MEETING
BEFORE THE
SCIENTIFIC REVIEW PANEL
OF THE
CALIFORNIA AIR RESOURCES BOARD
SOUTH SAN FRANCISCO CONFERENCE CENTER
255 SOUTH AIRPORT BOULEVARD
SOUTH SAN FRANCISCO, CALIFORNIA
FRIDAY, SEPTEMBER 17, 1999
8:30 A.M.
Vicki L. Ogelvie, C.S.R.
License No. 7871
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MEMBERS PRESENT
Dr. John Froines, Chairman
Dr. Craig Byus
Dr. Paul Blanc
Dr. Stanton Glantz
Dr. Gary Friedman
Dr. Hanspeter Witschi
Dr. Peter Kennedy
Dr. Roger Atkinson
Others Present:
Bill Lockett, Liason
Peter Mathews, ARB
Lynn Baker, ARB
Jim Behrmann, ARB
Kevin Mongar, ARB
Randy Segawa, DPR
John Sanders, DPR
Dr. Keith Pfeifer, DPR
Dr. Jay Schreider, DPR
Dr. Robert Spear, UC, Berkeley
Dr. Michael Majewski, US Geological Survey
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I N D E X
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Page
Proceedings 1
Call to Order 1
Opening remarks by Chairman Froines 1
AGENDA ITEMS:
Item 6 - SRP Workshop: Pesticides in the Air 2
Scientific issues in the design of an air
pollution sampling strategy,
presentation by Dr. Spear 82
Sampling of multiple pesticides,
presentation by Dr. Majewski 96
Afternoon Session 118
Prioritization 124
Adjournment 150
Certificate of Reporter 151
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1 P R O C E E D I N G S
2 --o0o--
3 CHAIRMAN FROINES: We will call the meeting to
4 order.
5 We are still missing two Members of the Panel, but
6 we have a quorum, so we will be ahead because we have a long
7 Agenda for today.
8 We are going to change the Agenda slightly. We are
9 going to start with current monitoring requests and
10 protocols, given by DPR staff and ARB staff, and then we are
11 going to go to update on 1999 projects, by Lynn Baker and his
12 staff, and then to changes to the current practice being
13 considered, DPR and ARB.
14 So, it is a very slight modification. So, why
15 don't we get started.
16 Just by way of background, for those that are not
17 familiar with why we are having this semi-workshop,
18 basically, as most of you know, when we find a chemical as a
19 toxic air contaminant within the context of the Air Resources
20 Board, that determination is made primarily on the basis of
21 health effects information, also with some knowledge of
22 exposure, whereas with DPR, the criteria for determining a
23 compound as a toxic air contaminant is based upon both health
24 effects information, risk assessment, as well as on the
25 results of air borne monitoring, which enables them to
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1 calculate MOE.
2 Since the issue of exposure and monitoring is so or
3 such a crucial element in the determination of a compound as
4 a toxic air contaminant with the Department of Pesticide
5 Regulation, we thought it would be important to look at how
6 effective we are approaching the issue of monitoring of
7 pesticides, with specific reference to the development of
8 protocols for monitoring and how to maximize our
9 opportunities, and it is particularly important, because, for
10 example, yesterday, it was apparent with methyl parathion,
11 that both -- there has been dramatic changes in the use of
12 methyl parathion in a number of counties and that the nature
13 of the pesticide use on the crops has changed.
14 So, we exist in a situation where the circumstances
15 change. How frequently, is not clear, but it is a changing
16 problem, and how we can best determine what the exposures may
17 be to the public is an issue of major consequence.
18 So, that is the underlying basis of this workshop.
19 So, why don't we go ahead and get started.
20 I don't know who will be lead for DPR.
21 MR. BAKER: Good morning, Dr. Froines, Members of
22 the Panel.
23 I'm Lynn Baker, with Air Resources Board. On my
24 left is Randy Segawa, from the Department of Pesticide
25 Regulation.
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1 We are going to give you a joint presentation this
2 morning on ARB's current approach to air monitoring of
3 pesticides. I also would like to introduce Kevin Mongar, who
4 will help us out with the overheads.
5 Kevin is with our Monitoring Lab Division, and
6 coordinates our field monitoring of pesticides and so if
7 analytical questions come up later in the presentation,
8 either he or Bob Okamoto, one of our chemists, can probably
9 answer analytical questions for us.
10 CHAIRMAN FROINES: I just want to make one point so
11 that everybody keeps in mind, one particular element of all
12 this, as we go through the morning, that is when we say,
13 talking about cotton, cotton doesn't have one pesticide
14 applied.
15 Cotton is one of the examples where you have
16 multiple pesticides, and so we have a tendency to take up
17 chemical by chemical, but that is not the way that the real
18 world exists.
19 Crops have multiple pesticide exposure. Therefore,
20 there is a potential for public exposure to multiple
21 pesticides from various crops. So, one of the issues that we
22 really have to address on the ongoing basis in the future and
23 beginning of this point, how can we address issues of
24 monitoring with respect to multiple pesticide exposure and
25 how can we incorporate to the risk assessment process, so
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1 that we are actually dealing with situations that are real
2 world situations rather than sort of abstract, regulatory
3 issues, where you take one thing at a time, which isn't the
4 reality.
5 Go ahead.
6 MR. BAKER: Thank you, for the additional
7 introduction.
8 We are going to first touch on the current
9 approach, and then Randy is going to go through suggested
10 modifications we have to that approach to address your point
11 about the exposure to multiple pesticides.
12 As most of you are aware, the Health and Safety
13 Code and the Agricultural Code requires the Air Resources
14 Board to conduct air monitoring of pesticides, at the request
15 of the Department of Pesticide Regulation, in support of
16 their toxic air contaminant program, and since 1986, we have
17 been doing air monitoring of pesticides in support of DPR.
18 I'm going to give a very brief overview of our
19 monitoring approach, and then Randy is going to describe the
20 monitoring recommendations that DPR gives us and the
21 pesticide use reporting system which is critical to those
22 monitoring recommendations.
23 Then we will describe our current study design,
24 give status of the monitoring to date and then we will finish
25 up with the update on this year's monitoring.
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1 Next slide.
2 We heard a little yesterday about DPR's
3 prioritization process. I guess we are going to hear a
4 little bit more later this morning.
5 Out of that prioritization process comes requests
6 to the ARB from DPR for monitoring of specific pesticides
7 and, as Dr. Froines mentioned, to date we have always
8 approached this on a pesticide by pesticide basis.
9 The DPR then provides ARB with a detailed
10 monitoring recommendation from which we, points us in the
11 direction of where and when to go, and then we develop a
12 sampling analysis methods, conduct the monitoring and provide
13 DPR with a report of the results.
14 Randy is going to describe our, the DPR monitoring
15 recommendation process.
16 MR. SEGAWA: Next slide.
17 Can you hear me okay?
18 How's that?
19 DPR requests monitoring from Air Resources Board
20 for five to six chemicals per year currently, plus any
21 breakdown products which we need or find necessary as well.
22 A couple of weeks ago, we sent the Panel Members an
23 example of both the monitoring recommendation and a protocol
24 that Air Resources Board creates for bifenthrin.
25 This is one of the chemicals that we are currently
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1 monitoring. DPR monitoring recommendation contains some
2 background information on the physical and chemical
3 characteristics of the chemical, vapor pressure, water
4 solubility, soil absorption constant and dissipation rates.
5 In addition, we describe how the specific chemical
6 is used, the amount applied, both statewide as well as by
7 individual county, the principal crops for which that
8 pesticide is used, the target pests, areas or counties of
9 high use, periods or seasons of high use, the different types
10 of formulations, whether it is a malathion concentrate or
11 ground or material, then methods of application, whether its
12 primarily a soil applied chemical, aerial applied chemical or
13 some other.
14 Then our recommendation also contains specific
15 suggestions for how to conduct the monitoring in terms of the
16 area or county that should be targeted, the months or season
17 that should be targeted for monitoring, the crop that should
18 be located in that particular area, any breakdown products
19 that should be monitored, as well as target quantification
20 limit, which is developed by our toxicology staff, and we
21 also make recommendations on number of sampling sites, number
22 of samples and duration of the individual samples and then
23 some suggestions about quality assurance as well.
24 For the application specific monitoring, we also
25 make additional recommendations on the application rate that
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1 should be monitored, the crop that should be monitored, the
2 size of the fields, we normally make a recommendation, for
3 example, how a ten-acre field should be monitored and then
4 the sampling schedule, the time period that the application
5 monitoring during application should occur, as well as the
6 following periods.
7 While we may make suggestions for specific
8 applications, a lot of times, for a variety of reasons, ARB
9 is not able to locate to an ideal application, so we may have
10 to monitor, for instance, a lower application rate than the
11 maximum we desire.
12 DPR also makes recommendations regarding safety for
13 the monitoring personnel.
14 CHAIRMAN FROINES: That little sentence is the key
15 issue, because you may not be able to monitor ideal
16 applications from the standpoint of the risk assessor.
17 That is the fundamental question as to how maximize
18 our monitoring, quote, ideal application. That is really the
19 center of why we are doing this whole workshop.
20 That is not something to pass over.
21 MR. SEGAWA: Now, I would like to talk about sort
22 of a side issue for a couple of minutes here, because it is
23 important to monitoring recommendation that is DPR's
24 pesticide use report program.
25 DPR at that time was Department of Food and
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1 Agriculture. We had a statewide reporting program since
2 1970, but only since 1990, we have what we call a full use
3 reporting system, and that is virtually all agricultural
4 applications are now reported to the county agricultural
5 commissioner, who then turns that information over to DPR,
6 and we compile it on an annual basis.
7 While there is a full use reporting system, there
8 are some applications that are not reported. In particular
9 home and garden use is not reported. Most industrial and
10 institutional applications are also not reported.
11 So, applications to schools or factories, things
12 like that, those types of applications are not reported to
13 DPR.
14 There are two primary types of reports that come to
15 us. One is what we call the production agricultural report
16 and then the second type is the summary report.
17 The production agricultural report is a report used
18 by all growers, most pest control operators and other
19 professional businesses in producing agricultural
20 commodities.
21 The information that is reported to us includes the
22 county in which the work was performed, the geographic
23 location which is given by base, meridian, township, range
24 and section.
25 This is the public land survey coordinate system
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1 that is used by the state, so we can identify the geographic
2 location of the application to within one square mile.
3 Then there is always a field location
4 identification that is normally assigned by the individual
5 county. The upper identification of permit number is
6 reported as well as the name, address, of both the operator
7 or grower of the fields, as well as applicator making the
8 pesticide application.
9 Then each site or field within the state is
10 assigned an ID number. Although it does vary by county, that
11 is the system for assigning the ID number, it varies from
12 county to county.
13 The commodity or crop that is treated is reported,
14 the number of acres planted, as well as the number of acres
15 treated is reported, date and time of application, the method
16 of application, at least whether it's an aerial, ground or
17 other type of application.
18 DR. GLANTZ: What would other be?
19 MR. SEGAWA: Other might be cow dip, for example.
20 For DPR, we have a very broad term for agricultural
21 use, so it includes things like livestock dips. It includes
22 applications to poultry and fish.
23 It includes rights of ways applications,
24 applications to timber, so it is a very broad definition of
25 agricultural in this case.
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1 Then the registration number of the specific
2 pesticide product is reported, and then the name of the
3 manufacturer of the pesticides as well.
4 The total amount of product applied for any
5 specific application is reported and the person who prepared
6 the report as well.
