Date:

Subject: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, 

### D.C. 20460

02-DEC-2014 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

Bentazon. Occupational and Residential Ex posure and Risk Assessment for Registration Review.

PC Code: 275200, 103901
Decision Nos.: 486719
Petition No.: N/ A DP Barcode: 0418591 Registration Nos.: N/ A Regulatory Action: Registration Review Risk Assessment
Case No.: 0182 Risk Assessment Type: Single Chemical/ Aggregate
TXRN o .: NA CAS N o.: 50723-80-3, 25057-89-0
40 CFR: §180.355 MRIDNo.: NA

From:

Through:

To:

Introduction Kelly M. Lowe, Environmental Scientist

### Y**C'~** Risk Assessment Branch 1 (RAB 1) Health Effec ts Division (HED; 7509P)

Charles W. Smith III, Branch Chief 

# C**c.)~** 

## §)-

HED I RABl (7509P)

and

### Shal~ M Shelat, Re':'iewer

### ~~ Casst L. Walls, Reviewer**~** ;(.**4)~** Exposure Science Advisory Committee (ExpoSAC) 

### I HED

Carolyn Schroeder Pesticide Reevaluation Division (7509P)

As part of Registration Review, the Pesticide Re-evaluation Division (PRD) of OPP has requested that HED evaluate the hazard and exposure data and conduct occupational and residential exposure assessments, as needed

, to estimate the risk to human heal th that will result from the currently registered uses of pesticides. This memorandum serves as HED's Registration Review risk asses

. sment of the occupational and residential handler and postapplication exposure and risk from the currently registered uses o f bentazon.

Page I of26It is HED policy t o use the best avai l able data to assess exposure. Severa l sources of generic data were used in th i s assessment as surrogate data in the absence of chemical

- specific data, including Pesticide H and l ers Exposure Database Version 1.1 (PHED 1.1 ); the Agricu l tural Hand l er Exposure Task Force (AHE TF ) database; the Outdoor Residential Exposure Task Force (ORETF) database; and the Agricultural Reentry Task Force (ARTF) database. Some ofthese data are proprietary, and subject to the data protection provisions of the Federal Insecticide, Fungicide, and Rodentic id e Act (FIFRA)

.

Note: T his memo r andum was reviewed by the Exposure Sc i ence Adv i sory Committee (ExpoSAC) on 25

- SEP

- 2014.

Page 2 of26Page 3 of 26 

### 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

................................ ................................ ................................ .. 6 2.3 Data Deficiencies and Requirements

................................ ................................ ............... 6 3.0 Hazard Characterization

................................ ................................ ................................ ....... 7 4. 0 Exposure and Use Profile

................................ ................................ ................................ ..... 8 5.0 Residential Exposure and Risk Estimates

................................ ................................ .......... 11 5.1 Residential Handler Exposure/Risk Estimates

................................ ............................... 11 5.2 Residential Post

- application Exposure/Risk Estimates

................................ .................. 12 5.3 Residential Risk Estimates for Use in Aggrega te Assessment

................................ ...... 13 5.4 Spray Drift

................................ ................................ ................................ ...................... 14 5.5 Residential Bystander Post

- Application Inhalation Exposure

................................ ....... 15 6.0 Occupational Exposure and Risk Estimates

................................ ................................ ...... 15 6.1 Occupational Handler Exposure/Risk Estimates

................................ ............................ 15 6.2 Occupational Post

- application Exposure/Risk Estimates

................................ .............. 19 6.2.1 Occupational Post

- application Inhalation Exposure/Risk Estimates

...................... 19 6.2.2 Occupational Post

- application Dermal Exposure/Risk Estimates

.......................... 20 Appendix A. Summa ry of Occupational and Residential Non

- cancer Algorithms

..................... 21Page 4 of 26



### 1.0 Executive Summary

Sodium b entazon (herein referred to as bentazon) is a selective, contact, early post

- emergent herbicide used to control a variety of broadleaf weeds and sedges

. This document assesses exposures and risk estimates from the registered uses of bentazon for Registration Review

. Exposure and U se Profile There are 11 end

- use product labels and 4 special local needs (SLNs) registered with bentazon as the active ingredient (ai)

. All products are liquid formulations

. Bentazon is currently registered for use on various agricultural crops, non

- bearing food crops, n on

- cropland sites, r oadsides,

r ights

- of

- way , nursery stock, ornamentals, and turf (including athletic fields, commercial/residential settings, golf courses (not greens), recreational areas, and sod farms)

. Most of the uses are foliar and are applied via aerial, groundboom

, or handheld equipment. The maximum application rate supported by the registrants f or any use site is 1.5 lb ai/A ; however, most use sites have a maximum single application rate of 1 lb ai/A ( or 0.023 lb ai/gal). Based on the registered use patterns, it has been determined that the potential exposure scenarios that will need to be asses sed include short

- and intermediate

- term occupational and residential exposures (handler and post

- application).

Hazard Profile The incidental oral and inhalation points of departure (PODs) are based on a study that examined the reproduction and fertilit y effects in the rat, where decreased absolute pup body weights during lactation were observed at 62 mg/kg/day. A n o

- o bserved

- a dverse

- e ffect

- l evel (NOAEL) was identified at 15 mg/kg/day. In the 28

- day dermal toxicity study in rats, no dermal or systemic toxicity was seen up to the limit dose (1,000 mg/kg/day) . In addition, bentazon exhibits low dermal absorption (1

- 2%) ; therefore, a dermal exposure assessment is not required for bentazon

. Bentazon has been classified as a Group “E” chemical (evidence of non

carcinogenicity for humans) based upon lack of evidence of carcinogenicity in rats and mice (TXR 010787, J. Rowe, 1/14/92). Therefore, a cancer exposure and risk assessment is not required.

The level of concern (LOC) for both occupational and non

- oc cupational risk is margins of exposure (MOEs) less than 100. For the non

- cancer risk assessment, s ince 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

. The acute toxicity data for bentazon show that this chemical has low acute toxi city by the oral, inhalation, and dermal routes of exposure (Toxicity Categories III and IV). It is moderately irritating to the eye (Toxicity Category II) and slightly irritating to the skin (Toxicity Category IV). It is also a dermal sensitizer.

