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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460 

OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION

Date: December 18, 2015

Subject: Fluopyram. Occupational and Residential Exposure Assessment for New Uses

on artichoke (globe), Brassica (cole) leafy vegetables, Brassica (cole) leafy

vegetables head and stem subgroup, bulb vegetables, canola, carrot, cereal grains 

(except rice), citrus, corn (including field, sweet, popcorn, and field corn grown 

for seed)cotton, cucurbit vegetables, fruiting vegetables, ginseng, grapes and 

small vines fruits (except fuzzy kiwifruit), herbs and spices (except black pepper), 

hops, leafy vegetables, legume vegetables (including soybean), peanut, pome 

fruits, potato and other root, tuberous and corm vegetables, small berries 

(caneberries and bushberries), stone fruit, strawberry and other low growing 

berries, sugar beet, sunflower subgroup, tree nuts; use as a seed treatment to 

peanuts; turf grass (golf courses, sod farms, sports fields, residential, industrial, 

municipal, commercial, and other turf grass areas), ornamentals (in residential and 

commercial settings), and Christmas trees.

PC Code: 080302 DP Barcode: D426622

Decision No.: 492321 File Symbols and Registration No.: 432-RLGI; 432-

RLGT; 432-RLGA; 432-RLGL; 432-RLUG; 264-1078; 

264-1084; 264-1085; 264-1090; 264-1091

Petition No.: 4F8284 Regulatory Action: Section 3

Risk Assessment Type: Occupational/Residential

Exposure Assessment

Case No.: NA

TXR No.: NA CAS No.: 658066-35-4

MRID No.: NA 40 CFR: §180.661

From: Barry O’Keefe, Senior Biologist

Risk Assessment Branch III

Health Effects Division (7509P)

Through: Christine Olinger, Branch Chief

Risk Assessment Branch III

Health Effects Division (7509P)

and

Matthew Lloyd, CIH, ExpoSAC Reviewer

Cassi Walls, Ph.D., ExpoSAC Reviewer

Exposure Science Advisory Committee (ExpoSAC) / HED
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To: Barry O’Keefe, Risk Assessor

Risk Assessment Branch III

Health Effects Division (7509P)

and

Tamue Gibson, Risk Management Team #20

Fungicide Herbicide Branch

Registration Division (7505P)

Introduction

The Health Effects Division (HED) of the Office of Pesticide Programs (OPP) is charged with 

estimating the risk to human health from exposure to pesticides. The Registration Division (RD) 

of OPP has requested that HED evaluate the hazard and exposure data and conduct occupational 

and residential exposure assessments, as needed, to estimate the risk to human health that will 

result from the proposed uses of fluopyram; the other active ingredients in the combination 

products have been addressed in separate assessments. This memorandum serves as HED’s 

assessment of the occupational and residential exposure and risk from these proposed uses. 

It is HED policy to use the best available data to assess exposure. Several sources of generic 

data were used in this assessment as surrogate data in the absence of chemical-specific data, 

including Pesticide Handlers Exposure Database Version 1.1 (PHED 1.1); the Agricultural 

Handler Exposure Task Force (AHETF) database; the Outdoor Residential Exposure Task Force 

(ORETF) database; ExpoSAC Policy 14, 15, and 15.1 (SOPs for Seed Treatment), The 

Reviewer’s Aid to Calculating Occupational Exposure from Activities Related to Agricultural 

Seed Treatment, the Agricultural Reentry Task Force (ARTF) database; and the Residential

SOPs (turf, gardens and trees). Some of these data are proprietary, and subject to the data 

protection provisions of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

Note: This memorandum was reviewed by the Exposure Science Advisory Committee 

(ExpoSAC) on August 27, 2015. 
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Table of Contents

1.0 Executive Summary............................................................................................................. 4

2.0 Risk Assessment Conclusions and Recommendations........................................................ 7

2.1 Summary of Risk Estimates............................................................................................. 7

2.2 Data Deficiencies and Requirements ............................................................................... 7

2.3 Label Recommendations.................................................................................................. 7

3.0 Hazard Characterization....................................................................................................... 7

4.0 Use Profile ......................................................................................................................... 10

5.0 Residential Exposure and Risk Estimates.......................................................................... 28

5.1 Residential Handler Exposure/Risk Estimates............................................................... 28

5.2 Residential Post-application Exposure/Risk Estimates for Proposed Uses ................... 30

5.3 Combined Residential Risk Estimates (Multiple Exposure Scenarios)......................... 32

5.4 Residential Risk Estimates for Use in Aggregate Assessment ...................................... 32

5.5 Spray Drift...................................................................................................................... 33

5.6 Residential Bystander Post-Application Inhalation Exposure ....................................... 33

6.0 Occupational Exposure and Risk Estimates ...................................................................... 34

6.1 Occupational Handler Exposure/Risk Estimates............................................................ 34

6.2 Occupational Post-application Exposure/Risk Estimates .............................................. 43

6.2.1 Occupational Post-application Inhalation Exposure/Risk Estimates...................... 44

6.2.2 Occupational Post-application Dermal Exposure/Risk Estimates.......................... 44

Appendix A. Summary of Occupational and Residential Non-cancer Algorithms..................... 51
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1.0 Executive Summary

The active ingredient, fluopyram (N-[2-[3-chloro-5-(trifluoromethyl)-2-pyridinyl]ethyl]-2-

(trifluoromethyl)benzamide) is a pyridylethylamide SDH (succinate-dehydrogenase-inhibitor, 

complex II) fungicide with broad spectrum of activity against fungal diseases in a wide range of 

crops. 

Use Profile

The registrant, Bayer CropScience, is requesting numerous new uses on agricultural field crops 

and crop groups be added to the Luna®Privilege label (4.16 lb ai/gal) [EPA Reg. No. 264-1078]

that contains the sole active ingredient (ai) fluopyram. Additionally, Bayer CropScience is 

requesting to add numerous agricultural field crops and crop groups to the following multi-active 

ingredient labels: 1) PropulseTM (1.67 lb ai/gal) [EPA Reg. No. 264-1084] which contains 

fluopyram and prothioconazole; 2) Luna®Tranquility (1.04 lb ai/gal) [EPA Reg. No. 264-1085] 

which contains fluopyram and pyrimethanil; 3) Luna®Sensation (2.1 lb ai/gal) [EPA Reg. No. 

264-1090] which contains fluopyram and trifloxystrobin; and 4) Luna®Experience (1.67 lb 

ai/gal) [EPA Reg. No. 264-1091] which contains fluopyram and tebuconazole. 

In addition, Bayer CropScience is requesting a new seed treatment use on peanut seeds to be 

added to the Luna®Privilege label (4.16 lb ai/gal) [EPA Reg. No. 264-1078].

Bayer CropScience, is also requesting new non-food uses of fluopyram on several newly 

proposed labels, including turf grass (golf courses, sod farms, sports fields, residential, industrial, 

municipal, commercial, and other turf grass areas), ornamentals (in residential and commercial 

landscapes, interiorscapes, field grown and container ornamentals, in nurseries, and greenhouses, 

lathhouses, shadehouses, containers and other enclosed structures), fruit and nut trees (including 

citrus, grapes, pome fruits, stone fruits, and tree nuts), ornamental sunflower, and Christmas 

trees. The proposed labels are as follows: 1) Fluopyram 500 SC (4.16 lb ai/gal) [EPA File 

Symbol 432-RLGI] which contains fluopyram; 2) FLU+TFS SC 500 (2.1 lb ai/gal) [EPA File 

Symbol 432-RLGT] which contains fluopyram and trifloxystrobin; 3) FLU+TFS SC 32.5 (0.104 

lb ai/gal) [EPA File Symbol 432-RLGA] which contains fluopyram and trifloxystrobin; 4) 

FLU+TFS SC 25 (0.104 lb ai/gal) [EPA File Symbol 432-RLGL] which contains fluopyram and 

trifloxystrobin; and 5) 13ESP715 3.3 SC (3.34 lb ai/gal) [EPA File Symbol 432-RLUG] which 

contains fluopyram. 

Most of the proposed labels require occupational handlers to wear the following personal 

protective equipment (PPE): long sleeved shirts, long pants, shoes, socks, and chemical resistant 

gloves. However, the FLU+TFS SC 32.5 and FLU+TFS SC 25 labels do not require the use of 

gloves. Additionally, for the Luna®Privilege label requires water proof gloves for seed 

treatment activities and no gloves for baggers and bag sewers.

On all registered and proposed labels the restricted entry interval (REI) is 12 hours.

Fluopyram is currently registered on a variety of agricultural food crops, including apple, cherry

(sweet and tart), cotton, dried beans, peanut, potato, strawberry, sugar beets, tree nuts,
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watermelon, viniferous variety grapes, and for seed treatment to cotton and soybean. There are 

no existing residential uses of fluopyram.

Exposure Profile

There is a potential for short- and intermediate-term occupational dermal and inhalation exposure 

to fluopyram during handling tasks (mixing, loading, and application) and during postapplication activities. Long-term occupational exposure is not expected for the proposed use 

patterns associated with fluopyram. There is a potential for residential short-term dermal and 

inhalation exposure to fluopyram to adults during handling tasks. During residential postapplication activities there is a potential for short-term dermal exposure to adults, youths, and 

children and incidental oral exposure to children 1 to <2 years old.

Hazard Concerns

There have been no changes in the hazard characterization, toxicity endpoints, or points of 

departure (PODs) since the last risk assessment for fluopyram. The toxicity database is 

considered complete for risk assessment. The liver was the target organ across species and 

exposure durations. Treatment-related thyroid effects were also observed at dose levels causing 

adverse liver perturbations in rats and mice. Decreased body weight was a common clinical 

finding throughout the toxicology database. Liver tumors were observed in female rats and 

thyroid tumors were observed in male mice in chronic feeding studies. 

Short- and intermediate-term dermal endpoints were chosen from a dermal toxicity study in rats 

in which increased prothrombin time and altered cholesterol levels were seen at the limit dose 

(NOAEL = 300 mg/kg/day). Short- and intermediate-term inhalation and short-term incidental 

oral risks are based on clinical chemistry and kidney effects in the parental generation observed 

at the LOAEL of 82.8 mg/kg/day (NOAEL of 14.5 mg/kg/day) from a 2-generation reproduction 

study in rats.

The subchronic inhalation study data requirement was waived by the Hazard and Science Policy

Council (HASPOC, K. Rury, 1/30/13, TXR No. 0056523). Since the dermal and inhalation 

endpoints are not based on developmental effects, the average body weight of an adult (80 kg) 

was used in the exposure assessments. Since the toxicological effects for dermal and inhalation 

routes are not similar, the risk estimates from both routes are not combined together. Also, since 

the toxicological effects for dermal and incidental oral routes are not similar, the risk estimates 

from both routes are not combined together.

HED recommends that the Food Quality Protection Act (FQPA) safety factor be reduced to 1x 

because there are no residual uncertainties with regard to pre- and postnatal susceptibility, the 

toxicology database is complete, and there is no evidence of neurotoxicity.

Fluopyram has low acute toxicity by the oral and dermal routes of exposure (Toxicity Category

III) and also by the inhalation route of exposure (Toxicity Category IV). It is not a dermal or eye 

irritant and is not a dermal sensitizer.

The cancer classification is “not likely to be carcinogenic to humans.” There is no mutagenic 

concern for fluopyram. 
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Occupational Exposure

No chemical-specific handler exposure data were submitted in support of these Section 3

registrations. To assess handler exposures for regulatory actions when chemical-specific 

monitoring data are not available, HED used the most scientifically-reliable surrogate data 

currently available from various sources such as the PHED and the AHETF. Some of this data, 

such as the industry task force data, is compensatory, subject to the data protection provisions of 

FIFRA. 

For occupational handlers for agricultural crops, turf, and Christmas trees, all short- and 

intermediate-term risk estimates resulted in margins of exposure (MOEs) ≥100, and therefore, do 

not exceed HED’s level of concern at any level of protection. For dermal exposures at baseline 

personal protective equipment (PPE), MOEs range from 410 to 1,500,000. For dermal exposures 

with gloves, MOEs range from 2,400 to 1,100,000. For inhalation exposures, MOEs range from 

7,400 to 5,400,000. For the seed treatment use on peanut seeds, risk estimates for dermal and 

inhalation short-term occupational handler exposures all resulted in MOEs ≥100, and therefore, 

do not exceed HED’s level of concern, with MOEs ranging from 1,400 to 9,200 for dermal 

exposures and from 1,700 to 17,000 for inhalation exposures.

Short- and intermediate-term dermal post-application exposures and risks to occupational 

workers were estimated using standard values established by HED, since no chemical-specific 

data were submitted. For all occupational post-application scenarios the dermal MOEs, at day

zero following application, do not exceed HED’s level of concern (MOEs ≥100), with dermal 

MOEs ranging from 270 to 23,000. Additionally, several post-application worker scenarios 

involved with the mechanical harvesting of cotton were assessed. The dermal exposures to these 

harvesters of cotton resulted in risk estimate MOEs ranging from 3,100,000 to 17,000,000, which 

also do not exceed HED’s level of concern (MOEs ≥100).

Based on the Agency's current practices, a quantitative occupational post-application inhalation 

exposure assessment was not performed for fluopyram at this time. If new policies or procedures 

are put into place, the Agency may revisit the need for a quantitative occupational postapplication inhalation exposure assessment for fluopyram.

Restricted Entry Interval: The 12-hour REI that appears on the registered and proposed labels is 

adequate to protect for worker exposure to fluopyram. 

Residential Exposure

All residential handler risk estimates are not of concern to HED (all MOEs ≥100), with MOEs 

ranging from 8,900 to 190,000 for dermal exposures and 260,000 for inhalation exposures.

For treated lawns and turf, all residential post-application risk estimates are not of concern to 

HED (all MOEs ≥100), with dermal post-application MOEs for all life stages ranging from 1,000 

to 97,000 and incidental oral post-application MOEs for children 1 to <2 years old ranging from 

2,400 to 1,100,000. For treated gardens, ornamental trees and shrubs, and fruit trees, the dermal 

post-application MOEs for all life stages range from 2,100 to 33,000 and are not of concern to 

HED (MOEs ≥100).
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Human Studies Review

This risk assessment relies in part on data from studies in which adult human subjects were 

intentionally exposed to a pesticide or other chemical. These data, which include studies from 

PHED 1.1; the AHETF database; the ARTF database; the ORETF database, and ExpoSAC 

Policies 14, 15, and 15.1 (SOPs for Seed Treatment), and The Reviewer’s Aid to Calculating 

Occupational Exposure from Activities Related to Agricultural Seed Treatment are (1) subject to 

ethics review pursuant to 40 CFR 26, (2) have received that review, and (3) are compliant with 

applicable ethics requirements. For certain studies, the ethics review may have included review 

by the Human Studies Review Board. Descriptions of data sources, as well as guidance on their 

use, can be found at the Agency website1. 

2.0 Risk Assessment Conclusions and Recommendations

2.1 Summary of Risk Estimates

There are no occupational or residential risk estimates of concern associated with the proposed 

uses of fluopyram. 

2.2 Data Deficiencies and Requirements

There are no data deficiencies or requirements missing from the fluopyram database at this time.

2.3 Label Recommendations

Some of the proposed products for fluopyram are intended for use by residential applicators on 

home lawns or residential areas, but require certain clothing and/or PPE to be worn. Generally, 

the Agency does not consider PPE and clothing requirements to be enforceable on consumer 

lawn products. If products containing fluopyram are meant to be marketed towards and applied 

by residential handlers on residential turf, ornamentals, fruit trees, or gardens, HED recommends 

that the label requirements for clothing and/or PPE be reevaluated or separate consumer-specific 

labels be developed.

3.0 Hazard Characterization

Acute Toxicity

The acute toxicity for fluopyram is summarized in Table 3.1. Fluopyram has low acute toxicity

by the oral and dermal routes of exposure (Toxicity Category III) and by the inhalation route of 

exposure (Toxicity Category IV). It is not a dermal or eye irritant and is not a dermal sensitizer.

Table 3.1. Acute Toxicity Profile of Fluopyram Technical.

 

1

http://www.epa.gov/pesticides/science/handler-exposure-data.html and 

http://www.epa.gov/pesticides/science/post-app-exposure-data.html
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Guideline No. Study Type MRID(s) Results Toxicity 

Category

870.1100 Acute Oral 47372430

LD50 > 2000 mg/kg in 

females III

870.1200 Acute Dermal 47372432

LD50 > 2000 mg/kg in males 

&, females III

870.1300 Acute Inhalation (4 hr) 47372434

LC50 > 5.112 mg/L in males 

& females IV

870.2400 Primary Eye Irritation 47372436

No positive scores at 24 hr; 

not irritating IV

870.2500 Primary Skin Irritation 47723701 Not irritating IV

870.2600 Dermal Sensitization 47372440 Not sensitizing N/A

870.2600 Dermal Sensitization 47753403 Not sensitizing N/A

Toxicological PODs Used for Risk Assessment

Short- and intermediate-term dermal endpoints were chosen from a dermal toxicity study in rats 

in which increased prothrombin time and altered cholesterol levels were seen at the limit dose 

(NOAEL = 300 mg/kg/day). Short- and intermediate-term inhalation and short-term incidental 

oral risks are based on clinical chemistry and kidney effects in the parental generation observed 

at the LOAEL of 82.8 mg/kg/day (NOAEL of 14.5 mg/kg/day) from a 2-generation reproduction 

study in rats.

The subchronic inhalation study data requirement was waived by the HASPOC (K. Rury, 

1/30/13, TXR No. 0056523). Since no inhalation absorption data are available, toxicity by the 

inhalation route is considered to be equivalent to the estimated toxicity by the oral route of 

exposure. Since the dermal and inhalation endpoints are not based on developmental effects, the 

average body weight of an adult (80 kg) was used in the exposure assessments. Further, since 

the toxicological effects for dermal and inhalation routes are not similar, the risk estimates from 

both routes are not combined together.

For small children (1 to <2 years old), the risk estimates from the incidental oral and dermal 

routes should not be combined. The common effects seen in the dermal tox study (used for 

establish dermal endpoint) and the 2-generation reproduction study (used to establish the 

incidental oral endpoint) appeared to be increases in liver weights and hepatocellular 

hypertrophy, but these effects are adaptive effects. For the dermal toxicity study, the other 

endpoints at the LOAEL included increased prothrombin time (which is hematological effect). 

In contrast, the other endpoints for establishing the LOAEL were a host of effects including 

decreases in body weights with decreases in spleen and thymus weights and slight delay in 

preputial separation in the offsprings. Therefore, the adverse effects at LOAEL for establishing 

the tox endpoints in these two studies are different.
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HED recommends that the Food Quality Protection Act (FQPA) safety factor be reduced to 1x 

because there are no residual uncertainties with regard to pre- and postnatal susceptibility, the 

toxicology database is complete, and there is no evidence of neurotoxicity.

There is no mutagenic concern for fluopyram. HED classified fluopyram as “Not Likely to be 

Carcinogenic to Humans” at doses that do not induce cellular proliferation in the liver or thyroid 

glands (TXR# 0056961, CARC Report, 05/08/2014). This classification was based on 

convincing evidence that non-genotoxic modes of action for liver tumors in rats and thyroid 

tumors in mice have been established and that the carcinogenic effects have been demonstrated 

as a result of a mode of action dependent on activation of the CAR/PXR receptors. HED has 

determined that quantification of risk is not required (TXR# 0056961, CARC Report, 

05/08/2014).

A summary of the toxicological doses and endpoints for occupational and residential human 

health risk assessment is provided in Table 3.2.

Table 3.2. Summary of Toxicological Doses and Endpoints for Fluopyram for Use in Occupational and 

Residential Human Health Risk Assessments.

