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 Residential Exposure Assessment for 

Proposed Amended Use on Com. 

PC Code: 02741 2,027402 

Decision No.: 471299 

DP Barcode: D41 0970 

Registration No.: 59639-140 

Regulatory Action: Section 3 

Case No.: NA 

Petition No.: NA 

Risk Assessment Type: Occupational/Residential Exposure Assessment 

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

MRIDNo.: NA 40 CFR: 180.627 

From: 

Through: 

To: 

Introduction 

Alexandra LaMay, Biologist 

Risk Assessment Branch VII 

::~:,:::::::ion (75 09P) ~ Michael Metzger, Chief . 

Risk Assessment Branch V 

Health Effects Division (7509 ) 

and 

Kristin Rury, Biologist ,fJ~ Aaron Niman, PHS c::{_';:j_ L0 

Exposure Science Advisory Committee (ExpoSAC) I HED 

Tony Kish!Dominic Schuler 

Fungicide Branch 

Registration Division (7505P) 

The Registration Division (RD) requested that the Health Effects Division (HED) conduct an 

exposure and risk assessment for the proposed reduction of plant back interval on com. There is 

no occupational exposure associated with the petition; however, residential exposures have been 

reassessed in this memorandum to be used for aggregate assessment. 

Page I of31 
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 the Residential SOPs. 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 April 4, 2013. 

Page 2 of3 1 
Page 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 Exposure 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 Algorithms.................................................. 21
Page 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 degradate/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 separately 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 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. 

Fluopicolide has low acute toxicity via oral, dermal and inhalation routes of exposure. 

Fluopicolide is not a dermal sensitizer, primary eye irritant, or primary skin irritant. The rabbit 

developmental and rat chronic/carcinogenicity studies were considered co-critical for endpoint 

selection for all routes (dietary, 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 factor to 1X for fluopicolide.

For BAM, the 90-day 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. The 10X FQPA safety 

factor 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 purpose 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 exposure 
Page 5 of 31

assessment was also completed for BAM as there is a potential for post-application exposure to 

BAM after fluopicolide application to turf and trees. All residential 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 exposure 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 

SOPs, 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

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 exposures 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 assessment 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.html
Page 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 application (FAR).

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 maximum FAR value seen using a liquid product was 6.1%

or 6.1 times higher than the default residue transfer value. The maximum FAR 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 MOEs 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 DFR studies are required when a pesticide has residential or occupational 

uses that 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 Assessment, 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 (FAR). 

This default value is 25% and is based on an analysis of 19 DFR studies where the FAR value 

ranged from 2% to 89%. This value is recommended for use in both residential and occupational 

postapplication assessments. Of the analyzed DFR studies, the maximum FAR value seen was 

89% or 3.6 times higher than the default residue transfer 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.html
Page 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. Table 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 

IntermediateTerm

(1 - 6 months)

Maternal 

NOAEL = 20 

mg/kg/day

UFA=10x

UFH=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 ShortIntermediateand LongTerm (1-30 

days, 1-6 

months, and 

>6 months)

Maternal 

NOAEL = 20 

mg/kg/day

UFA=10x

UFH=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 

thyroid lesions.

Inhalation 

ShortIntermediateand Longterm (1-30 

days, 1-6 

months, and 

>6 months)

Maternal 

NOAEL = 20 

mg/kg/day

UFA=10x

UFH=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. NOAEL 
Page 8 of 31

= 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). 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

UFA = 10X

UFH = 10X

FQPA SF = 10X

(includes UFDB)

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

UFA = 10X

UFH = 10X

FQPA SF = 1X 

(residential uses 

only)

Residential and 

Occupational 

LOC for 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 

UFA = 10X

UFH = 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: unclassified; parent herbicide dichlobenil classified as “Group C, possible 

human carcinogen” with RfD approach utilized for quantification of human risk

Abbreviations: UF = uncertainty factor, UFA = extrapolation from animal to human (interspecies), UFH = potential 

variation in sensitivity among members of the human population (intraspecies), FQPA SF = FQPA Safety Factor, 

UFL = use of a LOAEL to extrapolate a NOAEL, UFDB = 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 the 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, since the short- and intermediate-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, the 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 developmental 

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 SOPs3

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 interval of 14 days. There are 

also uses on ornamental plants and trees with application 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, there 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 are 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 

receive 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/lawns and gardens/trees using handheld 

equipment

 

3 Available: http://www.epa.gov/pesticides/science/residential-exposure-sop.html
Page 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 SOPs4.

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 SOPs5.

Combining Exposures/Risk Estimates:

Dermal and inhalation risk estimates were combined in this assessment, since the toxicological 

effects for these exposure routes were the same. Dermal and inhalation risk estimates were 

combined using the following formula:

Total MOE = Point of Departure (mg/kg/day) ÷ Combined Dermal + Inhalation 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/residential-exposure-sop.html

5 Available: http://www.epa.gov/pesticides/science/residential-exposure-sop.html
Page 11 of 31

Table 5.1.1. Residential Handler Non-cancer Exposure and Risk Estimates for Fluopicolide.

