Date: 

Subject: 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

December 4, 2015 

OFFICE OF CHEMICAL SAFETY 

AND POLLUTION PREVENTION 

Fluensulfone. Occupational and Residential Exposure Assessment for Proposed 

Uses on Golf Courses, Sports Fields, Commercial Areas, Sod Farms, and 

Residential Turfgrass and Lawns. 

PC Code: 050410 

Decision No.: 496677 

Petition No.: NA 

DP Ba rcode: 430164 

Registration No.: 53883-GL T 

Regulatory Action: Section 3 Registration 

Risk Assessment Type: Exposure Assessment Case No.: NA 

TXRNo.:NA CAS No.: 318290-98-1 

MRID No.: 49552503 40 CFR: 180.680 

From: 

Through: 

To: 

Introduction 

Zaida Figueroa, DrPH, Industrial Hygienist 

Risk Assessment Branch II 

Health Effects Division (7509P) 

Christina Swartz, Chief ~_}~ Risk Assessment Branch II 

Health Effects Division (7509P) 

and 11 

Kristin Rury, ExpoSAC Reviewe {j;;t~ Joshua Godshall, ExpoSAC Reviewer J7 

Exposure Science Advisory Committe{fExpoSAC) I HED 

Rita Kumar/Marianne Lewis/Meredith Laws 

Invertebrate and Vertebrate Branch 3 

Registration Division (7505P) 

The Registration Division (RD) requested that the Health Effects Division (HED) conduct an 

exposure and risk assessment for proposed uses of fluensulfone for nematode control on golf 

courses, sports fields, commercial areas, sod farms and residential lawns. This risk assessment 

addresses the potential occupational and residential exposures associated with the proposed uses. 

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

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

Page 1of37 
Page 2 of 37

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

Residential Exposure Task Force (ORETF) database; the Agricultural Reentry Task Force

(ARTF) database; the Residential SOPs (Turf SOP), and other registrant-submitted exposure 

monitoring studies (MRID No. 49552503). Some of these data are proprietary, and subject to the 

data protection provisions of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

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

(ExpoSAC) on November 19, 2015.
Page 3 of 37

Table of Contents

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

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

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

2.2 Label Recommendations from Occupational and Residential Assessment.......................... 7

2.3 Data Deficiencies and Requirements.................................................................................... 7

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

4.0 Use Profile .............................................................................................................................. 13

5.0 Residential Exposure and Risk Estimates............................................................................... 14

5.1 Residential Handler Exposure/Risk Estimates.................................................................... 14

5.2 Residential Post-application Exposure/Risk Estimates ...................................................... 17

5.3 Residential Risk Estimates for Use in Aggregate Assessment .......................................... 19

6.0 Non-Occupational Spray Drift Exposure and Risk Estimates................................................ 20

7.0 Non-Occupational Bystander Post-Application Inhalation Exposure and Risk Estimates..... 20

8.0 Occupational Exposure and Risk Estimates ........................................................................... 20

8.1 Occupational Handler Exposure/Risk Estimates................................................................ 20

8.2 Occupational Post-application Exposure/Risk Estimates................................................... 24

8.2.1 Occupational Post-application Inhalation Exposure/Risk Estimates........................... 24

8.2.2 Occupational Post-application Dermal Exposure/Risk Estimates............................... 24

Appendix A. Summary of Residential and Occupational Non-cancer Algorithms..................... 27
Page 4 of 37

1.0 Executive Summary

Fluensulfone [5-chloro-2-[(3,4,4-trifluoro-3-buten-1-yl)sulfonyl]thiazole] is a nematicide of the 

fluoroalkenyl group for the control of nematodes [e.g., control root-knot (Meloidogyne spp.), 

sting (Belonolaimus spp.), lance (Hoplolaimus spp.) and lesion nematodes (Pratylenchus spp.)]. 

The previous 2014 risk assessment evaluated fluensulfone as a new active ingredient for use on 

cucurbits and fruiting vegetables (D403814, Z. Figueroa, 7/18/2014). 

This document assesses the occupational and residential exposures and risks from the proposed

uses of fluensulfone on golf courses, sports fields, commercial areas, sod farms and residential 

lawns. This assessment includes the first proposed use of fluensulfone in residential settings

(i.e., turf/lawns). This document also evaluates the proposed residential scenarios for aggregate 

risk assessment.

Proposed Use Profile 

The proposed end-use (EP) granular product MCW2 1.5% (EPA Registration No. 53883-GLT

and alternate brand names: Quali-Pro® Nimitz® 1.5 G Nematicide or Quali-Pro® Nimitz PRO 

G Nematicide) may be applied broadcast overtop turfgrass at a maximum single application rate 

of 1.8 lb ai/A and may be applied as a rescue treatment to sod on sod farms using ground 

spreaders at a maximum application rate of 3.6 lb ai/A. Treated areas should be irrigated 

following applications in order to get the active ingredient into the root zone and soil. The 

proposed label requires handlers to wear long-sleeved shirt, long pants, shoes, socks, and 

chemical-resistant gloves. Rotation with nematicides with a different mode of action is 

suggested on the proposed label.

Exposure Profile 

Based on the proposed application rate and label information, only short- and intermediate-term 

dermal and inhalation exposures are expected for occupational handlers and post-application 

workers. Only short-term dermal and inhalation exposures are expected for use on turf/lawns by 

residential handlers. Short-term dermal residential post-application exposure is expected for 

adults, youth, and children from treated turf (i.e., golf course and residential lawns) and 

incidental oral post-application exposure is expected for children. Chronic exposure is not 

expected from the proposed use pattern.

Hazard Profile

HED has determined that the toxicology database for fluensulfone is complete and adequate to 

assess occupational/residential exposure. The short- and intermediate-term dermal points of 

departure (PODs) and short-term incidental oral POD are based on decreased body weight, 

increased mean hemoglobin concentration distribution width, and increased relative and absolute 

reticulocyte counts in both sexes, decreased prothrombin time in males, and increased platelets in 

females seen in the co-critical subchronic and chronic dog studies (no observed adverse effect 

level (NOAEL). The NOAEL of 3.1 mg/kg/day was selected for dermal risk assessment based 

on dose-spacing. The selected POD is applicable to incidental oral risk assessment since the 

effects were seen starting at week 6 in both studies and the lack of progression observed in the 

toxicity database. 
Page 5 of 37

For short- and intermediate-term inhalation risk assessment, a NOAEL could not be identified in 

the available subchronic inhalation toxicity study; therefore, an additional 10X uncertainty factor 

for the use of a LOAEL to extrapolate to a NOAEL was applied to short- and intermediate-term 

inhalation exposure scenarios. For purposes of estimating inhalation risk resulting from 

occupational and residential exposure, a portal of entry human equivalent concentration (HEC) 

and human equivalent dose (HED) were derived in accordance with standard methodology that 

results in a reduction in the interspecies uncertainty factor (UF) from 10X to 3X. The HEDs

determined for occupational inhalation risk assessment are 0.244, 0.491 and 0.853 mg/kg/day; 

the residential inhalation risk assessment HED is 0.164 mg/kg/day (see session 3.0 for HEC and 

HED calculations).

The Food Quality Protection Act (FQPA) safety factor was reduced to 1X based on the 

completeness of the toxicity database and no residual uncertainties concerning pre- or post-natal 

toxicity. In addition, the endpoints and doses chosen for risk assessment are protective of the 

qualitative susceptibility observed in the 2-generation reproduction study and the evidence of 

neurotoxicity observed in the acute neurotoxicity (ACN) study. The level of concern (LOC) for 

dermal exposure is equal to a margin of exposure (MOE) of 100, based on the combined 

interspecies (10X) and intraspecies (10X) uncertainty factors. The LOC for inhalation exposure 

is equal to a MOE of 300, based on the use of the lowest observed adverse effect level (LOAEL) 

to extrapolate a NOAEL (10X) and the combined interspecies (3X) and intraspecies (10X) 

uncertainty factors. Fluensulfone is classified as “Suggestive Evidence of Carcinogenicity” 

based on an increased incidence of alveolar/bronchiolar adenomas and carcinomas in the lung of 

mid- and high-dose female mice in the oncogenicity study. The EPA has determined that 

quantification of risk using a non-linear approach for fluensulfone will adequately account for all

chronic toxicity, including carcinogenicity that could result from exposure to fluensulfone.

