Acetamiprid DP No.: 372626

Page 1 of 14 UNITED STATES ENVIRONMENTAL PROTECTI ON AGENCY WASHINGTON, D.C. 20460

OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES Jan 1 4 , 2010 MEMORANDUM SUBJECT: Acetamiprid : Revised Human Health Risk Assessment for Proposed Food Use s

on Clov er Grown for Seed , Small Vine Climbing Fruits, except Fuzzy Kiwifruit, Subgroup 13 - 07F, Greenhouse Grown Tomatoes and Tea . PC Code: 099050 DP Barcode: D 372626 Decision No.: 408298 Registration No s . : 8033 - 23, 8033 - 36, 8033 - 94 Petition No.: 9E7544 Regulatory Action: Amended Section 3 Risk Assessment Type: Single Chemical Aggregate Case No.: N/A T XR No.: N/A CAS No.: 135410 - 20 - 7 MRID No s .: N/A 40 CFR: §180.578 FROM: Dennis McNeill y, Chemist

Registration Action Branch 2 Health Effects Division (7509 P ) THROUGH: Christina Swartz, Branch Chief

Richard Loranger, Ph . D . , Senior Scientist Registration Action Branch 2 Health Effects Division (7509 P ) TO: Laura Nollen, Risk Manager Reviewer

Barbara Madden, Team Leader (RM Team 5) RIMUE RB/Registration Division (RD) (7505P)Page 2 of 14 Table of Contents 1.0 Executive Summary ................................ ................................ ................................ ................................ 3 2.0 Summary of Toxicological Doses and Endpoints for Use in Human Risk Assessments .............. 5 3.0 Dietary Exposure/Risk Characterization ................................ ................................ ......................... 6 4.0 Residential (Non - Occupational) Exposure/Risk Characterization ................................ ............... 9 4.1 Residential Handler Exposure ................................ ................................ ................................ 10 4.2. Residential Postapplication Exposure ................................ ................................ .................... 10 5.0 Aggregate Risk Assessments and Risk Characterization ................................ ............................. 12 5.1 Acute Term Aggregate Risk ................................ ................................ ................................ .. 12 5.2 Short - and Intermediate - Term Aggregate Risk ................................ ................................ ...... 12 5.3 Chronic - Term Aggregate Risk ................................ ................................ ............................... 13 6.0 Data Needs and Label Recommendations ................................ ................................ ..................... 13 References: ................................ ................................ ................................ ................................ .................... 13Page 3 of 14

1.0 E xecutive Summary This memorandum serves to revise HED’s human health risk assessment for acetamiprid (D. McNei lly , D369474, 12/1/09). RD has requested that HED redo the dietary exposure anal ys es using 100% percent crop treated for amended use patterns, i.e., grapes and other crop subgroup 13 - 07F commodities, and tomatoes. This memorandum revaluates the acute and chronic dietary risk and exposure s, and updates the aggregate exposure and risk based on the revised chroni c dietary exposure assessment. The dietary

assessment is partially

refined, using field trial data, percent crop - treated values , and various empiri cal processing factors. Estimated drinking water concentrations (EDWCs) , which are based upon the highest application values of all registered and proposed uses, have been incorporated directl y into the dietary exposure model. A cute and chronic dietary risk estimates for all population subgroups do not indicate a risk of concern . Acute dietary exposure estimates at the 99.9 th percentile are below HED’s level of concern for the general U . S . population and all other population subgroups. For the U . S . population, the estimated exposure of 0.0 2 4 mg/kg/day corresponds to 2 4 % aPAD; for children 1 - 2 years old, the estimated exposure of 0.0 4 3 mg/kg/day corresponds to an acute dietary risk of 4 3 % aPAD. Chronic dietary exposure to acetamiprid, including existing and proposed uses, is below HED’s level of concern for the U . S . population and all other population subgroups. For the general US population, an estimated exposure of 0.00 2 8 mg/kg/day

