### D a t e:

S ubje c t: UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

03-MAR-2016 OFF I CE OF CHE MICAL SAFETY

AND POLLUTION PREVENTION



### Bcnsulide. Occupational and R esidential Exposure Assessment in Support of

R egistra ti on Review

P C Code: 00980 I

D

ec i s ion No.: 507866

P et iti on No.: NA DP Bar co d e: 0428877

R eg i s tr at i o n No.: NA

R eg ul ato r y Ac ti on: Registration

Review

Ri s k Assess m e nt T y p e: Occupationa l/ Residential Expo s ure Assessment

T XR No.: NA Case No.: 2035

CAS No.: 741-58-2

40 CF R : 180

. 241 MRID No.: NA



### F r om:

Th r ough:

To :

Introduction Alexa ndra Gavelek, Biolo g i s t

# /L**~** 

# { / t \,

# ~ Kelly M. Lowe, E n v ironm e nt af

## Sc**nti ··** **~~** Risk Assessment Branch Y / VII

_,, . 

## 0

v 

### Health Effects Division (7509P)

Michael Metzger, Branch Chief ' 

# J /} 

# !} ) N

Risk Assessment Branch YNII 

## L 1 ( 

# k (- tl 'v· { •

Health Effects Division (7509 P ) 

## f

and

Bridgett Bobowiec

# 'Pl**~** J ennifer Tyler**~""/< ~**  

### Exposure Science Advisory Committee (ExpoSAC) 

### I H ED

Margaret H a th away 

### I Kevin Costel l o
Pesticide Re-evaluation Di vision (7508P)

The Pesticide Re-Evaluation Division (PRO) requested that the H ea lth Effects Division (HED)

conduct an ex p osure and risk assessment for bensulide as part of r egistration review.

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

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

Page I of 4 1

### including Pesticide Handl e r s Expos ure Databa se Version I. I 

### (PHED I

. I) ; 

### the Agricultural

Handl er Exposure Ta sk Force (A HETF) database; the Outdoor R esident ial Exposu r e Task For ce (ORE TF ) database; the Agricultura l Reentry Task Force (A RTF) database; and the Residential

SOPs ( turf SOP). Some of these data are proprietary

, and subject to the data protect i on provisions of the Federal In secticide, Fungicide, and R odenticide Act (FIFRA).

Note: 

### T hi s memorandum was r eviewe d by the Exposure Sc i e nc e Advisory Com mittee (ExpoSAC) on October I

, 2015.

Page 2 of 41Page 3 of 41 

### Table of Contents

1.0 Executive Summary

................................ ................................ ................................ .................. 4

2.0 Risk Assessment Conclusions and Recommendations

................................ ............................. 5 2.1 Summary of Risk Estimates

................................ ................................ ................................ .. 5 2.2 Data Deficiencies and Requirements

................................ ................................ .................... 6

3.0 Hazard Characterization

................................ ................................ ................................ ............ 6

4.0 Use Profile

................................ ................................ ................................ ................................ 9 5.0 Residential Exposure and Risk Estimates

................................ ................................ ............... 11 5.1 Residential Handler Exposure/Risk Estimates

................................ ................................ .... 11

5.2 Residential Post

- app lication Exposure/Risk Estimates

................................ ...................... 14 5.3 Residential Risk Estimates for Use in Aggregate Assessment

................................ ........... 17

6.0 Non

- Occupational Spray Drift Exposure and Risk Estimates

................................ ................ 17

7.0 Non

- Occupational Bystander Post

- Application Inhalation Exposure and Risk Estimates

..... 22

8.0 Occu pational Exposure and Risk Estimates

................................ ................................ ........... 22 8.1 Occupational Handler Exposure/Risk Estimates

................................ ................................ 22 8.2 Occupational Post

- application Exposure/Risk Estimates

................................ ................... 28 8.2.1 Occupational Post

- application Inhalation Exposure/Risk Estimates

........................... 28 8.2.2 Occupational Post

- application Dermal Exposure/Risk Estimates

............................... 28 Appendix A. Summary of Occupational and Residential Non

- cancer Algorithms

..................... 31Page 4 of 41



### 1.0 Executive Summary

The Pesticide Re

- Evaluation Division (PRD) requested that the Health Effects Division (HED) conduct an exposure and risk asses sment for bensulide as part of Registration R eview. Bensulide is an organophosphate herbicide; its mode of toxic action in mammals is the inhibi tion of the cholinesterase (ChE) enzyme. Bensulide is used for weed control in residential and occupational settings. Bensulide can be applied to vegetable crops, golf courses, and residential

turf.

OPs exhibit a phenomenon known as steady

- state AChE inh ibition. After repeated dosing at the same dose level, the degree of inhibition comes into equilibrium with the production of new, uninhibited enzyme. At this point, the amount of AChE inhibition at a given dose remains

consistent across duration. As su ch, t he endpoints focus on acute (single

- day) effec ts and steady

state effects. For this assessment, the duration of exposure is assumed to be steady

- state and the toxicological endpoints are based on cholinesterase inhibition.

The e xisting residential uses of bensulide on residential turf and golf courses have been reassessed to reflect updates to HED’s Residential SOPs. Residential handler risk estimates for applying liquid and granule products to residential lawns are of concern at currently labeled use

rates. For residential handlers, a total aggregated risk index (ARI) was used since the LOCs for dermal exposure (1000) and inhalation exposure (3000) are different. The target ARI is 1; therefore, ARIs of less than 1 are risk estimates of concern. Residential post

- application risk

estimates for turf uses were assessed using chemical

- specific turf transferable residue (TTR) data for a liquid formulation, and accounting for the difference in toxicity between the parent, bensulide, and the oxon (i.e., by applying a 50x toxicity adjustment factor). Risk estimates are of concern for dermal exposure for adults and children conducting high exposure activities on treated turf; for dermal exposure for adults and youths golfing; for hand

- to

- mouth exposure for children on treated turf; and for episodic granule ingestion exposure.

A spray drift assessment was completed; spray drift risk estimates are based on an estimated deposited residue concentration as a result of the screening level agricultural applicatio n scenarios

. Risk estimates related to spray drift are of concern at various distances from the edge of the field for adults and children (1 to <2 years) dependin g on the spray drift scenario. For adults, the screening level scenario indicates the LOC is exceeded at a distance of less than 25

feet for application to vegetables and less than 75 feet for application s to golf courses . For children, the screening level scenario indicates the LOC is exceeded at a distance of 75 feet for application to vegetabl es and less than 150 feet for application to golf courses . Drift reduction technologies, such as using coarser sprays and lowering boom height for groundboom sprayers, reduces risk concerns; however

, there are still risk estimates of concern at the field e dge in some

cases

.

Occupational handler risk estimates were calculated for the registered uses on golf courses, turf, and vegetable crops

. Different personal protective equipment ( PPE ) are required based on formulations and target crops. With the label

- required PPE, all handler risk estimates are of

concern. Even with the addition of maximum PPE or engineering controls, many occupational

handler risk estimates remain of concern.Page 5 of 41



### Since bensulide is applied to vegetables as a preplant or preemergence ap plication only, occupational post

- application dermal exposure are not anticipated for these uses. Occupational

post

- application risk estimates were assessed for worker exposure to bensulide and bensulide

oxon during maintenan ce activities on golf courses. R isk estimates were of concer n (i.e., MOEs are < 1,000) until 5 days after treatment. The Worker Protection Statement interim REI is 12 hours; t his is the REI listed on the proposed labels, and is considered protective of post

application exposure. Howe ver, there were risk estimates of concern related to golf course maintenance activities; therefore, HED is recommending that the REI for golf courses be revised

on the label to address those concerns.

Based on the Agency's current practices, a quantitative non

- cancer occupational post

- application inhalation exposure assessment was not performed for bensulide 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 bensulide

.

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 AHETF database; the Outdoor Residential Exposure Task Force (ORETF) database; the ARTF database; and the Residential SOPs ( Turf SOP)

, 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, ca n be found at the Agency website 1



### .

2.0 Risk Assessment Conclusions and Recommendations

2.1 Summary of Risk Estimates

Residential handler risk estimates for applying liquid and granule products to residential lawns are of concern at currently labeled use rates. Residential post

- application risk estimates for turf uses were also of concern; Risk estimates are of concern f or dermal exposure for adults and children conducting high exposure activities are treated turf; for dermal exposure for adults and youths golfing; for hand

- to

- mouth exposure for children on treated turf; and for episodic granule ingestion exposure.

Risk estimates related to spray drift are of concern at various distances from the edge of the field for adults and children (1 to <2 years) dependin g on the spray drift scenario. For adults, the screening level scenario requires a distance of 25 feet for appl ication to vegetables and 75 feet for application to golf courses . For children, the screening level scenario requires a distance of

75 feet for application to vegetables and 150 feet for application to golf courses . Drift reduction

1 http://www.epa.gov/pesticides/science/handler

- exposure

- data.html and http://www.epa.gov/pesticides/science/post

- app

- exposure

- data.htmlPage 6 of 41



### technologies, such as using coarser sprays and lowering boom height for groundboom sprayers, reduces risk concerns; however there are still risk estimates of concern at the field edge in some

cases

.

Occupational handler risk estimates were calculated for the registered uses on golf courses, turf, and vegetable crops. With the label

- required PPE, all handler risk estimates are of concern. Even with applying maximum PPE or engineering controls, many occupational handler risk estimates

are of concern.

Occupational post

- applic ation risk estimates were assessed for worker exposure during maintenance activities on golf courses; risk estimates were of concern until 5 days after

treatment.

2.2 Data Deficiencies and Requirements

There are no data deficiencies. Chemical

- specific turf transferable residue ( TTR ) data are available; DFR data are not required based on the registered use pattern.

3 .0 Hazard Characterization

Bensulide is Toxicity Category II for acute oral toxicity . The acute lethal toxicity is low for other

routes, Toxicity Category III or IV for dermal and inhalation toxicity; and dermal and eye

irritation. It is not a dermal sensitizer.

