Page 3 of 59 

TABLE OF CONTENTS 

1.0 EXECUTIVE SUMMARY ................................................................................................ 4 

2.0 HAZARD CHARACTERIZATION................................................................................... 6 

2.1 ACUTE TOXICOLOGY CATEGORIES .................................................................................. 6 

2.2 POINTS OF DEPARTURE .................................................................................................... 7 

3.0 PROPOSED USE PATTERNS .......................................................................................... 8 

3.1 OCCUPATIONAL-USE PRODUCTS...................................................................................... 8 

3.2 TYPE OF PESTICIDE/TARGETED PEST ............................................................................... 8 

3.3 FORMULATION TYPES AND PERCENT ACTIVE INGREDIENT.............................................. 9 

3.4 REGISTERED USE SITES.................................................................................................... 9 

4.0 OCCUPATIONAL EXPOSURE/RISK PATHWAY....................................................... 12 

4.1 OCCUPATIONAL HANDLER EXPOSURES ......................................................................... 12 

4.1.1 Occupational Handler Assumptions ......................................................................... 12 

4.1.2 Occupational Handler Equations .............................................................................. 16 

4.1.3 Summary of Risk Concerns for Occupational Handlers........................................... 17 

4.1.3.1 Occupational Dermal Risks .............................................................................. 17 

4.1.3.2 Occupational Inhalation Risks.......................................................................... 18 

4.1.3.3 Occupational Combined Risks.......................................................................... 18 

4.2 OCCUPATIONAL POSTAPPLICATION EXPOSURES ............................................................ 23 

4.2.1 Occupational Dermal Postapplication Expsoures..................................................... 23 

4.2.1.1 Occupational Dermal Postapplication Assumptions and Calculations............. 23 

4.2.1.2 Summary of Dermal Risk Concerns for Postapplication Workers ................... 28 

4.2.1 Occupational Inhalation Postapplication Expsoures ................................................ 34 

5.0 RESIDENTIAL (NON-OCCUPATIONAL) EXPOSURE/RISK PATHWAY ............... 34 

5.1 RESIDENTIAL EXPOSURE................................................................................................ 34 

5.2 SPRAY DRIFT ................................................................................................................. 34 

5.3 RESIDENTIAL BYSTANDER POSTAPPLICATION INHALATION EXPOSURE......................... 35 
Page 4 of 59 

1.0 EXECUTIVE SUMMARY 

 This assessment was completed to incorporate a change to the dermal endpoint based on 

an updated BMD analysis (D376936, TXR0055350). A previous ORE assessment was 

completed in response to the Section 3 registration request for sugar beet use and as well as 

several label amendments including one for expanding use for dry bulb onion, garlic and shallot 

from regional to national use (A. Nielsen, D365459 5/27/09). The previous assessment also 

included evaluation of all currently labeled oxamyl use patterns and indicated that some 

revisions to labeled use patterns may be needed. Since the previous risk assessment was 

completed, the registrant has withdrawn all new use requests. Therefore this updated ORE 

assessment reflects the revised dermal endpoint as it applies to the current uses of oxamyl only 

and does not include any proposed new or expanded uses. 

 Oxamyl, [Methyl N', N'-dimethyl-N-[(methylcarbamoyl)oxy]-1-thio-oxamimidate], is an 

insecticide/nematicide that is formulated as a soluble concentrate liquid (24% and 42% active 

ingredient) and as a solid/technical (42% active ingredient). Oxamyl is applied with the 

following equipment: aerial equipment, chemigation, groundboom sprayer, airblast sprayer, 

spotgun (low-pressure handwand) applicator, handgun sprayer, and shank soil injection. 

Application rates for oxamyl range from 0.25 to 4 lb ai/acre. Oxamyl is a restricted use 

pesticide. At this time, products containing oxamyl are intended for occupational use only. 

HED has determined that there are potential exposures to mixers, loaders, applicators, and other 

handlers during usual use-patterns associated with oxamyl. Based on the use patterns, several 

major exposure scenarios were identified. 

Since the toxicological effects are similar (cholinesterase inhibition in red blood cells) for 

the dermal and inhalation PoDs, the dermal and inhalation risks to handlers are combined for an 

aggregate occupational assessment. Since the level of concern is 100 for dermal risks and 30 for 

inhalation risks, an aggregated risk index (ARI) is calculated. The level of concern for an ARI is 

1 (i.e., ARIs greater than 1 are not a concern). No chronic scenarios were identified. The shortand intermediate-term dermal risks are identical since the same PoD was chosen for short- and 

intermediate-term dermal assessments. The short- and intermediate-term inhalation risks are 

also identical since the same PoD was chosen for short- and intermediate-term inhalation 

assessments. 

The short- and intermediate-term dermal risks did not exceed HED’s level of concern at 

some level of risk mitigation for all handler scenarios, except: 

• Mixing/loading liquid concentrates to support aerial applications to cotton in CA and AZ 

at 1.0 lb ai/A;

• Mixing/loading liquid concentrates to support chemigation applications at 2.0 lb ai/A;

• Applying sprays by aircraft to cotton in CA and AZ at 1.0 lb ai/A.

The short- and intermediate-term inhalation risks did not exceed HED’s level of concern 

at the baseline level (no respirator) for all handler scenarios, except mixing/loading to support 

aerial applications to cotton in California and Arizona at the 1.0 lb ai/day application rate. Note 

that only the only data available for applying sprays with aircraft is for engineering controls (i.e., 

an enclosed cockpit) – the risks did not exceed HED’s level of concern for aerial applicators at 
Page 5 of 59 

baseline attire as long as enclosed cockpits are used. 

The short- and intermediate-term combined dermal plus inhalation risks did not exceed 

HED’s level of concern at some level of risk mitigation for all handler scenarios, except: 

• Mixing/loading liquid concentrates to support aerial applications to cotton in CA and AZ 

at 1.0 lb ai/A;

• Mixing/loading liquid concentrates to support chemigation applications at 2.0 lb ai/A;

• Applying sprays by aircraft to cotton in CA and AZ at 1.0 lb ai/A.

HED has determined that there are potential exposures to occupational postapplication 

workers during usual use-patterns associated with oxamyl. Three dislodgeable foliar residue 

(DFR) studies were submitted in support of the reregistration of oxamyl. The DFR studies were 

done on three crops: cucumbers, tomatoes, and citrus fruits. To represent an arid and a non-arid 

climate, two sites were chosen for each crop -- one in California and another one in Florida or 

Georgia. A soil residue dissipation study also was conducted at the California site under tomato 

plants. The results of the postapplication risk assessment indicate that for many crops, risks 

remain a concern for several days following application. 

 This exposure/risk assessment relies in part on data from studies in which adult human 

subjects were intentionally exposed to a pesticide to determine their dermal and inhalation 

exposure. Many such studies, involving exposure to many different pesticides, comprise generic 

pesticide exposure databases such as the Pesticide Handlers Exposure Database (PHED), the 

Outdoor Residential Exposure Task Force (ORETF) Database and the Agricultural Reentry Task 

Force (ARTF) Database. EPA has reviewed all the studies in these multi-pesticide generic 

exposure databases, and on the basis of available evidence has found them to have been neither 

fundamentally unethical nor significantly deficient relative to standards of ethical research 

conduct prevailing when they were conducted. There is no regulatory barrier to continued 

reliance on these studies, and all applicable requirements of EPA’s Rule for the Protection of 

Human Subjects of Research (40 CFR Part 26) have been satisfied. 
Page 6 of 59 

2.0 HAZARD CHARACTERIZATION 

2.1 Acute Toxicology Categories 

Table 1 presents the acute toxicity categories as outlined in the Oxamyl - Report of the 

Hazard Identification Assessment Review Committee, dated August 31, 1999. 

Table 1: Acute Toxicity Categories of Oxamyl 

Study Type Toxicity Category 

 (technical) 

Acute Oral Toxicity I 

Acute Dermal Toxicity IV 

Acute Inhalation Toxicity II 

Primary Eye Irritation III 

Primary Dermal Irritation IV 

Dermal Sensitization Not a skin sensitizer 
Page 7 of 59 

2.2 Points of Departure 

Dermal and inhalation points of departure (PoDs) have been identified for short-term (1 

to 7 days) and intermediate-term (one week to several months) exposures (E. Reaves, D379814, 

7/1/2010). These PoDs are listed in Table 2. 

Table 2. Summary of Toxicological Dose and Points of Departure for Oxamyl 

for Use in Human Health Risk Assessment 

Exposure 

Scenario 

Point of Departure 

(mg/kg/day) 

Uncertainty/ 

FQPA Safety 

Factors 

RfD, PAD, LOC 

for Risk 

Assessment 

Study and Toxicological 

Effects 

Acute Dietary 

All populations 

0.069 mg/kg 

UFA=1x 

UFH=10x 

FQPA SF=2.64x 

(brain) 

aRfD=0.0069 

aPAD= 0.0026 

(1⁄2 -life 2.5 hours) 

Human Study (MRID 

44912301) 

BMD10= 0.083 mg/kg 

BMDL10= 0.069 mg/kg, based 

on RBC AChE inhibition 

Chronic 

Dietary 

Due to the rapid recovery of ChE activity, the acute exposure from oxamyl is the main duration of 

concern and therefore a chronic assessment is not appropriate for oxamyl. 

Incidental Oral 

(All durations) Based on the current oxamyl uses, an incidental oral endpoint is not required. 

Dermal 8.0 mg/kg 

 (RBC ChE) 

UFA=10x 

UFH=10x 

FQPA SF=1x 

MOE = 100 

(adult) 

21-day dermal rabbit study 

(40827601) 

RBC BMD10 is 23.1 mg/kg 

RBC BMDL10 is 8.0 mg/kg 

Dermal 

Long-Term 

(>6 mos) 

Due to the rapid recovery of ChE activity, the acute exposure from oxamyl is the main duration of 

concern and therefore a long-term assessment is not appropriate for oxamyl. 

Inhalation 

RBC Occupational: 

HEC = 2.25 mg/m3 or 

0.39 mg/kg 

RBC Non-Occupational: 

HEC= 0.75 mg/m3

 or 

0.13 mg/kg 

UFA=3x 

UFH=10x 

FQPA SF= 1x 

MOE = 30 (adult, 

occupational) 

Acute inhalation rat 

(45155801) 

RBC BMD10= 0.002 mg/L 

RBC BMDL10= 0.0018 mg/L, 

based on RBC AChE 

inhibition in both sexes. 

Inhalation 

Long-Term 

(>6 mos) 

Due to the rapid recovery of ChE activity, the acute exposure from oxamyl is the main duration of 

concern and therefore a long-term assessment is not appropriate for oxamyl. 

Cancer (oral, 

dermal, 

inhalation) 

Determined to be “not likely” a human carcinogen (Memorandum: HIARC report, Geruva Reddy, 

8/31/1999) 

1 Explanation of Abbreviations: UF = uncertainty factor. UFA = extrapolation from animal to human (interspecies). UFH = 

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

aPAD = population adjusted dose. RfD = reference dose. MOE = margin of exposure. LOC = level of concern. N/A = not 

applicable. HEC = Human Equivalent Concentration. RDDR = regional deposited dose ratio. 

 

 
Page 8 of 59 

 Cancer Determination 

 Oxamyl was determined to be “not likely” a human carcinogen (Memorandum: HIARC 

report, Geruva Reddy, 8/31/1999). 

 

FQPA Safety Factor 

Since the time of the 1999 RED, the comparative cholinesterase study in which the sensitivity of 

the young to NMC’s is best evaluated has become available. Similar to results in comparative 

cholinesterase studies with other N-methyl carbamates, this comparative cholinesterase study 

revealed that PND11 pups are more sensitive to oxamyl than adult rats. The FQPA factor is 

based on the ratio of the adult BMD10 to PND11 BMD10. Cholinesterase data from this one 

comparative cholinesterase study indicates that the PND11 pups were 2.64 fold more sensitive 

than adult rats to brain cholinesterase inhibition. The FQPA factor is not appropriate for 

pregnant females since the developmental studies did not indicate susceptibility. Therefore, for 

the single chemical risk assessment for oxamyl, the FQPA factor may be applied to the oral, 

dermal, and inhalation assessments for those scenarios involving children. 

Levels of Concern 

The levels of concern for occupational handlers and postapplication workers are 100 for 

dermal risk and 30 for inhalation risk. 

Combined Risks 

Since the toxicological effects are similar (cholinesterase inhibition in red blood cells) for 

the dermal and inhalation PoDs, the dermal and inhalation risks to handlers are combined for an 

aggregate occupational assessment. Since the level of concern is 100 for dermal risks and 30 for 

inhalation risks, an aggregated risk index (ARI) is calculated. The level of concern for an ARI is 

1 (i.e., ARIs greater than 1 do not exceed HED’s level of concern). 

3.0 REGISTERED USE PATTERNS 

3.1 Occupational-Use Products 

Oxamyl [Methyl N', N'-dimethyl-N-[(methylcarbamoyl)oxy]-1-thio-oxamimidate] is an 

insecticide/nematicide/plant regulator that is registered for use on terrestrial food crops and 

terrestrial food and feed crops. 

3.2 Type of Pesticide/Targeted Pest 

Oxamyl is an insecticide, nematicide, and plant regulator. 
Page 9 of 59 

3.3 Formulation Types and Percent Active Ingredient 

Oxamyl is formulated as a soluble concentrate/liquid (24% and 42% active ingredient) 

and as a solid/technical (42% active ingredient). 

3.4 Registered Use Sites 

Table 3 lists the occupational use sites, the maximum application rates, and the 

application equipment for each of the registered uses of oxamyl. Current oxamyl labels state that 

oxamyl can only be used on commercial and farm plantings. Oxamyl is applied with the 

following equipment: aerial equipment, chemigation, groundboom sprayer, airblast sprayer, 

spotgun (low-pressure handwand) applicator, handgun sprayer, and shank soil injection. 

Application rates for oxamyl range from 0.25 to 4 lb ai/acre. Oxamyl can be applied anywhere 

from 1 to 12 times a year depending on the crop. Most crops have a maximum seasonal 

application rate of 6 times or less. Current end-use product labels limit aerial applications to a 

maximum of 1 pound active ingredient per acre and ground applications to foliage are limited to 

2 pounds active ingredient per acre. Soil-directed applications are a maximum of 4 pounds 

active ingredient per acre. Maximum application rates vary by crop, by method of application, 

by target of application (soil versus foliage) and by state or region. 

There are no registered uses of oxamyl at residential sites. Oxamyl is a restricted use 

pesticide. At this time, products containing oxamyl are intended for occupational use only. 

Current oxamyl labels state that oxamyl can only be used in commercial and farm plantings. 

Oxamyl is not for use in home plantings, nor on any commercial crop that is turned into a “upick” or “pick your own” or similar operation. 

