UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF           

PREVENTION, PESTICIDES,

AND TOXIC SUBSTANCES

MEMORANDUM

Date:		22-JUL-2009

Subject:	Saflufenacil in/on Legume Vegetables (group 06), the Foliage of
Legume Vegetables (group 07), Citrus Fruits (group 10), Pome Fruits
(group 11), Stone Fruits (group 12), Tree Nuts (group14), Pistachio,
Cereal Grains (group 15), Forage, Fodder and Straw of Cereal Grains
(group 16), Sorghum Stover, Undelinted Cotton Seed, Cotton Gin
Byproducts, Grapes, Pistachio, Almond Hulls, Sunflower Seed, and
Livestock Commodities.  Summary of Analytical Chemistry and Residue
Data.

 

PC Code:  118203	DP Barcodes:  D349938, D350198, D354472

Decision No.:  389161	Registration Nos.:  7969-ETA, 7969-ETI, 7969-ETO,
7969-EIN

Petition No.:  8F7322	Regulatory Action:  Sec. 3 Registration

Risk Assessment Type:  NA	Case No.:  NA

TXR No.:  NA	CAS No.:  372137-35-4

MRID Nos.:  471280-01 thru -21, 471282-22 thru -33, 474459-02 thru -05,
47523801, 47796103, 47796104	40 CFR:  §180.xxx



From:		George F. Kramer, Ph.D., Senior Chemist

		Risk Assessment Branch 1 (RAB1)

		Health Effects Division (HED) (7509P)

Through:		Dana M. Vogel, Branch Chief

		RAB1/HED (7509P)

To:	       Kathryn Montague/Joanne Miller, PM Team 23

Registration Division (RD; 7505P)

Executive Summary

Saflufenacil (BAS 800 H) is a broad-spectrum herbicide developed by
BASF.  It belongs to the herbicide mode-of-action Group 14 (cell
membrane disruptors).  Saflufenacil acts through the inhibition of
protoporphyrinogen oxidase (PPO), resulting in cell membrane damage and
subsequent plant death.  There are currently no registrations for
saflufenacil in the U.S.  Saflufenacil is being evaluated as part of a
trilateral joint review with Canada and Australia.

BASF has submitted draft labels for the 2.85 lb ai/gal
suspension-concentrate (SC) formulation (BAS 800 04H FiRoCrop Herbicide;
EPA Reg. 7969-ETI), the 70% ai wettable-granule (WG) formulation (BAS
800 01H TNV Herbicide; EPA Reg. No. 7969-ETA), the 0.57 lb ai/gal
emulsifiable-concentrate (EC) formulation (BAS 781 02H Herbicide; EPA
Reg. 7969-ETO), and the 17.8% WG formulation (BAS 804 00H LegVeg
Herbicide; EPA Reg. 7969-EIN) for use on legume vegetables, citrus
fruit, pome fruit, stone fruit, tree nuts, cereal grains, cotton,
sunflowers, and grapes.  This registration request represents the first
food use for this herbicide.  The end-use products are proposed for a
preplant/preemergence spray application at 0.011-0.134 lb
ai/A/application (legume vegetables, cereal grains, cotton); for
postemergence-directed spray applications at 0.022-0.044 lb
ai/A/application to weeds in orchards/vineyards (citrus fruit, pome
fruit, stone fruit, tree nuts, grapes); and for 2 foliar spray
applications at 0.0225-0.045 lb ai/A/application as a harvest aid
(sunflowers).  Applications may be made using ground or aerial
equipment, and use of an adjuvant is required.  Preharvest intervals
(PHIs) of 0-7 days are proposed.

Concurrently, BASF has submitted a petition for the establishment of
permanent tolerances for “the combined residues of saflufenacil
(N'-[2-chloro-4-fluoro-5-(3-methyl-2,6-dioxo-4-(trifluoromethyl)-3,6-dih
ydro-1(2H)-pyrimidinyl)benzoyl]-N-isopropyl-N-methylsulfamide) plus
metabolites M800H11
(N-[2-chloro-5-(2,6-dioxo-4-(trifluoromethyl)-3,6-dihydro-1(2H)-pyrimidi
nyl)-4-fluorobenzoyl]-N'-isopropylsulfamide) and M800H35
(N-[4-chloro-2-fluoro-5-({[(isopropylamino)sulfonyl]amino}carbonyl)pheny
l]urea),” in/on the following raw agricultural commodities (RACs):

Vegetable, legume, group 06	0.03 ppm

Vegetable, foliage of legume, group 07	0.1 ppm

Fruit, citrus, group 10	0.03 ppm

Fruit, pome, group 11	0.03 ppm

Fruit, stone, group 12	0.03 ppm

Nut, tree, group 14	0.03 ppm

Almond, hulls	0.2 ppm

Grain, cereal, group 15	0.03 ppm

Grain, cereal, forage, fodder and straw group 16	0.1 ppm

Sorghum stover	0.1 ppm

Cotton, undelinted seed	0.03 ppm

Cotton, gin byproducts	0.03 ppm

Sunflower, seed	0.7 ppm

Grape	0.03 ppm

Animal - Kidney	0.02 ppm

Animal - Liver	0.8 ppm



The nature of the residue in plants (resulting from
preplant/preemergence application), rotational crops, and livestock is
adequately understood based on acceptable metabolism studies conducted
on corn, soybean, tomato, rotational crops, lactating goats, and laying
hens.  A waiver request for a sunflower (postemergence) metabolism study
was approved.

In plants, the main reactions involved in the metabolic pathway of
saflufenacil are N-demethylation at the uracil ring, stepwise
degradation (N-dealkylation) of the N-methyl-N-isopropyl group,
hydrolytic cleavage of the uracil ring generating a urea side chain, and
hydroxylation of the phenyl ring.  M800H11 was found in all corn and
soybean matrices from both 14C-labeled uracil and 14C-labeled phenyl
saflufenacil.  M800H11 is formed when saflufenacil undergoes
demethylation at both nitrogen atoms.  M800H35 was detected only after
14C-labeled phenyl saflufenacil treatment and was detected at higher
levels in soybean matrices.  M800H35 is formed when parent saflufenacil
undergoes demethylation at the sulfonylurea side chain and cleavage of
the uracil ring.  The HED Residues of Concern Knowledgebase Subcommittee
(ROCKS) determined that residues of concern for the tolerance expression
and risk assessment consist of saflufenacil, M800H11, and M800H35 (Memo,
B. Daiss, 1/6/09; D359645).  This conclusion applies only to
preplant/preemergence and sunflower harvest-aid uses.

The metabolism of saflufenacil in rotational crops appears to be
consistent with the pathway observed in the plant metabolism studies. 
The residues of concern for rotational crops are saflufenacil, M800H11,
and M800H35 (Memo, B. Daiss, 1/6/09; D359645).  Unless the petitioner
requests plantback intervals (PBIs) shorter than 4 months, no additional
data are required, and tolerances for inadvertent residues in/on
rotational crops need not be established in conjunction with the
currently proposed uses.

In livestock, saflufenacil was metabolized by several dealkylation steps
occurring at two different sites in the molecule
(N-isopropyl-N-methylsulfamide side chain and at the uracil ring) and
via hydrolytic opening of the uracil ring (goat only).  In the ruminant
metabolism study, saflufenacil was a major residue in all matrices. 
M800H04, a ring opening product, was the only significant metabolite
found (liver).  In the poultry metabolism study, saflufenacil was a
major residue in all matrices and no significant metabolites were found.
 The HED ROCKS determined that saflufenacil per se is the only residue
of concern in livestock for the tolerance expression and risk assessment
(Memo, B. Daiss, 1/6/09; D359645).  

The petitioner has submitted two liquid chromatography/mass
spectroscopy/mass spectroscopy (LC-MS/MS) analytical methods for the
determination of residues of the parent and its metabolites in/on plant
and livestock commodities.  BASF Method D0603/02 was developed for
determination of residues of saflufenacil and its metabolites M800H11
and M800H35 in different plant matrices using LC-MS/MS.  The limit of
quantitation (LOQ) was 0.01 ppm for each analyte in food matrices (human
consumption) and 0.025 ppm for each analyte in feed matrices (livestock
consumption).  BASF analytical Method No. L0073/01 was developed for
determination of saflufenacil (BAS 800 H) in livestock matrices using
LC-MS/MS.  The LOQ was 0.01 ppm in all matrices.  These methods were
used as the data-collection methods in the analysis of samples for
residues of concern from the various studies associated with the current
petition.  Each method has been adequately validated by the petitioner
as well as by independent laboratories.  Method No. L0073/01 was also
adequately radiovalidated using weathered samples obtained from
metabolism studies.

HED has determined that Methods D0603/02 and L0073/01 are suitable
enforcement methods for plant and livestock commodities, respectively,
as defined in Standard Operating Procedure (SOP) No. ACB-019 (9/15/08). 


The submitted magnitude of the residue data for the raw and processed
commodities of legume vegetables, citrus fruit, pome fruit, stone fruit,
tree nuts, cereal grains, cotton, sunflowers, and grapes are adequate. 
There are also adequate storage stability data to validate the storage
conditions and intervals of samples collected from the field and
processing trials.  As no concentration of the total saflufenacil
residue was found in any processed commodity, separate tolerances for
residues in/on processed commodities are not required.

An adequate dairy cow feeding study has been submitted; this study is
acceptable for determining tolerance levels for ruminant commodities. 
Based on the submitted data, HED has concluded that the tolerances,
expressed as saflufenacil per se, are required for ruminant commodities.
 Based on the results of the laying hen metabolism study and the
proposed tolerances in poultry feed components, there is no reasonable
expectation of finite residues of saflufenacil in the meat, meat
byproducts, and eggs of poultry as a result of the proposed uses.

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

Pending submission of revised Sections B and F (see requirements under
Directions for Use and Proposed Tolerances), and the submission of
reference standards for the saflufenacil metabolites (see requirements
under Submittal of Analytical Reference Standards); there are no residue
chemistry issues that would preclude granting an unconditional
registration for the use of saflufenacil on the requested crops.  

The proposed uses and the submitted data support:  “Tolerances are
established for residues of saflufenacil, including its metabolites and
degradates, in or on the commodities in the table below.  Compliance
with the tolerance levels specified below is to be determined by
measuring only the sum of saflufenacil
(2-chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-py
rimidinyl]-4-fluoro-N-[[methyl(1-methylethyl)amino]sulfonyl]benzamide)
and its metabolites
N-[2-chloro-5-(2,6-dioxo-4-(trifluoromethyl)-3,6-dihydro-1(2H)-pyrimidin
yl)-4-fluorobenzoyl]-N'-isopropylsulfamide and
N-[4-chloro-2-fluoro-5-({[(isopropylamino)sulfonyl]amino}carbonyl)phenyl
]urea, calculated as the stoichiometric equivalent of saflufenacil, in
or on the commodities.”

Vegetable, legume, group 6	0.03 ppm

Vegetable, foliage of legume, group 7	0.10 ppm

Fruit, citrus, group 10	0.03 ppm

Fruit, pome, group 11	0.03 ppm

Fruit, stone, group 12	0.03 ppm

Nut, tree, group 14	0.03 ppm

Pistachio	0.03 ppm

Almond, hulls	0.10 ppm

Grain, cereal, group 15	0.03 ppm

Grain, cereal, forage, fodder and straw group 16	0.10 ppm

Cotton, undelinted seed	0.03 ppm

Cotton, gin byproducts	0.10 ppm

Sunflower, seed	1.0 ppm

Grape	0.03 ppm



The proposed uses and the submitted data also support:  “Tolerances
are established for residues of saflufenacil, including its metabolites
and degradates, in or on the commodities in the table below.  Compliance
with the tolerance levels specified below is to be determined by
measuring only saflufenacil,
2-chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-pyr
imidinyl]-4-fluoro-N-[[methyl(1-methylethyl)amino]sulfonyl]benzamide, in
or on the commodities.”

Milk	0.01 ppm

Cattle, meat	0.01 ppm

Cattle, fat	0.01 ppm

Cattle, liver	0.80 ppm

Cattle, meat byproducts, except liver	0.02 ppm

Goat, meat	0.01 ppm

Goat, fat	0.01 ppm

Goat, liver	0.80 ppm

Goat, meat byproducts, except liver	0.02 ppm

Hog, meat	0.01 ppm

Hog, fat	0.01 ppm

Hog, liver	0.80 ppm

Hog, meat byproducts, except liver	0.02 ppm

Sheep, meat	0.01 ppm

Sheep, fat	0.01 ppm

Sheep, liver	0.80 ppm

Sheep, meat byproducts, except liver	0.02 ppm

Horse, meat	0.01 ppm

Horse, fat	0.01 ppm

Horse, liver	0.80 ppm

Horse, meat byproducts, except liver	0.02 ppm



860.1200 Directions for Use

The BAS 800 04H FiRoCrop Herbicide contains directions for use on
varieties of forage sorghum.  However, forage sorghum is a member of the
grass crop group, for which no data were submitted or tolerances
proposed.  The BAS 800 04H FiRoCrop Herbicide label should thus be
amended to limit the sorghum use to sweet and grain varieties only.

All of the sunflower field trials were performed with a WG formulation;
whereas, the proposed use is for the SC formulation.  These formulation
types are not considered to be equivalent for mid- to late-season foliar
applications.  The proposed sunflower use should thus be removed from
the BAS 800 04H FiRoCrop Herbicide (SC) label and may be added to the
BAS 800 01H TNV Herbicide (WG) label.  Alternatively, bridging trials
could be performed to determine the effect of the formulation type on
residue levels.  

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

Analytical standards for of saflufenacil, M800H11, and M800H35 are
currently available in the National Pesticide Standards Repository
[Source:  personal communication with T. Cole of the Analytical
Chemistry Laboratory/Biological and Economics Analysis Division
(ACL/BEAD), 1/15/09].  However, since the standards for M800H11 and
M800H35 expired on 10/1/08, the petitioner is requested to provide a new
supply to the Repository.  

860.1550 Proposed Tolerances

The petitioner is requested to submit a revised Section F specifying the
following:  

The tolerance expression for plant commodities should be revised to: 
“Tolerances are established for residues of saflufenacil, including
its metabolites and degradates, in or on the commodities in the table
below.  Compliance with the tolerance levels specified below is to be
determined by measuring only the sum of saflufenacil
(2-chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-py
rimidinyl]-4-fluoro-N-[[methyl(1-methylethyl)amino]sulfonyl]benzamide)
and its metabolites
N-[2-chloro-5-(2,6-dioxo-4-(trifluoromethyl)-3,6-dihydro-1(2H)-pyrimidin
yl)-4-fluorobenzoyl]-N'-isopropylsulfamide and
N-[4-chloro-2-fluoro-5-({[(isopropylamino)sulfonyl]amino}carbonyl)phenyl
]urea, calculated as the stoichiometric equivalent of saflufenacil, in
or on the commodities.”

The tolerance expression for livestock commodities should be revised to:
 “Tolerances are established for residues of saflufenacil, including
its metabolites and degradates, in or on the commodities in the table
below.  Compliance with the tolerance levels specified below is to be
determined by measuring only saflufenacil,
2-chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-pyr
imidinyl]-4-fluoro-N-[[methyl(1-methylethyl)amino]sulfonyl]benzamide, in
or on the commodities.”

Revised tolerance levels and commodity definitions are presented in
Table 35 (summarized above).

A human-health risk assessment is forthcoming in a separate document.

Background

Saflufenacil is a broad-spectrum herbicide developed by BASF.  It
belongs to the herbicide mode-of-action Group 14 (cell membrane
disruptors).  Saflufenacil acts through the inhibition of PPO, resulting
in cell membrane damage and subsequent plant death.  Susceptible weeds
develop symptoms within hours of application under active growing
conditions.  Plant death occurs within 3-5 days depending upon growing
conditions.  The chemical structure and nomenclature of saflufenacil and
its metabolites M800H11 and M800H35, and the physicochemical properties
of the technical grade of saflufenacil, are presented in Tables 1 and 2.

TABLE 1.  Saflufenacil and Metabolite Nomenclature.

Chemical Structure	

Common name	Saflufenacil

Company experimental name	BAS 800 H (synonyms:  AC 433 379, BASF Reg.
No. 4054449)

IUPAC name
N'-[2-Chloro-4-fluoro-5-(3-methyl-2,6-dioxo-4-(trifluoromethyl)-3,6-dihy
dro-1(2H)-pyrimidinyl)benzoyl]-N-isopropyl-N-methylsulfamide

CAS name
2-Chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-pyr
imidinyl]-4-fluoro-N-[[methyl(1-methylethyl)amino]sulfonyl]benzamide

CAS registry number	372137-35-4

End-use product (EP)	BAS 800 00H (70% WG formulation)

Chemical Structure	

Common name	M800H11

Chemical name
N-[2-Chloro-5-(2,6-dioxo-4-(trifluoromethyl)-3,6-dihydro-1(2H)-pyrimidin
yl)-4-fluorobenzoyl]-N'-isopropylsulfamide

Chemical Structure	

Common name	M800H35

Chemical name
N-[4-Chloro-2-fluoro-5-({[(isopropylamino)sulfonyl]amino}carbonyl)phenyl
]urea



TABLE 2.  Physicochemical Properties of Technical Grade Saflufenacil.

Parameter	Value

Melting point	Average = 189.9 °C, peak max = 193.4 °C

pH	4.43 of 1% solution at 25 °C

Bulk Density (ambient temp.)	0.661 kg/L (free fall), 0.736 kg/L (packed)

Water solubility (20°C)	in g/100-mL:

0.0025 in water (pH = 5); 0.0014 in pH 4 buffer; 0.21 in pH 7 buffer;
not determined due to degradation in pH 9 buffer

Solvent solubility (20°C)	in g/100-mL: 

19.4 acetonitrile; 24.4 dichloromethane; 55.4 N,N-dimethylformamide;
27.5 acetone; 6.55 ethyl acetate; 36.2 tetrahydrofuran; 35.0
butyrolactone; 2.98 methanol; 0.25 isopropyl alcohol;

0.23 toluene; <0.01 1-octanol; <0.005 n-heptane

Vapor pressure at 20/25°C	20° C = 4.5 x 10-15 Pa

wavelength maximum:  λmax = 271.6 nm

extinction coefficient:  ε = 9709 L/mol-cm

Reference:  BASF Registration Document Number (DocID) 2005/1026464.

860.1200 Directions for Use

BASF has submitted draft labels dated 1/31/08 for the 2.85 lb ai/gal SC
formulation (BAS 800 04H FiRoCrop Herbicide; EPA Reg. 7969-ETI), for the
70% ai WG formulation (BAS 800 01H TNV Herbicide; EPA Reg. No.
7969-ETA), the 0.57 lb ai/gal EC formulation (BAS 781 02H Herbicide; EPA
Reg. 7969-ETO), and the 17.8% WG formulation (BAS 804 00H LegVeg
Herbicide; EPA Reg. 7969-EIN).  Information pertaining to the proposed
end-use product is listed in Table 3.  A summary of the proposed use
patterns on legume vegetables, citrus fruit, pome fruit, stone fruit,
tree nuts, cereal grains, cotton, sunflowers, and grapes is detailed in
Table 4.  

Table 3.  Summary of Proposed End-Use Products.

Trade Name	Reg. No.	ai (% of formulation)	Formulation Type	Target Crops
Target Pests	Label Date

BAS 800 04H FiRoCrop Herbicide 	7969-ETI	29.74	SC	legume vegetables,
cereal grains, cotton, sunflowers	Broadleaf weeds	Draft labels submitted
1/31/08

BAS 800 01H TNV	7969-ETA	70.0	WG	citrus fruit, pome fruit, stone fruit,
tree nuts, grapes



BAS 781 02H Herbicide	7969-ETO	6.24 + 55.04% dimethenamid	EC	corn, grain
sorghum



BAS 804 00H LegVeg Herbicide 	7969-EIN	17.8 + 50.2% imazethapyr	WG
legume vegetables, corn





Table 4.  Summary of Directions for Use of Saflufenacil.

Applic. Timing, Type, and Equip.	Formulation

[EPA Reg. No.]	App. ate

(lb ai/acre)	Max. No. App. per Season	Max. Seasonal App. Rate

(lb ai/acre)	PHI

(days)	Use Directions and Limitations

Corn, Sorghum, Small Grains

Preplant/

Preemergent 

Broadcast,

Ground or aerial	BAS 800 04H FiRoCrop Herbicide

2.85 lb/gal SC

[7969-ETI]	0.0225-0.134	Not specified	0.134	80 (forage, silage)
Applications are to be made in ≥3 gal/acre using ground or aerial
equipment.  

Legumes

Preplant/

Preemergent 

Broadcast,

Ground or aerial	BAS 800 04H FiRoCrop Herbicide

2.85 lb/gal SC

[7969-ETI]	0.011-0.089	Not specified	0.089	Not specified	Applications
are to be made in ≥3 gal/acre using ground or aerial equipment.  

Cotton

Preplant/

Preemergent 

Broadcast,

Ground or aerial	BAS 800 04H FiRoCrop Herbicide

2.85 lb/gal SC

[7969-ETI]	0.045	Not specified	0.045	Not specified	Applications are to
be made in ≥3 gal/acre using ground or aerial equipment.  

Citrus, Pome, & Stone Fruit; Tree Nuts

Post, Directed to Orchard Floor

	BAS 800 01H TNV Herbicide

30% WG

[7969-ETA]	0.022-0.044	3	0.131	7 (nuts)

0 (fruit)	Applications are to be made in ≥10 gal/acre using ground
equipment.  

Grapes

Post, Directed to Vineyard Floor

	BAS 800 01H TNV Herbicide

30% WG

[7969-ETA]	0.022	3	0.066	0	Applications are to be made in ≥10 gal/acre
using ground equipment.  

Sunflower

Preharvest

Dessication 

Broadcast,

Ground or aerial	BAS 800 04H FiRoCrop Herbicide

2.85 lb/gal SC

[7969-ETI]	0.0225-0.045	2	0.090	7	Applications are to be made in ≥3
gal/acre using ground or aerial equipment.  

Note:  Use of an adjuvant is required for burndown application to
emerged weeds or sunflower.

Table 5.  Rotational Crop PBIs for Saflufenacil.

