UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES MEMORANDUM Date: JUNE 13, 2005 Subj: Inorganic Chlorates: Occupational and Residential Exposure Assessment for the Reregistration Eligibility Decision ( RED) Document ( Case 4049)

PC Codes: Sodium Chlorate: 073301 Potassium Chlorate: 073302 Calcium Chlorate: 073303 Magnesium Chlorate: 530200 DP Barcode: D307365 From: Matthew Crowley, Environmental Protection Specialist Health Effects Division/ Reregistration Branch 4 ( 7509C)

Through: Susan Hummel, Branch Senior Scientist Health Effects Division/ Reregistration Branch 4 ( 7509C)

To: Bonnie Cropp Kohlligian, Risk Assessor Health Effects Division/ Reregistration Branch 4 ( 7509C)

Jacqueline Guerry, Chemical Review Manager Special Review and Reregistration Division/ Reregistration Branch 3 The attached document is the occupational and non occupational ( residential) exposure and risk assessment for inorganic chlorates to support the Health Effects Division ( HED) reregistration eligibility decision ( RED) document. This document addresses only the exposures and risks to sodium chlorate as it is the only inorganic chlorate as an active ingredient in any registered products. Occupational and residential exposures and risks to inorganic chlorates as inert ingredients in registered products are addressed under separate cover ( M. Crowley, 6/ 13/ 05, D318045).

The assessment was reviewed by HED's Science Advisory Council for Exposure ( ExpoSAC) to ensure compliance with current HED policy as well as ExpoSAC standard operating procedures ( SOPs) for conducting occupational and residential exposure ( ORE) assessments. Table of Contents Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 1.0 Occupational and Residential Exposure/ Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1.1 Purpose . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1.2 Criteria for Conducting Exposure Assessments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1.3 Summary of Hazard Concerns . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1.3.1 Sodium Chlorate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1.4 Incident Reports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 1.5 Summary of Physical and Chemical Properties of Sodium Chlorate . . . . . . . . . . . . . . . . 7 1.6 Summary of Use Patterns and Formulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1.6.1 End Use Products . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1.6.2 Registered Use Categories and Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1.6.3 Application Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 2.0 Occupational Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 2.1 Occupational Handler Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 2.1.1 Data and Assumptions For Handler Exposure Scenarios . . . . . . . . . . . . . . . . . 11 <IP_ADDRESS> Assumptions for Handler Exposure Scenarios . . . . . . . . . . . . . . . . . . 11 <IP_ADDRESS> Exposure Data for Handler Exposure Scenarios . . . . . . . . . . . . . . . . . 13 2.1.2 Sodium Chlorate Handler Exposure Scenarios . . . . . . . . . . . . . . . . . . . . . . . . 16 2.1.3 Non cancer Sodium Chlorate Handler Exposure and Assessment . . . . . . . . . . . 17 <IP_ADDRESS> Non cancer Sodium Chlorate Handler Exposure/ Risk Calculations . . . 17 <IP_ADDRESS> Sodium Chlorate Non cancer Risk Summary . . . . . . . . . . . . . . . . . . . 18 3.0 Residential Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 3.1 Residential Handler Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 3.1.1 Handler Exposure Scenarios . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 3.1.2 Data and Assumptions For Handler Exposure Scenarios . . . . . . . . . . . . . . . . . 24 3.1.3 Residential Handler Exposure and Non Cancer Risk Estimates . . . . . . . . . . . . 27 4.0 Occupational and Residential Handler Exposure and Risk Estimates for Cancer . . . . . . . . . . . . 30 5.0 Summary of Risk Concerns and Data Gaps for Occupational and Residential Handlers . . . . . . 30 6.0 Occupational and Residential Postapplication Exposures and Risks . . . . . . . . . . . . . . . . . . . . . 30 APPENDIX 1  Label Extraction Tables APPENDIX 2  Occupational and Residential Risk Calculations 3 Executive Summary This document contains the occupational and residential exposure assessment for agricultural, commercial ( non agricultural), and residential uses for sodium chlorate. As an agricultural defoliant/ desiccant, it is mostly used on cotton, however it is also applied to a wide variety of other crops including, but not limited to, rice, corn, soybeans, dry beans, potatoes, sunflowers, flax, safflower, chili peppers ( for processing only), grain sorghum, and wheat. Application rates range from 6 to 12.5 lb of active ingredient ( ai) sodium chlorate per acre and is applied by aerial and ground equipment. Agricultural product formulations are all soluble concentrates/ liquids.

As a non selective herbicide it is applied to industrial/ non crop areas such as rights ofways building perimeters, ditch banks, bleachers, airport runways, vacant lots, fire hydrants, or as a pre paving treatment at rates ranging from 0.76 lb ai per 250 ft2 ( 132 lb ai per acre) [ EPA Reg. No. 9754 1] to 2.37 lb ai per 100 ft2 ( 1032 lb ai per acre) [ EPA Reg. No. 77041 34] for soluble concentrate/ liquid formulations, and 0.37 lb ai per 100 ft2 ( 161 lb ai per acre) [ EPA Reg. Nos. 53883 97 and 66222 23] to 1.2 lb ai per 100 ft2 ( 523 lb ai per acre) [ EPA Reg. Nos. 690 48 and 33560 48] for granular or pellet/ tablet formulations. Its residential use is similar to the commercial herbicidal use, however is applied as a spot treatment/ edging treatment to driveway cracks and crevices, around foundations, and underneath or around wood decks. It is not labeled for broadcast on residential lawns or ornamentals. As an herbicide it is applied using handheld equipment ( i. e., low pressure handwands or sprinkler cans), but for the larger industrial/ non crop settings a rights of way sprayer, handgun sprayer, groundboom, or tractor drawn spreader may be applicable.

Sodium chlorate is toxicity category IV for acute dermal, inhalation, and oral toxicity and toxicity category III for skin and eye irritation potential. Results were negative for dermal sensitization. The only endpoint chosen is for short and intermediate term inhalation because as an inorganic salt, significant amounts of sodium chlorate are not expected to be absorbed through the skin. The inhalation endpoint chosen for use in this assessment, a no observed adverse effects level ( NOAEL) of 30 mg/ kg/ day, was defined in a 90 day oral study in rats. The level of concern ( LOC) for the margin of exposure ( MOE) is 100. The level of concern is based on 10x to account for interspecies extrapolation to humans from the animal test species and 10x to account for intraspecies sensitivity.

An occupational and residential cancer risk assessment was not conducted for sodium chlorate. The exposure durations for occupational and residential handlers are inconsistent with the mechanism of carcinogenicity. A 2 year NTP bioassay to determine the potential of sodium chlorate to induce thyroid tumors in laboratory animals ( rats and mice) has been recently reported in a draft form ( NTP, 2004). A final report of this study is expected during 2005. In these tests, there was some evidence of thyroid gland follicular cell carcinogenicity in male rats which may be attributed to the imbalance of thyroid hormones ( reduced T 3 and T 4 and elevated TSH) seen in these studies as a result of exposure to high doses of sodium chlorate. Current EPA HED policy 4 states that " nonmutagenic pesticides that induce elevated levels of TSH and thyroid follicular cell tumors in the rat should be classified as not likely to be carcinogenic to humans at doses that do not alter rat thyroid hormone homeostasis" (( HED hot sheet # 23). In female mice there was equivocal and marginal evidence of increased pancreatic islet carcinoma.

Risks for most occupational handler baseline ( without a respirator) inhalation exposure scenarios do not exceed HED's level of concern of 100 for the MOE ( i. e, most scenarios had MOEs > 100). However, risks for the following scenarios exceeded HED's level of concern at baseline:

° Mixing/ Loading liquids for groundboom application to industrial/ non crop sites at 1032 lb ai per acre ( MOE = 42) and 523 lb ai per acre ( MOE = 84); ° Loading granules for tractor drawn spreader applications to industrial/ non crop sites at 523 lb ai per acre ( MOE = 59); ° Applying sprays to industrial/ non crop sites using groundboom equipment ( open cab) at 1032 lb ai per acre ( MOE = 69); ° Applying granules to industrial/ non crop sites using a tractor drawn spreader ( open cab) at 523 lb ai per acre ( MOE = 84); ° Loading/ Applying granules to industrial/ non crop sites using a belly grinder at 523 lb ai per acre ( MOE = 65); and ° Mixing/ Loading/ Applying liquids for low pressure handwand applications to industrial/ non crop sites at 1032 lb ai per acre ( MOE = 34) and 523 lb ai per acre ( MOE = 67).

With the addition of a dust/ mist respirator ( with an 80% reduction factor), or, for certain scenarios, engineering controls ( enclosed cockpits or cabs), all occupational handler scenarios were below HED's level of concern. Additionally, risks were mitigated for certain scenarios, without the application of a respirator or engineering controls, by using lower application rates. Risks of concern were at the higher application rates ( 1032 and 523 lb ai per acre), whereas at lower rates the risk were not of concern ( MOEs > 100 at lower application rates).

All residential handler inhalation exposure scenarios were also below HED's level of concern ( i. e, all scenarios had MOEs > 100). Postapplication dermal and inhalation exposures are negligible due to its physical and chemical characteristics as an inorganic salt. No significant amount of sodium chlorate is expected to be absorbed through the skin and the vapor pressure is negligible. 5 1.0 Occupational and Residential Exposure/ Risk Assessment 1.1 Purpose This document is the occupational and residential non dietary exposure and risk assessment for sodium chlorate from its use as an agricultural defoliant/ desiccant and a nonagricultural non selective herbicide. In this document, which is for use in EPA's development of the HED chapter of the sodium chlorate RED Document, EPA presents the results of its review of the potential human health effects of occupational and residential/ non occupational exposure to sodium chlorate.

1.2 Criteria for Conducting Exposure Assessments An occupational and/ or residential exposure assessment is required for an active ingredient if ( 1) certain toxicological criteria are triggered and ( 2) there is a potential for exposure to handlers ( mixers, loaders, applicators) during use or to persons entering treated sites or exposed to vapors after application is complete. A toxicological endpoint was selected only for inhalation exposures to sodium chlorate. There is potential for short and intermediate term inhalation exposure in a variety of agricultural and commercial settings as well as in residential settings. Therefore, assessments for inhalation exposures to sodium chlorate use are required for occupational and residential handlers.

1.3 Summary of Hazard Concerns The sodium chlorate risk assessment team met to determine appropriate toxicological endpoints of concern for sodium chlorate. The toxicological endpoints extracted from the Toxicology Section for the RED document ( A. Khasawinah, D307358) that were used to complete the occupational and residential risk assessments are summarized below.

1.3.1 Sodium Chlorate Sodium chlorate is an agricultural defoliant/ desiccant and a commercial/ residential herbicide. Use patterns can vary from short term to intermediate term exposure durations. Longterm exposure durations are not expected. Sodium chlorate exposures are expected to occur to both occupational and residential users.

Dermal Route ( non cancer)

Because it is an inorganic salt, significant absorption of sodium chlorate through the skin is not expected, and a dermal toxicological endpoint was not selected. Therefore, a risk assessment for dermal exposure ( handler and postapplication) was not performed. 6 Inhalation Route ( non cancer)

The short and intermediate term ( non cancer) inhalation risk assessment for sodium chlorate is based on a NOAEL of 30 mg/ kg/ day, which was defined in a 90 day oral study in rats. The lowest observed adverse effects level ( LOAEL) of 112 mg/ kg/ day was based on colloid depletion and follicular cell hyperplasia. Long term exposures to sodium chlorate ( i. e. greater than 6 months) are not expected for current registered uses. As the toxicological endpoint is based on an oral study, standard HED practice calls for application of a 100% inhalation absorption factor to be used in exposure calculations.

Non cancer Level of Concern ( LOC)

HED's level of concern for sodium chlorate is 100 ( i. e. MOEs less than 100 exceed HED's level of concern) for both occupational and residential scenarios. The level of concern is based on 10x to account for interspecies extrapolation to humans from the animal test species and 10X to account for intraspecies sensitivity.