Residential Exposure and Risk There is the potential for residential exposure from the registered uses on ornamentals and turf. These uses have been assessed using t he most up

- to

- date exposure policies and data available in the 2012 Residential SOPs. Since a dermal hazard was not identified, a quantitative dermal assessment was not conducted for the residential uses of bentazon. The inhalation exposure risk estimate s for residential handlers are not of concern (i.e., MOEs ≥ the LOC of 100 ) at baseline for all scenarios

. All residential post

- application risk estimates are also not of concern (i.e.,Page 5 of 26



### MOEs ≥ the LOC of 100). A quantitative spray drift assessment for bentazon is not required since the turf post

- application MOEs are protective for any potential exposures related to spray drift for bentazon

. Occupational Exposure and Risk There is the potential for occupational exposure from the registered uses of benta zon. These uses have been assessed using the most up

- to

- date exposure policies and data available. Since no dermal hazard was identified for bentazon, a quantitative dermal assessment was not conducted for the occupational uses of bentazon. The occupati onal handler exposure and risk estimates indicate that the short

- and intermediate

- term inhalation MOEs are not of concern to HED (i.e., MOE > the LOC of 1 00 )

. O ccupational post

- application dermal exposure and risk estimates

were not assessed since a dermal hazard was not identified. In this case, the restricted entry interval ( REI ) is based on the acute toxicity of bentazon technical material , which would require

a 24

- hour R EI under 40 CFR 156.208 (c) (2)

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

- cancer occupational post

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

- appl ication inhalation exposure assessment for bentazon

.

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 studie s from the PHED 1.1, the AHETF database, and the ARTF database 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 hav e 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

There are no occupational or residential risk estimates of concern for the registered uses of bentazon

.

 The occupational handler exposure and risk estimates indicate that the short

- and intermediate

- term inhalation combined MOEs are not of concern to HED (i.e., MOE > 1 00); all MOEs ≥ 3,000

.

 The inhalation exposure risk estimates for residential handlers are not of concern (i.e., MOEs ≥ 100) at baseline for all scenarios; all MOEs ≥ 75 ,000

.

 All residential post

- application risk estimates are not of concern (i.e., M OEs ≥ 100); all MOEs ≥ 1000 for children.

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 26



### 2.2 Label Recommendations

There are no label rec ommendations

.

2.3 Data Deficiencies and Requirements

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. Because there is no hazard via the dermal r oute of exposure, a non

- cancer dermal post

- application risk assessment was not performed for bentazon . Therefore, DFR studies are not needed for bentazon at this time. If the PODs change, the need for DFR studies may be reevaluated in the future to refin e the post

application assessment.

Turf Transferable Residue (TTR): In accordance with 40CFR158, TTR data are required for all occupational (e.g., sod farms, golf courses, parks, and recreational areas) or residential turf uses that could result in pos t

- application exposure to turf. In the absence of chemical

- specific TTR data, EPA uses default values. The 2012 Standard Operating Procedures for Residential Pesticide Exposure Assessment includes an analysis of all TTR data, available at the time, which resulted in the selection of revised liquid and granular default values for the fraction of the application rate available for transfer after a turf application (F AR 

### ). These values are based on an analysis of 59 TTR studies performed with the Modified Ca lifornia Roller Method (36 studies using liquids, 11 studies using wettable powders/water dispersible granules, and 12 studies using granules). The liquid results (N=131) indicate a range of F AR 

### values from 0.0005% to 6.1% and the granular results (N=37) indicate a range of 0.00064% to 0.69%. In both the liquid and granular data, a large range of transferability is observed and this variability can potentially be attributable to many factors such as active ingredient; formulation; field conditions in the studies; weather conditions (e.g., humidity); or many other difficult to quantify factors. Although witnessed across multiple chemicals, this range in F AR 

### values is not expected when considering TTR data for a single chemical. HED selected 1% and 0.2% a s high

- end default values for liquid and granular products, respectively. Because TTR data are not available for bentazon

, EPA is using the default value of [appropriate value for liquid or granular product]. Although there may be a small degree of uncer tainty in the use of the default TTR value for bentazon (i.e., there is a small chance that the F AR 

### value may exceed the applicable default value ), it is likely that the health

- protective aspects of EPA’s residential post

- application turf assessment metho dology will more than compensate for this potential uncertainty (i.e., the methodology is likely to overestimate exposure by a factor greater than the highest measured F AR 

### values exceed the defaults ). For example, when assessing residential post

- applica tion turf exposure, EPA assumes the following: exposures occur to zero

- day (i.e., day of application ) residues every day of the assessed exposure duration (i.e., EPA assumes that no dissipation or degradation occurs, it doesn’t rain, the grass is not mo wed, etc); individuals perform the same post

application activities performed in the turf transfer coefficient study day after day (e.g., tumbling, playing on turf with toys, etc.); and individuals engage in these post

- application activities for a high

- en d amount of time every day that is represented by data reflecting time children spend outdoors and not specifically engaged in activities on turf, when in actualityPage 7 of 26



### children do not spend all of their outdoor time on turf and high

- end levels of activity wil l not occur every day.

Given the conservatisms discussed above and the potential compounding nature of these conservatisms, EPA is able to rely upon the calculated exposure estimates with confidence that exposure is not being underestimated.

Since the estimated post

- application exposure to residential turf usin g default TTR values for bentazon is minimal in comparison to the level of concern (i.e., the calculated MOE is greater than 10 times higher than the level of concern, MOE = 1000 compared to the LOC of 100) ; EPA is waiving the 40CFR TTR data requirement. In this instance, it is unlikely that chemical

specific TTR data would be needed to further refine exposure assessments or would add appreciably to our general understanding of the availabili ty of turf transferable pesticide residues.

3 .0 Hazard Characterization

Bentazon is a benzothiadiazinone contact herbicide that is manufactured by BASF Corporation. The acute toxicity data for bentazon show that this chemical has low acute toxic ity by the oral, inhalation, and dermal routes of exposure (Toxicity Categories III and IV). It is moderately irritating to the eye (Toxicity Category II) and slightly irritating to the skin (Toxicity Category III). It is also a dermal sensitizer.

