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**Number range CHAPTERUNITED STATES ENVIRONMENTAL PROTECTION AGENCY**

**WASHINGTON, D.C. 20460**

OFFICE OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES

Number range CHAPTER

**Date:** March 28, 2006

**Memorandum:**

**SUBJECT:** Secondary Review of \"Biomonitoring of Workers Hand
Thinning Peaches Treated with Phosmet Insecticide\"; MRID 446823-01.

PC Code Number range CHAPTER059201. DP Barcode D 296574.

**FROM:** Matthew Lloyd, Industrial Hygienist

Reregistration Branch I

Health Effects Division (7509C)

**THROUGH:** Whang Phang, Branch Senior Scientist

Reregistration Branch I

Health Effects Division (7509C)

**TO:** Diane Isbell

Reregistration Review Branch 2

Special Review and Reregistration Division (7508C)

Attached is a review of the Biomonitoring of Workers Hand Thinning
Peaches Treated with Phosmet Insecticide (MRID 466823-01 & 46682302)
study submitted by Gowan Company in support of the re-registration of
Phosmet. This review was completed by Versar, Inc. under the supervision
of HED. It has undergone secondary review and reflects current Agency
policies.

**[Executive Summary:]{.underline}**

This study was designed to examine postapplication exposure to workers
hand-thinning peach trees following airblast application of Phosmet
insecticide. The study measured the change in plasma and red blood cell
cholinesterase activity and to characterized urinary excretion of an
absorbed dose of Phosmet. Urine was analyzed for the urinary metabolites
of Phosmet (N-(methylsulfinyl) methyl-phthalamic acid and
N-(methylsulfonyl)methylphthalamic acid), the sulfinyl and sulfonyl
metabolites (assayed as oxidized sulfonyl). Potential Phosmet
equivalents were calculated using a molecular weight conversion factor
applied to the metabolite residue concentration. Dislodgeable foliar
residues (DFRs) of Phosmet and Phosmet oxon were also measured for one
day pre-second application and for the two days following the second
application.

A 70% active ingredient (ai) wettable powder formulation of Phosmet was
applied by airblast sprayer at the maximum label rate of 3 lb ai/acre to
mature peach trees near Morven, Georgia in the spring of 2005. This
application was made 14 days following the first seasonal application of
Phosmet to that peach orchard. A crew of 16 workers (14 male and 2
female) re-entered the field two days after the second application, in
order to hand thin the trees. Blood and 24-hour urine samples were
collected from the workers on four pre-exposure days, four post-exposure
days, and on the day of exposure.

The 24-hour urine collections were assayed for creatine and sulfonyl
concentration. To account for incomplete sample collection, the Study
Report compared measured creatinine to expected creatinine for each
individual at each sampling event. Based on this estimate of expected
creatinine, an adjustment factor was applied to the sulfonyl
concentration in each urine collection. The Study Author did not factor
any pharmacokinetic data into the estimation of phosmet equivalent dose.
One factor typically considered in the estimate of dose is the
percentage of active ingredient converted to urinary metabolite and
subsequently excreted in the urine. Another factor to be considered is
the percentage of metabolite expected to be excreted during the sampling
time period. The Study Report protocol states that the sulfinyl and
sulfonyl metabolites of phosmet account for approximately 50-60% of the
administered radioactivity in urine in a rat oral metabolism study. HED
made corrections for the percentage of active ingredient converted to
urinary metabolite and excreted in urine (95%) and a correction (55%) to
account for the percentage of administered radioactivity in urine in a
rat oral metabolism study (MRID 404253-01) in their estimate of dose.

Both plasma and red blood cell cholinesterase activity was monitored
throughout the conduct of the study, as well as on several pre-exposure
days. The Study Author reported no remarkable findings and no
exposure-related depression of either plasma or red blood cell
cholinesterase activity for the designated exposure day.

Dislodgeable foliar residue (DFR) was measured on the day before the
second application, the day of the second application (2 days prior to
reentry activity) and for the following 5 days (i.e., 7 monitored days).
The Study Author concluded that the continuing hard rain at the end of
the exposure day had affected the dissipation kinetics and reported that
a meaningful dissipation curve could not be developed. The residues on
days one and two after the phosmet application demonstrate residue
levels consistent with previous Phosmet DFR studies, though after the
rain event the phosmet residues drop off significantly. The Phosmet oxon
was also measured in the DFR and was found to be a tiny fraction of the
parent.

There were a number of issues that introduced uncertainty into the
study, including the following:

-   **Stormy weather changed the intended activity day from day 3
    postapplication to day 2 postapplication**

> With a forecast predicting rain, the study authors moved up the worker
> postapplication activity day from day 3 postapplication to day 2
> postapplication. The rain began to fall in the afternoon of day 2
> postapplication while the workers were still conducting thinning.

-   **Shortened work day due to rain event**

> On the reentry day, an afternoon thunderstorm forced the subjects to
> take cover for half an hour. They returned to work, although the rain
> intensity steadily increased and the work day was called off. Total
> working time was roughly 6 hours before the rain and half an hour in
> the rain for a 6.5 hour workday.

-   **DFR analysis compromised by the rain event**

> The Study Author concluded that the continuing hard rain at the end of
> the exposure day had affected the dissipation kinetics and reported
> that a meaningful dissipation curve could not be developed. The
> residues declined from 4.06 ug/cm^2^ on day 2 (the day the rain
> started) to 0.99 ug/cm^2^ on day 4 (the day the rain ended). The Study
> Report did not detail what time of the day the DFR samples were
> collected, further complicating interpretation of the DFR results.

-   **Poor participant compliance with urine collection**

> The Study Report details compliance issues with regard to urine sample
> collection procedures. Many of the 24 hour urine collections
> demonstrate total volumes substantially below what is expected for
> normal, healthy adults. The volume of urine produced by a normal adult
> over a 24 hour period typically ranges between 800 and 1800 mL (Tietz,
> 1970). Sample volumes obtained from the 16 workers against this
> standard demonstrate that 28 of 123 urine collections were below what
> normally would be expected. The study authors cited an instance of a
> field observer witnessing a study participant urinating on the ground,
> instead of in the sample collection bottles.

-   **Unknown effect of rain on thinning activity day**

> The effect of the rain event on the phosmet exposure estimate is
> unknown. The rainfall could have washed the transferable residue from
> the leaves, and/or washed residue from the workers' skin and clothing.
> It was also possible that the rain would solubilize the DFRs making
> them more readily available for transfer, or the water mass could have
> pushed residues through the clothing to skin increasing dermal
> exposure, or that the damp clothing could hydrate the skin, possibly
> enhancing dermal absorption.

-   **Inconsistent worker apparel**

> The study authors requested workers to have socks, shoes, long pants
> and a long sleeve shirt. No one was turned away from wearing more
> clothing than initially requested. The day warmed up quickly and a
> number of workers shed some clothing as the temperature increased.
> They then added it back on at some point during the rain event.
>
> Exposure is difficult to characterize accurately in these
> circumstances. A few of the workers wore jackets for part of the
> workday, some of the workers wore gloves, some wore hats, some workers
> wore short-sleeved shirts and others wore long-sleeved shirts. Seven
> of sixteen had more clothing than study authors requested for at least
> 2 hours. That includes clothing items like caps, hats, gloves, and
> jackets.

-   **Analytical lab utilized for cholinesterase activity does not have
    data to support whether storage length of samples (1 month) frozen
    blood samples would affect storage stability**

> The study report does not mention storage temperatures for the blood
> samples. There is a possibility that the interaction of the phosmet
> and the enyzme may be altered during storage.
>
> ![](media/image3.wmf){width="6.395138888888889in"
> height="3.8472222222222223in"}
>
> DFR vs. time for Georgia Biomonitoring Study

**References:**

Tietz, Norbert W. ed. (1970). Fundamentals of Clinical Chemistry,
Philadelphia, PA: W.B. Saunders Company. ISBN 0-7216-8865-9.

**Reviewer: [Teri Schaeffer/Traci Brody/Susan Anderson]{.underline}
Date: [March 10, 2006 ]{.underline}**

**[STUDY TYPE]{.underline}:** Post-application biological monitoring
study

**[TEST MATERIAL]{.underline}:** Phosmet

**[SYNONYMS:]{.underline}** Imidan®

*O,O*-dimethyl S-phthalimidomethyl phosphorodithioate (IUPAC)

**[CITATION]{.underline}:** Study Author: Douglas G. Baugher, Ph.D.

> Title: *Biomonitoring of Workers Hand-thinning Peaches Treated with
> Phosmet Insecticide.*
>
> Report Date: October 31, 2005

Analytical Laboratories: PTRL West, Inc.

625-B Alfred Nobel Drive

Hercules, CA 94547

> Identifying Codes: MRID: 46682301

Report No.: 0512

Study Number: EXP-49404

**[SPONSOR]{.underline}:** Gowan Company

370 South Main Street

Yuma, AZ 85364

**[EXECUTIVE SUMMARY]{.underline}:**

This study was designed to examine postapplication exposure to 16
workers hand-thinning peach trees following airblast application of
phosmet insecticide. The study proposed to measure the change in plasma
and red blood cell cholinesterase activity and to characterize urinary
excretion of an absorbed dose of phosmet following one day of
hand-thinning peach trees at the reentry interval (REI) of two days
postapplication. Urine was analyzed for the urinary metabolites of
phosmet (N-(methylsulfinyl) methyl-phthalamic acid, and
N-(methylsulfonyl)methylphthalamic acid), the sulfinyl (SI) and sulfonyl
(SO) metabolites (assayed as oxidized sulfonyl). Potential phosmet
equivalents were calculated using a molecular weight conversion factor
applied to the metabolite residue concentration. A small sampling of
dislodgeable foliar residues (DFRs) of phosmet and phosmet oxon were
also presented.

A 70% active ingredient (ai) wettable powder formulation of phosmet was
applied by airblast sprayer at a use rate of 3 lb ai/acre to mature
peach trees near Morven, Georgia in the spring of 2005. The application
rate was verified by application pass times rather than tank mix
analysis. The application was made 14 days following a first seasonal
application event. A crew of 16 workers (male and female) re-entered the
field two days after the second application, in order to hand thin the
trees. Blood and 24-hour urine samples were collected from the workers
on four pre-exposure days, four post-exposure days, and on the day of
exposure.

[]{.mark}

The Study Authors estimated phosmet-equivalent dose by measurement of
the urinary sulfonyl (SO) and sulfinyl (SI) metabolites of phosmet in 24
hour urine samples collected for five consecutive days beginning on the
morning of postapplication reentry. Over half of the pre-exposure
samples showed no detectable level of SO residue in the urine. Total
estimated phosmet equivalents ranged from 1,031 µg/day to 9,488 µg/day.
These reported phosmet-equivalents do not, however, take into
consideration the pharmacokinetics of phosmet metabolism. The highest
daily concentrations was generally found on the first exposure day (ED
0), although four of the sixteen workers demonstrated the highest urine
levels on the second exposure day (ED +1). Levels steadily decreased
during the monitoring period; however, the levels did not reduce to
pre-exposure levels by the end of the sample collection period.

Both plasma and red blood cell cholinesterase activity was monitored
throughout the conduct of the study, as well as on several pre-exposure
days. The Study Author reported no remarkable findings and no
exposure-related depression of either plasma or red blood cell
cholinesterase activity.

Dislodgeable foliar residue (DFR) was examined on the day before the
second application, the day of the second application (2 days prior to
reentry activity) and for the following 5 days (i.e., 7 monitored days).
The Study Author concluded that the continuing hard rain at the end of
the exposure day had affected the dissipation kinetics and reported that
a meaningful dissipation curve could not be developed. The residues on
the day of second application and the following day demonstrated
residues comparable to previous phosmet DFR studies. The phosmet DFR on
days 1 and 2 postapplication averaged 5.9 ug/cm^2^ and 5.0 ug/cm^2^,
respectively. Phosmet oxon DFR on days 1 and 2 postapplication averaged
0.012 ug/cm^2^ and 0.010 ug/cm^2^, respectively.

Major issues of concern in evaluation of the study include:

-   Other than a molecular weight factor to account for the difference
    in molecular weight between the urinary metabolite sulfonyl, and the
    active ingredient phosmet, the Study Author did not factor any
    pharmacokinetic data into the estimation of phosmet equivalent dose.
    One factor typically considered in the estimate of dose is the
    percentage of active ingredient converted to urinary metabolite and
    subsequently excreted in the urine. Another factor to be considered
    is the percentage of metabolite expected to be excreted during the
    sampling time period. The Study Report protocol states that the
    sulfinyl and sulfonyl metabolites of phosmet account for
    approximately 50-60% of the administered radioactivity in urine in a
    rat oral metabolism study. The Authors did not take this into
    consideration in their estimate of dose.

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-   Many of the 24 hour urine collections demonstrate total volumes
    substantially below what is expected for normal, healthy adults. The
    volume of urine produced by a normal adult over a 24 hour period
    typically ranges between 800 and 1800 mL (Tietz, 1970). Sample
    volumes obtained from the 16 workers against this standard
    demonstrate that 28 of 123 urine collections were below what
    normally would be expected.

-   The Study Authors attempted to correct for incomplete urine
    collection. They adjusted sulfonyl concentration in the urine
    samples using a technique which compared measured creatinine to
    expected creatinine for each individual at each sampling event (Mage
    et al., 2004). Based on this estimate of expected creatinine, an
    adjustment factor was applied to the sulfonyl concentration in each
    urine collection. Use of this correction strategy resulted in
    adjustment factors ranging from 0.64 to 4.38. Use of factors of this
    magnitude indicates that in some instances, urine volume was as low
    as 25% of the expected volume.

-   The study Authors also applied the adjustment factor to those
    samples where the actual creatinine level was higher than the
    expected creatinine level (e.g., adjustment factor \< 1.0). This had
    the effect of reducing the sulfonyl/sulfinyl that was actually
    excreted by those individuals.

-   The DFR analysis was most likely compromised by an exposure day
    rainfall event. The Study Report states that the "continued hard
    rain at the end of the exposure day had affected the dissipation
    kinetics and that a meaningful dissipation curve could not be
    developed." The study authors report that residue levels on the
    first and second day after the second application (approximately 6
    and 5 ug/cm^2,^ respectively) were consistent with expected DFR
    values. When comparing the DFR results with previously conducted
    phosmet dissipation regression curves, it appears that residues
    levels determined after the rain event demonstrate significantly
    lower levels than those expected.

-   In the afternoon of the reentry day, postapplication activities were
    cut short due to heavy rain. The affect of this event on the phosmet
    exposure estimate is unknown. It is possible; however, that
    meaningful exposure was affected. The rainfall could have washed the
    transferable residue from the leaves, and/or washed residue from the
    workers' skin and clothing. Or it is possible that the rain would
    solubilize the DFRs making them more readily available for transfer,
    or the water mass could have pushed residues through the clothing to
    skin increasing dermal exposure, or the damp clothing could hydrate
    the skin, possibly enhancing dermal absorption.

-   Urinary field fortification levels were inconsistent, with seven
    samples, or 25%, demonstrating recovery values less than 50%. The
    Study Author deleted these values from the calculation of average
    recovery, reporting that the values must have been misfortified. If
    these fortification values were included in the calculations,
    overall recovery would be 84%, necessitating the use of a correction
    factor.

