shrubs, trees) 0.25 40 26000 26000 27000 71000 92000 81000 110000 220000 turf ( sod farm) 0.64 80 5000 5000 5200 14000 18000 16000 21000 43000 Applying Sprays via Groundboom Equipment ( cont.) turf ( golf course) 0.64 40 10000 10000 10000 28000 36000 32000 42000 85000 apples, Christmas trees, pears 0.25 40 2600 3100 3200 5800 6600 6200 7100 34000 pine seedlings 0.5 40 1300 1600 1600 2900 3300 3100 3500 17000 grapes 0.188 40 3400 4100 4300 7800 8700 8300 9400 45000 Applying Sprays via Airblast Equipment grapes, raspberries 0.125 40 5100 6200 6400 12000 13000 12000 14000 68000 Page 65 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh turf ( LCO) 5.4 ( CA only) 5 No Data 1500 2300 1800 1900 3200 3300 No Data turf ( LCO) 2.7 ( except CA) 5 No Data 3000 4500 3700 3800 6300 6600 No Data turf ( LCO) 1.3 ( Bayer:

max residential) 5 No Data 6200 9400 7700 7900 13000 14000 No Data Applying Sprays via Handgun Equipment turf ( LCO) 0.64 5 No Data 13000 19000 16000 16000 27000 28000 No Data turf (

rightsof way) 5.4 ( CA only) 80 26 61 71 93 99 120 130 No Data turf (

rightsof way) 2.7 ( except CA) 80 52 120 140 190 200 240 260 No Data turf (

rightsof way) 1.3 ( Bayer:

max residential) 80 110 250 300 390 410 500 540 No Data Applying Sprays via Rights of Way Equipment turf (

rightsof way) 0.64 80 220 510 600 780 840 1000 1100 No Data Page 66 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh turf ( sod farm) 5.2 ( CA only) 80 430 440 460 1700 2700 1900 3300 2300 turf ( sod farm) 2.6 ( except CA) 80 860 880 910 3400 5300 3900 6500 4600 turf ( sod farm) 1.36 ( Bayer:

max residential) 80 1600 1700 1700 6500 10000 7400 12000 8800 turf ( golf course) 5.2 ( CA only) 40 860 880 910 3400 5300 3900 6500 4600 turf ( golf course) 2.6 ( except CA) 40 1700 1800 1800 6800 11000 7700 13000 9200 Applying Granulars via Tractor Drawn Spreader turf ( golf course) 1.36 ( Bayer:

max residential) 40 3300 3400 3500 13000 20000 15000 25000 18000 Page 67 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh Flagger apples, Christmas trees, pears 0.25 350 5500 No Data 5600 No Data No Data 13000 16000 270000 grapes 0.125 350 11000 No Data 11000 No Data No Data 27000 33000 550000 grapes 0.188 350 7300 No Data 7500 No Data No Data 18000 22000 370000 turf ( sod farm) 5.4 ( CA only) 350 250 No Data 260 No Data No Data 620 750 13000 turf ( sod farm) 2.7 ( except CA) 350 510 No Data 520 No Data No Data 1200 1500 25000 turf ( sod farm) 1.3 ( Bayer:

max residential) 350 1100 No Data 1100 No Data No Data 2600 3100 53000 Flagging for Aerial Sprays Applications pine seedlings 0.5 350 2700 No Data 2800 No Data No Data 6700 8100 140000 turf ( sod farm) 5.2 ( CA only) 350 700 No Data 760 No Data No Data 2600 3600 35000 turf ( sod farm) 2.6 ( except CA) 350 1400 No Data 1500 No Data No Data 5100 7200 70000 Flagging for Aerial Granular Applications turf ( sod farm) 1.36 ( Bayer:

max residential) 350 2700 No Data 2900 No Data No Data 9800 14000 130000 Page 68 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh Mixer/ Loader/ Applicator greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00938 lb ai/ gallon 40 gallons 3200 90000 No Data 130000 140000 No Data No Data Not Feasible ornamentals ( flowering,

shrubs, trees);

Pines ( Christmas trees) 0.0023 lb ai/ gallon 40 gallons 13000 370000 No Data 530000 560000 No Data No Data Not Feasible roses 0.00029 lb ai/ gallon 40 gallons 100000 2900000 No Data 4200000 4400000 No Data No Data Not Feasible turf ( LCO &

golf course) 5.4 ( CA only) 5 44 1200 No Data 1800 1900 No Data No Data Not Feasible turf ( LCO &

golf course) 2.7 ( except CA) 5 88 2500 No Data 3600 3800 No Data No Data Not Feasible turf ( LCO &

golf course) 1.3 ( Bayer:

max residential) 5 180 5200 No Data 7500 7900 No Data No Data Not Feasible turf ( LCO &

golf course) 0.64 5 370 11000 No Data 15000 16000 No Data No Data Not Feasible Mixing/ Loading / Applying Liquid Concentrates with Low Pressure Handwand ( ORETF) grapes 0.125 lb ai/ gallon 40 gallons 240 6700 No Data 9700 10000 No Data No Data Not Feasible Page 69 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh apples 0.00062 lb ai/ gallon 40 gallons No Data 7900 8100 29000 43000 32000 50000 Not Feasible azaleas 0.005 lb ai/ gallon 40 gallons No Data 980 1000 3600 5300 3900 6200 Not Feasible grapes 0.00094 lb ai/ gallon 40 gallons No Data 5200 5400 19000 28000 21000 33000 Not Feasible greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00625 lb ai/ gallon 40 gallons No Data 780 810 2900 4300 3200 5000 Not Feasible turf ( LCO &

golf course) 5.4 ( CA only) 5 No Data 7.3 7.5 26 39 29 46 Not Feasible turf ( LCO &

golf course) 2.7 ( except CA) 5 No Data 15 15 53 79 58 92 Not Feasible turf ( LCO &

golf course) 1.3 ( Bayer:

max residential) 5 No Data 30 31 110 160 120 190 Not Feasible turf ( LCO &

golf course) 0.64 5 No Data 61 63 220 330 250 390 Not Feasible ornamentals ( flowering,

shrubs, trees) 0.0025 lb ai/ gallon 40 gallons No Data 2000 2000 7100 11000 7900 12000 Not Feasible pears 0.00062 lb ai/ gallon 40 gallons No Data 7900 8100 29000 43000 32000 50000 Not Feasible Mixing/ Loading / Applying Wettable Powders with Low Pressure Handwand ( PHED) pine seedlings 0.5 5 No Data 78 81 290 430 320 500 Not Feasible Page 70 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh azaleas 0.005 lb ai/ gallon 40 gallons 5900 170000 No Data 240000 260000 No Data No Data Not Feasible ornamentals ( flowering,

shrubs, trees) 0.0025 lb ai/ gallon 40 gallons 12000 340000 No Data 490000 510000 No Data No Data Not Feasible turf ( LCO &

golf course) 5.4 ( CA only) 5 44 1200 No Data 1800 1900 No Data No Data Not Feasible turf ( LCO &

golf course) 2.7 ( except CA) 5 88 2500 No Data 3600 3800 No Data No Data Not Feasible turf ( LCO &

golf course) 1.3 ( Bayer:

max residential) 5 180 5200 No Data 7500 7900 No Data No Data Not Feasible Mixing/ Loading / Applying Dry Flowables with Low Pressure Handwand ( using liquids ORETF data) turf ( LCO &

golf course) 0.64 5 370 11000 No Data 15000 16000 No Data No Data Not Feasible greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00938 lb ai/ gallon 1000 gallons No Data 3400 5400 4000 4200 7000 7500 Not Feasible ornamentals ( flowering,

shrubs, trees);

Pines ( Christmas trees) 0.0023 lb ai/ gallon 1000 gallons No Data 14000 22000 16000 17000 29000 31000 Not Feasible Mixing/ Loading / Applying Liquid Concentrates with a Handgun Sprayer ( LCO ORETF data) roses 0.00029 lb ai/ gallon 1000 gallons No Data 110000 170000 130000 130000 230000 240000 Not Feasible Page 71 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh turf 5.4 ( CA only) 5 No Data 1200 1900 1400 1400 2400 2600 Not Feasible turf 2.7 ( except CA) 5 No Data 2400 3700 2800 2900 4900 5200 Not Feasible turf 1.3 ( Bayer:

max residential) 5 No Data 4900 7700 5800 6000 10000 11000 Not Feasible Mixing/ Loading / Applying Liquid Concentrates with a Handgun Sprayer ( LCO ORETF data)

( cont) turf 0.64 5 No Data 10000 16000 12000 12000 21000 22000 Not Feasible apples 0.00062 lb ai/ gallon 1000 gallons No Data 5100 5500 16000 23000 21000 32000 Not Feasible grapes 0.00094 lb ai/ gallon 1000 gallons No Data 3400 3600 11000 15000 14000 21000 Not Feasible pine seedlings 0.5 5 No Data 1300 1400 4100 5600 5100 7900 Not Feasible turf 5.4 ( CA only) 5 No Data 120 130 380 520 480 730 Not Feasible turf 2.7 ( except CA) 5 No Data 240 250 750 1000 950 1500 Not Feasible turf 1.3 ( Bayer:

max residential) 5 No Data 490 530 1600 2200 2000 3000 Not Feasible Mixing/ Loading / Applying Wettable Powders with a Handgun Sprayer ( LCO ORETF data) turf 0.64 5 No Data 1000 1100 3200 4400 4000 6200 Not Feasible Page 72 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00625 lb ai/ gallon 1000 gallons No Data 2400 3100 3800 4100 6000 6800 Not Feasible turf ( LCO &

golf course) 5.4 ( CA only) 5 No Data 560 730 890 960 1400 1600 Not Feasible turf ( LCO &

golf course) 2.7 ( except CA) 5 No Data 1100 1500 1800 1900 2800 3100 Not Feasible turf ( LCO &

golf course) 1.3 ( Bayer:

max residential) 5 No Data 2300 3000 3700 4000 5800 6500 Not Feasible turf ( LCO &

golf course) 0.64 5 No Data 4700 6200 7500 8100 12000 13000 Not Feasible Mixing/ Loading / Applying Water Soluble Bags with Handgun Sprayer ( LCO ORETF data) pine seedlings 0.5 5 No Data 6100 7900 9600 10000 15000 17000 Not Feasible turf ( LCO &

golf course) 5.4 ( CA only) 5 No Data 300 330 730 890 1000 1300 Not Feasible turf ( LCO &

golf course) 2.7 ( except CA) 5 No Data 590 670 1500 1800 2000 2700 Not Feasible turf ( LCO &

golf course) 1.3 ( Bayer:

max residential) 5 No Data 1200 1400 3000 3700 4200 5600 Not Feasible Mixing/ Loading / Applying Dry Flowables Concentrates with a Handgun Sprayer ( LCO ORETF data) turf ( LCO &

golf course) 0.64 5 No Data 2500 2800 6200 7500 8500 11000 Not Feasible Page 73 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00938 lb ai/ gallon 1000 gallons No Data 170 180 440 560 560 770 Not Feasible ornamentals ( flowering,

shrubs, trees) 0.0023 lb ai/ gallon 1000 gallons No Data 680 730 1800 2300 2300 3100 Not Feasible Mixing/ Loading / Applying Liquid Concentrates with a High Pressure Handwand ( only study in PHED is for greenhouse use) roses 0.00029 lb ai/ gallon 1000 gallons No Data 5400 5800 14000 18000 18000 25000 Not Feasible azaleas 0.005 lb ai/ gallon 1000 gallons No Data 310 340 830 1100 1100 1400 Not Feasible Mixing/ Loading / Applying Dry Flowables with a High Pressure Handwand ( only study in PHED is for greenhouse use for liquid concentrates) ornamentals ( flowering,

shrubs, trees) 0.0025 lb ai/ gallon 1000 gallons No Data 620 670 1700 2100 2100 2900 Not Feasible Page 74 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh ornamentals ( flowering,

shrubs, trees) 0.0025 lb ai/ gallon 1000 gallons No Data 620 670 1700 2100 2100 2900 Not Feasible azaleas 0.005 lb ai/ gallon 1000 gallons No Data 310 340 830 1100 1100 1400 Not Feasible Mixing/ Loading / Applying Wettable Powders with a High Pressure Handwand ( only study in PHED is for greenhouse use for liquid concentrates) greenhouse ornamentals ( flowering,

shrubs, trees)

