UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460

OFFICE OF 

PREVENTION, PESTICIDES AND 

TOXIC SUBSTANCES 

May 27, 2008 

MEMORANDUM

SUBJECT: Science and Ethics Review of AHETF Scenario Design and Protocol for 

Exposure Monitoring in Florida Citrus 

FROM: John M. Carley 

 Human Research Ethics Review Officer 

 Jeff Evans 

 Health Effects Division 

 Matthew Crowley 

 Health Effects Division 

TO: Jack Housenger, Associate Director 

 Health Effects Division 

REF: Smith, L. (2008) Determination of Dermal and Inhalation Exposure to 

Workers During Airblast Applications of Liquid Sprays Using Closed Cab 

Equipment in Florida Citrus. Unpublished protocol dated April 7, 2008, 

prepared for the Agricultural Handlers Exposure Task Force under 

Sponsor ID AHE55. 107 p., plus 674 p. supplement containing IRB 

correspondence. 

We have reviewed the referenced proposal from both scientific and ethics 

perspectives. Scientific aspects of the proposed research are assessed in terms of the 

recommendations of the EPA Guidelines Series 875 and of the EPA Human Studies 

Review Board. Ethical aspects of the proposed research are assessed in terms of the 

standards defined by 40 CFR 26 subparts K and L and the recommendations of the EPA 

Human Studies Review Board. 

Page 1 of 56 
A. Completeness and Contents of Protocol Submission 

The submitted protocol was reviewed for completeness against the required 

elements listed in 40 CFR §26.1125. All required elements are present. EPA’s checklist 

is appended to this review as Attachment 6. 

The scenario design for the closed-cab airblast scenario appears in Volume 1 of 

the AHETF submission of April 7, 2008 (V1:9-52)1. The IRB-approved protocol and 

supporting documents (consent forms, product-specific risk statements, and recruitment 

flyers in both English and Spanish) appears in Volume 2 of the AHETF submission. 

Documentation of all interactions between the investigators and the Independent 

Investigational Review Board, Inc., of Plantation FL appears in Volume 8 of the AHETF 

submission. Additional supporting materials relevant to this review also appear in the 

AHETF Governing Document (Volume 4), in the cited AHETF SOPs (Volume 6), and in 

the collection of referenced documents (Volume 7). 

In addition to the final protocol (V2:3-46) Volume 2 includes the following 

supporting documents: 

• Study documents in English approved by IIRB: 

o Informed Consent Form approved 3/25/08 (pp. 48-56) 

o Product-specific risk statements approved 3/25/08 (pp. 69-82) 

o Recruiting flyer approved 3/4/08 (p. 105) 

• Study documents in Spanish approved by IIRB: 

o Informed Consent Form approved 3/25/08 (pp. 57-67) 

o Product-specific risk statements approved 3/25/08 (pp.83-103) 

o Recruiting flyer approved 3/4/08 (pp. 106-107) 

Volume 8 of the AHETF submission documents interaction between the 

investigators and IIRB, Inc.: 

• Correspondence between the investigator and IIRB (pp. 4-10, 230, 274, 372-376, 

403, 438-445, 470, 540, 589-590, 652) 

• Protocol and supporting documents as initially submitted to IIRB on 2/28/08 

(pp. 11-229) 

• Revisions to protocol submitted to IIRB on 2/29/08 (pp. 231-273) 

• SOPs cited in protocol as submitted to IIRB on 2/29/08 (pp. 275-371) 

 

1 This convention will be used for all page number references in this review and its attachments. For 

example, “V1” refers to Volume 1 of the AHETF submission, which contains the “General Information and 

Scenario Sampling Plan” for the Closed-Cab Airblast scenario. “V2” indicates Volume 2 of the AHETF 

submission, and “V8” refers to Volume 8 of the AHETF submission. Many pages in all volumes bear more 

than one page number. All page references in this review to Volume 1 are to “page N of 52”, page 

references to Volume 2 are to “page N of 107”, page references to Volume 4 are to “page N of 153”, page 

references to Volume 6 are to “page N of 154”, page references to Volume 7 are to “page N of 54”, and 

page references to Volume 8 are to “page N of 674.” 

Page 2 of 56 
• IIRB approval letter of March 4, 2008 (pp. 375-376) 

• Minutes of 3/4/08 IIRB Meeting (pp. 377-378) 

• Track-changes version of English consent form and product-specific risk 

statements showing IIRB changes in 3/4/08 review (pp. 446-468) 

• Study documents in English approved by IIRB 3/4/08: 

o Informed Consent Form (pp. 379-387) 

o Product-specific risk statements (pp. 388-401) 

o Recruiting flyer (p. 402; identical to V2:105) 

• Spanish translations of study documents approved by IIRB on 3/4/08: 

o Informed Consent Form (pp. 406-416) 

o Product-specific risk statements (pp. 417-437) 

o Recruiting flyer (pp. 404-405; identical to V2:106-107) 

• Protocol revisions dated 3/21/08: Track changes (pp. 471-539) 

• Protocol revisions dated 3/24/08: Track changes (pp. 541-583) 

• Additional SOPs submitted to IIRB on 3/24/08 (pp. 584-587) 

• IIRB approval letter of March 25, 2008 (pp. 589-590) 

• Minutes of IIRB meeting of March 25, 2008 (pp. 647-650) 

• Study documents in English approved by IIRB on 3/25/08: 

o Informed Consent Form (pp. 605-613; identical to V2:48-56) 

o Product-specific risk statements (pp. 591-604; identical to V2:69-82) 

• Spanish translations of study documents approved by IIRB on 3/25/08: 

o Informed Consent Form (pp. 614-624; identical to V2:57-67) 

o Product-specific risk statements (pp. 625-647; identical to V2:83-103) 

• Additional SOPs transmitted to IIRB on 4/2/08 (pp. 653-674) 

The rationale for the proposed sample size and cluster configuration is presented in the 

AHETF Governing Document (V4:49-52) and its Appendix C (V4:127-153). 

The following SOPs are cited in the protocol, and can be found in Volume 6: 

AHETF-1.B.2 Personnel Responsibilities (V6:8) 

AHETF-1.F.0 Potential Referable Findings (V6:13) 

AHETF-2.C.2 Protocol Design and Preparation (V6:18) 

AHETF-6.B.1 Access to Archived Data (V6:31) 

AHETF-6.D.0 Access to Confidential Worker Info (V6:33) 

AHETF-8.A.3 Whole Body Sampling – Inner Dosimeters (V6:35) 

AHETF-8.B.4 Hand Wash Samples (V6:40) 

AHETF-8.C.4 Dermal Face/Neck Wipe Samples (V6:44) 

AHETF-8.D.2 Collection of Air Samples Using OVS Tubes (V6:47) 

AHETF-8.E.4 Fortification of Matrix Samples (V6:51) 

AHETF-8.F.4 Sample Identification (V6:60) 

AHETF-8.G.2 Worker Clothing Acceptability Criteria (V6:63) 

AHETF-8.K.0 Sample Quality (V6:74) 

AHETF-10.A.0 Rotameter Calibration (V6:100) 

AHETF-10.C.3 Worker and Study Observations (V6:102) 

AHETF-10.D.0 Application Equipment Operation Verification (V6:107) 

Page 3 of 56 
AHETF-10.E.2 Worker Sample Collection Sequence (V6:109) 

AHETF-10.G.1 Personal Air Sampling Pump Calibration (V6:111) 

AHETF-11.B.1 Recruitment of Study Volunteers and Informed Consent 

(V6:113) 

AHETF-11.D.0 Pregnancy Testing (V6:130) 

AHETF-11.F.0 Adverse Events Reporting for IRBs (V6:135) 

AHETF-11.G.0 Identification and Control of Heat Stress (V6:137) 

Reports of interviews with experts knowledgeable about the use of airblast application 

equipment are provided in Volume 7, pp. 4-31. Reports of interviews directly addressing 

agronomic and pesticide application practices in Florida citrus groves are on pp. 15-18. 

B. Summary Assessment of the Scenario Design2 

1. Scenario Design: This protocol addresses the handler exposure scenario 

involving application of liquid pesticides to orchard and trellis crops using 

conventional airblast sprayers drawn by closed-cab vehicles. EPA’s Worker 

Protection Standard (WPS) at 40 CFR 170.240(d)(5) requires enclosed cabs to 

completely surround occupants with a nonporous barrier that prevents contact 

with pesticides outside the cab. Limitation to use with an enclosed cab is a 

risk/exposure mitigation option EPA may exercise in its regulatory decisionmaking. 

According to the WPS, in an enclosed cab that does not provide respiratory 

protection, handlers need not wear all the PPE listed on the pesticide labeling, but 

must wear at least: 

• long-sleeved shirt and long pants, 

• shoes and socks, and 

• any respirator of a type listed on the label. 

In an enclosed cab that does provide respiratory protection equivalent to that 

provided by respirators identified on the pesticide label, handlers must still wear a 

long-sleeved shirt and long pants, shoes and socks, but need not wear a respirator. 

The AHE55 protocol calls for closed-cab airblast application of one of two 

surrogate insecticides to citrus in Florida. A total of 25 Monitoring Units (MUs) 

are proposed for the closed-cab airblast scenario; when the scenario is complete, 

the five (MUs) to be collected under this protocol will be combined in the AHED 

database with twenty more to be collected under other field study protocols. EPA 

intends to use these data to estimate daily dermal and inhalation exposures of 

pesticide applicators applying liquid pesticides to orchard and trellis crops using 

conventional airblast equipment drawn by closed-cab vehicles. 

 

2 Supporting details are in Attachment 1. 

Page 4 of 56 
2. Sampling Design: The closed-cab airblast scenario, as currently planned, will 

involve five clusters, each defined as a separate field study. Clusters have been 

purposively selected to create a diverse range of orchard/trellis crops, agronomic 

practices, and geographic regions. Each cluster is referred to as a monitoring 

‘site.’ 

The AHETF diversified the five clusters for this scenario by crop and geographic 

region through a five-step purposive process: 

• Identifying the principle crop types associated with airblast application, 

based on consultation with experts 

• Identifying the states where each principle crop is grown from NASS 

statistics 

• Grouping the states by EPA’s growing regions 

• Selecting one of the major producing states for each major crop, but no 

more than one state/crop pair per region 

• Selecting a county or counties for each state/crop pair in which to conduct 

each field study 

The result of executing the first four steps of this first stage of the diversity 

selection process was the purposive choice of the following five crop/state 

combinations for the five proposed monitoring sites: 

• Citrus crops in Florida (oranges) 

• Nut crops in Georgia (pecans) 

• Pome fruit in Washington (apples) 

• Stone fruit in Michigan (cherries) 

• Trellis crops in California (grapes) 

These choices are appropriate to cover the most important regional and agronomic 

variations in the use of airblast equipment. Of specific relevance to this protocol, 

Florida grows two-thirds of all citrus in the U.S., and citrus is the only major crop 

treated by airblast equipment in the “peninsular southeast” growing region. 

The specific ‘site’ selected in which to conduct the citrus study is Polk and 

Hillsborough Counties, adjacent to each other in central Florida. The AHETF 

choice of these counties was based on Polk County’s high orange production, 

Hillsborough County’s adjacency to Polk County and convenience to major 

transportation routes, and having identified a suitable Local Site Coordinator. 

There are approximately 2500 citrus farms in these two counties out of 

approximately 7000 citrus farms in the state. This is an appropriate choice to 

efficiently achieve the desired diversity of equipment and scale. 

Page 5 of 56 
In the next stage of the diversity selection process the practical range of amount of 

active ingredient handled (AaiH) for the airblast scenario is divided into five 

bands, of equal width on the log AaiH scale. Past studies have shown that AaiH 

is strongly associated with exposure and is a meta-factor associated with 

differences in equipment and spraying practices. Although the AHETF calculates 

the maximum amount an applicator may handle as 200 lbs AI/day, a more 

practical upper bound is 100 lbs AI/day. AHETF has set a lower limit at 5 lbs, to 

minimize non-detects. AHETF has partitioned the practical AaiH range from 5 to 

100 lbs AI/day into five strata: 

• 5 to 9 lbs AI handled 

• 10 to 17 lbs AI handled 

• 18 to 30 lbs AI handled 

• 31 to 55 lbs AI handled 

• 56 to 100 lbs AI handled 

This is a reasonable approach to stratification, and it should be possible to fill all 

strata in all five crop/region field studies defined for this scenario within the range 

of standard agronomic practices. 

The next stage of sample selection results in identifying the growers whose crops 

will be treated and the workers whose exposure will be monitored. As with other 

agricultural pesticide application scenarios, growers who agree to cooperate with 

the research and to spray their crop must be identified before their workers can be 

recruited. 

The AHETF process for identifying growers includes five steps: 

• Contacting local resources to identify growers of the crop of interest 

• Assembling a list of growers from all resources contacted and suppressing 

duplicates 

• Putting the list of growers into random order 

• Contacting growers, one at a time, in the sequence of the randomized list, 

to determine whether the grower is ‘eligible’ to participate 

• Placing eligible growers into a “working pool” 

Screening of growers for eligibility will continue until the pool contains 

somewhat more growers with somewhat more workers than are needed to fill five 

MUs. From each grower in the working pool, the following range of information 

will be compiled: 

• Crop and acreage that might be treated 

• Specific location of crop(s) that might be treated 

• Number, type, and size of airblast sprayers available 

• Surrogate chemical(s) that might be used 

• Estimated timing of applications 

Page 6 of 56 
• Number of experienced workers available 

• Range of AaiH those workers might be able to handle in a day 

This process of identifying cooperating growers is basically sound, but could be 

made stronger by relying less heavily on the Local Site Coordinator (especially 

since the LSC’s employees are not excluded as subjects) and if the processes of 

grower selection and construction of an efficient configuration of MUs were 

defined in an appropriate SOP—with particular attention to standards for 

documentation and methods for randomization. 

From the identified pool of potential cooperating growers—correctly 

characterized as a random sample of growers (of the purposively selected crop in 

the purposively selected state and county)—the Study Director and the Local Site 

Coordinator will purposively construct an “efficient configuration” of potential 

Monitoring Units (MUs). An efficient configuration will involve a group of 

growers in the same geographic area, who can provide workers for all five strata 

of AaiH, who would involve some diversity in spray equipment, and who expect 

to make airblast applications at approximately the same time. When constructing 

MUs, three additional restrictions will be enforced to increase diversity within the 

cluster: 

• No worker may be used more than once 

• No airblast sprayer may be utilized more than once 

• No more than 2 MUs may be obtained from one grower or 

grower/commercial applicator pair 

The growers and/or commercial applicators in the chosen configuration provide 

the pool of workers from which workers will be recruited to fill each of the five 

MU slots. If growers or workers drop out as the time of the field study 

approaches, additional workers appropriate to fill out the MU design may be 

recruitable from among those employed by growers already in the working pool 

of eligible growers. If there are too few workers available in the pool to complete 

a revised efficient configuration, the working pool can be expanded by 

approaching more growers from the original randomized list. 