7 Then there are some types of applications for which
8 we only get summary information. We don't get as much
9 detailed information as we do for the production agricultural
10 applications, and these include applications for structural
11 pest control, landscape maintenance, rights of way, public
12 health, such as a mosquito abatement, vertebrate pest
13 control, commodity fumigation and regulatory pest control,
14 Med Fly ratification program, for these types of application,
15 we get information regarding the county in which the work was
16 performed, the operator identification name and address, the
17 particular pesticide product that was applied and its
18 registration number, the commodity or site that was treated,
19 and the total amount applied.
20 If you make a comparison to the previous slide, you
21 notice you don't get information about the specific location,
22 number of applications, the acreage treated, there was a
23 number of important information that we do not get for these
24 types of applications.
25 MR. BAKER: To summarize, again, the DPR gives us a
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1 request, and then that request is followed up a few months
2 later by the detailed monitoring recommendation that Randy
3 just summarized describing the following information.
4 Two key points on that slide I would like to
5 highlight, in item C, the request may include breakdown
6 products.
7 For instance, next year's monitoring request from
8 DPR asks the ARB to do monitoring for six different
9 pesticides.
10 In addition, they have asked for five breakdown
11 products of those pesticides. In terms of sampling and
12 analytical preparation standpoint, that's almost twice the
13 workload, as if there weren't, compared to no breakdown
14 products.
15 DR. BLANC: Why is that, the workload?
16 MR. BAKER: Because the different sampling and
17 analytical methods have to be developed for this break down
18 products and they have to be developed in advance of the
19 field sampling.
20 DR. BLANC: Well, how frequently is, in fact, the
21 sampling methodology different?
22 MR. BAKER: The sampling methodology is usually not
23 different. There has been one case that I can remember where
24 it was different but it is usually the analysis method that
25 is different.
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1 DR. BLANC: So, it shouldn't be twice the work
2 then?
3 MR. BAKER: It's not quite twice the work.
4 DR. BLANC: I mean, it is more work for the
5 analytical chemical side of your operation, but I would say
6 that, I would assume that 90 percent, or 95 percent of all
7 the labor involved in these kinds of sampling is, in fact,
8 the sampling and that the analysis, which could then be
9 batched and done is actually, I'm not trying to belittle the
10 analytic side, but I would imagine in terms of person hours
11 of labor, the vast majority of the work must be in the
12 sampling.
13 MR. BAKER: I actually think it is in the analysis.
14 Some of these have taken, and Kevin, you might want
15 to respond to this, but some of these have taken a couple of
16 months of staff's time for method development followed by
17 several weeks of actual analysis of the individual samples,
18 where it is a month to six weeks of one staff time in the
19 field to collect the samples.
20 Does that respond to your question?
21 DR. BLANC: Yeah.
22 CHAIRMAN FROINES: Lynn, as you get into this, I
23 wanted to, Randy's final two sentences were about what is
24 missing, and this review of what is obtained in terms of the
25 pesticide use reports, the striking thing about them is what
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1 is missing as well as what is here.
2 So, in terms of developing a defined protocol for
3 monitoring purposes, hopefully you two can talk about what is
4 missing in the pesticide use reports in terms of maximizing
5 the monitoring as well as how you use the pesticide use
6 report.
7 MR. BAKER: We will.
8 The last point on this slide that I wanted to make
9 was that DPR's monitoring recommendations, the final point
10 there on the slide, requests that ARB provide results within
11 18 months of receipt of the recommendation.
12 We strive to meet that. Occasionally, if there are
13 unforeseen weather patterns that lead to unusual use of a
14 pesticide either early or late or very little, creates some
15 problems in preparing our analytical methods ahead of time,
16 and we may have to postpone the monitoring, so it may take us
17 two and a half years to find results rather than the one and
18 a half years.
19 Just a minor point.
20 DR. BYUS: I have just a brief question.
21 So, when you go out to monitor, DPR just doesn't
22 decide to spray a field with a certain amount at certain
23 time?
24 You go and find some farmer applying something that
25 you are interested in?
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1 MR. BAKER: Yes.
2 I will go into that.
3 DR. BYUS: Sorry.
4 MR. BAKER: That is all right.
5 As Randy mentioned in going through the monitoring
6 recommendation, there are two types of monitoring that we do,
7 ambient monitoring, for general population exposure, and
8 application site monitoring, that is associated with a
9 specific field application, and that is for acute, short term
10 concentrations.
11 Before we can do either one, the sampling analysis
12 methods have to be developed. So, they are developed prior
13 to the field sampling. They include the lab studies of
14 efficiency and sample stability to make sure the methods will
15 accomplish what we want them to accomplish.
16 The field studies include lab blanks and spikes,
17 trip blanks and spikes and field spikes.
18 DR. GLANTZ: For us who aren't -- can you explain
19 what that means in English?
20 MR. BAKER: I will.
21 The lab blanks and spikes are fairly
22 self-explanatory. You analyze a blank, whether it's a XAD
23 resin or a charcoal to be analyzed, a blank, to see if there
24 is any trace of the target pesticide on the blank.
25 The spike, you put known amounts of the pesticide
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1 on a charcoal tube, desorb it, and hopefully, you will get
2 close to the amount off of the charcoal that you spiked onto
3 it.
4 The trip blanks and spikes are samples that
5 actually go out into the field, with the field samples, so
6 there would be, for the charcoal tube, for instance, it would
7 be blank charcoal tubes, and then spiked charcoal tubes that
8 would be put into the ice chest with the dry ice, when the
9 field staff goes out into the field, they would accompany the
10 batch of samples back to the lab, and then they would show up
11 as either contamination on the blanks or degradation of the
12 samples that were spiked.
13 DR. GLANTZ: Do you spike them, do you spike them
14 before you go out or while you are in the field?
15 MR. BAKER: Before we go out.
16 Then field spikes are much like the trapping
17 deficiency studies, only their samples that are taken, spiked
18 samples that are taken out into the field, air is drawn
19 through them for 24 hours, if that is the ambient sample, the
20 sample is put on dry ice, brought back to the lab and
21 analyzed to check for any losses.
22 It is similar to the trapping efficiency studies,
23 only that these are done in the actual field conditions
24 rather than ahead of time here in Sacramento.
25 The sampling media have included XAD resin or
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1 charcoal absorbents, or three types of filters, glass, fiber,
2 quartz or teflon, depending on the target pesticide you are
3 interested in.
4 Sampling flows are varied from 2 to 30 liters a
5 minute, depending on whether we are doing ambient or
6 application site monitoring, and also depending on the group
7 that has done our work.
8 Some of our work has been done by our Monitoring
9 Lab Division, and some of it over the years has been
10 contracted out to universities, and then various analysis
11 methods are used from gas chromatography or high performance
12 liquid chromatography methods.
13 Then a study protocol, and I believe Randy
14 mentioned an example study protocol, bifenthrin, had been
15 sent to the Panel Members, sent as an example.
16 The study protocol is prepared, that summarizes the
17 analysis methods, and all of our studies follow ARB's quality
18 assurance plan for pesticide monitoring, that spells out how
19 we go about all of this.
20 The ambient monitoring for general population
21 exposure is conducted during a period of high use in a county
22 of high use. This is done following DPR's monitoring
23 recommendation.
24 Historically DPR would direct us to do monitoring,
25 in particular a county, say Fresno County, we would contact
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1 the Agricultural Commissioner. They would give us some hints
2 in terms, well, the grapes are grown in this particular area
3 of the county.
4 The fungicide you are looking for is probably used
5 in these areas, and we would go out and look for sampling
6 sites in that area.
7 We have greatly improved that somewhat flawed
8 system by the DPR now giving us maps that show historical use
9 of the target pesticide in the target county, and I will show
10 some examples of those later in my presentation.
11 Those we feel are really helping us get a lot
12 closer to the actual use of the target pesticide. To date,
13 you might be interested in knowing we have done monitoring in
14 18 different counties throughout the state, all the way from
15 the Tule Lake region, up near the Oregon border, all the way
16 down to Imperial County, within a stone's throw of the
17 California-Mexico border.
18 Next slide.
19 When our Monitoring and Lab Division is preparing
20 to go out in the field to do the monitoring, they do contact
21 the Agricultural Commissioner.
22 DPR usually gives them a heads-up that we are going
23 to be coming out and doing monitoring. Our field staff
24 contacts them to discuss the expected time and area of use of
25 the target pesticide, find out if any quirks occurred this
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1 particular year regarding weather conditions or the need for
2 the pesticide that particular year are going to affect our
3 monitoring.
4 I am not sure if that is the first question they
5 always ask, Kevin, or if your first question is where do you
6 recommend going for lunch.
7 Next. Some of these areas are in some pretty
8 remote parts of our state but very interesting areas.
9 The primary monitoring sites and urban background
10 sites are selected as follows. We pick three to five primary
11 monitoring sites that meet the ambient siting criteria for
12 ambient air sampling.
13 We pick the sites typically at schools or fire
14 stations in the area of expected use of the target pesticide.
15 The monitoring sites are often put on the roofs of
16 schools, one-story roofs of schools, those meet siting
17 criteria in one of our other key criteria, that the sites
18 have to have power, because most of our sampling pumps
19 require electricity.
20 Application site monitoring surrounding a field is
21 typically done with either batteries or generators, but for
22 our ambient monitoring, we need electricity.
23 DR. GLANTZ: What are your ambient siting criteria?
24 MR. BAKER: Actually, Kevin has a slide that he
25 can put up.
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1 When we first started this measuring in 1986, we
2 adopted EPA's ambient air quality monitoring siting criteria,
3 which specified that representing air quality measurements
4 would be made anywhere from 2 to 15 meters above ground with
5 vertical and horizontal spacing away from structures of a
6 minimum of one meter.
7 The sampler should be at least 20 meters from
8 trees. The distance from any obstacle that sticks above the
9 sampler, such as a tree or a nearby building must be at least
10 twice the distance that the obstacle protrudes above the
11 sampler intake.
12 The sampler must have 270 degree unrestricted air
13 flow around the sampler, and there are criteria regarding
14 co-locating some of the samplers for quality assurance
15 purposes for duplicates, and those should be two to four
16 meters apart, except for very low flow samplers, one of the
17 low flow samplers where it is not so critical that they be
18 two to four meters apart.
19 DR. GLANTZ: What about, if you are sampling for
20 some pesticide which is being used, let's say outside of
21 Fresno, you obviously wouldn't do your ambient sampling on
22 the roof here.
23 What is the criteria, if you are doing application
24 sampling?
25 Or do you do it adjacent to the field?
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1 But for the ambient sampling, what are the rules or
2 criteria in terms of where you are sampling relevant to the
3 application sites?
4 MR. BAKER: We use the use maps which I will show
5 at the end of my presentation.
6 We look for towns in the areas of the expected or
7 historical use, and then we look for monitoring sites that
8 are on the edges of towns, near the target crop.
9 So, if we are looking for cotton, we find a
10 pesticide that is applied on cotton.
11 We look for small towns in the cotton growing
12 regions in the San Joaquin Valley. Then we look for schools
13 typically in those small towns that are near the cotton
14 growing region, and then we have to, of course, seek
15 permission from those sites to request permission to actually
16 use one of those sites for our monitoring.
17 DR. GLANTZ: Okay. Thank you.
18 MR. BAKER: Sure.
19 DR. MAJEWSKI: Do you take any meteorological
20 information or measurements?
21 MR. BAKER: We do for our application site
22 monitoring.
23 We don't for the ambient monitoring, since it is
24 for six weeks, for twenty-four hour samples. We haven't seen
25 a need to collect the meteorological data.
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1 DR. ATKINSON: You could get it?
2 MR. BAKER: Oh, we could always get it from local
3 stations or air quality monitoring stations if we wanted it,
4 but we haven't seen any use for it.
5 CHAIRMAN FROINES: If I could just comment, Bob,
6 feel free to ask questions as the two of you find questions
7 that you think are appropriate.
