1
of
28
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
Date:
3/
2/
2006
Subject:
Benthiavalicarb­
Isopropyl.
PP#
3E6545.
Request
for
Tolerances
on
Imported
Grapes
and
Tomatoes.
Summary
of
Analytical
Chemistry
and
Residue
Data.

DP
Barcode:
D322934
Decision
No.:
305740
PC
Code:
098379
MRID
Nos.:
45834904
through
45834908,
and
45869702
through
45869713
40
CFR:
Not
Established
Chemical
Class
Valinamide/
Carbamate
Fungicide
From:
Douglas
Dotson,
Ph.
D.,
Chemist
RAB2/
Health
Effects
Division
(
7509C)

Through:
Dennis
McNeilly,
Chemist
Michael
Doherty,
Ph.
D.,
Chemist
RAB2/
Health
Effects
Division
(
7509C)

and
Richard
Loranger,
Ph.
D.
Branch
Senior
Scientist
RAB2/
Health
Effects
Division
(
7509C)

To:
Tamue
Gibson/
Mary
Waller
Fungicide
Branch
Registration
Division
(
7505C)

This
summary
document
was
originally
prepared
under
contract
by
Dynamac
Corporation
(
1910
Sedwick
Rd.,
Building
100,
Suite
B;
Durham,
NC
27713;
submitted
2/
22/
2005).
The
summary
document
has
been
reviewed
by
the
HED
and
revised
to
reflect
current
OPP
policies.
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
2
of
28
Executive
Summary
Benthiavalicarb­
isopropyl
(
hereafter
in
this
document
referred
to
solely
as
benthiavalicarb),
isopropyl[(
S)­
1­[[[(
1R)­
1­(
6­
fluoro­
2­
benzothiazolyl)
ethyl]
amino]
carbonyl]­
2­
methylpropyl]
carbamate,
is
a
new
valinamide/
carbamate
type
of
fungicide.
The
R­
L
stereoisomer
(
KIF­
230R­
L)
is
the
main,
pesticidally­
active
component;
however,
the
S­
L
stereoisomer
(
KIF­
230S­
L)
is
also
present
as
a
minor
impurity.
There
are
currently
no
food/
feed
uses
or
tolerances
for
benthiavalicarb
in
the
U.
S.

K­
I
Chemical
U.
S.
A.,
Inc.
has
submitted
a
petition
(
PP#
3E6545)
proposing
tolerances
for
benthiavalicarb
on
grapes
and
tomatoes
(
both
greenhouse
and
field)
grown
in
the
European
Union
(
EU)
for
importation
to
the
U.
S.
The
formulations
being
proposed
for
use
in
the
EU
include
a
15%
water­
dispersible
granule
(
WDG)
and
another
WDG
containing
both
benthiavalicarb
(
1.75%)
and
mancozeb
(
70%).
Proposed
labels
were
not
available
for
review,
but
a
summary
of
the
use
directions
indicates
that
the
maximum
use
rate
is
for
up
to
6
foliar
applications
to
grapes
during
fruit
development
at
0.031
lb
ai/
A/
application,
for
0.19
lb
ai/
A/
season,
with
a
minimum
preharvest
interval
(
PHI)
of
28
days.
For
tomatoes
(
greenhouse
and
field),
the
maximum
use
rate
is
for
up
to
6
foliar
applications
to
tomatoes
during
fruit
development
at
0.067
lb
ai/
A/
application,
for
0.40
lb
ai/
A/
season,
with
PHIs
of
3
days
for
greenhouse­
grown
tomatoes
and
7
days
for
fieldgrown
tomatoes.
Minimum
retreatment
intervals
(
RTIs)
were
not
specified.

For
the
purposes
of
this
tolerance
petition,
the
nature
of
the
residue
has
been
adequately
delineated
based
on
acceptable
grape
and
tomato
metabolism
studies.
The
available
potato
metabolism
study
is
also
acceptable
pending
submission
of
supporting
storage
stability
data
(
21
months).
In
grapes
and
tomatoes,
the
metabolism
of
benthiavalicarb
was
minimal
with
parent
being
the
only
major
residue
in
fruit
and
foliage
(
55­
95%
TRR).
Parent
was
also
the
principle
14C­
residue
in
potato
foliage
(
88­
90%
TRR),
but
other
minor
metabolites
were
identified.
In
potatoes,
the
metabolism
of
benthiavalicarb
occurs
primarily
via
direct
hydroxylation
of
the
phenyl
ring
or
defluorination
and
hydroxylation
of
the
phenyl
ring.
Secondary
metabolism
occurs
via
conjugation
of
sugar
with
hydroxy
groups.
Although
two
major
(>
10%)
residues
were
observed
in
potato
tubers,
the
absolute
levels
of
these
metabolites
(
suggested
to
be
sugar
conjugates)
were
<
0.006
ppm.
Chiral
analysis
of
potato
foliage
extracts
also
indicates
that
there
was
no
isomeric
conversion
of
the
active
R­
L
isomer
to
other
possible
isomers
(
S­
L,
R­
D,
or
S­
D).
Based
on
the
results
of
the
metabolism
studies,
the
residues
of
concern
in
grapes
and
tomatoes
for
both
tolerance
expression
and
risk
assessment
are
the
combined
residues
of
the
R­
L
and
S­
L
isomers
of
benthiavalicarb.
The
nature
of
the
residue
in
livestock
was
not
determined,
and
is
not
required,
as
there
are
no
significant
livestock
feed
items
associated
with
grapes
and
tomatoes.

An
adequate
GC/
NPD
Method
(
RCC
No.
665943)
is
available
for
collecting
data
on
residues
of
both
the
R­
L
and
S­
L
isomers
of
benthiavalicarb
in/
on
grape
and
tomato
commodities.
For
this
method,
residues
are
extracted
with
acetone,
partitioned
into
hexane,
purified
using
an
amino
SPE
cartridge,
and
determined
by
GC/
NPD.
The
lower
limit
of
method
validation
(
LLMV)
is
0.01
ppm
for
each
analyte
in
grape
and
tomato
commodities.
The
limit
of
detection
(
LOD)
in
grapes
is
0.001
ppm.
The
LOD
in
grape
processed
commodities,
tomatoes,
and
tomato
processed
commodities
is
0.002
ppm.
The
method
was
adequately
validated
by
the
petitioner,
and
is
being
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
3
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proposed
as
the
tolerance
enforcement
method.
The
method
was
successfully
validated
in
an
independent
laboratory
method
validation
(
ILV)
trial,
and
radiovalidation
data
are
not
required,
given
the
similarity
between
the
extraction
procedures
used
in
the
method
and
those
used
in
the
metabolism
studies.
However,
because
the
method
is
not
highly
specific,
the
petitioner
should
either
develop
a
confirmatory
method
for
the
analytes
of
interest
or
conduct
an
interference
study.
The
method
was
forwarded
to
the
Analytical
Chemistry
Branch
(
ACB)
of
the
Biological
and
Economic
Assessment
Division
(
BEAD)
for
a
petition
method
validation
(
PMV)
trial.
ACB
concluded
that
the
method
does
not
need
to
be
laboratory­
validated
by
EPA,
and
appears
to
be
suitable
for
tolerance
enforcement.

Benthiavalicarb
(
KIF­
230R­
L)
was
tested
using
FDA
Multiresidue
Method
Protocols
C,
D,
E
and
F.
The
compound
was
not
tested
through
Protocols
A,
B
and
G,
because
(
i)
it
is
not
naturally
fluorescent;
(
ii)
it
does
not
possess
an
N­
methylcarbamate,
acid,
or
phenol
structure;
and
(
iii)
it
is
not
a
substituted
urea.
The
multiresidue
methods
did
not
appear
to
be
suitable
for
analysis
of
benthiavalicarb.

Adequate
storage
stability
data
are
available
indicating
that
benthiavalicarb
is
stable
under
frozen
(#­
18
°
C)
conditions
for
at
least
13
months
in
grapes
and
8
months
in
tomatoes.
These
data
support
the
maximum
storage
intervals
(
7­
8
months)
from
the
grape
and
tomato
field
trials.

As
there
are
no
significant
livestock
feed
items
associated
with
the
proposed
use
on
grapes
and
tomatoes,
livestock
feeding
studies
are
not
required
for
this
petition.
Tolerances
do
not
need
to
be
established
on
animal
commodities.

The
available
field
trial
data
are
adequate
and
will
support
the
proposed
use
patterns
on
grapes
and
tomatoes.
The
number
and
geographic
distribution
of
the
field
trials
are
adequate.
For
grapes,
a
total
of
34
field
trials
were
conducted
throughout
the
EU,
in
which
grapes
were
treated
at
1x
the
maximum
proposed
rate
and
harvested
at
the
minimum
PHI
of
28
days.
Maximum
combined
residues
were
<
0.27
ppm
in/
on
grapes,
and
the
highest
average
field
trial
(
HAFT)
residue
value
was
0.22
ppm.
For
tomatoes,
12
trials
were
conducted
at
1x
the
maximum
rate
throughout
the
EU
on
both
greenhouse­
and
field­
grown
tomatoes.
Nine
of
these
12
field
trials
were
performed
on
greenhouse­
grown
tomatoes
and
three
were
performed
on
field­
grown
tomatoes.
Maximum
combined
residues
were
0.27
ppm
in/
on
greenhouse
tomatoes
3
days
after
treatment
(
DAT)
and
<
0.015
ppm
in/
on
field­
grown
tomatoes
(
7
DAT).
The
recommended
tolerances
for
grapes
and
tomatoes
were
generated
using
HED's
statistical
tolerance
generator
for
NAFTA­
harmonized
tolerances.
The
recommended
tolerance
for
grapes
is
0.25
ppm,
even
though
the
highest
field
trial
value
is
0.27
ppm.
The
recommended
tolerance
for
tomatoes
is
0.45
ppm.

The
available
processing
data
are
adequate
for
these
tolerance
requests.
The
average
processing
factors
were
3.7x
for
raisins,
0.47x
for
juice,
and
0.97x
for
wine.
Based
on
the
3.7x
processing
factor
for
raisins
and
the
HAFT
residue
value
of
0.22
ppm
for
grapes,
the
maximum
expected
residues
in
raisins
would
be
0.81
ppm,
which
is
above
the
recommended
grape
tolerance.
Therefore,
a
separate
tolerance
is
required
for
raisins.
HED
recommends
in
favor
of
the
proposed
tolerance
of
1.0
ppm
for
grape,
raisin.
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
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4
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28
In
the
tomato
processing
studies,
the
average
processing
factors
from
tests
having
quantifiable
residues
were
0.49x
in
juice,
1.2x
in
puree,
and
1.4x
in
ketchup.
As
residue
data
were
not
available
for
paste,
the
5.5x
theoretical
concentration
factor
based
on
loss
of
water
was
used
for
this
commodity.
The
highest
field
trial
residue
value
of
0.015
ppm
from
the
tests
on
field­
grown
tomatoes
was
used
to
assess
the
need
for
tolerances
on
processed
tomato
fractions
as
greenhouse
tomatoes
are
not
utilized
for
processing.
Based
on
the
above
processing
factors
and
the
highest
field
trial
value
of
0.015
ppm,
the
maximum
expected
residues
in
puree,
ketchup,
juice,
and
paste
would
be
0.018,
0.021,
0.0074
ppm,
and
0.083
ppm,
respectively,
all
of
which
are
below
the
recommended
tomato
tolerance
of
0.45
ppm.
Therefore,
separate
tolerances
are
not
required
for
processed
tomato
fractions.
Storage
stability
data
were
not
submitted
for
processed
grape
and
tomato
commodities.
These
data
are
not
required
for
the
current
tolerance
requests
because
acceptable
storage
stability
data
were
submitted
for
grapes
and
tomatoes.
Residues
were
stable
in
grapes
for
13
months
and
in
tomatoes
for
8
months.
In
the
tomato
storage
stability
studies,
tomatoes
were
homogenized
prior
to
storage.
Homogenized
tomatoes
are
comparable
in
both
composition
and
texture
to
processed
tomato
commodities.
The
matrix
is
an
acidic
one
which
would
very
likely
maximize
residue
decay.
As
a
result,
the
tomato
data
are
considered
adequate
to
demonstrate
storage
stability
in
processed
grape
commodities
as
well.