The process for selecting workers could be strengthened by over-recruiting 

growers, so that there are likely always to be more interested and qualified 

workers than MU slots, so that the workers actually sampled could be selected 

randomly. In addition it would be preferable if no more than one MU were 

obtained from a single grower or grower/commercial applicator pair. 

 

3. Choice of Surrogate Materials: The surrogate chemicals proposed for this 

scenario are carbaryl and malathion, formulated in seven registered products. 

These pesticides have been successfully used in previous worker/handler 

exposure monitoring studies and have well established and reliable analytical 

methods. Between 2005 and 2007, approximately 50,000 to 90,000 acres per year 

Page 7 of 56 
of Florida citrus were treated with these chemicals. These are appropriate choices 

for this research 

C. Summary Assessment of the Scientific Aspects of the Study Design3

1. Statistical design: This protocol describes collecting five Monitoring Units 

(MUs) reflecting the exposure of subjects making airblast applications to Florida 

citrus using closed-cab vehicles. This is one of five clusters in the scenario, each 

of which will include five MUs. The general rationale for the 5 x 5 cluster 

configuration is presented in Appendix C of the revised AHETF Governing 

Document; details specific to the closed-cab airblast scenario are in the scenario 

design. No characteristics of this scenario have been identified which would 

justify a departure from the 5 x 5 configuration. 

2. Proposed pattern of exposure: The proposed exposure duration for each MU 

will be at least 4 hours, involving application of at least 3 tank-loads. Subjects 

will only apply the pesticide; mixing and loading will be done by others not 

participating in the study. Over the course of a day each subject will apply the 

surrogate active ingredient in one if the following five strata of AaiH: 

• 5 to 9 pounds 

• 10 to 17 pounds 

• 18 to 30 pounds 

• 31 to 55 pounds 

• 56 to 100 pounds 

Seven registered products containing one of the two surrogate pesticides have 

been identified, and a cooperating grower may choose to use any of them for a 

specific MU. Carbaryl formulations include wettable powders enclosed in watersoluble bags and liquid flowable concentrates. Malathion formulations include 

emulsifiable concentrates or liquid flowable concentrates. All of these products 

will be mixed with water and loaded into the airblast spray tank by workers not 

participating in the study. 

During application subjects may need to leave their enclosed cab to adjust or 

repair equipment or for other reasons. Whenever they leave the cab applicators 

will wear all personal protective equipment (PPE) required by the label, in 

accordance with the Worker Protection Standard (WPS), which requires that in 

any enclosed cab where reduced PPE is worn handlers must: 

• Keep immediately available all PPE listed on the labeling for the type of 

task being performed 

 

3 Supporting details are in Attachment 2.

Page 8 of 56 
• Wear the PPE if it is necessary to leave the cab and contact pesticide 

treated surfaces in the treated area 

• Take off PPE that was worn in the treatment area before reentering the 

cab, and 

• Store all PPE in a chemical-resistant container, such as a plastic bag, to 

prevent contamination of the cab. 

The exposure pattern of open-cab airblast applicators is generally to the upper 

body as a result of falling aerosolized sprays or brushing into treated 

foliage/branches; the enclosed cab is meant to mitigate this exposure potential. 

However, individual behavior is also expected to affect exposure. 

In many of the existing closed-cab studies in PHED, the exposure contact values 

are based on many measurements that were below the Limit of Quantification 

(LOQ). Current analytical methods for the surrogate chemicals are more 

sensitive than those used in earlier studies populating PHED, but if the results of 

this study are measurements below the LOQ, the AHETF is prepared to use half 

the LOQ or some other statistical method to estimate potential exposures. 

3. Endpoints and Measures: The AHETF will measure dermal and inhalation 

exposure for each MU. These data can be used to develop Unit Exposures 

(exposure per unit of pesticide active ingredient applied) or other exposure 

metrics, and to estimate dermal and inhalation exposure to other pesticides 

applied to orchard or trellis crops with conventional airblast sprayers drawn by 

vehicles with closed cabs. EPA believes that the proposed measures are 

appropriate and sound for the study design. 

Dermal exposure will be measured by a whole body dosimeter (WBD) worn 

beneath the subject’s outer clothing. After the monitoring event, the inner 

dosimeter will be removed from the subject and sectioned into two pieces 

representing the upper and lower torso. Residues in socks measured in earlier 

open-cab airblast studies have been very low (e.g., ≈0.1% of dermal exposure). 

Exposure to the applicator’s feet in a closed-cab scenario is expected to be 

insignificant; socks will not be collected as dosimeters. 

Before beginning work subjects will wash their hands in 500 mL of 0.01% 

Aerosol® OT-75 solution (AOT solution) to remove any source of contamination 

and to practice the method of hand-washing. These samples will be discarded. 

Hand wash samples will be collected prior to restroom and lunch breaks, before 

water breaks if required by the label or requested by the subject, and at the end of 

each exposure period. 

Before each subject begins work his/her face and neck will be wiped with a cotton 

gauze swab to remove any contamination not associated with the monitoring 

event. This face/neck wipe sample will be discarded. Subjects will undergo 

Page 9 of 56 
another face/neck wipe sampling prior to the break and again at the end of the 

exposure period; both samples will be retained for analysis. 

Airborne concentrations of the surrogate will be monitored in the subject’s 

breathing zone using an OSHA Versatile Sampler (OVS) tube sample collector 

connected to a personal sampling pump. The unit will be calibrated prior to the 

monitoring event using a rotameter. The OVS tube will be clipped to the 

subject’s shirt collar with the intake facing downward. The air sampling pump 

will be connected to the OVS tube and will be operated for the total monitoring 

period including any breaks. 

Additional measures will record environmental conditions at the time of 

monitoring. Observers will make field notes of subject activity throughout the 

monitoring event, and photographs or videos may be taken selectively to illustrate 

events. 

4. QA/QC Plan: The study will be monitored by three different QAUs: one from 

the exposure monitoring contractor that conducts the study in the field, one from 

the analytical laboratory that determines the level of pesticide residues in field 

samples, and one contracted directly by AHETF.

Analytical and field sampling quality control procedures include complete 

validation of all analytical methods, field fortification and control samples, 

laboratory fortification and control samples, and guidelines on the use of 

calibration curves to determine chemical residues found on all sample matrices. 

Field fortifications will be conducted in the field under the same conditions as the 

field samples. They will be transported and stored in a similar manner as the field 

samples, and will be analyzed in the laboratory concurrently with the field 

samples. Samples collected from the subjects will be corrected based on the 

results of the recovery of the field fortified samples. 

5. Statistical Analysis Plan: The results of physical sample analysis will be 

provided in the final report of this field study and in the scenario monograph 

covering all monitoring conducted under the closed-cab airblast scenario, and will 

be posted to the AHED® database, where they will be available to regulatory 

agencies for later statistical analysis. The documentation will report a confidenceinterval-based approach to determine the relative accuracy for the arithmetic mean 

and 95th percentile of unit exposures. The AHETF will not otherwise statistically 

analyze the monitoring data. 

D. Compliance with applicable Scientific standards 

The scenario sampling design is generally sound, but would be strengthened by 

the following changes: 

Page 10 of 56 
• Reducing the role of the Local Site Coordinator in serving as a consulting expert, 

influencing the choice of locations in which to conduct the field study, identifying 

growers, screening growers for eligibility, developing an efficient configuration 

of MUs, and providing his own employees as potential subjects. As a contractor 

to the AHETF the LSC is a member of the research team, and should not also 

serve as part of the study population, either as an expert or as a cooperating 

grower or commercial applicator. 

• Documenting the processes of diversity selection of growers and construction of 

an efficient configuration of MUs in an appropriate SOP. 

• Increasing the numbers of growers and workers in the working pool, so that 

individual workers to fill each MU slot can be selected randomly from among 

qualified, interested volunteers. 

This protocol itself adequately addresses the following elements according to 

applicable scientific standards: 

• Scientific objective 

• Experimental design for achieving objectives 

• Quantification of the test materials 

• Data collection, compilation and summary of test results 

• Justification for selection of test substances 

• Justification for sample size 

• Fortification levels and number of samples for laboratory, field, and storage 

stability samples 

Additionally, the AHETF has addressed the technical aspects provided in the 

applicable exposure monitoring guidelines (i.e. Series 875 Group A and OECD 

Applicator Guidelines) as well as Good Laboratory Practices (GLPs). 

E. Summary Assessment of Ethical Aspects of the Proposed Research4

1. Societal Value of Proposed Research: The objective of this study is to 

determine the potential exposure for workers making closed-cab airblast 

applications in Florida citrus. This study will provide a partial answer to the 

question of what dermal and inhalation exposures are likely for applicators using 

conventional airblast equipment and closed-cab tractors. This is a widespread 

pattern of pesticide application in orchard and trellis crops, for which existing 

applicator exposure data are inadequate. EPA will use the results of this study, in 

conjunction with the results of four other field studies planned for this scenario, to 

 

4 Supporting details are in Attachment 2. 

Page 11 of 56 
estimate the dermal and inhalation exposure likely for future applicator-days for a 

wide range of agricultural pesticides applied under this exposure scenario. 

2. Subject Selection: Subjects will be recruited among the employees of citrus 

growers in Polk and Hillsborough Counties in Florida who are identified as 

“commercial citrus producers [who] might utilize airblast equipment in their 

operations” and who meet AHETF criteria for participation. Eligible growers will 

be identified from a complete list of citrus growers in the two affected counties, 

processed in random sequence. Subjects will be recruited who are employees of 

eligible growers (or of pesticide application service companies used by eligible 

growers), who are experienced in the use of closed-cab airblast application 

equipment, and who meet the eligibility requirements of the study; if more 

employees are available and interested than are needed, participants will be 

selected randomly. Although the design is purposive, and thus participants are 

not representative in a statistical sense, they are expected to be typical of those 

who use airblast equipment to treat Florida citrus. 

Inclusion factors are appropriate, requiring subjects to have recent experience 

operating the equipment to be used in the study. Exclusion factors are 

appropriate, with the exception of the unexplained exemption of employees of the 

Local Site Coordinator from the exclusion of all other employees of AHETF 

contractors. No such exemption is allowed by the AHETF Governing Document 

(§14.1.4) or by AHETF SOP 11.B.1 (§5.3), and this exemption should be deleted 

from the protocol. 

The description of the process for recruiting subjects relies heavily on references 

to AHETF SOP 11.B. Appropriate steps are proposed to protect candidates and 

subjects from coercion or undue influence to participate, again with the potential 

exception of employees of the Local Site Coordinator. Candidates who attend an 

individual interview will be paid $20 whether or not they agree to participate; 

enrolled subjects who once put on the whole-body dosimeter will be paid $80 in 

addition to their usual pay whether or not they complete participation. 

3. Risks to Subjects: Six kinds of risks to subjects are discussed in the protocol, 

along with specific steps proposed to minimize them: 

• The risk of heat-related illness 

• The risk of exposure to surrogate chemicals 

• The risk associated with scripting of field activities 

• Psychological risk 

• The risk of exposure to detergents used for hand washing and face wipes 

• The background risk of injury associated with agricultural work 

The surrogate chemical used will be either carbaryl or malathion; both are fully 

tested and well understood. Individual growers will choose from a list of seven 

registered products containing one of these ingredients, for each of which a 

Page 12 of 56 
product-specific supplement to the consent form describes the specific risks 

identified on the approved label. Margins of Exposure (MOEs) calculated for the 

highest levels of exposure proposed in this protocol substantially exceed the target 

MOE for occupational dermal and inhalation exposure. 

Appropriate provision is made for safety and medical monitoring. At the end of 

the test day subjects will be reminded that they have a copy of the consent form 

with phone numbers to call if they think they have any adverse effects resulting 

from participation; no other post-study follow-up is proposed. 

4. Benefits: This research offers no direct benefits to the subjects, but subjects may 

request their individual results. If they are told only their own results little benefit 

would result, but if they are told how their exposure compared to that of others it 

could be of potential indirect benefit to them. The principal benefit of this 

research is likely to be reliable data about the dermal and inhalation exposure of 

workers applying pesticides to citrus orchards using closed-cab airblast 

equipment, usable by EPA and other regulatory agencies to support exposure 

assessments for a wide variety of pesticides with similar use patterns. 

5. Risk/Benefit Balance: Risks to subjects have been minimized in the design of 

the research. The low residual risk is reasonable in light of the likely benefits to 

society from new data supporting more accurate applicator exposure assessments 

for a wide range of agricultural pesticides. 

6. Independent Ethics Review: The proposed research has been reviewed and 

approved by the Independent Investigational Review Board, Inc., (IIRB, Inc.) of 

Plantation FL. The submitted materials include a full record of correspondence 

between the investigators and the IIRB.

7. Informed Consent: Informed consent will be obtained from each prospective 

subject and appropriately documented. Subjects will sign both the consent form 

and the product-specific supplement describing the surrogate material chosen by 

the grower. Oral fluency in English or Spanish is a criterion for inclusion, but 

literacy is not required. Appropriate provision is made to meet the needs of 

subjects who do not read either language. EPA assessments of compliance with 

the requirements of 40 CFR §26.1116 and §26.1117 appear in Attachments 4 and 

5 to this review. 

8. Respect for Subjects: Subject identifying information will be recorded only 

once; all subsequent data records and reports will refer to individual subjects only 

by an arbitrary code. Provision is made for discrete handling of pregnancy 

testing, required of all female subjects on the day of testing. Candidates and 

subjects will be repeatedly reminded that they are free to decline to participate or 

to withdraw at any time for any reason, without penalty. 

Page 13 of 56 
F. Compliance with Applicable Ethical Standards 

This is a protocol for third-party research involving intentional exposure of 

human subjects to a pesticide, with the intention of submitting the resulting data to EPA 

under the pesticide laws. Thus the primary ethical standards applicable to this proposal 

are 40 CFR 26, Subparts K and L. In addition, the requirements of FIFRA §12(a)(2)(P) 

for fully informed, fully voluntary consent of subjects apply. A detailed evaluation of 

how this proposal addresses applicable standards of ethical conduct is included in 

Attachments 2-5 to this review. 

