Page 1 of 56 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 April 19, 2006 MEMORANDUM SUBJECT: Occupational and Residential Exposure Assessment for 2( Thiocyanomethylthio) benzothiazole TCMTB.

From: Siroos Mostaghimi, Ph. D., Senior Scientist Risk Assessment and Science Support Branch ( RASSB) Antimicrobials Division ( 7510C)

To: Mark Hartman, Acting Branch Chief Regulatory Management Branch II Antimicrobials Division ( 7510C)

Through: Norm Cook, Chief Risk Assessment and Science Support Branch ( RASSB) Antimicrobials Division ( 7510C)

Chemical No: 35603 DP Barcode: 322615 Attached please find the Occupational and Residential Exposure Assessment RED Chapter for 2( Thiocyanomethylthio) benzothiazole ( TCMTB). Page 2 of 56 EXECUTIVE SUMMARY This document is the Occupational and Residential Exposure Chapter of the Reregistration Eligibility Decision Document ( RED) for 2( Thiocyanomethylthio) benzothiazole ( TCMTB). It addresses the potential risks to humans that result from the use of this chemical in occupational and residential settings.

TCMTB is the active ingredient in numerous types of products. The products are used in commercial/ institutional premises, residential and public access areas, as material preservatives, industrial processes and water systems, and as wood preservatives ( Use Site Categories III, IV, VII, VIII, and X, respectively). Examples of uses include use in pulp and paper process water, use for sapstain control, and use as a textile preservative. Products containing TCMTB are formulated as liquid ready to use, soluble concentrate, and emulsifiable liquid. The percentage of TCMTB in the various end use products ranges from 1.0% to 60%.

The durations and routes of exposure evaluated in this assessment include short term ( ST), intermediate term ( IT), and in some instances long term ( LT) dermal and inhalation exposures, and ST oral exposures. The ST/ IT/ LT dermal endpoint is 25 mg/ kg/ day ( target MOE = 100 for ST/ IT, 300 for LT), based on a 21 day dermal toxicity study in rats. The adverse effects for this endpoint include decreased body weight gain, hematological changes, and clinical chemistry changes. For oral exposure scenarios, the ST endpoint is 16 mg/ kg/ day ( target MOE = 100), based on a rabbit developmental study in which reduced body weight gain and food consumption was observed. The short and intermediate term inhalation endpoint of 16 mg/ kg/ day ( target MOE = 100 for ST/ IT and MOE= 300 for LT) is also based on the same effects from the rabbit developmental study, as well as on a 90 day rodent study in which increased incidence of histopathology of the stomach was observed, including inflammation, necrosis, and ulceration.

This occupational and residential assessment was based on examination of product labels describing uses for the product. It has been determined that exposure to handlers can occur in a variety of occupational and residential environments. Additionally, post application exposures are likely to occur in these settings. The representative scenarios selected by the Antimicrobials Division ( AD) for assessment were evaluated using maximum application rates as stated on the product labels. The representative scenarios are believed to provide high end estimates of dermal, inhalation, and incidental oral exposure.

To assess most handler risks, AD used surrogate unit exposure data from the Chemical Manufacturers Association ( CMA) antimicrobial exposure study and the Pesticide Handlers Exposure Database ( PHED). Additionally, handler and post application exposures resulting from wood preservation activities were assessed using surrogate data from the proprietary study Measurement and Assessment of Dermal and Inhalation Exposures to Didecyl Dimethyl Ammonium Chloride ( DDAC) Used in the Protection of Cut Lumber ( Phase III) ( Bestari et al., 1999, MRID 455243 04). Because the study is proprietary, data compensation needs to be paid for use of these data in this exposure assessment. Page 3 of 56 Residential Handler Risk Summary For the residential handler dermal and inhalation risk assessment, the dermal MOEs were slightly below the target MOE of 100 for painting with a brush/ roller and are of concern for the airless sprayer. The inhalation MOEs were above the target MOE of 300 for all scenarios. Specifically, the dermal MOEs, which are less than the target MOE include:

  Painting, brush/ roller: ST dermal MOE = 25   Painting, airless sprayer: ST dermal MOE = 10 The total MOES were less than the target MOE of 100 for:

  Painting, brush/ roller: ST dermal MOE = 24.9   Painting, airless sprayer: ST dermal MOE = 9.8 Residential Post Application/ Bystander Risk Summary For the residential post application risk assessment, MOEs are above the respective target MOEs for all scenarios except for the following:

  Dermal exposure to toddlers contacting treated carpets: ST Dermal MOE = 2, ST Oral MOE = 4   Dermal exposure to adults contacting treated clothing: ST Dermal MOE < 1 using 100% transfer factor, ST Dermal MOE = 9 using 5% transfer factor.   Dermal exposure to toddlers contacting treated clothing: ST Dermal MOE < 1 using 100% transfer factor, ST Dermal MOE = 6 using 5% transfer factor.   Incidental oral exposure to toddlers mouthing treated clothing: ST Oral MOE = 21 Occupational Handler Risk Summary For the occupational handler dermal and inhalation risk assessment, the MOEs were above the target MOE of 100 for ST/ IT dermal and inhalation or 300 for LT dermal and inhalation for all scenarios except for the scenarios listed below. Tables 5.2 through 5.6 present the various needs for PPE and/ or metering pumps to mitigate risks for each scenario. It should be noted that the baseline ( ungloved) dermal MOEs for material preservation of paints, textiles, adhesives, and metalworking fluid were calculated using unit exposure values from the cooling tower CMA data set because baseline dermal unit exposures are not available for preservative or metal fluid categories.

  Paint Application   Airless Sprayer: ST/ IT Dermal MOE = 6 ( ungloved) and 17 ( gloved).   Paint Application   Paintbrush: ST/ IT Dermal MOE = 30 ( ungloved) and 97 ( gloved)   Paint Preservation   Liquid Pour: ST/ IT Dermal MOE = 1 ( ungloved)   Paint Preservation   Liquid Pump: ST/ IT Dermal MOE = 26 ( ungloved)   Textile Preservation   Liquid Pour: ST/ IT Dermal MOE = < 1 ( ungloved) Page 4 of 56   Textile Preservation   Liquid Pump: ST/ IT Dermal MOE = 64 ( ungloved)   Cutting Fluid Preservation   Liquid Pour: ST/ IT Dermal MOE = 11 ( ungloved)   Pulp and Paper   Liquid Pump: ST/ IT Dermal MOE = 5 ( ungloved)

The total MOEs were less than the target MOE of 100 for the following exposure scenarios:

  Paint Application   Airless Sprayer: MOE = 16   Paint Application   Paintbrush: MOE = 95 Occupational Post Application/ Bystander Risk Summary For the occupational post application risk assessment, the MOEs were above their respective target MOEs, and therefore not of concern for all scenarios.

Data Limitations and Uncertainties:

There are a number of uncertainties associated with this assessment. The data limitations and uncertainties associated with the residential handler and post application exposure assessments include the following:

  Surrogate dermal and inhalation unit exposure values were taken from the proprietary Chemical Manufacturers Association ( CMA) antimicrobial exposure study ( USEPA, 1999: DP Barcode D247642) or from the Pesticide Handler Exposure Database ( USEPA, 1998) ( See Appendix B for summaries of these data sources). Most of the CMA data are of poor quality; therefore, AD requests that confirmatory monitoring data be generated to support the values used in these assessments.

  The quantities handled/ treated were estimated based on information from various sources, including HED's Standard Operating Procedures ( SOPs) for Residential Exposure Assessments ( USEPA 2000 and 2001). In certain cases, no standard values were available for some scenarios. Assumptions for these scenarios were based on AD estimates and could be further refined from input from registrants.

The data limitations and uncertainties associated with the occupational handler and post application exposure assessments include:

  Surrogate dermal and inhalation unit exposure values were taken from the proprietary Chemical Manufacturers Association ( CMA) antimicrobial exposure study ( USEPA, 1999: DP Barcode D247642) or from the Pesticide Handler Exposure Database ( USEPA, 1998) ( See Appendix B for summaries of these data sources). Since the CMA data are of poor quality, the Agency requests that confirmatory data be submitted to support the occupational scenarios assessed in this document. Page 5 of 56   Unit exposures are not available for some of the specific scenarios that are prescribed for TCMTB. These scenarios include the following: open loading into oil well/ field environments and metering into cooling water systems at power plants.

  For the wood preservative treatment scenarios, DDAC exposure data were used for the lack of TCMTB specific exposure data. Limitations and uncertainties associated with the use of these data include:   The assumption was made that exposure patterns for workers at treatment facilities using DDAC would be similar to exposure patterns for workers at treatment facilities using TCMTB, and therefore the exposures could be used as surrogate data for workers that treat wood with TCMTB.

  For environmental modeling, it was assumed that the leaching process from the TCMTB treated wood would be similar to that of DDAC. However, due to the lack of real data for TCMTB treated wood, it is not possible to verify this assumption.

  The quantities handled/ treated were estimated based on information from various sources, including HED's Standard Operating Procedures ( SOPs) for Residential Exposure Assessments ( USEPA 2000, and 2001), and personal communication with experts. In particular, the use information for the pulp and paper processing, oil well uses, and cooling water tower uses are based on personal communication with biocide manufacturers for these types of uses. The individuals contacted have experience in these operations and their estimates are believed to be the best available without undertaking a statistical survey of the uses. In certain cases, no standard values were available for some scenarios. Assumptions for these scenarios were based on AD estimates and could be further refined from input from registrants. For example, the quantities handled/ treated for the application of TCMTB to the surface of metal/ wood cooling towers could be refined.

More detailed discussions of the uncertainties and limitations can be found in Sections 4.2.3 ( residential) and 5.3 ( occupational). Page 6 of 56 1.0 INTRODUCTION 1.1 Purpose In this document, the Antimicrobials Division ( AD) presents the results of its review of the potential human health effects of occupational and residential exposure to TCMTB. This information is for use in EPA's development of the TCMTB Re registration Eligibility Decision ( RED) Document.

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

In this document, handler scenarios were assessed by using unit exposure data to estimate occupational and residential handlers' exposures. Unit exposures are estimates of the amount of exposure to an active ingredient a handler receives while performing various handler tasks and are expressed in terms of micrograms or milligrams ( 1 mg = 1,000 µ g) of active ingredient per pounds of active ingredient handled. A series of unit exposures have been developed that are unique for each scenario typically considered in assessments ( i. e., there are different unit exposures for different types of application equipment, job functions, and levels of protection). The unit exposure concept has been established in the scientific literature and also through various exposure monitoring guidelines published by the USEPA and international organizations such as Health Canada and OECD ( Organization for Economic Cooperation and Development).

Using surrogate unit exposure data, maximum application rates from labels, and EPA estimates of daily amount handled, exposures and risks to handlers were assessed. The exposure/ risks were calculated using the following equations:

Daily Exposure: Daily dermal or inhalation handler exposures are estimated for each applicable handler task with the application rate, quantity treated/ handled in a day, and the applicable dermal or inhalation unit exposure using the following formula:

Daily Exposure: E = UE x AR x AT ( Eq. 1)

Where: E = Amount ( mg ai/ day) deposited on the surface of the skin that is available for dermal absorption or amount inhaled that is available for inhalation absorption; UE = Unit exposure value ( mg ai/ lb ai) derived from August 1998 PHED data or from 1992 CMA data; AR = Maximum application rate based on a logical unit treatment, such as acres ( A), square feet ( sq. ft.), gallons ( gal), or cubic feet ( cu. ft). Maximum values are generally used ( lb ai/ A, lb ai/ sq ft, lb ai/ gal, lb ai/ cu ft); and Page 7 of 56 AT = Normalized application area based on a logical unit treatment such as acres ( A/ day), square feet ( sq ft/ day), gallons ( gal/ day), or cubic feet ( cu ft/ day).

Daily Dose: The daily dermal or inhalation dose is calculated by normalizing the daily exposure by body weight and adjusting, if necessary, with an appropriate absorption factor. Daily dose was calculated using the following formula:

Daily Dose: ADD = E x ABS ( Eq. 2) BW Where: ADD = Average daily dose or the absorbed dose received from exposure to a chemical in a given scenario ( mg active ingredient/ kg body weight/ day); E = Amount ( mg ai/ day) deposited on the surface of the skin that is available for dermal absorption or amount inhaled that is available for inhalation absorption; ABS = A measure of the amount of chemical that crosses a biological boundary such as lungs (% of the total available absorbed); and BW = Body weight determined to represent the population of interest in a risk assessment ( kg).

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

Margins of Exposure: MOE = NOAEL or LOAEL ( Eq. 3) ADD Where: MOE = Margin of exposure, value used to represent risk or how close a chemical exposure is to being a concern ( unitless); NOAEL or LOAEL = Dose level in a toxicity study, where no observed adverse effects ( NOAEL) or where the lowest observed adverse effects ( LOAEL) occurred in the study; and ADD = Average daily dose or the absorbed dose received from exposure to a chemical in a given scenario ( mg ai/ kg body weight/ day).

In addition to the target MOEs presented in Table 3.2 that were used for the analysis, a series of assumptions and exposure factors served as the basis for completing the handler risk assessment. Each general assumption and factor for both residential and occupational assessments is detailed below. Assumptions specific to the use site category are listed in each separate section of this document. The general assumptions and factors include:

  TCMTB products are widely used and have a large number of use patterns that are difficult to completely capture in this document. As such, AD has patterned this risk assessment on a series of likely representative scenarios for each use site that are believed by AD to represent the vast majority of TCMTB uses.

  Exposure factors used to calculate daily exposures to handlers were based on applicable data, if available. When appropriate data were lacking, values from a scenario deemed similar were used.

  The maximum application rates allowed by labels were assumed. Page 8 of 56 1.3 Chemical Identification Table 1.1 Chemical Information for TCMTB Common Name: 2( Thiocyanomethylthio) benzothiazole ( TCMTB)

Chemical Name: 2( Benzothiazolylthio) methyl thiocyanate Other Names: TCMB CAS Number: 21564 17 0 OPP Chemical Code: 035603 Case Number: 2625 Empirical Formula: C9H6N2S3 Molecular Structure:

1.4 Physical/ Chemical Properties Table 1.4 shows physical/ chemical characteristics that have been reported for TCMTB. Table 1.2. Physical/ Chemical Properties of TCMTB1 Parameter TCMTB Molecular Weight 238.4 Melting Point 150 E C Water Solubility 42 mg/ L at 25 E C Vapor Pressure 3.1x10 7 mm Hg at 25 E C 1 Melting point, water solubility, and vapor pressure estimated using PBT Profiler, a screening level tool ( USEPA, 2004).