Crop	PBI (months)

	Application rate (lb ai/acre)

	0.0225	0.045	0.067	0.089	0.112	0.134

Corn	0	0	0	0	0	0

Sorghum	0	0	0	0	0	0

Small Grains	0	0	0	0	3	3

Chickpea

Field Pea	0	0	3	3	6	6

Lentil	0	2	3	3	6	9

Soybean	1	2	4	4	6	6

Cotton	1	3	4	6	6	9

Other Crops	4	4	6	6	6	9



Conclusions:  The submitted use directions for BAS 800 04H FiRoCrop
Herbicide, BAS 800 01H TNV Herbicide, BAS 781 02H Herbicide, and BAS 804
00H LegVeg Herbicide are adequate to allow evaluation of the residue
data relative to the proposed use.  The BAS 800 04H FiRoCrop Herbicide
contains directions for use on varieties of forage sorghum.  However,
forage sorghum is a member of the grass crop group, for which no data
were submitted or tolerances proposed.  The BAS 800 04H FiRoCrop
Herbicide label should thus be amended to limit the sorghum use to sweet
and grain varieties only.  Additionally, all of the sunflower field
trials were performed with a WG formulation; whereas, the proposed use
is for the SC formulation.  These formulation types are not considered
to be equivalent for mid- to late-season foliar applications.  The
proposed sunflower use should thus be removed from the BAS 800 04H
FiRoCrop Herbicide (SC) label and added to the BAS 800 01H TNV Herbicide
(WG) label.  Alternatively, bridging trials could be performed to
determine the effect of the formulation type on residue levels.

860.1300 Nature of the Residue - Plants

DER Reference List:	Soybean (47128002.der.doc)

			Corn (47128001.der.doc)

			Tomato (47128003.der.doc)

Soybean

The metabolism of saflufenacil was investigated in soybean following a
single pre-emergent spray application to loamy sand soil of either
[phenyl-U-14C]-saflufenacil or [uracil-4-14C]-saflufenacil formulated as
BAS 800 UBH at a nominal target application rate of 0.134 lbs. ai/A
(1.5X).  The actual application rates were 0.132 lbs. ai/A (1.5X) and
0.161 lbs. ai/A (1.8X) for the phenyl and uracil labels, respectively. 
Samples of soybean forage were harvested 39-40 days after treatment
(DAT), corresponding growth stage BBCH 70; and samples of soybean seed,
pod (without seed), and straw were harvested 95 DAT (BBCH stage 96). 
The soybean plants were cultivated in containers in climatic chambers
(phytotrons) and under greenhouse conditions under simulated conditions
for a typical U.S. soybean growing area.  The interval of frozen storage
of samples for both labels was supported by the re-extraction and
analysis of soybean pod (phenyl label) and forage (uracil label) RAC
samples; and by the re-analysis of the methanol extracts at the end of
the analytical phase.

14C-Residues in homogenates of soybean forage, pod, seed and straw were
extracted sequentially three times with methanol (3X) and water (2X). 
The seed extracts (methanol and water, for both labels) and the NH4OH
solubilizates of seed and pod (uracil label) were subjected to protein
precipitation with acetone at low temperatures.  The deproteinated
methanol extracts of seed were additionally partitioned three times with
cyclohexane, followed by mixing the aqueous phases with acetonitrile
(ACN) and centrifugation to remove precipitates.  The freeze-dried
protein precipitates from the water extracts of seed and from the NH4OH
solubilizates of seed and pod (uracil label) were incubated with
protease to release radioactive residues associated with proteins.  The
unextractable residues after solvent extraction of soybean seed and pod
for both labels and of soybean straw (phenyl label) were subjected to
solubilization procedures with 1% aqueous ammonia (two times) followed
by incubation with macerozyme (seed, pod, straw; all phenyl label only)
or macerozyme/cellulase (pod, uracil label), amylase/amyloglucosidase
(seed, pod and straw; all phenyl label only) and tyrosinase/laccase
(seed; phenyl label only).  

The identity of residues in the purified methanol extracts of soybean
forage (phenyl label) and straw (phenyl label) as well as the purified
fractions from the methanol extract of straw (phenyl label) and from the
methanol extract of forage (uracil label) were confirmed by LC-MS and
LC-MS/MS analyses.  Additional metabolites were identified/characterized
by co-chromatography and comparison of retention times with the
respective radiolabeled reference standards; and by comparison of the
metabolite profiles.  The reference standards included isolated
high-performance liquid chromatography (HPLC) fractions from the rat
metabolism study containing the metabolites M800H01, M800H02 and
M800H06, M800H03, M800H05, M800H10, and M800H37; the purified fractions
isolated from the methanol extract of soybean straw (phenyl label)
containing the metabolites M800H10, M800H36, M800H11, and M800H35; and
M800H11 from corn straw (phenyl label).  

The total radioactive residues (TRR) within soybean matrices were
highest in the pod and straw and were generally lower in forage and
seed.  The TRR, determined indirectly by the summation of the
extractable and unextractable residues, were 0.431 ppm (straw), 0.179
ppm (pod), 0.081 ppm (forage), and 0.038 ppm (seed) for the phenyl
label; and 2.031 ppm (pod), 1.183 ppm (straw), 0.383 ppm (forage), and
0.221 ppm (seed) for the uracil label.  With respect to label
differences, the TRR were the highest in all soybean matrices for the
uracil label.  

The major residues (>10% TRR or >0.1 ppm) identified in soybean forage
39-40 DAT were saflufenacil (23.5% of the TRR; 0.019 ppm) and M800H02
(18.2% of the TRR; 0.014 ppm) for the phenyl label only.  The only major
residue identified with the uracil label was trifluoroacetic acid (TFA)
(85.2% of the TRR; 0.074 ppm).  In soybean seed 95 DAT, the major
residues identified were M800H10 and/or M800H36 (14.5% of the TRR; 0.006
ppm) for the phenyl label only and TFA (65.4% of the TRR; 0.033 ppm) for
the uracil label only.  The major residues identified in soybean pod 95
DAT were M800H10 and/or M800H36 (12.2% of the TRR; 0.022 ppm) and
M800H35 (12.8% of the TRR; 0.023 ppm) for the phenyl label only.  The
only major residue identified for the uracil label was TFA (92.4% of the
TRR; 0.429 ppm).  In soybean straw 95 DAT, the major residues identified
were M800H10 and/or M800H36 (11.4% of the TRR; 0.050 ppm), M800H11
(24.9% of the TRR; 0.107 ppm), and M800H35 (15.6% of the TRR; 0.067 ppm)
for the phenyl label only.  The only major residue identified with the
uracil label was TFA (69.2% of the TRR; 0.187 ppm).

The main metabolic reactions involved in the proposed metabolic pathway
of radiolabeled saflufenacil are:

N-demethylation at the uracil ring.

stepwise degradation (N-dealkylation) of the N-methyl-N-isopropyl group
to NH2 forming a sulfonamide group.

hydrolytic cleavage of the uracil ring generating a urea side chain.

hydroxylation of the phenyl ring.

TABLE 6.  Summary of Characterization and Identification of Radioactive
Residues in Soybean Forage, Seed, Pod and Straw Following Pre-Emergent
Application of [Phenyl-U-14C]-Saflufenacil at 0.132 lbs. ai/ (1.5X).

Compound	Forage 	Seed	Pod	Straw 

	TRR = 0.081 ppm	TRR = 0.038 ppm	TRR = 0.179 ppm	TRR = 0.431 ppm

	% TRR	ppm	% TRR	ppm	% TRR	ppm	% TRR	ppm

Saflufenacil	23.5	0.019	2.3	0.001	1.5	0.003	2.5	0.011

M800H01	6.0	0.005	2.1	0.001	1.0	0.002	3.0	0.013

M800H02	18.2	0.0142	6.2	0.002	5.6	0.010	8.3	0.036

M800H03	1.2	0.001	n.d.	n.d.	n.d.	n.d.	n.d.	n.d.

M800H05	n.d.	n.d.	3.2	0.001	n.d.	n.d.	2.3	0.010

M800H10 and / or M800H36	6.6	0.005	14.5	0.006	12.2	0.022	11.4	0.050

M800H11	6.0	0.005	1.8	0.001	9.0	0.016	24.9	0.107

M800H35	5.3	0.004	3.8	0.001	12.8	0.023	15.6	0.067

M800H37	6.5	0.005	n.d.	n.d.	n.d.	n.d.	n.d.	n.d.

Total identified 	73.3	0.0582	33.9	0.013	42.1	0.076	68.0	0.294

Total characterized 	14.8	0.012	37.6	0.014	20.1	0.035	14.1	0.060

Total identified and/or characterized 	88.1	0.0702	71.5	0.027	62.2	0.111
82.1	0.354

Unextractable 	8.2	0.007	40.3	0.015	38.0	0.068	14.6	0.063

Total characterized after solubilization of unextractable residues 	n.a.
n.a.	26.9	0.011	27.3	0.049	7.5	0.032

Total identified and/or characterized	n.a.	n.a.	98.4	0.038	89.5	0.160
89.6	0.386

Post-extraction solids1	n.a.	n.a.	10.8	0.004	9.8	0.017	6.3	0.027

Accountability2	95%	111%	99%	96%

1  Residues remaining after exhaustive extractions.

2  Accountability = (Total extractable + Total
unextractable)/(calculated TRR) x 100.

Note:  M800H10 and M800H36 were not separated in HPLC systems B and C. 
However, both M800H10 and M800H36 were identified by LC-MS/MS analysis
of the purified fraction from the methanol extract of soybean straw.

TABLE 7.  Summary of Characterization and Identification of Radioactive
Residues in Soybean Matrices Following Application of Radiolabeled BAS
800 H (Uracil Label) at 0.161 lbs. ai/A (1.8X).

Compound	Forage (40 DAT)	Seed (95 DAT)	Pod (95 DAT)	Straw (95 DAT)

	TRR = 0.383 ppm	TRR = 0.221 ppm	TRR = 2.031 ppm	TRR = 1.183 ppm

	% TRR	ppm	% TRR	ppm	% TRR	ppm	% TRR	ppm

Saflufenacil	4.0	0.015	0.8	0.002	n.d.	n.d.	2.9	0.034

M800H01	2.3	0.009	1.1	0.002	n.d.	n.d.	2.0	0.023

M800H02	5.0	0.019	1.4	0.003	1.0	0.021	5.3	0.062

M800H11	2.5	0.010	n.d.	n.d.	1.3	0.026	14.5	0.173

TFA1	85.2	0.074 (0.326)	65.4	0.033 (0.145)	75.9	0.352 (1.54)	69.2	0.187
(0.819)

Total identified 	99.0	0.128 (0.379)	68.7	0.040 (0.152)	78.2	0.399
(1.59)	93.9	0.479 (1.11)

Total characterized 	3.1	0.012	9.8	0.021	n.d.	n.d.	6.6	0.080

Total identified and/or characterized 	102.1	0.139 (0.391)	78.5	0.061
(0.173)	78.2	0.399 (1.59)	100.5	0.559 (1.19)

Unextractable 	1.8	0.007	18.8	0.042	21.0	0.426	3.9	0.046

Total identified after solubilization of unextractable residues (TFA1)
n.a.	n.a.	n.a.	n.a.	16.5	0.077 (0.336)	n.a.	n.a.

Total characterized after solubilization of unextractable residues	n.a.
n.a.	13.72	0.0302 	2.3	0.048	n.a.	n.a.

Total identified and/or characterized 	n.a.	n.a.	13.7	0.030	18.8	0.125
(0.384)	n.a.	n.a.

Total identified	n.a.	n.a.	68.7	0.040 (0.152)	94.7	0.476 (1.93)	n.a.
n.a.

Total identified and/or characterized	n.a.	n.a.	92.2	0.091 (0.203)	97.1
0.524 (1.98)	n.a.	n.a.

Post-extraction solids3	n.a.	n.a.	6.0	0.013	1.0	0.020	n.a.	n.a.

Accountability4	104%	98%	98%	104%

1  Absolute amount (ppm) was calculated using the conversion factor of
0.228 [(molecular mass of TFA 114 g/mol) ÷ (molecular mass of
Saflufenacil 500 g/mol)].  The number in parentheses is the absolute
amount expressed as parent equivalents). 

2  Sum of fractions characterized from the unextractable residues after
protein precipitation from the NH4OH solubilitzate and protease
treatment of the precipitate.

3  Residues remaining after exhaustive extractions.

4  Accountability = (Total extractable + Total
unextractable)/(calculated TRR) x 100.

Corn

The metabolism of saflufenacil was investigated in corn following a
single pre-emergent spray application immediately after sowing to sandy
loam soil of either [phenyl-U-14C]-saflufenacil or
[uracil-4-14C]-saflufenacil formulated as BAS 800 UBH (EC) at a nominal
target application rate of 0.179 lbs. ai/A (1.3X).  The actual
application rates were 0.169 lbs. ai/A (1.3X) and 0.196 lbs. ai/A (1.5X)
for the phenyl and uracil labels, respectively.  Samples of corn forage
were harvested 42 and 101-102 DAT, corresponding to growth stages BBCH
18 and 85, respectively.  Samples of corn husks, cob, grain, and stover
were harvested 133 DAT (BBCH 89).  The corn plants were cultivated in
containers in climatic chambers (phytotrons), simulating the climate of
a typical U.S. corn-growing areas.  The interval of frozen storage of
samples for both labels was supported by the re-extraction and analysis
of corn forage and grain samples and the re-analysis of the methanol
extracts at the end of the analytical phase.

14C-Residues in homogenates of corn forage, husks, cob, grain, and
stover were extracted by homogenization sequentially with methanol
(three times) and water (two times).  Unextractable residues were
characterized by sequential treatment with 1% aqueous ammonia,
macerozyme, tyrosinase/laccase, and amylase/amyloglucosidase.  

Residues were characterized/identified by reversed-phase HPLC
co-chromatography or comparison of retention times to reference
standards.  The identity of metabolites isolated from corn stover
(phenyl label) and corn husks (uracil label) was confirmed by LC-MS and
LC-MS/MS.  

The TRR levels within corn matrices were highest in the husks and stover
(referred to as straw in the trial report) and were generally relatively
lower in forage, cob and grain.  The TRR were 0.215 ppm (husks), 0.096
ppm (stover), 0.029 ppm (forage 101 DAT), 0.020 ppm (grain), 0.018 ppm
(forage 42 DAT), and 0.016 ppm (cob) for the phenyl label; and were
0.553 ppm (stover), 0.226 ppm (husks), 0.149 ppm (forage 102 DAT), 0.065
ppm (cob), 0.049 ppm (grain), and 0.039 ppm (forage 42 DAT) for the
uracil label. 

The major residues (>10% TRR or >0.1 ppm) identified in corn forage 42
DAT were M800H01 (14.6% of the TRR; 0.003 ppm), M800H03 (13.5% of the
TRR; 0.002 ppm), M800H05 (11.1% of the TRR; 0.002 ppm), M800H09 (20.0%
of the TRR; 0.004 ppm), and M800H10 (16.0% of the TRR; 0.003 ppm) for
the phenyl label only.  The only major residue identified for the uracil
label was TFA (63.7% of the TRR; 0.006 ppm).  The major residues
identified in corn forage 101-102 DAT included M800H09 (21.4% of the
TRR; 0.006 ppm), H800H10 (20.4% of the TRR; 0.006 ppm), and M800H34
(21.0% of the TRR; 0.006 ppm) for the phenyl label only.  The only major
residue identified for the uracil label was TFA (75.7% of the TRR; 0.026
ppm).  In corn husks, the only major residue identified was TFA (87.7%
of the TRR; 0.045 ppm), for the uracil label only.  The major residues
identified in corn cob were M800H34 (16.7% of the TRR; 0.003 ppm) for
the phenyl label only and TFA (66.0% of the TRR; 0.010 ppm) for the
uracil label only.  The only major residue identified in corn grain was
TFA (30.5% of the TRR; 0.004 ppm), for the uracil label only. 
Identified residues in corn grain from the phenyl label were all <10%
TRR.  In corn stover, the major residues identified were M800H09 (12.6%
of the TRR; 0.012 ppm), M800H10 (12.8% of the TRR; 0.012 ppm), and
M800H34 (12.2% of the TRR; 0.012 ppm) for the phenyl label only; and TFA
(77.4% of the TRR; 0.098 ppm) for the uracil label only.

The main metabolic reactions involved in the proposed metabolic pathway
of radiolabeled saflufenacil are:

N-demethylation at the uracil ring.

stepwise degradation (N-dealkylation) of the N-methyl-N-isopropyl group
to NH2 forming a sulfonamide group.

hydrolytic cleavage of the uracil ring generating a urea side chain.

TABLE 8.  Summary of Characterization and Identification of Radioactive
Residues in Corn Forage Following Pre-Emergent Application of
[Phenyl-U-14C]-Saflufenacil at 0.169 lbs. ai/A (1.3X).

Metabolite Fraction	Corn Forage (42 DAT)	Corn Forage (101 DAT)

	TRR = 0.018 ppm	TRR = 0.029 ppm

	% TRR	ppm	% TRR	ppm

Saflufenacil	2.1	<0.0005	n.d.	n.d.

M800H01	14.6	0.003	1.6	<0.0005

M800H02	3.8	0.001	n.d.	n.d.

M800H03	13.5	0.002	1.1	<0.0005

M800H05	11.1	0.002	n.d.	n.d.

M800H09	20.0	0.004	21.4	0.006

M800H10	16.0	0.003	20.4	0.006

M800H11	8.9	0.002	7.3	0.002

M800H34	1.2	<0.0005	21.0	0.006

Total identified 	91.2	0.017	72.8	0.020

Total characterized 	19.2	0.003	28.5	0.008

Total extractable	110.4	0.020	101.3	0.028

Post-extraction solids	13.8	0.002	22.8	0.007

Accountability1	122%	121%

1  Accountability = (Total extractable + Total
unextractable)/(calculated TRR) x 100.

TABLE 9.  Summary of Characterization and Identification of TRR in Corn
Husks, Cob, Grain and Stover Following Pre-Emergent Application of
[Phenyl-U-14C]-Saflufenacil at 0.169 lbs. ai/A (1.3X).

Metabolite Fraction	Corn Husks	Corn Cob	Corn Grain	Corn Stover

	TRR = 0.215 ppm	TRR = 0.016 ppm	TRR = 0.020 ppm	TRR = 0.096 ppm

	% TRR	ppm	% TRR	ppm	% TRR	ppm	% TRR	ppm

Saflufenacil	0.7	0.001	n.d.	n.d.	n.d.	n.d.	0.3	<0.0005

M800H03	n.d.	n.d.	n.d.	n.d.	n.d.	n.d.	0.3	<0.0005

M800H05	1.2	0.002	n.d.	n.d.	n.d.	n.d.	n.d.	n.d.

M800H09	1.4	0.003	7.0	0.001	0.3	<0.0005	12.6	0.012

M800H10	4.1	0.009	3.1	<0.0005	0.5	<0.0005	12.8	0.012

M800H11	1.6	0.003	1.9	<0.0005	0.6	<0.0005	4.6	0.004

M800H34	6.0	0.013	16.7	0.003	2.0	<0.0005	12.2	0.012

Total identified 	15.0	0.031	28.7	0.005	3.4	0.001	42.8	0.041

Total characterized 	56.0	0.121	26.4	0.005	7.6	0.001	23.1	0.022

Total identified and/or characterized 	71.0	0.152	55.1	0.010	11.0	0.002
65.9	0.063

Unextractable 	23.8	0.051	80.8	0.013	81.6	0.017	16.8	0.016

Total characterized after solublization of unextractable residues	9.8
0.021	16.0	0.002	49.7	0.010	5.5	0.005

Total identified and/or characterized	80.8	0.173	71.1	0.012	60.7	0.012
71.4	0.068

Post-extraction solids1	not determined	not determined	20.6	0.004	8.7
0.008

Accountability2	94% 	144%	80%	79%

1  Residues remaining after exhaustive extractions.

2  Accountability = (Total extractable + Total
unextractable)/(calculated TRR) x 100.

TABLE 10.  Summary of Characterization and Identification of Radioactive
Residues in Corn Forage Following Pre-Emergent Application of
[Uracil-4-14C]-Saflufenacil at 0.196 lbs. ai/A (1.5X).

Metabolite Fraction	Corn Forage (42 DAT)	Corn Forage (102 DAT)

	TRR = 0.039 ppm	TRR = 0.149 ppm

	% TRR	ppm	% TRR	ppm

Saflufenacil 	1.1	<0.0005	n.d.	n.d.

M800H01	4.4	0.002	n.d.	n.d.

M800H02	1.0	<0.0005	n.d.	n.d.

M800H03	3.4	0.001	n.d.	n.d.

M800H05	1.8	0.001	n.d.	n.d.

M800H09	3.1	0.001	2.2	0.003

M800H10	3.1	0.001	2.9	0.004

M800H11	2.0	0.001	1.9	0.003

TFA1	63.7	0.006 (0.025)	75.7	0.026 (0.113)

Total identified 	83.6	0.013 (0.032)	82.7	0.036 (0.123)

Total characterized 	4.8	0.001	5.6	0.008

Total identified and/or characterized 	88.4	0.014 (0.033)	88.3	0.044
(0.131)

Post-extraction solids	4.0	0.002	5.2	0.008

Accountability2	90%	93%

1  Absolute amount (ppm) was calculated using the conversion factor of
0.228 [(molecular mass of TFA 114 g/mol) ÷ (molecular mass of
saflufenacil 500 g/mol)].  The number in parentheses is the absolute
amount expressed as parent equivalents. 

2  Accountability = (Total extractable + Total
unextractable)/(calculated TRR) x 100.

TABLE 11.  Summary of Characterization and Identification of TRR in
Corn Husks, Cob, Grain and Stover Following Pre-Emergent Application of
[Uracil-4-14C]-Saflufenacil at 0.196 lbs. ai/A (1.5X).

Metabolite Fraction	Corn Husks	Corn Cob	Corn Grain	Corn Stover

	TRR = 0.226 ppm	TRR = 0.065 ppm	TRR = 0.049 ppm	TRR = 0.553 ppm

	% TRR	ppm	% TRR	ppm	% TRR	ppm	% TRR	ppm

Saflufenacil 	n.d.	n.d.	n.d.	n.d.	n.d.	n.d.	n.d.	n.d.

