**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY**

**WASHINGTON, D.C. 20460**

![](media/image1.png){width="5.330555555555556in"
height="0.4777777777777778in"}

**April 19, 2006**

**[MEMORANDUM]{.underline}**

**SUBJECT: Occupational and Residential Exposure Assessment for
2-(Thiocyanomethylthio)benzothiazole TCMTB.**

**From:** **Siroos Mostaghimi, Ph.D., Senior Scientist**

**Risk Assessment and Science Support Branch (RASSB)**

**Antimicrobials Division (7510C)**

**To: Mark Hartman, Acting Branch Chief**

**Regulatory Management Branch II**

**Antimicrobials Division (7510C)**

**Through: Norm Cook, Chief**

**Risk Assessment and Science Support Branch (RASSB)**

**Antimicrobials Division (7510C)**

**Chemical No: 35603**

**DP Barcode: 322615**

> Attached please find the Occupational and Residential Exposure
> Assessment RED Chapter for **2-(Thiocyanomethylthio)benzothiazole
> (**TCMTB).

**EXECUTIVE SUMMARY**

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

TCMTB is the active ingredient in numerous types of products. The
products are used in commercial/institutional premises, residential and
public access areas, as material preservatives, industrial processes and
water systems, and as wood preservatives (Use Site Categories III, IV,
VII, VIII, and X, respectively). Examples of uses include use in pulp
and paper process water, use for sapstain control, and use as a textile
preservative. Products containing TCMTB are formulated as liquid
ready-to-use, soluble concentrate, and emulsifiable liquid. The
percentage of TCMTB in the various end-use products ranges from 1.0% to
60%.

[]{.mark}

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, and ST oral exposures.
The ST/IT/LT dermal endpoint is 25 mg/kg/day (target MOE = 100 for
ST/IT, 300 for LT), based on a 21-day dermal toxicity study in rats. The
adverse effects for this endpoint include decreased body weight gain,
hematological changes, and clinical chemistry changes. For oral exposure
scenarios, the ST endpoint is 16 mg/kg/day (target MOE = 100), based on
a rabbit developmental study in which reduced body weight gain and food
consumption was observed. The short- and intermediate-term inhalation
endpoint of 16 mg/kg/day (target MOE = 100 for ST/IT and MOE=300 for LT)
is also based on the same effects from the rabbit developmental study,
as well as on a 90-day rodent study in which increased incidence of
histopathology of the stomach was observed, including inflammation,
necrosis, and ulceration.

[]{.mark}

This occupational and residential assessment was 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, post-application exposures are
likely to occur in these settings. The representative scenarios selected
by the Antimicrobials Division (AD) for assessment were evaluated using
maximum application rates as stated on the product labels. The
representative scenarios are believed to provide high-end estimates of
dermal, inhalation, and incidental oral exposure.

[]{.mark}

To assess most handler risks, AD used surrogate unit exposure data from
the Chemical Manufacturers Association (CMA) antimicrobial exposure
study and the Pesticide Handlers Exposure Database (PHED). Additionally,
handler and post-application exposures resulting from wood preservation
activities were assessed using surrogate data from 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). Because the
study is proprietary, data compensation needs to be paid for use of
these data in this exposure assessment.

***Residential Handler Risk Summary***

[]{.mark}

For the [residential]{.underline} handler dermal and inhalation risk
assessment, the dermal MOEs were slightly below the target MOE of 100
for painting with a brush/roller and are of concern for the airless
sprayer. The inhalation MOEs were above the target MOE of 300 for all
scenarios. Specifically, the dermal MOEs, which are less than the target
MOE include:

-   Painting, brush/roller: ST dermal MOE = **25**

-   Painting, airless sprayer: ST dermal MOE = **10**

The total MOES were less than the target MOE of 100 for:

-   Painting, brush/roller: ST dermal MOE = **24.9**

-   Painting, airless sprayer: ST dermal MOE = **9.8**

***Residential Post-Application/Bystander Risk Summary***

[]{.mark}

For the [residential]{.underline} post-application risk assessment, MOEs
are above the respective target MOEs for all scenarios except for the
following:

-   Dermal exposure to toddlers contacting treated carpets: ST Dermal
    MOE = **2**, ST Oral MOE = **4**

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-   Dermal exposure to adults contacting treated clothing: ST Dermal MOE
    **\< 1** using 100% transfer factor, ST Dermal MOE = **9** using 5%
    transfer factor.

    -   Dermal exposure to toddlers contacting treated clothing: ST
        Dermal MOE **\< 1** using 100% transfer factor, ST Dermal MOE =
        **6** using 5% transfer factor.

-   Incidental oral exposure to toddlers mouthing treated clothing: ST
    Oral MOE = **21**

***Occupational Handler Risk Summary***

For the [occupational]{.underline} handler dermal and inhalation risk
assessment, the MOEs were above the target MOE of 100 for ST/IT dermal
and inhalation or 300 for LT dermal and inhalation for all scenarios
except for the scenarios listed below. Tables 5.2 through 5.6 present
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.

-   Paint Application -- Airless Sprayer: ST/IT Dermal MOE = **6**
    (ungloved) and **17** (gloved).

-   Paint Application -- Paintbrush: ST/IT Dermal MOE = **30**
    (ungloved) and **97** (gloved)

-   Paint Preservation -- Liquid Pour: ST/IT Dermal MOE = **1**
    (ungloved)

-   Paint Preservation -- Liquid Pump: ST/IT Dermal MOE = **26**
    (ungloved)

-   Textile Preservation -- Liquid Pour: ST/IT Dermal MOE = **\<1**
    (ungloved)

-   Textile Preservation -- Liquid Pump: ST/IT Dermal MOE = **64**
    (ungloved)

-   Cutting Fluid Preservation -- Liquid Pour: ST/IT Dermal MOE = **11**
    (ungloved)

-   Pulp and Paper -- Liquid Pump: ST/IT Dermal MOE = **5** (ungloved)

[]{.mark}

The total MOEs were less than the target MOE of 100 for the following
exposure scenarios:

-   Paint Application -- Airless Sprayer: MOE = **16**

-   Paint Application -- Paintbrush: MOE = **95**

[]{.mark}

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

[]{.mark}

For the [occupational]{.underline} post-application risk assessment, the
MOEs were above their respective target MOEs, and therefore not of
concern for all scenarios.

***Data Limitations and Uncertainties:***

There are a number of uncertainties associated with this assessment. The
data limitations and uncertainties associated with the residential
handler and post-application exposure assessments include the following:

[]{.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 B for summaries of these data sources). Most of the CMA
    data are of poor quality; therefore, AD requests that confirmatory
    monitoring data be generated to support the values used in these
    assessments.

-   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.

[]{.mark}

The data limitations and uncertainties associated with the occupational
handler and post-application 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 B 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.

-   Unit exposures are not available for some of the specific scenarios
    that are prescribed for TCMTB. These scenarios include the
    following: open loading into oil-well/field environments and
    metering into cooling water systems at power plants.

-   For the wood preservative treatment scenarios, DDAC exposure data
    were used for the lack of TCMTB-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 DDAC would be similar to exposure
    patterns for workers at treatment facilities using TCMTB, and
    therefore the exposures could be used as surrogate data for workers
    that treat wood with TCMTB.

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

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-   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 personal communication with experts. In particular, the use
    information for the pulp and paper processing, oil-well uses, and
    cooling water tower uses are based on personal communication with
    biocide manufacturers for these types of uses. The individuals
    contacted have experience in these operations and their estimates
    are believed to be the best available without undertaking a
    statistical survey of the uses. 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. For example, the quantities handled/treated for
    the application of TCMTB to the surface of metal/wood cooling towers
    could be refined.

More detailed discussions of the uncertainties and limitations can be
found in Sections 4.2.3 (residential) and 5.3 (occupational).

**1.0 INTRODUCTION**

**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 TCMTB. This information is for use in EPA\'s
development of the TCMTB Re-registration Eligibility Decision (RED)
Document.

**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 TCMTB, both criteria are met.
Toxicological endpoints were selected for short-, intermediate- and
long-term dermal, inhalation, and incidental oral exposures to TCMTB.
There is a significant potential for exposure in a variety of
occupational and residential settings. Therefore, risk assessments are
required for occupational and residential handlers as well as for
occupational and residential post-application exposures that can occur
as a result of TCMTB use.

In this document, handler 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. 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; 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 presented in 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:

-   TCMTB 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 TCMTB uses.

-   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.

-   The maximum application rates allowed by labels were assumed.

[]{.mark}

**1.3 Chemical Identification**

  ----------------------------------------------------------------------------------------
  **Table 1.1 Chemical Information    
  for TCMTB**                         
  ----------------------------------- ----------------------------------------------------
  Common Name:                        2-(Thiocyanomethylthio)benzothiazole (TCMTB)

  Chemical Name:                      2-(Benzothiazolylthio)methyl thiocyanate

  Other Names:                        TCMB

  CAS Number:                         21564-17-0

  OPP Chemical Code:                  035603

  Case Number:                        2625

  Empirical Formula:                  C~9~H~6~N~2~S~3~

  Molecular Structure:                ![](media/image2.png){width="1.4645833333333333in"
                                      height="1.3041666666666667in"}
  ----------------------------------------------------------------------------------------

**1.4 Physical/Chemical Properties**

Table 1.4 shows physical/chemical characteristics that have been
reported for TCMTB.

  -----------------------------------------------------------------------
  **Table 1.2. Physical/Chemical   
  Properties of TCMTB^1^**         
  -------------------------------- --------------------------------------
  Parameter                        TCMTB

  Molecular Weight                 238.4

  Melting Point                    150C

  Water Solubility                 42 mg/L at 25C

  Vapor Pressure                   3.1x10^-7^ mm Hg at 25C
  -----------------------------------------------------------------------

> ^1^ Melting point, water solubility, and vapor pressure estimated
> using PBT Profiler, a screening level tool (USEPA, 2004).

**2.0 USE INFORMATION**

**2.1 Formulation Types and Percent Active Ingredient**

The products containing TCMTB as the active ingredient (a.i.) are
formulated as liquid ready-to-use, soluble concentrate, emulsifiable
concentrate, and wettable powder. Concentrations of TCMTB in these
products range from 1.0% to 60%.

**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
Appendix A. Based on a review of product labels, TCMTB is the active
ingredient in products used in the following use site categories: III
(Commercial, institutional and industrial premises and equipment), IV
(Residential and public access premises), VII (Material Preservation),
VIII (Industrial processes and water systems), and X (Wood
preservatives).

[]{.mark}

From the scenarios in Appendix A (Master TCMTB Label List), AD selected
representative exposure scenarios to assess the labeled uses of TCMTB 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, inhalation, or incidental ingestion exposure. The representative
scenarios assessed in this document are shown in Table 4.1 (residential)
and Table 5.1 (occupational).

[]{.mark}

**3.0 SUMMARY OF TOXICITY DATA**

**3.1 Acute Toxicity**

The acute toxicity values for TCMTB are presented in Table 3.1.

+--------+----------------+----------+-----------------+--------------+
| *      |                |          |                 |              |
| *Table |                |          |                 |              |
| 3.1.   |                |          |                 |              |
| Acute  |                |          |                 |              |
| To     |                |          |                 |              |
| xicity |                |          |                 |              |
| of     |                |          |                 |              |
| T      |                |          |                 |              |
| CMTB** |                |          |                 |              |
+========+================+==========+=================+==============+
| Gui    | Study Type     | MRID     | Results         | Toxicity     |
| deline |                | #(s)     |                 | Category     |
|        |                |          |                 |              |
| No.    |                |          |                 |              |
+--------+----------------+----------+-----------------+--------------+
| 81-1   | Acute Oral     | 41583801 | LD~50~ = 750    | III          |
|        |                |          | mg/kg           |              |
+--------+----------------+----------+-----------------+--------------+
| 81-2   | Acute Dermal   | 41515401 | LD~50~ \> 2000  | III          |
|        |                |          | mg/kg           |              |
+--------+----------------+----------+-----------------+--------------+
| 81-3   | Acute          | 41640601 | LC~50~ = 0.07   | I            |
|        | Inhalation     |          | mg/L            |              |
+--------+----------------+----------+-----------------+--------------+
| 81-4   | Primary Eye    |          | No acceptable   | I            |
|        | Irritation     |          | studies; all    |              |
|        |                |          | show            |              |
|        |                |          | corrosivity     |              |
+--------+----------------+----------+-----------------+--------------+
| 81-5   | Primary Skin   | 41583701 | Severe erythema | II           |
|        | Irritation     |          | at 72 hrs.      |              |
+--------+----------------+----------+-----------------+--------------+
| 81-6   | Dermal         | 111991   |                 | Positive     |
|        | Sensitization  |          |                 | Sensitizer   |
+--------+----------------+----------+-----------------+--------------+

[]{.mark}

[]{.mark}

**3.2 Summary of Toxicity Endpoints**

Table 3.2 summarizes the toxicological endpoints for TCMTB.

