**Number range CHAPTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY**

**WASHINGTON, D.C. 20460**

![](media/image1.png)

OFFICE OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES

June 13, 2006Number range CHAPTER

**[MEMORANDUM]{.underline}**

SUBJECT: DCNA (Number range CHAPTERDicloran): 2^nd^ Revised Occupational
and Residential Exposure Assessment for the Reregistration Eligibility
Decision.

FROM: Matthew Lloyd, Industrial Hygienist and

Timothy Dole, CIH, Industrial Hygienist

Reregistration Branch 1

Health Effects Division

THRU: Whang Phang, Ph. D., Branch Senior Scientist

> Reregistration Branch 1

#########  Health Effects Division 

TO: James ParkerNumber range CHAPTER, Chemical Review Manager

Special Review and Reregistration Division

DP Barcode: D313892

PC Code: 031301

Number range CHAPTERAttached is the 2^nd^ Revised Occupational and
Residential Exposure Assessment for the DCNA (Dicloran) Registration
Elegibility Decision. Number range CHAPTERThis assessment has been
revised as follows: (1) Inhalation risk calculations for two handler
scenario have been added, (2) The aerial application scenario for the
dust formulation has been deleted, (3)The hand harvesting risk for
lettuce and celery has been refined, (4)The application rate for
potatoes has been increased, and (5) the applications rates for grapes,
deciduous tree fruits, Christmas trees and snap beans has been reduced.

Number range CHAPTERReviewer: Science Advisory Council on Exposure
(7/21/05)

**Table of Contents**

[Executive Summary 3](#__RefHeading___Toc137888300)

[1. Occupational and Residential Exposure/Risk Assessment
6](#__RefHeading___Toc137888307)

[1.1. Criteria for Conducting Exposure Assessments
6](#__RefHeading___Toc137888308)

[1.2. Summary of Hazard Concerns 6](#__RefHeading___Toc137888309)

[1.2.1. DCNA Hazard Concerns 6](#__RefHeading___Toc137888310)

[1.3. Incident Reports 8](#__RefHeading___Toc137888311)

[1.4. Summary of Use Patterns and Formulations
8](#__RefHeading___Toc137888312)

[1.4.1. End-Use Products 9](#__RefHeading___Toc137888313)

[1.4.2. Mode of Action and Targets Controlled
9](#__RefHeading___Toc137888314)

[1.4.3. Registered Use Categories and Sites
9](#__RefHeading___Toc137888315)

[1.4.4. Application Parameters 9](#__RefHeading___Toc137888316)

[2. Occupational Exposures and Risks 11](#__RefHeading___Toc137888317)

[2.1. Occupational Handler Exposures and Risks
11](#__RefHeading___Toc137888318)

[2.1.1. Handler Exposure Scenarios and Calculation Methods
11](#__RefHeading___Toc137888319)

[2.1.2. DCNA Occupational Handler Exposure Risk Estimates
15](#__RefHeading___Toc137888320)

[2.1.3. Overall Summary of Risk Concerns and Data Gaps for Handlers
18](#__RefHeading___Toc137888321)

[2.1.4. Recommendations For Refining Occupational Handler Risk
Assessment 18](#__RefHeading___Toc137888322)

[2.2. Occupational Handler Characterization
18](#__RefHeading___Toc137888323)

[2.3. Occupational Postapplication Exposures and Risks
20](#__RefHeading___Toc137888324)

[2.3.1. Occupational Postapplication Exposure Scenarios and Calculation
Methods 20](#__RefHeading___Toc137888325)

[2.3.2. Data Used for Occupational Postapplication Exposure Scenarios
22](#__RefHeading___Toc137888326)

[2.3.3. Exposure Assumptions, Factors and Transfer Coefficients
23](#__RefHeading___Toc137888327)

[2.3.4. Occupational Postapplication Exposure and Risk Estimates
25](#__RefHeading___Toc137888328)

[2.3.5. Summary of Occupational Postapplication Risk Concerns and Data
Gaps 26](#__RefHeading___Toc137888329)

[2.3.6. Occupational Postapplication Risk Characterization
26](#__RefHeading___Toc137888330)

List of Tables

[Table 1 - Acute Toxicity Study Results for DCNA
6](#__RefHeading___Toc137888350)

[Table 2- Endpoints for Assessing DCNA Non-Dietary Risks
8](#__RefHeading___Toc137888351)

[Table 3 - DCNA Product Formulations 9](#__RefHeading___Toc137888352)

[Table 4 - DCNA Application Rates 10](#__RefHeading___Toc137888353)

[Table 5 - DCNA Dermal MOEs for Agricultural Handlers
16](#__RefHeading___Toc137888354)

[Table 6 - DCNA Inhalation MOEs for Agricultural Handlers
17](#__RefHeading___Toc137888355)

[Table 7 - Summary of Handler Input Values and Their Uncertainty
19](#__RefHeading___Toc137888356)

[Table 8 - Postapplication Exposure Scenarios and Transfer Coefficients
24](#__RefHeading___Toc137888357)

[Table 9 -- DCNA Occupational Postapplication Risks
25](#__RefHeading___Toc137888358)

[Table 10 -- Summary of DCNA Postapplication Risks of Concern
26](#__RefHeading___Toc137888359)

###### 

###### List of Appendices

Appendix A -- DCNA Occupational Handler Risk Calculations

Appendix B -- DCNA DFR Study Information

Appendix C -- DCNA Occupational Post Application Risk Calculations

Number range CHAPTER[]{#__RefHeading___Toc137888300 .anchor}**Executive
Summary**

Number range CHAPTER**Use Information**

Number range CHAPTER Dicloran (DCNA) formulations include wettable
powders, liquid flowables and dusts. Agricultural uses include tree and
vine crops (e.g.,apricots, grapes, nectarines, sweet cherries), row
crops (e.g., lettuce, celery, potatoes and snap beans), and some
greenhouse and hothouse crops (e.g., cucumbers, tomatoes). Horticultural
uses include ornamental plants in nurseries and greenhouses for a
variety of cut flowers. There are no residential labels current for
DCNA.

There are currently 15 active DCNA labels and 10 section 24C
registrations. The application rate per application generally ranges
from 0.75 lb ai/acre to 4.5 lb ai/acre for most crops. The application
rate per year is 4.0 to 7.5 lb ai/acre for most crops. The application
rates in horticulture are 1 lb ai/acre for most ornamentals.
Horticulture applications are allowed as much as once weekly up to a
maximum of 4 lb ai/acre per season.

The application methods were derived from the labels and/or Agency
knowledge of typical use practices and include aerial, airblast,
groundboom, chemigation, and hand application methods such as handwand
and backpack sprayers. The daily acres treated are those typically used
by the Agency for risk assessment (e.g. 80 acres/day for groundboom, 350
acres/day for aerial and 40 acres/day for airblast).

Number range CHAPTER**Toxicology Endpoints**

Number range CHAPTERDCNA is not acutely toxic, but it is a dermal
sensitizer. The following endpoints were used for assessing DCNA risks:

[Exposure Route and Duration]{.underline} [Dose in mg/kg/day (Effects
Observed)]{.underline}

Dermal - short/intermediate Dermal NOAEL of 120 (adrenal weight
changes/histopathological effects)

Dermal - long term Oral NOAEL of 2.5 (clinical chemistry/liver weight
effects)

Inhalation - short/intermediate Oral NOAEL of 2.5 (hematological and
clinical chemistry effects)

Inhalation - long term Oral NOAEL of 2.5 (clinical chemistry/liver
weight effects)

A dermal absorption factor of 100% was used for long term dermal
exposures because the endpoint was based on an oral toxicity study for
long term postapplication scenarios. Risk calculations have been
completed for short/intermediate term exposures for all occupational
scenarios. Long term risks have not been calculated as long term
exposures are not expected because the labels limit the amount that can
be applied each year.

Occupational dermal or inhalation exposures that yield MOEs of 100 or
greater are not of concern for DCNA.

Number range CHAPTER

Number range CHAPTER

Number range CHAPTER**Occupational Handler Risks**

[Data Used for Occupational Handler Risk Assessments]{.underline}

No handler exposure studies were submitted in support of the
re-registration of DCNA, therefore, PHED was used to assess the
occupational handler exposures associated with DCNA applications to
crops and ornamentals. Seed piece treatment scenarios were not assessed
and remain as a data gap.

[Dermal Handler Risks]{.underline}

The dermal risks for loading dust are of concern at baseline and require
single layer PPE (i.e. chemical resistant gloves) to achieve MOEs of 100
or greater. The dermal risks for mixing/loading wettable powder to
support aerial application and chemigation are of concern at all PPE
levels and require engineering controls (i.e. water soluble bags)
achieve acceptable MOEs. The dermal risks for mixing/loading wettable
powder for ground application are less of a concern and can be addressed
with single layer PPE. The risks for the remaining scenarios
(applicators, flagger and mixer/loader/applicator) are not of concern
with baseline or single layer PPE.

[Inhalation Handler Risks]{.underline}

The inhalation risks for loading dust are of concern at baseline and
require PF10 respiratory protection to achieve MOEs of 100 or greater.
The inhalation risks for mixing/loading wettable powder to support
aerial application and chemigation are of concern at all PPE levels and
require engineering controls (i.e. water soluble bags) achieve
acceptable MOEs. The inhalation risks for mixing/loading wettable powder
for ground application are less of a concern and can be addressed with
PF5 or PF10 respiratory protection. The risks for the remaining
scenarios are not of concern with baseline or single layer PPE.

Number range CHAPTER**Occupational Postapplication Risks**

[Number range CHAPTERData Used for Postapplication Exposure
Assessment]{.underline}

Number range CHAPTEROne recent dislodgeable foliar residue (DFR) study
(completed in 2000) (MRID 450620-01) was submitted by Gowan Company. The
study involved the application of Botran^®^ 75WP wettable powder to snap
beans, DFR samples were collected using the standard methodology and
were analyzed for DCNA the using electron gas chromatography analysis.
Complete descriptions of the analytical methods and method validation
data were included in the study reports. This study was reviewed by the
Agency (Lloyd, D279651), it was found to comply with the series 875
guidelines. The study was adequate for exposure and risk assessment
purposes.

[Occupational Post Application Risk Summary]{.underline}

Post application dermal exposures occur when workers enter treated
fields to perform tasks such as irrigation, thinning and hand
harvesting. These exposures were assessed using the DFR data described
above and standard transfer coefficients from ExpoSAC Policy 3.1. Some
of the MOEs for post application exposures are less than 100 at the
currently labeled REI of 12 hours and the time needed to achieve MOEs of
100 ranges from 2 for hand harvesting snap beans, cut flowers,
greenhouse lettuce and endive to 32 days for cane turning and girdling
grapes. In some cases, the MOEs for hand harvesting are acceptable at
the Pre Harvest Intervals (PHIs) which are longer than the REI. The MOE
for the high hand harvesting celery, florence and fennel is 100 on day 7
which is the same as the PHI. This means that hand harvesting exposures
are not of concern because they will not occur until 7 days after
application at which time the MOE will have risen to 100 due to DFR
decline. The hand harvesting exposures for snap beans, greenhouse grown
lettuce and endive are also not of concern because the MOEs exceed 100
at the PHIs of 2 days for snap beans, 14 days for greenhouse grown
lettuce and 14 days for endive.

Number range CHAPTER**Data Gaps and Recommendations for Refinement**

The risks of dipping sweet potato seed pieces were not assessed because
dipping is no longer used. According to sweet potato researchers at
Sweet Potato Research Station (LSU), sweet potato seed pieces are
treated in the plant bed using a sprayer.

The risks of post-harvest dip treatment of sweet potatoes were not
assessed due to a lack of exposure data. This treatment is accomplished
by using automated equipment; however, exposures can be minimized with
the use of gloves.

The risk of loading the dust formulation was assessed with surrogate
unit exposure values from mixing and loading wettable powders. The risk
of applying dust formulations was not assessed due to lack of exposure
data and remains as a data gap.

Number range CHAPTERIt was reported that aerial application was not
usually used for applying fungicides to orchards and vineyards; however,
this method was assessed for these crops because it was included on the
labels and might be necessary during wet seasons. Information regarding
the types of formulations, if any, used for aerial application could be
used to refine the risk.

DCNA products are packaged as wettable powders, dusts, and liquid
flowables. The labels indicate that only the wettable powder
formulations can be used on all of the crops; however, it is suspected
that liquid formulations can be used. This information is critical
because the dust and wettable powder formulations create the highest
exposures particularly when it is used at high rates. These exposures
can be greatly reduced by using the liquid formulations or by using the
wettable powder in water soluble bags.

There are no data available to evaluate the mix/load/apply scenarios for
backpack sprayer application of wettable powders. The PHED data for both
high and low pressure handwand application of liquids (mix/load/apply
and apply only) is also of low quality. These data gaps make it
difficult to accurately assess the risks of the handwand method of
application which is commonly used in horticulture.

1.  Number range CHAPTER[]{#__RefHeading___Toc137888307
    .anchor}**Occupational and Residential Exposure/Risk Assessment**

Number range CHAPTERThis document is the occupational and residential
non-dietary exposure and risk assessment for DCNA (Dicloran) to be used
in the re-registration process.