Exposure/

Scenario

Point of 

Departure

Uncertainty 

Factors

Level of Concern 

for Risk 

Assessment

Study and Toxicological Effects

Incidental Oral 

Short-Term (1-30 

days) and 

Intermediate-Term

(1-6 months)

NOAEL= 

14.5

mg/kg/day

UFA= 10X

UFH=10X

FQPA SF=1X

Residential LOC 

for MOE = 100

2-Generation reproduction study in rats

The LOAEL of 82.8 mg/kg/day is based 

clinical chemistry changes and increased 

kidney weight in parents, and decreased 

body weight and body weight gain with 

decreases in spleen and thymus weights in 

offspring.

Dermal Short-Term

(1-30 days) and 

Intermediate-Term

(1-6 months)

NOAEL= 

300

mg/kg/day

UFA= 10X

UFH=10X

FQPA SF=1X

Residential and 

Occupational LOC 

for MOE = 100

A 28-day dermal study in rats

The LOAEL of 1000 mg/kg/day is based 

on increased cholesterol (F), increased 

prothrombin time (M).

Inhalation ShortTerm (1-30 days)

and IntermediateTerm (1-6 months)

NOAEL= 

14.5 

mg/kg/day

UFA= 10X

UFH=10X

FQPA SF=1X

Residential and 

Occupational LOC 

for MOE = 100

2-Generation reproduction study in rats

The LOAEL of 82.8 mg/kg/day is based 

clinical chemistry changes and increased 

kidney weight in parents, and decreased 

body weight and body weight gain with 

decreases in spleen and thymus weights in 

offspring.

Cancer (oral, 

dermal, inhalation)

Classification: The CARC classified fluopyram as “Not Likely to be Carcinogenic to Humans” 

at doses that do not induce cellular proliferation in the liver or thyroid glands.

Point of Departure (POD) = A data point or an estimated point that is derived from observed dose-response data and used to 

mark the beginning of extrapolation to determine risk associated with lower environmentally relevant human exposures. NOAEL 

= no observed adverse effect level. LOAEL = lowest observed adverse effect level. UF = uncertainty factor. UFA = 

extrapolation from animal to human (interspecies). UFH = potential variation in sensitivity among members of the human 

population (intraspecies). MOE = margin of exposure. LOC = level of concern.
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4.0 Use Profile 

Fluopyram is currently registered on a variety of agricultural food crops, including apple, cherry

(sweet and tart), cotton, dried beans, peanut, potato, strawberry, sugar beets, tree nuts,

watermelon, viniferous variety grapes, and for seed treatment to cotton and soybean. There are 

currently no existing residential uses of fluopyram.

The registrant, Bayer CropScience, is requesting the addition of new uses of fluopyram on 

registered liquid formulation product labels, as follows: 

1) The Luna®Privilege label (4.16 lb ai/gal) [EPA Reg. No. 264-1078] contains only the 

active ingredient fluopyram. New uses are proposed on artichoke (globe), Brassica

(cole) leafy vegetables, bulb vegetables, canola, carrot, cereal grains (except rice), citrus, 

cotton, cucurbit vegetables, fruiting vegetables, ginseng, grapes and small vines fruits 

(except fuzzy kiwifruit), herbs and spices (except black pepper), hops, leafy vegetables, 

legume vegetables (including soybean), peanut, pome fruits, potato and other root, 

tuberous and corm vegetables, small berries (caneberries and bushberries), stone fruit, 

strawberry and other low growing berries (except cranberries), sugar beet, sunflower 

subgroup, and tree nuts. Additionally, the Luna Privilege label is also proposed for use as 

a seed treatment to peanuts.

2) The PropulseTM label (1.67 lb ai/gal) [EPA Reg. No. 264-1084] contains the active 

ingredients fluopyram and prothioconazole. New uses are proposed on barley, 

buckwheat, bushberry subgroup, canola, corn, crambe, cucurbit vegetables, field mustard, 

Indian rapeseed, low growing berries (except strawberries and cranberries), millet (pearl 

and proso), oats, rapeseed, rye, soybean, triticale, and wheat (spring, durum, and winter).

3) The Luna®Tranquility label (1.04 lb ai/gal) [EPA Reg. No. 264-1085] contains the 

active ingredients fluopyram and pyrimethanil. New uses are proposed on bulb 

vegetables, ginseng, lemons, pome fruit, tuberous and corm vegetables, small berries 

(caneberries and bushberries), stone fruit (except cherries), strawberries and other lowgrowing berries (except cranberries), and tomato.

4) The Luna®Sensation label (2.1 lb ai/gal) [EPA Reg. No. 264-1090] contains the active 

ingredients fluopyram and trifloxystrobin. New uses are proposed on artichoke (globe), 

Brassica (head and stem subgroup), Brassica (leafy greens subgroup), carrot, citrus, 

cucurbit vegetables, fruiting vegetables, ginseng, grapes and small vines fruits (except 

fuzzy kiwifruit), herbs and spices (except black pepper), hops, leafy vegetables (leafy

greens subgroup), leafy vegetables (leaf petioles subgroup), pome fruits, potato and other 

root, tuberous and corm vegetables, soybean, stone fruit, strawberry and other low 

growing berries (except cranberries), and wheat.

5) The Luna®Experience label (1.67 lb ai/gal) [EPA Reg. No. 264-1091] contains the 

active ingredients fluopyram and tebuconazole. New uses are proposed on barley, bean 

(fresh and dry, except succulent shelled), bulb vegetable, corn (sweet corn, field corn, 

field corn grown for seed, and popcorn), cotton, cucurbit vegetables, fruiting vegetables, 
Page 11 of 59

grapes and small vines fruits (except fuzzy kiwifruit), hops, leafy Brassica greens, okra, 

pome fruits, soybean, stone fruit, sunflower, and wheat.

Bayer CropScience, is also requesting the registration of several new end-use products 

containing the following new non-food uses of fluopyram: turf grass (golf courses, sod farms, 

sports fields, residential, industrial, municipal, commercial, and other turf grass areas), 

ornamentals (in residential and commercial landscapes, interiorscapes, field grown and container 

ornamentals, in nurseries, and greenhouses, lathhouses, shadehouses, containers and other 

enclosed structures), and Christmas trees. These new end-use product labels also include 

proposed uses on citrus, grapes and small vine fruits, pome fruits, stone fruits, sunflower, and 

tree nuts. All of these uses can be used by occupational, as well as residential, handlers. The 

proposed end-use product labels are as follows: 1) Fluopyram 500 SC (4.16 lb ai/gal) [EPA File 

Symbol 432-RLGI] which contains the active ingredient fluopyram; 2) FLU+TFS SC 500 (2.1 lb 

ai/gal) [EPA File Symbol 432-RLGT] which contains the active ingredients fluopyram and 

trifloxystrobin; 3) FLU+TFS SC 32.5 (0.104 lb ai/gal) [EPA File Symbol 432-RLGA] which 

contains the active ingredients fluopyram and trifloxystrobin; 4) FLU+TFS SC 25 (0.104 lb 

ai/gal) [EPA File Symbol 432-RLGL] which contains the active ingredients fluopyram and 

trifloxystrobin; and 5) 13ESP715 3.3 SC (3.34 lb ai/gal) [EPA File Symbol 432-RLUG] which 

contains the active ingredient fluopyram. 

The proposed labels require occupational handlers to wear the following attire and PPE: long 

sleeved shirts, long pants, shoes, socks, and chemical resistant gloves. However, the FLU+TFS 

SC 32.5 and FLU+TFS SC 25 labels do not require the use of gloves. Additionally, for seed 

treatment of peanuts, the Luna®Privilege label requires water proof gloves for seed treatment 

activities and no gloves for baggers and bag sewers.

On all registered and proposed labels the proposed REI for new uses is 12 hours.

The proposed uses and application rates are described in detail in Table 4.1.
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Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

Agricultural Use Sites

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078] Artichoke (globe)

0.104 to 0.222

(3.2 to 6.84 fl oz/A)

NS 0.446 0

Retreatment interval of 7 

Luna Sensation to 10 days.

(2.1 lb ai/gal) [264-

1090]

0.0660 to 0.125

(4.0 to 7.6 fl oz/A)

Ground, aerial 

or chemigation

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

Brassica Leafy Vegetables Head and Stem Subgroup:

Broccoli, Chinese broccoli (Gai Lon), Brussels sprouts, 

Cabbage, Chinese cabbage (Napa), Chinese cabbage (Bok 

choy), Chinese mustard cabbage (Gai choy), Cauliflower, 

Cavalo broccolo, Kohlrabbi. Including all cultivars and/or 

hybrids of these.

0.0660 to 0.125

(4.0 to 7.6 fl oz/A) NS 0.446 0

Retreatment interval of 7 

to 10 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Brassica (cole) Leafy Vegetables: Broccoli, Broccoli raab 

(Rapini), Brussels sprouts, Cabbage, Cauliflower, Cavalo 

broccoli, Chinese broccoli (Gai Lon), Chinese cabbage (Bok 

choy), Chinese cabbage (Napa), Chinese mustard cabbage 

(Gai choy), Collards, Kale, Mizuna, Mustard greens, Mustard 

spinach, Rape greens, and Turnip greens. Including all 

cultivars and/or hybrids of these.

0.104 to 0.222

(3.2 to 6.84 fl oz/A) NS 0.446 0

Retreatment interval of 5 

to 10 days.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

Brassica Leafy Vegetables Leafy Greens Subgroup: 

Broccoli raab (Rapini), Chinese cabbage, Collards, Kale, 

Mizuna, Mustard greens, Mustard spinach, Rape greens, and 

Turnip greens. Including all cultivars and/or hybrids of these.

0.0660 to 0.125

(4.0 to 7.6 fl oz/A) NS 0.446 0

Retreatment interval of 7 

to 14 days.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Leafy Brassica Greens (Crop Subgroup 5B): Broccoli raab 

(rapini), Chinese cabbage (bok choy), Collards, Kale, 

Mizuma, Mustard greens, Mustard spinach, Rape greens, and 

Turnip greens,

0.0783 to 0.112

(6.0 to 8.6 fl oz/A) NS 0.446 7

Retreatment interval of 7 

to 14 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Bulb Vegetables: Chive fresh leaves, Chive fresh leaves 

(Chinese), Daylily bulb, Elegans hosta, Fritillaria (bulb and 

leaves), Garlic bulb, Garlic bulb (Great headed and Serpent), 

Kurrant, Leek, Leek (Lady’s and Wild), Lily bulb, Onion 

(Beltsville bunching, Bulb, Chinese bulb, Fresh, Green, 

Macrostem, Pearl, Potato bulb, Tree tops, and Welsh), Shallot 

(bulb and fresh leaves). Including all cultivars and/or hybrids 

of these.

0.13 to 0.222

(4.0 to 6.84 fl oz/A) NS 0.446 0

Retreatment interval of 5 

to 7 days.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Bulb Vegetables: Chive fresh leaves, Chive fresh leaves 

(Chinese), Daylily bulb, Elegans hosta, Fritillaria (bulb and 

leaves), Garlic bulb, Garlic bulb (Great headed and Serpent), 

Kurrant, Leek, Leek (Lady’s and Wild), Lily bulb, Onion 

(Beltsville bunching, Bulb, Chinese bulb, Fresh, Green, 

0.104 to 0.167

(8.0 to 12.8 fl oz/A) NS 0.446 7

Retreatment interval of 10 

to 14 days.
Page 13 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

Macrostem, Pearl, Potato bulb, Tree tops, and Welsh), Shallot 

(bulb and fresh leaves).

Luna Tranquility

(1.04 lb ai/gal) 

[264-1085]

Bulb Vegetables: Dry Bulb Onion, Eschalots, Green Onion, 

Garlic, Leeks, Japanese Bunching Onion, Scallions, Shallot, 

and Spring Onion.

0.130 to 0.219

(16.0 to 27.0 fl oz/A) NS 0.446 7

Retreatment interval of 7 

to 14 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Canola subgroup: Borage, Crambe, Cuphea, Echium, Flax 

seed, Gold of pleasure, Hare’ ear mustard, Lesquerella, 

Lunaria, Meadowfoam, Milkweed, Mustard seed, Oil radish, 

Poppy seed, Rapeseed, Sesame, and Sweet rocket. Including 

cultivars, varieties, and/or hybrids of these.

0.222

(6.84 fl oz/A) NS 0.446 14 Retreatment interval of 12 to 14 days.

Ground, aerial 

or chemigation

Propulse

(1.67 lb ai/gal) 

[264-1084]

Canola Rapeseed, Indian Rapeseed, Field Mustard, 

Crambe

0.177

(13.6 fl oz/A) NS 0.446 36 Retreatment interval of 14 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078] Carrot

0.156 to 0.222

(4.8 to 6.84 fl oz/A)

NS 0.446

0

Retreatment interval of 5 

to 7 days. Tops or greens 

from this crop may be 

utilized for food or feed.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

0.0660 to 0.125

(4.0 to 7.6 fl oz/A) 7

Retreatment interval of 14 

days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Cereal Grains (except Rice): Barley, Buckwheat, Corn 

(Sweet Corn, Field Corn, Field Corn Grown for Seed, and 

Popcorn), Millet, (Pearl and Proso), Oats, Rye, Sorghum, 

Sudan Grass, Teosinte, Triticale, and Wheat.

0.222

(6.84 fl oz/A) NS 0.446 14

Retreatment interval of 14 

days. Do not allow 

livestock to graze treated 

area for 14 days and do 

harvest for food or feed 

within 14 days of 

application.

Ground, aerial 

or chemigation

Propulse

(1.67 lb ai/gal) 

[264-1084]

Barley 0.177

(13.6 fl oz/A) NS 0.446 32 Retreatment interval of 14 days.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Barley 0.112

(8.6 fl oz/A) NS 0.446 30

Retreatment interval not 

specified. Do not allow 

livestock to graze treated 

area for 14 days and do 

not harvest for food or 

feed within 14 days of 

application.

Ground or 

aerial

Propulse

(1.67 lb ai/gal) 

[264-1084]

Buckwheat, Millet (Pearl and Proso), Oats, Rye 0.177

(13.6 fl oz/A) NS 0.446 30

Ground, aerial 

or chemigation

Propulse

(1.67 lb ai/gal) 

[264-1084]

Wheat 0.177

(13.6 fl oz/A) NS 0.446 30 Retreatment interval of 14 days. 
Page 14 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

Wheat 0.112

(6.84 fl oz/A) NS 0.446 35

Retreatment interval of 14 

to 21 days. If two 

applications or 0.224 lb 

ai/A/yr are applied, do not 

allow livestock to graze 

within the treated area and 

do not harvest the treated 

crop for forage or hay. If 

one application or 0.112 

lb ai/A/yr are applied, do 

not allow livestock to 

graze within the treated 

area within 30 days after 

application, and do not 

harvest the treated crop 

for forage within 30 days 

after application or for hay 

within 45 days after 

application.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Wheat 0.112

(8.6 fl oz/A) NS 0.446 30

Retreatment interval not 

specified. Do not allow 

livestock to graze treated 

area for 14 days and do 

not harvest for food or 

feed for 14 days of 

application.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Forage, Fodder or Straw from Cereal Grains: Barley, 

Buckwheat, Corn (Sweet Corn, Field Corn, Field Corn Grown 

for Seed, and Popcorn), Millet, (Pearl and Proso), Oats, Rye, 

Sorghum, Sudan Grass, Teosinte, Triticale, and Wheat.

0.222

(6.84 fl oz/A) NS 0.446 14

Retreatment interval of 14 

days. Do not allow 

livestock to graze treated 

area for 14 days and do 

harvest for food or feed 

within 14 days of 

application.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Citrus: Australian desert lime, Australian finger-lime, Brown 

River finger lime, Calamondin, Citron, Citrus hybrids, 

Grapefruit, Japanese summer grapefruit, Kumquat, Lemon, 

Lime, Mediterranean mandarin, Mount white lime, New 

Guinea wild lime, Orange (sour and sweet), Pummelo, 

Russell River lime, Satsuma mandarin, Sweet lime, 

Tachibana orange, Tahiti lime, Tangelo, Tangerine 

(Mandarin), Tangor, Trifoliate orange, Uniq fruit, White 

sapote (Casimiroa spp.) and cultivars, varieties, and/or 

hybrids of these.

0.156 to 0.222

(4.8 to 6.84 fl oz/A) NS 0.446 7

Retreatment interval of 7 

to 21 days. Minimum 30 

day interval between soil 

applications.
Page 15 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

Citrus: Calamondin, Citrus Citron, Citrus hybrids (Citrus

spp., includes Chironja, Tangelo and Tangor), Grapefruit, 

Grapefruit, Kumquat, Lemon, Lime, Mandarin (Tangerine), 

Orange (Sweet and Sour), Pummelo, Tangelo, Satsuma 

Mandarin, White Sapote (Casimiroa spp.), and other cultivars 

and/or hybrids of these.

0.125

(7.6 fl oz/A) NS 0.446 7

Retreatment interval of 7 

to 21 days.

Fluopyram 500 SC

(4.16 lb ai/gal) 

[264-RLGI]

Citrus

0.156 to 0.221 lb ai/100 gal/A

4.8 to 6.8 fl oz/100 gal/A

NS

0.446 lb ai/A

13.7 fl oz/A

7

Retreatment interval of 7 

to 21 days. Retreatment 

interval for nematode 

control is 30 days.

FLU+TFS SC 500

(2.10 lb ai/gal) 

[264-RLGT]

0.125 lb ai/100 gal/A

7.6 fl oz/100 gal/A

0.446 lb ai/A

27.3 fl oz/A

FLU+TFS SC 25

(0.104 lb ai/gal) 

[264-RLGL]

0.125 lb ai/100 gal/A

154 fl oz/100 gal/A

0.445 lb ai/A

548 fl oz/A

13ESP715 3.3 SC

(3.34 lb ai/gal) 

[432-RLUG]

0.157 to 0.446 lb ai/100 gal/A

6.0 to 17.1 fl oz/100 gal/A

0.446 lb ai/A

17.1 fl oz/A

Ground, aerial 

or chemigation

Luna Tranquility

(1.04 lb ai/gal) 

[264-1085]

Lemon

0.219

(27.0 fl oz/A) NS 0.446 7

Retreatment interval not 

specified. The use of 

adjuvants is prohibited.

Ground, aerial 

or chemigation

Propulse

(1.67 lb ai/gal) 

[264-1084]

Corn (including Field Corn, Sweet Corn, Popcorn, and 

Field Corn grown for seed) 

0.177

(13.6 fl oz/A) NS 0.446 140

Retreatment interval of 7 

to 14 days. For field corn, 

field corn grown for seed, 

and popcorn, do not apply 

within 14 days of harvest 

for grain or fodder. For 

sweet corn, do not apply 

within 14 days of harvest 

for fodder. Sweet corn 

ears and forage may be 

harvested the same day of 

application.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Corn (Sweet Corn, Field Corn, Field Corn Grown for 

Seed, and Popcorn)

0.167

(12.8 fl oz/A) NS 0.446 See Limits

Retreatment interval of 14 

days. For field corn, field 

corn grown for seed, and 

popcorn, may be applied 

up to 21 days before 

harvest of forage, and 36 

days before the harvest of 

grain or fodder. For sweet 

corn, may be applied 

within 7 days before 
Page 16 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

harvest of ears or forage, 

and 49 days before the 

harvest of fodder. Do not 

allow livestock to graze 

treated area for 14 days 

and do not harvest for 

food or feed within 14 

days of application.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Cotton Subgroup (20C): Includes cultivars, varieties and 

other hybrids of these.

