UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

	OFFICE OF PREVENTION, PESTICIDE

	AND TOXIC SUBSTANCES

  SEQ CHAPTER \h \r 1 MEMORANDUM

Date:  October 14, 2009

SUBJECT:	Acetamiprid.  Request for Label Amendments for New Uses on
Clover; Small Vine Climbing Fruits, except Kiwifruit, Subgroup 13-07F
(amending grape use); Greenhouse-grown Tomatoes; and a Regional
Registration for Tea.  Summary of Analytical Chemistry and Residue Data.

PC Code:  099050	DP Barcode:  D364833, D366269

Decision No.:  408298	Registration Nos.:  8033-23,  8033-36, 8033-94

Petition No.:  9E7544	Regulatory Action:  Amended Section 3 &

                                  Regional Registration for Tea

Risk Assessment Type:  NA	Case No.:  NA

TXR No.:  NA	CAS No.:  135410-20-7

MRID Nos.:  47716901, 47716902, 

                       47716903, 47781201	40 CFR:  §180.578



FROM:		     Dennis McNeilly, Chemist

		     Risk Assessment Branch II (RAB2)

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

	

THROUGH    William Drew, Chemist	

                   		 Risk Assessment Branch II (RAB2)

	     Health Effects Division (HED) (7509P)

			and

            Christina Swartz, Chief

		Richard A. Loranger, Ph.D., Senior Scientist

            Risk Assessment Branch II (RAB2)

	            Health Effects Division (HED) (7509P)	

TO:		Barbara Madden, Team 05

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

		Registration Division (RD) (7505P)

  SEQ CHAPTER \h \r 1 This document was originally prepared under
contract by Dynamac Corporation (1901 Research Boulevard, Suite 220;
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

Acetamiprid is a selective insecticide   SEQ CHAPTER \h \r 1 intended
for use against various sucking/chewing insect pests that feed upon
field, fruit, and vegetable crops.  Acetamiprid is registered for foliar
application to cotton, leafy vegetables, cole (Brassica) vegetables,
fruiting vegetables, tuberous and corm vegetables, citrus fruits, pome
fruits, cucurbit vegetables, stone fruits, tree nuts, berries, bulb
vegetables, succulent legume vegetables and grapes, and for seed
treatment of canola and mustard seeds.

The Interregional Research Project Number 4 (IR-4) has submitted amended
Section 3 registration requests for new uses of acetamiprid on clover
grown for seed, small vine climbing fruits, except kiwifruit, subgroup
13-07F (amending established grape uses), greenhouse-grown tomatoes, and
tea.  The end-use products associated with this action include:  (i)
Assail® 30SG Insecticide (EPA Reg. No. 8033-36), a 30% active
ingredient (ai) soluble granule (SG) formulation; (ii) Assail® 70WP
Insecticide (EPA Reg. No. 8033-23), a 70% ai wettable powder (WP)
formulation; and (iii) Tristar® 30SG Insecticide (EPA Reg. No.
8033-94), a 30% ai SG formulation.  

For clover, Assail® 30SG and Assail® 70WP are proposed for a single
postemergence broadcast foliar application at a maximum of 0.075 lb ai/A
with a 28-day preharvest interval (PHI); the proposed use is limited to
clover grown in ID, OR, and WA only.  For grapes, a change to the
registered use pattern is proposed.  The current label permits up to two
foliar applications on grapes at 0.05 lb ai/A/application for a maximum
seasonal rate of 0.1 lb ai/A with a 7-day PHI.  The requested new use on
grapes (and small vine climbing fruits, except kiwifruit, subgroup
13-07F) will permit up to two foliar applications of Assail® 30SG and
Assail® 70WP at 0.1 lb ai/A/application for a seasonal rate of 0.2 lb
ai/A with a 3-day PHI.  For tomatoes, a new use on greenhouse-grown
tomatoes is proposed.  The current Assail® 30SG and Assail® 70WP
labels permit up to four foliar applications on field-grown tomatoes at
0.075 lb ai/A/application for a maximum seasonal rate of 0.3 lb ai/A
with a 7-day PHI.  The requested new use on tomatoes will add a
greenhouse use pattern using Tristar® 30SG, with a maximum of two
applications at 0.075 lb ai/A/application (based on 10,000 plants per
acre) for a maximum seasonal rate of 0.15 lb ai/A, applied via
chemigation with a 1-day PHI.  No use directions were proposed for the
domestic use on tea grown in South Carolina.  The following GAP
information was provided for the 20% SP formulation in Japan:  one
application at 0.10-0.40 kg ai/ha applied in 2000-4000 L/ha, with a
14-day PHI.  Application rate GAP information for India were not
provided; however, the residue data conducted in India were a single
application of 0.022 lb ai/A (0.025 kg ai/ha) or 0.045 lb ai/A (0.050 kg
ai/ha).  The shoots along with bud are (reportedly) typically harvested
at a 7-day PHI in India.

Concurrently, IR-4 has proposed the establishment of permanent
tolerances for residues of acetamiprid in or on the raw agricultural
commodities (RACs) listed below.  

Clover, forage	0.10 ppm

Clover, hay	0.01 ppm

Fruit, small, vine climbing, except fuzzy kiwifruit,

   subgroup 13-07F	0.35 ppm

Tea 	 50.0 ppm

Tolerances have been established under 40 CFR §180.578 (a)(1) for
residues of the insecticide acetamiprid, ranging from 0.01 to 20 ppm
in/on canola seed, cotton matrices, and various fruits, nuts, and
vegetables.  Tolerances for the combined residues of acetamiprid and
N1-[(6-chloro-3-pyridyl)methyl]-N2-cyano-acetamidine have also been
established for livestock commodities (ruminants and poultry) ranging
from 0.01 to 0.20 ppm under 40 CFR §180.578(a)(2).  Compliance with the
tolerance levels listed in 40 CFR §180.578 is to be determined by
measuring only acetamiprid for plant commodities, and acetamiprid and
its IM-2-1 metabolite for animal commodities as quantitated by the
GC/ECD and LC/MS/MS analytical enforcement methods. 

HED has previously determined that the nature of the residue in plants
and animals is adequately understood.  The residue of concern in plants
is acetamiprid for both tolerance enforcement and risk assessment
purposes.  The residues of concern in livestock commodities for
tolerance expression are acetamiprid plus its IM-2-1 metabolite.  For
the purpose of risk assessment, the residues of concern in livestock
commodities (except ruminant muscle) are acetamiprid plus its IM-2-1
metabolite.  In ruminant muscle, the residues of concern for risk
assessment are acetamiprid plus IM-2-1 plus IM-2-1-amide.

The proposed use on clover could theoretically lead to the secondary
transfer of acetamiprid residues of concern to beef and dairy cattle
from the feeding of clover forage, hay, and silage.  However, the
proposed use on clover grown for seed is restricted to clover grown in
ID, OR, and WA and the residues in or on the animal feed items are very
low.  Therefore, HED does not believe that the proposed use on clover
would significantly increase the dietary burdens, and the established
tolerances in milk, meat, and meat byproducts need not be reassessed for
the purpose of this petition.

Adequate gas chromatograph with electron capture detection (GC/ECD) and
high performance liquid chromatography with ultraviolet detection
(HPLC/UV) residue analytical methods are available for the enforcement
of established tolerances on plant commodities.  The method limits of
quantitation (LOQ) are 0.01 ppm for vegetables and non-citrus fruits
(GC/ECD), and 0.050 ppm for citrus fruits (HPLC/UV).  A secondary liquid
chromatography with tandem mass spectrometric detection (LC/MS/MS)
method, designated by the petitioner as an alternative to the
established GC/ECD tolerance enforcement method, has been determined
suitable for tolerance enforcement, and confirmatory analysis of
vegetables and non-citrus fruits.  The GC/ECD method or LC/MS/MS Method
#KP-216R1 (or its modification) was used for the analysis of samples
from the clover, grape, and tomato field trials.  Acceptable recoveries
were obtained in method validation efforts conducted prior to the
analysis of field trial samples.

In a Japanese study, dried green tea leaves and brewed tea were analyzed
for combined residues of acetamiprid and metabolites convertible to
6-chloronicotinic acid (Metabolite IC-0) using a common moiety GC/ECD
method.  Briefly, dried tea leaves were homogenized, soaked in water,
and then extracted with methanol.  Brewed tea was simply filtered.  The
resulting extracts/filtrates were partitioned with hexane, and the
aqueous layer was subjected to base hydrolysis.  Acetamiprid and
metabolites were then converted to 6-chloronicotinic acid by oxidation,
then methylated (procedure not specified) and purified by silica column
chromatography prior to GC/ECD analysis.  The reported method LOD was
0.05 ppm as acetamiprid.  In India, samples of green shoots, dried black
tea leaves, brewed tea, and spent leaves were analyzed for residues of
acetamiprid using an HPLC/UV method.  The reported LOD was also 0.05
ppm.

Adequate multiresidue methods testing data have been submitted.  These
data indicate that the multiresidue methods are not appropriate for
determining residues of acetamiprid.  

The available storage stability data for acetamiprid on representative
crops, and the concurrent storage stability data for clover and tomato
are adequate to support the submitted clover, grape, tomato, and tea
field trials.

The use pattern of the clover field trials adequately reflects the
proposed label use pattern with the exception of the PHI for hay.  The
available field trial data indicate a regional tolerances for residues
of acetamiprid in clover forage at 0.10 ppm and clover hay at 0.01 ppm,
are appropriate.  However, the submitted clover field trial data are not
completely adequate to satisfy data requirements.  The three clover
field trials were all conducted in Zone 11 (OR) at the same location and
within a very short time period of each other.  Two additional clover
field trials are required, as confirmatory data.  In addition, the
submitted residue data included field trial data for only the 70WP
formulation.  However, since the requested PHI is for 28 days (generally
bridging data are required if the proposed PHI is less than or equal to
7 days), additional residue chemistry field trial data are not required
to support registration of the 30SG formulation.  Use on clover grown
for seed is to be limited to clover grown in ID, OR, and WA.  Since the
residue chemistry data submitted for clover hay reflect PHIs of between
56-63 days, the PHI for clover should be increased to 56 days for any
crop harvested as clover hay.

