 177 TABLE OF CONTENTS 1.0 OCCUPATIONAL AND RESIDENTIAL EXPOSURE/ RISK ASSESSMENT............................. 8 1.1 Purpose................................................................................................................................... 8 1.2 Criteria for Conducting Exposure Assessments ....................................................................... 8 1.3 Summary of Toxicity Concerns Relating to Occupational and Residential Exposures .............. 8 1.4 Incident Reports.................................................................................................................... 15 1.5 Summary of Physical and Chemical Properties of DMA, CAMA, MSMA, and DSMA ......... 17 1.6 Summary of Use Pattern and Formulations............................................................................ 25 1.6.1 Occupational Use and Homeowner Use Products.............................................................. 25 1.6.2 Type of Pesticide/ Targeted Pest ........................................................................................ 26 1.6.3 Formulation Types and Percent Active Ingredient ............................................................. 28 1.6.4 Registered Use Sites ......................................................................................................... 28 1.6.5 Application Rates ............................................................................................................. 30 1.6.6 Method and Types of Equipment Used for Mixing, Loading and Application ................. 32 1.6.7 Timing and Frequency of Application ............................................................................... 33 2.0 OCCUPATIONAL EXPOSURE AND RISKS............................................................................ 33 2.1 Occupational Handler Exposures and Risk Estimates ............................................................ 33 <IP_ADDRESS> Assumptions for Handler Exposure Scenarios ............................................................... 35 <IP_ADDRESS> Exposure Data for Handler Exposure Scenarios ............................................................ 35 2.1.2 Occupational Handler Exposure Scenarios ........................................................................ 38 2.1.3 Non cancer Occupational Handler Exposure and Assessment............................................ 40 <IP_ADDRESS> Non cancer Occupational Handler Exposure and Risk Calculations............................... 40 <IP_ADDRESS> Occupational Non cancer Risk Summary ( using PHED and ORETF data) .................... 41 2.1.4 Cancer Occupational Handler Exposure and Risk Assessment........................................... 63 2.1.5 Summary of Risk Concerns and Data Gaps for Occupational Handlers.............................. 63 <IP_ADDRESS> Summary of Risk Concerns .......................................................................................... 63 <IP_ADDRESS> Summary of Data Gaps................................................................................................. 65 2.1.6 Recommendations for Refining Occupational Handler Risk Assessment ........................... 65 2.2 Occupational Postapplication Exposures and Non Cancer Risk Estimates.............................. 65 2.2.1 Occupational Postapplication Exposure Scenarios ............................................................. 65 2.2.2 Data/ Assumptions for Postapplication Exposure Scenarios................................................ 68 2.2.3 Occupational Postapplication Exposure and Noncancer Risk Estimates ............................. 69 2.2.4 Noncancer Risk Summary................................................................................................. 69 2.2.5 Occupational Postapplication Exposure and Risk Estimates for Cancer ............................. 71 2.2.6 Summary of Occupational Postapplication Risk Concerns and Data Gaps ......................... 72 2.2.7 Recommendations for Refining Occupational Postapplication Risk Assessment ................ 72 3.0 RESIDENTIAL HANDLER EXPOSURES AND NON CANCER RISK ESTIMATES............. 72 3.1 Residential Handler Exposures and Risks .............................................................................. 72 3.1.1 Handler Exposure Scenarios ............................................................................................. 72 3.1.2 Data and Assumptions for Handler Exposure Scenarios..................................................... 74 3.1.3 Residential Handler Exposure and Non Cancer Risk Estimates ......................................... 77 3.1.4 Residential Handler Exposure and Risk Estimates for Cancer............................................ 80 3.1.5 Summary of Risk Concerns and Data Gaps for Handlers ................................................... 80 3.1.6 Recommendations for Refining Residential Handler Risk Assessment .............................. 81 3.2 Residential Postapplication Exposures and Assumptions ....................................................... 81 3.2.1 Residential Postapplication Exposure Scenarios ................................................................ 81 3.2.2 Data and Assumptions for Residential Postapplication Exposure Scenarios ....................... 83 3.2.3 Residential Postapplication Exposure and Noncancer Risk Estimates ............................... 86 3.2.4 Residential Postapplication Exposure Characterization...................................................... 93 3.2.5 Residential Postapplication Exposure to Inorganic Arsenic........................................... 94 Page 7 of 177 3.2.6 Residential Postapplication Exposure and Risk Estimates for Cancer................................. 96 3.2.7 Summary of Residential Postapplication Risk Concerns and Data Gaps............................. 97 3.2.8 Recommendations for Refining Residential Postapplication Risk Assessments.................. 97 Appendix A  DMA Occupational Handler Exposures and Risks ........................................................ 100 Appendix B   DMA Residential Handler Exposure and Risk Appendices ............................................ 111 Appendix C   DMA Residential Postapplication Exposure and Risk Appendices ................................. 114 Appendix D   CAMA Occupational Handler Exposures and Risks ...................................................... 121 Appendix E   CAMA Residential Handler Exposure and Risk Appendices .......................................... 127 Appendix F   CAMA Residential Postapplication Exposure and Risk Appendices ............................... 130 Appendix G   DSMA Occupational Handler Exposure and Risk Appendices ....................................... 137 Appendix H   DSMA Residential Handler Exposure and Risk Appendices .......................................... 145 Appendix I   DSMA Residential Postapplication Exposure and Risk Appendices ................................ 147 Appendix J   MSMA Occupational Handler Exposure and Risk Appendices ....................................... 153 Appendix K   MSMA Residential Handler Exposure and Risk Appendices ......................................... 165 Appendix L   MSMA Residential Postapplication Exposure and Risk Appendices............................... 167 Appendix M   Assumptions................................................................................................................. 173 Page 8 of 177 1.0 OCCUPATIONAL AND RESIDENTIAL EXPOSURE/ RISK ASSESSMENT 1.1 Purpose In this document, which is for use in EPA's development of the organic arsenicals Reregistration Eligibility Decision Document ( RED), EPA presents the results of its review of the potential human health effects of occupational and residential exposure to the arsenicals, including dimethylarsenic acid ( cacodylic acid or DMA)), calcium acid methanearsonate ( CAMA), monosodium methanearsonate ( MSMA) and disodium methanearsonate ( DSMA).

1.2 Criteria for Conducting Exposure Assessments An occupational and/ or residential exposure assessment is required for an active ingredient if ( 1) certain toxicological criteria are triggered and ( 2) there is potential exposure to handlers ( mixers, loaders, applicators, etc.) during use or to persons entering treated sites after application is complete. For the arsenicals, both criterion are met.

1.3 Summary of Toxicity Concerns Relating to Occupational and Residential Exposures Acute Toxicology DMA Table 1 presents the acute toxicity categories as outlined in the Cacodylic Acid   Reevaluation  Report of the Hazard Identification Assessment Review Committee ( USEPA, 1999a).

Table 1: DMA Acute Toxicity Categories Study Type Toxicity Category Acute Oral Toxicity III Acute Dermal Toxicity III Acute Inhalation Toxicity IV Primary Eye Irritation III Primary Dermal Irritation IV Dermal Sensitization not a sensitizer Page 9 of 177 CAMA Table 2 presents the acute toxicity categories as outlined in the Methanearsonic Acid and its Sodium and Calcium Salts  Report of the Hazard Identification Assessment Review Committee ( December 13, 2000). CAMA is classified as category IV for acute oral, acute dermal, acute inhalation, and primary skin irritation potential. For primary eye irritation potential, CAMA is classified as Category III. Results were negative for dermal sensitization.

Table 2: CAMA Acute Toxicity Categories Study Type Toxicity Category Acute Oral, rat IV Acute Dermal, rat IV Acute Inhalation, rat IV Primary Eye Irritation, rabbit III Primary Skin Irritation, rabbit IV Dermal Sensitization, rabbit none * Acute oral studies listed in table represent a formulation with 10.3% a. i.

MSMA Tables 3 presents the acute toxicity categories for MSMA as outlined in the MSMA and DSMA  Report of the Hazard Identification Assessment Review Committee ( HIARC). MSMA is classified as category II for acute oral, category III for acute dermal, and as category III for inhalation toxicity. It is classified as category III for eye irritation potential and for skin irritation potential. Results were negative for dermal sensitization.

Table 3: MSMA ( 37 38% a. i.) Acute Toxicity Categories Study Type Toxicity Category Acute Oral Toxicity II Acute Dermal Toxicity III Acute Inhalation Toxicity III Primary Eye Irritation III Primary Dermal Irritation III Dermal Sensitization not a sensitizer Page 10 of 177 DSMA Tables 4 presents the acute toxicity categories as outlined in the MSMA and DSMA  Report of the Hazard Identification Assessment Review Committee ( HIARC). DSMA is classified as category III for acute oral and dermal, and as category IV for inhalation toxicity. It is classified as category III for eye irritation potential and category IV for skin irritation potential. Results were negative for dermal sensitization.

Table 4: DSMA ( technical 81 83% ai) Acute Toxicity Categories Study Type Toxicity Category Acute Oral Toxicity III Acute Dermal Toxicity III Acute Inhalation Toxicity IV Primary Eye Irritation III Primary Dermal Irritation IV Dermal Sensitization not a sensitizer Non Cancer Endpoints of Concern DMA The endpoints, and associated uncertainty factors, used in assessing the risks for DMA acid are presented in Table 5. Page 11 of 177 Table 5: DMA Summary of Toxicological Doses and Endpoints for Use in Human Risk Assessments Exposure Scenario Dose Used in Risk Assessment, UF Special FQPA SF and Level of Concern for Risk Assessment Study and Toxicological Effects Acute Dietary ( females 13 49 and general population) NOAEL = 12 mg/ kg/ day UF = 100 Acute RfD = 0.12 mg/ kg/ day Developmental Toxicity  Rat ( 40625701) LOAEL = 36 mg/ kg/ day based on decreased fetal weights, shorter crownrump length, the suggestion of diaphragmatic hernia and delayed/ lack of ossification of numerous bones.

Developmental Toxicity  Rabbit ( 40663301) LOAEL = 48 mg/ kg/ day based on mortality, abortions, body weight loss and reduced food consumption.

Chronic Dietary ( all populations) BMDL10 = 0.43 mg/ kg/ day UF = 30 Chronic RfD = 0.014 mg/ kg/ day BMD10 of 0.92 mg/ kg/ day for BrdU labeling from Arnold et al ( 1999)

Incidental Oral Short Term ( 1  30 days)

Intermediate Term ( 1  6 months) BMDL10 = 0.43 mg/ kg/ day LOC = 30 BMD10 of 0.92 mg/ kg/ day for BrdU labeling from Arnold et al ( 1999)

Dermal Short Term ( 1  30 days)

Intermediate Term ( 1  6 months) Dermal NOAEL= 300 mg/ kg/ day LOC = 100 21 Day Dermal  Rabbit ( 41872801) LOAEL = 1000 mg/ kg/ day based on decreased body weight gain in females, and decreased testicular weights, hypospermia, and tubular hypoplasia in males.

Dermal Long Term (> 6 months) Not required Inhalation Short Term ( 1  30 days)

Intermediate Term ( 1  6 months) Inhalation NOAEL= 0.01 mg/ L ( 4.38 mg/ kg/ day, adjusted) LOC = 100 90 Day Inhalation  Rat ( 44700301) LOAEL = 0.034 mg/ kg/ L ( 14.95 mg/ kg/ day) based on presence of moderate and marked intracytoplasmic eosinophilic granules ( IEG) in the nasal turbinate cells of male and female rats.

Inhalation Long Term (> 6 months) Not required Cancer ( oral) Classification: not carcinogenic up to doses resulting in regenerative proliferation 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 Page 12 of 177 CAMA, DSMA, and MSMA CAMA, DSMA, and MSMA all breakdown to methanearsonic acid ( MMA) when mixed with water; therefore, the toxicological endpoints for MMA were used in the risk assessment for assessing handler and postapplication exposures. The endpoints, and associated uncertainty factors, used in assessing the risks for CAMA, MSMA, and DSMA are presented in Table 6.

Table 6: MMA Summary of Toxicological Doses and Endpoints for Use in Human Risk Assessments for CAMA, MSMA, and DSMA Exposure Scenario Dose Used in Risk Assessment, UF Level of Concern for Risk Assessment Study and Toxicological Effects Acute Dietary ( general population) NOAEL = 10 mg/ kg UF = 100 Acute RfD & PAD = 0.1 mg/ kg Chronic Toxicity in Dog, MMA study ( MRID No. 40546101) LOAEL = 40 mg/ kg/ day based on clinical signs of diarrhea and vomiting observed in the first of week of dosing with 2 5 hours of each days dosing.