1.  Number range CHAPTER[]{#__RefHeading___Toc137888308
    .anchor}**Criteria for Conducting Exposure Assessments**

Number range CHAPTERAn 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, flaggers, etc.)
during use or to persons entering treated sites after application is
complete. Toxicological endpoints have been selected for short-,
intermediate-, and long-term exposures to DCNA. There is a significant
potential for exposure in a substantial number of agricultural and
commercial settings. Therefore, risk assessments are required for
occupational handlers and occupational postapplication exposures that
can occur as a result of DCNA use.

2.  Number range CHAPTER[]{#__RefHeading___Toc137888309
    .anchor}**Summary of Hazard Concerns**

    1.  Number range CHAPTER[]{#__RefHeading___Toc137888310
        .anchor}**DCNA Hazard Concerns**

Number range CHAPTERThe acute toxicity data indicate that DCNA has low
acute toxicity by the oral, dermal and inhalation routes. Dicloran is a
mild ocular irritant but not a dermal irritant, and it is a dermal
sensitizer. Table 1 summarizes the acute toxicity data for DCNA.

  --------------------------------- ---------------- ----------------- ----------------------------- ------------
  []{#__RefHeading___Toc137888350                                                                    
  .anchor}**Table 1 - Number range                                                                   
  CHAPTERAcute Toxicity Study                                                                        
  Results for DCNANumber range                                                                       
  CHAPTER**                                                                                          

  **Guideline No.**                 **Study Type**   **MRID**          **Results**                   **Toxicity
                                                                                                     Category**

  870.1100/§81-1                    Acute Oral --    0006879           LD~50~ = 1000 mg/kg           IV
                                    rat                                                              

  870.1200/§81-2                    Acute Dermal --  Number range      LD~50~ = \>2000 mg/kg         III
                                    rabbit           CHAPTER00086894                                 

  870.1300/§81-3                    Acute Inhalation Number range      LC50 = N/A                    N/A
                                                     CHAPTERNot                                      
                                                     Available                                       

  870.2400/§81-4                    Number range     00086892          Mild ocular irritant          III
                                    CHAPTERPrimary                                                   
                                    Eye Irritation                                                   

  870.2500/§81-5                    Number range     00086893          Not a dermal irritant         IV
                                    CHAPTERPrimary                                                   
                                    Skin Irritation                                                  

  870.2600/§81-6                    Number range     00082721          Potential dermal sensitizer   N/A
                                    CHAPTERDermal                                                    
                                    Sensitization                                                    
  --------------------------------- ---------------- ----------------- ----------------------------- ------------

Number range CHAPTERThe toxicological endpoints that were used to
complete the occupational risk assessments for DCNA are listed in Table
2. Effects were identified at different durations of exposure ranging
from short-term (up to 30 days) to intermediate-term (up to 180 days)
and including long term (more than 180 days).

The incidental oral endpoints for DCNA were based on a 90-day oral study
in dogs (MRID Number range CHAPTER00029056, 00026810). The effects that
were observed and selected as the basis for the endpoint were
hematological and clinical biochemistry and included reduced body weight
gain, increased liver, spleen, and kidney weights, and histopathological
changes in the liver. A No Observed Adverse Effect Level (NOAEL) of 2.5
mg/kg/day was identified in the study. The results of this study were
applied to short and intermediate term exposure durations. No endpoints
were selected for long term incidental oral exposures because these
exposures were not anticipated to occur based upon DCNA use patterns in
the residential environment.

The endpoint for short and intermediate term dermal exposure was based
upon a 21 day dermal toxicity study on rabbits (MRID Number range
CHAPTER40555101) during which increased adrenal weights in males and
other effects were observed with a NOAEL of 120 mg/kg/day. The endpoint
for long term dermal exposure is based upon two chronic toxicity study
in dogs (MRID Number range CHAPTER45610801 (new study), Number range
CHAPTER00029056, 00082718 (old study) during which a number of clinical
chemistry changes were observed (increased alkaline phosphatase in both
sexes, increased liver weights, hepatocyte hypertrophy, vacuolar
alterations of the brain and spinal cord, etc.). A NOAEL of 2.5
mg/kg/day was identified in the study.

The endpoint for short and intermediate inhalation exposures is based on
the same 90 day oral toxicity study in dogs that was used to determine
the incidental oral endpoints. The NOAEL for the study was 2.5
mg/kg/day. The endpoint for long term inhalation exposure is based upon
a two year chronic toxicity study in dogs (MRID Number range
CHAPTER45610801 (new study), Number range CHAPTER00029056, 00082718 (old
study)) during which a number of clinical chemistry changes were
observed (increased alkaline phosphatase in both sexes, increased liver
weights, hepatocyte hypertrophy, vacuolar alterations of the brain and
spinal cord, etc.) A NOAEL of 2.5 mg/kg/day was identified in the study.

As indicated in Table 2, all of the long term endpoints for dermal and
inhalation exposures are based upon hematological and clinical
biochemistry effects. Since the revised product labels include maximum
seasonal rates, chronic exposures scenarios are no longer applicable to
the risk assessment and are not included in this chapter.

No dermal absorption studies are available on DCNA. Dermal absorption of
structurally related compounds varied. Therefore, according to OPP
policy, a default dermal absorption rate of 100% should be assumed, due
to lack of appropriate data. Because the DCNA short/intermediate dermal
endpoint is based upon a dermal toxicity study, the dermal absorption
factor is not needed when assessing short/intermediate dermal exposures
to DCNA. The dermal absorption factor is only needed when assessing long
term dermal exposures.

The Agency's level of concern for the handler risks is defined by the
uncertainty factors that are applied to the assessment. The level of
concern for the DCNA occupational dermal and inhalation exposures is an
MOE of less than 100 which includes the factors of 10 to account for
interspecies extrapolation to humans from the animal test species and
the factor of 10 to account for intraspecies sensitivity variation.

+-----------------+------------+----------------------+--------------+
| [               |            |                      |              |
| ]{#__RefHeading |            |                      |              |
| ___Toc137888351 |            |                      |              |
| .anchor}**Table |            |                      |              |
| 2Number range   |            |                      |              |
| CHAPTER-        |            |                      |              |
| Endpoints for   |            |                      |              |
| Assessing DCNA  |            |                      |              |
| Non-Dietary     |            |                      |              |
| RisksNumber     |            |                      |              |
| range CHAPTER** |            |                      |              |
+=================+============+======================+==============+
| **Exposure**    | **Dose**   | **Endpoint**         | **Study**    |
|                 |            |                      |              |
| **Scenario**    | **(mg      |                      |              |
|                 | /kg/day)** |                      |              |
+-----------------+------------+----------------------+--------------+
| **Incidental    |            |                      |              |
| Oral Exposures  |            |                      |              |
| (Pos            |            |                      |              |
| tapplication)** |            |                      |              |
+-----------------+------------+----------------------+--------------+
| \[ST and IT\]   | NOAEL =    | Hematological and    | 90 day       |
|                 | 2.5        | clinical             | Feeding, dog |
|                 |            | biochemistry --      |              |
|                 |            | reduced body weight  |              |
|                 |            | gain, increased      |              |
|                 |            | liver, spleen, and   |              |
|                 |            | kidney weights,      |              |
|                 |            | histopathological    |              |
|                 |            | changes in the liver |              |
+-----------------+------------+----------------------+--------------+
| **Dermal        |            |                      |              |
| Exposures**     |            |                      |              |
+-----------------+------------+----------------------+--------------+
| Short-Term      | NOAEL =    | Increased adrenal    | 21-day       |
| \[1-30 days\]   | 120        | weights in males     | Dermal,      |
|                 |            |                      | rabbit       |
+-----------------+------------+----------------------+--------------+
| In              | NOAEL =    | Increased adrenal    | 21-day       |
| termediate-Term | 120        | weights in males     | Dermal,      |
|                 |            |                      | rabbit       |
| \[\>30 days to  |            |                      |              |
| 6 mos.\]        |            |                      |              |
+-----------------+------------+----------------------+--------------+
| Long-Term \[\>  | NOAEL =    | Clinical Chemistry   | 2-year       |
| 6 months\]      | 2.5        | changes, increased   | Chronic, dog |
|                 |            | liver weights,       |              |
|                 |            | hepatocyte           |              |
|                 |            | hypertrophy,         |              |
|                 |            | vacuolar alterations |              |
|                 |            | of the brain and     |              |
|                 |            | spinal cord,         |              |
|                 |            | prostate atrophy,    |              |
|                 |            | degeneration of the  |              |
|                 |            | seminiferous         |              |
|                 |            | tubules, hypospermia |              |
|                 |            | in the epididymides  |              |
+-----------------+------------+----------------------+--------------+
| **Inhalation    |            |                      |              |
| Exposures**     |            |                      |              |
+-----------------+------------+----------------------+--------------+
| Short-Term      | NOAEL =    | Hematological and    | 90 day       |
| \[1-30 days\]   | 2.5        | clinical             | Feeding, dog |
|                 |            | biochemistry --      |              |
|                 |            | reduced body weight  |              |
|                 |            | gain, increased      |              |
|                 |            | liver, spleen, and   |              |
|                 |            | kidney weights,      |              |
|                 |            | histopathological    |              |
|                 |            | changes in the liver |              |
+-----------------+------------+----------------------+--------------+
| In              | NOAEL =    | Hematological and    | 90 day       |
| termediate-Term | 2.5        | clinical             | Feeding, dog |
|                 |            | biochemistry --      |              |
| \[\>30 days to  |            | reduced body weight  |              |
| 6 mos.\]        |            | gain, increased      |              |
|                 |            | liver, spleen, and   |              |
|                 |            | kidney weights,      |              |
|                 |            | histopathological    |              |
|                 |            | changes in the liver |              |
+-----------------+------------+----------------------+--------------+
| Long-Term \[\>6 | NOAEL =    | Clinical Chemistry   | 2-year       |
| months\]        | 2.5        | changes, increased   | Chronic, dog |
|                 |            | liver weights,       |              |
|                 |            | hepatocyte           |              |
|                 |            | hypertrophy,         |              |
|                 |            | vacuolar alterations |              |
|                 |            | of the brain and     |              |
|                 |            | spinal cord,         |              |
|                 |            | prostate atrophy,    |              |
|                 |            | degeneration of the  |              |
|                 |            | seminiferous         |              |
|                 |            | tubules, hypospermia |              |
|                 |            | in the epididymides  |              |
+-----------------+------------+----------------------+--------------+

The committee members of CARC evaluated the available carcinogenicity
toxicity data of DCNA and classified DCNA as having "Suggestive Evidence
of Carcinogenic Potential" and recommended no quantification of cancer
risk.

3.  Number range CHAPTER[]{#__RefHeading___Toc137888311
    .anchor}**Incident Reports**

Number range CHAPTER The incident report was prepared under a separate
memo (D294468 of April 14, 2005) by Jerome Blondell, Ph.D. There were no
incidents reported in the OPP Incident Data System from 1992 to 2002.
There were 7 exposures reported to the Poison Control Centers
(1993-2001) and 1 case has medical outcome determined with dermal
symptoms characterized as minor. Two involved children under age six,
one was occupational, and the other four were adults exposed in a
non-occupational setting. There were no reports of DCNA poisoning in the
California Pesticide Illness Surveillance Program (1982-2002).

4.  Number range CHAPTER[]{#__RefHeading___Toc137888312
    .anchor}**Summary of Use Patterns and Formulations**

Number range CHAPTERDCNA products are described in this section.
Additionally, available information that describes the manner in which
registered DCNA end-use products are used is provided in this section
(e.g. use categories/sites, application methods and application rates).

1.  Number range CHAPTER[]{#__RefHeading___Toc137888313
    .anchor}**End-Use Products**

Number range CHAPTERDicloran (2,6-dicloro-4-nitroaniline), also called
DCNA, belongs to the substituted aromatics class of pesticides and is
marketed in a variety of end-use products for occupational use. End-use
product names include Botran^®^ 6 Dust, Diclor Fungicide, Botran^®^
75-W, Botran^®^ 5F, Botran^®^ Sulfur 6-25.

DCNA formulations include dusts, flowables (liquid); and wettable
powders. The active products (per result of an OPPIN search on 2/03/05)
are listed in Table 3. Miscellaneous SLN's are not included below in
Table 3 as they are derived from the parent labels and represent the
same crop usage in all cases.

  ----------------------------------- -----------------------------------
  []{#__RefHeading___Toc137888352     
  .anchor}**Table 3 - Number range    
  CHAPTERDCNA Product Formulations**  

  **Formulation Type**                **EPA Registration Number (% Active
                                      Ingredient)**

  **Technical/Formulation**           10163-195 (95), 10163-239 (65)

  **Liquid Flowable**                 10163-221 (43.1), 10163-226 (46.7)

  **Wettable Powders**                10163-189 (75.0), 10163-207 \[WSB\]
                                      (75.0),

  **Dusts**                           10163-187 (8.0), 10163-188 (6.0),
                                      10163-190 (12.0), 10163-191 (15.0),
                                      10163-192 (10.0), 10163-193 (4.0),
                                      10951-13 (6.0), 10951-14 (6.0),
                                      2935-529 (6.0).
  ----------------------------------- -----------------------------------

> *\[WSB\]= water soluble bag*

2.  Number range CHAPTER[]{#__RefHeading___Toc137888314 .anchor}**Mode
    of Action and Targets Controlled**

Number range CHAPTERDCNA is used as a contact fungicide. It is
considered highly useful against grey mold (*Botrytis cinerea),* and
white mold *(Sclerotinia sclerotiorum).* It is also effective on the
post-harvest fungi *Botrytis,* *Rhizopus,* and *Monolinia* spp. DCNA
prevents or inhibits normal spore germination and it suppresses the
growth of fungus mycelium once infections are established.