Residential Exposure and Risk Assessment

There are residential handler and post-application exposure scenarios associated with the new 

proposed uses on treated turf. All residential handler and post-application exposure risk 

estimates were assessed using the single maximum application rate of 1.8 lb ai/acre and resulted 

in MOEs greater than their respective LOCs. The risk estimates are not of concern. 

Furthermore, all residential scenarios selected for the aggregate assessment resulted in MOEs 

greater than the LOC and are not of concern.

Occupational Exposure and Risk Assessment

No chemical-specific handler exposure data were submitted in support of this draft risk 

assessment; therefore, HED relied on the best available data to assess handler exposure. Default 

assumptions established by HED’s Science Advisory Council for Exposure (ExpoSAC) were 

used for parameters such as body weight and amount handled. All occupational handler 

scenarios for the proposed uses resulted in MOEs that are not of concern at some level of risk 

mitigation (e.g., baseline attire with no gloves and no respirator, or baseline attire with a PF5 

respirator). 

Occupational post-application dermal exposure and risk estimates resulted in MOEs that are 

≥100 and are not of concern. Fluensulfone is classified as Toxicity Category III via the dermal 

route and Toxicity Category IV for skin and eye irritation potential. The granular formulation is
Page 6 of 37

not a skin sensitizer. Short- and intermediate-term post-application risk estimates for workers 

conducting post-application activities on sod farms and golf courses (maintenance) were not a 

concern on Day 0 (following application) for all post-application activities. 

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

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

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

post-application inhalation exposure assessment for fluensulfone.

Human Studies Review

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

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

PHED 1.1; the ORETF database; the ARTF database; the Residential SOPs (Turf SOP); and 

other registrant-submitted exposure monitoring studies (MRID No. 49552503), are (1) subject to 

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

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

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

use, can be found at the Agency website1. 

2.0 Risk Assessment Conclusions and Recommendations

2.1 Summary of Risk Estimates

Residential

All residential handler exposure risk estimates were assessed using the single maximum 

application rate of 1.8 lb ai/acre and resulted in MOEs greater than their respective LOCs and not 

of concern. All residential post-application exposure scenarios as well as the risk estimates 

selected for the aggregate assessment resulted in MOEs greater than the LOC and are not of 

concern.

Occupational

All occupational handler scenarios for the proposed uses resulted in dermal risk estimates that 

are greater than the LOC of 100 at baseline level of risk mitigation (i.e., baseline attire with no 

gloves), and therefore, are not of concern. The inhalation risk estimates are higher than the LOC 

of 300 at baseline (i.e., no respirator) or using some level of mitigation (e.g., PF5 respirator). 

The following scenarios require a PF5 respirator to reach an inhalation MOE above the LOC of 

300:

• mixing/loading a granular formulation being applied using tractor-drawn spreader at an 

application rate of 1.8 lb ai/A (sod application rate),

• mixing/loading a granular formulation being applied using tractor-drawn spreader at an 

 1 http://www2.epa.gov/pesticide-science-and-assessing-pesticide-risks/occupational-pesticide-handler-exposure-data

and http://www2.epa.gov/pesticide-science-and-assessing-pesticide-risks/occupational-pesticide-post-applicationexposure
Page 7 of 37

application rate of 3.6 lb ai/A (sod rescue treatment application rate), and

• applying a granular formulation being applied using tractor-drawn spreader at an application 

rate of 3.6 lb ai/A (sod rescue treatment application rate).

All other inhalation MOEs ranged from 390 to 790 (LOC=300) with no respirator.

Occupational post-application dermal exposure and risk estimates resulted in MOEs that are 

≥100 and are not of concern. 

2.2 Label Recommendations from Occupational and Residential Assessment

Based on the occupational inhalation risk estimates, additional personal protective equipment 

(PPE) will be needed on the proposed label to protect occupational handlers (i.e., PF5 respirator).

2.3 Data Deficiencies and Requirements

A chemical-specific turf transferable residue (TTR) study (EPA MRID No. 49552503) is 

available for fluensulfone and it was used for this risk assessment. There are no data deficiencies

that would require submission of additional exposure data for this Section 3 action.

3.0 Hazard Characterization

The toxicity database for fluensulfone is complete for the purpose of assessing the proposed use

of fluensulfone. The primary effects in the toxicity database were changes in hematology 

parameters which were observed in rats, mice, and dogs following subchronic and chronic 

exposure. Other effects observed included changes in clinical chemistry parameters and 

decreased body weight in all three species. In addition to the effects above, fluensulfone caused 

lung toxicity following chronic dietary exposure in rats, but not mice or dogs. Fluensulfone also 

caused portal-of-entry effects in rats consisting of histopathological changes in the forestomach 

and pharynx following subchronic dietary exposure and in the epiglottis and nasal cavity 

following subchronic inhalation exposure.

There was no evidence of increased quantitative susceptibility in the developmental and 

reproduction studies as all effects in the pups were observed in the presence of maternal effects. 

However, there was increased qualitative susceptibility of pups in the 2-generation reproduction 

study. In this study, pup death was observed at the same dose causing decreased body weight in 

the parental generation. The endpoints and doses chosen for risk assessment are protective of the 

qualitative susceptibility observed in the 2-generation reproduction study and the evidence of 

neurotoxicity observed in the ACN study. Therefore, the FQPA safety factor was reduced to 1X 

based on the completeness of the toxicity database, there are no residual uncertainties concerning 

pre- or post-natal toxicity. 

Evidence of neurotoxicity was limited to findings in the acute neurotoxicity study. There was no 

evidence of immunotoxicity in the toxicity database. Fluensulfone and its major metabolites 

were determined to be non-mutagenic following a battery of genotoxicity studies. Fluensulfone 
Page 8 of 37

did result in an increased incidence of lung adenomas and carcinomas in female rats following 

chronic dietary exposure, however no tumors were observed in rats or dogs.

Fluensulfone is classified as “Suggestive Evidence of Carcinogenicity” based on an increased 

incidence of alveolar/bronchiolar adenomas and carcinomas in the lung of mid- and high-dose 

female mice in the oncogenicity study. Tumors were not observed in the rat chronic 

toxicity/carcinogenicity study in either sex or in male mice and mutagenicity is not of concern. 

The EPA has determined that quantification of risk using a non-linear approach for fluensulfone 

will adequately account for all chronic toxicity, including carcinogenicity that could result from 

exposure to fluensulfone.

Acute Toxicity

Testing in acute lethality studies with fluensulfone technical-grade material resulted in low 

toxicity classifications via the oral (Toxicity Category III), dermal (Toxicity Category III), and 

inhalation (Toxicity Category IV) routes of exposure. Fluensulfone technical-grade material was 

not an irritant to eyes (Toxicity Category IV) or skin (Toxicity Category IV) but was a skin 

sensitizer. Similar results were obtained in acute lethality studies with a granular formulation. 

The granular formulation was determined not to be a skin sensitizer. A summary of the acute 

toxicity of fluensulfone is presented in Table 3.1a and 3.1b.

Table 3.1a. Acute Toxicity Profile - Fluensulfone Technical. 

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

870.1100 Acute oral - rat 48574745 LD50 = 671 III

870.1200 Acute dermal - rat 48575035 LD50 > 2000 mg/kg III

870.1300 Acute inhalation - rat 48574748 LC50 > 5.1 mg/L IV

870.2400 Acute eye irritation - rabbit 48574750 Non-irritant IV

870.2500 Acute dermal irritation - rabbit 48574749 Non-irritant IV

870.2600 Skin sensitization - guinea pig 48574751 Sensitizer N/A

Table 3.1b. Acute Toxicity Profile - Fluensulfone Granular Formulations.

