Maximum Application Rate[a]
                                   (lb ai/A)
               Area Treated or Amount Handled Daily[b] (A/day)
                               Unit Exposure[d]
                         Daily Exposure[e] (mg/kg/day)
                                    MOE[f]

Baseline Dermal[c] (mg/lb ai)
PPE-G Dermal[c] (mg/lb ai)
Baseline Inhalation[c] (ug/lb ai)
Baseline Dermal
PPE-G Dermal
Baseline Inhalation
Baseline Dermal
PPE-G Dermal
Baseline Inhalation
                                 Mixer/Loader
  Mixing/Loading Liquid Concentrates for Aerial and Chemigation Applications
Artichoke (globe); Brassica (cole) Leafy Vegetables; Bulb Vegetables; Carrot; Citrus; Cucurbit Vegetables; Fruiting Vegetables; Ginseng; Grapes and Small Vine Fruits (except Fuzzy Kiwifruit); Herbs and Spices (except Black Pepper); Hops; Leafy Vegetables; Pome Fruit; Other Root, Tuberous and Corm Vegetables; Small Berries (Caneberries and Bushberries); Stone Fruit; Strawberry and Other Low-Growing Berries
                                     0.222
                                      350
                                     0.22
                                    0.0376
                                     0.219
                                     0.214
                                    0.0365
                                    2.13E-4
                                     1,400
                                     8,200
                                    68,000

               Brassica Leafy Vegetables Head and Stem Subgroup
                                     0.125
                                      350

                                     0.120
                                    0.0206
                                    1.20E-4
                                     2,500
                                    15,000
                                    120,000

Canola Subgroup; Cereal grains; Forage, Fodder, or Straw from Cereal Grains; Cotton; Legume Vegetables (including Soybean); Potato; Sugar Beet; Sunflower subgroup
                                     0.222
                                     1200

                                     0.733
                                     0.125
                                    7.29E-4
                                      410
                                     2,400
                                    20,000

           Nursery (ornamentals, vegetables, trees, container stock)
                                     0.131
                                      60

                                    0.0216
                                    0.00370
                                    2.15E-5
                                    14,000
                                    81,000
                                    670,000

                                      Sod
                                     0.446
                                      350

                                     0.429
                                    0.0734
                                    4.28E-4
                                      700
                                     4,100
                                    34,000
        Mixing/Loading Liquids Concentrates for Groundboom Applications
Artichoke (globe); Brassica (cole) Leafy Vegetables; Bulb Vegetables; Carrot; Citrus; Cucurbit Vegetables; Fruiting Vegetables; Ginseng; Grapes and Small Vine Fruits (except Fuzzy Kiwifruit); Herbs and Spices (except Black Pepper); Hops; Leafy Vegetables; Pome Fruit; Other Root, Tuberous and Corm Vegetables; Small Berries (Caneberries and Bushberries); Stone Fruit; Strawberry and Other Low-Growing Berries
                                     0.222
                                      80
                                     0.22
                                    0.0376
                                     0.219
                                    0.0489
                                    0.00835
                                    4.86E-5
                                     6,00
                                    36,000
                                    300,000

               Brassica Leafy Vegetables Head and Stem Subgroup
                                     0.125
                                      80

                                    0.0275
                                    0.00470
                                    2.74E-5
                                    11,000
                                    64,000
                                    530,000

Canola Subgroup; Cereal grains; Forage, Fodder, or Straw from Cereal Grains; Cotton; Legume Vegetables (including Soybean); Potato; Sugar Beet; Sunflower subgroup
                                     0.222
                                      200

                                     0.122
                                    0.0209
                                    1.22E-4
                                     2,500
                                    14,000
                                    120,000

                            Field Grown Ornamentals
                                     0.131
                                      40

                                    0.0144
                                    0.00246
                                    1.44E-5
                                    21,000
                                    120,000
                                    1.0E+6

           Nursery (ornamentals, vegetables, trees, container stock)
                                     0.131
                                      60

                                    0.0216
                                    0.0037
                                    2.15E-5
                                    14,000
                                    81,000
                                    670,000

                                      Sod
                                     0.446
                                      80

                                    0.0981
                                    0.0168
                                    9.76E-5
                                     3,100
                                    18,000
                                    150,000

                                     Turf
                                     0.446
                                      40

                                    0.0490
                                    0.00839
                                    4.89E-5
                                     6,100
                                    36,000
                                    300,000
         Mixing/Loading Liquids Concentrates for Airblast Applications
           Nursery (ornamentals, vegetables, trees, container stock)
                                     0.131
                                      20
                                     0.22
                                    0.0376
                                     0.219
                                    0.00720
                                    0.00123
                                    7.18E-6
                                    42,000
                                    240,000
                                    2.0E+6

Grapes and Small Vine Fruits (except Fuzzy Kiwifruit); Pome Fruit; Stone Fruit;
                                     0.222
                                      40

                                    0.0244
                                    0.00418
                                    2.43E-5
                                    12,000
                                    72,000
                                    600,000
                                  Applicator
                     Applying Sprays via Aerial Equipment
Artichoke (globe); Brassica (cole) Leafy Vegetables; Bulb Vegetables; Carrot; Citrus; Cucurbit Vegetables; Fruiting Vegetables; Ginseng; Grapes and Small Vine Fruits (except Fuzzy Kiwifruit); Herbs and Spices (except Black Pepper); Hops; Leafy Vegetables; Pome Fruit; Other Root, Tuberous and Corm Vegetables; Small Berries (Caneberries and Bushberries); Stone Fruit; Strawberry and Other Low-Growing Berries
                                     0.222
                                      350
                                  0.00208[g]
                                    No Data
                                   0.0049[g]
                                    0.00203
                                    No Data
                                    4.76E-6
                                    150,000
                                    No Data
                                    3.0E+6

               Brassica Leafy Vegetables Head and Stem Subgroup
                                     0.125
                                      350

                                    0.00114
                                    No Data
                                    2.68E-6
                                    260,000
                                    No Data
                                    5.4E+6

Canola Subgroup; Cereal grains; Forage, Fodder, or Straw from Cereal Grains; Cotton; Legume Vegetables (including Soybean); Potato; Sugar Beet; Sunflower subgroup
                                     0.22
                                     1200

                                    0.00693
                                    No Data
                                    1.64E-5
                                    43,000
                                    No Data
                                    880,000

           Nursery (ornamentals, vegetables, trees, container stock)
                                     0.131
                                      60

                                   0.000204
                                    No Data
                                    4.81E-7
                                    1.5E+6
                                    No Data
                                    3.0E+7

                                      Sod
                                     0.446
                                      350

                                    0.00406
                                    No Data
                                    9.56E-6
                                    74,000
                                    No Data
                                    1.5E+6
                   Applying Sprays via Groundboom Equipment
Artichoke (globe); Brassica (cole) Leafy Vegetables; Bulb Vegetables; Carrot; Citrus; Cucurbit Vegetables; Fruiting Vegetables; Ginseng; Grapes and Small Vine Fruits (except Fuzzy Kiwifruit); Herbs and Spices (except Black Pepper); Hops; Leafy Vegetables; Pome Fruit; Other Root, Tuberous and Corm Vegetables; Small Berries (Caneberries and Bushberries); Stone Fruit; Strawberry and Other Low-Growing Berries
                                     0.222
                                      80
                                    0.0786
                                    0.0161
                                     0.34
                                    0.0175
                                    0.00358
                                    7.55E-5
                                    17,000
                                    84,000
                                    190,000