-   The clothing worn by the workers was inconsistent. It is difficult
    to accurately characterize exposure in these circumstances. Table 1
    outlines the clothing worn by the individual workers. A few of the
    workers wore jackets for part of the workday, some of the workers
    wore gloves, some wore hats, some workers wore short-sleeved shirts
    and others wore long-sleeved shirts.

-   Several of the urine samples demonstrate incomplete oxidation of
    sulfinyl metabolite to the quantified metabolite, sulfonyl. The
    phosmet equivalent levels are based on measurement of sulfonyl only.
    The Study Authors did not adjust the estimate of phosmet
    concentration to account for this.

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-   EPA Reg No. 10163-169 specifies a maximum use rate of 4.25 lbs.
    ai/A. The test substance was applied to the peach trees at a rate of
    3 lbs. ai/A.

-   Postapplication activities were cut short (i.e., the workers worked
    6.5 hours on the day of exposure) due to the rainfall.

-   Creatinine levels were determined; however, it was not reported if
    the specific gravity of the urine was analyzed.

-   It is not well established that washed red cells can be frozen for a
    period of approximately one month and then assayed for RChe
    activity, as was the case in this Study. The laboratory utilized by
    the Study Author reports that their RChe method was validated using
    fresh specimens (within 48 hours of collection) for estimation of
    RChe activity. The analytical lab utilized for cholinesterase
    testing does not have data to support whether or not frozen storage
    would affect stability.

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-   This study was conducted at only one test site, a peach orchard in
    Morven, Georgia. Therefore, DFR data was not collected from at least
    three geographically distinct locations for each formulation and
    crop type as specified in the guidelines.

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

Signed and dated GLP, Data Confidentiality statements, and Quality
Assurance statements were provided in the Study Report. The Study Report
states that it meets FIFRA Good Laboratory Practices 40 CFR part 160
with the following exceptions: (1) the clinical facilities did not
operate under the GLP, but were licensed and accredited; (2) no data
evaluations, interpretations, or reports were generated by the labs; (3)
tank-mix samples were not collected during the application of the test
product; (4) one set of the field fortified urine samples was placed
into a freezer rather than into a cooler; (5) LabCorp was not identified
in the study protocol as the facility used to assay blood samples; and
(6) the Study Director selected the samples for analysis and inclusion
in reporting based on relevance to the study objectives without protocol
amendment. The statement noted that none of these exceptions negatively
impacted the integrity of the study.

**[GUIDELINE OR PROTOCOL FOLLOWED:]{.underline}**

The Protocol was approved by the Western Institutional Review Board
(WIRB) and provided in the Study Report. The Study Report states that
the exposure data requirements were from U.S. EPA OPPTS Harmonized Test
Guidelines, Series 875 Occupational and Residential Exposure, Group B
875.2600, Biological Monitoring. The DFR data requirements were from
U.S. EPA OPPTS Harmonized Test Guidelines, Series 875, Part B:
Dislodgeable Foliar Residue Dissipation: Agricultural, Guideline
875.2100.

[]{.mark}

[]{.mark}

**[I. MATERIALS AND METHODS]{.underline}**

**[A. MATERIALS]{.underline}**

**[1. Test Material:]{.underline}**

Formulation: Imidan® 70 W - water soluble packets containing 70% phosmet
as the active ingredient.

Lot/Batch \# formulation: Imidan®: 316-129A/30AK4163

Phosmet oxon: 1232W-001B

Sulfinyl urinary metabolite: 13449-5

Sulfonyl urinary metabolite: 13449-8

Purity: Imidan®: The purity of the batch was verified at 98% with an
expiration date of February, 2007.

Phosmet oxon: The purity of the batch was verified at 99.7% with an
expiration date of November 3, 2006.

Sulfinyl urinary metabolite: The purity of the batch was verified at
93.86% with an expiration date of June 22, 2006.

Sulfonyl urinary metabolite: The purity of the batch was verified at
97.01% with an expiration date of June 22, 2006.

CAS #(s): Phosmet: 732-11-6

Other Relevant Information: Imidan® 70 W - EPA Reg. No. 10163-169

**[2. Relevance of Test Material to Proposed
Formulation(s):]{.underline}**

A label was not provided with the Study Report; however, Versar was able
to obtain a label from the OPP Pesticide Products Database using the EPA
registration number. The wettable powder formulation sent to the field
sites was labeled as Imidan™ 70 W, which is the same product name that
appears on the label.

**[3. Packaging:]{.underline}**

The product was packaged in water soluble bags in 40 lb cardboard
cartons.

**[B. STUDY DESIGN]{.underline}**

There were 5 amendments to the protocol. These amendments included:

\(1\) A local laboratory could not be found to analyze the blood samples
the same day of sample collection therefore additional sample collection
procedures were instituted to account for proper sample storage and
shipping. Additionally, clarifications were made to the procedure for
worker illness, injury or manifestation of illness and acquiring medical
attention. Changes were made with the informed consent, changing the
criteria for determining when a worker should be transported to a
hospital emergency room and subsequent allowable return to work.

\(2\) Minor changes were made concerning the application rate to
accommodate water soluble bag packaging. Application of test substance
timing was changed from an 8AM deadline to an 11AM deadline. Leaf punch
size was clarified (diameter size of the leaf punch discs was 2.5 cm).
The addition of Day 7 sampling interval for DFR sampling was included,
and additional field fortification levels were included. .Urine aliquot
preparation was changed from the field site to the analytical lab and
additional urine control sampling fortifications were included.

\(3\) A plan was instituted for possible reentry on day 2
postapplication to allow flexibility in accommodating rain or forecast
rain. This amendment was instituted. The currently registered and
marketed label allows reentry at one day postapplication.

\(4\) The protocol called for estimating the urine volumes when
collected and this was changed to making exact urine volume measurements
at the analytical laboratory. Changed the DFR sampling protocol from
ARTF SOPs to SEAgR SOPs. Changing the collection of DFR field
fortification samples to only days the treated plot is sampled after the
second application. Changing the number of non-treated DFR samples
collected from 5 to 3. Starting on Day 4, the urine samples were jointly
spiked with sulfonyl and sulfinyl metabolites. The pH of the spray
solution was not adjusted to less than or equal to 7. Another orchard of
peaches was treated nearby with phosmet in case additional trees were
needed to keep the thinners busy. Ten, rather than five DFR samples were
collected from the treated plot on the day of reenty.

\(5\) This amendment provided additional information about the
laboratory used for creatinine analysis.

The protocol was amended to include a storage stability study of phosmet
urinary metabolites in urine for storage intervals of one week and two
weeks at freezer temperature. The protocol was also amended to change
the urine storage stability fortification set such that each urine
storage stability sample would be fortified with both phosmet urinary
metabolites instead of fortifying each metabolite to separate urine
samples.

A list of protocol deviations include: (1) the sodium sulfate was not
heated in a muffle furnace at 600ºC for 2 hours prior to use, (2) 50 mL
of DFR solution was fortified when preparing fortified control samples
rather than the specified 200 mL, (3) 125 mL separatory funnels were
used for partitioning rather than 250 mL separatory funnels, (4) a 15
meter DB-5MS column was used not a 10 or 20 meter column. The Study
Author states that these deviations would have no impact on the study.

**[1. Test Site:]{.underline}**

The test site was a peach orchard located in Morven, near Valdosta,
Georgia. The orchard contained approximately 17.5 acres with 45 rows of
peach trees. Each tree was planted 16 ft apart and each row was spaced
19 ft apart. The variety of peach was Florida Crest and the trees were 4
years old. The mature trees (approximately 7 ft tall) had a very good
crop that required thinning. Many of the leaves were \>2.5 cm in width.
The entire orchard was used as the test plot and according to the Study
Report subplots were not necessary.

The orchard received no applications of cholinesterase inhibiting
pesticides during the field phase of the study other than the monitored
phosmet applications. Typical cultural practices were employed at the
site.

**[2. Meteorology:]{.underline}**

Meteorological conditions were recorded during the applications.
Temperature and rainfall data were collected on-site with automated Hobo
monitors. According to the Study Report, the weather was favourable for
both application dates. This information is provided in Table 1. The
Study Report also noted that there was no precipitation or overhead
irrigation during the period between the second application and the day
of monitoring. Temperatures on the day between application and
monitoring ranged from 48 to 82^o^F.

On the day of the reentry thinning tasks, the weather was mixed clouds
and sun, with temperatures rising from 69 to 83^o^F with the relative
humidity ranging from 67% to 90%. The relative humidity data was
obtained from the Dixie, GA site of the Georgia Automated Weather
Network located approximately 13 miles from the test site. In the
afternoon of the reentry day, postapplication activities were cut short
due to a significant rain event. Workers completed their morning work at
noon and then took a break for lunch. They returned to the fields around
1:20 PM. Two hours later, a thunderstorm forced the subjects to take
cover in vehicles for about 25 minutes. They then re-entered the fields
even though it was raining lightly. The rain intensity increased, and
after less than 25 minutes, the subjects had to cease work, leave the
orchard, and return to the staging area. On-site rainfall data collected
with automated Hobo monitors reported 0.32 inches of rainfall on 31
March, the day of reentry. During the next two days, 2.09 and 0.02
inches of rain fell. Table 2 provides rainfall data for the duration of
the study.

[]{.mark}

**Table 1. Meteorological Conditions During Applications**

+---------------------------------+-----------------+-----------------+
| **Parameter**                   | **First         | **Second        |
|                                 | Application**   | Application**   |
|                                 |                 |                 |
|                                 | **(3/15/05)**   | **(3/29/05)**   |
+---------------------------------+-----------------+-----------------+
| Air Temperature (^o^F)          | 52 to 73        | 50 to 77        |
+---------------------------------+-----------------+-----------------+
| Wind Speed (mph)                | 0 to 6          | 2 to 11         |
+---------------------------------+-----------------+-----------------+
| Percent Cloud Cover             | Overcast        | Clear skies     |
+---------------------------------+-----------------+-----------------+

**Table 2. Rainfall Events for Duration of Study**

+---------------------+----------------------------+-------------------+
| **Date**            | **Activity**               | **Rainfall        |
|                     |                            | (inches)**        |
+---------------------+----------------------------+-------------------+
| March 15, 2005      | First Application          | 0.38              |
+---------------------+----------------------------+-------------------+
| March 16, 2005      |                            | 2.23              |
+---------------------+----------------------------+-------------------+
| March 17, 2005      |                            | 0.05              |
+---------------------+----------------------------+-------------------+
| March 22, 2005      |                            | 1.40              |
+---------------------+----------------------------+-------------------+
| March 23, 2005      |                            | 0.03              |
+---------------------+----------------------------+-------------------+
| March 25, 2005      |                            | 0.70              |
+---------------------+----------------------------+-------------------+
| March 26, 2005      |                            | 1.48              |
+---------------------+----------------------------+-------------------+
| March 27, 2005      |                            | 0.26              |
+---------------------+----------------------------+-------------------+
| March 28, 2005      |                            | 0.01              |
+---------------------+----------------------------+-------------------+
| March 29, 2005      | Second Application         | 0                 |
|                     |                            |                   |
|                     | Pre-App DFR Sampling       |                   |
+---------------------+----------------------------+-------------------+
| March 30, 2005      | 1DAT DFR Sampling          | 0                 |
+---------------------+----------------------------+-------------------+
| March 31, 2005      | Reentry Exposure           | 0.32              |
|                     | Monitoring                 |                   |
|                     |                            |                   |
|                     | 2DAT DFR Sampling          |                   |
+---------------------+----------------------------+-------------------+
| April 1, 2005       | 3DAT DFR Sampling          | 2.09              |
+---------------------+----------------------------+-------------------+
| April 2, 2005       | 4DAT DFR Sampling          | 0.02              |
+---------------------+----------------------------+-------------------+
| April 3, 2005       | 5DAT DFR Sampling          | 0                 |
+---------------------+----------------------------+-------------------+
| April 4, 2005       | 6DAT DFR Sampling          | 0                 |
+---------------------+----------------------------+-------------------+

[]{.mark}

**[3. Number and type of workers:]{.underline}**

Sixteen workers made up of both men and women were monitored for this
study. The work crew was made up of 14 annual temporary immigrants from
Mexico and two permanent residents employed as farm workers. The Study
Report stated that the workers were not exposed to phosmet or any other
cholinesterase inhibiting pesticides on workdays before and after the 2
day REI. Each worker was identified by a letter of the alphabet (A
through R). The workers ranged in age from 17 years to 60 years. The
weight of the workers ranged from 47.7 kg to 117.7 kg. The workers'
years of experience ranged from \<1 year to 8 years. All of the workers
had thinning experience, except for M, N, R, and S, who were trained the
day before the reentry event. All of the workers were provided with an
informed consent form to read and sign prior to the start of the study.

**[4. Exposure Replicates:]{.underline}**

At the beginning of the study there were 16 workers selected to
participate and each worker was identified by a letter of the alphabet
(A through R). Workers H and K dropped out of the study before any
samples were collected. Each worker was monitored for 9 days. The one
day of exposure occurred on the second day after the second seasonal
application. Peach tree thinning postapplication activities took place 2
days after the airblast application of 3.0 lb ai/A of phosmet to the
test site. Each worker was assigned to his/her own row for thinning. A
record of trees thinned and any other noteworthy events was recorded.
The morning shift began in the orchard a few minutes after 8:00 AM and
productivity was considered normal. The workers left the orchard at noon
for lunch. The workers returned to the orchard by 1:20 PM. The afternoon
shift was unremarkable until a thunderstorm forced the workers to take
cover in vehicles from 3:25 PM to 3:40 PM, at which time they re-entered
the orchard to continue with their thinning tasks. It was raining
lightly, but the crew foreman indicated that they would normally work in
this weather. The rain intensity increased, and by 4:05 PM the workers
left the orchard for the day. Total working time was approximately 6
hours before the rainfall and 25 minutes in the rain. The Study Report
states that productivity for this sampling event was "considered
typical." The workers were issued clean, dry clothing when they returned
to the staging area. Some of the workers changed clothing immediately,
and others waited until reaching their living quarters before changing.
Pages 103 through 115, in the Study Report, provide observations of the
workers recorded during the study.

[]{.mark}

**[5. Protective clothing:]{.underline}**

The Study Report states that the workers wore their own clothing. Table
3 outlines the clothing worn by the individual workers. A few of the
workers wore jackets for part of the workday, some of the workers wore
gloves, some wore hats, some workers wore short-sleeved shirts and
others wore long-sleeved shirts.