Guideline No. Study Type MRID(s) Results (from study 

report)

Toxicity Category

870.1100 Acute oral – rat, 15GR 49488603 LD50 > 2000 mg/kg III

870.1100 Acute oral – rat, 1.5GR 49488608 LD50 > 2000 mg/kg III

870.1200 Acute dermal – rat, 15GR 49488604 LD50 > 2000 mg/kg III

870.1300 Acute inhalation - rat waived - -

870.2400 Acute eye irritation – rabbit, 15GR 49488605 Non-irritant IV

870.2500 Acute dermal irritation – rabbit, 

15GR

49488606 Slightly irritating IV

870.2600 Skin sensitization – mice, 15GR 49488607 Not a sensitizer N/A
Page 9 of 37

Toxicological PODs Used for Risk Assessment

The chronic dietary study and a 90-day dietary study in dogs were chosen as co-critical studies 

for the short- and intermediate-term dermal endpoints. The NOAEL and LOAEL are derived 

from the chronic dog study based on the dose spacing. The NOAEL of 3.1 mg/kg/day was 

determined based on decreased body weight, increased mean hemoglobin concentration 

distribution width, and increased relative and absolute reticulocyte counts in both sexes, 

decreased prothrombin time in males, and increased platelets in females. While there was a 28-

day dermal study in the rat available which showed minimal toxicity, HED determined to use an 

oral study due to the high dermal absorption (58%) observed in vivo in rat studies using the 480 

EC formulation. Since dermal exposures to the formulation are expected to occur, the oral study 

with a dermal absorption factor was selected to assess dermal exposures.

For incidental oral exposure to children, HED also chose the co-critical dog studies. The two 

dog studies are appropriate for short-term exposure because the effects (hematology and clinical 

chemistry parameters) were seen starting at Week 6 in both studies and the lack of progression 

observed in the toxicity database (subchronic and chronic studies of all species had similar

NOAELs and LOAELs). The endpoint is protective of all effects observed in the database 

including the offspring effects observed in the 2-generation toxicity study in rats.

The short- and intermediate-term inhalation dose and endpoint for was selected from the 90-day 

inhalation study. Decreased weight loss, decreased thymus weight, and histopathological 

changes in the nasal cavity in males, prolonged prothrombin time in females, and 

histopathological changes in the epiglottis for both sexes were observed at the lowest dose tested 

of 0.04 mg/L. Since a NOAEL could not be identified in this study, an additional 10X 

uncertainty factor for the use of a LOAEL to extrapolate to a NOAEL was applied to short- and 

intermediate-term inhalation occupational exposure scenarios. The human equivalent 

concentrations (HECs) and the human equivalent doses (HEDs) were calculated using the 

methods and dosimetry equations described in EPA’s Reference Concentration (RfC) Guidance 

(1994) and OPP’s Guidance on the Application of the RfC Methodology (2014) for use in MOE 

calculations and presented in Table 3.2. 
Page 10 of 37

Table 3.2. Fluensulfone: HECs and HEDs: 90-day Subchronic Inhalation Study in Rats (MRID 49067003).

Short and 

intermediateterm 

Inhalation

Inhalation NOAEL = not 

identified

UFA= 3X

UFH =10X

UFL=10X

Residential and 

Occupational LOC 

for MOE = 300

Inhalation LOAEL = 0.04 

mg/L based on weight loss 

in males, prolonged 

prothrombin time in 

females, decreased thymus 

weight in males, 

histopathological changes 

in the epiglottis in both 

sexes, and 

histopathological changes 

in the nasal cavity of 

males.. 

Exposure Scenario HECs HEDs

Occupational 

Handler 

HECs and 

HEDs

Ventilation rate=8.3 L/min

0.00429 mg/L

0.244 mg/kg/day

Ventilation rate=16.7 L/min 0.491 mg/kg/day

Ventilation rate=29 L/min 0.853 mg/kg/day

Residential 

Handler 

HECs and 

HEDs

Handler 0.00572 mg/L 0.164 mg/L 

Although some of the toxicological effects for the dermal and inhalation exposure routes were 

similar (e.g., decrease body weight), these exposure routes are not combined in this assessment

because the inhalation POD is primarily based on portal of entry effects (D424168). Incidental 

oral and dermal routes of exposure are combined because the PODs for risk assessment are based 

on studies with the same toxicological effects.

A summary of the toxicological doses and endpoints for fluensulfone are summarized in Table 

3.3 below.

Table 3.3. Summary of Toxicological Doses and Endpoints for use in Residential and Occupational Human Health Risk 

Assessments for Fluensulfone.

Exposure/ 

Scenario

Point of Departure Uncertainty/ 

FQPA Safety 

Factors

Level of 

Concern for 

Risk 

Assessment

Study and Toxicological Effects

Acute Dietary 

(All 

Populations, 

including 

Infants and 

Children and 

Females 13-49 

years of age)

Offspring NOAEL= 16.2 

mg/kg/day 

UFA= 10x

UFH=10x

FQPA SF= 1x

Acute RfD = 

0.16 mg/kg/day

aPAD = 0.16 

mg/kg/day

2-generation reproduction – rat

Offspring LOAEL = 122.0 mg/kg/day based on 

an increase in pup loss between PND 1 and 4 in 

the F1 and F2 offspring with the majority of 

deaths occurring on day 2.
Page 11 of 37

Table 3.3. Summary of Toxicological Doses and Endpoints for use in Residential and Occupational Human Health Risk 

Assessments for Fluensulfone.

Exposure/ 

Scenario

Point of Departure Uncertainty/ 

FQPA Safety 

Factors

Level of 

Concern for 

Risk 

Assessment

Study and Toxicological Effects

Incidental Oral 

(Short-term)

NOAEL = 3.1 mg/kg/day UFA= 10x

UFH=10x

FQPA SF= 1x

Residential 

LOC for MOE 

= 100

Co-critical 90-day dog and chronic dog

Chronic: LOAEL = 16 mg/kg/day based on 

decreased body weight, increased mean 

hemoglobin concentration distribution width, 

and increased relative and absolute 

reticulocyte counts in both sexes, decreased 

prothrombin time in males and increased 

platelets in females.

Subchronic: NOAEL = 1.6 mg/kg/day LOAEL 

= 17.1 mg/kg/day based on decreased body 

weight in females and increased relative and 

absolute reticulocyte counts, decreased 

bilirubin, decreased albumin, decreased A/G 

ratio, increased TSH, and pigmented Kupffer 

cells in both sexes.

Dermal Shortand 

IntermediateTerm (1-30 

days and 1-6 

months)

NOAEL= 3.1 mg/kg/day

DAF = 9.5%

UFA=10x

UFH=10xFQP

A SF= 1x

Residential and 

Occupational 

LOC for MOE 

= 100

Co-critical 90-day dog and chronic dog

Chronic: LOAEL = 16 mg/kg/day based on 

decreased body weight, increased mean 

hemoglobin concentration distribution width, 

and increased relative and absolute 

reticulocyte counts in both sexes, decreased 

prothrombin time in males and increased 

platelets in females.

Subchronic: NOAEL = 1.6 mg/kg/day LOAEL 

= 17.1 mg/kg/day based on decreased body 

weight in females and increased relative and 

absolute reticulocyte counts, decreased 

bilirubin, decreased albumin, decreased A/G 

ratio, increased TSH, and pigmented Kupffer 

cells in both sexes.

Inhalation 

Short- and 

IntermediateTerm (1-30 

days and 1-6 

months)

NOAEL= not established 

(<0.04 mg/L)

b

HEC = 0.00429 mg/L

c

HED = 0.244 mg/kg/day 

(low breathing rate),

= 0.491 mg/kg/day

(medium breathing rate),

= 0.853 mg/kg/day

(high breathing rate)

= 0.164 mg/kg/day 

(medium breathing rate for 

residential handlers)

UFA=3x

UFH=10x

UFL=10x

FQPA = 1X

Residential and 

Occupational 

LOC for MOE 

= 300

90-day inhalation toxicity – rat

LOAEL = 0.04 mg/L (lowest dose tested) based 

on weight loss in males, prolonged prothrombin 

time in females, decreased thymus weight in 

males, histopathological changes in the 

epiglottis in both sexes, and histopathological 

changes in the nasal cavity of males. 

Cancer Classification: Suggestive evidence of carcinogenicity in humans based on lung tumors in female rats. The 

RfD is protective of potential cancer effects. 
Page 12 of 37

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

of extrapolation to determine risk associated with lower environmentally relevant human exposures. NOAEL = no observed adverse effect 

level. LOAEL = lowest observed adverse effect level. UF = uncertainty factor. UFA = extrapolation from animal to human (interspecies). UFH

= potential variation in sensitivity among members of the human population (intraspecies). UFL = use of a LOAEL to extrapolate a 

NOAEL. DAF = dermal absorption factor. MOE = margin of exposure. LOC = level of concern.

