UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

	OFFICE OF PREVENTION, PESTICIDE

	AND TOXIC SUBSTANCES

  SEQ CHAPTER \h \r 1 MEMORANDUM

Date:  11/24/2008

SUBJECT:	Boscalid.  Amended Use Pattern Request for Banana.  Summary of
Analytical Chemistry and Residue Data.

PC Code:  128008	DP Barcode:  D354687

Decision No.:  394534	Registration No.:  NA

Petition No.:  8E7366	Regulatory Action:  Amended Section 3

Risk Assessment Type:  NA	Case No.:  NA

TXR No.:  NA	CAS No.:  188425-85-6

MRID No.:  47353902	40 CFR:  §180.589

		              									

FROM:	Douglas Dotson, Ph.D., Chemist

		Registration Action Branch 2

		Health Effects Division (7509P)

			  SEQ CHAPTER \h \r 1 

THROUGH:	Dennis McNeilly, Chemist

		Christina Swartz, Branch Chief

		Registration Action Branch 2

		Health Effects Division (7509P)

TO:		Bryant Crowe/Tony Kish, RM Team 22

		Fungicide Branch

		Registration Division (7505P)		  SEQ CHAPTER \h \r 1   SEQ CHAPTER \h
\r 1 

		

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

Executive Summary

Boscalid is a carboxamide (an anilide) fungicide that inhibits
mitochondrial respiration, thereby inhibiting spore germination, germ
tube elongation, mycelial growth, and sporulation of pathogenic fungi on
the leaf surface.  Boscalid is currently registered to BASF Corporation
as water dispersible granule (WDG) formulations for use on a wide
variety of food/feed crops.

BASF Corporation has submitted bridging data (MRID 47353902) in support
of a request to:  (i) allow use of Cumora® Fungicide on bananas grown
in Central and South America; and (ii) amend the established import
tolerance [40 CFR §180.589] for residues of boscalid in/on banana from
0.2 ppm to 0.5 ppm.  The current submission is part of a tolerance
petition, PP#8E7366, which also includes an application to register and
establish a boscalid tolerance on coffee.  This summary document only
addresses the request for amended use pattern and tolerance for bananas.
 The coffee data, along with HED’s regulatory conclusions and
recommendations, will be addressed in a separate document.

Cumora® Fungicide is a 500 g/L suspension concentrate (SC) formulation
of boscalid intended to control Black and Yellow Sigatoka on banana and
plantain crops grown in Costa Rica, Ecuador, Colombia, Honduras, Panama,
Guatemala, Belize, El Salvador, Nicaragua, Dominican Republic, Mexico,
Argentina, Brazil, Philippines, and Martinique.  The product is proposed
for a maximum of four broadcast foliar applications to established
bananas at 0.134 lb ai/A per application for a total rate of 0.536 lb
ai/A, with either a 0- or 1-day preharvest interval (PHI) depending on
country.  The current import tolerance of 0.02 ppm for residues of
boscalid in/on banana was established based on residue data reflecting
use of a 50% WDG formulation applied at maximum seasonal rates of
0.52-0.56 lb ai/A and a 0-day PHI (DP# 322235, 11/3/05, D. Dotson  SEQ
CHAPTER \h \r 1 ).

Boscalid tolerances for plant commodities are listed in 40 CFR §180.589
(a)(1) and are expressed in terms of residues of the fungicide boscalid
[3-pyridinecarboxamide, 2-chloro-N-(4'-chloro[1,1'-biphenyl]-2-yl)]. 
Plant commodity tolerances range from 0.05 ppm in/on peanut and tuberous
and corm vegetables (Crop Subgroup 1-C) to 60 ppm in/on leafy greens
(Crop Subgroup 4-A), except head and leaf lettuce.

  SEQ CHAPTER \h \r 1 The nature of the residue in plants is adequately
understood.  The HED Metabolism Assessment Review Committee (MARC)
determined that, in target crops, the parent only is the residue of
concern for risk assessment and tolerance expression.  This
determination continues to be in effect.

There are no livestock feedstuffs associated with the proposed amended
use pattern on bananas.  Therefore, no livestock metabolism data,
enforcement methods, storage stability data, or feeding studies are
required to support this petition.  The requirements for rotational crop
data are also not relevant to this request because bananas are typically
not rotated, and data for Guidelines 860.1850 and 860.1900 (confined and
field accumulation in rotational crops) are not required to establish an
import tolerance.

An adequate GC/MS   SEQ CHAPTER \h \r 1 method (Method D0008) is
available for enforcing tolerances in plant commodities.  The method has
been validated or approved by the Analytical Chemistry Branch of BEAD. 
Residues in/on plant commodities from the banana field trials associated
with this petition were determined using an LC/MS/MS data-collection
method (BASF Method D9908, Version II).  This method was adequately
validated in conjunction with the field trial analyses, and the
validated limit of quantitation (LOQ) was 0.05 ppm for boscalid in all
commodities tested.

The requirements for multiresidue methods (MRM) testing data are
fulfilled.  Residues of boscalid and its hydroxy metabolite were not
adequately recovered using the MRMs.  The MRM data have been forwarded
to FDA for a future updating of PAM, Vol. I.