Table 3: Occupational Uses of Oxamyl 

Crop Geographic Location Target Application Equipment Maximum Application 

Rate (lb ai/A) 

Entire U.S. Foliage airblast, handgun, chemigation 2 

WA Foliage aerial 1 Apples Thinning - NJ, PA, VA, 

WV Foliage airblast, handgun, chemigation 1 

Foliage low pressure handwand Bananas, Plantains Puerto Rico Soil low pressure handwand 0.005 lb ai/plant 

Foliage groundboom, chemigation 1 

Carrot U.S., except CA groundboom 4 Soil chemigation 2 

Foliage aerial 0.5 AZ, CA Foliage groundboom, chemigation 0.5 

Foliage aerial 0.5 

FL Foliage groundboom, chemigation 2 

Soil groundboom 4 

Foliage groundboom, chemigation 2 

Celery 

PA, OH, MI, TX Soil groundboom 4 

Foliage aerial, airblast, handgun 1 

Citrus Entire U.S. Foliage 

Soil chemigation 2 
Page 10 of 59 

Table 3: Occupational Uses of Oxamyl 

Crop Geographic Location Target Application Equipment Maximum Application 

Rate (lb ai/A) 

Clover Grown for 

Seed 

CA SLN 

(CA060028) Foliage Aerial, groundboom 1 

AZ and CA Foliage aerial, groundboom, 

chemigation, 1 

Cotton 

U.S., except AZ and CA Foliage aerial, groundboom, 

chemigation, 0.5 

West of Rockies Foliage groundboom, chemigation 1 

Foliage aerial, groundboom, 

chemigation 1 

Cucurbits: 

Cucumber, 

Cantaloupe, 

Honeydew Melon, 

Watermelon, 

Squash, Pumpkin 

East of Rockies 

Soil groundboom 4 

Entire U.S. Foliage groundboom, chemigation 1 Eggplant U.S., except CA Soil groundboom, chemigation 2 

Foliage groundboom, chemigation 2 

Foliage aerial 1 

OR, 

 & NY SLN 

(NY990002) Soil groundboom 4 

CA (Modoc & Siskiyou 

counties) Foliage aerial, groundboom, 

chemigation 1 

WA SLN 

(WA000018) 

Foliage & 

Soil groundboom, chemigation 1 

Foliage 

Garlic 

CA Soil groundboom, chemigation 2 

Foliage groundboom 1 Ginger Root HI Soil groundboom 4 

Foliage aerial, groundboom, airblast, 

handgun, chemigation Nonbearing Fruit 1 

(apple, cherry, 

citrus, peach, pear) 

Entire U.S. 

Soil groundboom, airblast, 

handgun 4 

Foliage aerial 1 

Foliage groundboom, chemigation 2 

OR, ID, WA, 

& NY SLN 

(NY990002) Soil groundboom 4 

Soil groundboom 2 CA Foliage groundboom, chemigation 2 

CA (Modoc & Siskiyou 

counties) 

 & CO SLN 

(CO010005) 

& NV SLN 

(NY990002) 

& UT SLN 

(UT990004) 

Foliage aerial, groundboom, 

chemigation 1 

Foliage aerial 0.5 

MI, TX Foliage groundboom, chemigation 2 

Soil groundboom 4 

WI SLN Foliage aerial, groundboom 0.5 

(WI070005) Soil Groundboom 4 

Onions 

(dry bulb only) 

NM Foliage aerial, groundboom, 

chemigation 0.5 

Foliage aerial, groundboom, 

chemigation 0.5 

Peanuts U.S., except CA 

Soil aerial, groundboom, 

chemigation 0.5 

Pears U.S., except CA Foliage airblast, handgun, chemigation 2 
Page 11 of 59 

Table 3: Occupational Uses of Oxamyl 

Crop Geographic Location Target Application Equipment Maximum Application 

Rate (lb ai/A) 

Peppermint and groundboom, chemigation 2 

Spearmint 

ID, MI, MT, OR, WA, 

WI Foliage aerial 1 

Foliage aerial, groundboom, 

chemigation 1 Peppers 

(Bell and 

Non-Bell) 

Entire U.S. 

Soil groundboom, chemigation 1 

Foliage groundboom, chemigation 2 Pineapple U.S., except CA Soil groundboom, chemigation 2 

Entire U.S. Foliage aerial, groundboom, 

chemigation 1 

MD SLN 

(MD080003) 

& NY SLN 

(NY080001) 

Foliage & 

Soil groundboom, chemigation 2 

PA SLN Foliage groundboom, chemigation 1 

(PA070002) Soil groundboom 2 

Potatoes 

U.S., except Northeast, 

Mid-Atlantic States Soil groundboom 4 

Sweet Potatoes U.S., except CA Soil groundboom 4 

Tobacco Entire U.S. Soil groundboom, chemigation 2 

Foliage aerial, groundboom, 

chemigation 1 Entire U.S. 

Soil chemigation 2 Tomatoes 

CA only Soil groundboom 1.25 

Yams Puerto Rico Soil groundboom, chemigation 0.5 
Page 12 of 59 

4.0 OCCUPATIONAL EXPOSURE/RISK PATHWAY 

4.1 Occupational Handler Exposures 

HED has determined that there are potential exposures to mixers, loaders, applicators, 

and other handlers during usual use patterns associated with oxamyl. Based on the use patterns 

of oxamyl, several major exposure scenarios were identified for oxamyl: 

• mixing/loading liquids for aerial application; 

• mixing/loading liquids for chemigation application; 

• mixing/loading liquids for groundboom application; 

• mixing/loading liquids for airblast application; 

• applying liquids with aerial equipment; 

• applying liquids with a groundboom sprayer; 

• applying liquids with an airblast sprayer; 

• flagging for liquid aerial applications; 

• mixing/loading/applying with spotgun (low-pressure handwand) equipment; and 

• mixing/loading/applying with handgun equipment. 

4.1.1 Occupational Handler Assumptions 

 Chemical-specific data for assessing human exposures during pesticide handling 

activities were not submitted to the Agency in support of the reregistration of oxamyl. It is the 

policy of the HED to use data from the Pesticide Handlers Exposure Database (PHED) Version 

1.1 and data from the Outdoor Residential Exposure Task Force (ORETF) to assess handler 

exposures for regulatory actions when chemical-specific monitoring data are not available. 

PHED: The PHED Task Force is comprised of representatives from the U.S. EPA, Health 

Canada, the California Department of Pesticide regulation, and member companies of the 

American Crop Protection Association. PHED is a software system consisting of two parts: a 

database of measured exposure values for workers involved in the handling of pesticides under 

actual field conditions and a set of computer algorithms used to subset and statistically 

summarize the selected data. Currently, the database contains values for over 1,700 monitored 

individuals (i.e., replicates). 

Users select criteria to subset the PHED database to reflect the exposure scenario being 

evaluated. The subsetting algorithms in PHED are based on the central assumption that the 

magnitude of handler exposures to pesticides are primarily a function of activity (e.g., 

mixing/loading, applying), formulation type (e.g., wettable powders, granulars), application 

method (e.g., aerial, groundboom), and clothing scenarios (e.g., gloves, double layer clothing). 

Once the data for a given exposure scenario have been selected, the data are normalized 

(i.e., divided by) by the amount of pesticide handled resulting in standard unit exposures 

(milligrams of exposure per pound of active ingredient handled). Following normalization, the 

data are statistically summarized. The distribution of exposure values for each body part (e.g., 

chest upper arm) is categorized as normal, lognormal, or “other” (i.e., neither normal nor 
Page 13 of 59 

lognormal). A central tendency value is then selected from the distribution of the exposure 

values for each body part. These values are the arithmetic mean for normal distributions, the 

geometric mean for lognormal distributions, and the median for all “other” distributions. Once 

selected, the central tendency values for each body part are composited into a “best fit” exposure 

value representing the entire body. 

The unit exposure values calculated by PHED generally range from the geometric mean 

to the median of the selected data set. While data from PHED provide the best available 

information on handler exposures, it should be noted that some aspects of the included studies 

(e.g., duration, acres treated, pounds of active ingredient handled) may not accurately represent 

labeled uses in all cases. HED has developed a series of tables of standard unit exposure values 

for many occupational scenarios that can be utilized to ensure consistency in exposure 

assessments (PHED Surrogate Exposure Guide, August 1998). 

ORETF Handler Studies (MRID 44972201): A report was submitted by the ORETF 

(Outdoor Residential Exposure Task Force) that presented data in which the application of 

various products used on turf by homeowners and lawncare operators (LCOs) was monitored. 

All of the data submitted in this report were completed in a series of studies. 

OMA002: LCO Liquid Applications with a Low Pressure Handgun (MRID 44972201): 

A mixer/loader/applicator study was performed by the Outdoor Residential Exposure Task Force 

(ORETF) using Dacthal as a surrogate compound to determine “generic” exposures to 

individuals applying a pesticide to turf with a low-pressure “nozzle gun” or “handgun” sprayer. 

Dermal and inhalation exposures were estimated using whole-body passive dosimeters and 

breathing-zone air samples on OVS tubes. Inhalation exposure was calculated using an assumed 

respiratory rate of 17 liters per minute for light work (NAFTA, 1999), the actual sampling time 

for each individual, and the pump flow rate. All results were normalized for pounds active 

ingredient handled. 

A total of 90 replicates were monitored using 17 different subjects. Four different 

formulations of dacthal [75% wettable powder (packaged in 4 and 24 pound bags), 75% wettable 

powder in water soluble bags (3 pound bag), 75% water dispersible granules (2 pound bag) and 

55% liquid flowable (2.5 gallon container)] were applied by five different LCOs to actual 

residential lawns at each site in three different locations (Ohio, Maryland, and Georgia) for a 

total of fifteen replicates per formulation. An additional ten replicates at each site were 

monitored while they performed spray application only using the 75 percent wettable powder 

formulation. A target application rate of 2 pounds active ingredient was used for all replicates 

(actual rate achieved was about 2.2 pounds active ingredient per acre). Each replicate treated a 

varying number of actual client lawns to attain a representative target of 2.5 acres (1 hectare) of 

turf. The exposure periods averaged five hours twenty-one minutes, five hours thirty-nine 

minutes, and six hours twenty-four minutes, in Ohio, Maryland and Georgia, respectively. 

Average time spent spraying at all sites was about two hours. All mixing, loading, application, 

adjusting, calibrating, and spill clean up procedures were monitored, except for typical end-ofday clean-up activities, e.g. rinsing of spray tank, etc. Dermal exposure was measured using 

inner and outer whole body dosimeters, hand washes, face/neck washes, and personal air 

monitoring devices. All test subjects wore one-piece, 100 percent cotton inner dosimeters 
Page 14 of 59 

beneath 100 percent cotton long-sleeved shirt and long pants, rubber boots and nitrile gloves. 

Gloves are typically worn by most LCOs, and required by many pesticide labels for mixing and 

loading. 

Overall, residues were highest on the upper and lower leg portions of the dosimeters. In 

general, concurrent lab spikes produced mean recoveries in the range of 78-120 percent, with the 

exception of OVS sorbent tube sections which produced mean recoveries as low as 65.8 percent. 

 Adjustment for recoveries from field fortifications were performed on each dosimeter section or 

sample matrix for each study participant, using the mean recovery for the closest field spike level 

for each matrix and correcting the value to 100 percent. The unit exposure values are presented 

below in Table 4. [Note the data were found to be lognormally distributed. As a result, all 

exposure values are geometric means.] 

Table 4: Unit Exposure Values Obtained for LCO Liquid Applications with a Low Pressure 

Handgun from ORETF Handgun Studies (MRID 44972201)

Total Dermal Unit Exposure1 (mg/lb ai) 

Application Method4 Single Layer, 

No Gloves 

Single Layer, 

Gloves 

Double Layer3, 

Gloves 

Inhalation Unit 

Exposure1,2 (μg/lb ai)

LCO Handgun Spray Mixer/Loader/Applicator 

Liquid Flowable No Data 0.45 0.245 1.8 

1

 Unit exposure values reported are geometric means. 2 Air concentration (mg/m3

/lb ai) calculated using NAFTA ‘99 standard breathing rate of 17 lpm (1 m3/hr). 3

 Exposure calculated using OPP/HED 50% protection factor (PF) for cotton coveralls on torso, arms, and legs. 4

 All commercial handlers wore long pants, long-sleeved shirt, nitrile gloves and shoes. 

ORETF Handler Studies (MRID 44459801): A report was submitted by the ORETF 

(Outdoor Residential Exposure Task Force) that presented data in which the application of 

various products used on vegetable gardens by homeowners was monitored. All of the data 

submitted in this report were completed in a series of studies. 

OMA006: Homeowner Liquid Application to Garden with a Low Pressure Handwand 

(MRID 44459801): The study was designed to quantify dermal and inhalation exposure of 

homeowners as they mixed, loaded and applied liquid formulations of a carbaryl end-use product 

to home garden vegetables. A low pressure handwand) was used to apply Sevin Liquid® Brand 

Carbaryl Insecticide. Twenty replicates were conducted with gloves and 20 replicates were 

conducted without gloves. Inhalation exposure was monitored using personal air samplers 

(average flow rate of 1.5 liter/minute) and dermal exposure was monitored by using inner and 

outer dosimeters, facial/neck wipes, and hand washes. The overall mean field fortification 

recovery of each matrix ranged from 77.6 ± 13.6% (outer dosimeters) to 98.4 ± 3.8% (OVS 

tubes). Laboratory fortified recovery samples were analyzed with each set of samples analyzed 

on a particular day; however, the results of the laboratory recoveries were not provided in the 

Study Report. Unit exposures were calculated for short pants/short sleeves, long pants/short 

sleeves, and long pants/long sleeves scenarios. The results for the low pressure handwand are 

summarized in Table 5 below. 
Page 15 of 59 

Table 5. Unit Exposure Values for Homeowner Liquid Application to Garden with a 

Low Pressure Handwand Obtained From ORETF Study (MRID 44459801)

Total Dermal Unit Exposure1

(mg/lb ai) 

Inhalation Unit 

Exposure1

Scenario Monitored (μg/lb ai) 

Gloves No Gloves No Respirator 

Homeowner Liquid Applications with a 

Low Pressure Handwand Sprayer 0.33 15 2.7 

 1 Unit exposure values reported are geometric means. 

The following general assumptions are made: 

• Average body weight of an adult handler is 70 kg. 

• Average work day interval is 8 hours which represents a typical day. 

• Calculations of handler scenarios are completed using the maximum application rates on 

the oxamyl labels. 

• PHED Version 1.1 or ORETF surrogate data were used for to estimate exposures for all 

scenarios. NOTE: According to information provided by DuPont, the Vydate L spotgun 

applicator appears to have a similar application technique as a low pressure handwand 

and therefore exposure from the spotgun is assumed to be similar to the low pressure 

handwand. Thus, PHED and ORETF unit exposure data from the use of a low pressure 

handwand was used as surrogate data for the spotgun applicator. 

• Due to a lack of scenario-specific data, HED calculated unit exposure values using 

generic data from the Pesticide Handler Exposure Database (PHED) and the Outdoor 

Residential Exposure Task Force database (ORETF). When necessary, protection factors 

are applied to represent various risk mitigation options (i.e., the use of respirator and 

double-layer body protection). 