The submitted grape residue data included field trial data for only the
70WP formulation (the original field trials also used a 70WP
formulation).  Since the requested PHI for grape is for 3 days,
additional residue chemistry field trial data are needed to support
registration of the 30SG formulation.  As a condition of registration,
HED requests that three side-by-side field trials be conducted and
submitted to determine if residues are comparable for the two different
formulations.  In addition, the submitted grape field trials were not
conducted using an adjuvant.  The label for Assail® 30SG (EPA Reg. No.
8033-36) should be revised to remove the use of a spreader, methylated
seed oil or crop oil from the product label, unless an adjuvant is used
in the side-by-side testing.  The number and locations of the field
trials for the 70WP formulation are in accordance with OPPTS Guideline
860.1500 for grapes, and the use pattern of the field trials reflects
the use pattern proposed for grapes (and other climbing vine small
fruits, except fuzzy kiwifruit, within subgroup 13-07F), except for the
adjuvant use.  As the representative crop of the fruit, small, vine
climbing, except fuzzy kiwifruit, subgroup 13-07F, the available grape
field trial data from the current submission, which reflect a higher
seasonal rate and a shortened PHI from that which is currently
registered, will support a tolerance for residues of acetamiprid in
“fruit, small, vine climbing, subgroup 13-07F, except fuzzy
kiwifruit” at 0.35 ppm.  The established individual tolerance for
grape at 0.20 ppm should be concomitantly removed upon establishment of
the subgroup 13-07F tolerance.

The application rate used in the submitted tomato residue data for the
proposed greenhouse use was 2x the proposed seasonal rate for the
greenhouse tomato use.  The three trials conducted are adequate with
respect to the number of trials.  Although the greenhouse trials were
conducted at a 2x application rate, no additional residue data will be
required to support the proposed greenhouse use pattern for tomatoes
provided the use is limited to the 70WP product (conditional data needed
for SG formulation).  The available tomato greenhouse trial data
indicate that the established tolerance for residues of acetamiprid in
fruiting vegetables (Crop Group 8) at 0.20 ppm will not be exceeded
following applications of the Assail 70WP formulation of acetamiprid
according to the use patterns of the tomato greenhouse trials.  No
residue data were provided for the proposed use of Tristar® 30SG on
greenhouse tomatoes, the only formulation requested for this use on
greenhouse tomatoes.  HED does have side-by-side formulation trials (WP
and soluble liquid formulation) for acetamiprid in undelinted cottonseed
and cotton gin byproducts.  These data indicate that residue levels are
comparable for the two different formulation, i.e., WP and soluble
liquid.  In view of these data and the 70WP data reflecting 2x the
seasonal rate, HED requests submission of only one side-by-side
formulation trial (rather than the normal three side-by-side trials) to
support the use of Tristar® 30SG on greenhouse tomatoes as a condition
of registration. 

The submitted magnitude of the residue data for tea reflect application
of a 20% SP formulation of acetamiprid to green tea grown in Japan at
0.13 lb ai/A (0.15 kg ai/ha) and 0.27 lb ai/A (0.30 kg ai/ha) and to
black tea grown in India at 0.022 lb ai/A (0.025 kg ai/ha) and 0.045 lb
ai/A (0.050 kg ai/ha).  Samples of tea leaves (and shoots) were
harvested at PHIs of  7, 14, and 21 days in the Japan study and 0, 1, 3,
5, 7, 9, 11, 15, and 21 days in the India study and were processed into
dried tea leaves and brewed tea; spent tea leaves were also analyzed in
the India study.  Acceptable methods were used for quantitating residues
of acetamiprid and metabolites determined as acetamiprid.  No U.S.
residue field trial data were submitted and proposed domestic use
directions were not provided.  At least one U.S. field trial study is
required to establish a tolerance for domestic use of acetamiprid on
tea.  At this time HED can recommend for a 50 ppm tolerance on tea with
no U.S. registration.

An acceptable grape processing study was previously reviewed, which
reported processing factors of 1.5x for juice and 0.9x for raisins. 
Based on these data, no tolerances are needed for juice or raisins as a
result of the proposed use, because any residues in these commodities
are expected to be less than the RAC tolerance.

An acceptable tomato processing study was also previously reviewed,
which reported processing factors of 1.4x for puree and 3.0x for paste. 
Based on the observed processing factor of 3.0x and a HAFT of 0.1 ppm, a
tolerance of 0.40 ppm was established for residues of acetamiprid in
tomato paste.  A tolerance was not needed for puree because any expected
residues in puree would be less than the RAC tolerance.  The proposed
use on greenhouse-grown tomatoes will not change the expected residues
in puree or paste.  

An acceptable confined rotational crop study is available.  HED has
determined that the residue of concern in rotational crops is parent
only, and that tolerances would not be needed on rotational crops.  The
available confined rotational crop data indicate that field rotational
crop studies and label restrictions for rotational crops are not
required to support the proposed uses.

An analytical standard for acetamiprid is currently available in the
National Pesticide Standards Repository.  However, analytical standards
for the IM-2-1 and IM-2-1-amide metabolites are not available at the
Repository.  Analytical reference standards of these metabolites should
be supplied and supplies replenished as requested by the Repository.

  

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

HED has examined the residue chemistry database for acetamiprid. 
Pending submission of revised Section B (see requirements under
Directions for Use) and analytical reference standards (see requirements
under Submittal of Reference Standards), there are no residue chemistry
issues that would preclude granting a conditional registration for the
requested uses of acetamiprid.  The data that HED recommends be required
as a condition of registration are specified below.  Provided that the
forthcoming human health risk assessment does not identify any issues of
concern, the submitted data support the establishment of permanent
tolerances for acetamiprid, including its metabolites and degradates,
under 40 CFR §180.578, as listed below.  SEQ CHAPTER \h \r 1   
Compliance with tolerance levels specified below is to be determined by
measuring acetamiprid only.

Clover, forage*	0.10 ppm

Clover, hay*	0.01 ppm

Fruit, small, vine climbing, subgroup 13-07F,

  except fuzzy kiwifruit   	0.35 ppm

Tea**	50.0 ppm

* Tolerances with regional restrictions [40 CFR §180.578(c)].

**  Tolerance without a U.S. registration.

The established individual tolerance for grape at 0.20 ppm should be
concomitantly removed upon establishment of the subgroup 13-07F
tolerance.  

No change is needed with regard to the established tolerance for
residues of acetamiprid in fruiting vegetables (Crop Group 8) at 0.20
ppm as a result of adding greenhouse use on tomatoes.

860.1200 Directions for Use

Because the grape field trial data submitted with this petition did not
reflect the use of a surfactant in the application sprays, the label
directions regarding use of a spreader, methylated seed oil or crop oil
should be removed from the product label of Assail® 30SG (EPA Reg. No.
8033-36).

The PHI for clover harvested for hay should be increased to 56 days on
the 30SG and 70WP labels.

Use directions for the domestic use of acetamiprid on tea were not
submitted.  HED cannot evaluate the data without proposed use directions
for acetamiprid use on tea in South Carolina.  GAP information was
provided for Japan and India.  The use directions are adequate to
establish a tolerance without U.S. registrations (an “import”
tolerance). 

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

Analytical standards for the IM-2-1 and IM-2-1-amide metabolites are not
available at the Repository and should be supplied.  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.)

860.1550 Proposed Tolerances

The final tolerances for subgroup 13-07F should reflect the correct
commodity definition as specified in Table 8.  A revised Section F is no
needed for this minor change.  The established individual tolerance for
grape at 0.20 ppm should be concomitantly removed with establishment of
the subgroup 13-07F tolerance.

Conditional Data Requirements

Two clover field trials reflecting the same use pattern utilized in the
submitted studies.

Three side-by-side field trials on grapes to demonstrate that residues
from the 30SG formulation are comparable to or less than those from the
70WP product.  The spray in the plots for the SG formulation should
contain adjuvant (spreader, methylated seed oil, or crop oil) if a label
statement recommending such additives is desired.

One side-by-side greenhouse trial on tomatoes to demonstrate that
residues from the SG formulation are comparable to or less than those
from the 70WP product.

Background

The nomenclature of acetamiprid and its metabolites is summarized in
Table 1, and the physicochemical properties of acetamiprid are
summarized in Table 2.

 

 

Common Name	Acetamiprid

Molecular Formula	C10H11ClN4

Molecular Weight	222.68

Company Experimental Name	EXP-61842A, AEF124370, NI-25

IUPAC Name	  SEQ CHAPTER \h \r 1 (E)-N 1-[(6-chloro-3-pyridyl)methyl]-N
2-cyano-N 1-methylacetamidine

CAS Name	  SEQ CHAPTER \h \r 1
(1E)-N-[(6-chloro-3-pyridinyl)methyl]-N'-cyano-N-methylethanimidamide

CAS Registry Number	135410-20-7

End-use Products (EPs)	Assail® 30SG (30% SG; EPA Reg. No. 8033-36)

Assail® 70WP (70% WP; EPA Reg. No. 8033-23) 

Tristar® 30SG (30% SG; EPA Reg. No. 8033-94)

Chemical Structure of Acetamiprid Metabolite 

 

  SEQ CHAPTER \h \r 1 N 1-[(6-chloro-3-pyridyl)methyl]-N
2-cyano-acetamidine

Chemical Structure of Acetamiprid Metabolite 

IM-2-1-amide 

 

  SEQ CHAPTER \h \r 1 N 2-aminocarbonyl-N
1-[(6-chloro-3-pyridyl)methyl]acetamidine



Table 2.  Physicochemical Properties of Technical-Grade Acetamiprid.

Parameter	Value	Reference

Melting Point/Range ((C)	98.9	DP# 328216, W. Drew, 10/23/2007

pH	6.08 (Aqueous solution at 20(C)

	Density (g/cm3)	1.33 (at 20(C)

	Water Solubility (g/L)	4.25 (at 25(C)

	Solvent Solubility (at 25(C)	Acetone	>20 g/100 g

Methanol	>20 g/100 g

Ethanol	>20 g/100 g

Dichloromethane	>20 g/100 g

Chloroform	>20 g/100 g

Acetonitrile	>20 g/100 g

Tetrahydrofuran	>20 g/100 g

Benzene	2.44 g/100 g

Xylene	4.01 g/100 g

n-Hexane	6.54 ppm

Carbon disulfide	507 ppm

	Vapor Pressure (mm Hg)	7.5 x 10-9 (at 25(C)	DP# 264154, M. Doherty;
12/31/2001

Dissociation Constant, pKa	0.7 (at 25(C)	DP# 328216, W. Drew, 10/23/2007

Octanol/Water Partition Coefficient, Log KOW	0.8 (at 25(C)

	UV/Visible Absorption Spectrum	Not available

	

860.1200 Directions for Use

A list of acetamiprid end-use products (EPs) relevant to this
registration action is presented below in Table 3.  All listed EPs are
registered to Nippon Soda Co., Ltd. (c/o Nisso America, Inc.).   

Table 3.    List of Acetamiprid End-Use Products Associated with
PP#9E7544.

