UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460 

 OFFICE OF 

PREVENTION, PESTICIDES 

AND TOXIC SUBSTANCES 

DATE: February 23, 2010 

MEMORANDUM

SUBJECT: Indaziflam: Occupational and Residential Exposure Assessment for Use 

of New Active Ingredient on Turf, Golf Courses, Sod Farms, Christmas 

Tree Farms, Non-Crop Areas and Forestry. 

 PC Code: 080818 DP Number: D372538 

 MRID: 47443317; 47443316 Registration Nos.: 432-RUOO; 432-RUOL; 

 432-RUOA; 432-RUOT; 72155-IO; 

 72155-OR; 72155-ON 

 Petition Nos: NA Regulatory Action: Section 3 

 Assessment Type: Single Chemical CAS Number: 730979-19-8 

 TXR No.: NA Decision No.: 398884 

 Case No. NA 40 CFR: NA 

 

FROM: Margarita Collantes, Biologist 

 Risk Assessment Branch (RAB) II 

 Health Effects Division (7509P) 

THROUGH: Richard Loranger, Branch Senior Scientist 

 Risk Assessment Branch (RAB) II 

 Health Effects Division (7509P) 

TO: Erik Kraft/James Tompkins, RM Team 25 

 Herbicide Branch 

 Registration Division (7505P) 

ACTION REQUESTED: 

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

exposure risk assessment for proposed uses of the new active ingredient indaziflam to 

control annual grasses and broadleaf weeds in residential and commercial lawns, golf 

course, sod farms, recreational turf, ornamentals, non-crop areas, Christmas tree farms 

and forested areas. Commercial and residential handler and post application exposure 

assessments were conducted for the proposed Indaziflam uses. 

Page 1 of 21 
TABLE OF CONTENTS 

1.0 EXECUTIVE SUMMARY...................................................... ... 3

2.0. HAZARD CHARACTERIZATION.......................................... ......5

2.1 Hazard Profile............................................................ .....5 

 2.2 FQPA/Uncertainty Factors.......................................... .........6 

3.0 PROPOSED USE PATTERNS........................ ............................7

4.0 RESIDENTIAL (NON-OCCUPATIONAL) RISK................................9 

 4.1 Handler Exposure..............................................................9 

 4.2 Postapplication Exposure.....................................................11 

 4.2.1 Hand-To-Mouth .....................................................11 

 4.2.2 Object-To-Mouth ...................................................13 

 4.2.3 Incidental Ingestion of Soil ........................................14 

 4.2.5 Episodic Ingestion................................................... 15 

 4.3 Combined Residential Exposure and Risk............................... .16 

5.0 OCCUPATIONAL RISK.............................................................17 

 5.1 Handler Exposure.............................................................17 

 5.2 Postapplication Exposure.....................................................21 

Page 2 of 21 
1.0 EXECUTIVE SUMMARY 

Indaziflam ([1,3,5-triazine-2,4-diamine,N-[(1R2S)-2,3-dihydro-2,6-dimethyl-1H-inden1-yl]-6-(1-fluroethyl)]) is a new selective, pre-emergent and post-emergent alkylazine 

herbicide for control of many annual grasses and broadleaf weeds in lawns, golf course, 

sod farms, recreational turf, ornamentals, non-crop areas, Christmas tree farms and 

forested areas. It is also used as a pre-emergent herbicide for weed control in parks, rail 

roads, utility, industrial and municipal sites, sidewalks and driveways. Indaziflam may 

be applied through a variety of application methods including: ground equipment, right 

of way handgun, backpack, broadcast and rotary or drop type spreader, hand held 

equipment (low pressure, high pressure and trigger sprayer), and hose end sprayer. 

There are currently no registered uses for indaziflam in the United States. This 

assessment will review six proposed products for use by commercial and professional 

applicators (formulated as a water soluble packet and turf fertilizers) as well as three 

residential homeowners (formulated as a granule and liquid) products. It should be 

noted that several of these products contain additional active ingredients. This 

assessment will only assess exposure resulting from the use of indaziflam. Proposed 

uses are anticipated to result in short- and intermediate-term durations of exposure. 

Hazard Characterization 

Indaziflam shows low acute toxicity by all routes of exposure (Toxicity Category III, oral 

and dermal and Category IV, inhalation) and is not an ocular or dermal irritant or a 

dermal sensitizer. 

An appropriate endpoint for short- or intermediate-term dermal exposure was not 

identified. No toxicity was observed in a 28-day dermal toxicity study in the rat up to the 

limit dose of 1000 mg/kg/day. Therefore, a short- and intermediate-term dermal 

exposure assessment was not conducted. 

The short- and intermediate-term incidental oral and inhalation no observed adverse 

effect level (NOAEL) of 7.5 mg/kg/day was selected and based on brain, spinal cord and 

sciatic nerve degenerative lesions observed at the lowest observed adverse effect level 

(LOAEL) of 15 mg/kg/day from a subchronic oral dog (gavage) study. 

Indaziflam is classified as “Not likely to be carcinogenic to humans.” 

FQPA and Uncertainty Factors

Although there are no food uses associated with the currently proposed uses, HED is 

reviewing a subsequent submission of proposed food uses. Therefore, the RABII team 

has considered the postnatal susceptibility of infants and children in determining 

appropriate uncertainty and safety factors for the non-food uses. HED recommends 

reduction of the FQPA safety factor to 1X, based on (1) there is no evidence of increased 

quantitative or qualitative pre- and/or postnatal susceptibility in a complete database that 

includes developmental reproductive and developmental neurotoxicity, and 

immunotoxicity studies; (2) developmental effects in the rat that were observed, but only 

at high doses and in the presence of maternal/parental toxicity; and (3) selection of 

endpoints and doses for risk assessments that are protective of potential developmental 

Page 3 of 21 
toxicity. 

HED has retained the traditional uncertainty factors for inter-species extrapolation and 

10X for intra-species variability. Therefore, HED’s level of concern for residential and 

occupational handler and postapplication exposure risk is equal to an MOE of 100. 

Scenarios resulting in MOEs greater than or equal to 100 are not of concern to HED. 

Residential Handler Exposure: 

Three indaziflam turf products (i.e., Lawn 3 FL Concentrate/Ready-to-Spray, Lawn 3 FL 

Granule, and Lawn 3 FL Ready-To- Use) are proposed for use by home owners. These 

products are to be applied using hand held sprayers (pump style tank, hose end, and 

trigger) or drop/push rotary-type spreaders, and were assessed using the Pesticide 

Handlers Exposure Database (PHED) Surrogate Exposure Guide and the Outdoor 

Residential Exposure Task Force (OREFT) study (MRID 44972201) unit exposures to 

estimate handler exposure. Since a short-term dermal point was not selected, the only 

route of exposure addressed is via inhalation. Handler inhalation MOEs were 

significantly greater than 100 and are not of concern. 