Cancer A 2 year NTP bioassay to determine the potential of sodium chlorate to induce thyroid tumors in laboratory animals ( rats and mice) has been recently reported in a draft form ( NTP, 2004). A final report of this study is expected during 2005. In these test, there was some evidence of thyroid gland follicular cell carcinogenicity in male rats which may be attributed to the imbalance of thyroid hormones ( reduced T 3 and T 4 and elevated TSH) seen in these studies as a result of exposure to high doses of sodium chlorate. Current EPA HED policy states that " nonmutagenic pesticides that induce elevated levels of TSH and thyroid follicular cell tumors in the rat should be classified as not likely to be carcinogenic to humans at doses that do not alter rat thyroid hormone homeostasis" (( HED hot sheet # 23). In female mice there was equivocal and marginal evidence of increased pancreatic islet carcinomas.

Acute Toxicity Sodium chlorate is classified as category IV for acute oral, dermal, and inhalation toxicity. It is classified as category III for both eye irritation potential skin irritation potential. Results were negative for dermal sensitization.

Body Weight Since the adverse effects for all studies utilized in the sodium chlorate inhalation risk assessments are not gender specific, the average weight of an adult ( i. e., 70 kg) was used to estimate exposure. 7 1.4 Incident Reports An analysis of incident reports will be included in a separate memo by Jerome Blondell.

1.5 Summary of Physical and Chemical Properties of Sodium Chlorate Sodium chlorate ( CAS registry number 7775 09 9) is an odorless, water soluble, nonvolatile white crystalline solid ( like common table salt) with a molecular formula of NaClO 3 and a molecular weight of 106.44 g/ mole. Its vapor pressure is listed as " NA", not applicable, and is considered negligible ( D303554, Appendix C).

1.6 Summary of Use Patterns and Formulations Sodium chlorate products are described in this section.

1.6.1 End Use Products Sodium chlorate is used in agricultural, commercial, and residential settings. End use product formulations for sodium chlorate include liquids ( soluble concentrate and ready to use  RTU) and solids ( granular and pellet/ tablet).

1.6.2 Registered Use Categories and Sites Sodium chlorate is registered for use in occupational and residential scenarios ( see Tables 1 through 3). As a defoliant/ desiccant, professional agricultural uses include: cotton, corn, rice, dry beans, grain sorghum, flax, safflower, sunflower, soybeans, guar beans, southern peas, chili peppers ( for processing only), potatoes, ornamental gourds, cucurbits ( grown for seed), wheat, and fallow land. Labels indicate a restricted entry interval ( REI) of 12 hours which is the Worker Protection Standard ( WPS) requirement for active ingredients in toxicity category III for acute skin irritation potential.

As a non selective herbicide it is used to kill grasses and weeds in industrial and non crop sites such as: rights of way areas, building perimeters, driveways, parking lots, fence rows, tennis courts, ditch banks, picnic areas, bleachers, cemeteries, fuel tank farms, airport runways, helo pads, wood decks, guard rails, highway medians, sidewalks/ walkways, vacant lots, fire hydrants, recreational areas, pipelines, railroads, lumberyards, and other similar areas. As a residential herbicide it is applied as a spot treatment or edging treatment around patios, along fence lines, lawn edges, around foundations, underneath or around wood decks, and in cracks and crevices of driveways. Product labels indicate that it is not for use on lawns/ turf, ornamental plants, and desirable shrubs and trees. ( See Appendix 1 for label extraction and additional usage descriptions.) 8 Table 1: Summary of Application Rates for Sodium Chlorate Agricultural Uses ( Defoliant/ Desiccant)

Crop Type/ Use Site Application Equipment Application Rates Cotton, corn, rice, dry beans, sorghum, flax, safflower, sunflower, soybeans, guar beans, southern peas aerial, groundboom 7.5 lb ai/ A Chili peppers ( processing only), potatoes aerial, groundboom 12.5 lb ai/ A Ornamental gourds, cucurbits ( grown for seed), fallow land, wheat aerial, groundboom 6 lb ai/ A Table 2: Summary of Application Rates for Sodium Chlorate   Industrial and Other Non Crop Uses Crop Type/ Use Site Application Equipment Application Rates1,2 Industrial/ Non Crop sites rights of way sprayer, handgun sprayer, groundboom, low pressure handwand 1032 lb ai/ A 523 lb ai/ A 132 lb ai/ A belly grinder, push type spreader, tractor drawn spreaders 523 lb ai/ A 240 lb ai/ A 161 lb ai/ A Table 3: Summary of Application Rates for Registered Sodium Chlorate   Residential Herbicidal Uses Crop Type/ Use Site Application Equipment Application Rates Spot treatment/ edging treatment RTU sprinkler can 0.27 lb ai/ gallon low pressure handwand, sprinkler can 23.7 lb ai/ 1000 ft2 trigger pump sprayer 0.196 lb ai/ gallon belly grinder, push type spreader, hand 12 lb ai/ 1000 ft2 1 The extrapolation of the application rate into acres ( from a square foot based application rate) is presented to reflect the potential in occupational/ commercial settings to deal in acres treated per day as seen in the ExpoSAC SOP # 9: Standard Values for Daily Acres Treated in Agriculture which was completed on July 5, 2000. See Appendix 1 for label specific rates. 2 Application rates are presented to show upper and lower ranges as seen on different product labels as seen in Appendix 1. 9 1.6.3 Application Methods Sodium chlorate as a defoliant/ desiccant in agricultural settings is applied using aerial and groundboom equipment. As a herbicide it is applied using handheld equipment such as a lowpressure handwand, sprinkling cans, and also, rights of way, groundboom, and handgun sprayers for larger commercial scenarios. Granular formulations can be applied using belly grinders, pushtype spreaders, tractor drawn spreaders, or by hand.

2.0 Occupational Exposures and Risks Although potential for both dermal and inhalation exposure exists in occupational scenarios ( agricultural and non agricultural) from handling sodium chlorate products during the application process ( i. e., mixer/ loaders, applicators, flaggers, and mixer/ loader/ applicators), only risks for inhalation exposures are assessed as discussed in Section 1.3.1.

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

Exposure scenarios can be thought of as ways of categorizing the kinds of exposures that occur related to the use of a chemical. The use of scenarios as a basis for exposure assessment is very common as described in the U. S. EPA Guidelines For Exposure Assessment ( U. S. EPA; Federal Register Volume 57, Number 104; May 29, 1992). Information from the current labels, use and usage information, toxicology data, and exposure data were all key components in developing the exposure scenarios.

The first step in the handler risk assessment process is to identify the kinds of individuals that are likely to be exposed to sodium chlorate during the application process. In order to do this in a consistent manner, HED has developed a series of general descriptions for tasks that are associated with pesticide applications. Tasks associated with occupational pesticide use ( i. e., for " handlers") can generally be categorized using one of the following terms:

C Mixers and/ or Loaders: these individuals perform tasks in preparation for an application. For example, prior to application, mixer/ loaders would mix the sodium chlorate and load it into the holding tank of the airplane or groundboom.

C Applicators: these individuals operate application equipment during the release of a pesticide product into the environment. These individuals can make applications using 10 equipment such as airplanes or groundboom.

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

Most exposure scenarios for handheld equipment ( such as handwands, backpack sprayers, and push type spreaders) are assessed as a combined job function. With these types of handheld operations, all handling activities are assumed to be carried out by the same individual. The available monitoring data support this and HED presents them this way in risk assessments. Conversely, for equipment types such as fixed wing aircraft, and groundboom tractors, the applicator exposures are assessed and presented separately from those for the mixer/ loaders. By separating the two job functions, HED determines the most appropriate levels of personal protective equipment ( PPE) for each aspect of the job without requiring the applicator to wear unnecessary PPE that may be required for the mixer/ loaders ( e. g., chemical resistant gloves may only be necessary during the pouring of a liquid formulation).

C Occupational Flaggers: these individuals guide aerial applicators during the release of a pesticide product onto an intended target.

Next, assessors must understand how exposures to sodium chlorate occur ( i. e., frequency and duration) and how the patterns of these occurrences can cause the effects of the chemical to differ ( referred to as dose response). Wherever possible, use and usage data determine the appropriateness of certain types of risk assessments ( e. g., a chronic risk assessment is not warranted because chronic duration exposure patterns to sodium chlorate are not expected to occur). Other parameters are also defined from use and usage data such as application rates and application frequency. HED always completes non cancer risk assessments using maximum application rates for each scenario because what is possible under the label ( the legal means of controlling pesticide use) must be evaluated in order to ensure there are no concerns for each specific use.

A chemical can produce different effects based on how long a person is exposed, how frequently exposures occur, and the level of exposure. It is likely that sodium chlorate exposures can occur in a variety of patterns. HED believes that occupational sodium chlorate exposures can occur over a single day or up to weeks at a time for many use patterns and intermittent exposures over several weeks are also anticipated. Some applicators may apply sodium chlorate over a period of weeks because they are custom or commercial applicators who are completing applications for a number of different clients. HED classifies exposures up to 30 days as shortterm and exposures greater than 30 days up to several months as intermediate term. HED completes both short and intermediate term assessments for occupational scenarios in essentially all cases, because these kinds of exposures are likely and acceptable use/ usage data are not 11 available to justify deleting intermediate term scenarios. Long term handler exposures are not expected to occur for sodium chlorate. The same toxicological endpoint ( from an oral study) of concern was selected for short, and intermediate term inhalation sodium chlorate exposures, therefore the risk results for both inhalation exposure durations are numerically identical.

Occupational handler exposure assessments are completed by HED using different levels of personal protection. HED typically evaluates all exposures with a tiered approach. The lowest tier is represented by the baseline exposure scenario ( i. e., long sleeve shirt, long pants, shoes, socks, and no respirator) followed by increasing the levels of personal protective equipment ( PPE) ( e. g., gloves, double layer body protection, and respirators) and engineering controls ( e. g., enclosed cabs or cockpits and closed mixing/ loading systems). This approach is always used by HED in order to be able to define label language using a risk based approach. In addition, the minimal level of adequate protection for a chemical is generally considered by HED to be the most practical option for risk reduction ( i. e., over burdensome risk mitigation measures are not considered a practical alternative).

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

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

C Average body weight of an adult handler is 70 kg because the toxicity endpoint values used for the assessments are appropriate for average adult body weight representing the general population. This is the case because none of the effects identified in the selected toxicity studies were sex specific.

C Exposure factors used to calculate daily exposures to handlers are based on applicable data if available. For lack of appropriate data, values from a scenario deemed similar enough by the assessor might be used. As an example, for sodium chlorate handler exposures, ORETF data for hose end sprayer equipment were used to assess sprinkling can applications. The nature of these application methods are believed to be similar enough to bridge the data.

C HED always considers the maximum application rates allowed by labels in its risk assessments. If additional information such as a different range of rates are available, these values also may be used to allow risk managers to make a more informed risk 12 management decision.

C The typical occupational workday is assumed to be 8 hours.

C The daily area treated was defined for each handler scenario ( in appropriate units) by determining the amount that can be reasonably treated in a single day ( e. g. acres, square feet, or gallons per day). When possible, the assumptions for daily areas treated is taken from ExpoSAC SOP # 9: Standard Values for Daily Acres Treated in Agriculture which was completed on July 5, 2000. Assumptions for these scenarios, including further refinements based on HED estimates, are listed below.

Agricultural Scenarios S Aerial applications: 350 acres ( typical field crop assumption) for guar beans, southern peas, chili peppers ( for processing only), potatoes, ornamental gourds, and cucurbits ( grown for seed); 1200 acres ( high acreage crop assumption) for cotton, corn, rice, dry beans, sorghum, flax, safflower, sunflower, soybeans, wheat, and fallow land.

