Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

United States Chemical Safety June 2010

Environmental Protection and Pollution Prevention Agency (7510P)



# Dichromic Acid Summary Document:

Registration ReviewDocket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov



### TABLE OF CONTENTS

Dichromic Acid Registration Review Team ................................................................... 4

I. PRELIMINARY WORK PLAN – DICHROMIC ACID .......................................... 5

II. FACT SHEET ............................................................................................................ 14

III. GLOSSARY of TERMS & ABBREVIATIONS ................................................... 17

IV. APPENDIX A ............................................................................................................ 19

3 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

Dichromic Acid Registration Review Team

Human Health & Environmental Effects

Nathan Mottl A. Najm Shamim

Risk Management Rebecca von dem Hagen

Lance Wormell

Office of General Counsel Philip Ross

4 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

I. PRELIMINARY WORK PLAN – DICHROMIC ACID

Introduction

The Food Quality Protection Act (FQPA) of 1996 mandated the registration review program. All pesticides distributed or sold in the United States generally must be registered by the U.S. Environmental Protec tion Agency (USEPA, EPA, or the Agency), based on scientific data showing that they will not cause unreasonable risks to human

health or the environment when used as di rected on product labe ling. The registration review program is intended to make sure that , as the ability to assess risk evolves and as policies and practices change, all registered pesticides continue to meet the statutory

standard of no unreasonable adverse effects to human health or the environment. Changes in science, public policy, and pesticide use practices will occur over time. Through the registration review program, the Agency periodically reevaluate s pesticides to make sure that as change occurs, products in the mark etplace can be used safely. Information on this program is provided at http://www.epa.gov/oppsrrd1/ registration_review/

.

The Agency is implementing the registration review program pursuant to Section 3(g) of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and will review each registered pesticide every 15 years to de termine whether it continues to meet the FIFRA standard for registration. The Agency will consider benefits information and data as required by FIFRA. The public phase of re gistration review begins when the initial docket is opened for each case. The docket is the Agency’s opportunity to state what it knows about the pesticide and what additional risk analyses and data or information it believes are needed to make a registrati on review decision. After reviewing and responding to comments and data received in the docket during th is initial comment period, the Agency will develop and commit to a final work plan and schedule for the registration review of the active ingredient dichromic acid.

The sole pesticidal use of dichromic aci d (PC Code 068306) is for the formulation of tank mix solutions for chromated copper arsena te (CCA). CCA is sold as a restricted use wood preservative primarily for commerc ial and institutional uses in indoor and outdoor sites. Effective December 31, 2003, CCA registrants terminated through voluntary amendments to product registrations virtually all residen tial uses. The only remaining residential uses are shakes/shingl es and permanent wood foundations. There are currently no food uses , tolerances or exemptions from the requirement of a tolerance

for dichromic acid.

A pesticide product containing dichromic acid was first registered in 1994. Because dichromic acid was registered afte r November 1984, this ingredient was not considered under EPA’s reregistration progr am. However, a Reregistration Eligibility Decision (RED) for chromated arsenical s was completed in 2008. The 2008 RED addressed potential exposure and risk fr om chromium (VI) oxi de (also known as “chromic acid”). Chromic acid and dichro mic acid are both created through the same chemical processes and composed of chromium in the hexavalent form (CR(VI)), with dichromic acid being a relatively unstable fo rm of chromic acid. Because chromic acid

5 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

and dichromic acid are composed of the sa me chemical of toxicological significance (hexavalent chromium), the Agency intends to incorporate data received in response to the chromic acid RED DCI into the risk assessments to be performed for the registration review of dichromic acid. The Agency anti cipates issuing the chromic acid RED DCI in FY2011 and anticipates reviewing any data recei ved in response to the RED DCI prior to conducting the registration review risk assessm ents for dichromic acid. Also, the Agency notes that this registration re view will be based on updated labels received in response to the 2008 chromated arsenicals RED and approved by the Agency in May 2010 for the two active registrations. The updated labels reflect mitigation measures outlined in the

2008 RED.

Risk Assessment Status & Anticipa ted Data Needs

Human Health Risk Assessment Status and Anticipated Data Needs

The Agency reviewed the hazard and expos ure databases for dichromic acid. As a result of this review, EPA confirmed that th e data to be required for dichromic acid as a result of the September 2008 chromated arsenica ls RED are still needed. The studies that will be required upon issuance of the RED Da ta Call-In (DCI) can be found in the Agency’s chromated arsenicals RED at http://www.regulations.gov in docket number EPA-HQ-OPP-2003-0250. The Agency does not anti cipate the need to require any other

human health data for dichromic acid th rough the registration review program.