As
the
proposed
uses
are
for
grape
and
tomatoes
grown
in
the
EU,
confined
and
field
rotational
crops
studies
are
not
required
for
the
current
petition.

Regulatory
Recommendations
and
Residue
Chemistry
Deficiencies
Samples
in
the
potato
metabolism
study
were
stored
frozen
for
up
to
21
months.
HED
recommends
that
the
registrant
submit
data
supporting
the
stability
of
14C­
residues
during
frozen
storage.
These
storage
stability
data
are
not
needed
for
the
grape
and
tomato
tolerances.
However,
they
would
be
needed
in
the
event
that
the
registrant
proposes
tolerances
on
potatoes
or
a
crop
similar
to
potatoes.

No
major
deficiencies
were
noted
in
the
subject
petition
that
would
preclude
establishing
tolerances
for
benthiavalicarb
on
grape
and
tomato
commodities.
However,
before
any
further
tolerances
are
granted,
the
petitioner
should
either
develop
a
confirmatory
analytical
method
for
the
analytes
of
interest
or
conduct
an
interference
study.

There
are
no
residue
chemistry
issues
that
would
preclude
establishing
tolerances
of
0.25
ppm
for
grape,
0.45
ppm
for
tomato,
and
1.0
ppm
for
grape,
raisin.
The
recommended
tolerances
for
grape
and
tomato
were
generated
using
HED's
statistical
tolerance
generator
for
NAFTAharmonized
tolerances.
The
residues
to
be
included
in
the
tolerance
expression
are
the
combined
R­
L
and
S­
L
isomers
of
benthiavalicarb.
The
petitioner
has
recommended
that
only
the
R­
L
isomer
be
included
in
the
tolerance
expression
because
the
S­
L
isomer
is
a
minor
impurity
in
the
commercial
formulations
and
the
potato
metabolism
study
indicates
that
the
active
R­
L
isomer
is
not
converted
to
the
S­
L
isomer.
In
addition,
the
residue
definition
proposed
for
the
EU
MRLs
includes
only
the
R­
L
isomer.
The
registrant
has
proposed
EU
MRLs
of
0.2
ppm
for
grapes
and
0.3
ppm
for
tomatoes.
It's
possible
that
if
EU
MRLs
are
established,
the
residue
definition
might
be
benthiavalicarb­
isopropyl
only,
and
no
distinction
will
be
made
as
to
the
isomer.
HED
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
5
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S
N
N
H
H
CH
3
NH
O
C
H
3
CH
3
O
H
CH
3
C
H
3
F
O
concludes
that
the
S­
L
isomer
should
be
included
in
the
tolerance
expression,
however.
The
results
of
the
field
trials
indicate
that
the
residue
levels
of
the
S­
L
isomer
are
often
non­
negligible
compared
to
the
levels
of
the
R­
L
isomer.
In
the
grape
field
trials,
several
samples
had
S­
L
isomer
levels
that
were
10­
20%
of
the
R­
L
isomer
levels.
A
small
number
of
samples
had
S­
L:
RL
ratios
that
exceeded
20%.
In
the
tomato
field
trials,
the
S­
L
residue
levels
were
generally
nondetectable
In
a
few
cases,
however,
the
S­
L
isomer
was
present
at
6­
7%
of
the
level
of
the
R­
L
isomer.
The
technical
material
contains
93%
R­
L
isomer
and
3.4%
S­
L
isomer.
The
analytical
method
determines
both
isomers
separately.

RAB2
concludes
that
there
are
no
residue
chemistry
issues
that
would
preclude
establishing
tolerances
for
the
combined
residues
of
isopropyl[(
S)­
1­[[[(
1R)­
1­(
6­
fluoro­
2­
benzothiazolyl)
ethyl]
amino]
carbonyl]­
2­
methylpropyl]
carbamate
and
isopropyl[(
S)­
1­
[[[(
1S)­
1­(
6­
fluoro­
2­
benzothiazolyl)
ethyl]
amino]
carbonyl]­
2­
methylpropyl]
carbamate
at
0.25
ppm
in/
on
grape,
0.45
ppm
in/
on
tomato,
and
1.0
ppm
in/
on
grape,
raisin.

Background
Benthiavalicarb
is
a
new
valinamide
carbamate
type
of
fungicide
being
proposed
for
use
on
grapes
and
tomatoes
(
both
field
and
greenhouse)
in
the
EU
for
the
control
of
downy
mildew.
Its
mode
of
action
is
through
the
inhibition
of
phospholipid
biosynthesis.
The
R­
L
stereoisomer
of
benthiavalicarb
(
KIF­
230R­
L)
is
the
main
and
pesticidally
active
component;
however,
the
S­
L
stereoisomer
(
KIF­
230S­
L),
which
is
not
pesticidally
active,
is
also
present
as
a
minor
impurity.

The
benthiavalicarb
products
being
proposed
for
use
in
the
EU
on
grapes
and
tomatoes
include
a
15%
water­
dispersible
granule
(
WDG),
for
use
only
on
tomatoes,
and
a
multiple
active
ingredient
WDG
formulation
containing
both
benthiavalicarb
(
1.75%)
and
mancozeb
(
70%)
for
use
on
both
grapes
and
tomatoes.
These
formulations
are
labeled
for
multiple
foliar
applications.

There
are
currently
no
food/
feed
uses
or
tolerances
for
benthiavalicarb
in
the
U.
S.
K­
I
Chemical
U.
S.
A.,
Inc.
has
submitted
a
petition
(
PP#
3E6545)
proposing
the
use
of
benthiavalicarb
on
tomatoes
and
grapes
grown
in
Europe
for
importation
to
the
U.
S.

Table
1.
Nomenclature
of
Benthiavalicarb
Compound
Common
name
Benthiavalicarb­
isopropyl
(
R­
L
isomer)

Company
experimental
names
KIF­
230R­
L
Benthiavalicarb­
isopropyl
Summary
of
Analytical
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and
Residue
Data
Barcode:
D322934
Table
1.
Nomenclature
of
Benthiavalicarb
6
of
28
S
N
N
H
CH
3
H
NH
O
C
H
3
CH
3
O
H
CH
3
C
H
3
F
O
IUPAC
name
Isopropyl[(
S)­
1­{[(
1R)­
1­(
6­
fluoro­
1,3­
benzothiazol­
2­
yl)
ethyl]
carbamoyl}­
2­
methylpropyl]
carbamate
CAS
name
Isopropyl[(
S)­
1­[[[(
1R)­
1­(
6­
fluoro­
2­
benzothiazolyl)
ethyl]
amino]
carbonyl]­
2­
methylpropyl]
carbamate
CAS
#
177406­
68­
7
End­
use
products/
EP
15%
WDG,
1.75
WDG
(
MAI
with
70%
Mancozeb)

Compound
Common
name
Benthiavalicarb­
isopropyl
(
S­
L
isomer)

Company
experimental
names
KIF­
230S­
L
IUPAC
name
Isopropyl[(
S)­
1­{[(
1S)­
1­(
6­
fluoro­
1,3­
benzothiazol­
2­
yl)
ethyl]
carbamoyl}­
2­
methylpropyl]
carbamate
CAS
name
Isopropyl[(
S)­
1­[[[(
1S)­
1­(
6­
fluoro­
2­
benzothiazolyl)
ethyl]
amino]
carbonyl]­
2­
methylpropyl]
carbamate
CAS
#
Not
available
Table
2.
Physicochemical
Properties
of
Benthiavalicarb
Parameter
Value
Reference
Melting
point
167
±
0.5
°
C
Section
A
of
PP#
3E6545
pH
4.35
at
25
°
C
(
1%
w/
v
aqueous
suspension)

Density
1.25
g/
cm3
at
20.5
±
0.5
°
C
Water
solubility
(
20
/

C)
10.96
mg/
L
at
pH
5
13.14
mg/
L
at
unadjusted
pH
12.76
mg/
L
at
pH
9
Solvent
solubility
(
g/
L
at
20
/

C)
Not
reported
Vapor
pressure
at
25
/

C
<
3.0
x
10­
4
Pa
Dissociation
constant
(
pKa)
No
dissociation
from
pH
1.12­
12.81
at
20
°
C
Octanol/
water
partition
coefficient
Log(
KOW)
2.52­
2.59
at
pH
5­
9
UV/
visible
absorption
spectrum
(
8max,
nm)
Not
reported
Benthiavalicarb­
isopropyl
Summary
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and
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Data
Barcode:
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7
of
28
860.1200
Directions
for
Use
Table
3.
Summary
of
Directions
for
Use
of
Benthiavalicarb.

Applic.
Timing,
Type,
and
Equip.
Formulation
1
Applic.
Rate
(
lb
ai/
A)
Max.
No.
Applic.
per
Season
Max.
Seasonal
Applic.
Rate
(
lb
ai/
A)
PHI
(
days)
Use
Directions
and
Limitations
Grapes
Broadcast
foliar
application
Ground
or
aerial
equipment
1.75%
WDG
2
0.031
6
0.19
28
Minimum
application
volumes
and
RTIs
were
not
specified.

Tomatoes
Broadcast
foliar
application
Ground
or
aerial
equipment
15%
WDG
1.75%
WDG
2
0.067
(
0.031)
3
6
0.40
(
0.19)
3
greenhouse
­
3
field
­
7
Minimum
application
volumes
and
RTIs
were
not
specified.

1
No
formulations
are
currently
being
proposed
for
use
in
the
U.
S.
2
The
1.75%
WDG
is
a
MAI
that
also
contains
70%
mancozeb.
3
When
used
in
conjunction
with
mancozeb,
the
maximum
single
and
seasonal
application
rate
is
lower.

Conclusions.
No
benthiavalicarb
formulations
are
currently
being
proposed
for
use
in
the
U.
S.
Current
EU
labels
were
not
available
to
the
reviewer,
however,
the
use
directions
provided
are
adequate
to
allow
evaluation
of
the
residue
data
relative
to
the
proposed
uses.
For
grapes,
the
available
field
trial
data
will
support
a
maximum
of
six
foliar
applications
at
0.031
lb
ai/
A/
application
during
fruit
development
for
a
total
of
0.19
lb
ai/
A/
season,
with
a
minimum
RTI
of
9
days
and
a
28­
day
PHI.
For
tomatoes,
the
available
field
trial
data
will
support
a
maximum
of
six
foliar
applications
during
fruit
development
at
0.067
lb
ai/
A/
application,
for
0.40
lb
ai/
A/
season,
with
a
minimum
RTI
of
7
days.
The
PHIs
are
3
days
for
greenhouse­
grown
tomatoes
and
7
days
for
field­
grown
tomatoes.
For
both
grapes
and
tomatoes,
the
field
trials
were
performed
at
the
maximum
label
rate
(
1x)
and
the
minimum
PHI.

860.1300
Nature
of
the
Residue
­
Plants
45869702.
DER
(
Grape)
45869703.
DER
(
Tomato)
45869704.
DER
(
Potato)

The
petitioner
has
submitted
metabolism
studies
delineating
the
nature
of
the
residues
in
grapes,
tomatoes,
and
potatoes
following
multiple
foliar
applications.
The
results
are
summarized
below.
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
8
of
28
Grape
The
R­
L
isomer
of
[
14C]
benthiavalicarb,
radiolabeled
at
the
2­
valyl
position
[
Val­
14C]
or
uniformly
in
the
benzene
ring
[
Bz­
14C],
was
applied
as
six
broadcast
foliar
applications
to
grape
vines
during
fruit
development
at
rates
equivalent
to
0.089
lb
ai/
A
at
RTIs
of
7­
14
days,
for
a
total
of
0.53
lb
ai/
A/
season
(­
2.8x
the
maximum
proposed
seasonal
rate
of
0.19
lb
ai/
A/
season).
Grapevine
foliage
and
grapes
were
harvested
17
days
after
the
last
application
(
17
DAT).

The
total
radioactive
residues
(
TRR)
were
0.241
ppm
in/
on
grapes
and
21.66
ppm
in/
on
grapevine
foliage
from
the
[
Val­
14C]
test
and
0.327
ppm
in
grapes
and
14.01
ppm
in
foliage
from
the
[
Bz­
14C]
test.
Samples
were
extracted
sequentially
with
acetonitrile
(
ACN),
water,
and
acetone.
The
ACN
and
water
extracts
were
combined
and
partitioned
with
ethyl
acetate
(
EtOAc),
and
the
resulting
fractions
were
analyzed
by
HPLC
and/
or
TLC.
Aqueous
phase
extracts
from
vine
foliage
samples
were
further
subjected
to
$­
glucosidase
enzymatic
hydrolysis
and
analyzed
by
HPLC.