3.  Number range CHAPTER[]{#__RefHeading___Toc137888315
    .anchor}**Registered Use Categories and Sites**

Number range CHAPTER[Occupational Use Sites]{.underline}

Occupational populations are potentially exposed while making DCNA
applications to the following targets or from contact with the treated
targets. Use categories include tree and vine crops; vegetable crops;
grapes; conifers/christmas trees; greenhouse grown flowers; greenhouse
grown vegetables.

4.  Number range CHAPTER[]{#__RefHeading___Toc137888316
    .anchor}**Application Parameters**

Number range CHAPTER[Application Rates]{.underline}

The application rates are provided in Table 4. The current label
application rates were derived from the product labels and/or the Use
Closure Memo of August 14, 2003. The revised label rates are based upon
risk mitigation negotiations between SRRD and the Registrant and will be
incorporated into the RED.

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| 7888353 |            |        |       |         |       |          |
| .ancho  |            |        |       |         |       |          |
| r}Table |            |        |       |         |       |          |
| 4 -     |            |        |       |         |       |          |
| Number  |            |        |       |         |       |          |
| range   |            |        |       |         |       |          |
| CHAP    |            |        |       |         |       |          |
| TERDCNA |            |        |       |         |       |          |
| Appl    |            |        |       |         |       |          |
| ication |            |        |       |         |       |          |
| Rates   |            |        |       |         |       |          |
+=========+============+========+=======+=========+=======+==========+
| **Crop  | **Crop or  | **C    |       | **      |       | **SLUA   |
| Group** | Target**   | urrent |       | Revised |       | Max. %   |
|         |            | Label  |       | Label   |       | Crop     |
|         |            | R      |       | Rates** |       | Trea     |
|         |            | ates** |       |         |       | ted^3^** |
|         |            |        |       | **(lb   |       |          |
|         |            | **(lb  |       | ai/acr  |       |          |
|         |            | a      |       | e)^2^** |       |          |
|         |            | i/acre |       |         |       |          |
|         |            | )^1^** |       |         |       |          |
+---------+------------+--------+-------+---------+-------+----------+
|         |            | **Max. | *     | **Max.  | *     |          |
|         |            | Per    | *Max. | Per     | *Max. |          |
|         |            | A      | Per   | Applic  | Per   |          |
|         |            | pplica | Sea   | ation** | Y     |          |
|         |            | tion** | son** |         | ear** |          |
+---------+------------+--------+-------+---------+-------+----------+
| Fi      | Snap Beans | 3.75   | NS    | 2.0     | 4     | NS       |
| eld/Row |            |        |       |         |       |          |
| Crops,  |            |        |       |         |       |          |
| Low     |            |        |       |         |       |          |
| /Medium |            |        |       |         |       |          |
+---------+------------+--------+-------+---------+-------+----------+
| Cut     | Chry       | 0.75   | w     | 0.75    | 4     | \<50     |
| Flowers | santhemums |        | eekly |         |       | lbs.     |
|         |            | 1      |       | 1       |       | Nati     |
|         | Roses,     |        | NS    |         |       | onally\* |
|         | Hydrangeas |        |       |         |       |          |
+---------+------------+--------+-------+---------+-------+----------+
| Ornam   | Geraniums  | 0.75   | NS    | 0.75    | 4     | \<50     |
| entals, |            |        |       |         |       | lbs.     |
| Potted  |            |        |       |         |       | Nati     |
| Plants  |            |        |       |         |       | onally\* |
+---------+------------+--------+-------+---------+-------+----------+
| Veg     | Cucumbers, | 1      | NS    | 1       | 4     | NS       |
| etable, | Rhubarb    |        |       |         |       |          |
| C       |            |        |       | 2       |       | NS       |
| ucurbit |            |        |       |         |       |          |
+---------+------------+--------+-------+---------+-------+----------+
| Veg     | Tomatoes   | 1      | 4     | 0.75    | 4     | \<2.5    |
| etable, |            |        |       |         |       |          |
| F       |            |        |       |         |       |          |
| ruiting |            |        |       |         |       |          |
+---------+------------+--------+-------+---------+-------+----------+
| Tree,   | Apricots,  | 4      | NS    | 1.5     | 4     | \<2.5    |
| Fruit,  | Peaches,   |        |       |         |       | -peaches |
| De      | N          |        |       |         |       |          |
| ciduous | ectarines, |        |       |         |       | NS-all   |
|         | Plums,     |        |       |         |       | others   |
|         | Prunes,    |        |       |         |       |          |
|         | Cherries   |        |       |         |       |          |
+---------+------------+--------+-------+---------+-------+----------+
| Tree,   | Conifers,  | 2      | NS    | 1.5     | 4     | NS       |
| Fruit,  | Christmas  |        |       |         |       |          |
| Ev      | Trees      |        |       |         |       |          |
| ergreen |            |        |       |         |       |          |
+---------+------------+--------+-------+---------+-------+----------+
| Veg     | Lettuce    | 4      | 4     | 2       | 4     | 15       |
| etable, |            |        | lb/cc |         |       |          |
| Leafy,  |            |        |       |         |       |          |
| Gre     |            |        |       |         |       |          |
| enhouse |            |        |       |         |       |          |
+---------+------------+--------+-------+---------+-------+----------+
| Veg     | Potatoes   | 4.5    | 7.5   | 4.5     | 7.5   | \<2.5    |
| etable, |            |        |       |         |       |          |
| Root    |            |        |       |         |       |          |
+---------+------------+--------+-------+---------+-------+----------+
| Veg     | Celery,    | 1      | 4     | 4       | 5     | 6        |
| etable, | florence,  |        | lb/cc |         |       | 0-celery |
| Leafy,  | fennel     |        |       | 4       | 4     |          |
| O       |            |        |       |         |       | 15       |
| utdoors | Lettuce    |        |       | 2       | 4     | -lettuce |
|         |            |        |       |         |       |          |
|         | Endive     |        |       |         |       | N        |
|         |            |        |       |         |       | S-endive |
+---------+------------+--------+-------+---------+-------+----------+
| Veg     | (onions,   | 4      | 4     | 4       | 4     | \<2.5    |
| etable, | garlic     |        | lb/cc |         |       | -onions, |
| Root    | shallots)  | 120    |       | 120     | 120   | garlic   |
|         |            |        | NS    |         |       |          |
|         | (sweet     |        |       |         |       | NS-all   |
|         | potatoes)  |        |       |         |       | others   |
+---------+------------+--------+-------+---------+-------+----------+
| Vine/   | Grapes     | 3.5    | 3.5   | 1.5     | 4     | 15       |
| Trellis | (various   |        | lb/cc |         |       |          |
|         | types)     |        |       |         |       |          |
+---------+------------+--------+-------+---------+-------+----------+

1 - Current label rates are taken from currently registered products.

2 -- Revised label rates are from RED mitigation negotiations between
SRRD and the Registrant (June 2006)

Rates for ornamentals/greenhouse are given in lbs ai/100 gallons and
were converted to lb ai/acre by assuming that 100 gallons of spray would
be applied per acre.

NS -- Not Specified

cc -- Crop Cycle

3 - SLUA Maximum Percentage Crop Treated -- from SLUA report June 29,
2005

\<2.5 indicates that less than 2.5% of the crop is treated

\<50 pounds Nationally -- indicates that less than 50 lbs. is applied
via foliar application (from NASS Floriculture Survey -- 2003)

Number range CHAPTER[Application Equipment]{.underline}

A summary of the application equipment used is given below:

-   **Conifers and Christmas Trees**: aerial and airblast.

-   **Tree and Vine Crops**: aerial and airblast.

-   **Field/Row Crops**: groundboom, aerial, and chemigation.

-   **Vegetables**: groundboom, aerial, and chemigation.

-   **Ornamentals**: low-pressure (LP) handwand, backpack, high-pressure
    (HP) handwand, and groundboom.

-   **Greenhouse**: low-pressure (LP) handwand, backpack, high-pressure
    (HP) handwand, and groundboom.

Number range CHAPTER

2.  Number range CHAPTER[]{#__RefHeading___Toc137888317
    .anchor}**Occupational Exposures and Risks**

Number range CHAPTERIt has been determined there is the potential for
exposure in occupational scenarios from handling DCNA products during
the application process and from entering areas previously treated with
DCNA. As a result, risk assessments have been completed for both handler
and postapplication scenarios.

1.  Number range CHAPTER[]{#__RefHeading___Toc137888318
    .anchor}**Occupational Handler Exposures and Risks**

Number range CHAPTERThe 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 crop or target
being treated, and the circumstances of the user (e.g., the level of
protection used by an applicator) can cause exposure levels to differ in
a manner specific to each application event. Handler tasks can generally
be categorized using one of the following terms:

-   Mixer/loaders

-   Applicators

-   Mixer/loader/applicators

-   Flaggers

    1.  Number range CHAPTER[]{#__RefHeading___Toc137888319
        .anchor}**Handler Exposure Scenarios and Calculation Methods**

Number range CHAPTER[Handler Exposure Scenarios]{.underline}

The use patterns and labels indicate several major occupational exposure
scenarios based on the types of equipment and techniques that can
potentially be used to make DCNA applications. The quantitative
exposure/risk assessment developed for occupational handlers is based on
the following scenarios:

**Agricultural Crop Treatment Scenarios:**

Mix/Load wettable powder, dusts or liquids

Apply using Aerial, Groundboom, Airblast or HP Handwand application
methods

Mix/Load/Apply wettable powder with a LP handwand and backpack sprayer;

Mix/Load/Apply liquids with a LP handwand and backpack sprayer;

Mix/Load/Apply dusts with a Handheld Power Duster;

Flag aerial application of liquids

Number range CHAPTER[Calculation Methods:]{.underline}

The Agency uses a concept known as unit exposure as the basis for
assessing handler exposures. The unit exposure is amount of exposure
that occurs while handling a pound of active ingredient. Daily exposures
are calculated by considering application parameters (i.e., rate and
area treated) along with unit exposure levels. Exposures are then
normalized by body weight to calculate dose levels and the Margin of
Exposure (MOE).

**Daily Exposure:** The daily exposures to handlers are calculated as
described below. The first step is to calculate daily exposure (dermal
or inhalation) using the following formula:

**Daily Exposure = Unit Exposure x Application Rate x Amount Treated**

Where:

**Daily Exposure** = Amount deposited on the surface of the skin or
amount that is inhaled

(mg ai/day);

**Unit Exposure** = Normalized exposure value, derived from August 1998
PHED Surrogate

Exposure Table and various referenced exposure studies (mg ai/lb ai);

**Application Rate** = Amount of a.i. applied per unit treated such as
acres or pounds of seed

**Amount Treated** = Typically expressed as acres/day for crops and
pounds/day for seed.

Inhalation exposure values are calculated in a similar manner. The only
difference is that unit exposure values representing the inhalation
route are calculated using PHED and standard human breathing rates (29
liters/minute and an 8 hour exposure).

**Daily Dose:** Daily dose (inhalation or dermal) are then calculated by
normalizing the daily dermal exposure value by body weight. It should
also be noted that a dermal absorption factor is not needed for DCNA,
because the dermal endpoint was based upon a dermal study. The
inhalation absorption factor is assumed to be 100 percent because the
inhalation endpoint was based upon an oral study. Daily dose is
calculated using the following formula:

**Average Daily Dose**
$\left( \frac{\text{mg}}{\frac{\text{kg}}{\text{day}}} \right)$ **=
Daily Exposure**
$\left( \frac{\text{mg}\text{.}\text{ai}}{\text{day}} \right)$ **x**
$\left( \frac{\text{absorptionfactor}(\text{\%/}\text{100})}{\text{Bodyweight}(\text{kg})} \right)$

Where:

**Average Daily Dose** = The amount as absorbed dose received from
exposure to a pesticide in a given scenario (mg pesticide active
ingredient/kg body weight/day);

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

**Absorption Factor** = N/A for dermal exposures

100 percent for inhalation exposures

**Body Weight** = 70 kg for DCNA because the endpoints are not gender
specific.

The handler exposure assessment does not include any dietary or drinking
water inputs.

**Margins of Exposure:** Finally, the daily dermal dose and daily
inhalation dose received by handlers are compared to the appropriate
endpoint (i.e., NOAEL or LOAEL) to obtain a Margin of Exposure (MOE).
All MOE values were calculated separately for dermal and inhalation
exposures using the formula below:

**MOE = NOAEL/ADD**

Where:

> **MOE =** Margin of exposure
>
> **ADD =** Average Daily Dose (mg ai/kg/day) or the amount as absorbed
> dose received from exposure to a pesticide in a given scenario
>
> **NOAEL =** No Observed Adverse Effects Level (mg ai/kg/day).