( non WPS) 0.00625 lb ai/ gallon 1000 gallons No Data 250 270 670 850 840 1100 Not Feasible Mixing/ Loading / Applying Liquids with an Injector ornamentals ( shade trees,

woody shrubs) 0.000075 lb ai/ 1 inch of trunk circumfere nce inch of trunk circumfe rence No Data No Data No Data No Data No Data No Data No Data Not Feasible Mixing/ Loading / Applying RTU Briquette pine seedlings 0.00019 lb ai/ seedling seedlings No Data No Data No Data No Data No Data No Data No Data Not Feasible pine seed ( nurseries) 0.0000625 lb ai/ gallon 100 gallons No Data No Data No Data No Data No Data No Data No Data No Data Mixing/ Loading / Applying Dip pineapple ( post harvest) 0.0028 lb ai/ gallon 100 gallons No Data No Data No Data No Data No Data No Data No Data No Data Page 75 of 114 Table 7b. Combined Dermal plus Inhalation Handler Risks for Agricultural and Commercial Uses ( other than Seed Treatment Uses) Combined MOEsi Exposure Scenario Crop or Target App Rate ( lb ai/ acre) a Area Treated Daily ( acre) b Baselinec Dermal + Baseline Inh Single layer w/

glovesd Dermal +

Baseline Inh Double layer w/

glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Single layer w/

gloves Dermal +

90% Rg Inh Double layer w/

gloves Dermal +

80% R Inh Double layer w/

gloves Dermal +

90% R Inh Eng Controlh Dermal + Inh turf ( golf course) 5.2 ( CA only) 5 770 900 1000 2100 2500 3100 4200 Not Feasible turf ( golf course) 2.6 ( except CA) 5 1500 1800 2100 4200 5000 6300 8400 Not Feasible Loading/ Applying Granulars via Push Type Spreader ( ORETF) turf ( golf course) 1.36 ( Bayer:

max residential) 5 2900 3400 4000 8000 9600 12000 16000 Not Feasible a Application rates are the maximum application rates determined from EPA registered labels for triadimefon.

b Amount handled per day values are HED estimates of acres treated per day based on Exposure SAC SOP # 9 " Standard Values for Daily Acres Treated in Agriculture," industry sources, and HED estimates.

c Baseline = No gloves and no respirator d Single layer w/ gloves is baseline attire plus chemical resistant gloves.

e Double layer w/ gloves is coveralls worn over long sleeve shirt and long pants, plus chemical resistant gloves ( with headgear).

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

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

h Engineering control is closed mixing/ loading system, enclosed cab, or enclosed cockpit.

i Combined MOEs = 1/[( 1/ Dermal MOE) + (/ Inhalation MOE)] Page 76 of 114 Table 8a. Handler Exposures and Risks from On Nursery Seed Planter Box/ Hopper Box Treatments Unit Exposures MOEs Baseline Personal Protective Equipment Engineering Controls Baseline Personal Protective Equipment Dermal ( mg/ lb ai) Inhalation ( µ g/ lb ai) Dermal Inhalation Crop Acres treated/

day App Rate ( lb ai/

100 lb) a Amount Handled per dayb ( lb ai/ day) Dermalc ( mg/ lb ai) Inhalationd ( µ g/ lb ai) SL w/ glovese 80% Rf 90% Rg Dermalh ( mg/ lb ai) Inhalationi ( µ g/ lb ai) Inhalation SL w/ gloves 80% R 90% R LOADING/ APPLYING WITH HOPPER OR PLANTER BOX SEED TREATMENT Pinej Seed ( WP)

( S 1) 80 0.0013 0.13 No Data 1.2 12.6 0.24 0.12 No Data No Data 1500 11000 7600 15000 LOADING/ PLANTING PREVIOUSLY TREATED SEEDS Pine Seed ( WP)

( S 2) 80 0.0013 0.13 No Data 3.4 0.25 0.68 0.34 No Data No Data 540 550000 2700 5400 a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day calculated from the acres treated/ day and the maximum lb of seed planted per acre: for ponderosa seed  1.25 lb/ A.

c Baseline Dermal: Long sleeve shirt, long pants, no gloves.

d Baseline Inhalation: no respirator.

e PPE Dermal SL with gloves: Single layer plus chemical resistant gloves.

f PPE 80% R inhalation: assumes a dust/ mist removing quarter face style respirator providing an 80% protection factor.

g PPE 90% R inhalation: assumes a dust/ mist removing half face style respirator providing a 90% protection factor.

h Eng Controls Dermal: Closed System.

i Eng Controls Inhalation: Closed System.

j Ponderosa pine seeds used. Page 77 of 114 Table 8b. Combined Handler Risks from On Nursery Seed Planter Box/ Hopper Box Treatments Combined MOEsi Crop Acres treated/

day App Ratea ( lb ai/ lb) Amount Handled per dayb ( lb ai/ day) Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/ glovese Dermal +

Baseline Inh Single layer w/ gloves Dermal +

80% Rf Inh Double layer w/ gloves Dermal +

80% R Inh Single layer w/ gloves Dermal +

90% Rg Inh Double layer w/ gloves Dermal +

90% R Inh Eng Controlh Dermal +

Inh LOADING/ APPLYING WITH HOPPER OR PLANTER BOX SEED TREATMENT Pine Seedj ( S 1) 80 0.0013 0.129840019 No Data 1300 No Data 4500 No Data 6400 No Data No Data LOADING/ PLANTING PREVIOUSLY TREATED SEEDS Pine Seedj ( S 2) 80 0.0013 0.129840019 No Data 540 No Data 2700 No Data 5300 No Data No Data a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day calculated from the acres treated/ day and the maximum lb of seed planted per acre: for ponderosa seed  1.25 lb/ A.

c Baseline = No gloves and no respirator d Single layer w/ gloves is baseline attire plus chemical resistant gloves.

e Double layer w/ gloves is coveralls worn over long sleeve shirt and long pants, plus chemical resistant gloves.

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

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

h Engineering control is closed mixing/ loading system, enclosed cab, or enclosed cockpit.

i Combined MOEs = 1/[( 1/ Dermal MOE) + (/ Inhalation MOE)]

j Ponderosa pine seeds used. Page 78 of 114 Table 9. Handler Exposure and Risk from On Nursery Cement Mixer Seed Treatments Baseline MOEs Exposure Scenario Crop or Target Application Rate ( lb ai/ acre) a Area Treated Daily ( acres) b Dermalc Inhalationd Baseline Dermal + Baseline Inhalation e 500 7500 8500 4000 Loading/ applying wettable powders using cement mixer equipment ( PHED) ( S 3) 1000 3700 4300 2000 500 420000 480000 220000 Loading/ applying dry flowables using cement mixer equipment ( PHED) ( S 4) 1000 210000 240000 110000 Drying/ raking/ bagging treated seed ( S 5) ponderosa seed 0.0013 1000 No Data No Data No data a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day values are the range of acres treated daily provided by Bayer CropScience in a memo to EPA dated 4/ 13/ 06. c Baseline Dermal: Long sleeve shirt, long pants, no gloves. d Baseline Inhalation: no respirator. e Combined MOEs = 1/[( 1/ Dermal MOE) + (/ Inhalation MOE)] Page 79 of 114 Table 10a. Handler Exposure and Risk from Commercial Seed Treatments Unit Exposures MOEs Baseline Personal Protective Equipment Engineering Controls Baseline Personal Protective Equipment Engineering Controls Dermal ( mg/ lb ai) Inhalation ( µ g/ lb ai) Dermal Inhalation Crop Exposure Scenario AR ( lb ai/ 100 lb) a Amount Handled per day ( lb ai/ day) b Dermalc ( mg/ lb ai) Inhd ( µ g/ lb ai) SL w/ glovese DL w/ glovesf 80% Rg 90% Rh Dermali ( mg/ lb ai) Inhj ( µ g/ lb ai) Dermal Inh SL w/ gloves DL w/ gloves 80% R 90% R Dermal Inh Loader/ Applicator ( S 6) 0.13 16.23 No Data 0.34 0.023 0.18 0.068 0.034 No Data No Data No Data 43 48,000 62,000 220 430 No Data No Data Sewer ( S 7) 0.13 16.23 0.0062 0.23 No Data No Data No Data No Data No Data No Data 180000 64 No Data No Data 320 640 No Data No Data Bagger ( S 8) 0.13 16.23 0.0091 0.16 No Data No Data No Data No Data No Data No Data 120000 92 No Data No Data 460 920 No Data No Data Pinek Seeds Multiple Activitiesl ( S 9) 0.13 16.23 No Data 1.6 0.042 No Data No Data No Data No Data No Data No Data 9.2 26000 No Data 46 92 No Data No Data a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day calculated from the maximum application rate and the lbs of seed treated or planted/ day and: for ponderosa seed  12485 lb/ day.

c Baseline Dermal: Long sleeve shirt, long pants, no gloves.

d Baseline Inhalation: no respirator.

e PPE Dermal SL with gloves: Single layer plus chemical resistant gloves.

f PPE Dermal DL and gloves: Coveralls worn over long sleeve shirt and long pants plus chemical resistant gloves.

g PPE 80% R inhalation: assumes a dust/ mist removing quarter face style respirator providing an 80% protection factor.

h PPE 90% R inhalation: assumes a dust/ mist removing half face style respirator providing a 90% protection factor.

i Eng Controls Dermal: Closed System j Eng Controls Inhalation: Closed System.

k Ponderosa pine seeds used. Page 80 of 114 Table 10b. Combined Handler Dermal and Inhalation Risk from Commercial Seed Treatments Combined MOEsi Pine Seed Exposure Scenario App Ratea ( lb ai/ lb) Amount Handled per day b ( lb ai/ day) Baselinec Dermal +

Baseline Inh Single layer w/ glovesd Dermal +

Baseline Inh Double layer w/ glovese Dermal +

Baseline Inh Baseline Dermal +

80% Rf Inh Single layer w/ gloves Dermal+

80% R Inh Baseline Dermal +

90% Rf Inh Single layer w/ gloves Dermal +

90% Rg Inh Eng Controlh Dermal +

Inh Loader/ Applicator ( S 6) 0.0013 16.23 No Data 43 43 No Data 220 No Data 430 No Data Sewer ( S 7) 0.0013 16.23 64 No Data No Data 320 No Data 640 No Data No Data Bagger ( S 8) 0.0013 16.23 92 No Data No Data 460 No Data 910 No Data No Data Ponderosa Seedj Multiple Activitiesl ( S 9) 0.0013 16.23 No Data 9.2 No Data No Data 46 No Data 91 No Data a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day calculated from the maximum application rate and the lbs of seed treated or planted/ day and: for ponderosa seed  12485 lb/ day.

c Baseline = No gloves and no respirator d Single layer w/ gloves is baseline attire plus chemical resistant gloves.

e Double layer w/ gloves is coveralls worn over long sleeve shirt and long pants, plus chemical resistant gloves.