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

Assail® 30SG Insecticide	8033-36	30% by wt	Soluble granule	3/4/2009
(draft)

Assail® 70WP Insecticide	8033-23	70% by wt	Wettable powder	3/4/2009
(draft)

Tristar® 30SG Insecticide	8033-94	30% by wt	Soluble granule	3/4/2009
(draft)



A summary of the proposed or amended use patterns is presented in Table
4.  For clover, new use is proposed for Assail® 30SG and Assail® 70WP.
 For grapes, a change to the registered use pattern is proposed.  The
current labels permit up to two foliar applications on grapes at 0.05 lb
ai/A/application for a maximum seasonal rate of 0.1 lb ai/A with a 7-day
preharvest interval (PHI).  The requested new use on grapes (and small
vine climbing fruits, except kiwifruit, subgroup 13-07F) will permit up
to two applications of Assail® 30SG or Assail® 70WP at 0.1 lb
ai/A/application for a seasonal rate of 0.2 lb ai/A with a 3-day PHI. 
For tomatoes, new use is proposed for greenhouse-grown tomatoes.  The
current Assail® 30SG and Assail® 70WP labels permit up to four foliar
applications on field-grown tomatoes at 0.075 lb ai/A/application for a
maximum seasonal rate of 0.3 lb ai/A with a 7-day PHI.  The requested
new use on tomatoes will add a greenhouse use pattern for Tristar®
30SG, with a maximum of two applications (reduced from four for
resistance management) at 0.075 lb ai/A/application (based on 10,000
plants per acre) for a maximum seasonal rate of 0.15 lb ai/A, applied
via chemigation with a 1-day PHI.  There were no rotational crop
restrictions listed on any of the acetamiprid draft labels.

Table 4.   Summary of Directions for Use of Acetamiprid.

Applic. Timing, Type, and Equip.	Trade Name

[EPA Reg. No.]	Applic. Rate 

(lb ai/A)	Max. No. Applic. per Season 1	Max. Seasonal Applic. Rate

(lb ai/A)	PHI

(days)	Use Directions and Limitations

Clover 2

Postemergence

Broadcast foliar

  spray

Ground/aerial	Assail®

30SG;

[8033-36]

Assail® 70WP

[8033-23]	0.047-0.075	1 	0.075	28	Proposed use is limited to clover
grown in ID, OR, and WA only.  Begin applications when treatment
thresholds have been reached.  Apply in minimum spray volumes of 5 GPA
by air or 20 GPA by ground.

Grapes and Other Climbing Vine Small Fruits (Except Fuzzy Kiwifruit)
(Within Crop Subgroup 13-07F):  Amur River Grape; Gooseberry; Hardy
Kiwifruit; Maypop; Schisandra Berry; and Cultivars, Varieties, and/or
Hybrids

Postemergence

Broadcast foliar

  spray

Ground/aerial	Assail®

30SG;

[8033-36]

Assail® 70WP

[8033-23]	0.047-0.1	2	0.2	3	Begin applications when treatment thresholds
have been reached.  Do not apply more than once every 14 days.  Apply in
minimum spray volumes of 5 GPA by air or 20 GPA by ground.  Assail®
30SG states that the addition of a spreader, methylated seed oil or crop
oil will enhance pest control.  

Greenhouse-Grown Tomatoes

Postemergence

Drip or micro

  irrigation	Tristar®

30SG

[8033-94]	0.075 lb ai/A of crop (based on 10,000 plants/A)	2	0.15	1	For
use in greenhouse-grown tomato production.  May be applied by injection
into drip irrigation or micro-irrigation (spaghetti tube or emitter)
systems, soil drenching, or by hand-held or motorized calibrated
irrigation equipment directed to the plant roots. Application should be
made only to mature tomato plants grown in non-soil media such as rock
wool, vermiculite, perlite, or other soil-less media.  Some cultivars
may exhibit sensitivity and therefore treatment of a few plants is
recommended prior to treating an entire greenhouse.  Begin applications
when treatment thresholds have been reached.  

1   The number of treatments allowed per season when the EP is applied
at the maximum single application rate.

2   Section G of the petition specifies that the EP is proposed for use
on red clover grown for seed.  The draft label does not specify that use
is for clover grown for seed.

TEA

No use directions were proposed for the domestic use of acetamiprid on
tea grown in South Carolina.  The following GAP information was provided
for the 20% SP formulation in Japan:  one application at 0.10-0.40 kg
ai/ha applied in 2000-4000 L/ha, with a 14-day PHI. GAP information was
also provided for India:  one application at 0.022 lb ai/A (0.025 kg
ai/ha) or 0.045 lb ai/A (0.050 kg ai/ha), shoots along with bud are
typically harvested at a 7-day PHI.

Conclusions.  The submitted labels are adequate to allow evaluation of
the residue data relative to the proposed use, except for the use on tea
in South Carolina for which directions were not proposed.  The available
field trial data reflect the proposed use patterns for all of the
submitted field trials except those submitted for grapes and clover hay.
 Because the grape field trial data submitted with this petition did not
reflect the use of a surfactant in the application sprays, the label
directions regarding use of a spreader, methylated seed oil or crop oil
should be removed from the product label of Assail® 30SG (EPA Reg. No.
8033-36).  The PHI for clover harvested for hay should be increased to
56 days on the 30SG and 70 WP labels. 

860.1300 Nature of the Residue - Plants

Residue Chemistry Memo DP#   SEQ CHAPTER \h \r 1 264154, 12/31/2001, M.
Doherty (PP#0F6082)

MARC Decision Memo, DP# 278652, 11/13/2001, M. Doherty

Plant metabolism studies with acetamiprid on apple, cabbage, carrot,
cotton, and eggplant were submitted as part of the data package for the
original acetamiprid petition (PP#0F6082), which adequately delineate
the qualitative nature of the residue in plants.  It was found that in
most plants, acetamiprid is demethylated at the N1 amine to form IM-2-1,
which may then be further metabolized to form IM-0 and IC-0.  IM-0 is
then metabolized to form the glucose conjugate IM-0-Glc.  The HED has
previously determined that the residue of concern in plants is
acetamiprid for both tolerance enforcement and risk assessment purposes.

860.1300 Nature of the Residue - Livestock

Residue Chemistry Memo DP#   SEQ CHAPTER \h \r 1 264154, 12/31/2001, M.
Doherty (PP#0F6082)

MARC Decision Memo, DP# 278652, 11/13/2001, M. Doherty

The qualitative nature of acetamiprid residues in livestock is
adequately understood.  HED has previously determined that the tolerance
expression for enforcement purposes in livestock commodities should be
acetamiprid plus its IM-2-1 metabolite.  For the purpose of risk
assessment, the residues of concern in livestock commodities (except
ruminant muscle) are acetamiprid plus its IM-2-1 metabolite.  In
ruminant muscle, the residues of concern for risk assessment are
acetamiprid plus IM-2-1 plus IM-2-1-amide.  These conclusions are based
on acceptable metabolism studies with lactating goats (1 ppm or 8.6 ppm
dosing levels administered for 7 days) and laying hens (1.1 ppm or 12.5
ppm dosing levels administered for 14 days).  Metabolism data indicate
that levels of IM-2-1-amide will not exceed 10x the level of IM-2-1 in
ruminant muscle tissue.  Acetamiprid is metabolized in goats via loss of
an amine methyl group, forming IM-2-1, which can further hydrolyzed to
form IM-2-3 and IM-2-4.  IM-2-2 can be formed as an intermediate in the
metabolism of IM-2-1 to IM-2-4.  In poultry, IM-2-2 can be converted to
IM-2-5 through loss of the acetamide group.

860.1340 Residue Analytical Methods

Residue Chemistry Memo   SEQ CHAPTER \h \r 1 DP#s 342549 & 355773,
11/05/2008, W. Drew

Residue Chemistry Memo   SEQ CHAPTER \h \r 1 DP# 328216, 10/23/2007, W.
Drew (PP#6F7051 and PP#6E7163)

Residue Chemistry Memo DP# 303623, 11/05/2004, W. Drew (PP#4F6833)

Residue Chemistry Memo DP#   SEQ CHAPTER \h \r 1 264154, 12/31/2001, M.
Doherty (PP#0F6082)

  SEQ CHAPTER \h \r 1 Enforcement methods:    SEQ CHAPTER \h \r 1
Adequate residue analytical methods (GC/ECD and HPLC/UV) are available
for the enforcement of established tolerances on plant commodities.  The
method LOQs are 0.010 ppm for vegetables and non-citrus fruits (GC/ECD),
and 0.050 ppm for citrus fruits (HPLC/UV).  These methods have undergone
successful petition method validation (PMV) trials.  Under PP#4F6833,
Nisso America proposed that the LC/MS/MS method utilized for data
collection and confirmatory analysis (Method #KP-216R0 or its
modification, Method #KP-216R1) be designated an alternative to the
established GC/ECD tolerance enforcement method.  With submission of
acceptable independent laboratory validation (ILV) data and the ability
to analyze two daughter ions specific to acetamiprid, the LC/MS/MS
method, was determined to be suitable for tolerance enforcement and
confirmatory analysis of vegetables and non-citrus fruits (DP#s 342549 &
355773).  A summary of the available methods is presented in Table 5.

 Table 5.	Summary of Validated Analytical Methods for Acetamiprid.

Target Matrices	Method Description	LOQ (ppm)	Method Validation



	Fortification Levels (ppm)	Recovery Range (%)

Vegetables and Non-Citrus Fruits	Methanol extraction, residues
partitioned into dichloromethane, Florisil/silica gel column cleanup,
and LC/MS/MS determination.	0.010	0.010, 0.020	72-80

Vegetables and Non-Citrus Fruits	Methanol extraction, residues
partitioned into dichloromethane, Florisil/silica gel column cleanup,
and GC/ECD determination.	0.010	0.010, 0.050	68-112

Citrus Fruits	Acetonitrile extraction, co-extractives partitioned into
hexane, residues partitioned into dichloromethane, Florisil/C18 column
cleanup, and HPLC/UV determination.	0.050	0.050, 0.250	77-100



Data-collection methods:  Samples from the clover and grape field trials
submitted in conjunction with the subject petition were analyzed for
residues of acetamiprid using LC/MS/MS Method #KP-216R1 or a
modification of Method #KP-216R1.  Samples from the tomato field trials
were analyzed for residues of acetamiprid using a GC/ECD working method
entitled “Residue Analysis of Acetamiprid on Tomato (greenhouse) by
GC/EC Detection”, adapted with modifications from the reference
method, “Methods for the Analysis of Acetamiprid (NI-25) in Plants and
Plant Process Fractions.”  Acceptable recoveries were obtained in
method validation conducted prior to the analysis of field trial samples
and/or concurrent method validation using clover forage, clover hay,
grapes, and tomatoes fortified with acetamiprid at levels ranging from
the lowest limit of method validation (LLMV; 0.010 ppm) and up to 1.00
ppm.  The fortification levels used in method validation and concurrent
method validation were adequate to bracket the expected residue levels
for all trials.

