UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Date: September 20, 2015 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

Subject: Pronamide (Propyzamide). Occupational and Residential Exposure Assessment 

for the Registration Review Draft Risk Assessment and to Support the Section 3 

Proposed Use on Leaf Lettuce. 

PC Code: 101701 

Decision No.: 494935 

Petition No.: NA 

Risk Assessment Type: NA 

TXR No.: NA 

MRID No.: 4495250 I 

From: Seyed Tadayon, emist __/___£~ Risk 

Health 

Assessment 

Effects Division 

Branch(7509P) ~ 

Office of Pesticide Programs 

DP Barcode: 0422661 

Registra tion No.: NA 

Regulatory Action: Registration Review 

Case No.: 0082 

CAS No.: 23950-58-5 

40 CFR: 180.317 

Cassi L. Walls, ExpoSAC Reviewer · J. ' .\~ ~ £i ;_r Nancy Keller, ExpoSAC Reviewer (!j{? :/!:r-o.- Exposure Science Advisory Committee (Expo SAC) 7 HED 

THROUGH: Michael S. Metzger, Branch Chief μ D n .P- Risk Assessment Branches V and VII 1/(tM 

Health Effects Division (7509P) 

Office of Pesticide Programs 

TO: Ray Kent, Senior Risk Assessor 

Immediate Office (TO) 

Health Effects Division (7509P) 

Office of Pesticide Programs 

Page 1 of 35 
Page 2 of 35

Introduction

This assessment has been conducted for the purpose of addressing two separate regulatory 

actions: (1) Sections 3 for leaf lettuce, and (2) assessment of all currently registered uses to 

support the Draft Risk Assessment (DRA) for Registration Review. The Registration Division 

(RD) requested that HED conduct an exposure and risk assessment for a proposed use of 

pronamide on leaf lettuce. In addition, as part of Registration Review, the Pesticide Reevaluation Division (PRD) of OPP has requested that HED evaluate the hazard and exposure 

data and conduct occupational and residential exposure assessments, as needed, to estimate the 

risk to human health that will result from the currently registered uses of pesticides. This 

memorandum serves as HED’s Registration Review risk assessment of the occupational and 

residential handler and post-application exposures and risks from the current registered uses of 

pronamide. 

It is HED policy to use the best available data to assess exposure. Several sources of generic 

data were used in this assessment as surrogate data in the absence of chemical-specific data, 

including Pesticide Handlers Exposure Database Version 1.1 (PHED 1.1); the Agricultural 

Handler Exposure Task Force (AHETF) database; the Outdoor Residential Exposure Task Force 

(ORETF) dataset, and the Residential SOPs (Lawns/Turf). Some of these data are proprietary, 

and subject to the data protection provisions of the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA).

Note: This memorandum was reviewed by the Exposure Science Advisory Committee 

(ExpoSAC) on 07/09/2015.
Page 3 of 35

Table of Contents

1.0 Executive Summary............................................................................................................. 4

2.0 Risk Assessment Conclusions and Recommendations........................................................ 6

2.1 Summary of Risk Estimates............................................................................................. 6

2.2 Label Recommendations.................................................................................................. 6

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

3.0 Hazard Characterization....................................................................................................... 7

4.0 Exposure and Use Profile..................................................................................................... 9

5.0 Residential Exposure and Risk Estimates.......................................................................... 11

5.2 Residential Post-application Exposure/Risk Estimates.................................................. 11

5.3 Residential Risk Estimates for Use in Aggregate Assessment ...................................... 13

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

5.5 Residential Bystander Post-Application Inhalation Exposure ....................................... 14

6.0 Occupational Exposure and Risk Estimates ...................................................................... 14

6.1 Occupational Handler Exposure/Risk Estimates............................................................ 14

6.2 Occupational Post-application Exposure/Risk Estimates .............................................. 21

6.2.1 Occupational Post-application Inhalation Exposure/Risk Estimates...................... 21

6.2.2 Occupational Post-application Dermal Exposure/Risk Estimates.......................... 21

Appendix A. Summary of Occupational and Residential Non-cancer Algorithms..................... 25
Page 4 of 35

1.0 Executive Summary

Pronamide, also called propyzamide, [3,5-dichloro-N-(1,1-dimethyl-2-propynyl)benzamide] is a 

selective, systemic, pre-and post-emergence herbicide registered for the control of grasses and 

broadleaf weeds in several food and feed crops, as well as, woody ornamentals, Christmas trees, 

grasses grown for seed or turf (sod), golf course turf, recreational area turf, and fallow land. It is 

a soil active systemic herbicide with uptake by susceptible weeds occurring through the roots.

This document assesses exposures and risk estimates from the proposed section 3 on leaf lettuce

and also registered uses of pronamide. 

Exposure and Use Profile

Pronamide may be applied using ground (Chemigation and groundboom) spray equipments, soil 

incorporation, or aircraft. There are two end-use product labels registered with pronamide as the 

active ingredient (ai). These include liquid (EPA REG # 62719-578) and wettable powder

marketed in Water Soluble Package (WSP) formulations (EPA REG # 62719-397). The labeled 

use sites include various agricultural crops, Christmas tree farms, golf courses, seedling 

nurseries, landscape ornamentals, non-crop use sites (such as railroad, highway, roadside, 

pipeline and utility rights-of-way, and industrial areas), residential/commercial turf, and sod 

farms. The application rates range from 0.5 to 4 lb ai/A (0.012 lb ai/1000 ft2to 0.092 lb ai/1000 

ft2 or 0.025 to 0.2 lb ai/gal). 

The proposed section 3 use on leaf lettuce is an addition to liquid formulation product (EPA 

REG # 62719-578) for a soil-directed application via aerial, chemigation and groundboom 

equipment. The maximum rate is 1.0 lb ai/A and two broadcast applications can be made per 

year. The restricted entry interval (REI) for the registered uses and the proposed use is 24 hours. 

Hazard Profile

Pronamide has adverse liver effects including increases in liver weight, liver-related serum 

enzymes, and/or histopathology. In the immunotoxicity study with pronamide in mice, there was 

no evidence of immunotoxicity nor significant systemic toxicity. Pronamide is classified as “Not 

Likely to be Carcinogenic to Humans” at doses that do not result in induction of hepatic cell 

proliferation or metabolic enzymes leading to disruption of thyroid or gonadal endocrine axes

(CARC report 101701.004 CA.DOC; J. Rowland, 12/02/2014).

The level of concern (LOC) for occupational and non-occupational dermal risk estimates is for 

margins of exposure (MOEs) less than 100, inhalation and incidental oral risk estimates is for 

margins of exposure (MOEs) less than 1000. Pronamide is characterized as "not likely" to be a 

human carcinogen based on the negative carcinogenicity bioassays and negative mutagenicity 

studies. 

Residential Exposure and Risk

Residential handler exposures are not expected as pronamide is a Restricted Use Pesticide and as 

such can only be applied by Certified Applicator. The proposed use on leaf lettuce will not result 

in residential exposure; however, there are currently registered turf uses (e.g., residential turf, 

golf courses) that need to be reassessed to reflect updates to HED’s 2012 Residential SOPs. 
Page 5 of 35

All dermal and incidental oral risk estimates for post-application exposure are not of concern 

(i.e., dermal MOEs ≥ 100); all MOEs ≥ 200 for adults and ≥ 2,000 for children. 

A quantitative spray drift assessment for pronamide is not required because the maximum 

application rate for a crop/target site multiplied by the adjustment factor for drift of 0.26 is less 

than the maximum direct spray residential turf application rate (1.5 lb ai/A)1for any pronamide

product. Therefore, the turf post-application MOEs are protective for any potential exposures 

related to spray drift for pronamide.

Occupational Exposure and Risk

The most recent exposure assessment for pronamide was conducted in 2007 (D329436, M. Dow, 

05/05/2007). At the maximum rate of 4 lb ai/A identified for most agricultural crops, including 

the proposed use on leaf lettuce, there were no occupational handler risks of concern. 

The occupational handler exposure and risk estimates indicate that the short- and intermediateterm dermal and inhalation MOEs are not of concern to HED (i.e., MOEs > 100 for dermal and 

MOEs > 1000 for inhalation) from the wettable powder formulation in Water Soluble Package 

(WSP). For the liquid formulation, the short- and intermediate-term dermal and inhalation 

MOEs are not of concern to HED (i.e., MOEs > 100 for dermal and MOEs > 1000 for

inhalation), as long as label recommended PPE of double layer clothing and gloves are worn 

during mixing/loading of liquid formulation for aerial application to high-acreage crops (corn, 

soybeans and wheat).

Occupational post-application dermal exposure and risk estimates were assessed for the 

registered uses that are not soil-directed (e.g., turf), and resulted in MOEs greater than the LOC 

of 100 (ranging from 100 to 2,600) on day 1 (24 hours after application); and, therefore, are not 

of concern to HED.

The REI specified on registered and the proposed label is based on a short- and intermediateterm risk estimates for post-application scenarios of pronamide. Pronamide technical has a low 

order of acute toxicity via the oral, dermal, and inhalation routes of exposure (Toxicity Category 

III or IV), produces mild irritation to the eyes and skin (Toxicity Category IV), and is not a 

dermal sensitizer. Under 40 CFR 156.307 (c) (2) (iii), ai’s classified as Acute III or IV for acute 

dermal, eye irritation and primary skin irrigation are assigned a 12-hour REI. However, based on 

a quantitative post-application assessment, an REI of 24 hours is required to protect workers 

from exposures to pronamide 

Based on the Agency's current practices, a quantitative non-cancer occupational post-application 

inhalation exposure assessment was not performed for pronamide at this time. If new policies or 

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

post-application inhalation exposure assessment for pronamide.

Human Studies Review

 

1 4 lb ai/A x 0.26 ≤ 1.04 lb ai/A
Page 6 of 35

This risk assessment relies in part on data from studies in which adult human subjects were 

intentionally exposed to a pesticide or other chemical. These data, which include studies from 

the PHED 1.1, the AHETF database, and the ARTF database are (1) subject to ethics review 

pursuant to 40 CFR 26, (2) have received that review, and (3) are compliant with applicable 

ethics requirements. For certain studies, the ethics review may have included review by the 

Human Studies Review Board. Descriptions of data sources, as well as guidance on their use, 

can be found at the Agency website2. 

