![](media/image1.png){width="0.875in" height="0.875in"}UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES

**[MEMORANDUM]{.underline}**

Date: February 1, 2006

Subj: **Propiconazole**: Revised Occupational and Residential Exposure
Assessment of the Antimicrobial Uses to Support the Reregistration
Eligibility Decision (RED) Document. PC Code: 122101. Reregistration
Case No. 3125. DP Barcode 324052.

From: Tim Leighton, Environmental Scientist

Antimicrobials Division/Regulatory Management Branch 2 (7510C)

Through: Mark Hartman, Branch Chief

Antimicrobials Division/Regulatory Management Branch 2 (7510C)

To: Stacey Grigsby, Chemical Review Manager

Antimicrobials Division/Regulatory Management Branch 2 (7510C)

And,

Yan Donovan, Risk Assessor

Health Effects Division/Registration Action Branch 4 (7509C)

The attached assessment is the revised draft occupational and
non-occupational (residential) exposure and risk estimates for the
antimicrobial uses of propiconazole to support HED's Reregistration
Eligibility Decision (RED) document. The revisions are based on the
"error-only" comments submitted by Janssen Pharmaceutica Inc.

Number range CHAPTER

**TABLE OF CONTENTS**

[EXECUTIVE SUMMARY 2](#__RefHeading___Toc120347501)

[1.0 INTRODUCTION 6](#__RefHeading___Toc120347506)

[**1.1** **Purpose** 6](#__RefHeading___Toc120347507)

[**1.2** **Criteria for Conducting Exposure Assessments**
6](#__RefHeading___Toc120347508)

[**1.3** **Chemical Identification** 8](#__RefHeading___Toc120347509)

[**1.4** **Physical/Chemical Properties**
8](#__RefHeading___Toc120347510)

[2.0 USE INFORMATION 8](#__RefHeading___Toc120347511)

[**2.1** **Formulation Types and Percent Active Ingredient**
8](#__RefHeading___Toc120347512)

[**2.2** **Summary of Use Pattern and Formulations**
8](#__RefHeading___Toc120347513)

[3.0 SUMMARY OF TOXICITY DATA 10](#__RefHeading___Toc120347514)

[**3.1** **Acute Toxicity** 10](#__RefHeading___Toc120347515)

[**3.2** **Summary of Toxicity Endpoints**
10](#__RefHeading___Toc120347517)

[**3.3** **FQPA Considerations** 12](#__RefHeading___Toc120347518)

[4.0 RESIDENTIAL EXPOSURE ASSESSMENT 12](#__RefHeading___Toc120347519)

[**4.1** **Summary of Registered Uses**
12](#__RefHeading___Toc120347520)

[**4.2** **Residential Exposure** 12](#__RefHeading___Toc120347523)

[4.2.1 Residential Handler Exposures 13](#__RefHeading___Toc120347525)

[4.2.2 Residential Post-application Exposures
14](#__RefHeading___Toc120347527)

[4.2.3 Data Limitations/Uncertainties 15](#__RefHeading___Toc120347534)

[5.0 RESIDENTIAL AGGREGATE RISK ASSESSMENT AND CHARACTERIZATION
15](#__RefHeading___Toc120347535)

[6.0 OCCUPATIONAL EXPOSURE ASSESSMENT 15](#__RefHeading___Toc120347538)

[**6.1** **Occupational Handler Exposures**
18](#__RefHeading___Toc120347540)

[**6.2** **Occupational Post-application Exposures**
23](#__RefHeading___Toc120347542)

[**6.3** **Metalworking Fluids: Machinist**
23](#__RefHeading___Toc120347543)

[**6.4** **Wood Preservation** 25](#__RefHeading___Toc120347552)

[6.4.1 Non-Pressure Treatment Scenarios (Handler and Post-application)
25](#__RefHeading___Toc120347553)

[6.4.1.1 Scenarios Assessed by Worker Function
25](#__RefHeading___Toc120347554)

[6.4.1.2 Scenarios Assessed for High Pressure/High Volume Spray
Application Methods 31](#__RefHeading___Toc120347558)

[6.4.2 Pressure Treatment Scenarios (Handler and Post-Application)
34](#__RefHeading___Toc120347559)

[**6.5** **Data Limitations/Uncertainties**
36](#__RefHeading___Toc120347560)

[7.0 REFERENCES 38](#__RefHeading___Toc120347561)

[APPENDIX A (Summary of CMA and PHED Data) :
40](#__RefHeading___Toc120347562)

[APPENDIX B (Calculation of DDAC Unit Exposure Values)
43](#__RefHeading___Toc120347565)

[]{#__RefHeading___Toc120347501 .anchor}**EXECUTIVE SUMMARY**

This document is the Occupational and Residential Exposure Chapter of
the Reregistration Eligibility Decision Document (RED) for
propiconazole. It addresses the potential risks to humans that result
from the use of this chemical in occupational and residential settings.

At this time, propiconazole is the active ingredient in material
preservative products (Use Site Category VII) and in wood preservation
products (Use Site Category X). As a materials preservative, the
products are used in items such as metalworking fluids, adhesives,
caulks, coatings, stains, paints, inks, paper, textiles[^1], canvas,
cordage, leather, and leather finishing pastes, fat liquors, or
finishes. As a wood preservative, the products can be used on green or
fresh cut lumber, poles, posts, and timbers; manufactured wood products
such as logs (including for log home construction), wood chips/sawdust,
plywood veneer, and particle board; dry lumber; and finished wood
products such as millwork, shingles, shakes, siding, plywood, and
structural lumber and composites. The majority of the products are
intended for use at wood treatment facilities; however, propiconazole is
also formulated for use in mushroom houses to protect timber trays and
benches and for use on cooling tower wood. The wood and wood products
can be treated through non-pressure treatment methods and pressure
treatment methods. The percentage of propiconazole in various products
can range from 0.1% to 50%. Products containing propiconazole are
formulated as liquid ready-to-use, soluble concentrates, emulsifiable
concentrates, and flowable concentrates.

The durations and routes of exposure evaluated in this assessment
include short-term (ST), intermediate-term (IT), and in some instances
long-term (LT) dermal and inhalation exposures as well as ST incidental
oral exposures. Short-term dermal, inhalation, and incidental oral
endpoints are based on an acute neurotoxicity (oral) study in rats. The
short-term endpoint (NOAEL) is 30 mg/kg/day for dermal, inhalation, and
incidental oral exposures. The adverse effects for these endpoints are
based on observations of clinical signs consisting piloerection,
diarrhea, and tip toe. The intermediate- and long-term dermal,
inhalation, and incidental oral toxicological endpoints are the same at
10 mg/kg/day. These endpoints are based on a 24 month oncogenicity
(oral) study in mice where adverse effects included increased liver
weight and liver lesions (masses/raised areas/ swellings/nodular areas
mainly) in males. A dermal absorption factor of 40% was used based the
results of a dermal absorption study. For inhalation assessments, an
absorption factor of 100% was used.

The Agency's level of concern for non-cancer risks (i.e., target level
for MOEs or Margins of Exposure) is defined by the uncertainty factors
that are applied to the assessment. The Agency applies a 10X factor to
account for inter-species extrapolation and a 10X factor to account for
intra-species variation. The total uncertainty factors that have been
applied to non-cancer risk assessments are 100 for occupational and
residential short- and intermediate-term scenarios. Propiconazole is
listed as a Group C, Possible Human Carcinogen. A cancer slope factor
was not identified for propiconazole, therefore a quantitative cancer
risk assessment is not provided at this time. Since the toxicity effects
were the same for dermal, inhalation and incidental oral exposures,
these exposures were combined for a total MOE for both occupational and
residential assessments.

Based on examination of product labels describing uses for the product,
it has been determined that exposure to handlers can occur in a variety
of occupational and residential environments. Additionally,
postapplication exposures are likely to occur only in the occupational
setting. The representative scenarios selected by the Antimicrobials
Division (AD) for assessment were evaluated using maximum application
rates as stated on the product labels.

To assess the handler risks, AD used surrogate unit exposure data from
the following proprietary resources: Chemical Manufacturers Association
(CMA) antimicrobial exposure study, the Pesticide Handlers Exposure
Database (PHED), *Measurement and Assessment of Dermal and Inhalation
Exposures to Didecyl Dimethyl Ammonium Chloride (DDAC) Used in the
Protection of Cut Lumber (Phase III) (*Bestari et al., 1999, MRID
455243-04 which is a Sapstain Industry Task Force Study, #73154), and
"*Assessment of Potential Inhalation and Dermal Exposure Associated with
Pressure Treatment of Wood with Arsenical Wood Products*" (ACC, 2002).
Additionally, EPA's Health Effects Division's (HED) *Standard Operating
Procedures (SOPs) for Residential Exposure Assessments* was used to
estimate postapplication/bystander exposures.

***Residential Handler Risk Summary***

For the [residential]{.underline} handler dermal and inhalation risk
assessment, all dermal, inhalation and total MOEs were above the target
MOE of 100.

[]{.mark}

***Occupational Handler Risk Summary***

For the [occupational]{.underline} handler dermal and inhalation risk
assessment, the MOEs were above the target MOE of 100 at either baseline
PPE/open pouring or through the use of mitigation (e.g., metering pumps)
for all scenarios except for the following scenarios listed below. The
reader is referred to Tables 6.2 through 6.10 to review the various
needs for PPE and/or metering pumps to mitigate risks for each scenario.
It should be noted that the baseline (ungloved) dermal MOEs for material
preservation of paints, textiles, adhesives, and metalworking fluid were
calculated using unit exposure values from the cooling tower CMA data
set because baseline dermal unit exposures are not available for
preservative or metal fluid categories.

Wood Preservation:

-   Wood Preservation, spray in wood treatment facility: IT/LT dermal
    MOE (gloves) at 50 gallons = **96**, IT/LT total MOE at 50 gallons =
    **86**

-   Wood Preservation, spray in mushroom house: IT dermal MOE (gloves)
    at 1,000 gallons = **56**, IT total MOE at 1,000 gallons = **50**.

-   Wood Preservation, treatment operator (pressure treatment): IT
    dermal MOE = **86** and IT total MOE = **86**

Material Preservation:

-   Painting, airless sprayer: IT baseline dermal MOE = **26** and IT
    gloved dermal MOE **= 71**. IT baseline total MOE = **25** and IT
    gloved total MOE = **62**.

[]{.mark}

***Occupational Post-application/Bystander Risk Summary***

[]{.mark}

For the [occupational]{.underline} postapplication risk assessment, the
MOEs were above target MOE of 100, and therefore not of concern for all
scenarios except the following:

[]{.mark}

Wood Preservation:

-   Wood Preservation, clean-up worker (non-pressure treatment): IT/LT
    dermal MOE = **51** and IT/LT total MOE = **49**.

***Data Limitations and Uncertainties:***

There are a number of uncertainties associated with this assessment and
these have been reiterated from Sections 4.4.3 (residential) and 6.5
(occupational) respectively.

The data limitations and uncertainties associated with the residential
handler and postapplication exposure assessments include the following:

-   Surrogate dermal and inhalation unit exposure values were taken from
    the Pesticide Handler Exposure Database (USEPA, 1998) (See Appendix
    A for summary of this database).

-   The quantities handled/treated were estimated based on information
    from various sources, including HED's Standard Operating Procedures
    (SOPs) for Residential Exposure Assessments (USEPA 2000, and 2001)
    and AD standard assumptions. In certain cases, no standard values
    were available for some scenarios. Assumptions for these scenarios
    were based on AD estimates and could be further refined from input
    from registrants.

-   Propiconazole is used on many different types of wood. AD needs
    additional information on the "dry lumber" uses. The other wood
    treatments would result in minimal dermal and/or incidental oral
    exposure. Inhalation exposure (e.g., in log homes treated with
    propiconazole) is also expected to be negligible based on the low
    vapor pressure. The "dry lumber" uses need to be defined by the
    registrant to determine if propiconazole-treated lumber is used to
    build residential decks and/or play sets. There is the potential for
    dermal exposure to treated lumber for uses in decks and or play
    sets. To complete an assessment, dislodgeable residues from treated
    wood need to be generated (i.e., wipe studies).

[]{.mark}

The data limitations and uncertainties associated with the occupational
handler and postapplication exposure assessments include:

[]{.mark}

-   Surrogate dermal and inhalation unit exposure values were taken from
    the proprietary Chemical Manufacturers Association (CMA)
    antimicrobial exposure study (USEPA, 1999: DP Barcode D247642) or
    from the Pesticide Handler Exposure Database (USEPA, 1998) (See
    Appendix A for summaries of these data sources). Since the CMA data
    are of poor quality, the Agency requests that confirmatory data be
    submitted to support the occupational scenarios assessed in this
    document.

-   The baseline (ungloved) dermal exposures and risks for material
    preservation of paints, textiles, adhesives, and metalworking fluid
    were calculated using unit exposure values from the cooling tower
    CMA data set because baseline dermal unit exposures are not
    available for preservative or metal fluid CMA unit exposure
    categories.

-   For the wood preservative pressure treatment scenarios, proprietary
    CCA exposure data were used for lack of propiconazole-specific
    exposure data and for the wood preservative non-pressure treatment
    scenarios, proprietary DDAC exposure data were used for the lack of
    propiconazole-specific exposure data. Limitations and uncertainties
    associated with the use of these data include:

```{=html}
<!-- -->
```
-   The assumption was made that exposure patterns for workers at
    treatment facilities using CCA and DDAC would be similar to exposure
    patterns for workers at treatment facilities using propiconazole,
    and therefore the exposures could be used as surrogate data for
    workers that treat wood with propiconazole.

-   For environmental modeling, it was assumed that the leaching process
    from the propiconazole treated wood would be similar to that of CCA
    and DDAC. However, due to the lack of real data for propiconazole
    -treated wood, it is not possible to verify this assumption.

[]{.mark}

-   The quantities handled/treated were estimated based on information
    from various sources, including HED's Standard Operating Procedures
    (SOPs) for Residential Exposure Assessments (USEPA 2000, and 2001)
    and AD standard assumptions. In certain cases, no standard values
    were available for some scenarios. Assumptions for these scenarios
    were based on AD estimates and could be further refined from input
    from registrants. In particular, the quantities handled/treated for
    the application of propiconazole to wood in mushroom houses through
    high pressure/high volume spray methods could be further refined.

    []{#__RefHeading___Toc120347506 .anchor}**1.0 INTRODUCTION**

    []{#__RefHeading___Toc120347507 .anchor}**1.1 Purpose**

In this document, the Antimicrobials Division (AD) presents the results
of its review of the potential human health effects of occupational and
residential exposure to propiconazole. This information is for use in
EPA\'s development of the propiconazole Reregistration Eligibility
Decision Document (RED).

[]{#__RefHeading___Toc120347508 .anchor}**1.2 Criteria for Conducting
Exposure Assessments**

An occupational and/or residential exposure assessment is required for
an active ingredient if (1) certain toxicological criteria are triggered
[and]{.underline} (2) there is potential exposure to handlers (mixers,
loaders, applicators, etc.) during use or to persons entering treated
sites after application is complete. For propiconazole, both criteria
are met.

In this document, scenarios were assessed by using *unit exposure* data
to estimate occupational and residential handlers' exposures. *Unit
exposures* are estimates of the amount of exposure to an active
ingredient a handler receives while performing various handler tasks and
are expressed in terms of micrograms or milligrams (1 mg = 1,000 µg) of
active ingredient per pounds of active ingredient handled. A series of
unit exposures have been developed that are unique for each scenario
typically considered in assessments (i.e., there are different unit
exposures for different types of application equipment, job functions,
and levels of protection). The *unit exposure* concept has been
established in the scientific literature and also through various
exposure monitoring guidelines published by the USEPA and international
organizations such as Health Canada and OECD (Organization for Economic
Cooperation and Development).

Using surrogate unit exposure data, maximum application rates from
labels, and EPA estimates of daily amount handled, exposures and risks
to handlers were assessed. The exposure/risks were calculated using the
following equations:

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

*Daily Exposure: E = UE* x *AR* x *AT* **(Eq. 1)**

Where:

E = Amount (mg ai/day) deposited on the surface of the skin that is
available for dermal absorption or amount inhaled that is available for
inhalation absorption;

UE = Unit exposure value (mg ai/lb ai) derived from August 1998 PHED
data or from 1992 CMA data;

AR = Maximum application rate based on a logical unit treatment, such as
acres (A), square feet (sq. ft.), gallons (gal), or cubic feet (cu. ft).
Maximum values are generally used (lb ai/A, lb ai/sq ft, lb ai/gal, lb
ai/cu ft); and

AT = Normalized application area based on a logical unit treatment such
as acres (A/day), square feet (sq ft/day), gallons (gal/day), or cubic
feet (cu ft/day).

**Daily Dose:** The daily dermal or inhalation dose is calculated by
normalizing the daily exposure by body weight and adjusting, if
necessary, with an appropriate absorption factor. An absorption factor
of 40% was used for dermal exposures and an absorption factor of 100%
was used for inhalation exposures since the endpoint was based on an
oral study. Daily dose was calculated using the following formula:

*Daily Dose: ADD = [E ]{.underline}*[x *ABS*]{.underline} **(Eq. 2)**

*BW*

Where:

ADD = Average daily dose or the absorbed dose received from exposure to
a chemical in a given scenario (mg active ingredient/kg body
weight/day);

E = Amount (mg ai/day) deposited on the surface of the skin that is
available for dermal absorption or amount inhaled that is available for
inhalation absorption;

ABS = A measure of the amount of chemical that crosses a biological
boundary such as lungs (% of the total available absorbed); and

BW = Body weight determined to represent the population of interest in a
risk assessment (kg).

**Margins of Exposure:** Non-cancer inhalation and dermal risks for each
applicable handler scenario are calculated using a Margin of Exposure
(MOE), which is a ratio of the daily dose to the toxicological endpoint
of concern.

*Margins of Exposure: MOE =* [NOAEL *or* LOAEL]{.underline} **(Eq. 3)**

*ADD*

Where:

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

NOAEL or LOAEL = Dose level in a toxicity study, where no observed
adverse effects (NOAEL) or where the lowest observed adverse effects
(LOAEL) occurred in the study (mg/kg/day); and

ADD = Average daily dose or the absorbed dose received from exposure to
a chemical in a given scenario (mg ai/kg body weight/day).

In addition to the target MOEs from Table 3.2 that were used for the
analysis, a series of assumptions and exposure factors served as the
basis for completing the handler risk assessment. Each general
assumption and factor for both residential and occupational assessments
is detailed below. Assumptions specific to the use site category are
listed in each separate section of this document. The general
assumptions and factors include:

-   Propiconazole products are widely used and have a large number of
    use patterns that are difficult to completely capture in this
    document. As such, AD has patterned this risk assessment on a series
    of likely representative scenarios for each use site that are
    believed by AD to represent the vast majority of propiconazole uses.

```{=html}
<!-- -->
```
-   The average body weight of an adult handler of 70 kg was used to
    complete the non-cancer risk assessment.

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

```{=html}
<!-- -->
```
-   The maximum application rates allowed by labels were assumed.

