### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460



### Date:

Subject: May 8

, 2013 OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION



### Fluopicolide and BAM. Occupational and Re sident i a l Exposure Assessmen t for Proposed Ame nded Use on Com.

PC Code : 027 41 2,027 4 02

Dec ision No

. : 471299 DP Barcode: D41 0970 Registration No .: 59639-140 Regulatory Action: Section 3

Cas e No.: N A Pe tition N o

. : NA

Risk Assessment Type: Occupatio n al / R esi dential Exposu re Assessment

TXR No.:NA CAS No.: 239110-15-7

40 CFR : 1 80.627 MRIDNo.: NA



### From :

Through:

To:

Introduction Alexandra L aMay, Bio logi st

Ris k Assessment Branch VII

# ::~:,:::::::ion**(75 09P** **) ~** 

M i chael Metzger

, Chief

. Risk Assessmen t Branch V

Hea l th Effects Division (75 09 )

and

Kristin Rury, Biologist

# ,fJ~ Aaron Niman, P HS 

# c::{_';:j_ 

# L0

Exposure Science Advisory Co mmitt ee ( Ex poSAC) 

### I HED

Tony K ish! D om i nic Schuler

Fun g i c ide Br anch Regi stration Division (7505P)

T h e Registration Division (RD) requested that the Hea l th Ef f ects Division (HED) conduct an

exposure and risk assessme nt for the proposed redu ct ion of plant back i n terval on com

. There is

no occupat i onal exposure associated wit h the petition; h owever, resi dential exposures h ave bee n
reassessed in thi s memorandum to be used for agg r egate assess men t.

Page I of31

### It i s HED policy to use the best available data to assess exposure. Severa l sources of generic

data were u sed in thi s a ssessment as surrogate data i n the absence of chemica l -s p ecific data

, including the Residential SOPs

. Some of these data are proprietary, and subject to the data protection provi s ions of the Federal Ins ec ticide, Fun g icide

, and Rodenticide Act (F I FRA).

Note: 

### This memorandum was reviewed by the Exposure Science Advisory Committee (ExpoSAC) on Apri l 4, 2013.

P age 2 of3 1Page 3 of 31 

### Table of Contents

1.0 Executive Summary

................................ ................................ ................................ ............. 4

2.0 Risk Assessment Conclusions and Recommendations

................................ ........................ 5

2.1 Summary of Risk Estimates

................................ ................................ ............................. 5

2.2 Label Recommendations from Occupational Assessment

................................ ............... 5

2.3 Label Recommendations from Residential Assessment

................................ .................. 5

2.1 Data Deficiencies and Requirements

................................ ................................ ............... 5

3.0 Hazard Characterization

................................ ................................ ................................ ....... 6

4.0 Use Profile

................................ ................................ ................................ ........................... 9

5.0 Residential Ex posure and Risk Estimates

................................ ................................ ............ 9

5.1 Residential Handler Exposure/Risk Estimates

................................ ................................ . 9

5.2 Residential Post

- application Exposure/Risk Estimates

................................ .................. 13

5.3 Combined Residential Risk Estimates (Multiple Exposure Scenarios)

......................... 16

5.4 Residential Risk Estimates for Use in Aggregate Assessment

................................ ...... 16

5.5 Spray Drift

................................ ................................ ................................ ...................... 19

5.6 Residential Bystander Post

- Application Inhalation Exposure

................................ ....... 19

6.0 Occupational Exposure and Risk Estimates

................................ ................................ ...... 20 Appendix A. Summary of Residential Non

- cancer Algorit hms

................................ .................. 21Page 4 of 31



### 1.0 Executive Summary

Fluopicolide is formulated as a liquid/suspension concentrate and is registered for use on a wide variety of food crops. Fluopicolide is also registered for use on non

- agricultural sites such as ornamental plants, ornamental trees, lawns, recreational areas, parks, golf courses, athletic fields,

commercial and industrial areas.

BAM ( 2,6

- dichlorobenzamide ; PC code 027402 )

, the toxic degradat e/metabolite of fluopicolide is also a degradate/metabolite of the herbicide dichlobenil (2, 6

- dichlorobenzonitrile; PC code

027401 ). The risk from exposures to BAM through the use of both dichlobenil and fluopicolide is assessed separat ely from either of these active ingredients because it has its own toxicity database, toxic effects and points of departure.

Valent has proposed an inadvertent residue tolerance on corn due to a proposed reduction in plant back interval (PBI) from 18 mo nths to 30 days on the label for V

- 10161 4 SC (EPA Reg.

No. 59639

- 140). The proposed change in use pattern will not result in occupational exposure, as no application is made to corn.

F lu opicolide has low acute toxicity via oral, dermal and inhalation routes of exposure.

Flu opicolide is not a dermal sensitizer, primary eye irritant, or primary skin irritant. T he rabbit developmental and rat chronic/carcinogenicity studies were considered co

- critical for endpoint

selection for all routes ( di etary , incidental oral, dermal and inhalation) and durations of exposure (with the exception of acute exposures). The Agency considers it appropriate to reduce the Food Quality Protection Act (FQPA) safety f actor to 1X for fluopicolide.

For BAM, the 90

- d ay oral toxicity study in rat was chosen for the incidental oral endpoint selection for all exposure durations and a dermal toxicity study in the mouse ( using dichlobenil ) was chosen for dermal endpoint selection for all exposure durations. T he 10X FQPA s a fety

f actor has been retained as a database uncertainty factor for acute dietary, chronic dietary and incidental oral exposures to account for the lack of a special oral toxicity study with thorough examination of the olfactory system. The FQPA factor has been reduced to 1X for dermal exposures, since the olfactory endpoint of concern has been measured in dermal studies.

There are no proposed residential uses at this time; however, there are existing residential uses

that have been reassessed for the purp ose of updating the aggregate assessment. The update of the residential exposure assessment includes uses on residential turf/lawns, recreational sites such as park and golf courses, and ornamental plants and trees.

An updated residential handler exposure assessment was completed for fluopicolide as it is possible for homeowners to use the products

. All residential handler non

- cancer risk estimates

are not of concern (i.e., MOEs are > LOC) for fluopicolide

. Residential handler exposure was

not evaluated for BAM because the metabolite BAM is believed to form slowly in plants and soil

after the product containing the parent (fluopicolide) has been applied.

