United States      Prevention, Pesticides     EPA712-C-96-272
          Environmental Protection    and Toxic Substances     February 1996
          Agency        (7101)
&EPA    Occupational and
          Residential Exposure
          Test Guidelines
          OPPTS 875.2900
          Data Reporting and
          Calculations

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                           INTRODUCTION
     This  guideline is  one of a series of test guidelines that have been
developed by the Office  of Prevention, Pesticides and Toxic Substances,
United States Environmental  Protection Agency for use in the testing of
pesticides and toxic substances, and the development of test data that must
be submitted to the Agency for review under Federal regulations.

     The Office of Prevention, Pesticides and Toxic Substances (OPPTS)
has  developed  this guideline through a process of harmonization that
blended the testing  guidance  and requirements that  existed in the  Office
of Pollution Prevention  and  Toxics (OPPT) and appeared in  Title 40,
Chapter I,  Subchapter  R of the Code of Federal Regulations (CFR), the
Office of Pesticide Programs (OPP) which appeared  in publications of the
National Technical  Information Service (NTIS) and the guidelines pub-
lished by  the Organization for Economic Cooperation and Development
(OECD).

     The purpose of harmonizing these  guidelines  into a single  set of
OPPTS guidelines is to minimize  variations among the testing procedures
that must be performed to meet the data requirements of the U. S. Environ-
mental Protection Agency under  the  Toxic Substances  Control  Act (15
U.S.C. 2601) and the Federal Insecticide, Fungicide and Rodenticide Act
(7U.S.C.  I36,etseq.).

     This  guideline, along with the others in  Series 875.2000  through
875.2900, is being substantially revised for publication in 1997. However,
the current guidelines  are  still official. Before  initiating any studies for
post-application exposure registrants should contact EPA's Occupational
and Residential Exposure Branch (within the Office of Pesticide Programs)
at 703-305-6094.

     Final Guideline Release: This guideline is available from the U.S.
Government Printing Office, Washington, DC 20402 on The Federal Bul-
letin   Board.   By  modem   dial  202-512-1387,  telnet   and  ftp:
fedbbs.access.gpo.gov     (IP     162.140.64.19),     internet:     http://
fedbbs.access.gpo.gov,  or call 202-512-0132 for disks  or paper copies.
This guideline is also available electronically in ASCII and PDF (portable
document format) from the EPA  Public Access Gopher (gopher.epa.gov)
under the heading "Environmental Test Methods and Guidelines."

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OPPTS 875.2900   Data reporting and calculations.
     (a) Scope—(1) Applicability. This guideline is intended to meet test-
ing requirements of the  Federal Insecticide, Fungicide,  and Rodenticide
Act (FIFRA) (7 U.S.C. 136, et seq.).

     (2) Background. The source material used in developing this har-
monized OPPTS test guideline is OPP guideline 134.

     (b) Nondetectable residue method—(1) When used.  For purposes
of this section, a reentry interval is that time period beyond which there
are no  detectable  dislodgeable residues of the pesticide on surfaces to
which the pesticide was applied, as indicated by studies conducted as de-
scribed in OPPTS 875.2100 and 875.2200 of this guideline.

     (2) Approach. Environmental samples may be collected periodically
until no residues are detected in three consecutive samplings using suitably
sensitive analytical techniques  and  equipment. Alternately,  the  applicant
may be justified in extrapolating a dissipation curve to the minimum de-
tectable levels. The interval for residue dissipation to the nondetectable
level would be proposed as the reentry interval. For reentry intervals deter-
mined according to  this approach, exposure  information  described in
OPPTS  875.2400 and 875.2500  of this guideline are not required.

     (c) Allowable exposure level method—(1) When used. For purposes
of this  section, a  reentry interval  is  that  time period beyond which
dislodgeable residues on  surfaces to which  the pesticide was applied have
dissipated to the allowable exposure level  (AEL) (or lower) as indicated
by studies described in OPPTS 875.2100,  875.2200, 875.2400, and para-
graph (b) of this guideline.