8 MR. BAKER: Actually, I would like to go away from
9 this overhead for a minute and show a couple of slides, and I
10 don't have the slide changer.
11 I want to just show you five slides just to give
12 you an idea of some of these monitoring sites.
13 This is the town of Pond, in Kern County. This is
14 an ideal site.
15 We don't always come up with sites that are this
16 ideal.
17 Let me find the pointer.
18 DR. GLANTZ: The thing in the middle is the town?
19 That is a pretty little town.
20 MR. BAKER: This is actually -- well, it is a very
21 small town.
22 This is the Pond Elementary School.
23 These are almond orchards in this area. The target
24 pesticide in this case was as azinphos-methyl, which was to
25 be applied to almond orchards.
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1 So, we have been directed to look for almond
2 orchards. We were able to find this school, obviously
3 surrounding a couple of sides by almonds orchards.
4 Our flaw, of course, is always that we don't know
5 for sure that the pesticide is going to be applied to the
6 target crop in this, the almond orchards, when we set up our
7 ambient monitoring sites, but DPR can find that out after the
8 fact by checking the information.
9 CHAIRMAN FROINES: Can we just focus on that point?
10 Because it seems to me you have said this on at
11 least three other occasions when you made presentations, and
12 it seems to me that this is like the fundamental question.
13 If I had a kid in that school, I would probably
14 move them to another school. But let's assume that we have
15 children in the school.
16 I would really want to know whether my child was
17 being heavily exposed to azinphos-methyl, and I wouldn't be
18 very happy if I was told that we did monitoring, but maybe
19 and maybe not the pesticide was in use at the time that they
20 were monitoring.
21 It seems to me like it was such a fundamental
22 issue. How can I do the monitoring without some sense that
23 the chemical is being used?
24 MR. BAKER: It's obviously a very fundamental
25 question, and we have been unable to grapple with that to
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1 date.
2 I don't know. Randy, is there any way that the
3 agricultural commissioner could assist us in talking with the
4 growers or owners of these target crops prior to monitoring?
5 This is an unusual case that we were surrounded
6 this close.
7 More typically --
8 CHAIRMAN FROINES: Wait a second. It's your
9 example. You chose the picture.
10 The point is if you have a child in that school,
11 you have to sample when the material is being applied to get
12 some estimate whether children are at risk from that
13 pesticide, otherwise it makes no sense.
14 MR. BAKER: In this example, we were not put in
15 touch with the grower or owner of the property so, we had no
16 way of knowing when we set up the sampling whether, and I'm
17 not even sure when we set up the sampling whether the grower
18 knew whether he was going to need to apply azinphos-methyl to
19 this almond orchard.
20 DR. ATKINSON: What?
21 That is silly. It is obvious that you need to know
22 whether the grower is going to use a pesticide and when, and
23 it may change the application.
24 DR. GLANTZ: Earlier in the presentation, DPR gave
25 us all the information that is reported to them.
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1 Is that done after the fact?
2 DR. SPEAR: I would suggest, John, that they
3 actually do know this, because the monitoring of the
4 application itself is what's relevant to the school if it is
5 this close and had a lot of data on it, so they know, so,
6 they just don't get it from this ambient --
7 MR. BAKER: So, when we do application site
8 monitoring, this is about as close as we are to the actual
9 application sites when we do monitoring.
10 We would know the application rate and time of the
11 application.
12 What I was going to say is, looking at this school,
13 more typically, the closest field would be out in this
14 region. So, there would be a half a mile, a mile away and
15 there would be multiple different growers and owners, and it
16 would be the agricultural commissioner would have to assist
17 us in contacting all these different growers and owners of
18 the property, because we would have no way of knowing who
19 they all were, and being able to contact them all to try and
20 find out if they had an idea whether or not they were going
21 to be applying that target pesticide over the next six weeks
22 that we were doing the ambient monitoring.
23 The acute or worst case close near field exposure
24 issue is addressed by the application site monitoring.
25 DR. GLANTZ: Yeah, but that -- I don't understand.
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1 If when you are doing the application site
2 monitoring, you obviously have to know that they are applying
3 the pesticide in order to monitor it. So, there is some way
4 that you can find out if a pesticide is being applied before
5 the fact.
6 MR. BAKER: In that case, we are put in touch with
7 a single grower or applicator, so we aren't having to try and
8 find out this information from numerous fields and numerous
9 owners and applicators.
10 We are only working with a single individual.
11 DR. GLANTZ: If your ambient, I don't want to just
12 repeat what other people have said too much, but a little
13 bit.
14 It has never stopped me before.
15 DR. BYUS: Any of us.
16 DR. GLANTZ: That is true, but it just makes no
17 sense to go out and collect ambient data on pesticide levels
18 unless you know they are being used at the time that you are
19 collecting the data, because these pesticides are only used,
20 many of them, for brief periods during the year.
21 You've got to figure out some way to find out. The
22 historical data that you alluded to earlier should be of some
23 help, because these things tend to be used in more or less
24 the same places year after year, but as we talked about
25 yesterday, there are also times that these uses can change
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1 very radically.
2 I think a big hole in what you are doing is this
3 problem. I realize it is not easy, but I think you guys need
4 to put in place procedures working with DPR and the county ag
5 commissioners to make sure that you know what is being used.
6 Two things, one is to find out when these things
7 are going to be applied so you can do your ambient monitoring
8 when you can reasonably expect them to be applied, and after
9 the fact, find out exactly what was being done during your
10 monitoring period so you kind of know what the denominator
11 is.
12 DR. BLANC: May I ask a regulatory question?
13 The ratio of toxicity to actual exposures, which
14 has some initials, John mentioned earlier --
15 CHAIRMAN FROINES: MOE.
16 DR. BLANC: MOE. Does that always have to be based
17 on the ambient, or is it based on the edge of the field
18 application air borne values, or is there a regulatory reason
19 why you have to do the ambient level?
20 MR. BAKER: The DEF report, as example, the ambient
21 data was used to compare with the DPR seasonally adjusted
22 daily dose, the overall, but the general seasonal
23 concentration, and this general population exposure ambient
24 air data was what was used to compare with that seasonally
25 adjusted exposure level where the application site data, the
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1 acute data is compared with the daily dose, so that the acute
2 exposure level, I believe DPR uses two types of data for two
3 different reasons.
4 CHAIRMAN FROINES: Yesterday, we moved forward on
5 methyl parathion as being a toxic air contaminant, and the
6 MOEs that were calculated were in part based on the
7 application data.
8 In fact, that's what gave you the numbers that got
9 you to meet your criteria for it being listed as a TAC, so,
10 in fact, methyl parathion is a compound in which the
11 application data was used as a defining criteria for
12 designation.
13 DR. BLANC: The reason that I am asking the
14 question is, I wonder if there is any rationale at all for
15 the ambient sampling, and maybe all the effort should be put
16 in doing more sites for application monitoring since that is
17 the one time when you seem to be able to know in advance that
18 it is actually going to be used, and since it is a worst case
19 scenario, if that were negative, that would be eliminated,
20 and if it were positive, then you could use it for rationale
21 in public health policy.
22 DR. SPEAR: I am going to make a suggestion along
23 those lines when we get to my part of the discussion.
24 MR. BAKER: One of the things that we are going to
25 discuss is some of the modifications to the current
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1 approaches to do more than one application site study.
2 DR. BYUS: I agree, but would that minimize your
3 chance of getting multiple pesticides?
4 I think that the ambient, whatever it is, may
5 increase the chances of seeing multiple pesticides if you
6 concentrate only on application site, you would reduce that
7 probability.
8 MR. BAKER: You're right.
9 The ambient is the best approach for looking at
10 exposure to multiple pesticides, but in terms of a worst case
11 situation, the application site is far better.
12 DR. BYUS: Just briefly, say that you put your site
13 there, you want me to leave it there for six weeks; is that
14 correct?
15 MR. BAKER: Correct.
16 DR. BYUS: Why couldn't you in a case like this,
17 this is such a great site, you should leave it there for six
18 years for the ambient thing like for air monitoring all over.
19 DR. GLANTZ: That would certainly solve the problem
20 not knowing when the applications were done, because if you
21 sample for a long time, then you could go back and use the
22 post op reports that DPR gets to figure out when the
23 applications were being done and then look at the appropriate
24 samples.
25 MR. BAKER: We would still have no guarantee though
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1 this orchard has --
2 DR. BLANC: If you were trying to address the
3 question of integrating within a square mile what multiple
4 pesticides were used, and is there any ambient amount that
5 could be measured at this particular potentially high risk
6 place, and it would be asking a different question.
7 MR. BAKER: We have picked six weeks as kind of a
8 compromise between the typical window that the pesticide is
9 used, which is typically a month or two of the year versus
10 our resources.
11 DR. BLANC: You have high volume sampling going on
12 for six weeks.
13 Is this sampling apparatus checked on a daily
14 basis?
15 MR. BAKER: It is checked four times a week.
16 Four 24-hour samples are collected each week for
17 six weeks.
18 DR. BLANC: Oh. It is only a 24-hour sample.
19 It is not continuous monitoring?
20 It is intermittent?
21 MR. BAKER: It is one integrated 24-hour sample.
22 DR. BLANC: Four times a week?
23 So, four out of seven days?
24 MR. BAKER: Yes.
25 DR. ATKINSON: Previously you said in a condition
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1 like this you wouldn't have wind direction or anything else,
2 and this particular example looks as though that would be one
3 you would need.
4 MR. BAKER: It would -- there are enough stations,
5 air quality stations around, if we were interested, it would
6 not be that hard to get the information.
7 CHAIRMAN FROINES: I want to go back to a question
8 that Stan asked, too, because I think that this discussion is
9 illustrative, and I think Bob will probably speak to it, but
10 your, the siting criteria that you gave is entirely
11 mechanistic in a sense, doesn't have anything to do with
12 health problems, and it seems to be that one should define
13 what we want to have happen out of this is to define criteria
14 that has to do with whether or not there is a potential
15 health problem and how to look at that.
16 So, the ambient monitoring gives you some long term
17 average, whereas the application monitoring gives you a worst
18 case scenario, if you allow me to use that.
19 It is those kinds of criteria, it seems to me, you
20 need to establish. In other words, the monitoring should be
21 reflective of the problem that you are trying to identify,
22 and this is an example of the problems that we have in all
23 air pollution around the use of monitoring to identify
24 exposure, and so the question is, how does one identify
25 exposure, and what is the relationship between monitoring and
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1 exposure, and what criteria does one want to use within that
2 context?
3 MR. BAKER: I agree.
4 I think we probably should try to develop some
5 additional siting criteria. Maybe we can work out a system
6 with DPR with the ag commissioners for us to target some
7 specific crops or some specific fields and to make some
8 initial contacts with those actual growers to have some sense
9 whether or not they plan to use the pesticide.
10 The only potential problem with that would be that,
11 warned in advance that we may be doing monitoring for that
12 targeted pesticide, that grower may choose to use an
13 alternate for pesticide.
14 DR. BYUS: Being a laboratory scientist, can't you
15 just take a field and know how much pesticide is applied with
16 the appropriate doses, apply it yourself and monitor after
17 you apply by whatever criteria and application rate and
18 distance from the fields, and that way you control
19 everything?
20 MR. BAKER: The application site monitoring pretty
21 much accomplishes that.
22 We surround the field. We know the application
23 rate.
24 DR. BYUS: Couldn't you just set it up somewhere
25 like a field in Davis, a big pesticide application monitoring
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1 facility and apply and monitor constantly?
2 I apologize if I am naive to this, but since the
3 exposure of pesticides is a lot different than a lot of other
4 air pollutants, so this way would work, I believe.
5 DR. SPEAR: The problem is exposure of who or whom,
6 which it is.
7 If the question, originally, what were the kids in
8 the school exposed to, they would be able to deploy strategy
9 to nail that right to the mat. No problem with that.