**Table 3. Test Subjects and Clothing Worn During Exposure Event**

[]{.mark}

  ----------------------------------------------------------------------------
  **Replicate**   **Clothing**                    **Notes**
  --------------- ------------------------------- ----------------------------
  A               Denim jacket, long sleeves,     Jacket removed after lunch
                  brimmed hat, leather shoes,     
                  socks, denim pants              

  B               Long-sleeves, cap, socks,       
                  leather shoes, twill pants      

  C               Long-sleeves over               Sleeves rolled up after 25
                  short-sleeves, cap, socks, soft minutes working, jacket
                  shoes, corduroy pants           after rain started

  D               Coat, long-sleeves shirt,       Removed jacket and tied
                  socks, soft shoes, khaki pants  around waist, and went to
                                                  short-sleeves after 10
                                                  minutes working, jacket
                                                  totally removed after 2
                                                  hours working and put on
                                                  again after rain

  E               Long-sleeves, socks, soft       
                  shoes, jeans                    

  F               2 short-sleeved shirts, cap,    
                  socks, soft shoes, jeans        

  G               Long-sleeved shirt over other   Removed long-sleeved shirt
                  shirt, socks, leather shoes,    and tied around waist after
                  linen pants                     lunch, put jacket back on
                                                  after rains started

  I               Short-sleeves over knit shirt,  
                  cap, jeans, leather shoes,      

  J               Jacket, jeans, long-sleeved     Jacket removed and tied
                  shirt, socks, tennis shoes,     around waist , long-sleeves
                  cap,                            pushed up (after 2 hours
                                                  work)

  L               Long-sleeved shirt, jeans, cap, Took off glove at some point
                  socks, tennis shoes, one glove  in the afternoon
                  (jersey weave), bandana at neck 

  M               Long-sleeved shirt, jeans, cap, 
                  tennis shoes and t-shirt        

  N               Short-sleeved t-shirt, cap,     
                  jeans, socks hiking boots       

  O               Short-sleeved collared shirt,   
                  pants, cap, socks, tennis shoes 

  P               Short-sleeved t-shirt, cropped  
                  pants above ankle, tennis       
                  shoes, cloth gloves             

  Q               Long-sleeved shirt, jeans,      
                  socks, work boots, cap          

  R               Long-sleeved collared shirt,    Long-sleeves cuffed up or
                  jeans, boots, socks, cap        rolled back and forearms
                                                  exposed
  ----------------------------------------------------------------------------

[]{.mark}

[]{.mark}

**[6. Application Method and Rate:]{.underline}**

Application rate(s): Two foliar applications were made at 3.0 lb ai/A on
March 15, and March 29 of 2005. According to EPA Reg No. 10163-169, the
maximum application rate is 4.25 lb ai/A per application.

Antifoaming agents were used at a rate of 2 to 3 fluid ounces of
antifoaming agent per tank load. During the second application, the pH
was adjusted from 8.0 to 6.0 with Quest at a rate of 0.5 pints per 100
gallons.

Application Equipment: The applications were made according to usual
agricultural practice, using the orchard owner's equipment driven by an
experienced employee. The applications were made with a new Durand
Wayland AF505 airblast sprayer driven by the power take-off from a John
Deere 2750 diesel tractor. The 500-gallon tank had 2 manifolds, each
with 8 nozzles operating at approximately 185-200 pounds per square inch
pressure.

Spray Volume: The spray volume was reported to be approximately 77.5 or
74.2 gal finished spray per acre. According to the product label, the
test substance should be applied using an adequate spray volume to cover
the foliage.

[]{.mark}

Equipment Calibration: According to the Study Report, the sprayer was
calibrated before each application by the time/distance/volume output
method with a verified flowmeter to achieve a nominal rate of 3 lb
ai/A.. Based on recorded pass times versus pass times calculated for the
row lengths, 96% and 100% of the nominal application rate were achieved
in the first and second applications, respectively.

[]{.mark}

**[7. Exposure monitoring methodology:]{.underline}**

[]{.mark}

Urine: Each subject was issues an insulated cooler containing two
labelled 1-L high density polyethylene screw-cap wide-mouth bottles for
urine collection and two frozen gel packs. The coolers were issued at
the beginning of the monitoring day and collected at the close of the
monitoring day. A second cooler with empty bottles was issued at the
close of the monitoring day for the collection of night voids and the
first morning void. The two samples comprised one urine monitoring day.
Urine samples were placed into a freezer at the staging area,
transferred to freezers at SEAdR, and stored frozen until they were
shipped frozen to PTRL West via a FedEx freezer truck.

[]{.mark}

**[8. Dislodgeable Foliar Residue Sampling Procedures]{.underline}**

Method and Equipment: Samples were collected with a Birkestrand-type
leaf punch sampler with a disk diameter of 2.54 cm (1-inch).

Sampling Procedure: The leaf samples were collected directly into
pre-labelled glass jars using a Birkestrand-type leaf punch sampler.
Each sample consisted of a target of 40 leaf disks. The leaf disk
sampler was cleaned with water and then acetone between each subsample.
Sample jars were placed into coolers containing "blue ice" in the field
and were dislodged within 4 hours of collection. Additional nontreated
control samples were collected from nontreated orchards (location not
specified).

[]{.mark}

Surface area sampled (two sides): The double sided surface area per leaf
punch was approximately 10 cm^2^.

Total Surface Area per Replicate: The total surface area per replicate
was approximately 405 cm^2^.

Replicates per activity:

> \- Replicates per sampling time: Each sample consisted of 40 leaf
> disks.

[]{.mark}

> \- Number of sampling times: Five replicate samples were collected one
> day before the second application(ED -3), and one day after the second
> application (ED -1). Ten replicate samples were collected on the
> monitoring day (ED 0; 2 days postapplication). The Study Author also
> collected DFR replicates on the 4 days following reentry, resulting in
> a total of 7 sampling days.

[]{.mark}

Times of sampling: The exact time of day used for DFR sampling was not
reported.

[]{.mark}

Part(s) of foliage sampled: The samples were collected from the leaves
of the trees.

**[C. ANALYTICAL METHODOLOGY:]{.underline}**

**[1. Sample Extraction/Detection:]{.underline}**

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

Extraction method: The urine samples were analyzed for sulfinyl and
sulfonyl phosmet urinary metabolites using a KMnO4 oxidation reaction
followed by C18 Solid Phase Extraction cleanup allowing for a single
moiety analysis of sulfonyl by LC/MS/MS.

[]{.mark}

Detection methods: Sample analysis was performed using SCIEX 3000
Components (HPLC/Turbo Ion Spray Mode). See Table 4 for specific
conditions.

+-----------------+------------+------------+------------+------------+
| **Table 4.      |            |            |            |            |
| Summary of      |            |            |            |            |
| LC/MS/MS        |            |            |            |            |
| Conditions for  |            |            |            |            |
| Urine**         |            |            |            |            |
+=================+============+============+============+============+
| Mode            | HPLC/Turbo |            |            |            |
|                 | Ion Spray  |            |            |            |
+-----------------+------------+------------+------------+------------+
| GC Column       | Supelco    |            |            |            |
|                 | Supelcosil |            |            |            |
|                 | LC-318 (25 |            |            |            |
|                 | cm x 4.6   |            |            |            |
|                 | mm, 5 µm   |            |            |            |
|                 | with       |            |            |            |
|                 | Supelcosil |            |            |            |
|                 | LC-318     |            |            |            |
|                 | pre-column |            |            |            |
+-----------------+------------+------------+------------+------------+
| Solvents        | Solvent A  |            |            |            |
|                 | = Water    |            |            |            |
|                 | (0.05%     |            |            |            |
|                 | formic     |            |            |            |
|                 | acid)      |            |            |            |
|                 |            |            |            |            |
|                 | Solvent B  |            |            |            |
|                 | =          |            |            |            |
|                 | Ac         |            |            |            |
|                 | etonitrile |            |            |            |
|                 | (0.05%     |            |            |            |
|                 | formic     |            |            |            |
|                 | acid)      |            |            |            |
+-----------------+------------+------------+------------+------------+
| Solvent Program | Time       | Flow Rate  | %A         | %B         |
|                 | (min.)     | (mL/min.)  |            |            |
+-----------------+------------+------------+------------+------------+
|                 | 0          | 0.50       | 98         | 2          |
+-----------------+------------+------------+------------+------------+
|                 | 13.0       | 0.50       | 37         | 63         |
+-----------------+------------+------------+------------+------------+
|                 | 13.5       | 1.3        | 0          | 100        |
+-----------------+------------+------------+------------+------------+
|                 | 17.0       | 1.3        | 0          | 100        |
+-----------------+------------+------------+------------+------------+
|                 | 17.5       | 1.0        | 98         | 2          |
+-----------------+------------+------------+------------+------------+
|                 | 25.0       | 1.0        | 98         | 2          |
+-----------------+------------+------------+------------+------------+
|                 | 25.5       | 0.5        | 98         | 2          |
+-----------------+------------+------------+------------+------------+
|                 | 26.0       | 0.5        | 98         | 2          |
+-----------------+------------+------------+------------+------------+
| Injection       | 10 µL      |            |            |            |
| Volume          |            |            |            |            |
+-----------------+------------+------------+------------+------------+
| Ionization mode | Turbo      |            |            |            |
|                 | spray      |            |            |            |
+-----------------+------------+------------+------------+------------+
| Divert valve to | On at 10.8 |            |            |            |
| mass            | minutes,   |            |            |            |
| sp              | off at     |            |            |            |
| ectrophotometer | 13.0       |            |            |            |
|                 | minutes    |            |            |            |
+-----------------+------------+------------+------------+------------+
| Retention Time  | Sulfinyl = |            |            |            |
|                 | 11.6       |            |            |            |
|                 | minutes    |            |            |            |
|                 |            |            |            |            |
|                 | Sulfonyl = |            |            |            |
|                 | 12.3       |            |            |            |
|                 | minutes    |            |            |            |
+-----------------+------------+------------+------------+------------+

[]{.mark}

[]{.mark}

Method Validation: The analytical facility developed methods for the SI
and SO metabolites of phosmet in human urine using an oxidation reaction
(SI to SO) with KMnO~4~ followed by a C18 Solid Phase Extraction cleanup
allowing for single moiety analysis of sulfonyl by LC/MS/MS. The
analytical laboratory confirmed methods of analysis for the matrices and
fully supported the analysis of samples with controls and procedural
recoveries. The full method validation report is provided at the end of
the study.

[]{.mark}

Instrument performance and calibration: To determine instrument
calibration, each injection sequence was typically set up as follows:
test standard injection, 0.02 µg/mL sulfonyl calibrant, solvent blank
(1:9 acetonitrile:water), and a control urine sample. After that run,
the sequence alternated a calibrant injection and three or four extract
samples (including fortified control extracts, concurrent fortification
extracts, field fortification extracts and urine donor sample extracts).
The final injection for each sample set sequence was a quality control
calibrant injection used to assess the stability of the calibrant
response. Representative sulfinyl and sulfonyl calibration curves and
LC/MS/MS calibrant chromatograms are presented in the study.

[]{.mark}

Quantification: The mass spectra data was collected and quantitation was
based on the peak area of the daughter ion with m/z 176 from the parent
ion m/z 256 (sulfonyl). The transition of 240/176 amu was monitored for
confirmation of complete oxidation during the sample workup. The limit
of quantitation for urine analysis was 0.025 µg/mL for each analyte or
0.516 µg/mL for the sulfonyl equivalence.

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

Sample Preparation: Blood samples were analyzed for plasma and red blood
cell

> cholinesterase activity. A qualified local laboratory could not be
> located to perform the cholinesterase assays and due to concerns about
> the custody and integrity of the blood samples, the Study Director and
> Sponsor's Representative chose to fractionate the blood samples into
> plasma and saline-washed packed red blood cells; freeze the samples;
> and ship the frozen samples to a qualified facility at the conclusion
> of the field phase of the study. The time from last venipuncture to
> placement into the mobile freezer was less than four hours.

Analysis: The plasma samples were assayed on 20 April using the Ellman
photometric method. The red blood cell (RBC) samples were analyzed for
RChe on 20 and 21 April also using a method based on the Ellman method.

**[Dislodgeable Foliar Residues:]{.underline}**

Dislodging Procedure: The residues from the leaf disks were dislodged
within 4 hours of collection. Residues were dislodged twice, each time
with 100 mL of 0.01% Aerosol OT in distilled water. Each sample was
placed on a reciprocating shaker operated at approximately 200 cycles
per minute for 10 minutes. The leaf disks were counted and discarded
after the final dislodging and both 100 mL solutions were combined into
a single sample for analysis. The samples were placed in frozen storage
until shipment to the analytical laboratory.

[]{.mark}

Detection methods: The DFR samples were analyzed by GC-FPD using a Model
No. 6890 Hewlett Packard Gas Chromatograph equipped with a Hewlett
Packard Flame Photometric Detector (FPD) See Table 5 for specific
conditions.

[]{.mark}

+--------------------+-------------------------------------------------+
| **Table 5. Summary |                                                 |
| of GC-FPD          |                                                 |
| Operating          |                                                 |
| Conditions**       |                                                 |
+--------------------+-------------------------------------------------+
| Column             | DB-5MS Capillary Column                         |
|                    |                                                 |
|                    | 15m x 0.53 mm i.d. x 1.5 µm film thickness      |
+--------------------+-------------------------------------------------+
| Gas Flow Rates     | Carrier: 72.0 mL/min. (Helium)                  |
|                    |                                                 |
|                    | Detector: 133 mL/min. (Hydrogen)                |
|                    |                                                 |
|                    | Detector: 128 mL/min. (Air)                     |
|                    |                                                 |
|                    | Detector Makeup: 74 mL/min. (Nitrogen)          |
+--------------------+-------------------------------------------------+
| Injector           | 220°C                                           |
| Temperature        |                                                 |
+--------------------+-------------------------------------------------+
| Detector           | 225°C                                           |
| Temperature        |                                                 |
+--------------------+-------------------------------------------------+
| Injection Volume   | 4 µL, by Hewlett Packard 7683 Autosampler       |
+--------------------+-------------------------------------------------+
| Inlet Conditions   | Injection port liner: single-gooseneck liner    |
|                    | with Restek carbofrit insert. Splitless, purge  |
|                    | flow 2 mL/min. @ 2 minutes.                     |
+--------------------+-------------------------------------------------+
| Oven Temperature   | Initial Temperature: 160°C for 1 minute         |
| Program            |                                                 |
|                    | Ramp: 160°C to 260°C at 15°C/minute (hold 2     |
|                    | minutes)                                        |
|                    |                                                 |
|                    | Retention Time: \~5.3 minutes for Phosmet;      |
|                    | \~4.7 minutes for Phosmet oxon                  |
+--------------------+-------------------------------------------------+

[]{.mark}

Method validation: PTRL West validated an existing analytical method for
the determination of phosmet and phosmet oxon in foliar dislodging
solution. Method validation recoveries ranged from 84.5% to 90.2% for
phosmet and from 88.8% to 93.2% for phosmet oxon.

Instrument performance and calibration: A linear regression of the
calibration solutions peak area vs. concentration for each analyte was
determined and used to calculate the concentration of phosmet and
phosmet oxon in the DFR samples. Sample injections were bracketed by
calibration solution injections or a quality control calibrant solution
injection. Quality control calibrant injections were analyzed last and
compared to the relevant calibrant injections used in the quantitation
to assess the stability of the responses.

Quantification: The analytes were identified by the coincidence of their
retention times with that of reference standard calibration solutions.
Phosmet and phosmet oxon were quantified by integration of the GC/FPD
peak areas for each analyte in the samples. The limit of quantitation
for DFR samples is 1.0 µg/mL for phosmet and 0.2 µg/mL for phosmet oxon.