Tea:  In the Japan study, samples of dried green tea leaves and brewed
tea were analyzed for combined residues of acetamiprid and metabolites
convertible to 6-chloronicotinic acid (Metabolite IC-0) using a common
moiety GC/ECD method.  Briefly, dried tea leaves were homogenized,
soaked in water, and then extracted with methanol.  Brewed tea was
simply filtered.  The resulting extracts/filtrates were partitioned with
hexane, and the aqueous layer was subjected to base hydrolysis. 
Acetamiprid and metabolites were then converted to 6-chloronicotinic
acid by oxidation, then methylated (procedure not specified) and
purified by silica column chromatography prior to GC/ECD analysis.  The
reported method LOD was 0.05 ppm as acetamiprid.  

In the India study samples of green shoots, dried black tea leaves,
brewed tea, and spent leaves were analyzed for residues of acetamiprid
using an HPLC/UV method.  Briefly, green shoots, and dried and spent
leaves were extracted with acetonitrile, then filtered.  The filtrate
was concentrated and transferred to a separatory funnel containing
petroleum ether:5% NaCl solution (5:5, v:v).  Following shaking and
phase separation, the organic phase was washed twice with NaCl solution,
and the aqueous phases were combined and partitioned with
dichloromethane (DCM; 4x).  The resulting extracts were concentrated to
dryness, reconstituted in acetone:hexane (5:5, v:v), and purified by
silica-carbon column chromatography; residues were eluted with
acetone/hexane prior to HPLC/UV analysis.  Samples of brewed tea were
extracted with DCM (4x), and the organic layers were combined and
concentrated for analysis by HPLC/UV.  The reported LOD was 0.05 ppm.  

Only limited details were provided for the analytical phase for both
studies and that no raw data were included for either study.

Conclusions:   Adequate residue analytical methods (GC/ECD, HLPC/UV and
LC/MS/MS) are available for the purpose of tolerance enforcement.    SEQ
CHAPTER \h \r 1 The GC/ECD and LC/MS/MS Methods used for the analysis of
samples from the clover, grape, and tomato field trials are similar to
the enforcement methods, and were adequate as data-collection methods
based on acceptable method validation recoveries from clover forage,
clover hay, grapes, tomatoes, and tea.

860.1360 Multiresidue Methods

Residue Chemistry Memo DP#   SEQ CHAPTER \h \r 1 264154, 12/31/2001, M.
Doherty (PP#0F6082)

The petitioner submitted data concerning the recovery of residues of
acetamiprid using FDA multiresidue method protocols (PAM Volume I) in
conjunction with the original acetamiprid petition (PP#0F6082).  These
data have been forwarded to FDA for evaluation.  Based on the results of
the testing, the multiresidue methods are not appropriate for
determining acetamiprid residues of concern.  The Biological and
Economic Analysis Division (BEAD) is currently working on a
multi-residue method for the neonicotinoids.

860.1380 Storage Stability

Residue Chemistry Memo DP# 303623, 11/05/2004, W. Drew (PP#4F6833)

Residue Chemistry Memo DP#   SEQ CHAPTER \h \r 1 264154, 12/31/2001, M.
Doherty (PP#0F6082)

Storage stability data submitted with PP#6F7051 indicate that residues
of acetamiprid are relatively stable under frozen storage conditions for
up to 12 months in/on fortified samples of an oilseed (cotton seed), a
leafy vegetable (head lettuce), a Brassica leafy vegetable (cabbage), a
cucurbit vegetable (cucumber), and fruits (apple and orange), as well as
the processed commodities of apple, cotton, and orange.  In addition,
the stability of acetamiprid during short-term storage at ambient
temperatures was evaluated.  Samples of cottonseed, cotton gin
byproducts, cotton seed oil, whole grapes, grape juice, raisins, whole
oranges, whole tomatoes, and tomato paste spiked with acetamiprid at
0.100 and 0.250 ppm were stored at ambient temperatures for 7 days (15
days for raisins).  Under these conditions, residues of acetamiprid were
stable in all commodities.  

IR-4 conducted concurrent storage stability studies with the analysis of
the field trial samples in conjunction with the clover and tomato field
trials.  Although no 0-day data were provided, the data indicate that
residues of acetamiprid are relatively stable under frozen storage
conditions in/on fortified samples of clover forage for up to 239 days
(7.9 months), clover hay for up to 213 days (7.0 months), and tomatoes
for up to 114 days (3.7 months).  The storage durations and conditions
of samples from the submitted crop field trials are presented below in
Table 6.  

Table 6.   Summary of Storage Conditions and Durations of Samples from
Crop Field Trial Studies.  

Matrix 	Storage Temperature

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

Clover forage	-29 to -10	224-227 days (7.4-7.5 months)	Up to 239 days
in/on frozen clover forage.

Clover hay

195-204 days (6.4-6.7 months)	Up to 213 days in/on frozen clover.

Grape	-28 to -10	49-125 days (1.6-4.1 months)	Up to 12 months in/on
diverse representative crops, including fruits.

Tomato	-21 ± 7	20-99 days (0.7-3.3 months)	Up to 114 days in/on frozen
tomato.



Conclusions.  The available storage stability data for acetamiprid on
representative crops, and the submitted concurrent storage stability
data for clover and tomato are adequate to support the submitted clover,
grape, tomato, and tea field trials.  There is no need for correction of
residues, as no decline in residue was observed. 

860.1480 Meat, Milk, Poultry, and Eggs

The proposed use on clover could theoretically lead to the secondary
transfer of acetamiprid residues of concern to beef and dairy cattle
from the feeding of clover forage, hay, and silage.  However, the
proposed use on clover is to be restricted to that grown in ID, OR, and
WA only.  Therefore, HED does not believe that the proposed use on
clover would significantly increase the dietary burdens, and the
established tolerances in milk, meat, and meat byproducts need not be
reassessed for the purpose of this petition.

860.1500 Crop Field Trials

DER Reference List	47716901.der.doc (Clover)

			47716902.der.doc (Grapes)

			47716903.der.doc (Greenhouse Tomatoes)

			47782101.der.doc (Tea)

Residue Chemistry Memo DP#   SEQ CHAPTER \h \r 1 264154, 12/31/2001, M.
Doherty (PP#0F6082)

Minutes of the 11/16/2005 Meeting of the HED Chemistry SAC

IR-4 has submitted magnitude of the residue data for acetamiprid on red
clover, grapes, and tomato, and tea to support the new uses on clover
and greenhouse tomatoes, tea and amended use on grapes (also expanded to
small vine climbing fruits, except fuzzy kiwifruit, subgroup 13-07F).  A
summary of the residue data is presented in Table 7a and 7b.

Table 7a.   Summary of Residue Data from Crop Field Trials with
Acetamiprid.



Crop Matrix	Total Applic. Rate

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



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

Clover

(Proposed use = One broadcast foliar spray treatment at a maximum of
0.075 lb ai/A; 28-day PHI)

Clover forage	0.074-0.079	28-34	6	<0.01	0.05	0.05	0.05	0.04	0.02

Clover hay

56-63	6	<0.01	<0.01	<0.01	0.01	0.01	--

Grapes and Other Climbing Vine Small Fruits (Except Fuzzy Kiwifruit)
(Within Crop Subgroup 13-07F)

(Current registered use on Grapes = 0.1 lb ai/A total application rate;
7-day PHI)

(Proposed amended use = 0.2 lb ai/A total application rate; 3-day PHI)

Grape	0.195-0.206	2-3	36	0.01	0.25	0.25	0.08	0.11	0.07

Tomatoes

(Current registered field use = 0.3 lb ai/A total application rate;
7-day PHI)

(Proposed greenhouse use = 0.15 lb ai/A total application rate; 1-day
PHI)

Tomato	0.300-0.324	1	6	<0.01	0.052	0.050	0.027	0.029	0.018

1  HAFT = Highest average field trial result.

TABLE 7b.	Summary of Residue Data from Crop Field Trials with
Acetamiprid.

Commodity	Total Applic. Rate, 

lb ai/A

[kg ai/ha]	PHI (days)	Residue Levels  (ppm)



	n	Min.	Max.	HAFT1	Median

(STMdR)	Mean

(STMR)	Std. Dev.

Japan Study - Combined residues of acetamiprid and residues convertible
to Metabolite IC-0

Green tea - dried leaves	0.13-0.27

[0.15-0.30]	6-7	8	13.6	40.9	39.3	23.9	25.3	9.82



13-14	8	8.15	17.2	16.6	13.1	12.8	4.19



20-21	8	2.30	5.44	5.44	3.64	3.75	1.19

Green tea - brewed tea*	0.13-0.27

[0.15-0.30	6-7	8	7.74	27.7	27.0	17.3	17.4	7.29



13-14	8	5.17	12.7	12.6	9.21	9.07	3.38



20-21	8	1.57	3.30	3.27	1.87	2.15	0.70

India Study (wet and dry season tea) - Residues of acetamiprid per se
(only mean values reported)2

Black tea - green shoots	0.022-0.045

[0.025-0.050]	0	12	3.96	9.53	9.53	NC3	6.54	NC



7	12	0.20	0.51	0.51	NC	0.33	NC



15	12	0.03	0.11	0.11	NC	0.06	NC



21	12	<0.05	<0.05	<0.05	<0.05	<0.05	0

Black tea - dried leaves	0.022-0.045

[0.025-0.050]	0	12	11.2	26.4	26.4	NC	18.5	NC



7	12	0.54	1.47	1.47	NC	0.95	NC



15	12	<0.05	0.26	0.26	NC	0.11	NC



21	12	<0.05	<0.05	<0.05	<0.05	<0.05	0

Black tea - brewed tea*	0.022-0.045

[0.025-0.050]	0	12	5.4	12.6	12.6	NC	8.92	NC



7	12	0.24	0.61	0.61	NC	0.41	NC



15	12	<0.05	0.13	0.13	NC	0.07	NC



21	12	<0.05	<0.05	<0.05	<0.05	<0.05	0

Black tea - spent leaves	0.022-0.045

[0.025-0.050]	0	12	4.6	10.2	10.2	NC	7.5	NC



7	12	0.20	0.51	0.51	NC	0.36	NC



15	12	<0.05	0.09	0.09	NC	0.06	NC



21	12	<0.05	<0.05	<0.05	<0.05	<0.05	0

HAFT = Highest Average Field Trial.  2  The reported LOD (0.05 ppm) was
used for calculation of median, mean, and standard deviation where
appropriate.  Only the 0-day PHI and PHIs relevant for comparison to the
Japan trials were included in the summary.  3  NC = Not calculated. 
Median and standard deviation could not be calculated because only mean
values were reported for each sample set.  4  NA = Not applicable when
all residues are nonquantifiable (<0.05 ppm).  *  The relatively high
residues in the brewed tea, which HED expected to be much lower than the
residues in or on the dried tea leaves, may reflect a back calculation
of what the residues would have been on the dried tea leaves. 
Otherwise, HED can not account for why the residues were not diluted by
the water used for making the tea. 

