Page
1
of
11
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
MEMORANDUM
DATE:
26­
MAY­
2005
SUBJECT:
Health
Effects
Division
(
HED)
Human
Health
Risk
Assessment.
Request
for
Permanent
Tolerance
for
Residues
of
Triflumizole
in/
on
Imported
Greenhouse­
Grown
Tomatoes
(
PP#
3E6740)
and
Section
18
Specific
Exemption
for
the
Use
of
Triflumizole
on
Turnip
Greens
in
Texas
(
ID#
04TX20;).
Chemical
#:
128879.
DP#:
316789.
Decision#
346639.

FROM:
Jennifer
R.
Tyler,
Chemist
Mohsen
Sahafeyan,
Chemist
Mark
I.
Dow,
Ph.
D.,
Biologist
Robert
Mitkus,
Toxicologist
Registration
Action
Branch
1
(
RAB
1)
Health
Effects
Division
(
HED)
(
7509C)

THRU
PV
Shah,
Branch
Senior
Scientist
HED/
RAB1
(
7509C)

TO:
Libby
Pemberton/
Robert
Forrest,
PM
Team
05
Registration
Division
(
RD)
(
7505C)

Mary
Waller,
PM
Team
21
RD
(
7505C)

INTRODUCTION
Crompton
Corporation
has
requested
a
tolerance
of
triflumizole
and
its
metabolite
FM­
6­
1,
N­[
4­
chloro­
2­
trifluoromethylphenyl)­
n­
propoxyacetamide,
in/
on
greenhouse­
grown
tomatoes
imported
into
the
United
States
(
U.
S.)
from
the
Netherlands
and
Belgium.
It
is
formulated
as
a
150g/
L
EC
by
Certis
Europe
B.
V.
for
use
on
greenhouse­
grown
tomatoes
in
the
Netherlands
and
Belgium.
Page
2
of
11
In
addition,
in
accordance
with
40
CFR
166.20,
the
Texas
Department
of
Agriculture
(
TDA)
proposes
a
Section
18
Specific
Emergency
Exemption
for
the
use
of
triflumizole
on
turnip
greens
to
control
powdery
mildew.
The
proposed
program
will
entail
the
application
of
1200
oz.
of
Procure
50WS
[
37.5
pounds
active
ingredient
(
a.
i.)]
on
a
total
of
200
acres
of
turnip
greens
starting
October
1,
2004.

NOTE:
TDA
recently
requested
a
Section
18
Emergency
Exemption
for
the
use
of
triflumizole
on
parsley,
dandelion,
Swiss
chard,
collards,
kale,
kohlrabi,
mustard
greens,
Napa
cabbage,
broccoli
and
cilantro
to
control
Powdery
Mildew.
A
HED
human
health
risk
assessment
was
recently
conducted
in
conjunction
with
this
request,
and
the
following
information
from
that
risk
assessment
can
be
applied
directly
to
this
action
(
Memo,
J.
Tyler
et
al.;
1/
28/
05;
D306463):

°
Hazard
Characterization
(
pp.
2­
4).
°
Toxicity
Profile
and
Endpoint
Selection
summarized
in
Attachment
1
(
p.
15­
19).
°
Drinking
Water
Assessment
(
pp.
31­
32).
°
Occupational
Exposure
Assessment
(
pp.
8­
11).

This
document
contains
only
those
aspects
of
the
risk
assessment
which
are
affected
by
the
addition
of
the
tolerance
on
greenhouse­
grown
tomatoes
(
imported
only)
and
the
new
use
of
triflumizole
on
turnip
greens
in
Texas.

SUMMARY
Triflumizole
is
an
imidazole
fungicide
that
inhibits
ergosterol
biosynthesis
in
fungi.
Ergosterol
is
a
sterol
which
is
thought
to
function
as
a
stabilizer
for
the
membranes
that
make
up
the
cell
wall
of
fungi.
Triflumizole
is
currently
registered
for
use
on
apples,
cherries,
grapes,
pears,
strawberries,
cucurbit
vegetables
and
filberts
as
well
as
ornamentals
in
greenhouses,
shadehouses,
nurseries
(
including
Christmas
tree/
conifer
plantations),
and
interiorscapes.
There
are
currently
no
registered
or
proposed
homeowner
applicator
uses.
The
proposed
residential
applications
of
triflumizole
will
be
made
by
commercial
applicators
only.

HED
CONCLUSIONS/
RECOMMENDATIONS
Greenhouse­
Grown
Tomatoes:
The
toxicology,
residue
chemistry
database
is
adequate
to
support
a
permanent
tolerance
of
1.5
ppm
for
the
combined
residues
of
triflumizole
and
its
metabolites
containing
the
4­
chloro­
2­
trifluoromethylaniline
moiety,
calculated
as
the
parent
compound,
in/
on
imported
tomatoes.

Turnip
Greens:
Provided
the
label
is
amended
as
specified
on
page
7,
the
toxicology,
chemistry
and
occupational
exposure
databases
are
adequate
to
support
a
time­
limited
tolerance
of
9.0
ppm
for
the
combined
residues
of
triflumizole
and
its
metabolites
containing
the
4­
chloro­
2­
trifluoromethylaniline
moiety,
calculated
as
the
parent
compound,
in/
on
turnip,
tops.