10 But that is not the question here.
11 The question is what kind of exposure is sustained
12 by the population in agricultural areas around where
13 pesticides are used, and therefore, as I will try to make
14 clear, that the actual exposure to people is extraordinarily
15 variable.
16 You could go out there and take some random
17 samples, and generally speaking, the more sampling costs, the
18 more people believe it is true, and as a consequence, you
19 take a small numbers of samples that cost a lot of money, and
20 you understand the situation, where it is quite easy now to
21 go out and probably even pick another school kid in this same
22 school and monitor their personal exposure, find out if it
23 deviates from that which you estimated from the fixed
24 position monitoring.
25 So, I would summit that the problem that they are
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1 confronted with in a way is that as far as I can tell it
2 really hasn't been nailed about whose exposure we are really
3 talking about.
4 CHAIRMAN FROINES: I want to speak to that.
5 That is a really fundamental issue, because it is
6 interesting that one of the -- in the 80's, when there was
7 significant tension, which is the euphemism I will use,
8 between this Panel and the Department and Food and
9 Agriculture over 1807, was the notion that, in fact, they
10 would argue at that point that 1807 was not relevant to
11 pesticides, because we are really talking about these large
12 areas, like the South Coast Air Quality Basin with, you know,
13 formaldehyde or benzene, or what is in the air, and it was
14 the ambient exposure, ambient exposure that one was concerned
15 with.
16 Well, in fact, that is not true. 1807 doesn't
17 necessarily say it's only the South Coast Air Quality Basin
18 and diesel exhaust. It is interested in the issue of air
19 toxics and public exposure to it.
20 Therefore, yesterday, we spent the whole afternoon
21 talking about air toxics in the context of hot spots, which
22 is a very narrowly defined exposure, which is, in fact, the
23 school.
24 So that within the context of both AB 2588 and
25 1807, the issue is not limited to the broad base ambient
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1 exposure. It includes as well the public exposure associated
2 with, let's call that a hot spot, for lack of a better term.
3 The concern of the Panel then is more broad based.
4 DR. SPEAR: That is perfectly consistent with what
5 I said.
6 I would argue that the ambient monitoring, the kind
7 we have done in the past is really conditioned by thinking
8 about large scale sort of situations in the Los Angeles air
9 basin or whatever, and this inherently is a hot spot issue,
10 and it requires a different approach.
11 CHAIRMAN FROINES: We have been literally, this
12 Panel has been literally asked to address hot spot issues as
13 well as the South Coast basin, so we are within our frame
14 work, so that is why you get the sense, Bob, from the Panel
15 of focusing on not simply allowing itself to be seeing the
16 issue as limited to the South Coast basin.
17 MR. BAKER: Should I move on?
18 I'm glad I selected this slide.
19 DR. GLANTZ: Very stimulating slide.
20 I think we have seen it before actually.
21 MR. BAKER: You may have a year ago. I thought it
22 was worth showing again.
23 CHAIRMAN FROINES: It was at the end of the day,
24 where we were dull.
25 DR. GLANTZ: I remember this one too, actually.
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1 MR. BAKER: You have a good memory.
2 I didn't remember showing this one. Four slides of
3 actual monitoring equipment, just to give you a quick view of
4 that.
5 We talked about methyl parathion yesterday. This
6 was a collocated methyl parathion site situated obviously
7 close to a flooded rice field at the time the methyl
8 parathion being applied to flooded rice.
9 This is was the sampling cup, their XAD resin in
10 both of these sampling cups. Again, we were able to be close
11 to a potential application, the crop or the pesticide might
12 potentially be applied, but we again didn't know for sure
13 that it would be applied here.
14 Similar situation, this is in Fresno County. I
15 believe this was in the lovely town of Tranquility.
16 This was DEF and paraquat sampling near cotton,
17 again close to cotton fields.
18 Here, this was a site in the back of a fire
19 station. So, we didn't feel that we needed the security of a
20 roof, feeling that the back of the fire station should be
21 fairly secure, so we were going to put this on the ground.
22 This is a filter for paraquat and a XAD resin for
23 the DEF. This is a collocated methyl bromide and
24 chloropicrin sampler in Monterey County, again, close to the
25 target crop of the strawberries in the back.
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1 This site is on the roof of a school, sampling here
2 with charcoal tube and XAD resin, and I have a close-up
3 actually of this, without the -- we typically shield these
4 with foil or some device to prevent sunlight from interfering
5 with the sampling media.
6 This shows the foil removed, so you can see XAD
7 resin that was used to trap the chloropicrin and charcoal
8 tubes to trap methyl bromide.
9 This also illustrates the value of the trapping
10 efficiency studies prior to the field work. This trapping
11 efficiency study showed that we needed three charcoal tubes
12 in series to avoid having breakthrough, because the methyl
13 bromide didn't stick real well to the charcoal.
14 That is all of the slides.
15 DR. GLANTZ: For the tubes that you drew the air
16 through, so those are hooked up to the pump?
17 MR. BAKER: Right.
18 Those are hooked up to a pump, correct. So, those
19 are some examples of primary monitoring sites.
20 We also typically have an urban background site.
21 So, if we are doing monitoring in rural Fresno County, we
22 would typically use ARB air quality monitoring site for
23 downtown Fresno as an urban background site.
24 One co-located sample is collected at each of these
25 sites per week for quality assurance purposes.
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1 DR. GLANTZ: What is a co-located sample?
2 MR. BAKER: Duplicate sample, and we discussed DPR
3 can check with the counties and find out the amount of use
4 near the monitoring sites.
5 Next overhead.
6 We have already discussed this. We do five to six
7 weeks of ambient monitoring with 24-hour samples collected
8 each day, four days a week on the weekdays.
9 Next overhead.
10 DR. GLANTZ: Which days do you use?
11 MR. BAKER: Monday through Friday.
12 The staff goes down Monday morning, start sampling,
13 and then 24-hour sample is collected Monday to Tuesday,
14 Tuesday to Wednesday, Wednesday to Thursday, Thursday to
15 Friday.
16 They then return to Sacramento. Then the
17 application site monitoring --
18 DR. GLANTZ: Just one other thing, is there any
19 issue that you might be missing by not getting the weekends?
20 Is that a probable?
21 MR. BAKER: We don't have any reason to believe
22 that.
23 The application site monitoring will -- is
24 irrespective of weekends or weekdays. Once it starts, it's
25 for 72 hours or for three days following an application. So,
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1 we don't stop Friday at 5:00.
2 The ambient monitoring, we don't have any reason to
3 think that there would be more or less application on
4 weekdays versus weekends.
5 DR. GLANTZ: Is that consistent?
6 The DPR, they have to report when they do the
7 applications right?
8 So, people tend to run seven day a week operations
9 or five day a week operations?
10 MR. SEGAWA: Probably a seven day a week operation.
11 DR. GLANTZ: Then it is pretty uniform across days
12 of the week?
13 MR. SEGAWA: Yes.
14 It all depends on pesticide and weather at the
15 time.
16 DR. ATKINSON: You don't lose any information by
17 not doing it night and day?
18 I know it is cooler at nights.
19 MR. BAKER: We have done some 12-hour samples where
20 we get the night and day difference.
21 DR. ATKINSON: See any difference?
22 MR. BAKER: This actually is associated with
23 application site monitoring, and yes, we do.
24 We usually see higher concentrations at night when
25 the air is stable. But for the general population exposure,
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1 the data that is used by the DPR toxicologist, they are
2 interested in on more long-term average, so that the 24-hour
3 data is sufficient.
4 For the acute application site monitoring, we do
5 want that shorter term maximum concentration data, and that
6 is what we have summarized here.
7 We do the application site monitoring by closely
8 coordinating with the agricultural commissioner, product
9 representatives, pest control advisors, applicators, growers,
10 and the key point is we have to obtain permission from the
11 land owner or grower prior to doing our field sampling.
12 The monitoring is done adjacent to an application
13 at or near the highest use of the pesticide per acre, and
14 that is a point that Dr. Froines picked up on earlier about
15 the application site data.
16 Sometimes not all being at the highest label rate
17 per acre, we strive to do that, DPR directs us to do that,
18 but sometimes our field staff works with the ag commissioner
19 office to try and find the application of the type that would
20 produce the highest rate per acre, and sometimes we just are
21 not able to identify any.
22 So, in some cases, we end up doing the monitoring
23 for what we can find, which is documented, but is not always
24 the absolute worst case application rate.
25 This crop may also differ from the crop that is
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1 used for the ambient monitoring.
2 For instance, the almonds around Pond, that was the
3 most heaviest use statewide for azinphos-methyl, but there
4 might be some other minor crop that has a higher use rate per
5 acre, and that would be the crop that we would target for
6 this application site monitor.
7 There we do short term samples, one to two hours,
8 up to 24 hours. They are collected before the application
9 for background purposes, during and for a total of three days
10 following the application.
11 The shorter samples are during -- their sample is
12 collected during the application, and then a few hour samples
13 are collected following the application, and then the second
14 and third day, either 12 or 24 hour samples are collected.
15 Samples are collected on four sides of the field at
16 a distance of 15 to 20 meters from the field edge, and we do
17 collect on-site meteorological data with this application of
18 site monitoring.
19 A collocated sample is also collected at the site
20 that is predominant down wind direction, so we also get some
21 sampling quality assurance information.
22 I have two overheads next, right, Kevin?
23 DR. FRIEDMAN: Do you have problems getting
24 permission from the land owner to do that?
25 MR. BAKER: Sometimes we do.
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1 Sometimes they are very cooperative, and sometimes
2 they say, thank you very much. Why don't you ask someone
3 else.
4 DR. FRIEDMAN: Do you think there is any
5 correlation of permission with degree of exposure or
6 intensity of spraying or anything?
7 MR. BAKER: Almost in every case in our application
8 site monitoring, we have detected the target pesticide.
9 There have been maybe two cases where we didn't,
10 and they were for pesticides that were so non volatile, and
11 there was no wind at the time of the application, that we
12 decided that it just didn't move off the target.
13 DR. GLANTZ: I think Gary is asking a different
14 question.
15 That is, do you think that naughty people are more
16 likely to say no than the nice people in terms of seeking to
17 minimize dosage?
18 MR. BAKER: I don't know that we are able to really
19 say.
20 The ag commissioners usually will give us contacts
21 with people that they think will be cooperative.
22 DR. GLANTZ: Again --
23 DR. FRIEDMAN: The question is, are the cooperative
24 people being more careful spraying less of the material?
25 MR. MONGAR: I'm sorry.
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1 We really have no way of knowing.
2 It is very difficult to answer your question,
3 because we are not there to see what the uncooperative people
4 are up to.
5 DR. GLANTZ: Well, can you, at one level people are
6 going to be bad, they are going to be bad, but have you gone
7 back and looked at the post HAC reports to see if there is at
8 least at that level any systematic differences between the
9 people who will cooperate with you and the people who don't
10 in terms of what they are using or how much they are
11 applying?
12 MR. BAKER: Well, we don't have a control to
13 compare to.
14 So, we don't know if they are being extra careful
15 in their application method, because we are doing the
16 monitoring.
17 I can remember cases where our field staff would
18 tell us about witnessing over spray of the fields. So, I
19 think we have seen cases where they weren't extremely
20 careful.
21 DR. GLANTZ: The question that Gary is asking is,
22 is sort of epidemiological in terms of a response by his
23 question, and I think it would be nice to at least be able to
24 say that the places that you are monitoring are, if at least
25 if you look at the reports they have to file with DPR that
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1 the use of application and amounts of pesticides they are
2 applying and all that in the places you are monitoring, or at
3 least similar to what people are claiming they are doing in
4 the other sites or places that people will not consent to the
5 monitoring, because there is real serious potential for bias
6 here.
