Office of Pesticide Programs9
Comparison of Allender, RDFgen, and
 MaxLIP Decomposition Procedures
                February 1,2000
         Presented to FIFRA Scientific Advisory Meeting
                March 1,2000

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                          List of Abbreviations




BDL        Below Detection Limit




CDF        Cumulative Distribution Function




CLT        Central Limit Theorem




CV         Coefficient of Variation




DEEM      Dietary Exposure Evaluation Model




FIFRA      Federal Insecticide, Fungicide, and Rodenticide Act




IQR        Inter-quartile Range




LOD        Limit of Detection




LOQ        Limit of Quantitation




MaxLIP     Maximum Likelihood Imputation Procedure




MLE        Maximum Likelihood Estimation




POP        Pesticide Data Program




RDFgen     Residue Data File Generator




SAP        Scientific Advisory Panel




SD         Standard Deviation

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                           Table of Contents


EXECUTIVE SUMMARY	5

I. INTRODUCTION	7

II. DECOMPOSITION PROCEDURES UNDER CONSIDERATION	9
      A. MaxLIP Method	10
      B. RDFeen Method	12
      C. Allender Method	13

III. COMPARISON OF PROTOCOLS AND METHODS	14
      A. Comparison Using Theoretical Distributions 	.'	16
      B. Comparison Using Empirical Distributions
             	19
            1. Novartis Single-Serving Peach Study 	20
            2. POP Single Serving Potato Study 	21
            3. POP Single-Serving Special Study	22

IV.  RESULTS OF COMPARISON	25
      A. Results from Theoretical Analysis	25
            1. Highly skewed distribution. 30 composites. Uncensored	26
            2. Moderately skewed distribution. 30 composites. Censored (33%)	29
            3. Moderately skewed distribution. 10 composites, uncensored	32
            4. Moderately skewed distribution. 10 composites, censored (33%)	34
            5. Two Moderately skewed distributions. 25% overlap. 15 Composites per
                  distribution.  Censored (33%)	37
            6. Two Moderately skewed distributions. 10% overlap. 15 composites per
                  distribution. Censored (33%)	39
      B. Results from Empirical Analysis	42
            1. Novartis Georgia Peach Study	42
            2. POP Potato Study	44
            3  POP Single Serving Special Study	44

V. SUMMARY OBSERVATIONS AND CONCLUSIONS	46

VI.  REFERENCES	47

VII. QUESTIONS FORPANEL	49

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FIGURES	52




Appendix 1	  A-l

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       EXECUTIVE SUMMARY

       On May 26, 1999, the Environmental Protection Agency's (EPA) Office of Pesticide
Programs (OPP) issued a draft document entitled "Use of the Pesticide Data Program (POP) in
Acute Risk Assessment" which identified a statistical methodology for applying existing
information from the U.S. Department of Agriculture's (USDA) Pesticide Data Program (PDF)
report to risk assessments of the acute exposure to pesticide residues in food (see 64 FR 28485-
28487; also see EPA's web page~www.epa.gov/pesticides). This methodology (hereafter
referred to as the "Allender method") provided a statistical procedure for estimating single-
serving pesticide residue distributions from distributions of composite samples of fruits and
vegetables. OPP has used the Allender method to generate and then incorporate single-serving
data into a probabilistic exposure estimation model, such as the Monte Carlo method, in order to
estimate acute dietary exposure to pesticide residues in foods.

       In May, 1999, OPP also presented the Allender "decompositing" method to the SAP for
its scientific review and recommendations.  As part of its presentation, OPP acknowledged a
number of limitations and inadequacies in this methodology. Although the SAP stated, "EPA
has identified a reliable statistical methodology for applying existing information from the U.S.
Department of Agriculture's (USDA) Pesticide Data Program (POP)," the Panel nevertheless
recommended that OPP actively explore  the feasibility of using other methods (specifically,
maximum likelihood methods with censored data) which might better deal with the issues
associated with acute dietary exposure estimation.  Several public commenters in response to the
above-cited May 26,1999 FR Notice also made this recommendation. Accordingly, OPP has
investigated available alternative methods and compared them to OPP's current method.

       The purpose of this document is to provide an update on the issues being addressed
by OPP concerning the decompositing procedure and the progress, to date, on its
investigations into alternate methods.  This paper briefly describes the three decomposition
methods under consideration and provides details on OPP's comparison of these procedures: (a)
the "Allender method," (b)  "MaxLIP" by JSC Sielken/Novartis and "RDFgen" by Novigen
Sciences [the authors of the MaxLIP and RDFgen methodologies are providing additional
background information in their separate presentations to the SAP]. OPP invites the SAP to
compare the characteristics and behavior of these three methods and to make recommendations,
if desired, as to which method might be most suitable for decompositing field trial, market
basket, POP, or other food residue data for use in probabilistic acute dietary (food) exposure
estimation.

       OPP's comparison of the different methods was done by using both (a) theoretical data
designed to reflect differences in such characteristics as skewness, censoring, number of samples,
and number of distributions and (b) empirical (real world) pesticide data collected by USDA's
Pesticide Data  Program (POP) and others. Based on this analysis, OPP makes the following
observations with respect to the three decomposition methods and their performance
characteristics when applied to both theoretical  and empirical (actual) data:

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       (1)  Based on the analysis using both hypothetical and empirical data sets, estimates of the
high percentiles of daily exposure calculated using residues measured in composite samples are
much lower than estimated exposures using "decomposited" residue values. Composite residue
values tend to underestimate daily exposure by 30% - 50% at the upper percentiles.

       (2) All methods appeared comparable and seemed to do reasonably well at predicting
single-item residues at up to approximately the 90th percentile, regardless of the data set which
was used. This was true of both the theoretical and empirical datasets. As the number of
distributions increased, moderate censoring was imposed, or number of data points decreased, the
ability of the methods to predict the upper percentile residue values appeared to deteriorate to
varying degrees.

       (3) The presence of multiple distributions and censoring appear to have the most effect on
each methods ability to adequately deconvolute residue values while skewness of the distribution
and number of composite residue values seemed to have the least.

       (4) In many cases, the RDFgen and Allender procedures appeared to predict too large a
"spread" in the data, particularly in the lower percentiles. Nevertheless, this did not appear to
affect the exposures (as predicted by DEEM) in the region of regulatory interest (e.g., >95th
percentile)

       (5) Despite the findings in (2) and (4) above, the  most accurate decompositing method
rarely overestimated or underestimated the exposure of the 99.9th percentile by more than 15%,
compared to the calculation using the parent  data set, when using hypothetical data.  The
differences between the estimates obtained using the best method and the parent data set were
even smaller at lower percentiles.

       (6) All methods seemed be able to predict the 99.9th percentile exposure (as determined
by DEEM) reasonably well and no method appeared to have a significant bias toward over- or
under-prediction. At the 99lh percentile exposure and below, the methods appeared to be
essentially equivalent, with each method predicting the same exposure as the original (parent
data).

       In addition to seeking the SAP's comments and recommendations, OPP will shortly make
its analysis comparing the above three decompositing methods available  for public comment
along with additional information on MaxLIP and RDFgen.  After consideration of the SAP's
comments and all public comments received, OPP will issue a revised policy.

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I.  INTRODUCTION

       In March, 1998, OPP's Health Effects Division presented a draft Monte Carlo guidance
document to the FIFRA Scientific Advisory Panel. As part of this guidance document, OPP
stated that it:

              ... will not allow use of monitoring data as a distribution of residues for
              most raw commodities,  because data from composite samples do not
              adequately represent the range of residues in a single serving size sample,
              and the relationship between the residues measured in a composite sample
              and the range of residues in the individual samples that  make up the
              composite is not established for most chemical/commodity combinations.
              From limited data that are available, OPP has observed that residues in
              single serving samples can be higher by an order of magnitude or more than
              residues in the corresponding composite sample. While field trial data are
              also based on composite samples, they are generally measured at the "farm
              gate." Because residues  may decline during shipping, handling, and/or
              processing before food consumption at the "dinner plate," field trial data
              are considered sufficiently conservative for use in an acute dietary risk
              assessment.

       In short, OPP was concerned that unit-to-unit variation in pesticide residues within a
composite sample could be significant and could potentially result in significant underestimates
of acute risk if such calculations relied on residue data based on residue levels in composite
sample.  OPP believed that this issue deserved further attention since individual residues in a
composite sample can at times significantly exceed the average residues which would be
measured in a composite sample.

       The March 1998 SAP agreed with OPP stating:

              ...the use of monitoring data derived  from composite  samples seems
              inappropriate for direct use in acute dietary unchanged exposures for those
              reasons described. It is clear that if the Agency is protecting  against
              single-day exposures, it would  be inappropriate to utilize composite
              samples for evaluating acute risks... It would be incorrect to use these data
              from composite samples without adjustment.
       In May, 1999, OPP returned to the SAP with this issue, proposing a methodology
(Allender method) for "decompositing" the residues obtained from composite samples.  That is,
the methodology, when applied, would permit the use of monitoring data from PDF, FDA or
other monitoring programs in which residue data are collected on composite samples to be
"statistically adjusted" such that the residues on individual items which comprise that composite
can be simulated. As stated in OPP's background document for the SAP session,

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              The challenge to OPP has been to extrapolate from POP composite data to
              provide single unit values for use in acute risk assessments. In statistical
              terms, given composite samples collected by the USDA, OPP is faced with
              the  challenge of  estimating  the parameters  that  describe the  original
              population of residue concentrations in servings of fruits or vegetables.
              Specifically, the problem  is to estimate the population mean u and  the
              population variance (o2) from a set of composite samples where only the
              composite sample mean (x_bar), the composite sample variance (s2), and
              the number of units in each composite is known. With the estimation of the
              population parameters (u and o2) and assuming that the distribution of
              residues in  fruits and vegetables  follows a lognormal  distribution  (as
              established in previous goodness-of-fit studies), the function that describes
              chemical residues on fruits/vegetables is adequately established and ready
              for application into one of the components of the Monte-Carlo model for
              the acute risk assessment.
       As part of its presentation, OPP acknowledged a number of limitations and inadequacies
in the OPP-proposed methodology.  For example, OPP stated that the methodology assumes that
the individual items which comprise the composite sample are selected at random and are
independent. In reality, the sampling program is designed such that the individual units in any
given composite likely share the same treatment history and thus the individual units within a
composite are not randomly selected.  In addition, the procedure assumes that there is no
correlation between individual item residues in a composite sample; in reality, there is likely to
be at least some correlation because of the shared treatments. Finally, the proposed procedure
generally requires a minimum of 30 composites which have residues which exceed the limit of
detection in order to assure that there is enough representation in the sample such that there is
adequate simulation of the entire range of potential single serving residues.

       Although the SAP stated that "EPA has identified a reliable statistical methodology for
applying existing information from the U.S. Department of Agriculture's (USDA) Pesticide Data
Program (POP)," the Panel nevertheless recommended that OPP actively explore the feasibility
of using other methods (specifically, maximum likelihood methods with censored data) which
better deal with the issues associated with the  exposure estimation issues that were the focus of
this session.  Specifically, the Panel indicated  that it was encouraged by the methodology and
data introduced by a public commenter, and, although the Panel were unable to critically review
this information, it encouraged OPP to conduct further exploration and either adopt this
methodology or incorporate the concepts presented into the methodology which is ultimately
selected.

       As a follow-up to the  SAP's recommendations, OPP has been investigating methods
which could be used to better estimate single-item residue distributions from distributions of
composite residue measurements.  The purpose of this current background document is to
provide an update on the issues being addressed by OPP concerning the decomposing

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procedure and the progress, to date, on its investigations into alternate methods.  This paper
briefly describes three decomposition methods under consideration and provides details on
OPP's testing of these procedures.  OPP invites the SAP to compare the characteristics and
behavior of these three methods and to make recommendations, if desired, as to which method
might be most suitable for decompositing field trial, market basket, PDP, or other food residue
data for use in probabilistic acute dietary (food) exposure estimation.

       This document is divided in six sections. Section I is this introduction which discusses
past SAP reviews and comments on the issue of composite sampling and acute risk assessment.
Section II of this document provides general background information on the decomposition
procedures under consideration and being presented to the SAP.  Specific, and more detailed,
background documents for each of the three decomposition methods have been provided to the
panel and are also available in the Public Docket. Section III of this document describes some of
the standardized sample data sets and procedures (but not results) used to investigate how well
the model-predicted single-item values correspond to actual single-item values from whence the
composite samples came. This is done for theoretical data sets (which were specifically generated
to simulate as many real-world data anomalies as possible) in which "back-prediction" of
original (theoretically-based) single-item values by the proposed decomposition routines from
simulated composites as  well as with actual (empirical) data sets generated by USDA's PDP and
others.  The generated data (i.e., predicted single-serving residues) resulting from application of
each of the three decomposition methodologies is presented in Section IV and compared to the
original data which the decomposition methodologies were designed to reproduce. The next
section (Section V) summarizes overall OPP observations and conclusions regarding these
methods and their abilities to predict a single-serving distribution from  a distribution of residues
in a composite sample. References are presented in Section VI. Finally, the questions which OPP
would like to have addressed by the SAP are presented in the last section (Section VII).
II.  DECOMPOSITION PROCEDURES UNDER CONSIDERATION

       Three decomposition procedures are being presented to the SAP for their review and
consideration. One procedure (Allender Method) was formally presented to a previous SAP
during May 1999 and was reviewed by the SAP at that time.  Also introduced to the SAP  at that
time by public commenters were two additional procedures which the Panel was asked to
consider: the MaxLIP (for Maximum Likelihood Imputation Procedure) decomposition method
which relied on maximum likelihood estimation techniques for censored data and RDFgen, a
method introduced by Novigen Sciences.  A brief introduction to each of the three procedures is
provided below. Additional information concerning the details of each method is being provided
as supplementary material to the SAP and is being introduced into the relevant OPP docket.

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A. MaxLIP Method

       One method OPP is  investigating was a method introduced at the May, 1999 SAP by Dr.
Robert L. Sielken, Jr. of JSC Sielken and Dr. Leslie Bray of Novartis Crop Protection.  This
method (called MaxLIP for Maximum Likelihood Imputation Procedure) is a three-step
procedure which uses maximum likelihood estimation techniques and Monte Carlo simulation to
estimate the distribution of single serving residue concentrations from a database of composite
residue concentrations.  The final estimate provided by MaxLIP is a distribution of single-item
residue concentrations which is applicable for use in a probabilistic dietary risk assessment for
food items that are generally consumed individually or in small numbers.

       Briefly, the procedure consists of three major steps:

             STEP 1: This step consists of using a maximum likelihood estimation (MLE)
             technique to determine the parameters of a lognormal distribution of single-item
             residues that would, via Monte Carlo techniques, generate the best'approximation
             to the observed sample distribution of composite residue concentration values. In
             essence, the MLE procedure is used to generate a lognormal distribution of the
             single-item residue concentrations (or a mixture of up to five lognormal
             distributions if the measured composite residues are assumed to have come from a
             series of distinct lognormal distributions) that is "most likely" to have generated
             the observed  sample of measured composite residue concentrations. The result of
             this step is an estimated mean and variance of a lognormal distribution (or a series
             of means and variances of lognormal distributions if more than one source
             distribution is assumed) that maximize the likelihood function. Since  there are no
             closed-form solutions for the mean and standard deviation that maximize the
             likelihood function, MaxLIP uses computer-intensive numerical search
             procedures.   Although this step of the method assumes that the distribution of
             residues in treated single-servings from whence the composite residue
             concentrations came is lognormal, the method makes no implicit assumption
             concerning the distribution of composite residue concentrations (i.e, the
             distribution of composite residues is not assumed to be lognormal or any other
             specific distribution).1 This step can incorporate such factors as percent crop
             treated, treated composites containing non-detectable (
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              serving residues to be derived from up to five independent lognormal
              distributions, and uses imputation procedures for "below limit of detection"
              (BDL) observations, rather than assigning these to be '/•> LOD or aggregating these
              as one single-valued ('/z LOD) part of the distribution.

              STEP 2: Given the lognormal distribution of single-item residues generated in
              Step 1 (or the series of up to five lognormal distributions), Step 2 of the MaxLIP
              procedure consists of repeatedly sampling the single-item residue distribution to
              generate samples of single servings which, when composited, match the
              composite residue concentrations present in the composite sample database. This
              step uses the (lognormal) approximating, single-item distribution to generate a set
              of single-item residue values which more closely match the specific, observed
              composite residue values present in the database. This step provides a distribution
              of single-item residue concentrations which is more robust than the distribution
              produced in STEP 1  in that it better matches the observed composite residue
              concentrations and is less dependent on the theoretical characteristics of the parent
              lognormal distribution, or series of distributions, of single-item residues
              generated in STEP 1.

              STEP 3:. Step 3 provides the option to perform Steps 1 and 2 not only for a single
              lognormal distribution but also for a mixture of two, three, four, or five lognormal
              distributions. The MaxLIP user can run the MaxLIP software specifying that 1, 2,
              3,4, or 5 lognormal distributions be considered. Each such run would
              deconvolute the composite distribution into a mixture of the specified number of
              singe-item residue distributions. The result would include a separate mean,
              standard deviation, and proportion for each separate distribution as well as the
              joint log-likelihood value.  The user can compare these log-likelihood values
              using a likelihood ratio test to determine the statistical significance of the different
              log-likelihood values for different mixtures.2  It is the responsibility of the user to
       2 For example, the user may choose to deconvolute the distribution of composite values
into between one and five separate distributions, each of which has its own separate and
associated mean, standard deviation, proportion and loglikelihood. If the user chose to
deconvolute the composite input distribution into two separate and distinct distributions, one
result of the deconvolution might be one lognormal distribution with a mean of 2.34 ppm and a
standard deviation of 2.06 ppm comprising 62% of the sample, with a second distribution with a
mean of 1.32 ppm and a standard deviation of 0.78 ppm comprising 38% of the sample.
Associated with this deconvolution into two separate distributions would be a loglikelihood
value which would be used to test if two distributions were significantly better than one
distribution or significantly worse than three distributions. It is the responsibility of the user to
select the appropriate number of distributions into which the input distribution is deconvoluted
(between one and five) based on the program's  output of the loglikelihood value and the results
of the user-initiated and conducted likelihood ratio test.