               Brassica Leafy Vegetables Head and Stem Subgroup
                                     0.125
                                      80

                                    0.00983
                                    0.00201
                                    4.25E-5
                                    31,000
                                    150,000
                                    340,000

Canola Subgroup; Cereal grains; Forage, Fodder, or Straw from Cereal Grains; Cotton; Legume Vegetables (including Soybean); Potato; Sugar Beet; Sunflower subgroup
                                     0.222
                                      200

                                    0.0436
                                    0.00894
                                    1.89E-4
                                     6,900
                                    34,000
                                    77,000

                            Field Grown Ornamentals
                                     0.131
                                      40

                                    0.00515
                                    0.00106
                                    2.23E-5
                                    58,000
                                    280,000
                                    650,000

           Nursery (ornamentals, vegetables, trees, container stock)
                                     0.131
                                      60

                                    0.00773
                                    0.00159
                                    3.34E-5
                                    39,000
                                    190,000
                                    430,000

                                      Sod
                                     0.446
                                      80

                                    0.0175
                                    0.00359
                                    7.59E-5
                                    17,000
                                    84,000
                                    190,000

                                     Turf
                                     0.446
                                      40

                                    0.0350
                                    0.00718
                                    1.51E-4
                                     8,600
                                    42,000
                                    96,000
                    Applying Sprays via Airblast Equipment
           Nursery (ornamentals, vegetables, trees, container stock)
                                     0.222
                                      20
                                     1.77
                                     1.59
                                     4.71
                                    0.0580
                                    0.0521
                                    1.54E-4
                                     5,200
                                     5,800
                                    94,000

Grapes and Small Vine Fruits (except Fuzzy Kiwifruit); Pome Fruit; Stone Fruit
                                     0.131
                                      40

                                     0.196
                                     0.176
                                    5.23E-4
                                     1,500
                                     1,700
                                    28,000
                                    Flagger
                    Flagging for Aerial Sprays Applications
Artichoke (globe); Brassica (cole) Leafy Vegetables; Bulb Vegetables; Carrot; Citrus; Cucurbit Vegetables; Fruiting Vegetables; Ginseng; Grapes and Small Vine Fruits (except Fuzzy Kiwifruit); Herbs and Spices (except Black Pepper); Hops; Leafy Vegetables; Pome Fruit; Other Root, Tuberous and Corm Vegetables; Small Berries (Caneberries and Bushberries); Stone Fruit; Strawberry and Other Low-Growing Berries
                                     0.222
                                      350
                                     0.011
                                     0.012
                                     0.35
                                    0.0107
                                    0.0117
                                    3.40E-4
                                    28,000
                                    26,000
                                    43,000

               Brassica Leafy Vegetables Head and Stem Subgroup
                                     0.125
                                      350

                                    0.00601
                                    0.00656
                                    1.91E-4
                                    50,000
                                    46,000
                                    76,000

Canola Subgroup; Cereal grains; Forage, Fodder, or Straw from Cereal Grains; Cotton; Legume Vegetables (including Soybean); Potato; Sugar Beet; Sunflower subgroup
                                     0.22
                                     1200

                                    0.0366
                                     0.040
                                    0.00117
                                     8,200
                                     7,500
                                    12,000

           Nursery (ornamentals, vegetables, trees, container stock)
                                     0.131
                                      60

                                    0.00108
                                    0.00118
                                    3.44E-5
                                    280,000
                                    250,000
                                    420,000

                                      Sod
                                     0.446
                                      350

                                    0.0215
                                    0.0234
                                    6.83E-4
                                    14,000
                                    13,000
                                    21,000
                            Mixer/Loader/Applicator
Mixing/Loading/Applying Liquid Concentrates with Manually Pressurized Handwand
                            Greenhouse Ornamentals
                               0.00131 lb ai/gal
                                    40 gal
                                      100
                                     0.43
                                      30
                                    0.0655
                                    2.81E-4
                                    1.96E-5
                                     4,600
                                    1.1E+6
                                    740,000

           Nursery (ornamentals, vegetables, trees, container stock)
                               0.00131 lb ai/gal

                                    0.0655
                                    2.81E-4
                                    1.96E-5
                                     4,600
                                    1.1E+6
                                    740,000

                                Christmas Trees
                               0.00223 lb ai/gal

                                     0.112
                                    4.80E-4
                                    3.35E-5
                                     2,700
                                    630,000
                                    430,000

                                     Turf
                               0.0026 lb ai/gal

                                     0.130
                                    5.59E-4
                                    3.90E-5
                                     2,300
                                    540,000
                                    370,000
Mixing/Loading/Applying Liquid Concentrates with Mechanically-Pressurized Handgun
                            Greenhouse Ornamentals
                               0.00131 lb ai/gal
                                   1000 gal
                                      3.5
                                      2.5
                                      120
                                    0.0574
                                    0.0410
                                    0.00196
                                     5,200
                                     7,300
                                     7,400

           Nursery (ornamentals, vegetables, trees, container stock)
                               0.00131 lb ai/gal
                                   1000 gal
                                      1.3
                                     0.39
                                      3.9
                                    0.0213
                                    0.00639
                                    6.39E-5
                                    14,000
                                    47,000
                                    230,000

                                Christmas Trees
                               0.00223 lb ai/gal
                                   1000 gal

                                    0.0363
                                    0.0109
                                    1.09E-4
                                     8,300
                                    28,000
                                    130,000

                            Pome Fruit; Stone Fruit
                               0.0222 lb ai/gal
                                   1000 gal

                                     0.361
                                     0.108
                                    0.00108
                                      830
                                     2,800
                                    13,000

                               Golf Course; Turf
                                     0.446
                                       5
                                     1.14
                                     0.88
                                      1.9
                                    0.0318
                                    0.0245
                                    5.30E-5
                                     9,400
                                    12,000
                                    270,000
          Mixing/Loading/Applying Liquid Concentrates with a Backpack
           Nursery (ornamentals, vegetables, trees, container stock)
                               0.00131 lb ai/gal
                                    40 gal
                                     13.2
                                     11.2
                                      140
                                    0.00865
                                    0.00734
                                    1.98E-5
                                    35,000
                                    41,000
                                    160,000

                                Christmas Trees
                               0.00223 lb ai/gal

                                    0.0148
                                    0.0125
                                    1.56E-4
                                    20,000
                                    24,000
                                    93,000

                            Pome Fruit; Stone Fruit
                               0.0222 lb ai/gal

                                     8.26
                                     8.26
                                     2.58
                                    0.0916
                                    0.0916
                                    2.86E-5
                                     3,300
                                     3,300
                                    510,000

                                     Turf
                               0.0026 lb ai/gal

                                    0.0107
                                    0.0107
                                    3.35E-6
                                    28,000
                                    28,000
                                    4.3E+6
a. Application Rates are based on proposed uses from the proposed fluopyram labels.
b. Science Advisory Council Policy No. 9.1.
c. 	Baseline Dermal: Long-sleeve shirt, long pants, and no gloves.
  PPE-G Dermal: Baseline plus chemical-resistant gloves.
  Baseline Inhalation: no respirator.
d. Unit Exposures are based on "Occupational Pesticide Handler Unit Exposure Surrogate Reference Table".
e. Daily Exposure (mg/kg/day) = Application Rate (lb ai/A) * Unit Exposure (mg/lb ai) * Area Treated or Amount Applied (acre/day) / 80 kg.
f. MOE = NOAEL (mg/kg/day) / Daily Exposure (mg/kg/day); where dermal NOAEL = 300 mg/kg/day and inhalation NOAEL = 14.5 mg/kg/day.
g. Engineering control unit exposure for applying sprays via aerial equipment = enclosed cockpit.