The Haza rd and Science Policy Council (HASPOC) met on September 11 , 2014 (TXR 0057054 ) to discuss the need for a subchronic inhalation toxicity study for bentazon . Based on a weight of evidence approach, the HASPOC concluded that a subchronic inhalation toxicity study is not needed for bentazon at this time for the following reasons: 1) the well characterized hazard profile of bentazon which considered the chemical’s metabolic and toxicokinetic, and acute inhalation toxicity profiles; 2) the physiochemical proper ties of bentazon which were expected to result in negligible inhalation exposure; and 3) the predicted MOEs are higher than the agency’s levels of concern for residential and occupational exposure.

The incidental oral and inhalation PODs are based on a study that examined the reproduction and fertility effects in the rat, where decreased absolute pup body weights during lactation were observed at 62 mg/kg/day. A NOAEL was identified at 15 mg/kg/day. In the 28

- day dermal toxicity study in rats, no de rmal or systemic toxicity was seen up to the limit dose (1,000 mg/kg/day) . In addition, bentazon exhibits low dermal absorption (1

- 2%) ; therefore, a dermal

non

- cancer exposure assessment is not required for bentazon

. Bentazon has been classified as a Gro up “E” chemical (evidence of non

- carcinogenicity for humans) based upon lack of evidence of carcinogenicity in rats and mice (TXR 010787, J. Rowe, 1/14/92). Therefore, a cancer exposure and risk assessment is not required.

The Agency’s LOC for risks (i.e ., target level for MOE ) is defined by the uncertainty factors that are applied to the assessment. The Agency applies a factor of 10X to account for interspecies extrapolation to humans from the animal test species and another factor of 10X to account for intra

- species sensitivity. The total uncertainty factor that has been applied to occupational andPage 8 of 26



### residential risk assessments is 100 for short

- and intermediate

- term incidental oral and inhalation
exposures.

Table 3.1. Summary of Toxicological Dose s and Endpoints for B entazon for Use in Human Health Risk Assessments

Exposure/ Scenario Point of

Departure (POD) Uncertainty/FQP

A Safety Factors RfD, PAD,

Level of Concern for Risk Assessment Study and Toxicological Effects

Incidental Oral Short

- (1

- 30 days) and Intermediate

– Term (1

- 6 months) NOAEL= 15

mg/kg/day UF A = 10x

UF H = 10x FQPA SF= 1x Residential

LOC for MOE = 100 Reproduction and fertility effects

- Rat

Offspring LOAEL = 62 mg/kg/day based on decreased absolute pup body weights during lactation.

Dermal Short

- (1

- 30 days) and Intermediate

Term (1

- 6 months) Based upon a lack of dermal toxicity in the 21

- day dermal study, and the low absorption values

for bentazon (1

- 2%), a dermal risk assessment is not required.

Inhalation Short

- (1

- 30 days) and Intermediate

Term (1

- 6 months) NOAEL= 15

mg/kg/day UF A = 10x

UF H =10x FQPA SF= 1x Residential

LOC for MOE = 100 Reproduction and fertility effects

- Rat

Offspring LOAEL = 62 mg/kg/day based on decreased absolute pup body weights during lactation.

Cancer (oral, dermal, inhalation) Classification: Group “E” chemical (evidence of non

- carcinogenicity for humans) based upon

lack of evidence of carcinogenicity in rats and mice (TXR 010787, J. Rowe, 1/14/92). A cancer exposure and risk assessment is not required. 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 e nvironmentally relevant human exposures. NOAEL = no observed 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. MOE = margin of exposure. LOC = level of concern.



### Absorption : For the non

- cancer risk assessment, inhalation exposure is assumed to be equivalent to oral absorption.

Body Weight : T he inhalation PODs are not based on dev elopmental and/or fetal effects; therefore, the body weight appropriate for inhalation assessments is 8 0 kg.

4 .0 Exposure and Use Profile

There are 11 end

- use product labels , and 4 SLNs

, registered with bentazon as the active ingredient. All products are liquid formulations . The labeled use sites include various agricultural crops, non

- bearing food cro ps, n on

- cropland sites, r oadsides, r ights

- of

- way , nursery stock, ornamentals, and turf (including athletic fields, commercial/residential settings, golf courses (not greens), recreational areas, and sod farms) . Most of the uses are foliar and are applied via aerial, groundboom

, or handheld equipment. The maximum application ratePage 9 of 26



### supported by the registrants for any use site is 1.5 lb ai/A ; however, most use sites have a maximum single application rate of 1 lb ai/A ( or 0.023 lb ai/gal).

Based on the registered use patterns, it has been determined that the potential exposure scenarios that will need to be assessed include short

- and intermediate

- term occupational and residential exposures (handler and post

- application). A summary of the current use pattern is included in Table 4 .1.

Table 4.1. Summary of Proposed Directions for Use of Bentazon

.

Crop/Use Site Application

Timing and Type of Application Registered

Formulations Maximum

Application Rate Limitation and Restrictions 1 Personal Protective Equipment (PPE) Max # apps/year Min RTI

(days) REI

(hours) PHI

(days)

Alfalfa (grown for seed production) Prior to flower

bud formation

Aerial, Groundboom

Liquid 1.5 lb ai/A

2 5

48 NA

Long

sleeved shirt, long pants, gloves, shoes and socks;

some labels require protective
eyewear Beans (dry and succulent) Early

Postemergence

Aerial, Groundboom 1.5 lb ai/A NA 30

Clov er (grown for seed) Early

postemergence

Aerial, Groundboom 1.0 lb ai/A 5 36

Corn Early

postemergence

Aerial, Groundboom 1.5 lb ai/A NA 12

Non

- bearing food crops (almonds, apples, apricots, avocados, blackberries, blueberries, cherries, crabapples, dates, figs, grapes, grapefruit, lemons, limes, macadamias, nectarines, olives, oranges, peaches,
pears, pecans, pistachios, plums, pomegranates, prunes, raspberries, tangelos, tangerines, walnuts) Postemergence directed

Groundboom 1.0 lb ai/A NA NAPage 10 of 26

Table 4.1. Summary of Proposed Directions for Use of Bentazon

.

