Page
1
of
23
UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
MEMORANDUM
Date:
February
28,
2006
Subject:
TCMTB.
Summary
of
Analytical
Chemistry
and
Residue
Data
for
the
Reregistration
Eligibility
Decision
(
RED)
Document.

DP
Barcode:
D322617
PC
Code:
035603
40
CFR
§
:
180.288
Chemical
Class:
Benzothiazole
From:
Samuel
Ary,
Chemist
Reregistration
Branch
II
Health
Effects
Division
(
7509C)

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

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

To:
Deborah
Smegal,
Risk
Assessor
Reregistration
Branch
I
Health
Effects
Division
(
7509C)

Kathryn
Avivah
Jakob,
Chemical
Review
Manager
Regulatory
Management
Branch
II
Antimicrobial
Division
(
7510C)
OFFICE
OF
PREVENTION,
PESTICIDES,
AND
TOXIC
SUBSTANCES
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
DP
Barcode:
322617
Page
2
of
23
Executive
Summary
As
an
antimicrobial
pesticide,
TCMTB
[(
2­
benzothiazolylthio)
methyl
thiocyanate]
is
used
largely
as
a
wood
preservative.
It
is
also
used
as
a
microbiocide/
microbiostat
and
bacteriocide/
bacteriostat
in
industrial
processes
and
water
systems,
as
well
as
in
industrial
materials,
as
a
preservative.
As
an
agricultural
pesticide,
TCMTB
is
a
fungicide
used
as
a
seed
treatment
on
barley,
corn,
cotton,
oat,
rice,
safflower,
sorghum,
sugar
beet,
and
wheat.

The
reregistration
of
TCMTB
is
being
supported
by
Bayer
CropScience
(
Bayer)
and
Wilbur­
Ellis
Company
(
Wilbur­
Ellis).
TCMTB
food/
feed
end­
use
products
are
marketed
in
the
United
States
under
the
trade
names
Busan
®
,
Cotguard
®
,
Nusan
®
,
and
Nu­
Flow
®
.
The
Bayer
and
Wilbur­
Ellis
TCMTB
formulations
registered
for
food/
feed
uses
include
emulsifiable
concentrate
(
EC)
and
soluble
concentrate
(
SC).
For
food/
feed
uses,
Bayer
is
supporting
TCMTB
use
on
cotton
only,
while
Wilbur­
Ellis
is
supporting
uses
on
barley,
cotton,
oat,
rice,
wheat,
safflower,
and
sugar
beet.
The
technical
registrant
of
TCMTB,
Buckman
Laboratories,
Inc.
(
Buckman)
has
requested
cancellation
of
all
food/
feed
uses.
Therefore,
use
on
corn
and
sorghum
is
no
longer
being
supported.
Bayer
and
Wilbur­
Ellis
will
be
responsible
for
providing
the
Agency
with
the
appropriate
data
needed
to
maintain
the
supported
uses
on
their
product
labels.

Tolerances
are
established
for
residues
of
the
fungicide
2­(
thiocyanomethylthio)
benzothiazole
in/
on
barley
(
grain
and
straw),
sugar
beets
(
roots
and
tops),
corn
(
forage,
grain,
and
stover),
cotton
(
forage
and
undelinted
seed),
oats
(
forage,
grain,
hay,
and
straw),
rice
(
grain
and
straw),
safflower
(
seed),
sorghum
(
forage,
grain,
and
stover),
and
wheat
(
forage,
grain,
hay,
and
straw)
at
40
CFR
§
180.288.
The
permanent
tolerances
for
residues
in
plant
commodities
are
established
at
the
limit
of
quantitation
(
LOQ)
of
0.1
ppm
(
N).
The
"
N"
designation,
denoting
"
negligible"
residues
must
be
deleted
from
40
CFR
§
180.288.

The
reregistration
requirements
for
plant
metabolism
have
not
been
fulfilled.
Data
have
been
submitted
depicting
the
uptake
of
TCMTB
in
corn,
cotton,
safflower,
and
wheat
and
were
found
to
be
inadequate
due
to
lack
of
identification
and/
or
characterization
of
parent
and/
or
metabolites.
Additional
metabolism
studies
conducted
with
tomatoes
and
melons
have
been
submitted
and
briefly
reviewed;
however,
translation
to
the
currently
registered
crops
is
not
adequate
for
reregistration
purposes.
Confirmatory
metabolism
data
should
be
submitted
depicting
the
nature
of
residues
in
wheat,
cotton,
and
sugar
beets.
Adequate
identification
and/
or
characterization
of
parent
and/
or
metabolites
should
be
conducted
as
required
by
OPPTS
860
Series
Guidelines.
The
Risk
Assessment
Review
Committee
(
RARC)
met
and
determined
that
the
interim
residue
of
concern
for
tolerance
expression
and
risk
assessment
is
TCMTB
in/
on
plants
(
P.
Deschamp,
Report
of
the
RARC,
1/
11/
2006).
This
is
a
preliminary
decision
and
the
additional
confirmatory
plant
metabolism
data
should
be
submitted
in
a
timely
manner.

No
livestock
metabolism
studies
have
been
submitted
for
review.
Livestock
metabolism
studies
may
be
required
if
the
requested
plant
metabolism
studies
show
uptake
of
residues.
If
livestock
metabolism
studies
are
required,
the
registrant
must
provide
poultry
and
ruminant
metabolism
studies
following
OPPTS
860
Series
Guidelines.

A
tolerance
enforcement
method
is
available
for
determining
thiobenzothiazole­
containing
residues
in
barley,
corn,
cotton,
oat,
rice,
safflower,
sugar
beet,
and
wheat.
This
method
was
originally
submitted
with
Pesticide
Petition
(
PP)
0F0954
by
Buckman.
Residues
are
converted
to
2­
chlorobenzothiazole,
which
is
determined
by
a
gas­
liquid
chromatography
(
GLC)
method
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
DP
Barcode:
322617
Page
3
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using
an
electron
capture
detector
(
ECD).
The
quantitation
limit
of
the
method
has
been
determined
at
0.10
ppm.
This
method
is
listed
as
Method
B
in
PAM
Vol.
II.
The
method
is
outdated
and
uses
toxic
reagents;
therefore,
if
an
additional
method
that
is
adequate
for
tolerance
enforcement
is
available,
it
should
be
submitted
immediately
for
review.

Two
data­
collection
methods
are
available
for
determining
thiocyanate­
containing
residues.
The
first
method
was
originally
submitted
with
PP
0F0954
by
Buckman
for
the
determination
of
residues
in
barley,
corn,
cottonseed,
oat,
rice,
and
wheat.
The
method
is
listed
as
Method
I
in
PAM
Vol.
II.
The
second
method
was
originally
submitted
with
PP
5F1613
by
Buckman
for
the
determination
of
residues
in
safflower
seed,
sorghum
grain
and
foliage,
and
sugar
beet
and
foliage.
The
method
is
listed
as
Method
A
in
PAM
Vol.
II.
Residues
are
converted
from
thiocyanate
to
cyanogen
bromide;
then
the
cyanogen
bromide
is
treated
with
pyridine­
benzidine
reagent
to
form
an
intensely
colored
dye.
The
absorbance
of
the
dye
solution
is
determined
at
532
nm.
In
a
method
tryout
(
Method
I),
the
Agency
obtained
recoveries
of
90%
and
110%
(
duplicate
samples)
at
the
0.10
ppm
fortification
level
and
105%
and
115%
(
duplicate
samples)
at
the
0.20
ppm
fortification
level.
The
quantitation
limit
of
both
methods
has
been
determined
at
0.10
ppm.

If
the
requested
metabolism
studies
show
additional
residues
are
of
concern
and
the
current
enforcement
method
does
not
capture
these
additional
residues,
development
of
a
method
capable
of
doing
so
will
be
required.

The
requirement
of
a
tolerance
enforcement
method
for
livestock
is
put
on
reserve
pending
the
results
from
the
requested
plant
metabolism
studies,
and,
if
required,
the
livestock
metabolism
studies.

The
FDA
PESTDATA
database
dated
11/
2001
(
PAM
Volume
I,
Appendix
I)
indicates
that
TCMTB
per
se
is
completely
recovered
(>
80%)
using
Multiresidue
Methods
Section
302
(
Luke
Method),
but
is
only
partially
recovered
(
50­
80%)
using
303
(
Mills,
Onley,
Gaither
Method)
and
304
(
Mills
fatty
food
Method).
If
additional
residues
of
concern
are
determined
from
the
requested
metabolism
studies,
all
additional
residues
of
concern
for
tolerance
expression
will
need
to
be
tested
through
Multiresidue
Methods.

Storage
stability
data
for
TCMTB
in/
on
barley,
cotton,
oat,
rice,
wheat,
safflower,
and
sugar
beet
have
not
been
submitted
by
the
registrant.
No
data
were
provided
on
how
long
samples
from
the
submitted
field
trials
were
stored
prior
to
analysis;
therefore,
storage
stability
data
for
the
previously
submitted
field
trials
are
required
and
should
be
submitted
immediately.
Additionally,
if
field
trials
are
required
or
additional
uses
are
requested,
concurrent
storage
stability
data
will
be
required
under
this
guideline
topic.

TCMTB
is
not
intended
for
application
to
livestock
and
no
livestock
feeding
studies
have
been
submitted.
The
grain
crops,
their
byproducts
and
forages,
are
livestock
feed
items.
It
is
therefore
necessary
to
consider
if
TCMTB
residues
are
transferred
to
meat,
milk,
poultry,
and
eggs
of
livestock
through
ingestion
of
the
residue
bearing
commodities.
It
has
been
indicated
in
the
foregoing
considerations
that
the
nature
of
residue
in
plants
has
not
been
adequately
described.
In
the
absence
of
such
data,
the
residue
level
is
unclear.
If
the
requested
residue
data
show
finite
residues
in
the
feed
items,
livestock
feeding
studies
would
be
essential
to
an
evaluation
of
the
transfer
of
residues
to
milk,
meat,
poultry,
and
eggs.
Therefore,
no
valid
conclusions
relative
to
40
CFR
§
180.6
(
the
necessity
of
tolerances
in
livestock
commodities)
can
be
made
in
the
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
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absence
of
livestock
feeding
studies.