Initial
solvent
extractions
solubilized
90­
98%
TRR
from
grape
matrices,
and
another
5%
of
the
TRR
was
extracted
from
foliage
with
water.
Subsequent
acetone
extraction
solubilized
an
additional
1­
2%
TRR.
Nonextractable
residues
accounted
for
1.1­
2.4%
TRR
in
grape
matrices.
HPLC
analyses
identified
parent
(
94.0­
96.5%
TRR)
as
the
main
component
in
both
fruit
and
foliage.
No
other
metabolites
were
identified,
and
isolated
unknowns
accounted
for
#
2.0%
of
the
TRR
in
each
matrix.
Enzymatic
hydrolysis
of
foliage
extracts
with
$­
glucosidase
did
not
show
evidence
of
glucoside
conjugation.
No
differences
were
noted
in
either
the
level
or
distribution
of
14C­
residues
between
the
two
14C­
labels.

Tomato
The
R­
L
isomer
of
[
Bz­
14C]
benthiavalicarb
was
applied
as
six
broadcast
foliar
applications
to
tomato
plants
during
fruit
development
at
a
rate
equivalent
to
0.089
lb
ai/
A/
application,
at
RTIs
of
7­
14
days,
for
a
total
of
0.53
lb
ai/
A/
season
(
1.3x
the
maximum
proposed
seasonal
rate).
Tomato
fruit
was
harvested
at
14,
28,
35,
49,
and
56
DAT,
and
foliage
was
harvested
at
56
DAT.

Following
the
final
application,
TRR
in/
on
fruit
declined
slowly
from
0.018­
0.021
ppm
at
14
DAT
to
0.007
ppm
at
56
DAT.
TRR
was
2.33
ppm
in/
on
tomato
foliage
harvested
56
DAT.
Samples
were
extracted
sequentially
with
ACN
and
water.
The
ACN
extract
from
fruit
samples
was
diluted
with
water,
further
cleaned
up
using
solid
phase
extraction
(
SPE),
then
analyzed
by
HPLC
and
TLC.
The
aqueous
SPE
phase
was
concentrated,
reconstituted
in
water:
MeOH
(
4:
1,
v/
v),
and
analyzed
by
HPLC
and
TLC.
The
ACN
and
water
extracts
from
the
foliage
samples
were
combined,
concentrated,
and
analyzed
by
HPLC
and
TLC.

Initial
ACN
extractions
solubilized
63­
98%
TRR
from
tomato
matrices,
and
another
0­
34%
of
the
TRR
was
extracted
with
water.
Nonextractable
residues
accounted
for
2.4­
4.0%
TRR
in
tomato
matrices.
HPLC
analyses
identified
parent
as
comprising
54.8­
95.1%
of
the
TRR
in
tomatoes
and
tomato
foliage.
Parent
was
the
only
compound
detected
in
either
fruit
or
foliage.
In
the
56­
DAT
fruit,
unknowns
accounted
for
a
total
of
40.9%
of
the
TRR,
but
each
unknown
accounted
for
#
9.4%
of
the
TRR
(<
0.001
ppm).
Benthiavalicarb­
isopropyl
Summary
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Data
Barcode:
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9
of
28
Potato
The
metabolism
of
benthiavalicarb
(
R­
L
isomer)
in
potatoes
was
examined
in
three
different
tests
using
both
[
Bz­
14C]­
and
[
Val­
14C]­
labeled
benthiavalicarb
in
each
test.
In
a
preliminary
study
(
Test
I),
each
14C­
labeled
compound
was
applied
as
a
single
broadcast
foliar
application
to
immature
potato
plants
at
a
rate
equivalent
to
­
0.089
lb
ai/
A,
and
foliage
samples
were
collected
12
DAT.
In
the
second
study
(
Test
II),
each
[
14C]­
label
was
applied
as
a
single
post­
emergence
soil
application
at
a
rate
equivalent
to
­
0.089
lb
ai/
A,
and
samples
of
tubers
and
foliage
were
collected
90
DAT.
In
the
third
study
(
Test
III),
each
[
14C]­
label
was
applied
as
six
broadcast
foliar
applications,
at
RTIs
of
7
days,
to
mature
potato
plants
at
rates
equivalent
to
0.088­
0.091
lb
ai/
A,
for
a
total
of
approximately
0.54
lb
ai/
A/
season.
Mature
tubers
and
foliage
were
then
harvested
14
DAT.

Levels
of
radioactivity
were
similar
for
the
[
Bz­
14C]
and
[
Val­
14C]­
labels
in
samples
from
each
test.
In
Test
I,
TRR
in
immature
potato
foliage
were
0.198­
0.330
ppm
12
days
after
a
single
foliar
application,
and
in
Test
II,
TRR
were
#
0.001
ppm
in
tubers
and
0.041­
0.078
ppm
in
foliage
harvested
90
days
following
a
single
soil
application.
In
Test
III,
TRR
were
0.003­
0.014
ppm
in
tubers
and
4.57­
5.86
ppm
in
foliage
harvested
14
days
following
the
last
of
six
foliar
applications.
The
low
level
of
radioactivity
in
tubers
from
Test
III
indicates
that
transport
of
the
14C­
residues
from
foliage
is
minimal.

For
analysis,
foliage
and
tuber
samples
were
extracted
sequentially
with
ACN,
water,
and
acetone.
The
initial
ACN
and
water
extractions
solubilized
82­
98%
of
the
TRR
from
tubers
and
foliage,
and
acetone
solubilized
another
0.5­
1.4%
of
the
TRR.
Unextractable
14C­
residues
accounted
for
1.2­
9.8%
of
the
TRR
from
foliage
and
17.5%
of
the
TRR
(<
0.003
ppm)
from
tubers.
14C­
Residues
in
the
ACN
and
water
extracts
were
cleaned
up
and
analyzed
by
HPLC
and/
or
TLC,
and
identities
of
the
parent
and
metabolites
were
confirmed
by
LC/
MS.

Following
a
single
foliar
application
to
immature
plants,
parent
(
65­
75%
TRR)
was
the
only
component
detected
in
foliage
14
DAT.
Following
a
single
postemergence
soil
application,
14C­
residues
in
tubers
were
too
low
for
analysis,
and
the
major
component
detected
in
foliage
(
90
DAT)
was
the
sugar
conjugate
Metabolite
1
(
28­
30%
TRR).
Parent
also
accounted
for
10­
11%
of
the
TRR
in
foliage
and
Metabolites
2,
3,
and
6
each
accounted
for
3­
17%
of
the
TRR
(
0.001­
0.011
ppm).
Following
the
last
of
six
broadcast
foliar
applications,
the
primary
component
identified
in
foliage
at
14
DAT
was
parent
(
88­
90%
TRR),
along
with
minor
amounts
of
Metabolites
1,
2,
and
6
(
0.8­
3.2%
TRR).
Treatment
with
$­
glucosidase
and
LC/
MS
analysis
identified
Metabolites
1,
2,
and
6,
and
sugar
conjugates
of
ring­
hydroxylated
metabolites.
In
tubers,
the
primary
metabolites
detected
were
Unknown
Metabolites
4
(
40%
TRR)
and
5
(
23%
TRR),
along
with
trace
amounts
of
parent
(
4.7%
TRR).
Treatment
with
$­
glucosidase
suggests
that
Metabolites
4
and
5
are
also
sugar
conjugates;
however,
concentrations
of
these
metabolites
were
too
low
(<
0.006
ppm)
for
additional
analysis.
Chiral
analysis
of
foliage
extracts
also
indicated
that
there
was
no
isomeric
conversion
of
the
active
R­
L
isomer
to
other
stereoisomers
(
S­
L,
R­
D,
or
S­
D).

Conclusions.
The
grape
and
tomato
metabolism
studies
are
adequate,
and
the
potato
metabolism
study
is
acceptable
pending
submission
of
supporting
storage
stability
data.
In
the
grape
and
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
10
of
28
potato
metabolism
studies,
which
used
both
[
Bz­
14C]
and
[
Val­
14C]­
labeled
benthiavalicarb,
metabolism
of
the
two
14C­
labels
was
qualitatively
and
quantitatively
similar,
indicating
that
the
parent
molecule
remains
relatively
intact.
In
grapes
and
tomatoes,
the
metabolism
of
benthiavalicarb
was
minimal
with
parent
being
the
only
major
14C­
residue
in
fruit
and
foliage.
Parent
was
also
the
principle
14C­
residue
in
potato
foliage,
but
other
metabolites
were
identified.
In
potatoes,
the
metabolism
of
benthiavalicarb
occurs
primarily
via
direct
hydroxylation
of
the
phenyl
ring
or
defluorination
and
hydroxylation
of
the
phenyl
ring.
Secondary
metabolism
occurs
via
conjugation
of
sugar
to
hydroxy
groups.
Although
two
major
(>
10%)
residues
were
observed
in
potato
tubers,
the
absolute
levels
of
these
metabolites
(
suggested
to
be
sugar
conjugates)
were
<
0.006
ppm.
Chiral
analysis
of
potato
foliage
extracts
also
indicates
that
there
was
no
isomeric
conversion
of
the
active
R­
L
isomer
to
other
possible
isomers
(
S­
L,
R­
D,
or
S­
D).

Based
on
the
results
of
the
metabolism
studies,
the
residues
of
concern
in
grapes
and
tomatoes
for
both
tolerance
expression
and
risk
assessment
are
the
combined
residues
of
the
R­
L
and
S­
L
isomers
of
benthiavalicarb.

860.1300
Nature
of
the
Residue
­
Livestock
The
RAC
and
processed
commodities
associated
with
the
proposed
uses
on
imported
grapes
and
tomatoes
will
not
be
used
as
significant
livestock
feed
items.
Therefore,
a
determination
of
the
nature
of
the
residue
in
livestock
is
not
required
for
this
petition.

860.1340
Residue
Analytical
Methods
­
Plants
45834905.
DER
(
includes
MRIDs
45834904,
45834905,
45834906,
and
45834907)

The
submitted
GC/
NPD
method
(
RCC
No.
665943)
is
adequate
for
determining
residues
of
both
the
R­
L
and
S­
L
stereoisomers
of
benthiavalicarb
in/
on
grapes
and
tomatoes
and
their
processed
commodities.
The
method
was
adequately
validated
prior
to,
and
in
conjunction
with,
the
submitted
field
trials
and
processing
studies.

For
this
method,
residues
are
extracted
from
grape
and
tomato
matrices
by
homogenizing
or
mixing
with
acetone.
After
filtering
the
extracts,
residues
are
solvent­
partitioned
into
n­
hexane
and
cleaned
up
using
an
amino
SPE
cartridge
eluted
with
hexane:
ethyl
acetate
(
1:
1,
v/
v).
The
purified
residues
are
then
analyzed
by
GC/
NPD.
The
two
stereoisomers
(
KIF­
230R­
L
and
KIF­
230S­
L)
are
determined
simultaneously
by
GC/
NPD
with
the
type
of
column
being
dependent
on
the
matrix.
For
each
matrix,
the
lower
limit
of
method
validation
(
LLMV)
is
0.01
ppm
for
each
isomer.
Although
the
submitted
reports
state
that
the
limit
of
quantitation
(
LOQ)
was
0.01
ppm,
an
inspection
of
the
chromatograms
indicates
that
the
LOQ
would
probably
be
in
the
range
of
0.002­
0.003
ppm.
The
reported
LOD
for
each
analyte
is
0.001
ppm
in/
on
grapes
and
0.002
ppm
in/
on
grape
juice,
raisins,
and
tomato
commodities.
In
many
cases
residue
values
were
reported
as
being
between
0.001
and
0.01
ppm
(
i.
e.,
actual
values
were
reported
as
0.002
ppm,
0.003
ppm,
etc.).
The
reporting
of
such
values
is
further
evidence
that
the
LOQ
is
indeed
below
0.01
ppm.
Benthiavalicarb­
isopropyl
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of
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Chemistry
and
Residue
Data
Barcode:
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11
of
28
In
the
main
method
validation
trials,
recoveries
of
KIF­
230R­
L
and
KIF­
230S­
L
from
whole
grapes,
juice,
raisins
and
wine
fortified
with
each
analyte
at
0.01­
2.0
ppm
averaged
79­
104%,
with
standard
deviations
of
2­
13%.
Recoveries
of
both
analytes
from
whole
tomatoes,
ketchup,
and
puree
fortified
at
0.01­
2.0
ppm
averaged
76­
103%,
with
standard
deviations
of
2­
14%.

