1
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES,
AND
TOXIC
SUBSTANCES
MEMORANDUM
Date:
October
14,
2005
Subject:
Triadimenol.
Registrants
Response
to
Residue
Chemistry
Data
Requirements.
Field
Corn,
Cotton,
and
Wheat
Processing
Studies.

DP
Barcode:
D322336
PC
Code:
127201
40
CFR
§
:
180.410
Chemical
Class:
Azole
MRID
Numbers:
44519801,
44519802,
and
44519803
From:
Samuel
Ary,
Chemist
Reregistration
Branch
II
Health
Effects
Division
(
7509C)

Through:
Yvonne
Barnes,
Chemist
Reregistration
Branch
II
Health
Effects
Division
(
7509C)

William
Hazel,
Branch
Chief
Reregistration
Branch
II
Health
Effects
Division
(
7509C)

To:
Richard
Griffin,
Risk
Assessor
Reregistration
Branch
II
Health
Effects
Division
(
7509C)

John
Pates,
Chemical
Review
Manager
Reregistration
Branch
I
Special
Review
and
Reregistration
Division
(
7508C)

This
document
was
originally
prepared
under
contract
by
Dynamac
Corporation
(
2275
Research
Boulevard,
Rockville,
MD
20850;
submitted
August
16,
2000).
The
document
has
been
reviewed
by
the
Health
Effects
Division
(
HED)
and
revised
to
reflect
current
Office
of
Pesticide
Program
(
OPP)
policies.
INTRODUCTION
2
In
response
to
the
Triadimenol
Data
Call­
In
(
3/
8/
1996),
Gustafson,
Inc,
has
submitted
data
pertaining
to
the
magnitude
of
triadimenol
residues
of
concern
in
the
processed
commodities
of
field
corn
(
1998;
MRID
44519801),
cotton
(
1998;
MRID
44519802)
and
wheat
(
1998;
MRID
44519803).
These
data
are
evaluated
in
this
document
for
adequacy
in
fulfilling
residue
chemistry
data
requirements.

Triadimenol,
 ­(
4­
chlorophenoxy)­
 ­(
1,1­
dimethylethyl)­
1H­
1,2,4­
triazole­
1­
ethanol,
is
a
systemic
fungicide
registered
for
use
in
the
United
States
as
a
seed
treatment
for
barley,
corn,
cotton,
oats,
rye,
sorghum,
and
wheat.
Additionally,
an
import
tolerance
on
bananas
has
been
established.
Triadimenol
end­
use
products
are
marketed
in
the
U.
S.
under
the
trade
name
Baytan
®
.
The
reregistration
of
triadimenol
is
being
supported
by
Bayer
CropScience
(
Bayer),
the
basic
producer.
The
triadimenol
formulations
registered
for
food/
feed
uses
include
wettable
powder
(
WP),
flowable
concentrate
(
FlC),
emulsifiable
concentrate
(
EC),
and
soluble
concentrate
(
SC)
formulations.

Tolerances
are
established
for
residues
of
triadimenol
and
1­(
4­
chlorophenoxy)­
3,3­
dimethyl­
3­
hydroxymethyl­
1­(
1H­
1,2,4­
triazol­
1­
yl)­
2­
butanol
(
KWG
1342;
calculated
as
triadimenol)
in/
on
various
plant
commodities
[
40
CFR
§
180.450(
a)].
The
established
tolerances
for
plant
commodities
range
from
0.01
ppm
(
sorghum
grain
and
fodder)
to
2.5
ppm
(
green
forage
of
oats,
rye,
and
wheat).
Tolerances
are
established
for
residues
of
triadimenol
and
its
metabolites
containing
the
chlorophenoxy
moiety
(
calculated
as
triadimenol)
in/
on
livestock
commodities
at
0.01
ppm
(
milk,
and
poultry
commodities)
and
0.1
ppm
(
fat,
meat,
and
meat
byproducts
of
cattle,
goats,
hogs,
horses,
and
sheep).