Crop/Use Site Application

Timing and Type of Application Registered

Formulations Maximum

Application Rate Limitation and Restrictions 1 Personal Protective Equipment (PPE) Max # apps/year Min RTI

(days) REI

(hours) PHI

(days)

Non

- cropland sites, Roadsides, Rights

- of

way Postemergence

Groundboom, Handheld 1 lb ai/A; 0.023 lb ai/gal 7 NA

Nursery stock Postemergence

Groundboom, Handheld 1 lb ai/A; 0.023 lb ai/gal 7 NA

Ornamentals Postemergence

Groundboom, Handheld 1 lb ai/A; 0.02 3 lb ai/gal 7 NA

Peanuts Range from

cracking through pegging

Aerial, Groundboom 1.5 lb ai/A NA 50

Peas (dry and succulent) After 3 pairs of

leaves are present, do not apply when peas are in bloom

Aerial, Groundboom 1.5 lb ai/A NA dry peas = 30, succulent
peas = 10

Peppermint/ Spearmint Postemergence

Aerial, Groundboom 1.5 lb ai/A NA 20

Rice Postemergence

Aerial, Groundboom 1.0 lb ai/A NA NA

Sorghum Postemergence,

but not during crop heading or blooming

Aerial, Groundboom 1.0 lb ai/A NA 12

Soybeans Postemergence

Aerial, Groundboom 1.5 lb ai/A NA 30Page 11 of 26

Table 4.1. Summary of Proposed Directions for Use of Bentazon

.

Crop/Use Site Application

Timing and Type of Application Registered

Formulations Maximum

Application Rate Limitation and Restrictions 1 Personal Protective Equipment (PPE) Max # apps/year Min RTI

(days) REI

(hours) PHI

(days)
Turf (athletic fields, commercial/residential settings, golf courses (not greens),

recre ational areas, sod farms) Postemergence

Groundboom, Handheld 1 lb ai/A; 0.023 lb ai/gal 21

(perennial ryegrass) NA

1. RTI = retreatment interval; REI = restricted entry interval; PHI = Preharvest interval



### 5 .0 Residential Exposure and Risk Estimates

There is the potential for residential handler and post

- application expo sure from the registered uses on turf and ornamentals.

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 distin ct 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 pr otective equipment.

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

(1) mixing/loading/applying liquids to turf and gardens/trees with manually

- pressurized handwand, (2) mixing/loading/applyi ng liquids to turf and gardens/trees with hose

- end sprayer, and (3) mixing/loading/applying liquids turf and gardens/trees with backpack.

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: The application rates used in this assessment are provided in Table 4.1.

Unit Exposures and Area Treated or Amount Handled: Unit exposu re values and estimates for area treated or amount handled were taken from HED’s 2012 Residential SOPs 2



### .
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.

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

- exposure

- sop.htmlPage 12 of 26



### 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 3



### . Summary of Residential Handler Non

- Cancer Exposure and Risk Estimates Table 5.1 .1 provides a summary of the residential handler exposures and risk estimates for bentazon

. Since there is no dermal hazard, a quantitative residential handler dermal assess ment has not been conducted. The inhalation exposure risk estimates for residential handlers are not of concern (i.e., MOEs ≥ 100) at baseline for all scenarios ; all MOEs ≥ 75 ,000

.

Table 5.1.1. Residential Handler Non

- cancer Exposure and Risk Estimate s for Bentazon

.

Scenario Application

Equipment/Method Application Rate 1 Area Treated or Amount Handled Daily Inhalation

Unit Exposure (mg/lb ai) 2 Inhalation

Dose (mg/kg/day) 3 Inhalation

MOE 4

Mixer/Loader/Applicator for Liquid Formulations
Gardens / Trees Manually

- pressurized handwand 0.023 lb ai/gallon 5 gallons 0.018 0.000026 580,000 Lawns / Turf Gardens / Trees Hose

- end Sprayer 0.023 lb ai/gallon 11 gallons 0.0014 0.0000044 3,400,000 Lawns / Turf 1 lb ai/acre 0.5 acres 0.022 0.00014 110,000 Gardens / Trees Backpack 0.023 lb ai/gallon 5 gallons 0.14 0.0002 75,000 Lawns / Turf
1

. Based on registered label s ( see table 4.1 ). 2

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

- exposure

- sop.html ). 3

. Inhalation Dose = Inhalation Unit Exposure (mg/lb ai) × Application Rate (lb ai/acre or gal) × Area T reated or Amount Handled (A/day or gallons/day) ÷ Body Weight ( 80 kg). 4

. Inhalation MOE = Inhalation NOAEL ( 15 mg/kg/day) ÷ Inhalation Dose (mg/kg/day).



### 5.2 Residential Post

- application Exposure/Risk Estimates

There is the potential for post

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

. Since there is no dermal hazard identified for bentazon, a quantitative dermal post

- applica tion assessment has not been conducted. The quantitative exposure/risk assessment for residential post

- application exposures is based on the following scenarios:

 Physical activities on turf: children 1 to < 2 years old ( incidental oral).

The lifestag es selected for each post

- application scenario are based on an analysis provided as an Appendix in the 2012 Residential SOPs 4 

### . While not the only lifestage potentially exposed for these post

- application scenarios, the lifestage that is included in the qua ntitative assessment is health protective for the exposures and risk estimates for any other potentially exposed lifestage.

Residential Post

- application Exposure Data and Assumptions

3 Available: http://www.epa.gov/pesticides/sc ience/residential

- exposure

- sop.html

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

- exposure

- sop.htmlPage 13 of 26



### A series of assumptions and exposure factors served as the basis for com pleting the residential post

- application risk assessment. Each assumption and factor is detailed in the 2012 Residential SOPs 4

.
Application Rate: The application rates used in this assessment are provided in Table 4.1.