Residential Postapplication Exposure: 

Since residential postapplication scenarios occur outdoors where there is sufficient air 

exchange to reduce the potential for inhalation exposure to minimal levels, a quantitative 

postapplication inhalation exposure assessment was not conducted. Furthermore, since a 

dermal endpoint was not selected the only postapplication residential scenario assessed 

for this action is oral non-dietary ingestion exposures for children (i.e. soil ingestion, and 

hand-/object-to-mouth). 

The children’s oral postapplication residential scenarios were assessed using the HED 

Draft Standard Operating Procedures (SOP’s) for Residential Exposure Assessment, 

2000. All short- and intermediate-term hand-to-mouth (HTM), object-to-mouth (OTM) 

and soil ingestion scenarios resulted in MOEs greater than the level of concern (MOEs ≥

100) and therefore pose no risk of concern to HED. Oral MOEs ranged from 5,300 to 

2,100,000. 

Occupational Handler Exposure: 

No chemical specific data were available to assess potential exposure to pesticide 

handlers. The estimates of exposure to pesticide handlers are based upon surrogate study 

data available in the PHED (v. 1.1, 1998) and from the Outdoor Residential Exposure 

Task Force (ORETF: MRID 44972201). Short- and intermediate-term inhalation risks 

for commercial lawn handlers are not of concern. Handler inhalation MOEs ranged from 

2,900 to 6,000,000. 

Occupational Postapplication Exposure

HED assumes that inhalation exposures are minimal following outdoor applications of an 

active ingredient, due to the large volume of air exchange. Therefore, a separate 

inhalation postapplication risk assessment was not conducted. Since a dermal endpoint 

was not selected, a dermal postapplication exposure assessment was not conducted. 

Therefore, the restricted entry interval (REI) will be based on the acute toxicity of the 

technical, indaziflam. Since indaziflam has low acute toxicity by all routes of exposure 

Page 4 of 21 
and is not an ocular or dermal irritant or a dermal sensitizer, HED has no objection to the 

proposed 12-hour restricted entry interval (REI) in accordance with the Worker 

Protection Standard (WPS). 

Review of Human Research

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 studies, which 

comprise the Pesticide Handlers Exposure Database (PHED), and the Outdoor 

Residential Exposure Task Force (ORETF) Database, have been determined to require a 

review of their ethical conduct, have received that review, and have been determined to 

be ethically conducted. 

2.0. HAZARD CHARACTERIZATION 

2.1 Hazard Profile

Indaziflam shows low acute toxicity by all routes of exposure (Toxicity Category III, oral 

and dermal and Category IV, inhalation) and is not an ocular or dermal irritant or a 

dermal sensitizer. The database for acute toxicity for indaziflam is complete and is 

summarized below in Table 2.1a. 

An appropriate endpoint for short- or intermediate-term dermal exposure was not 

identified. No toxicity was observed in a 28-day dermal toxicity study in the rat up to the 

limit dose of 1000 mg/kg/day. This study is the most relevant study to use since there are 

no developmental or reproductive concerns and the relevant endpoint 

(neurotoxicity/histopathology of the nervous system) was measured in the dermal study. 

Therefore, a short- and intermediate-term dermal exposure assessment was not 

conducted. 

The short- and intermediate-term incidental oral and inhalation no observed adverse 

effect level (NOAEL) of 7.5 mg/kg/day is based on brain, spinal cord and sciatic nerve 

degenerative lesions observed at the LOAEL of 15 mg/kg/day from a subchronic oral dog 

(gavage) study. The selected endpoint (neurotoxicity) is the most sensitive NOAEL 

available from a study of appropriate exposure duration (90-days) for short- and 

intermediate-term exposure. The subchronic oral dog study was selected over other 

studies because the dog was the most sensitive species for neurotoxicity and the 

subchronic study had the overall lowest NOAEL. Inhalation absorption of 100% is 

assumed relative to oral absorption because there are no data on inhalation absorption. 

Indaziflam is classified as “Not likely to be carcinogenic to humans.” 

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

exposure scenarios is provided in Table 2.1b. The acute dietary endpoint and dose is 

provided for assessing episodic ingestion of granules. 

Page 5 of 21 
2.2 FQPA and Uncertainty Factor Considerations 

Although there are no food uses associated with the currently proposed uses, HED is 

reviewing a subsequent submission of proposed food uses. Therefore, the RABII team 

has considered the postnatal susceptibility of infants and children is determined 

appropriate uncertainty and safety factors for the non-food uses. HED recommends 

reduction of the FQPA safety factor to 1X, based on (1) there is no evidence of increased 

quantitative or qualitative pre- and/or postnatal susceptibility in a complete database that 

includes developmental reproductive and developmental neurotoxicity, and 

immunotoxicity studies; (2) developmental effects in the rat that were observed, but only 

at high doses and in the presence of maternal/parental toxicity; and (3) selection of 

endpoints and doses for risk assessments that are protective of potential developmental 

toxicity. 

HED has retained the traditional uncertainty factors for inter-species extrapolation and 

10X for intra-species variability. Therefore, HED’s level of concern for residential and 

occupational handler and postapplication exposure risk is equal to an MOE of 100. 

Therefore, scenarios resulting in MOEs greater than or equal to 100 are not of concern to 

HED. 

Table 2.1a Acute Toxicity Profile - Test Substance 

Guideline No. Study Type MRID(s) Results Toxicity Category 

870.1100 Acute oral - rat 47443281 LD50 > 2000 mg/kg 

(both sexes) 

III 

870.1200 Acute dermal - rabbit 47443282 LD50 > 2000 mg/kg 

(both sexes) 

III 

870.1300 Acute inhalation - rat 47443283 LC50 > 2.3 mg/L 

(both sexes) 

IV 

870.2400 Acute eye irritation - rabbit 47443284 Non-irritant IV 

870.2500 Acute dermal irritation - rabbit 47443285 Non-irritant IV 

870.2600 Skin sensitization - guinea pig 47443286 Not a sensitizer 

(Buehler method) 

N/A 

Page 6 of 21 
Table 2.1b Summary of Toxicological Doses and Endpoints for Indaziflam for Use in Occupational 

and Residential Risk Assessments 

Exposure/ 

Scenario 

Point of 

Departure (POD) 

Uncertainty 

Factors 

Level of Concern 

for Risk 

Assessment 

Study and Toxicological Effects 

Acute Dietary 

(All 

Populations) 

NOAEL = 50 

mg/kg/day 

UFA=10X 

UFH=10X 

FQPA SF = 

1X 

Occupational & 

Residential LOC 

= MOE = 100 

Acute oral neurotoxicity in the rat 

LOAEL = 100 mg/kg/day, based 

on decreased motor and 

locomotor activity in females. 