**Table 3.2. Summary of Toxicity Endpoints Selected for TCMTB**

+------------+---------------+---------------+------------------------+
| **         | **Dose Used   | **Target      | **Study and            |
| Exposure** | in Risk       | MOEs/UFs FQPA | Toxicological          |
|            | Assessment**  | safety factor | Effects**              |
| **         |               | for Risk      |                        |
| Scenario** | **            | Assessment**  |                        |
|            | (mg/kg/day)** |               |                        |
+------------+---------------+---------------+------------------------+
| **Acute    | **NOAE        | **Target      | Developmental Toxicity |
| Dietary**  | L(maternal)** | MOE** = 100   | Study in Rats          |
|            | = 25.1        |               | (accession no. 260491) |
| (general   | mg/kg/day     | **UF** = 100  |                        |
| population |               | (10x          | **LOAEL(maternal)** =  |
| including  |               | inter-species | 76.5 mg /kg/day, based |
| infants    |               | e             | on clinical signs of   |
| and        |               | xtrapolation, | toxicity (ventral      |
| children)  |               | 10x           | alopecia, rough coat,  |
|            |               | intra-species | dyspnea/wheezing, oral |
|            |               | variation)    | discharge,             |
|            |               |               | diarrhea/loose stool,  |
|            |               | **FQPA SF** = | urine staining,        |
|            |               | 1x            | piloerection, and      |
|            |               |               | hunched gait).         |
|            |               | **Acute PAD** |                        |
|            |               | = 0.25        |                        |
|            |               |               |                        |
|            |               | mg/kg/day     |                        |
+------------+---------------+---------------+------------------------+
| **Acute    | An endpoint   |               |                        |
| Dietary**  | for females   |               |                        |
|            | 13-49 was not |               |                        |
| (females   | identified in |               |                        |
| 13-49)     | the available |               |                        |
|            | database for  |               |                        |
|            | TCMTB. This   |               |                        |
|            | risk          |               |                        |
|            | assessment is |               |                        |
|            | not required. |               |                        |
+------------+---------------+---------------+------------------------+
| **Chronic  | **LOAEL** =   | **Target      | Chronic Toxicity Study |
| Dietary**  | 3.8 mg/kg/day | MOE** = 300   | in Dogs (MRID          |
|            |               |               | 41342201)              |
| (all       |               | **UF** = 100  |                        |
| po         |               | (10x          | **LOAEL** = 3.8        |
| pulations) |               | inter-species | mg/kg/day (males),     |
|            |               | e             | based on decreased     |
|            |               | xtrapolation, | body weight gain,      |
|            |               | 10x           | decreased white cells, |
|            |               | intra-species | monocytes, and plasma  |
|            |               | variation)    | ALT in males;          |
|            |               |               | decreased plasma ALT   |
|            |               | **DB UF** =3  | and uterine weight in  |
|            |               | (3x for use   | females.               |
|            |               | of a LOAEL)   |                        |
|            |               |               |                        |
|            |               | **FQPA SF** = |                        |
|            |               | 1x            |                        |
|            |               |               |                        |
|            |               | **Chronic     |                        |
|            |               | PAD** = 0.013 |                        |
|            |               |               |                        |
|            |               | mg/kg/day     |                        |
+------------+---------------+---------------+------------------------+
| **         | **NOAEL**= 16 | **Target      | Developmental Toxicity |
| Incidental | mg/kg/day     | MOE** = 100   | Study in Rabbits (MRID |
| Oral**     |               |               | 40075102)              |
| Short- and |               | **UF** = 100  |                        |
| Interme    |               | (10x          | **LOAEL** = 32         |
| diate-Term |               | inter-species | mg/kg/day, based on    |
|            |               | e             | decreased body weight  |
| (1-30      |               | xtrapolation, | gain and food          |
| days; 30   |               | 10x           | consumption in         |
| days-6     |               | intra-species | maternal animals.      |
| months)    |               | variation)    |                        |
|            |               |               |                        |
|            |               | **FQPA SF** = |                        |
|            |               | 1x            |                        |
+------------+---------------+---------------+------------------------+
| **Dermal** | **NOAEL**= 25 | **Target      | 21-Day Dermal Toxicity |
|            | mg/kg/day     | MOE** = 100   | Study in Rats (MRID    |
| All        |               | (ST and IT)   | 41655801)              |
| Durations  |               |               |                        |
|            |               | **Target      | **LOAEL** = 100        |
| (1-30      |               | MOE** = 300   | mg/kg/day, based on    |
| days; 1-6  |               | (LT)          | decreased body weight  |
| months; \> |               |               | gain, food             |
| 6 months)  |               | **UF** = 100  | consumption, and       |
|            |               | (10x          | hematological and      |
|            |               | inter-species | clinical chemistry     |
|            |               | e             | changes.               |
|            |               | xtrapolation, |                        |
|            |               | 10x           |                        |
|            |               | intra-species |                        |
|            |               | variation)    |                        |
|            |               |               |                        |
|            |               | **DB UF** = 3 |                        |
|            |               | (3x for use   |                        |
|            |               | of a          |                        |
|            |               | subchronic    |                        |
|            |               | endpoint)     |                        |
|            |               |               |                        |
|            |               | **FQPA SF** = |                        |
|            |               | 1x            |                        |
+------------+---------------+---------------+------------------------+
| **In       | **NOAEL** =   | **Target      | Developmental Toxicity |
| halation** | 16 mg/kg/day  | MOE** = 100   | Study in Rabbits (MRID |
|            |               |               | 40075102)              |
| Short- and |               | (ST and IT)   |                        |
| Interme    |               |               | **LOAEL** = 32         |
| diate-Term |               | **UF** = 100  | mg/kg/day, based on    |
|            |               | (10x          | decreased body weight  |
| (1-30      |               | inter-species | gain and food          |
| days; 1-6  |               | e             | consumption in         |
| months)    |               | xtrapolation, | maternal animals       |
|            |               | 10x           |                        |
|            |               | intra-species |                        |
|            |               | variation)    |                        |
|            |               |               |                        |
|            |               | **Note:** an  |                        |
|            |               | additional    |                        |
|            |               | 10x is        |                        |
|            |               | necessary for |                        |
|            |               | route         |                        |
|            |               | e             |                        |
|            |               | xtrapolation. |                        |
|            |               | If results    |                        |
|            |               | are below a   |                        |
|            |               | MOE of 1,000, |                        |
|            |               | a             |                        |
|            |               | confirmatory  |                        |
|            |               | inhalation    |                        |
|            |               | study may be  |                        |
|            |               | required      |                        |
+------------+---------------+---------------+------------------------+
| **In       | **LOAEL** =   | **Target      | Chronic Toxicity Study |
| halation** | 3.8 mg/kg/day | MOE** = 300   | in Dogs (MRID          |
|            |               | (LT)          | 41342201)              |
| Long-Term  |               |               |                        |
|            |               | **UF** = 100  | **LOAEL** = 3.8        |
| (\> 6      |               | (10x          | mg/kg/day (males),     |
| months)    |               | inter-species | based on decreased     |
|            |               | e             | body weight gain,      |
|            |               | xtrapolation, | decreased white cells, |
|            |               | 10x           | monocytes, and plasma  |
|            |               | intra-species | ALT in males;          |
|            |               | variation)    | decreased plasma ALT   |
|            |               |               | and uterine weight in  |
|            |               | **Note:** an  | females.               |
|            |               | additional    |                        |
|            |               | 10x is        |                        |
|            |               | necessary for |                        |
|            |               | route         |                        |
|            |               | e             |                        |
|            |               | xtrapolation. |                        |
|            |               | If results    |                        |
|            |               | are below a   |                        |
|            |               | MOE of 1,000, |                        |
|            |               | a             |                        |
|            |               | confirmatory  |                        |
|            |               | inhalation    |                        |
|            |               | study may be  |                        |
|            |               | required      |                        |
+------------+---------------+---------------+------------------------+
| **Carcino  | The CPRC      |               |                        |
| genicity** | concluded     |               |                        |
|            | that TCMTB    |               |                        |
|            | should be     |               |                        |
|            | classified as |               |                        |
|            | Group C -     |               |                        |
|            | possible      |               |                        |
|            | human         |               |                        |
|            | carcinogen -  |               |                        |
|            | and           |               |                        |
|            | recommended   |               |                        |
|            | that for the  |               |                        |
|            | purpose of    |               |                        |
|            | risk          |               |                        |
|            | char          |               |                        |
|            | acterization, |               |                        |
|            | the Reference |               |                        |
|            | Dose (RfD)    |               |                        |
|            | approach      |               |                        |
|            | should be     |               |                        |
|            | used for      |               |                        |
|            | quantitation  |               |                        |
|            | of human      |               |                        |
|            | risk. This    |               |                        |
|            | was based on  |               |                        |
|            | statistically |               |                        |
|            | significant   |               |                        |
|            | increases in  |               |                        |
|            | tumors in     |               |                        |
|            | both sexes of |               |                        |
|            | the           |               |                        |
|            | S             |               |                        |
|            | prague-Dawley |               |                        |
|            | rat:          |               |                        |
|            | testicular    |               |                        |
|            | interstitial  |               |                        |
|            | cell adenomas |               |                        |
|            | in males and  |               |                        |
|            | thyroid       |               |                        |
|            | c-cell        |               |                        |
|            | adenomas in   |               |                        |
|            | females.      |               |                        |
+------------+---------------+---------------+------------------------+

[]{.mark}

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.

[]{.mark}

**4.0 RESIDENTIAL EXPOSURE ASSESSMENT**

**4.1 Summary of Registered Uses**

Products containing TCMTB can be used in paints as a preservative.
Residents may also be exposed to items that have been treated with TCMTB
in occupational settings, such as dimensional lumber for decks and play
sets, and treated textiles. Appendix A presents a summary of all
exposure scenarios that may occur in residential settings based on
examination of product labels. Table 4.1 identifies the representative
exposure scenarios assessed in this document.

[]{.mark}

**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 TCMTB-preserved paint.
Post-application exposures were assessed for dermal and/or oral contact
with treated surfaces (textiles and lumber).

[]{.mark}

+-------------+-----------+--------------+-----------+----------------+
| **Table     |           |              |           |                |
| 4.1.        |           |              |           |                |
| Rep         |           |              |           |                |
| resentative |           |              |           |                |
| Uses        |           |              |           |                |
| Associated  |           |              |           |                |
| with        |           |              |           |                |
| Residential |           |              |           |                |
| Exposure**  |           |              |           |                |
+=============+===========+==============+===========+================+
| Rep         | Ap        | Exposure     | Reg       | Application    |
| resentative | plication | Scenario     | istration | Rate           |
| Use         | Method(s) |              | \#        |                |
+-------------+-----------+--------------+-----------+----------------+
| Paint       | -         | ST Handler:  | 1448-55   | 0.015 a.i.     |
|             |   Airless | adult dermal |           | weight         |
|             |           | and          |           | fraction in    |
|             |   sprayer | inhalation   |           | preserved      |
|             |           |              |           | paint          |
|             | -   P     |              |           |                |
|             | aintbrush |              |           | \[(5% product) |
|             |     /     |              |           | x (30% ai)\]   |
|             |           |              |           |                |
|             |    Roller |              |           |                |
+-------------+-----------+--------------+-----------+----------------+
| Carpets     | -   NA^1^ | ST Post-app: | 1448-55   | 0.006 a.i.     |
|             |           | child        |           | weight         |
|             |           | incidental   |           | fraction in    |
|             |           | ingestion    |           | preserved      |
|             |           | and dermal   |           | carpet         |
|             |           |              |           |                |
|             |           |              |           | \[(2% product) |
|             |           |              |           | x (30% ai)\]   |
+-------------+-----------+--------------+-----------+----------------+
| Wearing     | -   NA^1^ | ST Post-app: | 1448-55   | 0.006 a.i.     |
| treated     |           | child        |           | weight         |
| clothing    |           | incidental   |           | fraction in    |
|             |           | ingestion    |           | preserved      |
|             |           | and dermal   |           | clothing       |
|             |           |              |           |                |
|             |           |              |           | \[(2% product) |
|             |           |              |           | x (30% ai)\]   |
+-------------+-----------+--------------+-----------+----------------+
| Contacting  | -   NA^1^ | ST Post-app: | 1448-55   | 0.003 a.i.     |
| Preserved   |           | child        |           | weight         |
| Wood        |           | incidental   |           | fraction in    |
|             |           | ingestion    |           | preserved wood |
|             |           | and dermal   |           |                |
|             |           |              |           | \[(1% product) |
|             |           |              |           | x (30% ai)\]   |
+-------------+-----------+--------------+-----------+----------------+

^1^ The handler scenarios were not assessed because application of TCMTB
to carpets, textiles, and wood can only be performed by occupational
handlers.

[]{.mark}

**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 B.

**Unit Exposure Values**: Unit exposure values were taken from the PHED
data presented in HED's Residential SOPs (USEPA, 2000).

-   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 using an airless sprayer 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.

-   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.

-   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.

**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
activities, not exclusively TCMTB 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 MOEs were below the target MOE of 100 for both scenarios (10 for
airless sprayer and 25 for paintbrush). The inhalation MOEs were above
the target MOE of 300.

The short-term dermal MOEs for the paintbrush and airless spray
scenarios are below the short-term dermal target MOE of 100. The total
MOEs were less than the Target MOE of 100.

<table style="width:100%;">
<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: 8%" />
<col style="width: 10%" />
<col style="width: 9%" />
<col style="width: 9%" />
</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</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">ST 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 MOE= 100)</td>
<td><p>Inhalation</p>
<p>(Target = 100)</p></td>
<td><p>Total</p>
<p>MOE</p>
<p>(Target MOE=100)</p></td>
</tr>
<tr class="even">
<td>Painting – Airless Sprayer</td>
<td>0.015 a.i. weight fraction</td>
<td>150 lb/day</td>
<td>79</td>
<td>0.83</td>
<td>2.54</td>
<td>0.0267</td>
<td><strong>10</strong></td>
<td>600</td>
<td><strong>9.8</strong></td>
</tr>
<tr class="odd">
<td><p>Painting—</p>
<p>Paintbrush/Roller</p></td>
<td>0.015 a.i. weight fraction</td>
<td>20 lb/day</td>
<td>230</td>
<td>0.284</td>
<td>0.986</td>
<td>0.00122</td>
<td><strong>25</strong></td>
<td>13,000</td>
<td><strong>24.9</strong></td>
</tr>
</tbody>
</table>

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

b Amount handled per day values are estimates.

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

d No respirator used by exposed individual.

e Absorbed Daily dose (mg/kg/day) = \[unit exposure (mg/lb a.i.) \*
application rate (a.i. weight fraction) \* quantity treated (lb/day)\]/
Body weight (70 kg).

f MOE = NOAEL / Absorbed Daily Dose. \[Where short-term dermal NOAEL =
25 mg/kg/day and short-term inhalation NOAEL = 16 mg/kg/day\]. Target
MOE is 100 for dermal and inhalation.

[]{.mark}

**4.2.2 Residential Post-application Exposures**

For the purposes of this screening level assessment, post-application
scenarios have been developed that encompass multiple products, but
still represent a high end exposure scenario for all products
represented. As shown in Table 4.1, representative post-application
scenarios assessed include crawling on carpets, and wearing treated
clothing (dermal exposure to adults and children and incidental oral
exposure to children). []{.mark}

[]{.mark}

[]{.mark}

[]{.mark}

[]{.mark}

**4.2.2.1 Treated Carpets**

***Dermal Exposure to Toddlers from Treated Carpets***

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

There is the potential for dermal exposure to toddlers crawling on
carpets preserved with TCMTB. Short-term risks have been presented, as
the preservative is applied only during the manufacturing of the carpet.

Potential doses are calculated as follows:

*PDD = [C x SA x TR ]{.underline}* **(Eq. 4)**

*BW*

Where:

> PDD = potential daily dose (mg/kg/day);
>
> C = concentration on carpet (mg/m^2^);
>
> SA = surface area of skin that contacts the treated carpet (m^2^/day);
>
> TR = transferable residue from carpet to skin (%); and
>
> BW = body weight (kg).

And

*C = WF~ai~ x W x CF1 x CF2* **(Eq. 5)**

Where:

> C = concentration on carpet (mg/m^2^);

WF~ai~ = weight fraction of a.i. in treated carpet (unitless);

> W = face weight of carpet (oz/yd^2^);

CF1 = unit conversion factor (28,349 mg/oz); and

> CF2 = unit conversion factor (1.196 yd^2^/m^2^).

**[Assumptions]{.underline}**

-   The product is applied at a rate of 0.006 a.i. weight fraction to
    the carpet.

-   The face weight of the carpet is assumed to weigh 35 oz/yd^2^ (the
    face weight only includes the carpet fibers, not the backing
    materials). The face weight is a conservative value as the child
    will most likely only be exposed to the top portion of the carpet
    fibers (Doityourself.com, 2005).

-   Toddlers (3 years old) were used to represent the 1 to 6 year old
    age group. A body surface area of 0.657 m^2^ and a body weight of 15
    kg were assumed, which are the median values for 3 year olds (USEPA,
    1997).

-   No transferable residue data were available that could be used to
    estimate the transfer of TCMTB from the carpet to skin under dry
    conditions. Therefore, it is assumed that 5% of the residue on the
    treated carpet is available for dermal transfer (USEPA, 2000 and
    2001).

**[Results]{.underline}**

The calculation of the dermal dose and MOE are shown in Table 4.3. The
dermal MOE is below the target MOE of 100.