2.0 Risk Assessment Conclusions and Recommendations

2.1 Summary of Risk Estimates

There are no occupational or residential risk estimates of concern for the registered and proposed 

use of pronamide (exception is for handset irrigation of lettuce and ornamentals) 

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

intermediate-term dermal and inhalation MOEs are not of concern to HED (i.e., MOEs >

100 for dermal and MOEs > 1000 for inhalation) from the wettable powder formulation 

in Water Soluble Package (WSP). For the liquid formulation, the short- and 

intermediate-term dermal and inhalation MOEs are not of concern to HED i.e., MOEs >

100 for dermal and MOEs > 1000 for inhalation), as long as label recommended PPE of 

double layer clothing and gloves are worn during mixing/loading of liquid formulation 

for aerial application to high-acreage crops (corn, soybeans and wheat).

 Occupational post-application dermal exposure and risk estimates were assessed for the 

uses that are not soil-directed (e.g., turf), and are > 100 on the day of application, ranging 

from 100 to 2,600. For handset irrigation of lettuce and ornamentals, a one day REI is 

required (i.e., MOEs > 100). 

 All residential post-application risk estimates are not of concern (i.e., Dermal MOEs ≥ 

100); all MOEs ≥ 200 for adults and ≥ 100 for children.

2.2 Label Recommendations 

The current PPE on registered uses and the purposed use are coveralls over short-sleeved shirt and 

short pants, waterproof gloves, chemical-resistant footwear plus socks, are adequate and no extra PPE is 

required. 

2.3 Data Deficiencies and Requirements

Dislodgeable Foliar Residue (DFR): Since the highest estimated occupational post-application 

exposure using default DFR values for pronamide is equal in comparison to the level of concern 

(i.e., the calculated MOE is not greater than 2 times higher than the level of concern, MOE = 100

compared to the LOC of 100); EPA is requiring the 40CFR DFR data requirement. 

 

2 http://www.epa.gov/pesticides/science/handler-exposure-data.html and 

http://www.epa.gov/pesticides/science/post-app-exposure-data.html
Page 7 of 35

3.0 Hazard Characterization

Pronamide has adverse liver effects including increases in liver weight, liver-related serum 

enzymes, and/or histopathology. In the immunotoxicity study with pronamide in mice, there was 

no evidence of immunotoxicity nor significant systemic toxicity. Pronamide is classified as “Not 

Likely to be Carcinogenic to Humans” at doses that do not result in induction of hepatic cell 

proliferation or metabolic enzymes leading to disruption of thyroid or gonadal endocrine axes

(CARC report 101701.004 CA.DOC; J. Rowland, 12/02/2014).

The levels of concern (LOC) for occupational and non-occupational dermal is 100, and for

inhalation and incidental oral risk estimates is for margins of exposure (MOEs) less than 1000. 

Pronamide is characterized as "not likely" to be a human carcinogen based on the negative 

carcinogenicity bioassays and negative mutagenicity studies. 

Pronamide is classified as acute toxicity category IV for acute oral, and category III for acute 

dermal, and acute inhalation toxicity. It is classified as toxicity category IV for eye irritation 

potential and skin irritation potential. It is not a dermal sensitizer. Table 3.1 presents a summary 

of the acute toxicity information for pronamide

Table 3.1. Acute Toxicity Profile of Pronamide

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

870.1100 Acute oral [Rat] 00085505 LD50 > 5000 mg/kg IV

870.1100 Acute oral [Rat] 43583901 LD50 > 5000 mg/kg IV

870.1200 Acute dermal [Rabbit] 43583902 LD50 > 2000 mg/kg III

870.1300 Acute inhalation [Rat] 44034201 LC50 > 2.1 mg/L III

870.2400 Acute eye irritation [Rabbit] 43583904 Non-Irritating IV

870.2500 Acute dermal irritation [Rabbit] 43583903 Non-Irritating IV

870.2600 Skin sensitization [Guinea Pig] 00062605 Negative Non-Sensitizing

Dermal (Short and Intermediate-Term) Endpoints for Occupational and Non-Occupational 

Exposure Scenarios: The dermal endpoint was selected from a 28-day dermal toxicity study in 

rats. The point of departure (POD) was a NOAEL of 100 mg/kg/day. The LOAEL was 500 

mg/kg/day based on decreases in body weight and food consumption in males. No target organ 

(liver) toxicity was seen following repeated dermal dosing. This is considered a conservative 

endpoint since the animals could have tolerated a higher dose. The endpoint is appropriate for 

the route and duration of exposure as well as the population of concern.

Incidental Oral (short and intermediate term), and Inhalation Endpoint (short and intermediate 

term):

The LOAEL of 40 mg/kg/day based on motor activity and foot splay was selected for assessing 

risk from chronic dietary and non-dietary (short/ intermediate term incidental oral and inhalation) 

exposures. A chronic RfD of 0.04 mg/kg/day is derived using the LOAEL of 40 mg/kg/day from 

the ACN study and a 1000X Uncertainty Factor which includes 10X for inter-species 

extrapolation, 10X for intra-species variation and a 10X for the use of a LOAEL (UFL).
Page 8 of 35

In accordance with the Agency’s 2005 Guideline for Carcinogen Risk Assessment, pronamide is 

classified as “Not Likely to be Carcinogenic to Humans” at doses that do not result in 

induction of hepatic cell proliferation or metabolic enzymes leading to disruption of thyroid or 

gonadal endocrine axes (CARC J. Rowland, 12/02/2014).

The toxicity endpoints and the PODs for various exposure scenarios are described below and 

presented in Table 3.2.

Table 3.2. Summary of Toxicological Doses and Endpoints for Pronamide/Propyzamide for Non-Occupational and 

occupational Human Health Risk Assessments

Exposure/ 

Scenario

Point of 

Departure 

(POD)

Uncertainty/ 

FQPA Safety 

Factors

RfD, PAD, Level 

of Concern for 

Risk Assessment

Study and Toxicological Effects

Incidental Oral 

Short-Term (1-30 

days)

LOAEL = 40

mg/kg/day

UFA=10X

UFH=10X

UFL= 10X

FQPA SF=10X

Based on UFL

Residential and 

Occupational LOC 

for MOE = 1000

The POD of 40 mg/kg/day was selected based on a 

weight of evidence approach using the results from the 

3 studies listed below.

Subchronic neurotoxicity (SCN): NOAEL of 2.38 

mg/kg/day is based on the significant decreases in body 

weight, body weight gain, and food consumption seen 

at 11.28 mg/kg/day (LOAEL) in males.

Acute neurotoxicity (ACN): NOAEL was not 

established. The LOAEL of 40 mg/kg/day with a 10X 

LOAEL to NOAEL uncertainty factor (UFL) yields 

a derived POD of 4 mg/kg/day (40÷10).

Combined chronic toxicity/ carcinogenicity NOAEL

of 8.46/10.69 mg/kg/day is based on increased relative 

liver weight and histopathological lesions in the liver, 

thyroid, and ovaries at 42.59/55.09 mg/kg/day 

(LOAEL).

Dermal ShortTerm (1-30 days) 

and IntermediateTerm (1-6 months)

NOAEL=

100 mg/kg/day

FQPA SF=1x Residential and 

Occupational LOC 

for MOE = 100 

(includes UFA=10x 

and UFH=10x)

28-day dermal toxicity study in rat: LOAEL = 500 

mg/kg/day based on decreases in body weight and food 

consumption in males. No target organ (liver) toxicity 

was seen following repeated dermal dosing

Inhalation ShortTerm (1-30 days) 

and IntermediateTerm (1-6 months)

LOAEL = 

40 mg/kg/day

UFA=10X

UFH=10X

UFL= 10X

FQPA SF=10X

Based on UFL

Residential and 

Occupational LOC 

for MOE = 1000

The POD of 40 mg/kg/day was selected based on a 

weight of evidence approach using the results from the 

3 studies listed below.

Subchronic neurotoxicity (SCN): NOAEL of 2.38 

mg/kg/day is based on the significant decreases in body 

weight, body weight gain, and food consumption seen 

at 11.28 mg/kg/day (LOAEL) in males.

Acute neurotoxicity (ACN): NOAEL was not 

established. The LOAEL of 40 mg/kg/day with a 10X 

LOAEL to NOAEL uncertainty factor (UFL) yields 

a derived POD of 4 mg/kg/day (40÷10).

Combined chronic toxicity/ carcinogenicity NOAEL

of 8.46/10.69 mg/kg/day is based on increased relative 

liver weight and histopathological lesions in the liver, 

thyroid, and ovaries at 42.59/55.09 mg/kg/day 

(LOAEL).

Cancer (oral, 

dermal, 

inhalation)

Classification: “Not Likely to be Carcinogenic to Humans” at doses that do not result in induction of 

hepatic cell proliferation or metabolic enzymes leading to disruption of thyroid or gonadal endocrine axes.
Page 9 of 35

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

mark the beginning of extrapolation to determine risk associated with lower environmentally relevant human exposures. NOAEL 

= no observed adverse effect level. LOAEL = lowest observed adverse effect level. UF = uncertainty factor. UFA = 

extrapolation from animal to human (interspecies). UFH = potential variation in sensitivity among members of the human 

population (intraspecies). UFL = use of a LOAEL to extrapolate a NOAEL. UFS = use of a short-term study for long-term risk 

assessment. UFDB = to account for the absence of key data (i.e., lack of a critical study). FQPA SF = FQPA Safety Factor. PAD 

= population adjusted dose (a = acute, c = chronic). RfD = reference dose. MOE = margin of exposure. LOC = level of 

concern. N/A = not applicable.

The toxicology and exposure data bases for pronamide are complete and the toxicology studies 

are adequate for assessing increased susceptibility under FQPA. There was no evidence of 

quantitative or qualitative susceptibility in the developing organism and evidence for 

neurotoxicity was limited to effects seen following a single gavage dosing in the acute 

neurotoxicity study. For acute and chronic dietary and incidental oral and inhalation exposure 

assessments, the FQPA Safety Factor is retained in the form of a LOAEL to NOAEL (UFL) of 

10X. 