corresponds to 4 % of the chronic population adjusted dose (cPAD); child ren 1 - 2 years old were the highest exposed population subgroup, with an estimate of 0.0 1 0 mg/kg/day , or 15 % cPAD. Risks for all population subgroups are less than 100% cPAD, and are not of concern. Aggregate risk assessment s for acute, short - term , and chronic durations w ere conducted. Residential exposures incorporat ed into the aggregate assessments are based on currently registered residential uses (indoor crack and crevice , and outdoor perimeter treatment) . All aggregate assessments indicate no risks of concern ( aggregate MOEs ≥ 270 ) . Environmental Justice Considerations Potential areas of environmental justice concerns, to the extent possible, were considered for this human health risk assessment, in accordance with US Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and L ow - Income Populations, http://www.eh.doe.gov/oepa/guidance/justice/eo12898.pdf . As a part of every

pesticide ri sk assessment, OPP considers a large variety of consumer subgroups according to well - established procedures. In line with OPP policy, HED estimates risks to population subgroups from pesticide exposures that are based on patterns of that subgroup’s food and water consumption, and activities in and around the home that involve pesticide use in a residential setting. Extensive data on food consumption patterns are compiled by USDA under the CSFII, and are used in pesticide risk assessments for all registere d food uses of a pesticide. These data are anal yz ed and categorized b y subgroups based on age, season of the year, ethnic group, and region of the country. Whenever appropriate, non - dietary exposures based on home use of pesticide products, associated ri sks for adult applicators and for toddlers, youths, and adults entering or playing on treated areas post - application are evaluated. Further considerations are currently in development as OPP has committed resources andPage 4 of 14

expertise to the development of spec ialized software and models that consider exposure to by standers and farm workers as well as lifestyle and traditional dietary patterns among specific subgroups. Review of Human Research This risk assessment relies in part on data from studies in which adult human subjects were intentionally exposed to a pesticide or other chemical. These studies, which comprise the Pesticide Handlers Exposure Database (PHED), have been determined to require a review of their ethical conduct, and have received that review. The studies in PHED were considered appropriate (or ethically conducted) for use in risk assessments .Page 5 of 14

2.0 Summary of Toxicological Doses and Endpoints for Use in Human Risk Assessments The following table was labeled as table 3.5.11 in HED’s Dec 1, 2009 review (D369474, D. McNeilly). Itis included here to c onfirm that end - points have not changed since that recent review and also for eas y reference. Table 3.5 .11a . Summary of Toxicological Doses and Endpoints of Acetamiprid for Use in Dietary and Non - Occupational Hum an Health Risk Assessment Exposure Scenario Dose Used in Risk Assessment Uncertainty

Factors/FQPA Safety Factors RfD, PAD Level

of Concern for Risk Assessment Study and Toxicological Effect Acute Dietary (All populations) NOAEL = 10 mg/kg/day UF A = 10x

UF H = 10x FQPA SF = 1x aPAD = 0.10 mg/kg/day Developmental Neurotoxicity in rat LOAEL = 45 mg/kg/day based on decreased body weight and body wei ght gains in offspring, decreased early pup survival on PND 0 - 1, and decreased startle response on PND 20/60 in males. Acute Neurotoxicity Study in rat LOAEL = 30 mg/kg/day based on decreased locomotor activity Chronic Dietary all populations NOAEL = 7.1 mg/kg/day UF A = 10x

UF H = 10x FQPA SF = 1x cPAD = 0.071 mg/kg/day Chronic Toxicity/Oncogenicity Study in rats LOAEL = 17.5 mg/kg/day based on decreased body weight and body weight gains in females and hepatocellular vacuolation in males. Short - and Intermediate Term Incidental Oral (1 - 30 days and 1 - 6 mo.) NOAEL = 10 mg/kg/day UF A = 10x

UF H = 10x FQPA SF = 1x LOC for MOE = 100 Developmental Neurotoxicity in rat LOAEL = 45 mg/kg/day based on decreased body weight and body weight gains in offspring, de creased early pup survival on PND 0 - 1, and decreased startle response on PND 20/60 in males. Short - and Intermediate - term Dermal (1 - 30 days, 1

