 Page 1 of 39 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES Memorandum DATE: March 10, 2006 SUBJECT: MGK 264: REVISED Occupational and Residential Exposure Assessment for the Reregistration Eligibility Decision Document PC Code: 057001 DP Barcode: D324674 FROM: Steven Weiss, Industrial Hygienist Reregistration Branch 3 Health Effects Division ( 7509C)

Thru: William Donovan, Risk Assessor Reregistration Branch 3 Health Effects Division ( 7509C)

TO: Cathryn OConnell, Chemical Review Manager Reregistration Branch 2 Special Review and Reregistration Division ( 7508C)

The attached assessment is the updated occupational and residential exposure and risk estimates for MGK 264 to support HED's reregistration eligibility decision ( RED) document. There have been several changes have been made since the October 1, 2004 version of this assessment which include:

C The previous versions of this assessment have been based primarily on the maximum application rates listed on the master label ( ML) submitted to the Agency by MGK on April 14, 2003. On November 21, 2005 MGK has formally requested the following changes be made to the maximum application rates:

* General outdoor spray applications from 2.2 lb ai/ A to 0.3 lb ai/ A * General crack and crevice or spot spray applications from 1.6 to 0.05 lb ai/ 1000 ft2 * Ready to use trigger pump spray applications from 1.6 to 0.1 lb ai/ 1000 ft2 * General surface spray applications from 0.4 to 0.01 lb ai/ 1000 ft2 * Direct applications of solution to livestock from 0.2 lb ai/ gal to 2 oz of 0.2% Page 2 of 39 spray/ animal ( 0.00025 lb ai/ animal) * Ready to use wipe applications to horses from 0.00018 lb ai/ wipe to 0.0000826 lb ai/ wipe (~ 37.5 mg ai/ wipe) * Indoor surface spray applications from 0.4 to 0.01 lb ai/ 1000 ft2 * Indoor space spray applications with aerosol can from 0.006 to 0.001 lb ai/ 1000 ft3 * Dust application of pets 10% to 0.33% formulation with 0.00248 lb ai/ pet * Application of insect repellants from 8% to 5%

C The following maximum rate changes have also been made based on clarification by MGK:

* 0.0022 lb ai/ per collar for ready to use ( RTU) pet collars * 0.0177 lb ai/ 16 oz can for RTU aerosol spray can applications * 5.35 grams ai/ ft2 for indoor application of dust formulation * 0.0028 lb ai/ pet for direct application to pets * 0.0056 lbs ai per horse for RTU paste applications to horses * 0.5% is the maximum concentration for RTU residual pump spray ( trigger spray) * 1.77 mg ai/ spray event for metered release products * 0.011 lb ai/ 100 ft2 for dust applied to carpeted and other indoor surfaces C For estimating handler exposure, assumptions for area treated or amount handled per day were revised to the following:

* Livestock application from 400 animals/ day to 25 animals/ day for occupational * Applications to carpet with dust from 0.5 lbs product/ day to 256 ft2/ day for residential * Applications to indoor areas with dust from 2 lbs product/ day to 1,000 ft2/ day for occupational * Applications with RTU residual pump spray from 2 to 1 gallons/ day for occupational * Applications with RTU residual pump spray from 1000 ft2/ day to 0.25 gallons/ day for residential * Indoor applications using low pressure handwand, backpack, and handgun from 40,000 ft2/ day to 11,200 ft2/ day C Residential postapplication oral and dermal exposure for application of 1.18% dust applied to carpeted surfaces at a rate of 0.011 lb ai/ 100 ft2 was estimated C Inhalation risk was estimated for 2 air changes per hour ( i. e. for a commercial bldg) in addition to 0.18 air changes per hour ( i. e. for a house). Page 3 of 39 Table of Contents Executive Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 4 of 38 1.0 Occupational and Residential Exposure/ Risk Assessment . . . . . . . . . . . . . . . . . . . . . . . Page 5 of 38 1.1 Hazard Concerns for MGK 264 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 5 of 38 1.2 Physical and Chemical Properties of MGK 264 . . . . . . . . . . . . . . . . . . . . . . . . Page 8 of 38 1.3 Use Patterns and Formulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 9 of 38 2.0 Occupational Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10 of 38 2.1 Handlers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 10 of 38 2.1.1 Data Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 11 of 38 2.1.2 Assumptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 12 of 38 2.1.3 Exposure Scenarios . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 14 of 38 2.1.4 Equations for Exposure/ Risk Estimates . . . . . . . . . . . . . . . . . . . . . . Page 14 of 38 2.1.5 Risk Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 16 of 38 2.2.1 Data and Assumptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 18 of 38 2.2.2 Equations for Exposure/ Risk Estimates . . . . . . . . . . . . . . . . . . . . . . Page 19 of 38 2.2.3 Risk Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 19 of 38 3.0 Non Occupational/ Residential Exposures and Risks . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21 of 38 3.1 Handlers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21 of 38 3.1.1 Data and Assumptions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 21 of 38 3.1.2 Exposure Scenarios . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 23 of 38 3.1.3 Equations for Exposure/ Risk Estimates . . . . . . . . . . . . . . . . . . . . . . Page 23 of 38 3.2 Postapplication Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 25 of 38 3.2.1 Data Sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 25 of 38 3.2.2 Equations for Exposure/ Risk Estimates . . . . . . . . . . . . . . . . . . . . . . Page 29 of 38 3.2.3 Risk Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 35 of 38 Appendices ( 14 pages of Excel Spread Sheets) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Page 38 of 38 Page 4 of 39 Executive Summary MGK 264 is an insecticide synergist. Synergists are chemicals that lack pesticidal effects of their own but enhance the pesticidal properties of other chemicals. MGK 264 is usually formulated with natural pyrethrins, piperonyl butoxide ( PBO), or synthetic pyrethroids. It has numerous and varied commercial and residential applications, is available in a broad range of formulations, and is applied by wide variety of application methods. Commercial uses include application non food plants, applications in food and non food handling commercial and agricultural structures and outdoor premises, housing for veterinary and farm animals, and direct application to veterinary and non food animals. In addition, MGK 264 is currently registered for use in/ on all food items in food handling establishments where food and food products are held, processed, or prepared to control nuisance and food product contaminating insects such as ants, cockroaches, fleas and ticks. For residential applications, it is used to control insects both inside the home, and outside on gardens, lawns and ornamentals, patios, and other outdoor structures, and is directly applied to pets.

HED's Hazard Identification Assessment Review Committee ( HIARC) met to determine appropriate toxicological endpoints of concern for MGK 264. The toxicological endpoints used to complete the occupational and residential risk assessments have been extracted from the June 25, 2004 MGK 264 HIARC report.

The short and intermediate term ( non cancer) dermal occupational and residential risk assessment for MGK 264 is based on a LOAEL of 61 mg/ kg/ day from a multi generation reproduction study. A dermal absorption factor of 10 percent was selected based on a study using human volunteers. The incidental oral assessment for children is also based on the LOAEL of 61 mg/ kg/ day. The short and intermediate term ( non cancer) inhalation occupational and residential risk assessment for MGK 264 is based on a LOAEL of 0.01 mg/ L ( 1.86 mg/ kg/ day), which was defined in a 90 day inhalation study in rats. Long term exposure to MGK 264 are not expected for current registered uses.

For MGK 264 exposures via the oral, dermal and inhalation routes, MOEs of less than 1,000 are a risk concerns for occupational and residential scenarios. The level of concern is based on 10x to account for interspecies extrapolation to humans from the animal test species, 10x to account for intraspecies sensitivity and 10X for the use of a LOAEL, rather than a NOAEL. The dermal and inhalation margins of exposure were not combined for the handler assessment because the toxicity endpoints for the dermal and inhalation routes of exposure are based on different toxicological effects. Toddler dermal and oral MOEs are based on the same NOAEL and will be combined in HED's aggregate risk assessment for MGK 264.

MGK 264 is applied with several types of application equipment   including groundboom, low pressure handwand sprayers, high pressure handwand sprayers, handgun sprayers, hose end sprayers, and thermal misters/ foggers, pump trigger sprayers, foggers, aerosol cans, shampoos, dips, wipes, roll ons, impregnated collars, and dust ( puffer or shaker) cans.

With exception of a dog shampoo study, no chemical specific exposure data was submitted for MGK 264. Occupational and residential exposure estimates were based the one Page 5 of 39 study with best available surrogate data for other exposure scenarios. Handler exposure estimates were based on surrogate data from EPA's Pesticide Handler Exposure Database ( PHED) Version 1.1 , Outdoor Residential Exposure Task Force ( ORETF), Chemical Manufacturers Association ( CMA) Antimicrobial Exposure Assessment Study, and two proprietary studies ( trigger pump spraying with propoxur and shampoo application with carbaryl). For re entry dermal exposure to treated foliage, default values for residue dissipation were used with proprietary transfer coefficient data from the Agricultural Re entry Task Force ( ARTF) database. For postapplication exposure following indoor treatments surrogate data from the Non Dietary Exposure Task Force ( NDETF) was used for the percent of residue that can be transferred for dermal and oral exposure pathways. Toddler's oral and dermal and oral exposure from dogs treated with shampoo were estimated using a study that measured postapplication exposure to MGK 264. Dermal exposure from insect repellents applied to skin were estimated based on data from the Residential Exposure Joint Venture ( REJV), National Pesticide Use Survey. Exposure calculations and exposure factor inputs were based on HED's Standard Operating Procedures ( SOPs) for Residential Exposure Assessments ( except where noted).