Chronic Dietary ( all populations) NOAEL= 3.2 mg/ kg/ day UF = 100 Chronic RfD & PAD = 0.03 mg/ kg/ day Chronic Toxicity Rat, MMA study ( MRID No. 41669001) Rat LOAEL = 27.2 mg/ kg/ day for males and 32.9 mg/ kg/ day for females based on decreased body weights, diarrhea, body weight gains, food consumption, histopathology of gastrointestinal tract and thyroid.

Incidental Oral Short Term ( 1  30 days) NOAEL= 7 mg/ kg/ day LOC = 100 Rabbit developmental toxicity study ( MRID 15939001) LOAEL = 12 mg/ kg/ day, based on decreased body weight, food consumption ( during the dosing period), and abortions.

Incidental Oral Intermediate Term ( 1  6 months) NOAEL= 3.2 mg/ kg/ day LOC = 100 Chronic Rat study ( MRID 41669001)

LOAEL = 27.2 mg/ kg/ day for males and 32.9 mg/ kg/ day for females based on decreased body weights, diarrhea.

Dermal Short Term ( 1  30 days) Intermediate Term ( 1  6 months) Dermal NOAEL= 1000 mg/ kg/ day LOC = 100 21 Day Dermal Toxicity in Rabbit, MMA study ( MRID no. 41872701) LOAEL > 1000 mg/ kg/ day.

Dermal Long Term (> 6 months) Not applicable Inhalation Short Term ( 1  30 days)

Intermediate Term ( 1  6 months) Inhalation NOAEL= 0.01 mg/ L ( 4.38 mg/ kg/ day, adjusted) LOC = 100 90 Day Inhalation  Rat ( 44700301) LOAEL = 0.034 mg/ kg/ L ( 14.95 mg/ kg/ day) based on presence of moderate and marked intracytoplasmic eosinophilic granules ( IEG) in the nasal turbinate cells of male and female rats.

Cancer Classification: " not likely 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 Page 13 of 177 FQPA Safety Factor DMA Acceptable developmental studies in rats and rabbits along with a two generation reproductive toxicity study are available for DMA. Developmental toxicity was noted only at doses resulting in maternal toxicity; NOAELs were established for maternal and developmental toxicity. As such, results of developmental and reproductive toxicities studies provided no indication of increased susceptibility of rat or rabbit. Changes in organ weights for reproductive organs ( e. g., ovarian weight changes without pathological changes in the reproductive toxicity study) and testicular pathology ( dermal study only) were noted only at very high doses and were not replicated in other studies. The toxicology database is considered complete for the evaluation of sensitivity of the developing young. As the developing nervous system does not appear to be a target organ for DMA, a developmental neurotoxicity study is not required. Regarding potential thyroid toxicity, a comparative thyroid study in adult and juvenile animals is not expected to provide endpoints more sensitive than the bladder mode of action studies currently available. The bladder is a sensitive target organ and special mode of action studies provide health protective endpoints for DMA toxicity at low doses. Thus, a comparative thyroid study in juvenile and adult animals is not required. Based on the overall weight of the evidence, a hazard based FQPA factor is not needed for DMA.

MMA ( CAMA, DSMA, MSMA )

Acceptable developmental studies in rats and rabbits along with a two generation reproductive toxicity study are available for MMA. Results of developmental and reproductive toxicity studies provided no indication of increased susceptibility of rat or rabbit. The toxicology database is considered complete for the evaluation of sensitivity of the developing young. A developmental neurotoxicity study is not required. As described below, toxicity to gastrointestinal tract and kidney provide the critical effects for MMA following oral exposures. These effects are more sensitive than toxicities noted in other studies, including developmental and reproductive toxicity. Therefore, a hazard based FQPA factor is not needed for MMA.

Dermal Route ( non cancer)

DMA: For liquid formulations, the short and intermediate term ( non cancer) dermal risk assessment for DMA is based on a NOAEL of 300 mg/ kg/ day from a 21 day dermal toxicity study in rabbits. Long term exposures to DMA ( i. e., greater than 6 months) are not expected for current registered uses.

CAMA, DSMA, and MSMA: The short and intermediate term ( non cancer) dermal risk assessment for CAMA, DSMA, and MSMA is based on endpoints for MMA since all three chemicals convert to MMA in water. For MMA, the dermal endpoint is based on a NOAEL of 1000 mg/ kg/ day from a 21 day dermal toxicity study in rabbits. No systemic toxicity or dermal irritation were observed at the limit dose of 1000 mg/ kg/ day. Long term exposures to CAMA, DMSA, and MSMA ( i. e., greater than 6 months) are not expected for current registered uses. Page 14 of 177 Inhalation Route ( non cancer)

DMA: For liquid formulations, the short and intermediate term ( non cancer) inhalation risk assessment for DMA is based on a NOAEL of 0.01 mg/ L ( 4.38 mg/ kg/ day), which was defined in a 90 day inhalation study in rats. The NOAEL was based on the presence of moderate and marked intracytoplasmic eosinophilic granules ( IEG) in the cells of the nasal turbinates. Long term exposures to DMA ( i. e., greater than 6 months) are not expected for current registered uses.

CAMA, DSMA, and MSMA: The short and intermediate term ( non cancer) inhalation risk assessment for CAMA, DSMA, and MSMA is based on endpoints for DMA since no inhalation endpoint is available for MMA. For DMA, the inhalation endpoint is based on a NOAEL of 0.01 mg/ L ( 4.38 mg/ kg/ day), which was defined in a 90 day inhalation study in rats. The NOAEL was based on the presence of moderate and marked intracytoplasmic eosinophilic granules ( IEG) in the cells of the nasal turbinates. Long term exposures to CAMA, DSMA, and MSMA ( i. e., greater than 6 months) are not expected for current registered uses.

Oral Route ( non cancer)

DMA: For liquid formulations, the short and intermediate term ( non cancer) incidental oral risk assessment for DMA is based on a BMDL10 of 0.43 mg/ kg/ day, which was defined in an open literature study ( Arnold et al, 1999). Long term exposures to DMA ( i. e., greater than 6 months) are not expected for current registered uses.

CAMA, DMSA, and MSMA: The short term ( non cancer) incidental oral risk assessment for CAMA, DSMA, and MSMA is based on endpoints for MMA since all three chemicals convert to MMA in water. For MMA, the incidental oral endpoint is based on a NOAEL of 7.0 mg/ kg/ day, which was defined in a rabbit developmental toxicity study. Long term exposures to CAMA, DSMA, and MSMA ( i. e., greater than 6 months) are not expected for current registered uses.

Non cancer Level of Concern ( LOC)

HED's level of concern ( LOC) for DMA, CAMA, MSMA, and DSMA occupational and residential dermal and inhalation exposures is 100 ( i. e., a margin of exposure ( MOE) less than 100 exceeds HED's level of concern). The level of concern is based on 10X to account for interspecies extrapolation to humans from the animal test species and 10X to account for intraspecies sensitivity. For incidental oral exposures, HED's LOC for MMA is 100, but for DMA is 30, due to the use of a BMDL10.

Body Weight Since the adverse effects for the dermal and inhalation endpoints are based on studies where the effects were observed in both males and females, the body weight of an average adult male ( i. e., 70 kg) was used to estimate dermal and inhalation exposure. Page 15 of 177 Aggregation The dermal and inhalation margins of exposure were not combined for the toddler postapplication residential MMA and DMA risk assessments because the toxicity endpoints for the dermal and inhalation routes of exposure are based on different toxicological effects. The postapplication assessments involving incidental oral ingestion by toddlers ( hand to mouth, object to mouth, and soil ingestion) are aggregated for MMA and DMA. Dermal postapplication exposure was not aggregated with the incidental oral scenarios since the endpoints have different toxicological effects.

Cancer Determination DMA As described in the special issue paper for DMA, the mode of action for the development of bladder tumors in rats has been established and supports a nonlinear doseresponse assessment. This mode of action is expected to be functional in humans. A key step in this mode of action is that sufficient DMAIII is available at the target site to cause cell killing. This cytotoxicity must be sustained to result in regenerative proliferation. Each of these key steps is necessary for the development of bladder tumors. As regenerative proliferation is expected to be the rate limiting step in the development of the DMA induced bladder tumors, DMA is considered not carcinogenic up to doses resulting in regenerative proliferation.

CAMA, MSMA, and DSMA The Hazard Identification Assessment Review Committee ( HIARC) classified CAMA, DSMA, and MSMA as " not likely" a human carcinogen. 1 Although the parathyroid adenomas described above in rats were outside of the historical controls ( 0.1% for both sexes), the tumors are not a concern because of the following rationale: 1) Only the benign tumors were increased in incidence. 2) Pair wise significance was not attained for either sex. A significant trend test was observed only for males. 3) An increase in tumor incidence was not observed in mice. 4) The acceptable genetic toxicology studies indicate that MMA is not mutagenic in bacteria ( Salmonella typhimurium ) or cultured mammalian cells ( Chinese hamster ovary). Similarly, MMA did not induce unscheduled DNA synthesis ( UDS) in primary rat hepatocytes.

1.4 Incident Reports OPP draws from 4 different databases to determine what, if any, poisoning incidents have occurred that can be related to pesticidal use. A summary of the databases follows.

1) Office of Pesticide Program's Incident Data System ( IDS)  includes reports of incidents from various sources, including required Federal Insecticide Fungicide and Rodenticide Act ( FIFRA) Section 6 ( a) ( 2) registrants, other federal and state health and environmental agencies and Page 16 of 177 individual consumers, submitted to the Agency since 1992. Reports submitted to the IDS represent anecdotal reports or allegations only, unless otherwise stated. Typically no conclusions can be drawn implicating the pesticide as a cause of any of the reported health effects. Nevertheless, sometimes with enough cases and/ or enough documentation risk mitigation measures may be suggested.

2) American Association of Poison Control Centers ( AAPCC)  as the result of Data Call Ins issued in 1993, the Agency received Poison Control Center data covering the years 1985 through 1992 for 28 organophosphate and carbamate chemicals. Most of the national Poison Control Centers ( PCCs) participate in a national data collection system, the Toxic Exposure Surveillance System which obtains data from about 70 centers at hospitals and universities. PCCs provide telephone consultation for individuals and health care providers on suspected poisonings involving drugs, household products, pesticides, etc.

3) California Pesticide Illness Surveillance Program  California has collected uniform data on suspected pesticide poisonings since 1982. Physicians are required, by statute, to report to their local health officer all occurrences of illness suspected of being related to exposure to pesticides. The majority of the incidents involve workers. Information on exposure ( worker activity), type of illness ( systemic, eye, skin, eye/ skin and respiratory), likelihood of a causal relationship, and number of days off work and in the hospital is provided.

4) National Pesticide Telecommunications Network ( NPTN)  NPTN is a toll free information service supported by the Agency's Office of Pesticide Programs. A ranking of the top 200 active ingredients for which telephone calls were received during calendar years 1984 1991, inclusive has been prepared. The total number of calls was tabulated for the categories; human incidents, animal incidents, calls for information, and others.

DMA Incidents For the purposes of this assessment the focus was on those human incidents that are directly, or probably, related to exposures to DMA or sodium cacodylate per se. Drawing from four data sources, there were reported poisoning incidents involving children < 6 years of age, but none were hospitalized, and no specifics were given about the activity associated with the exposures. Incidents reported for adults involved both agricultural and non agricultural uses, and resulted in days off from work and, in a few cases, hospitalization. The symptoms ranged from systemic, to skin and eye irritation, to respiratory system effects. Some cases involved multiple symptoms. The uses included lawn, turf, ornamentals, weeds, and cotton. For more details see Allen 2000a.

CAMA Incidents HED searched the same four databases for evidence of poisoning incidents connected with the use of CAMA and found none. Currently, CAMA has no agricultural uses. See Allen 2001. Page 17 of 177 MSMA and DSMA Incidents HED searched the four databases discussed above for reports of incidents occurring resulting from exposures to MSMA or DSMA. There were incidents reported for both MSMA and DSMA, involving both adults and children. Most were treated on an outpatient basis but a few required hospitalization. Some reports described symptoms such as dizziness, sinusitis, rhinitis, memory loss, numbness, tingling, rash, and fever, after aerial applications, but many were nonspecific about the source of exposure. Other reports described effects such as systemic allergic symptoms, nausea, dizziness, and eye irritation for both agricultural and non agricultural uses. Specific details may be found in Allen 2000b.

There are only scattered reports for MSMA and DSMA among the four data systems used by the Agency's epidemiology group to evaluate human poisoning incidents. The sparsity of data could be due to low usage, and/ or poor reporting to surveillance programs.

