 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF

CHEMICAL SAFETY AND

POLLUTION PREVENTION

MEMORANDUM

Date:	   January 4, 2011 

SUBJECT:	Fluazifop-P-Butyl.  Amended Section 3 Registration Request to
Add New Uses on Bananas, Citrus, Grapes, and Sugar Beets.  Summary of
Analytical Chemistry and Residue Data. 

PC Code:  122809	DP Barcode:  385205

Decision No.:  421334	Registration No.:  100-1001

Petition No.: 9F7624	Regulatory Action: New Use Registration

Risk Assessment Type: NA	Case No.: 2285

TXR No.: NA	CAS No.: 79241-46-6

MRID No.: Summary Table Provided Below 	40 CFR: 180.411



FROM:	Peter Savoia, Chemist

	Risk Assessment Branch V

	Health Effects Division (7509P)

THRU:	William H. Donovan, Ph.D., Chemist

	Risk Assessment Branch V

	Health Effects Division (7509P)

	

TO:	Kathryn Montague/Michael Walsh, RM 23

	Herbicide Branch 

	Registration Division (7505P)

		

MRID Summary Table

MRID No.	Study Type	Comments

47874601	860.1500 (banana)	47874601.der.doc

47874602	860.1500 (citrus)	47874602.der.doc

47874603	860.1500 (sugar beet)	47874603.der.doc

47874604	860.1500 (grapes)	47874604.der.doc

47874605	860.1520 (grapes)	47874605.der.doc

47874606	860.1520 (sugar beet)	47874606.der.doc



This memorandum revises the August 31, 2010 version (D380017) by
refining the recommended fluazifop-P-butyl tolerance level for the dried
pulp citrus processed commodity.  

The initial memorandum was prepared by Versar, reviewed by the Health
Effects Division (HED), and revised as needed for correctness, language
and to reflect current Office of Pesticide Programs (OPP) policies.

Prior actions made to develop the fluazifop-P-butyl herbicide active
ingredient (ai) have identified a number of studies that are required
for completing data gaps.  In accordance, a number of Data Call-In (DCI)
submissions have been provided by the registrant in order to satisfy
these database requirements.  These studies are as follows:

• Carrot and endive nature of residue studies, test guideline
860.1300. 

• Ruminant and poultry nature of residue studies, test guideline
860.1300. 

• Radiovalidation study made for the tolerance enforcement method
proposed for analyzing plants,                         test guideline
860.1340. 

• Method validation study made for the tolerance enforcement method
proposed for analyzing poultry, eggs and livestock, test guideline
860.1340.

• Cattle and poultry feeding studies, test guideline 860.1480.

• Confined rotational crop study, test guideline 860.1850. 

An assessment of these studies is currently in progress and will be
addressed in a separate memorandum in due course.  Should the results of
the studies submitted in response to the registration DCI impact the
conclusions reached in the present document, appropriate changes will be
made at that time.  No further discussion of these in review studies
will be included in this memorandum.

Executive Summary

  SEQ CHAPTER \h \r 1 Fluazifop-P-butyl
[(R)-2-(4-((5-(trifluoromethyl)-2-pyridinyl)oxy)phenoxy)propanoic acid,
butyl ester] is a selective herbicide registered for postemergence
control of perennial and annual grass weeds.  It   SEQ CHAPTER \h \r 1
is the resolved isomer (R enantiomer) of fluazifop-butyl
[(R,S)-2-(4-((5-(trifluoromethyl)-2-pyridinyl)oxy)phenoxy) propanoic
acid, butyl ester].  After application fluazifop-P-butyl is rapidly
hydrolyzed to fluazifop acid (R enantiomer) where it accumulates in the
meristems of grass weeds working to interrupt lipid synthesis in
susceptible plants.  Fluazifop-P-butyl end-use products are registered
in the United States to Syngenta Crop Protection, Inc. under the trade
names Fusilade®, Fusion®, Oramec®, Tornado®, and Typhoon®.   

This herbicide active ingredient is the resolved isomer (R enantiomer)
of fluazifop-butyl (PC code 122805) which has since been cancelled
resulting in only fluazifop-P-butyl to be supported for re-registration.
 The Residue Chemistry Chapter of the   SEQ CHAPTER \h \r 1
Fluazifop-P-Butyl TRED (referred to herein as the Residue Chapter) was
issued on August 17, 2005 (DP No. 319907, S. L. Kinard, 08/17/2005).  It
provided   SEQ CHAPTER \h \r 1 the Residue Chemistry Assessments that
went into the “Report on FQPA Tolerance Reassessment Progress and
Interim Risk Management Decisions (TRED) for fluazifop-P-butyl.”

In the current petition, Syngenta Crop Protection, Inc. requests the
establishment of permanent tolerances for the residues of
fluazifop-P-butyl in/on the following crop and processed commodities:

Banana	0.01 ppm

Citrus (whole fruit)	0.05 ppm

Citrus (dried pulp)	0.40 ppm

Citrus (oil)	0.05 ppm

Citrus (juice)	0.05 ppm

Grapes	0.01 ppm

Sugar beet (root)	0.25 ppm

Sugar beet (top)	1.5 ppm

Sugar beet (dried pulp)	1.0 ppm

Sugar beet (molasses)	3.5 ppm

The end-use product relevant for this petition request is Fusilade® DX
Herbicide (EPA Reg. No. 100-1070), an emulsifiable concentrate
formulation containing 24.5% ai of fluazifop-P-butyl (equivalent to 2 lb
ai/gal).  The petitioner wishes to amend the product label for
Fusilade® DX Herbicide to add new uses on banana, citrus, grapes, and
sugar beets.  Fusilade® DX Herbicide is proposed for multiple foliar or
vineyard/orchard floor applications at maximum seasonal rates of 1.125
lb ai/A for bananas, grapes, and citrus and 0.75 lb ai/A for sugar
beets.  Applications are to be made with an adjuvant using ground or
aerial equipment.  The proposed Pre-Harvest Intervals (PHIs) for the
requested new uses range from 0 days on treatments made to bananas up to
90 days for sugar beet applications.

Fluazifop-butyl isomers are List B chemicals with parent and
fluazifop-acid (free and conjugated) regulated for tolerance expression
as the residues of concern used to determine misuse (DP No. D319907, S.
L. Kinard, 08/17/2005).  Its registered uses include dry beans, carrot,
cotton, endive (escarole), macadamia nut, onion, peanut, pecan, soybean,
spinach, stone fruit, and sweet potato.  It also carries tolerances with
regional registrations on asparagus, coffee, pepper, and rhubarb along
with being registered for use on lawns as a weed control application.
Tolerances are established under 40 CFR §180.411(a) for residues of the
herbicide fluazifop-P-butyl which include both the free and conjugated
forms of its resolved isomer expressed as fluazifop.  There are no
Section 18 emergency exemptions in effect but fluazifop-P-butyl
tolerances are likewise established under 40 CFR §180.411(c) which
carry regional restrictions expressed as fluazifop. 

The nature of the residue in both plants and livestock cannot yet be
described as adequately understood.  For the current action, an
acceptable soybean metabolism study is available, and the soybean
metabolism study will also support the proposed uses on the other crops
addressed herein.  The Metabolism Assessment Review Committee (MARC)
concluded that the residues of concern for tolerance expression for
plants and animals are parent and fluazifop-acid (free and conjugated)
since they are adequate to determine misuse.  The MARC also concluded
that the residues of concern in plants for risk assessment are parent,
fluazifop-acid (free and conjugated), 5-trifluoromethyl-2-pyridone, and
2-(4-hydroxyphenoxy) propionic acid (free and conjugated).  The residues
of concern in animals for risk assessment are parent and fluazifop-acid
(free and conjugated) (DP No. D298939, S. L. Kinard, 6/22/2004).

There are adequate residue analytical methods listed in PAM II for
tolerance enforcement and data collection.    SEQ CHAPTER \h \r 1 For
the enforcement of tolerances for fluazifop-P-butyl residues of concern,
a High Performance Liquid Chromatography/Ultra-Violet Spectrometry
(HPLC/UV) method is available for crop commodities.  In conjunction,
HPLC/UV and Gas Chromatography/Mass Spectrometry (GC/MS) methods are
available for milk and animal commodities.  The stated quantitation
limits are 0.02-0.05 ppm for crop commodities, 0.01 ppm for milk, and
0.02 ppm for animal tissues.  In addition, the FDA PESTDATA database
dated 11/01 (PAM Volume I, Appendix I) indicates that fluazifop-butyl
(only) is completely recovered using Multiresidue Methods Sections 302
(Luke Method; Protocol D) and 303 (Mills, Onley, and Gaither Method;
Protocol E, nonfatty food).  

To support this petition, the field trial samples were analyzed for
residues of total fluazifop (fluazifop-P-butyl, fluazifop free and
conjugated) using either a GC/MS or Fluorine-19 Nuclear Magnetic
Resonance (19F NMR) protocol.  These procedures provide a total
determination by hydrolyzing the fluazifop ester or acid conjugates and
then derivatizing them to form the fluazifop methyl ester for
quantitation with residues being reported as fluazifop.  The protocols
are adequate for data collection based upon acceptable method validation
and concurrent method recoveries.

The current petition requests the establishment of tolerances on dried
pulp citrus and sugar beet tops, commodities which have been considered
livestock feedstuffs.   Following revision of the Table 1 Feedstuffs in
2008, sugar beet tops were removed as being a significant feed item, and
thus it no longer contributes to the dietary burden of cattle.  The
potential contribution of citrus dried pulp to the livestock dietary
burden was considered by assuming a concentration factor of 13x and
comparing the resulting residue contribution to that of soybean hulls,
the current roughage component in the dietary burden calculation.  Since
soybean hulls has a higher tolerance than the recommended tolerance
level of dried pulp citrus, the current tolerances on meat, milk,
poultry, and eggs are considered adequate and should remain unchanged. 
This conclusion should be re-examined upon receipt of the requested
processing study for citrus.      