**[2. Quality Control:]{.underline}**

[Lab Recovery:]{.underline}

[Urine:]{.underline} Concurrent laboratory urine fortification sample
recoveries are summarized in Table 6 below. Each sample set included two
concurrent fortified urine samples fortified with both sulfinyl and
sulfonyl. The fortification levels were the following: 0.025 µg/mL, 0.05
µg/mL, 0.10 µg/mL, and 0.25 µg/mL. In addition, each sample set (except
day 1 and 2) included two fortified control urine extract samples that
were fortified with sulfonyl only, at 0.5 µg/mL and 0.2 µg/mL. The
control urine used for each sample set was an unfortified field
fortification sample. Concurrent fortification sample recoveries ranged
from 62% to 119% with an overall recovery of 90 ± 14% recovery. Control
extract fortification sample recoveries ranged from 76% to 122% with an
overall recovery of 104 ± 10%.

+----------+-----------+-----------+-----------+----------+----------+
| **Table  |           |           |           |          |          |
| 6.       |           |           |           |          |          |
| Co       |           |           |           |          |          |
| ncurrent |           |           |           |          |          |
| La       |           |           |           |          |          |
| boratory |           |           |           |          |          |
| Urine    |           |           |           |          |          |
| Forti    |           |           |           |          |          |
| fication |           |           |           |          |          |
| Reco     |           |           |           |          |          |
| veries** |           |           |           |          |          |
+==========+===========+===========+===========+==========+==========+
| **Urine  | *         | *         | **Total   | **       | **       |
| Sample   | *Sulfinyl | *Sulfonyl | Sulfonyl  | Sulfonyl | Sulfonyl |
| Set**    | Fort      | Fort      | Fort      | Detected | Re       |
|          | ification | ification | ification | (        | covery** |
|          | (ug/mL)** | (ug/mL)** | Eq        | ug/mL)** |          |
|          |           |           | uivalence |          | **(%)**  |
|          |           |           | (ug       |          |          |
|          |           |           | /mL)^1^** |          |          |
+----------+-----------+-----------+-----------+----------+----------+
| Days 1   | 0.025     | 0.025     | 0.052     | 0.046    | 90%      |
| and 2    |           |           |           |          |          |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.05      | 0.05      | 0.103     | 0.083    | 80%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 2A   | 0.025     | 0.025     | 0.052     | 0.055    | 106%     |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.25      | 0.25      | 0.517     | 0.389    | 75%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 2B   | 0.025     | 0.025     | 0.052     | 0.054    | 104%     |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.25      | 0.25      | 0.517     | 0.433    | 84%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 4A   | 0.025     | 0.025     | 0.052     | 0.052    | 101%     |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.25      | 0.25      | 0.517     | 0.429    | 83%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 4B   | 0.025     | 0.025     | 0.052     | 0.060    | 117%     |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.25      | 0.25      | 0.517     | 0.469    | 91%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 5A   | 0.025     | 0.025     | 0.052     | 0.055    | 106%     |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.25      | 0.25      | 0.517     | 0.395    | 77%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 5B   | 0.025     | 0.025     | 0.052     | 0.061    | 118%     |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.25      | 0.25      | 0.517     | 0.459    | 89%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 6A   | 0.05      | 0.05      | 0.103     | 0.094    | 91%      |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.25      | 0.25      | 0.517     | 0.427    | 83%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 6B   | 0.05      | 0.05      | 0.103     | 0.095    | 92%      |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.25      | 0.25      | 0.517     | 0.403    | 78%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 7A   | 0.05      | 0.05      | 0.103     | 0.092    | 89%      |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.25      | 0.25      | 0.517     | 0.410    | 79%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 7B   | 0.025     | 0.025     | 0.052     | 0.050    | 97%      |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.1       | 0.1       | 0.207     | 0.179    | 86%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 8A   | 0.10      | 0.1       | 0.207     | 0.129    | 62%      |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.025     | 0.025     | 0.052     | 0.036    | 69%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 8B   | 0.025     | 0.025     | 0.052     | 0.048    | 93%      |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.10      | 0.1       | 0.207     | 0.148    | 72%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 9A   | 0.025     | 0.025     | 0.052     | 0.055    | 106%     |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.10      | 0.1       | 0.207     | 0.182    | 88%      |
+----------+-----------+-----------+-----------+----------+----------+
| Day 9B   | 0.025     | 0.025     | 0.052     | 0.058    | 112%     |
+----------+-----------+-----------+-----------+----------+----------+
|          | 0.10      | 0.1       | 0.207     | 0.165    | 80%      |
+----------+-----------+-----------+-----------+----------+----------+
| **A      |           |           |           |          | **90%**  |
| verage** |           |           |           |          |          |
+----------+-----------+-----------+-----------+----------+----------+
| **Std.   |           |           |           |          | **14%**  |
| Dev.**   |           |           |           |          |          |
+----------+-----------+-----------+-----------+----------+----------+

^1^ Total sulfonyl equivalence = sulfonyl fortification (µg/mL) +
(sulfinyl fortification (µg/mL) x (257/241) where 257/241 = the
molecular weight ratio of sulfonyl ÷ sulfinyl.

[DFR:]{.underline} Concurrent laboratory DFR fortification sample
recoveries are summarized in Table 7. Each sample set included two
concurrent fortified DFR samples and a control sample. Duplicate
concurrent fortification samples were analyzed with each set; each
sample in the set was fortified with phosmet and phosmet oxon. For set
1, the concurrent fortification samples were fortified at 1.0 µg/mL
phosmet and 0.2 µg/mL phosmet oxon. For sets 2 through 7, the concurrent
fortification samples were fortified at 10.0 µg/mL phosmet and 2.0 µg/mL
phosmet oxon. Overall recovery of phosmet and phosmet oxon from all
concurrent fortification samples was 88.2 ± 2.8% and 98.4 ± 4.2%,
respectively. No phosmet or phosmet oxon was detected in the control
sample analyzed with each set, with the exception of set 4 and set 5
where 0.13 µg and 0.12 µg phosmet was detected. For these sets,
concurrent fortification recoveries were corrected for the phosmet
detected in the control samples.

  -----------------------------------------------------------------------------------------------------------------------------
  **Table 7.                                                                                                        
  Concurrent                                                                                                        
  Laboratory DFR                                                                                                    
  Fortification                                                                                                     
  Recoveries**                                                                                                      
  --------------- ----------------- ----------- ----------- ----------- -------------- -------------- ------------- -----------
  **Sample Set**  **Fortification               **Phosmet   **Phosmet   **Phosmet      **Phosmet Oxon **Percent     
                  Level**                       Detected    Oxon        Detected       Detected       Recovered**   
                                                (ug/mL)**   Detected    (ug/cm^2^)**   (ug/cm^2^)**                 
                                                            (ug/mL)**                                               

                  **Phosmet         **Phosmet                                                         **Phosmet**   **Phosmet
                  (ug/mL)**         Oxon                                                                            Oxon**
                                    (ug/mL)**                                                                       

  DFR set 1       1.0               0.2         0.902       0.196       0.445          0.097          90.2%         98.0%

                  1.0               0.2         0.920       0.198       0.454          0.098          92.0%         99.0%

  DFR set 2       10.0              2.0         9.205       1.862       4.546          0.920          92.1%         93.1%

                  10.0              2.0         9.153       1.841       4.520          0.909          91.5%         92.1%

  DFR set 3       10.0              2.0         8.568       2.003       4.231          0.989          85.7%         100.2%

                  10.0              2.0         8.918       2.049       4.404          1.012          89.2%         102.5%

  DFR set 4       10.0              2.0         8.591       2.102       4.242          1.038          85.9%         105.1%

                  10.0              2.0         8.411       2.098       4.154          1.036          84.1%         104.9%

  DFR set 5       10.0              2.0         8.396       2.000       4.146          0.988          84.0%         100.0%

                  10.0              2.0         8.651       2.002       4.272          0.989          86.5%         100.1%

  DFR set 6       10.0              2.0         8.600       1.818       4.247          0.898          86.0%         90.9%

                  10.0              2.0         8.908       1.947       4.399          0.961          89.1%         97.4%

  DFR set 7       10.0              2.0         8.936       1.975       4.413          0.975          89.4%         98.8%

                  10.0              2.0         8.978       1.927       4.434          0.952          89.8%         96.4%

  **Average**                                                                                         **88.2%**     **98.4%**

  **Std. Dev.**                                                                                       **2.7%**      **4.2%**
  -----------------------------------------------------------------------------------------------------------------------------

[Field recovery:]{.underline}

[]{.mark}

Urine: Urine field fortification samples were analyzed on ED-6, ED-5,
ED-2, ED+0, ED+1, ED+2, ED+3, and ED+4. For ED-6 field fortification
samples, a control and two samples fortified in the field with sulfinyl
only and two samples fortified in the field with sulfonyl only were
analyzed. For ED-5 samples, a control and one sample fortified with both
analytes and two samples fortified with either sulfinyl or sulfonyl only
were analyzed. For days ED+0 through ED+4 samples, a control sample was
analyzed as well as duplicate field fortification samples fortified with
sulfinyl and sulfonyl at two levels. No detectable residues were found
in the control field fortification samples analyzed.

The Study Author excluded seven samples with recovery values \<50% from
their overall field fortification recovery. Excluding these apparently
misfortified samples, the Study Author reported an overall field
fortification recovery of 103 ± 15%. Versar included all reported
recovery values, which resulted in an overall field fortification
recovery of 84 ± 38% recovery. A summary of the field fortification
recoveries are reported in Table 8.

  ----------------------------------------------------------------------------------------------------
  **Table 8.                                                                             
  Urine Field                                                                            
  Fortification                                                                          
  Samples**                                                                              
  --------------- --------- --------------- --------------- --------------- ------------ -------------
  **Collection    **Urine   **Sulfinyl      **Sulfonyl      **Total         **Sulfonyl   **Percent
  Day             Volume    Fortification   Fortification   Sulfonyl        Detected     Recovered**
  (postapp.)**    (mL)**    (ug)**          (ug)**          Fortification   (ug)^2^**    
                                                            Equivalence                  
                                                            (ug)^1^**                    

  ED-6            520       25              0               26.7            32.6         122%

                  465       50              0               53.3            52.8         99%

                  420       0               15              15.0            17.2         115%

                  507       0               25              25.0            26.7         107%

  ED-5            505       25              15              41.7            43.6         105%

                  526       0               50              53.3            54.7         103%

                  470       25              0               25.0            25.1         100%

  ED-2            536       25              15              41.7            54.7         131%

                  492       50              25              78.3            7.0          9%

                  568       25              15              41.7            45.7         110%

                  440       50              25              78.3            89.0         114%

  ED+0            538       125             60              193.3           206.7        107%

                  515       125             60              193.3           192.0        99%

                  440       250             100             366.6           396.5        108%

                  457       250             100             366.6           347.5        95%

  ED+1            435       250             100             366.6           318.5        87%

                  440       125             60              193.3           197.0        102%

                  325       125             60              193.3           27.6         14%

                  508       250             100             366.6           350.0        95%

  ED+2            407       125             60              193.3           213.8        111%

                  487       250             100             366.6           428.8        117%

                  440       250             100             366.6           179.3        49%

                  508       125             60              193.3           59.0         31%

  ED+3            352       50              25              78.3            70.2         90%

                  502       25              15              41.7            32.3         78%

                  315       25              15              41.7            5.3          13%

                  350       50              25              78.3            5.2          7%

  ED+4            521       25              15              41.7            44.9         108%

                  440       50              25              78.3            8.1          10%

                  480       50              25              78.3            47.8         61%

                  507       25              15              41.7            46.6         112%

  **Average                                                                              **103%**
  (excluding the                                                                         
  fortification                                                                          
  with values                                                                            
  \<50%)**                                                                               

  **Std. Dev**                                                                           **15%**

  **Average                                                                              **84%**
  (including all                                                                         
  samples)**                                                                             

  **Std. Dev.**                                                                          **38%**
  ----------------------------------------------------------------------------------------------------

^1^ Total sulfonyl equivalence = sulfonyl fort. (ug/mL) + sulfinyl fort.
(ug/mL) x (257/241) where 257/241 = the molecular weight ratio of
sulfonyl/sulfinyl

^2^ The sulfonyl values reported for the first two days postapplication
in Table VII (page 181) of the study report differ from the values
presented in Table 7 (page 32) of the redacted report. Versar was
informed by the study author that the values reported in the redacted
report were incorrect due to data entry error; therefore; the values
reported in this table are from Table VII (page 181) of the study
report.

[]{.mark}

[]{.mark}

[]{.mark}

[DFR]{.underline} DFR field fortification samples were collected from
monitoring days ED-6, ED-5, ED+2, ED+3, and ED+4. For each of these
days, a control field fortification sample was analyzed as well as two
field fortification samples fortified with phosmet only (at two
different levels) and two samples fortified with phosmet oxon only (at
two different levels). No detectable residues were found in the day ED-6
and ED-5 control field fortification samples analyzed. Low levels of
phosmet were detected in day ED+2, ED+3, and ED+4 control field
fortification samples (\<0.01 µg/mL).

The study author excluded one sample with a recovery values of 25.1%
from their overall field fortification recovery. Excluding this outlier,
the study author reported an overall field fortification recovery of
83.0% for phosmet and 91.7% for phosmet oxon. A summary of the field
fortification recoveries are reported in Table 9.

  --------------- -------- ----------------- ----------- ------------- ----------- ----------------- ----------- -------------- ----------- ----------- ------------- -----------
  **Table 9. DFR                                                                                                                                                      
  Field                                                                                                                                                               
  Fortification                                                                                                                                                       
  Recoveries**                                                                                                                                                        

  **Collection    **DFR    **Fortification               **Residues                **Fortification               **Residues                             **Percent     
  Day**           Volume   (ug/mL)**                     Detected                  (ug/cm^2^)**                  Detected                               Recovery**    
                  (mL)**                                 (ug/mL)**                                               (ug/cm^2^)**                                         

                           **Phosmet**       **Phosmet   **Phosmet**   **Phosmet   **Phosmet**       **Phosmet   **Phosmet**    **Phosmet               **Phosmet**   **Phosmet
                                             Oxon**                    Oxon**                        Oxon**                     Oxon**                                Oxon**

  ED-6            198      8.84                          6.828                     4.365                         3.372                                  77.3%         

                  200      10.00                         9.085                     4.938                         4.486                                  90.9%         

                  196                        0.026                     0.024                         0.013                      0.012                                 94.1%

                  198                        0.025                     0.025                         0.012                      0.012                                 99.0%

  ED-5            196      7.65                          6.515                     3.779                         3.217                                  85.1%         

                  193      9.07                          7.130                     4.478                         3.521                                  78.6%         

                  196                        0.026                     0.025                         0.013                      0.012                                 98.0%

                  193                        0.052                     0.039                         0.026                      0.019                                 75.3%

  ED+2            192      5.21                          3.002                     2.572                         1.482                                  57.6%         

                  195      6.41                          4.766                     3.166                         2.354                                  74.3%         

                  192                        0.052                     0.043                         0.026                      0.021                                 82.6%

                  192                        0.078                     0.063                         0.039                      0.031                                 80.6%

  ED+3            195      3.85                          0.964                     1.899                         0.476                                  25.1%         

                  200      5.00                          4.262                     2.469                         2.105                                  85.2%         

                  190                        0.079                     0.050                         0.039                      0.025                                 63.3%

                  194                        0.103                     0.093                         0.051                      0.046                                 90.2%

  ED+4            197      3.81                          2.906                     1.880                         1.435                                  76.3%         

                  196      5.10                          3.879                     2.520                         1.916                                  76.0%         

                  197                        0.076                     0.056                         0.038                      0.028                                 73.5%

                  196                        0.102                     0.082                         0.050                      0.040                                 80.4%

  **Average                                                                                                                                 **83.0%**                 **91.7%**
  Recovery                                                                                                                                                            
  (excluding                                                                                                                                                          
  sample \<50%)**                                                                                                                                                     
  --------------- -------- ----------------- ----------- ------------- ----------- ----------------- ----------- -------------- ----------- ----------- ------------- -----------

Tank mix: Tank-mix samples were not collected during the application of
the test product.