FQPA = 

b

HEC = rat NOAEL *(daily duration adjustment)*weekly daily duration adjustment*RDDR 

=0.04 mg/l *(6 hr/8 hr)*(1)*0.143 = 0.00429 mg/L. c

HED = HEC x human specific conversion factor x activity factor for the exposure scenario x daily duration.

= 0.00429 mg/L x 11.8 L/hr-kg x (0.6, 1.2, and 2.1 for activities assigned a breathing rate of 8.3, 16.7, and 29 L/min, respectively) x 8 hr.

Absorption: Based on in vivo dermal absorption observed in the rat and in vitro comparative 

rat:human absorption data, an estimated human dermal absorption factor (DAF) of 9.5% was 

obtained and used in the exposure assessment. The dermal absorption values from the in vivo

and in vitro studies were calculated based on dermal loadings of 90.2-98.0 μg/cm2

, reflecting 

typical concentrations recommended for the use in the field. Since the short- and intermediateterm inhalation PODs were based on route-specific toxicity studies, no absorption factors were 

necessary to estimate exposure.

Body Weight: The standard body weight for the general population (80 kg) was used for all adult 

exposure scenarios covered in this risk assessment since the endpoints selected were not from a 

developmental study and/or based on developmental or fetal effects. A body weight of 57 kg 

was used for youth 11 to <16 years old. Body weights of 32 kg and 11 kg were used for children 

6 to <11 years old and 1 <2 years old, respectively.
Page 13 of 37

4.0 Use Profile 

Fluensulfone [5-chloro-2-[(3,4,4-trifluoro-3-buten-1-yl)sulfonyl]thiazole] is a nematicide of the 

fluoroalkenyl group used to control nematodes [e.g., control root-knot (Meloidogyne spp.), sting 

(Belonolaimus spp.), lance (Hoplolaimus spp.) and lesion nematodes (Pratylenchus spp.)].

The proposed end-use (EP) granular product MCW2 1.5% (EPA Registration No. 53883-GLT

and alternate brand names: Quali-Pro® Nimitz® 1.5 G Nematicide or Quali-Pro® Nimitz PRO 

G Nematicide) may be applied broadcast overtop turfgrass at a maximum single application rate 

of 1.8 lb ai/A (3.6 lb ai/A per year) using typical ground spreaders (including tractors, rotary or 

drop spreaders). In addition, this EP could be applied as a one-time rescue treatment on sod at a 

maximum single application rate of 3.6 lb ai/A.

Treated areas should be irrigated following applications in order to get the active ingredient into 

the root zone and soil. The label recommends this product to be applied by a licensed applicator; 

however, it is not a restricted use product. Rotation with nematicides with a different mode of 

action is suggested.

The proposed label requires handlers to wear long-sleeved shirts, long pants, shoes, socks, and 

chemical-resistant gloves. 

Table 4.1. Summary of Directions for Use of Fluensulfone.

Applic. 

Timing, 

Type, and 

Equip.

Formulation 

[EPA Reg. No.]

Applic. Rate 

(lb ai/A)

Max. No. 

Applic. per 

Season

Max. 

Seasonal 

Applic. Rate 

(lb ai/A)

PHI 

(days) Use Directions and Limitations

Golf courses, sports fields, commercial areas, sod farms and residential lawns

Broadcast;

Ground 

spreaders 

MCW2 1.5%

[53883-GLT]

Granular; 

1.5% ai

0.9-1.8 

(0.00002066-

0.00004132 lb 

ai/ft2

)

1-4 

(depending 

on rate)

3.6 lb ai/A NA

Treated areas should be irrigated 

following applications in order to get the 

active ingredient into the root zone and 

soil.

May be applied at 0.9 lb ai/A - 1 month 

intervals for 4 consecutive months 

limited to 3.6 lb ai/A/year. 

May be applied at 1.2 lb ai/A for 1 month 

intervals for 3 consecutive months

limited to 3.6 lb ai/A/year.

May be applied at 1.8 lb ai/A in spring or 

early summer with a second application 

2-6 months following the initial broadcast 

application with a limit of 3.6 lb 

ai/A/year.

3.6 (for sod 

farms only as 

a rescue 

treatment)

1 3.6 lb ai/A NA

Rescue treatment. Broadcast application 

1-2 months prior to harvesting or cutting 

turfgrass sod.
Page 14 of 37

5.0 Residential Exposure and Risk Estimates

5.1 Residential Handler Exposure/Risk Estimates

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

application process. HED believes that there are distinct tasks related to applications and that 

exposures can vary depending on the specifics of each task. Residential handlers are addressed 

somewhat differently by HED as homeowners are assumed to complete all elements of an 

application without use of any protective equipment.

The proposed label recommends the end-use product to be applied by a licensed applicator; 

however, fluensulfone is not a restricted use pesticide and is not restricted to commercial areas. 

Therefore, there is potential for residential handler exposure. A quantitative exposure/risk 

assessment was developed for residential handlers based on the following scenarios applied 

broadcast: 

• Mixer/Loader/Applicator granules using a push-type rotary spreader;

• Mixer/Loader/Applicator granules using a belly grinder; and,

• Mixer/Loader/Applicator granules using a shaker can.

Since fluensulfone is to be applied broadcast, spoon and cup equipment as well as hand dispersal 

applications are not anticipated.

Residential Handler Exposure Data and Assumptions

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

handler risk assessments. Each assumption and factor is detailed below.

Application Rate: The proposed application rates are listed on Table 4.1. Refer to section 4.0 

for a complete use pattern description.

Unit Exposures and Area Treated: Unit exposure values and estimates for area treated or 

amount handled were taken from HED’s 2012 Residential SOPs2

.

Exposure Duration: Residential handler exposure is expected to be short-term in duration. 

Intermediate-term exposures are not likely because of the intermittent nature of applications by 

homeowners.

Residential Handler Non-Cancer Exposure and Risk Estimate Equations

The algorithms used to estimate exposure and dose for residential handlers can be found in the 

2012 Residential SOPs3.

Summary of Residential Handler Non-Cancer Exposure and Risk Estimates

 2 Available: http://www2.epa.gov/pesticide-science-and-assessing-pesticide-risks/standard-operating-proceduresresidential-pesticide 3 Available: http://www2.epa.gov/pesticide-science-and-assessing-pesticide-risks/standard-operating-proceduresresidential-pesticide
Page 15 of 37

The exposure and risk estimates for residential handler exposure are provided in Table 5.1.1. All 

estimated risks are above HED’s LOC for residential risk (dermal MOE ≥100 or inhalation MOE 

≥ 300) and are not of concern.
Page 16 of 37

Table 5.1.1. Residential Handler Non-cancer Exposure and Risk Estimates for Fluensulfone.

Exposure Scenario 

Dermal Unit 

Exposure 

(mg/lb ai)

Inhalation 

Unit Exposure 

(mg/lb ai)

Maximum 

Application 

Rate1

Area Treated or 

Amount Handled 

Daily2

Dermal Inhalation

Dose (mg/kg/day)3 MOE4 Dose (mg/kg/day)5 MOE6

Mixer/Loader/Applicator

Granules - Push-type rotary spreader 0.81 0.0026 1.8 lb ai/A 0.5 A 0.00087 3,600 0.000029 5,600

Granules – Belly grinder 360 0.039 0.00004132 lb 

ai/ft2 1,200 ft2 0.021 150 0.000024 6,800

Granules – Shaker can (surrogate 

granules with cup)

0.11 0.013 0.00004132 lb 

ai/ft2 100 ft2 0.00000054 5,700,000 0.00000067 240,000

1 Based on proposed label (EPA Reg. No. 53883-GLT). AR=1.8 lb ai/A (1 A/43,560 ft2)=0.00004132 lb ai/ft2.

2 Based on HED’s 2012 Residential SOPs (http://www2.epa.gov/pesticide-science-and-assessing-pesticide-risks/standard-operating-procedures-residential-pesticide).