The submitted field trial data for bananas are adequate.  The field
trials were conducted according to the proposed use rate and PHI.  The
maximum residues of total fluazifop were less than the 0.01 ppm Limit of
Quantitation (LOQ) in/on bananas harvested 0 days after the last of
three broadcast applications.  For this application program, treatments
were made using the 2 lb/gal Emulsifiable Concentrate (EC) formulation
applied at ≈1x the proposed seasonal use rate to the soil.  Based on
the LOQ, the best estimate for a tolerance for bananas is 0.01 ppm.

≈1x to 2x the proposed seasonal use rate.  Based on the LOQ, the best
estimate for a tolerance for citrus is 0.03 ppm.

≈1x the proposed seasonal use rate.  Based on the LOQ, the best
estimate for a tolerance for grapes is 0.01 ppm.

≈1x the proposed seasonal use rate.  The residue data for sugar beet
roots 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.  The
spreadsheet provides a best estimate of a tolerance at 0.25 ppm for the
sugar beet roots.  With regards to sugar beet tops, no tolerance is
needed for this commodity since it is no longer considered a significant
feed item.

The submitted sugar beet and grape processing studies are acceptable. 
For sugar beets, total fluazifop residues concentrated in dried pulp
(processing factor of 3.9x) and molasses (14x) but do not appear to
concentrate in refined sugar (0.36x).  For grapes, total fluazifop
residues do not appear to concentrate in raisins or juice (<1x).  This
data along with the sugar beet root HAFT (0.22 ppm), indicate that a
tolerance is needed for fluazifop-P-butyl residues of concern in sugar
beet dried pulp at 1.0 ppm and molasses at 3.5 ppm.  No tolerances are
needed for the sugar beet refined sugar or the grape processed
commodities.

As was previously concluded by the Agency (DEB No. 6343, M. J. Bradley,
08/15/1990), the submitted citrus processing study is not acceptable. 
Given the age of the original submission, the petitioner should provide
a new study.  While the processing study is conducted, tolerances for
citrus processed commodities should be set based on maximum theoretical
concentration factors for the appropriate fractions:  2x for juice and
1000x for oil.  These factors along with the citrus HAFT of 0.03 ppm,
indicate that fluazifop-P-butyl tolerance levels for citrus juice and
oil should be 0.06 and 30.0 ppm, respectively.  With regard to dried
pulp citrus, there is no theoretical concentration factor determined for
this processed commodity.  However, in a recent chlorantraniliprole
review, an examination of 27 pesticides having dried pulp citrus
tolerances was made to determine a practical maximum concentration
factor (DP No. D361791, D. Rate, 01/08/2010).  This review found
concentration factors range between 2-13x for dried pulp citrus. 
Therefore, using the practical maximum concentration factor of 13x for
fluazifop along with the citrus HAFT of 0.03 ppm, a resulting tolerance
of 0.40 ppm should be set for dried pulp citrus.    

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

Provided the petitioner submits a revised Section F, HED concludes that
the residue chemistry database supports a conditional registration and
establishment of permanent tolerances for the proposed new uses of
fluazifop-P-butyl.  Tolerances are to be established for residues of the
herbicide fluazifop-P-butyl, including its metabolites and degradates,
in or on the commodities listed below.  Compliance with the tolerance
levels specified below is to be determined by measuring only the sum of
fluazifop-P-butyl,
butyl(R)-2-[4-[[5-(trifluoromethyl)-2-pyridinyl]oxy]phenoxy]propanoate,
and the free and conjugated forms of the resolved isomer of fluazifop,
(R)-2-[4-[[5-(trifluoromethyl)-2-pyridinyl]oxy]phenoxy]propanoic acid,
calculated as the stoichiometric equivalent of fluazifop, in or on the
commodity.

Banana	0.01 ppm

Fruit, citrus, group 10-10	0.03 ppm

Citrus, oil	30.0 ppm

Citrus, dried pulp	0.40 ppm

Citrus, juice	0.06 ppm

Grape	0.01 ppm

Sugar, beet, root	0.25 ppm

Sugar, beet, dried pulp	1.0 ppm

Sugar, beet, molasses	3.5 ppm

An unconditional registration may be appropriate upon determination of
the adequacy of a new citrus processing study (see requirements under
Processed Food and Feed).  A revised human-health risk assessment which
includes these new crop uses is forthcoming in a separate document
(D385178).

860.1520 Processed Food and Feed

As was previously concluded by the Agency (DEB No. 6343, M. J. Bradley,
08/15/1990), the submitted citrus processing study is not acceptable. 
Given the age of the original submission, the petitioner should provide
a new study.

860.1550 Proposed Tolerances

The proposed tolerances should be revised to reflect the recommended
tolerance levels and correct commodity definitions as specified in Table
8.  

Background

Fluazifop-P-butyl
[(R)-2-(4-((5-(trifluoromethyl)-2-pyridinyl)oxy)phenoxy)propanoic acid,
butyl ester] is a selective herbicide used for the post-emergence
control of perennial and annual grass weeds.  It is the resolved isomer
(R enantiomer) of fluazifop-butyl (PC code 122805) which has since been
cancelled resulting in only fluazifop-P-butyl to be supported for
re-registration.  The fluazifop-butyl isomers are List B chemicals with
parent and fluazifop-acid (free and conjugated) regulated for tolerance
expression as the residues of concern used to determine misuse (DP No.
D319907, S. L. Kinard, 08/17/2005).  T  SEQ CHAPTER \h \r 1   SEQ
CHAPTER \h \r 1 he Phase 4 Reviews for fluazifop-butyl and
fluazifop-P-butyl were completed on 02/26/1991.  The subsequent Phase 5
review of these studies has also been completed.  This includes the
Residue Chemistry Science Assessments with respect to the Report on FQPA
Tolerance Reassessment Progress and Interim Risk Management Decisions
(TRED) for fluazifop-P-butyl issued on 08/17/2005.  For review, the
chemical structure and nomenclature of fluazifop-P-butyl, including its
free acid fluazifop-P as well as the physicochemical properties of the
technical grade of fluazifop-P-butyl are presented below in Tables 1 and
2.   

 

Common name	Fluazifop-P (free acid)

Chemical name	  SEQ CHAPTER \h \r 1
(R)-2-(4-[5-(trifluoromethyl-2-pyridinyl)oxy]phenoxy)propionic acid



Table2.   Physicochemical Properties of Fluazifop-P-butyl. 

Parameter	Value	Reference1

Melting point/range	  SEQ CHAPTER \h \r 1 Decomposes at 210 ºC

164 ºC at 0.02 mm Hg	  SEQ CHAPTER \h \r 1 2002 Farm Chemicals Handbook

RCB No. 1674, 2/3/87, L. Cheng

pH	  SEQ CHAPTER \h \r 1 Not dispersible in water	  SEQ CHAPTER \h \r 1
RCB No. 1674, 2/3/87, L. Cheng

Density	  SEQ CHAPTER \h \r 1 1.22 g/cc (PAI) and 1.20 g/cc (T) at 20
ºC	  SEQ CHAPTER \h \r 1 RCB No. 809, 6/3/86, L. Cheng

Water solubility	  SEQ CHAPTER \h \r 1 1 mg/L	  SEQ CHAPTER \h \r 1 RCB
No. 1674, 2/3/87, L. Cheng

Solvent solubility	  SEQ CHAPTER \h \r 1 Soluble in most organic
solvents

>500 g/L in acetone, dichloromethane, ethyl acetate, hexane, methanol,
toluene, and xylene	  SEQ CHAPTER \h \r 1 2002 Farm Chemicals Handbook

RCB No. 1674, 2/3/87, L. Cheng

Vapor pressure	  SEQ CHAPTER \h \r 1 3 x 10-8 KPa at 20 ºC	  SEQ
CHAPTER \h \r 1 RCB No. 809, 6/3/86, L. Cheng

Dissociation constant, pKa	  SEQ CHAPTER \h \r 1 -3.1 (by calculation)	 
SEQ CHAPTER \h \r 1 RCB No. 809, 6/3/86, L. Cheng

Octanol/water partition coefficient, Log(KOW)	  SEQ CHAPTER \h \r 1 4.5
at 20 ºC	  SEQ CHAPTER \h \r 1 RCB No. 809, 6/3/86, L. Cheng

UV/visible absorption spectrum	  SEQ CHAPTER \h \r 1 Not available

	1DP No. D348246, D. Soderberg, 09/16/2008

860.1200  Directions for Use

A summary of the proposed/amended use patterns for bananas, citrus,
grapes and sugar beets is presented in Table 3.  The information
presented in Table 3 was obtained from a specimen label provided by
Syngenta for the Fusilade® DX Herbicide (EPA Reg. No. 100-1070).

Table 3.  Summary of Directions for Use of Fluazifop-P-butyl.

Commodity	Trade Name (EPA Reg. No.)	Application Timing, Type, and
Equipment	Application Rate

(lb ai/A)	Maximum Number Applications per Season	Maximum Seasonal
Application Rate

(lb ai/A)	PHI

(days)	Use Directions and Limitations

Bananas	Fusilade® DX (100-1070)	Ground and aerial	0.375	3	1.125	0 days
RTI:  30 days

Citrus

Ground and aerial	0.375	3	1.125	14 days	RTI: 21 days

Grapes

Ground and aerial	0.375	3	1.125	50 days	RTI: 14 days

Sugar beet

Ground and aerial	0.375	2	0.75	90 days	RTI: 14 days

Do not enter or allow worker entry into treated areas during the
restricted entry interval (REI) of 12 hours following application.  



The general label use directions specify that:  (1) adjuvants (crop oil
concentrate, non-ionic surfactant, or other approved adjuvants) plus
liquid nitrogen fertilizer may be used on soybeans; (2) ground and
aerial applications are to be made in a minimum of 5 gal/A; (3) for
chemigation (sprinkler irrigation), adjuvants are not to be used in the
manner described for use in conventional applications or applied with a
system connected to a public water system; and (4) the restricted-entry
interval is 12 hours.  Rotational grass crops such as corn, sorghum and
cereals are not to be planted within 60 days of last application.