This
GC/
NPD
method
is
also
being
proposed
for
tolerance
enforcement,
and
was
successfully
validated
in
an
independent
laboratory
validation
(
ILV)
trial
using
grapes,
tomatoes,
and
potatoes
fortified
with
each
isomer
at
0.01
and
0.10
ppm.
Radiolabeled
method
validation
data
were
not
provided
for
the
method,
but
these
data
are
not
required
given
the
similarity
between
the
extraction
procedures
in
the
proposed
method
and
the
extraction
procedures
used
in
the
metabolism
studies.

The
proposed
GC/
NPD
method
does
not
currently
include
a
confirmatory
method.
As
the
method
is
not
a
highly
specific
one,
such
as
GC/
MS,
the
registrant
should
either
submit
a
confirmatory
method
or
conduct
an
interference
study
using
other
pesticides
registered
on
grapes
and
tomatoes.

Conclusions.
Although
the
method
has
been
deemed
acceptable
for
data
collection,
the
petitioner
should
either
develop
a
confirmatory
method
for
the
analytes
of
interest
or
conduct
an
interference
study.
RAB2
recommends
that
before
any
further
tolerances
are
granted,
the
petitioner
be
required
to
develop
a
confirmatory
method
or
conduct
an
interference
study.
A
successful
ILV
has
already
been
conducted.
ACB
concluded
that
the
method
does
not
need
to
be
laboratory­
validated
by
EPA,
and
appears
to
be
suitable
for
tolerance
enforcement
(
Memo,
D321532,
P.
Schermerhorn,
2/
21/
2006).

860.1340
Residue
Analytical
Methods
­
Livestock
As
there
are
no
significant
livestock
feed
items
associated
with
the
proposed
uses
on
imported
grapes
and
tomatoes,
a
method
for
determining
residues
of
benthiavalicarb
in
animal
commodities
is
not
required
for
this
petition.

860.1360
Multiresidue
Methods
45834908.
DER
(
Multiresidue
Methods
Testing)
Benthiavalicarb
(
KIF­
230R­
L)
was
tested
using
FDA
Multiresidue
Method
Protocols
C,
D,
E
and
F.
The
compound
was
not
tested
through
Protocols
A,
B
and
G,
because
(
i)
it
is
not
naturally
fluorescent;
(
ii)
it
does
not
possess
an
N­
methylcarbamate,
acid,
or
phenol
structure;
and
(
iii)
it
is
not
a
substituted
urea.

Acceptable
GC
responses
were
obtained
under
Level
II
conditions
(
230
°
C)
using
a
DB­
1
column
with
ECD
or
ELCD­
X;
and
the
recovery
of
benthiavalicarb
using
Method
302
E1
(
without
cleanup)
from
fortified
tomatoes
was
complete
(>
80%)
at
0.1
ppm
or
partial
(
50­
80%)
at
0.5
ppm.
However,
matrix
interference
precluded
reliable
quantitation
of
the
analyte,
and
recovery
of
the
analyte
through
Florisil
column
cleanup
procedures
(
C1
and
C2)
was
low
(<
30%).
Therefore,
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
12
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28
the
FDA
multiresidue
methods
do
not
appear
to
be
suitable
for
analysis
of
benthiavalicarb.
The
submitted
data
will
be
forwarded
to
the
U.
S.
FDA
for
further
evaluation.

860.1380
Storage
Stability
45869705.
DER
(
Grape)
45869706.
DER
(
Tomato)

Grape
In
a
storage
stability
study,
grapevines
were
treated
once
with
KIF­
230
(
1.5
WDG)
as
a
foliar
application
at
0.040
lb
ai/
A
to
generate
field­
incurred
residues.
Grapes
were
harvested
21
DAT
and
a
single
control
and
duplicate
treated
subsamples
of
grapes
were
then
analyzed
to
establish
day­
zero
recoveries.
The
remaining
samples
were
stored
frozen
(<­
18
°
C)
for
up
to
395
days.
Grape
samples
were
extracted
and
analyzed
for
KIF­
230R­
L
and
KIF­
230S­
L
residues
after
storage
intervals
of
34,
94,
184,
366,
and
395
days.
Additional
control
samples
of
homogenized
grapes
were
fortified
with
KIF­
230R­
L
and
KIF­
230S­
L,
each
at
0.1
ppm,
and
analyzed
concurrently
with
the
stored
samples.

Samples
were
analyzed
for
residues
of
KIF­
230R­
L
and
KIF­
230S­
L
using
the
GC/
NPD
method
(
Method
RCC
665943)
described
in
the
above
analytical
method
section.
The
LLMV
is
0.01
ppm
for
each
isomer
in/
on
grapes,
and
the
method
was
adequately
validated
in
conjunction
with
the
sample
analyses.

The
average
residues
of
KIF­
230R­
L
in/
on
treated
grapes
(
corrected
for
the
concurrent
recovery)
were
initially
0.044
ppm
at
day
zero.
After
the
initial
34
days
of
frozen
storage,
there
was
an
apparent
decline
of
­
16%
with
average
corrected
residues
of
0.037
ppm
(
84%
of
initial
value).
However,
the
mean
corrected
residues
(
0.039
ppm)
at
the
last
sampling
interval
of
395
days
were
still
at
88%
of
the
initial
value,
indicating
stability
over
the
entire
storage
interval.
These
data
indicate
that
KIF­
230R­
L
is
stable
in
frozen
grapes
for
at
least
395
days.
The
stability
of
the
S­
L
isomer
could
not
be
ascertained
in
grapes,
as
residues
of
this
isomer
were
<
LLMV
in/
on
the
treated
grape
sample.

Tomato
In
a
storage
stability
study,
control
samples
of
homogenized
tomato
fruit
were
fortified
with
KIF­
230R­
L
and
KIF­
230S­
L,
each
at
0.2
ppm,
and
placed
in
frozen
(<­
18
°
C)
storage.
Stored
samples
were
analyzed
after
0,
7,
14,
30,
59,
90,
181,
and
251
days
of
storage.
At
each
interval,
duplicate
stored
samples
were
analyzed
for
KIF­
230R­
L
and
KIF­
230S­
L
along
with
a
control
sample
and
a
freshly
fortified
sample.

Samples
were
analyzed
for
residues
of
both
KIF­
230R­
L
and
KIF­
230S­
L
using
a
GC/
NPD
method
(
Method
RCC
665943)
which
was
adequately
validated
in
conjunction
with
the
sample
analyses.
The
LLMV
is
0.01
ppm
for
each
isomer
in/
on
tomatoes;
the
LOD
is
0.002
ppm.
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
13
of
28
Residues
of
KIF­
230R­
L
and
KIF­
230S­
L
were
stable
in/
on
tomato
fruit
for
up
to
251
days.
Mean
corrected
recoveries
ranged
from
86­
120%
for
KIF­
230R­
L
and
from
75­
105%
for
KIF­
230S­
L
from
all
storage
intervals,
with
no
indication
of
decline
over
the
entire
storage
interval.

Conclusions.
The
storage
stability
data
are
adequate
and
indicate
that
benthiavalicarb
is
stable
under
frozen
(#­
18
°
C)
conditions
in
grapes
for
at
least
13
months
and
in
tomatoes
for
at
least
8
months.
Samples
of
grapes
and
tomatoes
from
the
crop
field
trials
were
stored
frozen
for
a
maximum
of
7
months
and
8
months,
respectively.
Storage
stability
data
for
processed
grape
and
tomato
commodities
are
not
available.
These
data
are
not
required
for
the
current
tolerance
requests
because
acceptable
storage
stability
data
were
submitted
for
grapes
and
tomatoes.
Residues
were
stable
in
grapes
for
13
months
and
in
tomatoes
for
8
months.
In
the
tomato
storage
stability
studies,
tomatoes
were
homogenized
prior
to
storage.
Homogenized
tomatoes
are
comparable
in
both
composition
and
texture
to
processed
tomato
commodities.
The
matrix
is
an
acidic
one
which
would
very
likely
maximize
residue
decay.
As
a
result,
the
tomato
data
are
considered
adequate
to
demonstrate
storage
stability
in
processed
grape
commodities
as
well.
Samples
from
the
processing
studies
were
stored
frozen
for
a
maximum
of
8
months.

860.1480
Meat,
Milk,
Poultry,
and
Eggs
The
RAC
and
processed
commodities
associated
with
the
proposed
uses
on
imported
grapes
and
tomatoes
will
not
be
used
as
significant
livestock
feed
items.
Therefore,
residue
data
for
benthiavalicarb
in
animal
commodities
is
not
required
for
this
petition.

860.1500
Crop
Field
Trials
45869707.
DER1
(
Grape)
45869711.
DER1
(
Tomato)
45869708.
DER1
(
Grape)
45869712.
DER
(
Tomato)
45869709.
DER
(
Grape)
45869713.
DER1
(
Tomato)
45869710.
DER
(
Grape)

The
petitioner
has
submitted
crop
field
trial
data
from
throughout
the
EU
on
grapes
as
well
as
both
field­
grown
and
greenhouse­
grown
tomatoes
to
support
tolerances
on
imported
grape
and
tomato
commodities.
The
results
of
the
grape
and
tomato
field
trials
are
summarized
in
Table
4
and
discussed
below.
Table
4
also
provides
a
summary
of
the
residue
decline
studies
in
which
samples
were
taken
at
the
following
PHIs
(
in
days):
0,
7,
14,
21,
and
28
(
approximately).
The
proposed
PHI
is
28
days.
Table
8
provides
the
individual
field
trial
residue
values
used
to
determine
the
recommended
tolerances
for
grapes
and
tomatoes.

In
all
grape
and
tomato
field
trials,
the
GC/
NPD
method
RCC
665943
was
used
for
determination
of
both
benthiavalicarb
isomers
(
KIF­
230R­
L
and
KIF­
230S­
L).
The
method
was
adequately
validated
in
conjunction
with
the
sample
analyses.
The
lower
limit
of
method
validation
(
LLMV)
is
0.01
ppm
for
each
isomer
in
all
commodities.
The
reported
LOD
for
each
isomer
is
0.001
ppm
in/
on
grapes
and
0.002
in
tomatoes.
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
14
of
28
Table
4.
Summary
of
Residue
Data
from
the
Crop
Field
Trials
using
Benthiavalicarb
(
WDG)

Commodity
Formulation
Total
Rate
(
lb
a.
i./
A)
1
PHI
(
days)
2
Combined
Benthiavalicarb
Residue
Levels
(
ppm)
3
n
Min.
Max.
HAFT
4
Median
(
STMdR5)
Mean
(
STMR5)
Std.
Dev.