Clover

Three red clover field trials were conducted in the U.S. in Zone 11 (OR)
during the 2006 growing season.  Each trial site consisted of one
untreated plot and one treated plot.  Red clover was treated with a
single broadcast foliar application of Assail® 30SG, a 30% SG
formulation of acetamiprid, at a rate of 0.074-0.079 lb ai/A (ca. 1x the
maximum proposed seasonal rate on clover).  Application was made when
the crop was in the vegetative stage to blooming stage using ground
equipment in 23-25 GPA spray volumes, without an adjuvant.  Samples of
clover forage were harvested 28 to 34 days following application. 
Additionally, hay samples were cut at a normal harvest time (coinciding
with PHIs of 56-63 days) and allowed to dry in the field prior to
collection.

Samples were analyzed for residues of acetamiprid using an LC/MS/MS
working outline based on Cerexagri Method No. KP-216R1.  The adequacy of
the method for data collection was verified by analysis of untreated
samples of red clover forage and hay fortified with acetamiprid at
0.01-1.0 ppm.  Overall method recoveries ranged 75% to 96% for forage,
and 75% to 100% for hay.  The fortification levels used in method
validation adequately bracketed the expected residues in/on treated
clover forage and hay.  The validated LOQ (and LLMV) was 0.01 ppm in
both clover forage and hay.

Samples were held in frozen storage prior to analysis.  The maximum
sample storage durations, from harvest to analysis, were 227 days (7.5
months) for clover forage, and 204 days (6.7 months) for clover hay. 
Sample storage conditions and durations are supported by concurrent
storage stability data.  

The results of the clover field trials are summarized in Table 7. 
Residues of acetamiprid were <0.01-0.05 ppm in/on red clover forage
harvested 28-34 days following a single broadcast foliar application of
the 30% SG at 0.074-0.079 lb ai/A.  Residues were below the LLMV (<0.01
ppm) in/on clover hay harvested 56-63 days following treatment.

Conclusions:  The use pattern of the clover field trials adequately
reflects the proposed label use pattern with the exception of the PHI
for hay.  The available field trial data indicate a regional tolerances
for residues of acetamiprid in clover forage at 0.10 ppm and clover hay
at 0.01 ppm, are appropriate.  However, the submitted clover field trial
data are not completely adequate to satisfy data requirements.  The
three clover field trials were all conducted in Zone 11 (OR) during the
2006 growing season, at the same location and within a very short time
period of each other.  The number of trials are adequate to support
restricted use on clover in ID, OR and WA (Zones 11 and 12) according to
OPPTS Guideline 860.1500, Attachment 11; however the guidelines state
that for crops requiring 8 or more trials nationally (12 are required
for clover), the trials for regional registrations must be conducted in
multiple years to account for variability due to climate conditions.  As
a condition of registration, HED recommends that two additional clover
field trials be required, as confirmatory data.  In addition, the
submitted reside data included field trial data for only the 70WP
formulation (the original field trials also used a 70WP formulation). 
However, since the requested PHI is for 28 days, additional residue
chemistry field trial data are not required to support registration of
the 30SG formulation (generally bridging data are required if the
proposed PHI is less than or equal to 7 days).  Use on clover grown for
seed is to be limited to clover grown in ID, OR, and WA.  Since the
residue chemistry data submitted for clover hay reflect PHIs of between
56-63 days, the PHI for acetamiprid use on clover should be increased to
56 days for any clover crop which will be harvested for hay.

No residue decline data were included in the clover field trials. 
However, residue decline studies on cotton, head lettuce, oranges,
pears, and peppers were submitted in conjunction with PP#0F6082
(D264154, 12/31/2001, M. Doherty).  These data indicated that residues
of acetamiprid did not increase in the subject crops with increasing
harvest intervals.  Given the long PHI (28-days) for clover and
available residue decline data on other crops, residue decline data will
not be required to support the clover field trials.  The available field
trial data will support tolerances with regional registration for
residues of acetamiprid in clover forage at 0.10 ppm (with a 28-day PHI)
and clover hay at 0.01 ppm (with a 56-day PHI); the tolerance
calculations for clover forage are presented in Appendix I. 

Grape; Fruit, Small Vine Climbing, Subgroup 13-07F, Except Fuzzy
Kiwifruit

Eighteen grape field trials were conducted in the U.S. and Canada in
Zones 1 (NY; 1 trial), 2 (NJ; 2 trials), 5 (ON; 4 trials), 5A (MI; 1
trial), 10 (CA; 8 trials), 11 (BC; 1 trial), and 11/12 (WA; 1 trial)
during the 2005 growing season.  Mature grape vines in established
orchards were treated with two directed foliar applications of Assail®
70WP, a 70% WP formulation of acetamiprid, at 0.096-0.103 lb
ai/A/application, with a 13- to 14-day retreatment interval (RTI), for a
total rate of 0.195-0.206 lb ai/A (ca. 1x the maximum proposed seasonal
rate on grapes and other climbing vine small fruits).  Applications were
made during the crop’s fruiting to berry ripening stages using ground
equipment in 22-130 GPA spray volumes, without an adjuvant.  Samples of
mature grape fruits were harvested 2 to 3 days after the second
application.

Samples were analyzed for residues of acetamiprid using an LC/MS/MS
method based on Cerexagri Method No. KP-216R1.  The adequacy of the
method for data collection was verified by analysis of untreated samples
of grapes fortified with acetamiprid at 0.01-1.0 ppm.  Overall method
recoveries ranged from 80% to 98%.  The fortification levels used in
method validation adequately bracketed the expected residues in/on
treated grapes.  The validated LOQ (and LLMV) was 0.01 ppm in grape.

Samples were held in frozen storage prior to analysis.  The maximum
sample storage duration from harvest to analysis was 125 days (4.1
months) for grape.  Adequate storage stability data are available for
acetamiprid demonstrating that residues are stable in/on diverse
representative crops (including fruits) for up to one year.  

The results of the grape field trials are summarized in Table 7. 
Residues of acetamiprid were 0.01-0.25 ppm in/on grapes harvested 2-3
days following the last of two directed foliar applications of the 70%
WP at a total rate of 0.195-0.206 lb ai/A.  No residue decline data were
included in the grape field trial study.

Conclusions:  The submitted grape residue data included field trial data
for only the 70WP formulation (the original field trials also used a
70WP formulation).  Since the requested PHI for grape is for 3 days,
additional residue chemistry field trial data are needed to support
registration of the 30SG formulation.  As a condition of registration,
HED requests that three side-by-side field trials be conducted and
submitted to determine if residues are comparable for the two different
formulations.

The submitted grape field trial data are adequate for the 70 WP
formulation pending label revision.  Because the grape field trial data
did not reflect the use of a surfactant in the application sprays, the
label directions regarding use of a spreader, methylated seed oil or
crop oil should be removed from the product label of Assail® 30SG (EPA
Reg. No. 8033-36).  The number and locations of the field trials are in
accordance with OPPTS Guideline 860.1500 for grapes, and the use pattern
of the field trials reflects the use pattern proposed for grapes (and
other climbing vine small fruits,  except fuzzy kiwifruit, within
subgroup 13-07F), except for the adjuvant use.  

No residue decline data were included in the grape field trials.  The
residue decline studies from PP#0F6082 (DP# 264154, 12/31/2001, M.
Doherty), which indicated that residues of acetamiprid did not increase
in various crops with increasing harvest intervals, will be used to
fulfill the requirements for residue decline data.  The available field
trial data from the current submission, which reflect a higher seasonal
rate and a shortened PHI from those which are currently registered for
grape, will support a tolerance for residues of acetamiprid at 0.35 ppm;
the tolerance calculations for grape are presented in Appendix I.  

Grape is the representative crop of the fruit, small vine climbing,
subgroup 13-07F, except fuzzy kiwifruit, and the available grape data
will support a subgroup tolerance at 0.35 ppm.  The established
individual tolerance for grape at 0.20 ppm should be deleted when the
subgroup 13-07F tolerance is established.

Tomatoes (Greenhouse Study)

Three trials were conducted on tomatoes in the U.S. and Canada in Zones
4 (TN), 5 (ON), and 6 (TX) during the 2002 and 2003 growing seasons. 
Each trial site included one untreated plot and one treated plot. 
Tomato plants grown in rock wool substrate under greenhouse conditions
were treated at the fruiting stage with four simulated drip-irrigation
(chemigation) treatments of Assail® 70WP, a 70% WP formulation of
acetamiprid, at rates equivalent to 0.074-0.081 lb ai/A/application. 
Applications were made with 7-day RTIs, for a total rate of 0.300-0.324
lb ai/A (ca. 2x the maximum proposed seasonal rate for greenhouse-grown
tomato); no adjuvant was used.  Samples of mature tomato were harvested
one day after the last application.  At the TX trial, additional treated
samples were harvested 3, 5, and 7 days after the last application to
generate residue decline data.

Samples were analyzed for residues of acetamiprid using a GC/ECD working
method entitled “Residue Analysis of Acetamiprid on Tomato
(greenhouse) by GC/EC Detection”, adapted with modifications from the
reference method, “Methods for the Analysis of Acetamiprid (NI-25) in
Plants and Plant Process Fractions.”  The adequacy of the method for
data collection was verified by analysis of untreated samples of tomato
fruit fortified with acetamiprid at 0.01-1.0 ppm.  Overall method
recoveries ranged from 86% to 120%.  The fortification levels used in
method validation adequately bracketed the expected residues in/on
treated tomato.  The validated LOQ (and LLMV) was 0.01 ppm in tomato.

Tomato samples were held under frozen storage conditions for a maximum
duration of 99 days (3.3 months) prior to residue analysis.  Sample
storage conditions and durations are supported by concurrent storage
stability data.  

