UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

	OFFICE OF PREVENTION, PESTICIDE

	AND TOXIC SUBSTANCES

  SEQ CHAPTER \h \r 1 MEMORANDUM

Date:  July 28, 2008

SUBJECT:	Propiconazole.  Application for Amended Section 3 Registration
to Add Uses on Garden Beets, Turnips, Parsley, Cilantro, Pineapple, and
the Leaves of the Root and Tuber Vegetable Group (Crop Group 2). 
Summary of Analytical Chemistry and Residue Data.  

PC Code:  122101	DP Barcode:  D348248

Decision No.:  386896	Registration Nos.:  100-617 and 100-780

Petition No.:  7E7300	Regulatory Action:  Petition and Amended Section 3
Registration

Risk Assessment Type:  Residue Chemistry Summary Document	Case No.:  NA

TXR No.:  NA	CAS No.:  60207-90-1

MRID No.:  See MRID Summary Table	40 CFR:  180.434

		              									

FROM:	Yan Donovan, Chemist

          		Reregistration Branch 4

Health Effects Division (7509C)

THROUGH:	Susan V. Hummel, Branch Senior Scientist

          		Reregistration Branch 4

Health Effects Division (7509C)

TO:		Dan Rosenblatt/Shaja Joyner, PM#5

		RIMUERB

		Registration Division  SEQ CHAPTER \h \r 1 

		  SEQ CHAPTER \h \r 1   SEQ CHAPTER \h \r 1 	

MRID Summary Table

MRID No.	Study Type	Comments

47297201	860.1500 Garden beet	New DER; 47297201.der.doc

47297202	860.1500 Turnip	New DER; 47297202.der.doc

47297203	860.1500 Parsley	New DER; 47297203.de1.doc

	860.1520 Parsley	New DER; 47297203.de2.doc

47297204	860.1500 Pineapple	New DER; 47297204.de1.doc

	860.1520 Pineapple	New DER; 47297204.de2.doc



  SEQ CHAPTER \h \r 1 This document was originally prepared under
contract by Dynamac Corporation (2275 Research Boulevard, Suite 300;
Rockville, MD 20850).  

Dynamac Program Manager:		Date:  5/14/08

     	Danilo Martinez

	

The document has been reviewed by the Health Effects Division (HED) and
revised to reflect current Office of Pesticide Programs (OPP) policies.

 Executive Summary

Propiconazole is a triazole-type fungicide that provides broad spectrum
disease control on a variety of crops.  Tolerances are currently
established for the combined residues of propiconazole,
1-[[2-(2,4-dichlorophenyl)-4-propyl-1,3-dioxolan-2-yl]methyl]-1H-1,2,4-t
riazole, and its metabolites determined as 2,4-dichlorobenzoic acid
(2,4-DCBA) and expressed as parent compound in 40 CFR §180.434. 
Tolerances have been established for plant commodities in 40 CFR
§180.434(a), at levels ranging from 0.1 ppm for several commodities,
including pineapple, to 40 ppm for grass straw.  Tolerances for residues
in livestock commodities are also established under 40 CFR §180.434(a),
and range from 0.05 ppm for meat and meat byproducts to 2.0 ppm for
liver and kidney of cattle, goat, horse, and sheep.  Time-limited
tolerances are established in 40 CFR §180.434(b) for nectarine and
peach (expiration date of 12/31/10); tolerances with regional
registration are established in 40 CFR §180.434(c) for cranberry and
wild rice; and tolerances for indirect or inadvertent residues are
established in 40 CFR §180.434(d) for alfalfa forage and hay.  

The Interregional Research Project No. 4 (IR-4), on behalf of the
Agricultural Experiment Stations of CA, GA, HI, MS, NJ, OH, OK, OR, SC,
TN, and TX, is proposing to amend the use pattern for the 3.6 lb/gal
emulsifiable concentrate (EC) formulation of propiconazole (Tilt®
Fungicide, EPA Reg. No. 100-617) to add uses on garden beets, turnips,
parsley, cilantro (coriander), and the leaves of the root and tuber
vegetable group (crop group 2).  IR-4 is also proposing to amend the use
pattern for the 3.6 lb/gal EC formulation to add seed piece and
postharvest dip treatments for pineapple.  A copy of the supplemental
label proposing the use of 45% WP formulation (Tilt® 45W; EPA Reg. No.
100-780) on pineapple as postapplication dipping treatment was also
provided.   In conjunction with the requested amended uses, IR-4 has
submitted a petition, PP#7E7300, for the establishment of tolerances for
the combined residues of the fungicide propiconazole
1-[[2-(2,4-dichlorophenyl)-4-propyl-1,3-dioxolan-2-yl]methyl]-1H-1,2,4-t
riazole and its metabolites determined as 2,4-dichlorobenzoic acid and
expressed as parent compound, in or on the following commodities:

Vegetables, leaves of root and tuber, group 2	8.0 ppm

Beet, garden, roots	0.6 ppm

Turnip, roots	0.2 ppm

Parsley, fresh	13 ppm

Parsley, dried	60 ppm

Cilantro leaves	13 ppm

Pineapple	0.9 ppm

The Codex Alimentarius Commission has established several maximum
residue limits (MRLs) for propiconazole in/on various raw agricultural
commodities.  In addition, both Canada and Mexico have established MRLs
for propiconazole in/on various commodities.  The Codex and Mexican MRLs
are expressed in terms of propiconazole per se.  The Canadian MRLs are
expressed in terms of combined residues of propiconazole and its
metabolites containing the 2,4-DCBA moiety.  No Codex, Mexican, or
Canadian MRLs have been established for any crop commodity associated
with this petition.  

The nature of propiconazole residues in plants and animals is adequately
understood based on the available peanut, wheat, grape, rice, celery,
carrot, goat, and poultry metabolism studies.  HED has concluded that
for plants and livestock, residues of propiconazole and all its
metabolites containing the 2,4-DCBA moiety, including conjugates, are of
concern and should be included in the dietary (food) risk assessments,
and that propiconazole per se should be included in the dietary (water)
risk assessments.  For tolerance expression, HED concluded that the
current tolerance expression for propiconazole should be amended to
include residues of propiconazole per se only.  This allows for
harmonization with the residue definition for Codex.

The free triazole metabolites, 1,2,4-triazole (1,2,4-T),
triazolylalanine (TA), and triazolylacetic acid (TAA) are also residues
of concern.  Since these are common metabolites from several triazole
pesticides, the risk assessment for triazoles will be assessed
separately.  HED also issued guidance on the residue chemistry data
requirements for the triazole-based metabolites under DP# 327788
(4/25/06, M. Doherty) which specified that any field trial or processing
studies conducted after September1, 2005 to support new uses must
analyze for the triazole metabolites.  Although none of the crop field
trial and processing studies submitted with this petition included
analysis for the triazole metabolites, these field studies are accepted
at this time because these studies were initiated and analyses were
completed before the issuance of HED’s policy regarding triazole
metabolites.  A revised triazole risk assessment will be conducted by
HED to reflect the propiconazole new uses base on available data from
propiconazole metabolism studies and other conazole- pesticide residue
data.

For enforcing the proposed tolerances, a gas chromatography (GC) method
using flame ionization detection (Method AG-354) is available for
determining residues of propiconazole per se in/on plant commodities,
with a limit of quantitation (LOQ) of 0.05 ppm.  In addition, FDA’s
PAM 1 Multiresidue Methods Section 302 may be used to determine parent
propiconazole in both plant and livestock matrices.

Samples from the field trials and processing studies submitted to
support the current petition were analyzed for combined residues of
propiconazole and its metabolites containing the 2,4-DCBA moiety using
GC methods with electron capture detection (ECD).   The methods are
similar common moiety methods in which all residues of concern are
converted by base hydrolysis and oxidation to 2,4-DCBA, then determined
as the 2,4-DCBA methyl ester, and reported in propiconazole equivalents.
 The lower level of method validation (LLMV) was 0.05 ppm for garden
beet roots and tops, fresh and dried parsley, and pineapple fruit and
processed commodities, and was 0.20 ppm for turnip roots and tops.  Each
of the methods was validated in conjunction with the field trial and
processing studies, and acceptable method validation and concurrent
method recoveries were obtained for all crop matrices, with the
exception of turnip commodities.

