UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF CHEMICAL SAFETY AND

                                                                        
                      POLLUTION PREVENTION

MEMORANDUM

	Date:	April 13, 2011

	Subject:	Triflusulfuron-methyl.  Petition for the Establishment of
Permanent Tolerances and Registration for Use on Garden Beets (PP
9E7669).  Summary of Analytical Chemistry and Residue Data.

PC Code:  129002	DP Barcode:  D388620

Decision No.: 425459	Registration No.:  352-569

Petition No.:  9E7669	Regulatory Action:  Section 3

Assessment Type:  Single Chemical	Registration Case No.:  NA

TXR No.:  None	CAS No.:  126535-15-7

MRID No.:  47943201	40 CFR §180.492



	FROM:	Elizabeth Holman, Chemist

		Risk Assessment Branch II 

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

	THROUGH:   William T. Drew, Chemist

                    	Risk Assessment Branch II (RAB2)

	 	Health Effects Division (HED) (7509P)

			   and

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

		Risk Assessment Branch II

		Health Effects Division (7509P)

	TO:	Laura Nollen/Barbara Madden 

		Minor Use Team

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

The residue chemistry summary document completed 2/17/11 (D376350; E.
Holman) has been revised to address an issue related to plant-back
intervals for rotational crops.  Table of Contents

  TOC \o "1-3" \h \z \u    HYPERLINK \l "_Toc260732602"  Executive
Summary	  PAGEREF _Toc260732602 \h  3  

  HYPERLINK \l "_Toc260732603"  Residue Chemistry Deficiencies	  PAGEREF
_Toc260732603 \h  4  

  HYPERLINK \l "_Toc260732604"  Background	  PAGEREF _Toc260732604 \h  5
 

  HYPERLINK \l "_Toc260732605"  860.1200  Directions for Use	  PAGEREF
_Toc260732605 \h  6  

  HYPERLINK \l "_Toc260732606"  860.1300 Nature of the Residue - Plants	
 PAGEREF _Toc260732606 \h  9  

  HYPERLINK \l "_Toc260732607"  860.1300 Nature of the Residue -
Livestock	  PAGEREF _Toc260732607 \h  9  

  HYPERLINK \l "_Toc260732608"  860.1340 Residue Analytical Methods	 
PAGEREF _Toc260732608 \h  10  

  HYPERLINK \l "_Toc260732609"  860.1360 Multiresidue Methods	  PAGEREF
_Toc260732609 \h  12  

  HYPERLINK \l "_Toc260732610"  860.1380 Storage Stability	  PAGEREF
_Toc260732610 \h  12  

  HYPERLINK \l "_Toc260732611"  860.1400 Water, Fish, and Irrigated
Crops	  PAGEREF _Toc260732611 \h  12  

  HYPERLINK \l "_Toc260732612"  860.1460 Food Handling	  PAGEREF
_Toc260732612 \h  13  

  HYPERLINK \l "_Toc260732613"  860.1480 Meat, Milk, Poultry, and Eggs	 
PAGEREF _Toc260732613 \h  13  

  HYPERLINK \l "_Toc260732614"  860.1500 Crop Field Trials	  PAGEREF
_Toc260732614 \h  13  

  HYPERLINK \l "_Toc260732615"  860.1520 Processed Food and Feed	 
PAGEREF _Toc260732615 \h  17  

860.1650 Submittal of Analytical Reference Standards	18

  HYPERLINK \l "_Toc260732616"  860.1850 Confined Accumulation in
Rotational Crops	  PAGEREF _Toc260732616 \h  18  

  HYPERLINK \l "_Toc260732617"  860.1900 Field Accumulation in
Rotational Crops	  PAGEREF _Toc260732617 \h  19  

  HYPERLINK \l "_Toc260732618"  860.1550 Proposed Tolerances	  PAGEREF
_Toc260732618 \h  19  

 Executive Summary

Triflusulfuron-methyl is a sulfonylurea herbicide that inhibits the
biosynthesis of branched-chain amino acids in plants (via inhibition of
the plant enzyme acetolactate synthase).  Marketed as UpBeet, a dry
flowable (DF) formulation containing 50% active ingredient (ai),
triflusulfuron-methyl is currently approved for use on sugar beet
commodities and chicory using broadcast (ground- or aerial-based) or
band application methods at seasonal rates of up to 0.078 pounds ai per
acre (lb ai/A).  UpBeet is not to be applied via any type of irrigation
system. The existing label for UpBeet lists a pre-harvest interval (PHI)
of 60 days for both sugar beet and chicory.  The registrant, E. I. du
Pont de Nemours and Company, has submitted a supplemental label for a
proposed use on garden beets. 

The maximum proposed single application rate on this supplemental label
is 0.0156 lb ai/A for agricultural use on garden beets for control of
broadleaf weeds, with a maximum seasonal application rate of 0.047 lb
ai/A.  Consistent with the existing uses, the requested new use on
garden beet involves aerial or groundboom application methods. The
proposed PHI on garden beet is 30 days, a value that is well supported
by the garden beet field trial data submitted for this new use petition.


The residue chemistry database is relatively complete and there are no
residue chemistry issues that would preclude granting the requested new
use and establishing permanent tolerances on garden beet roots and tops.
 The petitioner has previously submitted data depicting the nature of
the residue in sugar beet and lactating goat.   For the purposes of this
petition on garden beet, the previously reviewed sugar beet metabolism
study is sufficient to support the requested use of
triflusulfuron-methyl on garden beets.  The proposed tolerance
expression in/on garden beets should include only the parent compound,
triflusulfuron-methyl.  The registrant is petitioning for tolerances of
0.01 ppm on garden beet roots and 0.02 ppm on garden beet tops.  The
existing tolerances on sugar beet and chicory commodities are 0.05 ppm. 


HED previously reviewed the goat metabolism study and cited deficiencies
to be addressed should additional Section 3 registrations be pursued by
the petitioner. However, based on residue levels observed in the goat
metabolism study, finite residues are not expected in ruminant meat,
meat byproduct, fat, or milk and tolerances are not required for these
commodities.  Therefore, the deficiencies cited by HED do not need to be
addressed for the purposes of this new food use on garden beet. 
However, if future uses on large-acreage crops such as wheat, corn, or
soybean are proposed, and consequently involve feedstuffs, then an
adequate ruminant metabolism study should be provided.