0.156 to 0.222

(4.8 to 6.84 fl oz/A) NS 0.446 30 Retreatment interval not specified.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Cotton 0.222

(17.0 fl oz/A) NS 0.446 30 Retreatment interval of 7 to 14 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Cucurbit Vegetables: Chayote (fruit), Chinese waxgourd 

(Chinese preserving melon), Citron melon, Cucumber, 

Gherkin (edible, includes Hyotan, Cucuzza, Hechima, 

Chinese okra), Momordica spp. (includes Balsam apple, 

Balsam pear, Bitter melon, Chinese cucumber), Muskmelon 

(hybrids and/or cultivars of Cucumis melo including True 

cantaloupe, Cantaloupe, Casaba, Crenshaw melon, Golden 

Pershaw melon, Honeydew melon, Honey balls, Mango 

melon, Persian melon, Pineapple melon, Santa Claus melon, 

Snake melon), Pumpkin, Squash (includes Summer Squash 

types such as: Crookneck squash, Scallop squash, Straight 

neck squash, Vegetable marrow, Zucchini, and Winter squash 

types such as Acorn squash, Butternut squash, Calabaza, 

Hubbard squash, Spaghetti squash), and Watermelon

(includes hybrids and/or varieties of Citrullus lanatus).

0.104 to 0.222

(3.2 to 6.84 fl oz/A) NS 0.446 0

Retreatment interval of 5 

to 14 days; except for soil 

applications with 

minimum 5 day interval 

between soil applications.

Ground or 

chemigation

Propulse

(1.67 lb ai/gal) 

[264-1084]

Cucurbit Vegetables: Chayote (fruit), Chinese waxgourd 

(Chinese preserving melon), Citron melon, Cucumber, 

Gherkin, Edible gourd (includes hyotan, cucuzza, hechima, 

Chinese okra), Momordica spp. (includes Balsam apple, 

Balsam pear, Bitter melon, Chinese cucumber), Muskmelon 

(includes cantaloupe), Pumpkin, Squash (summer and winter, 

includes Butternut squash, Calabaza, Hubbard squash, Acorn 

squash, Spaghetti squash), and Watermelon.

0.177

(13.6 fl oz/A) NS 0.446 7

Retreatment interval of 5 

to 10 days. Only 1 soil 

application allow; up to 

two foliar applications 

allowed.

Ground, aerial 

or chemigation

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

Cucurbit Vegetables: Chayote (fruit), Chinese waxgourd 

(Chinese preserving melon), Citron melon, Cucumber, 

Gherkin (edible, includes Hyotan, Cucuzza, Hechima, 

Chinese okra), Momordica spp. (includes Balsam apple, 

Balsam pear, Bitter melon, Chinese cucumber), Muskmelon 

(hybrids and/or cultivars of Cucumis melo including True 

0.0660 to 0.125

(4.0 to 7.6 fl oz/A) 4 0.446 0

Retreatment interval of 7 

to 14 days; except for soil 

applications with 

minimum 7 day interval 

between soil applications.
Page 17 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

cantaloupe, Cantaloupe, Casaba, Crenshaw melon, Golden 

Pershaw melon, Honeydew melon, Honey balls, Mango 

melon, Persian melon, Pineapple melon, Santa Claus melon, 

Snake melon), Pumpkin, Squash (includes Summer Squash 

types such as: Crookneck squash, Scallop squash, Straight 

neck squash, Vegetable marrow, Zucchini, and Winter squash 

types such as Acorn squash, Butternut squash, Calabaza, 

Hubbard squash, Spaghetti squash), and Watermelon

(includes hybrids and/or varieties of Citrullus lanatus).

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Cucurbit Vegetables: Chayote (fruit), Chinese waxgourd 

(Chinese preserving melon), Citron melon, Cucumber, 

Gherkin (edible, includes Hyotan, Cucuzza, Hechima, 

Chinese okra), Momordica spp. (includes Balsam apple, 

Balsam pear, Bitter melon, Chinese cucumber), Muskmelon 

(hybrids and/or cultivars of Cucumis melo including True 

cantaloupe, Cantaloupe, Casaba, Crenshaw melon, Golden 

Pershaw melon, Honeydew melon, Honey balls, Mango 

melon, Persian melon, Pineapple melon, Santa Claus melon, 

Snake melon), Pumpkin, Squash (includes Summer Squash 

types such as: Crookneck squash, Scallop squash, Straight 

neck squash, Vegetable marrow, Zucchini, and Winter squash 

types such as Acorn squash, Butternut squash, Calabaza, 

Hubbard squash, Spaghetti squash), and Watermelon

(includes hybrids and/or varieties of Citrullus lanatus).

0.0783 to 0.222

(6.0 to 17.0 fl oz/A) NS 0.446 7

Retreatment interval of 10 

to 14 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Fruiting Vegetables: African eggplant, Bush Tomato, 

Cocona, Currant tomato, Eggplant, Garden huckleberry, Goji 

berry, Martynia, Naranjilla, Okra, Pea eggplant, Pepino, 

Pepper (Capsicum spp., including Bell, Chili, Cooking, 

Pimento and Sweet), Roselle, Scarlet eggplant, Sunberry, 

Tomatillo, Tomato, Tree tomato, and cultivars, varieties, 

and/or hybrids of these.

0.117 to 0.222

(3.60 to 6.84 fl oz/A) NS 0.446 0

Retreatment interval of 7 

days.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

Fruiting Vegetables: Eggplant, Groundcherry, Okra, 

Pepinos, Pepper (Capsicum spp., including Bell, Chili, 

Cooking, Pimento and Sweet), Tomatillo, and Tomato.

0.0825 to 0.125

(5.0 to 7.6 fl oz/A) 5 0.446 3

Retreatment interval of 7 

to 14 days.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Fruiting Vegetables: African eggplant, Bush Tomato, 

Cocona, Currant tomato, Eggplant, Garden huckleberry, Goji 

berry, Martynia, Naranjilla, Pea eggplant, Pepino, Non Bell 

Pepper, Roselle, Scarlet eggplant, Sunberry, Tomatillo, 

Tomato, Tree tomato, and cultivars, varieties, and/or hybrids 

of these.

0.0783 to 0.222

(6.0 to 17.0 fl oz/A) NS 0.446 7

Retreatment interval of 7 

to 14 days.

Ground, aerial 

or chemigation

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Okra

0.167

(12.8 fl oz/A) NS 0.446 3

Retreatment interval of 14 

days.
Page 18 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

Ground, aerial 

or chemigation

Luna Tranquility

(1.04 lb ai/gal) 

[264-1085]

Tomato 0.0910

(11.2 fl oz/A NS 0.446 1

Retreatment interval of 7 

to 14 days. For 

greenhouse uses apply 

only in well-ventilated 

plastic tunnel houses or 

glass houses. Ventilate 

for at least 2 hours after 

application.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Ginseng

0.222

(6.84 fl oz/A) NS 0.446 7

Retreatment interval of 5 

to 7 days.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

0.125

(7.6 fl oz/A) NS 0.446 7

Retreatment interval of 14 

days.

Luna Tranquility

(1.04 lb ai/gal) 

[264-1085]

0.130 to 0.219

(16.0 to 27.0 fl oz/A) NS 0.446 30 Retreatment interval of 7 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Grapes and Small Vine Fruits (except fuzzy kiwifruit): 

Amur River grape, Gooseberry, Grape, Kiwifruit, Hardy, 

Maypop, Schisandra berry, and cultivars, varieties, and/or 

hybrids of these varieties.

0.104 to 0.222

(3.2 to 6.84 fl oz/A) NS 0.446 7

Retreatment interval of 12 

to 21 days.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

0.0660 to 0.125

(4.0 to 7.6 fl oz/A) 6 0.446 14 Retreatment interval of 12 to 21 days.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

0.0783 to 0.112

(6.0 to 8.6 fl oz/A) NS 0.446 14 Retreatment interval of 12 to 21 days.

Luna Tranquility

(1.04 lb ai/gal) 

[264-1085]

0.130 to 0.219

(16.0 to 27.0 fl oz/A) NS 0.446 7

Retreatment interval of 12 

to 14 days.

Ground, 

Drench or 

Chemigation

Fluopyram 500 SC

(4.16 lb ai/gal) 

[264-RLGI]

Grapes and Small Vine Fruits

0.104 to 0.221 lb ai/100 gal/A

3.2 to 6.8 fl oz/100 gal/A NS 0.446 lb ai/A13.7 fl oz/A 7

Retreatment interval of 12 

to 21 days.

FLU+TFS SC 500

(2.10 lb ai/gal) 

[264-RLGT]

0.0656 to 0.125 lb ai/100 gal/A

4.0 to 7.6 fl oz/100 gal/A 6

0.446 lb ai/A

27.3 fl oz/A 14 Retreatment interval of 12 to 21 days.

FLU+TFS SC 25

(0.104 lb ai/gal) 

[264-RLGL]

0.0821 to 0.125 lb ai/100 gal/A

101 to 154 fl oz/100 gal/A 6

0.445 lb ai/A

548 fl oz/A 14 Retreatment interval of 12 to 21 days.

13ESP715 3.3 SC

(3.34 lb ai/gal) 

[432-RLUG]

0.112 to 0.223 lb ai/100 gal/A

4.28 to 8.56 fl oz/100 gal/A NS 0.446 lb ai/A17.1 fl oz/A 7

Retreatment interval of 12 

to 21 days.

Ground, aerial Luna Privilege Herbs and Spices (except black pepper): Allspice, 0.13 to 0.222 NS 0.446 0 Retreatment interval of 7 
Page 19 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

or chemigation (4.16 lb ai/gal) 

[264-1078]

Angelica, Anise (anise seed), Anise (star), Annatto, (seed), 

Balm (lemon balm), Basil (fresh and dried), Borage, Bumet, 

Camomile, Caper buds, Caraway, Caraway (black),

Cardamom, Cassia (bark and buds), Catnip, Celery seed, 

Chervil (dried), Chinese chive, Chive, Cinnamon, Clary, 

Clove (buds), Coriander (cilantro or Chinese parsley leaves), 

Corinader seed (cilantro seed), Costmary, Cilantro (leaf and 

seed), Cumin, Curry leaf, Dill (seed), Dillweed, Fennel 

[common and Florence (seed)], Fenugreek, Grains of 

paradise, Horehound, Hyssop, Juniper berry, Lavender, 

Lemongrass, Lovage (leaf and seed), Mace, Marigold, 

Mustard (seed), Nasturtium, Nutmeg, Parsley (dried), 

Pennyroyal, Poppy (seed), Rosemary, Rue, Saffron, Sage, 

Savory (summer and winter), Sweet bay (bay leaf), Tansy, 

Tarragon, Thyme, Vanilla, Wintergreen, Woodruff, and 

Wormwood.

(4.0 to 6.84 fl oz/A) to 10 days.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

0.0660 to 0.125

(4.0 to 7.6 fl oz/A) NS 0.446 7

Retreatment interval of 7 

to 10 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Hops

0.104 to 0.222

(3.2 to 6.84 fl oz/A) NS 0.446 7

Retreatment interval of 14 

days.

NS

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

0.0495 to 0.125

(3.0 to 7.6 fl oz/A) 4 0.446 14

Retreatment interval of 14 

days. Do not replant areas 

within 30 days of the last 

application. Do not graze 

cover crops within the 

treated area. Do not 

harvest cover crops within 

the area treated for silage 

and hay. Do not apply 

using aerial application. 

Do not apply using low 

volume applicators. Do 

not apply through any 

type of irrigation system. 

Do not apply on hops in 

California.

Ground, aerial 

or chemigation

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

0.104 to 0.222

(8.0 to 17.0 fl oz/A) NS 0.446 14 Retreatment interval of 14 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Leafy Vegetables (except Watercress): Amaranth (Leafy 

amaranth, Chinese spinach, Tampala), Arugula (Roquette), 

Cardoon, Celery, Celtuce, Chervil, Chinese celery, 

Chrysanthemum, (Edible-leaved and Garland), Cilantro, Corn 

salad, Cress (Garden), Cress (Upland, Yellow rocket, Winter 

0.104 to 0.222

(3.2 to 6.84 fl oz/A) NS 0.446

0

3

Retreatment interval of 7 

to 10 days. For lettuce 

greenhouse uses the PHI

is 3 days.
Page 20 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

cress), Dandelion, Dock (Sorrel), Endive (Escarole), Florence 

fennel (Sweet anise, Sweet fennel, Finocchio), Lettuce (Head 

and Leaf), Orach, Parsley, Purslane (Garden and Winter), 

Radicchio (Red Chicory), Rhubarb, Spinach [including New 

Zealand and vine (Malabar spinach, Indian spinach)], and 

Swiss chard.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

Leafy Greens Vegetables (except Watercress): Amaranth 

(Leafy amaranth, Chinese spinach, Tampala), Arugula 

(Roquette), Chervil, Chrysanthemum, (Edible-leaved and 

Garland), Cilantro, Corn salad, Cress (Garden), Cress 

(Upland, Yellow rocket, Winter cress), Dandelion, Dock

(Sorrel), Endive (Escarole), Lettuce (Head and Leaf), Orach, 

Parsley, Purslane (Garden and Winter), Radicchio (Red 

Chicory), Rhubarb, and Spinach [including New Zealand and 

vine (Malabar spinach, Indian spinach)].

0.125

(7.6 fl oz/A) NS 0.446 0

Retreatment interval of 14 

days.

Ground, aerial 

or chemigation

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

Leafy Petiole Vegetables: Cardon, Celery, Chinese celery, 

Florence fennel (including Sweet anise, Sweet fennel, 

Finocchio), Rhubarb, Swiss chard.

0.0660 to 0.0957

(4.0 to 5.8 fl oz/A) NS 0.446 7

Retreatment interval of 14 

days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Legume Vegetables (including Soybean): Edible Podded 

Legume Vegetables: Bean (Phaseolus spp.) (includes Runner 

Bean, Snap Bean, Wax Bean); Bean (Vigna spp.) (includes 

Asparagus Bean, Chinese Longbean, Moth Bean, Yardlong 

Bean); Jackbean; Pea (Pisum spp.) (includes Dwarf Pea, 

Edible-pod Pea, Snow Pea, Sugar Snap Pea); Pigeon Pea; 

Soybean (immature seed); Sword Bean. Succulent Shelled 

Pea and Bean: Bean (Phaseolus spp.) (includes Lima Bean 

(green); Broad Bean (succulent); Bean (Vigna spp.) ( except 

Cowpea, Southpea); Pea (Pisum spp.) (includes English Pea, 

Garden Pea, Green Pea); Pigeon Pea. Dried Shelled Pea and 

Bean. Dried Cultivars of Bean (Lupinus spp.) (includes Grain 

Lupin, Sweet Lupin, White Lupin, White Sweet Lupin); 

(Phaseolus spp.) (includes Field Bean, Kidney Bean, Lime 

Bean Dry), Navy Bean, Pinto Bean; Tepary Bean; Bean 

(Vigna spp.) (includes Adzuki Bean, Blackeyed Pea, Catjang, 

Moth Bean, Mung Bean, Rice Bean, Southern Pea, Urd Bean; 

except Cowpea & Crowder Pea); Broad Bean (Dry); 

Chickpea; Guar; Lablab Bean; and Lentil.

0.156 to 0.222

(4.8 to 6.84 fl oz/A) NS 0.446 0

Do not apply to cultivars 

that are to be grazed, cut 

for forage or hay, or used 

as livestock feed.

Ground, aerial 

or chemigation

Propulse

(1.67 lb ai/gal) 

[264-1084]

Dried Beans: Bean (Lupinus spp., includes Grain lupin, 

Sweet lupin, White lupin, and White sweet lupin), Bean 

(Phaseolus spp., includes Field bean, Kidney bean, Lima 

bean, Navy bean, Pinto bean, and Tepary bean), Bean (Vigna 

spp., includes Adzuki bean, Blackeyed pea, Catjang, Crowder 

pea, Moth bean, Mung bean, Rice bean, Southern pea, and 

0.134 to 0.177

(10.3 to 13.6 fl oz/A) NS 0.446 14

Retreatment interval of 7 

to 14 days. Allow 7 days 

from the last application

until cutting or swathing 

the crop for harvest. Do 

not feed hay or threshings 
Page 21 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

Urd bean), Broad Bean (dry), Chickpea, Guar, Lablab Bean,

and Lentil.

or allow livestock to graze 

in treated areas.

Ground, aerial 

or chemigation

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Beans (Fresh and Dry, except Succulent Shelled) 0.104 to 0.167

(8.0 to 12.8 fl oz/A) NS 0.446 14

Retreatment interval of 10 

to 14 days. Do not allow 

livestock to graze treated 

area for 14 days and do 

not harvest for food or 

feed within 14 days of 

application. 

Ground, aerial 

or chemigation

Propulse

(1.67 lb ai/gal) 

[264-1084]

Soybean

0.133

(10.2 fl oz/A) NS 0.446 21

Retreatment interval of 10 

to 14 days. Do not allow 

livestock to graze soybean 

and do not harvest 

soybean hay for food or 

feed.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

0.125

(7.6 fl oz/A) NS 0.446 21

Retreatment interval of 14 

days. Do not allow 

livestock to graze soybean 

and do not harvest 

soybean hay for food or 

feed.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

0.112

(8.6 fl oz/A) NS 0.446 21

Retreatment interval of 10 

to 14 days. Do not allow 

livestock to graze soybean 

and do not harvest 

soybean hay for food or 

feed. 

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Pome Fruits: Apple, Azarole, Crabapple, Loquat, Mayhaw, 

Medlar, Pear, Pear (Asian), Quince, Quince (Chinese and 

Japanese), Tejocote, and cultivars, varieties, and/or hybrids of 

these.

0.078 to 0.222

(2.4 to 6.84 fl oz/A) NS 0.446 7

Retreatment interval of 7 

to 14 days.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

0.0652 to 0.130

(5.0 to 10.0 fl oz/A) NS 0.446 75 Retreatment interval of 7 to 14 days.

Luna Sensation

(2.1 lb ai/gal) [264-

1090] Pome Fruits: Apple, Crabapple, Loquat, Mayhaw, Pear, 

Oriental Pear, Quince.

0.0660 to 0.0957

(4.0 to 5.8 fl oz/A) 4 0.446 14 Retreatment interval of 7 to 14 days.

Luna Tranquility

(1.04 lb ai/gal) 

[264-1085]

0.0975 to 0.130

(12.0 to 16.0 fl oz/A) NS 0.446 72 Retreatment interval of 7 to 10 days.

Ground, 

Drench or 

Chemigation

Fluopyram 500 SC

(4.16 lb ai/gal) 

[264-RLGI] Pome Fruits

0.0780 to 0.221 lb ai/100 gal/A

2.4 to 6.8 fl oz/100 gal/A NS 0.446 lb ai/A13.7 fl oz/A 7

Retreatment interval of 7 

to 14 days.

FLU+TFS SC 500 0.0656 to 0.0952 lb ai/100 gal/A 4 0.345 lb ai/A 14 Retreatment interval of 7 
Page 22 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

(2.10 lb ai/gal) 

[264-RLGT]

4.0 to 5.8 fl oz/100 gal/A 21.0 fl oz/A to 14 days.

FLU+TFS SC 25

(0.104 lb ai/gal) 

[264-RLGL]

0.0650 to 0.0951 lb ai/100 gal/A

80 to117 fl oz/100 gal/A 4

0.345 lb ai/A

425 fl oz/A 14 Retreatment interval of 7 to 14 days.

13ESP715 3.3 SC

(3.34 lb ai/gal) 

[432-RLUG]

0.0783 to 0.223 lb ai/100 gal/A

3.0 to 8.56 fl oz/100 gal/A NS 0.446 lb ai/A17.1 fl oz/A 7

Retreatment interval of 7 

to 14 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Potato and Other Root, Tuberous, and Corm Vegetables: 

Arracacha, Arrowroot, Artichoke (Chinese and Jerusalem), 

Beet (Garden), Burdock (Edible), Canna (Edible, Queensland 

arrowroot), Cassava (Bitter & Sweet), Celeriac (Celery root), 

Chayote (root), Chervil (Turnip-rooted), Chickory, Chufa, 

Dasheen (Taro), Ginger, Horseradish, Leren, Parsley (Turniprooted), Parsnip, Potato, Radish, Oriental radish (Daikon), 

Rutabaga, Salsify (Black), Salsify (Oyster plant), Salsify 

(Spanish), Skirret, Sweet potato, Tanier (Cocoyam), 

Turmeric, Turnip, Yam bean (Jicama, Manoic pea) and Yam 

(True).