    []{#__RefHeading___Toc120347509 .anchor}**1.3 Chemical
    Identification**

Propiconazole is identified as follows:

-   Common/Chemical Name: Propiconazole

```{=html}
<!-- -->
```
-   PC Code: 122101

```{=html}
<!-- -->
```
-   CAS Number: 60207-90-1

    []{#__RefHeading___Toc120347510 .anchor}**1.4 Physical/Chemical
    Properties**

Table 1.1 shows physical/chemical characteristics that have been
reported for propiconazole.

  -------------------------------- --------------------------------------
  **Table 1.2. Physical/Chemical   
  Properties of Propiconazole**    

  Parameter                        Propiconazole

  Molecular Weight                 342.23

  Density                          1.27 g/ cm^3^

  Boiling Point                    180 C at 0.1 mmHg

  Water Solubility                 110 ppm at 20 C

  Vapor Pressure                   1.0 x 10^-6^ mmHg at 20 C
  -------------------------------- --------------------------------------

[]{#__RefHeading___Toc120347511 .anchor}**2.0 USE INFORMATION**

[]{#__RefHeading___Toc120347512 .anchor}**2.1 Formulation Types and
Percent Active Ingredient**

The products containing propiconazole as the active ingredient (a.i) are
formulated as liquid ready-to-use, soluble concentrates, emulsifiable
concentrates, and flowable concentrates. Concentrations of propiconazole
in these products range from 0.1% to 50%.

[]{#__RefHeading___Toc120347513 .anchor}**2.2 Summary of Use Pattern and
Formulations**

The Agency determines potential exposures to handlers of the product by
identifying exposure scenarios from the various application methods that
are plausible, given the label uses. These scenarios are identified in
Table 2.1. Based on a review of product labels, propiconazole is the
active ingredient in material preservation products (Use Site Category
VII) and in wood preservation products (Use Site Category X). As a
materials preservative, the products are used in items such as
metalworking fluids, adhesives, caulks, coatings, stains, paints, inks,
paper, textiles[^2], canvas, cordage, leather, and leather finishing
pastes, fat liquors, or finishes. As wood preservative, the products can
be used on green or fresh cut lumber, poles, posts, and timbers;
manufactured wood products such as logs (including for log home
construction), wood chips/sawdust, plywood veneer, and particle board;
dry lumber; and finished wood products such as millwork, shingles,
shakes, siding, plywood, and structural lumber and composites. The
majority of the products are intended for use at wood treatment
facilities, however, propiconazole is also formulated for use in
mushroom houses to protect timber trays and benches and for use on
cooling tower wood. The wood and wood products can be treated through
non-pressure treatment methods and pressure treatment methods.

From Table 2.1, AD selected representative exposure scenarios to assess
the labeled uses of propiconazole in this document. These scenarios were
selected to be representative of the vast majority of uses and are
believed to provide high-end degrees of dermal or inhalation, exposure.
The representative scenarios assessed in this document are shown in
Table 4.1 (residential) and Table 6.1 (occupational).

+-----------------+------------------------+--------------------------+
| **Table 2.1.    |                        |                          |
| Potential Use   |                        |                          |
| Scenarios Based |                        |                          |
| on Product      |                        |                          |
| Labels for      |                        |                          |
| Propiconazole** |                        |                          |
+=================+========================+==========================+
| Registration    | Example Use Sites      | Scenarios                |
| Numbers         |                        |                          |
+-----------------+------------------------+--------------------------+
| **Use Site      |                        |                          |
| Category VII -  |                        |                          |
| Material        |                        |                          |
| Preservatives** |                        |                          |
+-----------------+------------------------+--------------------------+
| 5383-114,       | Used in the production | -   Adhesives            |
| 1448-394,       | of various household,  |                          |
| 3813-19,        | institutional and      | -   Caulks               |
| 43813-37,       | industrial items       |                          |
| 43813-16,       |                        | -   Coatings (including  |
| 70227-6,        |                        |     paper, roof and      |
| 71406-1         |                        |     stucco and EIFS      |
|                 |                        |     coatings)            |
|                 |                        |                          |
|                 |                        | -   Inks                 |
|                 |                        |                          |
|                 |                        | -   Joint cements        |
|                 |                        |                          |
|                 |                        | -   Leather              |
|                 |                        |                          |
|                 |                        | -   Leather finishing    |
|                 |                        |     pastes, fatliquors,  |
|                 |                        |     or finishes          |
|                 |                        |                          |
|                 |                        | -   Metalworking fluids  |
|                 |                        |                          |
|                 |                        | -   Paints               |
|                 |                        |                          |
|                 |                        | -   Sealants             |
|                 |                        |                          |
|                 |                        | -   Stains               |
|                 |                        |                          |
|                 |                        | -   Canvas, and cordage  |
|                 |                        |     (through dye         |
|                 |                        |     incorporation, pad,  |
|                 |                        |     exhaust, or spray    |
|                 |                        |     application)         |
+-----------------+------------------------+--------------------------+
| **Use Site      |                        |                          |
| Category X -    |                        |                          |
| Wood            |                        |                          |
| Preservatives** |                        |                          |
+-----------------+------------------------+--------------------------+
| 1022-585,       | -   Fresh lumber,      | -   Non-pressure         |
| 1448-394,       |     poles, posts,      |     treatment of wood    |
| 1448-414,       |     timbers            |     and wood products    |
| 5383-114^a^,    |                        |     through methods such |
| 43813-15,       | -   Dry lumber         |     as dipping,          |
| 43813-16^b^,    |                        |     conventional spray   |
| 43813-19,       | -   Wood products such |     system, spray box,   |
| 43813-37^c^,    |     as logs (including |     low pressure spray,  |
| 57227-3,        |     log home           |     high pressure spray, |
| 57227-6,        |     construction,      |     low volume spray     |
| 60061-102^d^,   |     poles, timbers),   |     machine, immersion,  |
| 60061-107,      |     particle board,    |     brush, roller        |
| 60061-109,      |     wafer board, wood  |     coater, and flood.   |
| 60061-112,      |     chips, saw dust,   |                          |
| 60061-114,      |     and plywood        | -   Pressure treatment   |
| 60061-115,      |                        |     of wood and wood     |
| 62190-12,       | -   Wood in cooling    |     products through     |
| 62190-17,       |     towers             |     methods such as      |
| 70227-4,        |                        |     vacuum, full-cell,   |
| 70227-6,        | -   Wood in mushroom   |     and modified         |
| 71406-1,        |     houses             |     full-cell.           |
| 72616-1,        |                        |                          |
| 74405-1,        |                        | -   Spray and paint      |
| 75101-1         |                        |     cooling tower wood   |
|                 |                        |                          |
|                 |                        | -   Pouring of product   |
|                 |                        |     into cooling tower   |
|                 |                        |     water for protection |
|                 |                        |     of wood              |
|                 |                        |                          |
|                 |                        | -   Spray (large droplet |
|                 |                        |     sprayer) or dip wood |
|                 |                        |     trays and boards in  |
|                 |                        |     mushroom house       |
+-----------------+------------------------+--------------------------+

a\. Label 5383-114 does not provide an application method.

b\. Label 43813-16 does not specifically indicate if the cooling tower
wood is treated before or after manufacture of the cooling tower.

c\. Label 43813-37 indicates a maximum of 1% ai solution for
non-pressure treatment methods such as immersion, roller coater, flood,
spray, and brush

d\. Label 60061-102 indicates that the product (Kop-Coat Woodtreat-10)
is to be used only in combination with Kop-Coats sapstain control
products.

[]{#__RefHeading___Toc120347514 .anchor}**3.0 SUMMARY OF TOXICITY DATA**

[]{#__RefHeading___Toc120347515 .anchor}**3.1 Acute Toxicity**

The acute toxicity data for propiconazole are summarized below in Table
3.1 (USEPA, 2003).

+--------+----------------+----------+-----------------+--------------+
| *      |                |          |                 |              |
| *Table |                |          |                 |              |
| 3.1.   |                |          |                 |              |
| Acute  |                |          |                 |              |
| To     |                |          |                 |              |
| xicity |                |          |                 |              |
| P      |                |          |                 |              |
| rofile |                |          |                 |              |
| for    |                |          |                 |              |
| Pro    |                |          |                 |              |
| picona |                |          |                 |              |
| zole** |                |          |                 |              |
+========+================+==========+=================+==============+
| Gui    | Study Type     | MRID \#  | Results         | Toxicity     |
| deline |                |          |                 | Category     |
|        |                |          |                 |              |
| No.    |                |          |                 |              |
+--------+----------------+----------+-----------------+--------------+
| 81-1   | Acute Oral -   | 00058591 | LD~50~ =1517    | III          |
|        | rat            |          | mg/kg           |              |
+--------+----------------+----------+-----------------+--------------+
| 81-2   | Acute          | 00058596 | LD~50~ = \>4000 | III          |
|        | Dermal-rabbit  |          | mg/kg           |              |
+--------+----------------+----------+-----------------+--------------+
| 81-3   | Acute          | 41594801 | LC~50~ =        | IV           |
|        | Inhalation -   |          | \>50.84 mg/L    |              |
|        | rat            |          |                 |              |
+--------+----------------+----------+-----------------+--------------+
| 81-4   | Primary Eye    | 00058597 | Corneal opacity | III          |
|        | Irritation     |          | reversed in 72  |              |
|        |                |          | hours           |              |
+--------+----------------+----------+-----------------+--------------+
| 81-5   | Primary Skin   | 00058598 | No irritation   | IV           |
|        | Irritation     |          |                 |              |
+--------+----------------+----------+-----------------+--------------+
| 81-6   | Dermal         | 00058600 | Non sensitizer  | \-           |
|        | Sensitization  |          |                 |              |
+--------+----------------+----------+-----------------+--------------+

[]{#__RefHeading___Toc120347517 .anchor}**3.2 Summary of Toxicity
Endpoints**

Table 3.2 summarizes the toxicological endpoints for propiconazole
(USEPA, 2003).

+-------------+-------------+---------------+-------------------------+
| **Table 3.2 |             |               |                         |
| Summary of  |             |               |                         |
| To          |             |               |                         |
| xicological |             |               |                         |
| Doses and   |             |               |                         |
| Endpoints   |             |               |                         |
| for         |             |               |                         |
| Pr          |             |               |                         |
| opiconazole |             |               |                         |
| for Use in  |             |               |                         |
| Human Risk  |             |               |                         |
| As          |             |               |                         |
| sessments** |             |               |                         |
+=============+=============+===============+=========================+
| Exposure    | Dose Used   | Special FQPA  | Study and Toxicological |
|             | in Risk     | SF\* and      | Effects                 |
| Scenario    | Assessment, | Level of      |                         |
|             | UF          | Concern for   |                         |
|             |             | Risk          |                         |
|             |             | Assessment    |                         |
+-------------+-------------+---------------+-------------------------+
| Number      | Number      | Number range  | Number range            |
| range       | range       | CHAPTERFQPA   | CHAPTERDevelopmental    |
| C           | CHAPTERDev. | SF = 1X       | Toxicity Study - Rats.  |
| HAPTERAcute | NOAEL = 30  |               | Increased incidence of  |
| Dietary     | mg          | aPAD =        | rudimentary ribs, cleft |
|             | ai/kg/day   |               | palate malformations    |
| (Females    |             | [acute        | (0.3%) unossified       |
| 13-50)      | UF =100     | RfD           | sternebrae, as well as  |
|             |             | ]{.underline} | increased incidence of  |
|             | Acute RfD = |               | shortened and absent    |
|             | 0.3         | FQPA SF       | renal papillae.         |
|             | mg/kg/day   |               |                         |
|             |             | = 0.3         |                         |
|             |             | mg/kg/day     |                         |
+-------------+-------------+---------------+-------------------------+
| Acute       | NOAEL = 30  | FQPA SF = 1X  | Acute Neurotoxicity     |
| Dietary     | mg ai/kg    |               | Study - Rats.           |
|             |             | aPAD =        |                         |
| (General    | UF =100     |               | Clinical toxicity:      |
| Population  |             | [acute        | piloerection, diarrhea, |
| including   | Acute RfD   | RfD           | tip toe at 100 mg/kg    |
| infants and | =0.3        | ]{.underline} |                         |
| children)   | mg/kg/day   |               |                         |
|             |             | FQPA SF       |                         |
|             |             |               |                         |
|             |             | =0.3          |                         |
|             |             | mg/kg/day     |                         |
+-------------+-------------+---------------+-------------------------+
| Chronic     | NOAEL = 10  | 1X            | 24 Month Oncogenicity   |
| Dietary     | mg          |               | Study - Mice.           |
|             | ai/kg/day   | cPAD =        |                         |
| (All        |             |               | Liver toxicity          |
| p           | UF = 100    | [chronic      | (increased liver weight |
| opulations) |             | RfD           | in males and increase   |
|             | Chronic RfD | ]{.underline} | in liver lesions        |
|             | = 0.1       |               | (masses/raised areas/   |
|             | mg/kg/day   | FQPA SF       | swellings/nodular areas |
|             |             |               | mainly)                 |
|             |             | =0.1          |                         |
|             |             | mg/kg/day     |                         |
+-------------+-------------+---------------+-------------------------+
| Short-Term  | NOAEL=30 mg | Residential   | Acute Neurotoxicity     |
|             | ai/kg       | MOE = 100     | Study - Rats.           |
| (1-30 days) |             |               |                         |
| Incidental  |             | Occupational  | Clinical toxicity:      |
| Oral        |             | = NA          | piloerection, diarrhea, |
|             |             |               | tip toe at 100 mg/kg    |
+-------------+-------------+---------------+-------------------------+
| Interm      | NOAEL= 10   | Residential   | 24 Month Oncogenicity   |
| ediate-Term | mg          | MOE = 100     | Study - Mice.           |
| (1 - 6      | ai/kg/day   |               |                         |
| months)     |             | Occupational  | Liver toxicity          |
| Incidental  |             | = NA          | (increased liver weight |
| Oral        |             |               | in males and increase   |
|             |             |               | in liver lesions        |
|             |             |               | (masses/raised areas/   |
|             |             |               | swellings/nodular areas |
|             |             |               | mainly)                 |
+-------------+-------------+---------------+-------------------------+
| Short-Term  | Oral NOAEL= | Residential   | Acute Neurotoxicity     |
|             | 30 mg ai/kg | MOE = 100     | Study - Rats.           |
| (1 - 30     |             |               |                         |
| days)       | (Dermal     | Occupational  | Clinical toxicity:      |
| Dermal      | absorption  | MOE = 100     | piloerection, diarrhea, |
|             | rate = 40%) |               | tip toe at 100 mg/kg    |
| (General    |             |               |                         |
| Pop.        |             |               |                         |
| including   |             |               |                         |
| infants and |             |               |                         |
| children)   |             |               |                         |
+-------------+-------------+---------------+-------------------------+
| Interm      | Oral NOAEL= | Residential   | 24 Month Oncogenicity   |
| ediate-Term | 10 mg       | MOE = 100     | Study - Mice.           |
| (1 - 6      | ai/kg/day   |               |                         |
| months) and |             | Occupational  | Liver toxicity          |
| Long-Term   | (Dermal     | MOE = 100     | (increased liver weight |
| Dermal      | absorption  |               | in males and increase   |
|             | rate = 40%) |               | in liver lesions        |
| (\>6        |             |               | (masses/raised areas/   |
| months)     |             |               | swellings/nodular areas |
|             |             |               | mainly)                 |
+-------------+-------------+---------------+-------------------------+
| Short-Term  | Oral NOAEL= | Residential   | Acute Neurotoxicity     |
|             | 30          | MOE = 100     | Study - Rats.           |
| (1 - 30     | mg/kg/day   |               |                         |
| days)       |             | Occupational  | Clinical toxicity:      |
| Inhalation  | (Inhalation | MOE = 100     | piloerection, diarrhea, |
|             | absorption  |               | tip toe at 100 mg/kg    |
|             | rate =      |               |                         |
|             | 100%)       |               |                         |
+-------------+-------------+---------------+-------------------------+
| Interm      | Oral NOAEL= | Residential   | 24 Month Oncogenicity   |
| ediate-Term | 10          | MOE = 100     | Study - Mice.           |
| (1 - 6      | mg/kg/day   |               |                         |
| months) and |             | Occupational  | Liver toxicity          |
| Long-Term   | (Inhalation | MOE = 100     | (increased liver weight |
| Inhalation  | absorption  |               | in males and increase   |
|             | rate =      |               | in liver lesions        |
| (\>6        | 100%)       |               | (masses/raised areas/   |
| months)     |             |               | swellings/nodular areas |
|             |             |               | mainly)                 |
+-------------+-------------+---------------+-------------------------+
| Cancer      | Group C,    |               |                         |
|             | possible    |               |                         |
| (Oral,      | human       |               |                         |
| dermal,     | carcinogen  |               |                         |
| inhalation) |             |               |                         |
+-------------+-------------+---------------+-------------------------+

UF = uncertainty factor, FQPA SF = special FQPA safety factor, NOAEL =
no observed adverse effect level, LOAEL = lowest observed adverse effect
level, PAD = population adjusted dose (a = acute, c = chronic), RfD =
reference dose, MOE = margin of exposure, LOC = Level of concern, NA =
Not Applicable.

It should be noted that although the target inhalation MOE is 100, if
the MOE is below 1,000 the Agency may request a confirmatory inhalation
toxicity study because the current inhalation endpoint is based on an
oral NOAEL.

[]{#__RefHeading___Toc120347518 .anchor}

**3.3 FQPA Considerations**

It has been determined by the HED Hazard Identification Assessment
Review Committee (HIARC) that Number range CHAPTERno special FQPA safety
factor is required for propiconazole because there are no residual
uncertainties for pre and/or post natal toxicity. For a more thorough
review of the FQPA safety factor the reader is referred to the HIARC
report (USEPA 2003a).

[]{#__RefHeading___Toc120347519 .anchor}**4.0 RESIDENTIAL EXPOSURE
ASSESSMENT**

[]{#__RefHeading___Toc120347520 .anchor}**4.1 Summary of Registered
Uses**

Some products containing propiconazole can be used as a material
preservative in a variety of products, such as textiles and paints,
which can result in exposure to residential users handling the treated
products. Table 2.1 presents a summary of all exposure scenarios,
including those scenarios which may occur in residential settings*.*
Table 4.1 identifies the representative exposure scenarios assessed in
this document. It should be noted that Syngenta and Janssen agree to
withdraw the use of propiconazole for the treating of carpet fibers,
apparel, and furnishings. The primary textile use includes "canvas"
(i.e., awnings, boat covers, carpet backing, cordage, tents, tarpaulins,
and wall coverings).

[]{#__RefHeading___Toc120347523 .anchor}**4.2 Residential Exposure**

The exposure scenarios assessed in this document for the representative
uses selected by AD are shown in Table 4.1. The table also shows the
maximum application rate associated with the representative use and the
EPA Registration number for the corresponding product label. Handler
exposures were assessed for the application of propiconazole used as a
material preservative in paint (paint brush/roller and airless sprayer).
Based on the low vapor pressure of propiconazole, no post application
inhalation exposure is anticipated to occur. Furthermore, based on the
new use patterns (i.e., no treated fibers/textiles) in the residential
setting, no post-application exposures are expected to occur.