7 I don't know what else you can do.
8 MR. MONGAR: We assume that they follow the label
9 guidelines when making the applications, and if they don't
10 follow the guidelines listed on the product label, then
11 that's a problem for the agricultural commissioner's office.
12 That's an enforcement issue.
13 DR. BYUS: That was my question.
14 Do you actually watch them put the chemical and mix
15 it up and go in the airplane and you know what actually is
16 going on at the rate that they are saying it is going?
17 MR. BAKER: No.
18 And that issue has come up.
19 DR. BYUS: If you had our own facility all of this
20 for hot spots, this would be all trivial sorts of
21 information.
22 You spray the maximum amount, more than the maximum
23 amount, less than the maximum amount, you could control for
24 everything.
25 MR. BAKER: Maybe DPR can purchase some land.
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1 DR. BYUS: I don't think it would be that expensive
2 to do this.
3 DR. GLANTZ: The only problem with what you are
4 suggesting, which is an interesting idea, but maybe it leaves
5 aside sort of local meteorological conditions and local,
6 maybe what the ground is made of makes a difference in terms
7 of absorption and what the crop is and what they are spraying
8 it on, so I think that is one thing that would, I mean it
9 sort of defeats the purpose.
10 The good thing about what they are doing is, except
11 for all the problems that we are identifying, it's the real
12 world, sort of.
13 DR. BYUS: You don't know it's the real world.
14 DR. FRIEDMAN: The problem is we don't know if the
15 people who are using extra concentrated solutions are the
16 one's who are denying you permission to monitor there, and
17 that is a serious possible cause of bias where you may be
18 underestimating what is going on in the real world.
19 DR. SPEAR: Let me make two comments.
20 One easy way around this that people in the past
21 have done, you make arrangements with the grower not to
22 monitor what they do, but to actually use their field at the
23 time where they would normally make the application and the
24 application is made by DPR personnel, and that sort of solves
25 the problem because you are actually doing it.
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1 DR. FRIEDMAN: Then you are missing what is
2 happening in the real world.
3 DR. SPEAR: The other thing to keep in mind is that
4 these pesticides are quite expensive, and people are not
5 going to really do a lot of extra application for the most
6 part and doses that depart very much from label
7 recommendations, just because it is a cost issue.
8 So, they are very sensitive, at least in my
9 experience, the agricultural, with what the label
10 recommendation is and not doing much more if they can avoid
11 it.
12 You are quite right. You can't -- again, this
13 whole issue of variations of application raises another
14 variable in this whole moulage that does go to the issue.
15 DR. GLANTZ: That is actually a very good idea.
16 That is something that you guys could do, feasible,
17 say we will apply it for you. That way you are sort of doing
18 what Craig is saying in a real world situation.
19 DR. BYUS: We will pay to spray.
20 DR. SPEAR: We will pay the commercial applicator,
21 someone who is licensed, to spray the chemical for them for
22 free.
23 DR. BYUS: They are going to get a lot more
24 compliance.
25 It is going to be a real world thing. Now,
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1 granted, this doesn't get to the real world.
2 DR. GLANTZ: Naughty.
3 DR. BYUS: But it makes the data a lot more solid.
4 CHAIRMAN FROINES: Let's keep the --
5 DR. FRIEDMAN: You also brought up the cost issue
6 which may be created by us in the opposite direction, and
7 maybe people are using less of it and maybe pay at the
8 standard application will overestimate what is getting into
9 the air.
10 CHAIRMAN FROINES: We need to -- I think these
11 kinds of suggestions have merit.
12 There are probably, if you are dealing with
13 hundreds of pesticides on a continuing basis, there are
14 obvious cost issues.
15 DR. BLANC: They are only doing five a year.
16 CHAIRMAN FROINES: No, but I'm talking about the
17 overall problem.
18 DPR is a regulatory agency. I doubt very seriously
19 if they want to get into the business of being pesticide
20 applicators.
21 Well, anyway, let's keep it as an option, but it
22 still seems to be that our goal is in part to define
23 protocol that maximize our information, and that is one
24 option, but I think perhaps there are other options with
25 different looks of practicality.
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1 MR. SEGAWA: In response to Dr. Byus' question, I
2 think it is definitely possible.
3 My concern, of course, would be the cost. Some of
4 these pesticides are rather expensive, and my guess is there
5 would be several thousand dollars for each application.
6 DR. BYUS: What is the big picture here?
7 DR. BLANC: It has got to be trivial compared to
8 the staff time.
9 I am sure it must cost $100,000 each time you
10 analyze one of these. Maybe its more, maybe 2 or $300,000.
11 MR. SEGAWA: Yes, except that DPR has budgeted its
12 staff to work on 1807, have not budgeted it from pesticide
13 applications.
14 DR. BYUS: You could.
15 MR. BAKER: I know in the case of metam-sodium, the
16 sprinkler application that monitoring was done around by DPR
17 you actually paid for the application but that was over and
18 above 1807.
19 DR. GLANTZ: I don't want to belabor this because
20 we do need to get on, but I think this a reasonable thing
21 that you guys ought to seriously look into, because I think
22 the point that Paul made is almost certainly true that the
23 data collection costs plus the costs associated with all of
24 the work that follows from the data that drags on for years,
25 if the cost of applying this to a field is few thousand
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1 dollars, that is a small amount of money, and it may be that
2 you ought to be going in to develop your budgets and planning
3 to do this as part of your sampling cost.
4 CHAIRMAN FROINES: Everyone is making this so it is
5 an easy thing and maybe an easy thing to do in terms of doing
6 it, but this is not something you do without legislation and
7 regulation.
8 You cannot tell farmers we are going to use your
9 field when we choose to, to apply pesticides. My point is
10 that this is potentially a litigated complicated regulatory
11 issue.
12 It is not something -- it is simply not a voluntary
13 question that DPR says we have the money we are going sample
14 pesticides in a field that we.
15 DR. GLANTZ: No, no, no.
16 That is not what anybody is suggesting. I think
17 what people are suggesting, but that is another approach I
18 suppose you can take, but I think at least my understanding
19 of what is on the table is the idea that you would go to a
20 farmer who, the local ag commissioner says, well, this guy is
21 probably going to use pesticide X, and you would go to him
22 and say, okay, we will go do it for you, you are planning to
23 use pesticide X, we will do it for you, we will pay for it,
24 if you let us do this sampling at the time that we are
25 spraying it.
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1 It isn't where you are compelling them to do it. I
2 think then that gives you much better control over what is
3 going on. It gives you much more reliable data.
4 It is not where you would go in and say, we picked
5 your field, and we are going to do this whether you like it
6 or not.
7 It would be a thing where you would offer to them
8 and say, look we will do the spraying, and we will pay for
9 the pesticide to collect the data and bet you would get a
10 much broader cooperation then because they are getting
11 something out of it other than worrying that they are going
12 to get fingered by some regulatory agency for letting you
13 come in and make the measurements.
14 So, we are not talking about anything where people
15 are compelled to do anything. It would be an offer.
16 CHAIRMAN FROINES: This discussion is an academic
17 approach.
18 This is the researcher that wants to study the
19 problem. This is not regulatory policy for a state agency,
20 and let me just finish, Stan.
21 I think the point that we have to be careful about
22 here, we are trying to define a broad based approach to
23 monitoring for public health protection from pesticides. The
24 way that you describe it is much too ad hoc.
25 It is sort of like going around and saying let's do
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1 it this way. That's fine. I think we should do things like
2 that.
3 But I still think that we need to define the broad
4 approach which ARB develops a protocol for sampling
5 irrespective getting volunteer information.
6 DR. GLANTZ: I agree with that except for that the
7 current approaches are voluntary.
8 There are two issues here that I see. One of them
9 is that the issue that we talked about before the ambient
10 monitoring, and I think that is a real serious problem if you
11 are out taking ambient data and you don't know whether the
12 stuff is actually being applied or not, and then the second
13 thing, when you are doing the hot spot monitoring, I think
14 that the kind of things that we are talking about here are
15 things that could be realistically done.
16 The only difference which they are doing now, what
17 we are talking about is that they would actually do the
18 application for the grower so they would know precisely what
19 is going on.
20 We are going through this whole process in
21 developing these reports and coming up with recommendations
22 in terms of public health stuff where the basic exposure data
23 may be wrong. That is pretty discouraging.
24 I think that the broad public health issues are
25 related to the problem with the ambient monitoring which are
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1 serious, but in terms of hot spot monitoring, this might be a
2 way to improve the data quality.
3 So, I don't think it is just an academic issue. It
4 is just a minor adjustment to what they are doing.
5 Do you see what I am saying?
6 CHAIRMAN FROINES: I see it as an academic way of
7 looking at things.
8 DR. GLANTZ: Well, but I'm a professor.
9 CHAIRMAN FROINES: Keep in mind, as far as I know
10 there is no regulatory agency, whether occupational health,
11 environmental protection, clean drinking water, where the
12 regulatory agency goes to the regulated party and says, we
13 are going to do the sampling in your factory, or your field,
14 or your waterway or whatever for you, and then based on that
15 data that we collect, we are going to regulate you.
16 There are obviously some limitations to how one can
17 do that, but that is what we are saying. The industry will
18 be impacted by the regulating agency collecting data in the
19 regulated field, and so the effected party is bound to be
20 somewhat concerned about whether or not they are going to ask
21 the reverse question, is he not going to worry about money
22 and use a much higher concentration to get a much greater
23 worst case situation, and therefore, he comes back and DPR
24 regulates the devil out of this particular pesticide based on
25 DPR's monitoring.
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1 You've got a conflict of interest issue.
2 DR. ATKINSON: Do you only do the application
3 monitoring site once?
4 MR. BAKER: We are going to propose more than once.
5 DR. ATKINSON: I guess you could end up with a fair
6 amount of variation depending upon meteorological conditions.
7 MR. BAKER: Yes.
8 CHAIRMAN FROINES: Let's move on.
9 MR. BAKER: Okay.
10 Next overhead, Kevin.
11 DR. GLANTZ: Just for the record, I was the warm
12 fuzzy guy yesterday, and John was mean, but today he is being
13 warm and fuzzy, and I am being mean.
14 I was instructed to be mean, because he wants to be
15 warm and fuzzy.
16 MR. BAKER: I have two overheads.
17 DR. GLANTZ: For the record, that was a joke.
18 MR. BAKER: I have two overheads to show examples
19 of our application site monitoring.
20 This was a 40-acre field, a 40-acre peach orchard
21 actually, where we did monitoring for diazinon, applied as a
22 dormant spray in January with no leaves on the trees.
23 These X's are the locations of the monitoring sites
24 showing again that they are in the roughly 20 yards from the
25 edge of field. This is co-located site in the predominant
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1 down wind direction, the northwesterly winds.
2 This also shows what we show not only and this is a
3 diagram out of one of our reports to DPR. This also shows
4 what was on the adjacent fields. This is the grassy area,
5 alfalfa, two foot high trees, new orchard, and just the dirt
6 to the bare field to the south here.
7 Next slide, please.
8 That was fairly ideal condition. This next
9 overhead is less ideal, and I wanted to contrast the two.
10 Often we will have, this was an application of
11 chlorphyrifos to an orange grove. Often there will be plots
12 or blocks as referred to here of land.
13 Here it was a 40-acre block, and then a 20-acre
14 block to the north, both received applications of
15 chlorpyrifos on two consecutive days, so that complicates our
16 sampling, because we are set up here to the southeast and
17 north of the 60-acre plot.
18 A couple of complicating factors. One, the fact
19 that the application occurred on two consecutive days. So,
20 what we were measuring in our off-site locations were, it
21 cannot be totally assigned to one day's application because
22 there is a carryover.