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

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

h Engineering control is closed mixing/ loading system, enclosed cab, or enclosed cockpit.

i Combined MOEs = 1/[( 1/ Dermal MOE) + (/ Inhalation MOE)]

j Ponderosa pine seeds used. Page 81 of 114 2.1.3 Cancer Triadimefon Handler Exposure and Risk Assessment No cancer endpoints of concern for triadimefon were identified; therefore, cancer risks to handlers were not assessed.

2.1.4 Summary of Risk Concerns and Data Gaps for Occupational Handlers There are several occupational handler scenarios for triadimefon that have risks associated with them that are above HED's level of concern for risk assessments, even at the highest level of risk mitigation. However, there are also some occupational handler scenarios for triadimefon that have data gaps.

<IP_ADDRESS> Summary of Risk Concerns The short and intermediate term dermal plus inhalation handler risk assessment for triadimefon indicates risk concerns for a few handler scenarios, even with maximum risk mitigation. See Section <IP_ADDRESS> for a detailed summary.

<IP_ADDRESS> Summary of Data Gaps Several data gaps were identified for triadimefon in many different use areas that include:

  mixing/ loading/ applying dry flowables using a low pressure handwand sprayer ( data for liquid formulations was used as a surrogate),   mixing/ loading/ applying wettable powders using a high pressure handwand sprayer ( data for liquid formulations was used as a surrogate),   mixing/ loading/ applying dry flowables using a high pressure handwand sprayer ( data for liquid formulations was used as a surrogate),   mixing/ loading/ applying liquid concentrates for tree injection ( no surrogate available),   mixing/ loading/ applying ready to use briquettes for pine seedlings ( no surrogate available), and   mixing/ loading/ applying dip to pine seeds and postharvest pineapples ( no surrogate available).

2.1.5 Recommendations for Refining Occupational Handler Risk Assessment In order to refine this occupational risk assessment, data on actual use patterns including rates, timing, and areas treated would better characterize triadimefon risks. Exposure studies for many equipment types that lack data or that are not well represented in PHED ( e. g., because of low replicate numbers or data quality) should also be considered based on the data gaps identified above and based on a review of the quality of the data used in this assessment. Page 82 of 114 2.2 Occupational Postapplication Exposures and Risks 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 ( also referred to as reentry exposure). HED believes that there are distinct job functions or tasks related to the kinds of activities that occur in previously treated areas. Job requirements ( e. g., the kinds of jobs to cultivate a crop), the nature of the crop or target that was treated, and how the chemical residues degrade in the environment can cause exposure levels to differ over time. Each factor has been considered in this assessment.

2.2.1 Occupational Postapplication Exposure Scenarios Triadimefon can be used on agricultural crops ( ornamental, and turf) and in outdoor occupational settings. As a result, a wide array of individuals can potentially be exposed by working in areas that have been previously treated. HED is concerned about the kinds of exposures one could receive in the workplace. Triadimefon is applied to the following crops that are subject to the Worker Protection Standard for Agricultural Pesticides:

  grapes,   turf, including sod farm turf   ornamentals,   apples,   pears,   Christmas trees, and   raspberries.

HED uses a concept known as the transfer coefficient to numerically represent the postapplication exposures one would receive ( generally presented as cm2/ hour). The transfer coefficient concept has been established in the scientific literature and through various exposure monitoring guidelines published by the U. S. EPA and international organizations such as Health Canada and the Organization for Economic Cooperation and Development. The establishment of transfer coefficients also forms the basis of the work of the Agricultural Reentry Task Force. A transfer coefficient is a measure of the residue transferred from a treated surface to a person who is doing a task or activity in a treated area. These values are the ratio of an exposure for a given task or activity to the amount of pesticide residue on treated surfaces available for transfer. HED has developed a series of standard transfer coefficients that are unique for variety of job tasks or activities that are used in lieu of chemical and scenario specific data.

To develop a postapplication assessment, HED considers the types of tasks and activities that individuals are likely to be doing in areas recently treated with a pesticide. For consistency within postapplication assessments, HED has developed a list of tasks commonly associated with specific crops or use patterns, which are likely to result in postapplication exposures. Postapplication pesticide exposures that result from an individual's employment are considered occupational exposures. Common examples include: crop harvesting tasks ( e. g., harvesting treated turf), crop maintenance tasks ( e. g., irrigating, weeding, and mowing), and crop advisor tasks ( e. g., scouting). Page 83 of 114 HED considers how and when a pesticide is applied to estimate the level of transferable residues to which individuals could be exposed over time. Label directions and other use data are considered to determine application rates and application frequency. HED completes postapplication risk assessments using maximum application rates for each scenario. When postapplication risks are a concern using maximum application rates, HED may also consider typical application rates or application frequency, to further evaluate the overall risks associated with the use of the pesticide. To estimate the amount of transferable residues on a treated surface, HED uses, when possible, chemical and crop specific studies as described in HED guidelines for exposure data collection ( Series 875, Occupational and Residential Exposure Test Guidelines: Group B  Postapplication Exposure Monitoring Test Guidelines). For postapplication exposures, unique techniques are used to measure the amount of pesticide residue on a treated surface available for possible transfer. These techniques are distinct from those which measure total pesticide residue on a treated surface and absorbed into a treated entity. When appropriate chemical and crop specific transferable residue data are unavailable, HED also has developed a standard modeling approach to predict transferable residues over time ( best described in HED's SOPs for Residential Exposure Assessment). All triadimefon agricultural occupational postapplication scenarios were evaluated using HED's default assumptions that 20 percent of the initial application is available for transfer on day 0 ( i. e., 12 hours after application) and that the residue dissipates at a rate of 10 percent per day. All lawn and turf occupational postapplication scenarios were evaluated using HED's default assumptions that 5 percent of the initial application is available for transfer on day 0 ( i. e., 12 hours after application) and that the residue dissipates at a rate of 10 percent per day.

HED also must consider the likely frequency and duration of postapplication occupational exposures to triadimefon. Short term (< 30 days) always are considered in these assessments. Intermediate term ( greater than 30 days to several months) exposure durations are appropriate for postapplication occupational exposures scenarios where the pesticide is reapplied several times over a growing season, or the pesticide residues persist for relatively long periods of time, or the crop or use pattern is such that occupational postapplication workers may be exposed to several different treated areas in the course of their work. For example, migrant and seasonal workers may move from farm to farm and be exposed several weeks to several months or different fields or greenhouses on an individual establishment may be treated over a period of weeks due to differing levels of infestation or staggered crop cycles. For triadimefon, the exposure durations for postapplication risk assessment were short term (< 30 days) and intermediate term ( greater than 30 days up to several months). However, since the dermal toxicological endpoint of concern is the same for short and intermediate term exposures, the short and intermediate term postapplication risks are numerically identical.

Inhalation exposures are thought to be negligible in outdoor postapplication scenarios, since triadimefon has low vapor pressure and the dilution factor outdoors is considered infinite. In addition, under the Worker Protection Standard for Agricultural Pesticides   WPS   ( 40 CFR 170) greenhouses must be appropriately ventilated ( ventilation criteria are provided) following pesticide applications so that postapplication inhalation exposures are minimal. As such, inhalation postapplication exposures are not considered in this assessment. Page 84 of 114 In agricultural crop settings, the use of personal protective equipment or other types of equipment to mitigate postapplication exposures to workers is not considered a viable alternative for the regulatory process. This is described in some detail in the WPS. Instead, an administrative approach   a Restricted Entry Interval or REI   is used to mitigate postapplication risks following applications to crops. The REI is time period following a pesticide application during which entry into the treated area is restricted. Postapplication risk levels are generally calculated in the risk assessment process on a chemical, crop, and activity specific basis. To establish REIs, HED considers postapplication risks on varying days after application.

HED has used the basic approach described above since the mid 1980s for calculating postapplication risks to pesticides. From that time to the present, several revisions and modifications were made to Agency policies as data, which warranted such changes, became available. In 1995, the Agency issued a Data Call In for postapplication agricultural data that prompted the formation of the Agricultural Reentry Task Force ( ARTF). This task force has generated a number of exposure studies and associated documents that are currently under review. The work of the ARTF is not yet complete; however, sufficient data were available from the group that warranted a significant interim change in Agency policy related to the data which were already available as the efforts of the ARTF paralleled a push for tolerance reassessment stipulated by the timelines established by FQPA. As a result of the need for the revision and using the latest data, the Agency developed a revised policy on August 7, 2000 entitled Policy 003.1 Science Advisory Council for Exposure Policy Regarding Agricultural Transfer Coefficients. The revision to this policy entailed linking worker activities to more specific crop/ agronomic groupings and making better use of the available occupational postapplication exposure data. In the new policy, transfer coefficients were selected to represent the activities associated with 18 distinct crop/ agronomic groupings based on different types of vegetables, trees, berries, vine/ trellis crops, turf, field crops, and bunch/ bundle crops ( e. g., tobacco). Triadimefon uses were identified in the following crop groupings from the policy:

  Flowers, cut ( ornamental),   Tree, fruit, evergreen,   Tree, fruit, deciduous,   Turf/ sod, and   Vine/ trellis ( with and without girdling).