The level of concern for all assessments is established by the
uncertainty factor. The uncertainty factor is 100 for both dermal and
inhalation occupational exposures.

Number range CHAPTER**Data and Assumptions for Occupational Handler
Exposure Scenarios**

Number range CHAPTERA series of assumptions and exposure factors served
as the basis for completing the occupational handler risk assessments.
Each assumption and factor is detailed below.

-   It is anticipated that the occupational handler DCNA exposures will
    generally occur in a short- and intermediate-term pattern because
    the labels limit the amount that can be applied per year.

-   No PHED data were available for loading dusts. The PHED baseline
    unit exposure data for mixing and loading wettable powders (3.7
    mg/lb ai for dermal and 43 g/lb for inhalation) were used to
    calculate dermal and inhalation exposures for loading dusts.

-   No PHED data were available for applying dusts with ground
    equipment. Applicator exposures from these scenarios remain as a
    data gap.

-   No PHED data were available for the loading and applying dust with a
    handheld power duster. This scenario remains as a data gap.

-   Several generic protection factors were used to calculate handler
    exposures. The values used for respiratory protection (i.e., PF 5 or
    PF 10) are based on the *NIOSH Respirator Decision Logic.*

-   It is understood that human flagging is an uncommon because Global
    Positioning Satellite (GPS) technology is now predominantly used as
    indicated by the 2003 National Agricultural Aviation Association
    (NAAA) survey of their membership. This survey did indicate,
    however, that human flaggers are still used in approximately 4
    percent of aerial application operations. The Agency strongly
    encourages the use of GPS, but will continue to evaluate risks for
    human flaggers until the potential for exposure is eliminated.

-   The revised application rates were used as listed in Table 4.

```{=html}
<!-- -->
```
-   The acres treated per day values were taken from Health Effects
    Division Science Advisory Committee on Exposure *Policy 9.1:
    Standard Values for Daily Acres Treated in Agriculture* of September
    25, 2001. These factors are listed below:

```{=html}
<!-- -->
```
-   Aerial applications: 350 acres;

-   Chemigation: 350 acres for most crops

-   Groundboom: 80 acres treated

-   Groundboom (sweet potatoes): 3 acres/day for plant bed spray based
    on the assumption that one acre of bedded seed will produce enough
    transplants for 100 acres of potatoes (USDA Crop Profile for Sweet
    Potatoes in Texas, June 2003).

-   Airblast: 40 acres treated

-   High Pressure Handwand: 10 acres for ornamental applications based
    on the assumption that at least 100 gallons are applied per acre and
    1000 gallons are applied per day;

-   Backpack Sprayer: 0.40 acres per day based on the assumption that at
    100 gallons are applied per acre and 40 gallons are applied per day;

-   [Baseline PPE:]{.underline} includes typical work clothing (i.e., a
    long-sleeved shirt, long pants, shoes, socks, and no respiratory
    protection). It does not include chemical-resistant gloves.

-   [Single Layer PPE:]{.underline} includes chemical-resistant gloves
    in addition to baseline clothing.

-   [Double Layer PPE:]{.underline} adds coveralls to single layer PPE.

-   [PF5 Respirator]{.underline}**:** is a respirator with a protection
    factor of 5 (i.e., it provides 80 percent inhalation protection). A
    PF5 respirator is a filtering facepiece respirator (i.e. a dustmask)
    that provides dust/mist filtering only.

-   [PF10 Respirator:]{.underline} is a respirator with a protection
    factor of 10 (i.e., it provides 90 percent inhalation protection). A
    PF10 respirator is a half-face elastomeric facepiece with
    appropriate cartridges for dust/mists and/or organic vapors.

-   [Engineering Controls (EC):]{.underline} includes enclosed tractor
    cab, enclosed cockpit, water soluble bags and closed loading
    systems.

    **Unit Exposure Data Sources**

    All of the unit exposure values used in this assessment were based
    upon the **Pesticide Handler Exposure Database (PHED) Version 1.1
    (August 1998).** PHED was designed by a task force of
    representatives from the U.S. EPA, Health Canada, the California
    Department of Pesticide regulation, and member companies of the
    American Crop Protection Association. Currently, the database
    contains values for over 1,700 monitored individuals (i.e.,
    replicates) and HED has developed a series of tables of standard
    unit exposure values for many occupational scenarios that can be
    utilized to ensure consistency in exposure assessments. These values
    are included in the "PHED Surrogate Exposure Guide" of August 1998.

    [Exposure Data Used for Agricultural Handlers and
    Applicators]{.underline}

    No additional chemical-specific data that had not been previously
    considered in the development of PHED were submitted to the Agency
    for the reregistration of DCNA. Therefore all of the handler
    assessments were performed using PHED data. These data are listed in
    Appendix A. There are no exposure data in PHED that are relevant to
    the application of dusts; therefore, dust application scenarios were
    not evaluated.

    [Exposure Data Used for Seed Piece Treatment:]{.underline}

    No chemical specific data are available for assessing exposures
    during seed piece treatments.

    No data are available to assess post-harvest dipping operations and
    because this operation is less hazardous than other scenarios
    assessed here, protective gloves should be adequate for PPE. This
    scenario is a "data gap."

    1.  Number range CHAPTER[]{#__RefHeading___Toc137888320
        .anchor}**DCNA Occupational Handler Exposure Risk Estimates**

The MOEs were calculated for short/intermediate term exposures of DCNA
handlers and a complete listing of these MOEs is included in Appendix A.
The MOEs for dermal exposures are summarized in Table 5 and the MOEs for
inhalation exposures are summarized in Table 6. Several scenarios have
been excluded from Tables 5 and 6 and they remain as data gaps. These
include an applicator scenario for application of dust using ground
equipment and a mix/load/apply scenario for handheld power dusting.

**Dermal Handler Risks**

The dermal risks for loading dust are of concern at baseline and require
single layer PPE (i.e. chemical resistant gloves) to achieve MOEs of 100
or greater. The dermal risks for mixing/loading wettable powder to
support aerial application and chemigation are of concern at all PPE
levels and require engineering controls (i.e. water soluble bags)
achieve acceptable MOEs. The dermal risks for mixing/loading wettable
powder for ground application are less of a concern and can be addressed
with single layer PPE. The risks for the remaining scenarios
(applicators, flagger and mixer/loader/applicator) are not of concern
with baseline or single layer PPE.

**Inhalation Handler Risks**

The inhalation risks for loading dust are of concern at baseline and
require PF10 respiratory protection to achieve MOEs of 100 or greater.
The inhalation risks for mixing/loading wettable powder to support
aerial application and chemigation are of concern at all PPE levels and
require engineering controls (i.e. water soluble bags) achieve
acceptable MOEs. The inhalation risks for mixing/loading wettable powder
for ground application are less of a concern and can be addressed with
PF5 or PF10 respiratory protection. The risks for the remaining
scenarios are not of concern with baseline or single layer PPE.