Triadimenol
and
its
butanediol
metabolite
(
KWG
1342)
are
also
regulated
as
metabolites
of
the
fungicide
triadimefon
(
40
CFR
§
180.410).

The
reregistration
requirements
for
plant
metabolism
have
not
been
fulfilled.
No
metabolism
studies
with
triadimenol
have
been
submitted;
however,
metabolism
studies
with
triadimefon
have
been
received
and
reviewed.
The
Health
Effects
Division
(
HED)
has
examined
the
results
of
these
studies
and
determined
that
the
triadimefon
residues
of
concern
in/
on
apples,
grapes,
pears,
pineapples,
and
raspberries
for
tolerance
expression
are
triadimefon
and
triadimenol
and
for
risk
assessment
are
triadimefon,
triadimenol,
KWG
1323
[
1­(
4­
chlorophenoxy)­
3,3­
dimethyl­
3­
hydroxymethyl­
1­(
1H­
1,2,4­
triazol­
1­
yl)­
2­
butanone],
and
KWG
1342
(
S.
Ary,
D314742,
11/
23/
2005).
Of
these
compounds,
triadimenol
and
KWG
1342
are
currently
regulated
for
plant
commodities.

HED
has
determined
that
translation
of
metabolism
data
from
triadimefon
to
triadimenol
is
not
appropriate
for
the
existing
uses
on
cereal
grains
and
cotton.
The
metabolism
studies
with
triadimefon
were
conducted
using
a
foliar
application
and
triadimenol
is
used
only
as
a
seed
treatment.
Additionally,
in
the
submitted
triadimenol
seed
treatment
wheat
study,
residues
in
grain
were
not
identifiable
due
to
the
low
activity
found
in
wheat
grain.
Therefore,
HED
concludes
that
the
nature
of
the
residue
in
cereal
grains
and
cotton
is
not
adequately
understood;
however,
based
on
chemical
structure
and
the
probable
metabolic
pathway
of
triadimenol,
the
residues
of
concern
for
tolerance
expression
and
risk
assessment
are
likely
to
be
triadimenol,
KWG
1342,
and
KWG
1732
in/
on
cereal
grains
(
barley,
corn,
oats,
rye,
and
wheat)
and
cotton.
Separate
metabolism
studies
with
triazole­
14C
and
phenyl­
14C
labeled
triadimenol
applied
as
a
seed
treatment
to
corn
or
wheat
and
cotton
should
be
conducted
to
confirm
the
residues
of
concern.
The
residues
of
concern
for
tolerance
expression
and
risk
assessment
for
bananas
are
triadimenol
and
KWG
1342.
3
The
Pesticide
Analytical
Manual
(
PAM)
Vol.
II
does
not
contain
a
listing
for
triadimenol
(
February
1997
Index).
However,
the
methods
listed
for
triadimefon
can
be
used
for
the
determination
of
triadimenol,
KWG
1323,
KWG
1342,
and
KWG
1732.
PAM
lists
two
gas
chromatography
with
mass
spectrometry
detection
(
GC/
MS)
methods
(
Methods
I
and
II)
for
the
determination
of
triadimenol
and
its
free
and
conjugated
metabolites
in
plant
and
livestock
commodities.
Both
methods
are
common
moiety
methods.
The
reported
limit
of
quantitation
(
LOQ)
is
0.05
and
limit
of
detection
(
LOD)
is
0.01
ppm
for
both
methods.