• Exposures were estimated for handlers using: 

3⁄4 1200 acres per day for aerial applications to cotton, 

3⁄4 350 acres per day for aerial applications to all other crops, 

3⁄4 350 acres per day for chemigation applications, 

3⁄4 200 acres per day for groundboom applications to cotton, 

3⁄4 80 acres per day for groundboom applications to all other crops, 

3⁄4 40 acres per day for airblast applications to tree crops, 

3⁄4 5 acres per day for handgun applications to tree crops, and 

3⁄4 2 acres per day for a spotgun (low-pressure handwand applications to bananas and 

plantains. Note: According to information provided by DuPont, there are 

approximately 715 banana plants per acre and a person can apply oxamyl with a 
Page 16 of 59 

spotgun to approximately 2 acres per day. Since 10 mL of concentrate is applied 

per plant, then 3.6 pounds active ingredient is applied per acre. 

• There are no data to assess handler exposure during a shank injection application. 

However, exposure to handlers during groundboom application is considered to be a 

reasonable surrogate.

4.1.2 Occupational Handler Equations 

Potential daily dermal exposure is calculated using the following formula: 

Potential daily inhalation exposure is calculated using the following formula: 

The daily dermal and inhalation dose is calculated using a 70 kg body weight for both short-term 

and intermediate-term exposure as follows: 

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

Body Weight(kg)

1

x

day

mg ai = Daily InhalationExposure kg/daymg ai Daily InhalationDose

The short-term and intermediate-term risks for dermal exposure were calculated using a NOAEL 

of 8 mg/kg/day. The short-term and intermediate-term risks for inhalation exposure were 

calculated using a NOAEL of 0.39 mg/kg/day. The inhalation and dermal MOEs were 

calculated using the following formulas: 

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ ⎟

⎠

⎞ ⎜

⎝

⎛ ⎟

⎠

⎞ ⎜

⎝

⎛ ⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

day

A

x Daily Acres Treated

A

lb ai

xUse Rate

lb ai

mg ai =Unit Exposure daymg ai Daily Dermal Exposure

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ ⎟

⎠

⎞ ⎜

⎝

⎛ ⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛ ⎟

⎠

⎞ ⎜

⎝

⎛

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

day

A

x Daily Acres Treated

A

lb ai

xUse Rate

1,000 g

1mg x Conversion Factor

lb ai

g ai Unit Exposure

= day

mg ai Daily Inhalation Exposure

μ

μ

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

Body Weight (Kg)

1

x

Day

mg ai = Daily Dermal Exposure Kg/Daymg ai Daily Dermal Dose
Page 17 of 59 

⎟

⎟

⎠

⎞ ⎜

⎜

⎝

⎛

⎟

⎟

⎠

⎞ ⎜

⎜

⎝

⎛

kg/day

mg Dermal Daily Dose

kg/day

mg NOAEL

Dermal MOE=

⎟

⎟

⎠

⎞ ⎜

⎜

⎝

⎛

⎟

⎟

⎠

⎞ ⎜

⎜

⎝

⎛

kg/day

mg Inhalation Daily Dose

kg/day

mg NOAEL

Inhalation MOE=

Since the toxicological effects are similar (cholinesterase inhibition in red blood cells) for the 

dermal and inhalation PoDs, the dermal and inhalation risks to handlers are combined. Since the 

level of concern is 100 for dermal risks and 30 for inhalation risks, an aggregated risk index 

(ARI) is calculated. The level of concern for an ARI is 1 (i.e., ARIs greater than 1 are not a 

concern). ARIs are calculated using the following formula: 

Aggregated Risk Index (ARI) = 1 / (1/ (Dermal MOE /100) + 1/ (Inhalation MOE / 30)). 

4.1.3 Summary of Risk Concerns for Occupational Handlers 

The short- and intermediate-term dermal risks are identical since the same PoD was 

chosen for short- and intermediate-term dermal assessments. The short- and intermediate-term 

inhalation risks are also identical since the same PoD was chosen for short- and intermediateterm inhalation assessments. A summary of the short-term and intermediate-term risks are 

presented in Table 6 (see Appendices A-C for more detail regarding risk calculations). Since the 

toxicological effects are similar (cholinesterase inhibition in red blood cells) for the dermal and 

inhalation PoDs, the dermal and inhalation risks to handlers are combined for an aggregate 

occupational assessment. Since the level of concern is 100 for dermal risks and 30 for inhalation 

risks, an aggregated risk index (ARI) is calculated. The level of concern for an ARI is 1 (i.e., 

ARIs greater than 1 are not a concern). 

    4.1.3.1 Occupational Dermal Risks 

The short- and intermediate-term dermal risks did not exceed HED’s level of concern at 

some level of risk mitigation for all handler scenarios, except: 

• Mixing/loading liquid concentrates to support aerial applications to cotton in CA and AZ 

at 1.0 lb ai/A;

• Mixing/loading liquid concentrates to support chemigation applications at 2.0 lb ai/A;

• Applying sprays by aircraft to cotton in CA and AZ at 1.0 lb ai/A.

   
Page 18 of 59 

4.1.3.2 Occupational Inhalation Risks 

The short- and intermediate-term inhalation risks did not exceed HED’s level of concern 

at the baseline level (no respirator) for all handler scenarios, except mixing/loading to support 

aerial applications to cotton in California and Arizona at the 1.0 lb ai/day application rate. Note 

that only the only data available for applying sprays with aircraft is for engineering controls (i.e., 

an enclosed cockpit) – the risks did not exceed HED’s level of concern for aerial applicators at 

baseline attire as long as enclosed cockpits are used. 

    4.1.3.3 Occupational Combined Risks 

The short- and intermediate-term combined dermal plus inhalation risks did not exceed 

HED’s level of concern at some level of risk mitigation for all handler scenarios, except: 

• Mixing/loading liquid concentrates to support aerial applications to cotton in CA and AZ 

at 1.0 lb ai/A;

• Mixing/loading liquid concentrates to support chemigation applications at 2.0 lb ai/A;

• Applying sprays by aircraft to cotton in CA and AZ at 1.0 lb ai/A.

 
Page 19 of 59 

Table 6: Summary of Risk Mitigation for Handlers Exposed to Oxamyl 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area Treated 

Dailyb

(acres) 

Handle

Mixer/Loader 

Apples (WA only); Citrus; Clover Grown for Seed (SLN CA), 

Cucurbits (East of Rockies), Garlic (OR & CA - Modoc & Siskiyou 

counties, SLN NY); Nonbearing Fruit (apple, cherry, citrus, peach, 

pear); Dry Bulb Onions (CA - Modoc & Siskiyou counties, OR, ID, 

WA, SLN CO, SLN NV, SLN NY, SLN UT); Peppermint and 

Spearmint (ID, MI, MT, OR, WA, WI); Peppers; Potatoes (also 

SLN PA); Tomatoes 

1 350 Engin

(

Cotton (CA and AZ) 1 1200 

Risks of concern w

closed sy

(

Cotton (not AZ and CA) 0.5 1200 Engin

(

Mixing/Loading Liquid 

Concentrates for Aerial 

Applications (PHED) 

Celery (AZ, CA, FL); Dry Bulb Onions (MI, NM, TX, SLN WI); 

Peanuts (not CA) 0.5 350 Baselin

Mixing/Loading Liquid 

Concentrates for Chemigation 

Applications (PHED) 

Apples; Carrot (not CA); Celery (FL, PA, OH, MI, TX); Citrus; 

Eggplant (not CA); Garlic (CA, OR); Dry Bulb Onions (CA, OR, 

ID, WA. MI, TX); Pears (not CA); Peppermint and Spearmint (ID, 

MI, MT, OR, WA, WI); Pineapple (not CA); Potatoes (SLN MD, 

SLN NY, SLN PA); Tobacco; Tomatoes 

2 350 

Risks of concern w

closed mi

(

Apples for Thinning (NJ, PA, VA, WV); Cotton (CA and AZ); 

Cucurbits; Dry Bulb Onions (SLN CO, SLN NV, SLN UT ); 

Eggplant (CA); Garlic (SLNWA); Nonbearing Fruit (apple, cherry, 

citrus, peach, pear); Peppers; Potatoes 

1 350 Engin

(

Mixing/Loading Liquid 

Concentrates for Chemigation 

Applications (PHED) 

Celery (AZ, CA); Cotton (not CA and AZ); Dry Bulb Onions 

(NM); Peanuts (not CA); Yams (Puerto Rico only) 0.5 350 Baselin
Page 20 of 59 

Table 6: Summary of Risk Mitigation for Handlers Exposed to Oxamyl 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area Treated 

Dailyb

(acres) 

Handle

Nonbearing Fruit (apple, cherry, citrus, peach, pear; soil); Carrots 

(not CA); Celery (FL, PA, OH, MI, TX); Cucurbits (East of 

Rockies); Garlic (OR, SLN NY); Ginger Roots (HI); Dry Bulb 

Onions (MI, TX, OR, ID, WA, SLN NY, SLN WI); Sweet Potatoes 

(not in CA); Potatoes (U.S. except Northeast, Mid-Atlantic States) 

4 

(all soildirected) 80 Engin

(

Pineapples (not CA); Eggplants (not CA); Garlic (CA); Dry Bulb 

Onions (CA); Peppermint and Spearmint (ID, MI, MT, OR, WA, 

WI); Potatoes (SLN MD, SLN NY, SLN PA); Tobacco 

2 80 Baselin

Tomatoes (CA) 1.25 80 Baselin

Mixing/Loading Liquids 

Concentrates for Groundboom 

Applications (PHED) 

Clover Grown for Seed (SLN CA); Cucurbits (West of Rockies); 

Dry Bulb Onions (SLN CO, SLN NV, SLN UT); Eggplants (CA); 

Garlic (SLNWA); Peppers; Potatoes (Northeast and Mid-Atlantic 

States); Tomatoes (entire US) 

1 80 Baselin

Cotton (AZ and CA) 1 200 Double la

(

Cotton (U.S. except CA and AZ) 0.5 200 Baselin

Mixing/Loading Liquids Concentrates for Groundboom Applications (PHED) cont Celery (AZ, CA); Dry Bulb Onions (NM); Yams (Puerto Rico 

Only); Peanuts (not in CA) 0.5 80 Baselin

Apples; Pears (not CA) 2 40 Baselin

Mixing/Loading Liquids Concentrates for Airblast 

Applications (PHED) Apples for Thinning (NJ, PA, VA, WV); Citrus; Nonbearing Fruit (apple, cherry, citrus, peach, pear) 1 40 Baselin

Applicator 

Apples (WA only); Citrus; Clover Grown for Seed (SLN CA); 

Cucurbits (East of Rockies), Garlic (OR & CA - Modoc & Siskiyou 

counties, SLN NY); Nonbearing Fruit (apple, cherry, citrus, peach, 

pear); Dry Bulb Onions (CA - Modoc & Siskiyou counties, OR, ID, 

WA, SLN CO, SLN NV, SLN NY, SLN UT); Peppermint and 

Spearmint (ID, MI, MT, OR, WA, WI); Peppers; Potatoes (also 

SLN PA); Tomatoes 

1 350 Enc

(

Applying Sprays via Aerial 

Equipment (PHED) 

Cotton (CA and AZ) 1 1,200 

Risks of concern w

enc

(
Page 21 of 59 

Table 6: Summary of Risk Mitigation for Handlers Exposed to Oxamyl 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area Treated 

Dailyb

(acres) 

Handle

Cotton (not AZ and CA) 0.5 1,200 Enc

Applying Sprays via Aerial 

Equipment (PHED) Celery (AZ, CA, FL); Dry Bulb Onions (MI, NM, TX, SLN WI); 

Peanuts (not CA) 0.5 350 Enc

(

Nonbearing Fruit (apple, cherry, citrus, peach, pear); Carrot (not 

CA); Celery (FL, PA, OH, MI, TX); Cucurbits (East of Rockies); 

Garlic (OR, SLN NY); Ginger Root (HI); Dry Bulb Onions (MI, 

TX, OR, ID, WA, SLN NY, SLN WI); Sweet Potatoes (not in CA); 

Potatoes (U.S. except Northeast, Mid-Atlantic States) 

4 

(all soildirected) 80 Double la

(

Pineapple (not CA); Eggplant (not CA); Garlic (CA); Dry Bulb 

Onions (CA); Peppermint and Spearmint (ID, MI, MT, OR, WA, 

WI); Potatoes (SLN MD, SLN NY, SLN PA); Tobacco 

2 80 B

(

Tomatoes (CA) 1.25 80 B

(

Clover Grown for Seed (SLN CA); Cucurbits (West of Rockies); 

Dry Bulb Onions (SLN CO, SLN NV, SLN UT): Eggplant (CA); 

Garlic (SLNWA); Peppers; Potatoes (Northeast and Mid-Atlantic 

States); Tomatoes (entire US) 

1 80 B

(

Cotton (AZ and CA) 1 200 B

(

Cotton (U.S. except CA and AZ) 0.5 200 B

(

Applying Sprays via 

Groundboom Equipment 

(PHED) 

Celery (AZ, CA); Dry Bulb Onions (NM); Yams (Puerto Rico 

Only); Peanuts (not in CA) 0.5 80 B

(

Apples; Pears (not CA) 2 40 

Engineering contr

baseline inh

(

Applying Sprays via Airblast 

Equipment PHED) 

Apples for Thinning (NJ, PA, VA, WV); Citrus; Nonbearing Fruit 

(apple, cherry, citrus, peach, pear) 1 40 

Engineering contr

baseline inh

(
Page 22 of 59 

Table 6: Summary of Risk Mitigation for Handlers Exposed to Oxamyl 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area Treated 

Dailyb

(acres) 

Handle

Flagger 

Apples (WA only); Citrus; Clover Grown for Seed (SLN CA); 

Cucurbits (East of Rockies), Garlic (OR & CA - Modoc & Siskiyou 

counties, SLN NY); Nonbearing Fruit (apple, cherry, citrus, peach, 

pear); Dry Bulb Onions (CA - Modoc & Siskiyou counties, OR, ID, 

WA, SLN CO, SLN NV, SLN NY, SLN UT); Peppermint and 

Spearmint (ID, MI, MT, OR, WA, WI); Peppers; Potatoes (also 

SLN PA); Tomatoes 

1 350 

(

Cotton (CA and AZ) 1 350 

(

Cotton (U.S. except AZ and CA) 0.5 350 

(

Flagging for Aerial Sprays 

Applications (PHED) 

Celery (AZ, CA, FL); Dry Bulb Onions (MI, NM, TX, SLN WI); 

Peanuts (not CA) 0.5 350 

(

Mixer/Loader/Applicator

Mixing/Loading/Applying 

Liquid Concentrates with Low 

Pressure Handwand (PHED) 

Bananas, Plantains (PR) 3.6 2 Baselin

Mixing/Loading/Applying 

Liquid Concentrates with Low 

Pressure Handwand (ORETF, 

ground directed) 

Bananas, Plantains (PR) 3.6 2 Baselin

Nonbearing Fruit (apple, cherry, citrus, peach, pear) 4 5 Double la

(

Apples; Pears (not CA) 2 5 Baselin

Mixing/Loading/Applying 

Liquid Concentrates with a 

Handgun Sprayer (LCO 

ORETF data) Apples for Thinning (NJ, PA, VA, WV); Citrus 1 5 Baselin

Footnotes

a. Application rates are maximum application rates from the labels. b. Science Advisory Council Policy # 9.1 c. Risk Mitigation: Baseline = long-sleeved shirt, long pants, shoes, and socks; C-R gloves = chemical-resistant gloves; Double layers = coverall

pants; Engineering control for mixing/loading = closed system; Engineering control for aerial applicators = enclosed cockpit; and Engineering 

enclosed cab.
Page 23 of 59 

4.2 Occupational Postapplication Exposures 

 4.2.1 Occupational Dermal Postapplication Expsoures 

 4.2.1.1 Occupational Dermal Postapplication Assumptions and Calculations 

The registrant has submitted three dislodgeable foliar residue (DFR) studies in support of the 

reregistration of oxamyl: 

• “Dissipation of Dislodgeable Foliar and Soil Residues of Oxamyl Following Application 

of Vydate® L Insecticide to Tomatoes in the USA- Season 1997 and 1998;” MRID 

44704801. 