Provided that changes are made to the proposed use directions, the
submitted field trial data on garden beets and parsley are adequate and
support the proposed use patterns for the 3.6 lb/gal EC formulation of
propiconazole on these crops.  The number and geographic distribution of
the field trials are adequate, samples were analyzed using adequate
analytical methods, and the sample storage intervals are supported by
available or concurrent storage stability data.  The field trial data
for parsley may be translated to support the proposed use on cilantro. 
The proposed uses must be modified to specify PHIs of 14 days for garden
beets, parsley, and cilantro

The submitted postharvest trial data on pineapple are adequate and
support the proposed use directions of the 3.6 lb/gal EC formulation as
a postharvest dip treatment.  Samples were analyzed using adequate
analytical methods, and the sample storage intervals were supported by
concurrent storage stability data.  The proposed tolerance for pineapple
is too low; a tolerance of 4.5 ppm must be proposed.  HED determined
that the above residue data on EC formulation can not be translated to
WP formulation even though the application rate is the same.  Field
trials on WP formulation are needed if the registrant wants to add the
use of WP formulation on pineapples.

The submitted turnip field trial data are not adequate because the
method used for sample analyses was not adequate.  Readily quantifiable
residues were observed in reagent blanks and untreated turnip top
samples, and concurrent method recoveries were generally low.  A new set
of turnip crop field trial data must be submitted.  Since turnip is one
of the representative crops for the Crop Group 2- the leaves of the root
and tuber vegetable group, the proposed use on this crop group 2 needs
to be removed.  The petitioner must propose separate tolerances for
garden beet tops.  

The Agency’s Guidance for Setting Pesticide Tolerances Based on Field
Trial Data was utilized for determining appropriate tolerance levels for
garden beet roots, garden beet tops, parsley leaves, and pineapple.  The
available data indicate that the proposed tolerance for parsley leaves
is adequate but the proposed tolerance for pineapple is too low.  A
tolerance of 4.5 ppm would be appropriate for pineapple.  The available
data for parsley may be translated to support use on cilantro; the
proposed tolerance, at the same level as the tolerance for parsley
leaves, is appropriate.  Based on the garden beet field trial data at
1.5x the proposed rate, tolerance spreadsheet predicted a 0.45 ppm for
garden beet roots and 8.0 ppm for garden beet tops.  Adjusting to 1.0x
the application rate, HED is recommending a 0.30 ppm tolerance on garden
beet roots and a 5.5 ppm on garden beet tops.  

Adequate processing data are available for parsley and pineapple.  These
data indicate that propiconazole residues concentrate in dried parsley
leaves (5.5x) and pineapple process residue (1.7x) but do not
concentrate in pineapple juice.  The appropriate tolerance levels for
these commodities were calculated using the HAFTs and the processing
factors.  The proposed tolerance for dried parsley leaves is too high; a
tolerance of 35 ppm would be appropriate.  A tolerance of 7.0 ppm must
be proposed for pineapple process residue.  

Adequate livestock feeding study data have been submitted previously for
propiconazole.  No changes in the existing tolerances for livestock
commodities are needed to support the proposed uses of propiconazole.

Adequate confined and field rotational crop studies are available
indicating that the residues in rotational crops are similar to those in
primary crops.  The studies also support the PBIs listed on product
labels of 75 days for alfalfa and 105 days for all other crops without
direct uses.  No changes to the existing rotational crop restrictions
are needed to support the proposed uses.

  SEQ CHAPTER \h \r 1 Regulatory Recommendations and Residue Chemistry
Deficiencies

Pending the submission of a revised Section B (see requirements under
Directions for Use) and a revised Section F (see requirements under
Proposed Tolerances), and the favorable outcome of HED’s aggregate
risk assessment, there are no residue chemistry issues that would
preclude granting registration for the requested uses of the 3.6 lb/gal
EC formulation on garden beets, parsley, and cilantro, as a postharvest
dip for pineapple (EC formulation only), and as a seed treatment for
pineapple.  HED recommends the establishment of the following tolerances
for residues of propiconazole per se on:

Beet, garden, roots	0.45 ppm

Beet, garden, tops	8.0 ppm

Parsley, leaves	13 ppm

Parsley, dried leaves	35 ppm

Cilantro, leaves	13 ppm

Pineapple, process residue	7.0 ppm

And to increase the existing tolerance for residues in/on pineapple to:

Pineapple	4.5 ppm

Data Gaps

 

860.1200 Directions for Use

The proposed use on turnip must be removed from Section B until adequate
field trial data have been submitted.

The proposed use on the leaves of root and tuber vegetables, crop group
2 must be removed from Section B.  

The proposed use of 45% WP formulation of propiconazole on pineapple
must be removed from the supplemental label.

The proposed uses on garden beets, parsley, and cilantro must be revised
to specify PHIs of 14 days instead of 7 day, because the submitted crop
field trial data for garden beet and parsley reflected PHIs of 14 days. 


860.1550 Proposed Tolerances

The petitioner must submit a revised Section F reflecting the
recommended tolerances and commodity definitions presented above and in
Table 7.  The proposed tolerances for “Vegetables, leaves of root and
tuber, group 2” and “Turnip, roots” must be removed from Section
F.

860.1500 Crop Field Trials

To support the proposed use on turnips, the petitioner must submit a
full set of crop field trial data in which turnips are treated at 1x the
proposed maximum seasonal rate, harvested at the proposed PHI, and
analyzed using adequate methods for residues of propiconazole per se and
the triazole metabolites, 1,2,4-T, TA, and TAA.  

Background

Propiconazole is a triazole-type fungicide that provides broad spectrum
disease control through inhibition of sterol biosynthesis in fungi.  It
is registered to Syngenta Crop Protection for the control of fungal
diseases on a variety of crops.   IR-4 has proposed use of the 3.6
lb/gal EC formulation of propiconazole on garden beet, turnip, parsley,
cilantro, and pineapple, and use of the 45% WP formulation of
propiconazole on pineapple.  The chemical structure and nomenclature of
propiconazole and the physicochemical properties of the technical grade
of propiconazole are presented in Tables 1 and 2.  

Table 1.	Nomenclature of Propiconazole.

Compound	

Common name	Propiconazole

Company experimental names	CGA-64250

IUPAC name
1-((2-(2,4-dichlorophenyl)-4-propyl-1,3-dioxolan-2-yl)methyl)-1H-1,2,4-t
riazole

CAS name
1-((2-(2,4-dichlorophenyl)-4-propyl-1,3-dioxolan-2-yl)methyl)-1H-1,2,4-t
riazole

CAS #	60207-90-1

End-use products/EP	3.6 lb/gal EC formulation (Tilt® Fungicide; EPA
Reg. No. 100-617);

45% WP formulation (Tilt® 45W; EPA Reg. No. 100-780)



Table 2.	Physicochemical Properties of Technical Grade Propiconazole.