The following specific deficiencies in the protocol should be addressed before the 

research is initiated: 

• The Local Site Coordinator must be identified in the protocol. 

• If employees of the Local Site Coordinator are to be exempted from the exclusion 

criterion applying to all other contractors to AHETF, this exemption must be 

justified, as should be the departure from the prohibitions of LSC employee 

participation in the AHETF Governing Document and SOP, and special provision 

must be made to protect such employees from any coercion or undue influence 

that might be brought to bear on them by the Local Site Coordinator. 

• Care must be taken to ensure that all materials provided to candidates in the 

recruiting and interviewing processes, including label and MSDS summaries and 

other materials described in SOPs, are reviewed and approved by the responsible 

IRB before use. 

• Clarify whether the questions in Attachment 11-B-3 to SOP 11.B.1 are intended 

as examples of the kinds of questions the interviewer might ask to confirm 

understanding of the consent form, or if they are all to be asked of all candidates. 

• The standard of documentation required to support a decision to rely on an 

interpreter rather than a bilingual investigator should be defined in the protocol or 

in an SOP, as should be procedures for how interpreters and “impartial bilingual 

witnesses”, if required, will be recruited and compensated, and how their 

competency and impartiality will be assessed. 

• Add to the protocol provision for counting and reporting the number of potentially 

eligible workers linked to each grower, and the numbers attending initial group 

meetings, attending individual consent interviews, signing consent forms, 

subsequently withdrawing or being withdrawn, and completing participation. 

40 CFR 26 Subpart L, at §26.1703, as amended effective August 22, 2006, 

provides in pertinent part: 

Page 14 of 56 
Page 15 of 56 

EPA shall not rely on data from any research involving intentional 

exposure of any human subject who is a pregnant woman (and therefore 

her fetus), a nursing woman, or a child. 

The protocol requires that subjects be at least 18 years old and excludes female subjects 

who are pregnant or lactating. Thus §26.1703 would not forbid EPA to rely on a study 

executed according to this protocol. 

 If the deficiencies noted above are addressed and the amended protocol is 

approved by the overseeing IRB, this research should meet the ethical standards of 

FIFRA §12(a)(2)(P) and 40 CFR 26 subparts K and L. 

Attachments: 

1. Summary Review of Closed-Cab Airblast Scenario Design dated 7 April 08 

2. Summary Review of Protocol AHE55 dated 7 April 08

3. §26.1111 Criteria for IRB approval of research 

4. §26.1116 General requirements for informed consent 

5. §26.1117 Documentation of informed consent 

6. §26.1125 Criteria for Completeness of Proposals for Human Research 
Page 16 of 56 

Attachment 1 

EPA Scenario Review: AHETF Close-Cab Air Blast Scenario 

Title: Closed Cab Airblast Applicator Scenario Sampling Plan: pp. 9-52 in 

AHETF Volume 1: General Information and Scenario Sampling Plan 

Date: 7 April 2008 

Sponsor: Agricultural Handlers Exposure Task Force 

 

1. Scope of Scenario Design 

“This scenario includes application of liquid sprays to actively growing, foliated crops using 

conventional airblast equipment and closed-cab tractors.” (V1:12) 

“The following five crop type/state combinations are proposed for this scenario that will 

provide the desired diversity in crop and geography: 

• Citrus crops in Florida (e.g., oranges) 

• Nut crops in Georgia (e.g., pecans) 

• Pome fruit in Washington (e.g., apples) 

• Stone fruit in Michigan (e.g., cherries) 

• Trellis crops in California (e.g., grapes)” (V1:13) 

(a) Is the scenario adequately defined? 

The scenario is clearly and appropriately defined. 

(b) Is there a need for the data? Will it fill an important gap in understanding? 

“AHETF has identified the closed cab airblast application scenario as being within the 

scope of the task force goals and one for which data are lacking. A number of AHETF 

member products are labeled for this use pattern. This application scenario is applicable 

to a wide variety of commercially important crops (e.g., fruit trees, nut trees, and trellis 

crops). Therefore, it is necessary to have data in AHED for the application technique 

described by this scenario. . . . 

“AHETF (in conjunction with EPA, PMRA, and CDPR, collectively the Joint Regulatory 

Committee (JRC)) reviewed handler exposure measurements in existing studies (mostly 

not included in PHED) to identify those that satisfy current acceptability criteria and 

qualify for inclusion in a generic database. For this particular scenario, the JRC reviewed 

two closed cab airblast application studies and did not identify any data from existing 

studies that were deemed useful for a generic database. 
Page 17 of 56 

Attachment 1 

“AHETF also conducted a detailed review of the data in PHED for this scenario to 

determine if any of the data weresuitable for a modern generic database. Data for closed 

cab airblast application of liquid sprays comprise PHED Scenario 12 –Airblast 

Application, Closed Cab (APPL). Data within that scenario were graded by EPA as “Low 

Confidence” for the “No Clothes” and “Single Layer, No Gloves” clothing scenarios. The 

inhalation exposure data are also graded as “Low Confidence”. The “Single Layer, 

Gloves” clothing scenario in PHED was graded as “High Confidence” but it was noted 

that there are a large number of non-quantifiable residues for this clothing scenario. In the 

AHETF detailed review of these PHED data, one MU from one study was found that 

possibly met the acceptance criteria established by AHETF. However, several issues 

associated with this MU make it of dubious quality and the logistical problems of 

obtaining a single MU from a single study provides sufficient rationale for not further 

pursuing these data (Exponent, 2007). Thus, there are no data currently in PHED for this 

scenario that are useful for a modern generic database. 

“Finally, EPA examined data from 13 existing airblast exposure studies or exposure 

assessments (for open and/or closed cabs) that were not available to the AHETF and 

concluded that none of the exposure data should be included in the AHETF database 

(correspondence from EPA on July 3 as a follow-up to a June 27, 2007 meeting with 

AHETF). This MU selection plan therefore proposes to collect a full set of new data for 

this closed cab airblast application scenario to meet the scientific objectives outlined in 

the Governing Document.” (V1:16-17) 

2. Rationale for Scenario Sampling Design 

(a) Are the variables in the scenario design likely to capture diverse exposures at the 

high-end? 

“AHETF experts agree that exposure potential will be considerably less for closed cab 

situations than for open cab situations and believe that overhead spraying, exiting the cab, 

and contacting surfaces (e.g., while making adjustments or repairs) may be the most 

important parameters influencing exposure in closed cab situations. . . . AHETF believes 

the best way to get diversity in these various parameters is to vary the crop type, 

especially for crop height and foliage density. This will ensure the collection of MUs 

includes some overhead exposure and a variety of equipment configurations and settings 

(see Section 6 for more details). 

“Crop conditions are therefore considered an important parameter that should be formally 

diversified. Consequently, any stratification should distinguish orchard and trellis crops, 

both commonly treated with closed cab airblast sprayers. . . .” (V1:26) 

“. . . Five crop categories encompass approximately 97% of all the acreage that might be 

treated by airblast applications. This suggests the possibility of stratifying the crops 

treated by airblast into these five crop types: 
Page 18 of 56 

Attachment 1 

• Nut crops 

• Citrus 

• Pome fruit 

• Stone fruit 

• Trellis crops 

“The “other orchard” category will be restricted from the target population because 

overall acreage is relatively low and agricultural experts did not indicate there were 

fundamental differences in how these crops are treated by airblast. These orchard crops 

include avocados, dates, figs, guavas, olives, and papayas. 

“Trellis crops will be considered as a group with one exception – tall hops. Hops are 

treated with conventional airblast equipment like other trellis crops, but unlike grapes and 

caneberries they can grow very tall and involve overhead exposure similar to orchard 

situations. Since trellis crops are purposively included in the sampling plan because they 

are shorter than orchard crops and don’t involve overhead exposure, this plan will restrict 

MUs involving trellis crops to situations that do not involve overhead exposure (i.e., tall 

hops will not be included). 

“However, exposure potential for workers who use airblast sprayers in tall hops will still 

be covered within AHED by data from orchard applications.” (V1:27-28) 

“Crop Type Growing Areas: Acreage by state for each of the five crop types is readily 

available from USDA . . . and provides a convenient way to identify where important 

crop types are commonly grown. A ‘predominant growing area’ for each of the five crop 

types can be defined in terms of states that account for 5% or more of the total crop type 

acreage.” (V1:28) 

“One state will ultimately be selected from each of these five crop type strata. It should 

be emphasized, however, that relative crop acreage was used only to delineate states 

associated with where most of the crops are grown. Acreages cannot be used to guide a 

“representative” sample of airblast application conditions. This is because information on 

the number of sprays performed per year by airblast with enclosed cabs in particular areas 

and for particular crops would be needed. This information is not readily available and it 

varies from year to year based on the amount and type of pest pressure in each crop in 

each area. Therefore, acreage data are used only as a guide to indentifying locations 

where enclosed cab airblast applications are probably common. Discussions with local 

agricultural experts are then used to verify that the scenario of interest is common and 

then specific study sites can be chosen.” (V1:30) 

“Geographic Stratification: . . . Closed-cab airblast applications are made almost 

exclusively to orchard and trellis crops and these crops are grown in many regions of the 

country. . . . For this reason, geographic diversity between sites is also desired. 

Geographic diversity between clusters of monitoring units is . . . viewed as a meta-factor 
Page 19 of 56 

Attachment 1 

that is associated with both known and unknown effects usually classified as simply 

‘study effects’. . . . 

“The 13 U.S. Growing Regions established by EPA (Figure 2) provide a convenient basis 

for geographic stratification. These regions have been used when planning and 

conducting pesticide residue trials for various crop types. The regions were based on 

natural geography and climatic boundaries (ACPA, 1992) and are therefore useful for 

indicating when locations selected for exposure monitoring are geographically diverse. . . 

. The goal in diversity selection is to obtain no more than a single state from each EPA 

growing region.” (V1:30-31) 

“Selecting States from Crop Type and Geographic Strata: . . . The diversity selection 

goal is to choose one state for each crop type with the proviso that no two states are in the 

same EPA growing region. Guided by this rule and the information in Table 5, the 

following five combinations . . . were purposively selected. 

1. Citrus / Florida 

“This citrus combination was chosen because of the dominant acreage for citrus crops in 

Florida (66%) and because it is the only combination in Region III. Florida was selected 

over California (the only other combination involving citrus) since California will be 

chosen for another crop type (see below). Florida reflects a hot and humid climate in the 

peninsular southeastern US (EPA Region III). 

2. Trellis Crops / California 

“This trellis crop combination was chosen because of the dominant acreage for trellis 

crops in California (77%). California was selected over Washington (the number two 

acreage state) so that Washington could be selected for pome fruits due to its dominance 

in that crop type (see below). California reflects a hot and dry climate in the western US 

(EPA Region X). 

3. Nut Crops / Georgia 

“This nut crop combination was chosen because California (the highest nut crop acreage) 

is already selected and because AHETF has a qualified Local Site Coordinator in Georgia 

that will likely result in a localized and efficient study. This state reflects a hot and humid 

climate in the southeastern US (EPA Region II). 

4. Pome Fruit / Washington 

“This pome fruit combination was chosen because of the dominant acreage available for 

pome fruits (84%) and because it provides good geographic diversity. This state reflects a 

cool climate in the Pacific Northwestern US (EPA Region XI or XII). 
Page 20 of 56 

Attachment 1 

5. Stone Fruit / Michigan 

“This stone fruit combination was chosen because Michigan has the highest acreage for a 

stone fruit after California. This combination also provides geographic diversity because 

it reflects a cool climate in the upper Midwestern US (EPA Region V). 

“Collectively, these crop type/state combinations cover five different EPA growing 

regions including the West, Northwest, Southeast, and upper Midwest portions of the US. 

They also cover all five of the crop types that are desired for diversity. AHETF also has 

acceptable Local Site Coordinators in each of these states. Finally, local agricultural 

experts have been contacted from each of these states to confirm airblast applications are 

common to the crop indicated.” (V1:32-34) 

“Selection of Specific Monitoring Sites for Each Study: The final step for selecting 

sites is to choose a specific area within each selected state identified above where 

growers and workers can be recruited to conduct a study in a reasonable amount of time. 

This involves staging the study (i.e., site) in a reasonably limited geographic area so that 

MU identification and selection operations can be conducted efficiently in one local area 

within the state. This is necessary primarily to keep the costs of study conduct reasonable 

so an adequate number MUs can be obtained in the AHETF monitoring program. 

“Choosing a cost-effective configuration of MUs is necessary since costs escalate rapidly 

when a research team makes several visits to a location in order to monitor the desired 

five MUs. Cost-effectiveness is obviously maximized when all MUs are collected during 

the same visit so researcher salary, travel, food, lodging, and field fortification expenses 

are minimized.” (V1:35) 

“Therefore, for each study (i.e., site), a particular area of each state will be selected and 

identified in the study protocol. This will be determined by discussions with local 

resources to indicate areas that are most likely to have sufficient growers, equipment, and 

workers to allow an efficient study. It may also be restricted based on the availability of 

a Local Site Coordinator who is responsible for providing logistical support to the 

CROs.” (V1:36) 

“The primary considerations for site selection will be the availability of citrus crops 

sprayed with airblast equipment, suitable growers that are willing to use the AHETF 

surrogate compounds and are willing to participate in the study, and the availability of 

a Local Site Coordinator with experience conducting similar studies and a familiarity 

with agricultural practices in the area. Full details of the site selection process and 

actual sites will be recorded in the study file.” (V2:26) 

(b) How have random elements been incorporated into the scenario sampling design? 

All choices in the first stage of the proposed diversity selection process, and stratification 

by AaiH in the second stage, are purposive choices. 
Page 21 of 56 

Attachment 1 

“AHETF has determined that a method of randomly choosing a working pool of growers 

is practical for this scenario. This pool of growers will provide the workers and 

application conditions needed to construct MUs for the study. Random selection of 

growers is preferable, when feasible, to reduce the possibility of selection bias that might 

arise from the Local Site Coordinator (LSC; i.e., a local agricultural researcher) 

purposively choosing which growers to contact. Therefore, a procedure for generating a 

list of available growers for each study (i.e., associated with each local monitoring site), 

and randomly selecting a pool of growers from that list, will be established in the 

protocol for that study. The general procedure to be followed is described in the 

following steps: 

1. Contact local resources from each of the following groups and ask for a list of 

growers for the crop type of interest at the identified location (generally about one 

to three counties) . . . . 

2. Assemble a list of growers from all of the resources contacted and eliminate any 

duplicates. 

