UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

	OFFICE OF PREVENTION, PESTICIDE

	AND TOXIC SUBSTANCES

  SEQ CHAPTER \h \r 1 MEMORANDUM

Date:	04/02/09

SUBJECT:	Pyraclostrobin: Petitions for the Establishment of Permanent
Tolerances on Grain, Sorghum Grain, Forage and Stover (PP#8F7385);
Increase of Tolerance for the Stone Fruit Crop Group 12 to satisfy
European Union (EU) import requirement (PP#8F7390); and Establishment of
a Permanent import Tolerance for Coffee (PP#8E7394).  Summary of
Analytical Chemistry and Residue Data. 

 

PC Code:  099100, 125620 & 128008	DP Barcode: 359194

Decision No.: 397102	Registration No.: 7969-186, 7969-266

Petition Nos.: 8F7385, 8F7390, and 8E7394 	Regulatory Action:  Section 3
Registration

Risk Assessment Type: N/A	Case No.: N/A

TXR No.: N/A	CAS No.: 175013-18-0 

MRID No.: 47470201 through 47470204	40 CFR: 180.582

		              									Ver.Apr.08

	          	

FROM:		Meheret Negussie, Chemist	  SEQ CHAPTER \h \r 1 

			Risk Assessment Branch III

			Health Effects Division (7509P)

THROUGH:		Thurston Morton, Chemist	  SEQ CHAPTER \h \r 1 

			Risk Assessment Branch IV

			Health Effects Division (7509P)

				and

			Leung Cheng, Senior Chemist	  SEQ CHAPTER \h \r 1 

			Risk Assessment Branch III

			Health Effects Division (7509P)

		

TO:			Tony Kish, RM# 22 

			Fungicide Branch		  SEQ CHAPTER \h \r 1   SEQ CHAPTER \h \r 1 

			Registration Division (7505P)

	

Executive Summary

  SEQ CHAPTER \h \r 1 Pyraclostrobin belongs to the strobilurin class of
fungicides.  Strobilurins are synthetic analogs of a natural antifungal
substance which inhibits spore germination, mycelial growth, and
sporulation of the fungi causing diseases such as fruit rot in
strawberry, early leaf rot in peanuts, late blight in pestachios, rust
diseases in soybeans, pre- and post fruit rot of pome and stone fruits. 
The fungicide is currently registered to BASF Corporation (BASF) for use
on a variety of field, vegetable, fruit, and nut crops.  It is
formulated as water-dispersible granules (WDG) or an emulsifiable
concentrate (EC) and is typically applied as foliar applications using
ground or aerial equipment at maximum seasonal rates of 0.3-3.0 lb ai/A.
 The 20% WDG formulation is also registered for use as a seed treatment
on some crops.

In PP#8F7385, BASF requests the establishment of new tolerances for the
combined residues of the fungicide pyraclostrobin (carbamic acid,
[2-[[[1-(4-chlorophenyl)-1H- pyrazol-3-yl]oxy]methyl]phenyl]methoxy-,
methyl ester) and its desmethoxy metabolite
(methyl-N-[[[1-(4-chlorophenyl)pyrazol-3-yl]oxy]-o-tolyl] carbamate),
expressed as parent compound, in/on the following commodities:

Sorghum, grain	0.5 ppm

Sorghum, forage	5 ppm

Sorghum, stover	0.8 ppm

Concurrently, BASF wishes to amend the registration of Headline®
Fungicide (EPA Reg. No. 7969-186) to add use on grain sorghum. 
Headline® Fungicide is an EC formulation containing 23.6% ai (2.09 lb
ai/gal) of pyraclostrobin.  The proposed use is one foliar application
at the maximum seasonal rate of 0.2 lb ai/A. The application may be made
using ground equipment.  The proposed preharvest intervals (PHI) range
to the beginning of flowering stage (25%).  In addition, the petitioner
is requesting to amend the registration of Stamina Fungicide Seed
Treatment BAS 500 12 F (EPA Reg. No. 7969-266), containing 18.4% ai
(1.67 lb/gal), to add seed treatment on grain sorghum.  BAS 500 12 F is
proposed for seed treatment at maximum rates of 0.01-0.02 lb ai/100 lb
seed (0.002 lb ai/A).

In PP#8F7390, BASF requests an increase in tolerance for the combined
residues of the fungicide pyraclostrobin and its desmethoxy metabolite,
expressed as parent compound, in/on stone fruit crop group 12.  The
proposed tolerance is: 

Fruit, stone, group	2.5 ppm

In PP#8E7394, BASF requests the establishment of tolerances for the
combined residues of the fungicide pyraclostrobin and its desmethoxy
metabolite, expressed as parent compound, in/on imported coffee.  The
proposed tolerance is: 

Coffee, bean, green	0.5 ppm

  SEQ CHAPTER \h \r 1 Pyraclostrobin tolerances have been established in
40 CFR §180.582.  Tolerances for plant commodities are listed in 40 CFR
§180.582 (a)(1) and are expressed in terms of the combined residues of
the fungicide pyraclostrobin (carbamic acid,
[2-[[[1-(4-chlorophenyl)-1H- pyrazol-3-yl]oxy]methyl]phenyl]methoxy-,
methyl ester) and its desmethoxy metabolite (methyl
N-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl carbamate),
expressed as parent compound.  The established tolerances for plant
commodities range from 0.02 ppm in/on wheat grain to 29 ppm in/on leafy
vegetables, except Brassica.

Tolerances for livestock commodities are listed in 40 CFR §180.582
(a)(2) and are expressed in terms of the combined residues of the
fungicide pyraclostrobin and its metabolites convertible to
1-(4-chlorophenyl)-1H-pyrazol-3-ol and
1-(4-chloro-2-hydroxyphenyl)-1H-pyrazol-3-ol, expressed as parent
compound.  The established tolerances for livestock commodities range
from 0.1 to 1.5 ppm; no tolerances are established for poultry
commodities.

	

The nature of the residue in plants, rotational crops, and livestock is
adequately understood.   In plants,   SEQ CHAPTER \h \r 1 the results of
metabolism studies conducted on grape, potato, and wheat indicate that
pyraclostrobin and its desmethoxy metabolite (BF 500-3) are the major
residues in crop matrices including livestock feeds; tryptophan was
found to be the major residue in potato tuber and wheat grain when
carbon-14 was introduced in the tolyl ring (via the shikimic acid
pathway).  The major degradation reactions are the removal of the
methoxy group from the carbamate nitrogen and breakage of the ether
bond.  In rotational crops, it was   SEQ CHAPTER \h \r 1 shown that
pyraclostrobin and its desmethoxy metabolite are the major residues
taken up into the plants.  In the   SEQ CHAPTER \h \r 1 goat, the major
residues are pyraclostrobin and BF 500-3 in muscle and fat;
pyraclostrobin, BF 500-3, and BF 500-5
(1-(4-chlorophenyl)-1H-pyrazol-3-ol) and its sulfate conjugate in milk;
pyraclostrobin, BF 500-3, and BF 500-5 and its sulfate conjugate, and
hydroxylated desmethoxy metabolite (500M67) in kidney; and metabolites
hydrolyzed to BF 500-5 and its hydroxylated compound (BF 500-8;
1-(4-chloro-2-hydroxyphenyl)-1H-pyrazol-3-ol in liver.  In poultry, the
major residues are pyraclostrobin and BF 500-3 in eggs; pyraclostrobin,
BF 500-3, and hydroxylated BF 500-3 (500M64) in fat; and the glucuronic
acid conjugate of hydroxylated BF 500-3 (500M32) in liver.  Radioactive
residues were below detection in muscle.  The main degradation reactions
in livestock consist of demethoxylation, hydroxylation, and conjugation,
and breaking of the ether bond.

The HED Metabolism Assessment Review Committee (MARC memo 10/9/01, DP#
278044, L. Cheng) has determined that for purposes of tolerance and
dietary risk assessments, the residues of concern in plant and
rotational crop commodities include pyraclostrobin and metabolite BF
500-3.  The residues of concern in livestock commodities include
pyraclostrobin and its metabolites convertible to
1-(4-chlorophenyl)-1H-pyrazol-3-ol (BF 500-5) and
1-(4-chloro-2-hydroxyphenyl)-1H-pyrazol-3-ol (BF 500-8).

There are adequate residue analytical methods for tolerance enforcement
and data collection.    SEQ CHAPTER \h \r 1 The analytical methods
(LC/MS/MS and HPLC/UV) for plant commodities measure pyraclostrobin and
its desmethoxy metabolite.  The methods (GC/MS and LC/MS/MS) for
livestock commodities convert pyraclostrobin and related metabolites to
chlorophenylpyrazolol (BF 500-5) and hydroxylated chlorophenylpyrazolol
(BF 500-8) in goats and chlorophenylpyrazolol (BF 500-5) and
hydroxylated chlorophenylpyrazolol (BF 500-9) in poultry.  These methods
were successfully validated by an independent laboratory and validated
using radiolabeled samples from metabolism studies.  The proposed
enforcement methods have been forwarded to ACB/BEAD for petition method
validations.  HED concludes that these methods are suitable as
enforcement methods.  Samples of raw agricultural and processed
commodities from the current petitions were analyzed for pyraclostrobin
residues of concern using an adequate LC/MS/MS method (BASF Method
D9908), which is similar to the proposed enforcement method.  The method
was adequately validated in conjunction with the field trial analyses. 
For each analyte, the validated limit of quantitation (LOQ) is 0.02 ppm
in plant commodities, 0.01 ppm in milk, and 0.05 ppm in eggs and
tissues. 