1.5 Summary of Physical and Chemical Properties of DMA, CAMA, MSMA, and DSMA Table 7: Product Chemistry Data Summary for Cacodylic Acid OPPTS Guideline Numbers Data Requirements: Cacodylic Acid [ TGAI] PC 012501 CAS# 75 60 5 Master Record Identification [ MRID] or Reference Are Data Requirements Fulfilled? Results or * Data Gap 830.1550 Product Identity and Composition NO * DATA GAP 830.1600 Description of Materials Used to Produce the Product NO * DATA GAP 830.1620 Description of Production Process NO * DATA GAP 830.1650 Description of Formulation Process NO * DATA GAP 830.1670 Discussion of Formation of Impurities NO * DATA GAP 830.1700 Preliminary Analysis 41608302, 42614501 YES 830.1750 Certified Limits NO * DATA GAP 830.1800 Enforcement Analytical Method NO * DATA GAP 830.1900 Submittal of Samples NO * DATA GAP 830.6302 Color 40957813, 42473801 YES WHITE 830.6303 Physical State 40957813, 42473801 YES CRYSTALLINE SOLID 830.6304 Odor 40957813, 42473801 YES NO ODOR 830.6313 Stability to normal and elevated temperatures, metals and metal ions NO * DATA GAP 830.7000 pH 40957813, 42473801 YES 830.7050 UV/ VIS absorption NO * DATA GAP 830.7200 Melting Point/ Melting Range 42397101 YES 192 º C   194 º C 830.7220 Boiling Point/ Boiling Point Range NOT APPLICABLE SEE GUIDELINE 830.7220 830.7300 Density/ Relative Density/ Bulk Density 40957813, 42473801 YES 1.10 g / mL 830.7370 Dissociation Constant 42403501 YES 6.17 AT 25 º C 830.7550 Partition coefficient ( n octanol / water) shake flask method 42397101 YES K O/ W = < 0.028 AT 25 º C 830.7560 Partition coefficient ( n octanol / water) generator column method SEE GUIDELINE 830.7550 830.7570 Partition coefficient ( n octanol / water) estimation by liquid chromatography SEE GUIDELINE 830.7550 830.7840 Water Solubility: Column Elution Method; Shake Flask Method 42397101 YES 102 g / 100mL 830.7860 Water solubility generator column method SEE GUIDELINE 830.7840 830.7950 Vapor pressure NO * DATA GAP Page 18 of 177 Table 8: Product Chemistry Data Summary for Sodium Cacodylate OPPTS Guideline Numbers Data Requirements Sodium Cacodylate [ TGAI] PC 012502 CAS# 124 65 2 Master Record Identification [ MRID] or Reference Are Data Requirements Fulfilled? Results or * Data Gap 830.1550 Product Identity and Composition NO * DATA GAP 830.1600 Description of Materials Used to Produce the Product NO * DATA GAP 830.1620 Description of Production Process NO * DATA GAP 830.1650 Description of Formulation Process NO * DATA GAP 830.1670 Discussion of Formation of Impurities NO * DATA GAP 830.1700 Preliminary Analysis 41608302, 42614501 YES 830.1750 Certified Limits NO * DATA GAP 830.1800 Enforcement Analytical Method NO * DATA GAP 830.1900 Submittal of Samples NO * DATA GAP 830.6302 Color 40957813, 42473801 YES WHITE 830.6303 Physical State 40957813, 42473801 YES CRYSTALLINE SOLID 830.6304 Odor 40957813, 42473801 YES NO ODOR 830.6313 Stability to normal and elevated temperatures, metals and metal ions 42403501 YES STABLE 830.7000 pH 42473801 YES 830.7050 UV/ VIS absorption NO * DATA GAP 830.7200 Melting Point/ Melting Range 42403501 YES 77 oC   79.5 oC 830.7220 Boiling Point/ Boiling Point Range NOT APPLICABLE 830.7300 Density/ Relative Density/ Bulk Density 40957813, 42473801 YES 1.10 g / mL 830.7370 Dissociation Constant 42403501 YES 6.21 at 25 oC 830.7550 Partition coefficient ( n octanol / water) shake flask method NOT APPLICABLE CRBS 8865, D170691 12/ 12/ 1991 A. Perfetti 830.7560 Partition coefficient ( n octanol / water) generator column method 830.7570 Partition coefficient ( n octanol / water) estimation by liquid chromatography SEE GUIDELINE 830.7550 830.7840 Water Solubility: Column Elution Method; Shake Flask Method 42397101 YES 82 g / 100 mL 830.7860 Water solubility generator column method SEE GUIDELINE 830.7840 830.7950 Vapor pressure NO * DATA GAP Page 19 of 177 Table 9: Product Chemistry Data Summary for DiSodium Methanearsonic Salt OPPTS Guideline Numbers Luxembourg Pamol, Inc. Data Requirements: DSMA [ TGAI] PC 013802 CAS# 144 21 8 Master Record Identification [ MRID] Are Data Requirements Fulfilled? Results or * Deficiency 830.1550 Product Identity and Composition NO * Data Gap 830.1600 Description of Materials Used to Produce the Product 42388301, 44150401 YES 830.1620 Description of Production Process 42388301, 44150401 YES 830.1650 Description of Formulation Process NO * Data Gap 830.1670 Discussion of Formation of Impurities NO * Data Gap 830.1700 Preliminary Analysis 42053701, 45053702 YES 830.1750 Certified Limits NO * Data Gap 830.1800 Enforcement Analytical Method NO * Data Gap 830.1900 Submittal of Samples NO * Data Gap 830.6302 Color 42451102 YES WHITE 830.6303 Physical State 42451102 YES CRYSTALINE SOLID 830.6304 Odor 42451102 YES No Odor 830.6313 Stability to normal and elevated temperatures, metals and metal ions NO * Data Gap 830.7000 pH 41982002 YES 830.7050 UV/ VIS absorption NO * Data Gap 830.7200 Melting Point/ Melting Range 41982001 YES > 300 º C 830.7220 Boiling Point/ Boiling Point Range NOT APPLICABLE 830.7300 Density/ Relative Density/ Bulk Density 42451102 YES 830.7370 Dissociation Constant 41976201 YES 830.7550 Partition coefficient ( n octanol / water) shake flask method 41976202 YES Log P O/ W < 1 830.7560 Partition coefficient ( n octanol / water) generator column method SEE GUIDELINE 830.7550 830.7570 Partition coefficient ( n octanol / water) estimation by liquid chromatography SEE GUIDELINE 830.7550 830.7840 Water Solubility: Column Elution Method; Shake Flask Method 41602502 YES 830.7860 Water solubility, generator column method SEE GUIDELINE 830.7840 830.7950 Vapor pressure 42120701 YES 0.0000001 mm Hg at 25 ° C Page 20 of 177 Table 10: Product Chemistry Data Summary for DiSodium Methanearsonic Salt OPPTS Guideline Numbers APC Holdings Data Requirements: DSMA [ TGAI] PC 013802 CAS# 144 21 8 Master Record Identification [ MRID] Are Data Requirements Fulfilled? Results or * Deficiency 830.1550 Product Identity and Composition NO * DATA GAP 830.1600 Description of Materials Used to Produce the Product 42361001 YES 830.1620 Description of Production Process 42361001 YES 830.1650 Description of Formulation Process NO * DATA GAP 830.1670 Discussion of Formation of Impurities 42053701 YES 830.1700 Preliminary Analysis 42053702 YES 830.1750 Certified Limits NO * DATA GAP 830.1800 Enforcement Analytical Method NO * DATA GAP 830.1900 Submittal of Samples NO * DATA GAP 830.6302 Color 42451102 YES 830.6303 Physical State 42451102 YES 830.6304 Odor 42451102 YES NO ODOR 830.6313 Stability to normal and elevated temperatures, metals and metal ions NO * DATA GAP 830.7000 pH 41982002 YES 830.7050 UV/ VIS absorption NO * DATA GAP 830.7200 Melting Point/ Melting Range 41982001 YES 830.7220 Boiling Point/ Boiling Point Range SEE GUIDELINE 830.7200 830.7300 Density/ Relative Density/ Bulk Density 42451102 YES 830.7370 Dissociation Constant 41976201 YES 830.7550 Partition coefficient ( n octanol / water) shake flask method 41976202 YES 830.7560 Partition coefficient ( n octanol / water) generator column method 830.7570 Partition coefficient ( n octanol / water) estimation by liquid chromatography SEE GUIDELINE 830.7550 830.7840 Water Solubility: Column Elution Method; Shake Flask Method 41602502 YES 830.7860 Water solubility, generator column method SEE GUIDELINE 830.7840 830.7950 Vapor pressure 42120701 YES Page 21 of 177 Table 11: Product Chemistry Data Summary for DiSodium Methanearsonic Salt OPPTS Guideline Numbers GB Biosciences Corporation Data Requirements: 81% DSMA FI [ Technical] PC 013802 CAS# 144 21 8 Master Record Identification [ MRID] Are Data Requirements Fulfilled? Results or * Deficiency 830.1550 Product Identity and Composition 42051902 YES CSF 09/ 23/ 1991 830.1600 Description of Materials Used to Produce the Product NO * DATA GAP 830.1620 Description of Production Process NO * DATA GAP 830.1650 Description of Formulation Process NO * DATA GAP 830.1670 Discussion of Formation of Impurities NO * DATA GAP 830.1700 Preliminary Analysis NO * DATA GAP 830.1750 Certified Limits 42051902, CSF 09/ 23/ 1991 YES 830.1800 Enforcement Analytical Method NO * DATA GAP 830.1900 Submittal of Samples NO * DATA GAP 830.6302 Color NO * DATA GAP 830.6303 Physical State NO * DATA GAP 830.6304 Odor NO * DATA GAP 830.6313 Stability to normal and elevated temperatures, metals and metal ions NO * DATA GAP 830.7000 pH NO * DATA GAP 830.7050 UV/ VIS absorption NO * DATA GAP 830.7200 Melting Point/ Melting Range NO * DATA GAP 830.7220 Boiling Point/ Boiling Point Range NO * DATA GAP 830.7300 Density/ Relative Density/ Bulk Density NO * DATA GAP 830.7370 Dissociation Constant NO * DATA GAP 830.7550 Partition coefficient ( n octanol / water) shake flask method NO * DATA GAP 830.7560 Partition coefficient ( n octanol / water) generator column method NO * DATA GAP 830.7570 Partition coefficient ( n octanol / water) estimation by liquid chromatography NO * DATA GAP 830.7840 Water Solubility: Column Elution Method; Shake Flask Method NO * DATA GAP 830.7860 Water solubility, generator column method NO * DATA GAP 830.7950 Vapor pressure NO * DATA GAP Page 22 of 177 Table 12: Product Chemistry Data Summary for MonoSodium Methanearsonic Salt OPPTS Guideline Numbers Luxembourg Pamol, Inc Data Requirements: MSMA [ TGAI] PC 013803 CAS# 2163 80 6 Master Record Identification [ MRID] Are Data Requirements Fulfilled? Results or * Deficiency 830.1550 Product Identity and Composition NO * DATA GAP 830.1600 Description of Materials Used to Produce the Product NO * DATA GAP 830.1620 Description of Production Process 41602701, 42387801 YES 830.1650 Description of Formulation Process NO * DATA GAP 830.1670 Discussion of Formation of Impurities 41602701, 42387801 YES 830.1700 Preliminary Analysis 42387802 YES 830.1750 Certified Limits NO * DATA GAP 830.1800 Enforcement Analytical Method NO * DATA GAP 830.1900 Submittal of Samples NO * DATA GAP 830.6302 Color 41610001, 42451101 YES WHITE 830.6303 Physical State 41610001, 42451101 YES CRYSTALLINE 830.6304 Odor 41610001, 42451101 YES NO ODOR 830.6313 Stability to normal and elevated temperatures, metals and metal ions 41610001, 42378601 YES 830.7000 pH 41610001, 42378601 YES 830.7050 UV/ VIS absorption NO * DATA GAP 830.7200 Melting Point/ Melting Range 41789501 YES 830.7220 Boiling Point/ Boiling Point Range NOT APPLICABLE 830.7300 Density/ Relative Density/ Bulk Density 42451101 YES 1.65 g/ mL at 25 º C 830.7370 Dissociation Constant 41610001 YES 830.7550 Partition coefficient ( n octanol / water) shake flask method 830.7560 Partition coefficient ( n octanol / water) generator column method 830.7570 Partition coefficient ( n octanol / water) estimation by liquid chromatography NO * DATA GAP 830.7840 Water Solubility: Column Elution Method; Shake Flask Method 41610001 YES 830.7860 Water solubility, generator column method SEE GUIDELINE 830.7840 830.7950 Vapor pressure 41610001, 41651901 YES 0.00001 Pa Page 23 of 177 Table 13: Product Chemistry Data Summary for MonoSodium Methanearsonic Salt OPPTS Guideline Numbers APC Holdings, Inc. Data Requirements: MSMA [ TGAI] PC 013803 CAS# 2163 80 6 Master Record Identification [ MRID] Are Data Requirements Fulfilled? Results or * Deficiency 830.1550 Product Identity and Composition NO * DATA GAP 830.1600 Description of Materials Used to Produce the Product 41702001 YES 830.1620 Description of Production Process 41702001 YES 830.1650 Description of Formulation Process NO * DATA GAP 830.1670 Discussion of Formation of Impurities 42474101 YES 830.1700 Preliminary Analysis 41702002, 42474101 YES 830.1750 Certified Limits NO * DATA GAP 830.1800 Enforcement Analytical Method NO * DATA GAP 830.1900 Submittal of Samples NO * DATA GAP 830.6302 Color 41610001 YES 830.6303 Physical State 41610001 YES 830.6304 Odor 41610001 YES NO ODOR 830.6313 Stability to normal and elevated temperatures, metals and metal ions 41610001, 4237801 YES 830.7000 pH 41610001, 4237801 YES 830.7050 UV/ VIS absorption NO * DATA GAP 830.7200 Melting Point/ Melting Range 41789501 YES 830.7220 Boiling Point/ Boiling Point Range SEE GUIDELINE 830.7200 830.7300 Density/ Relative Density/ Bulk Density 42451101 YES 830.7370 Dissociation Constant 41610001 YES 830.7550 Partition coefficient ( n octanol / water) shake flask method 830.7560 Partition coefficient ( n octanol / water) generator column method 830.7570 Partition coefficient ( n octanol / water) estimation by liquid chromatography NO * DATA GAP 830.7840 Water Solubility: Column Elution Method; Shake Flask Method 41610001 YES 830.7860 Water solubility, generator column method SEE GUIDELINE 830.7840 830.7950 Vapor pressure 41610001, 41651901 YES Page 24 of 177 Table 14: Product Chemistry Data Summary for MonoSodium Methanearsonic Salt OPPTS Guideline Numbers GB Biosciences Corporation Data Requirements: MSMA 59% [ Technical] PC 013803 CAS# 2163 80 6 Master Record Identification [ MRID] Are Data Requirements Fulfilled? Results or * Deficiency 830.1550 Product Identity and Composition 42153501 YES 830.1600 Description of Materials Used to Produce the Product 42081201 YES 830.1620 Description of Production Process 42081201 YES 830.1650 Description of Formulation Process NO * DATA GAP 830.1670 Discussion of Formation of Impurities 41608101 YES 830.1700 Preliminary Analysis 41608101 YES 830.1750 Certified Limits NO * DATA GAP 830.1800 Enforcement Analytical Method NO * DATA GAP 830.1900 Submittal of Samples NO * DATA GAP 830.6302 Color NO * DATA GAP 830.6303 Physical State NO * DATA GAP 830.6304 Odor NO * DATA GAP 830.6313 Stability to normal and elevated temperatures, metals and metal ions 41610001, 42378601 YES 830.7000 pH NO * DATA GAP 830.7050 UV/ VIS absorption NO * DATA GAP 830.7200 Melting Point/ Melting Range 41789501 YES 830.7220 Boiling Point/ Boiling Point Range SEE GUIDELINE 830.7200 830.7300 Density/ Relative Density/ Bulk Density NO * DATA GAP 830.7370 Dissociation Constant 41610001 YES 830.7550 Partition coefficient ( n octanol / water) shake flask method 830.7560 Partition coefficient ( n octanol / water) generator column method 830.7570 Partition coefficient ( n octanol / water) estimation by liquid chromatography NO * DATA GAP 830.7840 Water Solubility: Column Elution Method; Shake Flask Method 41610001 YES 830.7860 Water solubility, generator column method SEE GUIDELINE 830.7840 830.7950 Vapor pressure 41610001, 41651901 YES Page 25 of 177 Table 15: Product Chemistry Data Summary for Calcium Methanearsonate OPPTS Guideline Numbers APC Holding Company Data Requirements: CAMA [ TGAI] PC 013806 CAS# 5902 95 4 Master Record Identification [ MRID] Are Data Requirements Fulfilled? Results or * Deficiency 830.1550 Product Identity and Composition NO * DATA GAP 830.1600 Description of Materials Used to Produce the Product 42913801 YES 830.1620 Description of Production Process 42913801 YES 830.1650 Description of Formulation Process NO * DATA GAP 830.1670 Discussion of Formation of Impurities 42913801 YES 830.1700 Preliminary Analysis 42825901 YES 830.1750 Certified Limits NO * DATA GAP 830.1800 Enforcement Analytical Method NO * DATA GAP 830.1900 Submittal of Samples NO * DATA GAP 830.6302 Color 42807602 YES 830.6303 Physical State 42807603 YES 830.6304 Odor 42807604 YES 830.6313 Stability to normal and elevated temperatures, metals and metal ions 42807609 YES 830.7000 pH 42807608 YES 830.7050 UV/ VIS absorption NO * DATA GAP 830.7200 Melting Point/ Melting Range 42807605 YES 830.7220 Boiling Point/ Boiling Point Range SEE GUIDELINE 830.7200 830.7300 Density/ Relative Density/ Bulk Density 42807606 YES 830.7370 Dissociation Constant Memo YES MEMO 09/ 29/ 1995, 07/ 29/ 1993, A. SMITH 830.7550 Partition coefficient ( n octanol / water) shake flask method 830.7560 Partition coefficient ( n octanol / water) generator column method 830.7570 Partition coefficient ( n octanol / water) estimation by liquid chromatography NO * DATA GAP 830.7840 Water Solubility: Column Elution Method; Shake Flask Method 42807607 YES 830.7860 Water solubility, generator column method SEE GUIDELINE 830.7840 830.7950 Vapor pressure NO * DATA GAP 1.6 Summary of Use Pattern and Formulations 1.6.1 Occupational Use and Homeowner Use Products At this time, products containing DMA, CAMA, MSMA and DSMA are intended for both occupational and homeowner uses. DMA is an organic arsenical cotton defoliant and herbicide registered for weed control under non bearing citrus trees, around buildings, and sidewalks and for lawn renovation. CAMA is an organic arsenical herbicide registered for postemergent weed control on lawns. Both MSMA and DSMA are organic arsenical herbicides registered for weed control on cotton, for turfgrass and lawns, and under trees, vines, and shrubs. Page 26 of 177 The MAA ( Methanearsonic Acid) Research Task Force consists of the primary registrants for DMA, CAMA, DSMA, and MSMA, which are Luxembourg Pamol, Inc., Zeneca Agricultural Products/ GP Biosciences, Drexel/ APC Holdings, and Albaugh Inc. This Task Force provided a Master Label review that contains maximum application rates and use parameters for each active ingredient. This assessment examines exposures using the maximum application rates obtained from the Master Label ( ML).