With the exception of 3 occupational handler scenarios assessed, estimated MOEs were not a risk concern for all scenarios at the baseline level ( i. e single layer with no gloves, and no respirator). Dermal MOEs for mixing loading and applying liquids with low pressure handwand, high pressure handwand, and backpack sprayers are not a risk concern if gloves are worn. For residential handlers, none of the scenarios had risks of concern ( i. e. all MOE > 1,000)

For occupational dermal contact with treated foliage during re entry activities, MOEs are greater than 1,000 on the day of application for all of the crops assessed.

Several of the residential uses have risk concerns ( i. e. MOEs < 1,000) for postapplication exposure including indoor surface and space sprays, dusts applied to carpets, and insect repellents applied to the skin.

Data gaps exist for: ( 1) Dermal and inhalation handler monitoring for mixing/ loading/ applying liquids for fogger applications; ( 2) dermal and inhalation handler monitoring for mixing/ loading/ applying liquids for dip applications; and ( 3) air monitoring for compact metered release products; and ( 4) deposition data for dusts applied to carpets ( followed by vacuuming.)

Print outs of Microsoft Excel Spreadsheets used to estimate all occupational and residential MOEs in this assessment are included in the appendices.

1.0 Occupational and Residential Exposure/ Risk Assessment 1.1 Hazard Concerns for MGK 264 HED's Hazard Identification Assessment Review Committee ( HIARC) met to determine appropriate toxicological endpoints of concern for MGK 264. The toxicological endpoints that were used to complete the occupational and residential risk assessments are summarized below, which have been extracted from the MGK 264 HIARC report ( June 25, 2004). Page 6 of 39 Dermal Route ( non cancer)

The short, intermediate, and long term ( non cancer) dermal risk assessment for MGK 264 is based on a LOAEL of 61 mg/ kg/ day from a multi generation reproduction study. The LOAEL was based on slight decreases in maternal body weight. Long term exposures to MGK 264 ( i. e., greater than 6 months) are not expected for current registered uses. A dermal absorption factor of 10 percent was selected based on a study using human volunteers.

Inhalation Route ( non cancer)

The short, intermediate, and long term ( non cancer) inhalation risk assessment for MGK 264 is based on a LOAEL of 0.01 mg/ L ( 1.86 mg/ kg/ day), which was defined in a 90 day inhalation study in rats. The LOAEL was based on the presence of hyperplasia and metaplasia in the larynx. Long term exposure to MGK 264 ( i. e., greater than 6 months) are not expected for current registered uses.

Oral Route ( non cancer)

The ( non cancer) incidental oral risk assessment for MGK 264 is based on a LOAEL of 61 mg/ kg/ day from a multi generation reproduction study. The LOAEL was based on slight decreases in maternal body weight.

Non cancer Level of Concern ( LOC)

HED's level of concern ( LOC) for MGK 264 oral, dermal and inhalation exposures is 1,000 ( i. e., a margin of exposure ( MOE) less than 1,000 exceeds HED's level of concern) for occupational and residential scenarios. The level of concern is based on 10X to account for interspecies extrapolation to humans from the animal test species, 10X to account for intraspecies sensitivity and 10X for the use of a LOAEL, rather than a NOAEL.

Cancer The Carcinogenicity Peer Review Committee ( CPRC) classified MGK 264 as a Group C  Possible Human Carcinogen based on statistically significant increases mainly in benign liver adenomas in both sexes of mice at doses approaching the limit dose and on increases in benign thyroid follicular tumors in male rats at doses considered to be adequate to assess carcinogenic potential. The CPRC determined that a quantification of cancer risk is not required because of the Group C classification and the lack of concern for mutagenicity and support from SAR ( TXR No. 0011577).

Acute Toxicity The toxicology data base is adequate to characterize the toxicity of MGK 264. MGK 264 is placed in Toxicity Category IV for acute oral toxicity and dermal irritation and in Toxicity Category III for acute dermal toxicity and dermal irritation. An acute inhalation toxicity study Page 7 of 39 and a dermal sensitization study is not available.

Body Weight Since the adverse effects for the dermal endpoint are based on a reproductive study, the body weight of an average adult female ( i. e., 60 kg) was used to estimate dermal exposure. The adverse effects for the inhalation endpoint are based on an inhalation study where the effects were observed in males and females, therefore, the body weight of an average adult ( i. e., 70 kg) was used to estimate inhalation exposure. Page 8 of 39 CH 2 N O O C8H17 1.2 Physical and Chemical Properties of MGK 264 Chemical Structure Empirical Formula C17H25NO2 Common name N octylbicycloheptene dicarboximide Company experimental name MGK 264 IUPAC name N( 2 ethylhexyl) 8,9,10 trinorborn 5 ene 2,3 dicarboximide CAS name 4,7 Methano 1H isoindole 1,3( 2H) dione, 2( 2 ethylhexyl) 3a, 4,7,7a tetrahydro

CAS Registry Number 113 48 4 Chemical Class Insecticide synergist Known Impurities of Concern None Melting point/ range N/ A Molecular Weight 275 Boiling point/ range 155 161 ° C @ 1 mm Hg.

pH 6.9; typical range of 6.8 to 7.2 Density 1.049 ± 0.003 g/ mL @ 20 ° C Water solubility 15 ± 3 µ g/ mL @ 25 ° C Solvent solubility Miscible in: Acetone, Methanol, Isopropanol, Petroleum Ether, Concoco LPA ( petroleum distillate), Ethyl Acetate, Toluene, Chloroform, Acetonitrile, Cyclo Solv 53 ( aromatic petroleum distillate) and Isopar M ( petroleum distillate)

Vapor pressure 1.84 ± 0.49 x 10 5 mm Hg @ 25 ° C Dissociation constant ( pKa) N/ A Octanol/ water partition coefficient Log( KOW) Log P = 3.61 & 3.80 for isomers 1 & 2, respectively, at 24 ° C UV/ visible absorption spectrum Not available Page 9 of 39 1.3 Use Patterns and Formulations MGK 264 is used in agricultural, commercial, and residential settings. MGK 264 is formulated as an emulsifiable concentrate, as well as a number of ready to use formulations such as aerosol cans, foggers, trigger pump sprayers, shampoos, pastes, wipes, dusts, etc.

Table 1 summarizes the major use sites, maximum rates, and type of equipment used to apply MGK 264 based on the Master Label ( ML) submitted to the Agency by MGK on April 14, 2003 ( except where noted), updated November 21, 2005 MGK submission, and subsequent communications with MGK.

Table 1. Summary of Maximum Application Rates for MGK 264 Use Site and Application Equipment Application Rate f Outdoor Groundboom 0.3 lb ai/ acre Handgun Low Pressure Handwand Backpack Sprayer High Pressure Handwand Hose end Sprayer ULV Fogger for Mosquito Abatement a 0.07 lb ai/ acre Indoor Handgun 0.01 lb ai/ 1000ft2 Low Pressure Handwand Backpack Sprayer Fogger or Mist Generator b 0.006 lb ai/ 1000ft3 Ready to use Foggers c 0.0064 lb ai/ 5000ft3 Shaker Can ( dust/ powder formulation) 0.011 lb ai/ 100 ft2 Metered Release d 1.77 mg ai/ spray event Crack & Crevice or Spot Low Pressure Handwand 0.05 lb ai/ 1000ft2 Backpack Sprayer Handgun Trigger pump Sprayer 0.042 lb ai/ gallon Aerosol Cans 0.0177 lb ai/ 16 oz can Livestock Handgun 0.00025 lb ai/ animal Low Pressure Handwand Backpack Sprayer Ready to use Paste 0.056 lb ai/ animal Ready to use Wipes e 0.08 grams ai/ wipe Pets Trigger pump Sprayer 0.042 lb ai/ gallon Ready to use Wipes e 0.08 grams ai/ wipe Pour on Or Spot on 0.07 lb ai/ gallon Shaker Can ( dust/ powder formulation) 0.00248 lb ai/ pet Dip Applications 0.0021 lb ai/ gallon Mousse, Soap, Lotion, Gel, Comb, or Roll on 0.035 lb ai/ gallon Shampoo 0.07 lb ai/ gallon Ready to use Collar 0.0022 lb ai/ collar Skin/ Clothing Spray or Lotion 0.08 mg ai/ mg of product Foam Injected Into Wall Voids 5.8 g ai/ 3ft3 void a. MGK reports that wide area mosquito abatement uses will no longer be supported. b. MGK reports that the rate of 0.5 lb ai/ 1000 ft3 for space spraying pet premises is listed on the master label was an error. The maximum rate should be 0.006 lb ai/ 1000 ft3 ( same as rate that is listed for indoor residential spaces). c. Product labels say each one 6 oz fogger containing 1.71% ai treats 5000 ft3 ( 0.01 lb ai/ 1000ft2 for treated area with 8 ft ceilings ) d. MGK reports that indoor metered release products dispense 1.77 mg ai every 15 minutes e. Rate for ready to use wipes based on information provided to SRRD from MGK Page 10 of 39 f. Maximum rates are listed. Not every use site and application rate from ML is listed 2.0 Occupational Exposures and Risks There is a potential for exposure to MGK 264 in occupational scenarios from handling MGK 264 products during the application process ( i. e., mixer/ loaders, applicators, and mixer/ loader/ applicators) and a potential for postapplication worker exposure from entering into areas previously treated with MGK 264. As a result, risk assessments have been completed for occupational handler scenarios as well as occupational postapplication scenarios.

