UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES

June 28, 2006

Memorandum

SUBJECT:	Rotenone: Final Occupational and Residential Exposure
Assessment for the Reregistration Eligibility Decision Document.

FROM:	Charles Smith, Environmental Scientist

		Reregistration Action Branch II/Health Effects Division (7509C)

THROUGH:	Alan Nielsen, Branch Senior Scientist

		Reregistration Action Branch II/Health Effects Division (7509C)

TO:		Charles Smith, Risk Assessor/Environmental Scientist

Elissa Reaves, Ph.D., Risk Assessor/Toxicologist

		Reregistration Action Branch II/Health Effects Division (7509C)

PC Code:	071003

DP Barcode:	D328776

The attached Occupational and Residential Exposure (ORE) assessment was
generated as part of Phase 4 of the public participation process.  The
Health Effects Division’s (HED) Final ORE chapter reflects the
comments received during the Phase 3 public comment period.  It contains
occupational and non-occupational (residential) exposure and risk
estimates for rotenone to support HED’s reregistration eligibility
decision (RED) document.  The assessment was reviewed by HED’s Science
Council for Exposure (ExpoSAC) to ensure compliance with current HED
policy as well as ExpoSAC standard operating procedures (SOPs) for
conducting occupational and residential exposure (ORE) assessments.

This assessment relies in part on data from studies in which adult human
subjects were intentionally exposed to a pesticide.  These studies,
listed below, have been determined to require a review of their ethical
conduct.  The listed studies have either received the appropriate review
or are in the process of being ethically reviewed.

	Clark NWE, Scott RC, Blain PG, Williams FM (1993). Fate of
fluazifop-butyl in rat and 	human 	skin in vitro. Arch Toxicol.
67:44-48.

	The PHED Task Force, 1995.  The Pesticide Handler Exposure Database
(PHED), Version 1.1.  Task Force members Health Canada, U.S.
Environmental Protection Agency, and the National Agricultural Chemicals
Association, released February 1995.

Table of Contents

  TOC \o "1-4" \h \z \u    HYPERLINK \l "_Toc137365742"  Executive
Summary	  PAGEREF _Toc137365742 \h  4

  HYPERLINK \l "_Toc137365743"  1.0	Occupational and Residential
Exposure/Risk Assessment	  PAGEREF _Toc137365743 \h  6

  HYPERLINK \l "_Toc137365744"  1.1	Purpose	  PAGEREF _Toc137365744 \h
6

  HYPERLINK \l "_Toc137365745"  1.2	Criteria for Conducting Exposure
Assessments	  PAGEREF _Toc137365745 \h  6

  HYPERLINK \l "_Toc137365746"  1.3	Summary of Hazard Concerns for
Rotenone	  PAGEREF _Toc137365746 \h  6

  HYPERLINK \l "_Toc137365747"  1.4	Incident Reports	  PAGEREF
_Toc137365747 \h  9

  HYPERLINK \l "_Toc137365748"  1.5	Summary of Physical and Chemical
Properties of Rotenone	  PAGEREF _Toc137365748 \h  10

  HYPERLINK \l "_Toc137365749"  1.5.1	Structure and Nomenclature
PAGEREF _Toc137365749 \h  10

  HYPERLINK \l "_Toc137365750"  1.5.2	Physical and Chemical Properties
PAGEREF _Toc137365750 \h  11

  HYPERLINK \l "_Toc137365751"  1.6	Summary of Use Patterns and
Formulations	  PAGEREF _Toc137365751 \h  12

  HYPERLINK \l "_Toc137365752"  1.6.1	End-Use Products	  PAGEREF
_Toc137365752 \h  12

  HYPERLINK \l "_Toc137365753"  1.6.2	Registered Use Categories and
Sites	  PAGEREF _Toc137365753 \h  12

  HYPERLINK \l "_Toc137365754"  1.6.3	Application Methods and Rates
PAGEREF _Toc137365754 \h  12

  HYPERLINK \l "_Toc137365755"  1.7 Monitoring Data from Rotenone’s
Use as a Piscicide	  PAGEREF _Toc137365755 \h  14

  HYPERLINK \l "_Toc137365756"  2.0	Occupational Exposures and Risks
PAGEREF _Toc137365756 \h  14

  HYPERLINK \l "_Toc137365757"  2.1	Occupational Handler Exposures and
Risks	  PAGEREF _Toc137365757 \h  14

  HYPERLINK \l "_Toc137365758"  2.1.1	Data and Assumptions for Handler
Exposure Scenarios	  PAGEREF _Toc137365758 \h  15

  HYPERLINK \l "_Toc137365759"  <IP_ADDRESS>	Rotenone Handler Exposure
Discussion	  PAGEREF _Toc137365759 \h  15

  HYPERLINK \l "_Toc137365760"  <IP_ADDRESS>	Assumptions for Handler Exposure
Scenarios	  PAGEREF _Toc137365760 \h  17

  HYPERLINK \l "_Toc137365761"  <IP_ADDRESS>	Exposure Data for Handler
Exposure Scenarios	  PAGEREF _Toc137365761 \h  18

  HYPERLINK \l "_Toc137365762"  2.1.2	Rotenone Handler Exposure
Scenarios	  PAGEREF _Toc137365762 \h  20

  HYPERLINK \l "_Toc137365763"  <IP_ADDRESS>	Non-cancer Rotenone Handler
Exposure and Risk     Calculations	  PAGEREF _Toc137365763 \h  21

  HYPERLINK \l "_Toc137365764"  <IP_ADDRESS>	Rotenone Non-cancer Risk Summary
(using PHED data)	  PAGEREF _Toc137365764 \h  22

  HYPERLINK \l "_Toc137365765"  2.1.3	Occupational Risk Characterization
  PAGEREF _Toc137365765 \h  25

  HYPERLINK \l "_Toc137365766"  2.1.4	Summary of Risk Concerns and Data
Gaps for Occupational     Handlers	  PAGEREF _Toc137365766 \h  26

  HYPERLINK \l "_Toc137365767"  <IP_ADDRESS>	Summary of Risk Concerns
PAGEREF _Toc137365767 \h  26

  HYPERLINK \l "_Toc137365768"  <IP_ADDRESS>	Summary of Data Gaps	  PAGEREF
_Toc137365768 \h  26

  HYPERLINK \l "_Toc137365769"  2.1.5	Recommendations For Refining
Occupational Handler Risk Assessment	  PAGEREF _Toc137365769 \h  26

  HYPERLINK \l "_Toc137365770"  2.2	Occupational Postapplication
Exposures and Risks	  PAGEREF _Toc137365770 \h  26

  HYPERLINK \l "_Toc137365771"  3.0	Residential and Other
Non-Occupational Exposures and Risks	  PAGEREF _Toc137365771 \h  26

  HYPERLINK \l "_Toc137365772"  3.1	Residential Handler Exposures and
Risks	  PAGEREF _Toc137365772 \h  26

  HYPERLINK \l "_Toc137365773"  3.2	Residential Postapplication
Exposures and Risks	  PAGEREF _Toc137365773 \h  27

  HYPERLINK \l "_Toc137365774"  3.2.1	Residential Postapplication
Exposure Scenarios	  PAGEREF _Toc137365774 \h  27

  HYPERLINK \l "_Toc137365775"  3.2.2	Data and Assumptions for
Residential Postapplication Exposure Scenarios	  PAGEREF _Toc137365775
\h  28

  HYPERLINK \l "_Toc137365776"  3.2.3	Residential Postapplication
Exposure and Noncancer Risk Estimates	  PAGEREF _Toc137365776 \h  29

  HYPERLINK \l "_Toc137365777"  3.2.4	Summary of Residential
Postapplication Risk Concerns and Data	  PAGEREF _Toc137365777 \h  31

  HYPERLINK \l "_Toc137365779"  3.2.5	Recommendations for Refining
Residential Postapplication Risk Assessments	  PAGEREF _Toc137365779 \h
32

  HYPERLINK \l "_Toc137365780"  4.0	References	  PAGEREF _Toc137365780
\h  32

  HYPERLINK \l "_Toc137365781"  Appendix A: Occupational Exposure
PAGEREF _Toc137365781 \h  33

  HYPERLINK \l "_Toc137365782"  Appendix B: Residential Postapplication
Exposure	  PAGEREF _Toc137365782 \h  42

 Executive Summary tc "Executive Summary"

This document is the occupational and residential/non-occupational risk
assessment for rotenone from its use as a piscicide.  In separate memos
the rotenone technical registrants (Prentiss, Inc. 3/7/06; Foreign
Domestic Chemicals Corporation 3/17/06; and Tifa Limited 4/5/06)
voluntarily cancelled all residential and food crop uses of rotenone
leaving only the piscicidal use pattern.  In this document, which is for
use in EPA's development of the Health Effects Division (HED) chapter of
the rotenone RED Document, EPA presents the results of its review of the
potential human health effects of occupational and
residential/non-occupational exposure to rotenone’s use as a
piscicide.  The cancelled uses of rotenone were previously assessed in
HED’s document entitled Rotenone: Phase 3 Occupational and Residential
Exposure Assessment for the Reregistration Eligibility Decision Document
(January 24, 2006).

	Hazard Concerns:  The toxicological endpoints used to complete the
occupational and residential risk assessments have been selected by the
HED.  Adverse effects were identified at durations of exposure ranging
from short-term (up to 30 days) to intermediate-term durations (> 30
days up to 6 months) and long-term durations (> 6 months).  No cancer
endpoint was identified, therefore, cancer risks were not assessed.

	The short- and intermediate-term (non-cancer) dermal occupational and
residential risk assessment for rotenone is based on a NOAEL of 0.5
mg/kg/day from a reproduction study. A dermal absorption factor of 10
percent was selected.  The short- and intermediate-term (non-cancer)
inhalation occupational and residential risk assessment for rotenone is
based on a NOAEL of 0.5 mg/kg/day, also from a reproduction study.
Long-term exposure to rotenone is not expected for current registered
uses.  HED’s level of concern (LOC) for rotenone dermal and inhalation
exposures is 1000 (i.e., a margin of exposure (MOE) less than 1000
exceeds HED’s level of concern) for occupational and residential
scenarios.  The level of concern is based on 10x for interspecies
extrapolation, 10x for intraspecies extrapolation, and 10x for database
uncertainty.  The dermal and inhalation margins of exposure were
combined for the rotenone risk assessment because the toxicity endpoints
for the dermal and inhalation routes of exposure are based on the same
toxicological effects.  The adverse effects for the dermal and
inhalation endpoints are based on a reproductive study; however, the
effects were noted in both males and females, therefore, the body weight
of an average adult (i.e., 70 kg) was used to estimate dermal and
inhalation exposure.

Use Patterns:  Currently, rotenone is used as a piscicide in two main
areas.  The first use is when rotenone is used in water body (lakes,
ponds, streams, etc.) fish management strategies.  Rotenone is typically
used in this manner when a water body has an unbalanced fish population
or a non-native introduced species threatens native fish populations.
The second use is when rotenone is used in catfish aquaculture.  The use
of rotenone in catfish aquaculture is typically limited to treatment of
the aquaculture ponds in the spring prior to stocking of a new
“crop” of catfish fry.  The purpose of this treatment is to
eliminate undesirable fish species (i.e., shad, blue gills, and mud
cats) that would compete with the catfish fry.

	Piscicidal applications of rotenone are applied using several types of
application equipment – including helicopters, closed system
aspirators, boats with over-surface booms, boats with underwater hoses,
drip bars (in rivers and streams) and backpack sprayers.  Table 5
includes a description of application methods and rates that are
currently being approved for use by the rotenone technical registrants.
These rates and methods apply to use of rotenone in fish management
strategies as well as catfish aquaculture.

	Occupational Handler Risks:  It has been determined that exposure to
pesticide handlers is likely during the occupational use of rotenone in
aquatic 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 rotenone
applications.  For applications to aquatic sites (liquid applications),
combined dermal and inhalation risks to mixers/loaders and aerial
applicators, generally did not exceed HED’s level of concern at some
level of risk mitigation.  For applications to aquatic sites (wettable
powder applications), combined dermal and inhalation risks to
mixers/loaders, generally exceeded HED’s level of concern even at
maximum risk mitigation.  Many of the mixer/loader/applicator scenarios
for aquatic sites (liquid and wettable powder applications) also
exceeded HED’s level of concern even at maximum risk mitigation.  In
particular, HED has serious concerns for any scenario that involves open
mixing/loading of wettable powder formulations of rotenone.  HED also
has concerns for mixing/loading/applying via backpack sprayers for both
liquid and wettable powder formulations.

Occupational Postapplication Risks:   tc "2.2	Occupational
Postapplication Exposures and Risks " \l 2 HED expects minimal
occupational postapplication exposure from the piscicidal use of
rotenone.  As a result, no quantitative assessment was completed for
occupational postapplication exposure.

Residential Handler Risks:  As a result of the March 7, 2006; March 17,
2006; and April 5, 2006 cancellation memos from the rotenone technical
registrants, there are currently no residential uses for rotenone.

	Residential Postapplication Risks:  HED determined there is a potential
for residential postapplication exposure from recreational swimming in
rotenone-treated waters.  Short-term MOEs do not exceed HED’s level of
concern for all adult swimming scenarios (MOEs > 1000).  Short-term MOEs
exceed HED’s level of concern for all toddler swimming scenarios (MOEs
< 1000).  The Environmental Fate and Effects Division (EFED) calculated
the number of days it would take to reach a rotenone concentration that
results in acceptable toddler MOEs (170 ppb of rotenone results in an
MOE of 1000).  This is done by assuming that the dissipation rate for
rotenone in a warm water pond is 1.5 days, as seen in the aquatic
dissipation study.  The time it takes for the rotenone to dissipate to
170 ppb from 200 ppb is 0.35 days and from 250 ppb is 0.89 days.  EFED
assumed first order degradation below 200 ppb and zero order degradation
above.