Within each agronomic group, a variety of cultural practices are required to maintain the included crops. These practices are varied and typically involve light to heavy contact with immature plants as well as with more mature plants. HED selected transfer coefficient values in its revision of Policy 003 to represent this range of exposures within each agronomic group. In the policy, transfer coefficients were placed in 1 of 5 generic categories based on the exposures relative to that group. These 5 categories include: very low exposure, low exposure, medium exposure, high exposure, and very high exposure. Numerical values were not necessarily assigned to each category for each crop group. Selections depended upon the actual agronomic practices that were identified for each group ( i. e., some groups had 2 assigned transfer coefficients while others had 5). The transfer coefficient values which have been used are excerpted directly from Agency policy 003. [ The nursery crop group data have not yet been Page 85 of 114 formally included in EPA Policy 3. However, the studies in this area submitted by ARTF have been reviewed and used since they will be integrated into Policy 3.]

2.2.2 Data/ Assumptions for Postapplication Exposure Scenarios A series of assumptions and exposure factors served as the basis for completing the occupational postapplication worker risk assessments. Each assumption and factor is detailed below on an individual basis. In addition to these values, transfer coefficient values were used to calculate risk estimates. The transfer coefficients were taken from HED's revised policy entitled Policy 003.1 Science Advisory Council for Exposure Policy Regarding Agricultural Transfer Coefficients ( August 7, 2000). The assumptions and factors used in the risk calculations are presented below:

  There are many factors that are common to handler and postapplication risk assessments such as body weights, duration, and application rates. See Section <IP_ADDRESS> for these values. In the postapplication risk assessment, maximum application rates were considered.

  Levels of Concern: HED has established levels of concern ( LOC) for occupational postapplication risks   margins of exposure of less than 1000 for occupational dermal and inhalation risks are a concern.

  Turf Transferable Residues: Triadimefon specific turf transferable residue ( TTR) data were available; however, the TTR data were developed concurrently with transfer coefficients for high contact dermal activities. The TTR data could not be used with HED's default transfer coefficients for postapplication occupational exposures to treated turf, since at one of the sites the day zero TTR values were below the required one to five percent necessary for use with current transfer coefficients. Therefore, this assessment uses HED's default assumption that 5 percent of the application rate is available on day 0 ( i. e., 12 hours after application) and the residue dissipates at a rate of 10 percent per day.

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

  Exposures were calculated to reflect default TTR and DFR values over time coupled with surrogate transfer coefficients as outlined in HED's revised policy.

2.2.3 Occupational Postapplication Exposure and Noncancer Risk Estimates Occupational risks were calculated using a Margin of Exposure ( MOE), which is a ratio of the daily dose to the toxicological endpoint of concern. Postapplication risks diminish over time because triadimefon residues eventually dissipate in the environment. As a result, risks Page 86 of 114 were calculated over time based on changing residue levels.

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

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

Where:

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

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

Daily Dose and Margins of Exposure: The use of dissipation data and the manner in which daily postapplication dermal exposures were calculated are inherently different than with handler exposures. However, once daily exposures are calculated, the calculation of daily absorbed dose and the resulting Margin of Exposures use the same algorithms that are described above for the handler exposures ( See Section 2.1.3). These calculations are completed for each day or appropriate block of time after application.

Risk Summary A summary of the postapplication risks are provided in Table 11. The occupational postapplication exposure and risk assessment for agricultural crop uses of triadimefon indicates that risks are not a concern at day 0 ( i. e., 12 hours after application) for all crops and all postapplication activities.

Table 11. Summary of Triadimefon Occupational Postapplication Risks Crop Crop Grouping Application rate ( lb ai/ acre) Transfer Coefficient DAT a MOE at Day 0 3000 ( Thinning) 12 hours 1300 1500 ( Harvest ( hand), Propping, Pruning ( hand), Training, Tying) 12 hours 2700 Apples Tree, fruit, deciduous 0.25 1000 ( Scouting, Weeding ( hand), Irrigation) 12 hours 4000 Page 87 of 114 Table 11. Summary of Triadimefon Occupational Postapplication Risks Crop Crop Grouping Application rate ( lb ai/ acre) Transfer Coefficient DAT a MOE at Day 0 Apples ( cont.) Tree, fruit, deciduous 0.25 100 ( Propping) 12 hours 40000 8000 ( Hand Labor ( misc.), Harvest ( hand), Staking, Training, Thinning, Tying) 12 hours 500 3000 ( Pruning ( cones), Pruning ( hand), Thinning, Seed Cone Harvesting) 12 hours 1300 1000 ( Irrigation, Scouting, Weeding ( hand), Thinning) 12 hours 4000 Christmas trees Tree, fruit, evergreen 0.25 100 ( Propping) 12 hours 40000 5000 ( Harvest ( hand), Pruning ( hand), Training, Tying, Thinning, Leaf Pulling) 12 hours 1100 1000 ( Scouting, Training, Tying) 12 hours 5300 Grapes ( juice and wine) 0.188 500 ( Irrigation, Weeding ( hand), Scouting, Hedging) 12 hours 11000 10000 ( Girdling, Cane turning), Cane Tying 12 hours 530 5000 ( Harvest ( hand), Pruning ( hand), Training, Tying, Thinning, Leaf Pulling) 12 hours 1100 1000 ( Scouting, Training, Tying) 12 hours 5300 Grapes ( table and raisin) Vine/ trellis ( with and without girdling)

0.188 500 ( Irrigation, Weeding ( hand), Scouting, Hedging) 12 hours 11000 5100 ( cut flowers and foliage) 12 hours 790 Ornamental flowers Flowers, cut ( ornamental) 0.25 400 ( all other nursery crops) 12 hours 10000 3000 ( Thinning) 12 hours 1300 1500 ( Harvest ( hand), Propping, Pruning ( hand), Training, Tying) 12 hours 2700 1000 ( Scouting, Weeding ( hand), Irrigation) 12 hours 4000 Pears Tree, fruit, deciduous 0.25 100 ( Propping) 12 hours 40000 Page 88 of 114 Table 11. Summary of Triadimefon Occupational Postapplication Risks Crop Crop Grouping Application rate ( lb ai/ acre) Transfer Coefficient DAT a MOE at Day 0 5000 ( Harvest ( hand), Pruning ( hand), Training, Tying, Thinning, Leaf Pulling) 12 hours 1600 1000 ( Scouting, Training, Tying) 12 hours 8000 Raspberries Vine/ trellis ( with and without girdling). 0.125 500 ( Irrigation, Weeding ( hand), Scouting, Hedging) 12 hours 16000 6800 ( Transplanting, Weeding ( hand), Harvest ( hand), Harvest ( mechanical)) 12 hours 110 5.4 ( CA only) 3800 ( Mowing) 12 hours 200 6800 ( Transplanting, Weeding ( hand), Harvest ( hand), Harvest ( mechanical)) 12 hours 220 Sod Farms and Golf Course Turf Turf/ sod 2.7 ( other than CA) 3800 ( Mowing) 12 hours 390 a DAT is " days after treatment"

2.2.4 Occupational Postapplication Exposure and Risk Estimates for Cancer Since no toxicological endpoint of concern was identified for cancer, cancer risks from occupational postapplication exposures were not assessed.

2.2.5 Summary of Occupational Postapplication Risk Concerns and Data Gaps HED has used the most up to date information available to complete this postapplication risk assessment for triadimefon. Several data gaps exist, such as a lack of triadimefon specific postapplication studies and lack of transfer coefficients for certain crop activities.

2.2.6 Recommendations for Refining Occupational Postapplication Risk Assessment To refine this occupational risk assessment, data on actual use patterns including rates, timing, and the kinds of tasks that are required to produce agricultural commodities and other products would better characterize triadimefon risks. In addition, triadimefon specific TTR or DFR data could refine exposure and risk estimates. Exposure studies for many cultural practices that lack data or that are not well represented in the revised transfer coefficient policy should also be considered based on the data gaps identified above.

3.0 Residential and Other Non Occupational Exposures and Risks Page 89 of 114 It has been determined there is a potential for exposure in residential settings during the application process for homeowners who use products containing triadimefon. There is also a potential for exposure from entering triadimefon treated areas, such as lawns, golf courses, and home gardens that could lead to exposures to adults and children. Risk assessments have been completed for both residential handler and postapplication scenarios.

3.1 Residential Handler Exposures and Risks HED uses the term " handlers" to describe those individuals who are involved in the pesticide application process. HED believes that there are distinct tasks related to applications and that exposures can vary depending on the specifics of each task as was described above for occupational handlers 3.1.1 Handler Exposure Scenarios Scenarios are used to define risks based on the U. S. EPA Guidelines for Exposure Assessment ( U. S. EPA; Federal Register Volume 57, Number 104; May 29, 1992). Assessing exposures and risks resulting from residential uses is very similar to assessing occupational exposures and risks, with the following exceptions:

  Residential handler exposure scenarios are considered to be short term only, due to the infrequent use patterns associated with homeowner products.

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

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

  Label use rates and use information specific to residential products serve as the basis for the risk calculations.

  Area/ volumes of spray or chemical used in the risk assessment are based on HED's guidance specific to residential use patterns.

It has been determined that exposure to pesticide handlers is likely during the residential use of triadimefon in a variety of outdoor environments, including on lawns, gardens, and ornamentals. The anticipated use patterns and current labeling indicate several residential handler exposure scenarios based on the types of equipment and techniques that can potentially be used to make triadimefon applications. The quantitative exposure/ risk assessment developed for residential handlers is based on these scenarios. Page 90 of 114 Mixer/ Loader/ Applicators: ( 1) Liquid Formulations: Low Pressure Handwand ( ORETF data for fruit trees and ornamentals) ( 2) Wettable Powder Formulations: Low Pressure Handwand ( PHED data) ( 3) Liquid Concentrates with Hose End Sprayer ( Residential ORETF data  fruit trees and ornamental shrubs) ( 4) Liquid Concentrates with Hose End Sprayer ( Residential ORETF data   gardens) ( 5) Liquid Concentrates with Hose End Sprayer ( Residential ORETF data   turf) ( 6) Wettable Powders with Hose End Sprayer ( Residential ORETF data  liquid concentrate application to fruit trees and ornamentals) ( 7) Wettable Powders with Hose End Sprayer ( Residential ORETF data  liquid concentrates application) ( 8) Liquid Concentrates with a Tree Injector ( no data) ( 9) Loading/ Applying Granulars via Push Type Spreader ( ORETF data) ( 10) Loading/ Applying Granulars via Belly Grinder ( PHED data)

3.1.2 Data and Assumptions for Handler Exposure Scenarios A series of assumptions and exposure factors served as the basis for completing the residential handler risk assessments. Each assumption and factor is detailed below. In addition to these factors, unit exposure values were used to calculate risk estimates. Mostly, these unit exposure values were taken from the Pesticide Handlers Exposure Database ( PHED) and the Outdoor Residential Exposure Task Force ( ORETF) studies. In other cases, chemical specific exposure data were submitted to support the reregistration of triadimefon. Both PHED and the individual studies are presented below. [ Note: Several of the assumptions and factors used for the assessment are similar to those used in the occupational assessment presented above. As such, only factors that are unique to the residential scenarios are presented below.]

