SEQ CHAPTER \h \r 1

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

	OFFICE OF PREVENTION, PESTICIDESs

                                                                                AND TOXIC SUBSTANCES

MEMORANDUM

Date:  		22 October 09

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

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

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

Petition No.:  8E7419	Regulatory Action:  Section 3

Risk Assessment Type:  NA	Case No.:  2245

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

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

FROM:	David Soderberg, Chemist

RAB5/Health Effects Division (7509P)

THROUGH:	David Hrdy, Senior Biologist

Debra Rate, Biologist

Dietary Exposure Science Advisory Council (DESAC)

Health Effects Division (7509P)

and

Jack Arthur, Branch Chief

RAB5/Health Effects Division (7509P)

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

		Barbara Madden, Team Leader

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

Minor Use Team (7505P)

Executive Summary

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

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

Acute and Cancer Dietary Exposure

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

Chronic Dietary Exposure Results and Characterization

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

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

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

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

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

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

Introduction

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

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

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

II.	Residue Information

Endothall Use:

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

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

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

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

Residue Data on Foods used for the Chronic Assessment:

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

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

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

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

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

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

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

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

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

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

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

Meat, Milk, Poultry and Eggs

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

The detailed dietary burden calculations are provided in attachment 6.

Summary of Dietary Exposure Input Data for Foods

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

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

Table 1. 	Residue Summary for Endothall.

Commodity	Residues (ppm)	Percent Crop Treated	Processing Factor	Comments

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

Carrots	0.08	100	1	carrots

Potatoes	0.08	100	1	potatoes

Potatoes, dry

100	6.5	Potatoes

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

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

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

Ginger, dried	0.33	100	1	No default processing factor

Root crop Tops, Crop Group 2	1.3	100

From sugar beet tops

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

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

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

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

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

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

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

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

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

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

Soybean seed	0.034	9	1	soybeans (0.034 ppm).

Soybean flour	0.034	9	1	soybeans (0.034 ppm).

Soybean milk	0.034	9	1	soybeans (0.034 ppm).

Soybean oil	0.034	9	0.005	soybeans (0.034 ppm).

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

Tomato Paste

100	3.3

	Tomato Puree

100	2.1

	Tomato Juice

100	1.5

	Dried tomato	0.025	100	14.3

	Okra	0.025	100	1	From Tomato (0.025 ppm)