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              select the appropriate number of distributions into which the input composite
              distribution is deconvoluted (between one and five) based on what is expected
              from agricultural practice and/or based on the program's output of log-likelihood
              values and the results of the user-conducted likelihood ratio test3

B. RDFeen Method

       A second method of decompositing composite residues into their constituent individual
components was presented by Novigen Sciences, Inc. In the methodology used under this
scheme, each observed composite sample is assumed to be comprised of individual, single-items
whose (unmeasured) residues are obtained from a lognormal distribution with a mean residue
equal to the measured residue in the composite sample from which the single-item residues are
derived. In addition, the standard deviation associated with the individual residue values in each
composite is a function of the standard deviation of the measured composite samples
(specifically, the assumed standard deviation is equal to the product of the standard deviation
calculated from the composite samples and the square root of a user-estimated average or typical
number of single items within a composite).  This latter calculation is derived from the Central
Limit Theorem4. For each measured composite sample (comprised of individual items whose
defined mean is equal to the measured composite residue value), individual residue values are
selected from a simulated lognormal distribution with the defined mean and standard deviation
via a Latin Hypercube simulation.  Sampling is continued until such time as the mean of the
individual single-sample residues selected is within 5% of the measured composite
       J Testing of the MaxLIP program by OPP revealed some inconsistencies in the MaxLIP-
generated loglikelihood values. This was communicated to Dr. Sielken who indicated that this
was likely a result of the iteration procedure locating a local maximum as opposed to a global
maximum and that this would be corrected in subsequent versions of MaxLIP. OPP believes that
the anomolous decreases in the loglikelihood values as the number of specified distributions is
increased and the occasional generation of unrealistic means and standard deviations are
symptomatic of this situation and will be eliminated in a subsequent version of MaxLIP.

       "Briefly, the distribution of composite sample residues represents a distribution of sample
means since the measured value in a composite sample is simply the mean of the residues in the
single-item units making up the composite.  The Central Limit Theorem states that the
distribution of these means (i.e., the distribution of the measured composite sample residues) will
be nearly normal provided the sample size is sufficiently large: this is true regardless of the
nature of the specific distribution of the single-item residues.  The Central Limit Theorem goes
on to state that the standard deviation of the means (i.e., the standard deviation of the composite
sample measurements) is ol(N'2) where a is the standard deviation of the parent population and
TV is the size of each sample (here, the number of items in a composite). Thus, it is possible to
estimate the standard deviation (and variance) of the  parent population of residues by taking the
product of the standard deviation of the composites and the square root of the number of items in
each composite.

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concentration. For treated composite samples with DDL observations, the RDFgen methodology
assumes that residues are present at !/2 LOD (and thus the composite residue will be
decomposited into a series of single-serving residues whose mean value is !/2 LOD).  Such a
process is repeated for each composite value until a distribution of single-item residue
concentrations is generated which corresponds to (and is consistent with) each sampled
composite. The result is a series of synthesized single-item pesticide residue concentrations
which can be used in a probabilistic exposure assessment5.
C.  Allender Method

       The Allender procedure was originally presented to the SAP in May, 1999 and the initial
background material made available to the SAP at that time has been made available again to the
current SAP. The method is applied only to composite samples with detectable residues, with a
separate single-valued distribution at '/z LOD assumed for the treated non-detects. Briefly, the
method relies on three pieces of information to estimate a distribution of single-item
concentrations: (i) the mean of each composite sample collected; (ii) the number of samples
collected (n); and (iii) an estimated average number of units within each sample (N). The method
proceeds in two steps:

       (1)     Calculation of the mean and variance of the sample composite values6; and

       (2)     Adjustment of the composite sample variance estimated in (1) above to correct for
              the number of single-item units comprising the composite.

Specifically, step (2) above consists of multiplying the variance obtained in (1) by  \/N, in
accordance with the Central Limit Theorem (CLT). That is, the Allender method assumes that
       5 The background document prepared by Novigen Sciences on the DEEM software
program presents a recent modification of the RDFgen program which OPP has not had the
opportunity to use or test in its comparison protocol. The modification proposed by Novigen
incorporates the concept of a coefficient of variation in refining the estimate of the sample
standard deviation and is expected to produce an estimate single-serving distribution which
would be considerably "narrower" than the one currently produced by the version of RDFgen
currently available to OPP for testing.

       6 The background paper presented to the SAP in May, 1999 indicated that the mean and
standard deviation of the composite samples were to be calculated on a log-basis (i.e., the
composite residue values were to be log transformed, with the mean and standard deviation of
the log-transformed values calculated. These log-transformed would then to be converted back
to the real scale by using back-transformation formulae). The Allender calculation done in the
present paper does not perform this  transformation and the means and standard deviations are
calculated directly from the data with no intermediate log-transformation.

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there is one (lognormal) distribution or residues in single-items from which the composite
sample is obtained, that the assignment of each item to a composite is random and independent
(and that no correlations between residues in a composite are present), and the CLT applies.

       The information developed in steps (1) and (2) (namely an estimated mean and standard
deviation of the distribution of single-item residues) is then used to create the individual values
that comprise this (lognormally-distributed) population and are used as individual item residue
inputs in OPP's acute dietary risk assessments.

       Overall, then, two of the three methods (Allender and RDFgen) use the standard deviation
of the composite samples to calculate the standard deviation of a parent distribution (by way of
the CLT and Nl/2 factor). The Allender method assumes that the composites are derived from a
single (common) lognormal parent distribution from which all composites samples are obtained,
while the RDFgen method assumes that each composite is derived from its own unique
lognormal distribution with  a mean equal to the mean of the specific composite sample and a
standard deviation equal to Nl/2 * SD of all composites. Each of these methods assigns a value of
'/2 LOD to treated samples with BDL residues and uses an average or typical number of items in a
composite to estimate the standard deviation of the single-serving population.  In contrast, the
third method under consideration (MaxLIP) uses a maximum likelihood estimation procedure to
estimate the "most likely" (or series of up to five "most likely") distributions from which the
observed distribution of composite residues might be seen. Residue values associated with
treated BDL samples (i.e., censored observations) are imputed using MLE techniques, and  the
number of items in each composite (as opposed to an average of typical number over all
composites) is explicitly considered. In a second step, the MaxLIP method produces from  this
distribution a series of single-serving values which, when composited, would (nearly) exactly
match the  "observed" composite distribution.

       Given these similarities and differences in the basic approach, OPP believes it to be
useful to subject a series of standardized data sets to each of the three decomposition
methodologies being presented to the SAP.  The design of this comparison is discussed in
Section III, while the results of the comparison are discussed in Section IV.
III. COMPARISON OF PROTOCOLS AND METHODS

       In order to understand better the three decomposition methodologies being presented to
the SAP, OPP initiated a protocol to evaluate the distribution of model-predicted single-item
residue concentrations developed from composite data. The protocol used both actual measured
(i.e., empirical) and simulated (theoretical) single-item residue concentrations. OPP believes that
it is appropriate to use both empirical and theoretical data in comparing the three decomposition
schemes (Allender method, Novigen's RDFgen, and JSC Sielken's MaxLIP) because no single
set of data, considered separately, permits a wide range of conditions and situations to be fully
considered and evaluated. Given the nature of the residue values and data collection protocol,
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OPP believes that it is important that each method be evaluated and compared through as
comprehensive a set of data and conditions as possible.

       This section provides details of the protocol used to compare each of the three proposed
decomposition methods. The protocols cover both the testing of theoretically-generated data and
empirical (real-world) data. OPP considers the use of theoretical distributions and their
artificially-generated (simulated) composites to be useful since it allows for controlled
investigation of the impact of important real-world factors (such as skewness of the distribution,
level of censoring, presence of multiple distributions, and the number of available composite
values) on the simulated computer-generated single-serving residues.  Although limited in
quantity and availability, the  use of empirical data from specially conducted composite/single-
serving studies is similarly considered to be valuable since it permits comparisons between
decomposited data based on actual' analytical measurements of residues in composited samples
and the corresponding residues measured on a single-item basis.

       The comparison was conducted in two parts in accordance with the above rationale. The
first part involved comparing the predictive capabilities of the three decomposition protocols
based on theoretical data which was artificially generated to meet testing requirements (e.g,
varying skewness, degree of censoring, number of component distributions, etc). The second
part involved comparing the prediction capabilities of the three decomposition protocols based
on empirical data which was produced by PDP (including a discussion of PDP data on aldicarb
on potatoes and analysis of a second recent special study conducted by PDP which has not yet
been formally released) and industry (diazinon on peaches) as part of a series of special studies
designed to investigate the composite-single serving relationship.  These are described in further
detail below.

       The comparison protocol used by OPP did not incorporate a number of factors which can
be considered and incorporated by one or more of the decomposition procedures being presented
to the SAP. For example, the theoretical analysis done here did not incorporate percent crop
treated factor, assumed a uniform number of items in a composite, considered that each
composite was comprised of only treated items, and assumed random assignment of single items
to a composite (no correlation of residues within  a composite).  Although the degree of censoring
was evaluated, censoring was limited to 33%. In reality, censoring of PDP or other monitoring
data may be substantially higher than this. Nevertheless, OPP believes that the analysis
conducted may serve as a useful adjunct to the Panel in  assessing the ability of each
decomposition method bing presented to adequately predict residues in single-serving items.
A. Comparison Using Theoretical Distributions

       The objective of this first part of the comparison scheme was to evaluate each of the three
methodologies described above in reliably "back-predicting" a given log-normal parent
distribution of single-item residues, with each decomposition procedure's "back-prediction"
                                           15

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ability based on a set of simulated composites (10 or 30 composites of 15 "items" each)
developed (or chosen) from the parent distribution7.

       The accuracy of the predicted distribution was assessed by evaluating how well the
model-generated single serving data "match" or otherwise compare to the original data. Such a
comparison was done by comparing how well the predicted mean, standard deviation,
interquartile range, absolute range or spread, and upper-percentile residue values generated (or
implied) by each methodology match with the corresponding statistics associated with the
original, or "test", parent distribution. This comparison of numerical values such as the predicted
vs. original mean, predicted vs. original standard deviation, etc. was extended (and more
effectively conveyed) by also examining graphical plots of the distributions and performing one
or more statistical tests which compare the equality of distributions. A wide variety of graphical
methods have been developed for this manner of exploration including frequency histograms,
stem and leaf plots, dot plots, line plots for discrete distributions, box and whisker plots, and one-
way scatter plots. These graphical methods are all intended to permit visual inspection of the
density function corresponding to the distribution of the data and can assist in examining the data
for skewness, behavior in the tails, rounding biases, presence of multi-modal behavior, and data
outliers. Some of the specific graphical and other analyses which were performed in this
decomposition method comparison are described below:

       One-way scatter and box-and-whisker plots can be a very effective graphic display for
       summarizing the distribution of a data set. They permit  not only a graphical point-by -
       point comparison of two or more distributions, but also effectively display various
       significant percentiles (e.g., 25th, 50th, 75th etc) and outlying (or extreme) data points. Box
       plots provide easily explained and comprehended visual summaries of:

              • the center of the data (median - the center line of the box)

              • the spread in the data (inter-quartile range - the box length)
       7 Specifically, a composite value is simply the average of the items comprising that
composite. Thus, as an example, a total of 450 single items were randomly selected from a
defined parent distribution (e.g., a lognormal distribution with an arithmetic mean of 0.1 and a
standard deviation of 0.1) using Crystal Ball software.  A total of 30 composite values were
simulated by averaging the generated values from the parent distribution in contiguous blocks
consisting of 15 values each.  Thus, the first 15 values were averaged to produce the estimate of
the first composite, the second contiguous block of 15 were averaged to produce the second
composite value etc. until the last contiguous block of 15 is averaged to produce the 30th
composite. In this way, a total of simulated 30 composite values are generated which can be
entered into the decomposition software in an attempt to "re-create" the original parent
distribution. Each decomposition routine was  assessed by comparing how closely the generated
values (or the distribution of generated values) matched those of the original lognormal parent
distribution with defined mean and standard deviation.

                                            16

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       • the skewness (quartile skew - the relative size of the box halves)

       • the range (whiskers - lines from the ends of the box to some other elected
       endpoint, e.g., the last data point within a distance of 1.5x the inter-quartile range
       (IQR) from the mean.)

       In the box plots used in this paper here (for an example, see Figure 1), the
whiskers extend to the last data point within one step beyond either end of the box,
where a step is defined as 1.5 times the inter-quartile range. Data points beyond 1.5 steps
of either end of the box are plotted as individual points. The values at the extreme left and
right ends of the box plots represent the natural log of the concentrations for the overall
minimum and maximum values, respectively (considering values from all methods
together). The dots below each box plot are a one-way scatter plot with each point
representing one original or predicted residue value. The density of points (or degree of
dithering) in the one-way scatter plot represents the probability density of the values.
When constructed in this manner, the box plot provides a rapid visual impression of the
prominent features of the data. The median (or central line within the box) shows the
location of the center of the data. The spread of the central 50% of the data is represented
by the length of the box.  The length of the whiskers (relative to the box)  show how
stretched the tails of the distribution are and provide and indication of the skewness of the
data. Individual points which extend beyond the whiskers are  outside values which may
be further investigated and provide clues as to the distributional form. If the distribution
is symmetric (e.g., as with a normal distribution), the box will  be divided into two equal
halves by the median, the upper-  and lower- end whiskers will be the same length, and
the number of extreme data points will be distributed equally on either end of the plot.

Frequency histograms are a second method by which two or more distributions can be
compared and is a convenient and readily-understood way of communicating
distributional information (see Figure 1  for an example). A frequency histogram is a
graphical estimate of the empirical probability density function.  Frequency histograms
can be plotted on both linear and logarithmic scales. In the histograms used in this
document, the distribution is plotted on a logarithmic  scale, so a "normal" curve here
represents lognormal data.

Empirical O-O  (quantile-quantile) plots can be particularly effective in making detailed
comparisons of distributions of two sets of data and are constructed by plotting in a two-
dimensional scatter plot the quantiles of the first distribution against the quantiles of the
second. If two distributions are identical, then all the  plotted points will lie on a 45
degree straight line (y=x). The location and magnitude of departures from this "y=x"line
emphasize differences between the two distributions. Q-Q plots tend  to emphasize
differences in the tails of a distribution (as opposed to P-P plots in which  differences in
the central portion of the distribution are emphasized). In the empirical Q-Q plots shown
in this document, the residues are log-transformed.
                                     17

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       Kolmogorov-Smirnov two-sample test statistics are not visual plots per se, but rather a
       calculated statistic which evaluates the null hypothesis of two identical populations.
       Specifically, the Kolmogorov-Smirnov Test is a non-parametric test based on the
       maximum absolute difference between the theoretical and sample cumulative distribution
       functions (CDFs). Large values of this statistic indicate a poor fit, while small values
       indicate a good fit. The Kolmogorov-Smirnov test is most sensitive around the median
       and less sensitive in the tails and is best at detecting shifts in the empirical CDF relative
       to the known CDF. Because it is specific to continuous data, it is often considered more
       appropriate than the chi-square test which is intended for use with categorical data.
       Although generally considered to be less proficient at detecting differences in spread
       among distributions, the Kolmogorov-Smirnov two sample test is considered to be more
       powerful than the chi-square test.
       In addition, the comparison procedure initiated by OPP evaluated the "robustness" of
each of the three proposed decomposition methodologies to various perturbations or
characteristics of the data. The residue data typically available to OPP are rarely "perfect" from a
statistical standpoint. That is, samples are frequently small (e.g., <30), are often considerably
skewed (with a long right tail), are frequently moderately to heavily censored at the limit of
detection or quantitation, and are likely to be comprised of a "mixture" of distributions with
varying (and unknown) proportions. Thus, OPP believes that any proposed decompositing
methodology must be sufficiently "rugged" to adequately deal with these situations. Therefore,
OPP tested each proposed methodology by varying the following parameters in an attempt to
better simulate real-world data which each method would be expected to adequately deal with:

              N. the number of composites which are collected. As N decreases from 30
              composite residue values to  10, the ability of each proposed methodology to
              accurately predict the original parent distribution is expected to diminish. The
              ability of each method to predict the parent distribution based on decreasing
              numbers of composite samples was evaluated. OPP considers it important that
              any method used be able to adequately decomposite samples with as few as ten or
              so samples with detections.

              CV. the coefficient of variation of the parent distribution. As the skewness (or
              "tailedness") of the original parent distribution increases from a CV of 0.5 (low
              skew), to a CV of 1.0 (moderate skew), to a CV of 2.0 (high skew), the  ability of
              each method to accurately predict the original parent distribution was assessed8.  It
              was expected that as the skewness increases from low to high skew, the ability of
              each method to predict the original parent distribution would decrease.  It is
       8 The results of the analyses conducted with parent populations with low skew (CV=0.5)
are not shown in this paper. Overall, all three proposed decomposition methods performed
reasonably well under these circumstances.

                                           18

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             important that any method selected be able to effectively decomposite samples
             from moderately- to highly-skewed parent populations.

             Level of censoring.  As the composite values become increasingly censored
             [increasing from no censoring (0%) to moderate censoring (33%)], the ability of
             each methodology to adequately predict the parent distribution was assessed.  The
             decomposition methodology selected should appropriately consider censored data
             and be able to adequately predict the parent distribution when moderate to heavy
             censoring is present.

             Number of separate parent distributions.  As the number of separate parent
             distributions is increased from one to two, the ability of each method to
             adequately predict the original distribution was assessed.  As composite samples
             will frequently be derived from multiple distributions, it is important that any
             decomposition methodology be able to adequately handle composites derived
             from multiple distributions.

The results of these analyses are presented in Section IV.
B. Comparison Using Empirical Distributions

       In an effort to investigate the decomposition methodologies' behavior with actual
measured residue data, a second part of the comparison procedure was performed by
decompositing a variety of actual data sets on which both composite and single-item residue
analyses have been performed.  These tests spanned a variety of data sets to include specially
conducted field trials in which all of numerous samples were obtained from a single field and
where all analyzed samples were subjected to the same (identical) pesticide treatment at the same
time.  In addition, the decompositing procedure was applied to data sets from USDA Pesticide
Data Program (POP) special studies specifically conducted to evaluate the variability in single-
item residue concentrations in composite samples and assess its significance. The three sample
data sets which were evaluated  or reviewed are presented below:

                     (1)    Industry-conducted single serving and composite analyses of
        diazinon on peaches

                     (2)    USDA PDF single serving and composite analyses of aldicarb on
                           potatoes

                     (3)    USDA PDP single-serving and composite analyses of a widely-
                                           19

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                           used agricultural pesticide on a common single-serving fruit item9.
       A brief description of each data set is presented below, along with a number of important
caveats that apply when using the above "real-world" composite analyses. The results of these
comparisons are presented in Section IV of this document.