– 6 mo.) NOAEL = 10 mg/kg/day DAF = 10% UF A = 10x

UF H = 10x FQPA SF = 1x LOC for MOE = 100 Developmental Neurotoxicity in rat LOAEL = 45 mg/kg/day based on decreased body weight and body weight gains in offspring, decreased early pup survival on PND 0 - 1, and decreased startle response on PND 20/60 in males. Short - and Intermediate - term Inhalation (1 - 30 days, 1

– 6 mo.) NOAEL = 10 mg/kg/day IAF = 100% UF A = 10x

UF H = 10x FQPA SF = 1x LOC for MOE = 100 Developmental Neurotoxicity in rat LOAEL = 45 mg/kg/day based on decreased body weight and body weight gains in offspring, decreased early pup survival on PND 0 - 1, and decreased startle response on PND 20/60 in males. Cancer (oral, dermal, inhalation) - not likely to be carcinogenic to humans. DAF = dermal absorption factor. Point of Departure (POD) = A data point or an estimated point that is derived from observed dose - response data and used to mark the beginning of extrapolation to determine risk associated with lower environmentally relevant human exposures. NOAEL = no observed adverse effect level. LO AE L = lowest observed adverse effect level. UF = uncer tainty factor. UF A = extrapolation from animal to human (interspecies). UF H = potential variation in sensitivity among members of the human population (intraspecies). FQPA SF = FQPA Safety Factor. PA D = population adjusted dose (a = acute, c = chronic) . RfD = reference dose. MOE = margin of exposure. LOC = level of concern. N/A = not applicable.Page 6 of 14

3 .0 Dietary Exposure/Risk Characterization Acute and chronic dietary risk assessments were conducted f or acetamiprid using the Dietary Exposure Evaluation Model (DEEM - FCID  , Version 2 . 0 3) which use s food consumption data from the USDA’s Continuing Survey s of Food Intakes by Individuals (CSFII, 1994 - 1996 and 1998). The acute and chronic dietary analy s e s ar e considered partially refined by

the inclusion of percent crop treated values and processing data. The full dietary anal ys is for the subject petition can be found in the HED memorandum : Acetamiprid . Revised Acute and Chronic Dietary Exposure Assessment s to Support Section 3 Registration of Uses on Clover, Small Vine Climbing Fruits, except Kiwifruit, Subgroup 13 - 07F, Greenhouse Grown Tomatoes and Tea . D 372890 , 1 / 1 4 / 10 , D. McNeilly . The current acute and chronic dietary exposure assessments include exi sting uses and the tolerances proposed b y the Interregional Research Project Number 4 (IR - 4) for new uses of acetamiprid on clover grown for seed, small vine climbing fruits, except kiwifruit, subgroup 13 - 07F (amending established grape uses), greenhouse - grown tomatoes , and tea. For the acute dietary

assessment, f

ield trial residues were refined when possible . If field trial residues were reported below the limit of quantification (LOQ), HED assumed 1⁄2 LOQ (i.e., 0.005 ppm). In certain cases where it was appropriate, HED translated field trial data from one commodity

to another (e.g., peaches to nectarines, or plum to apricots). Percent crop treated estimates, which exist for only several of the subject crops (apples, broccoli, celery , lettuce, pears, gra pefruit, oranges, peppers, and spinach), were incorporated into the dietary assessment s as a refinement. 100% crop treated was assumed for both grapes and tomatoes, since these commodities are involved in the label use amendments. Average percent crop treated values for commodities were applied to the chronic dietary assessment, and maximum percent crop treated values were applied to the acute dietary assessment. Processing factors based on submitted studies were incorporated into the acute dietary anal ys e s for the following commodities: apple juice, orange juice, grape fruit juice, raisins, dried prunes, and tomato puree. For all other commodities included in the acute assessment, the DEEMTM Version 7.87 default processing factors were used. Those default factors were used for all processed commodities in the chronic assessment except for grape juice, and raisins ( dried prunes and tomato paste h ave separate tolerance s ) . Finall y, t o lerance level residues were also used for livestock commodities. Usage Data In order to refine the dietary exposure estimates for acetamiprid, HED requested a Screening Level Usage Anal ys is (SLUA), which was conducted by the Biological and Economic Anal y sis Division (BEAD), 6/11/09. The SLUA includes estimates of maximum %CT for the acute assessment and average %CT for determining chronic exposure (Table 3.0 ) . Commodities with the most significant acetamiprid usage in terms of maximum %CT include pears (60%), apples (30%), celery