The
available
field
trial
data
are
not
adequate
according
to
current
OPPTS
860
Series
Guidelines.
The
correct
number
of
field
trials,
number
of
samples
collected,
and
locations
of
trials
are
all
insufficient.
Additionally,
no
storage
stability
data
was
submitted
with
the
field
trial
studies
and
the
application
rates
are
unknown
for
the
barley,
corn,
oat,
rice,
and
wheat
studies.
The
method
used
for
determining
residues
in
barley,
corn,
oat,
rice,
and
wheat
is
the
data­
collection
method
which
only
determines
the
thiocyanate
ion
(
Method
I
or
A
in
PAM
Vol.
II).
The
method
used
for
determining
residues
in
cotton
is
the
tolerance
enforcement
method
which
determines
thiobenzothiazole­
containing
residues
(
Method
B
in
PAM
Vol.
II).
If
the
requested
metabolism
studies
show
additional
metabolites
of
concern
are
expected,
new
field
trials
should
be
conducted
using
a
method
which
is
capable
of
determining
all
residues
of
concern
as
determined
by
the
tolerance
expression.
Additionally,
tolerances
should
be
proposed
in/
on
barley
hay
and
cotton
gin
byproducts
as
these
are
now
considered
significant
livestock
feed
items
according
to
Table
1
of
OPPTS
860.1000.
Field
trial
data
are
not
available
for
sugar
beets;
therefore,
magnitude
of
residue
data
in
sugar
beets
should
be
submitted
following
all
OPPTS
860
Series
Guidelines.

No
processing
studies
have
been
submitted.
Once
the
requested
metabolism
studies
have
been
submitted,
reviewed,
and
the
metabolites
of
concern
are
determined,
data
should
be
submitted
which
show
whether
residues
concentrate
in
the
byproducts
of
the
registered
raw
agricultural
commodities.

No
confined
accumulation
data
in
rotational
crops
are
available;
however,
soil
persistence
studies
are
available.
The
registrant
should
provide
confirmatory
method
data
along
with
storage
stability
data
in
order
for
the
data
to
be
considered
scientifically
adequate.
Contingent
upon
the
adequacy
of
the
storage
stability
and
method
data,
soil
persistence
is
not
likely
to
be
a
concern
with
respect
to
follow­
up
crops.
However,
the
method
used
is
unknown
and
the
exact
compounds
that
make
up
the
residues
found
is
unknown;
therefore,
this
data
requirement
is
put
on
reserve
awaiting
submission
of
the
requested
data
and
pending
the
results
from
the
plant
metabolism
studies.

Residue
Chemistry
Deficiencies
and
Regulatory
Guidelines
1.
Confirmatory
metabolism
data
should
be
submitted
depicting
the
nature
of
residues
in
wheat,
cotton,
and
sugar
beets.

2.
The
available
enforcement
method
(
Method
B
in
PAM
Vol.
II.)
is
outdated
and
uses
toxic
reagents;
therefore,
if
an
additional
method
that
is
adequate
for
tolerance
enforcement
is
available,
it
should
be
submitted
immediately
for
review.

3.
Storage
stability
data
were
not
included
with
the
original
field
trial
data
submissions;
therefore,
storage
stability
data
for
the
previously
submitted
field
trials
are
required
and
should
be
submitted
immediately.

4.
Storage
stability
and
method
data
were
not
provided
with
the
original
soil
persistence
studies
summarized
under
OPPTS
860.1850
in
this
document.
Storage
stability
and
method
data
are
required
and
should
be
submitted
immediately.

5.
Application
rates
in
lbs
a.
i./
100
lbs
seed
for
all
the
submitted
field
trial
studies
should
be
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
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provided.

6.
Tolerances
for
barley
hay
and
cotton
gin
byproducts
should
be
proposed
once
the
requested
metabolism
data
are
submitted
and
reviewed.

7.
Data
should
be
submitted
which
show
whether
residues
concentrate
in
the
byproducts
of
the
registered
raw
agricultural
commodities.

8.
Magnitude
of
residue
data
in
sugar
beets
following
all
OPPTS
860
Series
Guidelines
should
be
submitted.

9.
Additionally,
numerous
OPPTS
860
Series
Guidelines
have
been
placed
on
reserve
pending
the
requested
plant
metabolism
data
(
see
Table
4).

Background
The
TCMTB
Phase
4
Review
dated
3/
11/
1991
summarized
the
status
of
available
residue
chemistry
data
for
the
reregistration
of
TCMTB.
The
Phase
4
Review
requested
plant
metabolism
data
on
corn
or
wheat,
cotton,
and
sugar
beet.
Data
requirements
for
livestock
metabolism,
residue
analytical
methods,
storage
stability,
and
magnitude
of
the
residue
in
plants
were
put
on
reserve
status
pending
the
results
from
the
plant
metabolism
studies.
This
document
presents
an
overall
and
up­
to­
date
Residue
Chemistry
Science
Assessment
with
respect
to
the
reregistration
of
TCMTB.
The
PC
Code
and
nomenclature
of
TCMTB
are
listed
below
in
Table
1
and
the
physicochemical
properties
are
listed
in
Table
2.
The
structure
of
TCMTB
and
metabolites/
degradates
of
concern
are
presented
in
Table
3.

Table
1.
TCMTB
Nomenclature.

Chemical
structure
N
S
S
S
N
Common
name
TCMTB
or
TCMB
Molecular
formula
C9H6N2S3
IUPAC
name
2­(
thiocyanomethylthio)
benzothiazole
CAS
name
(
2­
benzothiazolylthio)
methyl
thiocyanate
CAS
number
21564­
17­
0
PC
Code
035603
Supported
food/
feed
site
uses
barley,
cotton,
oat,
rice,
safflower,
sugar
beet,
and
wheat
Table
2.
Physicochemical
Properties
of
TCMTB
Parameter
Value
Reference
Molecular
weight
238.35
g/
mol
Merck
Index
12th
Edition
Melting
point/
range
Not
applicable
(
NA)
for
liquids
NA
Boiling
point/
range
Decomposed
at
191
E
C
at
741.9
mm
Hg
C.
Jiang,
D322899,
11/
17/
05
pH
5.99
(
1:
100
dilution
in
water)
C.
Jiang,
D322899,
11/
17/
05
Density
1.3761
g/
cm3
C.
Jiang,
D322899,
11/
17/
05
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
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DP
Barcode:
322617
Page
6
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23
Table
2.
Physicochemical
Properties
of
TCMTB
Parameter
Value
Reference
Water
solubility
45
mg/
L
C.
Jiang,
D322899,
11/
17/
05
Vapor
pressure
1.45
x
10­
4
mm
Hg
at
20
E
C
1.72
x
10­
4
mm
Hg
at
25
E
C
C.
Jiang,
D322899,
11/
17/
05
Vapor
pressure1
2.44
x
10­
10
mm
Hg
at
20
E
C
4.04
x
10­
10
mm
Hg
at
25
E
C
C.
Jiang,
D322899,
11/
17/
05
Dissociation
constant,
pKa
NA
NA
Octanol/
water
partition
coefficient
log
Kow
of
3.23
at
20
E
C
C.
Jiang,
D322899,
11/
17/
05
Viscosity
352.4
cSt
C.
Jiang,
D322899,
11/
17/
05
1.
Tests
done
with
pure
active
ingredient
(
PAI).

Table
3.
Chemical
Names,
Metabolism
Data,
and
Structures
of
TCMTB
and
Its
Metabolites/
Degradates.

Percent
TRR1
Chemical
Name
Commodity
Major
Residue
(>
10%
TRR)
Minor
Residue
(<
10%
TRR)
Structure
Melon
fruit
ND2
Melon
plant
0.9%

Tomato
fruit
ND
Tomato
plant
ND
TCMTB
[
2­
benzothiazolylthio)
methyl
thiocyanate]
CAS
number:
21564­
17­
0
Aerobic
soil
(
58
DPT3)
0.6%
N
S
S
S
N
Melon
fruit
31.9%

Melon
plant
14.0%

Tomato
fruit
61.7%

Tomato
plant
32.6%
2­
BTSA
[
2­
benzothiazolesulfonic
acid]

Aerobic
soil
(
58
DPT)
70.8%
N
S
SO
3
H
Melon
fruit
8.4%

Melon
plant
2.6%

Tomato
fruit
8.5%
OH­
2­
BTSA4,5
[
2­(
hydroxybenzothiazolyl)
sulfonic
acid]

Tomato
plant
21.2%
N
S
SO
3
H
O
H
Melon
fruit
1.3%

Melon
plant
2.5%

Tomato
fruit
ND
Tomato
plant
ND
2­
OH­
BT
[
2­
hydroxybenzothiazole]
or
BTOL
[
2­
benzothiazolol]
CAS
number:
934­
34­
9
Aerobic
soil
(
21
DPT)
7.0%
N
S
OH
Melon
fruit
0.7%

Melon
plant
0.1%

Tomato
fruit
ND
Tomato
plant
ND
Cotton
forage
ND
Aerobic
soil
(
1.5
DPT)
30.3%
2­
MBT
or
2­
SH­
BT
[
2­
mercaptobenzothiazole]
CAS
number:
149­
30­
4
Aerobic
soil
(
14­
21
DPT)
0.3­
0.4%
N
S
SH
TCMTB
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Table
3.
Chemical
Names,
Metabolism
Data,
and
Structures
of
TCMTB
and
Its
Metabolites/
Degradates.