23 Another complicating factor is that these sites
24 here to the north and to the east are between orange groves.
25 So, the microscale meteorological impacts of air passing over
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1 the canopy from one orange grove into the next complicates
2 the air flow.
3 The ideal is to have an orchard with just bare soil
4 or all the way around put our samplers on the four sides and
5 not have any complicating factors, but it is tough to find an
6 orchard like that without something around it.
7 The other interesting note is that we had samplers
8 on three sides. We started out with a sampler here on the
9 west side, because we always ring the fields with four
10 samplers, but midway through the study, someone else decided
11 that they needed our sampler more then we did, and we only
12 got data from three of the samplers, but that has been very
13 rare.
14 We have been very fortunate in not having samplers
15 stolen.
16 Next overhead.
17 Finally, then we wrap all this information up to
18 report to DPR.
19 That summarizes the sampling analysis methods, the
20 results of both types of monitoring and also the quality
21 assurance results from the lab and the field.
22 Next overhead.
23 I quickly I will run through the status of our
24 monitoring to date. To date DPR has requested monitoring for
25 48 pesticides. They have given us monitoring recommendations
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1 for 42.
2 The difference there of six. Just about two months
3 ago, they gave us the request for six more pesticides for
4 next year, and so those monitoring recommendations will be
5 following.
6 To date, ARB has finalized reports for 35 different
7 pesticides. We have actually done monitoring for more than
8 that, so several of these pesticides we have done monitoring
9 multiple times, but we have done reports on 35 different
10 pesticides.
11 There are six reports in preparation. Monitoring
12 is just being completed for our last pesticide of 1999
13 cycloate, down in Imperial County, and we have monitoring for
14 nine pesticides scheduled for 2000-2001.
15 Next overhead.
16 CHAIRMAN FROINES: Can I ask you a question?
17 You said that you sometimes have multiple samples.
18 Case in point, I said this yesterday, but I want to say it
19 again, in 1991, 1,108 pounds of Telone was used in
20 California.
21 In the first six months of 1995, 409,820 pounds
22 were used. I suspected that there is a lot more being used
23 even now.
24 So, my question is, since we knew there was a
25 problem in 1990 that actually led to suspension of Telone
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1 used, do we know that that problem exists today?
2 In other words, have you been asked to do
3 monitoring over time to characterize what is in this case an
4 obvious problem, and have you done application site
5 monitoring to characterize whether or not they are hot spots?
6 MR. BAKER: We have done the monitoring most
7 recently in, I believe, July of 1996, for Telone in Kern
8 County, but we recently did discuss with DPR that we believe
9 that DPR may consider requesting us to go back and do
10 additional monitoring for Telone, because of the increase
11 used.
12 We have not done application site monitoring for
13 Telone other than the joint studies between ARB and Dow back
14 in the early 90's that were part of Dow Elanco's efforts to
15 bring Telone back under the California market.
16 CHAIRMAN FROINES: I would argue that with Telone
17 that application site monitoring should be a priority.
18 MR. BAKER: I would think if we were asked to do
19 additional ambient monitoring, we would do application site
20 monitoring as well.
21 CHAIRMAN FROINES: Especially given the change in
22 methyl bromide.
23 This whole permethrin issue is actually quite
24 complicated. It is almost that we are thinking about how do
25 we look at the permethrin issue, because it is changing so
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1 fast.
2 MR. BAKER: It really is with the dramatic increase
3 and use of metam-sodium in 1990, since Telone was suspended
4 and the phase out over the next few years of methyl bromide.
5 DR. GLANTZ: What is DPR planning to do in response
6 to the issues that are just being discussed?
7 MR. SEGAWA: Specifically, about Telone?
8 DR. GLANTZ: Well, in methyl bromide and
9 metam-sodium, I mean are you planning to alter your
10 monitoring plan?
11 In the past it has been like usually you go out and
12 look at something once. I mean are you planning on tracking
13 these things and going at and taking additional data to see
14 how the exposures are changing over time?
15 MR. SEGAWA: For the chemical, it is definitely
16 under serious consideration.
17 Lynn had pointed out that we have actually
18 requested 48 chemicals but have only sent over 42
19 recommendations, and normally we would have sent over the
20 recommendations for year the 2000 monitoring.
21 One of the reasons for the delays, we are now
22 considering changing the chemicals that we want monitored,
23 including some of the fumigants.
24 MR. BAKER: Next overhead.
25 This is an overhead just very quickly of the
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1 pesticides that we have monitored to date. Metam-sodium is
2 listed up there just because it is the parent for MITC, but
3 we have not done air monitoring for metam-sodium, just for
4 MITC, and its breakdown product, methyl isocyanate.
5 So, there is 41 up there on the list, we have done
6 monitoring for to date.
7 DR. GLANTZ: So, DPR has reports on all these?
8 MR. BAKER: They have reports on 35.
9 There are six that are in preparation, actually it
10 will be seven.
11 One is just being completed.
12 CHAIRMAN FROINES: The key to this entire
13 discussion is focused on the fact that we have a very nice
14 list, but the question is when you look inside the list what
15 do we really know.
16 Do we have application monitoring and ambient
17 monitoring for all of these compounds, and we could raise a
18 series of questions that we have discussed and there is no
19 sense of going back over them, but the question is, to what
20 degree do we have sufficient information for decision making
21 purposes?
22 MR. BAKER: Seems to me that the key question is,
23 is the data adequately representative of public exposure?
24 Now, Randy is going to discuss a little bit more on
25 DPR's evaluation of our reports.
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1 CHAIRMAN FROINES: This is for Randy, how long do
2 you think you are going to be?
3 MR. SEGAWA: I will only be talking about two
4 minutes, but it may generate a number of questions.
5 DR. BYUS: Brief question, Randy, about the use
6 data, that is analogous to this in the drug industry, in
7 terms of the amount of drugs that people use and listing the
8 amount of drugs that pharmacies prescribe and the amount of
9 drug that is actually manufactured, it doesn't always add up,
10 so my question to you is, now it is a question for the
11 pesticides, if you have all this use data but do you monitor
12 the amount, say, of the pesticides that are brought into the
13 State of California and sold, and does that actually add up
14 with the use data, is my question?
15 MR. SEGAWA: DPR does have information regarding
16 sales of pesticides in the state.
17 We are currently running an analysis comparing that
18 sales data to our pesticide use data and seeing how well they
19 match up.
20 One of the problems that we have most pesticides
21 have non agricultural applications, so we don't get pesticide
22 use reports for all chemicals, and so for many of the
23 chemicals, it is impossible to match up because the use is
24 not required to be reported.
25 DR. BYUS: Some of this is going to add up.
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1 Granted, if people store the stuff and you make the
2 estimates, but if it's grossly out of kilter --
3 MR. SEGAWA: We are doing that analysis now.
4 CHAIRMAN FROINES: I just want to make one comment
5 before we break.
6 I hope that everybody appreciates why there is such
7 sensitivity to the issue of having a requirement that we use
8 monitoring data before we determine a particular chemical a
9 toxic air contaminant, that we are trapped at some level in
10 the quality of the exposure and monitoring data.
11 We can take a highly toxic chemical, and we could
12 not declare it a toxic air contaminant without adequate
13 monitoring data. It's so different than what we do with ARB.
14 I would still argue that we shouldn't, it still
15 raises a question of whether or not the designation of a
16 compound of a toxic air contaminant should be based solely on
17 this kind of requirement. So, let's leave it, but you see
18 why this is such a troubling issue.
19 So, let's take a break.
20 (Thereupon a brief recess was taken.)
21 CHAIRMAN FROINES: Okay. Go ahead.
22 MR. SEGAWA: As Lynn mentioned previously, ARB has
23 sent to DPR 35 monitoring reports, and the next couple of
24 overheads here will list the status of those 35 reports.
25 Similarly, chemicals are currently toxic air
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1 contaminants, and you see the list of seven chemicals there.
2 One chemical has been cancelled by DPR. That is
3 monocrotophos. One is currently proposed as a toxic air
4 contaminant, DEF. Seven reports are in preparation for
5 review by DPR.
6 Next slide.
7 Then we have 18 chemicals sort of in line waiting
8 for our evaluation by DPR staff, and one chemical for which
9 we requested additional monitoring, that is benomyl.
10 DR. BLANC: I found this very confusing.
11 It was in your handout. Everything on this list,
12 is this list and the previous list completely a subset of the
13 pesticides monitored to date list?
14 MR. SEGAWA: Well, there are 41 pesticides
15 monitored to date, but ARB has sent us 35 reports.
16 So, these two slides show the status of those 35.
17 DR. BLANC: 18 and 35 would mean 53.
18 MR. SEGAWA: 19 on this slide and the previous
19 slide at 16.
20 DR. BLANC: Well, again, maybe I don't understand
21 the terminology, in the que --
22 DR. GLANTZ: What does it mean that it is in the
23 que?
24 MR. SEGAWA: That means the monitoring has been
25 completed, but we don't have staff assigned to all parts of
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1 the health effects document.
2 DR. BLANC: But DPR, you have received the report
3 from the ARB for 35 reports?
4 MR. SEGAWA: Right.
5 We have the monitoring data but, for instance,
6 parts of the risk characterization or the exposure assessment
7 is not yet done.
8 DR. BLANC: Okay. So, none of this refers to
9 anything else that you are expecting from the ARB except for
10 the one thing that you have asked for additional monitoring
11 for?
12 MR. SEGAWA: Correct, and that the six reports that
13 they are currently working on.
14 DR. BLANC: Right, which are things that are not
15 even in the que yet?
16 MR. SEGAWA: That's correct.
17 DR. BLANC: But will be in the que?
18 MR. BAKER: Once we finalize them.
19 MR. SEGAWA: Correct.
20 DR. BLANC: So, could you go back to the previous
21 slide then?
22 There are seven toxic air contaminants that are
23 already put to bed. There is one that you canceled because
24 it is not made anymore, or something.
25 There is one that has been proposed to us to
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1 finalize that really would move up into the top list now,
2 right?
3 MR. SEGAWA: Yes.
4 We have regulation currently as proposed to add it
5 to the toxic air contaminant list but it is not yet official.
6 DR. BLANC: Right, but it is basically, we have
7 done our part, and we just finished our part for methyl
8 parathion.
9 MR. SEGAWA: Correct.
10 DR. BLANC: So, therefore, of the seven reports
11 that are in preparation or review, that means they are not
12 done, but they are farther along than things that are in que;
13 is that the difference?
14 MR. SEGAWA: Correct.
15 All three sections of the health effects document
16 and then environmental fate section, exposure assessment and
17 the risk assessment section are all in active preparation
18 right now.
19 DR. BLANC: Well, some of them are more than in
20 active preparation, right?
21 MR. SEGAWA: Correct.
22 DR. BLANC: So, the one's that we have already
23 gotten drafts of here, it's molinate and MITC, have we gotten
24 a draft?
25 MR. SEGAWA: The leads have the MITC.
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1 DR. BLANC: So, what else does the leads have or
2 not have yet?
3 MR. SEGAWA: That's it, MITC and molinate.
4 DR. BLANC: And methyl parathion.
5 MR. SEGAWA: Yes.
6 DR. BLANC: So, there are four things that the lead
7 people have been assigned but don't have the documents or
8 nobody has been assigned yet, John?
9 CHAIRMAN FROINES: What is what?
10 Azinphos methyl, chlorothalonil, endosulfan and
11 naled?
12 DR. BLANC: So, in fact, any discussion that we
13 would have, our next discussion after you is going to be on
14 how priorities are set, and that would be in terms of how
15 priorities are set for things for which the Air Resources
16 Board has already done the air monitoring for?
17 MR. SEGAWA: In part, yes.
18 DR. BLANC: Or would it be a discussion of how
19 priorities are set for things beyond the 18 chemical list?