Exposure Duration: Residential post

- application exposure is expected to be short

- term in duration. While multiple applications may be possible, it is anticipated that these appl ications will be intermittent in nature and dissipation due to rainfall/irrigation, grass growth, and grass

m owing is expected.

Residential Post

- application Non

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

- applicat ion exposure and dose can be found in Appendix A and/or the 2012 Residential SOPs 4



### . Combining Exposure and Risk Estimates The incidental oral sce narios (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 these scenarios would be overly

- conservative because of the conservative nature of each individual assessment. Therefore, these scenarios have not been combined.

Summary of Residential Post

- application Non

- Cancer Exposure and Risk Estimates Table 5. 2 .1 provides a summary of the residential post

- application exposures and risk estimates for bentazon

. All risk estimates for post

- application exposure are no t of concern (i.e., MOEs ≥ 100) ; all MOEs ≥ 1000 for children

.

Table 5.2.1. Short

- Term Residential Post

- application Exposure and Risk Estimates for Bentazon

.
Lifestage Post

- application Exposure Scenario Dose (mg/kg/day) 1 MOEs 2
Liquid formulation

Child 1 to < 2 year old Turf

Liquid formulation

1 lb ai/A Hand to Mouth 0.0152 1

, 000
Object to Mouth 0.000456 32,000

Short

- and Intermediate

- term Incidental Soil Ingestion 0.000034 440,000

1 Dose (mg/kg/day) equations provided in Appendix A

. 2 MOE = POD (Incidental oral = 1 5 mg/kg/day) ÷ Dose (mg/kg/day). LOC = 100.



### 5.3 Residential Risk Estimates for Use in Aggregate Assessment

Table 5.3.1 reflects the residential risk estimates that are recommended for use in the aggregate assessment for bentazon

.

 The recommended residential exposure for use in the adult short

- term aggregate assessment reflects inhalation exposure from handler a pplications using a backpack
sprayer.

 The recommended residential exposure for use in the children 1<2 years old short

- term aggregate assessment reflects hand

- to

- mouth exposures from post

- application exposure to turf applications.Page 14 of 26

Table 5.3.1. Recommendations for the Residential Exposures for the Bentazon Aggregate Assessment.

Lifestage Exposure

Scenario Dose (mg/kg/day) 1 MOE 2

Dermal Inhalation Oral Total Dermal Inhalation Oral Total
Short

- term

Adult Handler

application via backpack
sprayer NA 0.0002 NA 0.0002 NA 75,000 NA 75,000

Child 1 < 2 year old Hand

- to

mouth NA NA 0.0152 0.0152 NA NA 1

, 000 1

, 000

1 Dose = the highest dose for each applicable life stage of all residential scenarios assessed. Total = dermal + inhalation + incidental

oral (where applicable). 2 MOE = the MOEs associated with the highest residential doses.



### 5

. 4 Spray Drift

Off

- target movement of pesticides can occur via many types of pathways and it is governed by a variety of factors. Sprays that are released and do not deposit in the application area end up off

target and can lead to exposures to those it may directly contact. They can also deposit on surfaces where contact with residues can eventually lead to exposures ( e.g. , children playing on lawn s where residues have deposited next to treated fields). The potential risk estimates from these residues can be calculated using drift modeling coupled with methods employed for residential risk assessments for turf products.

The approach to be used for quantitatively incorporating spray drift into risk assessment include assessing exposures for children (1 to < 2 years old) and adults who have contact with turf where residues are assumed to have deposited via spray drift thus resulting in an exposure scen ario. Aside from the predicted residues available for transfer, the routes of exposure and assessment methodology is analogous to how exposures to turf products are considered in risk assessment. Several bentazon products have existing labels for use on turf, thus it was considered whether the risk assessment for turf may be considered protective of any type of exposure resulting from spray drift. If the maximum application rate on crops adjusted by the amount of drift expected is less than or equal to existing turf application rates, the existing turf assessment is considered protective of spray drift exposure. The maximum single application rate registered for bentazon is 1.5 lb ai/ A

. The highest fraction of spray drift noted for any application metho d immediately adjacent to a treated field results in a deposition fraction of 0.26 5 

### of the application rate. A quantitative spray drift assessment for bentazon is not required because the maximum application rate for a crop/target site multiplied by the a djustment factor for drift of 0.26 is less than the maximum direct spray residential turf application rate ( 1 lb ai/A) 6 

### for any bentazon products. The turf post

- application MOEs are protective for any potential exposures related to spray drift for bentazon and have previously been discussed in Section 5. 2

.

5 Tier 1 output from the aerial application using fine to medium spray quality based on AgDrift output files

6 1.5 lb ai/A x 0.26 = 0.39 ≤ 1 lb ai/APage 15 of 26



### 5

. 5 Residential Bystander Post

- Application Inhalation Exposure

Volatilization of pesticides may be a source of post

- application inhalation exposure to individuals nearby pesticide applications . The agency sought expert advice and input on issues related to volatilization of pesticides from its Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel (SAP) in December 2009, and received the SAP’s final report on March 2, 20 10 (http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html). The agency has evaluated the SAP report and has developed a Volatilization Screening Tool and a subsequent Volatilization Screening Analysis (http://www.regulations.gov/#!docketDetail;D =EPA

- HQ

- OPP

- 2014

- 0219). During Registration Review, the agency will utilize this analysis to determine if data (i.e., flux studies, route

- specific inhalation toxicological studies) or further analysis is required for bentazon.

6 .0 Occupational Exposure an d Risk Estimates

6 .1 Occupational Handler Exposure/Risk Estimates

HED uses the term handlers to describe those individuals who are involved in the pesticide application process. HED believes that there are distinct job functions or tasks related to appl ications and exposures can vary depending on the specifics of each task. Job requirements (amount of chemical used in each application), the kinds of equipment used, the target being treated, and the level of protection used by a handler can cause exposur e levels to differ in a manner specific to each application event.