Incidental 

Oral ShortTerm (1 to 30 

days) and 

IntermediateTerm (1 to 6 

months) 

NOAEL = 7.5 

mg/kg/day 

UFA=10X 

UFH=10X 

FQPA SF = 

1X 

(residential) 

Occupational & 

Residential LOC 

= MOE = 100 

Subchronic oral (gavage) in the 

beagle dog 

LOAEL = 15 mg/kg/day, based 

on axonal degenerative 

microscopic findings in the brain, 

spinal cord and sciatic nerve. 

Dermal (all 

durations) 

Not required for this assessment. An appropriate endpoint was not identified for short- or 

intermediate-term dermal exposure. Long-term dermal exposure is not anticipated. 

Inhalation 

Short-Term (1 

to 30 days) 

and 

IntermediateTerm (1 to 6 

months) 

NOAEL= 7.5 

mg/kg/day. 

Inhalation 

absorption 

assumed to be 

100% (default) 

relative to oral. 

UFA=10X 

UFH=10X 

FQPA SF = 

1X 

(residential) 

Occupational & 

Residential LOC 

= MOE = 100 

Subchronic oral (gavage) in the 

beagle dog 

LOAEL = 15 mg/kg/day, based 

on axonal degenerative 

microscopic findings in the brain, 

spinal cord and sciatic nerve. 

Inhalation 

Long-Term (> 

6 months) 

Not required for this assessment (exposure is seasonal; long-term occupational exposure 

scenarios are not anticipated). 

Cancer (oral, 

dermal, 

inhalation) 

Classification: “Not likely to be Carcinogenic to Humans” (under 2005 carcinogenicity 

guidelines), based lack of treatment-related tumors in the two-year rat and mouse 

bioassays and no concerns for mutagenicity. 

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

data and used to mark the beginning of extrapolation to determine risk associated with lower 

environmentally relevant human exposures. NOAEL = no observed adverse effect level. LOAEL = lowest 

observed adverse effect level. UF = uncertainty factor. UFA = extrapolation from animal to human 

(interspecies). UFH = potential variation in sensitivity among members of the human population 

(intraspecies). MOE = margin of exposure. LOC = level of concern. N/A = not applicable. 

3.0 PROPOSED USE PATTERNS 

Indaziflam is a selective, pre-emergent and post-emergent alkylazine herbicide for 

control of many annual grasses and broadleaf weeds in turf (lawns, sod farms, golf 

courses, recreational fields, etc), ornamentals and trees. It is also proposed for use as a 

pre-emergent herbicide for weed control in parks, rail roads, utility, industrial and 

municipal sites. Indaziflam is available for use by commercial and professional 

applicators (formulated as a water soluble packet and turf fertilizers) as well as residential 

homeowners (formulated as Lawn 3 FL granules and liquid). It may be applied through a 

variety of application methods including: ground equipment, right of way handgun, 

backpack, broadcast and rotary or drop type spreader, hand held equipment (low 

pressure, high pressure and trigger sprayer) and hose end sprayer. The herbicide requires 

rainfall or irrigation within several weeks after application to activate it and ensure its 

Page 7 of 21 
effectiveness. The proposed uses are anticipated to result in short- and intermediate-term 

exposure durations. Table 3 provides a summary of the proposed uses. 

Table 3: Proposed Commercial and Residential Products and Uses of Indaziflam 

Product 

EPA Reg. No. 

Use Site Application 

Method 

Application 

Rate 

Area 

Treated 

Comments 

Commercial Products 

ground 

equipment 

0.089 lb ai/A 40 acres 

right of way 25 acres or 

1000 gals 

handgun 1 acre or 

40 gals 

low pressure 

handwand 

Esplanade 

200 SC 

(Soluble 

Concentrate) 

19% ai 

432-xxxx 

Annual grasses and weeds 

in non-crop areas (utilities, 

industrial, municipal and 

government sites, roadsides) 

ornamental perennial 

plantings, around farm 

buildings, educational 

facilities, parking lots 

back pack 

0.089 lb ai/A 

or 0.0178 

 lb ai/gal 

5 acres or 

40 gals 

Pre-emergent 

aerial 1200 acres 

groundboom 0.125 lb ai/A 200 acres 

Esplanade F 

(Flowable 

Concentrate) 

19% ai 432-

xxxx 

forestry 

backpack 0.125 lb ai/A 

or 0.0248 lb ai 

/gal 

1 acre or 

 (40 gals) 

Preemergent 

1 appliation 

groundboom 0.088 lb ai/A 200 acres 

(forestry) 

80 acres 

(sod farms 

and 

Christmas 

Trees) 

40 acres 

(golf course 

and field 

grown 

ornamentals) 

BCSAA10717 

20 WSP 

(Water Soluble 

Packet)

 432-RUOO

Annual grasses and weeds 

in turfgrass, golf courses, 

sod farms; ornamentals, 

nurseries, Christmas trees, 

landscapes forestry, noncrop areas 

groundboom, 

 hand held 

equipment 

 

0.071 lb ai/A – 

non-crop areas 

5 acres 

(handheld) 

Single application in 

spring, summer and 

fall; 3 month interval 

between applications; 

not to exceed 0.088 

lb ai/A per year 

BCSAA10717 

0.0142% Plus 

Turf Fertilizer 

(granule) 

432-RUOL 

80 acres 

(sodfarm) 

40 acres 

(golf course) 

BCSAA10717 

0.0213% Plus 

Turf Fertilizer 

(granule)432-

RUOA 

10 acres 

cemeteries 

BCSAA10717 

0.0284% Plus 

Turf Fertilizer 

(granule) 

432-RUOT 

Annual grasses and weeds 

in turfgrass, (golf courses 

and sod farms; lawns, 

cemeteries 

Tractor-drawn 

spreader and 

push type 

spreader and 

belly grinder for 

use on lawns and 

parks 

0.071 lb ai/A 

5 acres 

(parks and 

commercial 

lawns) 

Not to exceed 0.088 

lb ai/A per year 

Page 8 of 21 
1 acre (belly 

grinder) 