An updated residential post

- application exposure assessment was also completed for fluopicolide for use on turf, golf courses, and ornamental plants/ trees. An updated post

- application exposurePage 5 of 31



### assessment was also completed for BAM as t here is a potential for post

- application exposure to

BAM after fluopicolide application to turf and trees. All res idential post

- application risk estimates for fluopicolide and BAM were not of concern for all post

- application exposure

scenarios assessed

.

Based on the Agency's current practices, a quantitative non

- cancer occupational post

- application inhalation exposur e assessment was not performed at this time. If new policies or procedures are put into place, the Agency may revisit the need for a quantitative occupational post

- application inhalation exposure assessment for fomesafen and/or BAM

.

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 the Residential

SOP s , 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 website 1



### .

2.0 Risk Assessment Conclusions and Recommendations

2.1 Summary of Risk Estimates

All residential handler non

- cancer risk estimates are not of concern for fluopicolide. Combined

dermal and inhalation MOEs for residential handlers range from 1,900 (handler applying liquid to lawns and trees with backpack sprayer) to 45,000 (handlers applying liquid to lawns with sprinkler can).

All residential post

- application risk estimates for fluopicolide and BAM were not of concern for all post

- application exposure scenarios assessed. The recommended residential exposure s for use in the aggregate assessment for fluopicolide can be found in Table 5.4.1

. The recommended residential exposure for use in the adult aggregate ass essment for BAM can be found in Table

5.4.2

.

2.2 Label Recommendations from Occupational Assessment

Not applicable.

2.3 Label Recommendations from Residential Assessment

None.

2. 1 Data Deficiencies and Requirements

1 http://www.epa.gov/pesticides/science/handler

- exposure

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

- app

- exposure

- data.htmlPage 6 of 31



### Turf Transferable Residue (TTR): In accordance with the updated Part 158 data requirements (2007), a TTR study is required for all occupational (e.g., sod farms, golf courses, parks, and recreational areas) or residential turf uses. As part of the recent revision to the Health Effects Division’s 2012 Standard Operating Procedures for Residential Pesticide Exposure Assessment

, HED analyzed all available data and selected new liquid and granular default values for the

fraction of the application rate available for transfer after a turf ap plication (F AR 

### )

. 2 

### These

defaults are 1% for formulations applied as liquids (i.e., emulsifiable concentrates, liquids, wettable powders, dry flowables, etc.) and 0.2% for granular formulations. Of the available TTR studies submitted to the Agency, the ma ximum F AR 

### value seen using a liquid product was 6.1 % or 6.1 times higher than the default residue transfer value. The maximum F AR 

### value seen in a TTR study using a granular product was 0.69% or 3.5X the default residue transfer value. Therefore, for both liquid and granular formulations, a calculated MOE of approximately 10 times higher than the level of concern ( e.g ., an MOE > 1,000 if the LOC = 100 ) using the default residue transfer values would provide an adequate margin of safety for any potentially higher

residues seen in a chemical

- specific TTR study ( Guidance for Requiring/Waiving Turf Transferrable Residue (TTR) and Dislodgeable Foliar Residue (DFR) Studies . 6/7/2012, Exposure Science Advisory Council ).

A TTR study is required for fluopicolide at this time since the dermal MOE s are less than 10

times the LOC based on default values for the fraction of application rate available for transfer after a turf application.

A TTR study is not required for BAM at this time since the dermal MOEs are not less than 10

times the LOC of 100 and incidental oral are not less than 10 times the LOC of 1000.

Dislodgeable Foliar Residue (DFR): In accordance with the updated Part 158 data requirements (2007), one or more DF R stud ies are required when a pesticide has residential or occupational

uses t hat could result in post

- application dermal exposure. As part of the recent revision to the Health Effects Division’s 2012 Standard Operating Procedures for Residential Pesticide Exposure As sessment , HED analyzed a number of DFR studies and selected a new default value for the fraction of the application rate available to be dislodged after a foliar application (F AR 

### ).

This default value is 25 % and is based on an analysis of 19 DFR studies wh ere the F AR 

### value ranged from 2% to 89%. This value is recommended for use in both residential and occupational postapplication assessments. Of the analyzed DF R studies, the maximum F AR 

### value seen was

89% or 3.6 times higher than the default residue tran sfer value. Therefore, the HED has decided that a calculated MOE of approximately 4 times higher than the level of concern (e.g., an MOE >

400 if the LOC = 100) using the default dislodged residue values would provide an adequate margin of safety for any potentially higher residues seen in a chemical

- specific DFR study ( Guidance for Requiring/Waiving Turf Transferrable Residue (TTR) and Dislodgeable Foliar Residue (DFR) Studies . 6/7/2012, Exposure Science Advisory Council ). DFR data are available

for fluopicolide . This data requirement is satisfied. A DFR study is not required for BAM at this

time.

3 .0 Hazard Characterization

2 http://www.epa.gov/pesticides/science/residential

- exposure

- sop.htmlPage 7 of 31



### Acute Toxicity Fluopicolide has demonstrated low to moderate acute toxicity by the oral (Toxicity Category III), dermal (IV) and inhalation routes (IV). It is not an eye or dermal irritant and is not a dermal

sensitizer.

Toxicological PODs Used for Risk Assessment

Table 3.0.1 provides a summary of the toxicological endpoints for fluopicolide human health risk

assessment. T able 3.0.2 provides a summary of the toxicological endpoints for BAM human

health risk assessment.

Table 3.0. 1. Summary of Toxicological Doses and Endpoints for Fluopicolide for Use in Human Health Risk

Assessments

Exposure/

Scenario Point of

Departure Uncertainty/

FQPA Safety

Factors RfD, PAD,

Level of

Concern for

Risk

Assessment Study and Toxicological Effects

Incidental

Oral

Intermediate

Term (1

- 6 months) Maternal

NOAEL = 20 mg/kg/day UF A =10x

UF H =10x FQPA SF = 1X MOE = 100

(occupational)

MOE = 100 (residential) Developmental Toxicity Study in Rabbits

LOAEL (maternal) = 60 mg/kg/day based on death, abortions/ premature deliveries, decreased food consumption and body weight gain.

Dermal Short

Intermediate

and Long

Term (1

- 30 days, 1

- 6 months, and >6 months) Maternal

NOAEL = 20 mg/kg/day UF A =10x

UF H =10x FQPA SF = 1X

37% dermal absorption MOE = 100

(occupational)

MOE = 100 (residential) Developmental Toxicity Study in Rabbits

LOAEL (maternal) = 60 mg/kg/day based on death, abortions/ premature deliveries, decreased food consumption and body weight gain.

