7/29/99

MEMORANDUM

SUBJECT:	Triallate.  Residue Chemistry and Product Chemistry Chapters of
the Reregistration Eligibility Decision Document.   P.C.Code 078802. 
Case No. 2500.  DP Barcode D257865.

FROM:		José J.  Morales, Ph.D., Chemist

Reregistration Branch 3

Health Effects Division (7509C)

THRU:		Steve Knizner, Branch Senior Scientist

Reregistration Branch 3

Health Effects Division (7509C)

TO:			Michael Goodis/Kathy Monk

Special Review and Reregistration Division (7508C)

The Residue and Product Chemistry Chapters of the Triallate
Reregistration Eligibility Decision Document are attached.  These were
completed by Dynamac Corp. under contract to the Agency and they have
undergone secondary review within HED to assure that they reflect
current policy.  

If you need additional information, HED will be pleased to provide it.

	TRIALLATE

PC Code No. 078802; Case 2695

Reregistration Eligibility Decision (RED) Document;

Product Chemistry Considerations

November 9, 1998

Contract No. 68-D4-0010

Submitted to:

U.S. Environmental Protection Agency

Arlington, VA

Submitted by:

Dynamac Corporation

The Dynamac Building

2275 Research Boulevard

Rockville, MD 20850-3268

	TRIALLATE

	REREGISTRATION ELIGIBILITY DECISION:

	PRODUCT CHEMISTRY CONSIDERATIONS

	PC Code 078802; Case No. 2695

DESCRIPTION OF CHEMICAL

Triallate [S-(2,3,3-trichloroally) diisopropylthiocarbamate] is a
preemergence selective herbicide registered for use on barley, lentils,
peas (dried and succulent), and wheat.

Empirical Formula:		C10H16Cl 3NOS

Molecular Weight:		304.66

CAS Registry No.:		2303-17-5

PC Code:				078802

IDENTIFICATION OF ACTIVE INGREDIENT

Triallate technical is an amber to dark brown solid with a melting point
of 29-30 (C, specific gravity of 1.2600-1.2624 at 35 (C, octanol/water
partition coefficient (log Kow) of 4.54, and vapor pressure of 1.1 x
10-4 mm Hg at 25 (C.  Triallate is slightly soluble in water (4 ppm at
25 (C), and is soluble in methylene chloride, n-octanol, and toluene at
>200 g/100 mL. 

MANUFACTURING-USE PRODUCTS

A search of the Reference Files System (REFS) conducted 9/21/99
identified a single triallate manufacturing-use product (MP) registered
under PC Code 078802; the Monsanto Agricultural Company 94% T (EPA Reg.
No. 524-307).  Only the registered 94% T/TGAI is subject to a
reregistration eligibility decision.

REGULATORY BACKGROUND

The Triallate Phase 4 Review dated 1/22/91 by S. Funk determined that
additional data were required concerning starting materials and the
production process, enforcement analytical methods, and solubility
(OPPTS 830.1600, 1620, 1800, and 7840); all other product chemistry data
submissions were determined to be adequate for Phase 5 review.  The
current status of the product chemistry data requirements for the
triallate T/TGAI is presented in the attached data summary tables. 
Refer to these tables for a listing of the outstanding product chemistry
data requirements. 

CONCLUSIONS

Pertinent product chemistry data requirements remain unfulfilled for the
Monsanto 94% T/TGAI concerning discussion of formation of impurities,
stability, pH, UV/visible absorption, and octanol/water partition
coefficient (OPPTS 830.1670, 6313, 7000, 7050, and 7550).  Provided that
the registrant submits the data required in the attached data summary
table for the 94% T/TGAI, and either certifies that the suppliers of
beginning materials and the manufacturing process for the triallate
technical product have not changed since the last comprehensive product
chemistry review or submits a complete updated product chemistry data
package, HED has no objections to the reregistration of triallate with
respect to product chemistry data requirements.

AGENCY MEMORANDA CITED IN THIS DOCUMENT

CBRS No(s):	8578

DP Barcode(s):	D168458

Subject:		Triallate.  Monsanto Response to June 1991 DCI.

From:		F. Fort

To:			L. Deluise

Dated:		1/28/92

MRID(s):		00155733

CBRS No(s):	10311

DP Barcode(s):	D181084

Subject:		Triallate Reregistration (a List B Chemical):  Monsanto
Response to Triallate (Case #2695; Chemical #078802) Reregistration
Product Chemistry Data Requirements (Regarding Solubility Guideline
#63-8).

From:		F. Toghrol

To:			L. Rossi and L. Deluise

Dated:		10/8/92

MRID(s):		42408401

CBRS No(s):	11102

DP Barcode(s):	D185979

Subject:		Triallate Reregistration (List B Chemical):  Monsanto Response
to Triallate (Case #2695; Chemical #078802) Reregistration Product
Chemistry Data Requirements (Guideline Nos. 61-1 and 61-2a).

From:		F. Toghrol

To:			K. Davis

Dated:		3/26/93

MRID(s):		No MRID Number

DP Barcode(s):	None; Registration Division Memorandum

Subject:		Triallate Technical (Amend CSF to Include
Cross-Contamination), EPA Registration No. 524-307, Your Application
Dated December 8, 1997.

From:		J. Tompkins

To:			A. Li (Monsanto Company)

Dated:		1/22/98

MRID(s):		None

PRODUCT CHEMISTRY CITATIONS

Bibliographic citations include only MRIDs containing data which fulfill
data requirements. 

References (cited):

00155733 Hicks, O.; Schulz, W.; Dietrich, D., et al.  (1985) Product
Chemistry Data for Manufacturing-use Product triallate
S-(2,3,3-Trichloroallyl)-N,N-diisopropylthiocarbamate): Project No: 7162
and Report No.: MSL-5095. Unpublished compilation prepared by Monsanto
Co. 300 p. 

42089001 Monsanto Agricultural Co. (1991) Addendum to Phase 3 Summary of
 MRID 00155733: [Product Chemistry]: Lab Project No: 7162 and 1064. 
Unpublished study.  9 p.  

42273501 Pesselman, R. (1992) Dissociation Constant Determination of 
Triallate: Lab Project Number: HWI 6103-141: CP12-91-9-H. Unpublished
study prepared by Hazleton Wisconsin, Inc.  31 p. 

42408401 Pesselman, R. (1992) Series 63 Product Chemistry: Determination
 of Triallate (Solubility): Lab Project Number: HWI 6103-150:  MAC
CP12-91-9-I: RD 1116.  Unpublished study prepared by  Hazleton
Wisconsin, Inc.  33 p. 



Table 1:  Manufacturing and Impurity Data for the Monsanto 94% T.



GLN	

Requirement	

MRID	

Status1	

Details and/or Deficiency



830.1550	

Product identity and composition	

	

A	





830.1600	

Description of materials used to produce the product	

	

A	





830.1620	

Description of production process	

42089001	

A	





830.1670	

Discussion of formation of impurities	

00155733	

N	

A discussion is required concerning the potential for formation of
post-production impurities resulting from degradation of the product, or
cross-contamination from manufacturing equipment or migration of
packaging materials.



830.1700	

Preliminary analysis	

00155733	

A	

The registrant must confirm that the preliminary analyses represent the
current manufacturing site; otherwise, preliminary analysis will be
required on five batches manufactured at the current site using the
current manufacturing process.



830.1750	

Certified limits 	

	

A	





830.1800	

Enforcement analytical method	

	

A	





1  A = Acceptable; N = Unacceptable (see Deficiency); N/A = Not
Applicable.



Table 2:  Physical and Chemical Properties for Monsanto 94% T/TGAI and
PAI (unspecified purity).



GLN	

Requirement	

MRID	

Status1	

Result2 or Deficiency



830.6302	

Color	

00155733	

A	

White (PAI)

Amber to dark brown (T/TGAI)



830.6303	

Physical state	

00155733	

A	

Crystalline solid (PAI)

Solid (T/TGAI)



830.6304	

Odor	

00155733	

A	

None (PAI)

Slightly sulfurous (T/TGAI)



830.6313	

Stability	

00155733	

N	

Stable for 2 weeks at 50 C; stable upon exposure to iron, copper, and
zinc (T/TGAI)

Quantitative data are required demonstrating the stability of the TGAI
upon exposure to metals and metal ions.



830.6314	

Oxidation/reduction:  chemical incompatibility	

00155733	

A	

No reaction with NH4H2PO4, Zn, Fe, CO4, and H2O; partially reduced with
0.1 M KMnO4 (T/TGAI)



830.6315	

Flammability	

00155733	

A	

170 C (T/TGAI; ASTM D56-79)



830.6316	

Explodability	

00155733	

A	

No exotherms were observed to indicate combustion; endothermic (melting)
changes observed in an aluminum crucible with platinum lid at an air
atmosphere flow rate of 75 cc/min and heating rate of 10 C/minute
(T/TGAI; ASTM E487)



830.6317	

Storage stability	

00155733	

N	

Stable for 1.5 years (T/TGAI)

The storage temperature and container must be specified. 



830.6319	

Miscibility	

00155733	

A	

Miscible with C9 hydrocarbons used for formulation



830.6320	

Corrosion characteristics	

00155733	

A	

Corrosive to many metals, but is produced in glass-lined steel equipment
and stored/shipped in phenolic-resin lined tanks or drums; following 120
hours exposure at 105 C, Hastelloy C-276 lost 17.3 MPY in the liquid
phase and 1.4 MPY in the vapor phase, titanium lost 0.2 and 0.1 MPY,
Inconel 625 lost 17.3 and 14.6 MPY, and  titanium with 0.2% palladium
lost 0.4 MPY in each phase.



830.7000	

pH	

00155733	

N	

4.59 (TGAI; 1% solution in dioxane:0.1 M NaCl, 4:1)

The temperature at which the determination was made must be specified.



830.7050	

UV/Visible absorption	

	

N	

The OPPTS Series 830, Product Properties Test Guidelines require data
pertaining to UV/visible absorption for the PAI.



830.7100	

Viscosity	

00155733	

A	

10.24 cS at 45 C (T/TGAI)



830.7200	

Melting point/

melting range	

00155733	

A	

32-34 C (PAI)

29-30 C (T/TGAI)



830.7220	

Boiling point/

boiling range	

	

N/A	

T/TGAI is a solid at room temperature



830.7300	

Density/

relative density/

bulk density	

00155733	

A	

Specific gravity = 1.2600-1.2624 at 35 C

(T/TGAI; hydrometer)



830.7370	

Dissociation constants in water	

42273501	

N/A	

TGAI is not an acid or a base; attempts to determine the dissociation
constant using titration and UV/vis spectrophotometric methods were
unsuccessful (T/TGAI)



830.7550 	

Partition coefficient (n-octanol/water), shake flask method	

00155733	

N	

log Kow = 4.54 (PAI)

The temperature at which the determination was made must be specified.



830.7840 	

Water solubility:  column elution method; shake flask method	

	

A	





830.7950	

Vapor pressure	

00155733	

A	

1.1 x 10-4 mm Hg at 25 C 

(PAI; gas saturation)



1  A = Acceptable; N = Unacceptable (see Deficiency); N/A = Not
applicable.  

2  For example, "brown" for 830.6302; "155o C" for 830.7200.

Case No. 2695

PC Code 078802

Case Name:  Triallate

Registrant:  Monsanto Agricultural Company

Product(s):  94% T (EPA Reg No. 524-307)

	PRODUCT CHEMISTRY DATA SUMMARY

Guideline

Number	

Requirement	

Are Data Requirements Fulfilled? 1	

MRID Number 2



830.1550	

Product identity and composition	

Y  	

00155733, 

CSF dated 12/14/92 3,

CSF dated 12/8/97 4



830.1600	

Description of materials used to produce the product	

Y 	

00155733 5, No MRID # 3



830.1620	

Description of production process	

Y 	

00155733 5, 42089001



830.1670	

Discussion of formation of impurities	

N 6 	

00155733



830.1700	

Preliminary analysis	

Y 7 	

00155733



830.1750	

Certified limits	

Y 	

00155733,

CSF dated 12/14/92 3,

CSF dated 12/8/97 4



830.1800	

Enforcement analytical method	

Y 	

00155733 5



830.6302	

Color	

Y 	

00155733



830.6303	

Physical state	

Y 	

00155733



830.6304	

Odor	

Y 	

00155733



830.6313	

Stability to normal and elevated temperatures, metals, and metal ions	

N 8	

00155733



830.7000	

pH	

N 9	

00155733



830.7050	

UV/Visible absorption	

N 10	





830.7200	

Melting point/melting range	

Y 	

00155733



830.7220	

Boiling point/boiling range	

N/A 11 	





830.7300	

Density/relative density/bulk density	

Y 	

00155733



830.7370	

Dissociation constants in water	

N/A 12	

42273501 



830.7550	

Partition coefficient (n-octanol/water), shake flask method	

N 9	

00155733



830.7840	

Water solubility: column elution method; shake flask method	

Y 	

00155733 13, 42408401 13



830.7950	

Vapor pressure	

Y 	

00155733



1 Y = Yes; N = No; N/A = Not Applicable.

2 Bolded references were determined to be adequate for Phase 5 review in
the Triallate Phase 4 review dated 1/22/91 by S. Funk; the remaining
references were reviewed as noted.