Percent
TRR1
Chemical
Name
Commodity
Major
Residue
(>
10%
TRR)
Minor
Residue
(<
10%
TRR)
Structure
2,2'­
DTBB
or
DBB
[
2,2'­
dithiobis(
benzothiazole)
CAS
number:
120­
78­
5
Aerobic
soil
(
maximum
at
1
DPT)
6.7%

N
S
S
S
N
S
1.
TRR
=
Total
radioactive
residue.
2.
ND
=
Not
detected.
3.
DPT
=
Days
post­
treatment.
4.
Two
isomers
make
up
2­(
hydroxybenzothiazolyl)
sulfonic
acid.
The
exact
position
of
the
hydroxyl
group
was
not
determined.
The
numbers
presented
in
the
table
are
the
summation
of
the
two
isomers.
The
following
is
the
breakdown
of
TRR
for
each
isomer
(
in
parenthesis)
following
each
individual
commodity:
melon
fruit:
8.4%
(
1.1%
and
7.3%);
melon
plant:
2.6%
(
1.4%
and
1.2%);
tomato
fruit:
8.5%
(
6.9%
and
1.6%);
and
tomato
plant:
21.2%
(
6.7%
and
14.5%).

Summary
of
Science
Findings
A
tabular
summary
of
the
residue
chemistry
science
assessments
for
reregistration
of
TCMTB
is
presented
below
in
Table
4.
The
conclusions
listed
in
Table
4
regarding
the
reregistration
eligibility
of
TCMTB
food/
feed
uses
are
based
on
the
use
patterns
being
supported
by
Bayer
and
Wilbur­
Ellis.
When
end­
use
product
data­
call­
ins
(
DCIs)
are
developed
(
e.
g.,
at
issuance
of
the
RED),
the
Registration
Division
(
RD)
should
require
that
all
end­
use
product
labels
(
e.
g.,
MAI
labels,
special
local
needs
(
SLNs),
and
products
subject
to
the
generic
data
exemption)
be
amended
such
that
they
are
consistent
with
labels
registered
to
Bayer
and
Wilbur­
Ellis.

Table
4.
Residue
Chemistry
Science
Assessment
for
the
Reregistration
of
TCMTB.

GLN
Data
Requirements
Current
Tolerances,
ppm
[
40
CFR]
Must
Additional
Data
Be
Submitted?
References
860.1200
Directions
for
Use
Not
applicable
(
NA)
No
None
860.1300
Plant
Metabolism
NA
Yes4
423768011,
204314712,
446541013,
446541023
860.1300
Livestock
Metabolism
NA
Reserved
None
860.1340
Residue
Analytical
Methods
Plant
commodities
NA
Yes6
PP
5F1613,
PP
0F0954,
FDA
PAM
Vol.
II
Livestock
commodities
NA
Reserved7
None
860.1360
Multiresidue
Methods
NA
Reserved8
None
860.1380
Storage
Stability
Data
Plant
commodities
NA
Yes5
None
Processed
commodities
NA
Reserved
None
TCMTB
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Chemistry
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Data
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Table
4.
Residue
Chemistry
Science
Assessment
for
the
Reregistration
of
TCMTB.

GLN
Data
Requirements
Current
Tolerances,
ppm
[
40
CFR]
Must
Additional
Data
Be
Submitted?
References
Livestock
commodities
NA
Reserved
None
860.1400
Water,
Fish,
and
Irrigated
Crops
NA
No
None
860.1460
Food
Handling
NA
No
None
860.1480
Meat,
Milk,
Poultry,
and
Eggs
NA
Reserved7
None
860.1500
Crop
Field
Trials
Root
and
Tuber
Vegetables
Group
Beet,
sugar,
roots
0.1(
N)
[
§
180.288(
a)]
Reserved9
None
Leaves
of
Root
and
Tuber
Vegetables
Group
Beet,
sugar,
tops
0.1(
N)
[
§
180.288(
a)]
Reserved9
None
Cereal
Grains
Group
Barley,
grain
0.1(
N)
[
§
180.288(
a)]
Reserved9
0011787412
Corn,
field,
grain
and
aspirated
grain
fractions
0.1(
N),
grain
[
§
180.288(
a)]
No11
0011787412
Corn,
pop,
grain
None
established
No11
None
Corn,
sweet,
K+
CWHR
None
Established
No11
None
Oat,
grain
0.1(
N)
[
§
180.288(
a)]
Reserved9
0011787412
Rice,
grain
0.1(
N)
[
§
180.288(
a)]
Reserved9
0011787412
Sorghum,
grain,
grain
and
aspirated
grain
fractions
0.1(
N),
grain
[
§
180.288(
a)]
No11
None
Wheat,
grain
and
aspirated
grain
fractions
0.1(
N),
grain
[
§
180.288(
a)]
Reserved9
0011787412
Fodder,
Forage,
Hay,
and
Straw
of
Cereal
Grains
Group
Barley,
hay
and
straw
0.1(
N),
straw
[
§
180.288(
a)]
Reserved9
0011787412
Corn,
field,
forage
and
stover
0.1(
N)
[
§
180.288(
a)]
No11
0011787412
Corn,
pop,
stover
None
established
No11
None
Corn,
sweet,
forage
and
stover
None
established
No11
None
Oat,
forage,
hay,
and
straw
0.1(
N)
[
§
180.288(
a)]
Reserved9
0011787412
Rice,
straw
0.1(
N)
[
§
180.288(
a)]
Reserved9
0011787412
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
DP
Barcode:
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9
of
23
Table
4.
Residue
Chemistry
Science
Assessment
for
the
Reregistration
of
TCMTB.

GLN
Data
Requirements
Current
Tolerances,
ppm
[
40
CFR]
Must
Additional
Data
Be
Submitted?
References
Sorghum,
grain,
forage
and
stover
0.1(
N)
[
§
180.288(
a)]
No11
None
Wheat,
forage,
hay,
and
straw
0.1(
N)
[
§
180.288(
a)]
Reserved9
0011787412
Miscellaneous
Commodities
Cotton,
undelinted
seed
and
gin
byproducts
0.1(
N),
undelinted
seed
[
§
180.288(
a)]
Reserved9
0000423913
Safflower,
seed
0.1(
N)
[
§
180.288(
a)]
Reserved9
None
860.1520
Processed
Food/
Feed
Barley
None
established
Yes
None
Beet,
sugar
None
established
Yes
None
Corn,
field
None
established
No11
None
Cotton
None
established
Yes
None
Oat
None
established
Yes
None
Rice
None
established
Yes
None
Safflower
None
established
Yes
None
Sorghum
None
established
No11
None
Wheat
None
established
Yes
None
860.1650
Submittal
of
Analytical
Reference
Standards
NA
Yes10
None
860.1850
Confined
Rotational
Crops
NA
Reserved9
None
860.1900
Field
Rotational
Crops
None
established
Reserved9
None
1.
F.
Fort,
D187529,
MRID
42376801,
00/
00/
0000.
2.
M.
Perry,
D221887,
MRID
20431471,
5/
11/
1998.
3.
Both
studies
(
MRID
44654101
and
44654102)
are
summarized
in
this
chemistry
summary
document.
Full
review
of
both
studies
is
currently
underway.
4.
Confirmatory
metabolism
data
should
be
submitted
depicting
the
nature
of
residues
in
wheat,
cotton,
and
sugar
beets.
5.
Storage
stability
data
was
not
included
with
the
original
field
trial
data
submissions,
therefore,
it
is
required.
6.
The
available
enforcement
method
(
Method
B
in
PAM
Vol.
II.)
is
outdated
and
uses
toxic
reagents;
therefore,
if
an
additional
method
that
is
adequate
for
tolerance
enforcement
is
available,
it
should
be
submitted
immediately
for
review.
Additionally,
if
the
requested
metabolism
studies
show
additional
residues
are
of
concern
and
the
current
enforcement
method
does
not
capture
these
additional
residues,
development
of
a
method
capable
of
doing
so
will
be
required.
7.
This
requirement
is
put
on
reserve
pending
the
results
from
the
requested
plant
metabolism
studies,
and
if
required,
the
livestock
metabolism
studies.
8.
If
additional
residues
of
concern
are
determined
from
the
requested
metabolism
studies,
all
additional
residues
of
concern
for
tolerance
expression
will
need
to
be
tested
through
Multiresidue
Methods.
9.
This
requirement
is
put
on
reserve
pending
the
results
from
the
requested
metabolism
studies.
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
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DP
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10
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23
10.
Analytical
standards
must
be
replenished
as
requested
by
the
Repository.
If
additional
residues
are
included
in
the
tolerance
expression
based
on
the
requested
metabolism
data,
analytical
reference
standards
should
be
submitted
and
replenished
as
requested
by
the
Repository.
11.
The
registrants
are
not
supporting
use
of
TCMTB
on
corn
and
sorghum;
therefore,
all
tolerances
associated
with
those
uses
should
be
revoked.
12.
MRID
00117874
was
reviewed
in
PP
2F1264.
13.
MRID
00004239
was
reviewed
in
PP
0F0954.

860.1200
Directions
for
Use
Product
List
There
are
two
Bayer
and
two
Wilbur­
Ellis
end­
use
products
containing
the
active
ingredient
TCMTB,
which
are
registered
for
use
on
domestically
grown
food/
feed
crops
as
indicated
in
Table
5.

Table
5.
TCMTB
End­
use
Products
(
EPs)
Registered
by
Bayer
and
Wilbur­
Ellis.

EPA
Reg.
No.
Formulation1
Registrant
Product
Name
Supported
Seed
Treatment
Use
Sites
264­
965
30%
EC
Bayer
CropScience
Busan
®
30A
cotton
264­
9832
5%
EC
Bayer
CropScience
Cotguard
®
cotton
2935­
389
30%
EC
Wilbur­
Ellis
Co.
Nusan
®
30
EC
barley,
cotton,
oat,
rice,
safflower,
sugar
beet,
and
wheat
2935­
4133
9%
SC
Wilbur­
Ellis
Co.
Nu­
Flow
®
ND
cotton
on
farm
1.
EC
=
Emulsifiable
Concentrate
and
SC
=
Soluble
Concentrate.
2.
Formulation
also
contains
Carboxin
(
PC
Code
090201)
at
14.35%
and
Metalaxyl
(
PC
Code
113501)
at
2.4%.
3.
Formulation
also
contains
Chloroneb
(
PC
Code
027301)
at
23.5%.