Residential Products 

Lawn 3FL 

Concentrate 

/Ready to 

spray 

72155-IO 

Pump style tank 

sprayer; hoseend sprayer 

concentrate; prepacked hose-end 

ready to spray; 

low pressure 

handwand 

0.094 lb ai/A 0.5 acres 

Lawn 3FL 

Granule 

72155-OR 

Push type 

spreader and 

belly grinder 

0.044 lb ai/A 0.5 acres Do not repeat 

applications within 6 

months 

Lawn 3FL 

Concentrate 

Ready to Use 

72155-ON 

Residential lawns, hard 

scapes and ornamentals 

Trigger sprayer 0.00026 lb ai 

/gal 

1 gallon As needed 

4.0 RESIDENTIAL (NON-OCCUPATIONAL) EXPOSURE 

4.1 Residential Handler Exposure and Risk

The Agency uses the term “Handlers” to describe those individuals who are involved in 

the pesticide application process. Three indaziflam turf products (i.e., Lawn 3 FL 

Concentrate/Ready-to-Spray, Lawn 3 FL Granule, and Lawn 3 FL Ready-To-Use) can be 

applied by home owners. These products are to be applied using hand held sprayers 

(pump style tank, hose end, and trigger) or drop/push rotary-type spreaders. The 

following use scenarios and sources of unit exposures were used to assess handler 

exposure: 

1. mixer/loader/applicator for garden hose end sprayer (PHED) 

2. mixer/loader/applicator for hose end sprayer – Mix-Your-Own (ORETF) 

3. mixer/loader applicator for belly grinder (PHED) 

4. mixer/loader/applicator for hand held pump sprayer (ORETF) 

5. mixer/loader/applicator for trigger sprayer read to use 

6. applicator for granular push spreader (ORETF) 

7. applicator hose-end ready-to-use sprayer (ORETF) 

4.1.1 Turf Data and Assumptions: 

Unit Exposures: No chemical specific unit exposure data were provided in support 

of this submission; therefore, Pesticide Handlers Exposure Database (PHED) Surrogate 

Exposure Guide and the Outdoor Residential Exposure Task Force (OREFT) study 

(MRID 44972201) unit exposures were used to estimate handler exposure. 

Acres/Amount Treated: Information regarding area treated for the various use 

scenarios was provided by the Science Advisory Council for Exposure Policy #12: 

Page 9 of 21 
Recommended Revisions to the Standard Operating Procedures (SOPs) for Residnetial 

Exposure Assessments. 

Application Rate and Amount Handled: 

 0.094 lb ai per acre for broadcast treatment using liquids 

 0.044 lbs ai per acre using granular formulation 

 0.00026 lb ai /gal using trigger spray for spot treatment

Exposure Duration: Based on information provided in the proposed labels, handler 

exposure is anticipated to be short- and intermediate-term in duration. 

Body Weight: The average adult body weight of 70 kilograms was used to assess handler 

exposure as endpoint was not gender specific. 

4.1.2 Residential Turf Handler Exposure and Risk

HED’s level of concern for risks (i.e., Margins of Exposure (MOE)) for indaziflam is 100 

for residential exposure. Since a short-term dermal point was not selected, the only route 

of exposure to be addressed is inhalation. Handler inhalation MOEs were significantly 

greater than 100 and therefore not of concern to HED. Inhalation exposure for residential 

handlers is summarized in Table 4.1.2. 

Table 4.1.2: Indaziflam Handler Exposure and Risk 

Turf 

Exposure 

Scenarios 

Use Site Inhalation 

Unit 

Exposure 

(mg/lb) a

Application 

Rate b

 (lb ai/acre) 

Area 

Treated 

(A/day) 

Inhalation 

Dose c

(mg/kg/day) 

 MOE d

Mixer/Loader/Applicator 

Garden Hose 

End Sprayer 

(PHED) 

72155-IO 

0.0095 0. 094 6.38E-6 1,100,000 

Hose-end 

Sprayer “Mix 

Your Own” 

(ORETF – 

OMA004)) 

0.017 0.094 1.14E-5 660,000 

Belly Grinder 

(PHED) 

72155-OR 

0.062 0.044 1.95E-5 380,000 

Hand-Held 

Pump Sprayer 

(ORETFOMA005) 

72155-IO 

0.0038 0. 094 

0.5 

2.55E-6 2,900,000 

Trigger 

sprayer 

Ready to Use 

(ORETF –

OMA006) 

72155-ON 

lawns, 

hardscapes 

and 

ornamentals 

0.0019 

 0.00026 

lbai/gal 

1 gal 7.0E-9 

100,000,000 

Applicator 

Granular Push lawns 0.00088 0.044 2.77e-7 27,000,000 

Page 10 of 21 
Table 4.1.2: Indaziflam Handler Exposure and Risk 

Turf 

Exposure 

Scenarios 

Use Site Inhalation 

Unit 

Exposure 

(mg/lb) a

Application 

Rate b

 (lb ai/acre) 

Area 

Treated 

(A/day) 

Inhalation MOE d

Dose c

(mg/kg/day) 

Spreader 

(ORETF –

OMA003) 

72155-OR 

Hose End 

Sprayer 

Ready to Use 

(ORETF – 

OMA004) 

72155-IO 

lawns, 

hardscapes 

and 

ornamentals 

0.011 0. 094 

0.5 

7.39E-6 1,000,000 

a. Inhalation Unit Exposure derived from PHED Version 1.1 and ORETF Handler Exposure Study MRID 44972201 

b. Application Rate based on proposed labels 

c. Inhalation Dose = Unit Exposure (mg/lb) x Application Rate (lb ai/day) x Area Treated/BW 

d. Inhalation MOE = NOAEL (7.5 mg/kg/day) 

 Inhalation Dose

4.2 Residential Postapplication Exposure 

Since a dermal endpoint was not selected the only postapplication residential scenario 

quantitatively assessed for this action is oral non-dietary ingestion exposures for children 

(i.e. soil ingestion, and hand-/object-to-mouth). The oral postapplication scenarios 

resulting from commercial and residential applications were assessed using the HED 

Draft Standard Operating Procedures (SOP’s) for Residential Exposure Assessments, 

2000. Residential postapplication oral exposure and risk resulting in MOEs greater than 

or equal to 100 are not of concern. 

4.2.1 Hand-To-Mouth Assumptions, Exposure, and Risk

This scenario assumes that pesticide residues are transferred to the skin of children 

playing on treated areas and are subsequently ingested as a result of hand-to-mouth 

transfer. 

Assumptions:

• On the day of application, it may be assumed that 5% of the application rate is 

available on turf grass as transferable residue. 

• Oral postapplication exposure was estimated using the standard assumption for 

the initial fraction of residues available and assuming a 10% daily dissipation rate. 

• The median surface area of both hands is 20 cm2

 for children. 

• It is assumed that there is a one-to-one relationship between the dislodgeable 

residues on the turf and on the surface area of the skin after contact. 