3. Put the list of growers into random order. 

4. Contact growers, one at a time, following the random order, and determine 

whether the grower is ‘eligible’ to participate. . . . 

5. Each grower identified as eligible (sometimes along with an associated 

commercial applicator) is placed into a working pool along with information on: 

• Crop(s) available, with acreage that might be treated 

• Specific location of crop(s) that might be treated 

• Description of equipment available (e.g., number, type, and size) 

• Surrogate chemical(s) that might be utilized 

• Approximate timing of surrogate applications 

• Number of workers available 

• AaiH those workers might be able to handle in a day 

“Screening of the grower list (in random order) continues until a pool of eligible growers 

(and/or commercial applicators) that is sufficiently large is obtained. . . . 

“This process results in a random sample of eligible growers and, by association, a 

random pool of potential workers associated with eligible growers.” (V1:38-40) 

“AHETF researchers will contact local resources from each of the following categories in 

Polk and Hillsborough counties in Florida: 

• Local Site Coordinator (LCS) 

• Commercial Applicator Firms that service citrus groves 
Page 22 of 56 

Attachment 1 

• University Agricultural Researchers / County Extension Agents 

• Crop Consultants (e.g., pest control advisors or commercial applicators) that 

service citrus groves 

• Chemical Dealers or Sales Representatives 

• Citrus Grower Associations 

“The researchers will briefly explain the AHETF Exposure Monitoring Program to the 

local resources who are then asked for a list of growers in Polk and Hillsborough counties 

who are commercial citrus producers and might utilize airblast equipment in their 

operations. The list of growers from all of the resources will be compiled and duplicate 

names eliminated. All local resource contacts shall be documented in a detailed record 

that shall be maintained in the study file. 

“The compiled list of growers from local resources shall be placed in random order for 

further consideration. The randomization process will be documented and maintained in 

the study file. 

“The growers shall be contacted, one at a time, following the random order, to determine 

whether the grower is ‘eligible’ to participate in this study. 

“Screening of the growers (in the order of the random list) continues until the pool of 

eligible growers (and/or commercial applicators) contains at least 10 workers who may 

potentially volunteer for the study, and at least 2 workers are available for each of the 

AaiH strata. This pool will include more growers and more workers than are ultimately 

needed for the study.” (V2:26-28) 

(c) What feasible opportunities to incorporate random elements in the design—if any— 

have been overlooked? 

By constructing an “efficient configuration” of MUs such that only 10 workers are in the 

recruiting pool it is unlikely that the opportunity will often arise to select randomly from 

among interested workers. If the configuration included a pool of at least 3 or 4 potential 

workers for each MU, the opportunity to select randomly would arise in nearly all cases. 

(d) What typical patterns of exposure will likely be included by the sampling design? 

“This is an application scenario defined entirely by the application equipment, i.e., 

airblast sprayers with closed cabs. Airblast sprayers are used to apply chemicals to 

orchard trees and trellis crops (e.g., grapes, caneberries, etc.) by delivering pesticides as a 

liquid carried in a large volume of air. Other crop types, such as row and field crops, are 

not treated by airblast equipment and are therefore not relevant for this scenario. The air 

stream functions to move spray into the trees or vines to enhance the uniformity of 

deposition onto foliage, fruit, and wood. The air stream physically displaces the air space 

surrounding the foliage and deposits the chemicals on all surfaces of the leaves and 

branches.” (V1:15) 
Page 23 of 56 

Attachment 1 

“Sprayers are commonly drawn by a tractor or vehicle to move the sprayer through the 

orchard or vineyard, but can also be mounted on a tractor or other vehicle.” (V1:44) 

“AHETF experts ... believe that overhead spraying, exiting the cab, and contacting 

surfaces (e.g., while making adjustments or repairs) may be the most important 

parameters influencing exposure in closed cab situations.” (V1:26) 

“The workers will be allowed to follow their normal procedures as long as they fit the 

scenario definition and do not conflict with EPA’s Worker Protection Standard (WPS) 

regulations. The duration of the work activity will be partially determined by the amount 

of AaiH but will involve the application of at least three loads and a minimum duration of 

four hours. 

“For this particular scenario the applicator will be in a closed cab while the actual 

spraying takes place. The cab enclosure should reduce dermal and inhalation exposure 

from airborne spray that would otherwise reach the operator. This protection is due to the 

physical barrier between the pesticide spray and the worker. When doors or windows are 

opened, however, this barrier is no longer effective and the potential for worker exposure 

is increased. Opening windows during actual spraying would be contrary to the WPS and 

a violation of the label. This will, therefore, not be allowed. 

“AHETF suspects that exposure potential, especially dermal exposure, may be impacted 

by how often the applicator gets out of the closed cab, where that exiting occurs, and 

what the worker does while outside the cab. Exiting the cab might occur to make sprayer 

adjustments, perform repairs, or prepare a new load. Therefore, exiting might occur 

within or outside of the treated area. By exiting the cab, the worker might be subjected to 

lingering airborne sprays and/or surfaces that may have been sprayed with pesticide 

including the crop itself, the ground, various parts of the sprayer, and the outside of the 

cab. Exiting the cab is not, however, something that can be predicted or controlled in 

advance since it depends on factors such as worker preference, number of loads 

performed, and whether repairs or adjustments are necessary. The agricultural experts 

consulted by AHETF indicated that exiting the cab is rare. Number of exits, therefore is 

not amenable to formal diversification, but will likely vary as a result of purposive 

diversity in AaiH, and other factors such as crop type, equipment, etc.” (V1:42-43) 

“Setup of an airblast sprayer can be very complex involving the following factors and 

others: nozzle type, nozzle size, nozzle placement, number of nozzles, orientation of air 

director vanes, liquid pressure setting, spray volume per acre (GPA), engine speed, 

ground speed, etc... Collectively, these factors might also have an impact on exposure 

potential for airblast applicators, for example by influencing the amount of spray that 

remains airborne long enough to reach the operator or that contaminates surfaces the 

operator may later contact.” (V1:45) 
Page 24 of 56 

Attachment 1 

(e) What typical patterns of exposure will likely be excluded by the sampling design? 

“Airblast applications are sometimes made to dormant crops (e.g., to control scale), but 

agricultural experts for orchard and trellis crops indicate that foliar applications (e.g., to 

control diseases and insects on foliage) are much more common. Overall, dormant 

applications are estimated to account for 15% or less of all airblast applications (Bruce, 

2008). Therefore, because foliar sprays are much more common than dormant sprays, 

AHETF intends to collect MUs for foliar applications only; dormant applications will be 

excluded from the target population of conditions for this scenario.” (V1:15-16) 

“Figure 1 summarizes U.S. acreage statistics for these important groups of orchard and 

trellis crops. This chart indicates that five crop categories encompass approximately 97% 

of all the acreage that might be treated by airblast applications. 

“The ‘other orchard’ category will be restricted from the target population because 

overall acreage is relatively low and agricultural experts did not indicate there were 

fundamental differences in how these crops are treated by airblast. These orchard crops 

include avocados, dates, figs, guavas, olives, and papayas. 

“Trellis crops will be considered as a group with one exception – tall hops. Hops are 

treated with conventional airblast equipment like other trellis crops, but unlike grapes and 

caneberries they can grow very tall and involve overhead exposure similar to orchard 

situations... this plan will restrict MUs involving trellis crops to situations that do not 

involve overhead exposure (i.e., tall hops will not be included)... exposure potential for 

workers who use airblast sprayers in tall hops will still be covered within AHED by data 

from orchard applications.” (V1:27-28) 

“Other application equipment types can sometimes be used as an alternative to 

conventional airblast sprayers. Agricultural experts indicated the following are sometimes 

alternatives in orchard or trellis crops: aerial application, directed-spray rigs, wrap-around 

sprayers, covered boom sprayers (e.g., tunnel or curtain), electrostatic sprayers, and mist 

blowers... these alternative systems are not nearly as common as conventional airblast 

sprayers for either trellis or orchard crops. AHETF will therefore limit its MU collection 

to include exposure to workers operating conventional airblast sprayers.” (V1:45) 

3. Are the proposed test materials appropriate surrogates? 

“The following active ingredients are approved for use on orchards and trellis crops, meet the 

minimum PPE requirements listed above, and will be considered for use in this closed-cab 

airblast application scenario. The commercial products of these active ingredients that might 

be used in particular studies will be listed in study-specific protocols. 

• Carbaryl (insecticide; orchards or trellis) 

• Malathion (insecticide; orchards or trellis) 
Page 25 of 56 

Attachment 1 

“These surrogate active ingredients also typically have high use rates for the potential crops 

of interest that enables measurements at the high end of AaiH per day. Additionally, 

cooperating growers who will use these products are likely to be available. Finally, these 

active ingredients have been used as surrogates in other studies and are known to have the 

required stability under field study conditions. Since this scenario involves only applications 

of liquid sprays, any product with the proper registration that can be added to water and 

applied as a liquid spray is suitable. The actual product and packaging type has no influence 

on the potential exposures to these applicators and is, therefore, not an important 

consideration for this scenario.” (V1:46-47) 

4. What is the rationale for the proposed cluster design and sample size? 

“Appendix C of the Governing Document describes the methodology to calculate sample 

sizes when the reference model used is cluster sampling from a lognormal distribution. For 

the purposes of determining sample sizes, the default variation structure for normalized 

dermal exposure derived in Appendix C is also assumed applicable to the closed cab airblast 

application scenario. AHETF and the Joint Regulatory Committee agreed there is no 

evidence to suggest otherwise and no strong opinion to the contrary (meeting with AHETF, 

June 27, 2007). It is therefore appropriate to use the default relative variation structure 

consisting of a geometric standard deviation (GSD) of 4.0 and intra-cluster correlation (ICC) 

of 0.3. Appendix C shows that under these conditions (and where no suitable MUs exist) a 

sample of 5 clusters (NC =5) with 5 MUs per cluster (NM=5) is the most cost effective design 

configuration that meets the 3-fold accuracy requirement. This accuracy is possible with a 

variable number of MUs/cluster as long as the total number of MUs is at least 25 and no 

cluster has more than 5 MUs. Each cluster (i.e. monitoring site) will be addressed by a 

separate study protocol. 

“Appendix C of the Governing Document also shows that when the benchmark accuracy 

requirement above is met there may also be sufficient power to permit users of the database 

to perform a limited examination of the relationship between the normalizing factor (e.g., 

AaiH) and exposure. This is true provided: (1) the practical range of the normalizing factor 

is at least an order of magnitude and (2) there is adequate within-cluster variation in the 

normalizing factor. When these conditions occur, the MU sample will be of sufficient size 

and diversity to provide at least 80% statistical power to distinguish complete proportionality 

from complete independence between exposure and the normalizing factor used in the 

primary benchmark. Since these conditions can be satisfied for the reference sampling 

design, then the purposive diversity design for the closed cab airblast scenario should provide 

adequate power for the minor (i.e., secondary) objective: the ability to conduct limited 

examinations of the relationship between AaiH and exposure.” (V1:22-23) 
Page 26 of 56 

 

Attachment 2 

 

EPA Protocol Review: AHE55: Closed-Cab Airblast Application to Florida Citrus 

Title: Determination of Dermal and Inhalation Exposure to Workers During Airblast 

Applications of Liquid Sprays Using Closed Cab Equipment in Florida Citrus. 

Revision Date: 24 March 2008 

Study Director and Sub-Investigators: 

Larry D. Smith, Ph.D. 

 Brian Lange5

 Tami Belcher5

 Aaron Rotondaro5 

Local Site Coordinator: TBD6

 

Field Facility: Southeast Ag Research

86 Jim Moore Rd. 

Chula GA 31733 

 

Analytical Facility: TBD6 

 

Sponsor: Agricultural Handlers Exposure Task Force, LLC 

c/o David R. Johnson, Ph.D. 

1720 Prospect Drive 

Macon MO 63552 

 

Reviewing IRB: Independent Investigational Review Board, Inc. 

6738 West Sunrise Blvd Suite 102 

Plantation FL 33313 

 

1. Societal Value of Proposed Research 

(a) What is the stated purpose of the proposed research? 

“The objective of this study is to develop data to determine the potential exposure for 

workers making closed cab airblast applications in Florida citrus.” (V2:7) 

5 One of these three will be the “Principal Field Investigator” for this study. When the choice is made it will be 

reflected in the protocol and consent document. 

6 The Local Site Coordinator, Analytical Facility, and Principle Analytical Investigator must all be identified. 
Page 27 of 56 

Attachment 2 

(b) What research question does it address? Why is this question important? Would 

the research fill an important gap in understanding? 

This study will provide a partial answer to the question of what dermal and inhalation 

exposures are likely for applicators using conventional airblast equipment and closed-cab 

tractors. This is a widespread pattern of pesticide application in orchard and trellis crops, 

for which existing data are inadequate. 

(c) How would the study be used by EPA? 

In conjunction with the results of four other field studies planned for this scenario, EPA 

will use the results of this study to estimate the dermal and inhalation exposure likely for 

future applicator-days for a wide range of agricultural pesticides.

(d) Could the research question be answered with existing data? If so, how? 

“For this particular scenario, the JRC [Joint Regulatory Committee] reviewed two closed 

cab airblast application studies and did not identify any data from existing studies that 

were deemed useful for a generic database. 

“AHETF also conducted a detailed review of the data in PHED for this scenario to 

determine if any of the data were suitable for a modern generic database. . . . In the 

AHETF detailed review of these PHED data, one MU from one study was found that 

possibly met the acceptance criteria established by AHETF. However, several issues 

associated with this MU make it of dubious quality . . . . Thus there are no data currently 

in PHED for this scenario that are useful for a modern generic database. 

“Finally, EPA examined data from 13 existing airblast exposure studies or exposure 

assessments (for open and/or closed cabs) that were not available to the AHETF and 

concluded that none of the exposure data should be included in the AHETF database.” 

(V1:16-17) 

(e) Could the question be answered without newly exposing human subjects? If so 

how? If not, why not? 

There is no alternative to monitoring applicators as they apply pesticides for measuring 

their dermal and inhalation exposure as they apply pesticides. 

2. Study Design 

(a) What is the scientific objective of the study? If there is an explicit hypothesis, what 

is it? 
Page 28 of 56 

Attachment 2 

The objective of the proposed study is to collect exposure monitoring data “to represent 

future exposures to an arbitrary active ingredient under the closed cab airblast application 

scenario.” (V1:12) 

 “The primary benchmark objective for this scenario is that a sample from the 

hypothetical reference sampling distribution above be of adequate size to describe 

selected measures of the (normalized) exposure distribution with a pre-determined level 

of accuracy. 