Adequate storage stability data are available demonstrating that
residues of boscalid are reasonably stable under frozen conditions in/on
diverse crop matrices for at least 24 months.  Samples from the crop
field trials were stored for a maximum of ~6 months prior to residue
analysis.  There are no storage stability issues or corrections that
might need to be applied to the banana field studies discussed in this
document.

Adequate field residue data on both bagged and unbagged bananas were
provided along with data on banana pulp and peel.  These data reflect
side-by-side trials reflecting both formulations at the maximum use
pattern.  In the trials conducted using the WDG formulation, maximum
residues of boscalid in/on unbagged whole bananas were 0.12 ppm at 0-day
PHI and 0.19 ppm at 1-day PHI.  In the trials conducted using the SC
formulation, maximum residues of boscalid in/on unbagged whole bananas
were 0.28 ppm at 0-day PHI and 0.42 ppm at 1-day PHI.  In treated bagged
bananas, the majority (22 of 24 samples) bore residues below the LOQ
(LOQ = 0.05 ppm).  

The Agency generally recommends that 12 field trials be submitted for
imported bananas.  Twelve trials were originally submitted for the
registration of the WDG formulation.  For the bridging study, the
registrant submitted the results of 6 trials performed using each
formulation.  In the bridging study, the residue levels resulting from
the use of the two formulations were comparable.  The average field
trial value for the WDG and SC formulations were 0.07 ppm and 0.11 ppm,
respectively.  A value of ½ LOQ (0.025 ppm) was used for samples whose
residue value was reported as <LOQ (0.05 ppm).  Although the average
field trial values were relatively close, the maximum field trial value
for the SC formulation was approximately twice as high as the maximum
value for the WDG formulation (0.42 ppm as opposed to 0.19 ppm).  As the
bridging study demonstrated that, in general, residues were comparable,
the results of all banana field trials were used to determine the
recommended tolerance.  All residue values for unbagged whole bananas
were entered into the Agency’s Tolerance Generator for
NAFTA-Harmonized Tolerances to determine an appropriate tolerance level;
see Appendix I.  The tolerance spreadsheet recommends a RAC tolerance of
0.40 ppm.  This value is higher than the current 0.2 ppm tolerance for
banana because the maximum residue values for the SC formulation ((0.28
and 0.42 ppm) were higher than any of the values from the WDG field
trials.  The petitioner should submit a revised Section F to lower the
proposed RAC tolerance from 0.5 ppm to 0.4 ppm. 

HED does not require residue data for any processed commodities
associated with banana.  Therefore, data requirements for processed food
and feed are not relevant to this tolerance petition.

The Codex Alimentarius Commission has established a maximum residue
limit (MRL) for residues of boscalid in or on banana at 0.2 ppm, which
is equivalent to the current U.S. tolerance.  However, the recommended
U.S. tolerance of 0.4 ppm will be higher than the Codex MRL.  Mexico has
not established any MRLs for residues of boscalid in/on raw agricultural
commodities.  Canadian MRLs have been established for a variety of crops
but not for banana.

Analytical reference standards for boscalid are available at the EPA
National Pesticide Standards Repository.

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

Pending submission of a revised Section F, there are no residue
chemistry issues that would preclude granting a registration for the
amended use pattern requested for boscalid on imported bananas. 
Provided the forthcoming human health risk assessment does not identify
any issues of concern, the submitted data support the following
tolerance for residues of boscalid in/on:

Banana	0.40 ppm

860.1550 Proposed Tolerances

The petitioner should submit a revised Section F in which the proposed
tolerance for banana is 0.40 ppm, rather than 0.5 ppm.

Other Considerations

HED notes that there are outstanding deficiencies/issues from an early
boscalid petition, PP# 1F06313 (DP# 278385, 8/15/03, M. Nelson), which
must still be addressed by the petitioner.  As a condition of
registration, a date of submission should be confirmed.

	•	Submission of radiovalidation data demonstrating the efficiency of
the hydrolysis step in the proposed tolerance enforcement method (DFG
S19) for livestock matrices.  These radiovalidation data will also be
used in support of the data collection method (471/0) for livestock
matrices.

	•	Submission of radiovalidation data demonstrating the efficiency of
the microwave hydrolysis step in Method 476/0, which determines bound
residues of boscalid in milk and liver.

	•	Data are required demonstrating the frozen storage stability of
boscalid residues in processed grape juice (2 months).

Background

The chemical structure and nomenclature of boscalid are presented in
Table 1.  The physicochemical properties of the technical grade of
boscalid are presented in Table 2.

Table 1.   Boscalid Nomenclature.

Compound	

Common name	Boscalid

Company experimental name	BAS 510 F

IUPAC name	2-chloro-N-(4'-chlorobiphenyl-2-yl)-nicotinamide

CAS name	3-pyridinecarboxamide,2-chloro-N-(4'-chloro[1,1'-biphenyl]-2-yl

CAS registry number	188425-85-6

End-use product (EPs) requested for registration	BAS 510 01F (Cantus®
fungicide; 50% WDG)

BAS 510 05F (Cumora® 50 SC fungicide; 500 g/L SC)



TABLE 2.	Physicochemical Properties of Boscalid.