0.13 to 0.222

(4.0 to 6.84 fl oz/A) NS 0.446 7

Retreatment interval of 5 

to 7 days. The grazing of 

livestock in treated areas 

within 7 days of 

application is prohibited.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

0.0825 to 0.0957

(5.0 to 5.8 fl oz/A) 4 0.446 7

Retreatment interval of 14 

days. 

Luna Tranquility

(1.04 lb ai/gal) 

[264-1085]

Potato and Other Root, Tuberous, and Corm Vegetables: 

Arracacha, Arrowroot, Artichoke (Chinese and Jerusalem), 

Canna (Edible), Cassava (Bitter & Sweet), Chayote (root), 

Chufa, Dasheen (Taro), Ginger, Leren, Potato, Sweet Potato, 

Tanier (Cocoyam), Turmeric, Yam bean, and Yam (True).

0.0650 to 0.0910

(8.0 to 11.2 fl oz/A) NS 0.446 7

Retreatment interval of 7 

to 14 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Small Berries (caneberries and bushberries): 

Blackberry Rubus spp. (including Andean blackberry, Artic 

blackberry, Bingleberry, Black blackberry, Boysenberry, 

Brombeere, California blackberry, Chesterberry, Cherokee 

blackberry, Cheyenne blackberry, Common blackberry, 

Coryberry, Darrowberry, Dewberry, Dirksen thornless berry, 

Evergreen blackberry, Himalayaberry, Hullberry, 

Lavacaberry, Loganberry, Lowberry, Lucretiaberry, 

Mammoth blackberry, Marionberry, Mora, Mures deronce, 

Nectarberry, Northern dewberry, Olallieberry, Oregon 

evergreen berry, Phenomenalberry, Rangeberry, Ravenberry, 

Rossberry, Shawnee blackberry, Southern dewberry, 

Tayberry, Youngberry, Zarzamora, and cultivars, varieties, 

and/or hybrids of these.

Raspberry Rubus spp. (Rubus occidentalis, Rubus strigosus, 

Rubus idaeus) (including Bababery, Black raspberry, 

Blackcap, Framboise, Frambueso, Himbeere, Keriberry, 

Mayberry, Purple raspberry, Red raspberry, Thimblberry, 

Tulameen, Wild raspberries, Yellow raspberry) and cultivars, 

0.156 to 0.222

(4.8 to 6.84 fl oz/A) NS 0.446 0

Retreatment interval of 7 

to 10 days.
Page 23 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

varieties, and/or hybrids of these.

Bushberry (including Berry (Aronia), Blueberry (Highbush 

and Lowbush), Currant (Buffalo), Guava (Chilean), Currant 

(Black and Red), Barberry (European), Elderberry, 

Gooseberry, Cranberry (Highbush), Honeysuckle, 

Huckleberry, Jostaberry, Juneberry, Currant (Native), Salal, 

Sea buckthorn, and cultivars, varieties, and/or hybrids of 

these.

Ground, aerial 

or chemigation

Luna Tranquility

(1.04 lb ai/gal) 

[264-1085]

Small Berries (caneberries and bushberries): 

Blackberry Rubus spp. (including Andean blackberry, Artic 

blackberry, Bingleberry, Black Satin berry, Boysenberry, 

Brombeere, California blackberry, Chesterberry, Cherokee 

blackberry, Cheyenne blackberry, Common blackberry, 

Coryberry, Darrowberry, Dewberry, Dirksen thornless berry, 

Evergreen blackberry, Himalayaberry, Hullberry, 

Lavacaberry, Loganberry, Lowberry, Lucretiaberry, 

Mammoth blackberry, Marionberry, Mora, Mures deronce, 

Nectarberry, Northern dewberry, Olallieberry, Oregon 

evergreen berry, Phenomenalberry, Rangeberry, Ravenberry, 

Rossberry, Shawnee blackberry, Southern dewberry, 

Tayberry, Youngberry, Zarzamora, and cultivars, varieties, 

and/or hybrids of these.

Raspberry Rubus spp. (Rubus occidentalis, Rubus strigosus, 

Rubus idaeus) (including Bababery, Black raspberry, 

Blackcap, Framboise, Frambueso, Himbeere, Keriberry, 

Mayberry, Purple raspberry, Red raspberry, Thimblberry, 

Tulameen, Wild raspberries, Yellow raspberry) and cultivars, 

varieties, and/or hybrids of these.

Bushberry (including Berry (Aronia), Blueberry (Highbush 

and Lowbush), Currant (Buffalo), Guava (Chilean), Currant 

(Black and Red), Barberry (European), Elderberry, 

Gooseberry, Cranberry (Highbush), Honeysuckle, 

Huckleberry, Jostaberry, Juneberry, Currant (Native), Salal, 

Sea buckthorn, and cultivars, varieties, and/or hybrids of 

these.

0.111 to 0.219

(13.6 to 27.0 fl oz/A) NS 0.446 0

Retreatment interval of 7 

to 14 days.

Ground or 

chemigation

Propulse

(1.67 lb ai/gal) 

[264-1084]

Bushberry subgroup: Aronia berry, Blueberry (Highbush 

and Lowbush), Chilean Guava, Currant (Black, Buffalo, and 

Red), Highbush Cranberry, Elderberry, European Barberry, 

Gooseberry, Edible Honeysuckle, Huckleberry, Jostaberry, 

Juneberry (Saskatoon berry), Ligonberry, Native Currant, 

Salal, Sea buckthorn, and cultivars, varieties, and/or hybrids 

of these.

0.177

(13.6 fl oz/A) NS 0.446 7

Retreatment interval of 7 

to 10 days.

Ground, aerial Luna Privilege Stone Fruit: Apricot, Apricot (Japanese), Capulin, Cherry 0.13 to 0.222 NS 0.446 0 Retreatment interval of 5 
Page 24 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

or chemigation (4.16 lb ai/gal) 

[264-1078]

(Black, Nanking, Canada, Sweet, Tart), Jujube (Chinese), 

Nectarine, Peach, Plum, Plum (American, Beach, Canada, 

Cherry, Chickasaw, Damson, Japanese, Klamath), Prune, 

Plumcot, Sloe, and cultivars, varieties, and/or hybrids of 

these.

(4.0 to 6.84 fl oz/A) to 7 days.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

Stone Fruit: Apricot, Cherry (Sweet and Tart), Nectarine, 

Peach, Plum (including Chickasaw, Damson, Japanese), 

Plumcot, and Prune (Fresh and Dried).

0.0825 to 0.125

(5.0 to 7.6 fl oz/A) 4 0.446 1

Retreatment interval of 7 

to 14 days.

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Stone Fruit: Apricot, Cherry (Sweet, Tart), Nectarine, Peach, 

Plum (all varieties including Chickasaw, Damson, Japanese, 

and Stanley), Plumcot, and Prune (fresh and dried).

0.0783 to 0.130

(6.0 to 10.0 fl oz/A NS 0.446 0

Retreatment interval of 5 

to 7 days.

Luna Tranquility

(1.04 lb ai/gal) 

[264-1085]

Stone Fruit: Apricot, Nectarine, Peach, Plum (all varieties 

including Chickasaw, Damson, Japanese, and Stanley), 

Plumcot, and Prune (fresh and dried).

0.0975 to 0.219

(12.0 to 27.0 fl oz/A NS 0.446 2

Retreatment interval of 7 

to 14 days. Do not make 

more than two 

applications of a group 9 

fungicide within 30 days 

of harvest.

Ground, 

Drench or 

Chemigation

Fluopyram 500 SC

(4.16 lb ai/gal) 

[264-RLGI]

Stone Fruits

0.130 to 0.221 lb ai/100 gal/A

4.0 to 6.8 fl oz/100 gal/A NS 0.446 lb ai/A13.7 fl oz/A 0

Retreatment interval of 5 

to 7 days.

FLU+TFS SC 500

(2.10 lb ai/gal) 

[264-RLGT]

0.0820 to 0.125 lb ai/100 gal/A

5.0 to 7.6 fl oz/100 gal/A 4

0.251 lb ai/A

15.3 fl oz/A 1

Retreatment interval of 7 

to 14 days.

FLU+TFS SC 25

(0.104 lb ai/gal) 

[264-RLGL]

0.0821 to 0.125 lb ai/100 gal/A

101 to 154 fl oz/100 gal/A 4

0.251 lb ai/A

309 fl oz/A 1

Retreatment interval of 7 

to 14 days.

13ESP715 3.3 SC

(3.34 lb ai/gal) 

[432-RLUG]

0.157 to 0.223 lb ai/100 gal/A

6.0 to 8.56 fl oz/100 gal/A NS 0.446 lb ai/A17.1 fl oz/ 0

Retreatment interval of 5 

to 7 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Strawberry and Other Low-Growing Berries (except 

Cranberries): Bearberry, Bilberry, Blueberry (Low-bush), 

Cloudberry, Ligonberry, Muntries, Partridgeberry, and 

Strawberry.

0.104 to 0.222

(3.2 to 6.84 fl oz/A) NS 0.446 0

Retreatment interval of 7 

days.

Ground or 

chemigation

Propulse

(1.67 lb ai/gal) 

[264-1084]

Low Growing Berry subgroup, except Strawberry and 

Cranberries: Bearberry, Bilberry, Cloudberry, Muntries, 

Partridgeberry, and cultivars, varieties, and/or hybrids of 

these.

0.134

(10.3 fl oz/A) NS 0.446 45 Retreatment interval of 7 to 10 days.

Ground, aerial 

or chemigation

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

Strawberry and Other Low-Growing Berries (except 

Cranberries): Bearberry, Bilberry, Blueberry (Low-bush), 

Cloudberry, Ligonberry, Muntries, Partridgeberry, and 

Strawberry.

0.0660 to 0.125

(4.0 to 7.6 fl oz/A) NS 0.446 0

Retreatment interval of 7 

to 14 days.

Luna Tranquility Strawberry and Other Low-Growing Berries (except 0.130 to 0.219 NS 0.446 1 Retreatment interval of 7 
Page 25 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

(1.04 lb ai/gal) 

[264-1085]

Cranberries): Bearberry, Bilberry, Blueberry (Low-bush), 

Cloudberry, Ligonberry, Muntries, Partridgeberry, and 

Strawberry.

(16.0 to 27.0 fl oz/A) to 14 days.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Sugar beet

0.222

(6.84 fl oz/A) NS 0.446 7

Retreatment interval of 5 

to 7 days.

Propulse

(1.67 lb ai/gal) 

[264-1084]

0.177

(13.6 fl oz/A) NS 0.446 7

Retreatment interval of 14 

days.

Luna Sensation

(2.1 lb ai/gal) [264-

1090]

0.0924 to 0.125

(5.6 to 7.6 fl oz/A) NS 0.446 21

Retreatment interval of 10 

to 14 days. Tops or 

greens from this crop may 

be utilized for food or 

feed.

Ground, aerial 

or chemigation

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Sunflower Subgroup: Calendula, Castor oil plant, Chinese 

tallowtree, Euphorbia, Evening primrose, Jojoa, Niger seed, 

Rose hib, Safflower, Stokes aster, Sunflower, Tallowwood, 

Tea oil plant, Veronia, and cultivars, varieties and/or hybrids 

of these.

0.222

(6.84 fl oz/A) NS 0.446 14 Retreatment interval of 14 days.

Ground, aerial 

or chemigation

Luna Experience

(1.67 lb ai/gal) 

[264-1091]

Sunflower 0.117 to 0.167

(9.0 to 12.8 fl oz/A NS 0.446 50

Retreatment interval of 14 

Ground, days.

Drench or 

Chemigation

Fluopyram 500 SC

(4.16 lb ai/gal) 

[264-RLGI] Sunflower

0.221 lb ai/100 gal/A

6.8 fl oz/100 gal/A NS 0.446 lb ai/A13.7 fl oz/A 14

13ESP715 3.3 SC

(3.34 lb ai/gal) 

[432-RLUG]

0.223 lb ai/100 gal/A

8.56 fl oz/100 gal/A NS 0.446 lb ai/A17.1 fl oz/ 14

Ground or 

Chemigation

FLU+TFS SC 500

(2.10 lb ai/gal) 

[264-RLGT] Tree Nuts

0.0820 to 0.125 lb ai/100 gal/A

5.0 to 7.6 fl oz/100 gal/A NS 0.251 lb ai/A15.3 fl oz/A 60

Retreatment interval of 7 

FLU+TFS SC 25 to 21 days.

(0.104 lb ai/gal) 

[264-RLGL]

0.0821 to 0.125 lb ai/100 gal/A

101 to 154 fl oz/100 gal/A NS 0.251 lb ai/A309 fl oz/A 60

Seed Treatment

Seed treatment 

with 

commercial 

slurry mixture 

equipment 

only.

Luna Privilege

(4.16 lb ai/gal) 

[264-1078]

Peanut

0.049725 to 0.124475

lb ai/100 lb seed

(1.53 to 3.83 fl oz

per 100 lb of

peanut seeds)

1 0.446 (from all uses) NA

Do not use treated seed 

for food, feed, or oil 

purposes.

Non Agricultural Use Sites
Page 26 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

Ground or 

Chemigation

Fluopyram 500 SC

(4.16 lb ai/gal) 

[264-RLGI]

Turf Grass: Golf Courses, Sod Farms, Sports Fields, 

Industrial, Municipal, Commercial, and other Turf Grass 

areas.

0.0013 to 0.0101 lb ai/1000 ft2

(0.04 to 0.31 fl oz/1000 ft2)

(0.0566 to 0.439 lb ai/A)

NS

0.3145 fl oz/1000 ft2

13.7 fl oz/A

0.446 lb ai/A

NA Retreatment interval of 7 

to 28 days.

FLU+TFS SC 500

(2.10 lb ai/gal) 

[264-RLGT]

0.000820 to 0.00984 lb ai/1000 ft2

(0.05 to 0.6 fl oz/1000 ft2)

(0.0557 to 0.429 lb ai/A)

0.6267 fl oz/1000 ft2

27.3 fl oz/A

0.446 lb ai/A

FLU+TFS SC 25

(0.104 lb ai/gal) 

[264-RLGL]

0.00121 to 0.0102 lb ai/1000 ft2

(1.5 to 12.6 fl oz/1000 ft2)

(0.0531 to 0.446 lb ai/A)

12.6 fl oz/1000 ft2

549 fl oz/A

0.446 lb ai/A

FLU+TFS SC 32.5

(0.104 lb ai/gal) 

[264-RLGA]

0.00121 to 0.0102 lb ai/1000 ft2

(1.5 to 12.6 fl oz/1000 ft2)

(0.0531 to 0.446 lb ai/A)

12.6 fl oz/1000 ft2

549 fl oz/A

0.446 lb ai/A

13ESP715 3.3 SC

(3.34 lb ai/gal) 

[432-RLUG]

0.0013 to 0.0102 lb ai/1000 ft2

(0.05 to 0.39 fl oz/1000 ft2)

(0.0566 to 0.444 lb ai/A)

0.393 fl oz/1000 ft2

17.1 fl oz/A

0.446 lb ai/A

Ground

Fluopyram 500 SC

(4.16 lb ai/gal) 

[264-RLGI]

Residential Turf Grass

0.0013 to 0.00912 lb ai/1000 ft2

(0.04 to 0.28 fl oz/1000 ft2)

(0.0566 to 0.396 lb ai/A)

NS

0.2847 fl oz/1000 ft2

12.4 fl oz/A

0.403 lb ai/A

NA Retreatment interval of 7 

to 28 days.

FLU+TFS SC 500

(2.10 lb ai/gal) 

[264-RLGT]

0.000820 to 0.00919 lb ai/1000 ft2

(0.05 to 0.56 fl oz/1000 ft2)

(0.0557 to 0.400 lb ai/A)

0.5647 fl oz/1000 ft2

24.6 fl oz/A

0.404 lb ai/A

FLU+TFS SC 25

(0.104 lb ai/gal) 

[264-RLGL]

0.00121 to 0.00926 lb ai/1000 ft2

(1.5 to 11.4 fl oz/1000 ft2)

(0.0531 to 0.404 lb ai/A)

11.4 fl oz/1000 ft2

497 fl oz/A

2

0.404 lb ai/A

FLU+TFS SC 32.5

(0.104 lb ai/gal) 

[264-RLGA]

0.00121 to 0.00926 lb ai/1000 ft2

(1.5 to 11.4 fl oz/1000 ft2)

(0.0531 to 0.404 lb ai/A)

11.4 fl oz/1000 ft2

497 fl oz/A

0.404 lb ai/A

13ESP715 3.3 SC

(3.34 lb ai/gal) 

[432-RLUG]

0.0013 to 0.009285 lb ai/1000 ft2

(0.05 to 0.3558 fl oz/1000 ft2)

(0.0566 to 0.404 lb ai/A)

0.3558 fl oz/1000 ft2

15.5 fl oz/A

0.404 lb ai/A

Ground, 

Drench or 

Chemigation

Fluopyram 500 SC

(4.16 lb ai/gal) 

[264-RLGI]

Ornamentals: in Residential and Commercial Landscapes, 

Interiorscapes, Field Grown and Container Ornamentals, in 

Nurseries, and Greenhouses, Lathhouses, Shadehouses, 

Containers and Other Enclosed Structures.

0.221 lb ai/100 gal/A

6.8 fl oz/100 gal/A

NS

13.7 fl oz/A

0.446 lb ai/A

NA

Retreatment interval of 7 

to 21 days.

FLU+TFS SC 500

(2.10 lb ai/gal) 

[264-RLGT]

0.0164 to 0.131 lb ai/100 gal/A

1.0 to 8.0 fl oz/100 gal/A

27.3 fl oz/A

0.446 lb ai/A

Retreatment interval of 7 

to 28 days.

FLU+TFS SC 25

(0.104 lb ai/gal) 

[264-RLGL]

0.0163 to 0.130 lb ai/100 gal/A

20 to 160 fl oz/100 gal/A

0.445 lb ai/A

548 fl oz/A

Retreatment interval of 7 

to 28 days.

13ESP715 3.3 SC

(3.34 lb ai/gal) 

[432-RLUG]

0.223 lb ai/100 gal/A

8.56 fl oz/100 gal/A

0.446 lb ai/A

17.1 fl oz/A

Retreatment interval of 7 

to 21 days.
Page 27 of 59

Table 4.1. Summary of Proposed Directions for Use of Fluopyram.

Application 

Timing, Type, 

and Equip.

Formulation

[EPA Reg. No.] Crops Application Rate (lb ai/A)

Max. 

No. 

Applic

. per 

Season

Max. Seasonal 

Applic. Rate

(lb ai/A)

PHI

(days)

Use Directions and 

Limitations

Ground or 

Chemigation

Fluopyram 500 SC

(4.16 lb ai/gal) 

[264-RLGI]

Christmas Trees

0.221 lb ai/100 gal/A

6.8 fl oz/100 gal/A

NS

13.7 fl oz/A

0.446 lb ai/A

NA Retreatment interval of 7 

to 21 days.

FLU+TFS SC 500

(2.10 lb ai/gal) 

[264-RLGT]

0.220 lb ai/100 gal/A

13.4 fl oz/100 gal/A

27.1 fl oz/A

0.445 lb ai/A

FLU+TFS SC 25

(0.104 lb ai/gal) 

[264-RLGL]

0.220 lb ai/100 gal/A

271 fl oz/100 gal/A NS

13ESP715 3.3 SC

(3.34 lb ai/gal) 

[432-RLUG]

0.223 lb ai/100 gal/A

8.56 fl oz/100 gal/A

0.446 lb ai/A

17.1 fl oz/A
Page 28 of 59

5.0 Residential Exposure and Risk Estimates

Based on the proposed product labels, several products are intended for use by homeowners, or 

by occupational handlers in residential settings. Therefore, non-occupational/residential risk 

assessments have been completed.

