> ![](media/image1.png)**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY**

**WASHINGTON, D.C. 20460**

OFFICE OF PREVENTION,

PESTICIDES AND

TOXIC SUBSTANCES

February 27, 2006

**[Memorandum:]{.underline}**

SUBJECT: Alkyl Dimethyl Benzyl Ammonium Chloride (ADBAC): Occupational
and Residential Exposure Assessment for the Reregistration Eligibility
Decision Document.

FROM: Matthew Lloyd, Industrial Hygienist

Reregistration Branch -- RRB1

Health Effects Division (7509C)

THROUGH: Whang Phang, Branch Senior Scientist

Reregistration Branch -- RRB1

Health Effects Division (7509C)

TO: Jacquie McFarlane

Regulatory Management Branch

Antimicrobials Division (7510C)

PC Code: 069105

DP Barcode: D326917

The attached assessment is the occupational and residential exposure and
risk estimates for ADBAC to support AD=s reregistration eligibility
decision (RED) document. This exposure assessment was based on the
toxicity endpoints selected by AD. The data analysis included in this
assessment was prepared by Versar, Inc. under the supervision of HED.

**TABLE OF CONTENTS**

[**Executive Summary** 3](#__RefHeading___Toc128276198)

[**1.0 Occupational and Residential Exposure/Risk Assessment**
7](#__RefHeading___Toc128276199)

[**1.1** **Purpose** 7](#__RefHeading___Toc128276200)

[**1.2** **Criteria for Conducting Exposure Assessments**
7](#__RefHeading___Toc128276201)

[**1.3** **Summary of Hazard Concerns for ADBAC**
7](#__RefHeading___Toc128276202)

[**1.4** **Incident Reports** 10](#__RefHeading___Toc128276203)

[**1.5** **Summary of Use Patterns and Formulations**
10](#__RefHeading___Toc128276204)

[**1.5.1** **End-Use Products** 10](#__RefHeading___Toc128276205)

[**1.5.2** **Registered Use Categories and Sites**
10](#__RefHeading___Toc128276206)

[**1.5.3** **Application Methods** 10](#__RefHeading___Toc128276207)

[**2.0 Occupational Exposures and Risks**
10](#__RefHeading___Toc128276208)

[**2.1** **Occupational Handler Exposures and Risks**
10](#__RefHeading___Toc128276209)

[**2.1.1** **Data and Assumptions for Handler Exposure Scenarios**
10](#__RefHeading___Toc128276210)

[**2.1.1.1** **Assumptions for Handler Exposure Scenarios**
10](#__RefHeading___Toc128276211)

[**2.1.1.2** **Exposure Data for Handler Exposure Scenarios**
10](#__RefHeading___Toc128276212)

[**2.1.1.3** **ADBAC Handler Exposure Scenarios**
10](#__RefHeading___Toc128276213)

[**2.1.2** **ADBAC Handler Exposure and Assessment**
10](#__RefHeading___Toc128276214)

[**2.1.2.1** **ADBAC Handler Exposure and Risk Calculations**
10](#__RefHeading___Toc128276215)

[**2.1.2.2** **ADBAC Risk Summary** 10](#__RefHeading___Toc128276216)

[**2.1.3** **Cancer ADBAC Handler Exposure and Risk Assessment**
10](#__RefHeading___Toc128276217)

[**2.1.4** **Summary of Risk Concerns and Data Gaps for Occupational
Handlers** 10](#__RefHeading___Toc128276218)

[**2.1.4.1** **Summary of Risk Concerns**
10](#__RefHeading___Toc128276219)

[**2.1.4.2** **Summary of Data Gaps** 10](#__RefHeading___Toc128276220)

[**2.1.5** **Recommendations for Refining Occupational Handler Risk
Assessment** 10](#__RefHeading___Toc128276221)

[**2.2** **Occupational Postapplication Exposures and Risks**
10](#__RefHeading___Toc128276222)

[**2.2.1** **Occupational Postapplication Exposure Scenarios**
10](#__RefHeading___Toc128276223)

[**2.2.2** **Data/Assumptions for Postapplication Exposure Scenarios**
10](#__RefHeading___Toc128276224)

[**2.2.3** **Occupational Postapplication Exposure and Risk Estimates**
10](#__RefHeading___Toc128276225)

[**2.2.4** **Occupational Postapplication Exposure and Risk Estimates
for Cancer** 10](#__RefHeading___Toc128276226)

[**2.2.5** **Summary of Occupational Postapplication Risk Concerns and
Data Gaps** 10](#__RefHeading___Toc128276227)

[**2.2.6** **Recommendations for Refining Occupational Postapplication
Risk Assessment** 10](#__RefHeading___Toc128276228)

[**3.0 Residential and Other Non-Occupational Exposures and Risks**
10](#__RefHeading___Toc128276229)

[**3.1** **Residential Handler Exposures and Risks**
10](#__RefHeading___Toc128276230)

[**3.1.1** **Handler Exposure Scenarios**
10](#__RefHeading___Toc128276231)

[**3.1.2** **Data and Assumptions for Handler Exposure Scenarios**
10](#__RefHeading___Toc128276232)

[**3.1.3** **Residential Handler Exposure and Risk Estimates**
10](#__RefHeading___Toc128276233)

[**3.1.4** **Residential Handler Exposure and Risk Estimates for
Cancer** 10](#__RefHeading___Toc128276234)

[**3.1.5** **Summary of Risk Concerns and Data Gaps for Handlers**
10](#__RefHeading___Toc128276235)

[**3.1.6** **Recommendations for Refining Residential Handler Risk
Assessment** 10](#__RefHeading___Toc128276236)

[**3.2** **Residential Postapplication Exposures and Risks**
10](#__RefHeading___Toc128276237)

[**3.2.1** **Residential Postapplication Exposure Scenarios**
10](#__RefHeading___Toc128276238)

[**3.2.2** **Data and Assumptions for Residential Postapplication
Exposure Scenarios** 10](#__RefHeading___Toc128276239)

[**3.2.3** **Residential Postapplication Exposure and Risk Estimates**
10](#__RefHeading___Toc128276240)

[**3.2.4** **Residential Postapplication Exposure and Risk Estimates for
Cancer** 10](#__RefHeading___Toc128276241)

[**3.2.5** **Summary of Residential Postapplication Risk Concerns and
Data** 10](#__RefHeading___Toc128276242)

[**Gaps** 10](#__RefHeading___Toc128276243)

[**3.2.6** **Recommendations for Refining Residential Postapplication
Risk Assessments** 10](#__RefHeading___Toc128276244)

**APPENDICES**

**Appendix A - ADBAC Occupational Handler/Postapplication Risk
Calculations**

**Appendix B -- ADBAC Agricultural and Residential Handler Risks**

[]{#__RefHeading___Toc128276198 .anchor}**Executive Summary**

ADBAC (Group II Quat Cluster) is a group of structurally similar
quaternary ammonium compounds ("quats"). Most of the registered uses of
ADBAC are classified as antimicrobial uses and will be assessed by the
Antimicrobial Division in EPA=s Office of Pesticide Programs. This
document is the occupational and residential exposure assessment for
ADBAC from its use as a fungicide, bactericide, viricide, algaecide on
plants and as an insecticide for controlling mosquitoes. In this
document, the Agency presents the results of its review of the potential
human health effects of occupational and residential (non-occupational)
exposure to ADBAC.

Toxicological endpoints were selected for short-term dermal, short- and
intermediate-term inhalation, and incidental oral exposures to ADBAC.
There is a significant potential for exposure in occupational
agricultural and commercial settings, as well as in residential
settings. Therefore, risk assessments are required for occupational and
residential handlers, as well as for occupational and residential
postapplication exposures that can occur as a result of ADBAC use.

ADBAC is used to control plant diseases and to treat for mosquito larvae
in water. The use patterns can range from short-term through
intermediate-term exposure durations. Endpoints were selected to address
each of these exposure durations. ADBAC exposures are expected to occur
to both occupational and residential users. The Agency selected a
short-term dermal endpoint for ADBAC based on adverse dermal effects
rather than systemic toxicity. The short-term endpoint for a formulated
product (NOAEL= 500 mg/kg/day which is equivalent to 7,750 µμg/cm^2^)
was determined from a 21-day dermal toxicity in guinea pigs where a
denuded non-vascularized epidermal layer was observed at 1,000
mg/kg/day. The short-term dermal endpoint for the technical grade active
ingredient (TGAI -- 80% ai) (NOAEL=20 mg/kg/day which is equivalent to
40 µg/cm^2^) was determined from 90-day dermal toxicity in rats.

For short- and intermediate-term inhalation exposures to ADBAC, a NOAEL
of 3 mg/kg/day was selected chosen for a prenatal developmental toxicity
study in rabbits. The LOAEL of 9 mg/kg/day was based clinical signs of
toxicity at 9 mg/kg/day in maternal rabbits. Long-term inhalation
exposure to ADBAC (i.e., greater than 6 months) is not expected for
current registered uses. The short-term incidental oral risk assessment
for ADBAC was based on a NOAEL of 10 mg/kg/day, derived from a prenatal
developmental toxicity study in rats. The LOAEL of (100 mg/kg/day was
based decreased body weight and food consumption. No cancer endpoint was
identified.

The level of concern (LOC) for occupational and non-occupational ADBAC
dermal and inhalation exposures is a margin of exposure (MOE) of less
than 100. The MOE was based on 10x for interspecies extrapolation, and
10x for intraspecies variability. Since the toxicological endpoint for
inhalation is female-specific, a body weight of 60 kilograms was used in
the assessment. This value represents the average body weight of an
adult female. For calculating dermal exposure risk, the unit was based
on the treatment area (e.g.- µg/cm^2^).

ADBAC is formulated as a soluble concentrate, emulsifiable concentrate,
ready-to-use solution, pressurized liquid, wettable powder, water
soluble packet, flowable concentrate, microencapsulated and impregnated
material. There are many end-use products that contain ADBAC and each
label cannot be reviewed to determine the formulation-type and the
registered uses. Also note that the Master Label does not indicate the
formulation types that have been registered for individual use-patterns.
Therefore, as a conservative approach, this chapter will assume that
ADBAC when used to control plant diseases may be formulated as a liquid
concentrate, a dry flowable, and a wettable powder. For mosquito
control, it is assume that it is formulated as a liquid concentrate
only, since it is designed to be poured into water as a treatment

In occupational settings, ADBAC is applied with several types of
application equipment including groundboom sprayers, airblast sprayers,
low-pressure handwand sprayers, high pressure handwand sprayers, handgun
sprayers, dip or soak tanks, watering cans, and pump-trigger sprayers.
ADBAC dermal exposures and risks were not estimated for occupational
handler exposures. Instead, dermal exposures and risks will be mitigated
using default personal protective equipment requirements based on the
toxicity of the end-use product. To minimize dermal exposures, the
minimum PPE required for mixers, loaders, and others exposed to end-use
products containing concentrations of ADBAC that result in
classification of category I or II for skin irritation potential will be
long-sleeve shirt, long pants, shoes, socks, chemical-resistant gloves,
and chemical-resistant apron. The minimum PPE required for mixers,
loaders, and others exposed to end-use products containing
concentrations of ADBAC that result in classification of category III
for skin irritation potential will be long-sleeve shirt, long pants,
shoes, socks, and chemical-resistant gloves. Once diluted, if the
concentration of ADBAC in the diluted solution would result in
classification of toxicity category IV for skin irritation potential,
then the chemical-resistant gloves and chemical-resistant apron can be
eliminated for applicators and others exposed to the dilute. Note that
chemical-resistant eye protection will be required if the end-use
product is classified as category I or II for eye irritation potential.

[]{.mark}

There are no occupational handler scenarios for ADBAC that have
inhalation risks of concern for occupational exposures at the maximum
level of risk mitigation. The following handler inhalation risks are of
concern at baseline (i.e., no respirator):

-   (1a) mixing/loading liquids concentrates for groundboom applications
    for drench applications to carnations (256 lb ai/A) -- risks are not
    of concern with the addition of a dust/mist respirator,

-   (2a) mixing/loading wettable powders for groundboom applications for
    drench applications to carnations (256 lb ai/A) and for drench
    applications to ornamental plants (72 lb ai/A) and for application
    to sodfarm turf (0.9 lb ai/A) -- risks are not of concern with
    engineering controls (i.e., water-soluble packaging) for the drench
    application, and risks are not of concern for application to sod
    farms with the addition of a dust/mist respirator,

-   (2b) mixing/loading wettable powders support LCO handgun
    applications (mixing/loading supports 20 LCOs) for applications to
    turf (7 lb ai/A and 0.9 lb ai/A) ) -- risks are not of concern with
    engineering controls (i.e., water-soluble packaging),

-   (2b) mixing/loading wettable powders support LCO handgun
    applications (mixing/loading supports 20 LCOs) for applications to
    turf (0.9 lb ai/A) -- risks are not of concern with the addition of
    a dust/mist respirator,

-   (3a) mixing/loading dry flowables for groundboom applications for
    drench applications to carnations (256 lb ai/A) -- risks are not of
    concern with the addition of a dust/mist respirator,

-   \(4\) applying sprays via groundboom equipment for drench
    applications to carnations (256 lb ai/A) -- risks are not of concern
    with the addition of a dust/mist respirator,

-   \(11\) mixing/loading/applying liquid concentrates with a handgun
    sprayer applications to carnations (256 lb ai/A) -- MOE is 94 at
    baseline and risks are not of concern with the addition of a
    dust/mist respirator,

-   \(12\) mixing/loading/applying wettable powders with a handgun
    sprayer for drench applications to carnations (256 lb ai/A) and for
    drench applications to ornamental plants (72 lb ai/A) -- risks are
    not of concern with engineering controls for mixing/loading (i.e.,
    water-soluble packaging) and the addition of a dust/mist respirator
    for application,

-   \(14\) mixing/loading/applying dry flowables with a handgun sprayer
    for drench applications to carnations (256 lb ai/A) -- risks are not
    of concern with engineering controls for mixing/loading (i.e.,
    water-soluble packaging) and the addition of a dust/mist respirator
    for application, and

-   \(14\) mixing/loading/applying dry flowables with a handgun sprayer
    for drench applications to ornamental plants (72 lb ai/A) -- risks
    are not of concern with the addition of a dust/mist respirator.

[]{.mark}

ADBAC can be used on ornamental crops in greenhouse and outdoor
occupational settings and on also on turfgrass. As a result, individuals
can potentially be exposed by working in areas that have been previously
treated. The occupational postapplication exposure and risk assessment
for ornamental crop uses of ADBAC indicates that dermal risks are of
concern following applications applied as a spray for the three
application rates. When applied as a spray for ornamental crops uses,
dermal risks remain of concern for 3 days until after application for
turf application at the lower application rate, 7 days until after
application for the higher rate and for 13 days until after application
for treating plants. Dermal risks also remain of concern following
applications applied as a drench to carnations until 69 days after
application and applied as a drench to herbaceous ornamentals until 57
days after application.

[]{.mark}

-   Inhalation exposures are thought to be negligible in outdoor
    postapplication scenarios, since ADBAC has low vapor pressure and
    the dilution factor in an outdoor environment is considered
    infinite. In addition, under the Worker Protection Standard for
    Agricultural Pesticides B WPS B (40 CFR 170) greenhouses must be
    appropriately ventilated (ventilation criteria are provided)
    following pesticide applications so that postapplication inhalation
    exposures are minimal. As such, inhalation postapplication exposures
    are not considered in this assessment.

[]{.mark}

It has been determined that there is a potential for exposure in
residential settings during the application process for homeowners who
use products containing ADBAC. There is also a potential for exposure
from entering ADBAC-treated areas, such as residential turfgrass, home
gardens and greenhouses that could lead to exposures to adults and
children. Risk assessments have been completed for both residential
handler and postapplication scenarios.

[]{.mark}

Risks for all inhalation scenarios were not of concern for residential
handlers. One dermal scenario for residential handlers was of concern
when the end-use product formulation was less than 10 percent;
mixing/loading/applying liquid concentrates with a hose-end sprayer on
residential turf at the 7 lb ai/A rate had an MOE of **66**. When the
end-use product is formulated with more than 10% ADBAC, the dermal risks
for residential handlers are of concern for ADBAC residential handler
scenarios where data are available (MOEs range from **4** to **55**)
except mixing/loading/applying liquids for seedlings, seeds & cuttings
with watering cans (MOE - 280).

[]{.mark}

Short-term MOEs were calculated for adults performing tasks in home
greenhouses, gardens and residential turfgrass following applications of
ADBAC, and for toddlers entering treated turfgrass. Cancer risks were
not calculated, since no toxicological endpoint for cancer was
identified. In residential settings, the Agency does not use
restricted-entry intervals or other mitigation approaches to limit
postapplication exposures, because they are viewed as impractical and
not enforceable. As such, risk estimates on the day of application are
the key concern. Dermal risks were calculated for adults performing
tasks in home greenhouses and gardens and on home lawns following
applications of ADBAC. The dermal MOEs are of concern (i.e., MOEs ≥100)
on the day of application for these scenarios. MOEs range from **41** to
**79**, depending on the application rate. Incidental oral ingestion
risks were calculated for toddlers playing on treated turf. Only one
scenario \-- hand-to-mouth activity at the higher application rate \--
had MOEs \<100. Short-term MOEs were \>100 for object-to-mouth
activities and incidental soil ingestion and for hand-to-mouth activity
at the lower application rate. The combined risk from incidental oral
ingestion by toddlers following applications to home lawns is of concern
with an MOE of **76** for the higher application rate on treated turf (7
lb ai/A), but not a concern for the lower application rate on treated
turf (0.9 lb ai/A) (MOE -- 590).

[]{#__RefHeading___Toc128276199 .anchor}**1.0 Occupational and
Residential Exposure/Risk Assessment**

[]{#__RefHeading___Toc128276200 .anchor}**1.1 Purpose**

ADBAC (Group II Quat Cluster) is a group of structurally similar
quaternary ammonium compounds ("quats") that are characterized by having
a positively charged nitrogen covalently bonded to three alkyl group
substituents and a benzyl substituent. In finished form, these quats are
salts with the positively charged nitrogen (cation) balanced by a
negatively charged molecule (anion). The most common anion for the quats
in this cluster is chloride. However, other anions, such as saccharinate
and bromide are also used. Most of the registered uses of ADBAC are
classified as antimicrobial uses and will be assessed by the
Antimicrobial Division in EPA=s Office of Pesticide Programs.

