UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF           

PREVENTION, PESTICIDES

AND TOXIC SUBSTANCES

  SEQ CHAPTER \h \r 1 MEMORANDUM

Date:  10/21/08.

SUBJECT:	Dimethomorph.  Application for Amended Section 3 Registration
to Add Uses on Lima Bean, Ginseng, Grape, and Turnip Greens.  Summary of
Analytical Chemistry and Residue Data.  

PC Code:  268800	DP Barcode:  D349735

Decision No.:  388342	Registration No.:  241-410 and 241-427

Petition No.:  8E7314	Regulatory Action:  Amended Section 3 Registration

Risk Assessment Type:  NA	Case No.:  NA

TXR No.:  NA	CAS No.:  110488-70-5

MRID Nos.:  47317201 and 47317202	40 CFR:  180.493

		              									

FROM:	Anant Parmar, Biologist

		  SEQ CHAPTER \h \r 1 RAB2/Health Effects Division (7509P)		

		

THROUGH:	Douglas Dotson, Ph.D., Chemist

		Richard Loranger, Ph.D., Senior Scientist

		RAB2/Health Effects Division (7509P)

		

TO:		William T. Drew, Chemist  SEQ CHAPTER \h \r 1   SEQ CHAPTER \h \r 1


		RAB2/Health Effects Division (7509P)

and

Daniel Rosenblatt/Barbara Madden, RIMUERB

Registration Division (7505P)

  SEQ CHAPTER \h \r 1 This document was originally prepared under
contract by Dynamac Corporation (2275 Research Boulevard, Suite 300;
Rockville, MD 20850).  The document has been reviewed by the Health
Effects Division (HED) and revised to reflect current Office of
Pesticide Programs (OPP) policies.

Executive Summary

  SEQ CHAPTER \h \r 1 Dimethomorph [(E,Z)
4-[3-(4-chlorophenyl)-3-(3,4-dimethoxyphenyl)-1-oxo-2-propenyl]morpholin
e] is a systemic morpholine fungicide (Group 5) currently registered for
use on bulb vegetables, cucurbit vegetables, fruiting vegetables, leafy
Brassica greens, hops, lettuce, potatoes, taro, and tobacco, and
approved for use on head and stem Brassica vegetables.  Its mode of
action is the inhibition of sterol (ergosterol) synthesis.  Dimethomorph
was developed for control of downy mildews, late blights, as well as for
crown and root rots.  

The Interregional Research Project No. 4 (IR-4), on behalf of the
Agricultural Experiment Stations of CO, DE, HI, MI, NJ, NY, NC, OR, and
TN, is proposing tolerances for lima beans, ginseng, grapes, and turnip
greens.  The end use products include a 4.17 lb/gal suspension
concentrate (equivalent to a flowable concentrate; FlC) formulation of
dimethomorph (Forum® Fungicide, EPA Reg. No. 241-427) and a 50%
wettable powder (WP) formulation (Acrobat 50WP Fungicide; EPA Reg. No.
241-410).  Foliar uses on these proposed crops are to be made at a
maximum seasonal rate of 1.0 lb ai/A with a 0-day PHI for lima bean and
turnip greens, 14-day PHI for ginseng, and 28-day PHI for grape. 
Applications may be made using ground or aerial equipment.

In conjunction with the requested amended uses, IR-4 has submitted a
petition, PP#8E7314, for the establishment of permanent tolerances for
the combined residues (free and bound) of the fungicide dimethomorph,
(E,Z)
4-[3-(4-chlorophenyl)-3-(3,4-dimethoxyphenyl)-1-oxo-2-propenyl]morpholin
e, in or on the following raw agricultural commodities:

Beans, lima 	0.6 ppm

Ginseng 	0.85 ppm

Grape 	3.5 ppm

Grape, raisin 	6 ppm

Greens, turnip 	20 ppm

The tolerances for grape and raisin are based on the currently
established import tolerances for these commodities, and the tolerance
for turnip greens is based on the established tolerance for Brassica
leafy greens (subgroup 5B).

Tolerances for residues of dimethomorph are established under 40 CFR
§180.493 and are expressed in terms of dimethomorph per se.  Permanent
tolerances are established under §180.493(a) for residues of parent
dimethomorph in/on a variety of crops, ranging from 0.5 ppm for cucurbit
vegetables to 60 ppm for hop dried cones.  Time-limited tolerances for
indirect or inadvertent residues of dimethomorph were established for
the cereal grains group and the forage, fodder, and straw of the cereal
grains group under §180.493(d); these tolerances expired on 5/12/04.

The nature of the residue in plants has been adequately delineated based
on metabolism studies with grape, lettuce and potato.  In all three
studies, parent dimethomorph was the predominant residue.  No
metabolites were identified that require regulation.  For purposes of
this petition, the residue of concern for tolerance setting and risk
assessment purposes is considered to be parent dimethomorph.  

There are no livestock feedstuffs associated with the proposed uses on
lima beans, ginseng, grape, and turnip greens.  Therefore, no livestock
metabolism data, enforcement methods, storage stability data, or feeding
studies are required to support this petition.

  SEQ CHAPTER \h \r 1 An adequate method is available for enforcement of
tolerances for dimethomorph residues in/on crops, HPLC/UV Method FAMS
002-04.  The limits of quantitation (LOQs) range from 0.01 to 0.05 ppm,
depending on sample matrix.  In addition, dimethomorph is recovered
using FDA Multiresidue Method Section 302 (Protocol D).

The available European field trial data are adequate to support the
proposed use of the 50% WP and 4.17 lb/gal FlC formulations on grapes
grown east of the Rocky Mountains.  No change in the established
tolerance level for grapes is necessary; however, the tolerance must be
moved to 180.493(c), for tolerances with regional registration.

No crop field trial data were submitted to support use of the 4.17
lb/gal FlC formulation of dimethomorph on lima bean, ginseng, or turnip
greens.  On an interim basis for a conditional registration, these uses
are supported by the European grape field trials.  In these trials,
residue levels arising from the application of various formulations of
dimethomorph to grapes were compared.  They demonstrated that residues
on grape were comparable between the WP and FlC formulations.  HED
concludes that the existing dimethomorph database and European field
trials support the conditional use of the 4.17 lb/gal FlC formulation on
lima bean (succulent), ginseng, and turnip greens.

To support these conditional uses, IR-4 should submit at least two
side-by-side field trials, comparing residues from the use of the WP and
FlC formulations, for both lima beans (succulent) and turnip greens. 
These side-by-side trials should reflect application of the 4.17 lb/gal
FlC formulation at 1x the proposed maximum seasonal rate.  These
commodities should be harvested at the proposed zero-day PHI.  If these
trials demonstrate that the two different formulations result in
comparable residues (1.5x or less) then ginseng will not require side by
side trials.  Otherwise, all RACs lacking adequate residue data on the
4.17 lb/gal FlC formulation may require a full complement of field
trials.

Adequate field trial data reflecting application of a 50% WP formulation
have been submitted to support the proposed uses of this formulation on
ginseng and lima bean; label amendments are required to specify that use
on lima beans is restricted to areas east of the Rocky Mountains.  The
submitted crop field trial data were collected using modified versions
of the existing enforcement method and are supported by concurrent
storage stability data.  The data indicate that the proposed tolerance
for lima beans is adequate.  For ginseng, the crop field trial data
indicate that the proposed tolerance of 0.85 ppm is slightly too low; a
tolerance of 0.90 ppm is needed instead.  

Previously submitted data for mustard greens (a member of the Leafy
Brassica Greens Subgroup (5B)) are adequate to support the proposed use
of the 50% WP formulation on turnip greens.  The proposed tolerance for
turnip greens is adequate.  

The residue data for all the subject crops do not reflect addition of
adjuvants to the spray mixture.  Therefore, the labels for both
formulations should prohibit addition of adjuvants for uses on these
crops.

Previously submitted processing data for grapes indicate that
dimethomorph residues do not concentrate in juice.  The Chemistry
Science Advisory Council (ChemSAC) has concluded that residue data for
raisins are not required to support use of dimethomorph on grapes grown
east of the Rocky Mountains, as almost all raisins consumed in the U.S.
come from California (minutes of 7/12/2006 meeting).  

Adequate confined rotational crop data have been submitted previously. 
Based on the existing data and ARIA’s review of new rotational crop
data (D323873, D. Rate, 09/05/2008), ARIA has concluded that additional
rotational crop data are needed for a leafy vegetable, and a root crop,
and permanent rotational crop tolerances are needed for the forage,
fodder, hay, and straw of grain, cereal group.  The existing rotational
crop restrictions on the label for the 50% WP and 4.17 lb/gal FlC
formulations are adequate.  