2.1 Handlers Tasks associated with occupational pesticide handlers are 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 MGK 264 and load it into the holding tank of the groundboom tractor.

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

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 MGK 264 into the application equipment and then also apply it.

A chemical can produce different effects based on how long a person is exposed, how frequently exposures occur, and the level of exposure. HED classifies exposures up to 30 days as short term and exposures greater than 30 days up to several months as intermediate term. HED completes both short and intermediate term assessments for occupational scenarios in essentially all cases, because these kinds of exposures are likely and acceptable use/ usage data are not available to justify deleting intermediate term scenarios. Based on use data and label instructions, HED believes that occupational MGK 264 exposures may occur over a single day or up to weeks at a time for many use patterns and that intermittent exposures over several weeks also may occur. Some applicators may apply MGK 264 over a period of weeks, because they are custom or commercial applicators who are completing a number of applications for a number of different clients. Long term handler exposures are not expected to occur for MGK 264. Note that the same toxicological endpoint of concern ( from an oral study) was selected for short, intermediate , and long term dermal MGK 264 exposures, therefore, the risk estimates for all dermal durations of exposure are numerically identical. The same toxicological endpoint of concern ( from an inhalation study) has been selected for short, intermediate and long term inhalation exposures to MGK 264, therefore, the risk estimates for all inhalation durations of exposure also are numerically identical. Page 11 of 39 Other parameters are also defined from use and usage data such as application rates and application frequency. HED always completes non cancer risk assessments using maximum application rates for each in order to ensure there are no concerns for each specific use.

Occupational handler exposure assessments are completed by HED using different levels of risk mitigation. Typically, HED uses a tiered approach. The lowest tier is designated as the baseline exposure scenario ( i. e., long sleeve shirt, long pants, shoes, socks, and no respirator). If risks are of concern at baseline attire, then increasing levels of personal protective equipment or PPE ( e. g., gloves, double layer body protection, and respirators) are evaluated. If risks remain a concern with maximum PPE, then engineering controls ( e. g., enclosed cabs or cockpits, watersoluble packaging, and closed mixing/ loading systems) are evaluated. This approach is used to ensure that the lowest level of risk mitigation that provides adequate protection is selected, since the addition of PPE and engineering controls involves an additional expense to the user and   in the case of PPE   also involves an additional burden to the user due to decreased comfort and dexterity and increased heat stress and respiratory stress.

2.1.1 Data Sources No chemical specific exposure data was available for MGK 264. Handler exposure estimates were based on the best available surrogate data.

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

Occupational Handler unit exposures for MGK 264 were based on the following sources:

C Pesticide Handler Exposure Database ( PHED) Version 1.1 ( August 1998)

C MRID 449722 01. 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 scenarios using a low pressure, high volume turf handgun is ORETF Study OMA002. The study that monitored homeowner exposures while using a hose end sprayer is ORETF Study OMA004.

C MRID 444598 01. A report was submitted by the ORETF that presented data in which the application of various products used on vegetable gardens by homeowners was monitored. The study that monitored homeowner exposure scenarios using a duster was ORETF Study OMA007. Page 12 of 39 C Chemical Manufacturers Association ( CMA) Antimicrobial Exposure Assessment Study ( December 1992): The CMA exposure study was a response to March 4, 1987 data call in notice by EPA. CMA is a generic biocide exposure assessment protocol used to assess potential dermal and/ or inhalation exposure from the application of antimicrobial pesticide products in multiple settings using various application methods.

° MRID 410547 01. Exposure of Applicators to Propoxur During Trigger Pump Spray Applications of a Liquid Product, November 1, 1988. ( proprietary data)

° MRID 446584 01, Dermal Exposure and Inhalation Exposure to Carbaryl by Commercial Pet Groomers During Applications of Adams Carbaryl Shampoo, September 1998. ( proprietary data)

Currently, EPA has no exposure data for mixing/ loading/ applying liquids for fogger and dip applications.

2.1.2 Assumptions 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 MGK 264 has a large number of use patterns that are difficult to completely capture in this document. As such, HED has patterned this risk assessment on a series of likely representative scenarios that are believed by HED to represent the vast majority of MGK 264 uses.

C Generic protection factors ( PFs) were used to calculate exposures when data were not available. For example, a filtering facepiece dustmask is assumed to have a protection factor ( PF) of 5 ( i. e. reduces inhalation exposure by 80%).

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 MGK 264 handler exposures, PHED data for backpack sprayer equipment were used to assess applications using an ULV backpack fogger. The nature of these application methods are believed to be similar enough to bridge the data.

C The daily areas treated were defined for each handler scenario ( in appropriate units) by determining the amount that can be reasonably treated in a single day ( e. g., acres, square feet, cubic feet, or gallons per day). When possible, the assumptions for daily areas treated are taken from the Health Effects Division Science Advisory Committee on Exposure SOP # 9: Standard Values for Daily Acres Treated in Agriculture, which was completed on July 5, 2000. However, no standard values are available for numerous scenarios. Assumptions for these scenarios are based on HED estimates and could be further refined from input from affected sectors. Table 2 summarizes the daily areas treated assumptions used in Page 13 of 39 this assessment.

Table 2. Assumptions for Occupational Daily Areas Treated Application Equipment Exposure Scenario Area Treated Daily Low Pressure Handwand, Outdoor 1 acres Livestock 25 animals C& C or Spot a 11,200 ft2 Backpack Sprayer Outdoor 1 acre Livestock 25 animals C& C or Spot a 11,200 ft2 Handgun Outdoor 5 acres C& C or Spot b 11,200 ft2 Livestock b 25 animals High Pressure Handwand Outdoor 1 acre Aerosol Cans C& C or Spot 2 16 oz cans Mousse, Soap, Lotion, Gel, Comb, or Roll on Pets c 0.2 gallons Pour on or Spot on Pets d 8 gallons Ready to use Paste Livestock 2 gallons Ready to use Wipes Pets e 8 wipes Livestock f 25 wipes Ready to use Foggers Indoor g 6 6 oz cans Shaker Can Pets h 8 pets Shampoo Pets c 0.2 gallons Trigger pump Sprayer Pets/ indoor 1 gallon a. Based on BEAD's review of the National Pest Management Association ( NPMA) sponsored Pest Control Operators ( PCO) Product Use and Usage Information Survey. b. 25 animals treated per day is based on 10/ 21/ 05 survey provided by MGK c. 10% of 16 ounce container per animal and assumes 16 animals per day d. 1 gallon per pet and 8 pets treated per day e. 1 wipe per animal ( 8 pets treated per day is based on ORE chapter for permethrin RED) f. 1 wipe per animal g. assume handler will use six 6 oz cans ( 3 cans come in package, each can treats up to 5,000 ft3) h. 8 pets treated per day i. 0.25 gallon per pet and 8 pets treated per day Page 14 of 39 2.1.3 Exposure Scenarios It has been determined that exposure to pesticide handlers is likely during the occupational use of MGK 264 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 MGK 264 applications. The quantitative exposure/ risk assessment developed for occupational handlers is based on the following scenarios:

Mixing/ Loading ( M/ L): M/ L Liquids for Groundboom M/ L Liquids for Dips Mixer/ Loader/ Applying ( M/ L/ A): M/ L/ A Liquids with Low Pressure M/ L/ A Liquids with Backpack M/ L/ A Liquids with ULV Fogger M/ L/ A Liquid with Handgun M/ L/ A Liquids with High Pressure Handwand Applying: Applying RTU Paste Applying RTU Wipes Applying Pour on or Spot on Applying RTU Formulations via Trigger Pump Sprayer Applying RTU Formulations via Mousse, Soap, Lotion, Gel, Comb, or Roll On Applying RTU Shampoo Applying RTU Formulations with Aerosol Cans Applying RTU Formulations with Fogger Cans 2.1.4 Equations for Exposure/ Risk Estimates Daily Exposure: Daily dermal or inhalation handler exposures are estimated for each applicable handler task ( except applying impregnated collars) with the application rate, the area treated in a day, and the applicable dermal or inhalation unit exposure using the following formula:

Where:

Daily Exposure = Amount ( mg or µ g ai/ day) deposited on the surface of the skin that is available for dermal absorption or amount inhaled that is available for inhalation absorption; Unit Exposure = Unit exposure value ( mg or µ g ai/ lb ai) derived from August 1998 PHED data, from ORETF data, from CMA data, and from Proprietary data; Page 15 of 39 Application Rate = Normalized application rate based on a logical unit treatment, such as acres, square feet, gallons, or cubic feet. Maximum values are generally used ( lb ai/ A, lb ai/ ft2, lb ai/ gal, lb ai/ cu ft); and Daily Area Treated = Normalized application area based on a logical unit treatment such as acres ( A/ day), square feet ( ft2/ day), gallons per day ( gal/ day), or cubic feet ( cu ft/ day).

Since there is no unit exposure values for applying impregnated collars to pets, the default values in the Standard Operating Procedures for Residential Exposure Assessments ( R SOPs) is used to assess daily dermal exposure. The R SOPs indicate that daily dermal exposure is estimated for impregnated pet collars by assuming that one percent of the active ingredient in the collar is transferred to the person placing the collar onto a pet.