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

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

Citrus Fruit Oil	0.024	100	0.2	Citrus oil factor

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

Citrus Peels	0.024	100	1.0	Between oil factor and pulp factor

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

Dried apple 	0.041	100	8.0	Processing Study

Apple sauce	0.041	100	1	No Factor

Apple and pear juices	0.041	100	1.2	Processing Study

Dried pear	0.041	100	6.25	Default Factor

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

Dried Peach	0.098	100	7.0	Default factor

Dried Plum (Prune)	0.098	100	5.0	Default factor

Prune Juice	0.098	100	1.4	Default factor

Cherry Juice	0.098	100	1.5	Default factor

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

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

Current, dried	0.33	100	4.4	Raisin drying factor

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

Grape Juice	0.52	97	1.0	Residues on grapes, Default Factor

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

Grape Leaves	0.52	97	1	Based upon average residues on grapes

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

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

Pecans	0.024	100	1	Pecan Study

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

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

Wheat	0.71	14	1	Wheat field studies

Wheat flour	0.71	14	0.6	Wheat Processing Study

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

Wheat Bran	0.71	14	2.3	PF 2.3x for bran,

Barley, grain	0.71	36	1	From wheat

Barley, flour	0.71	36	1	Wheat residues corn flour processing

Barley, bran	0.71	36	2.3	Wheat processing study

Sorghum, grain	1.0	15	1.0	Percent irrigated for grain only

Sorghum, syrup	1.0	100	1.0	Percent irrigated for grain only

Oats	0.71	7	1.0	Residues from wheat

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

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

Corn meal and flour	0.05	19	1.0	Corn Processing Study

Corn, field, bran	0.05	19	2.3	Corn Processing Study

Corn, field, starch	0.05	19	1.0	Corn Processing Study

Corn, field, syrup	0.05	19	1.5	Corn Processing Study

Corn, field, oil	0.05	19	1	Corn Processing Study

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

Herb and spice, group 19

100	1	Based upon Mint Study

Rice, grain	1.05	100	1	Average residues in Rice

White Rice	1.05	100	0.1	Rice Processing Study

Rice Bran	1.05	100	2.3	Rice Processing Study

Rice flour	1.05	100	0.1	Rice Processing Study for white rice

Alfalfa	0.11	92	1	From Alfalfa trials

Acerola	0.041	100	1	Translated from apple residues

Amaranth	0.71	100	1	Translated from leaf lettuce

Artichoke	0.71	100	1	Translated from leaf lettuce

Asparagus	0.32	100	1	Translated from head lettuce

Avocado	0.041	100	1	Translated from apple residues

Bamboo	2.2	100	1	From average grass residues

Banana	0.041	100	1	Translated from apple residues

Dried Banana	0.041	100	3.9	Translated from apple residues

Belgium endive	0.32	100	1	Translated from head lettuce

Breadfruit	0.041	100	1	Translated from apple residues

Cactus	0.71	100	1	Translated from leaf lettuce

Canistel	0.041	100	1	Translated from apple residues

Carob	0.041	100	1	Translated from apple residues

Cherimoya	0.041	100	1	Translated from apple residues

Cocoa bean	0.041	100	1	Translated from apple residues

Cocoa bean powder	0.041	100	1 	Translated from apple residues

Coconut meat	0.041	100	1	Translated from apple residues

Dried coconut meat	0.041	100	2.1	Translated from apple residues

Coconut milk	0.041	100	1	Translated from apple residues

Coconut oil	0.041	100	0.005	Translated from apple residues

Coffee, roasted bean	0.041	100	1	Translated from apple residues

Coffee, Instant	0.041	100	1	Translated from apple residues

Cottonseed oil	0.1	100	0.001	Regular Cotton residues and processing factor

Cranberry	0.33	100	1	From blackberries

Cranberry, Dried	0.33	100	1	From blackberries

Cranberry, Juice	0.33	100	1.1	From blackberries

Date	0.041	100	1	Translated from apple residues

Feijoa	0.041	100	1	Translated from apple residues

Fig	0.041	100	1	Translated from apple residues

Dried fig	0.041	100	1	Translated from apple residues

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

Guava	0.041	100	1	Translated from apple residues

Honey	0.003	100	1	Use milk residues

Hop	0.1	100	1	Tolerance from Terrestrial use

Jaboticaba	0.041	100	1	Translated from apple residues

Jack fruit	0.041	100	1	Translated from apple residues

Kiwi fruit	0.52	100	1	From grapes

Longan	0.041	100	1	Translated from apple residues

Lychee	0.041	100	1	Translated from apple residues

Mamey apple	0.041	100	1	Translated from apple residues

Mango	0.041	100	1	Translated from apple residues

Dried mango	0.041	100	1	Translated from apple residues

Mango juice	0.041	100	1	Translated from apple residues

Maple sugar	0.041	100	1	Translated from apple residues

Maple syrup	0.041	100	1	Translated from apple residues

Mulberry	0.041	100	1	Translated from apple residues

Mushroom	0.71	100	1	Translated from leaf lettuce

Olive	0.041	100	1	Translated from apple residues

Olive oil	0.041	100	0.005	Translated from apple residues

Palm heart	2.2	100	1	Translated from grass residues

Plam oil	2.2	100	0.005	Translated from grass residues

Papaya	0.041	100	1	Translated from apple residues

Dried papaya	0.041	100	1.8	Translated from apple residues

Papaya juice	0.041	100	1.5	Translated from apple residues

Passionfruit	0.041	100	1	Translated from apple residues

Passionfruit juice	0.041	100	1	Translated from apple residues

Pawpaw	0.041	100	1	Translated from apple residues

Peanut	0.08	42	1	From potato residues

Peanut butter	0.08	42	1.89	From potato residues

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

Peppermint	2.14	100	1	From Mint Study

Peppermint oil	2.14	100	0.01	From Mint Study

Persimmon	0.041	100	1	Translated from apple residues

Pine nut	0.041	100	1	Translated from apple residues

Pineapple	0.5	100	1	From curcubits

Dried pineapple	0.5	100	5.0	From curcubits

Pineapple juice	0.5	100	1.7	From curcubits

Plantain	0.041	100	1	Translated from apple residues

Dried plantain	0.041	100	3.9	Translated from apple residues

Pomegranate	0.041	100	1	Translated from apple residues

Psyllium seed	0.71	100	1	Translated from leaf lettuce

Quinoa gra oilin	0.71	100	1	Translated from leaf lettuce

Rapeseed	0.034	100	0.005	From Soybeans and soybean oil PF

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

Sapote	0.041	100	1	Translated from apple residues

Sesame seed	0.71	100	1	Translated from leaf lettuce

Sesame seed oil	0.71	100	0.005	Translated from leaf lettuce

Soursop	0.041	100	1	Translated from apple residues

Spanish lime	0.041	100	1	Translated from apple residues

Spearmint	2.14	100	1	From Mint Study

Sunflower	0.034	100	0.005	From Soybeans and soybean oil PF

Spearmint oil	2.14	100	0.01	From Mint Study

Starfruit	0.041	100	1	Translated from apple residues

Strawberry	0.52	100	1	Translated from grapes

Strawberry juice	0.52	100	1	Translated from grapes

Sugar apple	0.041	100	1	Translated from apple residues

Sugarcane	2.2	100	1	From grass

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

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

Tamarind	0.041	100	1	Translated from apple residues

Tea, dried	0.33	100	1	Translated from blackberry residues

Instant  tea	0.33	100	1	Translated from blackberry residues

Tomato tree	0.041	100	1	Translated from apple residues

Vinegar	0.025	100	1	Translated from apple residues

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Finfish	0.1	100	1	Tolerance

Crustaceans	1	100	1	Recommended Tolerance

Mollusks	4	100	1	Recommended Tolerance

 Drinking Water Data

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

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

IV.	DEEM-FCID™ Program and Consumption Information

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

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

V.	Toxicological Information

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

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

Exposure

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

Acute Dietary

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

Chronic Dietary

(All populations)

LOAEL= 2 mg/kg/day

UFA = 10

UFH = 10

UFDB = 3

UFtotal = 300

	Chronic RfD =

0.007 mg/kg/day

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

Cancer (oral, dermal, inhalation)

Not likely to be carcinogenic to humans

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

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

VI.	Results/Discussion

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

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

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

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

Population Subgroup	Chronic Dietary

	Food Only	Water Only	Food Plus Water

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

(mg/kg/day)	% cPAD	Dietary Exposure

(mg/kg/day)	% cPAD

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

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

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

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

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

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

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

Adults 50+ years old	0.001367	20	0.000642	9	0.002009	29

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

VII.	Characterization of Inputs/Outputs

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

Level of Refinement

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

Residue Issues

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

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

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

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

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

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

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

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

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

Translation of Residue Data

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

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

Processing Factors

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

Adequacy of %CT data

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

Sensitivity Analyses

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

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

Significant Risk Contributors ("Risk Drivers")

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

Additional Information for Risk Managers

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

VIII.	Conclusions

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

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

List of Attachments

Chronic Food Plus Water Residue Input file.

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

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

Residues in Field Trials

Processing Study results

Dietary Burden Calculations

Percent Crop Treated Memo from BEAD

Water Residues Memo from EFED

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

Attachment 1.  Chronic Food Plus Water Input File

U.S. Environmental Protection Agency                                 Ver. 2.00

DEEM-FCID Chronic analysis for ENDOTHALL                          1994-98 data

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

                                                               Adjust. #2 used

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

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

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

Food Crop                                       Residue       Adj.Factors      Comment

EPA Code  Grp  Food Name                          (ppm)

                                                             #1         #2

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

95000010 O    Acerola                            0.041000   1.000      1.000   from a

  Full comment: from apples

18000020 18   Alfalfa, seed                      0.110000   1.000      0.920

14000030 14   Almond                             0.031000   1.000      1.000   almond

  Full comment: almond field trial

14000031 14   Almond-babyfood                    0.031000   1.000      1.000   almond

  Full comment: almond field trial

14000040 14   Almond, oil                        0.031000   0.005      1.000   soy oi

  Full comment: soy oil factor

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

  Full comment: soy oil factor

04010050 4A   Amaranth, leafy                    0.710000   1.000      1.000

95000060 O    Amaranth, grain                    0.710000   1.000      1.000   from w

  Full comment: from wheat grain

11000070 11   Apple, fruit with peel             0.041000   1.000      0.780

11000080 11   Apple, peeled fruit                0.041000   1.000      0.780

11000081 11   Apple, peeled fruit-babyfood       0.041000   1.000      0.780

11000090 11   Apple, dried                       0.041000   8.000      0.440

11000091 11   Apple, dried-babyfood              0.041000   8.000      0.440

11000100 11   Apple, juice                       0.041000   1.200      0.490   juice

  Full comment: juice factor

11000101 11   Apple, juice-babyfood              0.041000   1.200      0.490   juice

  Full comment: juice factor

11000110 11   Apple, sauce                       0.041000   1.000      0.140

11000111 11   Apple, sauce-babyfood              0.041000   1.000      0.140

12000120 12   Apricot                            0.098000   1.000      1.000

12000121 12   Apricot-babyfood                   0.098000   1.000      1.000

12000130 12   Apricot, dried                     0.098000   6.000      1.000   DEEM d

  Full comment: DEEM default proc factor

12000140 12   Apricot, juice                     0.098000   1.000      1.000

12000141 12   Apricot, juice-babyfood            0.098000   1.000      1.000

01030150 1CD  Arrowroot, flour                   0.330000   6.500      1.000   PF fro

  Full comment: PF from potato

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

  Full comment: PF from potato

95000160 O    Artichoke, globe                   0.710000   1.000      1.000   from l

  Full comment: from leafy greens

01030170 1CD  Artichoke, Jerusalem               0.330000   1.000      1.000

04010180 4A   Arugula                            0.710000   1.000      1.000

95000190 O    Asparagus                          0.320000   1.000      1.000   from h

  Full comment: from head lettuce

95000200 O    Avocado                            0.041000   1.000      1.000   from a

  Full comment: from apples

09020210 9B   Balsam pear                        0.500000   1.000      1.000

95000220 O    Bamboo, shoots                     2.200000   1.000      1.000   from g

  Full comment: from grass

95000230 O    Banana                             0.041000   1.000      1.000   from a

  Full comment: from apples

95000231 O    Banana-babyfood                    0.041000   1.000      1.000   from a

  Full comment: from apples

95000240 O    Banana, dried                      0.041000   3.900      1.000   from a

  Full comment: from apples

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

  Full comment: from apples

15000250 15   Barley, pearled barley             0.710000   1.000      0.360   from w

  Full comment: from wheat

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

  Full comment: from wheat

15000260 15   Barley, flour                      0.710000   1.000      0.360   from w

  Full comment: from wheat

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

  Full comment: from wheat

15000270 15   Barley, bran                       0.710000   2.300      0.360   wheat