       1.  Novartis Single-Serving Peach Study

       The first set of data which were decomposited by each decomposition method were
residue data from a trial conducted on peaches in Georgia in 1998. The pesticide was sprayed on
a peach orchard, with peaches harvested shortly after spraying10. A total of twenty composites
were collected with each composite comprising 10 peaches. Individual peaches were
homogenized and the homogenate split into two portions with one portion going to the composite
sample for ten peaches and the other bing used for the  single-serving pesticide residue analysis
for that peach.  This  resulted in a total of 20 composite analyses and 200 associated individual-
item analyses (10 per composite).

       OPP has used the 20 composite samples as input values for the three decomposition
routines to compare the predicted distribution with the measured residues in the 200 individually-
analyzed samples. Results of these analyses are presented in Section IV.
       2. POP Single Serving Potato Study

       In 1997, PDF conducted a special survey of aldicarb concentrations in single-item
potatoes in an effort to investigate the relationship between measured composite residues and
residues present in single potatoes that comprise that composite. This survey was initiated in
response to a request from EPA and was designed to re-evaluate the tolerance for use of aldicarb
       9 This data has not yet been officially released by USDA and has not been subjected to
their full QA/QC or reconciliation procedures. OPP's normal practice is to avoid the use of
USDA PDF data which is not available for public review and has not been publically released.
Nevertheless, USDA and OPP have agreed to make a one-time exception to their usual policy
and permit the limited release of this data provided that the name of the crop and pesticide were
not disclosed and the disclaimer made that QA/QC and reconciliation procedures have not been
completed. It is anticipated that formal release of this data and crop/pesticide identity will occur
in late February, 2000.

       10 For this trial, peaches were harvested before the label-specified pre-harvest interval in
an effort to maximize residue values and thus do not reflect residue concentrations which would
normally be encountered. All unsampled peaches from the test orchard were destroyed  in
accordance with the experimental nature of this trial.

                                           20

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on potatoes .  The survey targeted potato samples which originated in four states with registered
uses for aldicarb on potatoes (FL, ID, OR, and WA), and samples were collected for 13 months
from December 1, 1996 through December 31, 1997 by eight participating states.

       A total of 342 composite potato samples (consisting of 10 potatoes each) were analyzed
for aldicarb and its metabolites.  However, matched composite and single-serving analyses, were
performed on only a subset of the 342 collected composites. Specifically, for each of the
collected composite samples (consisting of 10 potatoes each), potatoes were washed and cut in
half lengthwise, with one-half of each potato separately labeled and frozen for possible later
single serving analysis if certain pre-established trigger criteria were  met. The remaining ten
half-portions were composited together for analysis. The analysis of these half portions was
conducted in batches (i.e., analytical sets) of 12-15 samples per batch". The limit of detection
for these analyses was either 0.004 ppm or 0.005 ppm depending upon the metabolite determined
(the sulfoxide or sulfone).

       Subsequent single serving analyses were performed by the laboratory on only those
stored, frozen single potatoes which corresponded to the highest composite measurements in
each batch or analytical set. That is, of the 28 analytical sets analyzed, only 16 sets contained
one or more samples with detectable levels of aldicarb or its metabolites and only the 10 single
serving halves associated with the highest composite in each of those 16 sets were analyzed.
Thus, for the purposes of the single-serving study, a total of 16 composite analyses and their 160
single-serving counterparts (10 per composite) were available. The study demonstrated the wide
variation in occurrence of residues within the single-serving samples when compared to the
reported composite value. Aldicarb sulfoxide individual serving results varied in magnitude by
up to 7.4 times the reported composite value while aldicarb sulfone in individual single-serving
results ranged up to 6.1 times the measured composite value.

       This study was NOT purposefully conducted to elucidate a general model for the
composite-single serving relationship since it selected only a very specific set of samples (namely
those with among the highest residues) to analyze on a matched composite/single serving basis.
For example, the 16 composite samples and their single serving counterparts selected for analysis
represented the highest reported value in a set which itself comprised 12-15 composite samples
and thus were not a random sample of potatoes. This study, instead,  was designed to be simply a
"first look" at how different concentrations in individual potatoes could be from the composite
sample from which they came and if concentrations in single potatoes could exceed the tolerance.
Thus, while the study supported the belief that concentrations in individual items in a composite
could be substantially higher than the composite value, the study is not particularly well-suited to
comparing the three decomposition methods under consideration since only composites with
detected or quantified residues above a certain trigger value were  subsequently analyzed on a
       11 That is, 12-15 samples were extracted and analyzed at the same time along with the
required QA/QC spikes, blanks, standards, and controls for that analytical set according to PDF
standard operating procedures (SOPs)

                                           21

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single-serving basis.  Thus, the PDF potato samples which were analyzed were not really a
random sample and this non-random sampling in the composite selection also led to a
nonrandom grouping of single servings within a composite with a bias toward high values.

       Given the limitations described above, OPP had elected not to attempt to use the aldicarb
data collected by PDP in its comparison procedures.

       3.  PDP Single-Serving Special Study

       Finally, PDP is currently conducting a single-serving study as an added component of its
national sampling plan. Sampling for this single-serving study was begun in January 1999 at half
the normal monthly sampling rate and is expected to continue through to December 1999. As
stated in III.B.3., the data have not been subjected to full QA/QC or reconciliation procedures
and have been released to the Agency with the caveat that the identity of the specific crop and
pesticide not be released until such time that formal public release of the data by USDA occurs.
Samples were collected according to established PDP sampling procedures. Composite samples
were formed by combining the halves of each often fruits selected for analysis.  An individual
fruit from the sample was selected for single-serving analysis12.  A total of 334 composite
samples were analyzed with one fruit from each composite removed and analyzed separately as a
single serving. This single-serving analysis was done regardless of the concentration detected in
the composite (i.e., there was no "trigger concentration" (as there was in the PDP potato single
serving study) which was required to be present in the composite before the single fruit was
analyzed).

       The analysis of this data, however, had to proceed somewhat differently than the analysis
of the theoretical data due to complications arising from use of "real-world" residues with the
significant intrinsic limitations detailed below:

       1) true zeroes (from untreated commodities) could not be differentiated from "below
       detection level" determinations (here O.006 ppm). That is, it was not known if a non-
       detect was due to a sample not being treated or due to it being treated but having
       concentrations less than the detection limit of 0.006 ppm

       2) all detectable levels which were between the detection limit of 0.006 ppm and the
       quantitation limit (i.e., three times this level or ca. 0.02 ppm) were censored and instead
       reported as one-half the quantitation limit. That is, if a residue was measured as present
       between 0.006 ppm and 0.02 ppm, it was reported by the laboratory as 0.01 ppm.

       3) Items (1) and (2) above resulting in a significant portion of the data being non-detect
       1 Beginning in May 1999, the PDP protocol was changed to require, at all times, analysis
of one of the remaining halves of the ten fruits comprising the composite. Therefore, results for a
single-serving sample are available for each corresponding composite for the entire year.

                                           22

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       (i.e., below detectable levels due to either absence of treatment or residue levels below
       the limit of detection) or being reported as one-half the LOQ (i.e., 0.01 ppm). OPP
       recognizes that a) many of the non-detects are truly not treated and therefore should not
       be decomposited; and b) the 0.02 ppm LOQ is an artificial constraint and the "true"
       single-item distribution of residues extends well below the 0.02 ppm censoring level- -
       that is, there is no true "spike " or agglomeration of residues at 0.01 ppm and this is only
       an artifact of the analytical method and reporting protocol.

       Given these limitations in the single-serving analyses and the requirement that these
single-serving analyses serve as the reference population (or "gold-standard" or benchmark) for
comparing the three decomposition methods being presented to the SAP, the following
assumptions were made in an attempt to "correct" the data to allow the use of the full distribution
as a standard reference population for comparison purposes:

       (1) If no detectable residue (i.e., residue was reported by PDP as <0.006 ppm) was found
       in analyses of either the single-item sample or the associated composite sample from
       which the single-item was obtained, OPP made the assumption that the sample was not
       treated and this was therefore removed from the data set and not included as part of the
       distribution of residues in treated commodities. This was true of 31% of the paired (i.e.,
       composite and associated single serving samples) samples, and thus a detectable residue
       was found in the composite sample and/or the associated single serving sample in
       approximately 69% of the cases. This compares favorably to estimates of the percent of
       the crop treated with the pesticide in question.13  Thus it seems reasonable to assume for
       purposes of this comparison protocol that if the pesticide of interest was not found in
       either the composite or the associated single-serving analysis, then the sample was not
       treated and should not be decomposited or considered as part of the distribution of treated
       commodities. This assumption removes 31% of the paired samples from the data set.

       (2) It was assumed that the residues in the remaining single-serving samples (i.e., 69% of
       the dataset) were lognormally distributed and that the true values which were associated
       with the approximately half of the data which were censored at 0.02 ppm could be
       adequately imputed by means of Helsel's Robust Method (Helsel 1990, ILSI, 1998) using
       Maximum Likelihood Estimation techniques. This was done with the result shown  in the
       normal probability plot on the following page (with residues plotted as their natural
       logarithms)14. As is apparent from the histogram and normal probability plot shown
       13 OPP's Biological and Economic Analysis Division estimated that approximately 64%,
76%, and 80% of the crop in question was treated with the pesticide of interest in 1996, 1997,
and 1998, respectively.

       14 A better characterization of the observations between the LOD (0.006) and the LOQ
(0.02) would be to treat them as censored values between 0.006 and 0.02 rather than just less
than 0.02. This could be incorporated into the MaxLIP procedure and substantially impact its

                                           23

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       below, the lower
       half of the
       distribution was
       imputed (using
       Helsel's method
       andMLE
       techniques) from
       the observed and
       measured residue
       values in the upper
       half of the
       distribution15.
       Given the resulting
       plot, OPP believes
       that this is a
       reasonable means of
       "filling-out" the remainder of the distribution. In any case, we note that, in our
       experience, the lower part of the distribution is generally less critical in the exposure and
       risk assessments performed by OPP and thus believe this to be a reasonable and
       appropriate attempt to generate an entire distribution of single-serving analyses as a
       standard to which the proposed decomposition methods can be compared.

       With the nature of the reference population established as described above, the composite
samples were decomposited using each of the three decomposition methodologies and compared
to the distribution of imputed and actual residues obtained from the single-serving analyses (i.e.,
both the actual residue measurements and-the imputed values based on Helsel's Robust method
and MLE techniques)16. Results of this comparison are shown in Section IV.
Normal Quantile
IV.  RESULTS OF COMPARISON

       The results of OPP's comparison of the three decomposition procedures being presented
characterization of the distribution below 0.02 ppm.

       15 The imputed portion of the distribution is shown in dark in the histogram and as large
X's in the normal probability plot.

       16 Actually, the comparison was not made directly with the entire distribution of
decomposited values, but rather with one randomly selected individual item from each
synthetically generated composite. This was done in order to permit a valid comparison with the
PDP single-item analyses since only one item from each composite was routinely selected for a
single-serving analysis.
                                           24

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to the SAP are presented in this section. As described earlier, the objective of this first part of
the comparison scheme was to assess the adequacy of each of the three methodologies described
above in "back-predicting" a given lognormal parent distribution of single-item residue. The
accuracy of the predicted distribution was assessed by determining how well the model-generated
single serving data "matched" or otherwise compared to the original data by comparing the
predicted mean, standard deviation, interquartile range, absolute range or spread, and upper-
percentile residue values generated (or implied) by each methodology to the corresponding
statistics associated with the original, or "test," parent distribution. The comparison was
extended to include examination of key graphical plots of the distributions and performing one or
more statistical tests specifically intended to assess  the equality of two distributions.

       To summarize, results from two sets of comparisons included (a) theoretical analyses
conducted with artificial parent/original distributions generated with specific means, standard
deviations, skewness, etc. and (b) empirical analyses conducted with PDF or industry-generated
data.  These analyses are each described and detailed below under "Results from Theoretical
Analysis" and "Results from Empirical Analysis," respectively.
A.  Results from Theoretical Analysis

       The results from each of the theoretical analyses discussed earlier in Section III.A. are
discussed in detail in this section. Each section below begins with a description of how the
standardized data were generated and used.  The statistical tests (including graphical
comparisons) are then described, followed by a table which compares various key statistics, and a
second table which compares exposures (on a normalized basis) which would be predicted at
various percentiles when the individual values are used as residues in the DEEM exposure
assessment software. The intent of this latter information is to evaluate whether differences in
predicted pesticide residue distributions result in significant differences in predicted pesticide
exposures at the upper percentiles of regulatory interest to OPP.

       1. Highly skewed distribution. 30 composites. Uncensored

       OPP first investigated the ability of each of the three decomposition methods to
"reproduce" the single-item components from a heavily  skewed (CV=2) lognormal distribution
which was uncensored.  Specifically, 450  random "draws" were made from a lognormal
distribution with a fixed mean of 0.10, a fixed standard deviation of 0.20 (both on an arithmetic
scale), and a coefficient of variation of 2 (by definition). This was done with Crystal Ball
software and the resulting distribution of individual values was termed the parent or "original"
distribution.  A total of 30 "sets" consisting of 15 consecutive values each were created from
these 450 values and the arithmetic mean  of each of the 30 sets was determined. This procedure,
in effect, simulated the compositing process which occurs when 15 single-item units are
combined and result in one measured residue concentration being reported which is equal to the
                                           25

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weighted-arithmetic average of the component single-item units17.

       For this analysis, the set of 30 composite values was not artificially censored (i.e., all
values were retained). These values were then used as input to each of the three decomposition
programs which created (from only the information contained in the 30 averages, or simulated
composite values) a set of 450 simulated single item values which was expected to "match" or
otherwise reasonably reproduce the parent or original  distribution (which, as indicated
previously, consisted of 450 random draws from a lognormal distribution with mean equal to
0.10 and standard deviation equal to 0.2)

       Detailed graphical and statistical results of these analysis are shown in Attachment 1.
Briefly, one method of assessing the accuracy of the predicted distribution is to evaluate how
well the model-generated single serving data "match" or otherwise compare to the original data.
Such a comparison was done by evaluating how well the predicted mean, standard deviation,
interquartile range, absolute range or spread, and various upper-percentile residue values
generated (or implied) by each methodology with the corresponding statistics which are
characteristic of the original, or "test", parent distribution.  In addition, statistical tests
specifically designed to compare (on a non-parametric basis) the equality of two distribution
were used as were a variety of graphical plots designed to highlight differences and similarities
between the original parent data and the synthetic distributions generated by each of the three
decomposition procedures.

A tabular summary of various specific statistics characteristic of the parent (and theoretical) and
 decomposition routine-generated values is shown in Table  1:
       17 This procedure is not precisely equivalent to the compositing procedure used by PDF in
that in the procedure used by PDF, units making up the composite are correlated (generally
coming from the same field and having been subjected to the same treatment practice), while the
procedure used here randomly draws from the entire distribution and the samples are independent
and uncorrelated. Nevertheless, there is not normally a correlation coefficient available for PDF
composite samples and the assessment methodologies used here to compare the decomposition
methods are believed to be adequate to compare the strengths and weaknesses and overall
adequacy of the methods.

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Table 1 . Comparison of Parent and Theoretical Single-Item Distributions With Single-Unit
Distributions of Values Generated from Three Decomposition Methods (Highly
skewed distribution, 30 composites, Uncensored)
Statistic
Mean
± SD
Q
U
A
N
T
I
L
E
S
min
0.50
0.75
0.90
0.95
0.99
max
IQRb
K-S statistic"
(p value)
Distribution
Theoretical8
0.1000
± 0.2000
0.0000
0.0447
0.1046
0.2269
0.3582
0.8595
OO
~
-
Parent"
(original)
0.10017
± 0.1898
0.0012
0.0446
0.1051
0.2268
0.3614
0.8992
2.5308
0.0861
-
Allender
0.1003
± 0.1566
0.0021
0.0529
0.1133
0.2246
0.3400
0.7650
1.9224
0.0886
0.0778
(0.115)
Novigen
0.0985
± 0.1263
0.0011
0.0489
0.1186
0.2440
0.4452
0.5309
0.7023
0.0996
0.0467
(0.682)
MaxLIP-1"
0.1003
± 0.1543
0.0016
0.0516
0.1131
0.2288
0.3532
0.7560
1.6195
0.0899
0.0578
(0.408)
aThe parent distribution represents the distribution of the 450 generated values, while the
theoretical distribution represents the mean, standard deviation (SD), and various selected
percentiles of the lognormal distribution with mean = 0.1000 and SD = 0.2000
b Interquartile Range. This represents the difference between the 75th and 25th percentiles.
c Kolmogorov-Smirnov Two-sample Test Statistic with associated p-value.
d MaxLIP with 1 lognormal distribution estimated.
       A histogram as well as a one-way scatter plot (with associated box and whisker plot)
which compares the distribution of the 450 values from each of the three generated distributions
with the 450 values from the original test distribution is shown in Figure 1. Additional, more
detailed information regarding the distribution of predicted values (included comparative
empirical Q-Q plots, Kolmogorov-Smirnov statistics, additional summary descriptive measures,
etc.) is presented in Appendix 1.

       OPP also evaluated whether potential differences in the distribution of model-predicted
single item values (or residues) might lead to significant differences in predicted exposure levels
at various percentiles as calculated by DEEM (Dietary Exposure Evaluation Model) software.
DEEM is the software used by OPP to estimate the distribution of (acute) exposures to the
general U.S. population and various population subgroups of interest. DEEM does this by
combining reported food consumption figures from USDA's Continuing Survey of Food Intake
                                           27

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by Individuals (CSFII) with randomly selected pesticide residue concentrations generally
available from industry-conducted field trials and/or USDA or FDA monitoring data. While it is
true in general that differences in the distribution of residues used as one of many inputs to the
DEEM model would be expected to produce differences in exposure estimates at various
percentiles, it is not necessarily true that these estimated exposure differences at the high end
percentiles of particular regulatory interest to OPP are large or even significant from a regulatory
perspective. That is, it may be that, despite the differences in "predicted" single-item residue
concentrations among methods, predicted exposures at various regulatory thresholds of interest
may not be significantly different.