1.0	Occupational and Residential Exposure/Risk Assessment tc "1.0
Occupational and Residential Exposure/Risk Assessment"

	1.1	Purpose tc "1.1	Purpose " \l 2

This document is the occupational and residential/non-occupational risk
assessment for rotenone from its use as a piscicide.  In separate memos
the rotenone technical registrants (Prentiss, Inc. 3/7/06; Foreign
Domestic Chemicals Corporation 3/17/06; and Tifa Limited 4/5/06)
voluntarily cancelled all residential and food crop uses of rotenone
leaving only the piscicidal use pattern.  In this document, which is for
use in EPA's development of the Health Effects Division (HED) chapter of
the rotenone RED Document, EPA presents the results of its review of the
potential human health effects of occupational and
residential/non-occupational exposure to rotenone’s use as a
piscicide.  The cancelled uses of rotenone were previously assessed in
HED’s document entitled Rotenone: Phase 3 Occupational and Residential
Exposure Assessment for the Reregistration Eligibility Decision Document
(January 24, 2006).

	1.2	Criteria for Conducting Exposure Assessments  tc "1.2	Criteria for
Conducting Exposure Assessments " \l 2

	An occupational and/or residential exposure assessment is required for
an active ingredient if (1) certain toxicological criteria are triggered
and (2) there is a potential for exposure to handlers (mixers, loaders,
applicators) during use or to persons entering treated sites or exposed
to vapors after application is complete.  Toxicological endpoints were
selected for short- and intermediate-term dermal, inhalation, and
incidental oral exposures to rotenone.  There is a significant potential
for exposure in a variety of piscicide application settings as well as
to residential individuals entering the treated site (i.e., swimming).
Therefore, risk assessments are required for occupational handlers as
well as for residential postapplication exposures that can occur as a
result of rotenone use.

	1.3	Summary of Hazard Concerns for Rotenone  tc "1.3    	Summary of
Hazard Concerns for MGK-264 " \l 2

	The toxicological endpoints used to complete the occupational and
residential risk assessments have been selected by the HED and are
summarized below.  Adverse effects were identified at durations of
exposure ranging from short-term (up to 30 days) to intermediate-term
durations (> 30 days up to 6 months) and long-term durations (> 6 months
up to 1 year).  No cancer endpoint was identified; therefore cancer
risks are not assessed.

	Rotenone is a piscicide where the use patterns typically result in
short-term exposure durations.  Intermediate- and long-term exposures
are not expected for rotenone piscicide uses.  The rotenone hazard
database was evaluated and endpoints were selected to address each of
the durations of exposure.  Rotenone exposures are expected to occur to
both occupational and residential individuals.

	Dermal Route (non-cancer)

	The short- and intermediate-term (non-cancer) dermal risk assessment
for rotenone is based on a NOAEL of 0.5 mg/kg/day from a reproduction
study. The NOAEL was based on decrease in body weight for both males and
females. Long-term exposures to rotenone (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 dermal absorption study for
fluazifop-butyl.  Fluazifop-butyl is a structurally related analog to
rotenone based on molecular weight.  A dermal absorption study is
available in humans for fluazifop-butyl, which indicates a dermal
absorption factor of 9% (HIARC report 2004 fluazifop-butyl, Clark et
al., 1993).  Based on a structure activity search and dermal information
in the human, the estimated dermal absorption of rotenone in humans is
likely 10%.

	Inhalation Route (non-cancer)

	The short- and intermediate-term (non-cancer) inhalation risk
assessment for rotenone is based on a NOAEL of 0.5 mg/kg/day, which is
also based on the reproduction study.  Long-term exposure to rotenone
(i.e., greater than 6 months) is not expected for current registered
uses.

	Non-cancer Level of Concern (LOC)

	HED’s level of concern (LOC) for rotenone dermal and inhalation
exposures is 1000 (i.e., a margin of exposure (MOE) less than 1000
exceeds HED’s level of concern) for occupational and residential
scenarios.  The level of concern is based on 10x for interspecies
extrapolation, 10x for intraspecies extrapolation, and 10x for toxicity
database uncertainty.

	Aggregation

	The dermal and inhalation margins of exposure were combined for the
rotenone risk assessment because the toxicity endpoints for the dermal
and inhalation routes of exposure are based on the same toxicological
effects.

	Cancer

No cancer endpoint was identified.

	Acute Toxicity

	Rotenone is classified as category I for acute oral and inhalation and
as category IV for acute dermal toxicity.  It is classified as category
IV for eye irritation potential and for skin irritation potential.
Results were negative for dermal sensitization in guinea pigs.

	Body Weight

	The adverse effects for the dermal and inhalation endpoint are based on
a reproductive study; however, the effects were seen in both males and
females.  Therefore, the body weight of an average adult (i.e., 70 kg)
was used to estimate dermal and inhalation exposure.

Table 1:  Acute Toxicity Data on Rotenone

Guideline No.	Study Type	MRID(s)	Results	Toxicity Category

870.1100

81-1	Acute oral [rat]	00145496	LD50 = 102 mg/kg (M)

LD50 = 39.5 mg/kg (F)	I

870.1200

81-2	Acute dermal [rabbit]	43907501	LD50 = >5000 mg/kg	IV

870.1300

81-3	Acute inhalation [rat]	43882601	LC50 = 0.0212 mg/L combined

LC50 = 0.0235 mg/L (M)

LC50 = 0.0194 mg/L (F)	I

870.2400

81-4	Acute eye irritation [rabbit]	43907503	minimal, in unwashed eyes
conjunctival irritation, PIS 3.3 at 1 hr, cleared less than 24 hrs.	IV

870.2500.

81-5	Acute dermal irritation [rabbit]	43907504	PIS 0.08 at 1 hour which
decreased to 0 at 72 hours	IV

870.2600

81-6	Skin sensitization [guinea pig]	43817903	Not a dermal sensitizer	NA

Table 2.  Summary of Toxicological Doses and Endpoints for Rotenone for
Use in Human Risk Assessments

Exposure

Scenario	Dose Used in Risk Assessment, UF	Special FQPA SF* and Level of
Concern for Risk Assessment	Study and Toxicological Effects

Incidental Oral Short- and Intermediate-Term

(1 - 30 days)	NOAEL = 0.5 mg/kg/day	Residential LOC for MOE = 1000
Reproductive toxicity - rat

LOAEL = 3.0 mg/kg/day based on decreased pup body weight and body weight
gain

Dermal

All Durations

(1 - 30 days)	NOAEL = 0.5 mg/kg/day

10% dermal absorption factor	Residential and Occupational LOC for MOE =
1000	Reproductive toxicity - rat

LOAEL = 3.0 mg/kg/day based on decreased pup body weight and body weight
gain

Inhalation

Short- and Intermediate-Term

(1 - 30 days)	NOAEL = 0.5 mg/kg/day

100% absorption factor	Residential and Occupational LOC for MOE = 1000
Reproductive toxicity - rat

LOAEL = 3.0 mg/kg/day based on decreased pup body weight and body weight
gain

Inhalation

Long-Term

(> 6 months)	NOAEL = 0.375 mg/kg/day	Residential and Occupational LOC
for MOE = 1000	Chronic/oncogenicity - rat

LOAEL = 1.88 mg/kg/day based on decreased body weight and food
consumption in both males and females

Cancer (oral, dermal, inhalation)	Classification: no evidence of
carcinogenicity

	1.4	Incident Reports  tc "1.4	Incident Reports " \l 2

	The following databases were consulted for the poisoning incident data
on the active ingredient rotenone (071003):

1) OPP Incident Data System (IDS) - reports of incidents from various
sources, including registrants, other federal and state health and
environmental agencies and individual consumers, submitted to OPP since
1992.  Reports submitted to the Incident Data System represent anecdotal
reports or allegations only, unless otherwise stated.  Typically no
conclusions can be drawn implicating the pesticide as a cause of any of
the reported health effects.  Nevertheless, sometimes with enough cases
and/or documentation risk mitigation measures may be suggested.

2) Poison Control Centers - as the result of a data purchase by EPA, OPP
received Poison Control Center data covering the years 1993 through 1998
for all pesticides.  Most of the national Poison Control Centers (PCCs)
participate in a national data collection system, the Toxic Exposure
Surveillance System which obtains data from about 65-70 centers at
hospitals and universities.  PCCs provide telephone consultation for
individuals and health care providers on suspected poisonings, involving
drugs, household products, pesticides, etc.

3) California Department of Pesticide Regulation - California has
collected uniform data on suspected pesticide poisonings since 1982.
Physicians are required, by statute, to report to their local health
officer all occurrences of illness suspected of being related to
exposure to pesticides.  The majority of the incidents involve workers.
Information on exposure (worker activity), type of illness (systemic,
eye, skin, eye/skin and respiratory), likelihood of a causal
relationship, and number of days off work and in the hospital are
provided.

4) National Pesticide Information Center (NPIC) - NPIC is a toll-free
information service supported by OPP.  A ranking of the top 200 active
ingredients for which telephone calls were received during calendar
years 1984-1991, inclusive has been prepared.  The total number of calls
was tabulated for the categories human incidents, animal incidents,
calls for information, and others.

5) National Institute of Occupational Safety and Health’s Sentinel
Event Notification System for Occupational Risks (NIOSH SENSOR) performs
standardized surveillance in seven states from 1998 through 2002.
States included in this reporting system are Arizona, California,
Florida, Louisiana, Michigan, New York, Oregon, Texas, and Washington.
Reporting is very uneven from state to state because of the varying
cooperation from different sources of reporting (e.g., workers
compensation, Poison Control Centers, emergency departments and
hospitals, enforcement investigations, private physicians, etc.).
Therefore, these reports should not be characterized as estimating the
total magnitude of poisoning.  The focus is on occupationlly-related
cases not residential or other non-occupational exposures.  However, the
information collected on each case is standardized and categorized
according to the certainty of the information collected and the severity
of the case.

A c  SEQ CHAPTER \h \r 1 omparison (expressed in percent of cases,)
between rotenone and all other pesticides reported to Poison Control
Centers between 1993-2003 with either symptomatic outcome (SYM),
moderate or more severe outcome (MOD), life-threatening or fatal outcome
(LIFE-TH), seen in a health care facility (HCF), hospitalized (HOSP), or
seen in an intensive care unit (ICU), showed that for occupational
exposure cases, as well as for non-occupational cases involving adults,
older children, and children under six years old, rotenone had a similar
or higher percentage of poisoning incidents reported than other
pesticides (Hawkins 2005).

  SEQ CHAPTER \h \r 1 In general, the most common symptom reported was
eye irritation, which was four times more prevalent than any other
symptom.  Other symptoms reported included dermal irritation, throat
irritation, nausea, and cough/choke.  This supports the finding that
rotenone’s main effect is due to its irritant properties.  Few
neurological symptoms, other than headache and dizziness, were reported,
though there were a few reports of peripheral neuropathy, numbness, or
tremor.    SEQ CHAPTER \h \r 1 Neither fatalities nor systemic
poisonings have been reported in relation to "ordinary use.”  There
were reports of fatalities from intentional ingestion of rotenone.

 	1.5	Summary of Physical and Chemical Properties of Rotenone  tc "1.5
Summary of Physical and Chemical Properties of MGK-264 " \l 2

		1.5.1	Structure and Nomenclature tc "2.2	Structure and Nomenclature "
\l 2

Empirical formula	C23 H22 O6

Common name	Rotenone

IUPAC name
(2R,6aS,12aS)-1,2,6,6a,12,12a-hexahydro-2-isopropenyl-8,9-dimethoxychrom
eno[3,4-b]furo[2,3-h]chromen-6-one.

CAS Registry Number	83-79-4

Chemical Class	Rotenoid

Known Impurities of Concern	Extraction compounds such as
trichloroethylene & toluene in unspecified amounts

		1.5.2	Physical and Chemical Properties tc "2.3	Physical and Chemical
Properties " \l 2

Table 4.    SEQ CHAPTER \h \r 1 The Physicochemical Properties of
Rotenone

OPPTS Guideline Numbers	Master Record Identification [MRID]	Status1
Results or *Deficiency

830.1550 Product Identity and Composition     	441115-01	A

	830.1600 Description of Materials Used to Produce the Product	441115-01
A

	830.1620 Description of Production Process	441115-01	A

	830.1650 Description of Formulation Process	446528-01	A

	830.1670 Discussion of Formation of Impurities	441115-01	A

	830.1700 Preliminary Analysis	441386-01	A

	830.1750 Certified Limits	443953-01	A

	830.1800 Enforcement Analytical Method	447265-01,  445108-01

HPLC/UV	A

	830.1900 Submittal of Samples 	EPA Repository, Ft. Meade, MD.	A	44.2%
--- TIFA, Inc.

 Expiration Date: 02/22/2006

830.6302 Color	438180-02	A	Tan

830.6303 Physical State	438180-02	A	Powder

830.6304 Odor	438180-02	A	Wet chalk

830.6313  Stability to normal and elevated temperatures, metals and
metal ions	441237-05	A	Temp(s) = No change was observed; the loss was
less than 5%.  Metals = No change was observed, the loss was about 5%.