[]{.mark}

Travel Recovery: Information on travel recovery was not reported.

[]{.mark}

Storage Stability: The study author reported that the sulfonyl analyte
was found to be stable in the final extracts when stored for 18 days in
a freezer. Field fortification sample extracts from day 4 were
re-analyzed with the day 8B sample set. Re-analysis of the extracts for
concurrent fortified samples 1 and 2 and day 4 field fortification gave
recoveries of 99%, 80% and 114%, respectively where initial analysis
gave recoveries of 102%, 83% and 110%, respectively. All final extract
samples were analyzed within 18 days of extraction and were stored in a
freezer when not analyzed directly.

**[II. RESULTS AND CALCULATIONS:]{.underline}**

**[A. EXPOSURE CALCULATIONS:]{.underline}**

[Urinary Metabolites]{.underline}

[]{.mark}

Phosmet-equivalent residue was estimated by the Study Authors by
measurement of the sulfonyl and sulfinyl metabolites of phosmet in 24
hour urine samples collected for five consecutive days beginning on the
morning of postapplication reentry. The Study Authors report that worker
compliance with collection of 24 hour urine samples was "excellent to
poor". They discuss the difficulties encountered in getting some of the
workers to comply with proper collection procedures. This difficulty led
to the use of multipliers to adjust metabolite concentrations for
incomplete sample collection. The Study used a creatinine correction
strategy outlined in Mage et.al. (2004). Expected creatinine
concentration was modelled as a function of a person's age, gender, and
body surface area according to the following formulas:

> Male μg Cn/day = 1.93(140-age\[year\]) \* wt\[kg\]1.5\* ht\[cm\]0.5
>
> Female μg Cn/day = 1.64(140-age\[year\]) \* wt\[kg\]1.5\* ht\[cm\]0.5

Urinary creatinine levels determined in the samples was compared to the
expected urinary creatinine for each individual at each sampling event.
Based on this estimate of expected creatinine, an adjustment factor
(ranging from 0.64 to 4.38) was applied to the sulfonyl concentration in
each urine collection and residues were estimated by:

> Creatinine adjusted sulfonyl = measured sulfonyl \* adjustment factor
>
> Reported phosmet equivalents (ug/day) = corrected SO (ug/day) \*
> adjustment factor \* 1.235 molecular weight conversion to phosmet
> equivalents. Molecular weight of phosmet (317.33) and molecular weight
> of sulfonyl (257). No pharmacokinetic factors were utilized in this
> calculation.

Table 10 provides a summary of SO residues assayed in the urine samples
and the corresponding creatinine-adjusted potential phosmet-equivalents
excreted per day as calculated by the Study Author. The reported
phosmet-equivalents do not take into consideration the pharmacokinetics
of phosmet metabolism. Over half of the pre-exposure samples showed no
detectable level of SO residue in the urine. The total post-exposure
phosmet equivalents ranged from 1031 µg/day (worker G) to 9488 µg/day
(worker J). The highest daily concentrations was generally found on the
first exposure day (ED 0), although four of the sixteen workers
demonstrated the highest urine levels on the second exposure day (ED
+1). Levels steadily decreased during the monitoring period; however,
the levels did not reach pre-exposure levels by the end of the sample
collection period.

[Cholinesterase Activity]{.underline}

A laboratory qualified to perform immediate cholinesterase assays was
not available near the test site. Therefore the Study Director chose to
separate the blood samples into plasma and red blood cells. The red
blood cells were washed with saline and both fractions were stored and
shipped frozen to LabCorp in North Carolina. The samples were assayed on
20 and 21 April using assays based on the Ellman photometric method.

[Plasma Cholinesterase Activity:]{.underline}

Plasma samples were divided into two sets (subsample set "a" and
subsample set "b"). All subsample "a" tubes were assayed along with
randomly selected subsample "b" tubes (\~19%). The 27 duplicate samples
(subsample "b") averaged 0.4% greater than the corresponding "a"
subsamples, with a standard deviation of ± 2.4%. Mean values ranged from
2,699 U/L (ED -2) to 3,406 U/L (ED +1). An analysis of variance showed
no significant differences between days for the subsample "a" assays.
The activity of the positive ChE controls at the beginning and end of
the run (2 each) were near the expected mean and were well within
specifications. The Study Author reported no remarkable findings and no
exposure-related depression of PChe. A summary of the results is
presented in Table 10.

[Red Blood Cell Cholinesterase Assays:]{.underline}

Mean values of the RChe samples ranged from 2,849 U/L (ED -6) to 5,229
U/L (ED +4). The study director noticed that the SOP was not being
followed after the first set of 28 had been prepared. The technician
attempted to recover the samples and hemolyze the samples, but forgot
the vortexing steps. There was also a concern that a vortexing step
might have been left out of the remaining samples. Therefore, the
results of the first 28 samples were compromised and there was
uncertainty about the remaining samples. The study author decided to
complete a subsample "b" set the following day. A summary of the results
is presented in Table 10. The RChe results were more variable than the
PChe results. The RChe activity on ED-6 was markedly lower than on other
days. This was explained as normal population variance as the handling
of samples was similar. An analysis of variance with and without the
Bonferroni correction at the p=\<0.05 level showed some significant
differences among some day-wise comparisons. Most were associated with
the lower values on ED -6. The Study Author reports no remarkable
findings and no exposure-related depression of RChe.

[DFR:]{.underline}

Dislodgeable foliar residue (DFR) was examined on the day before the
second application, the day of the second application (2 days prior to
reentry activity) and for the following five days (i.e., 7 monitored
days). The Study Author concluded that the continuing hard rain at the
end of the exposure day had affected the dissipation kinetics and
reported that a meaningful dissipation curve could not be developed. The
residues on the day of second application and the following day
demonstrated residues comparable to previous phosmet DFR studies. The
phosmet DFR on days 1 and 2 postapplication averaged 5.9 ug/cm^2^ and
5.0 ug/cm^2^ , respectively. Phosmet oxon DFR on days 1 and 2
postapplication averaged 0.012 ug/cm^2^ and 0.010 ug/cm^2^ ,
respectively. DFR sampling also occurred on the subsequent 4 days. By
the 6^th^ day after application DFR levels declined to 0.7 ug/cm^2^ and
0.004 ug/cm^2^ for phosmet and phosmet oxon, respectively. A summary of
the DFR results is presented in Table 11. The residue levels were
corrected for field fortification recovery values.