In
conjunction
with
triadimefon
reregistration,
Bayer
has
proposed
a
GC/
MS
method
(
Report
No.
106549)
for
enforcement
of
tolerances
for
residues
of
triadimefon,
triadimenol,
KWG
1342,
KWG
1323,
and
KWG
1732
in/
on
barley,
corn,
cotton,
oat,
rye,
and
wheat
commodities.
The
method
has
been
successfully
radiovalidated
and
has
undergone
independent
laboratory
validation.
The
reported
method
LOQ
is
0.05
ppm
for
each
analyte
in
cereal
grains
and
0.02
ppm
in
each
analyte
in
cotton.
Additionally,
a
GC
method
using
a
nitrogen
phosphorus
detector
(
NPD;
Report
No.
80488)
is
available
for
determination
of
residues
of
triadimenol,
KWG
1342,
and
KWG
1323
and
is
adequate
for
the
enforcement
of
the
banana
tolerance.
The
method
has
undergone
a
successful
Agency
method
validation
on
tomatoes
and
was
submitted
to
the
FDA
for
publication
in
PAM
Vol.
II.
The
reported
method
LOQ
is
0.01
ppm
for
each
analyte.

CONCLUSIONS
AND
RECOMMENDATIONS
Processed
Food/
Feed
1.
Field
corn:
The
submitted
data
are
adequate
to
fulfill
the
requirement
for
a
field
corn
grain
processing
study.
As
triadimenol
residues
of
concern
were
each
below
the
LOQ
(
0.05
ppm)
in/
on
corn
grain
grown
from
seed
treated
at
5x
the
maximum
application
rate,
a
corn
grain
processing
study
and
tolerances
for
field
corn
processed
commodities
are
not
required.

2.
Cotton:
The
submitted
data
are
adequate
to
fulfill
the
requirement
for
a
cottonseed
processing
study.
As
triadimenol
residues
of
concern
were
each
below
the
LOQ
(
0.02
ppm)
in/
on
cottonseed
grown
from
seed
treated
at
5x
the
maximum
application
rate,
a
cottonseed
processing
study
and
tolerances
for
cotton
processed
commodities
are
not
required.

3.
Wheat:
The
available
wheat
grain
data
do
not
fulfill
the
requirement
for
a
wheat
grain
processing
study.
Residues
of
triadimenol
and
KWG
1342
were
each
<
LOQ
(<
0.05
ppm)
and
residues
of
KWG
1732
were
0.11
ppm
and
0.23
ppm
in/
on
two
samples
of
wheat
grain
grown
from
seed
treated
with
triadimenol
(
FlC)
at
5x
the
maximum
rate.
However,
the
treated
grain
was
not
processed.
Instead,
the
registrant
proposed
translating
data
from
a
triadimefon
wheat
grain
processing
study;
however,
these
data
cannot
be
translated
to
triadimenol
due
to
differences
in
the
use
patterns
(
seed
treatment
vs.
late
season
foliar
sprays)
that
are
likely
to
impact
the
potential
for
concentration
of
residues
in
grain.
The
registrant
should
conduct
a
processing
study
using
the
available
wheat
grain
grown
from
the
seeds
treated
with
triadimenol
at
5x.
DETAILED
CONSIDERATIONS
Residue
Analytical
Methods
Samples
of
field
corn
grain,
cottonseed,
and
wheat
grain
were
analyzed
for
residues
of
triadimenol,
KWG
1342,
and
KWG
1732
at
ABC
Laboratories
(
Columbia,
MO)
using
a
4
GC/
MS
method
(
Bayer
Corporation
Report
No.
106549).
This
method
has
been
proposed
for
enforcement
of
tolerances
for
triadimefon
residues
of
concern
and
has
undergone
successful
independent
laboratory
validation
(
J.
Punzi;
D222403,
D227497,
and
D227543;
7/
13/
2000).

Briefly,
residues
are
extracted
under
reflux
in
methanol:
water
(
7:
3,
v:
v)
for
2
hours
and
then
concentrated
to
an
aqueous
solution.
The
extract
is
then
hydrolyzed
with
cellulase
at
37
C
overnight
(
at
pH
5.5)
and
partitioned
with
dichloromethane:
acetonitrile
(
3:
2,
v:
v).
The
aqueous
phase,
containing
KWG
1732,
is
reserved.
The
organic
phase
is
dried
using
sodium
sulfate
and
evaporated
to
dryness,
and
residues
are
redissolved
in
ethyl
acetate,
cleaned
up
by
gel
permeation
chromatography,
and
separated
by
semi­
preparative
HPLC
into
two
fractions:
one
containing
triadimenol
and
the
other
containing
KWG
1342.
Triadimenol
was
determined
directly
by
GC/
MS;
KWG
1342
was
derivatized
prior
to
GC/
MS
analysis.
The
reported
LOQ
was
0.05
ppm
for
each
analyte
in
field
corn
and
wheat
grain
and
0.02
ppm
for
each
analyte
in
cottonseed.