+-------------+--------------+--------+-----------+-----------------+
| **Table     |              |        |           |                 |
| 4.1.        |              |        |           |                 |
| Rep         |              |        |           |                 |
| resentative |              |        |           |                 |
| Uses        |              |        |           |                 |
| Associated  |              |        |           |                 |
| with        |              |        |           |                 |
| Residential |              |        |           |                 |
| Exposure to |              |        |           |                 |
| Prop        |              |        |           |                 |
| iconazole** |              |        |           |                 |
+=============+==============+========+===========+=================+
| Rep         | Exposure     | Appli  | Reg       | Application     |
| resentative | Scenario     | cation | istration | Rate            |
| Use         |              | Method | \#        |                 |
+-------------+--------------+--------+-----------+-----------------+
| Using       | ST Handler:  | Paint  | 5383-114  | 0.35% a.i. by   |
| treated     | Adult dermal | brush/ |           | weight of       |
| paint       | and          |        |           | material to be  |
|             | inhalation   | ro     |           | preserved       |
|             | (aerosols)   | llers, |           |                 |
|             |              |        |           | (5% product by  |
|             |              | a      |           | weight of       |
|             |              | irless |           | material        |
|             |              | s      |           | treated x 7%    |
|             |              | prayer |           | a.i. in the     |
|             |              |        |           | product)        |
+-------------+--------------+--------+-----------+-----------------+

ST = Short-term exposure

[]{#__RefHeading___Toc120347525 .anchor}**4.2.1 Residential Handler
Exposures**

The residential handler scenarios described in Table 4.1 were assessed
to determine dermal and inhalation exposures. The scenarios were
assessed using PHED data and Equations 1-3 in Section 1.2, "Criteria for
Conducting Risk Assessment." A summary of the PHED data set is presented
in Appendix A.

**Unit Exposure Values**: Unit exposure values were taken from the PHED
data presented in HED's Residential SOPs (USEPA, 1997).

-   For the ***airless sprayer*** scenario, PHED dermal and inhalation
    unit exposure values for a residential handler applying a pesticide
    using an airless sprayer were used. These unit ungloved exposure
    values (79 mg/lb a.i. for dermal and 0.83 mg/lb a.i. for inhalation)
    represent a handler wearing short pants and a short sleeve shirt,
    with no gloves.

-   For the ***brush/roller*** scenario***,*** PHED dermal and
    inhalation unit exposure values for a residential handler applying a
    pesticide in paint using a paint brush to paint a bathroom were
    used. These unit exposure values (230 mg/lb a.i. for dermal and
    0.284 mg/lb a.i. for inhalation) represent a handler wearing short
    pants and a short sleeve shirt, with no gloves.

**Quantity handled/treated**: The quantities handled/treated were
estimated based on information from various sources, including AD's
standard assumptions.

-   For the ***airless sprayer*** in paint applications, it is assumed
    that 15 gallons (or 150 lb/day, assuming paint has a density of 10
    lb/gal) of treated paint will be used per day (USEPA, 2005b).

-   For the ***brush/roller*** in paint applications, it is assumed that
    2 gallons (or 20 lb/day, assuming paint has a density of 10 lb/gal)
    of treated paint will be used per day (USEPA, 2005b).

**Duration of Exposure:** The duration of exposure for most homeowner
applications of paint is believed to be best represented by the
short-term duration (1 to 30 days). The reason that short term duration
was chosen to be assessed is because the different handler and
post-application scenarios are assumed to be episodic, not daily. In
addition, homeowners are assumed to use different products with varying
actives, not exclusively propiconazole treated products.

**[Results]{.underline}**

The resulting short-term exposures and MOEs for the representative
residential handler scenarios are presented in Table 4.2. The calculated
dermal and total MOEs were above the target MOE of 100 for both
scenarios (330 for brush/roller and 130 for airless spray). The
inhalation MOEs were also well above the target MOE of 100.

Although the target inhalation MOE is 100, if the MOE is below 1,000 the
Agency may request a confirmatory inhalation toxicity study because the
current inhalation endpoint is based on an oral NOAEL. All short-term
inhalation MOEs exceeded 1,000 therefore, a confirmatory inhalation
toxicity study is **not** warranted based on the results of these
exposure scenarios.

<table>
<colgroup>
<col style="width: 16%" />
<col style="width: 10%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 10%" />
<col style="width: 8%" />
<col style="width: 10%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="10"><strong>Table 4.2 Short-Term Residential Handlers
Exposures and MOEs</strong></td>
</tr>
<tr class="even">
<td rowspan="2">Exposure Scenario --Application Method</td>
<td rowspan="2">Application Rate<sup>a</sup></td>
<td rowspan="2">Quantity Handled/ Treated per day<sup>b</sup></td>
<td colspan="2"><p>Unit Exposure</p>
<p>(mg/lb a.i.)</p></td>
<td colspan="2">Absorbed Daily Dose (mg/kg/day) <sup>e</sup></td>
<td colspan="3">MOE <sup>f</sup></td>
</tr>
<tr class="odd">
<td>Dermal<sup>c</sup></td>
<td>Inhalation<sup>d</sup></td>
<td>Dermal</td>
<td>Inhalation</td>
<td>Dermal (Target = 100)</td>
<td>Inhalation (Target = 100)</td>
<td>TOTAL MOE <sup>g</sup> (Target = 100)</td>
</tr>
<tr class="even">
<td>Painting -- Brush/Roller</td>
<td>0.35% a.i. by weight</td>
<td>20 lbs</td>
<td>230</td>
<td>0.284</td>
<td>0.092</td>
<td>0.0003</td>
<td>330</td>
<td>110,000</td>
<td>330</td>
</tr>
<tr class="odd">
<td><p>Painting—</p>
<p>Airless Sprayer</p></td>
<td>0.35% a.i. by weight</td>
<td>150 lbs</td>
<td>79</td>
<td>0.83</td>
<td>0.24</td>
<td>0.0062</td>
<td>130</td>
<td>4,800</td>
<td>120</td>
</tr>
</tbody>
</table>

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

b Amount handled per day values are estimates based on AD's standard
assumptions.

c All dermal unit exposures represent ungloved, short-sleeve shirt, and
short pants replicates.

d Baseline = No respirator

e Absorbed Daily dose (mg/kg/day) = \[unit exposure (mg/lb a.i.) \*
application rate (% a.i. weight) \* quantity treated (lb/day) \*
absorption factor (0.4 for dermal; 1.0 for inhalation)\]/ Body weight
(70 kg).

f MOE = NOAEL / Absorbed Daily Dose. \[Where short-term NOAEL = 30
mg/kg/day for dermal and inhalation\]. Target MOE is 100.

g Total MOE = 1/((1/Dermal ST MOE) + (1/Inhalation ST MOE)). The target
MOE is 100.

[]{#__RefHeading___Toc120347527 .anchor}**4.2.2 Residential
Post-application Exposures**

As previously stated, post-application residential scenarios were not
necessary to assess because of propiconazole's low vapor pressure
(therefore, no inhalation exposure) and the registrants' deletion of the
only other residential use (i.e., materials preservative in fabrics,
textiles, are carpet fibers).

Additionally, propiconazole is used to treat various types of wood.
Propiconazole is used on many different types of wood including 1) green
or fresh cut lumber, poles, posts, and timbers; 2) manufactured wood
products such as logs (including for log home construction), wood
chips/sawdust, plywood veneer, and particle board; 3) dry lumber; and 4)
finished wood products such as millwork, shingles, shakes, siding,
plywood, and structural lumber and composites. From these 4 groupings,
AD needs additional information on the "dry lumber" uses. The other 3
groupings would result in minimal dermal and/or incidental oral
exposure. Inhalation exposure (e.g., in log homes treated with
propiconazole) is also expected to be negligible based on the low vapor
pressure. The "dry lumber" uses need to be defined by the registrant to
determine if propiconazole-treated lumber is used to build residential
decks and/or play sets. There is the potential for dermal and incidental
oral exposures to treated lumber for uses in decks and or play sets. To
complete an assessment, dislodgeable wood residues would need to be
generated (i.e., wipe studies).

[]{#__RefHeading___Toc120347534 .anchor}**4.2.3 Data
Limitations/Uncertainties**

There are several data limitations and uncertainties associated with the
residential handler exposure assessments. These include the following:

-   Surrogate dermal and inhalation unit exposure values were taken from
    the Pesticide Handler Exposure Database (USEPA, 1998) (See Appendix
    A for summaries of these data sources).

-   The quantities handled/treated were estimated based on information
    from various sources, including HED's Standard Operating Procedures
    (SOPs) for Residential Exposure Assessments (USEPA 2000, and 2001).
    In certain cases, no standard values were available for some
    scenarios. Assumptions for these scenarios were based on AD
    estimates and could be further refined from input from registrants.

    []{#__RefHeading___Toc120347535 .anchor}**5.0 RESIDENTIAL AGGREGATE
    RISK ASSESSMENT AND CHARACTERIZATION**

    The aggregate risk assessment for propiconazole will be conducted by
    the Health Effects Division (HED). However, there are no
    antimicrobial residential uses that are likely to co-occur.

    []{#__RefHeading___Toc120347538 .anchor}**6.0 OCCUPATIONAL EXPOSURE
    ASSESSMENT**

The exposure scenarios assessed in this document for the representative
uses selected by AD are shown in Table 6.1. The table also shows the
maximum application rate associated with the representative use and the
appropriate EPA Registration number for the product label. It should be
noted that for the calculation of application rates in which 8.34 lb
a.i./gal is noted, the product is assumed to have the density of water
because no product-specific density is available.

Occupational handler exposure can occur during the preservation of
materials that are used for household, institutional, and industrial
uses (metalworking fluid, paint, canvas, etc), along with the
preservation of wood. Additionally, occupational post-application
exposures can occur through the use of the treated products through job
functions such as a painter and machinist. The "preservation of
materials" refers to the scenario of a worker adding the preservative to
the material being treated through either liquid pour or liquid pump
methods. Liquid pour refers to transferring the antimicrobial product
from a small container to an open vat. Liquid pump refers to
transferring the preservative by connecting/disconnecting a chemical
metering pump from a tote or by gravity flow. For the preservation of
wood, the procedure for treatment can occur in different ways, such that
multiple worker functions were analyzed. Due to the complexity of the
wood preservative analysis, the results for handler and post-application
exposures are presented in a separate section, 6.4.

+----------+-------------+-------------+---------+--------------------+
| # Tabl   |             |             |         |                    |
| e 6.1. R |             |             |         |                    |
| epresent |             |             |         |                    |
| ative Ex |             |             |         |                    |
| posure S |             |             |         |                    |
| cenarios |             |             |         |                    |
|  Associa |             |             |         |                    |
| ted with |             |             |         |                    |
|  Occupat |             |             |         |                    |
| ional Ex |             |             |         |                    |
| posures  |             |             |         |                    |
| to Propi |             |             |         |                    |
| conazole |             |             |         |                    |
+==========+=============+=============+=========+====================+
| Repres   | Method of   | Exposure    | Regis   | Application Rate   |
| entative | Application | Scenario    | tration |                    |
| Use      |             |             | \#      |                    |
+----------+-------------+-------------+---------+--------------------+
| **       |             |             |         |                    |
| Material |             |             |         |                    |
| Pres     |             |             |         |                    |
| ervation |             |             |         |                    |
| (Use     |             |             |         |                    |
| Site     |             |             |         |                    |
| Category |             |             |         |                    |
| VII)**   |             |             |         |                    |
+----------+-------------+-------------+---------+--------------------+
| Paint    | [P          | IT and ST   | 5       | 0.35% a.i. by      |
|          | reservation | Handler:    | 383-114 | weight of material |
|          | of          | Dermal and  |         | to be preserved    |
|          | paint]{     | inhalation  |         |                    |
|          | .underline} |             |         | (5% product by     |
|          |             | ST Prof     |         | weight of material |
|          | -   Liquid  | Painter:    |         | treated x 7% a.i.  |
|          |     pour    |             |         | in the product)    |
|          |             | Dermal and  |         |                    |
|          | -   Liquid  | inhalation  |         |                    |
|          |     pump    |             |         |                    |
|          |             |             |         |                    |
|          | [P          |             |         |                    |
|          | rofessional |             |         |                    |
|          | painter]{   |             |         |                    |
|          | .underline} |             |         |                    |
|          |             |             |         |                    |
|          | -   B       |             |         |                    |
|          | rush/Roller |             |         |                    |
|          |             |             |         |                    |
|          |             |             |         |                    |
|          | -   Airless |             |         |                    |
|          |             |             |         |                    |
|          |     sprayer |             |         |                    |
+----------+-------------+-------------+---------+--------------------+
| Textile  | -   Liquid  | IT and ST   | 5       | 0.28% a.i. by      |
| s/Canvas |     pour    | Handler:    | 383-114 | weight of material |
|          |             | Dermal and  |         | to be preserved    |
|          | -   Liquid  | inhalation  |         |                    |
|          |     pump    |             |         | (4% product by     |
|          |             |             |         | weight of material |
|          |             |             |         | treated x 7% a.i.  |
|          |             |             |         | in the product)    |
+----------+-------------+-------------+---------+--------------------+
| Ad       | -   Liquid  | IT and ST   | 4       | 1.213% a.i. by     |
| hesives, |     pour    | Handler:    | 3813-19 | weight of material |
| c        |             | Dermal and  |         | to be preserved    |
| oatings, | -   Liquid  | inhalation  |         |                    |
| caulks,  |     pump    |             |         | (12.5% based on    |
| s        |             |             |         | total weight of    |
| ealants, |             |             |         | formulation x 9.7% |
| and inks |             |             |         | a.i. in product)   |
+----------+-------------+-------------+---------+--------------------+
| Meta     | -   Liquid  | IT/LT and   | 4       | 0.07% a.i. by      |
| lworking |     pour    | ST Handler: | 3813-16 | weight of fluid    |
| fluid    |             | Dermal and  |         |                    |
| (worker  | ```{=html}  | inhalation  |         | (700 ppm a.i. in   |
| pouring  | <!-- -->    |             |         | diluted fluid x    |
| pres     | ```         | ST and      |         | 1%/10,000 ppm)     |
| ervative | -   Liquid  | IT/LT       |         |                    |
| into     |     pump    | Machinist:  |         |                    |
| fluid    |             |             |         |                    |
| being    |             | dermal and  |         |                    |
| treated) |             | inhalation  |         |                    |
+----------+-------------+-------------+---------+--------------------+

+----------+-------------+-------------+---------+--------------------+
| **Wood   |             |             |         |                    |
| Pres     |             |             |         |                    |
| ervation |             |             |         |                    |
| (Use     |             |             |         |                    |
| Site     |             |             |         |                    |
| Category |             |             |         |                    |
| X)**     |             |             |         |                    |
+----------+-------------+-------------+---------+--------------------+
| Non-     | [Handler    | IT/LT and   | 4       | [Diptank operators |
| pressure | Worker      | ST Handler  | 3813-19 | and blender/spray  |
| t        | Functions]{ | and         | or      | opera              |
| reatment | .underline} | Post-a      | 4381    | tors:]{.underline} |
| of wood  |             | pplication: | 3-37^a^ |                    |
| and wood | -   Diptank | Dermal and  |         | 1% ai solution for |
| products |             | inhalation  |         | sapstain           |
| in wood  |   Operators |             |         | (43813-19)         |
| t        |             |             |         |                    |
| reatment | -   Bl      |             |         | and                |
| fa       | ender/spray |             |         |                    |
| cilities |             |             |         | 0.5% ai solution   |
|          |   operators |             |         | for decay control  |
|          |             |             |         |                    |
|          | -           |             |         | [All other worker  |
|          |    Chemical |             |         | funct              |
|          |             |             |         | ions:]{.underline} |
|          |   operators |             |         |                    |
|          |             |             |         | 50% ai in product  |
|          | [Post-      |             |         | (43813-37)         |
|          | Application |             |         |                    |
|          | Worker      |             |         |                    |
|          | Functions]{ |             |         |                    |
|          | .underline} |             |         |                    |
|          |             |             |         |                    |
|          | -   Graders |             |         |                    |
|          |             |             |         |                    |
|          | -   Trim    |             |         |                    |
|          |     saw     |             |         |                    |
|          |             |             |         |                    |
|          |   operators |             |         |                    |
|          |             |             |         |                    |
|          | -           |             |         |                    |
|          |    Clean-up |             |         |                    |
|          |     crews   |             |         |                    |
|          |             |             |         |                    |
|          | -   C       |             |         |                    |
|          | onstruction |             |         |                    |
|          |     Workers |             |         |                    |
+----------+-------------+-------------+---------+--------------------+
|          | -   High    | IT and ST   | 60      | 0.1460 lb ai gal   |
|          |     pr      | Handler:    | 061-112 | (1 gal product/2   |
|          | essure/high | Dermal and  |         | gal water \*       |
|          |     volume  | inhalation  |         | density 8.34       |
|          |     spray   |             |         | lb/gal \* 3.5% ai) |
+----------+-------------+-------------+---------+--------------------+
| Mushroom | -   High    | IT and ST   | 4       | 0.0125 lb ai/gal   |
| house    |     pr      | Handler:    | 3813-15 | (19.5 oz/25gal     |
| (Non-    | essure/high | Dermal and  |         | water\* 1gal/128   |
| pressure |     volume  | inhalation  |         | oz \* 2.05 lb      |
| tr       |     spray   |             |         | ai/gal)            |
| eatment) |             |             |         |                    |
|          |             |             |         | \*\*1 gal          |
|          |             |             |         | solution/200 ft^2^ |
|          |             |             |         | wood               |
+----------+-------------+-------------+---------+--------------------+
| Cooling  | -   High    | IT and ST   | 4       | 0.0216 lb ai/gal   |
| towers   |     pr      | Handler:    | 3813-16 | (1.1% product      |
| (Non-    | essure/high | Dermal and  |         | solution \* 23.6%  |
| pressure |     volume  | inhalation  |         | ai \* 8.34 lb/gal) |
| tr       |     spray   |             |         |                    |
| eatment) |             |             |         | \*\*1 gal          |
|          |             |             |         | solution/47 ft^2^  |
|          |             |             |         | wood               |
+----------+-------------+-------------+---------+--------------------+
| Pressure | [Handler    | IT/LT and   | P       | 1% ai solution     |
| t        | Worker      | ST Handler  | rovided |                    |
| reatment | Functions]{ | and         | by      |                    |
| of wood  | .underline} | Post-a      | Reg     |                    |
| and wood |             | pplication: | istrant |                    |
| products | -           | Dermal and  | ^b^     |                    |
| in wood  |   Treatment | inhalation  |         |                    |
| t        |             |             |         |                    |
| reatment |   assistant |             |         |                    |
| fa       |             |             |         |                    |
| cilities | -           |             |         |                    |
|          |   Treatment |             |         |                    |
|          |             |             |         |                    |
|          |    operator |             |         |                    |
|          |             |             |         |                    |
|          | [Post-      |             |         |                    |
|          | Application |             |         |                    |
|          | Worker      |             |         |                    |
|          | Functions]{ |             |         |                    |
|          | .underline} |             |         |                    |
|          |             |             |         |                    |
|          | -   Tram    |             |         |                    |
|          |     setter, |             |         |                    |
|          |     stacker |             |         |                    |
|          |             |             |         |                    |
|          |   operator, |             |         |                    |
|          |     loader  |             |         |                    |
|          |             |             |         |                    |
|          |   operator, |             |         |                    |
|          |             |             |         |                    |
|          | supervisor, |             |         |                    |
|          |     test    |             |         |                    |
|          |     borer,  |             |         |                    |
|          |     and     |             |         |                    |
|          |             |             |         |                    |
|          |    tallyman |             |         |                    |
+----------+-------------+-------------+---------+--------------------+

ST= short-term (1 to 30 days), IT=intermediate-term (1 to 6 months), LT
= long-term (greater than 6 months)

a\. Diptank operators and blender/spray operators are assessed using the
maximum percent ai in solution. The maximum application for non-pressure
treatment methods such as immersion, roller coater, flood, spray, and
brush is 1% ai solution (43813-19). These methods are for finished wood
products. Label 43813-37 also indicates a maximum of 1% ai solution for
these application methods; however, the dilution rate on the label
(gallons product to gallons water) does not coincide with % ai in
solution. The Registrant indicated that for dip tank, conventional
spray, and electrostatic spray methods, the maximum application rate is
0.5% ai solution from Propiconazole Use Closure Memo Amendment dated
April 22, 2005 (USEPA, 2005a). Therefore, the assessment for diptank
operators and blender/spray operators was conducted using both
application rates. It should be noted, however, that the maximum
application rates according to the labels are 0.65% ai solution
(60061-115) for an open dip tank, 0.8% ai solution (1448-394) for
conventional spray, and 50% ai (43813-37) for electrostatic spray. For
the remaining worker functions, the exposures are assessed using the %
active ingredient in the product. The product with the highest percent
active ingredient is 43813-37 (50% ai).

b\. Not all of the labels provided the application rate in terms of % ai
solution, therefore, pressure treatment was assessed using the maximum
application rate of 1 % which was provided by the Registrant and
reported in the Propiconazole Use Closure Memo Amendment dated April 22,
2005 (USEPA, 2005a). The application rate is needed in terms of % ai
solution in order to use the surrogate unit exposure data.