Parameter	Value	References

Melting point/range	142.8-143.8 C	MRIDs 45404802 and
45404804-45404809

pH	Does not dissociate in water. 

	Relative Density (20ºC)	1.381g/cm3

	Water solubility (20ºC)	4.64 mg/L at pH 6

	Solvent solubility (g/100 mL at 20ºC)	acetone	16-20	ethyl acetate
6.7-8.0 methanol	4-5	2-propanol	<0.01 acetonitrile	4-5	dichloromethane
20-25 toluene 	2-5	n-heptane 	<0.01

1-octanol	<0.01	olive oil	2.9 

N,N-DMF >25

	Vapor pressure (20ºC)	7 x 10-7 Pa 

	Dissociation constant, pKa	None

	Octanol/water partition coefficient, Log(KOW)	2.96 

	UV/visible absorption spectrum	molar extinction coefficient = 3.15 x104
L/mole/cm at 228 nm; 1.53 x103 at 290 nm

	

860.1200  Directions for Use

In support of the proposed import tolerance, the petitioner has
submitted undated specimen labels with English translations for the 500
g/L suspension concentrate formulation (Cumora® 50 SC fungicide).  The
specimen labels claim to be effective for control of Black/Yellow
Sigatoka on banana and plantain crops grown in Central and South
America.  A summary of the proposed use patterns was extracted from the
various labels included in the petition’s Section B, and is summarized
below in Table 3.

Table 3.	Summary of Directions for Use of Boscalid.

Applic. Timing, Type, and Equip.	Formulation	Applic. Rate 

(lb ai/A)

[kg ai/ha]	Max. No. Applic. per Season	Max. Seasonal Applic. Rate

(lb ai/A)

[kg ai/ha]	PHI

(days)	Use Directions and Limitations

Banana (For Use in Costa Rica, Ecuador, Colombia, Honduras, Panama,
Guatemala, Belize, El Salvador, Nicaragua, Dominican Republic, Mexico,
Argentina, Brazil, Philippines, and Martinique)

Broadcast foliar

Ground or aerial	500 g/L SC	0.134

[0.150]	4	Implied:

0.536

[0.600]	0 (for Central America and Colombia)

1 (for Ecuador)	Applications are to be made with oil (7-10 L/ha) plus an
emulsifier with a 10- to 15-day retreatment interval.



Conclusions.  The proposed use directions on banana are adequately
described and sufficient to allow evaluation of the residue data
relative to the proposed use.

860.1300 Nature of the Residue - Plants

Residue Chemistry Memo DP# 278385, 8/15/03, M. Nelson, (PP# 1F06313)

HED MARC Decision Memo DP# 286786, 1/9/03

  SEQ CHAPTER \h \r 1 The nature of boscalid residues in target
(primary) crops is adequately understood based upon acceptable 14C
metabolism studies conducted on grapes, lettuce, and beans.  These
studies were reviewed in the initial boscalid petition, PP# 1F06313.  No
significant metabolism of boscalid occurred in grapes or lettuce. 
Unchanged parent was the only component identified, accounting for
92-98% and 99% TRR (total radioactive residues), respectively.  In bean
plants, boscalid was metabolized slowly.  Unchanged parent was the major
component identified, accounting for up to 72% TRR in/on bean dry seeds
and 99% TRR in/on bean plants.  Cleavage products
1-(chlorophenyl)-2-aminobenzene and 2-chloronicotinic acid were present
in small amounts, accounting for <1% and <10% TRR, respectively.

The HED MARC concluded that parent boscalid is the sole residue of
concern for risk assessment and the tolerance expression for primary
(target) crops.  The cleavage products were not included based on the
limited cleavage which occurred and the low levels of their ingestion
expected from dietary and environmental sources.  These conclusions
continue to be in effect.

860.1300 Nature of the Residue – Livestock

Residue Chemistry Memo D278385, 8/15/03, M. Nelson, (PP# 1F06313)

HED MARC Decision Memo D286786, 1/9/03

≥10% of the TRR.  No amide bridge cleavage products were identified. 
Based on the structural similarity of boscalid and M510F 01, and the
fact that the enzymatic hydrolysis step in the proposed enforcement
method will release M510F 02 back to free M510F 01, the MARC concluded
that the combined residues of parent BAS 510 F, M510F 01, and M510F02
are the residues of concern for risk assessment and the tolerance
expression in livestock matrices.  This conclusion continues to be in
effect.

860.1340 Residue Analytical Methods

DER Reference List Reviewed in PP# 1F06313:

46351405.der (Data Collection Method, 445/0)

45405027.der (Data Collection Method, D9908)

45405028.der (Proposed Enforcement Method, D0008)

Residue Chemistry Memo D278385, 8/15/03, M. Nelson, (PP# 1F06313)

Residue Chemistry Memo D284510, 8/12/03, D. Swineford and E. Kolbe (PMV
memo)

An adequate GC/MS method (Method D0008) is available for enforcing
boscalid tolerances in plant commodities.  The Analytical Chemistry
Branch in BEAD concluded that the method is acceptable for enforcement
purposes in plants without the need for an EPA validation. 

