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XII.
APPENDIX
^V
ANALYTICAL METHOD FOR REFINED PETROLEUM SOLVENTS'
The
White et al
following
analytical
method is adapted from those described by the
[160] and from Method Kos. s382 and s380 of
Branch of NIOSH [103,104].
Physical
and
Chemical
Analysis
This analytical method will
yield adequate results for refined petroleum solvents with
boiling
ranges
from 120-200 C, eg, varnish makers' and painters' naphtha, mineral spirits,
and Stoddard solvents.
By collecting
two
'samples
of
rubber
solvent
and
desorbing one with carbon disulfide and the other with toluene, this method
should provide adequate results for rubber solvent. results
To
obtain
the
best
for kerosene, the gas-chromatographic conditions should be changed
oparatlon.
from Isothermal to a temperature programmed mode of
chroniatographic
conditions
and
The
gas-
columns
stated in this Appendix have not
been tested for all refined petroleum solvents and some be required for adequate results.
modifications
may
Principle of the Method
Refined petroleum solvent vapor trapped on an activated charcoal from
a. known volume of air Is desorbed with carbon
disulfide,
except
petroleum
ether
or
other
solvents
with boiling points below 60
C, which should be
into
desorbed with toluene.
a
An aliquot of the desorbed sample is injected
The
area
gas
chromatograph.
of the resulting peak is determined and
compared with those obtained from Injection of standards.
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Range and Sensitivity
This method was developed to analyze Stoddard solvents over the range
of 1.417-5,940 and
mg/cu
m at an atmospheric temperature and
pressure of
24
C
749 nsnHg [103].
For a 3-liter sample, the useful range of this method
m at a detector
was 295-8,850
mg/cu
sensitivity
that
gives
nearly
full
deflection on the strip chart recorder for a 26.6-mg sample.
the air sample size, it should
concentrations
By increasing
solvent
be
possible
m
to
detect
airborne
below
195
mg/cu
provided the desorption efficiency is
adequate.
The
Desorption efficiency must be determined over the range used,
upper
limit
of
the
range
of
the method is dependent on the
absorptive capacity of the charcoal tube.
concentrations
This capacity
varies
with
the
of
the
Stoddard
or
other refined petroleum solvents and
other substances in the air.
The first section of
test
the. charcoal", tube held
26.3 mg of Stoddard solvent when a
atmosphere containing 6,026 mg/cu m
of Stoddard solvent in air was sampled at 0.19 liter/minute for 23 minutes;
at
that
time,
the
concentration of Stoddard solvent in the effluent was
less than 5Z of that in the influent.
Interferences
Any
compound which has about the same retention time as Stoddard', or
conditions
This type
other refined petroleum solvents, under the gas-chromatographic
for
this
method, given below, will interfere with the analysis.
of interference can be overcome by changing the operating conditions of the
instrument,
usually the column, the column temperature, or
both.'
When the
humidity is so great that condensation occurs in the sampling tube, organic
vapors will
not be
trapped efficiently.
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Precision and Accuracy
The
coefficient
of
variation for the total analytical and sampling
method for Stoddard solvents in the range of 1,417-5,940
mg/cu'm
was
0.052.
which represents a standard deviation of 153.4 mg/cu m at the OSHA standard
level.
The
average
values
obtained
lower
using
the
the
overall
sampling
and
analytical
methods
were
4.7X
than
"true"
value at the OSHA and
standard level-
The coefficient of variation for the total analytical for
sampling
method
petroleum distillates (varnish makers' and painters'
naphtha)
standard
in the range of
937-3.930 mg/cu
104
m was
0.05^,
which
represents
a
deviation
of
mg/cu n
at the OSHA standard level.
The data method.
were based
on*validation experiments using the
and
internal
standard
Precision
accuracy
data
are
not
available
for rubber solvent -and
as
kerosene.
The data for mineral spirits are assumed to be similar
that
for Stoddard solvents.