Conclusions:  The label directions are adequate to allow evaluation of
the residue data relative to the proposed use.  There are no aerial
application restrictions specified on the label.  For the banana,
citrus, and grape field trials that were conducted, treatment was made
to the orchard/vineyard floor below the plant canopy which is not an
aerial application method.

860.1300 Nature of the Residue - Plants

Residue Chemistry Memo, DP No. D319907, 08/17/2005, S. L. Kinard (TRED
Residue Chemistry Chapter)

HED MARC Decision Memo, DP No. D298939, 06/22/2004, S. L. Kinard

The Fluazifop-P-Butyl Residue Chapter of the TRED (DP No. 319907, S. L.
Kinard, 08/17/2005) concluded that the nature of the residue in soybeans
is adequately understood.  No new plant metabolism studies for the
proposed new use crops were submitted as part of the current petition. 
The MARC has determined that for tolerance expression, parent and
fluazifop-acid (free and conjugated) are the residues of concern since
they are adequate to determine misuse.  The MARC also concluded that the
residues of concern in plants for risk assessment are parent,
fluazifop-acid (free and conjugated), 5-trifluoromethyl-2-pyridone, and
2-(4-hydroxyphenoxy) propionic acid (free and conjugated).  

860.1300 Nature of the Residue - Livestock

The MARC has concluded that for tolerance expression and risk
assessment, parent and fluazifop-acid (free and conjugated) are the
residues of concern since they are adequate to determine misuse.   SEQ
CHAPTER \h \r 1 

860.1340 Residue Analytical Methods

Residue Chemistry Memo, DP No. D319907, 08/17/2005, S. L. Kinard (TRED
Residue Chemistry Chapter)

Enforcement methods

  SEQ CHAPTER \h \r 1 For the enforcement of tolerances for
fluazifop-P-butyl residues of concern, PAM Vol. II lists two methods,
Method I for animal tissues and milk and Method II for oily and non-oily
crops.  The stated detection limits are 0.02-0.05 ppm for crops, 0.01
ppm for milk, and 0.02 ppm for animal tissues.  In Method I, samples
(except fat) are extracted with acetonitrile/acetone/hexane, which
separates residues of fluazifop and fluazifop-butyl (found in the
acetonitrile/acetone layer) from residues of fluazifop lipophilic
conjugates (found in the hexane layer).  Fluazifop and fluazifop-butyl
are determined in milk using an HPLC/UV instrumental technique.  In
tissue samples, fluazifop-butyl is converted to fluazifop via
hydrolysis, and then its residues are methylated using diazomethane, and
determined by GC/MS.  Fluazifop lipophilic conjugates (for both milk and
tissue samples) are cleaned up by florisil chromatography, hydrolyzed to
fluazifop, and determined by HPLC/UV.  For fat, samples are extracted
with chloroform/methanol at reflux (2 hours) and residues of fluazifop,
fluazifop-butyl, and lipophilic conjugates are hydrolyzed to fluazifop,
methylated, and determined by GC/MS.

For Method II, residues of fluazifop-butyl, fluazifop, and any ester or
acid conjugates are extracted from crop samples using acetonitrile and
hydrochloric acid.  Residues are then hydrolyzed to fluazifop and
cleaned up using a coagulation procedure, solvent partitioning, and
silica column chromatography for determination by HPLC/UV.  Residues may
be confirmed by GC/MS following methylation with diazomethane. 
Consequently, neither of the enforcement methods distinguishes the
optical isomers of fluazifop-butyl or fluazifop.

  SEQ CHAPTER \h \r 1 Data collection methods

Samples collected from the crop field trial and processing studies were
analyzed for residues of fluazifop using either a GC/MS method or a 19F
NMR method.  The GC/MS methods used were Method 45820-M-1 by Zeneca
(bananas in MRID No. 47874601) and Method RR 91-014B by Zeneca (grapes
in MRID Nos. 47874604 & 47874605, sugar beet in MRID Nos. 47874603 &
47874606, and citrus in MRID No. 47874602).  The 19F NMR method used was
based on Plant Protection Division Analytical Method no. 83 and was
employed for analyzing a portion of the citrus studies that were
provided (citrus in MRID Nos. 41373705 & 41373706).  In all, these
methods are based on the protocols listed in PAM Vol. II, Method II. 
These procedures work by hydrolyzing the target analytes
(fluazifop-P-butyl, fluazifop, and any ester or acid conjugates) to a
common moiety (fluazifop acid) for quantitation with residues being
reported as fluazifop equivalents.  

For the GC/MS method used on bananas, residues are extracted from crop
samples using a mixture of acetonitrile and dilute acid, hydrolyzed to
fluazifop using hydrochloric acid, and cleaned up on a silica SPE
cartridge.  Residues are derivatized to form the methyl ester of
fluazifop prior to GC/MS quantitation.  In regard to the GC/MS method
used on grapes, sugar beet and citrus, residues are extracted from crop
samples using a mixture of acetonitrile and dilute acid.  Residues are
then hydrolyzed to fluazifop using hydrochloric acid, and cleaned up by
solvent partitioning and adsorption chromatography.  Residues are
derivatized to form the methyl ester derivative of fluazifop prior to
GC/MS quantitation.  For the 19F NMR method used on citrus, residues are
extracted from crop samples using a mixture of acetonitrile and
concentrated hydrochloric acid, hydrolyzed to fluazifop using
hydrochloric acid, and cleaned up by solvent partitioning.  Residues are
derivatized to form the methyl ester of fluazifop prior to 19F NMR
quantitation.  

Adequate method verification analyses were made prior to the
determination of the field samples using fluazifop-P-butyl and
fluazifop-P fortified sugar beet tops (0.01 and 10 ppm), sugar beet
roots (0.01 and 1.0 ppm), and grapes (0.01 and 1.0 ppm).  In addition,
acceptable concurrent method recoveries were obtained for
fluazifop-P-butyl from fortified samples of bananas at 0.01 and 0.5 ppm,
sugar beet root, dried pulp, and refined sugar at 0.01 and 1.0 ppm,
sugar beet tops at 0.01 and 10.0 ppm, and grapes, grape juice and
raisins at 0.01 and 1.0 ppm.  For sugar beet molasses, acceptable
concurrent method recoveries were obtained for fluazifop-P-butyl from
samples fortified at 0.01 and 10.0 ppm.  However, the average concurrent
recovery for sugar beet molasses was slightly below the generally
acceptable range of 70 to 120% at the 15.0 ppm fortification level. 
Similarly, for citrus study MRID No. 47874602, acceptable concurrent
method recoveries were obtained for fluazifop-P-butyl from samples
fortified at 0.01 ppm.  However, average concurrent recovery was
slightly below the generally acceptable range of 70 to 120% for the
citrus samples analyzed at the 1.0 ppm.  For citrus studies MRID Nos.
41373705 and 41373706, acceptable concurrent method recoveries were
obtained for fluazifop-P-butyl from samples fortified at 0.05 ppm (whole
fruit and processed commodities) and 1.0 ppm (whole fruit only).  The
fortification levels are adequate to bracket expected residue levels of
total fluazifop in banana, citrus, grape, and sugar beet matrices,
except for the processed citrus commodities in which residues for
chopped peel, dried pulp, molasses, and oil were higher than the
fortification level.

Conclusions:  The existing GC/MS enforcement methods, or the modified
versions, are adequate for collecting data on residues of
fluazifop-P-butyl and fluazifop in/on banana, citrus, grape, and sugar
beet commodities.  The method will be adequate for tolerance enforcement
purposes for these commodities.  

860.1360 Multiresidue Methods

Residue Chemistry Memo, DP No. D319907, 08/17/2005, S. L. Kinard (TRED
Residue Chemistry Chapter)

  SEQ CHAPTER \h \r 1 The FDA PESTDATA database dated 11/01 (PAM Volume
I, Appendix I) indicates that fluazifop-butyl is completely recovered
using Multiresidue Methods Sections 302 (Luke Method; Protocol D) and
303 (Mills, Onley, and Gaither Method; Protocol E, nonfatty food);
recovery using Section 304 (Mills Method; Protocol F, fatty food) is
variable.

860.1380 Storage Stability

48412503.der.doc D. Soderberg  Storage Stability of Residues of various
crops and Processed Fractions Stored for up to 18 Month in Deep Freeze

Storage stability data have been reviewed in conjunction with earlier
actions undertaken for fluazifop-P-butyl which indicate that its
residues are stable in a number of crop commodities.  As such, its
stability has been investigated in a wide variety of frozen crop
commodities and documented in several prior reports generated by
Syngenta.  These reports demonstrate that residues of fluazifop are
stable in/on soybeans, sugar beets, green beans, strawberries, oilseed
rape, coffee, cauliflower, onions, potatoes, peanuts, macadamia nuts,
tomatoes, endive, and celery for durations of 3 to 28 months (DP No.
D348246, D. Soderberg, 09/16/2008).  Given the results obtained from
these prior studies, this data is adequate in directly supporting or can
be translated to corroborate the sample storage intervals incurred in
these field trials.  Although no data were provided to substantiate the
holding times that were incurred for many of the processed commodities
tested, none are needed since these analyses were made within thirty
(30) days of production.  A summary of the storage durations and
conditions of the samples from the crop field trials and processing
studies provided to support this petition are presented below in Table 4
for review.  

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

Matrix 	MRID	Storage

Temperature (°C) 1	Actual Storage

Duration2	Interval of Demonstrated

Storage Stability

Banana	47874601	≤ -20	217 to 282 days

(7.2 to 9.4 months)	None. Up to 28 months in a variety of crops at
-20ºC ± 10ºC.

Citrus	47874602	< 0	24 to 71 days

(0.77 to 2.4 months)	None. Up to 28 months in a variety of crops at
-20ºC ± 10ºC.