3 Dermal Dose = Dermal Unit Exposure (mg/lb ai) × Application Rate (lb ai/acre or ft2) × Dermal Absorption Factor (9.5%) x Area Treated (A or ft2/day) ÷ Body Weight (80 kg).

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

5 Inhalation Dose = Inhalation Unit Exposure (mg/lb ai) × Application Rate (lb ai/acre or ft2) × Area Treated (A/day or ft2/day) ÷ BW (80 kg).

6 Inhalation MOE = Inhalation HED (mg/kg/day) ÷ Inhalation Dose (mg/kg/day). LOC=300.
Page 17 of 37

5.2 Residential Post-application Exposure/Risk Estimates

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

an environment that has been previously treated with fluensulfone. The quantitative 

exposure/risk assessment for residential post-application exposures is based on the following 

scenarios: 

• Dermal exposure for adults during high contact lawn activities, mowing turf and golfing;

• Dermal exposure for youth 11 < 16 years old during mowing turf and golfing;

• Dermal exposure for children 6 < 11 year old during golfing and 1 < 2 years old during 

high contact lawn activities; and,

• Incidental oral exposure (i.e., hand-to-mouth, object-to-mouth, soil ingestion and episodic 

granular ingestion) for children 1 < 2 years old.

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

Appendix in the 2012 Residential SOPs4

. While not the only lifestage potentially exposed for 

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

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

Residential Post-application Exposure Data and Assumptions

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

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

SOPs4

.

Application Rate: The proposed application rates are listed on Table 4.1. Refer to section 4.0 for 

a complete use pattern description.

A chemical-specific turf transferable residue (TTR) study (“Determination of Transferable 

Residues of Fluensulfone Turf Treated with MCW-2 1.5% GR Nematicide”, EPA MRID No. 

49552503) was used to assess post-application exposures from treated turf using a granular 

formulation. The study was reviewed by HED on June 29, 2015 (D425403, J. Godshall). The 

study summary reflects current policies and provide reliable information for residential turf use 

risk assessments. Based on the results from the TTR study, the half-life of fluensulfone on 

treated turf ranged from 1.8 to 12.4 days. The predicted day 0 residue value of 0.0022 ug/cm2

was from the New York site at an application rate of 3.6 lb ai/A (i.e., initial C0 right after 

application). A residue value of 0.0011 ug/cm2 was adjusted by the proposed maximum single 

application rate of 1.8 lb ai/A and was used to estimate residential post-application exposure and 

risk. 

Exposure Duration: Residential handler exposure is expected to be short-term in duration. 

Intermediate-term exposures are not likely because of the intermittent nature of applications by 

homeowners and the use directions (i.e., irrigation following applications in order to get the 

active ingredient into the root zone and soil). 

 4 Available: http://www2.epa.gov/pesticide-science-and-assessing-pesticide-risks/standard-operating-proceduresresidential-pesticide
Page 18 of 37

Characterization Granular Ingestion

Ingestion of granules is considered an episodic event and not a routine behavior. Because HED 

does not believe that this would occur on a regular basis, our concern for human health is related 

to acute poisoning rather than short-term residue exposure. Therefore, an acute dietary dose is 

used to estimate exposure and risk resulting from episodic ingestion of granules. For these same 

reasons, the episodic ingestion scenario is not recommended for inclusion in the aggregate 

assessment. 

Residential Post-application Non-Cancer Exposure and Risk Equations

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

the 2012 Residential SOPs5.

Combining Exposure and Risk Estimates

Since dermal and incidental oral exposure routes share a common toxicological endpoint, risk 

estimates have been combined for those routes. The incidental oral scenarios (i.e., hand-tomouth and object-to-mouth) should be considered inter-related and it is likely that they occur 

interspersed amongst each other across time. Combining these scenarios with the dermal 

exposure scenario would be overly-conservative because of the conservative nature of each 

individual assessment. Therefore, the post-application exposure scenarios that were combined 

for children 1 < 2 years old are the dermal and hand-to-mouth scenarios. This combination 

should be considered a protective estimate of children’s exposure.

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

The post-application exposure scenarios presented in Table 5.2.1 are considered protective of all 

the proposed residential uses. All residential post-application MOEs are above the LOC of 100 

and are not of concern, except for episodic granular ingestion for children (MOE=40 with 

LOC=100). However, the episodic oral ingestion of pellets is listed only as a poisoning scenario 

and its likelihood is diminished because the label instructs users to irrigated (“water-in”) treated 

areas following applications in order to get the product into the root zone and soil. 

Table 5.2.1. Residential Post-application Non-cancer Exposure and Risk Estimates for Fluensulfone.

Lifestage

Post-application Exposure 

Scenario Application 

Rate1

Dose 

(mg/kg/day)2 MOEs3

Combined Routes

(X indicates 

included in 

Combined MOE)

Combined 

MOEs Use Site Route of 

Exposure

Adult

Turf (High 

Contact 

Activities)

Dermal 1.8 lb ai/A 0.00039 7,900 N/A

Turf (Mowing 

Turf) Dermal 1.8 lb ai/A 0.0000072 430,000 N/A

Turf (Golfing) Dermal 1.8 lb ai/A 0.0000270 110,000 N/A

Youth 11 < 16 

old years old

Turf (Mowing 

Turf) Dermal 1.8 lb ai/A 0.0000082 380,000 N/A

Turf (Golfing) Dermal 1.8 lb ai/A 0.0000320 96,000 N/A

Children 6 < 

11 years old Turf (Golfing) Dermal 1.8 lb ai/A 0.0000378 82,000 N/A

 5 http://www2.epa.gov/pesticide-science-and-assessing-pesticide-risks/standard-operating-procedures-residentialpesticide
Page 19 of 37

Table 5.2.1. Residential Post-application Non-cancer Exposure and Risk Estimates for Fluensulfone.

Lifestage

Post-application Exposure 

Scenario Application 

Rate1

Dose 

(mg/kg/day)2 MOEs3

Combined Routes

(X indicates 

included in 

Combined MOE)

Combined 

MOEs Use Site Route of 

Exposure

Child 1 < 2 

years old

Turf (High 

Contact 

Activities)

Dermal 1.8 lb ai/A 0.0007695 4,000 X 3,700 Hand-to-Mouth 1.8 lb ai/A 0.0000747 41,000

Object-to-Mouth 1.8 lb ai/A 0.0000046 680,000 N/A

Soil Ingestion 1.8 lb ai/A 0.0000610 51,000 N/A

Episodic 

Granular 

Ingestion

1.8 lb ai/A 0.41 40 N/A

1. Based on proposed label (EPA Reg. No. 53883-GLT).

2. Dose (mg/kg/day) algorithms provided in 2012 Residential SOPs (http://www2.epa.gov/pesticide-science-and-assessing-pesticiderisks/standard-operating-procedures-residential-pesticide).

3. MOE = POD (mg/kg/day) ÷ Dose (mg/kg/day).

4. Combined MOE = 1 ÷ (1/dermal MOE) + (1/inhalation MOE) + (1/incidental oral MOE), where applicable.

5.3 Residential Risk Estimates for Use in Aggregate Assessment

Although dermal and inhalation exposures both resulted in similar clinical signs (e.g., decrease 

body weight), the inhalation endpoint selected for risk assessment was based on portal of entry 

effects since these effects resulted in lower Human Equivalent Concentrations (HECs) than the 

HEC for systemic effects. Therefore, the portal of entry HEC is protective of the systemic 

effects and the dermal and inhalation exposure estimates were not combined since the 

toxicological effects are different for these routes of exposure. 

The child dermal and oral routes of exposure have been combined as it is likely that they can 

occur simultaneously based on the use pattern and because the toxicological effects across these 

routes of exposure are the same. 

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

assessment for fluensulfone.

• The recommended residential exposure for use in the adult aggregate assessment reflects 

dermal exposure only from handler applications to turf via belly grinder spreader.

• The recommended residential exposure for use in the children 1<2 years old aggregate 

assessment reflects dermal and hand-to-mouth exposures from post-application exposure 

to outdoor turf/lawn applications (high contact activities).