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

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

  HED always considers the maximum application rates allowed by labels in its risk assessments. If additional information such as average or typical rates are available, these values also may be used to allow risk managers to make a more informed risk management decision. Average/ typical application rates were not available for residential scenarios.

  Residential risk assessments are based on estimates of what homeowners would typically treat, such as the size of a lawn or the size of a garden. The factors used for the triadimefon assessment were from the Health Effects Division Science Advisory Committee Policy 12: Recommended Revisions to the Standard Operating Procedures for Page 91 of 114 Residential Exposure Assessment which was completed on February 22, 2001, and on professional judgement. The daily volumes handled and area treated used in each residential scenario are provided in Table 4.

Residential Handler Exposure Studies: The unit exposure values that were used in this assessment were based on the Outdoor Residential Exposure Task Force studies and the Pesticide Handler Exposure Database ( PHED, Version 1.1 August 1998) [ Note: PHED and some ORETF studies are described above in Section 2.1.1.]

ORETF Handler Studies  OMA001 OMA004 ( MRID 449722 01) A report was submitted by the ORETF ( Outdoor Residential Exposure Task Force) that presented data in which the application of various products used on turf by homeowners and lawncare operators ( LCOs) was monitored. All of the data submitted in this report were completed in a series of studies.

Homeowner Liquid Applications with a Ready to use Hose end Sprayer and a Dial Type Hoseend Sprayer ( MRID 449722 01): A mixer/ loader/ applicator study was performed by the Outdoor Residential Exposure Task Force ( ORETF) using diazinon ( 25% EC) as a surrogate compound to determine " generic" exposures to individuals applying a pesticide to turf with a garden hose end sprayer. Surrogate chemicals were chosen by the Task Force for their representativeness based on physical chemical properties and other factors. The study was designed to simulate a typical application event for a homeowner applying pesticides to home lawns via a hose end sprayer. Each replicate monitored the test subject treating 5,000 square feet of turf at a nominal application rate of 4 pounds active ingredient per acre and handling a total of 0.5 pounds active ingredient per replicate. The average time per replicate was 75 minutes. A total of 60 replicates were monitored using 30 test subjects ( two replicates each). Thirty applicator replicates were monitored using a ready to use ( RTU) product ( Bug B Gon) packaged in a 32 fl. oz. screw on container. These containers were attached to garden hose ends. An additional 30 mixer/ loader/ applicator replicates were monitored using Diazinon Plus also packaged in 32 fl. oz. plastic bottles. This product required the test subjects to pour the product into dial type sprayers ( DTS) that were attached to garden hose ends.

Dermal and inhalation exposures were monitored using passive dosimetry ( inner and outer whole body dosimeters, hand washes, face/ neck wipes, and personal inhalation monitors with OVS tubes). The inner samples represent a single layer of clothing. Inhalation exposure was calculated using an assumed respiratory rate of 17 liters per minute for light work ( NAFTA, 1999), the actual sampling time for each individual, and the pump flow rate. No gloves were worn in any replicate. All results were normalized for the amount of active ingredient handled. The QA/ QC data are within an acceptable range and the study results are corrected for field recoveries. The unit exposure values are presented below. [ Note: All values are geometric means as the data were lognormally distributed.] Page 92 of 114 Table 12: Unit Exposure Values for Homeowner Liquid Applications with a Ready touse Hose end Sprayer and a Dial Type Hose end Sprayer Obtained From ORETF Study ( MRID 449722 01) Total Dermal Unit Exposure1 ( mg/ lb ai) Scenario Monitored Short Pants, Short Sleeves Long Pants, Short Sleeves Long Pants, Long Sleeves Inhalation Unit Exposure1,2 ( µ g/ lb ai) Homeowner Liquid Applications with a Dial Type Hose end Sprayer ( Mix your own) ( home lawns) 11 6.2 5.6 17 1 Unit exposure values reported are geometric means. 2 Air concentration ( mg/ m3/ lb ai) calculated using NAFTA ` 99 standard breathing rate of 17 lpm ( 1 m3/ hr).

ORETF Handler Studies  OMA005 ( MRID 445185 01) A report was submitted by the ORETF ( Outdoor Residential Exposure Task Force) that presented data in which the application of various products used on fruit trees and ornamentals by homeowners was monitored. All of the data submitted in this report were completed in a series of studies.

Homeowner Liquid Applications to Fruit Trees and Ornamental Plants with a Hose end Sprayer and a Low Pressure Handwand ( MRID 445185 01): Applications of Sevin Liquid ® Carbaryl insecticide [ RP 2 liquid ( 21%)] were made by volunteers to two young citrus trees and two shrubs in each replicate that was monitored in the study. The test field was located only in Florida. Twenty ( 20) replicates were monitored using hose end sprayer ( Ortho ® DIAL or Spray ® hose end sprayer), and 20 replicates were monitored using hand held pump sprayers ( low pressure handwands).

Each replicate opened the end use product, added it to the hose end sprayer or hand held pump and then applied it to the trees and shrubs. After application to two trees and two shrubs dosimeters were collected. Inhalation exposure was monitored with personal air sampling pumps with OVS tubes attached to the shirt collar in the breathing zone. Dermal exposure was assessed by extraction of carbaryl from inner and outer 100 percent cotton dosimeters. The inner and outer dosimeters were segmented into: lower and upper arms, lower and upper legs, front and back torso. No gloves were worn therefore hand exposure was assessed with 400 ml handwash with 0.01 percent Aerosol OT 75 sodium dioctyl sulfosuccinate ( OTS). One hundred percent cotton handkerchiefs wetted with 25 ml OTS were used to wipe face and neck to determine exposure.

Field fortification recoveries for passive dosimeters averaged 88.3 percent for inner and 76.2 percent for outer dosimeters. Face and neck wipe fortifications average 82.5 percent. Handwash and inhalation OVS tube field fortification averaged > 90 percent. Inner and outer dosimeter and face and neck wipe residues were adjusted for field fortification results. Handwash and inhalation residues were not adjusted.

Laboratory method validation for each matrix fell within the acceptable range of 70 to 120 percent. The limit of quantitation ( LOQ) was 1.0 µ g/ sample for all media except the inhalation monitors where the LOQ was 0.01 µ g/ sample. The limit of detection ( LOD) was 0.5 µ g/ sample for all media except the inhalation monitors where the LOQ was 0.005 µ g/ sample. Page 93 of 114 For use in reregistration documents, the dermal exposure was calculated by adding the values from the hand rinses, face/ neck wipes to the outer dosimeter lower legs and lower arms plus the inner dosimeter front and rear torso, upper legs and upper arms. This accounts for the residential handler wearing short sleeved shirt and short pants. The results for the low pressure handwand are summarized in Table 13 below.

The distribution of the unit exposure values is categorized as normal, lognormal, or " other" ( i. e., neither normal nor lognormal). A central tendency value is selected from the distribution of the exposure values. These values are the arithmetic mean for normal distributions, the geometric mean for lognormal distributions, and the median for all " other" distributions. The dermal exposure had a lognormal distribution so the geometric mean value was used to determine dermal exposure. The inhalation exposure had neither a normal or lognormal distribution so the median was used to determine inhalation exposure.

Table 13: Unit Exposure Values for Homeowner Liquid Applications to Fruit Trees and Ornamental Plants with a Hose end Sprayer and a Low Pressure Handwand Obtained From ORETF Study ( MRID 445185 01) Total Dermal Unit Exposure1 ( mg/ lb ai) Scenario Monitored Short Pants, Short Sleeves Long Pants, Short Sleeves Long Pants, Long Sleeves Inhalation Unit Exposure2 ( µ g/ lb ai) Homeowner Liquid Applications with a Hoseend Sprayer 39 27 23 1.6 Homeowner Liquid Applications with a Hand Held Sprayer ( Low Pressure Handwand) 56 36 30 2.6 1 Dermal unit exposure values reported are the geometric means. 2 Inhalation unit exposure values reported are the median values.

3.1.3 Residential Handler Exposure and Noncancer Risk Estimates Risks were calculated using the Margin of Exposure ( MOE) as described in Section 2.1.3. Assessing exposures and risks resulting from residential uses is very similar to assessing occupational exposures and risks, except as described in Section 3.1.1.

Risk Summary: The data used by HED have provided a basic broad overview of the uses of triadimefon around a residential environment ( i. e., the database is fairly complete). As indicated above, however, it is likely that triadimefon can be used in a myriad of ways that have not specifically been identified in this assessment. HED believes that the scenarios assessed in this document represent worse case exposures and risks resulting from use of triadimefon in residential environments. It should also be noted that there were many other scenarios where medium to low PHED quality data were used to complete the assessment. Data quality should be considered in the interpretation of the uncertainties associated with each risk value presented.

Short term risks for residential handlers are presented in Table 14. Intermediate term exposures are not likely because of the intermittent nature of applications by homeowners. Inhalation risks for residential handlers are not a concern for all residential uses of triadimefon. Dermal and total risks for residential handlers are not a concern for most triadimefon residential handler scenarios. Dermal and total risks remain a concern ( MOEs < 1000) for: Page 94 of 114   mixing/ loading/ applying liquid concentrates with a hose end sprayer ( using ORETF data) to greenhouse ornamentals ( trees and shrubs) at 0.00938 lb ai/ gal ( MOE = 490);   mixing/ loading/ applying liquid concentrates with a hose end sprayer ( using ORETF data) to greenhouse ornamentals ( flowers) at 0.00938 lb ai/ gal ( MOE = 560);   mixing/ loading/ applying liquid concentrates with a hose end sprayer ( using ORETF data) to turf ( home lawns) ( MOE = 440);   mixing/ loading/ applying wettable powders with hose end sprayer ( residential ORETF data  liquid concentrate data) to greenhouse ornamentals ( trees and shrubs) at 0.00625 lb ai/ gal ( MOE = 740); and   mixing/ loading/ applying wettable powders with hose end sprayer ( residential ORETF data  liquid concentrate data) to greenhouse ornamentals ( flowers) at 0.00625 lb ai/ gal ( MOE = 850). Page 95 of 114 Table 14. Triadimefon Residential Handler Risks Baseline Unit Exposure MOEs Exposure Scenario Crop or Target App Ratea ( lb ai/ gallon) Area Treated Dailyb ( gallons) Dermalc ( mg/ lb ai) Inhalationd ( µ g/ lb ai) Baseline Dermal Baseline Inhalation Baseline Dermal +