S Groundboom: 80 acres ( typical field crop assumption) for guar beans, southern peas, chili peppers ( for processing only), potatoes, ornamental gourds, and cucurbits ( grown for seeds); 200 acres ( high acreage crop assumption) for cotton, corn, rice, dry beans, sorghum, flax, safflower, sunflower, soybeans, wheat and fallow land.

S Flaggers: 350 acres.

Refinements into " typical field" and " high acreage" crops was performed with help from HED crop expert Bernard Schneider ( email from B. Schneider, 5/ 24/ 04).

Industrial/ Non Crop Sites S Rights of Way Sprayer and Handgun Sprayer: 5 acres per day;

S Low Pressure Handwand Sprayer: 2 acres per day;

Note: Although assessments for applications involving rights of way sprayers and low pressure handwands typically use a volume based approach for amount handled/ treated per day ( 1000 gallons and 40 gallons, respectively, from ExpoSAC Policy # 9), label specific application rates and their respective dilution factors for larger application settings are better represented by a daily unit area treated than a volume based approach. For example, the label specific application of 8 pints per 100 square feet [ EPA Reg. No. 7701 34] yields the application rate of 1032 lb ai in 2196 gallons of solution per acre. At this rate, the volume based approach of 1000 gallons per day would have a worker treating approximately ½ acres per day. Because a rights of way sprayer would likely treat more than ½ acre per day, a daily unit area of 5 acres was used as a more appropriate estimate. 13 S Belly grinder: 1 acre per day.

S Push type spreader: 5 acres per day S Groundboom and Tractor drawn Spreader: 40 acres per day.

<IP_ADDRESS> Exposure Data for Handler Exposure Scenarios For sodium chlorate handler exposure assessments, all analyses were completed using data that were deemed to be a source of acceptable surrogate exposure data for the scenario in question.

HED uses a concept known as unit exposure as the basis for the scenarios used to assess handler exposures to pesticides. Unit exposures numerically represent the exposures one would receive related to an application. They are generally presented as ( mg active ingredient exposure/ pounds of active ingredient handled). HED has developed a series of unit exposures that are unique for each scenario typically considered in our assessments ( i. e., there are different unit exposures for different types of application equipment; job functions; and levels of protection). The unit exposure concept has been established in the scientific literature and also through various exposure monitoring guidelines published by the U. S. EPA and international organizations such as Health Canada and OECD ( Organization For Economic Cooperation and Development). The concept of using unit exposures as surrogate data for different chemicals can be illustrated by the following example. If an individual makes an application using a lowpressure sprayer with either 10 pounds of chemical A or 10 pounds of chemical B using the same clothing and personal protective equipment, the exposures to chemicals A and B would be similar.

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

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

Once the data for a given exposure scenario have been selected, the data are normalized ( i. e., divided by) by the amount of pesticide handled resulting in standard unit exposures ( milligrams of exposure per pound of active ingredient handled). Following normalization, the data are statistically summarized. The distribution of exposure values for each body part ( e. g., chest upper arm) is categorized as normal, lognormal, or " other" ( i. e., neither normal nor 14 lognormal). A central tendency value is then selected from the distribution of the exposure values for each body part. These values are the arithmetic mean for normal distributions, the geometric mean for lognormal distributions, and the median for all " other" distributions. Once selected, the central tendency values for each body part are composited into a " best fit" exposure value representing the entire body.

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

ORETF Handler Studies ( MRID 44972201): A report was submitted by the ORETF that presented data in which the application of various products used on turf by homeowners and lawncare operators ( LCOs) was monitored. All of the data submitted in this report were completed in a series of studies. The study that monitored LCO exposure using a low pressure, high volume turf handgun ( ORETF Study OMA002) is summarized below as is the study that monitored LCO exposure scenarios using a push cyclone granular spreader ( ORETF Study OMA001).

LCO Handgun Sprayer: A mixer/ loader/ applicator study was performed by the Outdoor Residential Exposure Task Force ( ORETF) using Dacthal as a surrogate compound to determine " generic" exposures to individuals applying a pesticide to turf with a low pressure " nozzle gun" or " handgun" sprayer. Dermal and inhalation exposures were estimated using whole body passive dosimeters and breathing zone air samples on OVS tubes. Inhalation exposure was calculated using an assumed respiratory rate of 17 liters per minute for light work ( NAFTA, 1999), the actual sampling time for each individual, and the pump flow rate. All results were normalized for pounds active ingredient handled. A total of 90 replicates were monitored using 17 different subjects. Four different formulations of dacthal [ 75% wettable powder ( packaged in 4 and 24 pound bags), 75% wettable powder in water soluble bags ( 3 pound bag), 75% water dispersable granules ( 2 pound bag) and 55% liquid flowable ( 2.5 gallon container)] were applied by five different LCOs to actual residential lawns at each site in three different locations ( Ohio, Maryland, and Georgia) for a total of fifteen replicates per formulation. An additional ten replicates at each site were monitored while they performed spray application only using the 75 percent wettable powder formulation. A target application rate of 2 pounds active ingredient was used for all 15 replicates ( actual rate achieved was about 2.2 pounds active ingredient per acre). Each replicate treated a varying number of actual client lawns to attain a representative target of 2.5 acres ( 1 hectare) of turf. The exposure periods averaged five hours twenty one minutes, five hours thirtynine minutes, and six hours twenty four minutes, in Ohio, Maryland and Georgia, respectively. Average time spent spraying at all sites was about two hours. All mixing, loading, application, adjusting, calibrating, and spill clean up procedures were monitored, except for typical end of day clean up activities, e. g. rinsing of spray tank, etc. Dermal exposure was measured using inner and outer whole body dosimeters, hand washes, face/ neck washes, and personal air monitoring devices. All test subjects wore one piece, 100 percent cotton inner dosimeters beneath 100 percent cotton long sleeved shirt and long pants, rubber boots and nitrile gloves. Gloves are typically worn by most LCOs, and required by many pesticide labels for mixing and loading. Overall, residues were highest on the upper and lower leg portions of the dosimeters In general, concurrent lab spikes produced mean recoveries in the range of 78 120 percent, with the exception of OVS sorbent tube sections which produced mean recoveries as low as 65.8 percent. Adjustment for recoveries from field fortifications were performed on each dosimeter section or sample matrix for each study participant, using the mean recovery for the closest field spike level for each matrix and correcting the value to 100 percent. The unit exposures are presented in Table 4 below.

Table 4: ORETF LCO Exposure Study Data Summary ( MRID 44972201): Handgun Sprayer Application Method Inhalation Unit Exposure ( µ g/ lb ai) 1 LCO Handgun Spray Mixer/ Loader/ Applicator Liquid Flowable 1.8 1Air concentration ( mg/ m3/ lb ai) calculated using NAFTA ` 99 standard breathing rate of 17 lpm ( 1 m3/ hr)

LCO Push Cyclone Granular Spreader: A loader/ applicator study was performed by the Outdoor Residential Exposure Task Force ( ORETF) using Dacthal ( active ingredient DCPA, dimethyl tetrachloroterephthalate) as a surrogate compound to determine " generic" exposures of lawn care operators ( LCOs) applying a granular pesticide formulation to residential lawns. Surrogate chemicals were chosen by the Task Force for their representativeness based on physical chemical properties and other factors. Dacthal, which was the surrogate chemical used for the granular spreader and low pressure hand gun sprayer studies, has a molecular weight of 331.97 and a vapor pressure of 1.6 x 10 6 mm Hg, and is believed to be an appropriate surrogate for many relatively nonvolatile pesticides. The study was designed to simulate a typical work day for a LCO applying granular pesticide formulation to home lawns. Each LCO replicate loaded and applied approximately 3.3 lb ai ( 360 lb formulated product) over a period of about 4 hours to 15 simulated residential lawns ( 6480 ft2 each) with a rotary type spreader. The average industry application rate of 2 lb ai/ acre was simulated ( actual rate achieved was about 1.9 lb ai/ acre). The monitoring period included simulated driving, placing the spreader onto and off of the truck, carrying and loading the formulation in the spreader, and the actual application. Incidental activities such as repairs, cleaning up spills, and disposing of empty bags were monitored. 16 A total of 40 replicates ( individual test subjects) were monitored using passive dosimetry ( inner and outer whole body dosimeters, hand washes, face/ neck wipes, and personal inhalation monitors with OVS tubes). Inhalation exposure was calculated using an assumed respiratory rate of 17 Lpm ( 1 m3/ hr) for light work ( NAFTA, 1999), the actual sampling time for each individual, and the pump flow rate. All results were normalized for lb ai handled. Twelve professional lawn care operators ( LCO) participated in the study. Ten individuals per day ( 20 per site) were monitored over 4 days at 2 different sod farms near Columbus, Ohio. Each replicate consisted of a LCO loading and applying approximately 3.3 lb ai / 360 lb formulated product ( 1.5 kg ai/ 163 kg formulated product) to 15 simulated residential lawns, for an approximate total duration of 4 hours and total area of 2.2 acres ( 0.9 ha). Twenty test subjects wore chemical resistant gloves during all loading and application activities and moving the spreader on and off the truck, then removed and place the gloves in the truck during simulated driving time. The other twenty test subjects did not wear gloves during any activity. Each test subject wore long sleeve cotton shirts and pants over one piece cotton inner dosimeters. Both outer and inner dosimeters were analyzed to estimate potential exposure for a number of clothing scenarios. Unit exposures for the granular push spreader are presented in Table 5 below.

Table 5: ORETF LCO Exposure Study Data Summary ( MRID 44972201): Granular Spreader Application Method Inhalation Unit Exposure ( µ g/ lb ai) 1 LCO Push Cyclone Granular Spreader 7.3 1Air concentration ( mg/ m3/ lb ai) calculated using NAFTA ` 99 standard breathing rate of 17 lpm ( 1 m3/ hr)

2.1.2 Sodium Chlorate Handler Exposure Scenarios It has been determined that exposure to pesticide handlers is likely during the occupational use of sodium chlorate in a variety of occupational environments. The anticipated use patterns and current labeling indicate several occupational exposure scenarios based on the types of equipment and techniques that can potentially be used for sodium chlorate applications. The quantitative exposure/ risk assessment developed for occupational handlers is based on the following scenarios. [ Note: The scenario numbers correspond to Table 6: Sodium Chlorate  Short and Intermediate Term Occupational Inhalation Exposure.]

Mixer/ Loaders: ( 1a) Liquids for Aerial Applications; ( 1b) Liquids for Groundboom Applications; ( 1c) Liquids for Rights of Way Sprayer Applications; ( 2) Granules for Tractor drawn Broadcast Spreader Applications;

Applicators: ( 3a) Sprays via aerial equipment ( Enclosed cockpit); ( 3b) Sprays via Groundboom ( Open cab); 17 ( 3c) Sprays via Rights of Way Sprayer; ( 4) Granules via Tractor drawn Broadcast Spreader ( Open cab);

Flaggers: ( 5) Flagging for Aerial Sprays;

Mixer/ Loader/ Applicators & Loader/ Applicators: ( 6) Liquid: Low Pressure Handwand Sprayer; ( 7) Liquid: Handgun Sprayer; ( 8) Granulars: Belly Grinder; ( 9) Granulars: Push type Spreader.

2.1.3 Non cancer Sodium Chlorate Handler Exposure and Assessment The occupational handler exposure and non cancer risk calculations are presented in this section. ( See Appendix 2 for sodium chlorate exposure calculation spreadsheets.)

<IP_ADDRESS> Non cancer Sodium Chlorate Handler Exposure and Risk Calculations Non cancer risks were calculated using the Margin of Exposure ( MOE) which is a ratio of the daily dose to the toxicological endpoint of concern. Daily dose values are calculated by first calculating exposures by considering application parameters ( i. e., rate and area treated) along with unit exposures. Exposures were then normalized by body weight and adjusted for absorption factors as appropriate to calculate dose levels. Then MOEs were calculated.

