November 23, 2009

Note to file

From: 	Laura E. Nollen, Biologist

	Minor Use Team

	Registration Division (7505P)

	Office of Pesticide Programs

	U.S. Environmental Protection Agency 

The fenarimol residue chemistry database is complete except for required
storage stability data for livestock commodities. Storage stability data
for livestock commodities are required to support the storage intervals
used in livestock feeding studies. As such, EPA required a study that
demonstrates tissue stability for the same duration as the samples
stored in the fenarimol livestock feeding study. 

The EPA received preliminary results of the storage stability study.
This study submission is an 'interim' report, reflecting 12 months of
bovine tissue storage. It was stated that the final report was to
reflect 30 months of storage. The review of this interim study concluded
that bovine tissues are fairly stable for up to 12 months. 

Based on current fenarimol registrations, the only feedstuff for
livestock is wet apple pomace. Wet apple pomace is unlikely to
contribute to the dietary burden because it is not a significant
feedstuff. It is estimated that wet apple pomace contributes to <5% of
the beef cattle diet and up to 10% of the diet for dairy cattle;
however, it is unlikely to be fed to lactating dairy. In most cases wet
apple pomace will be fed to growing cows – not beef on finishing
feedlots; its use as feed to lactating dairy would be limited to avoid
contaminating marketable milk, and it is only available during apple
processing months – from October to March.

Additionally, the dietary assessment for fenarimol is refined with the
use of anticipated residues from the livestock feeding study and the use
of percent crop treated data (20%) for apples; thus, no more than 20% of
residues from apples is expected to enter into livestock feedstuff.
Given the above considerations, the Agency does not anticipate secondary
residues of fenarimol in meat and milk based on current registrations of
fenarimol and believes that the existing data are sufficient for
endpoint selection for exposure/risk assessment scenarios and for
evaluation of the requirements under the FQPA.