830.6314 Oxidation /Reduction Chemical Incompatibility	438180-02	A	None

830.6315 Flammability	438180-02	A	Not Applicable

830.6316 Explodability	438180-02	A	Not Applicable

830.6317 Storage Stability	441308-01	A	Container / Stability   /
Duration / Temp.

Poly bag  /   Stable       /   1.0 yr.    /   22(C

Poly bag /  Loss (5%  /    0.5 yr.  /    40(C

830.6319 Miscibility	441308-01	A	Not Applicable

830.6320 Corrosion Characteristics	441308-01	A	None

830.6321 Dielectric Breakdown Voltage	441308-01	A	Not Applicable

830.7000 pH	441308-01	A	Not Applicable

830.7050  UV/VIS absorption 	(MRID to be assigned)	A	Absorptivity at
235nm & 292 nm

830.7100 Viscosity	441308-01	A	Not Applicable

830.7200 Melting Point/Melting Range	 ADVANCE \d4 441237-02	A	160 -163
oC

830.7220 Boiling Point/Boiling Point Range	    ------         	------
PAI is solid at room temperature.

830.7300 Density/Relative Density/Bulk Density	438180-02	A	Fluffy
0.2400 g/cm3; 14.70 lb/cu. ft

Compacted   0.4500g/cm3; 28.10 lb/cu. ft

830.7370 Dissociation  Constant	447181-01	A	PAI no dissociation constant
at pH 2-12.  (OECD Method No. 112)

830.7550 Partition coefficient (n-octanol /water) shake flask method
441237-04	A	K o/w       Log P = 4.16

830.7560 Partition coefficient (n-octanol /water) generator column
method	------	------	See Guideline 830.7550

830.7570 Partition coefficient (n-octanol /water) estimation by liquid
chromatography	-------	-------	See Guideline 830.7550

830.7840 Water Solubility: Column Elution Method; Shake Flask Method
441237-03	A	Solvent = Water;  Temperature = 20 ºC;

Avg. Solubility = 0.142 mg/ml

830.7860 Water solubility, generator column method	--------	--------	See
Guideline 830.7840

830.7950 Vapor pressure	446529-01	A	Not Applicable

1 A = Acceptable; U = Unacceptable (See *Deficiency)

	1.6	Summary of Use Patterns and Formulations  tc "1.6	Summary of Use
Patterns and Formulations " \l 2

		1.6.1	End-Use Products  tc "1.6.1	End-Use Products " \l 3

	Rotenone is a widely used piscicide in the United States.  Rotenone
piscicide products are formulated as liquids and as wettable powders.

		1.6.2	Registered Use Categories and Sites  tc "1.6.2	Registered Use
Categories and Sites " \l 3

Rotenone is currently registered for use in a variety of occupational
and residential scenarios, however, in memos dated (March 7, 2006; March
17, 2006; and April 5, 2006) the technical registrants (Prentiss, Inc.;
Foreign Domestic Chemicals Corporation; and Tifa Limited) for rotenone
voluntarily cancelled all uses of rotenone except for the piscicidal
uses.  This assessment deals with occupational populations that could be
potentially exposed while performing rotenone applications as well as
residential populations that may be exposed to rotenone during
postapplication time periods (i.e., swimming).  The cancelled uses of
rotenone were previously assessed in HED’s document entitled Rotenone:
Phase 3 Occupational and Residential Exposure Assessment for the
Reregistration Eligibility Decision Document (January 24, 2006).

Currently, rotenone is used as a piscicide in two main areas.  The first
use is when rotenone is used in water body (lakes, ponds, streams, etc.)
fish management strategies.  Rotenone is typically used in this manner
when a water body has an unbalanced fish population or a non-native
introduced species threatens native fish populations.  The second use is
when rotenone is used in catfish aquaculture.  The use of rotenone in
catfish aquaculture is typically limited to treatment of the aquaculture
ponds in the spring prior to stocking of a new “crop” of catfish
fry.  The purpose of this treatment is to eliminate undesirable fish
species (i.e., shad, blue gills, and mud cats) that would compete with
the catfish fry.

1.6.3	Application Methods and Rates tc "1.6.3	Application Methods " \l 3

	Piscicidal applications of rotenone are applied using several types of
application equipment – including helicopters, closed system
aspirators, boats with over-surface booms, boats with underwater hoses,
drip bars (in rivers and streams) and backpack sprayers.  Table 5
includes a description of application methods and rates that are
currently being approved for use by the rotenone technical registrants.
These rates and methods apply to use of rotenone in fish management
strategies as well as catfish aquaculture.

	The area treated per day throughout this assessment is described as
acre-foot/day (A-ft/day) for lake, pond, and reservoir applications and
as cubic feet/day (ft3/day) for stream and river applications.
Acre-foot/day numbers are calculated by taking the number of surface
acres treated per day and multiplying by the depth of the lake being
treated, which was assumed to by HED to be 5 feet.  For example, with
helicopter applications, HED assumed the high end of the treatment range
would be 10 surface acres and when this number is multiplied by the
depth of 5 feet, a value of 50 A-ft/day is acquired.  Similar
calculations were performed for river and stream applications but for
these applications HED used the length of stream treated, the depth of
stream, and the width of stream.  For example, with backpack
applications, HED estimated that the length of stream that could be
treated in one day is 10,560 ft (2 miles) and when this number is
multiplied by the 2 foot depth of the stream and the 10 foot width of
the stream, a value of 211,200 ft3 is acquired.

Table 5. Summary of Maximum Application Rates for Registered Rotenone
Aquatic Uses

Use Site	Target of Application	Maximum Application Rate 1	Formulation
Application Equipment	Area Treated or Amount Handled Per Day 2

Lakes, ponds, reservoirs	Fish	0.68 lb ai/A-ft

&

0.54 lb ai/A-ft	Liquid	Helicopter	50 A-ft/day

&

25 A-ft/day

Boat: over-surface boom	500 A-ft/day

&

250 A-ft/day

Boat: underwater hoses	500 A-ft/day

&

250 A-ft/day

Backpack	10 A-ft/day

Closed system aspirator	500 A-ft/day

&

250 A-ft/day

0.68 lb ai/A-ft

&

0.54 lb ai/A-ft	WP	Boat: over-surface boom	500 A-ft/day

&

250 A-ft/day

Boat: underwater hoses	500 A-ft/day

&

250 A-ft/day

Backpack	10 A-ft/day

Closed system aspirator	500 A-ft/day

&

250 A-ft/day

Moving water (streams)

0.000016 lb ai/ft3

&

0.000013 lb ai/ft3	Liquid	Backpack	211,200 ft3

Drip bar

	0.000016 lb ai/ft3

&

0.000013 lb ai/ft3	WP	Backpack

	Drip bar

	Seeps or Springs

	WP	Volumetric container

(powder/sand/gelatin paste)

	1	Maximum of two applications of rotenone per year.

2	Area treated per day values for all application methods except boats
are based on personal contact with Brian Finlayson, California
Department of Fish and Game (1/9/06).  Area treated per day values for
boat application methods are based on HED professional judgement.1.7
Monitoring Data from Rotenone’s Use as a Piscicide

Monitoring Data.  There are limited monitoring data that explains how
rotenone acts in the environment (i.e., water).  An aquatic field
dissipation study, and data collected in association with a piscicidal
application to Lake Davis in California are informative but not useful
for quantitative risk assessment purposes (R. David Jones 2006).

Rotenone can persist in water bodies for at least several weeks when
used as a piscicide.  In California’s Lake Davis, rotenone was shown
to have a half-life of 10.3 days.  Concentrations initially were 45
μg/L-1 and had decreased to about 7 μg/L-1 on a mean basis across the
Lake after 26 days (see review in R. David Jones 2006).  Conversely,
application to a warm water pond in an aquatic field dissipation study
showed rotenone to have a half-life of 1.5 days.  The difference in
dissipation rates was likely due to differences in temperature.

2.0	Occupational Exposures and Risks tc "2.0	Occupational Exposures and
Risks"

	There is a potential for exposure to rotenone in occupational scenarios
from handling rotenone products during the application process (i.e.,
mixer/loaders, applicators, and mixer/loader/applicators).  As a result,
risk assessments have been completed for a number of occupational
handler scenarios.

2.1	Occupational Handler Exposures and Risks  tc "2.1	Occupational
Handler Exposures and Risks " \l 2

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

	HED uses exposure scenarios to describe the various types of handler
exposures that may occur for a specific active ingredient. The use of
scenarios as a basis for exposure assessment is very common as described
in the U.S. EPA Guidelines for Exposure Assessment (U.S. EPA; Federal
Register Volume 57, Number 104; May 29, 1992).  Information from the
current labels, use and usage information, toxicology data, and exposure
data were all key components in the development of the exposure
scenarios.  HED has developed a series of general descriptions for tasks
that are associated with pesticide applications.  Tasks associated with
occupational pesticide handlers are categorized using one of the
following terms:

Mixers and/or Loaders: These individuals perform tasks in preparation
for an application.  For example, prior to application, mixer/loaders
would mix the rotenone and load it into the holding tank of a helicopter
or boat.

Applicators: These individuals operate application equipment during the
release of a pesticide product into the environment.  These individuals
can make applications using equipment such as helicopters or boats.

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 rotenone 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 rotenone exposures may occur over a few
days for many use-patterns and that intermittent exposure over several
weeks also may occur.  Long-term handler exposures are not expected to
occur for rotenone.  Note that the same toxicological endpoint of
concern (from a reproductive study) was selected for short-,
intermediate-, and long-term dermal rotenone exposures, therefore, the
risk results for all dermal durations of exposure are numerically
identical.  The same toxicological endpoint of concern (from the same
reproductive study) has been selected for short- and intermediate-term
inhalation exposures to rotenone, therefore, the risk results for these
inhalation durations of exposure also are numerically identical.

	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, water-soluble 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 and Assumptions for Handler Exposure Scenarios  tc "2.1.1
Data and Assumptions For Handler Exposure Scenarios " \l 3

<IP_ADDRESS>	Rotenone Handler Exposure Discussion tc "<IP_ADDRESS>	Assumptions for
Handler Exposure Scenarios " \l 4

As described above in section 1.6.3, piscicidal applications of rotenone
are applied using several types of application equipment – including
helicopters, closed system aspirators, boats with over-surface booms,
boats with underwater hoses (weighted or unweighted), drip bars (in
rivers and streams) and backpack sprayers.  Many of these application
methods are specific to rotenone (and other aquatic pesticides) and have
intricacies that many of the agricultural pesticide applications do not.
 HED has attempted to learn the intricacies within each of these
application methods through discussions with the rotenone technical
registrants as well as other interested stakeholders and by utilizing
the document entitled, ROTENONE USE IN FISHERIES MANAGEMENT:
Administrative and Technical Guidelines Manual which was produced by the
American Fisheries Society in April of 2000.  The application methods
for rotenone are described in further detail below.

Helicopters: Treatments made via helicopters use only liquid
formulations of rotenone.  Helicopter applications are made only to
lakes, ponds, and reservoirs (i.e., standing bodies of water).
Typically, helicopter applications of rotenone occur only to small
acreages due to the high cost of the applications.  The main use of
helicopters in the application of rotenone is when a water body needs to
be treated, but is difficult to access, such as a high mountain lake.

For helicopter treatments, large droplets or streams of dilute rotenone
are preferred over mist or small droplet applications. Mist or small
droplet applications may result in drift that reduces treatment efficacy
and increases the risk of detrimental effects on nontarget organisms.

Boats with Over-surface Booms: Treatments made via boats with
over-surface booms may use liquid or wettable powder formulations of
rotenone. Typically, this type of application is made to larger water
bodies such as lakes, ponds, reservoirs, and larger rivers that are
easily accessible.

Boat-boom applications (with liquid formulations) lend themselves to
closed system applications that result in less handler exposure.  A
closed system boat-boom application (liquid formulation) includes a hose
that is attached to the rotenone barrel, an intake hose that can draw
water from the lake, and a pump connected to a gasoline engine that
draws and mixes the lake water and rotenone.  This pump is connected to
a discharge hose which dispenses the diluted rotenone into the lake via
the spray boom.  A similar closed system can be setup for
boat-boom-applications using wettable powder formulations.  However,
this type of application requires the use of an aspirator which sucks
the powdered rotenone out of its container (typically a barrel or bag).
The rest of the system is similar to when a liquid formulation is
utilized.

Boats with Underwater Hoses (Weighted and Unweighted: Treatments made
via boats with underwater hoses may use liquid or wettable powder
formulations of rotenone.  Typically, this type of application is made
to larger bodies of water, such as lakes, ponds, and reservoirs (i.e.,
standing bodies of water that are easily accessible.

There are two main methods that are used with underwater hose
applications.  With the first method, the underwater hose is placed just
under the boat and with the second method weighted hoses are used to
reach deep areas (below the thermocline) of lakes.  These applications
lend themselves to the same closed-system type of application setup that
is used for boat-boom applications.  However, many applications
performed using boat-underwater hose systems use gravity feed systems
which are open systems.

Closed System Aspirators (Direct Metering): Treatments made via closed
system aspirators (direct metering) may use liquid or wettable powder
formulations of rotenone.  This application method is similar to the
closed systems that can be setup on boats and it can be used to make
applications to a variety of water bodies.

A closed system aspirator application (liquid formulation) includes a
hose that is attached to the rotenone barrel, an intake hose that draws
in water from the lake, and a pump connected to a gasoline engine that
draws and mixes the lake water and rotenone.  This pump is connected to
a discharge hose that dispenses the diluted rotenone into the lake.  A
similar closed system can be setup for applications using wettable
powder formulations.  However, this type of application requires the use
of an aspirator that sucks the powdered rotenone out of its container
(typically a barrel or bag).  The rest of the system is similar to when
a liquid formulation is utilized.

Drip Bars: Treatments made via drip bars may use liquid or wettable
powder formulations of rotenone.  This application method is typically
used in streams and rivers.  Drip bars are also used to enhance rotenone
applications in moving water when barriers, beaver dams, seeps, springs,
and/or tributaries are identified in the treatment area.  Barriers such
as diversion structures and beaver dams should be removed, if possible,
before the treatment.  However, if they cannot be removed, drip stations
may be setup below such barriers to boost rotenone concentrations.  Drip
bar applications consist of a series of cans, barrels, or other
containers that hold the diluted rotenone product and dispense it into
the stream or river.