3 CBRS No. 11102, D185979, 3/26/93, F. Toghrol. 

4 Registration Division Memorandum, 1/22/98, J. Tompkins.

5 CBRS No. 8578, D168458, 1/28/92, F. Fort.

6 A discussion is required concerning the potential for formation of
post-production impurities resulting from degradation of the product, or
cross-contamination from manufacturing equipment or migration of
packaging materials.

7 The registrant must confirm that the preliminary analyses represent
the current manufacturing site; otherwise, preliminary analysis will be
required on five batches manufactured at the current manufacturing site
using the current manufacturing process.

8 Quantitative data are required demonstrating the stability of the TGAI
upon exposure to metals and metal ions.

9 The temperature at which the determination was made must be specified.

10 The OPPTS Series 830, Product Properties Test Guidelines require data
pertaining to UV/visible absorption for the PAI.

11 Data are not required because the TGAI is a solid at room
temperature.

12 Data are not required because the TGAI is not an acid or a base;
attempts to generate the dissociation constant for the TGAI were
unsuccessful.

13 CBRS No. 10311, D181084, 10/8/92, F. Toghrol.

	TRIALLATE

PC Code No. 078802; Case 2695

Reregistration Eligibility Decision (RED) Document;

Residue Chemistry Considerations

November 9, 1998

Contract No. 68-D4-0010

Submitted to:

U.S. Environmental Protection Agency

Arlington, VA

Submitted by:

Dynamac Corporation

The Dynamac Building

2275 Research Boulevard

Rockville, MD 20850-3268

	TRIALLATE

	REREGISTRATION ELIGIBILITY DECISION

	RESIDUE CHEMISTRY CONSIDERATIONS

	PC Code  No. 078802; Case 2695

	TABLE OF CONTENTS	page

 TOC \f 

INTRODUCTION	2

REGULATORY BACKGROUND	2

SUMMARY OF SCIENCE FINDINGS	3

GLN 860.1200:  Directions for Use	3

GLN 860.1300:  Nature of the Residue - Plants	6

GLN 860.1300:  Nature of the Residue - Animals	7

GLN 860.1340:  Residue Analytical Methods	7

GLN 860.1360:  Multiresidue Methods	8

GLN 860.1380:  Storage Stability Data - Plants	9

GLN 860.1380:  Storage Stability Data - Animals	9

GLN 860.1500:  Crop Field Trials	10

GLN 860.1520:  Processed Food/Feed	12

GLN 860.1480:  Meat, Milk, Poultry, Eggs	13

GLN 860.1400:  Water, Fish, and Irrigated Crops	16

GLN 860.1460:  Food Handling	16

GLN 860.1850 and 860.1900:  Confined/Field Accumulation in Rotational
Crops	16

TOLERANCE REASSESSMENT SUMMARY	23

Tolerances Listed Under 40 CFR §180.314	23

New Tolerances Needed Under 40 CFR §180.314	23

Pending Active Tolerance Petition	24

CODEX HARMONIZATION	27

DIETARY EXPOSURE ASSESSMENT	27

AGENCY MEMORANDA RELEVANT TO REREGISTRATION	28

MASTER RECORD IDENTIFICATION NUMBERS	34

 

	TRIALLATE

 

	REREGISTRATION ELIGIBILITY DECISION

	RESIDUE CHEMISTRY CONSIDERATIONS

	PC Code 078802; Case 2695

INTRODUCTION tc \l1 "INTRODUCTION 

Triallate is a pre-emergent selective herbicide regionally registered
for use on barley, lentils, peas (dried and succulent), triticale, and
wheat.  Triallate is sold in the United States by its basic producer,
Monsanto Company, under the trade names Far-Go®, Buckle®, and
Avadex®.  The 10% granular (G) and 4 lb/gal emulsifiable concentrate
(EC) for  Far-Go® and Buckle® are the only triallate formulations
registered for food/feed uses.  Depending on the crop, these
formulations may be applied at application rates of 1.0-1.5 lb ai/A as
preplant and postplant soil incorporated using ground or aerial
equipment.  Application is typically made either in the fall or in the
spring before targeted weed species germinate.  Regional registrations
and tolerances (labels restrict the use to the following states: CO, ID,
KS, MN, MT, NE, NV, ND, OR, SD, UT, WA, and WY) are currently
established under 40 CFR §180.314 (a) for residues of parent triallate
in or on the following commodities: barley grain and straw, 0.05 ppm
(N); canary grass (annual) seed and straw, 0.05 ppm; lentils and lentil
forage and hay, 0.05 ppm (N); peas and pea forage and hay, 0.05 ppm (N);
wheat grain and straw, 0.05 ppm (N).  No tolerances have been
established for processed food/feed or animal commodities.  At the
request of the Special Review and Reregistration Division (SRRD),
residue data for sugar beets are discussed in this chapter although
sugar beets are not registered for use in the US.  A tolerance petition
for sugar beets is currently pending.

REGULATORY BACKGROUND tc \l1 "REGULATORY BACKGROUND 

A Triallate Phase 4 Review of residue chemistry data was issued on
1/22/91, and a Triallate Data-Call-In (DCI) Notice was subsequently
issued on 6/4/91.  The Health Effects Division (HED) has conducted Phase
5 Review of several residue chemistry studies that were submitted in
response to the DCI as well as studies that were deemed acceptable for
evaluation during Phase 4 Review.  The information contained in this
document outlines the Residue Chemistry Science Assessments with respect
to the reregistration of triallate.

 No Codex MRLs have been established for residues of triallate;
therefore, issues of compatibility between U.S. tolerances and Codex
MRLs do not exist.  Adequate methods are available for the enforcement
of triallate tolerances, as currently expressed, in/on plant
commodities.  A GC method, using electron capture detection (Method A)
is listed in the Pesticide Analytical Manual (PAM) Vol. II for the
determination of residues of triallate per se.

SUMMARY OF SCIENCE FINDINGS tc \l1 "SUMMARY OF SCIENCE FINDINGS 

GLN 860.1200:  Directions for Use tc \l2 "GLN 860.1200:  Directions for
Use 

Monsanto Company has five active triallate end-use products (EPs; see
Table A1) registered under FIFRA Section 3 for food/feed uses [Source:
REFS search conducted 9/21/98].  There are no active triallate Special
Local Need (SLN) registrations under FIFRA Section 24(c).

Table A1.	Triallate EPs with Food/Feed Uses Registered to Monsanto
Company.

EPA Reg. No.	

Label Acceptance Date	

Formulation	

Product Name



524-124 a	

9/24/74	

4 lb/gal EC	

Avadex® BW Selective Herbicide



524-145	

12/11/96	

4 lb/gal EC	

Triallate Far-Go® Herbicide



524-291	

9/25/72	

10% G	

Granular Avadex® BW Herbicide



524-292	

2/27/98	

10% G	

Granular Far-Go® Herbicide



524-375	

11/17/97	

10% G	

Granular Buckle® Herbicide



a	The jacket for EPA Reg. No. 524-124 specifies that this product is
currently suspended for failure to comply with a Label DCI Notice dated
10/6/89.  Therefore, the uses associated with this label are not
included in Table A2.

A comprehensive summary of triallate food/feed use patterns, based on
the product labels registered to Monsanto Company, is presented in Table
A2.  A tabular summary of the residue chemistry science assessments for
reregistration of triallate is presented in Table B.  The status of
reregistration requirements for each guideline topic listed in Table B
is based on the use patterns registered to Monsanto Company.  For the
purpose of generating this Residue Chemistry Chapter, the Agency
examined the registered food/feed use patterns and reevaluated the
available residue chemistry database for adequacy in supporting these
use patterns. 

When end-use product DCIs are developed (e.g., at issuance of the RED),
RD should require that all end-use product labels (e.g., MAI labels and
products subject to the generic data exemption) be amended such that
they are consistent with the basic producer labels.

Table A2.	Food/Feed Use Patterns Subject to Reregistration for
Triallate (Case 2695).

Site

Application Timing

Application Type

Application Equipment	

Formulation

[EPA Reg. No.]	

Maximum Single Application Rate (ai)	

Maximum Number of Applications Per Season	

Maximum Seasonal Rate (ai)	

Preharvest Interval (Days)	

Use Limitations 3



Barley



Fall or spring 1

Preemergence soil incorporated 2

Ground/Aerial	

10% G

[524-291]

[524-292]

[524-375]

4 lb/gal EC

[524-145]	

1.5 lb/A	

1 (Implied)	

1.5 lb/A	

Not specified (NS)	

Use limited to the states of CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, UT,
WA, and WY.  The 4 lb/gal EC formulation may be tank mixed with
trifluralin when applied during spring.





Lentils



Spring 1

Preemergence soil incorporated 2

Ground/Aerial	

10% G

[524-292]

4 lb/gal EC

[524-145]	

1.5 lb/A	

1 (Implied)	

1.5 lb/A	

NS	

Use limited to the states of CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, UT,
WA, and WY.





Peas (Including Green, Field, Chickpeas, and Garbanzo Beans)



Spring 1

Preemergence soil incorporated 2

Ground/Aerial	

10% G

[524-292]

[524-375]

4 lb/gal EC

[524-145]	

1.5 lb/A	

1 (Implied)	

1.5 lb/A	

NS	

Use limited to the states of CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, UT,
WA, and WY.





Triticale



Spring 1

Preemergence soil incorporated 2

Ground/Aerial	

10% G

[524-292]

4 lb/gal EC

[524-145]	

1.5 lb/A	

1 (Implied)	

1.5 lb/A	

NS	

Use limited to the states of CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, UT,
WA, and WY.





Wheat



Fall or spring 1

Preemergence soil incorporated 2

Ground/Aerial	

10% G

[524-291]

[524-292]

[524-375]

4 lb/gal EC

[524-145]	

1.25 lb/A for spring treatment

1.5 lb/A for fall treatment	

1 (Implied)	

1.5 lb/A	

NS	

Use limited to the states of CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, UT,
WA, and WY.  The 4 lb/gal EC formulation may be tank mixed with
trifluralin when applied during spring.



Sugar Beets



Fall or Spring1 Preemergence soil incorporated

Ground/Aerial	

10%G

[524-292]

4 lb/gal EC

[524-145]	

1.25 - 1.5 lb/A	

1	

1.5 lb/A	

NS	

Apply before seeding.  Band applications are permitted at proportional
rates.  No rotational crop restrictions are specified.  Use limited to
the states of CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, UT, WA, and WY.



1	Fall application on barley and wheat should be made within 3 weeks of
normal freeze-up cover or until snow cover occurs.  Spring application
to barley and wheat should be made before or after seeding.  Spring
application on barley, lentils, peas, triticale, and wheat should be
made before weeds germinate or immediately after seeding.

2	Soil incorporation should be made within 48 hours after application. 
Surface application with delayed incorporation may be made in ID, MN,
MT, ND, and UT.  No till application may be made in spring-planted crops
in MT only.

3	Do not graze livestock on treated crops.

GLN 860.1300:  Nature of the Residue - Plants tc \l2 "GLN 860.1300: 
Nature of the Residue - Plants 

The reregistration requirements for plant metabolism are fulfilled based
on acceptable studies conducted on wheat, peas, and sugar beets.  In
wheat, it was demonstrated that some portion of the radiolabeled
triallate is catabolized and subsequently incorporated into natural
products.  In peas, neither triallate nor any of the trichlorinated
3-carbon metabolites [such as
3-(methylsulfinyl)-1,1,2-trichloro-1-propene;
3-(methylsulfonyl)-1,1,2-trichloro-1-propene; and
2,3,3-trichloro-2-propen-1-ol which were previously reported in rat
urine] were identified.  The metabolite
2,3,3-trichloroprop-2-enesulfonic acid (TCPSA) was the major residue
found in the pea with pod (16% TRR), green vine (40% TRR), and dry hay
(21% TRR).  Two other minor metabolites, oxalylglucose sulfoxide and
sulfone, were also found in dried hay (1% and 13% TRR, respectively);
only the sulfoxide was found in green vine (9% TRR).  The pea
metabolism study demonstrated the incorporation of radioactivity into
sugars (mono-, di-, and trisaccharides), amino acids, starch, pectins,
lignin and cellulose.  Triallate was metabolized in pea via oxidation at
the allylic carbon, leading to natural products, or oxidation and
hydrolysis at the sulfur atom, leading to metabolites (oxalylglucose
sulfoxide and sulfone).  The sulfoxide and sulfone metabolites would
metabolize to TCPSA.  A sugar beet metabolism study submitted and
evaluated in conjunction with PP#8F2128 showed that TCPSA was the major
residue in sugar beet root (15% TRR) and foliage (55% TRR).  