[]{.mark}

+---------------------+-----------+-----+-----+-----+----+----+----+---+
| []{#__RefHea        |           |     |     |     |    |    |    |   |
| ding___Toc137888354 |           |     |     |     |    |    |    |   |
| .anchor}**Table 5 - |           |     |     |     |    |    |    |   |
| Number range        |           |     |     |     |    |    |    |   |
| CHAPTERDCNA Dermal  |           |     |     |     |    |    |    |   |
| MOEs for            |           |     |     |     |    |    |    |   |
| Agricultural        |           |     |     |     |    |    |    |   |
| Handlers**          |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| **(Note - The       |           |     |     |     |    |    |    |   |
| labels typically    |           |     |     |     |    |    |    |   |
| require single      |           |     |     |     |    |    |    |   |
| layer PPE)**        |           |     |     |     |    |    |    |   |
+=====================+===========+=====+=====+=====+====+====+====+===+
| ***Exposure         | ***Crop   | **  | **  | **  | *  | *  | ** |   |
| Scenario***         | Groups*** | *lb | *Ac | *Ba | ** | ** | *E |   |
|                     |           | a   | res | sel | SL | DL | C* |   |
|                     |           | i/a | per | ine | PP | PP | ** |   |
|                     |           | cre | Day | PPE | E* | E* |    |   |
|                     |           | *** | *** | *** | ** | ** |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| **Mixer/Loader      |           |     |     |     |    |    |    |   |
| (M/L)**             |           |     |     |     |    |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L Dust for Ground | tree/vine | 1.5 | 40  | 38  | 8  | 11 | N  |   |
| Equipment           | crops,    |     |     |     | 20 | 00 | /A |   |
|                     |           | 2   |     | *   |    |    |    |   |
|                     | field/row | .0- |     | *[\ | [  | [  |    |   |
|                     | crops     | 4.5 |     | >]{ | \> | \> |    |   |
|                     |           |     |     | .un | ]{ | ]{ |    |   |
|                     |           |     |     | der | .u | .u |    |   |
|                     |           |     |     | lin | nd | nd |    |   |
|                     |           |     |     | e}1 | er | er |    |   |
|                     |           |     |     | 3** | li | li |    |   |
|                     |           |     |     |     | ne | ne |    |   |
|                     |           |     |     |     | }2 | }3 |    |   |
|                     |           |     |     |     | 70 | 60 |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L Wettable Powder | field/row | 2   | 350 | **[ | ** | ** | [\ |   |
| (WP) for Aerial     | crops,    | .0- |     | \>] | [\ | [\ | >] |   |
| Application or      |           | 4.5 |     | {.u | >] | >] | {. |   |
| Chemigation         | tree/vine |     |     | nde | {. | {. | un |   |
|                     | crops     | 1.5 |     | rli | un | un | de |   |
|                     |           |     |     | ne} | de | de | rl |   |
|                     |           |     |     | 1** | rl | rl | in |   |
|                     |           |     |     |     | in | in | e} |   |
|                     |           |     |     | **  | e} | e} | 5  |   |
|                     |           |     |     | 4** | 31 | 41 | 40 |   |
|                     |           |     |     |     | ** | ** |    |   |
|                     |           |     |     |     |    |    | \> |   |
|                     |           |     |     |     | ** | 1  | 10 |   |
|                     |           |     |     |     | 94 | 20 | 00 |   |
|                     |           |     |     |     | ** |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L WP for          | sweet     | 120 | 3   | **  | 1  | 1  | \> |   |
| Ground-boom         | potatoes  |     |     | 6** | 40 | 80 | 10 |   |
|                     |           | 2   | 80  |     |    |    | 00 |   |
|                     | field/row | .0- |     | *   | \  | \  |    |   |
|                     | crops     | 4.5 |     | *\> | >1 | >1 | \> |   |
|                     |           |     |     | 6** | 40 | 80 | 10 |   |
|                     |           |     |     |     |    |    | 00 |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L WP for Airblast | tree/vine | 1.5 | 40  | **3 | 8  | \> | \> |   |
|                     | crops     |     |     | 8** | 20 | 10 | 10 |   |
|                     |           |     |     |     |    | 00 | 00 |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L WP for HP       | g         | 0.  | 10  | *   | \> | \> | \> |   |
| Handwand            | reenhouse | 75- |     | *[\ | 10 | 10 | 10 |   |
|                     | crops     | 2.5 |     | >]{ | 00 | 00 | 00 |   |
|                     |           |     |     | .un |    |    |    |   |
|                     |           |     |     | der |    |    |    |   |
|                     |           |     |     | lin |    |    |    |   |
|                     |           |     |     | e}9 |    |    |    |   |
|                     |           |     |     | 4** |    |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L Liquids for     | field/row | 2   | 350 | *   | \  | \  | \  |   |
| Aerial Application  | crops     | .0- |     | *\> | >2 | >3 | >6 |   |
| or Chemigation      |           | 4.5 |     | 2** | 30 | 10 | 20 |   |
|                     | tree/vine |     |     |     |    |    |    |   |
|                     | crops     | 1.5 |     | **  | 6  | 9  | \> |   |
|                     |           |     |     | 6** | 90 | 30 | 10 |   |
|                     |           |     |     |     |    |    | 00 |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L Liquids for     | field/row | 2   | 80  | *   | [\ | \> | \> |   |
| Groundboom          | crops     | .0- |     | *\> | >] | 10 | 10 |   |
|                     |           | 4.5 |     | 8** | {. | 00 | 00 |   |
|                     |           |     |     |     | un |    |    |   |
|                     |           |     |     |     | de |    |    |   |
|                     |           |     |     |     | rl |    |    |   |
|                     |           |     |     |     | in |    |    |   |
|                     |           |     |     |     | e} |    |    |   |
|                     |           |     |     |     | 10 |    |    |   |
|                     |           |     |     |     | 00 |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L Liquids for     | tree/vine | 1.5 | 40  | **4 | \> | \> | \> |   |
| Airblast            | crops     |     |     | 8** | 10 | 10 | 10 |   |
|                     |           |     |     |     | 00 | 00 | 00 |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| **Applicator        |           |     |     |     |    |    |    |   |
| (APP)**             |           |     |     |     |    |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| Aerial Application  | All crops | 1   | 350 | N/  |    |    | \> |   |
|                     | above     | .5- |     | A - |    |    | 10 |   |
| (Closed Cockpit)    |           | 4.5 |     | o   |    |    | 00 |   |
|                     |           |     |     | nly |    |    |    |   |
|                     |           |     |     | clo |    |    |    |   |
|                     |           |     |     | sed |    |    |    |   |
|                     |           |     |     | c   |    |    |    |   |
|                     |           |     |     | ock |    |    |    |   |
|                     |           |     |     | pit |    |    |    |   |
|                     |           |     |     | ai  |    |    |    |   |
|                     |           |     |     | rcr |    |    |    |   |
|                     |           |     |     | aft |    |    |    |   |
|                     |           |     |     | are |    |    |    |   |
|                     |           |     |     | u   |    |    |    |   |
|                     |           |     |     | sed |    |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| Groundboom          | All crops | 1.5 | 3   | \>1 | \> | \> | \> |   |
| Application         | above     | -   | -80 | 000 | 10 | 10 | 10 |   |
|                     |           | 120 |     |     | 00 | 00 | 00 |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| Airblast            | tree/vine | 1.5 | 40  | 390 | 5  | 6  | \> |   |
| Application         | crops     |     |     |     | 80 | 40 | 10 |   |
|                     |           |     |     |     |    |    | 00 |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| HP Handwand         | g         | 0.  | 10  | [   | \> | \> | ND |   |
| Application         | reenhouse | 75- |     | \>] | 10 | 10 |    |   |
|                     | crops     | 2.5 |     | {.u | 00 | 00 |    |   |
|                     |           |     |     | nde |    |    |    |   |
|                     |           |     |     | rli |    |    |    |   |
|                     |           |     |     | ne} |    |    |    |   |
|                     |           |     |     | 260 |    |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| **Mixe              |           |     |     |     |    |    |    |   |
| r/Loader/Applicator |           |     |     |     |    |    |    |   |
| (M/L/A)**           |           |     |     |     |    |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L/A WP with LP    | g         | 0.  | 0.4 | No  | [  | [  | *  |   |
| Handwand            | reenhouse | 75- |     | D   | \> | \> | N/ |   |
|                     | crops     | 2.5 |     | ata | ]{ | ]{ | A* |   |
|                     |           |     |     |     | .u | .u |    |   |
|                     |           |     |     |     | nd | nd |    |   |
|                     |           |     |     |     | er | er |    |   |
|                     |           |     |     |     | li | li |    |   |
|                     |           |     |     |     | ne | ne |    |   |
|                     |           |     |     |     | }4 | }6 |    |   |
|                     |           |     |     |     | 90 | 80 |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L/A WP with       |           |     |     | No  |    |    |    |   |
| Backpack Sprayer    |           |     |     | D   |    |    |    |   |
|                     |           |     |     | ata |    |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L/A Liquids with  |           |     |     | [   | \> | \> | *  |   |
| LP Handwand         |           |     |     | \>] | 10 | 10 | N/ |   |
|                     |           |     |     | {.u | 00 | 00 | A* |   |
|                     |           |     |     | nde |    |    |    |   |
|                     |           |     |     | rli |    |    |    |   |
|                     |           |     |     | ne} |    |    |    |   |
|                     |           |     |     | **8 |    |    |    |   |
|                     |           |     |     | 4** |    |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| M/L/A Liquids with  |           |     |     | No  | \> | \> | *  |   |
| Backpack Sprayer    |           |     |     | D   | 10 | 10 | N/ |   |
|                     |           |     |     | ata | 00 | 00 | A* |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| ***Flagger***       |           |     |     |     |    |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| Flag Aerial         | All crops | 1   | 350 | 480 | No | 5  | \> |   |
| Applications        | above     | .5- |     |     | Da | 30 | 10 |   |
|                     |           | 4.5 |     |     | ta |    | 00 |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+
| **\*MOEs in bold    |           |     |     |     |    |    |    |   |
| are less than 100   |           |     |     |     |    |    |    |   |
| and are of          |           |     |     |     |    |    |    |   |
| conce               |           |     |     |     |    |    |    |   |
| rn**[.]{.underline} |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| ND - No Data        |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| N/A -- Not          |           |     |     |     |    |    |    |   |
| applicable.         |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| [Crop               |           |     |     |     |    |    |    |   |
| Groups]{.underline} |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| Field/Row crops -   |           |     |     |     |    |    |    |   |
| includes celery,    |           |     |     |     |    |    |    |   |
| florence, fennel,   |           |     |     |     |    |    |    |   |
| endive, lettuce,    |           |     |     |     |    |    |    |   |
| onion, shallots,    |           |     |     |     |    |    |    |   |
| garlic, potatoes,   |           |     |     |     |    |    |    |   |
| snap beans, etc.    |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| Tree/Vine crops --  |           |     |     |     |    |    |    |   |
| includes apricots,  |           |     |     |     |    |    |    |   |
| grapes, peaches,    |           |     |     |     |    |    |    |   |
| nectarines, plums,  |           |     |     |     |    |    |    |   |
| prunes, sweet       |           |     |     |     |    |    |    |   |
| cherries, Christmas |           |     |     |     |    |    |    |   |
| trees and other     |           |     |     |     |    |    |    |   |
| conifers            |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| Greenhouse Crops -- |           |     |     |     |    |    |    |   |
| includes            |           |     |     |     |    |    |    |   |
| ornamentals,        |           |     |     |     |    |    |    |   |
| certain vegetables  |           |     |     |     |    |    |    |   |
| and potato          |           |     |     |     |    |    |    |   |
| transplant          |           |     |     |     |    |    |    |   |
| seedlings           |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| [PPE                |           |     |     |     |    |    |    |   |
| Levels]{.underline} |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| Baseline - includes |           |     |     |     |    |    |    |   |
| long pants and long |           |     |     |     |    |    |    |   |
| sleeve shirts       |           |     |     |     |    |    |    |   |
| without gloves.     |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| Single Layer (SL) - |           |     |     |     |    |    |    |   |
| includes baseline   |           |     |     |     |    |    |    |   |
| PPE with chemical   |           |     |     |     |    |    |    |   |
| resistant gloves    |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| Double Layer (DL) - |           |     |     |     |    |    |    |   |
| includes coveralls  |           |     |     |     |    |    |    |   |
| over baseline PPE   |           |     |     |     |    |    |    |   |
| and chemical        |           |     |     |     |    |    |    |   |
| resistant gloves -  |           |     |     |     |    |    |    |   |
| typically required  |           |     |     |     |    |    |    |   |
| by the labels       |           |     |     |     |    |    |    |   |
|                     |           |     |     |     |    |    |    |   |
| EC - Engineering    |           |     |     |     |    |    |    |   |
| control - includes  |           |     |     |     |    |    |    |   |
| water soluble bags, |           |     |     |     |    |    |    |   |
| closed loading      |           |     |     |     |    |    |    |   |
| systems and         |           |     |     |     |    |    |    |   |
| enclosed cabs.      |           |     |     |     |    |    |    |   |
+---------------------+-----------+-----+-----+-----+----+----+----+---+