Backpack Sprayers:  Treatments made via backpack sprayers may use liquid
or wettable powder formulations of rotenone.  This application method is
typically used in backwater areas of streams and rivers as well as in
the shallows of lakes and ponds where boats are unable to travel.
Backpack sprayer applications consist of an individual carrying a
tankful of diluted rotenone on their back and spraying this dilution
into the water through a wand.

Powder/Sand/Gelatin Pastes: Treatments made via powder/sand/gelatin
pastes use wettable powder formulations of rotenone.  This type of
application method is typically applied only to seeps and springs.  When
this powder/sand/gelatin paste is mixed, it is either made in a lab
under a fume hood or mixed by an individual wearing a respirator.

<IP_ADDRESS>	Assumptions for Handler Exposure Scenarios  tc "<IP_ADDRESS>
Assumptions for Handler Exposure Scenarios " \l 4

	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:

HED has patterned this risk assessment on a series of likely
representative scenarios that are believed by HED to represent the vast
majority of rotenone uses.

Occupational handler exposure estimates were based on surrogate data
from the Pesticide Handlers Exposure Database (PHED) because no
chemical- or application- equipment specific exposure data was
available.  PHED consists of data that was produced for the purposes of
assessing land-based agricultural and residential application scenarios.
 In the case of rotenone, applications occur over and to water bodies.
There are clearly limitations and uncertainties regarding the use of
PHED to assess rotenone occupational handler exposure because of the
distinct differences in application sites (land vs. water), however, HED
can not currently define the extent of these limitations and
uncertainties.  Specific examples of surrogate scenarios used in this
assessment are explained below:

To assess exposure from applying sprays via helicopter, the exposure
scenario for applying via fixed wing aircraft was used.

To assess exposure from applying sprays via boat-mounted spray
equipment, the exposure scenario for applying via ground boom equipment
was used.

To assess exposure from mixing/loading/applying liquid formulations via
closed system aspirators, the exposure scenario for liquid formulation
closed system mixing/loading equipment was used.

To assess exposure from mixing/loading/applying wettable powder
formulations via closed system aspirators, the exposure scenario for
wettable powder formulation closed system mixing/loading equipment was
used.

To assess exposure from mixing/loading/applying liquid formulations via
drip bars (in moving waters), the exposure scenario for liquid
formulation mixing/loading equipment was used.

To assess exposure from mixing/loading/applying wettable powder
formulations via drip bars (in moving waters), the exposure scenario for
wettable powder formulation mixing/loading equipment was used.

The toxicological endpoint of concern for dermal and inhalation risks is
from a reproductive study; however, the effects were seen in both males
and females, therefore, the average body weight of an adult handler
(i.e., 70 kg) is used to complete the dermal noncancer risk assessment.

Generic protection factors (PFs) were used to calculate exposures when
data were not available.  For example, an 80 percent protection factor
was assumed for the use of a respirator equipped with a dust/mist
filter.

For non-cancer assessments, HED assumes the maximum application rates
allowed by labels in its risk assessments (see Table 5).

The average occupational workday is assumed to be 8 hours.

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, miles, or feet per day).  The
values for all application methods except boats presented in this
assessment were provided via personal contact with Brian Finlayson,
California Department of Fish and Game (1/9/06).  Area treated per day
values for boat application methods are based on HED professional
judgment.

<IP_ADDRESS>	Exposure Data for Handler Exposure Scenarios  tc "<IP_ADDRESS>
Exposure Data for Handler Exposure Scenarios " \l 4

	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).

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

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

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

	The unit exposures calculated by PHED generally range from the
geometric mean to the median of the selected data set.  To add
consistency and quality control to the values produced from this system,
the PHED Task Force has evaluated all data within the system and has
developed a set of grading criteria to characterize the quality of the
original study data.  The assessment of data quality is based on the
number of observations and the available quality control data. These
evaluation criteria and the caveats specific to each exposure scenario
are summarized in Appendix A, Table A1.  While data from PHED provide
the best available information on handler exposures, it should be noted
that some aspects of the included studies (e.g., duration, acres
treated, pounds of active ingredient handled) may not accurately
represent labeled uses in all cases.  HED has developed a series of
tables of standard unit exposure for many occupational scenarios that
can be utilized to ensure consistency in exposure assessments.  Unit
exposures are used which represent different levels of personal
protection as described above.  Protection factors were used to
calculate unit exposures for varying levels of personal protection if
data were not available.

		2.1.2	Rotenone Handler Exposure Scenarios  tc "2.1.2	MGK-264 Handler
Exposure Scenarios " \l 3

	It has been determined that exposure to pesticide handlers is likely
during the occupational use of rotenone in various water bodies.  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 rotenone applications. The
quantitative exposure/risk assessment developed for occupational
handlers is based on the following scenarios. [Note: The scenario
numbers correspond to the tables of risk calculations included in the
occupational risk calculation aspects of the appendices.]

Mixer/Loaders:

	(1a) Liquid Formulations for Helicopter Applications

(1b) Liquid Formulations for Boat Applications (boom and underwater hose
applications)

	(2a) Wettable Powder Formulations for Boat Applications (boom and
underwater hose applications)

	Applicators:

(3) Helicopter Spray Applications (using PHED fixed wing aerial spray
application data)

(4) Boat Boom Spray Applications (using PHED groundboom spray
application data)

	Mixer/Loader/Applicators:

(5) Liquid Formulations: Backpack Sprayer (using PHED liquid low
pressure handwand data)

(6)  Liquid Formulations: Closed System Aspirators (using PHED closed
system mixing/loading liquids) – no contact should occur once liquid
rotenone is loaded

(7)  Liquid Formulations: Drip Bars (using PHED mixing/loading liquids)
– no contact should occur once liquid rotenone is loaded

(8) Wettable Powder: Backpack Sprayer (using PHED wettable powder low
pressure handwand data)

(9)  Wettable Powder Formulations: Closed System Aspirators (using PHED
closed system mixing/loading wettable powders) - no contact should occur
once wettable powder rotenone is loaded

(10)  Wettable Powder Formulations: Drip Bars (using PHED mixing/loading
wettable powders) - no contact should occur once wettable powder
rotenone is loaded

(11)  Wettable Powder Formulations: Powder/Sand/Gelatin Pastes

	2.1.3	Non-cancer Rotenone Handler Exposure and Assessment tc "2.1.3
Non-cancer MGK-264 Handler Exposure and Assessment " \l 3

<IP_ADDRESS>	Non-cancer Rotenone Handler Exposure and Risk 				Calculations
tc "<IP_ADDRESS>	Non-cancer MGK-264 Handler Exposure and Risk Calculations "
\l 4

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

Daily Exposure (mg ai/day) = Unit Exposure * Application Rate * Daily
Area Treated

Where:

Daily Exposure		=	Amount (mg or μg 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 μg ai/day) derived from
August 1998 			PHED data;

Application Rate		=	Normalized application rate based on a logical unit
treatment, such as 			acre-foot or cubic foot; and

Daily Area Treated	=	Normalized application area based on a logical unit
treatment such as 	acres (A/day) or cubic feet (cu ft/day).

	Daily Dose:  The daily dermal or inhalation dose is calculated by
normalizing the daily exposure by body weight and adjusting, if
necessary, with an appropriate dermal or inhalation absorption factor.
For all dermal and inhalation exposure scenarios for rotenone, an
average adult body weight of 70 kilograms was used, since the
toxicological endpoint of concern was not gender-specific.  Since the
dermal toxicological endpoints of concern are based on oral studies, a
dermal absorption rate is used to estimate the amount of rotenone likely
to be absorbed through the skin following dermal exposures. A dermal
absorption value of 10% was used.  The inhalation toxicological endpoint
of concern also was based on an oral studie, therefore an inhalation
absorption rate is used to estimate the amount of rotenone likely to be
absorbed through the lungs following inhalation exposures.  An
inhalation absorption factor of 100% was used.

Daily dose was calculated using the following formula:

Average Daily Dose (mg/kg/day) = Daily Exposure * Absorption Factor /
Body Weight

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).

	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:

MOE = NOAEL or LOAEL (mg/kg/day) / Average Daily Dose (mg/kg/day)

Where:

MOE 	= 	Margin of Exposure, value used by HED to represent risk or how
close 	a chemical exposure is to being a concern (unitless);

Average Daily Dose	= 	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 calculated for
rotenone because the dermal and inhalation toxicological endpoints of
concern are based on the same adverse effects.

<IP_ADDRESS>	Rotenone Non-cancer Risk Summary (using PHED data) tc "<IP_ADDRESS>
MGK-264 Non-cancer Risk Summary (using PHED, ORETF, and proprietary
data) " \l 4

	All of the non-cancer risk calculations for occupational rotenone
handlers completed in this assessment are included in the appendices.
The results indicate that many of the occupational aquatic-use handler
risks exceed HED’s level of concern [i.e., MOEs are less than 1000].
A summary of the short- and intermediate-term risks for each exposure
scenario are presented below in Table 6.Table 6.  Combined Dermal plus
Inhalation Aquatic-Use Occupational Handler Risks

Exposure Scenario	Crop or Target	Application  Ratea	Area Treated Dailyb
Depth of Water Bodyb	Width of Water Bodyb	Combined MOEsc

Baseline	G + NR	G, DL + NR	G + 80% R	G, DL + 80% R	G + 90% R	G, DL + 90%
R	Eng Cont

Mixer/Loader

Mixing/Loading Liquid Concentrates for Helicopter Applications (1a)
Lakes, ponds	0.68 lb ai/A-ft	10 acres	5 ft	NA	3.5	290	350	410	530	430
570	1100

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	NA	7.1	590	710	810	1100	850
1100	2200

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	NA	4.5	370	450	510	670	540
710	1400

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	NA	8.9	740	890	1000	1300	1100
1400	2700

Mixing/Loading Liquid Concentrates for Boat Applications (1b)	Lakes,
ponds	0.68 lb ai/A-ft	100 acres	5 ft	NA	0.35	29	35	41	53	43	57	110

	Lakes, ponds	0.68 lb ai/A-ft	50 acres	5 ft	NA	0.71	59	71	81	110	85	110
220

	Lakes, ponds	0.54 lb ai/A-ft	100 acres	5 ft	NA	0.45	37	45	51	67	54	71
140

	Lakes, ponds	0.54 lb ai/A-ft	50 acres	5 ft	NA	0.89	74	89	100	130	110
140	270

Mixing/Loading Wettable Powders for Boat Applications (2a)	Lakes, ponds
0.68 lb ai/A-ft	100 acres	5 ft	NA	0.25	1.7	1.8	4	4.8	4.8	6	84

	Lakes, ponds	0.68 lb ai/A-ft	50 acres	5 ft	NA	0.5	3.4	3.7	8	9.5	9.7	12
170

	Lakes, ponds	0.54 lb ai/A-ft	100 acres	5 ft	NA	0.31	2.2	2.3	5.1	6	6.1
7.5	110

	Lakes, ponds	0.54 lb ai/A-ft	50 acres	5 ft	NA	0.63	4.3	4.6	10	12	12	15
210

Applicator

Applying Sprays via Helicopter (3)	Lakes, ponds	0.68 lb ai/A-ft	10 acres
5 ft	NA	ND	ND	ND	ND	ND	ND	ND	1800

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	NA	ND	ND	ND	ND	ND	ND	ND	3600

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	NA	ND	ND	ND	ND	ND	ND	ND	2300

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	NA	ND	ND	ND	ND	ND	ND	ND	4600

Applying Sprays via Boat Over-surface Boom Equipment (4)	Lakes, ponds
0.68 lb ai/A-ft	100 acres	5 ft	NA	48	48	56	66	82	70	88	190

	Lakes, ponds	0.68 lb ai/A-ft	50 acres	5 ft	NA	96	96	110	130	160	140	180
380

	Lakes, ponds	0.54 lb ai/A-ft	100 acres	5 ft	NA	61	61	70	84	100	88	110
240

	Lakes, ponds	0.54 lb ai/A-ft	50 acres	5 ft	NA	120	120	140	170	210	180
220	480

Mixer/Loader/Applicator

Mixing/Loading/Applying Liquids with a Backpack Sprayer (using PHED
liquid low pressure handwand data) (5)	Lakes, ponds	0.68 lb ai/A-ft	2
acres	5 ft	NA	0.51	71	77	110	120	110	130	NF

	Lakes, ponds	0.54 lb ai/A-ft	2 acres	5 ft	NA	0.51	71	77	110	120	110	130
NF

	Moving water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft	10
1400	1500	2100	2400	2300	2600	NF

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	13
1700	1900	2600	3000	2800	3200	NF

Mixing/Loading/

Applying Liquids with Closed System Aspirators (PHED: mixing/loading
liquid - closed system) (6)	Lakes, ponds	0.68 lb ai/A-ft	10 acres	5 ft
N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	110

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	N/A	N/A	N/A
N/A	220

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	N/A	N/A	N/A	N/A	N/A	N/A	N/A
N/A	140

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	N/A	N/A	N/A
N/A	270

Mixing/Loading/

Applying Liquids with Drip Bars (PHED: mixing/loading liquid) (7)	Moving
water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft	360	30000
36000	41000	53000	43000	57000	110000

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	440
36000	44000	50000	66000	53000	70000	140000

Mixing/Loading/

Applying Wettable Powders with a Backpack Sprayer (using PHED wettable
powder low pressure handwand data) (8)	Lakes, ponds 	0.68 lb ai/A-ft	2
acres	5 ft	NA	ND	2.6	3	4.8	6.1	5.3	7.1	NF

	Lakes, ponds	0.54 lb ai/A-ft	2 acres	5 ft	NA	ND	2.6	3	4.8	6.1	5.3	7.1
NF

	Moving water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft	ND
53	60	96	120	110	140	NF

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	ND
65	74	120	150	130	170	NF

Mixing/Loading/

Applying Wettable Powders with Closed System Aspirators (PHED:
mixing/loading liquid - closed system) (9)	Lakes, ponds	0.68 lb ai/A-ft
10 acres	5 ft	N/A	N/A	N/A	N/A	N/A	N/A	N/A	N/A	84

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	N/A	N/A	N/A
N/A	170

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	N/A	N/A	N/A	N/A	N/A	N/A	N/A
N/A	110

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	N/A	N/A	N/A
N/A	210

Mixing/Loading/

Applying Wettable Powders with Drip Bars (PHED: mixing/loading liquid)
(10)	Moving water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft
250	1700	1800	4000	4800	4900	6000	85000

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	310
2100	2300	5000	5900	6000	7400	100000

Mixing/Loading/

Applying Wettable Powders via Powder/Sand/Gelatin Paste (11)	Seeps and
Springs

	N/A	N/A	There is currently no data to assess this scenario.  HED
believes this scenario will result in minimal exposure due to the amount
of rotenone used and the fact that this paste is typically mixed in
either a lab under a fume hood or by an individual wearing a respirator.

a	Application rates are the maximum application rates determined from
EPA registered labels for rotenone

b	Area treated per day values for all application methods except boats
are based on personal contact with Brian Finlayson, California
Department of Fish and Game (1/9/06).  Area treated per day values for
boat application methods are based on HED professional judgment.

c	Baseline:		Long-sleeve shirt, long pants, no gloves, and no
respirator.