Co

- critical: Chronic/Oncogenicity Study

in Rats NOAEL = 31.5 mg/kg/day. LOAEL = 109.4 mg/kg/day based on decreased body weight gain and increased thyroid weight and increased incidence of thyro id lesions.

Inhalation

Short

Intermediate

and Long

term (1

- 30 days, 1

- 6 months, and >6 months) Maternal

NOAEL = 20 mg/kg/day UF A =10x

UF H =10x FQPA SF = 1X

(inhalation and oral toxicity are

assumed to be equivalent) MOE = 100

(occupational)

MOE = 100 (residential) Developmental Toxicity Study in Rabbits

LOAEL (maternal) = 60 mg/kg/day based on death, abortions/ premature deliveries, decreased food consumption and body weight gain.

Co

- critical: Chronic/Oncogenicity Study

in Rats NOAEL = 31.5 mg/kg/day. LOAEL = 109.4 mg/kg/day based on decreased body weight gain and increased thyroid weight and increased incidence of thyroid lesions. Cancer (oral, dermal, inhalation) Classification: “Not Likely to be Carcinogenic to Humans”

.

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. NOAELPage 8 of 31

= no ob served adverse effect level. LOAEL = lowest observed adverse effect level. UF = uncertainty factor. UF A = extrapolation from animal to human (interspecies). UF H = potential variation in sensitivity among members of the human population (intraspecies). FQPA SF = FQPA Safety Factor. PAD = population adjusted dose (a = acute, c = chronic). RfD = reference dose. MOE = margin of exposure. LOC = level of concern. N/A = not applicable.

Table 3.0.2. Summary of Toxicological Doses and Endpoints for 2,6

- Dichlorobenzamide (BAM) for Use in

Human Health Risk Assessments Exposure Scenario Point of

Departure Uncertainty/

FQPA Safety

Factors RfD, PAD,

Level of

Concern for

Risk

Assessment Study and Toxicological

Effects

Incidental Oral

Short

- and

Intermediate

- Term (1

- 30 days and 1

- 6 months) NOAEL = 14

mg/kg/day UF A = 10X

UF H = 10X FQPA SF = 10X (includes UF DB ) Residential

LOC for MOE

= 1000 90

- day oral (rat) LOAEL = 49

mg/kg/day based on decreased body weight gain (M) and

reduced skeletal muscle tone (day 4 only in males; days 91 and 92 only in females)

Dermal

Short

- , Intermediate

- , and Long

- Term (1

- 30 days, 1

- 6 months, and >6 months) NOAEL = 25

mg/kg/day UF A = 10X

UF H = 10X

FQPA SF = 1X (residential uses only) Residential and

Occupational

LOC f or MOE

= 100 5

- day dermal using dichlobenil

(mouse; literature study) LOAEL = 50 mg/kg/day based on olfactory epithelial damage

Inhalation

Short

- , Intermediate

- , and Long

- Term (1

- 30 days, 1

- 6 months, and >6 months) NOAEL = 3.1

mg/kg/day UF A = 10X

UF H = 10X

FQPA SF = 1X (residential uses only) Residential and

Occupational

LOC for MOE

= 100 28

- day inhalation using

dichlobenil (rat) LOAEL = 5.5 mg/kg/day based on nasal degeneration

Cancer Classification: u nclassified; parent herbicide dichlobenil classified as “Group C, possible

human carcinogen” with RfD approach utilized for quantification of human risk Abbreviations: UF = uncertainty factor, UF A = extrapolation from animal to human (interspecies), UF H = potential variation in sensitivity among members of the human population (intraspecies), FQPA SF = FQPA Safety Factor,

UF L = use of a LOAEL to extrapolate a NOAEL, UF DB = to account for the absence of key data, NOAEL = no observed adverse effect level, LOAEL = lowest observed adverse effect level, RfD = reference dose (a = acute, c = chronic), PAD = population adjusted dose, MOE = margin of exposure, LOC = level of concern, N/A = Not Applicable



### Absorption A dermal absorption factor of 37 % was used for t he exposure assessment for fluopicolide . 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.

For BAM, s ince the short

- and intermediat e

- term dermal and inhalation PODs were based on

route

- specific toxicity studies, no absorption factors were necessary to estimate exposure.

Body Weight

Since the dermal and inhalation PODs for fluopicolide are based on developmental and/or fetal effects, the body weight appropriate for dermal and inhalation assessments is 69 kg.Page 9 of 31



### For BAM, t he standard body weight for the general population (80 kg) was used for all exposure scenarios covered in this risk assessment since the endpoints selected were not deve lopmental

and/or fetal effects.

4 .0 Use Profile

Valent has proposed an inadvertent residue tolerance on corn due to a proposed reduction in plant back interval (PBI) from 18 months to 30 days on the label for V

- 10161 4 SC (EPA Reg.

No. 59639

- 140) . The proposed change in use pattern will not result in occupational exposure, as no application is made to corn.

5 .0 Residential Exposure and Risk Estimates

There are no proposed residential uses at this time; however, there are existing residential uses

that have been reassessed in this document to reflect updates to HED’s 2012 Residential SOPs 3


### along with policy changes for body weight assumptions. The revision of residential exposures will impact the human health aggregate risk assessment for fluopicolide

.

There are products with uses on residential turfgrass and recreational sites. The products may be applied to turf at rates up to 0.27 lb ai/A, for two applications at an in terval of 14 days. There are

also uses on ornamental plants and trees with appli cation rates up to 0.54 lb ai/A.

Residential handler exposure was not evaluated for BAM because the metabolite BAM is believed to form slowly in plants and soil after the product containing the parent (fluopicolide) has been applied. However, t here is a potential for dermal (adults and children) and incidental

non

- dietary ingestion (for children) exposure to BAM during post

- application activities on fluopicolide

- treated turf and trees

.

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 a re addressed somewhat differently by HED as homeowners are assumed to complete all elements of an application without use of any protective equipment.

It is possible for residential handlers to apply these products ; therefore, residential handlers may

re ceive short

- term dermal and inhalation exposure to fluopicolide when applying the product

.

The quantitative exposure/risk assessment developed for residential handlers is based on the following scenarios: Application of liquid formulation to turf/lawn s and gardens/ trees using handheld equipment

3 Available: http://www.epa.gov/pesticides/science/residential

- exposure

- sop.htmlPage 10 of 31



### Residential handler exposure was not evaluated for BAM because the metabolite BAM is believed to form slowly in plants and soil after the product containing the parent (fluopicolide) has been applied.