• “Dissipation of Dislodgeable Foliar Residues of Oxamyl from Citrus Following 

Application of Vydate® L Insecticide in the U.S.A - Season 1997;” MRID 44686901. 

• “Dissipation of Dislodgeable Foliar Residues of Oxamyl from Cucumbers Following 

Application of Vydate® L Insecticide in the U.S.A. - Season 1997;” MRID 44686902. 

 The dissipation data obtained from these studies has been used to determine the days 

after treatment when the calculated MOE did not exceed HED’s level of concern (MOE ≥ 100) 

for oxamyl crops following foliar applications of oxamyl. The raw data from the studies are 

corrected for recoveries as appropriate. The data is then natural log transformed. A semi-log 

regression analysis is run on the log transformed data. From the regression analysis, a 

dissipation rate (slope) and predicted dislodgeable foliar residue data for each site and crop is 

determined. If the day 0 actual DFR data are significantly higher than the predicted DFR, then 

the actual data are used for day 0 calculations. The following calculations are used to calculate 

the dose and risk. The Restricted Entry Interval (REI) typically is established on the day that the 

calculated MOE is 100 or above. 

Daily dose is calculated as follows: 

Where: 

DFR = Dislodgeable Foliar Residue initial or daily (μg/cm2) at time (t). 

Tc = Transfer coefficient (cm2

/hr) 

CF = Conversion factor (1 mg/1,000 μg) 

ED = Exposure duration (hours per day) 

BW = Body weight (kg) 

BW (kg)

x ED (hrs) 1,000 g

1mg (DFR( g/ cm ) x Tc ( cm /hr) x CF

Dose (mg/kg/d)=

2 2

⎟

⎟

⎠

⎞ ⎜

⎜

⎝

⎛

μ

μ
Page 24 of 59 

The daily MOE is calculated as follows: 

Where: 

NOAEL = 8 mg/kg/day 

Dose = Calculated dose 

The following general assumptions are made: 

• Only crops where oxamyl is applied to the foliage are included in this assessment. 

There are no soil transfer values or other data available to evaluate 

postapplication exposure and risk following oxamyl applications to the soil. 

However, the exposure is likely to be minimal and the default REI for oxamyl 

should be sufficiently protective for postapplication workers exposed to oxamyl 

in the soil. 

• The transfer coefficients used in this assessment are from the Agricultural Reentry 

Task Force (ARTF) database. An interim transfer coefficient policy was 

developed by HED’s Science Advisory Council for Exposure using the ARTF 

database (policy # 3.1). It is the intention of HED’s Science Advisory Council for 

Exposure that this policy will be periodically updated to incorporate additional 

information about agricultural practices in crops and new data on transfer 

coefficients. 

• A route-specific dermal study was used to select a dermal PoD, so a dermal 

absorption value is not necessary. 

• The exposure duration is assumed to be 8 hour work day. 

• Adult body weight is 70 kg. 

Dose(mg/kg/day)

NOAEL(mg/kg/day) MOE=
Page 25 of 59 

Table 7 is a summary of the DFR studies’ parameters. A detailed summary of each DFR 

is below. 

Table 7. Comparison of Dislodgeable Foliar Residue Study Parameters

Crop Tomatoes Citrus Cucumbers 

Site Florida California Florida California Georgia California 

Slope -0.43 -0.12 -0.235 -0.078 -0.51 -0.282 

Initial Residues (μg/cm2) 1.85 3.83 

(actual) 

2.14 

(actual) 

2.05 

(actual) 

4.1 

(actual) 

3.9 

(actual) 

Study Application Rate (lb ai/A) 1 1 1 

Half Life (days) 1.6 5.8 3.0 8.9 1.4 2.5 

R2 Values 0.99 0.67 0.86 0.76 0.81 0.94 

Cucumber DFR Study - MRID 44686902: The study: “Dissipation of Dislodgeable Foliar 

Residues of Oxamyl from Cucumbers Following Application of Vydate® L Insecticide in the 

U.S.A. - Season 1997;" (MRID 44686902), was submitted by the registrant and reviewed by 

HED. The study was conducted at two sites, one in California and one in Georgia, during the 

summer of 1997. The treated plot at each site received two applications of Vydate® L 

insecticide/ nematicide using a tractor-mounted boom sprayer. There was a fourteen-day 

interval between the applications. The application rate for each treatment was 1 pound of active 

ingredient (ai) per acre applied at a rate of 50 gallons per acre of finished spray at both sites. 

The data from leaf punches after the second treatment were used to characterize concentration of 

oxamyl on the treated crop and the rate of dissipation. 

The subplots at the California site were furrow /flood irrigated, while the subplots at the 

Georgia site did not require irrigation. The rainfall for the month of July was 10.64 inches at the 

Georgia site. This exceeded the 10-year average for July at the Georgia site of 6.58 inches. 

However, the total average rainfall during the course of the study at the Georgia site was 12.55 

inches. This was lower than the 10-year total average for the same stretch of time, which was 

14.97 inches. The first rainfall after the last application at the Georgia site occurred on Day 4. 

At the California site, there was no rain during the course of the study and the irrigation water 

did not wet the sampled foliage. 

Foliage leaf punch samples were collected randomly from dry viable leaves from each 

subplot and control plot using a one inch diameter Birkestrand® leaf punch sampler. One 

control sample from the control plot and three replicate samples from the treated plot were 

collected at both study sites at the following sampling intervals: prior to each application, 

immediately after each application after the spray dried (day 0), and 1, 2, 3, 7, 14 ,21, 28, and 35 

days after the second (final) application. The California site experienced an insect infestation 

after the 28th day, leaving no viable leaves to be sampled on the 35th day. 

For the Georgia and California sites, on day 0 the actual DFR data are higher than the 

predicted DFR data. Since using the predicted values for day 0 would underestimate exposure, 
Page 26 of 59 

the actual values are also reported for day 0 for this site. Results from the regression analysis are 

presented in Table 8 of this report. 

Table 8. Cucumber Foliar Dissipation for Oxamyl (MRID 44686902)

DFR (μg/cm2) Predicted Values–Based on Log Transformed Data (Values in Parentheses are Actual Field 

Measured Averages) 

Site 0 DAT 1 DAT 2 DAT 3 DAT 4 DAT 5 DAT 6 

DAT 7 DAT R2

Slope 

(t1⁄2

days)a

Georgia 1 

(4.1) 

0.6 

(0.87) 0.36 0.22 0.13 0.079 0.048 0.029 0.81 -0.508 

(1.36) 

California 3.2 

(3.9) 

2.4 

(3.4) 

1.8 

(2.8) 1.4 1.03 0.78 0.59 0.44 0.94 -0.282 

(2.46) 

a t1⁄2 is the calculated half-life of oxamyl at the Georgia site are from 0 DAT to 14 DAT and the half-life of oxamyl at 

the California site are from 0 DAT to 28 DAT. 

 Tomato DFR Study - MRID 44704801: The study: “Dissipation of Dislodgeable Foliar 

and Soil Residues of Oxamyl Following Application of Vydate® L Insecticide to Tomatoes in the 

USA- Season 1997 and 1998." (MRID 44704801) was submitted by the registrant and reviewed 

by HED. There were two sites in the study, one in California and one in Florida. Two 

applications of Vydate®L were applied 5 days apart to test fields. For the California site, the 

applications were made beginning in mid July 1997 and for the Florida site, the applications 

were made in mid November 1997. Vydate®L was applied twice at each site using a broadcast 

boom sprayer at an application rate of 1.0 lb ai per acre in 50 gallons per acre of final volume. 

The data from leaf punches after the second treatment were used to characterize concentration of 

oxamyl on the treated crop and the rate of dissipation. Numerous rainfall events occurred during 

the study at the Florida site. During the study from Nov. 13, 1997 - Dec. 23, 1997, 14.40 inches 

of precipitation fell at the Florida site, while the 10-year average precipitation amounts were 2.36 

inches in Nov. and 2.82 inches in December. The first rainfall after the last application at the 

Florida site occurred on Day 16. Only one rain event occurred at the California site - 0.05 inches 

on Day 2 after the last application. 

The average foliar residues immediately after the second (last) application were 2.03 

μg/cm2

 at the Florida site and 3.83 μg/cm2 at the California site. After 14 days, the residues 

declined to 0.005 μg/cm2 at the Florida site and 0.065 μg/cm2 at the California site. At the 

Florida site, the DFR residues were less than the limit of quantitation (LOQ) of 0.001 μg/cm2

after Day 14; therefore, data on Day 21, 28, and 35 were removed from regression analysis for 

this site. Results from the regression analysis are presented in Table 9 of this report. 
Page 27 of 59 

Table 9. Tomato Foliar Dissipation for Oxamyl (MRID 44704801) 

DFR (μg/cm2) Predicted Values – Based on Log Transformed Data (Values in Parentheses are Actual Field 

Measured Averages) 

Site 

0 DAT 1 DAT 2 DAT 3 DAT 4 DAT 5 DAT 6 DAT 7 DAT R2

Slope 

(t1⁄2

days)a

Florida 1.85 1.21 0.79 0.51 0.34 0.22 0.14 0.094 0.99 -0.425 

(1.62) 

California 

(foliar) 

0.61 

(3.83) 

0.54 

(1.29) 0.48 0.43 0.38 0.34 0.30 0.27 0.24 -0.119 

(5.84) 

a t1⁄2 is the calculated half-life of oxamyl at the Florida site are from 0 DAT to 14 DAT and the half-life of Oxamyl at 

the California site are from 0 DAT to 35 DAT. 

 Citrus DFR Study - MRID 44686901: The study: “Dissipation of Dislodgeable Foliar 

Residues of Oxamyl from Citrus Following Application of Vydate® L Insecticide in the U.S.A - 

Season 1997" (MRID 44686901) was submitted by the registrant and review by HED. The study 

was done at two sites, one in Florida and one in California. The treated plots at each site 

received two applications of Vydate® L insecticide using airblast sprayer applications of the test 

substance. At the California site, each application was 1.0 pounds of active ingredient per acre 

in 100 gallons of finished spray per acre. The data from leaf punches after the second treatment 

were used to characterize concentration of oxamyl on the treated crop and the rate of dissipation. 

 A protocol deviation occurred when for the first application in Florida; Vydate®L was sprayed 

1.25 lb ai/acre due to an increase in spray pressure from 60 to 100 PSI in 147 gallons per acre. 

Insertion of a pressure regulator for the second application brought the application rate down to 

1.0 lb ai/acre in 101 gallons of finished spray per acre. The sprayers were calibrated prior to all 

applications by the volume/time method. In California, irrigation occurred four times with a 

microsprinkler irrigation that did not wet the foliage sampled. The California site had 1.3 inches 

of rainfall during the course of the study – the ten year average is 1.46 inches. In Florida, the 

rainfall per day ranged from 0.2 to 2.6 inches. The total rainfall during the sampling period was 

13.7 inches – the ten year average is 20 inches. 

For the Florida and California sites, on day 0 the actual DFR data are higher than the 

predicted DFR data. Since using the predicted values for day 0 would underestimate exposure, 

the actual values are also reported for day 0 for this site. Results from the regression analysis are 

presented in Table 10 of this report. 
Page 28 of 59 

Table 10. Citrus Foliar Dissipation for Oxamyl (MRID 44686901) 

DFR (μg/cm2) Predicted Values – Based on Log Transformed Data (Values in Parentheses are Actual 

Field Measured Averages) 

Site 

0 DAT 1 DAT 2 DAT 3 

DAT 4 DAT 5 DAT 6 DAT 7 DAT R2

Slope 

(t1⁄2

days)a

Florida 0.639 

(2.14) 

0.505 

(1.46) 

0.40 

(0.477) 0.316 0.250 0.198 0.156 0.124 0.858 -0.235 

(2.95) 

Californi

a 

0.738 

(2.05) 0.683 0.632 0.585 0.541 0.501 0.463 0.429 0.76 0.078 

(8.92) 

a t1⁄2 is the calculated half-life of oxamyl at the Florida and California site are from 0 DAT to 35 DAT. 

Use of the Oxamyl DFR Study Data 

The citrus DFR study data was used to assess exposure to oxamyl-treated foliage for 

citrus and also was used to assess exposure to foliage from the other tree crops (pears, apples, 

bananas, plantains, and non-bearing trees). The cucumber DFR study data was used to assess 

exposure to oxamyl-treated foliage for the cucurbit crops. And the tomato DFR study data were 

used to assess exposure to oxamyl-treated foliage for tomatoes and other fruiting vegetables 

(peppers and eggplant). For all the remaining crops, both the tomato residue data (MRID 

44704801) and the cucumber residue data (MRID 44686902) were used to assess exposure to 

oxamyl-treated foliage. For all crops where both tomato and cucumber residue data are 

presented, the results for the California sites were averaged and the results from the Florida and 

Georgia sites were averaged. The DFR values from the three submitted studies were adjusted 

proportionately to reflect remaining crops application rates. The new DFR values are calculated 

as follows: 

    4.2.1.2 Summary of Dermal Risk Concerns for Postapplication Workers 

See Tables 11 and 12 for a summary of the postapplication results. The resulting 

postapplication assessments indicate that the MOEs equal or exceed 100 on the day specified for 

the following crops, according to the DFR study site and tasks that represent the highest transfer 

coefficient. The postapplication risk assessment indicates that for many crops, risks remain a 

concern for several days following application. 

study application rate (lbsai/A)

Study DFR( g/ cm ) x crop application rate (lbsai/A) Adjusted DFR( g/ cm )=

2

2 μ μ
Page 29 of 59 

Table 11: Oxamyl Postapplication Risks for Tree Crops

Crop 

Appl. 