M800H09	0.3	0.001	0.3	<0.0005	n.d.	n.d.	1.8	0.010

M800H10	0.6	0.001	n.d.	n.d.	n.d.	n.d.	2.7	0.015

M800H11	0.5	0.001	n.d.	n.d.	n.d.	n.d.	0.8	0.004

TFA1	87.7	0.045 (0.198)	66.0	0.010 (0.043)	30.5	0.004  (0.015)	77.4
0.098  (0.428)

Total identified 	89.1	0.048 (0.201)	66.3	0.010 (0.043)	30.5	0.004
(0.015)	82.7	0.127 (0.457)

Total characterized 	4.8	0.011	9.4	0.006	12.0	0.006	6.1	0.034

Total identified and/or characterized 	93.9	0.059 (0.212)	75.7	0.016
(0.049)	42.5	0.010 (0.021)	88.8	0.161 (0.491)

Unextractable 	5.7	0.013	22.6	0.015	39.9	0.019	3.6	0.020

Total characterized after solubilization of unextractable residues	1.3
0.002	4.4	0.003	18.8	0.009	1.8	0.010

Total identified and/or characterized	95.2	0.061 (0.214)	80.1	0.019
(0.052)	61.3	0.019 (0.030)	90.6	0.171 (0.501)

Post-extraction solids2	4.0	0.009	17.6	0.011	18.2	0.009	1.5	0.008

Accountability3	99%	97%	80%	92%

1  Absolute amount (ppm) was calculated using the conversion factor of
0.228 [(molecular mass of TFA 114 g/mol) ÷ (molecular mass of
Saflufenacil 500 g/mol)]. The number in parentheses is the absolute
amount expressed as parent equivalents. 

2  Residues remaining after exhaustive extractions.

3  Accountability = (Total extractable + Total
unextractable)/(calculated TRR) x 100.

Tomato

The metabolism of saflufenacil was investigated in tomato after one
single spray application of the test substance in the EC formulation BAS
800 UB H at a nominal application rate of 100 g ai/ha (0.089 lbs. ai/A).
 The active substance was applied to soil directly before planting of
tomato plants (pre-plant treatment).  Treatment was performed with
either [phenyl-U-14C]-saflufenacil or [uracil-4-14C]-saflufenacil. 
Tomato plants at BBCH growth stage 16/17 were planted into the sprayed
soil after drying and were grown in climatic chambers (phytotrons) and
later on in the greenhouse.  Immature tomato plants (BBCH growth stage
62/63) were sampled 68 DAT.  The mature tomato plants were harvested 113
DAT and separated into plant and fruit samples.  Frozen samples were
homogenized and extracted with methanol and water.  The extractable
radioactive residues were measured by liquid-scintillation counting
(LSC), and the residual radioactive residues after solvent extraction
were determined by combustion analysis.  The residual radioactive
residue of immature tomato plant (BBCH 62/63; phenyl label) and of
mature tomato plant at harvest (phenyl label and uracil label) were
further characterized by means of sequential solubilization procedures
using base and acid hydrolysis and microwave treatment.  The nature of
the residues in the methanol extracts was investigated using two methods
of HPLC radiodetection.  Metabolite identification was based on HPLC
co-chromatography experiments performed with reference items obtained
from other metabolism studies with saflufenacil in corn, rotational
crops, and rats. 

The TRR were determined by combustion/LSC of homogenized sample
material.  The TRR in immature tomato plant (BBCH 62/63; 68 DAT)
accounted for 0.089 ppm (phenyl label) and 0.131 ppm (uracil label).  In
tomato plants at harvest (113 DAT), the TRR were 0.113 ppm for the
phenyl label and 0.138 ppm for the uracil label.  In tomato fruits (113
DAT), the TRR levels were significantly lower, accounting for 0.015 ppm
(phenyl label) and 0.037 ppm (uracil label).  Extractability of
radioactive residues with methanol and water was good and ranged from
102.5-103.9% in immature tomato plant, 80.9-90.5% in tomato plant at
harvest, and 68.4-84.0% in tomato fruit.

The common major metabolite identified in tomato plant matrices
following the soil application of [phenyl-U-14C]-saflufenacil was the
parent compound, saflufenacil, accounting for 28.6% of the TRR (0.026
ppm) in immature tomato plants and 10.9% of the TRR (0.012 ppm) in the
tomato plant at harvest.  Two other major metabolites, M800H07 and
M800H11, were also identified in immature tomato plant, accounting for
14.1% of the TRR (0.013 ppm) and 12.6% of the TRR (0.011 ppm),
respectively.  In tomato fruit, the only major residue was a sugar
compound (probably fructose), accounting for 52.9% of the TRR (0.008
ppm).

The common major metabolite identified in all tomato matrices following
the soil application of [uracil-4-14C]-saflufenacil was TFA, accounting
for 82.2% of the TRR (0.025 ppm) in immature tomato plant, 51.7% of the
TRR (0.016 ppm) in tomato plant at harvest, and 48.6% of the TRR (0.004
ppm) in tomato fruit.  The concentration of TFA was calculated using the
molecular mass of the compound.  In tomato fruit, a sugar compound
(probably fructose) was also identified as a major compound and
accounted for 33.7% of the TRR (0.012 ppm).

Saflufenacil was metabolized in tomato by N-dealkylation at two sites in
the molecule and via hydrolysis of the uracil ring.  The metabolites
M800H01, M800H02, M800H09, M800H10, and M800H11 were produced by
dealkylation at either the sulfonamide nitrogen or the uracil nitrogen
of saflufenacil.  The metabolites M800H07, M800H35, and TFA were
produced when the uracil ring was hydrolyzed.  In addition, a sugar
metabolite (probably fructose) found in tomato fruit resulted from the
uptake of the small carbon fragments generated by further degradation of
the other identified metabolites.  All these metabolites were found at
very low level (<0.02 ppm), although the % TRR levels varied among
matrices.

Table 12.  Summary of Characterization and Identification of
Radioactive Residues in Tomato Matrices Following Application of
[Phenyl-U-14C]-Saflufenacil at 0.089 lbs. ai/A. 

Metabolite Fraction	Tomato Plant(BBCH 62/63)	Tomato Plant(Harvest)
Tomato Fruit(Harvest)

	TRR = 0.089 ppm	TRR = 0.113 ppm	TRR = 0.015 ppm

	% TRR	ppm	% TRR	ppm	% TRR	ppm

Saflufenacil 	28.6	0.026	10.9	0.012	0.7	<0.0005

M800H01	1.9	0.002	1.5	0.002	n.d.	n.d.

M800H02	5.9	0.005	2.3	0.003	n.d.	n.d.

M800H07	14.1	0.013	5.8	0.007	n.d.	n.d.

M800H09	-2	-2	5.0	0.006	n.d.	n.d.

M800H11	12.6	0.011	5.9	0.007	n.d.	n.d.

M800H35	5.22	0.0052	5.8	0.007	n.d.	n.d.

M800H10 and Unknown1	9.4	0.008	10.2	0.012	n.d.	n.d.

Sugar (most probably fructose)	n.d.	n.d.	n.d.	n.d.	52.9	0.008

Total identified	68.2	0.061	37..3	0.042	53.6	0.008

Total characterized	35.7	0.032	43.6	0.05	14.9	0.002

Total extractable	103.9	0.093	80.9	0.092	68.4	0.01

Post-extraction solids3	3.9	0.003	7.1	0.008	32.2	0.005

Accountability4	108%	88%	100%

1   “M800H10 and unknown” were counted as characterized.

2   M800H09 and M800H035 co-eluted in the methanol extract of immature
tomato plants and were quantified together.

3   Residues remaining after exhaustive extractions.

4   Accountability = (Total extractable + Total unextractable)/(TRR from
combustion analysis) * 100.

n.d. = not detected. 

Table 13.  Summary of Characterization and Identification of Radioactive
Residues in Tomato Matrices Following Application of
[Uracil-4-14C]-Saflufenacil at 0.089 lbs. ai/A. 

Metabolite Fraction	Tomato Plant

(BBCH 62/63)	Tomato Plant

(Harvest)	Tomato Fruit

(Harvest)

	TRR = 0.131 ppm	TRR = 0.138 ppm	TRR = 0.037 ppm

	% TRR	ppm	% TRR	ppm	% TRR	ppm

Saflufenacil 	4.8	0.006	8.5	0.012	n.d.	n.d.

M800H10	2.4	0.003	2.9	0.004	n.d.	n.d.

M800H11	3.9	0.005	3.6	0.005	n.d.	n.d.



TFA	82.2	0.108

(0.025*)	51.7	0.071

(0.016*)	48.6	0.018

(0.004*)

Sugar (most probably fructose)	n.d.	n.d.	n.d.	n.d.	33.7	0.012

Total identified	93.2	0.122	66.8	0.092	82.3	0.03

Total characterized	9.3	0.012	23.7	0.033	1.8	0.001

Total extractable	102.5	0.134	90.5	0.125	84.0	0.031

Post-extraction solids1	6.4	0.008	6.4	0.009	11.8	0.004

Accountability2	108%	97%	95%

*   ppm calculated using the molecular mass of TFA.

1   Residues remaining after exhaustive extractions.

2   Accountability = (Total extractable + Total unextractable)/(TRR from
combustion analysis) * 100.

n.d. = not detected.

Sunflower

On 8/30/06, the HED Chemistry Science Advisory Council (ChemSAC)
reviewed a waiver request for a sunflower metabolism study:

“BAS 800-H Sunflower Metabolism Waiver Request – BASF has requested
a waiver for a crop metabolism study to support use of BAS 800-H as a
foliar agent on sunflower.  ChemSAC agreed that the proposed sunflower
use is acceptable without a sunflower metabolism study - so long as the
results of existing non-GLP studies of velvet leaf metabolism and of
cell culture metabolism are submitted.  A major concern, however, was
addressed not to the use on sunflower, but to possible future attempts
to extend use to other crops.  It was felt that acceptance of the
currently requested waiver should not serve as a precedent for also
waiving studies on those other crops.  

In sum, ChemSAC concluded that submission of the cell culture and velvet
leaf studies would be adequate to support the sunflower use without need
for additional metabolism data. But ChemSAC also concluded that if it is
desired to expand this treatment to any major crop in the future ChemSAC
will require proper GLP metabolism studies on any such crops.”

The summaries of the non-GLP studies (included in MRID# 47128004)
confirm that there were no additional metabolites seen in these studies.
 No additional metabolism data are required to support the sunflower
desiccation use.

Conclusions:  The submitted metabolism data for corn, soybean, and
tomato are adequate to elucidate the nature of the residue in plants
resulting from preplant/preemergence application.  The main reactions
involved in the metabolic pathway of saflufenacil are N-demethylation at
the uracil ring, stepwise degradation (N-dealkylation) of the
N-methyl-N-isopropyl group, hydrolytic cleavage of the uracil ring
generating a urea side chain, and hydroxylation of the phenyl ring. 
Three metabolites of saflufenacil were present either in all plant
matrices or were relatively prominent in some plant matrices; i.e.,
exceeded 10% of the TRR and, 0.05 ppm.  M800H11 was found in all corn
and soybean matrices from both 14C-labeled uracil and 14C-labeled phenyl
saflufenacil.  M800H11 is formed when saflufenacil undergoes
demethylation at both nitrogen atoms.  Metabolite M800H11 thus has a
very similar chemical structure compared to the parent compound. 
M800H35 was detected only after 14C-labeled phenyl saflufenacil
treatment and was detected at higher levels in soybean matrices. 
M800H35 is formed when parent saflufenacil undergoes demethylation at
the sulfonylurea side chain and cleavage of the uracil ring.  The third
prominent metabolite, designated as M800H29 and commonly known as TFA,
was detected only after treatment with 14C-labeled uracil saflufenacil
and was detected at relatively high levels in all matrices.  However,
TFA is a polar, low-molecular-weight organic acid with no chemical
structural resemblance to the parent molecule.  The HED ROCKS determined
that residues of concern for the tolerance expression and risk
assessment consist of saflufenacil, M800H11, and M800H35 (Memo, B.
Daiss, 1/6/09; D359645).  This conclusion applies only to
preplant/preemergence and sunflower harvest-aid uses.

FIGURE 1.  Proposed Metabolic Profile of Saflufenacil in Corn.

FIGURE 2.  Proposed Metabolic Profile of Saflufenacil in Soybean.

860.1300 Nature of the Residue - Livestock

DER Reference List	Lactating Goat (47128005.der.doc)

			Hen (47128007.der.doc)

Goat

[Phenyl-U-14C]-saflufenacil or [uracil-4-14C]-saflufenacil were
administered to two lactating goats (one goat per label) at an average
dose of 13.9 ppm feed (corresponding to 18.4 mg/animal/day) for the
phenyl label and an average dose of 13.4 ppm feed (corresponding to 17.8
mg/animal/day) for the uracil label (~57X).  The radiolabeled compound
was administered orally by gavage once a day in the morning for eight
consecutive days.  Milk was collected twice a day (in the morning before
the administration of the test substance and in the afternoon) and
excreta samples were collected once a day throughout the study period. 
The animals were sacrificed 23 hours after the last administration and
the following tissues were collected for analysis: liver, kidney, blood,
fat, muscle, gastrointestinal tract and contents, and bile.

The majority of the administered dose (AD) was eliminated via urine
(62.0% AD and 45.6% AD for phenyl and uracil label, respectively) and
feces (28.5% AD and 41.9% AD for phenyl and uracil label, respectively).
 An additional 0.8% AD (phenyl label) and 0.5% AD (uracil label) was
recovered from the stomach and gut contents.  Throughout the study
period (8 days), only 0.04% AD (phenyl label) and 0.10% AD (uracil
label) was transferred into milk and less than 0.4% AD (phenyl label)
and 1.6% AD (uracil label) was transferred to edible tissues (muscle,
fat, kidney, and liver).  The highest concentration of residues were
detected in liver and kidney (0.962 ppm and 0.130 ppm, respectively, for
the phenyl label and 3.832 ppm and 0.171 ppm, respectively, for the
uracil label).

Extractability of residues from feces, urine, milk, and tissues was
high, with 82.0% to 105.7% (phenyl label) and 80.9% to 107.7% (uracil
label) of 14C-residues released after treatment of homogenized matrices
with ACN (all matrices, except urine) and water (kidney) or isohexane
(muscle and fat).  Characterization and identification of metabolites by
HPLC was conducted on tissues, feces, and milk following organic
extraction of samples.  TRR identified in tissues and milk ranged from
58.8% to 103.0% for the phenyl label and from 80.2 % to 106.3% for the
uracil label, while TRR identified in excreta ranged from 89.2% to
100.0% (phenyl label) and 92.9% to 98.7% (uracil label).  Metabolite
identification and peak assignment was confirmed by HPLC, LC-MS/MS
analysis of selected concentrated extracts, co-chromatography, and by
comparison of the retention time with those of the respective reference
items. 

For the phenyl label, the predominant metabolite identified in all
matrices was the parent compound, saflufenacil, constituting 44.2 % of
the TRR (0.004 ppm) in muscle, 44.1% of the TRR (0.004 ppm) in fat,
73.8% of the TRR (0.096 ppm) in kidney, 80.2% of the TRR (0.772 ppm) in
liver, 47.0% of the TRR (0.003 ppm) in milk, 91.8% of the TRR (8.119
ppm) in urine, and 41.5% of the TRR (0.432 ppm) in feces.  Other major
metabolites identified in milk and tissues were M800H04 accounting for
12.9% of the TRR (0.017 ppm) in kidney and 13.2% of the TRR (0.127 ppm)
in liver, and M800H10, accounting for 37.5% of the TRR (0.003 ppm) in
muscle, 14.7% of the TRR (0.001 ppm) in fat, and 39.1% of the TRR (0.002
ppm) in milk.  Major metabolites identified in excreta were M800H01,
accounting for 5.2% of the TRR (0.463 ppm) in urine and 30.3% of the TRR
(0.316 ppm) in feces, and M800H03 accounting for 3.0% of the TRR (0.262
ppm) in urine.  Minor metabolites (<10% of the TRR and/or <0.1 ppm)
identified in some of the goat matrices were M800H01, M800H03, M800H07,
M800H10, and M800H11.

For the uracil label, the predominant metabolite (except in milk and
feces) identified in all matrices was the parent compound, saflufenacil,
constituting 56.7% of the TRR (0.006 ppm) in muscle, 65.1% of the TRR
(0.011 ppm) in fat, 71.3% of the TRR (0.122 ppm) in kidney, 75.7% of the
TRR (2.900 ppm) in liver, 25.4% of the TRR (0.003 ppm) in milk, 69.4% of
the TRR (7.010 ppm) in urine, and 33.8% of the TRR (0.460 ppm) in feces.
 Other major metabolites identified in milk and tissues were M800H04,
accounting for 10.0% of the TRR (0.017 ppm) in kidney and 14.2% of the
TRR (0.543 ppm) in liver, and M800H10, accounting for 49.6% of the TRR
(0.005 ppm) in muscle, 15.1% of the TRR (0.003 ppm) in fat, and 39.9% of
the TRR (0.005 ppm) in milk.  Major metabolites identified in excreta
were M800H01, accounting for 8.8 % of the TRR (0.893 ppm) in urine and
39.5% of the TRR (0.538 ppm) in feces, M800H03, accounting for 10.2% of
the TRR (1.027 ppm) in urine and 11.0% of the TRR (0.150 ppm) in feces,
M800H05, accounting for 1.8% of the TRR (0.184 ppm) in urine, and
M800H11, accounting for 2.7% of the TRR (0.268 ppm) in urine and 9.3% of
the TRR (0.127 ppm) in feces. Minor metabolites identified in some of
the goat matrices were M800H01, M800H02, M800H03, and M800H10.

Saflufenacil was metabolized in lactating goat by several dealkylation
steps (phase-I reaction) occurring at two different sites in the
molecule (N-isopropyl-N-methylsulfamide side chain and at the uracil
ring) and via hydrolytic opening of the uracil ring.

TABLE 14.  Summary of Characterization and Identification of Radioactive
Residues in Goat Matrices Following Application of
[Phenyl-U-14C]-Saflufenacil at a Mean of 13.87 ppm/day (~57X).

Metabolite Fraction	Muscle	Fat	Kidney	Liver	Milk1

	TRR = 0.008 ppm	TRR = 0.010 ppm	TRR = 0.130 ppm	TRR = 0.962 ppm	TRR =
0.006

ppm2

	%TRR	ppm	%TRR	ppm	%TRR	ppm	%TRR	ppm	%TRR	ppm

Saflufenacil	44.2	0.004	44.1	0.004	73.8	0.096	80.2	0.772	47.0	0.003

M800H01



	2.2	0.003	1.2	0.011	9.1	0.001

M800H03







	7.8	<0.0005

M800H04



	12.9	0.017	13.2	0.127



M800H10	37.5	0.003	14.7	0.001	1.7	0.002

	39.1	0.002

Total identified	81.7	0.007	58.8	0.006	90.6	0.118	94.7	0.911	103.0	0.006

Total characterized	0.3	<0.0005	23.6	0.002	5.8	0.008	1.5	0.015	2.7
<0.0005

Total extractable	82.0	0.007	82.4	0.008	96.4	0.126	96.2	0.925	105.7
0.006

Unextractable3	16.5	0.001	12.0	0.001	3.7	0.005	2.7	0.026	4.0	<0.0005

Accountability4	100%	90%	101%	99%	100%

Shaded areas = not detected.

1   Calculated for Day 1-8 in the case of the pooled milk samples.

2   Milk TRR values were calculated assuming a density of 1.0 g/mL.

3   Residues remaining after exhaustive extractions.

4   Accountability = (Total extractable + Total unextractable)/(TRR from
combustion analysis) * 100.



TABLE 15.  Summary of Characterization and Identification of Radioactive
Residues in Goat Matrices Following Application of
[Uracil-4-14C]-Saflufenacil at a Mean of 13.37 ppm/day (~57X).

Metabolite Fraction	Muscle	Fat	Kidney	Liver	Milk1

	TRR = 0.011 ppm	TRR = 0.017 ppm	TRR = 0.171 ppm	TRR = 3.832 ppm	TRR =
0.012 ppm2

	%TRR	ppm	%TRR	ppm	%TRR	ppm	%TRR	ppm	%TRR	ppm

Saflufenacil	56.7	0.006	65.1	0.011	71.3	0.122	75.7	2.900	25.4	0.003

M800H01



	5.2	0.009	1.4	0.054	6.7	0.001

M800H03



	3.7	0.006

	8.8	0.001

M800H04



	10.0	0.017	14.2	0.543



M800H10	49.6	0.005	15.1	0.003	2.5	0.004

	39.9	0.005

Total identified	106.3	0.012	80.2	0.014	92.8	0.159	91.3	3.497	80.9	0.009

Total characterized	1.4	<0.0005	26.8	0.005	4.5	0.008	1.9	0.073	---	---

Total extractable	107.7	0.012	107.0	0.018	97.3	0.167	93.2	3.570	80.9
0.009

Unextractable3	1.0	<0.0005	9.2	0.002	3.5	0.006	2.4	0.094	14.1	0.002

Accountability4	109%	118%	101%	96%	92%

Shaded areas = not detected.

1   Calculated for Day 1-8 in the case of the pooled milk samples.

2   Milk TRR values were calculated assuming a density of 1.0 g/mL.

3   Residues remaining after exhaustive extractions.

4   Accountability = (Total extractable + Total unextractable)/(TRR from
combustion analysis) * 100.

Hen

The nature of the residue in egg and tissues was investigated in laying
hens (n = 8 animals per treatment group) dosed orally once daily by
gavage with either [phenyl-U-14C]-saflufenacil or
[uracil-U-14C]-saflufenacil at a rate of 0.83-0.84 mg ai/kg bw/day
(12.6-12.7 ppm in the feed) for 10 consecutive days (~47X).  Samples of
eggs and excreta were collected daily.  The treated hens were sacrificed
~23 hours after the final dosage.  Samples of blood, liver, muscle (leg
and chest), fat, and gastrointestinal (GI) tract (plus contents) were
collected.  The maximum storage interval of samples from collection to
analysis was 4.4 months.

The majority of the AD was detected in the excreta, accounting for
78-85% of the AD.  Only 0.04-0.05% of the AD and 0.029-0.046% of the AD
were detected in the edible tissues and eggs, respectively.  In edible
tissues, the TRR were highest in liver (0.060-0.062 ppm) and were
relatively lower in muscle (0.011 ppm) and fat (0.011 ppm).  The TRR in
Day-10 egg samples were 0.010-0.016 ppm.  Peak egg residues were
observed on Day-6 (0.012 ppm for the phenyl label and 0.018 ppm for the
uracil label).

The majority of the TRR in excreta (pooled samples Day 1-Day 10),
muscle, fat, liver, and eggs (pooled sample Day 2-Day 10) were each
extracted with ACN (78.5-98.9% of the TRR; 0.008-4.690 ppm).  Residues
in liver and fat were further extracted with water (11.3-13.1% of the
TRR; 0.007-0.008 ppm) and isohexane (4.3-12.7% of the TRR; 0.0004-0.001
ppm), respectively.  The isohexane extract of fat was not further
characterized.  Unextractable residues in excreta, muscle, fat, liver,
and eggs each accounted for 1.1-18.1% of the TRR (0.0004-0.052 ppm). 
Pronase treatment of the unextractable residues in liver released a
further 2.7-4.6% of the TRR (0.002-0.003 ppm).  Sample extracts were
analyzed by reversed-phase HPLC with UV-VIS and radioactivity detection.
 Identification of metabolites was confirmed by LC-MS and LC-MS/MS. 