Adequate crop field trials and processing studies have been conducted to
support tolerances in the plant commodities of sugar beet, chicory, and
garden beet.  Even at exaggerated rates (8X) for the field trial used to
generate the processing study samples, no triflusulfuron-methyl was
found in the sugar beet roots or processed commodities.  DuPont Method
4480 was used to quantitate triflusulfuron-methyl residues in samples
from the garden beet field trials currently under review via solvent
extraction and High Performance Liquid Chromatography-Mass
Spectrometry/Mass Spectrometry (HPLC-MS/MS).  With the exception of
sugar beet tops at one location that contained residues at the LOQ of
0.01 ppm, these eight field trials yielded residues that were less than
the limit of quantitation.  A registered non-ionic surfactant (NIS) or
crop oil concentrate (COC) was added to the spray mixture for each
application at a rate of 0.25% by volume (v/v) at all garden beet field
trials with the exception of a single trial conducted in Oregon.  No
impact on residue levels was observed in this non-adjuvant garden beet
field trial.  Therefore, adjuvant restrictions on the supplemental label
are not needed.  There are no processed commodities or livestock feed
items associated with garden beet.  The review of these garden beet
field trials was originally conducted by Canada’s Pest Management
Regulatory Agency (PMRA) under a work share arrangement, but their
conclusions have been reviewed by HED and are consistent with OCSPP
policy.

An analytical standard for triflusulfuron-methyl is currently available
in the National Pesticide Standards Repository (NPSR).  

Residue Chemistry Deficiencies

The residue chemistry data set is complete with the exception of:   

1. The following label amendments are needed: a) The requested 30-day
PHI for garden beet needs to be added to the supplemental label.  b) The
use of the aerial application method needs to be clarified in the
supplemental label.  The submitted supplemental label for garden beet
does not include the petition-requested 30-day PHI, nor does it
delineate the use of the aerial application method.   Aerial application
method instructions are included in the existing label for sugar beets. 

2. Analytical Method – An adapted version of DuPont Method 4480 (MRID
48207101) was used in the submitted garden beet field trials under
review in this petition.  The enforcement method on record for
triflusulfuron-methyl is method AMR 1930-91 (MRID 42496873), an HPLC-UV
method.  Method AMR 2021-91 (MRID 42496872) is very similar to AMR
1930-91, with the addition of an automatic switching column protocol,
and was used in the previously submitted sugar beet and chicory field
trials.  Method 4480 is also similar to both these methods, with the
primary difference being the addition of a tandem mass spectrometric
detection protocol in Method 4480.  In addition, the independent
laboratory validation (ILV) of Method 4480 successfully demonstrated the
reliability of the method on the first attempt.  The registrant should
clarify whether they want to replace the existing enforcement method
with Method 4480 when applying for future new uses, as this newer method
does appear to be an acceptable enforcement method.  

Should the registrant decide to request Method 4480 be used for
enforcement purposes, they will need to ensure that the standards are
made available to the USEPA’s Analytical Chemistry Branch (ACB) in the
event that they differ from those used in method AMR 1930-91.  

Regulatory Recommendations

There are no major deficiencies which would preclude the establishment
of permanent tolerances for the use of triflusulfuron-methyl (as the DF
formulation, UpBeet) on garden beets.  Provided that the forthcoming
human health risk assessment (D373433; E.Holman; January 2011) does not
identify any issues of concern, the submitted data support tolerances
for residues of triflusulfuron-methyl, including its metabolites and
degradates, in or on garden beet roots and tops, at the levels listed
below.  Compliance with the tolerance levels specified below is to be
determined by measuring triflusulfuron-methyl only.  

Beet, garden, roots	0.01 ppm

Beet, garden, tops	0.02 ppm

Note to RD:  According to HED’s Interim Guidance on Tolerance
Expressions (S. Knizner, 27 May 2009), the tolerance expression for
triflusulfuron-methyl cited in 40CFR §180.492[a] should be revised to
state:  

Tolerances are established for residues of triflusulfuron-methyl,
including its metabolites and degradates, in or on the commodities
listed in the table below.  Compliance with the tolerance levels
specified below is to be determined by measuring only
triflusulfuron-methyl (methyl
2-[[[[[4-(dimethylamino)-6-(2,2,2-trifluoroethoxy)-1,3,5-triazin-2-yl]am
ino]carbonyl]amino]sulfonyl]-3-methylbenzoate) in or on the commodity.  

Background

Triflusulfuron-methyl is a post-emergence selective herbicide which acts
by inhibiting biosynthesis of the essential amino acids valine, leucine
and isoleucine, hence stopping cell division and plant growth.  HED
previously assessed and recommended in favor of the food uses of this
herbicide on sugar beets and chicory (M. Doherty, et al., D260076, 12
February 2002).  Nomenclature and the physicochemical properties of
triflusulfuron-methyl are summarized in Tables 1 and 2, below.

TABLE 1.	Test Compound Nomenclature.

Compound	Chemical Structure



Common name	Triflusulfuron-methyl

Company experimental name	DPX 66037

IUPAC name	methyl
2-[4-dimethylamino-6-(2,2,2-trifluoroethoxy)-1,3,5-triazin-2-ylcarbamoyl
sulfamoyl]-m-toluic acid

CAS name	methyl
2-[[[[[4-(dimethylamino)-6-(2,2,2-trifluoroethoxy)-1,3,5-triazin-2-yl]am
ino] carbonyl]amino]sulfonyl]-3-methylbenzoate

CAS #	126535-15-7

End-use product/(EP)	UpBeet Herbicide*

*The EP used in the submitted garden beet field trials under review was
Safari 50DF, an EP that is equivalent to that of UpBeet.   

TABLE 2.	Physicochemical Properties of the Triflusulfuron-Methyl.

Parameter	Value	Reference

Melting point/range	155-158oC	PMRA REG99-03

pH	Not indicated

	Density (g/mL)	1.45 absolute

0.56 (Bulk)

	Water solubility ( 25°C)	  SEQ CHAPTER \h \r 1 pH                     
      ppm

3                                 1.0

5                                 2.7

7                               110

9                          11 000	PMRA REG99-03

	Low solubility at pH3 and pH 5; soluble at pH 7; very soluble at pH 9.
Solubility  increases with increasing pH.