	PPE-G-NR:  	Baseline plus chemical-resistant gloves, and no respirator.

	PPE-G,DL-NR: 	Coveralls worn over long-sleeve shirt and long pants,
chemical-resistant gloves, and no respirator.

	PPE-G-80% R:	Baseline plus chemical-resistant gloves and an 80% PF
(quarter-face dust/mist) respirator.

	PPE-G,DL-80% R: 	Coveralls worn over long-sleeve shirt and long pants,
chemical-resistant gloves, and an 80% PF (quarter-face dust/mist)
respirator.

	PPE-G-90% R:	Baseline plus chemical-resistant gloves and a 90% PF
(half-face dust/mist) respirator.

	PPE-G,DL-90% R: 	Coveralls worn over long-sleeve shirt and long pants,
chemical-resistant gloves, and a 90% PF (half-face dust/mist)
respirator.

	Eng Controls: 	Closed mixing/loading system, enclosed cab, or enclosed
cockpit.

Occupational Risk Characterization

	The data that were used in the rotenone occupational handler risk
assessment represent the best data and approaches that are currently
available.  While some of the data which have been used may not be of
optimal quality or directly represent current rotenone application
methods, they represent the best available data for the scenario in
question.  In all cases, the Pesticide Handlers Exposure Database (PHED)
was used to develop the unit exposure values.  The quality of the data
included in PHED vary widely from scenarios that meet guideline
requirements for studies to others where a limited number of poor
quality datapoints are available.  The results for each scenario should
be reviewed in the context of the quality of these data.  Along with the
unit exposure values used in the assessment, other inputs include
application rates and area treated daily values.  Selected application
rates represent maximum rates that have been approved by the rotenone
technical registrants.  The other key input for completing handler risk
assessments used for defining how much chemical can be used in a day is
how much can be treated in a day which is generally expressed as the
number of acres treated per day.  Area treated per day values for all
application methods except boats are based on personal contact with
Brian Finlayson, California Department of Fish and Game (1/9/06).  Area
treated per day values for boat application methods are based on HED
professional judgment.

	In addition to the key sources of information considered above, there
are many underlying factors that may impact the overall results of a
risk assessment.  For example, the protection factors used for adding
additional levels of dermal and respiratory protection may impact the
overall risk picture.  The factors used in this assessment by HED are
the ones that have been used for several years.  There also are exposure
monitoring issues that should be considered.  For example, in many cases
the data included in PHED are based on the use of cotton gloves for hand
exposure monitoring which are thought by many to overestimate exposure
because they potentially retain residues more than human skin would over
time (i.e., they may act like a sponge compared to the actual hand).
These intangible elements of the risk assessment reflect many of the
hidden uncertainties associated with exposure data.  The overall impacts
of these uncertainties is hard to quantify.

	In summary, HED believes that the risk values presented in this
occupational assessment represent the highest quality results that could
be produced given the exposure, use, and toxicology data that are
available.  Certainly risk managers and other interested parties should
consider the quality of individual inputs when interpreting the results
and make decisions accordingly.  It is difficult to ascertain where on a
distribution the values that have been calculated fall because the
distributional data for exposure, application rates, acres treated, and
many other parameters are unrefined.  HED does believe, however, that
the risks represent conservative estimates of exposure because maximum
application rates are coupled with liberal estimates of daily area
treated to define risk estimates that likely fall in the upper
percentiles of the actual exposure distributions.

2.1.4	Summary of Risk Concerns and Data Gaps for Occupational
Handlers  tc "2.1.5 	Summary of Risk Concerns and Data Gaps for
Occupational Handlers " \l 3

	There are several occupational handler scenarios for rotenone that have
risks associated with them that are above HED’s level of concern for
non-cancer risk assessments.

			<IP_ADDRESS>	Summary of Risk Concerns  tc "<IP_ADDRESS>	Summary of Risk
Concerns " \l 4

For applications to aquatic sites (liquid applications), risks to
mixers/loaders and aerial applicators, generally did not exceed HED’s
level of concern at some level of risk mitigation.  For applications to
aquatic sites (wettable powder applications), risks to mixers/loaders,
generally exceeded HED’s level of concern even at maximum risk
mitigation.  Many of the mixer/loader/applicator scenarios for aquatic
sites (liquid and wettable powder applications) also exceeded HED’s
level of concern even at maximum risk mitigation.

In particular, HED has serious concerns for any scenario that involves
open mixing/loading of wettable powder formulations of rotenone.  HED
also has concerns for mixing/loading/applying via backpack sprayers for
both liquid and wettable powder formulations.

			<IP_ADDRESS>	Summary of Data Gaps  tc "<IP_ADDRESS>	Summary of Data Gaps " \l 4

Although actual exposure data would refine the rotenone exposure
assessment, there are currently no specific data gaps for rotenone.

2.1.5	Recommendations For Refining Occupational Handler Risk Assessment
tc "2.1.6	Recommendations For Refining Occupational Handler Risk
Assessment " \l 3

In order to refine this occupational risk assessment, data on actual use
patterns including rates, timing, and areas treated would better
characterize rotenone risks.  Exposure studies for the many equipment
types that lack data in PHED should be considered based on a review of
the quality and applicability of the data used in this assessment.

	2.2	Occupational Postapplication Exposures and Risks  tc "2.2
Occupational Postapplication Exposures and Risks " \l 2

	HED expects minimal occupational postapplication exposure from the
piscicidal use of rotenone.  As a result, no quantitative assessment was
completed for occupational postapplication exposure.

3.0	Residential and Other Non-Occupational Exposures and Risks tc "3.0
Residential and Other Non-Occupational Exposures and Risks"

	3.1	Residential Handler Exposures and Risks  tc "3.1	Residential
Handler Exposures and Risks " \l 2

Rotenone is currently registered for use in a variety of residential
scenarios, however, in memos dated (March 7, 2006; March 17, 2006; and
April 5, 2006) the rotenone technical registrants (Prentiss, Inc.;
Foreign Domestic Chemicals Corporation; and Tifa Limited) voluntarily
cancelled all uses of rotenone except for the piscicidal uses.  The
cancelled uses of rotenone were previously assessed in HED’s document
entitled Rotenone: Phase 3 Occupational and Residential Exposure
Assessment for the Reregistration Eligibility Decision Document (January
24, 2006).

	3.2	Residential Postapplication Exposures and Risks  tc "3.2
Residential Postapplication Exposures and Risks " \l 2

	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.  Rotenone can be used in
various types of water bodies that can be frequented by the general
public.  As a result, individuals can be exposed by swimming in the
rotenone treated water.

		3.2.1	Residential Postapplication Exposure Scenarios  tc "3.2.1
Residential Postapplication Exposure Scenarios " \l 3

	Individuals of varying ages potentially can be exposed to rotenone when
they are in waters that have been previously treated with rotenone.
Postapplication exposure scenarios were developed for aquatic settings
where rotenone can be used.  The following are important pieces of
HED’s residential postapplication exposure assessment:

exposures were calculated for children of differing ages as well as
adults; and

the SWIMODEL 3.0 has been used to estimate dermal and incidental
ingestion exposure that may occur from swimming in rotenone treated
water.

	HED relies on a standardized approach for completing residential risk
assessments that is based on current rotenone labels and guidance
contained in the following two documents:

Standard Operating Procedures for Residential Exposure Assessment (Dec.
1997): This document provides the overarching guidance for developing
residential risk assessments including scenario development, algorithms,
and values for inputs.

Science Advisory Council for Exposure Policy 12 (Feb. 2001): Recommended
Revisions to the Standard Operating Procedures (SOPs) For Residential
Exposure Assessment: This document provides additional, revised guidance
for completing residential exposure assessments.

	When the guidance in current labels and these documents is considered,
it is clear that HED should consider children of differing ages as well
as adults in its assessments.  It is also clear that different age
groups should be considered in different situations.  The populations
that were considered in the assessment include:

Residential Adults: these individuals are members of the general
population that could be exposed by engaging in swimming activities in
water previously treated with rotenone.

Residential Children: children are members of the general population
that could be exposed by engaging in swimming activities in water
previously treated with rotenone.

	The SOPs for Residential Exposure Assessment define scenarios that
apply to uses specified in current labels.  These scenarios serve as the
basis for the residential postapplication assessment along with the
modifications to them and the additional data and approaches described
above.  The SOPs and the associated scenarios are presented below:

Dose from dermal exposure while swimming in treated water:
Postapplication dermal dose calculations for adults and toddlers while
swimming; and

Dose from ingestion of water while swimming in treated water:
Postapplication dose calculations for adults and toddlers from
incidental ingestion of pesticide residues from ingesting water while
swimming in treated water.

The detailed residential postapplication calculations are presented in
the appendices of this document.

3.2.2	Data and Assumptions for Residential Postapplication Exposure
Scenarios  tc "3.2.2	Data and Assumptions for Residential
Postapplication Exposure Scenarios " \l 3

	Assumptions and Exposure Factors

	A series of assumptions and exposure factors served as the basis for
completing the residential postapplication risk assessments.  The
assumptions and factors used in the risk calculations are consistent
with current Agency policy for completing residential exposure
assessments (i.e., SOPs for Residential Exposure Assessment).  The
values used in this assessment include:

HED combines risks resulting from exposures to individual applications
when it is likely they can occur simultaneously based on the use pattern
and the behavior associated with the exposed population.  For rotenone,
HED has combined risks (i.e., MOEs) for different kinds of exposures for
the swimming scenarios – dermal plus incidental ingestion.

Exposures to adults and children while swimming in treated water have
been addressed using the latest HED standard operating procedures for
this scenario including:

the SWIMODEL was used to calculate the total worst-case exposure for
swimmers expressed as a mass-based intake value (mg/event) (detailed
information and the downloadable executable file are available at
GOTOBUTTON BM_1_ http://www.epa.gov/oppad001/swimodel.htm. );

exposure durations for swimming scenarios are estimated to be 1 hour
based on information from the 2002 Child Specific Exposure Factors
Handbook;

the ingestion rate used in the SWIMODEL 3.0 is based on the value used
in EPA’s Residential SOPs (U.S. EPA, 2000) and an EPA pilot study as
discussed in ACC’s swimmer survey (ACC, 2002); and

dermal and incidental ingestion are combined to represent an overall
risk from exposure to swimming in treated water.

Postapplication residential risks are based on maximum application rates
or values specified in the SOPs for Residential Exposure Assessment.

		3.2.3	Residential Postapplication Exposure and Noncancer Risk
Estimates  tc "3.2.3	Residential Postapplication Exposure and Noncancer
Risk Estimates " \l 3

	Noncancer risks were calculated using the Margin of Exposure (MOE)
approach, which is a ratio of the body burden to the toxicological
endpoint of concern. Exposures were calculated by considering the
potential sources of exposure then calculating dermal and nondietary
ingestion exposures.

	Postapplication Exposure From Swimming in Treated Water:
Postapplication exposures from swimming in treated water were calculated
using the following equations.  These values were then used to calculate
MOEs.

Dermal Exposure from Swimming in Treated Water (adult, youth, and
toddler)

The approach used to calculate the dermal exposures that are
attributable to exposure from swimming in treated water is:

ADD	=	(Cw * Kp * SA * ET * CF) / BW

where:

	ADD	=	average daily dose for lakes/ponds or streams, (mg/kg/day);

	Cw	=	chemical concentration in water (mg/L);

	Kp	=	permeability constant (cm/hr);

	SA	=	surface area (cm2);

	ET	=	exposure time (hrs/day);

	CF	=	conversion factor (0.001 L/cm3); and

	BW	=	body weight (kg).

Incidental Ingestion Exposure from Swimming in Treated Water (adult,
youth, and toddler)

The approach used to calculate the incidental ingestion exposures that
are attributable to exposure from swimming in treated water is:

ADD	=	(C2 * IR * ET) / BW

where:

	ADD	=	average daily dose for lakes/ponds or streams, (mg/kg/day);

	Cw	=	chemical concentration in water (mg/L);

	IR	=	ingestion rate of water (L/hr);

	ET	=	exposure time (hrs/day); and

	BW	=	body weight (kg).