Exposure Scenario Level of 

Concern

Dermal Unit 

Exposure

(mg/lb ai)

Inhalation 

Unit 

Exposure

(mg/lb ai)

Maximum 

Application 

Rate1

Area Treated or 

Amount 

Handled Daily2

Dermal Inhalation Total

Dose 

(mg/kg/day)3 MOE4 Dose (mg/kg/day)5 MOE6 MOE7

Mixer/Loader/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/ft2 1200 ft2

0.0051 3,900 0.0000039 5,100,000 3,900

Gardens/Trees, Liquid, 

Hose-end 

Sprayer/Sprinkler Can

58 0.0014

0.0000125 lb 

ai/ft2 1200 ft2

0.0047 4,300 0.0000003 66,000,000 4,300

Gardens/Trees, Liquid, 

Hose-end Sprayer

0.0025 lb 

ai/gallon 11 gallons 0.0086 2,300 0.00000056 36,000,000 2,300

Gardens/Trees, Liquid, 

Sprinkler Can

0.0025 lb 

ai/gallon 5 gallons 0.0039 5,100 0.00000025 79,000,000 5,100

Lawns/Turf, 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/Turf, Liquid, 

Sprinkler Can

0.0000062 lb 

ai/ft2 1000 ft2

0.00045 45,000 0.000002 10,000,000 45,000

Gardens/Trees, Liquid, 

Backpack

130 0.14

0.0000125 lb 

ai/ft2 1200 ft2

0.01 1,900 0.00003 660,000 1,900

Gardens/Trees, Liquid, 

Backpack

0.0025 lb 

ai/gallon 5 gallons 0.0087 2,300 0.000025 790,000 2,300

Lawns/Turf, Liquid, 

Backpack

0.003 lb 

ai/gallon 5 gallons 0.01 1,900 0.00003 660,000 1,900

1 Based on registered labels. Application rate for turf is 0.27 lb ai/acre, or 0.0000062 lb ai/ft2. The label states that a volume of 2 gallons treats 1000 sq. ft, which is equivalent 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 ai/ft2. The label 

states that 100 gallons treats 20,000 sq ft, which is equivalent 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) × Dermal 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) ÷ Body Weight (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. There is 

also a potential for exposure to BAM during post-application activities 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 exposure 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 SOPs6. 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 

SOPs6.

TTR for fluopicolide

Because turf transferable residue (TTR) data were not available fluopicolide, turf residues were 

estimated using default assumptions.

DFR data for fluopicolide

A dislodgeable 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 application 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.html
Page 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/cm2) 0.418 0.446

Time Interval Of Peak TTR 8hr after treatment 1DAT

Predicted Day 0 Residue (μg/cm2) 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/cm2. 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/cm2 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). 

The 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 grapes (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 BAM 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 application). 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 SOPs6.

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 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 protective 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 and Risk Estimates for Fluopicolide.

Lifestage

Post-application Exposure 

Scenario Application 

Rate1

Dose 

(mg/kg/day)2 MOEs3

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

0.043 460

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 0.074 270 X

260 Hand-to-Mouth 0.0041 4,900 X

Object-to-Mouth 0.00012 160,000

Incidental Soil N/A N/A

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 and Risk Estimates for BAM.

Lifestage

Post-application Exposure 

Scenario Application 

Rate/ 

Residue1

Dose 

(mg/kg/day)2 MOEs3

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 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 fluopicolide.

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

dermal post-application exposure to treated gardens.

The recommended residential exposure 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-application 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 MOE3 Dose (mg/kg/day)4 MOE5

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

Short-Term

Adult 0.01 0.00003 0.010 - - 1,900 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 Residential 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 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 information7. 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 significant risk estimates associated with drift.

It is noted that the 0.27 lb ai/acre application rate for turf was modeled to estimate postapplication residential exposure of children. As this rate is equal to or higher than many of 

agricultural application 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 associated 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 because 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, 20108. 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 postapplication 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.html
Page 20 of 31

Although a quantitative residential post-application inhalation exposure assessment was not 

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 Occupational 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 combination, is estimated by multiplying the formulationapplication 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/ft2, lb ai/gal); and

A = area treated or amount handled (e.g., ft2/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/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) 0.27 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

FD

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 49,000
Page 23 of 31

Table A-1: Turf (Physical Activities) -- Inputs for Residential Post-application Dermal Exposure

Algorithm Notation Exposure Factor

(units) Point Estimate(s)

(cm2/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 * (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:

BW

E

D
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)

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) 0.27 lb ae/acre

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

Freq_OtM = number of object-to-mouth contact events per hour (events/hour).
Page 25 of 31

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) 0.27 lb ae/acre

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:

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 10-6g/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) 0.27 lb ae/acre

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

Turf/Mowing
Page 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);

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 0.27 lb ae/acre

FAR

Fraction of AR as 

TTR following 

application

L/WP/WDG 0.01

Granules 0.002
Page 28 of 31

Table A-5: Turf (Mowing) – Inputs for Residential Post-application Dermal Exposure 

FD

Daily residue 

dissipation

L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient

(cm2/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); 

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 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, is calculated as:
Page 29 of 31

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-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

FD Daily residue dissipation L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient

(cm2/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 = DFRt * CF1 * TC * ET

where:

E = exposure (mg/day);

DFRt = dislodgeable foliar residue on day "t" (μg/cm2);

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

TC = transfer coefficient (cm2/hr); and
Page 30 of 31

ET = exposure time (hrs/day).

In the absence of chemical-specific data, DFRt can be calculated as follows:

DFRt = AR * FAR * (1-FD)

t

* CF2 * CF3

where:

DFRt = dislodgeable foliar residue on day "t" (μg/cm2);

AR = application rate (lbs ai/ft2or lb ai/acre);

FAR = fraction of ai as dislodgeable 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).

Absorbed dermal 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/or inhalation); 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

FAR

DFR following application, if chemical-specific is unavailable

(fraction) 0.25

FD

Daily residue dissipation, if chemical-specific is unavailable

(fraction) 0.10

TC

Transfer 

Coefficient

(cm2/hr)

Gardensa 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 activitiesb

Gardens

Adults 2.2

Children 6 < 11 years 

old 1.1

Trees, Retail 

Plants (if 

applicable)

Adults 1.0

Children 6 < 11 years 

old 0.50
Page 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.