“The current consensus is that estimates of the geometric mean, the arithmetic mean, and 

the 95th percentile generally need to be accurate to within approximately 3-fold of the 

actual population value. AHETF and the Joint Regulatory Committee (EPA, California 

Dept. of Pesticide Registration, Pest Management Regulatory Agency [Canada], and the 

U.S. Department of Agriculture) agreed 3-fold accuracy is an appropriate benchmark for 

this scenario (meeting with AHETF, June 27, 2007).” (V1:21) 

No explicit hypothesis is stated, nor is the study explicitly designed to test one. 

(b) Can the study as proposed achieve that objective or test this hypothesis? 

It is likely that the objective can be achieved by the proposed study. 

“If the adequacy analyses... indicate that the target benchmark objectives for a particular 

scenario are not met, then the AHETF, in consultation with the JRC, could decide to 

conduct new studies in order to obtain additional clusters.” (V4:73) 

2.1 Statistical Design 

(a) What is the rationale for the choice of sample size?

“On balance, a configuration consisting of 5 clusters with 5 MUs/cluster seems to be 

a reasonable compromise given the existing variation seen in the current exposure 

data. Obviously, fewer resources would be necessary when it is felt that the GSD and 

ICC for normalized exposure can be less than the assumed values of 4 and 0.3, 

respectively. Smaller sample sizes could also be used when K>3 is considered 

acceptable. For tighter accuracy requirements, additional samples would be needed. 

The methods described above can be used, as needed, to determine the sample sizes 

for other combinations of GSD, ICC, and K.” (V4:144) 

“Appendix C of the Governing Document describes the methodology to calculate 

sample sizes when the reference model used is cluster sampling from a lognormal 

distribution. For the purposes of determining sample sizes, the default variation 

structure for normalized dermal exposure derived in Appendix C is also assumed 

applicable to the closed cab airblast application scenario. AHETF and the Joint 

Regulatory Committee agreed there is no evidence to suggest otherwise and no strong 
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opinion to the contrary (meeting with AHETF, June 27, 2007). It is therefore 

appropriate to use the default relative variation structure consisting of a geometric 

standard deviation (GSD) of 4.0 and intra-cluster correlation (ICC) of 0.3. Appendix 

C shows that under these conditions (and where no suitable MUs exist) a sample of 5 

clusters (NC=5) with 5 MUs per cluster (NM=5) is the most cost effective design 

configuration that meets the 3-fold accuracy requirement. This accuracy is possible 

with a variable number of MUs/cluster as long as the total number of MUs is at least 

25 and no cluster has more than 5 MUs.” (V1:22) 

(b) What negative and positive controls are proposed? Are proposed controls 

appropriate for the study design and statistical analysis plan? 

No positive or negative controls are proposed. This is appropriate for the study 

design and statistical analysis plan. 

(c) How is the study blinded? 

The study is not blinded, nor could it be.

(d) What is the plan for allocating individuals to treatment or control groups? 

“After the randomly-selected pool of eligible growers is assembled, researchers (e.g., 

Local Site Coordinator and Study Director) will examine the details of potential MUs 

and identify a configuration of MUs (i.e., growers, chemicals, workers, AaiH, timing) 

that will result in an efficient study.” (V1:40)

“The Study Director or designated researcher will seek permission from the eligible 

grower to approach his/her employees to recruit volunteers for the study. . . . The 

Study Director or researcher shall continue conducting site inspections and potential 

participant recruitment as described above until an adequate number of eligible 

growers and potential participants have been secured for an efficient configuration of 

all MUs in the study. During this process, the following restrictions will be 

maintained: 

• At least 10 workers who may potentially volunteer for the study 

• At least 2 workers available for each of the AaiH strata 

• No more than 2 MUs from any one grower (this effectively requires at least 3 

different growers since 5 MUs are desired) 

• No workers may be used more than once 

• No piece of equipment (tractor plus sprayer) may be used more than once” 

(V2:29) 
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(e) Can the data be statistically analyzed? 

“As has always been the case, any statistical conclusions based on such data imply 

the qualification: ‘to the extent that the data can be viewed as deriving from a true 

random sample.’” (V1:49) 

 (f) What is the plan for statistical analysis of the data? 

“As detailed in the Governing Document, the data collected from the studies for this 

scenario will only be statistically evaluated with respect to the benchmark measures 

of adequacy. These two categories of data adequacy are: 

1. The relative accuracy of selected statistics characterizing the distribution of 

exposure normalized by amount of active ingredient handled (AaiH). 

2. How well the data can be expected to describe a relationship between exposure 

and AaiH, if one existed.” (V1:49) 

“The primary benchmark objective is that selected lognormal-based estimates of 

normalized dermal exposure distribution be accurate to within 3-fold, at least 95% of 

the time. The benchmark estimates specified are those for the geometric mean, 

arithmetic mean, and the 95th percentile. 

“To evaluate how well the collected data conform to this benchmark, the 95 percent 

bound on relative accuracy will be calculated from the confidence interval for each of 

the three parameters given above.” (V1:49-50) 

“This secondary benchmark objective [Adequacy of the Data for Distinguishing a 

Proportional from an Independent Relationship between Exposure and AaiH] applies 

to the closed cab airblast scenario because the practical range in the amount of active 

ingredient handled (AaiH) exceeds an order of magnitude. In this case it is 

reasonable to consider the linear regression of log dermal exposure on log AaiH. 

Such a regression would use a mixed model formulation in order to incorporate 

random cluster effects.” (V1:50) 

(g) Are proposed statistical methods appropriate to answer the research question? 

 Yes. 

(h) Does the proposed design have adequate statistical power to definitively answer 

the research question? 

Since the primary objective of the research is to characterize the distribution of 

exposure normalized by the amount of active ingredient handled (AaiH), statistical 

power does not relate to this objective. However, EPA believes the resulting data will 
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reliably characterize the distribution of exposures for the individuals monitored 

during the closed-cab airblast applications in this study, and that these exposures can 

inform assessments of the likely exposures for individuals in similar future situations. 

Regarding the secondary objective, distinguishing a proportional from an independent 

relationship between exposure and AaiH, statistical power is relevant. 

 “This secondary benchmark objective applies to the closed cab airblast scenario 

because the practical range in the amount of active ingredient handled (AaiH) exceeds 

an order of magnitude. In this case it is reasonable to consider the linear regression of 

log dermal exposure on log AaiH. Such a regression would use a mixed model 

formulation in order to incorporate random cluster effects. As described in the 

Governing Document, in such a model the true slope, β, would be equal to one if 

dermal exposure were directly proportional to AaiH. If exposure were independent of 

AaiH, then β=0. This benchmark objective requires that the number of clusters and 

the allocation of AaiH levels to MUs should be adequate to ensure that the regression 

analysis has at least 80% power to reject the hypothesis that β=0 when β is actually 

equal to one. By symmetry, the mixed model linear regression would also have the 

same power to reject the hypothesis that β=1 when β=0. This is the precise meaning 

of being able to ‘discriminate between proportionality and independence’.” (V1:50) 

2.2 How and to what will human subjects be exposed? 

“The closed cab airblast scenario program will monitor instances of worker exposure 

resulting from the airblast application of pesticides” to citrus in Florida. (V1:17) 

“The test substances approved for use in this study are listed in Section 2.3.2 above and 

Table 1 below. The most appropriate test substance, based largely on the preference of 

the grower, will be used at each of the individual locations. A different test substance 

may be used at each location and by each worker within a location if appropriate.” 

(V2:31-32)

(a) What is the rationale for the choice of test material and formulation? 

“The AHETF has developed several pesticide active ingredient compounds for use as 

surrogates. . . . Since the AHETF is developing a generic database that will be 

applicable to nearly all pesticide products and uses, any of the AHETF surrogates can 

be used for generating exposure data for this scenario. The choice of surrogate at each 

location will depend largely upon the preference of the grower and pest pressure on 

his crop at that time. 

“The following active ingredients are approved for use on orchards and trellis crops, 

meet the minimum PPE requirements listed above, and will be considered for use in 

this closed cab airblast application scenario. The commercial products of these active 
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ingredients that might be used in particular studies will be listed in study-specific 

protocols. 

• Carbaryl (insecticide; orchards or trellis) 

• Malathion (insecticide; orchards or trellis)

“These surrogate active ingredients also typically have high use rates for the potential 

crops of interest that enables measurements at the high end of AaiH per day. 

Additionally, cooperating growers who will use these products are likely to be 

available. Finally, these active ingredients have been used as surrogates in other 

studies and are known to have the required stability under field study conditions.” 

(V1:46-47)

(b) What is the rationale for the choice of dose/exposure levels and the staging of 

dose administration? 

“Since the number of pounds of active ingredient handled is the normalizing factor 

and indirectly influences many other handling conditions, efforts will be taken to 

generate data in as wide a range of AaiH as practical within each cluster of MUs. 

AaiH is selected since EPA currently normalizes closed cab airblast exposure by 

AaiH during pesticide product exposure assessments and there is no other factor 

identified as being more appropriate. 

“In addition to its potential direct relationship to exposure, the amount of active 

ingredient handled is also viewed as a meta-factor affecting parameters such as tank 

size, number of loads applied, etc. Thus, diversification of AaiH induces 

diversification of such associated factors as well. 

“The MUs for this scenario will span the practical AaiH range of 5 to 100 pounds, 

just over 1 order-of-magnitude. As noted in Section 4.5 above, it is also important 

that the AaiH levels be well-diversified within each cluster. This allows the data for 

this scenario to be used to discriminate a completely proportional relationship from a 

completely independent relationship between exposure and AaiH (if one of those two 

relationships were true). Within-cluster diversification of AaiH will be accomplished 

by following the standard approach of partitioning the practical AaiH range into five 

strata. These strata are: 

• 5 to 9 pounds ai handled 

• 10 to 17 pounds ai handled 

• 18 to 30 pounds ai handled 

• 31 to 55 pounds ai handled 

• 56 to 100 pounds ai handled” (V1:36-37) 

“A single MU will be conducted in this study from each of the five strata.” (V2:34) 
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(c) What duration of exposure is proposed? 

“Duration of monitoring is another parameter that could vary between MUs, 

especially since the AaiH will be varied by more than an order of magnitude. 

Airblast applicators often spend several hours making applications, so all MUs for 

this scenario must meet the general rule of being at least 4 hours long. This is 

designed to overcome the criticism of early exposure studies where many of the 

sampling regimes monitored workers for only a few minutes. Avoiding very short 

monitoring intervals will ensure that daily exposure estimates are not biased by 

unusual conditions during that short interval. If necessary, some minor scripting of 

worker activities will be done to ensure the lowest levels of AaiH are handled and/or 

a minimum of four hours are monitored. For example, a worker might be asked to 

use a smaller tank, make smaller loads, or increase the spray volume slightly in order 

to apply 3 loads in four hours for the lowest AaiH.” (V1:43) 

2.3 Endpoints and Measures 

(a) What endpoints will be measured? Are they appropriate to the question(s) 

being asked? 

“At the completion of the monitoring period, exposure samples will be taken in the 

following order to minimize cross contamination: inhalation samples (discussed in the 

next section), then hand washes, then face/neck wipes, and finally inner dosimeters as 

described below and in SOP AHETF-10.E.

“Workers will wear one layer of work clothing over the inner dosimeters. The inner 

dosimeter will consist of 100% white cotton long underwear, pre-washed and 

provided by the AHETF. The inner dosimeter is designed to represent the worker’s 

skin and will act as a collection medium that will be analyzed.

“Hand exposure will be measured by having the worker wash their hands in a 0.01% 

Aerosol OT solution according to a standardized washing procedure described in the 

most recent version of SOP AHETF-8.B. Interim hand wash samples will be 

collected whenever a worker would normally wash his/her hands (e.g., before using 

the toilet, etc.)... All hand washes collected during and at the end of the work period 

will be treated as separate samples.

“Face/neck exposure will be measured by wiping the entire face and neck areas (front 

and back of neck) with two gauze sponges, sequentially, that have been wetted with 

0.01% Aerosol OT as described in the most recent version of SOP AHETF-8.C. 

Interim face/neck wipe samples (consisting of two gauze sponges) will be collected 

prior to eating... All wipes collected during the study for a worker will be combined 

in the same container, resulting in a single sample for analysis. 
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“Full details of the personal air-sampling method, attachment of pumps, monitoring 

of workers, and pump calibration are given in the most recent versions of SOP 

AHETF-8.D and 10.G. Suitable low-volume personal air-sampling pumps and OVS 

tubes with a glass fiber filter and the appropriate sorbent for the test substance being 

used are required.” (V2:34-36)

(b) What steps are proposed to ensure measurements are accurate and reliable? 

“Sample matrix fortifications designed to assess the stability of the active ingredient 

during field, storage and transit conditions in or on the sampling materials (inner 

dosimeters, hand wash solutions, face/neck wipes, and air sampling matrices) will be 

conducted on a minimum of one day of exposure monitoring at each location, or more 

days as appropriate for environmental conditions. 

“After fortification, the inner dosimeters and OVS tubes will be exposed to ambient 

conditions (i.e., weathered) for the longest expected exposure monitoring period in a 

location away from possible contamination (e.g., upwind of mixing/loading and 

application operations). Inner dosimeter samples will be covered with a single layer 

of shirt material during weathering. Segments representing any body area may be 

used for inner dosimeter fortification samples. An air sampling system will be set up 

in a manner similar to that of the workers, in which a pump will continuously draw 

air through the pre-fortified filter and OVS tube for the entire duration of the work 

period. 

“Hand wash and face/neck wipe samples will be fortified and immediately placed in 

frozen storage without exposure to ambient conditions. In addition, on each 

fortification day, duplicate samples of the inner dosimeters fortified in the field at the 

highest level, and duplicate OVS tubes fortified in the laboratory at the highest 

fortification level, will be processed for immediate frozen storage and used as travel 

spikes. These travel spikes will be analyzed only if deemed necessary by the Study 

Director, for example to help determine the cause of unusually low field fortification 

recovery results. 

“Finally, on each fortification day, two untreated control samples of each matrix will 

be processed similar to the field fortification samples (i.e., some are weathered). 

Packaging, storage and shipment of the field fortification samples will be the same as 

for the worker exposure samples.” (V1:37-38) 

(c) What QA methods are proposed? 