The
reserved
aqueous
phase,
containing
KWG
1732,
is
acidified
to
pH
1
(
using
concentrated
HCl)
and
the
residues
are
partitioned
into
ethyl
acetate.
The
residues
are
then
partitioned
into
0.5
M
sodium
carbonate,
acidified
to
pH
1,
and
repartitioned
back
into
ethyl
acetate.
The
residues
are
then
evaporated
to
dryness,
redissolved
in
methanol:
dichloromethane
(
20:
80;
v:
v),
methylated
with
trimethylsilyl
diazomethane,
and
cleaned
up
by
silica
gel
solid
phase
extraction
for
analysis
by
GC/
MS.
Triadimefon
was
used
as
an
internal
standard
for
KWG
1732
analysis.
The
reported
LOQ
was
0.05
ppm
for
field
corn
and
wheat
grain
and
0.02
ppm
for
cottonseed.

The
registrant
provided
method
validation
and
concurrent
method
recovery
data
for
the
GC/
MS
method
from
fortifications
at
the
LOQ.
These
recovery
data
are
presented
in
Table
1.
These
data
indicate
that
the
GC/
MS
method
is
adequate
for
data
collection
purposes.

Table
1.
Recoveries
of
triadimenol
and
its
metabolites
KWG
1342,
and
KWG
1732
from
fortified
samples
of
untreated
field
corn
grain,
cottonseed,
and
wheat
grain.
Triadimenol
KWG
1342
KWG
1732
Commodity
Fortification
Level
(
ppm)
%
Recovery
a
Fortification
Level
(
ppm)
%
Recovery
a
Fortification
Level
(
ppm)
%
Recovery
a
Field
corn
Grain
0.05
76­
84
(
4)
0.05
86,88;
134,
142
0.05
88­
102
(
3)

Cottonseed
0.02
95­
100
(
3)
0.02
75­
80
(
3)
0.02
75­
120
(
3)
Wheat
Grain
0.05
72­
82
(
3)
0.05
100­
108
(
3)
0.05
60,
62;
76
a
Each
value
represents
one
sample
unless
otherwise
indicated
in
parentheses;
recovery
values
outside
the
acceptable
70­
120%
range
are
listed
separately.

Storage
Stability
Data
Samples
of
field
corn
grain,
cottonseed,
and
wheat
grain
were
placed
in
frozen
storage
(
temperature
unspecified)
within
4
hours
of
sample
collection,
and
then
shipped
frozen
to
the
analytical
laboratory,
where
they
were
stored
frozen
(~­
20
C)
until
analysis.
Subsamples
of
the
unginned
cottonseed
were
removed
from
the
freezer
at
the
field
trial
site
after
approximately
3
months
of
storage;
these
subsamples
were
ginned,
frozen,
and
then
shipped
to
the
analytical
laboratory.
Analyses
were
completed
82­
96
days
following
collection
for
field
corn
grain
samples,
201­
236
days
following
collection
for
cottonseed
samples,
and
44­
51
days
following
collection
for
wheat
grain
samples.
5
Storage
stability
data
for
triadimenol,
KWG
1342,
and
KWG
1732
have
been
submitted
by
Bayer
Corporation
to
satisfy
reregistration
data
requirements
for
triadimefon.
These
data
indicate
that
residues
of
triadimenol
and
KWG
1342
are
stable
in
wheat
grain
for
up
to
2
years
of
at
­
20
C
(
S.
Hummel;
D168542
and
D178884;
12/
22/
92)
and
residues
of
KWG
1732
are
stable
in
wheat
grain
for
up
to
2.5
years
at
­
20
°
C
(
J.
Punzi;
D222403,
D227497,
and
D227543;
7/
13/
2000).
These
data
are
adequate
to
support
the
storage
intervals
and
conditions
of
the
samples
from
the
submitted
field
corn
grain,
cottonseed,
and
wheat
grain
studies.