Ratea

(lbs. ai/ 

acre) 

Transfer Coefficientb

(cm2/hr) 

and 

Activity 

DFR Data 

Sourcec

Dose at Day 0d

(mg/kg/day) 

MOE at 

Day 0e

Day After 

Treatment When 

MOE ≥100f

Florida 1.8 5 9 

Banana/ 

Plantain 3.6 

2000 

Training, Hand Pruning, 

Thinning, Topping, Hand 

Weeding California 1.7 5 27 

Florida 1.5 6 8 

Apples 2 

3000 

Hand Harvesting, Thinning, 

Propping, Training, Hand 

Pruning 

California 1.4 6 24 

Florida 1.5 6 8 

Citrus 2 

3000 

Hand Harvesting, Hand 

Pruning, Thinning California 1.4 6 24 

Pears Florida 1.5 6 8 

 (U.S., except 

CA) 

2 

3000 

Hand Harvesting, Thinning, 

Tying, Hand Pruning, 

Training 

California 1.4 6 24 

Nonbearing Florida 0.098 82 1 

Fruit Trees 1 

400 

All Tasks California 0.094 85 1 

a. Application rates are the maximum application rates determined from EPA registered labels for oxamyl. 

b. Transfer Coefficients are from Science Advisory Council on Exposure Policy 3.1. Risks were only assessed for the highest 

transfer coefficient available for a crop. 

c. The results from the analysis using actual DFR values for Day 0. The actual DFR values were used instead of the predicted 

DFRs when the actual DFR values were higher than the predicted DFR values (Day 0, 1, and 2 for Citrus FL and Day 0 for 

Citrus CA). 

DFR Data sources:

Citrus CA: MRID 44686901: Slope = -0.078, Day 0 (actual) = 2.05, Study Application Rate = 1 

Citrus FL: MRID 44686901: Slope = -0.235, Day 0 (actual) = 2.14, Study Application Rate = 1 

d. Daily Dose = [DFR (μg/cm2

) x Transfer Coefficient (cm2/hr) x 0.001 mg/μg x 8 hrs/day] ÷ body weight (70 kg adult) 

e. MOE = NOAEL/Daily Dose (Adult Dermal NOAEL = 8 mg/kg/day). Target MOE = 100 

f. Day After Treatment When MOE ≥100. Values in bold indicate that the calculated REI is greater than 48 hrs. 
Page 30 of 59 

Table 12: Oxamyl Postapplication Risks for Vegetable and Non-Tree Fruit Crops

Crop 

Appl. 

Ratea

(lbs. ai/ 

acre) 

Transfer 

Coefficientb

(cm2/hr) 

And Activity 

DFR Data Sourcec Dose at Day 0d

(mg/kg/day) 

MOE at 

Day 0e

Day After 

Treatment 

When 

MOE ≥100f

Average 

Day after 

Treatment 

when MOE 

≥100 

Cucumber 

GA 2.3 3 4 

Tomato 

FL 1.1 8 9 

7 

Cucumber 

CA 2.2 4 12 

Celery 

(FL, PA, OH, 

MI, TX) 

2 

2500 

Hand harvesting 

Tomato 

CA 2.2 4 13 

13 

Cucumber 

GA 0.59 14 2 

Tomato 

FL 0.26 30 3 

3 

Cucumber 

CA 0.55 15 7 

Celery 

(AZ, CA) 0.5 

2500 

Hand harvesting 

Tomato 

CA 0.55 15 2 

5 

Cucumber 

GA 1.4 6 3 

Tomato 

FL 0.63 13 5 

4 

Cucumber 

CA 1.3 6 10 

Peppermint 

and 

Spearmint 

(ID, MI, MT, 

OR, WA, WI) 

2 

1500 

Irrigation; 

scouting; hand 

weeding 

Tomato 

CA 1.3 6 9 

10 

Cucumber 

GA 0.94 9 3 

Tomato 

FL 0.21 38 3 

3 

Cucumber 

CA 0.88 9 8 

Pineapples 2 

1000 

Hand harvesting; 

hand pruning 

Tomato 

CA 0.88 9 5 

7 

Cucumber 

GA 0.28 28 1 

Tomato 

FL 0.13 63 2 

2 

Cucumber 

CA 0.26 30 4 

Garlic 

(OR, CA) 2 

300 

Irrigation; 

scouting; 

thinning; hand 

weeding Tomato 

CA 0.26 30 2 

3 
Page 31 of 59 

Table 12: Oxamyl Postapplication Risks for Vegetable and Non-Tree Fruit Crops

Crop 

Appl. 

Ratea

(lbs. ai/ 

acre) 

Transfer 

Coefficientb

(cm2/hr) 

And Activity 

DFR Data Sourcec Dose at Day 0d

(mg/kg/day) 

MOE at 

Day 0e

Day After 

Treatment 

When 

MOE ≥100f

Average 

Day after 

Treatment 

when MOE 

≥100 

Cucumber 

GA 0.14 57 1 

Tomato 

FL 0.06 130 0 (12 hours) 

1 

Cucumber 

CA 0.13 60 3 

Garlic 

(SLN NY, 

SLN WA) 

1 

300 

Irrigation; 

scouting; 

thinning; hand 

weeding Tomato 

CA 0.13 61 1 

2 

Cucumber 

GA 0.28 28 1 

Tomato 

FL 0.13 63 2 

2 

Cucumber 

CA 0.26 30 4 

Onions, Dry 

Bulb 

(OR, ID, WA, 

CA, MI, TX 

2 

300 

Irrigation; 

scouting; 

thinning; hand 

weeding Tomato 

CA 0.26 30 2 

3 

Cucumber 

GA 0.14 57 1 

Tomato 

FL 0.06 130 0 (12 hours) 

1 

Cucumber 

CA 0.13 60 3 

Onions, Dry 

Bulb 

 (SLN CO, 

SLN NV, 

SLN NY, 

SLN UT) 

1 

300 

Irrigation; 

scouting; 

thinning; hand 

weeding Tomato 

CA 0.13 61 1 

2 

Cucumber 

GA 0.07 110 0 (12 hours) 

Tomato 

FL 0.03 250 0 (12 hours) 

0 (12 

hours) 

Cucumber 

CA 0.07 120 0 (12 hours) 

Onions, Dry 

Bulb 

(NM, SLN 

WI) 

0.5 

300 

Irrigation; 

scouting; 

thinning; hand 

weeding Tomato 

CA 0.07 120 0 (12 hours) 

0 (12 

hours) 

Cucumber 

GA 0.7 11 2 

Tomato 

FL 0.32 25 4 

3 

Cucumber 

CA 0.66 12 7 

Clover Grown 

for Seed 

(SLN CA) 

1.0 

1500 

Irrigation; 

scouting; 

Tomato 

CA 0.66 12 3 

5 
Page 32 of 59 

Table 12: Oxamyl Postapplication Risks for Vegetable and Non-Tree Fruit Crops

Crop 

Appl. 

Ratea

(lbs. ai/ 

acre) 

Transfer 

Coefficientb

(cm2/hr) 

And Activity 

DFR Data Sourcec Dose at Day 0d

(mg/kg/day) 

MOE at 

Day 0e

Day After 

Treatment 

When 

MOE ≥100f

Average 

Day after 

Treatment 

when MOE 

≥100 

Cucumber 

GA 1.2 7 3 

Tomato 

FL 0.53 15 5 

4 

Cucumber 

CA 1.1 7 9 

Carrot 1 

2500 

Hand harvesting; 

Tomato 

CA 1.1 7 7 

8 

Cucumber 

GA 1.2 7 3 3 

Cucurbits 1 

2500 

Hand harvesting; 

hand pruning, 

thinning 

Cucumber 

CA 1.1 7 9 9 

Cucumber 

GA 1.2 7 3 

Tomato 

FL 0.53 15 5 

4 

Cucumber 

CA 1.1 7 9 

Cotton 

(AZ and CA) 1 

2500 

Hand harvesting; 

Tomato 

CA 1.1 7 7 

8 

Cucumber 

GA 0.59 14 2 

Tomato 

FL 0.26 30 3 

3 

Cucumber 

CA 0.55 15 7 

Cotton 

 (U.S. except 

AZ and CA); 

0.5 

2500 

Hand harvesting 

Tomato 

CA 0.55 15 2 

5 

Cucumber 

GA 1.4 6 3 

Tomato 

FL 0.63 13 5 

4 

Cucumber 

CA 1.3 6 10 

Potatoes 

(SLN MD, 

SLN NY) 

2 

1500 

Irrigation; 

scouting 

Tomato 

CA 1.3 6 9 

10 

Cucumber 

GA 0.7 11 2 

Tomato 

FL 0.32 25 4 

3 

Cucumber 

CA 0.66 12 7 

Potatoes 

(also SLN 

PA) 

1 

1500 

Irrigation; 

scouting 

Tomato 

CA 0.66 12 3 

5 
Page 33 of 59 

Table 12: Oxamyl Postapplication Risks for Vegetable and Non-Tree Fruit Crops

Crop 

Appl. 

Ratea

(lbs. ai/ 

acre) 

Transfer 

Coefficientb

(cm2/hr) 

And Activity 

DFR Data Sourcec Dose at Day 0d

(mg/kg/day) 

MOE at 

Day 0e

Day After 

Treatment 

When 

MOE ≥100f

Average 

Day after 

Treatment 

when MOE 

≥100 

Tomato 

FL 0.21 38 3 3 Eggplant; 

 Tomatoes; 

Peppers 

1 

1000 

Hand harvesting; 

hand pruning 

(eggplant and 

tomato); staking; 

tying, thinning 

(tomato); training 

(tomato) 

Tomato 

CA 0.44 18 2 2 

Cucumber 

GA 0.14 57 1 

Tomato 

FL 0.06 130 0 (12 hours) 

1 

Cucumber 

CA 0.13 60 3 

Ginger Root 

(HI) 1 

300 

Irrigation; 

scouting; 

thinning; hand 

weeding Tomato 

CA 0.13 61 1 

2 

Cucumber 

GA 0.35 23 1 

Tomato 

FL 0.16 50 2 

2 

Cucumber 

CA 0.33 24 5 

Peanuts (U.S. 

except CA) 0.5 

1500 

Irrigation; 

scouting 

Tomato 

CA 0.33 24 2 

4 

a. Application rates are the maximum application rates determined from EPA registered labels for oxamyl. 

b. Transfer Coefficients are from Science Advisory Council on Exposure Policy 3.1. Risks were only assessed for the highest 

transfer coefficient available for a crop. 

c. The results from the analysis using actual DFR values for Day 0 for cucumber GA, cucumber CA, and tomato CA. The actual 

DFR values were used instead of the predicted DFRs when the actual DFR values were significantly higher than the predicted 

DFR values. An analysis using actual DFR values was not necessary for the tomato data from Florida. 

DFR Data sources:

3⁄4 Cucumber CA: MRID 44686902: Study Application Rate = 1, Slope = -0.282, Day 0 (predicted) = 3.2 μg/cm2

, Day 0 

(actual) = 3.86 μg/cm2

, Day 1 (actual) = 3.42 μg/cm2, Day 2 (actual) = 2.83 μg/cm2, Day 3 (predicted) = 1.37 μg/cm2, 

Day 4 (predicted) = 1.03 μg/cm2

), Day 5 (predicted) = 0.778 μg/cm2. 

3⁄4 Tomato CA: MRID 44704801: Study Application Rate = 1, Slope = -0.119, Day 0 (predicted) = 0.61 μg/cm2

, Day 0 

(actual) = 3.83 μg/cm2

, Day 1 (actual) = 1.29 μg/cm2, Day 2 (predicted) = 0.48 μg/cm2, Day 3 (predicted) = 0.43 

μg/cm2

, Day 4 (predicted) = 0.38 μg/cm2 , Day 5 (predicted) = 0.34 μg/cm2 ,Day 6 (predicted) = 0.30 μg/cm2

3⁄4 Cucumber GA: MRID 44686902: Study Application Rate = 1 lb ai/A, Slope (predicted) = -0.508, Day 0 (predicted) = 

1, Day 0 (actual) = 4.11 μg/cm2

, Day 1 (actual) = 0.869 μg/cm2, Day 2 (predicted) = 0.36 μg/cm2, Day 3 (predicted) = 

0.21 μg/cm2

. 

3⁄4 Tomato FL: MRID 44704801: Study Application Rate = 1, Slope = -0.425, Day 0 (predicted) = 1.85 

d. Daily Dose = [DFR (μg/cm2

) x Transfer Coefficient (cm2/hr) x 0.001 mg/μg x 8 hrs/day] ÷ body weight (70 kg adult) 

e. MOE = NOAEL/Daily Dose (Adult Dermal NOAEL = 8 mg/kg/day). Target MOE = 100 

f. Day After Treatment When MOE ≥100. Values in bold indicate that the calculated REI is greater than 48 hrs. 
Page 34 of 59 

4.2.2 Occupational Inhalation Postapplication Expsoures 

 Based on the Agency's current practices, a quantitative occupational postapplication 

inhalation exposure assessment was not performed for oxamyl at this time. However, there are 

multiple potential sources of postapplication inhalation exposure to individuals performing 

postapplication activities in previously treated fields. These potential sources include 

volatilization of pesticides and resuspension of dusts and/or particulates that contain pesticides. The 

Agency sought expert advice and input on issues related to volatilization of pesticides from its 

Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel (SAP) in 

December 2009. The Agency received the SAP’s final report on March 2, 2010 

(http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html). The Agency is in the 

process of evaluating the SAP report as well as available postapplication inhalation exposure 

data generated by the Agricultural Reentry Task Force and may, as appropriate, develop policies 

and procedures, to identify the need for and, subsequently, the way to incorporate occupational 

postapplication inhalation exposure into the Agency's risk assessments. If new policies or 

procedures are put into place, the Agency may revisit the need for a quantitative occupational 

postapplication inhalation exposure assessment for oxamyl. [Note: Oxamyl could potentially be 

used on crops in greenhouses. The Worker Protection Standard for Agricultural Pesticides 

contains requirements for protecting workers from inhalation exposures during and after 

greenhouse applications through the use of ventilation requirements.] 

5.0 RESIDENTIAL (NON-OCCUPATIONAL) EXPOSURE/RISK PATHWAY 

 5.1 Residential Exposure 

 This document presents the assessment of agricultural uses of oxamyl. No residential 

uses and no occupational uses at residential sites are registered for oxamyl; therefore, no 

residential risk assessment has been conducted. 

 5.2 Spray Drift

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

operations. This is particularly the case with aerial application, but, to a lesser extent, could also 

be a potential source of exposure from the ground application method employed for oxamyl. 

The Agency has been working with the Spray Drift Task Force, EPA Regional Offices and State 

Lead Agencies for pesticide regulation and other parties to develop the best spray drift 

management practices (see the Agency’s Spray Drift website for more information at 

http://www.epa.gov/opp00001/factsheets/spraydrift.htm). On a chemical by chemical basis, the 

Agency is now requiring interim mitigation measures for aerial applications that must be placed 

on product labels/labeling. The Agency has completed its evaluation of the new database 

submitted by the Spray Drift Task Force, a membership of U.S. pesticide registrants, and is 

developing a policy on how to appropriately apply the data and the AgDRIFT computer model to 

its risk assessments for pesticides applied by air, orchard airblast and ground hydraulic methods. 