Residential Handler Exposure Data and Assumptions 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 : Fluopicolide may be applied to turf at a maximum application rate of 0.27 lb ai/A and applied to ornamental plants /trees at a rate up to 0.54 lb ai/acre.

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 SOPs 4



### .

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 Non

- Cancer 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 SOPs 5



### .

Combining Exposures/Risk Estimate s:
D ermal and inhalation risk estimate s were combined in this assessment, since the toxicological effects for these exposure routes were the same . Dermal and inhalation risk estimate s were combined using the following formula:

Total MOE = Point of Departure (mg/kg/day) ÷ Combined D ermal + I nhalation dose (mg/kg/day)



### Summary of Residential Handler Non

- Cancer Exposure and Risk Estimates

All residential handler non

- cancer risk estimates are not of concern ( i.e., MOEs are > 100 ). Combined dermal and inhalation MOEs for residential handlers range from 1,900 (handler applying liquid to lawns and trees with backpack sprayer) to 45,000 (handlers applying liquid to lawns with sprinkler can).

4 Available: http://www.epa.gov/pesticides/science/r esidential

- exposure

- sop.html

5 Available: http://www.epa.gov/pesticides/science/residential

- exposure

- sop.htmlPage 11 of 31

Table 5.1.1. Residential Handler Non

- cancer E xposure and Risk Estimates for Fluopicolide

.

Exposure Scenario Level of

Concern Dermal Unit

Exposure (m g/lb ai) Inhalation

Unit Exposure (m g/lb ai) Maximum

Application

Rate 1 Area Treated or

Amount

Handled Daily 2 Dermal Inhalation Total

Dose (mg/kg/day) 3 MOE 4 Dose (mg/kg/day) 5 MOE 6 MOE 7

Mixer/ L oader/Applicator

Gardens/Trees, Liquid, Manually

- pressurized

handwand

100 63 0.018 0.0025 lb ai/gallon 5 gallons 0.0042 4

, 700 0.0000033 6,100,000 4

, 700

Lawns/Turf, Liquid, Manually

- pressurized

handwand 0.003 lb ai/gallon 5 gallons 0.0051 3900 0.0000039 5,100,000 3,900

Gardens/Trees, Liquid, Manually

- pressurized

handwand 0.0000125 lb

ai/ft 2 1200 ft 2 0.0051 3,900 0.0000039 5,100,000 3,900

Gardens/T rees, Liquid,

Hose

- end Sprayer/Sprinkler Can

58 0.0014 0.0000125 lb

ai/ft 2 1200 ft 2 0.0047 4,300 0.0000003 66,000,000 4,300

Gardens/T rees, Liquid,

Hose

- end Sprayer 0.0025 lb ai/gallon 11 gallons 0.0086 2,300 0.00000056 36,000,000 2,300

Gardens/T rees, Liquid, Sprinkler Can 0.0025 lb ai/gallon 5 gallons 0.0039 5,100 0.00000025 79,000,000 5,100

Lawns/Tur f, Liquid,

Hose

- end Sprayer 13.4 0.022 0.27 lb ai/acre 0.5 acres 0.0097 2,100 0.000043 460,000 2,100

Lawns/Tur f, Liquid, Sprinkler Can 0.0000062 lb

ai/ft 2 1000 ft 2 0.00045 45,000 0.000002 10,000,000 45,000

Gardens/T rees, Liquid, Backpack

130 0.14 0.0000125 lb

ai/ft 2 1200 ft 2 0.01 1,900 0.00003 660,000 1,900

Gardens/T rees, Liquid, Backpack 0.0025 lb ai/gallon 5 gallons 0.0087 2,300 0.000025 790,000 2,300

Lawns/Tur f, Liquid, Backpack 0.003 lb ai/gallon 5 gallons 0.01 1,900 0.00003 660,000 1,900

1 Based on registered label s

. Application rate for turf is 0.27 lb ai/acre , or 0.0000062 lb ai/ft 2

. The label states that a volume of 2 gallons treats 1000 sq. ft, which is equivale nt to 87 gallons per acre. Therefore, the turf rate is 0.003 lb ai/gallon. Application rate for ornamental plants is 0.54 lb ai/acre , which is equivalent to 0.0000125 lb a i/ft 2

. The label states that 100 gallons treats 20,000 sq ft, which is equivalen t to 218 gallons per acre. Therefore, the ornamental plant rate is 0.0025 lb ai/gallon.

2 Based on HED’s 2012 Residential SOPs ( http://www.epa.gov/pesticides/science/residential

- exposure

- sop.html ).Page 12 of 31

3 Dermal Dose = Dermal Unit Exposure (mg/lb ai) × Application Rate (lb ai/acre or gal) × Area Treated or Amount Handled (A /day or gallons/day) × Derma l Absorption Factor (%) ÷ Body Weight (kg).

4 Dermal MOE = Dermal NOAEL (mg/kg/day) ÷ Dermal Dose (mg/kg/day).

5 Inhalation Dose = Inhalation Unit Exposure (mg/lb ai) × Application Rate (lb ai/acre or gal) × Area Treated or Amount Handled (A /day or gallons /day) ÷ B ody W eight (kg).

6 Inhalation MOE = Inhalation NOAEL (mg/kg/day) ÷ Inhalation Dose (mg/kg/day).

7 Total MOE = NOAEL (mg/kg/day) ÷ (Dermal Dose + Inhalation Dose)Page 13 of 31



### 5

. 2 Residential Post

- application Exposure/Risk Estimates

There is the potential for post

- application exposure to fluopicolide for individuals exposed as a result of being in an environment that has been previously treated with fluopicolide

. T here is also a potential for exposure to BAM during post

- application a ctivities on fluopicolide

- treated

turf and plants

.

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 to treated turf. Adult and children (11 to < 16 years old) dermal exposure to treated turf during mowing and golfing activities. Children (6 to < 11 years old) dermal expo sure to treated turf during golfing activities. Adult 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 trees.

The lifestages selected for each post

- application scenario are based on an analysis provided as an Appendix in the 2012 Residential SOPs 6 

### . These lifestages are not the only lifestages that could be potentially exposed for these post

- application scenarios; how ever, 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

SOPs 6



### .

TTR for flu o

p i colide

Because turf transferable residue (TTR) data were not available fluopicolide , turf residues were estimated using default assumptions.