Note
to
RD:
HED
recommends
that
the
current
tolerances
on
grape
pomace
(
15
ppm)
and
grape,
Page
3
of
11
raisin,
waste
(
10
ppm)
should
be
deleted
from
the
40
CFR
§
180.476,
as
these
are
no
longer
regulated
livestock
feed
items.
In
addition
the
tolerance
on
apple
pomace
should
also
be
deleted
since
it
is
based
on
dry
apple
pomace,
which
is
no
longer
regulated.
The
apple
processing
study
indicated
that
residues
do
not
concentrate
in
wet
apple
pomace.

EXPOSURES
AND
RISKS
In
examining
aggregate
exposure,
FQPA
directs
EPA
to
consider
available
information
concerning
exposures
from
pesticide
residues
in
food
and
all
other
non­
dietary,
non­
occupational
exposures
(
i.
e.,
residential).
The
primary
non­
food
sources
of
non­
occupational
exposure
is
drinking
water
(
from
both
groundwater
and
surface
water).
There
are
no
uses
that
would
result
in
residential
exposure
to
children.
In
evaluating
food
exposures,
EPA
takes
into
account
varying
consumption
patterns
of
major
identifiable
subgroups
of
consumers,
including
infants
and
children.

Dietary
Risks
from
Food:
A
triflumizole
acute
[
separate
assessment
for
general
U.
S.
population
(
including
infants
and
children)
and
females
13­
49
years
old]
and
chronic
dietary
exposure
(
general
U.
S.
population
and
all
population
subgroups)
assessments
were
conducted
using
the
Dietary
Exposure
Evaluation
Model
­
Food
Commodity
Intake
Database
 
(
DEEM­
FCID
 
;
ver.
2.03)
program
which
incorporates
consumption
data
from
USDA's
Continuing
Surveys
of
Food
Intakes
by
Individuals
(
CSFII),
1994­
1996
and
1998
(
Memo,
J.
Tyler,
D310514,
5/
26/
05).
The
1994­
96,
98
data
are
based
on
the
reported
consumption
of
more
than
20,000
individuals
over
two
non­
consecutive
survey
days.
Foods
"
as
consumed"
(
e.
g.,
apple
pie)
are
linked
to
EPA­
defined
food
commodities
(
e.
g.
apples,
peeled
fruit
­
cooked;
fresh
or
N/
S;
baked;
or
wheat
flour
­
cooked;
fresh
or
N/
S,
baked)
using
publicly
available
recipe
translation
files
developed
jointly
by
USDA/
ARS
and
EPA.
Consumption
data
are
averaged
for
the
entire
U.
S.
population
and
within
population
subgroups
for
chronic
exposure
assessment,
but
are
retained
as
individual
consumption
events
for
acute
exposure
assessment.

For
chronic
exposure
and
risk
assessment,
an
estimate
of
the
residue
level
in
each
food
or
foodform
(
e.
g.,
orange
or
orange
juice)
on
the
food
commodity
residue
list
is
multiplied
by
the
average
daily
consumption
estimate
for
that
food/
food
form.
The
resulting
residue
consumption
estimate
for
each
food/
food
form
is
summed
with
the
residue
consumption
estimates
for
all
other
food/
food
forms
on
the
commodity
residue
list
to
arrive
at
the
total
average
estimated
exposure.
Exposure
is
expressed
in
mg/
kg
body
weight/
day
and
as
a
percent
of
the
cPAD.
This
procedure
is
performed
for
each
population
subgroup.

For
acute
exposure
assessments,
individual
one­
day
food
consumption
data
are
used
on
an
individual­
by­
individual
basis.
The
reported
consumption
amounts
of
each
food
item
can
be
multiplied
by
a
residue
point
estimate
and
summed
to
obtain
a
total
daily
pesticide
exposure
for
a
deterministic
(
Tier
1
or
Tier
2)
exposure
assessment,
or
"
matched"
in
multiple
random
pairings
with
residue
values
and
then
summed
in
a
probabilistic
(
Tier
3/
4)
assessment.
The
resulting
distribution
of
exposures
is
expressed
as
a
percentage
of
the
aPAD
on
both
a
user
(
i.
e.,
those
who
reported
eating
relevant
commodities/
food
forms)
and
a
per­
capita
(
i.
e.,
those
who
reported
Page
4
of
11
eating
the
relevant
commodities
as
well
as
those
who
did
not)
basis.
In
accordance
with
HED
policy,
per
capita
exposure
and
risk
are
reported
for
all
tiers
of
analysis.
However,
for
Tiers
1
and
2,
significant
differences
in
user
vs.
per
capita
exposure
and
risk
are
identified
and
noted
in
the
risk
assessment.

HED's
level
of
concern
is
when
the
exposure
is
greater
than
100%
of
the
PAD.
That
is,
estimated
exposures
above
this
level
are
of
concern,
while
estimated
exposures
at
or
below
this
level
are
not
of
concern.
The
DEEM­
FCID
 
analysis
estimates
the
dietary
exposure
of
the
U.
S.
population
and
26
population
subgroups.
The
results
reported
in
Table
1
are
for
the
U.
S.
Population,
all
infants
(<
1
year
old),
children
1­
2,
children
3­
5,
children
6­
12,
youth
13­
19,
females
13­
49,
males
20­
49,
and
adults
50+
years.