Daily dermal handler exposures were estimated for handlers applying impregnated collars with the application rate, number of collars handled per day, and the assumption that 1 percent of the active ingredient transfers from the collar to the person using the following formula:

Where:

Daily Exposure = Amount ( mg ai/ day) deposited on the surface of the skin that is available for dermal absorption; Application Rate = Application rate ( active ingredient in each collar) converted to milligrams active ingredient per collar. Maximum values are used ( mg ai/ collar); Number of Collars Applied = Assumption regarding the number of impregnated collars placed on a pet per day in an occupational setting, such as a veterinary clinic; and Percent Transferred = Percent active ingredient transferred from the pet collar to the person putting it on the pet. Assumption from R SOPs is that 1% transfers.

The average 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) deposited on the surface of the skin that is available for dermal absorption or amount inhaled that is available for inhalation absorption; Absorption Factor = A measure of the amount of chemical that crosses a biological boundary such as the skin or lungs (% of the total available absorbed); and Body Weight = Body weight determined to represent the population of interest in a risk assessment ( kg). Page 16 of 39 Margins of Exposure: Non cancer dermal and inhalation risks for each applicable handler scenario are calculated using a Margin of Exposure ( MOE), which is a ratio of the daily dose to the toxicological endpoint of concern. All MOE values were calculated separately for dermal and inhalation exposure levels using the formula below:

Where:

MOE = Margin of Exposure, value used by HED to represent risk or how close a chemical exposure is to being a concern ( unitless); ADD = Average Daily Dose or the absorbed dose received from exposure to a pesticide in a given scenario ( mg pesticide active ingredient/ kg body weight/ day); and NOAEL or LOAEL = Dose level in a toxicity study, where no observed adverse effects ( NOAEL) or where the lowest observed adverse effects ( LOAEL) occurred in the study Risk values are presented for each route of exposure ( i. e., dermal or inhalation) in each scenario, because risk mitigation measures are specific to the route of exposure. A total MOE was not calculated for MGK 264 because the dermal and inhalation toxicological endpoints of concern are based on different adverse effects.

2.1.5 Risk Summary Handler data gaps exist for: ( 1) Dermal and inhalation handler monitoring for mixing/ loading/ applying liquids for fogger applications and ( 2) dermal and inhalation handler monitoring for mixing/ loading/ applying liquids for dip applications.

A summary of the short and intermediate term risks for each exposure scenario are presented in Table 4. With the exception of 3 occupational handler scenarios assessed, estimated MOEs were not a risk concern for all scenarios at the baseline level ( i. e single layer with no gloves, and no respirator). Dermal MOEs for mixing loading and applying liquids with low pressure handwand, high pressure handwand, and backpack sprayers are not a risk concern if gloves are worn. Page 17 of 39 Table 4. Summary of MOEs for Occupational Handlers Exposure Scenario ( Data Source) Application Rate Area Treated Baseline Dermal MOE Baseline Inhalation MOE PPE Gloves Dermal MOE PPE Gloves + Coveralls Dermal MOE PPE PF5 Respirator Inhalation MOE PPE PF10 Respirator Inhalation MOE M/ L Liquids for Dips ( PHED) 0.00005 lb ai/ gal 0.5 gal 5.0E+ 08 4.3E+ 09 6.4E+ 10 8.6E+ 10 2.2E+ 10 4.3E+ 10 M/ L/ A Liquids w\ LPH ( PHED) 0.00005 lb ai/ ft2 11200 ft2 654 7,750 151,993 176,641 38,750 77,500 0.00025 lb ai/ animal 25 animals 58,560 694,400 1.4E+ 07 1.6E+ 07 3,472,000 6,944,000 M/ L/ A Liquids w\ Backpack ( PHED) 0.00005 lb ai/ ft2 11200 ft2 ND 7,750 26,143 40,848 38,750 77,500 0.3 lb ai/ A 1 A ND 14,467 48,800 76,250 72,333 144,667 0.00025 lb ai/ animal 25 animals ND 694,400 2,342,400 3,660,000 3,472,000 6,944,000 M/ L/ A Liquids w\ Backpack ( PHED for ULV Fogger) 0.07 lb ai/ A 5 A ND 12,400 41,829 65,357 62,000 124,000 M/ L/ A Liquid w\ Handgun ( MRID 44972201, ORETF) 0.3 lb ai/ A 5 A ND 45,684 48,800 90,370 228,421 456,842 0.00005 lb ai/ ft2 11200 ft2 ND 122,368 130,714 242,063 611,842 1,223,684 0.00025 lb ai/ animal 25 animals ND 1.1E+ 07 1.2E+ 07 2.2E+ 07 5.5E+ 07 1.1E+ 08 M/ L/ A Liquids w\ HPH ( PHED) 0.3 lb ai/ A 1 A ND 3,617 48,800 76,250 18,083 36,167 Applying RTU Paste ( PHED for paint brush) 0.0056 lb ai/ animal 25 animals 1,452 3,321 10,893 11,883 16,607 33,214 Applying RTU Wipe to Livestock ( CMA) 0.0000826 lb ai/ wipe 25 wipes 6,176 2,276 ND ND 11,381 22,762 Applying RTU Wipe to Pets ( CMA) 0.0001764 lb ai/ wipe 8 wipes 9,038 3,331 ND ND 16,657 33,313 Applying Pour on or Spot on ( MRID 44972201, Hose end ORETF) 0.07 lb ai/ gal 8 gal 11,671 14,531 ND ND 72,656 145,313 Applying RTU Formulations via Trigger Pump Sprayer ( MRID 410547 01, Propoxur) 0.042 lb ai/ gal 1 gal 64,550 25,203 ND ND 126,016 252,033 Applying RTU Formulations via Mousse, Soap, Lotion, Gel, Comb, or Roll On ( MRID 446584 01, Carbaryl) 0.035 lb ai/ gal 0.2 gal 2,905 1.6E+ 11 ND ND 7.8E+ 11 1.6E+ 12 Applying RTU Shampoo ( MRID 446584 01, Carbaryl) 0.07 lb ai/ gal 0.2 gal 1,452 7.8E+ 10 ND ND 3.9E+ 11 7.8E+ 11 Applying RTU Formulations w\

Aerosol Cans ( PHED aerosol) 0.0177 lb ai/ 16oz can 2 16oz cans 5,442 2,829 12,764 16,155 14,146 28,292 Applying RTU Formulations w\

Foggers ( PHED aerosol) 0.0064125 lb ai/ 6oz can 3 6oz cans 10,013 5,206 23,488 29,727 26,031 52,062 0.0064125 lb ai/ 6oz can 6 6oz cans 5,007 2,603 11,744 14,864 13,015 26,031 Applying Dusts via Shaker Can ( MRID 444598 01) 0.00011 lb ai/ ft2 1000 ft2 4,378 1,909 ND ND 9,545 19,091 0.00248 lb ai/ pet 8 pets 24,273 10,585 ND ND 52,923 105,847 Page 18 of 39 ND = No data, NF = Not Feasible MOEs of less than 1,000 are a risk concern Page 19 of 39 2.2 Postapplication Activities HED uses the term " postapplication" to describe exposures to individuals that occur as a result of being in an environment that has been previously treated with a pesticide. MGK 264 uses that may result in foliar contact were identified in the following crop groupings based on HED's Science Advisory Council For Exposure Policy 3.1:

C Floriculture crops grown for cutting;

C Floriculture crops not grown for cutting;

C Trees/ fruit, evergreen ( Christmas trees);

C Turf/ sod ( e. g., golf courses, sod farms); and C Nursery crops ( e. g., container and balled and burlapped ornamentals).

For MGK 264, the exposure durations for noncancer postapplication risk assessment were short term (# 30 days) and intermediate term ( greater than 30 days up to several months). However, since the dermal toxicological endpoint of concern is the same for short and intermediate term exposures, the short and intermediate term postapplication risks are numerically identical.

Inhalation exposures are thought to be negligible in outdoor postapplication scenarios, since MGK 264 has low vapor pressure and the dilution factor outdoors is considered infinite. In addition, under the Worker Protection Standard for Agricultural Pesticides   WPS   ( 40 CFR 170) greenhouses must be appropriately ventilated ( ventilation criteria are provided) following pesticide applications so that postapplication inhalation exposures are minimal. As such, inhalation postapplication exposures from outdoor applications are not considered in this assessment. See Section 3.2 for postaplication postapplication exposure from indoor applications.

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

C Transfer Coefficients ( TCs): Turf TCs were based on the latest ARTF studies. The other TCs used were taken from HED's revised policy entitled Policy 003.1 Science Advisory Council For Exposure Policy Regarding Agricultural Transfer Coefficients ( August 7, 2000).

C Turf Transferrable Residues ( TTRs): No MGK 264 specific turf transferrable residue ( TTR) data were available. Therefore, this assessment uses HED's default assumption that 5 percent of the application rate is available on day 0 ( i. e., 12 hours after application) and the residue dissipates at a rate of 10 percent per day.

C Dislodgeable Foliar Residues ( DFRs): No MGK 264 specific dislodgeable foliar residue Page 20 of 39 ( DFR) data were available. Therefore, this assessment uses HED's default assumption that 20 percent of the application rate is available on day 0 ( i. e., 12 hours after application) and the residue dissipates at a rate of 10 percent per day.

2.2.2 Equations for Exposure/ Risk Estimates Occupational non cancer risks were calculated using a Margin of Exposure ( MOE), which is a ratio of the daily dose to the toxicological endpoint of concern. Postapplication risks diminish over time because MGK 264 residues eventually dissipate in the environment. As a result, risks were calculated over time based on changing residue levels.