Use
Patterns
As
an
agricultural
pesticide,
TCMTB
is
a
fungicide
used
as
a
seed
treatment
on
barley,
corn,
cotton,
oat,
rice,
safflower,
sorghum,
sugar
beet,
and
wheat.
It
is
used
in
commercial
and
onfarm
settings.
For
food/
feed
uses,
Bayer
is
supporting
TCMTB
use
as
a
seed
treatment
on
cotton
only,
while
Wilbur­
Ellis
is
supporting
uses
on
barley,
cotton,
oat,
rice,
wheat,
safflower,
and
sugar
beet
(
K.
Jakob,
TCMTB
Use
Closure
Memo,
1/
30/
2006).
Use
on
corn
and
sorghum
are
not
being
supported.
The
technical
registrant
of
TCMTB,
Buckman,
has
requested
cancellation
of
all
food/
feed
uses
(
K.
Jakob,
TCMTB
Use
Closure
Memo,
1/
30/
2006).
An
analysis
of
the
current
labeling
and
available
use
information
was
completed
by
HED.
A
summary
of
directions
for
the
use
of
TCMTB
is
presented
below
in
Table
6.

Table
6.
Summary
of
Maximum
Application
Rates
for
Registered
TCMTB
Food/
Feed
Seed
Treatment
Uses.
EPA
Reg.
No.
Product
Name
Formulation
Crop
Application
Equipment
Max.
App.
Rate
(
fl
oz/
100
lbs
of
seed)
Max.
App.
Rate
(
lbs
ai/
100
lbs
of
seed)
264­
965
Busan
®

30A
30%
EC
cotton
commercial
treater
4.5
fl
oz/
100
lbs
of
seed
0.093
lbs
a.
i./
100
lbs
of
seed
264­
983
Cotguard
®
5%
EC
cotton
commercial
treater
9.0
fl
oz/
100
lbs
of
seed
0.032
lbs
a.
i./
100
lbs
of
seed
cotton
commercial
treater
5.0
fl
oz/
100
lbs
of
seed
0.10
lbs
a.
i./
100
lbs
of
seed
barley,
oat,
rice,
wheat
commercial
treater
1.25
fl
oz/
100
lbs
of
seed
0.026
lbs
a.
i./
100
lbs
of
seed
2935­
389
Nusan
®

30
EC
30%
EC
safflower,
sugar
beet
commercial
treater
2.0
fl
oz/
100
lbs
of
seed
0.041
lbs
a.
i./
100
lbs
of
seed
TCMTB
Summary
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Chemistry
and
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Data
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Barcode:
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Table
6.
Summary
of
Maximum
Application
Rates
for
Registered
TCMTB
Food/
Feed
Seed
Treatment
Uses.
EPA
Reg.
No.
Product
Name
Formulation
Crop
Application
Equipment
Max.
App.
Rate
(
fl
oz/
100
lbs
of
seed)
Max.
App.
Rate
(
lbs
ai/
100
lbs
of
seed)
commercial
treater
19.7
fl
oz/
100
lbs
of
seed
0.13
lbs
a.
i./
100
lbs
of
seed
2935­
413
Nu­
Flow
®

ND
9%
SC
cotton
on­
farm
treater
8.0
fl
oz/
100
lbs
of
seed
0.051
lbs
a.
i./
100
lbs
of
seed
860.1300
Nature
of
the
Residue
­
Plants
The
reregistration
requirements
for
plant
metabolism
have
not
been
fulfilled.
In
the
Phase
4
review
(
3/
11/
1991)
the
registrant,
Buckman,
was
instructed
to
provide
three
new
plant
metabolism
studies,
one
each
on
corn
or
wheat,
cotton
and
sugar
beets,
to
determine
if
any
uptake
occurred
in
the
aerial
portion
and/
or
edible
root
portion
of
the
growing
crop.
Based
on
this
information,
a
determination
would
be
made
as
to
whether
TCMTB
uses
are
food
or
nonfood.
Data
have
been
submitted
depicting
the
uptake
of
TCMTB
in
corn,
cotton,
safflower,
and
wheat
and
were
found
to
be
inadequate
due
to
lack
of
identification
and/
or
characterization
of
parent
and/
or
metabolites.
Additional
metabolism
studies
conducted
with
tomatoes
and
melons
have
been
submitted;
however,
translation
to
the
currently
registered
crops
is
not
adequate
for
reregistration
purposes.
Confirmatory
metabolism
data
should
be
submitted
depicting
the
nature
of
residues
in
wheat,
cotton,
and
sugar
beets.
Adequate
identification
and/
or
characterization
of
parent
and/
or
metabolites
should
be
conducted
as
required
by
OPPTS
860
Series
Guidelines.

The
Risk
Assessment
Review
Committee
(
RARC)
met
and
determined
that
the
interim
residue
of
concern
for
tolerance
expression
and
risk
assessment
is
TCMTB
in/
on
plants
(
P.
Deschamp,
Report
of
the
RARC,
1/
11/
2006).
This
is
a
preliminary
decision
dependent
on
the
results
from
the
requested
metabolism
data.
For
drinking
water,
the
RARC
decided
that
the
residues
of
concern
for
risk
assessment
are
TCMTB
and
2­
MBT.
Summary
of
the
preliminary
decisions
concerning
the
residues
of
concern
in
plants
and
drinking
water
are
presented
below
in
Table
7.

Table
7.
Summary
of
TCMTB
Residues
to
be
Included
in
the
Risk
Assessment
and
Tolerance
Expression.

Matrix
Residues
Included
in
Risk
Assessment
Residues
Included
in
Tolerance
Expression
Primary
crop
­
barley,
cotton,
oat,
rice,
safflower,
sugar
beet,
and
wheat
TCMTB
TCMTB
Plants
Rotational
crop
NA
=
not
applicable
NA
Ruminant
NA
NA
Livestock
Poultry
NA
NA
Drinking
water
TCMTB
and
2­
MBT
NA
All
submitted
studies
are
summarized
below.
No
data
have
been
submitted
depicting
the
uptake
of
TCMTB
in
sugar
beets.

Corn,
Cotton,
Safflower,
and
Wheat
(
MRID
42376801
and
43147201)

Buckman
submitted
a
study
(
MRID
42376801)
entitled
"
Uptake
and
Translocation
of
14C­
Busan
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
DP
Barcode:
322617
Page
12
of
23
30A
Used
in
Seed
Treatment
Combustion
Analysis
Phase".

Uniformly
labelled
14C­
TCMTB
in
the
benzene
ring
was
applied
(
as
a
solution
of
unknown
concentration
in
an
unspecified
solvent)
to
four
seed
types,
corn,
cotton,
safflower,
and
wheat
at
the
maximum
application
rate
at
the
time.
No
data
were
submitted
depicting
residues
in/
on
sugarbeets.
The
specific
activity
and
radiopurity
of
the
test
substance
were
determined
to
be
45,600
dpm/
ug
(
5.26
mCi/
mmol)
and
100%,
respectively.
Seeds
were
added
to
amber
bottles
that
contained
the
radioactive
material
and
placed
on
a
roller
for
an
hour
to
insure
uniform
coating.
Acetonitrile
washes
of
ten
seeds
were
analyzed
by
liquid
scintillation
counting
(
LSC)
and
the
washed
seeds
were
combusted
to
determine
the
rate
of
application.
The
remaining
seeds
were
planted.
Samples
were
taken
from
the
aerial
portion
of
the
plant
at
various
growth
stages.
Corn
silage,
haylage,
grain
and
stover;
wheat
forage,
hay,
grain
and
straw;
safflower
forage,
seed,
thinnings,
and
stalk;
and
cotton
forage
samples
were
obtained.
Control
samples
showed
some
uptake
of
radioactivity
which
increased
with
time.
The
registrant
concluded
that
this
was
a
result
of
housing
the
control
samples
in
the
same
greenhouse
with
the
treated
plants.
The
Health
Effects
Division
(
HED)
previously
concurred
with
this
assumption;
however,
some
of
the
control
samples
contained
higher
radioactive
residues
than
its
treated
counterpart.
The
treated
samples
were
stored
frozen
before
processing
and
were
analyzed
by
high­
performance
liquid
chromatography
(
HPLC)
using
an
ultraviolet
detector
(
UV).

Radioactive
residues
were
found
in
all
plant
parts
with
the
least
amount
of
residue
in
corn
commodities
(
0.0011­
0.0021
ppm).
The
highest
residues
were
found
in
cotton
forage
samples
(
2.7856
ppm).
Cotton
forage
samples
were
analyzed
for
the
presence
of
2­
MBT.
No
2­
MBT
residues
were
found
in
the
aqueous
or
organic
cotton
forage
extracts.
During
the
HPLC
analysis
of
both
the
aqueous
and
organic
extracts,
a
peak
was
noted
to
elute
with
a
retention
time
similar
to
that
of
TCMTB.
The
identity
of
this
peak
was
not
confirmed
by
alternative
means.
Additionally,
the
registrant
stated
that
subsequent
analyses
for
the
presence
of
2­
MBT
in
other
plant
extracts
were
being
performed;
however,
no
additional
data
have
been
submitted
to
the
Agency
for
review.

Buckman
submitted
an
addendum
(
MRID
43147201)
to
the
previous
study
report
(
MRID
42376801)
evaluating
the
uptake
and
translocation
of
C14­
TCMTB
in
seed
treatment
of
corn,
wheat,
safflower
and
cotton.
This
addendum
includes
the
results
of
combustion
analysis
of
radioactive
residues
in
cotton
seed,
lint,
and
stalk.
These
results
were
not
included
in
the
previous
study
report
because
the
treated
cotton
plants
were
not
mature
when
the
report
was
prepared.
Table
8
below
presents
the
results
of
the
initial
study
and
the
addendum
report.

Table
8.
Radioactivity
in
Corn,
Cotton,
Safflower,
and
Wheat.