Advantages and Disadvantages
(a)
liquids.
eliminated
The
sampling
device is small, portable, and does not contain
Interferences are minimal and most of those that do occur can
be
by altering chromatographic conditions.
which
The tubes are analyzed
by an
instrumental' method,
or
by
changing
the
gas-chromatographic
conditions
columns, is capable of qualitating and quantitating complex
mixtures such as refined petroleum solvents.
(b)
number
The
amount,
of
sample -that
the
can
be taken is limited by the
of
milligrams
that
tube
will
hold
before
loading.
The
possibility
of
sample
loss exists when the sample value obtained for the front
backup section of the charcoal Cube exceeds 25X of that found on the
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section.
Furthermore,
the
precision
of
the -method the tubes.
is
limited
by
will
reproducibllity of the pressure drop across
affect the
This
drop
flowrate and cause the volume to be imprecise because the pump
is usually calibrated for only one .tube.
Apparatus
(a)
(b)
Gas chromatograph equipped with a flame ionizatlon detector,
The
following
is
a list of gas-chromatographic columns that
can be used in the analysis of" all
refined
petroleum
solvents
with
the
exception
of petroleum ether-
Columns (3) and (4) may be used where it is
desirable to separate aromatics from aliphatics.
(1)
Stainless
steel column (6 feet x 1/8 inch) packed with
1.5X OV-101 on 100/120 mesh Chromosorb W (recommended for mineral
St&ddA^d solvents, and kerosene),
spirits,
(2)
100/120 mesh
Stainless
steel
column
packed
rubber
with
10Z
OV-101
and
on
Supelcoport
(recommended
for
solvent
varnish
makers' and painters' naphtha).
(3)
Stainless
steel column (8 feet x 1/8 Inch) packed with
10X TCEP on 100/120 mesh Chromosorb PAW.
(4)
Stilnless
steel column (8 feet x 1/8 inch) packed with mesh
72 tetracyanoethylat&d pentacrythrilol (Penta) on 100/120
PAW.
Chromosorb
(5)
Stainless steel column (20 feet x
1/8 inch) packed with
102 FFAP on 80/100 Chromosorb W AW DMCS.
(6)
\07. SP-2100 on
Stainless steel column (10 feet x
1/8 inch) packed with
100/120 Supelcoport.
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(c)
A
mechanical
or
electronic
Integrator
-'
or
a
recorder for
determining peak area.
(d)
Small
(2-ml)
glass
test
tubes or equivalent with glass- or
polymer-lined stoppers,
(e)
A
10-fil
syringe
and
other
conveniently sized syringes for
preparation of the standards,
(f)
Delivery pipets, 1.0-ml type graduated in 0.1-ml Increments.
Volumetric flasks, about 10-ml.
(g)
Reagents
(a)
(b)
Carbon disulfide or toluene chroinatographic'quality.
The refined petroleum solvent bulk sample.
(c)
(d)
Undecane, or other suitable internal.standard.
Hydrogen, purified,
Helium, purified.
(e)
(f)
Compressed air filtered.
Analysis of Samples
All
glassware, used
for the laboratory analysis should be washed in
detergent and rinsed with tap and distilled water-
(a)
Preparation;
Score
each
charcoal tube, including the blank
from field samples, with a file and
section
break,
open
in
front
of
the
firsc
of
charcoal.
Remove
and
discard the glass wool.
a
Transfer the
test
charcoal in the first (larger)
Remove
and
section to
small
stoppered
tube-
discard
the,
foam separating sections and transfer the second
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section of charcoal
sections separately.
to
another
test
tube.
Analyze
the
two
charcoal
(b)
Desorption;
Prior
to
analysis,
the
pipet
Stoddard
1.0
ml
of
carbon
refined
disulfide into each test tube to- desorb
or
is
other
petroleum
solvents
from
the
charcoal.
Desorption
complete in 30
solutions
minutes if the sample is stirred occasionally.
with
a
For some solvent
boiling range below 160 C, it may be necessary to take two samples.
to
One should be desorbed with carbon disulfide
boiling
components
analyze
for
the
high-
and
the other sample desorbed with toluene to analyze
for the low-boiling components.
If
an
automatic sample injector is used, the sample vials should be
capped as soon as the carbon disulfide is added to minimize volatilization.