+-------+----------+-------+----------+---------+--------+-----------+
| **    |          |       |          |         |        |           |
| Table |          |       |          |         |        |           |
| 4.3:  |          |       |          |         |        |           |
| D     |          |       |          |         |        |           |
| ermal |          |       |          |         |        |           |
| P     |          |       |          |         |        |           |
| ost-A |          |       |          |         |        |           |
| pplic |          |       |          |         |        |           |
| ation |          |       |          |         |        |           |
| Expo  |          |       |          |         |        |           |
| sures |          |       |          |         |        |           |
| and   |          |       |          |         |        |           |
| MOEs  |          |       |          |         |        |           |
| for   |          |       |          |         |        |           |
| Tod   |          |       |          |         |        |           |
| dlers |          |       |          |         |        |           |
| Conta |          |       |          |         |        |           |
| cting |          |       |          |         |        |           |
| Tr    |          |       |          |         |        |           |
| eated |          |       |          |         |        |           |
| Carp  |          |       |          |         |        |           |
| ets** |          |       |          |         |        |           |
+-------+----------+-------+----------+---------+--------+-----------+
| W     | W (face  | C     | SA       | TR      | PDD^b^ | ST Dermal |
| F~ai~ | weight   | (Conc | (Surface | (trans  | (mg/k  | MOE^c^    |
| (fra  | of       | .)^a^ | Area     | ferable | g/day) |           |
| ction | carpet)  |       | exposed) | r       |        |           |
| a.i.  | (o       | (mg/  | (m       | esidue) |        |           |
| in    | z/yd^2^) | m^2^) | ^2^/day) |         |        |           |
| ca    |          |       |          |         |        |           |
| rpet) |          |       |          |         |        |           |
+-------+----------+-------+----------+---------+--------+-----------+
| 0.006 | 35.0     | 7,120 | 0.657    | 5%      | 15.6   | **2**     |
+-------+----------+-------+----------+---------+--------+-----------+

a\. Concentration on carpet (mg/cm^2^) = (fraction a.i. in treated
carpet) \* (face weight of carpet, oz/yd^2^) \* (28,349 mg/oz) \* (1.196
yd^2^/m^2^)

b . Absorbed Potential Daily Dose (mg/kg/day) = \[(concentration on
carpet, mg/m^2^) \* (surface area of skin in contact with carpet,
m^2^/day) \* (transferable residue from carpet to skin)\] / (body
weight, kg).

c\. Dermal MOE = NOAEL (mg/kg/day) / Absorbed Potential Daily Dose
(mg/kg/day) \[Where short-term dermal NOAEL is 25 mg/kg/day\]. Target
MOE = 100.

***Child Incidental Ingestion Exposure to Treated Carpets***

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

In addition to dermal exposure, toddlers crawling on treated carpets
will also be exposed to TCMTB residues via incidental oral exposure
through hand-to-mouth activity. To calculate incidental ingestion
exposure to these chemicals due to hand-to-mouth transfer, the
methodologies established in the *Standard Operating Procedures (SOPs)
for Residential Exposure Assessments* (USEPA, 2000 and 2001) were used.
The assumptions used are similar to those used in calculating dermal
exposures for toddlers crawling on treated carpets.

Potential doses are calculated as follows:

*PDD = [C x SA x ET x D x SE x EF]{.underline}* **(Eq. 6)**

*BW*

Where:

> PDD = potential daily dose (mg/kg/day);
>
> C = concentration on carpet (mg/cm^2^);
>
> SA = surface area of the hands mouthed (cm^2^/event);
>
> ET = exposure time (hours/day);

D = fraction dislodgeable (unitless);

SE = saliva extraction efficiency (%);

> EF = exposure frequency (events/hr); and
>
> BW = body weight (kg).

And

*C = WF~ai~ x W x CF1 x CF2* **(Eq. 7)**

Where:

> C = concentration on carpet (mg/cm^2^);

WF~ai~ = weight fraction of a.i. in treated carpet (unitless);

> W = face weight of carpet (oz/yd^2^);

CF1 = unit conversion factor (28,349 mg/oz); and

> CF2 = unit conversion factor (0.00012 yd^2^/cm^2^).

**[Assumptions]{.underline}**

-   The product is applied at a rate of 0.006 a.i. weight fraction to
    the carpet.

-   The face weight of the carpet is assumed to weigh 35 oz/yd^2^ (the
    face weight only includes the carpet fibers, not the backing
    materials). The face weight is a conservative value as the child
    will most likely only be exposed to the top portion of the carpet
    fibers. (Doityourself.com, 2005)

```{=html}
<!-- -->
```
-   Toddlers (3 years old) were used to represent the 1 to 6 year old
    age group and are assumed to weigh 15 kg, the median for male and
    female toddlers (USEPA, 1997).

-   Based on HED's Residential SOP, it was assumed that the surface area
    used for each hand-to-mouth event is 20 cm^2^ (USEPA, 2000 and
    2001).

-   An exposure time of 8 hours was used, based on the total amount of
    time spent indoors for young children and subtracting the amount of
    time spent sleeping, eating, and bathing (USEPA, 2000 and 2001).

-   The saliva extraction efficiency was 50% (USEPA, 2000 and 2001).

-   The exposure frequency was assumed to be 20 events/ hour (USEPA,
    2000 and 2001).

**[Results]{.underline}**

The calculation of the oral doses and MOEs are shown in Table 4.4. The
oral MOE of 5 is below the target MOE of 100.

  ------------------ ---------- ----------- --------------- ------------- ------------- ------------- ----------
  **Table 4.4:                                                                                        
  Incidental Oral                                                                                     
  Post-application                                                                                    
  Exposures and MOEs                                                                                  
  for Toddlers                                                                                        
  Contacting Treated                                                                                  
  Carpets**                                                                                           

  C (Concentration   SA         ET          D (Fraction     SE (Saliva    EF (Exposure  PDD^b^        ST Oral
  of a.i. in         (Surface   (Exposure   Dislodgeable)   Extraction    Frequency)    (mg/kg/day)   MOE^c^
  carpet)^a^         Area       Time)                       Efficiency)   (events/hr)                 
  (mg/cm^2^)         exposed)   (hrs/day)                                                             
                     (cm^2^/                                                                          
                     event)                                                                           

  0.714              20.0       8.00        5%              50%           20.0          3.81          **4**
  ------------------ ---------- ----------- --------------- ------------- ------------- ------------- ----------

a\. Concentration on carpet (mg/cm^2^) = (fraction a.i. in treated
carpet) \* (face weight of carpet, oz/yd^2^) \* 28,349 mg/oz \* 0.00012
yd^2^/cm^2^

b\. Potential Daily Dose (mg/kg/day) = \[(concentration on carpet,
mg/cm^2^) \* (fraction dislodgeable) \* (exposure time, hrs/day) \*
(surface area of hand, cm^2^/event) \* (exposure frequency, events/hr)
\* (saliva extraction efficiency)\]/(body weight, kg)

c Oral MOE = NOAEL (mg/kg/day) / Potential Daily Dose(mg/kg/day) \[Where
short-term incidental oral NOAEL = 16 mg/kg/day\]. Target MOE = 100.

**4.2.2.2 Textiles**

***Dermal Exposure to Adults and Toddlers from Contacting Treated
Clothing***

There is the potential for dermal exposure to adults and children from
wearing clothing treated via factory impregnation of the chemical as a
preservative. A post-application assessment assuming no laundering was
conducted as a conservative measure (i.e., the effect on dislodgeable
residues over time during washing is not quantifiable). It should be
noted that it was assumed that not all articles of clothing are treated
with the TCMTB products or worn on a continuous basis; therefore, only
short-term duration exposures were assessed for the clothing scenarios.
It is believed that most treated textiles used in a residential setting
will result in exposures occurring over a short-term time duration (1 to
30 days) because residents are assumed to be exposed to treated textiles
with varying active ingredients, not exclusively TCMTB treated textiles.

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

Potential doses are calculated as follows:

*PDD = [W x WF~ai~ x CF x TF]{.underline}* **(Eq. 8)**

*BW*

Where:

> PDD = potential daily dose (mg/kg/day);
>
> W = weight of clothing work (g/day);
>
> WF~ai~ = percent active ingredient in clothing (%);
>
> TF = percent transfer;
>
> CF = conversion factor (1000 mg/µg); and
>
> BW = body weight (kg).

And

*W = (SW/SSA) \* BSA* **(Eq. 9)**

Where:

> W = weight of clothing worn (g/day);
>
> SW = weight of medium shirt (g);
>
> SSA = surface area of medium shirt (cm^2^); and
>
> BSA = surface area of body covered (cm^2^).

**[Assumptions]{.underline}**

-   The product is applied at a rate of 0.006 a.i. weight fraction to
    the clothing.

-   The median surface area of clothing contacting skin for a 3-year-old
    toddler is 5,670 cm^2^ (total body surface area minus the head)
    (USEPA, 1997). For adults, the median surface area is 16,900 cm^2^
    (total body surface area minus the head) (USEPA, 1997).

-   The clothing is assumed to be medium weight. For an adult, a cotton
    polo shirt has a mass of approximately 250 g, and the surface area
    covered by the shirt is assumed to be 0.659 m^2^. The density of the
    fabric is therefore 379 g/cm^2^. It is assumed that the type of
    fabric used in the polo shirt is used to cover the rest of the body
    for both adults and toddlers, minus the head. Therefore, the total
    amount of fabric worn per day is equal to the density of the fabric
    (379 g/cm^2^) times the surface area covered (5,670 cm^2^ for
    toddlers, 16,900 cm^2^ for adults), or 215 g/day for toddlers, and
    641 g/day for adults.