This document is the occupational and residential exposure assessment
for ADBAC from its use to control plant diseases and to control mosquito
larvae in standing water. In this document, the Agency presents the
results of its review of the potential human health effects of
occupational and residential/ nonoccupational exposure to ADBAC.

[]{#__RefHeading___Toc128276201 .anchor}**1.2 Criteria for Conducting
Exposure Assessments**

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

[]{#__RefHeading___Toc128276202 .anchor}**1.3 Summary of Hazard Concerns
for ADBAC**

The toxicological endpoints used to complete the occupational and
residential risk assessment were based on the best professional judgment
of EPA toxicologists. Adverse effects were identified at durations of
exposure ranging from short-term (up to 30 days) to intermediate-term
durations (30 days up to 6 months) and long-term durations (greater than
6 months). No cancer endpoint was identified; therefore, cancer risks
were not assessed.

ADBAC is used to control plant diseases and mosquito larvae where the
use patterns can range from short-term through intermediate-term
exposure durations. Endpoints were selected from the ADBAC hazard
database to address each of these durations of exposure. ADBAC exposures
are expected to occur to both occupational and residential users.

[Dermal Route:]{.underline}

No short- or intermediate-term dermal endpoint for systemic effects was
selected for ADBAC, since no systemic effects were identified up to 20
mg/kg/day, which is the highest dose tested before irritation became
significant. However, short-term dermal irritation endpoints were
identified for ADBAC. The short-term endpoint for a formulated product
(500 mg/kg/day which is equivalent to 7,750 μg/cm^2^) was determined
from a 21-day dermal toxicity in guinea pigs where a denuded
non-vascularized epidermal layer was observed at 1,000 mg/kg/day. The
short-term dermal endpoint for the technical grade active ingredient
(TGAI -- 80% ai) (20 mg/kg/day which is equivalent to 40 μg/cm^2^) was
determined from 90-day dermal toxicity in rats.No intermediate- or
long-term dermal irritation endpoints were identified for ADBAC.

.

[Inhalation Route:]{.underline}

For short- and intermediate-term inhalation exposures to ADBAC, a NOAEL
of 3 mg/kg/day was derived from a prenatal developmental toxicity study
in rabbits. The LOAEL of 9 mg/kg/day was based clinical signs of
toxicity at 9 mg/kg/day in maternal rabbits. Long-term inhalation
exposure to ADBAC (i.e., greater than 6 months) is not expected for
current registered uses. It was assumed that inhalation absorption is
equivalent to oral absorption (i.e.- 100%).

[Incidental Oral Route:]{.underline}

The short-term incidental oral risk assessment for ADBAC is based on a
NOAEL of 10 mg/kg/day, derived a prenatal developmental toxicity study
in rats. The LOAEL (100 mg/kg/day) was based decreased body weight and
food consumption.

[Level of Concern (LOC)]{.underline}

The level of concern (LOC) for occupational and residential ADBAC
dermal, inhalation, and incidental oral exposures was an MOE of less
than 100. The level of concern is based on 10x for interspecies
extrapolation, and 10x for intraspecies variation.

[Body Weight]{.underline}

Since the toxicological endpoint for inhalation is female-specific, a
body weight of 60 kilograms was used in the assessment. This value
represents the average body weight of an adult female. For calculating
dermal exposure risk, the unit was based on the treatment area (e.g.-
µg/cm2). For incidental oral assessments, 15 kilograms is used to
represent a toddler's body weight.

[Aggregation]{.underline}

The dermal and inhalation margins of exposure were not combined for the
ADBAC risk assessment because the toxicity endpoints for the dermal and
inhalation routes of exposure were based on different toxicological
effects. The incidental oral risks for hand-to-mouth, object-to-mouth,
and soil ingestion were combined, because the same endpoint is used for
each of these assessments.

[Cancer]{.underline}

No cancer endpoint was identified.

[Acute Toxicity]{.underline}

ADBAC has a low order of acute oral toxicity (Toxicity Category III and
IV), dermal toxicity (Toxicity Category III and IV), and inhalation
toxicity (Toxicity Category III and IV). However, it is severely
irritating to the skin and eyes (Toxicity Category I labeling is
routinely applied to products containing ADBAC. ADBAC is not known to be
a dermal sensitizer. The acute toxicity profile for ADBAC is presented
in Table 1.

+----------+------------------+----------+-------------------+--------+
| **       |                  |          |                   |        |
| Table 1. |                  |          |                   |        |
| Acute    |                  |          |                   |        |
| Toxicity |                  |          |                   |        |
| P        |                  |          |                   |        |
| rofile - |                  |          |                   |        |
| ADBAC**  |                  |          |                   |        |
+==========+==================+==========+===================+========+
| G        | Study Type       | MRID(s)  | Results           | To     |
| uideline |                  |          |                   | xicity |
| No.      |                  |          |                   | Ca     |
|          |                  |          |                   | tegory |
+----------+------------------+----------+-------------------+--------+
| Number   | Number range     | Number   | Number range      | Number |
| range    | CHAPTERAcute     | range    | CHAPTERLD50       | range  |
| CHAPTER  | oral, rat        | CHAPTER  | =304.5 mg/kg      | CHA    |
| 870.1100 |                  | 45109204 | (combined)        | PTERII |
|          | BQ451-8 Biocide  |          |                   |        |
|          | (Purity 82.26%)  |          | LD50 =510.9 mg/kg |        |
|          |                  |          | (males)           |        |
|          |                  |          |                   |        |
|          |                  |          | LD50 =280.8 mg/kg |        |
|          |                  |          | (females)         |        |
+----------+------------------+----------+-------------------+--------+
| 870.1200 | Acute dermal,    | 45109202 | LD50 =930 mg/kg   | III    |
|          | rat              |          | (combined)        |        |
|          |                  |          |                   |        |
|          | BQ451-8 Biocide  |          | LD50 =1100 mg/kg  |        |
|          | (Purity 82.26%)  |          | (males)           |        |
|          |                  |          |                   |        |
|          |                  |          | LD50 =704 mg/kg   |        |
|          |                  |          | (females)         |        |
+----------+------------------+----------+-------------------+--------+
| 870.1300 | Acute            | 44885201 | 0.054 \< LC50 \<  | II     |
|          | inhalation, rat  |          | 0.51 mg/L         |        |
|          |                  |          |                   |        |
|          | (Purity 82.26%)  |          |                   |        |
+----------+------------------+----------+-------------------+--------+
| 870.2400 | Primary Eye      | Waived   | N/A               | I      |
|          | Irritation       |          |                   |        |
+----------+------------------+----------+-------------------+--------+
| 870.2500 | Primary Dermal   | 45109201 | Corrosive         | I      |
|          | Irritation, ,    |          |                   |        |
|          | rabbit           |          |                   |        |
|          |                  |          |                   |        |
|          | BQ451-8 Biocide  |          |                   |        |
|          | (Purity 82.26%)  |          |                   |        |
+----------+------------------+----------+-------------------+--------+
| 870.2600 | Dermal           | 45109201 | Not a dermal      | N/A    |
|          | sensitization,   |          | sensitizer        |        |
|          | guinea pigs      |          |                   |        |
|          |                  |          |                   |        |
|          | BQ451-8 Biocide  |          |                   |        |
|          | (Purity 82.26%)  |          |                   |        |
+----------+------------------+----------+-------------------+--------+

+------------+-----------+-----------------------------+--------------+
| **TABLE 2. |           |                             |              |
| Summary of |           |                             |              |
| Tox        |           |                             |              |
| icological |           |                             |              |
| E          |           |                             |              |
| ndpoints - |           |                             |              |
| ADBAC**    |           |                             |              |
+============+===========+=============================+==============+
| **         | **Dose    | **Endpoint**                | **Study**    |
| Exposure** | Used in   |                             |              |
|            | Risk      |                             |              |
| **         | Ass       |                             |              |
| Scenario** | essment** |                             |              |
|            |           |                             |              |
|            | **(mg/    |                             |              |
|            | kg/day)** |                             |              |
+------------+-----------+-----------------------------+--------------+
| Acute      | Number    |                             |              |
| Dietary    | range     |                             |              |
|            | CHAPTERAn |                             |              |
|            | acute     |                             |              |
|            | dietary   |                             |              |
|            | endpoint  |                             |              |
|            | was not   |                             |              |
|            | i         |                             |              |
|            | dentified |                             |              |
|            | in the    |                             |              |
|            | database. |                             |              |
|            | This risk |                             |              |
|            | a         |                             |              |
|            | ssessment |                             |              |
|            | is not    |                             |              |
|            | required. |                             |              |
+------------+-----------+-----------------------------+--------------+
| Chronic    | NOAEL =44 | Decreased body weight and   | Chronic      |
| Dietary    | mg/kg/day | weight gain at 88           | toxicity/car |
|            |           | mg/kg/day.                  | cinogenicity |
|            | UF = 100  |                             | -rat         |
+------------+-----------+-----------------------------+--------------+
|            |           | > **Chronic RfD =** 0.44    |              |
|            |           | > mg/kg/day                 |              |
+------------+-----------+-----------------------------+--------------+
| Incidental | NOAEL =   | Decreased body weight and   | D            |
| Oral       | 10        | food consumption at 100     | evelopmental |
| (s         | mg/kg/day | mg/kg/day                   | Toxicity -   |
| hort-term) |           |                             | Rat          |
|            | MOE = 100 |                             |              |
+------------+-----------+-----------------------------+--------------+
| Incidental | NOAEL =   | Decreased body weight and   | Chronic      |
| Oral       | 44        | weight gain at 88 mg/kg/day | to           |
| (intermed  | mg/kg/day |                             | xicity/carci |
| iate-term) |           |                             | nogenicity - |
|            | MOE = 100 |                             | rat          |
+------------+-----------+-----------------------------+--------------+
| Short-Term | NOAEL=    | Denuded non-vascularized    | 21-day       |
|            | 500       | epidermal layer observed at | dermal       |
| Dermal-**  | mg/kg/day | 1000 mg/kg/day.             | toxicity-    |
| formulated |           |                             | guinea pigs  |
| product**  | (7750     |                             | (MRID        |
|            | µg/       |                             | 41105801)    |
|            | cm^2^)^a^ |                             |              |
|            |           |                             |              |
|            | MOE = 100 |                             |              |
+------------+-----------+-----------------------------+--------------+
| Short-term | NOAEL =   | 20 mg/kg/day is the highest | 90-day       |
| dermal     | 20        | dose tested before          | dermal       |
| *          | mg/kg/day | irritation became           | toxicity in  |
| *technical |           | significant.                | rats (MRID   |
| grade      | (40       |                             | 41499601)    |
| a.i.**     | µg/       |                             |              |
|            | cm^2^)^b^ |                             |              |
|            |           |                             |              |
|            | MOE = 100 |                             |              |
+------------+-----------+-----------------------------+--------------+
| Interme    | No        |                             |              |
| diate-Term | ap        |                             |              |
|            | propriate |                             |              |
| (Dermal)   | endpoint  |                             |              |
|            | id        |                             |              |
|            | entified. |                             |              |
|            | No        |                             |              |
|            | systemic  |                             |              |
|            | effects   |                             |              |
|            | observed  |                             |              |
|            | up to 20  |                             |              |
|            | m         |                             |              |
|            | g/kg/day, |                             |              |
|            | highest   |                             |              |
|            | dose of   |                             |              |
|            | technical |                             |              |
|            | grade     |                             |              |
|            | that      |                             |              |
|            | could be  |                             |              |
|            | tested    |                             |              |
|            | without   |                             |              |
|            | i         |                             |              |
|            | rritation |                             |              |
|            | effects.  |                             |              |
+------------+-----------+-----------------------------+--------------+
| Long-Term  | No        |                             |              |
| (Dermal)   | ap        |                             |              |
|            | propriate |                             |              |
|            | endpoint  |                             |              |
|            | id        |                             |              |
|            | entified. |                             |              |
|            | No        |                             |              |
|            | systemic  |                             |              |
|            | effects   |                             |              |
|            | observed  |                             |              |
|            | up to 20  |                             |              |
|            | m         |                             |              |
|            | g/kg/day, |                             |              |
|            | highest   |                             |              |
|            | dose of   |                             |              |
|            | technical |                             |              |
|            | grade     |                             |              |
|            | that      |                             |              |
|            | could be  |                             |              |
|            | tested    |                             |              |
|            | without   |                             |              |
|            | i         |                             |              |
|            | rritation |                             |              |
|            | effects.  |                             |              |
+------------+-----------+-----------------------------+--------------+
| Inh        | NOAEL= 3  | Clinical signs of toxicity  | D            |
| alation^a^ | mg/kg/day | at 9 mg/kg/day in maternal  | evelopmental |
|            |           | rabbits. (10x inter-species | toxicity -   |
| (All       | MOE = 100 | extrapolation, 10x          | rabbit       |
| exposure   |           | intra-species variation)^c^ |              |
| durations) |           |                             |              |
+------------+-----------+-----------------------------+--------------+

> a Formulated-based dermal endpoint = (500 mg/kg guinea pig x 0.4 kg
> guinea pig x 1000 ug/mg) / 25.8 cm^2^ treated area = 7,750 µg/cm^2^ .
>
> b TGAI-based dermal endpoint = (20 mg/kg rat x 0.2 kg rat x 1000
> ug/mg) / 100 cm^2^ treated area = 40 µg/cm^2^ .

^C^ an additional uncertainty factor of 10x is used for route
extrapolation from an oral endpoint.

[]{#__RefHeading___Toc128276203 .anchor}**1.4 Incident Reports**

> Number range CHAPTERThe incident report is being prepared under a
> separate memo by Jonathan Chen, of the Office of Pesticide Programs.

[]{#__RefHeading___Toc128276204 .anchor}**1.5 Summary of Use Patterns
and Formulations**

[]{#__RefHeading___Toc128276205 .anchor}**1.5.1 End-Use Products**

ADBAC (Group II Quat Cluster) is a group of structurally similar
quaternary ammonium compounds ("quats"). It is used in agricultural,
commercial, and residential settings. ADBAC is formulated as a soluble
concentrate, emulsifiable concentrate, ready-to-use solution,
pressurized liquid, wettable powder, water soluble packet, flowable
concentrate, microencapsulated and impregnated material. Note that there
are many end-use products that contain ADBAC and each label could not be
reviewed to determine the formulation-type and the registered uses. Also
note that the Master Label does not indicate the formulation types that
were registered for individual use-patterns. Therefore, as a
conservative approach, this chapter will assume that ADBAC when used to
control plant diseases may be formulated as a liquid concentrate, a dry
flowable, and a wettable powder. For mosquito control, it is assume that
it is formulated as a liquid concentrate only, since it is designed to
be poured into the water to be treated.

[]{#__RefHeading___Toc128276206 .anchor}**1.5.2 Registered Use
Categories and Sites**

An analysis of the current labeling and available use information was
completed by the Antimicrobial Division. ADBAC is registered for use in
a variety of occupational and residential scenarios and thus both
occupational and residential populations could be potentially exposed
while performing ADBAC applications. It is also possible for
occupational and residential populations to be exposed to ADBAC during
postapplication scenarios. Tables 3a and 3b provide a summary of the
maximum application rates, equipment, and amounts handled daily for
registered ADBAC uses.