5.1 Residential Handler Exposure/Risk Estimates

HED uses the term “handlers” to describe those individuals who are involved in the pesticide 

application process. HED believes that there are distinct tasks related to applications and that 

exposures can vary depending on the specifics of each task. Residential handlers are addressed 

somewhat differently by HED as homeowners are assumed to complete all elements of an 

application without use of any protective equipment.

The quantitative exposure/risk assessment developed for residential handlers is based on the 

following residential handler scenarios: 

1. Mixing/Loading/Applying liquids for manually pressurized handwand for gardens, 

ornamentals, fruit trees, and turf;

2. Mixing/Loading/Applying liquids for hose-end sprayers for gardens, ornamentals, fruit 

trees, and turf;

3. Mixing/Loading/Applying liquids for backpack for gardens, ornamentals, fruit trees, and 

turf; and

4. Mixing/Loading/Applying liquids for sprinkler cans for gardens, ornamentals, fruit trees, 

and turf.

Residential Handler Exposure Data and Assumptions

Short-term dermal and inhalation exposures were assessed for residential handlers. A series of 

assumptions and exposure factors served as the basis for completing the residential handler risk 

assessments. Each assumption and factor is detailed below.

Application Rate:

For flower gardens, ornamentals, and fruit trees, the proposed maximum single application rate is 

0.223 lb ai/A. Applications to residential turf have a proposed maximum single application rate 

of 0.446 lb ai/A for occupational handlers and 0.404 lb ai/A for residential handlers. 

Unit Exposures and Area Treated or Amount Handled:

Unit exposure values and estimates for area treated or amount handled were taken from HED’s 

2012 Residential SOPs2. 

 

2 Available: http://www.epa.gov/pesticides/science/residential-exposure-sop.html
Page 29 of 59

Exposure Duration:

Residential handler exposure is expected to be short-term in duration. Intermediate-term 

exposures are not likely because of the intermittent nature of applications by homeowners.

Residential Handler Exposure and Risk Estimate Equations

The algorithms used to estimate exposure and dose for residential handlers can be found in 

Appendix A and/or the 2012 Residential SOPs3.

Summary of Residential Handler Non-Cancer Exposure and Risk Estimates

Dermal and inhalation exposures were not combined, since different endpoints and PODs are 

used for both routes of exposure. Table 5.1 summarizes the residential handler exposures and 

risk estimates for fluopyram. All residential handler risk estimates are not of concern to HED 

(all MOEs ≥100), with MOEs ranging from 8,900 to 190,000 for dermal exposures and 260,000 

for inhalation exposures.

Table 5.1. Residential Handler Short-term Exposure and Risk Estimates for Fluopyram.

Use Site

Equipment/

Application Method

Application 

Rate1

Area

Treated

or 

Amount 

Handled

Daily2

Exposure 

Route

Unit 

Exposure 

(mg/lb ai)

Daily Dose3

(mg/kg/day) MOE4

Gardens / 

Trees

Manually-Pressurized 

Handwand

0.00223 lb 

ai/gal 5 gal

Dermal 63 0.0088 34,000

Inhalation 0.018 0.0000025 5,800,000

Gardens / 

Trees

Manually-Pressurized 

Handwand

0.000005119 

lb ai/ft2 1200 ft2 Dermal 63 0.0048 62,000

Inhalation 0.018 0.0000014 10,000,000

Gardens / 

Trees Hose-End Sprayer 0.00223 lb ai/gal 11 gal

Dermal 58 0.018 17,000

Inhalation 0.0014 0.00000043 34,000,000

Gardens / 

Trees Hose-End Sprayer 0.000005119 lb ai/ft2 1200 ft2 Dermal 58 0.0045 67,000

Inhalation 0.0014 0.00000011 130,000,000

Gardens / 

Trees Backpack 0.00223 lb ai/gal 5 gal

Dermal 130 0.018 17,000

Inhalation 0.14 0.000020 740,000

Gardens / 

Trees Backpack 0.000005119 lb ai/ft2 1200 ft2 Dermal 130 0.010 30,000

Inhalation 0.14 0.000011 1,300,000

Gardens / 

Trees Sprinkler Can 0.00223 lb ai/gal 5 gal

Dermal 58 0.0081 37,000

Inhalation 0.0014 0.00000020 74,000,000

Gardens / 

Trees Sprinkler Can 0.000005119 lb ai/ft2 1200 ft2 Dermal 58 0.0045 67,000

Inhalation 0.0014 0.00000011 130,000,000

Lawns / 

Turf

Manually-Pressurized 

Handwand

0.00404 lb 

ai/gal 5 gal

Dermal 63 0.016 19,000

Inhalation 0.018 0.0000045 3,200,000

Lawns / 

Turf Hose-End Sprayer 0.404 lb ai/A 0.5 A

Dermal 13.4 0.034 8,900

Inhalation 0.022 0.000056 260,000

 

3 Available: http://www.epa.gov/pesticides/science/residential-exposure-sop.html
Page 30 of 59

Table 5.1. Residential Handler Short-term Exposure and Risk Estimates for Fluopyram.

Use Site

Equipment/

Application Method

Application 

Rate1

Area

Treated

or 

Amount 

Handled

Daily2

Exposure 

Route

Unit 

Exposure 

(mg/lb ai)

Daily Dose3

(mg/kg/day) MOE4

Lawns / 

Turf Backpack 0.00404 lb ai/gal 5 gal

Dermal 130 0.033 9,100

Inhalation 0.14 0.000035 410,000

Lawns / 

Turf Sprinkler Can 0.000009285 lb ai / ft2 1000 ft2 Dermal 13.4 0.0016 190,000

Inhalation 0.022 0.0000026 5,700,000

1 Maximum Single Application Rate.

2 Units Treated taken from Science Advisory Council for Exposure, Standard Operating Procedure 9.1, Standard Values for Daily Acres Treated 

in Agriculture, Rev. 25 SEP 2001.

3 Daily Dose = Unit Exposure x Application Rate x Units Treated  Body Weight (80 kg).

4 Margin Of Exposure (MOE) = NOAEL (mg/kg/day)  Daily Dose (mg/kg/day); where the NOAEL = 300 mg/kg/day for dermal exposure & 

14.5 mg/kg/day for inhalation exposure.

5.2 Residential Post-application Exposure/Risk Estimates for Proposed Uses

There is the potential for post-application exposure to fluopyram for individuals exposed as a 

result of being in an environment that has been previously treated with fluopyram. 

The quantitative exposure/risk assessment for residential post-application exposures includes the 

following scenarios: 

 Adults and children (1 to <2 years old) dermal exposure to treated turf during high 

contact lawn activities,

 Children (1 to <2 years old) incidental oral exposure as a result of contacting treated turf,

 Adults and youths (11 to <16 yr old) dermal exposure to treated turf during mowing and 

golfing activities,

 Children (6 to <11 years old) dermal exposure to treated turf during golfing activities, 

and

 Adults and children (6 to <11 years old) dermal exposure to treated gardens.

The exposure assessment for dermal exposure to treated gardens is protective of exposure to 

treated ornamental and fruit trees.

The lifestages selected for each post-application scenario are based on an analysis provided as an 

Appendix in the 2012 Residential SOPs4. These lifestages are not the only lifestages that could 

be potentially exposed for these post-application scenarios; however, the assessment of these 

lifestages is health protective for the exposures and risk estimates for any other potentially

exposed lifestages.

Residential Post-application Exposure Data and Assumptions

A series of assumptions and exposure factors served as the basis for completing the residential 

post-application risk assessment. Each assumption and factor is detailed in the 2012 Residential 

 

4 Available: http://www.epa.gov/pesticides/science/residential-exposure-sop.html
Page 31 of 59

SOPs4. The algorithms used to estimate exposure and dose for residential post-application 

exposures can be found in Appendix A and/or the 2012 Residential SOPs5.

TTR data for Fluopyram

Because turf transferable residue data were not available for fluopyram, turf residues were 

estimated using default assumptions. A TTR study is not required for fluopyram at this time. 

Refer to Section 6.2.2 of this document for a detailed rationale.

DFR data for Fluopyram

Because dislodgeable foliar residue data were not available for fluopyram, foliar residues were 

estimated using default assumptions. A DFR study is not required for fluopyram at this time. 

Refer to Section 6.2.2 of this document for a detailed rationale.

Exposures are expected to be short-term in duration. Short-term dermal and incidental oral 

exposure and risk estimates have been assessed. 

Combining Exposure and Risk Estimates

HED combines risk values resulting from separate routes of exposure when it is likely they can 

occur simultaneously based on the use pattern and the behavior associated with the exposed 

population, and if the hazard associated with the points of departure is similar across routes. 

Since dermal and incidental oral exposure routes do not share a common toxicological endpoint

for fluopyram, risk estimates have not been combined for those routes. 

Tables 5.2.1 and 5.2.2 summarize the residential post-application exposure and risk estimates for 

exposures to treated lawns and turf. The proposed liquid formulations do not lead to postapplication risk estimates of concern. Residential dermal post-application MOEs for all life 

stages range from 1,000 to 97,000. Residential incidental oral post-application MOEs for 

children 1 to <2 years old range from 2,400 to 1,100,000.

Table 5.2.1. Residential Post-Application Dermal Short-Term Exposure and Risk Estimates from Turf.

Scenario Application 

Rate (lb ai/A)

TTR1

(μg/cm2)

Exposure 

Time (hr) Population TC (cm2/hr)

Daily Dose2

(mg/kg/day) MOE3

Golf Course 

Turf 0.446 0.0496 4

Adults 5,300 0.0131 23,000

Youths 11 to <16 yr old 4,400 0.0153 20,000

Children 6 to <11 yr old 2,900 0.0180 17,000

High 

Contact 

Activities

0.404 0.0449 1.5

Adults 180,000 0.152 2,000

Children 1 to <2 yr old 49,000 0.300 1,000

Mowing 

Turf 0.404 0.0449 1

Adults 5,500 0.00309 97,000

Youths 11 to <16 yr old 4,500 0.00355 85,000

1 TTR derived as follows: 0.446 lb ai/A x 4.54E+8 μg/lb x 2.47E-8 A/cm2

x 0.01 (fraction of transferable ai) = 0.0496 μg/cm2or 0.404 lb ai/A x 

4.54E+8 μg/lb x 2.47E-8 A/cm2x 0.01 (fraction of transferable ai) = 0.0449 μg/cm2.

2 Daily Dose = [TTR (μg/cm2

) x (0.001 mg/μg) x Dermal Transfer Coefficient x Exposure Time] / [Body weight (80 kg for adults, 57 kg for 

youths 11 to <16 yr, 32 kg for children 6 to <11 yr, and 11 kg for children 1 to <2 yr old)].

3 MOE = NOAEL/Daily Dose. Short-Term NOAEL = 300 mg/kg/day.

Table 5.2.2. Residential Post-Application Incidental Oral Exposure to 1 to <2 Year Olds from Turf.

 

5 Available: http://www.epa.gov/pesticides/science/residential-exposure-sop.html
Page 32 of 59

Scenario

Application Rate 

(lb ai/A)

Daily Dose (mg/kg/day) MOE

Hand-to-Mouth 0.404 0.00615 2,400

Object-to-Mouth 0.404 0.000187 78,000

Soil Ingestion 0.404 0.000014 1,100,000

1 TTR derived as follows: 0.404 lb ai/A x 4.54E+8 μg/lb x 2.47E-8 A/cm2

x 0.01 (fraction of transferable ai) = 0.0449 μg/cm2.

2 Based on HED’s 2012 Residential SOPs: Lawns/Turf (http://www.epa.gov/pesticides/science/residential-exposure-sop.html).

3 MOE = NOAEL/Daily Dose. Short-Term NOAEL = 14.5 mg/kg/day.

Table 5.2.3 summarizes the residential post-application exposure and risk estimates for 

exposures to treated gardens, ornamental trees and shrubs, and fruit trees. The proposed liquid

formulations do not lead to post-application risk estimates of concern (all MOEs ≥100). 

Residential dermal post-application MOEs for all life stages range from 2,100 to 33,000.

Table 5.2.3. Residential Post-Application Dermal Short-Term Exposure and Risk Estimates from Gardens, 

Ornamentals and Fruit Trees.

Scenario Application 

Rate (lb ai/A)

DFR

1

(μg/cm2)

Exposure 

Time (hr) Population TC (cm2/hr)

Daily Dose2

(mg/kg/day) MOE3

Gardens 0.223 0.625

2.2 Adults 8,400 0.143 2,100

1.1 Children 6 to <11 yr old 4,600 0.0980 3,100

Trees 0.223 0.625

1.0 Adults 1,700 0.0132 23,000

0.5 Children 6 to <11 yr old 930 0.0090 33,000

1 DFR derived as follows: 0.223 lb ai/A x 4.54E+8 μg/lb x 2.47E-8 A/cm2

x 0.25 (fraction of transferable ai) = 0.625 μg/cm2.

2 Daily Dose = [DFR (μg/cm2

) x (0.001 mg/μg) x Dermal Transfer Coefficient x Exposure Time] / [Body weight (80 kg for adults and 32 kg for 

children 6 to <11 yr)].

3 MOE = NOAEL/Daily Dose. Short-Term NOAEL = 300 mg/kg/day.

5.3 Combined Residential Risk Estimates (Multiple Exposure Scenarios)

Residential handler and post-application scenarios should generally not be combined. Although 

there is potential for the same individual (i.e., adult) to apply a pesticide in and around the home 

and be exposed by reentering a treated area in the same day, this is unlikely to occur day after 

day for 30 days. Combining both of these exposure scenarios would also be inappropriate 

because of the conservative nature of each individual assessment.

Since the application rates are different for turf and ornamental plants/trees, and because of the 

conservative nature of the individual turf and gardens/trees assessments, these scenarios were not 

combined.

5.4 Residential Risk Estimates for Use in Aggregate Assessment

Table 5.4.1 reflects the residential risk estimates that are recommended for use in the aggregate 

assessment for fluopyram.

 The recommended residential exposure for use in the adult aggregate assessment reflects 

inhalation handler exposure from treating lawns from by hose-end sprayer.

 The recommended residential exposure for use in the children (1 to <2 years old) 

aggregate assessment reflects incidental oral hand-to-mouth post-application exposure to 

treated lawns.
Page 33 of 59

Table 5.4.1. Recommendations for the Residential Exposures for the Fluopyram Aggregate Assessment.

Lifestage Dose 

(mg/kg/day)4 MOE5

Adults [inhalation handler exposure from treating lawns by hose-end sprayer] 0.000056 260,000

Child (1 to <2 years old) [incidental oral hand-to-mouth post-application exposure to treated lawns] 0.00615 2,400

5.5 Spray Drift

Spray drift is a potential source of exposure to those nearby pesticide applications. This is 

particularly the case with aerial application, but, to a lesser extent, spray drift can also be a 

potential source of exposure from the ground application methods (e.g., groundboom and 

airblast) employed for fluopyram. The agency has been working with the Spray Drift Task Force 

(a task force composed of various registrants which was developed as a result of a Data Call-In 

issued by EPA), EPA Regional Offices and State Lead Agencies for pesticide regulation and 

other parties to develop the best spray drift management practices (see the agency’s Spray Drift 

website for more information). 6 The agency has also developed a policy on how to 

appropriately consider spray drift as a potential source of exposure in risk assessments for 

pesticides. The potential for spray drift will be quantitatively evaluated for each pesticide during 

the Registration Review process which ensures that all uses for that pesticide will be considered 

concurrently. The approach is outlined in the revised (2012) Standard Operating Procedures 

For Residential Risk Assessment (SOPs) - Residential Exposure Assessment Standard Operating 

Procedures Addenda 1: Consideration of Spray Drift. This document outlines the quantification 

of indirect non-occupational exposure to drift. 

5.6 Residential Bystander Post-Application Inhalation Exposure

Volatilization of pesticides may be a source of post-application inhalation exposure to 

individuals nearby pesticide applications. The agency sought expert advice and input on issues 

related to volatilization of pesticides from its Federal Insecticide, Fungicide, and Rodenticide Act 

Scientific Advisory Panel (SAP) in December 2009, and received the SAP’s final report on 

March 2, 2010 (http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2009-0687-

0037). The agency has evaluated the SAP report and has developed a Volatilization Screening 

Tool and a subsequent Volatilization Screening Analysis 

(http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2014-0219). During Registration 

Review, the Agency will utilize this analysis to determine if data (i.e., flux studies, route-specific 

inhalation toxicological studies) or further analysis is required for fluopyram.

In addition to this screen, the Agency has developed a preliminary bystander volatilization 

inhalation exposure assessment for fluopyram utilizing the currently available inhalation toxicity

and air monitoring data. 

 

6 Available: http://www2.epa.gov/reducing-pesticide-drift 
Page 34 of 59

6.0 Occupational Exposure and Risk Estimates

6.1 Occupational Handler Exposure/Risk Estimates

HED uses the term handlers to describe those individuals who are involved in the pesticide 

application process. HED believes that there are distinct job functions or tasks related to 

applications and exposures can vary depending on the specifics of each task. Job requirements 

(amount of chemical used in each application), the kinds of equipment used, the target being 

treated, and the level of protection used by a handler can cause exposure levels to differ in a 

manner specific to each application event. 

Based on the anticipated use patterns and proposed labeling, types of equipment and techniques 

that can potentially be used, occupational handler exposure is expected from the proposed uses. 

The quantitative dermal and inhalation exposure/risk assessment developed for occupational 

handlers is based on the following scenarios: 

1) Mixing/loading liquids for aerial and chemigation application,

2) Mixing/loading liquids for groundboom application,

3) Mixing/loading liquids for airblast application, 

4) Applying sprays via aerial equipment, 

5) Applying sprays via groundboom equipment, 

6) Applying sprays via airblast equipment, 

7) Flagging for aerial sprays, 

8) Mixing, loading, and applying liquids with manually pressurized handwand, 

9) Mixing, loading, and applying liquids with mechanically-pressurized handgun, and

10) Mixing, loading, and applying liquids with a backpack.

Occupational Agricultural Handler Exposure Data and Assumptions

A series of assumptions and exposure factors served as the basis for completing the occupational 

handler risk assessments. Each assumption and factor is detailed below on an individual basis.

Application Rate: A summary of the maximum application rates for each crop or use site are 

provided in Table 4.1.

Unit Exposures: It is the policy of HED to use the best available data to assess handler exposure. 

Sources of generic handler data, used as surrogate data in the absence of chemical-specific data, 

include PHED 1.1, the AHETF database, or other registrant-submitted occupational exposure 

studies. Some of these data are proprietary (e.g., AHETF data), and subject to the data 

protection provisions of FIFRA. The standard values recommended for use in predicting handler 

exposure that are used in this assessment, known as “unit exposures”, are outlined in the 

“Occupational Pesticide Handler Unit Exposure Surrogate Reference Table7”, which, along with 

 

7 Available: http://www.epa.gov/opp00001/science/handler-exposure-table.pdf
Page 35 of 59

additional information on HED policy on use of surrogate data, including descriptions of the 

various sources, can be found at the Agency website8.

Area Treated or Amount Handled: The daily areas treated or amounts handled were defined for 

each handler scenario (in appropriate units) by determining the amount that can be reasonably 

treated by an individual in a single day. When possible, the assumptions for daily areas treated 

or amounts handled are taken from the HED’s ExpoSAC Policy 9.1: “Standard Values for Daily

Acres Treated in Agriculture”. 