For
the
Internal standard method, desorb using X.O ml of carbon disulfide
containing a known amount of the chosen internal standard.
EXTREME CAUTION MUST BE EXERCISED AT ALL TIMES WHEN USING CARBON
DISULFIDE BECAUSE OF ITS HIGH TOXICITY AMD FIRE AND EXPLOSION
HAZARDS.
IT CAN BE IGNITED BY HOT STEAM PIPES.
ALL WORK WITH
CARBON DISULFIDE MUST BE PERFORMED UNDER AN EXHAUST HOOD.
(c)
Typical gas-chroroatographic operating conditions are:
(1) (2) (3.) (4) (5)
30 ml/minute (60 psig) helium flowrate. 35 ml/minute (25 psig) hydrogen flowrate. 400 ml/minute (60 psig) air flowrate.
225 C injector temperature. 250 C manifold temperature (detector).
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(6)
75
C
column
temperature
(recommended
for
mineral
spirits, Stoddard solvents and kerosene),
(7)
and varnish
85 C column temperature (recommended for rubber solvent
makers' and painters' naphtha).
gas-chromatographic
conditions
The
have of
been chosen such that the
solvent-related peaks elute as a
distinctive
cluster
unresolved
peaks.
Observe
patterns
In
searching
for Interferences and adjust the gasThese conditions were specifically
chromatographic conditions accordingly.
chosen' for
Stoddard' or other refined petroleum solvents.
Some alteration
solvents.
In these conditions may be necessary for other refined petroleum
One method that would reduce the number of peaks needed to quantitate
a refined
petroleum solvent air sample- Is the use
supplied
of
head-space
samples.
Using
the
liquid bulk sample, head-space volatlles are prepared
This tube Is then desorbed with
and sampled with'a charcoal tube.
carbon
disulflde
and
analyzed
using a gas chromatograph.
A portion of the bulk
analyzed
sample Is then diluted with carbon
manner
disulflde
and
In
the
same
as
the
head-space sample.
Comparing the two chromatograms should
show three or four peaks Chat have the same relative area for both samples.
These three or four peaks can then be used to quantltate the solvent.
This air
method Is particularly useful for multiple exposure samples.
The bulk
sample
referred to In Appendix III could be used Instead of the head-space
sample of this purpose.
(d)
Injection:
The first step in the analysis is the injection of
the sample into h& gas chromatograph.
technique.
This eliminates
Employ the solvent flush
arising
Injection
difficulties
from
the
blowback
accuracy
or
and
distillation within the syringe needle, thus increasing
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reproducibility
of
the
Injected sample volume.
First, flush the
10*0-^1
plunger,
syringe with carbon disulfide several tiroes to vet the barrel and
then
draw
3.0-^1 of carbon disulfide
into the syringe.
Next, remove the
needle from the carbon disulfide and pull the plunger back about
0.2-^1
to
separate the solvent flush from the sample with an'air pocket to be used as
a marker.
Immerse the needle in the sample
taking
into
and .withdraw
a
1-
to
2-fil
portion,
consideration
the
volume
of the needle since the After
sample in the needle will be completely
removed
injected-
the
needle
is
from
the
sample and prior to injection in the gas chromatograph,
pull the plunger back a short distance to minimize sample evaporation
the tip.
from
Hake duplicate injections of each sample and of the standard.. No of
the,
similar
more than a 32 difference between the peak areas
samples
should be accepted as .a valid result.
(e)
Measurement
of. area:
The
areas
of
the
sample peaks are
measured by electronic integration or some other suitable
measurement*
method
of
area
Preliminary
sample
results
are read from a. standard curve
prepared as outlined below,
Determination of Desorption Efficiency
The
desorption efficiency of a particular compound can vary from' one
one
laboratory to another and also from
batch
of
charcoal
to
another.
Thus, it is necessary t6 determine at least once the percentage of- Stoddard
or other refined petroleum solvents
that
is
removed
in
the
desorption
use.
process.
Repeat this procedure for each new batch of charcoal in
the
Place
same amount of activated charcoal as in the first section
of the sampling tube (100 mg) into a 2.5-inch, 4^rnm ID glass
tube,
flane-
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sealed
at one end.