 After the policy is in place, the Agency may impose further refinements in spray drift 

management practices to reduce off-target drift with specific products with significant risks 
Page 35 of 59 

associated with drift. 

 5.3 Residential Bystander Postapplication Inhalation Exposure 

 Based on the Agency's current practices, a quantitative residential bystander 

postapplication inhalation exposure assessment was not performed for oxamyl at this time. 

However, volatilization of pesticides may be a potential source of postapplication inhalation 

exposure to individuals nearby to 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. The Agency received the 

SAP’s final report on March 2, 2010 

(http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html). The Agency is in the 

process of evaluating the SAP report and may, as appropriate, develop policies and procedures, 

to identify the need for and, subsequently, the way to incorporate postapplication inhalation 

exposure into the Agency's risk assessments. If new policies or procedures are put into place, the 

Agency may revisit the need for a quantitative postapplication inhalation exposure assessment 

for oxamyl. 
Page 36 of 59 

APPENDIX A Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl Doses a

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres) 

Dermal 

 (mg/lb 

ai) 

Inhalation 

(μg/lb ai) 

Dermale

(mg/kg/day

) 

Inhalationf

(mg/kg/day

) 

Dermal

(LOC 

=100) 

Mixer/Loader 

Apples (WA only); Citrus; Clover 

Grown for Seed (SLN CA), 

Cucurbits (East of Rockies), 

Garlic (OR & CA - Modoc & 

Siskiyou counties, SLN NY); 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear); Dry Bulb 

Onions (CA - Modoc & Siskiyou 

counties, OR, ID, WA, SLN CO, 

SLN NV, SLN NY, SLN UT); 

Peppermint and Spearmint (ID, 

MI, MT, OR, WA, WI); Peppers; 

Potatoes (also SLN PA); 

Tomatoes 

1 350 2.9 1.2 15 0.006 0.55 

Cotton (CA and AZ) 1 1200 2.9 1.2 50 0.021 0.16 

Cotton (not AZ and CA) 0.5 1200 2.9 1.2 25 0.01 0.32 

Mixing/Loading Liquid 

Concentrates for Aerial 

Applications (PHED) 

Celery (AZ, CA, FL); Dry Bulb 

Onions (MI, NM, TX, SLN WI); 

Peanuts (not CA) 

0.5 350 2.9 1.2 7.3 0.003 1.10 
Page 37 of 59 

APPENDIX A Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl Doses a

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres) 

Dermal 

 (mg/lb 

ai) 

Inhalation 

(μg/lb ai) 

Dermale

(mg/kg/day

) 

Inhalationf

(mg/kg/day

) 

Dermal

(LOC 

=100) 

Apples; Carrot (not CA); Celery 

(FL, PA, OH, MI, TX); Citrus; 

Eggplant (not CA); Garlic (CA, 

OR); Dry Bulb Onions (CA, OR, 

ID, WA. MI, TX); Pears (not 

CA); Peppermint and Spearmint 

(ID, MI, MT, OR, WA, WI); 

Pineapple (not CA); Potatoes 

(SLN MD, SLN NY, SLN PA); 

Tobacco; Tomatoes 

2 350 2.9 1.2 29 0.012 0.28 

Apples for Thinning (NJ, PA, 

VA, WV); Cotton (CA and AZ); 

Cucurbits; Dry Bulb Onions 

(SLN CO, SLN NV, SLN UT ); 

Eggplant (CA); Garlic (SLNWA); 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear); Peppers; 

Potatoes 

1 350 2.9 1.2 15 0.006 0.55 

Mixing/Loading Liquid 

Concentrates for 

Chemigation Applications 

(PHED) 

Celery (AZ, CA); Cotton (not CA 

and AZ); Dry Bulb Onions (NM); 

Peanuts (not CA); Yams (Puerto 

Rico only) 

0.5 350 2.9 1.2 7.3 0.003 1.10 
Page 38 of 59 

APPENDIX A Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl Doses a

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres) 

Dermal 

 (mg/lb 

ai) 

Inhalation 

(μg/lb ai) 

Dermale

(mg/kg/day

) 

Inhalationf

(mg/kg/day

) 

Dermal

(LOC 

=100) 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear; soil); Carrots 

(not CA); Celery (FL, PA, OH, 

MI, TX); Cucurbits (East of 

Rockies); Garlic (OR, SLN NY); 

Ginger Roots (HI); Dry Bulb 

Onions (MI, TX, OR, ID, WA, 

SLN NY, SLN WI); Sweet 

Potatoes (not in CA); Potatoes 

(U.S. except Northeast, MidAtlantic States) 

4 

(all soildirected) 80 2.9 1.2 13 0.0055 0.60 

Pineapples (not CA); Eggplants 

(not CA); Garlic (CA); Dry Bulb 

Onions (CA); Peppermint and 

Spearmint (ID, MI, MT, OR, 

WA, WI); Potatoes (SLN MD, 

SLN NY, SLN PA); Tobacco 

2 80 2.9 1.2 6.6 0.0027 1.20 

Tomatoes (CA) 1.25 80 2.9 1.2 4.1 0.0017 1.90 

Clover Grown for Seed (SLN 

CA); Cucurbits (West of 

Rockies); Dry Bulb Onions (SLN 

CO, SLN NV, SLN UT); 

Eggplants (CA); Garlic 

(SLNWA); Peppers; Potatoes 

(Northeast and Mid-Atlantic 

States); Tomatoes (entire US) 

1 80 2.9 1.2 3.3 0.0014 2.40 

Cotton (AZ and CA) 1 200 2.9 1.2 8.3 0.0034 0.97 

Cotton (U.S. except CA and AZ) 0.5 200 2.9 1.2 4.1 0.0017 1.90 

Mixing/Loading Liquids 

Concentrates for 

Groundboom 

Applications (PHED) 

Celery (AZ, CA); Dry Bulb 

Onions (NM); Yams (Puerto Rico 

Only); Peanuts (not in CA) 

0.5 80 2.9 1.2 1.7 0.00069 4.80 
Page 39 of 59 

APPENDIX A Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl Doses a

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres) 

Dermal 

 (mg/lb 

ai) 

Inhalation 

(μg/lb ai) 

Dermale

(mg/kg/day

) 

Inhalationf

(mg/kg/day

) 

Dermal

(LOC 

=100) 

Apples; Pears (not CA) 2 40 2.9 1.2 3.3 0.0014 2.40 

Mixing/Loading Liquids 

Concentrates for Airblast 

Applications (PHED) Apples for Thinning (NJ, PA, VA, WV); Citrus; Nonbearing 

Fruit (apple, cherry, citrus, peach, 

pear) 

1 40 2.9 1.2 1.7 0.00069 4.80 

Applicator 

Apples (WA only); Citrus; Clover 

Grown for Seed (SLN CA); 

Cucurbits (East of Rockies), 

Garlic (OR & CA - Modoc & 

Siskiyou counties, SLN NY); 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear); Dry Bulb 

Onions (CA - Modoc & Siskiyou 

counties, OR, ID, WA, SLN CO, 

SLN NV, SLN NY, SLN UT); 

Peppermint and Spearmint (ID, 

MI, MT, OR, WA, WI); Peppers; 

Potatoes (also SLN PA); 

Tomatoes 

1 350 No Data No Data No Data No Data No Dat

Cotton (CA and AZ) 1 1,200 No Data No Data No Data No Data No Dat

Cotton (not AZ and CA) 0.5 1,200 No Data No Data No Data No Data No Dat

Applying Sprays via 

Aerial Equipment 

(PHED) 

Celery (AZ, CA, FL); Dry Bulb 

Onions (MI, NM, TX, SLN WI); 

Peanuts (not CA) 

0.5 350 No Data No Data No Data No Data No Dat
Page 40 of 59 

APPENDIX A Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl Doses a

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres) 

Dermal 

 (mg/lb 

ai) 

Inhalation 

(μg/lb ai) 

Dermale

(mg/kg/day

) 

Inhalationf

(mg/kg/day

) 

Dermal

(LOC 

=100) 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear); Carrot (not 

CA); Celery (FL, PA, OH, MI, 

TX); Cucurbits (East of Rockies); 

Garlic (OR, SLN NY); Ginger 

Root (HI); Dry Bulb Onions (MI, 

TX, OR, ID, WA, SLN NY, SLN 

WI); Sweet Potatoes (not in CA); 

Potatoes (U.S. except Northeast, 

Mid-Atlantic States) 

4 

(all soildirected) 80 0.014 0.74 0.064 0.0034 130 

Pineapple (not CA); Eggplant 

(not CA); Garlic (CA); Dry Bulb 

Onions (CA); Peppermint and 

Spearmint (ID, MI, MT, OR, 

WA, WI); Potatoes (SLN MD, 

SLN NY, SLN PA); Tobacco 

2 80 0.014 0.74 0.032 0.0017 250 

Tomatoes (CA) 1.25 80 0.014 0.74 0.02 0.0011 400 

Clover Grown for Seed (SLN 

CA); Cucurbits (West of 

Rockies); Dry Bulb Onions (SLN 

CO, SLN NV, SLN UT): 

Eggplant (CA); Garlic (SLNWA); 

Peppers; Potatoes (Northeast and 

Mid-Atlantic States); Tomatoes 

(entire US) 

1 80 0.014 0.74 0.016 0.00085 500 

Cotton (AZ and CA) 1 200 0.014 0.74 0.04 0.0021 200 

Cotton (U.S. except CA and AZ) 0.5 200 0.014 0.74 0.02 0.0011 400 

Applying Sprays via 

Groundboom Equipment 

(PHED) 

Celery (AZ, CA); Dry Bulb 

Onions (NM); Yams (Puerto Rico 

Only); Peanuts (not in CA) 

0.5 80 0.014 0.74 0.008 0.00042 1000 
Page 41 of 59 

APPENDIX A Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl Doses a

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres) 

Dermal 

 (mg/lb 

ai) 

Inhalation 

(μg/lb ai) 

Dermale

(mg/kg/day

) 

Inhalationf

(mg/kg/day

) 

Dermal

(LOC 

=100) 

Apples; Pears (not CA) 2 40 0.36 4.5 0.41 0.0051 19 

Applying Sprays via 

Airblast Equipment 

PHED) 

Apples for Thinning (NJ, PA, 

VA, WV); Citrus; Nonbearing 

Fruit (apple, cherry, citrus, peach, 

pear) 

1 40 0.36 4.5 0.21 0.0026 39 

Flagger 

Apples (WA only); Citrus; 

Clover Grown for Seed (SLN 

CA); Cucurbits (East of Rockies), 

Garlic (OR & CA - Modoc & 

Siskiyou counties, SLN NY); 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear); Dry Bulb 

Onions (CA - Modoc & Siskiyou 

counties, OR, ID, WA, SLN CO, 

SLN NV, SLN NY, SLN UT); 

Peppermint and Spearmint (ID, 

MI, MT, OR, WA, WI); Peppers; 

Potatoes (also SLN PA); 

Tomatoes 

1 350 0.011 

0.35 

0.055 0.0018 150 

Cotton (CA and AZ) 1 350 0.011 0.35 0.055 0.0018 150 

Cotton (U.S. except AZ and CA) 0.5 350 0.011 0.35 0.028 0.00088 290 

Flagging for Aerial 

Sprays Applications 

(PHED) 

Celery (AZ, CA, FL); Dry Bulb 

Onions (MI, NM, TX, SLN WI); 

Peanuts (not CA) 

0.5 350 0.011 0.35 0.028 0.00088 290 
Page 42 of 59 

APPENDIX A Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl Doses a

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres) 

Dermal 

 (mg/lb 

ai) 

Inhalation 

(μg/lb ai) 

Dermale

(mg/kg/day

) 

Inhalationf

(mg/kg/day

) 

Dermal

(LOC 

=100) 

Mixer/Loader/Applicator 

Mixing/Loading/Applyin

g Liquid Concentrates 

with Low Pressure 

Handwand (PHED) 

Bananas, Plantains (PR) 3.6 2 100 30 10 0.0031 0.78 

Mixing/Loading/Applyin

g Liquid Concentrates 

with Low Pressure 

Handwand (ORETF, 

ground directed) 

Bananas, Plantains (PR) 3.6 2 15 2.7 1.5 0.00028 5.20 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear) 4 5 No Data 1.8 No Data 0.00051 No Dat

Apples; Pears (not CA) 2 5 No Data 1.8 No Data 0.00026 No Dat

Mixing/Loading/Applyin

g Liquid Concentrates 

with a Handgun Sprayer 

(LCO ORETF data) 

Apples for Thinning (NJ, PA, 

VA, WV); Citrus 1 5 No Data 1.8 No Data 0.00013 No Dat

Footnotes

a. Application rates are maximum application rates from the labels. b. Science Advisory Council Policy # 9.1 c. Unit Exposures based on PHED Version 1.1 and ORETF. Baseline dermal unit exposure represents long pants, long sleeved shirt, no 

mixing/loading, open cab tractor. Baseline inhalation exposure represents no respirator. 

d. Only engineering control (enclosed cockpit) data are available to assess dermal and inhalation risks to handlers operating aircraft. On

layer of clothing) plus chemical-resistant glove data are available to assess dermal risks to handlers mixing/loading/applying liquid concsprayer. e. Dermal Dose (mg/kg/day) = daily unit exposure (mg/lb ai) x application rate (lb ai/acre) x acres treated / body weight (70 kg). f. Inhalation Dose (mg/kg/day) = daily unit exposure (μg/lb ai) x conversion factor (1 mg/1,000 μg) x application rate (lb ai/acre) x acr

(70 kg). g. Dermal MOE = NOAEL (8 mg/kg/day) / dermal daily dose (mg/kg/day). Level of concern = 100.
Page 43 of 59 

h. Inhalation MOE = NOAEL (0.39 mg/kg/day) / inhalation daily dose (mg/kg/day). Level of concern = 30. i Aggregated Risk Index (ARI) -- combined dermal and inhalation risks = 1 / (1/ (Dermal MOE /300) + 1/ (Inhalation MOE / 100)). L
Page 44 of 59 

APPENDIX B Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Personal Protective Equipment.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres)

Dermal 

PPE-G 

(mg/lb ai)

Baseline 

Inhalation 

(μg/lb ai) 

Dermal PPE-Gd

(mg/kg/day) 

Baseline 

Inhalatione

(mg/kg/day

) 

Dermal 

PPE-Gf

(LOC = 

100) 

Mixer/Loader 

Apples (WA only); Citrus; 

Clover Grown for Seed (SLN 

CA); Cucurbits (East of 

Rockies), Garlic (OR & CA - 

Modoc & Siskiyou counties, 

SLN NY); Nonbearing Fruit 

(apple, cherry, citrus, peach, 

pear); Dry Bulb Onions (CA - 

Modoc & Siskiyou counties, OR, 

ID, WA, SLN CO, SLN NV, 

SLN NY, SLN UT); Peppermint 

and Spearmint (ID, MI, MT, OR, 

WA, WI); Peppers; Potatoes 

(also SLN-PA); Tomatoes 

1 350 0.023 1.2 0.12 0.006 70 

Cotton (CA and AZ) 1 1200 0.023 1.2 0.39 0.021 20 

Cotton (not AZ and CA) 0.5 1200 0.023 1.2 0.2 0.01 41 

Mixing/Loading Liquid 

Concentrates for Aerial 

Applications (PHED) 

Celery (AZ, CA, FL); Dry Bulb 

Onions (MI, NM, TX, SLN WI); 

Peanuts (not CA) 

0.5 350 0.023 1.2 0.058 0.003 140 
Page 45 of 59 

APPENDIX B Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Personal Protective Equipment.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres)

Dermal 

PPE-G 

(mg/lb ai)

Baseline 

Inhalation 

(μg/lb ai) 

Dermal PPE-Gd

(mg/kg/day) 

Baseline 

Inhalatione

(mg/kg/day

) 

Dermal 

PPE-Gf

(LOC = 

100) 

Apples; Carrot (not CA); Celery 

(FL, PA, OH, MI, TX); Citrus; 

Eggplant (not CA); Garlic (CA, 

OR); Dry Bulb Onions (CA, OR, 

ID, WA. MI, TX); Pears (not 

CA); Peppermint and Spearmint 

(ID, MI, MT, OR, WA, WI); 

Pineapple (not CA); Potatoes 

(SLN MD, SLN NY, SLN PA); 

Tobacco; Tomatoes 

2 350 0.023 1.2 0.23 0.012 35 

Apples for Thinning (NJ, PA, 

VA, WV); Cotton (CA and AZ); 

Cucurbits; Eggplant (CA); Garlic 

(SLNWA); Nonbearing Fruit 

(apple, cherry, citrus, peach, 

pear); Peppers; Potatoes 

1 350 0.023 1.2 0.12 0.006 70 

Mixing/Loading Liquid 

Concentrates for 

Chemigation Applications 

(PHED) 

. 