Absorption: Since the short- and intermediate-term dermal POD is based on dermal toxicity 

study, an absorption factor is not required for dermal assessment. For inhalation risk assessment 

absorption is assumed to be equivalent to the oral dose; an absorption factor was not used.

Body Weight: The dermal, inhalation, or incidental oral PODs are not based on developmental 

and/or fetal effects, therefore the body weight appropriate for these assessments is 80 kg.

4.0 Exposure and Use Profile 

There are two end-use products registered with pronamide as the active ingredient. These 

include liquid and wettable powder in Water Soluble Packages (WSP) formulations. The

registered use sites include various agricultural crops, Christmas tree farms, golf courses, 

seedling nurseries, landscape ornamentals, non-crop use sites (such as railroad, highway, 

roadside, pipeline and utility rights-of-way, and industrial areas), residential/commercial turf, 

and sod farms. Most of the uses are soil-directed, and are applied either via aerial, chemigation, 

groundboom, or handheld equipment. The application rates for all uses range from 0.5 to 4 lb 

ai/A. The REI for the registered uses is 24 hours. All of the pronamide registered labels require 

handlers to wear a double layer of clothing (long sleeved shirt and long pants) with either 

waterproof or chemical-resistant gloves. 

The proposed section 3 is an addition to liquid formulation product (EPA REG # 62719-578). 

The purposed use on leaf lettuce is for a soil-directed application via aerial, chemigation, and 

groundboom equipment. The single maximum application rate is 1.0 lb ai/A. Two broadcast 

applications can be made per year. The REI for the proposed use is 24 hours. 

Based on the proposed and registered use patterns, it has been determined that the potential 

exposure scenarios that will need to be assessed include short- and intermediate-term 

occupational (handler and post-application?) and residential exposures (handler and postapplication). A summary of the proposed use directions based on all registered and proposed 

labels are included in Table 4.1 below. 
Page 10 of 35

Table 4.1. Summary of Registered and Proposed Uses for Pronamide

Crop/Use Site Application Timing and Type of Application Registered 

Formulations

Maximum 

Application 

Rate

Personal Protective 

Equipment (PPE) and 

Restricted Entry Interval 

(REI)

Agricultural Fallow/Idleland

Agricultural Uncultivated Areas September/December/Broadcast Aerial L/WP(WSP) 0.5 24 hrs REI 

Alfalfa Spring/Fall/Winter/ Broadcast/ Aerial Chemigation/

Groundboom L/WP(WSP) 2 24 hrs REI 50 days PHI

Apple Fall/Postharvest direct spray L/WP(WSP) 4 24 hrs REI 

Apricot Fall/Postharvest direct spray L/WP(WSP) 4 24 hrs REI

Artichoke Ratoon/ Broadcast/Aerial Chemigation/ Groundboom L/WP(WSP) 4 24 hrs REI 60 days PHI

Blackberry Fall/Winter/ Broadcast/ Chemigation/ Groundboom L/WP(WSP) 3 24 hrs REI 

Blueberry Fall/Winter/ Broadcast/ Chemigation/ Groundboom, L/WP(WSP) 3 24 hrs REI 

Boysenberry Fall/Winter/ Broadcast/ Chemigation/ Groundboom L/WP(WSP) 3 24 hrs REI 

Cherry Fall/Postharvest direct spray L/WP(WSP) 4 24 hrs REI

Christmas Tree Plantations Early winter/Fall/ direct spray/Aerial L/WP(WSP) 4 24 hrs REI 365 days PHI

Clover Fall/Winter/ Broadcast/Chemigation/ Groundboom L/WP(WSP) 2 24 hrs REI 120 days PHI

Commercial/Industrial Lawns Spring/Broadcast/Aerial/Chemigation/ Groundboom L 1.44 24 hrs REI

Crown Vetch Fall/Winter/ Broadcast/Chemigation/ Groundboom L/WP(WSP) 2 24 hrs REI 120 days PHI

Endive Postplant/Broadcast/Aerial /Chemigation/ Groundboom L/WP(WSP) 2 24 hrs REI 55 days PHI

Golf Course Turf Spring/Broadcast/Aerial/Chemigation/ Groundboom L/WP(WSP) 1.44 24 hrs REI

Grapes Fall/Postharvest direct spray L/WP(WSP) 4 24 hrs REI

Grasses Grown For Seed Fall/Preemergence/Early Winter WP(WSP) 0.375 24 hrs REI

Leafy Greens Postemergence/ Chemigation/ Groundboom L 224 hrs REI 55 days PHI WP(WSP) 1.5

Lettuce Postplant/Broadcast/Aerial / Chemigation/ Groundboom L/WP(WSP) 2 24 hrs REI 55 days PHI

Leaf Lettuce (Section 3)

Postplant/Broadcast/Aerial / Chemigation/ Groundboom/

Hand held sprayer L 1 24 hrs REI 45 days PHI

Nectarine Fall/Postharvest direct spray L/WP(WSP) 4 24 hrs REI

Ornamental And/or Shade Trees Fall/ direct spray/ Hand held sprayer L/WP(WSP) 2 24 hrs REI

Ornamental Grasses Broadcast/Aerial/ Chemigation/ Groundboom/Hand held 

sprayer

WP(WSP) 1.5 24 hrs REI

Ornamental Herbaceous Plants Fall/ direct spray/ Hand held sprayer L/WP(WSP) 2 24 hrs REI

Ornamental Lawns And Turf Spring/Broadcast/Aerial/Chemigation/ Groundboom/ 

Hand held sprayer L/WP(WSP) 1.44 24 hrs REI

Ornamental Nonflowering Plants Fall/ direct spray/ Hand held sprayer L/WP(WSP) 2 24 hrs REI

Ornamental Sod Farm (Turf) Spring/Broadcast/Aerial/Chemigation/ Groundboom /

Hand held sprayer L 1.44 24 hrs REI

Ornamental Woody Shrubs And 

Vines Fall/ direct spray/ Hand held sprayer L/WP(WSP) 2 24 hrs REI

Peach Fall/Postharvest direct spray L/WP(WSP) 4 24 hrs REI 

Pear Fall/Postharvest direct spray L/WP(WSP) 4 24 hrs REI 

Peas Broadcast/Early winter/ Chemigation/ Groundboom L/WP(WSP) 1.5 24 hrs REI

Plum Fall/Postharvest direct spray L/WP(WSP) 4 24 hrs REI 

Prune Fall/Postharvest direct spray L/WP(WSP) 4 24 hrs REI 

Raspberry (Black - Red) Fall/Winter/ Broadcast/ Chemigation/ Groundboom L/WP(WSP) 3 24 hrs REI 

Rhubarb Fall/Broadcast/ Chemigation/ Groundboom L/WP(WSP) 2 24 hrs REI 38 days PHI

Sainfoin Fall/Winter/ Broadcast/Chemigation/Groundboom L/WP(WSP) 2 24 hrs REI 120 days PHI

Sugar Beet Fall/Winter/ Broadcast/Chemigation/ Groundboom L/WP(WSP) 1 24 hrs REI 

Trefoil Fall/Winter/ Broadcast/ Chemigation/ Groundboom L/WP(WSP) 2 24 hrs REI 120 days PHI

PPE

Applicators and other handlers must wear:

• Coveralls over short-sleeved shirt and short pants

• Waterproof gloves

• Chemical-resistant footwear plus socks
Page 11 of 35

• Chemical-resistant headgear for overhead exposure

• Chemical-resistant apron when cleaning equipment, mixing or loading

L/WP in in Water Soluble Package (WSP)= Liquid(35.6% active ingredient, 3.3 Lb ai/gal, EPA Reg # 62719-578)/Wettable 

Powder in water soluble package)(50% active ingredient, EPA Reg # 62719-397)

5.0 Residential Exposure and Risk Estimates

The proposed use on leaf lettuce is not expected to result in residential exposure. In this 

assessment pronamide is assessed for residential uses on turf grass using the 2012 Residential 

SOPs, and covers all of the scenarios necessary for the new Section 3 and Registration Review. 

Residential handler and post-application scenarios were assessed at a maximum application rate 

of 1.44 lb ai/A for liquid and 1.5 lb ai/A for wettable powder in Water Soluble Package (WSP)

formulations. There were no residential risk estimates of concern identified.

5.1 Residential Handler Exposure/Risk Estimates

Residential handler exposures are not expected as pronamide is a Restricted Use Pesticide and as 

such can only be applied by Certified Applicator. There are sufficient data available to perform a 

residential assessment.

5.2 Residential Post-application Exposure/Risk Estimates

There is the potential for post-application exposure for individuals exposed as a result of being in 

an environment that has been previously treated with pronamide The quantitative exposure/risk 

assessment for residential post-application exposures is based on the following scenarios: 

 Physical activities on turf: adults (dermal) and children 1 to < 2 years old (dermal and 

incidental oral);

 Mowing: adults (dermal) and children 11 to < 16 years old (dermal); and

 Golfing: adults (dermal), children 11 to < 16 years old (dermal), and children 6 to< 11 

years old (dermal).

The lifestages selected for each post-application scenario are based on an analysis provided as an 

Appendix in the 2012 Residential SOPs3. While not the only lifestage potentially exposed for 

these post-application scenarios, the lifestage that is included in the quantitative assessment is 

health protective for the exposures and risk estimates for any other potentially exposed lifestage.

Residential Post-application Exposure Data and Assumptions

A series of assumptions and exposure factors served as the basis for completing the residential 

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

SOPs3.

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

 

3 Available: http://www.epa.gov/pesticides/science/residential-exposure-sop.html
Page 12 of 35

Exposure Duration: Residential post-application exposure is expected to be short-term in 

duration. While multiple applications may be possible, it is anticipated that these applications 

will be intermittent in nature and dissipation due to rainfall/irrigation, grass growth, and grass 

mowing is expected. There is the potential for intermediate-term exposure to pronamide in the

however, since the maximum yearly application rate is the same as the maximum single 

application rate, the short-term assessment is protective of intermediate-term soil ingestion 

exposure. 