“All aspects of the studies are monitored while they are in progress by appropriate 

quality assurance units (QAUs) to ensure compliance with GLP regulations and 

adherence to the protocol and relevant AHETF Standard Operating Procedures. This 

will typically involve three different QAUs: one from the exposure monitoring 

contractor that conducts the study in the field, one from the analytical laboratory that 
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determines the level of pesticide residues in field samples, and one contracted directly 

by the sponsor. For each field study, the following specific activities are conducted by 

these QAUs: 

• Sponsor-contracted QAU inspects all contract research organizations and 

laboratories prior to use in a study to ensure that those researchers operate in 

compliance with GLPs 

• Sponsor-contracted QAU reviews protocols prior to finalization 

• Sponsor-contracted QAU and/or field contractor QAU observes study conduct 

in the field 

• Field contractor QAU audits the raw data file from the field and audits the 

Field Report 

• Analytical laboratory QAU audits the raw analytical data and audits the 

Analytical Report 

• Sponsor-contracted QAU reviews the Final Report which includes the Field 

Report and Analytical Report as appendices 

“Each QAU submits an inspection report(s) to the Study Director and AHETF 

Sponsor Representative and any exceptions to full GLP compliance are listed in the 

Final Report associated with each protocol. 

“Chapter 5 of the AHETF SOP Manual provides details about the responsibilities of 

and procedures to be followed by the sponsor-contracted QAU. Field contractor and 

laboratory QAU’s follow similar SOPs from their own facility.” (V4:67) 

(d) How will uncertainty be addressed? Will reported point values be accompanied 

by measures of uncertainty? 

Uncertainty in field measurements will be addressed via fortification samples. 

“Field fortification samples are exposure matrix samples that are fortified (or spiked), 

generally in the field, with known amounts of active ingredient and subsequently 

analyzed to determine the amount of active ingredient recovered. Field fortification 

samples are subjected to the same environmental, handling, shipping and storage 

conditions as worker samples. Because these conditions are similar, and because field 

fortification samples are analyzed along with worker samples, recovery values 

calculated from analysis of fortification samples are applicable to worker exposure 

samples. Field fortification recoveries are therefore used to adjust residue levels 

found in worker samples for residue losses that might have occurred during 

collection, handling, shipping and storage.” (V6:51) 

“Sample matrix fortifications designed to assess the stability of the active ingredient 

during field, storage and transit conditions in or on the sampling materials (inner 

dosimeters, hand wash solutions, face/neck wipes, and air sampling matrices) will be 

conducted on a minimum of one day of exposure monitoring at each location, or more 
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days as appropriate for environmental conditions. . . . On each fortification day, two 

untreated control samples of each matrix will be processed similar to the field 

fortification samples (i.e., some are weathered). Packaging, storage and shipment of 

the field fortification samples will be the same as for the worker exposure samples.” 

(V2:37-38) 

In general, field measurements are adjusted based on the recovery from the 

fortification sample. For example, a field measurement for an inner dosimeter of 300 

ug would be adjusted based on the applicable fortification sample for the inner 

dosimeter matrix. If the recovery from that matrix was 80%, the reported 

measurement for that sample would be 300 ug/80% = 375 ug. 

3. Subject Selection 

3.1 Representativeness of Sample 

(a) What is the population of concern? How was it identified? 

“The closed cab airblast scenario program will monitor instances of worker exposure 

resulting from the airblast application of pesticides. Each instance is termed a 

monitoring unit (MU). Each MU consists of a set of airblast application conditions 

(including the particular worker) that are intended to represent the scenario activities 

for a single workday. In many cases monitoring units will be selected from ‘naturally 

occurring’ airblast applicator-days. However, the selected application conditions are 

sometimes modified or scripted slightly to ensure that the sample of MUs reflects the 

expected diversity in the entire population of future airblast application-days. Thus, 

MUs are technically not ‘sampled’ from a population. More correctly, they should be 

viewed as synthetic closed cab airblast application-days derived from both selected 

and constructed conditions.” (V1:17) 

(b) From what populations will subjects be recruited? 

Subjects will be recruited among the employees of citrus growers in Polk and 

Hillsborough Counties in Florida who are identified as “commercial citrus producers 

[who] might utilize airblast equipment in their operations” (V2:26) and who meet 

AHETF criteria for participation. 

Implicitly included in this class of commercial citrus producers is the unidentified 

“Local Site Coordinator”, whose employees are specifically exempted from the 

exclusion applying to all other employees of “a pesticide manufacturer or a contractor 

to AHETF (except employees of the Local Site Coordinator)” (V2:10) 
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 (c) Are expected participants representative of the population of concern? If not, 

why not? 

A ‘working pool’ of eligible growers will be identified from a randomized list of 

citrus growers in the two affected counties. Based on considerations of equipment 

type, acreage, anticipated time of treatment, and geographic location the Study 

Director and LSC will purposively select from this pool of growers to construct an 

‘efficient configuration’ of MUs. All employees of eligible growers included in the 

efficient configuration (or of pesticide application service companies used by eligible 

growers included in the efficient configuration) who are experienced in the use of 

closed-cab airblast application equipment and who meet the eligibility requirements 

of the study will be recruited; if more employees are available and interested than are 

needed for a specific MU, participants will be selected randomly. Although the 

design is purposive, and thus participants are not representative in a statistical sense, 

they are expected to be typical of those who use airblast equipment to treat Florida 

citrus. 

(d) Can the findings from the proposed study be generalized beyond the study 

sample? 

Yes, within the limits imposed by the purposive design of the study. 

3.2 Equitable Selection of Subjects 

(a) What are the inclusion/exclusion criteria? Are they complete and appropriate? 

“Participants in this study must meet the following inclusion criteria: 

• Be freely willing to participate and to understand and sign the consent form 

• Handle pesticides as part of their job 

• Be trained in safe pesticide handling practices in accordance with the Worker 

Protection Standard (WPS), or be exempt from such training 

• Have experience within the past year with making airblast applications to 

citrus using closed cab tractors and airblast sprayers (including the particular 

equipment to be used) 

• Be at least 18 years old with a government-issued ID to verify age 

• Consider themselves to be in good general health with no medical conditions 

that could impact their ability to participate in the study 

• Be willing to follow all label and WPS requirements 

“In addition, potential subjects who meet the following exclusion criteria will not be 

allowed to participate in this study: 

• Are pregnant females 

• Are nursing mothers 
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• Normally wear personal protective equipment (PPE) that is not required by 

the label, such as chemical-resistant clothing 

• Don’t understand Spanish or English 

• Are employed by a pesticide manufacturer or a contractor to AHETF (except 

employees of the Local Site Coordinator)” (V2:10) 

(b) What, if any, is the relationship between the investigators and the subjects? 

None, unless a subject is an employee of the Local Site Coordinator. 

(d) If any potential subjects are from a vulnerable population, what is the 

justification for including them? 

No justification is provided for exempting employees of the Local Site Coordinator 

from the exclusion applying to all other contractors to AHETF. No special provision 

is made to protect such employees from any coercion or undue influence that might 

be brought to bear to influence their decision whether to participate. 

(e) What process is proposed for recruiting and informing potential subjects? 

See sections 2.6 and 2.7 of the protocol (V2:20-24) and SOP AHETF 11.B.1 

(V6:113-127) 

“AHETF will follow standard procedures (see SOP AHETF-11.B) to recruit potential 

participants for this closed cab airblast application study. Individual workers will be 

recruited during an initial site inspection or subsequent visit(s) to an eligible grower 

facility. 

“The Study Director or designated researcher will seek permission from the eligible 

grower to approach his/her employees to recruit volunteers for the study. Depending 

on the number of employees and size of the grower facility the Study Director or 

researcher may contact employees through the use of an informational recruitment 

flyer posted in a common work area. Such a flyer will briefly describe the research 

study and provide contact information for employees who may have an interest in 

participation in the study. The flyer shall have been previously reviewed and 

approved by an IRB. 

“Alternatively, or subsequent to the use of a flyer, the Study Director or researcher 

will arrange a meeting with the grower’s employees who express an interest in 

participation. Such meetings will always occur without the grower or supervisors 

being present (SOP AHETF-11.B). The Study Director or researcher shall make a 

presentation describing the AHETF Exposure Monitoring Program, the goals of the 

research study, the procedures used in exposure monitoring, and the risks and benefits 

to participants. Contact information will be provided, and individuals will be 

encouraged to contact AHETF if they desire additional information about the study or 
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are interested in participating in the study. All presentation materials, such as 

handouts or visual aids, shall be reviewed and approved by an IRB prior to use in 

recruiting subjects.” (V2:28-29) 

(e) If any subjects are potentially subject to coercion or undue influence, what 

specific safeguards are proposed to protect their rights and welfare? 

“In accordance with SOP AHETF-11.B the individual growers will be asked to sign a 

non-coercion statement (Employer Cooperation Statement) affirming to their workers 

and AHETF that they will not coerce or unduly influence their workers to either 

participate or not participate in the study. Growers must also certify that alternate 

work will be provided on study days for workers who choose not to volunteer; and 

that the employee’s decision to participate or not will have no impact on their 

employment.” (V2:28) 

If both of the candidate workers identified for a specific MU decline to participate, 

the investigators would have to repeat several preliminary steps to identify potentially 

appropriate workers employed by growers in the working pool already identified, or 

to screen additional growers for inclusion in the working pool. The cost and time 

associated with repeating these steps could result in some pressure on the second 

candidate originally identified. This problem could be largely eliminated by 

identifying a larger pool of candidate workers—at least 3 or 4 for each defined MU—

in the first iteration. 

3.3 Remuneration of Subjects 

(a) What remuneration, if any, is proposed for the subjects? 

“During recruitment, workers will be offered an opportunity to take part in a group 

meeting with the Study Director or other designated member of the study team (but 

without the workers’ supervisors) to learn about participating in this study (Section 

6.2). No remuneration is offered for this introductory meeting. Workers who are still 

interested will attend a private meeting with a researcher who will obtain the 

informed consent of the worker (Section 2.7). Workers will be paid $20 for their 

attendance right after the consent meeting, whether or not they decide to participate in 

the study. Workers who decide to participate in the study will be paid an additional 

$80 each time they suit up (i.e., put on the long underwear) to participate in the study. 

Usually, workers will participate in the study on only one day unless their 

participation is terminated due to weather or other unexpected occurrences. The 

additional $80 is provided in cash at the end of the monitoring period or at the time 

the volunteer withdraws from the study. All workers who participate will receive the 

payment, even if they withdraw or their participation is terminated by the study 

team.” (V2:9-10) 
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(b) Is proposed remuneration so high as to be an undue inducement? No. 

(c) Is proposed remuneration so low that it will only be attractive to economically 

disadvantaged subjects? No. 

(d) How and when would subjects be paid? 

In cash, immediately after their participation.

4. Risks to Subjects 

4.1 Risk characterization 

(a) Have all appropriate prerequisite studies been performed? What do they show 

about the hazards of the test materials? 

The potential surrogate materials are registered with EPA, are well understood, and 

have been fully tested. 

“This study could involve either of two active ingredients: carbaryl or malathion. The 

pesticide products containing these active ingredients and potentially used in this 

study are currently registered for airblast applications to citrus crops. AHETF will 

only monitor workers making applications in accordance with all label and Worker 

Protection Standard (WPS) requirements. . . . For each of the active ingredients that 

may be used in this scenario the [Margins of Exposure (MOEs) calculated for the 

highest levels of exposure in this protocol] greatly exceeded the required MOE for 

both the individual dermal and inhalation routes of exposure, as well as for the 

combined [dermal/inhalation] exposure, and their use is acceptable for this scenario.” 

(V2:14) 

 

(b) What is the nature of the risks to subjects of the proposed research? 

“Six kinds of risks are associated with the conduct of the current exposure monitoring 

study. These are: 

• The risk of heat-related illness 

• The risk of exposure to surrogate chemicals 

• The risk associated with scripting of field activities 

• Psychological risks 

• The risk of exposure to detergents 

• The background risk of injury associated with agricultural work 

“In this study risks to subjects are classified as ‘greater than minimal’, primarily since 

agricultural work is considered a high risk occupation where the likelihood of harm or 
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discomfort is greater than what is encountered in ordinary daily life. In particular, 

this study involves the operation of tractors and airblast sprayers which present risks 

of accidents and physical injury, as well as the use of chemicals (pesticides, 

fertilizers, additives, etc.) which presents a risk of adverse health effects. In addition, 

AHETF believes the risk of heat-related illness (resulting from wearing an extra layer 

of clothing to trap chemical) will be increased due to study participation.” (V2:11) 

 Each of the six identified kinds of risk is discussed in V2:11-19 

“The following signs and symptoms of toxicity from short-term exposure might 

occur. These effects are not anticipated with normal use, but might occur following a 

spill or other accidental exposure. 

“This [carbaryl/malathion] product is classified as [low/moderate] toxicity for 

exposure by mouth, by skin, and by breathing. Signs and symptoms of too much 

short-term exposure include moderate eye irritation, slight skin irritation, [possible 

allergic skin reaction,] and inhibition of cholinesterase (cholinesterase is a chemical 

in our nervous system that allows the nerves to work correctly; when chemicals 

prevent it from working correctly, there is a stimulation of the nervous system.) 

“Inhibition of cholinesterase may result in headache, dizziness, nausea, vomiting, 

cramps, diarrhea, blurred vision, pinpoint pupils, tightness in the chest, difficulty 

breathing, nervousness, sweating, watering of the eyes, drooling, muscle spasms, and 

coma.” (V2:70, 72, 74, 76, 78, 80, 82 product-specific supplements to consent form) 

(b) What is the probability of each risk associated with the research? How was this 

probability estimated? 

Quantitative probabilities are not estimated. 

4.2 Risk minimization 

(a) What specific steps are proposed to minimize risks to subjects? 

“The following practices, designed to minimize these risks and respond to injuries, 

will be followed during this study: 

• Selecting only experienced pesticide handlers 

• Requiring experience operating the equipment to be used 

• Reminding workers of safe chemical handling practices 

• Identifying nearby hospitalization facilities in case of emergency 

• Monitoring the heat index and stopping the study if conditions warrant 

• Providing transportation to medical treatment and covering the costs of 

treatment 
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• Having a medical professional on site to observe the workers and provide 

urgent care 

• Observing study participants throughout the monitoring period 

• Ensuring that all tank mix products are used according to approved label(s) 

and do not require any additional PPE.” (V2:19) 

Risk reduction actions specific to each of the six identified kinds of risk are 

discussed in V2:11-18 

(b) How do proposed dose/exposure levels compare to established NOELs/NOAELs 

for the test materials? 