Seed Treatment Use on Peanut Seeds
Based on the anticipated use patterns and labeling, types of equipment and techniques that can potentially be used, occupational handler exposure is expected from the proposed seed treatment of peanuts.  The quantitative exposure/risk assessment developed for occupational handlers is based on the following scenarios:

 Mixing/loading liquids for commercial seed treatment,
 Bagging treated seed,
 Sewing bags,
 Multiple activities, and
 Planting treated seed.

Occupational seed treatment handlers may experience short- and intermediate-term exposure to fluopyram while performing seed treatment activities in commercial settings.  In addition, occupational secondary handlers may experience short- and intermediate-term exposure while planting fluopyram-treated seeds.  No chemical-specific handler exposure data were submitted in support of this use pattern.  For assessing commercial seed treatment and seed planting activities, unit exposure data were taken from HED ExpoSAC Policy 14: SOPs for Seed Treatment.  The amount of ai handled depends on the application rate (lb ai/lb seed) and the pounds of seed treated in a day (or the pounds of seed that can be planted in a day), all of which vary depending upon the seed type.  Values for the amount of seed treated and planted per day were obtained from HED ExpoSAC Policy 15 and 15.1.

Treating Seed (Primary Handler)
Potential occupational exposure scenarios from the use of fluopyram as a commercial seed treatment include: mixing, loading, applying liquid formulations; bagging treated seed; sewing bags; and multiple activities.  Typically, for large-scale commercial seed treatments, workers perform only those specific individual tasks listed above; however, it is assumed that workers also may perform multiple activities throughout the day.  As a result a "multiple activities" scenario (i.e. where one worker performs all seed treatment tasks such as loading/applying, sewing, bagging, cleaning, calibration, repair, forklift driver, etc.) was addressed.

Planting Treated Seed (Secondary Handler)
Potential occupational exposure scenarios from the use of fluopyram as a commercial seed treatment include planting treated seed (secondary handler).  Planting treated seed consists of the farmer purchasing bags of treated seed, placing the seed in the hopper and applying seed to fields (considered a secondary handler exposure scenario).

Occupational Handler Exposure Data and 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.

Application Rate:
Refer to the proposed use pattern table in Section 4.0 for a detailed description.

Unit Exposures:  It is the policy of HED to use the best available data to assess handler exposure.  Chemical-specific data for assessing exposure during commercial seed treatment and seed planting were not submitted to the Agency in support of these applications.  Unit exposures are from ExpoSAC Policy 14: SOPs for Seed Treatment (May 1, 2003) and are based on data for open mixing/loading/application systems.

Amount Handled:
HED is currently in the process of revising ExpoSAC Policy 15: Amount of Seed Treated or Planted per Day (March 2, 2004) in efforts to update the daily amount of seed treated in commercial seed treatment facilities.  With the increasing demand for hybridized treated seeds, there have been modifications not only in the seed treatment equipment, but in the market shares of new and currently registered pesticide products.  HED understands that due to the high cost of producing hybrid seeds, direct seeding is done in a precision manner which requires lower volumes of seed per acre.  However, this does not provide a direct correlation to the amount of seed which is treated in the commercial seed treatment facilities.

The amount of seed handled (for both primary/treater and secondary/planter handlers) is based on HED ExpoSAC Policy 15, HED ExpoSAC Policy SOP 15.1, and the BEAD memo: "Acres Planted Per Day and Seeding Rates of Crops Grown in the United States."

 The amount of peanut seed treated per day at a commercial facility for short-term exposure durations is 339,500 lb.

 Amount of seed planted per acre (ASP, lb seed/A) for peanut is 228 lb seed/A (105,000 seeds/A x lb peanut seeds/460 peanut seeds).

 The amount of seed planted per acre per day for peanut is 18,260 lb (228 lb seed/A x 80 A/day).

Exposure Duration:
HED classifies exposures from 1 to 30 days as short-term and exposures 30 days to six months as intermediate-term.

Mitigation/Personal Protective Equipment:  Results are presented for PPE (gloves); defined as a single layer of clothing consisting of a long sleeved shirt, long pants, shoes plus socks, protective gloves, and no respirator for all scenarios, except bagging and sewing, for which "baseline" attire was evaluated.

Occupational Handler Non-Cancer Exposure and Risk Estimate Equations
The algorithms used to estimate non-cancer exposure and dose for occupational handlers can be found in Appendix A.

Summary of Occupational Handler Non-Cancer Exposure and Risk Estimates
The results of the occupational handler exposure and risk assessment indicate that short-term dermal and inhalation risk estimates do not exceed HED's LOC (i.e., an MOE < 100 for short-term exposures).  Short-term exposure risk estimates are protective of intermediate-term exposure risk estimates because the throughput (amount of seed treated) of short-term exposure is greater than, or equal to, the throughput of intermediate-term exposure.  The dermal MOEs range from 1,400 to 9,200 for handlers (treaters and planters).  The inhalation MOEs range from 1,700 to 15,000 for handlers (treaters and planters).  Because the short- and intermediate-term dermal and inhalation PODs are the same, and the intermediate-term exposure inputs are less conservative than the short-term exposure inputs for seed treatment, short-term exposure risk estimates are protective of intermediate-term exposure risk estimates.

Table 6.1.2.  Summary of Short- and Intermediate-Term Handler Exposures and Risk Estimates for Fluopyram Seed Treatment of Peanut Seed.[a]
                          Maximum Application Rate[b]
                                 lb ai/lb seed
                            Amount of Seed Treated
                             or Planted Per Day[d]
                                  lb seed/day
                                    Dermal
                               Unit Exposure[c]
                                     mg/lb
                                  Inhalation
                               Unit Exposure[c]
                                     mg/lb
                                Dermal Dose[e]
                                   mg/kg/day
                              Inhalation Dose[f]
                                   mg/kg/day
                                 Dermal MOE[f]
                                   LOC = 100
                               Inhalation MOE[h]
                                   LOC = 100
                               Loader/Applicator
                                   0.001245
                                    339,500
                                     0.023
                                    0.00034
                                    0.1215
                                   0.001796
                                     2,500
                                     8,100
                                     Sewer
                                   0.001245
                                    339,500
                                    0.0062
                                    0.00023
                                    0.03276
                                   0.001215
                                     9,200
                                    12,000
                                    Bagger
                                   0.001245
                                    339,500
                                    0.0091
                                    0.00016
                                    0.04808
                                   0.0008454
                                     6,200
                                    17,000
                              Multiple Activities
                                   0.001245
                                    339,500
                                     0.042
                                    0.0016
                                    0.2219
                                   0.008454
                                     1,400
                                     1,700
                                   Planters
                                   0.001245
                                    18,260
                                     0.25
                                    0.0034
                                    0.07104
                                   0.0009662
                                     4,200
                                    15,000
a	Seed treatment rate calculations are based on the following assumptions:
	Peanut: 460 seeds per lb; 228 lb of seed planted per acre, 80 acres planted per day.
b	Application Rate based on proposed label for fluopyram (Luna Privilege, EPA Reg. No. 264-1078).
c	Unit Exposures from HED Exposure Science Advisory Council Policy 14: Standard Operating Procedures for Seed Treatment (baseline inhalation = no respirator; dermal unit exposure includes PPE with gloves for loading/applicator, multiple activities and planter scenarios).
d	HED default for lb seed treated/planted per day from HED Exposure Science Advisory Council Interim Policy 15.1 and the BEAD memo "Acres Planted Per Day and Seeding Rates of Crops Grown in the United States" (J. Becker, March 2011).
e	Daily Dermal Dose (mg/kg/day) = daily dermal unit exposure (mg/ - lb ai) x application rate (lb ai/lb seed) x amount planted (lb seed/day) / body weight (80 kg adult).
f	Daily Inhalation Dose (mg/kg/day) = daily inhalation unit exposure (mg/ - lb ai) x application rate (lb ai/lb seed) x amount planted (lb seed/day) / body weight (80 kg adult).
g	Dermal MOE = NOAEL (300 mg/kg/day for short- and intermediate-term exposure) / Dermal Dose (mg/kg/day). Level of concern = 100.
h	Inhalation MOE = NOAEL (14.5 mg/kg/day for short- and intermediate-term exposure) / Inhalation Dose (mg/kg/day). Level of concern = 100.