TTR Data:

MRID NO.-44952501 Turf Transferrable Residues for Pronamide Applied to Turf 

Turf transferable residues (TTR) were monitored using the Modified California Roller sampling 

methodology for the typical end-use product (EPA Reg. No. 707-159), a wettable powder 

formulation containing 50 % active ingredient (ai). The product was applied at one 

geographically representative site in North Carolina (NC) with three replicated subplots. A 

single application by ground sprayer was applied prior to monitoring. The product was applied 

once at the label specified maximum application rate of 1.5 lb ai/A. Three replicate samples 

were collected at intervals from 0 to 14 days after treatment (DAT). The residue values from site 

one in California was used in this assessment. The summary of statistic for TTR data are 

presented below in Table 6.2.2.2.

Table 6.2.2.2. Summary of Pronamide TTR Residues and Regression Analysis Results for Turf

Turf TTR (liquid) MRID # 44952501

Statistic Pronamide WP Formulation

Application Rate (lb ai/A) 1.5

Measured Average Day 0 Residue (μg/cm2) 0.252

Predicted Day 0 Residue (μg/cm2) 0.148

Slope -0.363

Half-Life (days) 2

R

2 0.88

Residential Post-application Non-Cancer Exposure and Risk Equations

The algorithms used to estimate residential post-application exposure and dose can be found in 

Appendix A and/or the 2012 Residential SOPs3.

Combining Exposure and Risk Estimates

The incidental oral scenarios (i.e., hand-to-mouth and object-to-mouth) should be considered 

inter-related and it is likely that they occur interspersed amongst each other across time. 

Combining these scenarios would be overly-conservative because of the conservative nature of 

each individual assessment. Therefore, these scenarios have not been combined.

Summary of Residential Post-application Non-Cancer Exposure and Risk Estimates

Table 5.2.1 provides a summary of the residential post-application exposures and risk estimates 

for pronamide. All dermal and incidental oral risk estimates for post-application exposure are 

not of concern (for dermal MOEs ≥ 100) and (for incidental oral MOEs ≥1,000); all MOEs ≥ 200

for adults and ≥ 2,000 for children. 
Page 13 of 35

Table 5.2.1. Short-Term Residential Post-application Exposure and Risk Estimates for Pronamide

Lifestage Post-application Exposure Scenario Dose (mg/kg/day)1 MOEs2 Combined 

MOEs

Liquid formulation and wettable powder(WSP)**

Adult

Turf

Liquid 

formulation

1.5 lb ai/A

Dermal

Physical Activities on Turf 0.50 200

N/A

Mowing 0.01 9,800

Golfing 0.039 2,500

Child 11 to < 16 

years old Dermal Mowing 0.012 8,600

Golfing 0.046 2,200

Child 6 to < 11 

years old Dermal Golfing 0.054 1,900

Child 1 to < 2 

year old

Dermal Physical Activities on Turf 0.99 100

Hand to Mouth 0.020 2,000

Object to Mouth 0.00062 65,000

Short- and Intermediate-term Incidental Soil 

Ingestion 0.000051 790,000

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

2 MOE = POD (Dermal = 100 mg/kg/day and Incidental oral = 40 mg/kg/day) ÷ Dose (mg/kg/day). LOC = 100 for dermal and 1,000 

for Incidental oral.

5.3 Residential Risk Estimates for Use in Aggregate Assessment

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

assessment for pronamide

 The recommended residential exposure for use in the adult short-term aggregate 

assessment reflects dermal exposure from applications to turf via backpack sprayer.

 The recommended residential exposure for use in the children 1 to <2 years old shortterm aggregate assessment reflects dermal exposure from post-application exposure to 

turf applications.

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

Lifestage Exposure Scenario

Dose (mg/kg/day)1 MOE2

Dermal Inhalation 3 Oral Dermal Inhalation 3 Oral

Short-term

Child 11 to < 16 years old

Post-application exposure 

from golfing (liquid 

formulation) 

0.046 NA NA 2,200 NA NA

Child 6 to < 11 years old

Post-application exposure 

from golfing (liquid 

formulation) 

0.054 NA NA 1,900 NA NA

Child to 1 < 2 year old

Post-application exposure 

from activities on turf (liquid 

formulation) 

0.99 NA 0.020 100 NA 2,000

1 Dose = the highest dose for each applicable lifestage of all residential scenarios assessed. 

2 MOE = the MOEs associated with the highest residential doses. 

3 Inhalation risk estimates were not combined with dermal or oral risk estimates in this assessment since the toxicological effects in the 

inhalation toxicological study were different from those seen in the dermal and oral toxicological studies.

5.4 Spray Drift

Off-target movement of pesticides can occur via many types of pathways and it is governed by a 

variety of factors. Sprays that are released and do not deposit in the application area end up offtarget and can lead to exposures to those it may directly contact. They can also deposit on 

surfaces where contact with residues can eventually lead to exposures (e.g., children playing on 
Page 14 of 35

lawns where residues have deposited next to treated fields). The potential risk estimates from 

these residues can be calculated using drift modeling coupled with methods employed for 

residential risk assessments for turf products.

The approach to be used for quantitatively incorporating spray drift into risk assessment include 

assessing exposures for children (1 to <2 years old) and adults who have contact with turf where 

residues are assumed to have deposited via spray drift thus resulting in an exposure scenario. 

Aside from the predicted residues available for transfer, the routes of exposure and assessment 

methodology is analogous to how exposures to turf products are considered in risk assessment. 

Several pronamide products have existing labels for use on turf, thus it was considered whether 

the risk assessment for turf may be considered protective of any type of exposure resulting from 

spray drift. If the maximum application rate on crops adjusted by the amount of drift expected is 

less than or equal to existing turf application rates, the existing turf assessment is considered 

protective of spray drift exposure. The proposed maximum single application rate of pronamide

for several registered agricultural crops is 4 lb ai/A. The highest fraction of spray drift noted for 

any application method immediately adjacent to a treated field results in a deposition fraction of 

0.264of the application rate. A quantitative spray drift assessment for pronamide is not required 

because the maximum application rate for a crop/target site multiplied by the adjustment factor 

for drift of 0.26 is less than the maximum direct spray residential turf application rate (4 lb ai/A)5

for any pronamide products. The turf post-application MOEs are protective for any potential 

exposures related to spray drift for pronamide and have previously been discussed in Section 5.2. 

5.5 Residential Bystander Post-Application Inhalation Exposure

Volatilization of pesticides may be a source of post-application inhalation exposure to 

individuals nearby pesticide applications. The agency sought expert advice and input on issues 

related to volatilization of pesticides from its Federal Insecticide, Fungicide, and Rodenticide Act 

Scientific Advisory Panel (SAP) in December 2009, and received the SAP’s final report on 

March 2, 2010 (http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html). The 

agency has evaluated the SAP report and has developed a Volatilization Screening Tool and a 

subsequent Volatilization Screening Analysis

(http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html). 

During Registration Review, the agency will utilize this analysis to determine if data (i.e., flux 

studies, route-specific inhalation toxicological studies) or further analysis is required for

Pronamide.

6.0 Occupational Exposure and Risk Estimates

6.1 Occupational Handler Exposure/Risk Estimates

HED uses the term handlers to describe those individuals who are involved in the pesticide 

application process. HED believes that there are distinct job functions or tasks related to 

applications and exposures can vary depending on the specifics of each task. Job requirements 

 

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

5 4.0 lb ai/A x 0.26 ≤ 4.0 lb ai/A
Page 15 of 35

(amount of chemical used in each application), the kinds of equipment used, the target being 

treated, and the level of protection used by a handler can cause exposure levels to differ in a 

manner specific to each application event. 

Based on a review of registered pronamide labels, uses on Christmas tree farms and landscape 

ornamentals were identified which are not covered by the previous assessment. These use 

patterns have been assessed in this document to complete the Registration Review for pronamide 

Updated risk estimate tables have also been included for occupational handlers for all registered 

uses since the inhalation point of departure and LOC for pronamide have been changed since the 

previous assessment. 

The quantitative exposure/risk assessment developed for occupational handlers is based on the 

following scenarios which covers all the registered and proposed uses of pronamide: 

 Mixing/loading liquids to support aerial applications,

 Mixing/loading liquids to support chemigation applications,

 Mixing/loading liquids to support groundboom applications, 

 Mixing/loading wettable powder in Water Soluble Package (WSP) to support aerial 

applications,

 Mixing/loading wettable powder in Water Soluble Package (WSP) to support 

chemigation applications,

 Mixing/loading wettable powder in Water Soluble Package (WSP) to support 

groundboom applications,

 Mixing/loading wettable powder in Water Soluble Package (WSP) for groundboom 

applications,

 Applying sprays with aircraft,

 Applying sprays with groundboom equipment,

 Mixing/loading/applying wettable powder in Water Soluble Package (WSP) or liquids 

via backpack,

 Mixing/loading/applying wettable powder in Water Soluble Package (WSP) or liquids 

via mechanically-pressurized handgun,

 Mixing/loading/applying wettable powder in Water Soluble Package (WSP), or liquids 

via manually-pressurized handwand,

Occupational Handler Exposure Data and Assumptions

A series of assumptions and exposure factors served as the basis for completing the occupational 

handler risk assessments. Each assumption and factor is detailed below on an individual basis.

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

similar crop/application method scenarios, the highest application rate was assessed assuming 

this would be protective of lower application rates. 

Unit Exposures: It is the policy of HED to use the best available data to assess handler exposure. 

Sources of generic handler data, used as surrogate data in the absence of chemical-specific data, 

include PHED 1.1, the AHETF database, the Outdoor Residential Exposure Task Force 

(ORETF) database, or other registrant-submitted occupational exposure studies. Some of these 
Page 16 of 35

data are proprietary (e.g., AHETF data), and subject to the data protection provisions of FIFRA. 

The standard values recommended for use in predicting handler exposure that are used in this 

assessment, known as “unit exposures”, are outlined in the “Occupational Pesticide Handler Unit 

Exposure Surrogate Reference Table6”, which, along with additional information on HED policy 

on use of surrogate data, including descriptions of the various sources, can be found at the 

Agency website7. 