  Full comment: wheat and rice bran factor

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

  Full comment: from mint per ChemSAC

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

  Full comment: from mint per ChemSAC

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

  Full comment: from mint per ChemSAC

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

  Full comment: from mint per ChemSAC

06030300 6C   Bean, black, seed                  0.110000   1.000      0.320

06020310 6B   Bean, broad, succulent             0.390000   1.000      1.000

06030320 6C   Bean, broad, seed                  0.110000   1.000      0.320

06020330 6B   Bean, cowpea, succulent            0.390000   1.000      1.000

06030340 6C   Bean, cowpea, seed                 0.110000   1.000      0.320

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

06030360 6C   Bean, kidney, seed                 0.110000   1.000      0.320

06020370 6B   Bean, lima, succulent              0.390000   1.000      1.000

06030380 6C   Bean, lima, seed                   0.110000   1.000      1.000

06030390 6C   Bean, mung, seed                   0.110000   1.000      0.320

06030400 6C   Bean, navy, seed                   0.110000   1.000      0.320

06030410 6C   Bean, pink, seed                   0.110000   1.000      0.320

06030420 6C   Bean, pinto, seed                  0.110000   1.000      0.320

06010430 6A   Bean, snap, succulent              0.390000   1.000      1.000

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

21000440 M    Beef, meat                         0.002500   1.000      1.000   from d

  Full comment: from dairy cattle

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

  Full comment: from dairy cattle

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

  Full comment: from dairy cattle

21000460 M    Beef, meat byproducts              0.023000   1.000      1.000   from d

  Full comment: from dairy cattle

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

  Full comment: from dairy cattle

21000470 M    Beef, fat                          0.001000   1.000      1.000   from d

  Full comment: from dairy cattle

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

  Full comment: from dairy cattle

21000480 M    Beef, kidney                       0.023000   1.000      1.000   from d

  Full comment: from dairy cattle

21000490 M    Beef, liver                        0.010000   1.000      1.000   from d

  Full comment: from dairy cattle

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

  Full comment: from dairy cattle

01010500 1AB  Beet, garden, roots                0.330000   1.000      1.000

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

02000510 2    Beet, garden, tops                 1.300000   1.000      1.000

01010530 1A   Beet, sugar, molasses              0.330000   2.400      0.370

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

95000540 O    Belgium endive                     0.320000   1.000      1.000   from h

  Full comment: from head lettuce

13010550 13A  Blackberry                         0.330000   1.000      1.000

13010560 13A  Blackberry, juice                  0.330000   1.000      1.000

13010561 13A  Blackberry, juice-babyfood         0.330000   1.000      1.000

13020570 13B  Blueberry                          0.180000   1.000      1.000

13020571 13B  Blueberry-babyfood                 0.180000   1.000      1.000

13010580 13A  Boysenberry                        0.330000   1.000      1.000

14000590 14   Brazil nut                         0.031000   1.000      1.000   almond

  Full comment: almond field trial

95000600 O    Breadfruit                         0.041000   1.000      1.000   from a

  Full comment: from apples

05010610 5A   Broccoli                           0.060000   1.000      1.000   from c

  Full comment: from cabbage

05010611 5A   Broccoli-babyfood                  0.060000   1.000      1.000   from c

  Full comment: from cabbage

05010620 5A   Broccoli, Chinese                  0.060000   1.000      1.000   from c

  Full comment: from cabbage

05020630 5B   Broccoli raab                      0.710000   1.000      1.000   from l

  Full comment: from leaf lettuce

05010640 5A   Brussels sprouts                   0.060000   1.000      1.000   from c

  Full comment: from cabbage

15000650 15   Buckwheat                          0.710000   1.000      1.000   from w

  Full comment: from wheat

15000660 15   Buckwheat, flour                   0.710000   0.600      1.000   from w

  Full comment: from wheat and wheat flour

01010670 1AB  Burdock                            0.330000   1.000      1.000

14000680 14   Butternut                          0.031000   1.000      1.000   almond

  Full comment: almond field trial

05010690 5A   Cabbage                            0.060000   1.000      1.000

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

  Full comment: from leaf lettuce

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

  Full comment: from cabbage

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

  Full comment: from cabbage

95000730 O    Cactus                             0.710000   1.000      1.000   from l

  Full comment: from leafy greens

95000740 O    Canistel                           0.041000   1.000      1.000   from a

  Full comment: from apples

09010750 9A   Cantaloupe                         0.500000   1.000      1.000

04020760 4B   Cardoon                            0.710000   1.000      1.000

95000770 O    Carob                              0.041000   1.000      1.000   from a

  Full comment: from apples

01010780 1AB  Carrot                             0.080000   1.000      1.000

01010781 1AB  Carrot-babyfood                    0.080000   1.000      1.000

01010790 1AB  Carrot, juice                      0.080000   1.000      1.000

09010800 9A   Casaba                             0.500000   1.000      1.000

14000810 14   Cashew                             0.031000   1.000      1.000   almond

  Full comment: almond field trial

01030820 1CD  Cassava                            0.330000   1.000      1.000

01030821 1CD  Cassava-babyfood                   0.330000   1.000      1.000

05010830 5A   Cauliflower                        0.060000   1.000      1.000   from c

  Full comment: from cabbage

01010840 1AB  Celeriac                           0.330000   1.000      1.000

04020850 4B   Celery                             0.320000   1.000      1.000   from h

  Full comment: from head lettuce

04020851 4B   Celery-babyfood                    0.320000   1.000      1.000   from h

  Full comment: from head lettuce

04020860 4B   Celery, juice                      0.320000   1.000      1.000   from h

  Full comment: from head lettuce

04020870 4B   Celtuce                            0.710000   1.000      1.000

09020880 9B   Chayote, fruit                     0.500000   1.000      1.000

95000890 O    Cherimoya                          0.041000   1.000      1.000   from a

  Full comment: from apples

12000900 12   Cherry                             0.098000   1.000      1.000

12000901 12   Cherry-babyfood                    0.098000   1.000      1.000

12000910 12   Cherry, juice                      0.098000   1.500      1.000

12000911 12   Cherry, juice-babyfood             0.098000   1.500      1.000

14000920 14   Chestnut                           0.031000   1.000      1.000   almond

  Full comment: almond field trial

40000930 P    Chicken, meat                      0.001000   1.000      1.000

40000931 P    Chicken, meat-babyfood             0.001000   1.000      1.000

40000940 P    Chicken, liver                     0.003000   1.000      1.000

40000950 P    Chicken, meat byproducts           0.014000   1.000      1.000

40000951 P    Chicken, meat byproducts-babyfoo   0.014000   1.000      1.000

40000960 P    Chicken, fat                       0.001000   1.000      1.000

40000961 P    Chicken, fat-babyfood              0.001000   1.000      1.000

40000970 P    Chicken, skin                      0.014000   1.000      1.000

40000971 P    Chicken, skin-babyfood             0.014000   1.000      1.000

06030980 6C   Chickpea, seed                     0.110000   1.000      0.320

06030981 6C   Chickpea, seed-babyfood            0.110000   1.000      0.320

06030990 6C   Chickpea, flour                    0.110000   1.000      0.320

01011000 1AB  Chicory, roots                     0.330000   1.000      1.000

02001010 2    Chicory, tops                      1.300000   1.000      1.000

09021020 9B   Chinese waxgourd                   0.500000   1.000      1.000

19011030 19A  Chive                              2.140000   1.000      1.000   from m

  Full comment: from mint per ChemSAC

04011040 4A   Chrysanthemum, garland             0.710000   1.000      1.000

19021050 19B  Cinnamon                           2.140000   1.000      1.000   from m

  Full comment: from mint

19021051 19B  Cinnamon-babyfood                  2.140000   1.000      1.000   from m

  Full comment: from mint

10001060 10   Citrus citron                      0.024000   1.000      1.000

10001070 10   Citrus hybrids                     0.024000   1.000      1.000

10001080 10   Citrus, oil                        0.024000   0.200      1.000   citrus

  Full comment: citrus oil factor

95001090 O    Cocoa bean, chocolate              0.041000   1.000      1.000   from a

  Full comment: from apples

95001100 O    Cocoa bean, powder                 0.041000   1.000      1.000   from a

  Full comment: from apples

95001110 O    Coconut, meat                      0.041000   1.000      1.000   from a

  Full comment: from apples

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

  Full comment: from apples

95001120 O    Coconut, dried                     0.041000   2.100      1.000   from a

  Full comment: from apples

95001130 O    Coconut, milk                      0.041000   1.000      1.000   from a

  Full comment: from apples

95001140 O    Coconut, oil                       0.041000   0.005      1.000   from a

  Full comment: from apples and soy oil factor

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

  Full comment: from apples and soy oil factor

95001150 O    Coffee, roasted bean               0.041000   1.000      1.000   from a

  Full comment: from apples

95001160 O    Coffee, instant                    0.041000   1.000      1.000   from a

  Full comment: from apples

05021170 5B   Collards                           0.710000   1.000      1.000   from l