(45%), and lettuce (20%). Commodities with the most significant usage in terms of lbs ai applied include apples (10,000), cotton (20,000), and pears (5,000).Page 7 of 14

Table 3.0 . Percent Crop Treated Data Used in DEEM Comm odity Avg Max Apples 20 30 Broccoli 5 1 5 Cabbage 5 10 Cauliflower 10 1 5 Celery 25 45 Cotton 5 5 Grapefruit 2.5 5 1 Lemons 5 100 Lettuce 10 20 Oranges 2.5 5 Peaches 1 2.5 Pears 35 60 Peppers 2.5 5 Potatoes 2.5 2. 5 Pum pkins 1 2.5 Spinach 5 15 Squash 2 .5 2.5 1 - The residue distribution file for oranges which used 5% CT wa s also used for grapefruit . This was higher than the 2.5% CT for grapefruit e s timated by BEAD and is more conservative. For the acute anal ys is, %CT was incorporated into RDFs. Fo r the chronic analysis, average %CT was included for the commodities listed in the table above. 3.1 Exposure and Risk Characterization The dietary

anal ys es reflect all currently registered and proposed acetamiprid uses and indicate that both the acute and chronic dietary exposure do not present a risk concern for HED for the general U.S. population o r any of population subgroup (Table 3.1 ) . HED incorporated EDWCs directly into the DEEMTM FCID model for “water, direct, all sources” and “water, indirect, all sources.” For the acute assessment, an EDWC of 20.1 ppb was entered into the model, and for the chronic assessment, the value of 4.9 ppb was used. Acute Dietary

(Food and Drinking Water) Exposure Results and Characterization The probabilistic acute dietary exposure assessment included anticipated residues from field residue trials, processing factors, maximum %CT estimates (for existing uses only) generated by the Biological and Economic Analy sis Division (BEAD), and the modeled peak concentration of acetamiprid residues in surface water sources of drinking water. 100 %CT was assumed for grapes, tomatoes , and crops where % crop treated information was not available. Although the acute assessment has been refined, the resulting exposure estimates are still consideredPage 8 of 14

conservative since field trial data were the basis for the anticipated residues, and because a lower tier drinking water model (FIRST) was used to estimate residues in drinking water. Acute dietary

exposure estimates at the 99.9 th percentile are below HED’s level of concern for the general US population and all other population subgroups. For the US population, the estimated exposure of 0.0 2 4 mg/kg/day corresponds to 2 4 % aPAD; for children 1 - 2 years old, the estimated exposure of 0.0 4 3 m g/kg/day corresponds to an acute dietary risk of 4 3 % aPAD. Chronic Dietary (Food and Drinking Water) Exposure Results and Characterization For the chronic anal ys is, tolerance - level residues were assumed for all food commodities with existing and proposed acetamiprid tolerances. Percent crop treated was used for many commodities as detailed in Table 3.0 . The chronic anal ys is also included the modeled surface water annual average residue in drinking water. Even though %CT information was used in the chro nic analy sis, the exposure and risk estimates are still conservative since tolerance level residues were used, because 100 %CT was assumed for crops where % crop treated information was not available, and because a lower tier drinking water model (FIRST) w as used. Chronic dietary