     (2) Approach, (i) Calculation  of a reentry interval  according to the
criteria  of paragraph  (c)(l) of this  guideline involves evaluation of data
to determine that level of residue in a reentry site which will result in
an amount of human exposure under specified human activities that is at
or less than an AEL. To make this evaluation, the applicant should use
two kinds of data:

     (A) Data on the relationship between pesticide residue levels and total
human exposure during an eight-hour period.

     (B) Data on  the relationship between pesticide residue levels  and
time.

     (ii) For the approach outlined in paragraphs (c)(2)(i) of this guideline:

     (A) The applicant will determine  an  AEL and described according
to OPPTS 875.2000, paragraph (h), based on the  toxicity data required
by 40 CFR 158.340 and described by OPPTS Series 870 guidelines.

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     (B)  The applicant will examine human  exposure data to  determine
how much exposure (or what dose) a person would receive when perform-
ing activities (specific to the proposed use) in  a treated area with specified
levels of residues. These data will enable the  applicant to determine a re-
entry level (Rs) for a particular combination of human activity,  crop, pes-
ticide formulation type, and site.

     (C)  Finally,  the applicant will review residue dissipation  curves  to
determine how long after application it will take the residue levels to de-
cline to the reentry level in the particular study location, thus estimating
the reentry interval (Ts).

     (D)  The number of sampling units in the study and all assumptions
used in the calculations should be specified.

     (d) Adjustment to  reentry  intervals—(1) When used. A registrant
or registration applicant may provide information to support an adjustment
of a reentry interval. Such information should be of one of the types de-
scribed in paragraphs (d)(2) through (d)(4) of this guideline.

     (2) Adjustments based on toxicity studies. The animal toxicity stud-
ies described in OPPTS  Series 870  guidelines may have been performed
using test substances of an end-use  product or active  ingredient in a sol-
vent. Solvents may aid in dermal absorption of the pesticides and/or may
increase their apparent  toxicity. After application, such  components of end-
use products may dissipate from the  application  site more rapidly  than
the active ingredient. Testing of animals with the pesticide without sol-
vents may show  that it  is not as toxic as the  original product. If there
are sufficient differences in toxicity or in residue retention after applica-
tion, the applicant  may  wish to  submit data to support adjustment  of a
reentry interval.

     (3)  Adjustments  based on residue dissipation studies. In  some
cases, established reentry intervals are based on data developed from stud-
ies of a  site that may not adequately  characterize residue dissipation  at
another site because of regional and  climatological  differences, differences
in application methods, or differences in post-treatment methods  and expo-
sure. These factors would likely affect the slope of the residue vs.  time
curve. In such  cases, additional data may be  submitted to the Agency  to
support an additional reentry interval.

     (4)  Adjustments  based on human exposure studies. Data from
human exposure  studies  may indicate significantly different human expo-
sure levels because  of widespread changes in agricultural practices or other
conditions. Such  data may be submitted to support adjustment  of the re-
entry interval.

     (e) Early  reentry:  practices  and  limitations—(1) General. Local
conditions and  activities may necessitate early reentry by individuals into

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treated areas before the reentry period has completely elapsed. Such activi-
ties may include posting,  scouting, crop sampling, and similar  related ac-
tivities, often of a brief and limited nature. Several practices may be nec-
essary to protect individuals who must undertake early reentry.  Some of
these are described below. Consultation with local agricultural experts is
generally recommended before early reentry is undertaken.

     (2) Reduction of site residues.  Site residues may be reduced to re-
entry level by rainfall or  artificial means, such as spraying the  site  with
water. Data on residue  reduction by rainfall or equivalent spray washing
(as in overhead irrigation) may  be submitted to support early  reentry. In
those cases, early reentry  may be  granted to  allow people to enter treated
sites before expiration of the reentry interval.