Parameter	Value	Reference

Boiling point	>250 ºC at 101.325 kPa;

120 ºC at 1.9 Pa 	HED Chapter of the Propiconazole RED (DP# 324652,
2/1/06, Y. Donovan).

pH	4.9 at 25 ºC (1% aqueous dispersion)

	Density	1.289 g/cm3 (typical) at 20 ºC

	Water solubility	0.10 g/L at 20 ºC

	Solvent solubility (temperature not specified)	Completely miscible in
ethanol, acetone, toluene and n-octanol;

Hexane = 47 g/L

	Vapor pressure	4.2 x 10-7  mm Hg at 25 ºC

	Dissociation constant (pKa)	1.09

	Octanol/water partition coefficient Log(KOW)	3.72 at pH 6.6 and 25 ºC

	UV/visible absorption spectrum	Not available

	

860.1200 Directions for Use

IR-4 included a copy of an existing label for the 3.6 lb/gal EC
formulation (EPA Reg. No. 100-617), and provided a text description of
the proposed use patterns for garden beets, turnip, leaves of the root
and tuber vegetable group, parsley, cilantro, and pineapple.  In
addition, a copy of a proposed supplemental label for the 3.6 lb/gal EC
formulation was provided, which included use directions for garden
beets, turnip, leaves of the root and tuber vegetable group, parsley,
cilantro, and pineapple, and a copy of a proposed supplemental label for
the 45% WP formulation (Tilt® 45W; EPA Reg. No. 100-780) was provided,
which included use directions for pineapple.  The proposed use
directions are summarized in Table 3.

Table 3.	Summary of Proposed Directions for Use of Propiconazole.

Applic. Timing, Type, and Equip.	Formulation

[EPA Reg. No.]	Applic. Rate 

(lb ai/A)	Max. No. Applic. per Season	Max. Seasonal Applic. Rate

(lb ai/A)	PHI

(days)	Use Directions and Limitations

Garden Beet and Turnip

Postemergence

Broadcast foliar

Ground or aerial 	3.6 lb/gal EC

[100-617]	0.084-0.113	Not specified (NS)	0.45	7	A minimum retreatment
interval (RTI) of 14 days is proposed.

Leaves of Root and Tuber Vegetables, including leaves of: garden beet,
edible burdock, carrot, bitter and sweet cassava, celeriac,
turnip-rooted chervil, chicory, dasheen (taro), parsnip, radish,
oriental radish, rutabaga, black salsify, sweet potato, tanier, turnip
and true yam

Postemergence

Broadcast foliar

Ground or aerial 	3.6 lb/gal EC

[100-617]	0.084-0.113	NS	0.45	7	A minimum RTI of 14 days is proposed.

Parsley, Fresh and Dried, and Cilantro (Coriander)

Postemergence

Broadcast foliar

Ground or aerial 	3.6 lb/gal EC

[100-617]	0.084-0.113	NS	0.45	7	A minimum RTI of 14 days is proposed.

Pineapple

Seed-piece treatment	3.6 lb/gal EC

[100-617]1	0.084-0.113 lb/100 gal water	1	0.113 lb/100 gal water	NS
Seed-pieces are to be immersed for 30 seconds, and then allowed to dry
or planted immediately

Postharvest treatment	3.6 lb/gal EC

[100-617]

45% WP

[100-780]2	0.084-0.113 lb/100 gal water	1	0.113 lb/100 gal water	NS
Fruit are to be immersed for 30 seconds; the dipping solution may be
mixed with postharvest waxes.  

1  This proposed use was included in Section B of the petition but was
not included on the proposed supplemental labels included in the
submission.

2  This proposed use was included on the supplemental label but not
included in Section B.

The proposed uses do not include any information about spray volumes for
foliar applications and do not include any rotational crop restrictions.
 The parent label for the 3.6 lb/gal EC formulation specifies that
ground applications to crops other than tree crops be made in a minimum
of 10 gal/A, and aerial applications to crops other than tree crops be
made in a minimum of 2 gal/A.  In addition, the following rotational
crop restrictions are specified on the parent label:  other crops
intended for food, grazing, or any component of animal feed may not be
planted within 105 days of application to the preceding crop, unless the
second crop appears on this label; and alfalfa may be planted 75 days
after the last application if the application of propiconazole has not
exceeded 0.22 lb ai/A during the previous year.

Conclusions.  The proposed use directions are not adequate.  Several
revisions to the proposed use directions are required as specified
below: 

The turnip field trial data have been determined to be inadequate due to
problems with the analytical method.  Therefore, the proposed use on
turnip must be removed from Section B until adequate field trial data
have been submitted.

Since turnip is one of the representative crops for Crop Group2 - leaves
of root and tuber vegetables, as a result of the unacceptable turnip
data, the proposed use on this group must be removed from Section B.  

The residue data from EC formulation on pineapple post harvest treatment
can not be translated to the WP formulation (ChemSAC minutes of
07/23/08).  Field trial data are needed for the WP formulation (Tilt®
45W; EPA Reg. No. 100-780) if the registrant is to pursuit the WP use.  
The proposed use from the supplemental label of the 45% WP formulation
on pineapple must be removed.

The submitted crop field trial data for garden beet and parsley
reflected PHIs of 14 days.  Therefore, the proposed uses on garden
beets, parsley, and cilantro must be revised to specify PHIs of 14 days.

860.1300 Nature of the Residue - Plants

Propiconazole RED, DP# 329394, 6/15/06, Y. Donovan

Residue Chemistry Memo DP#s 238458 etc, 7/31/06, Y. Donovan

The nature of propiconazole residues in plants is adequately understood
based on metabolism studies with peanut, wheat, grape, rice, celery, and
carrot.  Together these data indicate that the major metabolic pathway
in plants appears to involve hydroxylation of the n-propyl group on the
dioxolane ring of the cis/trans isomers of propiconazole, with
subsequent conjugation to sugars.  A possible alternative pathway
involves reductive deketalization of the dioxolane ring and sugar
conjugation of the resulting metabolite.  The alkyl bridge between the
phenyl and triazole rings is metabolized, and free 1,2,4-T is released. 
The free triazole is readily conjugated with the amino acid,
serine/alanine, forming TA which is further metabolized to TAA, possibly
through the intermediate formation of triazole lactic acid.  The free
triazole (1,2,4-T), TA, and TAA are also residues of concern.  Since
these are common metabolites from several triazole-containing
pesticides, the risk assessment for triazoles will be conducted
separately to reflect the new proposed uses of propiconazole.

Based on these studies, HED concluded that the residues of concern for
dietary risk assessment should include propiconazole and all of its
metabolites containing the 2,4-DCBA moiety, including conjugates, as
virtually all of the residue data have been generated using a common
moiety method that converts parent and all of the metabolites of concern
to 2,4-DCBA.  However, HED has recommended that the tolerance expression
be amended to include only propiconazole, per se, because:  (i) there
are a number of pesticides that have 2,4-DCBA as common metabolite, and
an enforcement agency may not be able to determine if residues are due
to misuse of propiconazole or the proper use of other pesticides
containing 2,4-DCBA; (ii) propiconazole per se can be detected by FDA
multiresidue methods; and (iii) inclusion of only parent allows
harmonization with the residue definition for the Codex MRLs.  

860.1300 Nature of the Residue - Livestock

Propiconazole RED, DP# 329394, 6/15/06, Y. Donovan

The nature of propiconazole residues in livestock is adequately
understood based on the acceptable goat and poultry metabolism studies. 
The Agency concluded that parent and all metabolites convertible to
2,4-DCBA are the residues of concern for risk assessment, as the
analytical method is a common moiety method that detects all residues
convertible to 2,4-DCBA.  However, for tolerance enforcement purposes,
the current tolerance expression should be amended to include only
propiconazole per se for the same reasons as described above for plants.
 

860.1340 Residue Analytical Methods

Propiconazole RED, DP# 329394, 6/15/06, Y. Donovan

Plant commodities

Samples from the field trial and processing studies submitted with the
current petition were analyzed for combined residues of propiconazole
and its 2,4-DCBA-containing metabolites using GC/ECD methods based on
Methods AG-454B and/or AG-626, which are more recent versions of the
original tolerance enforcement method (AG-454).  The methods are common
moiety methods in which residues were converted by base hydrolysis and
oxidation to 2,4-DCBA, which was then methylated for determination as
the 2,4-DCBA methyl ester; residues were reported in propiconazole
equivalents.  The LLMV was 0.05 ppm for garden beet roots and tops,
fresh and dried parsley, and pineapple fruit and processed commodities,
and 0.20 ppm for turnip roots and tops.  Each of the methods was
validated in conjunction with the field trial and processing studies,
and acceptable method validation and concurrent method recoveries were
obtained for all crop matrices, with the exception of turnip
commodities.