The requirements for multiresidue methods testing data are fulfilled. 
Pyraclostrobin was successfully evaluated through several of the FDA
protocols (complete recovery through protocols D and E), while recovery
of metabolite BF 500-3 was unsuccessful in all protocols.

There are adequate storage stability data from previous pyraclostrobin
petition submissions.  (DP# 269668, 11/28/01, L. Cheng (PP#0F6139). 
These data may be translated in the current petition to validate sample
storage conditions and durations.  There are no corrections which need
to be applied since pyraclostrobin residues of concern were found to be
reasonably stable over a wide range of commodities under frozen storage
conditions for 19-25 months.

Adequate cattle and poultry feeding studies are available to support the
livestock dietary burdens resulting from the proposed uses.  Previously
the maximum theoretical dietary burden (MTDB) of pyraclostrobin to beef
and dairy cattle were estimated (DP# 269668, 11/28/01, L. Cheng) to be
36.3 ppm and 35.4 ppm, respectively. Dietary burdens were calculated for
beef (4.9 ppm), dairy (9.5 ppm), poultry (0.95 ppm), and swine (0.55
ppm).  The calculations reflect the most recent guidance from HED
concerning revisions of feedstuff percentages in “Table 1
Feedstuffs” (June 2008) and construction of reasonably balanced
livestock diets.  Based on these dietary exposure levels and the residue
data from the ruminant feeding study, the existing pyraclostrobin
tolerances for milk, meat, fat, meat byproducts except liver, and liver
of cattle, goats, hogs, horses, and sheep are adequate, and no
adjustments are needed.  Tolerances for eggs and poultry are not needed
at this time based on data from the poultry feeding and metabolism
studies [Category 180.6(a)(3)].  If in the future, the petitioner
proposes a use which increases the dietary burdens of poultry, then the
Category 3 situation will be re-evaluated.

The submitted field trial data on grain sorghum forage, grain sorghum
grain, and grain sorghum stover are adequate.  Based on the available
data, HED recommends tolerances of 5.0 ppm on grain sorghum, forage,
0.60 ppm on grain sorghum, grain, and 0.80 ppm on grain sorghum, stover.

The submitted field trial data on stone fruits submitted in PP#8F7390
are adequate.  There are already existing residue data at 0-day PHI for
stone fruits generated using the Headline 20%WDG formulation (containing
pyraclostrobin as the only active ingredient).  The new stone fruit
field trials were conducted using the Pristine 12.8% WG formulation
(containing pyraclostrobin and boscalid as the active ingredients). 
Combined residues of pyraclostrobin in stone fruits resulting from
applications of Pristine WG formulation (5 x 0.12 lb ai/A) ranged from
0.04 – 1.88 ppm at 0-day PHI and from 0.04 – 1.90 ppm at 1-day PHI. 
The new 0-day residue data are higher than those submitted using the
Headline that ranged from 0.04 - 0.67 ppm.  The current EPA established
tolerance for total residues of pyraclostrobin in the fruit stone, group
12 is 0.9 ppm.  Based on the available data, HED recommends for the
increased tolerance of 2.5 ppm on fruit stone, group 12.  

The submitted field trial data on coffee are adequate.  Adequate
processing studies were also available on coffee.  The coffee processing
study indicates that residues of pyraclostrobin do not concentrate in
coffee processed fractions.  Based on the available data, HED recommends
a 0.30 ppm tolerance on coffee, green bean.

Analytical reference standards for pyraclostrobin and its regulated
metabolites are available at the EPA National Pesticide Standards
Repository. 

Regulatory Recommendations and Residue Chemistry Deficiencies

Provided a revised Section F is submitted, there are no residue
chemistry issues that would preclude granting registration for the
requested use of pyraclostrobin as stated below. 

Provided the forthcoming Human Health Risk Assessment does not identify
any risks concerns, HED recommends establishment of tolerances as
follows:

	Appropriate 	Tolerances For Revised Section F:

Sorghum, grain, forage	5.0 ppm

Sorghum, grain, grain	0.60 ppm

Sorghum, grain, stover	0.80 ppm

Fruit, stone, group 12	2.5 ppm

Coffee	0.30 ppm

HED also recommends in favor of the registrant’s requests to amend
Headline® Fungicide (EPA Reg. No. 7969-186) to add uses on grain
sorghum and coffee, and Stamina Fungicide Seed Treatment (EPA Reg. No.
7969-266) to add new uses on grain sorghum. 

	Background

Pyraclostrobin belongs to the strobilurin class of fungicides. 
Strobilurins are synthetic analogs of a natural antifungal substance
which inhibits spore germination and mycelial growth and sporulation of
the fungus on the leaf surface.  The fungicide is currently registered
to BASF for use on a variety of field, vegetable, fruit, and nut crops. 
Permanent tolerances are established [40 CFR §180.582(a)(1)] for the
combined residues of pyraclostrobin and its desmethoxy metabolite (BF
500-3), expressed as parent, in/on numerous plant commodities at levels
ranging from 0.02 ppm in/on wheat grain to 29 ppm in/on leafy
vegetables, except Brassica.  The chemical structure and nomenclature of
pyraclostrobin are presented in Table  1.  The physicochemical
properties of the technical grade of pyraclostrobin are presented in
Table 2.

TABLE 1.	Test Compound Nomenclature.

Compound	

Common name	Pyraclostrobin

Company experimental name	BAS 500 F

IUPAC name	methyl
N-{2-[1-(4-chlorophenyl)-1H-pyrazol-3-yloxymethyl]phenyl}(N-methoxy)
carbamate

CAS name	methyl
[2-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl]methoxycarbam
ate

CAS registry number	175013-18-0

End-use products (EP)	2.0 lb/gal EC-formulation (Headline® Fungicide,
EPA Reg. No. 7969-186), 1.67 lb/gal Stamina Fungicide Seed Treatment BAS
500 12 F (EPA Reg. No. 7969-266), BAS 516 04F -12.8% WG (Pristine®
Fungicide;  EPA Reg. No. 7969-199, which also contains 25.2% of
boscalid)





TABLE 2.	Physicochemical Properties of Technical Grade Pyraclostrobin.

Parameter	Value	References1  (MRID) 

Melting point/range	63.7-65.2º C	45118213

pH	Not applicable

	Density	1.367 g/cm3 	45118214

Water solubility at 20º C	1.9 ± 0.17 mg/L (deionized water, pH 5.8)

	45118233

Solvent solubility	n-heptane: (0.37 g/100mL);  2-propanol (3.0 g/100mL);
1-octanol (2.42 g/100mL);  olive oil (2.80 g/100m/L);  methanol  (10.08
g/100mL); >50 g/100mL in acetone, ethyl acetate , acetonitrile, DCM and
toluene.	45118228

Vapor pressure	2.6 x 10-10 hPa  at 20º C

	45118214

Dissociation constant, pKa	None (no dissociable moieties)

	Octanol/water partition coefficient, Log(KOW) at room temperature	3.990
mean log Pow;  (Pow is 9772) 

	45118215

UV/visible absorption spectrum	The structural identity of BAS 500 F was
confirmed by NMR and MS spectra. UV molecular extinction (e [1 mol-1
cm-1]): 2.5x104 at 205 nm; 2.4x104 at 275 nm.	1996/109552



1	Product Chemistry data were reviewed by the Registration Division (DP#
269848 and DP# 274191, 5/3/01, 5/15/01, and 6/7/01, S. Malak).  

2	BASF  Document Number.

	

Directions for Use

A summary of the pyraclostrobin end-use products proposed for use on the
crops discussed in this document is listed in Table 3. Table 4 presents
the summary of proposed crop use patterns. 

TABLE 3.   Summary of Proposed Pyraclostrobin End-Use Products.

Trade Name	EPA Reg. No.	% ai of Formulation	Formulation Type	Target
Crops	Label Date

Headline® Fungicide	7969-186	23.6%,

(2.09 lb ai/gal)	EC	Sorghum	Supplemental label attached in Section B.
(June 30, 2008)

Stamina BAS 500 12 F	7969-266	18.4%

(1.67 lb ai/gal)	Seed Treatment	Sorghum	Supplemental label attached in
Section B. (June 30, 2008)

Pristine® Fungicide

BAS 516 04F (Mix with Boscalid)	7969-199	12.8%

(1.1 lb ai/gal)

	WG	Stone Fruits Group-Apricot, Cherry (sweet and sour), Nectarine,
Peach, Plum and Prune.	Label March 27, 2008

Headline® Fungicide (COMET® in Brazil)	7969-186	23.6%

(2.09 lb ai/gal)	EC	Coffee	Supplemental label attached in Section B.
(June 30, 2008).



TABLE 4.  Summary of Proposed/Registered Use Patterns of Pyraclostrobin
on Various Crops.

Applic. Timing, Type, and Equip.	Formulation

[EPA Reg. No.]	Applic. Rate

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

(lb ai/A)	PHI

(days)	Use Directions and Limitations

Grain Sorghum

 Ground sprayer, aerial, or sprinkler irrigation systems.	[7969-186]

23.6% EC	(0.1-0.2)

6 to 12 fl ozs/A	1	(0.2)

12 fl ozs/A	 No later than 25% flowering	 Begin applications prior to
disease development. Use higher rate (0.15-0.2 lb ai/A) when disease
pressure is high (Northern leaf blight and Southern leaf blight). 