-   Potential doses were calculated using a conservative percent
    transfer of 100%, which assumes that all residues are transferable
    from clothing surfaces to the skin. In cases where the MOEs did not
    meet the Agency's target MOE, potential doses were also calculated
    using a less conservative percent transfer of 5%, which is based on
    the amount of residue assumed to be transferable from carpeted
    surfaces (USEPA, 2000 and 2001). In these cases, confirmatory data
    are needed to support the use of the lower transfer factor.

```{=html}
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```
-   Toddlers (3 years old) are assumed to weigh 15 kg. This is the mean
    of the median values for male and female toddlers (USEPA, 1997). For
    adults, a body weight of 70 kg has been assumed. (USEPA, 1997).

-   It is assumed that not all articles of clothing are treated with
    TCMTB products or worn on a continuous basis; therefore, only
    short-term duration exposures are expected.

**[Results]{.underline}**

The calculations of the short-term dermal doses and MOEs for adults and
toddlers wearing treated clothing are shown in Table 4.5. The dermal
MOEs for adults and toddlers are below the target MOE of 100.

  ----------------------------------------------------------------------------------
  **Table 4.5:                                                             
  Dermal                                                                   
  Post-application                                                         
  Exposures and MOEs                                                       
  for Toddlers and                                                         
  Adults Contacting                                                        
  Treated Clothing**                                                       
  ------------------ ---------- ----------- ------------- ---------------- ---------
  Exposure Scenario  *W*        *WF*        *TF* (percent *PDD*            ST Dermal
                     (weight of (fraction   transfer)     (mg/kg/day)^b^   MOE^c^
                     clothing   a.i. in                                    
                     worn per   clothing)                                  
                     day)^a^                                               
                     (g/day)                                               

  Toddler            215        0.006       100%          86.0             **\<1**

                                            5%            4.30             **6**

  Adult              641        0.006       100%          55.0             **\<1**

                                            5%            2.70             **9**
  ----------------------------------------------------------------------------------

a\. Weight of clothing worn (g/day) = (Density of shirt 379 g/cm^2^) \*
(surface area of body covered, cm^2^) \* 1 outfit/day

b\. Absorbed Potential Daily Dose (mg/kg/day) = \[(weight of clothing
worn, g/day) \* (weight fraction a.i. in treated clothing) \* (percent
transfer) \* (conversion factor, 1000 mg/g)\] / (body weight, kg).

c\. Dermal MOE = NOAEL (mg/kg/day) /Absorbed Potential Daily Dose
\[Where short-term dermal NOAEL = 25 mg/kg/day\]. Target MOE = 100.

***Incidental Oral Exposure to Toddlers Mouthing Treated Textiles
(Clothing/Blankets)***

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

There is the potential for incidental oral exposure to toddlers from
mouthing textiles treated with TCMTB.

Potential doses are calculated as follows:

*PDD = [C x SE x SA]{.underline}* **(Eq. 10)**

*BW*

Where:

> PDD = potential daily dose (mg/kg/day);
>
> C = concentration on clothing (mg/cm^2^);
>
> SE = saliva extraction efficiency (%);
>
> SA = surface area mouthed (cm^2^/day); and
>
> BW = body weight (kg).

And

*C = WF~ai~ x W x CF1 x CF2* **(Eq. 11)**

Where:

> C = concentration on clothing (mg/cm^2^);
>
> WF~ai~ = weight fraction of a.i. in clothing (unitless);
>
> W = weight of clothing (g/m^2^);
>
> CF1 = unit conversion factor (1,000 mg/g); and
>
> CF2 = unit conversion factor (0.0001 m^2^/cm^2^).

**[Assumptions]{.underline}**

-   The product is applied at a rate of 0.006 a.i. weight fraction to
    the carpet.

-   The clothing is assumed to be medium weight. For an adult, a cotton
    polo shirt has a mass of approximately 250 g, and the surface area
    covered by the shirt is assumed to be 0.659 m^2^. The density of the
    fabric is therefore 379 g/cm^2^.

-   The saliva extraction efficiency was 50% (USEPA, 2000 and 2001).

-   The surface area of textiles mouthed by toddlers is 100 cm^2^ (HERA,
    2005).

-   Toddlers (3 years old) are used to represent the 1 to 6 year old age
    group. For three-year olds, the median body weight is 15 kg (USEPA,
    1997).

**[Results]{.underline}**

Table 4.6 shows the calculation of the oral dose and oral MOE for
toddlers mouthing treated textiles. The MOE value is below the target
MOE of 100.

+-----------+-----------+--------+---------+-------------+-----------+
| **Table   |           |        |         |             |           |
| 4.6:      |           |        |         |             |           |
| I         |           |        |         |             |           |
| ncidental |           |        |         |             |           |
| Oral      |           |        |         |             |           |
| Exposures |           |        |         |             |           |
| and MOEs  |           |        |         |             |           |
| for       |           |        |         |             |           |
| Toddlers  |           |        |         |             |           |
| Wearing   |           |        |         |             |           |
| Treated   |           |        |         |             |           |
| Textiles  |           |        |         |             |           |
| (Cl       |           |        |         |             |           |
| othing/Bl |           |        |         |             |           |
| ankets)** |           |        |         |             |           |
+-----------+-----------+--------+---------+-------------+-----------+
| Weight of | Conc      | S      | Saliva  | Potential   | I         |
| clothing  | entration | urface | ext     | daily dose  | ncidental |
| (g/m^2^)  | on        | area   | raction | (mg         | Oral      |
|           | cl        | m      | eff     | a           | MOE^c^    |
|           | othing^a^ | outhed | iciency | .i./kg/day) |           |
|           | (         | (cm^2  |         |             |           |
|           | mg/cm^2^) | ^/day) |         |             |           |
+-----------+-----------+--------+---------+-------------+-----------+
| 379       | 0.2274    | 100    | 50%     | 0.758       | **21**    |
+-----------+-----------+--------+---------+-------------+-----------+

a\. Concentration on clothing (mg/cm^2^) = (Weight fraction a.i. in
clothing, 0.006) \* (weight of clothing, g/cm^2^) \* (1,000 mg/g) \*
(0.0001 m^2^/cm^2^)

b\. Potential Daily Dose (mg/kg/day) = (concentration on clothing,
mg/cm^2^) \* (surface area mouthed, cm^2^/day) \* (saliva extraction
efficiency) / (body weight, kg).

c Oral MOE = NOAEL (mg/kg/day) / Potential Daily Dose \[Where short-term
incidental oral NOAEL = 16 mg/kg/day\]. Target MOE = 100.

**4.2.3 Data Limitations/Uncertainties**

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

-   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 B for summaries of these data sources). Most of the CMA
    data are of poor quality, therefore, AD requests that confirmatory
    monitoring data be generated to support the values used in these
    assessments.

-   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.

[]{.mark}

**5.0 OCCUPATIONAL EXPOSURE ASSESSMENT**

The exposure scenarios assessed in this document for the representative
uses selected by AD are shown in Table 5.1. The table also shows the
maximum application rate associated with the representative use and the
appropriate EPA Registration number for the product label. Appendix A
(Master List of TCMTB Products) presents a summary of all exposure
scenarios that may occur in occupational settings based on examination
of product labels*.*

[]{.mark}

Potential occupational handler exposure can occur in various use sites,
which include: commercial/institutional premises, and industrial
processes and water systems. Additionally, occupational exposure can
occur during the preservation of wood. 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 (Section 5.3).

[]{.mark}

+------------+---+----------+---+--------+---+---------+---+--------------------------+
| **Table    |   |          |   |        |   |         |   |                          |
| 5.1.       |   |          |   |        |   |         |   |                          |
| Repr       |   |          |   |        |   |         |   |                          |
| esentative |   |          |   |        |   |         |   |                          |
| Exposure   |   |          |   |        |   |         |   |                          |
| Scenarios  |   |          |   |        |   |         |   |                          |
| Associated |   |          |   |        |   |         |   |                          |
| with       |   |          |   |        |   |         |   |                          |
| Oc         |   |          |   |        |   |         |   |                          |
| cupational |   |          |   |        |   |         |   |                          |
| Exposures  |   |          |   |        |   |         |   |                          |
| to TCMTB** |   |          |   |        |   |         |   |                          |
+============+===+==========+===+========+===+=========+===+==========================+
| Repr       | M |          | E |        | R |         | A |                          |
| esentative | e |          | x |        | e |         | p |                          |
| Use        | t |          | p |        | g |         | p |                          |
|            | h |          | o |        | i |         | l |                          |
|            | o |          | s |        | s |         | i |                          |
|            | d |          | u |        | t |         | c |                          |
|            | o |          | r |        | r |         | a |                          |
|            | f |          | e |        | a |         | t |                          |
|            | A |          | S |        | t |         | i |                          |
|            | p |          | c |        | i |         | o |                          |
|            | p |          | e |        | o |         | n |                          |
|            | l |          | n |        | n |         | R |                          |
|            | i |          | a |        | \ |         | a |                          |
|            | c |          | r |        | # |         | t |                          |
|            | a |          | i |        |   |         | e |                          |
|            | t |          | o |        |   |         |   |                          |
|            | i |          |   |        |   |         |   |                          |
|            | o |          |   |        |   |         |   |                          |
|            | n |          |   |        |   |         |   |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| **Comm     |   |          |   |        |   |         |   |                          |
| ercial/Ins |   |          |   |        |   |         |   |                          |
| titutional |   |          |   |        |   |         |   |                          |
| Premises   |   |          |   |        |   |         |   |                          |
| (III)**    |   |          |   |        |   |         |   |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| Paint      | - |          | S |        | 1 |         | 1 |                          |
| A          |   |          | T |        | 4 |         | . |                          |
| pplication |   |          | / |        | 4 |         | 5 |                          |
|            |   |          | I |        | 8 |         | % |                          |
|            | A |          | T |        | - |         | a |                          |
|            | i |          | H |        | 5 |         | . |                          |
|            | r |          | a |        | 5 |         | i |                          |
|            | l |          | n |        |   |         | . |                          |
|            | e |          | d |        |   |         | b |                          |
|            | s |          | l |        |   |         | y |                          |
|            | s |          | e |        |   |         | w |                          |
|            |   |          | r |        |   |         | e |                          |
|            |   |          | : |        |   |         | i |                          |
|            |   |          | D |        |   |         | g |                          |
|            |   |          | e |        |   |         | h |                          |
|            | S |          | r |        |   |         | t |                          |
|            | p |          | m |        |   |         |   |                          |
|            | r |          | a |        |   |         | \ |                          |
|            | a |          | l |        |   |         | [ |                          |
|            | y |          | a |        |   |         | ( |                          |
|            | e |          | n |        |   |         | 5 |                          |
|            | r |          | d |        |   |         | % |                          |
|            |   |          | I |        |   |         | P |                          |
|            | - |          | n |        |   |         | r |                          |
|            |   |          | h |        |   |         | o |                          |
|            |   |          | a |        |   |         | d |                          |
|            |   |          | l |        |   |         | u |                          |
|            | P |          | a |        |   |         | c |                          |
|            | a |          | t |        |   |         | t |                          |
|            | i |          | i |        |   |         | ) |                          |
|            | n |          | o |        |   |         | x |                          |
|            | t |          | n |        |   |         | ( |                          |
|            | b |          |   |        |   |         | 3 |                          |
|            | r |          |   |        |   |         | 0 |                          |
|            | u |          |   |        |   |         | % |                          |
|            | s |          |   |        |   |         | a |                          |
|            | h |          |   |        |   |         | i |                          |
|            |   |          |   |        |   |         | ) |                          |
|            |   |          |   |        |   |         | \ |                          |
|            |   |          |   |        |   |         | ] |                          |
|            |   |          |   |        |   |         |   |                          |
|            | / |          |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            | R |          |   |        |   |         |   |                          |
|            | o |          |   |        |   |         |   |                          |
|            | l |          |   |        |   |         |   |                          |
|            | l |          |   |        |   |         |   |                          |
|            | e |          |   |        |   |         |   |                          |
|            | r |          |   |        |   |         |   |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| **Material |   |          |   |        |   |         |   |                          |
| Pr         |   |          |   |        |   |         |   |                          |
| eservation |   |          |   |        |   |         |   |                          |
| (VII)**    |   |          |   |        |   |         |   |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| Paint      | - |          | S |        | 1 |         | 1 |                          |
| Pr         |   |          | T |        | 4 |         | . |                          |
| eservation |   |          | / |        | 4 |         | 5 |                          |
|            |   |          | I |        | 8 |         | % |                          |
|            | L |          | T |        | - |         | a |                          |
|            | i |          | H |        | 9 |         | . |                          |
|            | q |          | a |        | 9 |         | i |                          |
|            | u |          | n |        |   |         | . |                          |
|            | i |          | d |        |   |         | b |                          |
|            | d |          | l |        |   |         | y |                          |
|            |   |          | e |        |   |         | w |                          |
|            |   |          | r |        |   |         | e |                          |
|            |   |          | : |        |   |         | i |                          |
|            |   |          | D |        |   |         | g |                          |
|            | P |          | e |        |   |         | h |                          |
|            | o |          | r |        |   |         | t |                          |
|            | u |          | m |        |   |         |   |                          |
|            | r |          | a |        |   |         | \ |                          |
|            |   |          | l |        |   |         | [ |                          |
|            | - |          | a |        |   |         | ( |                          |
|            |   |          | n |        |   |         | 1 |                          |
|            |   |          | d |        |   |         | 5 |                          |
|            |   |          | i |        |   |         | % |                          |
|            | L |          | n |        |   |         | P |                          |
|            | i |          | h |        |   |         | r |                          |
|            | q |          | a |        |   |         | o |                          |
|            | u |          | l |        |   |         | d |                          |
|            | i |          | a |        |   |         | u |                          |
|            | d |          | t |        |   |         | c |                          |
|            |   |          | i |        |   |         | t |                          |
|            |   |          | o |        |   |         | ) |                          |
|            |   |          | n |        |   |         | x |                          |
|            |   |          |   |        |   |         | ( |                          |
|            | P |          |   |        |   |         | 1 |                          |
|            | u |          |   |        |   |         | 0 |                          |
|            | m |          |   |        |   |         | % |                          |
|            | p |          |   |        |   |         | a |                          |
|            |   |          |   |        |   |         | i |                          |
|            |   |          |   |        |   |         | ) |                          |
|            |   |          |   |        |   |         | \ |                          |
|            |   |          |   |        |   |         | ] |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| Textile    | - |          | S |        | 1 |         | 0 |                          |
| Pr         |   |          | T |        | 4 |         | . |                          |
| eservation |   |          | / |        | 4 |         | 6 |                          |
|            |   |          | I |        | 8 |         | % |                          |
|            | L |          | T |        | - |         | a |                          |
|            | i |          | H |        | 5 |         | . |                          |
|            | q |          | a |        | 5 |         | i |                          |
|            | u |          | n |        |   |         | . |                          |
|            | i |          | d |        |   |         | b |                          |
|            | d |          | l |        |   |         | y |                          |
|            |   |          | e |        |   |         | w |                          |
|            |   |          | r |        |   |         | e |                          |
|            |   |          | : |        |   |         | i |                          |
|            |   |          | D |        |   |         | g |                          |
|            | p |          | e |        |   |         | h |                          |
|            | o |          | r |        |   |         | t |                          |
|            | u |          | m |        |   |         |   |                          |
|            | r |          | a |        |   |         | \ |                          |
|            |   |          | l |        |   |         | [ |                          |
|            | - |          | a |        |   |         | ( |                          |
|            |   |          | n |        |   |         | 2 |                          |
|            |   |          | d |        |   |         | % |                          |
|            |   |          | i |        |   |         | p |                          |
|            | L |          | n |        |   |         | r |                          |
|            | i |          | h |        |   |         | o |                          |
|            | q |          | a |        |   |         | d |                          |
|            | u |          | l |        |   |         | u |                          |
|            | i |          | a |        |   |         | c |                          |
|            | d |          | t |        |   |         | t |                          |
|            |   |          | i |        |   |         | ) |                          |
|            |   |          | o |        |   |         | x |                          |
|            |   |          | n |        |   |         | ( |                          |
|            |   |          |   |        |   |         | 3 |                          |
|            | p |          |   |        |   |         | 0 |                          |
|            | u |          |   |        |   |         | % |                          |
|            | m |          |   |        |   |         | a |                          |
|            | p |          |   |        |   |         | i |                          |
|            |   |          |   |        |   |         | ) |                          |
|            |   |          |   |        |   |         | \ |                          |
|            |   |          |   |        |   |         | ] |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| Metal      | - |          | S |        | 1 |         | 0 |                          |
| Working    |   |          | T |        | 4 |         | . |                          |
| Fluid      |   |          | / |        | 4 |         | 1 |                          |
| pr         |   |          | I |        | 8 |         | 2 |                          |
| eservation | L |          | T |        | - |         | 5 |                          |
|            | i |          | / |        | 2 |         | % |                          |
|            | q |          | L |        | 6 |         | a |                          |
|            | u |          | T |        | 5 |         | . |                          |
|            | i |          | H |        |   |         | i |                          |
|            | d |          | a |        |   |         | . |                          |
|            |   |          | n |        |   |         | b |                          |
|            |   |          | d |        |   |         | y |                          |
|            |   |          | l |        |   |         | w |                          |
|            |   |          | e |        |   |         | e |                          |
|            | p |          | r |        |   |         | i |                          |
|            | o |          | : |        |   |         | g |                          |
|            | u |          | D |        |   |         | h |                          |
|            | r |          | e |        |   |         | t |                          |
|            |   |          | r |        |   |         |   |                          |
|            | - |          | m |        |   |         | \ |                          |
|            |   |          | a |        |   |         | [ |                          |
|            |   |          | l |        |   |         | ( |                          |
|            |   |          | a |        |   |         | 1 |                          |
|            | L |          | n |        |   |         | 2 |                          |
|            | i |          | d |        |   |         | 5 |                          |
|            | q |          | i |        |   |         | 0 |                          |
|            | u |          | n |        |   |         | p |                          |
|            | i |          | h |        |   |         | p |                          |
|            | d |          | a |        |   |         | m |                          |
|            |   |          | l |        |   |         | a |                          |
|            |   |          | a |        |   |         | . |                          |
|            |   |          | t |        |   |         | i |                          |
|            |   |          | i |        |   |         | . |                          |
|            | p |          | o |        |   |         | ) |                          |
|            | u |          | n |        |   |         | / |                          |
|            | m |          |   |        |   |         | 1 |                          |
|            | p |          | S |        |   |         | , |                          |
|            |   |          | T |        |   |         | 0 |                          |
|            |   |          | a |        |   |         | 0 |                          |
|            |   |          | n |        |   |         | 0 |                          |
|            |   |          | d |        |   |         | , |                          |
|            |   |          | I |        |   |         | 0 |                          |
|            |   |          | T |        |   |         | 0 |                          |
|            |   |          | / |        |   |         | 0 |                          |
|            |   |          | L |        |   |         | \ |                          |
|            |   |          | T |        |   |         | ] |                          |
|            |   |          | M |        |   |         |   |                          |
|            |   |          | a |        |   |         |   |                          |
|            |   |          | c |        |   |         |   |                          |
|            |   |          | h |        |   |         |   |                          |
|            |   |          | i |        |   |         |   |                          |
|            |   |          | n |        |   |         |   |                          |
|            |   |          | i |        |   |         |   |                          |
|            |   |          | s |        |   |         |   |                          |
|            |   |          | t |        |   |         |   |                          |
|            |   |          | : |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   |          | d |        |   |         |   |                          |
|            |   |          | e |        |   |         |   |                          |
|            |   |          | r |        |   |         |   |                          |
|            |   |          | m |        |   |         |   |                          |
|            |   |          | a |        |   |         |   |                          |
|            |   |          | l |        |   |         |   |                          |
|            |   |          | a |        |   |         |   |                          |
|            |   |          | n |        |   |         |   |                          |
|            |   |          | d |        |   |         |   |                          |
|            |   |          | i |        |   |         |   |                          |
|            |   |          | n |        |   |         |   |                          |
|            |   |          | h |        |   |         |   |                          |
|            |   |          | a |        |   |         |   |                          |
|            |   |          | l |        |   |         |   |                          |
|            |   |          | a |        |   |         |   |                          |
|            |   |          | t |        |   |         |   |                          |
|            |   |          | i |        |   |         |   |                          |
|            |   |          | o |        |   |         |   |                          |
|            |   |          | n |        |   |         |   |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| **         |   |          |   |        |   |         |   |                          |
| Industrial |   |          |   |        |   |         |   |                          |
| processes  |   |          |   |        |   |         |   |                          |
| and water  |   |          |   |        |   |         |   |                          |
| systems    |   |          |   |        |   |         |   |                          |
| (Use       |   |          |   |        |   |         |   |                          |
| Category   |   |          |   |        |   |         |   |                          |
| VIII)**    |   |          |   |        |   |         |   |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| Drilling   | - |          | S |        | 1 |         | 0 |                          |
| Fluid^a^   |   |          | T |        | 4 |         | . |                          |
|            |   |          | / |        | 4 |         | 0 |                          |
|            |   |          | I |        | 8 |         | 7 |                          |
|            | L |          | T |        | - |         | 5 |                          |
|            | i |          | H |        | 9 |         | % |                          |
|            | q |          | a |        | 9 |         | a |                          |
|            | u |          | n |        |   |         | . |                          |
|            | i |          | d |        |   |         | i |                          |
|            | d |          | l |        |   |         | . |                          |
|            |   |          | e |        |   |         | b |                          |
|            |   |          | r |        |   |         | y |                          |
|            |   |          | : |        |   |         | w |                          |
|            |   |          |   |        |   |         | e |                          |
|            | P |          | D |        |   |         | i |                          |
|            | o |          | e |        |   |         | g |                          |
|            | u |          | r |        |   |         | h |                          |
|            | r |          | m |        |   |         | t |                          |
|            |   |          | a |        |   |         |   |                          |
|            |   |          | l |        |   |         | \ |                          |
|            |   |          | a |        |   |         | [ |                          |
|            |   |          | n |        |   |         | ( |                          |
|            |   |          | d |        |   |         | 0 |                          |
|            |   |          | I |        |   |         | . |                          |
|            |   |          | n |        |   |         | 7 |                          |
|            |   |          | h |        |   |         | 5 |                          |
|            |   |          | a |        |   |         | % |                          |
|            |   |          | l |        |   |         | P |                          |
|            |   |          | a |        |   |         | r |                          |
|            |   |          | t |        |   |         | o |                          |
|            |   |          | i |        |   |         | d |                          |
|            |   |          | o |        |   |         | u |                          |
|            |   |          | n |        |   |         | c |                          |
|            |   |          |   |        |   |         | t |                          |
|            |   |          |   |        |   |         | ) |                          |
|            |   |          |   |        |   |         | x |                          |
|            |   |          |   |        |   |         | ( |                          |
|            |   |          |   |        |   |         | 1 |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | % |                          |
|            |   |          |   |        |   |         | a |                          |
|            |   |          |   |        |   |         | i |                          |
|            |   |          |   |        |   |         | ) |                          |
|            |   |          |   |        |   |         | \ |                          |
|            |   |          |   |        |   |         | ] |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| Pulp and   | - |          | S |        | 1 |         | 0 |                          |
| Paper      |   |          | T |        | 4 |         | . |                          |
|            |   |          | / |        | 4 |         | 0 |                          |
|            |   |          | I |        | 8 |         | 7 |                          |
|            | M |          | T |        | - |         | 5 |                          |
|            | e |          | H |        | 3 |         | % |                          |
|            | t |          | a |        | 8 |         | a |                          |
|            | e |          | n |        | 6 |         | . |                          |
|            | r |          | d |        |   |         | i |                          |
|            | e |          | l |        |   |         | . |                          |
|            | d |          | e |        |   |         | b |                          |
|            |   |          | r |        |   |         | y |                          |
|            |   |          | : |        |   |         | w |                          |
|            |   |          |   |        |   |         | e |                          |
|            |   |          | D |        |   |         | i |                          |
|            | p |          | e |        |   |         | g |                          |
|            | u |          | r |        |   |         | h |                          |
|            | m |          | m |        |   |         | t |                          |
|            | p |          | a |        |   |         |   |                          |
|            |   |          | l |        |   |         | \ |                          |
|            |   |          | a |        |   |         | [ |                          |
|            |   |          | n |        |   |         | ( |                          |
|            |   |          | d |        |   |         | 3 |                          |
|            |   |          | I |        |   |         | 0 |                          |
|            |   |          | n |        |   |         | l |                          |
|            |   |          | h |        |   |         | b |                          |
|            |   |          | a |        |   |         | s |                          |
|            |   |          | l |        |   |         | p |                          |
|            |   |          | a |        |   |         | r |                          |
|            |   |          | t |        |   |         | o |                          |
|            |   |          | i |        |   |         | d |                          |
|            |   |          | o |        |   |         | / |                          |
|            |   |          | n |        |   |         | t |                          |
|            |   |          |   |        |   |         | o |                          |
|            |   |          |   |        |   |         | n |                          |
|            |   |          |   |        |   |         | p |                          |
|            |   |          |   |        |   |         | a |                          |
|            |   |          |   |        |   |         | p |                          |
|            |   |          |   |        |   |         | e |                          |
|            |   |          |   |        |   |         | r |                          |
|            |   |          |   |        |   |         | ) |                          |
|            |   |          |   |        |   |         | x |                          |
|            |   |          |   |        |   |         | ( |                          |
|            |   |          |   |        |   |         | 5 |                          |
|            |   |          |   |        |   |         | % |                          |
|            |   |          |   |        |   |         | a |                          |
|            |   |          |   |        |   |         | i |                          |
|            |   |          |   |        |   |         | ) |                          |
|            |   |          |   |        |   |         | / |                          |
|            |   |          |   |        |   |         | 2 |                          |
|            |   |          |   |        |   |         | , |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | l |                          |
|            |   |          |   |        |   |         | b |                          |
|            |   |          |   |        |   |         | / |                          |
|            |   |          |   |        |   |         | t |                          |
|            |   |          |   |        |   |         | o |                          |
|            |   |          |   |        |   |         | n |                          |
|            |   |          |   |        |   |         | \ |                          |
|            |   |          |   |        |   |         | ] |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| Small      | - |          | S |        | 1 |         | 9 |                          |
| process    |   |          | T |        | 4 |         | . |                          |
| water      |   |          | / |        | 4 |         | 0 |                          |
| systems    |   |          | I |        | 8 |         | 0 |                          |
|            | L |          | T |        | - |         | x |                          |
|            | i |          | H |        | 5 |         | 1 |                          |
|            | q |          | a |        | 5 |         | 0 |                          |
|            | u |          | n |        | ( |         | ^ |                          |
|            | i |          | d |        | f |         | - |                          |
|            | d |          | l |        | o |         | 4 |                          |
|            |   |          | e |        | r |         | ^ |                          |
|            |   |          | r |        | u |         | % |                          |
|            |   |          | : |        | s |         | a |                          |
|            |   |          |   |        | e |         | . |                          |
|            | P |          | D |        | i |         | i |                          |
|            | o |          | e |        | n |         | . |                          |
|            | u |          | r |        | w |         | b |                          |
|            | r |          | m |        | a |         | y |                          |
|            |   |          | a |        | s |         | w |                          |
|            | - |          | l |        | t |         | e |                          |
|            |   |          | a |        | e |         | i |                          |
|            |   |          | n |        | w |         | g |                          |
|            |   |          | d |        | a |         | h |                          |
|            | M |          | I |        | t |         | t |                          |
|            | e |          | n |        | e |         |   |                          |
|            | t |          | h |        | r |         | \ |                          |
|            | e |          | a |        | s |         | [ |                          |
|            | r |          | l |        | y |         | ( |                          |
|            | e |          | a |        | s |         | 3 |                          |
|            | d |          | t |        | t |         | 0 |                          |
|            |   |          | i |        | e |         | p |                          |
|            |   |          | o |        | m |         | p |                          |
|            |   |          | n |        | s |         | m |                          |
|            |   |          |   |        | ) |         | P |                          |
|            | P |          |   |        |   |         | r |                          |
|            | u |          |   |        |   |         | o |                          |
|            | m |          |   |        |   |         | d |                          |
|            | p |          |   |        |   |         | u |                          |
|            |   |          |   |        |   |         | c |                          |
|            |   |          |   |        |   |         | t |                          |
|            |   |          |   |        |   |         | ) |                          |
|            |   |          |   |        |   |         | x |                          |
|            |   |          |   |        |   |         | ( |                          |
|            |   |          |   |        |   |         | 3 |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | % |                          |
|            |   |          |   |        |   |         | a |                          |
|            |   |          |   |        |   |         | i |                          |
|            |   |          |   |        |   |         | ) |                          |
|            |   |          |   |        |   |         | / |                          |
|            |   |          |   |        |   |         | 1 |                          |
|            |   |          |   |        |   |         | , |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | , |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | 0 |                          |
|            |   |          |   |        |   |         | \ |                          |
|            |   |          |   |        |   |         | ] |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| **Wood     |   |          |   |        |   |         |   |                          |
| Pr         |   |          |   |        |   |         |   |                          |
| eservation |   |          |   |        |   |         |   |                          |
| (Use       |   |          |   |        |   |         |   |                          |
| Category   |   |          |   |        |   |         |   |                          |
| X)**       |   |          |   |        |   |         |   |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+
| No         |   | [Handler |   | ST     |   | 1448-55 |   | 0.3% a.i. by weight      |
| n-pressure |   | Worker   |   | /IT/LT |   |         |   |                          |
| treatment  |   | Functi   |   | Ha     |   |         |   | \[(1% product) x (30%    |
| of wood    |   | ons]{.un |   | ndler: |   |         |   | ai)\] []{.mark}          |
| and wood   |   | derline} |   | inha   |   |         |   |                          |
| products   |   |          |   | lation |   |         |   | []{.mark}                |
| in wood    |   | -        |   |        |   |         |   |                          |
| treatment  |   |  Diptank |   | ST     |   |         |   | []{.mark}                |
| facilities |   |     O    |   | /IT/LT |   |         |   |                          |
|            |   | perators |   | Post-  |   |         |   |                          |
|            |   |          |   | applic |   |         |   |                          |
|            |   | -        |   | ation: |   |         |   |                          |
|            |   |    Blend |   | dermal |   |         |   |                          |
|            |   | er/spray |   | and    |   |         |   |                          |
|            |   |     o    |   | inha   |   |         |   |                          |
|            |   | perators |   | lation |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   | -        |   |        |   |         |   |                          |
|            |   | Chemical |   |        |   |         |   |                          |
|            |   |     o    |   |        |   |         |   |                          |
|            |   | perators |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   | [Post-   |   |        |   |         |   |                          |
|            |   | App      |   |        |   |         |   |                          |
|            |   | lication |   |        |   |         |   |                          |
|            |   | Worker   |   |        |   |         |   |                          |
|            |   | Functi   |   |        |   |         |   |                          |
|            |   | ons]{.un |   |        |   |         |   |                          |
|            |   | derline} |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   | -        |   |        |   |         |   |                          |
|            |   |  Graders |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   | -   Trim |   |        |   |         |   |                          |
|            |   |     saw  |   |        |   |         |   |                          |
|            |   |     o    |   |        |   |         |   |                          |
|            |   | perators |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   | -        |   |        |   |         |   |                          |
|            |   | Clean-up |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   |    crews |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   | -   Cons |   |        |   |         |   |                          |
|            |   | truction |   |        |   |         |   |                          |
|            |   |          |   |        |   |         |   |                          |
|            |   |  Workers |   |        |   |         |   |                          |
+------------+---+----------+---+--------+---+---------+---+--------------------------+

^a^ There are no representative unit exposures data for chemical
metering (i.e. liquid pump) into secondary recovery oil operations.
Since the volume of water being treated in secondary recovery oil
operations is so large, the available CMA data can not be reliably
extrapolated. This is because CMA data are based on activities that
handle much lower volumes and possibly different techniques.

[]{.mark}

[]{.mark}

**5.1 Occupational Handler Exposures**

The occupational handler scenarios included in Table 5.1 were assessed
to determine inhalation exposures. The general assumptions and equations
that were used to calculate occupational handler inhalation 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):** Inhalation unit exposure values were
taken from the proprietary Chemical Manufacturers Association (CMA)
antimicrobial exposure study (USEPA, 1999b: DP Barcode D247642) or from
the Pesticide Handler Exposure Database (USEPA, 1998).

[]{.mark}

-   For the ***liquid pour*** scenarios, the unit exposure depends on
    the material being treated. The following CMA unit exposures were
    available and used for the following scenarios:

```{=html}
<!-- -->
```
-   *Paint preservation, textile preservation, drilling fluids:* CMA
    preservative data (gloved). The dermal UE is 0.135 mg/lb a.i. and
    the inhalation unit exposure is 0.00346 mg/lb a.i. and is based on 2
    replicates. Although this unit exposure is based on minimal
    replicates, the exposure value is similar to the one found in PHED
    for a similar scenarios. 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).

-   *Metal working 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 metal working fluid, the baseline dermal exposures were
    evaluated using the cooling tower CMA data (50.3 mg/lb ai).

-   *Small process water systems:* CMA cooling tower data (gloved and
    ungloved). The dermal and inhalation unit exposures are 10.1 and
    0.450 mg/lb a.i., respectively, based on 5 replicates. The ungloved
    dermal unit exposure value is 50.3 mg/lb ai.

```{=html}
<!-- -->
```
-   For the ***liquid/metering pump*** scenarios, the unit exposure
    depends on the material being treated. The following CMA unit
    exposures were available and used for the following scenarios:

```{=html}
<!-- -->
```
-   *Metal working 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 metal working fluid, the baseline dermal exposures were
    evaluated using the cooling tower CMA data (0.454 mg/lb ai).

-   *Pulp and paper, cooling water systems*: CMA pulp and paper gloved
    data were used. The dermal and inhalation unit exposures are
    0.000454 mg/lb ai and 0.000265 mg/lb a.i., respectively. These
    values are based on 7 replicates where the test subjects were
    wearing a single layer of clothing and chemical resistant gloves.
    These unit exposures were used for the once through cooling water
    system because no representative data exists for the volume of water
    treated in power plant facilities. Since no baseline dermal
    (ungloved) unit exposure data are available for metal working fluid,
    the baseline dermal exposures were evaluated using the cooling tower
    CMA data (0.454 mg/lb ai).

-   *Paint preservation and textile preservation*: 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).

-   *Small process water systems:* CMA cooling tower data. The dermal UE
    is 0.086 and the inhalation UE is 0.00432 mg/lb a.i., based on 4
    replicates. 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).

```{=html}
<!-- -->
```
-   For ***airless sprayer*** scenarios, the occupational PHED dermal
    and inhalation unit exposure values for airless sprayer application
    (PHED scenario 23) were used. The dermal and inhalation exposure
    values are 38 mg/lb a.i. and 0.83 mg/lb a.i., respectively.

-   For the ***brush/roller*** scenario, the occupational PHED dermal
    and inhalation unit exposure values for paintbrush applications were
    used (single layer of clothing). The dermal and inhalation exposure
    values are 79 mg/lb a.i. and 0.28 mg/lb a.i., respectively.

[]{.mark}

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

-   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.

-   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.