6.2	Occupational Post-application Exposure/Risk Estimates

HED uses the term post-application to describe exposures that occur when individuals are present in an environment that has been previously treated with a pesticide (also referred to as re-entry exposure).  Such exposures may occur when workers enter previously treated areas to perform job functions, including activities related to crop production, such as scouting for pests or harvesting.  Post-application exposure levels vary over time and depend on such things as the type of activity, the nature of the crop or target that was treated, the type of pesticide application, and the chemical's degradation properties.  In addition, the timing of pesticide applications, relative to harvest activities, can greatly reduce the potential for post-application exposure.

6.2.1	Occupational Post-application Inhalation Exposure/Risk Estimates

There are multiple potential sources of post-application inhalation exposure to individuals performing post-application activities in previously treated fields.  These potential sources include volatilization of pesticides and resuspension of dusts and/or particulates that contain pesticides.  The agency sought expert advice and input on issues related to volatilization of pesticides from its Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel (SAP) in December 2009, and received the SAP's final report on March 2, 2010 (http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html).  The agency has evaluated the SAP report and has developed a Volatilization Screening Tool and a subsequent Volatilization Screening Analysis (http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2014-0219).  During Registration Review, the agency will utilize this analysis to determine if data (i.e., flux studies, route-specific inhalation toxicological studies) or further analysis is required for fluopyram.

In addition, the Agency is continuing to evaluate the available post-application inhalation exposure data generated by the Agricultural Reentry Task Force.  Given these two efforts, the Agency will continue to identify the need for and, subsequently, the way to incorporate occupational post-application inhalation exposure into the agency's risk assessments.

Although a quantitative occupational post-application inhalation exposure assessment was not performed, an inhalation exposure assessment was performed for occupational/commercial handlers.  Handler exposure resulting from application of pesticides outdoors is likely to result in higher exposure than post-application exposure.  Therefore, it is expected that these handler inhalation exposure estimates would be protective of most occupational post-application inhalation exposure scenarios.

6.2.2	Occupational Post-application Dermal Exposure/Risk Estimates

Use on Agricultural Field Crops

Occupational Post-application Dermal Exposure Data and Assumptions
In addition to the application rate and body weight values discussed above in the handler exposure section, the following assumptions were made in assessing short- and intermediate-term dermal post-application risks:

Dislodgeable Foliar Residues:
There were no chemical-specific dislodgeable foliar residue data to assess post-application risks to workers while performing tasks related to crops treated with fluopyram.  For agricultural crops, occupational post-application exposures and risks were assessed using HED's default assumptions that 25% of the initial application is available for transfer on day 0 (i.e., 12 hours after application) and that the residue dissipates at a rate of 10% per day.

In accordance with 40 CFR §158, DFR data are required for all occupational (e.g., crop, nursery, greenhouse use sites) or residential (e.g., ornamental and vegetable gardens, pick your own farms, retail tree farms) uses that could result in post-application exposure to foliage.  In the absence of chemical-specific DFR data, EPA uses default values.  The 2012 Standard Operating Procedures for Residential Pesticide Exposure Assessment includes an analysis of a number of DFR studies, which resulted in the selection of a revised default values for the fraction of the application rate available for transfer after a foliar application (FAR).  These values are based on an analysis of 19 DFR studies.  Since that time, the Agricultural Re-entry Task Force has submitted information (MRID 49299201) that corrects an application rate error made in the original submission of "ARF039  -  Determination of Dermal and Inhalation Exposure to Reentry Workers During Chrysanthemum Pinching in a Greenhouse" (EPA MRID 45344501).  As a result, the range of FAR values was revised from 2% - 89% to 2% - 47%.  In the data, a large range of transferability is observed and this variability can potentially be attributable to many factors such as active ingredient; formulation; field conditions in the studies; weather conditions (e.g., humidity); or many other difficult to quantify factors.  Although witnessed across multiple chemicals, this range in FAR values is not expected when considering DFR data for a single chemical.  At this time, the ARTF submission did not alter the selection of 25% as the reasonable, high-end default value.  Because DFR data are not available for fluopyram, EPA is using the default value of 25%.  Although there may be a small degree of uncertainty in the use of the default DFR value for fluopyram (i.e., there is a small chance that the FAR value may exceed the applicable default value), it is likely that the health-protective aspects of EPA's occupational post-application assessment methodology will more than compensate for this potential uncertainty.  For example,  when assessing residential and occupational post-application exposure to gardens and ornamentals, EPA assumes the following:  exposures occur to zero-day (i.e., day of application ) residues every day of the assessed exposure duration (i.e., EPA assumes that no dissipation or degradation occurs, it doesn't rain, etc); individuals perform the same post-application activities performed in the transfer coefficient study day after day (e.g., weeding, harvesting, pruning, etc.); and individuals engage in these post-application activities for a high-end amount of time every day (represented by data reflecting time spent gardening based on survey data).

Given the conservatisms discussed above and the potential compounding nature of these conservatisms, EPA is able to rely upon the calculated exposure estimates with confidence that exposure is not being underestimated.

Since the highest estimated residential and occupational post-application exposures using default DFR values for fluopyram are minimal in comparison to the level of concern (i.e., the calculated MOE is greater than 2 times higher than the level of concern, residential MOE = 2,100 and occupational MOE = 250 compared to the LOC of 100); EPA is waiving the 40 CFR §158 DFR data requirement.  In this instance, it is unlikely that chemical-specific DFR data would be needed to further refine exposure assessments or would add appreciably to our overall understanding of the availability of dislodgeable foliar pesticide residues for fluopyram.

Turf Transferrable Residues
A turf transferrable residue study has not been submitted for fluopyram.  Therefore, HED's standard operating procedures and assumptions were used to determine an estimate of day zero fluopyram residues on treated turf.