An adequate LC/MS/MS method (BASF Method D9908, Version II) is also
available for collecting residue data on plant commodities.  Boscalid
residues in all of the plant commodities associated with the current
field trials were determined using this LC/MS/MS method.  According to
the method, residues are extracted with methanol:water:2 N HCl (70:25:5,
v:v:v), centrifuged, and an aliquot of the supernatant cleaned by
partitioning between cyclohexane and 1 N HCl saturated with NaCl (5:1,
v:v).  The cyclohexane phase is evaporated to dryness and reconstituted
in a buffered methanol:water (80:20, v:v) solution.  Residues are
determined by LC/MS/MS using the m/z 343→307 transition for detecting
and quantifying boscalid.  Residues are quantified using an external
calibration curve of boscalid standards.  The validated limit of
quantitation is 0.05 ppm for boscalid in all commodities tested.  In
conjunction with each field trial, the method was adequately validated
using control samples of each plant matrix fortified with boscalid at
levels ranging from 0.05 to 200 ppm.

860.1360 Multiresidue Methods

Residue Chemistry Memo D278385, 8/15/03, M. Nelson, (PP# 1F06313)

  SEQ CHAPTER \h \r 1 Residues of boscalid and its metabolite M510F01
were not adequately recovered using the multiresidue methods.  Protocol
A was not applicable.  Protocol B was not applicable for boscalid and
yielded inconsistent recoveries of M510F01.  Residues of boscalid and
its hydroxy metabolite M510F01 had good responses with GC/ECD on a DB-1
column under Protocol C.  Neither analyte was recovered at ≥30% using
Protocols D, E, and F.  The study has been forwarded to FDA for a future
updating of PAM, Vol. I.

860.1380 Storage Stability

DER Reference List Reviewed in PP#s   SEQ CHAPTER \h \r 1 1F6313,
3E6791, 4F6875, & 5E6933: 

  SEQ CHAPTER \h \r 1 46351404.der (Plant Matrices)

46160103.der (Tomato Paste)

Residue Chemistry Memo D322235, 11/3/05, D. Dotson (PP#s   SEQ CHAPTER
\h \r 1 1F6313, 3E6791, 4F6875, & 5E6933)

 ≤-20ºC in/on fortified samples of cabbage (leafy vegetables), canola
seed (oil seed), peach (fruit/fruiting vegetable), sugar beet roots
(root crop), peas (legume vegetable), wheat grain (non-oily grain),
wheat forage (foliage), and wheat straw (dry feed) for up to 24 months. 
Data are also available indicating that boscalid is stable for up to 45
days in peanut oil and for up to 38.4 months in tomato paste stored at
≤-20ºC.  In the initial boscalid petition, PP# 1F06313, storage
stability data for grape processed commodities were requested.  This
data requirement remains outstanding.

The storage intervals and conditions for samples from the current crop
field trials are presented in Table 4.

Table 4.   Summary of Storage Conditions and Intervals of Samples from
Crop Field Trials. 

Matrix 	Storage Temperature (°C)	Actual Storage Duration (Days)
Interval of Demonstrated Storage Stability 

Banana, whole fruit	Ambient at the field sites and during shipping

<-5°C at the analytical laboratory	100-166 days

(3.3-5.5 months)	Storage stability data are available demonstrating that
boscalid is stable under frozen conditions in diverse crop matrices for
at least 24 months.

Banana , pulp

123-168 days

(4.0-5.5 months)

	Banana, peel

128-173 days

(4.2-5.7 months)

	

Conclusions.  Adequate storage stability data are available
demonstrating that residues of boscalid are stable under frozen
conditions in/on diverse crop matrices for at least 24 months.  Samples
from the crop field trials were stored for a maximum of 5.7 months prior
to residue analysis.  There are no storage stability issues or
corrections that might need to be applied to the various residue studies
relevant to the crop commodities discussed in this document.

860.1480 Meat, Milk, Poultry, and Eggs

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

860.1500 Crop Field Trials

Banana

An import tolerance of 0.02 ppm is currently established in 40 CFR
§180.589 for residues of boscalid on banana.  The residue data used to
establish the import tolerance were generated using the 50% WDG
formulation and were reviewed in PP#s   SEQ CHAPTER \h \r 1 1F6313,
3E6791, 4F6875, and 5E6933 (DP# 322235, 11/3/05, D. Dotson).    SEQ
CHAPTER \h \r 1 The petitioner is now proposing to amend the registered
uses of boscalid on bananas to include the use of a 500 g/L SC (Cumora®
Fungicide) formulation.  In support of the proposal to amend the use
pattern, BASF has submitted revised Sections B and F along with a
bridging study (MRID 47353902).  The proposed new use pattern for banana
is presented in Table 3.  In the revised Section F, the petitioner
proposes an increase in the existing tolerance level for banana, from
0.2 ppm to 0.5 ppm.

The Executive Summary of the bridging study DER (MRID 47353902) is
reproduced below.  For the purpose of completeness, the previous study
DER (MRID 46537101) from the initial petition is also reproduced below.