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

HED has examined the residue chemistry database for dimethomorph. 
Pending submission of a revised Section B (see requirements under
Directions for Use), a revised Section F (see requirements under
Proposed Tolerances), and the submission of analytical standard for the
dimethomorph Z isomer (see requirements under Submittal of Analytical
Reference Standards) there are no residue chemistry issues that would
preclude granting: conditional Section 3 registration for the requested
uses of the 50% WP and 4.17 lb/gal FlC formulations of dimethomorph on
lima beans, ginseng, turnip greens, and grapes; or establishment of
tolerances for residues of dimethomorph, as follows:

	Tolerances to be listed under 40 CFR §180.493(a):

Ginseng 	0.90 ppm

Turnip, greens 	20.0 ppm

	Tolerances to be listed under 40 CFR §180.493(c):

Bean, lima, succulent 	0.60 ppm

Grape 	3.5 ppm

Note to PM:

  

With establishment of the above tolerances, the tolerance listed for
“Grape” under 40 CFR §180.493(a) should be removed.  In addition,
the text for footnote 1 should be changed from “There are no U.S.
registrations as of August 25, 2000, for the use of dimethomorph on the
growing crops, grape, hop, and raisins” to “There are no U.S.
registrations as of XX 2008, for the use of dimethomorph on grapes grown
for raisin production.”  Domestic registration of dimethomorph on hops
was addressed in the Federal Register notice of 9/27/02.

A tolerance is established for “Potato, wet peel” under 40 CFR
§180.493(a), but there is no tolerance listed for “Potato.”  HED
recommends for a permanent tolerance of 0.05 ppm.  The FR Notice dated
Oct. 13, 1998 established permanent tolerance in/on potato at 0.05 ppm.

860.1200 Directions for Use

The proposed uses of the 50% WP and 4.17 lb/gal FlC formulation on lima
bean should be amended to specify that the product may only be applied
to lima beans grown east of the Rocky Mountains.  In addition, the
proposed use should be amended to specify that application may only be
made to lima beans intended for harvest as succulent seed.

The proposed uses of the 50% WP and 4.17 lb/gal FlC formulation on grape
should be amended to specify that application may only be made to grapes
grown east of the Rocky Mountains.  In addition, a minimum spray volume
of 10 gal/A should be specified for aerial application to grapes.  

The proposed uses of the 50% WP and 4.17 lb/gal FlC formulation on
turnip greens should be amended to prohibit applications to turnip
cultivars that are grown for root production.

The proposed uses of both the WP and FlC formulations on the four
subject crops should be amended to prohibit addition of adjuvants to the
spray mixture.

860.1550 Proposed Tolerances

The proposed tolerance expression must be revised to state:  “ . . .
the residues of the fungicide dimethomorph, ( E,Z
)4-[3-(4-chlorophenyl)-3-(3,4-dimethoxyphenyl)-1-oxo-2-propenyl]morpholi
ne in or on . . .”  The reference to combine free and bound residues
should not be included in the expression.  

The proposed tolerances should be revised to reflect the recommended
tolerance levels and correct commodity definitions as specified above
and in Table 6.

Conversion of conditional registration to unconditional registration for
the requested uses may be considered upon submission of the following
outstanding residue chemistry data.

860.1900 Field Rotational Crops

As specified in DP# 323873 (08/05/08, D. Rate), two additional field
rotational crop studies with a leafy vegetable, and a root crop should
be submitted.  

860.1500 Crop Field Trials

To support the conditional uses of the FlC formulation IR-4 should
submit at least two side-by-side field trials, comparing residues from
use of the WP and FlC formulations, for both lima beans (succulent) and
turnip greens.  These side-by-side trials should reflect application of
the 4.17 lb/gal FlC formulation at 1x the proposed maximum seasonal
rate.  These commodities should be harvested at the proposed PHI.

If these trials demonstrate that the two different formulations result
in comparable residues then ginseng will not require side by side
trials.  Otherwise, all RACs lacking adequate residue data on the 4.17
lb/gal FlC formulation may require a full complement of field trials.

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

The standard for dimethomorph Z isomer at the National Pesticide
Standards Repository has expired (expiration date 9/01/2008).  For the
expired standard, the registrant must either recertify the lot in the
repository and send in an updated certificate of analysis (COA), or
submit a new standard (different lot #) if the previous lot will not be
recertified.  If new COAs are being submitted, they should be faxed to
the repository at 410-305-2999.  If new standards are being submitted
they should be sent to the Analytical Chemistry Branch, which is located
at Fort Meade, to the attention of Theresa Cole at the following
address:

		USEPA

		National Pesticide Standards Repository/Analytical Chemistry
Branch/OPP

		701 Mapes Road

		Fort George G. Meade, MD  20755-5350

(Note that the mail will be returned if the extended zip code is not
used.)

Background

Dimethomorph is a systemic morpholine fungicide (Group 5) currently
registered for use on bulb vegetables, cucurbit vegetables, fruiting
vegetables, leafy Brassica greens, hops, lettuce, potatoes, taro, and
tobacco; currently there are no U.S. uses on grapes.  The chemical
structures and nomenclature of dimethomorph are listed in Table 1.  The
physicochemical properties of technical grade dimethomorph are listed in
Table 2.

Table 1.		Dimethomorph Nomenclature.

Chemical structure	

Common name	  SEQ CHAPTER \h \r 1 Dimethomorph

Company experimental name	AC 336379

IUPAC name
(E,Z)-4-[3-(4-chlorophenyl)-3-(3,4-dimethoxyphenyl)acryloyl]morpholine

CAS name
4-[3-(4-chlorophenyl)-3-(3,4-dimethoxyphenyl)-1-oxo-2-propenyl]morpholin
e

CAS registry number	110488-70-5

End-use product (EP)	Acrobat® 50WP (50% WP formulation); EPA Reg. No.
241-410

Forum Fungicide (4.17 lb/gal FlC formulation); EPA Reg. No. 241-427



Table 2.		Physicochemical Properties of Dimethomorph.

Parameter	Value	Reference

Melting point/range	125-149ºC	DP# 316328, 7/18/05, W. Cutchin

pH	Not applicable; not soluble in water

	Density	  SEQ CHAPTER \h \r 1 1.318 g/cm3 at 20ºC (pycnometer method)

	Water solubility (20ºC)	  SEQ CHAPTER \h \r 1 water, pH 5		19 mg/L

water, pH 7		18 mg/L

water, pH 9		16 mg/L

	Solvent solubility (20ºC)	  SEQ CHAPTER \h \r 1 n-hexane		0.11 mg/mL

methanol		39.0 mg/mL

toluene		49.5 mg/mL

acetone		100 mg/mL

dichloromethane		461 mg/mL

	Vapor pressure	  SEQ CHAPTER \h \r 1 E-isomer:  9.7 x 10-7 Pa at 25ºC

Z-isomer:  1.0 x 10-6 Pa at 25ºC

	Dissociation constant, pKa	Not determinable (the solubility of
dimethomorph is very low, and the ionized and nonionized forms have
identical absorption coefficients)

	Octanol/water partition coefficient, Log(KOW)	  SEQ CHAPTER \h \r 1
E-isomer:  Kow = 430 (log Kow = 2.63) at 20ºC

Z-isomer:  Kow = 543 (log Kow = 2.73) at 20ºC

	UV/visible absorption spectrum	Not available

	

860.1200  Directions for Use

IR-4 included copies of an existing label and an amended label for the
4.17 lb/gal FlC formulation (EPA Reg. No. 241-427); the amended label
included use directions for lima beans, ginseng, grape, and turnip
greens.  IR-4 also provided a description of the proposed uses of the
50% WP formulation (EPA Reg. No. 241-410) on lima beans, ginseng, grape,
and turnip greens.  The proposed new uses are summarized in Table 3.

Table 3.	Summary of Directions for Use of Dimethomorph.

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

Bean, lima

Postemergence,

Foliar,

Ground or aerial	50% WP 

[241-410]	0.2	5	1.0	0	A minimum retreatment interval (RTI) of 7 days has
been proposed.

Postemergence,

Foliar,

Ground or aerial	4.17 lb/gal FlC [241-427]	0.2	5	1.0	0	A minimum RTI of
7 days has been proposed.  Ground applications are to be made in ≥20
gal/A and aerial applications are to be made in ≥5 gal/A.

Ginseng

Postemergence,

Foliar,

Ground or aerial	50% WP 

[241-410]	0.2	5	1.0	14	A minimum RTI of 7 days has been proposed.

Postemergence,

Foliar,

Ground	4.17 lb/gal FlC [241-427]	0.2	5	1.0	14	A minimum RTI of 7 days
has been proposed.  Applications are to be made in ≥20 gal/A.

Grape

Postemergence,

Foliar,

Ground or aerial	50% WP 

[241-410]	0.2	5	1.0	28	A minimum RTI of 7 days has been proposed.

Postemergence,

Foliar,

in ≥20 gal/A.