Area Treated or Amount Handled: The inputs for area treated were mostly based on information 

in Expo SAC Policy 9.1. 1200 acres for aerial application to high acreage crops

 350 acres for aerial application to typical acreage crops

 60 acres for aerial and groundboom applications to nurseries

 200 acres for ground application to high acreage crops

 80 acres for ground application to typical acreage crops

 80 acres for ground application to sod farms

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

 350 acres for chemigation applications

 350 acres for flaggers

 5 acres or 40 gallons for backpack and manually-pressurized handwand applications

 5 acres or 1000 gallons for mechanically-pressurized handgun

 

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

days to six months as intermediate-term. Exposure duration is determined by many things, 

including the exposed population, the use site, the pest pressure triggering the use of the 

pesticide, and the cultural practices surrounding that use site. For most agricultural uses, it is 

reasonable to believe that occupational handlers will not apply the same chemical every day for 

more than a one-month time frame; however, there may be a large agribusiness and/or 

commercial applicators who may apply a product over a period of weeks. 

For the proposed use pattern, short- and intermediate-term exposures are anticipated for the 

following reasons: (1) up to two applications can be made 60 days apart; and (2) commercial 

applicators may apply this product at various locations within a region over a period of weeks. 

The same exposure durations are anticipated for all registered pronamide uses, and it should be 

noted that the short- and intermediate-term PODs are the same; therefore, short-term risk 

estimates are protective of longer-term exposures.

Mitigation/Personal Protective Equipment: Estimates of dermal and inhalation exposure were 

calculated for various levels of personal protective equipment (PPE). Results are presented for 

“baseline,” defined as a single layer of clothing consisting of a long sleeved shirt, long pants, 

shoes plus socks, no protective gloves, and no respirator, as well as baseline with various levels 

of PPE as necessary (e.g., gloves, respirator, etc). All of the pronamide registered labels require 

handlers to wear a double layer of clothing (long sleeved shirt and long pants) with either 

waterproof or chemical-resistant gloves.

 

6 Available: http://www.epa.gov/opp00001/science/handler-exposure-table.pdf

7 Available: http://www.epa.gov/pesticides/science/handler-exposure-data.html
Page 17 of 35

Occupational Handler Non-Cancer Exposure and Risk Estimate Equations

The algorithms used to estimate non-cancer exposure and dose for occupational handlers can be 

found in Appendix A.

Combining Exposures/Risk Estimates

Dermal and inhalation risk estimates were not combined in this assessment, since the 

toxicological effects for these exposure routes were not the same.

Summary of Occupational Handler Non-Cancer Exposure and Risk Estimates

The occupational handler exposure and risk estimates indicate that the short- and intermediateterm dermal and inhalation MOEs are not of concern to HED (i.e., MOEs > 100 for dermal and 

MOEs > 1000 for inhalation), as long as double layer and gloves are worn for the highest 

application rate for mixing/loading liquids for aerial application to high-acreage crops and 

wettable powder used in Water Soluble Packages (WSP).

HED has no data to assess exposures to pilots using open cockpits. The only data available is for 

exposure to pilots in enclosed cockpits. Therefore, risks to pilots are assessed using the 

engineering control (enclosed cockpits) and baseline attire (long-sleeve shirt, long pants, shoes, 

and socks); per the Agency’s Worker Protection Standard stipulations for engineering controls, 

pilots are not required to wear protective gloves for the duration of the application. With this 

level of protection, there are no risk estimates of concern for applicators.

The Agency matches quantitative occupational exposure assessment with appropriate 

characterization of exposure potential. While HED presents quantitative risk estimates for human 

flaggers where appropriate, agricultural aviation has changed dramatically over the past two 

decades. According the 2012 National Agricultural Aviation Association (NAAA) survey of 

their membership, the use of GPS for swath guidance in agricultural aviation has grown steadily 

from the mid 1990’s. Over the same time period, the use of human flaggers for aerial pesticide 

applications has decreased steadily from ~15% in the late 1990’s to only 1% in the most recent 

(2012) NAAA survey. The Agency will continue to monitor all available information sources to 

best assess and characterize the exposure potential for human flaggers in agricultural aerial 

applications.
Page 18 of 35

Table 6.1.1. Occupational Handler Non-Cancer Exposure and Risk Estimates for Pronamide

Exposure Scenario Crop or Target

Dermal Unit 

Exposure 

(μg/lb ai)1

Inhalation 

Unit Exposure 

(μg/lb ai)1

Maximum 

Application 

Rate (lb 

ai/A)2

Area 

Treated 

(acres)3

Dermal

(LOC = 100)

Inhalation

(LOC = 1000)

Mitigation Level = baseline 

unless indicated otherwise

Dose 

(mg/kg/day)4 MOE5 Dose (mg/kg/day)6 MOE7

Mixer/Loader

Aerial application of 

Wettable powder in 

Water Soluble Package

(WSP)

Nursery (ornamentals, vegetables, trees, container stock) 8.6

(Engineering

Control)

0.083

(Engineering

Control )

1.5 60 0.011 9,100 0.00027 150,000

Sod 1.5 350 0.0644 1,600 0.00158 25,000

Field crop, typical acreage8and Orchard 4 0.171 580 0.0042 9,500

Field crop, high-acreage9 2 1200 0.294 340 0.0072 5,600

Chemigation 

application of Wettable 

powder in Water 

Soluble Package

(WSP)

Sod 1.5

350

0.0644 1,600 0.00158 25,000

Field crop, typical acreage 8

and Orchard 4 0.171 580 0.0042 9,500

Field crop, high-acreage9 2 0.0585 1,200 0.0021 19,000

Nursery (ornamentals, vegetables, trees, container stock) 1.5 60 0.011 9,100 0.00027 150,000

Groundboom 

application of Wettable 

powder in Water 

Soluble Package

(WSP)

Golf course (fairways, tees, greens) 1.5 40 0.00735 14,000 0.00018 220,000 Field-grown ornamental crops

Nursery (ornamentals, vegetables, trees, container stock) 1.5 60 0.011 9,100 0.00027 150,000

Sod 1.5 80 0.0148 8,800 0.00036 110,000

Field crop, typical acreage8and Orchard 4 0.0393 2,500 0.00096 42,000

Field crop, high-acreage9 2 200 0.049 2,000 0.0012 33,000

Aerial application of 

liquid formulation

Nursery (ornamentals, vegetables, trees, container stock) 37.6

(Single 

layer/Glove)

0.219 2 60 0.0564 1,800 0.000329 120,000

Sod 1.44

350

0.238 420 0.00138 29,000

Field crop, typical acreage8and Orchard 4 0.658 150 0.00384 10,000

Field crop, high-acreage9 29.1 (DL/G) 0.219 2 1200 0.873 110 0.00658 6,100

Chemigation 

application of a liquid 

formulation

Nursery (ornamentals, vegetables, trees, container stock) 37.6

(Single 

layer/Glove)

0.219 2 60 0.0564 1,800 0.000329 120,000

Sod 1.44

350

0.238 420 0.00138 29,000

Field crop, typical acreage8and Orchard 4 0.658 150 0.00384 10,000

Field crop, high-acreage9 2 0.329 300 0.00768 20,000

Groundboom 

application of liquid 

formulation

Nursery (ornamentals, vegetables, trees, container stock) 2 60 0.0564 1,800 0.000329 120,000

Sod 1.44 80 0.0541 1,800 0.000315 130,000

Golf course (fairways, tees, greens) 40 0.0271 3,700 0.000158 250,000

Field crop, typical acreage8 4 80 0.15 670 0.000876 46,000

Field crop, high-acreage9 2 200 0.188 530 0.0011 36,000
Page 19 of 35

Table 6.1.1. Occupational Handler Non-Cancer Exposure and Risk Estimates for Pronamide

Exposure Scenario Crop or Target

Dermal Unit 

Exposure 

(μg/lb ai)1

Inhalation 

Unit Exposure 

(μg/lb ai)1

Maximum 

Application 

Rate (lb 

ai/A)2

Area 

Treated 

(acres)3

Dermal

(LOC = 100)

Inhalation

(LOC = 1000)

Mitigation Level = baseline 

unless indicated otherwise

Dose 

(mg/kg/day)4 MOE5 Dose (mg/kg/day)6 MOE7

Applicator

Aerial spray 

application

Nursery (ornamentals, vegetables, trees, container stock) 2.08

(Engineering

Control)

0.0049

(Engineering

Control)

2 60 0.00313 32,000 0.00000735 5,400,000

Sod 1.5 350 0.0136 7,400 0.0000321 1,200,000

Field crop, typical acreage8and orchard 4 0.0364 2,700 0.0000858 470,000

Field crop, high-acreage9 2 1200 0.0624 1,600 0.000148 270,000

Groundboom spray 

application

Golf course (fairways, tees, greens) 78.6 0.34 1.5 40 0.059 1,700 0.000255 160,000 Field-grown ornamental crops

Nursery (ornamentals, vegetables, trees, container stock) 2 60 0.118 850 0.00051 78,000

Sod 1.5 80 0.118 850 0.00051 78,000

Field crop, typical acreage8 and orchard 4 0.315 320 0.00136 29,000

Field crop, high-acreage9 2 200 0.393 250 0.0017 24,000

Flagger

Flagger for aerial spray 

application

Nursery (ornamentals, vegetables, trees, container stock) 11 0.35 2 60 0.0165 6,100 0.00525 76,000

Sod 1.5

350

0.0723 1,400 0.0023 17,000

Field crop, typical acreage8and orchard 4 0.193 520 0.00613 6,500

Field crop, typical and high-acreage9 2 0.0963 1,000 0.00306 13,000
Page 20 of 35

Table 6.1.1. Occupational Handler Non-Cancer Exposure and Risk Estimates for Pronamide

Exposure Scenario Crop or Target

Dermal Unit 

Exposure 

(μg/lb ai)1

Inhalation 

Unit Exposure 

(μg/lb ai)1

Maximum 

Application 

Rate (lb 

ai/A)2

Area 

Treated 

(acres)3

Dermal

(LOC = 100)

Inhalation

(LOC = 1000)

Mitigation Level = baseline 

unless indicated otherwise

Dose 

(mg/kg/day)4 MOE5 Dose (mg/kg/day)6 MOE7

Mixer/Loader/Applicator

Wettable powder in 

Water Soluble Package

(WSP) via Backpack

Orchard crops (ground soil directed) 8260 2.58 0.1 lb ai/gal

40 gallons

0.413 240 0.000129 310,000

Wettable powder in 

Water Soluble Package

(WSP) via Backpack

Landscaping, turf (lawns, athletic fields, parks, etc.) 8,260 2.58

0.075

0.31 320 0.0000968 410,000

Wettable powder in 

Water Soluble Package

(WSP)via ManuallyPressurized Handwand

Landscaping, turf (lawns, athletic fields, parks, etc.)