Daily Exposure: The daily exposure and daily dose to handlers were calculated as described below. The first step was to calculate daily inhalation exposure using the following formula:

Where:

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

Daily Dose: Daily dose ( inhalation) was calculated by normalizing the daily inhalation exposure value by body weight and accounting for inhalation absorption. For adult handlers using 18 sodium chlorate, an average body weight of 70 kilograms was used for all exposure scenarios. Since the inhalation toxicological endpoint of concern is based on an oral study, the inhalation absorption factor is 100% ( HED assumption). Daily dose was calculated using the following formula:

Where:

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

Margins of Exposure: Finally, the calculations of daily inhalation dose received by handlers were then compared to the appropriate endpoint ( i. e., NOAEL) to assess the total risk to handlers for each exposure route within the scenarios. All MOEs were calculated for inhalation exposure levels using the formula below:

Where:

MOE = Margin of exposure, value used by HED to represent risk or how close a chemical exposure is to being a concern ( unitless); ADD = ( Average Daily Dose) or the amount as absorbed dose received from exposure to a pesticide in a given scenario ( mg pesticide active ingredient/ kg body weight/ day); and NOAEL = Dose level in a toxicity study, where no observed adverse effects occurred ( NOAEL) in the study <IP_ADDRESS> Sodium Chlorate Non cancer Risk Summary All of the non cancer risk calculations for occupational sodium chlorate handlers completed in this assessment are included in Appendix 2. A summary of the short and intermediate term risks for each exposure scenario are presented in Table 6.

Short and Intermediate term Inhalation Risks Risk for most occupational handler baseline ( without a respirator) inhalation exposure 19 scenarios do not exceed HED's level of concern of 100 ( i. e, most scenarios had MOEs > 100) at the baseline level of worker protection. However, risks for the following occupational scenarios did exceed HED's level of concern at baseline.

° Mixing/ Loading liquids for groundboom application to industrial/ non crop sites at 1032 lb ai per acre ( MOE = 42) and 523 lb ai per acre ( MOE = 84); ° Loading granules for tractor drawn spreader applications to industrial/ non crop sites at 523 lb ai per acre ( MOE = 59); ° Applying sprays to industrial/ non crop sites using groundboom equipment ( open cab) at 1032 lb ai per acre ( MOE = 69); ° Applying granules to industrial/ non crop sites using a tractor drawn spreader ( open cab) at 523 lb ai per acre ( MOE = 84); ° Loading/ Applying granules to industrial/ non crop sites using a belly grinder at 523 lb ai per acre ( MOE = 65); and ° Mixing/ Loading/ Applying liquids for low pressure handwand applications to industrial/ non crop sites at 1032 lb ai per acre ( MOE = 34) and 523 lb ai per acre ( MOE = 67).

Risk mitigation for these scenarios was accomplished with the addition of a dust/ mist respirator ( with an 80% reduction factor), or, for certain scenarios, with engineering controls ( enclosed cabs or cockpits). Additionally, risks were mitigated for certain scenarios, without the application of PPE or engineering controls, by using the lower application rates. Most risks of concern were at the high end of application rate ranges ( 1032 and 523 lb ai per acre), whereas at lower rates the risks were not of concern ( MOEs > 100 at lower application rates). 20 Table 6: Sodium Chlorate: Short and Intermediate Term Occupational Inhalation Exposure Exposure Scenario ( Scenario #) Daily Area Treated1 Crop/ Target2 Application Rate3 Inhalation MOE4 Mitigation Level5 Mixer/ Loader Mixing/ Loading liquids for Aerial application ( 1a) 1200 Cotton, Corn, Rice, Dry Beans, Grain Sorghum, Flax,

Safflower, Sunflower, Soybeans 7.5 190 Baseline Fallow Land, Wheat 6 240 Baseline 350 Chili Peppers ( for processing only), Potatoes 12.5 400 Baseline Ornamental Gourds, Cucurbits ( grown for seed) 6 830 Baseline Guar Beans, Southern Peas 7.5 670 Baseline Mixing/ Loading liquids for Groundboom application ( 1b) 200 Cotton, Corn, Rice, Dry Beans, Grain Sorghum, Flax,

Safflower, Sunflower, Soybeans 7.5 1200 Baseline Fallow Land, Wheat 6 1500 Baseline 80 Chili Peppers ( for processing only), Potatoes 12.5 1800 Baseline Ornamental Gourds, Cucurbits ( grown for seed) 6 3600 Baseline Guar Beans, Southern Peas 7.5 2900 Baseline 40 Industrial/ Non Crop Sites 1032 210 PPE  80% R 523 420 PPE  80% R 132 330 Baseline Mixing/ Loading liquids for Rights of

Way Sprayer application ( 1c) 5 Rights of Way & Industrial/ Non Crop Sites 1032 340 Baseline 523 670 Baseline 132 2700 Baseline Loading granules for Tractor drawn Spreader application ( 2) 40 Industrial/ Non Crop Sites 523 300 PPE  80% R 240 130 Baseline 161 190 Baseline Applicator Aerial spray applications ( 3a) 1200 Cotton, Corn, Rice, Dry Beans, Grain Sorghum, Flax,

Safflower, Sunflower, Soybeans 7.50 3400 Engineering Control Exposure Scenario ( Scenario #) Daily Area Treated1 Crop/ Target2 Application Rate3 Inhalation MOE4 Mitigation Level5 21 Fallow Land, Wheat 6 4300 Engineering Control 350 Guar Beans, Southern Peas 7.5 12000 Engineering Control Chili Peppers ( for processing only), Potatoes 12.5 7100 Engineering Control Ornamental Gourds, Cucurbits ( grown for seed) 6 15000 Engineering Control Groundboom spray applications ( 3b) 1200 Cotton, Corn, Rice, Dry Beans, Grain Sorghum, Flax,

Safflower, Sunflower, Soybeans 7.5 1900 Baseline Fallow Land, Wheat 6 2400 Baseline 350 Guar Beans, Southern Peas 7.5 4700 Baseline Chili Peppers ( for processing only), Potatoes 12.5 2800 Baseline Ornamental Gourds, Cucurbits ( grown for seed) 6 5900 Baseline 40 Industrial/ Non Crop Sites 1032 350 PPE  80% R 1200 Engineering Control 523 140 Baseline 2300 Engineering Control 132 540 Baseline 9200 Engineering Control Rights of Way Sprayer Applications ( 3c) 5 Rights of Way & Industrial/ Non Crop Sites 1032 110 Baseline 523 210 Baseline 132 820 Baseline Tractor drawn Spreader Applications ( 4) 40 Industrial/ Non Crop Sites 523 420 PPE  80% R 460 Engineering Control 240 180 Baseline 990 Engineering Control 161 270 Baseline Exposure Scenario ( Scenario #) Daily Area Treated1 Crop/ Target2 Application Rate3 Inhalation MOE4 Mitigation Level5 22 1500 Engineering Control Flagger Flagging for Aerial Spray applications ( 5) 350 Various Agricultural Crops 12.5 1400 Baseline Mixer/ Loader/ Applicators & Loader/ Applicators M/ L/ A liquids with a Low Pressure Handwand Sprayer ( 6) 2 Industrial/ Non Crop Sites 1032 170 PPE  80% R 523 330 PPE  80% R 132 270 Baseline M/ L/ A liquids with a Handgun Sprayer ( 7) 5 Industrial/ Non Crop Sites 1032 230 Baseline 523 450 Baseline 132 1800 Baseline L/ A granules with a Belly Grinder ( 8) 1 Industrial/ Non Crop Sites 523 320 PPE  80% R 240 140 Baseline 161 210 Baseline L/ A granules with a Push type Spreader ( 9) 5 Industrial/ Non Crop Sites 523 110 Baseline 240 240 Baseline 161 360 Baseline 1 Amount treated is presented in acres/ day. ( Standard EPA/ OPP/ HED values).

2 Crops and use patterns are from label extractions ( Appendix 1), BEAD's LUIS reports, and the Sodium Chlorate Use Closure Memo ( J. Guerry, 8/ 5/ 04; 10/ 13/ 04; 11/ 15/ 04).

3 Ranges of application rates are based on values from label extractions ( Appendix 1), BEAD's LUIS reports, and the Sodium Chlorate Use Closure Memo ( J. Guerry, 8/ 5/ 04; 10/ 13/ 04;

11/ 15/ 04). Application rates upon which the analysis is based are presented as lb ai/ acre.

4 Inhalation MOE = Oral NOAEL ( 30 mg/ kg/ day) / Daily Inhalation Dose. HED LOC for MOE is 100.

5 Mitigation Levels Baseline: No respirator PPE  80% R: Dust/ mist respirator with an 80% reduction factor Engineering Control: Closed cockpit or cab 23 3.0 Residential Exposures and Risks It has been determined there is a potential for exposure in residential settings during the application process for homeowners who use products containing sodium chlorate, however a postapplication exposure assessment was not performed. This risk assessment was only completed for residential handlers.

3.1 Residential Handler Exposures and Risks HED uses the term " handlers" to describe those individuals who are involved in the pesticide application process. HED believes that there are distinct tasks related to applications and that exposures can vary depending on the specifics of each task as was described above for occupational handlers. Residential handlers are addressed somewhat differently by HED as homeowners are assumed to complete all elements of an application without use of any protective equipment.

3.1.1 Handler Exposure Scenarios Scenarios are used to define risks based on the U. S. EPA Guidelines For Exposure Assessment ( U. S. EPA; Federal Register Volume 57, Number 104; May 29, 1992). Assessing exposures and risks resulting from residential uses is very similar to assessing occupational exposures and risks, with the following exceptions:

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

C A tiered approach for personal protection using increasing levels of PPE is not used in residential handler risk assessments. Homeowner handler assessments are based on the assumption that individuals are wearing shorts, short sleeved shirts, socks, and shoes;

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

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

It has been determined that exposure to pesticide handlers is likely during the residential use of sodium chlorate in outdoor environments as a spot treatment or edging treatment around patios, along fence lines, lawn edges, around foundations, underneath or around wood decks, and in cracks and crevices of driveways. The anticipated use patterns and current labeling indicate 24 seven major residential exposure scenarios based on the types of equipment and techniques that can potentially be used to make sodium chlorate applications. The quantitative exposure/ risk assessment developed for residential handlers is based on these scenarios. [ Note: The scenario numbers correspond to Table 10: Sodium Chlorate  Short Term Residential Inhalation Exposure.]

Mixer/ Loader/ Applicators, Loader/ Applicators, & Applicators: ( 1) Liquid: Low Pressure Handwand; ( 2) RTU Liquid: Trigger Pump Sprayer; ( 3) Liquid: Sprinkler Can; ( 4) RTU One gallon, Pre packaged Sprinkler Can; ( 5) Granulars: Hand; ( 6) Granulars: Belly Grinder; ( 7) Granulars: Push type Spreader.

3.1.2 Data and Assumptions For Handler Exposure Scenarios A series of assumptions and exposure factors served as the basis for completing the residential handler risk assessments. Each assumption and factor is detailed below. In addition to these factors, unit exposures were used to calculate risk estimates. Unit exposures were taken from PHED, ORETF studies, and one proprietary study. The ORETF studies and the proprietary study are presented below. [ Note: Several of the assumptions and factors used for the assessment are similar to those used in the occupational assessment presented above. As such, only factors that are unique to the residential scenarios are presented below.]

Assumptions and Factors: The assumptions and factors used in the risk calculations include:

C Due to the lack of chemical specific data, exposures from a scenario deemed similar might be used. As an example, mixer/ loader/ applicator data for hose end sprayers were used to assess sprinkler can applications. These application methods are believed to be similar enough to bridge the data.

C HED always considers the maximum application rates allowed by labels in its risk assessments. If additional information such as average or typical rates are available, these values also may be used to allow risk managers to make a more informed risk management decision.