       To test this arid evaluate potential differences in estimated pesticide exposures at the
upper percentiles resulting from differences  among the decomposition methods, OPP has used
the parent distribution and model-predicted (decomposited) values as residue concentrations in
the DEEM software and estimated exposures at the 99.9th, 99th, and 95th percentiles for two
groups (general U.S. population and children 1-6). This analysis  was done by each of the three
decomposition methods being assessed, with each DEEM  predicted "exposure" normalized (for
ease of comparison) to the exposure predicted by the original parent distribution at the 99.9th
percentile18. The analyses were done by assigning original and predicted values as residues to a
widely consumed fruit present in the DEEM consumption  database:  results and/or conclusions
might differ if a different commodity were selected or a set of commodities were analyzed
simultaneously.  For the data set presently being evaluated, normalized exposures as predicted by
DEEM for various percentiles are shown in Table 2:
Table 2. Comparison of Normalized Exposures by Decomposition Method (Highly skewed
distribution. 30 composites, Uncensored)
Method
Original
Allender
Novigen
Normalized Exposure"
(relative to DEEM-predicted exposures from original distribution at 99.9th
percentile)
General U.S. Population
99.9th
1
0.89
0.80
99th
0.27
0.23
0.25
95th
0.08
0.06
0.07
Children 1-6
99.9th
1
0.88
0.70
99th
0.27
0.26
0.28
95th
0.08
0.08
0.08
       !8As a hypothetical example, if the DEEM-estimated exposure for the original parent
distribution was 10 mg/kg bw/day and was 12, 14, and 16- mg/kg bw/day for the Allender,
Novigen, and MaxLIP procedures (all at the 99.9th percentile) and 6, 7, and 8 mg/kgbw/day (all
at the 99th percentile), normalized relative exposures for the Allender, Novigen, and MaxLIP
procedures would be 1.2, 1.4, and 1.6, respectively for the 99.9th percentile and 0.6, 0.7, and 0.8
at the 99th percentile, respectively.
                                           28

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MaxLIP
Composites
0.89
0.46
0.24
0.19
0.06
0.08
0.88
0.40
0.27
0.18
0.08
0.09
 3 Normalized exposures all relate to exposure at the 99.9th percentile (as estimated by DEEM) for
 the original data. These analyses were done by assigning original or decomposition-predicted
 values as residues to a widely consumed fruit present in the DEEM CSFII (USDA Continuing
 Survey of Food Intake by Individuals) database. Results would be expected to differ if another
 commodity was selected or several food commodities were simultaneously analyzed.  The
 residues (and chemical) are hypothetical, and no toxicity value was assigned.  Interpretation of
 the normalized exposures presented in this table should therefore be done with the understanding
 that the DEEM-estimated exposures in the table are relative to an arbitrarily-assigned baseline
 value, and no health-based implications should be inferred.
       2.  Moderately skewed distribution. 30 composites. Censored (33%)

       OPP next investigated the ability of each of the three decomposition methods to
"reproduce" the single-item components from a moderately skewed (CV=1) lognormal
distribution which was censored at 33%. Specifically, 450 random "draws" were made from a
lognormal distribution with a mean and standard deviation each equal to 0.10 (on an arithmetic
scale), and a coefficient of variation of 1 (by definition). This was termed the parent or
"original" distribution. As before, a total of 30 "sets" consisting of 15 consecutive values each
were created from these 450 values and the arithmetic mean of each  of the 30 sets calculated in
an attempt to simulate a compositing process.  However, the set of 30 composite values was then
artificially censored by assigning a default "less than" concentration to all values up to the value
representing the 33rd percentile (i.e., the lowest 10 values were to be  considered as treated "non-
detects" with default values assigned in accordance with the requirements of the protocol to the
decomposition method.19)  These values were then used as input to each of the three
decomposition programs which were used to create (from only the information contained in the
30 averages, or simulated composite values) a set of 450 simulated single item values which was
expected to "match" or otherwise reasonably reproduce the parent or original distribution
       19 Specifically, a total of 10 of the 30 composite values generated were assigned to be
"less than detect" values where the detection limit was determined by the next higher value
which was retained. For the Allender method, the 10 "less than detects" were dropped because
the Allender method decomposites only detected values, with the treated non-detects assigned to
a different residue pool; for the Novigen RDFgen procedure, these values were assigned values
of !/2 the detection limit; for the MaxLIP procedure (which used MLE methods to impute values
for these ND residues), the censored values are treated exactly as censored values "less than" the
detection limit without having to be replaced with a specific selected value below the detection
limit.  For consistency in comparison, the histograms and one-way box/scatter plots illustrated in
this document for the Allender method do not show these values (which represent treated non-
detect residues) which would normally appear as a prominent peak or bulge of values at Vz LOD.
                                           29

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consisting of 450 random draws from a lognormal distribution with mean and standard deviation
equal to 0.10.  This was done in an effort to compare each method's ability to use moderately-
censored data and still obtain reasonable estimates of the distribution of original single-serving
values.

       Detailed graphical and statistical results of these analysis are shown in Appendix 1. As
before, a comparison between the predicted mean, standard deviation, interquartile range,
absolute range or spread, and various upper-percentile residue values generated (or implied) by
each methodology with the corresponding statistics which are characteristic of the original, or
"test", parent distribution and its theoretical counterpart was made to assess how well the model-
generated single serving data matched or compared to the original parent data. In addition,
statistical tests specifically designed to compare (on a non-parametric basis) the  equality of two
distributions was used as were a variety of graphical plots designed to highlight  differences.and
similarities between the original parent data and the synthetic distributions generated by each of
the three decomposition procedures.

       A tabular summary of various specific statistics characteristic of the parent (and
theoretical) and decomposition routine-generated values is shown below in Table 3:
Table 3.
Comparison of Parent and Theoretical Single-Item Distributions With Single-Unit
Distributions of Values Generated from Three Decomposition Methods
(Moderately skewed distribution, 30 composites. Censored (33.3%))

Statistic
Mean
± SD
Q
U
A
N
T
1
L
E
S
min
0.50
0.75
0.90
0.95
0.99
max
IQRb
K-S statistic0
(p-value)
Distribution
Theoretical3
0.1000
± 0.1000
0.0000
0.0707
0.1235
0.2053
0.2770
0.4920
00
-
~
Parent"
(original)
0.1000
± 0.0991
0.0064
0.0705
0.1241
0.2045
0.2848
0.5068
1 .0000
0.0836
-
Allender
0.1124
± 0.0793
0,p146
0.0916
0.1411
0.2067
0.2663
0.4135
0.6952
0.0812
0.1756
(0.000)
Novigen
0.0885
± 0.1153
0.00008
0.0455
0.1069
0.2388
0.3681
0.5110
0.5975
0.0910
0.2422
(0.000)
MaxLIP1d
0.0982
+ 0.1066
0.0031
0.0640
0.1228
0.2168
0.2937
0.5383
0.9512
0.0893
0.0711
(0.182)
                                            30

-------
 "The parent distribution represents the distribution of the 450 generated values, while the
 theoretical distribution represents the mean, standard deviation  (SD), and various selected
 percentiles of the lognormal distribution with mean  = 0.1000 and SD = 0.1000.
 b Interquartile Range. This represents the difference between the 75th and 25th percentiles.
 c Kolmogorov-Smirnov Two-sample Test Statistic with associated p-value.
 d MaxLIP with 1 lognormal distribution estimated.
       A histogram and one-way scatter plot (with associated box and whisker plot) which
compares these distributions is shown in Figure 2. Additional, more detailed information is
presented in Appendix 1.

       As before,  OPP evaluated if potential differences in the model-predicted single serving
values might lead to significant differences in predicted exposure levels at various percentiles as
determined by DEEM (Dietary Exposure Evaluation Model) software. Also as before, this
procedure was followed for each of the three decomposition methods being assessed, with each
DEEM predicted "exposure" normalized to the exposure predicted by the original* parent
distribution at the 99.9th percentile.  For the data set presently being evaluated, normalized
exposures are shown in Table 4:
Table 4. Comparison of Normalized Exposures by Decomposition Method
(Moderately skewed distribution, 30 composites. Censored (33%)
Method
Original
Allender
Novigen
MaxLIP
Composites
Normalized Exposure'
(relative to DEEM-predicted exposures from original distribution at 99.9th
percentile)
General U.S. Population
99.9th
1
0.94
1.09
1.03
0.61
99th
0.33
0.35
0.34
0.33
0.26
95th
0.11
0.12
0.09
0.10
0.10
Children 1-6
99.9th
1
0.9
1.03
1.02
0.56
99th
0.37
0.37
0.4
0.38
0.26
95th
0.14
0.16
0.12
0.14
0.13
a Normalized exposures all relate to exposure at the 99.9th percentile (as estimated by DEEM) for
the original data. These analyses were done by assigning original or decomposition-predicted
values as residues to a widely consumed fruit present in the DEEM CSFII (USDA Continuing
Survey of Food Intake by Individuals) database. Results would be expected to differ if another
commodity was selected or several food commodities were simultaneously analyzed. The
residues (and chemical) are hypothetical, and no toxicity value was assigned. Interpretation of
the normalized exposures presented in this table should therefore be done with the understanding
that the DEEM-estimated exposures in the table are relative to an arbitrarily-assigned baseline
value, and no health-based implications should be inferred.
                                            31

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       3.  Moderately skewed distribution. 10 composites, uncensored
       OPP next investigated the ability of each of the three decomposition methods to
"reproduce" the single-item components from a moderately skewed (CV=1) lognormal
distribution with mean and standard deviation equal to 0.1 and which consisted of only 10
values.  Specifically, only the initial 150 random draws from the original 450 random draws from
the aforementioned lognormal distribution (i.e., mean = standard deviation = 0.1) were used.
These 150 values were deemed to be the parent or "original" distribution. As before, a total of
10 consecutive "sets" consisting of 15 values each were created from these 150 values and the
arithmetic mean  of each of the resulting 10 sets calculated. These values were then used as input
to each of the three decomposition programs which were used to create a generated set of 150
simulated single item values which was expected to "match" or otherwise reasonably reproduce
the parent or original distribution consisting of the initial 150 random draws. This was done in
an effort to compare each method's abilities to use minimal data and still obtain reasonable
estimates of the distribution of original single  serving values.

       Detailed graphical and statistical results of these analysis are shown in Appendix 1. As
before,  a comparison between the predicted mean, standard deviation, interquartile range,
absolute range or spread, and various upper-percentile residue values generated (or implied) by
each methodology  with the corresponding statistics which are characteristic of the original, or
"test," parent distribution was made to assess how well the model-generated single serving data
matched or compared to the original parent data. In addition, statistical tests specifically
designed to compare (on a non-parametric basis) the equality of two distributions were used as
were a variety  of graphical plots designed to highlight differences and similarities between the
original parent data and the synthetic distributions generated by each of the three decomposition
procedures.

       A tabular summary of various specific statistics characteristic of the parent and
decomposition routine-generated values is shown in Table 5:
Table 5. Comparison of Parent and Theoretical Single-Item Distributions With
Distributions of Values Generated from Three Decomposition Metho(
(Moderately skewed distribution, 10 composites, uncensored)

Statistic
Mean + SD
Single-Unit
Js
Distribution
Theoretical'
0.1000
± 0.1000
Parent"
(original)
0.0994
±0.0938
Allender
0.0992
±0.0992
Novigen
0.0980
±0.0936
MaxLIPl"
0.1010
±0.1133
                                           32

-------
Q
U
A
N
T
1
L
E
S
min
0.50
0.75
0.90
0.95
0.99
max
IQRb
K-S statistic0
(p-value)
0.0000
0.0707
0.1235
0.2053
0.2770
0.4920
00
-
-
0.0064
0.0705
0.1241
0.2045
0.2848
0.5153
0.6099
0.0838
-
0.01
0.07
0.12
0.21
0.29
0.55
0.65
0.08
0.0667
(0.866)
0.0024
0.0660
0.1281
0.2227
0.3116
0.4372
0.4563
0.0948
0.0867
(0.574)
0.0046
0.0639
0.1232
0.2254
0.3207
0.5856
0.7774
0.0909
0.0867
(0.574)
"The parent distribution represents the distribution of the 150 generated values, while the
theoretical distribution represents the mean, standard deviation (SD), and various selected
percentiles of the lognormal distribution with mean = 0.1000 and SD = 0.1000
b Interquartile Range. This represents the difference between the 75th and 25th percentiles.
c Kolmogorov-Smirnov Two-sample Test Statistic with associated p-value.
d MaxLIP with 1 lognormal distribution estimated.
       A histogram and one way scatter plot (with associated box and whisker plot) which
compares these distributions is shown in Figure 3. Additional, more detailed  information is
presented in Appendix 1.

       OPP has evaluated if potential differences in the model-predicted single serving values
might lead to significant differences in predicted exposure levels at various percentiles as
determined by DEEM (Dietary Exposure Evaluation Model) software. For the data set presently
being evaluated, normalized exposures are shown below in Table 6:
Table 6. Comparison of Normalized Exposures by Decomposition Method
(Moderatelv skewed distribution. 10 composites, uncensored)
Method
Original
Allender
Normalized Exposure8
(relative to DEEM -predicted exposures from original distribution at 99.9th
percentile)
General U.S. Population
99.9th
1
1.03
99th
0.34
0.34
95th
0.11
0.11
Children 1-6
99.9th
1
1.04
99th
0.39
0.40
95th
0.15
0.15
                                           33

-------
Novigen
MaxLIP
Composites
0.99
1.12
0.64
0.34
0.36
0.28
0.11
0.11
0.12
0.96
1.16
0.62
0.41
0.43
0.29
0.15
0.15
0.15
 a Normalized exposures all relate to exposure at the 99.9th percentile (as estimated by DEEM) for
 the original data.  These analyses were done by assigning original or decomposition-predicted
 values as residues to a widely consumed fruit present in the DEEM  CSFII (USDA Continuing
 Survey of Food Intake by Individuals) database. Results would be expected to differ if another
 commodity was selected or several food commodities were simultaneously analyzed.  The
 residues (and chemical) are hypothetical, and no toxicity value was assigned. Interpretation of
 the normalized exposures presented in this table should therefore be done with the understanding
 that the DEEM-estimated exposures in the table are relative to an arbitrarily-assigned baseline
 value, and no health-based implications should be inferred.
       4. Moderately skewed distribution. 10 composites, censored (33%)

       OPP next investigated the ability of each of the three decomposition methods to
"reproduce" the single-item components from a small, moderately skewed (CV=1) lognormal
distribution which was also censored at 33%.  Specifically, only the initial 150 random draws
from the original 450 random draws from the aforementioned  lognormal distribution (i.e., mean
= standard deviation = 0.1) were used. These  150 values were designated as the parent or
"original" distribution. As before, a total of 10 consecutive "sets" consisting of 15 values each
were created from these 150 values and the arithmetic mean of each of the resulting 10 sets
calculated. However, as before, the set of 10 composite values was artificially censored by
assigning a default "less than" concentration to all values up to the value representing the 33rd
percentile [i.e., the lowest 3 values of the 10 were assigned treated "non-detects" status with
default values assigned in accordance with the requirements of the decomposition method
protocol (described in footnote 19)]. These values were then used as input to each of the three
decomposition programs which were used to create a generated set of 150 simulated single item
values which was expected to "match" or otherwise reasonably reproduce the parent or original
distribution consisting of the initial 150 random draws. This was done to investigate how the
different methods compared when there were was only minimal data, which was compounded by
issues of moderate censoring.

       Detailed graphical and statistical results of these analysis are shown in Attachment  1. As
before,  a comparison between the predicted statistics and the corresponding statistics which are
characteristic of the original, or "test," parent distribution was made to assess how well the
model-generated single serving data matched or otherwise compared to the original parent  data.
In addition, statistical tests specifically designed to compare (on a non-parametric basis) the
equality of two distributions was used as were a variety of graphical plots designed to highlight
differences and similarities between the original parent data and the synthetic distributions
generated by each of the three decomposition procedures.
                                            34

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       A tabular summary of various specific statistics characteristic of the parent and
decomposition routine-generated values is shown below in Table 7:
Table 7. Comparison of Parent and Theoretical Single-Item Distributions With Single-Unit
Distributions of Values Generated from Three Decomposition Methods (
Moderately skewed distribution, 10 composites, censored (33%))
Statistic
Mean
± SD
Q
U
A
N
T
I
L
E
S
min
0.50
0.75
0.90
0.95
0.99
max
IQR
K-S statistic
(p-value)
Distribution
Theoretical
0.1000
± 0.1000
0.000
0.0707
0.1235
0.2053
0.2770
0.4920
00

-
Parent
(original)
0.0994
± 0.0938
0.0064
0.0705
0.1241
0.2045
0.2848
0.5153
0.6099
0.0838
-
Allender
0.1036
± 0.0726
0.0199
0.0837
0.1249
0.1857
0.2472
0.3351
0.5693
0.0861
0.1600
(0.032)
Novigen
0.0900
± 0.1151
0.0008
0.0468
0.1135
0.2399
0.3713
0.4838
0.5740
0.0984
0.2333
(0.000)
MaxLIP1d
0.1011
± 0.1245
0.0032
0.0578
0.124
0.2375
0.334
0.6323
0.8681
0.0966
0.1333
(0.111)
3 The parent distribution represents the distribution of the 150 generated values, while the
theoretical distribution represents the mean, standard deviation (SD), and various selected
percentiles of the lognormal distribution with mean = 0.1000 and SD = 0.1000
b Interquartile Range. This represents the difference between the 75th and 25th percentiles.
c Kolmogorov-Smirnov Two-sample Test Statistic with associated p-value.
d MaxLIP with 1 lognormal distribution estimated.
       A histogram and one-way scatter plot (with associated box and whisker plot) which
compares these distributions is shown in Figure 4.  Additional, more detailed information is
presented in Appendix 1.