```{=html}
<!-- -->
```
-   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:

```{=html}
<!-- -->
```
-   *Paint*: 2,000 lbs (approximately 200 gallons, weight based on a
    density 10 lb a.i./gal).

-   *Textiles*: 10,000 lbs

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

-   *Drilling fluids:* The following use information was used to
    estimate the amount of ai handled per day during oil-well
    activities. Biocide is typically added directly to drilling rig mud
    tanks via open pouring. Over a 3 to 6 week period, while a 13,000 ft
    well is being drilled, 1 to 2 drums (1 drum = 42 gallons) of biocide
    may be used if microbiological problems are encountered. Therefore,
    the short-term exposure assessment used 5.6 gallons for the amount
    of biocide handled per day by the drilling rig worker \[i.e., (2
    drums x 42 gal/drum) / (5 days/week x 3 weeks) = 5.6 gal/day\].
    Since Product #1448-99 has a density of 8.2 lbs/gal, this
    corresponds to 45.9 lb/day. The intermediate-term exposure
    assessment used 2.8 gallons (22.9 lb/day) for the amount of biocide
    handled per day by the drilling rig worker \[i.e., (2 drums x 42
    gal/drum) / (5 days/week x 6 weeks) = 2.8 gal/day\]. Although crew
    changes may occur in drilling rig operations, typically a designated
    customer representative is responsible for the biocide feeding.
    Therefore, one person would be involved with the biocide application
    activities on a daily basis.

-   *Small process water systems:* Workers in small systems are assumed
    to manually pour 5 to 10 gallons of biocide into the system, but
    larger systems would utilize chemical pumps in order to save time
    and labor expense. Therefore, AD assumed that workers handle 10
    gallons of biocide per day when making open pour applications (or 90
    lb/day, assuming a density of 9 lb/gal for the product).

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

```{=html}
<!-- -->
```
-   *Paint*: 10,000 lbs (approximately 1,000 gallons, weight based on a
    density of 10 lb a.i./gal)

-   *Textiles*: 10,000 lbs

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

-   *Pulp and Paper*: 500 tons of paper produced/day (1,000,000 lbs/day)

-   *Small process water systems:* AD has assumed that 20,000 gallons of
    water are treated daily when chemical pump applications are made (or
    180,000 lb/day, assuming the product has a density of 9 lb/gal).

**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.

[]{.mark}

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

The resulting inhalation exposures and MOEs for the representative
occupational handler scenarios are presented in Tables 5.2 and 5.3. The
calculated MOEs as well as total MOEs were above the corresponding
target MOEs for all scenarios, except those listed below.

**Dermal MOES:**

-   Paint Application -- Airless Sprayer: ST/IT Dermal MOE = **6**
    (ungloved) and **17** (gloved).

-   Paint Application -- Paintbrush: ST/IT Dermal MOE = **30**
    (ungloved) and **97** (gloved)

-   Paint Preservation -- Liquid Pour: ST/IT Dermal MOE = **1**
    (ungloved)

-   Paint Preservation -- Liquid Pump: ST/IT Dermal MOE = **26**
    (ungloved)

-   Textile Preservation -- Liquid Pour: ST/IT Dermal MOE = **\<1**
    (ungloved)

-   Textile Preservation -- Liquid Pump: ST/IT Dermal MOE = **64**
    (ungloved)

-   Metal working fluid Preservation -- Liquid Pour: ST/IT Dermal MOE =
    **11** (ungloved)

-   Pulp and Paper -- Liquid Pump: ST/IT Dermal MOE = **5** (ungloved)

[]{.mark}

**Total MOES:**

-   Paint Application -- Airless Sprayer: MOE =**16**

-   Paint Application -- Paintbrush: MOE = **95**

> []{.mark}

<table style="width:100%;">
<colgroup>
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 6%" />
<col style="width: 6%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="14"><strong>Table 5.2 Short-and Intermediate-Term Risks
Associated with Occupational Handlers</strong></th>
</tr>
<tr class="odd">
<th rowspan="2">Exposure Scenario</th>
<th rowspan="2">Method of Application</th>
<th colspan="3">Unit Exposure (mg/lb a.i.)</th>
<th rowspan="2">Application Rate (% a.i. by weight)</th>
<th rowspan="2">Quantity Handled/ Treated per day</th>
<th colspan="3">Absorbed Daily Dose (mg/kg/day)<sup>c</sup></th>
<th colspan="4">MOE<sup>d</sup></th>
</tr>
<tr class="header">
<th>Baseline Dermal<sup>a</sup></th>
<th>PPE- Gloves Dermal<sup>b</sup></th>
<th>Inhalation</th>
<th>Baseline Dermal<sup>a</sup></th>
<th>PPE- Gloves Dermal<sup>b</sup></th>
<th>Inhalation</th>
<th>Baseline Dermal (Target MOE = 100)<sup>a</sup></th>
<th>PPE-Glove Dermal (Target MOE = 100)<sup>b</sup></th>
<th><p>Inhalation</p>
<p>(Target MOE = 100)</p></th>
<th><p>Total MOE</p>
<p>(Target MOE=100)</p></th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td rowspan="2">Paint Application</td>
<td>Airless Sprayer</td>
<td>38.0</td>
<td>14.0</td>
<td>0.830</td>
<td>0.015 a.i. weight fraction</td>
<td>500 lb/day</td>
<td>4.07</td>
<td>1.50</td>
<td>0.0889</td>
<td><strong>6</strong></td>
<td><strong>17</strong></td>
<td>180</td>
<td><strong>16</strong></td>
</tr>
<tr class="even">
<td>Paintbrush</td>
<td>79.0</td>
<td>24.0</td>
<td>0.280</td>
<td>0.015 a.i. weight fraction</td>
<td>50 lb/day</td>
<td>0.846</td>
<td>0.257</td>
<td>0.00300</td>
<td><strong>30</strong></td>
<td><strong>97</strong></td>
<td>5,300</td>
<td><strong>95</strong></td>
</tr>
<tr class="odd">
<td rowspan="2">Paint Preservation</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.135</td>
<td>0.00346</td>
<td>0.015 a.i. weight fraction</td>
<td>2,000 lb/day</td>
<td>21.6</td>
<td>0.0579</td>
<td>0.00149</td>
<td><strong>1</strong></td>
<td>430</td>
<td>11,000</td>
<td>414</td>
</tr>
<tr class="even">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.00629</td>
<td>4.03x10<sup>-4</sup></td>
<td>0.015 a.i. weight fraction</td>
<td>10,000 lb/day</td>
<td>0.973</td>
<td>0.0135</td>
<td>0.000863</td>
<td><strong>26</strong></td>
<td>1900</td>
<td>19,000</td>
<td>1727</td>
</tr>
<tr class="odd">
<td rowspan="2">Textiles</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.135</td>
<td>0.00346</td>
<td>0.006 a.i. weight fraction</td>
<td>10,000 lb/day</td>
<td>43.1</td>
<td>0.116</td>
<td>0.00297</td>
<td><strong>&lt;1</strong></td>
<td>220</td>
<td>5.400</td>
<td>211</td>
</tr>
<tr class="even">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.00629</td>
<td>4.03x10<sup>-4</sup></td>
<td>0.006 a.i. weight fraction</td>
<td>10,000 lb/day</td>
<td>0.389</td>
<td>0.00539</td>
<td>3.46x10<sup>-4</sup></td>
<td><strong>64</strong></td>
<td>4,600</td>
<td>46,000</td>
<td>4182</td>
</tr>
<tr class="odd">
<td rowspan="2">Metal Working Fluid</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.184</td>
<td>0.00854</td>
<td>0.00125 a.i. weight fraction</td>
<td>2,502 lb/day</td>
<td>2.24</td>
<td>0.00821</td>
<td>3.81x10<sup>-4</sup></td>
<td><strong>11</strong></td>
<td>3,000</td>
<td>42,000</td>
<td>2800</td>
</tr>
<tr class="even">
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.312</td>
<td>0.00348</td>
<td>0.00125 a.i. weight fraction</td>
<td>2,502 lb/day</td>
<td>0.0203</td>
<td>0.0139</td>
<td>1.56x10<sup>-4</sup></td>
<td>1,200</td>
<td>1,800</td>
<td>1.00x10<sup>5</sup></td>
<td>1768</td>
</tr>
<tr class="odd">
<td>Drilling Fluids</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.135</td>
<td>0.00346</td>
<td>0.00075 a.i. weight fraction</td>
<td>ST = 45.9 lb/day</td>
<td>ST = 0.0247</td>
<td>ST = 6.64x10<sup>-5</sup></td>
<td>ST = 1.70x10<sup>-6</sup></td>
<td>ST = 1000</td>
<td>ST = 380,000</td>
<td>ST = 9.4x10<sup>6</sup></td>
<td>365235</td>
</tr>
<tr class="even">
<td>Drilling Fluids</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>0.135</td>
<td>0.00346</td>
<td>0.00075 a.i. weight fraction</td>
<td>IT = 22.9 lb/day</td>
<td>IT = 0.0123</td>
<td>IT = 3.31x10<sup>-5</sup></td>
<td>IT = 8.49x10<sup>-7</sup></td>
<td>IT = 2,000</td>
<td>IT = 7.60x10<sup>5</sup></td>
<td>IT = 1.9x10<sup>7</sup></td>
<td>730769</td>
</tr>
<tr class="odd">
<td>Pulp and Paper</td>
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.00454</td>
<td>2.65x10<sup>-4</sup></td>
<td>0.00075 a.i. weight fraction</td>
<td>1,000,000 lb/day</td>
<td>4.86</td>
<td>0.0486</td>
<td>0.00284</td>
<td><strong>5</strong></td>
<td>510</td>
<td>5,600</td>
<td>467</td>
</tr>
<tr class="even">
<td>Small Process Water Systems</td>
<td>Liquid Pour</td>
<td>50.3</td>
<td>10.1</td>
<td>0.450</td>
<td>0.000009 a.i. weight fraction</td>
<td>90 lb/day</td>
<td>0.0006</td>
<td>0.000117</td>
<td>5.21x10<sup>-6</sup></td>
<td>43,000</td>
<td>21,000</td>
<td>3.1x10<sup>6</sup></td>
<td>20858</td>
</tr>
<tr class="odd">
<td>Small Process Water Systems</td>
<td>Liquid Pump</td>
<td>0.454</td>
<td>0.0860</td>
<td>0.00432</td>
<td>0.000009 a.i. weight fraction</td>
<td>180,000 lb/day</td>
<td>0.0105</td>
<td>0.00199</td>
<td>0.0001</td>
<td>2,400</td>
<td>13,000</td>
<td>1.6x10<sup>5</sup></td>
<td>12023</td>
</tr>
</tbody>
</table>

ST = short-term; IT = intermediate-term

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

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

c Absorbed Daily dose (mg/kg/day) = \[unit exposure (mg/lb a.i.) \*
application rate \* quantity treated / Body weight (70 kg).

d MOE = NOAEL (mg/kg/day) / Absorbed Daily Dose \[Where ST/IT NOAEL = 25
mg/kg/day for dermal and 16 mg/kg/day for inhalation\].

[]{.mark}

**5.2 Occupational Post-application Exposures**

**5.2.1 Metal Working Fluids: Machinist**

There is a potential for dermal and inhalation exposure when a worker
handles treated metal working fluids. This route of exposure occurs
after the chemical has been incorporated into the metal working 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 F a.i. x FT x FQ]{.underline}* **(Eq. 15)**

*BW*

Where:

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

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

F a.i. = Fraction active ingredient in treated metal working fluid
(unitless);

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

FQ = Frequency of events (event/day); and

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 fraction of active ingredient in treated metal working fluid is
    0.00125.

-   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 titled, "A Laboratory Method to Determine the Retention
    of Liquids on the Surface of Hands." The film thickness is based on
    a machinist immersing both hands in metal working 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 metal working 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 F a.i. x ED]{.underline}* **(Eq. 16)**

*BW*

Where:

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

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

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

F a.i. = Fraction active ingredient in treated metal working fluid
(unitless);

ED = Exposure duration (hrs/day); and

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 fraction active ingredient in treated metal working fluid is
    0.00125.

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

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

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

***Dermal and Inhalation Results***

Table 5.3 shows the calculation of the absorbed daily doses and MOEs for
a machinist working with metal working fluids. The dermal and inhalation
MOE values as well as total MOEs are above the target MOEs for all
durations.

<table>
<colgroup>
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 11%" />
<col style="width: 5%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 8%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="14"><strong>Table 5.3. Short-, Intermediate-, and Long-Term
Risks Associated with Post-application Exposure to Metal Working Fluids
treated with Preservative (Machinist)</strong></td>
</tr>
<tr class="even">
<td rowspan="3">Weight Fraction a.i. in Fluid</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="5">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">Inhalation<sup>b</sup></td>
<td>Dermal MOE (Target MOE = 100 for ST/IT, 300 for LT)<sup>c</sup></td>
<td colspan="2">Inhalation MOE (Target MOE = 100 for ST/IT and 300 for
LT)<sup>d</sup></td>
<td colspan="2">Total MOE</td>
</tr>
<tr class="even">
<td>ST/IT/LT</td>
<td>ST/IT</td>
<td>LT</td>
<td><p>ST/IT</p>
<p>MOE=100</p></td>
<td><p>LT</p>
<p>MOE=300</p></td>
</tr>
<tr class="odd">
<td>0.00125</td>
<td>840</td>
<td>1.75</td>
<td>1</td>
<td>5</td>
<td>1</td>
<td>8</td>
<td>0.0263</td>
<td>0.000714</td>
<td>950</td>
<td>22,000</td>
<td>5300</td>
<td>910</td>
<td>806</td>
</tr>
</tbody>
</table>

a Absorbed Dermal Daily Dose (mg/kg/day) = \[fraction a.i. in treated
fluid \* hand surface area\* film thickness (mg/cm^2^)\* Frequency
(event/day)\] / Body weight (70 kg).

b Absorbed Inhalation Daily Dose (mg/kg/day) = fraction a.i. in treated
fluid \* OSHA PEL (mg/m^3^) \* Inhalation rate (m^3^/hr) \* exposure
duration (hr/day) / body weight (70 kg)

c Dermal MOE = NOAEL (mg/kg/day) / Absorbed Daily Dose (mg/kg/day)
\[Where: ST/IT/LT dermal NOAEL = 25 mg/kg/day\].

d Inhalation MOE = NOAEL (mg/kg/day) / Absorbed Daily Dose (mg/kg/day)
\[Where: ST/IT inhalation NOAEL = 16 mg/kg/day and LT Inhalation NOAEL =
3.8 mg/kg/day\].

**[\
]{.mark}**

**5.2.2 Wood Preservation**

TCMTB is used in products that are intended to preserve wood through
non-pressure treatment methods. It can be applied as a sapstain control
to freshly-cut wood, incorporated into particle board, or used to treat
wood chips. When used as a sapstain control, the product may be dipped,
sprayed, or impregnated into the wood via pressure treatment (up to 0.3%
a.i. solution). When used in particle board, the pesticide is
incorporated into the resin or binding agent (0.3% a.i., based on dry
weight of wood).

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) 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 TCMTB
products and TCMTB treated-wood, therefore, these same functions were
assessed for TCMTB.

**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:**

-   ***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 TCMTB
    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 TCMTB 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). This study is proprietary; therefore, data
compensation needs to be paid 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 TCMTB. It was assumed that batches of wood slurry 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). Since wood chips have a density of
approximately 380 kg/m^3^ (SIMetric, 2005), 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). The
assumptions used for batch sizes and the quantity of preservative needed
are consistent with an assessment performed previously by the EPA. For
this assessment, an application rate of 0.003 TCMTB w/w was used.

Table 5.4 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 ST/IT dermal and inhalation and above
300 for LT dermal and inhalation exposures.

<table>
<colgroup>
<col style="width: 9%" />
<col style="width: 9%" />
<col style="width: 7%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 12%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 11%" />
<col style="width: 11%" />
</colgroup>
<tbody>
<tr class="odd">
<td colspan="11"><strong>Table 5.4. Short-, Intermediate-, and Long-term
Exposures and MOEs for Wood Preservative Blender/Spray
Operators</strong></td>
</tr>
<tr class="even">
<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>App. Rate<sup>c</sup></p>
<p>(fraction 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="5">MOE<sup>f</sup></td>
</tr>
<tr class="odd">
<td rowspan="2">Dermal</td>
<td rowspan="2">Inhal.</td>
<td>Dermal</td>
<td colspan="2">Inhalation</td>
<td colspan="2">Total MOE</td>
</tr>
<tr class="even">
<td>ST/IT/LT</td>
<td>ST/IT</td>
<td>LT</td>
<td>ST/IT</td>
<td>LT</td>
</tr>
<tr class="odd">
<td colspan="11">Occupational Handler</td>
</tr>
<tr class="even">
<td>0.00629</td>
<td>4.03x10<sup>-4</sup></td>
<td>0.00300</td>
<td>1.78x10<sup>5</sup></td>
<td>0.0480</td>
<td>0.00307</td>
<td>520</td>
<td>5200</td>
<td>1200</td>
<td>478</td>
<td>364</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 maximum application rate for the "immersion" application method
is a solution containing 0.3% a.i.

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 (fraction
ai/day) x Quantity treated (lb/day) / BW (70 kg)

f\. MOE = NOAEL (mg/kg/day)/ Daily dose \[Where dermal ST/IT/LT NOAEL =
25 mg/kg/day, ST/IT inhalation NOAEL = 16 mg/kg/day, and LT inhalation
NOAEL = 3.8 mg/kg/day\]. Target MOE is 100 for ST/IT dermal exposures
and 300 for LT dermal and 100 for ST/IT and 300 for LT inhalation
exposures.

**[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). 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 C-1 in Appendix C. To determine TCMTB exposures, the
average DDAC exposures measured on individuals (in terms of total mg
DDAC) were multiplied by a modification factor of 0.00375 to account for
the difference in percent active ingredient between TCMTB and DDAC (3%
TCMTB 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 TCMTB:

*Daily Dose = [DDAC UE x CR x AB ]{.underline}* **(Eq. 17)**

*BW*

Where:

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

CR = Conversion ratio (3% TCMTB / 80% DDAC);

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

BW = Body weight (70 kg).

In using this methodology, the following assumptions were made:

-   DDAC and TCMTB 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 chemical
    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), a sample duration
    of 8 hrs/day, and a conversion factor of 1 mg/1000 µg. Table C-1 in
    Appendix C presents the inhalation and dermal DDAC exposures.

-   Average DDAC dermal and inhalation exposures were multiplied by a
    conversion ratio of 0.00375 to account for the differences in TCMTB
    and DDAC concentrations \[(3% TCMTB / 80% DDAC)\].

Table 5.5 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 corresponding target MOEs for ST/IT/LT durations, and
therefore are not of concern. For all worker functions, the dermal MOEs
are above the target MOE of 100 for ST/IT/LT durations. The total MOEs
were also above the target MOEs for all durations.

[]{.mark}

<table style="width:100%;">
<colgroup>
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 9%" />
<col style="width: 13%" />
<col style="width: 14%" />
<col style="width: 10%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 7%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="11"><strong>Table 5.5. 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="5">MOEs<sup>e</sup></th>
</tr>
<tr class="header">
<th rowspan="2">Dermal</th>
<th rowspan="2">Inhalation</th>
<th>Dermal</th>
<th colspan="2">Inhalation</th>
<th colspan="2">Total MOE</th>
</tr>
<tr class="odd">
<th>ST/IT/LT</th>
<th>ST/IT</th>
<th>LT</th>
<th>ST/IT</th>
<th>LT</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="11">Occupational Handler</td>
</tr>
<tr class="even">
<td>Chemical Operator (n=11)</td>
<td>9.81</td>
<td>0.0281</td>
<td>0.00375</td>
<td>5.25x10<sup>-4</sup></td>
<td>1.50x10<sup>-6</sup></td>
<td>48,000</td>
<td>1.10x10<sup>7</sup></td>
<td>2.50x10<sup>6</sup></td>
<td>47790</td>
<td>47095</td>
</tr>
<tr class="odd">
<td colspan="11">Occupational Post-application</td>
</tr>
<tr class="even">
<td>Grader (n=13)</td>
<td>3.13</td>
<td>0.0295</td>
<td>0.00375</td>
<td>1.68x10<sup>-4</sup></td>
<td>1.58x10<sup>-6</sup></td>
<td>1.50x10<sup>5</sup></td>
<td>1.00x10<sup>7</sup></td>
<td>2.40x10<sup>6</sup></td>
<td>147783</td>
<td>141176</td>
</tr>
<tr class="odd">
<td>Trim Saw (n=2)</td>
<td>1.38</td>
<td>0.0610</td>
<td>0.00375</td>
<td>7.39x10<sup>-5</sup></td>
<td>3.24x10<sup>-6</sup></td>
<td>3.40x10<sup>5</sup></td>
<td>4.90x10<sup>6</sup></td>
<td>1.20x10<sup>6</sup></td>
<td>317940</td>
<td>264935</td>
</tr>
<tr class="even">
<td>Millwright (n=3)</td>
<td>12.8</td>
<td>0.0570</td>
<td>0.00375</td>
<td>6.86x10<sup>-4</sup></td>
<td>3.05x10<sup>-6</sup></td>
<td>36,000</td>
<td>5.20x10<sup>6</sup></td>
<td>1.20x10<sup>6</sup></td>
<td>35752</td>
<td>34951</td>
</tr>
<tr class="odd">
<td>Clean-Up (n=6)</td>
<td>55.3</td>
<td>0.600</td>
<td>0.00375</td>
<td>0.00296</td>
<td>3.24x10<sup>-5</sup></td>
<td>8,400</td>
<td>4.90x10<sup>5</sup></td>
<td>1.20x10<sup>5</sup></td>
<td>8258</td>
<td>7850</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).
Refer to Table C-1 in Appendix C 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 = 0.3% TCMTB / 80% DDAC

d\. Absorbed Daily dose (mg/kg/day) = exposure (mg/day) \* conversion
ratio (0.00375) \* absorption factor (100% for dermal and
inhalation)/body weight (70 kg).

e\. MOE = NOAEL (mg/kg/day)/ Daily dose \[Where ST/IT/LT dermal NOAEL =
25 mg/kg/day, ST/IT NOAEL for inhalation is 16 mg/kg/day and LT NOAEL
for inhalation is 3.8 mg/kg/day\]. Target MOE is 100 for ST/IT dermal
and inhalation exposures and 300 for LT dermal and inhalation exposures.

**[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 C-2 in Appendix C. 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 a 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}* **(Eq. 18)**

*BW*

Where:

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

AI = AI (30% ai in solution/day);

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

BW = Body weight (70 kg).

Table 5.6 provides the short-term and the intermediate- and long-term
doses and MOEs for diptank operators. All dermal and inhalation MOES s
as well as otal MOEs were above the corresponding target MOEs and are
therefore not of concern.

<table>
<colgroup>
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 5%" />
<col style="width: 7%" />
<col style="width: 11%" />
<col style="width: 11%" />
<col style="width: 11%" />
<col style="width: 12%" />
<col style="width: 12%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="11"><strong>Table 5.6. 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>(fraction 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="5">MOEs<sup>d</sup></th>
</tr>
<tr class="header">
<th rowspan="2">Dermal</th>
<th rowspan="2">Inhalation</th>
<th>Dermal</th>
<th colspan="2">Inhalation</th>
<th colspan="2">Total MOE</th>
</tr>
<tr class="odd">
<th>ST/IT/LT</th>
<th>ST/IT</th>
<th>LT</th>
<th>ST/IT</th>
<th>LT</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="11">Occupational Handler</td>
</tr>
<tr class="even">
<td>Dipping, with gloves (n=7)</td>
<td>2.99</td>
<td>0.0460</td>
<td>0.300</td>
<td>0.0128</td>
<td>1.98x10<sup>-4</sup></td>
<td>1,900</td>
<td>81000</td>
<td>19000</td>
<td>1856</td>
<td>1727</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). Refer to Table C-2 in Appendix C 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\. A 30% ai TCMTB solution was used.

d\. Absorbed Daily dose (mg/kg/day) = unit exposure (mg/1% ai solution)
\* percent active ingredient in solution / body weight (70 kg).

e\. MOE = NOAEL (mg/kg/day)/ Daily dose \[Where ST/IT/LT dermal NOAEL =
25 mg/kg/day, ST/IT inhalation NOAEL = 16 mg/kg/day, and LT inhalation
NOAEL 3.8 mg/kg/day\]. Target MOE is 100 for ST/IT dermal and inhalation
exposures and 300 for LT dermal and inhalation exposures.

**[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.

[]{.mark}

**5.3 Data Limitations/Uncertainties**

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

-   Surrogate dermal and inhalation unit exposure values were taken from
    the proprietary Chemical Manufacturers Association (CMA)
    antimicrobial exposure study (USEPA, 1999b: DP Barcode D247642) or
    from the Pesticide Handler Exposure Database (USEPA, 1998) (See
    Appendix B 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.

-   Unit exposures are not available for some of the specific scenarios
    that are prescribed for TCMTB. These scenarios include the
    following: open loading into oil-well/field environments and
    metering into cooling water systems at power plants.

-   The CMA data used for oil-well uses are based on open pouring of a
    material preservative. Although these data are only represented by 2
    replicates each, the exposure values are similar to open loading of
    pesticides in PHED. Furthermore, there are no representative unit
    exposure data for chemical metering into secondary recovery oil
    operations. Since the volume of water being treated in secondary
    recovery operations is so large, the available CMA data can not be
    reliably extrapolated because they are based on activities that
    handle much lower volumes and possibly different techniques.
    Therefore, it was assumed that if the open pour handling activities
    for the other oil well operations resulted in MOEs that are not of
    concern, then the MOEs for the closed system chemical metering into
    secondary recovery operations would also be not of concern. AD
    requests that confirmatory data be conducted to show that this is
    accurate.

-   The CMA data used for cooling water systems at power plants are
    based on closed metering for pulp and paper. The pulp and paper unit
    exposures were deemed more appropriate than the cooling water tower
    data because of the large volume of water treated in cooling water
    systems at power plants. However, the CMA data for pulp and paper
    does not reliably represent the volume of water treated and the
    possibly different techniques used to treat the water.

-   For the wood preservative treatment scenarios, DDAC exposure data
    were used for the lack of TCMTB-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 DDAC would be similar to exposure
    patterns for workers at treatment facilities using TCMTB, and
    therefore the exposures could be used as surrogate data for workers
    that treat wood with TCMTB.

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