	Solvent solubility (mg/L)	  SEQ CHAPTER \h \r 1 solvent                
       mg/L

hexane                      <0.0016

octanol                          0.026

toluene                              2.0

methanol                           7.0

ethyl acetate                       27

acetonitrile                         80

acetone                            120

chloroform                       160

methylene chloride          580

	Vapor pressure at 25°C	<1 x 10-7 mm Hg



A relatively non-volatile compound; low potential for losses due to
volatilization.

	Dissociation constant (pKa)	4.4



This compound will dissociate and exist in its anionic form at most
environmentally relevant pHs.

	Octanol/water partition coefficient (KOW)	  SEQ CHAPTER \h \r 1 pH     
                 Kow at 25°C

5                                220

7                                 9.2

9                                 0.86



Low potential for bioaccumulation in biota.

	UV/visible absorption spectrum	  SEQ CHAPTER \h \r 1 λmax = 395 nm

absorption at λ>400 nm is not anticipated



Potential to absorb sunlight in the UV/visible range of 290-400 nm.

	 

860.1200  Directions for Use

Summary of Existing Uses on Garden Beet and Chicory

For sugar beet, UpBeet may be broadcast applied via ground or air
equipment at up to 0.032 lb ai/A/application.  Multiple applications can
be made at 5-10 day re-treatment intervals (RTIs) with the total
application not to exceed 0.078 lb ai/A/season.  For chicory, two
applications may be made, at 0.024 lb ai/A and at 5- to 10-day RTIs, for
a maximum seasonal application rate of 0.048 lb ai/A.  This formulation
may also be band-applied at rates equivalent to the broadcast rates
(actual band rates are dependent upon crop row spacing).  UpBeet is not
to be applied via any type of irrigation system.  The existing label for
UpBeet lists a PHI of 60 days for both sugar beet and chicory,
representing a potential mid-season use.  Plant-back intervals are 0
days for sugar beets, 14 days for all other crops except corn, and 21
days for corn.  A plant-back interval has not been proposed for chicory
or garden beet.  HED is satisfied with the 14-day interval that these
crops receive from being in the “other crop” category as listed on
the current label.

Proposed Use on Garden Beet

Table 3 provides a summary of the proposed uses for DuPont™ UpBeet®
Herbicide (DF, water-dispersible granule, WDG, containing 50%
triflusulfuron-methyl by weight).  The maximum single application rate
is 0.0156 lb ai/A for agricultural use on garden beets for control of
broadleaf weeds.  Triflusulfuron-methyl (as UpBeet) may be applied
aerially or with groundboom equipment.  

TABLE 3.  Summary of Proposed Directions for Use of
Triflusulfuron-Methyl on Garden Beets.

Trade Name	Application Timing	Application Rate 

(lb ai/A)	Max. No. Applic. per Season	RTI1

(days)	Max. Seasonal Applic. Rate

(lb ai/A)	PHI

(days)	Use Directions and other Limitations

(i.e. grazing, type of application/equipment, plant-back interval,
other)

Garden Beets

UpBeet® Herbicide	Apply as a post-emergent spray when garden beets are
at the following stages: 2-4 leaf stage; 4-6 leaf stage; and 6-8 leaf
stage.	0.0156 

+                       NIS or COC

(at 0.25% v/v)	3	See appli-cation timing	0.047 	30a	- Apply UpBeet®
Herbicide with NIS or COC.

- Apply UpBeet® Herbicide via groundboom or aerial application
equipment.b  

- Do not apply UpBeet® Herbicide through any type of irrigation
equipment.



1 RTI = retreatment interval

Notes: 

a The label does not indicate a specific PHI for garden beets, however
there is a general label statement that appears on the new proposed
supplemental label indicating that “UpBeet® Herbicide must not be
applied within 60 days of harvest” (PMRA# 1708273). The letter from
the sponsor (PMRA# 1708271) and the letter of support from the
registrant (PMRA# 1708272) both indicate a PHI of 30 days. According to
the D.3.1 note to file (M2004-4211/cc050119.ntf.wpd), a clarifax was
sent on 13 January 2005 to the sponsor to clarify the correct PHI. The
sponsor indicated that the correct PHI is 30 days. Therefore, a specific
PHI of 30 days for garden beets needs to be added to the supplemental
label.  

b The petition under review (9E7669, pg. 17) for the new use on garden
beets lists both ground and aerial application methods.  The existing
label for sugar beets covers both of these application methods.  The
proposed supplemental label for garden beets covers only the ground
application method.  The sponsor has confirmed that aerial application
is requested for this new use.  Therefore, the aerial application method
needs to be added to the supplemental label.  

Conclusions.  The proposed labels are adequate to evaluate the residue
data relative to the proposed uses.  However, the proposed supplemental
label for garden beet needs to be revised to reflect the requested 30
day PHI and the aerial application method.

Therefore, the following label amendments are required for the proposed
supplemental label for use of UpBeet® Herbicide (Reg. No. 352-569) on
garden beet:

1) Under the Directions for Use section: 

	ADD: Do not apply within 30 days of harvest.

2) Aerial application method – The use of the aerial application
method needs to be delineated, either by reference to the existing label
instructions for aerial application on sugar beets or by including
similar language on the supplemental label itself.  

860.1300 Nature of the Residue - Plants

MRID 42496866 – Sugar Beet

The initial step in the metabolic breakdown of triflusulfuron-methyl on
sugar beet plants appears to be cleavage of the sulfonylurea bridge,
forming triazine urea and ester sulfonamide.  This process appears to
occur readily on the leaf surfaces of the sugar beet.  Triazine urea
undergoes reduction and demethylation steps over time, eventually
forming N,N-bisdesmethyl triazine amine.  The ester sulfonamide
intermediate is rapidly converted to acid sulfonamide, which, over time,
appears to form a conjugate with glucose.

The confined rotational crop studies show that cleavage of the
sulfonylurea bond also occurs readily in soil.  No parent compound was
detected in any plant commodities, even from the shortest rotation
interval of 30 days, suggesting that it is rapidly cleaved and/or not
translocated.  However, the triazine side of the triflusulfuron-methyl
molecule appears to be more systemic and/or more persistent than the
sulfonamide portion.  