Baseline Inhalation MOE Mixer/ Loader/ Applicator greenhouse ornamentals ( flowering,

shrubs, trees) 0.00938 5 56 2.6 6900 2000000 6800 roses 0.00029 5 56 2.6 220000 63000000 220000 turf ( home lawns) 0.033 5 56 2.6 1900 550000 1900 Mixing/ Loading/ Applying Liquid Concentrates with Low Pressure Handwand ( ORETF fruit trees and ornamentals) ornamentals ( flowering,

shrubs, trees) 0.0023 5 56 2.6 28000 8000000 28000 Mixing/ Loading/ Applying Liquid Concentrates with Low Pressure Handwand ( ORETF ground directed) turf ( home lawns) 0.033 5 38 2.7 2900 530000 2900 apples, pears 0.00062 5 250 1063 23000 72000 18000 Mixing/ Loading/ Applying Wettable Powders with Low Pressure Handwand ( PHED) azaleas 0.005 5 250 1063 2900 9000 2200 Page 96 of 114 Table 14. Triadimefon Residential Handler Risks Baseline Unit Exposure MOEs Exposure Scenario Crop or Target App Ratea ( lb ai/ gallon) Area Treated Dailyb ( gallons) Dermalc ( mg/ lb ai) Inhalationd ( µ g/ lb ai) Baseline Dermal Baseline Inhalation Baseline Dermal +

Baseline Inhalation MOE grapes 0.00094 5 250 1063 15000 48000 12000 greenhouse ornamentals ( flowering,

shrubs, trees) 0.00625 5 250 1063 2300 7200 1700 Mixing/ Loading/ Applying Wettable Powders with Low Pressure Handwand ( PHED) ( cont.) ornamentals ( flowering,

shrubs, trees) 0.0025 5 250 1063 5800 18000 4400 greenhouse ornamentals ( shrubs, trees) 0.00938 100 39 1.6 490 160000 490 ornamentals ( shrubs, trees) 0.0023 100 39 1.6 2000 650000 2000 pines 0.0023 100 39 1.6 2000 650000 2000 Mixing/ Loading/ Applying Liquid Concentrates with Hose End Sprayer ( Residential ORETF data

fruit trees and ornamental shrubs) roses 0.00029 100 39 1.6 16000 5100000 16000 Page 97 of 114 Table 14. Triadimefon Residential Handler Risks Baseline Unit Exposure MOEs Exposure Scenario Crop or Target App Ratea ( lb ai/ gallon) Area Treated Dailyb ( gallons) Dermalc ( mg/ lb ai) Inhalationd ( µ g/ lb ai) Baseline Dermal Baseline Inhalation Baseline Dermal +

Baseline Inhalation MOE greenhouse ornamentals ( flowering) 0.00938 100 34 0.82 560 310000 560 Mixing/ Loading/ Applying Liquid Concentrates with Hose End Sprayer ( Residential ORETF data for gardens) ornamentals ( flowering) 0.0023 100 34 0.82 2300 1300000 2300 Mixing/ Loading/ Applying Liquid Concentrates with Hose End Sprayer ( Residential ORETF data for home lawns) turf ( home lawns) 0.033 100 11 17 500 4200 440 apples, pears 0.00062 100 39 1.6 7400 2400000 7400 grapes 0.00094 100 39 1.6 4900 1600000 4900 Mixing/ Loading/ Applying Wettable Powders with Hose End Sprayer ( Residential ORETF data

liquid concentrate application to fruit trees and ornamentals) greenhouse ornamentals ( shrubs, trees) 0.00625 100 39 1.6 740 240000 740 Page 98 of 114 Table 14. Triadimefon Residential Handler Risks Baseline Unit Exposure MOEs Exposure Scenario Crop or Target App Ratea ( lb ai/ gallon) Area Treated Dailyb ( gallons) Dermalc ( mg/ lb ai) Inhalationd ( µ g/ lb ai) Baseline Dermal Baseline Inhalation Baseline Dermal +

Baseline Inhalation MOE Mixing/ Loading/ Applying Wettable Powders with Hose End Sprayer ( Residential ORETF data

liquid concentrate application to fruit trees and ornamentals) ( cont.) ornamentals ( shrubs, trees) 0.0025 100 39 1.6 1800 600000 1800 azaleas 0.005 100 34 0.82 1100 580000 1100 greenhouse ornamentals ( flowering) 0.00625 100 34 0.82 850 460000 850 Mixing/ Loading/ Applying Wettable Powders with Hose End Sprayer ( Residential ORETF data liquid concentrate for gardens) ornamentals ( flowering) 0.0025 100 34 0.82 2100 1200000 2100 Mixing/ Loading/ Applying Liquid Concentrates with a Tree Injector ( no data) Ornamentals ( shade trees,

woody shrubs) 0.000026 lb ai/ inch of trunk inches of trunk No Data No Data No Data No Data No Data Page 99 of 114 Table 14. Triadimefon Residential Handler Risks Baseline Unit Exposure MOEs Exposure Scenario Crop or Target App Ratea ( lb ai/ gallon) Area Treated Dailyb ( gallons) Dermalc ( mg/ lb ai) Inhalationd ( µ g/ lb ai) Baseline Dermal Baseline Inhalation Baseline Dermal +

Baseline Inhalation MOE turf 5.2 lb ai/ acre ( CA only) 0.5 acres 0.67 0.88 10000 100000 9400 turf 2.7 lb ai/ acre ( except CA) 0.5 acres 0.67 0.88 20000 200000 18000 Loading/ Applying Granulars via Push Type Spreader ( ORETF data) turf 1.3 lb ai/ acre ( Bayer max residential rate) 0.5 acres 0.67 0.88 41000 420000 38000 turf 0.00012 lb ai/ ft2 ( CA only) 1000 ft2 110 62 1400 32000 1300 turf 0.00006 lb ai/ ft2 ( except CA) 1000 ft2 110 62 2600 62000 2500 Loading/ Applying Granulars via Belly Grinder ( PHED data) turf 0.00003 lb ai/ ft2 ( Bayer max residential rate) 1000 ft2 110 62 5500 130000 5300 a Application rates are the maximum application rates determined from EPA registered labels for triadimefon b Amount handled per day values are HED estimates of acres, square feet, or cubic feet treated or gallons applied based on Exposure SAC SOP # 9 " Standard Values for Daily Acres Treated in Agriculture," industry sources, and HED estimates.

c Baseline Dermal: Long sleeve shirt, long pants, no gloves.

d Baseline Inhalation: no respirator. Page 100 of 114 3.1.4 Residential Handler Exposure and Risk Estimates for Cancer Residential handler cancer risks are not assessed, since no toxicological endpoint of concern for cancer was selected.

3.1.5 Summary of Risk Concerns and Data Gaps for Handlers Generally, risks ( i. e., MOEs) associated with most scenarios are not of concern, because they exceed HED's uncertainty factor of 1000. Inhalation risks for residential handlers are not a concern for all residential uses of triadimefon. Dermal and total risks for residential handlers are not a concern for most triadimefon residential handler scenarios. Dermal and total risks remain a concern ( MOEs < 1000) for:

  mixing/ loading/ applying liquid concentrates with a hose end sprayer ( using ORETF data) to greenhouse ornamentals ( trees and shrubs) at 0.00938 lb ai/ gal ( MOE = 490);   mixing/ loading/ applying liquid concentrates with a hose end sprayer ( using ORETF data) to greenhouse ornamentals ( flowers) ) at 0.00938 lb ai/ gal ( MOE = 560);   mixing/ loading/ applying liquid concentrates with a hose end sprayer ( using ORETF data) to turf ( home lawns) ( MOE = 440);   mixing/ loading/ applying wettable powders with hose end sprayer ( residential ORETF data  liquid concentrate data) to greenhouse ornamentals ( trees and shrubs) at 0.00625 lb ai/ gal ( MOE = 740); and   mixing/ loading/ applying wettable powders with hose end sprayer ( residential ORETF data  liquid concentrate data) to greenhouse ornamentals ( flowers) at 0.00625 lb ai/ gal ( MOE = 850). Page 101 of 114 The key data gaps identified by HED for residential handlers are:   mixing/ loading/ applying liquids with an injector  HED has no data for this scenario and is not aware of any surrogate data that could be applied to this scenario; and   mixing/ loading/ applying wettable powders with hose end sprayer   HED used data for mixing/ loading/ applying liquid concentrates with a hose end sprayer ( ORETF data) as a surrogate; however this likely underestimates risks.

3.1.6 Recommendations for Refining Residential Handler Risk Assessment In order to refine this residential risk assessment, more data on actual use patterns including rates, timing, and areas treated would better characterize triadimefon risks. Exposure studies for many equipment types that lack data or that are not well represented in PHED ( e. g., because of low replicate numbers or data quality) should also be considered based on the data gaps identified above and based on a review of the quality of the data used in this assessment.

3.2 Residential Postapplication Exposures and Risks 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. Triadimefon can be used in many areas that can be frequented by the general population including residential areas ( e. g., home lawns and gardens). As a result, individuals can be exposed by entering these areas if they have been previously treated.

3.2.1 Residential Postapplication Exposure Scenarios A wide array of individuals of varying ages can potentially be exposed to triadimefon when they are in areas that have been previously treated. Postapplication exposure scenarios were developed for each residential setting where triadimefon can be used. Assessing postapplication exposures and risks resulting from residential uses is very similar to assessing occupational postapplication exposures and risks ( Section 2.2), except in residential assessments:

  exposures were calculated for children of differing ages as well as adults and   non dietary ingestion exposures to toddlers were calculated ( i. e., soil ingestion, hand / object to mouth).

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

  Series 875, Residential and Residential Exposure Test Guidelines: Group B  Postapplication Exposure Monitoring Test Guidelines ( V 5.4, Feb. 1998): This document provides general risk assessment guidance and criteria for analysis of residue dissipation data.

  Standard Operating Procedures for Residential Exposure Assessment ( Dec. 1997): This document provides the overarching guidance for developing residential risk assessments Page 102 of 114 including scenario development, algorithms, and values for inputs.

  Science Advisory Council for Exposure Policy 003.1 ( Aug. 2000): Agricultural Transfer Coefficients: This document provides transfer coefficients which have been used to assess exposures in home gardens.

  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.

  Overview of Issues Related to the Standard Operating Procedures for Residential Exposure Assessment ( August 1999 Presentation To The FIFRA SAP): This document provides rationale for Agency changes in SOPs.

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 are exposed to chemicals by engaging in activities at their residences ( e. g., in their lawns or gardens) and also in areas not limited to their residence ( e. g., golf courses or parks) previously treated with a pesticide. These kinds of exposures are attributable to a variety of activities and are usually addressed by HED in risk assessments by considering a representative activity as the basis for the exposure calculation.

  Residential Children: children are members of the general population that can also be exposed in their residences ( e. g., on lawns and other residential turfgrass areas, in gardens, on carpets and hard flooring, or from contact with treated pets). These kinds of exposures are attributable to a variety of activities such as playing outside, home gardening, playing on carpeting or hard flooring, and playing with a companion animal. Toddlers have been selected as the sentinel ( representative) population for turf, indoor flooring, and companion animal assessments. Youth aged children ( ages 10 to 12) are considered the sentinel population for a gardening assessment, because it is likely that children of this age would help with garden maintenance. Children are addressed by HED in risk assessments by considering representative activities for each age group in an exposure calculation.