2.0 USE INFORMATION 2.1 Formulation Types and Percent Active Ingredient The products containing TCMTB as the active ingredient ( a. i.) are formulated as liquid ready to use, soluble concentrate, emulsifiable concentrate, and wettable powder. Concentrations of TCMTB in these products range from 1.0% to 60%.

2.2 Summary of Use Pattern and Formulations Page 9 of 56 The Agency determines potential exposures to handlers of the product by identifying exposure scenarios from the various application methods that are plausible, given the label uses. These scenarios are identified in Appendix A. Based on a review of product labels, TCMTB is the active ingredient in products used in the following use site categories: III ( Commercial, institutional and industrial premises and equipment), IV ( Residential and public access premises), VII ( Material Preservation), VIII ( Industrial processes and water systems), and X ( Wood preservatives).

From the scenarios in Appendix A ( Master TCMTB Label List), AD selected representative exposure scenarios to assess the labeled uses of TCMTB in this document. These scenarios were selected to be representative of the vast majority of uses and are believed to provide high end degrees of dermal, inhalation, or incidental ingestion exposure. The representative scenarios assessed in this document are shown in Table 4.1 ( residential) and Table 5.1 ( occupational).

3.0 SUMMARY OF TOXICITY DATA 3.1 Acute Toxicity The acute toxicity values for TCMTB are presented in Table 3.1.

Table 3.1. Acute Toxicity of TCMTB Guideline No. Study Type MRID #( s) Results Toxicity Category 81 1 Acute Oral 41583801 LD50 = 750 mg/ kg III 81 2 Acute Dermal 41515401 LD50 > 2000 mg/ kg III 81 3 Acute Inhalation 41640601 LC50 = 0.07 mg/ L I 81 4 Primary Eye Irritation No acceptable studies; all show corrosivity I 81 5 Primary Skin Irritation 41583701 Severe erythema at 72 hrs. II 81 6 Dermal Sensitization 111991 Positive Sensitizer 3.2 Summary of Toxicity Endpoints Table 3.2 summarizes the toxicological endpoints for TCMTB. Page 10 of 56 Table 3.2. Summary of Toxicity Endpoints Selected for TCMTB Exposure Scenario Dose Used in Risk Assessment ( mg/ kg/ day) Target MOEs/ UFs FQPA safety factor for Risk Assessment Study and Toxicological Effects Acute Dietary ( general population including infants and children) NOAEL( maternal) = 25.1 mg/ kg/ day Target MOE = 100 UF = 100 ( 10x inter species extrapolation, 10x intra species variation)

FQPA SF = 1x Acute PAD = 0.25 mg/ kg/ day Developmental Toxicity Study in Rats ( accession no. 260491)

LOAEL( maternal) = 76.5 mg / kg/ day, based on clinical signs of toxicity ( ventral alopecia, rough coat, dyspnea/ wheezing, oral discharge, diarrhea/ loose stool, urine staining, piloerection, and hunched gait).

Acute Dietary ( females 13 49) An endpoint for females 13 49 was not identified in the available database for TCMTB. This risk assessment is not required.

Chronic Dietary ( all populations) LOAEL = 3.8 mg/ kg/ day Target MOE = 300 UF = 100 ( 10x inter species extrapolation, 10x intra species variation) DB UF = 3 ( 3x for use of a LOAEL)

FQPA SF = 1x Chronic PAD = 0.013 mg/ kg/ day Chronic Toxicity Study in Dogs ( MRID 41342201)

LOAEL = 3.8 mg/ kg/ day ( males), based on decreased body weight gain, decreased white cells, monocytes, and plasma ALT in males; decreased plasma ALT and uterine weight in females.

Incidental Oral Short and Intermediate Term ( 1 30 days; 30 days 6 months) NOAEL= 16 mg/ kg/ day Target MOE = 100 UF = 100 ( 10x inter species extrapolation, 10x intra species variation)

FQPA SF = 1x Developmental Toxicity Study in Rabbits ( MRID 40075102)

LOAEL = 32 mg/ kg/ day, based on decreased body weight gain and food consumption in maternal animals.

Dermal All Durations ( 1 30 days; 1 6 months; > 6 months) NOAEL= 25 mg/ kg/ day Target MOE = 100 ( ST and IT)

Target MOE = 300 ( LT)

UF = 100 ( 10x inter species extrapolation, 10x intra species variation)

DB UF = 3 ( 3x for use of a subchronic endpoint)

FQPA SF = 1x 21 Day Dermal Toxicity Study in Rats ( MRID 41655801)

LOAEL = 100 mg/ kg/ day, based on decreased body weight gain, food consumption, and hematological and clinical chemistry changes.

Inhalation NOAEL = 16 mg/ kg/ day Target MOE = 100 ( ST and IT) Developmental Toxicity Study in Rabbits Page 11 of 56 Short and Intermediate Term ( 1 30 days; 1 6 months) UF = 100 ( 10x inter species extrapolation, 10x intra species variation)

Note: an additional 10x is necessary for route extrapolation. If results are below a MOE of 1,000, a confirmatory inhalation study may be required ( MRID 40075102)

LOAEL = 32 mg/ kg/ day, based on decreased body weight gain and food consumption in maternal animals Inhalation Long Term (> 6 months) LOAEL = 3.8 mg/ kg/ day Target MOE = 300 ( LT)

UF = 100 ( 10x inter species extrapolation, 10x intra species variation)

Note: an additional 10x is necessary for route extrapolation. If results are below a MOE of 1,000, a confirmatory inhalation study may be required Chronic Toxicity Study in Dogs ( MRID 41342201)

LOAEL = 3.8 mg/ kg/ day ( males), based on decreased body weight gain, decreased white cells, monocytes, and plasma ALT in males; decreased plasma ALT and uterine weight in females.

Carcinogenicity The CPRC concluded that TCMTB should be classified as Group C  possible human carcinogen  and recommended that for the purpose of risk characterization, the Reference Dose ( RfD) approach should be used for quantitation of human risk. This was based on statistically significant increases in tumors in both sexes of the Sprague Dawley rat: testicular interstitial cell adenomas in males and thyroid c cell adenomas in females.

UF = uncertainty factor, FQPA SF = special FQPA safety factor, NOAEL = no observed adverse effect level, LOAEL = lowest observed adverse effect level, PAD = population adjusted dose ( a = acute, c = chronic), RfD = reference dose, MOE = margin of exposure, LOC = Level of concern, NA = Not Applicable.

4.0 RESIDENTIAL EXPOSURE ASSESSMENT 4.1 Summary of Registered Uses Products containing TCMTB can be used in paints as a preservative. Residents may also be exposed to items that have been treated with TCMTB in occupational settings, such as dimensional lumber for decks and play sets, and treated textiles. Appendix A presents a summary of all exposure scenarios that may occur in residential settings based on examination of product labels. Table 4.1 identifies the representative exposure scenarios assessed in this document.

4.2 Residential Exposure The exposure scenarios assessed in this document for the representative uses selected by AD are shown in Table 4.1. The table also shows the maximum application rate associated with the representative use and the EPA registration number for the corresponding product label. Handler exposures were assessed for the application of TCMTB preserved paint. Page 12 of 56 Post application exposures were assessed for dermal and/ or oral contact with treated surfaces ( textiles and lumber).

Table 4.1. Representative Uses Associated with Residential Exposure Representative Use Application Method( s) Exposure Scenario Registration # Application Rate Paint   Airless sprayer   Paintbrush / Roller ST Handler: adult dermal and inhalation 1448 55 0.015 a. i. weight fraction in preserved paint [( 5% product) x ( 30% ai)] Carpets   NA1 ST Post app: child incidental ingestion and dermal 1448 55 0.006 a. i. weight fraction in preserved carpet [( 2% product) x ( 30% ai)] Wearing treated clothing   NA1 ST Post app: child incidental ingestion and dermal 1448 55 0.006 a. i. weight fraction in preserved clothing [( 2% product) x ( 30% ai)] Contacting Preserved Wood   NA1 ST Post app: child incidental ingestion and dermal 1448 55 0.003 a. i. weight fraction in preserved wood [( 1% product) x ( 30% ai)] 1 The handler scenarios were not assessed because application of TCMTB to carpets, textiles, and wood can only be performed by occupational handlers.

4.2.1 Residential Handler Exposures The residential handler scenarios described in Table 4.1 were assessed to determine dermal and inhalation exposures. The scenarios were assessed using PHED data and Equations 1 3 in Section 1.2, " Criteria for Conducting Risk Assessment." A summary of the PHED data set is presented in Appendix B.

Unit Exposure Values: Unit exposure values were taken from the PHED data presented in HED's Residential SOPs ( USEPA, 2000).

  For the airless sprayer scenario, PHED dermal and inhalation unit exposure values for a residential handler applying a pesticide using an airless sprayer were used. These unit ungloved exposure values ( 79 mg/ lb a. i. for dermal and 0.83 mg/ lb a. i. for inhalation) represent a handler wearing short pants and a short sleeve shirt, with no gloves.

  For the brush/ roller scenario, PHED dermal and inhalation unit exposure values for a residential handler applying a pesticide using an airless sprayer were used. These unit exposure values ( 230 mg/ lb a. i. for dermal and 0.284 mg/ lb a. i. for inhalation) represent a handler wearing short pants and a short sleeve shirt, with no gloves.

Quantity handled/ treated: The quantities handled/ treated were estimated based on information from various sources.

  For the airless sprayer in paint applications, it is assumed that 15 gallons ( or 150 lb/ day, assuming paint has a density of 10 lb/ gal) of treated paint will be used per day. Page 13 of 56   For the brush/ roller in paint applications, it is assumed that 2 gallons ( or 20 lb/ day, assuming paint has a density of 10 lb/ gal) of treated paint will be used per day.

Duration of Exposure: The duration of exposure for most homeowner applications of paint is believed to be best represented by the short term duration ( 1 to 30 days). The reason that short term duration was chosen to be assessed is because the different handler and post application scenarios are assumed to be episodic, not daily. In addition, homeowners are assumed to use different products with varying activities, not exclusively TCMTB treated products.

Results The resulting short term exposures and MOEs for the representative residential handler scenarios are presented in Table 4.2. The calculated dermal MOEs were below the target MOE of 100 for both scenarios ( 10 for airless sprayer and 25 for paintbrush). The inhalation MOEs were above the target MOE of 300.

The short term dermal MOEs for the paintbrush and airless spray scenarios are below the short term dermal target MOE of 100. The total MOEs were less than the Target MOE of 100.

Table 4.2 Short Term Residential Handlers Exposures and MOEs Unit Exposure ( mg/ lb a. i.) Absorbed Daily Dose ( mg/ kg/ day) e ST MOE f Exposure Scenario Application Ratea Quantity Handled/ Treated per dayb Dermalc Inhalationd Dermal Inhalation Dermal ( Target MOE= 100) Inhalation ( Target = 100) Total MOE ( Target MOE= 100)

Painting   Airless Sprayer 0.015 a. i. weight fraction 150 lb/ day 79 0.83 2.54 0.0267 10 600 9.8 Painting  Paintbrush/ Roller 0.015 a. i. weight fraction 20 lb/ day 230 0.284 0.986 0.00122 25 13,000 24.9 a Application rates are the maximum application rates determined from EPA registered labels for TCMTB. b Amount handled per day values are estimates. c All dermal unit exposures represent ungloved, short sleeve shirt, and short pants replicates. d No respirator used by exposed individual. e Absorbed Daily dose ( mg/ kg/ day) = [ unit exposure ( mg/ lb a. i.) * application rate ( a. i. weight fraction) * quantity treated ( lb/ day)]/ Body weight ( 70 kg). f MOE = NOAEL / Absorbed Daily Dose. [ Where short term dermal NOAEL = 25 mg/ kg/ day and short term inhalation NOAEL = 16 mg/ kg/ day]. Target MOE is 100 for dermal and inhalation.

4.2.2 Residential Post application Exposures For the purposes of this screening level assessment, post application scenarios have been developed that encompass multiple products, but still represent a high end exposure scenario for all products represented. As shown in Table 4.1, representative post application scenarios assessed include crawling on carpets, and wearing treated clothing ( dermal exposure to adults and children and incidental oral exposure to children). Page 14 of 56 <IP_ADDRESS> Treated Carpets Dermal Exposure to Toddlers from Treated Carpets Exposure Calculations There is the potential for dermal exposure to toddlers crawling on carpets preserved with TCMTB. Short term risks have been presented, as the preservative is applied only during the manufacturing of the carpet.

Potential doses are calculated as follows:

PDD = C x SA x TR ( Eq. 4) BW Where:

PDD = potential daily dose ( mg/ kg/ day); C = concentration on carpet ( mg/ m2); SA = surface area of skin that contacts the treated carpet ( m2/ day); TR = transferable residue from carpet to skin (%); and BW = body weight ( kg).

And C = WFai x W x CF1 x CF2 ( Eq. 5)

Where:

C = concentration on carpet ( mg/ m2); WFai = weight fraction of a. i. in treated carpet ( unitless); W = face weight of carpet ( oz/ yd2); CF1 = unit conversion factor ( 28,349 mg/ oz); and CF2 = unit conversion factor ( 1.196 yd2/ m2).

Assumptions   The product is applied at a rate of 0.006 a. i. weight fraction to the carpet.

  The face weight of the carpet is assumed to weigh 35 oz/ yd2 ( the face weight only includes the carpet fibers, not the backing materials). The face weight is a conservative value as the child will most likely only be exposed to the top portion of the carpet fibers ( Doityourself. com, 2005).

  Toddlers ( 3 years old) were used to represent the 1 to 6 year old age group. A body surface area of 0.657 m2 and a body weight of 15 kg were assumed, which are the median values for 3 year olds ( USEPA, 1997). Page 15 of 56   No transferable residue data were available that could be used to estimate the transfer of TCMTB from the carpet to skin under dry conditions. Therefore, it is assumed that 5% of the residue on the treated carpet is available for dermal transfer ( USEPA, 2000 and 2001).