Crop
Harvest
Point
Days
Harvested
After
Planting
Total
DPM/
G1
Corrected
ppm2
Corn
Haylage
Silage
Grain
Stover
62
days
114
days
139
days
139
days
68.4
95.83
54.7
50.2
0.0015
0.0021
0.0012
0.0011
Cotton
Forage
Seed
Lint
Stalk
52
days
211
days
211
days
211
days
127000
192
264
502
2.7856
0.0041
0.0058
0.0110
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
DP
Barcode:
322617
Page
13
of
23
Table
8.
Radioactivity
in
Corn,
Cotton,
Safflower,
and
Wheat.

Crop
Harvest
Point
Days
Harvested
After
Planting
Total
DPM/
G1
Corrected
ppm2
Safflower
Forage
Seed
Stalk
49
days
147
days
147
days
948.5
478.8
1860
0.0208
0.0105
0.0408
Wheat
Forage
Hay
Grain
Straw
22
days
63
days
141
days
141
days
18660
1158
538.1
3083
0.4092
0.0254
0.0118
0.0676
1.
Total
dpm/
g
=
corrected
ppm
X
specific
activity.
2.
Corrected
for
machine
recovery
and
matrix
recovery.
3.
Sample
was
combusted
twice.
Number
represents
average
of
both
combustions.

Residues
of
0.0011
ppm
to
2.7856
ppm
total
radioactivity
(
TCMTB
equivalents)
were
found
demonstrating
uptake
of
TCMTB
residues
in
crop
parts.
Identification
and/
or
characterization
of
parent
and/
or
metabolites
were
not
performed.
The
solvent
and
TCMTB
concentration
in
the
treatment
solution
was
not
provided
as
well
as
the
seed
treatment
rate.
Both
of
these
should
be
comparable
with
the
commercial/
agricultural
practices.
Residues
were
found
above
0.005
ppm,
which
is
the
trigger
value
for
food­
use
classification.
Additional
metabolism
studies
should
be
conducted
with
corn
or
wheat,
cotton,
and
sugar
beets
where
identification
and/
or
characterization
of
parent
and/
or
metabolites
are
completed.

Melon
(
MRID
44654101)

Transplanted
melon
plants
were
grown
in
two
confined
plots.
The
treated
plot
received
two
soildrench
applications
of
14C­
TCMTB
containing
20.0
mCi
and
supplementary
unlabelled
TCMTB
in
blank
formulation
of
Busan
30
WB,
so
that
the
applications
were
equivalent
to
approximately
5.0
lb
a.
i./
A.
The
applications
were
made
at
the
time
of
transplanting
and
again
14
days
later.
Immature
melons
(
0.78
kg)
were
sampled
at
a
preliminary
sampling,
at
29
days
after
last
application.
At
the
sampling
at
maturity,
approximately
5.4
kg
of
melons
was
sampled
and
0.59
kg
of
mature
plant
material
was
also
taken.
At
all
sampling
events,
the
plant
material
was
promptly
frozen.
It
was
stored
frozen
and
shipped
frozen
to
the
analytical
laboratory.
The
melons
were
stored
and
shipped
under
refrigeration
to
facilitate
handling
and
chopping
at
the
analytical
laboratory.

On
receipt
at
Xenobiotic
Laboratories,
the
fruit
and
plant
material
were
frozen
and
homogenized
and
samples
were
taken
for
determination
of
the
total
radioactive
residue
(
TRR)
of
each
matrix.
No
radioactivity
was
detected
in
any
of
the
untreated
samples
(<
0.001
ppm).
The
immature
treated
melons
contained
0.304
ppm
and
the
immature
plant
material
contained
0.532
ppm
and
the
mature
plant
material
contained
8.00
ppm
of
radioactivity
as
TCMTB­
equivalents.

The
parent
compound,
TCMTB,
was
found
only
in
the
plant
material
and
at
very
low
concentration,
0.073
ppm.
One
principle
metabolite,
2­
BTSA,
was
found
in
both
the
fruit
and
plant
material.
It
was
present
in
the
fruit
at
0.170
ppm
and
in
the
plant
material
at
1.12
ppm.
2­
OH­
BT
and
2­
MBT
were
also
detected,
but
at
<
0.01
ppm
in
fruit
and
at
0.203
ppm
and
0.010
ppm
in
the
plant,
respectively.
Two
positional
isomers
of
OH­
2­
BTSA
were
also
detected,
but
primarily
in
the
plant
at
0.113
ppm
and
0.097
ppm.
In
addition,
14C
incorporation
was
also
detected
in
sucrose,
fructose,
and
glucose
at
more
than
27%
of
TRR.
Table
9
presents
the
results
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
DP
Barcode:
322617
Page
14
of
23
of
the
melon
metabolism
study.

Table
9.
Major
TCMTB
Metabolites
Found
in
Melons.
Residue
Melon
Fruit
Melon
Plant
Compound
ppm
%
ppm
%
TCMTB
<
0.001
0
0.073
0.9
2­
BTSA
0.170
31.9
1.12
14.0
2­
OH­
BT
0.007
1.3
0.203
2.5
2­
MBT
0.004
0.7
0.010
0.1
OH­
2­
BTSA1
0.006
1.1
0.113
1.4
OH­
2­
BTSA1
0.039
7.3
0.097
1.2
Sugars2
0.144
27.1
0.032
0.4
Totals
0.370
69.4
1.65
20.5
Post­
Extraction
Solids
0.109
20.5
5.80
72.5
Grand
Totals
0.479
89.9
7.45
93.0
1.
Two
positional
isomers
of
hydroxy­
2­
benzothiazolesulfonic
acid
were
detected.
The
exact
position
of
the
hydroxyl
group
could
not
be
determined.
2.
Sucrose
+
glucose
+
fructose
with
14C
incorporation.

Tomato
(
MRID
44654102)

Transplanted
tomato
plants
were
grown
in
two
confined
plots.
The
treated
plot
received
two
soil­
drench
applications
of
14C­
TCMTB
containing
20.0
mCi
and
supplementary
unlabelled
TCMTB
in
blank
formulation
of
Busan
30
WB,
so
that
the
applications
were
equivalent
to
approximately
5.0
lb
a.
i./
A.
The
applications
were
made
at
the
time
of
transplanting
and
again
14
days
later.
Immature
tomatoes
(
0.24
kg)
were
sampled
at
a
preliminary
sampling,
at
29
days
after
last
application.
Tomatoes
were
sampled
twice
at
maturity,
approximately
1.0
kg
of
ripe
tomatoes
was
sampled
at
56
days
after
last
application
and
1.5
kg
of
ripe
tomatoes
as
well
as
1.2
kg
of
green
tomatoes
were
sampled
two
weeks
later.
In
addition,
approximately
1.0
kg
of
mature
plant
material
was
also
taken.
Samples
were
taken
from
the
untreated
control
plants
on
the
same
schedule.
At
all
sampling
events,
the
plant
material
was
promptly
frozen.
It
was
stored
frozen
and
shipped
frozen
to
the
analytical
laboratory.
The
tomatoes
were
stored
and
shipped
under
refrigeration
to
facilitate
handling
and
chopping
at
the
analytical
laboratory.

On
receipt
at
Xenobiotic
Laboratories,
the
fruit
and
plant
material
were
frozen
and
homogenized
and
samples
were
taken
for
determination
of
the
total
radioactive
residue
(
TRR)
of
each
matrix.
No
radioactivity
was
detected
in
any
of
the
untreated
samples
(<
0.001
ppm).
The
immature
(
29
day
sampling)
treated
tomatoes
contained
0.298
ppm
and
the
immature
plant
material
contained
6.41
ppm
of
radioactivity
as
TCMTB­
equivalents.
The
mature
(
56
day
sampling)
treated
tomatoes
contained
0.221
ppm
and
the
mature
plant
material
contained
4.08
ppm
of
radioactivity
as
TCMTB­
equivalents.

The
parent
compound,
TCMTB,
was
not
found
in
the
tomato
fruit
of
in
the
plant
material,
<
0.001
ppm.
One
principle
metabolite,
2­
BTSA,
was
found
in
both
the
fruit
and
plant
material.
It
was
present
in
the
fruit
at
0.136
ppm
and
in
the
plant
material
at
1.33
ppm.
Two
positional
isomers
of
OH­
2­
BTSA
were
also
detected,
but
only
in
significant
quantities
in
the
plant
material
(
0.272
ppm
and
0.590
ppm).
In
addition,
14C
incorporation
was
also
detected
in
sucrose,
fructose,
and
glucose
at
more
than
18%
of
TRR.
Table
10
presents
the
results
of
the
tomato
metabolism
study.
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
DP
Barcode:
322617
Page
15
of
23
Table
10.
Major
TCMTB
Metabolites
Found
in
Tomatoes.
Residue
Tomato
Fruit
Tomato
Plant
Compound
ppm
%
ppm
%
TCMTB
<
0.001
0
<
0.001
0
2­
BTSA
0.136
61.7
1.33
32.6
OH­
2­
BTSA1
0.015
6.9
0.272
6.7
OH­
2­
BTSA1
0.004
1.6
0.590
14.5
Sugars2
0.031
14.1
0.193
4.7
Unidentified
0.008
3.6
0.494
12.1
Totals
0.194
87.9
2.88
70.6
Post­
Extraction
Solids
0.017
7.8
0.927
22.7
Grand
Totals
0.211
95.7
3.81
93.3
1.
Two
positional
isomers
of
hydroxy­
2­
benzothiazolesulfonic
acid
were
detected.
The
exact
position
of
the
hydroxyl
group
could
not
be
determined.
2.
Sucrose
+
glucose
+
fructose
with
14C
incorporation.