Conclusions: For the purposes of this petition (9E7669) on garden beet,
the previously reviewed sugar beet metabolism study is sufficient to
support the new requested uses of triflusulfuron-methyl on garden beets.
 The proposed tolerance expression should include only the parent
compound, triflusulfuron-methyl, as determined by HED [Per memo of J.
Stokes (February 1996), meeting of 16 January 1996].

860.1300 Nature of the Residue – Livestock

MRID 42991431

Based on the characterization performed on the liver, kidney, and milk
(triazine-labeled only for milk), the principle pathways for metabolism
of triflusulfuron-methyl in the goat appear to be hydrolysis of the
sulfonylurea linkage and demethylation of the dimethylamino group
attached to the triazine ring (either before of after the sulfonylurea
linkage is split).  The triazine-labeled studies show that additional
metabolic pathways exist that involve conjugation with endogenous
proteins, producing a high proportion of covalently bound or highly
polar, soluble residue.

Conclusions: HED previously reviewed this goat metabolism study and
cited deficiencies to be addressed if additional Section 3 registrations
were pursued by the petitioner.  However, HED has determined that
measurable triflusulfuron-methyl residues above the limit of detection
(LOD; 0.005 ppm) will not be detectable in milk, meat, fat, muscle, or
meat byproducts from the existing use on sugar beets and the new
proposed use on garden beet.  Therefore, the deficiencies cited in the
HED memorandum of 7 June 1993 (J. Herndon) do not need to be addressed
for the purposes of this new food use on garden beet.  However, if
future uses on large-acreage crops such as wheat, corn, or soybean are
proposed, and consequently involve feedstuffs, then an adequate ruminant
metabolism study should be provided.

860.1340 Residue Analytical Methods

MRID 42496873 – Method AMR 1930-91

Method AMR 1930-91 is the enforcement method on record for
triflusulfuron-methyl, which was independently validated (MRID
42517103).  Frozen beet foliage or beet root samples are chopped prior
to extraction.  Samples (10 g.) are extracted with 20% acetonitrile
(ACN)/80% 0.1M (NH4)2CO3 buffer, macerated, centrifuged, and the
resulting supernatant drawn off.  The supernatant is acidified to
between pH 2-3 and recentrifuged.  The solutions are passed through
phenyl solid phase extraction (SPE) cartridges and acidified (pH <3).
The samples are further purified using a phenyl HPLC column and UV
detector (232nm).  The samples are eluted using 0.01 M potassium
phosphate in 60% methanol (pH 3.5) and the fractions eluting around
DPX-66037 (retention time, RT, verified with a standard) are collected. 
The samples are acidified to between pH 2-3 and injected onto a C18 HPLC
column, eluted with 0.01 M potassium phosphate in 42% methanol (pH 7.0),
with the DPX-66037 peak detected by UV (232nm).  The LOQ is 0.05 ppm.

MRID 42496872 – Method AMR-2021-91

This AMR 2021-91 method is very similar to the enforcement method, AMR
1930-91.  By using automated column switching equipment for the columns
and eluate, the sample transfer from the phenyl to C18 column can occur
automatically.  In addition, without the sample loss that occurs in the
transfer of sample from the phenyl to C18 column (only 2 mL of the 10 mL
is transferred to the C18 column in the AMR 1930-91 method), the method
is able to achieve a lower LOQ (the registrant claims 0.02 ppm).  For
sugar beet roots at fortifications from 0.020 to 1.00, the registrant
achieved recovery values from 89 to 111% (average recovery of 101%,
standard deviation of 7%).  For sugar beet foliage at fortifications
from 0.020 to 1.00, the registrant achieved recovery values from 89 to
106% (average recovery of 98%, standard deviation of 5%).

MRID 48207101 – Method 4480 

E.I. du Pont’s Method 4480 is proposed as a data-gathering method in
plant matrices for the determination of residues of
triflusulfuron-methyl (also referred to as DPX-66037).  Two separate
HPLC protocols were developed, differing in detection instrumentation,
with similar extraction and clean-up procedures for both methods.

ed with 0.1 M acetic acid and subjected to sequential clean-up by SPE
using Bond Elut® and/or Oasis™ HLB cartridges.  Residues of
triflusulfuron-methyl are eluted with ACN, and the eluate is evaporated
to dryness and redissolved in methanol (MeOH)/water (25:75, v:v) prior
to analysis by reverse-phase HPLC, with either tandem mass spectrometry
(MS/MS) or ultraviolet (UV) detection.

n sugar beet and red beet samples spiked at the LOQ and analyzed by
HPLC/MS/MS following Oasis™ HLB clean-up only, recoveries ranged from
81% to 104%, with all standard deviations (SDs) less than or equal to
8%.  In samples cleaned-up by sequential application to SAX and Oasis™
HLB cartridges and analyzed by HPLC/MS/MS, recoveries in the same
matrices ranged from 82% to 101% when spiked at the LOQ, with SDs less
than or equal to 10%.   In samples spiked at the LOQ and analyzed by
column-switching HPLC-UV, recoveries ranged from 82% to 105%, with SDs
less than or equal to 10%.  The good recoveries and low SDs in spiked
samples indicate that Method 4480 is reliable and reproducible,
regardless of the clean-up procedures and detection methods used.

Control chromatograms were provided for sugar beet foliage, sugar beet
root, red beet foliage and red beet root.  No interferences were noted
at or near the RTs of triflusulfuron-methyl, indicating that the method
is specific for the analyte in question.  There was no interference from
reagents reported.  Detector linearity was demonstrated for both
methods, with coefficients of determination (r2) greater than 0.9900 in
sugar beet foliage analyzed by HPLC/MS/MS and red beet foliage analyzed
by column switching HPLC-UV.  Extraction efficiency was not demonstrated
for Method 4480.

Conclusions: The review of Method 4480 was originally completed by PMRA,
but has been reviewed by HED and is consistent with OCSPP policy.  An
adapted version of Method 4480 was utilized in the garden beet field
trials submitted for this new use petition.  

The independent laboratory validation (ILV) of Method 4480 successfully
demonstrated the reliability of the HPLC/MS/MS method for the analysis
of residues of triflusulfuron-methyl in sugar beet foliage and sugar
beet roots on the first attempt.  Method 4480 also included a
scientifically acceptable rationale to waive the requirement of a
radiovalidation study for this method, based on the similarities in
extraction steps between this method and those employed in a
corresponding sweet potato metabolism study (received and reviewed by
PMRA).  Therefore, method 4480 is considered acceptable as a
data-gathering and enforcement method for the determination of
triflusulfuron-methyl in plant matrices (including garden beets).  