+-------------+----------+------------+------------------+------------+
| **Table 3a: |          |            |                  |            |
| O           |          |            |                  |            |
| ccupational |          |            |                  |            |
| Uses of     |          |            |                  |            |
| ADBAC**     |          |            |                  |            |
+=============+==========+============+==================+============+
| **Target**  | **For    | **A        | **Application    | **Area     |
|             | mulation | pplication | Equipment**      | Treated or |
|             | Type**   | Rate**     |                  | Amount     |
|             |          |            |                  | Applied**  |
+-------------+----------+------------+------------------+------------+
| Sodfarm     | LC, WP,  | 0.9 lb     | Groundboom       | 80 acres   |
| turf        | DF       | ai/A       |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          | 7 lb ai/A  | Low pressure     | 5 acres    |
|             |          |            | handwand         |            |
|             |          |            | sprayer, Handgun |            |
|             |          |            | sprayer          |            |
+-------------+----------+------------+------------------+------------+
| Golf        | LC, WP,  | 0.9 lb     | Groundboom       | 80 acres   |
| Course,     | DF       | ai/A       |                  |            |
| R           |          |            |                  |            |
| esidential, |          |            |                  |            |
| and         |          |            |                  |            |
| Commercial  |          |            |                  |            |
| Turf        |          |            |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          | 0.0065 lb  | Low pressure     | 40 gallons |
|             |          | ai/A &     | handwand         |            |
|             |          |            | sprayer,         |            |
|             |          | 7 lb ai/A  |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | Handgun sprayer  | 5 acres    |
+-------------+----------+------------+------------------+------------+
| Ornamental  | LC, WP,  | 0.0065 lb  | Handgun sprayer  | 5 acres    |
| herbaceous  | DF       | ai/gal &   |                  |            |
| plants      |          | (assume    |                  |            |
|             |          | 0.65 lb    |                  |            |
|             |          | ai/A)      |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | Low-pressure     | 40 gallons |
|             |          |            | handwand sprayer |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | High-pressure    | 1000       |
|             |          |            | handwand sprayer | gallons    |
+-------------+----------+------------+------------------+------------+
|             |          | 0.0065 lb  | Low-pressure     | 40 gallons |
|             |          | ai/gal &   | handwand,        |            |
|             |          | 72 lb ai/A |                  |            |
|             |          | (drench)   |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | Handgun          | 5 acres    |
+-------------+----------+------------+------------------+------------+
|             |          |            | Groundboom       | 20 acres   |
+-------------+----------+------------+------------------+------------+
|             |          | 0.0065 lb  | Dip or Soak      | 100        |
|             |          | ai/gal     |                  | gallons    |
+-------------+----------+------------+------------------+------------+
| Ornamental  | LC, WP,  | 0.0043 lb  | Trigger pump     | 1 gallon   |
| Shrubs      | DF       | ai/gal     | sprayer          |            |
|             |          |            |                  |            |
|             |          | (assume    |                  |            |
|             |          | 0.43 lb    |                  |            |
|             |          | ai/A)      |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | Low-pressure     | 40 gallons |
|             |          |            | handwand sprayer |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | Handgun sprayer, | 1000       |
|             |          |            | High-pressure    | gallons    |
|             |          |            | handwand sprayer |            |
+-------------+----------+------------+------------------+------------+
| Ornamental  | LC, WP,  | 0.0065 lb  | Low-pressure     | 40 gallons |
| Trees       | DF       | ai/gal     | handwand sprayer |            |
|             |          |            |                  |            |
|             |          | (assume    |                  |            |
|             |          | 0.65 lb    |                  |            |
|             |          | ai/A)      |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | Handgun sprayer, | 5 acres    |
+-------------+----------+------------+------------------+------------+
|             |          |            | High-pressure    | 1000       |
|             |          |            | handwand sprayer | gallons    |
+-------------+----------+------------+------------------+------------+
|             |          |            | Airblast sprayer | 20 acres   |
+-------------+----------+------------+------------------+------------+
| Seedlings   | LC, WP,  | 0.0043 lb  | Low-pressure     | 40 gallons |
| (planted in | DF       | ai/gal     | handwand sprayer |            |
| field)      |          |            |                  |            |
|             |          | (assume    |                  |            |
|             |          | 0.43 lb    |                  |            |
|             |          | ai/A)      |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | Handgun sprayer  | 5 acres    |
+-------------+----------+------------+------------------+------------+
|             |          |            | Groundboom       | 20 acres   |
+-------------+----------+------------+------------------+------------+
| Seedlings,  | LC, WP,  | 0.0043 lb  | Low-pressure     | 40 gallons |
| Seeds,      | DF       | ai/gal     | handwand sprayer |            |
| Cuttings    |          |            |                  |            |
| (preplant   |          |            |                  |            |
| or at       |          |            |                  |            |
| plant)      |          |            |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | Dip or Soak      | 100        |
|             |          |            |                  | gallons    |
+-------------+----------+------------+------------------+------------+
|             |          |            | Sprinkling can   | 5 gallons  |
+-------------+----------+------------+------------------+------------+
|             |          |            | Trigger-pump     | 1 gallons  |
|             |          |            | sprayer          |            |
+-------------+----------+------------+------------------+------------+
| Ornamental  | LC, WP,  | 0.013 lb   | Sprinkling can   | 5 gallons  |
| Palms       | DF       | ai/gal     |                  |            |
+-------------+----------+------------+------------------+------------+
| Carnations  | LC, WP,  | 0.0235 lb  | Low-pressure     | 40 gallons |
|             | DF       | ai/gal &   | handwand,        |            |
| (drench)    |          | 256 lb     |                  |            |
|             |          | ai/A       |                  |            |
|             |          | (drench)   |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | Handgun          | 5 acres    |
+-------------+----------+------------+------------------+------------+
|             |          |            | Groundboom       | 20 acres   |
+-------------+----------+------------+------------------+------------+
| Mosquito    | LC       | 0.0017 lb  | Sprinkling can   | 5 gallons  |
| control in  |          | ai/gal of  |                  | of end-use |
| fountains,  |          | water to   |                  | product    |
| water       |          | be         |                  | (20% ai)   |
| displays,   |          | treated;   |                  |            |
| decorative  |          |            |                  |            |
| pools,      |          | Pools =    |                  |            |
| decorative  |          | 20,000 gal |                  |            |
| ponds,      |          |            |                  |            |
| sewage      |          | Hot tubs   |                  |            |
| treatment   |          | =1000 gal  |                  |            |
| systems,    |          |            |                  |            |
| spas, hot   |          |            |                  |            |
| tubs,       |          |            |                  |            |
| swimming    |          |            |                  |            |
| pools and   |          |            |                  |            |
| standing    |          |            |                  |            |
| water       |          |            |                  |            |
+-------------+----------+------------+------------------+------------+
|             |          |            | Handgun sprayer  | 1000       |
|             |          |            |                  | gallons of |
|             |          |            |                  | end-use    |
|             |          |            |                  | product    |
|             |          |            |                  | (20% ai)   |
+-------------+----------+------------+------------------+------------+
|             |          |            | Boom sprayer     | 800,000    |
|             |          |            | over pond        | gallons    |
|             |          |            | (groundboom      |            |
|             |          |            | sprayer as       | 100,000    |
|             |          |            | surrogate)       | gallons    |
|             |          |            |                  | and 20,000 |
|             |          |            |                  | gallons    |
+-------------+----------+------------+------------------+------------+

LC = liquid concentrate, WP = wettable powder , DF = dry flowable.

+--------------+---------+-------------+-----------------+-----------+
| **Table 3b:  |         |             |                 |           |
| Residential  |         |             |                 |           |
| Uses of      |         |             |                 |           |
| ADBAC**      |         |             |                 |           |
+==============+=========+=============+=================+===========+
| Target       | Form    | Application | Application     | Area      |
|              | ulation | Rate        | Equipment       | Treated   |
|              | Type    |             |                 | or Amount |
|              |         |             |                 | Applied   |
+--------------+---------+-------------+-----------------+-----------+
| Residential  | LC, WP, | 0.0065 lb   | Low pressure    | 5 gallons |
| Turf         | DF      | ai/gal &    | handwand        |           |
|              |         |             | sprayer         |           |
|              |         | 7 lb ai/A   |                 |           |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Hose-end        | 0.5 acres |
|              |         |             | sprayer         |           |
+--------------+---------+-------------+-----------------+-----------+
| Ornamental   | LC, WP, | 0.0065 lb   | Low pressure    | 5 gallons |
| Bulbs &      | DF      | ai/gal &    | handwand        |           |
| Orchids      |         | (assume     | sprayer         |           |
|              |         | 0.43 lb     |                 |           |
|              |         | ai/A)       |                 |           |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Dip or Soak     | 5 gallons |
+--------------+---------+-------------+-----------------+-----------+
| Ornamental   | LC, WP, | 0.0043 lb   | Low pressure    | 5 gallons |
| Herbaceous   | DF      | ai/gal &    | handwand        |           |
| Plants       |         | (assume     | sprayer         |           |
|              |         | 0.43 lb     |                 |           |
|              |         | ai/A)       |                 |           |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Hose-end        | ¼ acre    |
|              |         |             | sprayer         |           |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Dip or Soak     | 5 gallons |
+--------------+---------+-------------+-----------------+-----------+
| Ornamental   | LC, WP, | 0.0043 lb   | Trigger pump    | 1 gallon  |
| Shrubs       | DF      | ai/gal      | sprayer         |           |
|              |         |             |                 |           |
|              |         | (assume     |                 |           |
|              |         | 0.43 lb     |                 |           |
|              |         | ai/A)       |                 |           |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Low-pressure    | 5 gallons |
|              |         |             | handwand        |           |
|              |         |             | sprayer         |           |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Hose-end        | ¼ acre    |
|              |         |             | sprayer         |           |
+--------------+---------+-------------+-----------------+-----------+
| Ornamental   | LC, WP, | 0.0043 lb   | Low-pressure    | 5 gallons |
| Trees        | DF      | ai/gal      | handwand        |           |
|              |         |             | sprayer         |           |
|              |         | (assume     |                 |           |
|              |         | 0.43 lb     |                 |           |
|              |         | ai/A)       |                 |           |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Hose-end        | ¼ acre    |
|              |         |             | sprayer         |           |
+--------------+---------+-------------+-----------------+-----------+
| Seedlings    | LC, WP, | 0.0043 lb   | Low-pressure    | 5 gallons |
| (planted in  | DF      | ai/gal      | handwand        |           |
| garden)      |         |             | sprayer         |           |
|              |         | (assume     |                 |           |
|              |         | 0.43 lb     |                 |           |
|              |         | ai/A)       |                 |           |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Hose-end        | ¼ acre    |
|              |         |             | sprayer         |           |
+--------------+---------+-------------+-----------------+-----------+
| Seedlings,   | LC, WP, | 0.0043 lb   | Low-pressure    | 5 gallons |
| Seeds,       | DF      | ai/gal      | handwand        |           |
| Cuttings     |         |             | sprayer         |           |
| (preplant or |         |             |                 |           |
| at plant)    |         |             |                 |           |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Dip or Soak     | 5 gallons |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Sprinkling can  | 5 gallons |
+--------------+---------+-------------+-----------------+-----------+
|              |         |             | Trigger-pump    | 1 gallons |
|              |         |             | sprayer         |           |
+--------------+---------+-------------+-----------------+-----------+
| Ornamental   | LC, WP, | 0.013 lb    | Sprinkling can  | 5 gallons |
| Palms        | DF      | ai/gal      |                 |           |
+--------------+---------+-------------+-----------------+-----------+
| Mosquito     | LC      | 0.0017 lb   | Sprinkling can  | 5 gallons |
| control in   |         | ai/gal of   |                 | of        |
| fountains,   |         | water to be |                 | end-use   |
| water        |         | treated;    |                 | product   |
| displays,    |         |             |                 | (20% ai)  |
| decorative   |         | Pools =     |                 |           |
| pools,       |         | 20,000 gal  |                 |           |
| decorative   |         |             |                 |           |
| ponds,       |         | Hot tubs    |                 |           |
| sewage       |         | =1000 gal   |                 |           |
| treatment    |         |             |                 |           |
| systems,     |         |             |                 |           |
| spas, hot    |         |             |                 |           |
| tubs,        |         |             |                 |           |
| swimming     |         |             |                 |           |
| pools and    |         |             |                 |           |
| standing     |         |             |                 |           |
| water        |         |             |                 |           |
+--------------+---------+-------------+-----------------+-----------+

LC = liquid concentrate, WP = wettable powder , DF = dry flowable.

[]{#__RefHeading___Toc128276207 .anchor}**1.5.3 Application Methods**

ADBAC is applied with several types of application equipment including
groundboom sprayers, airblast sprayers, low-pressure and high-pressure
handwand sprayers, handgun sprayers, hose-end sprayers, watering cans,
pump-trigger sprayers, and by dipping or soaking plants or plant parts.

[]{#__RefHeading___Toc128276208 .anchor}**2.0 Occupational Exposures and
Risks**

There is a potential for exposure to ADBAC in occupational scenarios
from handling ADBAC products during the application process (i.e.,
mixer/loaders, applicators, and mixer/ loader/applicators) and a
potential for postapplication worker exposure from entering into areas
previously treated with ADBAC. As a result, exposure scenarios have been
completed for occupational handler scenarios as well as occupational
postapplication scenarios.

[]{#__RefHeading___Toc128276209 .anchor}**2.1 Occupational Handler
Exposures and Risks**

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

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

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

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

-   Mixer/Loader/Applicators and or Loader/Applicators: These
    individuals are involved in the entire pesticide application process
    (i.e., they do all job functions related to a pesticide application
    event). These individuals would transfer ADBAC into the application
    equipment and then also apply it.

A chemical can produce different effects based on how long a person is
exposed, how frequently exposures occur, and the level of exposure. The
Agency classifies exposures up to 30 days as short-term and exposures
greater than 30 days up to several months as intermediate-term. The
Agency completes both short- and intermediate-term assessments for
occupational scenarios in essentially all cases, because these kinds of
exposures are likely and acceptable use/usage data are not available to
justify deleting intermediate-term scenarios. Based on use data and
label instructions, the Agency believes that occupational ADBAC
exposures may occur over a single day or up to weeks at a time for many
use-patterns and that intermittent exposure over several weeks also may
occur. Some applicators may apply ADBAC over a period of weeks, because
they are custom or commercial applicators who are completing a number of
applications for a number of different clients. Long-term handler
exposures are not expected to occur for ADBAC.

Other parameters are also defined from use and usage data such as
application rates and application frequency. The Agency typically
completes exposure assessments using maximum application rates for each
scenario to ensure there are no concerns for each specific use.

Occupational handler exposure assessments are completed by the Agency
using different levels of risk mitigation. Typically, the Agency uses a
tiered approach. The lowest tier is designated as the baseline exposure
scenario (i.e., no respirator). If risks are of concern at baseline
attire, then increasing levels of personal protective equipment or PPE
(e.g., respirators) are evaluated. If risks remain of concern with
maximum PPE, then engineering controls (e.g., enclosed cabs,
water-soluble packaging, and closed mixing/loading systems) are
evaluated. This approach is used to ensure that the lowest level of risk
mitigation that provides adequate protection is selected, since the
addition of PPE and engineering controls involves an additional expense
to the user and B in the case of PPE B also involves an additional
burden to the user due to decreased comfort and dexterity and increased
heat stress and respiratory stress.

[]{#__RefHeading___Toc128276210 .anchor}**2.1.1 Data and Assumptions for
Handler Exposure Scenarios**

[]{#__RefHeading___Toc128276211 .anchor}**2.1.1.1 Assumptions for
Handler Exposure Scenarios**

A series of assumptions and exposure factors served as the basis for
completing the occupational handler risk assessments. Each assumption
and factor is detailed below on an individual basis. The assumptions and
factors used in the risk calculations include:

-   Occupational handler exposure estimates were based on surrogate data
    from: (1) the Pesticide Handlers Exposure Database (PHED) and (2)
    the Outdoor Residential Exposure Task Force (ORETF).

-   The toxicological endpoint of concern for dermal risks is from a
    dermal study; with the effects being irritation (no systemic effects
    were observed). Therefore, no dose is calculated and no body weight
    is used to complete the dermal exposure assessment. The
    toxicological endpoint of concern for inhalation risks is from a
    prenatal developmental toxicity study; with the effects seen in
    females; therefore, the average body weight of an adult female
    (i.e., 60 kg) is used to complete the inhalation risk assessment.

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

-   Exposure factors used to calculate daily exposures to handlers are
    based on applicable data, if available. For lack of appropriate
    data, values from a scenario deemed similar enough by the assessor
    might be used. For example, ORETF data for hose-end sprayers is used
    as a surrogate for inhalation unit exposures for
    mixing/loading/applying with a sprinkling can.

-   The Agency typically assumes the maximum application rates allowed
    by labels in its risk assessments (see Table 3a/b).

-   The average occupational workday is assumed to be 8 hours.

-   The daily areas treated were defined for each handler scenario (in
    appropriate units) by determining the amount that can be reasonably
    treated in a single day (e.g., acres or gallons per day). When
    possible, the assumptions for daily areas treated are taken from the
    Health Effects Division Science Advisory Committee on Exposure SOP
    #9: Standard Values for Daily Acres Treated in Agriculture, which
    was completed on July 5, 2000. However, no standard values are
    available for numerous scenarios. Assumptions for these scenarios
    are based on the Agency estimates and could be further refined from
    input from affected sectors.

-   For mosquito larvae uses in standing water, application rates are
    provided on the label only in terms of pounds active ingredient per
    gallon of water to be treated. The Agency has no specific
    information about the gallons of water likely in a decorative pond
    or sewage treatment system. Risks were assessed based on a
    rangefinder of gallons of treated water that might be applied per
    day. The rangefinder includes: 800,000 gallons, 100,000 gallons, and
    20,000 gallons.

There are data gaps that have been identified for some ADBAC
applications. Each is identified in the calculation tables and is also
noted in the summary of risk calculations.

[]{#__RefHeading___Toc128276212 .anchor}**2.1.1.2 Exposure Data for
Handler Exposure Scenarios**

The Agency uses unit exposure to assess handler exposures to pesticides.
Unit exposures are estimates of the amount of exposure to an active
ingredient a handler receives while performing various handler tasks and
are expressed in terms of micrograms or milligrams of active ingredient
per pounds of active ingredient handled. The Agency has developed a
series of unit exposures that are unique for each scenario typically
considered in our assessments (i.e., there are different unit exposures
for different types of application equipment, job functions, and levels
of protection). The unit exposure concept has been established in the
scientific literature and also through various exposure monitoring
guidelines published by the U.S. EPA and international organizations
such as Health Canada and OECD (Organization for Economic Cooperation
and Development).

Unit exposures values have been taken from both the Pesticide Handler
Exposure Database (PHED) and studies provided by the Outdoor Residential
Exposure Task Force (ORETF) where the scenario unit exposure values are
more applicable. Appendix A contains background information on PHED and
ORETF.

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

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

A report was submitted by the ORETF (Outdoor Residential Exposure Task
Force) that presented data in which the application of various products
used on turf by homeowners and lawncare operators (LCOs) was monitored.
All of the data submitted in this report were completed in a series of
studies. ORETF conducted a mixer/loader/applicator study applying a
pesticide to turf with a low pressure handgun sprayer. The unit
exposures relevant to the residential assessment are summarized below in
Table 4.The unit exposures relevant to the residential assessment from
the LCO exposure scenarios using a low pressure, high volume turf
handgun (ORETF Study OMA002) are summarized below (Table 5) as is the
study (ORETF Study OMA004) that monitored homeowner exposures while
using a hose-end sprayer (Table 6).

+-----------------------------------+----------------------------------+
| **Table 4: Unit Exposure Values   |                                  |
| Obtained for LCO Liquid           |                                  |
| Applications with a Low Pressure  |                                  |
| Handgun from ORETF Handgun        |                                  |
| Studies (MRID 449722-01)**        |                                  |
+===================================+==================================+
| Application Method^3^             | Inhalation Unit Exposure^1,2^    |
|                                   | (g/lb ai)                       |
+-----------------------------------+----------------------------------+
| LCO Handgun Spray                 | 1.5                              |
| Mixer/Loader/Applicator           |                                  |
|                                   |                                  |
| Liquid Flowable                   |                                  |
+-----------------------------------+----------------------------------+
| LCO Handgun Spray                 | 22                               |
| Mixer/Loader/Applicator Water     |                                  |
| Dispersable Granule               |                                  |
+-----------------------------------+----------------------------------+
| LCO Handgun Spray                 | 7.2                              |
| Mixer/Loader/Applicator           |                                  |
|                                   |                                  |
| Wettable Powder in Water Soluble  |                                  |
| Bags                              |                                  |
+-----------------------------------+----------------------------------+
| LCO Handgun Spray                 | 64                               |
| Mixer/Loader/Applicator           |                                  |
|                                   |                                  |
| Wettable Powder                   |                                  |
+-----------------------------------+----------------------------------+
| LCO Handgun Spray Applicator Only | 1.0                              |
|                                   |                                  |
| Wettable Powder                   |                                  |
+-----------------------------------+----------------------------------+

^1^ Unit exposure values reported are geometric means.

^2^ Air concentrations (mg/m^3^/lb ai) calculated using NAFTA \>99
standard breathing rate of 17 lpm (1 m^3^/hr).

^3^ All commercial handlers wore long pants, long-sleeved shirt, nitrile
gloves and shoes.