Do not use in greenhouse or transplant production systems. For
resistance management, if additional fungicide application is needed use
a labeled non-group 11 fungicide with a different mode of action. No
aerial application in NY state except as permitted under FIFRA section
24(c).

Grain Sorghum      

Apply as a water-based mixture using standard slurry or mist-type seed
treatment application equipment. 	[7969-266]

18.4%	(0.001-0.002)

0.01-0.02 lb/100 lbs seed

	N/S

	N/S

	Seed treatment	Use at commercial treatment facilities. Not for use on a
farm. Use higher rate when disease pressure is expected to be high. 

Mechanical agitation is required for proper mixing. 

Coffee      

Ground sprayer, aerial, or sprinkler irrigation systems.	[7969-186]

25% EC	(0.1-0.2) 

150-200

g/ha	2	N/S

	45	Apply when leaf infection indexes up to 5% are observed. Re-apply in
dose of  0.1 lb ai/A whenever the infection index by rust reaches up to
5% again. Maximum of two applications.  

Stone Fruits Crop Group 12

 Ground application, aerial, or sprinkler irrigation equipment. 
[7969-199]

12.8% WG	(0.084-0.117)

10.5-14.5 ozs of product1	5	(0.585)

72.5 ozs of product1	0	 Begin application at pink bud or prior to onset
of disease development and continue on a 7-14 day interval. Do not make
more than 5 applications of Pristine or other group 7 or 11 fungicides
per season.  Do not make more than 2 sequential applications before
alternating to a labeled fungicide with a different mode of action. For
aerial application, use no less than 10 gal of spray solution per acre. 

Do not apply when wind speed favors drift. Do not use in grrenhouse or
transplant production. No aerial application in NY state except as
permitted under FIFRA section 24(c).

N/S= not specified

1 0.128 oz (0.008lb) of pyraclostrobin in 1 oz of product.

Conclusions.  The submitted use directions are sufficient to allow
evaluation of the available residue data relative to the proposed use. 
The field trial data for grain sorghum, the stone fruit crop group 12,
and coffee reflect the proposed use pattern.  

860.1300 Nature of the Residue - Plants

HED Metabolism Assessment Review Committee Decision Memo, DP# 278044,
10/9/01, L. Cheng;  Residue Chemistry Memo, DP# 269668, 11/28/01, L.
Cheng (PP#0F6139)

The nature of the residue in plants is adequately understood based on
acceptable metabolism studies conducted on grape, potato, and wheat. 
The metabolism of pyraclostrobin is similar in the three crops
investigated.  Pyraclostrobin and its desmethoxy metabolite (BF 500-3)
are the major residues in crop matrices including livestock feeds;
tryptophan was found to be the major residue in potato tuber and wheat
grain when carbon-14 was introduced in the tolyl ring (via the shikimic
acid pathway).  The major degradation reactions are the removal of the
methoxy group from the carbamate nitrogen and breakage of the ether
bond.

The HED MARC has determined that for the tolerance and risk assessment,
the terminal residues of concern in plants consist of pyraclostrobin and
its metabolite BF 500-3.

		

860.1300 Nature of the Residue – Livestock

HED Metabolism Assessment Review Committee Decision Memo, DP# 278044,
10/9/01, L. Cheng;  Residue Chemistry Memo, DP# 269668, 11/28/01, L.
Cheng (PP#0F6139)

The nature of the residue in livestock is adequately understood based on
acceptable ruminant and poultry metabolism studies.  In the   SEQ
CHAPTER \h \r 1 goat, the major residues are pyraclostrobin and BF 500-3
in muscle and fat; pyraclostrobin, BF 500-3, and BF 500-5 and its
sulfate conjugate in milk; pyraclostrobin, BF 500-3, and BF 500-5 and
its sulfate conjugate, and hydroxylated desmethoxy metabolite (500M67)
in kidney; and metabolites hydrolyzed to BF 500-5 and its hydroxylated
compound (BF 500-8) in liver.  In poultry, the major residues are
pyraclostrobin and BF 500-3 in eggs; pyraclostrobin, BF 500-3, and
hydroxylated BF 500-3 (500M64) in fat; and the glucuronic acid conjugate
of hydroxylated BF 500-3 (500M32) in liver.  Radioactive residues were
below detection in muscle.  The main degradation reactions in livestock
consist of demethoxylation, hydroxylation, and conjugation, and breaking
of the ether bond.

The HED MARC has determined that for the tolerance and risk assessment,
the residues of concern in livestock commodities consist of
pyraclostrobin and its metabolites convertible to
1-(4-chlorophenyl)-1H-pyrazol-3-ol (BF 500-5) and
1-(4-chloro-2-hydroxyphenyl)-1H-pyrazol-3-ol (BF 500-8).

860.1340 Residue Analytical Methods

Chemistry Memo, DP# 269668, 11/28/01, L. Cheng (PP#0F6139)

Chemistry Memo DP# 269850, 11/8/00, L. Cheng (PP#0F6139)

There are adequate residue analytical methods for tolerance enforcement
and data collection.

  SEQ CHAPTER \h \r 1 

Plant commodities:  Two adequate methods were proposed in PP#0F6139 for
enforcing tolerances for residues of pyraclostrobin and the metabolite
BF 500-3 in/on plant commodities:  an LC/MS/MS method (BASF Method
D9908) and an HPLC/UV method (Method D9904).  The validated method LOQ
for both pyraclostrobin and BF 500-3 is 0.02 ppm in all tested plant
matrices, for a combined LOQ of 0.04 ppm.  Adequate independent method
validation and radiovalidation data were submitted for both methods and
forwarded to ACB/BEAD for a petition method validation.

Except for green coffee beans, samples of raw agricultural and processed
commodities PP#8F7385, PP#8F7390 and PP#8E7394 were analyzed for
residues of pyraclostrobin and its desmethoxy metabolite BF 500-3 using
BASF Analytical Method D9908 (version II for sorghum).  Briefly,
residues were extracted by shaking with methanol:water:2 N HCl (70:25:5;
v:v:v); methanol:water (70:30, v:v) and centrifuged.  Residues were then
partitioned with cyclohexane and 1N HCL saturated with NaCl,
concentrated to dryness, and re-dissolved in buffered methanol:water
(80:20, v:v).  The final chromatographic analysis of residues was
determined by LC/MS/MS.  Total residues of pyraclostrobin and BF 500-3
are expressed as pyraclostrobin equivalents.  For each analyte, the
validated method LOQ is 0.02 ppm. The method is adequate for data
collection based on acceptable concurrent method recovery data.

Samples of coffee (green beans) (PP#8E7394) in Brazil were analyzed for
residues of pyraclostrobin and its metabolite BF 500-3 using an LC/MS/MS
method according to SOP-PA.0243 based on BASF method 445/0.  Sample
extraction is similar to Method D9908 described above, except the final
extract is re-dissolved in buffered methanol:water (50:50, v:v).  For
each analyte, the validated method LOQ is 0.02 ppm, and the calculated
LODs are 0.003 ppm for pyraclostrobin and 0.001 ppm for BF-500-3.  The
method is adequate for data collection based on acceptable concurrent
method recovery data.

Livestock commodities:    SEQ CHAPTER \h \r 1 In the previous petition,
PP#0F06139, two tolerance enforcement methods were proposed for ruminant
commodities:  HPLC/UV method 439/0 and Method 446, consisting of GC/MS
method 446/0 and LC/MS/MS method 446/1.  The HPLC/UV method determines
residues of pyraclostrobin per se.  Method 446 has a hydrolysis step,
and determines residues of pyraclostrobin and its metabolites as BF
500-5 and BF 500-8.  The validated method LOQs for BF 500-5 type
residues, in parent equivalents, are 0.01 ppm for milk and 0.05 ppm for
tissues, and the validated LOQs for BF 500-8 type residues, in parent
equivalents, are 0.01 ppm for milk, and 0.05 ppm for tissues. 
Independent method validation data for the HPLC/UV and LC/MS/MS methods
are acceptable.  Radiovalidation data submitted for the GC/MS and
LC/MS/MS methods are adequate for liver and milk, and marginal for
muscle.  Method 446 has been forwarded to ACB/BEAD for petition method
validation.  HED concludes that Method 446 is suitable as an enforcement
method.  The petitioner had been requested to modify the proposed
enforcement method to include any modifications made by the EPA
laboratory during the Agency laboratory validation.  An enforcement
method for poultry was reviewed in PP#0F06139.  However, tolerances for
poultry egg and tissues have not been established and are not required
for the purpose of these petitions.

860.1360 Multiresidue Methods

Residue Chemistry Memo, DP# 269668, 11/28/01, L. Cheng (PP#0F6139)

A cursory summary of the multiresidue methods testing data for
pyraclostrobin and its metabolite BF500-3 was reported in PP#0F6139. 
Pyraclostrobin was successfully evaluated through several of the FDA
protocols, while recovery of BF 500-3 was unsuccessful in all protocols.
 Pyraclostrobin was completely recovered through Protocol D (in grape)
and E (in grape), and partially recovered through Protocol F (in
peanut).  Metabolite BF 500-3 had poor peak shape and inadequate
sensitivity with Protocol C columns, and therefore, was not further
analyzed under Protocol D, E, and F.  The results of the multiresidue
testing for pyraclostrobin were forwarded to FDA on 1/4/02 for the
purpose of updating PAM, Volume I.