This charcoal must be from the same batch as that used
in sampling and can be obtained from unused charcoal tubes.
Cap
the
open
end with Parafilm or equivalent-
Inject a known amount of solvent directly
into the activated charcoal with a microliter syringe and cap the tube with
more Parafilm or
equivalent.
tubes at each of three concentrations (0.5x, Ix, and 2x
present
Prepare
six
of the standard) by adding an amount of analyte equivalent to that
in
a
10-liter
sample
at
the
selected level.
Allow the tubes to stand
overnight to assure complete adsorption of the solvent onto
These
six
-tubes
the
charcoal.
are
referred to as the samples.
Treat a parallel blank
Desorb and
tube in the same manner, except add no solvent to it.
analyze
the
sample and blank tubes in exactly-the same manner as the sampling tube
described for unknown air samples.
Prepare
two
or .three standards by injecting the same volume of the
solvent or into 1.0 ml of carbon disulfide with the same the preparation of the sample.
syringe
used
in
These are analyzed with the samples.
If
the
internal
standard
method
is
used,
prepare a calibration
amount
standard by using 1.0 ml of carbon disulfide containing a known
of
the internal standard.
The
desorption
efficiency equals the difference between the average
peak area of the samples and that of the blank divided by the average
area of the standards, or:
peak
desorption effici&ncy
average weight'recovered (mg)
weight added (ing)
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Calibration and Standards
The bulk
samples of the analyte should be used for the calibration.
of
standards
in
terms
It is convenient to express the concentration
of
rae/ml
of
carbon
disulfide because samples are desorbed in 1 ml of carbon
disulfide.
Use the density of the solvent
tested
to
'convert
milligrams
into microliters for easy measurement with a microliter syringe.
Prepare
a
series of standards varying in concentration over the range of interest and
then
analyze
under the same gas-chromatographic. conditions and during the
ths
same time period as
unknown
samples*
Prepare
standard
curves
by
plotting concentration in
mg/ml
versus peak area.
For
the
internal standard method, use carbon disulfide containing a
The
predetermined amount of internal standard.
analyte -concentration
in
nig/ml
is plotted versus the area ratio of the solvent peaks to that of the
internal standard.
Calculations
Read
the
weight
curve*
in milligrams corresponding to the total peak area
from the standard standard
curve
No volume
on
corrections
are
needed
because
the
is
based
mg/ml of carbon disulfide and the volume of
sample Injected is identical to the volume of the standards injected.
Hake
corrections
for
the
blank
from
the field sampling for each
other
sample by subtracting the amounts of Stoddard or
refined
petroleum
solvents found on the front and back sections of the blank from the amounts
found in tha respective sections of the sample;
corrected amount
amount on
sample
230
amount on blank
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Add
che
corrected
amounts
present
In the front and In the backup
Stoddard
sections of the same sample tube Co determine the total amount of
or
other
refined
petroleum
solvents
in
the sample.
Divide this total
of
amount
by the desorption efficiency to obtain the adjusted total amount
Stoddard or other refined petroleum solvents in the sample:
adjusted total amount
____s total amount
desorption efficiency
The
concentration of Stoddard or other refined petroleum solvents in
the air sampled, expressed in
mg/cu m,
is given
by
the
quotient
of
the
adjusted amount, in mg, divided by the volume of air sampled, in cu m:
concentration
(mg/cu m)
adjusted amount (mg)___ volume of air sampled (cu m)
Another method of expressing concentration is ppm:
concentration
(ppm)
concentration
(mg/cu m) x 24.45 x 760 x (T 4- 273) MW P 298
where:
24.45
760
molar volume (liter/mole) at 25 C (78.F) and 760 mmHg
standard pressure
P T
MW
pressure (mmHg) of air sampled
temperature (degrees C) of air sampled
molecular weight of Stoddard solvent (or other refined petroleum solvents (g/mole)
298
standard temperature (degrees K)
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Appendix
V
Results of the Analysis of Inhabitant Exposure Samples From Typical Slab Termite Treatments in the Los Angeles Area-(ug/sample^.