The parent compound saflufenacil was identified as a major residue in
excreta (50.4-53.2% of the TRR; 2.027-2.525 ppm), muscle (38.2-54.7% of
the TRR; 0.005-0.006 ppm), fat (24.0-26.1% of the TRR; 0.002 ppm), liver
(47.0-47.4% of the TRR; 0.028-0.029 ppm), and eggs (20.8% of the TRR;
0.002 ppm for the phenyl label only).  Additional major residues
identified included M800H01 in excreta (20.6-22.1% of the TRR;
0.888-0.979 ppm) and liver (21.0-24.0% of the TRR; 0.012-0.014 ppm);
M800H02 in excreta (6.7-7.6% of the TRR; 0.305-0.0316 ppm); M800H03 in
excreta (3.8-3.9% of the TRR; 0.153-0.186 ppm), M800H05 in excreta
(7.2-7.6% of the TRR; 0.289-0.362 ppm); M800H10 in muscle (22.0-23.1% of
the TRR; 0.002-0.003 ppm), fat (12.7-15.8% of the TRR; 0.001 ppm) and
eggs (51.6-67.6% of the TRR; 0.008-0.009 ppm) and M800H11 in excreta
(3.9-4.4% of the TRR; 0.177-0.185 ppm). 

The metabolism of saflufenacil in laying hens proceeds via different
dealkylation steps, which occur at either the sulfamide side chain or
the uracil ring.  These reactions produce metabolites that are rapidly
excreted, along with parent, and do not readily accumulate in tissues or
eggs.

TABLE 16.  Summary of Characterization and Identification of Radioactive
Residues in Hen Matrices Following Application of [Phenyl-U-14C]
Saflufenacil (~47X).

Compound	Excreta(Pooled Sample Day 1-10)	Muscle	Fat	Liver	Eggs(Pooled
Sample Day 2-10)

	TRR = 4.586 ppm	TRR = 0.011 ppm	TRR = 0.011 ppm	TRR = 0.062 ppm	TRR =
0.011 ppm

	%TRR	ppm	% TRR	ppm	% TRR	ppm	% TRR	ppm	%TRR	ppm

Saflufenacil	53.2	2.525	54.7	0.006	26.1	0.002	47.4	0.029	20.8	0.002

M800H01	20.6	0.979	3.2	<0.0005	1.7	<0.0005	24.0	0.014	-	-

M800H021	6.7	0.316	1.0	<0.0005	-	-	3.2	0.002	-	-

M800H03	3.9	0.186	1.2	<0.0005	-	-	2.0	0.001	-	-

M800H05	7.6	0.362	1.0	<0.0005	2.3	<0.0005	2.2	0.001	-	-

M800H10	1.6	0.074	23.1	0.002	15.8	0.001	7.6	0.005	67.6	0.008

M800H11 	3.9	0.185	1.0	<0.0005	-	-	2.6	0.002	–	–

Total identified	97.5	4.627	85.2	0.009	45.9	0.004	89.0	0.054	88.4	0.010

Total characterized	1.4	0.064	3.3	<0.0005	48.1	0.0044	6.5	0.004	9.2
0.001

Total extractable	98.9	4.690	93.4	0.010	94.7	0.0084	95.2	0.058	94.8
0.011

Unextractable2	1.1	0.051	6.6	0.001	5.3	0.0004	5.0	0.003	5.2	0.001

Accountability3	103%	100%	80%	98%	109%

1  The excreta extract contained the metabolite M800H02 (identified by
LC-MS/MS) and potentially in addition the metabolite M800H06 (not
separated by HPLC).

2  Residues remaining after exhaustive extractions.

3  Accountability = (Total extractable + Total unextractable)/(TRR from
combustion analysis) × 100.



TABLE 17.  Summary of Characterization and Identification of Radioactive
Residues in Hen Matrices Following Application of [Uracil-4-14C]
Saflufenacil (~47X).

Compound	Excreta(Pooled Sample Day 1-10)	Muscle	Fat	Liver	Eggs(Pooled
Sample Day 2-10)

	TRR = 3.825 ppm	TRR = 0.011 ppm	TRR = 0.011 ppm	TRR = 0.060 ppm	TRR =
0.016 ppm

	%TRR	ppm	% TRR	ppm	% TRR	ppm	% TRR	ppm	%TRR	ppm

Saflufenacil	50.4	2.027	38.2	0.005	24.0	0.002	47.0	0.028	9.9	0.002

M800H01	22.1	0.888	2.4	<0.0005	1.8	<0.0005	21.0	0.012	0.8	<0.0005

M800H021	7.6	0.305	0.3	<0.0005	2.4	<0.0005	1.9	0.001	–	–

M800H03	3.8	0.153	1.3	<0.0005	–	–	2.4	0.001	–	–

M800H05	7.2	0.289	–	–	0.7	<0.0005	1.2	0.001	1.3	<0.0005

M800H10	0.9	0.037	22.0	0.003	12.7	0.001	7.3	0.004	51.6	0.009

M800H11 	4.4	0.177	–	–	1.9	<0.0005	1.4	0.001	2.2	<0.0005

Total identified	96.4	3.876	64.2	0.009	43.5	0.004	82.2	0.048	65.8	0.012

Total characterized	2.4	0.093	18.4	0.003	49.3	0.005	8.3	0.006	17.6	0.003

Total extractable	98.7	3.970	81.9	0.011	93.7	0.009	91.6	0.056	87.7	0.015

Unextractable2	1.3	0.052	18.1	0.003	6.3	0.001	8.2	0.005	12.3	0.002

Accountability3	105%	127%	91%	102%	106%

1  The excreta extract contained the metabolite M800H02 and potentially
in addition the metabolite M800H06 (not separated by HPLC).

2  Residues remaining after exhaustive extractions.

3  Accountability = (Total extractable + Total unextractable)/(TRR from
combustion analysis) × 100.

Conclusions:  The submitted goat and poultry metabolism data are
adequate to satisfy data requirements.  Saflufenacil was metabolized by
several dealkylation steps occurring at two different sites in the
molecule (N-isopropyl-N-methylsulfamide side chain and at the uracil
ring) and via hydrolytic opening of the uracil ring (goat only).  In the
ruminant metabolism study, saflufenacil was a major residue in all
matrices.  Only M800H04, a ring opening product, exceeded 10% of the TRR
and 0.05 ppm (liver; 14.2% of the TRR, 0.543 ppm).  In the poultry
metabolism study, saflufenacil was a major residue in all matrices and
no metabolites exceeded 10% of the TRR and 0.05 ppm.  The HED ROCKS
determined that saflufenacil per se is the only for the tolerance
expression and risk assessment (Memo, B. Daiss, 1/6/09; D359645).  This
conclusion and the decision to exclude the plant metabolites M800H11 and
M800H35 as residues of concern in livestock were based on the low
potential for exposure associated with the currently proposed uses. 
These conclusions will be reevaluated if future proposed uses result in
a significant increase in the livestock dietary burden.

FIGURE 3.  Proposed Metabolic Profile of Saflufenacil in Lactating
Goat.

 

860.1340 Residue Analytical Methods

Plant methods

DER Reference List	47128008.der.doc

BASF Method D0603/02 was developed for determination of residues of
saflufenacil and its metabolites M800H11 and M800H35 in different plant
matrices using LC-MS/MS.  Residues of saflufenacil and its metabolites
M800H11 and M800H35 were extracted from non-oily crop matrices (wheat
grain and hay, garbanzo bean, and peach fruit) with methanol:water
(70:30; v:v). The methanol extract, or in some matrices the concentrated
methanol extract, was partitioned with a mixture of ethyl
acetate-cyclohexane (70:30; v:v) and 0.1% TFA.  An aliquot of the
organic phase was evaporated and reconstituted in methanol:water (50:50;
v:v) for LC-MS/MS analysis.  Oily crops (orange fruit and soybean seed)
were extracted with methanol:water (70:30; v:v) and pre-partitioned with
isooctane.  An aliquot of the aqueous methanol phase or the concentrated
methanol phase was partitioned with a mixture of ethyl
acetate-cyclohexane (70:30; v:v) and 0.1% TFA.  An aliquot of the
organic phase was evaporated and reconstituted in methanol:water (50:50;
v:v) for LC-MS/MS quantitation.  For the residues in oil matrices (corn
oil), samples were extracted with acetonitrile.  Following partitioning
of the acetonitrile extract with isooctane (3 times), an aliquot of the
acetonitrile layer was diluted with methanol-water (50:50; v:v) for
LC-MS/MS determination.  Two transitions per analyte were monitored for
the quantitation and confirmation of saflufenacil, M800H11 and M800H35.
The residues of each analyte were expressed as parent equivalents using
a molecular weight conversion factor (1.0 for saflufenacil, 1.06 for
M800H11, and 1.42 for M800H35).  The LOQ was 0.01 ppm for each analyte
in food matrices (human consumption) and 0.025 ppm for each analyte in
feed matrices (livestock consumption).  The limit of detection (LOD) was
not tested, but set at 20% of LOQ.

.  The method detector response was determined to be linear in the range
of 0.05 ng/mL to 0.5 ng/mL (r ≥0.98).  

The method D0603/02 was successfully validated by an independent
laboratory, ADPEN Laboratories, INC.  

Residues of saflufenacil and its metabolites M800H11 and M800H35 in
soybean matrices (phenyl label) from the metabolism study were extracted
sequentially in methanol and water.  The extractability and
accountability experiments indicate that the recoveries of bioincurred
residues from soybean matrices (forage and straw, except for soybean
pod) with methanol:water (70:30,v/v) were very similar to the metabolism
study.

Conclusions:  Based on validation data provided by the petitioner and
the successful ILV, HED has determined that BASF Method D0603/02 is
suitable as an enforcement method for plant commodities as defined in
SOP No. ACB-019 (9/15/08).  Note that the petitioner submitted a revised
version of the method (MRID# 47796103) in which the calculations section
was revised by removing the directions to correct the results for
apparent residues in the control samples.

Livestock methods

DER Reference List	47128010.der.doc

BASF analytical Method No. L0073/01 was developed for determination of
saflufenacil (BAS 800 H) in livestock matrices using LC-MS/MS. 
Livestock tissue samples including bovine liver, kidney, fat, muscle,
whole milk, skimmed milk, cream, and hen’s egg were extracted with
acetonitrile.  The acetonitrile extract was cleaned-up by liquid/liquid
partition using dichloromethane and water.  The dichloromethane phase
was evaporated and reconstituted in methanol:water (50:50; v:v) for
LC-MS/MS analysis.  Two transition ions were monitored (m/z of 501 to
459 and 501 to 349) for saflufenacil and either of the transitions can
be used for quantitation purposes.

The LOQ and LOD of the method are 0.01 ppm and 0.000084 ppm,
respectively.  Concurrent recovery samples were prepared at LOQ and 10X
LOQ in each matrix and were found generally to be within the acceptable
range of 70% to 120%.  Good linearity between detector response and
concentration of the analyte was observed in the range of 0.01 to 0.25
ng/mL.  The extraction efficiency study was not performed since Method
L0073/01 uses the same extraction solvent as that used in the livestock
metabolism study.  Method L0073/01 was successfully validated by an
independent laboratory.

Conclusions:  Based on validation data provided by the petitioner and
the successful ILV, HED has determined that BASF Method L0073/01 is
suitable as an enforcement method for livestock commodities as defined
in SOP No. ACB-019 (9/15/08).  Note that the petitioner submitted a
revised version of the method (MRID# 47796104) in which the calculations
section was revised by removing the directions to correct the results
for apparent residues in the control samples.

860.1360 Multiresidue Methods (MRM)

DER Reference List	47128010.der.doc

Saflufenacil and its metabolites M800H11 and M800H35 were screened
through the MRM described in the United States Food and Drug
Administration (FDA) Pesticide Analytical Manual, Vol. I (PAM I). 
Saflufenacil and the metabolites were tested using procedures outlined
in Protocols B, C, D, E, and F of the MRM.  All Protocols B, C, D, E,
and F were found to be unsuitable for determination of residues of
saflufenacil and its metabolites M800H11 and M800H35.  Since the
analytes are not N-methyl-carbamates, naturally fluorescent or
substituted urea derivatives, the tests using Protocol A and G were not
performed.

Conclusions:  The MRMs are not suitable for the analysis of saflufenacil
or its metabolites.  The multiresidue methods testing data will be
forwarded to FDA for further evaluation and inclusion of results in PAM
Vol. I.  

860.1380 Storage Stability

Plant commodities

DER Reference List	47523801.der.doc 

Samples of corn (forage, grain, and stover), garbanzo bean (chickpea),
orange (fruit, juice, oil, and pulp), radish roots, grape (raisin), and
soybean (forage, hay, and seed) were fortified separately with
saflufenacil, M800H11, and M800H35 at a level of 1.0 ppm each and were
stored at <-5 ºC for a duration of 0, 44, 130, 214, 410-422, and
548-553 days (approximately 0, 1.5, 4.3, and 7.1, 13.7-14.1, and
18.3-18.4 months).  The samples were analysed for residues of
saflufenacil and the metabolites M800H11 and M800H35 by LC-MS/MS using
BASF Analytical Method Number D0603/02.  The freezer storage stability
results were corrected for mean concurrent recovery values obtained from
freshly fortified samples.

Under these conditions, residues of saflufenacil and its metabolites
M800H11 and M800H35 are stable in/on corn (grain, forage, stover);
soybean (seed, forage, hay); orange (fruit, pulp, juice, oil); radish
(root); grape (raisin); and garbanzo bean (seed) commodities during
frozen storage for up to 548 days.

Sample storage conditions and intervals

The storage intervals and conditions of samples from the residue field
trials, rotational crop field trials, and processing studies which were
submitted to support this petition are presented in Table 18.

Table 18.  Summary of Storage Conditions and Intervals of Samples from
Crop Field Trial, Processing, and Field Rotational Crop Studies.

Matrix 	Storage Temperature (°C)	Actual Storage Duration for Most
Samples	Interval of Demonstrated Storage Stability

Legume Vegetables (MRID 47128218)

Pea, succulent seed with pod	<-5 	83-405 days	548 days

Pea, succulent seed without pod

83-399 days

	Pea, dry seed

317-372 days

	Garbanzo, dry seed

14-353 days

	Soybean, succulent seed with pod

250-342 days

	Soybean, succulent seed without pod

251-289 days

	Soybean, dry seed

193-236 days

	Soybean, forage

225-263 days

	Soybean, hay

228-266 days

	Citrus (MRIDs 47128219 & 47128228)

Orange	<-5	44-417 days	548 days

Grapefruit

57-451 days

	Lemon

43-257 days

	Citrus oil

430 days

	Sunflower (MRID 47128226)

Sunflower, seed	<-5	10-97 days	548 days

Cotton (MRID 47128224 & 47445902)

Cotton, undelinted seed	<-5	7-53 days	548 days

Cotton, gin byproducts	<-5	7-55 days

	Cotton Processed Commodities	<-5	129 days

	Grapes (MRID 47128225 & 47128232)

Grapes 	-5 to -28	389-450 days

	Cereal Grains (MRID 47128223 & 47128231)

Wheat, Forage	<-5	29-392 days	548 days

Wheat, Hay

33-493 days

	Wheat, Grain

10-367 days

	Wheat, Straw

15-387 days

	Corn, K+CWHR

281-462 days 

	Corn, Forage

56-391 days 

	Corn, Grain

70-429 days

	Corn, Stover

70-371 days

	Grain sorghum, Forage

253-363 days

	Grain sorghum, Grain

337-448 days

	Grain sorghum, Stover

250-401 days 

	Rice, Grain

155-381 days

	Rice, Straw

329 days

	Barley, Grain

48-239 days

	Sweet sorghum

353 days

	Pome Fruit (MRIDs 47128220 & 47128229)

Apple Fruit	<-5	304-436 days	548 days

Pear Fruit

411-474 days

	Stone Fruit (MRID 47128221 & 47128230)

Cherry	<-5	32-448 days	548 days

Peach

303-428 days

	Plum

315-432 days

	Tree Nuts (MRID 47128222)

Almond Nutmeat	<-5	330-427 days	548 days

Almond Hulls

417-462 days

	Pecan Nutmeat

265-307 days

	Rotational Crop Study:  Wheat, Lettuce, and Radish as the Rotational
Crops (MRID 47128018)

Wheat, Forage	<-5	109-144 days	548 days

Wheat, Hay

111-133 days

	Wheat, Grain

43-82 days

	Wheat, Straw

50-89 days

	Radish, Tops/Roots

105-267 days

	Lettuce, Leaves

88-273 days

	

Livestock commodities

DER Reference List	47128015.der.doc 

Storage stability was demonstrated concurrently with the analytical
phase of the ruminant feeding study (Table 19).



TABLE 19.  Summary of Storage Conditions and Intervals of Samples from
the Ruminant Feeding Study.

Matrix	Storage Temperature (oC)	Actual Storage Duration1 (days)	Interval
of Demonstrated Storage Stability (days)

Whole Milk	(-18	4-63	51	Demonstrated concurrently with the analytical
phase by storing fortified and untreated control samples (5 g) of whole
milk, muscle, liver, kidney and fat at <-18oC.  After the specified
storage interval, one control sample, two freshly fortified samples and
two stored fortified samples were analyzed. 

Skim Milk

29	Not conducted

	Cream

29	Not conducted

	Muscle

23-30	31

	Liver

24-31	32

	Kidney

24-31	32

	Fat

27-34	35

	1  From sample collection to analysis.

Conclusions:  Adequate storage stability data have been submitted. 
Residues of saflufenacil, M800H11, and M800H35 were stable (<30%
degradation) in all plant matrices during freezer storage for up to 548
days; and residues of saflufenacil were stable in all ruminant matrices
during freezer storage for up to 35 days.  These data support the
storage conditions and intervals of samples collected from the various
crop field trials, the rotational crop studies, and the ruminant feeding
study.  There are no unresolved storage stability issues, and no
corrections need to be applied to the various magnitude of the residue
studies.  

860.1480 Meat, Milk, Poultry, and Eggs

Livestock dietary burdens

The potential for secondary transfer of saflufenacil residues of concern
in meat, milk, and eggs exists because there are livestock feedstuffs
associated with the proposed uses on apples, citrus, cereal grains,
legumes, sunflowers, and almonds.  The livestock dietary burdens of
saflufenacil and its metabolites are presented in Table 20 and reflect
the most recent guidance from HED (June, 2008) concerning revisions of
feedstuff percentages in Table 1 and constructing reasonably balanced
dietary burdens (RBDBs).  The calculated total dietary burdens of
saflufenacil and its metabolites (based on tolerance-level residues) are
0.12 ppm for beef cattle, 0.24 ppm for dairy cattle, 0.27 ppm for
poultry, and 0.18 ppm for swine.  

Table 20a.  Beef Cattle Dietary Burden Contribution for Saflufenacil. 

Feedstuff	Type1	Tolerance

(ppm)	% Dry Matter	% Diet2	Dietary Contribution (ppm)3

Target % Diet Roughage	15

	Corn, field, forage	R	0.10	40	15	0.038



Target % Diet Carbohydrate Concentrate	80

	Corn, field, grain	CC	0.03	88	80	0.027



Target % Diet Protein Concentrate	5

	Sunflower meal	PC	1.0	92	5	0.054

TOTALS	100	0.12



Table 20b.  Dairy Cattle Dietary Burden Contribution for Saflufenacil. 

Feedstuff	Type1	Tolerance

(ppm)	% Dry Matter	% Diet2	Dietary Contribution (ppm)3

Target % Diet Roughage	45

	Corn, field, forage	R	0.10	40	45	0.11



Target % Diet Carbohydrate Concentrate	45

	Corn, field, grain	CC	0.03	88	45	0.015



Target % Diet Protein Concentrate	10

	Sunflower meal	PC	1.0	92	10	0.11

TOTALS	100	0.24



Table 20c.  Poultry Dietary Burden Contribution for Saflufenacil.

Feedstuff	Type1	Tolerance

(ppm)	% Dry Matter	% Diet2	Dietary Contribution (ppm)3



Target % Diet Carbohydrate Concentrate	75

	Corn, field, grain	CC	0.03	--	75	0.022



Target % Diet Protein Concentrate	25

	Sunflower meal	PC	1.0	--	25	0.25

TOTALS	100	0.27



Table 20d.  Swine Dietary Burden Contribution for Saflufenacil. 

Feedstuff	Type1	Tolerance

(ppm)	% Dry Matter	% Diet2	Dietary Contribution (ppm)3



Target % Diet Carbohydrate Concentrate	85

	Corn, field, grain	CC	0.03	--	85	0.026



Target % Diet Protein Concentrate	15

	Sunflower meal	PC	1.0	--	15	0.15

TOTALS	100	0.18

1  R:  Roughage; CC:  Carbohydrate concentrate; PC:  Protein
concentrate.

2  OPPTS 860.1000 Table 1 Feedstuffs (June 2008).  

3  Dietary contribution = tolerance ÷% dry matter x % diet (for poultry
and swine % dry matter is not considered). 

Livestock feeding studies

DER Reference List	47128015.der.doc (Dairy cattle feeding study)

			Poultry feeding waiver request 

Dairy cattle feeding study

Saflufenacil was administered orally in treated feed to 14 Friesian
dairy cows for 28-29 consecutive days.  The target doses were 0.1
(0.4X), 0.3 (1.2X), and 1.0 ppm (4.0X) (corresponding to target doses
per unit body weight of 0.0036, 0.011, and 0.036 mg/kg bw/day).  The
actual residue intakes (mean) in the diets were 0.118, 0.363, and 1.386
ppm.  Three animals were allocated each to the 0.1-ppm and 0.3-ppm dose
groups, while five cattle were placed in the 1.0-ppm group, with the
additional two animals being used for the depuration study.  Three
animals were allocated to the untreated control group.  Samples of whole
milk were collected twice daily during the dosing period.  Whole milk
samples from each dose group were analyzed for saflufenacil residues on
study days -3, -1, 1, 3, 6, 9, 12, 15, 18, 21, 24, 28 or 29, 30, and 35.
 Samples of day-22 milk were separated into skim milk and cream, and
each was analyzed.  On study day 28 or day 29, animals were sacrificed
and samples of liver, kidney, composite muscle, and composite fat were
collected for analysis.  Depuration studies were conducted for the
1.0-ppm dosing group where selected animals were sacrificed 2 days (day
30) and 7 days (day 35) after withdrawal of the dose.  Sample stability
over the storage interval used during the study was demonstrated
concurrently by storing fortified samples of untreated milk and tissues.
 Residues of saflufenacil were determined using LC-MS/MS, BASF
Analytical Method No. L0073/01.  