1.6.2 Type of Pesticide/ Targeted Pest DMA DMA ( cacodylic acid, dimethylarsenic acid) is used as a cotton defoliant. It also is an herbicide used in agricultural, commercial and residential settings for the postemergent control of annual grasses and broadleaf weeds, which include ( but, are not limited to) the following:

  Annual Grass: Annual Bluegrass, Annual Bromegrass, Annual Ryegrass, Bahiagrass, Barnyard grass, Bentgrass, Bermuda grass, Carpet grass, Crabgrass, Giant Foxtail, Goosegrass, Green Foxtail, Kentucky Bluegrass, Kikuyugrass, Lovegrass, Madien Cane, Napiergrass, Nimblewill, Nutgrass, Panicum, Pepeergrasss, Poa Annua, Sandbur, Saint Augustinegrass, Timothy, Velvetgrass, Watergrass, Wild Barley, Wild Oats, Witchgrass, Yellow Foxtail.

  Annual Broadleaf Weeds: Bendweed, Brassbuttons, Buckhorn, Burr Clover, Butter Cup, Cat Tails, Cats ear, Chickweed, Chicory, Cocklebur, Common Plantain, Common Ragweed, Course Fescues, Creeping Beagarweed, Dandeloins, Dichondria, Docks, Dogbane, Dog Fennel, Dollarweed, English Daisy, Fine Fescues, Fleabane, Florida Pusley, Frenchweed, Galingsoga, Hawkweed, Healall, Henbit, Knotweed, Kochia, Lambsquarters, Mallow, Milkweed, Moneywort, Morning Glory, Mullein, Nightshade, Oxalis, Pegweed, Pigweed, Posion Ivy, Posion Oak, Prostrate Spruge, Puncture Vine, Purslane, Shattercane, Sheep Sorrel, Shepard's Purse, Smart Weed, Spanish Needles, Speedwell, Spotted Spruge, Stich Wart, Stinging Nettle, Thistle, Wild Aster, Wild Carrot, Wild Mustard, Wild Onion, Wild Radish, Wintercress, Witchweed, Velvetleaf, Vervains, Yarrow, Yellow Wood Sorrel.

  Perennial Weeds: Bermuda grass, Dallis Grass, Johnsongrass, Nutsedge, Quackgrass, Yellow Nutsedge.

CAMA CAMA is a selective herbicide used in commercial and residential settings for postemergent weed control of annual grasses and broadleaf weeds, which include ( but, are not limited to) the following:

  Grasses: Bahiagrass, Barnyard grass, Carpetgrass, Centipedegrass , Crabgrass, Crowfootgrass, Dallisgrass, Foxtail, Goosegrass, Johnsongrass, Lovegrass, Nutgrass, Page 27 of 177 Nutsedge, Paspalum, Saint Augustine Grass, Sandbur, Sedge, Vaseygrass and Witchgrass.

  Weeds: Chickweed, Dandelions, Knotweed, and Puncture Vine.

DSMA DSMA is a selective herbicide used in agricultural, commercial, and residential settings for post emergent weed control of annual grasses and broadleaf weeds, which include ( but, are not limited to) the following:

  Grasses: Bahiagrass, Barnyard grass, Brachiaria, Carpetgrass, Centipedegrass , Crabgrass, Crowfootgrass, Dallisgrass, Foxtail, Goosegrass, Guineagrass, Johnsongrass, Lemongrass, Lovegrass, Nutgrass, Nutsedge, Panicum, Paspalum, Peppergrass, Ryegrass, Saint Augustine grass, Sandbur, Sedge, Signalgrass, Watergrass, Wild Oats, and Witchgrass.

  Weeds: Aster, Bedstraw, Beggarweed, Bindweed, Blackgum, Black Medic, Bullnettle, Burclover, Burdock, Buttonweed, Carpetweed, Carelessweed, Chickweed, Chicory, Clover, Cocklebur, Coffeeweed, Dandeloins, Dayflower, Dock, Fiddleneck, Goathead, Gooseberry, Groundcherry, Hairy Beggarticks, Healall, Henbit, Ironweed, Ivy, Jimsonweed, Knotweed, Lambsquarters, Lespedeza, Mallow, Malva, Morning Glory, Mustard, Pigweed, Plantain, Posion Ivy, Posion Oak, Puncture Vine, Oxalis, Punturevine, Purslane, Pusley, Ragweed, Sesbania, Shepherdspurse, Sicklepod, Sida, Smartweed, Sourwood, Speedwell, Spurge, Teaweed, Tules, Tumbleweed, Velvetleaf, Wild Carrot, Wild Garlic, Wild Lettuce, Wild Onion, Wood Sorrel, Yarrow.

MSMA MSMA is a selective herbicide used in agricultural, commercial, and residential settings for post emergent weed control of annual grasses and broadleaf weeds, which include ( but, are not limited to) the following:

  Grasses: Bahiagrass, Barnyard grass, Brachiaria, Carpetgrass, Centipedegrass , Crabgrass, Crowfootgrass, Dallisgrass, Foxtail, Goosegrass, Guineagrass, Johnsongrass, Lemongrass, Lovegrass, Nutgrass, Nutsedge, Panicum, Paspalum, Peppergrass, Ryegrass, Saint Augustine grass, Sandbur, Sedge, Signalgrass, Watergrass, Wild Oats, and Witchgrass.

  Weeds: Aster, Bedstraw, Beggarweed, Bindweed, Blackgum, Black Medic, Bullnettle, Burclover, Burdock, Buttonweed, Carpetweed, Carelessweed, Chickweed, Chicory, Clover, Cocklebur, Coffeeweed, Dandeloins, Dayflower, Dock, Fiddleneck, Goathead, Gooseberry, Groundcherry, Hairy Beggarticks, Healall, Henbit, Ironweed, Ivy, Jimsonweed, Knotweed, Lambsquarters, Lespedeza, Mallow, Malva, Morning Glory, Mustard, Pigweed, Plantain, Posion Ivy, Posion Oak, Puncture Vine, Oxalis, Punturevine, Purslane, Pusley, Ragweed, Sesbania, Shepherdspurse, Sicklepod, Sida, Smartweed, Page 28 of 177 Sourwood, Speedwell, Spurge, Teaweed, Tules, Tumbleweed, Velvetleaf, Wild Carrot, Wild Garlic, Wild Lettuce, Wild Onion, Wood Sorrel, Yarrow.

1.6.3 Formulation Types and Percent Active Ingredient DMA DMA is formulated as a liquid concentrate ( 0.6 to 4.9 percent active ingredient), a pressurized liquid ( 0.21 percent active ingredient), and a ready to use solution ( 0.09 to 0.39 percent active ingredient).