<table>
<colgroup>
<col style="width: 7%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 6%" />
<col style="width: 7%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 7%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 8%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="13"><strong>TABLE 10. Summary of Postapplication
Biomonitoring Data – Phosmet Treated Peach Trees</strong></th>
</tr>
<tr class="odd">
<th><strong>Worker ID</strong></th>
<th><strong>Clothing</strong></th>
<th><strong>Body Weightkg</strong></th>
<th><strong>Day of Collection<sup>a</sup></strong></th>
<th><strong>24 hour Urine Volume<sup>b</sup> mL/day</strong></th>
<th><strong>Cn<sup>c</sup> mg/mL</strong></th>
<th><strong>Cn mg/day</strong></th>
<th><strong>Adjustment Factor<sup>d</sup></strong></th>
<th><strong>SO residue<sup>e</sup> ug/mL</strong></th>
<th><strong>SO residue<sup>f</sup> ug/day</strong></th>
<th><strong>Reported Phosmet equivalent<sup>g</sup>
(ug/day)</strong></th>
<th><strong>Plasma ChE Activity (U/L)</strong></th>
<th><p><strong>RBC ChE Activity</strong></p>
<p><strong>(U/L)</strong></p></th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td rowspan="9"><p>A</p>
<p>(male)</p>
<p>Ht 168 cm</p>
<p>Age 34</p></td>
<td rowspan="9"><p>Denim jacket, Long sleeves, hat, denim pants, leather
shoes</p>
<p>(Jacket removed after lunch)</p></td>
<td rowspan="9">66.8</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,323</td>
<td>3,712</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td><strong>295</strong></td>
<td>1.12</td>
<td>330</td>
<td>4.38</td>
<td>0.045</td>
<td>13</td>
<td>72</td>
<td>3,425</td>
<td>5,384</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,468</td>
<td>4,608</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td>920</td>
<td>1.27</td>
<td>1,168</td>
<td>1.24</td>
<td>0.016</td>
<td>15</td>
<td>23</td>
<td>3,289</td>
<td>5,151</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>930</td>
<td>1.23</td>
<td>1,143</td>
<td>1.27</td>
<td>0.427</td>
<td>397</td>
<td>621</td>
<td>3,055</td>
<td>5,518</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,140</td>
<td>0.97</td>
<td>1,102</td>
<td>1.31</td>
<td>0.181</td>
<td>206</td>
<td>335</td>
<td>3,354</td>
<td>4,369</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>1,240</td>
<td>0.87</td>
<td>1,078</td>
<td>1.34</td>
<td>0.097</td>
<td>120</td>
<td>199</td>
<td>3,277</td>
<td>4,343</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td>1,070</td>
<td>1.00</td>
<td>1,075</td>
<td>1.35</td>
<td>0.042</td>
<td>45</td>
<td>75</td>
<td>3,408</td>
<td>5,022</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td>1,350</td>
<td>0.83</td>
<td>1,126</td>
<td>1.28</td>
<td>0.051</td>
<td>69</td>
<td>109</td>
<td>3,212</td>
<td>4,849</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
A</strong></td>
<td><strong>1,339</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>B</p>
<p>(male)</p>
<p>Ht 163 cm</p>
<p>Age 28</p></td>
<td rowspan="9">Long sleeves, cap, twill pants, leather shoes</td>
<td rowspan="9">91.4</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,352</td>
<td>706</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td>1,430</td>
<td>1.24</td>
<td>1,773</td>
<td>1.36</td>
<td>0.047</td>
<td>67</td>
<td>113</td>
<td>3,499</td>
<td>4,120</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,522</td>
<td>4,470</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td>1,450</td>
<td>1.22</td>
<td>1,769</td>
<td>1.36</td>
<td>0.024</td>
<td>35</td>
<td>58</td>
<td>3,354</td>
<td>4,683</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>1,780</td>
<td>0.79</td>
<td>1,410</td>
<td>1.71</td>
<td>0.727</td>
<td>1294</td>
<td>2,728</td>
<td>3,432</td>
<td>4,987</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,940</td>
<td>0.65</td>
<td>1,267</td>
<td>1.90</td>
<td>0.219</td>
<td>425</td>
<td>997</td>
<td>3,441</td>
<td>4,510</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>1,710</td>
<td>1.00</td>
<td>1,705</td>
<td>1.41</td>
<td>0.17</td>
<td>291</td>
<td>507</td>
<td>3,553</td>
<td>4,857</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td><strong>780</strong></td>
<td>1.69</td>
<td>1,321</td>
<td>1.82</td>
<td>0.088</td>
<td>69</td>
<td>154</td>
<td>3,476</td>
<td>4,430</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td>1,570</td>
<td>1.26</td>
<td>1,975</td>
<td>1.22</td>
<td>0.111</td>
<td>174</td>
<td>262</td>
<td>3,545</td>
<td>6,871</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
B</strong></td>
<td><strong>4,648</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>C</p>
<p>(male)</p>
<p>Ht 160 cm</p>
<p>Age 19</p></td>
<td rowspan="9"><p>Long sleeve over short sleeve shirt, cap, cords, soft
shoes.</p>
<p>(Long sleeve shirt</p></td>
<td rowspan="9">59.5</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,276</td>
<td>4,115</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td><strong>215</strong></td>
<td>1.47</td>
<td>316</td>
<td>4.29</td>
<td>0.043</td>
<td>9</td>
<td>49</td>
<td>3,343</td>
<td>5,233</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,514</td>
<td>5,022</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td><strong>550</strong></td>
<td>1.85</td>
<td>1,018</td>
<td>1.33</td>
<td>0.009</td>
<td>5</td>
<td>8</td>
<td>3,471</td>
<td>5,577</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>990</td>
<td>1.34</td>
<td>1,322</td>
<td>1.03</td>
<td>1.258</td>
<td>1245</td>
<td>1,579</td>
<td>3,168</td>
<td>5,884</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td><strong>540</strong></td>
<td>1.43</td>
<td>770</td>
<td>1.76</td>
<td>1.442</td>
<td>779</td>
<td>1,695</td>
<td>3,419</td>
<td>5,023</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td><strong>670</strong></td>
<td>1.22</td>
<td>819</td>
<td>1.66</td>
<td>0.701</td>
<td>470</td>
<td>961</td>
<td>NS</td>
<td>NS</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td><strong>520</strong></td>
<td>1.72</td>
<td>895</td>
<td>1.52</td>
<td>0.208</td>
<td>108</td>
<td>203</td>
<td>3,447</td>
<td>5,108</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td><strong>780</strong></td>
<td>1.93</td>
<td>1,509</td>
<td>0.90</td>
<td>0.116</td>
<td>90</td>
<td>101</td>
<td>3,290</td>
<td>5,810</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
C</strong></td>
<td><strong>4,539</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>D</p>
<p>(male)</p>
<p>Ht 160 cm</p>
<p>Age 19</p></td>
<td rowspan="9"><p>Coat, long sleeves, khaki pants, soft shoes.</p>
<p>(Jacket worn round waist – removed after 2 hrs work)</p></td>
<td rowspan="9">65</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2,665</td>
<td>3,317</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td><strong>650</strong></td>
<td>0.83</td>
<td>540</td>
<td>2.87</td>
<td>0.032</td>
<td>21</td>
<td>74</td>
<td>2,780</td>
<td>4,834</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2,865</td>
<td>4,996</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td>950</td>
<td>1.53</td>
<td>1,454</td>
<td>1.07</td>
<td>0.018</td>
<td>17</td>
<td>22</td>
<td>2,679</td>
<td>5,259</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td><strong>600</strong></td>
<td>1.77</td>
<td>1,061</td>
<td>1.46</td>
<td>0.164</td>
<td>98</td>
<td>177</td>
<td>2,569</td>
<td>3,922</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,295</td>
<td>1.37</td>
<td>1,775</td>
<td>0.87</td>
<td>0.599</td>
<td>776</td>
<td>836</td>
<td>2,658</td>
<td>4,853</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>1,740</td>
<td>0.99</td>
<td>1,717</td>
<td>0.90</td>
<td>0.228</td>
<td>397</td>
<td>442</td>
<td>2,757</td>
<td>5,195</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td>1,540</td>
<td>1.02</td>
<td>1,572</td>
<td>0.98</td>
<td>0.105</td>
<td>162</td>
<td>197</td>
<td>2,720</td>
<td>5,252</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td>1,630</td>
<td>1.13</td>
<td>1,848</td>
<td>0.84</td>
<td>0.095</td>
<td>155</td>
<td>160</td>
<td>2,590</td>
<td>5,624</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
D</strong></td>
<td><strong>1,812</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>E</p>
<p>(male)</p>
<p>Ht 160 cm</p>
<p>Age 17</p></td>
<td rowspan="9">Long sleeves, jeans, soft shoes</td>
<td rowspan="9">60.5</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,258</td>
<td>3,158</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td><strong>710</strong></td>
<td>0.89</td>
<td>632</td>
<td>2.23</td>
<td>0.033</td>
<td>23</td>
<td>65</td>
<td>3,094</td>
<td>5,884</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,381</td>
<td>4,548</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td>850</td>
<td>1.35</td>
<td>1,148</td>
<td>1.23</td>
<td>0.023</td>
<td>20</td>
<td>30</td>
<td>3,373</td>
<td>5,638</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td><strong>690</strong></td>
<td>2.40</td>
<td>1,653</td>
<td>0.85</td>
<td>0.582</td>
<td>402</td>
<td>424</td>
<td>3,258</td>
<td>5,200</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>840</td>
<td>1.42</td>
<td>1,194</td>
<td>1.18</td>
<td>1.456</td>
<td>1223</td>
<td>1,786</td>
<td>3,218</td>
<td>5,305</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>1,165</td>
<td>1.38</td>
<td>1,608</td>
<td>0.88</td>
<td>0.556</td>
<td>648</td>
<td>702</td>
<td>3,125</td>
<td>5,864</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td><strong>510</strong></td>
<td>1.17</td>
<td>598</td>
<td>2.36</td>
<td>0.374</td>
<td>191</td>
<td>556</td>
<td>3,287</td>
<td>4,712</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td>1,050</td>
<td>2.10</td>
<td>2,210</td>
<td>0.64</td>
<td>0.066</td>
<td>69</td>
<td>55</td>
<td>3,102</td>
<td>4,702</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
E</strong></td>
<td><strong>3,523</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>F (male)</p>
<p>Ht 165 cm</p>
<p>Age 18</p></td>
<td rowspan="9">2 short sleeve shirts, cap, jeans, soft shoes</td>
<td rowspan="9">69.1</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,121</td>
<td>3,303</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td>NS</td>
<td>NS</td>
<td>NS</td>
<td>NS</td>
<td>NS</td>
<td>NS</td>
<td>NS</td>
<td>2,985</td>
<td>5,327</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,027</td>
<td>4,871</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td>1,400</td>
<td>1.01</td>
<td>1,414</td>
<td>1.23</td>
<td>0.019</td>
<td>27</td>
<td>40</td>
<td>3,065</td>
<td>4,539</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>2,700</td>
<td>0.73</td>
<td>1,958</td>
<td>0.89</td>
<td>1.626</td>
<td>4390</td>
<td>4,811</td>
<td>3,009</td>
<td>2,585</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,355</td>
<td>1.14</td>
<td>1,539</td>
<td>1.13</td>
<td>0.965</td>
<td>1308</td>
<td>1,823</td>
<td>2,862</td>
<td>5,111</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>1,250</td>
<td>0.92</td>
<td>1,146</td>
<td>1.52</td>
<td>0.467</td>
<td>584</td>
<td>1,093</td>
<td>NS</td>
<td>NS</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td>1,150</td>
<td>1.18</td>
<td>1,354</td>
<td>1.28</td>
<td>0.284</td>
<td>327</td>
<td>518</td>
<td>3,170</td>
<td>4,715</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td>1,940</td>
<td>0.71</td>
<td>1,368</td>
<td>1.27</td>
<td>0.123</td>
<td>239</td>
<td>374</td>
<td>2,958</td>
<td>5,657</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
F</strong></td>
<td><strong>8,619</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>G (female)</p>
<p>Ht 145 cm</p>
<p>Age 29</p></td>
<td rowspan="9">Long sleeve shirt, short sleeve shirt, linen pants,
leather shoes (long sleeve shirt put on after rains started)</td>
<td rowspan="9">85.5</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2,152</td>
<td>3,023</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td><strong>720</strong></td>
<td>1.47</td>
<td>1,058</td>
<td>1.63</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>2,227</td>
<td>5,459</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2,558</td>
<td>5,853</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td>1,110</td>
<td>1.16</td>
<td>1,288</td>
<td>1.34</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>2,347</td>
<td>5,337</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>1,000</td>
<td>1.39</td>
<td>1,393</td>
<td>1.24</td>
<td>0.235</td>
<td>235</td>
<td>361</td>
<td>2,391</td>
<td>2,437</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,410</td>
<td>1.18</td>
<td>1,658</td>
<td>1.04</td>
<td>0.234</td>
<td>330</td>
<td>425</td>
<td>2,323</td>
<td>5,702</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>800</td>
<td>1.40</td>
<td>1,120</td>
<td>1.54</td>
<td>0.061</td>
<td>49</td>
<td>93</td>
<td>2,468</td>
<td>5,151</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td><strong>710</strong></td>
<td>1.66</td>
<td>1,182</td>
<td>1.46</td>
<td>0.041</td>
<td>29</td>
<td>53</td>
<td>2,532</td>
<td>6,135</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td><strong>730</strong></td>
<td>1.41</td>
<td>1,026</td>
<td>1.69</td>
<td>0.065</td>
<td>47</td>
<td>99</td>
<td>2,621</td>
<td>5,767</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
G</strong></td>
<td><strong>1,031</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>I</p>
<p>(male)</p>
<p>Ht 160 cm</p>
<p>Age 40</p></td>
<td rowspan="9">Short sleeves over knit shirt, cap, jeans</td>
<td rowspan="9">70.5</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,419</td>
<td>3,507</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td>1,350</td>
<td>1.25</td>
<td>1,688</td>
<td>0.86</td>
<td>0.038</td>
<td>51</td>
<td>54</td>
<td>3,315</td>
<td>5,813</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,333</td>
<td>4,716</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td>1,055</td>
<td>1.32</td>
<td>1,393</td>
<td>1.04</td>
<td>0.013</td>
<td>14</td>
<td>18</td>
<td>3,538</td>
<td>5,023</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>800</td>
<td>1.91</td>
<td>1,527</td>
<td>0.95</td>
<td>0.464</td>
<td>371</td>
<td>433</td>
<td>3,438</td>
<td>4,994</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,023</td>
<td>1.51</td>
<td>1,542</td>
<td>0.94</td>
<td>0.658</td>
<td>673</td>
<td>778</td>
<td>3,384</td>
<td>5,255</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>900</td>
<td>1.31</td>
<td>1,183</td>
<td>1.22</td>
<td>0.366</td>
<td>329</td>
<td>496</td>
<td>3,311</td>
<td>5,420</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td><strong>550</strong></td>
<td>2.62</td>
<td>1,439</td>
<td>1.00</td>
<td>0.05</td>
<td>28</td>
<td>34</td>
<td>3,201</td>
<td>4,622</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td><strong>500</strong></td>
<td>2.56</td>
<td>1,281</td>
<td>1.13</td>
<td>0.017</td>
<td>9</td>
<td>12</td>
<td>3,069</td>
<td>4,244</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
I</strong></td>
<td><strong>1,753</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>J</p>
<p>(male)</p>
<p>Ht 168 cm</p>
<p>Age 34</p></td>
<td rowspan="9"><p>Jacket</p>
<p>Long sleeves, cap, jeans, tennis shoes</p>
<p>(Jacket removed after 2 hrs work)</p></td>
<td rowspan="9">72.7</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,116</td>
<td>1,127</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td>1,435</td>
<td>1.13</td>
<td>1,622</td>
<td>1.01</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>3,074</td>
<td>4,224</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,236</td>
<td>5,123</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td>950</td>
<td>1.54</td>
<td>1,463</td>
<td>1.12</td>
<td>0.025</td>
<td>24</td>
<td>33</td>
<td>3,245</td>
<td>4,431</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>1,555</td>
<td>0.95</td>
<td>1,476</td>
<td>1.11</td>
<td>2.625</td>
<td>4082</td>
<td>5,611</td>
<td>3,184</td>
<td>3,155</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,925</td>
<td>0.86</td>
<td>1,650</td>
<td>1.00</td>
<td>0.768</td>
<td>1478</td>
<td>1,818</td>
<td>3,258</td>
<td>5,136</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>2,050</td>
<td>0.81</td>
<td>1,658</td>
<td>0.99</td>
<td>0.385</td>
<td>789</td>
<td>966</td>
<td>3,300</td>
<td>4,716</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td>2,080</td>
<td>0.86</td>
<td>1,793</td>
<td>0.92</td>
<td>0.25</td>
<td>520</td>
<td>588</td>
<td>NS</td>
<td>NS</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td>2,400</td>
<td>0.76</td>
<td>1,822</td>
<td>0.90</td>
<td>0.189</td>
<td>454</td>
<td>505</td>
<td>3,132</td>
<td>4,229</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
J</strong></td>
<td><strong>9,488</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>L</p>
<p>(male)</p>
<p>Ht 170 cm Age 19</p></td>
<td rowspan="9">Long sleeve shirt, cap, jeans, bandana, tennis shoes one
glove (glove removed in late afternoon)</td>
<td rowspan="9">64.1</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,378</td>
<td>2,900</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td>1,650</td>
<td>0.66</td>
<td>1,089</td>
<td>1.44</td>
<td>0.035</td>
<td>58</td>
<td>102</td>
<td>3,317</td>
<td>4,725</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,532</td>
<td>4,320</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td>930</td>
<td>1.08</td>
<td>1,004</td>
<td>1.56</td>
<td>0.034</td>
<td>32</td>
<td>61</td>
<td>3,424</td>
<td>4,658</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>1,660</td>
<td>0.51</td>
<td>852</td>
<td>1.83</td>
<td>0.911</td>
<td>1512</td>
<td>3,426</td>
<td>3,541</td>
<td>4,493</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,520</td>
<td>0.71</td>
<td>1,076</td>
<td>1.45</td>
<td>0.575</td>
<td>874</td>
<td>1,568</td>
<td>3,453</td>
<td>5,041</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td><strong>635</strong></td>
<td>0.91</td>
<td>579</td>
<td>2.70</td>
<td>0.333</td>
<td>211</td>
<td>705</td>
<td>3,298</td>
<td>4,707</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td>2,080</td>
<td>0.83</td>
<td>1,731</td>
<td>0.90</td>
<td>0.187</td>
<td>389</td>
<td>434</td>
<td>3,469</td>
<td>4,422</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td><strong>480</strong></td>
<td>1.88</td>
<td>904</td>
<td>1.73</td>
<td>0.12</td>
<td>58</td>
<td>123</td>
<td>3,402</td>
<td>4,425</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
L</strong></td>
<td><strong>6,256</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>M (male)</p>
<p>Ht 160 cm</p>
<p>Age 52</p></td>
<td rowspan="9">Long sleeves, t-shirt, cap, jeans, tennis shoes</td>
<td rowspan="9">47.7</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2,408</td>
<td>1,715</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td>1,325</td>
<td>0.67</td>
<td>888</td>
<td>0.80</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>2,380</td>
<td>5,760</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td><strong>670</strong></td>
<td>1.40</td>
<td>938</td>
<td>0.76</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>2,227</td>
<td>4,796</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2,321</td>
<td>5,045</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>1,350</td>
<td>0.62</td>
<td>842</td>
<td>0.84</td>
<td>0.462</td>
<td>624</td>
<td>648</td>
<td>2,161</td>
<td>4,511</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td><strong>600</strong></td>
<td>0.34</td>
<td>205</td>
<td>3.46</td>
<td>0.118</td>
<td>71</td>
<td>302</td>
<td>2,555</td>
<td>5,500</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td><strong>760</strong></td>
<td>1.14</td>
<td>867</td>
<td>0.82</td>
<td>0.236</td>
<td>179</td>
<td>181</td>
<td>2,421</td>
<td>5,187</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td>1,020</td>
<td>1.08</td>
<td>1,105</td>
<td>0.64</td>
<td>0.1</td>
<td>102</td>
<td>81</td>
<td>2,281</td>
<td>4,410</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td>1,130</td>
<td>0.79</td>
<td>898</td>
<td>0.79</td>
<td>0.069</td>
<td>78</td>
<td>76</td>
<td>2,402</td>
<td>5,711</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
M</strong></td>
<td><strong>1,288</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>N</p>
<p>(male)</p>
<p>Ht 168 cm</p>
<p>Age 32</p></td>
<td rowspan="9">Short sleeves, cap, jeans, hiking boots</td>
<td rowspan="9">80</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2,411</td>
<td>3,949</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td>1,475</td>
<td>0.55</td>
<td>811</td>
<td>2.38</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>2,325</td>
<td>5,167</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2,437</td>
<td>4,745</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td><strong>340</strong></td>
<td>1.71</td>
<td>581</td>
<td>3.32</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>2,335</td>
<td>5,163</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>950</td>
<td>1.31</td>
<td>1,246</td>
<td>1.55</td>
<td>1.392</td>
<td>1322</td>
<td>2,531</td>
<td>2,309</td>
<td>4,186</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>810</td>
<td>1.12</td>
<td>909</td>
<td>2.12</td>
<td>0.237</td>
<td>192</td>
<td>504</td>
<td>2,329</td>
<td>4,979</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>1,175</td>
<td>0.74</td>
<td>873</td>
<td>2.21</td>
<td>0.27</td>
<td>317</td>
<td>867</td>
<td>2,389</td>
<td>4,664</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td>1,075</td>
<td>0.94</td>
<td>1,007</td>
<td>1.92</td>
<td>0.247</td>
<td>266</td>
<td>629</td>
<td>2,405</td>
<td>4,185</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td>1,160</td>
<td>1.33</td>
<td>1,547</td>
<td>1.25</td>
<td>0.224</td>
<td>260</td>
<td>401</td>
<td>2,521</td>
<td>5,429</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
N</strong></td>
<td><strong>4,932</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>O</p>
<p>(male)</p>
<p>Ht 155 cm</p>
<p>Age 60</p></td>
<td rowspan="9">Short sleeves, cap, pant, tennis shoes</td>
<td rowspan="9">65.5</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2,528</td>
<td>1,686</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td><strong>750</strong></td>
<td>0.85</td>
<td>638</td>
<td>1.60</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>2,698</td>
<td>6,254</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>NS</td>
<td>NS</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td><strong>517</strong></td>
<td>1.38</td>
<td>713</td>
<td>1.43</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>2,715</td>
<td>5,508</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td><strong>620</strong></td>
<td>0.95</td>
<td>587</td>
<td>1.73</td>
<td>1.934</td>
<td>1199</td>
<td>2,568</td>
<td>2,744</td>
<td>2,968</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td><strong>660</strong></td>
<td>0.69</td>
<td>458</td>
<td>2.22</td>
<td>0.767</td>
<td>506</td>
<td>1,389</td>
<td>2,788</td>
<td>4,532</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>870</td>
<td>1.00</td>
<td>873</td>
<td>1.17</td>
<td>0.253</td>
<td>220</td>
<td>317</td>
<td>2,608</td>
<td>4,503</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td><strong>740</strong></td>
<td>0.83</td>
<td>616</td>
<td>1.65</td>
<td>0.131</td>
<td>97</td>
<td>198</td>
<td>2,564</td>
<td>5,607</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td><strong>760</strong></td>
<td>0.63</td>
<td>478</td>
<td>2.13</td>
<td>0.169</td>
<td>128</td>
<td>338</td>
<td>NS</td>
<td>NS</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
O</strong></td>
<td><strong>4,810</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>P</p>
<p>(female)</p>
<p>Ht 155 cm</p>
<p>Age 45</p></td>
<td rowspan="9">Short sleeves, cropped pants, <strong>cloth
gloves</strong></td>
<td rowspan="9">96.4</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>2,893</td>
<td>3,963</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td><strong>750</strong></td>
<td>0.89</td>
<td>668</td>
<td>3.23</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>2,958</td>
<td>4,950</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>NS</td>
<td>NS</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td><strong>517</strong></td>
<td>1.38</td>
<td>713</td>
<td>3.03</td>
<td>0.021</td>
<td>11</td>
<td>41</td>
<td>2,766</td>
<td>4,361</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>940</td>
<td>0.86</td>
<td>808</td>
<td>2.67</td>
<td>1.035</td>
<td>973</td>
<td>3,210</td>
<td>2,845</td>
<td>4,264</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,270</td>
<td>0.90</td>
<td>1,139</td>
<td>1.90</td>
<td>0.554</td>
<td>704</td>
<td>1,647</td>
<td>2,824</td>
<td>4,921</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>1,325</td>
<td>0.51</td>
<td>676</td>
<td>3.19</td>
<td>0.183</td>
<td>242</td>
<td>956</td>
<td>3,077</td>
<td>4,625</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td>1,480</td>
<td>0.83</td>
<td>1,228</td>
<td>1.76</td>
<td>0.143</td>
<td>212</td>
<td>460</td>
<td>2,931</td>
<td>4,541</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td>1,410</td>
<td>0.82</td>
<td>1,160</td>
<td>1.86</td>
<td>0.176</td>
<td>248</td>
<td>570</td>
<td>2,978</td>
<td>4,588</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
P</strong></td>
<td><strong>6,843</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>Q</p>
<p>(male)</p>
<p>Ht 168 cm</p>
<p>Age 38</p></td>
<td rowspan="9">Long sleeve shirt, cap, jeans, work boots</td>
<td rowspan="9">70</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,296</td>
<td>783</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td>1,225</td>
<td>1.00</td>
<td>1,225</td>
<td>1.22</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>3,427</td>
<td>4,982</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,260</td>
<td>3,380</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td><strong>760</strong></td>
<td>1.12</td>
<td>851</td>
<td>1.75</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>3,218</td>
<td>3,276</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>990</td>
<td>0.98</td>
<td>972</td>
<td>1.54</td>
<td>0.363</td>
<td>359</td>
<td>682</td>
<td>3,352</td>
<td>4,712</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,000</td>
<td>0.81</td>
<td>810</td>
<td>1.84</td>
<td>0.179</td>
<td>179</td>
<td>407</td>
<td>3,466</td>
<td>5,211</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>1,043</td>
<td>1.11</td>
<td>1,159</td>
<td>1.29</td>
<td>0.075</td>
<td>78</td>
<td>124</td>
<td>3,448</td>
<td>5,037</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td>990</td>
<td>0.96</td>
<td>953</td>
<td>1.57</td>
<td>0.049</td>
<td>49</td>
<td>94</td>
<td>3,433</td>
<td>4,773</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td>1,070</td>
<td>0.98</td>
<td>1,052</td>
<td>1.42</td>
<td>0.12</td>
<td>128</td>
<td>225</td>
<td>3,277</td>
<td>5,051</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
Q</strong></td>
<td><strong>1,532</strong></td>
<td colspan="2"></td>
</tr>
<tr class="odd">
<td rowspan="9"><p>R</p>
<p>(male)</p>
<p>Ht 170 cm</p>
<p>Age 40</p></td>
<td rowspan="9">Long sleeves, cap, jeans, boots (shirt cuffed up after
20 min work)</td>
<td rowspan="9">117.7</td>
<td>ED-6</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,368</td>
<td>4,610</td>
</tr>
<tr class="even">
<td>ED-5</td>
<td>1,150</td>
<td>1.70</td>
<td>1,955</td>
<td>1.65</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>3,469</td>
<td>5,163</td>
</tr>
<tr class="odd">
<td>ED-3</td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td></td>
<td>3,424</td>
<td>2,774</td>
</tr>
<tr class="even">
<td>ED-2</td>
<td><strong>670</strong></td>
<td>2.28</td>
<td>1,528</td>
<td>2.11</td>
<td>ND</td>
<td>ND</td>
<td>ND</td>
<td>3,520</td>
<td>4,839</td>
</tr>
<tr class="odd">
<td>ED 0</td>
<td>1,065</td>
<td>1.76</td>
<td>1,870</td>
<td>1.72</td>
<td>0.37</td>
<td>394</td>
<td>837</td>
<td>2,794</td>
<td>5,078</td>
</tr>
<tr class="even">
<td>ED+1</td>
<td>1,075</td>
<td>1.70</td>
<td>1,824</td>
<td>1.76</td>
<td>0.18</td>
<td>194</td>
<td>421</td>
<td>3,434</td>
<td>4,625</td>
</tr>
<tr class="odd">
<td>ED+2</td>
<td>1,050</td>
<td>1.29</td>
<td>1,351</td>
<td>2.38</td>
<td>0.144</td>
<td>151</td>
<td>445</td>
<td>3,380</td>
<td>4,865</td>
</tr>
<tr class="even">
<td>ED+3</td>
<td>1,350</td>
<td>1.34</td>
<td>1,808</td>
<td>1.78</td>
<td>0.062</td>
<td>84</td>
<td>184</td>
<td>3,514</td>
<td>4,367</td>
</tr>
<tr class="odd">
<td>ED+4</td>
<td><strong>660</strong></td>
<td>1.84</td>
<td>1,214</td>
<td>2.65</td>
<td>0.178</td>
<td>117</td>
<td>384</td>
<td>3,421</td>
<td>5,483</td>
</tr>
<tr class="even">
<td colspan="10"><strong>TOTAL POST EXPOSURE PHOSMET FOR WORKER
R</strong></td>
<td><strong>2,271</strong></td>
<td colspan="2"></td>
</tr>
</tbody>
</table>