In whole milk samples, residues of saflufenacil were <0.01 ppm (<LOQ)
over the entire 28- to 29-day dosing period.  Residues of saflufenacil
did not concentrate in samples of skim milk (<0.01 ppm) or cream (<0.01
ppm).  In tissues, residues of saflufenacil were not quantifiable in fat
(<0.01 ppm) or muscle (<0.01 ppm).  There was a linear relationship
between the feeding level and residues of saflufenacil in kidney and
liver.  Residues of saflufenacil in kidney were <0.01 ppm at the 0.1-ppm
dose level, 0.02 ppm at the 0.3-ppm dose level and ranged from 0.03 ppm
to 0.04 ppm at the 1.0-ppm dose level.  In liver, residues of
saflufenacil ranged from 0.17 ppm to 0.26 ppm at the 0.1-ppm dose level,
0.67 ppm to 0.88 ppm at the 0.3-ppm dose level, and from 2.09 ppm to
3.49 ppm at the 1.0-ppm dose level. 

Following withdrawal of the dose, residues of saflufenacil were <0.01
ppm (<LOQ) in samples of whole milk, muscle, and fat on day 30 and day
35 of the study.  In kidney, residues of saflufenacil decreased from
0.03 ppm at day 30 to <0.01 ppm at day 35.  In liver, residues of
saflufenacil decreased from 1.66 ppm at day 30 to 0.34 ppm at day 35. 
Half lives of 2.5 and 4.0 days were calculated for saflufenacil residues
in liver and kidney, respectively.

TABLE 21.  Summary of Residue Data from Ruminant Feeding Study with
Saflufenacil.1

Matrix	Target Feeding Level (ppm)	Residue Levels (ppm)



n	Min.	Max.	Median	Mean	Std. Dev.

Whole milk/day 1-28/29	0	3	<0.01	<0.01	<0.01	<0.01	0

	0.1 (0.4X)	3	<0.01	<0.01	<0.01	<0.01	0

	0.3 (1.2X)	3	<0.01	<0.01	<0.01	<0.01	0

	1.0 (4.0X)	5	<0.01	<0.01	<0.01	<0.01	0

Skim milk/day 22	0	3	<0.01	<0.01	<0.01	<0.01	0

	0.1 (0.4X)	3	<0.01	<0.01	<0.01	<0.01	0

	0.3 (1.2X)	3	<0.01	<0.01	<0.01	<0.01	0

	1.0 (4.0X)	5	<0.01	<0.01	<0.01	<0.01	0

Cream/day 22	0	3	<0.01	<0.01	<0.01	<0.01	0

	0.1 (0.4X)	3	<0.01	<0.01	<0.01	<0.01	0

	0.3 (1.2X)	3	<0.01	<0.01	<0.01	<0.01	0

	1.0 (4.0X)	5	<0.01	<0.01	<0.01	<0.01	0

Fat	0	3	<0.01	<0.01	<0.01	<0.01	0

	0.1 (0.4X)	3	<0.01	<0.01	<0.01	<0.01	0

	0.3 (1.2X)	3	<0.01	<0.01	<0.01	<0.01	0

	1.0 (4.0X)	3	<0.01	<0.01	<0.01	<0.01	0

Muscle	0	3	<0.01	<0.01	<0.01	<0.01	0

	0.1 (0.4X)	3	<0.01	<0.01	<0.01	<0.01	0

	0.3 (1.2X)	3	<0.01	<0.01	<0.01	<0.01	0

	1.0 (4.0X)	3	<0.01	<0.01	<0.01	<0.01	0

Liver	0	3	<0.01	<0.01	<0.01	<0.01	0

	0.1 (0.4X)	3	0.17	0.26	0.19	0.21	0.047

	0.3 (1.2X)	3	0.67	0.88	0.76	0.77	0.105

	1.0 (4.0X)	3	2.09	3.49	2.25	2.61	0.77

Kidney	0	3	<0.01	<0.01	<0.01	<0.01	0

	0.1 (0.4X)	3	<0.01	<0.01	<0.01	<0.01	0

	0.3 (1.2X)	3	0.02	0.02	0.02	0.02	0

	1.0 (4.0X)	3	0.03	0.04	0.04	0.037	0.006

1  The LOQ for saflufenacil in all matrices analyzed was reported as
0.01 ppm.

Expected secondary residues in meat and milk

To determine the need for tolerances for saflufenacil residues in milk
and tissues, the anticipated secondary residues in cattle matrices were
estimated using transfer coefficient factors calculated from the maximum
residues of saflufenacil observed in the ruminant feeding study.  The
transfer coefficients (calculated as residue-level-to-feed ratios) are
presented in Table 22.  The transfer coefficient for each matrix was
then used to calculate the expected secondary residues by multiplying
the transfer coefficient by the calculated dietary burden (Table 21).  

Table 22.  Residue-Level-to-Feed Ratios (Transfer Coefficients) in Dairy
Cattle Milk and Tissues.1

Matrix	Maximum Residue (ppm)	Feeding Level, ppm	Transfer Coefficient

Milk/Cream	<0.01	1.0	<0.01

Fat	<0.01

<0.01

Muscle 	<0.01

<0.01

Kidney	0.02	0.3	0.067

	0.04	1.0	0.04

Liver	0.26	0.1	2.6

	0.88	0.3	2.9

	3.49	1.0	3.49

1  Calculated from the maximum residues divided by the dose level.

Table 23.  Expected Secondary Residues in Meat and Milk.

Matrix	Dietary burden (ppm)	Secondary Residues (ppm)1	Proposed Tolerance
(ppm)	Recommended Tolerance (ppm)2

Milk 	0.24	<0.0024	-	0.01

Fat

<0.0024	-	0.01

Kidney

0.013	0.02	0.023

Muscle 

<0.0024	-	0.01

Liver

0.72	0.80	0.80

1  Calculated from dietary burden x average transfer coefficient from
Table 22.  

2  HED is recommending for LOQ-level tolerances as a 10X feeding level
was not included in the feeding study.

3  Meat byproducts, except liver.

Conclusions:  The residue data from the cattle feeding study is adequate
to satisfy data requirements.  The feeding study data indicate that
tolerances are needed for residues of saflufenacil at 0.80 ppm in liver
and at 0.02 ppm in the meat byproducts, except liver of cattle, goats,
horses, hogs, and sheep.  HED is recommending for LOQ-level tolerances
(0.01 ppm) for fat, meat, and milk as a 10X feeding level was not
included in the feeding study.  

Poultry feeding study waiver request

BASF submitted a rationale to waive the data requirement for a poultry
feeding study (MRID No. 47128019).  The petitioner argues that, based on
the results of the laying hen metabolism study (conducted for 10 days,
residues in eggs plateaued by day 6) and the proposed tolerances in
poultry feed components, the potential for secondary residues in poultry
products would be negligible.  The anticipated total residues (maximum
TRR in each matrix from the hen metabolism study ÷ 47X) were 0.0013 ppm
in liver and 0.0002-0.0003 ppm each in egg, muscle and fat.  Taking into
account that the parent saflufenacil accounted for 47% of the TRR in
liver from the hen metabolism study; the absolute amount of saflufenacil
in liver would be 0.00061 ppm (47% x 0.0013 ppm TRR in liver) at the 1X
feeding level and 0.0061 ppm at the 10X feeding level.  The LOQ of the
proposed enforcement method is 0.01 ppm for saflufenacil in eggs and
bovine matrices.  Therefore, assuming the maximum dietary burden, the
anticipated levels of saflufenacil would <LOQ in all matrices.  The
basis of the rationale to waive the data requirement for a poultry
feeding study is deemed acceptable.  The results of the hen metabolism
study indicate that there is no reasonable expectation of finite
residues of saflufenacil in the meat, meat byproducts, and eggs of
poultry as a result of the proposed uses.

860.1500 Crop Field Trials

Legume Vegetables, Crop Groups 6 and 7

DER Reference List	47128218.der.doc

BASF Agro Research has submitted field trial data for saflufenacil on
pea, garbanzo beans (chickpeas), and soybean as representative crops of
crop groups 6, legume vegetables; and 7, foliage of legume vegetables. 
Thirty-nine trials were conducted on legume vegetables in the U.S. and
Canada during the 2006 and 2007 growing seasons.  These included 13
trials on peas in NAFTA Zones 1 (NY and PA; 1 trial each), 5 (IL, IA,
MB, and MN; 1 trial each), 10 (CA; 1 trial), 11 (ID; 1 trial), 12 (OR; 1
trial), and 14 (AB; 2 trials, MB; 1 trial, and SK; 1 trial); 11 trials
on garbanzo beans (chickpeas) in NAFTA Zones 5 (MB and MN; 2 trials
each), 6 (OK; 1 trial), 7 (SK; 1 trial), 7A (AB; 1 trial), 8 (TX; 1
trial), 9 (UT; 1 trial), 10 (CA; 1 trial), and 11 (ID; 1 trial); and 15
trials on soybeans in NAFTA Zones 2 (GA and VA; 1 trial each), 4 (AR and
LA; 1 trial each), and 5 (IL; 1 trial, IA; 1 trial, KS; 2 trials, MB; 2
trials, MN; 2 trials, NE; 1 trial, ND; 1 trial, and ON; 1 trial).

Each trial location consisted of one control plot and one or two treated
plots.  For sites with two treatment plots, one plot was designated to
produce succulent peas/beans (representing edible-podded seed and
succulent shelled seed) and the second plot was designated to produce
dried pea and bean seeds.  At each treated plot, a single pre-plant
incorporated or pre-emergence soil broadcast application of the 70% WG
formulation of saflufenacil (BAS 800 00 H) was made at a rate of
0.083-0.093 lb ai/A (0.93-1.1X).  The applications were made using
ground equipment in spray volumes of 16-31 gal/A.  An adjuvant was
included in the spray mixture. 

Samples of pea and soybean immature pod with seed were harvested by hand
62-119 days after treatment, targeting growth stage BBCH 73-77, to yield
succulent seed with pod.  A portion was shelled to generate samples of
succulent seed without pod.  Soybean forage and hay samples were
harvested at the same time the succulent pods were collected; hay
samples were air-dried under ambient conditions.  Samples of mature pea,
garbanzo bean, and soybean dry seed were harvested 82-117 days after
treatment, 93-148 days after treatment, and 82-162 days after treatment,
respectively.  At four sites, additional samples of succulent pea,
succulent soybean seed, soybean forage, and soybean hay were collected
at 2-3 additional sampling intervals to evaluate residue decline.

Samples of legume vegetable RACs were analyzed for residues of
saflufenacil and its metabolites M800H11 and M800H35 using an LC-MS/MS
method, BASF Analytical Method Number D0603.  This method is adequate
for data collection based on acceptable concurrent method recoveries. 
The LOQ was 0.025 ppm for each analyte (0.075 ppm combined) in soybean
forage and hay and 0.01 ppm for each analyte (0.03 ppm combined) in all
other commodities.  

Residues of saflufenacil, M800H11, and M800H35 were each below the LOQ
in/on all collected samples of the following RACs:  succulent pea seed
with pod; succulent pea seed without pod; dried pea seed; dried garbanzo
bean seed; succulent soybean seed with pod; succulent soybean seed
without pod; mature soybean seed; soybean forage; and soybean hay. 
Because residues were <LOQ in/on all samples from the four decline
trials, residue decline could not be evaluated.

Conclusions:  The submitted residue data for legume vegetables, crop
groups 6 and 7 are adequate to fulfill data requirements.  The number
and locations of the crop field trials are in accordance with OPPTS
Guideline 860.1500 (Table 24).  This residue program was previously
approved by HED (Memorandum of Understanding, BASF with EPA and PMRA,
1/25/06; MRID No. 47128215).  The available data will support the
proposed use pattern.

TABLE 24.  Trial Numbers and Geographical Locations for Legume
Vegetables, Crop Groups 6 and 7.

NAFTA Growing Zones	Pea, Dry	Pea, Succulent	Garbanzo (Bean, Dried)
Soybean

	Submitted	Requested1	Submitted	Requested1	Submitted	Requested1
Submitted	Requested1



Canada	U.S.2

Canada	U.S.2

Canada	U.S.3

Canada	U.S.4

1



	1	15







1A	2

	2	1







	2





15



2

2

4









2

2

5

2

	3	4	4	4	4	11	11	11

5B	4

	4	2





1

	6





	1





	7





	1

1



	7A





	1	1





8





	1

1



	9





	1

1



	10





	1

1



	11	1

	1

2	1

1



	12	1

	1	1	1







14	4	6

4









Total	13	8	5	13	8	8	11	5	9	15	12	15

1  As required under OPPTS 860.1500 Tables 1, 2, and 5 and PMRA
Directive 98-02 Section 9 Table 2.

2  As required under OPPTS 860.1500 Tables 1 and 5 for succulent and
dried pea; no regions specified for dried peas.

3  As required under OPPTS 860.1500 Table 5 for dried bean as a
representative crop of crop group 6.

4  As required under OPPTS 860.1500 Table 5 for soybean as
representative crop of crop groups 6 and 7.

5  One trial should be conducted in either Zone 1 or Zone 2.

The residue data for legume vegetables, crop groups 6 and 7 were not
entered into the Agency’s tolerance spreadsheet as specified by the
Guidance for Setting Pesticide Tolerances Based on Field Trial Data SOP
as all residues were <LOQ (0.025 ppm for each analyte (0.075 ppm
combined) in soybean forage and hay and 0.01 ppm for each analyte (0.03
ppm combined) in all other commodities)).  The recommended tolerances
for the combined residues of saflufenacil and its metabolites M800H11
and M800H35, expressed as parent equivalents, are 0.03 ppm for legume
vegetables (group 6) and 0.10 ppm for the foliage of legume vegetables
(group 7). 

Citrus Fruit, Crop Group 10

DER Reference List	47128219.der.doc

BASF Corporation has submitted field trial data for saflufenacil on
orange, grapefruit, and lemon as representative crops of crop group 10,
citrus fruit.  A total of 23 citrus fruit field trials were conducted in
the U.S. during the 2006 and 2007 growing seasons.  Twelve orange trials
were conducted in NAFTA Zones 3 (FL; 8 trials), 6 (TX, 1 trial), and 10
(CA; 3 trials).  Six grapefruit trials were conducted in NAFTA Zones 3
(FL; 3 trials), 6 (TX; 1 trial), and 10 (AZ and CA; 1 trial each).  Five
lemon trials were conducted in NAFTA Zones 3 (FL; 1 trial) and 10 (AZ
and CA, 2 trials each).

Each trial location consisted of one untreated and one treated plot.  At
each treatment plot, three broadcast applications of the 70% WG
formulation of saflufenacil (BAS 800 00 H) were made to the orchard
floor at 0.043-0.049 lb ai/A/application with a 20- to 22-day
retreatment interval (RTI), for a total seasonal rate of 0.134-0.141 lb
ai/A (1.0-1.1X).  Applications were made using ground equipment, in
20-36 gal/A spray volumes.  An adjuvant was included in the spray
mixture.  Samples of mature citrus fruit were harvested on the day of
the last application.  Additional samples of treated orange fruit were
harvested at 7-, 14-, and 21-day PHIs from two FL sites.

Samples of citrus fruit RACs were analyzed for residues of saflufenacil
and its metabolites M800H11 and M800H35 using an LC-MS/MS method, BASF
Analytical Method Number D0603.  This method is adequate for data
collection based on acceptable concurrent method recoveries.  Residues
were reported in ppm saflufenacil equivalents.  The LOQ was 0.01 ppm for
each analyte in each matrix.  

Residues of saflufenacil, M800H11, and M800H35 were each below the LOQ
in/on all samples of orange, grapefruit, and lemon harvested the day of
the last of three soil broadcast applications at a total rate of
0.134-0.141 lb ai/A.  Residues of saflufenacil, M800H11, and M800H35
were each <LOQ in/on samples of citrus fruit harvested 7, 14, and 21
days after the last application.

Conclusions:  The submitted field trial data for citrus are adequate to
fulfill data requirements.  The number and locations of the trials are
in accordance with OPPTS Guideline 860.1500 (Table 25).  The available
data will support the proposed use pattern.

TABLE 25.  Trial Numbers and Geographical Locations for Citrus.

NAFTA Growing Zones	Orange	Grapefruit	Lemon

	Submitted	Requested1	Submitted	Requested1	Submitted	Requested1



Canada	U.S.

Canada	U.S.

Canada	U.S.

3	8

8	3

3	1

1

6	1

1	1

1



	10	3

3	2

2	4

4

Total	12

12	6

6	5

5

1  As required under U.S. EPA OPPTS 860.1500 Tables 2 and 5 for orange,
grapefruit, and lemon as representative crops of crop group 10, citrus
fruit.

The residue data for citrus were not entered into the Agency’s
tolerance spreadsheet as specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data SOP as all residues were <LOQ (0.01
ppm for each analyte (0.03 ppm combined)).  The recommended tolerances
for the combined residues of saflufenacil and its metabolites M800H11
and M800H35, expressed as parent equivalents, are 0.03 ppm for fruit,
citrus, group 10.

Pome Fruit, Crop Group 11

DER Reference List	47128220.der.doc

BASF Corporation has submitted field trial data for saflufenacil on
apple and pear as representative crops of crop group 11, pome fruit.  A
total of 25 pome fruit field trials were conducted in the U.S. and
Canada during the 2006 growing season.  Fifteen trials were conducted on
apples in NAFTA Zones 1 (NY; 3 trials), 2 (VA, 1 trial), 5 (MI; 2
trials, IL; 1 trial, and ON; 1 trial), 5B (QC; 1 trial), 9 (UT; 1
trial), 10 (CA; 1 trial), and 11 (ID and WA; 2 trials each).  Ten trials
were conducted on pears in NAFTA Zones 1 (NY; 2 trials), 5 (MI; 2 trials
and ON; 1 trial), 10 (CA; 2 trials), and 11 (ID; 1 trial and WA; 2
trials).  

Each trial location consisted of one untreated and two treated plots. 
At each treatment plot, three broadcast applications of the 70% WG
formulation of saflufenacil (BAS 800 00 H) were made to the orchard
floor at 0.042-0.047 lb ai/A/application for a total rate of 0.129-0.140
lb ai/A (1.0-1.1X).  The initial application was made at dormancy,
121-210 days before harvest [except at one apple site where the
application was made during fruiting at 64 days prior to harvest].  The
two subsequent applications were made, at 19-22 days before harvest (28
days before harvest at one apple site) and on the day of harvest.  The
applications were made using ground equipment in 20-38 gal/A spray
volumes.  An adjuvant was included in the spray mixture.

Samples of mature pome fruit were collected from each plot at each site
on the day of the last application.  At one apple and one pear site,
additional samples were collected 7, 14, and 21 days after the last
application to evaluate residue decline.  

Samples of apple and pear RACs were analyzed for residues of
saflufenacil and the metabolites M800H11 and M800H35 using an LC-MS/MS
method, BASF Analytical Method Number D0603.  This method is adequate
for data collection based on acceptable concurrent method recoveries. 
The LOQ was 0.01 ppm for each analyte in apple and pear.  

Residues of saflufenacil, M800H11, and M800H35 were each below the LOQ
in/on all samples of apple and pear harvested the day of the last of
three soil broadcast applications at a total rate of 0.129-0.140 lb ai/A
(1.0-1.1X).  Because residues were <LOQ in/on all samples from the
decline trials, residue decline could not be evaluated.

Conclusions:  The submitted field trial data for pome fruit are adequate
to fulfill data requirements.  The number and locations of the trials
are in accordance with OPPTS Guideline 860.1500 (Table 26).  The
available data will support the proposed use pattern.



TABLE 26.  Trial Numbers and Geographical Locations for Pome Fruit.

NAFTA Growing Zones	Apple	Pear

	Submitted	Requested1`	Submitted	Requested1



Canada	U.S.

Canada	U.S.

1	3	1	3	2

1

1A

1

	1

	2	1

1



	5	4	4	2	3	3

	5A







5B	1	3





9	1

1



	10	1

1	2

2

11	4	3	4	3	1	3

Total	15	12	12	10	5	6

1  As required under OPPTS 860.1500 Tables 2 and 5 for apple and pear as
representative crops of the pome fruit crop group (crop group 11), and
PMRA Directive 98-02 Section 9 Table 2.

The residue data for pome fruit were not entered into the Agency’s
tolerance spreadsheet as specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data SOP as all residues were <LOQ (0.01
ppm for each analyte (0.03 ppm combined)).  The recommended tolerances
for the combined residues of saflufenacil and its metabolites M800H11
and M800H35, expressed as parent equivalents, are 0.03 ppm for fruit,
pome, group 11.

Stone Fruit, Crop Group 12

DER Reference List	47128221.der.doc

BASF Corporation has submitted field trial data for saflufenacil on
cherry, peach, and plum as representative crops of crop group 12, stone
fruit.  A total of 29 stone fruit field trials were conducted in the
U.S. and Canada during the 2006 and 2007 growing seasons.  Six trials
were conducted on cherry (three each on sweet and tart cherry) in NAFTA
Zones 5 (MI; 2 trials and ON; 1 trial), 10 (CA; 1 trial), and 11 (ID and
WA, 1 trial each).  Thirteen trials were conducted on peach in NAFTA
Zones 1 (NY; 1 trial), 2 (GA; 3 trials), 5 (IL and MI; 1 trial each and
ON; 2 trials), 6 (OK; 1 trial), 10 (CA; 3 trials), and 11 (ID; 1 trial).
 Ten trials were conducted on plum in NAFTA Zones 1 (NY; 1 trial), 5
(MI; 2 trials and ON; 1 trial), 10 (CA; 4 trials), 11 (WA; 1 trial), and
12 (OR; 1 trial).  

Each trial location consisted of one untreated and two treated plots. 
In each treated plot, three broadcast applications of the 70% WG
formulation of saflufenacil (BAS 800 00 H) were made to the orchard
floor at 0.041-0.047 lb ai/A/application with a 20- to 174-day RTI, for
a total seasonal rate of 0.131-0.140 lb ai/A (1.0-1.1X).  Applications
were made using ground equipment in 20-36 gal/A spray volumes.  An
adjuvant was included in the spray mixture.

Samples of mature stone fruit were harvested on the day of the last
application.  Additional samples of treated fruit were harvested at
approximately 7-, 14-, and 21-day PHIs.