Table 3.0.1. Acute Toxicity Profile

- Bensulide

Guideline

No. Study Type MRID # Results Toxicity Category

870.1100 Acute oral [rat] 00097921

92005011 LD 50 = 360 mg/kg (M)

LD 50 = 270 mg/kg (F) II

870.1200 Acute dermal [rat] 41597501 LD 50 ≥ 2000 mg/kg III

870.1200 Acute dermal [rabbit] 00097921 LD50 > 5000 mg/kg IV

870.1300 Acute inhalation [rat] 41646201 LC 50 > 1.75 mg/L III

870.2400 Acute eye irritation [rabbit] 41597502 mild irritant III

870.2500 Acute dermal irritation [rabbit] 00097921

92005012 mild irritant IV

870.2600 Dermal sensitization [guinea pig] 00160075 not a sensitizer NA



### OPs exhibit a phenomenon known as steady

- state AChE inhibition. After repeated dosing at the same dose level, the degree of inhibition comes into equilibrium with the production of new, uninhibited enzyme. At this point, the amount of AChE inhibition at a given dose remains

consistent ac ross duration. As such, t he endpoints focus on acute (single

- day) effec ts and steady

state effects.

HED’s Hazard Science Policy Council (HASPOC) recommended a waiver for the immunotoxicity study (Van Alstine, 2013; TXR # 0056 738 )

. Furthermore, HASPOC

recommended waivers for t he 6

- month ocular toxicity study in dog, and developmental and subchronic neurotoxicity studies; however, the subchronic inhalation study is required and is considered a datagap (Leshin, 2015, TXR # 0057280 )

.Page 7 of 41



### The toxicological endpoints for risk assessment are summarized in Tables 3.0.2 and 3.0.3 below. The endpoint for all exposure scenarios is RBC AChEI and points of departure (PODs) were selected from high quality, well

- conducted CCA rat studies. Th e POD f or the steady

- state (a 21

- day assessment) incidental oral, dermal, and inhalation scenarios i s 6 mg/kg /day. The FQPA safety factor (10X) has been retained for infants, children, youths, and women of child

- bearing age for all exposure scenarios due to uncer tainty in the human dose

- response relationship for neurodevelopmental effects. Additionally, for inhalation exposures, a database uncertainty factor of 30X was applied due to uncertainty in the human dose

- response relationship for neurodevelopmental effec ts and lack of an inhalation toxicity study. For all exposure scenarios, interspecies (10X) and intraspecies (10X) uncertainty factors were applied. As a result, a total uncertainty factor of 1000X was applied for all non

- cancer exposure scenarios, except inhalation exposures (total uncertainty factor = 3000X).

As a CCA study is not ava ilable for the bensulide oxon, a default toxicity adjustment factor (TAF) of 50X was applied to the bensulide oxon (assuming the oxon is 50X the toxicity of the parent)

.

T able 3.0.2. Summary of Toxicological Doses and Endpoints and Points of Departure for Bensulide in Dietary and Non

- Occupational Human Health Risk Assessments a

Exposure

Scenario Point of

Departure (mg/kg/day) Uncertainty/FQPA

Factors RFD, PAD, & LOC

for Risk

Assessment Study and Toxicological

Effects

Acute Dietary (All Populations) BMDL 10 = 11

mg/kg/day UF A = 10x

UF H = 10x FQPA SF = 10x Acute RfD = aPAD =

0.011 mg/kg/day Acute CCA Study (MRID

49433502) in the rat

BMD 10 = 16 mg/kg/day

Inhibition of RBC ChE in female pups (PND 11)

Incidental

Oral ( Steady

- state ) BMDL 10 = 6

mg/kg/day UF A = 10x

UF H = 10x FQPA SF = 10x Residential LOC for

MOE = 1000x Repeated

- Dose CCA Study

(MRID 49466201) in the rat

BMD 10 = 8 mg/kg/day

Inhibition of RBC ChE in male pups (PND 11 initially)

Dermal ( Steady

- state ) BMDL 10 = 6

mg/kg/day UF A = 10x

UF H = 10x FQPA SF = 10x

DAF = 10% Residential LOC for

MOE = 1000x Repeated

- Dose CCA Study

(MRID 49466201) in the rat

BMD 10 = 8 mg/kg/day

Inhibition of RBC ChE in male pups (PND 11 initially)

Inhalation ( Steady

- state ) BMDL 10 = 6

mg/kg/day UF A = 10x

UF H = 10x FQPA SF/ UF DB = 3 0 x Residential LOC for

MOE = 3 000x Repeated

- Dose CCA Study

(MRID 49466201) in the rat

BMD 10 = 8 mg/kg/day

Inhibition of RBC ChE in male pups (PND 11 initially)

Cancer (oral, dermal, inhalation) Bensulide has been classified as a Group E substance; the chemical is not likely to be

carcinogenic in humans via relevant routes of exposure.Page 8 of 41 a 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. BMDL = lower limit of the bench mark dose. NOAEL = no observed adverse effect level. LOAEL = lowest observed adverse effect level. UF = uncertainty factor. UF A = extrapolation from animal to human (interspecies). UF H = potential variation in sensitivity among membe rs of the human population (intraspecies). SF = Safety Factor. PAD = population adjusted dose (a = acute, c = chronic). RfD = reference dose. MOE = margin of exposure. LOC = level of concern. FQPA SF retained for infants, children, youths, and women o f childbearing age for all exposure scenarios due to uncertainty in the human dose

- response relationship for neurodevelopmental effects. UF DB for inhalation exposures = database uncertainty factor incorporating uncertainty in the human dose

- response relati onship for neurodevelopmental effects and the lack of a subchronic inhalation toxicity study.

Table 3.0.3 Summary of Toxicological Doses and Endpoints for Bensulide for Use in Occupational Human

Health Risk Assessments a

Exposure/

Scenario Point of

Departure Uncertainty/

FQPA

Factors LOC for Risk

Assessment Study and Toxicological Effects

Dermal Steady

- state BMDL 10 = 6

mg/kg/day UF A = 10x

UF H = 10x

UF DB = 10X

DAF = 10% Occupational

LOC for MOE =

10 0 0x Repeated

- Dose CCA Study (MRID

49466201) in the rat

BMD 10 = 8 mg/kg/day

Inhibition of RBC ChE in male pups (PND 11 initially)

Inhalation Steady

- state BMDL 10 = 6

mg/kg/day UF A = 10 x

UF H = 10x

UF DB = 30 X Occupational

LOC for MOE =

30 00 x Repeated

- Dose CCA Study (MRID

49466201) in the rat

BMD 10 = 8 mg/kg/day

Inhibition of RBC ChE in male pups (PND 11 initially)

Cancer (oral, dermal, inhalation) Bensulide has been classified as a Group E substance; the chemical is not likely to be

carcinogenic in humans via relevant routes of exposure.

a 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 low er environmentally relevant human exposures. BMDL = lower limit of the bench mark dose. NOAEL = no observed adverse effect level. LOAEL = lowest observed adverse effect level. UF = uncertainty factor. UF A = extrapolation from animal to human (interspec ies). UF H = potential variation in sensitivity among members of the human population (intraspecies).

LOC = level of concern.

UF DB for occupational dermal exposures = database uncertainty factor for uncertainty in the human dose

- response relationship for neurodevelopmental effects.

UF DB for occupational inhalation exposures = database uncertainty factor incorporating uncertainty in t he human

dose

- response relationship for neurodevelopmental effects and the lack of a subchronic inhalation toxicity study.



### Absorption A dermal absorption factor of 10 % was used for the exposure assessment and is based on comparing the results occurring in an oral developmental rat study to the 21

- day dermal rat study. Since no inhalation absorption data are available, toxicity by the inhalation route is considered to be equivalent to the estimated toxicity by the oral rout e of exposure.

Body WeightPage 9 of 41



### For adults, when an endpoint is not sex

- specific (i.e., the endpoints are based on developmental or fetal effects) a body weight of 80 kg is typically used in risk assessment; however, in this case,

a female

- specific body weight of 69 kg was used. While the endpoint of concern, RBC AChE inhibition, is not sex

- specific, the female

- specific body weight was used to protect for pregnant women due to uncertainty in the human dose

- response relationship for neurodevelopmental

effects. Bo dy weight s of 57, 32 and 11 kg was used to assess exposure to children 11 to <16 years, 6 to <11 years, and 1 to <2 years old

.

4 .0 Use Profile

Bensulide is used for weed control in residential and occupational settings. Bensulide can be applied to v egetable crops, golf courses, and residential turf. A summary of bensulide uses is

listed in Table 4.1.

Table 4 .1. Summary of Directions for Use of Bensulide

.

Applic. Timing, Type, and Equip. Formulation

[EPA Reg. No.] Applic.

Rate (lb ai/A) Max.

Seasonal Applic. Rate (lb ai/A) PHI (days) Use Directions and Limitations

Turf (Golf Courses and Residential Lawns)

Groundboom or low pressure turfgun,

Handwand for

spot treatment

Watered in Liquid

4 lb ai/gal

(46% ai)

EPA Reg. No.

2217

- 696 12.5 lb

ai/acre 25 lb ai/acre NA PPE: baseline , gloves, PF5 respirator

Tractor drawn spreader, Push type spreader

Watered in Granular

7% ai

EPA Reg. No.

2217

- 778 12.6 lb

ai/acre 25.2 lb

ai/acre NA PPE: Loaders, spreader applicator: Coveralls, glove s , PF5 respirator

All others: baseline, gloves

For hire applicators must wear PF5

respirator

Cannot be applied aerially

Only on lawns

Push type spreader only Granular

3.6% ai

EPA Reg. No.