The quantitative exposure/risk assessment developed for occupational handlers is based on the following scenarios which cover all the registered and proposed uses of bentazon :

 Mixing/loading liquids to support aerial applications,

 Mixing/loading liquids to support groundboom applications,

 Applying sprays with aircraft,

 Applying sprays with groundboom equipment,

 Flagging to support aerial spray applications,

 Mixing/loading/appl ying liquids via backpack,

 Mixing/loading/applying liquids via mechanically

- pressurized handgun,

 Mixing/loading/applying liquids vi a manually

- pressurized handwand.

Occupational Handler Exposure Data and Assumptions A series of assumptions and exposure f actors served as the basis for completing the occupational handler risk assessments. Each assumption and factor is detailed below on an individual basis.

Application Rate : The application rates used in this assessment are provided in Table 4.1.

Unit Exposures: It is the policy of HED to use the best available data to assess handler exposure. Sources of generic handler data, used as surrogate data in the absence of chemical

- specific data, include PHED 1.1, the AHETF database, the Outdoor Residential Exposure Task Force (ORETF) database, or other registrant

- submitted occupational exposure studies. Some of thesePage 16 of 26



### data are proprietary (e.g., AHETF data), and subject to the data protection provisions of FIFRA. The standard values recommended for use in p redicting handler exposure that are used in this assessment, known as “unit exposures”, are outlined in the “Occupational Pesticide Handler Unit Exposure Surrogate Reference Table 7 

### ”, which, along with additional information on HED policy on use of surrogat e data, including descriptions of the various sources, can be found at the Agency website 8



### .

Area Treated or Amount Handled : The inputs for area treated were mostly based on information in ExpoSAC Policy 9.1. The following summarizes the inputs used for estimating handler
exposures:

 1200 acres for aerial application to high acreage crops

 350 acres for aerial application to typical acreage crops

 60 acres for aerial and groundboom applications to nurseries

 200 acres for ground application to high acreage crops

 80 acres for ground application to typical acreage crops

 80 acres for ground application to sod farms

 40 acres for ground application to golf courses and field ground ornamentals

 60 or 350 acres for flaggers

 5 acres or 40 gallons for backpack and manually

- pressurized handwand applications

 5 acres or 1000 gallons for mechanically

- pressurized handgun

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

- term and exposures 30 days to six months as intermediate

- term. Exposure duration is determined by many things, including the exposed population, the use site, the pest pressure triggering the use of the pesticide, and the cultural practices surrounding that use site. For most agricultural uses, it is reasonable to believe tha t occupational handlers will not apply the same chemical every day for more than a one

- month time frame; however, there may be a large agribusiness and/or commercial applicators who may apply a product over a period of weeks

.

For the registered use patt ern , short

- and intermediate

- term exposures are anticipated for the following reasons : (1) up to two applications ca n be made anywhere from 5 to 21 days apart ; and ( 2 ) commercial applicators may apply this product at various locations within a region over a period of weeks. The same exposure durations are anticipated for all registered bentazon uses, and it should be noted that the short

- and intermediate

- term PODs are the same; therefore, short

term risk estimates are protective of longer

- term exposures.

Mitigation/Personal Protective Equipment: Estimates of dermal and inhalation exposure were calculated for various levels of personal protective equipment (PPE). Results are presented for “baseline,” defined as a single layer of clothing consisting of a long sleeved shirt, long pants, shoes plus socks, no protective gloves, and no respirator, as well as baseline with various levels of PPE as necessary (e.g., gloves, respirator, etc ). Most of the bentazon registered labels require

7 Available: http://www.epa.gov/opp00001/science/handler

- exposure

- table.pdf

8 Avail able: http://www.epa.gov/pesticides/science/handler

- exposure

- data.htmlPage 17 of 26



### handlers to wear a single layer of clothing (long sleeved shirt and long pants) , gloves, shoes and socks, and some labels require protective eyewear.

Occupational Handler Non

- Cancer Exposure and Risk Estimate Equations The algorithms used to estimate non

- cancer exposure a nd dose for occupational handlers can be found in Appendix A

. Summary of Occupational Handler Non

- Cancer Exposure and Risk Estimates The occupational handler exposure and risk estimates indicate that the short

- and intermediate

term inhalation combined MO Es are not of concern to HED (i.e., MOE > 100) at baseline (no respirator). MOEs are all greater than or equal to 3,000

. HED has no data to assess exposures to pilots using open cockpits. The only data available is for exposure to pilots in enclosed coc kpits. Therefore, risks to pilots are assessed using the engineering control (enclosed cockpits) and baseline attire (long

- sleeve shirt, long pants, shoes, and socks); per the Agency’s Worker Protection Standard stipulations for engineering controls, pilo ts are not required to wear protective gloves for the duration of the application. With this level of protection, there are no risk estimates of concern for applicators.

The Agency matches quantitative occupational exposure assessment with appropriate ch aracterization of exposure potential. While HED presents quantitative risk estimates for human flaggers where appropriate, agricultural aviation has changed dramatically over the past two decades. According the 2012 National Agricultural Aviation Associati on (NAAA) survey of their membership, the use of GPS for swath guidance in agricultural aviation has grown steadily from the mid 1990’s. Over the same time period, the use of human flaggers for aerial pesticide applications has decreased steadily from ~15% in the late 1990’s to only 1% in the most recent (2012) NAAA survey. The Agency will continue to monitor all available information sources to best assess and characterize the exposure potential for human flaggers in agricultural aerial applications.

Table 6.1.1. Occupational Handler Non

- Cancer Exposure and Risk Estimates for Bentazon.

Exposure Scenarios Crop / Target Category Application Rate 1 Amount

Handled / Area Treated 2 Inhalation

Unit Exposures (ug/lb ai) 3 Inhalation

Dose (mg/kg/ day) 4 Inhalati on

MOE 5

Baseline (unless otherwise noted) Baseline

(unless otherwise noted) Baseline

(unless otherwise noted)

Mixer/Loader

Aerial application of liquid formulation Peas

, Peppermint, Spearmint 1.5 lb ai/acre

350 acres 0.219 0.00144 10,000

Clover, Non

- bearing food crops (almonds, apples, apricots, avocados, blackberries, blueberries, cherries, crabapples, dates, figs, grapes, grapefruit, lemons, limes, macadamias, nectarines, olives, oranges, peaches, pears, pecans, pistachios, plums, pomegranates, prunes, raspberries, tangelos,

tangerines, walnuts) 1 lb ai/acre 0.000959 16,000Page 18 of 26

Table 6.1.1. Occupational Handler Non

- Cancer Exposure and Risk Estimates for Bentazon.