Results The calculation of the dermal dose and MOE are shown in Table 4.3. The dermal MOE is below the target MOE of 100.

Table 4.3: Dermal Post Application Exposures and MOEs for Toddlers Contacting Treated Carpets WFai ( fraction a. i. in carpet) W ( face weight of carpet) ( oz/ yd2) C ( Conc.) a ( mg/ m2) SA ( Surface Area exposed) ( m2/ day) TR ( transferable residue) PDDb ( mg/ kg/ day) ST Dermal MOEc 0.006 35.0 7,120 0.657 5% 15.6 2 a. Concentration on carpet ( mg/ cm2) = ( fraction a. i. in treated carpet) * ( face weight of carpet, oz/ yd2) * ( 28,349 mg/ oz) * ( 1.196 yd2/ m2) b . Absorbed Potential Daily Dose ( mg/ kg/ day) = [( concentration on carpet, mg/ m2) * ( surface area of skin in contact with carpet, m2/ day) * ( transferable residue from carpet to skin)] / ( body weight, kg). c. Dermal MOE = NOAEL ( mg/ kg/ day) / Absorbed Potential Daily Dose ( mg/ kg/ day) [ Where short term dermal NOAEL is 25 mg/ kg/ day]. Target MOE = 100.

Child Incidental Ingestion Exposure to Treated Carpets Exposure Calculations In addition to dermal exposure, toddlers crawling on treated carpets will also be exposed to TCMTB residues via incidental oral exposure through hand to mouth activity. To calculate incidental ingestion exposure to these chemicals due to hand to mouth transfer, the methodologies established in the Standard Operating Procedures ( SOPs) for Residential Exposure Assessments ( USEPA, 2000 and 2001) were used. The assumptions used are similar to those used in calculating dermal exposures for toddlers crawling on treated carpets.

Potential doses are calculated as follows:

PDD = C x SA x ET x D x SE x EF ( Eq. 6) BW Where:

PDD = potential daily dose ( mg/ kg/ day); C = concentration on carpet ( mg/ cm2); SA = surface area of the hands mouthed ( cm2/ event); ET = exposure time ( hours/ day); D = fraction dislodgeable ( unitless); SE = saliva extraction efficiency (%); EF = exposure frequency ( events/ hr); and BW = body weight ( kg). Page 16 of 56 And C = WFai x W x CF1 x CF2 ( Eq. 7)

Where:

C = concentration on carpet ( mg/ cm2); WFai = weight fraction of a. i. in treated carpet ( unitless); W = face weight of carpet ( oz/ yd2); CF1 = unit conversion factor ( 28,349 mg/ oz); and CF2 = unit conversion factor ( 0.00012 yd2/ cm2).

Assumptions   The product is applied at a rate of 0.006 a. i. weight fraction to the carpet.   The face weight of the carpet is assumed to weigh 35 oz/ yd2 ( the face weight only includes the carpet fibers, not the backing materials). The face weight is a conservative value as the child will most likely only be exposed to the top portion of the carpet fibers. ( Doityourself. com, 2005)   Toddlers ( 3 years old) were used to represent the 1 to 6 year old age group and are assumed to weigh 15 kg, the median for male and female toddlers ( USEPA, 1997).   Based on HED's Residential SOP, it was assumed that the surface area used for each hand to mouth event is 20 cm2 ( USEPA, 2000 and 2001).   An exposure time of 8 hours was used, based on the total amount of time spent indoors for young children and subtracting the amount of time spent sleeping, eating, and bathing ( USEPA, 2000 and 2001).   The saliva extraction efficiency was 50% ( USEPA, 2000 and 2001).   The exposure frequency was assumed to be 20 events/ hour ( USEPA, 2000 and 2001).

Results The calculation of the oral doses and MOEs are shown in Table 4.4. The oral MOE of 5 is below the target MOE of 100.

Table 4.4: Incidental Oral Post application Exposures and MOEs for Toddlers Contacting Treated Carpets C ( Concentration of a. i. in carpet) a ( mg/ cm2) SA ( Surface Area exposed) ( cm2/ event) ET ( Exposure Time) ( hrs/ day) D ( Fraction Dislodgeable) SE ( Saliva Extraction Efficiency) EF ( Exposure Frequency) ( events/ hr) PDDb ( mg/ kg/ day) ST Oral MOEc 0.714 20.0 8.00 5% 50% 20.0 3.81 4 a. Concentration on carpet ( mg/ cm2) = ( fraction a. i. in treated carpet) * ( face weight of carpet, oz/ yd2) * 28,349 mg/ oz * 0.00012 yd2/ cm2 b. Potential Daily Dose ( mg/ kg/ day) = [( concentration on carpet, mg/ cm2) * ( fraction dislodgeable) * ( exposure time, hrs/ day) Page 17 of 56 * ( surface area of hand, cm2/ event) * ( exposure frequency, events/ hr) * ( saliva extraction efficiency)]/( body weight, kg) c Oral MOE = NOAEL ( mg/ kg/ day) / Potential Daily Dose( mg/ kg/ day) [ Where short term incidental oral NOAEL = 16 mg/ kg/ day]. Target MOE = 100.

<IP_ADDRESS> Textiles Dermal Exposure to Adults and Toddlers from Contacting Treated Clothing There is the potential for dermal exposure to adults and children from wearing clothing treated via factory impregnation of the chemical as a preservative. A post application assessment assuming no laundering was conducted as a conservative measure ( i. e., the effect on dislodgeable residues over time during washing is not quantifiable). It should be noted that it was assumed that not all articles of clothing are treated with the TCMTB products or worn on a continuous basis; therefore, only short term duration exposures were assessed for the clothing scenarios. It is believed that most treated textiles used in a residential setting will result in exposures occurring over a short term time duration ( 1 to 30 days) because residents are assumed to be exposed to treated textiles with varying active ingredients, not exclusively TCMTB treated textiles.

Exposure Calculations Potential doses are calculated as follows:

PDD = W x WFai x CF x TF ( Eq. 8) BW Where:

PDD = potential daily dose ( mg/ kg/ day); W = weight of clothing work ( g/ day); WFai = percent active ingredient in clothing (%); TF = percent transfer; CF = conversion factor ( 1000 mg/ µ g); and BW = body weight ( kg).

And W = ( SW/ SSA) * BSA ( Eq. 9)

Where:

W = weight of clothing worn ( g/ day); SW = weight of medium shirt ( g); SSA = surface area of medium shirt ( cm2); and BSA = surface area of body covered ( cm2).

Assumptions   The product is applied at a rate of 0.006 a. i. weight fraction to the clothing. Page 18 of 56   The median surface area of clothing contacting skin for a 3 year old toddler is 5,670 cm2 ( total body surface area minus the head) ( USEPA, 1997). For adults, the median surface area is 16,900 cm2 ( total body surface area minus the head) ( USEPA, 1997).

  The clothing is assumed to be medium weight. For an adult, a cotton polo shirt has a mass of approximately 250 g, and the surface area covered by the shirt is assumed to be 0.659 m2. The density of the fabric is therefore 379 g/ cm2. It is assumed that the type of fabric used in the polo shirt is used to cover the rest of the body for both adults and toddlers, minus the head. Therefore, the total amount of fabric worn per day is equal to the density of the fabric ( 379 g/ cm2) times the surface area covered ( 5,670 cm2 for toddlers, 16,900 cm2 for adults), or 215 g/ day for toddlers, and 641 g/ day for adults.

  Potential doses were calculated using a conservative percent transfer of 100%, which assumes that all residues are transferable from clothing surfaces to the skin. In cases where the MOEs did not meet the Agency's target MOE, potential doses were also calculated using a less conservative percent transfer of 5%, which is based on the amount of residue assumed to be transferable from carpeted surfaces ( USEPA, 2000 and 2001). In these cases, confirmatory data are needed to support the use of the lower transfer factor.

  Toddlers ( 3 years old) are assumed to weigh 15 kg. This is the mean of the median values for male and female toddlers ( USEPA, 1997). For adults, a body weight of 70 kg has been assumed. ( USEPA, 1997).

  It is assumed that not all articles of clothing are treated with TCMTB products or worn on a continuous basis; therefore, only short term duration exposures are expected.

Results The calculations of the short term dermal doses and MOEs for adults and toddlers wearing treated clothing are shown in Table 4.5. The dermal MOEs for adults and toddlers are below the target MOE of 100. Page 19 of 56 a. Weight of clothing worn ( g/ day) = ( Density of shirt 379 g/ cm2) * ( surface area of body covered, cm2) * 1 outfit/ day b. Absorbed Potential Daily Dose ( mg/ kg/ day) = [( weight of clothing worn, g/ day) * ( weight fraction a. i. in treated clothing) * ( percent transfer) * ( conversion factor, 1000 mg/ g)] / ( body weight, kg). c. Dermal MOE = NOAEL ( mg/ kg/ day) / Absorbed Potential Daily Dose [ Where short term dermal NOAEL = 25 mg/ kg/ day]. Target MOE = 100.

Incidental Oral Exposure to Toddlers Mouthing Treated Textiles ( Clothing/ Blankets)

Exposure Calculations There is the potential for incidental oral exposure to toddlers from mouthing textiles treated with TCMTB.

Potential doses are calculated as follows:

PDD = C x SE x SA ( Eq. 10) BW Where:

PDD = potential daily dose ( mg/ kg/ day); C = concentration on clothing ( mg/ cm2); SE = saliva extraction efficiency (%); SA = surface area mouthed ( cm2/ day); and BW = body weight ( kg).

And C = WFai x W x CF1 x CF2 ( Eq. 11)

Where:

C = concentration on clothing ( mg/ cm2); WFai = weight fraction of a. i. in clothing ( unitless); W = weight of clothing ( g/ m2); CF1 = unit conversion factor ( 1,000 mg/ g); and CF2 = unit conversion factor ( 0.0001 m2/ cm2). Table 4.5: Dermal Post application Exposures and MOEs for Toddlers and Adults Contacting Treated Clothing Exposure Scenario W ( weight of clothing worn per day) a ( g/ day) WF ( fraction a. i. in clothing) TF ( percent transfer) PDD ( mg/ kg/ day) b ST Dermal MOEc 100% 86.0 < 1 Toddler 215 0.006 5% 4.30 6 100% 55.0 < 1 Adult 641 0.006 5% 2.70 9 Page 20 of 56 Assumptions   The product is applied at a rate of 0.006 a. i. weight fraction to the carpet.

  The clothing is assumed to be medium weight. For an adult, a cotton polo shirt has a mass of approximately 250 g, and the surface area covered by the shirt is assumed to be 0.659 m2. The density of the fabric is therefore 379 g/ cm2.

  The saliva extraction efficiency was 50% ( USEPA, 2000 and 2001).

  The surface area of textiles mouthed by toddlers is 100 cm2 ( HERA, 2005).

  Toddlers ( 3 years old) are used to represent the 1 to 6 year old age group. For three year olds, the median body weight is 15 kg ( USEPA, 1997).

Results Table 4.6 shows the calculation of the oral dose and oral MOE for toddlers mouthing treated textiles. The MOE value is below the target MOE of 100.

Table 4.6: Incidental Oral Exposures and MOEs for Toddlers Wearing Treated Textiles ( Clothing/ Blankets)

Weight of clothing ( g/ m2) Concentration on clothinga ( mg/ cm2) Surface area mouthed ( cm2/ day) Saliva extraction efficiency Potential daily dose ( mg a. i./ kg/ day) Incidental Oral MOEc 379 0.2274 100 50% 0.758 21 a. Concentration on clothing ( mg/ cm2) = ( Weight fraction a. i. in clothing, 0.006) * ( weight of clothing, g/ cm2) * ( 1,000 mg/ g) * ( 0.0001 m2/ cm2) b. Potential Daily Dose ( mg/ kg/ day) = ( concentration on clothing, mg/ cm2) * ( surface area mouthed, cm2/ day) * ( saliva extraction efficiency) / ( body weight, kg). c Oral MOE = NOAEL ( mg/ kg/ day) / Potential Daily Dose [ Where short term incidental oral NOAEL = 16 mg/ kg/ day]. Target MOE = 100.

4.2.3 Data Limitations/ Uncertainties There are several data limitations and uncertainties associated with the residential handler and post application exposure assessments. These include the following:

  Surrogate dermal and inhalation unit exposure values were taken from the proprietary Chemical Manufacturers Association ( CMA) antimicrobial exposure study ( USEPA, 1999: DP Barcode D247642) or from the Pesticide Handler Exposure Database ( USEPA, 1998) ( See Appendix B for summaries of these data sources). Most of the CMA data are of poor quality, therefore, AD requests that confirmatory monitoring data be generated to support the values used in these assessments.

  The quantities handled/ treated were estimated based on information from various sources, including HED's Standard Operating Procedures ( SOPs) for Residential Exposure Assessments ( USEPA 2000, and 2001). In certain cases, no standard values were Page 21 of 56 available for some scenarios. Assumptions for these scenarios were based on AD estimates and could be further refined from input from registrants.

5.0 OCCUPATIONAL EXPOSURE ASSESSMENT The exposure scenarios assessed in this document for the representative uses selected by AD are shown in Table 5.1. The table also shows the maximum application rate associated with the representative use and the appropriate EPA Registration number for the product label. Appendix A ( Master List of TCMTB Products) presents a summary of all exposure scenarios that may occur in occupational settings based on examination of product labels.

Potential occupational handler exposure can occur in various use sites, which include: commercial/ institutional premises, and industrial processes and water systems. Additionally, occupational exposure can occur during the preservation of wood. For the preservation of wood, the procedure for treatment can occur in different ways, such that multiple worker functions were analyzed. Due to the complexity of the wood preservative analysis, the results for handler and post application exposures are presented in a separate section ( Section 5.3).