Grapes:
45869707.
DER1,
45869708.
DER1,
45869709.
DER,
45869710.
DER
Grapes
1.75%
WDG
0.182­
0.195
0
22
<
0.031
0.243
NA
0.066
0.088
0.055
2­
3
4
0.050
0.081
NA
0.073
0.069
0.015
7­
8
22
0.024
0.168
NA
0.056
0.070
0.043
14
22
0.002
0.195
NA
0.049
0.055
0.040
20­
21
22
<
0.008
0.157
NA
0.040
0.049
0.036
26­
296
50
<
0.012
0.269
0.22
0.051
0.070
0.050
Grapes:
45869709.
DER
(
Decline
Studies)

Grapes
Decline
Studies
1.75%
WDG
0.185­
0.191
0
7
0.032
0.212
NA
0.086
0.093
0.057
7
7
0.024
0.168
NA
0.059
0.072
0.074
14
7
0.002
0.195
NA
0.060
0.073
0.047
21
7
0.018
0.157
NA
0.040
0.063
0.059
26­
29
7
0.012
0.161
NA
0.039
0.058
0.050
Tomatoes:
45869711.
DER1
Tomatoes
(
Greenhouse)
15%
WDG
0.398­
0.404
0
4
<
0.052
<
0.158
NA
0.119
0.112
0.049
1
4
<
0.025
<
0.163
NA
0.089
0.091
0.057
3
4
<
0.041
<
0.141
NA
0.105
0.098
0.043
7
4
<
0.043
<
0.137
NA
0.094
0.092
0.039
Tomatoes
(
Field)
15%
WDG
0.400­
0.404
0
3
<
0.019
<
0.060
NA
0.037
0.039
0.021
1
3
<
0.021
<
0.051
NA
0.022
0.031
0.017
3
3
<
0.004
<
0.024
NA
0.016
0.015
0.010
7
3
<
0.004
<
0.015
NA
0.004
0.008
0.006
Tomatoes:
45869712.
DER
Tomatoes
(
Greenhouse)
1.75%
WDG
0.185­
0.193
0
2
0.047
0.048
NA
0.048
0.048
NA
3
2
0.033
0.037
NA
0.035
0.035
NA
7
2
0.033
0.044
NA
0.039
0.039
NA
14
2
0.022
0.048
NA
0.035
0.035
NA
Tomatoes
(
Field)
1.75%
WDG
0.187
0
1
NA
NA
NA
0.013
0.013
NA
3
1
NA
NA
NA
0.012
0.012
NA
7
1
NA
NA
NA
0.004
0.004
NA
14
1
NA
NA
NA
0.004
0.004
NA
Tomatoes:
45869713.
DER1
Tomatoes
(
Greenhouse)
15%
WDG
0.388­
0.413
3
10
<
0.044
0.27
0.23
0.072
0.12
0.09
1
The
target
rates
were
0.031
lb
ai/
A/
application
and
0.187
lb
ai/
A/
season
for
grapes
and
tomatoes
using
the
1.75%
WDG
(
MAI
with
70%
Mancozeb),
and
0.067
lb
ai/
A/
application
and
0.40
lb
ai/
A/
season
for
tomatoes
using
the
15%
WDG.
2
The
proposed
PHIs
for
tomatoes
are
3
days
for
greenhouse
treatments
and
7
days
for
field
treatments.
The
proposed
PHI
for
grapes
is
28
days.
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
15
of
28
3
The
LLMV
is
0.01
ppm
for
each
isomer
in/
on
all
commodities.
The
LOD
was
0.001
ppm
in/
on
grapes;
the
LOD
in/
on
tomatoes
was
0.002
ppm.
For
calculation
of
the
median,
mean,
and
standard
deviation,
the
LOD
was
used
for
samples
with
residues
<
LOD.
4
HAFT
=
Highest
Average
Field
Trial.
For
tests
marked
NA,
HAFT
residues
were
not
calculated,
as
only
a
single
sample
was
harvested
at
each
interval
from
each
test.
5
STMdR
=
Supervised
Trial
Median
Residue;
STMR
=
Supervised
Trial
Mean
Residue.
6
Bolded
residue
values
are
for
samples
from
field
trials
conducted
at
1x
the
maximum
use
rate
and
harvested
at
the
proposed
minimum
PHI.

Grape
45869707.
DER1
In
four
grape
field
trials
conducted
in
Europe
(
France
and
Italy)
during
1998,
KIF­
230
(
1.75%
WDG)
was
applied
as
six
broadcast
foliar
applications
to
grapes
at
0.030­
0.033
lb
ai/
A,
for
a
total
of
0.187­
0.193
lb
ai/
A/
season.
In
each
test,
the
first
application
was
made
when
plants
were
at
the
BBCH
73­
77
stage,
and
subsequent
applications
were
made
at
retreatment
intervals
(
RTI)
of
9­
12
days.
Grapes
were
harvested
at
commercial
maturity,
0,
2­
3,
7­
8,
14,
and
20­
21
DAT
from
all
tests.
In
each
test,
one
treated
sample
and
one
untreated
control
sample
were
collected.
Samples
were
stored
frozen
from
collection
to
analysis
for
up
to
7
months,
an
interval
supported
by
available
stability
data.

KIF­
230R­
L
residues
were
0.039­
0.057
ppm
in/
on
4
grape
samples
harvested
0
DAT,
0.044­
0.073
ppm
in/
on
4
samples
harvested
2­
3
DAT,
0.023­
0.046
ppm
in/
on
4
samples
harvested
7­
8
DAT,
0.018­
0.038
ppm
in/
on
4
samples
harvested
14
DAT,
and
0.007­
0.049
ppm
in/
on
4
samples
harvested
20­
21
DAT.
KIF­
230S­
L
residues
were
#
0.014
ppm
in
all
grape
samples
from
all
sampling
intervals.
Residues
below
the
LOD
of
0.001
ppm
were
estimated
to
be
0.001
ppm
for
calculation
of
the
combined
residues.
Combined
residues
were
<
0.040­
0.065
ppm
in/
on
0
DAT
samples,
0.050­<
0.081
ppm
in/
on
­
3
DAT
samples,
0.027­
0.054
ppm
in/
on
­
7
DAT
samples,
<
0.019­<
0.039
ppm
in/
on
14
DAT
samples,
and
<
0.008­<
0.050
ppm
in/
on
­
21
DAT
samples.
Following
an
initial
increase
in
residues
between
0
and
3
DAT,
residues
declined
at
longer
sampling
intervals.
Average
combined
residues
were
0.053
ppm
at
0
DAT,
0.069
ppm
at
­
3
DAT,
0.038
ppm
at
­
7
DAT,
0.026
ppm
at
14
DAT,
and
0.024
ppm
at
­
21
DAT.

45869708.
DER1
Eight
field
tests
were
conducted
in
Europe
during
1999,
with
2
tests
each
in
France,
Germany,
Italy,
and
Spain.
In
each
test,
benthiavalicarb
(
1.75%
WDG)
was
applied
to
grapes
as
six
broadcast
foliar
applications
at
0.029­
0.034
lb
ai/
A,
for
a
total
of
0.184­
0.195
lb
ai/
A/
season.
In
each
test,
the
first
application
was
made
when
plants
were
at
the
BBCH
73­
80
stage,
approximately
78
days
prior
to
harvest,
and
subsequent
applications
were
made
at
retreatment
intervals
of
9­
11
days.
Grapes
were
collected
at
commercial
maturity
28
DAT
from
all
test
locations,
and
additional
grape
samples
were
collected
at
0,
7,
14,
and
21
DAT
from
five
test
locations
to
examine
residue
decline.
One
or
two
treated
samples
of
grapes
along
with
one
untreated
control
sample
were
collected
from
each
test.
Samples
were
stored
frozen
from
collection
to
analysis
for
up
to
5
months,
an
interval
supported
by
available
stability
data.

KIF­
230R­
L
residues
were
0.030­
0.136
ppm
in/
on
5
grape
samples
harvested
0
DAT,
0.039­
0.158
ppm
in/
on
5
samples
harvested
7
DAT,
0.025­
0.109
ppm
in/
on
5
samples
harvested
14
DAT,
0.031­
0.109
ppm
in/
on
5
samples
harvested
21
DAT,
and
0.022­
0.120
ppm
in/
on
11
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
16
of
28
samples
harvested
28
DAT.
KIF­
230S­
L
residues
were
#
0.008
ppm
in
all
grape
samples
from
all
sampling
intervals.
Residues
below
the
LOD
of
0.001
ppm
were
estimated
to
be
0.001
ppm
for
calculation
of
the
combined
residues.

Combined
residues
were
0.040­
0.146
ppm
in/
on
0
DAT
samples,
0.040­
0.164
ppm
in/
on
7
DAT
samples,
<
0.026­
0.113
ppm
in/
on
14
DAT
samples,
0.032­
0.115
ppm
in/
on
21
DAT
samples,
and
0.023­
0.125
ppm
in/
on
28
DAT
samples.
Average
combined
residues
in/
on
grapes
were
0.092
ppm
at
0
DAT,
0.085
ppm
at
7
DAT,
0.063
ppm
at
14
DAT,
0.060
ppm
at
21
DAT,
and
0.058
ppm
at
28
DAT.
The
HAFT
residue
value
from
the
28
DAT
samples
was
0.114
ppm.

45869709.
DER
In
14
grape
field
tests
conducted
in
Europe
(
France,
Germany,
Greece,
Italy,
and
Spain)
during
2000,
KIF­
230
(
1.75%
WDG)
was
applied
as
six
broadcast
foliar
applications
to
grapes
at
0.029­
0.035
lb
ai/
A,
for
a
total
of
0.185­
0.191
lb
ai/
A/
season.
In
each
test,
the
first
application
was
made
when
plants
were
at
the
BBCH
75­
79
stage,
approximately
78
days
prior
to
normal
harvest,
and
subsequent
applications
were
made
at
retreatment
intervals
(
RTIs)
of
9­
11
days.
Grapes
were
collected
26­
29
DAT
from
all
test
locations.
Additional
grapes
were
collected
0,
7­
8,
14­
15,
and
20­
22
DAT
from
seven
test
locations
to
determine
residue
decline.
A
single
control
and
a
single
or
duplicate
treated
samples
of
grape
bunches
were
collected
from
each
test.
Samples
were
stored
frozen
from
collection
to
analysis
for
up
to
3
months,
an
interval
supported
by
available
stability
data.

KIF­
230R­
L
residues
were
0.011­
0.21
ppm
and
KIF­
230S­
L
residues
were
<
0.001­
0.061
ppm
in/
on
21
grape
samples
harvested
26­
29
DAT.
Residues
<
LOD
were
estimated
to
be
0.001
ppm
for
calculation
of
the
combined
residues.
Combined
residues
were
<
0.012­
0.27
ppm
in/
on
­
28
DAT
samples.
Average
combined
residues
at
­
28
DAT
were
0.091
ppm,
with
a
HAFT
residue
value
of
0.22
ppm.
In
the
seven
decline
tests,
average
combined
residues
declined
from
0.093
ppm
at
0
DAT
to
0.058
ppm
by
­
28
DAT.

45869710.
DER
In
twelve
grape
field
trials
that
were
conducted
in
Europe
(
France,
Germany,
Greece,
Italy,
and
Spain)
during
2000,
KIF­
230
(
1.75%
WDG)
was
applied
as
six
broadcast
foliar
applications
to
grape
vines
at
0.029­
0.037
lb
ai/
A,
for
a
total
of
0.182­
0.193
lb
ai/
A/
season.
In
each
test,
the
first
application
was
made
when
plants
were
at
the
BBCH
76­
79
stage,
approximately
73­
79
days
prior
to
harvest,
and
subsequent
applications
were
made
at
retreatment
intervals
(
RTIs)
of
9­
11
days.
Grapes
were
harvested
from
each
test
at
26­
28
DAT,
and
additional
samples
were
collected
at
0,
7,
14,
20­
21
DAT
from
six
tests
to
examine
residue
decline.
A
single
or
duplicate
treated
samples
were
collected
from
each
test
along
with
an
untreated
control
sample.
Samples
were
stored
frozen
from
collection
to
analysis
for
up
to
3
months,
an
interval
supported
by
available
stability
data.

At
26­
28
DAT,
residues
of
KIF­
230R­
L
were
0.005­
0.11
ppm
and
residues
of
KIF­
230S­
L
were
<
0.001
ppm
in/
on
18
grape
samples.
Residues
<
LOD
were
estimated
to
be
0.001
ppm
for
calculation
of
the
combined
residues.
Combined
residues
were
<
0.006­
0.12
ppm.
Average
combined
residues
were
0.053
ppm
in/
on
grapes
harvested
26­
28
DAT
and
HAFT
residues
were
Benthiavalicarb­
isopropyl
Summary
of
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and
Residue
Data
Barcode:
D322934
17
of
28
0.109
ppm.
In
the
decline
tests,
the
average
combined
residues
declined
from
0.101
ppm
at
0
DAT
to
0.046
ppm
by
14
DAT;
average
combined
residues
then
remained
relatively
steady
from
14­
28
DAT
(
0.046­
0.053
ppm).