C Residential risk assessments are based on estimates of what homeowners would typically treat, such as the size of a lawn, or the size of a garden. The factors used for the sodium chlorate assessment were from the Health Effects Division Science Advisory Council for Exposure Policy 12: Recommended Revisions To The Standard Operating Procedures For Residential Exposure Assessment which was completed on February 22, 2001 and on 25 professional judgement. The daily volumes handled and area treated, used in each residential scenario, include:

C 1000 square feet when mixing/ loading/ applying liquids as a spot treatment with a low pressure handwand and sprinkler cans;

C 1 gallon when applying with a RTU sprinkler can and trigger pump sprayer; and,

C 1000 square feet for granular formulation spot treatments.

Residential Handler Exposure Studies: The unit exposures that were used in this assessment were based on PHED, ORETF studies, and one proprietary study.

ORETF Handler Studies ( MRID 44972201): A report was submitted by the ORETF that presented data in which the application of various products used on turf by homeowners and LCOs was monitored. All of the data submitted in this report were completed in a series of studies.

Homeowner Hose End Sprayer: A mixer/ loader/ applicator study was performed by the ORETF using Diazinon as a surrogate compound to determine " generic" exposures to individuals applying a pesticide to turf with a dial type hose end sprayer. Dermal and inhalation exposures were estimated using whole body passive dosimeters and breathing zone air samples on OVS tubes. Inhalation exposure was calculated using an assumed respiratory rate of 17 liters per minute for light work ( NAFTA, 1999), the actual sampling time for each individual, and the pump flow rate. All results were normalized for pounds active ingredient handled. A total of 30 replicates were monitored throughout the study. Diazinon ( 25% emulsifiable concentrate) was applied by homeowners to actual residential lawns at a site in Maryland. A target application rate of 4 pounds active ingredient was used for all replicates. Each replicate monitored the test subject treating 5,000 ft2 of turf and handling a total of 0.5 lb ai/ replicate. The exposure periods ( mixing/ loading/ applying) averaged seventy five minutes. Dermal exposure was measured using inner and outer whole body dosimeters, hand washes, face/ neck washes, and personal air monitoring devices. In general, concurrent lab spikes produced mean recoveries in the range of 87 103 percent. Adjustment for recoveries from field fortifications ( 79 104 %) were performed on each dosimeter section or sample matrix for each study participant, using the mean recovery for the closest field spike level for each matrix and correcting the value to 100 percent. The unit exposures are presented below. [ Note the data were found to be lognormally distributed. As a result, all exposure values are geometric means.]

Table 7: ORETF Resident Applicator Exposure Study Data Summary ( MRID 44972201)  Hose end Sprayer Type Inhalation ( µ g/ lb ai handled) 1 Hose end Sprayer ( Mix your own) 17 Hose end Sprayer 11 Table 7: ORETF Resident Applicator Exposure Study Data Summary ( MRID 44972201)  Hose end Sprayer Type Inhalation ( µ g/ lb ai handled) 1 26 ( ready to use)

All unit exposures are geometric means.

1Air concentration ( mg/ lb ai) calculated using NAFTA ` 99 standard breathing rate of 17 lpm ( 1 m3/ hr).

Homeowner Push Type Spreader ( OMA003): A mixer/ loader/ applicator study was performed by the ORETF using Dacthal ( active ingredient DCPA, dimethyl tetrachloroterephthalate) as a surrogate compound to determine " generic" exposures of individuals applying a granular pesticide formulation to residential lawns. A total of 30 volunteers were monitored using passive dosimetry ( inner and outer whole body dosimeters, hand washes, face/ neck wipes, and personal inhalation monitors). Each volunteer carried, loaded, and applied two 25 lb bags of fertilizer and pesticide granules ( 0.89% active ingredient) with a rotary type spreader to a lawn covering 10,000 ft2. The target application rate was 2 lb ai/ acre ( actual rate achieved was about 1.9 lb ai/ acre). The average application time was 22 minutes, including loading the rotary push spreader and disposing of the empty bags. Each replicate handled approximately 0.45 lb ai. The study results are normalized to kg ai handled. The US EPA HED typically assumes that residential applicators wear short pants and short sleeved shirts, as described in the Residential SOPs ( 1997). Therefore, the table reports the dermal exposures for the short pants and short sleeve shirt clothing scenario only.

Table 8: ORETF Resident Applicator Exposure Study Data Summary ( MRID 44972201)  Push Spreader Type Inhalation ( µ g ai/ lb handled)

Push Type Spreader 0.88 Proprietary Studies One proprietary study was used to obtain unit exposures for handlers applying ready touse liquid formulations via trigger pump sprayer. This study is summarized below:

EPA MRID 41054701 ( Propoxur trigger pump sprayer study): A total of 15 applicator events during residential applications using a hand operated trigger pump sprayer, attached with an 18 inch hose to half gallon cans containing 0.95 percent propoxur, were completed in this study. The study was completed between October 26 and November 1, 1988 in the Kansas City Missouri metro area. Each person monitored in the study was a Bayer ( the sponsor corporation) employee. Three employees were used to complete all replicates. In each replicate, " each applicator used a separate one half gallon can of Raid for each house. The cap was removed from the top of the can and the hose sprayer was attached by inserting the dip tube into the can and tightening the screw cap. The sprayer was primed by pumping the trigger. The applicator treated 27 the outside of the home in areas where pests were likely to be found, such as screens, door and window frames, foundation walls, patios, porches, stoops, and decks. When the application was completed, the hose sprayer was secured under the handle of the can." The data included in the study indicate that exposure durations ranged from 9 to 21 minutes per replicate and the amount of active ingredient handled ranged from 0.16 to 0.4 oz ( i. e., 0.01 to 0.025 lb ai). Dermal ( nonhand) exposure monitoring during each replicate was completed using gauze sponges held in " aluminized paper holders" with an open sampling surface area of 24.6 cm2 while hand exposures were quantified with the handwash technique ( 2  200 mL aliquots of ethanol per hand for a total volume of 800 mL per person). Inhalation exposures were monitored using standard personal sampling pumps operating a 1 liter per minute with quartz microfiber filters. Samples were collected in this study to represent exposures when a person was wearing normal work clothing ( i. e., long pants and long sleeved shirts) and chemical resistant gloves.

Analysis of propoxur residues was completed with high performance liquid chromatography, post column derivatization, and fluorescence detection. The limits of quantification ( LOQ) were 10 µ g per sample for the handwash solutions, 0.1 µ g/ sample for the inhalation filters, and 0.03 µ g/ cm2 for the dermal patch samples. Field and laboratory recovery data were generated for all media. This study was reviewed in September 1989 under EPA contract 68 02 4254 by Versar. The values used for regulatory purposes have been excerpted from that review ( including recovery results). Average laboratory recovery for all media ranged from 99.2 to 109 percent while the coefficients of variation for each media were generally less than 5 ( i. e., for the patches, the CV = 16.5). Patches and filters were fortified at 1 µ g/ sample while hand rinses were fortified at either 200 or 1000 µ g/ sample. Average field recovery results ranged from 90.3 to 102.2 percent while coefficients of variation also were generally less than 5 ( i. e., inside patch CV= 6.9). Patches were fortified at levels from 1 to 50 µ g/ sample, hand rinses were fortified at 200 µ g/ sample, and filters were fortified at 0.2 µ g/ sample. Unit exposures for this scenario are presented below in Table 8.

Table 9: Propoxur Trigger Pump Sprayer Study ( MRID 41054701)

Type Inhalation ( µ g ai/ lb handled)

Trigger Pump Sprayer 123 3.1.3 Residential Handler Exposure and Non Cancer Risk Estimates The residential handler exposure and non cancer risk calculations are presented in this section. Noncancer risks were calculated using the Margin of Exposure ( MOE) as described in Section 2.1.3. Assessing exposures and risks resulting from residential uses is very similar to assessing occupational exposures and risks, except as described above in Section 3.1.1. The other major difference with residential risk assessments is that the uncertainty factor which defines the level of risk concern has the additional FQPA safety factor applied. In the case of sodium chlorate, it was decided that the factor should be 1X based on the recently revised FQPA SFC standard operating procedures. Therefore, the overall uncertainty factor applied to sodium 28 chlorate for residential handler risk assessments is 100 which is based on the FQPA safety factor of 1X along with the 10x for inter species extrapolation and 10x for intra species sensitivity.

Noncancer Risk Summary: All of the noncancer risk calculations for residential sodium chlorate handlers completed in this assessment are included in Appendix 2.

HED believes that the scenarios assessed in this document represent worse case exposures and risks resulting from use of sodium chlorate in residential environments. It should also be noted that there were many other scenarios where medium to low PHED quality data were used to complete the assessment. Data quality should be considered in the interpretation of the uncertainties associated with each risk value presented.

Short term risks for residential handlers ( intermediate term exposures are not likely, because of the sporadic nature of applications by homeowners) are presented below in Table 10. All risks are not of concern because all MOEs are greater than the level of concern of 100. 29 Table 10: Sodium Chlorate  Short Term Residential Inhalation Exposure1 Exposure Scenario ( Scenario #) Daily Area Treated2 Crop/ Target3 Application Rate4 Inhalation MOE5 Mixer/ Loader/ Applicators, Loader/ Applicators, & Applicators M/ L/ A liquids with a Low Pressure Handwand Sprayer ( 1) 1000 Spot/ edging treatment 23.7 3000 L/ A RTU liquid with a Trigger Pump Sprayer ( 2) 1 Spot/ edging treatment 0.196 87000 M/ L/ A liquids with a Sprinkler Can ( 3) 1000 Spot/ edging treatment 23.7 5200 Applying liquid with a RTU Sprinkler Can ( 4) 1 Spot/ edging treatment 0.27 710000 Applying granules by Hand ( 5) 1000 Spot/ edging treatment 12 370 L/ A granules with a Belly Grinder ( 6) 1000 Spot/ edging treatment 12 2800 L/ A granules with a Push type Spreader ( 7) 1000 Spot/ edging treatment 12 200000 1 Residential exposures assessments do not include PPE.

2 Amount treated is presented in ft2/ day, except for Scenario # s 2 and 4 which are presented in gallons/ day. ( Standard EPA/ OPP/ HED values).

3 Crops and use patterns are from label extractions ( Appendix 1), BEAD's LUIS reports, and the Sodium Chlorate Use Closure Memo ( J. Guerry, 8/ 5/ 04; 10/ 13/ 04; 11/ 15/ 04).

4 Ranges of application rates are based on values from label extractions ( Appendix 1), BEAD's LUIS reports, and the Sodium Chlorate Use Closure Memo ( J. Guerry, 8/ 5/ 04; 10/ 13/ 04;

11/ 15/ 04). Application rates upon which the analysis is based are presented as lb ai/ 1000 ft2, except for Scenario # s 2 and 4 which are presented in lb ai/ gallon.

5 Inhalation MOE = Oral NOAEL ( 30 mg/ kg/ day) / Daily Inhalation Dose. HED LOC for MOE is 100. 30 4.0 Occupational and Residential Handler Exposure and Risk Estimates for Cancer An occupational and residential cancer risk assessment was not conducted for sodium chlorate. The exposure durations for occupational and residential handlers are inconsistent with the mechanism of carcinogenicity. A 2 year NTP bioassay to determine the potential of sodium chlorate to induce thyroid tumors in laboratory animals ( rats and mice) has been recently reported in a draft form ( NTP, 2004). A final report of this study is expected during 2005. In these tests, there was some evidence of thyroid gland follicular cell carcinogenicity in male rats which may be attributed to the imbalance of thyroid hormones ( reduced T 3 and T 4 and elevated TSH) seen in these studies as a result of exposure to high doses of sodium chlorate. Current EPA HED policy states that " nonmutagenic pesticides that induce elevated levels of TSH and thyroid follicular cell tumors in the rat should be classified as not likely to be carcinogenic to humans at doses that do not alter rat thyroid hormone homeostasis" (( HED hot sheet # 23). In female mice there was equivocal and marginal evidence of increased pancreatic islet carcinoma.