House No
Room
Sample____Pretreat
Treat
lanaed Post
24h Post
i/
1
denial patches
chlordane surface residue chlordane air sample
ethylene glycol impinger
,/ charcoal trap
&
deodorized kerosene air sample
indicates no sample collected
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Case 1:05-cv-01020-MMS
Document 39-19
Filed 01/05/2007
Page 27 of 49
Case 1:05-cv-01020-MMS
Document 39-19
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WORKER HEALTH AND SAFETY UNIT
Division of Pest Management, Environmental Protection and Worker Safety California Department of Food and Agriculture 1220 N Street, Sacramento. California 95814
Field Study
Report Number
HS-
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Case 1:05-cv-01020-MMS
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A STUDY IN SOUTHERN CALIFORNIA IN JULY 1979
OF THE POTENTIAL DERMAL AND INHALATION EXPOSURE OF APPLICATORS AND OTHER PERSONS WHO MIGHT LATER ENTER OR OCCUPY AREAS TREATED WITH CHLORDANE USED AGAINST SUBTERRANEAN TERMITES UNDER HOUSES
Keith T.'Maddy, Staff Toxicologist
Lori Johnston, Area Supervisor Bill Cusick, Field Supervisor
Frank. Schneider, Inspector Terry Jackson, Agricultural Chemist Catherine Cooper, Agricultural Chemist
A. Scott Frederickson, Agricultural Chemist
Worker Health and Safety Unit
Division of Pest Management, Environmental Protection, and Worker Safety California Department of Food and Agriculture 1220 N Street, Sacramento, California 95814
SUMMARY
In July 1979, a chlordane application study was conducted in Southern California to monitor the applicator's exposure during application, and to monitor air inside the homes during and following the chlordane application to determine if persons entering treated areas or the residents would be exposed to unsafe levels of chlordane. Six homes were treated, three with crawl spaces, and three with slab foundations. Exposure was measured by monitoring the concentration of chlordane in the applicator's breathing zone and by attaching cloth patches Co the applicator's coveralls. Air was monitored inside the houses during and after application. Soil samples obtained after the applications were analyzed to determine the potential skin exposure of persons contacting the treated soil. The majority of the air samples were negative or contained less than 1 ppb (.018 mg/m ). A few samples contained more chlordane-the highest was .070 mg/m these were found above the treated soil outside, at the edge of the foundation, and in the crawl space from the time of application through 7 days later. Levels detected on the cloth patches were usually less than 1 roicrogram per square centimeter (ug/cm ). Higher levels ranging from I to 2ug/cm were detected when the applicator had accidently sprayed himself or when he had apparently crawled through a treated The levels of chlordane in the gauze material (second layer of the area. cloth patches) whichcollected the residue expected to reach skin averaged well J>elow 1 ug/cm there was one patch with a level as high as 1.9 ug/cm in the gauze. Chlordane residues in treated Copsoil 24 hours after application ranged from 6 to 122 ppm. Based upon the application methods employed and the results obtained from the study, a set of regulations was developed to minimize exposures from the use of all chlorinated termiticides.
HS-683 (November 4, 1979)
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INTRODUCTION
C
Chlordane (1.2,4,5,6,7,8,8-oct achloro-2.3.3a,4,7,7a-hexahydro-4,7-methanoindane) was one of the first chlorinated hydrocarbon pesticides developed. This chemical is very stable in nature and is very effective against subterranean.termites. In recent years, most of the uses of chlordane as a pesticide have been phased out because of its residual properties and the presumed risk of cancer causation in man.