CAMA CAMA is formulated as a liquid concentrate ( 8.4 10.3% active ingredient) and a readyto use solution ( 0.5 percent active ingredient).

DSMA DSMA is formulated as a liquid concentrate ( 12.5 36.9%) and a wettable powder ( 63 81%)

MSMA MSMA technical is formulated as a liquid concentrate ( 7.2 58.2%) and a ready to use liquid ( 0.4 2.5%).

1.6.4 Registered Use Sites Occupational Use Sites DMA   Agricultural Crops: cotton and non bearing citrus trees ( grapefruit, lemons, limes, oranges, and tangerines).   Ornamentals: evergreen, shrubs, and deciduous ornamentals.   Lawn Renovation.   Non Crop Areas: drainage systems, vacant lots, storage areas, recreational areas, around buildings, fences, walls, flower beds, and gardens, railroad, highway and utility rights of way, pre paving areas, parking lots, brick and gravel walks, patios, curbs, gutters, industrial sites, sidewalks, and driveways. Page 29 of 177 CAMA   Turf ( including residential lawns, parks, athletic fields and golf courses)

DSMA   Agricultural Crops: cotton, non bearing vineyards and orchards, grass grown for seed.   Turfgrass: lawns and ornamental turf and turf grown for sod.   Non crop areas: drainage systems, vacant lots, storage areas, recreational areas, around buildings, fences, walls, flower beds, and gardens, railroad, highway and utility rights of way, pre paving areas, parking lots, brick and gravel walks, patios, curbs, gutters, industrial sites, sidewalks, and driveways.

MSMA   Agricultural Crops: cotton, non bearing vineyards and orchards, grass grown for seed.   Turfgrass: lawns and ornamental turf and turf grown for sod.   Non crop areas: drainage systems, vacant lots, storage areas, recreational areas, around buildings, fences, walls, flower beds, and gardens, railroad, highway and utility rights of way, pre paving areas, parking lots, brick and gravel walks, patios, curbs, gutters, industrial sites, sidewalks, and driveways.

Residential/ Non occupational Use Sites:

DMA   Ornamentals: evergreen, shrubs, and deciduous ornamentals.   Lawn Renovation.   Non Crop Areas: around buildings, fences, walls, flower beds, and gardens, brick and gravel walks, patios, curbs, gutters, sidewalks, and driveways.

CAMA   Turfgrass: Lawns and ornamental turf.

DSMA   Turfgrass: Lawns and ornamental turf.

MSMA   Turfgrass: Lawns and ornamental turf. Page 30 of 177 1.6.5 Application Rates The crop groupings with their corresponding range of application rates are summarized in Table 16 for DMA, Table 17 for CAMA, Table 18 for DSMA, and Table 19 for MSMA. In a memo dated December 9, 2005, master labels were provided for all of the organic arsenic chemicals by the MAA Research Task Force and the rates from these master labels were used in the assessment. Note that much higher rates are found on some current end use product labels and these higher rates will need to be reduced to the levels on the MAA Research Task Force master labels.

Table 16: DMA Maximum Application Rates obtained from the Master Label Application Master Label Maximum Application Rate ( lb ai/ A) Applications Per Year Cotton Preconditioning for defoliation 0.3 1 Cotton defoliation 0.8 1 Cotton defoliation 0.6 2 Lawns and Ornamental Turf Lawn renovation 7.3 2 Lawn edging 7.72 4 Ornamentals Ornamentals 7.3 6 Non Crop Areas Non crop 7.3 6 Nonbearing Citrus Ground directed 4.96 3 Table 17: CAMA Maximum Application Rates obtained from the Master Label Timing of Application/ Use Site Master Label Maximum Application Rate ( lb ai/ A) MMA equivalent ( lb ai/ A) Applications Per Year Turfgrass, Lawns and Ornamental Turf & Turf Grown for Sod By ground only on athletic fields, golf courses ( no greens), parks ( Bentgrass) 2.5 2.2 2 By ground on well established actively growing turf ( Grasses other than Bent) 5 4.4 2 By ground on established Bermudagrass & zoysiagrass 4.182 3.6 4 Note: One broadcast application per year. All additional applications are to be spot treatment only. In Florida all applications   spot treatment only. Page 31 of 177 Table 18: DSMA Maximum Application Rates obtained from the Master Label Timing of Application Master Label Maximum Application Rate ( lb ai/ A) MMA equivalent ( lb ai/ A) Maximum Number of Applications Per Crop Cotton By ground or air: pre plant or post plant ( up to cracking) 2.268 1.7 1 By ground or air: post emergent ( as over the top broadcast spray) 2.268 1.7 1 By ground: post emergent ( directed spray application) 2.268 1.7 2 By ground: post emergent ( directed band application) based on 40 inch row spacing) 2.268 1.7 2 Grasses Grown for Seed in Pacific Northwest only ( Ryegrass, Fescue, and Bluegrass) Pacific Northwest apply before boot stage 4.4 3.3 1 Lawns, Ornamental Turf, and Sod Farms By ground on well established actively growing turf 3.293 2.5 4 Sod Farms 3.293 2.5 4 Nonbearing Orchards and Vineyards Ground directed 4.85 3.7 3 Noncrop Areas Ground application 5.1 3.9 4 Table 19: MSMA Maximum Application Rates obtained from the Master Label Timing of Application Master Label Maximum Application Rate ( lb ai/ A) MMA equivalent ( lb ai/ A) Maximum Number of Applications Per Crop Cotton By ground or air: pre plant or post plant ( up to cracking) 2.0 1.7 1 1.875 1.6 1 By ground or air: post emergent ( as over the top broadcast spray) 0.9375 0.8 2 By ground: post emergent ( directed spray application) 2.0 1.7 2 Grasses Grown for Seed in Pacific Northwest only ( Ryegrass, Fescue, and Bluegrass) Pacific Northwest apply before boot stage 6.16 5.3 1 Lawns, Ornamental Turf, and Sod Farms By ground only on athletic fields, golf courses ( no greens), parks 2.6136 2.3 4 By ground on well established actively growing turf 2.178 1.9 4 By ground on established Bermudagrass & zoysiagrass 3.9204 3.4 4 Sod Farms 3.9204 3.4 4 Nonbearing Orchards and Vineyards Ground directed 4 3.5 3 Noncrop Areas Ground application 4.5 3.9 4 Page 32 of 177 1.6.6 Method and Types of Equipment Used for Mixing, Loading and Application DMA   Agricultural Crops: equipment includes aircraft, groundboom sprayer, low pressure handwand sprayer, and handgun sprayer.   General Weeds or Undesirable Grasses: Equipment for commercial use includes: handgun sprayer, low pressure handwand sprayer, and rights of way sprayer. Equipment for residential use includes: low pressure handwand sprayer, hose end sprayer, trigger pump sprayer, and sprinkler can.   Lawn and Turf Renovation: Equipment for commercial use includes: handgun sprayer and low pressure handwand sprayer. Equipment for residential use includes: low pressure handwand sprayer and hose end sprayer.   Non bearing Citrus Trees: Equipment for commercial use includes: groundboom sprayer, handgun sprayer, low pressure handwand.

CAMA According to the occupational use label, the product is applied using a fixed boom sprayer ( i. e. groundboom); however, HED has also assessed occupational exposures for handgun applications, because handguns are a typical application method for applications to turfgrass by occupational/ commercial applicators. The application equipment for homeowner liquid concentrate formulations are: hose end sprayer and low pressure handwand sprayers. Homeowner ready to use formulations are applied with trigger pump sprayers.

DSMA   Cotton  Equipment for commercial use includes: groundboom sprayer and aerial application.   General Weeds or Undesirable Grasses  Equipment for commercial use includes: turf handgun sprayer, low pressure hand wand, groundboom sprayer application, and rights of way sprayer. Equipment for residential use includes: low pressure hand wand, hose end sprayer and ready to use hose end sprayer.   Non bearing Vineyards and Orchards  Equipment for commercial use includes: turf handgun sprayer, and low pressure handwand.

MSMA   Cotton  Equipment for commercial use includes: groundboom sprayer and aerial application.   General Weeds or Undesirable Grasses  Equipment for commercial use includes: turf handgun sprayer, low pressure hand wand, groundboom sprayer application, and rights of way sprayer. Equipment for residential use includes: low pressure hand wand, hose end sprayer and ready to use hose end sprayer. Page 33 of 177   Non bearing Vineyards and Orchards  Equipment for commercial use includes: turf handgun sprayer, and low pressure handwand.   Forestry  Equipment for commercial use includes: Hypo Hatchet Injector 1.6.7 Timing and Frequency of Application DMA is typically applied postemergent at any time of the year, but for best results it should be applied during warm, sunny weather. Depending on the use pattern, DMA can be applied up to four times per year.

CAMA is most effective when applied to weeds during hot summer weather, but has worked effectively at temperatures as low as 70oF on day with high humidity. Apply to weeds when actively growing. Two applications, 5 to 7 days apart, are usually required for the complete killing of weeds.

MSMA and DSMA are typically applied post emergent at any time of the year, but for best results it should be applied during warm, sunny weather. For weed control on cotton, they are usually applied twice a year and for weed control on non bearing vineyards and orchards, they are usually applied three times a year. For weed control on turfgrass, they are usually applied four times a year.

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

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

  Mixers and/ or Loaders: these individuals perform tasks in preparation for an application. For example, prior to application, mixer/ loaders would mix the chemical and load it into the holding tank of the airplane or groundboom. Page 34 of 177   Applicators: these individuals operate application equipment during the release of a pesticide product into the environment. These individuals can make applications using equipment such as airplanes or groundboom.

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

  Flaggers: these individuals provide ground support to aerial applicators by indicating where the swath ends and the next one should begin.

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

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

Occupational handler exposure assessments are completed by HED using different levels of risk mitigation. Typically, HED uses a tiered approach. The lowest tier is designated as the baseline exposure scenario ( i. e., long sleeve shirt, long pants, shoes, socks, and no respirator). If risks are of concern at baseline attire, then increasing levels of personal protective equipment or PPE ( e. g., gloves, double layer body protection, and respirators) are evaluated. If risks remain a concern with maximum PPE, then engineering controls ( e. g., enclosed cabs or cockpits, watersoluble packaging, and closed mixing/ loading systems) are evaluated. This approach is used to ensure that the lowest level of risk mitigation that provides adequate protection is selected, since the addition of PPE and engineering controls involves an additional expense to the user and   in the case of PPE   also involves an additional burden to the user due to decreased comfort and dexterity and increased heat stress and respiratory stress. Page 35 of 177 2.1.1 Data and Assumptions For Handler Exposure Scenarios <IP_ADDRESS> Assumptions for Handler Exposure Scenarios A series of assumptions and exposure factors served as the basis for completing the occupational handler risk assessments. Each assumption and factor is detailed below on an individual basis. The assumptions and factors used in the risk calculations include:

  Occupational handler exposure estimates were based on surrogate data from: ( 1) the Pesticide Handlers Exposure Database ( PHED) and ( 2) the Outdoor Residential Exposure Task Force ( ORETF).

  The toxicological endpoint of concern for dermal and inhalation risks are from studies where the effects were observed in males and females, therefore, the average body weight of an adult male handler ( i. e., 70 kg) is used to complete the dermal and inhalation noncancer risk assessment.

  Generic protection factors ( PFs) were used to calculate exposures when data were not available. For example, an 80 percent protection factor was assumed for the use of a respirator equipped with a dust/ mist filter.

  For non cancer assessments, HED assumes the maximum application rates allowed by the master labels in its risk assessments ( see Tables 8, 9, 10, and 11).

  The average occupational workday is assumed to be 8 hours.

  The daily areas treated were defined for each handler scenario ( in appropriate units) by determining the amount that can be reasonably treated in a single day ( e. g., acres, square feet, or gallons per day). When possible, the assumptions for daily areas treated are taken from the Health Effects Division Science Advisory Committee on Exposure SOP # 9: Standard Values for Daily Acres Treated in Agriculture, which was completed on July 5, 2000. However, no standard values are available for numerous scenarios. Assumptions for these scenarios are based on HED estimates and could be further refined from input from affected sectors ( see Table 4).

<IP_ADDRESS> Exposure Data for Handler Exposure Scenarios HED uses unit exposure to assess handler exposures to pesticides. Unit exposures are estimates of the amount of exposure to an active ingredient a handler receives while performing various handler tasks and are expressed in terms of micrograms or milligrams of active ingredient per pounds of active ingredient handled. HED has developed a series of unit exposures that are unique for each scenario typically considered in our assessments ( i. e., there are different unit exposures for different types of application equipment, job functions, and levels of protection). The unit exposure concept has been established in the scientific literature and also through various exposure monitoring guidelines published by the U. S. EPA and Page 36 of 177 international organizations such as Health Canada and OECD ( Organization for Economic Cooperation and Development).