Turnip greens

Postemergence,

Foliar,

Ground or aerial	50% WP 

[241-410]	0.2	5	1.0	0	A minimum RTI of 7 days has been proposed.

Postemergence,

Foliar,

Ground or aerial	4.17 lb/gal FlC [241-427]	0.2	5	1.0	0	A minimum RTI of
7 days has been proposed.  Ground applications are to be made in ≥20
gal/A and aerial applications are to be made in ≥5 gal/A.



For the 50% WP formulation, IR-4 only included a text summary of
proposed use directions for the individual crops.  It was stated that
general use information should be obtained from the registered label
which was reportedly included in Section A of the petition.  No label
for EPA Reg. No. 241-410 was included in Section A.  The study reviewer
obtained the general use information for the 50% WP formulation from the
currently registered label (label accepted 4/22/04).  

The general use directions for the 50% WP and 4.17 lb/gal FlC
formulations specify that the product must be used as a tank-mix with
fungicides active against the target diseases in order to reduce the
risk of the development of fungicide resistance.  Applications are to be
made in ≥20 gal/A for ground equipment or a minimum of 5 gal/A for
aerial equipment.  The labels allow chemigation application through
sprinkler irrigation systems including center-pivot, lateral move, side
(wheel) roll, solid set or hand move irrigation systems; application
through any other type of irrigation system is prohibited.

The following rotational crop restrictions are specified for the 50% WP
formulation:

	0 months:	Potatoes, tomatoes, tobacco, bulb vegetables, cucurbit
vegetables, hops, lettuce (head and leaf), taro, and leafy Brassica
greens;

	1 month	Barley, oats, wheat, leafy vegetables (such as spinach, and
celery), Brassica vegetables (such as broccoli, cabbage, and
cauliflower), and root/tuber vegetables (such as carrot, radish, and
sugar beet);

	7 months	Alfalfa, beans, clover, corn, peas, rice, sorghum, and
soybeans;

	12 months	All other crops.

The following rotational crop restrictions are specified for the 4.17
lb/gal FlC formulation:

	0 months:	Brassica leafy vegetables, bulb vegetables, cucurbit
vegetables, fruiting vegetables, ginseng, grapes, hops, lettuce (head
and leaf), lima bean, potatoes, taro, tobacco, tomatoes, turnip greens;

	1 month	Barley, leafy vegetables, (such as spinach and celery), oats,
root and tuber vegetables, (such as carrot, radish, and sugar beet),
wheat;

	7 months	Alfalfa, beans (other than lima), clover, corn, peas, rice,
sorghum, and soybeans;

	12 months	All other crops.

Conclusions.  The submitted use pattern information is adequate to allow
evaluation of the residue data relative to the proposed use.  Several
amendments to the proposed use are required.

The petitioner has stated (MRID 47317202) that the lima bean field trial
data were intended to support use of dimethomorph on lima beans grown
east of the Rocky Mountains.  The geographic representation of lima bean
data is adequate to support the intended use pattern.  The proposed uses
of the 50% WP and 4.17 lb/gal FlC formulation should be amended to
specify that the product may only be applied to lima beans grown east of
the Rocky Mountains.  In addition, the proposed use should be amended to
specify that application may only be made to lima beans intended for
harvest as succulent seed.

The proposed uses of the 50% WP and 4.17 lb/gal FlC formulation on grape
should be amended to specify that application may only be made to grapes
grown east of the Rocky Mountains.  In addition, a minimum spray volume
of 10 gal/A should be specified for aerial application to grapes.  

The proposed uses of the 50% WP and 4.17 lb/gal FlC formulation on
turnip greens should be amended to prohibit applications to turnip
cultivars that are grown for root production.

The uses for both formulations on the four subject crops should be
amended to prohibit addition of adjuvants to the spray tank.  Field
trials to support the proposed uses did not reflect use of adjuvants.

Although the field trial data for lima bean and ginseng represent
application rates 40-70% higher than the maximum proposed seasonal rate,
the data are acceptable to support the proposed use because the single
application rate used in the crop field trials was ~1x the proposed
maximum single application rate.  

860.1300 Nature of the Residue - Plants

Residue Chemistry Memo DP# 192776, 3/13/95, D. Davis (PP#2E4054)

Residue Chemistry Memo DP# 219530, 10/31/95, D. Davis (PP#2E4054)

Residue Chemistry Memo DP#s 237101, 239372, 239899, and 242381, 5/4/00,
D. Dotson (PP#7F4816)

No new plant metabolism studies were submitted.  Adequate metabolism
studies with grape, lettuce, and potato have previously been submitted
and reviewed.  In all three studies, parent dimethomorph was the
predominant residue.  No metabolites were identified that require
regulation.  These metabolism studies are adequate to support the
requested uses.  For the purposes of this petition, the residue of
concern for tolerance setting and risk assessment purposes is considered
to be parent dimethomorph.  

HED had noted previously (DP# 316328, 7/18/05, W. Cutchin) that, based
on the existing metabolism studies, the nature of the residue in all
plants is not considered to be adequately understood and that if a
tolerance on a dissimilar major crop is sought in the future, additional
metabolism data may be required to support such a request.  

860.1300 Nature of the Residue - Livestock

There are no livestock feedstuffs associated with the proposed uses on
lima beans, ginseng, grape, and turnip greens.  Therefore, data
requirements for livestock metabolism are not relevant to this tolerance
petition.

860.1340 Residue Analytical Methods

Residue Chemistry Memo DP#s 237101, 239372, 239899, and 242381, 5/4/00,
D. Dotson (PP#7F4816)

Enforcement method:  The HPLC/UV method FAMS 002-04 has been determined
to be adequate for tolerance enforcement purposes for determining
residues of dimethomorph per se.  Briefly, homogenized samples are
extracted with acetone and the extract is mixed with sodium chloride
solution and partitioned with dichloromethane (DCM).  The DCM phase is
evaporated to dryness and redissolved in methanol for cleanup by gel
permeation chromatography.  The extract is then cleaned up on a silica
gel column, using acetone:n-hexane (20:80, v:v) to elute residues.  The
eluate is evaporated to dryness and redissolved in methanol for HPLC/UV
analysis.  The reported LOQs range from 0.01 to 0.05 ppm, depending on
sample matrix.  The method has been successfully validated by ACB/BEAD.

A confirmatory method is also available, Method M 2577, a GC method with
nitrogen phosphorus detection. 

Data collection methods:  Crop samples from the submitted lima bean and
ginseng field trial studies were analyzed for residues of dimethomorph
using GC/MS methods similar to the enforcement method FAMS 002-04. 
Briefly, samples were extracted with acetone and the extract was
partitioned twice with saturated sodium chloride solution and DCM.  The
DCM phase was evaporated to dryness, redissolved in acetonitrile (ACN)
and hexane, and the ACN phase was evaporated to dryness and redissolved
in DCM (ginseng) or 40% ethyl acetate in hexane (lima bean).  The
extract was cleaned up by solid phase extraction (Florisil or silica gel
column).  The eluate was concentrated to dryness and reconstituted in
0.1% corn oil in ethyl acetate (ginseng) or 1% corn oil in acetone (lima
bean) for GC/MS analysis.  The lowest level of method validation (LLMV)
was 0.05 ppm for ginseng and 0.01 ppm for lima bean. 

The methods were adequately validated prior to and with analysis of the
field samples.  Acceptable recoveries were obtained from untreated
ginseng samples fortified with dimethomorph at 0.05-5 ppm, and untreated
lima bean samples fortified at 0.01-1 ppm.  The fortification levels
used in method verification and concurrent method recovery were adequate
to bracket expected residue levels in lima bean and ginseng.

Conclusions.  The GC/MS methods are adequate for collecting data on
residues of dimethomorph in/on lima bean and ginseng.  The available
enforcement method will be adequate for tolerance enforcement purposes
for the proposed uses.  

860.1360 Multiresidue Methods

The FDA PESTDATA database (dated 06/05) indicates that dimethomorph is
recovered (variable recovery; 87-133%) using FDA multiresidue method
Section 302 (Protocol D) but is not recovered using Sections 303
(Protocol E) or 304 (Protocol F).  

860.1380 Storage Stability

DER Reference List:  	47317201.der.doc (Ginseng)

			47317202.der.doc (Lima bean)

The petitioner conducted supporting storage stability studies in
conjunction with the ginseng and lima bean field trials.  Samples of
untreated ginseng root and lima bean succulent seed were fortified with
dimethomorph at 0.5 and 0.1 ppm, respectively, and stored frozen with
the field trial samples.  No zero-day data were provided.  The
concurrent storage stability data indicate that fortified residues of
dimethomorph are stable in/on lima bean succulent seed stored frozen for
up to 764 days and ginseng root stored frozen for up to 175 days.  