       OPP investigated whether potential differences in the model-predicted  single serving
values might lead to significant differences in predicted exposure levels at various percentiles as
determined by DEEM (Dietary Exposure Evaluation Model) software. For the data set presently
being evaluated, normalized exposures from DEEM are shown in Table 8:
                                           35

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Table 8.
Method
Original
Allender
Novigen
MaxLIP
Composites
Comparison of Normalized Exposures by Decomposition Method
(Moderately skewed distribution, 10 composites, censored (33.3%))

Normalized Exposure8
(relative to DEEM-predicted exposures from original distribution at 99.9th
percentile)
General U.S. Population
99.9th
1
0.94
1.09
1.04
0.64
99th
0.33
0.35
0.33
0.33
0.29
95th
0.10
0.12
0.09
0.10
0.12
Children 1-6
99.9th
1
0.90
1.03
1.02
0.61
99th
0.37
0.37
0.4
0.38
0.28 •
95th
0.14
0.16
0.12
0.14
0.15
a Normalized exposures all relate to exposure at the 99.9th percentile (as estimated by DEEM) for
the original data. These analyses were done by assigning original or decomposition-predicted
values as residues to a widely consumed fruit present in the DEEM CSFII (USDA Continuing
Survey of Food Intake by Individuals) database. Results would be expected to differ if another
commodity was selected or several food commodities were simultaneously analyzed. The
residues (and chemical) are hypothetical, and no toxicity value was assigned. Interpretation of
the normalized exposures presented in this table should therefore be done with the understanding
that the DEEM-estimated exposures in the table are relative to an arbitrarily-assigned baseline
value, and no health-based implications should be inferred.
       5. Two Moderately skewed distributions. 25% overlap. 15 Composites per distribution.
       Censored (33%)

       OPP next investigated the ability of each of the three decomposition methods to
effectively distinguish and "reproduce" the single-item components from two (25% overlapping)
moderately skewed (CV=1) lognormal distributions, each of which were censored at the common
33rd percentile.  Specifically, only the initial 225 random draws from the original 450 random
draws from the aforementioned lognormal distribution (mean and standard deviation each equal
to 0.10) were used. To this were added 225 additional random draws from a second lognormal
distribution with a mean and standard deviation of 0.31 (structured to have a 25% overlap with
the first distribution20).  These 450 values were designated to be the parent or "original"
distribution. A total of 15 "sets" consisting of 15 consecutive values each were created from
each of these 225 values and two arithmetic means of the resulting 15 sets were calculated.
       20 The second distribution was defined such that the 25th percentile of this distribution was
equal to the 75th percentile of the first distribution.
                                           36

-------
Censoring was performed by designating any value in the bottom third of the ranked combined
data set as "less than detect." All values (both those above and below the censoring limit) were
used with MaxLIP and RDFgen (i.e., BDL values were assigned as either one-half the censoring
limit in the case of RDFgen or as "less than" the censoring limit in MaxLIP). Since the Allender
method would assign these to a separate, single-valued distribution at '/z LOD, these were not
used (and simply dropped) in this method which consequently relied only on the uncensored
values. The composite values from each of the two distributions were then used as input to each
of the three decomposition programs. This was done to investigate how the different methods
compared when the parent distribution actually consisted of two overlapping distributions, and
the  combined data set was moderately censored.

       Detailed graphical and statistical results of these analysis are shown in Appendix 1. As
before, a comparison between the predicted statistics and corresponding statistics which are
characteristic of the  original parent distribution was made to assess how well the model-
generated single serving data matched or otherwise compared to the original parent data.  In
addition, statistical tests specifically designed to compare (on a non-parametric basis) the
equality of two distributions were used as were a variety of graphical plots designed to highlight
differences and similarities between the original parent data and the synthetic distributions
generated by each of the three decomposition procedures.

       A tabular summary of various specific statistics characteristic of the parent and
decomposition routine-generated values is shown in Table 9:
Table 9. Comparison of Parent Single-Item Distributions With Single-Unit Distributions of
Values Generated from Three Decomposition Methods (Two Moderately skewed
distributions. 25% overlap, 15 Composites oer distribution. Censored (33%))
Statistic
Mean
± SD
Q
U
A
N
T
I
L
E
S
min
0.50
0.75
0.90
0.95
0.99
max
IQR
Distribution
Parent (original)
0.2046
±0.2646
0.0064
0.1211
0.2476
0.4501
0.6375
1.2726
3.0600
0.1862
Allender
0.2748
± 0.5237
0.0041
0.1536
0.3106
0.5809
0.8562
1.890
9.082
0.2371
Novigen
0.1939
±0.3284
0.00003
0.0609
0.2058
0.5631
0.8685
1.629
1.875
0.1946
MaxLIP-2d
0.2084
±0.2106
0.0133
0.14
0.26
0.45
0.603
1.05
1.84
0.1715
                                           37

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K-S statistic
(p-value)
--
0.100
(0.018)
0.3133
(0.000)
0.0978
(0.022)
 aThe parent distribution represents the generation of two lognormal distributions of 225 values
 each, with means of 0.100 and 0.306 and standard deviations (SD) of 0.100 and 0.306,
 respectively.
 5 Interquartile Range.  This represents the difference between the 75th and 25th percentiles.
 c Kolmogorov-Smirnov Two-sample Test Statistic with associated p-value.
 d Likelihood  Ratio Test and other ancillary data indicated that MaxLIP  (2 distributions) provided
 the most appropriate fit to the data,  with  proportions of .0.52 and 0.48 for the two component
 distributions.  LogLikelihood1distr= -1.73;  LogLikelihood2distr = 7.31 (p<0.005);
 LogLikelihood3distr = 7.20 (p not calculated); LogLikelihood4distr = 9.75  (p>0.05). See Footnote 3
 for further explanation of these results.
       A histogram and one-way scatter plot (with associated box and whisker plot) which
compares these distributions is shown in Figure 5. Additional, more detailed  information is
presented in Appendix 1.

       OPP evaluated if potential differences in the model-predicted  single serving values might
lead to significant differences in predicted exposure levels at various percentiles as determined
by DEEM (Dietary Exposure Evaluation Model) software.  For the data set presently being
evaluated, normalized exposures are shown below in Table 10:
Table 10. Comparison of Normalized Exposures by Decomposition Method (Two Moderately
skewed distribution. 25% overlap, 15 Composites oer distribution Censored
(33%))
Method
Original
Allender
Novigen
MaxLIP
Composites
Normalized Exposure8
(relative to DEEM-predicted exposures from original distribution at 99.9th
percentile)
General U.S. Population
99.9th
1
1.53
1.25
0.89
0.64
99th
0.30
0.39
0.35
0.29
0.26
95th
0.09
0.11
0.08
0.09
0.09
Children 1-6
99.9th
1
1.51
1.18
0.84
0.58
99th
0.33
0.45
0.41
0.32
0.26
95th
0.11
0.14
0.1
0.12
0.12
                                            38

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 a Normalized exposures all relate to exposure at the 99.9th percentile (as estimated by DEEM) for
 the original data. These analyses were done by assigning original or decomposition-predicted
 values as residues to a widely consumed fruit present in the DEEM CSFII (USDA Continuing
 Survey of Food Intake  by Individuals) database. Results would be expected to differ if another
 commodity was selected or several food commodities were simultaneously analyzed. The
 residues (and chemical) are hypothetical, and no toxicity value was assigned. Interpretation of
 the normalized exposures presented in this table should therefore be done with the understanding
 that the DEEM-estimated exposures in the table are relative to an arbitrarily-assigned baseline
 value, and no health-based implications should be inferred.
       6.  Two Moderately skewed distributions. 10% overlap. 15 composites per distribution.
       Censored (33%)

       Finally, OPP investigated the ability of each of the three decomposition methods to
effectively distinguish and "reproduce" the single-item components from two (10% overlapping)
moderately skewed (CV=1) lognormal distributions, each of which were censored at the common
33rd  percentile. As before, only the initial 225 draws from the original 450 random draws from
the aforementioned (mean = SD = 0.1) lognormal distribution were used. To this were added
225 additional random draws from a second lognormal distribution with a mean and standard
deviation of 0.842.21  These 450 values were deemed to be the parent or "original" distribution.
A total of 15 "sets" consisting of 15 consecutive values each were created from each of these 225
values and two arithmetic means of the resulting 15 sets were calculated. Again, censoring was
performed by designating any value in the bottom third of the ranked combined data set as "less
than detect" and treating these values as per each decomposition methods protocol (see IV.A.5)

       Detailed graphical and statistical results of these analysis are shown in Attachment 1. As
before,  a comparison between the predicted mean, standard deviation, interquartile range,
absolute range or spread, and various upper-percentile residue values generated (or implied) by
each methodology with the corresponding statistics which are characteristic of the original, or
"test," parent distribution was made to compare  how well the model-generated single serving
data matched or otherwise compared to the original parent data. In addition, statistical tests
specifically designed to compare (on a non-parametric basis) the equality of two distributions
was used as were a variety of graphical plots designed to highlight differences and similarities
between the original parent data and the synthetic distributions generated by each of the three
decomposition procedures.

       A tabular summary of various specific statistics characteristic of the parent and
decomposition routine-generated values is shown below in Table  11:
       21 This produced a second distribution which overlapped the first by 10%

                                           39

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Table 1 1
Comparison of Parent and Theoretical Single-Item Distributions With Single-Unit
Distributions of Values Generated from Three Decomposition Methods (Two
Moderatelv skewed distribution, 10% overlap, 15 composites per distribution.
Censored (33%))

Statistic
Mean
± SD
Q
U
A
N
T
I
L
E
S
IQRb

min
0.50
0.75
0.90
0.95
0.99
max

K-S statistic'
(p-value)

Distribution
Parent (original)8
0.4797
±0.7463
0.0064
0.2064
0.6096
1.1940
1.6318
3.5892
8.4239
0.5387
-
Allender
0.6501
±1.1214
0.0075
0.2820
0.6936
1.5226
2.5007
5.9084
9.7446
0.4769
0.1311
(0.001)
Novigen
0.0464
±0.9708
4.69e-6
0.0755
0.4804
1.2613
2.0995
5.1883
6.2807
0.5768
0.3644
(0.000) >
MaxLIP-2"
0.4859
±0.7390
0.0103
0.199
0.581
1.23
1.84
3.71
6.86
0.4967
0.0511
(0.567)
"The parent distribution represents the generation of two lognormal distributions of 225 values
each, with means of 0.1000 and 0.8424 and standard deviations (SD) of 0.1000 and 0.8424,
respectively
b Interquartile Range. This represents the difference between the 75th and 25th percentiles.
0 Kolmogorov-Smirnov Two-sample Test Statistic with associated p-value.
d Likelihood Ratio Test and ancillary information indicated that MaxLIP (2 distributions) provided
the most appropriate fit to the data, with predicted proportions of 0.51 and 0.49 for the two
component distributions. LogLikelihoodldistr = -33.14; LogLikelihood2distr = -13.26 (p<0.005);
LogLikelihood3distr= -9.68 (p<0.05); Logl_ikelihood4distr = -11.17 (p>0.05) See Footnote 3 for
further explanation of these results.
       A histogram and one-way scatter plot (with associated box and whisker plot) which
compares these distributions is shown in Figure 6.  Additional, more detailed information is
presented in Appendix 1.

       OPP evaluated if potential differences in the model-predicted single serving values might
lead to significant differences in predicted exposure levels at various percentiles as determined
by DEEM (Dietary Exposure Evaluation Model) software. For the data set presently being .
evaluated, normalized exposures are shown below in Table 12:
                                           40

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Table 12. Comparison of Normalized Exposures by Decomposition Method (Two
Moderately skewed distribution, 10% overlap, 15 comoosites oer distribution.
Censored (33.3%))
Method
Original
Allender
Novigen
MaxLIP
Composites
Normalized Exposure3
(relative to DEEM-predicted exposures from original distribution at 99.9th
percentile)
General U.S. Population
99.9th
1
1.50
1.32
1.02
0.67
99th
0.28
0.39
0.32
0.29
0.26
95th
0.07
0.09
0.06
0.07
0.09
Children 1-6
99.9th
1
1.57
1.32
1.02
0.61
99th
0.32
0.44
0.38
0.34
0.27
95th
0.10
0.13
0.09
0.10
0.12
3 Normalized exposures all relate to exposure at the 99.9th percentile (as estimated by DEEM) for
the original data. These analyses were done by assigning original or decomposition-predicted
values as residues to a widely consumed fruit present in the DEEM CSFII (USDA Continuing
Survey of Food Intake by Individuals) database. Results would be expected to differ if another
commodity was selected or several food commodities were simultaneously analyzed. The
residues (and chemical) are hypothetical, and no toxicity value was assigned. Interpretation of
the normalized exposures presented in this table should therefore be done with the understanding
that the DEEM-estimated exposures in the table are relative to an arbitrarily-assigned baseline
value, and no health-based implications should be inferred.
B. Results from Empirical Analysis

       The results of the empirical analysis discussed in Section III.B. are discussed in detail in
this section. Each section below begins with a brief description of the specific study under
consideration. Statistical comparisons are then described, followed, as before, by a table which
compares various key statistics, and a second table which compares exposures (on a normalized
basis) which would be predicted at various percentiles were the individual values to be placed in
to the DEEM exposure assessment software.

       1. Novartis Georgia Peach Study

       The first set of data which were decomposited by each decomposition method were
residue data from an experimental field trial conducted by Novartis Crop Protection in Georgia in
1998. The pesticide was sprayed on a peach orchard, with peaches harvested shortly after
spraying. A total of twenty composites were collected with each composite comprising  10
peaches.  Both the composite sample and each individual peach within the composite were
                                           41

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analyzed for the pesticide resulting in a total of 20 composite analyses and 200 individual single
serving analysis (10 per composite).  OPP has used the 20 composite samples as input values for
the three decomposition routines.

       Detailed graphical and statistical results of these analysis are shown in Appendix 1. As
before, a comparison between the predicted mean, standard deviation, interquartile range,
absolute range or spread, and various upper-percentile residue values generated by each
methodology with the corresponding statistics which are characteristic of the actual single
serving data was made to compare the model-generated single serving data to the original parent
data.  In addition, statistical tests specifically designed to compare (on a non-parametric basis)
the equality of two distributions was used as were a variety of graphical plots designed to
highlight differences and similarities between the original parent data and the synthetic
distributions generated by each of the three  decomposition procedures.

       A tabular summary of various specific statistics characteristic of the parent and
decomposition routine-generated values is shown below in Table 13:
Table 13. Comparison of Novartis Peach Field Trial Study Single-Item Residue Distribution
With Single-Unit Distributions of Values Generated from Three Decomposition
Methods
Statistic
Mean
± SD
Q
U
A
N
T
I
L
E
S
min
0.50
0.75
0.90
0.95
0.99
max
IQRb
K-S statistic0
(p-value)
Distribution
Field trial data3
0.1446
± 0.2047
0.001
0.067
0.1855
0.4175
0.51
0.973
1.499
0.1660
--
Allender
0.1470
± 0.1921
0.000
0.08
0.17
0.36
0.525
1.025
1.43
0.13
0.2048
(0.000)
Novigen
0.1432
± 0.1754
0.0004
0.0757
0.1751
0.4211
0.5299
0.7604
0.7718
0.1509
0.0600
(0.837)
MaxLIP-1d
0.1439
± 0.2174
0.0033
0.0746
0.1607
0.3179
0.5110
1.1805
1.8706
0.1262
0.1600
(0.009)
                                            42

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 a This distribution represents the standard distribution for comparison purposes
 " Interquartile Range. This represents the difference  between the 75th and 25th percentiles.
 c Kolmogorov-Smirnov Two-sample Test Statistic with associated p-value.
 d Likelihood Ratio Test indicated that MaxLIP (1 distribution) provided the most appropriate fit to
 the data.  LogLikelihoodldistr = 28.65; LogLikelihood2distr = 30.43 (p>0.05); LogLikelihood3distr =
 31.99; LogLikelihood4distr = 34.71.
       A histogram and one-way scatter plot (with associated box and whisker plot) which
compares these distributions is shown in Figure 7. Additional, more detailed information is
presented in Appendix 1.

       OPP evaluated if potential differences in the model-predicted  single serving values might
lead to significant differences  in predicted exposure levels at various percentiles as determined
by DEEM (Dietary Exposure Evaluation Model) software.  For the data set presently being
evaluated, normalized exposures are shown below in Table 14:
Table 14. Comparison of Novartis Peach Field Trial DEEM-Predicted Exposures by Decomposition
Method
Method
Original (field trial)
Allender
Novigen
MaxLIPI
Composites
Normalized Exposure8
(relative to DEEM -predicted exposures from original distribution at 99.9th
percentile)
General U.S. Population
99.9th
1
0.95
0.96
0.95
0.67
99th
0.18
0.18
0.19
0.17
0.19
95th
0.01
0.01
0.01
0.03
0.03
Children 1-6
99.9th
1
0.97
0.9
1.0
0.53
99th
0.27
0.27
0.28
0.24
0.23
95th
0.02
0.03
0.03
0.03
0.06
a Normalized exposures all relate to exposure at the 99.9th percentile (as estimated by DEEM) for
the original data. These analyses were done by assigning original or decomposition-predicted
values as residues to a widely consumed fruit present in the DEEM CSFII (USDA Continuing
Survey of Food Intake by Individuals) database. Results would be expected to differ if another
commodity was selected or several food commodities were simultaneously analyzed. The
residues (and chemical) are hypothetical, and no toxicity value was assigned. Interpretation of
the normalized exposures presented in this table should therefore be done with the understanding
that the DEEM-estimated exposures in the table are relative to an arbitrarily-assigned baseline
value, and no health-based implications should be inferred.
                                             43

-------
       2. PDF Potato Study
       As indicated earlier, the PDF aldicarb in potatoes study was not conducted in a manner
which would make the data amenable to straightforward use in a comparison of decomposition
methods. Therefore, OPP has elected not to conduct this analysis.

       3 POP Single Serving Special Study

       The final set of data which were decomposited by each procedure being presented to the
Panel as a PDP single serving special study conducted on a trial basis as part of its national
sampling plan. As described earlier, composite samples were collected, with one individual item
from each composite selected for analysis for the pesticide of interest. A total of 334 analytical
results from composite samples were available with one item from each composite removed and
analyzed separately as a single serving. This single-serving analysis was done regardless of the
concentration detected in the composite (i.e., there was no "trigger concentration" (as there was
in the PDP potato single serving study) which was required to be present in the composite before
the single apple was analyzed).