	41373705	<-18	456 to 686 days

(16 to 25 months)

	Citrus (for processing)	41373706	<-18	589 days (21 months)

	Citrus, dried pulp	41373706	<-18	591 days (21 months)

	Citrus, oil	41373706	<-18	654 days (23 months)

	Citrus, juice	41373706	<-18	592 days (21 months)

	Grapes	47874604	< 0	8 to 45 days

(0.25-1.5 months)	None. Up to 28 months in a variety of crops at -20ºC
± 10ºC.

Grapes (for processing)	47874605	< 0	36 days (1.2 months)

	Grape, juice	47874605	< 0	29 days (1.0 months)	None. Storage stability
data is not required because the samples were extracted/analyzed within
approximately 30 days from processing. 3

Grape, raisins	47874605	< 0	43 days (1.4 months)

	Sugar beet, top	47874603	< 0	9-75 days

(0.25-2.5 months)	None. Up to 28 months in a variety of crops at -20ºC
± 10ºC.

Sugar beet, root	47874603	< 0	9-75 days

hen ≤-15oC until analysis.

2 Actual storage duration is from harvest to extraction. 

3 For grapes, the storage duration between processing and extraction was
33 days for grapes, 26 days for grape juice, and 30 days for raisins.

4 For sugar beets, the storage duration between processing and
extraction was 28 to 31 days for molasses, 32 days for sugar beet roots,
32 to 33 days for dry pulp, and 33 days for refined sugar. 

and then at ≤-15ºC until analysis at the laboratory (except bananas
which were stored at the laboratory at <-20ºC).  

860.1400 Water, Fish, and Irrigated Crops

For the purpose of this summary, this guideline requirement is not
relevant to this evaluation since   SEQ CHAPTER \h \r 1
Fluazifop-P-butyl has no registered or proposed uses on water or aquatic
food and feed crops.

860.1460 Food Handling

For the purpose of this summary, this guideline requirement is not
relevant to this evaluation since   SEQ CHAPTER \h \r 1
Fluazifop-P-butyl has no food-handling uses which are being proposed.

860.1480 Meat, Milk, Poultry, and Eggs

Residue Chemistry Memo, DP No. D348246, 09/16/2008, D. Soderberg
(PP#7F7289 Residue Chemistry Chapter)

In evaluating the data provided to support this petition, the
establishment of tolerance limits will be recommended for several RACs
commonly recognized for use as livestock feedstuffs.  This would include
establishing tolerance limits for citrus dried pulp and sugar beet tops
which are requested in part with this action.  The maximum theoretical
dietary burdens to livestock were previously evaluated in the prior
residue chemistry chapter prepared to support pending uses on dry beans
and peanuts (DP No. D348246, D. Soderberg, 09/16/2008).  The resulting
theoretical dietary burdens of fluazifop-P-butyl to livestock were put
forward with the updated version of Table 1 (Table 1 Feedstuffs June
2008) and are presented below in Table 5 for review.

Table 5.   Calculation of Dietary Burdens of Fluazifop-P-butyl Residues
to Livestock.

Feedstuff	Type1	% Dry Matter2	% Diet2	Recommended Tolerance (ppm)
Dietary Contribution (ppm)3

Beef Cattle

Soybean, hulls	R	90	20	2.5	0.555

Untreated CC	CC	NA	65	NA	0

Soybean, meal	PC	92	15	2.5	0.408

TOTAL BURDEN	--	--

--	0.963

Dairy Cattle

Soybean, hulls	R	90	15	2.5	0.417

Untreated R	R	NA	30	NA	0

Carrot, culls	CC	12	10	2.0	1.667

Untreated CC	CC	NA	35	NA	0

Soybean, seed	PC	89	15	2.5	0.421

TOTAL BURDEN	--	--

--	2.505

Poultry

Untreated CC	CC	NA	75	NA	0

Soybean, meal	PC	--	25	2.5	0.625

TOTAL BURDEN	--	--

--	0.625

Swine

Untreated CC	CC	NA	85	NA	0

Soybean, meal	PC	--	15	2.5	0.375

TOTAL BURDEN

	--	--	0.375

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

2  OPPTS 860.1000 Table 1 Feedstuffs (June 2008).  

3  Contribution = ([tolerance /% DM] X % diet) for beef and dairy
cattle; contribution = ([tolerance] X % diet) for poultry and swine. 

4  N/A:  Not applicable.  Tolerances/uses of Fluazifop-P-butyl have not
been registered or proposed for this feedstuff. 

These calculations are considered tentative because plant and animal
metabolism studies remain outstanding and additional field trials are
required for some crops.  It was also noted that there are label
restrictions against the grazing or harvesting of peanut hay as well as
soybean forage and hay which are appropriate according to Table 1 of
860.1000.  In all, the addition of the use on peanut did not affect the
theoretical dietary burden of fluazifop residues to livestock.  Soybeans
were found to have a larger impact and these matrices were incorporated
into the previous dietary burden calculations.  The effect of use on
cowpea forage and hay along with residues on the soybean aspirated grain
fractions will be evaluated after these data have been submitted.  Prior
calculated dietary burden maximums of fluazifop-P-butyl were reported to
beef/dairy cattle at 4.49 ppm, 1.00 ppm to poultry, and 0.70 ppm to
swine.  These differ significantly from the updated values presented in
Table 5 due to the current calculations being based on a “reasonably
balanced” diet and the reduction in the diet percentage for carrot
culls.

  

Nonetheless, in assessing the new uses pursuant to this petition, sugar
beet tops are no longer a contributor to the dietary burden of cattle
because when updating the Table 1 Feedstuffs it was removed as being a
significant feed item.  Although in the assessment of prior actions
sugar beet tops would have comprised a large portion of the beef and
dairy cattle diet, it is no longer a factor for consideration in the
calculation of dietary burden.  With regards to dried pulp citrus, the
tolerance of this livestock feed item is being set based on a practical
maximum concentration factor of 13x.  In comparing the recommended
tolerance level of 0.40 ppm for this commodity to the 2.5 ppm tolerance
level of soybean hulls (roughage component) now in the dietary burden
calculation, no increase in the dietary burden to livestock results. 
Hence, the prior calculations for secondary transfer of
fluazifop-P-butyl residues to meat, milk, poultry, and eggs remain
current. 

Conclusions:  No change in the tolerances of meat, milk, poultry, and
eggs is needed at this time.  

860.1500 Magnitude of the Residue in Crops

DER References:  	47874601.der.doc (banana)

			47874602.der.doc (citrus)

			R062698.tif  (MRID 41373705) (citrus)

			47874603.der.doc (sugar beet)

			47874604.der.doc (grape)

Syngenta Crop Protection has submitted field trial data for
fluazifop-P-butyl on bananas, citrus, grapes, and sugar beets.  A
summary of the residue data is presented in Table 6.

Table 6.   Summary of Residue Data from Crop Field Trials with
Fluazifop-P-Butyl.

Crop matrix	Total Applic. Rate

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



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

Bananas (proposed use = 1.125 lb ai/A total application rate, 0-day PHI)

Banana, bagged	1.125	0	10	<0.01	<0.01	<0.01	<0.01	<0.01	N/A

Banana, unbagged	1.125	0	10	<0.01	<0.01	<0.01	<0.01	<0.01	N/A

Citrus (proposed use = 1.125 lb ai/A total application rate, 14-day PHI)

Orange	1.10 – 1.15	12-14	14	<0.012	<0.01	<0.01	<0.01	<0.01	N/A

	1.5	14	5	<0.033	<0.03	<0.03	<0.03	<0.03	N/A

	2.25	14	5	<0.03	<0.03	<0.03	<0.03	<0.03	N/A

Lemon	1.5	14	5	<0.03	<0.03	<0.03	<0.03	<0.03	N/A

	2.25	14	5	<0.03	<0.03	<0.03	<0.03	<0.03	N/A

Grapefruit	1.14	12-14	2	<0.01	<0.01	<0.01	<0.01	<0.01	N/A

	1.5	14	5	<0.03	<0.03	<0.03	<0.03	<0.03	N/A

	2.25	14	5	<0.03	<0.03	<0.03	<0.03	<0.03	N/A

Grapes (proposed use = 1.125 lb ai/A total application rate, 50-day PHI)

Grapes	1.11 – 1.16	49-50	24	<0.01	<0.01	<0.01	<0.01	<0.01	N/A

Sugar beets (proposed use = 0.75 lb ai/A total application rate, 90-day
PHI)

Sugar beet, top	0.747-0.764	89-90	24	0.02	1.45	1.01	0.390	0.425	0.277

Sugar beet, root	0.747-0.764	89-90	24	<0.01	0.23	0.215	0.070	0.080	0.051

1  HAFT = Highest average field trial result.

2  LOQ of the GC/MS method used for the quantitation of the sample
results noted.

3  LOQ of the 19F NMR method used for the quantitation of the sample
results noted.

Banana (MRID No. 47874601)

Five field trials were conducted in/on bagged and unbagged bananas in
the United States during the 1999 growing season.  The trials were
conducted in Zone 3 (1 trial in Florida) and Zone 13 (4 trials in
Hawaii).  For each trial, three applications of the 2 lb/gal EC
formulation of fluazifop-P-butyl were made at a target rate of 0.375 lbs
fluazifop-p-butyl/acre for a total seasonal rate of 1.125 lb a.i./acre. 
All applications were made in spray volumes of 17 to 29 gal/A (GPA)
using ground-based equipment.  An adjuvant was added to the spray
mixture for all applications (non-ionic surfactant or crop oil
concentrate).  Each test site consisted of a control and treated plot
for both bagged and unbagged bananas.  Applications were made by
broadcast spray to the soil at 60, 30, and 0 days prior to normal
harvest.  Banana whole fruit samples were collected at the normal
harvest which was immediately following the last application (PHI of 0
days).  