430

(Single 

layer/Glove)

30 0.0161 6,200 0.00113 35,000

Wettable powder in 

Water Soluble Package

(WSP) via 

Mechanicallypressurized Handgun

Golf course (fairways, tees, greens)

1350 18 1.5 5 0.126 790 0.00169 24,000 Landscaping, turf (lawns, athletic fields, parks, etc.)

Liquids via Backpack Orchard crops (ground soil directed) 8,260 2.58 0.2

40 gallons

0.826 120 0.000258 160,000

Nursery (ornamentals, vegetables, trees, container stock)

0.072

0.298 340 0.0000929 430,000

Liquids via Manuallypressurized Handwand Landscaping, turf (lawns, athletic fields, parks, etc.)

430

(Single 

layer/Glove)

30 0.0155 6,500 0.00108 37,000

Liquids via 

Mechanicallypressurized Handgun

Golf course (fairways, tees, greens) 1,140 1.9 1.44 5 0.103 970 0.000171 23,000 Landscaping, turf (lawns, athletic fields, parks, etc.)

Orchard crops (ground soil directed) 390

(Single 

layer/Glove)

3.9

0.2 1000 

gallons

0.971 100 0.00975 4,100

Nursery (ornamentals, vegetables, trees, container stock) 0.072 0.351 280 0.00351 110,000

1 Based on the “Occupational Pesticide Handler Unit Exposure Surrogate Reference Table” (March 2013); 

2 Based on registered and proposed labels.

3 Exposure Science Advisory Council Policy #9.1 and Registrant information.

4 Dermal Dose = Dermal Unit Exposure (μg/lb ai) × Conversion Factor (0.001 mg/μg) × Application Rate (lb ai/acre) × Area Treated (A/day) ÷ BW (80 kg).

5 Dermal MOE = Dermal NOAEL (100 mg/kg/day) ÷ Dermal Dose (mg/kg/day). LOC = 100

6 Inhalation Dose = Inhalation Unit Exposure (μg/lb ai) × Conversion Factor (0.001 mg/μg) × Application Rate (lb ai/acre) × Area Treated (A/day) ÷ BW (80 kg).

7 Inhalation MOE = Inhalation NOAEL (40 mg/kg/day) ÷ Inhalation Dose (mg/kg/day). LOC =1000

8 Field crops, typical acreage category covers the following crops: asparagus, Brassica, head and stem, Brassica, leafy greens, cabbage, berries, edamame, fallow cropping systems, flax, fruiting 

vegetables, okra, horseradish, lima beans, melons, rhubarb, strawberry, succulent peas, tobacco, turnips, Christmas tree farms, mint, peanuts, peppermint, spearmint, potato sugarcane, dry shelled peas 

and beans and sunflower @ a maximum of 2lb ai/A and for berries @ 3 lb ai/A 

9 Field crops, high acreage crops category covers the following crops: corn, soybeans and wheat @2 lb ai/A. 

10 Orchard crops, apples, apricot, artichoke, cherry, peach, pear, peach, pear, plum, nectarine, citrus fruits, tree nuts, grapes, Christmas tree plantations @4 lb ai/A
Page 21 of 35

6.2 Occupational Post-application Exposure/Risk Estimates

HED uses the term post-application to describe exposures that occur when individuals are 

present in an environment that has been previously treated with a pesticide (also referred to as reentry exposure). Such exposures may occur when workers enter previously treated areas to 

perform job functions, including activities related to crop production, such as scouting for pests 

or harvesting. Post-application exposure levels vary over time and depend on such things as the 

type of activity, the nature of the crop or target that was treated, the type of pesticide application, 

and the chemical’s degradation properties. In addition, the timing of pesticide applications, 

relative to harvest activities, can greatly reduce the potential for post-application exposure. The 

majority of pronamide usage occurs preemergence or when the plants are dormant. The only 

crop with post-application activities is lettuce.

6.2.1 Occupational Post-application Inhalation Exposure/Risk Estimates

There are multiple potential sources of post-application inhalation exposure to individuals 

performing post-application activities in previously treated fields. These potential sources 

include volatilization of pesticides and resuspension of dusts and/or particulates that contain 

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, and received the SAP’s final report on March 2, 2010 

(http://www.epa.gov/scipoly/SAP/meetings/2009/120109meeting.html). The agency has 

evaluated the SAP report and has developed a Volatilization Screening Tool and a subsequent 

Volatilization Screening Analysis (http://www.regulations.gov/#!docketDetail;D=EPA-HQOPP-2014-0219). During Registration Review, the agency will utilize this analysis to determine 

if data (i.e., flux studies, route-specific inhalation toxicological studies) or further analysis is 

required for pronamide.

In addition, the Agency is continuing to evaluate the available post-application inhalation 

exposure data generated by the Agricultural Reentry Task Force. Given these two efforts, the 

Agency will continue to identify the need for and, subsequently, the way to incorporate 

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

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

performed, an inhalation exposure assessment was performed for occupational/commercial 

handlers. Handler exposure resulting from application of pesticides outdoors is likely to result in 

higher exposure than post-application exposure. Therefore, it is expected that these handler 

inhalation exposure estimates would be protective of most occupational post-application 

inhalation exposure scenarios.

6.2.2 Occupational Post-application Dermal Exposure/Risk Estimates

Most of the registered uses (with exception of lettuce), for pronamide are soil-directed preplant 

or pre- emergent uses where no crop foliage is present. Currently, HED has no transfer 

coefficients or other data to assess post-application dermal exposures to soil by occupational 
Page 22 of 35

workers. In general, such exposures are considered to be negligible. Therefore, for the soildirected uses, post-application exposures and risks to occupational workers were not assessed. 

The registered and proposed uses lettuce, turf (golf courses and sod farms) and ornamentals are 

not specifically soil-directed and, therefore, could result in potential post-application exposures. 

These exposures have been assessed in this memo.

Occupational Post-application Dermal Exposure Data and Assumptions

A series of assumptions and exposure factors served as the basis for completing the occupational 

post-application risk assessments. Each assumption and factor is detailed below on an individual 

basis. 

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

days to six months as intermediate-term. For the proposed use pattern, short- and intermediateterm exposures are anticipated for the following reasons: (1) up to two applications can be made

60 days apart; and (2) commercial applicators may apply this product at various locations within 

a region over a period of weeks. The same exposure durations are anticipated for all registered 

pronamide uses, and it should be noted that the short- and intermediate-term PODs are the same; 

therefore, short-term risk estimates are protective of longer-term exposures.

Transfer Coefficients: It is the policy of HED to use the best available data to assess postapplication exposure. Sources of generic post-application data, used as surrogate data in the 

absence of chemical-specific data, are derived from ARTF exposure monitoring studies, and, as 

proprietary data, are subject to the data protection provisions of FIFRA. The standard values 

recommended for use in predicting post-application exposure that are used in this assessment, 

known as “transfer coefficients”, are presented in the ExpoSAC Policy 38” which, along with 

additional information about the ARTF data, can be found at the Agency website9. 

Table 6.2.2.1. Summary of Post-Application Activities and Dermal Transfer Coefficients.

Crop Policy Crop 

Group Category

Crop 

Height

Foliage 

Density

Transfer 

Coefficients 

(cm2/hr)

Activities

Landscape 

ornamentals 

(Container, Field 

grown Ornamental 

plantings)

Nursery Crop 

(Ornamentals, 

Non-bearing 

Plants)

Low Min

230

Grafting, Propagating, Transplanting

Low Full

Hand Harvesting, Hand Pruning, Scouting, Hand 

Weeding, Transplanting, Pinching, 

Tying/Training

High Min Hand Harvesting, Hand Pruning, Transplanting

High Full

Hand Harvesting, Hand Pruning, Scouting, 

Container Moving, Hand Weeding, 

Transplanting, Pinching

Low/High Full 1,900 Handset Irrigation

Golf Courses

Turf/Sod

Low Full 2,500 Maintenance, greens only

3,700 Maintenance

Sod Low Full 6,700 Maintenance, Slab Harvesting, 

Transplanting/Planting

Lettuce Low Full 1,900 Handset Irrigation

 

8 Available: http://www.epa.gov/pesticides/science/exposac_policy3.pdf

9 Available: http://www.epa.gov/pesticides/science/post-app-exposure-data.html
Page 23 of 35

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

Exposure Time: The average occupational workday is assumed to be 8 hours. 

Dislodgeable Foliar Residue (DFR): In accordance with the updated Part 158 data requirements 

(2007), one or more DFR studies are required when a pesticide has residential or occupational 

uses that could result in post-application dermal exposure. As part of the recent revision to the 

Health Effects Division’s 2012 Standard Operating Procedures for Residential Pesticide 

Exposure Assessment, HED analyzed a number of DFR studies and selected a new default value 

for the fraction of the application rate available to be dislodged after a foliar application (FAR). 

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

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

post-application assessments. Of the analyzed DFR studies, the maximum FAR value seen was 

89% or 3.6 times higher than the default residue transfer value. Therefore, the HED has decided 

that a calculated MOE of approximately 2 times higher than the LOC (e.g., an MOE > 200 if the 

LOC =100) using the default dislodged residue values would provide an adequate margin of 

safety for any potentially higher residues seen in a chemical-specific DFR study (Guidance for

Requiring/Waiving Turf Transferrable Residue (TTR) and Dislodgeable Foliar Residue (DFR) 

Studies. 12/12/2012, Exposure Science Advisory Council). 

Since the highest estimated occupational post-application exposure using default DFR values for 

pronamide is not minimal in comparison to the level of concern (i.e., the calculated MOE is not 

greater than 2 times higher than the level of concern, MOE = 100 on day 1 compared to the LOC 

of 100; EPA is requiring the 40CFR DFR data. Therefore, EPA is requiring the 40CFR DFR 

data requirement to facilitate any necessary exposure assessments refinements and to further 

EPA’s general understanding of the availability of dislodgeable foliar pesticide residues. 