“For each of the active ingredients that may be used in this scenario the [Margins of 

Exposure (MOEs) calculated for the highest levels of exposure in this protocol] 

greatly exceeded the required MOE for both the individual dermal and inhalation 

routes of exposure, as well as for the combined [dermal/inhalation] exposure.” 

(V2:14)

 (c) What stopping rules are proposed in the protocol?

“Since workers may exit the cab, AHETF will monitor ambient conditions outside the 

cab to determine the heat index and base monitoring decisions on the external heat 

index. A heat index of 120o F is the cutoff, as measured outside the cab. When the 

worker is inside an air conditioned closed cab the external heat index will not be 

applicable to that subject and exposure monitoring will not necessarily stop if the heat 

index cutoff is reached or exceeded. A worker will be allowed to exit the cab for 

short periods of time even if the heat index cutoff is exceeded; however, if the 

duration of exiting becomes prolonged (more than 30 minutes), the Study Director or 

other researcher shall stop the monitoring and/or move the worker to a cooler 

environment until monitoring can be resumed.” (V2:13) 

(d) How does the protocol provide for medical management of potential illness or 

injury to subjects? 

“As a precaution, AHETF will have a paramedic, physician’s assistant, nurse or 

emergency medical technician on site during the study. If needed, this professional 

will also observe you for signs of illness and will provide medical attention.” (V2:51) 

SOP AHETF-11.H (V6:152-154) defines procedures to be followed if a subject in an 

AHETF study requires emergency medical attention. 
Page 43 of 56 

Attachment 2 

(e) How does the protocol provide for safety monitoring? 

The protocol refers to various SOPs which define procedures for safety monitoring: 

• SOP AHETF-11.E (V6:132-134) calls for researchers to monitor worker 

compliance with label and Worker Protection Standard requirements, and 

permits the Study Director to remove from the study a worker who engages in 

unsafe work practices. 

• SOP AHETF-11.G (V6:137-151) calls for the Study Director, the on-site 

medical professional, and all researchers and observers to monitor subjects 

for any indication of heat-related illness. 

• SOP AHETF-11.H (V6:152-154) defines procedures to be followed if a 

subject in an AHETF study requires emergency medical attention.

(f) How does the protocol provide for post-exposure monitoring or follow-up? Is it 

of long enough duration to discover adverse events which might occur? 

“Just prior to the completion of the worker’s participation in the study, a researcher 

will remind the participant he/she should bathe or shower as soon as practical and that 

they have received a copy of the signed consent form with phone numbers for 

reporting any health changes they think might be related to participation in the study. 

Post-study inquiries will be forwarded to the Study Director who will deal with the 

situation as appropriate and notify AHETF management (SOP AHETF-11.B).” 

(V2:25) 

(g) How and by whom will medical care for research-related injuries to subjects be 

paid for? 

“If you are injured or get sick during or after the day of the study, medical treatment 

will be available at your workplace and at a nearby health care facility. If necessary, 

AHETF will arrange transportation for you to receive medical attention. You may 

refuse medical treatment unless you get sick from too much pesticide exposure or 

from getting too hot, or if we believe you are too sick to make a rational decision 

about receiving medical treatment. AHETF will cover the cost of reasonable and 

appropriate medical attention that is not covered by your own insurance or insurance 

provided through your employer.” (V2:52) 

5. Benefits 

(a) What benefits of the proposed research, if any, would accrue to individual subjects? 

“There are no personal benefits to the study participants.” (V2:19) 
Page 44 of 56 

Attachment 2 

 Although there are no direct benefits to study participants, a potential indirect benefit 

is knowledge about how their exposure compares to that of others doing similar work; 

this is not addressed in the protocol. 

(b) What benefits to society are anticipated from the information likely to be gained 

through the research? 

“Since there are no existing data suitable for use in a generic database describing the 

exposure of closed-cab airblast application workers, society will likely benefit from data 

generated by this study through the improved risk assessments by EPA and other 

regulatory agencies. 

“Data from the AHETF exposure monitoring program has the potential to improve the 

ability of EPA and other regulatory agencies to accurately assess occupational risks 

associated with spraying pesticides using airblast equipment and closed-cab tractors. The 

knowledge likely to be obtained from this study is generalizable and will contribute to 

assessments of the risks of both new and existing pesticides.” (V2:19) 

 (c) How would societal benefits be distributed? Who would benefit from the proposed 

research? 

“Growers who allow the study to be conducted using their equipment, crops and facilities 

will be reimbursed for the pesticides used for the study. While this is beneficial to the 

grower, it is considered a minor benefit when compared to the costs of running their 

businesses. 

“The AHETF member companies will likely realize a benefit by addressing regulatory 

data requirements generically, at lower cost (and using fewer human subjects), than if 

they conducted similar studies for individual pesticide ingredients.” (V2:19) 

(c) What is the likelihood that each identified societal benefits would be realized? 

Identified societal benefits are likely to be realized. 

6. Risk/Benefit Balance: How do the risks to subjects weigh against the anticipated 

benefits of the research, to subjects or to society? 

“This study presents a greater than minimal risk to participants. The primary risk comes from 

their employment as an agricultural worker where accidents and chemicals contribute to 

injury and illness. In particular, this scenario involves the use of mechanical equipment that 

could cause physical injury and handling chemicals that could cause adverse health effects. 

However, workers will be experienced with the equipment they will be using and will follow 

their usual practices while handling pesticides approved for this use pattern. 
Page 45 of 56 

Attachment 2 

“Participating in this study increases the risk of heat-related illness, but this risk is mitigated 

by a medical management program which emphasizes prevention measures and guidelines 

for stopping participation when warranted based on environmental conditions. 

“The likely benefit to agricultural workers as a whole and to society in general, in the form of 

more accurate measurements of potential exposure to pesticides, must be weighed against the 

risks to participants. Airblast applications are common in both orchard and trellis crops 

across the country, and a wide variety of experts consulted by AHETF reported that closed 

cabs are most common now, and are becoming even more common. Exposure data for this 

scenario meeting contemporary standards of reliability and quality will likely provide a 

significant benefit to society. Because the margins of exposure (MOEs) calculated for the 

exposures in this research indicate that subjects are very unlikely to experience acute toxic 

effects, and because extensive procedures will be in place to minimize these and other risks 

to participants, the likelihood of serious adverse effects is very small. In sum, AHETF 

believes the risks to study participants from participating in this study are reasonable in light 

of the likely benefit to society of the knowledge to be gained.” (V2:20) 

7. Independent Ethics Review 

(a) What IRB reviewed the proposed research? 

Independent Investigational Review Board, Inc., of Plantation FL 

(b) Is this IRB independent of the investigators and sponsors of the research? Yes

(c) Is this IRB registered with OHRP? Yes

(d) Is this IRB accredited? No. 

(e) Does this IRB hold a Federal-Wide Assurance from OHRP? No. 

(f) Are complete records of the IRB review provided as required by 40 CFR 26.1125? 

Yes. 

(g) What standard(s) of ethical conduct would govern the work? 

“This study will be conducted in accordance with EPA’s final regulation published at 40 

CFR Part 26 that establishes requirements for the protection of subjects in human 

research. The protocol, informed consent form, and other required documentation for 

this study will be approved by an institutional review board (IRB) and submitted to the 

EPA as required by 40 CFR 26.1125. The report of the completed research is subject to 

40 CFR 26.1303 requirements to document its ethical conduct. 
Page 46 of 56 

Attachment 2 

“The proposed research described by this protocol, the informed consent form, and all 

recruitment materials, such as handouts or visual aids, shall be reviewed and approved by 

Independent Investigational Review Board Inc. (IIRB) of Plantation, Florida. Complete 

records of the IRB review as required by 40 CFR 26.1125 will be submitted to EPA for 

review along with this protocol and other documents. 

“Researchers that participate in the study and interact with study participants must 

undergo ethics training (SOP AHETF-1.B). The training shall include successful 

completion of the course from the National Institutes of Health (NIH; Human Participant 

Protections Education for Research Teams) and/or the Basic Collaborative IRB Training 

Initiative Course (CITI; The Protection of Human Research Subjects). Copies of the 

certificates of completion for the ethics courses will be submitted to the IRB and stored in 

the respective personnel files (maintained by the AHETF and all contract facilities.)” 

(V2:9-10) 

8. Informed Consent 

(a) Will informed consent be obtained from each prospective subject? Yes 

(b) Will informed consent be appropriately documented, consistent with the 

requirements of 40 CFR §26.1117? Yes. See also Attachment 5. 

(c) Do the informed consent materials meet the requirements of 40 CFR §26.1116, 

including adequate characterization of the risks and discomforts to subjects from 

participation in the research, the potential benefits to the subject or others, and the 

right to withdraw from the research? Yes. See also Attachment 4. 

(d) What is the literacy rate in English or other languages among the intended research 

subjects? 

Not addressed in protocol. Appropriate provision is made for informing candidates who 

cannot read the consent form in English or Spanish. 

(e) What measures are proposed to overcome language differences, if any, between 

investigators and subjects? 

“Study participation will be limited to English or Spanish speakers. When Spanish 

speakers are involved, a bilingual researcher will conduct the interview. Potential 

participants that have limited reading ability will have the consent form verbally 

explained in their preferred language (English or Spanish) with an impartial witness 

(bilingual as appropriate) present. Witnesses must have no association with AHETF, its 

member companies, researchers, growers, or workers. Witnesses must have some 

familiarity with farming and will be recruited from any appropriate source such as a 

university, grower association, or other organization. The witness cannot serve as the 
Page 47 of 56 

Attachment 2 

interpreter or an advisor to the volunteer. The witness will sign the consent form to 

acknowledge that the study participant apparently understood the information presented 

to him/her.” (V2:22) 

“However, if all reasonable efforts to obtain a bilingual researcher have been exhausted, 

it is acceptable to instead use an interpreter.” (V6:117) 

(f) What measures are proposed to ensure subject comprehension of risks and 

discomforts? 

“During the discussions with potential participants, ample time will be provided for 

questions and any additional information or clarification that is requested will be 

provided. When the Study Director or designated member of the study team is satisfied 

that the volunteer understands the requirements and risks of the study, and if the worker 

still wants to participate, he/she will be asked to sign and date the informed consent form 

and the Product Risk Statement.” (V2:23) 

“If the AHETF interviewer is not comfortable that the worker fully understands the 

discussions and the contents of the consent form, the worker will be excluded from 

consideration to participate in the study. This will be ascertained by providing repeated 

opportunities to ask questions and by asking questions of the potential volunteers that 

would require a response that indicates understanding of key issues for all sections of the 

consent form. These responses will be documented and if necessary the person 

conducting the consent meeting will re-explain topics until the volunteer demonstrates an 

appropriate understanding.” (V2:23-24) 

Attachment 11-B-3 to SOP 11.B.1 (V6:124-126) lists questions which might be asked to 

confirm understanding of the consent form.

(g) What specific procedure will be followed to inform prospective subjects and to seek 

and obtain their consent? 

“The Study Director or designated member of the study team will obtain informed 

consent from all study volunteers prior to their participation in the study. The consenting 

process is conducted in a private meeting between the researcher and the volunteer (and 

possibly other individuals as described below). Depending on the circumstances, 

consenting may occur several days prior to the study up to the day of the study. The 

volunteer will be given a copy of the consent form to review at least one day before the 

consent meeting, and advised of study provisions to accommodate their language 

preference, the need for readers, witnesses, and their desire to have a confidant or 

counselor present during an informed consent meeting. For example, the volunteer may 

feel more comfortable with a confidant or counselor in the consent meeting with him/her. 

“During the private consent meeting the worker will be provided with a full explanation 

of the study, its requirements, any potential risks, and its likely benefits. Workers will be 
Page 48 of 56 

Attachment 2 

informed that the grower or their employer will be reimbursed for the product used in the 

conduct of the study on their farms. Workers will be advised of their right to withdraw 

from the study at any time and for any reason without jeopardizing their normal position 

with their employers. Each volunteer will be provided a copy of the supervisor’s signed 

Employer’s Cooperation Statement (in the worker’s preferred language) that states they 

will not suffer any consequence if they decide to participate or not and they will receive 

their usual pay for the day when the study is conducted. 

“The volunteer will be informed that he/she will receive the $20 remuneration payment 

even if he/she decides not to participate. 

“The volunteer will be provided information about the risk of the particular product 

he/she will handle, including signs and symptoms of acute overexposure. The product 

and its risks will be identified in a Product Risk Statement that is an attachment to the 

consent form. Appropriate sections of the product label and Material Safety Data Sheet 

will be discussed by the person conducting the consent meeting and made available for 

review by the volunteer. WPS requirements, especially proper use of clothing, personal 

protection equipment, and cleaning facilities will be discussed. 

“The Study Director or designated member of the study team will discuss the germane 

aspects of the AHETF medical management plan with the prospective participants. 

Information will be provided about the risk of heat stress, including signs and symptoms, 

and ways to prevent it. 

“The IRB-approved consent form will be presented in the preferred language (English or 

Spanish) of the volunteer. All sections of the consent form including the test substance 

Product Risk Statement will be discussed in detail. 

“During the discussions with potential participants, ample time will be provided for 

questions and any additional information or clarification that is requested will be 

provided. When the Study Director or designated member of the study team is satisfied 

that the volunteer understands the requirements and risks of the study, and if the worker 

still wants to participate, he/she will be asked to sign and date the informed consent form 

and the Product Risk Statement. The member of the study team conducting the interviews 

(and witness, if applicable) will also sign the consent form and provide a copy of the 

signed form (and signed attachments) to the worker.” (V2:22-23)

(h) What measures are proposed to ensure fully voluntary participation and to avoid 

coercion or undue influence? 

“In accordance with SOP AHETF-11.B the individual growers will be asked to sign a 

non-coercion statement (Employer Cooperation Statement) affirming to their workers and 

AHETF that they will not coerce or unduly influence their workers to either participate or 

not participate in the study. Growers must also certify that alternate work will be 
Page 49 of 56 

Attachment 2 

provided on study days for workers who choose not to volunteer; and that the employee’s 

decision to participate or not will have no impact on their employment.” (V2:28) 

“Workers will be informed that the grower or their employer will be reimbursed for the 

product used in the conduct of the study on their farms. Workers will be advised of their 

right to withdraw from the study at any time and for any reason without jeopardizing 

their normal position with their employers. Each volunteer will be provided a copy of the 

supervisor’s signed Employer’s Cooperation Statement (in the worker’s preferred 

language) that states they will not suffer any consequence if they decide to participate or 

not and they will receive their usual pay for the day when the study is conducted.” 