Acute
Dietary
Exposure
Estimates:
Acute
dietary
exposure
assessments
were
conducted
for
the
general
U.
S.
population
(
including
infants
and
children)
and
females
13­
49
years
old
using
tolerance
level
residues
and
100%
crop
treated
(
CT)
information
for
all
registered
and
proposed
uses).
These
assessments
conclude
that
the
acute
dietary
exposure
estimates
are
below
HED's
level
of
concern
(<
100%
aPAD)
for
the
general
U.
S.
population
and
all
population
subgroups
(
children
1­
2
years
old
at
21%
aPAD)
and
females
13­
49
years
old
(
10%
aPAD).

Chronic
Dietary
Exposure
Estimates:
A
refined,
chronic
dietary
exposure
assessment
was
performed
for
the
general
U.
S.
population
and
various
population
subgroups
using
anticipated
residues
(
ARs)
from
average
field
trial
residues
for
apple,
grape,
pear,
cherry,
cucurbit,
strawberry,
and
milk
commodities;
registered
and
proposed
tolerance
for
all
other
commodities;
%
CT
information
for
apples,
grapes
and
pear
commodities;
and
100%
CT
information
for
all
other
uses).
This
assessment
concludes
that
the
chronic
dietary
exposure
estimates
are
below
HED's
level
of
concern
(<
100%
cPAD)
for
the
general
U.
S.
population
(
10%
cPAD)
and
all
population
subgroups.
The
most
highly
exposed
population
subgroup
is
Children
1­
2
years
old
at
18%
cPAD.

Table
1.
Summary
of
Dietary
Exposure
and
Risk
for
Triflumizole.

Population
Subgroup
Acute
Dietary
1
Chronic
Dietary
2
Dietary
Exposure
(
mg/
kg/
day)
%
aPAD
Dietary
Exposure
(
mg/
kg/
day)
%
cPAD
U.
S.
Population
(
total)
0.014994
6
0.001426
10
All
Infants
(<
1
year
old)
0.029856
12
0.000780
5
Children
1­
2
years
old
0.053447
21
0.002749
18
Children
3­
5
years
old
0.036997
15
0.002548
17
Children
6­
12
years
old
0.018023
7
0.001648
11
Youth
13­
19
years
old
0.009555
4
0.001282
9
Adults
20­
49
years
old
0.009750
4
0.001210
8
Adults
50+
years
old
0.011704
5
0.001441
10
Females
13­
49
years
old
0.010288
10
0.001161
8
1.
Acute
dietary
endpoints
of
0.25
and
0.1
mg/
kg/
day
applies
to
general
U.
S.
population
(
including
infants
and
children)
and
females
13­
49
years
old,
respectively.
2.
Chronic
dietary
endpoint
of
0.015
mg/
kg/
day
applies
to
the
general
U.
S.
population
and
all
population
subgroups.
Page
5
of
11
Aggregate
Risks
Aggregate
risk
assessments
were
performed
for
acute
and
chronic
aggregate
exposure
(
food
+
drinking
water).
Short­,
intermediate­
and
long­
term
aggregate
risk
assessments
were
not
performed
because,
there
are
no
registered
or
proposed
residential
uses
for
triflumizole.
A
cancer
aggregate
risk
assessment
was
not
performed
because
triflumizole
is
not
carcinogenic.
All
potential
exposure
pathways
were
assessed
in
the
aggregate
risk
assessment.

Since
HED
does
not
have
ground
and
surface
water
monitoring
data
to
calculate
a
quantitative
aggregate
exposure,
drinking
water
levels
of
comparison
(
DWLOCs)
were
calculated.
A
DWLOC
is
a
theoretical
upper
limit
on
a
pesticide's
concentration
in
drinking
water
in
light
of
total
aggregate
exposure
to
a
pesticide
through
food,
drinking
water,
and
residential
uses.
A
DWLOC
will
vary
depending
on
the
toxicity
endpoint,
drinking
water
consumption,
body
weights,
and
pesticide
uses.
Different
populations
will
have
different
DWLOCs.
HED
uses
DWLOCs
in
the
risk
assessment
process
to
assess
potential
concern
for
exposure
associated
with
pesticides
in
drinking
water.
DWLOC
values
are
not
regulatory
standards
for
drinking
water.
To
calculate
DWLOCs,
the
dietary
food
estimates
(
from
DEEM­
FCID
 
)
were
subtracted
from
the
PAD
value
to
obtain
the
maximum
water
exposure
level.
DWLOCs
were
then
calculated
using
the
standard
body
weights
and
drinking
water
consumption
figures:
70kg/
2L
(
adult
male
and
U.
S.
population),
60
kg/
2L
(
adult
female
and
youth),
and
10kg/
1L
(
infants
and
children).

Acute
Aggregate
Risk
Assessment
(
Food
and
Drinking
Water):
The
acute
aggregate
risk
assessment
considered
exposure
from
food
and
water.
The
acute
dietary
exposure
estimates
are
below
HED's
level
of
concern
(<
100%
aPAD)
for
the
general
U.
S.
population
and
all
population
subgroups
(
see
Table
1).
The
estimated
environment
concentrations
(
EECs)
generated
by
EFED
are
less
than
HED's
DWLOCs.
Acute
aggregate
risk
to
triflumizole,
as
a
result
of
all
registered
and
proposed
uses,
is
less
than
HED's
level
of
concern.
Table
2
summarizes
the
acute
aggregate
risk
to
triflumizole.