Occupational Post-application Non-Cancer Dermal Exposure and Risk Estimate Equations

The algorithms used to estimate non-cancer exposure and dose for occupational post-application 

workers can be found in Appendix A.

Occupational Post-application Non-Cancer Dermal Risk Estimates

The short- and intermediate-term post-application exposure scenarios associated with the 

registered uses of pronamide are summarized in Table 6.2.2.2. All scenarios resulted in MOEs 

greater than the LOC of 100 (ranging from 100 to 2,600) on day 1 (24 hours after application);

and, therefore, are not of concern to HED.

Table 6.2.2.2. Occupational Post-application Non-Cancer Exposure and Risk Estimates for Pronamide

Crop/Site Activities

Transfer 

Coefficient 

(cm2/hr)

Application

Rate (lb ai/A)

DFR or

TTR 1

Dermal Dose

(mg/kg/day)2

MOE3

(LOC = 100)

Short- and Intermediate-term

Landscape 

ornamentals 

(Container, Field 

grown 

Ornamental 

plantings)

Hand Harvesting, Hand Pruning, 

Transplanting, Hand Harvesting, Hand 

Pruning, Scouting, Container Moving, 

Hand Weeding, Transplanting, 

Pinching

230 2 5.61 0.129 780

Handset Irrigation 1,900 1.066 94 (day0)
Page 24 of 35

Table 6.2.2.2. Occupational Post-application Non-Cancer Exposure and Risk Estimates for Pronamide

Crop/Site Activities

Transfer 

Coefficient 

(cm2/hr)

Application

Rate (lb ai/A)

DFR or

TTR 1

Dermal Dose

(mg/kg/day)2

MOE3

(LOC = 100)

Short- and Intermediate-term

5.05 0.959 100 (day1)

Golf Courses Maintenance, greens only 2,500

1.5 0.148

0.038 2600

Maintenance 3,700 0.055 1800

Sod Maintenance, Slab Harvesting, 

Transplanting/Planting 6,700 0.099 1,000

Lettuce Handset Irrigation 1900 2

5.61 1.066 94 (day0)

5.05 0.959 100 (day1)

1 DFR = Application Rate × F × (1-D)t × 4.54E8 μg/lb × 2.47E-8 acre/cm2; where F = 0.25 and D = 0.10 per day. 

TTR= obtained from pronamide TTR study MRID # 449525-01

2 Daily Dermal Dose = [DFR (μg/cm2) × Transfer Coefficient × 0.001 mg/μg × 8 hrs/day]  BW (80 kg).

3 MOE = POD (100 mg/kg/day) / Daily Dermal Dose. 

Restricted Entry Interval

The REI specified on registered and the proposed label is based on a short- and intermediateterm risk estimates for post-application scenarios of pronamide. Pronamide technical has a low 

order of acute toxicity via the oral, dermal, and inhalation routes of exposure (Toxicity Category 

III or IV), produces mild irritation to the eyes and skin (Toxicity Category IV), and is not a 

dermal sensitizer. Under 40 CFR 156.307 (c) (2) (iii), ai’s classified as Acute III or IV for acute 

dermal, eye irritation and primary skin irrigation are assigned a 12-hour REI. However, based on 

a quantitative post-application assessment, an REI of 24 hours is required to protect workers 

from exposures to pronamide 

 
Page 25 of 35

Appendix A. Summary of Occupational and Residential Non-cancer Algorithms

OCCUPATIONAL NON-CANCER HANDLER ALGORITHMS

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

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

where:

E = exposure (mg ai/day),

UE = unit exposure (μg ai/lb ai),

AR = maximum application rate according to proposed label (lb ai A or lb ai/gal), and

A = area treated or amount handled (e.g., A/day, gal/day).

The daily doses are calculated using the following formula:

ADD= 

E * AF

BW

where:

ADD = average daily dose absorbed in a given scenario (mg ai/kg/day),

E = exposure (mg ai/day),

AF = absorption factor (dermal and/or inhalation), and

BW = body weight (kg).

Margin of Exposure: Non-cancer risk estimates for each application handler scenario are 

calculated using a Margin of Exposure (MOE), which is a ratio of the toxicological endpoint to 

the daily dose of concern. The daily dermal and inhalation dose received by occupational 

handlers are compared to the appropriate POD (i.e., NOAEL) to assess the risk to occupational 

handlers for each exposure route. All MOE values are calculated using the following formula:

MOE= 

POD

ADD

where:

MOE = margin of exposure: value used by HED to represent risk estimates (unitless),

POD = point of departure (mg/kg/day), and

ADD = average daily dose absorbed in a given scenario (mg ai/kg/day).

OCCUPATIONAL NON-CANCER POST-APPLICATION ALGORITHMS
Page 26 of 35

Potential daily exposures for occupational post-application workers are calculated using the 

following formulas:

DFRt=AR * F* (1-D)t* (4.54E8

ug

lb) * (2.47E-8

A

cm2

)

where:

DFR = dislodgeable foliage residue on day "t" (μg/cm2),

AR = application rate (lb ai/acre),

F = fraction of ai retained on foliage or 25% (unitless),

D = fraction of residue that dissipates daily or 10% (unitless), and

t = number of days after application day (days).

E=TC * DFR t * ET * 0.001

mg

ug

where:

E = exposure (mg ai/day),

TC = transfer coefficient (cm2/hr),

DFR = dislodgeable foliar residue on day “t” (μg/cm2), and

ET = exposure time (hours/day).

The daily doses are calculated using the following formula:

ADD= 

E * AF

BW

where:

ADD = average daily dose absorbed in a given scenario (mg ai/kg/day),

E = exposure (mg ai/day),

AF = absorption factor (dermal and/or inhalation), and

BW = body weight (kg).

Margin of Exposure: Non-cancer risk estimates for each scenario are calculated using a Margin 

of Exposure (MOE), which is a ratio of the toxicological endpoint to the daily dose of concern. 

The daily dermal dose received by occupational post-application workers is compared to the 

appropriate POD (i.e., NOAEL) to assess the risk to occupational post-application workers. All 

MOE values are calculated using the following formula:

MOE= 

POD

ADD

where:
Page 27 of 35

MOE = margin of exposure: value used by HED to represent risk estimates (unitless),

POD = point of departure (mg/kg/day), and

ADD = average daily dose absorbed in a given scenario (mg ai/kg/day).

RESIDENTIAL NON-CANCER HANDLER ALGORITHMS

Dermal and Inhalation Handler Exposure Algorithm - Turf

Daily dermal and inhalation exposure (mg/day) for residential pesticide handlers, for a given 

formulation-application method combination, is estimated by multiplying the formulationapplication method-specific unit exposure by an estimate of the amount of active ingredient 

handled in a day, using the equation below:

E = UE * AR * A

where:

E = exposure (mg/day);

UE = unit exposure (mg/lb ai);

AR = application rate (e.g., lb ai/ft2, lb ai/gal); and

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

Dermal and/or inhalation absorbed doses normalized to body weight are calculated as:

D = E *AF / BW

where:

D = dose (mg/kg-day);

E = exposure (mg/day);

AF = absorption factor (dermal and/or inhalation); and

BW = body weight (kg).

RESIDENTIAL NON-CANCER POST-APPLICATION ALGORITHMS

Post-application Dermal Exposure Algorithm – Physical Activities on Turf

Exposure resulting from contacting previously treated turf while performing physical activities is 

calculated as shown below. Residential post-application exposure assessment must include 

calculation of exposure on the day of application. Therefore, though an assessment can present 

exposures for any day “t” following the application, it must include “day 0” exposure.

E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day);
Page 28 of 35

TTRt = turf transferable residue on day t (μg/cm2);

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

TC = transfer coefficient (cm2/hr); and

ET = exposure time (hr/day).

If chemical-specific TTR data are available, then surface residues from the day of application 

should be used (assume that individuals could be exposed to residues immediately after 

application). However, if data are not available, then TTRt can be calculated using the following 

formula:

TTRt= AR * F * (1-FD)t * CF2 * CF3

where:

TTRt = turf transferable residue on day t (μg/cm2);

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

F = fraction of ai as transferable residue following application (unitless);

FD = fraction of residue that dissipates daily (unitless);

t = post-application day on which exposure is being assessed;

CF2 = weight unit conversion factor (4.54 x 108 μg/lb); and

CF3 = area unit conversion factor (1.08 x 10-3ft2/ cm2or 2.47 x 10-8acre/cm2).

Dermal absorbed doses are calculated as:

BW

E AF D*



where:

D = dose (mg/kg-day);

E = exposure (mg/day);

AF = absorption factor (dermal); and

BW = body weight (kg).

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

Algorithm Notation Exposure Factor

(units) Point Estimate(s)

AR Application rate

(mass active ingredient per unit area) See table 4.1

F

Fraction of AR as TTR 

following application (if 

chemical-specific data is 

unavailable)

L/WP/WDG 0.01

Granules 0.002

FD

Daily residue dissipation (if 

chemical-specific data is 

unavailable)

(fraction)

L/WP/WDG 0.1

Granules 0.1

TC

Transfer 

Coefficient 

(cm2/hr)

L/WP/WDG

Adults 180,000

Children 1 < 2 years old 49,000

Granules Adults 200,000
Page 29 of 35

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

Algorithm Notation Exposure Factor

(units) Point Estimate(s)

Children 1 < 2 years old 54,000

ET Exposure Time

(hours per day)

Adults 1.5

Children 1 < 2 years old 1.5

BW Body Weight

(kg)

Adults 69

Children 1 < 2 years old 11

L/WP/WDG = Liquids/Wettable Powders/Water-dispersible Granules

Post-application Hand-to-Mouth Exposure Algorithm– Physical Activities on Turf

Exposure from hand-to-mouth activity is calculated as follows (based on the algorithm utilized in 

the SHEDS-Multimedia model):

E = [HR * (FM * SAH) * (ET * N_Replen) * (1- (1- SE)

(Freq_HtM/N-Replen))]

where:

E = exposure (mg/day);

HR = hand residue loading (mg/cm2);

FM = fraction hand surface area mouthed / event (fraction/event);

SAH = typical surface area of one hand (cm2);

ET = exposure time (hr/day);

N_Replen = number of replenishment intervals per hour (intervals/hour);

SE = saliva extraction factor (i.e., mouthing removal efficiency); and

Freq_HtM = number of hand-to-mouth contacts events per hour (events/hour).

and

SA * 2

Fai *DE

HR

H

hands



where:

HR = hand residue loading (mg/cm2);

Faihands = fraction ai on hands compared to total surface residue from dermal transfer coefficient 

study (unitless);

DE = dermal exposure (mg); and

SAH = typical surface area of one hand (cm2).