Dietary Assessment

Acute and chronic dietary assessments are not necessary for dichromic acid

because there are no uses of di chromic acid attributable to the dietary route of exposure.

Because wood preservative use is not expected to result in drinking water exposure, a drinking water assessment is not an ticipated to be needed. According to the RED, “studies of sorption into soils from utility poles, have shown that the release of

metals into soils/sediments from the base of treated wood, decks or utility poles or from the pressure treatment facil ities, do not show a high degree of migration, either to groundwater or to the surface. In most cases, after migration of the metals a few meters down into soil, these metals attain the background level conc entration of soil.”

Tolerances

There are currently no tolerances or exemp tions for the requirement of a tolerance

for dichromic acid.

Occupational and Residen tial Assessm ent and Risk

The Agency reviewed all available data associated with dichromic acid and has determined that the currently registered uses of dichromic acid may result in occupational

6 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

exposure. An occupational risk assessm ent for inhalation exposure to Cr (VI) was performed in 2008 for the chromated arsenical s RED. The Agency reviewed the 2008

risk assessment and determined that the data to be called in up on the issuance of the chromated arsenicals RED DCI are still needed and does not anticipate the need to require any other human health data for di chromic acid through the registration review program. Contingent upon the receipt of the data for chromic acid to be required through the reregistration process from chromated arsenicals, the Agency may develop new occupational inhalation risk assessments fo r the dichromic acid registration review.

CCA is no longer registered for use on wood intended to be used for decks or play sets and the remaining two residential us es (shakes/shingles and permanent wood foundations) are not expected to result in significant exposure to dichromic acid. Therefore, a residential assessment is not required for these uses.

Aggregate Exposure and Risk

In examining aggregate exposure, EPA takes into account the available and reliable information concerning exposures to pesticide residues in food and drinking water, and non-occupational pe sticide exposures. As previous ly stated, acute and chronic dietary assessments will not be conducted for dichromic acid because there are no uses of

dichromic acid which would be attributable to the dietary route of exposure. The remaining residential uses of dichromic acid are not expected to result in significant residential exposure. Therefore, no need is anticipated for an aggregate exposure

assessment.

Anticipated Human Health Data Needs

EPA confirmed that the data to be requi red for dichromic acid as a result of the September 2008 chromated arsenicals RED are still needed and the Agency does not anticipate the need to require any other human health data for dichromic ac id through the registration review program.

For further information see the document titled, “Summary of Human Health Effects Data for the Dichromic Acid Regi stration Review Decision Document,” dated May 27, 2010.

Anticipated Physical/Chemical Property Data Needs

All product chemistry data requirements have been fulfilled for dichromic acid. Therefore, it is anticipated that additional pr oduct chemistry data will not be needed for

dichromic acid.

For further information see the docum ent titled, Dichromic Acid: Product Chemistry/Environmental Fate and Eco-Ef fects Scoping Document dated May 6, 2010.

7 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

Environmental Fate and Ecological Risk A ssessment Status and Anticipated Data

Needs

The Agency reviewed the environmental fate and ecological hazard databases for dichromic acid. As a result of this review, EPA confirmed that the data to be required for

dichromic acid as a result of the chromated ar senicals RED are still needed. The studies that will be called in for reregistration can be found in the Agency’s chromated arsenicals

RED at http://www.regulations.gov in docket number EPA-HQ-OPP-2003-0250. The Agency does not anticipate the need to requir e any additional environmental fate data for dichromic acid through the registration review program.

For further information see the docum ent titled, “Dichromic Acid: Product Chemistry/Environmental Fate and Eco-Ef fects Scoping Document” dated May 6, 2010.

Endangered Species

The Agency has not conducted a risk assessment that supports a complete endangered species determination for dichro mic acid. The ecological risk assessment planned during registration review will a llow the Agency to determine whether chromium (VI), the chemical of toxicol ogical concern found in pesticide products containing dichromic acid (Case 5012) and ch romic acid (Case 0132), has “no effect” or “may affect” federally listed threatened or endangered species (listed species) or their designated critical habitats. Because the chemical of t oxicological concern and use patterns are the same for chromic acid and dichromic acid, the Agency intends to perform a comprehensive endangered species assessmen t for chromium (VI). When an assessment concludes that a pesticide’s use “may affect” a listed species or its designated critical habitat, the Agency will consult with the U.S. Fish and Wildlife Service and/or National Marine Fisheries Services (the Services), as appropriate.