For the turnip field trials, the method validation and concurrent method
recovery data, along with the data for untreated samples and reagent
blanks, indicate that the method was not adequate for data collection
purposes.  Readily quantifiable residues were observed in reagent blanks
and untreated turnip top samples, and concurrent method recoveries were
generally low (49-88%, with only three values greater than 70%).

No samples were analyzed for the triazole and its metabolites, 1,2,4-T,
TA, and TAA.  

For enforcement purposes, residue Method AG-354 is available for
determining propiconazole per se in/on plant commodities using GC and
flame ionization detection; the reported LOQ is 0.05 ppm.  In addition,
Multiresidue Methods Section 302 can also be used to detect parent
propiconazole.

Conclusions.  With the exception of the turnip crop field trial data,
the methods used for the determination of combined residues of
propiconazole and its 2,4-DCBA-containing metabolites were adequate. 
The turnip crop field trial data may not be used to support the proposed
use due to problems with the method.

IR-4 stated that the crop field trial and processing study data were
submitted without accompanying data for parent propiconazole as
determined by LC/MS/MS and without triazole metabolite data as
determined by LC/MS/MS.  The crop field trial and processing studies
were initiated and the laboratory work was completed long before the
issue regarding triazole metabolites came to the forefront, and
therefore these methods of analysis were not considered and used.  

Livestock commodities

GC/ECD Methods AG-517 and AG-629 (a modification of method AG-517) are
available for determining residues of propiconazole and its
2,4-DCBA-containing metabolites in livestock commodities.  These methods
use a single moiety detection in which residues are converted to
2,4-DCBA, determined as the 2,4-DCBA methyl ester, and reported as
propiconazole equivalents.  The method LOQ is 0.05 ppm for residues in
meat, poultry, and eggs and 0.02 ppm for residues in milk.  For
enforcement purposes, the Multiresidue Methods Section 302 will detect
residues of parent propiconazole.

860.1360 Multiresidue Methods

The FDA PESTDATA database (dated 06/05) indicates that propiconazole is
completely recovered (>80%) using PAM 1 Multiresidue Methods Section
302.  The recovery of propiconazole metabolites CGA-91305, CGA-118244,
and 1,2,4-T is variable using PAM 1 Section 302.  Propiconazole and
metabolites CGA-91305, CGA-118244, and 1,2,4-T are not recovered using
PAM 1 Multiresidue Methods Sections 303 and 304.

860.1380 Storage Stability

Propiconazole RED, DP# 329394, 6/15/06, Y. Donovan

 ≤-15 ºC for up to 36 months in/on peaches, bananas, corn meal, wheat
grain, celery, corn oil, and peanut nutmeat, hay, and hulls; 10 months
in/on carrots; 4 months in/on soybean seed; and 6 months in/on soybean
fodder.  Weathered residues of propiconazole and its metabolites were
also found to be stable in/on grass forage, straw, and seed stored at
-20 ºC for up to 39 months; in/on wild rice and stone fruits stored
frozen for up to 25 months; in/on peanut hulls and fodder stored at -15
ºC for 25 months; and in the extracts of silage-stage corn forage and
soybeans for 3 and 8 months, respectively, at 4 ºC.  

Additionally, concurrent storage stability studies were conducted with
the garden beet and pineapple residue studies submitted with this
petition (MRIDs 47297201 and 47297204, respectively).  Untreated samples
of garden beet roots and tops were fortified with propiconazole at 1.0
ppm and stored frozen for 1134 and 1137 days; the average corrected
recoveries after frozen storage were 90% for tops and 115% for roots. 
Untreated samples of pineapple fruit, juice, and process residue were
fortified with propiconazole at 2.0 ppm and stored frozen for 760, 734,
and 741 days, respectively; the average corrected recoveries after
storage were 89%, 84%, and 90% for fruit, juice, and process residue,
respectively.  No zero-day data were provided for either study.  

The storage durations and conditions of samples from the crop field
trials submitted to support this petition are presented in Table 4.  

Table 4.	Summary of Storage Conditions and Durations of Samples from
Crop Field Trial Studies.  

Matrix 	Storage Temperature

 (°C)	Actual Storage Duration	Interval of Demonstrated Storage
Stability

Beet, garden, roots	<-18	769-916 days	1134 days for garden beet roots
(concurrent study)

Beet, garden, tops

804-964 days	1137 days for garden beet tops (concurrent study)

Parsley, fresh	-20	624-847 days (21-28 months)	36 months for fortified
residues in/on celery, and 39 months for weathered residues in/on grass
forage and straw

Parsley, dried

628-847 days (21-28 months)

	Pineapple, fruit	-20	543-720 days	760 days for pineapple fruit
(concurrent study)

Pineapple, edible fresh pulp

661-727 days	734 days for pineapple juice (concurrent study)

Pineapple, juice

701 days

	Pineapple, process residue

710 days	741 days for pineapple process residue (concurrent study)

Pineapple, peel

710 days

	Turnip, roots	<-18	930-1225 days	1134 days for garden beet roots

Turnip, tops

852-1105 days	1137 days for garden beet tops



Conclusions.  The storage conditions and durations of samples from the
garden beet, parsley, and pineapple field trials, as well as the parsley
and pineapple processing studies, are supported by adequate storage
stability data.  No additional storage stability data are required.  The
available data indicate that no corrections for decline during storage
are needed.

IR-4 is reminded that storage stability studies should always include a
zero-day sampling interval to establish the residue levels present at
the time samples are placed into storage [see OPPTS 860.1380(d)(6)(i)]. 


860.1400 Water, Fish, and Irrigated Crops

There are no proposed uses that are relevant to this guideline topic.

860.1460 Food Handling

There are no proposed uses that are relevant to this guideline topic.

860.1480 Meat, Milk, Poultry, and Eggs

Residue Chemistry Memo DP#s 238458 etc, 7/31/06, Y. Donovan

The livestock feedstuffs associated with the subject petition are
pineapple process residue, turnip roots and tops.  These commodities are
fed to cattle but not to poultry and swine.  The theoretical dietary
burdens of propiconazole to livestock were most recently calculated
under DP#s 238458 etc.; dietary burdens of 29.0 and 18.5 ppm were
calculated for beef and dairy cattle respectively, based on diets
consisting of grass hay, field corn grain and stover, rice bran,
aspirated grain fractions, and soybean meal.  Because pineapple process
residue is in the same feed category as grass hay – “Roughage”,
adding the pineapple process residues will not increase the dietary
burden since grass hay has a much higher tolerance (40 ppm) than the
proposed pineapple process residue tolerance (7.0 ppm).   HED is not
recommending tolerance on turnips; therefore, the conclusions of the
previous review pertaining to tolerances for livestock commodities are
not changed.  

860.1500 Crop Field Trials

DER Reference:	47297201.der.doc (Garden beets)

		47297202.der.doc (Turnips)

		47297203.de1.doc (Parsley)

		47297204.de1.doc (Pineapple)

Table 5.	Summary of Residue Data from Crop Field Trials with
Propiconazole.

Crop matrix	Total Applic. Rate

 (lb ai/A)	PHI (days)	Residue Levels (ppm)



	n	Min.	Max.	HAFT1	Median	Mean	Std. Dev.