In accordance with 40 CFR §158, TTR data are required for all occupational (e.g., sod farms, golf courses, parks, and recreational areas) or residential turf uses that could result in post-application exposure to turf.  In the absence of chemical-specific TTR data, EPA uses default values.  The 2012 Standard Operating Procedures for Residential Pesticide Exposure Assessment includes an analysis of all TTR data, available at the time, which resulted in the selection of revised liquid and granular default values for the fraction of the application rate available for transfer after a turf application (FAR).  These values are based on an analysis of 59 TTR studies performed with the Modified California Roller Method (36 studies using liquids, 11 studies using wettable powders/water dispersible granules, and 12 studies using granules).  The liquid results (N=131) indicate a range of FAR values from 0.0005% to 6.1% and the granular results (N=37) indicate a range of 0.00064% to 0.69%.  In both the liquid and granular data, a large range of transferability is observed and this variability can potentially be attributable to many factors such as active ingredient; formulation; field conditions in the studies; weather conditions (e.g., humidity); or many other difficult to quantify factors.  Although witnessed across multiple chemicals, this range in FAR values is not expected when considering TTR data for a single chemical.  HED selected 1% and 0.2% as high-end default values for liquid and granular products, respectively.  Because TTR data are not available for fluopyram, EPA is using the default value of 1%.  Although there may be a small degree of uncertainty in the use of the default TTR value for fluopyram (i.e., there is a small chance that the FAR value may exceed the applicable default value), it is likely that the health-protective aspects of EPA's residential and occupational post-application turf assessment methodology will more than compensate for this potential uncertainty (i.e., the methodology is likely to overestimate exposure by a factor greater than the factor than the highest measured FAR values exceed the defaults).  For example, when assessing residential post-application turf exposure, EPA assumes the following:  exposures occur to zero-day (i.e., day of application ) residues every day of the assessed exposure duration (i.e., EPA assumes that no dissipation or degradation occurs, it doesn't rain, the grass is not mowed, etc.); individuals perform the same post-application activities performed in the turf transfer coefficient study day after day (e.g., tumbling, playing on turf with toys, etc.); and individuals engage in these post-application activities for a high-end amount of time every day that is represented by data reflecting time children spend outdoors and not specifically engaged in activities on turf, when in actuality children do not spend all of their outdoor time on turf and high-end levels of activity will not occur every day.

Given the conservatisms discussed above and the potential compounding nature of these conservatisms, EPA is able to rely upon the calculated exposure estimates with confidence that exposure is not being underestimated.

Since the estimated residential turf post-application exposure from high contact activities on lawns and the occupational post-application activities on golf course turf using default TTR values for fluopyram are minimal in comparison to the level of concern (i.e., the calculated MOEs are greater than 10 times higher than the level of concern, residential MOE = 1,000 and occupational MOE = 9,000, compared to the LOC of 100); EPA is waiving the 40 CFR §158 TTR data requirement.  In this instance, it is unlikely that chemical-specific TTR data would be needed to further refine exposure assessments or would add appreciably to our general understanding of the availability of turf transferable pesticide residues.

Transfer Coefficients:
HED uses a concept known as the transfer coefficient to numerically represent the post-application exposures one would receive (generally presented as cm[2]/hour).  A transfer coefficient is a measure of the residue transferred from a treated surface to a person who is doing a task or activity in a treated area.  These values are the ratio of an exposure for a given task or activity to the amount of pesticide residue on treated surfaces available for transfer.  HED has developed a series of standard transfer coefficients that are unique for variety of job tasks or activities that are used in lieu of chemical- and scenario-specific data.

No post-application data were submitted in support of this registration action; therefore, dermal exposures during post-application activities were estimated for the various tasks that post-application workers might perform on each crop grouping using dermal transfer coefficients from the Science Advisory Council for Exposure Policy Number 3 (http://www.epa.gov/pesticides/science/exposac_policy3.pdf).  This policy reflects adoption of all ARTF data.  Use of the data in this policy requires compensation to the ARTF under FIFRA.  The transfer coefficients used in this assessment were taken from the Agency's revised Agricultural Transfer Coefficient SOP.  Many of the transfer coefficients in this SOP are based on work of the ARTF.

Workday:
HED assumes an 8 hour workday for post-application workers.

Equations and Calculations:
Daily Dermal Exposure and default DFR calculations are presented below.  The algorithms used to estimate dermal post-application exposure and dose can be found in Appendix A.

The post-application dermal exposure and risk estimates associated with agricultural crops, Christmas trees, and nursery ornamentals are summarized in Table 6.2.2.  For each crop or crop group the post-application activities with the highest transfer coefficient and highest exposure contact are presented.  The occupational post-application MOEs for all crops and crop groups and scenarios shown below do not exceed HED's level of concern (MOEs >=100) on day 0 (i.e., 12 hours following application) with dermal MOEs ranging from 250 to 23,000.  All other scenarios involving lesser contact activities would have higher MOEs and are also not of concern.

Table 6.2.2.  Summary of Occupational Non-Cancer Post-application Risks (Short- and Intermediate-Term) with HED Default Assumptions.
                             Crops or Crop Groups
                               Application Rate
                                 (lb ai/acre)
              Default DFR on 0 days (12 hr) after application[a]
                                   (ug/cm2)
                             Work Activity &
                       Maximum Transfer Coefficient[b]
                                  (cm[2]/hr)
                                 Daily Dose[c]
                                  (mg/kg/day)
                                    MOE[d]
                                  (LOC = 100)
                                   Artichoke
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
              Brassica Leafy Vegetables Head & Stem Subgroup
                                     0.125
                                     0.350
     4200 Hand Harvesting, Hand Weeding, Scouting, Topping, Tying/Training
                                     0.147
                                     2,000
                           Brassica Leafy Vegetables
                                     0.222
                                     0.622
                               4200 Hand Weeding
                                     0.261
                                     1,100
                                Bulb Vegetables
                                     0.222
                                     0.622
                               4200 Hand Weeding
                                     0.261
                                     1,100
                                Canola Subgroup
                                     0.222
                                     0.622
                                 1100 Scouting
                                    0.0684
                                     4,400
                                    Carrot
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                                  Sweet Corn
                                     0.222
                                     0.622
                   17,600 Hand Detasseling, Hand Harvesting
                                     1.09
                                      270
                                 Cereal Grains
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                  Forage, Fodder or Straw from Cereal Grains
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                                    Citrus
                                     0.222
                                     0.622
                             1400 Hand Harvesting
                                    0.0871
                                     3,400
                                    Cotton
                                     0.222
                                     0.622
                                 210 Scouting
                                    0.0131
                                    23,000
                                   Cucurbits
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                              Fruiting Vegetables
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                                     Okra
                                     0.167
                                     0.468
                          1900 Irrigation (Hand Set)
                                    0.0889
                                     3,400
                                    Ginseng
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                               Small Vine Fruits
                                     0.222
                                     0.622
                            10,100 Hand Harvesting
                                     0.628
                                      480
                              Herbs & Spices
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                                     Hops
                                     0.222
                                     0.622
                   19,300 Harvesting, Mechanically Assisted
                                     1.20
                                      250
                               Leafy Vegetables
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                               Legume Vegetables
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                                    Soybean
                                     0.222
                                     0.622
                                 1100 Scouting
                                    0.0684
                                     4,400
                                  Pome Fruit
                                     0.222
                                     0.622
                              3600 Thinning Fruit
                                     0.224
                                     1,300
                     Root, Tuberous & Corm Vegetables
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                                 Small Berries
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                                  Stone Fruit
                                     0.222
                                     0.622
                              3600 Thinning Fruit
                                     0.224
                                     1,300
                              Low Growing Berries
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                                  Sugar Beet
                                     0.222
                                     0.622
                             1100 Hand Harvesting
                                    0.0684
                                     4,400
                                   Sunflower
                                     0.222
                                     0.622
                          1900 Irrigation (Hand Set)
                                     0.118
                                     2,500
                                Christmas Trees
                                     0.223
                                     0.625
                          1900 Irrigation (Hand Set)
                                     0.119
                                     2,500
                              Nursery Ornamentals
                                     0.131
                                     0.367
                          1900 Irrigation (Hand Set)
                                    0.0697
                                     4,300
 Default DFR (ug/cm[2]) = application rate (lb ai/A) x (1- daily dissipation rate) [t] x 4.54E+8 ug/lb x 24.7E-9 A/cm[2] x 25% DFR after initial treatment.
 Crops were assessed using the highest transfer coefficient (TC) available.
 Daily Dose = DFR x TC x (1 mg/1000 ug) x ET (8 hr/day) / body weight (80 kg)
 MOE = NOAEL (300 mg/kg/day) / Daily Dose (mg/kg/day)