Daily Exposure: Daily dermal exposures were calculated on each postapplication day after application using the following equation ( see equation D2 20 from Series 875 Occupational and Residential Test Guidelines: Group B Postapplication Exposure Monitoring Test Guidelines and Residential SOP 3.2: Postapplication Dermal Potential Doses From Pesticide Residues On Gardens):

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

Where:

DE( t) = Daily exposure or amount deposited on the surface of the skin at time ( t) attributable for activity in a previously treated area, also referred to as potential dose ( mg ai/ day); TR( t) = Transferable residues that can either be dislodgeable foliar or turf transferable residue at time " t" ( µ g/ cm2); TC = Transfer Coefficient ( cm2/ hour); and Hr/ day = Exposure duration meant to represent a typical workday ( hours).

Note that the ( TR ( t)) input may represent levels on the day of application in the case of short term risk calculations.

Daily Dose and Margins of Exposure: The use of dissipation data and the manner in which daily postapplication dermal exposures were calculated are inherently different than with handler exposures. However, once daily exposures are calculated, the calculation of daily absorbed dose and the resulting Margin of Exposures use the same algorithms that are described above for the handler exposures. These calculations are completed for each day or appropriate block of time after application.

2.2.3 Risk Summary A summary of MOEs estimated for occupational postapplication activities are provided in Table 5. None of the crops have a risk concern on day 0 ( i. e., 12 hours after application). Page 21 of 39 Table 5. Summary of MOEs for Postapplication Activities Crop Maximum Application Rate ( lb ai/ A) Activity TC cm2/ hr Short/ Intermediate Term MOE DAT ( days)

field grown Christmas trees 0.3 hand harvesting, thinning 3000 2300 0 hand pruning 1500 4500 0 hand weeding, scouting, irrigating 1000 6800 0 ornamentals  nursery grown 0.3 irrigating, scouting ( all at medium development) 500 14000 0 ornamentals  floriculture 0.3 hand pruning 400 17000 0 hand pinching 175 39000 cut roses 2600 2600 0 all other cut flowers 500 14000 0 turfgrass 0.3 transplanting, hand weeding, hand or mechanical harvesting 16,500 * 1600 0 mowing, scouting, irrigating 500 54000 0 golf course maintenance ( mowing) 3,400 * 8000 0 sod harvesting 6,800 * 4000 0 * TCs of 16,500 cm2/ hr for turf is from the policy 3.1. This value has been replaced with the values from the latest ARTF studies and is shown for comparative purposes.

It should be noted that there were a few scenarios for which no appropriate exposure data are known to exist or ongoing transfer coefficient studies have not yet been submitted ( e. g., ARTF nursery and ornamental data). The scope of HED's revised policy 3.1 for transfer coefficients should also be considered, as it only quantitatively addresses risks where the transfer coefficient model is appropriate ( i. e., where foliar contact is known to exist). There are many kinds of potential exposure pathways that do not involve foliar contact that have not been addressed in this risk assessment ( as defined in policy 3.1, refer to that document for a complete list). The scenarios include: Page 22 of 39 C Transplanting many crops, including in the ornamental and forestry industry; and C Various operations with Christmas trees, such as pruning or balling.

3.0 Non Occupational/ Residential Exposures and Risks There is a potential for non occupational exposure during the application process and for persons entering MGK 264 treated areas, such as lawns, golf courses, home gardens, and indoor surfaces ( carpets and flooring). Risk assessments have been completed for both residential handler and postapplication scenarios.

In addition to homeowner uses in residential settings, MGK 264 is labeled for wide area broadcast use for insect control, which would be applied by occupational applicators, but may result in postapplication exposures in residential settings. MGK reports that this use will no longer be supported. Therefore, exposure for this use was not assessed.

Residential handler and postapplication exposures were estimated based on current Standard Operating Procedures ( SOPs) for Exposure Assessments except where noted. The exposure estimates based on the SOPs are considered to be high end estimates.

3.1 Handlers 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 3.1.1 Data and Assumptions A series of assumptions and exposure factors served as the basis for completing the residential handler risk assessments. Each assumption and factor is detailed below. In addition to these factors, unit exposure values were used to calculate risk estimates. Mostly, these unit exposure values were taken from the Pesticide Handlers Exposure Database ( PHED) and the Outdoor Residential Exposure Task Force ( ORETF) studies. In other cases, chemical specific exposure data were submitted to support the reregistration of MGK 264. Both PHED and the individual studies 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.]

The assumptions and factors used in the risk calculations include:

C Residential handler exposure scenarios are considered to be short term only, due to the infrequent use patterns associated with homeowner products. Page 23 of 39 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 MGK 264 is a widely used pesticide active ingredient. It has many use patterns that would be difficult to completely capture in this document. As such, HED has developed this risk assessment on a series of representative scenarios that are believed to represent the majority of MGK 264 uses. Refinements to the assessment will be made as more detailed information about MGK 264 use patterns become available.

C Maximum application rates allowed by labels were assumed for all exposure scenarios.

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 MGK 264 assessment were from the Health Effects Division Science Advisory Committee Policy 12: Recommended Revisions To The Standard Operating Procedures For Residential Exposure Assessment which was completed on February 22, 2001, and on professional judgement.

C Residential handler unit exposures for MGK 264 were based on the same studies previous mentioned in the occupational handler assessment. The only study used for residential handlers that was not mentioned in the occupational section was a carbaryl homeowner dog dusting study ( MRID 444399 01, Carbaryl Applicator Exposure Study During Application of Sevin Dust to Dogs By the Non Professional, August 22, 1997). Page 24 of 39 3.1.2 Exposure Scenarios The anticipated use patterns and current labeling indicate several residential handler exposure scenarios based on the types of equipment and techniques that can potentially be used to make MGK 264 applications. The quantitative exposure/ risk assessment developed for residential handlers is based on the following scenarios:

Mixing/ Loading/ Applying Liquid Formulations with Low Pressure Handwand ( LPH) Mixing/ Loading/ Applying Formulations with Hose End Sprayer Mixing/ Loading/ Applying Formulations with Foggers Applying Ready to use Dusts with Shaker Can Applying Ready to use Shampoos Applying Ready to use Mousse, Soap, Lotion, Gel, Comb, or Roll On Products Applying Ready to use Wipes Applying Ready to use Formulations Using Trigger Pump Sprayer Applying Ready to use Aerosol Cans Applying Ready to use Foggers Applying Ready to use Impregnated Collars on Dogs 3.1.3 Equations for Exposure/ Risk Estimates The data used by HED have provided a basic broad overview of the uses of MGK 264 around a residential environment. However, it is likely that MGK 264 can be used in a myriad of ways that have not specifically been identified in this assessment. HED believes that the scenarios assessed in this document represent worse case exposures and risks resulting from use of MGK 264 in residential environments.

Handler data gaps exist for: ( 1) Dermal and inhalation handler monitoring for mixing/ loading/ applying liquids for fogger applications and ( 2) dermal and inhalation handler monitoring for mixing/ loading/ applying liquids for dip applications. MOEs estimated for residential handlers are presented in Table 6. MOEs for all of the scenarios assessed were greater than 1,000 and therefore not risk a concern. Page 25 of 39 Table 6. Residential Handler MOEs Exposure Scenario Crop or Target Application Rate Area Treated Daily MOEs Dermal Inhalation M/ L/ A Liquids with LPH ( PHED) Indoor/ Outdoor Spaces 0.00005 lb ai/ ft2 1000 ft2 13071 6.9e+ 05 M/ L/ A Liquids with Hose End Sprayer ( MRID,

44972201, ORETF) Outdoors 0.3 lb ai/ A 0.5 A 22182 5.1e+ 04 M/ L/ A Dusts via Shaker Can ( MRID 444598 01,

Carbaryl) Indoor Surfaces 0.00011 lb ai/ sq ft 256 ft2 8724 7.5e+ 03 M/ L/ A Dusts to Pets ( MRID 444399 01, Carbaryl) Pets 0.00248 lb ai/ pet 1 pet 4472 2.1e+ 06 Applying RTU Formulations via Shampoo ( MRID 446584 01, Carbaryl) Pets 0.0088 lb ai/ 16 oz can 0.1 16 oz can 23106 1.2e+ 12 Applying RTU Formulations via Mousse, Soap,

Lotion, Gel, Comb, or Roll On ( MRID 446584 01,

Carbaryl) Pets 0.0044 lb ai/ 16 oz can 0.1 16 oz can 46212 2.5e+ 12 Applying RTU Formulations via RTU Wipe ( CMA data) Pets 0.00018 lb ai/ wipe 1 wipes 72306 2.7e+ 04 Applying RTU Formulations via Trigger Pump Sprayer ( MRID 410547 01, Propoxur) Pets 0.022 lb ai/ 16 oz container 0.5 16 oz container 246465 9.6e+ 04 Applying RTU Formulations via Trigger Pump Sprayer ( MRID 410547 01, Propoxur) Indoor/ Outdoor Spaces 0.042 lb ai/ gal 0.25 gal 258201 1.0e+ 05 Applying RTU Formulations with Aerosol Cans ( PHED Data) Indoor/ Outdoor Surfaces & Spaces 0.0177 lb ai/ 16oz can 1 16 oz aerosol can 9399 3.1e+ 03 Applying RTU Formulations with Aerosol Cans ( PHED Data) Indoor Total Release Foggers 0.0064 lb ai/ 6 oz can 3 6 oz cans 8648 2.8e+ 03 Applying RTU Pet Collars ( R SOPs) Pets 998 mg ai/ collar 2 collars 1834 no data Page 26 of 39 3.2 Postapplication Activities HED uses the term " postapplication" to describe exposures to individuals that occur as a result of being in an environment that has been previously treated with a pesticide. MGK 264 can be used in many areas that can be frequented by the general population including residential areas ( e. g., home lawns and gardens). As a result, individuals can be exposed by entering these areas if they have been previously treated. MGK 264 can also be used on pets, which can lead to exposures by contact with the treated animal.