Studies have shown that chlordane can cause tumors in laboratory animals; human cancer cases, as a result of chlordane exposure, have not been identified. However, it is considered a potential risk which should be
A number of chlorinated hydrocarbons, including chlorguarded against. dane, heptachlor, lindane, and aldrin are animal carcinogens. All of these are effective for controlling subterranean termites. pesticides Safer alternate pesticides for control of subterranean termites with suitable Since termiticides are needed, persistence are not yet available. it is considered necessary to use chlordane and other chlorinated termiticides, but in the safest manner possible. In California, in the past, some chlordane applications have been made by spraying chlordane under high pressure in the crawl spaces under houses. This caused the material to be deposited on furnaces, cooling and heating ducts, and hot water pipes. The material would subsequently enter the home at the time of application, or-more often-later, when heating systems were turned on. By field testing different application techniques, it was found that the dispersal of fine spray into heating ducts, furnaces, etc., could be eliminated by applying chlordane under low pressure with nozzles It was thought that restrictions imposed by producing large droplets. regulations which specify areas that could be sprayed within crawl spaces would further reduce the likelihood of chlordane entering the home.
Y-
f
MATERIALS AND METHODS
Los Angeles and Orange Counties were selected for the treatment sites because of the frequency of applications and gene rally warm weather. Temperatures averaged 85* during the day with lows at night of 65. The humidity ranged from 20 to 40 percent.
were made using "Gold Crest C-100" chlordane, EPA registration number 876-63-AA, in a IX solution. The application equipment consisted of a 100-gallon mix tank with an agitator to maintain a uniform Six houses were treated; 3 were constructed of monolithic mixture. slab, and 3 had concrete cross foundations and girders.
Applications
The application rates for the houses treated were: House 8981 exterior, 30 gallons; house 8982 exterior, 30 gallons; house 8961 exterior, A5 gallons; house 3826 sub-area, 100 gallons, and exterior, 25 gallons; house 3901 65 gallons, and exterior, 25 gallons; house 3706 sub-area, 85 sub-area, gallons, and exterior, 15 gallons.
r
'<_
2-
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Crawl Space
A surface application was made Co the soil area within 18 inches horizonA Spraying tally from the interior foundation wall, piers, and pipes. System "36" valve and a 2-1/2 ft. aluminum spray vand were used; the pump The nozzle pressure was gauge pressure registered approximately 40 psi. less, approximately at 25 psi.
Exterior Foundation
a rodding application was made to the perimeter of the Chlordane was injected at a depth of 10 inches. exterior foundation. For rodding and sub-slab injections, the pump pressure was 60 psi. A B&G Extenda Rod attachment was used.
In all 6 homes,
Slab Construction
Applications were made by sub-slab injection to all probable termite entry points, including cracks, pipes, and voids. A B&G Sub-Slab Injector
attachment
was
used.
All
treatment
holes were
backfilled with
cement.
Samples were collected to determine the potential inhalation and dermal exposure to pest control applicators and inhabitants of the household Samples were during the application and subsequent to the application. also collected to determine the possible risk of exposure to persons who would have contact with the treated area subsequent to application.
Air samples were drawn using an MSA Model S air pump or a Dupont Model S 4,000 air pump through a spill-proof midget impinger containing 10 milli-Iiters of ethylene glycol at the rate of 1,000 ml per minute.
Two air samples were drawn from each applicator's breathing zone during application by using a modified respirator to obtain inside and outside Samples were repremeasurements of chlordane concentration in the air. sentative of exposure occurring during a complete application. Monitoring began just prior to mixing, and continued until the application was completed.
Dermal exposure of the applicators was measured using prewashed patches. The patches consisted of 2 layers of material. The outer material was white duck cotton cloth represent ing the worker's coveralls, with 8 layers of cotton cheese cloth underneath to represent the possible expoBelow the cheese cloth was an aluminum foil sure Co the worker's skin. The patches were attached to the worker's coveralls below the backing. elbows and below the knees, with the cotton cloth on the outside.
To measure potential inhalation exposure to inhabitants, air samplers were placed in the kitchen, bedroom, the crawl space, and above the soil treated at the edge of the slabs. Air samples were taken at the following intervals: 24-hour pre-sample, during application, and 24 hours, 48 hours, 7 All samples were taken for a period days, and 56 days after application. of approximately 2 hours.
3-
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The laboratory analyses were by standard methods chromatography. (See Appendix I.)
employing gas
(^
RESULTS
The sample results are displayed in Tables I and II.