+--------------------------+-------------------------------------------+
| **Table 5. Unit Exposure |                                           |
| Values for Homeowner     |                                           |
| Liquid Applications with |                                           |
| a Ready-to-use Hose-end  |                                           |
| Sprayer and a Dial Type  |                                           |
| Hose-end Sprayer         |                                           |
| Obtained From ORETF      |                                           |
| Study (MRID 449722-01**) |                                           |
+==========================+===========================================+
| Scenario Monitored       | Inhalation Unit Exposure^1,2^             |
|                          |                                           |
|                          | (g/lb ai)                                |
+--------------------------+-------------------------------------------+
| Homeowner Liquid         | 11                                        |
| Applications with a      |                                           |
| Ready-to-use Hose-end    |                                           |
| Sprayer                  |                                           |
+--------------------------+-------------------------------------------+
| Homeowner Liquid         | 17                                        |
| Applications with a Dial |                                           |
| Type Hose-end Sprayer    |                                           |
| (Mix-your-own)           |                                           |
+--------------------------+-------------------------------------------+

^1^ Unit exposure values reported are geometric means.

^2^ Air concentrations (mg/m^3^/lb ai) calculated using NAFTA 99
standard breathing rate of 17 lpm (1 m^3^/hr).

+-----------------------------+----------------------------------------+
| **Table 6. Unit Exposure    |                                        |
| Values for Homeowner Liquid |                                        |
| Application to Garden with  |                                        |
| a Dial type Sprayer, a Low  |                                        |
| Pressure Handwand and a     |                                        |
| Ready-to-use Bottle         |                                        |
| Obtained From ORETF Study   |                                        |
| (MRID 444598-01)**          |                                        |
+=============================+========================================+
| Scenario Monitored          | Inhalation Unit Exposure^1^            |
|                             |                                        |
|                             | (g/lb ai)                             |
+-----------------------------+----------------------------------------+
| Homeowner Liquid            | 2.7                                    |
| Applications with a Low     |                                        |
| Pressure Handwand Sprayer   |                                        |
+-----------------------------+----------------------------------------+
| Homeowner Liquid            | 19                                     |
| Applications with a         |                                        |
| Ready-to-Use Sprayer        |                                        |
+-----------------------------+----------------------------------------+
| Homeowner Liquid            | 0.82                                   |
| Applications with a         |                                        |
| Hose-end Sprayer            |                                        |
+-----------------------------+----------------------------------------+

^1^ Unit exposure values reported are geometric means.

[]{#__RefHeading___Toc128276213 .anchor}**2.1.1.3 ADBAC Handler Exposure
Scenarios**

It has been determined that exposure to pesticide handlers is likely
during the occupational use of ADBAC in a variety of occupational
environments. The anticipated use patterns and current labeling indicate
several occupational exposure scenarios based on the types of equipment
and techniques that can potentially be used for ADBAC applications.

ADBAC inhalation exposure was estimated using PHED or ORETF data. Risks
were calculated by comparing the inhalation dose to the short- and
intermediate-term NOAEL to determine the margin of exposure (MOE).

ADBAC dermal exposures and risks were not estimated for occupational
handler exposures. Instead, dermal exposures and risks will be mitigated
using default personal protective equipment requirements based on the
toxicity of the end-use product. To minimize dermal exposures, the
minimum PPE required for mixers, loaders, and others exposed to end-use
products containing concentrations of ADBAC that result in
classification of category I or II for skin irritation potential will be
long-sleeve shirt, long pants, shoes, socks, chemical-resistant gloves,
and chemical-resistant apron. The minimum PPE required for mixers,
loaders, and others exposed to end-use products containing
concentrations of ADBAC that result in classification of category III
for skin irritation potential will be long-sleeve shirt, long pants,
shoes, socks, and chemical-resistant gloves. Once diluted, if the
concentration of ADBAC in the diluted solution would result in
classification of toxicity category IV for skin irritation potential,
then the chemical-resistant gloves and chemical-resistant apron can be
eliminated for applicators and others exposed to the dilute. Note that
chemical-resistant eye protection will be required if the end-use
product is classified as category I or II for eye irritation potential.

The quantitative inhalation exposure and risk assessment developed for
occupational handlers is based on the following scenarios. \[Note: The
scenario numbers correspond to the tables of risk calculations included
in the occupational risk calculation aspects of the appendices.\]

**[Mixer/Loader/Applicators:]{.underline}**

-   Mixing/Loading Liquids Concentrates for Groundboom Applications
    (PHED) (1a)

-   Mixing/Loading Liquid Concentrates to Support LCO Handgun
    Applications (mixing/loading supports 20 LCOs) (PHED) (1b)

-   Mixing/Loading Liquids Concentrates for Airblast Applications (PHED)
    (1c)

-   Mixing/Loading Liquid Concentrates via Dip or Soak (PHED) (1d)

-   Mixing/Loading Wettable Powders for Groundboom Applications (PHED)
    (2a)

-   Mixing/Loading Wettable Powders Support LCO Handgun Applications
    (mixing/loading supports 20 LCOs) (PHED) (2b)

-   Mixing/Loading Wettable Powders for Airblast Applications (PHED)
    (2c)

-   Mixing/Loading Wettable Powders via Dip or Soak (PHED) (2d)

-   Mixing/Loading Dry Flowables for Groundboom Applications (PHED) (3a)

-   Mixing/Loading Dry Flowables for Airblast Applications (PHED) (3b)

-   Mixing/Loading Dry Flowables to Support LCO Handgun Applications
    (mixing/loading supports 20 LCOs) (PHED) (3c)

-   Mixing/Loading Dry Flowables via Dip or Soak (PHED) (3d)

-   Applying Sprays via Groundboom Equipment (PHED) (4)

-   Applying Sprays via Airblast Equipment (PHED) (5)

-   Applying Sprays via Handgun Equipment (PHED) (6)

-   Applying as a Soak or Dip (no data) (7)

-   Mixing/Loading/Applying Liquid Concentrates with Low Pressure
    Handwand (ORETF data) (8)

-   Mixing/Loading/Applying Wettable Powders with Low Pressure Handwand
    (PHED data) (9)

-   Mixing/Loading/Applying Dry Flowables with Low Pressure Handwand
    (using liquid concentrate ORETF data) (10)

-   Mixing/Loading/Applying Liquid Concentrates with a Handgun Sprayer
    (LCO ORETF data) (11)

-   Mixing/Loading/Applying Wettable Powders with a Handgun Sprayer (LCO
    ORETF data) (12)

-   Mixing/Loading/Applying Water Soluble Bags with Handgun Sprayer (LCO
    ORETF data) (13)

-   Mixing/Loading/Applying Dry Flowables Concentrates with a Handgun
    Sprayer (LCO ORETF data) (14)

-   Mixing/Loading/Applying Liquid Concentrates with a High Pressure
    Handwand (PHED) (15)

-   Applying Ready to Use Formulations via Trigger-Pump Sprayer (ORETF)
    (16)

-   Mixing/Loading/Applying Liquids with a Watering Can (using ORETF
    residential hose-end data) (17)

-   Mixing/Loading/Applying Dip or Soak (no data) (18)

    []{#__RefHeading___Toc128276214 .anchor}**2.1.2 ADBAC Handler
    Exposure and Assessment**

    []{#__RefHeading___Toc128276215 .anchor}**2.1.2.1 ADBAC Handler
    Exposure and Risk Calculations**

Handler risks (i.e. MOEs) were calculated as described in Appendix A.
The basic rationale for these calculations is that the daily exposure is
the product of the amount of ai handled per day times a unit exposure
value. The MOEs were calculated for short/intermediate term dermal and
inhalation exposures. These MOEs were calculated separately because the
dermal and inhalation endpoints were based upon different effects. A MOE
greater than 100 indicates the risk is not of concern for that scenario.

[]{#__RefHeading___Toc128276216 .anchor}**2.1.2.2 ADBAC Risk Summary**

The short- and intermediate-term risks for each inhalation exposure
scenario are presented in Table 7 and details are presented in Appendix
B.

**[Short- and Intermediate-term Inhalation Risks]{.underline}**

In all occupational handler scenarios, inhalation MOEs are above the
level of concern of 100 at baseline (i.e., no respirator), except for
those identified in Section 2.1.4.1. In the case that the MOE is below
1000, the Agency may request a confirmatory inhalation toxicity study
inhalation toxicity study according to AD's policy (oral communication
from Tim Leighton).

> **[Short- and Intermediate-term Total Risks]{.underline}**

Since no dermal endpoint for systemic toxicological effects was
selected, no dermal doses were estimated. Therefore, no combined dermal
and inhalation risks were calculated.