The results of the greenhouse grown tomato field trials are summarized
in Table 7.  Residues of acetamiprid ranged from below the LLMV (<0.01
ppm) to 0.052 ppm in/on greenhouse-grown tomatoes harvested one day
following the last of four drip-irrigation (chemigation) treatments of
the 70% WP at a total rate of 0.300-0.324 lb ai/A.  The decline data
show that residues accumulated slightly, from an average of 0.027 ppm at
the 1-day PHI to an average of 0.037 ppm at the 7-day PHI.

Conclusions:  The submitted tomato data do not reflect the proposed
greenhouse use pattern because the application rate used in the trials
is 2x the proposed seasonal rate for tomatoes grown under greenhouse
conditions.  In addition, the three trials conducted are marginally
adequate with respect to the number of trials.  Because the established
field tomato uses differ from the proposed greenhouse-grown tomato use,
HED (ChemSAC 11/16/05 minutes) typically requires data depicting
residues from 4 greenhouse sites, with 4 samples per site.  For
chemicals with tomato tolerances resulting from a field use and for
which the field and greenhouse use patterns are similar, any of the
following 3 study designs would generally be found to be appropriate: 
(i) residue data from 3 greenhouse sites with 2 samples per site; (ii)
residue decline data, encompassing the proposed PHI, from 2 greenhouse
sites with 2 samples per time interval; or (iii) residue data from 2
greenhouse sites with 4 samples per site.

Although the greenhouse trials were conducted at a 2x rate and the
number of trials is marginal, no additional residue data will be
required to support the proposed greenhouse use pattern for tomatoes if
use is limited to the WP formulation.  The tomato greenhouse data
indicate that resulting acetamiprid residues resulting from applications
of Assail 70WP formulation of acetamiprid according to the proposed use
pattern would not exceed the established tolerance for residues of
acetamiprid in fruiting vegetables, crop group 8 (0.20 ppm).  No data
were provided for the proposed use of Tristar® 30SG on greenhouse
tomatoes.  HED does have side-by-side formulation trials (WP and soluble
liquid formulation) for acetamiprid in undelinted cottonseed and cotton
gin byproducts (D330540, M. Doherty, 30 Oct 2007).  These data indicate
that residue levels are comparable for the two different formulations at
the same use rate.  In view of these data and the 70WP data reflecting
2x the seasonal application rate, HED requests only one side-by-side
formulation trial (rather than the normal of three trials) to support
the use of Tristar® 30SG on greenhouse tomatoes as a condition of
registration. 

Tea

The Interregional Research Project No. 4 (IR-4) has submitted a report
summarizing the results of two studies on tea conducted in Japan (by
Nippon Soda Co., Ltd.) and India (by the Institute of Himalayan
Bioresource Technology; IHBT).  No raw data were included in the
submission, all data presented herein are as reported in the original
studies.

Nippon Soda Co, Ltd. conducted two trials in the Mie Prefecture and the
Fukuoka Prefecture of Japan investigating the magnitude of the residue
in dried green tea leaves and brewed tea following a single foliar
application of a 20% water-soluble powder (SP) formulation of
acetamiprid made to green tea in separate plots at 0.13 lb ai/A (0.15 kg
ai/ha) and 0.27 lb ai/A (0.30 kg ai/ha).  Applications were made in
spray volumes of 321 gal/A (3000 L/ha).  The following Good Agricultural
Practice (GAP) information was provided for the 20% SP formulation in
Japan:  one foliar application at 0.10-0.40 kg ai/ha applied in
2000-4000 L/ha, with a 14-day preharvest interval (PHI).  Duplicate
samples of green tea leaves were harvested 6-7, 13-14, and 20-21 days
after application, and were processed into dried leaves and brewed tea
(green tea drink) according to standard procedures for green tea.  

In a separate study, the Institute of Himalayan Bioresource Technology
(IHBT) conducted two sets of trials in Palampur (Himachal Pradesh,
India) investigating the magnitude of the residue in black tea for green
shoots, dried tea leaves, brewed tea, and spent leaves after brewing. 
Acetamiprid was applied to black tea in separate plots as a single
foliar application of a 20% SP formulation of acetamiprid at 0.022 lb
ai/A (0.025 kg ai/ha) and 0.045 lb ai/A (0.050 kg ai/ha) in spray
volumes of 43 gal/A (400 L/ha).  The application rates were reported to
be 1x and 2x the recommended application rate for acetamiprid on tea. 
Two sets of trials were conducted, one during the dry season (June) and
the second during the wet season (August).  The following GAP
information was provided for India:  shoots along with bud are typically
harvested at a 7-day PHI.  Samples of green shoots (consisting of two
leaves and a bud) were collected 0 (2 hours post application), 1, 3, 5,
7, 9, 11, 15, and 21 days after application; three replicate samples
were collected from each plot at each sampling interval.  Samples were
processed into dried tea leaves and brewed tea (infusion) using standard
procedures for black tea production; samples of spent leaves following
brewing were also collected. 

Samples of dried green tea leaves and brewed tea from the Japan study
were analyzed for residues of acetamiprid and its metabolites
convertible to 6-chloronicotinic acid (Metabolite IC-0) using a common
moiety gas chromatography method with electron capture detection
(GC/ECD).  Using this method, acetamiprid and metabolites are converted
to Metabolite IC-0 and methylated prior to determination by GC/ECD;
residues are expressed as acetamiprid.  The reported method limit of
detection (LOD) is 0.05 ppm as acetamiprid.  Samples of green shoots,
dried black tea leaves, brewed tea, and spent leaves from the India
study were analyzed for residues of acetamiprid using a high performance
liquid chromatography method with ultraviolet detection (HPLC/UV).  The
reported LOD was 0.05 ppm. Both methods are adequate for data collection
based on the submitted concurrent recovery data; however, we note that
the fortification levels used in concurrent method validation in the
Japan study did not encompass residues found in dried green tea leaves
or brewed tea. 

Regarding the common moiety method used in the Japan study, we note
that, although Metabolite IC-0 is not a residue of concern for tolerance
enforcement or risk assessment, based on the available plant metabolism
studies, it may constitute a significant portion of the total residues
(e.g., up to 24% total radioactive residues (TRR) in cotton seed and 31%
TRR in carrot flesh; refer to D278652, 11/13/01, H. Bietlot and M.
Doherty).  Therefore, the residues reported for the Japan study may
reflect an overestimation of expected residues of acetamiprid per se in
green tea.

Samples of dried green tea leaves and brewed tea from the Japan study
were stored frozen from collection to analysis for up to 3.5 and 1.7
months, respectively.  Storage conditions and durations for samples of
green shoots, dried black tea leaves, brewed tea, and spent leaves from
the India study were not reported; however, the study indicated that
samples were analyzed immediately after receipt in the laboratory and
that extensive storage was not required.  HED believes there are
sufficient storage stability data available for acetamiprid,
demonstrating that residues are stable in crop commodities stored frozen
for up to 12 months and crop commodities stored at ambient temperatures
for up to 7 days, to support both studies (refer to D264154, 12/31/01,
M. Doherty).

Following a single foliar application of the 20% SP formulation of
acetamiprid at 0.13-0.27 lb ai/A (0.15-0.30 kg ai/ha) to green tea grown
in Japan, combined residues of acetamiprid and metabolites were
13.6-40.9 ppm in dried green tea leaves harvested 6-7 days after
application and were 8.15-17.2 and 2.30-5.44 ppm in dried leaves
harvested 13-14 and 20-21 days after application, respectively.  In
brewed tea produced from the dried leaves harvested at the 6- to 7-, 13-
to 14-, and 20- to 21-day PHIs, residues were 7.74-27.7, 5.17-12.7, and
1.57-3.30 ppm, respectively.

Following a single foliar application of the 20% SP formulation of
acetamiprid at 0.022-0.045 lb ai/A (0.025-0.050 kg ai/ha) to black tea
grown in India during the wet and dry seasons, combined residues of
acetamiprid in green shoots harvested at 0-, 7, -15, and 21-day PHIs
were 3.96-9.53, 0.20-0.51, 0.03-0.11, and <0.05 ppm, respectively. 
Residues in dried black tea leaves processed from the shoots were
generally higher at the 0-, 7-, and 15-day PHIs, 11.2-26.4, 0.54-1.47,
and <0.05-0.26 ppm, respectively, and were <0.05 ppm at the 21-day PHI. 
Residues were 5.4-12.6, 0.24-0.61, and <0.05-0.13 ppm, respectively, in
brewed tea, and 4.6-10.2, 0.20-0.51, and <0.05-0.09 ppm, respectively,
in spent leaves from tea harvested at the 0-, 7-, and 15-day PHIs, and
were <0.05 ppm in brewed tea and spent leaves at the 21-day PHI.

The study report also contained a list of multiresidue method analysis
results for residues of acetamiprid in tea received in commercial
shipments from various countries.  Although residues were nondetectable
in the majority of green and black tea samples received from Argentina,
Bangladesh, Burundi, China, Ecuador, Ethiopia, India, Indonesia, Iran,
Kenya, Malawi, Mozambique, Rwanda, Sri Lanka, South Africa, Tanzania,
Turkey, Uganda, Vietnam, Zimbabwe, detectable residues of acetamiprid
were found in tea samples from China (0.03-0.04 ppm; n=3), Indonesia
(0.03 ppm; n=1), and Vietnam (0.03-0.12 ppm; n=7).  The source of these
data was not identified.

860.1520 Processed Food and Feed

Residue Chemistry Memo DP#   SEQ CHAPTER \h \r 1 264154, 12/31/2001, M.
Doherty (PP#0F6082)

No new processing studies were submitted with this petition request.  

Grape

An acceptable grape processing study (MRID 44988620) was reviewed under
PP# 0F6082 which reported processing factors of 1.5x for juice and 0.9x
for raisins.  Expected residues, based on the new HAFT (0.25 ppm) for
grape from the amended use, would be 0.375 ppm in juice and 0.225 ppm in
raisins.  Based on these data, no tolerance is needed in grape raisins
as a result of the proposed use because any expected residues in raisins
are less than the RAC tolerance.  Considering that the maximum
theoretical concentration factor for grape juice is 1.2 (Guideline
860.1520), HED also expects residues in grape juice, resulting from the
proposed use, will not  exceed the RAC tolerance of 0.35 ppm; therefore,
a separate tolerance is not needed for grape juice. 

Tomato

An acceptable tomato processing study (MRID 44988621) was reviewed under
PP# 0F6082 which reported processing factors of 1.4x for puree and 3.0x
for paste.  Based on the observed processing factor of 3.0x and a HAFT
of 0.1 ppm, a tolerance of 0.40 ppm was established for residues of
acetamiprid in tomato paste.  A tolerance was not needed in puree
because any expected residues in puree would be less than the RAC
tolerance (0.20 ppm).  The proposed use on greenhouse-grown tomatoes
will not change the expected residues in puree or paste.  