Exposure Scenarios Crop / Target Category Application Rate 1 Amount

Handled / Area Treated 2 Inhalation

Unit Exposures (ug/lb ai) 3 Inhalation

Dose (mg/kg/ day) 4 Inhalati on

MOE 5

Baseline (unless otherwise noted) Baseline

(unless otherwise noted) Baseline

(unless otherwise noted) Corn, Peanuts

, Beans, Soybeans 1.5 lb ai/acre 0.00493 3,000 Sorghum, Rice, Alfalfa 1 lb ai/acre 0.00329 4,600

Groundboom applications with liquid formulation Golf course (fairways, tees, greens) 1 lb ai/acre 40 acres 0.00011 140,000

Nursery (ornamentals, vegetables, trees,

container stock) 1 lb ai/acre 60 acres 0.000164 91,000

Sod 1 lb ai/acre

80 acres 0.000219 68,000 Peas

, Peppermint, Spearmint 1.5 lb ai/acre 0.000329 46,000 Clover, Non

- bearing food crops (almonds, apples, apricots, avocados, blackberries, blueberries, cherries, crabapples, dates, figs, grapes, grapefruit, lemons, limes, macadamias, nectarines, olives, oranges, peaches, pears, pecans, pistachios, plums, pomegranates, prunes, raspberries, tangelos,

tangerines, walnuts) 1 lb ai/acre 0.000219 68,000

Corn, Peanuts

, Beans, Soybeans 1.5 lb ai/acre 0.000821 18,000 Sorghum, Rice, Alfalfa 1 lb ai/acre 0.000548 27,000 Applicator

Aerial application of liquid formulation Peas

, Peppermint, Spearmint 1.5 lb ai/acre

350 acres 0.0049 (EC) 0.0000321

(EC) 470,000

(EC) Clover, Non

- bearing food crops (almonds, apples, apricots, avocados, blackberries, blueberries, cherries, crabapples, dates, figs, grapes, grapefruit, lemons, limes, macadamias, nectarines, olives, oranges, peaches, pears, pecans, pistachios, plums, pomegranates, prunes, raspberries, tangelos,

tangerines, walnuts) 1 lb ai/acre 0.0000215 (EC) 700,000

(EC)

Corn, Peanuts

, Beans, Soybeans 1.5 lb ai/acre 0.00011 (EC) 140,000

(EC)
Sorghum, Rice, Alfalfa 1 lb ai/acre 0.0000735 (EC) 200,000

(EC)

Groundboom applications with liquid formulation Golf course (fairways, tees, greens) 1 lb ai/acre 40 acres

0.34 0.00017 88,000

Nursery (ornamentals, vegetables, trees,

container stock) 1 lb ai/acre 60 acres 0.000255 59,000

Sod 1 lb ai/acre

80 acres 0.00034 44,000 Peas

, Peppermint, Spearmint 1.5 lb ai/acre 0.00051 29,000 Clover, Non

- bearing food crops (almonds, apples, apricots, avocados, blackberries, blueberries, cherries, crabapples, dates, figs, grapes, grapefruit, lemons, limes, macadamias, nectarines, olives, oranges, peaches, pears, pecans, pistachios, plums, pomegranates, prunes, raspberries, ta ngelos,

tangerines, walnuts) 1 lb ai/acre 0.00034 44,000

Corn, Peanuts

, Beans, Soybeans 1.5 lb ai/acre 0.00128 12,000 Sorghum, Rice, Alfalfa 1 lb ai/acre 0.00085 18,000 Mechanically

- pressurized Handgun Rights

- of

- way (e.g., utilities, railroad, roadways) 0.023 lb ai/gallon 1000

gallons 3.9 0.00112 13,000Page 19 of 26

Table 6.1.1. Occupational Handler Non

- Cancer Exposure and Risk Estimates for Bentazon.

Exposure Scenarios Crop / Target Category Application Rate 1 Amount

Handled / Area Treated 2 Inhalation

Unit Exposures (ug/lb ai) 3 Inhalation

Dose (mg/kg/ day) 4 Inhalati on

MOE 5

Baseline (unless otherwise noted) Baseline

(unless otherwise noted) Baseline

(unless otherwise noted)
Flagger

Aerial application of liquid formulation Peas

, Peppermint, Spearmint 1.5 lb ai/acre

350 acres 0.35 0.0023 6,500

Clover, Non

- bearing food crops (almonds, apples, apricots, avocados, blackberries, blueberries, cherries, crabapples, dates, figs, grapes, grapefruit, lemons, limes, macadamias, nectarines, olives, oranges, peaches, pears, pecans, pistachios, plums, pomegranates, prunes, raspberries, tangelos,

tangerines, walnuts) 1 lb ai/a cre 0.00154 9,700

Corn, Peanuts

, Beans, Soybeans 1.5 lb ai/acre 0.0023 6,500
Sorghum, Rice, Alfalfa 1 lb ai/acre 0.00154 9,700 Mixer/Loader/Applicator

Backpack Rights

- of

- way (e.g., utilities, railroad, roadways)

0.023 lb ai/gallon 40 gallons 2.58 0.0000296 510,000 Landscaping, turf (lawns, athletic fields,

parks, etc.) Manually

pressurized Handwand Landscaping, turf (lawns, athletic fields, parks, etc.) 30 0.000345 43,000

Mechanically

- pressurized Handgun Golf course (fairways, tees, greens) 1 lb ai/acre 5 acres 1.9 0.000119 130,000

Landscaping, turf (lawns, athletic fields,

parks, etc.)
1 Based on registered and proposed labels

. 2 Exposure Science Advisory Council Policy #9.1. 3 Based on the “Occupational Pesticide Handler Unit Exposure Surrogate Reference Table” ( March 201 4 ); Level of mitigation: Baseline, EC = Eng. Controls. 4 Inhalation Dose = Inhalation Unit Exposure ( μ g/lb ai) × Conversion Factor (0.001 mg/ μ g) × Application Rate (lb ai/acre) × Area Treated (A / day) ÷ BW ( 80 kg). 5 Inhalation MOE = Inhalation NOAEL ( 15 mg/kg/day) ÷ Inhalation Dose (mg/kg/day).