Samples of stone fruit RACs were analyzed for residues of saflufenacil
and metabolites M800H11 and M800H35 using an LC-MS/MS method, BASF
Analytical Method Number D0603.  This method is adequate for data
collection based on acceptable concurrent method recoveries.  The LOQ
was 0.01 ppm for each analyte in each matrix.  

Residues of saflufenacil, M800H11, and M800H35 were each below the LOQ
(0.01 ppm each analyte) in/on all samples of cherry, peach, and plum
fruit harvested the day of the last of three soil broadcast applications
at a total rate of 0.131-0.140 lb ai/A (1.0-1.1X).  Residues of
saflufenacil, M800H11, and M800H35 were also <LOQ in/on all fruit
samples harvested 6-8, 13-14, and 20-21 days after the last application.

Conclusions:  The submitted field trial data for stone fruit are
adequate to fulfill data requirements.  The number and locations of the
trials are in accordance with OPPTS Guideline 860.1500 (Table 27).  This
residue program was previously approved by HED (Memorandum of
Understanding, BASF with EPA and PMRA, 1/25/06; MRID No. 47128215).  The
available data will support the proposed use pattern.

TABLE 27.  Trial Numbers and Geographical Locations for Stone Fruit.

NAFTA Growing Zones	Cherry	Peach	Plum

	Submitted	Requested1	Submitted	Requested1	Submitted	Requested1



Canada	U.S.2

Canada	U.S.2

Canada	U.S.2

1

	1 (tart)	1

1	1



1A







1

	2



3

3



	5	3 (tart)	3	2 (sweet); 4 (tart)	4	4	1	3	3	1

6



1

1



	9

	1 (tart)







10	1 (sweet)

2 (sweet)	3

3	4

4

11	2 (sweet)	2	2 (sweet)	1	1

1	1

	12





	1

1

Total	6	5	6	13	5	9	10	5	6

1  As required under OPPTS 860.1500, Tables 2 and 5 for cherry, peach,
and plum as representative crops of Crop Group 12, Stone Fruit, and PMRA
Directive 98-02 Section 9 Table 2.

2  To support a Crop Group 12 tolerance, OPPTS 860.1500, Table 2
requires six cherry field trials with sweet or tart cherry. 

The residue data for stone fruit were not entered into the Agency’s
tolerance spreadsheet as specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data SOP as all residues were <LOQ (0.01
ppm for each analyte (0.03 ppm combined)).  The recommended tolerance
for the combined residues of saflufenacil and its metabolites M800H11
and M800H35, expressed as parent equivalents, is 0.03 ppm for fruit,
stone, group 12.

Tree Nuts, Crop Group 14

DER Reference List	47128222.der.doc

BASF Corporation has submitted field trial data for saflufenacil on
almond and pecan, the representative crops of crop group 14, tree nuts. 
Ten tree nut field trials were conducted in the U.S. during the 2006
growing season.  Five trials were conducted on almond in NAFTA Zone 10
(CA; 5 trials) and five trials were conducted on pecan in NAFTA Zones 2
(GA; 2 trials), 4 (LA; 1 trial), 6 (TX; 1 trial), and 8 (TX; 1 trial).  

Each trial location consisted of one untreated and two treated plots. 
At each treatment plot, three broadcast applications of the 70% WG
formulation of saflufenacil (BAS 800 00 H) were made to the orchard
floor at 0.044-0.046 lb ai/A/application for a total seasonal rate of
0.133-0.137 lb ai/A (1.0X).  The first application was made at dormancy
(169-243 days before harvest), the second 20-24 days before harvest, and
the third at maturity, mostly at 7-14 DAT.  Applications were made using
ground equipment, in 19-31 gal/A spray volumes.  An adjuvant was
included in the spray mixture.

Samples of mature almond nutmeat, pecan nutmeat, and almond hulls were
harvested approximately 7 and 14 days after the last application. 
Additional samples of treated almond nutmeat and hulls were collected
0-, 21-, and 28-day PHIs at one CA site to evaluate residue decline.

Samples of tree nut RACs were analyzed for residues of saflufenacil and
metabolites M800H11 and M800H35 using an LC-MS/MS method, BASF
Analytical Method Number D0603.  This method is adequate for data
collection based on acceptable concurrent method recoveries.  The LOQ
was 0.025 ppm for each analyte in almond hulls and 0.01 ppm for each
analyte in nutmeats. 

Residues of saflufenacil, and the metabolites M800H11, and M800H35 were
each below the LOQ in/on all samples of almond nutmeat, almond hulls,
and pecan nutmeat harvested 7 or 14 days after the last of three soil
broadcast applications at a total rate of 0.133-0.137 lb ai/A (1.0X).

Residues of saflufenacil, M800H11, and M800H35 were each below the LOQ
in/on all samples of almond nutmeat from the decline trial; therefore,
residue decline in almond nutmeat could not be evaluated.  In almond
hulls, residues of saflufenacil were 0.089-0.131 ppm at the 0-day PHI
(only 4 samples were harvested at this interval) and below the LOQ in/on
all samples harvested at later PHIs; residues of the metabolites M800H11
and M800H35 were each below the LOQ in/on all samples from the decline
trials.  

Conclusions:  The submitted field trial data for tree nuts are adequate
to fulfill data requirements. The number and locations of the trials are
in accordance with OPPTS Guideline 860.1500 (Table 28).  The available
data will support the proposed use pattern.

TABLE 28.  Trial Numbers and Geographical Locations for Tree Nuts.

NAFTA Growing Zones	Almond	Pecan

	Submitted	Requested	Submitted	Requested



Canada	U.S.1

Canada	U.S.1

2



2

2

4



1

1

6



1

1

8



1

1

10	5

5



	Total	5

5	5

5

1  As required under OPPTS 860.1500 Tables 2 and 5 for almond and pecan
as representative crops of the tree nut crop group (crop group 14).

The residue data for tree nuts were not entered into the Agency’s
tolerance spreadsheet as specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data SOP as all residues were <LOQ
(0.025 ppm for each analyte in almond hulls and 0.01 ppm for each
analyte in nutmeats) at the proposed PHI (7 days).  The recommended
tolerances for the combined residues of saflufenacil and its metabolites
M800H11 and M800H35, expressed as parent equivalents, are 0.03 ppm for
tree nuts, group 14 and 0.10 ppm for almond hulls.  HED notes that
pistachio residue data have not been submitted and concludes that the
tree nut crop group tolerance may be translated to pistachio (see
Reviewer's Guide and Summary of HED ChemSAC Approvals for Amending
Commodity Definitions (40 CFR 180.1(h)) and Crop Group/Subgroups (40 CFR
180.41)).  

Grapes

DER Reference List	47128225.der.doc

BASF Corporation has submitted crop field trial data for saflufenacil on
grape.  Twelve grape field trials were conducted in the U.S. and Canada
in Zones 1 (NY; 2 trials), 5 (MI, WI, ON; 1 trial each), 10 (CA; 6
trials), and 11 (WA; 1 trial) during the 2006 growing season.  

Each trial location consisted of one untreated and two treated plots. 
Each treated plot received three broadcast applications of the 70% WG
formulation of saflufenacil (BAS 800 00 H) to the vineyard floor at
0.022-0.024 lb ai/A/application for a total seasonal rate of 0.066-0.070
lb ai/A (1.0-1.1X).  The first application was made at dormancy (115-159
days before harvest), the second 20-21 days before harvest, and the
third at maturity.  Applications were made using ground equipment, in
20-36 gal/A spray volumes.  An adjuvant was included in the spray
mixture.

Samples of mature grape fruit RAC were harvested 0 and 13-15 days after
the last application.  The 0-day PHI samples from all sites were
analyzed; the 14-day PHI samples from one CA site were analyzed.

Samples of grapes were analyzed for residues of saflufenacil and
metabolites M800H11 and M800H35 using an LC-MS/MS method, BASF
Analytical Method Number D0603.  This method is adequate for data
collection based on acceptable concurrent method recoveries.  The LOQ
was 0.01 ppm for each analyte.  Apparent residues of saflufenacil,
M800H11, and M800H35 were each <LOQ in/on all samples of untreated
grape.

Residues of saflufenacil, M800H11, and M800H35 were each below the LOQ
in/on all samples of grape harvested on the day of the last of three
soil broadcast applications at a total rate of 0.066-0.070 lb ai/A
(1.0-1.1X).  Residue of saflufenacil, M800H11, and M800H35 were each
<LOQ in/on two samples of grape samples harvested 14 days after the last
application.

Conclusions:  The submitted field trial data for grapes are adequate to
fulfill data requirements. The number and locations of the trials are in
accordance with OPPTS Guideline 860.1500 (Table 29).  This residue
program was previously approved by HED (Memorandum of Understanding,
BASF with EPA and PMRA, 1/25/06; MRID No. 47128215).  The available data
will support the proposed use pattern.

TABLE 29.  Trial Numbers and Geographical Locations for Grapes.

NAFTA Growing Zones	Grape

	Submitted	Requested1



Canada	U.S.

1	2

2 [2]

5	3	4

	10	6

8 [5]

11	1	1	2 [2]

Total	12	5	12 [9]

1  As required under U.S. EPA OPPTS 860.1500 Tables 1 and 5 for grape,
and PMRA Directive 98-02 Section 9 Table 2.  Numbers in brackets
represent the required number of trials for a use resulting in no
quantifiable residues.  

The residue data for grapes were not entered into the Agency’s
tolerance spreadsheet as specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data SOP as all residues were <LOQ (0.01
ppm for each analyte (0.03 ppm combined)).  The recommended tolerance
for the combined residues of saflufenacil and its metabolites M800H11
and M800H35, expressed as parent equivalents, is 0.03 ppm for grape.

Cereal Grains, Crop Groups 15 and 16

DER Reference List	47128223.der.doc

BASF Corporation has submitted field trial data for saflufenacil on
barley, corn (field and sweet), rice, grain sorghum, and wheat in
support of registration of saflufenacil on crop group 15, cereal grains,
and crop group 16, forage, fodder, and straw of cereal grains.  During
the 2006-2007 growing seasons, 66 field trials were conducted on cereal
grains in the U.S. and Canada.  

Twenty-five field trials were conducted on wheat.  Eight trials were
conducted on winter wheat in NAFTA Zones 2 (GA; 1 trial), 4 (AR; 1
trial), 5 (MI; 1 trial), 6 (OK and TX; 1 trial each), and 8 (KS; 2
trials and OK; 1 trial).  Seventeen trials were conducted on spring
wheat in NAFTA Zones 5 (ND and WI; 1 trial each), 7 (NE and SK; 2 trials
each and ND; 1 trial), 7A (AB; 1 trial), 11 (ID; 1 trial), and 14 (AB
and SK; 3 trials each and MB; 2 trials).

Twenty field trials were conducted on corn.  Fifteen trials were
conducted on field corn in NAFTA Zones 1 (NY; 1 trial), 2 (GA; 1 trial),
5 (ND and WI; 3 trials each, MI and MN; 2 trials each, MB and QC; 1
trial each), and 6 (TX; 1 trial).  Five trials were conducted on sweet
corn varieties in NAFTA Zones 3 (FL; 1 trial), 7A (AB; 1 trial), 10 (CA;
1 trial), 11 (ID; 1 trial), and 12 (OR; 1 trial).  

Nine trials were conducted on grain sorghum in NAFTA Zones 4 (AR; 1
trial), 5 (MI and ND; 1 trial each), 6 (OK; 1 trial and TX; 2 trials), 7
(ND; 1 trial), and 8 (KS; 2 trials).

Six trials were conducted on rice in Zones 4 (AR; 2 trials and LA; 1
trial), 5 (MO; 1 trial), 6 (TX; 1 trial), and 10 (CA; 1 trial).

Six trials were conducted on barley in NAFTA Zones 5 (MB; 3 trials) and
7 (AB; 1 trial and SK; 2 trials).

At each trial location, one untreated control and one or two treated
plots were established.  The treated plots received a single broadcast
pre-plant incorporated or pre-emergence application of the 70% WG
formulation of saflufenacil (BAS 800 00 H) to the soil surface at
0.124-0.141 lb ai/A (0.93-1.1X).  The applications were made using
ground equipment in 10-37 gal/A spray volumes.  An adjuvant was included
in the spray mixture.

Samples of wheat forage were collected targeting the 6- to 8-inch stage
to stem elongation (jointing) stage (Treatment 2; around BBCH stage 30)
or early flowering (Treatment 3; around BBCH stage 61).  Wheat hay was
harvested targeting early flower (boot; around BBCH 61) to soft dough
stage (BBCH stage 85) and allowed to field dry to a moisture content
targeting 10-20% (between 2 and 20 days of dry time).  Wheat grain and
straw were harvested at normal maturity.  Wheat samples were collected
from two sites (NE and MB) at additional sampling intervals to evaluate
residue decline.

Corn kernel plus cob with husk removed (K+CWHR) samples were harvested
at commercial maturity at the sweet corn trial sites.  At four of the
field corn trials (Zone 5), field corn was sampled early (at the milk
stage; around BBCH stage 73) to provide residue data translatable to
sweet corn K+CWHR.  Corn forage samples (entire aerial portion of the
plant) were harvested targeting the late dough/early dent stage
(Treatment 2; around BBCH stage 85) or the milk stage (Treatment 3;
around BBCH stage 73).  The milk stage samples were collected to provide
residue data translatable to sweet corn forage.  Field corn grain and
stover RAC samples were harvested at maturity.

Grain sorghum forage samples were harvested targeting the soft dough to
hard dough stage (BBCH stage 85-87), and grain sorghum grain and stover
samples were harvested at maturity.  Rice and barley grain plus hull
samples were harvested at maturity.  Rice straw samples were collected
from one site only, and no samples of barley hay or straw were
collected.  

Samples of cereal grain RACs were analyzed for residues of saflufenacil
and metabolites M800H11 and M800H35 using an LC-MS/MS method, BASF
Analytical Method Number D0603.  This method is adequate for data
collection based on acceptable concurrent method recoveries.  The LOQ
was 0.025 ppm for each analyte in forage, hay, straw, and stover, and
0.01 ppm for each analyte in grain and K+CWHR.  

Following a single broadcast pre-plant incorporated or pre-emergence
application of saflufenacil (70% WG) at 0.124-0.141 lb ai/A (0.93-1.1X),
residues of saflufenacil, M800H11, and M800H35 were each below the LOQ
in/on all samples of treated wheat grain, corn grain, corn K+CWHR,
sorghum grain, rice grain, and barley grain.

Residues of saflufenacil, M800H11, and M800H35 were each below the LOQ
in/on all samples of treated wheat forage, hay, and straw; treated corn
forage and stover; and grain sorghum forage.  Residues of saflufenacil,
M800H11, and M800H35 were each below the LOQ in/on all but four treated
samples of sorghum stover.  Four grain sorghum stover samples, collected
from the same trial in TX, bore quantifiable residues of M800H35 at
0.03-0.04 ppm; residues of saflufenacil and M800H11 were each below the
LOQ in/on these samples.  Residues of saflufenacil, M800H11, and M800H35
were each below the LOQ in/on the two collected samples of treated rice
straw.

Residue decline could not be evaluated because residues of saflufenacil,
M800H11, and M800H35 were each below the LOQ in/on all samples of wheat
forage, hay, grain, and straw from the decline trials.  

No samples of aspirated grains fractions were collected from the field
corn, sorghum, or wheat trials.  Because application of the test
substance was made pre-plant or pre-emergence and residues in grain were
<LOQ for all samples, no residue data for aspirated grain fractions are
required.

Conclusions:  The submitted field trial data for cereal grains are
adequate to fulfill data requirements.  The number and locations of the
trials are generally in accordance with OPPTS Guideline 860.1500 (Table
30).  This residue program was previously approved by HED (Memorandum of
Understanding, BASF with EPA and PMRA, 1/25/06, MRID No. 47128215; and
Minutes of the 1/18/06 ChemSAC).  The available data will support the
proposed use pattern.

TABLE 30a.  Trial Numbers and Geographical Locations (Sorghum, Barley,
and Rice Trials).

NAFTA Growing Zones	Grain Sorghum1	Rice1	Barley2

	Submitted	Requested	Submitted	Requested	Submitted	Requested



Canada	U.S.

Canada	U.S.

Canada	U.S.

1







	13

2







	13

4	1

1	3

7



	5	2

3	1

1	3	1	2

5B







1

	6	3

2	1

2



	7	1

1



3	2	3

8	2

2







9







	1

10



1

2

	1

11







	1

14







12

	Total	9

9	6

12	6	16	9

1  As required under OPPTS 860.1500 Tables 2 and 5 for grain sorghum and
rice as representative crops of cereal grains (Crop Group 15) and
forage, fodder, and straw of cereal grains (Crop Group 16).  For
Canadian requirements, refer to PMRA Directive 98-02 Section 9, Table 2.

2  As required under OPPTS 860.1500 Tables 1 and 5 for barley, and PMRA
Directive 98-02 Section 9 Table 2.  OPPTS 860.1500 does not require
field trials on barley to support a U.S. crop group tolerance for Crop
Groups 15 and 16.  The requested number of trials for U.S. reflect a 25%
reduction due to the crop being a representative commodity used to
obtain a crop group tolerance or due to pesticidal use resulting in no
quantifiable residues.  

3  For barley, either Zone 1 or Zone 2 is acceptable.

TABLE 30b.  Trial Numbers and Geographical Locations (Wheat and Corn
Trials).

NAFTA Growing Zones	Wheat1	Field Corn1	Sweet Corn1

	Submitted	Requested	Submitted	Requested	Submitted	Requested



Canada	U.S.

Canada	U.S.

Canada	U.S.

1



1

1

	1

2	1

1	1

1

	1

3





	1

1

4	1

1







5	3	2	3	12	8	12	[4]2	4	3

5A









	5B



	4

	2

	6	2

1	1

1



	7	5	7	4







7A	1	1



	1	1

	8	3

4







10





	1

1

11	1

1



1

1

12





	1	1	1

14	8	10







	Total	25	20	15	15	12	15	9	8	9

1  As required under OPPTS 860.1500 Tables 2 and 5 for wheat, field
corn, and sweet corn as representative crops of cereal grains (Crop
Group 15) and forage, fodder, and straw of cereal grains (Crop Group
16), and PMRA Directive 98-02 Section 9 Table 2.

2  The number in brackets represents four trials on field corn in which
samples were also collected at the milk stage to provide additional
samples of K+CWHR and forage for sweet corn.

The residue data for cereal grains were not entered into the Agency’s
tolerance spreadsheet as specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data SOP as all residues were <LOQ
(0.025 ppm for each analyte in almond hulls and 0.01 ppm for each
analyte in nutmeats) in/on all but four treated samples of sorghum
stover (maximum residue of <0.09 ppm).  The recommended tolerances for
the combined residues of saflufenacil and its metabolites M800H11 and
M800H35, expressed as parent equivalents, are 0.03 ppm for crop group
15, cereal grains and 0.10 ppm for crop group 16, forage, fodder, and
straw of cereal grains.

Cotton

DER Reference List	47128224.der.doc

BASF Corporation has submitted field trial data for saflufenacil on
cotton.  Twelve cotton field trials were conducted in the U.S. in Zones
2 (GA, 1 trial), 4 (AR and MS, 1 trial each), 6 (TX; 1 trial), 8 (OK; 1
trial, TX; 3 trials), and 10 (AZ; 1 trial and CA; 3 trials) during the
2007 growing season.  

At each trial location, two treated plots were established.  Each
treated plot received a single, at-planting preemergence broadcast spray
of the 70% WG formulation of saflufenacil (BAS 800 00 H) to the soil
surface at 0.022-0.032 lb ai/A (0.49-0.71X; Treatment 2) or 0.044-0.064
lb ai/A (1.0-1.4X; Treatment 3).  The applications were made using
ground equipment in 20-28 gal/A spray volumes.  An adjuvant was included
in the spray mixture.  Samples of mature cotton were harvested by
spindle-picker or stripper-picker, or by hand, at a 141- to 186-day PHI
and ginned into undelinted cotton seed and cotton gin byproducts.  At
one site, the cotton used to generate the undelinted seed RAC samples
was harvested 130 days after treatment, to obtain samples for analysis
earlier than the anticipated harvest for that location; samples used to
generate the gin byproducts samples from this site were harvested at the
expected time, 175 days after treatment.

Samples of cotton RACs were analyzed for residues of saflufenacil and
metabolites M800H11 and M800H35 using an LC-MS/MS method, BASF
Analytical Method Number D0603/02.  This method is adequate for data
collection based on acceptable concurrent method recoveries.  The LOQ
was 0.025 ppm for each analyte in gin byproducts and 0.01 ppm for each
analyte in cotton seed.  Apparent residues of saflufenacil, M800H11, and
M800H35 were <LOQ in/on all samples of untreated cotton undelinted seed
and gin byproducts.

Residues of saflufenacil, M800H11, and M800H35 were each below the LOQ
in/on all samples of cotton undelinted seed and gin byproducts harvested
130-186 days after one preemergence soil broadcast application of the
70% WG formulation (BAS 800 00 H) at a rate of 0.022-0.032 lb ai/A
(0.49-0.71X) or 0.044-0.064 lb ai/A (1.0-1.4X).  

Because the submitted data reflect preemergence application, no residue
decline studies are required.

Conclusions:  The submitted field trial data for cotton are adequate to
fulfill data requirements.  The number and locations of the trials are
in accordance with OPPTS Guideline 860.1500 (Table 31).  The available
data will support the proposed use pattern.

TABLE 31.  Trial Numbers and Geographical Locations for Cotton.

NAFTA Growing Zones	Cotton

	Submitted	Requested



Canada	U.S.1

2	1

1 [1]

4	2

3 [2]

6	1

1 [1]

8	4

4 [3]

10	4

3 [2]

Total	12

12 [9]

1  As per OPPTS 860.1500, Tables 1 and 5 for cotton seed.  Numbers in
brackets represent the required number of trials for a use resulting in
no quantifiable residues.  OPPTS 860.1000, Table 1, specifies that six
field trials must be conducted for cotton gin byproducts, three

The residue data for cotton were not entered into the Agency’s
tolerance spreadsheet as specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data SOP as all residues were <LOQ
(0.025 ppm for each analyte in gin byproducts and 0.01 ppm for each
analyte in cotton seed).  The recommended tolerances for the combined
residues of saflufenacil and its metabolites M800H11 and M800H35,
expressed as parent equivalents, are 0.03 ppm for cotton seed and 0.10
ppm for cotton gin byproducts.

Sunflower

DER Reference List	47128226.der.doc

BASF Corporation has submitted field trial data for saflufenacil on
sunflower.  Eight sunflower field trials were conducted in the U.S. and
Canada in Zones 5 (KS, MI, WI; 1 trial each), 7 (ND; 3 trials), 8 (KS; 1
trial), and 14 (SK; 1 trial) during the 2007 growing season.  