exposure to acetamiprid, including existing and proposed uses, is below HED’s level of concern for the U . S . population and all other population subgroups. For the general U . S . population, and estimated exposure of 0.0 02 8 mg/kg/day corresponds to 4 % of the chronic population adjusted dose (cPAD); children 1 - 2 years old were the highest exposed population subgroup, with an estimate of 0.0 1 0 mg/kg/day , or 15 % cPAD. Risks for all population subgroups are less than 100 % cPAD, and are not of concern.Page 9 of 14 Table 3.1. Summ ary of Dietary (Food + Water) Exposure and Risk for Acetamiprid Population Subgroup Ac ute Dietary (99.9 th Percentile) Chronic Dietary Dietary Exposure (mg/kg/day) % aPAD Dietary Exposure (mg/kg/day) % cPAD General U .S. Population 0.023768 24 0.002835 4.0 All Infants (< 1 year old) 0.031227 31 0.005206 7.3 Children 1 - 2 years old 0.042928 43 0.010358 15 Children 3 - 5 years old 0.034282 34 0.007296 10 Children 6 - 12 years old 0.024123 24 0.004055 5.7 Youth 13 - 19 year s old 0.017682 18 0.002170 3.1 Adults 20 - 49 years old 0.015543 16 0.002031 2.9 Adults 50+ years old 0.013291 13 0.002130 3.0 Females 13 - 49 years old 0.013133 13 0.002057 2.9 3 .2 Cancer Dietary Risk HED has classified acetamiprid as “not likely to be carcinogenic to humans.” Based upon this classification, HED has determined there is no cancer risk associated with the existing and proposed uses. 4 .0 Residential (Non - Occupational) Exposure/Risk Characterization The registrant has not proposed new or revised residential use s . Therefore, new residential handler and postapplication exposure assessments were not conducted . Acetamiprid is registered for controlling a wide vari ety of indoor and outdoor insect pests in residential settings. The MOEs for residents applying bait and gel products were 1500 - 3500 (D303171, T. Moriarty, 10/25/07). In a more recent assessment of exposures t o residential handlers from products used on indoor and outdoor residential settings, the risks were found to be not of concern for all scenarios identified (D353040, Z. Figueroa, 12/1/08). An anal ys is of the postapplication risks to adults and children from contacting treated areas ha s also been performed recentl y (D353012, C. Swartz, 12/12/08) . Inthe tables below, only the risk to children are shown since as noted in the 12/12/08 memo they

are the worse case versus those for adults.Page 10 of 14

Table 4 a . Acetamiprid: Short - and Intermediate - Term Postappli cation Exposures and Risks to Toddlers Following Turf Treatments in Residential Settings. 1 Exposure Scenario Application Rate (lb AI/acre) Exposure (mg/kg/day) MOE 2

Short - term Interm. term Sh ort - term Interm. term Residential turf (dermal) 0.187 0.0072 0.0036 1,400 2,800 Hand to mouth (oral) 0.0028 0.0013 3,600 7,600 Object to mouth (oral) 0.00069 NA 14,500 NA Incidental s oil i ngestion (oral) 0.0000093 NA 1,100,000 NA Total e xposur e (dermal & oral) N/A 0.0107 0.0049 900 2,000 1. From C . Swartz, D353012, 12/12/08. 2. Short - & intermediate - term dermal or oral NOAEL (10 mg/kg/day)/exposure (mg/kg/day). TABLE 4 b : Acetamiprid: Short - term Postapplication Exposure and Risk to Toddle rs Following Indoor Crack and Crevice Treatments 1 Exposure Scenario Descriptor Exposure (mg/kg/day) MOE 2 Dermal exposure Carpet and hard surfaces 0.0195 510 Incidental oral exposure 0.0065 1500 Total dermal & oral exposures 0.026 380 1. From C . Sw artz, D353012, 12/12/08. 2. Short - & intermediate - term dermal or oral NOAEL (10 mg/kg/day)/exposure (mg/kg/day). Aggregate exposures of acetamiprid include the short - and interm ediate - term postapplication exposures following turf treatment and the short - term postapplication exposure following indoor crack and crevice treatment. 4 .1 Residential Handler Exposure The MOEs for residents app lying bait and gel products were 1500 - 3500 (D303171, T. Moriarty, 10/25/07). Ina recent assessment of exposures to residential handlers from products used on indoor and outdoor residential settings, the risks are not of concern for all applicable scenari os identified (D353040, Z. Figueroa, 12/1/08). 4 .2. Residential Postapplication Exposure An evaluation of postapplication exposure resulting from the proposed use and label change was completed (D353040, Z. Figueroa, 12/1/08 and D366701, S . Oonnithan , 10/ 9 /09 ); risks were not of concern for any of the scenarios identified and assessed. Detailed discussions of the assumptions and methods used for assessing residential exposure from the proposed use are provided in the 12/1/08 memorandum. The postapplication scenarios assessed for toddlers’ exposure following perimeter treatment include:Page 11 of 14