Magnitude
of
the
Residue
in
Processed
Food/
Feed
Field
Corn
Established
tolerances:
No
tolerance
has
been
established
for
triadimenol
residues
of
concern
in
any
field
corn
processed
commodity.
A
tolerance
of
0.05
ppm
has
been
established
for
triadimenol
residues
of
concern
in/
on
field
corn
grain
[
§
180.450(
a)].

Use
directions:
The
2.65
lb/
gal
FlC
formulation
(
EPA
Reg.
No.
7501­
91)
is
registered
for
use
on
field
corn
as
a
seed
treatment
at
0.062
lb
ai
(
1.0
oz
ai)
per
100
lb
of
seed.
Application
is
to
be
made
by
mixing
the
dosage
in
16
fluid
oz
of
water
per
100
lb
of
seed.
The
use
of
treated
seed
for
feed,
food
or
oil
purposes
is
prohibited.
A
45­
day
PHI
has
been
established
for
forage.

Discussion
of
data:
Gustafson
has
submitted
data
(
1998;
MRID
44519801)
depicting
the
potential
for
concentration
of
triadimenol
residues
of
concern
in
field
corn
processed
commodities.
Field
corn
seed
was
treated
with
the
2.65
lb/
gal
FlC
formulation
at
0.313
lb
ai
(
5.0
oz
ai)
per
100
lb
of
seed
(
5x
the
maximum
application
rate)
prior
to
planting.
The
treated
seed
was
planted
in
IA
six
days
after
treatment.
One
sample
of
field
corn
grain
grown
from
untreated
seed
and
two
samples
of
field
corn
grain
grown
from
treated
seed
were
collected
at
maturity,
177
days
after
planting.
The
field
corn
grain
samples
were
placed
in
frozen
storage
within
2
hours
of
collection,
and
then
shipped
frozen
to
the
analytical
laboratory
(
ABC
Laboratories),
where
they
were
stored
frozen
until
analysis.

Field
corn
grain
samples
were
analyzed
for
residues
of
triadimenol,
KWG
1342,
and
KWG
1732.
Residues
were
below
the
LOQ
(<
0.05
ppm)
for
each
analyte
in/
on
one
sample
of
untreated
field
corn
grain
and
two
samples
of
treated
field
corn
grain.
Because
no
quantifiable
residues
were
observed
in/
on
corn
grain
following
treatment
at
5x
the
maximum
application
rate,
a
processing
study
was
not
conducted.

Study
summary:
The
submitted
data
are
adequate
to
fulfill
the
requirements
for
a
field
corn
grain
processing
study.
As
triadimenol
residues
of
concern
were
<
LOQ
in/
on
corn
grain
grown
from
seed
treated
at
5x
the
maximum
application
rate,
a
corn
grain
processing
study
and
tolerances
for
field
corn
processed
commodities
are
not
required.

Cottonseed
Established
tolerances:
No
tolerance
has
been
established
for
triadimenol
residues
of
concern
in
any
cottonseed
processed
commodity.
A
tolerance
of
0.02
ppm
has
been
established
for
triadimenol
residues
of
concern
in/
on
cottonseed
[
§
180.450(
a)].