### 6

. 2 Occupational Post

- application Exposure/ Risk Estimates

HED uses the term post

- application to describe exposures that occur when individuals are present in an environment that has been previously treated with a pesticide (also referred to as re

entry exposure). Such exposures may occur when workers enter previously treated areas to perform job functions, including activities related to crop production, such as scouting for pests or harvesting. Post

- application exposure levels vary over time and depend o n such things as the type of activity, the nature of the crop or target that was treated, the type of pesticide application, and the chemical’s degradation prope rties. In addition, the timing of pesticide applications, relative to harvest activities, can greatly reduce the potential for post

- application exposure.

6

. 2 .1 Occupational Post

- application Inhalation Exposure/Risk EstimatesPage 20 of 26



### There are multiple potential sources of post

- application inhalation exposure to individuals performing post

- application activities in previously treated fields. These potential sources include volatilization of pesticides and resuspension of dusts and/or particulates that contain
pes ticides. 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 Marc h 2, 2010 ( http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html ). The agency has evaluated the SAP report and has developed a Volatilization Screening Tool and a subsequent Volatilization Screening Analysis ( http://www.regulations.gov/#!docketDetail;D=EPA

- HQ

OPP

- 2014

- 0219 ). During Registration Review, the agency will utilize this analysis to determine if data (i.e., flux studi es, route

- specific inhalation toxicological studies) or further analysis is required for bentazon.

In addition, the Agency is continuing to evaluate the available post

- application inhalation exposure data generated by the Agricultural Reentry Task Force. Given these two efforts, the Agency will continue to identify the need for and, subsequently, the way to incorporate occupational post

- application inhalation exposure into the agency's risk assessments.

Although a quantitative occupational post

- applicati on inhalation exposure assessment was not performed, an inhalation exposure assessment was performed for occupational/commercial handlers. Handler exposure resulting from application of pesticides outdoors is likely to result in higher exposure than post

- application exposure. Therefore, it is expected that these handler inhalation exposure estimates would be protective of most occupational post

- application inhalation exposure scenarios.

6

. 2 .2 Occupational Post

- application Dermal Exposure/Risk Estimates

A quantitative dermal post

- application assessment was not conducted because a dermal hazard for bentazon has not been identified.

Restricted Entry Interval The REI specified on the proposed label is based on the acute toxicity of bentazon

. Bentazon is classified as acute toxicity category III and IV for acute oral, acute dermal, and acute inhalation toxicity. It is classified as toxicity category II for eye irritation potential and category I II for skin irritation potential. It is a dermal sensitizer. Under 40 CFR 156.208 (c) (2) , ai’s classified as Acute II for acute dermal, eye irritation or primary skin irrigation are assigned a 24

- hour REI. Therefore, the [156 subpart K] Worker Protection Statement interim REI of 24 hours is adequate to protect agricultural workers from post

- application exposures to bentazon

.Page 21 of 26



### Appendix A. Summary of Occupational and Residential Non

- cancer Algorithms

OCCUPATIONAL NON


### - CANCER HANDLER ALGOR ITHMS



### Potential daily exposures for occupational handlers are calculated using the following formulas:

E=UE * AR * A * 0.001 mg/ug

where:

E = exposure (mg ai/day), UE = unit exposure (μg ai/lb ai), AR = maximum application rate according to proposed label (lb ai A or lb ai/gal), and A = area treated or amount handled (e.g., A/day, gal/day).

The daily doses are calculated using the following formula:

ADD= E * AF
BW

where:

ADD = average daily dose absorbed in a given scenario (mg ai/kg/day), E = exposu re (mg ai/day), AF = absorption factor (inhalation), and BW = body weight (kg).

Margin of Exposure: Non

- cancer risk estimates for each application handler scenario are calculated using a Margin of Exposure (MOE), which is a ratio of the toxicological endpoint to the daily dose of concern. The daily inhalation dose received by occupational handlers are compared to the appropriate POD (i.e., NOAEL) to assess the risk to occupational handlers for each exposure route. All MOE values are calculated using the following formula:

MOE= POD
ADD

where:

MOE = margin of exposure: value used by HED to represent risk estimates (unitless), POD = point of departure (mg/kg/day), and ADD = average daily dose absorbed in a given scenario (mg ai/kg/day).Page 22 of 26

RESIDENTIAL NON


### - CANCER HANDLER ALGOR ITHMS



### Inhalation Handler Exposure Algorithm

- Turf Daily inhalation exposure (mg/day) for residential pesticide handlers, for a given formulation

application method combination, is estimated by multiplying the formulation

- applicat ion 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/ga l); and A = area treated or amount handled (e.g., ft 2 

### /day, gal/day).

I nhalation 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 ALGORITH MS



### Post

- application Hand

- to

- Mouth Exposure Algorithm

– Physical Activities on Turf Exposure from hand

- to

- mouth activity is calculated as follows (based on the algorith m 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 contact s events per hour (events/hour).Page 23 of 26



### 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:

where: D = dose (mg/kg

- day); E = exposure (mg/day); and BW = body weight (kg).

Table A

- X: 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) See table 4.1

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 11Page 24 of 26



### 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

- t o

- mouth contact events per hour (events/hour).

and

OR = AR * F O 

### * CF2 * 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

- X: 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) See table 4.1

F O Fraction of AR as OR following application 1 0.01Page 25 of 26

Table A

- X: Turf (Physical Activities)

– Inputs for Residential Post

- application Object

- to

- Mouth Exposure Algorithm Notation Exposure Factor

(units) Point Estimate(s)

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); 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 unit con version 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); andPage 26 of 26



### BW = body weight (kg).

Table A

- X: 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) See table 4.1

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