> Note: The results for samples collected following re-entry exposure
> are shaded in the table.
>
> NS = no sample collected
>
> ND = Non-detected
>
> a Date specimen collected in relation to exposure (e.g., ED-6
> represents the results on samples collected 6 days pre-exposure, ED 0
> represents the day of reentry)
>
> b 24 hour urine volumes less than 800 mL are highlighted in bold.
>
> c Cn (mg/mL) = urinary creatinine level
>
> d Adjustment Factor = Creatinine concentration was modeled as a
> function of a person's age, gender, and body surface area according to
> the formulas presented in Study Report. Male μg Cn/day =
> 1.93(140-age\[year\]) \* wt\[kg\]1.5\* ht\[cm\]0.5 and Female μg
> Cn/day = 1.64(140-age\[year\]) \* wt\[kg\]1.5\* ht\[cm\]0.5 .
>
> e SO (ug/mL) = daily concentration of sulfonyl metabolite measured in
> urine.
>
> f SO (ug/day) = SO (ug/mL) \* 24 hour urine volume.
>
> g Reported Phosmet equivalents (ug/day) = corrected SO (ug/day) \*
> adjustment factor \* 1.235 molecular weight conversion to Phosmet
> equivalents. Molecular weight of phosmet = 317.33 and molecular weight
> of sulfonyl = 257. This value has been adjusted for possible
> incomplete urine collection -- see footnote d. No pharmcokinetic
> factors have been utizilied in this calculation.

+-----------------+---+---------+---+----------+---+----------+---+-----------------+
| **Table 11.     |   |         |   |          |   |          |   |                 |
| Dislodgeable    |   |         |   |          |   |          |   |                 |
| Foliar Residues |   |         |   |          |   |          |   |                 |
| of Phosmet and  |   |         |   |          |   |          |   |                 |
| Phosmet Oxon**  |   |         |   |          |   |          |   |                 |
+=================+===+=========+===+==========+===+==========+===+=================+
| **Collection    | * |         | * |          | * |          | * |                 |
| Day**           | * |         | * |          | * |          | * |                 |
|                 | P |         | P |          | A |          | A |                 |
|                 | h |         | h |          | v |          | v |                 |
|                 | o |         | o |          | e |          | e |                 |
|                 | s |         | s |          | r |          | r |                 |
|                 | m |         | m |          | a |          | a |                 |
|                 | e |         | e |          | g |          | g |                 |
|                 | t |         | t |          | e |          | e |                 |
|                 | ( |         | O |          | P |          | P |                 |
|                 | u |         | x |          | h |          | h |                 |
|                 | g |         | o |          | o |          | o |                 |
|                 | / |         | n |          | s |          | s |                 |
|                 | c |         | ( |          | m |          | m |                 |
|                 | m |         | u |          | e |          | e |                 |
|                 | ^ |         | g |          | t |          | t |                 |
|                 | 2 |         | / |          | ( |          | O |                 |
|                 | ^ |         | c |          | u |          | x |                 |
|                 | ) |         | m |          | g |          | o |                 |
|                 | * |         | ^ |          | / |          | n |                 |
|                 | * |         | 2 |          | c |          | ( |                 |
|                 |   |         | ^ |          | m |          | u |                 |
|                 |   |         | ) |          | ^ |          | g |                 |
|                 |   |         | * |          | 2 |          | / |                 |
|                 |   |         | * |          | ^ |          | c |                 |
|                 |   |         |   |          | ) |          | m |                 |
|                 |   |         |   |          | * |          | ^ |                 |
|                 |   |         |   |          | * |          | 2 |                 |
|                 |   |         |   |          |   |          | ^ |                 |
|                 |   |         |   |          |   |          | ) |                 |
|                 |   |         |   |          |   |          | * |                 |
|                 |   |         |   |          |   |          | * |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
| ED -3           |   | 0.006   |   | 0.0016   |   | 0.01     |   | 0.001           |
|                 |   |         |   |          |   |          |   |                 |
| Pre-Application |   |         |   |          |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.016   |   | 0.0016   |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.013   |   | 0.0016   |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.010   |   | 0.0016   |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.002   |   | 0.0000   |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
| ED -2           |   | 6.7     |   | 0.012    |   | 5.9      |   | 0.012           |
|                 |   |         |   |          |   |          |   |                 |
| Day of          |   |         |   |          |   |          |   |                 |
|                 |   |         |   |          |   |          |   |                 |
| Second          |   |         |   |          |   |          |   |                 |
|                 |   |         |   |          |   |          |   |                 |
| Application     |   |         |   |          |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 6.6     |   | 0.011    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 5.5     |   | 0.011    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 5.4     |   | 0.012    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 5.6     |   | 0.012    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 6.4     |   | 0.009    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
| ED 0            |   | 4.4     |   | 0.009    |   | 5.0      |   | 0.010           |
|                 |   |         |   |          |   |          |   |                 |
| Day of          |   |         |   |          |   |          |   |                 |
|                 |   |         |   |          |   |          |   |                 |
| Exposure        |   |         |   |          |   |          |   |                 |
|                 |   |         |   |          |   |          |   |                 |
| (2 days after   |   |         |   |          |   |          |   |                 |
|                 |   |         |   |          |   |          |   |                 |
| second          |   |         |   |          |   |          |   |                 |
| application)    |   |         |   |          |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 5.9     |   | 0.010    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 4.6     |   | 0.009    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 5.0     |   | 0.010    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 4.9     |   | 0.011    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 5.8     |   | 0.010    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 4.7     |   | 0.012    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 4.1     |   | 0.008    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 4.7     |   | 0.009    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 4.8     |   | 0.009    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
| ED +1           |   | 3.8     |   | 0.010    |   | 3.6      |   | 0.009           |
|                 |   |         |   |          |   |          |   |                 |
| (3 days after   |   |         |   |          |   |          |   |                 |
| second          |   |         |   |          |   |          |   |                 |
|                 |   |         |   |          |   |          |   |                 |
| application)    |   |         |   |          |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 3.5     |   | 0.008    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 3.3     |   | 0.008    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 3.6     |   | 0.008    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 3.7     |   | 0.009    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
| ED +2           |   | 1.7     |   | 0.008    |   | 1.2      |   | 0.006           |
|                 |   |         |   |          |   |          |   |                 |
| (4 days after   |   |         |   |          |   |          |   |                 |
| second          |   |         |   |          |   |          |   |                 |
|                 |   |         |   |          |   |          |   |                 |
| application)    |   |         |   |          |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 1.0     |   | 0.006    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.7     |   | 0.005    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 1.2     |   | 0.007    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 1.4     |   | 0.006    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
| ED +3           |   | 1.0     |   | 0.005    |   | 1.0      |   | 0.006           |
|                 |   |         |   |          |   |          |   |                 |
| (5 days after   |   |         |   |          |   |          |   |                 |
| second          |   |         |   |          |   |          |   |                 |
|                 |   |         |   |          |   |          |   |                 |
| application)    |   |         |   |          |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 1.3     |   | 0.009    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.6     |   | 0.004    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.9     |   | 0.007    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 1.3     |   | 0.007    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
| ED +4           |   | 0.9     |   | 0.005    |   | 0.7      |   | 0.004           |
|                 |   |         |   |          |   |          |   |                 |
| (6 days after   |   |         |   |          |   |          |   |                 |
| second          |   |         |   |          |   |          |   |                 |
|                 |   |         |   |          |   |          |   |                 |
| application)    |   |         |   |          |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.8     |   | 0.004    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.5     |   | 0.004    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.6     |   | 0.004    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+
|                 |   | 0.9     |   | 0.005    |   |          |   |                 |
+-----------------+---+---------+---+----------+---+----------+---+-----------------+

Phosmet residues were corrected for an average field fortification of
83%

Phosmet Oxon residues were corrected for an average field fortification
of 91.7%

**[III DISCUSSION:]{.underline}**

**[A. LIMITATIONS OF THE STUDY:]{.underline}**

Major issues of concern in evaluation of the study include:

-   Other than a molecular weight factor to account for the difference
    in molecular weight between the urinary metabolite sulfonyl, and the
    active ingredient phosmet, the Study Author did not factor any
    pharmacokinetic data into the estimation of phosmet equivalent dose.
    One factor typically considered in the estimate of dose is the
    percentage of active ingredient converted to urinary metabolite and
    subsequently excreted in the urine. Another factor to be considered
    is the percentage of metabolite expected to be excreted during the
    sampling time period. The Study Report protocol states that the
    sulfinyl and sulfonyl metabolites of phosmet account for
    approximately 50-60% of the administered radioactivity in urine in a
    rat oral metabolism study. The Authors did not take this into
    consideration in their estimate of dose.

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```
-   Many of the 24 hour urine collections demonstrate total volumes
    substantially below what is expected for normal, healthy adults. The
    volume of urine produced by a normal adult over a 24 hour period
    typically ranges between 800 and 1800 mL (Tietz, 1970). Sample
    volumes obtained from the 16 workers against this standard
    demonstrate that 28 of 123 urine collections were below what
    normally would be expected.