For use on cotton, HED has also assessed the post-application dermal exposure and risk estimates for workers involved in harvesting cotton bolls.  Although most of cotton harvesting is done mechanically, there are still some activities, with the potential for exposure, that are associated with the harvesting of cotton.  The anticipated post-application activities and dermal transfer coefficients for these activities are presented in Table 6.2.3.  The recommended transfer coefficients are derived from EPA's Science Advisory Council for Exposure (ExpoSAC) Policy 3 (http://www.epa.gov/pesticides/science/exposac-policy3-march2013.pdf).  No chemical specific data are available for the amount of residue available on the cotton bolls; i.e., dislodgeable boll residue (DBR) data.  Such data are available from a study with the active ingredient tribufos; i.e., MRID 42701601.  Note to RD:  These data may be proprietary, and subject to the data protection provisions of FIFRA, and therefore, may trigger a data compensation issue between registrants.  Since the proposed fluopyram labels include a 30 day pre-harvest interval, the best fit residue data used from MRID 42701601 was chosen from 30 days after harvest and then adjusted for the difference in application rates.  All of the cotton harvesting activities resulted in MOEs ranging from 3,100,000 to 17,000,000, which do not exceed the LOC, and are therefore not of concern; see Table 6.2.4.

Table 6.2.3.  Anticipated Post-Application Activities and Transfer Coefficients for Cotton Harvesters.
                                     Crop
                          Policy Crop Group Category
                                  Crop Height
                                Foliage Density
                             Transfer Coefficients
                                  Activities
                                    Cotton
                        Field / row. crop, low / medium
                                     High
                                      Min
                             900 g cotton boll/hr
                Mechanical Harvesting (Module Builder Operator)

                            2,400 g cotton boll/hr
               Mechanical Harvesting (Picker Operator and Raker)

                            5,050 g cotton boll/hr
                        Mechanical Harvesting (Tramper)

Table 6.2.4.  Occupational Post-application Exposure and Risk Estimates for Cotton Harvesting Activities.
                        Mechanical Harvesting Activity
                                  Appl. Rate
                                   (lb ai/A)
                                      DBR
                                  (ug/g)[1]
                             Transfer Coefficient
                                   (g/hr)[2]
                                Dermal Dose[3]
                                  (mg/kg/day)
                                 Dermal MOE[4]
                            Module Builder Operator
                                     0.222
                                   0.000194
                                      900
                                   0.0000175
                                  17,000,000
                           Picker Operator and Raker

                                     2,400
                                   0.0000466
                                   6,400,000
                                    Tramper

                                    5,0500
                                   0.0000981
                                   3,100,000
1. Cotton Harvesting Dislodgeable Boll Residue (DBR) = (Best fit DBR at 30 days MRID# 42701601 (0.082 ug/50g = 0.00164 ug/g) x Application Rate (0.222 lb ai/A)) / Study Application Rate (1.875 lb ai/A) = 0.000194 ug/g
2. From Non-Foliar Transfer Coefficient Table: http://epa.gov/pesticides/science/exposac-policy-3-march2013.pdf
3. Daily Dose (mg/kg/day) = [DBR x Transfer Coefficient x Conv. Factor (0.001 mg/ug) x 8 hr/day] / Body Weight (80 kg).
4: Short- & Intermediate-term Margin of Exposure (MOE) = Short-term Dermal NOAEL (300 mg/kg/day) / Daily Dose (mg/kg/day).

For use on turf, the exposure/risk assessment for the proposed uses results in a post-application occupational MOE of 9,000, which is above the dermal LOC (MOE >=100); and therefore is not of concern.

Table 6.2.5.  Exposure and Risk Assessment for Occupational Post-Application Activities on Turf.
                               Application Rate
                                   (lb ai/A)
          Dermal Transfer Coefficient (cm[2]/hr) & Activities[1]
                               Post Application
                                    Day (t)
                 Turf Transferable Residue (TTR)[2](ug/cm[2])
                           Daily Dose[3] (mg/kg/day)
                 Short- & Intermediate-Term Dermal MOE[4]
                                     0.446
       6,700 (Maintenance, Transplanting/Planting, & Harvesting Sod)
                                       0
                                     0.05
                                    0.0335
                                     9,000
[1] The transfer coefficient is the arithmetic mean value taken from MRID 46734001.  It should be noted that a previous study on golf course maintenance (MRID 45530101) had been submitted, but had been determined to be unacceptable.  Data from MRID 46734001 are believed to be more appropriate.
[2] TTR derived as follows: 0.446 lb ai/A x 4.54E+8 ug/lb x 2.47E-8 A/cm[2]x 0.01 (fraction of transferable ai) = 0.05 ug/cm[2].
[3] Daily Dose = [TTR (ug/cm[2]) x (0.001 mg/ug) x Dermal Transfer Coefficient x Exposure Time (8 hr)] / [Body Weight (80 kg)] = 0.0335 mg/kg/day.
[4] MOE = LOAEL/Daily Dose.  Short-/Intermediate-Term LOAEL = 300 mg/kg/day.

Restricted Entry Interval
Since post-application risk estimates were not a concern on day 0 (12 hours following application), the REI is based on the acute toxicity of fluopyram technical material.  Fluopyram is classified as Toxicity Category III by the acute dermal route of exposure and Toxicity Category IV for acute eye irritation potential and skin irritation potential.  Under the WPS for Agricultural Pesticides, active ingredients classified as acute toxicity categories III or IV for these routes are assigned a 12-hour REI.  Therefore, the 12-hour REI that appears on the proposed labels is adequate to protect agricultural workers from post-application exposures to fluopyram.

Seed Treatment Use on Peanut Seeds
With regard to seed treatment, the potential for post-application exposures following the planting of fluopyram-treated seeds is unlikely because sustained levels of contact with treated seed after it has been placed in the soil or other planting media would not be expected because no routine cultural practice required for the production of agricultural commodities involves such an activity, as defined in the no/low contact criteria in the Worker Protection Standard (WPS) in 40 CFR §170.112.  Therefore, no quantitative post-application assessment is required for exposure to treated seeds that have already been planted.