  Full comment: from leaf lettuce

19011180 19A  Coriander, leaves                  2.140000   1.000      1.000   from m

  Full comment: from mint per ChemSAC

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

  Full comment: from mint per ChemSAC

19021190 19B  Coriander, seed                    2.140000   1.000      1.000   from m

  Full comment: from mint

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

  Full comment: from mint

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

  Full comment: corn flour 1x

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

  Full comment: corn flour 1x

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

  Full comment: corn meal 1x

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

  Full comment: corn meal 1x

15001220 15   Corn, field, bran                  0.050000   2.300      0.190   wheat

  Full comment: wheat and rice bran factor

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

  Full comment: corn starch 1x

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

  Full comment: corn starch 1x

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

  Full comment: corn starch 1x

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

  Full comment: corn starch 1x

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

  Full comment: corn oil 1x

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

  Full comment: corn oil 1x

15001260 15   Corn, pop                          0.050000   1.000      0.190

15001270 15   Corn, sweet                        0.110000   1.000      1.000

15001271 15   Corn, sweet-babyfood               0.110000   1.000      1.000

95001280 O    Cottonseed, oil                    0.100000   0.005      1.000   soy oi

  Full comment: soy oil factor

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

  Full comment: soy oil factor

11001290 11   Crabapple                          0.041000   1.000      1.000

95001300 O    Cranberry                          0.330000   1.000      1.000   from c

  Full comment: from cane berries

95001301 O    Cranberry-babyfood                 0.330000   1.000      1.000   from c

  Full comment: from cane berries

95001310 O    Cranberry, dried                   0.330000   1.000      1.000   from c

  Full comment: from cane berries

95001320 O    Cranberry, juice                   0.330000   1.100      1.000   from c

  Full comment: from cane berries

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

  Full comment: from cane berries

04011330 4A   Cress, garden                      0.710000   1.000      1.000

04011340 4A   Cress, upland                      0.710000   1.000      1.000

09021350 9B   Cucumber                           0.500000   1.000      1.000

13021360 13B  Currant                            0.180000   1.000      1.000

13021370 13B  Currant, dried                     0.180000   1.000      1.000

04011380 4A   Dandelion, leaves                  0.710000   1.000      1.000

01031390 1CD  Dasheen, corm                      0.330000   1.000      1.000

02001400 2    Dasheen, leaves                    1.300000   1.000      1.000

95001410 O    Date                               0.041000   1.000      1.000   from a

  Full comment: from apples

13011420 13A  Dewberry                           0.330000   1.000      1.000

19021430 19B  Dill, seed                         2.140000   1.000      1.000   from m

  Full comment: from mint

19011440 19A  Dillweed                           2.140000   1.000      1.000   from m

  Full comment: from mint per ChemSAC

70001450 P    Egg, whole                         0.003700   1.000      1.000

70001451 P    Egg, whole-babyfood                0.003700   1.000      1.000

70001460 P    Egg, white                         0.000300   1.000      1.000

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

70001470 P    Egg, yolk                          0.003700   1.000      1.000

70001471 P    Egg, yolk-babyfood                 0.003700   1.000      1.000

08001480 8    Eggplant                           0.025000   1.000      1.000   from t

  Full comment: from tomato 1/2 LOD

13021490 13B  Elderberry                         0.180000   1.000      1.000

04011500 4A   Endive                             0.320000   1.000      1.000   from h

  Full comment: from head lettuce

95001510 O    Feijoa                             0.041000   1.000      1.000   from a

  Full comment: from apples

04021520 4B   Fennel, Florence                   0.710000   1.000      1.000

95001530 O    Fig                                0.041000   1.000      1.000   from a

  Full comment: from apples

95001540 O    Fig, dried                         0.041000   1.000      1.000   from a

  Full comment: from apples

14001550 14   Filbert                            0.031000   1.000      1.000   almond

  Full comment: almond field trial

14001560 14   Filbert, oil                       0.031000   0.005      1.000   soy oi

  Full comment: soy oil factor

80001570 F    Fish-freshwater finfish            0.100000   1.000      1.000

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

80001610 F    Fish-shellfish, crustacean         1.000000   1.000      1.000

80001620 F    Fish-shellfish, mollusc            4.000000   1.000      1.000

20001630 20   Flaxseed, oil                      0.034000   0.005      1.000   from s

  Full comment: from soybeans +soy oil factor

03001640 3    Garlic                             0.050000   1.000      1.000

03001650 3    Garlic, dried                      0.050000   1.000      1.000

03001651 3    Garlic, dried-babyfood             0.050000   1.000      1.000

01031660 1CD  Ginger                             0.330000   1.000      1.000

01031661 1CD  Ginger-babyfood                    0.330000   1.000      1.000

01031670 1CD  Ginger, dried                      0.330000   1.000      1.000

01011680 1AB  Ginseng, dried                     0.330000   1.000      1.000

23001690 M    Goat, meat                         0.001500   1.000      1.000   from b

  Full comment: from beef cattle

23001700 M    Goat, meat byproducts              0.001500   1.000      1.000   from b

  Full comment: from beef cattle

23001710 M    Goat, fat                          0.000600   1.000      1.000   from b

  Full comment: from beef cattle

23001720 M    Goat, kidney                       0.014000   1.000      1.000   from b

  Full comment: from beef cattle

23001730 M    Goat, liver                        0.006000   1.000      1.000   from b

  Full comment: from beef cattle

13021740 13B  Gooseberry                         0.180000   1.000      1.000

95001750 O    Grape                              0.520000   1.000      0.990

95001760 O    Grape, juice                       0.520000   1.200      0.940   maximu

  Full comment: maximum conc factor

95001761 O    Grape, juice-babyfood              0.520000   1.200      0.940   maximu

  Full comment: maximum conc factor

95001770 O    Grape, leaves                      0.520000   1.000      0.990

95001780 O    Grape, raisin                      0.520000   4.400      0.940

95001790 O    Grape, wine and sherry             0.520000   1.000      0.940

10001800 10   Grapefruit                         0.024000   1.000      1.000

10001810 10   Grapefruit, juice                  0.024000   0.820      1.000   adjust

  Full comment: adjusted OJ factor

06031820 6C   Guar, seed                         0.110000   2.100      0.320

06031821 6C   Guar, seed-babyfood                0.110000   2.100      0.320

95001830 O    Guava                              0.041000   1.000      1.000   from a

  Full comment: from apples

95001831 O    Guava-babyfood                     0.041000   1.000      1.000   from a

  Full comment: from apples

19011840 19A  Herbs, other                       2.140000   1.000      1.000   from m

  Full comment: from mint per ChemSAC

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

  Full comment: from mint per ChemSAC

14001850 14   Hickory nut                        0.031000   1.000      1.000   almond

  Full comment: almond field trial

95001860 O    Honey                              0.003000   1.000      1.000   from m

  Full comment: from milk

95001861 O    Honey-babyfood                     0.003000   1.000      1.000   from m

  Full comment: from milk

09011870 9A   Honeydew melon                     0.500000   1.000      1.000

95001880 O    Hop                                0.100000   1.000      1.000

24001890 M    Horse, meat                        0.001500   1.000      1.000   from b

  Full comment: from beef cattle

01011900 1AB  Horseradish                        0.330000   1.000      1.000

13021910 13B  Huckleberry                        0.180000   1.000      1.000

95001920 O    Jaboticaba                         0.041000   1.000      1.000   from a

  Full comment: from apples

95001930 O    Jackfruit                          0.041000   1.000      1.000   from a

  Full comment: from apples

05021940 5B   Kale                               0.710000   1.000      1.000   from l