The enforcement method on record for triflusulfuron-methyl is method AMR
1930-91 (MRID 42496873).  Method AMR 2021-91 (MRID 42496872) is very
similar to AMR 1930-91 and was used in the previously submitted sugar
beet and chicory field trials.  Method 4480 is also similar to both
these methods, with the primary difference being the addition of a
tandem mass spectrometric detection protocol in Method 4480.  The
registrant should clarify whether they want to replace the existing
enforcement method with Method 4480 when applying for future new uses,
as this newer method appears to be an acceptable enforcement method.    
   

860.1360 Multiresidue Methods 

MRID 42496874

Analysis of DPX-66037 was not applicable to FDA Multi-Residue Protocol A
(due to lack of N-methylcarbamate structure), Protocol B (due to lack of
an acid of phenol structure), or Protocol E (due to lack of adequate
recovery from Florisil).  Testing through Protocol C produced responses
that were greater than 50% full scale deflection using several
column/detector combinations. The laboratory noted that these responses
may have been due to thermal degradation of DPX-66037 rather than
elution of DPX-66037 itself.  Recoveries of DPX-66037 from sugar beets
were tested using Protocol D.  A 2% diethylene glycol succinate (DEGS)
on Chromosorb W-AW packed column was used in conjunction with an
electrolytic conductivity detector (ELCD) operated in the nitrogen mode.
 The following recoveries were achieved: 67 and 99% recovery from 0.02
ppm fortifications, and 92 and 106% recovery from 0.1 ppm
fortifications.

Conclusions:  FDA’s multiresidue method Protocol D is suitable for
analysis or enforcement of triflusulfuron-methyl residues.  This
information was previously forwarded to FDA.

860.1380 Storage Stability

Previously submitted storage stability data indicate that
triflusulfuron-methyl in/on sugar beet roots and tops is stable for
periods of up to 18 months when stored frozen at -25(C.  The storage
stability data submitted in support of the proposed use in garden beet
roots and tops (leaves) demonstrated that residues were stable for up to
~15 months (436 days) when stored frozen at -29(C to -10(C.  

Conclusions:  The available storage stability data indicate that
residues of triflusulfuron-methyl are stable in frozen storage for up to
approximately 15 months.  Samples from the garden beet residue field
trials were stored for up to ~13 months (381 days).  Therefore no
additional storage stability data are needed for the proposed use on
garden beet.

860.1400 Water, Fish, and Irrigated Crops

There are no proposed uses for triflusulfuron-methyl that are germane to
this guideline.  No evaluation is necessary at this time.

860.1460 Food Handling

There are no proposed uses for triflusulfuron-methyl that are germane to
this guideline.  No evaluation is necessary at this time.

860.1480 Meat, Milk, Poultry, and Eggs

In an earlier review (PP#4F4278), the petitioner was granted a waiver of
ruminant and poultry feeding studies (and the tolerances in meat, milk,
poultry, and egg associated with them) for the existing use on sugar
beets. 

The ruminant feeding study waiver was granted on the basis of estimated
dietary consumption by dairy cattle of triflusulfuron-methyl from the
three feed items associated with sugar beets – leaves, molasses, and
dried pulp.  In the goat metabolism study the highest residue values
(total radioactivity, expressed as triflusulfuron-methyl equivalents)
occurred in the kidneys at 0.66 ppm and liver at 0.61 ppm (based on
feeding 10 ppm of triazine-labeled triflusulfuron-methyl in the diet). 
The maximum expected residue level in ruminant liver/kidney was found to
be <0.003 ppm, well below the LOQ of the enforcement methodology for
triflusulfuron-methyl residues in sugar beet commodities and the likely
LOQ of a reasonable livestock analytical method.   

There are no ruminant feed items associated with the new proposed use on
garden beets.  Therefore this new use should have no additional impact
on the estimated ruminant dietary consumption of triflusulfuron-methyl. 


Sugar and garden beet products are not utilized as poultry feedstuffs,
therefore triflusulfuron-methyl residues would not be expected in
poultry commodities.   

Conclusions:  Using information in the goat metabolism studies, residues
of triflusulfuron-methyl (as defined by the livestock residue
definition) are expected to be below the LOQ of a reasonable livestock
analytical method.  Hence a 40 CFR 180.6(a)(3) situation (no expectation
of finite residues) exists.  Neither feeding studies nor tolerances in
livestock commodities are required at this time.  Feeding studies and
analytical methods may be required to support future uses of
triflusulfuron-methyl that involve significant livestock feed items. 

860.1500 Crop Field Trials

Sugar Beet  

MRID 42496868, 42496867

No additional field trial residue data for sugar beets were submitted in
this petition.  The registrant previously provided 3 volumes of residue
data on sugar beet in PP 3G4161 (MRID#’s above, see 6/7/93 G. J.
Herndon review, D184250).

The registrant conducted residue trials in 1991 at sites in North
Dakota, Michigan, Colorado, Nebraska, and California. These 5 states
account for 47% of the sugar beet for sugar production

(Agricultural Statistics, 1994, USDA).  Three applications of a 50% DF
formulation were made one week apart to each treated plot at 0.5 or 1.0
oz ai/A (0.03 or 0.06 lb ai/A), which corresponds to between 2X and 4X
the maximum proposed seasonal use rate.  Samples were harvested between
101 and 126 days after the last application.  The samples were stored up
to 8 months between harvest and analysis. The samples were analyzed by
method AMR 2021-91 (MRID 42496872) for the parent compound (average
recovery 92%), and method AMR 2187-91 (MRID 42496875) for the 3 triazine
metabolites (average recoveries of 79 to 81%).  No residues of
triflusulfuron-methyl, or its metabolites D8526, E7710, or M7222 were
found in any of the samples (0.05 ppm LOQ for each analyte; LOD
estimated at 0.005 ppm for parent and 0.02 ppm for triazine
metabolites).

	

The registrant included additional, non-GLP data from trials conducted
in France.  At similar application rates and PHIs from 119 to 162 days,
no triflusulfuron-methyl was found (0.02 ppm LOD).  No residues of D8526
or E7710 were found in any samples.  Quantities of M7222 were detected
in sugar beet foliage at levels up to 0.05 ppm at 160 days.  This is
based on an LOD of 0.02 ppm. 