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

Lima bean, succulent seed (without pod)	≤-4	395-867 days

(13.0-28.5 months)	Concurrent storage stability data indicate that
residues of dimethomorph are stable for up to 764 days (25.1 months)
in/on frozen lima bean.

Ginseng root	-26 to -16	132-176 days

(4.3-5.8 months)	Concurrent storage stability data indicate that
residues of dimethomorph are stable for up to 175 days in/on frozen
ginseng root.



Conclusions.  The concurrent storage stability studies are adequate to
support the storage durations and conditions of samples of lima bean and
ginseng from the submitted crop field trial studies.  No corrections for
potential decline during storage are needed for any of the residue
studies.

Zero-day data were not provided with the concurrent storage stability
studies.  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

There are no livestock feedstuffs associated with the proposed use on
lima bean, ginseng, grape, and turnip greens.  Therefore, data
requirements pertaining to meat, milk, poultry, and eggs are not
relevant to this tolerance petition.

860.1500 Crop Field Trials

DER Reference List:  	47317202.der.doc (Lima bean)

			47317201.der.doc (Ginseng)

IR-4 has submitted field trial data for dimethomorph on lima bean
(succulent seed) and ginseng in support of the requested uses.  The
results from these studies are discussed below and summarized in Table
5.    

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

Crop matrix	Total Applic. Rate

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



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

LIMA BEAN (proposed use = 1.0 lb ai/A total application rate, 0-day PHI)

Lima bean, succulent seed	1.41-1.63	0	14	0.03	0.48	0.47	0.04	0.13	0.16

GINSENG (proposed use = 1.0 lb ai/A total application rate, 14-day PHI)

Ginseng, dried root	Drip irrigation; 1.68	14	2	0.60	0.62	0.61	0.61	0.61
--

	Foliar broadcast; 1.40-1.44	13-15	6	0.27	0.43	0.42	0.29	0.33	0.07

	Overall; 1.4-1.7	13-15	8	0.27	0.62	0.61	0.35	0.40	0.15

1  HAFT = Highest average field trial result.

Bean, lima

Seven lima bean field trials were conducted in Zones 2 (GA, MD, and NJ;
6 trials) and 5 (WI; 1 trial) during the 2002 and 2003 growing seasons. 
At each trial, seven foliar applications of a 50% WP formulation of
dimethomorph were made at a target rate of 0.2 lb ai/A/application (1x
the proposed maximum single application rate), with 6- to 8-day
retreatment intervals (RTIs), for a total rate of 1.41-1.43 lb ai/A
(1.4x the proposed maximum seasonal rate).  Applications were made as
foliar directed sprays at five of the sites and as foliar broadcast
sprays at two of the sites.  At one GA trial, a total of eight
applications were made, due to delayed crop maturity, yielding a total
application rate of 1.63 lb ai/A (1.6x the proposed maximum seasonal
rate).  In addition, at one MD trial, there was one 5-day RTI and at the
other MD trial, there was one 11-day RTI.  Applications were made using
ground equipment, in 30-52 gal/A spray volumes, without an adjuvant. 
Samples of mature lima bean (succulent seed without pod) were harvested
on the day of the last application.  Additional samples were collected
from one trial site 3, 5, and 11 days after last application to evaluate
residue decline.

Samples of lima bean were analyzed for residues of dimethomorph using an
adequate GC/MS method.  The LLMV was 0.01 ppm for dimethomorph in/on
lima bean.  Sample storage conditions and durations are reported in
Table 4.  Adequate concurrent storage stability data were submitted to
support sample storage durations and conditions.  

The results of the crop field trials are reported in Table 5.  Maximum
residues of dimethomorph were 0.48 ppm in/on succulent lima bean seed
(without pod) harvested on the day of the last of 7-8 applications at
total rates of 1.41-1.63 lb ai/A.  It is noted that residues in/on
samples from the trial in which 8 applications were made were low (0.03
ppm).

The residue decline data indicate that residues of dimethomorph in/on
lima bean decrease with increasing sampling intervals.

Conclusions.  Provided the petitioner modifies the proposed use as
specified under 860.1200, the submitted lima bean crop field trial data
are adequate.  The number and locations of the field trials are not in
accordance with OPPTS 860.1500 for lima bean.  However, the petitioner
has stated that the field trial data are intended to support use on lima
beans grown east of the Rocky Mountains.  The number and location of
lima bean trials are adequate to support use in areas east of the Rocky
Mountains.  Although the trials reflected both foliar directed and
foliar broadcast applications, the petitioner is proposing that
dimethomorph applications be made to lima bean as broadcast foliar
applications.

Because no field trial data for dry lima beans were submitted, use on
lima beans must be restricted to those varieties intended for harvest as
succulent seed.

Although the field trial data for lima bean represent seasonal rates
~40-60% higher than the maximum proposed seasonal rate, the data are
acceptable to support the proposed use because the single application
rate used in the crop field trials was 1x the proposed maximum single
application rate.  

No field trial data were submitted to support use of the 4.17 lb/gal FlC
formulation of dimethomorph on lima bean (succulent).  On an interim
basis for a conditional registration, these uses are supported by the
European grape field trials.  These trials compared residue levels
arising from the application of various formulations of dimethomorph to
grapes.  These trials demonstrated that residues on grape were
comparable between the WP and FlC formulations.    

To support this conditional use IR-4 should submit at least two
side-by-side field trials, comparing residues from use of the WP and FLC
formulations, for lima beans (succulent).  These side-by-side trials
should reflect application of the 4.17 lb/gal FlC formulation at 1x the
proposed maximum seasonal rate.  This commodity should be harvested at
the proposed zero-day PHI.

If these trials demonstrate that the two different formulations do not
result in comparable residues, all RACs lacking adequate residue data on
the 4.17 lb/gal FlC formulation may require a full complement of field
trials.

The data support a tolerance with regional registration for residues of
dimethomorph in/on lima bean succulent seed at 0.60 ppm.  The tolerance
calculation for lima bean is presented in Appendix I.

Ginseng

Four ginseng field trials were conducted in Zone 5 (MI and WI) during
the 2004 growing season.  At each trial, seven applications of a 50% WP
formulation of dimethomorph were made at a target rate of ~0.2 lb
ai/A/application (1x the proposed maximum single application rate) with
6- to 9-day retreatment intervals.  At the three WI trials, foliar
broadcast applications were made using ground equipment in 159-202 gal/A
spray volumes without an adjuvant, for a total rate of 1.40-1.44 lb ai/A
(~1.4x the proposed maximum seasonal rate).  At the MI trial, drip
irrigation applications were made in 115 gal/A volumes without an
adjuvant, for a total rate of 1.68 lb ai/A (1.7x the proposed maximum
seasonal rate).  The petitioner noted that individual applications at
the MI site were over-applied by ~20%.  Samples of ginseng root were
harvested 13-15 days after the last application.

Samples of ginseng were analyzed for residues of dimethomorph using an
adequate GC/MS method.  The LLMV was 0.05 ppm for dimethomorph in
ginseng.  Sample storage conditions and durations are reported in Table
4.  Adequate concurrent storage stability data were submitted to support
sample storage durations and conditions.  

The results of the ginseng field trials are reported in Table 5. 
Maximum residues of dimethomorph were 0.62 ppm in/on ginseng root
harvested 14 days following the last of seven drip irrigation
applications of the 50% WP formulation at a total rate of 1.68 lb ai/A. 


Maximum residues of dimethomorph were 0.43 ppm in/on ginseng root
harvested 13-15 days following the last of seven foliar broadcast
applications of the 50% WP formulation at a total rate of 1.4 lb ai/A.

Conclusions.  Provided the petitioner modifies the proposed use as
specified under 860.1200, the submitted ginseng crop field trial data
are adequate.  The number and locations of the field trials are in
accordance with OPPTS 860.1500 for ginseng.  Although the field trial
data represent application rates ~40-70% higher than the maximum
proposed seasonal rate, the data are acceptable to support the proposed
use on ginseng because the single application rate used in the crop
field trials was ~1x the proposed maximum single application rate.  

No field trial data were submitted to support use of the 4.17 lb/gal FlC
formulation of dimethomorph on ginseng.  On an interim basis for a
conditional registration, these uses are supported by the European grape
field trials.  In these trials, residue levels arising from the
application of various formulations of dimethomorph to grapes were
compared.  These trials demonstrated that residues on grape were
comparable between the WP and FlC formulations.    

To support this conditional use IR-4 should submit at least two
side-by-side field trials, comparing residues from use of the WP and FlC
formulations, for lima beans (succulent) and turnip greens.  These
side-by-side trials should reflect application of the 4.17 lb/gal FlC
formulation at 1x the proposed maximum seasonal rate.  These commodities
should be harvested at the proposed zero-day PHI.