```{=html}
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```
-   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 personal communication with experts. In particular, the use
    information for the pulp and paper processing, oil-well uses, and
    cooling water tower uses are based on personal communication with
    biocide manufacturers for these types of uses. The individuals
    contacted have experience in these operations and their estimates
    are believed to be the best available without undertaking a
    statistical survey of the uses. 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. For example, the quantities handled/treated for
    the application of TCMTB to the surface of metal/wood cooling towers
    could be refined.

    **6.0 REFERENCES**

[]{.mark}

Bestari 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.

[]{.mark}

Freeman, N , Jimenez M, Reed KJ,Gurunathan S, Edwards RD, Roy A, Adgate
JL, Pellizzari ED, Quackenboss J, Sexton K, Lioy PJ, 2001. Quantitative
analysis of chilren's microactivity patterns: The Minnesota Children's
Pesticide Exposure Study. Journal of Exposure Analysis and Environmental
Epidemiology. 11(6): 501-509.

HERA, 2005. Human and Environmental Risk Assessment, Guidance Document
Methodology, February 2005 (http://www.heraproject.com).

The Multi-Chamber Concentration and Exposure Model (MCCEM) Model Version
1.2. Prepared for the US EPA Office of Pollution Prevention and Toxics.
Prepared by Versar, Inc. and Wilkes Technologies, LLC.

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

[]{.mark}

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.

[]{.mark}

USEPA. 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.

[]{.mark}

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.

[]{.mark}

Doityourself.com. 2005. What You Need to Know When Carpet Shopping.
http://doityourself.com/carpet/carpetshopping.htm, viewed September
2005.

[]{.mark}

USEPA. 2004. PBT Profiler: Assessing Chemicals in the Absence of Data,
v1.203. http://www.pbtprofiler.net/default.asp. Accessed January 2006.

USEPA. 2006. 2-(thiocyanomethylethylthio) benzothaizole (TCMTB)- report
of the Antimicrobials Division Toxicity Endpoint Selection Committee
(ADTC). Memorandum from Timothy McMahon to Deborah Smegal. April 4,
2006.

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[]{.mark}

**APPENDIX A: Master TCMTB Label List**

[]{.mark}

Table A shows the uses and application rates stated on the product
labels for 43 TCMTB products. The table is ordered by the type of use
associated with a product. As any one product may have multiple uses,
products can be listed multiple times. Application rates, as stated on
the product labels, were converted either into terms of lbs a.i./gal or
into terms of a weight fraction, in order to more easily compare
application rates between products. All products listed below are
formulated as liquids (i.e. ready-to-use liquid, emulsifiable
concentrate, soluble concentrate) except for Product \# 1448-408, which
is a wettable powder and used only for formulation.

  -----------------------------------------------------------------------------------------------------------------
  **Table A:                                                                                     
  Application                                                                                    
  Rates and                                                                                      
  Uses for                                                                                       
  TCMTB                                                                                          
  Products**                                                                                     
  ------------- ----------- ------------- -------------- ----------- ------------- ------------- ------------------
  **Product     **Percent   **Density     **Use**        **App. Rate **Converted   **Converted   **Comments**
  Number**      AI**        (lbs/gal)**                  on Label**  App Rate      App. Rate     
                                                                     (Rounded)**   Units**       

  1448-265      30          9             Cutting Fluids 1250 ppm    0.00125       a.i. weight   for use in diluted
                                                         a.i.                      fraction      cutting fluids

  1448-244      10          8.19          Cutting Fluids 3750 ppm    3.75x10^-4^   a.i. weight   for use in diluted
                                                         Product                   fraction      cutting fluids

  1448-99       10          8.2           Cutting Fluids 3750 ppm    3.75x10^-4^   a.i. weight   for use in diluted
                                                         Product                   fraction      cutting fluids

  1448-100      5           7.8           Cutting Fluids 7500 ppm    3.75x10^-4^   a.i. weight   for use in diluted
                                                         Product                   fraction      cutting fluids

  1448-152      5           7.8           Cutting Fluids 7500 ppm    3.75x10^-4^   a.i. weight   for use in diluted
                                                         Product                   fraction      cutting fluids

  1448-55       30          9             Cutting Fluids 1250 ppm    3.75x10^-4^   a.i. weight   for use in diluted
                                                         Product                   fraction      cutting fluids

  1448-150      30          8.7           Cutting Fluids 1250 ppm    3.75x10^-4^   a.i. weight   for use in diluted
                                                         Product                   fraction      cutting fluids

  1448-386      5           8.5           Cutting Fluids 7500 ppm    3.75x10^-4^   a.i. weight   
                                                         Product                   fraction      

  1448-151      10          8.19          Cutting Fluids 750 ppm     7.50x10^-5^   a.i. weight   
                                                         Product                   fraction      

  1448-153      5           7.8           Cutting Fluids 1500 ppm    7.50x10^-5^   a.i. weight   
                                                         Product                   fraction      

  1448-149      30          9             Cutting Fluids 250 ppm     7.50x10^-5^   a.i. weight   
                                                         Product                   fraction      

  1448-386      5           8.5           Drilling       1.5 Percent 7.50x10^-4^   a.i. weight   
                                          Fluids         Product                   fraction      

  1448-99       10          8.2           Drilling       0.75        7.50x10^-4^   a.i. weight   50.4
                                          Fluids         Percent                   fraction      
                                                         Product                                 

  1448-152      5           7.8           Drilling       1.5 Percent 7.50x10^-4^   a.i. weight   22.96
                                          Fluids         Product                   fraction      

  1448-100      5           7.8           Drilling       1.5 percent 7.50x10^-4^   a.i. weight   
                                          Fluids         product                   fraction      

  1448-153      5           7.8           Drilling       1.5 Percent 7.50x10^-4^   a.i. weight   
                                          Fluids         Product                   fraction      

  1448-151      10          8.19          Drilling       0.75        7.50x10^-4^   a.i. weight   
                                          Fluids         Percent                   fraction      
                                                         Product                                 

  1448-244      10          8.19          Drilling       0.75        7.50x10^-4^   a.i. weight   
                                          Fluids         Percent                   fraction      
                                                         Product                                 

  1448-150      30          8.7           Drilling       0.25        7.50x10^-4^   a.i. weight   
                                          Fluids         Percent                   fraction      
                                                         Product                                 

  1448-149      30          9             Drilling       0.25        7.50x10^-4^   a.i. weight   
                                          Fluids         Percent                   fraction      
                                                         Product                                 

  1448-55       30          9             Drilling       0.25        7.50x10^-4^   a.i. weight   
                                          Fluids         percent                   fraction      
                                                         Product                                 