860.1380 Storage Stability

Residue Chemistry Memo, DP# 269668, 11/28/01, L. Cheng (PP#0F6139)

hat pyraclostrobin and metabolite BF 500-3 are reasonably stable at
≤-10 ºC in fortified samples of grape juice (juices), sugar beet tops
(leafy vegetables), sugar beet roots (root crop), tomatoes
(fruit/fruiting vegetable), wheat grain (non-oily grain), and wheat
straw (dry feed) for up to 25 months, and in fortified samples of peanut
nutmeats (oilseed) and peanut oil for up to 19 months.

The storage intervals and conditions for samples collected from the
magnitude of the residue and processing studies discussed in this
document are presented below in Table 5.

TABLE 5.   Summary of Storage Conditions and Intervals of Samples from
Crop Field Trials.  

Matrix 	MRID	Storage Temperature (°C)	Actual Storage Duration (Months)
Interval of Demonstrated Storage Stability (months) 

Sweet/Sour Cherry	47470201

	-10

	5.7	19-25



Peach

	4.9

	Plum

	3.8

	Sorghum Forage	47470203

	-5

	5.3	19-25



Sorghum Grain

	8.2

	Sorghum Stover

	5.3

	Coffee	47470204

	≤-20	4.1	19-25

Coffee (Green bean, Caleaned green bean, Roasted beans, Dried spent
grounds, Liquor extract, and Instant coffee).	47470202

	<-5	<1 month	19-25



Conclusions.  The storage conditions and durations of samples are
supported by adequate storage stability data available indicating that
pyraclostrobin and BF 500-3 are stable in frozen representative plant
matrices for at least 25 months (DP# 269668, L. Cheng, 11/28/01).

860.1400 Water, Fish, and Irrigated Crops

This guideline requirement is not relevant to the current petitions as
there are no aquatic uses being proposed for pyraclostrobin.

860.1460 Food Handling

This guideline requirement is not relevant to the current petitions as
there are no food-handling uses being proposed for pyraclostrobin.

860.1480 Meat, Milk, Poultry, and Eggs

Livestock dietary burdens

No new livestock feeding studies were submitted with these petitions.
The potential for transfer of pyraclostrobin residues of concern to
meat, milk, poultry, and eggs exists because there are several livestock
feedstuffs (sorghum forage, sorghum grain, and sorghum forage) that are
associated with the proposed use in the current petition (PP#8F7385). 
The livestock dietary burdens of pyraclostrobin are presented in Table
6, and reflect the most recent guidance from HED concerning revisions of
feedstuff percentages in OPPTS 860.1000 Table 1 and construction of
reasonably balanced livestock diets (RBLDs).  The new livestock
feedstuffs included in the current petition are sorghum grain, sorghum
forage, and sorghum stover. The calculated dietary burdens of
pyraclostrobin are estimated at 4.9 ppm (beef), 9.5 ppm (dairy), 0.95
ppm (poultry), and 0.55 ppm (swine).  The current dietary burdens for
cattle and poultry differ very slightly from the previous estimates
(D343754, J. Stokes, 2/12/2008).

Table 5.   Calculation of Reasonably Balanced Dietary Burdens (RBDBs) of
Pyraclostrobin Residues for  Livestock. 1

Feedstuff	Type	% Dry Matter 	% Diet 	Tolerance (ppm)	Dietary
Contribution (ppm) 

Beef Cattle R 15%, CC 80%, PC 5%

Barley, hay	R	88	10	25	2.84

Cotton, gin byproducts	R	90	5	30	1.67

Barley, grain	CC	88	20	0.4	0.091

Corn, field, grain/milled byproducts	CC	88	20	0.1	0.023

Canola/sunflower, meal	PC	92	5	0.3	0.016

Sorghum, grain, forage/silage	R	35	--	5.0	--

Sorghum, grain, grain	CC	86	40	0.6	0.27

Sorghum, grain, stover	R	88	--	0.8	--

TOTAL BURDEN	--	--	100

4.9

Dairy Cattle R 45%, CC 45%, PC 10%

Almond, hulls	R	90	5	1.6	0.09

Legume, hay (cowpea)	R	30	5	25	4.16

Barley, grain	CC	88	20	0.4	0.091

Cotton, undelinted seed	PC	90	10	0.3	0.033

Sorghum, grain, forage/silage	R	35	35	5.0	5

Sorghum, grain, grain	CC	86	25	0.6	0.15

Sorghum, grain, stover	R	88	--	0.8	--

TOTAL BURDEN	--	--	100	--	9.5

Poultry CC 75%, PC 25%

Oat, grain	CC	88	70	1.2	0.84

Canola/sunflower, meal	PC	92	25	0.3	0.075

Sorghum, grain, grain	CC	86	5	0.6	0.03

TOTAL BURDEN	--	--	100	--	0.945

Swine CC  85%, PC 15%

Barley, grain	CC	88	5	0.4	0.02

Canola/sunflower, meal	PC	92	15	0.3	0.045

Sorghum, grain, grain	CC	86	80	0.6	0.48

TOTAL BURDEN	--	--	100	--	0.545

1   All data are based on Table 1 Feedstuffs (June 2008), a revision of
feedstuffs data found in Table 1 (180.1000 OPPTS Test Guidelines). 
Residue levels for beef and dairy are corrected for moisture content and
are determined by formula: tolerance / %DM  x  % in diet.  Residue
levels for poultry and swine are considered “as-is” and are
determined by formula: tolerance  x   % in diet.  R: roughage; CC:
carbohydrate concentrate;  PC:  protein concentrate.

Typical compositions of daily rations for the animals of choice for
Table 1 data  follow: 

Feedlot beef  are fed higher amounts of CC (up to 80 %), and lower
amounts of  R (15-20 %) and PC (5-10 %) as the slaughter time (last 3
months) gets closer.  High volume milk-producing lactating dairy cows
have a daily ration of 45 % R, 40-45 % CC, and 10-15 % PC.  

A laying hen that will give a steady egg production is fed 75-80 % CC
and 20-25 % PC.   A marketable hog diet that will give steady growth
would have 80-85 % CC and 15-20 % PC.  

Livestock feeding studies: Residue Chemistry Memo, DP# 269668,
11/28/01, L. Cheng (PP#0F6139)

Adequate feeding studies were reviewed in PP#0F6139.  The current
pyraclostrobin tolerances

for livestock commodities were established based on results from these
studies and the Agency’s 

estimated dietary burdens for pyraclostrobin residues, which were
originally calculated to be 36.3

 ppm for beef cattle, 35.4 ppm for dairy cattle, and 0.35 ppm for
poultry.  The more recent dietary 

burden for pyraclostrobin residues are estimated at 4.9 ppm (beef ), 9.5
ppm (dairy), 0.95 ppm 

(poultry), and 0.55 ppm (swine).  In the poultry feeding study, l  SEQ
CHAPTER \h \r 1 aying hens were orally dosed once 

daily for 30 consecutive days with pyraclostrobin at dose levels
equivalent to 0.28 ppm (0.3x), 

0.88 ppm (0.9x), and 3.01 ppm (3.0x).  At the highest feeding level of
3.01 ppm, residues of 

pyraclostrobin and its metabolites hydrolyzable to BF 500-5 were less
than the method LOQ 

(0.05 ppm) in all egg and tissue samples, except for one egg sample (Day
17) where residues of

 pyraclostrobin were detected at 0.064 ppm and <0.05 ppm upon
re-analysis.  Residue analysis of 

BF 500-8 was not conducted (the metabolism data show all metabolites
hydrolyzable to BF 500-

8 would be less than 10% TRR), but instead an isomeric compound (BF
500-9) was measured.

Levels of BF 500-9 also were all <0.05 ppm.

Conclusions:  Based on these dietary exposure levels and the residue
data from the ruminant feeding study, the existing pyraclostrobin
tolerances for milk (0.1 ppm), meat (0.1 ppm), fat (0.1 ppm), meat
byproducts except liver (0.2 ppm), and liver (1.5 ppm) of cattle, goats,
hogs, horses, and sheep are adequate to support the proposed uses. 
Tolerances for eggs and poultry are not needed based on data from the
poultry feeding and metabolism studies [Category 180.6(a)(3)].  If, in
the future, the petitioner proposes a use which increases the dietary
burdens of poultry, then the Category 3 situation will be re-evaluated.

	

860.1500 Crop Field Trials

BASF has submitted grain sorghum field trials supporting a new use of
pyraclostrobin (EC) and seed treatment on grain sorghum, along with an
increased tolerance petition on stone fruits.  In addition, BASF has
submitted coffee field trials plus a processing study on coffee to
support a tolerance on imported coffee.    SEQ CHAPTER \h \r 1 The
results from these studies are summarized and discussed below.