The HED  Metabolism Assessment Review Committee (L. Cheng memo of
6/22/98) has determined that only triallate and TCPSA should be
regulated and assessed for dietary exposure.  The chemical name and
structures of triallate residues of concern are depicted in Figure 1.

Figure 1	 Chemical Names and Structures of Triallate Residues of Concern
in Plant and Animal Commodities.

Common Name

Chemical Name	

Structure



Triallate

S-2,3,3-Trichloroallyl diisopropyl- thiocarbamate	

 





TCPSA

2,3,3-Trichloroprop-2-enesulfonic acid	

 





GLN 860.1300:  Nature of the Residue - Animals tc \l2 "GLN 860.1300: 
Nature of the Residue - Animals 

The reregistration requirements for animal metabolism are fulfilled. 
Acceptable ruminant and poultry metabolism studies have been submitted
and evaluated.  In a ruminant metabolism study, a lactating goat was
orally administered  [14C]triallate at 14 ppm in the diet for five
consecutive days.  The total radioactive residues (expressed as
triallate equivalents) were 0.177 ppm in milk, 1.08 ppm in liver, 2.46
ppm in kidney, 0.033 ppm in muscle, and 0.017 ppm in omental fat.  The
parent triallate was identified as a minor component in omental fat
(12.4% TRR) and milk (2.3% TRR).  The majority of radioactive residues
in goat milk and edible tissues were found to be associated with natural
constituents.

In a poultry metabolism study, laying hens were orally dosed once daily
with [14C]triallate at approximately 13 ppm in the diet for five
consecutive days.  The total radioactive residues (expressed as
triallate equivalents) were 0.540 ppm in egg yolk, 0.054 ppm in egg
white, 1.29 ppm in liver, 0.042 ppm in breast muscle, 0.049 ppm in thigh
muscle, 0.193 ppm in abdominal fat, and 0.100 ppm in skin with fat.  The
parent triallate was identified in egg yolk (2.8% TRR), abdominal fat
(23.7% TRR), and skin with fat (16.5% of TRR).  The majority of
radioactive residues in poultry eggs and edible tissues were also found
to be associated with natural constituents.

Since very little or low levels of triallate were transferred to animal
tissues (0.004 ppm in milk and 0.002 ppm in poultry fat), the HED 
Metabolism Assessment Review Committee (L. Cheng memo of 6/22/98) has
concluded that meat, egg, and milk tolerances are not required, pending
results of the rotational crop studies and reassessment of animal feed
tolerances.  The Committee’s determination was based on the current
feed tolerances (expressed in terms of triallate per se) and the
theoretical maximum dietary burden for livestock animals which is a
fraction of the dose administered in the completed goat and chicken
metabolism studies.

GLN 860.1340:  Residue Analytical Methods tc \l2 "GLN 860.1340:  Residue
Analytical Methods 

Methods for determination of residues in/on plant commodities:  The
current PAM Vol. II method is a GC/ECD method (designated as Method A)
which is used for analysis of residues of triallate per se in/on
lentils, peas, and grain and straw of barley and wheat (Pesticide Reg.
Sec. 180.314).  PAM Vol. II reports the sensitivity of the method (LOQ)
as 0.02 ppm.

In conjunction with an ongoing petition (PP#8F2128) for the regional
registration of triallate on sugar beets, the registrant has proposed a
GC/ECD method (designated as Method RES-099-96, Version No. 2) for
tolerance enforcement purposes.  The method determines residues of
triallate and its TCPSA metabolite.  This method has been subjected to a
successful independent laboratory validation.  The method has also been
validated in an Agency study at Beltsville, MD. 

 	The laboratory (Analytical Chemistry Branch, BEAD) verified the
limits of quantitation (LOQs) to be 0.025 ppm triallate and 0.025 ppm
TCPSA in/on sugar beet roots, and 0.05 ppm triallate and 0.20 ppm TCPSA
in/on sugar beet foliage.  The Beltsville report (7/28/98) also
estimated the limits of detection (LODs) to be 0.001 ppm triallate and
0.004 ppm TCPSA in sugar beet root, and 0.005 ppm triallate and 0.04 ppm
TCPSA in sugar beet top.  This method has been submitted to FDA for
inclusion in PAM II.

A brief description of the modified method follows.  Residues in samples
are extracted by homogenization with  acetonitrile/water.  Solids are
removed by filtration and a solution of Na2SO4 is added to the extract. 
The solution is partitioned with isooctane to isolate triallate.  The
aqueous phase is retained for later isolation of TCPSA.  The isooctane
phase is concentrated and eluted through a silica gel SPE cleanup column
and then analyzed by capillary GC using a 63Ni electron capture
detector.  The retained aqueous layer is partitioned with methylene
chloride, once as a cleanup, and a second time using phase transfer
catalyst.  The second extract is evaporated, treated with a cation
exchange resin, derivatized with triethylorthoformate, eluted through a
silica gel SPE cleanup column, and analyzed for ethyl sulfonate by
capillary GC using an 63Ni-ECD.  As a confirmatory technique, the
conditions for separation on a different GC column (non-polar instead of
polar) were provided.  Positive residues can be confirmed with this
alternate GC column or by GC/MS.

The Agency concludes that Monsanto’s GC/ECD method (designated as
Method RES-099-96, Version No. 2) is adequate for data gathering and
enforcement purposes.  Radiovalidation of the proposed method using
weathered samples from plant metabolism studies are not required because
the Agency has determined that the initial extraction procedures of
residues in representative samples collected from plant metabolism
studies are similar to those of the proposed enforcement method.

Methods for determination of residues in animal commodities:  An
enforcement method for determination of residues of triallate and its
TCPSA metabolite is not required because tolerances for eggs, milk, and
animal tissues have not been established and are not required for
reregistration purposes.   Samples of eggs, milk, and tissues collected
from animal feeding studies were analyzed for residues of triallate and
its TCPSA metabolite using an adequate GC/ECD method with a detection
limit of 0.01 ppm.

GLN 860.1360:  Multiresidue Methods tc \l2 "GLN 860.1360:  Multiresidue
Methods 

The 2/97 FDA PESTDATA database (PAM Volume I, Appendix I) indicates that
residues of triallate are completely recovered (>80%) using Multiresidue
Method Sections 302 (Luke Method; Protocol D), 303 (Mills, Onley,
Gaither Method; Protocol E, non-fatty foods), and Section 304 (Mills
Method; Protocol E, fatty foods).

Multiresidue methods test data for determination of TCPSA in/on plant
commodities have recently been submitted and forwarded to FDA for
evaluation and inclusion in PAM Volume I, Appendix I.

GLN 860.1380:  Storage Stability Data - Plants tc \l2 "GLN 860.1380: 
Storage Stability Data - Plants 

Adequate data concerning the storage stability of triallate and its
TCPSA metabolite in/on plant commodities have been submitted and
evaluated.  Residues of triallate have been demonstrated to be stable
under frozen storage condition in/on the following representative RACs: 
wheat forage (for up to 1,732 days), wheat straw (for up to 645 days),
barley straw (for up to 689 days), dry bean hay (for up to 731 days),
dry bean vines (for up to 653 days), and succulent bean hay (for up to
752 days).  Residues of TCPSA metabolite have been demonstrated to be
stable under frozen storage condition in/on the following representative
RACs:  wheat forage (for up to 1736 days), wheat straw (for up to 659
days), wheat grain (for up to 719 days), barley straw (for up to 702
days), dry bean hay (for up to 741 days), dry bean vines (for up to 682
days), succulent bean seeds/pods (for up to 964 days), and succulent
bean hay (for up to 759 days).  Residues of triallate and TCPSA are
stable for up to 314 days in sugar beet tops and for up to 376 days in
sugar beet root.  The storage intervals and conditions of RAC samples
collected from the respective field trials are validated by acceptable
storage stability data.

Adequate storage stability data are available for wheat processed
fractions.  Residues of triallate and its TCPSA metabolite are stable
under frozen storage conditions in wheat bran, shorts, and flour for at
least 5 months.  Although storage stability data for middlings were not
submitted, the Agency believes that triallate residues of concerns would
also be stable in this processed fraction.

GLN 860.1380:  Storage Stability Data - Animals tc \l2 "GLN 860.1380: 
Storage Stability Data - Animals 

Adequate data concerning the storage stability of triallate and its
TCPSA metabolite in animal  commodities have been submitted and
evaluated.  Residues of triallate and its TCPSA metabolite have been
demonstrated to be stable under frozen storage condition in/on the
following animal matrices:  chicken muscle (for up to 611 days), eggs
(for up to 615 days), milk (for up to 611 days), beef muscle (for up to
651 days), beef fat (for up to 658 days), beef liver (for up to 647
days), beef kidney (for up to 647 days), and pork kidney (for up to 616
days).  The storage intervals and conditions of animal tissue samples
collected from the respective animal feeding studies trials are
validated by acceptable storage stability data.

GLN 860.1500:  Crop Field Trials tc \l2 "GLN 860.1500:  Crop Field
Trials 

This Residue Chemistry Chapter assumes that for the purpose of
reregistration, uses of triallate on barley, lentils, peas
(dried/succulent and field peas), and wheat will be limited to the
following states:  CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, UT, WA, and
WY.  The registrant has indicated that use of triallate on canary grass
will not be supported for reregistration, and has deleted this use site
from all triallate end-use product labels.  Overall, the available data
indicate that residues of the metabolite TCPSA were generally higher
than the parent.  There appears to be no significant differences in the
results of field trials using the G and EC formulations.  A discussion
of the adequacy of the available field trial data for each crop follows.
 Triallate is not registered for use on sugar beets in the US, but a
petition for tolerances is pending.

Barley:  The reregistration requirements for magnitude of the residue
in/on barley grain and straw are fulfilled pending tolerance
adjustments.  Barley hay has now been included in Table 1 (OPPTS GLN
860.1000) as a significant livestock feed item.  The requested wheat hay
data may be translated to barley hay since the registered uses of
triallate on barley and wheat are identical.  In field trials conducted
in MT and WA, representative G and EC formulations were applied
according to label directions at 1.5, 2.0, 2.5, and 3.0 lb ai/A (1x,
1.3x, 1.7x, and 2x the maximum registered rate, respectively).  Barley
grain and straw were harvested at 110 to 113 days posttreatment, and
forage was harvested 54 to 59 days posttreatment.  The harvested samples
were analyzed for residues of triallate and its TCPSA metabolite using
an adequate GC/ECD method with a detection limit of 0.01 ppm.  The
results of the barley field trials, reflecting treatment at 1x, are
presented in Table 1.  Refer to “Tolerance Reassessment Summary"
section for recommendations regarding appropriate tolerance levels for
barley grain and straw. 

	Table 1. Residues of triallate and its TCPSA metabolite in/on barley
commodities following application

	of representative G and EC formulations at 1.5 lb ai/A (1x) (MRID
40117702).

Barley Matrix 1	

Residue Levels (ppm)

	

Triallate	

TCPSA	

Maximum Combined Residues



Grain	

<0.01	

<0.01	

<0.02



Straw	

0.01-0.03	

0.05-0.23	

0.26



Forage	

0.04-0.06	

0.10-0.23	

0.29



1	According to Table 1 (OPPTS 860.1000), the RACs of barley are grain,
hay, and straw.  Barley forage has been deleted from Table 1.

Lentils:  According to 40 CFR §180.1(h), the available dried pea field
trial data may be translated to lentils since the registered use
patterns of peas and lentils are identical.