The registrant conducted field trials to determine the decline of
triflusulfuron-methyl residues and the formation and decline of residues
of the triazine metabolites D8526, E7710, and M7222 in sugar beet over
time (MRID 42496867).  Field trials were conducted in Idaho, North
Dakota, and California in 1990 and 1991.  Three applications of either
40% or 50% DF formulations were made one week apart at either 0.4 or 0.8
oz ai/A (0.025 or 0.05 lb ai/A) or 0.5 or 1.0 oz ai/A (0.03 or 0.06 lb
ai/A), which corresponds to between 1.6X and 4X the maximum proposed
seasonal use rate.  Samples were harvested at intervals of about 0, 7,
14, 28, 56, 84, and 112 days following the last application.  The whole
plant was analyzed up to 28 days after last application; at 56 days and
beyond, tops and roots were analyzed separately.  The samples were
stored up to 18 months between harvest and analysis.  The samples were
analyzed by method AMR 2021-91 for the parent compound (average recovery
93%), and method AMR 2187-91 for the 3 triazine metabolites (average
recoveries of 82 to 86%).  Up to 2.56 ppm of triflusulfuron-methyl was
found on the whole beet plants at 0 days after treatment (DAT).  At the
next harvest, 7 DAT, and beyond, no parent was detected in any of the
samples (the next sampling of the Idaho trial occurred at 28 DAT, not 7
DAT, due to severe hail damage).  This is based on an LOD of 0.005 ppm
and an LOQ of 0.05 ppm.  At 7 DAT and beyond (28 DAT for Idaho trial),
no residues of D8526 or E7710 were found in any samples.  Trace
quantities of M7222 (0.03 ppm) were detected in sugar beet foliage as
long as 112 DAT in two of the three trials.  This is based on an LOD of
0.02 ppm and an LOQ of 0.05 ppm.

MRID 43982901

In response to the Agency's request for field trial data reflecting the
60 day PHI, additional data (MRID 43982901, see 5/14/96 J. Stokes
review, D225643) from 12 trials conducted in the US (5), Germany (6),
and Sweden (1), as well as comments on the US sugar beet production
areas and possible PHIs (based upon US agricultural growing practices
for sugar beet) were submitted.  The PHIs of the US trials ranged from
45 to 56 days at rates of 1.4 to 6 oz ai/A (0.09 to 0.375 lb ai/A; 1.9X
to 8X the proposed label seasonal maximum).  In the Germany trials
(conducted at 1.1X the maximum proposed seasonal label rate) samples
were harvested and analyzed from 15, 16, 16, 26, 34, and 53 days after
the last application.  In the Sweden trial, samples were analyzed 33
days after the last application.  Triflusulfuron-methyl residues were
not detected (<0.02 ppm) in the samples. 

Therefore, the field trial and residue decline data demonstrate that
triflusulfuron-methyl is rapidly degraded after application to sugar
beet plants.  

Chicory 

MRID 45211101

No additional field trial data was submitted with this petition.  The
results from the supervised crop field trials study (MRID 45211101; see
11/9/01 G. J. Herndon review, D279136) in chicory conducted in Mt.
Vernon, WA, La Conner, WA, Sedro Woolley, WA, and Manteca, CA, showed
that the maximum residues in chicory, collected 59 to 62 days following
the last application of triflusulfuron-methyl (as 50% ai WDG) and
treated at 0.75 oz ai/A (0.05 lb ai/A, equivalent to 1X the approved use
rate), were below the LOD (0.016 ppm).  The residues in these field
trials were determined using DuPont Method AMR 2021-91.  These data were
sufficient to establish a 0.05 ppm tolerance in chicory roots.  Data
were also provided for dry pulp and inulin, although tolerances were not
needed for these commodities.  These analytical results adequately
demonstrated that in this limited setting the proposed use pattern would
not result in residues that exceed this tolerance. 

Garden Beet

MRID 47943201

The sponsor, Interregional Research Project No. 4 (IR4), has submitted
field trial data for triflusulfuron-methyl on garden beets.  Five garden
beet field trials were conducted in the United States and 3 field trials
were conducted in Canada for a total of eight field trials conducted
during the 2005 growing season.  In the United States, trials were
located in New York (Zone 1), Ohio (Zone 5), Oregon (Zone 12), Texas
(Zone 6) and Wisconsin (Zone 5A).  In Canada, two trials were conducted
in Quebec (Zone 5B) and one trial was conducted in Ontario (Zone 5). At
each trial site, garden beets were treated with triflusulfuron-methyl
(formulated as Safari 50 DF) in 3 foliar broadcast applications at a
rate of 0.016 – 0.017 lb ai/A/application, at 5-12 day RTIs, for a
maximum seasonal application rate ranging from 0.047 – 0.049 lb ai/A. 
Garden beet roots and tops (leaves) were harvested at PHIs of 22-56
days.  A registered NIS or COC was added to the spray mixture for each
application at a rate of 0.25% v/v at all trials except the trial
conducted in Oregon.

Garden beet samples were analyzed for residues of triflusulfuron-methyl
using a modified version of DuPont method 4480 entitled “Analytical
Method for the Determination of Triflusulfuron-Methyl in sugar beets and
red beets by HPLC/MS/MS and column switching HPLC-UV” (PMRA# 1708274).
 This method has been previously reviewed and deemed acceptable for both
data-gathering and enforcement (M2005-0813 – PMRA# 1041650). 

The method was adequately validated in garden beet roots and tops at
spiking levels of 0.01 ppm, 0.10 ppm, and 1.00 ppm (recoveries ranged
from 94-118% in roots and from 90-107% in tops) indicating that the
modifications to the method did not adversely affect the method’s
data-gathering capabilities.  The instrument’s LOQ for this method was
set at the lowest level of method validation (LLMV) of 0.01 ppm for each
matrix (roots and tops).  The calculated/statistical LOQ values were
0.0069 ppm for roots and 0.0044 ppm for tops.  The
calculated/statistical LOD values were 0.0023 ppm for roots and 0.0015
ppm for tops.  Method suitability was also evaluated concurrently with
sample analysis.  Mean concurrent recoveries ± SD in garden been roots
and tops spiked with 0.01 ppm (1x LOQ) of triflusulfuron-methyl were 99
± 9% (n = 8) and 98 ± 5% (n = 8), respectively.  All recoveries fell
within the generally recognized acceptable 70-120% range indicating that
DuPont method 4480 is reliable for the determination of residues of
triflusulfuron-methyl in/on garden beet roots and tops.