Field Trial Data Submitted Under 8F7390

DER Reference List	47470201.der.doc

Adequate field trial data are available supporting the use of
pyraclostrobin on cherries (sweet and sour), peaches, and plums.  A
total of eighteen field trials were conducted in the United States and
Canada during the 2007 growing season in EPA Regions 1, 2, 5, 6, 10 and
11.  Seven trials were conducted on cherries (sweet and sour) grown in
MI (2), CA (3), WA (1), and ON (1), six trials were conducted on peaches
grown in  NY (1), GA (2), MI (1),  OK (1), and CA (1), and five trials
were conducted on  plums grown in CA (4) and MI (1).  At each field
trial location, an untreated plot and a treated plot were established. 
The treated plots received five foliar applications of a WG formulation
of boscalid (BAS 510 F) and pyraclostrobin (BAS 500 F) at 258 g ai/ha
(0.230 lb ai/A) and 131 g ai/ha (0.117 lb ai/A), respectively. (Only the
residue data from treatments with pyraclostrobin are reported in this
Data Evaluation Record).  All applications were made as foliar sprays
using commercial ground equipment or equipment which simulated
commercial applications.  The target application timing was 28, 21, 14,
7, and 0 days before harvest.  The applications were made between crop
growth stages BBCH 85 and 89, using 1.02 kg of product/ha (0.91 lb of
product/A) in spray volumes targeting 187 L/ha (19.99 gal/A).  Samples
of cherries, peaches, and plums were harvested 0 days after last
application (DALA) as well as 1-DALA.  At three sites, additional
samples were harvested 5 and 10 days after treatment to generate residue
decline data.   An adjuvant was not added to the spray mixture for all
applications.  The storage interval of treated samples from harvest to
analysis was 259 days (8.6 months). Storage stability data are supported
by a previous study.

The residues of pyraclostrobin and its N-desmethoxy metabolite (BF
500-3) were quantitated by HPLC/MS/MS according to BASF Method No.
D9908.  The LOQ was 0.02 mg/kg each for pyraclostrobin and BF 500-3.  
Acceptable concurrent method validation data were obtained.  Samples
were fortified with pyraclostrobin and its metabolite at 0.02 mg/kg and
50 mg/kg with average recoveries of 89%, 89%, 103%, and 104% in sweet
cherries, sour cherries, peaches and plums, respectively.  For BF 500-3,
the average procedural recoveries were 78%, 85%, 95%, and 111% in sweet
cherries, sour cherries, peaches, and plums, respectively. Recoveries
were within the acceptable range (70-120%). 

A summary of residue data from the stone fruit field trials is presented
in Table 7.  The results from these trials indicate that following five
applications of the 2.0 lb/gal EC formulation of pyraclostrobin
reflecting a PHI of 0-days, combined residues (BAS 500 F and BF-500-3,
in parent equivalents) ranged from 0.04 - 1.88 mg/kg in sweet cherries,
0.52 - 1.33 mg/kg in sour cherries, 0.31 - 1.75 mg/kg in peaches, and
0.04 - 0.45 mg/kg in plums.  At 1-DALA, total pyaclostrobin residues
ranged from 0.04 - 1.38 mg/kg in sweet cherries, 0.44 - 1.17 mg/kg in
sour cherries, 0.24 - 1.90 mg/kg in peaches, and 0.04 - 0.36 mg/kg in
plums.  The average combined residues were 0.764 in sweet cherries,
0.955 in sour cherries, 0.602 in peaches, and 0.198 in plums.  Residue
decline data show that residues of pyraclostrobin decrease in sweet
cherries, sour cherries, peaches, and plums with increasing pre-harvest
intervals.

TABLE 7.  Summary of Residues from the Crop Field Trials with
Pyraclostrobin.       

Crop Matrix

 	Total Applic. Rate

(lb ai/A)

 	PHI (days)

 	Residues (mg/kg)



	Mean	Std. Dev.	HAFT	Min.	Max.

Stone Fruit  (proposed use = 0.585 lb ai/A total application rate, 0-day
PHI)       

Sweet Cherry	0.585	0	0.764	0.624	1.605	0.04	1.88

Sour Cherry	0.585	0	0.955	0.320	1.165	0.52	1.33

Peach	0.585	0	0.602	0.493	1.645	0.31	1.75

Plum	0.585	0	0.198	0.159	0.395	0.04	0.45



Conclusions: The petitioner has provided adequate residue data
reflecting the maximum proposed use pattern of pyraclostrobin in/on
stone fruits.  The combined residues of pyraclostrobin and its
metabolite BF 500-3 did not exceed the proposed tolerance level of 2.5
ppm in/on stone fruits following five applications of the 2.0 lb/gal EC
formulation of pyraclostrobin reflecting a PHI of 0-days.  The combined
residues ranged from 0.04 - 1.88 mg/kg in sweet cherries, 0.52 - 1.33
mg/kg in sour cherries, 0.31 - 1.75 mg/kg in peaches and 0.04 - 0.45
mg/kg in plums.  At 1-DALA, total pyaclostrobin residues ranged from
0.04 - 1.38 mg/kg in sweet cherries, 0.44 - 1.17 mg/kg in sour cherries,
0.24 - 1.90 mg/kg in peaches and 0.04 - 0.36 mg/kg in plums.  The
average combined residues were 0.764 in sweet cherries, 0.955 in sour
cherries, 0.602 in peaches, and 0.198 in plums.  Samples were analyzed
using an adequate analytical method, and are supported by the available
storage stability data.  The number and locations of field trials are in
accordance with OPPTS Guideline 860.1500, and the conducted field trials
reflect the maximum proposed foliar use pattern. 

The field trial data for all stone fruits (cherry, peach, and plum)
reflecting the 0.585 lb ai/A 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 an appropriate
tolerance level; see Appendix II.  The tolerance spreadsheet recommends
a tolerance of 2.5 ppm for stone fruits crop group 12.

Field Trial Data Submitted Under 8F7385

DER Reference List	47470203.der.doc

BASF Corporation (BASF) has submitted field trial data for
pyraclostrobin (BAS 500 F) on grain sorghum.  A total of twelve field
trials were conducted in the United States in Regions 2 (GA, 1 trial), 4
(AR, 1 trial), 5 (IA, IL, KS, MN, 1 trial each), 6 (OK, TX 1 trial
each), 7 (NE, 1 trial) and 8 (TX, 3 trials) during the 2006 - 2007
growing season.  At each test location, an untreated plot and a treated
plot were established.  At the trials on grain sorghum, the crops were
grown from seed treated with both triticonazole (4.2 lb/gal flowable) at
50 g ai/100 kg seed (0.005 lb ai/A) and pyraclostrobin (1.7 lb/gal
flowable) at 20 g ai/100kg seed (0.002 lb ai/A).  The sorghum plants
were later treated once foliarly with pyraclostrobin (2 lb/gal EC) at
0.19 -0.22 lb ai/A (0.22 - 0.23 kg ai/ha) targeting the growth stage 25%
flowering (BBCH code 61 -63).  The foliar applications were made in 20 -
34 gal/A of water (189 - 318 L/ha) using ground equipment. An adjuvant
was added to the spray mixture for all foliar applications except one
site (R060574). 

The residues of pyraclostrobin and its N-desmethoxy metabolite (BF
500-3) in/on grain sorghum raw agricultural commodity (RAC) samples
(forage, grain, and stover) were quantitated by LC/MS/MS using BASF
analytical method D9908 (version II).  The validated LOQ was 0.02 ppm
for each analyte, for a combined LOQ of 0.04 ppm.  The method was
adequate for data collection based on acceptable concurrent method
recoveries. 

A summary of residue data from sorghum field trials is presented in
Table 8.  The results from these trials indicate that after a single
broadcast foliar application of pyaclostrobin at ~ 0.2 lb ai/A to
sorghum grown from seed treated with pyraclostrobin at 20 g ai/100 kg
seed (0.002 lb ai/A), combined residues of pyraclostrobin (BAS 500 F and
BF-500-3) ranged from <0.04 - 1.96,  <0.04 - 0.47, and <0.04 - 0.85 ppm,
in/on sorghum forage, grain, and stover, respectively, each harvested at
commercial maturity.  The storage interval from collection to extraction
ranged from 109 - 247 days (3.6 - 8.1 months) for sorghum RAC samples. 
Adequate storage stability data are available to support the storage
interval.

TABLE 8.  Summary of Residues from the Crop Field Trials with
Pyraclostrobin.       

Crop Matrix

 	Total Applic. Rate

(lb ai/A)

 	PHI (days)

 	Residues (ppm)



	Mean	Std. Dev.	HAFT 	Min.	Max.

Sorghum Grain (proposed use = 0.20 lb ai/A total application rate,
13-122-day PHI)       

Sorghum forage	0.20	13-43	0.61	0.52	1.72	<0.04	1.96

Sorghum grain	0.20	46-122	0.09	0.11	0.41	<0.04	0.47

Sorghum stover	0.20	46-122	0.17	0.21	0.75	<0.04	0.85



Conclusions: The petitioner has provided adequate residue data
reflecting the maximum proposed use pattern of pyraclostrobin (seed
treatment and foliar) in/on sorghum.  The combined residues of
pyraclostrobin and its metabolite BF 500-3 did not exceed the proposed
tolerance level of 5.0 ppm and 0.5 ppm in sorghum forage and grain,
respectively; however, in sorghum stover, the combined residue value was
slightly higher (0.85) than the proposed value of 0.80 ppm.  The
combined residues ranged from <0.04 - 1.96, <0.04 - 0.47, and <0.04 -
0.85 ppm, in/on sorghum forage, grain, and stover, respectively, each
harvested at commercial maturity.  Samples were analyzed using adequate
methods and are supported by the available storage stability data.  