-   The Study Authors attempted to correct for incomplete urine
    collection. They adjusted sulfonyl concentration in the urine
    samples using a technique which compared measured creatinine to
    expected creatinine for each individual at each sampling event (Mage
    et al., 2004). Based on this estimate of expected creatinine, an
    adjustment factor was applied to the sulfonyl concentration in each
    urine collection. Use of this correction strategy resulted in
    adjustment factors ranging from 0.64 to 4.38. Use of factors of
    these magnitudes indicate that in some instances, urine volume was
    as low as 25% of the expected volume.

-   The study Authors also applied the adjustment factor to those
    samples where the actual creatinine level was higher than the
    expected creatinine level (e.g., adjustment factor \< 1.0). This had
    the effect of reducing the sulfonyl/sulfinyl that was actually
    excreted by those individuals.

-   The DFR analysis was most likely compromised by an exposure day
    rainfall event. The Study Report states that the "continued hard
    rain at the end of the exposure day had affected the dissipation
    kinetics and that a meaningful dissipation curve could not be
    developed." The study authors report that residue levels on the
    first and second day after the second application (approximately 6
    and 5 ug/cm^2,^ respectively) were consistent with expected DFR
    values. When comparing the DFR results with previously conducted
    phosmet dissipation regression curves, it appears that residues
    levels determined after the rain event demonstrate significantly
    lower levels than those expected.

-   In the afternoon of the reentry day, postapplication activities were
    cut short due to heavy rain. The affect of this event on the phosmet
    exposure estimate is unknown. It is possible, however, that
    meaningful exposure was affected. The rainfall could have washed the
    transferable residue from the leaves, and/or washed residue from the
    workers' skin and clothing. Or it is possible that the rain would
    solubilize the DFRs making them more readily available for transfer,
    or the water mass could have pushed residues through the clothing to
    skin increasing dermal exposure, or the damp clothing could hydrate
    the skin, possibly enhancing dermal absorption.

-   Urinary field fortification levels were inconsistent, with seven
    samples, or 25%, demonstrating recovery values less than 50%. The
    Study Author deleted these values from the calculation of average
    recovery, reporting that the values must have been misfortified. If
    these fortification values were included in the calculations,
    overall recovery would be 84%, necessitating the use of a correction
    factor.

-   The clothing worn by the workers was inconsistent. It is difficult
    to accurately characterize exposure in these circumstances. Table 1
    outlines the clothing worn by the individual workers. A few of the
    workers wore jackets for part of the workday, some of the workers
    wore gloves, some wore hats, some workers wore short-sleeved shirts
    and others wore long-sleeved shirts.

-   Several of the urine samples demonstrate incomplete oxidation of
    sulfinyl metabolite to the quantified metabolite, sulfonyl. The
    phosmet equivalent levels are based on measurement of sulfonyl only.
    The Study Authors did not adjust the estimate of phosmet
    concentration to account for this.

```{=html}
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```
-   EPA Reg No. 10163-169 specifies a maximum use rate of 4.25 lbs.
    ai/A. The test substance was applied to the peach trees at a rate of
    3 lbs. ai/A.

-   Postapplication activities were cut short (i.e., the workers worked
    6.5 hours on the day of exposure) due to the rainfall.

-   Creatinine levels were determined; however, it was not reported if
    the specific gravity of the urine was analyzed.

-   It is not well established that washed red cells can be frozen for a
    period of approximately one month and then assayed for RChe
    activity, as was the case in this Study. The laboratory utilized by
    the Study Author reports that their RChe method was validated using
    fresh specimens (within 48 hours of collection) for estimation of
    RChe activity. The analytical lab utilized for cholinesterase
    testing does not have data to support whether or not frozen storage
    would affect stability.

```{=html}
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```
-   This study was conducted at only one test site, a peach orchard in
    Morven, Georgia. Therefore, DFR data was not collected from at least
    three geographically distinct locations for each formulation and
    crop type as specified in the guidelines.

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Name: Name:

Evaluator Peer Reviewer

Occupational Exposure Assessment Section Occupational Exposure
Assessment Section

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date Date

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Name:

Head,

Occupational Exposure Assessment Section

\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

Date

**APPENDIX A**

**Compliance Checklists for "Biomonitoring of Workers Hand-thinning
Peaches Treated with Phosmet Insecticide"**

**COMPLIANCE CHECKLIST**

Compliance with OPPTS Series 875, Postapplication Occupational and
Residential Exposure Test Guidelines, Group B: Guidelines, 875.2600
(Biological monitoring) is critical. The itemized checklist below
describes compliance with the major technical aspects of OPPTS 875.2600.

875.2600:

-   *The Agency requires investigators to submit protocols for review
    purposes prior to the inception of the study. Adequate
    pharmacokinetic data must exist to effectively interpret the data.*
    This criterion was met.

```{=html}
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```
-   *Expected deviations from GLPs should be presented concurrently with
    any protocol deviations and their potential study impacts.* This
    criterion was met.

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```
-   *The test substance should be a typical end use product of the
    active ingredient.* This criterion was met.

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```
-   *The application rate used in the study should be provided and
    should be the maximum rate specified on the label. However,
    monitoring following application at a typical application rate may
    be more appropriate in certain cases.* This criterion was not met.
    The label states the maximum use rate is 4.25 lbs. ai/acre. The test
    substance was applied to the peach trees at a rate of 3 lbs.
    ai/acre.

-   *Selected sites and seasonal timing of monitoring should be
    appropriate to the activity.* This criterion was met.

-   *A sufficient number of replicates should be generated to address
    the exposure issues associated with the population of interest.
    Specifically, each study should include a minimum of 15 individuals
    (replicates) per activity.* This criterion was met.

-   *Test subjects should be regular workers, volunteers trained in the
    work activities required, or typical homeowners*. This criterion was
    met.

-   *The monitored activity should be representative of a typical
    working day for the specific task in order to capture all related
    exposure activities.* This criterion may not have been met.
    Meaningful exposure was possibly affected by rainfall on the day the
    thinning tasks were conducted. In the afternoon of the reentry day,
    postapplication activities were cut short due to a significant rain
    event.

-   *The exposure monitoring period should be of sufficient length to
    ensure reasonable detectability of residues in biological media
    (e.g., blood and urine) consistent with pharmacokinetic data such as
    excretion profile, duration time, etc.* This criterion was met.

-   *Biomonitoring should be conducted using methodologies based on the
    pharmacokinetic properties of the pesticide (parent compound and its
    metabolites) of concern* *(e.g., need validated pharmacokinetic
    models from humans or appropriate animal surrogate and appropriate
    route of exposure).* This criterion was not met. The study author
    did not account for the pharmacokinetics of the metabolite when
    estimating phosmet equivalents.

-   *Any protective clothing worn by study participants should be
    identified and should be consistent with the product label.* This
    criterion was partially met. The clothing worn by the participants
    was identified; however, the test subjects wore their own clothing
    on the day of reentry, resulting in inconsistent work apparel. It is
    difficult to accurately characterize exposure in these
    circumstances.

-   *If urine monitoring is being conducted, urine samples should be
    collected one or two days before participating in the applicator
    exposure monitoring activities and should continue on the day of
    exposure and for an appropriate time period after these activities
    have been completed, depending on the excretion kinetics of the
    compound. The 24-hour sample collection cycle should begin with the
    first void after beginning work activities and end with the first
    void on the following morning, continuing this 24-hour cycle on
    subsequent days.* This criterion was not met. It appears that the
    urine sample collections were incomplete. 28 of 123 urine
    collections were below what normally would be expected in a normal
    healthy adult.

-   *If blood monitoring is being conducted, baseline blood samples
    should be collected from each individual prior to exposure. Based on
    pharmacokinetics, postapplication exposure samples should be
    collected at the appropriate times before, during, and after
    exposure.* This criterion was met.

-   *Materials used for sample collection should not interfere with
    (e.g., absorb) the analytes of interest.* This criterion was met.

-   *Creatinine levels should be determined as a way of qualitatively
    monitoring completeness of urine collection samples.* *Specific
    gravity, as another measure of 24-hour sample completeness, should
    be performed as soon after collection as possible (and before sample
    storage)*. These criteria were partially met. Creatinine levels were
    determined; however, it was not reported if the specific gravity of
    the urine was analyzed.

-   *Prior exposures to the test pesticide or structurally related
    compounds may interfere with study results. A brief history should
    be taken from each participant relating to known prior exposures to
    pesticides for at least the last 2 weeks, including reentry into
    potentially treated fields*. *For urine monitoring, there should
    also be a sufficient time period between such exposures and
    participation in the study to ensure adequate urinary clearance of
    the compound and its metabolites, based on pharmacokinetic data.*
    This criterion was met.

-   *Validated analytical methods for the biological analyte (parent
    compound and its metabolites) of sufficient sensitivity are needed.
    Information on method efficiency and limit of quantitation (LOQ)
    should be provided.* This criterion was met.

-   *Samples should be stored in a manner that will minimize
    deterioration and loss of analytes between collection and analysis.
    Biological monitoring samples (e.g., serum, plasma and urine) should
    be refrigerated or stored frozen prior to analysis. Whole blood
    should not be frozen. Information on storage stability should be
    provided.* This criterion was met. The red blood cells were washed
    with saline prior to frozen storage. It is expected that lysis of
    the red blood cells due to freezing would not interfere with the red
    blood cell cholinesterase testing.

-   *Data should be corrected if any appropriate field fortified,
    laboratory fortified or storage stability recovery is less than 90
    percent.* This criterion was not met. Overall average recovery of
    all field fortification samples was 84%; however, the study author
    excluded seven of the samples they considered to be misfortified
    with recovery values \<50%. This resulted in an overall average
    recovery of 103%.

-   *Unless stability of the analyte has been established prior to
    initiation of the study, three samples of control (nonparticipant)
    should be fortified with two levels of the biological analyte
    (parent or metabolite(s), whichever is appropriate) for each
    experimental site.* .This criterion was met.

-   *Each subject's absorbed dose should be expressed in terms of body
    weight using his/her own measured value, and as a cumulative total
    for each exposure period. The arithmetic mean, range, standard
    deviation, and coefficient of variation should be calculated from
    the results of all individuals. Geometric mean, range and standard
    deviation may be calculated if the results are shown to be
    log-normally distributed. Other distributional data should be
    reported, to the extent possible (e.g., percentiles).* These
    criteria were partially met.

**COMPLIANCE CHECKLIST**

Compliance with OPPTS Series 875, Postapplication Occupational and
Residential Exposure Test Guidelines, Group B: Guidelines, 875.2100
(dislodgeable foliar residue dissipation - postapplication) is critical.
The itemized checklist below describes compliance with the major
technical aspects of OPPTS 875.2100.

875.2100:

-   *The test substance must be the typical end use product of the
    active ingredient.* This criterion was met.

-   *The production of metabolites, breakdown products, or the presence
    of contaminants of potential toxicologic concern, should be
    considered on a case-by-case basis.* This criterion was partially
    met. The Study assayed for both phosmet and phosmet oxon, however,
    no explanation was provided for other possible breakdown products.

-   *Applications should occur at the time of season that the end-use
    product is normally applied to achieve intended pest control.* This
    criterion was met.

-   *Initiating testing immediately before a precipitation event should
    be avoided.* This criterion was partially met. The Study Authors
    reported that "examination of the post-exposure DFR results let us
    to conclude that the continuing hard rain at the end of the exposure
    day had affected the dissipation kinetics".

-   *The end use product should be applied by the application method
    recommended for the crop. Information that verifies that the
    application equipment (e.g., sprayer) was properly calibrated should
    be included.* This criteria was met. The application equipment was
    calibrated and airblast application is the recommended treatment for
    peach trees.

-   *The application rate used in the study should be provided and
    should be the maximum rate specified on the label. However,
    monitoring following application at a typical application rate is
    more appropriate in certain cases.* This criterion was not met. The
    label states the maximum use rate is 3.75 lbs. ai/acre. The test
    substance was applied to the peach trees at a rate of 3 lbs.
    ai/acre.

-   *If multiple applications are made, the minimum allowable interval
    between applications should be used.* This criterion was met.

-   *Dislodgeable foliar residue (DFR) data should be collected from at
    least three geographically distinct locations for each formulation
    and crop type. The sites should be representative of the regions
    (and crops) where the chemical is used.* This criterion was not met.
    This study was conducted at only one test site, a peach orchard in
    Morven, Georgia.

-   *The site(s) treated should be representative of reasonable
    worst-case climatic conditions expected in intended use areas.
    Meteorological conditions including temperature, wind speed, daily
    rainfall, and humidity should be provided for the duration of the
    study.* This criterion was met.

-   *Sampling should be sufficient to characterize the dissipation
    mechanisms of the compound (e.g., three half-lives or 35 days after
    the final application, unless the compound has been found to fully
    dissipate in less time; for more persistent pesticides, longer
    sampling periods may be necessary). Sampling intervals may be
    relatively short in the beginning and lengthen as the study
    progresses. Background samples should be collected before
    application of the test substance occurs.* This criteria was not
    met, however, the purpose of collection DFR residue for this study
    was to characterize the residue level on the day of reentry, The DFR
    data was not intended to be used to establish a dissipation curve".

-   *Triplicate, randomly collected samples should be collected at each
    sampling interval.* This criterion was met.

-   *A leaf punch apparatus should be used unless the nature of the crop
    precludes its use. Samples should represent at least an area of 400
    cm2.* This criterion was met.

-   *Control plots should be established from which sufficient control
    samples can be collected. Control sites should be upwind and a
    reasonable distance from the treatment site.* This criterion may
    have been met. The study author reported that additional nontreated
    control samples were collected from nontreated orchards; however,
    the location of this orchard was not specified in the report and the
    collected residues were not assayed..

-   *Residues should be dislodged from leaf surfaces using an aqueous
    surfactant solution within a reasonable time period (i.e., EPA
    recommends that dislodging occur within 4 hours). Dislodging should
    be repeated at least once and the resultant solutions pooled for
    analysis.* This criterion was met.

-   *Samples should be stored in a manner that will minimize
    deterioration and loss of analytes between collection and analysis.
    Information on storage stability should be provided.* This criterion
    was met.

-   *Validated analytical methods of sufficient sensitivity are needed.
    Information on method efficiency (residue recovery), and limit of
    quantitation (LOQ) should be provided.* This criterion was met.

-   *Information on recovery samples must be included in the study
    report. A complete set of field recoveries should consist of at
    least one blank control sample and three or more each of a low-level
    and high-level fortification. These fortifications should be in the
    range of anticipated residue levels in the field study.* This
    criterion was met.

-   *Raw residue data must be corrected if appropriate recovery values
    are less than 90 percent).* This criteria was met.

-   *Dislodgeable foliar residues should be reported as mg or µg per
    m^2^ or cm^2^ of leaf sampled. Distributional data should be
    reported, to the extent possible.* This criterion was met.

[REFERENCES]{.underline}

Mage, David T., Allen, R.H., Gondy, G, Smith, W., Barr, D.B., and L.
Needham. Estimating pesticide dose from urinary pesticide concentration
data by creatinine correction in the Third National Health and Nutrition
Examination Survey (NHANES-III). (2004). JEAEE14:457-465.

Tietz, Norbert W. ed. (1970). Fundamentals of Clinical Chemistry,
Philadelphia, PA: W.B. Saunders Company. ISBN 0-7216-8865-9.