DFR data for fluopicolide

A dis lodgeable foliar residue (DFR) study for fluopicolide use on leaf lettuce was previously

submitted (MRID 46708641) for use in assessing post

- application activities. This study is considered to be acceptable. The target application rate for each applicati on was 0.119 lb ai/A ; 3 applications were completed at an approximate re

- treatment interval of 5 days . The total target

6 Available: http://www.epa.gov/pesticides/science/residential

- exposure

- sop.htmlPage 14 of 31



### application was 0.3575 lb ai/A. A linear regression analysis was conducted using the natural logarithm of the individual DFR values.

Table 5.2. 1 . Summary of TTR data and Regression Analysis (MRID 46708641 )

Treatment Pennsylvania California

Peak measured TTR ( μg/cm 2 ) 0.418 0.446

Time Interval Of Peak TTR 8hr after treatment 1DAT

Predicted Day 0 Residue (μg/cm 2 ) 0.363 0.358

Slope

- 0.27

- 0.145

Predicted Half

- life (days) 2.54 4.77

R 2 0.972 0.767



### The maximum predicted day 0 residue from the DFR study is 0.36 μg/cm 2



### . For risk assessment purposes, this residue value is scaled from the study application rate of 0.12 lb ai/acre to the maximum registered application rate on ornamental trees of 0.54 lb ae/acre; the residue value for

risk assessment is 1.62 μg/cm 2 

### on day 0

.

Residue Data for BAM

Residential post

- application scenarios were previously assessed for BAM (D345920 , K. O’Rourke, 10/9/07 ). The same BAM residue assumptions from the previous assessment are used

for this assessment ; a description of the BAM residue assumptions is copied below

.

Grape, lettuce, and potato metabolism data indicate that the majority of total radioactive residue (TRR) was located on the surface of foliage and fruit samples (D327026, A. Acierto, 8/20/ 07).

Th e parent fluopicolide was the primary residue identified in grape fruit, lettuce leaves, and

potato foliage and tubers, accounting for 51

- 98% TRR. The metabolite BAM was found in foliarly

- treated grape s ( fruit ), lettuce leaves , and potato foliage at <4% TRR. For the purposes of this exposure assessment

, it was conservatively assumed that the surface residues of BA M are transferable, and that they are present at 4% of the initial amount of parent fluopicolide. These

residues were used in conjunction with the DFR data to provide protective residue estimates for

BAM on ornamentals. Because turf transferable residue (TTR) data were not available, turf residues were estimated using standard assumptions (in addition to BAM surface residue data from the metabolism studies). Post

- application exposures are typically estimated for “Day 0" exposure (i.e., the day of applica tion). However, BAM is a metabolite/degradate which forms slowly; therefore, the exposures were estimated assuming that BAM is present at 4% of residue (which was actually measured on day 21 after application) for “Day 0” in order to provide a protective assessment.

Additionally , the drinking water assessment (D340773, J. Angier, 8/29/07) indicates that, based on aerobic soil metabolism data, BAM may be present at up to 40% of application rate; this

value was used to estimate residues for the incidental soil ingestion scenario.

Exposure Duration:

Residential post

- application exposure is expected to be short

- term in duration.Page 15 of 31



### Residential Post

- application Non

- Cancer Exposure and Risk Equations The algorithms used to estimate residential post

- application exposure and dose can be found in Appendix A and/or the 2012 Residential SOPs 6



### .

Combi ning 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 associa ted with the points of departure is similar across routes. Since dermal and incidental oral exposure routes share a common toxicological endpoint for fluopicolide , risk estimates have been combined for those routes. The incidental oral scenarios (i.e., hand

- to

- mouth and object

- to

- mouth) should be considered inter

- related and it is likely that they occur interspersed amongst each other across time. Combining all of these scenarios with the dermal exposure scenario would be overly

- conservative because of the conservative nature of each individual assessment. Therefore, for fluopicolide, the post

- application exposure scenarios that were combined for children 1 < 2 years old are the dermal and hand

- to

- mouth scenarios.

This combination is considered a prote ctive estimate of children’s exposure to pesticides used on turf

.

For BAM, the dermal and incidental oral exposure routes do not share a common toxicological endpoint, therefore, risk estimates have not been combined for these exposure routes.

Summary of Residential Post

- application Non

- Cancer Exposure and Risk Estimates All residential post

- application risk estimates for fluopicolide and BAM were not of concern (MOEs > LOCs) for all exposure scenarios and all lifestages.

Table 5

. 2 .2

. Residential Post

- application Non

- cancer Exposure a nd Risk Estimates for Fluopicolide

.

Lifestage Post

- application Exposure

Scenario Application

Rate 1 Dose

(mg/kg/day) 2 MOEs 3 Combined Routes (X indicates included in Combined MOE) Combined MOEs

Use Site Route of Exposure

Adult Turf Dermal

– High

Contact

0.27 lb

ai/acre for turf, 0.54 lb

ai/acre for garden/ trees 0.04 3 460

N/A N/A Garden Dermal 0.161 120

Turf Dermal

- Mowing 0.00089 23,000

Dermal

- Golfing 0.0034 5,900

11 to < 16 year

old Dermal

- Mowing 0.00088 23,000

Dermal

- Golfing 0.0034 5,800

6 to < 11 year

old Dermal

- Golfing 0.0040 5,000

Garden Dermal 0.095 210

1 to < 2 year

old Turf Dermal 0.07 4 270 X 260 Hand

- to

- Mouth 0.0041 4,900 X
Object

- to

- Mouth 0.00012 160,000

N / A N/A Incidental Soil Ingestion 9.1E

- 06 2,200,000

1 Based on registered label

. 2 Dose (mg/kg/day) equations can be found in Appendix A.

3 MOE = POD (mg/kg/day) ÷ Dose (mg/kg/day).Page 16 of 31

4 Combined MOE = 1 ÷ (1/dermal MOE) + (1/inhalation MOE) + (1/incidental oral MOE), where applicable.

Table 5.2.3

. Residential Post

- application Non

- cancer Exposure a nd Risk Estimates for BAM.