Each trial location consisted of one untreated and one treated plot. 
Each treated plot received two late-season, over-the-top broadcast
applications of the 70% WG formulation of saflufenacil (BAS 800 00 H) at
0.043-0.046 lb ai/A/application, with a retreatment interval of 7 days,
for a total seasonal rate of 0.088-0.091 lb ai/A (1X).  The applications
were made using ground equipment in 19-21 gal/A spray volumes.  An
adjuvant was included in the spray mixture.

Samples of mature sunflower seed RAC were harvested at 6- to 8-day and
13- to 15-day PHIs.  Additional samples were taken from the KS site at
3-, 10-, and 20-day PHIs to evaluate residue decline.

Samples of sunflower seed were analyzed for residues of saflufenacil and
metabolites M800H11 and M800H35 using an LC-MS/MS method, BASF
Analytical Method Number D0603.  This method is adequate for data
collection based on acceptable concurrent method recoveries.  The LOQ
was 0.01 ppm for each analyte.  Apparent residues of saflufenacil,
M800H11, and M800H35 were <LOQ in/on all samples of untreated sunflower
seed.  

Maximum residues of saflufenacil, M800H11, and M800H35 were 0.50, 0.16,
and 0.04 ppm, respectively, in/on sunflower seed harvested 6-8 days
after the last of two over-the-top broadcast applications of
saflufenacil at a total rate of 0.088-0.091 lb ai/A (1X).  Maximum
combined residues at the 6- to 8-day PHI were 0.58 ppm.  Maximum
residues of saflufenacil, M800H11, and M800H35 were 0.46, 0.33, and 0.06
ppm, respectively, in/on sunflower seed harvested 13-15 days
posttreatment.  Maximum combined residues at the 13- to 15-day PHI were
0.56 ppm.

Average combined residues of saflufenacil, M800H11, and M800H35 appeared
to decrease overall with increasing sampling intervals, from 0.12 ppm at
the 3-day PHI to 0.06 ppm at the 20-day PHI.

TABLE 32.  Summary of Residue Data from Sunflower Field Trials with
Saflufenacil.

Commodity	Total Applic. Rate (lb ai/A)	PHI (days)	Analyte	Residue Levels
(ppm)1





n	Min.	Max.	HAFT2	Median	Mean	Std. Dev.

Sunflower, seed	0.088-0.091	6-8	Saflufenacil	16	0.03	0.50	0.44	0.11	0.15
0.13



	M800H11	16	<0.01	0.16	0.15	0.01	0.04	0.05



	M800H35	16	<0.01	0.04	0.04	0.01	0.01	0.01



	Combined	16	<0.05	<0.58	<0.50	0.17	0.20	0.14



13-15	Saflufenacil	16	0.02	0.46	0.39	0.07	0.12	0.12



	M800H11	16	<0.01	0.33	0.33	0.02	0.06	0.11



	M800H35	16	<0.01	0.06	0.05	0.01	0.02	0.02



	Combined	16	<0.04	<0.56	<0.48	0.12	0.20	0.17

1  Residues are reported in ppm saflufenacil equivalents.  For
calculation of the HAFT, median, and mean, the LOQ (0.01 ppm for each
analyte) was used for values reported as <LOQ.

2  HAFT = highest-average field trial.

Conclusions:  The submitted field trial data for sunflower seed are
adequate to fulfill data requirements.  The number and locations of the
trials are in accordance with OPPTS Guideline 860.1500 (Table 33). 
However, all of the field trials were performed with a WG formulation;
whereas, the proposed use is for the SC formulation.  These formulation
types are not considered to be equivalent for mid- to late-season foliar
applications.  The proposed sunflower use should thus be removed from
the BAS 800 04H FiRoCrop Herbicide (SC) label and added to the BAS 800
01H TNV Herbicide (WG) label.  Alternatively, bridging trials could be
performed to determine the effect of the formulation type on residue
levels.

TABLE 33.  Trial Numbers and Geographical Locations for Sunflower Field
Trials.

NAFTA Growing Zones	Sunflower

	Submitted	Requested1



Canada	U.S.

5	3	2	3

7	3	1	4

8	1

1

14	1	2

	Total	8	5	8

1  As required under U.S. EPA OPPTS 860.1500 Tables 2 and 5 for
sunflower, and PMRA Directive 98-2 Section 9 Table 2.

The residue data for sunflower seed were entered into the Agency’s
tolerance spreadsheet as specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data SOP to determine appropriate
tolerance levels; see Appendix II.  In three of the trials, residues
were higher at PHIs (10-14 days) that are greater than the proposed PHI
(7 days).  In these cases, the higher values were entered into the
spreadsheet.  The recommended tolerance for the combined residues of
saflufenacil and its metabolites M800H11 and M800H35, expressed as
parent equivalents, is 1.0 ppm for sunflower seed.

860.1520 Processed Food and Feed

Apple

DER Reference List	47128229.der.doc

A processing study was carried out to determine the magnitude of
saflufenacil residues in apples and processed apple commodities (juice
and pomace).  BAS 800 00 H (saflufenacil, 70% ai, WG) was applied to
apples as three broadcast orchard floor applications of 0.22 lb ai/A for
a total seasonal application rate of 0.67 lb ai/A (5X).  The
applications were made at dormancy (179 days prior to harvest), 21 days
prior to harvest and on the day of harvest with 25 gal/A of water using
ground equipment.  An adjuvant was included in the spray mixture.

Mature apples were harvested on the day of the last application (0-day
PHI) from one untreated control plot and one treated plot.  Bulk samples
of apples were delivered to the processing facility on the same day and
were placed in cool storage at 3-8ºC prior to processing into juice and
wet pomace.  Processing was completed within one day of harvest and was
carried out using protocols simulating commercial processing procedures.

Residues of saflufenacil and its metabolites M800H11 and M800H35 in
apple samples were quantified by analytical method D0603, an LC-MS/MS
method.  Concurrent recoveries were determined for each analyte during
sample analysis to demonstrate the validity of the method.  The LOQ was
determined as 0.01 ppm each for saflufenacil, M800H11, and M800H35 in/on
apple fruit. 

The results from this study demonstrated that individual residues of
saflufenacil and its metabolites M800H11 and M800H35 were below their
LOQs of 0.01 ppm each, and correspondingly, combined residues were <0.03
ppm in/on apple samples (unwashed fruit) harvested at 0-day PHI
following a total application of 0.67 lb ai/A (5X).  Since quantifiable
residues were not found in the whole fruit, analysis of juice and wet
pomace was not carried out. Therefore, a conclusion regarding the
comparison of saflufenacil residues in processed apple commodities with
theoretical concentration factors cannot be reached.

Conclusions:  The submitted apple processing data are adequate to
fulfill data requirements.  As the residues in the RAC were <LOQ after
treatment at a 5X rate, separate tolerances for wet apple pomace and
apple juice will not be required.

Citrus

DER Reference List	47128228.der.doc

A processing study was carried out to determine the magnitude of
saflufenacil residues in oranges and processed orange commodities
(juice, dried pulp, and oil).  BAS 800 00 H (saflufenacil, 70% ai, WG)
was applied to oranges as three broadcast orchard floor applications of
0.22 lb ai/A each for a total seasonal application rate of 0.67 lb ai/A
(5X).  Applications were made at a RTI of 20-21 days starting at 42 days
before harvest, with 30 gal/A using ground equipment.  An adjuvant was
included in the spray mixture.

 samples were stored frozen (≤-20(C) at the field facility for 25 days
before being shipped directly to the laboratory (these samples were not
analyzed, since raw oranges were subsampled prior to processing for
analysis from the bulk sample shipped to the processor).  Bulk orange
samples used for processing were delivered to the processing facility on
the day of harvest.  Both sets of samples were placed in cool storage at
3-8ºC prior to collection of RAC fractions or processing into dried
pulp, juice, and oil.  Processing was completed within 15 days of
harvest and was carried out using protocols simulating commercial
processing procedures.

Residues of saflufenacil and its metabolites M800H11 and M800H35 in
orange samples were quantified by analytical method D0603, an LC-MS/MS
method.  Concurrent recoveries were determined for each analyte during
sample analysis to demonstrate the validity of the method.  The LOQ was
determined as 0.01 ppm each for saflufenacil, M800H11, and M800H35 in/on
orange fruit and orange oil. 

Results from this study demonstrated that individual residues of
saflufenacil and its metabolites M800H11 and M800H35 were below their
LOQs of 0.01 ppm each, and correspondingly, combined residues were <0.03
ppm in/on orange samples (unwashed fruit; n=2) harvested at 0-day PHI
following a total application of 0.67 lb ai/A (5X).  Since quantifiable
residues were not found in the whole fruit, analysis of dried pulp and
juice was not carried out.  Residues of each analyte were also below LOQ
(<0.01 ppm) in citrus oil samples (n=2) derived from the orange fruit
samples.  As the residues of saflufenacil were below LOQ in citrus oil,
and dried pulp and juice were not analyzed; concentration factors could
not be determined.

Conclusions:  The submitted citrus processing data are adequate to
fulfill data requirements.  As the residues in the RAC and oil were <LOQ
after treatment at a 5X rate, separate tolerances for citrus oil, dried
pulp, and juice will not be required.  

Grape

DER Reference List	47128232.der.doc

A processing study was carried out to determine the magnitude of
saflufenacil residues in grapes and processed grape commodities (juice
and raisins).  BAS 800 00 H (saflufenacil, 70% ai, WG) was applied to
grapes as three broadcast vineyard floor applications of 0.044-0.046 lb
ai/A for a total seasonal application rate of 0.134 lb ai/A (2X).  The
applications were made at dormancy (146 days prior to harvest), 21 days
prior to harvest and on the day of harvest with 34-36 gal/A using ground
equipment.  An adjuvant was included in the spray mixture.

Mature grapes were harvested on the last day of application (0-day PHI)
from one untreated control plot and one treated plot.  One set of the
treated and control bulk grape samples was shipped by overnight courier
on blue ice to be delivered to the processing facility on the same day
and was placed in cool storage at approximately 4ºC prior to processing
into juice.  Processing into juice was completed within 9 days of
harvest and was carried out using protocols simulating commercial
processing procedures.  Following frozen storage for 17 days, these
samples were shipped to the same processing facility for collection of
fractions.  Processing into raisins was completed within 105 days of
harvest.  A second set of treated and control bulk grape samples
harvested on the same day as the first set was field-dried for 20 days
and collected as sun-dried raisins.  

Residues of saflufenacil and its metabolites M800H11 and M800H35 in
grape samples were quantitated by analytical method D0603, an LC-MS/MS
method.  Concurrent recoveries were determined for each analyte during
sample analysis to demonstrate the validity of the method.  The LOQ was
determined as 0.01 ppm each for saflufenacil, M800H11, and M800H35 in/on
grapes.

The results from this study demonstrated that individual residues of
saflufenacil and its metabolites M800H11 and M800H35 were below their
LOQs of 0.01 ppm each, and correspondingly, combined residues were <0.03
ppm in/on grape samples (unwashed fruit) harvested at 0-day PHI
following a total application of 0.134 lb ai/A (2X).  Since quantifiable
residues were not found in the whole fruit, analysis of grape juice and
raisins was not carried out. Therefore, a conclusion regarding the
comparison of saflufenacil residues in processed grape commodities with
theoretical concentration factors cannot be reached.

Conclusions:  The submitted grape processing data are adequate to
fulfill data requirements.  As the residues in the RAC and oil were <LOQ
after treatment at a 2X rate, separate tolerances for grape juice and
raisins will not be required.  Note that HED previously approved the use
of rates <5X due to phytotoxicity concerns (Memorandum of Understanding,
BASF with EPA and PMRA, 1/25/06; MRID No. 47128215).  

Plum

DER Reference List	47128230.der.doc

A processing study was carried out to determine the magnitude of
saflufenacil residues in plums and processed plum commodities (prunes). 
Three broadcast applications of BAS 800 00 H (saflufenacil, 70% ai, WG)
were made to the ground in a plum orchard.  The first application was
made at a rate of 0.154 lb ai/A followed by two applications at a rate
of 0.226-0.229 lb ai/A each for a total seasonal application rate of
0.61 lb ai/A (4.7X).  The applications were made at dormancy (140 days
prior to harvest), 20 days prior to harvest and on the day of harvest
with 30-31 gal/A using ground equipment.  An adjuvant was included in
the spray mixture.

Mature plums were harvested on the day of the last application (0-day
PHI) from one untreated control plot and one treated plot.  Bulk samples
of plums were delivered to the processing facility the next day under
ambient conditions and were placed in cool storage at 4ºC prior to
processing into prunes.  Processing was completed within seven days of
harvest and was carried out using protocols simulating commercial
processing procedures.

Residues of saflufenacil and its metabolites M800H11 and M800H35 in plum
samples were quantitated by analytical method D0603, an LC-MS/MS method.
 Concurrent recoveries were determined for each analyte during sample
analysis to demonstrate the validity of the method.  The LOQ was
determined as 0.01 ppm each for saflufenacil, M800H11, and M800H35 in/on
plum fruit.

The results from this study demonstrated that individual residues of
saflufenacil and its metabolites M800H11 and M800H35 were below their
LOQs of 0.01 ppm each, and correspondingly, combined residues were <0.03
ppm in/on plum samples (unwashed fruit) harvested at 0-day PHI following
a total application of 0.61 lb ai/A (4.7X).  Since quantifiable residues
were not found in the whole fruit, analysis of prunes was not carried
out.  Therefore, a conclusion regarding the comparison of saflufenacil
residues in processed plum commodities with theoretical concentration
factors cannot be reached.

Conclusions:  The submitted plum processing data are adequate to fulfill
data requirements.  As the residues in the RAC were <LOQ after treatment
at a 4.7X rate, a separate tolerance for dried prunes will not be
required.

Cereal Grain

DER Reference List	47128231.der.doc

A processing study was carried out to determine the magnitude of
saflufenacil residues in cereal grain (field corn, winter wheat, sweet
sorghum, and rice) processed fractions.  BAS 800 00 H (saflufenacil, 70%
ai, WG) was applied to cereal grains as a single broadcast pre-emergence
soil surface application using ground equipment.  An adjuvant was
included in the spray mixture.

For winter wheat, saflufenacil was applied on the day of planting at a
rate of 0.22 lb ai/A (1.6X) in 36.8 gal/A of water.  Wheat grain samples
for processing were harvested at maturity (280 days after planting).

For field corn, saflufenacil was applied on the day of planting at a
rate of 0.27 lb ai/A (2X) in 15.0 gal/A of water.  Corn grain samples
for processing were harvested at maturity (154 days after planting).

For rice, saflufenacil was applied one day after planting at a rate of
0.21 lb ai/A (1.6X) in 13.6 gal/A of water.  Rice grain samples for
processing were harvested at maturity (151 days after planting).

For sweet sorghum, saflufenacil was applied on the day of planting at a
rate of 0.089 lb ai/A (0.7X) in 15.8 gal/A of water.  A lower rate was
used, since the 0.267 lb ai/A (2X) rate applied to a first planting
caused 100% plant mortality.  Sweet sorghum stalk samples for processing
were harvested at maturity (104 days after planting).

Mature cereals were harvested from one untreated control plot and one
treated plot.  Bulk samples of wheat and rice grains were shipped to the
processing facility on the same day by freezer truck; bulk samples of
corn grains and sorghum stalks were frozen at the field facility and
shipped to the processing facility 4-5 days after harvest by freezer
truck.  All samples were kept in frozen storage throughout the study and
were only thawed for processing and for extraction.  Processing was
carried out using protocols simulating commercial processing procedures.

Wheat was processed into aspirated grain fractions (AGF), middlings,
flour, shorts, bran, and wheat germ.  Corn was processed into AGF,
grits, meal, and flour (all dry milled), oil (both wet and dry milled),
and starch (wet milled).  Rice was processed into hulls, bran and
polished rice, while sorghum stalks were processed into sorghum syrup. 
Both treated and control samples were processed.

Residues of saflufenacil and its metabolites M800H11 and M800H35 in
cereal samples were quantified by analytical method D0603, an LC-MS/MS
method.  The LOQ was determined as 0.01 ppm each for saflufenacil,
M800H11, and M800H35 in/on the grain of field corn, winter wheat, and
rice.  The LOQ was determined as 0.025 ppm each for saflufenacil,
M800H11, and M800H35 in/on sweet sorghum stalk. 

The results from this study demonstrated that individual residues of
saflufenacil and its metabolites M800H11 and M800H35 were below their
LOQs of 0.01 ppm each, and correspondingly, combined residues were <0.03
ppm in/on wheat, corn, and rice grain samples harvested at maturity
following a single pre-emergence application of 0.21-0.27 lb ai/A
(1.6-2X). The individual residues of saflufenacil and its metabolites
M800H11 and M800H35 were below their LOQs of 0.025 ppm, and
correspondingly, total residues were <0.075 ppm in/on sweet sorghum
stalk samples harvested at maturity following a single pre-emergence
application of 0.089 lb ai/A (0.7X).  Since quantifiable residues were
not found in samples of wheat, corn and rice grain, and sorghum stalk,
analysis of processed commodities was not carried out.  Therefore, a
conclusion regarding the comparison of saflufenacil residues in
processed cereal grain commodities with theoretical concentration
factors cannot be reached.

Conclusions:  The submitted cereal grain processing data are adequate to
fulfill data requirements.  As the residues in the RACs were <LOQ (0.025
ppm for each analyte in sweet sorghum stalk and 0.01 ppm for each
analyte in grain) after treatment at a 0.7X-2X rate, separate tolerances
for residues in processed cereal grain commodities will not be required.
 Note that HED previously approved the use of rates <5X due to
phytotoxicity concerns (Memorandum of Understanding, BASF with EPA and
PMRA, 1/25/06; MRID No. 47128215).  

Cotton

DER Reference List	47445902.der.doc

A processing study was carried out to determine the magnitude of
saflufenacil residues in cotton and processed cotton commodities
(refined oil, meal, and hulls).  BAS 800 00 H (saflufenacil, 70% ai, WG)
was applied to cotton as a single pre-emergence broadcast application to
the soil surface at a rate of 0.045 lb ai/A (1X) or 0.112 lb ai/A
(2.5X).  The application was made one day after planting in 28.3 gal/A
of water using ground equipment.  An adjuvant was included in the spray
mixture.

The bulk seed cotton samples used to generate the processed fractions in
the present study were harvested at commercial harvest timing, 176 days
after planting (175 DAT), using a mechanical spindle picker.  The
unginned cotton samples for processing were shipped 3-5 days following
harvest by overnight courier under ambient conditions to the processing
facility, where they were placed in frozen storage.  Processing was
carried out using protocols simulating commercial processing procedures.
 Processed samples were shipped frozen to the analytical laboratory,
where they were kept frozen, extracted within 105-109 days, and analyzed
on the same day (hulls and meal) or within 4 days (oil).

Residues of saflufenacil and its metabolites M800H11 and M800H35 in
cotton undelinted seed, hull, meal, and refined oil samples were
quantitated by analytical method D0603, an LC-MS/MS method.  Concurrent
recoveries were determined for each analyte during sample analysis to
demonstrate the validity of the method.  The LOQ was determined as 0.01
ppm each for saflufenacil, M800H11, and M800H35 in/on cotton undelinted
seeds, cotton hull, meal, and refined oil. 

In these trials, the cotton plot treated at a rate of 2.5X showed severe
crop injury; therefore, the processing studies were conducted with seed
from plots treated at a lower rate (1x).  The results from this study
demonstrated that, following a single broadcast soil surface application
of saflufenacil on cotton at a total rate of 0.045 lb ai/A (1X), the
individual residues of saflufenacil and its metabolites M800H11 and
M800H35 were below their LOQs of 0.01 ppm each, and correspondingly,
combined residues were <0.03 ppm in cotton hull, meal, and refined oil
from cottonseed harvested at 175 DAT (176 days after planting).  As the
combined residues of saflufenacil were below LOQ in cotton seed, hulls,
meal, and refined oil, concentration factors could not be determined.

Conclusions:  The submitted cotton processing data are adequate to
fulfill data requirements.  As the residues in the RAC were <LOQ after
treatment at a 1X rate, separate tolerances for residues in cotton
hulls, meal, and refined oil will not be required.  Note that HED
previously approved the use of rates <5X due to phytotoxicity concerns
(Memorandum of Understanding, BASF with EPA and PMRA, 1/25/06; MRID No.
47128215).  

Soybean

DER Reference List	47128227.der.doc

A processing study was carried out to determine the magnitude of
saflufenacil residues in soybeans and processed soybean commodities
(refined oil, meal, hulls, and AGF).  BAS 800 00 H (saflufenacil, 70%
ai, WG) was applied to soybean plants one day after planting as a single
broadcast pre-emergence application at a rate of 0.089 lb ai/A (1X) or
0.267 lb ai/A (3X).  The applications were made in 22.5 gal/A of water
using ground equipment.  An adjuvant was included in the spray mixture.

Mature soybean samples were harvested 126 days after planting (125 days
after the pre-emergent application of saflufenacil) from one untreated
control plot and two treated plots.  Bulk seed samples of soybeans were
held at ambient temperatures for a day and delivered to the processing
facility by freezer truck within 18 days, where they were placed in
frozen storage at ≤-12ºC prior to processing.  Processing into seed,
AGF, hulls, meal, and oil was completed within 81-109 days of harvest
and was carried out using protocols simulating commercial processing
procedures.

Residues of saflufenacil and its metabolites M800H11 and M800H35 in
soybean samples were quantified by analytical method D0603, an LC-MS/MS
method.  Concurrent recoveries were determined for each analyte during
sample analysis to demonstrate the validity of the method.  The LOQ was
determined as 0.01 ppm each for saflufenacil, M800H11 and M800H35 in/on
soybean seed. 

The results from this study demonstrated that the individual residues of
saflufenacil and its metabolites M800H11 and M800H35 were below their
LOQs of 0.01 ppm each, and correspondingly, the combined residues were
<0.03 ppm in/on soybean seed samples harvested at a 125-day PHI
following a total application of 0.267 lb ai/A (3X).  Since quantifiable
residues were not found in soybean seeds, analysis of processed
commodities was not carried out.  Therefore, a conclusion regarding the
comparison of saflufenacil residues in processed soybean commodities
with theoretical concentration factors cannot be reached.

Conclusions:  The submitted soybean processing data are adequate to
fulfill data requirements.  As the residues in the RAC were <LOQ after
treatment at a 3X rate, separate tolerances for soybean AGF, hulls,
meal, and oil will not be required.  Note that HED previously approved
the use of rates <5X due to phytotoxicity concerns (Memorandum of
Understanding, BASF with EPA and PMRA, 1/25/06; MRID No. 47128215).  