Table
2.
Acute
Aggregate
Risk
to
Triflumizole
Population
aPAD
(
mg/
kg/
day)
Acute
Food
Exposure
(
mg/
kg/
day)
Max
Acute
Water
Exposure1
(
mg/
kg/
day)
Ground
Water
EEC2
(
ppb)
Surface
Water
EEC2
(
ppb)
Acute
DWLOC3
(
ppb)

General
U.
S.
Population
0.25
0.014994
0.235006
0.12
191
8200
All
Infants
(<
1
year
old)
0.029856
0.220144
2200
Children
1­
2
years
old
0.053447
0.196553
2000
Children
3­
5
years
old
0.036997
0.213003
2100
Children
6­
12
years
old
0.018023
0.231977
2300
Youth
13­
19
years
old
0.009555
0.240445
7200
Adults
20­
49
years
old
0.009750
0.240250
8400
Adults
50+
years
old
0.011704
0.238296
8300
Females
13­
49
years
old
0.1
0.010288
0.089712
0.12
191
2700
1.
maximum
acute
water
exposure
(
mg/
kg/
day)
=
aPAD
(
mg/
kg/
day)
­
acute
food
exposure
from
DEEM
(
mg/
kg/
day);
no
res.
exp.
2.
FIRST
and
SCI­
GROW
modeling
EECs
(
Tier
1);
cherry
application
used
(
3.0
lb
ai/
A/
year)
3.
DWLOC(
µ
g/
L)
=
(
allowable
water
exposure
(
mg/
kg/
day)
x
body
weight
(
kg)
x
1000
µ
g/
mg)
÷
(
water
consumption
(
liters))
Page
6
of
11
Chronic
Aggregate
Risk
Assessment
(
Food
and
Drinking
Water):
The
chronic
aggregate
risk
assessment
considered
exposure
from
food
and
water.
The
chronic
dietary
exposure
estimates
are
below
HED's
level
of
concern
(<
100%
cPAD)
for
the
general
U.
S.
population
and
all
population
subgroups
(
see
Table
1).
The
EECs
generated
by
EFED
are
less
than
HED's
DWLOCs.
Chronic
aggregate
risk
to
triflumizole,
as
a
result
of
all
registered
and
proposed
uses,
is
less
than
HED's
level
of
concern.
Table
3
summarizes
the
chronic
aggregate
risk
to
triflumizole.

Table
3.
Chronic
Aggregate
Risk
to
Triflumizole
Population
cPAD
(
mg/
kg/
day)
Chronic
Food
Exposure
(
mg/
kg/
day)
Max
Chronic
Water
Exposure1
(
mg/
kg/
day)
Ground
Water
EEC2
(
ppb)
Surface
Water
EEC2
(
ppb)
Chronic
DWLOC3
(
ppb)

General
U.
S.
Population
0.015
0.001426
0.013574
0.12
40
500
All
Infants
(<
1
year
old)
0.000780
0.014220
140
Children
1­
2
years
old
0.002749
0.012251
120
Children
3­
5
years
old
0.002548
0.012452
120
Children
6­
12
years
old
0.001648
0.013352
130
Youth
13­
19
years
old
0.001282
0.013718
410
Adults
20­
49
years
old
0.001210
0.013790
480
Females
13­
49
years
old
0.001441
0.013559
370
Adults
50+
years
old
0.001161
0.013839
480
1
maximum
chronic
water
exposure
(
mg/
kg/
day)
=
cPAD
(
mg/
kg/
day)
­
chronic
food
exposure
from
DEEM
(
mg/
kg/
day);
no
res.
exp.
2
FIRST
and
SCI­
GROW
modeling
EECs
(
Tier
1);
cherry
application
used
(
3.0
lb
ai/
A)
3
DWLOC(
µ
g/
L)
=
(
allowable
water
exposure
(
mg/
kg/
day)
x
body
weight
(
kg)
x
1000
µ
g/
mg)
÷
(
water
consumption
(
liters))

Occupational
Exposure
and
Risk
Assessment
Greenhouse­
grown
Tomatoes:
As
the
current
request
is
for
greenhouse
tomatoes
imported
into
the
U.
S.,
there
is
no
potential
triflumizole
exposure
to
the
occupational
worker
as
a
result
of
the
proposed
use.
Therefore,
an
occupational
exposure
assessment
is
not
warranted.

Turnip
Greens:
As
mentioned
previously,
HED
recently
conducted
a
human­
health
risk
assessment
in
conjunction
with
a
Section
18
Emergency
Exemption
request
for
the
use
of
triflumizole
on
parsley,
dandelion,
Swiss
chard,
collards,
kale,
kohlrabi,
mustard
greens,
Napa
cabbage,
broccoli
and
cilantro
to
control
Powdery
Mildew
(
Memo,
J.
Tyler
et
al.;
1/
28/
05;
D306463).
An
occupational
exposure
assessment
was
conducted
in
that
risk
assessment.
As
the
proposed
use
patterns
are
the
same
as
those
used
in
previous
occupational
exposure
assessment
(
see
Table
4),
a
new
assessment
was
not
conducted.
For
occupational
handler
and
postapplication
exposure,
all
MOE's
were
greater
than
100;
therefore,
these
exposures
do
not
exceed
HED's
level
of
concern.