Table 5.1. Representative Exposure Scenarios Associated with Occupational Exposures to TCMTB Representative Use Method of Application Exposure Scenario Registration # Application Rate Commercial/ Institutional Premises ( III) Paint Application   Airless Sprayer   Paintbrush / Roller ST/ IT Handler: Dermal and Inhalation 1448 55 1.5% a. i. by weight [( 5% Product) x ( 30% ai)]

Material Preservation ( VII) Paint Preservation   Liquid Pour   Liquid Pump ST/ IT Handler: Dermal and inhalation 1448 99 1.5% a. i. by weight [( 15% Product) x ( 10% ai)]

Textile Preservation   Liquid pour   Liquid pump ST/ IT Handler: Dermal and inhalation 1448 55 0.6% a. i. by weight [( 2% product) x ( 30% ai)]

Metal Working Fluid preservation   Liquid pour   Liquid pump ST/ IT/ LT Handler: Dermal and inhalation ST and IT/ LT Machinist: dermal and inhalation 1448 265 0.125% a. i. by weight [( 1250 ppm a. i.) / 1,000,000]

Industrial processes and water systems ( Use Category VIII) Page 22 of 56 Table 5.1. Representative Exposure Scenarios Associated with Occupational Exposures to TCMTB Representative Use Method of Application Exposure Scenario Registration # Application Rate Drilling Fluida   Liquid Pour ST/ IT Handler: Dermal and Inhalation 1448 99 0.075% a. i. by weight [( 0.75% Product) x ( 10% ai)]

Pulp and Paper   Metered pump ST/ IT Handler: Dermal and Inhalation 1448 386 0.075% a. i. by weight [( 30 lbs prod/ ton paper) x ( 5% ai) / 2,000 lb/ ton] Small process water systems   Liquid Pour   Metered Pump ST/ IT Handler: Dermal and Inhalation 1448 55 ( for use in wastewater systems) 9.00x10 4 % a. i. by weight [( 30 ppm Product) x ( 30% ai) / 1,000,000]

Wood Preservation ( Use Category X) Non pressure treatment of wood and wood products in wood treatment facilities Handler Worker Functions   Diptank Operators   Blender/ spra y operators   Chemical operators Post Application Worker Functions   Graders   Trim saw operators   Clean up crews   Construction Workers ST/ IT/ LT Handler: inhalation ST/ IT/ LT Post applicat ion: dermal and inhalation 1448 55 0.3% a. i. by weight [( 1% product) x ( 30% ai)]

a There are no representative unit exposures data for chemical metering ( i. e. liquid pump) into secondary recovery oil operations. Since the volume of water being treated in secondary recovery oil operations is so large, the available CMA data can not be reliably extrapolated. This is because CMA data are based on activities that handle much lower volumes and possibly different techniques.

5.1 Occupational Handler Exposures The occupational handler scenarios included in Table 5.1 were assessed to determine inhalation exposures. The general assumptions and equations that were used to calculate occupational handler inhalation risks are provided in Section 1.2, Criteria for Conducting the Risk Assessment. The majority of the scenarios were assessed using CMA data and Equations 1 3. However, for the occupational scenarios in which CMA data were insufficient, other data and methods were applied. Page 23 of 56 Unit Exposure Values ( UE): Inhalation unit exposure values were taken from the proprietary Chemical Manufacturers Association ( CMA) antimicrobial exposure study ( USEPA, 1999b: DP Barcode D247642) or from the Pesticide Handler Exposure Database ( USEPA, 1998).

$ For the liquid pour scenarios, the unit exposure depends on the material being treated. The following CMA unit exposures were available and used for the following scenarios:   Paint preservation, textile preservation, drilling fluids: CMA preservative data ( gloved). The dermal UE is 0.135 mg/ lb a. i. and the inhalation unit exposure is 0.00346 mg/ lb a. i. and is based on 2 replicates. Although this unit exposure is based on minimal replicates, the exposure value is similar to the one found in PHED for a similar scenarios. Since no baseline dermal ( ungloved) unit exposure data are available for preservative uses in adhesives, paint, or textiles, the baseline dermal exposures were evaluated using the cooling tower CMA data ( 50.3 mg/ lb ai).

  Metal working fluid: CMA metal fluid gloved data. The dermal UE is 0.184 mg/ lb a. i. and the inhalation UE is 0.00854 mg/ lb a. i.. The values are based on 8 replicates where the test subjects were wearing a single layer of clothing and chemical resistant gloves. Since no baseline dermal ( ungloved) unit exposure data are available for metal working fluid, the baseline dermal exposures were evaluated using the cooling tower CMA data ( 50.3 mg/ lb ai).

  Small process water systems: CMA cooling tower data ( gloved and ungloved). The dermal and inhalation unit exposures are 10.1 and 0.450 mg/ lb a. i., respectively, based on 5 replicates. The ungloved dermal unit exposure value is 50.3 mg/ lb ai.

$ For the liquid/ metering pump scenarios, the unit exposure depends on the material being treated. The following CMA unit exposures were available and used for the following scenarios:   Metal working fluid: CMA metal fluid gloved data. The dermal UE is 0.312 mg/ lb a. i. and the inhalation UE is 0.00348 mg/ lb a. i. The values are based on 2 replicates where the test subjects were wearing a single layer of clothing and chemical resistant gloves. Since no baseline dermal ( ungloved) unit exposure data are available for metal working fluid, the baseline dermal exposures were evaluated using the cooling tower CMA data ( 0.454 mg/ lb ai).

  Pulp and paper, cooling water systems: CMA pulp and paper gloved data were used. The dermal and inhalation unit exposures are 0.000454 mg/ lb ai and 0.000265 mg/ lb a. i., respectively. These values are based on 7 replicates where the test subjects were wearing a single layer of clothing and chemical resistant gloves. These unit exposures were used for the once through cooling water system because no representative data exists for the volume of water treated in power plant facilities. Since no baseline dermal ( ungloved) unit exposure data are available for metal working fluid, the baseline dermal exposures were evaluated using the cooling tower CMA data ( 0.454 mg/ lb ai).   Paint preservation and textile preservation: CMA preservative gloved data. The dermal UE is 0.00629 mg/ lb a. i. and the inhalation UE is 0.000403 mg/ lb a. i. Page 24 of 56 The values are based on two replicates where the test subjects were wearing a single layer of clothing and chemical resistant gloves. Since no baseline dermal ( ungloved) unit exposure data are available for preservative uses in adhesives, paint, or textiles, the baseline dermal exposures were evaluated using the cooling tower CMA data ( 0.454 mg/ lb ai).

  Small process water systems: CMA cooling tower data. The dermal UE is 0.086 and the inhalation UE is 0.00432 mg/ lb a. i., based on 4 replicates. Since no baseline dermal ( ungloved) unit exposure data are available for preservative uses in adhesives, paint, or textiles, the baseline dermal exposures were evaluated using the cooling tower CMA data ( 0.454 mg/ lb ai).

$ For airless sprayer scenarios, the occupational PHED dermal and inhalation unit exposure values for airless sprayer application ( PHED scenario 23) were used. The dermal and inhalation exposure values are 38 mg/ lb a. i. and 0.83 mg/ lb a. i., respectively.

$ For the brush/ roller scenario, the occupational PHED dermal and inhalation unit exposure values for paintbrush applications were used ( single layer of clothing). The dermal and inhalation exposure values are 79 mg/ lb a. i. and 0.28 mg/ lb a. i., respectively.

Quantity handled/ treated: The quantity handled/ treated values were estimated based on information from various sources. The following assumptions were made:

  For the roller/ brush painting scenario, it was assumed that 50 lbs ( approximately 5 gallons of paint with a density of 10 lb/ gal) of treated paint are used.

  For the airless sprayer in the painting scenario, it was assumed that 500 lbs ( approximately 50 gallons of paint with a density of 10 lb/ gal) of treated paint are used.

  For the liquid pour scenarios, the quantity of the chemical that is handled depends on the material that is being treated. The following values were used for the different materials:

  Paint: 2,000 lbs ( approximately 200 gallons, weight based on a density 10 lb a. i./ gal).

  Textiles: 10,000 lbs   Metal working fluid: 2,502 lbs ( approximately 300 gallons, based on the density of water, 8.34 lb a. i./ gal)

  Drilling fluids: The following use information was used to estimate the amount of ai handled per day during oil well activities. Biocide is typically added directly to drilling rig mud tanks via open pouring. Over a 3 to 6 week period, while a 13,000 ft well is being drilled, 1 to 2 drums ( 1 drum = 42 gallons) of biocide may be used if microbiological problems are encountered. Therefore, the short term exposure assessment used 5.6 gallons for the amount of biocide handled per day by the drilling rig worker [ i. e., ( 2 drums x 42 gal/ drum) / ( 5 days/ week x 3 weeks) = 5.6 gal/ day]. Since Product # 1448 99 has a density of 8.2 lbs/ gal, this Page 25 of 56 corresponds to 45.9 lb/ day. The intermediate term exposure assessment used 2.8 gallons ( 22.9 lb/ day) for the amount of biocide handled per day by the drilling rig worker [ i. e., ( 2 drums x 42 gal/ drum) / ( 5 days/ week x 6 weeks) = 2.8 gal/ day]. Although crew changes may occur in drilling rig operations, typically a designated customer representative is responsible for the biocide feeding. Therefore, one person would be involved with the biocide application activities on a daily basis.

  Small process water systems: Workers in small systems are assumed to manually pour 5 to 10 gallons of biocide into the system, but larger systems would utilize chemical pumps in order to save time and labor expense. Therefore, AD assumed that workers handle 10 gallons of biocide per day when making open pour applications ( or 90 lb/ day, assuming a density of 9 lb/ gal for the product).

$ For the liquid/ metering pump scenarios the quantity that is handled depends on the material that is being treated. The following values were used for the different materials:   Paint: 10,000 lbs ( approximately 1,000 gallons, weight based on a density of 10 lb a. i./ gal)

  Textiles: 10,000 lbs   Metal working fluid: 2,502 lbs ( approximately 300 gallons, based on the density of water, 8.34 lb a. i./ gal)

  Pulp and Paper: 500 tons of paper produced/ day ( 1,000,000 lbs/ day)

  Small process water systems: AD has assumed that 20,000 gallons of water are treated daily when chemical pump applications are made ( or 180,000 lb/ day, assuming the product has a density of 9 lb/ gal).

Duration of Exposure: The MOEs were calculated for the short and intermediate term durations for occupational handlers using the appropriate endpoints in Table 3.2.

Exposure Calculations and Results The resulting inhalation exposures and MOEs for the representative occupational handler scenarios are presented in Tables 5.2 and 5.3. The calculated MOEs as well as total MOEs were above the corresponding target MOEs for all scenarios, except those listed below.

Dermal MOES:

  Paint Application   Airless Sprayer: ST/ IT Dermal MOE = 6 ( ungloved) and 17 ( gloved).   Paint Application   Paintbrush: ST/ IT Dermal MOE = 30 ( ungloved) and 97 ( gloved)   Paint Preservation   Liquid Pour: ST/ IT Dermal MOE = 1 ( ungloved)   Paint Preservation   Liquid Pump: ST/ IT Dermal MOE = 26 ( ungloved)   Textile Preservation   Liquid Pour: ST/ IT Dermal MOE = < 1 ( ungloved)   Textile Preservation   Liquid Pump: ST/ IT Dermal MOE = 64 ( ungloved) Page 26 of 56   Metal working fluid Preservation   Liquid Pour: ST/ IT Dermal MOE = 11 ( ungloved)   Pulp and Paper   Liquid Pump: ST/ IT Dermal MOE = 5 ( ungloved)

Total MOES:

  Paint Application   Airless Sprayer: MOE = 16   Paint Application   Paintbrush: MOE = 95 Page 27 of 56 Table 5.2 Short and Intermediate Term Risks Associated with Occupational Handlers Unit Exposure ( mg/ lb a. i.) Absorbed Daily Dose ( mg/ kg/ day) c MOE d Exposure Scenario Method of Application Baseline Dermala PPEGloves Dermalb Inhalation Application Rate (% a. i.

by weight) Quantity Handled/

Treated per day Baseline Dermala PPE Gloves Dermalb Inhalation Baseline Dermal ( Target MOE =

100) a PPE Glove Dermal ( Target MOE =

100) b Inhalation ( Target MOE =

100) Total MOE ( Target MOE= 100)

Airless Sprayer 38.0 14.0 0.830 0.015 a. i.

weight fraction 500 lb/ day 4.07 1.50 0.0889 6 17 180 16 Paint Application Paintbrush 79.0 24.0 0.280 0.015 a. i.

weight fraction 50 lb/ day 0.846 0.257 0.00300 30 97 5,300 95 Liquid Pour 50.3 0.135 0.00346 0.015 a. i.

weight fraction 2,000 lb/ day 21.6 0.0579 0.00149 1 430 11,000 414 Paint Preservation Liquid Pump 0.454 0.00629 4.03x10 4 0.015 a. i.

weight fraction 10,000 lb/ day 0.973 0.0135 0.000863 26 1900 19,000 1727 Liquid Pour 50.3 0.135 0.00346 0.006 a. i.

weight fraction 10,000 lb/ day 43.1 0.116 0.00297 < 1 220 5.400 211 Textiles Liquid Pump 0.454 0.00629 4.03x10 4 0.006 a. i.

weight fraction 10,000 lb/ day 0.389 0.00539 3.46x10 4 64 4,600 46,000 4182 Liquid Pour 50.3 0.184 0.00854 0.00125 a. i.

weight fraction 2,502 lb/ day 2.24 0.00821 3.81x10 4 11 3,000 42,000 2800 Metal Working Fluid Liquid Pump 0.454 0.312 0.00348 0.00125 a. i.

weight fraction 2,502 lb/ day 0.0203 0.0139 1.56x10 4 1,200 1,800 1.00x105 1768 Drilling Fluids Liquid Pour 50.3 0.135 0.00346 0.00075 a. i.

weight fraction ST = 45.9 lb/ day ST = 0.0247 ST = 6.64x10 5 ST = 1.70x10 6 ST = 1000 ST = 380,000 ST = 9.4x106 365235 Drilling Fluids Liquid Pour 50.3 0.135 0.00346 0.00075 a. i.

weight fraction IT = 22.9 lb/ day IT = 0.0123 IT = 3.31x10 5 IT = 8.49x10 7 IT = 2,000 IT = 7.60x105 IT = 1.9x107 730769 Pulp and Paper Liquid Pump 0.454 0.00454 2.65x10 4 0.00075 a. i.