The
reregistration
requirements
for
plant
metabolism
have
not
been
fulfilled.
Data
have
been
submitted
depicting
the
uptake
of
TCMTB
in
corn,
cotton,
safflower,
and
wheat
and
were
found
to
be
inadequate
due
to
lack
of
identification
and/
or
characterization
of
parent
and/
or
metabolites.
Additional
metabolism
studies
conducted
with
tomatoes
and
melons
have
been
submitted;
however,
translation
to
the
currently
registered
crops
is
not
adequate
for
reregistration
purposes.
Confirmatory
metabolism
data
should
be
submitted
depicting
the
nature
of
residues
in
wheat,
cotton,
and
sugar
beets.
Adequate
identification
and/
or
characterization
of
parent
and/
or
metabolites
should
be
conducted
as
required
by
OPPTS
860
Series
Guidelines.
The
Risk
Assessment
Review
Committee
(
RARC)
met
and
determined
that
the
interim
residue
of
concern
for
tolerance
expression
and
risk
assessment
is
TCMTB
in/
on
plants
(
P.
Deschamp,
Report
of
the
RARC,
1/
11/
2006).
This
is
a
preliminary
decision
and
additional
confirmatory
data
should
be
submitted
in
a
timely
manner.
For
drinking
water,
the
RARC
decided
that
the
residues
of
concern
for
risk
assessment
are
TCMTB
and
2­
MBT.

The
determination
of
the
residues
of
concern
in
plant
commodities
is
based
on
the
tomato
and
melon
metabolism
studies
and
the
available
toxicity
data.
2­
BTSA
was
found
at
significant
levels
(
62%
in
tomato
fruit);
however,
it
should
be
excluded
as
a
residue
of
concern
because
it
is
expected
to
be
less
toxic
than
the
parent
TCMTB.
2­
BTSA
is
likely
to
not
contribute
significantly
to
the
chronic
toxicity
of
the
parent
based
on
the
following
considerations:

1.
2­
BTSA
has
a
very
polar
structure
lacking
the
structural
features
of
the
parent
(
TCMTB)
that
might
lead
to
toxicologically
significant
species.
Although
the
mode
of
toxic
action
of
the
parent
is
not
known,
its
thiocyanomethylthio
group
is
likely
to
be
metabolized
to
toxic
species.
This
group
is
not
present
in
2­
BTSA.
Thus,
2­
BTSA
cannot
contribute
to
toxicity
via
this
group.

2.
If
the
benzimidazole
ring
of
TCMTB
is
involved
in
its
toxic
effects
by
biotransformation
to
electrophilic
species,
2­
BTSA
is
not
likely
to
undergo
this
type
of
biotransformation.
2­
BTSA,
being
a
sulfonic
acid,
is
expected
to
undergo
little
or
no
metabolism.
Smallmolecule
sulfonic
acids
generally
undergo
little
or
no
biotransformation.
For
example,
methanesulfonic,
benzenesulfonic,
and
naphthylaminesulfonic
acids
are
excreted
untransformed
in
laboratory
animals
(
Biological
Basis
of
Detoxication,
Caldwell
J.
&
Jakoby
W.
B.
[
eds],
1984,
p.
162).
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3.
In
a
chemical
with
a
mercapto
group
(­
SH),
oxidation
of
the
mercapto
group
to
the
corresponding
sulfonic
acid
is
known
to
produce
a
marked
decrease
in
toxicity.
For
example,
phenyl
mercaptan
(
i.
e.
benzenethiol)
is
a
fairly
toxic
chemical
producing
neurotoxicity,
liver
toxicity,
and
other
effects
and
has
a
rat
acute
oral
LD50
of
46
mg/
kg
(
McCord
&
Witheridge,
1949,
cited
in
NIOSH
website).
In
contrast,
the
oxidized
form,
benzenesulfonic
acid
is
reported
as
having
a
rat
acute
oral
LD50
of
890
mg/
kg
(
Benzenesulfonic
acid
MSDS).
This
marked
decrease
of
toxicity
can
be
attributed
to
polarity
resulting
from
the
replacement
of
the
­
SH
group
with
a
sulfonic
acid
group.

4.
2­
BTSA
is
the
oxidized
(
sulfonic
acid)
form
of
2­
MBT;
thus,
it
is
expected
to
be
equally
or
less
systemically
toxic
than
2­
MBT
by
analogy
with
the
benzenethiol/
benzenesulfonic
acid
pair
of
compounds.
Barring
high­
dose
effects
such
as
gastrointestinal
effects,
the
chronic
RfD
for
2­
MBT
of
0.6
mg/
kg/
day
set
by
the
HED
RfD/
Peer
Review
suggests
that
the
chronic
toxicity
of
2­
BTSA
is
much
smaller
than
that
of
the
parent
TCMTB
with
a
chronic
RfD
of
0.013
mg/
kg/
day.
Although
there
are
concerns
for
the
carcinogenic
potential
of
2­
MBT
(
Group
C),
there
are
no
such
concerns
for
2­
BTSA
due
to
its
very
high
polarity
and
probable
absence
of
metabolism.

Additionally,
2­
MBT
and
other
TCMTB
metabolites
were
not
found
at
significant
levels
to
be
considered
residues
of
concern.
Therefore,
only
TCMTB
should
be
considered
a
residue
of
concern
in
plant
commodities.

For
drinking
water,
the
residues
of
concern
should
include
TCMTB
and
2­
MBT
and
is
based
on
the
available
aerobic
soil
metabolism
study
(
MRID
43532201).
2­
BTSA
was
found
at
71%
TRR;
however,
it
should
be
excluded
as
a
residue
of
concern
for
reasons
noted
in
the
above
section.
2­
MBT
was
found
at
30%
TRR
after
1.5
days
post­
treatment
and
should
be
considered
a
residue
of
concern.
2­
MBT
is
distinctly
less
toxic
than
the
parent;
however,
it
can
not
be
ruled
out
as
a
residue
of
concern
and
should
be
included
in
the
dietary
risk
assessment.
All
other
metabolites
were
not
found
at
significant
levels;
therefore,
they
should
not
be
considered
residues
of
concern.

860.1300
Nature
of
the
Residue
 
Livestock
Livestock
metabolism
studies
may
be
required
if
the
requested
plant
metabolism
studies
show
uptake
of
residues.
If
livestock
metabolism
studies
are
required,
the
registrant
must
provide
poultry
and
ruminant
metabolism
studies
following
OPPTS
860
Series
Guidelines.

860.1340
Residue
Analytical
Methods
 
Plants
A
tolerance
enforcement
method
is
available
for
determining
thiobenzothiazole­
containing
residues
in
barley,
corn,
cotton,
oat,
rice,
safflower,
sugar
beet,
and
wheat.
This
method
was
originally
submitted
with
Pesticide
Petition
(
PP)
0F0954
by
Buckman.
Residues
are
extracted
by
blending
with
water
and
the
extract
is
refluxed
with
NaOH.
After
partition
with
CH2Cl2,
glacial
acetic
acid
and
sulfuryl
chloride
are
added
to
convert
the
residues
to
2­
chlorobenzothiazole,
which
is
determined
by
a
gas­
liquid
chromatography
(
GLC)
method
using
an
electron
capture
detector
(
ECD).
The
quantitation
limit
of
the
method
has
been
determined
at
0.10
ppm.
This
method
is
listed
as
Method
B
in
PAM
Vol.
II.
The
method
is
outdated
and
uses
toxic
reagents;
therefore,
if
an
additional
method
that
is
adequate
for
tolerance
enforcement
is
available,
it
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should
be
submitted
immediately
for
review.

Two
data­
collection
methods
are
available
for
determining
thiocyanate­
containing
residues.
The
first
method
was
originally
submitted
with
PP
0F0954
by
Buckman
for
the
determination
of
residues
in
barley,
corn,
cottonseed,
oat,
rice,
and
wheat.
Residues
are
extracted
with
benzene
and
the
extract
is
cleaned
up
with
liquid­
liquid
extractions
(
isooctane
to
H2SO4­
water
and
then
H2SO4­
water
to
CH2Cl2).
The
TCMTB
residue
is
heated
with
sodium
polysulfide
solution
to
liberate
thiocyanate
ion.
Bromine
is
added
to
convert
the
thiocyanate
to
cyanogens
bromide;
then
the
cyanogen
bromide
is
treated
with
pyridine­
benzidine
reagent
to
form
an
intensely
colored
dye.
The
absorbance
of
the
dye
solution
is
determined
at
532
nm.
In
a
method
tryout,
the
Agency
obtained
recoveries
of
90%
and
110%
(
duplicate
samples)
at
the
0.10
ppm
fortification
level
and
105%
and
115%
(
duplicate
samples)
at
the
0.20
ppm
fortification
level.
The
quantitation
limit
of
the
method
has
been
determined
at
0.10
ppm.
The
method
is
listed
as
Method
I
in
PAM
Vol.
II.

The
second
method
was
originally
submitted
with
PP
5F1613
by
Buckman
for
the
determination
of
residues
in
safflower
seed,
sorghum
grain
and
foliage,
and
sugar
beet
and
foliage.
TCMTB
is
extracted
from
samples
by
blending
with
acetone.
The
extract
is
filtered
and
cleaned
up
on
a
Florisil
column,
and
TCMTB
is
eluted
with
benzene.
After
liquid­
liquid
partitioning,
the
same
procedure
described
above
for
Method
I
is
followed.
Samples
of
safflower
seed,
sorghum
grain
and
foliage,
and
sugar
beet
and
foliage
were
fortified
with
0.10
ppm
to
0.30
ppm
TCMTB
and
recoveries
ranged
from
70%
to
93%.
The
quantitation
limit
of
the
method
has
been
determined
at
0.10
ppm.
The
method
is
listed
as
Method
A
in
PAM
Vol.
II.

If
the
requested
metabolism
studies
show
additional
residues
are
of
concern
and
the
current
enforcement
method
does
not
capture
these
additional
residues,
development
of
a
method
capable
of
doing
so
will
be
required.

860.1340
Residue
Analytical
Methods
­
Livestock
This
requirement
is
put
on
reserve
pending
the
results
from
the
requested
plant
metabolism
studies,
and
if
required,
the
livestock
metabolism
studies.

860.1360
Multiresidue
Methods
There
is
no
information
in
the
review
documents
regarding
submittal
of
data
for
FDA
Multiresidue
Methods
by
the
petitioner.
However,
the
FDA
PESTDATA
database
dated
11/
2001
(
PAM
Volume
I,
Appendix
I)
indicates
that
TCMTB
per
se
is
completely
recovered
(>
80%)
using
Multiresidue
Methods
Section
302
(
Luke
Method),
but
is
only
partially
recovered
(
50­
80%)
using
303
(
Mills,
Onley,
Gaither
Method)
and
304
(
Mills
fatty
food
Method).