MRID 47353902

DER Reference:	47353902.der.doc

Six side-by-side banana field trials were conducted during the 2006-2007
growing season in Costa Rica (1 trial), Ecuador (1 trial), Colombia (1
trial), Honduras (1 trial), Guatemala (1 trial) and the French West
Indies (1 trial).  Each trial site consisted of one untreated plot and
two treated plots.  At each treated plot, four foliar broadcast
applications of either the 50% water dispersible granules (WDG) or 500
g/L suspension concentrate (SC) formulation of boscalid were made at
~0.135 lb ai/A per application (~0.15 kg ai/ha per application), with a
9- to 11-day retreatment interval, for a total seasonal rate of ~0.54 lb
ai/A (~0.60 kg ai/ha; ~1x the maximum proposed seasonal rate).  All
applications were made using ground equipment from above the canopy to
simulate aerial application in ~3 gal/A (25-30 L/ha) spray volumes; an
adjuvant was added to the spray mixture (spray oil at 2.5-3 L/ha, plus
emulsifier).  Bagged and unbagged bananas were harvested 0 and 1 day
after the last application (DALA).

Samples of banana whole fruit, pulp, and peel were analyzed for residues
of boscalid using an LC/MS/MS method, BASF Analytical Method Number
D9908 (Version II).  The validated limit of quantitation (LOQ) was 0.05
ppm for boscalid in each banana matrix.  The method was adequate for
data collection based on acceptable concurrent recoveries.

Whole banana fruit was stored frozen (<-5°C) for a maximum of 166 days
(5.5 months), banana pulp was stored for a maximum of 168 days (5.5
months), and banana peel was stored for a maximum of 173 days (5.7
months).  Adequate storage stability data are available to support the
conditions and durations for banana samples.

The results of the banana side-by-side trials are summarized in Table 5.
 Following the last of four foliar broadcast applications of the 50% WDG
formulation to banana at a total rate of ~0.54 lb ai/A (0.60 kg ai/ha)
with a 0-day PHI, maximum residues of boscalid were 0.12 ppm in/on
unbagged whole fruit, 0.08 ppm in/on unbagged pulp, and 0.31 ppm in/on
unbagged peel.  Residues of boscalid were below the method LOQ (<0.05
ppm) in/on bagged whole fruit, pulp, and peel.  At the 1-day PHI,
maximum residues of boscalid were 0.06 ppm in/on bagged whole fruit,
0.19 ppm in/on unbagged whole fruit, and 0.47 ppm in/on unbagged peel. 
Residues of boscalid were below the method LOQ (<0.05 ppm) in/on bagged
pulp and peel and in/on unbagged pulp.

In the side-by side trials, following the last of four foliar broadcast
applications of the 500 g/L SC formulation to banana at a total rate of
~0.54 lb ai/A (~0.60 kg ai/ha) with a 0-day PHI, maximum residues of
boscalid were 0.07 ppm in/on bagged whole fruit, 0.28 ppm in/on unbagged
whole fruit, and 0.56 ppm in/on unbagged peel.  Residues of boscalid
were below the method LOQ (<0.05 ppm) in/on bagged pulp and peel and
in/on unbagged pulp.  At the 1-day PHI, maximum residues of boscalid
after use of this formulation were 0.42 ppm in/on unbagged whole fruit
and 0.93 ppm in/on unbagged peel.  Residues of boscalid were below the
method LOQ (<0.05 ppm) in/on bagged whole fruit, pulp, and peel, and
in/on unbagged pulp.

The results of this study indicate that there is no discernible
difference between the residues in bananas obtained using the WDG and SC
formulation of boscalid.  Peel is not considered a significant food/feed
item of banana; therefore, the data are presented for informational
purposes only.

MRID 46537101

DER Reference	46537101.der.doc

Residue Chemistry Memo D322235, 11/3/05, D. Dotson (PP#s   SEQ CHAPTER
\h \r 1 1F6313, 3E6791, 4F6875, & 5E6933)

Twelve field trials were conducted on banana during the 2003-2004
growing season in Costa Rica (2 trials), Colombia (2 trials), Ecuador (2
trials), Guatemala (1 trial), Honduras (2 trials), Martinique (2
trials), and Mexico (1 trial).  At each test location four broadcast
foliar applications of boscalid (50% WDG) were made to bananas at
0.125-0.144 lb ai/A/application.  The total seasonal application rate
ranged from 0.52-0.56 lb ai/A (~1x the maximum proposed seasonal rate). 
The RTI was 10-13 days.  Applications were made using ground equipment,
simulating aerial application above the plant canopy, in spray volumes
of approximately 3 gal/A of water.  An adjuvant (spray oil plus
emulsifier) was added to the spray mixture for all applications.  Mature
banana RAC samples were harvested at 0 DALA.

The residues of boscalid in/on banana samples (unbagged and bagged,
whole fruit RAC and pulp) were quantitated using a validated LC/MS/MS
method, BASF Analytical Method D9908, the data collection method for
plant matrices.  Acceptable concurrent method validation data for banana
commodities were obtained for boscalid.  The validated LOQ was 0.05 ppm
for residues of boscalid in/on banana whole fruit and pulp.  The LOD was
0.005 ppm.