Residues of fluazifop-p-butyl, fluazifop, and conjugate esters in
bananas were determined as total fluazifop using ABC method 45820-M-1. 
This method is a modification of the Zeneca method entitled
“Determination of Total Fluazifop in Crops by Gas Chromatography.” 
The LOQ for total fluazifop residues was set at 0.01 ppm.  The method
was adequate for data collection based on concurrent method recoveries. 


Sample storage conditions and durations incurred for this study which
support this action are reported in Table 4.  No storage stability data
have been submitted for bananas specifically.  Nonetheless, the
stability of fluazifop-P-butyl has been investigated in a wide variety
of frozen crop commodities and documented in several prior reports
generated by the registrant.  These reports show residues are stable
in/on soybeans, sugar beets, green beans, strawberries, oilseed rape,
coffee, cauliflower, onions, potatoes, peanuts, macadamia nuts,
tomatoes, endive, and celery for durations of 3 to 28 months.

Following three applications of fluazifop-p-butyl at a seasonal target
application rate of 1.125 lbs ai/A, residue levels (reported as total
fluazifop) were below the LOQ (0.01 ppm) in all bagged and unbagged
samples of whole bananas (PHI of 0 days).  

	

Conclusions:  The submitted residue data for bananas are adequate in
fulfilling these data requirements.  The number and locations of the
field trials are in accordance with OPPTS Guideline 860.1500 for
bananas.  The trials were made to appropriately reflect the proposed
maximum seasonal use pattern.  Adequate stability data available for
other similar crops can be translated to substantiate the storage
conditions and durations that were incurred.  Based on the LOQ, the best
estimate for a tolerance for bananas is 0.01 ppm.

Citrus (MRID No. 41373705)

A total of fifteen field trials were conducted in the United States
during the 1986 growing season in/on oranges (n=5), grapefruit (n=5),
and lemons (n=5).  For oranges, 5 trials were conducted in Zone 3
(Florida).  For the grapefruit and lemons, 2 trials were conducted in
Zone 3 (Florida), 1 trial in Zone 6 (Texas), and 2 trials in Zone 10 (1
trial in California and 1 trial in Arizona).  For each trial, two
treated test plots were established.  One plot received three
applications of the 2 lb/gal EC formulation of fluazifop-P-butyl at a
target rate of 0.5 lbs fluazifop-p-butyl/acre for a total seasonal rate
of 1.5 lb ai/acre.  The other plot received three applications of the 2
lb/gal EC formulation of fluazifop-P-butyl at a target rate of 0.75 lbs
fluazifop-P-butyl/acre for a total seasonal rate of 2.25 lb ai/acre. 
The three applications were made at approximate 21 day re-treatment
intervals using ground equipment that directed the spray to the ground
beneath the trees.  Citrus fruit were harvested 14 days after the last
application.  

The analytical method used for data collection was ICI Plant Protection
Method 82.  The method performed extraction with
acetonitrile:concentrated HCl to convert residues to fluazifop.  The
procedure employed similar clean-up steps as those specified in PAM II
method, but final determination using this protocol is made by 19F NMR
analysis.  Residues in citrus were reported as total fluazifop.  The LOQ
for total fluazifop residues was set at 0.03 ppm.  This method is
adequate for data collection based upon acceptable concurrent recovery
data from oranges, grapefruit, and lemons fortified at 0.05 ppm and 1.0
ppm. 

Sample storage conditions and durations incurred for this study which
support this action are reported in Table 4.  Samples of citrus fruit
were analyzed within 25 months of harvest.  No storage stability data
have been submitted for citrus specifically.  Nonetheless, the stability
of fluazifop-P-butyl has been investigated in a wide variety of frozen
crop commodities and documented in several prior reports generated by
the registrant.  These reports show residues are stable in/on soybeans,
sugar beets, green beans, strawberries, oilseed rape, coffee,
cauliflower, onions, potatoes, peanuts, macadamia nuts, tomatoes,
endive, and celery for durations of 3 to 28 months.

Following the applications of fluazifop-p-butyl at a seasonal target
application rate of 1.5 lbs ai/A and at 2.25 lb ai/A, fluazifop-p-butyl
residues (reported as total fluazifop) were below the LOQ (0.03 ppm) in
oranges, grapefruit and lemon (PHI 14 days).  

Citrus (MRID No. 47874602)

A total of eight field trials were conducted in the United States during
the 2000 growing season in/on oranges (n=7) and grapefruit (n=1).  For
oranges, 3 trials were conducted in Zone 3 (Florida), 1 trial in Zone 6
(Texas), and 3 trials in Zone 10 (1 trial in Arizona; 2 trials in
California).  For grapefruit, 1 trial was conducted in Zone 3 (Florida).
 For each trial, three applications of the 2 lb/gal EC formulation of
fluazifop-P-butyl were made at a target rate of 0.375 lbs
fluazifop-P-butyl/acre for a total seasonal rate of 1.125 lb ai/acre. 
Each test site consisted of a untreated control and treated test plots. 
The three applications were made by broadcast spray to the orchard soil
beneath the trees, 19 to 21 days apart and citrus fruit were harvested
12 to 14 days after the last application (PHI of 12 to 14 days). 
Applications were made using ground equipment in 19 to 26 gal/A spray
volumes with an adjuvant (non-ionic surfactant or crop oil concentrate).

Residues of fluazifop-P-butyl and fluazifop-P were extracted by
hydrolyzing the ester or acid conjugates to fluazifop which are then
derivatized to the methyl ester and analyzed by GC/MS.  Residues in
citrus were reported as total fluazifop.  The LOQ for total fluazifop
residues was set at 0.01 ppm.  This method is adequate for data
collection based upon acceptable method validation recovery data in
grapes at the 0.01 ppm and 1.0 ppm fortification levels and concurrent
recovery data in citrus at the 0.01 ppm fortification level.  The
average concurrent recovery at the 1.0 ppm fortification level was only
68.4% which is slightly outside the generally acceptable range of 70 to
120%.  However, this is not a concern because the 0.01 ppm fortification
level more accurately reflects the residue levels in the RAC samples
than does the 1.0 ppm fortification level.

The samples were stored frozen from collection through analysis with the
storage conditions and durations incurred for this study being reported
in Table 4.  The maximum storage interval from sampling to extraction
was 71 days (2.4 months).  All sample extracts were analyzed within 1
day of extraction.  No storage stability data have been submitted for
citrus specifically.  Nonetheless, the stability of fluazifop-P-butyl
has been investigated in a wide variety of frozen crop commodities and
documented in several prior reports generated by the registrant.  These
reports show residues are stable in/on soybeans, sugar beets, green
beans, strawberries, oilseed rape, coffee, cauliflower, onions,
potatoes, peanuts, macadamia nuts, tomatoes, endive, and celery for
durations of 3 to 28 months.

Following 3 treatments of fluazifop-p-butyl at the seasonal application
rate of 1.125 lbs ai/A, residues (reported as total fluazifop) were
below the 0.01 ppm LOQ in oranges and grapefruit (12-14 day PHI).  

Conclusions:  By combining the 1986 and 2000 trials, the submitted data
are adequate in fulfilling the  test guideline requirements for citrus. 
The number and locations of the field trials follow OPPTS Guideline
860.1500 for citrus fruit crop group 10 (12 orange, 6 grapefruit & 5
lemon trials).  They generally reflect the proposed maximum seasonal use
pattern, although the trials made in 1986 (MRID No. 41373705) were
performed at a 1.3x and 2x greater rate.  Adequate stability data
available for other similar crops can be translated to substantiate the
storage conditions and durations that were incurred.  Based on the LOQ,
a 0.03 ppm tolerance is estimated for citrus and a revised section F
should be submitted specifying this recommend limit. 

Grapes (MRID No. 47874604)

Twelve field trials were conducted on grapes during the 2000 growing
season, encompassing Zone 1 (2 trials in NY), 10 (8 trials in CA), and
11 (1 trial in OR and 1 trial in WA).  Separate untreated control and
treated test plots were established at each trial site.  At each test
location, three broadcast spray applications of the 2 lb/gal EC
formulation of fluazifop-P-butyl were made to the vineyard floor beneath
the grape vines at a target application rate of 0.375 lb
ai/A/application, for a total target seasonal rate of 1.125 lb ai/A. 
Applications were made 12 to 15 days apart in spray volumes of 10 to 30
gal/A at 9 trial sites and 8 to 10 gal/A at 3 trial sites.  Adjuvants
(non-ionic surfactant or crop oil concentrate) were used at all the
sites and the grapes subsequently harvested at a PHI of 49-50 days.  

 

Samples of grapes were analyzed for total fluazifop residues
(fluazifop-P-butyl, fluazifop free and conjugated) using a GC/MS
protocol.  This procedure is a common moiety method which hydrolyzes any
ester or acid conjugates and treats the resulting extract to form the
methyl ester of fluazifop so that a total determination can be made. 
This method is adequate for data collection based upon acceptable method
validation and concurrent method recoveries.  The validated LOQ was 0.01
ppm for grapes. 

Sample storage conditions and durations incurred for this study which
support this action are reported in Table 4.  Samples were stored frozen
for a maximum duration of 45 days (1.5 months) from harvest to analysis.
 Samples from all but three sites were extracted within one month of
harvest.  All sample extracts were analyzed within 1 day of extraction. 
No storage stability data have been submitted for grapes specifically. 
Nonetheless, the stability of fluazifop-P-butyl has been investigated in
a wide variety of frozen crop commodities and documented in several
prior reports generated by the registrant.  These reports show residues
are stable in/on soybeans, sugar beets, green beans, strawberries,
oilseed rape, coffee, cauliflower, onions, potatoes, peanuts, macadamia
nuts, tomatoes, endive, and celery for durations of 3 to 28 months. 
Alternately, stability data are not required for samples that are stored
frozen for less than 30 days, which includes the majority of the samples
in this study.  As such, the available stability data support the sample
storage durations/conditions incurred for the crop field trials made on
grapes.

Residues of total fluazifop were <LOQ (0.01 ppm) in/on grapes harvested
49 to 50 days after the last of three vineyard floor applications of the
2 lb/gal EC formulation at a total rate of 1.11 to 1.16 lb ai/A/season. 