2217

- 838 12.5 lb

ai/acre NA NA No PPE listed

Hand

- held rotary broadcast spreader

prohibited

Tractor drawn spreader, push type spreader Granular

8.5% ai

EPA Reg. No

9198

- 172 12.4 lb

ai/acre NA NA PPE: loaders, spreader applicator: coveralls, gloves , PF5 respirator

All others: baseline, gloves

Golf courses only

Tractor drawn spreader or push type spreader Granular

5.25% ai

EPA Reg. No.

9198

- 17 6 16 lb ai/acre 32 lb ai/acre NA Not for sale or use by homeowners

PPE: push spreaders and loade r: coveralls, gloves , PF5 respirator

Other applicators: baseline, gloves

For hire applicators must wear PF5

respiratorPage 10 of 41

Table 4 .1. Summary of Directions for Use of Bensulide

.

Applic. Timing, Type, and Equip. Formulation

[EPA Reg. No.] Applic.

Rate (lb ai/A) Max.

Seasonal Applic. Rate (lb ai/A) PHI (days) Use Directions and Limitations

Watered in

Golf courses only

Groundboom, low pressure turfgun,

LP Handwand for

spot treatment Liquid

46.4% ai

4 lb ai/gal

EPA Reg. No.

10163

- 196 12.5 lb

ai/acre 25 lb ai/acre NA PPE: Mixer/loader: baseline, gloves,

PF5 respirator

Applicator and other: baseline, gloves; for hire applicators must wear PF5 respirator

Golf courses only

Watered in Granular

12.5% ai

EPA Reg. No.

10163

- 198 12.5 lb

ai/acre 25 lb ai/acre NA PPE: Loaders, spreader applicator: coveralls, gloves, respirator

Other applicators: baseline, gloves,

respirator

Golf courses only

Tractor drawn spreader or push

type spreader

Watered in Granular

3.6% ai

EPA Reg. No.

10163

- 199 12.5 lb

ai/acre NA NA PPE: Loaders and spreader applicators: coveralls, gloves, eyewear, for

- hire applicators must wear respirator

All other applicators: baseline, gloves, respirator

Hand

- held rotary spreaders are

prohibited

Golf courses only

Tractor drawn spreader or push

type spreader

Watered in Granular

7% ai

EPA Reg. No.

10163

- 204 12.6 lb

ai/acre 25 lb ai/acre NA PPE: loaders and spreader applicators: coveralls, gloves, respirator; others: baseline, gloves,

for

- hire applicators must wear

respirator

Residential lawns only

RTU Garden hose

sprayer 46.4% ai

EPA Reg. No.

10163

- 205 16 fl oz

product/ 2500 sq. ft

8.7 lb ai/A NA NA No PPE listed

Cucurbit vegetables

Groundboom, Chemigation, Handgun

Preplant or

preemergence Emulsifiable

Liquid

4 lb ai/gal

EPA Reg. No.

10163

- 200 6 lb ai/acre NA NA PPE: baseline, gloves; Mixers, loaders and commercial applicators must wear a PF5 respirator

May not be applied by aircraft

9 lb ai/acre NA NA SLN label

– CA 960003

Brassica (cole) leafy vegetables ; leafy vegetables

Groundboom, Chemigation, Handgun Emulsifiable

Liquid

4 lb ai/gal 6 lb ai/acre 6 lb ai/acre NA PPE: baseline, gloves; Mixers, loaders and commercial applicators must wear a PF5 respirator

Do not use on spinach or Swiss

ChardPage 11 of 41

Table 4 .1. Summary of Directions for Use of Bensulide

.

Applic. Timing, Type, and Equip. Formulation

[EPA Reg. No.] Applic.

Rate (lb ai/A) Max.

Seasonal Applic. Rate (lb ai/A) PHI (days) Use Directions and Limitations

Preplant or

preemergence EPA Reg. No.

10163

- 200 May not be appli ed by aircraft

9 lb ai/acre 9 lb ai/acre NA SLN label

– NJ 070001

Fruiting vegetables

Groundboom, Chemigation, Handgun

Preplant or

preemergence Emulsifiable

Liquid

4 lb ai/gal

EPA Reg. No.

10163

- 200 6 lb ai/acre NA NA PPE: baseline, gloves; Mixers, loaders and commercial applicators must wear a PF5 respirator

May not be applied by aircraft

Carrots

Groundboom, Chemigation, Handgun

Preplant or Preemergence Emulsifiable

Liquid

4 lb ai/gal

EPA Reg. No.

10163

- 200 5 lb ai/acre 5 lb ai/acre NA PPE: baseline, gloves; Mixers, loaders and commercial applicators must wear a PF5 respirator

May not be applied by aircraft

Dry Bulb Vegetables

Groundboom, Chemigation, Handgun

Preplant or Preemergence Emulsifiable

Liquid

4 lb ai/gal

EPA Reg. No.

10163

- 200 6 lb ai/acre 6 lb ai/acre NA PPE: baseline, gloves; Mixers, loaders and commercial applicators must wear a PF5 respirator

May not be applied by aircraft

NA = Not Applicable; early season application



### 5 .0 Residential Exposure and Risk Estimates

The existing residential uses that have been reassessed in this document to reflect updates to

HED’s 2012 Residential SOPs 2 

### along with policy changes for body weight assumptions. The revision of residential exposures will impact the human health aggregate ri sk assessment for

bensulide

. Exposure to bensulide is assessed for handler scenarios; exposure to bensulide and bensulide oxon was assessed for post

- application scenarios.

5 .1 Residential Handler Exposure/Risk Estimates

HED uses the term “handlers” to d escribe 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

so mewhat differently by HED as homeowners are assumed to complete all elements of an application without use of any protective equipment.

2 Available: http://www.epa.gov/pesticides/science/residential

- exposure

- sop.htmlPage 12 of 41



### The quantitative exposure/risk assessment developed for residential handlers is based on the following scenarios:

 M ixing/loading/applying liquid and granular formulations dispersed by hand to
residential turf/lawns

, and

 Mixing/loading/applying liquid and granular formulations with handheld equipment to

residential turf/lawns.

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 : Application rates are listed in Table 4.1.

Unit Expos ures and Area Treated or Amount Handled : Unit exposure values and estimates for area treated or amount handled were taken from HED’s

2012 Residential SOPs 3



### .

Exposure Duration: Residential handler exposure is assessed as steady

- state in duration

.

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 SOPs 4



### .

Combining Exposures/Risk Estimate s:

A total aggregated risk index (ARI) was used since the LOCs for dermal exposure (100 0) and inhalation exposure (3 000) are different. The target ARI is 1; therefore, ARIs of less than 1 are

risk estimates of concern. The aggregate risk index (ARI) was cal culated as follows.

Aggregate Risk Index (ARI) = 1÷ [ ( Dermal LOC ÷ Dermal MOE ) + ( Inhalation LOC ÷ Inhalation MOE ) ]



### Summary of Residential Handler Non

- Cancer Exposure and Risk Estimates

A summary of residential handler risk estimates is provided in Table 5.1.1 below. Most residential handler risk estimates are of concern (ARI < 1).

3 Available: http://www.epa.gov/pesticides/sc ience/residential

- exposure

- sop.html

4 Available: http://www.epa.gov/pesticides/science/residential

- exposure

- sop.htmlPage 13 of 41

Table 5.1.1. Residential Handler Non

- cancer Exposure a nd Risk Estimates for Bensulide

.

Exposure Scenario Dermal Unit Exposure (mg/lb ai) Inhalation Unit

Exposure (mg/lb ai) Maximum

Application

Rate 1 Area Treated or

Amount Handled Daily 2 Dermal Inhalation Total

Dose (mg/kg/day) 3 MOE

(LOC = 1000) 4 Dose

(mg/kg/day) 5 MOE

(LOC = 3000) 6 ARI 7

Mixer/Loader/Applicator Liquid Concentrate, Handwand, Lawns 63 0.018 0.16 lb ai/gal 5 gallons 0.073 82 0.0002 29,000 0.081

Ready

- to

- use, hose end sprayer, Lawns 6.26 0.034 8.7 lb ai/acre 0.5 acres 0.039 150 0.0021 2

, 800 0.13

Liquid, Backpack,

Lawns 130 0.14 0.16 lb ai/gal 5 gallons 0.15 40 0.0016 3,700 0.039

Granule, Push type rotary spreader, Lawns 0.81 0.0026 12.5 lb ai/acre 0.5 acres 0.0073 820 0.0002 25,000 0.75

Granule, belly grinder,

lawns 360 0.039

0.00029 lb

ai/ft 2 1200 ft 2 0.18 33 0.0002 31,000 0.033

Granule, Spoon, Lawns 6.2 0.087

100 ft 2 0.00026 23,000 0.000037 160,000 16 Granule, Cup, Lawns 0.11 0.013 0.0000046 1,300,000 0.0000055 1,100,000 290
Granule, Hand dispersal, Lawns 160 0.38 0.0067 890 0.00016 38,000 0.83

Granule, Shaker can,

Lawns 0.11 0.013 0.0000046 1,300,000 0.0000055 1,100,000 290

1 Based on registered labels (see Table 4.1)

. 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 , ft 2 or gal) × Area Treated or Amount Handled (A or ft 2 /day or gallons/day) × Dermal Absorption Factor ( 10 %) ÷ Body Weight ( 69 kg).

4 Dermal MOE = Dermal NOAEL ( 6 mg/kg/day) ÷ Dermal Dose (mg/kg/day).

5 Inhalation Dose = Inhalation Unit Exposure (mg/lb ai) × Application Rate (lb ai/acre , ft 2 or gal) × Area Tre ated or Amount Handled (A or ft 2 /day or gallons/day) ÷ Body Weight ( 69 kg).