If these trials demonstrate that the two different formulations result
in comparable residues (1.5x or less) then ginseng will not require side
by side trials.  Otherwise, all RACs lacking adequate residue data on
the 4.17 lb/gal FlC formulation might require a full complement of field
trials.

The data support a tolerance for residues of dimethomorph in/on ginseng
at 0.90 ppm.  The tolerance calculation for ginseng is presented in
Appendix I.

Grape

Residue Chemistry Memo DP# 192776, 3/13/95, D. Davis (PP#2E4054)

Residue Chemistry Memo DP#s 226315 and 227506, 8/2/96, C. Eiden
(PP#2E4054)

Residue Chemistry Memo DP#s 237101, 239372, 239899 & 242381, 5/4/00, D.
Dotson (PP#7F4816)

No new grape field trial data were submitted.  To support the proposed
uses for dimethomorph on grapes in the U.S., IR-4 is relying on European
field trial data submitted to establish the current import tolerance for
dimethomorph residues in/on grape (PP#s 2E4054 and 7F4816).  ChemSAC
considered this request (see minutes of 7/12/2006 meeting) and concluded
that, because the available European data were conducted in multiple
countries and/or multiple years, the residue data may be used to support
application of dimethomorph to grapes grown east of the Rocky Mountains,
provided that the petitioner addresses the following issues:  (i) the
maximum U.S. application rate should be equal to or less than the rate
used in the European trials; (ii) the U.S. preharvest and reapplication
intervals should match the European trials; and (iii) the petition needs
to address any differences in formulation and inert ingredients between
those used in the European trials and those proposed in the U.S.

IR-4 is proposing the 50% WP and 4.17 lb/gal FlC formulations of
dimethomorph for up to five applications to grapes grown east of the
Rocky Mountains at 0.2 lb ai/A/application, for a maximum seasonal rate
of 1.0 lb ai/A, with a 7-day minimum RTI and a 28-day PHI. 

IR-4 submitted (in Section G of the petition) summaries of the European
grape field trial data reviewed in conjunction with PP#s 2E4054 and
7F4816 for imported grapes as well as a description of the products used
in the field trials.  Based on the product summary provided by IR-4 and
the field trial residue summaries included in the submission, six
different products were used in the European field trials:  9%, 10%, and
50% WP formulations (two of which also contained mancozeb), a 53 g/L oil
enhanced suspension concentrate formulation, a 150 g/L dispersible
concentrate (DC) formulation, and a 600 g/L FlC formulation. 
Information pertaining to inerts was provided for three of the products
(the 9% WP, 150 g/L DC, and 500 g/L FlC formulations).  IR-4 stated that
a 500 g/L FlC formulation equivalent to the 4.17 lb/gal FlC formulation
(proposed for use on grapes in the U.S.) was used in the European field
trials.  However, none of the data submitted previously reflect
application of this product, and no summary data were submitted for
field trials in which this product was used.  

A summary of the previously submitted grape residue data follows.

Ten tests were conducted between 1988 and 1990 in various regions of
France.  The 10% or 50% WP formulation was foliarly applied to grape
plants 3-9 times, with 9- to 17-day RTIs, at 0.16-0.2 lb
ai/A/application for total rates of 0.48-1.81 lb ai/A (0.5-1.8x the
maximum proposed seasonal rate for the current petition).  The 53 g/L
oil enhanced suspension concentrate formulation or 150 g/L DC
formulation was foliarly applied to grape plants 4-11 times, with 9- to
17-day RTIs, at 0.18-0.27 lb ai/A/application for total rates of
0.72-2.94 lb ai/A (0.7-2.9x).  Grapes were harvested 0-90 days following
the final application.  HED concluded that, calculating the theoretical
residue values by prorating the application rates to 1x, yielded residue
values well below 1.0 ppm, even when PHIs of 0, 7, 14, and 21 days were
used.  In field trials with a 28- or 33-day PHI, the highest theoretical
residue value obtained when the application rate was prorated to 1x was
0.64 ppm.  Residue levels did not decline substantially with increasing
harvest intervals (PP# 2E4054).

In addition, four field trials were conducted in Spain in which grapes
were harvested 30 days following the last of five applications of the
150 g/L DC formulation at rates of ~0.16 or 0.20 lb ai/A/application
(0.8x and 1x); maximum residue levels were 2.55 ppm in/on samples
treated at the 1x rate and 2.02 ppm in/on samples treated at the 0.8x
rate (PP#2E4054).

Two additional field trials were conducted in Spain in which grapes were
harvested 28 days following the last of six applications, with ~10-day
RTIs, of the 9% WP formulation at rates of 0.15-0.23 lb ai/A/application
for total rates of 1.2 1b ai/A (1.2x).  The maximum residues observed
were 0.11 ppm (PP#7F4816).  

Based on these data, including calculation of theoretical residue levels
at 1x treatment rates, HED recommended a tolerance of 3.5 ppm for
grapes.

IR-4 included crop field trial residue summary tables for European grape
data in the petition submission.  These summaries included information
on trial location, crop variety, application rate, number of
applications, PHI, and residues, but did not include information on
methods of analysis, and the data were not supported by any raw data. 
Several tables corresponded to the previously submitted data.  However,
summaries were also submitted for field trials that do not appear to
have been submitted to EPA previously.  Tables were submitted for:  

two tests in France in 1991 in which grapes were harvested 38 or 44 days
following the last of 9 or 10 applications of the 150 g/L DC formulation
at 0.300 kg ai/ha/application (0.27 lb ai/A), for total rates of 2.4 and
2.7 lb ai/A;

three tests in France from 1992 in which grapes were harvested 31-45
days following the last of 9 or 10 applications of the 150 g/L DC, 50%
WP, and 600 g/L FlC formulations (in separate tests) at 0.300 kg
ai/ha/application (0.27 lb ai/A; DC) or 0.400 kg ai/ha/application (0.36
lb ai/A; WP and FlC), for total rates of 2.4-3.6 lb ai/A;

two tests in France from 1993 in which grapes were harvested 0-27 days
following the last of 4 applications of the 9% WP formulation at 0.198
kg ai/ha/application (0.18 lb ai/A), for total rates of 0.71 lb ai/A; 

two tests in Germany from 1993 in which grapes were harvested 0-28 days
following the last of 4 applications of the 9% WP formulation at 0.198
kg ai/ha/application (0.18 lb ai/A), for total rates of 0.71 lb ai/A; 

three tests in Germany from 1993 in which grapes were harvested 0-42
days following the last of 8 applications of the 150 g/L DC formulation
at 0.121-0.288 kg ai/ha/application (0.11-0.26 lb ai/A; total rate not
reported); and

three tests in Germany from 1994 in which grapes were harvested 0-43
days following a single application of the 150 g/L DC formulation at an
unstated rate.

Residues of dimethomorph in/on grapes harvested 27-45 days posttreatment
were 0.09-1.7 ppm, with the lower residues found in/on samples receiving
4 applications.  

opean data represent application rates ≥1x the proposed maximum
seasonal rate use in the U.S., and several studies are available at the
proposed U.S. PHI of 28 days.  

The European data generally reflected applications using WP or DC
formulations.  Very few of the European studies were conducted using an
FlC formulation; only three tests were conducted (in France), and only
summary data for these tests were submitted.  However, at these three
sites, tests were conducted at the same time with three different
formulations, a WP, an FlC, and a DC formulation.  The resulting
residues at each site were very similar for the three formulations, even
though the DC formulation was applied at a lower rate (0.27 lb
ai/A/application for the DC and 0.36 lb ai/A/application for the WP and
FlC).  These data indicate that use of the FlC formulation on grapes
yields residues at the same level or lower than use of a DC formulation.
 Therefore, HED concludes that the available European data may be
translated to support use of the WP and FlC formulations on grapes grown
east of the Rocky Mountains.  

The available data will support a tolerance with regional registration
for residues of dimethomorph in/on grapes at 3.5 ppm.

Turnip greens

Residue Chemistry Memo DP# 288872, 10/9/03, M. Nelson (PP#3E6588)

No turnip green field trial data have been submitted.  The petitioner
wishes to translate data on the leafy Brassica greens, subgroup 5B, to
turnip greens.  HED has previously concluded that turnip greens will be
moved from the leaves of root and tuber vegetables crop group (group 2)
to the Brassica leafy vegetables crop group (group 5); turnip greens
will also be a member of the leafy Brassica greens subgroup.  Therefore,
crop field trial data for mustard greens as the representative commodity
of the leafy Brassica greens subgroup are sufficient to support use on
turnip greens.  