20 MR. SEGAWA: Both.
21 DR. BLANC: Can you tell us, of the six things that
22 you sent requests, you said that there are six things that
23 have been, you have gotten requests for monitoring, that you
24 have planned out for the next two years, what are those six
25 things?
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1 MR. BAKER: I don't have a table of that, but I
2 could list them for you. They are, carbaryl, dimethoate,
3 maneb, phosmet, tralomethirn and benomyl.
4 DR. BLANC: So, none of those are Telone?
5 MR. BAKER: No, but as Randy mentioned earlier, one
6 of the reasons they have not sent us monitoring
7 recommendations yet is that they are reconsidering those
8 requests.
9 DR. BLANC: Those six, you mean they may change
10 those?
11 MR. BAKER: Correct.
12 CHAIRMAN FROINES: What was the last?
13 MR. BAKER: Tralomethirn, T-r-a-l-o-m-e-t-h-r-i-n.
14 CHAIRMAN FROINES: T-r-a-l-o-m-e-t-h-r-i-n.
15 DR. BLANC: What about bifenthrin that we got the
16 handout on?
17 MR. BAKER: We have done the monitoring on it
18 already.
19 DR. BLANC: Okay. So, let's say I wanted to
20 potentially review a substance as an air contaminant,
21 pesticide, that wasn't yet one of the 18 chemicals in que,
22 for which there has already been monitoring done, and it
23 wasn't one of the six that you mentioned, does that mean that
24 earliest sampling could be three years from now, and
25 therefore, it would be five years from now before we would
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1 have a document?
2 MR. BAKER: No, there are, let me reiterate, we
3 have done monitoring for 41, or I think it is 42.
4 We have finalized reports for 35. Of the remaining
5 seven, one is the monitoring is just ending, the other six
6 the reports are under preparation.
7 So, there will be, over the next several months,
8 there will be seven more reports going in from ARB to DPR.
9 Then for those other six pesticides or replacements for those
10 that DPR has requested monitoring for us, that will be done
11 either in 2000 or 2001, with either a report to follow
12 probably the following year.
13 DR. BLANC: That is how I came up with three years
14 of the stuff that is in the pipeline.
15 Therefore, if there was something that is not in
16 the pipeline yet, wouldn't it be more like five years before?
17 MR. BAKER: Well, you mean if they were to next
18 month substitute a request for Telone instead of the phosmet?
19 DR. BLANC: Then it would only be three years.
20 MR. BAKER: Possibly two, two to three.
21 DR. BLANC: Why would you consider things in que
22 for which -- there are other things that are sort of in the
23 second que for which ARB is preparing the reports for you, or
24 are those in the 18?
25 MR. BAKER: Those 18 are just compounds that we
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1 have finalized reports.
2 DR. BLANC: So, what are the one's that the reports
3 are pending for?
4 MR. SEGAWA: Amitraz, atrazine, bifenthrin,
5 propargite, cycloate, diquat dibromide, and there is a
6 seventh, oh, simazine.
7 DR. BLANC: So, let's say I was to go back to the
8 1996 document.
9 MR. BAKER: The prioritization document.
10 DR. BLANC: Prioritization document where
11 propargite is number one.
12 So, propargite, which is number one on that list,
13 is actually not even appearing on the radar screen as being
14 in que?
15 MR. BAKER: It is actually somewhat unique.
16 We did monitoring for it in 1996, gave DPR a report
17 in 1998, but we and DPR agreed that the report was not
18 adequate. There was a problem with the analysis method and
19 sort of fluctuating limit of quantifications. So, we redid
20 that monitoring the past couple of months.
21 DR. BLANC: Okay. What was the next one on your
22 list?
23 CHAIRMAN FROINES: Can I ask a question, Paul?
24 Do you have an application site report
25 for propargite?
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1 MR. BAKER: We do, and that was finalized and sent
2 to DPR last year.
3 DR. BLANC: So, actually is has been held up
4 because of some school or fire house or some place where you
5 had the levels?
6 MR. BAKER: Well, we again did the application site
7 monitoring -- hold on a second. I have a summary.
8 All the data -- no. I take that back.
9 We got measurable results from the application site
10 monitoring for propargite. So there is nothing wrong with
11 that data.
12 We did repeat it this year, but the problem was
13 with the ambient monitoring for propargite, but we chose to
14 repeat both studies.
15 DR. GLANTZ: When will those be available?
16 MR. BAKER: Probably spring or summer of next year.
17 Is that a fair guess, Kevin?
18 MR. MONGAR: Yes, that is correct.
19 DR. GLANTZ: So, if we were to say we would truly
20 like to see a report on that, it could conceivably be before
21 the Panel by the fall, like a year from now?
22 MR. BAKER: That would be at the early spring or
23 more likely summer, us giving DPR a final report on --
24 DR. GLANTZ: Right, but they could be doing the
25 health effects part while you are finishing your monitoring
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1 study.
2 MR. BAKER: I don't know how long that takes DPR to
3 put all that together.
4 MR. SEGAWA: I'm not sure what the stats on risk
5 assessment for propargite is.
6 DR. BLANC: Okay. What about something like
7 simazine?
8 MR. BAKER: Simazine was actually withdrawn.
9 DR. BLANC: So, it fell off the map.
10 CHAIRMAN FROINES: What about chlorothalonil?
11 DR. BLANC: Chlorothalonil.
12 MR. SEGAWA: It is all done, and it is one of the
13 next few that will be coming up shortly.
14 DR. BLANC: That is in preparation.
15 CHAIRMAN FROINES: Oh. I'm sorry. You are right.
16 DR. BLANC: I am sorry to make you go over this
17 again, but the one's that you are preparing that you have
18 done the sampling for already and you are preparing the
19 reports but they haven't formally gone to DPR, could you list
20 those again, those seven?
21 MR. BAKER: Yes.
22 There are seven and they are, amitraz, bifenthrin,
23 diquat dibromide, cycloate, propargite, simazine and
24 atrazine.
25 DR. BLANC: So, we should remember those and ask
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1 when we talk about the priority setting, we should get a
2 sense as to where those would fall, because they are not in
3 the que yet.
4 MR. SEGAWA: Yes, we will discuss those more when
5 we discuss the prioritization.
6 CHAIRMAN FROINES: Any other questions?
7 MR. BAKER: Next overhead.
8 We could have remembered all these on this next
9 overhead if I had been thinking of it.
10 This is an update of our monitoring this past year.
11 This lists the six pesticides that we did monitoring ambient
12 and application site application for, and then in addition of
13 these six, the seventh report that will soon be completed is
14 simazine, which was monitoring done late last year.
15 These, just quickly to run through these, amitraz
16 an insecticide used on cotton in Kings and Fresno County,
17 atrazine a herbicide used on sudangrass in Sacramento County,
18 bifenthrin an insecticide used on cotton in Kings and Fresno
19 County, cycloate that we are just completing monitoring for
20 an herbicide used for sugar beets, used on vegetation in
21 sugar beets in Imperial County, diquat dibromide a desiccant
22 used for alfalfa seed in Kings County, and propargite an
23 insecticide used on cotton and grapes in Kings and Fresno
24 County.
25 As we move on here, I would like to point out that
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1 there are three that are listed for Kings and Fresno County,
2 amitraz, bifenthrin, and propargite, and this presented a
3 rare opportunity for us this year to actually do monitoring
4 for three pesticides simultaneously at some of the sites.
5 If I could have the next overhead. I will now go
6 through a few overheads of the pesticide use maps that have
7 been so helpful to us that DPR provides, and we won't get
8 into a lot of specifics on these, but they give us, they can
9 illustrate a couple of different things.
10 This is the use map that DPR provided for the use
11 of amitraz in Fresno and Kings County during 1994, during the
12 period of July through August of 1994.
13 You can see scattered use here in Fresno County and
14 then a little more concentrated used down in Kings County
15 around Hanford.
16 If we could look at the next slide, for the 1997
17 use, you see the pattern has changed a fair amount in a three
18 year period there is not nearly as much used in around
19 Hanford and it has spread up to the valley more.
20 So, this illustrates both the change in the use
21 pattern for this particular pesticide but also that the
22 complication that we would be under if we using outdated use
23 information to pick our monitoring sites.
24 If we had used 1994 data, we would have done all
25 the monitoring down here and would have missed locations up
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1 here in the valley.
2 Kevin, why don't you put up that overlay. We have
3 another slide here that we will use for a couple of these
4 that overlays that shows our actual monitoring locations in
5 this area.
6 As I mentioned a minute ago, we did monitoring at
7 some of the sites for amitraz, bifenthrin and propargite.
8 So, Fresno again, was our urban background site for this
9 monitoring.
10 We had amitraz monitors at the locations here with
11 the A, Huron, five points, Lemoore and Stratford and you can
12 see in general these sites are in the areas of historical for
13 amitraz.
14 Why don't you pull that off, and we will move on to
15 bifenthrin.
16 CHAIRMAN FROINES: Is there another name for
17 bifenthrin?
18 MR. BAKER: Is there another name for bifenthrin?
19 MR. SEGAWA: There is but it doesn't come to me at
20 the moment.
21 CHAIRMAN FROINES: I don't find it on the priority
22 list for '96.
23 MR. SEGAWA: Oh, bifenthrin is a recently
24 registered active ingredient.
25 CHAIRMAN FROINES: Okay.
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1 MR. BAKER: The bifenthrin and the propargite we
2 were actually able to monitor simultaneously the same
3 sampling media.
4 The amitraz used a different sampling media, but we
5 were able to use the same sites in some cases for all three.
6 This is the 1994 use pattern for bifenthrin. It is
7 pretty uniform throughout the western part of Fresno County
8 and down here in Kings County.
9 Now, the 1997 use, you will see a change in that
10 pattern. Instead of pretty uniformly distributed throughout
11 there, just a little bit of use in the western Fresno County
12 and scattered use down in Kings County.
13 Now, why don't you overlay again the monitoring
14 sites for bifenthrin. Some of these, again, are picked as
15 primarily bifenthrin sites. Some were primarily for
16 propargite sites.
17 For instance, the Kerman station here, there is no
18 historical use by bifenthrin there, but we were able to get
19 both the alunites off of the same sampling cartridge, so we
20 used that primarily for propargite.
21 We had these two sites in San Joaquin in the heart
22 of the historical bifenthrin use area, Stratford and Huron,
23 also in that same region, and then Kingsburg is another site
24 that is more of a propargite site.
25 DR. BLANC: Could I see the previous map just for a
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1 second?
2 MR. BAKER: The '94, '94 for bifenthrin.
3 The kind of pink is the '94 bifenthrin use and the
4 tannish or whatever color that is, is the '97.
5 Anything else on that?
6 CHAIRMAN FROINES: I still don't understand why
7 bifenthrin is not in the '96 documents?
8 That is 1994.
9 MR. SEGAWA: I'm lost myself.
10 I don't know.
11 DR. BLANC: Seemed like it didn't work very well, I
12 mean it is not very popular.
13 It lost popularity.
14 MR. SEGAWA: Bifenthrin is a propylene type
15 chemical, and one of the problems with propylene chemicals is
16 that insects get resistance to that very rapidly.
17 DR. BLANC: So, just in terms of our upcoming
18 discussion here is a chemical which doesn't appear at all on
19 the list of priorities as, is a propylene which probably
20 wouldn't be my choice for high priority to study, because it
21 is not particularly that potent, had a brief popularity of
22 use which is now sort of collapsing, but took up 20 percent
23 of what the ARB could do in terms of sampling.
24 I mean, it was one of the five things you could
25 sample.
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1 MR. BAKER: There are actually two on our
2 2000-2001 list, tralomethirn and methamidophos, which is a
3 carry over from last year that are also not listed in the '96
4 document.