6 Inhalation MOE = Inhalation NOAEL ( 6 mg/kg/day) ÷ Inhalation Dose (mg/kg/day).

7 ARI = Aggregate Risk Index = 1÷ [(Dermal LOC ÷ Dermal MOE) + (Inhalation LOC ÷ Inhalation MOE)]

.Page 14 of 41



### 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 bensulide

. The quantitativ e exposure/risk

assessment for residential post

- application exposures is based on the following scenarios:

 Dermal exposure from high contact with treated turf (adults and children 1 to < 2 years old)

 Dermal exposure f

ro m golfing ( adults and youth 11 to < 16 years old and youth 6 to < 11 years old)

 Dermal exposure from mowing treated turf ( adult and youth 11 to < 16 years old)

 Incidental ingestion (i.e., hand

- to

- mouth, object

- to

- mouth, soil ingestion exposure) from contact with treated turf (children 1 to < 2 years old)

 Episodic granular ingestion (children 1 to < 2 years old)

The lifestages selected for each post

- application scenario are based on an analysis provided as an Appendix in the 2012 Residential SOPs 5



### . 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 a nd 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

SOPs 5



### .

Application Rate: Application rates are listed in Table 4.1.

T urf T ransferable R esidue (TTR) D ata:

Liquid Formulations:

Chemical

- specific TTR data are available for bensulide and are summarized in Table

5.2.1 ( HED review: D413875, 10/29/13, A. Rivera

- Lupianez)

. The study includes TTR

data on bensulide and its metabolite

, bensulide oxon

, that transferred from turf treated

w ith a liquid formulation containing bensulide at a rate of 12 .5 lb ai/A. The product was watered in immediately following the application. Residues were sampled using the modified California Roller technique. First

- order dissipation kinetics were assume d in

order to generate dissipation curves for bensulide and combined residues of bensulide and bensulide oxon. The summary of s tatistics include only post

- irrigation measurements as the product labels require the product to be watered in. Due to the diffe rences in the dissipation of bensulide and the oxon, residues of the oxon were adjusted by the TAF of 50 [ oxon residue, ug/cm 2 

### * 50X TAF] , and total residues (bensulide + adjusted oxon) were used to determine the risk resulting from exposures following bensulide

5 Available: http://www2.epa.gov/pesticide

- science

- and

- assessing

- pesticide

- risks/standard

- operating

- procedures

residential

- pesticidePage 15 of 41



### applications. For assessment of residential post

- application exposures, the predicted day 0 combined residues (0.479 ug/cm 2 

### ) were used in th e exposure calculations (see Table 5.2.1 below)

.

Table 5.2.1 . Regression Summary for Turf Treated with BENSUMEC 4LF (MRID 44799001)

Statistic Bensulide Bensulide oxon Combined

residues Combined

Residue with

50x factor for

oxon 1

Actual Application Rate (lb ai/A) 12.6

Actual Average 8

- 12 hours (μg/cm 2 ) (post

- irrigation ) 0.2093 0.0057 0.2144 0.4627

Predicted Day 0 (μg/cm 2 ) (post

- irrigation ) 0.201 0.002 0.206 0.479

Slope

- 0.27

- 0.049

- 0.271

- 0.303

Half

- life (days) 2.6 14.2 2.6 2.3

R 2 0.897 0.0285 0.8934 0.8123

Bolded value represents residue value used in post

- application exposure calculations.

1 Combined residue, ug/cm 2 = [ (oxon residue, ug/cm 2 ) * 50 X TAF] + [bensulide residue, ug/cm 2 )



### Solid Formulations : Chemical

- specific TTR data are not available for solid formulations applied to turf ; liquid TTR data were used as surrogate

. This is considered a health protective approach since, in general, granular formulations tend to result in lower percent transfer from turf than do liquid formulatio ns (e.g., the 2012 Residential SOP turf default percent transfer factor is 1% for liquids and 0.2% for granulars).

Exposure Duration: The exposure duration for residential post

- application exposures is steady

- state . Granule ingestion is considered episodic and thus is an acute duration.

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 SOPs 6



### .

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

- to

mouth and object

- to

- mouth) should be considered inter

- r elated 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

6 Available: http://www2.epa.gov/pesticide

- science

- and

- assessing

- pesticide

- risks/standard

- operating

- procedures

residential

- pesticidePage 16 of 41



### 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 N on

- Cancer Exposure and Risk Estimates A summary of the residential post

- application exposure and risk estimates for bensulide and its

oxon is in Table s 5.2.2 (for the liquid formulations) and 5.2.3 (for the granular formulations)

below. Risk estimates are of concern (MOEs < 1000) for dermal exposure for adults and children conducting high exposure activities are treated turf; for dermal exposure for adults and youths golfing; for hand

- to

- mouth exposure for children on treated turf; and for episodic granule ingestion exposure.

Table 5

. 2

. 2

. Residential Post

- application Non

- cancer Exposure a nd Risk Estimates for Bensulide + Oxon (L iquid

F ormulations)

.

Lifestage Post

- application Exposure

Scenario Application

Rate 1 Dose

(mg/kg/day) 2 MOEs

(LOC = 1000) 3 Combined Routes
(X indicates included in Combined MOE) Combined MOEs 4
(LOC = 1000) Use Site Route of

Exposure

Adult

Lawns/ Turf Dermal

– Turf

12.5 lb ai/A 0.187 32

NA Dermal

- Mowing 0.0038 1,600

Dermal

– Golfing 0.0147 410

Youth (11 to < 16 years) Dermal

- Mowing 0.00378 1,600

Dermal

– Golfing 0.0148 410
Youth (6 to < 11 years) Dermal

- Golfing 0.0174 350

Child (1 to < 2 years) Dermal

- Turf 0.32 19 X 16 HTM 0.0656 91 X

OTM 0.00199 3,000 NA Soil Ingestion 0.00042 14,000

1 Based on registered labels (see Table 4.1)

. Predicted Day 0 combined (bensulide + adjusted oxon) residue value (0.479 ug/cm 2 ; from MRID

44799001 ) used in calculations.

2 Dose (mg/kg/day) algorithms provided in 2012 Residential SOPs ( http://www2.epa.gov/pesticide

- science

- and

- assessing

- pesticide

risks/standard

- operating

- procedures

- residential

- pesticide ).

3 MOE = Dermal and Incidental Oral POD ( 6 mg/kg/day) ÷ Dose (mg/kg/day).

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

Table 5.2.3. Residential Post

- application Non

- cancer Exposure a nd Risk Estimates for Bensulide + Oxon ( Solid

F ormulations).

Lifestage Post

- application Exposure

Scenario Application

Rate 1 Dose

(mg/kg/day) 2 MOEs

(LOC = 1000) 3 Combined Routes (X indicates included in Combined MOE) Combined MOEs 4
(LOC = 1000) Use Site Route of

Exposure

Adult

Lawns/ Turf Dermal

– Turf 12.5 lb ai/A 0.2082 29

NA Dermal

- Mowing 0.0038 1,600

Dermal

– Golfing 16 lb ai/A 0.0188 320

Youth (11 to < 16 years) Dermal

- Mowing 12.5 lb ai/A 0.00378 1,600

Dermal

– Golfing

16 lb ai/A 0.0189 320
Youth (6 to < 11 years) Dermal

- Golfing 0.0222 270

Child (1 to < 2 years) Dermal

- Turf

12.5 lb ai/A 0.3527 1 7 X 16 HTM 0.0325 180 X

OTM 0.00199 3,000 NA Soil Ingestion 0.00042 14,000Page 17 of 41

Table 5.2.3. Residential Post

- application Non

- cancer Exposure a nd Risk Estimates for Bensulide + Oxon ( Solid

F ormulations).

Lifestage Post

- application Exposure

Scenario Application

Rate 1 Dose

(mg/kg/day) 2 MOEs

(LOC = 1000) 3 Combined Routes (X indicates included in Combined MOE) Combined MOEs 4
(LOC = 1000) Use Site Route of

Exposure Episodic Granule Ingestion 3.41 3.2

1 Based on registered labels (see Table 4.1)

. Predicted Day 0 combined (bensulide + adjusted oxon) residue value (0.479 ug/cm 2 ; from MRID

44799001 ) used in calculations.

2 Dose (mg/kg/day) algorithms provided in 2012 Residential SOPs ( http://www2.epa.gov/pesticide

- science

- and

- assessing

- pesticide

risks/standard

- operating

- procedures

- residential

- pesticide ).

3 MOE = Dermal and Incidental Oral POD ( 6 mg/kg/day) ÷ Dose (mg/kg/day).

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



### 5.3 Residential Risk Estimates for Use in Aggregate Assessment

As the residential turf scenarios are risks of concern, there are no residential risk estima tes
recommended for steady state aggregate assessment.

6.0 Non

- Occupational Spray Drift Exposure and Risk Estimates

Off

- target movement of pesticides can occur via many types of pathways and it is governed by a variety of factors. Sprays that are released and do not deposit in the application area end up off

target and can lead to exposures to those it may directly contact. They can also deposit on surfaces where contact with residues can eventually lead to indirect exposures ( e.g.
, children playi ng on lawns where residues have deposited next to treated fields). The potential risk estimates from these residues can be calculated using drift modeling onto 50 feet wide lawns coupled with methods employed for residential risk assessments for turf prod ucts.

The approach to be used for quantitatively incorporating spray drift into risk assessment is based on a premise of compliant applications which, by definition, should not result in direct exposures to individuals because of existing label language a nd other regulatory requirements intended to prevent them. 7 

### Direct exposures would include inhalation of the spray plume or being sprayed directly. Rather, the exposures addressed here are thought to occur indirectly through contact with impacted areas, such as residential lawns, when com pliant applications are conducted. Given this premise, exposures for children (1 to <2 years old) and adults who have contact with turf where residues are assumed to have deposited via spray drift thus resulting in an in direct exposure are the focus of th is analysis analogous to how exposures to turf products are

considered in risk assessment.