The use pattern proposed for the 50% WP and 4.17 lb/gal FlC on turnip
greens (a maximum of 5 foliar applications at 0.2 lb ai/A/application
for a total rate of 1.0 lb ai/A, and a 0-day PHI) is the same as that
registered for the leafy Brassica greens.  Adequate residue data for
mustard greens have been submitted previously (PP#3E6558).  The
available data for mustard greens reflect use of the 50% WP formulation
as multiple foliar applications at a total rate of 1.4 lb ai/A (1.4x the
registered use rate on leafy Brassica greens and the proposed use rate
on turnip greens), with 6- to 8-day RTIs and a 0-day PHI.  HED concluded
that the mustard greens data supported the use pattern proposed with the
petition:  a maximum of five applications of 50% WP formulation at 0.2
lb ai/A/application with a minimum RTI of 7 days and a 0-day PHI.  HED
also concluded that a tolerance of 20 ppm would be appropriate for leafy
Brassica greens.  The petitioner did not propose use of a FlC
formulation on mustard greens with PP#3E6558.

No field trial data were submitted to support use of the 4.17 lb/gal FlC
formulation of dimethomorph on turnip greens.  On an interim basis for a
conditional registration, these uses are supported by the European grape
field trials.  In these trials, residue levels arising from the
application of various formulations of dimethomorph to grapes were
compared.  These trials demonstrated that residues on grape were
comparable between the WP and FlC formulations.    

To support this conditional use IR-4 should submit at least two
side-by-side field trials, comparing residues from use of the WP and FlC
formulations, for turnip greens.  These side-by-side trials should
reflect application of the 4.17 lb/gal FlC formulation at 1x the
proposed maximum seasonal rate.  This commodity should be harvested at
the proposed zero-day PHI.

If these trials demonstrate that the two different formulations do not
result in comparable residues, all RACs lacking adequate residue data on
the 4.17 lb/gal FlC formulation might require a full complement of field
trials.

Until the regulations incorporating turnip greens into crop subgroup 5B
have been finalized in the Federal Register, a separate tolerance must
be established for turnip greens, at the same level as the leafy
Brassica greens tolerance.  The available data will support a tolerance
for dimethomorph at 20 ppm on turnip greens.

860.1520 Processed Food and Feed

Residue Chemistry Memo DP# 192776, 3/13/95, D. Davis (PP# 2E4054)

Residue Chemistry Memo DP#s 237101, 239372, 239899 & 242381, 5/4/00, D.
Dotson (PP# 7F4816)

HED does not require residue data for any processed commodities of lima
beans, ginseng, or turnip greens.  Processing study data for grapes were
submitted previously in conjunction with the import tolerance petitions
(PP#s 2E4054 and 7F4816).  These data indicated that dimethomorph
residues do not concentrate in grape juice but do concentrate in raisins
(average processing factor of 1.8x).  ChemSAC has concluded that residue
data for raisins are not required to support use of dimethomorph on
grapes grown east of the Rocky Mountains, as almost all raisins consumed
in the U.S. come from California (minutes of 7/12/2006 meeting). 
Therefore, no tolerances for grape processed commodities are required to
support the proposed domestic use of dimethomorph on grapes.

The existing tolerance for dimethomorph residues in raisins was
established to support use of dimethomorph on grapes grown outside the
U.S.; therefore, the tolerance should remain in 40 CFR §180.493.

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

The following analytical reference standards (and their expiration
dates) are currently available in the EPA National Pesticide Standards
Repository (personal communication with Dallas Wright, ACB, 11/14/07): 
dimethomorph (9/1/2016), dimethomorph Z isomer (9/1/2008), and
dimethomorph E isomer (7/1/2011).

The standard for dimethomorph Z isomer at the National Pesticide
Standards Repository has expired (expiration date 9/01/2008).  For the
expired standard, the registrant must either recertify the lot in the
repository and send in an updated certificate of analysis (COA), or
submit a new standard (different lot #) if the previous lot will not be
recertified.  If new COAs are being submitted, they should be faxed to
the repository at 410-305-2999.  If new standards are being submitted
they should be sent to the Analytical Chemistry Lab, which is located at
Fort Meade, to the attention of Theresa Cole at the following address:

	USEPA

	National Pesticide Standards Repository/Analytical Chemistry Branch/OPP

	701 Mapes Road

	Fort George G. Meade, MD  20755-5350

(Note that the mail will be returned if the extended zip code is not
used.)

860.1850 Confined Accumulation in Rotational Crops

Residue Chemistry Memo DP#s 251605 and 252556, 7/19/00, D. Dotson
(PP#7F4816)

An adequate confined rotational crop study with dimethomorph has been
submitted previously and reviewed by HED.  Following treatment of sandy
loam soil with [14C]dimethomorph at a total rate of 1.44-1.54 lb ai/A
(~1.4x the maximum proposed seasonal rate to annual crops), total
radioactive residues (TRR) accumulated at ≥0.01 ppm in/on the
commodities of lettuce, radish (tops and roots), wheat (forage, straw,
and grain), and soybeans (forage, straw, and seed) planted 30, 60, 181,
274, and 394 days after treatment (DAT).  Uptake and accumulation of
radioactive residues was highest in/on 30-DAT wheat straw (0.15 ppm),
30-DAT lettuce (0.09 ppm), and 30-DAT radish tops (0.07 ppm).  In
general, accumulation of radioactivity decreased with longer plantback
intervals.  At 394-DAT, total radioactive residues were 0.01-0.02 ppm
in/on all commodities.  

All mature raw agricultural commodities with TRR levels of ≥0.01 ppm
were subjected to solvent extraction and fractionation procedures.  HPLC
analysis of extractable residues identified the parent, dimethomorph, at
levels ≥0.01 ppm in/on 30-DAT lettuce, 30-DAT radish tops, and 30-DAT
wheat straw.  Dimethomorph was found at levels <0.01 ppm in/on lettuce
planted at 60 and 274 DAT, radish tops planted 30, 60, 274, and 394 DAT,
radish roots planted 60 and 274 DAT, soybean forage and straw planted
274 DAT, wheat forage planted 30, 60, and 181 DAT, and wheat straw
planted 60, 181, and 394 DAT.  The glucoside metabolite (CL 411266) and
the corresponding aglycone (CL 900986) accounted for <0.01-0.04 ppm and
<0.01-0.02 ppm in all crop samples examined, respectively.  All other
components of the residue were present at a level of <0.01 ppm.

HED concluded that the residue of concern in rotational crops is
dimethomorph per se.  Although the glucoside metabolite CL411266 was
found at higher levels than parent in some samples, its levels were low
(maximum 0.04 ppm in wheat straw).  In consideration of the nature of
this metabolite and the low dietary risk from dimethomorph, HED
concluded that CL411266 need not be analyzed in field rotational crop
studies.

860.1900 Field Accumulation in Rotational Crops

Residue Chemistry Memo DP#s 251605 and 252556, 7/19/00, D. Dotson

Residue Chemistry Memo DP# 323873, 8/05/08, D. Rate 

BASF previously submitted a limited wheat rotational field trial which
was reviewed by HED.  In the study, six rotational crop trials were
conducted in which a primary crop of potato plants was treated with
seven broadcast foliar applications, with 5- to 10-day retreatment
intervals, of the 9% WP formulation at 0.2 lb ai/A/application for a
total application rate of 1.4 lb ai/A (~1.4x the maximum proposed
seasonal rate to annual crops).  Potatoes were harvested 0, 3, and 7
days following the last application, and winter wheat was planted at a
16- to 23-day PBI.  Samples of wheat forage, hay, straw, and grain were
collected at appropriate growth stages.  Residues of dimethomorph were
below the LOQ (<0.05 ppm) in/on all samples of wheat forage and grain. 
Residues were <0.05 ppm in/on 10 out of 12 wheat hay samples and in/on 8
out of 12 wheat straw samples.  Quantifiable residues of dimethomorph
were found at 0.054 and 0.064 ppm in/on wheat hay with PBIs of 16 and 21
days, respectively.  Quantifiable residues of dimethomorph were found at
0.055 and 0.066 ppm in/on wheat straw with a 16-day PBI, and 0.079 and
0.101 ppm in/on wheat straw with a 21-day PBI.

HED concluded that the study was not adequate because of inadequate
geographic representation of data and the lack of supporting storage
stability data.  However, as the available data indicated that most
treated wheat commodity samples bore nonquantifiable residues, HED
recommended in favor of the establishment of time-limited tolerances for
the forage and grain of cereal grains at 0.05 ppm, the hay of cereal
grains at 0.1 ppm, and the fodder and straw of cereal grains at 0.15
ppm.  In addition, HED concluded that the following plantback intervals
would be appropriate for dimethomorph uses at a maximum seasonal rate of
1.0 lb ai/A:

0 months:	potatoes

1 month:	wheat, barley, oats, leafy Brassica vegetables, root/tuber,
bulb vegetables, tobacco

7 months:	alfalfa, beans, clover, corn, peas, rice, soybeans, sorghum

12 months:	all other crops

The recommended rotational crop restrictions agree with the established
rotational crop restrictions for the 50% WP formulation (see 860.1200
Directions for Use), except that several crops (tomatoes, tobacco, bulb
vegetables, cucurbit vegetables, hops, head and leaf lettuce, taro, and
leafy Brassica greens) have been added to the 0-month plantback interval
listing.  Since the time of HED’s conclusions about rotational crop
restrictions, BASF Corporation has registered uses of the 50% WP
formulation on bulb vegetables, cucurbit vegetables, fruiting
vegetables, hops, leafy Brassica greens, lettuce, taro, and tobacco. 
Therefore, it is appropriate that 0-day plantback intervals are
specified for these crops on the label for the 50% WP formulation.