The field residue samples were stored frozen (<-10ºC) a maximum of 4
months from harvest to analysis.  The available storage stability data
indicate that residues of boscalid are stable under frozen conditions
in/on diverse crop matrices for at least 24 months.

The results of the banana trials (MRID 46537101) are summarized in Table
5.  In the banana field trials residues of boscalid ranged from <0.05
ppm to 0.18 ppm in/on 12 samples of unbagged whole bananas harvested
immediately (0-day PHI) after the last of four applications of boscalid
(50% WDG) totaling 0.52-0.56 lb ai/A/season.  Boscalid residues were
<0.05 ppm in/on all 12 treated bagged whole banana samples.  The residue
levels of boscalid in treated pulp samples, both bagged and unbagged
(n=24), were <0.05 ppm (<LOQ).  

Table 5.	Summary of Residue Data from Banana Field Trials with Boscalid.

Crop matrix

[MRID]	Total Applic. Rate 

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



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

Banana (proposed use = 0.536 lb ai/A total application rate, 0/1-day
PHI)

50% WDG Formulation

Whole fruit, bagged [46537101]	0.52-0.56	0	12	<0.05	<0.05	<0.05	<0.05
<0.05	--

Whole fruit, unbagged

[46537101]

	12	<0.05	0.18	0.18	0.07	0.08	0.04

Whole fruit, both

[46537101]

	24	<0.05	0.18	0.18	<0.05	0.07	0.03

Pulp

[46537101]	0.52-0.56	0	24	<0.05	<0.05	<0.05	<0.05	<0.05	--

Whole fruit, bagged

[47353902]	0.534-0.538	0	6	<0.05	<0.05	0.05	0.05	0.05	--

Pulp, bagged

[47353902]

0	6	<0.05	<0.05	0.05	0.05	0.05	--

Peel, bagged

[47353902]

0	6	<0.05	<0.05	0.05	0.05	0.05	--

Whole fruit, unbagged

[47353902]

0	6	<0.05	0.12	0.12	0.06	0.07	0.029

Pulp, unbagged

[47353902]

0	6	<0.05	0.08	0.08	0.05	0.06	0.012

Peel, unbagged

[47353902]

0	6	0.07	0.31	0.31	0.23	0.21	0.103

Whole fruit, bagged

[47353902]	0.534-0.538	1	6	<0.05	0.06	0.06	0.05	0.05	0.004

Pulp, bagged

[47353902]

1	6	<0.05	<0.05	0.05	0.05	0.05	--

Peel, bagged

[47353902]

1	6	<0.05	<0.05	0.05	0.05	0.05	--

Whole fruit, unbagged

[47353902]

1	6	<0.05	0.19	0.19	0.08	0.09	0.05

Pulp, unbagged

[47353902]

1	6	<0.05	<0.05	0.05	0.05	0.05	--

Peel, unbagged

[47353902]

1	6	<0.05	0.47	0.47	0.10	0.15	0.158

500 g/L SC Formulation

Whole fruit, bagged

[47353902]	0.533-0.539	0	6	<0.05	0.07	0.07	0.05	0.05	0.008

Pulp, bagged

[47353902]

0	6	<0.05	<0.05	0.05	0.05	0.05	--

Peel, bagged

[47353902]

0	6	<0.05	<0.05	0.05	0.05	0.05	--

Whole fruit, unbagged

[47353902]

0	6	<0.05	0.28	0.28	0.09	0.12	0.094

Pulp, unbagged

[47353902]

0	6	<0.05	<0.05	0.05	0.05	0.05	--

Peel, unbagged

[47353902]

0	6	0.06	0.56	0.56	0.23	0.25	0.198

Whole fruit, bagged

[47353902]	0.533-0.539	1	6	<0.05	<0.05	0.05	0.05	0.05	--

Pulp, bagged

[47353902]

1	6	<0.05	<0.05	0.05	0.05	0.05	--

Peel, bagged

[47353902]

1	6	<0.05	<0.05	0.05	0.05	0.05	--

Whole fruit, unbagged

[47353902]

1	6	<0.05	0.42	0.42	0.05	0.12	0.148

Pulp, unbagged

[47353902]

1	6	<0.05	<0.05	0.05	0.05	0.05	--

Peel, unbagged

[47353902]

1	6	<0.05	0.93	0.93	0.19	0.30	0.329

1  HAFT = Highest average field trial result.

Conclusions.  The submitted and available residue data for banana are
adequate, and the trials conducted reflect the proposed use pattern for
banana.  The number and locations of field trials are adequate for the
purpose of amending the import tolerance on bananas.  An acceptable
method was used for the quantitation of residues of boscalid, and the
studies are supported by adequate storage stability data.