OTHER
CONSIDERATIONS
Residue
Chemistry
Triflumizole
is
an
imidazole
fungicide
that
inhibits
ergosterol
biosynthesis
in
fungi.
Ergosterol
is
a
sterol
which
is
thought
to
function
as
a
stabilizer
for
the
membranes
that
make
up
the
cell
wall
of
Page
7
of
11
fungi.
Permanent
tolerances
are
established
under
40
CFR
§
180.476(
a)
for
the
combined
residues
of
triflumizole
and
its
metabolites
containing
the
4­
chloro­
2­
trifluoromethylaniline
moiety,
calculated
as
the
parent
compound,
in/
on
apples,
cherries,
grapes,
pears,
strawberries,
and
cucurbit
vegetables.
In
addition
permanent
tolerances
for
livestock
commodities
have
been
established
under
40
CFR
§
180.476(
b)
for
the
combined
residues
of
triflumizole,
the
metabolite
4­
chloro­
2­
hydroxy­
6­
trifluoromethylaniline
sulfate,
and
other
metabolites
containing
the
4­
chloro­
2­
trifluoromethylaniline
moiety,
calculated
as
the
parent
compound,
in/
on
milk;
eggs;
meat,
fat,
and
meat
byproducts
(
mbyp)
of
cattle,
goats,
hogs,
horses,
and
sheep;
and
in/
on
meat,
and
mbyp
of
poultry.
A
time­
limited
tolerance
in
conjunction
with
a
Section
18
Emergency
Exemption
has
been
established
under
40
CFR
§
180.476(
a)
for
the
combined
residues
of
triflumizole
and
its
metabolites
containing
the
4­
chloro­
2­
trifluoromethylaniline
moiety,
calculated
as
the
parent
compound,
in/
on
filberts.

Summary
of
Proposed
Uses:
See
Table
4
for
a
summary
of
the
proposed
use
pattern.
A
rotational
crop
restriction
is
not
included
on
the
label
for
turnip
greens.

Table
4.
Summary
of
Directions
for
Use
of
Triflumizole
(
EC).

Applic.
Timing,
Type,
and
Equip.
Formulation
Max.
Single
Appl.
Rate
(
lb.
a.
i./
A)
Max.
No.
Appl.
per
Season
Max.
Seasonal
Appl.
Rate
(
lb.
a.
i./
A)
RTI
1
(
days)
PHI
2
(
days)

Greenhouse­
Grown
Tomatoes
in
Belgium
and
the
Netherlands
Broadcast
foliar
application
during
fruit
development
Ground
equipment
Rocket
®
EC,
No
EPA
Reg.
No.,
150
g/
L
EC
0.21
(
0.236
kg
ai/
ha)
3
0.63
(
0.71
kg
ai/
ha)
7
3
Turnip
Greens
in
Texas
Groundboom,
aerial
Procure
®
50
WS
Fungicide,
EPA
Reg.
No.
400
­
431,
50
%
a.
i.
powder
0.1875
Not
specified
0.5
10­
14
1
1
RTI
=
retreatment
interval.
2
PHI
=
preharvest
interval
HED's
Conclusions:
For
the
proposed
greenhouse­
grown
tomatoes
use,
the
Table
in
Section
B
appears
to
contain
errors
on
the
application
rate
for
triflumizole.
Based
on
the
label­
specified
dose
rate
of
a
0.1%
concentration
for
the
EC
formulation
(­
150
g/
L
EC)
in
the
spray
tank,
the
actual
rate
would
be
0.075­
0.300
kg
ai/
ha
for
application
volumes
of
500­
2000
L/
ha.
Total
rates
would
be
0.23­
0.90
kg
ai/
ha/
crop.
The
available
field
trials
were
conducted
0.308­
0.322
kg
ai/
ha/
application,
for
0.935­
0.951
kg
ai/
ha/
crop,
which
is
­
1x
the
maximum
labeled
rate.

For
the
proposed
use
on
turnip
greens,
the
label
should
be
amended
to
include
the
following
plantback
intervals
(
PBIs)
for
non­
labeled
rotational
crops:
no
restriction
for
labeled
crops,
30
days
for
leafy
vegetables,
and
60
days
for
root
vegetables.
Rotation
to
all
other
crops
is
prohibited.
Provided
these
amendments
are
made,
the
application
scenarios
are
adequately
described.
Page
8
of
11
Nature
of
the
Residue
­
Plants
and
Livestock:
The
nature
of
the
residue
in
fruit
is
adequately
understood
based
on
acceptable
metabolism
data
on
apples,
cucumbers,
grapes,
and
pears.
The
results
of
metabolism
studies
were
extensively
discussed
in
connection
with
PP#
5G3232
(
Memo,
N.
Dodd,
7/
3/
85).
HED
concluded
that
the
residues
of
concern
in/
on
apples,
pears,
cucumbers
and
grapes
include
the
parent
compound,
triflumizole
and
its
metabolites
(
free
and
conjugates)
containing
the
4­
chloro­
2­
trifluormethyaniline
moiety
(
calculated
as
triflumizole).
In
a
meeting
on
2/
26/
02,
HED
MARC
concluded
that
there
was
no
need
to
revisit
the
residues
of
concern
in
primary
crops
(
Memo,
J.
Tyler,
3/
13/
02;
D280869).
The
MARC
concurred
with
the
current
tolerance
expression
for
plants
as
stated
in
40
CFR
§
180.476.

There
are
no
livestock
feed
items
associated
with
the
proposed
uses;
therefore,
a
discussion
of
potential
transfer
of
secondary
residues
to
livestock
commodities
is
not
relevant
to
the
proposed
uses.