 Dermal e xposure from treated l awns due to h igh c ontact l awn activities;  H and - to - mouth transfer of p esticide residues on l awns ;  O bject - to - mouth transfer of p esticide residues on lawns; and  Incidental ingestion of s oil from p esticide - treated r esidential areas. Risks for these scenarios are provided in Table 4 .2a. Table 4 .2a . Short - and Intermediate - Term Dermal & Indire ct Ingestion - Toddler Residential Risk Estimates for Postapplication Exposure on Turf Exposure Scenario Route of

Exposure Application

Rate (lb ai/acre) Dermal Transfer

Coefficient (μg/cm2 ) Absorbed Dose (mg/kg/day) MOE Residential Turf Dermal 0.187 5,2 00 (Short- term) 0.0072

(Short- term) 1,400 2,600 (Intermediate - term) 0.0036

(Intermediate - term) 2,800 Hand to Mouth Oral NA 0.0028 (Short- term) 3,600 0.0013 (Intermediate - term) 7,600 Object to Mouth Oral NA 0.00069 14,500 Incidental Soil Inge stion Oral NA 0.0000093 1,100,000 Combined Exposure 1 N/A N/A N/A 0.0107 1 (Short- term) 900 1 0.00 49 1 (Intermediate - term) 2 , 00 0 1 1 - Com bined exposure is the sum of dermal and oral exposures. Table 4 .2b summarizes the postapplication exposure and risk for toddlers resulting from contact with carpet and hard surfaces following c rack and crevice application of F4688 50 W P Insecticide/Termiticide on indoor surfaces. The bolded values represent the exposure to be aggregated with exposure from food and drinking water.

TABLE 4 .2b : Postapplication Exposure and Risk Following Indoor Crack / Crevice Treatm ent . Scenario Descriptor Daily Dose (mg/kg/day) MOE Dermal Exposure Carpet and Hard Surfaces 0.0195 510 Incidental Oral Exposure Carpet and Hard Surfaces 0.0065 1500 Combined Dermal Incidental Oral Exposure Carpet and Hard Surfaces 0.0260 380Page 12 of 14

5 .0 Aggregate Risk Assessments and Risk Characterization Consistent with FQPA, HED consider s ag gregate risk to a pesticide from the three major routes (dermal, oral, and inhalation) when potential residential exposures exist . In its acetamiprid aggregate assessment, HED combined dietary (food + water) and non - dietary (residential) exposure sources to obtain an estimated aggregate exposure. When aggregating exposures and risks from various sources, HED considers both the route and duration of exposure. Based upon the residential use pattern of acetamiprid products, HED has determined that acute, sh ort - term, intermediate - term and chronic aggregate risk assessments are appropriate. 5 .1 Acute Term Aggregate Risk The acute aggregate risk is equal to the acute dietary exposure via food and drinking water , and th erefore is identical to the exposure and risk characterization found in Section 3.1 . The acute aggregate risks for acetamiprid are less than 100 % of the aPAD for all population subgroups and , therefore , do not pose a risk concern for HED. 5 .2 Short- and Intermediate - Term Aggregate Risk Short - term aggregate risk is based on the chronic (average) dietary exposure (food + water) combined with short - term residential exposure. Intermediate - term aggregate risk is based on the chronic (average) dietary exposure combined with intermediate - term residential exposure. Short - and intermediate - term aggregate risks for residential handlers were assessed previously by T. Moriarty (see Table 15, D303171, 10/25/07 ). The aggregate MOEs for two adult populations (20 - 49 years; 50+ ye ars) were 900 to 930. Since the dietary exposure estimates are now more refined due to the greater use of percent crop treated, these aggregate risks would be even lower and are not of c oncern. For short - term and intermediate - term aggregate risks, the combined chronic dietary (food + water) exposure is combined with short - and intermediate - term residential postapplication exposures for toddlers. The combined food, water and residential exposures are then compared to the dose for risk assessment to determine the resulting margin of exposure (MOE). HED has updated the dietary