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

Lifestage Exposure 

Scenario

Dose (mg/kg/day)1 MOE2

Dermal Inhalation Oral Total Dermal Inhalation Oral Total

Adult Turf 0.021 0.000029 N/A NA 150 5,600 N/A NA

Child 1 < 2 

years old

Turf (High 

Contact 

Activities)

0.0007695 N/A 0.0000747 0.0008442 4,000 N/A 41,000 3,700

1. Dose = the highest dose for each applicable lifestage of all residential scenarios assessed. Total = dermal + inhalation + incidental oral (where 

applicable). Dermal adult dose is from the residential handler belly grinder scenario. Inhalation adult dose is from push-type rotary spreader 

scenario. Both scenarios are listed in Table 5.1.1.

2. MOE = the MOEs associated with the highest residential doses. 
Page 20 of 37

6.0 Non-Occupational Spray Drift Exposure and Risk Estimates

Spray drift is a potential source of exposure to those nearby pesticide applications. This is 

particularly the case with aerial application, but, to a lesser extent, spray drift can also be a 

potential source of exposure from the ground application methods employed for fluensulfone. 

The agency has been working with the Spray Drift Task Force (a task force composed of various 

registrants which was developed as a result of a Data Call-In issued by EPA), EPA Regional 

Offices and State Lead Agencies for pesticide regulation and other parties to develop the best 

spray drift management practices (see the agency’s Spray Drift website for more information). 6

 

The agency has also developed a policy on how to appropriately consider spray drift as a 

potential source of exposure in risk assessments for pesticides. The potential for spray drift will 

be quantitatively evaluated for each pesticide during the Registration Review process which 

ensures that all uses for that pesticide will be considered concurrently. The approach is outlined 

in the revised (2012) Standard Operating Procedures For Residential Risk Assessment (SOPs) -

Residential Exposure Assessment Standard Operating Procedures Addenda 1: Consideration of 

Spray Drift. This document outlines the quantification of indirect non-occupational exposure to 

drift. 

7.0 Non-Occupational Bystander Post-Application Inhalation Exposure and Risk Estimates

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

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

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

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

March 2, 2010 (http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2009-0687-

0037). The agency has evaluated the SAP report and has developed a Volatilization Screening 

Tool and a subsequent Volatilization Screening Analysis 

(http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2014-0219). 

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

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

fluensulfone.

8.0 Occupational Exposure and Risk Estimates

8.1 Occupational Handler Exposure/Risk Estimates

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

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

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

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

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

manner specific to each application event. 

 6 Available: http://www2.epa.gov/reducing-pesticide-drift 
Page 21 of 37

Based on the anticipated use patterns and current labeling, types of equipment and techniques 

that can potentially be used, occupational handler exposure is expected from the proposed uses. 

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

following scenarios: 

• Mixing/loading granules for a tractor-drawn spreader;

• Applying granules using a tractor-drawn spreader;

• Loader/applicator granules using a belly grinder; and

• Loader/applicator granules using a rotary spreader.

Occupational Handler Exposure Data and Assumptions

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

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

Application Rate: The proposed application rates are listed on Table 4.1. Refer to section 4.0 for 

a complete use pattern description.

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

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

include PHED 1.1, the Outdoor Residential Exposure Task Force (ORETF) database, or other 

registrant-submitted occupational exposure studies. Some of these data are proprietary (e.g., 

AHETF data), and subject to the data protection provisions of FIFRA. The standard values 

recommended for use in predicting handler exposure that are used in this assessment, known as 

“unit exposures”, are outlined in the “Occupational Pesticide Handler Unit Exposure Surrogate 

Reference Table7

”, which, along with additional information on HED policy on use of surrogate 

data, including descriptions of the various sources, can be found at the Agency website8.

Area Treated or Amount Handled: The inputs for area treated were based on the Science 

Advisory Council for Exposure Policy 9.1: Standard Values for Daily Acres Treated in 

Agriculture (values are listed in Table 8.1.1). 

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

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

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

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

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

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

commercial applicators who may apply a product over a period of weeks (e.g., completing 

multiple applications for multiple clients within a region). 

 7 Available: http://www2.epa.gov/sites/production/files/2015-09/documents/handler-exposure-table-2015.pdf 8 Available: http://www2.epa.gov/pesticide-science-and-assessing-pesticide-risks/occupational-pesticide-handlerexposure-data
Page 22 of 37

Based on the proposed use pattern (i.e., 1-4 applications per year), short- and intermediate-term

exposures are expected for occupational handlers. In addition, the proposed label suggests to 

rotate the end-use product with nematicides with a different mode of action.

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

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

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

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

of PPE as necessary (e.g., PF5 respirator). The fluensulfone product labels direct mixers, 

loaders, applicators and other handlers to wear long-sleeved shirts, long pants, shoes, socks, and 

chemical-resistant gloves.

Occupational Handler Non-Cancer Exposure and Risk Estimate Equations

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

found in Appendix A.

Summary of Occupational Handler Non-Cancer Exposure and Risk Estimates

All occupational handler scenarios for the proposed uses resulted in dermal risk estimates that 

are greater than the LOC of 100 at baseline level of risk mitigation (i.e., baseline attire with no 

gloves), and therefore, are not of concern. The lowest dermal MOE is 140 (LOC=100) 

associated with loading/applying a granular formulation using belly grinder over 1 acre. All 

other dermal MOEs were higher ranging from 660 to 4,300 (LOC=100). 

The inhalation risk estimates are higher than the LOC of 300 at baseline (i.e., no respirator) or 

using some level of mitigation (e.g., PF5 respirator). The following scenarios require a PF5 

respirator to reach an inhalation MOE above the LOC of 300:

• mixing/loading a granular formulation being applied using tractor-drawn spreader at an 

application rate of 1.8 lb ai/A (sod application rate) over up to 80 acres,

• mixing/loading a granular formulation being applied using tractor-drawn spreader at an 

application rate of 3.6 lb ai/A (sod rescue treatment application rate) over up to 80 acres, and

• applying a granular formulation being applied using tractor-drawn spreader at an application 

rate of 3.6 lb ai/A (sod rescue treatment application rate) over up to 80 acres.

All other inhalation MOEs ranged from 390 to 790 (LOC=300) at baseline (i.e., no respirator).
Page 23 of 37

Table 8.1.1. Occupational Handler Non-Cancer Exposure and Risk Estimates for Fluensulfone.

Exposure Scenario Crop or Target

Dermal Unit 

Exposure (μg/lb ai)1

Inhalation Unit 

Exposure (μg/lb ai)1 Maximum

Application 

Rate2

Area 

Treated 

Daily3

Dermal Inhalation

Mitigation Level Mitigation Level Dose 

(mg/kg/day)4

MOE5

(LOC=100)

Dose 

(mg/kg/day)6

MOE7

(LOC=300)

Mixer/Loader

Tractor-drawn 

spreader

Golf course 8.4 [Baseline] 1.7 [Baseline] 1.8 lb ai/A 40 A 0.000718 4,300 0.00153 560

Tractor-drawn 

spreader

Sod

(Typical Application)

8.4 [Baseline] 1.7 [Baseline] 1.8 lb ai/A 80 A0.00144 2,200 0.00306 280

8.4 [Baseline] 0.34 [PF5 respirator] 0.00144 2,200 0.000613 1,400

Sod

(Rescue Treatment)

8.4 [Baseline] 1.7 [Baseline]

3.6 lb ai/A 80 A

0.00287 1,100 0.00613 140

8.4 [Baseline] 0.34 [PF5 respirator] 0.00287 1,100 0.00122 700

Applicator

Tractor-drawn 

spreader

Golf course 9.9 [Baseline] 1.2 [Baseline] 1.8 lb ai/A 40 A 0.000847 3,700 0.00108 790

Tractor-drawn 

spreader

Sod

(Typical Application)

9.9 [Baseline] 1.2 [Baseline] 1.8 lb ai/A 80 A 0.00170 1,800 0.00216 390

Sod

(Rescue Treatment)

9.9 [Baseline] 1.2 [Baseline]

3.6 lb ai/A 80 A 0.00338 920

0.00433 200

0.24 [PF5 respirator] 0.000864 990

Loader/Applicator

Belly grinder

Landscaping, turf 

(lawns, athletic fields, 

parks)

10,000 [Baseline] 62 [Baseline]

1.8 lb ai/A 1 A 0.0214 140 0.0014 610

Rotary spreader

Golf course, 

Landscaping, turf 

(lawns, athletic fields, 

parks)

440 [Baseline] 10 [Baseline]

1.8 lb ai/A 5 A 0.0047 660 0.00113 430

1 Based on the “Occupational Pesticide Handler Unit Exposure Surrogate Reference Table” (September, 2015); Level of mitigation: Baseline, PPE (PF5 Respirator).