The field trial data for grain sorghum (forage, grain, and stover)
reflecting the 0.19 - 0.22 lb ai/A 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 an appropriate
tolerance level; see Appendix II.  The tolerance spreadsheet recommends
a tolerance of 5.0 ppm for sorghum forage, 0.60 ppm for sorghum grain,
and 0.80 ppm for sorghum stover.  The tolerance spreadsheet recommends a
tolerance of 0.60 ppm for sorghum grain which is slightly higher than
the level (0.50 ppm) proposed by the petitioner.

 

Field Trial Data Submitted Under 8E7394

DER Reference List	47470204.der.doc

BASF has submitted five field trial data for pyraclostrobin on coffee,
conducted in Brazil during the 2007 growing season.  At each test
location, an untreated plot and a treated plot were established with
each plot containing mature coffee trees.  The treated plots received
two foliar broadcast applications of the EC formulation of
pyraclostrobin at 200 g ai/ha (0.178 lb ai/A) and 150 g ai/ha (0.134 lb
ai/A).  Samples of mature green coffee beans were harvested 45 days
after treatment.  At two sites, additional samples were harvested 0, 15,
30, and 60 days after treatment to generate residue decline data.  Only
one sample was collected from all the field trials.  An adjuvant was not
added to the spray mixture for all applications. 

The residues of pyraclostrobin and its N-desmethoxy metabolite (BF
500-3) in coffee samples were quantitated by HPLC/MS/MS according to
SOP-PA.0243 based on BASF method 445/0, entitled “Method for the
determination of BAS 480 F, BAS 490 F, BAS 500 F, BAS 505 F and BAS 510
F in plant matrices.” The LOQ was 0.02 mg/kg for each analyte, and the
LODs were 0.003 mg/kg for pyraclostrobin and 0.001 mg/kg for its
metabolite.  The analytical method was validated at the LOQ and 100X LOQ
for pyraclostrobin and its metabolite.  Acceptable recovery data was
obtained for each analyte.  Recoveries ranged from 84 - 114%. 

A summary of residue data from the coffee field trials is presented in
Table 9.  The results from these trials indicate that combined residues
(parent and metabolite) ranged from 0.04 to 0.15 mg/kg in/on all samples
of green coffee beans harvested 45 days following two foliar treatments
of coffee crops with EC formulation.  Combined residues ranged from 0.04
- 0.31 mg/kg in/on samples treated at the same rate and collected at
PHIs of 0, 15, 30, and 60.  Residue decline data show that
pyraclostrobin decreases in coffee beans with increasing pre-harvest
intervals.  The maximum storage interval of treated coffee samples from
harvest to analysis was 123 days (4 months).  Storage stability data
were not submitted with this study.  Adequate storage stability data are
available to support the storage interval.

TABLE 9.  Summary of Residues from the Crop Field Trials with
Pyraclostrobin.       

Crop Matrix

 	Total Applic. Rate

(lb ai/A)

 	PHI (days)

 	Residues (ppm)



	Mean	Std. Dev.	HAFT1	Min.	Max.

Coffee (total application rate-not specified, 45-day PHI)       

Coffee	0.312	45	0.064	0.048	--	0.04	0.15

1 = Only one sample collected per field trial.

Conclusions:  The petitioner has provided adequate residue data
reflecting the maximum proposed use pattern of pyraclostrobin in/on
coffee bean.  The combined residues of pyraclostrobin and its metabolite
BF 500-3 did not exceed the proposed tolerance level of 0.5 ppm
harvested 44-DALA, following two foliar applications of an EC
formulation at ~0.178 lb ai/A/application and 0.134 lb ai/A for a total
seasonal application rate of ~0.312 lb ai/A.  The combined residues were
0.04 - 0.15 mg/kg.  Samples were analyzed using adequate methods and are
supported by the available storage stability data.  

The field trial data for coffee reflecting 0.312 lb ai/A 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 an appropriate tolerance level; see Appendix II.  The
tolerance spreadsheet recommends a tolerance of 0.30 ppm for coffee,
which is slightly lower than the level (0.5 ppm) proposed by the
petitioner.

860.1520 Processed Food and Feed

DER Reference	47470202.der.doc

In conjunction with the coffee field trials,   SEQ CHAPTER \h \r 1 BASF
Corporation (BASF) has submitted a processing study for pyraclostrobin
on coffee.  Two field trials were conducted in Costa Rica during the
2007 growing season.  The treated plots received two broadcast foliar
applications of the EC at 0.82 - 0.89 lb ai/A (918 - 996 g ai/ha) (~5X
the proposed rate) and 0.68 lb ai/A (758 - 760 g ai/ha) (~5X the
proposed rate) for a total rate of 1.50 - 1.57 lb ai/A (1.678 - 1.754 kg
ai/ha/season).  There was a 61-day retreatment interval between the
applications, which were made 105 and 44 days before harvest.  The
applications were made in 27 - 30 gal/A of water (459 - 507 L/ha) using
ground equipment, with an adjuvant.  Single control and duplicate
treated samples of mature coffee were harvested 44 days after the last
application.  Green coffee beans were processed to cleaned green bean,
roasted bean, coffee extract, dried spent grounds, liquor extract and
freeze-dried instant coffee using simulated commercial procedures. 
Storage stability data are not required since the samples were stored
less than 30 days from collection to analysis.  However, adequate
storage stability data are available to support storage conditions and
durations of samples. 

The coffee RAC (green bean) and processed commodity samples were
analyzed for residues of pyraclostrobin and its N-desmethoxy metabolite
(BF 500-3) using an LC/MS/MS method D9908, Version II.  Acceptable
concurrent method validation data were obtained.  The LOD and LOQ of
residues of pyraclostrobin and its metabolite (BF 500-3) in/on coffee
RAC and processed commodity samples were 0.005 and 0.02 ppm,
respectively, for each analyte.  The results from the processing study
on coffee indicated that combined residues of pyraclostrobin and its
metabolite BF 500-3 in four green bean RAC samples were 0.05 - 0.12 ppm.
 Combined residues in cleaned green bean samples were 0.05 - 0.11 ppm. 
Combined residues were non-quantifiable in all other coffee processed
fractions with the exception of two treated dried spent grounds samples
from one of the trials (RCN R070040) that contained combined residues at
0.04 ppm.  

A summary of residue data from the coffee processing study is presented
in Table 10.  A comparison of the residues in the RAC with those in each
processed fraction indicated that residues of pyraclostrobin do not
concentrate in coffee processed fractions.  

 

TABLE 10.   Residue Data from Coffee Processing Study with
Pyraclostrobin.

RAC; Trial ID	Processed Commodity	Total Rate

(lb ai/A) 	PHI 

(days)	Combined Residues of Pyraclostrobin and its BF 500-3 Metabolite
(ppm)	Processing Factor





Pyraclostrobin	BF-500-3	Combined

	Green beans (RAC); RCN R070040	Green beans (RAC)	1.57	44	0.0984; 0.0997
<0.0259; 0.0237	<0.12; <0.12 	N/A; N/A

	Cleaned green bean

	0.0881; 0.0868	<0.02; <0.02	<0.11; <0.11	0.9; 0.9 

	Roasted beans

	<0.02; <0.02	<0.02; <0.02	<0.04; <0.04	0.2; 0.2 

Green beans (RAC); RCN R070040	Dried spent grounds

	<0.02; <0.02	0.0238; 0.0204	<0.04; <0.04	0.2; 0.2 

	Liquor extract

	<0.02; <0.02	<0.02; <0.02	<0.04; <0.04 	0.2; 0.2 

	Instant coffee

	<0.02; <0.02	<0.02; <0.02	<0.04; <0.04	0.2; 0.2 

Green beans

(RAC); RCN R070041  	Green beans (RAC)	1.50	44	0.0333; 0.0368
<0.02<0.02;	<0.05; <0.06	N/A; N/A 

	Cleaned green bean

	0.0350; 0.0343	<0.02<0.02;	<0.06; <0.05	1.1X; 0.9 

	Roasted beans

	<0.02; <0.02	<0.02<0.02;	<0.04; <0.04 	0.6; 0.5

Green beans (RAC); RCN R070041	Dried spent grounds

	<0.02; <0.02	<0.02<0.02;	<0.04; <0.04 	0.6; 0.5 

	Liquor extract

	<0.02; <0.02	<0.02<0.02;	<0.04; <0.04 	0.6; 0.5 

	Instant coffee

	<0.02; <0.02	<0.02<0.02;	<0.04; <0.04 	0.6; 0.5 



Conclusions.  The coffee processing study is adequate.  Residues of
pyraclostrobin were detected in the green bean RAC and cleaned green
bean from a field trial treated at an exaggerated 5x rate. Combined
residues were non-quantifiable in all other coffee processed fractions,
with the exception of two treated dried spent grounds samples from one
of the trials (RCN R070040) that contained combined residues at 0.04
ppm.  The data indicate that residues of pyraclostrobin and its
metabolite do not concentrate in cleaned green bean, coffee roasted
beans, dried spent grounds, liquor extract, and instant coffee samples. 


Plums/Prunes

Residue Chemistry Memo, DP# 269668, 11/28/01, L. Cheng (PP#0F6139)

Field trial data was submitted (PP#0F6139) depicting the potential for
concentration of residues of pyraclostrobin in prunes, the only
processed commodity of plums.  The submitted plum processing data were
adequate.  The data indicate that the combined residues of
pyraclostrobin and its metabolite BF 500-3 concentrated slightly in
prunes at 1.2x and 1.3x.