5 So, I am assuming there has been new information
6 that DPR has come upon since that document was prepared that
7 has caused those to become priorities. I assume the case is
8 similar for bifethrin.
9 MR. SEGAWA: We will talk more about that in depth
10 when we get to prioritization discussion.
11 MR. BAKER: Okay. Let's just wrap up with the
12 propargite overheads and then we will move on.
13 Prior to amitraz and bifenthrin, we noted a fair
14 change in the use pattern from '94 to '97, and here that is
15 not the case, '94 received pretty uniform use throughout
16 Fresno and more eastern in Kings County.
17 Propargite used some on cotton but slightly more
18 heavily on grapes, and this is the grape growing region.
19 Now, '97, and you see the use pattern has not really changed
20 significantly. It's still that grape growing region.
21 If you recall, there were a couple of sites, Kevin,
22 do you want to put the overhead back again, that we used for
23 bifenthrin and propargite, that were not big.
24 In fact, there was no historical use for
25 bifenthrin. They were coming in Kingsburg, but you can see
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1 that they are in the use area for propargite as well as for
2 others and to lesser extent by Helm and Stratford.
3 So, if there are no further questions, that
4 concludes what I was planning to present.
5 We could move on to Randy's presentation on the
6 modifications that are being considered.
7 MR. SEGAWA: Go ahead, next slide, Kevin.
8 DPR and ARB staff have had a couple of meetings now
9 to discuss possible options for revising the current
10 monitoring. This summarizes those discussions.
11 All of these options will give us more data for
12 each chemical, but then the sacrifices that we will be doing
13 fewer chemicals for or less frequent monitoring for each
14 chemical.
15 Currently ARB collects about 120 ambient samples
16 for each chemical at 40 application site samples. Now we
17 currently monitor 5 to 6 chemicals per year.
18 Some of the options we are discussing is monitoring
19 an additional season, we currently do that of course for one
20 year. We could do that over two or three years.
21 We could also monitor additional areas. Right now
22 we target the highest or second highest county of use, and we
23 could spread that out more.
24 We could also monitor additional sites. We
25 normally monitor 3 to 5 sites of each chemical. We could
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1 monitor for a longer period of time, as Lynn said.
2 We currently monitor for about six weeks, or we
3 could monitor additional applications. Currently we do one.
4 As you know, we have not yet monitored for TAC.
5 We would like to begin including those into our monitoring
6 scheme as well.
7 Another option would be and go back for those 18
8 chemicals in cue and gather additional monitoring data for
9 those.
10 Another idea we have been considering is
11 supplementing the monitoring data with some computer modeling
12 information. We are looking for suggestions and
13 recommendation from the Panel here.
14 One question we had, was if it is important to
15 distinguish between particulate phase and vapor phase for
16 these pesticides.
17 DR. BLANC: Why was that a question?
18 MR. SEGAWA: That question has came up in other
19 monitoring that we have been doing where people are
20 interested in the partitioning between the particulate phase
21 and vapor phase.
22 Unfortunately, at this point the sampling
23 analytical methodology is not well worked out, so we can't
24 get a good distinction between the two phases.
25 So up until now, we haven't tried to make that
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1 distinction.
2 DR. ATKINSON: That would be important for
3 environmental fate because two phases could be quite
4 different.
5 MR. BAKER: Right.
6 We have had some discussions I know with DPR's
7 toxicologist, and they might care to comment, but it didn't
8 sound like that they would do much with the data if it was
9 particulate versus gaseous phase.
10 It's not like they would do the same. They would
11 treat the data the same way. So from a toxic end point
12 perspective, we want to be certain that there was a real need
13 for separating the two types of information.
14 CHAIRMAN FROINES: It depends also on your
15 sampling.
16 If you are not picking up particulate because you
17 are doing, let's say, charcoal tube sampling, or if you are
18 picking up both, then of course, that is an issue.
19 DR. MAJEWSKI: The chances are you are picking up
20 both you are just not getting a high efficiency for the
21 particulates.
22 CHAIRMAN FROINES: The question of how much of the
23 organic gets particle associated?
24 MR. BAKER: Even if we were able to measure with a
25 filter upstream of the absorbent resin and trap the
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1 particulate from fraction and the gaseous fractions some of
2 the pesticide that would be absorbed to the particle that
3 would be trapped on a filter, then also the pesticide would
4 be stripped off of that particle from the filter during the
5 sampling, so we wouldn't necessarily be able to accurately
6 characterize what was occurring in the ambient air.
7 DR. ATKINSON: Yeah, it wouldn't necessarily be
8 particularly accurate, yet some knowledge.
9 CHAIRMAN FROINES: My suggestion on that list of
10 yours, is that it would be best to actually wait on any
11 discussion of it until after our guest speakers have
12 contributed and then go back to it following their
13 recommendations.
14 MR. SEGAWA: That is about all I had.
15 The other slide was just our current thoughts that
16 we had monitored, continued to monitor for 5 to 6 chemicals
17 each year but monitoring for two years rather than one, that
18 those chemicals would include 2 to 3 toxic air contaminants,
19 ARB would give us the data from the first season which we
20 would then look and help plan for the second season of
21 monitoring whether we want to monitor in a different area or
22 monitor a second application or increase the number of weeks
23 that we monitor.
24 CHAIRMAN FROINES: One of the questions obviously,
25 is why do you monitor what is the purpose in the long-term,
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1 and going back to Craig and Stan's arguments about sampling
2 in the field and just putting pesticide on it and calculating
3 the data, if one of questions for this Panel is, is if one of
4 the issues is a chemical to be designated a toxic air
5 contaminant as opposed to having a broad based picture of the
6 pesticide exposure, those may have different, one may be done
7 more quickly than the other depending on what your ultimate
8 end point goal is.
9 DR. BLANC: To expand on that thought, it might be
10 in fact, I realize we are going to embark on a discussion
11 about priority setting for labeling, what should be
12 considered to be labeled a toxic air contaminant from
13 pesticides, but maybe the question is the reverse, which is
14 maybe what we need is just the minimum amount of information
15 so that we can designate many of these pesticides as toxic
16 air contaminants and let that drive, what we need to do in
17 terms of ambient monitoring.
18 Let's sample at the edge of fields and let's find
19 enough that we can decide that things are toxic air
20 contaminants in terms of the pesticides and then let that
21 drive your population based monitoring rather then everything
22 happening, it seems to me, in reverse a bit.
23 So, many of the things that we are talking about
24 would automatically be toxic air contaminants, if we can
25 demonstrate that there are any amount of either,
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1 aerosolization or volatility at all or persistence.
2 I mean, to me, these things have to prove that
3 they are not toxic air contaminants. After all they are
4 all toxins, because, after all --
5 They are all toxins, that is how they got to be
6 pesticides, and the only question is do they get into the air
7 or not beyond some kind of trivial amount because of their
8 physical properties and use patterns, right?
9 CHAIRMAN FROINES: These two questions, what I
10 raise and this follow-up is exactly the issue it seems to me.
11 DR. BLANC: So, then I would say no I wouldn't
12 actually take any of this strategy what you are suggesting,
13 what I would is get us rapidly measurements of the edges of
14 the fields and do 20 chemicals a year and then once we
15 declare that they are toxic air contaminants then you can go
16 back and do your monitoring of multiple, to detect the
17 multiple one's so you can get some kind of public health risk
18 assessment on that level and intervention strategies, because
19 the process of declaring something a toxic air contaminant is
20 simply the first step in allowing the Air Resources Board
21 then to proceed with public health regulatory steps that
22 would obviously require the kind of data that we are talking
23 about the very detailed information, whereas ours is really
24 more a dichotomous decision.
25 CHAIRMAN FROINES: The broad based in-depth data on
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1 ambient monitoring is information that one needs for risk
2 management purposes and literally has nothing to do with the
3 dichotomous decision of the Panel.
4 It's not even in the risk assessment phase.
5 MR. BAKER: I like your suggestion.
6 The only case that I can think of that it might not
7 work would be if there was a pesticide for which the chronic
8 exposure was what was driving the risk and the acute
9 exposure, the information that we get from the application
10 site data, and in that case the application site data might
11 not lead DPR to identify it as a toxic air contaminant and
12 then we would need the ambient longer term data for that
13 chronic risk assessment, or DPR that is, would need that
14 information.
15 DR. BLANC: I would be curious to hear what Bob and
16 our other guess have to say on this topic.
17 CHAIRMAN FROINES: Are we ready to move on and hear
18 from Bob?
19 DR. SPEAR: We are ready.
20 CHAIRMAN FROINES: For those of you that don't
21 know this is Dr. Robert Spear, who is the Director of the
22 Center for Occupational Environmental Health.
23 DR. SPEAR: By way of introduction, I will say two
24 things.
25 I think you can actually leave the lights pretty
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1 well up to keep everyone awake.
2 By way of introduction, I will say two things. I
3 spent about a decade in the 70's dealing with pesticides and
4 I haven't done much since, so some of these might be a tad
5 dated, but unfortunately when I do revisit this it has
6 changed unremarkably little.
7 The other thing that will very shortly become
8 obvious to you is I am engineered by training and so when
9 faced with a short time to talk about a complicated subjected
10 I usually fall back on some kind of equations so I apologize
11 for that.
12 The first thing that I'm talking about here, air
13 born exposures to agricultural chemicals I don't have to tell
14 you that compounds air borne exposures are not the only
15 exposures one has to consider, but I understand the
16 partitioning of the regulatory world, and I would like to be
17 quite explicit about what I mean about exposure, and that is
18 that I am talking about inhalation exposure here where C is
19 the concentration of this stuff that we are worried about
20 actually in the breathing zone of the individual who we're
21 concerned about, and I want to underscore here that I am
22 talking about a person.
23 We picked a person and that person is exposed to
24 whatever it is we are concerned here about and concentration
25 C, which varies as a function of time as they move about
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1 their activity whatever it is that they do, and we are
2 assuming that they are breathing, their ventilation rate is
3 some rate, B, which also is the two years of the person and
4 changes over time given their activity.
5 So, that inherently from an engineering experience
6 gives us a little notion, that is to say that this notion of
7 exposure moves with the person.
8 What we get out of this is we sum up or integrate
9 over some exposure time, T, which can be an hour, a day or
10 year, and this particular formulation here, this is the
11 inhalation exposure that you sustain over that period, and it
12 is in, let's say milligrams, then C is for milligrams per
13 cubic meter, then E would be in milligrams, the total amount
14 of this stuff that is inhaled over whatever the exposure
15 period may be.
16 In general, in the risk assessment practice there
17 are two approaches to estimating exposures, the first one
18 here says, well, we can actually in many cases put on some
19 kind of a device on people not unlike this little thing here
20 on the microphone, that will actually measure that interval,
21 C by T over, will measure C by T over the exposure of
22 interval and we then in that formulation we usually make some
23 assumptions about the ventilation rate depending upon the
24 activities that are going on, the age of the person, whatever
25 it may be.
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1 Then we can then take the direct measurement of the
2 concentration over the exposure, multiply it by our estimates
3 of ventilation rates and get an individuals exposure. The
4 other way that it's commonly done is to use the sort of micro
5 environment approach in which we have, we sum up over a
6 number of micro environments, and micro environments can be
7 your car on the way to work, the actual workplace, your home
8 where you are sleeping at night, whatever in each one of
9 these places is characterized by what it is you are doing
10 there and also the amount of time you spend and this where
11 the time activity notion comes in.
12 In this case generally speaking, C, we associate
13 with the environment itself it is a constant number which we
14 associate with the environment, now it could be associated
15 with an individuals environment, as in this case, C, is the
16 function of the person in the environment or it may not be,
17 but any case says you can see in order to make it an exposure
18 esti