If
additional
residues
of
concern
are
determined
from
the
requested
metabolism
studies,
all
additional
residues
of
concern
for
tolerance
expression
will
need
to
be
tested
through
Multiresidue
Methods.

860.1380
Storage
Stability
Storage
stability
data
for
TCMTB
in/
on
barley,
cotton,
oat,
rice,
wheat,
safflower,
and
sugar
beet
have
not
been
submitted
by
the
registrant.
No
data
were
provided
on
how
long
samples
from
the
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submitted
field
trials
were
stored
prior
to
analysis;
therefore,
storage
stability
data
for
the
previously
submitted
field
trials
are
required
and
should
be
submitted
immediately.
Additionally,
if
field
trials
are
required
or
additional
uses
are
requested,
storage
stability
data
will
be
required
under
this
guideline
topic.

860.1400
Water,
Fish,
and
Irrigated
Crops
TCMTB
is
not
intended
for
direct
use
on
water
and
aquatic
food
and
feed
crops;
therefore,
no
residue
chemistry
data
are
required
under
this
guideline
topic.

860.1460
Food
Handling
TCMTB
is
not
intended
for
use
in
food­
handling
establishments;
therefore,
no
residue
chemistry
data
are
required
under
this
guideline
topic.

860.1480
Meat,
Milk,
Poultry,
and
Eggs
TCMTB
is
not
intended
for
application
to
livestock.
The
grain
crops,
byproducts,
and
forages
are
livestock
feed
items.
It
is
therefore
necessary
to
consider
if
TCMTB
residues
are
transferred
to
meat,
milk,
poultry,
and
eggs
of
livestock
through
ingestion
of
the
residue­
bearing
commodities.

It
has
been
indicated
in
the
foregoing
considerations
that
the
nature
of
residue
in
plants
has
not
been
adequately
described.
In
the
absence
of
such
data,
the
residue
level
is
unclear.

No
livestock
feeding
studies
have
been
submitted.
If
the
requested
residue
data
show
finite
residues
in
the
feed
items,
livestock
feeding
studies
would
be
essential
to
an
evaluation
of
the
transfer
of
residues
to
milk,
meat,
poultry,
and
eggs.
Therefore,
no
valid
conclusions
relative
to
40
CFR
§
180.6
(
the
necessity
of
tolerances
in
livestock
commodities)
can
be
made
in
the
absence
of
livestock
feeding
studies.

860.1500
Crop
Field
Trials
The
available
field
trial
data
are
not
adequate
according
to
current
OPPTS
860
Series
Guidelines.
The
correct
number
of
field
trials,
number
samples
collected,
and
locations
of
trials
are
all
insufficient.
Additionally,
no
storage
stability
data
were
submitted
with
the
field
trial
studies
and
the
application
rates
are
unknown
for
the
barley,
corn,
oat,
rice,
and
wheat
studies.
The
method
used
for
determining
residues
in
barley,
corn,
oat,
rice,
and
wheat
is
the
data­
collection
method
which
only
determines
the
thiocyanate
ion
(
Method
I
or
A
in
PAM
Vol.
II).
The
method
used
for
determining
residues
in
cotton
is
the
tolerance
enforcement
method
which
determines
thiobenzothiazole­
containing
residues
(
Method
B
in
PAM
Vol.
II).
If
the
requested
metabolism
studies
show
that
additional
metabolites
of
concern
are
expected,
new
field
trials
should
be
conducted
in
which
the
method
samples
for
all
residues
of
concern
as
determined
by
the
tolerance
expression.
Field
trial
data
are
not
available
for
sugar
beets;
therefore,
magnitude
of
residue
data
in
sugar
beets
should
be
submitted
following
all
OPPTS
860
Series
Guidelines.

Cotton
(
MRID
00004239)

Cotton:
Four
studies
reflecting
seed
treatments
of
2­
3
oz
of
Busan
72/
100
lbs
seed
are
reported.
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The
exact
application
rate
in
lbs
a.
i./
100
lbs
of
seed
is
unknown.
Control
values
ranged
from
0.01
ppm
to
0.04
ppm,
with
values
from
treated
samples
ranging
from
0.01
ppm
to
0.09
ppm.
These
data
are
inadequate
to
determine
whether
of
not
real
residues
are
present.
Additionally,
no
data
on
cotton
gin
byproducts
have
been
provided
and
are
currently
required.

Barley,
Corn,
Oat,
Rice,
and
Wheat
(
MRID
00117874)

Barley:
Grain
and
foliage
samples
were
obtained
from
crops
in
Wisconsin,
Tennessee,
and
North
Dakota
which
had
received
seed
treatments
of
0.7x
to
5.6x
the
original
application
rate.
Apparent
residues
in
grain
or
foliage
were
0.01­
0.04
ppm.
Untreated
grain
or
foliage
samples
had
residues
of
0.01­
0.04
ppm.

Corn:
Grain
and
foliage
samples
were
obtained
from
crops
in
Indiana,
Illinois,
Kansas,
Missouri,
and
Wisconsin
which
had
received
seed
treatments
of
1x
to
1.5x
the
original
application
rate.
Apparent
residues
in
grain
or
foliage
were
0.01­
0.04
ppm.
Untreated
grain
and
foliage
samples
had
residues
of
0.01­
0.05
ppm.

Oat:
Grain
and
foliage
samples
were
obtained
from
crops
in
Arkansas
and
Wisconsin
which
had
received
seed
treatments
of
0.6x
to
1.4x
the
original
application
rate.
Apparent
residues
in
grain
and
foliage
were
0.02­
0.04
ppm.
Residues
in
untreated
grain
and
foliage
samples
were
0.02­
0.04
ppm.

Rice:
Grain
and
foliage
samples
were
collected
from
crops
in
Arkansas
and
Louisiana
which
had
received
seed
treatments
of
1x
to
2.4x
the
original
application
rate.
Apparent
residues
in
grain
and
foliage
were
0.02­
0.04
ppm.
Residues
in
untreated
grain
or
foliage
were
0.02­
0.04
ppm.

Wheat:
Samples
of
grain
and
foliage
were
taken
from
crops
in
Arkansas
and
North
Dakota
which
had
received
seed
treatments
of
1.2x
to
5.6x
the
original
application
rate.
Apparent
residues
in
grain
and
foliage
were
0.02­
0.04
ppm.
Residue
in
untreated
grain
and
foliage
samples
were
0.02­
0.04
ppm.

A
comparison
of
the
data
for
the
field
studies
of
all
the
crops
indicates
that
there
is
no
significant
difference
between
residue
levels
for
the
treated
and
untreated
crops
(
grain
or
foliage).
It
may
be
concluded
that
no
residues
of
the
parent
compound,
TCMTB,
are
likely
to
occur
in
the
grain
or
foliage
of
barley,
cotton,
corn,
oats,
rice,
and
wheat
from
the
current
use
pattern.
Thus,
the
tolerance
level
of
0.1
ppm
represents
the
analytical
method's
sensitivity
rather
than
determinable
residues.

The
above
conclusions
apply
only
to
the
residues
of
the
parent
compound.
No
data
have
been
submitted
indicating
if
plant
residues
contain
components
other
than
the
parent
compound.
If
additional
metabolism
data
show
the
presence
in
the
residue
of
components
other
than
the
parent
compound
in
significant
quantities,
then
residue
data
on
the
subject
crops
may
be
necessary.

860.1520
Processed
Food
and
Feed
No
processing
studies
have
been
submitted.
Once
the
requested
metabolism
studies
have
been
submitted,
reviewed,
and
the
metabolites
of
concern
are
determined,
data
should
be
submitted
which
show
whether
residues
concentrate
in
the
byproducts
of
the
registered
raw
agricultural
commodities.
If
concentration
occurs,
and
the
concentrated
residue
levels
exceed
the
proposed
TCMTB
Summary
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Chemistry
and
Residue
Data
­
RED
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tolerance,
then
food
additive
tolerances
to
cover
such
residues
will
be
necessary.

860.1650
Submittal
of
Analytical
Reference
Standards
An
analytical
reference
standard
for
TCMTB
was
submitted
by
Buckman
in
February
of
2002
and
expires
February
of
2012.
The
standard
is
available
at
the
EPA
National
Pesticide
Standards
Repository.
If
additional
residues
are
included
in
the
tolerance
expression
based
on
the
requested
metabolism
data,
analytical
reference
standards
should
be
submitted
and
replenished
as
requested
by
the
Repository.

860.1850
Confined
Accumulation
in
Rotational
Crops
and
860.1900
Field
Accumulation
in
Rotational
Crops
TCMTB
treated
seeds
were
planted
in
silt
loam
and
yellow
clay
loam
soils.
The
seeds
were
treated
at
0.75­
4.5
fl
oz/
100
lbs
seed.
Less
than
0.10
ppm
of
TCMTB
residues
were
noted
in
the
soils
at
intervals
of
30
days
and
beyond.

Loess
and
clay
loam
soils
were
treated
in­
furrow
or
broadcast
at
1.2­
1.6
lbs
a.
i./
100
lbs
seed
(
9x
the
current
maximum
seed
treatment
rate).
Residues
were
1.1­
1.7
ppm
at
30
days,
0.6­
1.0
ppm
at
100
days,
less
than
0.10­
1.0
ppm
at
189
days,
and
less
than
0.10
ppm
at
215
days.

Sandy
loam
and
silt
loam
soils
were
treated
at
0.72­
4.32
lb
a.
i./
100lbs
seed.
Residues
were
less
than
0.10­
1.0
ppm
at
30
days
and
less
than
0.10
ppm
at
60
days.

It
is
unclear
which
method
was
used
to
determine
residue
levels
in
the
above
soil
persistence
studies.
The
registrant
should
provide
method
data
along
with
storage
stability
data
in
order
for
the
data
to
be
considered
scientifically
adequate.
However,
with
the
exception
of
storage
stability
and
method
data,
soil
persistence
is
not
likely
to
be
a
concern
with
respect
to
follow­
up
crops.
However,
the
method
used
is
unknown
and
the
exact
compounds
that
make
up
the
residues
found
is
unknown;
therefore,
this
data
requirement
is
put
on
reserve
awaiting
submission
of
the
requested
data
and
pending
the
results
from
the
plant
metabolism
studies.