       Detailed graphical and statistical results of these analysis are shown in Appendix 1. As
before,  a comparison between the predicted mean, standard deviation, interquartile range,
absolute range or spread, and various upper-percentile residue values generated by each
methodology with the corresponding  statistics which are characteristic of the imputed single
serving distribution was made to compare the model-generated single serving data to the original
data (including imputed values for 
-------
Q
U
A
N
T
1
L
E
S
min
0.50
0.75
0.90
0.95
0.99
max
IQRb
K-S statistic0
(p-value)
0.0012
0.0198
0.044
0.099
0.12
0.16
0.24
0.0343
-
0.0142
0.0325
0.0422
0.0504
0.0579
0.0686
0.0840
0.0156
0.4808
(0.000)
< 0.0001
0.0053
0.0339
0.0963
0.1882
0.3259
0.4361
0.0332
0.3977
(0.000)
<0.0002
0.0082
0.0298
0.0735
0.131
0.331
0.74
0.0298
0.4242
(0.000)
a This distribution represents the standard distribution for comparison purposes
b Interquartile Range. This represents the difference between the 75th and 25th percentiles.
c Kolmogorov-Smirnov Two-sample Test Statistic with associated p-value
       A histogram and one-way scatter plot (with associated box and whisker plot) which
compares these distributions is shown in Figure 8. Additional, more detailed information is
presented in Appendix 1.

       OPP evaluated if potential differences in the model-predicted  single serving values might
lead to significant differences  in predicted exposure levels at various percentiles as determined
by DEEM (Dietary Exposure Evaluation Model) software. For the data set presently being
evaluated, normalized exposures are shown below in Table 16:
Table 16. Comparison of POP Single-Item Special Study DEEM-Predicted Exposures by
Decomposition Method
Method
POP single-item
Allender
Novigen
MaxLIP4
Composites
Normalized Exposure8
(relative to DEEM-predicted exposures from original distribution at 99.9th
percentile)
General U.S. Population
99.9th
1
0.61
1.55
1.51
0.96
99th
0.33
0.26
0.42
0.33
0.32
95th
0.09
0.10
0.08
0.07
0.10
Children 1-6
99.9th
1
0.60
1.63
1.76
0.96
99th
0.40
0.28
0.54
0.44
0.39
95th
0.13
0.14
0.12
0.10
0.14
                                           45

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 a Normalized exposures all relate to exposure at the 99.9th percentile (as estimated by DEEM) for
 the original data. These analyses were done by assigning original or decomposition-predicted
 values as residues to a widely consumed fruit present in the DEEM CSFII (USDA Continuing
 Survey of Food Intake by Individuals) database. Results would be expected to differ if another
 commodity was selected or several food  commodities were simultaneously analyzed. The
 residues (and chemical) are hypothetical, and  no toxicity  value was assigned. Interpretation of
 the normalized exposures presented in this table should therefore be done with the understanding
 that the DEEM-estimated exposures in the table are relative to an arbitrarily-assigned baseline
 value, and no health-based implications should be inferred.
V. SUMMARY OBSERVATIONS AND CONCLUSIONS
       EPA's Office of Pesticide Programs has compared its current decomposition procedure
with the those presented to the SAP by JSC Sielken/Novartis (MaxLIP) and Novigen Sciences
(RDFgen). This comparison was done by using both (a) theoretical data designed to reflect
differences in such characteristics as skewness, censoring, number of samples, and number of
distributions and (b) empirical (real world) pesticide data collected by USDA's Pesticide Data
Program (PDF) and others.  Based on this analysis, OPP makes the following observations with
respect to the three decomposition methods and their performance characteristics when applied to
both theoretical and empirical (actual) data:

       (1)  Based on the analysis using both hypothetical and empirical data sets, estimates of the
       high percentiles of daily exposure calculated using residues measured in composite
       samples are much lower than estimated exposures using "decomposited" residue values.
       Composite residue values tend to underestimate daily exposure by 30% - 50% at the
       upper percentiles.

       (2) All methods appeared comparable and seemed to do reasonably well at predicting
       single-item residues at up to approximately the 90th percentile, regardless of the data  set
       which was used. This was true of both the theoretical and empirical datasets. As the
       number of distributions increased, moderate censoring was imposed, or number of data
       points decreased, the ability of the methods to predict the upper percentile residue values
       appeared to deteriorate to varying degrees.

       (3) The presence of multiple distributions and censoring appear to have the most effect on
       each methods ability to adequately deconvolute residue values while skewness of the
       distribution and number of composite residue values seemed to have the least.

       (4) In many cases, the RDFgen and Allender procedures appeared to predict too large a
       "spread" in the data, particularly in the lower percentiles. Nevertheless, this did not
       appear to affect the exposures (as predicted by DEEM) in the region of regulatory interest

                                           46

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       (e.g., >95lh percentile)

       (5) Despite the findings in (2) and (4) above, the most accurate decompositing method
       rarely overestimated or underestimated the exposure of the 99.9th percentile by more than
       15%, compared to the calculation using the parent data set, when using hypothetical data.
       The differences between the estimates obtained using the best method and the parent data
       set were even smaller at lower percentiles.

       (6) All methods seemed be able to predict the 99.9th  percentile exposure (as determined
       by DEEM) reasonably well and no method appeared to have a significant bias toward
       over- or under-prediction. At the 99th percentile exposure and below, the methods
       appeared to be essentially equivalent, with each method predicting the same exposure as
       the original (parent data).

VI. REFERENCES

       Helsel, DR 1990. Less than obvious: statistical treatment of data below the detection
limit. Environ. Sci. Technol. 24(12): 1766-1774.

       ILSI (International Life Sciences Institute). 1998. Aggregate Exposure Assessment.
ILSI Risk Science Institute Workshop Report. Washington, D.C.

       Office of Pesticide Programs (OPP). Health Effects Division. 1999. "A Background
Document for the  Session: Statistical Methods for Use of Composite Data in Acute Dietary
Exposure Assessment of the May 26,  1999 Meeting of the FIFRA Scientific Advisory Panel".
May 11.
                                          47

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VII. QUESTIONS FOR PANEL

Question 1

The current PDF program collects residue data on approximately 5 Ib. composite samples,
whereas the residue values of interest in acute risk assessment are associated with residue
concentrations in single items of produce. In order to make better and fuller use of the current
PDF data, OPP is currently using its own decomposition method in an effort to convert residues
from a "composite" basis to a "single-item" basis which was presented to the SAP in May, 1999.

      Two additional methods for decompositing pesticide residue data have been
      presented to the SAP (RDFgen and MaxLIP). What are the overall strengths and
      weaknesses of each method with respect to their ability to adequately represent
      pesticide residues in  single unit items ?

Question 2

The OPP comparison attempted to gauge each decomposition method's performance against
several standard sets of data which reflected differences in number of samples, degree of
skewness, amount of censoring, and number of distributions.

      Each method may be sensitive to various "imperfections" , limitations, or
      characteristics of real-world data. For example, often data from many fewer than
      30 composite samples are available for decomposition. Frequently, the data are
      censored and/or are  heavily left-skewed. Many times, the composite samples  may
      have been collected from a multitude of separate and distinct pesticide residue
      distributions.  How sensitive are the two methods being presented to the SAP for
      consideration to these different factors? Does each method being presented tot the
      SAP have an adequately robust statistical underpinning?

Question 3

Despite an adequate statistical underpinning and overall robustness, there may be specific
situations in which characteristics of available data may make it unreasonable to expect a  method
to adequately deconvolute a dataset comprised of composite samples and decomposition should
be avoided as it may produce invalid or questionable output data.

      What limitations does the Panel see in the decomposition methodologies being
      presented to the SAP (e.g., minimum number of samples, degree of censoring, etc.
      )? In what specific kinds of situations might each presented methodologies fail or be
      likely to fail?
                                         48

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Question 4

In contrast to OPP's original decomposition method which was presented to the SAP in May
1999, the MaxLIP and RDFgen methods being presented to the current Panel do not assume that
PDP residue measurements are derived from one overall lognormal distribution of residues.
MaxLIP permits up to five distinct residue distributions, while RDFgen permits any number of
residue distributions and assumes that each composite measurement is derived from its own
distribution.

       The MaxLIP  method is able to account for only up to five separate distributions of
       residues and the user must use the Likelihood Ratio Test to determine if an
       adequate number of distributions is modeled. Does the Panel have any comments
       on this aspect of the program and how might this affect the adequacy of the
       decompositions which are performed? In contrast, RDFgen assumes that each that
       each composite is derived from a separate and distinct distribution and
       decompositing is performed by using the standard deviation of composite value
       measurements and assuming (once adjusted) that this applies to each composite.
       Does the Panel have any comments on these differences in approach and
       assumptions?

Question 5

Although limited in scope, OPP's comparison of each method's ability to accurately predict
individual item residue levels based only on information in residue levels in composite samples
did not appear to provide any clear evidence of systematic over- or under-estimation of residues
in decomposited samples.  All three methods did not necessarily perform equally well
(particularly at the upper and lower tails of the distribution) under all circumstances in predicting
single-item residue levels, but differences in predicted exposure levels (and therefore risk levels)
appeared to differ to a much lesser extent.  This situation is not unexpected:  it is often not the
extreme upper tail of a residue distribution which are responsible for  driving the 99.9th or 99th
percentile exposure levels, but rather a combination of reasonable (but high end) consumption
and reasonable (but high end) residue levels of one or two frequently consumed agricultural
commodities.  That is, it is not necessarily true that significant differences in predicted residue
levels in the upper tail (e.g., >95th  percentile) of the residue distribution will as a matter of
course result in significant differences in predicted exposure levels  at the upper tails of the
exposure distribution  since  it is a combination of both consumption and residue levels over a
wide variety of commodities which determine high-end exposure levels.

       Does the Panel have any thoughts, insights, or concerns about the potential for
       underestimation or overestimation (or other biases) of residue levels by each of the
       two decomposition procedures being presented for consideration?  Does any
       concern regarding over/under estimation extend to concern about over/under
                                          49

-------
estimation of exposures (and therefore risks)? Can any characteristic statements be
made about over- or under-estimation at various percentile levels (e.g., median, 75th,
90th, 99th 99.9th percentiles)?
                                   50

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FIGURES
   51

-------
 theo_cv=2_30comp_uncensored
o
0)
O"
0)
       original
                                   Allender
     30 -
     20
     10 -
o 4
  Novigen
                                   i	r
                                   MaxLIPI
                                                 ~t	1—i—r
     30 -
     20 -
     10 -
     o -i
       .001    .01   .05   .2 .5124
                                       .001    .01   .05  .2  .5 1  2 4
                      residue concentration (log scale)
            Histograms by Decomposition Method
theo_cv=1_30comp_uncensored
  -6.8406
                        original, log res
.929438
  -6.8406
                       Allender, logres
.929438
  -6.8406
                       Novigen, logres
.929438
  -6.8406
                       MaxLIPI,  logres
.929438
                         ln(residue concentration)
      One-way Box diagrams by Decomposition Method
                                 Figure 1
                                   52

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  0)
  3
  C7
  0)
  LL
 theo_cv= 1 _30comp_censored
       original
    70 -
    60-
    50-
    40 -
    30 -
    20 -
.,   10
t
     o H
                                          MaxLIPI
       Allender
Novigen
    70 -
    60-
    50 -
    40
    30 -
    20 -
    10 -
     0 -
         .0001  .001   .01  .05  .2 .5 1 2
                                          .0001   .001   .01  .05 .2 .5 1 2
                        residue concentration (log scale)
              Histograms by Decomposition Method
theo_cv= 1 _30comp_censored
 -9.49861
                           original, log res
                   -8.34e-06
 -9.49861
                                            H    I
                          MaxLIPI, log res
                   -8.34e-06
 -9.49861
                          Allender, logres
                   -8.34e-06
 -9.49861
                           Novigen, logres
                   -8.34e-06
                         ln(residue concentration)
     One-way Box diagrams by Decomposition Method
                                 Figure 2
                                   53

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  theo_cv=1_10comp_uncensored

        original

      15 -



      10 -
      5 -
 O
 c
 0
 D
 CT
 0)
Novigen
      15 -
      10 ~
      5 -
      o 4
                                Allender
                                MaxLIPI
        .001      .01    .05    .2  .5 1
                                        .001     .01   .05   .2  .5  1
                       residue concentration (log scale)
             Histograms by Decomposition Method
theo_cv=1_1 Ocomp_uncensored
 -6.014286
                    original, logres
-.251781
 -6.014286
                    Allender, logres
-.251781
 -6.014286
                    Novigen, logres
-.251781
 -6.014286
                   MaxLIPI, logres
-.251781
                        ln(residue concentration)
     One-way Box diagrams by Decomposition Method
                                Figure3



                                  54

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 u
 c
 0)
theo_cv=1_1 Ocomp_censored

      original

   25 -

   20 -

   15-

   10 -

    5-

    o-
                                       Allender
             i     i
        Novigen
                                       MaxLIPI
 V   25-
 LL
     20-

     15 -

     10-

      5 -

      o-
        .001
             .01   .05  .2  .512
                                       .001
.01  .05   .2 .512
                     residue concentration (log scale)
            Histograms by Decomposition Method
theo_cv=1_1 Ocomp_censored
 -7.151627
                                          I     h
                          original, log res
            -.1415636
 -7.151627
                         Allender, logres
            -.1415636
 -7.151627
                         Novigen, logres
            -.1415636
 -7.151627
                         MaxLIPI, logres
           -.1415636
                       ln(residue concentration)
     One-way Box diagrams by Decomposition Method


                              Figure 4
                                55

-------
  theo_2dist(25%)_cv=1_30comp_censored
        Original
                             Allender
                                              Novigen
 C
 0)
 D
 cr
 0)
so -
40-
30 -
20-
10 -
 0 -

50 -
40 -
30 -
20 -
10 -
 0 -
        MaxLIPI
                              MaxLIP2
                                                   .0001   .01  .2 1 4
        .0001  .01  .214
                              .0001  .01  .214
                      residue concentration (log scale)
             Histograms by Decomposition Method
theo_2dist(25%)_cv=1_30comp_censored
 -10.58859
 -10.58859
 -10.58859
 -10.58859
 -10.58859
                       Original, logres
Allender, logres
                       Novigen, logres
                                2.206326
                                                      2.206326
                                2.206326
                      MaxLIPI, logres                  2.206326
                      MaxLIP2, logres
                                2.206326
                        ln(residue concentration)
     One-way Box diagrams by Decomposition Method
                                Figure 5
                                  56

-------
 theo_2dist(10%)_cv=1_30comp_censored
      original                MaxLIPI
                                          MaxLIP2
    50 -
    40 -
    30 -
    20 -
    10 -
     0 -
   _A
       Novigen
                          Allender
                                                .0001  .01 .1 .52 8
fr
0)
C7
0)
50 -
40 -
30 -
20 -
10 -
 0 -
        .0001 .01 .1 .528
                            .0001 .01 .1 .52 8
                    residue concentration (log scale)
           Histograms by Decomposition Method
theo_2dist(10%)_cv=1_30comp_censored
 -12.2705
 -12.2705
 -12.2705
 -12.2705
 -12.2705
                      original, logres
                               -\     I
                      Novigen, logres
                      Allender, logres
2.815409
                      MaxLIPI, logres
2.815409
                      MaxLIP2, logres                 2.815409
2.815409
2.815409
                      ln(residue concentration)
     One-way Box diagrams by Decomposition Method

                              Figure 6
                                57

-------
  Novartis GA Peach field trial data
        field trial single-item
     20-
     15-
 o
 c
 0)
 0)
      10-
o-
        Novigen
                                   Allender
                                         IiIi "~iI
                                         MaxLIPI
     20-
      15 -
      10-
      5-
      0-i
       .0001   .001   .01  .05 .2 .5 1 2
                                        .0001   .001   .01  .05 .2 .5 1 2
                      residue concentration (log scale)
             Histograms by Decomposition Method
Novartis GA Peach field trial Data
 -7.911337
                 field trial single-item, logres
.6262592
 -7.911337
                      Allender, logres
.6262592
 -7.911337
                      Novigen, logres
.6262592
 -7.911337
                      MaxLIPI, logres
.6262592
                        ln(residue concentration)
     One-way Box diagrams by Decomposition Method
                                 Figure 7
                                   58

-------
  POP single-serving study
0)
3
(7
0)
       original
                                  Allender
    50-
    40-
    30-
    20
    10-
           .A.
                                              T	1—i—r
   Novigen
                              MaxLIP4
    50-


    40


    30 -


    20-


    10 -


     0 -
            .0001 .001 .01 .05 .2.51
                                    .0001 .001  .01 .05 .2.51
                   residue concentration (log scale)
POP
sin le serv!riS*S>t9a:^ms ^V Decomposition Method
 -13.87952
                    original, logres
-.3011051
 -13.87952
                    Allender, logres
-.3011051
 -13.87952
                    Novigen, logres
-.3011051
 -13.87952
                                      I     l-
                    MaxLIP4, logres
-.3011051
                    ln(residue concentration)
    One-way Box diagrams by Decomposition Method


                          Figure 8
                            59

-------
APPENDIX 1
    A-l

-------
STATA LOG FILE/OUTPUT: theo_CV=2_30comp_uncensored.log
label list
method:
         1 original
         2 AI lender
         3 Novigen
         4 MaxLIPI

.  sort meth

.  by meth: summarize residue,detaiI

-> meth=original
                      residue

1%
5%
10%
25%
50%

75%
90%
95%
99%
Percent! I es
.002512
.0055915
.0087305
.01904
.0446428

.1051224
.2268092
.3613527
.8992397
Smallest
.0011884
.0015736
.001632
.0024258

Largest
1.021243
1.247094
1.335169
2.533085



Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis



450
450
.1001748
.1898224

.0360326
6.774018
70.76885
-> meth=A I lender


1%
5%
10%
25%
50%

75%
90%
95%
99%

Percent i les
.00409
.00833
.01239
.02479
.052905

.11334
.22464
.33996
.76505
residue
Smallest
.0021
.0027
.00279
.00396

Largest
.85673
1.02339
1.08744
1.92235




Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis




450
450
.1003352
.1565942

.0245217
5.593789
51.01083
-> meth= Novigen


1%
5%
10%
25%
50%

75%
90%
95%
99%

Percent! les
.0014286
.0043364
.0079836
.0190545
.0489341

.1186389
.243962
.4451822
.5308715
residue
Smallest
.0010695
.0010941
.0011415
.0011662