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

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

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

The unit exposures calculated by PHED generally range from the geometric mean to the median of the selected data set. To add consistency and quality control to the values produced from this system, the PHED Task Force has evaluated all data within the system and has developed a set of grading criteria to characterize the quality of the original study data. The assessment of data quality is based on the number of observations and the available quality control data. These evaluation criteria and the caveats specific to each exposure scenario are summarized in Appendix M. While data from PHED provide the best available information on handler exposures, it should be noted that some aspects of the included studies ( e. g., duration, acres treated, pounds of active ingredient handled) may not accurately represent labeled uses in all cases. HED has developed a series of tables of standard unit exposure for many occupational scenarios that can be utilized to ensure consistency in exposure assessments. Unit exposures are used which represent different levels of personal protection as described above. Protection factors were used to calculate unit exposures for varying levels of personal protection if data were not available. Page 37 of 177 ORETF Handler Studies ( MRID 449722 01): A report was submitted by the ORETF ( Outdoor Residential Exposure Task Force) that presented data in which the application of various products used on turf by homeowners and lawncare operators ( LCOs) was monitored. All of the data submitted in this report were completed in a series of studies.

OMA002: LCO Spray Applications with a Low Pressure Handgun ( MRID 449722 01): A mixer/ loader/ applicator study was performed by the Outdoor Residential Exposure Task Force ( ORETF) using Dacthal as a surrogate compound to determine " generic" exposures to individuals applying a pesticide to turf with a low pressure " nozzle gun" or " handgun" sprayer. Dermal and inhalation exposures were estimated using whole body passive dosimeters and breathing zone air samples on OVS tubes. Inhalation exposure was calculated using an assumed respiratory rate of 17 liters per minute for light work ( NAFTA, 1999), the actual sampling time for each individual, and the pump flow rate. All results were normalized for pounds active ingredient handled.

A total of 90 replicates were monitored using 17 different subjects. Four different formulations of dacthal [ 75% wettable powder ( packaged in 4 and 24 pound bags), 75% wettable powder in water soluble bags ( 3 pound bag), 75% water dispersible granules ( 2 pound bag) and 55% liquid flowable ( 2.5 gallon container)] were applied by five different LCOs to actual residential lawns at each site in three different locations ( Ohio, Maryland, and Georgia) for a total of fifteen replicates per formulation. An additional ten replicates at each site were monitored while they performed spray application only using the 75 percent wettable powder formulation. A target application rate of 2 pounds active ingredient was used for all replicates ( actual rate achieved was about 2.2 pounds active ingredient per acre). Each replicate treated a varying number of actual client lawns to attain a representative target of 2.5 acres ( 1 hectare) of turf. The exposure periods averaged five hours twenty one minutes, five hours thirty nine minutes, and six hours twenty four minutes, in Ohio, Maryland and Georgia, respectively. Average time spent spraying at all sites was about two hours. All mixing, loading, application, adjusting, calibrating, and spill clean up procedures were monitored, except for typical end ofday clean up activities, e. g. rinsing of spray tank, etc. Dermal exposure was measured using inner and outer whole body dosimeters, hand washes, face/ neck washes, and personal air monitoring devices. All test subjects wore one piece, 100 percent cotton inner dosimeters beneath 100 percent cotton long sleeved shirt and long pants, rubber boots and nitrile gloves. Gloves are typically worn by most LCOs, and required by many pesticide labels for mixing and loading.

Overall, residues were highest on the upper and lower leg portions of the dosimeters. In general, concurrent lab spikes produced mean recoveries in the range of 78 120 percent, with the exception of OVS sorbent tube sections which produced mean recoveries as low as 65.8 percent. Adjustment for recoveries from field fortifications were performed on each dosimeter section or sample matrix for each study participant, using the mean recovery for the closest field spike level for each matrix and correcting the value to 100 percent. The unit exposure values are presented below in Table 20. [ Note the data were found to be lognormally distributed. As a result, all exposure values are geometric means.] Page 38 of 177 Table 20: Unit Exposure Values Obtained for LCO Spray Applications with a Low Pressure Handgun from ORETF Handgun Studies ( MRID 449722 01) Total Dermal Unit Exposure1 ( mg/ lb ai) Application Method4 Single Layer, No Gloves Single Layer, Gloves Double Layer, Gloves 3 Inhalation Unit Exposure1,2 ( ug/ lb ai)

LCO Handgun Spray Mixer/ Loader/ Applicator Liquid Flowable No Data 0.45 0.245 1.8 LCO Handgun Spray Mixer/ Loader/ Applicator Water Dispersable Granule No Data 0.58 0.37 22 LCO Handgun Spray Mixer/ Loader/ Applicator Wettable Powder in Water Soluble Bags No Data 0.58 0.37 7.2 LCO Handgun Spray Mixer/ Loader/ Applicator Wettable Powder No Data 0.80 0.43 64 LCO Handgun Spray Applicator Only Wettable Powder No Data 0.74 0.40 1.0 1 Unit exposure values reported are geometric means. 2 Air concentration ( mg/ m3/ lb ai) calculated using NAFTA ` 99 standard breathing rate of 17 lpm ( 1 m3/ hr). 3 Exposure calculated using OPP/ HED 50% protection factor ( PF) for cotton coveralls on torso, arms, and legs. 4 All commercial handlers wore long pants, long sleeved shirt, nitrile gloves and shoes.

2.1.2 Occupational Handler Exposure Scenarios It has been determined that exposure to pesticide handlers is likely during the occupational use of MMA or DMA on agricultural crops, non crop areas and on turfgrass. The anticipated use patterns and current labeling indicate occupational exposure scenarios based on the types of equipment and techniques that can potentially be used for MMA or DMA applications. The quantitative exposure/ risk assessment developed for occupational handlers is based on the following scenarios.

DMA Mixer/ Loaders: ( 1a) Mixing/ loading liquids for aerial application ( PHED); ( 1b) Mixing/ loading liquids for ground application ( PHED); ( 1c) Mixing/ loading liquids to support LCO handgun applications ( PHED); ( 1d) Mixing/ loading liquids for rights of way application ( PHED);

Applicators: ( 2) Applying sprays with aerial equipment ( PHED); ( 3) Applying liquids with groundboom sprayer ( PHED); ( 4) Applying sprays with a handgun sprayer ( PHED); ( 5) Applying sprays with rights of way sprayer ( PHED);

Flaggers: ( 6) Flagging sprays for aerial application ( PHED); Page 39 of 177 Mixer/ Loader/ Applicators: ( 7) Mixing/ loading/ applying liquids with low pressure handwand sprayer ( ORETF); ( 8) Mixing/ loading/ applying liquids with a handgun sprayer ( LCO ORETF); ( 9) Applying ready to use liquids with a trigger pump sprayer ( ORETF); and ( 10) Mixing/ loading/ applying liquids with a watering can ( ORETF hose end data).

CAMA Mixer/ Loaders: ( 1a) Liquid Formulations for Groundboom Applications ( PHED); ( 1b) Liquid Formulations for LCO Handgun Applications ( PHED);

Applicators: ( 2) Groundboom Spray Applications ( PHED); ( 3) Handgun Sprayer Applications ( PHED); and Mixer/ Loader/ Applicators: ( 4) Liquid Formulations: Handgun Sprayer ( ORETF).

DSMA Mixer/ Loaders: ( 1a) liquids for aerial application ( PHED); ( 1b) liquids for ground application ( PHED); ( 1c) liquids to support LCO handgun applications ( PHED); ( 1d) liquids for rights of way application ( PHED);

Applicators: ( 2) sprays with aerial equipment ( PHED); ( 3) sprays with groundboom sprayer ( PHED); ( 4) sprays with a turf handgun sprayer ( PHED); ( 5) sprays with rights of way sprayer ( PHED);

Flaggers: ( 6) flagging for aerial sprays applications ( PHED);

Mixer/ Loader/ Applicators: ( 7) liquids with low pressure handwand ( ORETF); and ( 8) liquids with a handgun sprayer ( LCO ORETF data).

MSMA Mixer/ Loaders: ( 1a) liquids for aerial application ( PHED); ( 1b) liquids for ground application ( PHED); Page 40 of 177 ( 1c) liquids to support LCO handgun applications ( PHED); ( 1d) liquids for rights of way application ( PHED);

Applicators: ( 2) sprays with aerial equipment ( PHED); ( 3) sprays with groundboom sprayer ( PHED); ( 4) sprays with a turf handgun sprayer ( PHED); ( 5) sprays with rights of way sprayer ( PHED);

Flaggers: ( 6) flagging for aerial sprays applications ( PHED);

Mixer/ Loader/ Applicators: ( 7) liquids with low pressure handwand ( ORETF); and ( 8) liquids with a handgun sprayer ( LCO ORETF data).

2.1.3 Non cancer Occupational Handler Exposure and Assessment <IP_ADDRESS> Non cancer Occupational Handler Exposure and Risk Calculations Daily Exposure: Daily dermal or inhalation handler exposures are estimated for each applicable handler task with the application rate, the area treated in a day, and the applicable dermal or inhalation unit exposure using the following formula:

Daily Exposure ( mg ai/ day) = Unit Exposure ( mg ai/ lb ai handled) x Application Rate ( lbs ai/ area) x Daily Area Treated ( area/ day)

Where:

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

Daily Dose: The daily dermal or inhalation dose is calculated by normalizing the daily exposure by body weight and adjusting, if necessary, with an appropriate dermal or inhalation absorption factor. For all dermal and inhalation exposure scenarios for MMA and DMA, an average male and female body weight of 70 kilograms was used, since the toxicological endpoint is not sex specific. Daily dose was calculated using the following formula: Page 41 of 177 Average Daily Dose ( mg/ kg/ day) = Daily Exposure ( mg ai/ day) x ( Absorption Factor (%/ 100) / Body Weight ( kg)

Where:

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

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

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

Where:

MOE = Margin of Exposure, value used by HED to represent risk or how close a chemical exposure is to being a concern ( unitless); ADD = Average Daily Dose or the absorbed dose received from exposure to a pesticide in a given scenario ( mg pesticide active ingredient/ kg body weight/ day); and NOAEL or LOAEL = Dose level in a toxicity study, where no observed adverse effects ( NOAEL) or where the lowest observed adverse effects ( LOAEL) occurred in the study Risk values are presented for each route of exposure ( i. e., dermal or inhalation) in each scenario, because risk mitigation measures are specific to the route of exposure. A total MOE was not calculated for MMA or DMA because the dermal and inhalation toxicological endpoints of concern are based on different adverse effects.

<IP_ADDRESS> Occupational Non cancer Risk Summary ( using PHED and ORETF data)

Tables 21, 22, 23 and 24 present the risk assessments for short and intermediate term dermal and inhalation exposures at baseline, with additional personal protective equipment, and with engineering controls, for DMA, CAMA, MSMA, and DSMA, respectively. Page 42 of 177 Table 21: DMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target Application Rate ( lb ai/ A) Area Treated Daily ( acres) Dermal Inhalation Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% Respirator Dermal Inhalation Mixer/ Loader Cotton ( defoliation) 0.8 1200 7.5 270 950 1300 1300 2500 3800 Mixing/ Loading Liquid Concentrates for Aerial Applications ( 1a) Cotton ( preconditioning for defoliation) 0.3 1200 20 710 2500 3400 3500 6800 10000 Cotton ( defoliation) 0.8 200 45 1600 5700 7700 8000 15000 23000 Cotton ( preconditioning for defoliation) 0.3 200 120 4300 15000 21000 21000 41000 62000 Non crop 7.3 100 9.9 350 1300 1700 1800 3300 5100 Mixing/ Loading Liquids Concentrates for Groundboom Applications ( 1b) Non bearing citrus orchards 4.96 80 18 640 2300 3100 3200 6200 9300 Page 43 of 177 Table 21: DMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target Application Rate ( lb ai/ A) Area Treated Daily ( acres) Dermal Inhalation Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% Respirator Dermal Inhalation Lawn edging 7.72 100 9.4 330 1200 1600 1700 3200 4800 Mixing/ Loading Liquid Concentrates to Support LCO Handgun Applications ( mixing/ loading supports 20 LCOs) ( 1c) Lawn renovation 7.3 100 9.9 350 1300 1700 1800 3300 5100 Mixing/ Loading Liquid Concentrates to Support Rights of Way ( 1d) Non crop 7.3 80 12 440 1600 2100 2200 4200 6300 Applicator Cotton ( defoliation) 0.8 1200 No Data No Data No Data No Data No Data 4400 4700 Applying Sprays via Aerial Equipment ( 2) Cotton ( preconditioning for defoliation) 0.3 1200 No Data No Data No Data No Data No Data 12000 13000 Page 44 of 177 Table 21: DMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target Application Rate ( lb ai/ A) Area Treated Daily ( acres) Dermal Inhalation Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% Respirator Dermal Inhalation Cotton ( defoliation) 0.8 200 9400 2600 9400 12000 13000 26000 45000 Cotton ( preconditioning for defoliation) 0.3 200 25000 6900 25000 32000 35000 70000 120000 Non crop 7.3 100 2100 570 2100 2600 2800 5800 9800 Applying Sprays via Groundboom Equipment ( 3) Non bearing citrus orchards 4.96 80 3800 1000 3800 4800 5200 11000 18000 Lawn edging 7.72 5 No Data 5700 1600 2900 28000 No Data No Data Applying Sprays via Handgun Equipment ( 4) Lawn renovation 7.3 5 No Data 6000 1700 3000 30000 No Data No Data Applying Sprays via Rights of Way Equipment ( 5) Non crop 7.3 80 28 130 92 120 670 No Data No Data Page 45 of 177 Table 21: DMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target Application Rate ( lb ai/ A) Area Treated Daily ( acres) Dermal Inhalation Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% Respirator Dermal Inhalation Flagger Cotton ( defoliation) 0.8 350 6800 3100 No Data 7500 16000 340000 160000 Flagging for Aerial Sprays Applications ( 6) Cotton ( preconditio ning for defoliation) 0.3 350 18000 8300 No Data 20000 42000 910000 420000 Mixer/ Loader/ Applicator Non bearing citrus orchards 4.96 5 56 4600 2600 No Data 23000 NF NF Lawn edging 7.72 5 36 2900 1600 No Data 15000 NF NF Lawn renovation 7.3 5 38 3100 1700 No Data 16000 NF NF Mixing/ Loading/