weight fraction 1,000,000 lb/ day 4.86 0.0486 0.00284 5 510 5,600 467 Small Process Water Systems Liquid Pour 50.3 10.1 0.450 0.000009 a. i. weight fraction 90 lb/ day 0.0006 0.000117 5.21x10 6 43,000 21,000 3.1x106 20858 Page 28 of 56 Table 5.2 Short and Intermediate Term Risks Associated with Occupational Handlers Unit Exposure ( mg/ lb a. i.) Absorbed Daily Dose ( mg/ kg/ day) c MOEd Exposure Scenario Method of Application Baseline Dermala PPEGloves Dermal b Inhalation Application Rate (% a. i.

by weight) Quantity Handled/

Treated per day Baseline Dermala PPE Gloves Dermalb Inhalation Baseline Dermal ( Target MOE =

100) a PPE Glove Dermal ( Target MOE =

100) b Inhalation ( Target MOE =

100) Total MOE ( Target MOE= 100)

Small Process Water Systems Liquid Pump 0.454 0.0860 0.00432 0.000009 a. i. weight fraction 180,000 lb/ day 0.0105 0.00199 0.0001 2,400 13,000 1.6x105 12023 ST = short term; IT = intermediate term a Baseline Dermal: Long sleeve shirt, long pants, no gloves.

b PPE Dermal with gloves: baseline dermal plus chemical resistant gloves.

c Absorbed Daily dose ( mg/ kg/ day) = [ unit exposure ( mg/ lb a. i.) * application rate * quantity treated / Body weight ( 70 kg).

d MOE = NOAEL ( mg/ kg/ day) / Absorbed Daily Dose [ Where ST/ IT NOAEL = 25 mg/ kg/ day for dermal and 16 mg/ kg/ day for inhalation]. Page 29 of 56 5.2 Occupational Post application Exposures 5.2.1 Metal Working Fluids: Machinist There is a potential for dermal and inhalation exposure when a worker handles treated metal working fluids. This route of exposure occurs after the chemical has been incorporated into the metal working fluid and a machinist is using/ handling this treated end product.

Dermal Exposures Exposure Calculations A short term and an intermediate and long term exposure estimate were derived using the 2 hand immersion model from ChemSTEER. The model is available at www. epa. gov/ opptintr/ exposure/ docs/ chemsteer. htm. The 2 hand immersion equation is as follows:

PDR = SA x F a. i. x FT x FQ ( Eq. 15) BW Where:

PDR = Potential dose rate ( mg/ kg/ day); SA = Surface area of both hands ( cm2/ event); F a. i. = Fraction active ingredient in treated metal working fluid ( unitless); FT = Film thickness of metal fluid on hands ( mg/ cm2); FQ = Frequency of events ( event/ day); and BW = Body weight ( kg).

Assumptions   The surface of area of both hands is 840 cm2 ( USEPA, 1997).

  The body weight of an adult is 70 kg ( USEPA, 1997).

  The fraction of active ingredient in treated metal working fluid is 0.00125.

  For short, intermediate and long term durations, the film thickness on the hands is 1.75 mg/ cm2, which was extracted from the document titled, " A Laboratory Method to Determine the Retention of Liquids on the Surface of Hands." The film thickness is based on a machinist immersing both hands in metal working fluid and then partially cleaning hands with a rag. The film thickness was chosen because the dermal endpoint for short, intermediate and long term durations is based on systemic effects. Page 30 of 56 Inhalation Exposures Exposure Calculations A screening level intermediate and long term inhalation exposure estimate for treated metal working fluids has been developed using the OSHA PEL for oil mist. The equation used for calculating the inhalation dose is:

PDR = PEL x IR x F a. i. x ED ( Eq. 16) BW Where:

PDR = Potential dose rate ( mg/ kg/ day); PEL = OSHA PEL ( mg/ m3); IR = Inhalation rate ( m3 / hr); F a. i. = Fraction active ingredient in treated metal working fluid ( unitless); ED = Exposure duration ( hrs/ day); and BW = Body weight ( kg).

Assumptions   The high end oil mist concentration is based on OSHA's Permissible Exposure Limit ( PEL) of 5 mg/ m3 ( NIOSH, 1998).   The fraction active ingredient in treated metal working fluid is 0.00125.   The inhalation rate for a machinist is 1.0 m3 / hr.   A machinist is exposed to the metal working fluid 8 hours a day, for 5 days a week.   The body weight of an adult is 70 kg ( US EPA 1997).

Dermal and Inhalation Results Table 5.3 shows the calculation of the absorbed daily doses and MOEs for a machinist working with metal working fluids. The dermal and inhalation MOE values as well as total MOEs are above the target MOEs for all durations. Page 31 of 56 Table 5.3. Short, Intermediate, and Long Term Risks Associated with Post application Exposure to Metal Working Fluids treated with Preservative ( Machinist)

Dermal Inputs Inhalation Inputs Absorbed Daily Dose ( mg/ kg/ day) MOE Dermal MOE ( Target MOE = 100 for ST/ IT, 300 for LT) c Inhalation MOE ( Target MOE = 100 for ST/ IT and 300 for LT) d Total MOE Weight Fraction a. i. in Fluid Hand Surface Area ( cm2) Film thickness ( mg/ cm2) Frequency ( event/ day) OSHA PEL ( mg/ m3) Inhal. rate ( m3/ hr) Exposure Duration ( hrs/ day) Dermala Inhalationb ST/ IT/ LT ST/ IT LT ST/ IT MOE= 10 0 LT MOE= 300 0.00125 840 1.75 1 5 1 8 0.0263 0.000714 950 22,000 5300 910 806 a Absorbed Dermal Daily Dose ( mg/ kg/ day) = [ fraction a. i. in treated fluid * hand surface area* film thickness ( mg/ cm2)* Frequency ( event/ day)] / Body weight ( 70 kg). b Absorbed Inhalation Daily Dose ( mg/ kg/ day) = fraction a. i. in treated fluid * OSHA PEL ( mg/ m3) * Inhalation rate ( m3/ hr) * exposure duration ( hr/ day) / body weight ( 70 kg) c Dermal MOE = NOAEL ( mg/ kg/ day) / Absorbed Daily Dose ( mg/ kg/ day) [ Where: ST/ IT/ LT dermal NOAEL = 25 mg/ kg/ day]. d Inhalation MOE = NOAEL ( mg/ kg/ day) / Absorbed Daily Dose ( mg/ kg/ day) [ Where: ST/ IT inhalation NOAEL = 16 mg/ kg/ day and LT Inhalation NOAEL = 3.8 mg/ kg/ day].

5.2.2 Wood Preservation TCMTB is used in products that are intended to preserve wood through non pressure treatment methods. It can be applied as a sapstain control to freshly cut wood, incorporated into particle board, or used to treat wood chips. When used as a sapstain control, the product may be dipped, sprayed, or impregnated into the wood via pressure treatment ( up to 0.3% a. i. solution). When used in particle board, the pesticide is incorporated into the resin or binding agent ( 0.3% a. i., based on dry weight of wood).

The proprietary study, " Measurement and Assessment of Dermal and Inhalation Exposures to Didecyl Dimethyl Ammonium Chloride ( DDAC) Used in the Protection of Cut Lumber ( Phase III)" ( Bestari et al., 1999, MRID 455243 04) identified various worker functions/ positions for individuals that handle DDAC containing wood preservatives for non pressure treatment application methods and for individuals that could then come into contact with the preserved wood. The worker functions/ positions identified in the DDAC study are presented below. It was assumed that similar tasks are performed when handling TCMTB products and TCMTB treated wood, therefore, these same functions were assessed for TCMTB.

Handler:   Blender/ spray operators are workers that add the wood preservative into a blender/ sprayer system for composite wood via closed liquid pumping.

  Diptank Operators can be in reference to wood being lowered into the treating solution through an automated process ( i. e., elevator diptank, forklift diptank). This scenario can also occur in a smaller scale treatment facility in which the worker can manually dip the wood into the treatment solution. Page 32 of 56   Chemical operators for a spray box system consist of chemical operators, chemical assistants, chemical supervisors, and chemical captains. These individuals maintain a chemical supply balance along with flushing and cleaning spray nozzles.

Post application:   Graders, positioned right after the spray box, grade dry lumber by hand ( i. e. detect faults). In the DDAC study, graders graded wet lumber; therefore, the exposures to graders using TCMTB are worst case scenarios.

  Millwrights repair all conveyer chains and general up keep of the mill.

  Clean up crews perform general cleaning duties at the mill.

  Trim saw operators operate the hula trim saw and consist of operators and strappers. In the DDAC study, hula trim saw operators handled dry lumber.

  Construction workers install treated plywood, oriented strand board, medium density fiberboard, and others.

As very little chemical specific data were available regarding typical exposures to TCMTB as a wood preservative, surrogate data were used to estimate exposure risks. The blender/ spray operator position was assessed using CMA unit exposure data and the remaining handler and post application positions were assessed using data from the DDAC study ( Bestari et al., 1999). This study is proprietary; therefore, data compensation needs to be paid for use of these data in this exposure assessment.

Blender/ Spray Operators Exposures and risks to the composite wood blender/ spray operators were assessed using Equations 1 through 3 in Section 1.2. The surrogate unit exposures were taken from the CMA study ( USEPA, 1999). Specifically, the liquid pump preservative unit exposures for gloved workers were used in this assessment. The dermal unit exposure was 0.00629 mg/ lb ai and the inhalation unit exposure was 0.000403 mg/ lb ai. These values are based on two replicates where the test subjects were wearing a single layer of clothing and chemical resistant gloves. The quantity of the wood being treated was derived from other wood preservative estimates ( USEPA, 2004) for the amount of wood slurry treated because no chemical specific data were available for TCMTB. It was assumed that batches of wood slurry are treated in 10,000 gallon tanks, and that eight batches of wood slurry are treated per day ( one per hour for an 8 hr work shift). Additionally, it was assumed that each batch requires 3,000 gallons of preservatives and the remainder volume of the tank consists of wood slurry ( 7,000 gallons of wood slurry per batch). Since wood chips have a density of approximately 380 kg/ m3 ( SIMetric, 2005), the total amount of wood slurry treated per day would be 178,000 lbs ( 8 batches/ day * 7,000 gallons/ batch * 0.003785 m3/ gallon * 380 kg/ m3 * 2.2 lb/ kg). The assumptions used for batch sizes and the quantity of preservative needed are consistent with an assessment performed previously by the EPA. For this assessment, an application rate of 0.003 TCMTB w/ w was used. Page 33 of 56 Table 5.4 provides the short and intermediate term doses and MOEs for the workers adding the preservative to the wood slurry. All MOEs are above the target MOE of 100 for ST/ IT dermal and inhalation and above 300 for LT dermal and inhalation exposures.

Table 5.4. Short, Intermediate, and Long term Exposures and MOEs for Wood Preservative Blender/ Spray Operators Absorbed Daily Dosee ( mg/ kg/ day) MOEf Dermal Inhalation Total MOE Dermal Unit Exposurea ( mg/ lb ai) Inhalation Unit Exposureb ( mg/ lb ai) App. Rate c ( fraction ai in solution/

day) Wood Slurry Treatedd ( lb/ day) Dermal Inhal. ST/ IT/ LT ST/ IT LT ST/ IT LT Occupational Handler 0.00629 4.03x10 4 0.00300 1.78x105 0.0480 0.0030 7 520 5200 1200 478 364 ST = Short term duration; IT = Intermediate term duration; and LT = long term. a. Dermal unit exposure: Single layer clothing with chemical resistant gloves. b. Inhalation unit exposure: Baseline. c. The maximum application rate for the " immersion" application method is a solution containing 0.3% a. i. d. Wood slurry treated = ( 8 batches/ day * 7,000 gallons/ batch * 0.003785 m3/ gallon * 380 kg/ m3 * 2.2 lb/ kg) e. Absorbed Daily Dose = unit exposure ( mg/ lb ai) x App Rate ( fraction ai/ day) x Quantity treated ( lb/ day) / BW ( 70 kg) f. MOE = NOAEL ( mg/ kg/ day)/ Daily dose [ Where dermal ST/ IT/ LT NOAEL = 25 mg/ kg/ day, ST/ IT inhalation NOAEL = 16 mg/ kg/ day, and LT inhalation NOAEL = 3.8 mg/ kg/ day]. Target MOE is 100 for ST/ IT dermal exposures and 300 for LT dermal and 100 for ST/ IT and 300 for LT inhalation exposures.

Chemical Operators, Graders, Millwrights, Clean up Crews, and Trim Saw Operators Exposures to chemical operators, graders, millwrights, trim saw operators, and clean up crews were assessed using surrogate data from the DDAC study ( Bestari et al., 1999). The DDAC study examined individuals =

exposure to DDAC while working with antisapstains and performing routine tasks at 11 sawmills/ planar mills in Canada. Dermal and inhalation exposure monitoring data were gathered for each job function of interest using dosimeters and personal sampling tubes. Dosimeters and personal air sampling tubes were analyzed for DDAC. Exposure data for individuals performing the same job functions were averaged together to determine job specific averages. Monitoring was conducted using 2 trim saw workers, 13 grader workers, 11 chemical operators, 3 millwrights, and 6 clean up staff.

The individual dermal and inhalation exposures from the DDAC study are presented in Table C 1 in Appendix C. To determine TCMTB exposures, the average DDAC exposures measured on individuals ( in terms of total mg DDAC) were multiplied by a modification factor of 0.00375 to account for the difference in percent active ingredient between TCMTB and DDAC ( 3% TCMTB in the wood preservative product versus 80% DDAC in the comparative wood preservative product). The lb ai handled by each person or the % ai in the treatment solution were not provided for these worker functions.

The following equation was used to calculate daily dose for TCMTB:

Daily Dose = DDAC UE x CR x AB ( Eq. 17) BW Page 34 of 56 Where:

DDAC UE = DDAC dermal or inhalation unit exposure ( mg/ day); CR = Conversion ratio ( 3% TCMTB / 80% DDAC); AB = Absorption factor ( 100% for dermal and inhalation); and BW = Body weight ( 70 kg).