Peas (succulent/dried):  The reregistration requirements for magnitude
of the residue in/on peas (succulent and dried), pea vines, and pea hay
are fulfilled pending tolerance adjustments. Field trials were conducted
on succulent peas (ND and WA, 2 field trials) and on dry peas (MN and
WI, 3 field trials).  Representative G and EC formulations were applied
according to label directions at 1.25 and 2.5 lb ai/A (~1x and 2x the
maximum registered rate).  Treated samples were harvested at the
following posttreatment intervals:  62-76 days for succulent pea
seed/pods and straw; 48-50 days for succulent pea vines; 79-110 days for
dry pea seed and straw; and 51-53 days for dry pea vines.  The harvested
samples were analyzed for residues of triallate and its TCPSA metabolite
using an adequate GC/ECD method with a detection limit of 0.01 ppm.  The
results of the pea field trials, reflecting treatment at ~1x, are
presented in Table 2.  Refer to “Tolerance Reassessment Summary"
section for recommendations regarding appropriate tolerance levels for
peas (succulent and dried), pea vines, and pea hay.

	Table 2.  Residues of triallate and its TCPSA metabolite in/on pea
commodities following

	 application of representative G and EC formulations at 1.25 lb ai/A
(~1x) (MRID 40117704).

Pea Matrix	

Residue Levels (ppm)

	

Triallate	

TCPSA	

Maximum Combined Residues



Succulent (green) Peas



Seed and pods	

<0.01	

0.06, 0.06, 0.10, 0.11	

<0.12



Vines	

<0.01-0.02	

0.19-0.37	

0.39



Straw	

<0.01	

0.31-0.72	

<0.73



Dry Peas



Seed and pods	

<0.01	

<0.01	

<0.02



Vines	

<0.01	

0.04-0.26	

<0.27



Straw	

<0.01	

0.05-0.35	

<0.36



Wheat:  The reregistration requirements for magnitude of the residue
in/on wheat grain, forage, and straw are fulfilled pending tolerance
adjustments.  Wheat hay and aspirated grain fractions have now been
included in Table 1 (OPPTS GLN 860.1000) as significant livestock feed
items.  Therefore, data depicting the magnitude of the residues of
triallate and its TCPSA metabolite in/on wheat hay are required; details
of data requirements for wheat hay are specified in Table B.  Data on
wheat aspirated grain fractions are not required because the registered
use of triallate on wheat involves preemergence application (before the
reproductive stage of the crop begins), and triallate residues of
concern in wheat grain were mostly below the LOD of the analytical
method.  

Eleven field  trials were conducted on spring wheat (ND, MT,CA and  KS)
and on winter wheat (CA, KS, MT, OK, WA and NY).  Representative G and
EC formulations were applied according to label directions at 1.5, 2.0,
2.5, and 3.0 lb ai/A (1x, 1.3x, 1.7x, and 2x the maximum registered
rate, respectively).  Harvest time varied considerably (36-312 days
posttreatment) depending on planting time and wheat matrix.  Wheat RACs
were analyzed for residues of triallate and its TCPSA metabolite using
an adequate GC/ECD method with a detection limit (LOD) of 0.01 ppm.  The
results of the wheat field trials, reflecting treatment at 1.0x, are
presented in Table 3.  Refer to “Tolerance Reassessment Summary"
section for recommendations regarding appropriate tolerance levels for
wheat grain, forage, and straw. 

	Table 3.  Residues of triallate and its TCPSA metabolite in/on wheat
commodities following

	application of representative G and EC formulations at 1.5 lb ai/A
(1x) (MRID 40117701).

Wheat Matrix 1	

Residue Levels (ppm)

	

Triallate	

TCPSA	

Maximum Combined Residues



Grain	

<0.01-0.01	

<0.01-0.03	

0.04



Straw	

0.01-0.03	

0.02-0.91	

0.94



Forage	

<0.01-0.12	

0.01-0.30	

0.42



1	According to Table 1 (OPPTS 860.1000), the RACs of wheat are grain,
forage, hay, straw, and aspirated grain fractions.

According to 40 CFR §180.1(h), the available wheat field trial data may
be translated to triticale since the registered use patterns of wheat
and triticale are identical.

Sugar Beets:  Ten field trials were conducted in ID, MN, ND, CA, NE, WY.
 Representative G and EC formulations were applied according to proposed
label directions from 1 to 10 lbs ai/A (0.5 x to 5x; 2 lbs ai/A = 1x
rate), 0 to 11 days prior to planting using ground application
techniques.  Roots and foliage samples were collected at harvest.  The
harvested samples were analyzed for residues of triallate and its TCPSA
metabolite using an adequate GC/ECD method with a detection limit (LOD)
of 0.01 ppm.  The results of the sugar beet trials reflecting
application at the proposed 1x rate are shown in Table 4.  Refer to
“Tolerance Reassessment Summary" section for recommendations regarding
appropriate tolerance levels for sugar beets. 

Table 4.  Residues of Triallate and its TCPSA metabolite in/on sugar
beet commodities following application of representative G and EC
formulations at 2.0 lbs ai/A (1x) (MRID 406922-01 and 406922-06).

Formulation	

Residue Levels (ppm)

	

Triallate	

TCPSA	

Maximum Combined Residues



Sugar Beet Root



10G	

<0.01, 0.01, 0.03	

<0.01	

<0.04



2 EC	

<0.01, 0.01	

<0.01	

<0.02



Sugar Beet Top



10G	

<0.01, 0.01	

0.02, 0.03, 0.04, 0.05, 0.07, 0.10, 0.13, 0.24, 0.24, 0.30 	

0.31



2 EC	

<0.01	

<0.01, 0.02, 0.02,  0.08, 0.08,  0.09, 0.12, 0.13, 0.16, 0.16	

<0.17



GLN 860.1520:  Processed Food/Feed tc \l2 "GLN 860.1520:  Processed
Food/Feed 

An acceptable wheat processing study has been submitted and evaluated. 
In this study, wheat was treated at 2.5 lb ai/A (1.7x the maximum
registered rate), and samples of treated whole grain were processed into
flour, bran, and shorts.  Residues were determined using an acceptable
GC/ECD method with a detection limit of 0.01 ppm.  The results of the
wheat processing study are presented  in Table 5.

	Table 5.  Results of a wheat processing study (MRID 40473801).

Commodity	

Residues (ppm)	

Concentration Factor

	

Triallate	

TCPSA	

Combined	

Triallate	

TCPSA	

Combined



Whole grain	

<0.01	

0.03	

<0.04	

--	

--	

--



Flour	

<0.01	

0.01	

<0.02	

1.0	

0.3	

0.5



Wheat Mill by-products	

<0.01	

0.07	

<0.08	

1.0	

2.3	

2.0



Bran	

<0.01	

0.09	

<0.10	

1.0	

3.0	

2.5



Shorts	

<0.01	

0.07	

<0.08	

1.0	

2.3	

2.0



The Agency has previously determined that although the potential for
concentration of residues in middlings was not investigated, no
additional data on this processed fraction will be required since
middlings are not a major end product, but an intermediate in producing
bran and shorts. Refer to “Tolerance Reassessment Summary" section for
a discussion regarding the need for tolerances on bran and shorts based
on the observed concentration factors.

A barley processing study is required for reregistration.  [According to
Triallate Phase 4, the registrant indicated in the Phase 2 Response that
a barley processing study is available, but no summary was provided.  A
search of PDMS showed no barley processing study.  The processed
fractions listed in Table 1 (OPPTS GLN.860.1000) for barley and wheat
are different.]

Two sugar beet processing studies  were  submitted to the Agency. 
Sugar beet root were treated at 10 lb ai/A (5x) and were processed in a
pilot facility under conditions similar to commercial processing. 
Samples of whole roots, dried pulp, white (refined) sugar and molasses
were analyzed for residues of triallate and TCPSA.  Results from the
processing studies are shown in Table 6.

Table 6.  Residues of Triallate and its TCPSA metabolite in/on sugar
beet and processed commodities following application of triallate at 10
lbs ai/A (5x) (MRID 412799-01).

Sugar Beet Matrix	

Residue Levels (ppm)

	

Triallate	

TCPSA	

Maximum Combined Residues



Baker, MN



Roots	

0.12, 0.05	

0.02, 0.03	

0.14, 0.08



Dried Pulp	

0.27	

0.03	

0.30



Sugar	

<0.01	

<0.01	

<0.02



Molasses	

<0.01	

0.01	

<0.02



Colfax, ND



Roots	

0.05, 0.01	

0.01, 0.02	

0.06, 0.03



Dried Pulp	

0.07	

0.01	

0.08



Sugar	

<0.01	

<0.01	

<0.02



Molasses	

<0.01	

0.02	

<0.03



As can be seen from Table 6, residues from the processing study
conducted in ND detected very low amounts of triallate and its
metabolite in the sugar beet root.  Therefore, for purposes of risk
assessment HED will only consider the study conducted in MN for
anticipated residue calculation.  The processing factors are shown in
Table 7.

Table 7.  Processing factors of Triallate and its TCPSA metabolite in/on
sugar beet processed commodities.

Sugar Beet Matrix	

Total Triallate + TCPSA Residues (ppm)	

Processing Factor



Roots	

0.11	

--



Dried Pulp	

0.30	

2.7x



Sugar	

<0.02	

<0.18x



Molasses	

<0.02	

<0.18x



Sugar beet tops, molasses, and dried sugar beet pulp may be fed to
livestock.  However, since triallate will be regionally registered,
exposure of triallate residues to livestock is minimal when compared to
the already registerd uses (wheat, barley, peas).

GLN 860.1480:  Meat, Milk, Poultry, Eggs tc \l2 "GLN 860.1480:  Meat,
Milk, Poultry, Eggs 

Acceptable ruminant and poultry feeding studies have been submitted and
evaluated in conjunction with previous triallate petitions (PP#8F2128,
PP#1F2460, and PP#6F3346; CB Nos. 840-845; 8/18/86, M. Firestone).  The
salient features of these feeding studies are presented below.  A
discussion regarding the need for animal commodity tolerances follows.

Milk, fat, meat, and meat byproducts of ruminants:  Triallate, a
preemergent selective herbicide, is not registered for direct animal
treatments on cattle, goats, hogs, horses, or sheep.  However, triallate
residues of concern may occur indirectly in milk and edible tissues of
livestock as a result of ingestion of feed items such as:  barley grain
and straw; pea vines and hay; and wheat grain and straw.  Using the
reassessed tolerances for these livestock feed items, the maximum
theoretical dietary burdens of triallate to beef and dairy cattle are
tentatively calculated to be 0.354 and 0.625 ppm, respectively (see
table below).  The dietary burden calculations are tentative because
field trial data remain outstanding for a few potential feed items
(i.e., barley hay and wheat hay); in addition, the data requirements for
limited/extensive field rotational crops studies remain outstanding.

	Table 8.  Calculation of maximum ruminant dietary burden for triallate.

Feed Commodity	

Reassessed Tolerance (ppm)	

% Dry Matter	

Beef Cattle	

Dairy Cattle



	

% of Diet	

Burden (ppm)	

% of Diet	

Burden (ppm)



Pea, hay	

1.0	

88	

25	

0.284	

50	

0.568



Barley, grain	

0.05	

88	

50	

0.028	

40	

0.023



Barley, straw	

0.3	

89	

10	

0.034	

10	

0.034



Wheat, grain	

0.05	

89	

15	

0.008	

--	

--



TOTAL	

100	

0.354	

100	

0.625



In a dairy cow feeding study, cows were fed capsules containing a
mixture of triallate:TCPSA (1:1) at dose levels of 1, 3, and 10 ppm (16x
for dairy cattle and 28x for beef cattle) each component (i.e., total
dose of 2, 6, and 20 ppm, respectively).  Sixteen cows were divided into
three treatment groups plus a control group.  After 28 days of dosing,
three of the four cows from each group were sacrificed, and tissue
samples were collected; the remaining animals were sacrificed after
administration of the final dose.  Milk and tissue samples were analyzed
for residues of triallate and its TCPSA metabolite using an adequate
GC/ECD method with a detection limit of 0.01 ppm.  Only when residue
levels were above the analytical method’s LOD were samples from the
next highest dose analyzed.  The results of the dairy cow feeding study
are presented in Table 9.



	Table 9.  Residues of triallate and its TCPSA metabolite in milk and
tissues of dairy cows fed capsules containing

	a mixture of triallate:TCPSA (1:1) at dose levels of  3 and 10 ppm each
component (MRID 00152876).

Sample	

Dose Level (ppm)	

Maximum Residue Level (ppm)





Triallate	

TCPSA	

Combined



Milk (Day 1 - 28)	

10	

<0.01	

<0.01	

<0.02



Muscle	

10	

<0.01	

<0.01	

<0.02



Liver	

10	

<0.01	

<0.01	

<0.02



Kidney	

3	

<0.01	

0.10	

<0.11



Kidney	

10	

<0.01	

0.05	

<0.06



Fat	

3	

0.01	

0.05	

0.06



Fat	

10	

0.03	

0.15	

0.18



The dairy cow feeding study shows that it is not possible to establish
with certainty whether finite residues of triallate will be incurred in
milk, muscle, and liver, but there is no reasonable expectation of
finite residues (category 3 of 40 CFR §180.6(a)) in these three
matrices.  Therefore, tolerances are not required for milk, muscle, and
liver.