• The mean rate of hand-to-mouth activity is 20 times/hour for short-term exposure 

scenarios. 

• The saliva extraction factor is 50% 

• The children are assumed to weigh 15 kg 

• Duration of exposure for children is assumed to be 2 hours per day for turf 

Page 11 of 21 
Equations:

TTRt = AR x F x (1-D)t x CF2 x CF3 

AR = application rate (lb ai/ft2 or lb ai/acre or mg ai) 

F = fraction of ai available on turf (unitless) 

D = fraction of residue that dissipates daily (unitless) (0.1) 

t = postapplication day on which exposure is being assessed 

CF2 = weight unit conversion factor to convert the lbs ai in the application rate to ug 

 for DFR value (4.54E8

 ug/lb) 

CF3 = area unit conversion factor to convert the surface area units (ft2

) in the 

 application rate to cm2

 for the DFR value (1.08E-3 ft 2 /cm2 or 2.47E-8 acre/cm2) 

TTR = Turf Transferable Residue 

 

PDR = TTR x SA x FQ x ET x SE x CF1 

BW 

 

PDR = potential dose rate (mg/day) 

TTR = turf transferable residue (ug/cm2

 turf) 

SA = surface area of the hands (cm2

/event) 

FQ = frequency of hand-to-mouth activity (20 events/hr for short-term) 

ET = exposure time (hr/day) 

CF1 = weight unit conversion factor to convert ug units in the TTR value to mg for the 

 daily exposure (0.001 mg/ug for turf) 

SE = Saliva Extraction Factor (50%)

BW = 15 kg

Hand-to-Mouth Exposure and Risk 

All short-term hand-to-mouth (HTM) scenarios resulted in MOEs greater than the level 

of concern (MOEs ≥ 100) and therefore pose no risk of concern. Although a quantitative 

assessment of intermediate-term HTM exposure was not performed since the short- and 

intermediate-term endpoints are the same, short-term exposure and risk would be 

protective of intermediate-term exposure. Table 4.2.1 provides a summary of the shortand intermediate-term HTM exposures. 

Table 4.2.1: Hand-To-Mouth Exposure and Risk 

Product TTR 1 

(ug/cm2) 

SA 

(cm2/event) 

FQ SE ET 

(hr/day) 

CF BW 

(kg) 

HTM Dose 2 

(mg/kg/day) 

HTM 

MOE 3

Commercial Product 

BCS AA10717 

Turf Fertilizer 

(432-RUOL; 432-

RUOA; and 432-

RUOT) and 20 

WSP (432-RUOO) 

3.98E-2 20 20 0.5 2 0.001 15 1.06E-3 7,000 

Residential Product 

Lawn 3FL 

(72155-IO) 

5.27E-2 20 20 0.5 2 0.001 15 1.41E-3 5,300 

1. Turf Transferable Residues = (TTR) = 

AR (0.071 lb ai/A = commercial product; or 0.094 lb ai/A = residential product) x F (0.05) x (1-D)0

 x CF2 (4.54E8 

μg/lb) x CF3 (2.47E-8 acre /cm2

) = 3.98E-2 or 5.27E-2 ug/cm2

2. HTM Dose = TTRt x SA x FQ x ET x SE x CF1 

Page 12 of 21 
 BW 

3. HTM MOE = NOAEL (7.5 mg/kg/day)/HTM Dose (mg/kg/day) 

4.2.2 Object to Mouth (Ingestion of Treated Turf) Assumptions and Equations 

This scenario estimates doses to toddlers, resulting from incidental ingestion of pesticide 

and or residential turf grass that has been previously treated with pesticides. It assumes 

that pesticide from a treated object or turf is ingested by toddlers who play on treated 

areas. 

Assumptions: 

• On the day of application it may be assumed that 20% of the application rate is 

available to be ingested.

• Oral postapplication exposure was estimated using the standard assumption for 

the initial fraction of residues available and assuming a 10% dissipation rate. 

• Assumed ingestion rate for grass for children (3 years old) is 25 cm2/day.

• Children are assumed to weigh 15 kg.

Equations: 

GRt = AR x F x (1-D)t x CF2 x CF3

GRt = grass residue on day t (ug/cm2) 

AR = application rate (lb ai/A) 

F = fraction of ai available on the grass (unitless) 

D = fraction of residue that dissipates daily (unitless) (0.1) 

t = postapplication day on which exposure is being assessed 

CF2 = weight unit conversion factor to convert the lbs ai in the application rate to μg 

 for grass residue value (4.54E8 μg/lb) 

CF3 = area unit conversion factor to convert surface area units (A) in the application 

 rate to cm2

 for grass residue value (2.47E-8 A/cm2)

PDD = GR t x IgR x CF1

PDD = potential daily dose (mg/kg/day) 

GRt = grass residue (ug/cm2

) 

IgR = ingestion rate of grass (cm2

/day) 

CF1 = weight unit conversion factor to convert the μg of residues on the grass to mg to 

 provide units of mg/day (1E-3 mg/μg) 

Object-To-Mouth (OTM) Exposure and Risk 

The object-to-mouth scenario resulted in a MOE greater than the level of concern (MOEs 

≥ 100) and therefore poses no risk of concern. Table 4.2.2 provides a summary of the 

OTM exposure and risk. 

Page 13 of 21 
Table 4.2.2: Object–to-Mouth Exposure and Risk

Product GR 1 

(ug/cm2) 

CF 

(mg/μg)

IgR 

(cm2/day) 

BW 

(kg) 

OTM Dose 2 

(mg/kg/day) 

OTM 

MOE 3

BCS AA10717 Turf Fertilizer 

(432-RUOL; 432-RUOA; and 

432-RUOT) and 

20 WSP (432-RUOO) 

1.59E-1 0.001 25 15 2.65E-4 28,000 

Lawn 3FL 

(72155-IO) 

2.11E-1 0.001 25 15 3.51E-4 21,000 

1. GR (grass residue) = Application Rate x F x (1-D)0 x CF2 x CF3 

2. OTM Dose = GR 0 x IgR x CF1 

3. OTM MOE = NOAEL (7.5 mg/kg/day)/OTM Dose (mg/kg/day) 

4.2.3 Incidental Ingestion of Soil Assumptions, Exposure and Risk 

This scenario assumes pesticide residues in soil are ingested by toddlers who play on 

treated areas as a result of normal mouthing activities. 

Assumptions: 

• on the day of application, it is assumed that 100% of the application rate is located 

within the soil’s uppermost 1 cm. 

• Postapplication must be assessed on the same day the pesticide is applied. 

• Assumed soil ingestion rate for children is 100 mg/day. 