Use
directions:
The
0.43
lb/
gal
EC
formulation
(
EPA
Reg.
No.
7501­
80)
is
registered
for
use
on
cotton
as
a
seed
treatment
at
0.040
lb
ai
(
0.6
oz
ai)
per
100
lb
of
seed.
The
use
of
treated
seed
for
feed,
food
or
oil
purposes
is
prohibited.
6
The
2.65
lb/
gal
FlC
formulation
(
EPA
Reg.
No.
7501­
91)
is
registered
for
use
on
cotton
as
a
seed
treatment
at
0.062
lb
ai
(
1.0
oz
ai)
per
100
lb
of
seed.
Application
is
to
be
made
by
mixing
the
dosage
in
16
fluid
oz
of
water
per
100
lb
of
seed.
The
use
of
treated
seed
for
feed,
food
or
oil
purposes
is
prohibited.

Discussion
of
data:
Gustafson
has
submitted
data
(
1998;
MRID
44519802)
depicting
the
potential
for
concentration
of
triadimenol
residues
of
concern
in
cottonseed
processed
commodities.
Cotton
seed
was
treated
with
the
2.65
lb/
gal
FlC
formulation
at
0.313
lb
ai
(
5.0
oz
ai)
per
100
lb
of
seed
(
5x
the
maximum
application
rate)
prior
to
planting.
The
treated
seed
was
planted
in
MS
13
days
after
treatment.
One
sample
of
cottonseed
grown
from
untreated
seed
and
two
samples
of
cottonseed
grown
from
treated
seed
were
collected
at
maturity,
148
days
after
planting.
The
samples
were
placed
in
frozen
storage
within
1
hour
of
collection.
Subsamples
of
the
unginned
cottonseed
were
removed
from
the
freezer
after
approximately
3
months
of
storage;
these
subsamples
were
ginned,
frozen,
and
then
shipped
to
the
analytical
laboratory
(
ABC
Laboratories),
where
they
were
stored
frozen
until
analysis.

Ginned
cottonseed
samples
were
analyzed
for
residues
of
triadimenol,
KWG
1342,
and
KWG
1732.
Residues
were
below
the
LOQ
(<
0.02
ppm)
for
each
analyte
in/
on
one
sample
of
untreated
cottonseed
and
two
samples
of
treated
cottonseed.
Because
no
quantifiable
residues
were
observed
following
treatment
at
5x
the
maximum
application
rate,
a
processing
study
was
not
conducted.

Study
summary:
The
submitted
data
are
adequate
to
fulfill
the
requirement
for
a
cottonseed
processing
study.
As
triadimenol
residues
of
concern
were
each
below
the
LOQ
(
0.02
ppm)
in
cottonseed
grown
from
seed
treated
at
5x
the
maximum
application
rate,
a
cottonseed
processing
study
and
tolerances
for
cotton
processed
commodities
are
not
required.

Wheat
Established
tolerances:
No
tolerance
has
been
established
for
triadimenol
residues
of
concern
in
any
wheat
processed
commodity.
A
tolerance
of
0.05
ppm
has
been
established
for
triadimenol
residues
of
concern
in/
on
wheat
grain
[
§
180.450(
a)].

Use
directions:
The
0.43
bl/
gal
EC
formulation
(
EPA
Reg.
No.
7501­
80),
2.65
lb/
gal
FlC
formulation
(
EPA
Reg.
No.
7501­
91),
2.6
lb/
gal
FlC
formulation
(
EPA
Reg.
No.
3125­
424),
and
6.25%
D
formulation
(
EPA
Reg.
No.
7501­
150)
are
registered
for
use
on
wheat
as
a
seed
treatment
at
0.03
lb
ai
(
0.5
oz
ai)
per
100
lb
of
seed.
Application
is
to
be
made
by
mixing
the
dosage
in
16
fluid
oz
of
water
per
100
lb
of
seed
(
FlC
formulations
only).
The
use
of
treated
seed
for
feed,
food
or
oil
purposes
is
prohibited.
A
40­
day
PHI
has
been
established
for
forage.
We
note
that
the
registrant
has
requested
cancellation
of
the
6.25%
D
formulation
(
65
FR
24477,
4/
26/
00).