Conclusions.  The submitted residue data for grapes are adequate in
fulfilling these data requirements.  The trials were made to
appropriately reflect the proposed maximum seasonal use pattern. 
Adequate stability data available for other similar crops can be
translated to substantiate the storage conditions and durations that
were incurred.  Based on the LOQ, the best estimate for a tolerance for
grapes is 0.01 ppm.

Sugar beet (MRID No. 47874603)

Twelve field trials were conducted on sugar beets during the 2000
growing season, encompassing Zones 5 (2 trials in MN, 2 trials in ND,
and 1 trial in WI), 7 (1 trial in NE), 8 (1 trial in KS), 9 (1 trial in
MT), 10 (2 trials in CA), and 11 (1 trial in ID and 1 trial in WA). 
Separate untreated control and treated test plots were established at
each trial site.  At each test location, two foliar broadcast spray
applications of the 2 lb/gal EC formulation of fluazifop-P-butyl were
made to sugar beets at a target application rate of 0.375 lb
ai/A/application, for a total target seasonal rate of 0.75 lb ai/A.
Applications were made at 12- to 14-day retreatment intervals in spray
volumes of 10 to 30 gal/A at 9 trial sites and 8 to 10 gal/A at the
other 3 trial sites.  Adjuvants (non-ionic surfactant or crop oil
concentrate) were used at all sites and the sugar beets subsequently
harvested at a PHI of 89 to 90 days.  

Samples of sugar beet tops and roots were analyzed for total fluazifop
residues (fluazifop-P-butyl, fluazifop free and conjugated) using a
GC/MS protocol.  This procedure is a common moiety method which
hydrolyzes any ester or acid conjugates and treats the resulting extract
to form the methyl ester of fluazifop so that a total determination can
be made.  This method is adequate for data collection based upon
acceptable method validation and concurrent method recoveries.  The LOQ
was 0.01 ppm for sugar beet tops and roots.  

Sample storage conditions and durations incurred for this study which
support this action are reported in Table 4.  Samples were stored frozen
for a maximum of 75 days (2.5 months) from harvest to analysis.  All
sample extracts were analyzed within 2 days of extraction.  The
available storage stability data demonstrate that residues of fluazifop
are generally stable in/on sugar beet roots stored frozen for up to 12
months (MRID No. 00157193).  Storage stability data are also available
which demonstrate that residues of fluazifop are stable in/on a wide
variety of other crop matrices for 3 to 28 months.  The available
storage data support the sample storage durations/conditions incurred
for the crop field trials made on sugar beet tops and roots.

For the application program tested, samples were harvested 89 to 90 days
after the last of two broadcast foliar applications made with the 2
lb/gal EC formulation at total rates of 0.747-0.764 lb ai/A/season.  In
accordance, maximum residues of total fluazifop were found to be 1.45
ppm in/on sugar beet tops and at 0.23 ppm for the roots.

Conclusions.  The submitted residue data for sugar beets are adequate in
fulfilling these data requirements.  The trials were made to
appropriately reflect the proposed maximum seasonal use pattern. 
Adequate stability data are available for this RAC to substantiate the
storage conditions and durations that were incurred.  The residue data
for sugar beets 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
(Appendix I).  The spreadsheet provides a best estimate of a tolerance
at 0.25 ppm for sugar beet roots.  In regard to sugar beet tops, no
tolerance will be required for this commodity since it is no longer
considered to be a significant food or feed item.  A revised Section F
should therefore be submitted to include only the HED-recommended
tolerance of 0.25 ppm for residues in/on sugar beet roots.

860.1520 Processed Food and Feed

DER References:  	R062698.tif  (MRID No. 41373705) (citrus)

			47874605.der.doc (grapes)

			47874606.der.doc (sugar beets)

Syngenta Crop Protection has submitted processing studies for
fluazifop-P-butyl on citrus, grapes, and sugar beets.  A summary of the
processing factors is presented below in Table 7 for review.

  SEQ CHAPTER \h \r 1 Table 7.	   Summary of Processing Factors for
Fluazifop-P-Butyl.

RAC	Processed Commodity	Processing Factor

Grapes	Raisins	≤1x

	Juice	≤1x

Sugar beets	Refined Sugar	0.36x

	Dried Pulp	3.9x

	Molasses	14x



Citrus (MRID No. 41373705)  

In a single citrus (orange) trial conducted in FL during the 1986
growing season using the 2 lb/gal EC formulation of fluazifop-P-butyl. 
For this test program, three applications were made at the nominal rate
of 3.75 lb ai/A/application, for a total seasonal rate of 11.25 lb ai/A
(10x the maximum proposed seasonal rate for citrus).  Applications were
made at 21 day intervals using ground equipment, with the spray directed
to the ground beneath and around the trees.  Samples of oranges were
harvested 14 days after the last application and processed into chopped
peel, dried pulp, molasses, juice, and oil.

The analytical method used for data collection was ICI Plant Protection
Method 82.  The method performed extraction with
acetonitrile:concentrated HCl to convert residues to fluazifop.  The
procedure employed similar clean-up steps as those specified in PAM II
method, but final determination using this protocol is made by 19F NMR
analysis.  Residues in citrus are reported as total fluazifop.  The LOQ
for total fluazifop residues was set at 0.03 ppm.  This method is
adequate for data collection based upon acceptable concurrent recoveries
from the matrices fortified at 0.05 ppm.  Sample storage conditions and
durations incurred for this study which support this action are reported
in Table 4.  

Samples of citrus fruit were analyzed within 25 months of harvest.  No
storage stability data have been submitted for citrus specifically. 
Nonetheless, the stability of fluazifop-P-butyl has been investigated in
a wide variety of frozen crop commodities and documented in several
prior reports generated by the registrant.  These reports show residues
are stable in/on soybeans, sugar beets, green beans, strawberries,
oilseed rape, coffee, cauliflower, onions, potatoes, peanuts, macadamia
nuts, tomatoes, endive, and celery for durations of 3 to 28 months.

Total fluazifop residues were <LOQ (0.03 ppm) in/on the whole oranges
treated with fluazifop-P-butyl at a total of 11.25 lb ai/A.  Following
processing of the whole oranges, total fluazifop residues were 1.7 ppm
in chopped peel, 2.6 ppm in dried pulp, 0.09 ppm in molasses and oil,
and <LOQ (0.03 ppm) in juice.  Based on these data, processing factors
would be 87x in dried pulp, 3x in oil, and <1x in juice.  However, the
Petitioner states that processing factor in dried pulp is unreasonable
considering that oranges contain about 86% water.  Therefore, the
Petitioner calculated processing factors by assuming that the residue in
the whole oranges was 0.65 ppm, as calculated from the total residue
found in the processed commodities and the weight of the starting
oranges.  The resulting reported processing factors were 4x for dried
pulp, 2.6x for peel, 1.7x for molasses, and 0.14x for oil.

Conclusions:  EPA previously concluded that proposed tolerances in
citrus fruit and dried citrus cannot be determined (DEB No. 6343, M. J.
Bradley, 08/15/1990).  Rather then attempting to upgrade these results,
it would be prudent for the petitioner to provide a new study given the
age of this data submission.  To satisfy the establishment of tolerances
for the citrus processed commodities, the theoretical concentration
factors are therefore used for setting the pertinent limits on juice
(2x) and oil (1000x).  These factors along with the citrus HAFT of 0.03
ppm, determine that an appropriate fluazifop-P-butyl tolerance for
citrus juice would be 0.06 ppm and 30.0 ppm for the oil fraction.  In
regard to citrus dried pulp, there is no theoretical concentration
factor determined for this processed commodity.  Nonetheless, in a
recent action made for chlorantraniliprole, a snap-shot of 27 pesticides
having citrus dried pulp limits was made to determine a practical
maximum concentration factor for this processed commodity (DP No.
D361791, D. Rate, 01/08/2010).  This determination found that
concentration factors range between 2-13x for the citrus dried pulp
tolerances which were examined.  Therefore, using the maximum
concentration factor of 13x for fluazifop along with the citrus HAFT of
0.03 ppm, a resulting tolerance of 0.40 ppm should be set for the citrus
dried pulp processed commodity.  

Grapes (MRID No. 47874605) 

A single field trial was conducted during the 2000 growing season on
grapes, encompassing Zone 10 (1 trial in CA).  Separate untreated
control and treated test plots were established at the trial site. 
Three broadcast spray applications of the 2 lb/gal EC formulation of
fluazifop-P-butyl were made to the vineyard floor beneath the grape
vines to conduct this trial.  Treatments were made at a target
application rate of 1.875 lb ai/A/application, with a 14-day retreatment
interval (RTI), for a total target seasonal rate of 5.63 lb ai/A (5x the
maximum application rate).  Grapes were harvested 50 days after final
treatment.  The grape RACs were processed into grape juice and raisins.

Samples of the grape RAC and its processed commodities were analyzed for
total fluazifop residues (fluazifop-P-butyl, fluazifop free and
conjugated) using a GC/MS protocol.  This procedure is a common moiety
method which hydrolyzes any ester or acid conjugates and treats the
resulting extract to form the methyl ester of fluazifop so that a total
determination can be made.  This method is adequate for data collection
based upon acceptable method validation and concurrent method
recoveries.  The LOQ was 0.01 ppm for all grape matrices.  

Sample storage conditions and durations incurred for this study which
support this action are reported in Table 4.  Samples were stored frozen
from harvest to extraction for up to 36 days (1.2 months) for grapes, 29
days (1 month) for grape juice, and 43 days (1.4 months) for raisins.
The storage duration between processing and extraction was 33 days for
grapes, 26 days for grape juice, and 30 days for raisins.  Samples were
analyzed within 0-2 days of extraction.  No storage stability data have
been submitted for grapes specifically.  Nonetheless, the stability of
fluazifop-P-butyl has been investigated in a wide variety of frozen crop
commodities and documented in several prior reports generated by the
registrant.  These reports show residues are stable in/on soybeans,
sugar beets, green beans, strawberries, oilseed rape, coffee,
cauliflower, onions, potatoes, peanuts, macadamia nuts, tomatoes,
endive, and celery for durations of 3 to 28 months.