Residue
Decline
in
Grapes
Overall,
22
grape
field
trials
were
performed
in
which
samples
were
taken
at
1­
week
intervals.
The
samples
were
taken
at
0,
7,
14,
21,
and
28
DAT.
In
four
of
those
trials,
samples
were
not
taken
at
28
days.
Average
residues
declined
as
follows:
0.088
ppm,
0.070
ppm,
0.055
ppm,
0.049
ppm,
and
0.046
ppm
at
0,
7,
14,
21,
and
28
days,
respectively.
Residues
declined
by
0.018
ppm,
0.015
ppm,
0.006
ppm,
and
0.003
ppm
over
the
four
intervals.
In
effect,
residues
declined
with
the
greatest
decreases
occurring
in
the
early
stages
of
the
field
trials.

Tomatoes
45869711.
DER1
In
seven
tomato
trials
(
4
greenhouse
and
3
field)
conducted
in
Europe
during
1999,
benthiavalicarb
(
15%
WDG)
was
applied
as
six
broadcast
foliar
applications
at
0.064­
0.070
lb
ai/
A/
application,
for
a
total
of
0.398­
0.404
lb
ai/
A/
season.
The
first
application
was
made
beginning
at
BBCH
60­
89
growth
stages,
and
retreatment
intervals
(
RTIs)
were
7­
8
days.
A
single
control
and
treated
sample
were
collected
from
each
test
at
0,
1,
3,
and
7­
8
DAT.
Samples
were
stored
frozen
(#­
18
°
C)
for
a
maximum
of
243
days,
an
interval
that
is
supported
by
the
available
storage
stability
data.

In
the
greenhouse
trials,
maximum
combined
residues
were
<
0.158
ppm,
<
0.163
ppm,
<
0.141
ppm,
and
<
0.137
ppm
at
0,
1,
3,
and
7
DAT,
respectively.
Average
combined
residues
were
0.112,
0.091,
0.098,
and
0.092
ppm
at
0,
1,
3,
and
7
DAT,
respectively.
In
the
outdoor
field
trials,
maximum
combined
residues
in/
on
tomatoes
were
<
0.060
ppm
at
0
DAT,
<
0.051
ppm
at
1
DAT,
<
0.024
ppm
at
3
DAT,
and
<
0.015
ppm
at
7
DAT.
Average
combined
residues
were
0.039,
0.031,
0.015,
and
0.008
ppm
at
0,
1,
3,
and
7
DAT,
respectively.
Residues
<
LOD
were
estimated
to
be
0.002
ppm
for
calculation
of
the
combined
residues.
Residue
levels
in/
on
tomatoes
were
higher
in
the
greenhouse
trials
than
in
the
outdoor
field
trials.
Residue
levels
in
greenhouse­
grown
tomatoes
remained
relatively
steady
over
time
(
0­
7
DAT),
whereas
residue
levels
in
field­
grown
tomatoes
declined
steadily
over
time.

45869712.
DER
In
three
trials
(
two
greenhouse
and
one
field)
on
tomatoes
conducted
in
France
and
the
Netherlands
during
1999,
benthiavalicarb
(
1.75%
WDG)
was
applied
as
six
broadcast
foliar
applications
at
0.030­
0.033
lb
ai/
A/
application,
for
a
total
of
0.185­
0.193
lb
ai/
A/
season,
beginning
at
BBCH
60­
89
growth
stages,
at
retreatment
intervals
(
RTIs)
of
7
days.
Single
control
and
treated
samples
were
collected
for
analysis
from
each
test
at
0,
3,
7,
and
14
DAT.
Samples
were
stored
frozen
(#­
18
°
C)
for
a
maximum
of
231
days,
an
interval
that
is
supported
by
the
available
storage
stability
data.

Detectable
residues
of
KIF­
230R­
L
were
found
in
both
the
field
and
greenhouse
trials;
however,
residues
of
KIF­
230S­
L
were
<
LOD
in
all
samples.
In
the
two
greenhouse
trials,
average
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
18
of
28
combined
residues
at
the
various
PHIs
are
as
follows:
0.048
ppm
(
0­
day),
0.035
ppm
(
3­
day),
0.039
ppm
(
7­
day),
and
0.035
ppm
(
14­
day).
In
the
outdoor
field
trials,
combined
residues
are
as
follows:
0.013
ppm
(
0­
day),
0.012
ppm
(
3­
day),
0.004
ppm
(
7­
day),
and
0.004
ppm
(
14­
day).
Residues
<
LOD
were
estimated
to
be
0.002
ppm
for
calculation
of
the
combined
residues.
In
both
trials,
residues
appear
to
have
decayed
slightly
over
time.

45869713.
DER1
Five
tomato
greenhouse
trials
were
conducted
during
2000
in
Europe
(
France,
Italy,
Spain,
Greece,
and
the
Netherlands).
In
each
test,
benthiavalicarb
(
15%
WDG)
was
applied
as
six
broadcast
foliar
applications
at
0.062­
0.070
lb
ai/
A/
application,
for
a
total
of
0.388­
0.413
lb
ai/
A/
season,
beginning
approximately
40
days
prior
to
harvest
with
retreatment
intervals
(
RTIs)
of
6­
8
days.
Two
treated
and
one
untreated
control
sample
were
collected
for
analysis
from
each
test
at
3
DAT.
Samples
were
stored
frozen
(#­
18
°
C)
for
a
maximum
of
52
days,
an
interval
that
is
supported
by
the
available
storage
stability
data.

In
the
five
greenhouse
trials,
residues
of
KIF­
230R­
L
were
0.04­
0.25
ppm
in/
on
10
tomato
samples
harvested
at
3
DAT,
and
KIF­
230S­
L
residues
were
#
0.014
ppm
in/
on
the
same
samples,
for
combined
residues
of
<
0.044­
0.27
ppm.
Average
combined
residues
were
0.12
ppm
and
the
HAFT
residue
value
was
0.23
ppm.
Residues
<
LOD
were
estimated
to
be
0.002
ppm
for
calculation
of
the
combined
residues.

Conclusions.
The
available
field
trial
data
are
adequate
and
will
support
the
proposed
use
patterns
on
grapes
and
tomatoes
imported
from
the
EU
into
the
U.
S.
The
number
and
geographic
distribution
of
the
field
trials
are
adequate,
and
the
appropriate
samples
were
collected
at
the
proposed
PHIs.
The
samples
were
analyzed
using
an
adequate
analytical
method,
and
the
sample
storage
intervals
are
supported
by
the
available
storage
stability
data.

For
grapes,
a
total
of
34
field
tests
were
conducted
in
which
grapes
were
treated
at
1x
the
maximum
proposed
rate
(
0.19
lb
ai/
A/
season)
and
harvested
(
approximately)
at
the
proposed
minimum
PHI
of
28
days.
These
tests
were
conducted
during
1999­
2000
throughout
the
EU
in
France
(
17
tests),
Germany
(
7
tests),
Italy
(
4
tests),
Spain
(
4
tests),
and
Greece
(
2
tests).
Combined
residues
were
<
0.006­
0.269
ppm
in/
on
50
grape
samples
collected
from
these
tests
at
28
DAT,
and
average
combined
residues
were
0.070
ppm
with
a
standard
deviation
of
0.050
ppm.
The
HAFT
residue
value
was
0.22
ppm.
In
residue
decline
tests,
residues
declined
over
time
with
the
greatest
decreases
occurring
early
in
the
field
trials.

For
tomatoes,
twelve
tests
were
conducted
during
1999­
2000
at
1x
the
maximum
proposed
use
rate
of
0.40
lb
ai/
A/
season.
Nine
of
the
tests
were
greenhouse
trials
conducted
in
France
(
2
tests),
Italy
(
2
tests),
Spain
(
2
tests),
the
Netherlands
(
2
tests)
and
Greece
(
1
test),
and
the
remaining
3
tests
were
field
trials
conducted
in
France,
Italy
and
Spain.
Although
the
number
of
field
tests
was
limited,
the
lower
PHI
for
greenhouse­
grown
tomatoes
(
3
days)
and
the
available
data
indicate
that
residues
are
higher
on
greenhouse
tomatoes;
therefore,
greenhouse
tomato
data
will
be
used
for
tolerance
assessment.
In
the
greenhouse
tests
conducted
at
1x,
combined
residues
were
<
0.041­
0.27
ppm
in/
on
14
tomato
samples
collected
3
DAT.
Average
combined
residues
were
0.11
ppm
with
a
standard
deviation
of
0.076
ppm,
and
the
HAFT
residue
was
0.23
ppm.
In
the
field
tests
conducted
at
1x,
combined
residues
were
<
0.015
ppm
in/
on
3
tomato
samples
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
19
of
28
collected
7
DAT.
Average
combined
residues
were
0.0077
ppm
with
a
standard
deviation
of
0.006
ppm.
Only
one
sample
was
collected
in
each
trial;
therefore,
a
HAFT
residue
value
was
not
calculated.
The
maximum
combined
residues
in/
on
any
field­
grown
tomatoes
from
a
1x
test
were
<
0.060
ppm
at
0
DAT.

Based
on
the
results
of
HED's
statistical
tolerance
generator
for
NAFTA­
harmonized
tolerances,
HED
finds
that
tolerances
of
0.25
ppm
for
grape
and
0.45
ppm
for
tomato
are
appropriate.

860.1520
Processed
Food
and
Feed
The
petitioner
has
submitted
data
from
nine
grape
processing
studies
and
four
tomato
processing
studies
to
support
tolerances
on
imported
grape
and
tomato
processed
commodities.
The
results
of
the
grape
and
tomato
processing
studies
are
discussed
below
and
summarized
in
Tables
5
and
6.
Only
processing
studies
using
RAC
samples
with
readily
quantifiable
residues
were
used
for
calculating
average
processing
factors.

The
GC/
NPD
method
RCC
665943
was
used
to
determine
residues
of
both
benthiavalicarb
isomers
(
KIF­
230R­
L
and
KIF­
230S­
L)
in
grape
and
tomato
commodities.
The
method
was
adequately
validated
in
conjunction
with
the
sample
analyses.
The
lower
limit
of
method
validation
(
LLMV)
for
all
grape
and
tomato
commodities
is
0.01
ppm
for
each
isomer.
For
both
isomers
the
LODs
are
0.001
ppm
for
grapes
and
0.002
ppm
for
processed
grape
commodities,
tomatoes,
and
processed
tomato
commodities.

Grapes
Table
5.
Residue
Data
from
Grape
Processing
Studies
with
Benthiavalicarb
(
WDG).

Trial
ID
(
City,
Country,
Year)
Commodity
Total
Rate
(
lb
ai/
A)
PHI
(
days)
Residues
(
ppm)
1
Processing
Factor
2
KIF­
230R­
L
KIF­
230S­
L
Combined
45869707.
DER2
Panzult,
France,
1998
Grape
(
RAC)
0.190
21
0.049
ND
<
0.050
Raisins
0.095
0.067
0.162
3.24
Juice
0.012
0.003
0.015
0.30
Must
0.017
0.003
0.020
0.40
Wine
0.020
0.005
0.025
0.50
Rochecorbon,
France,
1998
Grape
(
RAC)
0.193
20
0.013
ND
<
0.014
Raisins
0.078
0.042
0.120
8.57
Juice
0.014
0.003
0.017
1.21
Must
0.012
ND
0.014
1.00
Wine
0.017
0.003
0.020
1.43
Piacenza,
Italy,
1998
Grape
(
RAC)
0.187
21
0.023
ND
<
0.023
Raisins
0.074
0.019
0.093
3.88
Juice
0.010
0.003
0.013
0.54
Must
0.014
0.003
0.017
0.71
Wine
0.019
0.003
0.022
0.92
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
Table
5.
Residue
Data
from
Grape
Processing
Studies
with
Benthiavalicarb
(
WDG).