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

An analytical standard for acetamiprid is currently available in the
National Pesticide Standards Repository (personal communication with
Dallas Wright, ACB, 07/06/2009).  However, analytical standards for the
IM-2-1 and IM-2-1-amide metabolites are not available at the Repository.
 Analytical reference standards of these metabolites must be supplied
and supplies 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 Confined Accumulation in Rotational Crops

Residue Chemistry Memo   SEQ CHAPTER \h \r 1 DP# 328216, 10/23/2007, W.
Drew (PP#6F7051 and PP#6E7163)

Residue Chemistry Memo DP#   SEQ CHAPTER \h \r 1 264154, 12/31/2001, M.
Doherty (PP#0F6082)

  SEQ CHAPTER \h \r 1 No new confined rotational crop data were
submitted with this petition; the nature of the residue in rotational
crops is understood.  A confined rotational crop study was reviewed in
conjunction with PP#0F6082.  In the study, acetamiprid was not detected
in any rotational crop matrix (mustard greens, radish, and grain crops)
at any of the plantback intervals (PBIs), which were 30-, 58-, 120- and
365 days after treatment (DAT) following application to bare soil at
0.66 lb ai/A.  The major metabolite identified in rotational crops was
IM-1-4, at 2.94-56.65% TRR (<0.001-0.040 ppm).  Two other metabolites
were identified in most rotational crops:  IM-0-Glc, at 1.11-15.23% TRR
(<0.001-0.010 ppm), and IC-0, at 2.75-24.19% TRR (<0.001-0.014 ppm). 
Storage stability data, required as a condition of registration in the
original petition PP#0F6082, have been submitted and determined to
rectify deficiencies under PP#6F7051.  

HED has determined that the residue of concern in rotational crops is
parent only, and that tolerances would not be needed on rotational
crops.  The available rotational crop data are adequate to support the
uses proposed in this petition.  

860.1900 Field Accumulation in Rotational Crops

Residue Chemistry Memo   SEQ CHAPTER \h \r 1 DP# 328216, 10/23/2007, W.
Drew (PP#6F7051 and PP#6E7163)

No field rotational crop data have been submitted, and no rotational
crop restrictions have been proposed.  The available confined rotational
crop data indicate that no field rotational crop studies or label
restrictions for rotational crops are required to support the proposed
uses.

860.1550 Proposed Tolerances

Tolerances are currently established under 40 CFR §180.578 (a)(1) for
residues of the insecticide, acetamiprid, in or on crop matrices.  The
tolerance expression proposed by IR-4 in this petition is consistent
with 40 CFR §180.578(a)(1).

Adequate field trial data were submitted for clover.  Provided
confirmatory data are submitted as a condition of registration, the
available field trial data will support the proposed regional tolerances
for residues of acetamiprid in clover forage at 0.10 ppm and clover hay
at 0.01 ppm.  The tolerance spreadsheet in the Agency’s Guidance for
Setting Pesticide Tolerances Based on Field Trial Data was utilized for
determining the appropriate tolerance level for clover forage; see
Appendix I.  The tolerance spreadsheet was not used to determine the
tolerance level on clover hay because all treated samples (n=6) bore
residues below the LLMV (<0.01 ppm).  

The submitted field trial data for grapes are adequate pending label
revision to remove use of a spreader, methylated seed oil or crop oil
from the product label of Assail® 30SG.  The available grape field
trial data from the current submission, which reflect a higher seasonal
rate and a shortened PHI from those which are currently registered on
grapes, will support the proposed tolerance for residues of acetamiprid
in “fruit, small, vine climbing, subgroup 13-07F, except fuzzy
kiwifruit” at 0.35 ppm.  The tolerance spreadsheet in the Agency’s
Guidance for Setting Pesticide Tolerances Based on Field Trial Data was
utilized for determining the appropriate tolerance level for grape; see
Appendix I.  The established individual tolerance for grape at 0.20 ppm
should be concomitantly removed upon the establishment of the Subgroup
13-07F (except fuzzy kiwifruit) tolerance.  HED notes that side-by-side
trials on grapes comparing residues from the WP and SG formulations are
recommended as a condition of registration.

Although the tomato greenhouse trials were conducted at 2x and the
number of trials is marginal, the submitted data indicate that the
established tolerance for residues of acetamiprid in fruiting vegetables
(Crop Group 8) at 0.20 ppm will not be exceeded following applications
of Tristar® 30SC according to the use patterns of the tomato greenhouse
trials.  HED notes that side-by-side trials on tomatoes comparing
residues from the WP and SG formulations are recommended as a condition
of registration.

Acceptable grape and tomato processing studies are available.  The grape
processing studies reported processing factors of 1.5x for juice and
0.9x for raisins.  The tomato processing studies reported processing
factors of 1.4x for puree and 3.0x for paste.  Based on these data, no
tolerances are needed in grape raisins and tomato puree as a result of
proposed uses because any expected residues in these processed
commodities are estimated to be less than the respective RAC tolerances.
 Based on the observed processing factor of 3.0x and a HAFT of 0.1 ppm,
a tolerance of 0.40 ppm was established under 40 CFR §180.578[a][1] for
residues of acetamiprid in tomato paste; this tolerance remains
appropriate with the proposed use on greenhouse tomatoes.  Considering
that the maximum theoretical concentration factor for grape juice is 1.2
(Guideline 860.1520), HED also expects residues in grape juice,
resulting from the proposed use, will not  exceed the RAC tolerance of
0.35 ppm; therefore, a separate tolerance is not needed for grape juice.

Although the tolerance spreadsheet recommends a 40 ppm level for dried
tea, one residue value (40.9 ppm) exceeded that level and Japan has an
established 50 ppm MRL for tea.  Therefore, HED recommends a 50 ppm
tolerance as well.  Given the data for brewed tea and understanding that
FDA would adjust residues measured on instant tea back to a dried tea
basis for enforcement purposes, a separate instant tea tolerance is not
required

The established tolerances on   SEQ CHAPTER \h \r 1 animal commodities
need not be reassessed for this petition.  The proposed use on clover
could theoretically lead to the secondary transfer of acetamiprid
residues of concern to beef and dairy cattle from the feeding of clover
forage, hay, and silage.  However, the proposed use on clover is to be
restricted to that grown in ID, OR, and WA only and the residues on the
clover RAC are very low.  Therefore, HED does not believe that this
would significantly increase the dietary burdens.

Tolerances on rotational crops are not needed.  Residues of acetamiprid
were not detected in any rotational crop matrix (mustard, lettuce,
radish, sorghum, or wheat) at any PBI (30, 58, 120, or 365 DAT).

There are no Codex maximum residue limits (MRLs) established for
residues of acetamiprid on crop or animal commodities; no Mexican MRLs
are established on crops associated with this petition.  Canada has
established an MRL for acetamiprid residues in grapes at 0.20 ppm.  The
recommended U.S. tolerance for Subgroup 13-07F tolerance at 0.35 ppm is
not harmonized with the Canadian MRL, presumably because of differences
in good agricultural practices.  Japan has a 50 ppm MRL for tea and HED
recommends setting the tolerance at the same level.  An International
Residue Limit Status (IRLS) sheet is appended to this document.

The final tolerance for subgroup 13-07F should reflect the correct
commodity definitions, as specified in Table 8.  A revised Section F
does not need to be submitted for this minor change.  

Provided that the forthcoming human health risk assessment does not
identify any issues of concern, the submitted data support the
establishment of permanent tolerances for acetamiprid, including its
metabolites and degradates under 40 CFR §180.578, as listed in Table 8,
below.    Compliance with tolerance levels specified below is to be
determined by measuring acetamiprid only.

Table 8.   Tolerance Summary for Acetamiprid.

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

Clover, forage	0.10	0.10	Recommended tolerances are for regional
registration.

Clover, hay	0.01	0.01

	Fruit, small, vine climbing, except fuzzy kiwifruit, subgroup 13-07F
0.35	0.35	Pending label revision to remove use of a spreader, methylated
seed oil or crop oil.   Fruit, small, vine climbing, except fuzzy
kiwifruit, subgroup 13-07F.

Grape	0.20	Remove	Grapes will be covered under the subgroup 13-07F
tolerance.

Tea, dried	50.0	50.0	Tolerance without a U.S. registration.



References

D342549/355773.  Acetamiprid.  Request for Label Amendment (TriStar
30SG) Allowing Food/Feed Use of the Insecticide on Vegetable
Transplants; Independent Laboratory Validation Study (Assail 70WP),
Submitted as Supplementary Data Pursuant to HED Memorandum of 5 November
2004 (D303623).    SEQ CHAPTER \h \r 1 W. Drew, 11/05/2008.  MRID: 
47185401.  SEQ CHAPTER \h \r 1 

D328216.  Acetamiprid.  Petitions Requesting the Establishment of
Permanent Tolerances (Associated with Section 3 Registration) for New
Food/Feed Uses of the Insecticide on Berries (Crop Group 13), Bulb
Vegetables (Crop Group 3), Edible Podded Legume Vegetables (Crop
Subgroup 6A), Succulent Shelled Pea and Bean (Crop Subgroup 6B), and
Strawberry and Other Low-growing Berries.  Summary of Analytical
Chemistry and Residue Data.  Petition Numbers 6F7051 (Various Crops) and
6E7163 (Strawberry).  W. Drew, 10/23/2007.  MRIDs:  46785502-46785504
and 47013601

	  SEQ CHAPTER \h \r 1 D303623.    SEQ CHAPTER \h \r 1 Acetamiprid. 
Tolerance Petition Requesting Section 3 Registration for Food Use of the
Insecticide Acetamiprid on Cucurbit Vegetables (Crop Group 9), Stone
Fruits (Crop Group 12), and Tree Nuts (Crop Group 14).  Summary of
Analytical Chemistry and Residue Data.  Petition Number 4F6833.  W.
Drew, 11/05/2004.  MRIDs:    SEQ CHAPTER \h \r 1 46265701-46265703.

  SEQ CHAPTER \h \r 1   SEQ CHAPTER \h \r 1 D306191.  Acetamiprid. 
Tolerance Petition Requesting Section 3 Registration for Food Use of the
Insecticide Acetamiprid on Tuberous and Corm Vegetables (Crop Subgroup
1C) and Non-Food Use on Tobacco.  Summary of Analytical Chemistry and
Residue Data.  Petition Number 3F6575.    SEQ CHAPTER \h \r 1 W. Drew,
11/03/2004.  MRIDs:    SEQ CHAPTER \h \r 1 45900506-45900509.