In order to evaluate the drift potential and associated risks, an approach based on drift modeling coupled with techniques used to evaluate residential uses of pesticides was utilized. Essentially, a residential turf assessment based on exposure to deposited residues has been completed to address drift from the agricultural applications of bensulide

. I n the spray drift scenario, the deposited residue value was determined based on the amount of spray drift that may occur at varying distances from the edge of the treated field using the AgDrift ® 

### (v2.1.1) model and the Residential Exposure Assessment Standard Operating Procedures Ad denda 1: Consideration of

7 This approach is consistent with the requir ements of the EPA’s Worker Protection Standard.Page 18 of 41



### Spray Drift Policy

. Once the deposited residue values were determined, the remainder of the spray drift assessment was based on the algorithms and input values specified in the recently revised (2012) Standard Operating Procedure s For Residential Risk Assessment (SOPs)

.

For bensulide, chemical

- specific turf transferable residue (TTR) data are available. See Section

5.2 for a description of the TTR data. The data include measurements on bensulide and the

oxon. For assessment o f exposures resulting from spray drift, the predicted day 0 combined (bensulide + adjusted oxon) residue value (0.479 ug/cm 2 

### ) was adjusted for differences in application rate between the study and the registered agricultural uses, and the adjusted residue value was used in the exposure calculations.

A screening approach was developed based on the use of the AgDrift ® 

### model in situations where specific label guidance that defines application parameters is not available. 8 

### AgDrift ® 

### is appropriate for use only when applications are made by aircraft, airblast orchard sprayers, and groundboom sprayers. When AgDrift ® 

### was developed, a series of screening values (i.e., the Tier 1 option) were incorporated into the mod el and represent eac h equipment type and use under varied conditions. The screening options specifically recommended in this methodology were selected because they are plausible and represent a reasonable upper bound level of drift for common application methods in agricultu re. These screening options are consistent with how spray drift is considered in a number of ecological risk assessments and in the process used to develop drinking water concentrations used for risk assessment. In all cases, each scenario is to

be evalu ated unless it is not plausible based on the anticipated use pattern (e.g., herbicides are not typically applied to tree canopies) or specific label prohibitions (e.g., aerial applications are not allowed). Table 6.1 provides the screening level drift rel ated risk estimates. In many cases, risk estimates are of concern when the screening level estimates for spray drift are used as the basis for the analysis. In order to account for this issue and to provide additional risk management options, additional spray drift deposition fractions were also considered. These drift estimates represent plausible options for pesticide labels.

Combined Risk Estimates from Lawn Deposition Adjacent to Applications

The spray drift risk estimates are based on an estimated deposited residue concentration as a result of the screening level agricultural application scenarios. Bensulide is registered in both liquid and granular formulation end

- use products. Granular formulations, applied as solid materials and no liquid spra y, have different drift patterns than liquid sprays, and as such need to be considered in a separate analysis. However, from a human health perspective, off

- site movement of granular products would result in lower risk estimates than those for liquid prod ucts ( e.g. , less drift occurs and there is less exposure uptake for granules). In most cases pesticides also have liquid end

- use products and an analysis for them would be protective of potential risks from granular drift ; thus granular products are not a ssessed

.

Bensulide is registered on vegetable crops and golf courses and can be applied via grou ndboom equipment at a maximum single application rate of 6 lb ai/A for vegetable crops (9 lb ai/A on SLN labels) and 12.5 lb ai/acre for golf courses . The r ecommended drift scenario screening level options are listed below:

8 http://www.agdrift.com/Page 19 of 41



###  Groundboom applications are based on the AgDrift ® 

### option for high boom height and using very fine to fine spray type using the 90 th 

### percentile results.

In addition to the screening level spray drift scenarios described above, additional results are provided which represent viable drift reduction technologies (DRTs) that represent potential risk management options. In particular, different spray qualities have been considered as well as the impact of other application conditions (e.g., boom height and crop canopy conditions).

Dermal risk estimates were calculated for adults. Dermal and incidental oral risk estimates for children (1 to <2 years old) were combined because the toxicity endpoint for each route of exposure is the same (RBC AChE inhibition). The total applicable LOC is 1000, so MOEs <1000 represent risk estimates of concern.

Risk estimates related to spray drift are of concern at various distances from the edge of the field for adults and children (1 to <2 years) depending on the spray drift scenario. Adult and children risk estimates are summarized in Table 6.1. For adults, the screening level scenario of a high boom and very fine to fine spray indicates the LOC is e xceeded at a distance of less than 25 feet for application to vegetables

, less than 50 feet for application to SLN vegetables, and less than 75 feet for application to golf courses to reach a dermal MOE ≥ 1000. For children, the screening

level scenario i ndicates the LOC is exceeded at a distance of less than 75 feet for application to vegetables

, less than 100 feet for application to SLN vegetables, and less than 150 feet for application to golf courses to reach a combined (dermal and incidental oral) MOE ≥1000. Drift reduction technologies, such as using coarser sprays and lowering boom height for groundboom sprayers, reduces risk concerns; however there are still risk estimates of concern at the field edge

for some scenarios

.Page 20 of 41

Table 6 .1. Spray Drift Risk Estimate Summary for Bensulide

.
Crop / Application Type Spray Type/

Nozzle Configuration Application

Rate

(lb ai/A) Estimated

TTR (ug/cm 2 ) MOE at Different Distances from Edge of Field

LOC = 1000

At Edge 10 Feet 25 Feet 50 Feet 75 Feet 100 Feet 125 feet 150 feet 200 feet 250 feet 300 feet

Adults (Dermal Exposure Only) ; Vegetable Crops (6 lb ai/acre)

Vegetable /

Groundboom Screening Level

High Boom Very

fine to Fine

6 0.2299 360 720 1,200 1,900 2,700 3,300 3,900 4,800 6,100 8,300 9,500

Low Boom Very

fine to Fine 780 2,100 3,300 5,100 6,700 8,300 9,500 11,000 13,000 17,000 22,000

High Boom Fine to

Medium / Coarse 1,400 3,500 5,100 7,400 9,500 11,000 13,000 13,000 17,000 22,000 22,000

Low Boom Fine to

Medium / Coarse 2,000 5,600 8,300 11,000 13,000 17,000 22,000 22,000 33,000 33,000 33,000

Adults (Dermal Exposure Only); Vegetable Crops (SLN rate of 9 lb ai/acre)

Vegetable /

Groundboom Screening Level

High Boom Very

fine to Fine

9 0.345 240 480 790 1,300 1,800 2,200 2,600 3,200 4,000 5,600 6,400

Low Boom Very

fine to Fine 520 1,400 2,200 3,400 4,400 5,600 6,400 7,400 8,900 11,000 15,000

High Boom Fine to

Medium / Coarse 910 2,300 3,400 4,900 6,400 7,400 8,900 8,900 11,000 15,000 15,000

Low Boom Fine to

Medium / Coarse 1,300 3,700 5,600 7,400 8,900 11,000 15,000 15,000 22,000 22,000 22,000

Adults (Dermal Exposure Only); Golf Courses

Golf Course /

Groundboom Screening Level

High Boom Very

fine to Fine

12.5 0.479 170 340 570 910 1,300 1,600 1,900 2,300 2,900 4,000 4,600

Low Boom Very

fine to Fine 380 1,000 1,600 2,500 3,200 4,000 4,600 5,300 6,400 8,000 11,000

High Boom Fine to

Medium / Coarse 650 1,700 2,500 3,600 4,600 5,300 6,400 6,400 8,000 11,000 11,000

Low Boom Fine to

Medium / Coarse 970 2,700 4,000 5,300 6,400 8,000 11,000 11,000 16,000 16,000 16,000

Children (1 to < 2 years old) (Dermal and Incidental Oral Exposure) ; Vegetable Crops (6 lb ai/acre)Page 21 of 41

Vegetable /

Groundboom Screening Level

High Boom Very

fine to Fine

6 0.2299 170 350 580 930 1,300 1,600 1,900 2,300 2,900 4,100 4,600

Low Boom Very

fine to Fine 380 1,000 1,600 2,500 3,200 4,100 4,600 5,400 6,500 8,100 11,000

High Boom Fine to

Medium/Coarse 660 1,700 2,500 3,600 4,600 5,400 6,500 6,500 8,100 11,000 11,000

Low Boom Fine to

Medium/Coarse 980 2,700 4,100 5,400 6,500 8,100 11,000 11,000 16,000 16,000 16,000

Children (1 to < 2 years old) (Dermal and Incidental Oral Exposure); Vegetable Crops (SLN rate of 9 lb ai/acre)

Vegetable /

Groundboom Screening Level

High Boom Very

fine to Fine

9 120 230 390 620 860 1,100 1,300 1,500 2,000 2,700 3,100

Low Boom Very

fine to Fine 250 680 1,100 1,700 2,200 2,700 3,100 3,600 4,300 5,400 7,200

High Boom Fine to

Medium/Coarse 440 1,100 1,700 2,400 3,100 3,600 4,300 4,300 5,400 7,200 7,200

Low Boom Fine to

Medium/Coarse 650 1,800 2,700 3,600 4,300 5,400 7,200 7,200 11,000 11,000 11,000

Children (1 to < 2 years old) (Dermal and Incidental Oral Exposure); Golf Courses

Golf Course /

Groundboom Screening Level

High Boom Very

fine to Fine

12.5 0.479 83 170 280 440 620 780 920 1,100 1,400 1,900 2,200

Low Boom Very

fine to Fine 180 490 780 1,200 1,600 1,900 2,200 2,600 3,100 3,900 5,200

High Boom Fine to

Medium/Coarse 320 820 1,200 1,700 2,200 2,600 3,100 3,100 3,900 5,200 5,200

Low Boom Fine to

Medium/Coarse 470 1,300 1,900 2,600 3,100 3,900 5,200 5,200 7,800 7,800 7,800

Bolded values are below the LOC of 1000.Page 22 of 41



### 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

rela ted 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

- OP P

- 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 bensulide

.

The California Department of Pesticide Regulation (DPR) has released a draft report on its air monitoring network for public comment. In 2011, DPR established a monitoring network to sample ambient air for multiple pesticides in three communities on a regular basis. The draft report of results for the monitori ng in 2014 is available at http://www.cdpr.ca.gov/docs/emon/airinit/air_network_results.htm. In the draft Air Monitoring Network Results for 2014 report, there were 0 detections of bensulide of 157 samples. Furthermore, i n the 2012 and 2013 report s , there were 0 detection s of bensulide

. In the 2011 report, there were 5 detects of bensulide of 142 samples ; a ll detects wer e below the quantitation

limit

.