+-----------------+-----------+-------+-------+-------+-------+-------+
| **TABLE 7.      |           |       |       |       |       |       |
| ADBAC:          |           |       |       |       |       |       |
| Occupational    |           |       |       |       |       |       |
| Handler         |           |       |       |       |       |       |
| Inhalation      |           |       |       |       |       |       |
| Risks**         |           |       |       |       |       |       |
+=================+===========+=======+=======+=======+=======+=======+
| **Exposure      | **Crop or | **A   | *     | **    |       |       |
| Scenario**      | Target**  | pplic | *Area | Inhal |       |       |
|                 |           | ation | Tr    | ation |       |       |
|                 |           | Rate  | eated | MOEs  |       |       |
|                 |           | ^a^** | Daily | ^c^** |       |       |
|                 |           |       | ^b^** |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 |           |       |       | **    | **80% | **Eng |
|                 |           |       |       | Basel | PP    | C     |
|                 |           |       |       | ine** | E-R** | ont** |
+-----------------+-----------+-------+-------+-------+-------+-------+
| *               |           |       |       |       |       |       |
| *Mixer/Loader** |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| Mixing/Loading  | C         | 256   | 20    | *     | 150   | 420   |
| (M/L) Liquids   | arnations | lb    | acres | *29** |       |       |
| for Groundboom  | (drench)  | ai    |       |       |       |       |
| Applications    |           | /acre |       |       |       |       |
| (1a)            |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 72 lb | 20    | 100   | 520   | 1,500 |
|                 | rnamental | ai    | acres |       |       |       |
|                 | H         | /acre |       |       |       |       |
|                 | erbaceous |       |       |       |       |       |
|                 | Plants    |       |       |       |       |       |
|                 | (drench)  |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Sodfarm   | 0.9   | 80    | 2,100 | 1     | 3     |
|                 | Turf      | lb    | acres |       | 0,000 | 0,000 |
|                 |           | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Seedlings | 0.43  | 20    | 1     | 8     | 25    |
|                 | (planted  | lb    | acres | 7,000 | 7,000 | 0,000 |
|                 | in field) | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Mosquito  | 0     | 80    | 110   | 550   | 1,600 |
|                 | Control   | .0017 | 0,000 |       |       |       |
|                 | in        | lb    | ga    |       |       |       |
|                 | D         | a     | llons |       |       |       |
|                 | ecorative | i/gal | of    |       |       |       |
|                 | Ponds,    | of    | water |       |       |       |
|                 | Sewage    | water |       |       |       |       |
|                 | Treatment | to be |       |       |       |       |
|                 | Systems,  | tr    |       |       |       |       |
|                 | and       | eated |       |       |       |       |
|                 | Standing  |       |       |       |       |       |
|                 | Water     |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Mosquito  | 0     | 10    | 880   | 4,400 | 1     |
|                 | Control   | .0017 | 0,000 |       |       | 3,000 |
|                 | in        | lb    | ga    |       |       |       |
|                 | D         | a     | llons |       |       |       |
|                 | ecorative | i/gal | of    |       |       |       |
|                 | Ponds,    | of    | water |       |       |       |
|                 | Sewage    | water |       |       |       |       |
|                 | Treatment | to be |       |       |       |       |
|                 | Systems,  | tr    |       |       |       |       |
|                 | and       | eated |       |       |       |       |
|                 | Standing  |       |       |       |       |       |
|                 | Water     |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Mosquito  | 0     | 2     | 4,400 | 2     | 6     |
|                 | Control   | .0017 | 0,000 |       | 2,000 | 4,000 |
|                 | in        | lb    | ga    |       |       |       |
|                 | D         | a     | llons |       |       |       |
|                 | ecorative | i/gal | of    |       |       |       |
|                 | Ponds,    | of    | water |       |       |       |
|                 | Sewage    | water |       |       |       |       |
|                 | Treatment | to be |       |       |       |       |
|                 | Systems,  | tr    |       |       |       |       |
|                 | and       | eated |       |       |       |       |
|                 | Standing  |       |       |       |       |       |
|                 | Water     |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| ML Liquid to    | Re        | 7 lb  | 100   | 210   | 1,100 | 3,100 |
| Support LCO     | sidential | ai    | acres |       |       |       |
| Handgun         | &         | /acre |       |       |       |       |
| Applications    | C         |       |       |       |       |       |
| (mixing/loading | ommercial |       |       |       |       |       |
| supports 20     | Turf      |       |       |       |       |       |
| LCOs) (1b)      |           |       |       |       |       |       |
|                 |           |       |       |       |       |       |
|                 |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Re        | 0.9   | 100   | 1,700 | 8,300 | 2     |
|                 | sidential | lb    | acres |       |       | 4,000 |
|                 | &         | ai    |       |       |       |       |
|                 | C         | /acre |       |       |       |       |
|                 | ommercial |       |       |       |       |       |
|                 | Turf      |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| M/L Liquids for | O         | 0.65  | 20    | 1     | 5     | 17    |
| Airblast (1c)   | rnamental | lb    | acres | 2,000 | 8,000 | 0,000 |
|                 | Trees     | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| M/L Liquid via  | O         | 0     | 100   | 23    | 1,20  | 3,30  |
| Dip or Soak     | rnamental | .0065 | ga    | 0,000 | 0,000 | 0,000 |
| (1d)            | H         | lb    | llons |       |       |       |
|                 | erbaceous | a     |       |       |       |       |
|                 | Plants,   | i/gal |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | S         | 0     | 100   | 35    | 1,70  | 5,00  |
|                 | eedlings, | .0043 | ga    | 0,000 | 0,000 | 0,000 |
|                 | Seeds,    | lb    | llons |       |       |       |
|                 | Cuttings  | a     |       |       |       |       |
|                 | (preplant | i/gal |       |       |       |       |
|                 | or at     |       |       |       |       |       |
|                 | plant)    |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| M/L WP for      | C         | 256   | 20    | **1** | **4** | 150   |
| Groundboom (2a) | arnations | lb    | acres |       |       |       |
|                 | (drench)  | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 72 lb | 20    | **3** | *     | 520   |
|                 | rnamental | ai    | acres |       | *15** |       |
|                 | H         | /acre |       |       |       |       |
|                 | erbaceous |       |       |       |       |       |
|                 | Plants    |       |       |       |       |       |
|                 | (drench)  |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Sodfarm   | 0.9   | 80    | *     | 290   | 1     |
|                 | Turf      | lb    | acres | *58** |       | 0,000 |
|                 |           | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Seedlings | 0.43  | 20    | 490   | 2,400 | 8     |
|                 | (planted  | lb    | acres |       |       | 7,000 |
|                 | in field) | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| M/L WP Support  | Re        | 7 lb  | 100   | **6** | *     | 1,100 |
| LCO Handgun     | sidential | ai    | acres |       | *30** |       |
| Applications    | &         | /acre |       |       |       |       |
| (mixing/loading | C         |       |       |       |       |       |
| supports 20     | ommercial |       |       |       |       |       |
| LCOs) (2b)      | Turf      |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Re        | 0.9   | 100   | *     | 230   | 8,300 |
|                 | sidential | lb    | acres | *47** |       |       |
|                 | &         | ai    |       |       |       |       |
|                 | C         | /acre |       |       |       |       |
|                 | ommercial |       |       |       |       |       |
|                 | Turf      |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| M/L WP for      | O         | 0.65  | 20    | 320   | 1,600 | 5     |
| Airblast (2c)   | rnamental | lb    | acres |       |       | 8,000 |
|                 | Trees     | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| M/L WP via Dip  | O         | 0     | 100   | 6,400 | 3     | 1,20  |
| or Soak (2d)    | rnamental | .0065 | ga    |       | 2,000 | 0,000 |
|                 | H         | lb    | llons |       |       |       |
|                 | erbaceous | a     |       |       |       |       |
|                 | Plants,   | i/gal |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | S         | 0     | 100   | 9,700 | 4     | 1,70  |
|                 | eedlings, | .0043 | ga    |       | 9,000 | 0,000 |
|                 | Seeds,    | lb    | llons |       |       |       |
|                 | Cuttings  | a     |       |       |       |       |
|                 | (preplant | i/gal |       |       |       |       |
|                 | or at     |       |       |       |       |       |
|                 | plant)    |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| M/L DF for      | C         | 256   | 20    | *     | 230   | 460   |
| Groundboom (3a) | arnations | lb    | acres | *46** |       |       |
|                 | (drench)  | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 72 lb | 20    | 160   | 810   | 1,600 |
|                 | rnamental | ai    | acres |       |       |       |
|                 | H         | /acre |       |       |       |       |
|                 | erbaceous |       |       |       |       |       |
|                 | Plants    |       |       |       |       |       |
|                 | (drench)  |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Sodfarm   | 0.9   | 80    | 3,200 | 1     | 3     |
|                 | Turf      | lb    | acres |       | 6,000 | 2,000 |
|                 |           | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Seedlings | 0.43  | 20    | 2     | 14    | 27    |
|                 | (planted  | lb    | acres | 7,000 | 0,000 | 0,000 |
|                 | in field) | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| M/L DF for      | O         | 0.65  | 20    | 1     | 9     | 5     |
| Airblast (3b)   | rnamental | lb    | acres | 8,000 | 0,000 | 8,000 |
|                 | Trees     | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| M/L DF to       | Re        | 7 lb  | 100   | 330   | 1,700 | 1,100 |
| Support LCO     | sidential | ai    | acres |       |       |       |
| Handgun         | &         | /acre |       |       |       |       |
| Applications    | C         |       |       |       |       |       |
| (mixing/loading | ommercial |       |       |       |       |       |
| supports 20     | Turf      |       |       |       |       |       |
| LCOs) (3c)      |           |       |       |       |       |       |
|                 |           |       |       |       |       |       |
|                 |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Re        | 0.9   | 100   | 2,600 | 1     | 8,300 |
|                 | sidential | lb    | acres |       | 3,000 |       |
|                 | &         | ai    |       |       |       |       |
|                 | C         | /acre |       |       |       |       |
|                 | ommercial |       |       |       |       |       |
|                 | Turf      |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| M/L DF via Dip  | O         | 0     | 100   | 36    | 1,80  | 1,20  |
| or Soak (3d)    | rnamental | .0065 | ga    | 0,000 | 0,000 | 0,000 |
|                 | H         | lb    | llons |       |       |       |
|                 | erbaceous | a     |       |       |       |       |
|                 | Plants,   | i/gal |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | S         | 0     | 100   | 54    | 2,70  | 1,70  |
|                 | eedlings, | .0043 | ga    | 0,000 | 0,000 | 0,000 |
|                 | Seeds,    | lb    | llons |       |       |       |
|                 | Cuttings  | a     |       |       |       |       |
|                 | (preplant | i/gal |       |       |       |       |
|                 | or at     |       |       |       |       |       |
|                 | plant)    |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| **Applicator ** |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| Applying Sprays | C         | 256   | 20    | *     | 240   | 820   |
| via Groundboom  | arnations | lb    | acres | *48** |       |       |
| Equipment (4)   | (drench)  | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 72 lb | 20    | 170   | 840   | 2,900 |
|                 | rnamental | ai    | acres |       |       |       |
|                 | H         | /acre |       |       |       |       |
|                 | erbaceous |       |       |       |       |       |
|                 | Plants    |       |       |       |       |       |
|                 | (drench)  |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Sodfarm   | 0.9   | 80    | 3,400 | 1     | 5     |
|                 | Turf      | lb    | acres |       | 7,000 | 8,000 |
|                 |           | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Seedlings | 0.43  | 20    | 2     | 14    | 49    |
|                 | (planted  | lb    | acres | 8,000 | 0,000 | 0,000 |
|                 | in field) | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Mosquito  | 0     | 80    | 180   | 890   | 3,100 |
|                 | Control   | .0017 | 0,000 |       |       |       |
|                 | in        | lb    | ga    |       |       |       |
|                 | D         | a     | llons |       |       |       |
|                 | ecorative | i/gal | of    |       |       |       |
|                 | Ponds,    | of    | water |       |       |       |
|                 | Sewage    | water | to be |       |       |       |
|                 | Treatment | to be | tr    |       |       |       |
|                 | Systems,  | tr    | eated |       |       |       |
|                 | Swimming  | eated |       |       |       |       |
|                 | Pools and |       |       |       |       |       |
|                 | Standing  |       |       |       |       |       |
|                 | Water     |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Mosquito  | 0     | 10    | 1,400 | 7,200 | 2     |
|                 | Control   | .0017 | 0,000 |       |       | 5,000 |
|                 | in        | lb    | ga    |       |       |       |
|                 | D         | a     | llons |       |       |       |
|                 | ecorative | i/gal | of    |       |       |       |
|                 | Ponds,    | of    | water |       |       |       |
|                 | Sewage    | water | to be |       |       |       |
|                 | Treatment | to be | tr    |       |       |       |
|                 | Systems,  | tr    | eated |       |       |       |
|                 | Swimming  | eated |       |       |       |       |
|                 | Pools and |       |       |       |       |       |
|                 | Standing  |       |       |       |       |       |
|                 | Water     |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Mosquito  | 0     | 2     | 7,200 | 3     | 12    |
|                 | Control   | .0017 | 0,000 |       | 6,000 | 0,000 |
|                 | in        | lb    | ga    |       |       |       |
|                 | D         | a     | llons |       |       |       |
|                 | ecorative | i/gal | of    |       |       |       |
|                 | Ponds,    | of    | water |       |       |       |
|                 | Sewage    | water | to be |       |       |       |
|                 | Treatment | to be | tr    |       |       |       |
|                 | Systems,  | tr    | eated |       |       |       |
|                 | Swimming  | eated |       |       |       |       |
|                 | Pools and |       |       |       |       |       |
|                 | Standing  |       |       |       |       |       |
|                 | Water     |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| Applying Sprays | O         | 0.65  | 20    | 3,100 | 1     | 3     |
| via Airblast    | rnamental | lb    | acres |       | 5,000 | 1,000 |
| Equipment (5)   | Trees     | ai    |       |       |       |       |
|                 |           | /acre |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| **Mixer/Load    |           |       |       |       |       |       |
| er/Applicator** |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| Mixing/L        | C         | 256   | 5     | 94    | 390   | Not   |
| oading/Applying | arnations | lb    | acres |       |       | Fea   |
| Liquid          | (drench)  | ai    |       |       |       | sible |
| Concentrates    |           | /acre |       |       |       |       |
| with a Handgun  |           |       |       |       |       |       |
| Sprayer (LCO    |           |       |       |       |       |       |
| ORETF data)     |           |       |       |       |       |       |
| (11)            |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 72 lb | 5     | 330   | 1,400 | Not   |
|                 | rnamental | ai    | acres |       |       | Fea   |
|                 | H         | /acre |       |       |       | sible |
|                 | erbaceous |       |       |       |       |       |
|                 | Plants    |       |       |       |       |       |
|                 | (drench)  |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 0.65  | 5     | 3     | 15    | Not   |
|                 | rnamental | lb    | acres | 7,000 | 0,000 | Fea   |
|                 | Trees and | ai    |       |       |       | sible |
|                 | O         | /acre |       |       |       |       |
|                 | rnamental |       |       |       |       |       |
|                 | H         |       |       |       |       |       |
|                 | erbaceous |       |       |       |       |       |
|                 | Plants    |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 0.43  | 5     | 5     | 23    | Not   |
|                 | rnamental | lb    | acres | 6,000 | 0,000 | Fea   |
|                 | Shrubs,   | ai    |       |       |       | sible |
|                 | Seedlings | /acre |       |       |       |       |
|                 | (planted  |       |       |       |       |       |
|                 | in field) |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| Mixing/L        | C         | 256   | 5     | 2     | 11    | Not   |
| oading/Applying | arnations | lb    | acres |       |       | Fea   |
| Wettable        | (drench)  | ai    |       |       |       | sible |
| Powders with a  |           | /acre |       |       |       |       |
| Handgun Sprayer |           |       |       |       |       |       |
| (LCO ORETF      |           |       |       |       |       |       |
| data) (12)      |           |       |       |       |       |       |
|                 |           |       |       |       |       |       |
|                 |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 72 lb | 5     | 8     | 39    | Not   |
|                 | rnamental | ai    | acres |       |       | Fea   |
|                 | H         | /acre |       |       |       | sible |
|                 | erbaceous |       |       |       |       |       |
|                 | Plants    |       |       |       |       |       |
|                 | (drench)  |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 0.65  | 5     | 870   | 4,300 | Not   |
|                 | rnamental | lb    | acres |       |       | Fea   |
|                 | Trees and | ai    |       |       |       | sible |
|                 | O         | /acre |       |       |       |       |
|                 | rnamental |       |       |       |       |       |
|                 | H         |       |       |       |       |       |
|                 | erbaceous |       |       |       |       |       |
|                 | Plants    |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 0.43  | 5     | 1,300 | 6,500 | Not   |
|                 | rnamental | lb    | acres |       |       | Fea   |
|                 | Shrubs,   | ai    |       |       |       | sible |
|                 | Seedlings | /acre |       |       |       |       |
|                 | (planted  |       |       |       |       |       |
|                 | in field) |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| Mixing/L        | C         | 256   | 5     | 6     | 32    | Not   |
| oading/Applying | arnations | lb    | acres |       |       | Fea   |
| Dry Flowables   | (drench)  | ai    |       |       |       | sible |
| Concentrates    |           | /acre |       |       |       |       |
| with a Handgun  |           |       |       |       |       |       |
| Sprayer (LCO    |           |       |       |       |       |       |
| ORETF data)     |           |       |       |       |       |       |
| (14)            |           |       |       |       |       |       |
|                 |           |       |       |       |       |       |
|                 |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 72 lb | 5     | 23    | 110   | Not   |
|                 | rnamental | ai    | acres |       |       | Fea   |
|                 | H         | /acre |       |       |       | sible |
|                 | erbaceous |       |       |       |       |       |
|                 | Plants    |       |       |       |       |       |
|                 | (drench)  |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 0.65  | 5     | 2,500 | 1     | Not   |
|                 | rnamental | lb    | acres |       | 3,000 | Fea   |
|                 | Trees and | ai    |       |       |       | sible |
|                 | O         | /acre |       |       |       |       |
|                 | rnamental |       |       |       |       |       |
|                 | H         |       |       |       |       |       |
|                 | erbaceous |       |       |       |       |       |
|                 | Plants    |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 0.43  | 5     | 3,800 | 1     | Not   |
|                 | rnamental | lb    | acres |       | 9,000 | Fea   |
|                 | Shrubs,   | ai    |       |       |       | sible |
|                 | Seedlings | /acre |       |       |       |       |
|                 | (planted  |       |       |       |       |       |
|                 | in field) |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| Mixing/L        | O         | 0     | 1,000 | 230   | 1,200 | Not   |
| oading/Applying | rnamental | .0065 | ga    |       |       | Fea   |
| Liquid          | H         | lb    | llons |       |       | sible |
| Concentrates    | erbaceous | ai/g  |       |       |       |       |
| with a High     | Plants    | allon |       |       |       |       |
| Pressure        | and       |       |       |       |       |       |
| Handwand (PHED) | O         |       |       |       |       |       |
| (15)            | rnamental |       |       |       |       |       |
|                 | Trees     |       |       |       |       |       |
|                 |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | O         | 0     | 1,000 | 350   | 1,700 | Not   |
|                 | rnamental | .0043 | ga    |       |       | Fea   |
|                 | Shrubs    | lb    | llons |       |       | sible |
|                 |           | ai/g  |       |       |       |       |
|                 |           | allon |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| Applying Ready  | O         | 0     | 1     | 2,20  | 11,00 | Not   |
| to Use          | rnamental | .0043 | ga    | 0,000 | 0,000 | Fea   |
| Formulations    | Shrubs,   | lb    | llons |       |       | sible |
| via             | S         | ai/g  |       |       |       |       |
| Trigger-Pump    | eedlings, | allon |       |       |       |       |
| Sprayer (ORETF) | Seeds,    |       |       |       |       |       |
| (16)            | Cuttins   |       |       |       |       |       |
|                 | (preplant |       |       |       |       |       |
|                 | or at     |       |       |       |       |       |
|                 | plant)    |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
| Mixing/L        | O         | 0.013 | 5     | 16    | 81    | Not   |
| oading/Applying | rnamental | lb    | ga    | 0,000 | 0,000 | Fea   |
| Liquids with a  | Palms     | ai/g  | llons |       |       | sible |
| Watering Can    |           | allon |       |       |       |       |
| (using ORETF    |           |       |       |       |       |       |
| residential     |           |       |       |       |       |       |
| hose-end data)  |           |       |       |       |       |       |
| (17)            |           |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | S         | 0     | 5     | 49    | 2,50  | Not   |
|                 | eedlings, | .0043 | ga    | 0,000 | 0,000 | Fea   |
|                 | Seeds,    | lb    | llons |       |       | sible |
|                 | Cuttins   | ai/g  |       |       |       |       |
|                 | (preplant | allon |       |       |       |       |
|                 | or at     |       |       |       |       |       |
|                 | plant)    |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Mosquito  | 0     | 2     | 310   | 1,600 | Not   |
|                 | Control   | .0017 | 0,000 |       |       | Fea   |
|                 | in        | lb    | ga    |       |       | sible |
|                 | D         | ai/g  | llons |       |       |       |
|                 | ecorative | allon | to be |       |       |       |
|                 | Ponds,    | of    | tr    |       |       |       |
|                 | Sewage    | water | eated |       |       |       |
|                 | Treatment | to be |       |       |       |       |
|                 | Systems,  | tr    |       |       |       |       |
|                 | Swimming  | eated |       |       |       |       |
|                 | Pools,    |       |       |       |       |       |
|                 | and       |       |       |       |       |       |
|                 | Standing  |       |       |       |       |       |
|                 | Water     |       |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+
|                 | Mosquito  | 0     | 1,000 | 6,200 | 3     | Not   |
|                 | Control   | .0017 | ga    |       | 1,000 | Fea   |
|                 | in        | lb    | llons |       |       | sible |
|                 | F         | ai/g  | to be |       |       |       |
|                 | ountains, | allon | tr    |       |       |       |
|                 | Water     | of    | eated |       |       |       |
|                 | Displays, | water |       |       |       |       |
|                 | D         | to be |       |       |       |       |
|                 | ecorative | tr    |       |       |       |       |
|                 | Pools     | eated |       |       |       |       |
+-----------------+-----------+-------+-------+-------+-------+-------+

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

b Amount handled per day values are HED estimates of gallons applied per
day based on Exposure SAC SOP #9 AStandard Values for Daily Acres
Treated in Agriculture,@ industry sources, and HED estimates.

c Inhalation MOE = inhalation NOAEL (mg/kg/day) / baseline inhalation
dose (mg/kg/day), where baseline inhalation exposure (mg/day) =
application rate (lb ai/gal ) x amount handled per day (gal/day) x
baseline inhalation unit exposure (μg/lb ai) x conversion factor from μg
to mg (0.001) and the baseline inhalation dose (mg/kg/day) = baseline
inhalation exposure (mg/day) x inhalation absorption factor (100%) /
female bodyweight (60 kg)

[]{#__RefHeading___Toc128276217 .anchor}**2.1.3 Cancer ADBAC Handler
Exposure and Risk Assessment**

No cancer endpoints were identified for ADBAC; therefore, cancer risks
to handlers were not assessed.

[]{#__RefHeading___Toc128276218 .anchor}**2.1.4 Summary of Risk Concerns
and Data Gaps for Occupational Handlers**

[]{#__RefHeading___Toc128276219 .anchor}**2.1.4.1 Summary of Risk
Concerns**

Three scenarios fall below an MOE of 1000 at the maximum level of
protection (engineering controls), and the Agency may request a
confirmatory inhalation toxicity study:

-   Mixing/Loading liquid concentrations via groundboom application
    (carnations -- drench) at 256 lb ai/gal \[MOE = 420 \]

-   Mixing/Loading dry flowables via groundboom application (carnations
    -- drench) at 256 lb ai/gal \[MOE = 460\]

-   Applying sprays via groundboom application (carnations -- drench) at
    256 lb ai/gal \[MOE =820\]

-   Mixing/Loading wettable powders for groundboom application
    (ornamental herbaceous plants -- drench) at 72 lb ai/gal \[MOE=520\]

-   Mixing/Loading wettable powders for groundboom application
    (carnations -- drench) at 256 lb/ai gal

There are no occupational handler scenarios for ADBAC that have
inhalation risks associated with them that are above the level of
concern for exposure assessments at the maximum level of risk
mitigation. Most handler inhalation risks assessed are not of concern at
baseline (i.e., no respirator), except:

-   (1a) mixing/loading liquids concentrates for groundboom applications
    for drench applications to carnations (256 lb ai/A) -- risks are not
    of concern with the addition of a dust/mist respirator,

-   (2a) mixing/loading wettable powders for groundboom applications for
    drench applications to carnations (256 lb ai/A) and for drench
    applications to ornamental plants (72 lb ai/A) and for application
    to sodfarm turf (0.9 lb ai/A) -- risks are not of concern with
    engineering controls (i.e., water-soluble packaging) for the drench
    applications, and risks are not of concern for application to sod
    farms with the addition of a dust/mist respirator,

-   (2b) mixing/loading wettable powders support LCO handgun
    applications (mixing/loading supports 20 LCOs) for applications to
    turf (7 lb ai/A) -- risks are not of concern with engineering
    controls (i.e., water-soluble packaging),

-   (2b) mixing/loading wettable powders support LCO handgun
    applications (mixing/loading supports 20 LCOs) for applications to
    turf (0.9 lb ai/A) -- risks are not of concern with the addition of
    a dust/mist respirator,

-   (3a) mixing/loading dry flowables for groundboom applications for
    drench applications to carnations (256 lb ai/A) -- risks are not of
    concern with the addition of a dust/mist respirator,

-   \(4\) applying sprays via groundboom equipment for drench
    applications to carnations (256 lb ai/A) -- risks are not of concern
    with the addition of a dust/mist respirator,

-   (11)mixing/loading/applying liquid concentrates with a handgun
    sprayer applications to carnations (256 lb ai/A) -- MOE is 94 at
    baseline and risks are not of concern with the addition of a
    dust/mist respirator,

-   \(12\) mixing/loading/applying wettable powders with a handgun
    sprayer for drench applications to carnations (256 lb ai/A) and for
    drench applications to ornamental plants (72 lb ai/A) -- risks are
    not of concern with engineering controls for mixing/loading (i.e.,
    water-soluble packaging) and the addition of a dust/mist respirator
    for application,

-   \(14\) mixing/loading/applying dry flowables with a handgun sprayer
    for drench applications to carnations (256 lb ai/A) -- risks are not
    of concern with engineering controls for mixing/loading (i.e.,
    water-soluble packaging) and the addition of a dust/mist respirator
    for application.

-   \(14\) mixing/loading/applying dry flowables with a handgun sprayer
    for drench applications to ornamental plants (72 lb ai/A) -- risks
    are not of concern with the addition of a dust/mist respirator.

    []{#__RefHeading___Toc128276220 .anchor}**2.1.4.2 Summary of Data
    Gaps**

There are the data gaps for the occupational handler scenarios:

-   mixing/loading/applying dip or soak (no surrogate data are available
    for this scenario),

-   mixing/loading/applying dry flowables using a low-pressure handwand
    sprayer (data for liquid formulations was used as a surrogate),

-   mixing/loading/applying liquid concentrates for sprinkling can
    (ORETF data for hose-end sprayers was used as a surrogate), and

-   mixing/loading/applying dip or soak (no surrogate data are available
    for this scenario).

    []{#__RefHeading___Toc128276221 .anchor}**2.1.5 Recommendations for
    Refining Occupational Handler Risk Assessment**

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

[]{#__RefHeading___Toc128276222 .anchor}**2.2 Occupational
Postapplication Exposures and Risks**

The Agency uses the term "postapplication" to describe exposures to
individuals that occur as a result of being in an environment that has
been previously treated with a pesticide (also referred to as reentry
exposure). The Agency believes that there are distinct job functions or
tasks related to the kinds of activities that occur in previously
treated areas. Job requirements (e.g., the kinds of jobs to cultivate a
crop), the nature of the crop or target that was treated, and how the
chemical residues degrade in the environment can cause exposure levels
to differ over time. Each factor has been considered in this assessment.

[]{#__RefHeading___Toc128276223 .anchor}**2.2.1 Occupational
Postapplication Exposure Scenarios**

ADBAC can be used on ornamental crops in greenhouse and outdoor
occupational settings. As a result, individuals can potentially be
exposed by working in areas that have been previously treated. The
Agency is concerned about the kinds of exposures one could receive in
the workplace after ADBAC is applied to ornamentals.