Lifestage Post

- application Exposure

Scenario Application

Rate /

Residue 1 Dose

(mg/kg/day) 2 MOEs 3 Combined Routes (X indicates included in Combined MOE) Combined MOEs

Use Site Route of

Exposure

Adult Turf Dermal

– High

Contact

0.27 lb

ai/acre for turf, 0.54 lb

ai/acre for garden/ trees

BAM

residue adjusted to

4% 0.0041 6,200

N/A N/A Garden Dermal 0.015 1,700

Turf Dermal

- Mowing 0.000083 300,000

Dermal

- Golfing 0.00032 79,000

11 to < 16 year

old Dermal

- Mowing 0.000095 260,000

Dermal

- Golfing 0.00037 67,000

6 < 11 year old Dermal

- Golfing 0.00044 57,000

Garden Dermal 0.01 2,400

1 to < 2 year

old Turf Dermal 0.008 3,100

N/A N/A Hand

- to

- Mouth 0.0002 85,000

Object

- to

- Mouth 0.000005 2,800,000

Incidental Soil Ingestion BAM

adjusted to

40% in soil 0.0000038 3,800,000

1 BAM TTR and DFR adjusted by 0.04 (to adjust for amount of BAM, based on plant metabolism data)

BAM Soil residue adjusted by 0.4 ( to adjust for amount of BAM, based on soil metabolism data)

2 Dose (mg/kg/day) equations can be found in Appendix A.

3 MOE = POD (mg/kg/day) ÷ Dose (mg/kg/day).

4 Combined MOE = 1 ÷ (1/dermal MOE) + (1/inhalation MOE) + (1/incidental oral MOE), where applicable.



### 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 ornament al 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 est imates that are recommended for use in the agg regate assessment for fluopicolide. The recommended residential exposure for use in the adult aggregate assessment reflects dermal post

- application exposure to treated gardens

. The recommended residential expos ure for use in the children (11 to < 16 years old) aggregate assessment reflects dermal post

- application exposure from golfing. The recommended residential exposure for use in the children (6 to < 11 years old)Page 17 of 31



### aggregate assessment reflected dermal post

- ap plication exposure to treated gardens. The recommended residential exposure for use in the children ( 1 to <2 years old ) aggregate assessment reflects dermal and hand

- to

- mouth exposures from post

- application turf scenario (i.e., post

- application exposure to treated turf)

.Page 18 of 31

Table 5

. 4 .1. Recommendations for the Residential Exposures for the Fluopicolide Aggregate Assessment

. 1

Lifestage Residential Handler Residential Post

- application

Dose (mg/kg/day) 2 MOE 3 Dose (mg/kg/day) 4 MOE 5

Dermal Inhalation Total Dermal Inhalation Total Dermal Inhalation Oral Total Dermal Inhalation Oral Total

Short

- Term

Adult 0.0 1 0.00 00 3 0.0 1 0

- - 1,9 00 0.161 N/A N/A 0.161 120 N/A N/A 120

Child (11 to < 16 years old)

N/A 0.0034 N/A N/A 0.003

4 5,800 N/A N/A 5,800

Child (6 to < 11 years old) 0.095 N/A N/A 0.095 210 N/A N/A 210

Child (1 to < 2 years old) 0.074 N/A 0.0041 0.078 270 N/A 4,900 260

1 Bolded risk estimates should contribute to the residential exposure portion of the aggregate assessment.

2 Residential Handler Dose = the highest handler dose for each applicable lifestage of all scenarios assessed

. Total = dermal + inhalation.

3 Residen tial Handler MOE = the MOEs associated with the highest doses identified. Total = 1 ÷ (1/Dermal MOE) + (1/Inhalation MOE).

4 Residential Post

- application Dose = the highest post

- application dose for each applicable lifestage of all scenarios assessed. Total = dermal + inhalation + incidental oral, where applicable.

5 Residential Post

- application MOE = the MOEs associated with the highest doses identified. Total = 1 ÷ (1/Dermal MOE) + (1/Inhalation MOE) + (1/Incidental oral MOE).Page 19 of 31



### 5

. 5 Spray Drift

Although there are no agricultural applications associated with this action , there are registered uses of fluopicolide on agricultural crops.

Spray drift is always a potential source of exposure to residents nearby to spraying operations. This is particularly the case with aerial application, but, to a lesser extent, could also be a potential source of exposure from the ground application method employed for fluopicolide . The Agency has been working with the Spray Drift Task Force, EPA Reg ional 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 7 

### . The Agency has completed its evaluation of the new database submitted by the Spray Drift Task Force, a membership of U.S. pesticide registrants, and is developing a policy on how to appropriately apply the data and the AgDRIFT computer model to its risk assessments for pesticides applied by air, orchard airblast and ground hydraulic methods. After the policy is in place, the Agency may impose further refinements in spray drift management practices to reduce

off

- target drift with specific products with s ignificant risk estimates associated with drift.

It is noted that the 0.27 lb ai/acre application rate for turf was modeled to estimate post

application residential exposure of children. As this rate is equal to or higher than many of agricultural applic ation rates, this scenario is protective of any exposure of farm children via spray drift from agricultural fluopicolide applications.

5

. 6 Residential Bystander Post

- Application Inhalation Exposure

Although there are no agricultural applications associa ted with this action, there are registered uses of fluopicolide on agricultural crops.

Based on the Agency's current practices, a quantitative post

- application inhalation exposure

assessment was not performed for fluopicolide at this time primarily beca use of the low acute inhalation toxicity (Toxicity Category IV) and low vapor pressure ( 6 x 10 - 9 

### mm Hg at 25° C )

. However, 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 8 

### . The Agency is in the process of evaluating the SAP report and may, as appropriate, develop policies and procedures to identify the need for and, subsequently, the way to incorporate post

- application inhalation exposure into the Agency's risk assessments . If new policies or procedures are developed, the Agency may revisit the need for a quantitative post

application inhalation exposure assessment for fluopicolide

.

7 Available: http://www.epa.gov/opp00001/factsheets/spraydrift.htm

8 Available: http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.htmlPage 20 of 31



### Although a quantitative residential post

- application inhalation exposure assessment was no t performed, an inhalation exposure assessment was performed for handlers. This exposure scenario is representative of a worst case inhalation exposure and should be considered protective of most post

- application inhalation exposure scenarios.