8 .0 Occupational Exposure and Risk Estimates

Exposure to bensulide is assessed for handler scenarios; e xposure to bensulide and bensulide oxon was assessed for post

- application scenarios.

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 bel ieves 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

trea ted, and the level of protection used by a handler can cause exposure levels to differ in a manner specific to each application event.

Based on 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 occupatio nal handlers is based on the following scenarios:

 Mixing/loading granules for tractor application

,

 Mixing/loading liquids for chemigation and groundboom application,Page 23 of 41



###  Applying granules via tractor,

 Applying sprays via groundboom equipment,

 Mixing/loadin g/applying liquids via handgun equipment, and

 Mixing/loading/applying granules via 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 : A summary of application rates is provided in Table 4.1.

Unit Exposures: It is the policy of HED to use the best available data to assess handler exposure. Sources of generic handler data, used as surrogate data in the absence of chemical

- specific data, include PHED 1.1, the AHETF database, the Outdoor Residential Exposure Task Force (ORETF) database, or other registrant

- submitted occupati onal 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 Table 9 

### ”, which, along with additional information on HED policy on use of surrogate data, including descriptions of the various sources, can be found at the

A gency website 10



### .

Area Treated or Amount Handled : Based on ExpoSAC Policy 9.1, the area treated or amount handled is assumed to be :

 40 acres for tractor or groundboom applications to golf courses,

 350 acres for chemigation applications

,

 80 acres for groundboom applications to typical field crops (vegetables)

,

 1000 gallons for handgun applications to field crops (vegetables), and

 5 acres for handgun/rotary spreader applications to golf courses.

Exposure Duration:

For bensulide , based on the proposed use, steady

- state exposure is expected.

Mitigation/Personal Protective Equipment: Estimates of dermal and inhalation exposure were calculated for various levels of personal protective equipment (PPE). Results are presented for

the label

- required PPE and also with various levels of additional PPE as necessary. A summary of PPE requirements in listed in Table 4.1.

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

.

9 Available: http://www2.epa.gov/sites/production/files/2015

- 09/documents/handler

- exposure

- table

- 2015.pdf

10 Available: http://www2.epa.gov/p esticide

- science

- and

- assessing

- pesticide

- risks/occupational

- pesticide

- handler

exposure

- dataPage 24 of 41



### Combining Exposures/ Risk Estimates : A total aggregated risk index (ARI) was used since the LOC values for dermal exposure (1 0 00)

and inhalation exposure ( 3 000) are different. The tar get ARI is 1; therefore, ARIs of less than 1

are risk estimates of concern. The aggregate risk index (ARI) was calculated as follows.

Aggregate Risk Index (ARI) = 1÷ [(Dermal LOC ÷ Dermal MOE) + (Inhalation LOC ÷ Inhalation MOE)]



### Summary of Occupational Handler Non

- Cancer Exposure and Risk Estimates A summary of occupational handler risk estimates for bensulide with the label

- required PPE is provided in Table 8.1.1 below. With the label

- required PPE, all handler risk estimates are of

concern (ARI < 1). A summary of handler risk estimates with additional PPE/ engineering controls to mitigate risks is provided in Table 8.1.2; most handler risk estimates are still of concern with the maximum PPE/ engineering controls.Page 25 of 41

Table 8 .1.1. Occupational Handler Non

- Cancer E xposure and Risk Estimates for Bensulide (with label

- required PPE)

.

Exposure Scenario Crop or Target Dermal Unit Exposure (μg/lb ai) 1 Inhalation Unit

Exposure (μg/lb ai) 1 Maximum

Application

Rate 2 Area

Treated or

Amount

Handled Daily 3 Dermal Inhalation Total

Dose (mg/kg/day) 4 MOE 5

(LOC = 1000) Dose (mg/kg/day) 6 MOE 7

(LOC = 3000) ARI 8

Mixer/Loader M/L, Granule, Tractor Application Golf Course DL/G: 3.4 PF 5: 0.34 16 lb ai/A 40 A 0.00316 1,900 0.00316 1,900 0.48

M/L, Liquid, Chemigation Cucurbit/ Brassica/ Fruiting/ Dry bulb Vegetables

SL/ G: 37.6 PF 5: 0.0438 6 lb ai/ A 350 A 0.114 53 0.00133 4,500 0.051

SLN Vegetables 9 lb ai/A 0.171 35 0.002 3,000 0.034

M/L, Liquid, Groundboom Application Golf Course 12.5 lb ai/A 40 A 0.0272 220 0.000317 19,000 0.21

Cucurbit/ Brassica/ Fruiting/ Dry bulb Vegetables 6 lb ai/A 80 A 0.0261 230 0.000304 20,000 0.22

SLN Vegetables 9 lb ai/A 0.0393 150 0.000457 13,000 0.14 Applicator

Applying Sprays via

Groundboom Equipment Golf Course

SL/G: 16.1 PF 5: 0.068 12.5 lb ai/A 40 A 0.0117 510 0.000493 12,000 0.45

Cucurbit/ Brassica/ Fruiting/ Dry bulb Vegetables 6 lb ai/A 80 A 0.0112 540 0.000472 13,000 0.48

SLN Vegetables 9 lb ai/A 0.0168 360 0.00071 8,500 0.32 Applying Granule via

Tractor Golf Course SL/G: 7.2 PF 5: 0.24 16 lb ai/A 40 A 0.00668 900 0.00223 2,700 0.45

Mixer/L oader/Applicator

M/L/A, Liquid, Handgun Golf Course/ Lawn SL/ G: 880 PF 5: 0.38 12.5 lb ai/A 5 A 0.0797 75 0.000345 17,000 0.074

Field Crop SL/G: 390 PF 5: 0.78 0.16 lb ai/gal 1000 gal 0.0904 66 0.00181 3,300 0.062

L/A, Granule, Rotary Spreader Lawn DL/G: 130 PF 5: 2 12.5 lb ai/A 5 A 0.0118 510 0.00181 3,300 0.35

Golf Course 16 lb ai/A 0.0151 400 0.00232 2,600 0.27

1 Based on the “Occupational Pesticide Handler Unit Exposu re Surrogate Reference Table” (March 2013 ); Level of mitigation: SL/G =Single layer clothing and gloves; DL/G = Double layer clothing and gloves; PF 5 = respirator with protection factor of 5; PF 10 = respirator w ith protection factor of 10; EC = engineering controls.

2 Based on registered labels

. 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 or gal) × Area Treated or Amount Handled (A or gal/day) × DAF (%) ÷ BW (kg).

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

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

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

8 ARI = Aggregate Risk Index = 1÷ [(Dermal LOC ÷ Dermal MOE) + (Inhalation LOC ÷ Inhalation MOE)].Page 26 of 41

Table 8.1.2 . Occupational Handler Non

- Cancer E xposure and Risk Estimates for Bensulide (with additional level of PPE)

.

Exposure Scenario Crop or Target Dermal Unit Exposure (μg/lb ai) 1 Inhalation Unit

Exposure (μg/lb ai) 1 Maximum

Application

Rate 2 Area Treated or

Amount Handled Daily 3 SL/G + PF 5 DL/G + PF 5 SL/G + PF 10 DL/G + PF 10 EC

ARI 4

Mixer/Loader

M/L, Granule, Tractor Application Golf Course SL/G: 6.9

DL/G: 3.4

EC: 8.6 PF 5: 0.34

PF 10: 0.17

EC: 0.083 16 lb ai/A 40 A 0.38 0.48 (current PPE) 0.54 0.76 0.58

M/L, Liquid, Chemigation Cucurbit/ Brassica/

Fruiting/ Dry bulb Vegetables

SL/ G: 37.6

DL/ G: 29.1

EC: 8.6 PF 5: 0.0438

PF 10: 0.0219

EC: 0.083 6 lb ai/ A

350 A 0.051 (current PPE) 0.065 0.052 0.066 0.18

SLN Vegetable 9 lb ai/A 0.034 (current PPE) 0.043 0.034 0.044 0.12

M/L, Liquid,

Groundboom Application Golf Course 12.5 lb ai/A 40 A 0.21 (current PPE) 0.27 0.22 0.27 0.75

Cucurbit/ Brassica/ Fruiting/ Dry bulb Vegetables 6 lb ai/A

80 A 0.22 (current PPE) 0.29 0.23 0.29 0.77

SLN Vegetables 9 lb ai/A 0.14 (current PPE) 0.19 0.15 0.2 0.52

Applicator

Applying Sprays via

Groundboom Equipment Golf Course

SL/G: 16.1

DL/ G: 12.6

EC: 5.1 PF 5: 0.068

PF 10: 0.034

EC: 0.043 12.5 lb ai/A 40 A 0.45 (current PPE) 0.57 0.48 0.61 1.3

Cucurbit/ Brassica/ Fruiting/ Dry bulb Vegetables 6 lb ai/A

200 A 0.48 (current PPE) 0.59 0.51 0.63 1.4

SLN Vegetables 9 lb ai/A 0.32 (current PPE) 0.4 0.34 0.43 0.88

Applying Granule via

Tractor Golf Course SL/G: 7.2

DL/ G: 4.2

EC: 2 PF 5: 0.24

PF 10: 0.12

EC: 0.22 16 lb ai/A 40 A 0.45 (current PPE) 0.56 0.6 0.82 0.74

Mixer/L oader/Applicator

M/L/A, Liquid, Handgun Golf Course/ Lawn SL/ G: 880

DL/G: 450 PF 5: 0.38

PF 10: 0.19 12.5 lb ai/A 5 A 0.074 (current PPE) 0.15 0.075 0.15 NA

Field Crop SL/G: 390

DL/G: 290 PF 5: 0.78

PF 10: 0.39 0.16 lb ai/gal 1000 gal 0.062 (current PPE) 0.082 0.064 0.086 NA

L/A, Granule, Rotary Spreader Lawn SL/G: 240

DL/G: 130 PF 5: 2

PF 10: 1 12.5 lb ai/A

5 A 0.22 0.35 (current PPE) 0.25 0.41 NA

Golf Course 16 lb ai/A 0.18 0.27 (current PPE) 0.2 0.33 NA

1 Based on the “Occupational Pesticide Handler Unit Exposure Surrogate Reference Table” ( March 2013 ); Level of mitigation: SL/G =Single layer clothing and gloves; DL/G = Double layer clothing and gloves; PF 5 = respirator with protection factor of 5; PF 10 = respirator with protection factor of 10; EC = engineering controls.