Conclusions.  The HAFT residue of plums treated at 1x the maximum
seasonal rate (0.6 lb ai/A/season; 0-day PHI) from the submitted plum
field trial studies was 0.19 ppm  for pyraclostrobin and <0.02 ppm for
BF 500-3 (<0.21 ppm combined residues).  Based on the HAFT (<0.21 ppm)
and an average concentration factor of 1.3x, the maximum expected
pyraclostrobin and BF 500-3 residues in prunes would be 0.273 ppm, which
is lower than the proposed RAC tolerance of 2.5 ppm for the stone fruits
crop group.  Based on these data, a tolerance for pyraclostrobin
residues in prunes is not warranted.

860.1650 Submittal of Analytical Reference Standards

Analytical standards for pyraclostrobin and its regulated metabolites
(BF 500-3) are currently available in the EPA National Pesticide
Standards Repository (e-mail correspondence with T. Cole, 2/17/09).  

860.1850 Confined Accumulation in Rotational Crops

HED Metabolism Assessment Review Committee Decision Memo, DP# 278044,
10/9/01, L. Cheng

Residue Chemistry Memo, DP# 269668, 11/28/01, L. Cheng (PP#0F6139)

An adequate confined rotational crop study was reviewed in PP#0F6139. 
The study showed that the metabolism of pyraclostrobin in rotated crops
is similar but more extensive than that in primary crops. 
Pyraclostrobin undergoes demethoxylation to yield BF 500-3, followed by
further degradation to medium polar and polar metabolites, and
subsequent conjugation reactions and incorporation into natural
products.  The HED MARC has determined that the residues of concern in
rotational crops consist of pyraclostrobin and metabolite BF 500-3.

860.1900 Field Accumulation in Rotational Crops

Residue Chemistry Memo, DP# 269668, 11/28/01, L. Cheng (PP#0F6139)

A limited field rotational crop study was reviewed in PP#0F6139.  The
results indicate that r  SEQ CHAPTER \h \r 1 esidues of pyraclostrobin
and its metabolite BF 500-3 were each less than the method LOQ (<0.02
ppm) in/on rotational crop matrices (radish, roots and tops; cabbage,
with and without wrapper leaves; and wheat forage, hay, and grain)
planted 14 days following the last of six sequential foliar applications
to the primary crop, cucumbers, of the 2 lb/gal EC formulation at 0.19 -
0.20 lb ai/A/application.  Residues of pyraclostrobin in/on one sample
of wheat straw from the CA test site were at the LOQ (0.02 ppm), but
residues of pyraclostrobin in/on a replicate sample from the same plot
were below the LOQ (0.012 ppm) for an average residue of <0.02 ppm. 
Residues of metabolite BF 500-3 were nondetectable (<0.02 ppm) in/on all
samples of wheat straw.

The registered pyraclostrobin end-use product labels presently specify a
14-day plantback interval restriction for all crops that are not
registered.  

860.1550 Proposed Tolerances

The HED Metabolism Assessment Review Committee (MARC memo of 10/9/01,
DP# 278044, L. Cheng) has determined that for purposes of tolerance and
dietary risk assessments, the residues of concern in plant and
rotational crop commodities include pyraclostrobin and its desmethoxy
metabolite, BF 500-3.  The residues of concern in livestock commodities
include pyraclostrobin and its metabolites convertible to
1-(4-chlorophenyl)-1H-pyrazol-3-ol (BF 500-5) and
1-(4-chloro-2-hydroxyphenyl)-1H-pyrazol-3-ol (BF 500-8).

  SEQ CHAPTER \h \r 1 Pyraclostrobin tolerances for plant commodities
are listed in 40 CFR §180.582 (a)(1) and are expressed in terms of the
combined residues of the fungicide pyraclostrobin (carbamic acid,
[2-[[[1-(4-chlorophenyl)-1H- pyrazol-3-yl]oxy]methyl]phenyl]methoxy-,
methyl ester) and its desmethoxy metabolite (methyl
N-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl carbamate),
expressed as parent compound.

Pyraclostrobin tolerances for livestock commodities are listed in 40 CFR
§180.582 (a)(2) and are expressed in terms of the combined residues of
the fungicide pyraclostrobin and its metabolites convertible to
1-(4-chlorophenyl)-1H-pyrazol-3-ol and
1-(4-chloro-2-hydroxyphenyl)-1H-pyrazol-3-ol, expressed as parent
compound.

For petition (PP#8F7385), BASF has proposed a tolerance for the combined
residues of pyraclostrobin and its desmethoxy metabolite in/on sorghum
forage, grain, and stover at 5.0 ppm, 0.5 ppm, and 0.8 ppm,
respectively.  The submitted field trial data for sorghum forage, grain,
and stover are adequate.  The field trial data for these crops 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.  The
tolerance spreadsheet recommends tolerances of 5.0 ppm for sorghum
forage, 0.60 ppm for sorghum grain, and 0.80 ppm for sorghum stover. 

For petition (PP#8F7390), BASF has proposed a tolerance for the combined
residues of pyraclostrobin and its desmethoxy metabolite in/on stone
fruit crop group at 2.5 ppm.  The submitted field trial data for stone
fruits are acceptable.  The field trial data for stone fruits 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.  The
tolerance spreadsheet recommends a tolerance of 2.5 ppm for stone
fruits.  

For petition (PP#8F7394), BASF has proposed a tolerance for the combined
residues of pyraclostrobin and its desmethoxy metabolite in/on coffee
green bean at 0.5 ppm.  The submitted field trial data for coffee is
adequate.  The field trial data for coffee 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.  The tolerance
spreadsheet recommends tolerances of 0.30 ppm for coffee. 

An acceptable coffee processing study has been submitted and the results
suggest that no tolerances are required for the processed commodities of
coffee.  

There are no Codex MRLs for pyraclostrobin for the crop commodities
discussed in this document. 

A summary of the recommended tolerances for the crop commodities
discussed in this document is presented in Table 11.  

The current EPA established tolerance for total residues of
pyraclostrobin in the stone fruit crop group is 0.9 ppm in 40 CFR
§180.582. 

 

TABLE 11.	Tolerance Summary for Pyraclostrobin.

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

Tolerances Proposed Under PP#8F7385

Sorghum grain, forage	5.0	5.0	Sorghum, grain, forage.

Sorghum, grain, grain.

Sorghum, grain, stover.

Adequate field trial data are available.

Sorghum grain, grain	0.5	0.60

	Sorghum grain, stover	0.8	0.80

	Tolerances Proposed Under PP#8F7390

Fruit, stone, group 12	2.5	6.0	Fruit, stone group 12. Adequate field
trial data are available.

Tolerances Proposed Under PP#8E7394

Coffee	0.5	0.30	Coffee, green bean. Adequate field trial data are
available.



References

DP#s:	269668, 272771, 272789, 274095, 274192, 274471, 274957, 275843,
and 278429

Subject:	PP#0F06139.  Pyraclostrobin on Various Crops:  Bananas
(import), Barley, Berries, Bulb Vegetables, Citrus Fruits, Cucurbit
Vegetables, Dried Shelled Pea & Bean (except Soybean), Fruiting
Vegetables, Grapes, Grass, Peanut, Pistachio, Root Vegetables (except
Sugar Beet), Rye, Snap Beans, Stone Fruits, Strawberry, Sugar Beet, Tree
Nuts, Tuberous and Corm Vegetables, and Wheat.  Review of Analytical
Methods and Residue Data.  EPA File Symbols:  

From:	L. Cheng

To:	C. Giles-Parker/J. Bazuin

Dated:	11/28/01

MRIDs:	45118428-451184-37, 45118501-45118512, 45118514-45118537,
45118601-45118625, 45160501, 45272801, 45274901, 45321101, 45367501,
45399401, and 45429901

DP#:	278044

Subject:	PP# 0F06139.  PC Code 099100.  Pyraclostrobin.  Outcome of the
HED Metabolism Assessment Review Committee (MARC) Meeting Held on
September 20, 2001.

From:	L. Cheng

To:	Y. Donovan

Dated:	10/09/01

MRIDs:	None

DP#:	269850

Subject:	PP# 0F06139.  Pyraclostrobin (BAS 500F) in or on Various Crops.
Request for Tolerance Method Validation (TMV) Trial.

From:	L. Cheng

To:	F. D. Griffith, Jr.

Dated:	11/8/00

MRIDs:	45118505, 45118504, 45118509, 45118510, 45118501, 45118503,
45118507, 45118514

  SEQ CHAPTER \h \r 1 Attachments:  

Appendix I - International Residue Limit Status sheet

Appendix II - Tolerance Assessment Calculations

Template Version November 2003

Appendix I – International Residue Limits

INTERNATIONAL RESIDUE LIMIT STATUS

Chemical Name:  methyl
[2-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl]methoxy
carbamate	Common Name:

Pyraclostrobin	(   Proposed tolerances

(  Reevaluated tolerance

(  Other	Date: 03/19/2009

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 Numbers:  PP#8F7385, PP#8F7390, PP#8E7394

DP#359194

Other Identifier: 

Residue definition (step 8/CXL):  pyraclostrobin	Reviewers/Branch: M.
Negussie, T. Morton, L. Cheng

	Residue definition in PP#8F7385, PP#8F7390, and PP#8E7394:  Combined
residues of pyraclostrobin and BF 500-3, expressed as pyraclostrobin.