Eggs, fat, meat, and meat byproducts of poultry.  There are no
registered direct animal treatments for triallate on poultry.  The only
poultry feed items with triallate uses include barley grain and wheat
grain.  The maximum theoretical dietary burden of triallate to poultry
is tentatively calculated to be 0.05 ppm (see Table 10).

	Table 10. Calculation of maximum theoretical dietary burden of
triallate to poultry.

Feed item	

Reassessed Tolerance, ppm	

% in Diet	

Dietary burden, ppm



Barley, grain	

0.05	

75	

0.0375



Wheat, grain	

0.05	

25	

0.0125



Total	

100	

0.050



In a poultry feeding study, eighty laying hens were divided into three
treatment groups plus a control group.  The treated hens were dosed with
gelatin capsules at levels corresponding to a diet containing a 1:1
mixture of triallate:TCPSA at 1, 3, and 10 ppm (200x dietary burden)
each component (i.e., total dose of 2, 6, and 20 ppm, respectively). 
After 28 days of dosing, 10 hens from each group were sacrificed, and
tissue samples were collected; the remaining hens were sacrificed after
a 28-day withdrawal period.  Eggs were collected throughout the study
administration of the final dose. Eggs and poultry tissue samples were
analyzed for residues of triallate and its TCPSA metabolite using an
adequate GC/ECD method with a detection limit of 0.01 ppm.  Only when
residue levels were above the analytical method’s LOD were samples
from the next highest dose analyzed.  The results of the poultry feeding
study are presented in Table 11.

	Table 11.  Residues of triallate and its TCPSA metabolite in eggs and
tissues of poultry fed capsules containing

	a mixture of triallate:TCPSA (1:1) at dose levels of 1, 3, and 10 ppm
each component (MRID 00150272)

Sample	

Dose Level (ppm)	

Maximum Residue Level (ppm)





Triallate	

TCPSA	

Combined



Eggs	

10	

0.01	

0.03	

0.04



Eggs	

3	

<0.01	

<0.01	

<0.02



Muscle	

10	

<0.01	

<0.01	

<0.02



Liver	

10	

<0.01	

<0.01	

<0.02



Kidney	

10	

<0.01	

<0.01	

<0.02



Fat	

10	

0.04	

<0.01	

<0.05



Fat	

3	

0.01	

<0.01	

<0.02



Fat	

1	

<0.01	

<0.01	

<0.02



The poultry feeding data show that it is not possible to establish with
certainty whether finite residues of triallate will be incurred, but
there is no reasonable expectation of finite residues (category 3 of 40
CFR §180.6(a)).  Therefore, tolerances are not required for eggs and
poultry tissues.

GLN 860.1400:  Water, Fish, and Irrigated Crops tc \l2 "GLN 860.1400: 
Water, Fish, and Irrigated Crops 

Triallate is presently not registered for direct use on water and
aquatic food and feed crops; therefore, no residue chemistry data are
required under these guideline topics.  EFED will provide levels for
residues of triallate and TCPSA in drinking water.

GLN 860.1460:  Food Handling tc \l2 "GLN 860.1460:  Food Handling 

Triallate is presently not registered for use in food-handling
establishments; therefore, no residue chemistry data are required under
this guideline topic.

GLN 860.1850 and 860.1900:  Confined/Field Accumulation in Rotational
Crops tc \l2 "GLN 860.1850 and 860.1900:  Confined/Field Accumulation in
Rotational Crops 

An acceptable confined rotational crop study has been submitted to
satisfy reregistration requirements under OPPTS GLN 860.1850.  The
confined rotational crop study indicates that the metabolism of
triallate in rotational crops is similar to that in primary crops (pea
and wheat).  Radioactive residues (expressed in terms of [14C]triallate
equivalents) accumulated at levels above 0.01 ppm in/on all commodities
of lettuce, radish, and wheat that were planted in sandy loam soil
30/76, 120, and 365 days after treatment (DAT) of the soil with
[14C]triallate at 1.95 lb ai/A (1.3x the maximum seasonal rate
registered for annual crops).  In general, residue accumulation declined
from shorter to longer rotation intervals.  Radioactive residues
remained detectable in all rotated plant matrices at the 365-DAT
rotation interval.

The study adequately characterized/identified the majority of
radioactive residues.  Triallate and its TCPSA metabolite were the only
identified residues in any of the crop matrices.  A major amount of
radioactivity (5-25% TRR) was also characterized as a polar unknown. 
Several approaches (such as acetylation, derivatization, acid/base
hydrolysis, and molecular weight size exclusion) were used in the
attempt to further identify the polar unknown residues.  Based on these
results, the registrant concluded that the polar unknown is
polysaccharide in character.

Because triallate and TCPSA were detected in rotational crop
commodities, the registrant has been requested to conduct limited field
rotational crop studies.  The limited field trials are to be conducted
on representative crops of the root and tuber vegetables, leafy
vegetables, and small grains at two sites per crop for a total of six
trials.  The six trials are to be conducted on crops which the
registrant intends to have as rotational crops on the product labels. 
Samples are to be analyzed for residues of triallate and TCPSA.  If
these limited field trials indicate that quantifiable triallate residues
of concern will occur, then extensive field rotational crop trials and
rotational crop tolerances will be required.  The need for rotational
crop restrictions will be determined following submission and evaluation
of the required field rotational crop studies.

Table B.	Residue Chemistry Science Assessments for Reregistration of
Triallate.

GLN:  Data Requirements	

Current Tolerances, ppm [40 CFR]	

Must Additional Data Be Submitted?	

References 



860.1200:  Directions for Use	

N/A = Not Applicable

	

No	





860.1300:  Plant Metabolism	

N/A	

No	

00148160 , 401080012, 41174401 , 41706903 2, 41706904, 41844401 ,
42962101 4, 43460701,  92187031, 92187032





860.1300:  Animal Metabolism	

N/A	

No	

40189501, 40189502 6, 41174401 , 43038201 5, 43038301 5, 92187033,
92187034





860.1340:  Residue Analytical Methods	

	





 -	Plant commodities	

N/A	

No 	

41110201 7, 44328801 , 44328802 9, 92187036





 -	Animal commodities	

N/A	

No	

41110201 7, 92187035, 92187037, 92187038





860.1360:  Multiresidue Methods	

N/A	

No	

41110101 7, 42848801 





860.1380:  Storage Stability Data	

	

	





 -	Plant commodities	

N/A	

No	

41110301 7, 42839401 ,

92187043





 -	Animal commodities	

N/A	

No	

00164197 , 92187044





860.1500:  Crop Field Trials

	





Legume Vegetables (Succulent or Dried) Group	

	





 -	Lentil	

0.05 (N) [§180.314]	

No 	

40117703, 40117704





 -	Pea (succulent and dried)	

0.05 (N) [§180.314]	

No	

40117704 , 92187049





Foliage of Legume Vegetables  Group	

	





 -	Lentil forage and hay	

0.05 (N) [§180.314]	

No 	

40117703, 40117704





 -	Pea vines and hay	

0.05 (N) [§180.314]

	

No	

40117704 14, 92187049





Sugar Beets	

	





Sugar Beet Root	

n/a	

No	

412797018, 412797007



Sugar Beet Top	

n/a	

No	

412797007, 412797018



Sugar Beet Pulp	

n/a	

No	

412799017



Cereal Grains Group	

	





 -	Barley grain	

0.05 (N) [§180.314]	

No	

40117702 14, 92187048





 -	Wheat (including triticale) grain and aspirated grain fractions	

0.05 (N) [§180.314]	

No 	

40117701 14, 41338401 , 92187051





Forage, Fodder, and Straw of Cereal Grains Group	

	





 -	Barley hay and straw	

0.05 (N) [§180.314]	

Yes 	

40117702 14, 92187048





 -	Wheat (including triticale) forage, hay, and straw

	

0.05 (N) [§180.314]	

Yes 	

40117701 14 , 41338401 17, 92187051





Grass Forage, Fodder, and Hay Group	

	

	





 -	Grass, canary, forage and hay	

0.05 (N), seed and straw [§180.314]

	

No 	





860.1520:  Processed Food/Feed



 -	Barley	

None established	

Yes 	





 -	Wheat	

None established	

No	

40473801 





Sugar Beets	

None established	

No	





860.1480:  Meat, Milk, Poultry, Eggs



 -	Milk and the Fat, Meat, and Meat Byproducts of Cattle, Goats, Hogs,
Horses, and Sheep

	

None established

	

No	

00150503 , 00152876 23, 92187047





 -	Eggs and the Fat, Meat, and Meat Byproducts of Poultry

	

None established	

No	

00150272 23, 92187046



860.1400:  Water, Fish, and Irrigated

Crops

	

N/A	

N/A	





860.1460:  Food Handling	

N/A	

N/A	





860.1850:  Confined Rotational Crops	

N/A	

No	

42499701 



860.1900:  Field Rotational Crops	

None established	

Yes 	







TOLERANCE REASSESSMENT SUMMARY tc \l1 "TOLERANCE REASSESSMENT SUMMARY 

The established tolerances [40 CFR §180.314 (a)] for residues of
triallate in/on plant commodities are currently expressed in terms of
triallate per se.  No tolerances have been established for animal or
processed food/feed commodities.  The triallate tolerance expression
needs to be revised in order to reflect the HED’s Metabolism
Assessment Review Committee determination that triallate and its TCPSA
metabolite should be regulated and assessed for dietary exposure.

The Agency has updated the list of raw agricultural and processed
commodities and feedstuffs derived from crops (Table 1, OPPTS GLN
860.1000).  As a result of changes to Table 1, triallate tolerances for
certain commodities which have been removed from Table 1 need to be
revoked, and some commodity definitions must be corrected.  In addition,
tolerances for commodities which will not be supported for
reregistration need to be revoked.  A summary of triallate tolerance
reassessments is presented in Table C.

Tolerances Listed Under 40 CFR §180.314 (a) tc \l2 "Tolerances Listed
Under 40 CFR §180.314 (a) :

The tolerances listed under 40 CFR §180.314 (a) should be moved to
§180.314 (c)  to specify regional registration of triallate.  Uses of
the registered G and EC formulations of triallate, when applied
according to label directions, are permitted only in the states of CO,
ID, KS, MN, MT, NE, NV, ND, OR, SD, UT, WA, and WY.

Sufficient data have been submitted to reassess the established
tolerances for the following plant commodities, as defined:  barley,
grain; barley, straw; peas; peas, forage; peas, hay; wheat, grain; and
wheat, straw.  The available data from field trials reflecting the
maximum registered use patterns suggest that the combined residues of
triallate and its TCPSA metabolite will exceed the currently established
tolerance level of 0.05 ppm for most of the above commodities. 

The established tolerances for the following commodities, as defined,
should be revoked:  grass, canary, annual, seed; grass, canary, annual,
straw; lentils; and lentils, hay.  The use of triallate on canary grass
is not being supported for reregistration, and this site has been
removed from all of Monsanto’s end-use products containing triallate
as the active ingredient.  Lentils may be classified as peas in
accordance with 40 CFR §180.1(h), and adequate data are available for
peas.  Lentil forage and hay are no longer considered significant
livestock feed items and have been deleted from Table 1 (OPPTS GLN
860.1000).

New Tolerances Needed Under 40 CFR §180.314 (c) tc \l2 "New Tolerances
Needed Under 40 CFR §180.314 (c) :

As a result of changes in Table 1 (OPPTS GLN 860.1000), field residue
data and tolerances are  required for barley hay, wheat forage, and
wheat hay.  The requested data for wheat hay may be translated to barley
hay since the registered uses of triallate on barley and wheat are
identical.  Adequate data are available for wheat forage and these data
may be the basis for tolerance establishment.

The available wheat processing data indicate that the combined residues
of triallate and TCPSA did not concentrate in flour but concentrated in
bran (2.5x) and shorts (2.0x).  These fractions  were processed from
whole wheat grain bearing nondetectable residues of triallate (<0.01
ppm) and detectable residues of TCPSA (0.03 ppm) following treatment at
1.7x the maximum registered rate.  The HAFT (combined residues) of wheat
grain from trials reflecting 1x treatment is <0.02 ppm.  Based on this
HAFT and the observed concentration factors, the maximum expected
combined residues are <0.05 ppm for bran (2.5 x <0.02) and <0.04 ppm for
shorts (2.0 x <0.02 ppm).  These maximum expected residues are equal or
less than the reassessed tolerance of 0.05 ppm for wheat grain. 
Therefore, tolerances for the combined residues of triallate and TCPSA
in wheat bran and shorts need not be proposed.