+--------------------+-----------+------+------+----+----+----+-----+
| []{#__RefHead      |           |      |      |    |    |    |     |
| ing___Toc137888355 |           |      |      |    |    |    |     |
| .anchor}**Table    |           |      |      |    |    |    |     |
| 6 - DCNA           |           |      |      |    |    |    |     |
| Inhalation MOEs    |           |      |      |    |    |    |     |
| for Agricultural   |           |      |      |    |    |    |     |
| Handlers**         |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| **(Note - The      |           |      |      |    |    |    |     |
| labels do not      |           |      |      |    |    |    |     |
| require            |           |      |      |    |    |    |     |
| respiratory        |           |      |      |    |    |    |     |
| protection)**      |           |      |      |    |    |    |     |
+====================+===========+======+======+====+====+====+=====+
| **Exposure         | **Crop    | **lb | **A  | *  | *  | ** | **E |
| Scenario**         | Groups**  | a    | cres | *B | *P | PF | C** |
|                    |           | i/ac | per  | as | F5 | 10 |     |
|                    | **( See   | re** | D    | e- | ** | ** |     |
|                    | Notes)**  |      | ay** | ** |    |    |     |
|                    |           |      |      |    |    |    |     |
|                    |           |      |      | ** |    |    |     |
|                    |           |      |      | li |    |    |     |
|                    |           |      |      | ne |    |    |     |
|                    |           |      |      | ** |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| **Mixer/Loader     |           |      |      |    |    |    |     |
| (M/L)**            |           |      |      |    |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L Dust with      | tree/vine | 1.5  | 40   | ** | 3  | 6  | N/A |
| Ground Equipment   | crops,    |      |      | 68 | 40 | 80 |     |
|                    | field/row | 2.0  |      | ** |    |    |     |
|                    | crops     | -4.5 |      |    | [  | [  |     |
|                    |           |      |      | ** | \> | \> |     |
|                    |           |      |      | [\ | ]{ | ]{ |     |
|                    |           |      |      | >] | .u | .u |     |
|                    |           |      |      | {. | nd | nd |     |
|                    |           |      |      | un | er | er |     |
|                    |           |      |      | de | li | li |     |
|                    |           |      |      | rl | ne | ne |     |
|                    |           |      |      | in | }1 | }2 |     |
|                    |           |      |      | e} | 10 | 30 |     |
|                    |           |      |      | 23 |    |    |     |
|                    |           |      |      | ** |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L Wettable       | field/row | 2.0  | 350  | *  | ** | ** | [   |
| Powder (WP) for    | crops,    | -4.5 |      | *[ | [\ | [\ | \>] |
| Aerial Application |           |      |      | \> | >] | >] | {.u |
| or Chemigation     | tree/vine | 1.5  |      | ]{ | {. | {. | nde |
|                    | crops     |      |      | .u | un | un | rli |
|                    |           |      |      | nd | de | de | ne} |
|                    |           |      |      | er | rl | rl | 460 |
|                    |           |      |      | li | in | in |     |
|                    |           |      |      | ne | e} | e} | [\  |
|                    |           |      |      | }3 | 13 | 26 | >]{ |
|                    |           |      |      | ** | ** | ** | .un |
|                    |           |      |      |    |    |    | der |
|                    |           |      |      | *  | ** | ** | lin |
|                    |           |      |      | *[ | [\ | [\ | e}1 |
|                    |           |      |      | \> | >] | >] | 000 |
|                    |           |      |      | ]{ | {. | {. |     |
|                    |           |      |      | .u | un | un |     |
|                    |           |      |      | nd | de | de |     |
|                    |           |      |      | er | rl | rl |     |
|                    |           |      |      | li | in | in |     |
|                    |           |      |      | ne | e} | e} |     |
|                    |           |      |      | }8 | 39 | 78 |     |
|                    |           |      |      | ** | ** | ** |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L WP for         | sweet     | 120  | 3    | ** | ** | 1  | \>1 |
| Groundboom         | potatoes  |      |      | 11 | 57 | 10 | 000 |
|                    |           | 2.0  | 80   | ** | ** |    |     |
|                    | Field/row | -4.5 |      |    |    | [  | \>1 |
|                    | crops     |      |      | ** | ** | \> | 000 |
|                    |           |      |      | [\ | [\ | ]{ |     |
|                    |           |      |      | >] | >] | .u |     |
|                    |           |      |      | {. | {. | nd |     |
|                    |           |      |      | un | un | er |     |
|                    |           |      |      | de | de | li |     |
|                    |           |      |      | rl | rl | ne |     |
|                    |           |      |      | in | in | }1 |     |
|                    |           |      |      | e} | e} | 10 |     |
|                    |           |      |      | 11 | 57 |    |     |
|                    |           |      |      | ** | ** |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L WP for         | Tree/vine | 1.5  | 40   | ** | 3  | 6  | \>1 |
| Airblast           | crops     |      |      | 68 | 40 | 80 | 000 |
|                    |           |      |      | ** |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L WP for HP      | g         | 0.75 | 10   | [  | \> | \> | \>1 |
| Handwand           | reenhouse | -2.5 |      | \> | 10 | 10 | 000 |
|                    | crops     |      |      | ]{ | 00 | 00 |     |
|                    |           |      |      | .u |    |    |     |
|                    |           |      |      | nd |    |    |     |
|                    |           |      |      | er |    |    |     |
|                    |           |      |      | li |    |    |     |
|                    |           |      |      | ne |    |    |     |
|                    |           |      |      | }1 |    |    |     |
|                    |           |      |      | 60 |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L Liquids for    | potatoes  | 4.5  | 350  | ** | 4  | 9  | \>1 |
| Aerial Application |           |      |      | 93 | 60 | 30 | 000 |
| or Chemigation     | field/row | 2.0  |      | ** |    |    |     |
|                    | crops     | -4.0 |      |    | 5  | 10 | \>1 |
|                    |           |      |      | 1  | 20 | 00 | 000 |
|                    | Tree/vine | 1.5  |      | 00 |    |    |     |
|                    | crops     |      |      |    | \> | \> | \>1 |
|                    |           |      |      | 2  | 10 | 10 | 000 |
|                    |           |      |      | 70 | 00 | 00 |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L Liquids for    | Field/row | 2.0  | 80   | \  | \> | \> | \>1 |
| Groundboom         | crops     | -4.5 |      | >4 | 10 | 10 | 000 |
|                    |           |      |      | 10 | 00 | 00 |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L Liquids for    | tree/vine | 1.5  | 40   | \> | \> | \> | \>1 |
| Airblast           | crops     |      |      | 10 | 10 | 10 | 000 |
|                    |           |      |      | 00 | 00 | 00 |     |
+--------------------+-----------+------+------+----+----+----+-----+
| **Applicator       |           |      |      |    |    |    |     |
| (APP)**            |           |      |      |    |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| Aerial Application | All crops | 1.5  | 350  | N  |    |    | \>1 |
|                    | above     | -4.5 |      | /A |    |    | 000 |
|                    |           |      |      | -- |    |    |     |
|                    |           |      |      | Cl |    |    |     |
|                    |           |      |      | os |    |    |     |
|                    |           |      |      | ed |    |    |     |
|                    |           |      |      | C  |    |    |     |
|                    |           |      |      | oc |    |    |     |
|                    |           |      |      | kp |    |    |     |
|                    |           |      |      | it |    |    |     |
|                    |           |      |      | Ai |    |    |     |
|                    |           |      |      | rc |    |    |     |
|                    |           |      |      | ra |    |    |     |
|                    |           |      |      | ft |    |    |     |
|                    |           |      |      | A  |    |    |     |
|                    |           |      |      | re |    |    |     |
|                    |           |      |      | us |    |    |     |
|                    |           |      |      | ed |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| Groundboom         | All crops | 2.0  | 3-80 | [  | \> | \> | \>1 |
| Application        | above     | -120 |      | \> | 10 | 10 | 000 |
|                    |           |      |      | ]{ | 00 | 00 |     |
|                    |           |      |      | .u |    |    |     |
|                    |           |      |      | nd |    |    |     |
|                    |           |      |      | er |    |    |     |
|                    |           |      |      | li |    |    |     |
|                    |           |      |      | ne |    |    |     |
|                    |           |      |      | }6 |    |    |     |
|                    |           |      |      | 60 |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| Airblast           | tree/     | 1.5  | 40   | 6  | \> | \> | \>1 |
| Application        | vine      |      |      | 50 | 10 | 10 | 000 |
|                    | crops     |      |      |    | 00 | 00 |     |
+--------------------+-----------+------+------+----+----+----+-----+
| HP Handwand        | g         | 0.8  | 10   | \> | \> | \> | ND  |
| Application        | reenhouse | -2.5 |      | 10 | 10 | 10 |     |
|                    | crops     |      |      | 00 | 00 | 00 |     |
+--------------------+-----------+------+------+----+----+----+-----+
| **Mixer            |           |      |      |    |    |    |     |
| /Loader/Applicator |           |      |      |    |    |    |     |
| (M/L/A)**          |           |      |      |    |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L/A WP with LP   | g         | 0.75 | 0.4  | [  | \> | \> | ND  |
| Handwand           | reenhouse | -2.5 |      | \> | 10 | 10 |     |
|                    | crops     |      |      | ]{ | 00 | 00 |     |
|                    |           |      |      | .u |    |    |     |
|                    |           |      |      | nd |    |    |     |
|                    |           |      |      | er |    |    |     |
|                    |           |      |      | li |    |    |     |
|                    |           |      |      | ne |    |    |     |
|                    |           |      |      | }1 |    |    |     |
|                    |           |      |      | 60 |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L/A WP with      |           |      |      | No |    |    |     |
| Backpack Sprayer   |           |      |      | Da |    |    |     |
|                    |           |      |      | ta |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L/A Liquids with |           |      |      | \> | \> | \> | ND  |
| LP Handwand        |           |      |      | 10 | 10 | 10 |     |
|                    |           |      |      | 00 | 00 | 00 |     |
+--------------------+-----------+------+------+----+----+----+-----+
| M/L/A Liquids with | Field/row | 4.0  | 0.4  | \> | \> | \> | ND  |
| Backpack Sprayer   | crops     |      |      | 10 | 10 | 10 |     |
|                    |           |      |      | 00 | 00 | 00 |     |
+--------------------+-----------+------+------+----+----+----+-----+
| **Flagger**        |           |      |      |    |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| Flag Aerial        | All crops | 1.5  | 350  | [  | \> | \> | \>1 |
| Applications       | above     | -4.5 |      | \> | 10 | 10 | 000 |
|                    |           |      |      | ]{ | 00 | 00 |     |
|                    |           |      |      | .u |    |    |     |
|                    |           |      |      | nd |    |    |     |
|                    |           |      |      | er |    |    |     |
|                    |           |      |      | li |    |    |     |
|                    |           |      |      | ne |    |    |     |
|                    |           |      |      | }3 |    |    |     |
|                    |           |      |      | 20 |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+
| **\*MOEs in bold   |           |      |      |    |    |    |     |
| are less than 100  |           |      |      |    |    |    |     |
| and are of         |           |      |      |    |    |    |     |
| concer             |           |      |      |    |    |    |     |
| n**[.]{.underline} |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| ND - No Data       |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| N/A -- Not         |           |      |      |    |    |    |     |
| Applicable         |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| [Crop              |           |      |      |    |    |    |     |
| G                  |           |      |      |    |    |    |     |
| roups]{.underline} |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| field/row crops -  |           |      |      |    |    |    |     |
| includes celery,   |           |      |      |    |    |    |     |
| florence, fennel,  |           |      |      |    |    |    |     |
| endive, lettuce,   |           |      |      |    |    |    |     |
| onion, shallots,   |           |      |      |    |    |    |     |
| garlic, potatoes,  |           |      |      |    |    |    |     |
| snap beans, etc.   |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| tree and vine      |           |      |      |    |    |    |     |
| crops -- includes  |           |      |      |    |    |    |     |
| apricots, grapes,  |           |      |      |    |    |    |     |
| peaches,           |           |      |      |    |    |    |     |
| nectarines, plums, |           |      |      |    |    |    |     |
| prunes, sweet      |           |      |      |    |    |    |     |
| cherries,          |           |      |      |    |    |    |     |
| Christmas trees    |           |      |      |    |    |    |     |
| and other conifers |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| Greenhouse crops - |           |      |      |    |    |    |     |
| includes           |           |      |      |    |    |    |     |
| ornamentals,       |           |      |      |    |    |    |     |
| certain vegetables |           |      |      |    |    |    |     |
| and potato         |           |      |      |    |    |    |     |
| transplant         |           |      |      |    |    |    |     |
| seedlings          |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| [PPE               |           |      |      |    |    |    |     |
| L                  |           |      |      |    |    |    |     |
| evels]{.underline} |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| Baseline - no      |           |      |      |    |    |    |     |
| respirator is worn |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| PF5 - Filtering    |           |      |      |    |    |    |     |
| facepiece          |           |      |      |    |    |    |     |
| respirator (i.e. a |           |      |      |    |    |    |     |
| dustmask) with a   |           |      |      |    |    |    |     |
| protection factor  |           |      |      |    |    |    |     |
| of 5               |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| PF10 - Half face   |           |      |      |    |    |    |     |
| cartridge          |           |      |      |    |    |    |     |
| respirator with a  |           |      |      |    |    |    |     |
| protection factor  |           |      |      |    |    |    |     |
| of 10              |           |      |      |    |    |    |     |
|                    |           |      |      |    |    |    |     |
| EC - Engineering   |           |      |      |    |    |    |     |
| control - includes |           |      |      |    |    |    |     |
| water soluble      |           |      |      |    |    |    |     |
| bags, closed       |           |      |      |    |    |    |     |
| loading systems    |           |      |      |    |    |    |     |
| and enclosed cabs. |           |      |      |    |    |    |     |
+--------------------+-----------+------+------+----+----+----+-----+

2.  Number range CHAPTER[]{#__RefHeading___Toc137888321
    .anchor}**Overall Summary of Risk Concerns and Data Gaps for
    Handlers**

Number range CHAPTERNumber range CHAPTERMany of the scenarios that
involve the mixing/loading of wettable powder for agricultural
applications have risks of concern with label required PPE (coveralls
and gloves over long sleeve clothing) and require engineering controls
to be below Agency levels of concern. These risks are often still of
concern at baseline for liquid formulations, but greatly reduced by
single layer PPE for dermal scenarios and the PF5 respirator for
inhalation exposure scenarios.

Data gaps were identified for the following handler scenarios (GDL
875.1100 & 875.1200):

-   Mix/Load/Apply wettable powders with low-pressure handwand or
    backpack sprayers

-   Post harvest seed dip applications

-   Application of dust formulations

-   Mix/Load dusts for aerial application & ground equipment (data for
    mixing and loading wettable powders was used as a surrogate)

-   Mix/Load/Apply dust with handheld power duster

```{=html}
<!-- -->
```
-   Flagger exposure to aerial application of dust

    1.  Number range CHAPTER[]{#__RefHeading___Toc137888322
        .anchor}**Recommendations For Refining Occupational Handler Risk
        Assessment**

> Number range CHAPTER

Number range CHAPTERIt was understood that aerial application was not
routinely used for applying fungicides to orchards and vineyards;
however, this method was assessed for these crops because it was
included on the labels and could be used during wet growing seasons.
Information regarding the types of formulations applied with aircraft
could be used to refine the risk.

DCNA products are packaged as wettable powders, dusts, and liquid
flowables. The labels indicate that all of the formulations can be used
on all of the crops; however, it is suspected that some application
scenarios require certain formulations. This information is critical
because the dust formulation and wettable powder formulation create
significant exposures particularly when used at high rates. These
exposures can be greatly reduced by using the other formulations or by
using the wettable powder in water soluble bags. Information on the use
of the dust formulations is also critical because the dust application
scenario is a data gap and can result in excessive exposures.

1.  Number range CHAPTER[]{#__RefHeading___Toc137888323
    .anchor}**Occupational Handler Characterization**

Product labels have been revised to include maximum seasonal application
rates eliminating chronic exposures for the handler scenarios. The
available NASS data indicate that very little (\<50 lbs.) dichloran is
used in floriculture.

Along with the unit exposure values used in the assessment, other inputs
include application rates and daily acres treated values. Number range
CHAPTERA summary of the input values and their uncertainty is given in
Table 7.

In addition to the sources of information considered above, there are
some underlying factors that may impact the overall results of a risk
assessment. For example, in many cases the data included in PHED are
based on the use of cotton gloves for hand exposure monitoring which are
thought by many to overestimate exposure because they potentially retain
residues more than human skin would over time (i.e., they act like a
sponge compared to the hand).

+--------------------+------------------------+------------------------+
| []{#__RefHead      |                        |                        |
| ing___Toc137888356 |                        |                        |
| .anchor}Table 7 -  |                        |                        |
| Number range       |                        |                        |
| CHAPTERSummary of  |                        |                        |
| Handler Input      |                        |                        |
| Values and Their   |                        |                        |
| Uncertainty        |                        |                        |
+====================+========================+========================+
| **Input Value**    | **Source**             | **Comments**           |
+--------------------+------------------------+------------------------+
| Daily Amt. Treated | Taken from ExpoSAC     | Believed to represent  |
|                    | Policy #9.1 of         | typical values.        |
| (based on 8 hour   |                        |                        |
| work day)          | July 5, 2000           |                        |
+--------------------+------------------------+------------------------+
| Application Rates  | Maximum product label  | N/A                    |
|                    | rates                  |                        |
+--------------------+------------------------+------------------------+
| Unit Exposure Data | PHED                   | Most values are        |
|                    |                        | geometric mean, not    |
|                    |                        | upper percentile.      |
+--------------------+------------------------+------------------------+
| Respiratory        | NIOSH                  | The values were        |
| Protection Factors |                        | generated from studies |
| (5x & 10x)         |                        | using subjects that    |
|                    |                        | were fit tested and    |
|                    |                        | trained. The fit       |
|                    |                        | factors that are       |
|                    |                        | achieved by untested   |
|                    |                        | and untrained          |
|                    |                        | personnel are much     |
|                    |                        | lower. Respirator fit  |
|                    |                        | testing and training   |
|                    |                        | are currently not      |
|                    |                        | required by WPS.       |
+--------------------+------------------------+------------------------+

2.  Number range CHAPTER[]{#__RefHeading___Toc137888324
    .anchor}**Occupational Postapplication Exposures and Risks**

Number range CHAPTERThe Agency uses the term "postapplication" to
describe exposures to individuals that occur as a result of working 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 such as harvesting vegetables in a
treated field. Job requirements (e.g., the kinds of jobs to cultivate a
crop), the nature of the crop or target that was treated, and the how
chemical residues degrade in the environment can cause exposure levels
to differ over time. Each factor has been considered in this assessment.

1.  Number range CHAPTER[]{#__RefHeading___Toc137888325
    .anchor}**Occupational Postapplication Exposure Scenarios** **and
    Calculation Methods**

Number range CHAPTER[Exposure Scenarios]{.underline}

DCNA use sites include field/row crops, tree crops, vineyards,
greenhouse crops and ornamentals. Applications are typically begun in
the spring or when disease conditions occur and can typically be
repeated at 5 to 14 day intervals for the seasonal applications. In some
instances, such as ornamental crops, it can be used more frequently.