Largest
.5417213
.5599318
.5666574
.7022806




Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis




450
450
.0985186
.1263297

.0159592
2.145612
7.231329
-> meth= MaxLIPI
                      residue
                                           A-2

-------

1%
5%
10%
25%
50%

75%
90%
95%
99%
Percent! I es
.00346
.00758
.0115985
.023184
.051655

.113096
.228798
.353235
.755985
Smallest
.001578
.00219
.002772
.00313

Largest
.883497
1.01795
1.24546
1.61948



Obs.
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis



450
450
.1002643
.154345

.0238224
4.72429
35.03111
.  with logres meth if meth==1|meth==2:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov  test for  equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.0778    0.066
 AUender:          -0.0111    0.946
 Combined K-S:       0.0778    0.131      0.115

. with logres meth if meth==1|meth==3:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for  equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.0467    0.375
 Novigen:           -0.0222    0.801
 Combined K-S:       0.0467    0.711      0.682

. with logres meth if meth==1|meth==4: ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.0578    0.223
 HaxLIPl:           -0.0067    0.980
 Combined K-S:       0.0578    0.440      0.408

. qqplot logresl logresl, xlab(-7(1) 0) ylab(-7(1) 0) saving(pic101)

. qqplot logresl Iogres2, xtab(-7(1) 0) ylab(-7(1) 0) saving(pic102)

. qqplot logresl Iogres3, xlab(-7(1) 0) ylab(-7(1) 0) saving(pic103)

. qqplot logresl Iogres4, xlab(-7(1) 0) ylab(-7(1) 0) saving(pic104)

. graph using piclOI pic102 pic103 pic104, margin(15) saving(pidOO)
                                                    A-3

-------
Q-Q PLOTS: theo_CV=2_30comp_uncensored
                     -i   •*    -3   -2
                            original
                    Quantile-Quantile Plot
                                                            -5-


                                                            •e-


                                                            -7-
 •5    -<    -3   -2
        Alender
Quantile-Quantile Plot
          -i-


          •t-


          -7 -
                      •S    -4    .3    .2
                            Novigen

                    Quantile-Quantile Plot
        MartJPI
Quantile-Quantile Plot
                                                   A-4

-------
STATA LOG FILE/OUTPUT: theo_CV= l_30comp_censored.log
label list
method:
1 original
2 MaxLIPI
3 MaxLIP2
4 MaxLIPS
5 MaxLIP4
6 MaxLIPS
7 A I lender
8 Novigen
.  sort meth

.  by meth: summarize residue, detail

-> meth=original
                     res i due

1%
5%
10%
25%
50%

75%
90%
95%
99%
Percent! les
.0104443
.0182625
.0241493
.040491
.0704659

.1241246
.2044574
.2848463
.5067896
Smallest
.0064023
.0078619
.0087233
.0094144

Largest
.5153022
.609885
.6113446
.9999917



Obs
Sum of Ugt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis



450
450
.1000437
.0991227

.0098253
3.384686
22.12941
-> meth= MaxLIPI


1%
5%
10%
25%
50%

75%
90%
95%
99%

Percenti les
.006801
.012948
.018105
.033539
.0639835

.122838
.2168105
.293713
.538324
residue
Smallest
.003112
.004712
.00522
.006293

Largest
.568162
.620855
.709869
.951251




Obs
Sum of Ugt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis




450
450
.0982464
.1065999

.0113635
3.071871
17.23734
-> meth= MaxLIP2


1%
5%
10%
25%
50%

75%
90%
95%
99%

Percenti les
.0341
.0501
.0636
.0776
.08645

.11
.168
.213
.34
residue
Smallest
.0218
.0273
.0297
.0323

Largest
.361
.391
.434
.509




Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis




450
450
.1039447
.0563251

.0031725
2.899569
14.91835
                                        A-5

-------
-> meth= MaxLIPS
                          residue
Percent! les
1% .00804
5% .0209
10% .0284
25% .0458
50% .0761

75% .125
90% .19
95% .247
99% .417
-> meth= MaxLIP4

Percent! les
1% .0488
5% .0696
10% .0737
25% .0811
50% .09205

75% .119
90% .1485
95% .165
99% .198
-> meth= MaxLIPS

Percent! les
1% .0623
5% .071
10% .07455
25% .0814
50% .09255

75% .119
90% .15
95% .17
99% .214
-> meth=A I lender

Percent! les
1% .02129
5% .03263
10% .04039
25% .05996
50% .09156

75% .14113
90% .206655
95% .26626
99% .41354
-> meth= Novigen

Percent! les
Smallest
0
0
0
0

Largest
.442
.469
.56
.717

residue
Smallest
1.09e-26
4.13e-23
6.17e-21
1.10e-18

Largest
.203
.209
.218
.234

residue
Smallest
1.72e-23
.0502
.0577
.0605

Largest
.22
.225
.241
.271

residue
Smallest
.01464
.01713
.01855
.01966

Largest
.41884
.47641
.47728
.69517

residue
Smallest



Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis






450
450
.0980601
.081478

.0066387
2.621793
14.33496





450
450
.1020758
.0318593

.001015
.8910966
4.740295





450
450
.1037798
.0329351

.0010847
1.452663
5.832544





450
450
.1124434
.0792857

.0062862
2.297578
11.94352



                                                  A-6

-------
1%
5%
10%
25%
50%

75%
90%
95%
99%
.0004956
.002254
.0049331
.015895
.0455017

.1068703
.238763
.368078
.5110412
.000075
.0003163
.0004724
.0004758

Largest
.5294565
.5486197
.5711085
.5974749


Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis


450
450
.0885098
.1153374

.0133027
2.228153
7.83988
.  with logres meth if meth==1|meth==2:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for  equality of distribution functions:

 Smaller group       0       P-value  Corrected

 original:           0.0133    0.923
 MaxLIPI:           -0.0711    0.103
 Combined K-S:       0.0711    0.205      0.182

.  with logres meth if meth==1|meth==7:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for  equality of distribution functions:

 Smaller group       D       P-value  Corrected

 original:           0.1756    0.000
 Allender:          -0.0133    0.923
 Combined K-S:       0.1756    0.000      0.000

.  with logres meth if meth==1|meth==8:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for  equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.0356    0.566
 Novigen:           -0.2422    0.000
 Combined K-S:       0.2422    0.000      0.000

. qqplot logresl logresl, xlab(-10(2) 0) ylab(-10(2) 0) saving(pic201)

. qqplot logresl Iogres7, xlab(-10(2) 0) ylab(-10(2) 0) saving(pic202)

. qqplot logresl logresS, xlab(-10(2) 0) ylab(-10(2) 0) saving(pic203)

. qqplot logresl Iogres2, xlab(-10(2) 0) ylab(-10(2) 0) saving(pic204)

. graph using pic201 pic202 pic203 pic204, margin(15) saving(pic200)
                                                    A-7

-------
Q-Q PLOTS: theo_CV=l_30comp_censored
                         origrol
                  Ouantile-Quantile Plot
        AUender
 Ouantile-Quantile Plot
                 -e     -6      -4     -2
                         Novtgen
                  Quanlile-Quanlile Plot
-a     -e      -4      .2
        MaxUPI
 Quantile-Quantile Plot
                                                  A-8

-------
STATA LOG FILE/OUTPUT: theo_cv=l_10comp_uncensored.
label List
method:
         1  original
         2  AUender
         3  Novigen
         4  MaxLIPl
.  sort meth

.  by meth: summarize residue,  detail

-> meth=original
                      residue
Percent i les
1% .0106457
5% .0182469
10% .0242162
25% .0403267
50% .0705089

75% .1241246
90% .2044574
95% .2848463
99% .5153022
-> meth=A I lender

Percenti les
1% .01
5% .02
10% .02
25% .04
50% .07

75% .12
90% .21
95% .29
99% .55
-> meth= Novigen

Percenti les
1% .0060007
5% .0115108
10% .0165487
25% .0333049
50% .0660467

75% .1280603
90% .2227006
95% .3116175
99% .4372376
-> meth= MaxLIPl

Percent!" les
Smallest
.0064023
.0106457
.0113911
.0131453

Largest
.3799233
.4373933
.5153022
.609885

residue
Smallest
.01
.01
.01
.01

Largest
.4
.46
.55
.65

residue
Smallest
.0024436
.0060007
.0066583
.0081255

Largest
.4147782
.4346096
.4372376
.4562849

res i due
Smallest



Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Ugt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis






150
150
.099377
.0937839

.0087954
2.524185
11.3392





150
150
.0992667
.0991785

.0098364
2.650132
12.13445





150
150
.0980262
.0936227

.0087652
1.808153
6.300382



                                           A-9

-------
1%
5%
10%
25%
50%

75%
90%
95%
99%
.006678
.012775
.0181775
.03228
.0639495

.123211
.225403
.320747
.58564
.004565
.006678
.008076
.009358

Largest
.441192
.493464
.58564
.777415


Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis


150
150
.1010434
.1133421

.0128464
2.82956
13.52952
. with logres meth if meth==1|meth==2: ksmirnov I ogres,  by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.0267    0.899
 Allender:          -0.0667    0.513
 Combined K-S:       0.0667    0.893      0.866

.  with logres meth if meth==1|meth==3: ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected

 original:           0.0333    0.846
 Novigen:           -0.0867    0.324
 Combined K-S:       0.0867    0.626      0.574

.  with logres meth if meth==1|meth==4: ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.0267    0.899
 MaxLIPl:           -0.0867    0.324
 Combined K-S:       0.0867    0.626      0.574

. qqplot logresl logres!, xlab(-6(1) 0) ylab(-6(1) 0) saving{pic301)

. qqplot logresl Iogres2, xlab(-6(1) 0) ylab(-6(1) 0) saving(pic202)
file pic202.gph already exists
r(602);

. qqplot logresl Iogres2, xlab(-6(1) 0) ylab(-6(1) 0) saving(pic302)

. qqplot logresl Iogres3, xlab(-6(1) 0) ylab(-6(1) 0) saving(pic303)

. qqplot logresl Iogres4, xlab(-6(1) 0) ylab(-6(1) 0) saving(pic304)

. graph using pic301 pic302 pic303 pic304, margin(15) saving(pic300)
                                                   A-10

-------
Q-Q PLOT:  theo_cv=l_10comp_uncensored
                           original
                   Quantile-Quantile Plot
                                                           -2-


                                                           -3-
        Allender
Quantile-Quantile Plot
                       -4     .3     -2
                           Novigen
                   Quantile-Quantile Plot
        MaxLIPI
Quantile-Quantile Plot
                                                   A-ll

-------
STATA LOG FILE/OUTPUT: theo_cv=l_10comp_censored
label list
method:
         1  original
         2  AI lender
         3  Novigen
         4  MaxLIP!

.  sort meth

.  by meth: summarize residue,  detail

-> meth=original
                      residue

1%
5%
10%
25%
50%

75%
90%
95%
99%
Percenti I es
.01065
.01825
.024215
.04033
.07051

.12412
.20446
.28485
.5153
Smallest
.0064
.01065
.01139
.01315

Largest
.37992
.43739
.5153
.60988



Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis



150
150
.099377
.0937834

.0087953
2.524163
11.33908
-> meth=Al lender


1%
5%
10%
25%
50%

75%
90%
95%
99%

Percenti I es
.0144658
.0292241
.0396419
.0568663
.0836838

.1248899
.1856865
.2471603
.3350985
residue
Smallest
.0119897
.0144658
.018851
.0241437

Largest
.2869433
.2930372
.3350985
.5692753




Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis




150
150
.1036115
.0725697

.0052664
2.522367
13.88663
-> meth= Novigen


1%
5%
10%
25%
50%

75%
90%
95%
99%

Percenti 1 es
.0008644
.0027517
.0052957
.015139
.0467842

.1135213
.2398872
.3712737
.483834
residue
Smallest
.0007836
.0008644
.000879
.0012189

Largest
.4738443
.4764183
.483834
.5739807




Obs
Sun of Ugt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis




150
150
.0899784
.1150946

.0132468
2.158361
7.452154
-> meth= MaxLIPl



Percenti 1 es
residue
Smallest




                                          A-12

-------
1%
5%
10%
25%
50%

75%
90%
95%
99%
.00457
.00931
.0137
.0274
.05785

.124
.2375
.334
.633
.00321
.00457
.00557
.00634

Largest
.484
.542
.633
.868


Otis
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurt os is


150
150
.10108.11
.124524

.0155062
2.977822
14.69869
.   with logres meth if meth==1|meth==2:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for equality of  distribution functions:

 Smaller group       D       P-value  Corrected
 original:            0.1600    0.021
 Allender:           -0.0333    0.846
 Combined K-S:       0.1600    0.043       0.032

   with logres meth if meth==1|meth==3:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for equality of  distribution functions:

 Smaller group       D       P-value   Corrected
 original:           0.0400    0.787
 Novigen:           -0.2333    0.000
 Combined K-S:       0.2333    0.001      0.000

   with logres meth if meth==1|meth==4:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected

 original:           0.0333    0.846
 MaxLIPI:           -0.1333    0.069
 Combined K-S:       0.1333    0.139      0.111

. qqplot logresl  logres!,  xlab (-8(2) 0) ylab(-8(2) 0)  saving(pic401)

. qqplot logresl  Iogres2,  xlab (-8(2) 0) ylab(-8(2) 0)  saving(pic402)

. qqplot logresl  Iogres3,  xlab (-8(2) 0) ylab(-8(2) 0)  saving(pic403)

. qqplot logresl  Iogres4,  xlab (-8(2) 0) ylab(-8(2) 0)  saving(pic404)

. graph using pic401 pic402 pic403 pic404, margin(15)  saving(pic400)
                                                   A-13

-------
Q-Q PLOT:  theo_cv=l_10comp_censored
          -8        -6       -4        -2
                          Original

                  Quantile-Quantile Plot
        Allender
Quantile-Quantile Plot
          -«        -e        -4
                          Novigen

                  Quantile-Quantile Plot
        MaxLIP4

Quantile-Quantile Plot
                                                   A-14

-------
STATA LOG FILE/OUTPUT: theo2dist(25%)_ cv=l _cens.log
label list
method:
1 Original
2 AUender
3 Novigen
4 MaxLIPI
5 MaxLIP2
6 MaxLIP3
7 MaxlIP4
           8 MaxLIPS

. sort meth

. by meth:  summarize residue,  detail

-> meth=0riginal
                          residue
 1%
 5%
10%
25%

50%

75%
90%
95%
99%
PercentiIes
   .013145
   .024512
  .0344085
   .061403

  .1211225

   .247587
   .450136
   .637528
  1.272551
-> meth=Allender
-> meth= Novigen
Smallest
 .006402
 .010444
 .010646
 .011391
 Largest
1.303771
1.550776
1.922001
3.059975
Obs
Sum of Wgt.

Mean
Std. Dev.

Variance
Skewness
Kurtosis
     450
     450

.2046446
.2646265

.0700272
4.668925
38.87212
                          residue

1%
5%
10%
25%
50%

75%
90%
95%
99%
Percenti les
.0123877
.025437
.0387616
.0733772
.1536242

.310614
.5808705
.8561678
1.890491
Smallest
.0041459
.0078348
.0104602
.0119519

Largest
2.12866
2.385667
2.637975
9.082289



Obs
Sum of Ugt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis



450
450
.274754
.5237432

.2743069
11.33465
181.0417
                          residue
 1%
 5%
10%
25%

50%
Percent!" les
  .0002374
  .0008388
  .0018749
  .0111889

  .0608923
75%     .2058088
90%     .5631062
95%     .8685383
Smallest
.0000252
.0000694
.0001249
.0002316
                 Largest
                1.640383
                 1.65851
                1.725988
Obs
Sum of Ugt.

Mean
Std. Dev.