• Children are assumed to weigh 15 kg. 

Equations:

SR0 = AR x F x (1-D)t x CF2 x CF3 x CF4

SR0 = soil residue on day 0 (ug/g) 

AR = application rate (lb ai/A) 

F = fraction of ai available in uppermost cm of soil (1 cm) 

D = fraction of residue that dissipates daily (unitless) 

t = postapplication day on which exposure is being assessed (day 0) 

CF2 = weight unit conversion factor to convert the lbs ai in the application rate to μg 

 for soil residue value (4.54E8 μg/lb) 

CF3 = area unit conversion factor to convert surface area units (A) in the application 

 rate to cm2

 for soil residue value (2.47E-8 A/cm2)

CF4 = volume to weight unit conversion factor to convert the volume units (cm3) to 

 weight units for the SR value (0.67 cm3

/g soil)

PDD = SR0 x IgR x CF1

PDD = potential daily dose on day 0 

SR0 = soil residue on day 0 (ug/g) 

IgR = ingestion rate of soil (mg/day) 

CF1 = weight unit conversion factor to convert the μg of residues on the soil to mg to 

 provide units of mg/day (1E-6 g/μg) 

Page 14 of 21 
Soil Ingestion Exposure and Risk 

The soil-ingestion scenario resulted in a MOE much greater than the level of concern 

(MOEs ≥ 100) and therefore poses no risk of concern. This assessment should be 

considered conservative in that it assumed no dissipation of soil residues would occur 

over the exposure period. Table 4.2.3 provides a summary of the soil ingestion exposure 

and risk. 

Table 4.2.3: Soil Ingestion Exposure and Risk 

Product SR 1 

(ug/g) 

CF 

(g/μg)

IgR 

(mg/day) 

BW 

(kg) 

Dose 2 

(mg/kg/day) 

MOE 3

BCS AA10717 Turf Fertilizer 

(432-RUOL; 432-RUOA; and 

432-RUOT) and 

20 WSP (432-RUOO) 

5.33E-1 0.000001 25 15 3.56E-6 2.11E6 

Lawn 3FL 

(72155-IO) 

7.06E-1 0.000001 25 15 4.71E-6 1.59E6 

1. SR0 (soil residue) = Application Rate (lb ai/A) x F(1) x (1-D)0 x 0.67 x (4.54x108 μg/lg)x (2.47 x 

10-8 A/cm2

) 

2. Soil Ingestion Dose (mg/kg/day) = SR0 (μg/g) x IgR (mg/day) x CF1 (g/μg)/BW (kg) 

3. Soil Ingestion MOE = NOAEL (7.5 mg/kg/day)/Soil Ingestion Dose (mg/kg/day) 

4.2.4 Episodic Ingestion of Granules 

This scenario was assessed using the Residential SOP and provides a standard method for 

estimating postapplication doses among toddlers from incidental ingestion of pesticide 

granules. 

 

Assumptions and Factors: 

• Ingestion rate for dry pesticide formulation (granules) is 0.3 gram/day for 3 year 

old child. 

• Average weight of toddler is 15 kg. 

• Ingestion of granules is considered an episodic event and not a routine behavior. 

Because HED does not believe that this would occur on a regular basis, our 

concern for human health is related to acute poisoning rather than short -term 

residue exposure. Therefore and acute dietary dose (NOAEL = 50 mg/kg/day) is 

used to estimate exposure and risk resulting from episodic ingestion of granules. 

Equations and Calculations: 

PDD = IgR x F x CF1 ÷ BW

PDD = Potential Daily Dose 

IgR = ingestion rate of dry pesticide formulation (0.3 grams/day) 

F = fraction of ai in dry formulation (0.0005) 

CF = weight unit conversion factor to convert g units to mg for daily 

 exposure (1,000 mg/g) 

BW = Body Weight (15kg) 

Ingestion of Granules MOE = NOAEL (50 mg/kg/day) ÷ Dose 

Page 15 of 21 
Exposure and Risk

The episodic oral MOE for incidental ingestion of granules is 5,000 and therefore is not 

of concern. Table 4.2.4 provides a summary or exposure risk. 

Table 4.2.4: Postapplication Exposure and Risk for Incidental Ingestion of Granules 

Scenario IgR 

(g/day) 

F CF1 

(mg/g) 

Dose a

(mg/kg/day) 

MOE b

Lawn 3FL Granule Reg. No. 72155-OR 0.3 0.0005 1000 0.001 5,000 

a. Dose = IgR x F x CF1 ÷ BW 

b. MOE = acute dietary NOAEL (50 mg/kg/day)/Dose 

4.3 Combined Residential Risk Estimates

HED combines risk values resulting from separate exposure scenarios when it is likely 

they can occur simultaneously based on the use-pattern and the behavior associated with 

the exposed population. In evaluating combined residential uses of indaziflam, HED 

reviewed all non-dietary sources of exposure which consisted of only adult inhalation 

handler (lawns only) exposure and child postapplication oral exposures of toddlers. The 

oral postapplication exposure resulted from hand-to-mouth exposure only, since it 

represents the worst case of oral exposure. To include exposure from object-to-mouth 

and soil ingestion in addition to hand-to-mouth could result in a very conservative 

estimation of exposure as it would overestimate the potential of oral exposure. A 

postapplication assessment for adults (homeowner and golfer) was not performed since 

there is no dermal endpoint and all uses are outdoors where inhalation exposure is 

expected to be minimal. Therefore, a combined residential assessment is not required. 

Table 4.3 identifies the residential scenarios and MOEs for adult and children 

subpopulations simply for use in performing an aggregate exposure assessment in the 

indaziflam human health risk assessment. 

Table 4.3: Combined Residential Exposure and Risk 

Product Use Site Handler 

Inhalation 

MOE 1

Post-application 

Inhalation 

MOE 

Hand-to-Mouth 

MOE 2

MOE 

Adult Handler 

Lawn 3FL Concentrate 

/Ready to spray 

72155-IO 

Lawns, 

hardscapes 

and 

ornamentals 

370,000 NA NA 370,000 

Child Postapplication

Lawn 3 FL (72155-IO) Lawns, 

hardscapes 

and 

ornamentals 

NA NA 

5,300 5,300 

1. See Table 4.1.2: Indaziflam Handler Exposure and Risk 

2. See Table 4.2.1 Hand-To-Mouth Exposure and Risk 

Page 16 of 21 
4.4 Other (Spray Drift, etc) 

Spray drift is always a potential source of exposure to residents nearby to spraying 

operations. It is noted that the 0.094 lb ai/acre application rate for turf was modeled to 

estimate postapplication residential exposure of children (ages 1 to 6 years of age). As 

this rate is equal to or higher than many of the agricultural application rates, this scenario 

is protective of any exposure of farm children via spray drift from agricultural indaziflam 

applications. 