Trial
ID
(
City,
Country,
Year)
Commodity
Total
Rate
(
lb
ai/
A)
PHI
(
days)
Residues
(
ppm)
1
Processing
Factor
2
KIF­
230R­
L
KIF­
230S­
L
Combined
20
of
28
45869708.
DER2
Forges,
France,
1999
Grape
(
RAC)
0.191
28
0.018
ND
<
0.019
Juice
ND
ND
<
0.004
0.21
Raisins
0.020
0.015
0.035
1.84
Must
0.015
ND
<
0.017
0.89
Wine
0.012
ND
<
0.014
0.74
Lugasson,
France,
1999
Grape
(
RAC)
0.188
28
0.023
ND
<
0.024
Juice
0.010
ND
<
0.012
0.50
Raisins
0.082
0.052
0.134
5.58
Must
0.045
ND
<
0.047
1.96
Wine
0.043
0.004
0.047
1.96
Kleinkarlbach,
Germany,
1999
Grape
(
RAC)
0.195
28
0.070
ND
0.071
Juice
0.014
ND
0.016
0.23
Raisins
0.130
0.033
0.163
2.30
Must
0.071
ND
0.073
1.03
Wine
0.050
0.004
0.054
0.76
Salerano,
Italy,
1999
Grape
(
RAC)
0.193
28
0.046
ND
0.047
Juice
0.017
ND
0.019
0.40
Raisins
0.053
0.013
0.066
1.40
Must
0.073
ND
0.075
1.60
Wine
0.041
0.003
0.044
0.94
Monserrat,
Spain,
1999
Grape
(
RAC)
0.186
28
0.052
ND
0.053
Juice
0.018
ND
0.020
0.38
Raisins
0.088
0.049
0.137
2.58
Must
0.017
ND
0.019
0.36
Wine
0.027
(
0.002)
0.029
0.55
1
The
LLMV
is
0.01
ppm,
the
LOD
was
0.001
ppm
for
grapes
and
0.002
ppm
for
processed
grape
commodities.
Residues
<
LOD
were
estimated
to
be
0.001
ppm
in
grapes
and
0.002
ppm
for
processed
commodities
for
calculation
of
the
combined
residues.
2
The
processing
factor
was
calculated
using
the
combined
residues
in
the
grape
RAC
and
processed
fractions.
NA=
not
applicable;
ND
=
not
detected.

45869707.
DER2
In
four
grape
processing
tests
conducted
in
Europe
during
1998,
benthiavalicarb
(
1.75%
WDG)
was
applied
to
grapes
during
fruit
development
as
six
broadcast
foliar
applications
at
0.030­
0.033
lb
ai/
A/
application,
at
retreatment
intervals
(
RTIs)
of
9­
12
days,
for
a
total
of
0.187­
0.193
lb
ai/
A/
season.
Grapes
were
harvested
at
­
21
DAT.
A
single
grape
RAC
sample
was
collected
from
each
test
and
the
remaining
bulk
samples
were
processed
into
raisins,
juice,
must,
and
wine
using
simulated
commercial
procedures.
Prior
to
analysis,
grapes
and
processed
grape
matrix
samples
were
stored
frozen
for
a
maximum
of
237
days.
Although
data
are
available
supporting
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
21
of
28
the
stability
of
residues
in
grapes
for
up
to
13
months,
stability
data
are
not
available
for
residues
in
processed
grape
fractions.

Combined
residues
of
KIF­
230R­
L
and
KIF­
230S­
L
were
<
0.008
­
<
0.050
ppm
in/
on
4
grape
RAC
samples
harvested
at
20­
21
DAT.
As
residues
of
both
analytes
were
<
LLMV
in
one
test,
processing
factors
were
calculated
using
data
from
only
three
of
the
tests.
After
processing,
combined
residues
were
0.047­
0.162
ppm
in
raisins,
0.012
­
0.017
ppm
in
juice,
<
0.008
­
0.020
ppm
in
must,
and
0.014
­
0.025
ppm
in
wine.
In
the
3
studies
used
for
processing
factor
establishment,
the
processing
factors
are
as
follows:
3.2,
3.9,
and
8.6x
for
raisins,
0.30,
0.54,
and
1.2x
for
juice,
0.40,
0.71,
and
1.0x
for
must,
and
0.50,
0.92,
and
1.8x
for
wine.

45869708.
DER2
In
five
grape
processing
tests
conducted
in
Europe
(
France,
Germany,
Italy,
and
Spain)
during
1999,
benthiavalicarb
(
1.75%
WDG)
was
applied
to
grapes
during
fruit
development
as
six
broadcast
foliar
applications
at
0.029­
0.034
lb
ai/
A/
application,
at
retreatment
intervals
(
RTIs)
of
9­
11
days,
for
a
total
of
0.186­
0.195
lb
ai/
A/
season.
Grapes
were
collected
at
commercial
maturity,
28
days
after
the
last
treatment
(
DAT).
A
single
grape
RAC
sample
was
collected
from
each
test,
and
the
remaining
bulk
samples
were
processed
into
raisins,
juice,
must,
and
wine
using
simulated
commercial
procedures.
Prior
to
analysis,
grapes
and
processed
grape
commodities
were
stored
frozen
for
a
maximum
of
140
days.
Although
data
are
available
supporting
the
stability
of
residues
in
grapes
for
up
to
13
months,
stability
data
are
not
available
for
residues
in
processed
grape
fractions.

Residues
of
KIF­
230R­
L
were
0.018­
0.070
ppm
and
residues
of
KIF­
230S­
L
were
nondetectable
(<
0.001
ppm)
in/
on
grape
RAC
samples
harvested
28
DAT
from
all
five
tests,
for
combined
residues
of
<
0.019
­
0.071
ppm.
For
the
processed
fractions,
KIF­
230R­
L
residues
were
quantifiable
in
all
samples
with
the
exception
of
one
juice
sample,
and
KIF­
230S­
L
residues
were
below
the
LLMV
in
all
commodities
except
raisins.
Combined
residues
were
0.035­
0.163
ppm
in/
on
raisins,
<
0.020­<
0.028
ppm
in
juice,
<
0.025­<
0.083
ppm
in
must,
and
<
0.022­<
0.060
in
wine.
Processing
factors
were
1.4
­
5.6x
for
raisins,
0.21
­
0.50x
for
juice,
0.36
­
2.0x
for
must,
and
0.55
­
2.0x
for
wine.

Tomatoes
Table
6.
Residue
Data
from
Tomato
Processing
Studies
with
Benthiavalicarb
(
WDG).

Trial
ID
(
City,
Country,
Year)
Processed
Commodity
Total
Rate
(
lb
ai/
A)
PHI
(
days)
Residues
(
ppm)
1
Processing
Factor
2
KIF­
230R­
L
KIF­
230S­
L
Combined
45869711.
DER2
Almusafes,
Spain,
1999
Tomato
(
RAC)
0.40
3
0.152
0.004
0.156
Peeled
tomatoes
<
0.01
<
0.002
<
0.007
0.045
Juice
0.054
<
0.002
<
0.056
0.359
Wet
pomace
0.085
0.003
0.088
0.564
Dry
pomace
0.943
0.046
0.989
6.34
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
Table
6.
Residue
Data
from
Tomato
Processing
Studies
with
Benthiavalicarb
(
WDG).

Trial
ID
(
City,
Country,
Year)
Processed
Commodity
Total
Rate
(
lb
ai/
A)
PHI
(
days)
Residues
(
ppm)
1
Processing
Factor
2
KIF­
230R­
L
KIF­
230S­
L
Combined
22
of
28
Puree
0.081
0.013
0.094
0.603
Ketchup
0.154
0.029
0.183
1.173
Canned
tomatoes
0.016
<
0.002
<
0.018
0.115
Benthiavalicarb­
isopropyl
Summary
of
Analytical
Chemistry
and
Residue
Data
Barcode:
D322934
Table
6.
Residue
Data
from
Tomato
Processing
Studies
with
Benthiavalicarb
(
WDG).

Trial
ID
(
City,
Country,
Year)
Processed
Commodity
Total
Rate
(
lb
ai/
A)
PHI
(
days)
Residues
(
ppm)
1
Processing
Factor
2
KIF­
230R­
L
KIF­
230S­
L
Combined
23
of
28
45869713.
DER2
Boschi
S.
Anna,
Italy,
2000
Tomato
(
RAC)
0.40
3
0.114
0.006
0.120
Peeled
tomatoes
0.016
<
0.002
<
0.018
0.15
Juice
0.070
0.005
0.075
0.63
Wet
pomace
0.31
0.02
0.33
2.8
Dry
pomace
1.57
0.13
1.70
14
Puree
0.170
0.036
0.206
1.72
Ketchup
0.164
0.032
0.196
1.63
Canned
tomatoes
0.025
0.002
0.027
0.23
1
The
LLMV
is
0.01
ppm,
the
LOD
was
0.002ppm.
For
calculation
of
the
combined
residues,
a
value
of
0.002
ppm
was
used
for
samples
with
residues
<
LOD.
2
The
processing
factor
was
calculated
by
the
reviewer
using
the
combined
residues
in
the
tomato
RAC
and
processed
fractions.

NA=
not
applicable;
NC=
Not
calculable
45869711.
DER2
Three
tomato
processing
tests
were
conducted
during
1999
on
greenhouse­
grown
tomatoes
from
Spain
and
field­
grown
tomatoes
from
France
and
Italy.
In
each
test,
benthiavalicarb
(
15%
WG)
was
applied
as
six
broadcast
foliar
applications
at
0.064­
0.069
lb
ai/
A/
application,
for
a
total
of
0.401­
0.404
lb
ai/
A/
season.
The
first
application
was
made
approximately
38­
42
days
prior
to
normal
maturity,
beginning
at
the
64­
88
growth
stages,
with
repeat
applications
made
at
retreatment
intervals
(
RTIs)
of
7­
8
days.
Bulk
control
and
treated
tomato
samples
were
harvested
at
3
DAT
from
the
greenhouse
test
and
7
DAT
from
the
two
outdoor
field
tests.
A
single
RAC
sample
was
collected
from
each
test
and
the
remaining
bulk
samples
were
processed
into
peeled
tomato,
juice,
wet
pomace,
dry
pomace,
puree,
ketchup,
and
canned
tomatoes
using
simulated
commercial
procedures.
Prior
to
analysis,
tomato
RAC
and
processed
tomato
commodity
samples
were
stored
frozen
for
a
maximum
of
231
days.
Although
data
are
available
supporting
the
stability
of
residues
in
tomatoes
for
up
to
8
months,
stability
data
are
not
available
for
residues
in
processed
tomato
fractions.

Combined
KIF­
230R­
L
and
KIF­
230S­
L
residues
were
0.156
ppm
in/
on
greenhouse­
grown
tomatoes
(
RAC)
harvested
at
3
DAT
and
<
0.013­<
0.015
ppm
in/
on
field­
grown
tomatoes
(
RAC)
harvested
at
7
DAT.
As
the
combined
residues
in
tomatoes
from
the
outdoor
field
tests
were
at
or
near
the
method
LLMV,
the
overall
processing
factors
were
determined
using
data
from
the
greenhouse
test.
Following
processing
of
greenhouse­
grown
tomatoes,
combined
residues
were
<
0.007
ppm
in
peeled
tomato,
<
0.056
ppm
in
juice,
0.088
ppm
in
wet
pomace,
0.989
ppm
in
dry
pomace,
0.094
ppm
in
puree,
0.183
ppm
in
ketchup,
and
0.018
ppm
in
canned
tomatoes.

Based
on
combined
residues
of
greenhouse
tomatoes,
the
overall
processing
factors
were
0.05x
for
peeled
tomatoes,
0.36x
for
juice,
0.56x
for
wet
pomace,
6.3x
for
dry
pomace,
0.60x
for
puree,
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isopropyl
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1.2x
for
ketchup,
and
0.12x
for
canned
tomatoes.
No
data
were
provided
on
tomato
paste.
For
paste,
the
theoretical
concentration
factor
based
on
loss
of
water
is
5.5x
(
OPPTS
Series
860
Guidelines,
Section
1520,
Table
2).

45869713.
DER2
In
a
processing
study
conducted
in
Italy
during
2000,
benthiavalicarb
(
15%
WDG)
was
applied
as
six
broadcast
foliar
applications
to
greenhouse­
grown
tomatoes
at
0.065­
0.067
lb
ai/
A/
application,
for
a
total
of
0.396
lb
ai/
A/
season.
The
first
application
was
made
approximately
38
days
prior
to
normal
maturity,
beginning
at
the
BBCH
71­
89
growth
stages.
Bulk
control
and
treated
tomato
samples
were
harvested
3
days
after
the
last
application
(
DAT).
A
single
RAC
sample
was
collected.
Using
simulated
commercial
procedures,
the
remaining
bulk
samples
were
processed
into
juice,
dry
pomace,
wet
pomace,
peeled
tomato,
ketchup
(
and
waste),
puree
(
and
waste),
canned
tomatoes,
peels,
and
blanching
water.
Prior
to
analysis,
tomatoes
and
processed
commodity
samples
were
stored
frozen
for
a
maximum
of
109
days.
Although
data
are
available
supporting
the
stability
of
residues
in
tomatoes
for
up
to
8
months,
stability
data
are
not
available
for
residues
in
processed
tomato
fractions.