Total fluazifop residues were found to be <LOQ (0.01 ppm) in/on the
grape RAC harvested 50 days after the last of three treatments made at a
5x seasonal application rate (5.64 lb ai/A/season).  Total fluazifop
residues were also found to be <LOQ (0.01 ppm) in/on the grape juice and
raisin processed grape fractions.  As such, the observed processing
factors for grape juice and raisins are less than the theoretical
concentration factor of 4.7x for raisins (based on the loss of water on
processing grapes into raisins; OPPTS 860.1520, Table 1) and 1.2x for
grape juice (based on separation of components; OPPTS 860.1520, Table
3).

Conclusions:  The grape processing data are adequate in fulfilling these
data requirements.  These data indicate that total fluazifop residues do
not appear to concentrate in raisins or grape juice.  As a result, no
tolerance is therefore needed for raisins or grape juice.

Sugar beets (MRID No. 47874606) 

A single field trial was conducted on sugar beets during the 2000
growing season, encompassing Zone 11 (1 trial in WA).  Separate
untreated control and treated test plots were established at the trial
site.  Two foliar broadcast spray applications using the 2 lb/gal EC
formulation of fluazifop-P-butyl were made to sugar beets to conduct
this trial.  Treatments were made at a target application rate of 1.875
lb ai/A/application, with a 14-day RTI, for a total target seasonal rate
of 3.75 lb ai/A (5x the maximum application rate).  Sugar beets were
harvested 90 days after final treatment.  The sugar beet RAC was
processed into refined sugar, dry pulp and molasses.

Samples of the sugar beet RAC and its processed commodities were
analyzed for total fluazifop residues (fluazifop-P-butyl, fluazifop free
and conjugated) using a GC/MS protocol.  This procedure is a common
moiety method which hydrolyzes any ester or acid conjugates and treats
the resulting extract to form the methyl ester of fluazifop so that a
total determination can be made.  This method is adequate for data
collection based upon acceptable method validation and concurrent method
recoveries.  The validated LOQ was 0.01 ppm for all sugar beet matrices.
 

Sample storage conditions and durations incurred for this study which
support this action are reported in Table 4.  Samples were stored frozen
from harvest to extraction for 48 days (1.6 months) for sugar beet
roots, and dry pulp, 48 to 51 days (1.6 to 1.7 months) for molasses, and
53 days (1.8 months) for refined sugar.  The storage duration between
processing and extraction was 28 to 31 days for molasses, 32 days for
sugar beet roots, 32 to 33 days for dry pulp, and 33 days for refined
sugar. Samples were analyzed on the day of extraction.  Storage
stability data demonstrate that residues of fluazifop are generally
stable in/on sugar beet roots stored frozen for up to 12 months (MRID
No. 00157193).  Although no storage stability studies are available for
the sugar beet processed fractions of sugar beets, no data are required
since extraction/analysis occurred within approximately 30 days from
processing. 

Average total fluazifop residues were found to be 0.86 ppm in/on the
sugar beet RAC (root) harvested 90 days after the last of two broadcast
foliar treatments made at a 5x seasonal application rate (3.79 lb
ai/A/season).  In processed sugar beet fractions, average total
fluazifop residues were found to be 0.31 ppm in refined sugar, 3.35 ppm
in the dry pulp, and 12 ppm in molasses.  A comparison of the residues
in the RAC with those in each processed fraction resulted in
concentration factors of 0.36x for refined sugar, 3.9x for dry pulp, and
14x for molasses.  These concentration factors are consistent with the
theoretical concentration factor of 12.5x for sugar (based on separation
of components; OPPTS 860.1520, Table 3) and the maximum observed
concentration factor of 20x (OPPTS 860.1520, Table 4) for dry pulp and
molasses.

Conclusions:  The sugar beet processing data are adequate in fulfilling
these data requirements.  These data indicate that total fluazifop
residues do not appear to concentrate in sugar beet refined sugar, but
may concentrate in sugar beet dried pulp and sugar beet molasses.  Based
on the sugar beet root HAFT (0.22 ppm) and the average processing factor
for dried pulp (3.9x) and molasses (14x), expected residues in these
fractions are 0.86 ppm and 3.1 ppm, respectively.  Likewise, no
tolerance is needed for the sugar beet refined sugar processed
commodity.  As a result, the proposed tolerances of 1.0 ppm in dried
pulp and 3.5 ppm for molasses are adequate for these sugar beet
processed commodities.

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

Analytical standards for fluazifop-P-butyl and fluazifop-P (resolved (R)
isomer of fluazifop acid) are currently available in the EPA National
Pesticide Standards Repository.  The fluazifop-P-butyl standard expires
1/1/2011.  Analytical reference standards must be 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 either Theresa Cole or Thuy Nguyen 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.)

860.1850/860.1900 Confined and Field Accumulation in Rotational Crops

The following plantback restriction exists on the product label (EPA
Reg. No. 100-1070):  a 60-day plantback interval for rotational crops
such as corn, sorghum, and cereals.    SEQ CHAPTER \h \r 1 This
plantback interval is also appropriate for sugar beet. 

860.1550 Proposed Tolerances

In a meeting on March 3, 2004, the MARC concluded that for tolerance
expression, parent and fluazifop-acid (free and conjugated) are the
residues of concern since they are adequate to determine misuse (DP No.
D298939, S. L. Kinard, 06/22/2004).  An acceptable soybean metabolism
study is available along with new studies made to a root crop and leafy
vegetable which are currently undergoing Agency review.  In accordance,
tolerances are established under 40 CFR §180.411(a)(1) and (c)(1) for
residues of fluazifop-butyl, including free and conjugated fluazifop,
expressed as fluazifop.  For fluazifop-P-butyl, including free and
conjugated fluazifop (R isomer), tolerances are likewise established
under 40 CFR §180.411(a)(2) and (c)(2) with residues expressed as
fluazifop.  Its registered uses include dry beans, carrot, cotton,
endive (escarole), macadamia nut, onion, peanut, pecan, soybean,
spinach, stone fruit, and sweet potato.  It also carries tolerances with
regional registrations on asparagus, coffee, pepper, and rhubarb along
with being registered for use on lawns as a weed control application.

For this action, field trials on bananas, citrus, grapes, and sugar
beets along with corresponding studies made on the pertinent processed
commodities were submitted to support this petition request.  In
evaluating the field trials provided by the registrant, these studies
were found to be adequate in satisfying these residue chemistry data
requirements.  In regard to the banana, grape, and citrus RACs, residues
levels in all of the treated samples analyzed were found to be below the
LOQ of the test method.  As such, the proposed tolerance of 0.01 ppm
specified by the registrant for bananas and grapes is acceptable. 
Following this approach a revised tolerance of 0.03 ppm for citrus based
upon the corresponding LOQ of the test method is therefore recommended
instead of the 0.05 ppm level proposed by the registrant.  Total
fluazifop residues in/on sugar beet RACs were found to be readily
quantifiable at levels greater then the LOQ of the test method.  In
accordance, the Agency’s Guidance for Setting Pesticide Tolerances
Based on Field Trial Data was utilized for determining appropriate
tolerance levels for sugar beet roots (Appendix I).  Based on these
calculations, the proposed sugar beet tolerance of 0.25 in roots is
adequate.

In evaluating of the corresponding processing study data that were
provided, it can be concluded that no additional tolerances are needed
for grape juice and raisins as well as sugar beet refined sugar. 
However, residues of fluazifop were found to concentrate in sugar beet
dry pulp (3.9x) and sugar beet molasses (14x).  Based on the sugar beet
root HAFT of 0.22 ppm and the processing factors calculated for dried
pulp and molasses, expected residues in these fractions are 0.86 ppm and
3.1 ppm, respectively.  As a result, the tolerances of 1.0 ppm in dried
pulp and 3.5 ppm for molasses proposed by the registrant are adequate
for these sugar beet processed commodities.  

For the citrus processed commodities, the petitioner has also proposed
tolerances of 0.40 ppm in dried pulp along with 0.05 ppm in juice and
oil.  However, EPA previously concluded that proposed tolerances in
citrus fruit and dried citrus cannot be determined (DEB No. 6343, M. J.
Bradley, 08/15/1990).  Rather then attempting to upgrade these results,
it would be prudent for the petitioner to provide a new study given the
age of this data submission.  To satisfy the establishment of tolerances
for the citrus processed commodities, the theoretical concentration
factors are therefore used for setting the pertinent limits on juice
(2x) and oil (1000x).  These factors along with the citrus HAFT of 0.03
ppm, determine that an appropriate fluazifop-P-butyl tolerance for
citrus juice would be 0.06 ppm and 30.0 ppm for the oil fraction.  In
regard to citrus dried pulp, there is no theoretical concentration
factor determined for this processed commodity.  Using a practical
maximum concentration factor of 13x as identified in a recent
chlorantraniliprole action, along with the citrus HAFT of 0.03 ppm, a
fluazifop-P-butyl tolerance of 0.40 ppm for citrus, dried pulp is
appropriate.

The current petition requests the establishment of tolerances on dried
pulp citrus and sugar beet tops, commodities which have been considered
livestock feedstuffs.   Following revision of the Table 1 Feedstuffs in
2008, sugar beet tops were removed as being a significant feed item, and
thus it no longer contributes to the dietary burden of cattle.  The
potential contribution of citrus dried pulp to the livestock dietary
burden was considered by assuming a concentration factor of 13x and
comparing the resulting residue contribution to that of soybean hulls,
the current roughage component in the dietary burden calculation.  Since
soybean hulls has a higher tolerance than the recommended tolerance
level of dried pulp citrus, the current tolerances on meat, milk,
poultry, and eggs are considered adequate and should remain unchanged. 
This conclusion should be re-examined upon receipt of the requested
processing study for citrus.      