 

5.0 OCCUPATIONAL EXPOSURE

The proposed use of indaziflam is for control of many annual grasses and broadleaf 

weeds in turf (lawns, sod farms, golf courses, recreational fields, etc), ornamentals and 

trees. It is also proposed for use as a pre-emergent herbicide for weed control in parks, 

rail roads, utility, industrial and municipal sites. Indaziflam is available for use by 

commercial and professional applicators (formulated as a water soluble packet and turf 

fertilizers). Therefore, the potential for occupational handler and postapplication 

exposure does exist. 

5.1 Occupational Handlers 

Based upon the proposed use pattern, HED expects the most highly exposed occupational 

pesticide handlers are likely to be: 

1) mixing/loading liquids for aerial applications (PHED); 

2) mixing/loading liquids for ground applications (PHED); 

3) mixing/loading liquids for right-of-way sprayer (PHED); 

4) mixing/loading water soluble packets (PHED); 

5) loading granulars of fertilizers using tractor-drawn granular spreader (PHED); 

6) applying sprays via aerial equipment (PHED); 

7) applying sprays via groundboom equipment (PHED); 

8) applying spray using right-of-way sprayer (PHED); 

9) applying granules using solid broadcast spreader (PHED); 

10) loading/applying granules by LCO for push cyclone spreader (ORETF); 

11) loading/applying granules for belly grinder (PHED); 

12) flagging for aerial sprays applications (PHED); 

13) mixing/loading/applying liquids with low-pressure handwand (PHED); 

14) mixing/loading/applying liquids with a backpack sprayer (PHED); and 

15) mixing/loading/applying liquids with handgun sprayer (ORETF). 

No chemical specific data were available to assess potential exposure to pesticide 

handlers. The estimates of exposure to pesticide handlers are based upon surrogate study 

data available in the PHED (v. 1.1, 1998) and from the Outdoor Residential Exposure 

Task Force (ORETF). For pesticide handlers, it is HED standard practice to present 

estimates of dermal exposure for “baseline” that is, for workers wearing a single layer of 

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

protective gloves, as well as for “baseline” and the use of protective gloves or other 

Page 17 of 21 
Personal Protective Equipment (PPE) as might be necessary. The proposed product label 

involved in this assessment directs applicators and other handlers to wear long sleeved 

shirt and long pants, shoes plus socks, and chemical resistant gloves. 

Handler exposure is expected to be short- or intermediate-term in duration based on 

information provided on proposed labels. In addition, the short- and intermediate-term 

toxicological endpoints are the same; therefore, the estimates of risk for short-term 

duration exposures are protective of those for intermediate-term durations. Long-term 

exposures are not expected; therefore, a long-term assessment was not conducted. 

 

As indicated previously, a dermal endpoint was not selected; therefore, a dermal exposure 

assessment was not conducted. Daily inhalation handler exposures are estimated for each 

applicable handler task with the application rate, the area treated in a day, and the 

applicable inhalation unit exposure using the following formula: 

Daily Exposure (mg ai/day) = Unit Exposure (mg ai/lb ai handled) x Application 

Rate (lbs ai/area) x Daily Area Treated (area/day) 

Where: 

Daily Exposure = Amount (mg or μg ai/day) inhaled that is available for 

inhalation absorption; 

Unit Exposure = Unit exposure value (mg or μg ai/lb ai) derived from August 

1998 PHED data or from ORETF data; 

Application Rate = Normalized application rate based on a logical unit treatment, 

such as acres, square feet, or gallons. Maximum values are 

generally used (lb ai/A, lb ai/sq ft, lb ai/gal); and 

 Daily Area Treated = Normalized application area based on a logical unit treatment 

such as acres (A/day), square feet (sq ft/day), gallons per day 

(gal/day). 

The daily inhalation dose is calculated by normalizing the daily exposure by body weight 

and adjusting, if necessary, with an appropriate dermal or inhalation absorption factor 

using the following formula: 

Average Daily Dose (mg/kg/day) = Daily Exposure (mg ai/day) x (Absorption Factor 

(%/100) / Body Weight (kg) 

Where: 

Average Daily Dose = Absorbed dose received from exposure to a pesticide 

in a given scenario (mg pesticide active ingredient/kg 

body weight/day); 

Daily Exposure = Amount (mg ai/day) inhaled that is available for 

inhalation absorption; 

Absorption Factor = A measure of the amount of chemical that crosses a 

biological boundary such as the lungs (% of the total 

available absorbed; 100% ); and 

Body Weight = Body weight determined to represent the population 

of interest in a risk assessment (70 kg for indaziflam). 

Page 18 of 21 
Inhalation risks for each applicable handler scenario are calculated using a MOE, which 

is a ratio of the NOAEL or LOAEL to the daily dose. In the case of indaziflam, a 

NOAEL was used in the calculation. All MOE values were calculated using the formula 

below: 

MOE= NOAEL (mg/kg/day) / Daily Dose (mg/kg/day) 

Occupational Handler Exposure and Risk 

Table 5.1 presents the estimated risks for workers based on the short- and intermediateterm inhalation exposures at baseline (i.e. no respirator). Short- and intermediate-term 

risks for handlers are not of concern (i.e., MOEs are above 100). 

Table 5.1. Occupational Handler Inhalation Exposures and Risks

Exposure Scenario 

and Product Target site Application 

Ratea

Inhalation Unit 

Exposures 

(mg/lb ai) 

Area 

Treated 

Daily b 

Inhalation 

Doses 

(mg/kg/day)c 

Inhalation 

MOEsd

Mixer/Loader 

Liquids for Aerial 

Applications 

(PHED) 

Esplanade F 

forestry 0.125 lb ai/A 

1200 A 0.002571 2900 

Liquids for 

Ground 

Applications 

(PHED) 

Esplanade F 

forestry 0.125 lb ai/A 200 A 0.000429 10,000 

25 A 3.81E-5 196,000 Liquids for 

Ground, and 

Right-of-Way, 

Applications 

(PHED) 

Esplanade 200SC

non-crop areas, rail 

road yards, 

roadsides, 

ornamental and 

perennial plantings, 

fence rows, utilities, 

hardscapes, 

industrial, municipal 

and government site 

0.089 lb ai/A 

Baseline e

: 

 0.0012 

40 A 6.1-5 

120,000 

Non-crop areas, turf 

grass, nurseries, 

landscapes 

5 A 1.22E-6 

6,000,000 

Golf course and 

fields grown for 

ornamentals 

40 A 9.74E-6 770,000 

sod farm and , 

Christmas tree 

farms 

0.071 lb ai/A 

(non-crop) 