D264154.  0F6082.  Section 3 Registration for Use of Acetamiprid on
Cotton, Leafy Vegetables, Cole Vegetables, Fruiting Vegetables, Citrus
Fruits, Pome Fruits, Grapes, and Canola and Mustard Seed.  Summary of
Analytical Methods and Residue Chemistry DERs.  M. Doherty, 12/31/2001. 
MRIDs:  44988518-44988524, 44988526, 44988529, 44988532-44988535,
44988601-44988603, 44988610, 44988611, 44988616, 44988618-44988623,
4498862.

D278652.  Acetamiprid.  Results of the HED Metabolism Assessment Review
Committee Meeting Held on October 16, 2001.  H. Bietlot, M. Doherty, and
P. Hurley, 11/13/2001.  MRID:  None.

  SEQ CHAPTER \h \r 1 Attachments:  

International Residue Limit Status sheet

Appendix I - Tolerance Assessment Calculations



INTERNATIONAL RESIDUE LIMIT STATUS



Chemical Name:	

Common Name:

Acetamiprid	

X Proposed tolerance

( Reevaluated tolerance

( Other	

Date:  07/06/2009

Updated: Oct 5, 2009 with the tea MRL information.



Codex Status (Maximum Residue Limits)	

U. S. Tolerances



X No Codex proposal step 6 or above

( No Codex proposal step 6 or above for the crops requested	

Petition Number:  9E7544

DP Barcode:  D364833

Other Identifier:  



Residue definition (step 8/CXL): N/A	

Reviewer/Branch:  Dennis McNeilly/RAB2

	

Residue definition:  acetamiprid
[N1-[(6-chloro-3-pyridyl)methyl]-N2-cyano-N1-methylacetamidine]



Crop (s)	

MRL (mg/kg)	

Crop(s) 	

Tolerance (ppm)



	

	Clover, forage	0.10 



	

	Clover, hay	0.01



	

	Fruit, small, vine climbing, except fuzzy kiwifruit, subgroup 13-07F
0.35



	

	Tea	

50.0



Limits for Canada	

Limits for Mexico



( No Limits

( No Limits for the crops requested	

( No Limits

X No Limits for the crops requested



Residue definition: (E )-N-[(6-chloro-3-pyridinyl)methyl]-N’
-cyano-N-methylethanimidamide

	

Residue definition: acetamiprid





Crop(s)	

MRL (mg/kg)	

Crop(s)	

MRL (mg/kg)



Grapes	

0.2	

	





	

	

	





Notes/Special Instructions:

S. Funk, 07/07/2009.  Note:  There are no MRLs for acetamiprid in Codex.
 There is no MRL for acetamiprid on tea in Australia.  There is no MRL
for acetamiprid on tea in Canada.  Japan has a 50 ppm MRL for tea.



Rev. 1998

Appendix I

Tolerance Assessment Calculations

Clover forage

The dataset used to establish a tolerance for acetamiprid on clover
forage consisted of field trial data representing a single application
at rates of 0.074-0.079 lb ai/A with a 28- to 34-day PHI.  As specified
by the Guidance for Setting Pesticide Tolerances Based on Field Trial
Data (SOP), the field trial application rates and PHIs are within 25% of
the maximum label application rate and minimum label PHI, respectively. 
The residue values that were entered into the tolerance spreadsheet are
provided in Table I-1.

2 of 6 field trial sample results were below LOQ (LOQ = 0.01 ppm),
entering the LOQ and using maximum likelihood estimation (MLE)
procedures for the censored values both yielded a recommended tolerance
of 0.1 ppm.  Visual inspection of the lognormal probability plot (Figure
I-1) and the result from the approximate Shapiro-Francia test statistic
(Figure I-2) indicated that the assumption of lognormality should be
rejected.

Since the field trial data for acetamiprid on clover forage are not
lognormal, the upper bound on the 89th percentile should be selected as
the tolerance value (distribution-free method).  Using the rounding
procedure as outlined in the SOP, the upper bound on the 89th percentile
rounds to the value 0.10 ppm.  Therefore, 0.10 ppm is the recommended
tolerance level for acetamiprid in/on clover forage.

Table I-1.	Residue data used to calculate tolerance for acetamiprid on
clover forage.

Regulator:	EPA

Chemical:	Acetamiprid

Crop:	Clover Forage (MLE)

PHI:	28-34 Days

App. Rate:	1 at 0.074-0.079 lb ai/A

Submitter:	IR-4

MRID Citation:	MRID 47716901

	Residues of Acetamiprid (ppm)

	0.05

	0.04

	0.05

	0.05

	0.01  

	0.01





Figure I-   SEQ Figure_II- \* ARABIC  1 .  Lognormal probability plot of
acetamiprid field trial data for clover forage.

Figure I- 2.  Tolerance spreadsheet summary of acetamiprid field trial
data for clover forage.

Grapes

The dataset used to establish a tolerance for acetamiprid on grape
consisted of field trial data representing application rates of
0.195-0.206 lb ai/A (2 applications at ~0.10 lb ai/A/application) with a
2- to 3-day PHI.  As specified by the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data (SOP), the field trial application
rates and PHIs are within 25% of the maximum label application rate and
minimum label PHI, respectively.  The residue values that were entered
into the tolerance spreadsheet are provided in Table I-2.

All 36 field trial sample results were equal to or greater than the LOQ
(LOQ = 0.01 ppm).  Visual inspection of the lognormal probability plot
(Figure I-3) and the result from the approximate Shapiro-Francia test
statistic (Figure I-4) indicated that the assumption of lognormality
should be rejected.  

Since the field trial data for acetamiprid on grape are not lognormal,
the upper bound on the 89th percentile should be selected as the
tolerance value (distribution-free method).  Using the rounding
procedure as outlined in the SOP, the upper bound on the 89th percentile
rounds to the value 0.35 ppm.  Therefore, 0.35 ppm is the recommended
tolerance level for acetamiprid on grape. 

Table I-2.	Residue data used to calculate tolerance for acetamiprid on
grapes.

Regulator:	EPA

Chemical:	Acetamiprid

Crop:	Grape

PHI:	2-3 Days

App. Rate:	2 at 0.10 lb ai/A/application

Submitter:	IR-4

MRID Citation:	MRID 47716902

	Residues of Acetamiprid (ppm)

	0.050

	0.050

	0.030

	0.030

	0.010

	0.010

	0.080

	0.080

	0.170

	0.150

	0.080

	0.090

	0.080

	0.080

	0.200

	0.210

	0.240

	0.250

	0.100

	0.110

	0.060

	0.060

	0.220

	0.220

	0.040

	0.040

	0.070

	0.060

	0.040

	0.030

	0.150

	0.150

	0.240

	0.220

	0.130

	0.130



Figure I- 3.  Lognormal probability plot of acetamiprid field trial data
for grape.

Figure I- 4.  Tolerance spreadsheet summary of acetamiprid field trial
data for grape.

Tea

The dataset used to establish a tolerance for acetamiprid on tea
consisted of a report summarizing the results of two studies on tea
conducted in Japan (by Nippon Soda Co., Ltd.) and India (by the
Institute of Himalayan Bioresource Technology; IHBT), submitted by the
Interregional Research Project No. 4 (IR-4).  The dataset used to
establish a tolerance for acetamiprid on tea consisted of field trial
data representing application rates of 0.022-0.27 lb ai/A (1 foliar
application) with a 6- to 14-day PHI.  As specified by the Guidance for
Setting Pesticide Tolerances Based on Field Trial Data (SOP), the field
trial application rates and PHIs are within 25% of the maximum label
application rate and minimum label PHI, respectively.  The residue
values that were entered into the tolerance spreadsheet are provided in
Table I-2.

The common moiety method used in the Japan study included the metabolite
IC-0 which is not a residue of concern for tolerance enforcement or risk
assessment but, based on the available plant metabolism studies, it may
constitute a significant portion of the total residues (e.g., up to 24%
total radioactive residues (TRR) in cotton seed and 31% TRR in carrot
flesh; refer to D278652, 11/13/01, H. Bietlot and M. Doherty). 
Therefore, the residues reported for the Japan study may reflect an
overestimation of expected residues of acetamiprid per se in green tea.

All 38 field trial sample results were equal to or greater than the LOD
(LOD = 0.05 ppm).  Visual inspection of the lognormal probability plot
(Figure I-3) and the result from the approximate Shapiro-Francia test
statistic (Figure I-4) indicated that the assumption of lognormality
should be rejected.  

Since the field trial data for acetamiprid on tea are not lognormal, the
upper bound on the 89th percentile should be selected as the tolerance
value (distribution-free method).  Using the rounding procedure as
outlined in the SOP, the upper bound on the 89th percentile rounds to
the value 40.0 ppm.  However, one residue value is above the 40 ppm
level (40.9 ppm) and Japan has already established a 50.0 ppm MRL for
acetamiprid on tea; therefore, HED recommends for a 50 ppm tolerance. 

Given our understanding that FDA would adjust residues measured on
instant tea back to a dried tea basis for enforcement purposes, HED
believes that the 50.0 ppm tolerance for dried tea is adequate to cover
residues in or on instant tea and hence is not recommending for a
separate instant tea tolerance.  HED notes that the 50.0 ppm tolerance
harmonizes with Japan.  The residue data from Japan included the IC-0
metabolite, which is not in the U.S. tolerance expression and therefore
the data are considered conservative.

Table I-3.	Residue data used to calculate tolerance for acetamiprid on
tea.

Regulator:	EPA

Chemical:	Acetamiprid

Crop:	Tea

PHI:	6-14 Days

App. Rate:

	Submitter:	IR-4

MRID Citation:	MRID 47781201

	Residues of Acetamiprid (ppm)

	16.4

	17.2

	8.15

	8.45

	16.5

	16.7

	13.6

	14.0

	9.32

	9.78

	0.24

	0.15

	0.07

	0.51

	0.42

	0.23

	0.68

	0.45

	0.21

	1.47

	1.21

	0.62

	0.2

	0.12

	0.06

	0.38

	0.26

	0.15

	0.54

	0.38

	0.18

	1.1

	0.67

	0.38

	37.7

	40.9

	22.5

	23.6





Figure I- 4.  Lognormal probability plot of acetamiprid field trial data
for tea.



Figure I- 5.  Tolerance spreadsheet summary of acetamiprid field trial
data for tea.

Acetamiprid              Summary of Analytical Chemistry and Residue
Data	                       DP#s:  364833 & 366269   

Page   PAGE  1  of   NUMPAGES  38 

Acetamiprid	Summary of Analytical Chemistry and Residue Data	DP#: 
364833

N

N

C

H

3

Cl

C

H

3

N

C

N

N

N

H

Cl

C

H

3

N

C

N

N

N

H

Cl

C

H

3

N

O

N

H

2