Storage
Stability:
No
storage
stability
data
were
submitted
to
support
the
current
actions.
Previously
reviewed
data
indicate
that
triflumizole
is
stable
for
up
to
10
months
in
frozen
cucurbit
vegetables
(
MRID
449713­
01
thru
­
03;
Memo,
J.
Tyler,
3/
11/
02;
D271003)
and
strawberries
(
MRID
45375406;
J.
Tyler,
3/
11/
02;
D274589)
and
up
to
­
12
months
in
frozen
cherries
(
MRID
44438401;
Memo,
J.
Tyler,
4/
30/
01;
D242429)
and
apples
and
grapes
(
MRID
41131203;
Memo,
S.
Malak,
1/
25/
90,
DEB#
s
5479
&
5480).
These
data
support
the
submitted
residue
studies
on
turnip
greens
and
tomatoes
in
which
the
samples
were
analyzed
within
­
2
month
of
sampling.

Magnitude
of
the
Residue
­
Plants:

Greenhouse­
Grown
Tomatoes
46026303.
der
To
support
the
use
of
triflumizole
(
EC)
on
greenhouse­
grown
tomatoes
in
the
Netherlands
and
Belgium
for
export
to
the
U.
S.,
Crompton
has
submitted
field
trial
data
from
a
total
of
8
tomato
greenhouse
trials
conducted
in
the
Netherlands
(
4
trials)
and
Belgium
(
4
trials),
which
together
account
for
#
5%
of
the
fresh
tomatoes
imported
into
the
U.
S.
The
results
from
the
these
greenhouse
trials
are
discussed
below
and
summarized
in
Table
5.

Table
5.
Summary
of
Residue
Data
for
Tomatoes
from
Greenhouse
Trials
using
Triflumizole
(
EC).

Commodity
Form.
Total
Rate
(
kg
ai/
ha)
PHI
(
days)
1
Residues
Residue
Levels
(
ppm)
3
n
Min.
Max.
HAFT
2
Median
Mean
Std.
Dev.

Tomato
fruit
150
g/
L
EC
0.938­
0.952
3
Triflumizole
10
0.12
0.73
0.73
0.24
0.30
0.17
FM­
6­
1
10
<
0.1
0.10
0.1
<
0.1
<
0.1
<
0.01
Combined
5
10
<
0.28
<
0.85
<
0.85
<
0.37
<
0.48
<
0.23
1
The
proposed
PHI
for
tomatoes
is
3
days.
2
HAFT
=
Highest
Average
Field
Trial.
3
Combined
residues
are
expressed
in
parent
equivalents.
4
The
calculated
combined
residues
are
based
on
using
½
LOQ
(
i.
e.,
0.1/
2)
for
residues
of
FM­
6­
1
and
multiplying
by
1.17
to
convert
to
the
parent
equivalent.
However
for
tolerance
setting,
the
LOQ
value
of
0.1
ppm
(
instead
of
0.05
ppm)
was
used
and
therefore,
the
maximum
combined
residue
in
the
above
Table
(
0.79
ppm),
is
recalculated
to
be
0.83
ppm.
Page
9
of
11
In
each
trial,
triflumizole
(
150
g/
L
EC)
was
applied
to
tomatoes
as
three
broadcast
foliar
applications
at
308­
322
g
ai/
ha,
for
a
total
of
0.935­
0.952
kg
ai/
ha/
crop
(­
1x).
Applications
were
made
during
fruit
development
at
retreatment
intervals
(
RTIs)
of
7
days.
Tomato
fruit
were
harvested
at
commercial
maturity,
3
days
after
treatment
(
DAT),
from
all
trials,
and
additional
tomato
samples
were
harvested
at
0,
1,
and
7
DAT
from
one
trial
each
in
the
Netherlands
and
Belgium
to
examine
residue
decline.
A
single
control
and
duplicate
treated
samples
were
collected
from
each
trial
at
each
interval.
Samples
were
stored
frozen
from
collection
to
analysis
for
up
to
­
2
months,
an
interval
supported
by
available
storage
stability
data.

Although
adequately
validated
for
the
determination
residues
of
triflumizole
and
FM­
6­
1
in/
on
tomatoes
at
levels
ranging
from
­
0.1­
1.0
ppm,
the
high­
performance
liquid
chromatography
with
ultraviolet
detection
(
HPLC/
UV)
method
(
BCO
Project
No.
3096040728)
used
for
determining
residues
is
not
adequate
for
data
collection
as
it
does
not
account
for
all
of
the
triflumizole
residues
of
concern.
In
addition,
residues
of
FM­
6­
1
in/
on
treated
tomatoes
were
below
the
lower
limit
of
method
validation.

Residues
of
triflumizole
per
se
were
0.12­
0.73
ppm
in/
on
10
samples
of
greenhouse­
grown
tomatoes
harvested
3
days
following
the
last
of
3
foliar
applications
of
triflumizole
(
EC)
at
­
1x.
Residues
of
Metabolite
FM­
6­
1
were
<
0.1­
0.10
ppm
in/
on
the
same
tomato
samples,
for
combined
residues
of
<
0.28­<
0.85
ppm
(
parent
equivalents).
The
calculated
combined
residues
were
based
on
using
limit
of
quantitation
(
LOQ)
(
0.1
ppm)
for
residues
of
FM­
6­
1
and
multiplying
by
1.17
to
convert
to
parent
equivalent.
Average
combined
residues
were
<
0.48
ppm,
and
combined
HAFT
residues
were
<
0.85
ppm.
In
the
residue
decline
trials,
residues
of
both
analytes
remained
relatively
steady
from
0
to
7
DAT.