3.2.1 Data Sources ( not included in updated Residential SOPs)

Non Dietary Exposure Task Force ( NDETF) Studies  Data regarding surface residue deposition and air concentrations from application to foggers and aerosols in indoor residential settings were based on studies submitted by the Non Dietary Exposure Task Force ( NDETF).

Oral Exposures Since MGK 264 was not one of the active ingredients considered in the study, mean values from all of the applicable studies were used in this assessment. Hand transfer data used in this assessment comes from the bare wetted hand scenarios that were performed in some of the NDETF studies. Transfer of MGK 264 to bare hands from fogger treated carpet was assumed to be 9.1 percent of deposition based on data from Project ID 98 031 PY01 ( Volume 5) and Project ID 01 017 PY01 ( Volume 25) of the NDETF studies. Transfer of MGK 264 to bare hands from fogger treated vinyl flooring was assumed to be 5.8 percent of deposition based on data from Project ID 98 031 PY01 ( Volume 5) and Project ID 01 017 PY01 ( Volume 25) of the NDETF studies. These data were used to assess the toddler incidental oral ingestion hand tomouth from indoor surfaces scenario.

Dermal Exposures Roller and drag sled transfer data were averaged together for use in this assessment as there was little difference between the data sets. Transfer of MGK 264 to rollers from fogger treated carpet was assumed to be 4.5 percent of deposition based on data from Project ID 98 031 PY01 ( Volume 5) and Project ID 01 017 PY01 ( Volume 25) of the NDETF studies. Transfer of MGK 264 to rollers/ drag sleds from fogger treated vinyl flooring was assumed to be 2.3 percent of deposition based on data from Project ID 98 031 PY01 ( Volume 5) and Project ID 01 017 PY01 ( Volume 25) of the NDETF studies. These data was used to assess the adult and toddler dermal exposure from indoor surfaces scenarios.

Inhalation Exposures The MGK 264 Indoor air concentration for the period during and after aerosol space spray application was assumed to be 0.38 mg/ m3 based on data from Volume 18 of the NDETF Page 27 of 39 Study, " Measurement of Air Concentration, Dermal Exposure, and Deposition of Pyrethrin and Piperonyl Butoxide Following the Use of an Aerosol Spray". The measured two hour time weighted average air concentration of pyrethrin at the 5 foot level ( air samples were also collected at the one foot level) was 0.019 : g/ L ( 0.019 mg/ m3 ) following aerosol application of 9.3 grams of a 0.5% pyrethrin formulation. This application was made to a simulated residential room that had an interior volume of 2048 ft3. The theoretical concentration is 1.6 mg ai/ m3 ( 0.000051 lb ai/ 1000 ft3) based upon the above parameters and assuming no deposition ( the room was not ventilated during the two time period). The measured pyrethrin air concentration of 0.019 mg/ m3 was then adjusted by a factor of 20 ( rate of 0.001 lb ai/ 1000ft3 divided by study application rate of 0.00005 lb ai/ 1000ft3) to reflect the revised application rate of 0.001 lb ai/ 1000 ft3 proposed by MGK.

It should be noted that the label for EPA Reg No 1021 1710 ( label that MGK cites as basis for revised rate of 0.001 lb ai/ 1000 ft3) includes the following instructions: " Point valve away from face and push button, holding container upright. When using indoors, do not remain in treated area. Ventilate the area for 15 minutes following treatment. Allow treated surfaces to thoroughly dry before use."

MRID 466010 01, Human Exposure During and Following Use of a Pyrethrins/ Piperonyl Butoxide/ MGK 264 Shampoo Formulation on Dogs. Data from this study was used to assess toddler dermal and incidental oral exposure to MGK 264 following its use as a dog shampoo. The study measured dermal postapplication exposure of a person petting and hugging a dog after the dog was bathed with a shampoo containing pyrethrin, piperonyl butoxide, and MGK 264. Each postapplication exposure session was 30 minutes in duration and consisted of 20 minutes of petting and 10 minutes of hugging. Dermal exposure to hands and to a tee shirt dosimeter was measured following each 30 minute session. The postapplication exposure to the adult petter/ hugger was measured on the day of treatment at 4 hours following application and then at 1 day, 3 days, 7 days, and 14 days following treatment.

Dermal Exposures For assessing dermal postapplication exposure to MGK 264 following treatment to a dog with a pesticide shampoo, the total MGK 264 residue (: g) found on the study subjects' t shirt and hands were combined. The total exposure was divided by the pounds of active ingredient applied to the dog ( lb ai/ animal) to provide a dermal unit exposure value ( mg/ lb ai applied/ animal) for the 30 minute exposure period on each day that samples were taken. The dermal unit exposure value ( mg/ lb ai applied/ animal) for 4 hours, 1 day, 3 days, 7 days, and 14 days following treatment were 205, 120, 61, 28, 10, respectively. The 4 hour value was used for short term exposure estimates.

Oral Exposures Page 28 of 39 For assessing incidental oral ingestion ( hand to mouth activity) to MGK 264 following treatment to a dog with a pesticide shampoo, postapplication exposure was determined using the MGK 264 residue (: g) found on the study subjects' hands. The residue on hands was divided by the average palmar surface area of the study subjects' hands ( 145.24 cm2/ hand x 2 hands = 290.48 cm2) to obtain the : g ai/ cm2 hand surface. This value was divided by the pounds of active ingredient applied to the dog ( lb ai/ animal) to provide a unit exposure value for hands (: g/ cm2/ lb ai applied/ animal) for the 30 minute exposure period on each day that samples were taken. The unit exposure value for hands (: g/ cm2/ lb ai applied/ animal) for 4 hours, 1 day, 3 days, 7 days, and 14 days following treatment were 806, 508, 256, 133, 44, respectively. The 4 hour value was used for short term exposure estimates ( assuming 30 minutes of exposure and no salvia extraction). The approach used to estimate dermal and oral exposures is believed to represent the high end of toddler's potential exposures from treated dogs. The results of study were not used for dusts applied to dogs based on the major differences in formulation and rate ( i. e. 0.0008 lb ai/ dog versus 0.05 lb ai/ dog). Exposures from dusts application were estimated using R SOPs ( 20% transferable residue).

Single Chamber Modeling Approach for Metered Release Units  Indoor air concentrations resulting from the use of the compact metered release units in homes were modeled using a single chamber modeling approach. This approach is intended for vapors and is considered to be a conservative screen for assessing aerosols. Time weight average concentrations of MGK 264 for estimated using the equation,

Air concentration at time t = Initial air concentration * 0.5 ( t/ 0.693* Q/ V)

Assuming each spray contains 55 mg of product with 3.21% and a 170 ft3 room, the initial air concentration was assumed to be 0.01 mg/ m3. It was assumed that there are 0.18 air changes per hour which is the recommended in the R SOPs for air exchange rate for a typical house in the summer time. Air concentrations were estimated every minute using the above equation assuming that a new spray occurred ever 15 minutes ( 1.77 mg ai/ spray event). The air concentration reached a steady state after approximately 24 hours. The average concentration after 24 hours was estimated to be 0.25 mg/ m3 and assumed to remain somewhat constant for several weeks. This estimate is assumed to be the worst case for registered use sites since air exchange rates in homes are usually less than what is expected for other registered use sites ( e. g. food handling establishments, barns, day care, and other commercial sites).

The same single chamber modeling approach was used by the Agency to assess pyrethrin. MGK submitted an assessment using the same approach for PBO and pyrethrin to evaluate a metered release scenario in a food handling establishment ( MRID 466275 01). In MGK's assessment 2 air changes per hour were assumed.

On 2/ 10/ 05 MGK stated that ` There are EPA registered products bearing the label claim " Homes" on the label, however we are advised that products are not being sold for use in Page 29 of 39 homes, that the claim was established for " homes" to be sold in countries other than the USA, where sanitation is poor and the units are used in residences to control flies, mosquitoes and the other listed pests. We have submitted data and several papers to the Agency concerning long term exposure and we have not had any response back from the Agency. We believe that our full support of all existing uses depends upon the Agency's response to our submission'.

MOEs were estimated for the same inputs above with 2 air changes per hour for comparative purposes.

Insect repellents applied directly to skin  The master label indicates that products containing up to 8% MGK 264 are registered for direct application to skin. MGK's 11/ 21/ 05 submission indicates that they are reducing the maximum to 5%. HED assumed that these products may include lotions, aerosol cans, pump sprays, and pre treated wipes. No chemical specific exposure or use data were submitted in support of these uses. Currently, HED's SOPs for Residential Exposure Assessments ( 12/ 18/ 97) contain no method for estimating exposure to repellents that are applied to the skin. Dermal and Oral exposure was calculated based a conservative method used in HED November 16, 2001 memo, " Human Health Risk Assessment for KBR 3023 All Family Insect Repellent Spray & Cream" ( D279006). Dermal exposure was also estimated based on data from the Residential Exposure Joint Venture ( REJV), National Pesticide Use Survey. HED conducted an analyses of the survey for MGK 326 in 2003 ( D292906).

Dermal Exposures Exposure was first estimated using default assumptions for body surface area, body weight, the percent of the body area that a repellent product is applied to, and the rate of application ( 1 mg product/ cm2 of skin).