Incidents:

In the chromated arsenicals RED only limite d incident reports ar e associated with exposure to end-use products containing chro mated arsenicals. In contrast, a large body of literature exists on the health effects (acute and chronic) in humans of exposure to the components of chromated arsenicals, partic ularly arsenic and, to a lesser degree, chromium and copper. Itching, burning rashes , neurological symp toms, and breathing problems associated with handling unmarked CCA-treated wood have been reported. Sap draining from CCA treated wood stairs has been reported as a potenti al source of dermal and inhalation exposure leading to dermatitis and development of f ilm on the teeth. At least one individual reported “ruined” nerves in feet and legs which he attributed to exposure to saw dust and fumes from cutting and routing CCA-treated lumber. No new incidents have been reported for dichromi c acid since the chromated arsenicals RED has been completed.

8 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

Timeline:

EPA has created the following estimated timeline for the completion of the dichromic acid registration review:

Anticipated Schedule

Activities Estimated Month/Year
Phase 1: Opening the docket
Open Public Comment Period for Dichromic Acid Docket June 2010

Close Public Comment Period August 2010
Phase 2: Case Development

Develop Final Work Plan (FWP) December 2010

Issue DCI December 2011

Data Submission December 2015
Open Public Comment Period for Preliminary Risk Assessments June 2016

Close Public Comment Period September 2016

Phase 3: Registration Review Decision
Open Public Comment Period for Propos ed Reg. Review Decision December 2016

Close Public Comment Period March 2017 Final Decision and Begin Post-Decision Follow-up 2017 Total (years) 7

9 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

Guidance for Respondents:

The public is invited to co mment on EPA’s preliminary registration review work plan and rationale. The Agency will caref ully consider all comments as well as any

additional information or data provided in a timely manner pr ior to issuing a final work plan for the dichromic acid registration review case.

Trade Irritants

Through the registration review process, th e Agency intends to solicit information on trade irritants and, to the extent feasible , take steps toward facilitating irritant

resolution. Growers and other stakeholders are asked to comment on any trade irritant issues resulting from lack of Maximum Residue Limits (MRL s) or disparities between U.S. tolerances and MRLs in key export ma rkets, providing as much specificity as possible regarding the nature of the concern.

Water Quality

Dichromic acid is not identified as a cause of impairment for any water bodies listed as impaired under sect ion 303(d) of the Clean Water Act, based on information provided at http://iaspub.epa.gov/tmdl_waters10/attain s_nation_cy.cause_detail_303d? p_cause_grou p_id=885 . In addition, no Total Maximum Daily Loads (TMDL) have been developed for dichromic acid, based on information provided at http://iaspub.epa.gov/tmdl_waters10/attain s_nation.tm dl_pollutant _detail?p_pollutant_gr oup_id=885&p_pollutant_group_name=PESTICIDES . More information on impaired

water bodies and TMDLs can be found at http://www.epa.gov/owow/tmdl/ . The Agency invites submission of water quality data for this pesticide. To the extent possible, data should conform to the quality standards in Appendix A of the OPP Standard Operating Procedure: Inclusion of Im paired Water Body and Other Water Quality Data in OPP’s Registration Review Risk A ssessment and Management Process (see: http://www.epa.gov/oppsrrd1/regist ration_review/water_quality_sop.htm ) in order to ensure they can be used quantitatively or qualitatively in pesticide risk assessments.

Environmental Justice

EPA seeks to achieve environmental justi ce, the fair treatment and meaningful involvement of all people, regardless of race, color, national origin, or income, in the development, implementation, and enforcemen t of environmental laws, regulations, and policies. To help address potential environmental justice issues, the Agency seeks information on any groups or segments of the population who, as a result of their location, cultural practices, or other factor s, may have atypical, unusually high exposure to dichromic acid compared to the general population. Please comment if you are aware of any sub-populations that may have atypical , unusually high exposure compared to the general population.