component (food and water) in this assessment. Inthe case of acetamiprid, all short - and intermediate - term risk assessments are based on the effects observed in the DNT study , and therefore exposures from dermal and oral routes have been combined. See Table 5 .2 for a summary

of short - and intermediate - term aggregate risks for toddlers.Page 13 of 14

TABLE 5 .2 : Acetamiprid Sho rt - and Interm ediate - Term Aggregate Exposure and Risk for Toddlers . Scenario Combined

Dermal/Oral Exposure (mg/kg/day) 1 Chronic Food Exposure Food (mg/kg/day) 2 Aggregate Exposure (mg/kg/day) 3 MOE 4 Indo or Exposure Crack and Crevice Treatment (short - term) 0.0260 0.010 358 0.0 3 6 4 270 Turf Exposure (short - term) 0.0107 0.010 358 0.0 211 470 Turf Exposure (intermediate - term) 0.00 49 0.010 358 0.01 53 650 1. Com bined d ermal and oral exposures were taken from D3 66701 , S . Oonnithan , 10/9 /0 9 . 2. Chronic food exposure does not change with each scenario; see Table 5.2.2 . 3. Aggregate exposure = Combined dermal/oral exposure + chronic food exposure. 4. MOE = NOAEL/Aggregate Exposure = 10 (mg/kg/day)/aggregate exposure (mg/kg/day). Short - and intermediate - term aggregate risks (MOEs) are not of concern . HED notes that the lowest aggregate MOE of 270 is based on the indoor use. The MOEs calculated for exposure from turf are higher, but are considered to be more conservative, becaus e the intended use pattern does not include broadcast treatment of lawns, but has been assessed as such in order to be protective. Adult aggregate risks due to postapplication exposure have not been assessed since the toddler risks are the worst case. 5 . 3 Chronic - Term Aggregate Risk The dietary

exposure pathway (food and drinking water) is the onl y source of chronic exposure to acetamiprid ( i.e., 180 consecutive day s or more ). Therefore, the chronic aggregate exp osure and risk estimates are equivalent to the chronic di etary exposure and risk estimate s discussed in Section 3.1 above . The chronic aggregate risks for acetamiprid are less than 100% of the cPAD for all population subgroups and , do not pose a risk conc ern for HED. 6 .0 Data Needs and Label Recommendations The data needs and labels recommendations remain unchanged since the Dec 1, 2009 memo randum (D369474, D. McNeill y).

References: Acetamiprid . Revised Acute and Chronic Dietary Exposure Assessments (Food and Drinking Water) to Support Section 3 Registration of Uses on Clover, Small Vine Climbing Fruits, exceptPage 14 of 14

Kiwifruit, Subgroup 13 - 07F, Greenhouse Grown Tomatoes and Tea. D 372890 , 01/ 1 4 /10, D. McNeilly . Acetamiprid: Human Health Risk Assessment for Proposed Food Uses on Clover Grown for Seed, Small Vine Climbing Fruits, except Kiwifruit, Subgroup 13 - 07F, Greenhouse Grown Tomatoes and Tea . . D 369474 , 12 / 01 / 09 , D. McNeilly .