Since no toxicological endpoint of concern was identified for dermal
systemic adverse effects, no postapplication occupational exposures and
risks were assessed using the traditional method of transfer
coefficients specific to activities performed. Instead, a dermal
endpoint was identified and expressed as μg/cm^2^. Postapplication
dermal risks were assessed by:

-   converting the application rate from lb ai/A to μg/cm^2^;

-   using the Agency=s default assumption that 20 percent of the initial
    application is available for transfer on day 0 (i.e., 12 hours after
    application);

-   using the Agency=s default assumption that the residue dissipates at
    a rate of 10 percent per day;

-   assuming that during the exposure period the skin repeatedly
    contacts foliar surfaces until a concentration of residues on the
    hand is equal to the concentration of residues on foliar surfaces,
    and thereafter, a steady-state is achieved whereby the concentration
    on the hands remains the same as the concentration on the foliar
    surfaces..

Inhalation exposures are thought to be negligible in outdoor
postapplication scenarios, since ADBAC has low vapor pressure and the
dilution factor the outdoor environment is considered infinite. In
addition, under the Worker Protection Standard for Agricultural
Pesticides B WPS B (40 CFR 170) greenhouses must be appropriately
ventilated (ventilation criteria are provided) following pesticide
applications so that postapplication inhalation exposures are minimal.
As such, inhalation postapplication exposures are not considered in this
assessment. The Agency recommends that WPS ventilation criteria be
imposed on non-WPS applications indoors in settings such as an atrium,
interiorscape, or other commercial plant setting. The WPS ventilation
requirements are:

-   10 air exchanges, or

```{=html}
<!-- -->
```
-   2 hours of mechanical ventilation (i.e., fans), or

-   4 hours of passive ventilation (i.e., windows, vents), or

-   11 hours of no ventilation followed by 1 hour of mechanical
    ventilation, or

-   11 hours of no ventilation followed by 2 hours of passive
    ventilation, or

-   24 hours of no ventilation

In agricultural crop settings, the use of personal protective equipment
or other types of equipment to mitigate postapplication exposures to
workers is not considered a viable alternative for the regulatory
process. This is described in some detail in the WPS. Instead, an
administrative approach B a Restricted Entry Interval or REI B is used
to mitigate postapplication risks following applications to crops. The
REI is time period following a pesticide application during which entry
into the treated area is restricted. Postapplication risk levels are
generally calculated in the risk assessment process on a chemical-,
crop-, and activity-specific basis. To establish REIs, the Agency
considers postapplication risks on varying days after application.

[]{#__RefHeading___Toc128276224 .anchor}**2.2.2 Data/Assumptions for
Postapplication Exposure Scenarios**

A series of assumptions and exposure factors served as the basis for
completing the occupational postapplication worker risk assessments.
Each assumption and factor is detailed below on an individual basis.

-   Maximum application rates were considered.

-   Levels of Concern: the Agency has established levels of concern
    (LOC) for occupational postapplication risks B margins of exposure
    of less than 100 for occupational dermal risks are of concern.

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

-   Turf Transferable Residues: No ADBAC-specific turf transferable
    residue (TTR) data were available. Therefore, this assessment uses
    the Agency=s default assumption that 5 percent of the application
    rate is available on day 0 (i.e., 12 hours after application) and
    the residue dissipates at a rate of 10 percent per day.

    []{#__RefHeading___Toc128276225 .anchor}**2.2.3 Occupational
    Postapplication Exposure and Risk Estimates**

Occupational risks were calculated using a Margin of Exposure (MOE),
which is a ratio of the daily exposure to the toxicological endpoint of
concern. Postapplication risks diminish over time because ADBAC residues
eventually dissipate in the environment. As a result, risks were
calculated over time based on changing residue levels. Postapplication
exposure (i.e. MOEs) were calculated as described in Appendix A.

**Post Application Risk Summary**

A summary of the postapplication risks are provided in Table 8. The
occupational postapplication exposure and risk assessment for ornamental
crop uses of ADBAC indicates that dermal risks are of concern following
applications applied as a spray for the three application rates. When
applied as a spray for ornamental crops uses, dermal risks remain of
concern for 3 days until after application for turf application at the
lower application rate, 7 days until after application for the higher
rate and for 13 days until after application for treating plants. Dermal
risks also remain of concern following applications applied as a drench
to carnations until 69 days after application and applied as a drench to
herbaceous ornamentals until 57 days after application.

+------------------------------+-------+--------+--------+-----------+
| **Table 8. Summary of Dermal |       |        |        |           |
| Risks to Occupational        |       |        |        |           |
| Postapplication Workers**    |       |        |        |           |
+==============================+=======+========+========+===========+
| Crop Grouping                | A     | Appli  | Day    | MOE at    |
|                              | pplic | cation | after  | Day 0     |
|                              | ation | r      | Tre    |           |
|                              | type  | ate^a^ | atment |           |
|                              |       |        | when   |           |
|                              |       | (lb    | MOE ≥  |           |
|                              |       | ai     | 100    |           |
|                              |       | /acre) |        |           |
+------------------------------+-------+--------+--------+-----------+
| Dermal Exposure to Treated   | D     | 256    | 69     | **\<1**   |
| Carnations                   | rench |        | days   |           |
+------------------------------+-------+--------+--------+-----------+
| Dermal Exposure to Treated   | D     | 72     | 57     | **\<1**   |
| Herbaceous Ornamentals       | rench |        | days   |           |
+------------------------------+-------+--------+--------+-----------+
| Dermal Exposure to Treated   | Spray | 0.65   | 13     | **27**    |
| Plants                       |       |        | days   |           |
+------------------------------+-------+--------+--------+-----------+
| Dermal Exposure to Treated   | Spray | 7      | 22     | **10**    |
| Turf                         |       |        | days   |           |
+------------------------------+-------+--------+--------+-----------+
|                              |       | 0.9    | 3 days | **79**    |
+------------------------------+-------+--------+--------+-----------+

Dermal endpoint: (Short-term technical grade a.i.) - 40 ug/cm^2^

[]{#__RefHeading___Toc128276226 .anchor}**2.2.4 Occupational
Postapplication Exposure and Risk Estimates for Cancer**

Since no toxicological endpoint of concern was identified for cancer,
cancer risks from occupational postapplication exposures were not
assessed.

[]{#__RefHeading___Toc128276227 .anchor}**2.2.5 Summary of Occupational
Postapplication Risk Concerns and Data Gaps**

The Agency has used the most up-to-date information available to
complete this postapplication risk assessment for ADBAC. A summary of
the postapplication risks are provided in Table 8. The occupational
postapplication exposure and risk assessment for ornamental crop uses of
ADBAC indicates that dermal risks are of concern on all occupational
postapplication scenarios.

[]{#__RefHeading___Toc128276228 .anchor}**2.2.6 Recommendations for
Refining Occupational Postapplication Risk Assessment**

To refine this occupational risk assessment, data on actual use patterns
including rates, timing, and the gallons per acre that are required to
apply ADBAC to control plant diseases or and the gallons of water
treated daily to control mosquito larvae in standing water would better
characterize ADBAC risks. In addition, ADBAC-specific DFR or TTR data
could refine exposure and risk estimates.

[]{#__RefHeading___Toc128276229 .anchor}**3.0 Residential and Other
Non-Occupational Exposures and Risks**

It has been determined there is a potential for exposure in residential
settings during the application process for homeowners who use products
containing ADBAC. There is also a potential for exposure from entering
ADBAC-treated areas, such as home lawns, gardens and greenhouses that
could lead to exposures to adults. Risk assessments have been completed
for both residential handler and postapplication scenarios.

[]{#__RefHeading___Toc128276230 .anchor}**3.1 Residential Handler
Exposures and Risks**

The Agency uses the term Ahandlers@ to describe those individuals who
are involved in the pesticide application process. The Agency believes
that there are distinct tasks related to applications and that exposures
can vary depending on the specifics of each task as was described above
for occupational handlers.

[]{#__RefHeading___Toc128276231 .anchor}**3.1.1 Handler Exposure
Scenarios**

Scenarios are used to define risks based on the U.S. EPA Guidelines for
Exposure Assessment (U.S. EPA; Federal Register Volume 57, Number 104;
May 29, 1992). Assessing exposures and risks resulting from residential
uses is very similar to assessing occupational exposures and risks, with
the following exceptions:

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

-   Homeowner handler assessments are based on the assumption that
    individuals experience irritation based on hand contact with ADBAC.

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

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

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

Since requiring personal protective equipment is not considered by EPA
as a feasible means of reducing exposure and risk for residential
handlers, dermal risks were estimated for residential handlers to
determine if dermal irritation would be of concern. Dermal risks were
estimated by using the dermal unit exposure for hands from Pthe Agency
for the application equipment/method being assessed divided by the
surface area of adult hands and then normalizing for the amount handled
per day (application rate in pounds active ingredient per gallon times
the gallons handled per day). The residue concentration on skin
(μg/cm^2^) was then compared directly to the dermal endpoint (μg/cm^2^).
The margin of exposure (MOE) for the dermal assessment is 100.

It has been determined that exposure to pesticide handlers is likely
during the residential use of ADBAC in indoor (greenhouse) and outdoor
while treating turf and ornamentals. The anticipated use patterns and
current labeling indicate several residential handler exposure scenarios
based on the types of equipment and techniques that can potentially be
used to make ADBAC applications. The quantitative exposure/risk
assessment developed for residential handlers is based on these
scenarios. \[Note: The scenario numbers correspond to the tables of risk
calculations included in the residential risk calculations in the
appendices.\]

**[Mixer/Loader/Applicators:]{.underline}**

> \(1\) Liquid Formulations: Low Pressure Handwand (PHED data for dermal
> and ORETF data for inhalation)
>
> \(2\) Wettable Powder Formulations: Low Pressure Handwand (PHED data
> for dermal and inhalation)
>
> \(3\) Dry Flowable Formulations: Low Pressure Handwand (using liquid
> concentrate PHED data for dermal and liquid concentrate ORETF data for
> inhalation)
>
> \(4\) Liquid Concentrates: Hose‑End Sprayer (PHED data for dermal and
> ORETF data for inhalation)
>
> \(5\) Wettable Powder Formulations: Hose‑End Sprayer (no data)
>
> \(6\) Dry Flowable Formulations: Hose‑End Sprayer (no data)
>
> \(7\) Ready-to-Use Formulations: Hose-End Sprayer (no data)
>
> \(8\) Liquid Concentrates: Watering Can (using PHED hose-end sprayer
> data for dermal and ORETF hose-end data for inhalation)
>
> \(9\) Ready to Use Formulations via Trigger-Pump Sprayer (PHED data
> for aerosol can for dermal and ORETF data for inhalation), and
>
> 10\) Dip or Soak Applications (no data)

[]{#__RefHeading___Toc128276232 .anchor}**3.1.2 Data and Assumptions for
Handler Exposure Scenarios**

A series of assumptions and exposure factors served as the basis for
completing the residential handler risk assessments. Each assumption and
factor is detailed below. In addition to these factors, unit exposure
values were used to calculate risk estimates. Dermal unit exposure
values were taken from the Pesticide Handlers Exposure Database (PHED).
Both PHED and the individual studies are presented below. \[Note:
Several of the assumptions and factors used for the assessment are
similar to those used in the occupational assessment presented above. As
such, only factors that are unique to the residential scenarios are
presented below.\] Assumptions and Factors: The assumptions and factors
used in the risk calculations include:

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

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

-   Residential risk assessments are based on estimates of what
    homeowners would typically treat, such as the size of a lawn or the
    size of a garden. The factors used for the ADBAC assessment were
    from the Health Effects Division Science Advisory Committee Policy
    12: Recommended Revisions to the Standard Operating Procedures for
    Residential Exposure Assessment which was completed on February 22,
    2001, and on professional judgment. The daily volumes handled for
    each residential scenario are provided in Table 3b.

    []{#__RefHeading___Toc128276233 .anchor}**3.1.3 Residential Handler
    Exposure and Risk Estimates**

Risks were calculated using the margin of exposure (MOE) as described in
Section 2.1.3. Assessing exposures and risks resulting from residential
uses is very similar to assessing occupational exposures and risks,
except as described in Section 3.1.1.

[Risk Summary]{.underline}

The Agency believes that the scenarios assessed in this document
represent worse-case exposures and risks resulting from use of ADBAC in
residential environments. It should be noted that there were many other
scenarios where medium to low PHED quality data were used to complete
the assessment. Data quality should be considered in the interpretation
of the uncertainties associated with each risk value presented.

Short-term dermal and inhalation unit exposures and risks for
residential handlers (intermediate-term exposures are not likely because
of the intermittent nature of applications by homeowners) are presented
in Tables 11, 12, and 13. One dermal scenario was of concern when the
end-use product formulation was less than 10 percent;
mixing/loading/applying liquid concentrates with a hose-end sprayer on
residential turf at the 7 lb ai/A rate. When the end-use product is
formulated with more than 10% ADBAC, the dermal risks for residential
handlers are of concern for ten of the eleven ADBAC residential handler
scenarios, where data are available. The inhalation risks for
residential handlers are not of concern for any residential uses of
ADBAC.

+---------------+------------+-------+--------+-------+-------+-----+
| **Table 11:   |            |       |        |       |       |     |
| Short-term    |            |       |        |       |       |     |
| Dermal Risks  |            |       |        |       |       |     |
| to            |            |       |        |       |       |     |
| Residential   |            |       |        |       |       |     |
| Handlers      |            |       |        |       |       |     |
| Using         |            |       |        |       |       |     |
| Formulations  |            |       |        |       |       |     |
| with 10% or   |            |       |        |       |       |     |
| Less ADBAC**  |            |       |        |       |       |     |
+===============+============+=======+========+=======+=======+=====+
| Scenario      | C          | A     | Qu     | Unit  | Esti  | Der |
|               | rop/Target | pplic | antity | Exp   | mated | mal |
|               |            | ation | H      | osure | Re    | MOE |
|               |            | Ra    | andled | for   | sidue |     |
|               |            | te^a^ | Per    | Han   | T     | (UF |
|               |            |       | Day^b^ | ds^c^ | ransf | =   |
|               |            |       |        |       | erred | 1   |
|               |            |       |        | (     | to    | 00) |
|               |            |       |        | mg/lb | Skin  | ^e^ |
|               |            |       |        | ai)   | on    |     |
|               |            |       |        |       | Hands |     |
|               |            |       |        |       | (ug   |     |
|               |            |       |        |       | a     |     |
|               |            |       |        |       | i/cm^ |     |
|               |            |       |        |       | 2^/da |     |
|               |            |       |        |       | y)^d^ |     |
+---------------+------------+-------+--------+-------+-------+-----+
| M/L/A Liquid  | R          | 0     | 5      | 102   | 4.0   | 1,  |
| Concentrates  | esidential | .0065 | g      |       |       | 900 |
| with LP       | Turf,      | lb    | al/day |       |       |     |
| Handwand (1)  | Ornamental | a     |        |       |       |     |
|               | Bulbs and  | i/gal |        |       |       |     |
|               | Orchids    | water |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+
|               | Ornamental | 0     | 5      | 102   | 2.7   | 2,  |
|               | Herbaceous | .0043 | g      |       |       | 900 |
|               | Plants,    | lb    | al/day |       |       |     |
|               | Ornamental | a     |        |       |       |     |
|               | Shrubs,    | i/gal |        |       |       |     |
|               | Ornamental | water |        |       |       |     |
|               | Trees,     |       |        |       |       |     |
|               | Seedlings  |       |        |       |       |     |
|               | (planted   |       |        |       |       |     |
|               | in         |       |        |       |       |     |
|               | garden),   |       |        |       |       |     |
|               | Seedlings, |       |        |       |       |     |
|               | Seeds,     |       |        |       |       |     |
|               | Cuttings   |       |        |       |       |     |
|               | (preplant  |       |        |       |       |     |
|               | or at      |       |        |       |       |     |
|               | plant)     |       |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+
| M/L/A WP LP   | R          | 0     | 5      | 229   | 9.1   | 850 |
| Handwand (2)  | esidential | .0065 | g      |       |       |     |
|               | Turf,      | lb    | al/day |       |       |     |
|               | Ornamental | a     |        |       |       |     |
|               | Bulbs and  | i/gal |        |       |       |     |
|               | Orchids    | water |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+
|               | Ornamental | 0     | 5      | 229   | 6.0   | 1,  |
|               | Herbaceous | .0043 | g      |       |       | 300 |
|               | Plants,    | lb    | al/day |       |       |     |
|               | Ornamental | a     |        |       |       |     |
|               | Shrubs,    | i/gal |        |       |       |     |
|               | Ornamental | water |        |       |       |     |
|               | Trees,     |       |        |       |       |     |
|               | Seedlings  |       |        |       |       |     |
|               | (planted   |       |        |       |       |     |
|               | in         |       |        |       |       |     |
|               | garden),   |       |        |       |       |     |
|               | Seedlings, |       |        |       |       |     |
|               | Seeds,     |       |        |       |       |     |
|               | Cuttings   |       |        |       |       |     |
|               | (preplant  |       |        |       |       |     |
|               | or at      |       |        |       |       |     |
|               | plant)     |       |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+
| M/L/A DF with | R          | 0     | 5      | 102   | 4.0   | 1,  |
| LP Handwand   | esidential | .0065 | g      |       |       | 900 |
| (liquid       | Turf,      | lb    | al/day |       |       |     |
| concentrate   | Ornamental | a     |        |       |       |     |
| PHED data as  | Bulbs and  | i/gal |        |       |       |     |
| surrogate)    | Orchids    | water |        |       |       |     |
| (3)           |            |       |        |       |       |     |
|               |            |       |        |       |       |     |
|               |            |       |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+
|               | Ornamental | 0     | 5      | 102   | 2.7   | 2,  |
|               | Herbaceous | .0043 | g      |       |       | 900 |
|               | Plants,    | lb    | al/day |       |       |     |
|               | Ornamental | a     |        |       |       |     |
|               | Shrubs,    | i/gal |        |       |       |     |
|               | Ornamental | water |        |       |       |     |
|               | Trees,     |       |        |       |       |     |
|               | Seedlings  |       |        |       |       |     |
|               | (planted   |       |        |       |       |     |
|               | in         |       |        |       |       |     |
|               | garden),   |       |        |       |       |     |
|               | Seedlings, |       |        |       |       |     |
|               | Seeds,     |       |        |       |       |     |
|               | Cuttings   |       |        |       |       |     |
|               | (preplant  |       |        |       |       |     |
|               | or at      |       |        |       |       |     |
|               | plant)     |       |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+
| M/L/A Liquid  | R          | 7 lb  | 0.5    | 27.5  | 120.0 | **6 |
| Concentrates  | esidential | ai/A  | acr    |       |       | 6** |
| with a        | Turf       |       | es/day |       |       |     |
| Hose-end      |            |       |        |       |       |     |
| Sprayer (4)   |            |       |        |       |       |     |
|               |            |       |        |       |       |     |
|               |            |       |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+
|               | Ornamental | 0.43  | 0.25   | 27.5  | 3.6   | 2,  |
|               | Herbaceous | lb    | acr    |       |       | 100 |
|               | Plants,    | ai/A  | es/day |       |       |     |
|               | Ornamental |       |        |       |       |     |
|               | Shrubs,    |       |        |       |       |     |
|               | Ornamental |       |        |       |       |     |
|               | Trees,     |       |        |       |       |     |
|               | Seedlings  |       |        |       |       |     |
|               | (planted   |       |        |       |       |     |
|               | in garden) |       |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+
| M/L/A Liquids | Ornamental | 0.013 | 5      | 27.5  | 0.7   | 11, |
| with a        | Palms      | lb    | g      |       |       | 000 |
| Watering Can  |            | a     | al/day |       |       |     |
| (PHED         |            | i/gal |        |       |       |     |
| residential   |            | water |        |       |       |     |
| hose-end data |            |       |        |       |       |     |
| as surrogate) |            |       |        |       |       |     |
| (8)           |            |       |        |       |       |     |
|               |            |       |        |       |       |     |
|               |            |       |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+
|               | Seedlings, | 0     | 5      | 27.5  | 0.1   | 54, |
|               | Seeds,     | .0043 | g      |       |       | 000 |
|               | Cuttins    | lb    | al/day |       |       |     |
|               | (preplant  | a     |        |       |       |     |
|               | or at      | i/gal |        |       |       |     |
|               | plant)     | water |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+
| Applying      | Ornamental | 0     | 1      | 106   | 2.8   | 2,  |
| Ready to Use  | Shrubs,    | .0043 | g      |       |       | 800 |
| Formulations  | Seedlings, | lb    | al/day |       |       |     |
| via           | Seeds,     | ai/g  |        |       |       |     |
| Trigger-Pump  | Cuttings   | allon |        |       |       |     |
| Sprayer (PHED | (preplant  |       |        |       |       |     |
| data for      | or at      |       |        |       |       |     |
| aerosol can   | plant)     |       |        |       |       |     |
| used as       |            |       |        |       |       |     |
| surrogate)    |            |       |        |       |       |     |
| (9)           |            |       |        |       |       |     |
+---------------+------------+-------+--------+-------+-------+-----+