80 A 1.95E-5 390,000 

Water Soluble 

Packets 

Ground

Applications 

(PHED) 

BCS-AA10717 

 20 WSP

forestry 0.088 lb ai/A 

Baselinee

 

0.00024 

200 A 0.000060E-5 120,000 

Lawns, recreational 

fields and parks 

 

5 A 8.62E-6 870,000 

golf course 

 40 A 6.9E-5 100,000 

Loading 

Granulars 

for Tractor Drawn 

Spreader 

Applications 

(PHED) 

BCS-AA10717 plus 

turf fertilizer 

(0.0142%, 

0.0213%, and 

0.0284%)

sod farm 

0.071 lb ai/A Baseline e: 

0.0017 

80 A 0.000138 54,000 

Page 19 of 21 
Table 5.1. Occupational Handler Inhalation Exposures and Risks

Exposure Scenario 

and Product

Inhalation Unit Area Inhalation Application Inhalation Target site Ratea Exposures 

(mg/lb ai) 

Treated Doses MOEsd

Daily b (mg/kg/day)c 

Applicators 

Applying Sprays 

via Aerial 

Equipment 

(PHED) 

forestry 0.125 lb ai/A 

Esplanade F

Eng controlf

: 

0.000068 1200 A 0.000146 51,000 

0.125 lb ai/A 

Esplanade F

0.000264 28,000 

forestry 0.088 lb ai/A 

BCSAA10717 

 20 WSP

200 A 

0.000186 40,000 

non-crop areas, rail 

road yards, 

roadsides, 

ornamental and 

perennial plantings 

0.089 lb ai/A 

Esplanade 

200SC

40 A 

3.76E-5 200,000 

Non-crop sites, turf 

and recreation fields 5 A 3.75E-6 2,000,000 

Golf course and 

field grown for 

ornamentals and 

nurseries 

40 A 3.0E-5 250,000 

Applying Sprays 

via Groundboom

Equipment 

(PHED) 

Sod and Christmas 

tree farms, 

0.071 lb ai/A 

BCSAA10717 

 20 WSP

Baseline e: 

0.00074 

80 A 6.0E-5 120,000 

Applying Sprays 

via Right-of-Way

Equipment 

(PHED) 

non-crop areas, rail 

road yards, 

roadsides, 

ornamental and 

perennial plantings, 

fence rows, utilities, 

hardscapes, 

industrial, municipal 

and government 

sites, 

0.089 lb ai/A 

Esplanade 

200SC

Baseline e: 

 0.0039 25 A 0.000124 60,000 

Lawns, turf, sports 

and recreation parks 

 

5 A 6.09E-6 1,000,000 

golf courses 

 40 A 4087E-5 150,000 

Applying Granules 

using Solid 

Broadcast 

Spreader (PHED) sod farms 

0.071 lb ai/A 

BCSAA10717 

plus turf 

fertilizer 

(0.0142%, 

0.0213%, 

and 

0.0284%)

0.0063 

80 A 9.74E-5 77,000 

Lawns, turf, sports 

and recreation parks 

 

5 A 3.7E-5 200,000 

golf courses 

 40 A 0.000296 25,000 

LCO Push 

Cyclone Granular 

Spreader

(OMA001)ORETF sod farms 

0.071 lb ai/A 

0.0073 

80 A 0.00532 12,000 

Page 20 of 21 
Table 5.1. Occupational Handler Inhalation Exposures and Risks

Exposure Scenario 

and Product

Inhalation Unit Area Inhalation Application Inhalation Target site Ratea Exposures 

(mg/lb ai) 

Treated Doses MOEsd

Daily b (mg/kg/day)c 

Belly Grinder

(PHED) 

Lawns, turf, sports 

and recreation parks 0.062 1 A 6.29E-5 120,000 

Flaggers 

Flagging for Aerial 

Sprays 

Applications 

(PHED) 

Esplanade F

forestry 0.125 lb ai/A Baseline e

: 

0.00035 

350 A 0.000219 34,000 

Mixer/Loader/Applicator 

0.125 lb ai/A 5 A 0.000268 28,000 

Forestry 

Esplanade F 0.0248 lb 

ai/gal 40 gals 0.000425 18,000 

0.089 lb ai/A 5 A 0.000191 39,000 

Mixing/Loading/ 

Applying Liquids 

with Low Pressure 

Handwand and 

Back Pack 

(PHED) 

non-crop areas, rail 

road yards, 

roadsides, 

ornamental and 

perennial plantings, 

fence rows, utilities, 

hardscapes, 

industrial, municipal 

and government 

sites 

Esplanade 200SC

0.0178 lb 

ai/gal 

Baseline e : 

 0.03 

40 gals 0.000305 25,000 

0.071 

BCS-A10717 

 20 WSP

Baseline e: 

0.0072 0.0000365 200,000 Mixing/Loading/ 

Applying Liquid 

Concentrates with 

a Handgun Sprayer 

(LCO ORETF) 

Non-crop sites, turf, 

recreation fields, 

Christmas tree 

farms, ornamentals 

and nurseries 

0.089 

Esplanade 

200SC

0.0018 

5 A 

0.000014E-5 650,000 

a Application rates = maximum application rates from labels. 

b Amount handled per day values are HED estimates of acres treated per day based on Exposure SAC SOP #9 “Standard 

Values for Daily Acres Treated in Agriculture,” industry sources, and HED estimates. 

c Dose (mg/kg/day) = Unit exposure(mg/lb ai) x App Rate (lb ai/acre) x Area Treated (acres/day) x %Absorption 

(100% inhalation) / Body weight (70 kg). 

d MOE = NOAEL (mg/kg/day) / Dose (mg/kg/day) 

e Baseline Inhalation: no respirator. 

f. Eng Con: Engineering control is enclosed cab, or enclosed cockpit. 

. 

5.2 Occupational/Commercial Postapplication Exposure 

HED assumes that inhalation exposures are minimal following outdoor applications of an 

active ingredient, due to the large volume of air exchange. Therefore, a quantitative 

inhalation postapplication risk assessment was not conducted. Furthermore, since a 

dermal endpoint was not selected, a postapplication exposure assessment was not 

conducted either. Therefore, the REI will be based on acute toxicity of the technical 

material, indaziflam. Since indaziflam has low acute toxicity by all routes of exposure 

(Toxicity Category III, oral and dermal and Category IV, inhalation) and is not an ocular 

or dermal irritant or a dermal sensitizer, HED has no objection to the proposed 12-hour 

restricted entry interval (REI) in accordance with the WPS. 

Page 21 of 21