[]{#__RefHeading___Toc120347540 .anchor}**6.1 Occupational Handler
Exposures**

The occupational handler scenarios included in Table 6.1 were assessed
to determine dermal and inhalation exposures. The general assumptions
and equations that were used to calculate occupational handler risks are
provided in Section 1.2, Criteria for Conducting the Risk Assessment.
The majority of the scenarios were assessed using CMA data and Equations
1-3. However, for the occupational scenarios in which CMA data were
insufficient, other data and methods were applied.

**Unit Exposure Values (UE):** Dermal unit exposure values were taken
from the proprietary Chemical Manufacturers Association (CMA)
antimicrobial exposure study (USEPA, 1999: DP Barcode D247642) or from
the Pesticide Handler Exposure Database (USEPA, 1998).

-   For the ***liquid pour*** scenarios for materials preservatives, the
    unit exposure depends on the material being treated. The following
    CMA unit exposures were available and used for the assessment of the
    risk associated with the treatment of the specified materials.

    -   *Metalworking fluid*: CMA metal fluid gloved data. The dermal UE
        is 0.184 mg/lb a.i. and the inhalation UE is 0.00854 mg/lb a.i..
        The values are based on 8 replicates where the test subjects
        were wearing a single layer of clothing and chemical resistant
        gloves. Since no baseline dermal (ungloved) unit exposure data
        are available for metalworking fluid, the baseline dermal
        exposures were evaluated using the cooling tower CMA data (50.3
        mg/lb ai).

    -   *Adhesives, Paint and Textiles*: CMA preservative gloved data.
        The dermal UE is 0.135 mg/lb a.i. and the inhalation UE is
        0.00346 mg/lb a.i.. The values are based on 2 replicates where
        the test subjects were wearing a single layer of clothing and
        chemical resistant gloves. Since no baseline dermal (ungloved)
        unit exposure data are available for preservative uses in
        adhesives, paint, or textiles, the baseline dermal exposures
        were evaluated using the cooling tower CMA data (50.3 mg/lb ai).

```{=html}
<!-- -->
```
-   For the ***liquid pump*** scenarios, the unit exposure depends on
    the material being treated. The following CMA unit exposures were
    available and used for the assessment of the risk associated with
    the treatment of the specified materials.

    -   *Metalworking fluid*: CMA metal fluid gloved data. The dermal UE
        is 0.312 mg/lb a.i. and the inhalation UE is 0.00348 mg/lb a.i.
        The values are based on 2 replicates where the test subjects
        were wearing a single layer of clothing and chemical resistant
        gloves. Since no baseline dermal (ungloved) unit exposure data
        are available for metalworking fluid, the baseline dermal
        exposures were evaluated using the cooling tower CMA data (0.454
        mg/lb ai).

    -   *Adhesives, Paint and Textiles*: CMA preservative gloved data.
        The dermal UE is 0.00629 mg/lb a.i. and the inhalation UE is
        0.000403 mg/lb a.i. The values are based on two replicates where
        the test subjects were wearing a single layer of clothing and
        chemical resistant gloves. Since no baseline dermal (ungloved)
        unit exposure data are available for preservative uses in
        adhesives, paint, or textiles, the baseline dermal exposures
        were evaluated using the cooling tower CMA data (0.454 mg/lb
        ai).

-   For ***roller/brush*** scenarios, the occupational PHED dermal and
    inhalation unit exposure values for paintbrush applications (PHED
    scenario 22) were used (single layer of clothing). The inhalation
    exposure value is 0.28 mg/lb a.i. The dermal unit exposures are 180
    mg/lb a.i. for ungloved replicates and 24 mg/lb a.i. for gloved
    replicates.

-   For ***airless sprayer*** scenarios, the occupational PHED dermal
    and inhalation unit exposure values for airless sprayer application
    (PHED scenario 23) were used (single layer of clothing). The
    inhalation exposure value is 0.83 mg/lb a.i. The dermal unit
    exposures are 38 mg/lb a.i. for ungloved replicates and 14 mg/lb
    a.i. for gloved replicates.

**Quantity handled/treated**: The quantity handled/treated values were
estimated based on information from various sources. The following
assumptions were made:

-   For the ***liquid pour*** scenarios, the quantity of the chemical
    that is handled depends on the material that is being treated. The
    following values were used for the different materials:

    -   *Metalworking fluid*: 2,502 lbs (approximately 300 gallons,
        based on the density of of water, 8.34 lb a.i./gal) (Dang, 1997)

    -   *Paint*: 2,000 lbs (approximately 200 gallons, weight based on a
        density 10 lb a.i./gal) (standard AD assumption).

    -   *Adhesives and Textiles*: 10,000 lbs (standard AD assumption).

```{=html}
<!-- -->
```
-   For the ***liquid pump*** scenarios the quantity that is handled
    depends on the material that is being treated. The following values
    were used for the different materials:

    -   *Metalworking fluid*: 2,502 lbs (approximately 300 gallons,
        based on the density of of water, 8.34 lb a.i./gal) (Dang, 1997)

    -   *Paint*: 10,000 lbs (approximately 1,000 gallons, weight based
        on a density of 10 lb a.i./gal) (standard AD assumption).

    -   *Adhesives and Textiles*: 10,000 lbs (standard AD assumption).

-   For the ***roller/brush*** painting scenario, it was assumed that 50
    lbs (approximately 5 gallons of paint with a density of 10 lb/gal)
    of treated paint are used (standard AD assumption).

-   For the ***airless sprayer*** in the ***painting*** scenario, it was
    assumed that 500 lbs (approximately 50 gallons of paint with a
    density of 10 lb/gal) of treated paint are used. (standard AD
    assumption).

**Duration of Exposure**: The MOEs were calculated for the short- and
intermediate-term durations for occupational handlers using the
appropriate endpoints in Table 3.2.

**[Exposure Calculations and Results]{.underline}**

The resulting exposures and MOEs for the representative occupational
handler scenarios are presented in Table 6.2 (short-term) and in Table
6.3 (intermediate-term). The calculated MOEs were above the target MOE
of 100 for all scenarios, except those listed below. It should be noted
that the baseline (ungloved) dermal MOEs for the material preservation
of paints, textiles, adhesives, and metalworking fluid were calculated
using unit exposure values from the cooling tower CMA data set because
baseline dermal unit exposures are not available for preservative or
metal fluid categories.

-   Adhesives, liquid pour: IT baseline dermal MOE and IT baseline total
    MOE = **\<1**. ST baseline dermal MOE and ST baseline total MOE =
    **\<1**.

-   Adhesives, liquid pump: ST baseline dermal MOE and ST baseline total
    MOE = **95**. IT baseline dermal MOE and IT baseline total MOE =
    **32**.

-   Metalworking fluid, liquid pour: ST baseline dermal MOE and ST
    baseline total MOE = **60**. IT/LT baseline dermal MOE and IT/LT
    baseline total MOE = **20**.

-   Paint, liquid pour: ST baseline dermal MOE and ST baseline total MOE
    = **15**. IT baseline dermal MOE and IT baseline total MOE = **5**.

-   Textiles, liquid pour: ST baseline dermal MOE and ST baseline total
    MOE = **4**. IT baseline dermal MOE and IT baseline total MOE =
    **1**.

-   Painting (professional), brush/roller: IT baseline dermal MOE =
    **56** and IT baseline total MOE = **55**.

-   Painting (professional), airless sprayer: IT baseline dermal MOE =
    **26** and IT gloved dermal MOE **= 71**. IT baseline total MOE =
    **25** and IT gloved total MOE = **62**. ST baseline dermal MOE =
    **79** and ST baseline total MOE = **75.**

It should be noted that although the target inhalation MOE is 100, if
the MOE is below 1,000 the Agency may request a confirmatory inhalation
toxicity study because the current inhalation endpoint is based on an
oral NOAEL. All of the occupational inhalation MOEs were above 1,000,
except for the following scenarios:

-   Painting (professional), airless sprayer: IT inhalation MOE =
    **480**.

<table>
<colgroup>
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 6%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="15"><strong>Table 6.2 Short-Term Risks Associated with
Occupational Handlers</strong></th>
</tr>
<tr class="odd">
<th rowspan="3">Exposure Scenario</th>
<th rowspan="3">Method of Application</th>
<th colspan="3">Unit Exposure (mg/lb a.i.)</th>
<th rowspan="3">Application Rate (% a.i. by weight)</th>
<th rowspan="3">Quantity Handled/ Treated per day</th>
<th colspan="3">Absorbed Daily Dose (mg/kg/day)<sup>c</sup></th>
<th colspan="5">MOE<sup>d</sup></th>
</tr>
<tr class="header">
<th rowspan="2">Baseline Dermal<sup>a</sup></th>
<th rowspan="2">PPE-Gloves Dermal<sup>b</sup></th>
<th rowspan="2">Inhalation</th>
<th rowspan="2">Baseline Dermal<sup>a</sup></th>
<th rowspan="2">PPE-Gloves Dermal<sup>b</sup></th>
<th rowspan="2">Inhalation</th>
<th>Baseline Dermal (Target MOE = 100)<sup>a</sup></th>
<th>PPE-Gloves Dermal (Target MOE = 100) <sup>b</sup></th>
<th><p>Inhalation</p>
<p>(Target MOE = 100)</p></th>
<th colspan="2"><p>Total ST MOE<sup>e</sup></p>
<p>(Target MOE = 100)</p></th>
</tr>
<tr class="odd">
<th>ST</th>
<th>ST</th>
<th>ST</th>
<th>Baseline</th>
<th>PPE</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="15"><strong>Material Preservatives (Use Site Category
VII)</strong></td>
</tr>
<tr class="even">
<td rowspan="2">Preservation of Adhesives</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.135</td>
<td>0.00346</td>
<td>1.213</td>
<td>10,000 lbs</td>
<td>35</td>
<td>0.094</td>
<td>0.006</td>
<td><strong>&lt;1</strong></td>
<td>320</td>
<td>4,300</td>
<td><strong>&lt;1</strong></td>
<td>300</td>
</tr>
<tr class="odd">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.00629</td>
<td>0.000403</td>
<td>1.213</td>
<td>10,000 lbs</td>
<td>0.31</td>
<td>0.0044</td>
<td>0.0007</td>
<td><strong>95</strong></td>
<td>6,900</td>
<td>37,000</td>
<td><strong>95</strong></td>
<td>5,900</td>
</tr>
<tr class="even">
<td rowspan="2">Preservation of Metalworking Fluid</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.184 (f)</td>
<td>0.00854</td>
<td>0.07</td>
<td>2,502 lbs</td>
<td>0.50</td>
<td>0.0018</td>
<td>0.00021</td>
<td><strong>60</strong></td>
<td>16,000 (f)</td>
<td>120,000</td>
<td><strong>60</strong></td>
<td>15,000 (f)</td>
</tr>
<tr class="odd">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.312 (f)</td>
<td>0.00348</td>
<td>0.07</td>
<td>2,502 lbs</td>
<td>0.0045</td>
<td>0.0031</td>
<td>0.000087</td>
<td>6,600</td>
<td>9,600 (f)</td>
<td>3,00,000</td>
<td>6,500</td>
<td>9,300 (f)</td>
</tr>
<tr class="even">
<td rowspan="2">Preservation of Paint</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.135</td>
<td>0.00346</td>
<td>0.35</td>
<td>2,000 lbs</td>
<td>2.0</td>
<td>0.0054</td>
<td>0.00035</td>
<td><strong>15</strong></td>
<td>5,600</td>
<td>74,000</td>
<td><strong>15</strong></td>
<td>5,200</td>
</tr>
<tr class="odd">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.00629</td>
<td>0.000403</td>
<td>0.35</td>
<td>10,000 lbs</td>
<td>0.091</td>
<td>0.0013</td>
<td>0.00020</td>
<td>330</td>
<td>24,000</td>
<td>130,000</td>
<td>330</td>
<td>21,000</td>
</tr>
<tr class="even">
<td rowspan="2">Preservation of Textiles</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.135</td>
<td>0.00346</td>
<td>0.28</td>
<td>10,000 lbs</td>
<td>8.0</td>
<td>0.022</td>
<td>0.0014</td>
<td><strong>4</strong></td>
<td>1,400</td>
<td>19,000</td>
<td><strong>4</strong></td>
<td>1,300</td>
</tr>
<tr class="odd">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.00629</td>
<td>0.000403</td>
<td>0.28</td>
<td>10,000 lbs</td>
<td>0.073</td>
<td>0.0010</td>
<td>0.00016</td>
<td>410</td>
<td>30,000</td>
<td>160,000</td>
<td>410</td>
<td>26,000</td>
</tr>
<tr class="even">
<td rowspan="2">Application of Paint by professionals</td>
<td>Brush/Roller</td>
<td>180</td>
<td>24</td>
<td>0.28</td>
<td>0.35</td>
<td>50 lbs</td>
<td>0.18</td>
<td>0.024</td>
<td>0.0007</td>
<td>170</td>
<td>1,300</td>
<td>37,000</td>
<td>170</td>
<td>1,200</td>
</tr>
<tr class="odd">
<td>Airless Sprayer</td>
<td>38</td>
<td>14</td>
<td>0.83</td>
<td>0.35</td>
<td>500 lbs</td>
<td>0.38</td>
<td>0.14</td>
<td>0.021</td>
<td><strong>79</strong></td>
<td>210</td>
<td>1,200</td>
<td><strong>75</strong></td>
<td>190</td>
</tr>
</tbody>
</table>

ST = short-term, N/A= No data available

a Baseline Dermal: Long-sleeve shirt, long pants, no gloves. It should
be noted that the baseline dermal unit exposures for the preservation of
adhesives, metalworking fluid, paint, and textiles were from the cooling
tower CMA data set because baseline (ungloved) dermal unit exposures are
not available for the preservation CMA data set.

b PPE Dermal with gloves: baseline dermal plus chemical-resistant
gloves.

c Absorbed Daily dose (mg/kg/day) = \[unit exposure (mg/lb a.i.) \*
absorption factor (0.4 for dermal; 1.0 for inhalation) \* application
rate \* quantity treated / Body weight (70 kg).

d MOE = NOAEL (mg/kg/day) / Absorbed Daily Dose \[Where short-term NOAEL
= 30 mg/kg/day for dermal and inhalation\].

e Total ST MOE = 1/((1/Dermal ST MOE) + (1/Inhalation ST MOE))

f The dermal exposures for the MWF use for liquid pour vs. pump appear
to be illogical/inconsistent with the protection afforded by closed
systems. The liquid pour value is based on 8 replicates while the pump
is based on 2 replicates.

<table>
<colgroup>
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 6%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="15"><strong>Table 6.3 Intermediate-Term Risks Associated
with Occupational Handlers</strong></th>
</tr>
<tr class="odd">
<th rowspan="3">Exposure Scenario</th>
<th rowspan="3">Method of Application</th>
<th colspan="3">Unit Exposure (mg/lb a.i.)</th>
<th rowspan="3">Application Rate (% a.i. by weight)</th>
<th rowspan="3">Quantity Handled/ Treated per day</th>
<th colspan="3">Absorbed Daily Dose (mg/kg/day)<sup>c</sup></th>
<th colspan="5">MOE<sup>d</sup></th>
</tr>
<tr class="header">
<th rowspan="2">Baseline Dermal<sup>a</sup></th>
<th rowspan="2">PPE-Gloves Dermal<sup>b</sup></th>
<th rowspan="2">Inhalation</th>
<th rowspan="2">Baseline Dermal<sup>a</sup></th>
<th rowspan="2">PPE-Gloves Dermal<sup>b</sup></th>
<th rowspan="2">Inhalation</th>
<th>Baseline Dermal (Target MOE = 100)<sup>a</sup></th>
<th>PPE-Gloves Dermal (Target MOE = 100) <sup>b</sup></th>
<th><p>Inhalation</p>
<p>(Target MOE = 100)</p></th>
<th colspan="2"><p>Total IT MOE<sup>e</sup></p>
<p>(Target MOE = 100)</p></th>
</tr>
<tr class="odd">
<th>IT</th>
<th>IT</th>
<th>IT</th>
<th>Baseline</th>
<th>PPE</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="15"><strong>Material Preservatives (Use Site Category
VII)</strong></td>
</tr>
<tr class="even">
<td rowspan="2">Preservation of Adhesives</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.135</td>
<td>0.00346</td>
<td>1.213</td>
<td>10,000 lbs</td>
<td>35</td>
<td>0.094</td>
<td>0.006</td>
<td><strong>&lt;1</strong></td>
<td>110</td>
<td>1,700</td>
<td><strong>&lt;1</strong></td>
<td>100</td>
</tr>
<tr class="odd">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.00629</td>
<td>0.000403</td>
<td>1.213</td>
<td>10,000 lbs</td>
<td>0.31</td>
<td>0.0044</td>
<td>0.0007</td>
<td><strong>32</strong></td>
<td>2,200</td>
<td>14,000</td>
<td><strong>32</strong></td>
<td>2,000</td>
</tr>
<tr class="even">
<td rowspan="2">Preservation of Metalworking Fluid</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.184</td>
<td>0.00854</td>
<td>0.07</td>
<td>2,502 lbs</td>
<td>0.50</td>
<td>0.0018</td>
<td>0.00021</td>
<td><strong>20</strong></td>
<td>5,400</td>
<td>47,000</td>
<td><strong>20</strong></td>
<td>4,900</td>
</tr>
<tr class="odd">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.312</td>
<td>0.00348</td>
<td>0.07</td>
<td>2,502 lbs</td>
<td>0.0045</td>
<td>0.0031</td>
<td>0.000087</td>
<td>2,200</td>
<td>3,200</td>
<td>110,000</td>
<td>2,200</td>
<td>3,100</td>
</tr>
<tr class="even">
<td rowspan="2">Preservation of Paint</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.135</td>
<td>0.00346</td>
<td>0.35</td>
<td>2,000 lbs</td>
<td>2.0</td>
<td>0.0054</td>
<td>0.00035</td>
<td><strong>5</strong></td>
<td>1,900</td>
<td>29,000</td>
<td><strong>5</strong></td>
<td>1,700</td>
</tr>
<tr class="odd">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.00629</td>
<td>0.000403</td>
<td>0.35</td>
<td>10,000 lbs</td>
<td>0.091</td>
<td>0.0013</td>
<td>0.00020</td>
<td><strong>110</strong></td>
<td>7,900</td>
<td>50,000</td>
<td>110</td>
<td>6,900</td>
</tr>
<tr class="even">
<td rowspan="2">Preservation of Textiles</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.135</td>
<td>0.00346</td>
<td>0.28</td>
<td>10,000 lbs</td>
<td>8.0</td>
<td>0.022</td>
<td>0.0014</td>
<td><strong>1</strong></td>
<td>460</td>
<td>7,200</td>
<td><strong>1</strong></td>
<td>440</td>
</tr>
<tr class="odd">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.00629</td>
<td>0.000403</td>
<td>0.28</td>
<td>10,000 lbs</td>
<td>0.073</td>
<td>0.0010</td>
<td>0.00016</td>
<td>140</td>
<td>9,900</td>
<td>62,000</td>
<td>140</td>
<td>8,600</td>
</tr>
<tr class="even">
<td rowspan="2">Application of Paint by professionals</td>
<td>Brush/ Roller</td>
<td>180</td>
<td>24</td>
<td>0.28</td>
<td>0.35</td>
<td>50 lbs</td>
<td>0.18</td>
<td>0.024</td>
<td>0.0007</td>
<td><strong>56</strong></td>
<td>420</td>
<td>14,000</td>
<td><strong>55</strong></td>
<td>400</td>
</tr>
<tr class="odd">
<td>Airless Sprayer</td>
<td>38</td>
<td>14</td>
<td>0.83</td>
<td>0.35</td>
<td>500 lbs</td>
<td>0.38</td>
<td>0.14</td>
<td>0.021</td>
<td><strong>26</strong></td>
<td><strong>71</strong></td>
<td>480</td>
<td><strong>25</strong></td>
<td><strong>62</strong></td>
</tr>
</tbody>
</table>