  Full comment: from leaf lettuce

95001950 O    Kiwifruit                          0.520000   1.000      1.000   from g

  Full comment: from grapes

05011960 5A   Kohlrabi                           0.060000   1.000      1.000   from c

  Full comment: from cabbage

10001970 10   Kumquat                            0.024000   1.000      1.000

03001980 3    Leek                               0.260000   1.000      1.000   from g

  Full comment: from green onion

10001990 10   Lemon                              0.024000   1.000      1.000

10002000 10   Lemon, juice                       0.024000   0.780      1.000   adjust

  Full comment: adjusted OJ factor

10002001 10   Lemon, juice-babyfood              0.024000   0.780      1.000   adjust

  Full comment: adjusted OJ factor

10002010 10   Lemon, peel                        0.024000   2.200      1.000   dried

  Full comment: dried pulp factor

19012020 19A  Lemongrass                         2.140000   1.000      1.000   from m

  Full comment: from mint per ChemSAC

06032030 6C   Lentil, seed                       0.110000   1.000      1.000

04012040 4A   Lettuce, head                      0.320000   1.000      1.000   from h

  Full comment: from head lettuce

04012050 4A   Lettuce, leaf                      0.710000   1.000      1.000

10002060 10   Lime                               0.024000   1.000      1.000

10002070 10   Lime, juice                        0.024000   0.780      1.000   adjust

  Full comment: adjusted OJ factor

10002071 10   Lime, juice-babyfood               0.024000   0.780      1.000   adjust

  Full comment: adjusted OJ factor

13012080 13A  Loganberry                         0.330000   1.000      1.000

95002090 O    Longan                             0.041000   1.000      1.000   from a

  Full comment: from apples

11002100 11   Loquat                             0.041000   1.000      1.000

95002110 O    Lychee                             0.041000   1.000      1.000   from a

  Full comment: from apples

95002120 O    Lychee, dried                      0.041000   1.850      1.000   from a

  Full comment: from apples

14002130 14   Macadamia nut                      0.031000   1.000      1.000   almond

  Full comment: almond field trial

95002140 O    Mamey apple                        0.041000   1.000      1.000   from a

  Full comment: from apples

95002150 O    Mango                              0.041000   1.000      1.000   from a

  Full comment: from apples

95002151 O    Mango-babyfood                     0.041000   1.000      1.000   from a

  Full comment: from apples

95002160 O    Mango, dried                       0.041000   1.000      1.000   from a

  Full comment: from apples

95002170 O    Mango, juice                       0.041000   1.000      1.000   from a

  Full comment: from apples

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

  Full comment: from apples

95002180 O    Maple, sugar                       0.041000   1.000      1.000   from a

  Full comment: from apples

95002190 O    Maple syrup                        0.041000   1.000      1.000   from a

  Full comment: from apples

19012200 19A  Marjoram                           2.140000   1.000      1.000   from m

  Full comment: from mint per ChemSAC

19012201 19A  Marjoram-babyfood                  2.140000   1.000      1.000   from m

  Full comment: from mint per ChemSAC

28002210 M    Meat, game                         0.001500   1.000      1.000   from b

  Full comment: from beef cattle

27002220 D    Milk, fat                          0.003000   1.000      1.000

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

27012230 D    Milk, nonfat solids                0.003000   1.000      1.000

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

27022240 D    Milk, water                        0.003000   1.000      1.000

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

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

15002260 15   Millet, grain                      0.710000   1.000      1.000   from w

  Full comment: from wheat

95002270 O    Mulberry                           0.041000   1.000      1.000   from a

  Full comment: from apples

95002280 O    Mushroom                           0.710000   1.000      1.000   from l

  Full comment: from leafy greens

05022290 5B   Mustard greens                     0.710000   1.000      1.000   from l

  Full comment: from leaf lettuce

12002300 12   Nectarine                          0.098000   1.000      1.000

15002310 15   Oat, bran                          0.710000   2.300      0.070   wheat

  Full comment: wheat and rice bran factor

15002320 15   Oat, flour                         0.710000   1.000      0.070   from w

  Full comment: from wheat

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

  Full comment: from wheat

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

  Full comment: from wheat

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

  Full comment: from wheat

08002340 8    Okra                               0.025000   1.000      1.000   from t

  Full comment: from tomato 1/2 LOD

95002350 O    Olive                              0.041000   1.000      1.000   from a

  Full comment: from apples

95002360 O    Olive, oil                         0.041000   0.005      1.000   from a

  Full comment: from apples +soy oil factor

03002370 3    Onion, dry bulb                    0.050000   1.000      1.000

03002371 3    Onion, dry bulb-babyfood           0.050000   1.000      1.000

03002380 3    Onion, dry bulb, dried             0.050000   9.000      1.000

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

03002390 3    Onion, green                       0.260000   1.000      1.000

10002400 10   Orange                             0.024000   1.000      1.000

10002410 10   Orange, juice                      0.024000   0.700      1.000   O J fa

  Full comment: O J factor

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

  Full comment: O J factor

10002420 10   Orange, peel                       0.024000   2.200      1.000   dried

  Full comment: dried pulp factor

95002430 O    Palm heart, leaves                 2.200000   1.000      1.000   from g

  Full comment: from grass

95002440 O    Palm, oil                          2.200000   0.005      1.000   from g

  Full comment: from grass + soy oil factor

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

  Full comment: from grass + soy oil factor

95002450 O    Papaya                             0.041000   1.000      1.000   from a

  Full comment: from apples

95002451 O    Papaya-babyfood                    0.041000   1.000      1.000   from a

  Full comment: from apples

95002460 O    Papaya, dried                      0.041000   1.800      1.000   from a

  Full comment: from apples

95002470 O    Papaya, juice                      0.041000   1.500      1.000   from a

  Full comment: from apples

04012480 4A   Parsley, leaves                    0.710000   1.000      1.000

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

  Full comment: from mint per ChemSAC

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

  Full comment: from mint per ChemSAC

01012500 1AB  Parsley, turnip rooted             0.330000   1.000      1.000

01012510 1AB  Parsnip                            0.330000   1.000      1.000

01012511 1AB  Parsnip-babyfood                   0.330000   1.000      1.000

95002520 O    Passionfruit                       0.041000   1.000      1.000   from a

  Full comment: from apples

95002521 O    Passionfruit-babyfood              0.041000   1.000      1.000   from a

  Full comment: from apples

95002530 O    Passionfruit, juice                0.041000   1.000      1.000   from a

  Full comment: from apples

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

  Full comment: from apples

95002540 O    Pawpaw                             0.041000   1.000      1.000   from a

  Full comment: from apples

06022550 6B   Pea, succulent                     0.730000   1.000      0.110

06022551 6B   Pea, succulent-babyfood            0.730000   1.000      0.110

06032560 6C   Pea, dry                           0.110000   1.000      1.000

06032561 6C   Pea, dry-babyfood                  0.110000   1.000      1.000

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

06032580 6C   Pea, pigeon, seed                  0.110000   1.000      1.000

06022590 6B   Pea, pigeon, succulent             0.390000   1.000      0.110

12002600 12   Peach                              0.098000   1.000      1.000

12002601 12   Peach-babyfood                     0.098000   1.000      1.000

12002610 12   Peach, dried                       0.098000   7.000      1.000

12002611 12   Peach, dried-babyfood              0.098000   7.000      1.000

12002620 12   Peach, juice                       0.098000   1.000      1.000

12002621 12   Peach, juice-babyfood              0.098000   1.000      1.000

95002630 O    Peanut                             0.080000   1.000      0.420   from p

  Full comment: from potato

95002640 O    Peanut, butter                     0.080000   1.890      0.420   from p

  Full comment: from potato

95002650 O    Peanut, oil                        0.080000   0.005      0.420   from p

  Full comment: from potato + soy oil factor

11002660 11   Pear                               0.041000   1.000      1.000

11002661 11   Pear-babyfood                      0.041000   1.000      1.000

11002670 11   Pear, dried                        0.041000   6.250      1.000   DEEM d