Treated garden beet root and top samples were stored frozen (-29oC to
-10oC) for 299-377 days and 300-381 days, respectively.  The freezer
storage stability of triflusulfuron-methyl residues in/on garden beets
was demonstrated concurrently, with samples spiked at 0.10 ppm.  The
mean ± SD corrected residue recoveries (corrected for concurrent
recoveries of 114% and 107% in roots and tops, each spiked with 0.10 ppm
of triflusulfuron-methyl, respectively) of triflusulfuron-methyl in
samples stored frozen for 436 days were 92 ± 3% (n = 3) in roots and 92
± 2% (n = 3) in tops, indicating that no significant degradation of
residues occurred throughout this time interval.  Therefore, there are
no concerns with the stability of residues over time in this study.

Residues of triflusulfuron-methyl in/on garden beet tops (leaves) were
≤ 0.01 ppm when treated at total rates of 0.047-0.048 lb ai/A (using a
NIS/COC) and harvested at PHIs of 22-56 days.  At the Oregon trial site
where no NIS/COC was used in the spray mixtures, residues in roots and
tops treated with a total of 0.049 lb ai/A and harvested at a PHI of 24
days were all <0.01 ppm.  Residue decline behaviour was not assessed in
this study. 

TABLE 4.	Summary of Residue Data from Crop Field Trials with
Triflusulfuron-Methyl.

Commodity	Total Applic. Rate

  (g a.i./ha)	PHI (days)	Triflusulfuron-methyl Residue Levels

 (ppm)



	n	Min.	Max.	HAFT*	Median

(STMdR)	Mean

(STMR)	Std. Dev.

WITH a Non-Ionic Surfactant or Crop Oil Concentrate

Garden Beet Tops (Leaves)	53.0 – 54.3a	22-56	14	<0.01	0.01	<0.01	<0.01
<0.01	0.00

Garden Beet Roots	53.0 – 54.3	22-56	14	<0.01	<0.01	<0.01	<0.01	<0.01
0.00

WITHOUT a Non-Ionic Surfactant or Crop Oil Concentrate

Garden Beet Tops (Leaves)	54.6b	24	2	<0.01	<0.01	<0.01	<0.01	<0.01	0.00

Garden Beet Roots	54.6	24	2	<0.01	<0.01	<0.01	<0.01	<0.01	0.00

a53.0-54.3 g ai/ha =  0.047-0.048 lb ai/A

b54.6 g ai/ha = 0.049 lb ai/A

* HAFT = Highest Average Field Trial.

STMdR = supervised trial median residues

STMR = supervised trial mean residues

Std. Dev. = standard deviation

Conclusions:  The crop field trials for chicory and sugar beets were
previously classified acceptable and satisfied the guideline requirement
for crop field trials (M. Doherty, et al., D260076, 12 February 2002).  

The newly submitted crop field trials are adequate to support the
requested new use of triflusulfuron-methyl on garden beet.  The review
of these field trials was originally conducted by PMRA under a work
share agreement, but their conclusions have been reviewed by HED and are
consistent with OCSPP policy.  The freezer storage stability of
triflusulfuron-methyl residues in/on garden beets was demonstrated
concurrently, with samples spiked at 0.10 ppm stored frozen for 436
days. Analysis of these samples showed no significant degradation of
residues occurred throughout this time interval. The maximum frozen
storage time for garden beet samples was 381 days, a duration that is
shorter than the demonstrated residue stability period.  Therefore,
there are no concerns with the stability of residues over time in this
study.

The data indicates that residues of triflusulfuron-methyl in/on garden
beet roots and tops were all ≤ 0.01 ppm when treated at total rates of
0.047-0.049 lb ai/A (using a NIS/COC or not) and harvested at PHIs of
22-56 days.  It should be noted that the petition under review requests
a 30-day PHI for garden beet, whereas a 60-day PHI is currently approved
for sugar beets.  The requested 30-day PHI for garden beet is supported
by the submitted field trial data.  Of the 8 submitted garden beet field
trials, 5 were conducted at PHIs of 30 days or less (22, 23, 24, 24, 30)
and 3 at PHIs greater than 30 days (36, 42, 56).  

860.1520 Processed Food and Feed

Processing data were not submitted for garden beets.  Such data are not
required as there are no processed commodities from garden beets in
which residues are expected to concentrate.

A previously submitted processing study (MRID 42496869; see 6/7/93 G. J.
Herndon review, D184250) was performed in North Dakota where plots of
sugar beet were treated one time at 45 days before harvest with a 50% DF
formulation of triflusulfuron-methyl at the rate of 6.0 oz ai/A (0.38 lb
ai/A; 8X the proposed seasonal use rate).  At harvest, roots and tops
were separated and frozen.  Sugar beet roots were processed into white
sugar, molasses, and dried pulp, and the samples were shipped frozen to
the registrant for analysis.  Samples were analyzed using method
AMR-2021-91 with modifications made to the sample extraction step for
the processed fractions.  Recoveries were as follows: sugar (range: 85
to 104%, average: 97%), molasses (range: 83 to 97%, average: 92%), and
dried pulp (range: 86 to 111%, average: 97%).

Up to 0.033 ppm of triflusulfuron-methyl was found in the sugar beet
tops at harvest (45 DAT).  No triflusulfuron-methyl was found in the
samples of sugar beet root, the raw agricultural commodity (RAC), or in
any of the processed commodities (sugar, molasses, or dried pulp).  This
is based on a 0.01 ppm LOD.  No analyses were performed to examine if
any of the three triazine metabolites, D8526, E7710, and M7222, were
present in any of the samples.

Conclusions.  Based on the available data, the field trial and residue
decline data demonstrate that triflusulfuron-methyl is rapidly degraded
after application to sugar beet plants.  Even at exaggerated rates (8X),
no triflusulfuron-methyl was found in the sugar beet roots (RAC) or
processed commodities; therefore concentration of residues in processed
commodities is unlikely at the currently approved use rates on sugar
beets.  Additional residue decline data was not submitted for the garden
beet proposed use currently under review.  There are no known processed
commodities for garden beets in which residues are expected to
concentrate; thus, processed food and feed should not be an issue for
this new food use petition.  