5.0 Summary of Risk Concerns and Data Gaps for Occupational and Residential Handlers The occupational and residential exposure assessment conducted for sodium chlorate is a highly conservative assessment intended to encompass all of the major uses. Chemical specific exposure studies are unavailable for handler scenarios so HED default exposure values and assumptions were used. HED exposure values and assumptions are selected to be realistic and yet provide a reasonable certainty that the exposures are not underestimated. High end assumptions were used for areas treated for handlers. Application rates used in handler assessments are presented as ranges ( from low end to high end application rates) to reflect different product labels. It should be noted that the extrapolation from label specific square foot based application rates to acreage based rates ( necessary to represent the possibility of professional applicators to treat more than one acre of crop/ non crop area per day) resulted in considerably large amounts of active ingredient handled per day, not to mention the corresponding diluted solution volumes ( i. e, 1032 lbs ai/ 2196 gallons solution/ acre). Though these may well be exorbitant amounts, due to label deficiencies and lack of chemical specific information regarding amount handled/ treated per day, use of HED standard defaults and assumptions was necessary until further information is available.

There were no risks of concern for residential handler exposure scenarios. Risks of concern for occupational scenarios, as outlined in Section <IP_ADDRESS>, were mitigated using a dust/ mist respirator with an 80% reduction factor or engineering controls. Using low end application rates also mitigated risks of concern without the application of a respirator or engineering controls. No handler scenarios have data gaps.

6.0 Occupational and Residential Postapplication Exposures and Risks HED uses the term " postapplication" to describe exposures to individuals that occur as a 31 result of being in an environment that has been previously treated with a pesticide ( also referred to as reentry exposure). HED believes that there are distinct job functions or tasks related to the kinds of activities that occur in previously treated areas. Job requirements ( e. g., the kinds of jobs to cultivate a crop), the nature of the crop or target that was treated, and the how chemical residues degrade in the environment can cause exposure levels to differ over time.

A postapplication exposure assessment was not conducted for the following reasons:

1) Although potential for postapplication dermal exposure in residential and occupational settings exists, sodium chlorate is an inorganic salt, therefore significant absorption of sodium chlorate through the skin is not expected. 2) Postapplication inhalation exposure is not expected due to a negligible vapor pressure. 3) Postapplication exposure assessments for residential settings ( dermal and incidental oral) are not typically performed for spot treatments/ edging treatments. 32 APPENDIX 1 Sodium Chlorate Label Extraction Tables Table A: Agricultural Defoliants/ Desiccants Registered Product Crop/ Use App Equipment Max App Rate ( ai) Comments/ Description Helena 2 lb. Sodium Chlorate Defoliant Desiccant Reg No. 5905 87 Cotton Ground 5 lb/ A Liquid ( SC)

Baseline PPE No chemigation/ irrigation 12 hour REI 7 day PHI ( cotton, grain sorghum)

No grazing ( cotton)

Aerial Grain Sorghum Ground 6 lb/ A Aerial Helena 3 lb. Chlorate Defoliant Desiccant Reg No. 5905 118 Chili Peppers ( processing only) Ground 7.5 lb/ A Liquid ( SC)

Baseline PPE No chemigation/ irrigation 12 hour REI 7 day PHI ( dry beans, flax, grain sorghum, guar beans, rice, safflower,

soybeans, sunflower)

10 day PHI ( chilipeppers, corn)

14 day PGI ( corn, flax, rice, sunflower)

No grazing ( dry beans, guar beans,

soybeans, sunflower)

Aerial Corn Ground 6 lb/ A Aerial Cotton Ground 4.5 lb/ A Aerial Dry Beans Ground 6 lb/ A Aerial Flax Ground 6 lb/ A Aerial Grain Sorghum Ground 6 lb/ A 33 Aerial Guar Beans Ground 6 lb/ A Aerial Rice Ground 6 lb/ A Aerial Safflowers Ground 6 lb/ A Aerial Southern peas Ground 6 lb/ A Aerial Soybeans Ground 6 lb/ A Aerial Sunflower Ground 6 lb/ A Aerial 34 Helena 6 lb. Sodium Chlorate Defoliant Desiccant Reg No. 5905 461 Dry Beans Ground 6 lb/ A Liquid ( SC)

PPE = Coveralls ( over short shirt/ pants),

chem resistant gloves, chem resistant footwear, protective eyewear,

chemresistant headwear, chem resistant apron.

No chemigation/ irrigation 12 hour REI California restriction ( dry beans, chili peppers, guar beans, flax, corn,

safflower, soybeans, sunflower)

7 day PHI ( dry beans, guar beans,

cotton, flax, grain sorghum, rice,

safflower, soybeans, sunflower)

14 day PGI ( corn, rice)

No grazing ( dry beans, guar beans,

cotton, safflower, soybeans, sunflower)

10 day PHI ( chilipeppers,

14 day PHI ( corn)

Aerial Chili Peppers ( processing only) Ground 7.5 lb/ A Aerial Guar Beans Ground 6 lb/ A Aerial Cotton Ground 4.5 lb/ A Aerial Flax Ground 6 lb/ A Aerial Grain Sorghum Ground 4.5 lb/ A Aerial Corn Ground 6 lb/ A Aerial Rice Ground 6 lb/ A Aerial Safflower Ground 6 lb/ A Aerial Soybeans Ground 6 lb/ A Aerial 35 Sunflower Ground 6 lb/ A Aerial LEAFEX 2 Defoliant Desiccant Reg No. 7001 46 Cotton Ground 5.28 lb/ A ( AZ only)

4.69 lb/ A ( all other states) Liquid ( SC)

PPE = Coveralls ( over short shirt/ pants),

dust/ mist filtering respirator,

chemresistant footwear, chem resistant gloves, protective eyewear,

chemresistant headwear, chem resistant apron 7 day PHI 12 hour REI No more than two apps.

No chemigation/ irrigation No grazing Use of NIS or COC Aerial LEAFEX 3 Defoliant Desiccant Reg No. 7001 335 Cotton Ground 5.25 lb/ A ( AZ only)

4 lb/ A ( all other states) Liquid ( SC)

PPE = Coveralls ( over short shirt/ pants),

dust/ mist filtering respirator,

chemresistant footwear, chem resistant gloves, protective eyewear,

chemresistant headwear, chem resistant apron Use of NIS or COC No chemigation/ irrigation 7 day PHI ( cotton, grain sorghum, rice,

soybeans, sunflower)

14 day PGI ( grain sorghum, corn, rice,

sunflower)

14 day PHI ( corn)

No grazing ( cotton, soybeans)

12 hour REI No more than two apps.

Aerial Grain Sorghum and Milo Ground 6 lb/ A Aerial Corn Aerial 6 lb/ A Rice Aerial 6 lb/ A Soybean Aerial 6 lb/ A Sunflower Aerial 6 lb/ A 36 SHED A LEAF " L"

Reg No. 8867 39 Cotton Ground 3.75 lb/ A Liquid ( SC)

PPE = Baseline plus gloves 12 hour REI 14 day PHI ( cotton)

No grazing ( cotton, soybean  MS)

14 day PGI ( rice  MS)

7 day PHI ( rice  MS, soybean  MS)

Aerial Rice ( MS only) Aerial 4.5 lb/ A Soybean ( MS only) Ground 6 lb/ A Aerial Riverside Sodium Chlorate Reg No. 9779 142 Corn Aerial 6 lb/ A Liquid ( SC)

PPE = Baseline plus gloves, protective eyewear 12 hour REI 14 day PHI ( corn)

14 day PGI ( corn, rice)

7 day PHI ( cotton, dry beans, grain sorghum, rice, safflower, southern peas,

soybeans, sunflower)

No grazing ( cotton, dry beans, safflower,

southern peas, soybeans, sunflower)

Cotton Ground 3.75 lb/ A Aerial Dry beans Ground 6 lb/ A Aerial Grain Sorghum Ground 6 lb/ A Aerial Rice Aerial 6 lb/ A Safflower Ground 6 lb/ A Aerial Southern peas Ground 6 lb/ A Aerial Soybeans Ground 6 lb/ A Aerial 37 Sunflower Ground 6 lb/ A Aerial Sodium Chlorate 6 Reg No. 9779 305 Dry beans Ground 6 lb/ A Liquid ( SC)

PPE = Baseline No chemigation/ irrigation 12 hour REI 7 10 day PHI ( dry beans, chilipeppers,

cotton, flax, grain sorghum, guar beans,

rice, safflower, southern peas, soybeans,

sunflower)

14 day PGI/ PHI ( corn, flax, rice)

No grazing ( cotton, guar beans,

safflower, soybeans, sunflower)

Aerial Chili Peppers ( processing only) Ground 7.5 lb/ A Aerial Corn Aerial 6 lb/ A Cotton Ground 4.5 lb/ A Aerial Flax Aerial 6 lb/ A Grain Sorghum Ground 6 lb/ A Aerial Guar beans Ground 6 lb/ A Aerial Rice Aerial 6 lb/ A Safflower Ground 6 lb/ A Aerial Southern peas Ground 6 lb/ A Aerial Soybeans Ground 6 lb/ A 38 Aerial Sunflower Ground 6 lb/ A Aerial D LEAF M Cotton Defoliant Reg No. 10163 122 Cotton Ground 4 lb/ A Liquid ( SC)

No statement of PPE No chemigation/ irrigation No grazing 7 day PHI Aerial Britz Cotton Defoliant concentrate Reg No. 10951 7 Cotton Ground 4.58 lb/ A Liquid ( SC)

Baseline PPE plus gloves 12 hour REI 7 day PHI No grazing Aerial First Choice Cotton Defoliant Concentrate Reg No. 11656 90 Cotton Ground 5.52 lb/ A Liquid ( SC)

Baseline PPE plus gloves 12 hour REI No chemigation/ irrigation 7 day PHI ( cotton)

10 day PHI ( chilipeppers, grain sorghum)

No grazing ( cotton)

14 day PGI ( grain sorghum)

Aerial Chili Peppers ( processing only) Ground 9.2 lb/ A Aerial Grain Sorghum Ground 4.97 lb/ A Aerial 39 Drexel Defol Reg No. 19173 12 &

GA890007 ( Ornamental Gourds) Chili Peppers ( processing only) Ground 7.5 lb/ A Liquid ( SC)

PPE = Coveralls ( over short shirt/ pants),

dust/ mist filtering respirator,

chemresistant footwear, chem resistant gloves, protective eyewear,

chemresistant headwear, chem resistant apron 12 hour REI Use of NIS or COC 10 day PHI ( chilipeppers, potatoes)

14 day PHI ( corn)

14 day PGI ( corn, flax, rice, sunflower)

7 day PHI ( dry beans, flax, grain sorghum, guar beans, rice, safflower,

southern peas, soybeans, sunflower,

ornamental gourds GA only)

No grazing ( cotton, dry beans, guar beans, potatoes, safflower, southern peas, soybeans, ornamental gourds GA only)

Aerial Corn Aerial 6 lb/ A Cotton Ground 4.5 lb/ A Aerial Dry beans Ground 6 lb/ A Aerial Flax Ground 6 lb/ A Aerial Grain Sorghum Ground 6 lb/ A Aerial Guar beans Ground 6 lb/ A Aerial Potatoes Ground 6 lb/ A Aerial Rice Aerial 6 lb/ A Safflowers Ground 6 lb/ A Aerial Southern peas Ground 6 lb/ A Aerial 40 Soybeans Ground 6 lb/ A Aerial Sunflower Ground 6 lb/ A Aerial Ornamental Gourds ( GA only) Ground 6 lb/ A Aerial Drexel Defol 6 Reg No. 19173 85 Chili Peppers ( processing only) Ground 7.5 lb/ A Liquid ( SC)