Dose, normalized to body weight, is calculated as:

BW

E

D 

where:

D = dose (mg/kg-day);
Page 30 of 35

E = exposure (mg/day); and

BW = body weight (kg).

Table A-X: Turf (Physical Activities) – Inputs for Residential Post-application Hand-to-Mouth Exposure 

Algorithm 

Notation

Exposure Factor

(units) Point Estimate(s)

Faihands

Fraction of ai on hands from 

dermal transfer coefficient 

study (unitless)

Liquid formulations 0.06

Granular formulations 0.027

DE Dermal exposure (mg) Calculated

SAH

Typical surface area of one hand (cm2), children 1 < 2 

years old 150

AR Application rate

(mass active ingredient per unit area) See table 4.1

HR Residue available on the hands (mg/cm2) Calculated via (DE * Faihands)/SAH

FM Fraction hand surface area mouthed (fraction/event) 0.127

N_Replen Replenishment intervals per hour (intervals/hr) 4

ET Exposure time (hrs/day) 1.5

SE Saliva extraction factor (unitless) 0.48

Freq_HtM Hand-to-mouth events per hour (events/hr) 13.9

BW Body Weight (kg) Children 1 < 2 years old 11

Post-application Object-to-Mouth Exposure Algorithm– Physical Activities on Turf

Exposure from object-to-mouth activity is calculated as follows (based on the algorithm utilized 

in SHEDS-Multimedia):

E = [OR* CF1 * SAMO * (ET * N_Replen) * (1- (1- SEO)

(Freq_OtM/N_Replen))]

where:

E = exposure (mg/day);

OR = chemical residue loading on the object on day “t” (ug/cm2);

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

SAMO = area of the object surface that is mouthed (cm2/event);

ET = exposure time (hr/day);

N_Replen = number of replenishment intervals per hour (intervals/hour);

SEO = saliva extraction factor (i.e., mouthing removal efficiency); and

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

and

OR = AR * FO * CF2 * CF3

where:

OR = chemical residue loading on the object (μg/cm2);

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

FO = fraction of residue available on the object (unitless);

CF2 = weight unit conversion factor (4.54 x 108 μg/lb); and
Page 31 of 35

CF3 = area unit conversion factor (1.08 x 10-3ft2/cm2or 2.47 x 10-8acre/cm2).

Dose, normalized to body weight, is calculated as:

BW

E

D 

where:

D = dose (mg/kg-day);

E = exposure (mg/day); and

BW = body weight (kg).

Table A-X: Turf (Physical Activities) – Inputs for Residential Post-application Object-to-Mouth Exposure 

Algorithm 

Notation

Exposure Factor

(units) Point Estimate(s)

AR Application rate (to turf)

(mass active ingredient per unit area) See table 4.1

FO Fraction of AR as OR following application 1 0.01

SAMO Surface area of object mouthed (cm2/event) 10

N_Replen Replenishment intervals per hour (intervals/hour) 4

SEO Saliva extraction factor(fraction) 0.48

ET Exposure time (hours per day) 1.5

Freq_OtM Object-to-mouth events per hour (events/hr) 8.8

BW Body Weight (kg) Children 1 < 2 years old 11

1 This SOP assumes that all of the residue on the turf could be transferred to the object (e.g., object residue is equal to turf 

transferable residue).

Post-application Incidental Soil Ingestion Exposure Algorithm– Physical Activities on Turf

Exposure from incidental soil ingestion is calculated as follows:

E = SRt * SIgR * CF1

where:

E = exposure (mg/day);

SRt = soil residue on day "t" (μg/g);

SIgR = ingestion rate of soil (mg/day); and

CF1 = weight unit conversion factor (1 x 10-6g/μg).

and

SRt = AR * FS * (1-FD)

t

* CF2 * CF3 * CF4

where:

SRt = soil residue on day "t" (μg/g);

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

FS = fraction of ai available in uppermost cm of soil (fraction/cm);

FD = fraction of residue that dissipates daily (unitless);
Page 32 of 35

T = post-application day on which exposure is being assessed;

CF2 = weight unit conversion factor (4.54 x 108 μg/lb);

CF3 = area unit conversion factor (1.08 x 10-3ft2/cm2 or 2.47 x 10-8acre/cm2); and

CF4 = soil volume to weight unit conversion factor (0.67 cm3/g soil).

Dose, normalized to body weight, are calculated as:

BW

E

D 

where:

D = dose (mg/kg-day);

E = exposure (mg/day); and

BW = body weight (kg).

Table A-X: Turf (Physical Activities) – Inputs for Residential Post-application Incidental Soil Ingestion Exposure 

Algorithm 

Notation

Exposure Factor

(units) Point Estimate(s)

AR Application rate (mass active ingredient per unit area) See table 4.1

FS Fraction of AR available in uppermost 1 cm of soil (unitless) 1

FD Daily residue dissipation (fraction) 0.1

SIgR Soil ingestion rate (mg/day) 50

BW Body weight (kg) Children 1 < 2 years old 11

Post-application Episodic Granular Ingestion Exposure Algorithm– Physical Activities on Turf

Exposure from incidental ingestion of pesticide pellets or granules is calculated as follows:

 E = GIgR* FD * CF1

where:

E = exposure (mg/day);

GIgR = ingestion rate of dry pesticide formulation (g/day);

FD = fraction of ai in dry formulation (unitless); and

CF1 = weight unit conversion factor (1,000 mg/g).

Dose, normalized to body weight, are calculated as:

BW

E

D 

where:

D = dose (mg/kg-day);

E = exposure (mg/day); and

BW = body weight (kg).

Table A-X: Turf (Physical Activities) – Inputs for Residential Post-application Episodic Granular Ingestion Exposure 

Algorithm 

Notation

Exposure Factor 

(units) Point Estimate(s)

FD Fraction of active ingredient in dry formulation See table 4.1
Page 33 of 35

Table A-X: Turf (Physical Activities) – Inputs for Residential Post-application Episodic Granular Ingestion Exposure 

AR Application rate (lbs/A or lbs/1,000 ft2) See table 4.1

GIgR Granule ingestion rate per day (g/day) 1 0.3

BW Body Weight (kg) Children 1 < 2 years old 11

1 See discussion below on how this value may be adjusted if product specific information is available.

Post-application Dermal Exposure Algorithm – Mowing

Exposure resulting from contacting previously treated turf while mowing is calculated as 

follows:

E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day);

TTRt = turf transferable residue on day "t" (μg/cm2);

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

TC = transfer coefficient (cm2/hr); and

ET = exposure time (hr/day).

and

TTRt = AR * FAR * (1-FD)

t

* CF2 * CF3

where:

TTRt = turf transferable residue on day "t" (μg/cm2);

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

FAR = fraction of ai retained on turf (unitless);

FD = fraction of residue that dissipates daily (unitless);

t = post-application day on which exposure is being assessed;

CF2= weight unit conversion factor (4.54 x 108 μg/lb); and

CF3 = area unit conversion factor (1.08 x 10-3ft2/cm2or 2.47 x 10-8acre/cm2).

Absorbed dose, normalized to body weight, are calculated as:

BW

E AF D*



where:

D = dose (mg/kg-day);

E = exposure (mg/day); 

AF = absorption factor (dermal); and

BW = body weight (kg).

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

Algorithm Notation Exposure Factor (units) Point Estimate(s)

AR Application rate mass active ingredient per unit area See table 4.1
Page 34 of 35

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

FAR

Fraction of AR as TTR following 

application

L/WP/WDG 0.01

Granules 0.002

FD Daily residue dissipation L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient (cm2/hr) Adult 5,500

Children 11 < 16 years old 4,500

ET Exposure time (hours per day) 1

BW Body Weight (kg) Adults 69

Children 11 < 16 years old 57

L/WP/WDG = liquid/wettable powder/water dispersible granule

Post-application Dermal Exposure Algorithm – Golfing

Exposure resulting from contacting previously treated turf while golfing is calculated as follows:

E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day); 

TTRt = turf transferable residue on day "t" (μg/cm2);

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

TC = transfer coefficient (cm2/hr); and

ET = exposure time (hr/day).

and

TTRt = AR * F * (1-FD)

t

* CF2 * CF3

where:

TTRt = turf transferable residue on day "t" (μg/cm2);

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

F = fraction of ai retained on turf (unitless);’

FD = fraction of residue that dissipates daily (unitless);

t = post-application day on which exposure is being assessed;

CF2 = weight unit conversion factor (4.54 x 108 μg/lb); and

CF3 = area unit conversion factor (1.08 x 10-3ft2/cm2or 2.47 x 10-8acre/cm2).

Absorbed dose, normalized to body weight, is calculated as:

BW

E AF D*



where:

D = dose (mg/kg-day);

E = exposure (mg/day); 

AF = absorption factor (dermal); and

BW = body weight (kg).
Page 35 of 35

Table A-X: Turf (Golfing) – Inputs for Residential Post-application Dermal Exposure 

Algorithm 

Notation

Exposure Factor

(units)

Point Estimate(s)

AR Application rate

(mass active ingredient per unit area)

See table 4.1

F Fraction of AR as TTR 

following application

L/WP/WDG 0.01

Granules 0.002

FD Daily residue dissipation L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient

(cm2/hr)

Adult 5,300

Children 11 < 16 years old 4,400

Children 6 < 11 years old 2,900

ET Exposure time

(hours per day)

Pesticides used on greens, tees, and 

fairways 

4

Pesticides used only on greens and 

tees

1

BW Body Weight

(kg)

Adults 69

Children 11 < 16 years old 57

Children 6 < 11 years old 32

NA = not applicable

L/WP/WDG = liquid/wettable powder/water dispersible granule