10 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

Structure Activity Relationships

EPA must rely upon information of appropr iate quality and reliability for each decision made by the Agency. In the Office of Pesticide Programs (OPP), the evaluation process for a pesticide chemical traditionally begins with the appli cant’s submission of a

set of studies conducted with th e specific pesticide chemical of interest. The use of the results of such testing (measured data) is a logical, scientifically rigorous process that identifies the physical, chemical, and environmen tal fate properties of the pesticide, as well as the dose and endpoints at which an adverse effect can occur in various animal species.

Today, there is significant interest in a lternative techniques, i.e., techniques other than data generation that could significan tly inform the Agency’s decision-making process. Recently, OPP has made increasing use of structure activity relationship (SAR) as part of its regulatory d ecision-making process. In the SAR process, a chemical's molecular structure is compared to that of other chemicals fo r which data are available.

These structural similarities are then us ed to make predictive judgments about a chemical’s physical, chemical, and biological properties. Thus, the chemical’s physical, chemical, and biological propertie s are a function of (o r directly related to) the chemical’s molecular structure. Quantitative SAR is re ferred to as QSAR. To develop a QSAR, a selected set of measured data on a single phys ical, chemical, or bi ological property is used to derive a model (an equation) to predict the valu e of that property.

Since SAR assessments and QSAR modeli ng are another set of tools that are available to Agency scientists, OPP has begun a process shift that envisions shifting from the current study-by-study appro ach to an approach in which the use of predicted data, generated using validated models, is cons idered along with information from open literature and studies specifi cally generated under Part 161 requirements. All relevant information would be considered as part of a weight-of-the-evidence evaluation.

At this time, EPA believes that for cert ain endpoints, especially physical/chemical and fate properties, that SAR and QSAR might be effectively utilized to fulfill these data requirements for many antimicrobial pesticide chemicals. When c onsidering biological properties, at this time, EPA believes that SAR and QSAR can be most effectively

utilized in the evaluation of ch emicals that exhibit lower toxi city for human health and/or ecotoxicity parameters. This is appropriate because the risk assessment for lower toxicity chemicals can be stream-lined, i.e., a screen ing-level assessment pr ocedure rather than multiple tiers of assessments with pr ogressively more data requirements.

If stakeholders believe that submission of predicted data can fulfill one of the data needs for dichromic acid, then the Agency i nvites submission of this information. The submitter would be expected to supply a rationa le describing the utility of the information and provide documentation on the scientif ic validity of the information. The determination that the predicted data fulfills the data requirement would be at the sole discretion of the Agency. Pre-submission c onsultation with the Agency is encouraged.

11 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

Endocrine Disruptor Screening Program

As required under FFDCA section 408(p) , EPA has developed the Endocrine Disruptor Screening Program (EDSP) to dete rmine whether certain substances (including pesticide active and other ingred ients) may have an effect in humans or wildlife similar to an effect produced by a “natur ally occurring estrogen, or othe r such endocrine effects as the Administrator may designate.” The ED SP employs a two-tiered approach to making the statutorily required determinations. Tier 1 consists of a battery of 11 screening assays to identify the potential of a chemical substa nce to interact with the estrogen, androgen, or thyroid (E, A, or T) hormonal systems. Chemicals that go through Tier 1 screening and are found to have the potential to inte ract with E, A, or T hormonal systems will proceed to the next stage of the EDSP wher e EPA will determine which, if any, of the Tier 2 tests are necessary based on the avai lable data. Tier 2 te sting is designed to identify any adverse endocrine related eff ects caused by the substance, and establish a dose-response relationship between th e dose and the E, A, or T effect.

Between October 2009 and February 2010, EPA issued test orders/data call-ins for the first group of 67 chemicals, which c ontains 58 pesticide ac tive ingredients and 9 inert ingredients. This list of chemicals was selected based on the potential for human exposure through pathways such as food and wa ter, residential activity, and certain postapplication agricultural s cenarios. This list should not be construed as a list of known or likely endocrine disruptors.

Dichromic acid is not among the group of 58 pesticide active ingredients on the

initial list to be screened under the EDSP. Under FFDCA sec. 408(p) the Agency must screen all pesticide chemicals. Accordingl y, EPA anticipates issuing future EDSP test orders/data call-ins for all pesticide active ingredients.

For further information on the status of the EDSP, the policies and procedures, the list of 67 chemicals, the test guidelines and the Tier 1 screening battery, please visit our website: http://www.epa.gov/endo/.