Combined
residues
were
0.120
ppm
in/
on
a
single
tomato
RAC
sample
harvested
at
3
DAT.
After
processing,
combined
residues
were
0.075
ppm
in/
on
juice,
1.70
ppm
in/
on
dry
pomace,
0.33
ppm
in/
on
wet
pomace,
<
0.018
ppm
in/
on
peeled
tomato,
0.196
ppm
in/
on
ketchup,
0.206
ppm
in/
on
puree,
0.027
ppm
in/
on
canned
tomatoes,
and
0.392
ppm
in/
on
peels.
The
processing
factors
for
combined
KIF­
230
residues
were
0.63x
in
juice,
14x
in
dry
pomace,
2.8x
in
wet
pomace,
0.15x
in
peeled
tomato,
1.6x
in
ketchup,
1.7x
in
puree,
0.23x
in
canned
tomatoes,
and
3.3x
in
peels.

Conclusions.
The
available
processing
data
are
adequate.
Samples
were
analyzed
using
adequate
analytical
methods.
Storage
stability
data
were
not
submitted
for
processed
grape
and
tomato
commodities.
These
data
are
not
required
for
the
current
tolerance
requests
because
acceptable
storage
stability
data
were
submitted
for
grapes
and
tomatoes.
Residues
were
stable
in
grapes
for
13
months
and
in
tomatoes
for
8
months.
In
the
tomato
storage
stability
studies,
tomatoes
were
homogenized
prior
to
storage.
Homogenized
tomatoes
are
comparable
in
both
composition
and
texture
to
processed
tomato
commodities.
The
matrix
is
an
acidic
one
which
would
very
likely
maximize
residue
decay.
As
a
result,
the
tomato
data
are
considered
adequate
to
demonstrate
storage
stability
in
processed
grape
commodities
as
well.

Eight
out
of
the
nine
grape
processing
studies
had
readily
quantifiable
combined
residues
in/
on
grape
RAC
samples
(
0.014­
0.70
ppm).
In
these
studies,
processing
factors
for
combined
residues
were
1.4x­
8.6x
in
raisins,
0.21­
1.2x
in
juice,
and
0.5­
1.96x
in
wine.
Average
processing
factors
were
3.67x
for
raisins,
0.47x
for
juice,
and
0.98x
for
wine.
Based
on
the
3.67x
processing
factor
for
raisins
and
the
HAFT
residue
of
0.22
ppm
from
the
grape
field
trials,
the
maximum
expected
residues
in
raisins
would
be
0.81
ppm,
which
is
above
the
recommended
grape
tolerance.
Therefore,
a
separate
tolerance
is
required
for
raisins.
Based
on
the
available
data,
a
tolerance
of
1.0
ppm
is
appropriate.

Two
out
of
the
four
tomato
processing
studies
had
readily
quantifiable
combined
residues
in/
on
whole
tomato
samples
(
0.120
and
0.156
ppm).
In
these
studies,
processing
factors
for
combined
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residues
were
0.045x
and
0.15x
in
peeled
tomatoes,
0.12x
and
0.23x
in
canned
tomatoes,
0.36x
and
0.63x
in
juice,
0.60x
and
1.7x
in
puree,
1.2x
and
1.6x
in
ketchup,
0.56x
and
2.8x
in
wet
pomace,
and
6.3x
and
14x
in
dry
pomace.
Average
processing
factors
were
0.49x
in
juice,
1.2x
in
puree,
1.4x
in
ketchup,
0.098x
in
peeled
tomatoes,
and
0.17x
in
canned
tomatoes.
Residue
data
on
tomato
paste
were
not
provided;
however,
the
petitioner
is
requesting
that
the
tolerance
for
tomato
paste
be
based
on
the
theoretical
concentration
factor
of
5.5x.

The
HAFT
residues
from
all
tomato
trials
is
0.23
ppm;
however,
this
value
is
from
the
greenhouse
trials
and
greenhouse­
grown
tomatoes
are
not
utilized
for
processing.
Therefore,
the
highest
field
trial
residue
value
of
0.015
ppm
from
the
tests
on
field­
grown
tomatoes
will
be
used
to
assess
the
need
for
tolerances
on
processed
tomato
fractions.
In
the
outdoor
field
trials,
only
one
sample
was
taken
in
each
of
the
3
trials;
therefore,
a
HAFT
value
is
not
available.
Based
on
the
above
processing
factors
and
the
highest
field
trial
residue
value
from
the
outdoor
field
trials
(
0.015
ppm),
the
maximum
expected
residues
in
puree,
ketchup,
and
paste
would
be
0.074,
0.017,
and
0.21
ppm,
respectively,
which
are
all
below
the
recommended
tomato
tolerance
of
0.45
ppm.
Therefore,
separate
tolerances
are
not
required
on
processed
tomato
fractions.

860.1650
Submittal
of
Analytical
Reference
Standards
The
analytical
reference
standards
for
benthiavalicarb
have
been
submitted
to
the
EPA
National
Pesticide
Standards
Repository.

860.1850/
1900
Confined
and
Field
Accumulation
in
Rotational
Crops
The
proposed
uses
are
for
crops
grown
in
Europe
for
importation
to
the
U.
S.;
therefore,
rotational
crop
studies
are
not
required
for
this
petition.

860.1550
Proposed
Tolerances
There
are
currently
no
food/
feed
uses
or
tolerances
for
benthiavalicarb
in
the
U.
S.
The
petitioner
has
recommended
that
only
the
R­
L
isomer
be
included
in
the
tolerance
expression
as
the
S­
L
isomer
is
a
minor
impurity
in
the
commercial
formulations
and
the
potato
metabolism
study
indicates
that
the
active
R­
L
isomer
is
not
converted
to
the
S­
L
isomer.
In
addition,
the
residue
definition
proposed
for
the
EU
MRLs
includes
only
the
R­
L
isomer.
The
registrant
has
proposed
EU
MRLs
of
0.2
ppm
for
grapes
and
0.3
ppm
for
tomatoes.
It's
possible
that
if
EU
MRLs
are
established,
the
residue
definition
might
be
benthiavalicarb­
isopropyl
only,
and
no
distinction
will
be
made
as
to
the
isomer.
HED
feels
that
the
S­
L
isomer
should
be
included
in
the
tolerance
expression,
however.
The
results
of
the
field
trials
indicate
that
the
residue
levels
of
the
S­
L
isomer
are
often
non­
negligible
compared
to
the
levels
of
the
R­
L
isomer.
In
the
grape
field
trials
several
samples
had
S­
L
isomer
levels
that
were
10­
20%
of
the
R­
L
isomer
levels.
A
small
number
of
samples
had
S­
L:
R­
L
ratios
that
exceeded
20%.
In
the
tomato
field
trials,
the
S­
L
residue
levels
were
generally
non­
detectable.
In
a
few
cases,
however,
the
S­
L
isomer
was
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present
at
6­
7%
of
the
level
of
the
R­
L
isomer.
The
analytical
method
determines
both
isomers
separately.

A
summary
of
the
recommended
tolerances
and
the
correct
commodity
definitions
for
the
commodities
in
PP#
3E6545
are
listed
in
Table
7.
The
recommended
tolerances
are
based
on
the
combined
residues
of
the
R­
L
and
S­
L
isomers.

Table
7.
Tolerance
Summary
for
Benthiavalicarb­
isopropyl
(
PP#
3E6545)

Commodity
Proposed
Tolerance
(
ppm)
Recommended
Tolerance
(
ppm)*
Correct
commodity
definition
and
comments
Grapes
0.5
0.25
Grape
The
available
data
are
adequate.
Maximum
residues
in/
on
grapes
were
0.27
ppm.

Raisins
1.0
1.0
Grape,
Raisin
The
available
data
are
adequate.
Based
on
an
average
processing
factor
of
3.7x
for
raisins
and
the
HAFT
residue
value
in
grapes
of
0.22
ppm,
maximum
residues
in
raisins
would
be
0.81
ppm.

Tomatoes
0.5
0.45
Tomato
The
available
data
are
adequate.
Maximum
residues
were
0.26
ppm
in/
on
greenhouse
grown
tomatoes
and
<
0.015
ppm
in/
on
field
grown
tomatoes.

Tomato
Paste
1.5
None
Tomato,
Paste
The
available
data
are
adequate.
Average
processing
factors
were
1.2x
and
1.4x
for
tomato
puree
and
ketchup,
respectively,
and
were
estimated
to
be
5.5x
for
paste
(
the
theoretical
concentration
factor
based
on
loss
of
water).
Based
on
the
highest
field
trial
residue
value
of
0.015
ppm
for
fieldgrown
tomatoes,
the
maximum
expected
residues
in
tomato
paste
would
be
0.083
ppm.

*
Based
on
HED's
statistical
tolerance
generator
for
NAFTA­
harmonized
tolerances
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Table
8.
Benthiavalicarb
Field
Trial
Values
Used
to
Establish
Recommended
Tolerances
Grapes
(
ppm)
Grapes
Continued
(
ppm)
Grapes
Continued
(
ppm)
Tomatoes
(
Greenhouse)
(
ppm)

0.023
0.039
0.028
0.116
0.051
0.077
0.036
0.041
0.091
0.093
0.028
0.095
0.125
0.041
0.032
0.141
0.084
0.161
0.057
0.124
0.043
0.149
0.069
0.268
0.042
0.153
0.020
0.048
0.039
0.269
0.035
0.044
0.077
0.175
0.122
0.230
0.040
0.039
0.082
0.222
0.024
0.038
0.080
0.066
0.044
0.051
0.114
0.077
0.071
0.072
0.104
0.067
0.112
0.083
0.028
0.047
0.110
0.012
0.034
0.032
0.032
0.006
0.082
0.043
Recommended
Tolerance*
0.25
0.45
*
Based
on
HED's
statistical
tolerance
generator
for
NAFTA­
harmonized
tolerances
There
are
currently
no
Canadian,
Mexican,
Codex,
or
EU
MRLs
for
benthiavalicarb.
The
registrant
has
proposed
EU
MRLs
of
0.2
ppm
for
grapes,
0.3
ppm
for
tomatoes,
and
0.01
ppm
for
potatoes.
The
MRL
status
sheet
is
attached.

References
None
Benthiavalicarb­
isopropyl
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INTERNATIONAL
RESIDUE
LIMIT
STATUS
Chemical
Name:
Isopropyl[(
S)­
1­
{[(
1R)­
1­(
6­
fluoro­
1,3­
benzothiazol­
2­
yl)
ethyl]
carbamoyl}­
2­
methylpropyl]
carbamate
Common
Name:
Benthiavalicarb
Isopropyl
:
Proposed
tolerance
9
Reevaluated
tolerance
9
Other
Date:
10/
18/
2005
Codex
Status
(
Maximum
Residue
Limits)
U.
S.
Tolerances
XNo
Codex
proposal
step
6
or
above
9
No
Codex
proposal
step
6
or
above
for
the
crops
requested
Petition
Number:
3E6545
DP
Barcode:
D
Other
Identifier:

Residue
definition
(
step
8/
CXL):
Not
applicable
Reviewer/
Branch:
Doug
Dotson/
RAB2
Residue
definition:
parent
benthiavalicarb
isopropyl
Crop
(
s)
MRL
(
mg/
kg)
Crop(
s)
Tolerance
(
ppm)

Grape
0.20
Grape,
Raisin
1.0
Tomato
0.45
Tomato
Paste
0.45
Limits
for
Canada
Limits
for
Mexico
X
No
Limits
9
No
Limits
for
the
crops
requested
XNo
Limits
9
No
Limits
for
the
crops
requested
Residue
definition:
N/
A
Residue
definition:
N/
A
Crop(
s)
MRL
(
mg/
kg)
Crop(
s)
MRL
(
mg/
kg)

Notes/
Special
Instructions:
S.
Funk,
10/
19/
2005.

Rev.
1998