IT = intermediate-term, N/A= No data available

a Baseline Dermal: Long-sleeve shirt, long pants, no gloves. It should
be noted that the baseline dermal unit exposures for the preservation of
adhesives, metalworking fluid, paint, and textiles were from the cooling
tower CMA data set because baseline (ungloved) dermal unit exposures are
not available for the preservation CMA data set.

b PPE Dermal with gloves: baseline dermal plus chemical-resistant
gloves.

c Absorbed Daily dose (mg/kg/day) = \[unit exposure (mg/lb a.i.) \*
absorption factor (0.4 for dermal; 1.0 for inhalation) \* application
rate \* quantity treated / Body weight (70 kg).

d MOE = NOAEL (mg/kg/day) / Absorbed Daily Dose \[Where intermediate-
and long- term NOAEL = 10 mg/kg/day for dermal and inhalation\]. Note
MWF is considered to be long-term.

e Total IT MOE = 1/((1/Dermal IT MOE) + (1/Inhalation IT MOE))

[]{#__RefHeading___Toc120347542 .anchor}**6.2 Occupational
Post-application Exposures**

Except for the post-application scenarios assessed for wood
preservatives in Section 6.4, occupational post-application exposures
are assumed to be negligible.

[]{#__RefHeading___Toc120347543 .anchor}**6.3 Metalworking Fluids:
Machinist**

There is a potential for dermal and inhalation exposure when a worker
handles treated metalworking fluids. This route of exposure occurs after
the chemical has been incorporated into the metalworking fluid and a
machinist is using/handling this treated end-product.

***Dermal Exposures***

**[Exposure Calculations]{.underline}**

A short-term and an intermediate- and long-term exposure estimate were
derived using the 2-hand immersion model from ChemSTEER. The model is
available at
[www.epa.gov/opptintr/exposure/docs/chemsteer.htm]{.underline}. The
2-hand immersion equation is as follows:

PDR = [SA x % a.i. x FT x FQ]{.underline}

BW

where:

PDR = Potential dose rate (mg/kg/day);

SA = Surface area of both hands (cm^2^);

\% a.i. = Fraction active ingredient in treated metalworking fluid
(unitless)

FT = Film thickness of metal fluid on hands (mg/cm^2^)

FQ = Frequency of events (event/day);

BW = Body weight (kg)

**[Assumptions]{.underline}**

-   The surface of area of both hands is 840 cm^2^ (USEPA 1997)

-   The body weight of an adult is 70 kg (USEPA 1997)

-   The percent active ingredient in treated metalworking fluid is 0.07
    % (EPA Registration No. 43813-16).

-   For short-, intermediate- and long-term durations, the film
    thickness on the hands is 1.75 mg/cm^2^, which was extracted from
    the document entitled, "A Laboratory Method to Determine the
    Retention of Liquids on the Surface of Hands" (Cinalli, 1992). The
    film thickness is based on a machinist immersing both hands in
    metalworking fluid and then partially cleaning hands with a rag. The
    film thickness was chosen because the dermal endpoint for short-,
    intermediate- and long-term durations is based on systemic effects.

***Inhalation Exposures***

**[Exposure Calculations]{.underline}**

A screening-level intermediate and long term inhalation exposure
estimate for treated metalworking fluids has been developed using the
OSHA PEL for oil mist. The equation used for calculating the inhalation
dose is:

PDR = [PEL x IR x % a.i. x ED]{.underline}

BW

where:

PDR = Potential dose rate (mg/kg/day);

PEL = OSHA PEL (mg/m^3^);

IR = Inhalation rate (m^3^ /hr)

\% a.i. = Fraction active ingredient in treated metalworking fluid
(unitless)

ED = Exposure duration (hrs/day);

BW = Body weight (kg)

**[Assumptions]{.underline}**

-   The high-end oil mist concentration is based on OSHA's Permissible
    Exposure Limit (PEL) of 5 mg/m^3^ (NIOSH, 1998).

-   The percent active ingredient in treated metalworking fluid is 0.07
    % (EPA Registration No. 43813-16).

-   The inhalation rate for a machinist is 1.0 m^3^ /hr.

-   A machinist is exposed to the metalworking fluid 8 hours a day, for
    5 days a week.

-   The body weight of an adult is 70 kg (USEPA 1997).

***Dermal and Inhalation Results***

Table 6.4 shows the calculation of the absorbed daily dose and MOE for a
machinist working with metalworking fluids. The dermal and inhalation
MOE values are above the target MOE of 100 for all durations. Total MOEs
are also above the target MOE of 100 for short- and
intermediate/long-term exposures (ST Total MOE = 4,800 and IT/LT Total
MOE = 1,600).

Although the target inhalation MOE is 100, if the MOE is below 1,000 the
Agency may request a confirmatory inhalation toxicity study because the
current inhalation endpoint is based on an oral NOAEL. Since the
inhalation MOEs are above 1,000, a confirmatory inhalation toxicity
study is **not** warranted based on the results of this scenario.

<table style="width:100%;">
<colgroup>
<col style="width: 4%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 9%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 5%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 6%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="15"><strong>Table 6.4. Short-, Intermediate-, and Long-Term
Risks Associated with Postapplication Exposure to Metalworking Fluids
treated with Propiconazole (Machinist)</strong></td>
</tr>
<tr class="even">
<td rowspan="3">% a.i.</td>
<td colspan="3">Dermal Inputs</td>
<td colspan="3">Inhalation Inputs</td>
<td colspan="2">Absorbed Daily Dose (mg/kg/day)</td>
<td colspan="6">MOE</td>
</tr>
<tr class="odd">
<td rowspan="2">Hand Surface Area (cm<sup>2</sup>)</td>
<td rowspan="2">Film thickness (mg/cm<sup>2</sup>)</td>
<td rowspan="2">Frequency (event/day)</td>
<td rowspan="2">OSHA PEL (mg/m<sup>3</sup>)</td>
<td rowspan="2"><p>Inhal. rate</p>
<p>(m<sup>3</sup>/hr)</p></td>
<td rowspan="2">Exposure Duration (hrs/day)</td>
<td rowspan="2">Dermal <sup>a</sup></td>
<td rowspan="2">Inhal. <sup>b</sup></td>
<td colspan="2">Dermal MOE (Target MOE = 100)<sup>c</sup></td>
<td colspan="2">Inhalation MOE (Target MOE = 100)<sup>d</sup></td>
<td colspan="2">Total MOE (Target MOE = 100)<sup>e</sup></td>
</tr>
<tr class="even">
<td>ST</td>
<td>IT/LT</td>
<td>ST</td>
<td>IT/LT</td>
<td>ST</td>
<td>IT/LT</td>
</tr>
<tr class="odd">
<td>0.07</td>
<td>840</td>
<td>1.75</td>
<td>1</td>
<td>5</td>
<td>1.0</td>
<td>8</td>
<td>0.0059</td>
<td>0.00040</td>
<td>5,100</td>
<td>1,700</td>
<td>75,000</td>
<td>25,000</td>
<td>4,800</td>
<td>1,600</td>
</tr>
</tbody>
</table>

a Absorbed Dermal Daily Dose (mg/kg/day) = \[(% active ingredient \*
hand surface area\* dermal absorption factor (40% for all durations)\*
film thickness (mg/cm^2^)\* Frequency (event/day)\] / Body weight (60
kg).

b Absorbed Inhalation Daily Dose (mg/kg/day) = % active ingredient \*
OSHA PEL (mg/m^3^) \* Inhalation rate (m^3^/hr) \* exposure duration
(hr/day) \* inhalation absorption factor (100% for all durations)/ body
weight (70 kg)

c Dermal MOE = NOAEL (mg/kg/day) / Absorbed Daily Dose (mg/kg/day)
\[Where: short-term NOAEL = 30 mg/kg/day and intermediate -- and
long-term NOAEL = 10 mg/kg/day for dermal exposures, Table 3.2 \].

d Inhalation MOE = NOAEL (mg/kg/day) / Absorbed Daily Dose (mg/kg/day)
\[Where: short-term NOAEL = 30 mg/kg/day and intermediate- and long-term
NOAEL = 10 mg/kg/day for inhalation exposures, Table 3.2\].

e Total MOE = 1/((1/Dermal MOE) + (1/Inhalation MOE))

[]{#__RefHeading___Toc120347552 .anchor}**6.4 Wood Preservation**

Propiconazole is used in products that are intended to preserve wood
through both non-pressure treatment methods and pressure treatment
methods. The products can be used on many different types of wood
including 1) green or fresh cut lumber, poles, posts, and timbers; 2)
manufactured wood products such as logs (including for log home
construction), wood chips/sawdust, plywood veneer, and particle board;
3) dry lumber; and 4) finished wood products such as millwork, shingles,
shakes, siding, plywood, and structural lumber and composites. The
majority of the products are intended for use at wood treatment
facilities, however, propiconazole is also formulated for use in
mushroom houses to protect timber trays and benches. Propiconazole is
also formulated for use on cooling tower wood, however, the label does
not specifically indicate if the wood is treated prior to or after
manufacture of the cooling tower.

The exposure scenarios assessed in this document for the representative
wood preservation uses selected by AD are shown in Table 6.1. Section
6.4.1 presents the exposure analysis for the handler and
post-application scenarios for non-pressure treatment scenarios and
Section 6.4.2 presents the exposure analysis for the handler and
post-application scenarios for pressure treatment scenarios.

[]{#__RefHeading___Toc120347553 .anchor}**6.4.1 Non-Pressure Treatment
Scenarios (Handler and Post-application)**

[]{#__RefHeading___Toc120347554 .anchor}**6.4.1.1 Scenarios Assessed by
Worker Function**

The proprietary study, "*Measurement and Assessment of Dermal and
Inhalation Exposures to Didecyl Dimethyl Ammonium Chloride (DDAC) Used
in the Protection of Cut Lumber (Phase III)"* (Bestari et al., 1999,
MRID 455243-04 which is a Sapstain Industry Task Force Study, \# 73154)
identified various worker functions/positions for individuals that
handle DDAC-containing wood preservatives for non-pressure treatment
application methods and for individuals that could then come into
contact with the preserved wood. The worker functions/positions
identified in the DDAC study are presented below. It was assumed that
similar tasks are performed when handling propiconazole products and
propiconazole treated-wood, therefore, these same functions were
assessed for propiconazole.

**Handler:**

-   ***Blender/spray operators*** are workers that add the wood
    preservative into a blender/sprayer system for composite wood via
    closed-liquid pumping.

-   ***Diptank Operators*** can be in reference to wood being lowered
    into the treating solution through an automated process (i.e.,
    elevator diptank, forklift diptank). This scenario can also occur in
    a smaller scale treatment facility in which the worker can manually
    dip the wood into the treatment solution.

-   ***Chemical operators*** for a spray box system consist of chemical
    operators, chemical assistants, chemical supervisors, and chemical
    captains. These individuals maintain a chemical supply balance along
    with flushing and cleaning spray nozzles.

    **Post-application:**

```{=html}
<!-- -->
```
-   ***Graders**,* positioned right after the spray box, grade dry
    lumber by hand (i.e. detect faults). In the DDAC study, graders
    graded wet lumber; therefore, the exposures to graders using
    propiconazole are worst-case scenarios.

-   ***Millwrights*** repair all conveyer chains and general up-keep of
    the mill.

-   ***Clean-up crews*** perform general cleaning duties at the mill.

-   ***Trim saw operators*** operate the hula trim saw and consist of
    operators and strappers. In the DDAC study, hula trim saw operators
    handled dry lumber.

-   ***Construction workers*** install treated plywood, oriented strand
    board, medium density fiberboard, and others.

As very little chemical specific data were available regarding typical
exposures to propiconazole as a wood preservative, surrogate data were
used to estimate exposure risks. The blender/spray operator position was
assessed using CMA unit exposure data and the remaining handler and
post-application positions were assessed using data from the DDAC study
(Bestari et al., 1999, Task Force #73154). This study is proprietary;
therefore, data compensation needs to be addressed for use of these data
in this exposure assessment.

**[Blender/Spray Operators]{.underline}**

Exposures and risks to the composite wood blender/spray operators were
assessed using Equations 1 through 3 in Section 1.2. The surrogate unit
exposures were taken from the CMA study (USEPA 1999). Specifically, the
liquid pump preservative unit exposures for gloved workers were used in
this assessment. The dermal unit exposure was 0.00629 mg/lb ai and the
inhalation unit exposure was 0.000403 mg/lb ai. These values are based
on two replicates where the test subjects were wearing a single layer of
clothing and chemical resistant gloves. The quantity of the wood being
treated was derived from other wood preservative estimates (USEPA, 2004)
for the amount of wood slurry treated because no chemical specific data
were available for propiconazole. It was assumed that batches of wood
Number range CHAPTERslurry are treated in 10,000 gallon tanks, and that
eight batches of wood slurry are treated per day (one per hour for an
8-hr work shift). Additionally, it was assumed that each batch requires
3,000 gallons of preservatives and the remainder volume of the tank
consists of wood slurry (7,000 gallons of wood slurry per batch). Wood
chips have a density of approximately 380 kg/m^3^ (SIMetric, 2005),
therefore, the total amount of wood slurry treated per day would be
178,000 lbs (8 batches/day \* 7,000 gallons/batch \* 0.003785
m^3^/gallon \* 380 kg/m^3^ \* 2.2 lb/kg). Number range CHAPTERThe
assumptions used for batch sizes and the quantity of preservative needed
are consistent with an assessment performed previously by the EPA. The
propiconazole assessment was conducted for both the 1% ai solution and
0.5% ai solution application rates. The higher maximum application rate
represents the labels which indicate the product can be used on finished
wood products through immersion, roller coater, flood, spray, and brush
application methods. The lower application rate used in this assessment
represents the maximum application rate presented by the registrant in
the Propiconazole Use Closure Memo Amendment dated April 22, 2005
(USEPA, 2005a) for dip tank, conventional spray, and electrostatic spray
methods on seasoned and unseasoned forest products. It should be noted,
however, that the maximum application rates according to the label
review are 0.65% ai solution (60061-115) for an open dip tank, 0.8% ai
solution (1448-394) for conventional spray, and 50% ai solution
(43813-37) for electrostatic spray.

Table 6.5 provides the short- and intermediate-term doses and MOEs for
the workers adding the preservative to the wood slurry. All MOEs are
above the target MOE of 100 for short-, intermediate-, and long-term
dermal, inhalation, and total exposures.

It should be noted that although the target inhalation MOE is 100, if
the MOE is below 1,000 the Agency may request a confirmatory inhalation
toxicity study because the current inhalation endpoint is based on an
oral NOAEL. All of the occupational inhalation MOEs were above 1,000,
except for the following scenarios:

-   Blender/spray operator: IT/LT inhalation MOE at the 1% application
    rate = **980**.

<table>
<colgroup>
<col style="width: 11%" />
<col style="width: 8%" />
<col style="width: 9%" />
<col style="width: 10%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 9%" />
<col style="width: 5%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 4%" />
<col style="width: 5%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="13"><strong>Table 6.5. Short-, Intermediate-, and Long-term
Exposures and MOEs for Wood Preservative Blender/Spray
Operators</strong></td>
</tr>
<tr class="even">
<td rowspan="3">Exposure Scenario</td>
<td rowspan="3"><p>Dermal Unit Exposure<sup>a</sup></p>
<p>(mg/lb ai)</p></td>
<td rowspan="3"><p>Inhalation Unit Exposure<sup>b</sup></p>
<p>(mg/lb ai)</p></td>
<td rowspan="3"><p>Application Rate<sup>c</sup></p>
<p>(% ai in solution/</p>
<p>day)</p></td>
<td rowspan="3"><p>Wood Slurry Treated<sup>d</sup></p>
<p>(lb/day)</p></td>
<td colspan="2"><p>Absorbed Daily Dose<sup>e</sup></p>
<p>(mg/kg/day)</p></td>
<td colspan="6">MOEs<sup>f</sup></td>
</tr>
<tr class="odd">
<td rowspan="2">Dermal</td>
<td rowspan="2">Inhalation</td>
<td colspan="2">Dermal</td>
<td colspan="2">Inhalation</td>
<td colspan="2">Total<sup>g</sup></td>
</tr>
<tr class="even">
<td>ST</td>
<td>IT/LT</td>
<td>ST</td>
<td>IT/LT</td>
<td>ST</td>
<td>IT/LT</td>
</tr>
<tr class="odd">
<td colspan="13">Occupational Handler</td>
</tr>
<tr class="even">
<td>CMA Liquid Pump</td>
<td>0.00629</td>
<td>0.000403</td>
<td>0.50</td>
<td>178,000</td>
<td>0.032</td>
<td>0.051</td>
<td>940</td>
<td>310</td>
<td>5,900</td>
<td>2,000</td>
<td>810</td>
<td>270</td>
</tr>
<tr class="odd">
<td>CMA Liquid Pump</td>
<td>0.00629</td>
<td>0.000403</td>
<td>1.0</td>
<td>178,000</td>
<td>0.064</td>
<td>0.010</td>
<td>470</td>
<td>160</td>
<td>2,900</td>
<td>980</td>
<td>400</td>
<td>130</td>
</tr>
</tbody>
</table>

ST = Short-term duration; IT = Intermediate-term duration; and LT =
long-term.

a.  Dermal unit exposure: Single layer clothing with chemical resistant
    gloves.

b.  Inhalation unit exposure: Baseline.

c\. The assessment was conducted using both the 0.5% and 1% ai solution
application rates where 0.5% is for sapstain treatment and 1% is for
decay control.

d\. Wood slurry treated = (8 batches/day \* 7,000 gallons/batch \*
0.003785 m^3^/gallon \* 380 kg/m^3^ \* 2.2 lb/kg)

e\. Absorbed Daily Dose = unit exposure (mg/lb ai) x App Rate (% ai/day)
x Quantity treated (lb/day) x absorption factor (40% dermal and 100% for
inhalation) / BW (70 kg)

f\. MOE = NOAEL (mg/kg/day)/ Daily dose \[Where short-term NOAEL = 30
mg/kg/day for dermal and inhalation and IT/LT NOAEL = 10 mg/kg/day for
dermal and inhalation\]. Target MOE is 100 for dermal and inhalation
exposures.

g\. Total MOE = 1/ ((1/MOE~dermal~) + (1/MOE~inhalation~)). Target MOE
is 100.