HED
Conclusions.
The
number
and
geographic
representation
of
the
submitted
tomato
field
trials
are
adequate
to
support
a
tolerance
on
greenhouse
tomatoes
imported
from
the
Netherlands
and
Belgium.
An
adequate
number
of
trials
were
conducted
at
1x
the
maximum
labeled
use
rate
in
both
countries.
Although
duplicate
treated
samples
from
each
trial
are
normally
required
to
be
analyzed
since
adequate
number
of
samples
(
n=
10)
were
provided,
this
requirement
is
waived.

Although
the
analytical
method
(
BCO
Project
No.
3096040728)
was
validated
for
parent
and
the
FM­
6­
1
metabolite
only,
HED
made
an
estimate
(
1.2
ppm)
for
all
the
residues
of
concern
based
on
a
cucumber
metabolism
study
(
N.
Dodd,
PP#
5G3232,
Accession
Nos.
073456,
073457,
073461,
7/
3/
85).
This
estimate
was
based
on
the
maximum
combined
residues
of
triflumizole
and
FM­
6­
1
in
the
submitted
tomato
study
(
0.85
ppm,
based
on
taking
<
LOQ
residues
of
FM­
6­
1
as
LOQ,
converting
it
to
the
parent
equivalent
and
adding
it
to
the
maximum
residue
of
the
parent),
and
the
assumption
that
combined
residues
of
triflumizole
and
FM­
6­
1
constituted
71.5%
of
TRR
as
in
cucumber
metabolism
study.

Turnip
Greens
TDA
cited
the
results
of
a
crop
field
trial
study
performed
on
turnip
leaves
in
Texas
in
2003
(
MRID#
46212401;
Region
6;
one
field
trial).
This
study
has
been
submitted
to
the
Agency,
and
HED
has
completed
a
preliminary
review
of
this
study.
Residues
of
triflumizole
were
4.30
ppm,
8.87
ppm,
and
8.11
ppm
(
average
7.09
ppm)
in
turnip
leaf
samples
collected
1
day
following
the
last
of
5
applications
of
Procure
®
50WS
at
0.25
lb
a.
i./
A
[
total
application
rate
of
1.25
lb.
a.
i./
A;
7­
day
retreatment
interval
(
RTI);
ground
airblast
applications].
Page
10
of
11
HED
Conclusions:
The
available
residue
data
show
that
residues
of
triflumizole
are
#
8.87
ppm
in
turnip
leaves
when
treated
with
a
total
of
1.25
lb
a.
i./
A/
year
(
5
applications
of
0.25
lb.
a.
i./
A/
application)
with
a
RTI
of
7
days
and
preharvest
interval
(
PHI)
of
1
day.
Although
the
application
rate
are
2.5x
the
proposed
total
application
rate,
the
submitted
data
are
adequate
and
support
time­
limited
tolerance
of
9.0
ppm
for
the
combined
residues
of
triflumizole
and
its
metabolites
containing
the
4­
chloro­
2­
trifluoromethylaniline
moiety,
calculated
as
the
parent
compound,
in/
on
turnip,
tops.

Processed
Food
and
Feed:

Greenhouse­
Grown
Tomatoes:
A
tomato
processing
study
was
not
submitted
with
the
current
petition.
As
greenhouse
tomatoes
in
the
Netherlands
and
Belgium
are
grown
only
for
the
fresh
market,
a
processing
study
is
not
required
for
this
use.

Turnip
Greens:
As
there
are
no
processed
commodities
associated
with
turnip
greens,
a
processing
study
is
not
required
to
support
the
current
action.

Magnitude
of
the
Residue
­
Livestock:
As
there
are
no
livestock
feed
items
associated
with
the
proposed
uses,
data
on
residues
of
triflumizole
in
livestock
tissues,
milk
and
eggs
are
not
required
to
support
the
current
actions.

Residues
in
Rotational
Crops:

Greenhouse­
Grown
Tomatoes:
As
the
proposed
use
is
for
tomatoes
grown
outside
the
U.
S.,
confined
and
field
rotational
crop
studies
are
not
required
for
establishing
an
import
tolerance
for
residues
in/
on
tomatoes.

Turnip
Greens:
Results
of
confined
and
limited
field
rotational
crop
studies
were
reviewed
in
the
HED
memoranda
dated
3/
11/
02
(
Memo,
J.
Tyler;
D274589).
HED
concluded
that
the
following
PBIs
are
appropriate:
no
restriction
for
labeled
crops,
30
days
for
leafy
vegetables,
and
60
days
for
root
vegetables.
Because
quantifiable
residues
were
found
in
wheat
commodities
at
the
longest
adequate
PBI
tested
(
120
days),
rotation
to
wheat
and
all
other
crops
is
not
permitted.
The
petitioner
should
submit
adequate
limited
field
rotational
crop
data
on
wheat
at
PBIs
longer
than
120
days.
Alternatively,
the
petitioner
has
the
option
of
submitting
a
full
set
of
residue
field
trials
on
all
intended
rotational
crops
other
than
leafy
and
root
vegetables.
The
petitioner
should
amend
the
proposed
Section
B
to
specify
the
aforementioned
rotational
crop
restrictions.