Applying Liquid Concentrates with Low Pressure Handwand ( ORETF) ( 7) Non crop 7.3 5 38 3100 1700 No Data 16000 NF NF Page 46 of 177 Table 21: DMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target Application Rate ( lb ai/ A) Area Treated Daily ( acres) Dermal Inhalation Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% Respirator Dermal Inhalation Non bearing citrus orchards 4.96 5 No Data 6900 1900 3500 34000 NF NF Lawn edging 7.72 5 No Data 4400 1200 2200 22000 NF NF Lawn renovation 7.3 5 No Data 4700 1300 2300 23000 NF NF Mixing/ Loading/

Applying Liquid Concentrates with a Handgun Sprayer ( LCO ORETF data) ( 8) Non crop 7.3 5 No Data 4700 1300 2300 23000 NF NF Applying Ready to Use Formulations via Trigger Pump Sprayer ( ORETF) ( 9) Non crop 0.00017 1000 3000 96000 70000 No Data 480000 NF NF Page 47 of 177 Table 21: DMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target Application Rate ( lb ai/ A) Area Treated Daily ( acres) Dermal Inhalation Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% Respirator Dermal Inhalation Lawn edging 0.00018 1000 11000 100000 No Data No Data 510000 NF NF Mixing/ Loading/

Applying Liquids with a Watering Can ( using ORETF residential hoseend data) ( 10) Lawn renovation 0.00017 1000 11000 110000 No Data No Data 540000 NF NF Page 48 of 177 Table 22: CAMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of CAMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Mixer/ Loader Lawn and ornamental turf ( on grasses other than Bent) 5 4.4 40 140 1500 17000 23000 7300 46000 21000 Lawn and ornamental turf ( on Bermuda and Zoysia grass) 4.182 3.7 40 160 1700 21000 28000 8700 55000 25000 Mixing/ Loading Liquids Concentrates for Groundboom Applications ( 1a) Lawn and ornamental turf ( on bentgrass) 2.5 2.2 40 270 2900 35000 47000 15000 92000 42000 Lawn and ornamental turf ( on grasses other than Bent) 5 4.4 100 55 580 6900 9400 2900 18000 8400 Lawn and ornamental turf ( on Bermuda and Zoysia grass) 4.182 3.7 100 66 690 8300 11000 3500 22000 10000 Mixing/ Loading Liquid Concentrates for LCO Handgun Applications ( 1b) Lawn and ornamental turf ( on bentgrass) 2.5 2.2 100 110 1300 14000 19000 5800 37000 17000 Page 49 of 177 Table 22: CAMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of CAMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Applicator Lawn and ornamental turf ( on grasses other than Bent) 5 4.4 40 28000 2400 28000 36000 12000 80000 40000 Lawn and ornamental turf ( on Bermuda and Zoysia grass) 4.182 3.7 40 34000 2800 34000 43000 14000 95000 48000 Applying Sprays via Groundboom Equipment ( 2) Lawn and ornamental turf ( on bentgrass) 2.5 2.2 40 57000 4700 57000 72000 24000 160000 81000 Lawn and ornamental turf ( on grasses other than Bent) 5 4.4 5 ND 10000 9400 17000 50000 NF NF Lawn and ornamental turf ( on Bermuda and Zoysia grass) 4.182 3.7 5 ND 12000 11000 20000 59000 NF NF Applying Sprays via Handgun Equipment ( 3) Lawn and ornamental turf ( on bentgrass) 2.5 2.2 5 ND 20000 19000 33000 100000 NF NF Page 50 of 177 Table 22: CAMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of CAMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Mixer/ Loader/ Applicator Lawn and ornamental turf ( on grasses other than Bent) 5 4.4 5 No Data 7700 7100 13000 39000 NF NF Lawn and ornamental turf ( on Bermuda and Zoysia grass) 4.182 3.7 5 No Data 9300 8500 16000 46000 NF NF Mixing/ Loading/ Applying Liquid Concentrates with a Handgun Sprayer ( LCO ORETF data)

( 4) Lawn and ornamental turf ( on bentgrass) 2.5 2.2 5 No Data 15000 14000 26000 77000 NF NF Page 51 of 177 Table 23: DSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of DSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Mixer/ Loader Mixing/ Loading Liquid Concentrates for Aerial Applications ( 1a) Cotton ( pre plant or post plant up to cracking) 2.268 1.7 1200 12 120 1500 2000 620 3900 1800 Cotton ( postemergent directed spray) 2.268 1.7 200 70 740 8800 12000 3700 24000 11000 Grass grown for seed 4.4 3.3 80 90 950 11000 15000 4800 30000 14000 Turf for sod farms 3.293 2.5 80 120 1300 15000 21000 6400 41000 18000 Lawns and Ornamental Turf 3.293 2.5 40 240 2600 31000 41000 13000 82000 37000 Nonbearing Fruit, Nut,

& Vineyards 4.85 3.7 80 82 870 10000 14000 4300 28000 13000 Mixing/ Loading Liquids Concentrates for Groundboom Applications ( 1b) Noncrop Areas 5.1 3.88 100 62 660 7800 11000 3300 21000 9500 Page 52 of 177 Table 23: DSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of DSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Mixing/ Loading Liquid Concentrates to Support LCO Handgun Applications ( mixing/ loadin g supports 20 LCOs) ( 1c) Lawns and Ornamental Turf ( well established actively growing turfgrass) 3.293 2.5 100 96 1000 12000 16000 5100 32000 15000 Mixing/ Loading Liquid Concentrates to Support Rights of Way ( 1d) Noncrop Areas 5.1 3.88 80 78 820 9800 13000 4100 26000 12000 Applicator Applying Sprays via Aerial Equipment ( 2) Cotton 2.268 1.7 1200 No Data No Data No Data No Data No Data 6800 2200 Cotton 2.268 1.7 200 14000 1200 14000 18000 6000 41000 21000 Grass grown for seed 4.4 3.3 80 19000 1500 19000 24000 7700 52000 27000 Applying Sprays via Groundboom Equipment ( 3) Turf on sod farms 3.293 2.5 80 25000 2100 25000 32000 10000 70000 36000 Page 53 of 177 Table 23: DSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of DSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Lawns and Ornamental Turf ( well established actively growing turfgrassgolf courses 3.293 2.5 40 50000 4100 50000 63000 21000 140000 71000 Nonbearing Fruit & Nut Orchards &

Vineyards 4.85 3.7 80 17000 1400 17000 22000 7000 47000 24000 Applying Sprays via Groundboom Equipment ( 3)

Cont. Noncrop Areas 5.1 3.88 100 13000 1100 13000 16000 5300 36000 18000 Applying Sprays via Handgun Equipment ( 4) Lawns and Ornamental Turf ( well established actively growing turfgrass) 3.293 2.5 5 No Data 17000 16000 29000 87000 NF NF Applying Sprays via Rights of Way Equipment ( 5) Noncrop Areas 5.10 3.88 80 170 250 580 780 1300 NF NF Flagger Flagging for Aerial Sprays Applications ( 6) Cotton 2.268 1.7 350 11000 1500 No Data 12000 7300 530000 73000 Page 54 of 177 Table 23: DSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of DSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Mixer/ Loader/ Applicator Mixing/ Loading/ Applying Liquid Concentrates with Low Pressure Handwand ( ORETF) ( 7) Lawns and Ornamental Turf ( well established actively growing turfgrass) 3.293 2.5 5 280 6900 13000 No Data 34000 NF NF Lawns and Ornamental Turf ( well established actively growing turfgrass) 3.293 2.5 5 No Data 14000 12000 23000 68000 NF NF Mixing/ Loading/ Applying Liquid Concentrates with a Handgun Sprayer ( LCO ORETF data)

( 8) Nonbearing Fruit & Nut Orchards &

Vineyards 4.85 3.7 5 No Data 9200 8400 15000 46000 NF NF Page 55 of 177 Table 24: MSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of MSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Mixer/ Loader Cotton ( pre plant or post plant up to cracking) 2 1.7 1200 12 120 1500 2000 620 3900 1800 Mixing/ Loading Liquid Concentrates for Aerial Applications ( 1a) Cotton ( postemergent over the top broadcast spray) 0.9375 0.8 1200 25 260 3100 4200 1300 8400 3800 Cotton ( postemergent directed spray) 2 1.7 200 70 740 8800 12000 3700 24000 11000 Cotton ( postemergent directed band application) 0.9375 0.8 200 150 1600 19000 25000 7900 50000 23000 Mixing/ Loading Liquids Concentrates for Groundboom Applications ( 1b) Grass grown for seed 6.16 5.3 80 57 600 7100 9700 3000 19000 8700 Page 56 of 177 Table 24: MSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of MSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Turf on sod farms 3.9204 3.4 80 89 940 11000 15000 4700 30000 14000 Lawns and Ornamental Turf ( athletic fields, golf courses, parks) 2.6136 2.3 40 270 2800 34000 46000 14000 91000 41000 Lawns and Ornamental Turf ( established Bermuda grass and zoysia grass 3.9204 3.4 40 180 1900 23000 31000 9500 60000 27000 Nonbearing Fruit, Nut, &

Vineyards 4 3.5 80 87 920 11000 15000 4600 29000 13000 Mixing/ Loading Liquids Concentrates for Groundboom Applications ( Cont.) ( 1b) Noncrop Areas 4.5 3.9 100 62 660 7800 11000 3300 21000 9500 Page 57 of 177 Table 24: MSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of MSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Lawns and Ornamental Turf ( athletic fields, golf courses, parks) 2.6136 2.3 100 110 1100 13000 18000 5700 36000 16000 Lawns and Ornamental Turf ( well established actively growing turfgrass) 2.178 1.9 100 130 1400 16000 22000 6800 43000 20000 Mixing/ Loading Liquid Concentrates to Support LCO Handgun Applications ( mixing/ loadin g supports 20 LCOs) ( 1c) Lawns and Ornamental Turf ( established Bermuda grass and zoysia grass 3.9204 3.4 100 71 750 9000 12000 3800 24000 11000 Page 58 of 177 Table 24: MSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of MSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Mixing/

Loading Liquid Concentrates to Support Rights of Way ( 1d) Noncrop Areas 4.5 3.9 80 78 820 9800 13000 4100 26000 12000 Applicator Cotton 2 1.7 1200 No Data No Data No Data No Data No Data 6700 2200 Applying Sprays via Aerial Equipment ( 2) Cotton 0.9375 0.8 1200 No Data No Data No Data No Data No Data 14000 4600 Cotton 2 1.7 200 14000 1200 14000 18000 6000 40000 21000 Cotton 0.9375 0.8 200 31000 2600 31000 39000 13000 86000 44000 Grass grown for seed 6.16 5.3 80 12000 970 12000 15000 4900 33000 17000 Applying Sprays via Groundboom Equipment ( 3) Turf on sod farms 3.9204 3.4 80 18000 1500 18000 23000 7600 52000 26000 Page 59 of 177 Table 24: MSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of MSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Lawns and Ornamental Turf ( athletic fields, golf courses, parks) 2.6136 2.3 40 55000 4600 55000 70000 23000 150000 79000 Lawns and Ornamental Turf ( well established actively growing turfgrass golf courses) 2.178 1.9 40 66000 5500 66000 85000 28000 190000 95000 Lawns and Ornamental Turf ( established bermudagrass and zoysia grass golf courses) 3.9204 3.4 40 37000 3100 37000 47000 15000 100000 53000 Nonbearing Fruit & Nut Orchards &