The REJV survey data was also used to estimate dermal exposures. In the survey it was reported that the mean amount of product applied to the skin and clothes of adult males and children 12 years and under was 5.2 and 4.8 grams, respectively. These values were assumed to be the amount of dermal exposure that adults and toddlers would receive from each application.

Both methods produced similar estimates for dermal exposure.

Oral Exposures Although the proposed label instructions prohibit direct application to the hands of small children, it was determined that some of the product from treated areas of the skin may be transferred to the hands of the children and subsequent hand to mouth ingestion may occur.

It was assumed that both hands of a child are covered with product at the rate of 1 mg formulation/ cm2. This rate is a standard value that has been used in other OPP assessments for Page 30 of 39 insect cream/ lotion repellents applied directly to the skin. There are no adequate data on the frequency and rate of transfer from treated skin to untreated hands of children. The assumption that the hands are covered at the same rate as the treated skin is considered a high end value.

It was assumed that each single oral exposure event involves the child placing the palmar surface of 3 fingers of one hand ( 20 cm2) into their mouth. A saliva extraction factor of 0.5 was applied to determine the quantity of product ingested. The use of the palmar surface area and 50% saliva extraction is consistent with current standard operating procedures for assessing handto mouth contact with residues on turf grass. Removal of product from wiping hands on clothes or surfaces or from washing hands was not considered.

Dust Applied to Indoor Carpets  The instructions on label for EPA 2596 132 say to: ( 1) keep children and pets out of the room; ( 2) apply at rate of 20 oz of product per 135 square feet of carpet ( i. e. 0.011 lb ai/ 100 ft2); ( 3) leave on for 2 hours, then vacuum; ( 4) remove vacuum bag and discard in trash. There was no data available to quantify the deposition of MKG 264 following vacuuming. Therefore, deposition rates of 100%, 50%, and 25% of the application label rate were assumed. The submission of data with deposition rates following vacuuming could be used to refine risk estimates ( provided it meets Agency guidelines).

3.2.2 Equations for Exposure/ Risk Estimates Non cancer risks were calculated using the Margin of Exposure ( MOE) approach, which is a ratio of the body burden to the toxicological endpoint of concern. The following equations were used to calculate the average daily dose ( ADD) for each residential exposure scenario in accordance with current HED SOPs:

Dermal Exposure from Treated Lawns ADD = ( TTR0 * ET * TC * DA * CF1) / BW Where: ADD = average daily dose ( mg/ kg/ day); TTRt = turf transferable residue on day " 0" ( µ g/ cm2); ET = exposure time ( 2 hr/ day); TC = transfer coefficient ( 14,500 cm2/ hr for adults and 5,200 cm2/ hr for toddlers); DA = dermal absorption factor ( 10%); CF1 = weight unit conversion factor to convert µ g units to mg for the daily exposure ( 0.001 mg/ µ g); and BW = body weight ( 60 kg for adults and 15 kg for toddlers).

Hand to mouth Transfer from Treated Lawns ADD = ( TTR0 * SA * FQ * ET * SE * CF1) / BW Where: ADD = average daily dose ( mg/ kg/ day); TTRt = turf transferable residue on day " 0" ( µ g/ cm2 ); Page 31 of 39 SA = surface area of the hands ( 20 cm2/ event); FQ = frequency of hand to mouth activity ( 20 events/ hr); ET = exposure time ( 2 hr/ day); SE = extraction by saliva ( 50%); CF1 = weight unit conversion factor to convert µ g units in the DFR value to mg for the daily exposure ( 0.001 mg/ µ g); and BW = body weight ( 15 kg).

Object to mouth Transfer from Treated Lawns ADD = ( TTR0 * IgR* CF1) / BW Where: ADD = average daily dose ( mg/ kg/ day); TTRt = turf transferable residue on day " 0" ( µ g/ cm2); IgR = ingestion rate of grass ( 25c cm2/ day); CF1 = weight unit conversion factor to convert the µ g of residues on the grass to mg to provide units of mg/ day ( 1E 3 mg/ µ g); and BW = body weight ( 15 kg).

Incidental Ingestion of Treated Soil ADD = ( SR0 * IgR * CF1) / BW Where: ADD = average daily dose ( mg/ kg/ day); SR0t = soil residue on day " 0" ( 0.0022 µ g/ g); IgR = ingestion rate of soil ( 100 mg/ day); CF1 = weight unit conversion factor to convert the µ g of residues on the soil to grams to provide units of mg/ day ( 1E 6 g/ µ g); and BW = body weight ( 15 kg).

and SRt = TTRt * F * CF2 Where: TTRt = turf transferable residue on day " 0" ( µ g/ cm2); F = fraction of ai available in uppermost cm of soil ( 1 fraction/ cm); and CF2 = volume to weight unit conversion factor to convert the volume units ( cm3) to weight units for the SR value ( U. S. EPA, 1992) ( 0.67 cm3/ g soil).

Dermal Exposure From Treated Pets ( based on R SOPs)

D = {(( AR* FAR)/ SApet) * ( 1 DR) t * SAhug * DA}/ BW Where: ADD = average daily dose via dermal pet contact ( mg/ kg/ day); AR = application rate or amount applied to animal in a single treatment ( mg ai/ animal); FAR = fraction of the application rate available for dermal contact as transferable residue ( 20%); SApet = surface area of a treated 30 lb dog ( 5,986cm2/ animal); t = time after application ( days); Page 32 of 39 DR = fractional dissipation rate per day ( 5% per day); SA hug = surface area of a child hug ( 1,875cm2 contact/ hug); DA = dermal absorption factor ( 10%); and BW = body weight ( 15 kg).

Hand to mouth Transfer From Treated Pets ( based on R SOPs)

D = {(( AR* FAR)/ SApet) * ( 1 DR) t * SE * SAhands * FQ * ET * DA}/ BW Where: D = nondietary ingestion dose from with treated pets ( mg/ day); AR = application rate or amount applied to animal in a single treatment ( mg ai/ animal); FAR = fraction of the application rate available for dermal contact as transferable residue ( 20%/ 100); SApet = surface area of a treated dog ( 5,986 cm2/ animal); t = time after application ( days); DR = fractional dissipation rate per day ( 5% per day/ 100); SE = saliva extraction factor ( 50% extractability); SAhands = surface area of the hands ( 20 cm2); FQ = frequency of hand to mouth activity ( 20 events/ hr); ET = exposure time ( 2 hr/ day); DA = dermal absorption factor ( 10%); and BW = body weight ( 15 kg).

Dermal Exposure From Treated Pets ( based on MGK 264 shampoo study)

ADD = AR * UE * DA / BW Where ADD = Average Daily Dose ( mg/ kg/ day), AR = Application rate ( lb ai/ animal), UE = Postapplication exposure ( 205 mg/ lb ai applied/ animal), DA = Dermal absorption ( 10%), and BW = Body weight ( 15 kg).

Hand to mouth Transfer From Treated Pets ( based on MGK 264 shampoo study)

ADD = AR * UE * CF1 * SA * FQ * ET / BW Where: ADD = Average Daily Dose ( mg/ kg/ day), AR = Application rate ( lb ai/ animal), UE = Postapplication dermal unit exposure to hands ( 806 ug/ cm2/ lb ai applied/ animal), CF1 = Conversion factor ( 0.001 mg/ ug), SA = Surface area of a toddler's fingers ( 20 cm2/ event), FQ = Exposure frequency ( 20 events/ hour), ET = Exposure time( 0.5 hours/ day), BW = Body weight ( 15kg).

Dermal Exposure from Indoor Surfaces after Spray Treatment Page 33 of 39 ADD = ( AR * TR * ET * TC * CF1 * CF2) / BW Where: ADD = average daily dose ( mg/ kg/ day); AR = application rate; ( lb ai/ ft2) TR = transferable residue available ( 5% for carpets and 10% for vinyl flooring, calculated from NDETF studies); ET = exposure time ( 8 hr/ day for carpets and 4 hr/ day for vinyl flooring); TC = transfer coefficient ( 16,700 cm2/ hr for adults and 6,000 cm2/ hr for toddlers); CF1 = weight unit conversion factor to convert lb units to mg for the daily exposure ( 4.54E5 mg/ lb) CF2 = area unit conversion factor to convert ft2 units to cm2 for the daily exposure ( 1.08E 3 ft2/ cm2); and BW = body weight ( 60 kg for adults and 15 kg for toddlers).

Hand to mouth Transfer from Indoor Surfaces after Spray Treatment ADD = ( AR * % D * SA * FQ * ET * SE * CF1 * CF2) / BW Where: ADD = average daily dose ( mg/ kg/ day); AR = application rate; % D = percent active ingredient dislodgeable ( 5% for carpets and 10% for vinyl flooring, calculated from NDETF studies); SA = surface area of the hands ( 20 cm2/ event); FQ = frequency of hand to mouth activity ( 20 events/ hr); ET = exposure time ( 2 hr/ day); SE = extraction by saliva ( 50%); CF1 = weight unit conversion factor to convert lb units to mg for the daily exposure ( 4.54E5 mg/ lb) CF2 = area unit conversion factor to convert ft2 units to cm2 for the daily exposure ( 1.08E 3 ft2/ cm2); and BW = body weight ( 15 kg).