2 Based on registered or proposed label (EPA Reg. No. 53883-GLT).

3 Exposure Science Advisory Council Policy #9.1.

4 Dermal Dose = Dermal Unit Exposure (μg/lb ai) × Conversion Factor (0.001 mg/μg) × Application Rate (lb ai/acre) × Area Treated Daily (A/day) × DAF (9.5%) ÷ BW (80 kg).

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

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

7 Inhalation MOE = Inhalation HED (mg/kg/day) ÷ Inhalation Dose (mg/kg/day). LOC=300.
Page 24 of 37

8.2 Occupational Post-application Exposure/Risk Estimates

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

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

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

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

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

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

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

8.2.1 Occupational Post-application Inhalation Exposure/Risk Estimates

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

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

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

pesticides. The agency sought expert advice and input on issues related to volatilization of 

pesticides from its Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel 

(SAP) in December 2009, and received the SAP’s final report on March 2, 2010 

(http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPP-2009-0687-0037). The agency 

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

subsequent Volatilization Screening Analysis 

(http://www.regulations.gov/#!docketDetail;D=EPA-HQ-OPP-2014-0219). During Registration 

Review, the agency will utilize this analysis to determine if data (i.e., flux studies, route-specific 

inhalation toxicological studies) or further analysis is required for fluensulfone.

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

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

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

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

8.2.2 Occupational Post-application Dermal Exposure/Risk Estimates

Occupational Post-application Dermal Exposure Data and Assumptions

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

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

basis.

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

days to six months as intermediate-term. Based on the proposed use pattern (i.e., 1-4 

applications per year), short- and intermediate-term exposures are expected. In addition, the 

proposed label suggests to rotate the end-use product with nematicides with a different mode of 

action.
Page 25 of 37

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

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

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

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

known as “transfer coefficients”, are presented in the ExpoSAC Policy 39

” which, along with 

additional information about the ARTF data, can be found at the Agency website10. Table 

8.2.2.1 provides a summary of the anticipated post-application activities and associated transfer 

coefficients for the proposed crops/use sites.

Table 8.2.2.1. Anticipated Post-Application Activities and Dermal Transfer Coefficients.

Proposed Crops

Policy Crop 

Group 

Category

Crop 

Height

Foliage 

Density

Transfer 

Coefficients 

(cm2/hr)

Activities

Sod/Turf Turf/Sod Low Full 6,700 Maintenance, Harvesting, Slab

Transplanting/Planting

Golf Course Turf/Sod Low Full 2,500 Maintenance (greens only)

3,700 Maintenance

Application Rate: Application Rate: The proposed application rates are listed on Table 4.1. 

Refer to section 4.0 for a complete use pattern description.

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

Turf Transferable Residues: A chemical-specific turf transferable residue (TTR) study 

(“Determination of Transferable Residues of Fluensulfone Turf Treated with MCW-2 1.5% GR 

Nematicide”, EPA MRID No. 49552503) was used to assess post-application exposures from 

treated using a granular formulation. The predicted day 0 residue value of 0.0022 ug/cm2 was 

from the New York site at an application rate of 3.6 lb ai/A and it was used to estimate 

occupational post-application dermal exposure and risk for sod farms (rescue treatment only). A 

residue value of 0.0011 ug/cm2 adjusted by the proposed maximum single application rate of 1.8 

lb ai/A was used to estimate occupational post-application exposure and risk for sod/turf (typical 

application) and golf courses. 

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

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

workers can be found in Appendix A.

Occupational Post-application Non-Cancer Dermal Risk Estimates

A summary of the post-application dermal exposure and risk estimates from use of fluensulfone 

on treated sod/turf is provided in Table 8.2.2.2. Post-application dermal exposure and risk 

estimates resulted in MOEs greater than 100 and are not of concern. 

 9 Available: http://www2.epa.gov/sites/production/files/2015-08/documents/exposac-policy-3-march2013.pdf 10 Available: http://www2.epa.gov/pesticide-science-and-assessing-pesticide-risks/occupational-pesticide-postapplication-exposure
Page 26 of 37

Table 8.2.2.2. Occupational Post-application Non-Cancer Exposure and Risk Estimates for Fluensulfone.

Crop/Site Activities Transfer Coefficient 

(cm2/hr) TTR1 Dermal Dose (mg/kg/day)2 MOE3

Short- and Intermediate-term

Sod Farm 

(Rescue Treatment) Maintenance, 

Harvesting, Slab

Transplanting/Planting

6,700

0.0022 0.000032 25,000

Sod Farm/Turf

(Typical Application) 0.0011 0.000064 49,000

Golf Course

Maintenance (greens 

only) 2,500 0.0011 0.000024 130,000

Maintenance 3,700 0.0011 0.000035 88,000

1. Predicted TTR at initial concentration (t0) = 0.0022 ug/cm2 at 3.6 lb ai/A or 0.0011 ug/cm2 at 1.8 lb ai/A from chemical-specific study (EPA 

MRID No. 49552503).

2. Daily Dermal Dose = [TTR (μg/cm2

) × Transfer Coefficient × 0.001 mg/μg × 8 hrs/day × dermal absorption (9.5%)] ÷ BW (80 kg).

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

Restricted Entry Interval

Fluensulfone is classified as Toxicity Category III via the dermal route and Toxicity Category IV 

for skin and eye irritation potential. The granular formulation is not a skin sensitizer. Short- and 

intermediate-term post-application risk estimates for sod farms and golf courses (maintenance) 

were not a concern on Day 0 (following application) for all post-application activities. 
Page 27 of 37

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

Residential Handler Dermal and Inhalation Exposure Algorithms

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

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

handled in a day, using the equation below:

E = UE * AR * A

where:

E = exposure (mg/day);

UE = unit exposure (mg/lb ai);

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

A = area treated or amount handled (e.g., ft2

/day or A/day).

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

D = E *AF / BW

where:

D = dose (mg/kg-day);

E = exposure (mg/day);

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

BW = body weight (kg).

Residential Post-application Dermal Exposure Algorithm – Physical Activities on Turf

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

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

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

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

E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day);

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

);

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

TC = transfer coefficient (cm2

/hr); and

ET = exposure time (hr/day).
Page 28 of 37

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

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

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

formula:

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

where:

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

AR = application rate (lbs ai/ft2 or lb ai/acre);

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

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

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

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

CF3 = area unit conversion factor (1.08 x 10-3 ft2

/ cm2 or 2.47 x 10-8 acre/cm2).

Dermal absorbed doses are calculated as:

BW

E AF D* =

where:

D = dose (mg/kg-day);

E = exposure (mg/day);

AF = absorption factor (dermal); and

BW = body weight (kg).

Table A.1. Turf (Physical Activities) -- Inputs for Residential Post-application Dermal Exposure.

Algorithm Notation Exposure Factor

(units) Point Estimate(s)

AR Application rate

(mass active ingredient per unit area) 1.8 lb ai/A

F

Fraction of AR as TTR 

following application (if 

chemical-specific data is 

unavailable)

L/WP/WDG 0.01

Granules 0.002

FD

Daily residue dissipation 

(if chemical-specific data 

is unavailable)

(fraction)

L/WP/WDG 0.1

Granules 0.1

TC

Transfer 

Coefficient 

(cm2

/hr)

L/WP/WDG

Adults 180,000

Children 1 < 2 years old 49,000

Granules Adults 200,000

Children 1 < 2 years old 54,000

ET Exposure Time

(hours per day)

Adults 1.5

Children 1 < 2 years old 1.5
Page 29 of 37

Table A.1. Turf (Physical Activities) -- Inputs for Residential Post-application Dermal Exposure.