Appendix A.  Summary of Occupational and Residential Non-cancer Algorithms

Occupational Handler Non-Cancer Algorithms

Potential daily exposures for occupational handlers are calculated using the following formulas:

E=UE * AR * A * 0.001 mg/ug

where:

E	=	exposure (mg ai/day),
UE	=	unit exposure (ug ai/lb ai),
AR	=	maximum application rate according to proposed label (lb ai A or lb ai/gal), and
A	=	area treated or amount handled (e.g., A/day, gal/day).

The daily doses are calculated using the following formula:

ADD=  E * AFBW

where:

ADD	= 	average daily dose absorbed in a given scenario (mg ai/kg/day),
E	=	exposure (mg ai/day),
AF	=	absorption factor (dermal and/or inhalation), and
BW 	= 	body weight (kg).

Margin of Exposure:  Non-cancer risk estimates for each application handler scenario are calculated using a Margin of Exposure (MOE), which is a ratio of the toxicological endpoint to the daily dose of concern.  The daily dermal and inhalation dose received by occupational handlers are compared to the appropriate POD (i.e., NOAEL) to assess the risk to occupational handlers for each exposure route.  All MOE values are calculated using the following formula:

MOE= PODADD

where:

MOE	=	margin of exposure: value used by HED to represent risk estimates (unitless),
POD	=	point of departure (mg/kg/day), and
ADD	=	average daily dose absorbed in a given scenario (mg ai/kg/day).

Occupational Post-application Algorithms
Exposure resulting from contacting previously treated turf while working is calculated as follows:

	E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day);
TTRt  = turf transferable residue on day "t" (ug/cm[2]);
CF1 = weight unit conversion factor (0.001 mg/ug);
TC  = transfer coefficient (cm[2]/hr); and
ET  = exposure time (hr/day).

and

                      TTRt = AR * F * (1-FD)t * CF2 * CF3

where:

TTRt = turf transferable residue on day t (μg/cm[2]);
AR = application rate (lbs ai/ft[2] or lb ai/acre);
F = fraction of ai as transferable residue following application (unitless);
FD = fraction of residue that dissipates daily (unitless);
t = post-application day on which exposure is being assessed;
CF2 = weight unit conversion factor (4.54 x 10[8] μg/lb); and
CF3 = area unit conversion factor (1.08 x 10[-3] ft[2]/ cm[2] or 2.47 x 10[-8] acre/cm[2]).

Absorbed dose, normalized to body weight, is calculated as:

where:
      D	= dose (mg/kg-day);
      E	= exposure (mg/day);
      AF	= absorption factor (dermal); and
      BW	= body weight (kg).

Residential Post-application Algorithms

Post-application Dermal Exposure Algorithm  -  Physical Activities on Turf
Exposure resulting from contacting previously treated turf while performing physical activities is calculated as shown below.  Residential post-application exposure assessment must include calculation of exposure on the day of application.  Therefore, though an assessment can present exposures for any day "t" following the application, it must include "day 0" exposure.

                           E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day);
TTRt = turf transferable residue on day t (μg/cm[2]);
CF1 = weight unit conversion factor (0.001 mg/μg);
TC = transfer coefficient (cm[2]/hr); and
ET = exposure time (hr/day).

If chemical-specific TTR data are available, then surface residues from the day of application should be used (assume that individuals could be exposed to residues immediately after application). However, if data are not available, then TTRt can be calculated using the following formula:

                      TTRt= AR * F * (1-FD)t * CF2 * CF3

where:

TTRt = turf transferable residue on day t (μg/cm[2]);
AR = application rate (lbs ai/ft[2] or lb ai/acre);
F = fraction of ai as transferable residue following application (unitless);
FD = fraction of residue that dissipates daily (unitless);
t = post-application day on which exposure is being assessed;
CF2 = weight unit conversion factor (4.54 x 10[8] μg/lb); and
CF3 = area unit conversion factor (1.08 x 10[-3] ft[2]/ cm[2] or 2.47 x 10[-8] acre/cm[2]).

Dermal absorbed doses are calculated as:

where:
      D	= dose (mg/kg-day);
      E	= exposure (mg/day);
      AF	= absorption factor (dermal); and
      BW	= body weight (kg).

Table A-1: Turf (Physical Activities) -- Inputs for Residential Post-application Dermal Exposure
                              Algorithm Notation
                                Exposure Factor
                                    (units)
                               Point Estimate(s)
                                      AR
                               Application rate
                    (mass active ingredient per unit area)
                              0.446 or 0.404 lb/A
                                       F
Fraction of AR as TTR following application (if chemical-specific data is unavailable)
                                   L/WP/WDG
                                     0.01

                                   Granules
                                     0.002
                                      FD
     Daily residue dissipation (if chemical-specific data is unavailable)
                                  (fraction)
                                   L/WP/WDG
                                      0.1

                                   Granules
                                      0.1
                                      TC
                        Transfer Coefficient (cm[2]/hr)
                                   L/WP/WDG
                                    Adults
                                    180,000

                          Children 1 < 2 years old
                                    49,000

                                   Granules
                                    Adults
                                    200,000

                          Children 1 < 2 years old
                                    54,000
                                      ET
                                 Exposure Time
                                (hours per day)
                                    Adults
                                      1.5

                          Children 1 < 2 years old
                                      1.5
                                      BW
                                  Body Weight
                                     (kg)
                                    Adults
                                      80

                          Children 1 < 2 years old
                                      11
L/WP/WDG = Liquids/Wettable Powders/Water-dispersible Granules

Post-application Hand-to-Mouth Exposure Algorithm -  Physical Activities on Turf
Exposure from hand-to-mouth activity is calculated as follows (based on the algorithm utilized in the SHEDS-Multimedia model):

  E = [HR * (FM * SAH) * (ET * N_Replen) * (1- (1- SE)[(Freq_HtM/N-Replen)])]

where:

E = exposure (mg/day);
HR = hand residue loading (mg/cm[2]);
FM = fraction hand surface area mouthed / event (fraction/event);
SAH = typical surface area of one hand (cm[2]);
ET = exposure time (hr/day);
N_Replen = number of replenishment intervals per hour (intervals/hour);
SE = saliva extraction factor (i.e., mouthing removal efficiency); and
Freq_HtM = number of hand-to-mouth contacts events per hour (events/hour).

and

where:

HR = hand residue loading (mg/cm[2]);
Faihands	 = fraction ai on hands compared to total surface residue from dermal transfer coefficient study (unitless);
DE = dermal exposure (mg); and
SAH = typical surface area of one hand (cm[2]).