  1448-383      4           8.6           Drilling       0.8 Percent 3.20x10^-4^   a.i. weight   
                                          Fluids         Product                   fraction      

  1448-377      10          9.2           Drilling       0.25        2.50x10^-4^   a.i. weight   
                                          Fluids         Percent                   fraction      
                                                         Product                                 

  1448-376      2.5         8.3           Drilling       1 Percent   2.50x10^-4^   a.i. weight   
                                          Fluids         Product                   fraction      

  1448-147      10          9             Drilling       0.25        2.50x10^-4^   a.i. weight   
                                          Fluids         Percent                   fraction      
                                                         Product                                 

  1448-148      10          9             Drilling       0.25        2.50x10^-4^   a.i. weight   
                                          Fluids         Percent                   fraction      
                                                         Product                                 

  44392-11      2.5         8.6           Drilling       1 Percent   2.50x10^-4^   a.i. weight   
                                          Fluids         Product                   fraction      

  1448-81       10          9             Drilling       0.25        2.50x10^-4^   a.i. weight   
                                          Fluids         Percent                   fraction      
                                                         Product                                 

  1448-102      2.5         8.6           Drilling       1 Percent   2.50x10^-4^   a.i. weight   
                                          Fluids         Product                   fraction      

  1448-172      2.5         8.6           Drilling       1 Percent   2.50x10^-4^   a.i. weight   
                                          Fluids         Product                   fraction      

  1448-171      2.5         8.6           Drilling       1 Percent   2.50x10^-4^   a.i. weight   
                                          Fluids         Product                   fraction      

  1448-82       60          10.1          Ion Exchange   100 ppm     6.00x10^-5^   a.i. weight   Twice a week
                                          (Metal         Product                   fraction      
                                          Recovery)                                              

  1448-55       30          9             Leather        0.2 percent 6.00x10^-4^   a.i. weight   
                                                         product                   fraction      

  1448-386      5           8.5           Leather        12 lbs      6.00x10^-4^   a.i. weight   
                                                         prod/1000                 fraction      
                                                         lbs white                               
                                                         weight                                  
                                                         stock                                   

  1448-37       60          0             Leather        1000 ppm    6.00x10^-4^   a.i. weight   
                                                         Product in                fraction (in  
                                                         Leather                   leather)      

  1448-100      5           7.8           Leather        12 lbs      6.00x10^-4^   a.i. weight   
                                                         prod/1000                 fraction      
                                                         lbs white                               
                                                         weight                                  
                                                         stock                                   

  1448-99       10          8.2           Leather        6 lbs       6.00x10^-4^   a.i. weight   
                                                         prod/1000                 fraction      
                                                         lbs white                               
                                                         weight                                  
                                                         stock                                   

  1448-412      10.4        9             Leather        3000 ppm    3.12x10^-4^   a.i. weight   to white lime
                                                         Product                   fraction      stock. 1% mix to
                                                                                                 fatliquor is
                                                                                                 possible as well.

  1448-377      10          9.2           Leather        2500 ppm    2.50x10^-4^   a.i. weight   
                                                         Product                   fraction      

  1448-81       10          9             Leather        0.25        2.50x10^-4^   a.i. weight   
                                                         Percent                   fraction      
                                                         Product                                 

  1448-102      2.5         8.6           Leather        10 lbs      2.50x10^-4^   a.i. weight   
                                                         prod/1000                 fraction      
                                                         lbs white                               
                                                         weight                                  
                                                         stock                                   

  1448-376      2.5         8.3           Leather        10 lbs      2.50x10^-4^   a.i. weight   
                                                         prod/1000                 fraction      
                                                         lbs white                               
                                                         weight                                  
                                                         stock                                   

  1448-37       60          0             mulch paper    2.5 lbs/ton 7.50x10^-4^   a.i. weight   
                                                         paper                     fraction      

  1448-100      5           7.8           Mulch Paper    30 lbs      7.50x10^-4^   a.i. weight   
                                                         prod/ton                  fraction      
                                                         paper                                   

  1448-82       60          10.1          Oil            6 fl oz     2.84x10^-4^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-386      5           8.5           Oil            32 fl oz    1.06x10^-4^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-99       10          8.2           Oil            16 fl oz    1.03x10^-4^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-100      5           7.8           Oil            32 fl oz    9.75x10^-5^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-377      10          9.2           Oil            6 fl oz     4.31x10^-5^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-81       10          9             Oil            6 fl oz     4.22x10^-5^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-148      10          9             Oil            6 fl oz     4.22x10^-5^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-147      10          9             Oil            6 fl oz     4.22x10^-5^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  44392-11      2.5         8.6           Oil            25 fl oz    4.20x10^-5^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-102      2.5         8.6           Oil            25 fl oz    4.20x10^-5^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-172      2.5         8.6           Oil            25 fl oz    4.20x10^-5^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well. crude,
                                                                                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well

  1448-171      2.5         8.6           Oil            25 fl oz    4.20x10^-5^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-376      2.5         8.3           Oil            24 fl oz    3.89x10^-5^   lbs a.i./gal  Oil preservation
                                          Preservation   prod/1000                               can mean crude,
                                                         gal oil                                 refined, and fuel
                                                                                                 preservation as
                                                                                                 well.

  1448-377      10          9.2           Oil Well       13 fl oz    9.34x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-81       10          9             Oil Well       13 fl oz    9.14x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-148      10          9             Oil Well       13 fl oz    9.14x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-147      10          9             Oil Well       13 fl oz    9.14x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-102      2.5         8.6           Oil Well       52 fl oz    8.73x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-171      2.5         8.6           Oil Well       52 fl oz    8.73x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-172      2.5         8.6           Oil Well       52 fl oz    8.73x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  44392-11      2.5         8.6           Oil Well       52 fl oz    8.73x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-376      2.5         8.3           Oil Well       52 fl oz    8.43x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-55       30          9             Oil Well       3.7 fl oz   7.80x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-149      30          9             Oil Well       3.7 fl oz   7.80x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-150      30          8.7           Oil Well       3.7 fl oz   7.54x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-386      5           8.5           Oil Well       22.2 fl oz  7.37x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-99       10          8.2           Oil Well       11.1 fl oz  7.11x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-151      10          8.19          Oil Well       11.1 fl oz  7.10x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-244      10          8.19          Oil Well       11.1 fl oz  7.10x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-153      5           7.8           Oil Well       22.2 fl oz  6.76x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-100      5           7.8           Oil Well       22.2 fl oz  6.76x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-383      4           8.6           Oil Well       10 fl oz    2.69x10^-5^   lbs a.i./gal  for intermittent
                                          Recovery       prod/1000                               feed. for
                                                         gal H2O                                 continuous feed,
                                                                                                 6.3. for slug
                                                                                                 feed, 12.6.

  1448-152      5           7.8           Oil Well       7.2 fl oz   2.19x10^-5^   lbs a.i./gal  
                                          Recovery       prod/1000                               
                                                         gal H2O                                 

  1448-99       10          8.2           Paint          15 Percent  0.015         a.i. weight   
                                                         Product                   fraction      

  1448-386      5           8.5           Paint          30 Percent  0.015         a.i. weight   
                                                         Product                   fraction      

  1448-55       30          9             Paint          5 percent   0.015         a.i. weight   
                                                         product                   fraction      

  1448-81       10          9             Paint          9 Percent   0.009         a.i. weight   Mold-resistant
                                                         Product                   fraction      coating

  44392-11      2.5         8.6           Paint          36 Percent  0.009         a.i. weight   
                                                         Product                   fraction      

  1448-102      2.5         8.6           Paint          36 Percent  0.009         a.i. weight   
                                                         Product                   fraction      

  1448-376      2.5         8.3           Paint          36 Percent  0.009         a.i. weight   
                                                         Product                   fraction      

  1448-377      10          9.2           Paint          0.75        7.50x10^-4^   a.i. weight   9% for sealant
                                                         Percent                   fraction      
                                                         Product                                 

  1448-383      4           8.6           Papermaking    800 ppm     3.20x10^-5^   a.i. weight   in coating
                                          Chemicals      Product                   fraction      formulations for
                                                                                                 paper

  1448-55       30          9             Particle Board 1 percent   0.003         a.i. weight   dry weight
                                                         product                   fraction      

  1448-99       10          8.2           Particle Board 3 Percent   0.003         a.i. weight   
                                                         Product                   fraction      

  1448-386      5           8.5           Particle Board 6 Percent   0.003         a.i. weight   
                                                         Product                   fraction      

  1448-100      5           7.8           Particle Board 6 percent   0.003         a.i. weight   
                                                         product                   fraction      

  1448-81       10          9             Particle Board 0.3 Percent 3.00x10^-4^   a.i. weight   
                                                         Product                   fraction      

  1448-377      10          9.2           Particle Board 0.3 Percent 3.00x10^-4^   a.i. weight   
                                                         Product                   fraction      

  1448-45       8           9.6           Process Fresh  4 ppm       3.20x10^-7^   a.i. weight   
                                          Water          Product                   fraction      

  1448-383      4           8.6           Process Fresh  8 ppm       3.20x10^-7^   a.i. weight   
                                          Water          Product                   fraction      

  1448-386      5           8.5           Pulp           30 lbs      7.50x10^-4^   a.i. weight   
                                          Preservation   prod/ton                  fraction      
                                                         paper                                   

  1448-100      5           7.8           Pulp           24 lbs      6.00x10^-4^   a.i. weight   
                                          Preservation   prod/ton                  fraction      
                                                         paper                                   

  1448-99       10          8.2           Pulp           12 lbs      6.00x10^-4^   a.i. weight   for agricultural
                                          Preservation   prod/ton                  fraction      mulch paper, 15
                                                         paper                                   lbs/ton

  1448-37       60          0             pulp           2 lbs/ton   6.00x10^-4^   a.i. weight   ton dry fiber
                                          preservation                             fraction      

  1448-55       30          9             Pulp           2 lbs/ton   3.00x10^-4^   a.i. weight   dry fiber
                                          Preservation                             fraction      

  1448-81       10          9             Pulp           4 lbs       2.00x10^-4^   a.i. weight   for wet lap or
                                          Preservation   prod/ton                  fraction      sheet pulp. for
                                                         paper                                   bacteriostatic
                                                                                                 paper, 9.0%
                                                                                                 addition.

  1448-377      10          9.2           Pulp           1.5 lbs     7.50x10^-5^   a.i. weight   9% for
                                          Preservation   prod/ton                  fraction      bacteriostatic
                                                         paper                                   paper

  1448-383      4           8.6           Pulp           2 lbs       4.00x10^-5^   a.i. weight   
                                          Preservation   prod/ton                  fraction      
                                                         paper                                   

  1448-376      2.5         8.3           Pulp           2 lbs       2.50x10^-5^   a.i. weight   
                                          Preservation   prod/ton                  fraction      
                                                         paper                                   

  1448-102      2.5         8.6           Pulp           2 lbs       2.50x10^-5^   a.i. weight   
                                          Preservation   prod/ton                  fraction      
                                                         paper                                   

  1448-45       8           9.6           Pulp           0.6 lbs     2.40x10^-5^   a.i. weight   400 ppm to coating
                                          Preservation   prod/ton                  fraction      formulations
                                                         paper                                   

  1448-368^1^   30          9             Pulp           0.1 lbs     0.00488       a.i. weight   For soapwrap
                                          Preservation   prod/1000                 fraction      application. (0.1
                                                         ft^2^                                   lb product/1000
                                                                                                 ft2) / (0.0205
                                                                                                 lbs/ft^2^)

  1448-55       30          9             Sapstain       0.08 gal    0.216         lbs a.i./gal  dipping solution
                                          Control        prod/gal                                
                                                         H2O                                     

  1448-386      5           8.5           Sapstain       480 gal     0.204         lbs a.i./gal  
                                          Control        prod/1000                               
                                                         gal H2O                                 

  1448-99       10          8.2           Sapstain       240 gal     0.197         lbs a.i./gal  
                                          Control        prod/1000                               
                                                         gal H2O                                 

  1448-100      5           7.8           Sapstain       0.48 gal    0.187         lbs a.i./gal  dipping solution
                                          Control        prod/gal                                
                                                         H2O                                     

  1448-341      5           7.6           Sapstain       100 Percent 0.05          a.i. weight   can be used
                                          Control        Product                   fraction      straight as a
                                                                                                 water repellant
                                                                                                 (not sapstain) for
                                                                                                 millwork,
                                                                                                 shingles,
                                                                                                 structural lumber,
                                                                                                 etc. in above
                                                                                                 ground service.
                                                                                                 Use inline
                                                                                                 application.

  1448-376      2.5         8.3           Sapstain       960 lbs     0.024         lbs a.i./gal  
                                          Control        prod/1000                               
                                                         gal H2O                                 

  1448-377      10          9.2           Sapstain       180 lbs     0.018         lbs a.i./gal  
                                          Control        prod/1000                               
                                                         gal H2O                                 

  1448-81       10          9             Sapstain       180 lbs     0.018         lbs a.i./gal  
                                          Control        prod/1000                               
                                                         gal H2O                                 

  1448-393      1           7.2           Sapstain       100 Percent 0.01          a.i. weight   to be used in
                                          Control        Product                   fraction      inline application
                                                                                                 for water
                                                                                                 repellant.

  1448-102      2.5         8.6           Sapstain       96 lbs      0.0024        lbs a.i./gal  
                                          Control        prod/1000                               
                                                         gal H2O                                 

  1448-55       30          9             Textile        2 percent   0.006         a.i. weight   
                                                         product                   fraction      

  1448-55       30          9             Wastewater     30 ppm      9.00x10^-6^   a.i. weight   
                                                         Product                   fraction      

  1448-37       60          0             wood chip      1 lbs/ton   3.00x10^-4^   a.i. weight   ton dry wood
                                          preservation                             fraction      
  -----------------------------------------------------------------------------------------------------------------

**^1^Product #1448-368 states that the product is to be applied at a
rate 0.1 lbs prod/1,000 ft^2^ for soap wrap. Without knowing the weight
of soapwrap (in lbs/ft^2^), the application rate cannot be converted
into terms that allow for comparison with other products. For lack of
information, it was assumed that soap wrap has a weight density of 100
grams/m^2^, or 0.0205 lbs/ft^2^.**

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**APPENDIX B: 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 re-registrations (CMA, 1992). The unit
exposures presented in the most recent EPA evaluation of the CMA
database (USEPA, 1999b) was 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.

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**APPENDIX C**: Calculation of DDAC Unit Exposure Values

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

  Replicate Number Chemical                                       Grader                                         Trim Saw                                       Millwright                                      Cleanup                          
                   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 Mean  **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**

  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>
<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 colspan="12"><strong>Table C-2: Normalization of DDAC Dermal and
Inhalation Exposure Values for Diptank
Operators<sup>a</sup></strong></td>
</tr>
<tr class="even">
<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="odd">
<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="even">
<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="odd">
<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="even">
<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="odd">
<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="even">
<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="odd">
<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="even">
<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="odd">
<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="even">
<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="odd">
<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="even">
<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="odd">
<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).

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 μg or 0.0056 mg/m3). 1/2 LOD
was used in all calculations (0.003 mg/m^3^). Air Concentration (mg/m3)
= 5.6 μg / (\~2 L/min flow rate x \~480 min) x 1000 L/m^3^ conversion x
0.001 μg/mg = 0.003 mg/m^3^

e\. Inhalation exposure (mg) = air concentration (mg/m3) 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 cm2 x \<0.007 ug/cm^2^ = LOD of 0.079 mg. 1/2 LOD reported
(i.e., 0.04 mg)