  Full comment: DEEM default proc factor

11002680 11   Pear, juice                        0.041000   1.200      1.000

11002681 11   Pear, juice-babyfood               0.041000   1.200      1.000

14002690 14   Pecan                              0.024000   1.000      1.000   pecan

  Full comment: pecan field trial

08002700 8    Pepper, bell                       0.025000   1.000      1.000   from t

  Full comment: from tomato 1/2 LOD

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

  Full comment: from tomato 1/2 LOD

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

  Full comment: from tomato 1/2 LOD

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

  Full comment: from tomato 1/2 LOD

08002720 8    Pepper, nonbell                    0.025000   1.000      1.000   from t

  Full comment: from tomato 1/2 LOD

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

  Full comment: from tomato 1/2 LOD

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

  Full comment: from tomato 1/2 LOD

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

  Full comment: from mint

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

  Full comment: from mint

95002750 O    Peppermint                         2.140000   1.000      1.000

95002760 O    Peppermint, oil                    2.140000   0.010      1.000

95002770 O    Persimmon                          0.041000   1.000      1.000   from a

  Full comment: from apples

95002780 O    Pine nut                           0.041000   1.000      1.000   from a

  Full comment: from apples

95002790 O    Pineapple                          0.500000   1.000      1.000   from c

  Full comment: from cucurbits

95002791 O    Pineapple-babyfood                 0.500000   1.000      1.000   from c

  Full comment: from cucurbits

95002800 O    Pineapple, dried                   0.500000   5.000      1.000   from c

  Full comment: from cucurbits

95002810 O    Pineapple, juice                   0.500000   1.700      1.000   from c

  Full comment: from cucurbits

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

  Full comment: from cucurbits

14002820 14   Pistachio                          0.031000   1.000      1.000   almond

  Full comment: almond field trial

95002830 O    Plantain                           0.041000   1.000      1.000   from a

  Full comment: from apples

95002840 O    Plantain, dried                    0.041000   3.900      1.000   from a

  Full comment: from apples

12002850 12   Plum                               0.098000   1.000      1.000

12002851 12   Plum-babyfood                      0.098000   1.000      1.000

12002860 12   Plum, prune, fresh                 0.098000   1.000      1.000

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

12002870 12   Plum, prune, dried                 0.098000   5.000      1.000

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

12002880 12   Plum, prune, juice                 0.098000   1.400      1.000

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

95002890 O    Pomegranate                        0.041000   1.000      1.000   from a

  Full comment: from apples

25002900 M    Pork, meat                         0.000700   1.000      1.000

25002901 M    Pork, meat-babyfood                0.000700   1.000      1.000

25002910 M    Pork, skin                         0.006500   1.000      1.000

25002920 M    Pork, meat byproducts              0.006500   1.000      1.000

25002921 M    Pork, meat byproducts-babyfood     0.006500   1.000      1.000

25002930 M    Pork, fat                          0.000300   1.000      1.000

25002931 M    Pork, fat-babyfood                 0.000300   1.000      1.000

25002940 M    Pork, kidney                       0.006500   1.000      1.000

25002950 M    Pork, liver                        0.002800   1.000      1.000

01032960 1C   Potato, chips                      0.080000   1.000      1.000

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

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

01032980 1C   Potato, flour                      0.080000   6.500      1.000

01032981 1C   Potato, flour-babyfood             0.080000   6.500      1.000

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

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

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

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

60003010 P    Poultry, other, meat               0.001000   1.000      1.000

60003020 P    Poultry, other, liver              0.003000   1.000      1.000

60003030 P    Poultry, other, meat byproducts    0.014000   1.000      1.000

60003040 P    Poultry, other, fat                0.001000   1.000      1.000

60003050 P    Poultry, other, skin               0.014000   1.000      1.000

95003060 O    Psyllium, seed                     0.710000   1.000      1.000   from w

  Full comment: from wheat grain

10003070 10   Pummelo                            0.024000   1.000      1.000

09023080 9B   Pumpkin                            0.500000   1.000      1.000

09023090 9B   Pumpkin, seed                      0.500000   1.000      1.000

11003100 11   Quince                             0.041000   1.000      1.000

95003110 O    Quinoa, grain                      0.710000   1.000      1.000   from w

  Full comment: from wheat grain

29003120 M    Rabbit, meat                       0.001500   1.000      1.000   from b

  Full comment: from beef cattle

04013130 4A   Radicchio                          0.710000   1.000      1.000

01013140 1AB  Radish, roots                      0.330000   1.000      1.000

02003150 2    Radish, tops                       1.300000   1.000      1.000

01013160 1AB  Radish, Oriental, roots            0.330000   1.000      1.000

02003170 2    Radish, Oriental, tops             1.300000   1.000      1.000

05023180 5B   Rape greens                        0.710000   1.000      1.000   from l

  Full comment: from leaf lettuce

20003190 20   Rapeseed, oil                      0.034000   0.005      1.000   from s

  Full comment: from soybeans +soy oil factor

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

  Full comment: from soybeans +soy oil factor

13013200 13A  Raspberry                          0.330000   1.000      1.000

13013201 13A  Raspberry-babyfood                 0.330000   1.000      1.000

13013210 13A  Raspberry, juice                   0.330000   1.000      1.000

13013211 13A  Raspberry, juice-babyfood          0.330000   1.000      1.000

04023220 4B   Rhubarb                            0.320000   1.000      1.000   from h

  Full comment: from head lettuce

15003230 15   Rice, white                        1.050000   0.100      1.000

15003231 15   Rice, white-babyfood               1.050000   0.100      1.000

15003240 15   Rice, brown                        1.050000   1.000      1.000

15003241 15   Rice, brown-babyfood               1.050000   1.000      1.000

15003250 15   Rice, flour                        1.050000   0.100      1.000

15003251 15   Rice, flour-babyfood               1.050000   0.100      1.000

15003260 15   Rice, bran                         1.050000   2.300      1.000

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

  Full comment: from wheat

01013270 1AB  Rutabaga                           0.330000   1.000      1.000

15003280 15   Rye, grain                         0.710000   1.000      1.000   from w

  Full comment: from wheat

15003290 15   Rye, flour                         0.710000   1.000      1.000   from w

  Full comment: from wheat

20003300 20   Safflower, oil                     0.034000   0.005      1.000   from s

  Full comment: from soybeans +soy oil factor

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

  Full comment: from soybeans +soy oil factor

01013310 1AB  Salsify, roots                     0.330000   1.000      1.000

02003320 2    Salsify, tops                      1.300000   1.000      1.000

95003330 O    Sapote, Mamey                      0.041000   1.000      1.000   from a

  Full comment: from apples

19013340 19A  Savory                             2.140000   1.000      1.000   from m

  Full comment: from mint per ChemSAC

95003360 O    Sesame, seed                       0.710000   1.000      1.000   from w

  Full comment: from wheat grain

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

  Full comment: from wheat grain

95003370 O    Sesame, oil                        0.710000   0.005      1.000   from w

  Full comment: from wheat grain + soy oil factor

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

  Full comment: from wheat grain + soy oil factor

03003380 3    Shallot                            0.050000   1.000      1.000

26003390 M    Sheep, meat                        0.001500   1.000      1.000   from b

  Full comment: from beef cattle

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

  Full comment: from beef cattle

26003400 M    Sheep, meat byproducts             0.014000   1.000      1.000   from b

  Full comment: from beef cattle

26003410 M    Sheep, fat                         0.000600   1.000      1.000   from b

  Full comment: from beef cattle

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

  Full comment: from beef cattle

26003420 M    Sheep, kidney                      0.014000   1.000      1.000   from b

  Full comment: from beef cattle

26003430 M    Sheep, liver                       0.006000   1.000      1.000   from b

  Full comment: from beef cattle

15003440 15   Sorghum, grain                     1.000000   1.000      0.150   from c