Garden beets (proposed use = 0.45 lb ai/A total application rate, 7-day
PHI)

Garden beet, tops	0.664-0.686	14-16	10	0.44	4.3	4.3	3.6	3.1	1.5

Garden beet, roots

14-16	10	<0.05	0.27	0.19	0.10	0.12	0.07

Parsley (proposed use = 0.45 lb ai/A total application rate, 7-day PHI)

Parsley	0.432-0.455	13-15	8	1.2	6.5	6.3	3.4	3.7	1.9

Pineapple (proposed use  = one postharvest dip application at 0.113 lb
ai/100 gal water)

Pineapple fruit	0.126 lb ai/100 gal	NA	6	0.88	4.1	3.6	1.8	2.1	1.2

	0.126 lb ai/100 gal plus fruit wax

6	0.34	0.50	0.48	0.41	0.41	0.06

	0.126 lb ai/100 gal plus fruit oil

6	0.37	0.82	0.69	0.54	0.56	0.15

1  HAFT = Highest average field trial result.

2  Residue data corrected for concurrent method recovery.

3  NA = Not applicable.

None of the field trial samples in this petition were analyzed for
triazole and its metabolites, 1,2,4-T, TA, and TAA. All of the field
trials were conducted prior to 2005, when the requirement to analyze for
1,2,4-T, TA, and TAA was established. 

Garden beets

IR-4 submitted field trial data for propiconazole on garden beets.  Five
field trials were conducted in the U.S. in Zones 1 (NY), 5 (MI and WI),
6 (TX), and 12 (OR) during the 1997-1998 growing season.  A 3.6 lb/gal
EC formulation of propiconazole was applied to garden beets as four
broadcast foliar applications at 0.162-0.174 lb ai/A/application (~1.5x
the proposed maximum single application rate), for a total rate of
0.664-0.686 lb ai/A (~1.5x the proposed maximum seasonal rate). 
Applications were made at retreatment intervals of 10-15 days.  All
applications were made using ground equipment, in spray volumes of 19-34
gal/A; no adjuvants were included in the spray mixtures. 

Samples of garden beet roots and tops were harvested from each test site
14-16 days after the last application.  A residue decline study was not
conducted.  

Samples were analyzed for combined residues of propiconazole and its
metabolites containing the 2,4-DCBA moiety by the University of Idaho
Analytical Sciences Laboratory (Moscow, ID) using an adequate GC/ECD
method.  The LLMV was 0.05 ppm for each commodity.  Samples were not
analyzed for the triazole metabolites.   Sample storage conditions and
durations are reported in Table 4.  Adequate concurrent storage
stability data were submitted to support the study.

The results of the garden beet field trials are presented in Table 5. 
Following four foliar applications of propiconazole to garden beets
totaling 0.664-0.686 lb ai/A, total propiconazole residues were
<0.05-0.27 ppm in/on roots and 0.44-4.3 ppm in/on tops harvested ~14
days following the last application.  

Conclusions.  The submitted residue data for garden beets are adequate
to satisfy data requirements.  The number and location of garden beet
field trials was in accordance with OPPTS Guideline 860.1500.  The
application rates in the trials reflect 1.5x the proposed use pattern,
and the PHIs of the field trials, 14-16 days, are longer than the
proposed PHI of 7 days.  Although no residue decline study was
conducted, a residue decline study with sugar beets has been submitted
previously which indicates that total propiconazole residues do not
increase in roots or tops with increasing sampling intervals (DP#s
238458 etc, 7/31/06, Y. Donovan).

Provided the petitioner amends the proposed use pattern to reflect a PHI
of 14 days for garden beets, HED concludes that registration for use of
the 3.6 lb/gal EC formulation on garden beets would be appropriate.  The
residue data will support a tolerance for the combined residues of
propiconazole and its metabolites determined as 2,4-DCBA in/on garden
beet roots at 0.45 ppm and garden beet tops at 8.0 ppm; the tolerance
calculations for garden beet roots and tops are presented in Appendix I.
 

Turnips

IR-4 submitted field trial data for propiconazole on turnips.  Six
trials were conducted in the U.S. in Zones 2 (GA, NJ, and TN), 5 (OH), 6
(TX), and 10 (CA) during the 1997-1998 growing season.  A 3.6 lb/gal EC
formulation of propiconazole was applied to turnips as four broadcast
foliar applications at 0.141-0.177 lb ai/A/application (~1.5 the
proposed maximum single application rate), for a total rate of
0.615-0.686 lb ai/A (~1.5x the proposed maximum seasonal rate).  At one
location (GA), a total of six applications were made at 0.170 lb ai/A,
for a total rate of 1.017 lb ai/A; the additional applications were made
to allow the crop to grow to maturity.  Applications were made at
retreatment intervals of 9-16 days.  All applications were made using
ground equipment, in spray volumes of 22-79 gal/A; no adjuvants were
included in the spray mixtures.  

Samples of turnip roots and tops were harvested from each test site
13-15 days after the last application.  A residue decline study was not
conducted.  

Samples were analyzed for combined residues of propiconazole and its
metabolites containing the 2,4-DCBA moiety by the USDA/ARS/SAA IR-4
Laboratory (Tifton, GA) using a GC/ECD method.  The LLMV was 0.20 ppm
for each commodity.  The method validation and concurrent method
recovery data, along with the data for untreated samples and reagent
blanks, indicate that the method was not adequate for data collection
purposes.  Readily quantifiable residues were observed in reagent blanks
and untreated turnip top samples, and concurrent method recoveries were
generally low (49-88%, with only three values greater than 70%).  As a
result, the residue data are not reported here, but can be found in the
individual DER.

Conclusions.  The submitted residue data for turnips are not adequate to
satisfy data requirements.  The validation data, along with residue data
for reagent blanks and untreated samples, indicate that the GC/ECD
method used for analysis was not adequate for data collection.  

To support the proposed use on turnips, the petitioner must submit a
full set of crop field trial data in which turnips are treated at 1x the
proposed maximum seasonal rate, harvested at the proposed PHI, and
analyzed using adequate methods for residues of propiconazole per se and
the triazole metabolites, 1,2,4-T, TA, and TAA.  

Parsley

IR-4 submitted field trial data for propiconazole on parsley.  Four
field trials were conducted in the U.S. in Zones 2 (NJ; 1 trial), 6 (TX;
2 trials), and 10 (CA; 1 trial) during the 1996 and 1997 growing
seasons.  A 3.6 lb/gal EC formulation of propiconazole was applied to
parsley as four broadcast foliar applications at 0.107-0.116 lb
ai/A/application, for a total rate of 0.432-0.455 lb ai/A (1x the
proposed maximum seasonal rate).  Applications were made at retreatment
intervals of 7-8 days.  All applications were made using ground
equipment, in spray volumes of 29-45 gal/A; no adjuvants were included
in the spray mixtures.  Samples of parsley were harvested from each test
site at 13-15 days following last application.  

Samples were analyzed for combined residues of propiconazole and its
metabolites containing the 2,4-DCBA moiety by Novartis Crop Protection
(Greensboro, NC) using an adequate GC/ECD method.  The LLMV was 0.05
ppm.  Samples were not analyzed for the triazole metabolites.   Sample
storage conditions and durations are reported in Table 4.  Adequate
storage stability data are available to support the study.

The results of the parsley field trials are presented in Table 5. 
Following four applications of propiconazole to parsley totaling
0.432-0.455 lb ai/A, total propiconazole residues were 1.2-6.5 ppm in/on
fresh parsley.

Conclusions.  The submitted residue data for parsley are adequate to
satisfy data requirements.  The number and location of parsley field
trials was in accordance with OPPTS Guideline 860.1500.  The application
rates in the trials reflect 1x the proposed use pattern; however, the
PHIs of the field trials, 13-15 days, are longer than the proposed PHI
of 7 days.  No residue decline study was conducted; however, no residue
decline study is required to support use on parsley.

Provided the petitioner amends the proposed use pattern to reflect a PHI
of 14 days for parsley, HED concludes that a conditional registration
for use of the 3.6 lb/gal EC formulation on parsley would be
appropriate.  

The residue data will support a tolerance for the combined residues of
propiconazole and its metabolites determined as 2,4-DCBA in/on parsley
leaves at 13 ppm; the tolerance calculation for parsley is presented in
Appendix I.  The available data for parsley may be translated to support
use of propiconazole on cilantro; therefore, the data will support a
tolerance for the combined residues of propiconazole and its metabolites
determined as 2,4-DCBA in/on coriander leaves at 13 ppm.  