Footnotes:

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

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

c From residential PHED unit exposures values for hands for the
scenarios listed.

d Application rate (lb ai/gal) \* amount handled per day (gal/day) \*
dermal unit exposures value (mg/lb ai) \* conversion factor mg to μg
(1000) / surface area of adult hands (cm^2^) 820 cm^2^ from Exposure
Factors Handbook.

f Dermal MOE = Estimated Residue transferred to Skin of Hands
(μg/cm^2^/day)/ Dermal Endpoint (7750 μg/cm^2^/day)

+---------------+------------+------+--------+--------+-------+-----+
| **Table 12:   |            |      |        |        |       |     |
| Short-term    |            |      |        |        |       |     |
| Dermal Risks  |            |      |        |        |       |     |
| to            |            |      |        |        |       |     |
| Residential   |            |      |        |        |       |     |
| Handlers      |            |      |        |        |       |     |
| Using         |            |      |        |        |       |     |
| Formulations  |            |      |        |        |       |     |
| With More     |            |      |        |        |       |     |
| Than 10%      |            |      |        |        |       |     |
| ADBAC**       |            |      |        |        |       |     |
+===============+============+======+========+========+=======+=====+
| Scenario      | C          | App  | Qu     | Unit   | Esti  | Der |
|               | rop/Target | lica | antity | Ex     | mated | mal |
|               |            | tion | H      | posure | Re    | MOE |
|               |            | Rat  | andled | for    | sidue |     |
|               |            | e^a^ | Per    | Ha     | T     | (UF |
|               |            |      | Day^b^ | nds^c^ | ransf | =   |
|               |            |      |        |        | erred | 1   |
|               |            |      |        | (mg/lb | to    | 00) |
|               |            |      |        | ai)    | Skin  | ^e^ |
|               |            |      |        |        | on    |     |
|               |            |      |        |        | Hands |     |
|               |            |      |        |        | (ug   |     |
|               |            |      |        |        | a     |     |
|               |            |      |        |        | i/cm^ |     |
|               |            |      |        |        | 2^/da |     |
|               |            |      |        |        | y)^d^ |     |
+---------------+------------+------+--------+--------+-------+-----+
| M/L/A Liquid  | R          | 0.   | 5      | 102    | 4.0   | **1 |
| Concentrates  | esidential | 0065 | g      |        |       | 0** |
| with LP       | Turf,      | lb   | al/day |        |       |     |
| Handwand (1)  | Ornamental | ai   |        |        |       |     |
|               | Bulbs and  | /gal |        |        |       |     |
|               | Orchids    | w    |        |        |       |     |
|               |            | ater |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+
|               | Ornamental | 0.   | 5      | 102    | 2.7   | **1 |
|               | Herbaceous | 0043 | g      |        |       | 5** |
|               | Plants,    | lb   | al/day |        |       |     |
|               | Ornamental | ai   |        |        |       |     |
|               | Shrubs,    | /gal |        |        |       |     |
|               | Ornamental | w    |        |        |       |     |
|               | Trees,     | ater |        |        |       |     |
|               | Seedlings  |      |        |        |       |     |
|               | (planted   |      |        |        |       |     |
|               | in         |      |        |        |       |     |
|               | garden),   |      |        |        |       |     |
|               | Seedlings, |      |        |        |       |     |
|               | Seeds,     |      |        |        |       |     |
|               | Cuttings   |      |        |        |       |     |
|               | (preplant  |      |        |        |       |     |
|               | or at      |      |        |        |       |     |
|               | plant)     |      |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+
| M/L/A WP with | R          | 0.   | 5      | 229    | 9.1   | **  |
| LP Handwand   | esidential | 0065 | g      |        |       | 4** |
| (2)           | Turf,      | lb   | al/day |        |       |     |
|               | Ornamental | ai   |        |        |       |     |
|               | Bulbs and  | /gal |        |        |       |     |
|               | Orchids    | w    |        |        |       |     |
|               |            | ater |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+
|               | Ornamental | 0.   | 5      | 229    | 6.0   | **  |
|               | Herbaceous | 0043 | g      |        |       | 7** |
|               | Plants,    | lb   | al/day |        |       |     |
|               | Ornamental | ai   |        |        |       |     |
|               | Shrubs,    | /gal |        |        |       |     |
|               | Ornamental | w    |        |        |       |     |
|               | Trees,     | ater |        |        |       |     |
|               | Seedlings  |      |        |        |       |     |
|               | (planted   |      |        |        |       |     |
|               | in         |      |        |        |       |     |
|               | garden),   |      |        |        |       |     |
|               | Seedlings, |      |        |        |       |     |
|               | Seeds,     |      |        |        |       |     |
|               | Cuttings   |      |        |        |       |     |
|               | (preplant  |      |        |        |       |     |
|               | or at      |      |        |        |       |     |
|               | plant)     |      |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+
| M/L/A DF with | R          | 0.   | 5      | 102    | 4.0   | **1 |
| LP Handwand   | esidential | 0065 | g      |        |       | 0** |
| (liquid       | Turf,      | lb   | al/day |        |       |     |
| concentrate   | Ornamental | ai   |        |        |       |     |
| PHED data as  | Bulbs and  | /gal |        |        |       |     |
| surrogate)    | Orchids    | w    |        |        |       |     |
| (3)           |            | ater |        |        |       |     |
|               |            |      |        |        |       |     |
|               |            |      |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+
|               | Ornamental | 0.   | 5      | 102    | 2.7   | **1 |
|               | Herbaceous | 0043 | g      |        |       | 5** |
|               | Plants,    | lb   | al/day |        |       |     |
|               | Ornamental | ai   |        |        |       |     |
|               | Shrubs,    | /gal |        |        |       |     |
|               | Ornamental | w    |        |        |       |     |
|               | Trees,     | ater |        |        |       |     |
|               | Seedlings  |      |        |        |       |     |
|               | (planted   |      |        |        |       |     |
|               | in         |      |        |        |       |     |
|               | garden),   |      |        |        |       |     |
|               | Seedlings, |      |        |        |       |     |
|               | Seeds,     |      |        |        |       |     |
|               | Cuttings   |      |        |        |       |     |
|               | (preplant  |      |        |        |       |     |
|               | or at      |      |        |        |       |     |
|               | plant)     |      |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+
| M/L/A Liquid  | R          | 7 lb | 0.5    | 27.5   | 120.0 | *   |
| Concentrates  | esidential | ai/A | acr    |        |       | *\< |
| with a        | Turf       |      | es/day |        |       | 1** |
| Hose-end      |            |      |        |        |       |     |
| Sprayer (4)   |            |      |        |        |       |     |
|               |            |      |        |        |       |     |
|               |            |      |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+
|               | Ornamental | 0.43 | 0.25   | 27.5   | 3.6   | **1 |
|               | Herbaceous | lb   | acr    |        |       | 1** |
|               | Plants,    | ai/A | es/day |        |       |     |
|               | Ornamental |      |        |        |       |     |
|               | Shrubs,    |      |        |        |       |     |
|               | Ornamental |      |        |        |       |     |
|               | Trees,     |      |        |        |       |     |
|               | Seedlings  |      |        |        |       |     |
|               | (planted   |      |        |        |       |     |
|               | in garden) |      |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+
| M/L/A Liquids | Ornamental | 0    | 5      | 27.5   | 0.7   | **5 |
| with a        | Palms      | .013 | g      |        |       | 5** |
| Watering Can  |            | lb   | al/day |        |       |     |
| (PHED         |            | ai   |        |        |       |     |
| residential   |            | /gal |        |        |       |     |
| hose-end data |            | w    |        |        |       |     |
| as surrogate) |            | ater |        |        |       |     |
| (8)           |            |      |        |        |       |     |
|               |            |      |        |        |       |     |
|               |            |      |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+
|               | Seedlings, | 0.   | 5      | 27.5   | 0.1   | 280 |
|               | Seeds,     | 0043 | g      |        |       |     |
|               | Cuttings   | lb   | al/day |        |       |     |
|               | (preplant  | ai   |        |        |       |     |
|               | or at      | /gal |        |        |       |     |
|               | plant)     | w    |        |        |       |     |
|               |            | ater |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+
| Applying      | Ornamental | 0.   | 1      | 106    | 2.8   | **1 |
| Ready to Use  | Shrubs,    | 0043 | g      |        |       | 4** |
| Formulations  | Seedlings, | lb   | al/day |        |       |     |
| via           | Seeds,     | a    |        |        |       |     |
| Trigger-Pump  | Cuttings   | i/ga |        |        |       |     |
| Sprayer (PHED | (preplant  | llon |        |        |       |     |
| data for      | or at      |      |        |        |       |     |
| aerosol can   | plant)     |      |        |        |       |     |
| used as       |            |      |        |        |       |     |
| surrogate)    |            |      |        |        |       |     |
| (9)           |            |      |        |        |       |     |
+---------------+------------+------+--------+--------+-------+-----+

Footnotes:

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

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

c From residential PHED unit exposures values for hands for the
scenarios listed.

d Application rate (lb ai/gal) \* amount handled per day (gal/day) \*
dermal unit exposures value (mg/lb ai) \* conversion factor mg to μg
(1000) / surface area of adult hands (cm^2^) 820 cm^2^ from Exposure
Factors Handbook.

f Dermal MOE = Estimated Residue transferred to Skin of Hands
(μg/cm^2^/day)/ Dermal Endpoint (40 μg/cm^2^/day)

+------------+------------+------+-----+------+------+------+------+
| **Table    |            |      |     |      |      |      |      |
| 13:        |            |      |     |      |      |      |      |
| Short-term |            |      |     |      |      |      |      |
| Inhalation |            |      |     |      |      |      |      |
| Risks to   |            |      |     |      |      |      |      |
| R          |            |      |     |      |      |      |      |
| esidential |            |      |     |      |      |      |      |
| Handlers** |            |      |     |      |      |      |      |
+============+============+======+=====+======+======+======+======+
| Scenario   | C          | App  | Qu  | In   | In   | In   | In   |
|            | rop/Target | lica | ant | hala | hala | hala | hala |
|            |            | tion | ity | tion | tion | tion | tion |
|            |            | Rate | Ha  | Unit | Exp  | Dos  | MO   |
|            |            | ^a^  | ndl | Expo | osur | e^e^ | E^f^ |
|            |            |      | ed/ | sure | e^d^ |      |      |
|            |            |      | T   | (u   |      |      |      |
|            |            |      | rea | g/lb |      |      |      |
|            |            |      | ted | ai   |      |      |      |
|            |            |      | per | )^c^ |      |      |      |
|            |            |      | day |      |      |      |      |
|            |            |      | ^s^ |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
| M/L/A      | R          | 0.   | 5   | 30   | 0.00 | 0.00 | 180  |
| Liquid     | esidential | 0065 | g   |      | 0975 | 0016 | ,000 |
| Co         | Turf,      | lb   | al/ |      |      |      |      |
| ncentrates | Ornamental | ai   | day |      |      |      |      |
| with LP    | Bulbs and  | /gal |     |      |      |      |      |
| Handwand   | Orchids    | w    |     |      |      |      |      |
| (1)        |            | ater |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
|            | Ornamental | 0.   | 5   | 30   | 0.0  | 0.00 | 280  |
|            | Herbaceous | 0043 | g   |      | 0065 | 0011 | ,000 |
|            | Plants,    | lb   | al/ |      |      |      |      |
|            | Ornamental | ai   | day |      |      |      |      |
|            | Shrubs,    | /gal |     |      |      |      |      |
|            | Ornamental | w    |     |      |      |      |      |
|            | Trees,     | ater |     |      |      |      |      |
|            | Seedlings  |      |     |      |      |      |      |
|            | (planted   |      |     |      |      |      |      |
|            | in         |      |     |      |      |      |      |
|            | garden),   |      |     |      |      |      |      |
|            | Seedlings, |      |     |      |      |      |      |
|            | Seeds,     |      |     |      |      |      |      |
|            | Cuttings   |      |     |      |      |      |      |
|            | (preplant  |      |     |      |      |      |      |
|            | or at      |      |     |      |      |      |      |
|            | plant)     |      |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
| M/L/A WP   | R          | 0.   | 5   | 1063 | 0    | 0.   | 5    |
| with LP    | esidential | 0065 | g   |      | .035 | 0058 | ,200 |
| Handwand   | Turf,      | lb   | al/ |      |      |      |      |
| (2)        | Ornamental | ai   | day |      |      |      |      |
|            | Bulbs and  | /gal |     |      |      |      |      |
|            | Orchids    | w    |     |      |      |      |      |
|            |            | ater |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
|            | Ornamental | 0.   | 5   | 1063 | 0    | 0.0  | 7    |
|            | Herbaceous | 0043 | g   |      | .023 | 0038 | ,900 |
|            | Plants,    | lb   | al/ |      |      |      |      |
|            | Ornamental | ai   | day |      |      |      |      |
|            | Shrubs,    | /gal |     |      |      |      |      |
|            | Ornamental | w    |     |      |      |      |      |
|            | Trees,     | ater |     |      |      |      |      |
|            | Seedlings  |      |     |      |      |      |      |
|            | (planted   |      |     |      |      |      |      |
|            | in         |      |     |      |      |      |      |
|            | garden),   |      |     |      |      |      |      |
|            | Seedlings, |      |     |      |      |      |      |
|            | Seeds,     |      |     |      |      |      |      |
|            | Cuttings   |      |     |      |      |      |      |
|            | (preplant  |      |     |      |      |      |      |
|            | or at      |      |     |      |      |      |      |
|            | plant)     |      |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
| M/L/A DF   | R          | 0.   | 5   | 30   | 0.00 | 0.00 | 180  |
| with Low   | esidential | 0065 | g   |      | 0975 | 0016 | ,000 |
| Pressure   | Turf,      | lb   | al/ |      |      |      |      |
| Handwand   | Ornamental | ai   | day |      |      |      |      |
| (liquid    | Bulbs and  | /gal |     |      |      |      |      |
| c          | Orchids    | w    |     |      |      |      |      |
| oncentrate |            | ater |     |      |      |      |      |
| PHED data  |            |      |     |      |      |      |      |
| as         |            |      |     |      |      |      |      |
| surrogate) |            |      |     |      |      |      |      |
| (3)        |            |      |     |      |      |      |      |
|            |            |      |     |      |      |      |      |
|            |            |      |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
|            | Ornamental | 0.   | 5   | 30   | 0.0  | 0.00 | 280  |
|            | Herbaceous | 0043 | g   |      | 0065 | 0011 | ,000 |
|            | Plants,    | lb   | al/ |      |      |      |      |
|            | Ornamental | ai   | day |      |      |      |      |
|            | Shrubs,    | /gal |     |      |      |      |      |
|            | Ornamental | w    |     |      |      |      |      |
|            | Trees,     | ater |     |      |      |      |      |
|            | Seedlings  |      |     |      |      |      |      |
|            | (planted   |      |     |      |      |      |      |
|            | in         |      |     |      |      |      |      |
|            | garden),   |      |     |      |      |      |      |
|            | Seedlings, |      |     |      |      |      |      |
|            | Seeds,     |      |     |      |      |      |      |
|            | Cuttings   |      |     |      |      |      |      |
|            | (preplant  |      |     |      |      |      |      |
|            | or at      |      |     |      |      |      |      |
|            | plant)     |      |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
| M/L/A      | R          | 7 lb | 0.5 | 17   | 0.06 | 0.0  | 3    |
| Liquid     | esidential | ai/A | acr |      |      | 0099 | ,000 |
| Co         | Turf       |      | es/ |      |      |      |      |
| ncentrates |            |      | day |      |      |      |      |
| with a     |            |      |     |      |      |      |      |
| Hose-end   |            |      |     |      |      |      |      |
| Sprayer    |            |      |     |      |      |      |      |
| (4)        |            |      |     |      |      |      |      |
|            |            |      |     |      |      |      |      |
|            |            |      |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
|            | Ornamental | 0.43 | 0   | 1.6  | 0.0  | 2.   | 1    |
|            | Herbaceous | lb   | .25 |      | 0017 | 9E-6 | ,000 |
|            | Plants,    | ai/A | acr |      |      |      | ,000 |
|            | Ornamental |      | es/ |      |      |      |      |
|            | Shrubs,    |      | day |      |      |      |      |
|            | Ornamental |      |     |      |      |      |      |
|            | Trees,     |      |     |      |      |      |      |
|            | Seedlings  |      |     |      |      |      |      |
|            | (planted   |      |     |      |      |      |      |
|            | in garden) |      |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
| M/L/A      | Ornamental | 0    | 5   | 1.6  | 0    | 1.   | 1    |
| Liquids    | Palms      | .013 | g   |      | .001 | 7E-6 | ,700 |
| with a     |            | lb   | al/ |      |      |      | ,000 |
| Watering   |            | ai   | day |      |      |      |      |
| Can (PHED  |            | /gal |     |      |      |      |      |
| r          |            | w    |     |      |      |      |      |
| esidential |            | ater |     |      |      |      |      |
| hose-end   |            |      |     |      |      |      |      |
| data as    |            |      |     |      |      |      |      |
| surrogate) |            |      |     |      |      |      |      |
| (8)        |            |      |     |      |      |      |      |
|            |            |      |     |      |      |      |      |
|            |            |      |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
|            | Seedlings, | 0.   | 5   | 1.6  | 0.00 | 5.   | 5    |
|            | Seeds,     | 0043 | g   |      | 0034 | 7E-7 | ,200 |
|            | Cuttings   | lb   | al/ |      |      |      | ,000 |
|            | (preplant  | ai   | day |      |      |      |      |
|            | or at      | /gal |     |      |      |      |      |
|            | plant)     | w    |     |      |      |      |      |
|            |            | ater |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+
| Applying   | Ornamental | 0.   | 1   | 19   | 0.00 | 1.   | 2    |
| Ready to   | Shrubs,    | 0043 | g   |      | 0082 | 4E-6 | ,200 |
| Use        | Seedlings, | lb   | al/ |      |      |      | ,000 |
| Fo         | Seeds,     | a    | day |      |      |      |      |
| rmulations | Cuttings   | i/ga |     |      |      |      |      |
| via        | (preplant  | llon |     |      |      |      |      |
| Tr         | or at      |      |     |      |      |      |      |
| igger-Pump | plant)     |      |     |      |      |      |      |
| Sprayer    |            |      |     |      |      |      |      |
| (9)        |            |      |     |      |      |      |      |
+------------+------------+------+-----+------+------+------+------+

