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Questions for EPA Consultation with FIFRA Science Advisory Panel on the Development of Aggregate Exposure and
Risk Assessment Guidance

  1. The draft guidance document describes methodologies for assessing pesticide risks from single exposure pathways (dietary, residential and drinking water). Are these methodologies complete and satisfactorily described, or does the Panel recommend changes?

  2. The draft guidance document describes a process for combining pesticide exposures and risk from multiple routes and pathways of exposure. Is the process, as described, logical, scientifically defensible, and complete?

  3. A basic concept underlying the draft aggregate exposure and risk assessment methodology is that of the individual being exposed through calender time with all model parameters referring back to that specific individual. Does the Panel agree with using this fundamental principal as the basis for the aggregate exposure and risk methodology?

  4. The draft guidance document acknowledges the need to understand how residential exposures co-occur. OPP is developing standards to identify co-dependencies and inter-relationships between events, and recognizes that product marketing data may be available to aid in this task. Does the Panel have any suggestions on how OPP can best evaluate co-occurrences of exposure events?

  5. During an aggregate exposure and risk assessment, some specific exposure scenarios may be identified as having a minimal contribution to the total aggregate risk. Does the Panel agree that it is appropriate to exclude specific exposure scenarios that contribute minimally to the total aggregate risk, and if so, at what risk level should an exposure scenario be dropped from further consideration?

  6. The draft guidance document describes three methods for combining risks from the three routes (oral, dermal, and inhalation). The Aggregate Risk Index (ARI) is currently being used by OPP. Does the Panel agree that OPP should continue to use the ARI approach or should OPP consider using one of the other described approaches?
Scientific Advisory Panel: February 1999 Meeting

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