Pineapple – seed piece treatment

No residue data were submitted to support the pineapple seed piece
treatment.  No data will be required because more than one year will
pass before pineapple will be harvested, and any potential residues
would be covered by the data on the pineapple post-harvest treatment.

Pineapple – post harvest

IR-4 submitted residue data for propiconazole on pineapple from three
field trials conducted in Hawaii (Zone 13) during 1997.  A 3.6 lb/gal EC
formulation of propiconazole was applied postharvest to mature harvested
pineapples as a dip at a rate of 0.126 lb ai/100 gal water (1.1x the
proposed maximum treatment rate).  Three different postharvest
treatments were examined:  one for which the treatment solution
contained only the 3.6 lb/gal EC formulation; one for which fruit wax
was added; and one for which fruit oil was added.  Following dip
treatment, pineapples were allowed to dry, and the crowns were removed. 
Samples were stored frozen up to 706 days prior to extraction for
analysis, an interval supported by concurrent storage stability data. 
The submission included processing data for pineapple; refer to the
860.1520 DER for MRID 47297204.

Samples were analyzed for combined residues of propiconazole and its
metabolites containing the 2,4-DCBA moiety by the IR-4 Satellite
Laboratory at the University of HI (Honolulu, HI) using an adequate
GC/ECD method.  The LLMV was 0.05 ppm.  The results of the pineapple
trials are presented in Table 5.  Following a postharvest application of
propiconazole at 0.126 lb ai/100 gal, residues in/on pineapple treated
with propiconazole without fruit wax or oil were 0.88-4.1 ppm; residues
were 0.34-0.50 ppm in/on pineapple treated with propiconazole and a
fruit wax, and were 0.37-0.82 in/on pineapples treated with
propiconazole and a fruit oil.

Conclusions.  The submitted residue data for pineapple are adequate to
support the proposed postharvest use pattern for the 3.6 lb/gal EC
formulation only.  The application rates in the trials reflect ~1x the
proposed use pattern.  These data can not be translated to 45% WP
formulation (ChemSAC minutes of 07/23/08).

The residue data will support an increase in the established tolerance
for the combined residues of propiconazole and its metabolites
determined as 2,4-DCBA in/on pineapple, from 0.1 ppm to 4.5 ppm; the
tolerance calculation for pineapple is presented in Appendix I.  The
tolerance calculation was based on residue data from all three dip
treatments.

860.1520 Processed Food and Feed

DER Reference:	47297203.de2.doc (Parsley)

		47297204.de2.doc (Pineapple)

Parsley

IR-4 has submitted a processing study for propiconazole on parsley. 
Three field trials were conducted in the U.S. in Zones 2 (NJ), 6 (TX),
and 10 (CA) during the 1996 growing season.  A 3.6 lb/gal EC formulation
of propiconazole was applied to parsley as four broadcast foliar
applications at 0.107-0.116 lb ai/A/application, for a total rate of
0.432-0.455 lb ai/A (1x the proposed maximum seasonal rate). 
Applications were made at retreatment intervals of 7-8 days.  Fresh
parsley was harvested 13-15 days after the last application and dried
according to local commercial practices.  

Samples were analyzed for combined residues of propiconazole and its
metabolites containing the 2,4-DCBA moiety by Novartis Crop Protection
(Greensboro, NC) using an adequate GC/ECD method.  The LLMV was 0.05 ppm
for each commodity.  Samples were not analyzed for the triazole
metabolites.   Sample storage conditions and durations are reported in
Table 4.  Adequate storage stability data are available to support the
study.

Following four applications of propiconazole to parsley totaling
0.432-0.455 lb ai/A, total propiconazole residues in/on fresh parsley
were 1.2-3.8 ppm, and residues in dried parsley were 7.5-21 ppm. 
Processing factors for parsley were 4.9-6.2x, with an average processing
factor of 5.5x (see Table 6).  

Pineapple

IR-4 has submitted a processing study for propiconazole on pineapple
receiving postharvest treatment.  A 3.6 lb/gal EC formulation of
propiconazole was applied as a postharvest application to mature
harvested pineapples at a rate of 0.126 lb ai/100 gal water (1.1x the
proposed maximum treatment rate), with added fruit wax.  Following dip
treatment, pineapples were allowed to dry and then processed into edible
fresh pulp, peel, beverage juice, and process residue.  

Samples were analyzed for combined residues of propiconazole and its
metabolites containing the 2,4-DCBA moiety by the IR-4 Satellite
Laboratory at the University of HI (Honolulu, HI) using an adequate
GC/ECD method.  The LLMV was 0.05 ppm for each commodity.  Although
samples were not analyzed for the triazole metabolites, analysis for
these metabolites is not required because there is an existing
preharvest use on this crop.  Sample storage conditions and durations
are reported in Table 4.  Adequate concurrent storage stability data
were submitted to support the study.

Following a postharvest application at 0.126 lb ai/100 gal water, total
propiconazole residues in/on pineapple fruit averaged 0.39 ppm.  The
processing data indicate that propiconazole residues do not concentrate
in edible fresh pulp (processing factor <0.13x), juice (processing
factor <0.13x), or peel (processing factor 0.9x), but do concentrate in
process residue (processing factor of 1.7x).  The observed processing
factors (see Table 6) are less than the theoretical concentration factor
of 3.8x for pineapple process residue (OPPTS 860.1520, Table 3).

  SEQ CHAPTER \h \r 1 Table 6.	Summary of Processing Factors for
Propiconazole.

RAC	Processed Commodity	Average Processing Factor

Parsley, fresh	Parsley, dried	5.5x

Pineapple	Edible fresh pulp	<0.13x

	Peel	0.90x

	Juice	<0.13x

	Process residue	1.7x



Conclusions.  The submitted parsley and pineapple processing study are
acceptable.  The processing data for pineapple indicate that
propiconazole residues do not concentrate in juice, but do concentrate
in process residue.  Based on the HAFT residues in pineapple (3.6 ppm)
and the processing factor (1.7x), expected residues in pineapple process
residue would be 6.1 ppm.  A tolerance of 7.0 ppm for combined residues
in pineapple process residue is needed.

The processing data for parsley indicate that propiconazole residues
concentrate in dried leaves.  Based on the HAFT residues in parsley (6.3
ppm) and the processing factor (5.5x), expected residues would be 35 ppm
in dried parsley.  A tolerance of 35 ppm is needed for dried parsley
leaves.

  SEQ CHAPTER \h \r 1 860.1650 Submittal of Analytical Reference
Standards

An analytical standard for propiconazole is currently available in the
EPA National Pesticide Standards Repository, with an expiration date of
2/5/11 (email correspondence with Dallas Wright, 3/23/08).

Analytical reference standards must be replenished as requested by the
EPA National Pesticide Standards Repository. 

860.1850 and 860.1900 Confined and Field Accumulation in Rotational
Crops

Propiconazole RED, DP# 329394, 6/15/06, Y. Donovan

Residue Chemistry Memo DP#s 238458 etc, 7/31/06, Y. Donovan

The nature of the residue in confined rotational crops is understood. 
Based on acceptable studies reviewed by EFED, the metabolism of
propiconazole in rotational crops is similar to that in primary crops. 
At the time of the propiconazole RED, it was concluded that the
established PBI of 105 days for any food/feed crops not listed on the
label was adequate.  This PBI was based on the confined rotational crop
studies.  

Field rotational crop studies with alfalfa have also been submitted, in
support of rotation after propiconazole-treated wheat.  The studies
indicate that a 75-day plantback is appropriate for alfalfa following
primary crops treated with propiconazole at rates totaling up to 0.22 lb
ai/A/season.

The proposed maximum seasonal application rates for rotatable crops in
this petition, 0.45 lb ai/A, are not greater than existing maximum
seasonal application rates for rotatable crops on registered
propiconazole products.  Therefore, no additional rotational crop data
are required to support the proposed uses.  The established rotational
crop restrictions are adequate.