Algorithm Notation Exposure Factor

(units) Point Estimate(s)

BW Body Weight

(kg)

Adults 80

Children 1 < 2 years old 11

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

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

Turf

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

the SHEDS-Multimedia model):

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

(Freq_HtM/N-Replen))]

where:

E = exposure (mg/day);

HR = hand residue loading (mg/cm2

);

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

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

ET = exposure time (hr/day);

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

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

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

and

SA * 2

Fai *DE

HR

H

hands =

where:

HR = hand residue loading (mg/cm2);

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

study (unitless);

DE = dermal exposure (mg); and

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

Dose, normalized to body weight, is calculated as:

BW

E D =

where:
Page 30 of 37

D = dose (mg/kg-day);

E = exposure (mg/day); and

BW = body weight (kg).

Table A.2. Turf (Physical Activities) – Inputs for Residential Post-application Incidental Oral Hand-toMouth Exposure. 

Algorithm 

Notation

Exposure Factor

(units) Point Estimate(s)

Faihands

Fraction of ai on hands 

from dermal transfer 

coefficient study

(unitless)

Liquid formulations 0.06

Granular formulations 0.027

DE Dermal exposure (mg) Calculated

SAH

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

2 years old 150

AR Application rate

(mass active ingredient per unit area) 1.8 lb ai/A

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

FM

Fraction hand surface area mouthed

(fraction/event) 0.127

N_Replen Replenishment intervals per hour

(intervals/hr) 4

ET Exposure time 

(hrs/day) 1.5

SE Saliva extraction factor

(unitless) 0.48

Freq_HtM Hand-to-mouth events per hour

(events/hr) 13.9

BW Body Weight

(kg)

Children 1 < 2 years 

old 11

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

Turf

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

in SHEDS-Multimedia):

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

(Freq_OtM/N_Replen))]

where:

E = exposure (mg/day);

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

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

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

ET = exposure time (hr/day);

N_Replen = number of replenishment intervals per hour (intervals/hour);
Page 31 of 37

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

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

and

OR = AR * FO * CF2 * CF3

where:

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

AR = application rate (lbs ai/ft2 or lb ai/acre);

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

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

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

Dose, normalized to body weight, is calculated as:

BW

E D =

where:

D = dose (mg/kg-day);

E = exposure (mg/day); and

BW = body weight (kg).

Table A.3. Turf (Physical Activities) – Inputs for Residential Post-application Object-to-Mouth 

Exposure. 

Algorithm 

Notation

Exposure Factor

(units) Point Estimate(s)

AR Application rate (to turf)

(mass active ingredient per unit area) 1.8 lb ai/A

FO Fraction of AR as OR following application 1 0.01

SAMO

Surface area of object mouthed 

(cm2/event) 10

N_Replen Replenishment intervals per hour (intervals/hour) 4

SEO

Saliva extraction factor

(fraction) 0.48

ET Exposure time 

(hours per day) 1.5

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

BW Body Weight (kg) Children 1 < 2 years old 11 1 This SOP assumes that all of the residue on the turf could be transferred to the object (e.g., object residue is 

equal to turf transferable residue).

Residential Post-application Incidental Soil Ingestion Exposure Algorithm– Physical 

Activities on Turf
Page 32 of 37

Exposure from incidental soil ingestion is calculated as follows:

E = SRt * SIgR * CF1

where:

E = exposure (mg/day);

SRt = soil residue on day "t" (μg/g);

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

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

and

SRt = AR * FS * (1-FD)

t * CF2 * CF3 * CF4

where:

SRt = soil residue on day "t" (μg/g);

AR = application rate (lbs ai/ft2 or lb ai/acre);

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

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

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

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

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

CF4 = soil volume to weight unit conversion factor (0.67 cm3

/g soil).

Dose, normalized to body weight, are calculated as:

BW

E D =

where:

D = dose (mg/kg-day);

E = exposure (mg/day); and

BW = body weight (kg).

Table A.4. Turf (Physical Activities) – Inputs for Residential Post-application Incidental Soil Ingestion 

Exposure. 

Algorithm 

Notation

Exposure Factor

(units) Point Estimate(s)

AR Application rate

(mass active ingredient per unit area) 1.8 lb ai/A

FS Fraction of AR available in uppermost 1 cm of soil

(unitless) 1

FD

Daily residue dissipation

(fraction) 0.1

SIgR Soil ingestion rate (mg/day) 50
Page 33 of 37

Table A.4. Turf (Physical Activities) – Inputs for Residential Post-application Incidental Soil Ingestion 

Exposure. 

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

Residential Post-application Dermal Exposure Algorithm – Mowing

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

follows:

E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day);

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

);

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

TC = transfer coefficient (cm2

/hr); and

ET = exposure time (hr/day).

and

TTRt = AR * FAR * (1-FD)

t * CF2 * CF3

where:

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

);

AR = application rate (lbs ai/ft2 or lb ai/acre);

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

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

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

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

CF3 = area unit conversion factor (1.08 x 10-3 ft2

/cm2 or 2.47 x 10-8 acre/cm2).

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

BW

E AF D

* =

where:

D = dose (mg/kg-day);

E = exposure (mg/day); 

AF = absorption factor (dermal); and

BW = body weight (kg).
Page 34 of 37

Table A.5. Turf (Mowing) – Inputs for Residential Post-application Dermal Exposure. 

Algorithm Notation Exposure Factor

(units) Point Estimate(s)

AR Application rate

mass active ingredient per unit area 1.8 lb ai/A

FAR

Fraction of AR as 

TTR following 

application

L/WP/WDG 0.01

Granules 0.002

FD

Daily residue 

dissipation

L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient

(cm2

/hr)

Adult 5,500

Children 11 < 16 years 

old 4,500

ET Exposure time 

(hours per day) 1

BW Body Weight 

(kg)

Adults 80

Children 11 < 16 years 

old 57

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

Residential Post-application Dermal Exposure Algorithm – Golfing

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

E = TTRt * CF1 * TC * ET

where:

E = exposure (mg/day); 

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

);

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

TC = transfer coefficient (cm2

/hr); and

ET = exposure time (hr/day).

and

TTRt = AR * F * (1-FD)

t * CF2 * CF3

where:

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

AR = application rate (lbs ai/ft2 or lb ai/acre);

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

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

t = post-application day on which exposure is being assessed;
Page 35 of 37

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

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

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

BW

E AF D* =

where:

D = dose (mg/kg-day);

E = exposure (mg/day); 

AF = absorption factor (dermal); and

BW = body weight (kg).

Table A.6. Turf (Golfing) – Inputs for Residential Post-application Dermal Exposure. 

Algorithm 

Notation

Exposure Factor

(units)

Point Estimate(s)

AR Application rate

(mass active ingredient per unit area)

1.8 lb ai/A

F Fraction of AR as TTR 

following application

L/WP/WDG 0.01

Granules 0.002

FD Daily residue dissipation L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient

(cm2/hr)

Adult 5,300

Children 11 < 16 years old 4,400

Children 6 < 11 years old 2,900

ET Exposure time

(hours per day)

Pesticides used on greens, tees, 

and fairways 

4

Pesticides used only on greens 

and tees

1

BW Body Weight

(kg)

Adults 80

Children 11 < 16 years old 57

Children 6 < 11 years old 32

NA = not applicable

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

Occupational Non-cancer Handler Algorithms

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

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

where:

E = exposure (mg ai/day),

UE = unit exposure (μg ai/lb ai),

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

A = area treated or amount handled (e.g., A/day, gal/day).
Page 36 of 37

The daily doses are calculated using the following formula:

ADD= 

E * AF

BW

where:

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

E = exposure (mg ai/day),

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

BW = body weight (kg).

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

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

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

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

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

MOE= 

POD

ADD

where:

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

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

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

Occupational Non-cancer Post-application Algorithms

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

following formulas:

E=TC * TTR t

* ET * 0.001 mg

ug

where:

E = exposure (mg ai/day),

TC = transfer coefficient (cm2/hr),

TTRt = turf transferable residue on day “t” (μg/cm2), and

ET = exposure time (hours/day).

The daily doses are calculated using the following formula:
Page 37 of 37

ADD= 

E * AF

BW

where:

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

E = exposure (mg ai/day),

AF = absorption factor (dermal), and

BW = body weight (kg).

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

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

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

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

MOE values are calculated using the following formula:

MOE= 

POD

ADD

where:

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

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

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