	Noncancer Risk Summary:  tc "Noncancer Risk Summary\: " \l 4   All of
the noncancer risk calculations for the various residential rotenone
assessments are included in the appendices.

	HED has addressed residential postapplication exposures to rotenone
using the standard set of scenarios that are prescribed in current
guidance.  There are many issues associated with the development of
these scenarios and, in general, residential exposure methods.  Readers
should refer to the guidance documents that are presented above for
further information concerning the development of scenarios for
residential exposure assessment purposes.  The uncertainty factors are
similar to those applied to the occupational handler assessments
described above (i.e., 1000 for short-term and intermediate-term
exposures).

	Adults

	Table 7 presents the postapplication MOE values calculated for adults
after piscicidal applications of rotenone.  For the swimming in treated
water scenarios, short-term MOEs are >1000 for all scenarios.

Table 7: Adult Residential Risk Estimates for Postapplication Exposure
to Rotenone

Exposure Scenario	Route of Exposure	Application Rate	MOE at Day 0

Swimming - Dermal	Dermal	0.25 ppm	1,300

0.20 ppm	1,600

Swimming – Incidental Ingestion	Oral	0.25 ppm	5,600

0.20 ppm	7,000

	Toddler (3 year old)

	Table 8 presents the postapplication MOE values calculated for toddlers
after piscicidal applications of rotenone.  For the swimming in treated
water scenarios, short-term MOEs are <1000 for all scenarios.

Table 8: Toddler Residential Risk Estimates for Postapplication Exposure
to Rotenone

Exposure Scenario	Route of Exposure	Application Rate	MOE at Day 0

Swimming - Dermal	Dermal	0.25 ppm	770

0.20 ppm	970

Swimming – Incidental Ingestion	Oral	0.25 ppm	680

0.20 ppm	850

	The Environmental Fate and Effects Division (EFED) calculated the
number of days it would take to reach a rotenone concentration that
results in acceptable toddler dermal and oral MOEs (170 ppb of rotenone
results in an oral MOE of 1000 and a dermal MOE of 1100).   This is done
by assuming that the dissipation rate for rotenone in a warm water pond
is 1.5 days, as seen in the aquatic dissipation study.  The time it
takes for the rotenone to dissipate to 170 ppb from 200 ppb is 0.35 days
and from 250 ppb is 0.89 days.  EFED assumed first order degradation
below 200 ppb and zero order degradation above.  Zero order degradation
assumes that the degradation rate is constant with time.  This includes
the assumption that more rotenone dissolves to keep the concentration
constant at 200 ppb until all the rotenone is in solution, and then
first order kinetics occurs after that.  The temperature in the “warm
water” pond in the aquatic dissipation study was 25oC which EFED and
HED consider to be a temperature at which swimming by the general public
could reasonably occur.

Combined Risk Assessment for Residential Scenarios

	HED combines risk values resulting from separate postapplication
exposure scenarios when it is likely they can occur simultaneously based
on the use-pattern and the behavior associated with the exposed
population.  Table 9 presents a summary of the combined MOE estimates.

The combined risk assessment for exposures to treated water was
calculated as:

  	Combined MOE	=	NOAEL / (ADDincidental ingestion + ADDdermal)

Table 9: Rotenone Residential Scenarios for Combined Risk Estimates

Postapplication Exposure Scenario	Margins of Exposure (MOEs)

(UF=1000)

	Short-Term Oral

(Non-Dietary)	Total  Non-Dietary Risk

Toddler	Swimming (0.25 ppm)	Dermal	770	360

Oral	680

Swimming (0.20 ppm)	Dermal	970	450

Oral	850

HED calculated the number of days it would take to reach a rotenone
concentration that results in acceptable toddler combined MOEs (90 ppb
of rotenone results in an oral MOE of 1900 and a dermal MOE of 2100,
which results in a combined MOE of 1000).  The time it takes for the
rotenone to dissipate to 90 ppb from 200 ppb is approximately 2 days and
from 250 ppb is approximately 3 days.  HED believes that swimming in
rotenone treated waters should be prohibited for at least 2 days after
completion of a 200 ppb rotenone application and at least 3 days after
completion of a 250 ppb rotenone application.

Summary of Residential Postapplication Risk Concerns and Data

Gaps  tc "3.2.5	Summary of Residential Postapplication Risk Concerns and
Data Gaps " \l 3

	HED considered two exposure scenarios for rotenone piscicidal products
that can be used in water bodies where different segments of the
population (including toddlers and adults) may be exposed to rotenone.
Short-term noncancer MOEs were calculated for all scenarios.  Cancer
risks were not calculated, since no toxicological cancer endpoint was
selected.

In residential settings, HED does not use restricted-entry intervals or
other mitigation approaches to limit postapplication exposures, because
they are viewed as impractical and not enforceable.  As such, risk
estimates on the day of application are the key concern.  However, in
the case of rotenone, HED believes that swimming in rotenone treated
waters should be prohibited for at least 2 days after completion of a
200 ppb rotenone application and at least 3 days after completion of a
250 ppb rotenone application.

3.2.5	Recommendations for Refining Residential Postapplication Risk
Assessments tc "3.2.6	Recommendations For Refining Residential
Postapplication Risk Assessments " \l 3

	In order to refine this residential assessment, data on actual use
patterns including rates, timing, and the kinds of tasks performed are
required to better characterize rotenone risks.

4.0	References

Barnes 2005.  Rotenone:  Summary of Product Chemistry Data for
Reregistration Eligibility Decision (RED) Document. DP Barcode:
D307391.  P. Yvonne Barnes.  August 11, 2005.

Carter 2005. Usage Report in Support of Reregistration for the
Insecticide Rotenone (074002).  Jenna Carter.  August 3, 2005.

Hawkins 2005.  Review of Rotenone Incident Reports.  DP Barcode D307408,
Chemical #071003 and #071002.  Monica S. Hawkins.  August 9, 2005.

R. David Jones 2006.  Drinking Water and Swimmer Exposure Assessment for
Rotenone from the Piscicide Use.  D307383.  R. David Jones.  May 10,
2006.

Rotenone: Decisions on Critical Effects and Endpoint Selection.  Results
of the Meeting of the HED Hazard Science Policy Council.  PC Code:
071003.  DP Barcode: D307370.  TXR# 0053480.  Diana Locke.  June 28,
2005.

Rotenone Use in Fisheries Management: Administrative and Technical
Guidelines Manual.  American Fisheries Society.  Brian Finlayson, et al.
 April 2000.Appendix A: Occupational ExposureAppendix A/Table A1.
Sources of Exposure Data Used In The Occupational Rotenone Handler
Exposure And Risk Calculations

Exposure Scenario (Number)	Data Source	Standard Assumptions

(8-hr work day)a	Commentsb,c

Mixer/Loader Descriptors

Mixing/Loading Liquid Formulations (1)	PHED V1.1	Helicopter: rangefinder
of 5 and 10 acres with a depth of 5 feet for lakes/ponds/reservoirs.

Boat: rangefinder of 50 and 100 acres with a depth of 5 feet for
lakes/ponds/reservoirs.

	Baseline: Dermal, hand, and inhalation = acceptable grades. Hands = 53
replicates; Dermal = 72 to 122 replicates; and Inhalation = 85
replicates.  High confidence in hand, dermal, and inhalation data. No
protection factor was needed to define the unit exposures.

PPE: The same dermal data are used as for baseline coupled with a 50%
protection factor to account for an additional layer of clothing.  Hands
= acceptable grades.  Hands = 59 replicates.  High confidence in hand
data.   A respirator protection factor of 5 is applied to estimate the
use of a quarter-face respirator (dust/mist filtering only).  A
respirator protection factor of 10 is applied to estimate the use of a
half-face negative pressure respirator or a powered air purifying
respirator (dust/mist filtering and/or organic vapor-removing).

Engineering Controls:  Hands, dermal, and inhalation = acceptable
grades. Hands = 31 replicates; Dermal = 16 to 22 replicates; and
Inhalation = 27 replicates.  High confidence in hand, dermal, and
inhalation data.  Gloves were used coupled with engineering controls
since empirical data without gloves were not available and back
calculation of gloves to a no glove scenario is believed to give
erroneously high estimates.

Mixing/Loading Wettable Powder Formulations (2)	PHED V1.1	Boat:
rangefinder of 50 and 100 acres with a depth of 5 feet for
lakes/ponds/reservoirs.	Baseline: Dermal, hand, and inhalation = ABC
grades. Hands = 7 replicates; Dermal = 22 to 45 replicates, and
Inhalation = 44 replicates.  Low confidence in the dermal/hands data due
to the low number of hand replicates.  Medium confidence in inhalation
data. No protection factor was needed to define the unit exposure value.

PPE:  Hands = ABC grades. Hands = 24 replicates. The same dermal data
are used as for baseline coupled with a 50% protection factor to account
for an additional layer of clothing. Hands = ABC grades. Hands = 24
replicates. Medium confidence in hand data.  A respirator protection
factor of 5 is applied to estimate the use of a quarter-face respirator
(dust/mist filtering only).  A respirator protection factor of 10 is
applied to estimate the use of a half-face negative pressure respirator
or a powered air purifying respirator (dust/mist filtering and/or
organic vapor-removing).

Engineering Controls: Dermal and hands = AB grades.  Inhalation = all
grades.  Dermal = 6 to 15 replicates; Hands = 9 replicates; and
Inhalation = 15 replicates.  Low confidence in hand, dermal, and
inhalation data.  Gloves were used coupled with engineering controls
since empirical data without gloves were not available and back
calculation of gloves to a no glove scenario is believed to give
erroneously high estimates.

Applying Sprays via Helicopter (3)	PHED V1.1

(Fixed-wing aircraft data used as a surrogate)	Rangefinder of 5 and 10
acres with a depth of 5 feet for lakes/ponds/reservoirs.	Engineering
Controls: Dermal and hands = AB grade and Inhalation = ABC grade.
Dermal = 20 to 28 replicates; Hands = 34 replicates; and Inhalation = 23
replicates.  High confidence in dermal and hand data.  Medium confidence
in inhalation data.  No protection factor was needed to define the unit
exposure value.

EPA has no data for this scenario, other than enclosed cockpits ( the
engineering control.

Applying Sprays via Boat-boom Sprayer (4)	PHED V1.1 (Groundboom data
used as a surrogate)	Rangefinder of 50 and 100 acres with a depth of 5
feet for lakes/ponds/reservoirs.	Baseline: Dermal, hand, and inhalation
= AB grades.  Dermal = 23 to 42 replicates; Hands =29 replicates; and
Inhalation = 22 replicates. High confidence in hand, dermal, and
inhalation data.  No protection factors were needed to define the unit
exposure values.

PPE: The same dermal data are used as for baseline coupled with a 50%
protection factor to account for an additional layer of clothing. Hands
= ABC grades. Hands = 21 replicates. Medium  confidence in hand data.
A respirator protection factor of 5 is applied to estimate the use of a
quarter-face respirator (dust/mist filtering only).  A respirator
protection factor of 10 is applied to estimate the use of a half-face
negative pressure respirator or a powered air purifying respirator
(dust/mist filtering and/or organic vapor-removing).

Engineering Controls: Dermal and Hands = ABC grade. Inhalation = AB
grades.  Dermal = 20 to 31 replicates; Hands = 16 replicates; and
inhalation = 16 replicates. Medium confidence in the hand and dermal
data.  High confidence in inhalation data.  No protection factor  needed
to define the unit exposure value.  Protective gloves not used.

Mixing/Loading/Applying Liquid Formulations via Backpack Sprayer (5)
PHED V1.1

(Low pressure handwand data used as a surrogate)	2 acres and 5 feet deep
for lakes/ponds/reservoirs; 10,560 feet long, 2 feet deep and 10 feet
long for moving water (streams).	Baseline: Hands = all grades; dermal
and inhalation = ABC grades. Dermal = 9 to 80 replicates; Hands = 70
replicates; and Inhalation = 80 replicates.  Medium confidence in
inhalation data.  Low confidence in dermal and hand data.  No protection
factor was needed to define the unit exposure values.

PPE: The same dermal data are used as for baseline coupled with a 50%
protection factor to account for an additional layer of clothing.  Hand
= 10 replicates.  Hands= ABC grades Low confidence in hand data.    A
respirator protection factor of 5 is applied to estimate the use of a
quarter-face respirator (dust/mist filtering only).  A respirator
protection factor of 10 is applied to estimate the use of a half-face
negative pressure respirator or a powered air purifying respirator
(dust/mist filtering and/or organic vapor-removing).

Engineering Controls: Not considered feasible for this exposure
scenario.

Mixing/Loading/Applying Liquid Formulations via Closed System Aspirators
(6)	PHED V1.1

(Closed system mixing/loading data used as a surrogate)	Rangefinder of
50 and 100 acres with a depth of 5 feet for lakes/ponds/reservoirs.
Baseline: Not considered applicable for this exposure scenario.

PPE: Not considered applicable for this exposure scenario.

Engineering Controls:  Hands, dermal, and inhalation = acceptable
grades. Hands = 31 replicates; Dermal = 16 to 22 replicates; and
Inhalation = 27 replicates.  High confidence in hand, dermal, and
inhalation data.  Gloves were used coupled with engineering controls
since empirical data without gloves were not available and back
calculation of gloves to a no glove scenario is believed to give
erroneously high estimates.

Mixing/Loading/Applying Liquid Formulations via Drip Bars (7)	PHED V1.1

(Mixing/loading data used as a surrogate)	10,560 feet long, 2 feet deep
and 10 feet long for moving water (streams).	Baseline: Dermal, hand, and
inhalation = acceptable grades. Hands = 53 replicates; Dermal = 72 to
122 replicates; and Inhalation = 85 replicates.  High confidence in
hand, dermal, and inhalation data. No protection factor was needed to
define the unit exposures.