6 .0 Occup ational Exposure and Risk Estimates

There are no agricultural or occupational applications associated with this action. Therefore, there is no potential occupational exposure associated with the proposed change in use pattern.Page 21 of 31



### Appendix A. Summary of Residential Non

- cancer Algorithms

Residential Non

- cancer Handler Algorithms

Dermal and Inhalation Handler Exposure Algorithm Daily dermal and inhalation exposure (mg/day) for residential pesticide handlers, for a given

formulation

- application method comb ination, is estimated by multiplying the formulation

application method

- specific unit exposure by an estimate of the amount of active ingredient handled in a day, using the equation below:

E = UE * AR * A

where:

E = exposure (mg/day); UE = unit exposure (mg/lb ai); AR = application rate (e.g., lb ai/ft 2 

### , lb ai/gal); and A = area treated or amount handled (e.g., ft 2 

### /day, gal/day).

Dermal and/or inhalation absorbed doses normalized to body weight are calculated as:

D = E *AF / BW

where:

D = dose (mg/kg

- day); E = exposure (mg/day); AF = absorption factor (dermal and/or inhalation); and BW = body weight (kg).

Residential Non

- cancer Post

- application Algorithms

Turf/Physical Activities on Turf

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

where:

E = exposure (mg/day);Page 22 of 31



### TTRt = turf transferable residue on day t (μg/cm 2 

### );

C F1 = weight unit conversion factor (0.001 mg/μg); TC = transfer coefficient (cm 2 

### /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 TTR t 

### can be calcula ted using the following

formula:

TTR t 

### = AR * F * (1

- FD) t 

### * CF2 * CF3

where:

TTRt = turf transferable residue on day t (μg/cm 2 

### ); AR = application rate (lbs ai/ft 2 

### or 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 10 8 

### μg/lb); and CF3 = area unit conversion factor (1.08 x 10 - 3 

### ft 2 

### / cm 2 

### or 2.47 x 10 - 8 

### acr e/cm 2 

### ).

Dermal absorbed doses are calculated as:

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) 0.27 lb ae/acre

F Fraction of AR as TTR

following application (if

chemical

- specific data is unavailable) L/WP/WDG 0.01

Granules 0.002

F D Daily residue dissipation

(if chemical

- specific data is unavailable) (fraction) L/WP/WDG 0.1

Granules 0.1

TC Transfer

Coefficient L/WP/WDG Adults 180,000
Children 1 < 2 years old 49,000Page 23 of 31

Table A

- 1 : Turf (Physical Activities)

-- Inputs for Residential Post

- application Dermal Exposure

Algorithm Notation Exposure Factor (units) Point Estimate(s)

(cm 2 /hr) 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 * ( F

M 

### * SA H 

### ) * (ET * N_Replen) * (1

- (1

- SE ) (Freq_HtM/N

- Replen) 

### )]

where:

E = exposure (mg/day); HR = hand residue loading (mg/cm 2 

### ); FM = fraction hand surface area mouthed / event (fraction/event); SAH = typical surface area of one hand (cm 2 

### ); 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

where:

HR = hand residue loading (mg/cm 2 

### );

Fai hands 

### = fraction ai on hands compared to total surface residue from dermal transfer coefficient study (unitless); DE = dermal exposure (mg); and

SA H 

### = typical surface area of one hand (cm 2 

### ).

Dose, normalized to body weight, is calculated as:Page 24 of 31



### 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)

Fai hands Fraction of ai on hands

from dermal transfer coefficient study (unitless) Liquid formulations 0.06

Granular formulations 0.027

DE Dermal exposure (mg) Calculated

SA H Typical surface area of one hand (cm 2 ), children 1 < 2 years old 150

AR Application rate

(mass active ingredient per unit area) 0.27 lb ae/acre

HR Residue available on the hands (mg/cm 2 ) Calculated via (DE * Fai hands )/SA H

F M 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 * SAM O 

### * (ET * N_Replen) * (1

- (1

- SE O 

### ) (Freq_OtM/N_Replen) 

### )]

where:

E = exposure (mg/day); OR = chemical residue loading on the object on day “t” (ug/cm 2 

### ); CF1 = weight unit conversion factor (0.001 mg/μg);

SAM O 

### = area of the object surface that is mouthed (cm 2 

### /event); ET = exposure time (hr/day); N_Replen = number of replenishment intervals per hour (intervals/hour);

SE O 

### = saliva extraction factor (i.e., mouthing removal efficiency); and Freq_OtM = number of object

- to

- mouth contact events per hour (events/hour).Page 25 of 31



### and

OR = AR * F O 

### * CF 2 * CF3

where:

OR = chemical residue loading on the object (μg/cm 2 

### ); AR = application rate (lbs ai/ft 2 

### or lb ai/acre);

F O 

### = fraction of residue available on the object (unitless); CF2 = weight unit conversion factor (4.54 x 10 8 

### μg/lb); and

CF3 = area unit conversion factor (1.08 x 10 - 3 

### ft 2 

### /cm 2 

### or 2.47 x 10 - 8 

### acre/cm 2 

### ).

Dose, normalized to body weight, is calculated as:

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) 0.27 lb ae/acre

F O Fraction of AR as OR following application 1 0.01

SAM O Surface area of object mouthed (cm 2 /event) 10

N_Replen Replenishment intervals per hour (intervals/hour) 4

SE O 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: E = exposure (mg/day);

SRt = soil residue on day "t" (μg/g);Page 26 of 31



### SIgR = ingestion rate of soil (mg/day); and CF1 = weight unit conversion factor (1 x 10 - 6 

### g/μg).

and

SRt = AR * FS * (1

- F D 

### ) t 

### * CF2 * CF3 * CF4

where:

SR t 

### = soil residue on day "t" (μg/g); AR = application rate (lbs ai/ft 2 

### or lb ai/acre); FS = fraction of ai available in uppermost cm of soil (fraction/cm);

F D 

### = fraction of residue that dissipates daily (unitless); T = post

- application day on which exposure is being assessed; CF2 = weight uni t conversion factor (4.54 x 10 8 

### μg/lb); CF3 = area unit conversion factor (1.08 x 10 - 3 

### ft 2 

### /cm 2 

### or 2.47 x 10 - 8 

### acre/cm 2 

### ); and CF4 = soil volume to weight unit conversion factor (0.67 cm 3 

### /g soil).

Dose, normalized to body weight, are calculated as:

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) 0.27 lb ae/acre

FS Fraction of AR available in uppermost 1 cm of soil (unitless) 1

F D Daily residue dissipation (fraction) 0.1

SIgR Soil ingestion rate (mg/day) 50

BW Body weight (kg) Children 1 < 2 years old 11



### Turf/MowingPage 27 of 31



### Post

- application Dermal Exposure Algorithm

– Mowing Exposure resulting from contacting previously treated turf while mowing is calculated as

follows:

E = TTRt * CF1 * TC * ET

where :

E = exposure (mg/day);