The agency uses a concept known as the transfer coefficient to
numerically represent the postapplication exposures one would receive
(i.e., generally presented as cm^2^/hour). These transfer coefficients
are listed in Policy 003.1 Science Advisory Council for *Exposure Policy
Regarding Agricultural Transfer Coefficients*. In this policy, transfer
coefficients were selected to represent the activities associated with
18 distinct crop/agronomic groupings based on different types of
vegetables, trees, berries, vine/trellis crops, turf, field crops, and
bunch/bundle crops (e.g., tobacco). DCNA uses were identified in most of
the crop groups in the policy.

These crop groups include:

-   Field/row crops, low/medium (e.g., snap beans);

-   Cut flowers (e.g., floriculture crops);

-   Ornamentals, potted plants, (e.g., ornamental plants);

-   Tree/fruit, deciduous (e.g., apples);

-   Tree/fruit, evergreen (e.g., conifers);

-   Vegetable, cucurbit (e.g., cucumber, endive);

-   Vegetable, fruiting (e.g., tomato);

-   Vegetable/leafy (e.g., lettuce, celery, florence, fennel);

-   Vegetable, root (e.g., onions, garlic, shallots, potatoes, sweet
    potatoes);

-   Vine/trellis (e.g., grapes -- various types).

    Within each agronomic group, a variety of cultural practices are
    required to maintain the included crops. These practices are varied
    and typically involve light contact with immature plants and heavy
    contact with more mature plants.

    [Calculation Methods]{.underline}

Post application exposures are calculated by considering transferable
residue levels in areas where people work and the kinds of jobs or tasks
that are required to produce agricultural commodities. These factors are
represented by DFR concentrations and by transfer coefficients.
Exposures are calculated by multiplying these factors by an 8 hour work
day. Exposures are then normalized by body weight to calculate absorbed
doses. MOEs were then calculated. Postapplication risks diminish over
time because DCNA residues dissipate in the environment. As a result,
risk values were calculated over time based on changing residue levels.

**Estimation of Residue Levels Using Dissipation Kinetics**

The first step in the postapplication risk assessment was to complete an
analysis of the available dislodgeable foliar residue (DFR) data. Best
fit DFR levels were calculated based on empirical data using the
equation D2-16 from Series 875-Occupational and Residential Test
Guidelines: Group B-Postapplication Exposure Monitoring Test Guidelines.
Half-lives were calculated using the algorithm (T~1/2~ = -Ln 2/slope).
The results of those statistical analyses were used to calculate best
fit concentrations over time using the following pseudo-first order
equation:

C~envir(t)~ = C~envir(0)~e^(PAI(t)\ \*\ M)^

Where:

C~envir(t)~ = dislodgeable foliar residue (μg/cm^2^) at time (t);

C~envir(0)~ **=** same as above at time (0);

e **=**natural logarithms base function;

PAI~(t)~ **=** postapplication interval or dissipation time (e.g., days
after treatment or DAT); and

**M =** slope of line generated during linear regression of data
\[ln(C~envir~) versus PAI\].

**Daily Exposure:** The next step in the risk assessment process was to
calculate dermal exposure values on each postapplication day after
application using the following equation (see equation D2-20 from
*Series 875-Occupational and Residential Test Guidelines: Group
B-Post-application Exposure Monitoring Test Guidelines* and *Residential
SOP 3.2: Postapplication Dermal Potential Doses from Pesticide Residues
on Gardens*):

**DE~(t)~ (mg/day) = (DFR~(t)~ (ug/cm^2^) x TC (cm^2^/hr) x Hr/Day)/1000
(ug/mg)**

Where:

**DE(t)** = Daily exposure or amount deposited on the surface of the
skin at time (t) attributable for activity in a previously treated area,
also referred to as potential dose (mg ai/day);

**DFR(t)** = Dislodgeable foliar residue at time (t) where the longest
duration is dictated by the decay time observed in the studies
(ug/cm^2^);

**TC** = Transfer Coefficient (cm^2^/hour); and

**Hr/day** = Exposure duration meant to represent a typical workday
(hours).

**Daily Dose and Margins of Exposure:** Once daily exposure values are
calculated, the calculation of daily absorbed dose and the resulting
MOEs use the same algorithms that are described for the handler
exposures. These calculations are completed for each day after
application.

The level of concern for all assessments is the same as for handlers
(i.e. the target MOE is 100) as discussed in Section 2.1.3.

1.  Number range CHAPTER[]{#__RefHeading___Toc137888326 .anchor}**Data
    Used for Occupational Postapplication Exposure Scenarios**

One DFR study (MRID 450620-01) was submitted by BASF in support of the
re-registration of DCNA. A brief description follows and additional
information is provided in Appendix B. The DFR study was conducted on
snap beans using groundboom application of a DCNA wettable powder
formulation. TheNumber range CHAPTER formulation used was Botran^®^ 75W,
a soluble powder that containing 75% by weight of active ingredient.
This study was conducted at one site located on a Madera County,
California (CA) research farm. A wetting agent was not used during
application, and is not recommended in the product label. Five weekly
applications were made at the site, representing 100% of the proposed
maximum use rate per season. The target rates for each application were
1.688 lb ai/acre to yield a total application of 8.4 lb ai/acre. The
finish spray was applied to the test site using a tractor mounted boom
sprayer. Two plots were established at the test area, one treated and
one untreated. The treated plot was divided into three subplots and the
untreated into one subplot. Each subplot was divided into 8, 40 inch
beds for sampling. The treated crop was planted on August 9, 1999 and
the untreated plot was planted on August 10, 1999. The 5^th^ (and final)
application took place on October 6^th^, 1999.

One sample from the untreated control plot and three samples were
collected from the treated plot before and after each application then
approximately 1,2,3,5,7,10,14,21,28 and 35 days after the fifth
application. Forty snap bean leaf disks were collected using 2.5 cm
Birkestrand leaf punches per sample for a total surface area of 405
cm^2^. Residues were dislodged in 100 ml of a 0.01% Aerosol OT using a
reciprocal shaker at approximately 200 rpm for ten minutes. Field spikes
were prepared by collecting and dislodging leaf disks from the untreated
plots in the same manner as the samples collected from the treated
plots. Separate Birkestrand punches were used for the treated and
untreated samples at each site. Dislodgeable foliar samples were
analyzed using a specific method that involves Gas Chromatography using
electron capture detection.The method was included in the study report.
The LOQ in terms of leaf area is 0.001 ug/cm^2^ and is supported by
method validation.

No DCNA residue was detected in the pre-application or control plot
samples except for the control samples taken pre- and postapplication
number 2. The average DCNA DFR (n=3) on Day After Treatment (DAT) zero
after the fifth application was 3.72 ug/cm^2^. The DFR declined to 0.85
ug/cm^2^ (the LOQ is 0.001 ug/cm^2^) on day 35. Regression analysis of
the natural logarithms of the 33 data points from DAT 0 to DAT 35
yielded an R^2^ value of 0.73 and a half life of 19 days.

This study appears to be of sufficient quality to be used for exposure
and risk assessment purposes. The product was applied to snap beans in a
manner consistent with the label.

Number range CHAPTER**Application of the Study Data to the Exposure
Scenarios**

DCNA is used on several crop groups but dislodgeable foliar residue
studies were submitted for only one crop. It is relevant to note that
the DFR study took place at a California-based site, in dry conditions.
Based upon this information, the data were extrapolated from the DFR
studies to the labeled crops.

2.  Number range CHAPTER[]{#__RefHeading___Toc137888327
    .anchor}**Exposure Assumptions, Factors and Transfer Coefficients**

Number range CHAPTERThe following assumptions, factors and transfer
coefficients were used for assessing the occupational postapplication
risks:

-   The body weights, dermal absorption factors and toxicological
    endpoints are the same as those used for the occupational handler
    assessments.

-   The revised application rates were used as listed in Table 4.

```{=html}
<!-- -->
```
-   The "multiple applications" rate of 2.0 lbs ai/acre was used for
    celery, florence and fennel because post application exposures do
    not occur when the "single application" rate of 4.0 lb ai/acre is
    applied. According to the labels, the single application rate is
    applied 4 to 8 weeks before harvest with \"a drop nozzle boom to
    direct spray to the base of plants and adjacent soil\" which
    minimizes post application exposure. Conversations with BEAD have
    also indicated that DCNA is applied to plant stems and soil to
    control soil borne organisms which is different than most fungicides
    which are applied to leaves to control airborne organisms.

-   The "prethinning" rate of 2.25 lbs ai/acre was used for lettuce
    because post application exposures do not occur when the "post
    thinning" rate of 4.0 lb ai/acre is applied. According to the
    labels, the post thinning rate is applied as a basal drench
    immediately after thinning and that \"the soil surrounding the
    plants should not be disturbed\" after the application. These two
    factors preclude post application exposure when the post thinning
    rate is applied.

-   When the Agency extrapolated the available DFR data to other crops,
    it adjusted the data for differences in application rate using a
    simple proportional approach

-   Risks were calculated using generic transfer coefficients that
    represent many different types of cultural practices. A listing of
    the transfer coefficients used in this assessment is given in
    Table 8. Most of these transfer coefficients were taken from the
    Agency's revised *Policy 003.1 Science Advisory Council for Exposure
    Policy Regarding Agricultural Transfer Coefficients (August 7,
    2000)*. The transfer coefficients for ornamentals excluding cut
    flowers was taken from studies (ARTF-039 and ARTF-043) recently
    submitted by the ARTF. The transfer coefficients for ornamentals
    including cut flowers was taken from the ARTF-055 study.

-   The use of personal protective equipment or other types of equipment
    to reduce exposures for postapplication workers is not considered a
    viable alternative for the regulatory process except in specialized
    situations (e.g., a rice scout will wear rubber boots in flooded
    paddies). This is described in some detail in the Agency's Worker
    Protection Standard (40 CFR 170).