PPE: The same dermal data are used as for baseline coupled with a 50%
protection factor to account for an additional layer of clothing.  Hands
= acceptable grades.  Hands = 59 replicates.  High confidence in hand
data.   A respirator protection factor of 5 is applied to estimate the
use of a quarter-face respirator (dust/mist filtering only).  A
respirator protection factor of 10 is applied to estimate the use of a
half-face negative pressure respirator or a powered air purifying
respirator (dust/mist filtering and/or organic vapor-removing).

Engineering Controls:  Hands, dermal, and inhalation = acceptable
grades. Hands = 31 replicates; Dermal = 16 to 22 replicates; and
Inhalation = 27 replicates.  High confidence in hand, dermal, and
inhalation data.  Gloves were used coupled with engineering controls
since empirical data without gloves were not available and back
calculation of gloves to a no glove scenario is believed to give
erroneously high estimates.

Mixing/Loading/Applying Wettable Powders via Backpack Sprayer (8)	PHED
V1.1

(Low pressure handwand data used as a surrogate)	2 acres and 5 feet deep
for lakes/ponds/reservoirs; 10,560 feet long, 2 feet deep and 10 feet
long for moving water (streams)	Baseline: Inhalation = ABC grades.
Inhalation = 16 replicates.  Medium confidence in inhalation data.  Low
confidence in dermal and hand data due to lack of (no glove( hand data.
The only empirical hand data available are based on the use of
chemical-resistant gloves.  It is generally not appropriate to
back-calculate a non-glove hand exposure levels.

PPE: The same dermal data are used as for baseline coupled with a 50%
protection factor to account for an additional layer of clothing.  Hand
= 15 replicates.  Hands= AB grades.  Medium confidence in hand data.
A respirator protection factor of 5 is applied to estimate the use of a
quarter-face respirator (dust/mist filtering only).  A respirator
protection factor of 10 is applied to estimate the use of a half-face
negative pressure respirator or a powered air purifying respirator
(dust/mist filtering and/or organic vapor-removing).

Engineering Controls: Not considered feasible for this exposure
scenario.

Mixing/Loading/Applying Wettebale Powder Formulations via Closed System
Aspirators (9)	PHED V1.1

(Closed system mixing/loading data used as a surrogate)	Rangefinder of
50 and 100 acres with a depth of 5 feet for lakes/ponds/reservoirs.
Baseline: Not considered applicable for this exposure scenario.

PPE: Not considered applicable for this exposure scenario.

Engineering Controls:  Dermal and hands = AB grades.  Inhalation = all
grades.  Dermal = 6 to 15 replicates; Hands = 9 replicates; and
Inhalation = 15 replicates.  Low confidence in hand, dermal, and
inhalation data.  Gloves were used coupled with engineering controls
since empirical data without gloves were not available and back
calculation of gloves to a no glove scenario is believed to give
erroneously high estimates.

Mixing/Loading/Applying Wettable Powder Formulations via Drip Bars (10)
PHED V1.1

(Mixing/loading data used as a surrogate)	10,560 feet long, 2 feet deep
and 10 feet long for moving water (streams).	Baseline: Dermal, hand, and
inhalation = ABC grades. Hands = 7 replicates; Dermal = 22 to 45
replicates, and Inhalation = 44 replicates.  Low confidence in the
dermal/hands data due to the low number of hand replicates.  Medium
confidence in inhalation data. No protection factor was needed to define
the unit exposure value.

PPE:  Hands = ABC grades. Hands = 24 replicates. The same dermal data
are used as for baseline coupled with a 50% protection factor to account
for an additional layer of clothing. Hands = ABC grades. Hands = 24
replicates. Medium confidence in hand data.  A respirator protection
factor of 5 is applied to estimate the use of a quarter-face respirator
(dust/mist filtering only).  A respirator protection factor of 10 is
applied to estimate the use of a half-face negative pressure respirator
or a powered air purifying respirator (dust/mist filtering and/or
organic vapor-removing).

Engineering Controls: Dermal and hands = AB grades.  Inhalation = all
grades.  Dermal = 6 to 15 replicates; Hands = 9 replicates; and
Inhalation = 15 replicates.  Low confidence in hand, dermal, and
inhalation data.  Gloves were used coupled with engineering controls
since empirical data without gloves were not available and back
calculation of gloves to a no glove scenario is believed to give
erroneously high estimates.

Mixing/Loading/Applying Wettable Powder Formulations via
Powder/Sand/Gelatin Paste (11)	There is currently no data to assess this
scenario.  HED believes this scenario will result in minimal exposure
due to the amount of rotenone used and the fact that this paste is
typically mixed in either a lab under a fume hood or by an individual
wearing a respirator.

	a	All Standard Assumptions are based on an 8-hour work day as estimated
by the Agency.  Area treated per day values for all application methods
except boats are based on personal 	contact with Brian Finlayson,
California Department of Fish and Game (1/9/06).  Area treated per day
values for boat application methods are based on HED professional
judgement.

	b	All handler exposure assessments in this document are based on the
"Best Available" data as defined by the HED SOP for meeting Subdivision
U Guidelines (i.e., completing exposure 	assessments).  Best available
grades are assigned to data as follows: matrices with A and B grade data
(i.e., Acceptable Grade Data) and a minimum of 15 replicates; if not
available, then 	grades A, B and C data and a minimum of 15 replicates;
if not available, then all data regardless of the quality (i.e., All
Grade Data) and number of replicates.  High quality data with a
protection factor take precedence over low quality data with no
protection factor.  Generic data confidence categories are assigned as
follows:

High 	= grades A and B and 15 or more replicates per body part

Medium	= grades A, B, and C and 15 or more replicates per body part

Low	= grades A, B, C, D and E or any combination of grades with less
than 15 replicates.

		c	PHED grading criteria do not reflect overall quality of the
reliability of the assessment.  Sources of the exposure factors should
also be considered in the risk

Appendix A/Table A2.  Occupational Dermal Handler Exposure and Risks

Exposure Scenario	Crop or Target	Application  Ratea	Area Treated Dailyb
Depth of Water Bodyb	Width of Water Bodyb	Dermal Unit Exposure (mg/lb
ai)	Dermal Dose (mg/kg/day)	Dermal MOEg

Baselinec	PPE-SL, Gd	PPE-DL, Ge	Eng Conf	Basec	PPE-

SL, Gd	PPE-

DL, Ge	Eng Conf	Basec	PPE-SL, Gd	PPE-DL, Ge	Eng Conf

Mixer/Loader

Mixing/Loading Liquid Concentrates for Helicopter Applications (1a)
Lakes, ponds	0.68 lb ai/A-ft	10 acres	5 ft	NA	2.9	0.023	0.017	0.0086
0.14	0.0011	0.00083	0.00042	3.5	450	610	1200

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	NA	2.9	0.023	0.017	0.0086
0.07	0.00056	0.00041	0.00021	7.1	900	1200	2400

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	NA	2.9	0.023	0.017	0.0086
0.11	0.00089	0.00066	0.00033	4.5	560	760	1500

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	NA	2.9	0.023	0.017	0.0086
0.056	0.00044	0.00033	0.00017	8.9	1100	1500	3000

Mixing/Loading Liquid Concentrates for Boat Applications (2a)	Lakes,
ponds	0.68 lb ai/A-ft	100 acres	5 ft	NA	2.9	0.023	0.017	0.0086	1.4	0.011
0.0083	0.0042	0.35	45	61	120

	Lakes, ponds	0.68 lb ai/A-ft	50 acres	5 ft	NA	2.9	0.023	0.017	0.0086
0.7	0.0056	0.0041	0.0021	0.71	90	120	240

	Lakes, ponds	0.54 lb ai/A-ft	100 acres	5 ft	NA	2.9	0.023	0.017	0.0086
1.1	0.0089	0.0066	0.0033	0.45	56	76	150

	Lakes, ponds	0.54 lb ai/A-ft	50 acres	5 ft	NA	2.9	0.023	0.017	0.0086
0.56	0.0044	0.0033	0.0017	0.89	110	150	300

Mixing/Loading Wettable Powders for Boat Applications (2a)	Lakes, ponds
0.68 lb ai/A-ft	100 acres	5 ft	NA	3.7	0.17	0.13	0.0098	1.8	0.083	0.063
0.0048	0.28	6.1	7.9	110

	Lakes, ponds	0.68 lb ai/A-ft	50 acres	5 ft	NA	3.7	0.17	0.13	0.0098	0.9
0.041	0.032	0.0024	0.56	12	16	210

	Lakes, ponds	0.54 lb ai/A-ft	100 acres	5 ft	NA	3.7	0.17	0.13	0.0098	1.4
0.066	0.05	0.0038	0.35	7.6	10	130

	Lakes, ponds	0.54 lb ai/A-ft	50 acres	5 ft	NA	3.7	0.17	0.13	0.0098	0.71
0.033	0.025	0.0019	0.7	15	20	260

Applicator

Applying Sprays via Helicopter (3)	Lakes, ponds	0.68 lb ai/A-ft	10 acres
5 ft	NA	ND	ND	ND	0.005	ND	ND	ND	0.00024	ND	ND	ND	2100

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	NA	ND	ND	ND	0.005	ND	ND	ND
0.00012	ND	ND	ND	4100

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	NA	ND	ND	ND	0.005	ND	ND	ND
0.00019	ND	ND	ND	2600

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	NA	ND	ND	ND	0.005	ND	ND	ND
0.000096	ND	ND	ND	5200

Applying Sprays via Boat Over-surface Boom Equipment (4)	Lakes, ponds
0.68 lb ai/A-ft	100 acres	5 ft	NA	0.014	0.014	0.011	0.005	0.0068	0.0068
0.0053	0.0024	74	74	94	210

	Lakes, ponds	0.68 lb ai/A-ft	50 acres	5 ft	NA	0.014	0.014	0.011	0.005
0.0034	0.0034	0.0027	0.0012	150	150	190	410

	Lakes, ponds	0.54 lb ai/A-ft	100 acres	5 ft	NA	0.014	0.014	0.011	0.005
0.0054	0.0054	0.0042	0.0019	93	93	120	260

	Lakes, ponds	0.54 lb ai/A-ft	50 acres	5 ft	NA	0.014	0.014	0.011	0.005
0.0027	0.0027	0.0021	0.00096	190	190	240	520

Mixer/Loader/Applicator

Mixing/Loading/Applying Liquids with a Backpack Sprayer (using PHED
liquid low pressure handwand data) (5)	Lakes, ponds	0.68 lb ai/A-ft	2
acres	5 ft	NA	100	0.43	0.37	NF	0.97	0.0042	0.0036	NF	0.51	120	140	NF

	Lakes, ponds	0.54 lb ai/A-ft	2 acres	5 ft	NA	100	0.43	0.37	NF	0.97
0.0042	0.0036	NF	0.51	120	140	NF

	Moving water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft	100
0.43	0.37	NF	0.048	0.00021	0.00018	NF	10	2400	2800	NF

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	100
0.43	0.37	NF	0.039	0.00017	0.00015	NF	13	3000	3400	NF

Mixing/Loading/

Applying Liquids with Closed System Aspirators (PHED: mixing/loading
liquid - closed system) (6)	Lakes, ponds	0.68 lb ai/A-ft	10 acres	5 ft
N/A	N/A	N/A	N/A	0.0086	N/A	N/A	N/A	0.0042	N/A	N/A	N/A	120

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	0.0086	N/A
N/A	N/A	0.0021	N/A	N/A	N/A	240

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	N/A	N/A	N/A	N/A	0.0086	N/A
N/A	N/A	0.0033	N/A	N/A	N/A	150

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	0.0086	N/A
N/A	N/A	0.0017	N/A	N/A	N/A	300

Mixing/Loading/

Applying Liquids with Drip Bars (PHED: mixing/loading liquid) (7)	Moving
water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft	2.9	0.023
0.017	0.0086	0.0014	0.000011	0.0000082	0.0000042	360	45000	61000	120000

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	2.9
0.023	0.017	0.0086	0.0011	0.000009	0.0000067	0.0000034	440	55000	75000
150000

Mixing/Loading/

Applying Wettable Powders with a Backpack Sprayer (using PHED wettable
powder low pressure handwand data) (8)	Lakes, ponds 	0.68 lb ai/A-ft	2
acres	5 ft	NA	ND	8.6	6.2	NF	ND	0.084	0.06	NF	ND	6	8.3	NF

	Lakes, ponds	0.54 lb ai/A-ft	2 acres	5 ft	NA	ND	8.6	6.2	NF	ND	0.084
0.06	NF	ND	6	8.3	NF

	Moving water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft	ND
8.6	6.2	NF	ND	0.0042	0.003	NF	ND	120	170	NF

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	ND
8.6	6.2	NF	ND	0.0034	0.0024	NF	ND	150	210	NF

Mixing/Loading/

Applying Wettable Powders with Closed System Aspirators (PHED:
mixing/loading liquid - closed system) (9)	Lakes, ponds	0.68 lb ai/A-ft
10 acres	5 ft	N/A	N/A	N/A	N/A	0.0098	N/A	N/A	N/A	0.0048	N/A	N/A	N/A	110

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	0.0098	N/A
N/A	N/A	0.0024	N/A	N/A	N/A	210

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	N/A	N/A	N/A	N/A	0.0098	N/A
N/A	N/A	0.0038	N/A	N/A	N/A	130

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	0.0098	N/A
N/A	N/A	0.0019	N/A	N/A	N/A	260

Mixing/Loading/

Applying Wettable Powders with Drip Bars (PHED: mixing/loading liquid)
(10)	Moving water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft
3.7	0.17	0.13	0.0098	0.0018	0.000082	0.000063	0.0000047	280	6100	8000
110000

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	3.7
0.17	0.13	0.0098	0.0015	0.000067	0.000051	0.0000038	340	7500	9800	130000

Mixing/Loading/Applying Wettable Powder Formulations via
Powder/Sand/Gelatin Paste (11)	Seeps and Springs	There is currently no
data to assess this scenario.  HED believes this scenario will result in
minimal exposure due to the amount of rotenone used and the fact that
this paste is typically mixed in either a lab under a fume hood or by an
individual wearing a respirator.