Prior to establishment of permanent tolerances for rotated cereal grain
commodities, HED required two additional trials each on wheat, barley,
and oats reflecting the 30-day plantback interval.  Although the
petitioner was required to conduct two trials each with barley, oat, and
wheat, the petitioner contacted HED prior to initiation of the studies
to note that it was difficult to locate trials with the appropriate
geographic representation and timing requirements for barley and oat. 
Instead, the registrant proposed to conduct all required trials with
wheat.  This proposal was approved by HED (e-mail correspondence D.
Dotson and R. Loranger; 03/MAR/2000).  HED concluded that residue data
for rotated corn, rice, and sorghum would not be required because the
petitioner had requested a much longer PBI (7 months) for these crops. 
In addition HED required two field rotational crop trials for each of a
leafy vegetable and a root crop.  Field rotational crop data for wheat
were submitted recently and have been reviewed by ARIA (DP# 323873, D.
Rate, 9/05/2008).  ARIA has concluded that the existing data indicate
that permanent rotational crop tolerances are needed for the forage,
fodder, hay, and straw of grain, cereal group.

Field rotational crop data for a leafy vegetable and a root crop remain
outstanding.

860.1550 Proposed Tolerances

Tolerances for residues of dimethomorph are established under 40 CFR
§180.493 and are expressed in terms of dimethomorph per se.  IR-4 has
proposed the establishment of tolerances for the combined residues (free
and bound) of the fungicide dimethomorph.  The proposed tolerance
expression needs to be revised to remove reference to combined free and
bound residues.  The enforcement and data collection methods do not
include any hydrolysis steps that would release bound residues.

There are no Canadian, Mexican, or Codex MRLs established for residues
of dimethomorph in ginseng, lima beans, and turnip greens.  Codex MRLs
have been finalized (CXL) for grape and raisin at 2 and 5 ppm,
respectively.  The Codex MRLs are not harmonized with the established
U.S. tolerances for grapes and raisins, which are based on European
residue data.  Field trials in Spain included residue levels up to 2.55
ppm from the 1x rate (0.2 lb ai/A) and 2.02 ppm from the 0.8x rate.  On
this basis HED concludes that a 2 ppm tolerance, which would match the
Codex MRL, is too low.  

The tolerances proposed by IR-4 are listed in Table 6, along with the
tolerance levels recommended by HED.  Provided the proposed uses are
amended as requested, adequate field trial data are available for
ginseng, grape, lima bean, and turnip greens.  

The Agency’s Guidance for Setting Pesticide Tolerances Based on Field
Trial Data was utilized for determining appropriate tolerance levels for
lima beans and ginseng; see Appendix I for tolerance calculations. 
Based on these calculations, the proposed tolerance for lima beans (0.60
ppm) is adequate, but the proposed tolerance for ginseng is too low; a
revised tolerance of 0.90 ppm needs to be proposed for ginseng.  Because
use on lima beans is to be restricted to areas east of the Rocky
Mountains, the lima bean tolerance must be established under 180.493(c)
for tolerances with regional registration.

The available European field trial data are adequate to support the
proposed use on grapes grown east of the Rocky Mountains.  No change in
the established tolerance level for grapes is necessary; however, the
tolerance must be moved to 180.493(c) for tolerances with regional
registration.

The proposed tolerance for turnip greens (20 ppm) is adequate, as the
turnip greens tolerance is to be set at the same level at the existing
tolerance for dimethomorph residues in/on leafy Brassica greens.

The proposed tolerances should be revised to reflect the recommended
tolerance levels and correct commodity definitions as specified in Table
6.  

Table 6. 	Tolerance Summary for Dimethomorph.

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

Tolerances established or to be listed under 40 CFR §180.493(a):

Ginseng	--	0.85	0.90	Ginseng

Grape	3.51	3.5	Move to 180.493(c)	Because use is to be restricted to
areas east of the Rocky Mountains, tolerance must be established with
regional registration.  Footnote on tolerance should be removed.

Grape

Grape, raisin	6.01	6	6.01	Footnote 1 to 40 CFR §180.493(a) should be
amended to state “There are no U.S. registrations as of XX 2008, for
the use of dimethomorph on grapes grown for raisin production.”

Grape, raisin

Turnip, greens 	--	20	20.0	Turnip, tops

Tolerances to be listed under 40 CFR §180.493(c):

Bean, lima	--	0.6	0.60	Because use is to be restricted to areas east of
the Rocky Mountains, tolerance must be established with regional
registration.

Bean, lima, succulent

Grape	[3.51]	3.5	3.5	Because use is to be restricted to areas east of
the Rocky Mountains, tolerance must be established with regional
registration.  

Grape

1  This tolerance was established as an import tolerance.

References

DP#:	192776

Subject:	PP#2E4054.  Dimethomorph
(4-[3-(4-chlorophenyl)-3-(3,4-dimethoxyphenyl)-1-oxo-2-propenyl]
morpholine) in/on Grapes, Potatoes, Animal Tissues and Milk.  Review of
Plant and Animal Metabolism Data, Analytical Methods, Crop Field Trials,
Ruminant Feeding Study Data and Storage Stability Data to Support the
Establishment of an Import Tolerance for a New Chemical.  CBTS No.:
12143.

From:	C. Eiden

To:	K. Scanlon/L. Cole and B. Madden/J. Smith

Date:	3/13/95

MRIDs:	42233935-42233956, 42302202, 42542301, and 42628302

DP#:	219530

Subject:	PP#2E4054.  Dimethomorph
(4-[3-(4-chlorophenyl)-3-(3,4-dimethoxyphenyl)-1-oxo-2-propenyl]
morpholine) in/on Grapes, Potatoes, Animal Tissues and Milk.  Import
Tolerance for a New Chemical.  Petition Status Update. CBTS No:  16233

From:	C. Eiden

To:	J. Tompkins/C. Welch and B. Madden/K. Whitby

Date:	10/31/95

MRIDs:	None

DP#s:	226315 and 227506

Subject:	PP#2E4054. Dimethomorph.  Registrant Response to Requirements
for Import Tolerances on Grapes and Potatoes and a Section 3
Registration for Potatoes for a New Chemical.  Product Chemistry  (GLNs:
61 & 62 Series), Plant Analytical Method (GLN: 171-4(c)), Residue Field
Trials/Processing Study (GLN 171-4(k & l)) & Confined Rotational Crops
(165-1).   Chemical No. 268800.  CBRS Nos. 17208 & 17336.

From:	C. Eiden

To:	P. Deschamp

Date:	8/2/96

MRIDs:	43909101-43909104, 43917201-43917204, 43970301-43970303, and
43917240  

DP#s:	237101, 239372, 239899, and 242381

Subject:	Tolerance Petitions for the Use of Dimethomorph on Domestic and
Imported Tomatoes, Imported Grapes, and Imported Hops Evaluation of
Residue Chemistry and Analytical Methodology; PP#s:  7F4816 (Grapes) and
8F4946 (Tomatoes and Hops)

From:	D. Dotson

To:	M. Waller/T. Stowe

Date:	5/4/00

MRIDs:	44271201, 44271202, 44388001, 44348901, 44457602-44457607, and
44993001

DP#s:	251605 and 252556

Subject:	Tolerance Petition for the Use of Dimethomorph on the Cereal
Grains Crop Group (Rotational Crops); Evaluation of Rotational Crop Data
and Analytical Methodology; Petition Number 7F4816.

From:	D. Dotson

To:	M. Waller

Date:	7/19/00

MRIDs:	43917240, 44678602, 44678603, 44717401, 44717402, 44746601

DP#:	288872

Subject:	Dimethomorph.  Residue Chemistry Summary Document for: 
PP#2E6483  Fruiting Vegetables (except cucurbits), Crop Group 8 and PP#
3E6588  Leafy Brassica Greens (Crop Subgroup 5B), Taro and Tanier..

From:	M. Nelson

To:	S. Brothers/R. Forrest

Date:	10/9/03

MRIDs:	44721201, 45872001, 45872002

DP#:	316328

Subject:	Dimethomorph.  Head and Stem Brassica Vegetables (Crop Subgroup
5A).  Summary of Analytical Chemistry and Residue Data.  Petition Number
4E6848.