Additional Information

Stakeholders are also specifically asked to provide available information and data that will assist the Agency in refining the risk assessments. The Agency is interested in receiving the following information:

1. Confirmation on the following label information:

a. Sites of application

b. Formulations

c. Application methods and equipment

d. Maximum application rates

e. Frequency of application, app lication intervals and maximum number of applications

f. Geographic limitations on use

12 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

2. Use or potential use distribution

3. Use history

4. Usage/use information for non-agricultural uses (e.g., materials preservation)

5. Typical application interval

6. State or local use restrictions

7. Ecological incidents (non-target plant damage and avian, fish, reptilian, amphibian and mammalian mo rtalities) not already reported to the Agency

8. Monitoring data

9. Structure Activity Relationships

Next Steps:

After the 60-day comment period closes, the Agency will review and respond to any comments received in a timely manner, and then issue a Final Work Plan for

dichromic acid.

13 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

II. FACT SHEET

Background Information

 Chemical Name: Dichromic Acid

 Common Names: Dichromic Acid, Di sodium Salt, Dihydrate; Sodium

Bichromate

 Registration review case number: 5012

 PC Code: 068306

 CAS#: 7789-12-0

 Technical Registrant: Elementis Chromium, LP

 First approved for use in a registered product: 1994

 Two active registrations: one manufactur ing use product and one end use product.

 Antimicrobials Division Chemical Revi ew Manager (CRM): Rebecca von dem Hagen, Vondem-Hagen.Rebecca@epa.gov

 Antimicrobials Division Product Mana ger (PM): Jacqueline CampbellMcFarlane, campbell-mcfarlane.jacqueline@epa.gov

Chemical Structure:

Use & Usage Information

 Type of Pesticide: Fungicide, Insecticide, M iticide and Molluscicide

 Antimicrobial Use Sites:

o Formulation intermediate in the pr oduction of CCA wood preservatives.

Use sites of CCA-treated wood include:

 Commercial and institutional uses in indoor and outdoor sites

 Limited residential uses includi ng shakes/shingles and permanent

wood foundations

Recent Regulatory Actions

Updated labels received in response to the 2008 chromated arsenicals RED were approved by the Agency in May 2010. Th e updated labels reflect the mitigation

measures outlined in the 2008 RED. The chromated arsenicals RED can be viewed at http://www.regulations.gov in docket number EPA-HQ-OPP-2003-0250

14 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

Human Health Risk Assessment Status

EPA confirmed that the data that wi ll be required for dichromic acid upon the issuance of the chromated arsenicals RED DCI are still needed and the Agency does not anticipate needing to require any other human health data for dichromic acid through the registration review program.

For further information see the document titled, “Summary of Human Health Effects Data for the Dichromic Acid Regi stration Review Decision Document,” dated May 27, 2010.

Environmental Fate & Ecologi cal Risk Assessment Status

The Agency reviewed the environmental fate and ecological hazard databases for dichromic acid. As a result of this review, EPA confirmed that the data to be required for dichromic acid upon the issuance of the chroma ted arsenicals RED DCI are still needed and the Agency does not anticipate the need to require any other en vironmental fate and ecological risk studies for dichromic acid th rough the registration review program.

For further information see the docum ent titled, “Dichromic Acid: Product Chemistry/Environmental Fate and Eco-Ef fects Scoping Document” dated May 6, 2010.

Tolerances

There are currently no tolerances or exemp tions for the requirement of a tolerance

for dichromic acid.

Data Call-In Status

In addition to the data call-in (DCI) sche duled to be issued through the chromated arsenicals RED in FY 2011, the Agency anticipa tes the need to require additional data to complete a risk assessment during the registration review of this case.

Labels

There are 2 registered products that contain dichromic acid. The EPA Registration Numbers are provide d in Tables 1 below. For future reference, during registration review a list of product registration numbers will be included in the docket. Product registration labels may be obtained from the Pesticide Product Label System (PPLS) website at: http://oaspub.epa.gov/pestlabl/ppls.home

.