The established tolerances for livestock commodities are 0.05 ppm for
total fluazifop residues in milk and the meat and meat byproducts of
cattle, goat, hog, horse, and sheep, and fat, meat and meat byproducts
of poultry.  These levels remain appropriate. 

The available residue data provided for fluazifop-P-butyl are adequate
to support the establishment of new permanent tolerance levels
recommended for the RACs proposed in this action.  There are no Codex,
Canadian or Mexican established Maximum Residue Limits (MRLs) for
residues of fluazifop-P-butyl in/on bananas, citrus, grapes and sugar
beets.  As a result, international harmonization is not an issue for
this data evaluation concerning any of these crops.  The proposed
tolerances should therefore be revised and a new Section F submitted to
reflect the recommended tolerance levels and correct commodity
definitions specified below in Table 8.

Table 8. 	Tolerance Summary for Fluazifop-P-butyl.

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

Tolerances Proposed for 40 CFR §180.411(a)(1)

Banana	--	0.01	0.01

	Citrus	--	0.05	0.03	Fruit, citrus, group 10-10

Citrus, oil	--	0.05	30.0

	Citrus, dried pulp	--	0.40	0.40

	Citrus, juice	--	0.05	0.06

	Grapes	--	0.01	0.01

	Beet, sugar, root	--	0.25	0.25

	Beet, sugar, top	--	1.5	None 	Removed from Table 1 Feedstuffs, June
2008

Beet, sugar, dried pulp	--	1.0	1.0

	Beet, sugar, molasses	--	3.5	3.5

	

References

DP No.:	D319907

Subject:	Fluazifop-P-butyl.  REVISED TRED – Report on FQPA Tolerance
Reassessment Progress and Interim Risk Management Decisions.  Residue
Chemistry Considerations.  Case No. 2285.

From:		S. L. Kinard

To:		D. Locke

Dated:		08/17/2005

MRID Nos.:	00093840-1, 00093843, 00093845, 00137763, 00144014, 00151494,
00157191, 001517193, 40140401, 40241901, 40341601, 40361104, 40361108,
40361111, 40693108, 40725701, 40831303-5, 40831307, 40831309-10,
41018001, 41373703.

DP No.:	D298939

Subject:	Fluazifop-P-butyl.  Report of the Metabolism Assessment Review
Committee. 

From:		S. L. Kinard

To:		Y. Donovan

Dated:		03/17/2004

MRIDs:	None

DP No.:	None

Subject:	PP#0F3842/FAP#0H5596.  Fluazifop-P-butyl on Citrus.  Evaluation
of Analytical Methods and Residue Data.  MRID Nos. 41373701-06.  DEB No.
6343.  Hed Project No. 0-0683.

From:		M. J. Bradley

To:		J. Miller

Dated:		08/15/1990

MRID Nos.:	41373701 - 41373706.

DP No.:	D361791

Subject:	Chlorantraniliprole.  Amended Section 3 Registration Request
for Uses on Various Field, Vegetable, and Fruit Crops and Discussion of
Future Registration and Tolerance Requests.  Summary of Analytical
Chemistry and Residue Data.

From:		D. Rate

To:		V. Eagle and K. Davis

Dated:		01/08/2010

MRID Nos.:	47588201-11 and 47588214-29

DP No.:	D348246

Subject:	Fluazifop-P-Butyl. Section 3 Registration Request to Add New
Uses on Beans (Dry), Peanuts and Soybeans. Summary of Analytical
Chemistry and Residue Data.

From:		D. Soderberg

To:		J. Miller

Dated:		9/16/2008

MRID Nos.:	47285501-05; 46412503

MRID No.:	00157193  Atreya, N. C. and Froggatt, D. A. (1983) Reside Data
Report No. PP009B157 Storage Stability Study; Sugar beet, Strawberries,
Oilseed Rape, Green Beans and Cauliflower.  Study Number: PP009BC04. 
Unpublished study prepared by Imperial Chemical Industries PLC Plant
Protection Division. 22 pages.

  SEQ CHAPTER \h \r 1 Attachments:  

International Residue Limit Status sheet

Appendix I - Tolerance Assessment Calculations

Template Version September 2005

International Residue Limits 

Fluazifop-P-butyl (122809; 08/26/2010)

Summary of US and International Tolerances and Maximum Residue Limits 

Residue Definition:

US	Canada	Mexico2	Codex3

40 CFR 180.411:

Plant/Livestock: 
butyl(R)-2-[4-[[5-(trifluoromethyl)-2-pyridinyl]oxy]phenoxy]propanoate,
and the free and conjugated forms of the resolved isomer of fluazifop,
(R)-2-[4-[[5-(trifluoromethyl)-2-pyridinyl]oxy]phenoxy]propanoic acid,
expressed as fluazifop.

	butyl (RS)-2-[4-[[5-(trifluoromethyl-2-pyridinyl]oxy]phenoxy]propanoate

(calculated as acid)



None

Commodity1	Tolerance (ppm) /Maximum Residue Limit (mg/kg)

	US	Canada	Mexico2	Codex

Banana	0.01	None

None

Fruit, citrus, crop group 10	0.03



	Citrus, dried pulp	0.40



	Citrus, juice	0.06



	Citrus, oil	30.0



	Grapes	0.01



	Beet, sugar, root	0.25



	Beet, sugar, dried pulp	1.0



	Beet, sugar, molasses	3.5













































	Completed: M. Negussie/08/30/2010

1 Includes only commodities of interest for this action.  Tolerance
values should be the HED recommendations and not those proposed by the
applicant.

2 Mexico adopts US tolerances and/or Codex MRLs for its export purposes.

3 * = absent at the limit of quantitation; Po = postharvest treatment,
such as treatment of stored grains.  PoP = processed postharvest treated
commodity, such as processing of treated stored wheat. (fat) = to be
measured on the fat portion of the sample. MRLs indicated as proposed
have not been finalized by the CCPR and the CAC.

Appendix I

Tolerance Assessment Calculations

For each of the crops listed below, the Guidance for Setting Pesticide
Tolerances Based on Field Trial Data (SOP), along with the tolerance
spreadsheet (January 2008 version), was used for calculating recommended
tolerances.

Sugar beet, Root

The dataset used to establish a tolerance for fluazifop-P-butyl on sugar
beet root consisted of field trial data representing seasonal
application rates of 0.747-0.764 lb ai/A (two applications at a target
of 0.375 lb ai/A) with a 89- to 90-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 used to calculate the tolerance are provided in Table I-2.

 

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摧咄/ഀ root dataset was entered into the tolerance spreadsheet.  The
result from the approximate Shapiro-Francia test statistic (Figure I-6)
indicated that the assumption of log normality should be rejected. 
Visual inspection of the lognormal probability plot (Figure I-3)
provided in the spreadsheet confirmed that the dataset is not lognormal.

Since the field trial data for fluazifop-P-butyl on sugar beet roots are
not lognormal, the mean plus 3 standard deviations should be selected as
the tolerance value.  Using the rounding procedure as outlined in the
Guidance for Setting Pesticide Tolerances Based on Field Trial Data SOP,
the mean plus 3SD rounds to the value 0.25 ppm (Figure I-4).  Therefore,
0.25 ppm is the recommended tolerance level for fluazifop-P-butyl on
sugar beet roots.  



Table I-1.	Residue data used to calculate tolerance for
fluazifop-P-butyl on sugar beet root.

Regulator:	EPA



Chemical:	Fluazifop-p-butyl

	Crop:	Sugar beet root



PHI:	89-90 Days



App. Rate:	0.747-0.764



Submitter:	Syngenta Crop Protection, Inc. 

	Residues	LN(Residues)	Z-scores

	0.06	-2.81	-0.48

	0.05	-3.00	-0.88

	0.09	-2.41	0.48

	0.1	-2.30	0.60

	0.08	-2.53	0.16

	0.07	-2.66	-0.26

	0.05	-3.00	-0.73

	0.07	-2.66	-0.16

	0.06	-2.81	-0.37

	0.07	-2.66	-0.05

	0.1	-2.30	0.73

	0.11	-2.21	0.88

	0.01	-4.61	-1.95

	0.01	-4.61	-1.50

	0.08	-2.53	0.26

	0.08	-2.53	0.37

	0.02	-3.91	-1.24

	0.03	-3.51	-1.04

	0.05	-3.00	-0.60

	0.07	-2.66	0.05

	0.11	-2.21	1.04

	0.11	-2.21	1.24

	0.2	-1.61	1.50

	0.23	-1.47	1.95



Figure I- 3.  Lognormal probability plot of fluazifop-P-butyl field
trial data for sugar beet root.

Figure I- 4.   Tolerance spreadsheet summary of fluazifop-P-butyl field
trial data for sugar beet root.

 	Regulator:	EPA

	 	Chemical:	Fluazifop-p-butyl

	 	Crop:	Sugar beet root

	 	PHI:	89-90 Days

	 	App. Rate:	0.747-0.764

	 	Submitter:	Syngenta Crop Protection, Inc.

 



	 	n:	24

	 	min:	0.01

	 	max:	0.23

	 	median:	0.07

	 	average:	0.08

	 



	 	95th Percentile	99th Percentile	99.9th Percentile

EU Method I

Normal	0.20	0.20	0.25

	(0.20)	(0.25)	(--)

95/99 Rule	0.25	0.40	0.70

	(0.40)	(0.80)	(--)

EU Method II

Distribution-Free

0.20







Mean+3SD

0.25







UCLMedian95th

0.40







Approximate Shapiro-Francia Normality Test Statistic

0.8814



	0.05 >= p-value > 0.01 : Reject lognormality assumption



 	 	 



Page   PAGE  1  of   NUMPAGES  31 

Fluazifop-P-butyl	Summary of Analytical Chemistry and Residue Data	DP
No. 385205

Fluazifop-P-butyl	Summary of Analytical Chemistry and Residue Data	DP
No. 372408