In using this methodology, the following assumptions were made:

  DDAC and TCMTB end use products will be used in similar quantities.

  The procedures for applying both chemicals are similar.

  The limits of detections ( LOD) for inhalation residues from chemical operators, graders, mill wrights, and clean up staff replicates were not provided in the DDAC report. For lack of better data, it was assumed that the inhalation LODs for these worker positions are equal to the LOD of the diptank operator replicates ( 5.6 Fg). For all measurements below the air concentration associated with this detection limit, half the detection limit was used. The dermal LOD for all operators is also 5.6 Fg.

  In the DDAC study, dermal exposures to hands were measured separately from the rest of the body. For each replicate, the body dose measurements and hand dose measurements were summed for a total dermal dose.

  Air concentrations were reported in the DDAC study. To convert air concentrations ( Fg/ m3) into terms of inhalation unit exposure ( mg/ day), the air concentrations were multiplied by an inhalation rate of 1.0 m3/ hr for light activity ( EPA 1997), a sample duration of 8 hrs/ day, and a conversion factor of 1 mg/ 1000 µ g. Table C 1 in Appendix C presents the inhalation and dermal DDAC exposures.

  Average DDAC dermal and inhalation exposures were multiplied by a conversion ratio of 0.00375 to account for the differences in TCMTB and DDAC concentrations [( 3% TCMTB / 80% DDAC)].

Table 5.5 provides the short, intermediate, and long term doses and MOEs for chemical operators, graders, millwrights, clean up crews, and trim saw operators. For all worker functions, the inhalation MOEs are above the corresponding target MOEs for ST/ IT/ LT durations, and therefore are not of concern. For all worker functions, the dermal MOEs are above the target MOE of 100 for ST/ IT/ LT durations. The total MOEs were also above the target MOEs for all durations. Page 35 of 56 Table 5.5. Short, Intermediate and Long Term Exposures and MOEs for Wood Preservative Chemical Operators, Graders, Trim Saw Operators, and Clean Up Crews Absorbed Daily Dosesd ( mg/ kg/ day) MOEse Dermal Inhalation Total MOE Exposure Scenarioa ( number of volunteers) Dermal UEb ( mg/ day) Inhalation UEb ( mg/ day) Conversion Ratioc Dermal Inhalation ST/ IT/ LT ST/ IT LT ST/ IT LT Occupational Handler Chemical Operator ( n= 11) 9.81 0.0281 0.00375 5.25x10 4 1.50x10 6 48,000 1.10x107 2.50x106 47790 47095 Occupational Post application Grader ( n= 13) 3.13 0.0295 0.00375 1.68x10 4 1.58x10 6 1.50x105 1.00x107 2.40x106 147783 141176 Trim Saw ( n= 2) 1.38 0.0610 0.00375 7.39x10 5 3.24x10 6 3.40x105 4.90x106 1.20x106 317940 264935 Millwright ( n= 3) 12.8 0.0570 0.00375 6.86x10 4 3.05x10 6 36,000 5.20x106 1.20x106 35752 34951 Clean Up ( n= 6) 55.3 0.600 0.00375 0.00296 3.24x10 5 8,400 4.90x105 1.20x105 8258 7850 ST = Short term duration; IT = Intermediate term duration; and LT = long term a. The exposure scenario represents a worker wearing short sleeve shirts, cotton work trousers, and cotton glove dosimeter gloves under chemical resistant gloves. Volunteers were grouped according to tasks they conducted at the mill.

b. Dermal and inhalation unit exposures are from Bestari et al ( 1999). Refer to Table C 1 in Appendix C for the calculation of the dermal and inhalation exposures. Inhalation exposure ( mg/ day)

was calculated using the following equation: air concentration ( Fg/ m3) x inhalation rate ( 1.0 m3/ hr) x sample duration ( 8 hr/ day) x unit conversion ( 1 mg/ 1000 Fg). The inhalation rate is from USEPA, 1997.

c. Conversion Ratio = 0.3% TCMTB / 80% DDAC d. Absorbed Daily dose ( mg/ kg/ day) = exposure ( mg/ day) * conversion ratio ( 0.00375) * absorption factor ( 100% for dermal and inhalation)/ body weight ( 70 kg).

e. MOE = NOAEL ( mg/ kg/ day)/ Daily dose [ Where ST/ IT/ LT dermal NOAEL = 25 mg/ kg/ day, ST/ IT NOAEL for inhalation is 16 mg/ kg/ day and LT NOAEL for inhalation is 3.8 mg/ kg/ day].

Target MOE is 100 for ST/ IT dermal and inhalation exposures and 300 for LT dermal and inhalation exposures. Page 36 of 56 Diptank Operators Exposures to diptank operators were also assessed using surrogate data from the DDAC study ( Bestari et al., 1999). The diptank scenario assessment was conducted differently than for the other job functions because the concentration of DDAC in the diptank solution was provided. The exposure data for diptank operators wearing gloves were converted into A unit exposures @

in terms of mg a. i. for each 1% of concentration of the product. The calculation of the dermal and inhalation unit exposures ( 2.99 and 0.046 mg/ 1% solution, respectively) is presented in Table C 2 in Appendix C. The air concentrations presented in the DDAC study were converted to unit exposures using an inhalation rate of 1.0 m3/ hr ( light activity) and a sample duration of 8 hrs/ day.

The following equations are used to estimate dermal and inhalation handler exposure:

Daily Dose = DDAC UE x AI x AB ( Eq. 18) BW Where:

DDAC UE = DDAC dermal unit exposure ( mg/ 1% in solution); AI = AI ( 30% ai in solution/ day); AB = Absorption factor ( 100% for dermal and inhalation); and BW = Body weight ( 70 kg).

Table 5.6 provides the short term and the intermediate and long term doses and MOEs for diptank operators. All dermal and inhalation MOES s as well as otal MOEs were above the corresponding target MOEs and are therefore not of concern. Page 37 of 56 Table 5.6. Short, Intermediate, and Long Term Exposures and MOEs for Diptank Operator Absorbed Daily Dosesc ( mg/ kg/ day) MOEsd Dermal Inhalation Total MOE Exposure Scenarioa ( number of replicates) Dermal Unit Exposureb ( mg DDAC/ 1%

solution) Inhalation Unit Exposureb ( mg DDAC/ 1%

solution) App Rate ( fraction a. i. in solution/

day) c Dermal Inhalation ST/ IT/ LT ST/ IT LT ST/ IT LT Occupational Handler Dipping,

with gloves ( n= 7) 2.99 0.0460 0.300 0.0128 1.98x10 4 1,900 81000 19000 1856 1727 ST = Short term duration; IT = Intermediate term duration; and LT = long term.

a. The exposure scenario represents a worker wearing long sleeved shirts, cotton work trousers, and gloves. Gloves were worn only when near chemical, not when operating diptank b. Dermal and inhalation unit exposures are from DDAC study ( MRID 455243 04). Refer to Table C 2 in Appendix C for the dermal and inhalation unit exposure calculations. Inhalation exposure ( mg) was calculated using the following equation: Air concentration ( mg/ m3) x Inhalation rate ( 1.0 m3/ hr) x Sample Duration ( 8 hr). The inhalation rate is from USEPA, 1997.

c. A 30% ai TCMTB solution was used.

d. Absorbed Daily dose ( mg/ kg/ day) = unit exposure ( mg/ 1% ai solution) * percent active ingredient in solution / body weight ( 70 kg).

e. MOE = NOAEL ( mg/ kg/ day)/ Daily dose [ Where ST/ IT/ LT dermal NOAEL = 25 mg/ kg/ day, ST/ IT inhalation NOAEL = 16 mg/ kg/ day, and LT inhalation NOAEL 3.8 mg/ kg/ day]. Target MOE is 100 for ST/ IT dermal and inhalation exposures and 300 for LT dermal and inhalation exposures. Page 38 of 56 Construction workers Not enough data exists to estimate the amount of exposure associated with construction workers who install treated wood. In particular, values for the transfer coefficient associated with a construction worker handling the wood could not be determined. However, it is believed that the construction worker using a trim saw will have larger dermal and inhalation exposures than the installer, due to the amount of sawdust generated and the greater amount of hand contact that would be necessary to handle the wood when using a saw compared to installing the wood.

5.3 Data Limitations/ Uncertainties There are several data limitations and uncertainties associated with the occupational handler and post application exposure assessments. These include:

  Surrogate dermal and inhalation unit exposure values were taken from the proprietary Chemical Manufacturers Association ( CMA) antimicrobial exposure study ( USEPA, 1999b: DP Barcode D247642) or from the Pesticide Handler Exposure Database ( USEPA, 1998) ( See Appendix B for summaries of these data sources). Since the CMA data are of poor quality, the Agency requests that confirmatory data be submitted to support the occupational scenarios assessed in this document.

  Unit exposures are not available for some of the specific scenarios that are prescribed for TCMTB. These scenarios include the following: open loading into oil well/ field environments and metering into cooling water systems at power plants.

  The CMA data used for oil well uses are based on open pouring of a material preservative. Although these data are only represented by 2 replicates each, the exposure values are similar to open loading of pesticides in PHED. Furthermore, there are no representative unit exposure data for chemical metering into secondary recovery oil operations. Since the volume of water being treated in secondary recovery operations is so large, the available CMA data can not be reliably extrapolated because they are based on activities that handle much lower volumes and possibly different techniques. Therefore, it was assumed that if the open pour handling activities for the other oil well operations resulted in MOEs that are not of concern, then the MOEs for the closed system chemical metering into secondary recovery operations would also be not of concern. AD requests that confirmatory data be conducted to show that this is accurate.

  The CMA data used for cooling water systems at power plants are based on closed metering for pulp and paper. The pulp and paper unit exposures were deemed more appropriate than the cooling water tower data because of the large volume of water treated in cooling water systems at power plants. However, the CMA data for pulp and paper does not reliably represent the volume of water treated and the possibly different techniques used to treat the water.

  For the wood preservative treatment scenarios, DDAC exposure data were used for the lack Page 39 of 56 of TCMTB specific exposure data. Limitations and uncertainties associated with the use of these data include:

  The assumption was made that exposure patterns for workers at treatment facilities using DDAC would be similar to exposure patterns for workers at treatment facilities using TCMTB, and therefore the exposures could be used as surrogate data for workers that treat wood with TCMTB.

  For environmental modeling, it was assumed that the leaching process from the TCMTB treated wood would be similar to that of DDAC. However, due to the lack of real data for TCMTB treated wood, it is not possible to verify this assumption.

  The quantities handled/ treated were estimated based on information from various sources, including HED's Standard Operating Procedures ( SOPs) for Residential Exposure Assessments ( USEPA 2000, and 2001) and personal communication with experts. In particular, the use information for the pulp and paper processing, oil well uses, and cooling water tower uses are based on personal communication with biocide manufacturers for these types of uses. The individuals contacted have experience in these operations and their estimates are believed to be the best available without undertaking a statistical survey of the uses. In certain cases, no standard values were available for some scenarios. Assumptions for these scenarios were based on AD estimates and could be further refined from input from registrants. For example, the quantities handled/ treated for the application of TCMTB to the surface of metal/ wood cooling towers could be refined. Page 40 of 56 6.0 REFERENCES Bestari KT, Macey K, Soloman KR, Tower N. 1999. Measurement and Assessment of Dermal and Inhalation Exposures to Didecyl Dimethyl Ammonium Chloride ( DDAC) Used in the Protection of Cut Lumber ( Phase III). MRID 455243 04.

Freeman, N , Jimenez M, Reed KJ, Gurunathan S, Edwards RD, Roy A, Adgate JL, Pellizzari ED, Quackenboss J, Sexton K, Lioy PJ, 2001. Quantitative analysis of chilren's microactivity patterns: The Minnesota Children's Pesticide Exposure Study. Journal of Exposure Analysis and Environmental Epidemiology. 11( 6): 501 509.

HERA, 2005. Human and Environmental Risk Assessment, Guidance Document Methodology, February 2005 ( http:// www. heraproject. com). The Multi Chamber Concentration and Exposure Model ( MCCEM) Model Version 1.2. Prepared for the US EPA Office of Pollution Prevention and Toxics. Prepared by Versar, Inc. and Wilkes Technologies, LLC.

USEPA. 1997. Exposure Factors Handbook. Volume I II. Office of Research and Development. Washington, D. C. EPA/ 600/ P 95/ 002Fa. August 1997.

USEPA. 1998. PHED Surrogate Exposure Guide. Estimates of Worker Exposure from the Pesticide Handler Exposure Database Version 1.1. Washington, DC: U. S. Environmental Protection Agency.

USEPA. 1999. Evaluation of Chemical Manufacturers Association Antimicrobial Exposure Assessment Study ( Amended on 8 December 1992). Memorandum from Siroos Mostaghimi, PH. D., USEPA to Julie Fairfax, USEPA. Dated November, 4 1999. DP Barcode D247642.

USEPA. 2000. Residential SOPs. EPA Office of Pesticide ProgramsBHuman Health Effects Division. Dated April 5, 2000.

USEPA. 2001. HED Science Advisory Council for Exposure. Policy Update, November 12. Recommended Revisions to the Standard Operating Procedures ( SOPs) for Residential Exposure Assessment, February 22, 2001.

Doityourself. com. 2005. What You Need to Know When Carpet Shopping. http:// doityourself. com/ carpet/ carpetshopping. htm, viewed September 2005.

USEPA. 2004. PBT Profiler: Assessing Chemicals in the Absence of Data, v1.203. http:// www. pbtprofiler. net/ default. asp. Accessed January 2006.

USEPA. 2006. 2( thiocyanomethylethylthio) benzothaizole ( TCMTB) report of the Antimicrobials Division Toxicity Endpoint Selection Committee ( ADTC). Memorandum from Timothy McMahon to Deborah Smegal. April 4, 2006. Page 41 of 56 APPENDIX A: Master TCMTB Label List Page 42 of 56 Table A shows the uses and application rates stated on the product labels for 43 TCMTB products. The table is ordered by the type of use associated with a product. As any one product may have multiple uses, products can be listed multiple times. Application rates, as stated on the product labels, were converted either into terms of lbs a. i./ gal or into terms of a weight fraction, in order to more easily compare application rates between products. All products listed below are formulated as liquids ( i. e. ready to use liquid, emulsifiable concentrate, soluble concentrate) except for Product # 1448 408, which is a wettable powder and used only for formulation.

