Questions for EPA Consultation with FIFRA Science Advisory
Panel on the Development of Aggregate Exposure and
Risk Assessment Guidance
- The draft guidance document describes methodologies for assessing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?
- The draft guidance document describes a process for combining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?
- 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?
- The draft guidance document acknowledges the need to understand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?
- 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?
- The draft guidance document describes three methods for combining risks from the three routes (oral, dermal, and inhalation).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?