The SOPs for Residential Exposure Assessment define several scenarios that apply to uses specified in current labels. These scenarios served as the basis for the residential postapplication assessment along with the modifications to them and the additional data and approaches described above. HED used this guidance to define the exposure scenarios that essentially include dermal and nondietary ingestion exposure to toddlers on treated lawns, dermal and nondietary ingestion exposure to toddlers on treated flooring, dermal exposure to Page 103 of 114 youths in treated gardens, dermal and nondietary ingestion exposure to children from treated companion animals, and dermal exposure to adults in treated gardens and on treated lawns. The SOPs and the associated scenarios are presented below:

  Dose from dermal exposure on treated lawns: Postapplication dermal dose calculations for toddlers from playing on treated turf and for adults mowing and exercising on treated turf;

  Dose from hand to mouth activity from treated turf: Postapplication dose calculations for toddlers from incidental nondietary ingestion of pesticide residues on treated turf from hand to mouth transfer ( i. e., those residues that are swallowed when toddlers get pesticide residues on their hands from touching treated turf and then put their hands in their mouth);

  Dose from object to mouth activity from treated turf: Postapplication dose calculations for toddlers from incidental nondietary ingestion of pesticide residues on treated turf from object to mouth transfer ( i. e., those residues that are swallowed when toddlers put treated turf in their mouths);

  Dose from soil ingestion activity from treated turf: Postapplication dose calculations for toddlers from incidental nondietary ingestion of pesticide residues from ingesting soil in a treated turf area ( i. e., those soil residues that are swallowed when toddlers get pesticide residues on their hands from touching treated soil and then put their hands in their mouth);

  Dose from ingestion of triadimefon granules from treated turf: Postapplication dose calculations for toddlers from episodic nondietary ingestion of pesticide granules picked up from treated turf ( i. e., those residues that are swallowed when toddlers pick up granules from treated turf and put the granules in their mouth);

  Dose from dermal exposure while golfing: Postapplication dermal dose calculations for adults and youth aged children ( ages 10 to 12) while golfing.

3.2.2 Data and Assumptions for Residential Postapplication Exposure Scenarios 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:

  There are many factors that are common to the occupational and residential Page 104 of 114 postapplication risk assessments, such as body weights for adults, analysis of residue dissipation data, and transfer coefficients used for the garden exposure scenarios. Please refer to the assumptions and factors in Section 2.1.2 for further information concerning these common values.   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 triadimefon, HED has combined risks ( i. e., MOEs) for different kinds of exposures for one scenario: o for turf scenarios   dermal plus hand to mouth plus object to mouth plus soil ingestion   Exposures to adults and children on treated turf have been addressed using the latest HED standard operating procedures for this scenario including: o For high contact activities, TTR values for dermal exposures are from a triadimefon specific turf transferable residue study ( note the study estimated both TTR values and transfer coefficients for adults and 5 year olds); o Dermal exposures for all remaining activities use HED's default assumption that 5 percent of the application rate is available on day 0 ( i. e., 12 hours after application) and the residue dissipates at a rate of 10 percent per day. o 5 percent of the application rate has been used to calculate the day zero TTR residue levels used for assessing risks from hand to mouth exposures, since even though triadimefon specific turf transferable residue study data are available, the residential SOPs indicate that the 5 percent default should be used; o 20 percent of the application rate has been used to calculate the day zero residue levels used for assessing risks from object to mouth behaviors ( a higher percent transfer has been used for object to mouth behaviors, because it involves a teething action believed to be more analogous to DFR/ leaf wash sample collection where 20 percent is also used); o the transfer coefficients used are those presented during the 1999 Agency presentation before the FIFRA Science Advisory Panel that have been adopted in routine practice by HED, except the transfer coefficient from the triadimefon specific TTR study was used for high contact dermal exposures on turf; o 3 year old toddlers are expected to weigh 15 kilograms ( representing an average weight from years one to six); o hand to mouth exposures are based on a frequency of 20 events/ hour and a surface area per event of 20 cm2, representing the palmar surfaces of three fingers; o saliva extraction efficiency is 50 percent meaning that every time the hand goes in the mouth approximately ½ of the residues on the hand are removed; o object to mouth exposures are based on a 25 cm2 surface area; o exposure durations for turfgrass scenarios are estimated to be 2 hours based on information in HED's Exposure Factors Handbook; o soil residues are contained in the top centimeter and soil density is 0.67 mL/ gram; and o dermal, hand and object to mouth, and soil ingestion are combined to Page 105 of 114 represent an overall risk from exposure to turf, while granular ingestion is considered to be a much more episodic behavior and is considered separately by HED.   Exposures to children and adults working in home gardens have been addressed using the latest HED approaches for this scenario including: o youth aged children are considered along with adults; o 12 year old youth are expected to weigh 39.1 kilograms; o exposure durations are expected to be 40 minutes for adults and 20 minutes for youths; o transfer coefficients for youths were calculated by adjusting the appropriate adult transfer coefficients by a 50% factor as has been done by HED since the inception of the SOPs For Residential Exposure Assessment; o transfer coefficients for adults and youths are from the R SOPs; o the combination of adjusting transfer coefficients for youth aged children and using appropriate body weights for the age group results in dose levels that are slightly lower than that of adults in the same activity ( the transfer coefficient reduction and body weight reduction is essentially a 1: 1 ratio); and o the DFR data used for the assessments are the default assumption that 20 percent of the application rate is available for transfer, since no triadimefonspecific DFR data are available.   Postapplication residential risks are based on maximum application rates or values specified in the SOPs for Residential Exposure Assessment.   The Jazzercize approach is the basis for the dermal transfer coefficients as described in HED's Series 875 guidelines, SOPs for Residential Exposure Assessment, and the 1999 FIFRA SAP Overview document.

The registrant has submitted one turf transferable residue study in support of the reregistration of triadimefon, titled Evaluation of Potential Exposure Resulting from Contact with Bayleton Treated Turf ( MRID No. 431254 01). This study will be used to assess postapplication exposure and risk from treated turfgrass for high contact activities. The study provides dermal exposure values, turf transferable residue ( TTR) values and dermal transfer factors measured and/ or calculated after the application of Bayleton 25 Turf and Ornamental Fungicide to turf. Adult volunteers performed a 20 minute Jazzercise routine on the treated turf, after which dermal exposures were measured, and the data also were adjusted to obtain surrogate values for 10 year old and 5 year old children. Using the dermal exposures and the TTR values measured, dermal transfer factors ( cm2/ hr) were obtained for each population. The TTR value measured in the study, as well as the calculated dermal transfer factors calculated for adults and 5 year olds, were used in the assessment of postapplication exposures from turf due to high contact lawn activities. The TTR value provided in the study was 0.502 ug/ cm2. This value was adjusted for the difference in the study's application rate ( 2.25 lb ai/ acre) and the maximum application rates in the ORE assessment. The dermal transfer factors ( adults: 29,125 cm2/ hr; toddlers ( 5 year olds): 12,274 cm2/ hr) calculated in the study were used in place of the default Residential SOP values ( adults: 14,500 cm2/ hr; toddlers: 5,200 cm2/ hr) for high contact lawn activities. The TTR study assumed that a typical 5 year old child would weigh 18.7 kilograms. In order to combine incidental oral and dermal risks to toddlers, the incidental oral risks were calculated using the 18.7 kilograms for a 5 year old child, rather than the usual 15 kilograms for a 3 year old child as Page 106 of 114 assumed in the Standard Operating Procedures for Residential Assessments.

3.2.3 Residential Postapplication Exposure and Noncancer Risk Estimates 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 ( i. e., DFRs on ornamental plants and TTRs on lawns), then calculating dermal and nondietary ingestion exposures.

Dermal exposures and risks from lawn, garden, and golf course turfgrass uses were calculated in the same manner as described above in Section 2.2.3. Along with calculating these dermal exposures, other aspects of the turf exposure scenario involved calculating dose from non dietary ingestion. The algorithms used for each type of calculation are presented below which have not been previously addressed in Section 2.2.3.

Dermal Exposure from Treated Lawns ( adult and toddler)

The approach used to calculate the dermal exposures that are attributable to exposure from contacting treated lawns is:

ADD = ( TTR0 * ET * TC * DA * CF1) / BW Where:

ADD = average daily dose ( mg/ kg/ day); TTRt = turf transferable residue on day " 0" ( µ g/ cm2); ET = exposure time ( 2 hr/ day); TC = transfer coefficient; DA = dermal absorption factor ( 100%); CF1 = weight unit conversion factor to convert µ g units to mg for the daily exposure ( 0.001 mg/ µ g); and BW = body weight ( 70 kg for adults and 18.7 kg for toddlers).

Hand to mouth Transfer of Pesticide Residues on Lawns ( toddler)

The approach used to calculate the nondietary ingestion exposures that are attributable to handto mouth behavior on treated turf is:

ADD = ( TTR0 * SA * FQ * ET * SE * CF1) / BW Where:

ADD = average daily dose ( mg/ kg/ day); TTRt = turf transferable residue on day " 0" ( µ g/ cm2); SA = surface area of the hands ( 20 cm2/ event); FQ = frequency of hand to mouth activity ( 20 events/ hr); ET = exposure time ( 2 hr/ day); SE = extraction by saliva ( 50%); CF1 = weight unit conversion factor to convert µ g units in the DFR value to mg for the daily Page 107 of 114 exposure ( 0.001 mg/ µ g); and BW = body weight ( 18.7 kg).

Object to mouth Transfer of Pesticide Residues on Lawns ( toddler)

The approach used to calculate exposures that are attributable to object to mouth behavior on treated turf that is represented by a child mouthing on a handful of turf is:

ADD = ( TTR0 * IgR* CF1) / BW Where:

ADD = average daily dose ( mg/ kg/ day); TTRt = turf transferable residue on day " 0" ( µ g/ cm2); IgR = ingestion rate of grass ( 25 cm2/ day); CF1 = weight unit conversion factor to convert the ug of residues on the grass to mg to provide units of mg/ day ( 1E 3 mg/ ug); and BW = body weight ( 18.7 kg).