The Agency generally recommends that twelve field trials be submitted
for imported bananas (NAFTA Guidance Document on Data Requirements for
Tolerances on Imported Commodities, 4/2003).  Twelve trials were
originally submitted for the registration of the WDG formulation.  For
the bridging study, the registrant submitted the results of six trials
performed using each formulation.  In the bridging study, the residue
levels resulting from the use of the two formulations were comparable. 
The average field trial value for the WDG and SC formulations were 0.07
ppm and 0.11 ppm, respectively.  A value of ½ LOQ (0.025 ppm) was used
for samples whose residue value was reported as <LOQ (0.05 ppm). 
Although the average field trial values were relatively close, the
maximum field trial value for the SC formulation was approximately twice
as high as the maximum value for the WDG formulation (0.42 ppm as
opposed to 0.19 ppm).  As the bridging study demonstrated that, in
general, residues were comparable, the results of all banana field
trials were used to determine the recommended tolerance.  Also, the SC
formulation will be used in addition to the WDG formulation currently
being used.  It is not meant to replace the WDG formulation.  All
residue values for unbagged whole bananas were entered into the
Agency’s tolerance spreadsheet to determine an appropriate tolerance
level (see Appendix I).  The tolerance spreadsheet recommends a RAC
tolerance of 0.40 ppm.  This value is higher than the current 0.2 ppm
tolerance for banana because the maximum residue values for the SC
formulation (0.28 and 0.42 ppm) were higher than any of the values from
the WDG field trials.  The petitioner should submit a revised Section F
to lower the proposed RAC tolerance from 0.5 ppm to 0.4 ppm. 

860.1520 Processed Food and Feed

HED does not require residue data for any processed commodities
associated with banana.  Therefore, data requirements for processed food
and feed are not relevant to this tolerance petition.

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

Analytical standards for boscalid (with an expiration date of 4/1/2014)
are currently available in the EPA National Pesticide Standards
Repository (electronic communication, D. Wright, ACB/BEAD, 10/17/08). 
The analytical reference standard for boscalid must be recertified or
replenished as requested by the Repository.  The reference standards
should be sent to the Analytical Chemistry Lab, which is located at Fort
Meade, to the attention of Theresa Cole at the following address:

	USEPA

	National Pesticide Standards Repository/Analytical Chemistry Branch/OPP

	701 Mapes Road

	Fort George G. Meade, MD  20755-5350

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

860.1850 and 860.1900 Confined and Field Accumulation in Rotational
Crops

As the proposed uses on banana do not include rotational crops, these
guideline requirements are not relevant to the current petition.

860.1550 Proposed Tolerances

The residue of concern in plants is boscalid per se for the purposes of
risk assessment and tolerance expression.  Boscalid tolerances for plant
commodities are listed in 40 CFR §180.589 (a)(1) and are expressed in
terms of residues of the fungicide boscalid [3-pyridinecarboxamide,
2-chloro-N-(4'-chloro[1,1'-biphenyl]-2-yl)].  The tolerance expression
proposed by BASF in PP#8E7366 is consistent with the tolerance
definition for plant commodities listed in 40 CFR §180.589 (a)(1).

The submitted banana side-by-side field trial data for the WDG and SC
formulations, along with the data previously submitted for banana using
the WDG formulation are adequate.  The field trial data for both
formulations were entered into the Agency’s tolerance spreadsheet as
specified by the Guidance for Setting Pesticide Tolerances Based on
Field Trial Data SOP (version dated 2/2008) to determine an appropriate
tolerance level (see Appendix I).  Based on the output from the
tolerance spreadsheet, HED recommends establishment of an import
tolerance of 0.40 ppm for banana.

The Codex Alimentarius Commission has established a MRL for residues of
boscalid in or on banana at 0.2 ppm, which is equivalent to the current
U.S. tolerance.  However, the recommended U.S. tolerance is higher than
the Codex MRL.  Mexico has not established any MRLs for residues of
boscalid in/on raw agricultural commodities.  Canadian MRLs have been
established for a variety of crops but not for banana.

A tolerance summary is presented below in Table 6.

Table 6.   Tolerance Summary for Boscalid.

Commodity	Current §180.589

Tolerance (ppm)	Proposed §180.589

Tolerance (ppm)	Recommended §180.589

Tolerance (ppm)	Comments; 

Correct Commodity Definition

Banana	0.2 1	0.5	0.40

	1 Import tolerance, no current U.S. registration

References

PP#1F06313.  BAS 510 F (Common Name: Boscalid), New Fungicide Active
Ingredient.  Residue Chemistry Summary Document, 278385, M. Nelson,
08/15/03

  SEQ CHAPTER \h \r 1 PP#s 1F6313, 3E6791, 4F6875, and 5E6933: 
Boscalid, Registrant’s Response to Deficiencies Cited in Tolerance
Petition 1F6313.  Summary of Analytical Chemistry and Residue Data for
Rotational Root Crops, Direct Uses on Celery, Spinach, Bananas,
Strawberries, Almonds, and Potatoes, and Seed Treatment Uses on Bulb
Vegetables, Brassica Leafy Vegetables, Legume Vegetables, Peanuts, and
Sunflowers, 322235, D. Dotson, 11/3/05

NAFTA Guidance Document on Data Requirements for Tolerances on Imported
Commodities, USEPA (OPP), Canada (PMRA), and Mexico (CICOPLAFEST),
4/2003

  SEQ CHAPTER \h \r 1 Attachments:  

International Residue Limit Status sheet

Appendix I - Tolerance Assessment Calculations



INTERNATIONAL RESIDUE LIMIT STATUS

Chemical Name:  3-pyridinecarboxamide,
2-chloro-N-(4'-chloro[1,1'-biphenyl]-2-yl	Common Name:  Boscalid