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

b Amount handled per day values are HED estimates of gallons applied per
day based on Exposure SAC SOP #9 AStandard Values for Daily Acres
Treated in Agriculture,@ industry sources, and HED estimates.

c Baseline Inhalation: no respirator.

d Baseline inhalation exposure (mg/day) = application rate (lb ai/gal )
x amount handled per day (gal/day) x baseline inhalation unit exposure
(μg/lb ai) x conversion factor from μg to mg (0.001)

e Baseline inhalation dose (mg/kg/day) = baseline inhalation exposure
(mg/day) x inhalation absorption factor (100%) / female bodyweight (kg)

f Inhalation MOE = inhalation NOAEL (mg/kg/day) / baseline inhalation
dose (mg/kg/day)

[]{#__RefHeading___Toc128276234 .anchor}**3.1.4 Residential Handler
Exposure and Risk Estimates for Cancer**

Residential handler cancer risks are not assessed, since no
toxicological endpoint of concern for cancer was selected.

[]{#__RefHeading___Toc128276235 .anchor}**3.1.5 Summary of Risk Concerns
and Data Gaps for Handlers**

Risks for all inhalation scenarios were not of concern for residential
handlers. One dermal scenario was of concern when the end-use product
formulation was less than 10 percent; mixing/loading/applying liquid
concentrates with a hose-end sprayer on residential turf at the 7 lb
ai/A rate had an MOE of **66**. Ten of the eleven dermal scenarios were
of concern when the end-use product was 10 percent or more.

There are several data gaps identified by the Agency for residential
handlers including:

-   mixing/loading/applying dry flowables with low-pressure handwand
    sprayers and with hose-end sprayers (no data are available as a
    reasonable surrogate),

-   mixing/loading/applying wettable powders with hose-end sprayers (no
    data are available as a reasonable surrogate),

-   mixing/loading/applying liquid concentrates with a sprinkling can
    (data from hose-end sprayers was used as a surrogate), and

-   applying as a dip or soak (no data are available as a reasonable
    surrogate).

-   Mixing/loading/applying with a trigger pump sprayer (used PHED data
    from aerosol can application for dermal exposure to hands as a
    reasonable surrogate).

    []{#__RefHeading___Toc128276236 .anchor}**3.1.6 Recommendations for
    Refining Residential Handler Risk Assessment**

In order to refine this residential risk assessment, more data on actual
use patterns including rates, timing, and areas treated would better
characterize ADBAC risks. In addition, if ORETF hand data are available
separately from other dermal data, then ORETF hand data could be used to
refine the dermal exposures and risks. Exposure studies for many
equipment types that lack data or that are not well represented in PHED
(e.g., because of low replicate numbers or data quality) should also be
considered based on the data gaps identified above and based on a review
of the quality of the data used in this assessment.

[]{#__RefHeading___Toc128276237 .anchor}**3.2 Residential
Postapplication Exposures and Risks**

The Agency uses the term Apostapplication@ to describe exposures to
individuals that occur as a result of being in an environment that has
been previously treated with a pesticide. ADBAC can be used in many
areas that can be frequented by the general population including
residential areas (e.g., home greenhouses, gardens, and residential
turfgrass). As a result, individuals can be exposed by entering these
areas if they have been previously treated.

[]{#__RefHeading___Toc128276238 .anchor}**3.2.1 Residential
Postapplication Exposure Scenarios**

Postapplication exposure scenarios were developed for each residential
setting where ADBAC can be used. Assessing postapplication exposures and
risks resulting from residential uses is very similar to assessing
occupational postapplication exposures and risks (Section 2.2), except
in residential assessments the risks must not be of concern on day 0.

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

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

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

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

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

Usually the Agency considers children of differing ages as well as
adults in its postapplication residential exposure and risk assessments.
However, since the dermal endpoint is for skin irritation potential,
only adults were considered in the assessment. The sole postapplication
residential scenario assessed is for residential adults. These
individuals are members of the general population that are exposed to
chemicals by engaging in activities at their residences (e.g., in home
greenhouses or gardens and residential turfgrass) previously treated
with a pesticide. These kinds of exposures are attributable to a variety
of activities and are usually addressed by the Agency in risk
assessments by considering a representative activity as the basis for
the exposure calculation.

The SOPs for Residential Exposure Assessment define several scenarios
that apply to uses specified in current labels. These scenarios served
as the basis for the residential postapplication assessment along with
the modifications to them and the additional data and approaches
described above. The Agency used this guidance to define the exposure
scenarios that essentially include dermal exposure to adults in treated
greenhouses and gardens and residential turfgrass. The SOPs and the
associated scenarios are presented below:

-   Dose from dermal exposure on treated lawns: Postapplication dermal
    irritation to adults contacting treated turf;

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

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

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

```{=html}
<!-- -->
```
-   Dose from dermal exposure on treated foliage in greenhouses or
    gardens.

    []{#__RefHeading___Toc128276239 .anchor}**3.2.2 Data and Assumptions
    for Residential Postapplication Exposure Scenarios**

[Assumptions and Exposure Factors]{.underline}

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

-   There are many factors that are common to the occupational and
    residential postapplication risk assessments, such as body weights
    for adults and analysis of residue dissipation data, Please refer to
    the assumptions and factors in Section 2.1.2 for further information
    concerning these common values.

-   The Agency combines risks resulting from exposures to individual
    applications when it is likely they can occur simultaneously based
    on the use pattern and the behavior associated with the exposed
    population. For ADBAC, the Agency has combined risks (i.e., MOEs)
    for different kinds of exposures for one scenario: for turf
    scenarios -- hand-to-mouth plus object-to-mouth plus soil ingestion.

```{=html}
<!-- -->
```
-   Exposures to adults and children on treated turf have been addressed
    using the latest the Agency standard operating procedures for this
    scenario including:

    -   5 percent of the application rate has been used to calculate the
        day-zero TTR residue levels used for assessing risks from dermal
        and hand-to-mouth exposures, since ADBAC-specific turf
        transferable residue study data are not available;

    -   20 percent of the application rate has been used to calculate
        the day-zero residue levels used for assessing risks from
        object-to-mouth behaviors (a higher percent transfer has been
        used for object-to-mouth behaviors, because it involves a
        teething action believed to be more analogous to DFR/leaf wash
        sample collection where 20 percent is also used);

    -   3 year old toddlers are expected to weigh 15 kilograms
        (representing an average weight from years one to six);

    -   hand-to-mouth exposures are based on a frequency of 20
        events/hour and a surface area per event of 20 cm^2^,
        representing the palmar surfaces of three fingers;

    -   saliva extraction efficiency is 50 percent meaning that every
        time the hand goes in the mouth approximately ½ of the residues
        on the hand are removed;

    -   object-to-mouth exposures are based on a 25 cm^2^ surface area;

    -   exposure durations for turfgrass scenarios are estimated to be 2
        hours based on information in the Agency's Exposure Factors
        Handbook;

    -   soil residues are contained in the top centimeter and soil
        density is 0.67 mL/gram; and

    -   hand- and object-to-mouth, and soil ingestion are combined to
        represent an overall incidental oral risk from exposure to turf.

```{=html}
<!-- -->
```
-   Exposures to adults working in home greenhouses and gardens have
    been addressed using the latest the Agency approaches for this
    scenario including: the DFR data used for the assessments are the
    default assumption that 20 percent of the application rate is
    available for transfer, since no ADBAC-specific DFR data are
    available.

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

    []{#__RefHeading___Toc128276240 .anchor}**3.2.3 Residential
    Postapplication Exposure and Risk Estimates**

Incidental oral risks were calculated using the Margin of Exposure (MOE)
approach, which is a ratio of the body burden to the toxicological
endpoint of concern. Dermal risks were calculated using the MOE approach
but using a ratio of residue on the skin to the toxicological endpoint
of concern. Exposures were estimated by considering the potential
sources of exposure (i.e., DFRs on ornamental plants and TTRs on treated
turf), then calculating dermal exposures.

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

[Risk Summary]{.underline}:

*Adults*

Table 14 presents the postapplication MOE values calculated for adults
after home greenhouse, garden or turfglass applications of ADBAC. The
dermal MOEs were of concern (i.e., MOEs \<100) on the day of application
for the three scenarios with different application rates.

+-------------------+---------+--------+---------+---------+---------+
| **Table 14:       |         |        |         |         |         |
| ADBAC: Adult      |         |        |         |         |         |
| Residential       |         |        |         |         |         |
| Dermal Risks for  |         |        |         |         |         |
| Postapplication   |         |        |         |         |         |
| Exposure**        |         |        |         |         |         |
+===================+=========+========+=========+=========+=========+
| Exposure Scenario | Route   | Formu  | Appl    | Residue | MOE^c^  |
|                   | of      | lation | ication | on      |         |
|                   | E       |        | Rate^a^ | Skin^b^ | at Day  |
|                   | xposure |        |         |         | 0       |
|                   |         |        | (lb     |         |         |
|                   |         |        | a       |         |         |
|                   |         |        | i/acre) |         |         |
+-------------------+---------+--------+---------+---------+---------+
| Exposure To       | Dermal  | Spray  | 0.43    | 0.96    | **41**  |
| Treated           |         |        |         |         |         |
| Ornamental Plants |         |        |         |         |         |
+-------------------+---------+--------+---------+---------+---------+
| Exposure to       |         |        | 7       | 3.9     | **10**  |
| Treated Turf      |         |        |         |         |         |
+-------------------+---------+--------+---------+---------+---------+
|                   |         |        | 0.9     | 0.5     | **79**  |
+-------------------+---------+--------+---------+---------+---------+

a Maximum application rate on label (lb ai/A).

b Residue concentration available to be transferred on day At@ =
application rate in μg/cm^2^ (lb ai/gal \* conversion factors (lb to μg
and A to cm^2^) \* fraction of DFR or TTR available on day 0 \* percent
of DFR or transferrable to skin (100%).

c Dermal MOE = dermal endpoint (40 ug/cm^2^)/ residue concentration on
skin

*Toddler (3 year old)*

Risks (MOEs) to toddlers were calculated for postapplication risks
following the application of ADBAC to home lawns. Table 15 summarizes
the risk assessment for toddlers. One scenario \-- hand-to-mouth
activity at the higher application rate \-- had MOEs less than 100.
Short-term MOEs were greater than 100 for object-to-mouth activities and
incidental soil ingestion and for hand-to-mouth activity at the lower
application rate.

  ----------------- -------------- -------------- -------------- --------------
  **Table 15.                                                    
  ADBAC: Toddler                                                 
  Residential Risk                                               
  Estimates for                                                  
  Postapplication                                                
  Exposure**                                                     

  Exposure Scenario Route of       Formulation    Application    MOE -- Day
                    Exposure                      Rate^a^ (lb    0^b^
                                                  ai/A)          

  Hand to Mouth     Oral           Spray          7              **96**
  Activity on Turf                                               

  Object to Mouth                                                380
  Activity on Turf                                               

  Incidental Soil                                                29,000
  Ingestion                                                      

  Hand to Mouth     Oral           Spray          0.9            740
  Activity on Turf                                               

  Object to Mouth                                                3,000
  Activity on Turf                                               

  Incidental Soil                                                220,000
  Ingestion                                                      
  ----------------- -------------- -------------- -------------- --------------

a Maximum application rate on label (lb ai/A).

b Incidental Oral MOE = incidental oral endpoint / average daily dose
from incidental ingestion exposure

*Combined Risk Assessment for Residential Scenarios*

The Agency combines risk values resulting from separate postapplication
exposure scenarios when it is likely they can occur simultaneously based
on the use-pattern and the behavior associated with the exposed
population. Table 16 presents a summary of the combined MOE estimates.
The combined risk assessment for exposures to toddlers following home
lawn applications was calculated:

Combined MOE = NOAEL / (ADD~hand-to-mouth~ + ADD~object-to-mouth~ +
ADD~incidental\ soil\ ingestion~)

The combined risk from incidental oral ingestion by toddlers following
applications to home lawns is of concern with an MOE of **76** for the
higher application rate on treated turf (7 lb ai/A), but were not of
concern for the lower application rate on treated turf (0.9 lb ai/A).

+-------------+-------------+-------------+-------------+-------------+
| **Table 16: |             |             |             |             |
| ADBAC:      |             |             |             |             |
| Combined    |             |             |             |             |
| Incidental  |             |             |             |             |
| Oral Risk   |             |             |             |             |
| Estimates - |             |             |             |             |
| Toddlers**  |             |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
| Post        |             |             | Margins of  |             |
| application |             |             | Exposure    |             |
| Exposure    |             |             | (MOEs)      |             |
| Scenario    |             |             |             |             |
|             |             |             | (UF=100)    |             |
+-------------+-------------+-------------+-------------+-------------+
|             |             |             | Short-Term  | Short-Term  |
|             |             |             | Oral        | Oral        |
|             |             |             |             |             |
|             |             |             | (N          | (N          |
|             |             |             | on-Dietary) | on-Dietary) |
+-------------+-------------+-------------+-------------+-------------+
| Toddler     | Turf        | Hand to     | **96**      | **76**      |
|             | application | Mouth       |             |             |
|             | at 7 lb     |             |             |             |
|             | ai/acre     |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
|             |             | Object to   | 380         |             |
|             |             | Mouth       |             |             |
+-------------+-------------+-------------+-------------+-------------+
|             |             | Incidental  | 29,000      |             |
|             |             | Soil        |             |             |
|             |             | Ingestion   |             |             |
+-------------+-------------+-------------+-------------+-------------+
|             | Turf        | Hand to     | 740         | 590         |
|             | application | Mouth       |             |             |
|             | at 0.9 lb   |             |             |             |
|             | ai/acre     |             |             |             |
+-------------+-------------+-------------+-------------+-------------+
|             |             | Object to   | 3,000       |             |
|             |             | Mouth       |             |             |
+-------------+-------------+-------------+-------------+-------------+
|             |             | Incidental  | 220,000     |             |
|             |             | Soil        |             |             |
|             |             |             |             |             |
|             |             | Ingestion   |             |             |
+-------------+-------------+-------------+-------------+-------------+

[]{#__RefHeading___Toc128276241 .anchor}**3.2.4 Residential
Postapplication Exposure and Risk Estimates for Cancer**

Residential postapplication cancer risks were not assessed for ADBAC,
since no toxicological endpoint of concern was identified for cancer.

[]{#__RefHeading___Toc128276242 .anchor}**3.2.5 Summary of Residential
Postapplication Risk Concerns and Data**

[]{#__RefHeading___Toc128276243 .anchor}**Gaps**

In residential settings, the Agency does not use restricted-entry
intervals or other mitigation approaches to limit postapplication
exposures, because they are viewed as impractical and not enforceable.
As such, risk estimates on the day of application are the key concern.

Dermal risks were calculated for adults performing tasks in home
greenhouses and gardens and on home lawns following applications of
ADBAC. The dermal MOEs were of concern (i.e., MOEs \<100) on the day of
application for the three scenarios.

Incidental oral ingestion risks were calculated for toddlers playing on
treated turf. Only one scenario \-- hand-to-mouth activity at the higher
application rate \-- had MOEs \<100. Short-term MOEs were \>100 for
object-to-mouth activities and incidental soil ingestion and for
hand-to-mouth activity at the lower application rate. The combined risk
from incidental oral ingestion by toddlers following applications to
home lawns is of concern with an MOE of **76** for the higher
application rate on treated turf (7 lb ai/A), but with the lower
application rate (0.9 lb/ai/A). The combined MOE was 590 and was not of
concern.

Cancer risks were not calculated, since no toxicological endpoint for
cancer was identified.

[]{#__RefHeading___Toc128276244 .anchor}**3.2.6 Recommendations for
Refining Residential Postapplication Risk Assessments**

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