Dose, normalized to body weight, is calculated as:

where:
      D	= dose (mg/kg-day);
      E	= exposure (mg/day); and
      BW	= body weight (kg).
Table A-2: Turf (Physical Activities)  -  Inputs for Residential Post-application Hand-to-Mouth Exposure
                              Algorithm Notation
                                Exposure Factor
                                    (units)
                               Point Estimate(s)
                                   Faihands
        Fraction of ai on hands from dermal transfer coefficient study
                                  (unitless)
                              Liquid formulations
                                     0.06

                             Granular formulations
                                     0.027
                                      DE
                             Dermal exposure (mg)
                                  Calculated
                                      SAH
     Typical surface area of one hand (cm[2]), children 1 < 2 years old
                                      150
                                      AR
                               Application rate
                    (mass active ingredient per unit area)
                                  0.404 lb/A
                                      HR
                   Residue available on the hands (mg/cm[2])
                      Calculated via (DE * Faihands)/SAH
                                      FM
                      Fraction hand surface area mouthed
                               (fraction/event)
                                     0.127
                                   N_Replen
                       Replenishment intervals per hour
                                (intervals/hr)
                                       4
                                      ET
                                Exposure time
                                   (hrs/day)
                                      1.5
                                      SE
                           Saliva extraction factor
                                  (unitless)
                                     0.48
                                   Freq_HtM
                         Hand-to-mouth events per hour
                                  (events/hr)
                                     13.9
                                      BW
                                  Body Weight
                                     (kg)
                          Children 1 < 2 years old
                                      11

Post-application Object-to-Mouth Exposure Algorithm -  Physical Activities on Turf
Exposure from object-to-mouth activity is calculated as follows (based on the algorithm utilized in SHEDS-Multimedia):

	E = [OR* CF1 * SAMO * (ET * N_Replen) * (1- (1- SEO)(Freq_OtM/N_Replen))]

where:

E = exposure (mg/day);
OR = chemical residue loading on the object on day "t" (ug/cm[2]);
CF1 = weight unit conversion factor (0.001 mg/ug);
SAMO = area of the object surface that is mouthed (cm[2]/event);
ET = exposure time (hr/day);
N_Replen = number of replenishment intervals per hour (intervals/hour);
SEO  = saliva extraction factor (i.e., mouthing removal efficiency); and
Freq_OtM  = number of object-to-mouth contact events per hour (events/hour).

and

	OR = AR * FO * CF2 * CF3

where:

OR = chemical residue loading on the object (μg/cm[2]);
AR = application rate (lbs ai/ft[2] or lb ai/acre);
FO = fraction of residue available on the object (unitless);
CF2 = weight unit conversion factor (4.54 x 10[8] ug/lb); and
CF3 = area unit conversion factor (1.08 x 10[-3] ft[2]/cm[2] or 2.47 x 10[-8] acre/cm[2]).

Dose, normalized to body weight, is calculated as:

where:
      D	=	dose (mg/kg-day);
      E	=	exposure (mg/day); and
      BW	=	body weight (kg).

Table A-3: Turf (Physical Activities)  -  Inputs for Residential Post-application Object-to-Mouth Exposure
                              Algorithm Notation
                                Exposure Factor
                                    (units)
                               Point Estimate(s)
                                      AR
                          Application rate (to turf)
                    (mass active ingredient per unit area)
                                  0.404 lb/A
                                      FO
                Fraction of AR as OR following application [1]
                                     0.01
                                     SAMO
                        Surface area of object mouthed
                                 (cm[2]/event)
                                      10
                                   N_Replen
               Replenishment intervals per hour (intervals/hour)
                                       4
                                      SEO
                           Saliva extraction factor
                                  (fraction)
                                     0.48
                                      ET
                                Exposure time
                                (hours per day)
                                      1.5
                                   Freq_OtM
                  Object-to-mouth events per hour (events/hr)
                                      8.8
                                      BW
                               Body Weight (kg)
                          Children 1 < 2 years old
                                      11
1 This SOP assumes that all of the residue on the turf could be transferred to the object (e.g., object residue is equal to turf transferable residue).

Post-application Incidental Soil Ingestion Exposure Algorithm -  Physical Activities on Turf
Exposure from incidental soil ingestion is calculated as follows:

	E = SRt * SIgR * CF1

where:
E = exposure (mg/day);
SRt = soil residue on day "t" (ug/g);
SIgR = ingestion rate of soil (mg/day); and
CF1 = weight unit conversion factor (1 x 10[-6] g/ug).

and

	SRt = AR * FS * (1-FD)t * CF2 * CF3 * CF4

where:

SRt = soil residue on day "t" (ug/g);
AR = application rate (lbs ai/ft[2] or lb ai/acre);
FS = fraction of ai available in uppermost cm of soil (fraction/cm);
FD = fraction of residue that dissipates daily (unitless);
T = post-application day on which exposure is being assessed;
CF2 = weight unit conversion factor (4.54 x 10[8] ug/lb);
CF3 = area unit conversion factor (1.08 x 10[-3] ft[2]/cm2 or 2.47 x 10[-8] acre/cm[2]); and
CF4 = soil volume to weight unit conversion factor (0.67 cm[3]/g soil).

Dose, normalized to body weight, are calculated as:

where:
	D	=	dose (mg/kg-day);
	E	=	exposure (mg/day); and
	BW	=	body weight (kg).

Table A-4: Turf (Physical Activities)  -  Inputs for Residential Post-application Incidental Soil Ingestion Exposure
                              Algorithm Notation
                                Exposure Factor
                                    (units)
                               Point Estimate(s)
                                      AR
                               Application rate
                    (mass active ingredient per unit area)
                                  0.404 lb/A
                                      FS
              Fraction of AR available in uppermost 1 cm of soil
                                  (unitless)
                                       1
                                      FD
                           Daily residue dissipation
                                  (fraction)
                                      0.1
                                     SIgR
                         Soil ingestion rate (mg/day)
                                      50
                                      BW
                               Body weight (kg)
                          Children 1 < 2 years old
                                      11

Post-application Dermal Exposure Algorithm  -  Mowing
Exposure resulting from contacting previously treated turf while mowing is calculated as follows:

	E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day);
TTRt  = turf transferable residue on day "t" (ug/cm[2]);
CF1 = weight unit conversion factor (0.001 mg/ug);
TC  = transfer coefficient (cm[2]/hr); and
ET  = exposure time (hr/day).

and

	TTRt = AR * FAR * (1-FD)t * CF2 * CF3

where:

TTRt  = turf transferable residue on day "t" (ug/cm[2]);
AR = application rate (lbs ai/ft[2] or lb ai/acre);
FAR = fraction of ai retained on turf (unitless);
FD = fraction of residue that dissipates daily (unitless);
t = post-application day on which exposure is being assessed;
CF2= weight unit conversion factor (4.54 x 10[8] ug/lb); and
CF3 = area unit conversion factor (1.08 x 10[-3] ft[2]/cm[2] or 2.47 x 10[-8] acre/cm[2]).

Absorbed dose, normalized to body weight, are calculated as:

where:
      D	= dose (mg/kg-day);
      E	= exposure (mg/day);
      AF	= absorption factor (dermal); and
      BW	= body weight (kg).

Table A-5: Turf (Mowing)  -  Inputs for Residential Post-application Dermal Exposure
                              Algorithm Notation
                                Exposure Factor
                                    (units)
                               Point Estimate(s)
                                      AR
                               Application rate
                     mass active ingredient per unit area
                                  0.446 lb/A
                                      FAR
                  Fraction of AR as TTR following application
                                   L/WP/WDG
                                     0.01

                                   Granules
                                     0.002
                                      FD
                           Daily residue dissipation
                                   L/WP/WDG
                                      0.1

                                   Granules
                                      0.1
                                      TC
                             Transfer Coefficient
                                  (cm[2]/hr)
                                     Adult
                                     5,500

                         Children 11 < 16 years old
                                     4,500
                                      ET
                                Exposure time
                                (hours per day)
                                       1
                                      BW
                                 Body Weight
                                     (kg)
                                    Adults
                                      80

                         Children 11 < 16 years old
                                      57
L/WP/WDG = liquid/wettable powder/water dispersible granule