860.1550 Proposed Tolerances

Tolerances are currently established for the combined residues of
propiconazole,
1-[[2-(2,4-dichlorophenyl)-4-propyl-1,3-dioxolan-2-yl]methyl]-1H-1,2,4-t
riazole, and its metabolites determined as 2,4-dichlorobenzoic acid
(2,4-DCBA) and expressed as parent compound in 40 CFR §180.434. 
Tolerances have been established for plant commodities in 40 CFR
§180.434(a), at levels ranging from 0.1 ppm for several commodities,
including pineapple, to 40 ppm for grass straw.  Tolerances for residues
in livestock commodities are also established under 40 CFR §180.434(a),
and range from 0.05 ppm for meat and meat byproducts to 2.0 ppm for
liver and kidney of cattle, goat, horse, and sheep.  Time-limited
tolerances are established in 40 CFR §180.434(b); tolerances with
regional registration are established in 40 CFR §180.434(c); and
tolerances for indirect or inadvertent residues are established in 40
CFR §180.434(d).  

The Codex Alimentarius Commission has established several MRLs for
propiconazole in/on various raw agricultural commodities.  In addition,
both Canada and Mexico have established MRLs for propiconazole in/on
various commodities.  The Codex and Mexican MRLs are expressed in terms
of propiconazole per se.  The Canadian MRLs are expressed in terms of
combined residues of propiconazole and its metabolites containing the
2,4-DCBA moiety.  No Codex, Mexican, or Canadian MRLs have been
established for any crop commodity associated with the proposed uses.  

IR-4 has proposed tolerances for combined residues of the fungicide
propiconazole and its metabolites determined as 2,4-dichlorobenzoic acid
and expressed as parent compound.  HED has concluded that for plants and
livestock, the current tolerance expression for propiconazole should be
amended to include residues of propiconazole per se only.  This allows
for harmonization with the residue definition for Codex.  However, the
tolerance expression has not yet been revised in 40 CFR §180.434.

The tolerances proposed by IR-4 are listed in Table 7, along with the
tolerance levels recommended by HED.  Although HED has recommended
changing the tolerance expression to include only parent, the residue
data submitted in support of the current petitions were generated using
common moiety methods, which do not differentiate between parent and its
2,4-DCBA- containing metabolites.  Therefore, the recommended tolerances
based on these data will overestimate actual propiconazole residues.  

Provided the proposed uses are amended as requested, adequate field
trial data are available for garden beets, parsley, and pineapple. 
Adequate field trial data are not available for turnip; new field trial
data must be submitted before the requested tolerances may be approved.

The Agency’s Guidance for Setting Pesticide Tolerances Based on Field
Trial Data was utilized for determining appropriate tolerance levels for
garden beet roots, garden beet tops, parsley leaves, and pineapple; see
Appendix I for tolerance calculations.  The available data indicate that
the proposed tolerance for parsley leaves is adequate but the proposed
tolerance for pineapple is too low.  A tolerance of 4.5 ppm would be
appropriate for pineapple.  The available data for parsley may be
translated to support use on cilantro; the proposed tolerance, at the
same level as the tolerance for parsley leaves, is appropriate.

The petitioner has proposed a crop group tolerance for crop group 2, the
leaves of the root and tuber vegetables.  Although the representative
crops of this group are garden beet tops and turnip tops, for which the
petitioner submitted crop field trial data, a crop group tolerance is
not appropriate at this time, because crop field trial data for turnip
are not acceptable.  Based on the garden beet field trial data at 1.5x
the proposed rate, tolerance spreadsheet predicted a 0.45 ppm for garden
beet roots and  8.0 ppm for garden beet tops.  Adjusting to 1.0x the
application rate, HED is recommending a 0.30 ppm tolerance on garden
beet roots and a 5.5 ppm on garden beet tops.  

Adequate processing data are available for parsley and pineapple.  These
data indicate that propiconazole residues concentrate in dried parsley
leaves (5.5x) and pineapple process residue (1.7x) but do not
concentrate in pineapple juice.  The appropriate tolerance levels for
these commodities were calculated using the HAFTs and the processing
factors.  The proposed tolerance for dried parsley leaves is too high; a
tolerance of 35 ppm would be appropriate.  A tolerance of 7.0 ppm must
be proposed for pineapple process residue.  

Table 7. 	Tolerance Summary for Propiconazole

Commodity	Proposed Tolerance (ppm)	Recommended Tolerance (ppm)	Comments;
Correct Commodity Definition

Vegetables, leaves of root and tuber, group 2	8.0	Remove	Insufficient
data have been submitted to support a crop group tolerance

Beet, garden, roots	0.6	0.30	Adjusted for 1x application rate

Beet, garden, tops	None	5.5

	Turnip, roots	0.2	Remove	A new set of crop field trial data are needed
if tolerances are to be established.

Turnip, tops	None	Remove

	Parsley, fresh	13	13	Parsley, leaves

Parsley, dried 	60	35	Parsley, dried leaves

Cilantro, leaves	13	13	Coriander, leaves

Pineapple	0.91	4.5	The recommend tolerance will cover the existing
tolerance

Pineapple, process residue	None	7.0

	1  A tolerance for propiconazole residues in/on pineapple is currently
established at 0.1 ppm [40 CFR 180.434(a)].

References

  SEQ CHAPTER \h \r 1 DP#:	324652

Subject:	Propiconazole:  Phase 2, HED Chapter of the Re-registration
Eligibility Decision Document (RED).  PC Code:  122101.  Reregistration
Case No. 3125.

From:	Y. Donovan

To:	C. Giles-Parker

Dated:	2/1/06

MRIDs:	None

DP#:	322215

Subject:	1,2,4-Triazole, Triazole Alanine, Triazole Acetic Acid:  Human
Health Aggregate Risk Assessment in Support of Reregistration and
Registration Actions for Triazole-derivative Fungicide Compounds.  Risk
Assessment Type:  Single Chemical Aggregate; PC Codes:  600074 –
1,2,4-Triazole; 600011 – Triazole Alanine; 600082 – Triazole Acetic
Acid.

From:	M. Doherty, K. Raffaele, K. Farwell, S. Dapson, K. Schumacher, J.
Arthur, D. Hrdy, and I. Maher

To:	T. Gibson/C. Giles-Parker, M. Goodis, and S. Lewis

Dated:	2/7/06

MRIDs:	None

  SEQ CHAPTER \h \r 1 DP#:	327788

Subject:	Triazole-Based Metabolites:  Guidance on Residue Chemistry Data
Submissions.

From:	M. Doherty

To:	C. Giles-Parker

Dated:	4/25/06

MRIDs:	None

  SEQ CHAPTER \h \r 1 DP#:	329394

Subject:	Propiconazole (122101):  Reregistration Eligibility Decision
(RED) Document; Revised Residue Chemistry Considerations; Reregistration
Case:  3125.

From:	Y. Donovan

To:	M. Goodis/C. Scheltema

Dated:	6/15/06

MRIDs:	None

  SEQ CHAPTER \h \r 1 DP#s:	238458, 238468, 238583, 238597, 238598,
247313, 312277, 313199, 313201

Subject:	Propiconazole.  Petitions for Tolerances on Field, Vegetable
and Fruit Crops.  Summary of Analytical Chemistry and Residue Data. 
Petition Numbers:  2F6371, 6E4788, 7E4860, and 8E4931.