Table A: Application Rates and Uses for TCMTB Products Product Number Percent AI Density ( lbs/ gal) Use App. Rate on Label Converted App Rate ( Rounded) Converted App. Rate Units Comments 1448 265 30 9 Cutting Fluids 1250 ppm a. i. 0.00125 a. i. weight fraction for use in diluted cutting fluids 1448 244 10 8.19 Cutting Fluids 3750 ppm Product 3.75x10  4 a. i. weight fraction for use in diluted cutting fluids 1448 99 10 8.2 Cutting Fluids 3750 ppm Product 3.75x10 4 a. i. weight fraction for use in diluted cutting fluids 1448 100 5 7.8 Cutting Fluids 7500 ppm Product 3.75x10 4 a. i. weight fraction for use in diluted cutting fluids 1448 152 5 7.8 Cutting Fluids 7500 ppm Product 3.75x10 4 a. i. weight fraction for use in diluted cutting fluids 1448 55 30 9 Cutting Fluids 1250 ppm Product 3.75x10 4 a. i. weight fraction for use in diluted cutting fluids 1448 150 30 8.7 Cutting Fluids 1250 ppm Product 3.75x10 4 a. i. weight fraction for use in diluted cutting fluids 1448 386 5 8.5 Cutting Fluids 7500 ppm Product 3.75x10 4 a. i. weight fraction 1448 151 10 8.19 Cutting Fluids 750 ppm Product 7.50x10 5 a. i. weight fraction 1448 153 5 7.8 Cutting Fluids 1500 ppm Product 7.50x10 5 a. i. weight fraction 1448 149 30 9 Cutting Fluids 250 ppm Product 7.50x10 5 a. i. weight fraction 1448 386 5 8.5 Drilling Fluids 1.5 Percent Product 7.50x10 4 a. i. weight fraction 1448 99 10 8.2 Drilling Fluids 0.75 Percent Product 7.50x10 4 a. i. weight fraction 50.4 Page 43 of 56 Table A: Application Rates and Uses for TCMTB Products Product Number Percent AI Density ( lbs/ gal) Use App. Rate on Label Converted App Rate ( Rounded) Converted App. Rate Units Comments 1448 152 5 7.8 Drilling Fluids 1.5 Percent Product 7.50x10 4 a. i. weight fraction 22.96 1448 100 5 7.8 Drilling Fluids 1.5 percent product 7.50x10 4 a. i. weight fraction 1448 153 5 7.8 Drilling Fluids 1.5 Percent Product 7.50x10 4 a. i. weight fraction 1448 151 10 8.19 Drilling Fluids 0.75 Percent Product 7.50x10 4 a. i. weight fraction 1448 244 10 8.19 Drilling Fluids 0.75 Percent Product 7.50x10 4 a. i. weight fraction 1448 150 30 8.7 Drilling Fluids 0.25 Percent Product 7.50x10 4 a. i. weight fraction 1448 149 30 9 Drilling Fluids 0.25 Percent Product 7.50x10 4 a. i. weight fraction 1448 55 30 9 Drilling Fluids 0.25 percent Product 7.50x10 4 a. i. weight fraction 1448 383 4 8.6 Drilling Fluids 0.8 Percent Product 3.20x10 4 a. i. weight fraction 1448 377 10 9.2 Drilling Fluids 0.25 Percent Product 2.50x10 4 a. i. weight fraction 1448 376 2.5 8.3 Drilling Fluids 1 Percent Product 2.50x10 4 a. i. weight fraction 1448 147 10 9 Drilling Fluids 0.25 Percent Product 2.50x10 4 a. i. weight fraction 1448 148 10 9 Drilling Fluids 0.25 Percent Product 2.50x10 4 a. i. weight fraction 44392 11 2.5 8.6 Drilling Fluids 1 Percent Product 2.50x10 4 a. i. weight fraction 1448 81 10 9 Drilling Fluids 0.25 Percent Product 2.50x10 4 a. i. weight fraction 1448 102 2.5 8.6 Drilling Fluids 1 Percent Product 2.50x10 4 a. i. weight fraction Page 44 of 56 Table A: Application Rates and Uses for TCMTB Products Product Number Percent AI Density ( lbs/ gal) Use App. Rate on Label Converted App Rate ( Rounded) Converted App. Rate Units Comments 1448 172 2.5 8.6 Drilling Fluids 1 Percent Product 2.50x10 4 a. i. weight fraction 1448 171 2.5 8.6 Drilling Fluids 1 Percent Product 2.50x10 4 a. i. weight fraction 1448 82 60 10.1 Ion Exchange ( Metal Recovery) 100 ppm Product 6.00x10 5 a. i. weight fraction Twice a week 1448 55 30 9 Leather 0.2 percent product 6.00x10 4 a. i. weight fraction 1448 386 5 8.5 Leather 12 lbs prod/ 1000 lbs white weight stock 6.00x10 4 a. i. weight fraction 1448 37 60 0 Leather 1000 ppm Product in Leather 6.00x10 4 a. i. weight fraction ( in leather)

1448 100 5 7.8 Leather 12 lbs prod/ 1000 lbs white weight stock 6.00x10 4 a. i. weight fraction 1448 99 10 8.2 Leather 6 lbs prod/ 1000 lbs white weight stock 6.00x10 4 a. i. weight fraction 1448 412 10.4 9 Leather 3000 ppm Product 3.12x10 4 a. i. weight fraction to white lime stock. 1% mix to fatliquor is possible as well.

1448 377 10 9.2 Leather 2500 ppm Product 2.50x10 4 a. i. weight fraction 1448 81 10 9 Leather 0.25 Percent Product 2.50x10 4 a. i. weight fraction 1448 102 2.5 8.6 Leather 10 lbs prod/ 1000 lbs white weight stock 2.50x10 4 a. i. weight fraction 1448 376 2.5 8.3 Leather 10 lbs prod/ 1000 lbs white weight stock 2.50x10 4 a. i. weight fraction 1448 37 60 0 mulch paper 2.5 lbs/ ton paper 7.50x10 4 a. i. weight fraction 1448 100 5 7.8 Mulch Paper 30 lbs prod/ ton paper 7.50x10 4 a. i. weight fraction 1448 82 60 10.1 Oil Preservation 6 fl oz prod/ 1000 gal oil 2.84x10 4 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well. Page 45 of 56 Table A: Application Rates and Uses for TCMTB Products Product Number Percent AI Density ( lbs/ gal) Use App. Rate on Label Converted App Rate ( Rounded) Converted App. Rate Units Comments 1448 386 5 8.5 Oil Preservation 32 fl oz prod/ 1000 gal oil 1.06x10 4 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well.

1448 99 10 8.2 Oil Preservation 16 fl oz prod/ 1000 gal oil 1.03x10 4 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well.

1448 100 5 7.8 Oil Preservation 32 fl oz prod/ 1000 gal oil 9.75x10  5 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well.

1448 377 10 9.2 Oil Preservation 6 fl oz prod/ 1000 gal oil 4.31x10 5 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well.

1448 81 10 9 Oil Preservation 6 fl oz prod/ 1000 gal oil 4.22x10 5 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well.

1448 148 10 9 Oil Preservation 6 fl oz prod/ 1000 gal oil 4.22x10 5 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well.

1448 147 10 9 Oil Preservation 6 fl oz prod/ 1000 gal oil 4.22x10 5 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well.

44392 11 2.5 8.6 Oil Preservation 25 fl oz prod/ 1000 gal oil 4.20x10 5 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well.

1448 102 2.5 8.6 Oil Preservation 25 fl oz prod/ 1000 gal oil 4.20x10 5 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well.

1448 172 2.5 8.6 Oil Preservation 25 fl oz prod/ 1000 gal oil 4.20x10 5 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well. crude, refined, and fuel preservation as well 1448 171 2.5 8.6 Oil Preservation 25 fl oz prod/ 1000 gal oil 4.20x10 5 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well.

1448 376 2.5 8.3 Oil Preservation 24 fl oz prod/ 1000 gal oil 3.89x10 5 lbs a. i./ gal Oil preservation can mean crude, refined, and fuel preservation as well. Page 46 of 56 Table A: Application Rates and Uses for TCMTB Products Product Number Percent AI Density ( lbs/ gal) Use App. Rate on Label Converted App Rate ( Rounded) Converted App. Rate Units Comments 1448 377 10 9.2 Oil Well Recovery 13 fl oz prod/ 1000 gal H2O 9.34x10 5 lbs a. i./ gal 1448 81 10 9 Oil Well Recovery 13 fl oz prod/ 1000 gal H2O 9.14x10 5 lbs a. i./ gal 1448 148 10 9 Oil Well Recovery 13 fl oz prod/ 1000 gal H2O 9.14x10 5 lbs a. i./ gal 1448 147 10 9 Oil Well Recovery 13 fl oz prod/ 1000 gal H2O 9.14x10 5 lbs a. i./ gal 1448 102 2.5 8.6 Oil Well Recovery 52 fl oz prod/ 1000 gal H2O 8.73x10 5 lbs a. i./ gal 1448 171 2.5 8.6 Oil Well Recovery 52 fl oz prod/ 1000 gal H2O 8.73x10  5 lbs a. i./ gal 1448 172 2.5 8.6 Oil Well Recovery 52 fl oz prod/ 1000 gal H2O 8.73x10 5 lbs a. i./ gal 44392 11 2.5 8.6 Oil Well Recovery 52 fl oz prod/ 1000 gal H2O 8.73x10 5 lbs a. i./ gal 1448 376 2.5 8.3 Oil Well Recovery 52 fl oz prod/ 1000 gal H2O 8.43x10 5 lbs a. i./ gal 1448 55 30 9 Oil Well Recovery 3.7 fl oz prod/ 1000 gal H2O 7.80x10  5 lbs a. i./ gal 1448 149 30 9 Oil Well Recovery 3.7 fl oz prod/ 1000 gal H2O 7.80x10 5 lbs a. i./ gal 1448 150 30 8.7 Oil Well Recovery 3.7 fl oz prod/ 1000 gal H2O 7.54x10 5 lbs a. i./ gal 1448 386 5 8.5 Oil Well Recovery 22.2 fl oz prod/ 1000 gal H2O 7.37x10 5 lbs a. i./ gal Page 47 of 56 Table A: Application Rates and Uses for TCMTB Products Product Number Percent AI Density ( lbs/ gal) Use App. Rate on Label Converted App Rate ( Rounded) Converted App. Rate Units Comments 1448 99 10 8.2 Oil Well Recovery 11.1 fl oz prod/ 1000 gal H2O 7.11x10 5 lbs a. i./ gal 1448 151 10 8.19 Oil Well Recovery 11.1 fl oz prod/ 1000 gal H2O 7.10x10 5 lbs a. i./ gal 1448 244 10 8.19 Oil Well Recovery 11.1 fl oz prod/ 1000 gal H2O 7.10x10  5 lbs a. i./ gal 1448 153 5 7.8 Oil Well Recovery 22.2 fl oz prod/ 1000 gal H2O 6.76x10 5 lbs a. i./ gal 1448 100 5 7.8 Oil Well Recovery 22.2 fl oz prod/ 1000 gal H2O 6.76x10 5 lbs a. i./ gal 1448 383 4 8.6 Oil Well Recovery 10 fl oz prod/ 1000 gal H2O 2.69x10 5 lbs a. i./ gal for intermittent feed. for continuous feed, 6.3. for slug feed, 12.6.

1448 152 5 7.8 Oil Well Recovery 7.2 fl oz prod/ 1000 gal H2O 2.19x10 5 lbs a. i./ gal 1448 99 10 8.2 Paint 15 Percent Product 0.015 a. i. weight fraction 1448 386 5 8.5 Paint 30 Percent Product 0.015 a. i. weight fraction 1448 55 30 9 Paint 5 percent product 0.015 a. i. weight fraction 1448 81 10 9 Paint 9 Percent Product 0.009 a. i. weight fraction Mold resistant coating 44392 11 2.5 8.6 Paint 36 Percent Product 0.009 a. i. weight fraction 1448 102 2.5 8.6 Paint 36 Percent Product 0.009 a. i. weight fraction 1448 376 2.5 8.3 Paint 36 Percent Product 0.009 a. i. weight fraction Page 48 of 56 Table A: Application Rates and Uses for TCMTB Products Product Number Percent AI Density ( lbs/ gal) Use App. Rate on Label Converted App Rate ( Rounded) Converted App. Rate Units Comments 1448 377 10 9.2 Paint 0.75 Percent Product 7.50x10 4 a. i. weight fraction 9% for sealant 1448 383 4 8.6 Papermaking Chemicals 800 ppm Product 3.20x10 5 a. i. weight fraction in coating formulations for paper 1448 55 30 9 Particle Board 1 percent product 0.003 a. i. weight fraction dry weight 1448 99 10 8.2 Particle Board 3 Percent Product 0.003 a. i. weight fraction 1448 386 5 8.5 Particle Board 6 Percent Product 0.003 a. i. weight fraction 1448 100 5 7.8 Particle Board 6 percent product 0.003 a. i. weight fraction 1448 81 10 9 Particle Board 0.3 Percent Product 3.00x10 4 a. i. weight fraction 1448 377 10 9.2 Particle Board 0.3 Percent Product 3.00x10 4 a. i. weight fraction 1448 45 8 9.6 Process Fresh Water 4 ppm Product 3.20x10 7 a. i. weight fraction 1448 383 4 8.6 Process Fresh Water 8 ppm Product 3.20x10 7 a. i. weight fraction 1448 386 5 8.5 Pulp Preservation 30 lbs prod/ ton paper 7.50x10 4 a. i. weight fraction 1448 100 5 7.8 Pulp Preservation 24 lbs prod/ ton paper 6.00x10 4 a. i. weight fraction 1448 99 10 8.2 Pulp Preservation 12 lbs prod/ ton paper 6.00x10 4 a. i. weight fraction for agricultural mulch paper, 15 lbs/ ton 1448 37 60 0 pulp preservation 2 lbs/ ton 6.00x10 4 a. i. weight fraction ton dry fiber 1448 55 30 9 Pulp Preservation 2 lbs/ ton 3.00x10 4 a. i. weight fraction dry fiber 1448 81 10 9 Pulp Preservation 4 lbs prod/ ton paper 2.00x10 4 a. i. weight fraction for wet lap or sheet pulp. for bacteriostatic paper, 9.0% addition.