The reregistration requirements for limited/extensive field rotational
crop studies have not been fulfilled.  Depending on the outcome of these
required studies, rotational crop tolerances may be required.

The expected dietary burdens of triallate to beef/dairy cattle and
poultry animals were recalculated following tolerance reassessment of
livestock feed items.  The available animal feeding studies suggest that
it is not possible to establish with certainty whether finite residues
of triallate will be incurred, but there is no reasonable expectation of
finite residues (Category 3 of 40 CFR §180.6).  Therefore, tolerances
are not required for milk, eggs, and animal tissues.

Pending Active Tolerance Petition tc \l2 "Pending Active Tolerance
Petition :

FAP#8F2128:  Monsanto has proposed the establishment of tolerances for
the combined residues of triallate and its TCPSA metabolite in/on sugar
beet roots at 0.1 ppm, sugar beet foliage at 0.5 ppm, and dried sugar
beet pulp at 0.2 ppm.  Pending adequate resolution of issues relating to
 drinking  water levels of comparison (DWLOCs), HED could  recommend for
 the establishment of the proposed tolerances  (DP Barcode D237774, S.
Chun, 1/12/98).  

	Table C.   Tolerance Reassessment Summary for Triallate.  All
tolerances should be established

	under 40 CFR §180.314 (c)

Commodity	

Established Tolerance 1

(ppm)	

Reassessed Tolerance 2

(ppm)	

Comments

[Correct Commodity Definition]



	Tolerance Listed Under 40 CFR §180.314 (c)



Barley, grain	

0.05 (N)	

0.05	

The available data, reflecting the maximum registered use pattern,
indicate that residues of triallate and its TCPSA metabolite were <0.01
ppm each in/on barley grain.



Barley, straw	

0.05 (N)	

0.3	

The available data, reflecting the maximum registered use patterns,
indicate that the maximum combined residues of triallate and its TCPSA
metabolite were 0.26 ppm in/on barley straw.



Grass, canary, annual, seed	

0.05	

Revoke	

Monsanto has indicated that it will not support the use of triallate on
canary grass, and this site has been removed from all of Monsanto’s
end-use products containing triallate as the active ingredient.



Grass, canary, annual, straw	

0.05





Lentils	

0.05 (N)	

Revoke	

Since a tolerance for peas is established, the tolerance for lentils
should be revoked.  According to 40 CFR §180.1(h), the established
tolerance for peas will apply to lentils.



Lentils, forage	

0.05 (N)	

Revoke	

Lentil forage and hay are no longer considered significant livestock
feed items and have been removed from Table 1 (OPPTS GLN 860.1000).



Lentils, hay	

0.05 (N)	

Revoke

	

Peas

[Pea, succulent]	

0.05 (N)	

0.2	

The available data, reflecting the maximum registered use pattern,
indicate that the maximum combined residues of triallate and its TCPSA
metabolite were 0.12 ppm in/on the seed and pods of succulent peas and
<0.02 ppm in/on the seed and pods of dried peas.



Peas

[Pea, dry]

	

0.05 (N)	

0.2	

The available data, reflecting the maximum registered use pattern,
indicate that the maximum combined residues of triallate and its TCPSA
metabolite were 0.12 ppm in/on the seed and pods of succulent peas and
<0.02 ppm in/on the seed and pods of dried peas.



Peas, forage

[Pea, field, vines]

	

0.05 (N)	

0.5	

The available data, reflecting the maximum registered use pattern,
indicate that the maximum combined residues of triallate and its TCPSA
metabolite were 0.39 ppm in/on the vines of succulent peas and 0.27 ppm
in/on the vines of dried peas.



Peas, hay

[Pea, field, hay]	

0.05 (N)	

1.0	

The available data, reflecting the maximum registered use pattern,
indicate that the maximum combined residues of triallate and its TCPSA
metabolite were 0.73 ppm in/on the straw of succulent peas and 0.36 ppm
in/on the straw of dried peas.



Wheat, grain	

0.05 (N)	

0.05	

The available data, reflecting the maximum registered use pattern,
indicate that the maximum combined residues of triallate and its TCPSA
metabolite were 0.04 ppm in/on wheat grain.



Wheat, straw	

0.05 (N)	

1.0	

The available data, reflecting the maximum registered use pattern,
indicate that the maximum combined residues of triallate and its TCPSA
metabolite were 0.94 ppm in/on wheat straw.



New Tolerances Needed Under 40 CFR §180.314 (c)



Barley, hay	

--	

TBD 3	

The requested data for wheat hay will be translated to barley hay.



Wheat, forage	

--	

0.5	

The available data, reflecting the maximum registered use pattern,
indicate that the maximum combined residues of triallate and its TCPSA
metabolite were 0.42 ppm in/on wheat forage.



Wheat, hay	

--	

TBD	





Proposed Tolerances Under 40 CFR§180.314 (c) 



Sugar Beet, root	

--	

0.1	

No additional data are needed.



Sugar Beet, top	

--	

0.5	

No additional data are needed.



Sugar Beet, pulp	

--	

0.2	

No additional data are needed.



1	The established tolerance is expressed in terms of triallate per se.

2	The reassessed tolerance is expressed in terms of the combined
residues of triallate and its TCPSA metabolite.

3	TBD = To be determined.  Reassessment of tolerance(s) cannot be made
at this time because additional data are required.

CODEX HARMONIZATION tc \l1 "CODEX HARMONIZATION 

There are no Codex MRLs for triallate; therefore, no questions of
compatibility with U.S. tolerances exists.

DIETARY EXPOSURE ASSESSMENT tc \l1 "DIETARY EXPOSURE ASSESSMENT 

Anticipated Residues

Table 12 contains the anticipated residues (ARs) which should be used
for acute and chronic dietary risk assessment for triallate for wheat,
barley, dry pea, and sugar beets.  Since wheat, barley, dry peas, and
sugar beets  are considered  blended commodities, the ARs for chronic
and acute analyses will be the same. For the purposes of this
assessment, residue field trial data were used for the chronic and acute
AR calculations. 

Wheat PDP monitoring data were available for wheat.  These data were not
used for the AR calculation for wheat because PDP does not analyze for 
the TCPSA metabolite.  All of the samples analyzed by PDP  reported 
non-detectable residues of parent triallate.  Field trial samples were 
analyzed for both triallate and the TCPSA metabolite and there were
measurable residues in these.

FDA monitoring data for peas are also available.  However, these data
were not used in the AR calculation for peas because very few samples
were analyzed, and analyses determined the parent compound only.  All of
the samples were non-detectable.  Available field trial data for peas
also analyzed the TCPSA metabolite with measurable residues.

For sugar beets, available field trial data analyzed parent triallate
and TCPSA residues, and it was used for chronic and acute anticipated
residues calculation.

For all the samples that were non-detectable, 1/2 LOD (0.005 ppm) was
used as the residue value.

	Table 12. Anticipated Residues for Triallate Acute and Chronic Dietary
Risk Assessment

Commodity	

Anticipated Residue

(ppm)	

% Crop Treated	

Concentration Factor





Estimated Maximum1	

Weighted Average2,3

	

wheat grain	

0.01	

8	

6	

--



wheat flour	

--	

8	

6	

0.5x



wheat bran	

--	

8	

6	

2.5x



wheat shorts	

--	

8	

6	

2.0x



wheat mill byps	

--	

8	

6	

2.0x



barley	

0.01	

13	

9	

--



barley flour	

--	

13	

9	

0.5x



barley bran	

--	

13	

9	

2.5x



dry pea	

0.01	

30	

13	

--



sugar beet tops	

0.11	

100	

100	





sugar beet root	

0.008	

100	

100	





sugar beet molasses	

--	

100	

100	

0.18x



sugar beet sugar	

--	

100	

100	

0.18x



sugar beet dried pulp	

--	

100	

100	

2.7x

1 Estimated maximum percent crop treated will be used for acute DEEM
runs.

2 Weighted average percent crop treated will be used for chronic DEEM
runs.

3 This percent of crop treated will also be used for the cancer dietary
risk assessment.

Succulent (green) peas are not considered a blended commodity. 
Therefore, acute and chronic ARs will be different.  For succulent
(green) peas an AR value of 0.09 ppm (average from field trials) should
be used for chronic dietary risk assessment with a percent of crop
treated of 4%.  For the acute dietary risk assessment, the residue data
file should be constructed using the following values for non-zeros:
0.11 ppm, 0.12 ppm, 0.07 ppm, 0.07 ppm. Note that the percent of crop
treated for acute dietary risk is 12%.

AGENCY MEMORANDA RELEVANT TO REREGISTRATION tc \l1 "AGENCY MEMORANDA
RELEVANT TO REREGISTRATION 

CB Nos.:	840-845

Subject:	PP#8F2128.  Triallate on Soybeans and Sugar Beets/

PP#1F2460.  Triallate on Oilseeds and Buckwheat/

PP#6F3346.  Triallate on Wheat and Barley Forage

(Note: This petition was not cited on the RD Data Review Record):
Evaluation of Amendments Dated July 22, September 23 and 30, 1985.

From:	M. Firestone

To:	R. Taylor and Tox Branch

Dated:	8/18/86

MRID(s):	00150503, 00150272, and 00152876

CB Nos.:	1834-1836

Subject:	PP#8F2128.  Triallate on Soybeans and Sugar Beets.

PP#1F2460.  Triallate on Oilseeds and Buckwheat.

PP#6F3346.  Triallate on Wheat and Barley Forage.

Evaluation of a Storage Stability Study in Animal Tissues of Triallate
and TCPSA Residues, Submission Dated 10/14/86.

From:	V. F. Boyd

To:	R. Taylor and Tox Branch

Dated:	7/14/87

MRID(s):	00164197

CB Nos.:	2406-2409

Subject:	PP#8F2128.  Triallate on Soybeans and Sugar Beets.

PP#1F2460.  Triallate on Oilseeds and Buckwheat.

PP#6F3346.  Triallate on Wheat and Barley Forage.

Evaluation of an Amendment on the Nature of the Residues in Peas and
Wheat - Submission Dated 2/17/87.

From:	V. F. Boyd

To:	R. Taylor and Tox Branch

Dated:	10/7/87

MRID(s):	40108001

CB Nos.:	2410-2413

Subject:	PP#’s 8F2128, 1F2460, and 6F3346.  EPA ID No. 524-307. 
Triallate on Soybeans, Sugar Beets, Oilseeds, Buckwheat, and Wheat and
Barley Forage.  Amendment of 4/20/87 Concerning Goat and Poultry
Metabolism Studies.

From:	N. Dodd

To:	R. Taylor and Tox Branch

Dated:	10/13/87

MRID(s):	40189501 and 40189502

CB Nos.:	2400-2403

Subject:	PP#8F2128.  Triallate on Soybeans and Sugar Beets.

PP#1F2460.  Triallate on Oilseeds and Buckwheat.

PP#6F3346.  Triallate on Wheat and Barley Forage.

Evaluation of an Amendment on Residue Data in Soybeans, Wheat, Barley,
Peas, Corn, and Beans.  Submission Dated 2/25/87.

From:	V. F. Boyd

To:	R. Taylor and Tox Branch

Dated:	11/20/87

MRID(s):	40117701-40117706

CB Nos.	4846-4849, 4858-4860

Subject:	PP#8F2128.  (Triallate on Soybeans and Sugar Beets).

PP#1F2460.  (Triallate on Oilseeds and Buckwheat).

PP#6F3346.  (Triallate on Wheat and Barley).

Amendments of 12/29 and 31/87, and 4/12/88; Evaluation of Residue Data
on Sugar Beets, Sunflowers, and Processed Wheat Fractions.

From:	H. Fonouni

To:	R. Taylor

Dated:	8/11/89

MRID(s):	40692201-40692206 [Note: An 10/20/98  PDMS search of these
citations indicate that these citations pertain to propiconazole].

CB No.	5794

Subject:	PP#8F2128.  Triallate on Soybeans and Sugar Beets.

PP#1F2460.  Triallate on Oilseeds and Buckwheat.

PP#6F3346.  Triallate on Wheat and Barley.

Triallate DCI.  Evaluation of Information Concerning Plant and Animal
Metabolism, Analytical Methodology, and Crop Storage Stability.