  Full comment: from corn

15003450 15   Sorghum, syrup                     1.000000   1.000      1.000   from c

  Full comment: from corn

95003460 O    Soursop                            0.041000   1.000      1.000   from a

  Full comment: from apples

06003470 6    Soybean, seed                      0.034000   1.000      0.090

06003480 6    Soybean, flour                     0.034000   1.000      0.090

06003481 6    Soybean, flour-babyfood            0.034000   1.000      0.090

06003490 6    Soybean, soy milk                  0.034000   1.000      0.090

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

06003500 6    Soybean, oil                       0.034000   0.005      0.090

06003501 6    Soybean, oil-babyfood              0.034000   0.005      0.090

95003510 O    Spanish lime                       0.041000   1.000      1.000   from a

  Full comment: from apples

95003520 O    Spearmint                          2.140000   1.000      1.000

95003530 O    Spearmint, oil                     2.140000   0.010      1.000

19023540 19B  Spices, other                      2.140000   1.000      1.000   from m

  Full comment: from mint

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

  Full comment: from mint

04013550 4A   Spinach                            0.710000   1.000      1.000

04013551 4A   Spinach-babyfood                   0.710000   1.000      1.000

09023560 9B   Squash, summer                     0.500000   1.000      1.000

09023561 9B   Squash, summer-babyfood            0.500000   1.000      1.000

09023570 9B   Squash, winter                     0.500000   1.000      1.000

09023571 9B   Squash, winter-babyfood            0.500000   1.000      1.000

95003580 O    Starfruit                          0.041000   1.000      1.000   from a

  Full comment: from apples

95003590 O    Strawberry                         0.520000   1.000      0.890   from l

  Full comment: from leafy greens

95003591 O    Strawberry-babyfood                0.520000   1.000      0.890   from l

  Full comment: from leafy greens

95003600 O    Strawberry, juice                  0.520000   1.000      1.000   from l

  Full comment: from leafy greens

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

  Full comment: from leafy greens

95003610 O    Sugar apple                        0.041000   1.000      1.000   from a

  Full comment: from apples

95003630 O    Sugarcane, molasses                2.200000   2.400      0.540   grass

  Full comment: grass + sugar beet molasses factor

95003631 O    Sugarcane, molasses-babyfood       2.200000   2.400      0.540   grass

  Full comment: grass + sugar beet molasses factor

20003640 20   Sunflower, seed                    0.034000   1.000      1.000   from s

  Full comment: from soybeans

20003650 20   Sunflower, oil                     0.034000   0.005      1.000   from s

  Full comment: from soybeans +soy oil factor

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

  Full comment: from soybeans +soy oil factor

01033660 1CD  Sweet potato                       0.330000   1.000      1.000

01033661 1CD  Sweet potato-babyfood              0.330000   1.000      1.000

04023670 4B   Swiss chard                        0.710000   1.000      1.000

95003680 O    Tamarind                           0.041000   1.000      1.000   from p

  Full comment: from peaches (high tree fruit)

10003690 10   Tangerine                          0.024000   1.000      1.000

10003700 10   Tangerine, juice                   0.024000   0.900      1.000   adjust

  Full comment: adjusted OJ factor

01033710 1CD  Tanier, corm                       0.330000   1.000      1.000

95003720 O    Tea, dried                         0.330000   1.000      1.000   from c

  Full comment: from cane berries

95003730 O    Tea, instant                       0.330000   1.000      1.000   from c

  Full comment: from cane berries

08003740 8    Tomatillo                          0.025000   1.000      1.000   from t

  Full comment: from tomato 1/2 LOD

08003750 8    Tomato                             0.025000   1.000      1.000   from t

  Full comment: from tomato 1/2 LOD

08003751 8    Tomato-babyfood                    0.025000   1.000      1.000   from t

  Full comment: from tomato 1/2 LOD

08003760 8    Tomato, paste                      0.025000   3.300      1.000   from t

  Full comment: from tomato 1/2 LOD

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

  Full comment: from tomato 1/2 LOD

08003770 8    Tomato, puree                      0.025000   2.100      1.000   from t

  Full comment: from tomato 1/2 LOD

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

  Full comment: from tomato 1/2 LOD

08003780 8    Tomato, dried                      0.025000  14.300      1.000   from t

  Full comment: from tomato 1/2 LOD

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

  Full comment: from tomato 1/2 LOD

08003790 8    Tomato, juice                      0.025000   1.500      1.000   from t

  Full comment: from tomato 1/2 LOD

95003800 O    Tomato, Tree                       0.041000   1.000      1.000   from a

  Full comment: from apples

15003810 15   Triticale, flour                   0.710000   0.600      1.000   from w

  Full comment: from wheat and wheat flour

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

  Full comment: from wheat and wheat flour

50003820 P    Turkey, meat                       0.001000   1.000      1.000

50003821 P    Turkey, meat-babyfood              0.001000   1.000      1.000

50003830 P    Turkey, liver                      0.003000   1.000      1.000

50003831 P    Turkey, liver-babyfood             0.003000   1.000      1.000

50003840 P    Turkey, meat byproducts            0.014000   1.000      1.000

50003841 P    Turkey, meat byproducts-babyfood   0.014000   1.000      1.000

50003850 P    Turkey, fat                        0.001000   1.000      1.000

50003851 P    Turkey, fat-babyfood               0.001000   1.000      1.000

50003860 P    Turkey, skin                       0.014000   1.000      1.000

50003861 P    Turkey, skin-babyfood              0.014000   1.000      1.000

01033870 1CD  Turmeric                           0.330000   1.000      1.000

01013880 1AB  Turnip, roots                      0.330000   1.000      1.000

05023890 5B   Turnip, greens                     0.710000   1.000      1.000   from l

  Full comment: from leaf lettuce

95003900 O    Vinegar                            0.025000   1.000      1.000   from a

  Full comment: from apples

14003910 14   Walnut                             0.031000   1.000      1.000   almond

  Full comment: almond field trial

86010000 O    Water, direct, all sources         0.031000   1.000      1.000

86020000 O    Water, indirect, all sources       0.031000   1.000      1.000

95003970 O    Water chestnut                     5.000000   1.000      1.000   from w

  Full comment: from water

95003980 O    Watercress                         5.000000   1.000      1.000   from w

  Full comment: from water

09013990 9A   Watermelon                         0.500000   1.000      0.390

09014000 9A   Watermelon, juice                  0.500000   1.000      0.390

15004010 15   Wheat, grain                       0.710000   1.000      0.140

15004011 15   Wheat, grain-babyfood              0.710000   1.000      0.140

15004020 15   Wheat, flour                       0.710000   0.600      0.140

15004021 15   Wheat, flour-babyfood              0.710000   0.600      0.140

15004030 15   Wheat, germ                        0.710000   2.600      0.140

15004040 15   Wheat, bran                        0.710000   2.300      0.140

15004050 15   Wild rice                          1.050000   1.000      1.000

01034060 1CD  Yam, true                          0.330000   1.000      1.000

01034070 1CD  Yam bean                           0.330000   1.000      1.000

Attachment 2. A. Chronic Food Plus Water Output File

U.S. Environmental Protection Agency                                 Ver. 2.00

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

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

                                                     Adjustment factor #2 used.