Celery (AZ, CA); Cotton (not 

CA and AZ); Dry Bulb Onions 

(NM); Peanuts (not CA); Yams 

(Puerto Rico only) 

0.5 350 0.023 1.2 0.058 0.003 140 
Page 46 of 59 

APPENDIX B Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Personal Protective Equipment.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres)

Dermal 

PPE-G 

(mg/lb ai)

Baseline 

Inhalation 

(μg/lb ai) 

Dermal PPE-Gd

(mg/kg/day) 

Baseline 

Inhalatione

(mg/kg/day

) 

Dermal 

PPE-Gf

(LOC = 

100) 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear; soil); Carrots 

(not CA); Celery (FL, PA, OH, 

MI, TX); Cucurbits (East of 

Rockies); Garlic (OR, SLN NY); 

Ginger Roots (HI); Dry Bulb 

Onions (MI, TX, OR, ID, WA, 

SLN NY, SLN WI); Sweet 

Potatoes (not in CA); Potatoes 

(U.S. except Northeast, MidAtlantic States) 

4 

(all soildirected) 80 0.023 1.2 0.11 0.0055 76 

Pineapples (not CA); Eggplants 

(not CA); Garlic (CA); Dry Bulb 

Onions (CA); Peppermint and 

Spearmint (ID, MI, MT, OR, 

WA, WI); Potatoes (SLN MD, 

SLN NY, SLN PA); Tobacco 

2 80 0.023 1.2 0.053 0.0027 150 

Tomatoes (CA) 1.25 80 0.023 1.2 0.033 0.0017 240 

Clover Grown for Seed (SLN 

CA); Cucurbits (West of 

Rockies); Dry Bulb Onions (, 

SLN CO, SLN NV, SLN UT); 

Eggplants (CA); Garlic 

(SLNWA); Peppers; Potatoes 

(Northeast and Mid-Atlantic 

States); Tomatoes 

1 80 0.023 1.2 0.026 0.0014 300 

Cotton (AZ and CA) 1 200 0.023 1.2 0.066 0.0034 120 

Cotton (U.S. except CA and AZ) 0.5 200 0.023 1.2 0.033 0.0017 240 

Mixing/Loading Liquid 

Concentrates for 

Groundboom Applications 

(PHED) 

Celery (AZ, CA); Dry Bulb 

Onions (NM); Yams (Puerto 

Rico Only); Peanuts (not in CA) 

0.5 80 0.023 1.2 0.013 0.00069 610 
Page 47 of 59 

APPENDIX B Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Personal Protective Equipment.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres)

Dermal 

PPE-G 

(mg/lb ai)

Baseline 

Inhalation 

(μg/lb ai) 

Dermal PPE-Gd

(mg/kg/day) 

Baseline 

Inhalatione

(mg/kg/day

) 

Dermal 

PPE-Gf

(LOC = 

100) 

Apples; Pears (not CA) 2 40 0.023 1.2 0.026 0.0014 300 

Mixing/Loading Liquid 

Concentrates for Airblast 

Applications (PHED) 

Apples for Thinning (NJ, PA, 

VA, WV); Citrus; Nonbearing 

Fruit (apple, cherry, citrus, 

peach, pear) 

1 40 0.023 1.2 0.013 0.00069 610 

Applicator 

Apples (WA only); Citrus; 

Clover Grown for Seed (SLN 

CA); Cucurbits (East of 

Rockies), Garlic (OR & CA - 

Modoc & Siskiyou counties, 

SLN NY); Nonbearing Fruit 

(apple, cherry, citrus, peach, 

pear); Dry Bulb Onions (CA - 

Modoc & Siskiyou counties, OR, 

ID, WA, SLN CO, SLN NV, 

SLN NY, SLN UT, SLN WI); 

Peppermint and Spearmint (ID, 

MI, MT, OR, WA, WI); Peppers; 

Potatoes (also SLN PA); 

Tomatoes 

1 350 No Data No Data No Data No Data No Data 

Cotton (CA and AZ) 1 1200 No Data No Data No Data No Data No Data 

Cotton (not AZ and CA) 0.5 1200 No Data No Data No Data No Data No Data 

Applying Sprays via 

Aerial Equipment 

(PHED)d 

Celery (AZ, CA, FL); Dry Bulb 

Onions (MI, NM, TX); Peanuts 

(not CA) 

0.5 350 No Data No Data No Data No Data No Data 
Page 48 of 59 

APPENDIX B Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Personal Protective Equipment.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres)

Dermal 

PPE-G 

(mg/lb ai)

Baseline 

Inhalation 

(μg/lb ai) 

Dermal PPE-Gd

(mg/kg/day) 

Baseline 

Inhalatione

(mg/kg/day

) 

Dermal 

PPE-Gf

(LOC = 

100) 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear); Carrot (not 

CA); Celery (FL, PA, OH, MI, 

TX); Cucurbits (East of 

Rockies); Garlic (OR, SLN NY); 

Ginger Root (HI); Dry Bulb 

Onions (MI, TX, OR, ID, WA, 

SLN NY, SLN WI); Sweet 

Potatoes (not in CA); Potatoes 

(U.S. except Northeast, MidAtlantic States) 

4 

(all soildirected) 80 0.014 0.74 0.064 0.0034 130 

Pineapple (not CA); Eggplant 

(not CA); Garlic (CA); Dry Bulb 

Onions (CA); Peppermint and 

Spearmint (ID, MI, MT, OR, 

WA, WI); Potatoes (SLN MD, 

SLN NY, SLN PA); Tobacco 

2 80 0.014 0.74 0.032 0.0017 250 

Tomatoes (CA) 1.25 80 0.014 0.74 0.02 0.0011 400 

Clover Grown for Seed (SLN 

CA); Cucurbits (West of 

Rockies); Dry Bulb Onions (SLN 

CO, SLN NV, SLN U T); 

Eggplant (CA); Garlic 

(SLNWA); Peppers; Potatoes 

(Northeast and Mid-Atlantic 

States); Tomatoes 

1 80 0.014 0.74 0.016 0.00085 500 

Cotton (AZ and CA) 1 200 0.014 0.74 0.04 0.0021 200 

Cotton (U.S. except CA and AZ) 0.5 200 0.014 0.74 0.02 0.0011 400 

Applying Sprays via 

Groundboom Equipment 

(PHED) 

Celery (AZ, CA); Dry Bulb 

Onions (NM); Yams (Puerto 

Rico Only); Peanuts (not in CA) 

0.5 80 0.014 0.74 0.008 0.00042 1000 
Page 49 of 59 

APPENDIX B Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Personal Protective Equipment.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres)

Dermal 

PPE-G 

(mg/lb ai)

Baseline 

Inhalation 

(μg/lb ai) 

Dermal PPE-Gd

(mg/kg/day) 

Baseline 

Inhalatione

(mg/kg/day

) 

Dermal 

PPE-Gf

(LOC = 

100) 

Apples; Pears (not CA) 2 40 0.24 4.5 0.27 0.0051 29 

Applying Sprays via 

Airblast Equipment 

(PHED) 

Apples for Thinning (NJ, PA, 

VA, WV); Citrus; Nonbearing 

Fruit (apple, cherry, citrus, 

peach, pear) 

1 40 0.24 4.5 0.14 0.0026 58 

Flagger 

Apples (WA only); Citrus; 

Clover Grown for Seed (SLN 

CA); Cucurbits (East of 

Rockies), Garlic (OR & CA - 

Modoc & Siskiyou counties, 

SLN NY); Nonbearing Fruit 

(apple, cherry, citrus, peach, 

pear); Dry Bulb Onions (CA - 

Modoc & Siskiyou counties, OR, 

ID, WA, SLN CO, SLN NV, 

SLN NY, SLN UT, SLN WI); 

Peppermint and Spearmint (ID, 

MI, MT, OR, WA, WI); Peppers; 

Potatoes (also SLN PA); 

Tomatoes 

1 350 Not applicable 0.35 Not applicable 0.0018 Not applicabl

Cotton (CA and AZ) 1 350 Not applicable 0.35 Not applicable 0.0018 Not applicabl

Cotton (U.S. except AZ and CA) 0.5 350 Not applicable 0.35 Not applicable 0.00088 Not applicabl

Flagging for Aerial Sprays 

Applications (PHED) 

Celery (AZ, CA, FL); Dry Bulb 

Onions (MI, NM, TX); Peanuts 

(not CA) 

0.5 350 Not applicable 0.35 Not applicable 0.00088 Not applicabl
Page 50 of 59 

APPENDIX B Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Personal Protective Equipment.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Application 

Ratea

(lb ai/A) 

Area 

Treated 

Dailyb

(acres)

Dermal 

PPE-G 

(mg/lb ai)

Baseline 

Inhalation 

(μg/lb ai) 

Dermal PPE-Gd

(mg/kg/day) 

Baseline 

Inhalatione

(mg/kg/day

) 

Dermal 

PPE-Gf

(LOC = 

100) 

Mixer/Loader/Applicator 

Mixing/Loading/Applying 

Liquid Concentrates with 

Low Pressure Handwand 

(PHED) 

Bananas, Plantains (PR) 3.6 2 0.43 30 0.044 0.0031 180 

Mixing/Loading/Applying 

Liquid Concentrates with 

Low Pressure Handwand 

(ORETF, ground directed) 

Bananas, Plantains (PR) 3.6 2 0.33 2.7 0.034 0.00028 240 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear) 4 5 0.45 1.8 0.13 0.00051 62 

Mixing/Loading/Applying Liquid Concentrates with 

a Handgun Sprayer (LCO 

ORETF data) Apples; Pears (not CA) 2 5 0.45 1.8 0.064 0.00026 120 

Mixing/Loading/Applying 

Liquid Concentrates with 

a Handgun Sprayer (LCO 

ORETF data) cont 

Apples for Thinning (NJ, PA, 

VA, WV); Citrus 1 5 0.45 1.8 0.032 0.00013 250 

Footnotes

a. Application rates are maximum application rates from the labels. b. Science Advisory Council Policy # 9.1 c. Unit Exposures based on PHED Version 1.1 and ORETF.  Baseline dermal unit exposure represents long pants, long sleeved shirt, no gloves, open mixing/loading, open cab tractor. 

 Baseline inhalation exposure represents no respirator. 

PPE – G = Baseline attire (single layer of clothing) plus chemical-resistant gloves. EC = Engineering Control = closed systems for mixing/loading liquids, enclosed cockpits for aerial application, and enclosed cabs fo

d. Only engineering control (enclosed cockpit) data are available to assess dermal and inhalation risks to handlers operating aircraft. e. Dermal Dose (mg/kg/day) = daily unit exposure (mg/lb ai) x application rate (lb ai/acre) x acres treated / body weight (70 kg). f. Inhalation Dose (mg/kg/day) = daily unit exposure (μg/lb ai) x conversion factor (1 mg/1,000 μg) x application rate (lb ai/acre) x acr

(70 kg). g. Dermal MOE = NOAEL (8 mg/kg/day) / dermal daily dose (mg/kg/day). Level of concern = 100.h. Inhalation MOE = NOAEL (0.39 mg/kg/day) / inhalation daily dose (mg/kg/day). Level of concern = 30. i Aggregated Risk Index (ARI) -- combined dermal and inhalation risks = 1 / (1/ (Dermal MOE /300) + 1/ (Inhalation MOE / 100)). L
Page 51 of 59 

APPENDIX C Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Engineering Controls.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Applicatio

n Ratea

(lb ai/A) 

Area 

Treate

d 

Dailyb

 (acres)

Dermal 

Eng Cntl

(mg/lb 

ai) 

Inhalation 

Eng Cntl 

(μg/lb ai) 

Dermal 

Eng Cntl d

(mg/kg/day) 

Inhalation 

Eng Cntl e

(mg/kg/day

) 

Derma

Eng Cn

 f

(LOC = 

100) 

Mixer/Loader 

Apples (WA only); Citrus; Clover 

Grown for Seed (SLN CA); 

Cucurbits (East of Rockies), Garlic 

(OR & CA - Modoc & Siskiyou 

counties, SLN NY); Nonbearing 

Fruit (apple, cherry, citrus, peach, 

pear); Dry Bulb Onions (CA - 

Modoc & Siskiyou counties, OR, 

ID, WA, SLN CO, SLN NV, SLN 

NY, SLN UT); Peppermint and 

Spearmint (ID, MI, MT, OR, WA, 

WI); Peppers; Potatoes (also SLNPA); Tomatoes 

1 350 0.0086 0.083 0.043 0.00042 190 

Cotton (CA and AZ) 1 1200 0.0086 0.083 0.15 0.0014 54 

Cotton (not AZ and CA) 0.5 1200 0.0086 0.083 0.074 0.00071 110 

Mixing/Loading Liquid 

Concentrates for Aerial 

Applications (PHED) 

Celery (AZ, CA, FL); Dry Bulb 

Onions (MI, NM, TX, SLN WI); 

Peanuts (not CA) 

0.5 350 0.0086 0.083 0.022 0.00021 370 
Page 52 of 59 

APPENDIX C Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Engineering Controls.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Applicatio

n Ratea

(lb ai/A) 

Area 

Treate

d 

Dailyb

 (acres)

Dermal 

Eng Cntl

(mg/lb 

ai) 

Inhalation 

Eng Cntl 

(μg/lb ai) 

Dermal 

Eng Cntl d

(mg/kg/day) 

Inhalation 

Eng Cntl e

(mg/kg/day

) 

Derma

Eng Cn

 f

(LOC = 

100) 

Apples; Carrot (not CA); Celery 

(FL, PA, OH, MI, TX); Citrus; 

Eggplant (not CA); Garlic (CA, 

OR); Dry Bulb Onions (CA, OR, ID, 

WA. MI, TX); Pears (not CA); 

Peppermint and Spearmint (ID, MI, 

MT, OR, WA, WI); Pineapple (not 

CA); Potatoes (SLN MD, SLN NY, 

SLN PA); Tobacco; Tomatoes 

2 350 0.0086 0.083 0.086 0.00083 93 

Apples for Thinning (NJ, PA, VA, 

WV); Cotton (CA and AZ); 

Cucurbits; Eggplant (CA); Garlic 

(SLNWA); Nonbearing Fruit (apple, 

cherry, citrus, peach, pear); Peppers; 

Potatoes 

1 350 0.0086 0.083 0.043 0.00042 190 

Mixing/Loading Liquid 

Concentrates for 

Chemigation Applications 

(PHED) 

. 