Analytical
Enforcement
Method
­
Plants:

Greenhouse­
Grown
Tomatoes
46026301.
der
In
conjunction
with
tomato
greenhouse
trials,
the
petitioner
submitted
a
method
description
and
validation
data
for
an
HPLC/
UV
method
(
BCO
Project
No.
3096040728)
for
determining
residues
of
triflumizole
and
its
metabolite
FM­
6­
1
in/
on
tomatoes.
For
this
method,
residues
of
triflumizole
and
FM­
6­
1
are
extracted
from
homogenized
tomatoes
with
hexane:
dichoromethane
(
CH
2
Cl
2
,
1:
1,
v/
v)
and
anhydrous
sodium
sulfate
and
then
centrifuged.
Residues
are
cleaned
up
using
a
silica
solidphase
extraction
(
SPE)
column
eluted
with
CH
2
Cl
2
:
ethyl
acetate
(
EtOAc,
7:
3),
concentrated,
and
analyzed
by
HPLC/
UV
(
240
nm)
using
a
NH
2
column.
The
reported
method
LOQ
is
0.01
and
0.02
Page
11
of
11
ppm
for
triflumizole
and
FM­
6­
1,
respectively,
and
the
limits
of
detection
(
LODs)
are
0.005
and
0.009
ppm.
However,
the
LOQ,
based
on
the
lowest
level
of
method
validation,
should
be
0.10
ppm
for
both
triflumizole
and
FM­
6­
1.

Method
validation
recoveries
from
control
tomato
samples
fortified
with
each
analyte
at
0.1­
1.0
ppm
averaged
76%
for
both
triflumizole
and
FM­
6­
1,
with
relative
standard
deviations
(
RSD)
of
10­
12%.
Procedural
method
recoveries
were
also
acceptable
(
85­
100%)
from
tomato
samples
fortified
with
each
analyte
at
­
0.1­
1.0
ppm
and
analyzed
concurrently
with
the
treated
samples.
Apparent
residues
in
control
samples
were
reported
to
be
below
the
LOQ
for
both
analytes.
Although
recoveries
of
the
two
analytical
were
adequate
through
this
method,
the
HPLC/
UV
method
is
not
adequate
for
data
collection
as
does
not
account
for
all
the
regulated
residues.

HED
Conclusions.
Although
the
HPLC/
UV
method
was
adequately
validated
for
determining
residues
of
triflumizole
and
its
metabolite
FM­
6­
1
in/
on
tomatoes,
this
method
does
not
account
for
all
of
the
residues
of
concern.
As
indicated
above,
the
residues
of
concern
include
triflumizole
and
its
metabolites
containing
the
4­
chloro­
2­
trifluoromethyaniline
moiety
(
calculated
as
triflumizole).
In
addition,
validation
data
were
not
provided
to
support
recoveries
at
the
reported
method
LOQ,
which
was
approximately
the
estimated
level
of
FM­
6­
1
residues
in/
on
treated
tomatoes.

Turnip
Greens
The
methods
used
in
the
crop
field
trials
are
suitable
for
data
gathering
purposes.
The
gas
chromatography/
mass
selective
detector
(
GC/
MSD)
method
(
Morse
Method
METH­
115,
Revision
#
3)
used
in
the
turnip
greens
crop
field
trial
has
a
validated
LOQ
of
0.05
ppm.
Morse
Method
METH­
115,
Revision
#
3
converts
residues
of
triflumizole
and
its
aniline­
containing
metabolites
to
4­
chloro­
2­
trifluoromethylaniline
(
FA­
1­
1)
which
is
then
quantified
as
triflumizole
equivalents.
A
similar
GC/
nitrogen­
phosphorus
detector
(
NPD)
method
has
been
deemed
acceptable
as
a
tolerance
enforcement
method
in
conjunction
with
a
petition
for
use
on
apples,
grapes,
and
pears,
and
has
been
forwarded
to
FDA
for
inclusion
in
the
Pesticide
Analytical
Manual
(
PAM),
Volume
II
as
Method
I
(
G.
Kramer,
12/
16/
94).
For
the
purposes
of
this
petition,
HED
concludes
that
the
current
enforcement
method
is
appropriate
for
enforcement
of
the
tolerance
associated
with
this
petition.

Analytical
Enforcement
Method
­
Livestock:
There
are
no
livestock
feed
items
associated
with
the
proposed
uses;
therefore,
data
collection
and
tolerance
enforcement
methods
for
livestock
commodities
are
not
required
for
the
establishment
of
a
tolerance
for
triflumizole
residues
in/
on
the
proposes
uses.

Multiresidue
Methods:
The
Food
and
Drug
Administration
(
FDA)
PESTDATA
database
(
PAM
Volume
I,
Appendix
I,
3rd
edition,
1994)
indicates
that
triflumizole
is
completely
recovered
(>
80%)
by
Multiresidue
Protocol
D
(
PAM
I
Sections
232.4).

cc:
J.
Tyler
(
RAB1),
R.
Mitkus
(
RAB1),
M.
Dow
(
RAB1)
RDI:
RA
Team
(
5/
25/
05),
PV
Shah
(
5/
25/
05)
J.
Tyler:
809B:
CM#
2:
(
703)
305­
5564:
7509C:
RAB1