Discussion
of
data:
Gustafson
has
submitted
data
(
1998;
MRID
44519803)
depicting
the
potential
for
concentration
of
triadimenol
residues
of
concern
in
wheat
processed
commodities.
Wheat
seed
was
treated
with
the
2.65
lb/
gal
FlC
formulation
at
0.16
lb
ai
(
2.5
oz
ai)
per
100
lb
of
seed
(
5x
the
maximum
application
rate)
prior
to
planting.
The
treated
seed
was
planted
in
TX
18
days
after
treatment.
The
registrant
noted
that
the
treated
seed
did
not
grow
as
well
as
the
untreated
seed,
and
that
the
treated
plot
suffered
~
40­
50%
loss
due
to
winter
freezing
conditions.
One
sample
of
wheat
grain
grown
from
untreated
seed
and
two
samples
of
wheat
grain
grown
from
treated
seed
were
collected
at
maturity,
308
days
after
planting.
The
wheat
grain
samples
were
placed
in
frozen
storage
within
4
hours
of
collection,
7
and
then
shipped
frozen
to
the
analytical
laboratory
(
ABC
Laboratories),
where
they
were
stored
frozen
until
analysis.

Wheat
grain
samples
were
analyzed
for
residues
of
triadimenol,
KWG
1342,
and
KWG
1732.
Residues
were
below
the
LOQ
(<
0.05
ppm)
for
each
analyte
in/
on
one
sample
of
untreated
wheat
grain.
Residues
of
triadimenol
and
KWG
1342
were
below
the
LOQ
in/
on
two
samples
of
treated
wheat
grain.
Detectable
residues
of
KWG
1732
were
observed
in
the
wheat
grain
samples
at
0.11
ppm
and
0.23
ppm.

The
registrant
did
not
process
seed
from
the
above
5x
field
trial;
instead,
Gustafson
cited
a
wheat
processing
study
submitted
by
Bayer
Corporation
to
fulfill
reregistration
requirements
for
triadimefon
(
1996;
MRID
44029301).
In
that
study,
mature
wheat
grain
was
harvested
35
days
following
the
last
of
two
foliar
broadcast
applications
of
a
50%
WP
triadimefon
formulation
(
EPA
Reg.
No.
3125­
340)
at
0.9
lb
ai/
A/
application
(
ca.
4x
the
maximum
seasonal
use
rate
for
triadimefon).
At
the
processing
facility
(
Texas
A&
M
University
Food
Protein
and
Development
Center,
Bryan,
TX),
aspirated
grain
fractions
were
collected
(
data
for
aspirated
grain
fractions
are
not
presented
here)
and
wheat
grain
samples
were
processed
into
bran,
wheat
germ,
flour,
middlings,
and
shorts,
using
a
small­
scale
processing
procedure
which
simulated
normal
commercial
processing
conditions.
The
residues
of
triadimenol,
KWG
1342,
and
KWG
1732
found
in
wheat
grain
and
its
processed
commodities
are
presented
in
the
Table
2.
These
data
indicate
that
the
combined
residues
of
triadimenol,
KWG
1342,
and
KWG
1732
concentrate
by
2.1x
in
wheat
bran
but
do
not
concentrate
in
wheat
flour,
middlings,
shorts,
or
germ.

Table
2.
Residues
of
triadimenol,
KWG
KWG
1342,
and
KWG
1732
in
the
processed
commodities
of
wheat
grain
harvested
at
maturity
(
35
days)
following
the
last
of
two
foliar
applications
of
triadimefon
at
4x
the
maximum
seasonal
triadimefon
rate
(
MRID
44029301).

Grain
Bran
Flour
Middlings
Shorts
Germ
a
Each
residue
value
represents
a
single
sample.