**[Chemical Operators, Graders, Millwrights, Clean-up Crews, and Trim
Saw Operators]{.underline}**

Exposures to chemical operators, graders, millwrights, trim saw
operators, and clean-up crews were assessed using surrogate data from
the DDAC study (Bestari et al., 1999, Task Force \# 73154). The DDAC
study examined individuals= exposure to DDAC while working with
antisapstains and performing routine tasks at 11 sawmills/planar mills
in Canada. Dermal and inhalation exposure monitoring data were gathered
for each job function of interest using dosimeters and personal sampling
tubes. Dosimeters and personal air sampling tubes were analyzed for
DDAC. Exposure data for individuals performing the same job functions
were averaged together to determine job specific averages. Monitoring
was conducted using 2 trim saw workers, 13 grader workers, 11 chemical
operators, 3 millwrights, and 6 clean-up staff.

The individual dermal and inhalation exposures from the DDAC study are
presented in Table B-1 in Appendix B. To determine propiconazole
exposures, the average DDAC exposures measured on individuals (in terms
of total mg DDAC) were multiplied by a modification factor of 0.625 to
account for the difference in percent active ingredient between
propiconazole and DDAC (50% propiconizole in the wood preservative
product versus 80% DDAC in the comparative wood preservative product).
The lb ai handled by each person or the % ai in the treatment solution
were not provided for these worker functions.

The following equation was used to calculate daily dose for
propiconazole:

Daily Dose = [DDAC UE x CR x AB]{.underline}

BW

Where

DDAC UE = DDAC dermal or inhalation unit exposure (mg/day);

CR = Conversion ratio (50% propiconazole / 80% DDAC) ;

AB = Absorption factor (40% for dermal, 100% for inhalation); and

BW = Body weight (70 kg).

In using this methodology, the following assumptions were made:

-   DDAC and propiconazole end-use products will be used in similar
    quantities.

-   The procedures for applying both chemicals are similar.

-   The limits of detections (LOD) for inhalation residues from Number
    range CHAPTERchemical operators, graders, mill wrights, and clean-up
    staff replicates were not provided in the DDAC report. For lack of
    better data, it was assumed that the inhalation LODs for these
    worker positions are equal to the LOD of the diptank operator
    replicates (5.6 g). For all measurements below the air
    concentration associated with this detection limit, half the
    detection limit was used. The dermal LOD for all operators is also
    5.6 g.

-   In the DDAC study, dermal exposures to hands were measured
    separately from the rest of the body. For each replicate, the body
    dose measurements and hand dose measurements were summed for a total
    dermal dose.

-   Air concentrations were reported in the DDAC study. To convert air
    concentrations (g/m^3^) into terms of inhalation unit exposure
    (mg/day), the air concentrations were multiplied by an inhalation
    rate of 1.0 m^3^/hr for light activity (EPA 1997), an exposure
    duration of 8 hrs/day, and a conversion factor of 1 mg/1000 mg.
    Table B-1 in Appendix B presents the inhalation and dermal DDAC
    exposures.

-   Average DDAC dermal and inhalation exposures were multiplied by a
    conversion ratio of 0.625 to account for the differences in
    propiconazole and DDAC concentrations \[(50% propiconazole / 80%
    DDAC)\].

Table 6.6 provides the short-, intermediate-, and long-term doses and
MOEs for chemical operators, graders, millwrights, clean-up crews, and
trim saw operators. For all worker functions, the inhalation MOEs are
above the target MOE of 100 for ST/IT/LT durations, and therefore are
not of concern. For all worker functions, except the clean-up worker,
the dermal and total MOEs are above the target MOE of 100 for ST/IT/LT
durations. For the clean-up worker, the intermediate- and long-term
dermal and total MOEs are below the target MOE of 100 (MOE of 51 and 49,
respectively).

All inhalation MOEs exceeded 1,000, therefore, a confirmatory inhalation
toxicity study is not warranted based on the results of these exposure
scenarios.

[]{.mark}

<table>
<colgroup>
<col style="width: 10%" />
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 11%" />
<col style="width: 8%" />
<col style="width: 9%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 6%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="12"><strong>Table 6.6. Short-, Intermediate- and Long-Term
Exposures and MOEs for Wood Preservative Chemical Operators, Graders,
Trim Saw Operators, and Clean-Up Crews</strong></th>
</tr>
<tr class="odd">
<th rowspan="3"><p>Exposure Scenario<sup>a</sup></p>
<p>(number of volunteers)</p></th>
<th rowspan="3"><p>Dermal UE<sup>b</sup></p>
<p>(mg/day)</p></th>
<th rowspan="3"><p>Inhalation UE<sup>b</sup></p>
<p>(mg/day)</p></th>
<th rowspan="3">Conversion Ratio<sup>c</sup></th>
<th colspan="2"><p>Absorbed Daily Doses<sup>d</sup></p>
<p>(mg/kg/day)</p></th>
<th colspan="6">MOEs<sup>e</sup></th>
</tr>
<tr class="header">
<th rowspan="2">Dermal</th>
<th rowspan="2">Inhalation</th>
<th colspan="2">Dermal</th>
<th colspan="2">Inhalation</th>
<th colspan="2">Total<sup>f</sup></th>
</tr>
<tr class="odd">
<th>ST</th>
<th>IT/LT</th>
<th>ST</th>
<th>IT/LT</th>
<th>ST</th>
<th>IT/LT</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="12">Occupational Handler</td>
</tr>
<tr class="even">
<td>Chemical Operator (n=11)</td>
<td>9.81</td>
<td>0.0281</td>
<td>0.625</td>
<td>0.035</td>
<td>0.00025</td>
<td>860</td>
<td>290</td>
<td>120,000</td>
<td>40,000</td>
<td>850</td>
<td>280</td>
</tr>
<tr class="odd">
<td colspan="12">Occupational Post-application</td>
</tr>
<tr class="even">
<td>Grader (n=13)</td>
<td>3.13</td>
<td>0.0295</td>
<td>0.625</td>
<td>0.011</td>
<td>0.00026</td>
<td>2,700</td>
<td>890</td>
<td>110,000</td>
<td>38,000</td>
<td>2,600</td>
<td>870</td>
</tr>
<tr class="odd">
<td>Trim Saw (n=2)</td>
<td>1.38</td>
<td>0.061</td>
<td>0.625</td>
<td>0.0049</td>
<td>0.00054</td>
<td>6,100</td>
<td>2,000</td>
<td>56,000</td>
<td>19,000</td>
<td>5,500</td>
<td>1,800</td>
</tr>
<tr class="even">
<td>Millwright (n=3)</td>
<td>12.81</td>
<td>0.057</td>
<td>0.625</td>
<td>0.046</td>
<td>0.00051</td>
<td>660</td>
<td>220</td>
<td>59,000</td>
<td>20,000</td>
<td>650</td>
<td>220</td>
</tr>
<tr class="odd">
<td>Clean-Up (n=6)</td>
<td>55.3</td>
<td>0.60</td>
<td>0.625</td>
<td>0.20</td>
<td>0.0054</td>
<td>150</td>
<td><strong>51</strong></td>
<td>5,600</td>
<td>1,900</td>
<td>150</td>
<td><strong>49</strong></td>
</tr>
</tbody>
</table>

ST = Short-term duration; IT = Intermediate-term duration; and LT =
long-term

a\. The exposure scenario represents a worker wearing short sleeve
shirts, cotton work trousers, and cotton glove dosimeter gloves under
chemical resistant gloves. Volunteers were grouped according to tasks
they conducted at the mill.

b\. Dermal and inhalation unit exposures are from Bestari et al (1999,
Task Force \# 73154). Refer to Table B-1 in Appendix B for the
calculation of the dermal and inhalation exposures. Inhalation exposure
(mg/day) was calculated using the following equation: air concentration
(g/m^3^) x inhalation rate (1.0 m^3^/hr) x sample duration (8 hr/day) x
unit conversion (1 mg/1000 g). The inhalation rate is from USEPA, 1997.

c\. Conversion Ratio = 50% propiconazole / 80% DDAC

d\. Absorbed Daily dose (mg/kg/day) = exposure (mg/day) \* conversion
ratio (0.625) \* absorption factor (40% for dermal and 100% for
inhalation)/body weight (70 kg).

e\. MOE = NOAEL (mg/kg/day)/ Daily dose \[Where short-term NOAEL = 30
mg/kg/day for dermal and inhalation and intermediate- and long-term
NOAEL = 10 mg/kg/day for dermal and inhalation\]. Target MOE is 100 for
dermal and inhalation exposures.

f\. Total MOE = 1/ ((1/MOE~dermal~) + (1/MOE~inhalation~)). Target MOE
is 100.

**[Diptank Operators]{.underline}**

Exposures to diptank operators were also assessed using surrogate data
from the DDAC study (Bestari et al., 1999). The diptank scenario
assessment was conducted differently than for the other job functions
because the concentration of DDAC in the diptank solution was provided.
The exposure data for diptank operators wearing gloves were converted
into Aunit exposures@ in terms of mg a.i. for each 1% of concentration
of the product. The calculation of the dermal and inhalation unit
exposures (2.99 and 0.046 mg/1% solution, respectively) is presented in
Table B-2 in Appendix B. The air concentrations presented in the DDAC
study were converted to unit exposures using an inhalation rate of 1.0
m^3^/hr (light activity) and sample duration of 8 hrs/day.

The following equations are used to estimate dermal and inhalation
handler exposure:

Daily Dose = [DDAC UE x AI x AB]{.underline}

BW

Where

DDAC UE = DDAC dermal unit exposure (mg/ 1% in solution);

AI = AI (1% ai and 0.5% ai in solution/day);

AB = Absorption factor (40% for dermal, 100% for inhalation); and

BW = Body weight (70 kg).

Table 6.7 provides the short-term and the intermediate- and long-term
doses and MOEs for diptank operators. All MOEs were above the target MOE
of 100 for dermal, inhalation, and total exposures and therefore, are
not of concern.

All inhalation MOEs exceeded 1,000, therefore, a confirmatory inhalation
toxicity study is not warranted based on the results of these exposure
scenarios.

<table style="width:100%;">
<colgroup>
<col style="width: 10%" />
<col style="width: 11%" />
<col style="width: 11%" />
<col style="width: 9%" />
<col style="width: 7%" />
<col style="width: 9%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 6%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="12"><strong>Table 6.7. Short-, Intermediate-, and Long-Term
Exposures and MOEs for Diptank Operator</strong></th>
</tr>
<tr class="odd">
<th rowspan="3"><p>Exposure Scenario<sup>a</sup></p>
<p>(number of replicates)</p></th>
<th rowspan="3"><p>Dermal Unit Exposure<sup>b</sup></p>
<p>(mg DDAC/1% solution)</p></th>
<th rowspan="3"><p>Inhalation Unit Exposure<sup>b</sup></p>
<p>(mg DDAC/1% solution)</p></th>
<th rowspan="3"><p>App Rate</p>
<p>(% a.i. in solution/ day)<sup>c</sup></p></th>
<th colspan="2"><p>Absorbed Daily Doses<sup>c</sup></p>
<p>(mg/kg/day)</p></th>
<th colspan="6">MOEs<sup>d</sup></th>
</tr>
<tr class="header">
<th rowspan="2">Dermal</th>
<th rowspan="2">Inhalation</th>
<th colspan="2">Dermal</th>
<th colspan="2">Inhalation</th>
<th colspan="2">Total<sup>f</sup></th>
</tr>
<tr class="odd">
<th>ST</th>
<th>IT/LT</th>
<th>ST</th>
<th>IT/LT</th>
<th>ST</th>
<th>IT/LT</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="12">Occupational Handler</td>
</tr>
<tr class="even">
<td>Dipping, with gloves (n=7)</td>
<td>2.99</td>
<td>0.046</td>
<td>0.50</td>
<td>0.0085</td>
<td>0.00033</td>
<td>3,500</td>
<td>1,200</td>
<td>91,000</td>
<td>30,000</td>
<td>3,400</td>
<td>1100</td>
</tr>
<tr class="odd">
<td>Dipping, with gloves (n=7)</td>
<td>2.99</td>
<td>0.046</td>
<td>1.0</td>
<td>0.017</td>
<td>0.00066</td>
<td>1,800</td>
<td>580</td>
<td>46,000</td>
<td>15,000</td>
<td>1,700</td>
<td>560</td>
</tr>
</tbody>
</table>

ST = Short-term duration; IT =Intermediate-term duration; and LT =
long-term.

a\. The exposure scenario represents a worker wearing long-sleeved
shirts, cotton work trousers, and gloves. Gloves were worn only when
near chemical, not when operating diptank

b\. Dermal and inhalation unit exposures are from DDAC study (MRID
455243‑04, Task Force \# 73154). Refer to Table B-2 in Appendix B for
the dermal and inhalation unit exposure calculations. Inhalation
exposure (mg) was calculated using the following equation: Air
concentration (mg/m^3^) x Inhalation rate (1.0 m^3^/hr) x Sample
Duration (8 hr). The inhalation rate is from USEPA, 1997.

c\. The assessment was conducted using both the 0.5% and 1% ai solution
application rates where 0.5% is used for sapstain treatments and 1% is
used for decay control.

d\. Absorbed Daily dose (mg/kg/day) = unit exposure (mg/1% ai solution)
\* percent active ingredient in solution \* absorption factor (40% for
dermal and 100% for inhalation) / body weight (70 kg).

e\. MOE = NOAEL (mg/kg/day) / Daily dose \[Where short-term NOAEL = 30
mg/kg/day for dermal and inhalation and intermediate-and long-term NOAEL
= 10 mg/kg/day for dermal and inhalation\]. Target MOE is 100 for dermal
and inhalation exposures.

f\. Total MOE = 1/ ((1/MOE~dermal~) + (1/MOE~inhalation~)). Target MOE
is 100.

**[Construction workers]{.underline}**

Not enough data exists to estimate the amount of exposure associated
with construction workers who install treated wood. In particular,
values for the transfer coefficient associated with a construction
worker handling the wood could not be determined. However, it is
believed that the construction worker using a trim saw will have larger
dermal and inhalation exposures than the installer, due to the amount of
sawdust generated and the greater amount of hand contact that would be
necessary to handle the wood when using a saw compared to installing the
wood.

[]{#__RefHeading___Toc120347558 .anchor}**6.4.1.2 Scenarios Assessed for
High Pressure/High Volume Spray Application Methods**

Handler exposures from operating high pressure/high volume spray
equipment were assessed using Equations 1 through 3 in Section 1.2 for
applications to wood in wood treatment facilities, wood in mushroom
houses, and cooling tower wood. Dermal and inhalation unit exposure
values were taken from PHED (liquid/open pour/high pressure spray).
These unit exposure data were monitored in greenhouses where the
applications were made to floors, benches, and overhead plants. The
dermal and inhalation unit exposure values are 2.5 mg/lb a.i. and 0.12
mg/lb a.i., respectively (single layer of clothing and gloves) (USEPA
1998). Only a gloved scenario was assessed because ungloved data are not
available.

Due to the uncertainty in the quantity of solution used for these
scenarios, the scenarios were assessed using a range of 25 to 1,000
gallons. For wood treatment facility non-pressure spray applications,
large applications are assumed to be performed by mechanical dip
operations while smaller treatments may be performed by reel-type
handwand methods where the quantity handled ranges from 25 to 50
gallons. During the error comment period Janssen provide additional
information on the quantities applied to cooling tower wood. An
applicator of cooling tower wood preservatives using a
high-pressure/high volume spray method could apply a maximum of 200
gallons of diluted solution per day assuming a complete 8-hr work shift
is dedicated to the application of the preservative. Typical quantities
handled are less than 100 gallons per day because service crews handle
many other unrelated maintenance tasks at the facility. The values could
be further refined from additional input from registrants.

The calculated dermal, inhalation, and total MOEs are shown in Table 6.8
for short-, intermediate-, and long-term durations of exposure. All MOEs
for high pressure/high volume wood preservative uses were above the
target MOE of 100 for all scenarios except for the following:

-   Wood Preservation, high pressure/high volume spray in wood treatment
    facility: IT/LT dermal MOE (gloves) at 50 gallons = **96**, IT/LT
    total MOE at 50 gallons = **86**.

-   Wood Preservation, high pressure/high volume spray in mushroom
    house: IT dermal MOE (gloves) at 1,000 gallons = **56**, IT total
    MOE at 1,000 gallons = **50**.

It should be noted that although the target inhalation MOE is 100, if
the MOE is below 1,000 the Agency may request a confirmatory inhalation
toxicity study because the current inhalation endpoint is based on an
oral NOAEL. All of the occupational inhalation MOEs are above 1,000,
except for the following scenarios:

-   Wood Preservation, high pressure/high volume spray in wood treatment
    facility: IT/LT inhalation MOE at 50 gallons = **800**

-   Wood Preservation, high pressure/high volume spray in mushroom
    house: IT inhalation MOE at 1,000 gallons = **470**.