     (3) Use of personal protective  equipment. Early reentry may be
granted to allow people to enter treated sites before expiration of the re-
entry interval by use of personal protective equipment, such as protective
clothing  and appropriate  respirators.  The personal  protective  equipment
should be appropriate for the pesticide residue levels at  the  site at the
time of reentry and should conform  to any  existing protective standards
(such as those established by OSHA). Data on the reduction of human
exposure to residues by use of personal  protective  equipment should be
submitted and support that the personal protective equipment would reduce
human exposure to the AEL and would be likely to be used.

     (4) Reduced  exposure times. The reentry level is based  on residue
exposures representative of normal reentry  activities  for an 8-hour  day.
In circumstances where only respiratory exposure  to airborne residue will
occur, early reentry may  be allowed  for  shorter periods at residue levels
higher than the reentry  level.  The  excursion factors described  in the
Threshold Limit Values (TLV) booklet of the American  Conference  of
Governmental Industrial Hygienists (ACGIH) may be used. Excursion fac-
tors  allow shorter exposures to  chemicals at levels  higher than  the TLV
or OSHA's  Permissible Exposure Limit.  This approach requires that the
exposure level be within an acceptable excursion range and that the prod-
uct of the concentration multiplied by the exposure  time does  not exceed
the product of the TLV concentration multiplied by 8  hours. Such excur-
sion factors are applied only to  chemicals which do not have  established
ACGIH "ceiling" designations. The ceiling  designations indicate that the
TLV should not be exceeded.

     (5) Residue level  test kits.  Early reentry may be allowed if  field
test  kits  establish  that residues  have dissipated to reentry level prior to
expiration of the reentry interval. Data should be submitted to support the
use of field test kit systems for monitoring pesticide residue levels. Such
systems could include any of several chemical residue detection devices
or procedures that would readily  indicate when residue levels of treated

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sites are greater  or  less than the AEL. (For this  factor,  the  adjustment
could either extend or shorten the reentry interval.)

     (f) References. The following references should be consulted for ad-
ditional background material on this test guideline. The following publica-
tions report procedures for the analysis of organophosphorus pesticide resi-
dues in the worker environment suitable for rapid tests in agricultural sites.

     (1) Smith, C.A., F.A.  Gunther, and J.D. Adams. 1976. Worker envi-
ronment research. III. A rapid method for the semiquantitative determina-
tion of some dislodgeable pesticide residues on citrus foliage. Bull.  Envi-
ron. Contam. Toxicol. 15:305-310. [This paper reported the use of a device
for sampling foliar surface residues, and rapid methods for residue cleanup
and quantification of organophosphorus pesticide residues. The method de-
pends   upon  the   generation  of  a   color   by   reaction   with   4(4-
nitrobenzyl)pyridine. ]

     (2)  Smith,   C.A.,  and F.A. Gunther.  1978.   Rapid  estimation  of
organophosphorus pesticide residues  in citrus  grove soil. Bull. Environ.
Contam.  Toxicol.   19:571-577.   [A   procedure for field analysis  of
organophosphorus pesticide residues sorbed to surface soil is reported in
this paper.]

     (3) Berck, B., Y. Iwata, and F.A. Gunther.  1981. Worker environment
research: Rapid field method for estimation of organophosphorus insecti-
cide residues  on  citrus foliage and in  grove soil.  J. Agric. Food Chem.
29:209-216.  [This paper is an  elaboration of the  studies  in  paragraphs
(f)(l) and  (f)(2)  of this guideline using different sampling methodology
and instrumentation. Procedures are reported for both foliar and soil resi-
dues.]

     (4) Iwata, Y., J.B.  Knaak, G.E. Carman, M.E.  Dusch, and F.A. Gun-
ther. 1982. Fruit residue data and worker reentry research for chlorthiophos
applied to California citrus trees. J. Agric. Food Chem. 30:215-222.  [This
paper reports  dissipation data for a pesticide and its five toxic alteration
products and uses that data to estimate a reentry interval by the AEL and
the CDF A methods. The authors report that both methods  give the same
reentry interval.]

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