Sunflower

DER Reference List	47128233.der.doc

A processing study was carried out to determine the magnitude of
saflufenacil residues in sunflowers and processed sunflower commodities
(refined oil and meal).  BAS 800 00 H (saflufenacil, 70% ai, WG) was
applied to sunflowers as two late-season broadcast applications of 0.229
lb ai/A and a RTI of 6 days, for a total seasonal application rate of
0.458 lb ai/A (5X). The applications were initiated 13 days prior to
mature dry seed harvest and were made in 20.5-20.6 gal/A of water using
ground equipment.  An adjuvant was included in the spray mixture.

Mature sunflowers were harvested from one untreated control plot and one
treated plot at a PHI of 7 days.  Bulk samples of the RAC of sunflower
seeds were frozen at the field facility following harvest and shipped to
the processing facility by freezer truck.  Processing was carried out
using protocols simulating commercial processing procedures.  

Residues of saflufenacil and its metabolites M800H11 and M800H35 in
sunflower seed, meal, and oil samples were quantified by analytical
method D0603, an LC-MS/MS method.  Concurrent recoveries were determined
for each analyte during sample analysis to demonstrate the validity of
the method.  The LOQ was determined as 0.01 ppm each for saflufenacil,
M800H11, and M800H35 in/on sunflower seeds and the processed sunflower
commodities, meal, and refined oil. 

The results from this study demonstrated that, following a foliar
broadcast application of BAS 800 H on sunflowers at a total rate of
0.458 lb ai/A (5X) with a PHI of 7 days, the mean combined residues of
saflufenacil and its metabolites M800H11 and M800H35 were 0.31 ppm in/on
sunflower seed, 0.24 ppm in meal, and below the combined LOQ (<0.03 ppm)
in refined oil.  A comparison of the combined saflufenacil residues in
sunflower seed with those in processed fractions resulted in
concentration factors of 0.8X for meal and <0.1X for refined oil.  It
can be concluded that residues of saflufenacil do not concentrate in
sunflower meal and oil.

Table 34.  Residue Data from Sunflower Processing Study with
Saflufenacil.

Processed Commodity	Total Rate	PHI

(days)	Residues (ppm)	Combined Residues (ppm)	Concentration factor



	Saflufenacil	M800H11	M800H35



Sunflower

Seed RAC	513 g ai/ha (0.458 lb ai/A)	7	0.28*, 0.30*	<0.01*, <0.01*
<0.01*, <0.01*	0.30, 0.32	NA

Meal

	0.21, 0.22	<0.01, <0.01	<0.01, <0.01	0.23, 0.24	0.8x

Refined Oil

	<0.01, <0.01	<0.01, <0.01	<0.01, <0.01	<0.03, <0.03	0.1x

* Mean results for multiple analyses of two replicate samples (For
saflufenacil, replicate A: 0.26, 0.32, 0.28, 0.27 ppm; replicate B:
0.27, 0.33, 0.32, 0.26 ppm).

Conclusions:  The submitted sunflower processing data are adequate to
fulfill data requirements. As no concentration (<1X) of the total
saflufenacil residue was found in any processed commodity, separate
tolerances for residues in sunflower meal and oil will not be required.

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

Analytical standards of saflufenacil, M800H11, and M800H35 are currently
available in the National Pesticide Standards Repository [source: 
personal communication with T. Cole of ACL/BEAD, 1/15/09].  However,
since the standards for M800H11 and M800H35 expired on 10/1/08, the
petitioner is requested to provide a new supply to the Repository.  The
reference standards should be sent to the ACL, 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

DER Reference List	47128017.der.doc

The metabolism of saflufenacil in rotational crops was investigated
using lettuce, radish and wheat after a single spray application of the
test substance in the EC formulation BAS 800 UBH at a nominal
application rate of 0.134 lbs. ai/A (1X).  The active substance was
applied to bare loamy sand soil in plastic containers placed under
natural climatic conditions without the influence of rain in a glass
roofed vegetation hall or in a glass house.  Treatment was performed
with either [phenyl-U-14C]-saflufenacil or [uracil-4-14C]-saflufenacil. 
The nature and the level of radioactive residues were investigated in
lettuce (head), white radish (roots and tops), and spring wheat (forage,
straw, chaff, and grain) after PBIs of 30, 58 (lettuce and radish only),
120, and 365 days.  Plant samples were harvested at maturity. 
Additional wheat forage samples were taken 48 to 68 days after sowing. 

The TRR were determined by the sum of the extractable and
non-extractable residues.  Frozen samples were homogenized and
successively extracted with methanol (three times) and water (twice). 
The extractable radioactive residues were measured by LSC, and the
residual radioactive residues (non-extractable residues) after solvent
extraction were determined by combustion analysis.  In most plant
samples taken after a PBI of 30 days and for samples of wheat grain at
365 DAT (uracil label), the metabolites extracted with methanol were
characterized by liquid/liquid partition.  The nature of the residues in
methanol extracts was investigated using two methods of HPLC with
radiodetection.  Metabolite identification was based on LC-MS and
LC-MS/MS analyses of purified fractions isolated from the methanol
extracts of spring wheat chaff (30 DAT, phenyl label and 120 DAT, uracil
label) and on co-chromatography with reference items (e.g., extract from
corn cell biotransformation suspension cultures).  Storage stability of
radioactive residues for both the phenyl and the uracil label has been
demonstrated for representative homogenized samples of lettuce head
(high water content) for a storage period up to 20 months and for
representative samples of spring wheat straw (low water content matrix)
for a storage period up to approximately 17 months.  Storage stability
of the methanol extracts has been demonstrated over 9 months for spring
wheat straw (phenyl label), and over 10 months for lettuce head (uracil
label) and spring wheat straw (uracil label), through re-analysis by
HPLC of the stored extracts.  

The major metabolites identified (≥10% of the TRR and/or ≥0.1 ppm)
with the phenyl label were the parent compound, saflufenacil (34.2% of
TRR; 0.003 ppm), and the metabolite M800H01 (13.7% of TRR; 0.001 ppm)
for lettuce head at 30 DAT, the parent compound (8.4-13.8 % of TRR;
0.001-0.004 ppm) and the metabolites M800H01 (10.5-16.0% of TRR;
0.001-0.004 ppm), M800H11 (9.0-13.1% of TRR; 0.001-0.003 ppm), and
M800H10 (and/or an unknown medium polar compound, counted as
characterized) (15.9-20.0% of TRR; 0.003-0.004 ppm) for white radish top
at 30 and 120 DAT, and the metabolites M800H05 (0.2-17.6% of TRR;
<0.0005-0.053 ppm), M800H35/M800H09 (3.2-42.3% of TRR; 0.001-0.162 ppm
(confirmatory analysis using a different HPLC system indicated that the
peak was mostly M800H35)), and M800H10 (and/or an unknown medium polar
compound, counted as characterized) (0.3-20.7% of TRR; <0.0005-0.044
ppm) for spring wheat. 

The only major metabolite identified with the uracil label for all
rotational crop matrices was the metabolite TFA.  The residue level of
TFA was calculated in parent-equivalents and based on the [molecular
mass of TFA].  The residue of TFA ranged from 89.8-95.9% of TRR
(0.076-0.085 ppm [0.017-0.019 ppm]) in lettuce head; from 88.4-89.3% of
TRR (0.010-0.030 ppm [0.002-0.007 ppm]) in white radish root; from
84.8-92.2% of TRR (0.039-0.149 ppm [0.009-0.034 ppm]) in white radish
top; from 79.4-90.9% of TRR (0.014-0.160 ppm [0.003-0.037 ppm]) in
spring wheat forage; from 73.7-77.4% of TRR (0.149-0.262 ppm
[0.034-0.060 ppm]) in spring wheat straw; from 81.6-88.0% of TRR
(0.358-1.413 ppm [0.082-0.322 ppm]) in spring wheat chaff; and from
37.3-87.8% of TRR (0.043-0.325 ppm [0.010-0.075 ppm]) in spring wheat
grain. Except for lettuce head (both labels), the calculated TRR in
rotational crops decreased between the 30 days and 120 days plant back
interval; however, in about half the plant matrices, the TRR increased
slightly between the 120 and 365 days PBIs (both labels).

Saflufenacil in rotational crops was metabolized by:  a) stepwise
degradation (N-dealkylation) of the N-methyl-N-isopropyl group to NH2,
forming a sulphonamide group; b) a N-demethylation at the uracil ring;
and c) a hydrolytic cleavage of the uracil ring generating a urea side
chain.  The metabolite M800H35 was identified as a metabolite in which
the methyl group of the N-methyl-N-isopropyl unit was lost and the
uracil ring was cleaved generating a urea side chain.  Metabolites
M800H01 and M800H05 resulted from stepwise demethylation and
dealkylation of the N-methyl-N-isopropyl group to NH2.  Metabolite
M800H11 was formed by demethylation of the methyl group of the
N-methyl-N-isopropyl unit and demethylation of the N-methyl group in the
uracil ring.  M800H10 was identified as a derivative of saflufenacil in
which the N-isopropyl group was lost and the uracil ring was
demethylated.  The metabolite TFA was only found in the uracil label. 
Based on the quantitative difference in TRR and the comparison of the
metabolite patterns from both labels, the study authors suggested that
the metabolite TFA originate from an uptake of the metabolite or a
precursor molecule from the soil into the plants.

Conclusions:  The submitted confined rotational crop study is adequate
to satisfy data requirements.  The metabolism of saflufenacil in
rotational crops appears to be consistent with the pathway observed in
the plant metabolism studies.  The HED ROCKS determined that residues of
concern for rotational crops consist of saflufenacil, M800H11, and
M800H35 (Memo, B. Daiss, 1/6/09; D359645).  

860.1900 Field Accumulation in Rotational Crops

DER Reference List	47128018.der.doc

The field rotational study was conducted in NAFTA Growing Regions 2 (3
trials in GA) and 10 (three trials in CA).  Saflufenacil (70% WG,
formulation code BAS 800 00 H) was applied as a single pre-emergence
application to the soil, after planting of the primary crop wheat, at
0.132-0.137 lb ai/A (1X).  The representative rotational crops radish,
lettuce, and wheat (spring and winter) were grown at PBIs of 4 months
(119-125 days), 6 months (180-183 days), and 9 months (270-274 days). 
All rotational crop samples were harvested at commercial maturity,
34-169 days after planting (DAP) for radish, 39-187 DAP for lettuce,
59-147 DAP for forage and hay, and 121-223 DAP for grain and straw.  All
collected samples were promptly frozen on the date of harvest.

The crop samples were analyzed for residues of saflufenacil and its
metabolites M800H11 and M800H35 using LC-MS/MS method BASF Analytical
Method D0603.  The LOQ is 0.01 ppm each for parent saflufenacil and its
metabolites M800H11 and M800H35 in crop samples, except for wheat
forage, hay, and straw, for which the LOQs are 0.025 ppm per analyte. 

Residues of saflufenacil and its metabolites M800H11 and M800H35 were
all below the LOQ in rotated wheat (<0.025 ppm for wheat forage, hay,
and straw, <0.01 ppm for grain), radish (<0.01 ppm, top and roots), and
lettuce (<0.01 ppm, leaves).

Conclusions:  The submitted field rotational crop data are adequate to
satisfy data requirements.  The available data indicate that residues of
saflufenacil and its metabolites M800H11 and M800H35 were each <LOQ
in/on all rotational crop matrices at a 120-day PBI.  These data support
the labeled rotational crop restriction of 4 months for all non-labeled
crops.  Unless the petitioner requests PBIs shorter than 120 days, no
additional data are required, and tolerances for inadvertent residues
in/on rotational crops need not be established in conjunction with the
currently proposed uses.

860.1550 Proposed Tolerances

BASF has proposed a tolerance expression for crops in terms of “the
combined residues of saflufenacil
(N'-[2-chloro-4-fluoro-5-(3-methyl-2,6-dioxo-4-(trifluoromethyl)-3,6-dih
ydro-1(2H)-pyrimidinyl)benzoyl]-N-isopropyl-N-methylsulfamide) plus
metabolites M800H11
(N-[2-chloro-5-(2,6-dioxo-4-(trifluoromethyl)-3,6-dihydro-1(2H)-pyrimidi
nyl)-4-fluorobenzoyl]-N'-isopropylsulfamide) and M800H35
(N-[4-chloro-2-fluoro-5-({[(isopropylamino)sulfonyl]amino}carbonyl)pheny
l]urea)”; and for livestock, in terms of saflufenacil, per se.  HED
has determined that the tolerance expression for plant commodities
should be revised to:  “the combined residues saflufenacil
(2-chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-py
rimidinyl]-4-fluoro-N-[[methyl(1-methylethyl)amino]sulfonyl]benzamide)
plus metabolites
N-[2-chloro-5-(2,6-dioxo-4-(trifluoromethyl)-3,6-dihydro-1(2H)-pyrimidin
yl)-4-fluorobenzoyl]-N'-isopropylsulfamide and
N-[4-chloro-2-fluoro-5-({[(isopropylamino)sulfonyl]amino}carbonyl)phenyl
]urea, calculated as saflufenacil equivalents.”

A summary of the recommended tolerances for the current petition are
listed in Table 35.  The petitioner should submit a revised section F
reflecting the recommended tolerances and commodity definitions
presented in Table 35.  

There are no Codex, Canadian, or Mexican MRLs established for residues
of saflufenacil and its metabolites in crop or livestock commodities.

The Agency’s Guidance for Setting Pesticide Tolerances Based on Field
Trial Data was utilized for determining appropriate tolerance levels for
sunflower seed; see Appendix II for tolerance calculations.  A detailed
discussion of the assessment of livestock commodity tolerances is
presented in the “860.1480 Meat, Milk, Poultry, and Eggs” section of
this Summary Document.



Table 35.  Tolerance Summary for Saflufenacil.



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

Vegetable, legume, group 06	0.03	0.03	Vegetable, legume, group 6

Vegetable, foliage of legume, group 07	0.1	0.10	Vegetable, foliage of
legume, group 7

Fruit, citrus, group 10	0.03	0.03

	Fruit, pome, group 11	0.03	0.03

	Fruit, stone, group 12	0.03	0.03

	Nut, tree, group 14	0.03	0.03

	Pistachio	-	0.03	Translated from tree nuts

Almond, hulls	0.2	0.10

	Grain, cereal, group 15	0.03	0.03

	Grain, cereal, forage, fodder and straw group 16	0.1	0.10

	Sorghum stover	0.1	-	Included in crop group 16

Cotton, undelinted seed	0.03	0.03

	Cotton, gin byproducts	0.03	0.10

	Sunflower, seed	0.7	1.0

	Grape	0.03	0.03

	Animal - Kidney	0.02	-	Individual tolerances required for each species

Animal - Liver	0.8	-

	Milk	-	0.01

	Cattle, meat	-	0.01

	Cattle, fat	-	0.01

	Cattle, liver	-	0.80

	Cattle, meat byproducts, except liver	-	0.02

	Goat, meat	-	0.01

	Goat, fat	-	0.01

	Goat, liver	-	0.80

	Goat, meat byproducts, except liver	-	0.02

	Hog, meat	-	0.01

	Hog, fat	-	0.01

	Hog, liver	-	0.80

	Hog, meat byproducts, except liver	-	0.02

	Sheep, meat	-	0.01

	Sheep, fat	-	0.01

	Sheep, liver	-	0.80

	Sheep, meat byproducts, except liver	-	0.02

	Horse, meat	-	0.01

	Horse, fat	-	0.01

	Horse, liver	-	0.80

	Horse, meat byproducts, except liver	-	0.02

	

  SEQ CHAPTER \h \r 1 Attachments:

International Residue Limit Status sheet

Appendix I - Chemical Name and Structure Table

Appendix II - Tolerance Assessment Calculations

cc:  G. Kramer (RAB1)

RDI:  RAB1 Chemists (1/28/09), HED ChemSAC (2/18/09)

G.F. Kramer:S10781:PY-S:(703)305-5079:7509P:RAB1

INTERNATIONAL RESIDUE LIMIT STATUS

Chemical Name: 
2-Chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-pyr
imidinyl]-4-fluoro-N-[[methyl(1-methylethyl)amino] sulfonyl]benzamide
Common Name:

Saflufenacil (experimental code:  BAS 800 H)	( Proposed tolerance

 Reevaluated tolerance

 Other	Date: 1/15/09

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

( No Codex proposal step 6 or above

⁯ Codex proposal step 6 or above for the crops requested	Petition
Numbers:  PP#8F7322

DP#:  349938

Other Identifier:  PC Code 118203

Residue definition (step 8/CXL):  N/A	Reviewer/Branch:  G. Kramer/RAB1

	Residue definition:  saflufenacil plus metabolites M800H11 and M800H35 
 SEQ CHAPTER \h \r 1   SEQ CHAPTER \h \r 1 

Crop (s)	MRL (ppm)	Crop(s) 	Tolerance (ppm)



Vegetable, legume, group 06	0.03



Vegetable, foliage of legume, group 07	0.1



Fruit, citrus, group 10	0.03



Fruit, pome, group 11	0.03



Fruit, stone, group 12	0.03



Stone fruit, crop group 12	0.03



Nut, tree, group 14	0.03



Almond, hulls	0.2



Grain, cereal, group 15	0.03



Grain, cereal, forage, fodder and straw group 16	0.1



Sorghum stover	0.1



Cotton, undelinted seed	0.03



Cotton, gin byproducts	0.03



Sunflower, seed	0.7



Grape	0.03



Animal - Kidney	0.02



Animal - Liver	0.8





	Limits for Canada	Limits for Mexico

(   No Limits

   No Limits for the crops requested	(   No Limits

   No Limits for the crops requested

Residue definition  N/A	Residue definition:  N/A

Crop(s)	MRL (ppm)	Crop(s)	MRL (ppm)





	Notes/Special Instructions:  S. Funk, 01/19/2009.





APPENDIX I.	Chemical Names and Structures of Saflufenacil and
Metabolites.

Common name/code

Figure C.3.1  ID No.	Chemical name	Chemical structure

Saflufenacil
2-chloro-5-[3,6-dihydro-3-methyl-2,6-dioxo-4-(trifluoromethyl)-1(2H)-pyr
imidinyl]-4-fluoro-N-[[methyl(1-methylethyl)amino]

sulfonyl]benzamide	

M800H01
N'-[2-chloro-4-fluoro-5-(3-methyl-2,6-dioxo-4-(trifluoromethyl)-3,6-dihy
dro-1(2H)-pyrimidinyl)benzoyl]-N-isopropylsulfamide	

M800H02
N'-[2-chloro-5-(2,6-dioxo-4-(trifluoromethyl)-3,6-dihydro-1(2H)-pyrimidi
nyl)-4-fluorobenzoyl]-N-isopropyl-N-methylsulfamide	

M800H03
N'-[2-chloro-4-fluoro-5-(3-methyl-2,6-dioxo-4-(trifluoromethyl)-3,6-dihy
dro-1(2H)-pyrimidinyl)benzoyl]-N-methylsulfamide	

M800H04
(2E)-3-{4-chloro-2-fluoro-5-[({[isopropyl(methyl)amino]sulfonyl}amino)ca
rbonyl]phenyl)amino]carbonyl(methylamino)}-4,4,4-trifluorobut-2-enoic
acid	

M800H05
N'-[2-chloro-4-fluoro-5-(3-methyl-2,6-dioxo-4-(trifluoromethyl)-3,6-dihy
dro-1(2H)-pyrimidinyl)benzoyl]-sulfamide	

M800H07
N-{4-chloro-2-fluoro-5-[({[isopropyl(methyl)amino]sulfonyl}amino)

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M800H34



M800H35	N-[4-chloro-2-fluoro-5-({[(isopropylamino)

sulfonyl]amino} carbonyl)phenyl]



M800H37	N-{4-chloro-2-fluoro-5-[({[ethyl(methyl)amino]sulfonyl}amino)



Appendix II.  Tolerance-Assessment Calculations.

Sunflower

The dataset used to establish a tolerance for saflufenacil and its
metabolites on sunflower seed consisted of sunflower field trial data
representing application rates of 0.088-0.090 lb ai/A with a 7- to
14-day PHI.  As specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data SOP, the field trial application
rates are within 25% of the maximum label application rate.  In three of
the trials, residues were higher at PHIs (10-14 days) that are greater
than the proposed PHI (7 days).  In these cases, the higher values were
entered into the spreadsheet.  The residue values (total of saflufenacil
and its metabolites M800H11 and M800H35, as parent equivalents) used to
calculate the tolerance are provided in Table II-1.

All 8 field trial sample results were above the combined LOQ of 0.03
ppm.  Since there were no values (combined residues) reported below the
LOQ, maximum-likelihood estimation (MLE) procedures were not needed to
impute censored values. 

The saflufenacil sunflower seed dataset was entered into the tolerance
spreadsheet as specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data SOP.  Visual inspection of the
lognormal probability plot (Figure II-1) provided in the spreadsheet
indicates that the dataset is reasonably lognormal.  The result from the
approximate Shapiro-Francia test statistic (Figure II-2) confirmed that
the assumption of lognormality should not be rejected.  

Using the rounding procedure as outlined in the Guidance for Setting
Pesticide Tolerances Based on Field Trial Data SOP, the lognormal EU
Method I and the point estimate of the 99th percentile round to the
value 1.0 ppm (Figure II-2).  Therefore, 1.0 ppm is the recommended
tolerance level for saflufenacil and its metabolites in/on sunflower
seed. 

Table II-1.	Residue Data Used to Calculate Tolerance for Combined Total
Residues of Saflufenacil in/on Sunflower Seed.  

Chemical:	Saflufenacil

Crop:	Sunflower

PHI:	7-14 Days

App. Rate:	0.088-0.090 lb ai/A

Submitter:	BASF

MRID Citation:	MRID 47128226

	Total Residues of Saflufenacil

	0.280

	0.150

	0.120

	0.120

	0.470

	0.440

	0.170

	0.170

	0.580

	0.420

	0.100

	0.100

	0.270

	0.150

	0.110

	0.050



Figure II-1.  Lognormal Probability Plot of Combined Total Residues of
Saflufenacil in/on Sunflower Seed.

 

Figure II-2.  Tolerance Spreadsheet Summary of Combined Total Residues
of Saflufenacil in/on Sunflower Seed.

 

Saflufenacil	Summary of Analytical Chemistry and Residue Data	DP#: 
349938

Page   PAGE  1  of   NUMPAGES  67 

soil

metabolites

soil

metabolites

