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Scientific Advisory Panel
Prior to the development of an exposure assessment for a detergent/handsoap scenario, the assessor should consult the pesticide label to determine whether the scenario is appropriate based on the usage of characteristics of the product. Specific labeling considerations for detergent/handsoap are as follows:
Detergent or Hand Soap with Pesticidal Claims. Some detergents and hand soaps that contain pesticides have a pesticide label on their container. The labels of such products make claims about pest control, such as "kills mildew," "disinfects," or "kills germs on contact." These labels will contain an active ingredient statement indicating the amount of active ingredient in the container.
Detergent or Hand Soap with No Pesticidal Claims. Some detergents and hand soaps that contain pesticides do not have a pesticide label on their container and their labels do not make claims about pest control. The pesticide in these products is present as a biocide to preserve the product itself. Persons using these household products are considered "secondary handlers," since they are not handling the pesticide itself -- they are handling products that contain pesticide as a general preservative. The SOP for exposure/risk assessments for such secondary handlers (and secondary post-application exposures) is in the biocide SOP under secondary exposures to general preservative uses. In order to determine the amount of pesticide in these products, the pesticide label for the biocide product must be obtained and the use-rate per quart/gallon of household product must be calculated.
Limitation and Descriptive Statements: Look for statements describing or limiting the use of detergents or hand soaps that have pesticide labels on their containers. These statements may be on the front panel of the label associated with the brand or trade name or in the use-directions section of the labeling. Assume that such products are used at residential sites unless a specific labeling statement indicates otherwise. Statements such as "For use by commercial or professional laundries only", "Not for sale or use at residential sites," or "Not for homeowner use" indicate that the product cannot be bought or applied by homeowners. Therefore, no residential handler exposure/risk assessment is required. Since the laundry will be returned to a residential site, a post-application exposure/risk assessment is required.
This SOP provides a standard method for estimating doses to handlers from dermal contact with detergent, bar soap, and other consumer products using the DERMAL model. The DERMAL model also provides a method for estimating postapplication (i.e., passive) exposure to laundry detergent.
The DERMAL model has been developed by EPA's Office of Pollution Prevention and Toxics, Economics, Exposure, and Technology Division to support the assessment of Premanufacture Notification chemicals under the Toxic Substance Control Act. DERMAL is used primarily in screening-level assessments of dermal exposure to the components of consumer products. The model estimates acute potential dose rates and annual average daily dose rates for handlers for dermal exposure scenarios involving the chemical components of 16 consumer product types. The list of consumer products in the model includes the following:
In addition, the DERMAL model includes a generic product scenario that allows users to input their own scenario. The only postapplication scenario included in the model is for transfer of laundry detergent residues on clothing to the skin.
The DERMAL model calculates dermal exposure using the weight fraction of the chemical in the product of interest and assuming a certain film thickness of product on the skin and surface area exposed. In addition, default values are used for the frequency of events per year, exposure duration, and body weight. These defaults can be changed by the user if desired. For detailed information on the use of the DERMAL model, refer to the User's Manual (U.S. EPA, 1995).
Methods for Estimating Dose
Label information is important for selecting appropriate data inputs for the exposure assessments in DERMAL (see Section 10.0). Because the DERMAL model provides default values for many of the standard model scenarios, the only input values that are generally required by the user is the weight fraction of ai in the product of interest. After entering the DERMAL model, the user should select the product scenario of interest. When the data entry menu appears, the user should enter the median and high-end weight fractions for the ai in the products. Although the other model inputs may be changed by the user, it is recommended that users accept all model defaults unless product or chemical-specific data are available for the scenario. After all data input values are entered, the user should select run the model. When the calculations are complete, the output selection screen will prompt the user to direct the results to the screen, the printer, or to a file. The results include central, high-end, and bounding estimates for acute potential dose rates (APDRs) and chronic exposure (lifetime average daily doses - LADDs). To be consistent with other doses calculated using these SOPs, the user should select the APDRs generated by the DERMAL model.
Limitations and Uncertainties
The DERMAL model provides central, high-end, and bounding estimates for dermal exposure to consumer products. The limitations associated with its use include uncertainties associated with the film thickness approach to dermal exposure assessment and uncertainties associated with the various model inputs. The DERMAL Manual (U.S. EPA, 1995) should be consulted for a discussion of the model inputs.
U.S. EPA (1995) DERMAL Exposure Model Description and User's Manual, draft report. Prepared for the U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics by Versar, Inc. under Contract No. 68-D3-0013.
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