Vineyards 4 3.5 80 18000 1500 18000 23000 7500 51000 26000 Applying Sprays via Groundboom Equipment ( Cont.) ( 3) Noncrop Areas 4.5 3.9 100 13000 1100 13000 16000 5300 36000 18000 Page 60 of 177 Table 24: MSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of MSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Lawns and Ornamental Turf ( athletic parks, golf courses, parks) 2.6136 2.3 5 No Data 19000 18000 33000 97000 NF NF Lawns and Ornamental Turf ( well established actively growing turfgrass) 2.178 1.9 5 No Data 23000 22000 39000 120000 NF NF Applying Sprays via Handgun Equipment ( 4) Lawns and Ornamental Turf ( established bermudagrass and zoysia grass) 3.9204 3.4 5 No Data 13000 12000 22000 65000 NF NF Applying Sprays via Rights of Way Equipment ( 5) Noncrop Areas 4.5 3.9 80 170 250 580 780 1300 NF NF Page 61 of 177 Table 24: MSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of MSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Flagger Cotton 2 1.7 350 11000 1400 No Data 12000 7200 530000 72000 Flagging for Aerial Sprays Applications ( 6) Cotton 0.9375 0.8 350 22000 3100 No Data 25000 15000 1100000 150000 Mixer/ Loader/ Applicator Lawns and Ornamental Turf ( athletic fields, golf courses, parks) 2.6136 2.3 5 360 8700 16000 No Data 43000 NF NF Lawns and Ornamental Turf ( well established actively growing turfgrass) 2.178 1.9 5 430 10000 19000 No Data 52000 NF NF Mixing/ Loading/ Applying Liquid Concentrates with Low Pressure Handwand ( ORETF) ( 7) Lawns and Ornamental Turf ( established bermudagrass and zoysia grass) 3.9204 3.4 5 240 5800 11000 No Data 29000 NF NF Page 62 of 177 Table 24: MSMA Occupational Handler Short and Intermediate term Dermal and Inhalation Exposure and Risks MOEs Baseline PPE Engineering Controls Exposure Scenario Crop or Target App Rate of MSMA ( lb ai/ acre) App Rate of MMA ( lb ai/ acre) Area Treated Daily ( acres) Dermal Inh Dermal

single layer w/ gloves Dermal

double layer w/ gloves Inhalation

80% R Dermal Inh Lawns and Ornamental Turf ( athletic fields, golf courses, parks) 2.6136 2.3 5 No Data 15000 14000 25000 75000 NF NF Lawns and Ornamental Turf ( well established actively growing turfgrass) 2.178 1.9 5 No Data 18000 17000 30000 90000 NF NF Lawns and Ornamental Turf ( established bermudagrass and zoysia grass) 3.9204 3.4 5 No Data 10000 9200 17000 50000 NF NF Mixing/ Loading/ Applying Liquid Concentrates with a Handgun Sprayer ( LCO ORETF data)

( 8) Nonbearing Fruit & Nut Orchards &

Vineyards ( MSMA) 4 3.5 5 No Data 9900 9000 17000 49000 NF NF Page 63 of 177 2.1.4 Cancer Occupational Handler Exposure and Risk Assessment No cancer endpoints of concern for DMA, CAMA, DSMA, and MSMA were identified therefore cancer risks to handlers were not assessed.

2.1.5 Summary of Risk Concerns and Data Gaps for Occupational Handlers <IP_ADDRESS> Summary of Risk Concerns For the dermal and inhalation, short and intermediate term exposure, the level of concern or target MOE is 100. The calculated dermal and inhalation risks were not combined for shortterm or for intermediate term because the dermal and inhalation endpoints were based on different toxicological effects. There are no occupational handler scenarios for MMA or DMA that have risks associated with them that are above HED's level of concern for non cancer risk assessments at some level of mitigation.

For inhalation exposure, all scenarios for all of the organic arsenical active ingredients exceeded the level of concern at baseline level of mitigation. For dermal exposure, the following scenarios are below the level of concern at baseline level of mitigation, but are above the level of concern with personal protective equipment ( i. e., single layer plus gloves):

DMA   Mixing/ Loading Liquid Concentrates for Aerial Applications o Cotton ( defoliation) ( MOE = 7.5 at baseline) o Cotton ( pre conditioning for defoliation) ( MOE = 20 at baseline)   Mixing/ Loading Liquid Concentrates for Groundboom Applications o Cotton ( defoliation) ( MOE = 45 at baseline) o Non crop ( MOE = 9.9 at baseline) o Non bearing citrus orchards ( MOE = 18 at baseline)   Mixing/ Loading Liquid Concentrates to Support LCO Handgun Applications ( mixing/ loading supports 20 LCOs) o Lawn edging ( MOE = 9.4 at baseline) o Lawn renovation ( MOE = 9.9 at baseline)   Mixing/ Loading Liquid Concentrates to Support Rights of Way o Non crop ( MOE = 12 at baseline)   Applying Sprays via Rights of Way Equipment o Non crop ( MOE = 28 at baseline); This scenario also is of concern with single layer plus gloves with an MOE of 92, but with double layer plus gloves, the risk is not a concern ( MOE > 100)   Mixing/ Loading/ Applying Liquid Concentrates with Low Pressure Handwand ( ORETF) o Non bearing citrus orchards ( MOE = 56 at baseline) o Lawn edging ( MOE = 36 at baseline) o Lawn renovation ( MOE = 38 at baseline) Page 64 of 177 o Non crop ( MOE = 38 at baseline)

CAMA   Mixing/ Loading Liquid Concentrates to Support LCO Handgun Applications ( mixing/ loading supports 20 LCOs) o Lawn and ornamental turf ( on grasses other than Bent) ( MOE = 55 at baseline) o Lawn and ornamental turf ( on Bermuda and Zoysia grass) ( MOE = 66 at baseline)

DSMA   Mixing/ Loading Liquid Concentrates for Aerial Applications o Cotton ( pre plant or post plant up to cracking) ( MOE = 12 at baseline)   Mixing/ Loading Liquid Concentrates for Groundboom Applications o Cotton ( post emergent directed spray) ( MOE = 70 at baseline) o Grass grown for seed ( MOE = 90 at baseline) o Non crop Areas ( MOE = 62 at baseline)   Mixing/ Loading Liquid Concentrates to Support LCO Handgun Applications ( mixing/ loading supports 20 LCOs) o Lawns and Ornamental Turf ( well established actively growing turfgrass) ( MOE = 96 at baseline)   Mixing/ Loading Liquid Concentrates to Support Rights of Way o Non crop Areas ( MOE = 78 at baseline)

MSMA   Mixing/ Loading Liquid Concentrates for Aerial Applications o Cotton ( pre plant or post plant up to cracking) ( MOE = 12 at baseline) o Cotton ( post emergent over the top broadcast spray) ( MOE = 25 at baseline)   Mixing/ Loading Liquid Concentrates for Groundboom Applications o Cotton ( post emergent directed spray) ( MOE = 70 at baseline) o Grass grown for seed ( MOE = 57 at baseline) o Turf on sod farms) ( MOE = 89 at baseline) o Nonbearing Fruit, Nut, & Vineyards ( MOE = 87 at baseline) o Nonbearing Fruit, Nut, & Vineyards ( MOE = 82 at baseline) o Non crop Areas ( MOE = 62 at baseline)   Mixing/ Loading Liquid Concentrates to Support LCO Handgun Applications ( mixing/ loading supports 20 LCOs) o Lawns and Ornamental Turf ( established Bermuda grass and zoysia grass) ( MOE = 71 at baseline)   Mixing/ Loading Liquid Concentrates to Support Rights of Way o Non crop Areas ( MOE = 78 at baseline) Page 65 of 177 <IP_ADDRESS> Summary of Data Gaps There are no data gaps associated with the occupational handler scenarios.

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

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

2.2.1 Occupational Postapplication Exposure Scenarios Currently, DMA is registered for use on cotton, turfgrass and lawns. CAMA is registered for use on turfgrass and lawns, and the occupational label for CAMA prohibits use on turf being grown for sale, commercial use as sod, commercial seed production, or for research purposes. MSMA and DSMA uses are varied as it can be used on agricultural crops ( i. e. cotton and sod farms) and in a variety of other outdoor occupational settings ( i. e., rights of way, golf course turf). As a result, a wide array of individuals can potentially be exposed by working in areas that have been previously treated. HED is concerned about the kinds of exposures one could receive in the workplace.

HED uses a concept known as the transfer coefficient to numerically represent the postapplication exposures one would receive ( generally presented as cm2/ hour). The transfer coefficient concept has been established in the scientific literature and through various exposure monitoring guidelines published by the U. S. EPA and international organizations such as Health Canada and the Organization For Economic Cooperation and Development. The establishment of transfer coefficients also forms the basis of the work of the Agricultural Reentry Task Force. A transfer coefficient is a measure of the residue transferred from a treated surface to a person who is doing a task or activity in a treated area. These values are the ratio of an exposure for a given task or activity to the amount of pesticide residue on treated surfaces available for transfer. Page 66 of 177 HED has developed a series of standard transfer coefficients that are unique for variety of job tasks or activities that are used in lieu of chemical and scenario specific data.

To develop a postapplication assessment, HED considers the types of tasks and activities that individuals are likely to doing in areas recently treated with a pesticide. For consistency within postapplication assessments, HED has developed a list of tasks commonly associated with specific crops or use patterns, which are likely to result in postapplication exposures. Postapplication pesticide exposures that result from an individual's employment are considered occupational exposures. Common examples include: crop maintenance tasks ( e. g., irrigating, weeding, and mowing) and crop advisor tasks ( e. g., scouting).

HED considers how and when a pesticide is applied to estimate the level of transferable residues to which individuals could be exposed over time. Label directions and other use data are considered to determine application rates and application frequency. HED completes noncancer postapplication risk assessments using maximum application rates for each scenario. When postapplication noncancer risks are a concern using maximum application rates, HED may also consider typical application rates or application frequency, to further evaluate the overall risks associated with the use of the pesticide. To estimate the amount of transferable residues on a treated surface, HED uses, when possible, chemical and crop specific studies as described in HED guidelines for exposure data collection ( Series 875, Occupational and Residential Exposure Test Guidelines: Group B  Postapplication Exposure Monitoring Test Guidelines). For postapplication exposures, unique techniques are used to measure the amount of pesticide residue on a treated surface available for possible transfer. These techniques are distinct from those which measure total pesticide residue on a treated surface and absorbed into a treated entity. When appropriate chemical and crop specific transferable residue data are unavailable, HED also has developed a standard modeling approach to predict transferable residues over time ( best described in HED's SOPs For Residential Exposure Assessment).

HED also must consider the likely frequency and duration of postapplication occupational exposures to DMA and MMA. Short term (   30 days) always are considered in these assessments. Intermediate term ( greater than 30 days to several months) exposure durations are appropriate for postapplication occupational exposures scenarios where the pesticide is reapplied several times over a growing season, or the pesticide residues persist for relatively long periods of time, or the crop or use pattern is such that occupational postapplication workers may be exposed to several different treated areas in the course of their work. For example, migrant and seasonal workers may move from farm to farm and be exposed several weeks to several months or different fields or greenhouses on an individual establishment may be treated over a period of weeks due to differing levels of infestation or staggered crop cycles. For DMA and MMA, the exposure durations for noncancer postapplication risk assessment were short term (   30 days) and intermediate term ( greater than 30 days up to several months). However, since the dermal toxicological endpoint of concern is the same for short and intermediate term exposures, the short and intermediate term postapplication risks are numerically identical. Inhalation exposures are thought to be negligible in outdoor postapplication scenarios, since DMA and MMA have low vapor pressure and the dilution factor outdoors is considered infinite. Page 67 of 177 HED has used the basic approach described above since the mid 1980s for calculating postapplication risks to pesticides. From that time to the present, several revisions and modifications were made to Agency policies as data, which warranted such changes, became available. In 1995, the Agency issued a Data Call In for postapplication agricultural data that prompted the formation of the Agricultural Reentry Task Force ( ARTF). This task force has generated a number of exposure studies and associated documents that are currently under review. The work of the ARTF is not yet complete; however, sufficient data were available from the group that warranted a significant interim change in Agency policy related to the data which were already available as the efforts of the ARTF paralleled a push for tolerance reassessment stipulated by the timelines established by FQPA. As a result of the need for the revision and using the latest data, the Agency developed a revised policy on August 7, 2000 entitled Policy 003.1 Science Advisory Council for Exposure Policy Regarding Agricultural Transfer Coefficients. The revision to this policy entailed linking worker activities to more specific crop/ agronomic groupings and making better use of the available occupational postapplication exposure data. In the new policy, transfer coefficients were selected to represent the activities associated with 18 distinct crop/ agronomic groupings based on different types of vegetables, trees, berries, vine/ trellis crops, turf, field crops, and bunch/ bundle crops ( e. g., tobacco).