From:	S. Willett

To:	R. Taylor, V. Walters, and Tox Branch

Dated:	2/14/90

MRID(s):	41110201, 41110301, and 41110101

CB Nos.	6298-6302

Subject:	PP#6F3346.  Triallate on Wheat and Barley Forage.

PP#9F3794.  Triallate on Peas, Wheat, Barley, Lentils, and Canary Grass.

Request for Amended Registrations and Response to DEB Deficiencies.

From:	S. Willett

To:	R. Taylor, V. Walters, and Tox Branch

Dated:	8/21/90

MRID(s):	41338401

CB No.	8304

Subject:	PP Nos. 8F2128, 1F2460, 6F3346, and 9F3794.  Triallate on
Several Commodities. Evaluation of Petition Method Validation Report
Dated 5/7/91.

From:	S. Willett

To:	R. Taylor, V. Walters, and D. Marlow

Dated:	9/16/91

MRID(s):	None

DP Barcode(s):	D168458

CB. No.	8578

Subject:	Triallate.  Monsanto Response to June 1991 DCI.

From:	F. Fort

To:	L. Deluise

Dated:	1/28/92

MRID(s):	None

DP Barcode(s):	D182956

CB No.:	10636

Subject:	Triallate.  List B Reregistration Case No. 2695/Chemical ID No.
078802.  10/27/92 Meeting to Discuss the Acceptability of Monsanto’s
Triallate Wheat Metabolism Studies.

From:	C. Swartz

To:	K. Davis and L. Deluise

Dated:	11/19/92

MRID(s):	00148160 and 41706903

DP Barcode(s):	None

Subject:	Triallate.  List B Reregistration Case No. 2695/Chemical ID No.
078802.  Issues to be Presented at the 11/30/92 Meeting of the HED
Metabolism Committee.

From:	C. Swartz

To:	Members of the HED Metabolism Committee

Dated:	11/23/92

MRID(s):	None

DP Barcode(s):	None

Subject:	Triallate.  List B Reregistration Case No. 2695/Chemical ID No.
078802.  Outcome of the 11/30/92 Meeting of the HED Metabolism
Committee.

From:	C. Swartz

To:	HED Metabolism Committee

Dated:	1/7/93 (hard copy) or 12/2/92 (electronic copy)

MRID(s):	None

DP Barcode:	D193379

CB No.:	12226

Subject:	Multi-residue Testing of Trichloropropene Sulfonic Acid
(TCPSA), the Major Metabolite of Triallate.  List B Case No. 2695.

From:	L. Edwards

To:	K. Davis

Dated:	8/11/93

MRID(s):	42848801

DP Barcode:	D193217

CB No.:	12249

Subject:	Triallate.  Storage Stability Study in Wheat (Bran, Flour, and
Shorts)

From:	D. Miller

To:	K. Davis

Dated:	9/16/93

MRID(s):	42839401

DP Barcode:	D215467, D215469, and D215471

CB Nos.:	15608-15610

Subject:	PP#8F2128.  Triallate in/on Sugar Beets in MN and ND. 
Amendment of 5/16/95.

From:	G. Kramer

To:	R. Taylor, V. Walters, and K. Whitby

Dated:	10/19/95

MRID(s):	41844401 and 42962101

DP Barcode:	D227041

CB No.	17288

Subject:	PP#8F2128.  Triallate in/on Sugar Beets.  Amendment of 5/6/96
(Revised Section F) and Anticipated Residue Calculations.

From:	G. Kramer

To:	D. McCall

Dated:	7/9/96

MRID(s):	None

DP Barcode:	D241071

Subject:	PP#8F2128.  Triallate in/on Sugar Beets.  Request for Petition
Method Validation: Sugar Beet RACs.  Chemical 078802.  Case 166931.

From:	S. Chun

To:	D. Marlow

Dated:	12/2/97

MRID:	44328801 and 44328802

DP Barcode:	D237774

Subject:	PP#8F2128.  Triallate in/on Sugar Beets.  Amendment of 7/17/97.
 Chemical 078802.  Case 166931.

From:	S. Chun

To:	P. Errico

Dated:	1/12/98

MRID:	44328801

DP Barcode(s):	D210750 and D197656

Subject:	Triallate.  Case 2695.  PC Code 078802.  Metabolism in the Pea,
Goat, and Hen.

From:	L. Cheng

To:	K. Whitby

Dated:	2/3/98

MRID(s):	43460701, 43038201, and 43038301

DP Barcode(s):	D201772

Subject:	Triallate.  Case 2695.  PC Code 078802.  Confined Rotational
Crop Study

From:	L. Cheng

To:	D. Davis

Dated:	3/18/98

MRID(s):	42499701

DP Barcode(s):	D245802

Subject:	Triallate.  PC Code 078802.  Metabolism in Plants, Livestock,
and Rotational Crops.  To be Presented to HED Metabolism Assessment
Review Committee

From:	L. Cheng

To:	Metabolism Assessment Review Committee

Dated:	5/6/98

MRID(s):	None

DP Barcode(s):	None

Subject:	Triallate.  PC Code 078802.  Outcome of the Metabolism
Assessment Review Committee Meeting Held on May 14, 1998.

From:	L. Cheng

To:	Metabolism Assessment Review Committee

Dated:	6/22/98

MRID(s):	None

DP Barcode:	D249039

Subject:	PP#8F2128.  Triallate in/on Sugarbeet Roots and Sugarbeet
Foliage.  Results of Petition Method Validation (PMV).  Chemical 078802.


From:	J. Rowell

To:	J. Tompkins

Dated:	1/14/99

MRID:	44328801 and 44328802

DP Barcode:	D255640

Subject:	Revised Anticipated Residues for Acute and Chronic Dietary Risk
Assessment for Triallate.  Chemical No.  078802. 

From:	J.  Morales

To:	M.  Goodis

Dated:	6/09/99

MRID:	None

MASTER RECORD IDENTIFICATION NUMBERS tc \l1 "MASTER RECORD
IDENTIFICATION NUMBERS 

References Used To Support Reregistration

00148160 Moran, S.; Grabiak, M. (1982) The Uptake and Metabolic Fate of
Triallate (S-(2,3,3-Trichlorallyl)diisopropylthiocarbamate) in Wheat
Straw and Wheat Grain: Report No. MSL-2401: Job/Project  No. 7812. 
Unpublished study prepared by Monsanto Agricultural Products Co.  55 p. 

00150272 Allan, J.; Lauer, R.; Horner, L.; et al. (1985) Residue
Determination of Triallate and the Sodium Salt of
2,3,3-Trichloroprop-2-ene-Sulfonic Acid in Eggs and Chicken Tissues:
Report No. MSL-3665 and Project No. 7112.  Unpublished study prepared by
Monsanto Co.  212 p.  

00150563 Horner, L.; Allan, J.; Lauer, R.; et al. (1985) Residue
Determination of Triallate and the Sodium Salt of
2,3,3-Trichloroprop-2-ene Sulfonic Acid in Swine Tissues: Report No.
MSL-3870: Job/- Project No. 7112.  Unpublished study prepared by
Monsanto Co.194 p. 

00152876 Lauer, R.; Allan, J.; Horner, L.; et al. (1985) Residue
Determination of Triallate and the Sodium Salt of 2, 3,
3-Trichloroprop-2-ene Sulfonic Acid in Milk and Beef Tissues: Special
Report: MSL-4867: Report No.: MSL-3611: Project No.: 7112: R.D. No.: 
629: Project No.: 30254.  Unpublished study prepared by Monsanto
Agricultural Products Co.  108 p. 

00164197 Allan, J.; Klein, A. (1986) Stability of Residues of Triallate
and  the Sodium Salt of 2,3,3-Trichloroprop-2-ene Sulphonic Acid in
Animal Tissue Samples during Frozen Storage: Report No. MSL-5494:
Job/Project No. 061200.  Unpublished study prepared by  Monsanto Co.,
Life Sciences Research Center.  58 p.  

40108001 Purdum, W. (1987) Nature of the Residues in Pea and Wheat
Metabolism Studies with Triallate: Laboratory ID: FR170 and FR203.
Unpublished compilation prepared by Monsanto Co.  216 p.  

40117701 Allan, J.; Nord, P. (1986) Determination of Triallate and its
Major Metabolite in Wheat Grain, Forage and Straw: Laboratory Project 
No. MSL-5998.  Unpublished study prepared by Monsanto Agricultural Co. 
139 p. 

40117702 Allan, J.; Nord, P. (1987) Determination of Triallate and its
Major Metabolite in Barley Grain, Forage and Straw: Laboratory Project
No. MSL-6040.  Unpublished study prepared by Monsanto Agricultural Co. 
93 p. 

40117703 Allan, J.; Nord, P. (1987) Determination of Triallate and its
Major  Metabolite in Soybean Seeds, Forage and Hay: Laboratory Project 
No. MSL-6041.  Unpublished study prepared by Monsanto Agricultural Co. 
93 p.  

40117704 Nord, P.; Allan, J. (1987) Determination of Triallate and its
Major  Metabolite in Raw Agricultural Commodities of Peas: Laboratory
Project No. MSL-6042.  Unpublished study prepared by Monsanto
Agricultural Co.  129 p. 

40189501 Purdum, W. (1987) Nature of the Residues in the Triallate Goat
Metabolism Study: Supplemental Submission: R.D. No. 771.  Unpublished
study prepared by Monsanto Agricultural Co.  33 p. 

40189502 Purdom, W. (1987) Nature of the Residues in the Triallate
Poultry Metabolism Study: Supplemental Submission: R.D. No. 772. 
Unpublished study prepared by Monsanto Agricultural Co.  27 p. 

40473801 Allan, J. (1987) Determination of Triallate and Its Major
Metabolite in Wheat Grain Mill Fractions: Laboratory Project No.
MSL-7064.  Unpublished study prepared by Monsanto Agricultural Co. 139
p. 

41110101 Lau, P. (1989) Multiresidue Method Testing of Triallate:
Laboratory Project No. MSL-8994: R.D. No. 936.  Unpublished study
prepared  by Monsanto Agricultural Co.  39 p.  

41110201 Allan, J. (1989) Regulatory Enforcement Method for the
Determination of Triallate and Its Metabolite, the Sodium Salt of
2,3,3-Trichloroprop-2-ene Sulfonic Acid in Animal Products and Crops: 
Laboratory Project No. MSL-9008: R.D. No. 937.  Unpublished study
prepared by Monsanto Agricultural Co.  56 p. 

41110301 Allan, J. (1989) Stability of Residues of Triallate and the
Sodium  Salt of 2,3,3-Trichloroprop-2-ene Sulfonic Acid in Crop Samples 
During Frozen Storage: Proj. No. MSL-8823.  Unpublished study prepared
by Monsanto Agricultural Co.  173 p.  

41174401 Hackett, A. (1989) In vitro Metabolism of Triallate and TCPSA:
R.D. No. 946.  Unpublished study prepared by Monsanto Co.  80 p. 

41338401 Allan, J.; Schneider, D. (1989) Determination of Triallate and
Its  Major Metabolite in Winter Wheat following Post Emergent 
Application of Far-go 10G: Report No. MSL-8642; R.D. No. 970; Project
061200.  Unpublished study prepared by Monsanto Co.  308 p. 

41706903 Marco, G.; Sharp, D. (1990) Final Report on Metabolism of
Avadex BW -Part I: Avadex BW-(allyl-2-(carbon 14)): Phase 3 Reformat:
Report No. 170.  Unpublished study prepared by Monsanto, Co.  70 p.  

41706904 Sutherland, M.; Curtis, T. (1990) Final Report on Metabolism of
 Avadex BW-Part II: Avadex BW-(amine-2-(Carbon 14)): Phase 3 Reformat:
Report No. 203.  Unpublished study prepared by Monsanto, Co.  70 p.  

41844401 Howe, R. (1991) Additional Data for Triallate Sugar Beet
Metabolism Study Response on PP# 8F2128 Triallate on Sugar and Soybeans:
Lab Project Number: 1037.  Unpublished study prepared by  Monsanto
Agricultural Co.  18 p. 

42499701 Kimmel, E.; Montenegro, X.; Sprinkle, R. (1992) A Confined 
Rotational Crop Study with [carbon 14]-Triallate Using Radishes 
(Raphanus sativus), Lettuce (Lactuca sativa), and Wheat (Triticum
aestivum): Lab Project Number: 504 (E).  Unpublished  study prepared by
PTRL-West, Inc.  249 p. 

42839401 Allan, J. (1993) Stability of Residues of Triallate and Its 
Major Metabolite in Wheat Processed Commodities During Frozen Storage:
Lab Project Number: MSL-12789: 40765-1: 1179.  Unpublished study
prepared by Monsanto Co. and Analytical Bio-Chemistry Labs, Inc.  107 p.