N/A  =  Not Applicable

NF  =  Not Feasible

ND  =  No Data

a	Application rates are the maximum application rates determined from
EPA registered labels for rotenone

	b	Area treated per day values for all application methods except boats
are based on personal contact with Brian Finlayson, California
Department of Fish and Game (1/9/06).  Area treated per 	day values for
boat application methods are based on HED professional judgment.

c	Baseline = long-sleeve shirt, long pants, shoes, socks and no gloves
or no respirator

d	SL, G = baseline attire plus chemical-resistant gloves.

e	DL, G = coveralls worn over long-sleeve shirt and long pants, plus
chemical-resistant gloves.

f	Eng con = closed mixing/loading system or enclosed cockpit.

g	Dermal MOE = NOAEL (0.5 mg/kg/day) / dermal daily dose (mg/kg/day),
where dermal dose = daily unit exposure (mg/lb ai)  x application rate x
amount handled per day  x dermal absorption factor / body weight (70 kg
adult).

Appendix A/Table A3.  Occupational Inhalation Handler Exposure and Risks

Exposure Scenario	Crop or Target	Application  Ratea	Area Treated Dailyb
Depth of Water Bodyb	Width of Water Bodyb	Inhalation Unit Exposure
(ug/lb ai)	Inhalation Dose (mg/kg/day)	Inhalation MOEg

Baselinec	80% Rd	90% Re	Eng Conf	Basec	80% Rd	90% Re	Eng Conf	Basec	80%

PPE-Rd	90% PPE-Re	Eng Conf

Mixer/Loader

Mixing/Loading Liquid Concentrates for Helicopter Applications (1a)
Lakes, ponds	0.68 lb ai/A-ft	10 acres	5 ft	NA	1.2	0.24	0.12	0.083
0.00058	0.00012	0.000058	0.00004	860	4300	8600	12000

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	NA	1.2	0.24	0.12	0.083
0.00029	0.000058	0.000029	0.00002	1700	8600	17000	25000

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	NA	1.2	0.24	0.12	0.083
0.00046	0.000093	0.000046	0.000032	1100	5400	11000	16000

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	NA	1.2	0.24	0.12	0.083
0.00023	0.000046	0.000023	0.000016	2200	11000	22000	31000

Mixing/Loading Liquid Concentrates for Boat Applications (2a)	Lakes,
ponds	0.68 lb ai/A-ft	100 acres	5 ft	NA	1.2	0.24	0.12	0.083	0.0058
0.0012	0.00058	0.0004	86	430	860	1200

	Lakes, ponds	0.68 lb ai/A-ft	50 acres	5 ft	NA	1.2	0.24	0.12	0.083
0.0029	0.00058	0.00029	0.0002	170	860	1700	2500

	Lakes, ponds	0.54 lb ai/A-ft	100 acres	5 ft	NA	1.2	0.24	0.12	0.083
0.0046	0.00093	0.00046	0.00032	110	540	1100	1600

	Lakes, ponds	0.54 lb ai/A-ft	50 acres	5 ft	NA	1.2	0.24	0.12	0.083
0.0023	0.00046	0.00023	0.00016	220	1100	2200	3100

Mixing/Loading Wettable Powders for Boat Applications (2a)	Lakes, ponds
0.68 lb ai/A-ft	100 acres	5 ft	NA	43	8.6	4.3	0.24	0.21	0.042	0.021
0.0012	2.4	12	24	430

	Lakes, ponds	0.68 lb ai/A-ft	50 acres	5 ft	NA	43	8.6	4.3	0.24	0.1	0.021
0.01	0.00058	4.8	24	48	860

	Lakes, ponds	0.54 lb ai/A-ft	100 acres	5 ft	NA	43	8.6	4.3	0.24	0.17
0.033	0.017	0.00093	3	15	30	540

	Lakes, ponds	0.54 lb ai/A-ft	50 acres	5 ft	NA	43	8.6	4.3	0.24	0.083
0.017	0.0083	0.00046	6	30	60	1100

Applicator

Applying Sprays via Helicopter (3)	Lakes, ponds	0.68 lb ai/A-ft	10 acres
5 ft	NA	ND	ND	ND	0.068	ND	ND	ND	0.000033	ND	ND	ND	15000

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	NA	ND	ND	ND	0.068	ND	ND	ND
0.000017	ND	ND	ND	30000

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	NA	ND	ND	ND	0.068	ND	ND	ND
0.000026	ND	ND	ND	19000

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	NA	ND	ND	ND	0.068	ND	ND	ND
0.000013	ND	ND	ND	38000

Applying Sprays via Boat Over-surface Boom Equipment (4)	Lakes, ponds
0.68 lb ai/A-ft	100 acres	5 ft	NA	0.74	0.148	0.074	0.043	0.0036	0.00072
0.00036	0.00021	140	700	1400	2400

	Lakes, ponds	0.68 lb ai/A-ft	50 acres	5 ft	NA	0.74	0.148	0.074	0.043
0.0018	0.00036	0.00018	0.0001	280	1400	2800	4800

	Lakes, ponds	0.54 lb ai/A-ft	100 acres	5 ft	NA	0.74	0.148	0.074	0.043
0.0029	0.00057	0.00029	0.00017	180	880	1800	3000

	Lakes, ponds	0.54 lb ai/A-ft	50 acres	5 ft	NA	0.74	0.148	0.074	0.043
0.0014	0.00029	0.00014	0.000083	350	1800	3500	6000

Mixer/Loader/Applicator

Mixing/Loading/Applying Liquids with a Backpack Sprayer (using PHED
liquid low pressure handwand data) (5)	Lakes, ponds	0.68 lb ai/A-ft	2
acres	5 ft	NA	30	6	3	NF	0.0029	0.00058	0.00029	NF	170	860	1700	NF

	Lakes, ponds	0.54 lb ai/A-ft	2 acres	5 ft	NA	30	6	3	NF	0.0029	0.00058
0.00029	NF	170	860	1700	NF

	Moving water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft	30
6	3	NF	0.00014	0.000029	0.000014	NF	3500	17000	35000	NF

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	30
6	3	NF	0.00012	0.000024	0.000012	NF	4200	21000	42000	NF

Mixing/Loading/

Applying Liquids with Closed System Aspirators (PHED: mixing/loading
liquid - closed system) (6)	Lakes, ponds	0.68 lb ai/A-ft	10 acres	5 ft
N/A	N/A	N/A	N/A	0.083	N/A	N/A	N/A	0.0004	N/A	N/A	N/A	1200

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	0.083	N/A	N/A
N/A	0.0002	N/A	N/A	N/A	2500

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	N/A	N/A	N/A	N/A	0.083	N/A
N/A	N/A	0.00032	N/A	N/A	N/A	1600

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	0.083	N/A	N/A
N/A	0.00016	N/A	N/A	N/A	3100

Mixing/Loading/

Applying Liquids with Drip Bars (PHED: mixing/loading liquid) (7)	Moving
water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft	1.2	0.24
0.12	0.083	0.0000058	0.0000012	0.00000058	0.0000004	86000	430000	860000
1200000

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	1.2
0.24	0.12	0.083	0.0000047	0.00000094	0.00000047	0.00000033	110000	530000
1100000	1500000

Mixing/Loading/

Applying Wettable Powders with a Backpack Sprayer (using PHED wettable
powder low pressure handwand data) (8)	Lakes, ponds 	0.68 lb ai/A-ft	2
acres	5 ft	NA	1100	220	110	NF	0.11	0.021	0.011	NF	4.7	23	47	NF

	Lakes, ponds	0.54 lb ai/A-ft	2 acres	5 ft	NA	1100	220	110	NF	0.11	0.021
0.011	NF	4.7	23	47	NF

	Moving water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft
1100	220	110	NF	0.0053	0.0011	0.00053	NF	94	470	940	NF

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft
1100	220	110	NF	0.0043	0.00086	0.00043	NF	120	580	1200	NF

Mixing/Loading/

Applying Wettable Powders with Closed System Aspirators (PHED:
mixing/loading liquid - closed system) (9)	Lakes, ponds	0.68 lb ai/A-ft
10 acres	5 ft	N/A	N/A	N/A	N/A	0.24	N/A	N/A	N/A	0.0012	N/A	N/A	N/A	430

	Lakes, ponds	0.68 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	0.24	N/A	N/A
N/A	0.00058	N/A	N/A	N/A	860

	Lakes, ponds	0.54 lb ai/A-ft	10 acres	5 ft	N/A	N/A	N/A	N/A	0.24	N/A	N/A
N/A	0.00093	N/A	N/A	N/A	540

	Lakes, ponds	0.54 lb ai/A-ft	5 acres	5 ft	N/A	N/A	N/A	N/A	0.24	N/A	N/A
N/A	0.00046	N/A	N/A	N/A	1100

Mixing/Loading/

Applying Wettable Powders with Drip Bars (PHED: mixing/loading liquid)
(10)	Moving water (streams)	0.000016 lb ai/ft3	10,560 ft long	2 ft	10 ft
43	8.6	4.3	0.24	0.00021	0.000042	0.000021	0.0000012	2400	12000	24000
430000

	Moving water (streams)	0.000013 lb ai/ft3	10,560 ft long	2 ft	10 ft	43
8.6	4.3	0.24	0.00017	0.000034	0.000017	0.00000094	3000	15000	30000
530000

Mixing/Loading/Applying Wettable Powder Formulations via
Powder/Sand/Gelatin Paste (11)	Seeps and Springs	There is currently no
data to assess this scenario.  HED believes this scenario will result in
minimal exposure due to the amount of rotenone used and the fact that
this paste is typically mixed in either a lab under a fume hood or by an
individual wearing a respirator.

N/A  =  Not Applicable

NF  =  Not Feasible

ND  =  No Data

a	Application rates are the maximum application rates determined from
EPA registered labels for rotenone

b	Area treated per day values for all application methods except boats
are based on personal contact with Brian Finlayson, California
Department of Fish and Game (1/9/06).  Area treated per day values for
boat application methods are based on HED professional judgment.

c	Baseline is no respirator

d	80% Respirator is quarter-face dust/mist respirator (that provides an
80% protection factor).

e	90% Respirator is half-face dust/mist respirator (that provides a 90%
protection factor).

f	Engineering control is closed mixing/loading system or enclosed
cockpit.

g	Inhalation MOE = NOAEL (0.5 mg/kg/day) / inhalation daily dose
(mg/kg/day), where inhalation dose = daily unit exposure (mg/lb ai)  x
application rate x amount handled per day  / body weight (70 kg adult).

Appendix B: Residential Postapplication ExposureAppendix B/Table B1.
Postapplication Dermal Dose from Swimming in Rotenone Treated Waters

	250 ppb	200 ppb

Concentration range of ai in lakes/ponds (mg/L)	Cw	0.25	0.2

Log Kp = -2.72 + (0.71 x log Kow) - 0.0061 x MW

	Log Kow

4.10

Kow

12589

Molecular weight of substance (g/mol)	MWs	394.4

Log Kp

-2.21

Kp (cm/hr)

6.10E-03

	PDR = Cw x SA x ET x Kp x CF1

Concentration range of ai in lakes/ponds (mg/L)	Cw	0.25	0.2

	Surface area exposed (cm2)	SA

   adults (males and females)

18200	18200

   children (2-6yrs of age)

7210	7210

	Exposure time (hr/day)	ET

   adult

1	1

   children (2-6yrs of age)

1	1

	Permeability coefficient (cm/hr)	Kp	6.10E-03	6.10E-03

	Conversion factor (L/cm3)	CF1	0.001	0.001

	Body weight (kg)	BW

     all adults

70	70

   children (2-6yrs of age)

17	17

	Adult dose (mg/kg-day)	PDR	0.0004	0.0003

Children (2-6yrs old) dose (mg/kg-day)	PDR	0.0006	0.0005

	NOAEL mg/kg/day	0.5

	Adult dose MOE

1300	1600

Children (2-6yrs old) dose MOE

770	970

Appendix B/Table B2.  Postapplication Dermal Dose from Ingesting
Rotenone Treated Waters

	250 ppb	200 ppb

Concentration range of ai in lakes/ponds (mg/L)	Cw	0.25	0.2

	Ingestion rate of water (L/hr)

	   adults (males and females)

0.025	0.025

   children (2-6yrs of age)

0.05	0.05

	Exposure time (hr/day)	ET

   adult

1	1

   children (2-6yrs of age)

1	1

	Body weight (kg)	BW

     all adults

70	70

   children (2-6yrs of age)

17	17

	Adult dose (mg/kg-day)	PDR	0.00009	0.00007

Children (2-6yrs old) dose (mg/kg-day)	PDR	0.00074	0.00059

	NOAEL mg/kg/day	0.5

	Adult dose MOE

5600	7000

Children (2-6yrs old) dose MOE

680	850

 Clark NWE, Scott RC, Blain PG, Williams FM (1993). Fate of
fluazifop-butyl in rat and human skin in vitro. Arch Toxicol. 67:44-48.

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trichloroethylene levels to exceed the MCL after applications of
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the impurities that may be present by any route of exposure.

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