DISCUSSION
The chlordane applications to the homes Chat had crawl spaces took approxThe applications to the houses with slab construction imately 2 hours. took approximately 1-1/2 hours. It is estimated that, depending on the amount of work necessary before treatment and the length of cleanup time, an applicator could perform from 1 to 3 chlordane applications per
day using the methods employed.
The applications were made with minimal exposure to the applicator's skin, although there was an instance where it appears that the applicator accidently sprayed himself or crawled back over an area that had just been treated. Also, when rodd ing the perimeter of one house, one applicator hit a rock with the application rod below the surface, and the 1 percent
chlordane solution squirted back onto the worker's knees.
3 Potential inhalation exposure during application was less than .018 mg/m except during one of the applications where there was .110 mg/m outside the respirator. In general, this type of application, as indicated in this study, seems to minimize the chlordane in air concentrations.
Chlordane residues ranging from 6 to 122 ppm were found in top soil in the Created areas at 24 hours after application.
(
CONCLUSIONS
The use of chlordane should be restricted to licensed pest control operaThis restriction should minimize exposure of tor? with trained personnel. workers and the public if the application methods used in this study are carefully followed. Based upon the application methods and techniques employed in this study, a set of proposed regulations were developed for the use of all chlorinated termiticides in California. The restrictions in these proposed regulations are as follows:
Termiticide Restrictions
The and of the chlorinated hydrocarbons-chlordane, heptachlor. lindane, aldrin-as termiticides shall be made only in accordance with the following restrictions:
use
(a)
Training.
(1) The employer shall inform each employee who may be exposed to these materials of the known and suspected hazards of use, including:
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(
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The fact that, although there are no adequate data to show that these compounds are carcinogenic in humans, because of their carcinogenicity in certain mouse strains and the extensive similarity of the carcinogenic action of chemicals in animals and
(A)
in humans,
and
these pesticides may be carcinogenic in humans;
(B) The in format ion contained in the Department *s Pesticide Safety Information Series Number 23. "Chlordane, Heptachlor, Lindane. and Aldrin, as Used in Termite Control."
(2) This training shall be documented training record.
in
each
employee's
(b) Protective clothing. The employer shall provide, and each employee working with these materials shall wear, clean outer clothing daily, such as long-sleeve coveralls or long-sleeve shirt and trousers. There shall be at least one set of outer clothing at the mixing and transfer site. The employer shall be responsible for cleaning or disposing of this clothing. The person or firm doing the laundry shall be informed by the employer if they receive pesticide-contaminated clothing.
(c.) Safety equipment. Each employer shall provide and each employee mixing, transferring, or applying these materials shall wear, safety equipment including neoprene gloves, neoprene boots, and a respirator with appropriate cartridges approved by NIOSH for filtering out the pesticide The employer shall be responsible for cleaning or disposing being used. of all safety equipment after each day's use.
Adequate water, soap, and towels are to be present at the work allow for thorough washing. Each employee actively engaged in mixing, transferring, or applying these pesticides shall wash his/her face, arms, and hands after any exposure and before eating, drinking, smoking, or finally leaving the worksite.
site
to
(d)
(e) Employers shall provide for a change area, and shall require employees who work with theqe pesticides to wash completely and put on a complete change of clothing at the end of the workday.
Closed systems. Employers shall provide closed systems, as defined in Section 2476(b), for employees who mix or transfer liquid formulations of these materials. No employee shall transfer or mix these materials except through a closed system. This subsection shall take effect on January 1, 1981.
(f)
(g)
shall
Notification.
first
An applicator who proposes to use these materials inform the person in charge of the property to be treated:
(1) That there are no adequate data to show that these compounds are carcinogenic in humans, but because of their carcinogenicity in certain mouse strains and the extensive similarity of
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the carcinogenic action of chemicals in animals and in humans, that these pesticides may be carcinogenic in humans, and exposure to the treated area should be considered as potentially hazardous Co human health.
(
(2) Of the posting requirements of subsection (1) of this section..
(h) Before mixing or transferring these materials, signs shall be "DANGER-PESTICIDE posted around the mix or transfer site which read: APPLICATION IN PROGRESS." These signs shall be visible from any direction of probable approach and readable from a distance of 25 feet. These. signs shall not be removed until the job is completed.