(V2:22) 

9. Respect for Subjects 

(a) How will information about prospective and enrolled subjects be managed to ensure 

their privacy? 

“Initial contact with workers during recruitment will be made without the presence of 

their employer as described in detail in Sections 2.7 and 6.2 of this protocol. If workers 

are interested in participating, a private meeting with the Study Director or his/her 

designee will be used to explain the study further, address any questions, and seek the 

candidate’s consent to participate. 

“Pregnancy tests, required for female participants, must be conducted within 24 hours of 

the start of the monitoring period. These will be self-administered in a private restroom, 

but under the supervision of a female researcher. Positive results from pregnancy tests 

will not be documented or given to a woman’s employers or co-workers. If a female 

volunteer has a positive pregnancy test result, she must withdraw from participation but 

can do so without stating a reason. Consent forms and all other records associated with 

the worker will be promptly shredded (SOP AHETF-11.D). Negative results must be 

confirmed by a female researcher and recorded in the study files. 

“Certain worker information will be collected during the course of this worker exposure 

monitoring study. The information collected, such as notes taken by study observers, will 

not be available to a participant’s employer. Most information identifies subjects only by 

a unique worker identifier. Forms and paperwork that contain personal information 

(including a worker’s name or address) will be kept confidential in a sealed envelope 

while in the field. After the study is completed, this confidential envelope will be sent to 

AHETF archives with the other raw data. Unrestricted access to this confidential 

information is allowed only to the AHETF Administrative Chair (SOP AHETF-6.B). 

“The information collected in this study may, under certain regulatory circumstances, be 

given to the U.S. Environmental Protection Agency (EPA) or to state governmental 

agencies and other countries. Participants in the study will be informed that their names 
Page 50 of 56 

Attachment 2 

will not be disclosed, but that absolute confidentiality cannot be guaranteed because of 

the need to give information to these parties. 

“The results of this research may be presented at meetings or in publications; however, 

only a unique worker identification number will identify each worker in reports or 

presentations.” (V2:20-21) 

“Your name will appear on the consent form, the Product Risk Statement, and an optional 

form for you to request your personal study results. All other study information will 

identify you only by a unique code. Records with your name will be stored in a secure, 

limited access archive. 

“Information about your participation in this study will not be given to your employer. 

“A study report will be written by AHETF and will be available to member companies. 

It will be sent to the US Environmental Protection Agency (EPA). It may also be sent to 

state government agencies and to governments in other countries. Your name will not be 

included in any study report. 

“We cannot promise you absolute confidentiality because of the need to give information 

to some organizations or to parties in legal actions, as required by law. All study 

information, including records which identify you, may be looked at or copied by the 

sponsor and any consultants working with the sponsor, by EPA or other government 

agencies, and by the Independent Investigational Review Board, Inc., (IIRB). IIRB is a 

group of people who review and monitor research to make sure the people who 

participate in it are protected. 

“You may ask the Study Director for a copy of your personal results from this study. 

You will need to provide your name and a mail or e-mail address.” (V2:52) 

(b) How will subjects be informed of their freedom to withdraw from the research at 

any time without penalty? 

“The absolute right for subjects to withdraw from the research is the cornerstone of 

protection of human subjects. Prospective and enrolled subjects will be informed of their 

right to withdraw without consequence prior to and during the conduct of the research. 

Any volunteer expressing a need or desire to withdraw from the research after exposure 

monitoring begins will be paid $80 and allowed to return to their normal work duties for 

their employer. If a participant withdraws while being monitored, the long underwear and 

air sampling pump will be removed, and the hand and face/neck samples will be collected 

with the worker’s consent. The Study Director will decide whether these samples will be 

analyzed (SOP AHETF-8.K).” (V2:21-22) 

“Your employer has agreed to let us do this research and has confirmed that he/she does 

not care whether you participate in this study. Your decision to be in this study is 
Page 51 of 56 

Attachment 2 

voluntary and entirely up to you. If you decide to participate, you may change your mind 

later and drop out of the study at any time and for any reason. A decision not to 

participate, or to withdraw from the study after it begins, will have no effect on your job 

or pay or [involve] any penalty or loss of benefits to which you may be entitled.” (V2:53) 

(c) How will subjects who decline to participate or who withdraw from the research be 

dealt with? 

“No one can require you to participate in this study. Participation is entirely voluntary. 

If you choose not to participate in this study, then on the day of the study you will 

perform your ordinary activities. Your alternative is to not participate. 

“If you withdraw or are removed from the study, or if the study does not last an entire 

workday, you will be released to resume your usual activities.” (V2:54)
Page 52 of 56 

Attachment 3 

§ 26.1111 Criteria for IRB approval of research 

AHETF Protocol AHE55: Florida Citrus: April 7, 2008 

Criterion Y/N Comment/Page Reference 

(a)(1)(i) Risks to subjects are minimized by using procedures which are consistent with 

sound research design and which do not unnecessarily expose subjects to risk. Y 

(a)(1)(ii) Risks to subjects are minimized, whenever appropriate, by using procedures 

already being performed on the subjects for diagnostic or treatment purposes. n/a 

(a)(2) Risks to subjects are reasonable in relation to anticipated benefits, if any, to 

subjects, and the importance of the knowledge that may reasonably be expected to 

result. In evaluating risks and benefits, the IRB should consider only those risks and 

benefits that may result from the research (as distinguished from risks and benefits 

subjects would receive even if not participating in the research). The IRB should not 

consider possible long-range effects of applying knowledge gained in the research (for 

example, the possible effects of the research on public policy) as among those 

research risks that fall within the purview of its responsibility. 

Y 

(a)(3) Selection of subjects is equitable, taking into account the purposes of the 

research and the setting in which it will be conducted, and being particularly cognizant 

of the special problems of research involving vulnerable populations, such as 

prisoners, mentally disabled persons, or economically or educationally disadvantaged 

persons. 

Y 

(a)(4) Informed consent will be sought from each prospective subject or the subject’s 

legally authorized representative, in accordance with, and to the extent required by 

§26.1116. 

Y 

(a)(5) Informed consent will be appropriately documented, in accordance with, and to 

the extent required by §26.1117. Y 

(a)(6) When appropriate, the research plan makes adequate provision for monitoring 

the data collected to ensure the safety of subjects. Y 

(a)(7) When appropriate, there are adequate provisions to protect the privacy of 

subjects and to maintain the confidentiality of data. Y 

(b) When some or all of the subjects are likely to be vulnerable to coercion or undue 

influence, additional safeguards have been included in the study to protect the rights 

and welfare of these subjects. 

Y 
Page 53 of 56 

Attachment 4 

§26.1116 General requirements for informed consent 

AHETF Protocol AHE55: Florida Citrus: April 7, 2008 

Criterion Y/N Comment/Page Reference 

No investigator may involve a human being as a subject in research covered by this 

subpart unless the investigator has obtained the legally effective informed consent of the 

subject or the subject’s legally authorized representative 

OK 

An investigator shall seek such consent only under circumstances that provide the 

prospective subject or the representative sufficient opportunity to consider whether or not 

to participate and that minimize the possibility of coercion or undue influence 

OK 

The information that is given to the subject or the representative shall be in language 

understandable to the subject or the representative 

OK Ensure bilingual competence 

among investigators who conduct 

recruitment and consent interviews 

No informed consent, whether oral or written, may include any exculpatory language 

through which the subject or the representative is made to waive or appear to waive any of 

the subject’s legal rights, or releases or appears to release the investigator, the sponsor, 

the institution or its agents from liability for negligence 

OK 

(1) A statement that the study involves research, an explanation of the 

purposes of the research and the expected duration of the subject’s 

participation, a description of the procedures to be followed, and identification 

of any procedures which are experimental 

OK 

(2) A description of any reasonably foreseeable risks or discomforts to the 

subject 

OK 

(3) A description of any benefits to the subject or to others which may 

reasonably be expected from the research 

OK 

(4) A disclosure of appropriate alternative procedures or courses of treatment, 

if any, that might be advantageous to the subject 

n/a 

(5) A statement describing the extent, if any, to which confidentiality of records 

identifying the subject will be maintained 

OK 

(6) For research involving more than minimal risk, an explanation as to 

whether any compensation and an explanation as to whether any medical 

treatments are available if injury occurs and, if so, what they consist of, or 

where further information may be obtained 

OK Although research doesn’t involve 

more than minimal risk, compensation and treatment of injuries are 

provided for 

(7) An explanation of whom to contact for answers to pertinent questions 

about the research and research subjects’ rights, and whom to contact in the 

event of a research-related injury to the subject 

OK Ensure Spanish capability at all 

listed phone numbers 

(a) In seeking informed consent the following information 

shall be provided to each subject 

(8) A statement that participation is voluntary, refusal to participate will involve 

no penalty or loss of benefits to which the subject is otherwise entitled, and the 

subject may discontinue participation at any time without penalty or loss of 

benefits to which the subject is otherwise entitled 

OK 

(1) A statement that the particular treatment or procedure may involve risks to 

the subject (or to the embryo or fetus, if the subject may become pregnant) 

which are currently unforeseeable 

OK 

(2) Anticipated circumstances under which the subject’s participation may be 

terminated by the investigator without regard to the subject’s consent 

OK 

(3) Any additional costs to the subject that may result from participation in the 

research 

OK 

(4) The consequences of a subject’s decision to withdraw from the research 

and procedures for orderly termination of participation by the subject 

OK 

(5) A statement that significant new findings developed during the course of 

the research which may relate to the subject’s willingness to continue 

participation will be provided to the subject 

n/a 

(b) When appropriate, one or 

more of the following elements 

of information shall also be 

provided to each subject 

(6) The approximate number of subjects involved in the study OK 

(e) If the research involves intentional exposure of subjects to a pesticide, the subjects of 

the research must be informed of the identity of the pesticide and the nature of its pesticidal 

function. 

OK 
Page 54 of 56 

Attachment 5 

§26.1117 Documentation of informed consent 

AHETF Protocol AHE55: Florida Citrus: April 7, 2008 

Criterion Y/N Comment/Page Reference 

(a) Informed consent shall be documented by the use of a written consent form 

approved by the IRB and signed by the subject or the subject’s legally authorized 

representative. A copy shall be given to the person signing the form. 

OK 

(b)(1) The consent form may be a written consent document that embodies the 

elements of informed consent required by §26.1116. This form may be read to the 

subject or the subject’s legally authorized representative, but in any event, the 

investigator shall give either the subject or the representative adequate opportunity to 

read it before it is signed; or 

OK 

(b)(2) The consent form may be a short form written consent document stating that the 

elements of informed consent required by §26.1116 have been presented orally to the 

subject or the subject’s legally authorized representative. When this method is used, 

there shall be a witness to the oral presentation. Also, the IRB shall approve a written 

summary of what is to be said to the subject or the representative. Only the short form 

itself is to be signed by the subject or the representative. However, the witness shall 

sign both the short form and a copy of the summary, and the person actually obtaining 

consent shall sign a copy of the summary. A copy of the summary shall be given to the 

subject or the representative, in addition to a copy of the short form. 

n/a 
Page 55 of 56 

Attachment 6 

40 CFR 26.1125 Prior submission of proposed human research for EPA review

AHETF Protocol AHE55: Florida Citrus: April 7, 2008 

Any person or institution who intends to conduct or sponsor human research covered by §26.1101(a) shall, after receiving 

approval from all appropriate IRBs, submit to EPA prior to initiating such research all information relevant to the proposed 

research specified by §26.1115(a), and the following additional information, to the extent not already included:

Requirement Y/N Comments/Page Refs 

(1) Copies of 

• all research proposals reviewed by the IRB, 

• scientific evaluations, if any, that accompanied the proposals 

reviewed by the IRB, 

• approved sample consent documents, 

• progress reports submitted by investigators, and reports of injuries 

to subjects. 

Y 

n/a 

Y 

n/a 

V8:11-229; 231-273; 471-587 

V2:48-67 

(2) Minutes of IRB meetings . . . in sufficient detail to show 

• attendance at the meetings; 

• actions taken by the IRB; 

• the vote on these actions including the number of members voting 

for, against, and abstaining; 

• the basis for requiring changes in or disapproving research; 

• a written summary of the discussion of controverted issues and 

their resolution. 

Y 

Y 

Y 

N 

n/a 

V8:377-378; 647-650 

Basis for changes not shown 

No controverted issues 

(3) Records of continuing review activities. n/a 

(4) Copies of all correspondence between the IRB and the investigators. Y V8:4-10, 230, 274, 372-376, 

403, 438-445, 540, 589-90, 

652 

(5) ● A list of IRB members identified by name; earned degrees; 

representative capacity; indications of experience such as board 

certifications, licenses, etc., sufficient to describe each member’s 

chief anticipated contributions to IRB deliberations; 

• any employment or other relationship between each member and 

the institution, for example, full-time employee, a member of 

governing panel or board, stockholder, paid or unpaid consultant. 

N No list of IRB members was 

provided 

(6) Written procedures for the IRB in the same detail as described in 

§26.1108(a) and §26.1108(b). 

N Previously submitted to EPA 

under claim of confidentiality 

All information relevant to the proposed research specified by § 26.1115(a) 

(7) Statements of significant new findings provided to subjects, as required 

by §26.1116(b)(5). 

n/a 

(1) The potential risks to human subjects Y V2:11-19; 

(2) The measures proposed to minimize risks to the human 

subjects; 

Y V2:12-19 

(3) The nature and magnitude of all expected benefits of such 

research, and to whom they would accrue 

Y V2:19 

(4) Alternative means of obtaining information comparable to what 

would be collected through the proposed research; and 

Y Addressed in Governing 

Document V4 

§1125(a) 

a discussion of: 

(5) The balance of risks and benefits of the proposed research. Y V2:20 

§1125(b): All information for subjects and written informed consent 

agreements as originally provided to the IRB, and as approved by the IRB. 

Y V8:18-25, 379-437 

V2:48-103 

§1125(c): Information about how subjects will be recruited, including any 

advertisements proposed to be used. 

Y V1:40-41; V2:20-24, 28-30, 

105-107 

§1125(d): A description of the circumstances and methods proposed for 

presenting information to potential human subjects for the purpose of 

obtaining their informed consent. 

Y V2:22-24 

§1125(e): All correspondence between the IRB and the investigators or 

sponsors. 

The following Information, to the 

Y See page references above 

extent not already included: 

§1125(f): Official notification to the sponsor or investigator . . . that 

research involving human subjects has been reviewed and approved by 

an IRB. 

Y V8:375-376; 589-590 
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