Exposure Duration: HED classifies exposures from 1 to 30 days as short-term and exposures 30 

days to six months as intermediate-term. Exposure duration is determined by many things, 

including the exposed population, the use site, the pest pressure triggering the use of the 

pesticide, and the cultural practices surrounding that use site. For most agricultural uses, it is 

reasonable to believe that occupational handlers will not apply the same chemical every day for 

more than a one-month time frame; however, there may be a large agribusiness and/or 

commercial applicators who may apply a product over a period of weeks (e.g., completing 

multiple applications for multiple clients within a region). 

For fluopyram, based on the existing labeled use patterns, short- and intermediate-term 

exposures are expected. Long-term exposure is not expected based on the proposed use patterns.

Mitigation/Personal Protective Equipment: Occupational handler exposure assessments are 

completed by HED using different levels of risk mitigation. Typically, HED uses a tiered 

approach. The lowest tier is designed as the baseline exposure scenario (i.e., long-sleeve shirt, 

long pants, shoes, socks, no respirator). If risk estimates are of concern at baseline attire, then 

increasing levels of PPE (i.e., gloves, respirators) are evaluated. This approach is used to ensure 

that the lowest level of risk mitigation that provides adequate protection is selected. Estimates of 

dermal and inhalation exposure were calculated for “baseline,” defined as a single layer of 

clothing consisting of a long sleeved shirt, long pants, shoes plus socks, no protective gloves, and 

no respirator. The fluopyram product labels direct mixers, loaders, applicators and other 

handlers to wear long-sleeved shirt and long pants, and chemical resistant gloves.

Occupational Handler Non-Cancer Exposure and Risk Estimate Equations

The algorithms used to estimate non-cancer exposure and dose for occupational handlers can be 

found in Appendix A.

Summary of Occupational Handler Non-Cancer Exposure and Risk Estimates

For all exposure scenarios the risk estimates do not exceed HED’s LOC (i.e., MOEs ≥100) at 

baseline clothing (i.e., long sleeved shirt, long pants, shoes plus socks, without gloves or a

respirator). The MOEs ranged from 410 to 1,500,000 for dermal exposure with baseline 

clothing, 2,400 to 1,100,000 for dermal exposure with the addition of gloves, and 7,400 to 

30,000,000 for inhalation exposure. See Table 6.1.1 for the summary of occupational handler 

risk estimates.

 

8 Available: http://www.epa.gov/pesticides/science/handler-exposure-data.html
Page 36 of 59

Table 6.1.1. Occupational Short- and Intermediate-Term Dermal and Inhalation Exposures and Risk Estimates For Fluopyram

Exposure 

Scenario Crop or Target

Maximum 

Application 

Ratea

(lb ai/A)

Area 

Treated 

or 

Amount 

Handled 

Dailyb

(A/day) 

Unit Exposured Daily Exposuree(mg/kg/day) MOEf

Baseline 

Dermalc

(mg/lb ai)

PPE-G 

Dermalc

(mg/lb ai)

Baseline 

Inhalationc

(μg/lb ai)

Baseline 

Dermal

PPE-G 

Dermal

Baseline 

Inhalation

Baseline 

Dermal

PPE-G 

Dermal

Baseline 

Inhalation

Mixer/Loader

Mixing/Loading 

Liquid 

Concentrates for 

Aerial and 

Chemigation 

Applications

Artichoke (globe); Brassica (cole) 

Leafy Vegetables; Bulb Vegetables; 

Carrot; Citrus; Cucurbit Vegetables; 

Fruiting Vegetables; Ginseng; 

Grapes and Small Vine Fruits 

(except Fuzzy Kiwifruit); Herbs and 

Spices (except Black Pepper); Hops; 

Leafy Vegetables; Pome Fruit; Other 

Root, Tuberous and Corm 

Vegetables; Small Berries 

(Caneberries and Bushberries); 

Stone Fruit; Strawberry and Other 

Low-Growing Berries

0.222 350

0.22 0.0376 0.219

0.214 0.0365 2.13E-4 1,400 8,200 68,000

Brassica Leafy Vegetables Head and 

Stem Subgroup 0.125 350 0.120 0.0206 1.20E-4 2,500 15,000 120,000

Canola Subgroup; Cereal grains; 

Forage, Fodder, or Straw from 

Cereal Grains; Cotton; Legume 

Vegetables (including Soybean); 

Potato; Sugar Beet; Sunflower 

subgroup

0.222 1200 0.733 0.125 7.29E-4 410 2,400 20,000

Nursery (ornamentals, vegetables, 

trees, container stock) 0.131 60 0.0216 0.00370 2.15E-5 14,000 81,000 670,000

Sod 0.446 350 0.429 0.0734 4.28E-4 700 4,100 34,000

Mixing/Loading 

Liquids 

Concentrates for 

Groundboom 

Applications

Artichoke (globe); Brassica (cole) 

Leafy Vegetables; Bulb Vegetables; 

Carrot; Citrus; Cucurbit Vegetables; 

Fruiting Vegetables; Ginseng; 

Grapes and Small Vine Fruits 

(except Fuzzy Kiwifruit); Herbs and 

Spices (except Black Pepper); Hops; 

Leafy Vegetables; Pome Fruit; Other 

Root, Tuberous and Corm 

Vegetables; Small Berries 

(Caneberries and Bushberries); 

Stone Fruit; Strawberry and Other 

Low-Growing Berries

0.222 80

0.22 0.0376 0.219

0.0489 0.00835 4.86E-5 6,00 36,000 300,000

Brassica Leafy Vegetables Head and 

Stem Subgroup 0.125 80 0.0275 0.00470 2.74E-5 11,000 64,000 530,000
Page 37 of 59

Table 6.1.1. Occupational Short- and Intermediate-Term Dermal and Inhalation Exposures and Risk Estimates For Fluopyram

Exposure 

Scenario Crop or Target

Maximum 

Application 

Ratea

(lb ai/A)

Area 

Treated 

or 

Amount 

Handled 

Dailyb

(A/day) 

Unit Exposured Daily Exposuree(mg/kg/day) MOEf

Baseline 

Dermalc

(mg/lb ai)

PPE-G 

Dermalc

(mg/lb ai)

Baseline 

Inhalationc

(μg/lb ai)

Baseline 

Dermal

PPE-G 

Dermal

Baseline 

Inhalation

Baseline 

Dermal

PPE-G 

Dermal

Baseline 

Inhalation

Canola Subgroup; Cereal grains; 

Forage, Fodder, or Straw from 

Cereal Grains; Cotton; Legume 

Vegetables (including Soybean); 

Potato; Sugar Beet; Sunflower 

subgroup

0.222 200 0.122 0.0209 1.22E-4 2,500 14,000 120,000

Field Grown Ornamentals 0.131 40 0.0144 0.00246 1.44E-5 21,000 120,000 1.0E+6

Nursery (ornamentals, vegetables, 

trees, container stock) 0.131 60 0.0216 0.0037 2.15E-5 14,000 81,000 670,000

Sod 0.446 80 0.0981 0.0168 9.76E-5 3,100 18,000 150,000

Turf 0.446 40 0.0490 0.00839 4.89E-5 6,100 36,000 300,000

Mixing/Loading 

Liquids 

Concentrates for 

Airblast 

Applications

Nursery (ornamentals, vegetables, 

trees, container stock) 0.131 20

0.22 0.0376 0.219

0.00720 0.00123 7.18E-6 42,000 240,000 2.0E+6

Grapes and Small Vine Fruits 

(except Fuzzy Kiwifruit); Pome 

Fruit; Stone Fruit; 

0.222 40 0.0244 0.00418 2.43E-5 12,000 72,000 600,000

Applicator

Applying 

Sprays via 

Aerial 

Equipment

Artichoke (globe); Brassica (cole) 

Leafy Vegetables; Bulb Vegetables; 

Carrot; Citrus; Cucurbit Vegetables; 

Fruiting Vegetables; Ginseng; 

Grapes and Small Vine Fruits 

(except Fuzzy Kiwifruit); Herbs and 

Spices (except Black Pepper); Hops; 

Leafy Vegetables; Pome Fruit; Other 

Root, Tuberous and Corm 

Vegetables; Small Berries 

(Caneberries and Bushberries); 

Stone Fruit; Strawberry and Other 

Low-Growing Berries

0.222 350

0.00208g No Data 0.0049g

0.00203 No Data 4.76E-6 150,000 No Data 3.0E+6

Brassica Leafy Vegetables Head and 

Stem Subgroup 0.125 350 0.00114 No Data 2.68E-6 260,000 No Data 5.4E+6

Canola Subgroup; Cereal grains; 

Forage, Fodder, or Straw from 

Cereal Grains; Cotton; Legume 

Vegetables (including Soybean); 

Potato; Sugar Beet; Sunflower 

subgroup

0.22 1200 0.00693 No Data 1.64E-5 43,000 No Data 880,000

Nursery (ornamentals, vegetables, 

trees, container stock) 0.131 60 0.000204

No Data 4.81E-7 1.5E+6 No Data 3.0E+7

Sod 0.446 350 0.00406 No Data 9.56E-6 74,000 No Data 1.5E+6
Page 38 of 59

Table 6.1.1. Occupational Short- and Intermediate-Term Dermal and Inhalation Exposures and Risk Estimates For Fluopyram

Exposure 

Scenario Crop or Target

Maximum 

Application 

Ratea

(lb ai/A)

Area 

Treated 

or 

Amount 

Handled 

Dailyb

(A/day) 

Unit Exposured Daily Exposuree(mg/kg/day) MOEf

Baseline 

Dermalc

(mg/lb ai)

PPE-G 

Dermalc

(mg/lb ai)

Baseline 

Inhalationc

(μg/lb ai)

Baseline 

Dermal

PPE-G 

Dermal

Baseline 

Inhalation

Baseline 

Dermal

PPE-G 

Dermal

Baseline 

Inhalation

Applying 

Sprays via 

Groundboom 

Equipment

Artichoke (globe); Brassica (cole) 

Leafy Vegetables; Bulb Vegetables; 

Carrot; Citrus; Cucurbit Vegetables; 

Fruiting Vegetables; Ginseng; 

Grapes and Small Vine Fruits 

(except Fuzzy Kiwifruit); Herbs and 

Spices (except Black Pepper); Hops; 

Leafy Vegetables; Pome Fruit; Other 

Root, Tuberous and Corm 

Vegetables; Small Berries 

(Caneberries and Bushberries); 

Stone Fruit; Strawberry and Other 

Low-Growing Berries

0.222 80

0.0786 0.0161 0.34

0.0175 0.00358 7.55E-5 17,000 84,000 190,000

Brassica Leafy Vegetables Head and 

Stem Subgroup 0.125 80 0.00983 0.00201 4.25E-5 31,000 150,000 340,000

Canola Subgroup; Cereal grains; 

Forage, Fodder, or Straw from 

Cereal Grains; Cotton; Legume 

Vegetables (including Soybean); 

Potato; Sugar Beet; Sunflower 

subgroup

0.222 200 0.0436 0.00894 1.89E-4 6,900 34,000 77,000

Field Grown Ornamentals 0.131 40 0.00515 0.00106 2.23E-5 58,000 280,000 650,000

Nursery (ornamentals, vegetables, 

trees, container stock) 0.131 60 0.00773 0.00159 3.34E-5 39,000 190,000 430,000

Sod 0.446 80 0.0175 0.00359 7.59E-5 17,000 84,000 190,000

Turf 0.446 40 0.0350 0.00718 1.51E-4 8,600 42,000 96,000

Applying 

Sprays via 

Airblast 

Equipment

Nursery (ornamentals, vegetables, 

trees, container stock) 0.222 20

1.77 1.59 4.71

0.0580 0.0521 1.54E-4 5,200 5,800 94,000

Grapes and Small Vine Fruits 

(except Fuzzy Kiwifruit); Pome 

Fruit; Stone Fruit 

0.131 40 0.196 0.176 5.23E-4 1,500 1,700 28,000

Flagger

Flagging for 

Aerial Sprays 

Applications

Artichoke (globe); Brassica (cole) 

Leafy Vegetables; Bulb Vegetables; 

Carrot; Citrus; Cucurbit Vegetables; 

Fruiting Vegetables; Ginseng; 

Grapes and Small Vine Fruits 

(except Fuzzy Kiwifruit); Herbs and 

Spices (except Black Pepper); Hops; 

Leafy Vegetables; Pome Fruit; Other 

Root, Tuberous and Corm 

Vegetables; Small Berries 

0.222 350 0.011 0.012 0.35 0.0107 0.0117 3.40E-4 28,000 26,000 43,000
Page 39 of 59

Table 6.1.1. Occupational Short- and Intermediate-Term Dermal and Inhalation Exposures and Risk Estimates For Fluopyram

Exposure 

Scenario Crop or Target

Maximum 

Application 

Ratea

(lb ai/A)

Area 

Treated 

or 

Amount 

Handled 

Dailyb

(A/day) 

Unit Exposured Daily Exposuree(mg/kg/day) MOEf

Baseline 

Dermalc

(mg/lb ai)

PPE-G 

Dermalc

(mg/lb ai)

Baseline 

Inhalationc

(μg/lb ai)

Baseline 

Dermal

PPE-G 

Dermal

Baseline 

Inhalation

Baseline 

Dermal

PPE-G 

Dermal

Baseline 

Inhalation

(Caneberries and Bushberries); 

Stone Fruit; Strawberry and Other 

Low-Growing Berries

Brassica Leafy Vegetables Head and 

Stem Subgroup 0.125 350 0.00601 0.00656 1.91E-4 50,000 46,000 76,000

Canola Subgroup; Cereal grains; 

Forage, Fodder, or Straw from 

Cereal Grains; Cotton; Legume 

Vegetables (including Soybean); 

Potato; Sugar Beet; Sunflower 

subgroup

0.22 1200 0.0366 0.040 0.00117 8,200 7,500 12,000

Nursery (ornamentals, vegetables, 

trees, container stock) 0.131 60 0.00108 0.00118 3.44E-5 280,000 250,000 420,000

Sod 0.446 350 0.0215 0.0234 6.83E-4 14,000 13,000 21,000

Mixer/Loader/Applicator

Mixing/Loading

/Applying 

Liquid 

Concentrates 

with Manually 

Pressurized 

Handwand

Greenhouse Ornamentals 0.00131 lb 

ai/gal

40 gal 100 0.43 30

0.0655 2.81E-4 1.96E-5 4,600 1.1E+6 740,000

Nursery (ornamentals, vegetables, 

trees, container stock)

0.00131 lb 

ai/gal 0.0655 2.81E-4 1.96E-5 4,600 1.1E+6 740,000

Christmas Trees 0.00223 lb 

ai/gal 0.112 4.80E-4 3.35E-5 2,700 630,000 430,000

Turf 0.0026 lb 

ai/gal 0.130 5.59E-4 3.90E-5 2,300 540,000 370,000

Mixing/Loading

/Applying 

Liquid 

Concentrates 

with 

MechanicallyPressurized 

Handgun

Greenhouse Ornamentals 0.00131 lb 

ai/gal 1000 gal 3.5 2.5 120 0.0574 0.0410 0.00196 5,200 7,300 7,400

Nursery (ornamentals, vegetables, 

trees, container stock)

0.00131 lb 

ai/gal 1000 gal

1.3 0.39 3.9

0.0213 0.00639 6.39E-5 14,000 47,000 230,000

Christmas Trees 0.00223 lb 

ai/gal 1000 gal 0.0363 0.0109 1.09E-4 8,300 28,000 130,000

Pome Fruit; Stone Fruit 0.0222 lb 

ai/gal 1000 gal 0.361 0.108 0.00108 830 2,800 13,000

Golf Course; Turf 0.446 5 1.14 0.88 1.9 0.0318 0.0245 5.30E-5 9,400 12,000 270,000

Mixing/Loading

/Applying 

Liquid 

Concentrates 

with a 

Backpack

Nursery (ornamentals, vegetables, 

trees, container stock)

0.00131 lb 

ai/gal

40 gal

13.2 11.2 140

0.00865 0.00734 1.98E-5 35,000 41,000 160,000

Christmas Trees 0.00223 lb 

ai/gal 0.0148 0.0125 1.56E-4 20,000 24,000 93,000

Pome Fruit; Stone Fruit 0.0222 lb 

ai/gal 8.26 8.26 2.58 0.0916 0.0916 2.86E-5 3,300 3,300 510,000
Page 40 of 59

Table 6.1.1. Occupational Short- and Intermediate-Term Dermal and Inhalation Exposures and Risk Estimates For Fluopyram

Exposure 

Scenario Crop or Target

Maximum 

Application 

Ratea

(lb ai/A)

Area 

Treated 

or 

Amount 

Handled 

Dailyb

(A/day) 

Unit Exposured Daily Exposuree(mg/kg/day) MOEf

Baseline 

Dermalc

(mg/lb ai)

PPE-G 

Dermalc

(mg/lb ai)

Baseline 

Inhalationc

(μg/lb ai)

Baseline 

Dermal

PPE-G 

Dermal

Baseline 

Inhalation

Baseline 

Dermal

PPE-G 

Dermal

Baseline 

Inhalation

Turf 0.0026 lb 

ai/gal 0.0107 0.0107 3.35E-6 28,000 28,000 4.3E+6

a. Application Rates are based on proposed uses from the proposed fluopyram labels.

b. Science Advisory Council Policy No. 9.1.

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

PPE-G Dermal: Baseline plus chemical-resistant gloves.

Baseline Inhalation: no respirator.

d. Unit Exposures are based on “Occupational Pesticide Handler Unit Exposure Surrogate Reference Table”. 

e. Daily Exposure (mg/kg/day) = Application Rate (lb ai/A) * Unit Exposure (mg/lb ai) * Area Treated or Amount Applied (acre/day) / 80 kg.

f. MOE = NOAEL (mg/kg/day) / Daily Exposure (mg/kg/day); where dermal NOAEL = 300 mg/kg/day and inhalation NOAEL = 14.5 mg/kg/day.

g. Engineering control unit exposure for applying sprays via aerial equipment = enclosed cockpit.
Page 41 of 59

Seed Treatment Use on Peanut Seeds

Based on the anticipated use patterns and labeling, types of equipment and techniques that can 

potentially be used, occupational handler exposure is expected from the proposed seed treatment 

of peanuts. The quantitative exposure/risk assessment developed for occupational handlers is 

based on the following scenarios: 

1. Mixing/loading liquids for commercial seed treatment,

2. Bagging treated seed,

3. Sewing bags,

4. Multiple activities, and

5. Planting treated seed.

Occupational seed treatment handlers may experience short- and intermediate-term exposure to

fluopyram while performing seed treatment activities in commercial settings. In addition, 

occupational secondary handlers may experience short- and intermediate-term exposure while 

planting fluopyram-treated seeds. No chemical-specific handler exposure data were submitted in 

support of this use pattern. For assessing commercial seed treatment and seed planting activities, 

unit exposure data were taken from HED ExpoSAC Policy 14: SOPs for Seed Treatment. The 

amount of ai handled depends on the application rate (lb ai/lb seed) and the pounds of seed 

treated in a day (or the pounds of seed that can be planted in a day), all of which vary depending 

upon the seed type. Values for the amount of seed treated and planted per day were obtained 

from HED ExpoSAC Policy 15 and 15.1.

Treating Seed (Primary Handler)

Potential occupational exposure scenarios from the use of fluopyram as a commercial seed 

treatment include: mixing, loading, applying liquid formulations; bagging treated seed; sewing 

bags; and multiple activities. Typically, for large-scale commercial seed treatments, workers 

perform only those specific individual tasks listed above; however, it is assumed that workers 

also may perform multiple activities throughout the day. As a result a “multiple activities” 

scenario (i.e. where one worker performs all seed treatment tasks such as loading/applying, 

sewing, bagging, cleaning, calibration, repair, forklift driver, etc.) was addressed.