(i) Nozzle and pressure specifications. For surface and trenching applications, pump pressure shall not exceed 40 pounds per square inch. For Nozzle orifices not less than 1/16 inch in diameter shall be used. rodding treatments, pump pressure shall not exceed 75 pounds per square
inch.
These materials shall not be applied (j) Application restrictions. heating equipment, duct work, or to the surface of wood members of No applications shall be made to any portion of the the structure. structure, such as foundations, piers, or pipes, which is above grade The level (that point where ground level is flush with the foundation). soil adjacent Co these portions may be spot treated. Infestations in the soil beneath floor furnaces, or active infestations in the general No application shall sub-area shall be treated by soil injection only. be made in plenum areas.
to
('
(k) Application methods. In addition to the requirements of subsections (i) and (j) of this section, the following techniques shall be used during the application process:
rodding, where soil conditions top of the footing, whichever permit trenching or rodding, not exceed an area 18 inches Infestations beneath pipes. or patios shall be treated by basement, garage floors, slabs, porches, drilling and treating the soil at probable termite entry points. Soil adjacent to the exterior foundations shall be treated by trenching or rodding only. Applications to new construction may be made by flooding cavities or voids in pillars, tile, brick or concrete block walls, chimneys, or other points likely to be penetrated by subterranean termites Soil surface to be covered by concrete before these voids are covered. slabs may be treated by surface application.
Soil shall be treated by trenching or permit, to a depth of 6 inches or to the is less. When soil composition will not surface application may be made but shall horizontally from foundations, piers, or
(1)
durable water-resistant the crawl space.
Immediately after the application, the applicator shall post a sign ionnedlately adjacent to the main entrance of
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(1) This sign shall not be less than 5 inches by 7 inches in length and width, and shall contain the following wording in waterresistant printing:
"WARNING. (PELIGRO, NO ENTRE) THIS AREA HAS BEEN TREATED WITH (specify chemical) ON (specify month, date, and year). THIS MATERIAL HAS BEEN DETERMINED TO CAUSE "CANCER IN LABORATORY ANIMALS AND> BECAUSE OF THIS, EXPOSURE TO THIS AREA SHOULD BE CONSIDERED AS POTENTIALLY HAZARDOUS TO HUMAN HEALTH. ANY PERSON ENTERING THIS AREA WITHIN SEVEN (7) DAYS AFTER APPLICATION SHOULD WEAR A RESPIRATOR APPROVED BY NIOSH FOR PROTECTION AGAINST THE MATERIAL, AS WELL AS NEOPRENE BOOTS AND GLOVES. AFTER
SEVEN (7) DAYS. PROTECTIVE CLOTHING AND EQUIPMENT IS NOT AN ESSENTIAL; HOWEVER, PERSONS ENTERING THIS AREA ARE ADVISED TO BATHE THOROUGHLY AS SOON AFTER LEAVING THE TREATMENT AREA AS IS PRACTICAL AND TO CHANGE CLOTHING AND LAUNDER THEM PRIOR TO REUSE. THIS SIGN SHALL REMAIN POSTED FOR ONE YEAR AFTER APPLICATION."
(2) The name, address, and telephone number shall also be included on the sign.
of
the
licensee
ACKNOWLEDGEMENTS
California Department: of Health Services, served as a consultant for this study. Sue Edmiscon, Rose Christiansen, Jodi Clary, and Cliff Smith, Inspectors in the Worker Health and Safety Unit, assisted in sample collection. The Velsicol Chemical Company carried on a similar study at the same time at the same site; their results were similar and are being reported separately.
Robert Reeves,
Case 1:05-cv-01020-MMS
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Case 1:05-cv-01020-MMS
Document 39-19
Filed 01/05/2007
Page 47 of 49
Case 1:05-cv-01020-MMS
Document 39-19
Filed 01/05/2007
Page 48 of 49
Case 1:05-cv-01020-MMS
Document 39-19
Filed 01/05/2007
Page 49 of 49
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