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



PP#8F7385



   Sorghum, grain,  forage	5.0



Sorghum, grain, grain	0.6



Sorghum,  grain, stover	0.8



PP#8F7390

	Stone Fruits	1.	Fruits, Stone,  group 12 	2.5







PP#8F7394	 

Coffee beans	0.3	   Coffee, bean, green 	0.3











Limits for Canada	Limits for Mexico

(No Limits

(No Limits for the crops requested	xNo Limits

(No Limits for the crops requested

Residue definition:

plant: methyl
[2-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl]methoxycarbam
ate, including the metabolite [2-[[[1(4-chlorophenyl)-1H-pyrazol
-3-yl]oxy]methyl]phenyl]carbamate

livestock: methyl
[2-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl]methoxycarbam
ate, including the metabolites

convertible to 1-(4-chlorophenyl)-1H-pyrazol-3-ol and
1-(4-chloro-2-hydroxyphenyl)-1H-pyrazol-3-ol

	Residue definition: N/A

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

Apricot	0.7



Nectarines	0.7



Peaches	0.7



Plumcots	0.7



Plums	0.7



Prune plums	0.7



Sweet cherries	0.7



Tart cherries	0.7



S.Funk, 03/31/2009.



Appendix I – International Residue Limits

Appendix I.  Tolerance Assessment Calculations

hat were small (≤15 samples) and reasonably lognormal, the upper bound
estimate of the 95th percentile based on the median residue value was
compared to the minimum of the 95% UCL on the 95th percentile and the
point estimate of the 99th percentile, and the minimum value was
selected as the tolerance value.  For datasets that were not lognormal,
the upper bound on the 89th percentile was selected as the tolerance
value (distribution-free method).  The rounding procedures specified in
the SOP were also used.  For Coffee field trial data ~60% (3 of 5
samples), plum ~20% (2 of 10 samples), and sorghum grain field trial
data ~46% (11 of 24 samples) were below LOQ.  Maximum likelihood
estimation (MLE) procedures were needed to impute censored values.  The
residue data for coffee, plum, and sorghum grain were first entered into
the MLE spreadsheet to obtain the censored values and the
pyraclostrobin-coffee, plum, and sorghum grain dataset was then entered
into the tolerance spreadsheet. 

The dataset used to establish tolerances for pyraclostrobin residues
in/on coffee reflect two broadcast foliar applications totaling 0.312 lb
ai/A and a PHI of 45 day (Table II-1).  The dataset used for cherry
(sweet & sour), peach, and plum reflect five foliar applications
totaling 0.585 lb ai/A and a PHI of 0 days (Table II-2-4), respectively.
 The dataset used for sorghum forage, grain, and stover reflect seed
treatment at 0.002 lb ai/A and one broadcast foliar application totaling
0.19-0.22 lb ai/A (Table II-5-7), respectively.  As specified by the
Guidance for Setting Pesticide Tolerances Based on Field Trial Data, the
field trial application rates were within 25% of each other, and the
PHIs are consistent with the proposed label.

The values for combined pyraclostrobin residues were used to calculate
the appropriate tolerances for cherry (sweet & sour) (Table II-2), peach
(Table II-3), sorghum-forage (Table II-5), and sorghum-stover (Table
II-7).  MLE spreadsheet was used to obtain the censored values for
coffee (Table II-1), plum (Table II-4), and sorghum-grain (Table II-6). 
The residue datasets for each commodity were entered into the tolerance
spreadsheet and visual inspection of the lognormal probability plots for
coffee, plum, sorghum forage and sorghum grain (Figures II-1, 7, 9 and
11) indicate that the data sets are reasonably lognormal; however, the
data sets for cherry (sweet & sour), peach and sorghum stover (Figures
II-3, 5 and 13) do not appear to be lognormal.  The results from the
Shapiro-Francia test statistic (Figures II-2, 8,10 and 12) indicate that
the assumption of lognormality is correct for coffee, plum, sorghum
forage and sorghum grain; however, the assumption of lognormality is not
correct for cherry (sweet & sour), peach and sorghum stover (Figures
II-4, 6 and 14).

The tolerance spreadsheet calculates and recommends 0.30 ppm for Coffee,
2.5 ppm for stone fruits, 5.0 ppm for sorghum forage, 0.60 ppm for
sorghum grain, and 0.80 ppm for sorghum stover. (Figures II-2, 4, 10, 12
and 14), respectively.  

Table II-1:  Residue Data Used to Calculate Tolerance of Pyraclostrobin
in/on Coffee.

Regulator:	EPA

Chemical:	Pyraclostrobin

Crop:	Coffee

PHI:	45 days

Application Rate:	0.312 lb ai/A/season

Submitter:	BASF

MRID Citation:	MRID 47470204

	Combined Residues/MLE

	0.012

	0.020

	0.05

	0.15

	0.029



Figure II-  SEQ Figure_II \* ARABIC  1 :  Lognormal Probability Plot of
Pyraclostrobin on Coffee.

Figure II-2:  Data Summary for Residues of Pyraclostrobin in/on Coffee.

 

Table II-2:  Residue Data Used to Calculate Tolerance of Pyraclostrobin
in/on Cherry (Sweet and Sour).

Regulator:	EPA

Chemical:	Pyraclostrobin

Crop:	Sweet Cherry

PHI:	0 days

Application Rate:	5 x 0.117 lb ai/A/application

Submitter:	BASF

MRID Citation:	MRID 47470201

	Combined Residues

	0.890

	0.870

	1.360

	1.850

	0.05

	0.04

	0.6

	0.45

	1.00

	1.33

	0.52

	0.65

	1.25

	0.98



Figure II-3:  Lognormal Probability Plot of Pyraclostrobin on Cherry
(sweet & sour). 

Figure II-4. Data Summary for Residues of Pyraclostrobin on Cherry
(sweet &sour).

 

Table II-3:  Residue Data Used to Calculate Tolerance of Pyraclostrobin
in/on Peach. 

Regulator:	EPA

Chemical:	Pyraclostrobin

Crop:	Peach

PHI:	0 days

Application Rate:	5 x 0.117 lb ai/A/application

Submitter:	BASF

MRID Citation:	MRID 47470201

	Combined Residues

	1.54

	1.75

	0.51

	0.51

	0.31

	0.35

	0.4

	0.4

	0.4

	0.32

	0.38

	0.35



Figure II-5:  Lognormal Probability Plot of Pyraclostrobin on Peach. 

Figure II-6. Data Summary for Residues of Pyraclostrobin on Peach.

 

Table II-4:  Residue Data Used to Calculate Tolerance of Pyraclostrobin
in/on Plum. 

Regulator:	EPA

Chemical:	Pyraclostrobin

Crop:	Plum

PHI:	0 days

Application Rate:	5 x 0.117 lb ai/A/application

Submitter:	BASF

MRID Citation:	MRID 47470201

	Combined Residues/MLE

	0.14

	0.08

	0.35

	0.44

	0.014

	0.026

	0.08

	0.09

	0.36

	0.36



Figure II-7:  Lognormal Probability Plot of Pyraclostrobin on Plum. 

Figure II-8. Data Summary for Residues of Pyraclostrobin on Plum.

 

Table II-5:  Residue Data Used to Calculate Tolerance of Pyraclostrobin
in/on Sorghum Forage.

Regulator:	EPA

Chemical:	Pyraclostrobin

Crop:	Sorghum-Forage

PHI:	Applied no later than 25% flowering

Application Rate:	0.19-0.22 lb ai/A/application

Submitter:	BASF

MRID Citation:	MRID 47470203

	Combined Residues

	0.69

	0.65

	0.2

	0.14

	0.44

	0.26

	1.42

	1.26

	0.85

	1.31

	0.23

	0.17

	0.52

	0.59

	0.47

	0.37

	0.04

	0.04

	0.49

	0.49

	1.96

	1.49

	0.12

	0.57



Figure II-9:  Lognormal Probability Plot of Pyraclostrobin on
Sorghum-Forage

Figure II-10. Data Summary for Residues of Pyraclostrobin in/on
Sorghum-Forage.

 

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Figure II-11.  Lognormal probability plot of Pyraclostrobin for
Sorghum-Grain

Figure II-12. Data Summary for Residues of Pyraclostrobin in/on
Sorghum-Grain.

 

Table II-7: Residue Data Used to Calculate Tolerance of Pyraclostrobin
in/on Sorghum Stover.

Regulator:	EPA

Chemical:	Pyraclostrobin

Crop:	Sorghum-stover

PHI:	Applied no later than 25% flowering

Application Rate:	0.19-0.22 lb ai/A/application

Submitter:	BASF

MRID Citation:	MRID 47470203

	Combined Residues

	0.21

	0.13

	0.05

	0.06

	0.09

	0.04

	0.17

	0.08

	0.66

	0.85

	0.15

	0.1

	0.15

	0.1

	0.04

	0.04

	0.1

	0.11

	0.14

	0.11

	0.55

	0.11

	0.08

	0.09



Figure II-13.  Lognormal probability plot of Pyraclostrobin for
Sorghum-Stover

Figure II-14. Data Summary for Residues of Pyraclostrobin in/on
Sorghum-Stover.

 

Pyraclostrobin	Summary of Analytical Chemistry and Residue Data	DP#: 
359194

	Page   PAGE  1  of   NUMPAGES  39 		