Planting Treated Seed (Secondary Handler)

Potential occupational exposure scenarios from the use of fluopyram as a commercial seed 

treatment include planting treated seed (secondary handler). Planting treated seed consists of the 

farmer purchasing bags of treated seed, placing the seed in the hopper and applying seed to fields 

(considered a secondary handler exposure scenario).

Occupational Handler Exposure Data and Assumptions

A series of assumptions and exposure factors served as the basis for completing the occupational 

handler risk assessments. Each assumption and factor is detailed below on an individual basis.

Application Rate: 

Refer to the proposed use pattern table in Section 4.0 for a detailed description.
Page 42 of 59

Unit Exposures: It is the policy of HED to use the best available data to assess handler exposure. 

Chemical-specific data for assessing exposure during commercial seed treatment and seed 

planting were not submitted to the Agency in support of these applications. Unit exposures are 

from ExpoSAC Policy 14: SOPs for Seed Treatment (May 1, 2003) and are based on data for 

open mixing/loading/application systems.

Amount Handled: 

HED is currently in the process of revising ExpoSAC Policy 15: Amount of Seed Treated or 

Planted per Day (March 2, 2004) in efforts to update the daily amount of seed treated in 

commercial seed treatment facilities. With the increasing demand for hybridized treated seeds, 

there have been modifications not only in the seed treatment equipment, but in the market shares 

of new and currently registered pesticide products. HED understands that due to the high cost of 

producing hybrid seeds, direct seeding is done in a precision manner which requires lower 

volumes of seed per acre. However, this does not provide a direct correlation to the amount of 

seed which is treated in the commercial seed treatment facilities.

The amount of seed handled (for both primary/treater and secondary/planter handlers) is based 

on HED ExpoSAC Policy 15, HED ExpoSAC Policy SOP 15.1, and the BEAD memo: “Acres 

Planted Per Day and Seeding Rates of Crops Grown in the United States.”

 The amount of peanut seed treated per day at a commercial facility for short-term 

exposure durations is 339,500 lb.

 Amount of seed planted per acre (ASP, lb seed/A) for peanut is 228 lb seed/A (105,000

seeds/A x lb peanut seeds/460 peanut seeds).

 The amount of seed planted per acre per day for peanut is 18,260 lb (228 lb seed/A × 80

A/day).

Exposure Duration: 

HED classifies exposures from 1 to 30 days as short-term and exposures 30 days to six months 

as intermediate-term.

Mitigation/Personal Protective Equipment: Results are presented for PPE (gloves); defined as a

single layer of clothing consisting of a long sleeved shirt, long pants, shoes plus socks, protective 

gloves, and no respirator for all scenarios, except bagging and sewing, for which “baseline” attire 

was evaluated.

Occupational Handler Non-Cancer Exposure and Risk Estimate Equations

The algorithms used to estimate non-cancer exposure and dose for occupational handlers can be 

found in Appendix A.

Summary of Occupational Handler Non-Cancer Exposure and Risk Estimates

The results of the occupational handler exposure and risk assessment indicate that short-term 

dermal and inhalation risk estimates do not exceed HED’s LOC (i.e., an MOE < 100 for shortterm exposures). Short-term exposure risk estimates are protective of intermediate-term 

exposure risk estimates because the throughput (amount of seed treated) of short-term exposure 
Page 43 of 59

is greater than, or equal to, the throughput of intermediate-term exposure. The dermal MOEs 

range from 1,400 to 9,200 for handlers (treaters and planters). The inhalation MOEs range from 

1,700 to 15,000 for handlers (treaters and planters). Because the short- and intermediate-term 

dermal and inhalation PODs are the same, and the intermediate-term exposure inputs are less 

conservative than the short-term exposure inputs for seed treatment, short-term exposure risk 

estimates are protective of intermediate-term exposure risk estimates.

Table 6.1.2. Summary of Short- and Intermediate-Term Handler Exposures and Risk Estimates for 

Fluopyram Seed Treatment of Peanut Seed.

a

Maximum 

Application 

Rateb

lb ai/lb seed

Amount of 

Seed Treated 

or Planted 

Per Dayd

lb seed/day

Dermal

Unit 

Exposurec

mg/lb

Inhalation

Unit 

Exposurec

mg/lb

Dermal 

Dosee

mg/kg/day

Inhalation 

Dosef

mg/kg/day

Dermal 

MOEf

LOC = 100

Inhalation 

MOEh

LOC = 100

Loader/Applicator

0.001245 339,500 0.023 0.00034 0.1215 0.001796 2,500 8,100

Sewer

0.001245 339,500 0.0062 0.00023 0.03276 0.001215 9,200 12,000

Bagger

0.001245 339,500 0.0091 0.00016 0.04808 0.0008454 6,200 17,000

Multiple Activities

0.001245 339,500 0.042 0.0016 0.2219 0.008454 1,400 1,700

Planters

0.001245 18,260 0.25 0.0034 0.07104 0.0009662 4,200 15,000

a Seed treatment rate calculations are based on the following assumptions:

Peanut: 460 seeds per lb; 228 lb of seed planted per acre, 80 acres planted per day.

b Application Rate based on proposed label for fluopyram (Luna Privilege, EPA Reg. No. 264-1078).

c Unit Exposures from HED Exposure Science Advisory Council Policy 14: Standard Operating Procedures for Seed Treatment (baseline 

inhalation = no respirator; dermal unit exposure includes PPE with gloves for loading/applicator, multiple activities and planter scenarios).

d HED default for lb seed treated/planted per day from HED Exposure Science Advisory Council Interim Policy 15.1 and the BEAD memo 

“Acres Planted Per Day and Seeding Rates of Crops Grown in the United States” (J. Becker, March 2011).

e Daily Dermal Dose (mg/kg/day) = daily dermal unit exposure (mg/lb ai) × application rate (lb ai/lb seed) × amount planted (lb seed/day) ÷ 

body weight (80 kg adult).

f Daily Inhalation Dose (mg/kg/day) = daily inhalation unit exposure (mg/lb ai) × application rate (lb ai/lb seed) × amount planted (lb seed/day) 

÷ body weight (80 kg adult).

g Dermal MOE = NOAEL (300 mg/kg/day for short- and intermediate-term exposure) ÷ Dermal Dose (mg/kg/day). Level of concern = 100.

h Inhalation MOE = NOAEL (14.5 mg/kg/day for short- and intermediate-term exposure) ÷ Inhalation Dose (mg/kg/day). Level of concern = 

100.

6.2 Occupational Post-application Exposure/Risk Estimates

HED uses the term post-application to describe exposures that occur when individuals are 

present in an environment that has been previously treated with a pesticide (also referred to as reentry exposure). Such exposures may occur when workers enter previously treated areas to 

perform job functions, including activities related to crop production, such as scouting for pests 

or harvesting. Post-application exposure levels vary over time and depend on such things as the 

type of activity, the nature of the crop or target that was treated, the type of pesticide application, 
Page 44 of 59

and the chemical’s degradation properties. In addition, the timing of pesticide applications, 

relative to harvest activities, can greatly reduce the potential for post-application exposure.

6.2.1 Occupational Post-application Inhalation Exposure/Risk Estimates

There are multiple potential sources of post-application inhalation exposure to individuals 

performing post-application activities in previously treated fields. These potential sources 

include volatilization of pesticides and resuspension of dusts and/or particulates that contain 

pesticides. The agency sought expert advice and input on issues related to volatilization of 

pesticides from its Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel 

(SAP) in December 2009, and received the SAP’s final report on March 2, 2010 

(http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html). The agency has 

evaluated the SAP report and has developed a Volatilization Screening Tool and a subsequent 

Volatilization Screening Analysis (http://www.regulations.gov/#!docketDetail;D=EPA-HQOPP-2014-0219). During Registration Review, the agency will utilize this analysis to determine 

if data (i.e., flux studies, route-specific inhalation toxicological studies) or further analysis is 

required for fluopyram.

In addition, the Agency is continuing to evaluate the available post-application inhalation 

exposure data generated by the Agricultural Reentry Task Force. Given these two efforts, the 

Agency will continue to identify the need for and, subsequently, the way to incorporate 

occupational post-application inhalation exposure into the agency's risk assessments.

Although a quantitative occupational post-application inhalation exposure assessment was not 

performed, an inhalation exposure assessment was performed for occupational/commercial

handlers. Handler exposure resulting from application of pesticides outdoors is likely to result in 

higher exposure than post-application exposure. Therefore, it is expected that these handler 

inhalation exposure estimates would be protective of most occupational post-application 

inhalation exposure scenarios.

6.2.2 Occupational Post-application Dermal Exposure/Risk Estimates

Use on Agricultural Field Crops

Occupational Post-application Dermal Exposure Data and Assumptions

In addition to the application rate and body weight values discussed above in the handler 

exposure section, the following assumptions were made in assessing short- and intermediateterm dermal post-application risks:

Dislodgeable Foliar Residues:

There were no chemical-specific dislodgeable foliar residue data to assess post-application risks 

to workers while performing tasks related to crops treated with fluopyram. For agricultural 

crops, occupational post-application exposures and risks were assessed using HED’s default 

assumptions that 25% of the initial application is available for transfer on day 0 (i.e., 12 hours 

after application) and that the residue dissipates at a rate of 10% per day. 
Page 45 of 59

In accordance with 40 CFR §158, DFR data are required for all occupational (e.g., crop, nursery, 

greenhouse use sites) or residential (e.g., ornamental and vegetable gardens, pick your own 

farms, retail tree farms) uses that could result in post-application exposure to foliage. In the 

absence of chemical-specific DFR data, EPA uses default values. The 2012 Standard Operating 

Procedures for Residential Pesticide Exposure Assessment includes an analysis of a number of 

DFR studies, which resulted in the selection of a revised default values for the fraction of the 

application rate available for transfer after a foliar application (FAR). These values are based on 

an analysis of 19 DFR studies. Since that time, the Agricultural Re-entry Task Force has 

submitted information (MRID 49299201) that corrects an application rate error made in the 

original submission of “ARF039 – Determination of Dermal and Inhalation Exposure to Reentry

Workers During Chrysanthemum Pinching in a Greenhouse” (EPA MRID 45344501). As a 

result, the range of FAR values was revised from 2% - 89% to 2% - 47%. In the data, a large 

range of transferability is observed and this variability can potentially be attributable to many 

factors such as active ingredient; formulation; field conditions in the studies; weather conditions 

(e.g., humidity); or many other difficult to quantify factors. Although witnessed across multiple 

chemicals, this range in FAR values is not expected when considering DFR data for a single 

chemical. At this time, the ARTF submission did not alter the selection of 25% as the 

reasonable, high-end default value. Because DFR data are not available for fluopyram, EPA is 

using the default value of 25%. Although there may be a small degree of uncertainty in the use 

of the default DFR value for fluopyram (i.e., there is a small chance that the FAR value may

exceed the applicable default value), it is likely that the health-protective aspects of EPA’s 

occupational post-application assessment methodology will more than compensate for this 

potential uncertainty. For example, when assessing residential and occupational postapplication exposure to gardens and ornamentals, EPA assumes the following: exposures occur 

to zero-day (i.e., day of application ) residues every day of the assessed exposure duration (i.e., 

EPA assumes that no dissipation or degradation occurs, it doesn’t rain, etc); individuals perform 

the same post-application activities performed in the transfer coefficient study day after day (e.g., 

weeding, harvesting, pruning, etc.); and individuals engage in these post-application activities for 

a high-end amount of time every day (represented by data reflecting time spent gardening based 

on survey data).

Given the conservatisms discussed above and the potential compounding nature of these 

conservatisms, EPA is able to rely upon the calculated exposure estimates with confidence that 

exposure is not being underestimated. 

Since the highest estimated residential and occupational post-application exposures using default 

DFR values for fluopyram are minimal in comparison to the level of concern (i.e., the calculated 

MOE is greater than 2 times higher than the level of concern, residential MOE = 2,100 and 

occupational MOE = 250 compared to the LOC of 100); EPA is waiving the 40 CFR §158 DFR 

data requirement. In this instance, it is unlikely that chemical-specific DFR data would be 

needed to further refine exposure assessments or would add appreciably to our overall 

understanding of the availability of dislodgeable foliar pesticide residues for fluopyram. 
Page 46 of 59

Turf Transferrable Residues

A turf transferrable residue study has not been submitted for fluopyram. Therefore, HED’s 

standard operating procedures and assumptions were used to determine an estimate of day zero 

fluopyram residues on treated turf. 

In accordance with 40 CFR §158, TTR data are required for all occupational (e.g., sod farms, 

golf courses, parks, and recreational areas) or residential turf uses that could result in postapplication exposure to turf. In the absence of chemical-specific TTR data, EPA uses default 

values. The 2012 Standard Operating Procedures for Residential Pesticide Exposure 

Assessment includes an analysis of all TTR data, available at the time, which resulted in the 

selection of revised liquid and granular default values for the fraction of the application rate 

available for transfer after a turf application (FAR). These values are based on an analysis of 59 

TTR studies performed with the Modified California Roller Method (36 studies using liquids, 11 

studies using wettable powders/water dispersible granules, and 12 studies using granules). The 

liquid results (N=131) indicate a range of FAR values from 0.0005% to 6.1% and the granular 

results (N=37) indicate a range of 0.00064% to 0.69%. In both the liquid and granular data, a 

large range of transferability is observed and this variability can potentially be attributable to 

many factors such as active ingredient; formulation; field conditions in the studies; weather 

conditions (e.g., humidity); or many other difficult to quantify factors. Although witnessed 

across multiple chemicals, this range in FAR values is not expected when considering TTR data 

for a single chemical. HED selected 1% and 0.2% as high-end default values for liquid and

granular products, respectively. Because TTR data are not available for fluopyram, EPA is using 

the default value of 1%. Although there may be a small degree of uncertainty in the use of the 

default TTR value for fluopyram (i.e., there is a small chance that the FAR value may exceed the 

applicable default value), it is likely that the health-protective aspects of EPA’s residential and 

occupational post-application turf assessment methodology will more than compensate for this 

potential uncertainty (i.e., the methodology is likely to overestimate exposure by a factor greater 

than the factor than the highest measured FAR values exceed the defaults). For example, when 

assessing residential post-application turf exposure, EPA assumes the following: exposures 

occur to zero-day (i.e., day of application ) residues every day of the assessed exposure duration 

(i.e., EPA assumes that no dissipation or degradation occurs, it doesn’t rain, the grass is not 

mowed, etc.); individuals perform the same post-application activities performed in the turf 

transfer coefficient study day after day (e.g., tumbling, playing on turf with toys, etc.); and 

individuals engage in these post-application activities for a high-end amount of time every day

that is represented by data reflecting time children spend outdoors and not specifically engaged 

in activities on turf, when in actuality children do not spend all of their outdoor time on turf and 

high-end levels of activity will not occur every day.

Given the conservatisms discussed above and the potential compounding nature of these 

conservatisms, EPA is able to rely upon the calculated exposure estimates with confidence that 

exposure is not being underestimated.

Since the estimated residential turf post-application exposure from high contact activities on 

lawns and the occupational post-application activities on golf course turf using default TTR 

values for fluopyram are minimal in comparison to the level of concern (i.e., the calculated 
Page 47 of 59

MOEs are greater than 10 times higher than the level of concern, residential MOE = 1,000 and 

occupational MOE = 9,000, compared to the LOC of 100); EPA is waiving the 40 CFR §158

TTR data requirement. In this instance, it is unlikely that chemical-specific TTR data would be 

needed to further refine exposure assessments or would add appreciably to our general 

understanding of the availability of turf transferable pesticide residues.

Transfer Coefficients:

HED uses a concept known as the transfer coefficient to numerically represent the postapplication exposures one would receive (generally presented as cm2

/hour). A transfer 

coefficient is a measure of the residue transferred from a treated surface to a person who is doing 

a task or activity in a treated area. These values are the ratio of an exposure for a given task or 

activity to the amount of pesticide residue on treated surfaces available for transfer. HED has 

developed a series of standard transfer coefficients that are unique for variety of job tasks or 

activities that are used in lieu of chemical- and scenario-specific data. 

No post-application data were submitted in support of this registration action; therefore, dermal 

exposures during post-application activities were estimated for the various tasks that postapplication workers might perform on each crop grouping using dermal transfer coefficients 

from the Science Advisory Council for Exposure Policy Number 3 

(http://www.epa.gov/pesticides/science/exposac_policy3.pdf). This policy reflects adoption of 

all ARTF data. Use of the data in this policy requires compensation to the ARTF under FIFRA. 

The transfer coefficients used in this assessment were taken from the Agency’s revised 

Agricultural Transfer Coefficient SOP. Many of the transfer coefficients in this SOP are based 

on work of the ARTF. 

Workday:

HED assumes an 8 hour workday for post-application workers.

Equations and Calculations:

Daily Dermal Exposure and default DFR calculations are presented below. The algorithms used 

to estimate dermal post-application exposure and dose can be found in Appendix A.

The post-application dermal exposure and risk estimates associated with agricultural crops, 

Christmas trees, and nursery ornamentals are summarized in Table 6.2.2. For each crop or crop 

group the post-application activities with the highest transfer coefficient and highest exposure 

contact are presented. The occupational post-application MOEs for all crops and crop groups 

and scenarios shown below do not exceed HED’s level of concern (MOEs ≥100) on day 0 (i.e., 

12 hours following application) with dermal MOEs ranging from 250 to 23,000. All other 

scenarios involving lesser contact activities would have higher MOEs and are also not of 

concern.
Page 48 of 59

Table 6.2.2. Summary of Occupational Non-Cancer Post-application Risks (Short- and Intermediate-Term) 

with HED Default Assumptions.

Crops or Crop 

Groups

Application 

Rate

(lb ai/acre)

Default DFR on 0 

days (12 hr) after 

applicationa

(μg/cm2)

Work Activity & 

Maximum Transfer 

Coefficientb

(cm2/hr)

Daily Dosec

(mg/kg/day)

MOEd

(LOC = 100)

Artichoke 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Brassica Leafy 

Vegetables Head & 

Stem Subgroup

0.125 0.350

4200 Hand Harvesting, Hand 

Weeding, Scouting, Topping, 

Tying/Training

0.147 2,000

Brassica Leafy 

Vegetables 0.222 0.622 4200 Hand Weeding 0.261 1,100

Bulb Vegetables 0.222 0.622 4200 Hand Weeding 0.261 1,100

Canola Subgroup 0.222 0.622 1100 Scouting 0.0684 4,400

Carrot 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Sweet Corn 0.222 0.622 17,600 Hand Detasseling, Hand 

Harvesting 1.09 270

Cereal Grains 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Forage, Fodder or 

Straw from Cereal 

Grains

0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Citrus 0.222 0.622 1400 Hand Harvesting 0.0871 3,400

Cotton 0.222 0.622 210 Scouting 0.0131 23,000

Cucurbits 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Fruiting Vegetables 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Okra 0.167 0.468 1900 Irrigation (Hand Set) 0.0889 3,400

Ginseng 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Small Vine Fruits 0.222 0.622 10,100 Hand Harvesting 0.628 480

Herbs & Spices 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Hops 0.222 0.622 19,300 Harvesting, Mechanically 

Assisted 1.20 250

Leafy Vegetables 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Legume Vegetables 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Soybean 0.222 0.622 1100 Scouting 0.0684 4,400

Pome Fruit 0.222 0.622 3600 Thinning Fruit 0.224 1,300

Root, Tuberous & 

Corm Vegetables 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Small Berries 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Stone Fruit 0.222 0.622 3600 Thinning Fruit 0.224 1,300

Low Growing 

Berries 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Sugar Beet 0.222 0.622 1100 Hand Harvesting 0.0684 4,400

Sunflower 0.222 0.622 1900 Irrigation (Hand Set) 0.118 2,500

Christmas Trees 0.223 0.625 1900 Irrigation (Hand Set) 0.119 2,500

Nursery 

Ornamentals 0.131 0.367 1900 Irrigation (Hand Set) 0.0697 4,300

a. Default DFR (μg/cm2) = application rate (lb ai/A) x (1- daily dissipation rate) tx 4.54E+8 μg/lb x 24.7E-9 A/cm

2

x 25% DFR after initial treatment.

b. Crops were assessed using the highest transfer coefficient (TC) available.

c. Daily Dose = DFR x TC x (1 mg/1000 μg) x ET (8 hr/day) / body weight (80 kg)

d. MOE = NOAEL (300 mg/kg/day) / Daily Dose (mg/kg/day)
Page 49 of 59

For use on cotton, HED has also assessed the post-application dermal exposure and risk 

estimates for workers involved in harvesting cotton bolls. Although most of cotton harvesting is 

done mechanically, there are still some activities, with the potential for exposure, that are 

associated with the harvesting of cotton. The anticipated post-application activities and dermal 

transfer coefficients for these activities are presented in Table 6.2.3. The recommended transfer 

coefficients are derived from EPA’s Science Advisory Council for Exposure (ExpoSAC) Policy

3 (http://www.epa.gov/pesticides/science/exposac-policy3-march2013.pdf). No chemical 

specific data are available for the amount of residue available on the cotton bolls; i.e., 

dislodgeable boll residue (DBR) data. Such data are available from a study with the active 

ingredient tribufos; i.e., MRID 42701601. Note to RD: These data may be proprietary, and 

subject to the data protection provisions of FIFRA, and therefore, may trigger a data 

compensation issue between registrants. Since the proposed fluopyram labels include a 30 day

pre-harvest interval, the best fit residue data used from MRID 42701601 was chosen from 30 

days after harvest and then adjusted for the difference in application rates. All of the cotton 

harvesting activities resulted in MOEs ranging from 3,100,000 to 17,000,000, which do not 

exceed the LOC, and are therefore not of concern; see Table 6.2.4.