Celery (AZ, CA); Cotton (not CA 

and AZ); Dry Bulb Onions (NM); 

Peanuts (not CA); Yams (Puerto 

Rico only) 

0.5 350 0.0086 0.083 0.022 0.00021 370 
Page 53 of 59 

APPENDIX C Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Engineering Controls.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Applicatio

n Ratea

(lb ai/A) 

Area 

Treate

d 

Dailyb

 (acres)

Dermal 

Eng Cntl

(mg/lb 

ai) 

Inhalation 

Eng Cntl 

(μg/lb ai) 

Dermal 

Eng Cntl d

(mg/kg/day) 

Inhalation 

Eng Cntl e

(mg/kg/day

) 

Derma

Eng Cn

 f

(LOC = 

100) 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear; soil); Carrots 

(not CA); Celery (FL, PA, OH, MI, 

TX); Cucurbits (East of Rockies); 

Garlic (OR, SLN NY); Ginger Roots 

(HI); Dry Bulb Onions (MI, TX, 

OR, ID, WA, SLN NY, SLN WI); 

Sweet Potatoes (not in CA); 

Potatoes (U.S. except Northeast, 

Mid-Atlantic States) 

4 

(all soildirected) 80 0.0086 0.083 0.039 0.00038 200 

Pineapples (not CA); Eggplants (not 

CA); Garlic (CA); Dry Bulb Onions 

(CA); Peppermint and Spearmint 

(ID, MI, MT, OR, WA, WI); 

Potatoes (SLN MD, SLN NY, SLN 

PA); Tobacco 

2 80 0.0086 0.083 0.02 0.00019 410 

Tomatoes (CA) 1.25 80 0.0086 0.083 0.012 0.00012 650 

Clover Grown for Seed (SLN CA); 

Cucurbits (West of Rockies); Dry 

Bulb Onions (, SLN CO, SLN NV, 

SLN UT); Eggplants (CA); Garlic 

(SLNWA); Peppers; Potatoes 

(Northeast and Mid-Atlantic States); 

Tomatoes (entire US) 

1 80 0.0086 0.083 0.0098 0.000095 810 

Cotton (AZ and CA) 1 200 0.0086 0.083 0.025 0.00024 330 

Cotton (U.S. except CA and AZ) 0.5 200 0.0086 0.083 0.012 0.00012 650 

Mixing/Loading Liquid 

Concentrates for 

Groundboom 

Applications (PHED) 

Celery (AZ, CA); Dry Bulb Onions 

(NM); Yams (Puerto Rico Only); 

Peanuts (not in CA) 

0.5 80 0.0086 0.083 0.0049 0.000047 1600 
Page 54 of 59 

APPENDIX C Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Engineering Controls.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Applicatio

n Ratea

(lb ai/A) 

Area 

Treate

d 

Dailyb

 (acres)

Dermal 

Eng Cntl

(mg/lb 

ai) 

Inhalation 

Eng Cntl 

(μg/lb ai) 

Dermal 

Eng Cntl d

(mg/kg/day) 

Inhalation 

Eng Cntl e

(mg/kg/day

) 

Derma

Eng Cn

 f

(LOC = 

100) 

Apples; Pears (not CA) 2 40 0.0086 0.083 0.0098 0.000095 810 

Mixing/Loading Liquid 

Concentrates for Airblast 

Applications (PHED) 

Apples for Thinning (NJ, PA, VA, 

WV); Citrus; Nonbearing Fruit 

(apple, cherry, citrus, peach, pear) 

1 40 0.0086 0.083 0.0049 0.000047 1600 

Applicator 

Apples (WA only); Citrus; Clover 

Grown for Seed (SLN CA); 

Cucurbits (East of Rockies), Garlic 

(OR & CA - Modoc & Siskiyou 

counties, SLN NY); Nonbearing 

Fruit (apple, cherry, citrus, peach, 

pear); Dry Bulb Onions (CA - 

Modoc & Siskiyou counties, OR, 

ID, WA, SLN CO, SLN NV, SLN 

NY, SLN UT, SLN WI); Peppermint 

and Spearmint (ID, MI, MT, OR, 

WA, WI); Peppers; Potatoes (also 

SLN PA); Tomatoes 

1 350 0.005 0.068 0.025 0.00034 320 

Cotton (CA and AZ) 1 1200 0.005 0.068 0.086 0.0012 93 

Cotton (not AZ and CA) 0.5 1200 0.005 0.068 0.043 0.00058 190 

Applying Sprays via 

Aerial Equipment 

(PHED)d 

Celery (AZ, CA, FL); Dry Bulb 

Onions (MI, NM, TX); Peanuts (not 

CA) 

0.5 350 0.005 0.068 0.013 0.00017 640 
Page 55 of 59 

APPENDIX C Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Engineering Controls.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Applicatio

n Ratea

(lb ai/A) 

Area 

Treate

d 

Dailyb

 (acres)

Dermal 

Eng Cntl

(mg/lb 

ai) 

Inhalation 

Eng Cntl 

(μg/lb ai) 

Dermal 

Eng Cntl d

(mg/kg/day) 

Inhalation 

Eng Cntl e

(mg/kg/day

) 

Derma

Eng Cn

 f

(LOC = 

100) 

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear); Carrot (not 

CA); Celery (FL, PA, OH, MI, TX); 

Cucurbits (East of Rockies); Garlic 

(OR, SLN NY); Ginger Root (HI); 

Dry Bulb Onions (MI, TX, OR, ID, 

WA, SLN NY, SLN WI); Sweet 

Potatoes (not in CA); Potatoes (U.S. 

except Northeast, Mid-Atlantic 

States) 

4 

(all soildirected) 80 0.005 

0.74 

(baseline 

inhalation

) 

0.023 

0.0034 

(baseline 

inhalation) 

350 

Pineapple (not CA); Eggplant (not 

CA); Garlic (CA); Dry Bulb Onions 

(CA); Peppermint and Spearmint 

(ID, MI, MT, OR, WA, WI); 

Potatoes (SLN MD, SLN NY, SLN 

PA); Tobacco 

2 80 0.005 

0.74 

(baseline 

inhalation

) 

0.011 

0.0017 

(baseline 

inhalation) 

700 

Tomatoes (CA) 1.25 80 0.005 

0.74 

(baseline 

inhalation

) 

0.0071 

0.0011 

(baseline 

inhalation) 

1100 

Clover Grown for Seed (SLN CA); 

Cucurbits (West of Rockies); Dry 

Bulb Onions (SLN CO, SLN NV, 

SLN U T); Eggplant (CA); Garlic 

(SLNWA); Peppers; Potatoes 

(Northeast and Mid-Atlantic States); 

Tomatoes (entire US) 

1 80 0.005 

0.74 

(baseline 

inhalation

) 

0.0057 

0.00085 

(baseline 

inhalation) 

1400 

Cotton (AZ and CA) 1 200 0.005 

0.74 

(baseline 

inhalation

) 

0.014 

0.0021 

(baseline 

inhalation) 

560 

Applying Sprays via 

Groundboom Equipment 

(PHED) 

Cotton (U.S. except CA and AZ) 0.5 200 0.005 0.74 

(baseline 

inhalation

0.0071 0.0011 

(baseline 

inhalation) 

1100 
Page 56 of 59 

APPENDIX C Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Engineering Controls.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Applicatio

n Ratea

(lb ai/A) 

Area 

Treate

d 

Dailyb

 (acres)

Dermal 

Eng Cntl

(mg/lb 

ai) 

Inhalation 

Eng Cntl 

(μg/lb ai) 

Dermal 

Eng Cntl d

(mg/kg/day) 

Inhalation 

Eng Cntl e

(mg/kg/day

) 

Derma

Eng Cn

 f

(LOC = 

100) 

) 

Celery (AZ, CA); Dry Bulb Onions 

(NM); Yams (Puerto Rico Only); 

Peanuts (not in CA) 

0.5 80 0.005 

0.74 

(baseline 

inhalation

) 

0.0029 

0.00042 

(baseline 

inhalation) 

2800 

Apples; Pears (not CA) 2 40 0.019 

4.5 

(baseline 

inhalation

) 

0.022 

0.0051 

(baseline 

inhalation) 

370 

Applying Sprays via 

Airblast Equipment 

(PHED) 

Apples for Thinning (NJ, PA, VA, 

WV); Citrus; Nonbearing Fruit 

(apple, cherry, citrus, peach, pear) 

1 40 0.019 

4.5 

(baseline 

inhalation

) 

0.011 

0.0026 

(baseline 

inhalation) 

740 

Flagger 

Apples (WA only); Citrus; Clover 

Grown for Seed (SLN CA); 

Cucurbits (East of Rockies), Garlic 

(OR & CA - Modoc & Siskiyou 

counties, SLN NY); Nonbearing 

Fruit (apple, cherry, citrus, peach, 

pear); Dry Bulb Onions (CA - 

Modoc & Siskiyou counties, OR, 

ID, WA, SLN CO, SLN NV, SLN 

NY, SLN UT, SLN WI); Peppermint 

and Spearmint (ID, MI, MT, OR, 

WA, WI); Peppers; Potatoes (also 

SLN PA); Tomatoes 

1 350 0.00022

0.35 

(baseline 

inhalation

) 

0.0011 

0.0018 

(baseline 

inhalation) 

7300 

Flagging for Aerial 

Sprays Applications 

(PHED) 

Cotton (CA and AZ) 1 350 0.00022 0.35 

(baseline 

inhalation

0.0011 0.0018 

(baseline 

inhalation) 

7300 
Page 57 of 59 

APPENDIX C Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Engineering Controls.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Applicatio

n Ratea

(lb ai/A) 

Area 

Treate

d 

Dailyb

 (acres)

Dermal 

Eng Cntl

(mg/lb 

ai) 

Inhalation 

Eng Cntl 

(μg/lb ai) 

Dermal 

Eng Cntl d

(mg/kg/day) 

Inhalation 

Eng Cntl e

(mg/kg/day

) 

Derma

Eng Cn

 f

(LOC = 

100) 

) 

Cotton (U.S. except AZ and CA) 0.5 350 0.00022

0.35 

(baseline 

inhalation

) 

0.00055 

0.00088 

(baseline 

inhalation) 

15000 

Celery (AZ, CA, FL); Dry Bulb 

Onions (MI, NM, TX); Peanuts (not 

CA) 

0.5 350 0.00022

0.35 

(baseline 

inhalation

) 

0.00055 

0.00088 

(baseline 

inhalation) 

15000 
Page 58 of 59 

APPENDIX C Occupational Short-Term and Intermediate-Term Dermal and Inhalation Oxamyl D

with Engineering Controls.

Unit Exposurec, d Dose 

Exposure Scenario Crop or Target 

Applicatio

n Ratea

(lb ai/A) 

Area 

Treate

d 

Dailyb

 (acres)

Dermal 

Eng Cntl

(mg/lb 

ai) 

Inhalation 

Eng Cntl 

(μg/lb ai) 

Dermal 

Eng Cntl d

(mg/kg/day) 

Inhalation 

Eng Cntl e

(mg/kg/day

) 

Derma

Eng Cn

 f

(LOC = 

100) 

Mixer/Loader/Applicator 

Mixing/Loading/Applyin

g Liquid Concentrates 

with Low Pressure 

Handwand (PHED) 

Bananas, Plantains (PR) 3.6 2 Not Feasible Not Feasible Not Feasible Not Feasible Not Feasibl

Mixing/Loading/Applyin

g Liquid Concentrates 

with Low Pressure 

Handwand (ORETF, 

ground directed) 

Bananas, Plantains (PR) 3.6 2 Not Feasible Not Feasible Not Feasible Not Feasible Not Feasibl

Nonbearing Fruit (apple, cherry, 

citrus, peach, pear) 4 5 Not Feasible Not Feasible Not Feasible Not Feasible Not Feasibl

Mixing/Loading/Applyin g Liquid Concentrates 

with a Handgun Sprayer 

(LCO ORETF data) Apples; Pears (not CA) 2 5 Not Feasible Not Feasible Not Feasible Not Feasible Not Feasibl

Mixing/Loading/Applyin

g Liquid Concentrates 

with a Handgun Sprayer 

(LCO ORETF data) cont 

Apples for Thinning (NJ, PA, VA, 

WV); Citrus 1 5 Not Feasible Not Feasible Not Feasible Not Feasible Not Feasibl

Footnotes

a. Application rates are maximum application rates from the labels. b. Science Advisory Council Policy # 9.1 c. Unit Exposures based on PHED Version 1.1 and ORETF. 

EC = Engineering Control = closed systems for mixing/loading liquids, enclosed cockpits for aerial application, and enclosed cabs f

airblast application, and enclosed cabs for flaggers. 

 Baseline inhalation exposure represents no respirator. d. Only engineering control (enclosed cockpit) data are available to assess dermal and inhalation risks to handlers operating aircraft. e. Dermal Dose (mg/kg/day) = daily unit exposure (mg/lb ai) x application rate (lb ai/acre) x acres treated / body weight (70 kg). f. Inhalation Dose (mg/kg/day) = daily unit exposure (μg/lb ai) x conversion factor (1 mg/1,000 μg) x application rate (lb ai/acre) x acr

(70 kg). 

g. Dermal MOE = NOAEL (8 mg/kg/day) / dermal daily dose (mg/kg/day). Level of concern = 100.
Page 59 of 59 

h. Inhalation MOE = NOAEL (0.39 mg/kg/day) / inhalation daily dose (mg/kg/day). Level of concern = 30. i Aggregated Risk Index (ARI) -- combined dermal and inhalation risks = 1 / (1/ (Dermal MOE /300) + 1/ (Inhalation MOE / 100)). L