Variance
Skewness
     450
     450

.1939281
.3284133

.1078553
2.809264
                                                 A-15

-------
99%      1.62936



-> meth= MaxLIP!
1.875082
Kurtosis
11.26928
-> meth= MaxLIPS
                           residue
Percent! I es
1% .00121
5% .00345
10% .006345
25% .01657
50% .0496

75% .15113
90% .411
95% .8328
99% 2.7684
-> meth= MaxLIP2

Percent! I es
1% .0209
5% .0365
10% .04845
25% .0786
50% .14

75% .26
90% .45
95% .603
99% 1.05
-> meth= MaxLIPS

Percent! les
1% 1.01e-23
5% 1.69e-18
10% . .0328
25% .0701
50% .1375

75% .262
90% .4435
95% .603
99% 1.03
-> meth= MaxLIP4

Percent! les
1% 1.06e-19
5% 4.05e-17
10% 6.42e-15
25% .0643
50% .1735

75% .27
90% .3955
95% .532
99% .915
Smallest
.00039
.00066
.00092
.00111

Largest
3.07284
3.52139
3.97003
5.55595

residue
Smallest
.0133
.0159
.0177
.0195

Largest
1.13
1.29
1.45
1.84

res i due
Smallest
9.48e-28
1.05e-25
8.82e-25
2.63e-24

Largest
1.15
1.26
1.48
1.86

residue
Smallest
4.90e-22
5.97e-21
1.58e-20
4.55e-20

Largest
.989
1.1
1.22
1.44



Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Ugt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis



450
450
.1959748
.501669

.2516718
5.954972
47.80728





450
450
.2084231
.210582

.0443448
2.967521
16.3107





450
450
.2016791
.2139922

.0457927
2.889687
16.0941





450
450
.1973293
.1884106

.0354986
2.145598
10.95138
                          residue
                                                  A-16

-------
Percent! les
1%
5%
10%
25%
50%

75%
90%
95%
99%
.0923
.113
.113
.113
.14

.259
.3965
.55
.905
Smallest
.0604
.0749
.0819
.0872

Largest
.982
1.07
1.18
1.62



Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis



450
450
.2161073
.1692832

.0286568
3.203414
18.57704
.   wtih logres meth if meth==1|meth==2:  ksmirnov logres,  by(meth)
unrecognized command:  wtih
r(199);

.   with logres meth if meth==1|meth==2:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 Original:           0.1000    0.011
 Allender:          -0.0044    0.991
 Combined K-S:       0.1000    0.022      0.018

.  with logres meth if meth==1|meth==3: ksmirnov logres, by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 Original:           0.0356    0.566
 Novigen:           -0.3133    0.000
 Combined K-S:       0.3133    0.000      0.000

.  with logres meth if meth==1|meth==4: ksmirnov logres, by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 Original:           0.0267    0.726
 HaxLIPI:           -0.3267    0.000
 Combined K-S:       0.3267    0.000      0.000

.  with logres meth if meth==1|meth==5: ksmirnov logres, by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 Original:           0.0978    0.014
 MaxLIP2:           -0.0133    0.923
 Combined K-S:       0.0978    0.027      0.022

. label  list
method:
           1 Original
           2 At lender
           3 Novigen
           4 MaxLIPI
           5 MaxLIP2
           6 MaxLIPS
           7 MaxLIP4
                                                   A-17

-------
           8 MaxlIPS

.  label  var logres 1  "Original"
invalid syntax
r(198);

.  label  var Ingres!  "Original"

.  label  var Iogres2  "Allender"

.  label  var logresS  "Novigen"

.  label  var Iogres4  "MaxLIPI"

.  label  var logresS  "HaxLIPZ"

.  qqplot logresl  logresl,  xlab  (-12(2)  2)  ylab(-12(2)  2)

.  qqplot logresl  logresl,  xlab  (-12(2)  2)  ylab(-12(2)  2)  saving(picSOI)

.  qqplot logresl  Iogres2,  xlab  (-12(2)  2)  ylab(-12(2)  2)  saving(pic502)

.  qqplot logresl  logresS,  xlab  (-12(2)  2)  ylab(-12(2)  2)  saving(pic503)

.  qqplot logresl  logresA,  xlab  (-12(2)  2)  ylab(-12(2)  2)  saving(pic504)

.  qqplot logresl  logresS,  xlab  (-12(2)  2)  ylab(-12(2)  2)  saving(pic505)

.  graph  using picSOl  pic502  pic503  picSOA  pic505, margin(15)  saving(picSOO)
                                                   A-18

-------
Q-Q PLOT: theo2dist(25%)_ cv=l _cens.log
                                     1  -
                                     6  -a
                                                                                              -103
                                               Quantla-Quantila Plot
                                                                                  Qu»ntila-Quantil* Plot
                                     a   -«-
             Quanbla-Quantila Plot
                                          -II  -10   4  .8  |pi-4   -I
                                               Ouantile-Quantla Plot
                                                     A-19

-------
STATA LOG FILE/OUTPUT: theo2dist(10%)_ cv=l _cens.log
label list
method:
1 original
2 MaxLIPI
3 MaxLIP2
4 MaxLIP3
5 MaxLIP4
6 MaxLIPS
7 Novigen
         8 AI lender

.  sort meth

.  by meth: summarize residue, detail

-> meth=original
                       residue

1%
5%
10%
25%
50%

75%
90%
95%
99%
Percent i les
.013145
.025809
.035604
.070851
.2063645

.60958
1.19396
1.6318
3.58921
Smallest
.006402
.010444
.010646
.011391

Largest
3.6846
4.34091
5.13767
8.42393



Obs
Sum of Ugt.
Mean
Std. Oev.

Variance
Skewness
Kurtosis



450
450
.4797407
.746337

.557019
4.601158
37.23031
-> meth= MaxLIPI
-> meth= MaxLIP2
                       residue
1
1%
5%
10%
25%
50%

75%
90%
95%
99%
Percenti les
.00025
.000949
.00214
.008
.03425

.149
.615
2.07
11.3
Smallest
.0000573
.000111
.000154
.000207

Largest
12.2
13.2
14.7
16.7



Obs
Sum of Wgt.
Mean
Std. Dev.

. Variance
Skewness
Kurtosis



450
450
.4977525
1.870777

3.499808
5.631229
37.28558
                      residue
Percent!" les
1%
5%
10%
25%
50%

75%
90%
95%
.0203
.0339
.0466
.0843
.199

.581
1.23
1.84
Smallest
.0103
.0149
.0177
.0189

Largest
4.04
4.52
5.03



Obs
Sum of Ugt.
Mean
Std. Dev.

Variance
Skewness



450
450
.4859113
.7390395

.5461794
3.689396
                                           A-20

-------
99% 3.71
-> meth= MaxLIPS

Percent! I es
1% .0151
5% .0339
10% .05625
25% .112
50% .1805

75% .592
90% 1.205
95% 1.82
99% 3.72
-> meth= MaxLIPA

Percent! I es
1% 7.47e-27
5% 1.83e-23
10% 1.86e-20
25% .067
50% .223

75% .728
90% 1.255
95% 1.58
99% 2.66
-> meth= MaxLIPS

Percent! I es
1% .000682
5% .00837
10% .0751
25% .112
50% .237

75% .749
90% 1.145
95% 1.55
99% 2.68
-> meth= Novigen

Percent! I es
1% .0000169
5% .0001228
10% .0003898
25% .0034506
50% .0755196

75% .4803623
90% 1.261279
95% 2.099527
99% 5.188283
6.86

residue
Smallest
.00701
.0106
.0126
.0135

Largest
4.02
4.52
5.43
7.68

residue
Smallest
6.94e-30
2.29e-28
9.07e-28
2.30e-27

Largest
2.84
3.1
3.56
4.66

residue
Smallest
.0000995
.00022
.000373
.000539

Largest
2.97
3.26
3.78
6.16

residue
Smallest
4.69e-06
7.30e-06
.0000107
.0000137

Largest
5.32036
5.636536
6.184605
6.280733
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis
22.47118





450
450
.4896067
.7602744

.5780172
4.116962
28.13415





450
450
.4754802
.5962599

.3555259
2.276724
11.01786





450
450
.5076794
.6039606

.3647685
3.224579
22.79787





450
450
.4644568
.9707761

.9424062
3.619737
17.46399
-> meth=AI lender
                         residue
                                                A-21

-------

1%
5%
10%
25%
50%

75%
90%
95%
99%
Percent! les
.01152
.03316
.05105
.11684
.282035

.69361
1.52257
2.50073
5.90843
Smallest
.00751
.00899
.0102
.01099

Largest
6.15467
8.66661
9.71312
9.74456



Obs
Sum of Ugt.
Mean
Std. Dev.

Variance
Skewness
Kurt os is



450
450
.6501363
1.121444

1.257638
4.558668
30.28356
. with logres meth if meth==1|meth==3: ksmirnov logres, by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected

 original:           0.0511    0.309
 MaxLIP2:           -0.0311    0.647
 Combined K-S:       0.0511    0.599      0.567

. with logres meth if meth==1|meth==7: ksmirnov logres, by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.0244    0.764
 Novigen:           -0.3644    0.000
 Combined K-S:       0.3644    0.000      0.000

. with logres meth if meth==1|meth==8: ksmirnov logres, by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.1311    0.000  '
 Allender:          -0.0044    0.991
 Combined K-S:       0.1311    0.001      0.001

. qqplot logresl logresl,  xlab(-13(1) 2) ylab(-13(1) 2) saving(pic601)

. qqplot logresl logresB,  xlab(-13(1) 2) ylab(-13(1) 2) saving(pic601)
file pic601.gph already exists
r(602);

. qqplot logresl logresB,  xlab(-13(1) 2) ylab(-13(1) 2) saving(pic602)

. qqplot logresl Iogres7,  xlab(-13(1) 2) ylab(-13(1) 2) saving(pic603)

. qqplot logresl logresS,  xlab(-13(1) 2) ylab(-13(1) 2) saving(pic604)

. graph using pic601 pic602 pic603 pic604, margin(15) saving(pic600)
                                                   A-22

-------
Q-Q PLOT: theor_2dist(10%)_ cv=l _cens.log
              -7-
              -8-
              -9-
             -10-
             -11 -
             -12-
             -13-
-13 -12 -11 -10 -9-8-7-6-5-4 -3  -2  -1
                   original
          Quantile-Quantile Plot
                                                                          -s-
                                                                          -6
                                                                          -7-
                                                         -10-
                                                         -11 -
                                                         -12-
                                                         -13-
                                                                            -13 -12 -11 -10 -9 -8
                                                                                               -6 -S
                                                                                               AUendei
                                                                                      Quantile-Quantile Plot
                                                                                                        •3 -2-101
              -5 -
              -6 -
              -7-
              -8-
              -9 -
             -10 -
             -11 -
             -12-
             -13-
                                                          o-
                                                          -i -
                                                          -2-
                                                          -3 -
                                                          -4 -
                                                          -5-
                                                          -8-
                                                          -7-
                                                          -8-
                                                          -9
                                                         -10-
                                                         -11 -
                                                         -12-
                                                         -13 -
                -13 -12 -11 -10 -9
                                 -7  -6 -5
                                   Novigen
                          Quantile-Quantile Plot
                                            •3 -2-101
                                                            -13 -12 -11 -10  -9 -8  -7-6-5-4  -3  -2 -1
                                                                               MaxLIP2
                                                                      Quantile-Quantile Plot
                                                             A-23

-------
STATA LOG FILE/OUTPUT: novartis_diazinon_peaches
label list
method:
1 field trial
2 A I lender
3 Novigen
4 MaxLIPI
5 MaxLIP2
6 MaxLIP3
7 MaxLIP4
8 MaxLIPS
single- item
.  sort meth

.  by meth: summarize residue, detail

-> meth=field trial single-item
                      residue
Percenti I es
1%
5%
10%
25%
50%

75%
90%
95%
99%
-> meth=

.0035
.006
.01
.0195
.067

.1855
.4175
.51
.973


Percenti les
1%
5%
10%
25%
50%

75%
90%
95%
99%
-> meth=

.01
.015
.02
.04
.08

.17
.36
.525
1.025


Percenti les
1%
5%
10%
25%
50%

75%
90%
95%
99%
.0008437
.0046175
.0076326
.0242813
.0757128

.1751336
.4211342
.5299276
.7603771
Smallest
.001
.003
.004
.004

Largest
.829
.877
1.069
1.499
A I lender
residue
Smallest
0
.01
.01
.01

Largest
.75
.91
1.14
1.43
Novigen
residue
Smallest
.0003666
.0005848
.0011025
.0012014

Largest
.7213647
.755182
.7655723
.7718232



Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis



200
200
.144605
.2047197

.0419101
2.965827
15.00825





200
200
.14705
.1920997

.0369023
3.194047
16.80296





200
200
.1432559
.1753759

.0307567
1.770232
5.564711
                                          A-24

-------
-> meth=

Percent iles
1%
5%
10%
25%
50%

75%
90%
95%
99% 1
-> meth=

.00527
.01152
.01755
.03457
.07455

.160745
.317935
.51104
.180485


Percent! les
1%
5%
10%
25%
50%

75%
90%
95%
99%
-> meth=

.00931
.017805
.025725
.045515
.083875

.16487
.32218
.48202
1.10256


Percent iles
1%
5%
10%
25%
50%

75%
90%
95%
99%
-> meth=

.01082
.02087
.029765
.05919
.118755

.210635
.30757
.3528
.468465


Percent iles
1%
5%
10%
25%
50%

75%
90%
95%
99%
-> meth=

.023355
.037045
.048455
.07965
.11889

.157125
.249195
.35951
.66911


MaxLIPl
residue
Smallest
.00329
.00478
.00576
.00676

Largest
.89415
1.03781
1.32316
1.8706
MaxLIP2
residue
Smal lest
.0058
.00831
.01031
.01164

Largest
.80878
.96647
1.23865
1.755
MaxLIP3
residue
Smallest
.00693
.0098
.01184
.01343

Largest
.42206
.44664
.49029
.62281
MaxLIP4
residue
Smal lest
.01886
.02189
.02482
.02728

Largest
.55377
.62339
.71483
1.03541
MaxLIPS
residue




Obs
Sum of Ugt.
Mean
Std. Dev.

Variance
Skeuness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Ugt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis






200
200
.14387
.217439

.0472797
4.298318
27.71191





200
200
.1471731
.2016268

.0406534
4.256404
27.72849





200
200
. 1468229
.1105692

.0122255
1.10568
4.193542





200
200
.1434092
.120316

.0144759
3.557626
21.2153


Percentites
Smallest
                                          A-25

-------
1%
5%
10%
25%
50%

75%
90%
95%
99%
.030295
.04658
.060685
.08897
.116055

.178155
.287105
.33202
.4075
.02294
.02847
.03212
.03452

Largest
.38303
.39794
.41706
.46759


Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis


200
200
.1451988
.087273

.0076166
1.300914
4.177967
. with logres meth if meth==1|meth==3: ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 field trial sing:   0.0600    0.487
 Novigen:           -0.0400    0.726
 Combined K-S:       0.0600    0.864      0.837

. with logres meth if meth==1|meth==4: ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 field trial sing:   0.1600    0.006
 MaxLIPI:           -0.0500    0.607
 Combined K-S:       0.1600    0.012      0.009

.  with logres meth if meth==1|meth==2:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for  equality of distribution functions:

 Smaller group       0       P-value  Corrected
 field trial sing:    0.2048    0.000
 Allender:           -0.0347    0.787
 Combined K-S:        0.2048    0.000      0.000

. qqplot logresl  logresl,  saving(picnov101) xlab(-8(2)  0)  ylab(-8(2)  0)
file picnov101.gph  already exists
r(602);

. qqplot logresl  logresl,  saving(picnov11) xlab(-8(2)  0) ylab(-8(2)  0)

. qqplot logresl  logresl,  saving(picnov12) xlab(-8(2)  0) ylab(-8(2)  0)

. qqplot logresl  Iogres2,  saving(picnov13) xlab(-8(2)  0) ylab(-8(2)  0)

. qqplot logresl  logresS,  saving(picnov14) xlab(-8(2)  0) ylab(-8(2)  0)

. qqplot logresl  Iogres4,  saving(picnov15) xlab(-8(2)  0) ylab(-8(2)  0)

. graph  using picnov11  picnov13 picnov14 picnov15,  margin(15)  saving(picnovlO)
                                                   A-26

-------
Q-Q PLOT: novartis_diazinon_peaches
                         single-item field trial
                   Quantile-Quantile Plot
                                                         s


                                                         |
                                                         s
        Allender
Quantile-Quantile Plot
                            Novigen
                   Quantile-Quantile Plot
-e        -4        -2
        McxLIPI
Quantile-Quantile Plot
                                                      A-27

-------
STATA OUTPUT/LOGFILE: PDF Single-serving Special Study
label list
method:
         1 original
         2 AI lender
         3 MaxLIP4
         4 Novigen

.  sort meth

.  by meth: summarize residue, detail

-> meth=original
                       residue
Percenti I es
1% .001816
5% .0034675
10% .0050123
25% .0096883
50% .0197696

75% .044
90% .099
95% .12
99% .16
-> meth=Al lender

Percenti I es
1% .016251
5% .019556
10% .021986
25% .026654
50% .032538

75% .042244
90% .050417
95% .05794
99% .06859
-> meth= MaxLIP4

Percenti 1 es
1% .0000152
5% .0000206
10% .000025
25% .0000373
50% .00815

75% .0298
90% .0735
95% .131
99% .331
-> meth= Novigen

Percenti 1 es
Smallest
.0011817
.0015394
.001816
.0020533

Largest
.15
.16
.17
.24

residue
Smal lest
.014212
.014937
.016251
.016676

Largest
.067989
.06859
.08377
.083983

residue
Smallest
.0000119
.0000143
.0000152
.0000162

Largest
.277
.331
.461
.74

residue
Smallest



Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis





Obs
Sum of Wgt.
Mean
Std. Dev.

Variance
Skewness
Kurtosis






229
229
.0346431
.0385296

.0014845
2.043471
7.641382





231
231
.035152
.0119166

.000142
1.096623
4.739464





231
231
.0305996
.0726232

.0052741
5.824271
47.94944



                                           A-28

-------
1%
5%
10%
25%
50%

75%
90%
95%
6.43e-06
.0000328
.0001093
.0006945
.0053245

.0339306
.0963392
.1882241
9.38e-07
2.80e-06
6.43e-06
7.99e-06

Largest
.2970301
.3259095
.3350351


Obs
Sum of Ugt.
Mean
Std. Dev.

Variance
Skewness


231
231
.0348873
.0673469

.0045356
3.008914
99%     .3259095       .4361157       Kurtosis       13.11701
.  with logres meth if meth==1 |meth==2:  ksmirnov logres by(meth)
time-series operators not allowed
. with logres meth if meth==1 |meth==2:  ksmirnov logres,  by(meth)

Two-sample Kolmogorov-Smirnov test for  equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.4808    0.000
 Allender:          -0.1312    0.019
 Combined K-S:       0.4808    0.000      0.000

. with logres meth if meth==1|meth==3: ksmirnov logres, by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.0303    0.810
 MaxLIP4:           -0.4242    0.000
 Combined K-S:       0.4242    0.000      0.000

. with logres meth if meth==1|meth==4: ksmirnov logres, by(meth)

Two-sample Kolmogorov-Smirnov test for equality of distribution functions:

 Smaller group       D       P-value  Corrected
 original:           0.0562    0.484
 Novigen:           -0.3977    0.000
 Combined K-S:       0.3977    0.000      0.000

. qqplot logres! logresl, saving(picpdpH) xlab(-14(2) 0) ylab(-14(2) 0)
file picpdp11.gph already exists
r(602);

. qqplot logres! logresl, saving(picpdpl) xlab(-14(2) 0) ylab(-14(2) 0)

. qqplot logresl Iogres2, saving(picpdp2) xlab(-14(2) 0) ylab(-14(2) 0)

. qqplot logresl Iogres3, saving(picpdp3) xlab(-14(2) 0) ylab(-14(2) 0)

. qqplot logresl Iogres4, saving(picpdp4) xlab(-14(2) 0) ylab(-14(2) 0)

. graph using picpdpl picpdp2 picpdp3 picpdp4, margin(15) saving(pdppicO)
                                                   A-29

-------
Q-Q PLOT: PDF Single-Serving Special Study
 o-



 -2-



 -4 -



 -6-



 •8-



-10-



-12-



-14 -
                   •12   -10    -8    -6
                               Original
                      Quantile-Quantile Plot
                                                                 -10-


                                                                 •12-
                                                                    -14   -12   -10
                                                                         -s     -e
                                                                          Mender
                                                                  Quantile-Quantile Plot
                        -10    -8    -6    -
                               M»tlP4

                      Quantile-Quantile Plot
                                                              -12    -10    -s    -6
                                                                          Novigen
                                                                  Quantile-Quantile Plot
                                                       A-30

-------