Table 6.2.3. Anticipated Post-Application Activities and Transfer Coefficients for Cotton Harvesters.

Crop Policy Crop 

Group Category

Crop 

Height

Foliage 

Density Transfer Coefficients Activities

Cotton Field / row. crop, 

low / medium High Min

900 g cotton boll/hr Mechanical Harvesting 

(Module Builder Operator)

2,400 g cotton boll/hr Mechanical Harvesting 

(Picker Operator and Raker)

5,050 g cotton boll/hr Mechanical Harvesting 

(Tramper)

Table 6.2.4. Occupational Post-application Exposure and Risk Estimates for Cotton Harvesting Activities.

Mechanical Harvesting Activity Appl. Rate

(lb ai/A)

DBR

(μg/g)

1

Transfer 

Coefficient

(g/hr)2

Dermal Dose3

(mg/kg/day)

Dermal 

MOE4

Module Builder Operator

0.222 0.000194

900 0.0000175 17,000,000

Picker Operator and Raker 2,400 0.0000466 6,400,000

Tramper 5,0500 0.0000981 3,100,000

1. Cotton Harvesting Dislodgeable Boll Residue (DBR) = (Best fit DBR at 30 days MRID# 42701601 (0.082 μg/50g = 0.00164 

μg/g) x Application Rate (0.222 lb ai/A)) / Study Application Rate (1.875 lb ai/A) = 0.000194 μg/g

2. From Non-Foliar Transfer Coefficient Table: http://epa.gov/pesticides/science/exposac-policy-3-march2013.pdf 

3. Daily Dose (mg/kg/day) = [DBR x Transfer Coefficient x Conv. Factor (0.001 mg/μg) x 8 hr/day] / Body Weight (80 kg). 

4: Short- & Intermediate-term Margin of Exposure (MOE) = Short-term Dermal NOAEL (300 mg/kg/day) / Daily Dose 

(mg/kg/day).

For use on turf, the exposure/risk assessment for the proposed uses results in a post-application 

occupational MOE of 9,000, which is above the dermal LOC (MOE ≥100); and therefore is not 

of concern.
Page 50 of 59

Table 6.2.5. Exposure and Risk Assessment for Occupational Post-Application Activities on Turf.

Application Rate

(lb ai/A)

Dermal Transfer Coefficient 

(cm2/hr) & Activities1

Post 

Application

Day (t)

Turf 

Transferable 

Residue 

(TTR)2(μg/cm2)

Daily Dose3

(mg/kg/day)

Short- & 

Intermediate

-Term 

Dermal 

MOE4

0.446

6,700 (Maintenance, 

Transplanting/Planting, & 

Harvesting Sod)

0 0.05 0.0335 9,000

1 The transfer coefficient is the arithmetic mean value taken from MRID 46734001. It should be noted that a previous study on 

golf course maintenance (MRID 45530101) had been submitted, but had been determined to be unacceptable. Data from MRID 

46734001 are believed to be more appropriate.

2 TTR derived as follows: 0.446 lb ai/A x 4.54E+8 μg/lb x 2.47E-8 A/cm2

x 0.01 (fraction of transferable ai) = 0.05 μg/cm2.

3 Daily Dose = [TTR (μg/cm2

) x (0.001 mg/μg) x Dermal Transfer Coefficient x Exposure Time (8 hr)] / [Body Weight (80 kg)]

= 0.0335 mg/kg/day.

4 MOE = LOAEL/Daily Dose. Short-/Intermediate-Term LOAEL = 300 mg/kg/day.

Restricted Entry Interval

Since post-application risk estimates were not a concern on day 0 (12 hours following 

application), the REI is based on the acute toxicity of fluopyram technical material. Fluopyram

is classified as Toxicity Category III by the acute dermal route of exposure and Toxicity

Category IV for acute eye irritation potential and skin irritation potential. Under the WPS for 

Agricultural Pesticides, active ingredients classified as acute toxicity categories III or IV for 

these routes are assigned a 12-hour REI. Therefore, the 12-hour REI that appears on the 

proposed labels is adequate to protect agricultural workers from post-application exposures to 

fluopyram.

Seed Treatment Use on Peanut Seeds

With regard to seed treatment, the potential for post-application exposures following the planting 

of fluopyram-treated seeds is unlikely because sustained levels of contact with treated seed after 

it has been placed in the soil or other planting media would not be expected because no routine 

cultural practice required for the production of agricultural commodities involves such an 

activity, as defined in the no/low contact criteria in the Worker Protection Standard (WPS) in 40 

CFR §170.112. Therefore, no quantitative post-application assessment is required for exposure 

to treated seeds that have already been planted.
Page 51 of 59

Appendix A. Summary of Occupational and Residential Non-cancer Algorithms

Occupational Handler Non-Cancer Algorithms

Potential daily exposures for occupational handlers are calculated using the following formulas:

E=UE * AR * A * 0.001 mg/ug

where:

E = exposure (mg ai/day),

UE = unit exposure (μg ai/lb ai),

AR = maximum application rate according to proposed label (lb ai A or lb ai/gal), and

A = area treated or amount handled (e.g., A/day, gal/day).

The daily doses are calculated using the following formula:

ADD= 

E * AF

BW

where:

ADD = average daily dose absorbed in a given scenario (mg ai/kg/day),

E = exposure (mg ai/day),

AF = absorption factor (dermal and/or inhalation), and

BW = body weight (kg).

Margin of Exposure: Non-cancer risk estimates for each application handler scenario are 

calculated using a Margin of Exposure (MOE), which is a ratio of the toxicological endpoint to 

the daily dose of concern. The daily dermal and inhalation dose received by occupational 

handlers are compared to the appropriate POD (i.e., NOAEL) to assess the risk to occupational 

handlers for each exposure route. All MOE values are calculated using the following formula:

MOE= 

POD

ADD

where:

MOE = margin of exposure: value used by HED to represent risk estimates (unitless),

POD = point of departure (mg/kg/day), and

ADD = average daily dose absorbed in a given scenario (mg ai/kg/day).

Occupational Post-application Algorithms

Exposure resulting from contacting previously treated turf while working is calculated as 

follows:
Page 52 of 59

E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day); 

TTRt = turf transferable residue on day "t" (μg/cm2);

CF1 = weight unit conversion factor (0.001 mg/μg);

TC = transfer coefficient (cm2/hr); and

ET = exposure time (hr/day).

and

TTRt = AR * F * (1-FD)t * CF2 * CF3

where:

TTRt = turf transferable residue on day t (μg/cm2);

AR = application rate (lbs ai/ft2or lb ai/acre);

F = fraction of ai as transferable residue following application (unitless);

FD = fraction of residue that dissipates daily (unitless);

t = post-application day on which exposure is being assessed;

CF2 = weight unit conversion factor (4.54 x 108μg/lb); and

CF3 = area unit conversion factor (1.08 x 10-3ft2/ cm2or 2.47 x 10-8acre/cm

2

).

Absorbed dose, normalized to body weight, is calculated as:

BW

E AF D*



where:

D = dose (mg/kg-day);

E = exposure (mg/day); 

AF = absorption factor (dermal); and

BW = body weight (kg).

Residential Post-application Algorithms

Post-application Dermal Exposure Algorithm – Physical Activities on Turf

Exposure resulting from contacting previously treated turf while performing physical activities is 

calculated as shown below. Residential post-application exposure assessment must include 

calculation of exposure on the day of application. Therefore, though an assessment can present 

exposures for any day “t” following the application, it must include “day 0” exposure.

E = TTRt * CF1 * TC * ET
Page 53 of 59

where:

E = exposure (mg/day);

TTRt = turf transferable residue on day t (μg/cm2);

CF1 = weight unit conversion factor (0.001 mg/μg);

TC = transfer coefficient (cm2/hr); and

ET = exposure time (hr/day).

If chemical-specific TTR data are available, then surface residues from the day of application 

should be used (assume that individuals could be exposed to residues immediately after 

application). However, if data are not available, then TTRt can be calculated using the following 

formula:

TTRt= AR * F * (1-FD)t * CF2 * CF3

where:

TTRt = turf transferable residue on day t (μg/cm2);

AR = application rate (lbs ai/ft2or lb ai/acre);

F = fraction of ai as transferable residue following application (unitless);

FD = fraction of residue that dissipates daily (unitless);

t = post-application day on which exposure is being assessed;

CF2 = weight unit conversion factor (4.54 x 108μg/lb); and

CF3 = area unit conversion factor (1.08 x 10-3ft2/ cm2or 2.47 x 10-8acre/cm2).

Dermal absorbed doses are calculated as:

BW

E AF D*



where:

D = dose (mg/kg-day);

E = exposure (mg/day);

AF = absorption factor (dermal); and

BW = body weight (kg).

Table A-1: Turf (Physical Activities) -- Inputs for Residential Post-application Dermal Exposure

Algorithm Notation Exposure Factor

(units) Point Estimate(s)

AR Application rate

(mass active ingredient per unit area) 0.446 or 0.404 lb/A

F

Fraction of AR as TTR 

following application (if 

chemical-specific data is 

unavailable)

L/WP/WDG 0.01

Granules 0.002

FD

Daily residue dissipation 

(if chemical-specific data 

is unavailable)

L/WP/WDG 0.1

Granules 0.1
Page 54 of 59

Table A-1: Turf (Physical Activities) -- Inputs for Residential Post-application Dermal Exposure

Algorithm Notation Exposure Factor

(units) Point Estimate(s)

(fraction)

TC

Transfer 

Coefficient 

(cm2/hr)

L/WP/WDG Adults 180,000

Children 1 < 2 years old 49,000

Granules Adults 200,000

Children 1 < 2 years old 54,000

ET Exposure Time

(hours per day)

Adults 1.5

Children 1 < 2 years old 1.5

BW Body Weight

(kg)

Adults 80

Children 1 < 2 years old 11

L/WP/WDG = Liquids/Wettable Powders/Water-dispersible Granules

Post-application Hand-to-Mouth Exposure Algorithm– Physical Activities on Turf

Exposure from hand-to-mouth activity is calculated as follows (based on the algorithm utilized in 

the SHEDS-Multimedia model):

E = [HR * (FM * SAH) * (ET * N_Replen) * (1- (1- SE)

(Freq_HtM/N-Replen))]

where:

E = exposure (mg/day);

HR = hand residue loading (mg/cm2);

FM = fraction hand surface area mouthed / event (fraction/event);

SAH = typical surface area of one hand (cm2);

ET = exposure time (hr/day);

N_Replen = number of replenishment intervals per hour (intervals/hour);

SE = saliva extraction factor (i.e., mouthing removal efficiency); and

Freq_HtM = number of hand-to-mouth contacts events per hour (events/hour).

and

SA * 2

Fai *DE HR

H

hands



where:

HR = hand residue loading (mg/cm2);

Faihands = fraction ai on hands compared to total surface residue from dermal transfer coefficient 

study (unitless);

DE = dermal exposure (mg); and

SAH = typical surface area of one hand (cm2).

Dose, normalized to body weight, is calculated as:
Page 55 of 59

BW

E

D 

where:

D = dose (mg/kg-day);

E = exposure (mg/day); and

BW = body weight (kg).

Table A-2: Turf (Physical Activities) – Inputs for Residential Post-application Hand-to-Mouth Exposure 

Algorithm

Notation

Exposure Factor

(units) Point Estimate(s)

Faihands

Fraction of ai on hands 

from dermal transfer 

coefficient study

(unitless)

Liquid formulations 0.06

Granular formulations 0.027

DE Dermal exposure (mg) Calculated

SAH

Typical surface area of one hand (cm2), children 1 < 

2 years old 150

AR Application rate

(mass active ingredient per unit area) 0.404 lb/A

HR Residue available on the hands (mg/cm2) Calculated via (DE * Faihands)/SAH

FM

Fraction hand surface area mouthed

(fraction/event) 0.127

N_Replen Replenishment intervals per hour

(intervals/hr) 4

ET Exposure time 

(hrs/day) 1.5

SE Saliva extraction factor

(unitless) 0.48

Freq_HtM Hand-to-mouth events per hour

(events/hr) 13.9

BW Body Weight

(kg) Children 1 < 2 years old 11

Post-application Object-to-Mouth Exposure Algorithm– Physical Activities on Turf

Exposure from object-to-mouth activity is calculated as follows (based on the algorithm utilized 

in SHEDS-Multimedia):

E = [OR* CF1 * SAMO * (ET * N_Replen) * (1- (1- SEO)

(Freq_OtM/N_Replen))]

where:

E = exposure (mg/day);

OR = chemical residue loading on the object on day “t” (ug/cm2);

CF1 = weight unit conversion factor (0.001 mg/μg);

SAMO = area of the object surface that is mouthed (cm2/event);

ET = exposure time (hr/day);

N_Replen = number of replenishment intervals per hour (intervals/hour);

SEO = saliva extraction factor (i.e., mouthing removal efficiency); and
Page 56 of 59

Freq_OtM = number of object-to-mouth contact events per hour (events/hour).

and

OR = AR * FO * CF2 * CF3

where:

OR = chemical residue loading on the object (μg/cm2);

AR = application rate (lbs ai/ft2or lb ai/acre);

FO = fraction of residue available on the object (unitless);

CF2 = weight unit conversion factor (4.54 x 108μg/lb); and

CF3 = area unit conversion factor (1.08 x 10-3ft2/cm2or 2.47 x 10-8acre/cm2).

Dose, normalized to body weight, is calculated as:

BW

E

D 

where:

D = dose (mg/kg-day);

E = exposure (mg/day); and

BW = body weight (kg).

Table A-3: Turf (Physical Activities) – Inputs for Residential Post-application Object-to-Mouth Exposure 

Algorithm

Notation

Exposure Factor

(units) Point Estimate(s)

AR Application rate (to turf)

(mass active ingredient per unit area) 0.404 lb/A

FO Fraction of AR as OR following application 10.01

SAMO

Surface area of object mouthed 

(cm2/event) 10

N_Replen Replenishment intervals per hour (intervals/hour) 4

SEO

Saliva extraction factor

(fraction) 0.48

ET Exposure time 

(hours per day) 1.5

Freq_OtM Object-to-mouth events per hour (events/hr) 8.8

BW Body Weight (kg) Children 1 < 2 years old 11

1 This SOP assumes that all of the residue on the turf could be transferred to the object (e.g., object residue is 

equal to turf transferable residue).

Post-application Incidental Soil Ingestion Exposure Algorithm– Physical Activities on Turf

Exposure from incidental soil ingestion is calculated as follows:

E = SRt * SIgR * CF1

where:
Page 57 of 59

E = exposure (mg/day);

SRt = soil residue on day "t" (μg/g);

SIgR = ingestion rate of soil (mg/day); and

CF1 = weight unit conversion factor (1 x 10-6g/μg).

and

SRt = AR * FS * (1-FD)

t

* CF2 * CF3 * CF4

where:

SRt = soil residue on day "t" (μg/g);

AR = application rate (lbs ai/ft2or lb ai/acre);

FS = fraction of ai available in uppermost cm of soil (fraction/cm);

FD = fraction of residue that dissipates daily (unitless);

T = post-application day on which exposure is being assessed;

CF2 = weight unit conversion factor (4.54 x 108μg/lb);

CF3 = area unit conversion factor (1.08 x 10-3ft2/cm2 or 2.47 x 10-8acre/cm2); and

CF4 = soil volume to weight unit conversion factor (0.67 cm3/g soil).

Dose, normalized to body weight, are calculated as:

BW

E

D 

where:

D = dose (mg/kg-day);

E = exposure (mg/day); and

BW = body weight (kg).

Table A-4: Turf (Physical Activities) – Inputs for Residential Post-application Incidental Soil Ingestion 

Exposure 

Algorithm

Notation

Exposure Factor

(units) Point Estimate(s)

AR Application rate

(mass active ingredient per unit area) 0.404 lb/A

FS Fraction of AR available in uppermost 1 cm of soil

(unitless) 1

FD

Daily residue dissipation

(fraction) 0.1

SIgR Soil ingestion rate (mg/day) 50

BW Body weight (kg) Children 1 < 2 years old 11

Post-application Dermal Exposure Algorithm – Mowing

Exposure resulting from contacting previously treated turf while mowing is calculated as 

follows:
Page 58 of 59

E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day);

TTRt = turf transferable residue on day "t" (μg/cm2);

CF1 = weight unit conversion factor (0.001 mg/μg);

TC = transfer coefficient (cm2/hr); and

ET = exposure time (hr/day).

and

TTRt = AR * FAR * (1-FD)

t

* CF2 * CF3

where:

TTRt = turf transferable residue on day "t" (μg/cm2);

AR = application rate (lbs ai/ft2or lb ai/acre);

FAR = fraction of ai retained on turf (unitless);

FD = fraction of residue that dissipates daily (unitless);

t = post-application day on which exposure is being assessed;

CF2= weight unit conversion factor (4.54 x 108μg/lb); and

CF3 = area unit conversion factor (1.08 x 10-3ft2/cm2or 2.47 x 10-8acre/cm2).

Absorbed dose, normalized to body weight, are calculated as:

BW

E AF D*



where:

D = dose (mg/kg-day);

E = exposure (mg/day); 

AF = absorption factor (dermal); and

BW = body weight (kg).

Table A-5: Turf (Mowing) – Inputs for Residential Post-application Dermal Exposure 

Algorithm Notation Exposure Factor

(units) Point Estimate(s)

AR Application rate

mass active ingredient per unit area

0.446 lb/A

FAR

Fraction of AR as 

TTR following 

application

L/WP/WDG 0.01

Granules 0.002

FD

Daily residue 

dissipation

L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient Adult 5,500
Page 59 of 59

Table A-5: Turf (Mowing) – Inputs for Residential Post-application Dermal Exposure 

(cm2/hr) Children 11 < 16 years 

old 4,500

ET Exposure time 

(hours per day) 1

BW Body Weight 

(kg)

Adults 80

Children 11 < 16 years 

old 57

L/WP/WDG = liquid/wettable powder/water dispersible granule