1448 377 10 9.2 Pulp Preservation 1.5 lbs prod/ ton paper 7.50x10 5 a. i. weight fraction 9% for bacteriostatic paper Page 49 of 56 Table A: Application Rates and Uses for TCMTB Products Product Number Percent AI Density ( lbs/ gal) Use App. Rate on Label Converted App Rate ( Rounded) Converted App. Rate Units Comments 1448 383 4 8.6 Pulp Preservation 2 lbs prod/ ton paper 4.00x10 5 a. i. weight fraction 1448 376 2.5 8.3 Pulp Preservation 2 lbs prod/ ton paper 2.50x10 5 a. i. weight fraction 1448 102 2.5 8.6 Pulp Preservation 2 lbs prod/ ton paper 2.50x10 5 a. i. weight fraction 1448 45 8 9.6 Pulp Preservation 0.6 lbs prod/ ton paper 2.40x10 5 a. i. weight fraction 400 ppm to coating formulations 1448 3681 30 9 Pulp Preservation 0.1 lbs prod/ 1000 ft2 0.00488 a. i. weight fraction For soapwrap application. ( 0.1 lb product/ 1000 ft2) / ( 0.0205 lbs/ ft2)

1448 55 30 9 Sapstain Control 0.08 gal prod/ gal H2O 0.216 lbs a. i./ gal dipping solution 1448 386 5 8.5 Sapstain Control 480 gal prod/ 1000 gal H2O 0.204 lbs a. i./ gal 1448 99 10 8.2 Sapstain Control 240 gal prod/ 1000 gal H2O 0.197 lbs a. i./ gal 1448 100 5 7.8 Sapstain Control 0.48 gal prod/ gal H2O 0.187 lbs a. i./ gal dipping solution 1448 341 5 7.6 Sapstain Control 100 Percent Product 0.05 a. i. weight fraction can be used straight as a water repellant ( not sapstain) for millwork, shingles, structural lumber, etc. in above ground service. Use inline application.

1448 376 2.5 8.3 Sapstain Control 960 lbs prod/ 1000 gal H2O 0.024 lbs a. i./ gal 1448 377 10 9.2 Sapstain Control 180 lbs prod/ 1000 gal H2O 0.018 lbs a. i./ gal 1448 81 10 9 Sapstain Control 180 lbs prod/ 1000 gal H2O 0.018 lbs a. i./ gal 1448 393 1 7.2 Sapstain Control 100 Percent Product 0.01 a. i. weight fraction to be used in inline application for water repellant.

1448 102 2.5 8.6 Sapstain Control 96 lbs prod/ 1000 gal H2O 0.0024 lbs a. i./ gal Page 50 of 56 Table A: Application Rates and Uses for TCMTB Products Product Number Percent AI Density ( lbs/ gal) Use App. Rate on Label Converted App Rate ( Rounded) Converted App. Rate Units Comments 1448 55 30 9 Textile 2 percent product 0.006 a. i. weight fraction 1448 55 30 9 Wastewater 30 ppm Product 9.00x10 6 a. i. weight fraction 1448 37 60 0 wood chip preservation 1 lbs/ ton 3.00x10 4 a. i. weight fraction ton dry wood 1Product # 1448 368 states that the product is to be applied at a rate 0.1 lbs prod/ 1,000 ft2 for soap wrap. Without knowing the weight of soapwrap ( in lbs/ ft2), the application rate cannot be converted into terms that allow for comparison with other products. For lack of information, it was assumed that soap wrap has a weight density of 100 grams/ m2, or 0.0205 lbs/ ft2. Page 51 of 56 APPENDIX B: Summary of CMA and PHED Data Page 52 of 56 Chemical Manufacturers Association ( CMA) Data: In response to an EPA Data Call In Notice, a study was undertaken by the Institute of Agricultural Medicine and Occupational Health of The University of Iowa under contract to the Chemical Manufacturers Association. In order to meet the requirements of Subdivision U of the Pesticide Assessment Guidelines ( superseded by Series 875.1000 875.1600 of the Pesticide Assessment Guidelines), handler exposure data are required from the chemical manufacturer specifically registering the antimicrobial pesticide. The applicator exposure study must comply with the assessment guidelines for AApplicator Exposure Monitoring@ in Subdivision U and the AOccupational and Residential Exposure Test Guidelines@ in Series 875. For this purpose, CMA submitted a study on 28 February, 1990, entitled " Antimicrobial Exposure Assessment Study ( amended on December 8, 1992)" which was conducted by William Popendorf, et al. It was evaluated and accepted by Occupational and Residential Exposure Branch ( OREB) of Health Effect Division ( HED), Office of Pesticides Program ( OPP) of EPA in 1990. The purpose of this CMA study was to characterize exposure to antimicrobial chemicals in order to support pesticide re registrations ( CMA, 1992). The unit exposures presented in the most recent EPA evaluation of the CMA database ( USEPA, 1999b) was used in this assessment.

The Agency determined that the CMA study had fulfilled the basic requirements of Subdivision U  Applicator Exposure Monitoring. The advantages of CMA data over other Asurrogate data sets@ is that the chemicals and the job functions of mixer/ loader/ applicator were defined based on common application methods used for antimicrobial pesticides. A few of the deficiencies in the CMA data are noted below:

  The inhalation concentrations were typically below the detection limits, so the unit exposures for the inhalation exposure route could not be accurately calculated.   QA/ QC problems including lack of either/ or field fortification, laboratory recoveries, and storage stability information.   Data have an insufficient amount of replicates.

The Pesticide Handlers Exposure Database ( PHED): The Pesticide Handlers Exposure Database ( PHED) has been developed by a Task Force consisting of representatives from Health Canada, the U. S. Environmental Protection Agency ( EPA), and the American Crop Protection Association ( ACPA). PHED provides generic pesticide worker ( i. e., mixer/ loader and applicator) exposure estimates. The dermal and inhalation exposure estimates generated by PHED are based on actual field monitoring data, which are reported generically ( i. e., chemical specific names not reported) in PHED. It has been the Agency= s policy to use Asurrogate@ or Ageneric@ exposure data for pesticide applicators in certain circumstances because it is believed that the physical parameters ( e. g., packaging type) or application technique ( e. g., aerosol can), not the chemical properties of the pesticide, attribute to exposure levels. [ Note: Vapor pressures for the chemicals in PHED are in the range of E 5 to E 7 mm Hg.] Chemical specific properties are accounted for by correcting the exposure data for study specific field and laboratory recovery values as specified by the PHED grading criteria.

PHED handler exposure data are generally provided on a normalized basis for use in exposure assessments. The most common method for normalizing exposure is by pounds of active ingredient ( ai) handled per replicate ( i. e., exposure in mg per replicate is divided by the amount of ai handled in that particular replicate). These unit exposures are expressed as mg/ lb ai Page 53 of 56 handled. This normalization method presumes that dermal and inhalation exposures are linear based on the amount of active ingredient handled. Page 54 of 56 APPENDIX C: Calculation of DDAC Unit Exposure Values Page 55 of 56 Table C 1: DDAC Dermal and Inhalation Exposure Values for Chemical Operators, Graders, Millwrights, Clean up Crews, and Trim Saw Operatorsa Chemical Operator Grader Trim Saw Operator Millwright Cleanup Crew Dermal Inhalation Dermal Inhalation Dermal Inhalation Dermal Inhalation Dermal Inhalation Replicate Number Potential exposure ( mg) Air Concentrationb,

c (: g/ m3) Potential exposured ( mg) Potential exposure ( mg) Air Concentration b, c (: g/ m3) Potential exposure d ( mg) Potential exposure ( mg) Air Concentration b, c (: g/ m3) Potential exposure d ( mg) Potential exposure ( mg) Air Concentration b, c (: g/ m3) Potential exposure d ( mg) Potential exposure ( mg) Air Concentration b, c (: g/ m3) Potential exposure d ( mg)

1 3.5 10.1 0.0808 3.05 2.90 0.0232 0.78 2.83 0.0227 1.31 2.92 0.0233 68.3 2.99145 0.0239 2 6.11 2.80 0.0224 7.47 2.93 0.0234 1.98 12.3 0.0984 29.08 2.83 0.0226 0.720 2.78840 0.0223 3 6.07 2.79 0.0223 1.09 2.91 0.0233 8.03 15.6 0.1248 166 30.3 0.2424 4 46.37 2.82 0.0226 10.51 3.00 0.0240 95.2 412 3.2960 5 0.94 2.93 0.0235 0.61 2.82 0.0226 1.20 2.83585 0.0227 6 22.15 2.83 0.0227 0.98 2.85 0.0228 0.260 2.80989 0.0225 7 21.45 2.77 0.0222 2.63 2.91 0.0233 8 0.22 2.73 0.0218 5.23 2.85 0.0228 9 0.44 2.77 0.0222 0.19 13.20 0.1056 10 0.33 3.14 0.0251 1.47 2.89 0.0231 11 0.29 2.88 0.0230 2.38 2.85 0.0228 12 4.09 2.81 0.0225 13 1.03 2.94 0.0235 Arithmetic Mean 9.81 3.51 0.0281 3.13 3.68 0.0295 1.38 7.57 0.061 12.8 7.12 0.057 55.3 75.6 0.60 Minimum 0.22 2.73 0.0218 0.19 2.81 0.0225 0.78 2.83 0.0227 1.31 2.83 0.0226 0.260 2.79 0.0223 Maximum 46.4 10.1 0.081 10.51 13.2 0.106 1.98 12.3 0.098 29.1 15.6 0.125 166 412 3.30 a. " Measurement and Assessment of Dermal and Inhalation Exposures to Didecyl Dimethyl Ammonium Chloride ( DDAC) Used in the Protection of Cut Lumber ( Phase III)" is the study that values were obtained from for this table ( Bestari et al., 1999, MRID 455243 04).

b. The inhalation LOD was not provided for chemical operators, graders, trim saw operators, millwrights, or the clean up crew. Therefore, the LOD provided for the diptank operator ( 5.6 : g)

was used for these positions. Residues less than the LOD were adjusted to 1/ 2 LOD.

c. The inhalation limit of detection was converted to : g/ m3 using the following equation: air concentration (: g/ m3) = 5.6 : g/ [ average flow rate ( L/ min) * sampling duration ( 480 min) * 1000 L/ m3. Data was obtained from Bestari et al ( 1999).

d. DDAC air concentrations were converted to inhalation exposure using the following equation: Air concentration (: g/ m3) x inhalation rate ( 1.0 m3/ hr) x Conversion factor ( 1 mg/ 1000 : g) x sample duration ( 8 hours/ day Page 56 of 56 Table C 2: Normalization of DDAC Dermal and Inhalation Exposure Values for Diptank Operatorsa Worker ID Mill number Sample Time ( min) DDAC Conc. in Diptank (%) Gloves Dermal Body Exposureb ( mg) Hand Exposureb ( mg) Total Dermal Exposure ( mg) Normalized Total Dermal Unit Exposurec ( mg/ 1 % solution) Air Conc. d ( mg/ m3) Inhalation Exposuree ( mg) Normalized Inhalation Unit Exposurec ( mg / 1% solution)

M7P1A 7 480 0.64 Rubber 0.5 3.44 3.94 6.16 0.003 0.024 0.0375 M7P1B 7 480 0.64 Rubber 0.32 2.02 2.34 3.66 0.003 0.024 0.0375 M8P4A 8 408 0.42 Rubber 0.04f 1.34 1.38 3.29 0.003 0.024 0.057 M8P4B 8 480 0.42 Rubber 0.04f 0.5 0.54 1.29 0.003 0.024 0.057 M8P7 8 480 0.42 Cotton 0.03 0.04 0.07 0.17 0.003 0.024 0.057 M11P9A 11 395 0.63 Leather 0.15 3.33 3.48 5.52 0.003 0.024 0.0381 M11P9B 11 480 0.63 Leather 0.1 0.45 0.55 0.87 0.003 0.024 0.0381 Arithmetic Mean 0.17 1.59 1.76 2.99 0.0030 0.0240 0.046 Standard Deviation 0.18 1.39 1.53 2.32 0.0000 0.0000 0.0103 Median 0.10 1.34 1.38 3.29 0.0030 0.0240 0.0381 Geometric Mean 0.10 0.83 0.99 1.86 0.0030 0.0240 0.045 90% tile 0.39 3.37 3.66 5.78 0.0030 0.0240 0.057 Maximum 0.50 3.44 3.94 6.16 0.0030 0.0240 0.057 a. " Measurement and Assessment of Dermal and Inhalation Exposures to Didecyl Dimethyl Ammonium Chloride ( DDAC) Used in the Protection of Cut Lumber ( Phase III)" is the study that values were obtained from for this table ( Bestari et al., 1999, MRID 455243 04).

b. DDAC concentration that was detected in the monitoring study ( MRID # 455243 04).

c. Normalization of DDAC data for percent ai treatment. Normalized Unit Exposure ( mg/ 1% ai solution) = Exposure ( mg DDAC) / concentration in diptank solution (% DDAC)

d. All inhalation residues were < LOD ( 5.6 µ g or 0.0056 mg/ m3). 1/ 2 LOD was used in all calculations ( 0.003 mg/ m3). Air Concentration ( mg/ m3) = 5.6 µ g / (~ 2 L/ min flow rate x ~ 480 min)

x 1000 L/ m3 conversion x 0.001 µ g/ mg = 0.003 mg/ m3 e. Inhalation exposure ( mg) = air concentration ( mg/ m3) x inhalation rate ( 1.0 m3/ hr) x sample duration ( 8 hours/ day).

f. Residues were < LOD for dermal samples M8P4A, M8P4B. Sample size of ~ 11,231 cm2 x < 0.007 ug/ cm2 = LOD of 0.079 mg. 1/ 2 LOD reported ( i. e., 0.04 mg)