42848801 Lyford, S. (1993) FDA Multiresidue Method Testing of 
Trichloropropene Sulfonic Acid (TCPSA), the Major Metabolite of 
Triallate: Final Report: Lab Project red by Monsanto Triallate: Final
Report: Lab Project Number: 6103-166:  MSL-12877: R.D. 1180. 
Unpublished study prepared by Hazleton  Wisconsin, Inc.  51 p. 

42962101 Howe, R. (1993) Additional Data for Triallate Sugar Beet
Metabolism Study (Monsanto MSL-3405): Lab Project Number: 1200: 
MSL-3405.  Unpublished study prepared by Howe Xenobiotic  Technologies
and Monsanto Co.  35 p.  

43038201 Klemm, G.; Hackett, A.; Horton, S.; et al. (1993) Metabolism of
 Triallate in the Lactating Goat: Lab Project Number: MSL/13104:  1214. 
Unpublished study prepared by Monsanto Agricultural  Group.  227 p.  

43038301 Hackett, A.; Horton, S.; Bellora, L.; et al. (1993) Metabolism
of Triallate in the Laying Hen: Final Report: Lab Project Number:
MSL/13039: 1211.  Unpublished study prepared by Monsanto Agricultural
Group.  242 p.  

43460701 Horton, S.; Klemm, G.; Solsten, R.; et al.  (1994) The 
Metabolism of Triallate in Peas: (Final Report): Lab Project  Numbers:
93-12-M17: MSL-13675: 1281.  Unpublished  study prepared by Monsanto
Co.; PTRL West, Inc.; and Plant Sciences, Inc.  264 p. 

44328801 Allen, J. (1996) Regulatory Enforcement Method for the 
Determination of Triallate and Its Metabolite, the Sodium Salt of
2,3,3-Trichloroprop-2-ene Sulfonic Acid in Crops: (Final Report): Lab
Project Number: MSL-14690: ACFS-43204: 1383. Unpublished study prepared
by Monsanto Co. and ABC Labs, Inc.161 p.  

44328802 Davis, K. (1997) Method Validation of the Regulatory 
Enforcement Method for Triallate and TCPSA in Crops Using Sugar Beet
Pulp, Wheat Straw, Peas, and Pea Forage: Final  Report: Lab Project
Number: 43467: ACFS-43467: 96-12-R-3. Unpublished study prepared by ABC
Labs, Inc.  92 p.  

92187031 Deyrup, C. (1990) Monsanto Company Phase 3 Summary of MRID
00146706.  Additional Information Submitted in Support of Far-Go
Herbicide - The Uptake and Metabolic Fate of Triallate in Sunflowers,
Sugar Beets and Peas: Special Report #MSL-4102; RD #556.  Prepared by
Monsanto Agricultural Products Co. 9 p. 

92187032 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
00148160.  The Uptake and Metabolic Fate of Triallate in Wheat  Grain:
Special Report #MSL-4564; MSL-2401 (CDL 257207). Prepared by Monsanto
Agricultural Products Co. 8 p.  

92187033 McLeod. W. (1990) Monsanto Company Phase 3 Summary of MRID
00153007.  Metabolism of Carbon-14-Triallate and
Carbon-14-2,3,3-Trichloroprop-2-enesulfonic Acid, Sodium Salt in Dairy
Goats: Special Report # MSL-4651 (CDL 257644).  Prepared by Monsanto
Agricultural Products Co. 8 p.  

92187034 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
00144508.  Metabolism of Carbon-14-Triallate and
Carbon-14-2,3,3-Trichloroprop-2-enesulfonic Acid, Sodium Salt in Laying
Hens: Special Report #MSL-4636; Project No. 30108 (CDL 257644). 
Prepared by Monsanto Agricultural Products Co. 8 p.  

92187035 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
00152876.  Residue Determination in Milk and Beef Tissues:  Special
Report #MSL-4867 (CDL 258936).  Prepared by Monsanto  Agricultural
Products Co. 13 p.  

92187036 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
41110201.  Regulatory Enforcement Method for the Determination of
Triallate and its Metabolite the Sodium Salt of
2,3,3-Trichloroprop-2-ene Sulfonic Acid in Animal Products and Crops:
Laboratory Project No. #MSL-9008.  Prepared by Monsanto Agricultural
Products Co. 21 p. 

92187037 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
00150272.  Residue in Eggs and Chicken Tissue: Special Report # 
MSL-4983 (CDL 259557).  Prepared by Monsanto Agricultural Products Co.
14 p.  

92187038 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
00150563.  Residue Determination in Swine Tissue: Special Report
#MSL-5029 (CDL259620).  Prepared by Monsanto Agricultural Products Co.
13 p.  

92187043 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
41110301.  Stability of Residue of Triallate and the Sodium Salt of
2,3,3-Trichloroprop-2-ene Sulfonic Acid in Crop Samples During Frozen
Storage: Laboratory Project No. # MSL-8823. Prepared by Monsanto
Agricultural Products, Inc. 9 p. 

92187044 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
00164197.  Stability of Residues of Triallate and the Sodium  Salt of
2,3,3-Trichloroprop-2-ene-Sulfonic Acid in Animal  Tissue Samples During
Frozen Storage: Laboratory Project No. MSL-5494 .  Prepared by Monsanto
Agricultural Products Co. 16 p.  

92187046 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
00150272.  Residue Determination in Eggs and Chicken Tissue:  Special
Report # MSL-4983 (CDL 259557).  Prepared by Monsanto Agricultural
Products Co. 10 p. 

92187047 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
00152876.  Residue Determination in Milk and Beef Tissues:  Special
Report MSL-4867 (CDL 258936).  Prepared by Monsanto Agricultural
Products Co. 10 p.  

92187048 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
40117702.  Submission of Residue Data in Barley Raw Agricultural
Commodities: Laboratory Project: # MSL-6040 R.D.#743.  Prepared  by
Monsanto Agricultural Products Co. 20 p. 

92187049 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
40117704.  Submission of Residue Data in Peas: Raw Agricultural 
Commodities: Lab Project: MSL-6042; R.D. 745.  Prepared by  Monsanto
Agricultural Products Co. 32 p. 

92187051 McLeod, W. (1990) Monsanto Company Phase 3 Summary of MRID
40117704.  Submission of Residue Data in Wheat Raw Agricultural 
Commodities: Laboratory Project# MSL-5998, R.D # 742.  Prepared  by
Monsanto Agricultural Products Co. 45 p. 

 PAGE  8 

 PAGE  2 

 PAGE  4 

 PAGE  11 

 PAGE  26 

 ADVANCE \d12 Table B (continued). ADVANCE \u12 

 PAGE  27 

.	Bolded references were reviewed in the Triallate Phase 4 Review (S.
Funk, 1/22/91).  All other references were reviewed as noted.

.	This study submission was originally reviewed in (i) PP#8F2128,
PP#1F2460, and PP#6F3346; CB Nos. 2406-2409; 10/7/87.  Additional
reconsideration/review of data were made in the following memos: (ii) DP
Barcode D168458, CB No. 8578, 1/28/92, F. Fort; and (iii) DP Barcode
D182956, CB No. 10636, 11/19/92, C. Swartz.

.	PP#6F3346, 2/14/90, S. Willett.

.	PP#8F2128; DP Barcodes D215467, D215469, and D215471; CB Nos.
15608-15610; 10/19/95; G. Kramer.

.	DP Barcodes D197656 and D210750, 2/3/98, L. Cheng.

.	PP#8F2128, PP#1F2460, and PP#6F3346; CB Nos. 2410-2413; 10/13/87; N.
Dodd.

.	PP#8F2128, PP#1F2460, and PP#6F3346; CB No. 5794; 2/14/90; S. Willett.

.	DP Barcode D241071, 12/2/97, S. Chun.

DP Barcode D237774, 1/12/98, S. Chun.

.	DP Barcode D193379, CB No. 12226, 8/11/93, L. Edwards. [This
submission, which pertains to multiresidue method testing of TCPSA, was
forwarded to FDA for review.]

.	DP Barcode D193217, CB No. 12249, 9/16/93, D. Miller.

.	This study submission was originally reviewed in: (i) PP#8F2128,
PP#1F2460, and PP#6F3346; CB Nos. 1834-1836; 7/14/87; V.F. Boyd. 
Additional reconsideration/review of data were made in the following
memos:  (ii) PP#8F2128, PP#1F2460, and PP#6F3346; CB Nos. 4846-4849,
4858-4860; 8/11/90; H. Fonouni; and (iii) DP Barcode D168458, 1/28/92,
F. Fort.

.	According to 40 CFR §180.1(h), lentils may be classified as peas. 
The available dried pea field trial data may be translated to lentils
since the registered use patterns of peas and lentils are identical.

14.	PP#8F2128, PP#1F2460, and PP#6F3346; CB Nos. 2400-2403; 11/20/87, V.
Boyd.

.	Lentil forage and hay have been deleted from Table 1 (OPPTS GLN
860.1000) as significant livestock feed items.  Therefore, the
established triallate tolerances for lentil forage and hay should be
revoked.

.	No additional data are required for wheat grain.  Aspirated grain
fractions have now been included in Table 1 (OPPTS GLN 860.1000) as a
significant livestock feed item.  Residue data on wheat aspirated grain
fractions are not required because the registered use of triallate on
wheat involves preemergence application (before the reproductive stage
of the crop begins), and triallate residues of concern in wheat grain
were mostly below the LOD of the analytical method.

.	PP#6F3346 and PP#9F3794; CB Nos. 6298-6302; 8/21/90; S. Willett.

.	No additional data are required for barley straw.  Barley hay has now
been included in Table 1 (OPPTS GLN 860.1000) as a significant livestock
feed item.  The requested wheat hay data may be translated to barley hay
since the registered uses of triallate on barley and wheat are
identical.  The registrant will be required to propose a tolerance for
barley hay when acceptable wheat hay data have been received and
evaluated.

.	No additional data are required for wheat straw.  Although a tolerance
has not been established for wheat forage, adequate data are available
for this wheat RAC.  Wheat hay has now been included in Table 1 (OPPTS
GLN 860.1000) as a significant livestock feed item.  Therefore the
following are required:  Data depicting residues of triallate and its
TCPSA metabolite in/on the hay of spring and winter wheat harvested
following a single preemergence soil application of representative G and
EC formulations at 1.5 lb ai/A.  Separate (or side-by-side) field trials
should be conducted for each registered formulation.  The trials must be
conducted in the states of CO, ID, KS, MN, MT, NE, NV, ND, OR, SD, UT,
WA, and WY where regional registration is currently permitted.  Wheat
hay samples should be analyzed within the storage intervals for which
residues have been demonstrated to be stable under frozen storage
conditions.  The registrant will be required to propose tolerances for
wheat hay when acceptable data have been submitted and evaluated.

.	The registrant has indicated that use of triallate on canary grass
will not be supported for reregistration, and has deleted this use site
from all labels.  Therefore, the established triallate tolerances for
the seed and straw of canary grass should be revoked.

.	A barley processing study utilizing exaggerated application rate (or a
rate equivalent to the maximum theoretical concentration factor) is
required.  If the exaggerated field trial should result in
non-quantifiable residues of triallate and its TCPSA metabolite in/on
the RAC (barley grain), then the harvested RAC samples need not be
processed, and tolerances for barley processed commodities will not be
required.  However, if the exaggerated rate should produce quantifiable
residues in/on the RAC, then the harvested RAC samples should be
processed into pearled barley, flour, and bran according to method(s)
simulating commercial practices.  Each processed fraction should be
analyzed for triallate residues of concern.

.	PP#8F2128, PP#1F2460, and PP#6F3346; CB Nos. 4846-4849, 4858-4860;
8/11/89; H. Fonouni.

.	PP#8F2128, PP#1F2460, and PP#6F3346; CB Nos. 840-845; 8/18/86; M.
Firestone.

.	DP Barcode D201772, 3/18/98, L. Cheng.

.	The registrant had been requested to conduct limited field rotational
crop studies.  The limited field trials are to be conducted on
representative crops of the root and tuber vegetables, leafy vegetables,
and small grains at two sites per crop for a total of six trials.  The
six trials are to be conducted on crops which the registrant intends to
have as rotational crops on the product labels.  Samples are to be
analyzed for residues of triallate and TCPSA.  If these limited field
trials indicate that quantifiable triallate residues of concern will
occur, then extensive field rotational crop trials and rotational crop
tolerances will be required.  The need for rotational crop restrictions
will be determined following submission and evaluation of the required
field rotational crop studies.