From:	Y. Donovan

To:	M. Waller/C. Giles-Parker

Dated:	7/31/06

MRIDs:	43640401, 43655612, 43655613, 44338101, 44416501, 44548402,
44757207, 44757208, 44757210, 45080807, 45080809-45080811, 45215806,
45275801, 45542401, 45778901, 46159401, 46473001, 46475301, 46576301,
46576302

  SEQ CHAPTER \h \r 1 Attachments:  

International Residue Limit Status sheet

Appendix I -Tolerance Assessment Calculations



INTERNATIONAL RESIDUE LIMIT STATUS

Chemical Name: 
1-((2-(2,4-dichlorophenyl)-4-propyl-1,3-dioxolan-2-yl)methyl)-1H-1,2,4-t
riazole	Common Name:

Propiconazole	X Proposed tolerance

 Reevaluated tolerance

 Other	Date:  5/8/08

Codex Status (Maximum Residue Limits)	U. S. Tolerances

No Codex proposal step 6 or above

 No Codex proposal step 6 or above for the crops requested	Petition
Number:  PP#7E7300

DP#:  348248

Other Identifier:  Decision No. 386896

Residue definition (step 8/CXL): 

No Limits

√ No Limits for the crops requested	No Limits

√  No Limits for the crops requested

Residue definition: 
1-[[2-(2,4-diclorophenyl)-4-propyl-1,3-dioxolan-2-yl]methyl]-1H-1,2,4-tr
iazole including all metabolites containing the
2,4-dichlorophenyl-1-methyl substituted moiety	Residue definition: 
Propiconazol

Crop(s)	MRL (mg/kg)	Crop(s)	MRL (mg/kg)

























	Notes/Special Instructions:  S.Funk, 05/08/2008.





Appendix I.  Tolerance Assessment Calculations.

For each of the crops listed below, the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data (SOP), along with the tolerance
spreadsheet (January 2008 version), was used for calculating recommended
tolerances.  As specified in the SOP, the minimum of the 95% upper
confidence limit (UCL) on the 95th percentile and the point estimate of
the 99th percentile was selected as the tolerance value in cases when
the dataset was large (greater than 15 samples) and reasonably
lognormal.  For datasets that were small (≤15 samples) and reasonably
lognormal, the upper bound estimate of the 95th percentile based on the
median residue value was compared to the minimum of the 95% UCL on the
95th percentile and the point estimate of the 99th percentile, and the
minimum value was selected as the tolerance value.  For datasets that
were not lognormal, the upper bound on the 89th percentile was selected
as the tolerance value (distribution-free method).  The rounding
procedures specified in the SOP were also used.

Beet, garden, roots and tops

The datasets used to establish a tolerance for propiconazole on garden
beet roots and tops consisted of field trial data for garden beets
representing application rates of 0.664-0.686 lb ai/A (4 applications at
0.162-0.174 lb ai/A/application) with a 14- to 16-day PHI.  The field
trial application rates and PHIs are 1.5x the maximum label application
rate and 2x the minimum label PHI, respectively.  The petitioner did not
submit any field trial data reflecting field trial application rates and
PHIs within 25% of the maximum label application rate and minimum label
PHI, respectively.  The residue values that were entered into the
tolerance spreadsheet are provided in Table I-1.

All field trial sample results for total propiconazole in/on garden beet
tops were above the LLMV (LLMV = 0.05 ppm for each commodity).  Because
2 of 10 field trial sample results for garden beet roots were below
LLMV, maximum likelihood estimation (MLE) procedures were needed to
impute censored values.  The datasets were small (10 samples).  For
garden beet roots, visual inspection of the lognormal probability plot
(Figure I-1) and the results from the approximate Shapiro-Francia test
statistic (Figure I-2) indicated that the dataset was reasonably
lognormal.  For garden beet tops, visual inspection of the lognormal
probability plot (Figure I-3) and the results from the approximate
Shapiro-Francia test statistic (Figure I-4) indicated that the
assumption of lognormality should be rejected.

Using the tolerance spreadsheet, the recommended tolerances are 0.45 ppm
for garden beet roots and 8.0 ppm for garden beet tops.  

Table I-1.	Residue data used to calculate tolerance for residues of
propiconazole in/on garden beet tops and tops.  

Regulator:	EPA	EPA

Chemical:	Propiconazole	Propiconazole

Crop:	Garden Beet Roots (MLE)	Garden Beet Tops

PHI:	14 days	14 days

App. Rate:	0.664-0.686 lb ai/A	0.664-0.686 lb ai/A

Submitter:	IR-4	IR-4

MRID Citation:	MRID 47297201	MRID 47297201

	Residues of Total Propiconazole (ppm)

	0.0341	4.3

	0.085	4.2

	0.11	4.2

	0.084	4.1

	0.20	4.0

	0.0431	3.0

	0.11	0.46

	0.27	0.44

	0.078	2.8

	0.16	3.1

1  This value was <LLMV prior to application of MLE procedures.

Figure I-1.  Lognormal probability plot of propiconazole field trial
data for garden beet roots.

Figure I-2.   Tolerance spreadsheet summary of propiconazole field trial
data for garden beet roots.

Figure I-3.  Lognormal probability plot of propiconazole field trial
data for garden beet tops.

Figure I-4.   Tolerance spreadsheet summary of propiconazole field trial
data for garden beet tops.

Parsley, fresh

The dataset used to establish a tolerance for propiconazole on fresh
parsley consisted of field trial data representing application rates of
0.432-0.455 lb ai/A (4 applications at 0.107-0.116 lb ai/A/application)
with a 13- to 15-day PHI.  As specified by the SOP, the field trial
application rates are within 25% of the maximum label application rate,
however, the PHIs are approximately twice as long as the minimum label
PHI.  No field trial data were submitted reflecting a PHI of 7 days. 
The residue values that were entered into the tolerance spreadsheet are
provided in Table I-2.

All field trial sample results for fresh parsley were above the LLMV
(LLMV = 0.05 ppm).  The dataset was small (8 samples).  Visual
inspection of the lognormal probability plot (Figure I-5) and the
results from the approximate Shapiro-Francia test statistic (Figure I-6)
indicated that the parsley dataset was reasonably lognormal.  

Using the tolerance spreadsheet, the recommended tolerance is 13 ppm for
fresh parsley.

Table I-2.	Residue data used to calculate tolerance for residues of
propiconazole in/on parsley.  

Regulator:	EPA

Chemical:	Propiconazole

Crop:	Parsley, Fresh

PHI:	13-15 days

App. Rate:	0.432-0.455 lb ai/A

Submitter:	IR-4

MRID Citation:	MRID 47297203

	Residues of Total Propiconazole (ppm)

	6.1

	6.5

	3.8

	3.0

	1.8

	1.2

	3.1

	3.7



Figure I-5.  Lognormal probability plot of propiconazole field trial
data for parsley.

Figure I-6.   Tolerance spreadsheet summary of propiconazole field trial
data for parsley.

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8tment types (propiconazole alone, propiconazole plus fruit wax, and
propiconazole plus fruit oil) were entered into the spreadsheet.

All field trial sample results for pineapple were above the LLMV (LLMV =
0.05 ppm).  The dataset was large (18 samples).   Visual inspection of
the lognormal probability plot (Figure I-7) and the results from the
approximate Shapiro-Francia test statistic (Figure I-8) indicated that
the assumption of lognormality should be rejected for the pineapple
dataset.

Using the tolerance spreadsheet, the recommended tolerance is 4.5 ppm
for pineapple.

Table I-3.	Residue data used to calculate tolerance for residues of
propiconazole in/on pineapple.  

Regulator:	EPA

Chemical:	Propiconazole

Crop:	Pineapple, Fruit

PHI:	Postharvest dip

App. Rate:	0.126 lb ai/100 gal

Submitter:	IR-4

MRID Citation:	MRID 47297204

	Residues of Total Propiconazole (ppm)

	4.1

	3.0

	0.88

	1.3

	1.8

	1.7

	0.50

	0.45

	0.34

	0.39

	0.42

	0.34

	0.37

	0.56

	0.50

	0.52

	0.56

	0.82



Figure I-7.  Lognormal probability plot of propiconazole field trial
data for pineapple.

Figure I-8.   Tolerance spreadsheet summary of propiconazole field trial
data for pineapple.

Page   PAGE  3  of   NUMPAGES  31 

Propiconazole	Summary of Analytical Chemistry and Residue Data	DP#: 
348248