2 Based on registered labels

. 3 Exposure Science Advisory Council Policy #9.1.Page 27 of 41

4 ARI = Aggregate Risk Index = 1÷ [(Dermal LOC ÷ Dermal MOE) + (Inhalation LOC ÷ Inhalation MOE)].Page 28 of 41



### 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 re

entry 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 o n 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 Occu pational 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 v olatilization 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 Sci entific 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 Scree ning 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 bensulide

.

In addition, the Agency is continuing to evalua te 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

Bensulide is registered for use on golf course turf and on vegetable crops. A dermal post

application assessment has been conduct ed for the golf course turf use. However, s ince bensulide is applied to vegetables as a preplant or preemergence application only, occupational

post

- application dermal exposure s are not anticipated for these uses. There is a low potential for occupational p ost

- application exposure when pre

- emergent herbicides are used. Bensulide is applied to the soil directly and is soil incorporated well befor e the crops are mature. The timing of the application of bensulide can greatly reduce the potential for post

- app lication exposure. Minimal expos ure during harvesting or any other late season activities is expected since bensulide is applied pre

- emergent. Therefore, HED does no t require a post

- application occupational exposure assessment (H ED Exposure Science Adviso ry Council Policy No. 008)

.

Occupational Post

- application Dermal Exposure Data and AssumptionsPage 2 9 of 41



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

post

- application risk assessments for the golf course use

. Each assumption and factor is detailed

below on an individual basis.

Exposure Duration:

For bensulide

, an exposure profile consistent with steady

- state exposure is expected.

Transfer Coefficients : It is the policy of HED to use the best available data to assess post

application 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 coefficien ts”, are presented in the ExpoSAC Policy 3 11 

### ” which, along with
additional information about the ARTF data, can be found at the Agency website 12



### . Table

8 .2.2.1 provides a summary of the anticipated post

- application activities and associated transfer

coeffi cients 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 (cm 2 /hr ) Activities

Golf Course Turf Low Full 3700 Maintenance



### Application Rate: Application rates are listed in Table 4.1.

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

Turf Transferable Residues : Chemical

- specific TTR data are available for the liquid formulation

of bensulide. See Section 6 .2 for a description of the TTR data. The data include measurements
on bensulide and the oxon. Due to the differences in the dissipation of bensulide and the oxon, residues of the oxon were adjusted by the toxicity adjustment factor ( TAF ; oxon residue, ug/cm 2



### * 50X TAF ) , and total residues (bensulide + adjusted oxon) were used to determine the risk resulting from exposures following bensulide applications. Sin ce no data are available for the granular formulation, the liquid formulation residue data were used as a surrogate. As noted above, this is considered a health protective approach since, in general, granular formulations tend to result in lower percent t ransfer from turf than do liquid formulations (e.g., the 2012 Residential SOP turf default percent transfer factor is 1% for liquids and 0.2% for granulars).

Occupational Post

- application Non

- Cancer Dermal Exposure and Risk Estimate Equations

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

12 Available: http://www.epa.gov/pesticides/science/post

- app

- exposure

- data.htmlPage 30 of 41



### The algorith ms 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 Occupational post

- application risks were estimated for workers; risk estimates were of concern until 5 days after treatment (DAT 5). See T able s 8. 2.2.2 (for liquid formulations) and 8.2.2.3 (for granular formulations) below for a summary of the occupational post

- application risk

estimates

.

Table 8

. 2 .2. 2

. Occupational Pos t

- application Non

- Cancer Exposure and Risk Estimates for Bensulide + Oxon (with 50X

TAF ) (Liquid Formulations)

.

Crop/Site Activities Transfer Coefficient (cm 2 /hr) DAT TTR 1 Dermal Dose (mg/kg/day) 2 MOE 3

Golf Course Maintenance 3700 0 0.475 0.0204 290

1 0.351 0.0151 400

2 0.259 0.0111 540

3 0.192 0.0082 730

4 0.141 0.0061 990

5 0.105 0.00448 1,300

1 TTR = Data from MRID 44799001

. Total TTR, ug/cm 2 = [ (oxon residue, ug/cm 2 ) * 50 X TAF] + [bensulide residue, ug/cm 2 )

2 Daily Dermal Dose = [DFR (μg/cm 2 ) × Transfer Coefficient × 0.001 mg/μg × 8 hrs/day × dermal absorption ( 10 %)]  BW ( 69 kg).

3 MOE = POD ( 6 mg/kg/day) / Daily Dermal Dose.

Table 8

. 2 .2. 3

. Occupational Post

- application Non

- Cancer Exposure and Risk Estimates for Bensulide + Oxon (with 50X TAF) (Solid Formulations)

.

Crop/Site Activities Transfer Coefficient (cm 2 /hr) DAT TTR 1 Dermal Dose (mg/kg/day) 2 MOE 3

Golf Course Maintenance 3700 0 0.6083 0.026097 230

1 0.4493 0.019276 310

2 0.3319 0.014238 420

3 0.2452 0.010517 570

4 0.181 0.00777 770

5 0.134 0.00574 1

, 000

1 TTR = Default assumption that 0.2% of application rate available as TTR on day 0. Dissipation rate and oxon conversion d ata from MRID

44799001. Total TTR, ug/cm 2 = [ (oxon residue, ug/cm 2 ) * 50 X TAF] + [bensulide residue, ug/cm 2 )

2 Daily Dermal Dose = [DFR (μg/cm 2 ) × Transfer Coefficient × 0.001 mg/μg × 8 hrs/day × dermal absorption ( 10 %)]  BW ( 69 kg).

3 MOE = POD ( 6 mg/kg/day) / Daily Dermal Dose.



### Restricted Entry Interval

Bensulide is classified as Toxicity Category III via the dermal route, Toxicity Category IV for dermal irritation, and Toxicity Category III for eye irritation. It is not a skin sensitizer. Under 40 CFR 156.208 (c) (2), ai’s classified as Acute III or IV for acute dermal, eye irritation and primary skin irritation are assigned a 12

- hour REI. However, s teady

- state post

- application risk

estimates were a concern up to Day 5 for golf course maintenance activities. T herefore, HED is recommending that the REI be revise d on the label to address those concerns.Page 31 of 41



### Appendix A. Summary of Occupational and Residential Non

- cancer Algorithms

Residential Non

- cancer Handler Algorithms

Dermal and Inhalation Handler Exposure Algorithm Daily dermal and inhalation exposure (mg/day) for residential pesticide handlers, for a given

formulation

- application method combination, is estimated by multiplying the formulation

application method

- specific unit exposure by an estimate of the amount of active ingredient handled in a day, u sing 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/ft 2 

### , lb ai/gal); and A = area treated or amount handled (e.g., ft 2 

### /day, gal/day).

Residential Handler Dose Algorithm Dermal and/or inhalation absorbed doses normalized to body weight are calculated as:

D = E *AF / BW

where:

D = dose (mg/kg

- day); E = exposure (mg/day); AF = absorption factor (dermal and/or inhalation); and BW = body weight (kg).

Residential Non

- cancer Post

- application Algorithms

Post

- application Dermal Exposure Algorithm

– Physical Activities on Turf Exposure resulting from contacting previously treated turf while performing physical activities is calculated as shown below. Residential pos t

- 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:Page 32 of 41



### E = exposure (mg/day); TTRt = turf transferable residue on day t (μg/cm 2 

### ); CF1 = weight unit conversion factor (0.001 mg/μg); TC = transfer coefficient (cm 2 

### /hr); and ET = exposure time (hr/day).

If chemical

- specific TTR data are available, then s urface 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 TTR t 

### can be calculated using the following

formula:

TTR t 

### = AR * F * (1

- FD) t 

### * CF2 * CF3

where:

TTRt = turf transferable residue on day t (μg/cm 2 

### ); AR = application rate (lbs ai/ft 2 

### 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 10 8 

### μg/lb); and CF3 = area unit conversion factor (1.08 x 10

- 3 

### ft 2 

### / cm 2 

### or 2.47 x 10

- 8 

### acre/cm 2 

### ).

Dermal absorbed doses are calculated as:

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) 12.5 lb ai/acre

F Fraction of AR as TTR

following application (if

chemical

- specific data is unavailable) L/WP/WDG 0.01

Granules 0.002

F D Daily residue dissipation

(if chemical

- specific data is unavailable) (fraction) L/WP/WDG 0.1

Granules 0.1

TC L/WP/WDG Adults 180,000Page 33 of 41

Table A

- 1 : Turf (Physical Activities)

-- Inputs for Residential Post

- application Dermal Exposure

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

Transfer

Coefficient (cm 2 /hr) 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

BW Body Weight (kg) Adults 80

Children 1 < 2 years old 11 L/WP/WDG = Liquids/Wettable Powders/Water

- dispersible Granules



### Post

- application Hand

- to

- Mouth Exposure Algorithm

– Physical Activities on Turf Exposure from hand

- to

- mouth activity is calculated as follows (based on the algorithm utilized in

the SHEDS

- Multimedia model ):

E = [HR * ( F

M 

### * SA H 

### ) * (ET * N_Replen) * (1

- (1

- SE ) (Freq_HtM/N

- Replen) 