PPE = Coveralls ( over short shirt/ pants),

dust/ mist filtering respirator,

chemresistant footwear, chem resistant gloves, protective eyewear,

chemresistant headwear, chem resistant apron 12 hour REI Use of NIS or COC 10 day PHI ( chilipeppers, potatoes)

14 day PHI ( corn)

14 day PGI ( corn, flax, rice, sunflower,

cucurbits)

7 day PHI ( dry beans, flax, grain sorghum, guar beans, rice, safflower,

southern peas, soybeans, sunflower)

No grazing ( cotton, dry beans, guar beans, potatoes, safflower, southern peas, soybeans)

Aerial Corn Aerial 6 lb/ A Cotton Ground 4.5 lb/ A Aerial Cucurbits ( grown for seed) Ground 6 lb/ A Aerial Dry beans Ground 6 lb/ A Aerial Flax Ground 6 lb/ A Aerial Grain Sorghum Ground 6 lb/ A Aerial Guar beans Ground 6 lb/ A 41 Aerial Potatoes Ground 6 lb/ A Aerial Rice Aerial 6 lb/ A Safflowers Ground 6 lb/ A Aerial Southern peas Ground 6 lb/ A Aerial Soybeans Ground 6 lb/ A Aerial Sunflower Ground 6 lb/ A Aerial 42 Drexel Defol 6W Reg No. 19173 265 &

CA920017 ( Fallow Land) Chili Peppers ( processing only) Ground 7.5 lb/ A Liquid ( SC)

PPE = Coveralls ( over short shirt/ pants),

dust/ mist filtering respirator,

chemresistant footwear, chem resistant gloves, protective eyewear,

chemresistant headwear, chem resistant apron 12 hour REI Use of NIS or COC 10 day PHI ( chilipeppers, potatoes)

14 day PHI ( corn)

14 day PGI ( corn, flax, rice, sunflower,

cucurbits)

7 day PHI ( dry beans, flax, grain sorghum, guar beans, rice, safflower,

southern peas, soybeans, sunflower)

No grazing ( cotton, dry beans, guar beans, potatoes, safflower, southern peas, soybeans)

Aerial Corn Aerial 6 lb/ A Cotton Ground 4.5 lb/ A Aerial Cucurbits ( grown for seed) Ground 6 lb/ A Aerial Dry beans Ground 6 lb/ A Aerial Flax Ground 6 lb/ A Aerial Grain Sorghum Ground 6 lb/ A Aerial Guar beans Ground 6 lb/ A Aerial Potatoes ( CA restriction) Ground 6 lb/ A Aerial Rice Aerial 6 lb/ A Safflowers Ground 6 lb/ A Aerial 43 Southern peas Ground 6 lb/ A Aerial Soybeans Ground 6 lb/ A Aerial Sunflower Ground 6 lb/ A Aerial Fallow Ground Ground 6 lb/ A Aerial Drexel Defol 5 Reg No. 19173 388 Chili Peppers ( processing only) Ground 7.5 lb/ A Liquid ( SC)

PPE = Coveralls ( over short shirt/ pants),

dust/ mist filtering respirator,

chemresistant footwear, chem resistant gloves, protective eyewear,

chemresistant headwear, chem resistant apron 12 hour REI Use of NIS or COC 10 day PHI ( chilipeppers, potatoes)

14 day PHI ( corn)

14 day PGI ( corn, flax, rice, sunflower,

cucurbits)

7 day PHI ( dry beans, flax, grain sorghum, guar beans, rice, safflower,

southern peas, soybeans, sunflower)

No grazing ( cotton, dry beans, guar beans, potatoes, safflower, southern peas, soybeans)

Aerial Corn Aerial 6 lb/ A Cotton Ground 4.5 lb/ A Aerial Cucurbits ( grown for seed) Ground 6 lb/ A Aerial Dry beans Ground 6 lb/ A Aerial Flax Ground 6 lb/ A Aerial Grain Sorghum Ground 6 lb/ A 44 Aerial Guar beans Ground 6 lb/ A Aerial Potatoes Ground 6 lb/ A Aerial Rice Aerial 6 lb/ A Safflowers Ground 6 lb/ A Aerial Southern peas Ground 6 lb/ A Aerial Soybeans Ground 6 lb/ A Aerial Sunflower Ground 6 lb/ A Aerial 45 Drexel Defol 750 Reg No. 19173 486 Chili Peppers ( processing only) Ground 7.5 lb/ A Liquid ( SC)

PPE = Coveralls ( over short shirt/ pants),

dust/ mist filtering respirator,

chemresistant footwear, chem resistant gloves, protective eyewear,

chemresistant headwear, chem resistant apron 12 hour REI Use of NIS or COC 10 day PHI ( chilipeppers, potatoes)

14 day PHI ( corn)

14 day PGI ( corn, flax, rice, sunflower,

cucurbits)

7 day PHI ( dry beans, flax, grain sorghum, guar beans, rice, safflower,

southern peas, soybeans, sunflower)

No grazing ( cotton, dry beans, guar beans, potatoes, safflower, southern peas, soybeans)

Aerial Corn Aerial 6 lb/ A Cotton Ground 4.5 lb/ A Aerial Cucurbits ( grown for seed) Ground 6 lb/ A Aerial Dry beans Ground 6 lb/ A Aerial Flax Ground 6 lb/ A Aerial Grain Sorghum Ground 6 lb/ A Aerial Guar beans Ground 6 lb/ A Aerial Potatoes Ground 6 lb/ A Aerial Rice Aerial 6 lb/ A Safflowers Ground 6 lb/ A Aerial 46 Southern peas Ground 6 lb/ A Aerial Soybeans Ground 6 lb/ A Aerial Sunflower Ground 6 lb/ A Aerial Clean Crop Sodium Chlorate Reg No. 34704 695 Cotton Ground 4.5 lb/ A Liquid ( SC)

Baseline PPE No chemigation/ irrigation 7 day PHI ( cotton, grain sorghum, rice,

safflower, soybeans, sunflower)

No grazing ( cotton, safflower, soybeans,

sunflower)

14 day PGI ( rice)

Aerial Grain Sorghum Ground 6 lb/ A Aerial Rice Aerial 6 lb/ A Safflower ( CA restriction) Ground 6 lb/ A Aerial Soybeans ( CA restriction) Ground 6 lb/ A Aerial Sunflower ( CA restriction) Ground 6 lb/ A Aerial MAPCO Brand Poly Foliant Liquid Defoliant Reg No. 49517 1 Cotton Ground 5.76 lb/ A Liquid ( SC)

Baseline PPE plus gloves No chemigation/ irrigation 12 hour REI 7 day PHI No grazing 47 Aerial Moore AG Brand Poly Foliant V Defoliant Desiccant Reg No. 49517 3 Dry beans Ground 7.5 lb/ A Liquid ( SC)

PPE = Coveralls ( over long shirt/ pants),

gloves, chem resistant footwear,

protective eyewear, chem resistant apron 12 hour REI No chemigation/ irriation 7 day PHI ( dry beans, guar beans,

cotton, flax, grain sorghum, rice,

safflower, soybeans, sunflower, southern peas, potatoes)

No grazing ( dry beans, guar beans,

cotton, safflower, soybeans, sunflower,

southern peas, potatoes)

10 day PHI ( chilipeppers)

14 day PGI ( corn, rice)

14 day PHI ( corn)

Aerial Chili Peppers ( processing only) Ground 12.5 lb/ A Aerial Guar beans Ground 7.5 lb/ A Aerial Cotton Ground 7.5 lb/ A Aerial Flax Aerial 7.5 lb/ A Grain Sorghum Ground 7.5 lb/ A Aerial Corn Aerial 7.5 lb/ A Rice Aerial 7.5 lb/ A Safflower Ground 7.5 lb/ A Aerial Soybean Ground 7.5 lb/ A Aerial Sunflower Ground 7.5 lb/ A 48 Aerial Southern peas Ground 7.5 lb/ A Aerial Potatoes Ground 12.5 lb/ A Aerial Pick Mor Reg No. 49517 5 Cotton Aerial 4.7 lb/ A Liquid ( SC)

PPE = baseline, gloves, protective eyewear, dust/ mist respirator ( outdoors),

organic vapor respirator ( enclosed areas)

4 hour REI No chemigation/ irrigation 7 day PHI Ground 49 Table B: Commercial/ Residential Herbicides Registered Product App Equipment Max App Rate ( ai) Comments/ Description/ Uses Riverdale Killsall Liquid Reg No. 228 133 Commercial M/ L/ A  LPHW, Handgun Sprayer Product conc = 18.5% ai = 2 lb ai/ gal prod Dilute conc: 0.25 gal prod/ 2 gal H20 = 0.25 gal prod/ 2.25 gal soln = 0.11 gal prod/ gal soln = 0.22 lb ai/ gal soln Treatment: 5 gal prod/ 3000 SF = 10 lb ai/ 3000 SF = 653 gal soln/ A = 144 lb ai/ A Liquid ( SC)

No PPE statement Fall application ( may require additional app in following spring)

Commercial Label: general use on driveways, parking lots, walks, around fences, curbs, similar areas. Not for use on lawns. Residential Label: same as commercial label.

App/ Equip: " coarse spray"

Residential M/ L/ A  LPHW, Sprinkler can Riverdale Killsall II Ready to

Use Liquid Reg No. 228 201 Residential L/ A  Trigger pump Sprayer Product conc = 2.3% ai = 0.196 lb ai/ gal RTU soln Treatment: 1 gal RTU soln/ 60 SF =

0.196 lb ai/ 60 SF = 142.3 lb ai/ A Ready to Use Solution ( RTU)

No PPE statement One time fall app.

Use: For general use on walks,

driveways, parking lots, around fences,

curbs, patios, buildings, and similar noncrop areas. Not for use in veg gardens,

flower bed, or around shrubs or ornamental plants; do not allow on or near desirable turf.

App/ Equip: " spot treatment"  " edging liquid"  " trigger spray nozzle" 50 Perkerson's Tri Chlor Weed Killer Reg No. 690 44 Commercial M/ L/ A  LPHW, Handgun Sprayer Product conc = 26.18% ai = 2.8 lb ai/ gal prod Sprinkler can:

Dilute conc: 1 gal prod/ 9 gal H20 = 1 gal prod/ 10 gal soln = 0.10 gal prod/ gal soln = 0.28 lb ai/ gal soln Pressure sprayer:

Dilute conc: 1 gal prod/ 4 gal H20 = 1 gal prod/ 5 gal soln = 0.2 gal prod/ gal soln = 0.56 lb ai/ gal soln Treatment: 1 gal prod/ 500 SF = 2.8 lb ai/ 500 SF = 871 gal soln/ A = 244 lb ai/ A ( sprinkler can) = 488 lb ai/ A ( pressure sprayer) Liquid ( SC)

No PPE statement Use: Industrial sites such as driveways,

paths, brick walks, cobble gutters, tennis courts.

App/ Equip: " ordinary sprinkler can"

" pressure sprayer"

Residential M/ L/ A  LPHW, Sprinkler can 51 Perkerson's Tri Ate Weed Killer Reg No. 690 48 Commercial Loading  Granules Applicator  Tractor drawn spreader L/ A  Belly grinder, Push spreader M/ L/ A  LPHW, Handgun Sprayer Product conc = 30% ai Granular treatment: 4 lb prod/ 100 SF = 1.2 lb ai/ 100 SF = 523 lb ai/ A Dilute conc ( under asphalt): 2 lb prod/ 1 gal H20 = 0.6 lb ai/ gal soln Treatment: 2 gal soln/ 100 SF = 1.2 lb ai/ 100 SF = 871 gal soln/ A = 523 lb ai/ A Granular ( also dissolve in water for spray)

PPE = Baseline plus gloves, protective eyewear Use: Driveways, paths, brick walks,

cobble gutters, tennis courts, porches,

patios, parking lots, under asphalt paving, fence lines, building perimeters,

ditch banks, picnic areas, vacant lots,

wood decks, bleachers, cemetaries, fuel tanks, runways, helo pads, etc.