Incidental Ingestion of Soil from Pesticide Treated Residential Areas ( toddler)

The approach used to calculate exposures that are attributable to soil ingestion is:

ADD = ( SR0 * IgR * CF1) / BW Where:

ADD = average daily dose ( mg/ kg/ day); SR0 = soil residue on day " 0" ( 0.0022 µ g/ g); IgR = ingestion rate of soil ( 100 mg/ day); CF1 = weight unit conversion factor to convert the ug of residues on the soil to grams to provide units of mg/ day ( 1E 6 g/ µ g); and BW = body weight ( 18.7 kg).

and SRt = TTRt * F * CF2 Where:

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

Incidental Ingestion of Granules from Pesticide Treated Residential Areas ( toddler)

The approach used to calculate exposures that are attributable to granule ingestion is:

ADD = ( IgR * F * CF1)/ BW Where: Page 108 of 114 ADD = average daily dose ( mg/ kg/ day); IgR = ingestion rate of soil ( 0.3 g/ day); F = fraction of ai in dry formulation ( unitless); CF1 = weight unit conversion factor to convert the g units in the ingestion rate value to mg for the daily exposure ( 1000 mg/ g); and BW = body weight ( 18.7 kg).

Dermal Exposure from Treated Ornamental Gardens ( adult and youth)

The approach used to calculate the dermal exposures that are attributable to exposure from contacting treated gardens is:

ADD = ( DFR0 * ET * TC * CF1) / BW Where: ADD = average daily dose ( mg/ kg/ day); DFRt = dislodgeable foliar residue on day " 0" ug/ cm2); ET = exposure time ( 0.67 hr/ day for adults and 0.33 hr/ day for youths); TC = transfer coefficient ( 10,000 cm2/ hr for adults and 5,000 cm2/ hr for toddlers); CF1 = weight unit conversion factor to convert ug units to mg for the daily exposure ( 0.001 mg/ ug) BW = body weight ( 70 kg for adults and 39 kg for youths).

Dermal Exposure from Golfing on Treated Golf Course Turf ( adult and youth)

The approach used to calculate the dermal exposures that are attributable to exposure from contacting treated golf course turf is:

ADD = ( DFR0 * ET * TC * CF1) / BW Where: ADD = average daily dose ( mg/ kg/ day); DFRt = dislodgeable foliar residue on day " 0" ( ug/ cm2); ET = exposure time ( 4 hr/ day for adults and youths); TC = transfer coefficient ( 500 cm2/ hr for adults and youths); CF1 = weight unit conversion factor to convert ug units to mg for the daily exposure ( 0.001 mg/ ug) BW = body weight ( 70 kg for adults and 39 kg for youths).

Risk Summary: HED has addressed residential postapplication exposures to triadimefon 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 residential handler assessments described above ( i. e., 1,000 for short term and intermediate term exposures).

Risk Summary: Page 109 of 114 Adults Table 15 presents the postapplication MOE values calculated for adults after lawn and home garden applications of triadimefon. For the residential adult scenarios, short term MOEs are > 1,000 on the day of application for all scenarios, except mowing at the 5.4/ 5.2 lb ai/ A ( CA only) application rate and the high contact turf activities at the 5.4/ 5.2 and 2.7 lb ai/ A application rates.

Table 15: Adult Residential Risk Estimates for Postapplication Exposure to Triadimefon Exposure Scenario Route of Exposure Formulation Application Rate ( lb ai/ acre) MOE at Day 0 Outdoors   with default transferable residues 5.4/ 5.2 ( CA only) 870/ 910 2.7 ( Other than CA) 1,700 Residential Turf ( Mowing) Dermal Spray/ Granular 1.3 ( Bayer max residential) 3,600 Home Garden ( Ornamentals) Dermal Spray 0.25 4,800 5.4/ 5.2 ( CA only) 3,000/ 3,100 2.7 ( Other than CA) 5,900 Golfer Dermal Spray/ Granular 1.3 ( Bayer max residential) 12,000 Outdoors   with actual transferable residues ( TTR data)

5.4/ 5.2 ( CA only) 310/ 320 2.7 ( Other than CA) 620 Residential Turf ( High Contact Activities) Dermal Spray/ Granular 1.3 ( Bayer max residential) 1,300 Youth aged children ( 10 to 12 years old)

Youths were considered in the home garden, residential turf/ mowing, and golfer scenarios. Short term MOEs for these youths were > 1,000 for all of the scenarios considered except mowing at the 5.4/ 5.2 ( CA only) application rate. Table 16 below summarizes the postapplication MOE values calculated for youths after applications of triadimefon. Page 110 of 114 Table 16: Youth Residential Risk Estimates for Postapplication Exposure to Triadimefon Exposure Scenario Route of Exposure Formulation Application Rate ( lb ai/ acre) MOE at Day 0 Outdoors   with default transferable residues 5.4/ 5.2 ( CA only) 570/ 590 2.7 ( Other than CA) 1,100 Residential Turf ( Mowing) Dermal Spray/ Granular 1.3 ( Bayer max residential) 2,400 Home Garden ( Ornamentals) Dermal Spray/ Granular 0.25 13,000 5.4/ 5.2 ( CA only) 1,900/ 2,000 2.7 ( Other than CA) 3,900 Golfer Dermal Spray/ Granular 1.3 ( Bayer max residential) 8,000 Toddler ( 3 year old)

Risks ( MOEs) to toddlers were calculated for postapplication risks following the application of triadimefon to home lawns. Table 17 summarizes the risk assessment for toddlers. Only one scenario, incidental soil ingestion, had MOEs > 1000. Short term MOEs were < 1000 for residential turf/ high contact activities, hand to mouth activities, object to mouth activities, and incidental ingestion of granules/ pellets.

Table 17: Toddler Residential Risk Estimates for Postapplication Exposure to Triadimefon Exposure Scenario Route of Exposure Formulation Application Rate ( lb ai/ A) MOE  Day 0b Outdoors 5.4/ 5.2 ( CA only) 230/ 240 2.7 ( Other than CA) 460 Residential Turf ( High Contact Activities) Dermal  with actual transferable residues ( TTR data) Residential Turf ( High Contact Activities) 1.3 ( Bayer max residential) 950 5.4/ 5.2 ( CA only) 52/ 55 2.7 ( Other than CA) 100 Hand to Mouth Activity on Turf Oral Spray/ Granular 1.3 ( Bayer max residential) 220 Page 111 of 114 Table 17: Toddler Residential Risk Estimates for Postapplication Exposure to Triadimefon Exposure Scenario Route of Exposure Formulation Application Rate ( lb ai/ A) MOE  Day 0b 5.4/ 5.2 ( CA only) 210/ 220 2.7 ( Other than CA) 420 Object to Mouth Activity on Turf Oral Spray/ Granular 1.3 ( Bayer max residential) 870 5.4/ 5.2 ( CA only) 16,000 2.7 ( Other than CA) 31,000 Incidental Soil Ingestion Oral Spray/ Granular 1.3 ( Bayer max residential) 65,000 Incidental Ingestion of Granules or Pellets Oral Granular 1% ai in formulation 62 Combined Risk Assessment for Residential Toddler Postapplication 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 18 presents a summary of the combined MOE estimates.

The combined risk assessment for exposures to toddlers following home lawn applications was calculated:

Combined MOE = NOAEL / ( ADDhand to mouth + ADDobject to mouth + ADDincidental soil ingestion + ADDdermal)

The combined risks were below 1000 for all application rates. Page 112 of 114 Table 18: Triadimefon Residential Scenarios for Combined Risk Estimates Margins of Exposure ( MOEs) ( UF= 1000) Postapplication Exposure Scenario Short Term MOE Combined MOE Turf  with actual transferable residues ( TTR data)

Hand to Mouth 52/ 55 Object to Mouth 210/ 220 Incidental Soil Ingestion 16,000 Sprays/ Granulars at 5.4/ 5.2 lb ai/ acre ( CA only)

Dermal 230/ 240 35/ 37 Hand to Mouth 100 Object to Mouth 420 Incidental Soil Ingestion 31,000 Sprays/ Granulars at 2.7 lb ai/ acre ( except CA)

Dermal 460 71 Hand to Mouth 220 Object to Mouth 870 Incidental Soil Ingestion 65,000 Toddler Sprays/ Granulars 1.3 lb ai/ acre ( Bayer max residential)

Dermal 950 150 Residential Postapplication Exposure to Turfgrass from Sod Farms An additional postapplication assessment was performed to assess the potential exposure of adults and toddlers to turf transplanted from sod farms into residential areas. Postapplication risks were assessed assuming the 2.7 lb ai/ A rate for sod farms, and attempting to estimate the number of days prior to harvest where the 2.7 lb/ A rate could be applied to sodfarms and not result in risks of concern to toddlers at residential sites. For dermal risks to toddlers, HED used the triadimefon specific turf transferable residue values and the triadimefon specific transfer coefficient for high contact dermal activities. For hand to mouth incidental oral ingestion risks to toddlers, HED assumed that day 0 residues were 5 percent of the application rate ( as specified in the Standard Operating Procedures for Residential Assessments) and used the dissipation slope from the triadimefon specific TTR study to estimate TTRs from day 1 and beyond. For object to mouth incidental oral ingestion risks to toddlers, HED assumed that day 0 residues were 20 percent of the application rate ( as specified in the Standard Operating Procedures for Residential Assessments) and used the dissipation slope from the triadimefon specific TTR study to estimate TTRs from day 1 and beyond. The results indicate that risks are not a concern ( i. e., the MOEs are   1000) for toddlers at day 5 for dermal exposures, at day 13 for hand to mouth exposures, at day 5 for object to mouth exposures, and at day 0 for soil ingestion exposures. The combined risks to toddlers are not a concern at day 15 following application to sodfarms at the 2.7 lb ai/ A rate. A summary of the risks are provided in Table 19. Page 113 of 114 Table 19. Residential Risk Estimates for Postapplication Exposure to Triadimefon Exposure Scenario Population Route of Exposure Formulation Application Rate ( lb ai/ A) Days after treatment when MOE

1000 MOE Adults 1,600 Residential Turf ( High Contact Activities) Toddlers Dermal Spray/ Granular 2.7 Day 5 1,200 Hand to Mouth Activity on Turf Toddlers Oral Spray/ Granular 2.7 Day 13 1,200 Object to Mouth Activity on Turf Toddlers Oral Spray/ Granular 2.7 Day 5 1,100 Incidental Soil Ingestion Toddlers Oral Spray/ Granular 2.7 Day 0 31,000 Aggregate exposure ( Dermal + Hand to mouth + Objectto Mouth + Soil Ingestion) Spray/ Granular 2.7 Day 15 1,100 3.2.4 Residential Postapplication Exposure and Risk Estimates for Cancer Residential postapplication cancer risks were not assessed for triadimefon, since no toxicological endpoint of concern was selected for cancer.

3.2.5 Summary of Residential Postapplication Risk Concerns and Data Gaps HED considered a number of exposure scenarios for products that can be used in the residential environment representing different segments of the population including toddlers, youth aged children, and adults. Short term MOEs were calculated for all scenarios. Cancer risks were not calculated, since no toxicological endpoint for cancer 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, Page 114 of 114 risk estimates on the day of application are the key concern.

In the assessment for residential postapplication exposure and risk, there are a number of risk concerns for triadimefon as it is currently used in a residential environment.

3.2.6 Recommendations for Refining Residential Postapplication Risk Assessments 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 triadimefon risks.