	X Proposed tolerance

⁪ Reevaluated tolerance

⁪ Other	Date:  8/26/08

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

⁪ No Codex proposal step 6 or above

⁪ No Codex proposal step 6 or above for the crops requested	Petition
Number:  PP#8E7366

DP#:  355200

Other Identifier:  

Residue definition (step 8/CXL):  Boscalid	Reviewer/Branch:  C.
Swartz/D. Dotson/RAB2

	Residue definition:  Boscalid  

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

Banana	0.2	Banana	0.5





















Limits for Canada	Limits for Mexico

(
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丠⁯楌業獴

⁪ No Limits for the crops requested

Residue definition:  2-chloro-N-(4'-chloro[1,1'-

biphenyl]-2-yl)-3-pyridinecarboxamide

	Residue definition:  N/A

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

























	Notes/Special Instructions:

S. Funk, 08/26/08



Appendix I.  Tolerance Assessment Calculations.

The dataset used to establish a tolerance for boscalid on imported
banana consisted of field trial data for unbagged whole banana.  For
unbagged whole banana, the data entered reflect application rates of
0.52-0.60 lb ai/A (4 applications at 0.125-0.144 lb ai/A per
application) using the WDG and SC formulation with either a 0- or 1-day
PHI.  As specified by the Guidance for Setting Pesticide Tolerances
Based on Field Trial Data SOP (version dated 2/2008), the field trial
application rates and PHIs are within 25% of the maximum label
application rate and minimum label PHI, respectively.  Table I-1 lists
the residue data for unbagged bananas sorted by formulation.  The
residue values that were entered into the tolerance spreadsheet in Table
I-1 are the aggregates of all data submitted for unbagged bananas using
both formulations and approximating the proposed use pattern. 

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Dximum likelihood estimation (MLE) procedures were needed to impute
censored values.  In Table I-1, “(MLE)” is used to designate he
imputed values.  Visual inspection of the lognormal probability plot
(Figure I-1) and the results from the approximate Shapiro-Francia test
statistic (Figure I-2) indicated that the dataset was reasonably
lognormal.  

As the field trial data for boscalid on unbagged banana represent a
large dataset (i.e., more than 15 samples) and are reasonably lognormal,
the minimum of the 95% upper confidence limit (UCL) on the 95th
percentile and the point estimate of the 99th percentile should be
selected as the tolerance value.  Using the rounding procedure as
outlined in the SOP, the 95% UCL on the 95th percentile rounds to the
value 0.40 ppm and the point estimate of the 99th percentile rounds to
the value 0.45 ppm (Figure I-2).  Because the 0.40-ppm value was the
minimum value, 0.40 ppm is the recommended tolerance level for boscalid
on banana.

Table I-1.	Residue data used to calculate tolerance for boscalid on
banana.

Regulator:	EPA	EPA	EPA	EPA

Chemical:	Boscalid (WDG)	Boscalid (WDG)	Boscalid (SC)	Boscalid (WDG &
SC)

Crop:	Banana, whole fruit, unbagged	Banana, whole fruit, unbagged
Banana, whole fruit, unbagged	Banana, whole fruit, unbagged (MLE)

PHI:	0 Days	0-1 Days	0-1 Days	0-1 Days

Total App. Rate:	0.52-0.56 lb ai/A	0.53-0.54 lb ai/A	0.60 lb ai/A
0.52-0.60 lb ai/A

Submitter:	BASF Corporation	BASF Corporation	BASF Corporation	BASF
Corporation

MRID Citation:	MRID 446537101	MRID 47353902	MRID 47353902	MRIDs
446537101 and 47353902

	Residues of Boscalid (ppm)

	0.050	0.120	0.120	0.050

	0.100	0.190	<0.05	0.100

	<0.05	<0.05	<0.05	0.015 (MLE)

	0.100	<0.05	<0.05	0.100

	<0.05	<0.05	0.180	0.017 (MLE)

	0.180	0.080	0.120	0.180

	<0.05	<0.05	<0.05	0.020 (MLE)

	0.070	<0.05	<0.05	0.070

	0.090	0.060	0.280	0.090

	0.110	0.080	0.420	0.110

	0.070	0.090	0.050	0.070

	<0.05	0.080	<0.05	0.022 (MLE)





0.120





0.190





0.024 (MLE)





0.026 (MLE)





0.028 (MLE)





0.080





0.030 (MLE)





0.032 (MLE)





0.060





0.080





0.090





0.080





0.120





0.034 (MLE)





0.036 (MLE)





0.039 (MLE)





0.180





0.120





0.041 (MLE)





0.043 (MLE)





0.280





0.420





0.050





0.048 (MLE)

  

Figure I-   SEQ Figure_II- \* ARABIC  1 .  Lognormal probability plot of
boscalid field trial data for banana.

Figure I- 2.  Tolerance spreadsheet summary of boscalid field trial data
for banana.

Page   PAGE  1  of   NUMPAGES  19 

Boscalid	Summary of Analytical Chemistry and Residue Data	DP#: 354687