TTR t 

### = turf transferable residue on day "t" (μg/cm 2 

### ); CF1 = weight unit conversion factor (0.001 mg/μg); TC = transfer coefficient (cm 2 

### /hr); and ET = exposure time (hr/day).

and

TTRt = AR * F AR 

### * (1

- F

D 

### ) t 

### * CF2 * CF3

where :

TTR t 

### = turf transferable residue on day "t" (μg/cm 2 

### ); AR = application rate (lbs ai/ft 2 

### or lb ai/acre);

F AR 

### = fraction of ai retained on turf (unitless);

F D 

### = 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 10 8 

### μg/lb); and CF3 = area unit conversion factor (1.08 x 10 - 3 

### ft 2 

### /cm 2 

### or 2.47 x 10 - 8 

### acre/cm 2 

### ).

Absorbed dose, normalized to body weight, are calculated as:

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 0.27 lb ae/acre

F AR Fraction of AR as TTR following application L/WP/WDG 0.01

Granules 0.002Page 28 of 31

Table A

- 5 : Turf (Mowing)

– Inputs for Residential Post

- application Dermal Exposure

F D Daily residue dissipation L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient (cm 2 /hr) Adult 5,500

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



### Turf/Golfing

Post

- application Dermal Exposure Algorithm

– Golfing Exposure resulting from contacting previously treated turf while golfing is calculated as follows:

E = TTRt * CF1 * TC * ET

where :

E = exposure (mg/day);

TTR t 

### = turf transferable residue on day "t" (μg/cm 2 

### ); CF1 = weight unit co nversion factor (0.001 mg/μg); TC = transfer coefficient (cm 2 

### /hr); and ET = exposure time (hr/day).

and

TTRt = AR * F * (1

- F D 

### ) t 

### * CF2 * CF3

where :

TTR t 

### = turf transferable residue on day "t" (μg/cm 2 

### ); AR = application rate (lbs ai/ft 2 

### or lb ai /acre); F = fraction of ai retained on turf (unitless);’

F D 

### = 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 10 8 

### μg/lb); and

CF3 = area unit conversion factor (1.08 x 10 - 3 

### ft 2 

### /cm 2 

### or 2.47 x 10 - 8 

### acre/cm 2 

### ).

Absorbed dose, normalized to body weight, is calculated as:Page 29 of 31



### where :
D = dose (mg/kg

- day);

E = exposure (mg/day);

AF = absorption factor (dermal); and

BW = body wei ght (kg).

Table A

- 6 : Turf (Golfing)

– Inputs for Residential Post

- application Dermal Exposure Algorithm

Notation Exposure Factor (units) Point Estimate(s)

AR Application rate (mass active ingredient per unit area) 0.27 lb ae/acre

F Fraction of AR as TTR

following application L/WP/WDG 0.01

Granules 0.002

F D Daily residue dissipation L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient

(cm 2 /hr) Adult 5,300 Children 11 < 16 years old 4,400 Children 6 < 11 years old 2,900

ET Exposure time

(hours per day) Pesticides used on greens, tees, and fairways 4

Pesticides used only on greens

and tees 1

BW Body Weight (kg) Adults 80

Children 11 < 16 years old 57 Children 6 < 11 years old 32 NA = not applicable L/WP/WDG = liquid/wettable powder/water dispersible granule



### Gardens and Trees

Post

- application Dermal Exposure Algorithm Exposure resulting from contacting previously treated gardens and trees 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 = DFR t 

### * CF1 * TC * ET

where :

E = exposure (mg/day);

DFR t 

### = dislodgeable foliar residue on day "t" (μg/cm 2 

### ); CF1 = weight unit conversion factor (0.001 mg/μg); TC = transfer coefficient (cm 2 

### /hr); andPage 30 of 31



### ET = exposure time (hrs/day).

In the absence of chemical

- specific da ta, DFR t 

### can be calculated as follows:

DFR t 

### = AR * F

AR 

### * (1

- F

D 

### ) t 

### * CF2 * CF3

where :

DFR t 

### = dislodgeable foliar residue on day "t" (μg/cm 2 

### ); AR = application rate (lbs ai/ft 2 

### or lb ai/acre);

F AR 

### = fraction of ai as dislodgeable residue following application (unitless);

F D 

### = 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 10 8 

### μg/lb); and

CF3 = area unit conversion factor (1.08 x 10 - 3 

### ft 2 

### /cm 2 

### or 2.47 x 10 - 8 

### acre/cm 2 

### ).

Absorbed dermal dose, normalized to body weight, is calculated as:

where :
D = dose (mg/kg

- day);

E = exposure (mg/day);

AF = absorption factor (dermal and/or inhala tion); and

BW = body weight (kg).

Table A

- 7 : Gardens, Trees, and “Pick

- your

- own” Farms

– Inputs for Residential Post

- application Dermal Exposure Algorithm

Notation Exposure Factor (units) Point Estimate(s)

AR Application rate (mass ai per unit area) 0.54 lb ae/acre

F AR DFR following application, if chemical

- specific is unavailable (fraction) 0.25

F D Daily residue dissipation, if chemical

- specific is unavailable (fraction) 0.10

TC Transfer

Coefficient (cm 2 /hr) Gardens a Adults 8400

Children 6 < 11 years old 4600
Trees, Retail Plants (if applicable) a Adults 1700

Children 6 < 11 years old 930

Indoor Plants Adults 220 Children 6 < 11 years old 120

ET Exposure

Time (hours per day) Home activities b Gardens Adults 2.2

Children 6 < 11 years

old 1.1

Trees, Retail Plants (if applicable) Adults 1.0

Children 6 < 11 years

old 0.50Page 31 of 31

Table A

- 7 : Gardens, Trees, and “Pick

- your

- own” Farms

– Inputs for Residential Post

- application Dermal Exposure Algorithm

Notation Exposure Factor (units) Point Estimate(s)

Indoor Plants Adults 1.0

Children 6 < 11 years

old 0.50

“Pick

- your

- own” Farms (if applicable) Adults 5.0

Children 6 < 11 years old 1.9

BW Body weight (kg) Adults 80

Children 6 < 11 years old 32

a Transfer coefficient point estimates from a composite distribution assuming equal proportion of time spent conducting various activities. Children 6 < 11 years old TC derived using surface area adjustment

. b Activity time point estimates from a composite distribution assuming equal proportion of each respective activity. Time for children 6 < 11 years old derived using hrs/day ratio adjustment.