<table>
<colgroup>
<col style="width: 8%" />
<col style="width: 9%" />
<col style="width: 7%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 5%" />
<col style="width: 4%" />
<col style="width: 5%" />
<col style="width: 4%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="14"><strong>Table 6.8. Short- and Intermediate-Term
Exposures and MOEs for High Pressure/High Volume Spray Scenarios (Wood
Treatment Facility, Mushroom House, and Cooling Tower
Wood)</strong></td>
</tr>
<tr class="even">
<td rowspan="3">Exposure Site</td>
<td rowspan="3">Surrogate Exposure Data</td>
<td rowspan="3"><p>App. Rate</p>
<p>(lb ai/dilute gallon)</p></td>
<td rowspan="3">Quantity Handled/ Treated per day<sup>a</sup>
(gallons)</td>
<td rowspan="3">Baseline Inhalation Unit Exposure (mg/lb ai)</td>
<td rowspan="3">Dermal (gloves) Unit Exposure<sup>b</sup> (mg/lb
ai)</td>
<td colspan="2"><p>Absorbed Daily Doses<sup>c</sup></p>
<p>(mg/kg/day)</p></td>
<td colspan="6">MOEs<sup>d</sup></td>
</tr>
<tr class="odd">
<td rowspan="2">Baseline Inhalation</td>
<td rowspan="2">Dermal (gloves)</td>
<td colspan="2">Baseline Inhalation</td>
<td colspan="2">Dermal (gloves)</td>
<td colspan="2">Total<sup>e</sup></td>
</tr>
<tr class="even">
<td>ST</td>
<td>IT</td>
<td>ST</td>
<td>IT</td>
<td>ST</td>
<td>IT</td>
</tr>
<tr class="odd">
<td rowspan="2">Wood Treatment Facility</td>
<td rowspan="6">PHED M/L/A high pressure spray</td>
<td rowspan="2">0.146</td>
<td>25</td>
<td>0.12</td>
<td>2.5</td>
<td>0.0063</td>
<td>0.052</td>
<td>4,800</td>
<td>1600</td>
<td>580</td>
<td>190</td>
<td>510</td>
<td>170</td>
</tr>
<tr class="even">
<td>50</td>
<td>0.12</td>
<td>2.5</td>
<td>0.013</td>
<td>0.10</td>
<td>2,400</td>
<td>800</td>
<td>290</td>
<td>96</td>
<td>260</td>
<td><strong>86</strong></td>
</tr>
<tr class="odd">
<td rowspan="2">Mushroom House</td>
<td rowspan="2">0.0125</td>
<td>100</td>
<td>0.12</td>
<td>2.5</td>
<td>0.0021</td>
<td>0.018</td>
<td>14,000</td>
<td>4,700</td>
<td>1,700</td>
<td>560</td>
<td>1,500</td>
<td>500</td>
</tr>
<tr class="even">
<td>1,000</td>
<td>0.12</td>
<td>2.5</td>
<td>0.021</td>
<td>0.18</td>
<td>1,400</td>
<td>470</td>
<td>170</td>
<td><strong>56</strong></td>
<td>150</td>
<td><strong>50</strong></td>
</tr>
<tr class="odd">
<td rowspan="2">Cooling Tower</td>
<td rowspan="2">0.0216</td>
<td>100</td>
<td>0.12</td>
<td>2.5</td>
<td>0.0037</td>
<td>0.031</td>
<td>8,100</td>
<td>2,700</td>
<td>970</td>
<td>520</td>
<td>870</td>
<td>290</td>
</tr>
<tr class="even">
<td>200</td>
<td>0.12</td>
<td>2.5</td>
<td>0.0074</td>
<td>0.062</td>
<td>4,100</td>
<td>1,400</td>
<td>490</td>
<td>160</td>
<td>430</td>
<td>140</td>
</tr>
</tbody>
</table>

a\. Due to the uncertainty of the use amounts, the scenarios were
assessed for both 100 and 1,000 gallons.

b\. No ungloved data available such that only a gloved scenario was
assessed.

c\. Absorbed Daily dose (mg/kg/day) = unit exposure (mg/1% ai solution)
\* percent active ingredient in solution \* absorption factor (40% for
dermal and 100% for inhalation) / body weight (70 kg).

d\. MOE = NOAEL (mg/kg/day) / Daily dose \[Where short-term NOAEL = 30
mg/kg/day for dermal and inhalation and intermediate-term NOAEL = 10
mg/kg/day for dermal and inhalation\]. Target MOE is 100 for dermal and
inhalation exposures. The mushroom house applications are expected to be
an intermittent exposure, at most once a week, and therefore the
mushroom house duration is believed to be short-term only.

e\. Total MOE = 1/ ((1/MOE~dermal~) + (1/MOE~inhalation~)). Target MOE
is 100.

[]{#__RefHeading___Toc120347559 .anchor}**6.4.2 Pressure Treatment
Scenarios (Handler and Post-Application)**

Propiconazole may be used to treat wood and wood products using
pressurized application methods such as vacuum, double vacuum,
full-cell, and modified full-cell. The maximum rate of application used
in this assessment is 1% ai solution for decay control (USEPA, 2005a).
Propiconazole-specific exposure data are not available for assessment of
pressure treatment exposure. Therefore, the assessment relies on
surrogate chromated copper arsenate (CCA) data (ACC, 2002) and was based
on the approach used in a previous exposure assessment (USEPA, 2003).

**[Surrogate Unit Exposure Data]{.underline}**

Dermal and inhalation exposures for pressure treatment uses are derived
from information in the exposure study by the American Chemistry Council
(2002) entitled "*Assessment of Potential Inhalation and Dermal Exposure
Associated with Pressure Treatment of Wood with Arsenical Wood
Products*" (ACC, 2002). In this study, a treatment solution of CCA was
approximately 0.5 percent. The CCA study is the best pressure treatment
data available for a water based solution to estimate exposure to
propiconazole.

The CCA study measured both handlers and post-application activities.
Although there is overlap in job functions, the handlers are defined as
being either treating operators (TOs) or treating assistants (TAs). The
TOs were monitored at three sites (A, B, and C) using 5 replicates at
each site. The TAs were monitored at two sites (Sites A and C) using 5
replicates at each site. The post-application activities included: tram
setter (TS) at Site A (n=5); stacker operator (SO) at Site A (n=4);
loader operator (LO) at Sites A, B, C (n=15); supervisor (S) at Site B
(n=5); test borer (TB) at Site C (n=5); and the tallyman (TM) at Site C
(n=5). According to the CCA study, workers wore cotton long-sleeved
shirts and cotton trousers (or one-piece cotton coveralls) over the
whole-body dosimeters ("plus additional shirts or jackets per typical
practice at Site B") and chemical-resistant or work gloves, when
appropriate. Therefore, the CCA study provides exposure data associated
with maximum PPE (excluding respirators). In using the CCA study for
this propiconazole assessment, the TO and TA handlers are assessed
separately. The post-application job functions, however, have been
combined into one data set to represent post-application activities
because for most activities the sample size is small (5 ≤ n ≤ 15).

The measured CCA dermal and inhalation exposure values were normalized
by the treatment solution concentration used at each of the 3 facilities
(i.e., unit exposure reported as µg arsenic/ppm treatment solution). The
normalization by treatment solution concentration was performed to
extrapolate the measured exposures in the CCA study (monitored at \~0.5%
ai solution) to the maximum propiconazole treatment solution
concentration (1% ai solution). Table 6.9 presents the dermal and
inhalation unit exposure values normalized to the treatment solution
concentration in ppm for (1) all sites, (2) treatment operator (TA
handler), (3) treatment assistant (TA handler), and (4) all
post-application job functions (TS, SO, LO, S, TB, TM).

[Note:]{.underline} The U.S. and Canadian sites indicate a 7x difference
in the mean dermal exposures (US site mean is 0.40 µg As/ppm compared to
the Canadian site mean of 2.84 µg As/ppm). It is recommended that
additional analysis be performed to determine if the increased exposure
levels at the Canadian site can be attributed to differences in
site-specific engineering controls or facility design.

**[Exposure Calculations]{.underline}**

The following equation was used to estimate dermal and inhalation
handler exposure:

Daily Dose = [UE x AI x AB]{.underline}

BW

Where

UE = Unit exposure (mg As/ppm);

AI = AI (1% ai and 0.5% ai in solution);

AB = Absorption factor (40% for dermal, 100% for inhalation); and

BW = Body weight (70 kg).

**[Results]{.underline}**

The estimated dermal and inhalation exposures and risks for
propiconazole are presented in Table 6.10. The calculated dermal,
inhalation, and total MOEs for short-, intermediate-, and long-term
durations are above the target MOE of 100 for all scenarios except for
the intermediate- and long-term dermal and total MOE for the treatment
operator (both MOEs are 86).

All inhalation MOEs exceeded 1,000, therefore, a confirmatory inhalation
toxicity study is not warranted based on the results of these exposure
scenarios.

+---------+-----+------+----------+----------+-----------+-----------+
| **Table |     |      |          |          |           |           |
| 6.9.    |     |      |          |          |           |           |
| Dermal  |     |      |          |          |           |           |
| and     |     |      |          |          |           |           |
| Inh     |     |      |          |          |           |           |
| alation |     |      |          |          |           |           |
| E       |     |      |          |          |           |           |
| xposure |     |      |          |          |           |           |
| Values  |     |      |          |          |           |           |
| from a  |     |      |          |          |           |           |
| CCA     |     |      |          |          |           |           |
| P       |     |      |          |          |           |           |
| ressure |     |      |          |          |           |           |
| Tr      |     |      |          |          |           |           |
| eatment |     |      |          |          |           |           |
| Study   |     |      |          |          |           |           |
| (E      |     |      |          |          |           |           |
| xposure |     |      |          |          |           |           |
| Data    |     |      |          |          |           |           |
| used as |     |      |          |          |           |           |
| Su      |     |      |          |          |           |           |
| rrogate |     |      |          |          |           |           |
| Unit    |     |      |          |          |           |           |
| Ex      |     |      |          |          |           |           |
| posures |     |      |          |          |           |           |
| for     |     |      |          |          |           |           |
| Propic  |     |      |          |          |           |           |
| onazole |     |      |          |          |           |           |
| Assess  |     |      |          |          |           |           |
| ment)** |     |      |          |          |           |           |
+=========+=====+======+==========+==========+===========+===========+
| Site    | Tre |      | S        | Dermal   | Air       | I         |
|         | atm |      | tatistic | Unit     |           | nhalation |
|         | ent |      |          | Exposure | Concent   | Unit      |
|         | So  |      |          |          | ration^b^ | Ex        |
|         | lut |      |          | (g      |           | posure^c^ |
|         | ion |      |          | As/ppm)  | (g       |           |
|         |     |      |          |          | A         | (g       |
|         |     |      |          |          | s/m3/ppm) | As/ppm)   |
+---------+-----+------+----------+----------+-----------+-----------+
|         | \%  | pp   |          |          |           |           |
|         |     | m^a^ |          |          |           |           |
+---------+-----+------+----------+----------+-----------+-----------+
| All     | 0.  | 4    | Average  | 0.97 ±   | 0.00013 ± | 0.00104   |
| sites - | 438 | ,380 | ± std    | Unknown  | 0.00023   |           |
| All     | to  | to   |          |          |           |           |
| Data    | 0.  | 5    |          |          |           |           |
|         | 595 | ,950 |          |          |           |           |
| (n =    |     |      |          |          |           |           |
| 64)     |     |      |          |          |           |           |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | Median   | 0.36     | 0.00013   | 0.00104   |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | 90th     | 2.07     | 0.00077   | 0.00617   |
|         |     |      | pe       |          |           |           |
|         |     |      | rcentile |          |           |           |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | Maximum  | 7.74     | 0.0011    | 0.00882   |
+---------+-----+------+----------+----------+-----------+-----------+
| All     | 0.  | 4    | Average  | 2.04 ±   | 0.00032 ± | 0.00257   |
| sites - | 438 | ,380 | ± std    | 2.68     | 0.00038   |           |
| Handler | to  | to   |          |          |           |           |
| Tr      | 0.  | 5    |          |          |           |           |
| eatment | 595 | ,950 |          |          |           |           |
| O       |     |      |          |          |           |           |
| perator |     |      |          |          |           |           |
|         |     |      |          |          |           |           |
| (n =    |     |      |          |          |           |           |
| 15)     |     |      |          |          |           |           |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | Median   | 0.37     | 0.00013   | 0.00104   |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | 90th     | 5.39     | 0.00092   | 0.00737   |
|         |     |      | pe       |          |           |           |
|         |     |      | rcentile |          |           |           |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | Maximum  | 7.74     | 0.0011    | 0.00882   |
+---------+-----+------+----------+----------+-----------+-----------+
| All     | 0.  | 4    | Average  | 0.24 ±   | 0.0001 ±  | 0.000802  |
| sites - | 438 | ,380 | ± std    | 0.14     | 0.00004   |           |
| Handler | to  | to   |          |          |           |           |
| Tr      | 0.  | 5    |          |          |           |           |
| eatment | 595 | ,950 |          |          |           |           |
| As      |     |      |          |          |           |           |
| sistant |     |      |          |          |           |           |
|         |     |      |          |          |           |           |
| (n =    |     |      |          |          |           |           |
| 10)     |     |      |          |          |           |           |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | Median   | 0.23     | 0.00013   | 0.00104   |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | 90th     | 0.40     | 0.00013   | 0.00104   |
|         |     |      | pe       |          |           |           |
|         |     |      | rcentile |          |           |           |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | Maximum  | 0.52     | 0.00014   | 0.00112   |
+---------+-----+------+----------+----------+-----------+-----------+
| All     | \-- | \--  | Average  | 0.74 ±   | 0.00020 ± | 0.00160   |
| sites   |     |      | ± std    | 0.73     | 0.00025   |           |
| --      |     |      |          |          |           |           |
| Pos     |     |      |          |          |           |           |
| t-appli |     |      |          |          |           |           |
| cation: |     |      |          |          |           |           |
| All job |     |      |          |          |           |           |
| fu      |     |      |          |          |           |           |
| nctions |     |      |          |          |           |           |
| (TS,    |     |      |          |          |           |           |
| SO, LO, |     |      |          |          |           |           |
| S, TB,  |     |      |          |          |           |           |
| TM)     |     |      |          |          |           |           |
|         |     |      |          |          |           |           |
| (n =    |     |      |          |          |           |           |
| 39)     |     |      |          |          |           |           |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | Median   | 0.42     | 0.00013   | 0.00104   |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | 90th     | 1.81     | 0.00050   | 0.00401   |
|         |     |      | pe       |          |           |           |
|         |     |      | rcentile |          |           |           |
+---------+-----+------+----------+----------+-----------+-----------+
|         |     |      | Maximum  | 3.11     | 0.0011    | 0.00882   |
+---------+-----+------+----------+----------+-----------+-----------+

a\. ppm = (% treatment solution) \* (10,000).

b\. Air concentration was calculated as g collected per sample per ppm
/ (480 min per day x 2 L/min).

c\. Inhalation unit exposure = air concentration (g As/m^3^/ppm) \*
breathing rate for light activities (0.0167 m^3^/min) \* sample duration
(480 min).

<table>
<colgroup>
<col style="width: 12%" />
<col style="width: 7%" />
<col style="width: 10%" />
<col style="width: 10%" />
<col style="width: 7%" />
<col style="width: 9%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 9%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 5%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="12"><strong>Table 6.10. Short-, Intermediate-, and
Long-Term Exposures and MOEs for Pressure Treatment Handler and
Post-application Scenarios</strong></th>
</tr>
<tr class="odd">
<th rowspan="3">Exposure Scenario<sup>a</sup></th>
<th colspan="2"><p>Unit Exposure<sup>a</sup></p>
<p>(g As/ppm)</p></th>
<th rowspan="3"><p>Application Rate</p>
<p>(% ai solution)</p></th>
<th colspan="2"><p>Absorbed Daily Doses<sup>b</sup></p>
<p>(mg/kg/day)</p></th>
<th colspan="6">MOEs<sup>c</sup></th>
</tr>
<tr class="header">
<th rowspan="2">Dermal</th>
<th rowspan="2">Inhalation</th>
<th rowspan="2">Dermal</th>
<th rowspan="2">Inhalation</th>
<th colspan="2">Dermal</th>
<th colspan="2">Inhalation</th>
<th colspan="2">Total<sup>d</sup></th>
</tr>
<tr class="odd">
<th>ST</th>
<th>IT/LT</th>
<th>ST</th>
<th>IT/LT</th>
<th>ST</th>
<th>IT/LT</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="12">Occupational Handler</td>
</tr>
<tr class="even">
<td>Treatment Operator (TO)</td>
<td>2.04</td>
<td>0.00257</td>
<td>1</td>
<td>0.12</td>
<td>0.00037</td>
<td>260</td>
<td><strong>86</strong></td>
<td>82,000</td>
<td>27,000</td>
<td>260</td>
<td><strong>86</strong></td>
</tr>
<tr class="odd">
<td>Treatment Assistant (TA)</td>
<td>0.24</td>
<td>0.000802</td>
<td>1</td>
<td>0.014</td>
<td>0.00012</td>
<td>2,200</td>
<td>730</td>
<td>260,000</td>
<td>87,000</td>
<td>2,200</td>
<td>730</td>
</tr>
<tr class="even">
<td colspan="12">Occupational Post-application</td>
</tr>
<tr class="odd">
<td>All (Tram setter, stacker operator, loader operator, supervisor,
test borer, and tallyman)</td>
<td>0.74</td>
<td>0.00160</td>
<td>1</td>
<td>0.042</td>
<td>0.00023</td>
<td>710</td>
<td>240</td>
<td>130,000</td>
<td>44,000</td>
<td>710</td>
<td>240</td>
</tr>
</tbody>
</table>

ST = Short-term duration; IT = Intermediate-term duration; and LT =
long-term.

> a\. Unit exposure values taken from CCA study and are shown in Table
> 6.10.
>
> b\. Absorbed Daily Dose (mg/kg/day) = Unit Exposure (μg As/ppm) \* \[%
> propiconazole in solution (1) \* 10,000 (parts per million
> conversion)\] \* (0.001 mg/μg) \* absorption factor (40% for dermal
> and 100% for inhalation) / Body weight (70 kg).

c\. MOE = NOAEL (mg/kg/day) / Daily dose \[Where short-term NOAEL = 30
mg/kg/day for dermal and inhalation and intermediate-term NOAEL = 10
mg/kg/day for dermal and inhalation\]. Target MOE is 100 for dermal and
inhalation exposures.

d\. Total MOE = 1/ ((1/MOE~dermal~) + (1/MOE~inhalation~)). Target MOE
is 100.

[]{#__RefHeading___Toc120347560 .anchor}

**6.5 Data Limitations/Uncertainties**

There are several data limitations and uncertainties associated with the
occupational handler and postapplication exposure assessments. These
include:

-   Surrogate dermal and inhalation unit exposure values were taken from
    the proprietary Chemical Manufacturers Association (CMA)
    antimicrobial exposure study (USEPA, 1999: DP Barcode D247642) or
    from the Pesticide Handler Exposure Database (USEPA, 1998) (See
    Appendix A for summaries of these data sources). Since the CMA data
    are of poor quality, the Agency requests that confirmatory data be
    submitted to support the occupational scenarios assessed in this
    document.

-   The baseline (ungloved) dermal exposures and risks for material
    preservation of paints, textiles, adhesives, and metalworking fluid
    were calculated using unit exposure values from the cooling tower
    CMA data set because baseline dermal unit exposures are not
    available for preservative or metal fluid CMA unit exposure
    categories.

-   For the wood preservative pressure treatment scenarios, CCA exposure
    data were used for lack of propiconazole-specific exposure data and
    for the wood preservative non-pressure treatment scenarios, DDAC
    exposure data were used for the lack of propiconazole-specific
    exposure data. Limitations and uncertainties associated with the use
    of these data include:

    -   The assumption was made that exposure patterns for workers at
        treatment facilities using CCA and DDAC would be similar to
        exposure patterns for workers at treatment facilities using
        propiconazole, and therefore the exposures could be used as
        surrogate data for workers that treat wood with propiconazole.