15 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

Table 1. Registered Active Antimicro bial Products of Dichromic Acid

Registration # Registration Name Company Name Formulation Type % of Active Ingredient

75449-1 Sodium Bichromate Liquid Elementis

Chromium Formulation

Intermediate 69.0%

75449-3 Sodium Bichromate

Solution Elementis

Chromium Soluble

Concentrate 69.0%

16 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

III. GLOSSARY of TERMS & ABBREVIATIONS

ai Active Ingredient AR Anticipated Residue ASTM American Society for Testing and Materials

AWPA American Wood Preserver’s Association CFR Code of Federal Regulations cPAD Chronic Population Adjusted Dose

CSF Confidential Statement of Formula CSFII USDA Continuing Surveys for Food Intake by Individuals

DCI Data Call-In DEEM Dietary Exposure Evaluation Model DFR Dislodgeable Foliar Residue DNT Developmental Neurotoxicity DWLOC Drinking Water Level of Comparison

EC Emulsifiable Concentrate Formulation EDWC Estimated Drinking Water Concentration

EEC Estimated Environmental Concentration EPA Environmental Protection Agency

EUP End-Use Product FDA Food and Drug Administration FIFRA Federal Insecticide, Fungicide, and Rodenticide Act FFDCA Federal Food, Drug, and Cosmetic Act FQPA Food Quality Protection Act FOB Functional Observation Battery GENEEC Tier I Surface Water Computer Model

IR Index Reservoir

LC 50 Median Lethal Concentration. A statistically derived concentration of a substance that can be expected to cause death in 50% of test animals. It is usually expressed as the weight of substance per weight or volume of water, air or feed, e.g., mg/l, mg/kg or ppm.

LD 50 Median Lethal Dose. A statistically deri ved single dose that can be expected to

cause death in 50% of the test animals when administered by the route indicated (oral, dermal, inhalation). It is expressed as a weight of substance per unit weight of animal, e.g., mg/kg.

LOC Level of Concern

LOAEL Lowest Observed Adverse Effect Level μg/g Micrograms Per Gram μg/L Micrograms Per Liter mg/kg/day Milligram Per Kilogram Per Day mg/L Milligrams Per Liter MOE Margin of Exposure

MRID Master Record Identifi cation (number). EPA's system of recording and tracking

submitted studies. MUP Manufacturing-Use Product

NA Not Applicable NAWQA USGS National Ambient Water Quality Assessment NPDES National Pollutant Discharge Elimination System

NR Not Required

NOAEL No Observed Adverse Effect Level

OPP EPA Office of Pesticide Programs OPPTS EPA Office of Prevention, Pesticides and Toxic Substances PAD Population Adjusted Dose PAIRA Pure Active Ingredient Radiolabelled PCA Percent Crop Area

PDP USDA Pesticide Data Program

17 of 19Docket Number: EPA-HQ-OPP-2010-0243 www.regulations.gov

18 of 19 PHED Pesticide Handler's Exposure Data

PHI Preharvest Interval ppb Parts Per Billion PPE Personal Protective Equipment ppm Parts Per Million PRZM/EXAMS Tier II Surface Water Computer Model Q 1 * The Carcinogenic Potential of a Compound, Quantified by the EPA's Cancer

Risk Model RAC Raw Agriculture Commodity RED Reregistration Eligibility Decision

REI Restricted Entry Interval

RfD Reference Dose RQ Risk Quotient SCI-GROW Tier I Ground Water Computer Model

SAP Science Advisory Panel SF Safety Factor

SLN Special Local Need (Registrati ons Under Section 24©) of FIFRA) TGAI Technical Grade Active Ingredient

TEP Typical End-Use Product USDA United States Department of Agriculture UF Uncertainty Factor

WPS Worker Protection StandardDocket Number: EPA-HQ-OPP-2010-0243www.regulations.govIV. APPENDIX AUse Patterns for DICHROMIC ACIDUse SiteFormulationMethod ofApplicationApplication Rate/ No. ofapplicationsUse LimitationsWood PreservativesProduction of woodpreservative pesticideformulationsFormulationIntermediate75449-1PourProduct is for manufacturing useonly for the production of pesticideformulations for use as woodpreservatives to control fungi,insects and mites.Wood preservativeLumber, timber, post,poles and pilesSolubleConcentrate75449-3PourCCA Type C Instructions:For a 1.5% working solution to onethousand gallons of water, add 32gallons of 25% copper sulfatesolution. Add 10 gallons of SodiumDichromate Solution 69%. The finalcomponent to be added is 4.9gallons of arsenic acid 75%.CCA Type A Instructions:For a 1.5% working solution 10 onethousand gallons of water, add 30gallons of 25% copper sulfatesolution. Add 13 gallons of SodiumDichromate Solution 69%. The finalcomponent to be added is 2.6gallons of arsenic acid 75%.19 of 19