+--------------------+-----------------------------------------+-------+
| []{#__RefHead      |                                         |       |
| ing___Toc137888357 |                                         |       |
| .anchor}**Table 8  |                                         |       |
| Number range       |                                         |       |
| CHAPTER-           |                                         |       |
| Postapplication    |                                         |       |
| Exposure Scenarios |                                         |       |
| and Transfer       |                                         |       |
| CoefficientsNumber |                                         |       |
| range CHAPTER**    |                                         |       |
+====================+=========================================+=======+
| **Crop Type        | **Postapplication Exposure Scenarios**  | **Tra |
| (Specific Crops)** |                                         | nsfer |
|                    |                                         | C     |
|                    |                                         | oeffi |
|                    |                                         | cient |
|                    |                                         | (c    |
|                    |                                         | m^2^/ |
|                    |                                         | hr)** |
+--------------------+-----------------------------------------+-------+
| Field/Row Crops,   | Low - Irrigation, handweeding, scouting | 100   |
| Low/Medium         | immature/low foliage plants Medium -    |       |
|                    | Irrigation and scouting mature/high     | 1500  |
| (Snap Beans)       | foliage plants                          |       |
|                    |                                         | 2500  |
|                    | High - Hand harvesting                  |       |
+--------------------+-----------------------------------------+-------+
| Cut Flowers        | Hand harvesting -- short term exposures | 51    |
| (gladiolas, roses, |                                         | 00^1^ |
| hydrangeas)        | Hand harvesting -- Intermediate         |       |
|                    | term/long term exposures                | 27    |
|                    |                                         | 00^2^ |
+--------------------+-----------------------------------------+-------+
| Ornamentals,       | Low - Irrigation, scouting, thinning    | 110   |
| Potted Plants      | weeding immature low foliage plants     |       |
|                    |                                         | 175   |
|                    | Medium - Irrigation, scouting           |       |
|                    | mature/high foliage plants              | 400   |
|                    |                                         |       |
|                    | High - Hand harvesting, pruning,        |       |
|                    | thinning, pinching                      |       |
+--------------------+-----------------------------------------+-------+
| Vegetable,         | Low - Irrigation, scouting, thinning    | 500   |
| Curcurbit          | weeding immature plants                 |       |
|                    |                                         | 1500  |
| (cucumber and      | Medium - Irrigation, scouting, weeding  |       |
| rhubarb)           | mature plants                           | 2500  |
|                    |                                         |       |
|                    | High - Hand harvesting, pulling, leaf   |       |
|                    | thinning, thinning, turning             |       |
+--------------------+-----------------------------------------+-------+
| Vegetable,         | Low - Irrigation, scouting, thinning    | 500   |
| Fruiting (tomato)  | weeding immature plants                 |       |
|                    |                                         | 700   |
|                    | Medium - Irrigation, scouting, weeding  |       |
|                    | mature plants                           | 1000  |
|                    |                                         |       |
|                    | High - Hand harvesting, pruning,        |       |
|                    | staking, tying                          |       |
+--------------------+-----------------------------------------+-------+
| Tree, Fruit,       | Low - Irrigation, scouting, weeding     | 100   |
| Deciduous          |                                         |       |
|                    | High -- Pruning, training, tying,       | 1500  |
| (apricots,         | harvesting                              |       |
| peaches,           |                                         | 3000  |
| nectarines, plums, | Very High -- Thinning                   |       |
| prunes, and sweet  |                                         |       |
| cherries)          |                                         |       |
+--------------------+-----------------------------------------+-------+
| Tree, Fruit,       | Low - Irrigation, scouting, hand        | 1000  |
| Evergreen          | weeding                                 |       |
|                    |                                         | 3000  |
| (Christmas         | Medium -- Shearing, harvesting          |       |
| trees/conifers)    |                                         |       |
+--------------------+-----------------------------------------+-------+
| Vegetable, Leafy,  | Low - Irrigation, scouting, thinning    | 500   |
| Outdoors           | weeding immature plants                 |       |
|                    |                                         | 1500  |
| (celery, endive,   | Medium - Irrigation, scouting, weeding  |       |
| florence, fennel)  | mature plants                           | 2500  |
|                    |                                         |       |
|                    | High - Hand harvesting                  |       |
+--------------------+-----------------------------------------+-------+
| Vegetable, Leafy,  | Low - Irrigation, scouting, thinning    | 500   |
| Outdoors           | weeding immature plants                 |       |
|                    |                                         | N/A   |
| (lettuce)          | Medium - N/A (applications are made     |       |
|                    | prior to thinning seedlings)            | N/A   |
|                    |                                         |       |
|                    | High -- N/A (applications are made      |       |
|                    | prior to thinning seedlings)            |       |
+--------------------+-----------------------------------------+-------+
| Vegetable, Leafy,  | Low - Irrigation, scouting, thinning    | 500   |
| Greenhouse         | weeding immature plants                 |       |
|                    |                                         | 1500  |
| (lettuce)          | Medium - Irrigation, scouting, weeding  |       |
|                    | mature plants                           | 2500  |
|                    |                                         |       |
|                    | High - Hand harvesting                  |       |
+--------------------+-----------------------------------------+-------+
| Vegetable, Root    | Low - Irrigation, scouting, thinning,   | 300   |
|                    | weeding immature plants                 |       |
| (onions, garlic,   |                                         | 1500  |
| shallots)          | Medium -- Irrigation and scouting       |       |
|                    | mature plants                           |       |
+--------------------+-----------------------------------------+-------+
| Vegetable, Root    | Low - Irrigation, scouting, thinning,   | 300   |
| (potatoes)         | weeding immature plants                 |       |
|                    |                                         | 1500  |
|                    | Medium -- Irrigation and scouting       |       |
|                    | mature plants                           |       |
+--------------------+-----------------------------------------+-------+
| Vine/Trellis       | Low - Hedging, irrigation, scouting,    | N     |
| (Grape)            | hand weeding                            | umber |
|                    |                                         | range |
|                    | Medium - Scouting, training, tying      | CHAPT |
|                    |                                         | ER500 |
|                    | High -- Leaf pulling, thinning,         |       |
|                    | pruning, training/tying                 | 1000  |
|                    |                                         |       |
|                    | Very High -- Cane Turning and Tabling   | 5000  |
|                    | Grapes                                  |       |
|                    |                                         | 10000 |
+--------------------+-----------------------------------------+-------+

> *1. Maximum mean value from ARTF-055*

*2. Mean of means from ARTF-055*

1.  Number range CHAPTER[]{#__RefHeading___Toc137888328
    .anchor}**Occupational Postapplication Exposure and Risk Estimates**

Number range CHAPTER**DCNA Risk Summary:**

The post application risks for DCNA are summarized in Table 9 and
details are presented in Appendix C. Within each crop group, differing
transfer coefficients were used to represent different types of cultural
practices which were applicable to each crop group. Some of the MOEs for
DCNA are of concern (i.e. are less than 100) at the currently labeled
REI of 12 hours. The time needed to achieve MOEs of 100 ranges from 2
for some high exposure tasks (hand harvesting) snap beans, cut flowers,
greenhouse lettuce and endive to 32 days for very high exposure tasks
(cane turning and girdling) grapes.

In the case of snap beans and leafy vegetables the high exposure task is
hand harvesting which cannot occur until the Pre Harvest Interval (PHI)
has expired. These MOEs are acceptable at the PHIs which are longer than
the REI. The MOE for the high hand harvesting celery, florence and
fennel is 100 on day 7 which is the same as the PHI. The MOEs for the
hand harvesting of snap beans, greenhouse grown lettuce and endive are
also not of concern because the MOEs exceed 100 at the PHIs of 2 days
for snap beans, 14 days for greenhouse grown lettuce and 14 days for
endive.

+--------------------------+--------+----+-----+-------+-----+-----+
| **Number range CHAPTER** |        |    |     |       |     |     |
| []{#__R                  |        |    |     |       |     |     |
| efHeading___Toc137888358 |        |    |     |       |     |     |
| .anchor}**Table 9 --     |        |    |     |       |     |     |
| Number range CHAPTERDCNA |        |    |     |       |     |     |
| Occupational             |        |    |     |       |     |     |
| Postapplication Risks**  |        |    |     |       |     |     |
+==========================+========+====+=====+=======+=====+=====+
| **Crop Group**           | *      | *  | **  |       |     |     |
|                          | *Appli | *P | MOE |       |     |     |
|                          | cation | HI | on  |       |     |     |
|                          | Rate** | (d | Day |       |     |     |
|                          |        | ay | 0   |       |     |     |
|                          | **(lb  | s* | (D  |       |     |     |
|                          | a.i/a  | *) | ays |       |     |     |
|                          | cre)** |    | w   |       |     |     |
|                          |        |    | hen |       |     |     |
|                          |        |    | MOE |       |     |     |
|                          |        |    | \>  |       |     |     |
|                          |        |    | 100 |       |     |     |
|                          |        |    | )** |       |     |     |
+--------------------------+--------+----+-----+-------+-----+-----+
|                          |        |    | *   | **Med | **  | **V |
|                          |        |    | *Lo | ium** | Hig | ery |
|                          |        |    | w** |       | h** | Hig |
|                          |        |    |     |       |     | h** |
+--------------------------+--------+----+-----+-------+-----+-----+
| Field/Row Crops,         | 2      | 2  | 2   | 160   | 95  | N/A |
| Low/Medium (snap beans)  |        |    | 400 |       | (   |     |
|                          |        |    |     |       | 2)* |     |
|                          |        |    |     |       | *^1 |     |
|                          |        |    |     |       | ^** |     |
+--------------------------+--------+----+-----+-------+-----+-----+
| Cut Flowers              | 0.75   | No | N/A | N/A   | 130 | N/A |
|                          |        | ne |     |       |     |     |
|                          | 1      |    | N/A | N/A   | *   | N/A |
|                          |        |    |     |       | *94 |     |
|                          |        |    |     |       | (2  |     |
|                          |        |    |     |       | )** |     |
+--------------------------+--------+----+-----+-------+-----+-----+
| Ornamentals, Potted      | 0.75   | No | 5   | 3600  | 1   | N/A |
| Plants                   |        | ne | 800 |       | 600 |     |
+--------------------------+--------+----+-----+-------+-----+-----+
| Vegetable, Curcurbit     | 1      | 1  | 950 | 320   | 190 | N/A |
|                          |        | a  |     |       |     |     |
|                          |        | nd |     |       |     |     |
|                          |        | 3  |     |       |     |     |
+--------------------------+--------+----+-----+-------+-----+-----+
| Vegetable, Fruiting      | 0.75   | 10 | 1   | 910   | 640 | N/A |
|                          |        |    | 300 |       |     |     |
+--------------------------+--------+----+-----+-------+-----+-----+
| Tree, Fruit, Deciduous   | 1.5    | 10 | 320 | N/A   | 210 | 110 |
+--------------------------+--------+----+-----+-------+-----+-----+
| Tree, Fruit, Evergreen   | 1.5    | No | 320 | 110   | N/A | N/A |
|                          |        | ne |     |       |     |     |
+--------------------------+--------+----+-----+-------+-----+-----+
| Vegetable, Leafy,        | 2      | 14 | 480 | 160   | 95  | N/A |
| Greenhouse               |        |    |     |       | (2) |     |
|                          |        |    |     |       | ^1^ |     |
+--------------------------+--------+----+-----+-------+-----+-----+
| Vegetable, Leafy,        | 2.5    | 7  | 380 | 130   | 76  | N/A |
| Outdoors                 |        |    |     |       | (   |     |
|                          | 2.25   | 14 | 420 | N/A   | 7)* | N/A |
| (celery, florence,       |        |    |     |       | *^1 |     |
| fennel)                  | 2      | 14 | 480 | 160   | ^** | N/A |
|                          |        |    |     |       |     |     |
| (lettuce)                |        |    |     |       | N/A |     |
|                          |        |    |     |       |     |     |
| (endive)                 |        |    |     |       | 95  |     |
|                          |        |    |     |       | (   |     |
|                          |        |    |     |       | 2)* |     |
|                          |        |    |     |       | *^1 |     |
|                          |        |    |     |       | ^** |     |
+--------------------------+--------+----+-----+-------+-----+-----+
| Vegetable, Root          | 4      | 14 | 400 | **80  | N/A | N/A |
|                          |        |    |     | (7)** |     |     |
| (onions, garlic          | 4.5    | 20 | 350 |       | N/A | N/A |
| shallots)                |        |    |     | **71  |     |     |
|                          |        |    |     | (     |     |     |
| (potatoes)               |        |    |     | 10)** |     |     |
+--------------------------+--------+----+-----+-------+-----+-----+
| Vine/Trellis (grapes)    | 1.5    | 1  | 640 | 320   | *   | *   |
|                          |        |    |     |       | *64 | *32 |
|                          |        |    |     |       | (13 | (32 |
|                          |        |    |     |       | )** | )** |
+--------------------------+--------+----+-----+-------+-----+-----+

1 -- The MOE is 100 on the PHI, therefore the risks are not of concern
for the high exposure tasks (hand harvesting)

**MOEs in bold font are less than 100 and indicate risks of concern.**

2.  Number range CHAPTER[]{#__RefHeading___Toc137888329
    .anchor}**Summary of Occupational Postapplication Risk Concerns and
    Data Gaps**

Number range CHAPTERA summary of all the occupational postapplication
risks of concern for DCNA is included in Table 10, below. Current label
requirements specify 12 hour REI's for all crops and PHIs of 2 to 14
days for food crops. In some of the scenarios, the MOEs for DCNA do not
exceed 100 at the REI for non-harvesting tasks or relevant PHI for
harvesting tasks; and are therefore of concern to HED.

+---------------------------+------------------------------------------+
| []{#__                    |                                          |
| RefHeading___Toc137888359 |                                          |
| .anchor}**Table 10 --     |                                          |
| Summary of DCNA           |                                          |
| Postapplication Risks of  |                                          |
| Concern**                 |                                          |
+===========================+==========================================+
| **Crop Group**            | **Risks of Concern on Day 0 (12 hr REI)  |
|                           | or the PHIs**                            |
+---------------------------+------------------------------------------+
| Field/Row Crops,          | None (MOE is 100 for hand harvesting     |
| Low/Medium                | after the 2 day PHI)                     |
+---------------------------+------------------------------------------+
| Cut Flowers               | High exposure tasks                      |
+---------------------------+------------------------------------------+
| Ornamentals, Potted       | None                                     |
| Plants                    |                                          |
+---------------------------+------------------------------------------+
| Vegetable, Curcurbit      | None                                     |
+---------------------------+------------------------------------------+
| Vegetable, Fruiting       | None                                     |
+---------------------------+------------------------------------------+
| Tree, Fruit, Deciduous    | None                                     |
+---------------------------+------------------------------------------+
| Tree, Fruit, Evergreen    | None                                     |
+---------------------------+------------------------------------------+
| Vegetable, Leafy,         | None (MOE is 100 for hand harvesting     |
| Greenhouse (Lettuce)      | after the 14 day PHI)                    |
+---------------------------+------------------------------------------+
| Vegetable, Leafy,         | None (MOEs are 100 for hand harvesting   |
| Outdoors                  | after the 7 and 14 day PHIs)             |
|                           |                                          |
| (lettuce, celery,         |                                          |
| florence, fennel, endive) |                                          |
+---------------------------+------------------------------------------+
| Vegetable, Root           | Medium exposure tasks - irrigating and   |
|                           | scouting mature plants                   |
| (onions, garlic,          |                                          |
| shallots, potatoes)       |                                          |
+---------------------------+------------------------------------------+
| Vine/Trellis              | High exposure tasks - hand harvest, leaf |
|                           | pulling, thinning, pruning,              |
| (grapes)                  |                                          |
|                           | Very high exposure tasks - cane turning  |
|                           | and girdling table grapes                |
+---------------------------+------------------------------------------+

3.  Number range CHAPTER[]{#__RefHeading___Toc137888330
    .anchor}**Occupational Postapplication Risk Characterization**

Since the DFR data was extrapolated from dry California test conditions,
dissipation of DCNA may be faster in greenhouse settings.

The 2003 NASS Floriculture Survey indicates very low usage of DCNA on
greenhouse grown plants and flowers.