Avoid contact with lawns, trees, shrubs,

crops and other desirables.

App/ Equip: " hand operated spreader"

" conventional cyclone type spreader"

" power spreader for larger areas"

" spray application"

Residential L/ A  Belly grinder, Push spreader M/ L/ A  LPHW Applicator  Hand AllPro Baracide 5PS Pelleted Herbicide Reg No. 769 978 Commercial Loading  Granules Applicator  Tractor drawn spreader L/ A  Belly grinder, Push spreader Product conc = 39.80% ai Treatment: 0.92 lb prod/ 100 SF =

0.37 lb ai/ 100 SF = 400 lb ai/ A Pelleted/ Tableted No PPE statement ( except for eyewear)

Use: Around buildings, storage areas,

fences, recreational areas, guard rails,

highway medians, industrial sites.

Avoid desirable trees, shrubs, etc. Not for greenhouse use.

App/ Equip: no statement 52 Grass, Weed and Vegetation Killer Reg No. 5887 46 Commercial M/ L/ A  LPHW, Handgun Sprayer Product conc = 18.5% = 2 lb ai/ gal prod Dilute conc: 0.25 gal prod/ 2 gal H20 = 0.25 gal prod/ 2.25 gal soln = 0.11 gal prod/ gal soln = 0.22 lb ai/ gal soln Treatment: 0.25 gal prod/ 100 SF =

0.5 lb ai/ 100 SF = 980 gal soln/ A =

216 lb ai/ A Liquid ( SC)

No PPE statement Use: Driveways, walks, patios, tennis courts, curbs, garages, etc. Not for use on turf, gardens, valuable trees, or near other desirables.

App/ Equip: " hand or power sprayer"

Residential M/ L/ A  LPHW, Sprinkler can Ferti lome Liquid Vegetation Killer Reg No. 7401 87 Commercial M/ L/ A  LPHW, Handgun Sprayer Product conc = 2.7 lb ai/ gal prod Typical dilute conc: 0.25 gal prod/ 1 gal H20 = 0.25 gal prod/ 1.25 gal soln = 0.2 gal prod/ gal soln = 0.54 lb ai/ gal soln Dilute conc ( under asphalt): 0.5 gal prod/ 0.5 gal H20 = 0.5 gal prod/ gal soln = 1.35 lb ai/ gal soln Typical treatment: 0.25 gal prod/ 100 SF = 0.675 lb ai/ 100 SF = 545 gal soln/ A = 294 lb ai/ A Treatment ( under asphalt): 0.5 gal prod/ 100 SF = 1.35 lb ai/ 100 SF =

436 gal soln/ A = 588 lb ai/ A Liquid ( SC)

No PPE statement Use: Brick walks, patios, parking areas,

along fences, curbs, gutters, around building, graveled pathways, driveways,

under asphalt paving.

Avoid lawn/ desirable plant contact.

App/ Equip: " sprinkler can or power sprayer"

Residential M/ L/ A  LPHW, Sprinkler can Ferti Lome Ready to Use Liquid Weed & Wild Grass Killer Reg No. 7401 85 Residential Applicator  RTU Sprinkler can Product conc = 0.27 lb ai/ gal RTU soln ( 1 gallon pre packaged container) Ready to Use Solution ( RTU)

Use: driveways, in sidewalk cracks,

around patio stones, along fence lines,

lawn edges, around fence posts, around foundations, around garbage cans App/ Equip: RTU sprinkler can 53 Ferti Lome Special Vegetation Killer Reg No. 7401 173 Commercial M/ L/ A  LPHW, Handgun Sprayer Product conc = 18% ai = 2 lb ai/ gal prod Typical dilute conc: 0.25 gal prod/ 1 gal H20 = 0.25 gal prod/ 1.25 gal soln = 0.2 gal prod/ gal soln = 0.4 lb ai/ gal soln Dilute conc ( under asphalt) = 0.75 gal prod/ 0.5 gal H20 = 0.75 gal prod/ 1.25 gal soln = 0.6 gal prod/ gal soln = 1.2 lb ai/ gal soln Typical treatment: 0.25 gal prod/ 67 SF = 0.5 lb ai/ 67 SF = 813 gal soln/ A = 325 lb ai/ A Treatment ( under asphalt): 0.75 gal prod/ 100 SF = 1.5 lb ai/ 100 SF = 545 gal soln/ A = 653 lb ai/ A Liquid ( SC)

No PPE statement Use: Brick walks, patios, parking areas,

along fences, curbs, gutters, around building, graveled pathways, driveways,

under asphalt paving.

Avoid lawn/ desirable plant contact.

App/ Equip: " sprinkler can or power sprayer"

Residential M/ L/ A  LPHW, Sprinkler can Lanscaper Weed Killer and Prepaving Preparation Reg No. 7701 34 Commercial M/ L  Liquid Applicator  Groundboom M/ L/ A  LPHW, Handgun Sprayer Product conc = 22.15% ai = 2.37 lb ai/ gal prod Dilute conc: 1 gal prod/ 4 gal H20 = 1 gal prod/ 5 gal soln = 0.2 gal prod/ gal soln = 0.47 lb ai/ gal soln Treatment: 8 pints prod/ 100 SF = 1 gal prod/ 100 SF = 2.37 lb ai/ 100 SF = 2196 gal soln/ A = 1032 lb ai/ A Liquid ( SC)

No PPE statement Use: non agricultural land; pre paving.

App/ Equip: " low pressure sprayer"

Residential M/ L/ A  LPHW Tri Kil Nonselective Weed and Grass Killer Reg No. 9754 1 Commercial M/ L  Liquid Applicator  ROW sprayer,

Groundboom M/ L/ A  LPHW, Handgun Sprayer Product conc = 7% ai = 0.76 lb ai/ gal prod Dilute conc: 1 gal prod/ 10 gal H20 =

1 gal prod/ 11 gal soln = 0.09 gal prod/ gal soln = 0.07 lb ai/ gal soln Treatment: 1 gal prod/ 250 SF = 0.76 lb ai/ 250 SF = 1891 gal soln/ A = 132 lb ai/ A Liquid ( SC)

Baseline PPE plus gloves Use: Fence rows, rights of way, similar areas. Avoid desirable trees/ shrubs. CA only  do not apply to more than one A/ day.

App/ Equip: none 54 Lane Weedkill  N. S. # 3 Reg No. 11440 3 Commercial M/ L  Liquid Applicator  ROW sprayer,

Groundboom M/ L/ A  LPHW, Handgun Sprayer Product conc = 18% ai = 2 lb ai/ gal prod Dilute conc: 2 gal prod/ 10 gal H20 =

2 gal prod/ 12 gal soln = 0.17 gal prod/ gal soln = 0.34 lb ai/ gal soln Treatment: 2 gal prod/ 200 SF = 4 lb ai/ 200 SF = 2562 gal soln/ A = 871 lb ai/ A Liquid ( SC)

PPE = Baseline plus gloves Use: Fence rows, ditch banks, around buildings, along roadways, power lines right of ways, similar areas. CA only

only one acre per day per applicator.

Prevent killing lawns/ trees/ shrubs.

App/ Equip: no statement Bareground BD Reg No. 33560 43 Commercial Loading  Granules Applicator  Tractor drawn spreader L/ A  Belly grinder, Push spreader Product conc = 40% ai Treatment: 1.37 lb prod/ 100 SF =

0.55 lb ai/ 100 SF = 240 lb ai/ A Pelleted/ Tableted PPE = Coveralls ( over long shirt/ pants),

chem resistant footwear, chem resistant gloves, goggles/ faceshield Use: Industrial sites, rights of way,

lumberyards, petroleum tank farms,

around farm buildings, along fence lines and similar areas.

Not for use in recreational areas or in/ around homes.

App/ Equip: no statement 55 Barespot Weed & Grass Reg No. 33560 46 Commercial Loading  Granules Applicator  Tractor drawn spreader L/ A  Belly grinder, Push spreader Product conc = 30% ai Treatment: 3 lb prod/ 100 SF = 0.9 lb ai/ 100 SF = 392 lb ai/ A Granular PPE = Baseline plus gloves, protective eyewear Use: Bleachers, bridge abutments,

buildings, bunkers, guard rails, helo pads, etc. Under asphalt, concrete,

gravel, driveways, sidewalks/ walkways,

wood decks. Avoid contact with lawns,

trees, shrubs, and other desirables.

For sale and use for professional turf maintenance, landscaping or commercial applicators. ( 20 lb product)

App/ Equip: " hand operated spreader"

" conventional cyclone spreader"

" power spreader for larger areas"

Barespot Ureabor Reg No. 33560 47 Commercial Loading  Granules Applicator  Tractor drawn spreader L/ A  Belly grinder, Push spreader Product conc = 30% ai Treatment: 1.8 lb prod/ 100 SF = 0.54 lb ai/ 100 SF = 235 lb ai/ A Granular PPE = Baseline plus gloves, protective eyewear Use: Bleachers, fence lines, fire hydrants, helo pads, parking lots,

runways, vacant lots, etc. Not for use in/ around homes or in recreational areas.

App/ Equip: " hand operated spreader"

" conventional cyclone spreader"

" power spreader for larger areas" 56 Barespot Monobor Chlorate Reg No. 33560 48 Commercial Loading  Granules Applicator  Tractor drawn spreader L/ A  Belly grinder, Push spreader M/ L/ A  LPHW, Handgun Sprayer Product conc = 30% ai Granular treatment: 4 lb prod/ 100 SF = 1.2 lb ai/ 100 SF = 523 lb ai/ A Dilute conc ( under asphalt): 2 lb prod/ 1 gal H20 = 0.6 lb ai/ gal soln Treatment: 2 gal soln/ 100 SF = 1.2 lb ai/ 100 SF = 871 gal soln/ A = 523 lb ai/ A Granular ( also dissolve in water for spray app)

PPE = Baseline plus gloves, protective eyewear For use in greenhouses ( 12 hour REI)

Use: Bleachers, fence lines, fire hydrants, guard rails, parking lots, etc.

Under asphalt, concrete, driveways,

sidewalks/ walkways. Avoid lawn/ shrub/ tree/ desirable plant contact App/ Equip: " hand operated spreader"

" conventional cyclone spreader"

" power spreader for larger areas"

Residential M/ L/ A  LPHW L/ A  Belly grinder, Push spreader Applicator  Hand Prometon 5PS Reg No. 53883 97 Commercial Loading  Granules Applicator  Tractor drawn spreader L/ A  Belly grinder, Push spreader Product conc = 39.8% ai Treatment: 0.92 lb prod/ 100 SF =

0.37 lb ai/ 100 SF = 161 lb ai/ A Pelleted/ Tableted PPE  only mentions eyewear Use: Around buildings, storage areas,

fences, pumps, machinery, fuel tanks,

recreational areas, roadways, guard rails,

airports, rights of way, etc. Not for use in greenhouses.

Do not apply where chemical may contact desirable trees/ shrubs/ plants.

App/ Equip: no statement 57 Pramitol 5PS Reg No. 66222 23 Commercial Loading  Granules Applicator  Tractor drawn spreader L/ A  Belly grinder, Push spreader Product conc = 39.8% ai Treatment: 0.92 lb prod/ 100 SF =

0.37 lb ai/ 100 SF = 161 lb ai/ A Pelleted/ Tableted PPE  only mentions eyewear Not for use in greenhouses Use: Around buildings, storage areas,

fences, pumps, machinery, fuel tanks,

recreational areas, roadways, guard rails,

airports, rights of way, etc. Not for use in greenhouses.

Do not apply where chemical may contact desirable trees/ shrubs/ plants.

App/ Equip: no statement APPENDIX 2 OCCUPATIONAL AND RESIDENTIAL RISK CALCULATIONS