### )]

where:

E = exposure (mg/day); HR = hand residue loading (mg/cm 2 

### ); FM = fraction hand surface area mouthed / event (fraction/event); SAH = typical surface area of one hand (cm 2 

### ); ET = exposure time (hr/day); N_Replen = number of replenishment intervals per hour (inter vals/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

where:

HR = hand residue loading (mg/cm 2 

### );

Fai hands 

### = fraction ai on hands compared to total surface residue from dermal transfer coefficient study (unitless); DE = dermal exposure (mg); and

SA H 

### = typical surface area of one hand (cm 2 

### ).

Dose, normalized to body weight, is calculated as:Page 34 of 41



### where:

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 Hand

- to

- Mouth Exposure Algorithm

Notation Exposure Factor (units) Point Estimate(s)

Fai hands Fraction of ai on hands

from dermal transfer coefficient study (unitless) Liquid formulations 0.06

Granular formulations 0.027

DE Dermal exposure (mg) Calculated

SA H Typical surface area of one hand (cm 2 ), children 1 < 2 years old 150

AR Application rate

(mass active ingredient per unit area) 12.5 lb ai/acre

HR Residue available on the hands (mg/cm 2 ) Calculated via (DE * Fai hands )/SA H

F M Fraction hand surface area mouthed (fraction/event) 0.127

N_Replen Replenishment intervals per hour (intervals/hr) 4

ET Exposure time (hrs/day) 1.5

SE Saliva extraction factor (unitless) 0.48

Freq_HtM Hand

- to

- mouth events per hour (events/hr) 13.9

BW Body Weight

(kg) Children 1 < 2 years

old 11



### Post

- application Object

- to

- Mouth Exposure Algorithm

– Physical Activities on Turf Exposure from object

- to

- mouth activity is calculated as follows (based on the algorithm utilized

in SHEDS

- Multimedia):

E = [OR* CF1 * SAM O 

### * (ET * N_Replen) * (1

- (1

- SE O 

### ) (Freq_OtM/N_Replen) 

### )]

where:

E = exposure (mg/day); OR = chemical residue loading on the object on day “t” (ug/cm 2 

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

SAM O 

### = area of the object surface that is mouthed (cm 2 

### /event); ET = exposure time (hr/day); N_Replen = number of replenishment intervals pe r hour (intervals/hour);

SE O 

### = saliva extraction factor (i.e., mouthing removal efficiency); and Freq_OtM = number of object

- to

- mouth contact events per hour (events/hour).Page 35 of 41



### and

OR = AR * F O 

### * CF2 * CF3

where:

OR = chemical residue loading on the object (μg/cm 2 

### ); AR = application rate (lbs ai/ft 2 

### or lb ai/acre);

F O 

### = fraction of residue available on the object (unitless); CF2 = weight unit conversion factor (4.54 x 10 8 

### μg/lb); and CF3 = area unit conversion factor (1.08 x 10

- 3 

### ft 2 

### /cm 2 

### or 2.47 x 10

- 8 

### acre/cm 2 

### ).

Dose, normalized to body weight, is calculated as:

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) 12.5 lb ai/acre

F O Fraction of AR as OR following application 1 0.01

SAM O Surface area of object mouthed (cm 2 /event) 10

N_Replen Replenishment intervals per hour (intervals/hour) 4

SE O Saliva extraction factor (fraction) 0.48

ET Exposure time (hours per day) 1.5

Freq_OtM Object

- to

- mouth events per hour (events/hr) 8.8

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

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



### Post

- application Incidental Soil Ingestion Exposure Algorithm

– Physical Activities on Turf Exposure from incidental soil ingestion is calculated as follows:

E = SRt * SIgR * CF1

where: E = exposure (mg/day);Page 36 of 41



### 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

- F D 

### ) t 

### * CF2 * CF3 * CF4

where:

SR t 

### = soil residue on day "t" (μg/g); AR = application rate (lbs ai/ft 2 

### or lb ai/acre); FS = fraction of ai available in uppermost cm of soil (fraction/cm);

F D 

### = 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 10 8 

### μg/lb); CF3 = area unit conversion factor (1.08 x 10

- 3 

### ft 2 

### /cm 2 

### or 2.47 x 10

- 8 

### acre/cm 2 

### ); and CF4 = soil volume to weight unit conversion factor (0.67 cm 3 

### /g soil).

Dose, normalized to body weight, are calculated as:

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) 12.5 lb ai/acre

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

F D Daily residue dissipation (fraction) 0.1

SIgR Soil ingestion rate (mg/day) 50

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



### Post

- application Episodic Granular Ingestion Exposure Algorithm

– Physical Activities on Turf Exposure from incidental ingestion of pesticide pellets or granules is calculated as follows:

E = GIgR* FD * CF1Page 37 of 41



### where: E = exposure (mg/day); GIgR = ingestion rate of dry pesticide formulation (g/day); FD = fraction of ai in dry formulation (unitless); and CF1 = weight unit conversion factor (1,000 mg/g).

Dose, normalized to body weight, are calculated as:

where :
D = dose (mg/kg

- day);

E = exposure (mg/day); and

BW = body weight (kg).

Table A

- 5 : Turf (Physical Activities)

– Inputs for Residential Post

- application Episodic Granular Ingestion Exposure
Algorithm

Notation Exposure Factor (units) Point Estimate(s)

F D Fraction of active ingredient in dry formulation 12.5%

AR Application rate (lbs/A or lbs/1,000 ft 2 ) 12.5 lb ai/acre

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

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

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



### Post

- application Dermal Exposure Algorithm

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

follows:

E = TTRt * CF1 * TC * ET

where :

E = exposure (mg/day);

TTR t 

### = turf transferable residue on day "t" (μg/cm 2 

### ); CF1 = weight unit conversion factor (0.001 mg/μg); TC = transfer coefficient (cm 2 

### /hr); and ET = exposure time (hr/day).

and

TTRt = AR * F AR 

### * (1

- F

D 

### ) t 

### * CF2 * CF3

where :Page 38 of 41



### TTR t 

### = turf transferable residue on day "t" (μg/cm 2 

### ); AR = application rate (lbs ai/ft 2 

### or lb ai/acre);

F AR 

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

F D 

### = fraction of residue that dissipates daily (unit less);

t = post

- application day on which exposure is being assessed; CF2= weight unit conversion factor (4.54 x 10 8 

### μg/lb); and CF3 = area unit conversion factor (1.08 x 10

- 3 

### ft 2 

### /cm 2 

### or 2.47 x 10

- 8 

### acre/cm 2 

### ).

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

where :
D = dose (mg/kg

- day);

E = exposure (mg/day);

AF = absorption factor (dermal); and

BW = body weight (kg).

Table A

- 6 : 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 12.5 lb ai/acre

F AR Fraction of AR as TTR following application L/WP/WDG 0.01

Granules 0.002

F D Daily residue dissipation L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient (cm 2 /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



### 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 :Page 39 of 41



### E = exposure (mg/day);

TTR t 

### = turf transferable resid ue on day "t" (μg/cm 2 

### ); CF1 = weight unit conversion factor (0.001 mg/μg); TC = transfer coefficient (cm 2 

### /hr); and ET = exposure time (hr/day).

and

TTRt = AR * F * (1

- F D 

### ) t 

### * CF2 * CF3

where :

TTR t 

### = turf transferable residue on day "t" (μg/cm 2 

### ); AR = application rate (lbs ai/ft 2 

### or lb ai/acre); F = fraction of ai retained on turf (unitless);’

F D 

### = 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 10 8 

### μg/lb); and CF3 = area unit conversion factor (1.08 x 10

- 3 

### ft 2 

### /cm 2 

### or 2.47 x 10

- 8 

### acre/cm 2 

### ).

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

where :
D = dose (mg/kg

- day);

E = exposure (mg/day);

AF = absorption factor (dermal); and

BW = body weight (kg).

Table A

- 7 : 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) 12.5 lb ai/acre

F Fraction of AR as TTR

following application L/WP/WDG 0.01

Granules 0.002

F D Daily residue dissipation L/WP/WDG 0.1

Granules 0.1

TC Transfer Coefficient

(cm 2 /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 32Page 40 of 41

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 = e xposure (mg ai/day),

UE = u nit e xposure (μ g ai/ lb ai),

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

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

.

The daily doses are calculated using the following formula:

ADD= E * AF

BW

where:

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

E = e xposure (mg ai/day),

AF = absorption fa ctor (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

h andlers a re compared to the appropriate POD ( i.e.

, NOAEL) to assess the risk to occupational handlers for each exposure route. All MOE values a re calculated using the following formula:

MOE= POD

ADD

where:

MOE = m argin of e xposure: value used by HED to represent risk estimates (unitless),

POD = p oint of d eparture (mg/kg/day)

, and

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

.Page 41 of 41



### Occupational Non

- cancer Post

- application Algorithms

Potential daily exposures for occupational post

- ap plication workers are calculated using the following formulas:

E=TC * DFR t 

### * ET * 0.001 mg

ug

where:

E = e xposure (mg ai/day),

TC = t ransfer coefficient (cm 2 

### /hr),

DFR t 

### = d islodgeable f oliar r esidue on day “t” (μg/cm 2 

### ), and

ET = e xposure t ime (hours/day).

The daily doses are calculated using the following formula:

ADD= E * AF

BW

where:

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

E = e xposure (mg ai/day),

AF = absorption fa ctor (dermal and/or inhalation), and

BW = body weight (kg).

Margin of Exposure: Non

- cancer risk estimates for each scenario are calculated using a Margin of Exposure (MOE), which is a ratio of the toxicological endpoint to the daily dose of concern. The daily dermal dose received by occu pational post

- application workers is compared to the appropriate POD ( i.e.

, NOAEL) to assess the risk to occupational post

- application workers

. All

MOE values a re calculated using the following formula:

MOE= POD

ADD

where:

MOE = margin of exposure: valu e 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).