From:	W. Cutchin

To:	B. Madden/D. Rosenblatt

Date:	7/18/05

MRIDs:	46318601-46318603

DP#:	323873

Subject:	Dimethomorph.  Data Submitted to Fulfill Conditions of
Registration for Acrobat MZ® (EPA Reg. No. 241-383) and Acrobat® 50WP
(EPA Reg. No. 241-410).  Summary of Analytical Chemistry and Residue
Data for Rotated Crops.

From:	D. Rate

To:	M. Waller/C. Grable

Date:	8/05/2008

MRIDs:	46291302, 46291303, 46291305-46291308, 46323501, 46323502

  SEQ CHAPTER \h \r 1 Attachments:  

International Residue Limit Status sheet

Appendix I - Tolerance Assessment Calculations



INTERNATIONAL RESIDUE LIMIT STATUS

Chemical Name:  (E,Z)
4-[3-(4-chlorophenyl)-3-(3,4-dimethoxyphenyl)-1-oxo-2-propenyl]morpholin
e	Common Name:

Dimethomorph	X Recommended tolerance

( Reevaluated tolerance

( Other	Date: 3/27/08

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

X No Codex proposal step 6 or above

( No Codex proposal step 6 or above for the crops requested	Petition
Number:  PP#8E7314

DP#:  349735

Other Identifier:  Decision No. 388342

Residue definition (step 8/CXL): dimethomorph (at Step 8/CXL)
Reviewer/Branch:  A. Parmar/RAB2

	Residue definition:  Residue definition:  Dimethomorph per se

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

Broccoli	1 (CXL)	Bean, lima 	0.6

Cabbages, Head	2 (CXL)	Ginseng 	0.9

Grape	2 (CXL)	Grape 	3.5

Grape, dried (raisin)	5 (CXL)	Grape, raisin 	6.0

Chilli peppers, dried	5 (CXL)	Turnip, greens	20.0

Corn salad	10 (CXL)



Eggs	0.01 (CXL)



Fruiting Vegetables, other than cucurbits	1 (CXL)



Fruiting Vegetables, Cucurbits	0.5 (CXL)



Hops, Dry	80 (CXL)



Kohlrabi 	0.02 (CXL)



Lettuce, Head	10 (CXL)



Meat, except marine	0.01  (CXL)



Milk	0.01 (CXL)



Pineapple	0.01  (CXL)



Potato	0.05  (CXL)



Poultry Meat	0.01 (CXL)



Strawberry	0.05 (CXL)



Limits for Canada	Limits for Mexico

( No Limits

X No Limits for the crops requested	( No Limits

X No Limits for the crops requested

Residue definition: 
(E,Z)-4-[3-(4-chlorophenyl)-3-(3,4-dimethoxyphenyl)-1-oxo-2-propenyl]mor
pholine 	Residue definition:  Dimetomorf

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





	Appendix I.  Tolerance Assessment Calculations.

e 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% upper confidence limit 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.

Bean, lima, green

The dataset used to establish a tolerance for dimethomorph on lima bean
succulent seed consisted of field trial data representing application
rates of 1.41-1.63 lb ai/A (7-8 applications at ~0.2 lb
ai/A/application) with a 0-day PHI.  The PHIs are within 25% of the
minimum label PHI, but the total application rates are 40-60% higher
than the maximum proposed seasonal application rate for lima bean.  The
petitioner did not submit any field trial data reflecting field trial
application rates within 25% of the maximum label application rate.  The
residue values that were entered into the tolerance spreadsheet are
provided in Table I-1.

-

$

%

.

L

M

O

x

y

{

Ÿ

¤

©

Á

!

$

%

M

y

 

£

¤

î

㄀Ĥ摧绻wጀÁ

Â

Ö

Ø

ì

í

ð

t

“

”

•

¦

¨

©

½

¾

 h

 h

”

•

§

¨

@

 h+

h

 h+

h

h

 h+

 h+

 h+

h+

 h+

h.

 h+

ㄊĤ摧巼

h*

h*

h*

hÈ

hÈ

hÈ

hÈ

hÈ

hÈ

hÈ

hÈ

hÈ

  h

h

hÈ

hÈ

hÈ

hÈ

hÈ

hÈ

혈Fᴃ⼋괛$휆

hÈ

hÈ

hÈ

hÈ

hÈ

hÈ

hÈ

$

@

@

@

@

@

@

@

@

ഀ׆Ā褐ༀ炄ᄈ還ㇷĤ葞ࡰ葠摧绻w
ԀĤ␆ഁ׆Ā褐ༀ炄ᄈ還ㇷĤ葞ࡰ葠摧绻w

ሀĀ㄀Ĥ摧绻w

ሀĀ㄀Ĥ摧绻w

hW@

㄀Ĥ摧绻w

㄀Ĥ摧绻w

 h

h·

ഀ׆Ā褐ༀ킄㄂Ĥ葞ː摧绻w

 h§

  hÈ

hÈ

h

  hÈ

h

  hÈ

  hÈ

  hÈ

  hÈ

h

  hÈ

  hÈ

攃昀Ĵ瑹䂳©܀

  hÈ

  hÈ

  hÈ

hÈ

hÈ

hÈ

hÈ

hÈ

hÈ

ഀ׆Ā֠ༀꂄᄅ悄ㇺĤ葞֠葠褐摧绻w
ԀĤ␆ഁ׆Ā֠ༀꂄᄅ悄ㇺĤ葞֠葠褐摧绻w

¾

hÈ

h

hÈ

hÈ

 

°

¾

Ì

 

!

E

F

R

ì

	

	

 

 

(

D

E

F

K

R

[

x

€

ì

h

h

h

h

hÈ

hÈ

hÈ

h

3ì

ý

ഀ׆Ā褐㄀Ĥ摧绻w

ԀĤ␆ഁ׆Ā褐㄀Ĥ摧绻w	ԀĤ␆㄁Ĥ摧绻w

$

  hÈ

LOQ (LOQ = 0.01 ppm).  The lima bean dataset was small (14 samples). 
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 assumption of lognormality should be rejected.

Using the tolerance spreadsheet, the recommended tolerance is 0.60 ppm
for lima bean succulent seed.

Table I-1.	Residue data used to calculate tolerance for residues of
dimethomorph on lima bean succulent seed.

Regulator:	EPA

Chemical:	Dimethomorph

Crop:	Lima bean

PHI:	0 days

App. Rate:	1.41-1.63 lb ai/A

Submitter:	IR-4

MRID Citation:	MRID 47317202

	Residues of Dimethomorph (ppm)

	0.48

	0.45

	0.03

	0.03

	0.11

	0.09

	0.21

	0.21

	0.03

	0.03

	0.05

	0.03

	0.03

	0.03



Figure I-1.  Lognormal probability plot of dimethomorph field trial data
for lima bean succulent seed.

Figure I-2.  Tolerance spreadsheet summary of dimethomorph field trial
data for lima bean succulent seed.

Ginseng

The dataset used to establish a tolerance for dimethomorph on ginseng
consisted of field trial data representing application rates of
1.40-1.44 lb ai/A (7 foliar broadcast applications at ~0.2 lb
ai/A/application) and 1.68 lb ai/A (7 drip irrigation applications at
~0.2 lb ai/A/application), with a 13- to 15-day PHI.  The field trial
PHIs are within 25% of the minimum label PHI, but the total rates are
40-70% higher than the maximum proposed seasonal rate for ginseng.  The
petitioner did not submit any field trial data reflecting field trial
application rates within 25% of the maximum label application rate.  The
residue values that were entered into the tolerance spreadsheet are
provided in Table I-2.

All field trial sample results for dimethomorph in/on ginseng were above
the LOQ (LOQ = 0.05 ppm).  The ginseng dataset was small (8 samples). 
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 ginseng dataset was reasonably lognormal.  

Using the tolerance spreadsheet, the recommended tolerance is 0.90 ppm
for ginseng.

Table I-2.	Residue data used to calculate tolerance for residues of
dimethomorph on ginseng.

Regulator:	EPA

Chemical:	Dimethomorph

Crop:	Ginseng

PHI:	13-15 days

App. Rate:	1.40-1.68 lb ai/A

Submitter:	IR-4

MRID Citation:	MRID 47317201

	Residues of Dimethomorph (ppm)1

	0.62

	0.60

	0.43

	0.41

	0.28

	0.27

	0.29

	0.27

1  Residues from the drip irrigation trial are presented in bold.

Figure I-3.  Lognormal probability plot of dimethomorph field trial data
for ginseng.

Figure I-4.  Tolerance spreadsheet summary of dimethomorph field trial
data for ginseng.

Page   PAGE  1  of   NUMPAGES  30 

Dimethomorph	Summary of Analytical Chemistry and Residue Data	DP#: 
349735