Tolerance
Reassessment
Summary
Tolerances
for
residues
in/
on
plant
livestock
commodities
have
been
established
under
40
CFR
§
180.288.
The
tolerances
for
residues
of
TCMTB
in/
on
plant
commodities
is
expressed
in
terms
of
residues
of
TCMTB
per
se
[(
2­
benzothiazolylthio)
methyl
thiocyanate].

Tolerances
Established
Under
40
CFR
§
180.288
Confirmatory
metabolism
data
conducted
with
wheat,
cotton,
and
sugar
beet
are
requested
to
determine
the
nature
of
residues
in
plants.
Depending
on
the
results
from
the
requested
confirmatory
metabolism
studies,
additional
guideline
requirements
may
be
requested
for:
livestock
metabolism;
enforcement
and
data­
collection
methods;
multiresidue
methods;
storage
stability;
and
livestock,
crop,
processed
commodity,
and
rotational
crop
magnitude
of
residue
studies.
A
summary
of
the
TCMTB
tolerance
reassessment
is
presented
below
in
Table
11.
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
DP
Barcode:
322617
Page
21
of
23
Tolerances
To
Be
Proposed
Under
40
CFR
§
180.288
Because
of
changes
to
Table
1
(
OPPTS
860.1000),
tolerances
for
barley
hay
and
cotton
gin
byproducts
must
be
proposed.

Table
11.
Tolerance
Reassessment
Summary
for
TCMTB.

Commodity
Current
Tolerance
Tolerance
Reassessment
Comment/[
Correct
CommodityDefinition]
Tolerances
Established
Under
40
CFR
§
180.288:
Barley,
grain
0.1
(
N1)
TBD2
Barley,
straw
0.1
(
N)
TBD
Beet,
sugar,
roots
0.1
(
N)
TBD
Beet,
sugar,
tops
0.1
(
N)
TBD
Corn,
grain
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
corn.

Corn,
forage
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
corn.

Corn,
stover
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
corn.

Cotton,
forage
0.1
(
N)
Revoke
No
longer
considered
a
significant
livestock
feed
item.
Cotton,
undelinted
seed
0.1
(
N)
TBD
Oat,
forage
0.1
(
N)
TBD
Oat,
grain
0.1
(
N)
TBD
Oat,
hay
0.1
(
N)
TBD
Oat,
straw
0.1
(
N)
TBD
Safflower,
seed
0.1
(
N)
TBD
Sorghum,
grain,
forage
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
sorghum.

Sorghum,
grain,
grain
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
sorghum.

Sorghum,
grain,
stover
0.1
(
N)
Revoke
The
registrants
do
not
intend
to
support
use
of
TCMTB
on
sorghum.
Wheat,
forage
0.1
(
N)
TBD
Wheat,
grain
0.1
(
N)
TBD
Wheat,
hay
0.1
(
N)
TBD
Wheat,
straw
0.1
(
N)
TBD
Tolerances
To
Be
Proposed
Under
40
CFR
§
180.288:
Barley,
hay
None
established
TBD
Cotton,
gin
byproducts
None
established
TBD
1.
N
=
Negligible.
The
"
N"
designation
must
be
removed
from
all
tolerances.
2.
TBD
=
To
be
determined.
Tolerances
cannot
be
determined
at
this
time
because
additional
data
are
required.

Codex
Harmonization
There
are
no
Codex
maximum
residue
limits
(
MRLs)
for
TCMTB;
therefore,
no
questions
of
compatibility
with
U.
S.
tolerances
exist.
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
DP
Barcode:
322617
Page
22
of
23
Bibliography
Agency
Memoranda
Citations
Table
12.
Agency
Memoranda
Citations.

Date
DP
Barcode
PP
No.
From
To
MRID
Nos.
Subject
12/
16/
1993
D187529
None
F.
Fort
V.
Dietrich
and
B.
Sidwell
42376801
TCMB.
Uptake
of
14C
from
Seed
Treatment.
Case
No.
2625.
Chemical
No.
035603.
MRID
No.
42376801.
CBRS
No.
11294.
DP
Barcode
D187529.

5/
11/
1998
D221887
None
M.
Perry
M.
Swindell
20431471
TCMTB.
Uptake
of
14C
from
seed
treatment.
Case
No.
2625.
Chemical
No.
035603.
MRID
No.
43147201.
DP
Barcode
D221887.

7/
31/
1970
None
0F0954
A.
Rathman
None
None
PP
#
0F0954:
TCMTB
on
cotton,
as
amended.
Evaluation
of
analytical
method
and
residue
data.

9/
23/
1972
None
2F1264
A.
Smith
None
None
PP
#
2F1264.
TCMTB
in
small
grain
crops.

Master
Record
Identification
Numbers
00004239
Wilbur­
Ellis
Company
(
1979)
Residue
Data
Summary.
Unpublished
study
including
letter
dated
Oct
16,
1978
from
J.
H.
Stoner
to
Dave
T.
Schulteis,
received
Feb
6,
1979
under
2935­
413;
pre­
pared
in
cooperation
with
Stoner
Laboratories;
CDL:
237334­
A
00004241
Wilbur­
Ellis
Company
(
1979)
Results
of
Tests
on
the
Amount
of
Resi­
due
Remaining,
Including
a
Description
of
the
Analytical
Method:
Nu­
Flow
ND.
Unpublished
study
received
Feb
6,
1979
under
2935­
413;
CDL:
237335­
B.

00046073
Buckman
Laboratories,
Incorporated
(
1975)
Analytical
Procedures
and
Results
of
Residue
Analyses:
Busan
30.
Undated
method.
Unpublished
study
received
Nov
12,
1976
under
7F1885;
CDL:
095601­
D.

00078556
Buckman
Laboratories,
Incorporated
(
1972)
Analytical
Procedures
and
Results
of
Residue
Analyses:
Busan
30.
Includes
undated
methods
entitled:
Analyses
of
2­
(
thiocyanomethylthio)
benzothiazole
in
soil;
Regulatory
method
of
analysis.
Unpublished
study
re­
ceived
Mar
26,
1975
under
4F1613;
CDL:
095525­
F.

00112618
Buckman
Laboratories,
Inc.
(
1970)
Results
of
Tests
on
the
Amount
of
Residue
Remaining,
Including
a
Description
of
the
Analytical
Method:
2­
(
Thiocyanomethylthio)
benzothiazole.
Compilation;
unpublished
study
received
on
unknown
date
under
0F0954;
CDL:
091624­
K.

00117874
Buckman
Laboratories,
Inc.
(
1967)
Study:
TCMTB
Residues
in
Selected
Grains).
(
Compilation;
unpublished
study
received
Sep
28,
1972
under
2F1264;
CDL:
091795­
A.

00124027
Buckman
Laboratories,
Inc.
(
19??)
Analysis
of
Grains
for
Thioben­
zothiazole­
Containing
Residues.
Unpublished
study
received
Oct
20,
1972
under
2F1264;
CDL:
094858­
A.
TCMTB
Summary
Analytical
Chemistry
and
Residue
Data
­
RED
DP
Barcode:
322617
Page
23
of
23
00136342
Buckman
Laboratories,
Inc.
(
19??)
Analysis
of
Grains
for
Thioben­
zothiazole­
Containing
Residues.
Unpublished
study
received
on
unknown
date
under
2F1264;
CDL:
097967­
A.

00138078
Buckman
Laboratories,
Inc.
(
1975)
Residue
Data:
Busan
30:
Sugar
Cane.
Unpublished
study
received
Nov
12,
1976
under
7F1885;
CDL:
097566­
B.

42376801
Raub,
M.;
Valle,
H.
(
1992)
Uptake
and
Translocation
of
carbon
14|
Busan
30A
Used
in
Seed
Treatment:
Combustion
Analysis
Phase:
Lab
Project
Number:
39601.
Unpublished
study
prepared
by
ABC
Labs,
Inc.
34
p.

43147201
Raub,
M.
(
1994)
Uptake
and
Translocation
of
(
carbon
14)­
Busan
30A
Used
in
Seed
Treatment:
Addendum
Report:
Lab
Project
Number:
39601A.
Unpublished
study
prepared
by
ABC
Labs.,
Inc.
13
p.

44501301
Singer,
G.
(
1998)
Nature
of
the
Residue
from
(
carbon
14)­
TCMTB
in/
on
Tomatoes
after
Soil­
Drench
Applications:
Final
Report:
Lab
Project
Number:
AA960317:
XBL96101.
Unpublished
study
prepared
by
American
Agricultural
Services,
Inc.
and
XenoBiotic
Labs.
26
p.

44501302
Singer,
G.
(
1998)
Nature
of
the
Residue
from
(
carbon
14)­
TCMTB
in/
on
Melons
after
Soil­
Drench
Applications:
Final
Report:
Lab
Project
Number:
AA960318:
XBL96101.
Unpublished
study
prepared
by
American
Agricultural
Services,
Inc.
and
XenoBiotic
Labs.
26
p.

44654101
Singer,
G.
(
1998)
Nature
of
the
Residue
from
(
carbon­
14)­
TCMTB
in/
on
Melons
after
Soil­
Drench
Applications:
Final
Report:
Lab
Project
Number:
AA960318:
XBL96101:
AA960318.
NC.
Unpublished
study
prepared
by
American
Agricultural
Services,
Inc.
and
XenoBiotic
Laboratories.
268
p.

44654102
Singer,
G.
(
1998)
Nature
of
the
Residue
from
(
carbon­
14)­
TCMTB
in/
on
Tomatoes
after
Soil­
Drench
Applications:
Final
Report:
Lab
Project
Number:
XBL96101:
AA960317.
Unpublished
study
prepared
by
American
Agricultural
Services,
Inc.
and
XenoBiotic
Laboratories.
257
p.