    -   For environmental modeling, it was assumed that the leaching
        process from the propiconazole treated wood would be similar to
        that of CCA and DDAC. However, due to the lack of real data for
        propiconazole -treated wood, it is not possible to verify this
        assumption.

```{=html}
<!-- -->
```
-   The quantities handled/treated were estimated based on information
    from various sources, including HED's Standard Operating Procedures
    (SOPs) for Residential Exposure Assessments (USEPA 2000, and 2001)
    and AD's standard assumptions. In certain cases, no standard values
    were available for some scenarios. Assumptions for these scenarios
    were based on AD estimates and could be further refined from input
    from registrants. In particular, the quantities handled/treated for
    the application of propiconazole to wood in mushroom houses through
    high pressure/high volume spray methods could be refined.

-   Inhalation exposures are expected to occur to bystanders as a result
    of material preservative applications in industrial settings.
    Currently, no data are available to assess these bystander exposures
    and therefore, monitoring data are needed.

    []{#__RefHeading___Toc120347561 .anchor}**7.0 REFERENCES**

    American Chemistry Council (ACC). 2002. Assessment of Potential
    Inhalation and Dermal Exposure Associated With Pressure Treatment of
    Wood with Arsenical Wood Products. MRID 4550211-01.

Number range CHAPTERBestari KT, Macey K, Soloman KR, Tower N. 1999.
Measurement and Assessment of Dermal and Inhalation Exposures to Didecyl
Dimethyl Ammonium Chloride (DDAC) Used in the Protection of Cut Lumber
(Phase III). MRID 455243-04.

Cinalli, Christina, et al. A Laboratory Method to Determine the
Retention of Liquids on the Surface of Hands. Exposure Evaluation
Division. September 1992.

NIOSH (1998) What You Need to Know About Occupational Exposure to
Metalworking Fluids. U.S. Department of Health and Human Services.
National Institute for Occupational Safety and Health.

SIMetric. 2005. <http://www.simetric.co.uk/si_materials.htm> Last viewed
November 9, 2005.

USEPA. 1998. PHED Surrogate Exposure Guide. Estimates of Worker Exposure
from the Pesticide Handler Exposure Database Version 1.1. Washington,
DC: U.S. Environmental Protection Agency.

Number range CHAPTERUSEPA. 1999. Evaluation of Chemical Manufacturers
Association Antimicrobial Exposure Assessment Study (Amended on 8
December 1992). Memorandum from Siroos Mostaghimi, PH.D., USEPA to Julie
Fairfax, USEPA. Dated November, 4 1999. DP Barcode D247642.

USEPA. 1997. Exposure Factors Handbook. Volume I-II. Office of Research
and Development. Washington, D.C. EPA/600/P-95/002Fa. August 1997.

USEPA. 2000. Residential SOPs. EPA Office of Pesticide ProgramsBHuman
Health Effects Division. Dated April 5, 2000.

USEPA. 2001. HED Science Advisory Council for Exposure. Policy Update,
November 12. Recommended Revisions to the Standard Operating Procedures
(SOPs) for Residential Exposure Assessment, February 22, 2001.

USEPA. 2003a. Propiconazole -- 3^rd^ Report of the Hazard Identification
Assessment Review Committee. Dated December 17, 2003. TXR No. 0052277.

USEPA. 2003b. Assessment of the Proposed Bardac Wood Preservative
Pressure Treatment Use. Memorandum from Tim Leighton and Siroos
Mostaghimi. February 11, 2003.

USEPA. 2004. Occupational and Residential Exposure Assessment for
Carboquat WP-50. Memorandum from Siroos Mostaghimi, USEPA to Welma
Noble, USEPA. Dated November 4, 2004. DP Barcodes D303714 and D303938.

USEPA 2005a. Propiconazole Use-Closure Memo Amendment. Memorandom from
Jaqueline Guerry, USEPA to Propiconazole RED Team Member, USEPA. Dated
April 22, 2005.

[]{#__RefHeading___Toc120347562 .anchor}**APPENDIX A:**

**Summary of CMA and PHED Data**

*[Chemical Manufacturers Association (CMA) Data:]{.underline}*

In response to an EPA Data Call-In Notice, a study was undertaken by the
Institute of Agricultural Medicine and Occupational Health of The
University of Iowa under contract to the Chemical Manufacturers
Association. In order to meet the requirements of Subdivision U of the
Pesticide Assessment Guidelines (superseded by Series 875.1000-875.1600
of the Pesticide Assessment Guidelines), handler exposure data are
required from the chemical manufacturer specifically registering the
antimicrobial pesticide. The applicator exposure study must comply with
the assessment guidelines for AApplicator Exposure Monitoring@ in
Subdivision U and the AOccupational and Residential Exposure Test
Guidelines@ in Series 875. For this purpose, CMA submitted a study on 28
February, 1990, entitled \"Antimicrobial Exposure Assessment Study
(amended on December 8, 1992)\" which was conducted by William
Popendorf, et al. It was evaluated and accepted by Occupational and
Residential Exposure Branch (OREB) of Health Effect Division (HED),
Office of Pesticides Program (OPP) of EPA in 1990. The purpose of this
CMA study was to characterize exposure to antimicrobial chemicals in
order to support pesticide reregistrations (CMA, 1992). The unit
exposures presented in the most recent EPA evaluation of the CMA
database (USEPA, 1999) were used in this assessment.

The Agency determined that the CMA study had fulfilled the basic
requirements of Subdivision U - Applicator Exposure Monitoring. The
advantages of CMA data over other Asurrogate data sets@ is that the
chemicals and the job functions of mixer/loader/applicator were defined
based on common application methods used for antimicrobial pesticides. A
few of the deficiencies in the CMA data are noted below:

-   The inhalation concentrations were typically below the detection
    limits, so the unit exposures for the inhalation exposure route
    could not be accurately calculated.

-   QA/QC problems including lack of either/or field fortification,
    laboratory recoveries, and storage stability information.

-   Data have an insufficient amount of replicates.

    *[The Pesticide Handlers Exposure Database (PHED):]{.underline}*

The Pesticide Handlers Exposure Database (PHED) has been developed by a
Task Force consisting of representatives from Health Canada, the U.S.
Environmental Protection Agency (EPA), and the American Crop Protection
Association (ACPA). PHED provides generic pesticide worker (i.e.,
mixer/loader and applicator) exposure estimates. The dermal and
inhalation exposure estimates generated by PHED are based on actual
field monitoring data, which are reported generically (i.e., chemical
specific names not reported) in PHED. It has been the Agency=s policy to
use Asurrogate@ or Ageneric@ exposure data for pesticide applicators in
certain circumstances because it is believed that the physical
parameters (e.g., packaging type) or application technique (e.g.,
aerosol can), not the chemical properties of the pesticide, attribute to
exposure levels. \[Note: Vapor pressures for the chemicals in PHED are
in the range of E-5 to E-7 mm Hg.\] Chemical specific properties are
accounted for by correcting the exposure data for study specific field
and laboratory recovery values as specified by the PHED grading
criteria.

PHED handler exposure data are generally provided on a normalized basis
for use in exposure assessments. The most common method for normalizing
exposure is by pounds of active ingredient (ai) handled per replicate
(i.e., exposure in mg per replicate is divided by the amount of ai
handled in that particular replicate). These unit exposures are
expressed as mg/lb ai handled. This normalization method presumes that
dermal and inhalation exposures are linear based on the amount of active
ingredient handled.

[]{#__RefHeading___Toc120347565 .anchor}**APPENDIX B:**

**Calculation of DDAC Unit Exposure Values**

(MRID 455243‑04)

**Table B-1: DDAC Dermal and Inhalation Exposure Values for Chemical
Operators, Graders, Millwrights, Clean-up Crews, and Trim Saw
Operators^a^**

  ------------ ----------- -------------------- ------------- ----------- -------------------- ------------- ----------- -------------------- ------------- ------------ -------------------- ------------- ----------- -------------------- -------------
  Replicate    Chemical                                       Grader                                         Trim Saw                                       Millwright                                      Cleanup                          
  Number       Operator                                                                                      Operator                                                                                       Crew                             

               Dermal      Inhalation                         Dermal      Inhalation                         Dermal      Inhalation                         Dermal       Inhalation                         Dermal      Inhalation           

               Potential   Air                  Potential     Potential   Air                  Potential     Potential   Air                  Potential     Potential    Air                  Potential     Potential   Air                  Potential
               exposure    Concentration^b,c^   exposure^d^   exposure    Concentration^b,c^   exposure^d^   exposure    Concentration^b,c^   exposure^d^   exposure     Concentration^b,c^   exposure^d^   exposure    Concentration^b,c^   exposure^d^
               (mg)        (g/m^3^)            (mg)          (mg)        (g/m^3^)            (mg)          (mg)        (g/m^3^)            (mg)          (mg)         (g/m^3^)            (mg)          (mg)        (g/m^3^)            (mg)

  1            3.5         10.1                 0.0808        3.05        2.90                 0.0232        0.78        2.83                 0.0227        1.31         2.92                 0.0233        68.3        2.99145              0.0239

  2            6.11        2.80                 0.0224        7.47        2.93                 0.0234        1.98        12.3                 0.0984        29.08        2.83                 0.0226        0.720       2.78840              0.0223

  3            6.07        2.79                 0.0223        1.09        2.91                 0.0233                                                       8.03         15.6                 0.1248        166         30.3                 0.2424

  4            46.37       2.82                 0.0226        10.51       3.00                 0.0240                                                                                                       95.2        412                  3.2960

  5            0.94        2.93                 0.0235        0.61        2.82                 0.0226                                                                                                       1.20        2.83585              0.0227

  6            22.15       2.83                 0.0227        0.98        2.85                 0.0228                                                                                                       0.260       2.80989              0.0225

  7            21.45       2.77                 0.0222        2.63        2.91                 0.0233                                                                                                                                        

  8            0.22        2.73                 0.0218        5.23        2.85                 0.0228                                                                                                                                        

  9            0.44        2.77                 0.0222        0.19        13.20                0.1056                                                                                                                                        

  10           0.33        3.14                 0.0251        1.47        2.89                 0.0231                                                                                                                                        

  11           0.29        2.88                 0.0230        2.38        2.85                 0.0228                                                                                                                                        

  12                                                          4.09        2.81                 0.0225                                                                                                                                        

  13                                                          1.03        2.94                 0.0235                                                                                                                                        

  Arithmetic   **9.81**    3.51                 **0.0281**    3.13        3.68                 **0.0295**    **1.38**    7.57                 **0.061**     **12.8**     7.12                 **0.057**     **55.3**    75.6                 **0.60**
  Mean                                                                                                                                                                                                                                       

  Minimum      0.22        2.73                 0.0218        0.19        2.81                 0.0225        0.78        2.83                 0.0227        1.31         2.83                 0.0226        0.260       2.79                 0.0223

  Maximum      46.4        10.1                 0.081         10.51       13.2                 0.106         1.98        12.3                 0.098         29.1         15.6                 0.125         166         412                  3.30
  ------------ ----------- -------------------- ------------- ----------- -------------------- ------------- ----------- -------------------- ------------- ------------ -------------------- ------------- ----------- -------------------- -------------

a\. *"Measurement and Assessment of Dermal and Inhalation Exposures to
Didecyl Dimethyl Ammonium Chloride (DDAC) Used in the Protection of Cut
Lumber (Phase III)"* is the study that values were obtained from for
this table (Bestari et al., 1999, MRID 455243-04).

b\. The inhalation LOD was not provided for chemical operators, graders,
trim saw operators, millwrights, or the clean-up crew. Therefore, the
LOD provided for the diptank operator (5.6 g) was used for these
positions. Residues less than the LOD were adjusted to 1/2 LOD.

c\. The inhalation limit of detection was converted to g/m^3^ using the
following equation: air concentration (g/m^3^) = 5.6 g/ \[average flow
rate (L/min) \* sampling duration (480 min) \* 1000 L/m^3^. Data was
obtained from Bestari et al (1999).

d\. DDAC air concentrations were converted to inhalation exposure using
the following equation: Air concentration (g/m^3^) x inhalation rate
(1.0 m^3^/hr) x Conversion factor (1 mg/1000 g) x sample duration (8
hours/day

**Table B-2: Normalization of DDAC Dermal and Inhalation Exposure Values
for Diptank Operators^a^**

<table>
<colgroup>
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 14%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 13%" />
</colgroup>
<tbody>
<tr class="odd">
<td>Worker ID</td>
<td>Mill number</td>
<td>Sample Time (min)</td>
<td><p>DDAC</p>
<p>Conc. in</p>
<p>Diptank</p>
<p>(%)</p></td>
<td>Gloves</td>
<td>Dermal Body Exposure<sup>b</sup> (mg)</td>
<td>Hand Exposure<sup>b</sup> (mg)</td>
<td>Total Dermal Exposure (mg)</td>
<td><p>Normalized Total Dermal Unit Exposure<sup>c</sup></p>
<p>(mg/ 1 % solution)</p></td>
<td>Air Conc.<sup>d</sup> (mg/m<sup>3</sup>)</td>
<td><blockquote>
<p>Inhalation Exposure<sup>e</sup> (mg)</p>
</blockquote></td>
<td><p>Normalized Inhalation Unit Exposure<sup>c</sup></p>
<p>(mg /1% solution)</p></td>
</tr>
<tr class="even">
<td>M7P1A</td>
<td>7</td>
<td>480</td>
<td>0.64</td>
<td>Rubber</td>
<td>0.5</td>
<td>3.44</td>
<td>3.94</td>
<td>6.16</td>
<td>0.003</td>
<td>0.024</td>
<td>0.0375</td>
</tr>
<tr class="odd">
<td>M7P1B</td>
<td>7</td>
<td>480</td>
<td>0.64</td>
<td>Rubber</td>
<td>0.32</td>
<td>2.02</td>
<td>2.34</td>
<td>3.66</td>
<td>0.003</td>
<td>0.024</td>
<td>0.0375</td>
</tr>
<tr class="even">
<td>M8P4A</td>
<td>8</td>
<td>408</td>
<td>0.42</td>
<td>Rubber</td>
<td>0.04<sup>f</sup></td>
<td>1.34</td>
<td>1.38</td>
<td>3.29</td>
<td>0.003</td>
<td>0.024</td>
<td>0.057</td>
</tr>
<tr class="odd">
<td>M8P4B</td>
<td>8</td>
<td>480</td>
<td>0.42</td>
<td>Rubber</td>
<td>0.04<sup>f</sup></td>
<td>0.5</td>
<td>0.54</td>
<td>1.29</td>
<td>0.003</td>
<td>0.024</td>
<td>0.057</td>
</tr>
<tr class="even">
<td>M8P7</td>
<td>8</td>
<td>480</td>
<td>0.42</td>
<td>Cotton</td>
<td>0.03</td>
<td>0.04</td>
<td>0.07</td>
<td>0.17</td>
<td>0.003</td>
<td>0.024</td>
<td>0.057</td>
</tr>
<tr class="odd">
<td>M11P9A</td>
<td>11</td>
<td>395</td>
<td>0.63</td>
<td>Leather</td>
<td>0.15</td>
<td>3.33</td>
<td>3.48</td>
<td>5.52</td>
<td>0.003</td>
<td>0.024</td>
<td>0.0381</td>
</tr>
<tr class="even">
<td>M11P9B</td>
<td>11</td>
<td>480</td>
<td>0.63</td>
<td>Leather</td>
<td>0.1</td>
<td>0.45</td>
<td>0.55</td>
<td>0.87</td>
<td>0.003</td>
<td>0.024</td>
<td>0.0381</td>
</tr>
<tr class="odd">
<td colspan="5">Arithmetic Mean</td>
<td>0.17</td>
<td>1.59</td>
<td>1.76</td>
<td><strong>2.99</strong></td>
<td>0.0030</td>
<td>0.0240</td>
<td><strong>0.046</strong></td>
</tr>
<tr class="even">
<td colspan="5">Standard Deviation</td>
<td>0.18</td>
<td>1.39</td>
<td>1.53</td>
<td>2.32</td>
<td>0.0000</td>
<td>0.0000</td>
<td>0.0103</td>
</tr>
<tr class="odd">
<td colspan="5">Median</td>
<td>0.10</td>
<td>1.34</td>
<td>1.38</td>
<td>3.29</td>
<td>0.0030</td>
<td>0.0240</td>
<td>0.0381</td>
</tr>
<tr class="even">
<td colspan="5">Geometric Mean</td>
<td>0.10</td>
<td>0.83</td>
<td>0.99</td>
<td>1.86</td>
<td>0.0030</td>
<td>0.0240</td>
<td>0.045</td>
</tr>
<tr class="odd">
<td colspan="5">90%tile</td>
<td>0.39</td>
<td>3.37</td>
<td>3.66</td>
<td>5.78</td>
<td>0.0030</td>
<td>0.0240</td>
<td>0.057</td>
</tr>
<tr class="even">
<td colspan="5">Maximum</td>
<td>0.50</td>
<td>3.44</td>
<td>3.94</td>
<td>6.16</td>
<td>0.0030</td>
<td>0.0240</td>
<td>0.057</td>
</tr>
</tbody>
</table>

a\. *"Measurement and Assessment of Dermal and Inhalation Exposures to
Didecyl Dimethyl Ammonium Chloride (DDAC) Used in the Protection of Cut
Lumber (Phase III)"* is the study that values were obtained from for
this table (Bestari et al., 1999, MRID 455243-04, Task Force \# 73154).

b\. DDAC concentration that was detected in the monitoring study (MRID
#455243-04).

c\. Normalization of DDAC data for percent ai treatment. Normalized Unit
Exposure (mg/1% ai solution) = Exposure (mg DDAC) / concentration in
diptank solution (% DDAC)

d\. All inhalation residues were \<LOD (5.6 g or 0.0056 mg/m3). 1/2 LOD
was used in all calculations (0.003 mg/m^3^). Air Concentration (mg/m3)
= 5.6 g / (\~2 L/min flow rate x \~480 min) x 1000 L/m^3^ conversion x
0.001 g/mg = 0.003 mg/m^3^

e\. Inhalation exposure (mg) = air concentration (mg/m^3^) x inhalation
rate (1.0 m^3^/hr) x sample duration (8 hours/day).

f\. Residues were \<LOD for dermal samples M8P4A, M8P4B. Sample size of
\~11,231 cm^2^ x \<0.007 ug/cm^2^ = LOD of 0.079 mg. 1/2 LOD reported
(i.e., 0.04 mg)

[^1]: It should be noted that Syngenta and Janssen agree to withdraw the
    use of propiconazole for the treating of carpet fibers, apparel, and
    furnishings. The primary textile use includes "canvas" (i.e.,
    awnings, boat covers, carpet backing, cordage, tents, tarpaulins,
    and wall coverings).

[^2]: It should be noted that Syngenta and Janssen agree to withdraw the
    use of propiconazole for the treating of carpet fibers, apparel, and
    furnishings. The primary textile use includes "canvas" (i.e.,
    awnings, boat covers, carpet backing, cordage, tents, tarpaulins,
    and wall coverings).