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

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

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

                    Total exposure by population subgroup

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

                                                    Total Exposure

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

          Population                         mg/kg             Percent of

           Subgroup                       body wt/day             Rfd

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

U.S. Population (total)                     0.002268                32.4%

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

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

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

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

Northeast region                            0.002412                34.5%

Midwest region                              0.002223                31.8%

Southern region                             0.002055                29.4%

Western region                              0.002524                36.1%

Hispanics                                   0.002223                31.8%

Non-hispanic whites                         0.002259                32.3%

Non-hispanic blacks                         0.002107                30.1%

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

All infants (< 1 year)                      0.004462                63.7%

Nursing infants                             0.002129                30.4%

Non-nursing infants                         0.005347                76.4%

Children 1-6  yrs                           0.004777                68.2%

Children 7-12 yrs                           0.002494                35.6%

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

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

Females 13-50 yrs                           0.001953                27.9%

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

Females 13+ (nursing)                       0.002563                36.6%

Males 13-19 yrs                             0.001698                24.3%

Males 20+ yrs                               0.001900                27.1%

Seniors 55+                                 0.002020                28.9%

Children 1-2 yrs                            0.005882                84.0%

Children 3-5 yrs                            0.004517                64.5%

Children 6-12 yrs                           0.002624                37.5%

Youth 13-19 yrs                             0.001616                23.1%

Adults 20-49 yrs                            0.001918                27.4%

Adults 50+ yrs                              0.002009                28.7%

Females 13-49 yrs                           0.001884                26.9%

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

Attachment 2. B. Food Only

U.S. Environmental Protection Agency                                 Ver. 2.00

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

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

                                                     Adjustment factor #2 used.

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

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

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

                    Total exposure by population subgroup

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

                                                    Total Exposure

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

          Population                         mg/kg             Percent of

           Subgroup                       body wt/day             Rfd

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

U.S. Population (total)                     0.001614                23.1%

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

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

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

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

Northeast region                            0.001816                25.9%

Midwest region                              0.001562                22.3%

Southern region                             0.001434                20.5%

Western region                              0.001775                25.4%

Hispanics                                   0.001481                21.2%

Non-hispanic whites                         0.001621                23.2%

Non-hispanic blacks                         0.001486                21.2%

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

All infants (< 1 year)                      0.002320                33.1%

Nursing infants                             0.001334                19.1%

Non-nursing infants                         0.002694                38.5%

Children 1-6  yrs                           0.003864                55.2%

Children 7-12 yrs                           0.001901                27.2%

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

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

Females 13-50 yrs                           0.001321                18.9%

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

Females 13+ (nursing)                       0.001657                23.7%

Males 13-19 yrs                             0.001217                17.4%

Males 20+ yrs                               0.001315                18.8%

Seniors 55+                                 0.001379                19.7%

Children 1-2 yrs                            0.004912                70.2%

Children 3-5 yrs                            0.003609                51.6%

Children 6-12 yrs                           0.001997                28.5%

Youth 13-19 yrs                             0.001144                16.3%

Adults 20-49 yrs                            0.001308                18.7%

Adults 50+ yrs                              0.001367                19.5%

Females 13-49 yrs                           0.001276                18.2%

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

Attachment 2. C..  Water Only

U.S. Environmental Protection Agency                                 Ver. 2.00

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

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

                                                     Adjustment factor #2 used.

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

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

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

                    Total exposure by population subgroup

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

                                                    Total Exposure

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

          Population                         mg/kg             Percent of

           Subgroup                       body wt/day             Rfd

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

U.S. Population (total)                     0.000653                 9.3%

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

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

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

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

Northeast region                            0.000596                 8.5%

Midwest region                              0.000661                 9.4%

Southern region                             0.000621                 8.9%

Western region                              0.000749                10.7%

Hispanics                                   0.000742                10.6%

Non-hispanic whites                         0.000637                 9.1%

Non-hispanic blacks                         0.000620                 8.9%

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

All infants (< 1 year)                      0.002142                30.6%

Nursing infants                             0.000795                11.4%

Non-nursing infants                         0.002654                37.9%

Children 1-6  yrs                           0.000913                13.0%

Children 7-12 yrs                           0.000594                 8.5%

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

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

Females 13-50 yrs                           0.000632                 9.0%

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

Females 13+ (nursing)                       0.000905                12.9%

Males 13-19 yrs                             0.000481                 6.9%

Males 20+ yrs                               0.000585                 8.4%

Seniors 55+                                 0.000641                 9.2%

Children 1-2 yrs                            0.000970                13.9%

Children 3-5 yrs                            0.000908                13.0%

Children 6-12 yrs                           0.000627                 9.0%

Youth 13-19 yrs                             0.000472                 6.7%

Adults 20-49 yrs                            0.000610                 8.7%

Adults 50+ yrs                              0.000642                 9.2%

Females 13-49 yrs                           0.000608                 8.7%

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

Attachment 3.  Sensitivity Analyses A.  All Tree residues removed

U.S. Environmental Protection Agency                                 Ver. 2.00

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

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

                                                     Adjustment factor #2 used.

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

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

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

                    Total exposure by population subgroup

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

                                                    Total Exposure

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

          Population                         mg/kg             Percent of

           Subgroup                       body wt/day             Rfd

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

U.S. Population (total)                     0.002166                30.9%

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

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

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

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

Northeast region                            0.002295                32.8%

Midwest region                              0.002124                30.3%

Southern region                             0.001968                28.1%

Western region                              0.002409                34.4%

Hispanics                                   0.002097                30.0%

Non-hispanic whites                         0.002161                30.9%

Non-hispanic blacks                         0.002012                28.7%

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

All infants (< 1 year)                      0.004093                58.5%

Nursing infants                             0.001907                27.2%

Non-nursing infants                         0.004922                70.3%

Children 1-6  yrs                           0.004433                63.3%

Children 7-12 yrs                           0.002365                33.8%

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

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

Females 13-50 yrs                           0.001880                26.9%

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

Females 13+ (nursing)                       0.002468                35.3%

Males 13-19 yrs                             0.001635                23.4%

Males 20+ yrs                               0.001840                26.3%

Seniors 55+                                 0.001938                27.7%

Children 1-2 yrs                            0.005410                77.3%

Children 3-5 yrs                            0.004217                60.2%

Children 6-12 yrs                           0.002482                35.5%

Youth 13-19 yrs                             0.001552                22.2%

Adults 20-49 yrs                            0.001860                26.6%

Adults 50+ yrs                              0.001930                27.6%

Females 13-49 yrs                           0.001821                26.0%

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

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

U.S. Environmental Protection Agency                                 Ver. 2.00

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

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

                                                     Adjustment factor #2 used.

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

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

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

                    Total exposure by population subgroup

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

                                                    Total Exposure

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

          Population                         mg/kg             Percent of

           Subgroup                       body wt/day             Rfd

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

U.S. Population (total)                     0.001844                26.3%

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

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

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

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

Northeast region                            0.001913                27.3%

Midwest region                              0.001803                25.8%

Southern region                             0.001689                24.1%

Western region                              0.002071                29.6%

Hispanics                                   0.001845                26.4%

Non-hispanic whites                         0.001815                25.9%

Non-hispanic blacks                         0.001729                24.7%

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

All infants (< 1 year)                      0.003580                51.1%

Nursing infants                             0.001713                24.5%

Non-nursing infants                         0.004289                61.3%

Children 1-6  yrs                           0.003157                45.1%

Children 7-12 yrs                           0.001964                28.1%

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

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

Females 13-50 yrs                           0.001665                23.8%

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

Females 13+ (nursing)                       0.002266                32.4%

Males 13-19 yrs                             0.001507                21.5%

Males 20+ yrs                               0.001653                23.6%

Seniors 55+                                 0.001705                24.4%

Children 1-2 yrs                            0.003550                50.7%

Children 3-5 yrs                            0.003089                44.1%

Children 6-12 yrs                           0.002057                29.4%

Youth 13-19 yrs                             0.001399                20.0%

Adults 20-49 yrs                            0.001668                23.8%

Adults 50+ yrs                              0.001702                24.3%

Females 13-49 yrs                           0.001615                23.1%

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

Attachment 4.  Residue Data from IR-4 Field trials

Residue Data for Endothall

Trial ID

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

(days)	Residues (ppm)5,6

ppm	lb ae/A

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

Sugar Beets

Conklin, MI 2007

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

3.5	4.80	0	0.523	0.531

	Roots	5.0	6.77	0	0.199	0.136

3.5	4.80	0	0.120	0.115

Arroyo Grande, CA  2007

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

3.5	4.88	0	1.279	0.948