Dermal Exposure from Indoor Surfaces after Fogger Treatment ADD = ( AR * TR * ET * TC * CF1 * CF2) / ( BW * RS) Where: ADD = average daily dose ( mg/ kg/ day); AR = application rate ( lb ai/ fogger); TR = transferable residue available ( 4.5% for carpets and 2.3% for vinyl flooring, calculated from NDETF studies); ET = exposure time ( 8 hr/ day for carpets and 4 hr/ day for vinyl flooring); TC = transfer coefficient ( 16,700 cm2/ hr for adults and 6,000 cm2/ hr for toddlers) CF1 = weight unit conversion factor to convert lb units to mg for the daily exposure ( 4.54E8 mg/ lb) CF2 = area unit conversion factor to convert ft2 units to cm2 for the daily exposure ( 1.08E 3 ft2/ cm2); BW = body weight ( 60 kg for adults and 15 kg for toddlers); and RS = room size in square feet ( 264 sq feet based on NDETF studies). Page 34 of 39 Hand to mouth Transfer from Indoor Surfaces after Fogger Treatment ADD = ( AR * % D * SA * FQ * ET * SE * CF1 * CF2) / BW * RS Where: ADD = average daily dose ( mg/ kg/ day); AR = application rate( lb ai/ fogger); % D = percent active ingredient dislodgeable ( 9.1% for carpets and 5.8% for vinyl flooring, calculated from NDETF studies); SA = surface area of the hands ( 20 cm2/ event); FQ = frequency of hand to mouth activity ( 20 events/ hr); ET = exposure time ( 2 hr/ day); SE = extraction by saliva ( 50%); CF1 = weight unit conversion factor to convert lb units to mg for the daily exposure ( 4.54E5 mg/ lb) CF2 = area unit conversion factor to convert ft2 units to cm2 for the daily exposure ( 1.08E 3 ft2/ cm2); BW = body weight ( 15 kg); and RS = room size in square feet ( 264 sq feet based on NDETF studies).

Inhalation Exposure from Space Spray Applications ADD = ( BZC * BR * ET) / BW Where: BZC = Breathing zone concentration in mg/ m3 ( for aerosol sprays the measured air concentration from NDETF study adjusted to reflect the application rate the BZC is 2.28 mg/ m3, for metered release in homes the 24 hr BZC is 0.23 mg/ m3) BR = Breathing rate for adult or child in m3/ hr or m3/ day ( adult is 13.3 m3/ day or 1.0 m3/ hr, child is 8.7 m3/ day or 0.7 m3/ hr); BW = body weight ( 70 kg for adults and 15 kg for toddlers); and ET = exposure time ( hrs/ day);

Dermal Exposure from Insect Repellents Applied to Skin ADD = ( AR * % ai * SA * DA* FQ)/ BW Where: ADD = average daily dose ( mg/ kg/ day); AR = application rate( mg product/ cm2 of skin); % ai = percent active ingredient in formulation ( 8%) SA = surface area of the body ( cm2); % SA = percent of SA treated ( 25%); DA = dermal absorption factor ( 10%); and FQ = frequency of application ( 1 per day); and BW = body weight ( 70 kg for adults and 15 kg for toddlers)

Oral Exposure from Insect Repellents applied to Skin ADD = ( AR * % ai * SA * SE* FQ)/ BW Where: Page 35 of 39 ADD = average daily dose ( mg/ kg/ day); AR = application rate( mg product/ cm2 of skin); % ai = percent active ingredient in formulation ( 8%) SA = surface area of the hands ( 20 cm2/ event); FQ = frequency of hand to mouth activity ( 1 event/ day); SE = extraction by saliva ( 50%); FQ = frequency of application ( 1 per day); and BW = body weight ( 15 kg for toddlers) Page 36 of 39 3.2.3 Risk Summary Estimated MOEs for adults and toddlers were calculated for postapplication risks following the application of MGK 264 to home lawns, indoor spaces/ surfaces, and pets and summarized in Table 7. MOEs of less than 1,000 were estimated for the following scenarios:

Toddlers C Dermal exposure for indoor spray applications to hard and carpeted surfaces ( MOE= 80)

C Dermal exposure for indoor fogger applications to carpeted surfaces ( MOE= 840)

C Oral exposure to indoor dust applications to carpeted surfaces ( MOE = 850 for 50% deposition)

C Dermal exposure to indoor dust applications to carpeted surfaces ( MOE = 410 for 25% deposition)

C Inhalation exposure to indoor space applications done with an aerosol can ( MOE = 52)

C Inhalation exposure to indoor metered release applications ( MOE = 13 for 0.18 ACH and MOE= 140 for 2 ACH)

C Dermal exposure to 5% insect repellants applied to skin ( MOE = 38 for one application)

C Oral exposure to 5% insect repellants applied to skin ( MOE = 38 to 110 for one application)

Adults C Dermal exposure to indoor dust applications to carpeted surfaces ( MOE = 290 for 25% deposition)

C Inhalation exposure to indoor space applications done with an aerosol can ( MOE = 170)

C Inhalation exposure to indoor metered release applications ( MOE = 40 for 0.18 ACH and MOE = 440 for 2 ACH)

C Dermal exposure to 5% insect repellants applied to skin ( MOE = 140 to 160 for one application) Page 37 of 39 Table 7. Residential Postapplication MOEs Exposure Scenario Route of Exposure Application Rate MOEs1 Adults Toddlers Outdoors Residential Turf ( High Contact Activities) Dermal 0.3 lb ai/ acre 7,500 5,231 Residential Turf ( Mowing) Dermal 0.3 lb ai/ acre 30,000 NA Hand to Mouth Activity on Turf Oral 0.3 lb ai/ acre NA 14,000 Object to Mouth Activity on Turf Oral 0.3 lb ai/ acre NA 54,400 Incidental Soil Ingestion Oral 0.3 lb ai/ acre NA 4,100,000 Indoors Hand to Mouth Activity on Indoor Surfaces ( Spray applications to carpeted surfaces) Oral 0.01 lb ai/ 1000 ft2 NA 4,700 Hand to Mouth Activity on Indoor Surfaces ( Fogger applications to carpeted surfaces) Oral 0.01 lb ai/ 1000 ft2 NA 2,500 Hand to Mouth Activity on Indoor Surfaces ( Fogger applications to hard surfaces) Oral 0.01 lb ai/ 1000 ft2 NA 7,900 Hand to Mouth Activity on Indoor Surfaces ( dust applications to carpeted surfaces) 100% of surface residue available Oral 0.011 lb ai/ 100 ft2 NA 430 Hand to Mouth Activity on Indoor Surfaces ( dust applications to carpeted surfaces) 50% of surface residue available Oral 0.011 lb ai/ 100 ft2 NA 850 Hand to Mouth Activity on Indoor Surfaces ( dust applications to carpeted surfaces) 25% of surface residue available Oral 0.011 lb ai/ 100 ft2 NA 1700 Indoor Surfaces ( Spray applications to carpeted/ hard surfaces) Dermal 0.01 lb ai/ 1000 ft2 1,000 780 Indoor Surfaces ( Fogger applications to carpeted surfaces) Dermal 0.01 lb ai/ 1000 ft2 1,200 840 Indoor Surfaces ( Fogger applications to hard surfaces) Dermal 0.01 lb ai/ 1000 ft2 4,700 3,300 Indoor Surfaces ( dust applications to carpeted surfaces) 100% of surface residue available Dermal 0.011 lb ai/ 100 ft2 100 70 ( dust applications to carpeted surfaces) 50% of surface residue available Dermal 0.011 lb ai/ 100 ft2 210 140 ( dust applications to carpeted surfaces) 25% of surface residue available Dermal 0.011 lb ai/ 100 ft2 290 410 Inhalation Exposure from Space Sprays ( aerosol cans) Inhalation 0.001 lb ai/ 1000 ft3 170 52 Inhalation Exposure from Space Sprays in homes ( metered release with 0.18 air changes per hour) Inhalation 1.77 mg ai/ spray event 40 13 Inhalation Exposure from Space Sprays ( metered release with 2 air changes per hour) Inhalation 1.77 mg ai/ spray event 440 140 Table 7. Residential Postapplication MOEs Exposure Scenario Route of Exposure Application Rate MOEs1 Adults Toddlers Page 38 of 39 Pets Hand to Mouth Activity Following Pet Contact ( Dust using R SOPs) Oral 0.00248 lb ai/ animal NA 130 Pet Contact ( Dust using R SOPs) Dermal 0.05lb ai/ animal NA 61 Hand to Mouth Activity Following Pet Contact ( Shampoo using MGK 264 data) Oral 0.00088 lb ai/ animal NA 6,500 Hand to Mouth Activity Following Pet Contact ( Mousse, Soap, Gel, Comb or roll on using MGK 264 data) Oral 0.00044 lb ai/ animal NA 13,000 Pet Contact ( Shampoo using MGK 264 data) Dermal 0.00088 lb ai/ animal NA 100,000 Pet Contact ( Mousse, Soap, Gel, Comb or roll on using MGK 264 data) Dermal 0.00044lb ai/ animal NA 50,000 Insect Repellents Applied to Skin One Application to 25% of Body Surface Area Using 1 mg product per cm2 of skin Dermal 8% ai formulation 100 70 Oral NA 1,100 One Application Based on REJV Survey Data Dermal 88 24 One Application to 25% of Body Surface Area Using 1 mg product per cm2 of skin Dermal 5% ai formulation 160 110 Oral NA 1,830 One Application Based on REJV Survey Data Dermal 140 38 1 MOEs of less than 1,000 are a risk concern Page 39 of 39 Appendices ( 14 pages of Excel Spread Sheets)