However,
these
data
cannot
be
translated
to
triadimenol
because
of
differences
in
the
use
patterns
of
the
two
compounds.
The
use
of
triadimefon
on
wheat,
which
Bayer
is
no
longer
supporting,
involves
late
season
foliar
applications
that
are
more
likely
to
result
in
surface
residues
in/
on
wheat
grain,
as
suggested
by
the
concentration
of
residues
in
bran
in
the
above
study.
However,
the
use
of
triadimenol
as
a
seed
treatment
is
unlikely
to
result
in
the
concentration
of
residues
in
the
outer
seed
coat.
To
assess
the
potential
for
the
concentration
of
triadimenol
residues
in
wheat
grain,
the
registrant
should
conduct
a
processing
study
using
the
available
wheat
grain
grown
from
the
5x
treated
seeds.

Study
summary:
The
available
wheat
grain
data
do
not
fulfill
the
requirement
for
a
wheat
grain
processing
study.
Residues
of
triadimenol
and
KWG
1342
were
each
<
LOQ
(<
0.05
ppm)
and
residues
of
KWG
1732
were
0.11
ppm
and
0.23
ppm
in/
on
two
samples
of
wheat
8
grain
grown
from
seed
treated
with
triadimenol
(
FlC)
at
5x
the
maximum
rate.
However,
the
treated
grain
was
not
processed.
Instead,
the
registrant
proposed
translating
data
from
a
triadimefon
wheat
grain
processing
study;
however,
these
data
cannot
be
translated
to
triadimenol
due
to
differences
in
the
use
patterns
(
seed
treatment
vs.
late
season
foliar
sprays)
that
are
likely
to
impact
the
potential
concentration
of
residues.
The
registrant
should
conduct
a
processing
study
using
the
available
wheat
grain
grown
from
the
seeds
treated
with
triadimenol
at
5x.

AGENCY
MEMORANDA
CITED
IN
THIS
REVIEW
DP
Barcodes:
D168542
and
D178884
Subject:
Triadimefon
(
109901):
Storage
Stability
Data,
PAM
Multiresidue
Methods,
Product
Chemistry
Data.
CBRS
Nos.
8566
and
9929.
From:
S.
Hummel
To
M.
Wilhite/
B.
Sidwell
Dated:
12/
22/
92
MRIDs:
41976601,
41976602,
and
42307801­
42307803
DP
Barcodes:
D222403,
D227497,
and
D227543
Subject:
Triadimefon.
Independent
Laboratory
Validation,
Radiovalidation
Data,
and
Storage
Stability
Data.
From:
J.
Punzi
To:
B.
Chambliss
Dated:
7/
13/
2000
MRIDs:
43870101,
44038901,
44041001,
and
44041002
MASTER
RECORD
IDENTIFICATION
NUMBERS
The
citations
for
the
MRID
documents
referred
to
in
this
review
are
presented
below.

44029301
Grace,
T.
(
1996)
BAYLETON
50WP
­
Magnitude
of
the
Residue
in
Wheat
Processed
Products:
Lab
Project
Number:
BL19WH02:
107130:
PR95322.
Unpublished
study
prepared
by
Bayer
Corp.;
Texas
A&
M
University;
and
Maxim
Technologies,
Inc.
2508
p.

44519801
Shen,
S.
(
1998)
Determination
of
Residues
of
Baytan
30
in
Processed
Field
Corn
Fractions:
Lab
Project
Number:
96­
003:
963HI:
43514.
Unpublished
study
prepared
by
ABC
Labs.,
Inc.
and
Gustafson
Research
and
Development
Center.
458
p.

44519802
Shen,
S.
(
1998)
Determination
of
Residues
of
Baytan
30
in
Processed
Cotton
Fractions:
Lab
Project
Number:
96­
001:
963HG:
43516.
Unpublished
study
prepared
by
ABC
Labs.,
Inc.
and
Gustafson
Research
and
Development
Center.
452
p.

44519803
Shen,
S.
(
1998)
Determination
of
Residues
of
Baytan
30
in
Processed
Wheat
Fractions:
Lab
Project
Number:
96­
002:
963HH:
43513.
Unpublished
study
prepared
by
ABC
Labs.,
Inc.
and
Gustafson
Research
and
Development
Center.
462
p.