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

An analytical standard for triflusulfuron-methyl is currently available
in the NPSR, via personal communication with Dallas Wright, of ACB, on
October 4 2010.  Analytical reference standards should be replenished as
requested by the Repository.  The reference standards should be sent to
the ACB, 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

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

860.1850 Confined Accumulation in Rotational Crops

A confined rotational crop study was conducted using wheat, beetroot
(red beet), and lettuce sown 30, 120, and 300 days post-application and
grown to maturity (MRID 42496865).  The study was conducted using
triflusulfuron-methyl labelled separately with carbon-14 in the triazine
ring and at the ester carbonyl position, similar to the plant and animal
metabolism studies.

The confined rotational crop studies show that cleavage of the
sulfonylurea bond also occurs readily in soil.  No parent compound was
detected in any plant commodities, even from the shortest rotation
interval of 30 days, suggesting that it is rapidly cleaved and/or not
translocated.  However, the triazine side of the triflusulfuron-methyl
molecule appears to be more systemic and/or more persistent than the
sulfonamide portion.  Uptake of triazine residues into wheat straw has
been observed.

Conclusions: Additional rotational crop studies or rotational crop
tolerances are not needed at this time.  Such studies may be needed if
uses are proposed on major crops (e.g., wheat, cotton, corn, soybeans)
due to the observed uptake of triazine-derived soil residues into wheat
straw in the confined study.  [See memo of J. Stokes (31 January 1996)
for HED meeting of 16 January 1996].

860.1900 Field Accumulation in Rotational Crops

Additional rotational crop studies or rotational crop tolerances are not
needed at this time.  Such studies may be needed if uses are proposed on
major crops (e.g., wheat, cotton, corn, soybeans).

860.1550 Proposed Tolerances

At this time, tolerances are not required in livestock commodities.  For
plant commodities, existing tolerances are in place for the previously
assessed sugar beets and chicory.   New tolerances in/on garden beets
are being requested in the petition under review (Petition 9E7669).  The
registrant has proposed that tolerances for the residues of the
herbicide triflusulfuron-methyl, or methyl
2-[[[[[4-(dimethylamino)-6-(2,2,2-trifluoroethoxy)-1,3,5-triazin-2-yl]am
ino]carbonyl]amino]sulfonyl]-3-methylbenzoate, be established on garden
beet roots at 0.01 ppm (parent only) and sugar beet tops at 0.02 ppm
(parent only).  For the purposes of this tolerance petition, the
compound to be regulated is parent only.  

A summary of the petitioned-for tolerances and HED’s recommendations
is provided in Table 5, below.  The requested new use on garden beet is
being assessed as part of a work share agreement with Canada’s PMRA. 
Therefore, implemented tolerances stemming from this new use will be
harmonized with the PMRA review.  The recommended tolerance for garden
beet roots of 0.01 ppm is identical to that of PMRA’s, with all garden
beet roots having concentrations less than the LOQ of 0.01 ppm in
observed field trials.  However, the recommended tolerance of 0.02 ppm
for garden beet tops is not harmonized with PMRA’s value of 0.01 ppm. 
Based on the submitted garden beet field trial data, garden beet tops
had concentrations equal to 0.01 ppm at a single field trial in Texas
(Trial 08043.05-TX*19).  Given the level of uncertainty for
quantification around the LOQ of 0.01 ppm and the limited number of
field trials, HED does not consider setting the garden beet top
tolerance at 0.01 ppm to be appropriate.  Therefore, HED is concurring
with the registrant-proposed tolerance of 0.02 ppm for garden beet tops.
    

Table 5.  Tolerance Summary for Triflusulfuron-methyl

Commodity	Proposed Tolerance (ppm)	Recommended Tolerance (ppm)	Comments
(correct commodity definition)

Beet, garden, roots	0.01	0.01	--

Beet, garden, tops	0.02	0.02	--



References

Triflusulfuron-methyl: Human Health Risk Assessment for the Section 3
Registration on Sugar

Beets (PP#4F4278) and Chicory (PP#0E6214).  (M. Doherty, Ph.D., D260076;
February 2002)    

PP#4F4278. Triflusulfuron-methyl (DPX-66037) on Sugarbeets.  Evaluation
of Analytical Method and

Residue Data. MRID#s 429914-01, 429914-02, and 429914-31.  DP Barcodes#
211798 and 211802.

CBTS# 15084 and 15085.  (J. Stokes, January 31, 1996)  

PP#4F4278. Triflusulfuron-methyl (DPX-66037) In/On Sugarbeet. 
Additional Comments on Proposed 60-Day PHI.  Product Chemistry.  MRID#s
439829-00 and 439829-01.  DP Barcode# D225643.  (J. Stokes, May 14,
1996)

PP#3G04161. Temporary Tolerance Petition and Experimental Use Permit for
Use of Triflusulfuron-methyl (DPX-66037) on Sugar Beets; 000352-EUP-RAN.
Evaluation of Analytical Method and Residue Data.   (G. J. Herndon,
D184250, 6/7/93)

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48207101	Peterson, B.; Walker, D.; Cabusas, M. (2001) Analytical Method
for the Determination of Triflusulfuron-Methyl in Sugar Beets and Red
Beets by HPLC/MS/MS and Column-Switching HPLC-UV. Project Number:
AAFC03/003, XENO3/88, AAFCO3/003/OCR. Unpublished study prepared by E.I.
du Pont de Nemours and Company. 35 p.

	42991431	Hawkins, D.; Kirkpatrick, D.; Dean, G.; et al. (1993) The
Metabolism of (carbon-14)-DPX-66037 in the Goat Following Administration
at a Level Equivalent to 10 PPM in the Diet: Lab Project Number: AMR
1640-90: HRC/DPT 244/911287. Unpublished study prepared by Dept. of
Chemical Metabolism & Radiosynthesis, Huntingdon Research Centre Ltd.
123 p. 	20-Oct-1993



Attachment 1 – International Residue Limits 

Triflusulfuron-methyl (PC Code 129002; 10/01/10)

Summary of US and International Tolerances and Maximum Residue Limits 

Residue Definition: 

US	Canada	Mexico2	Codex3

40 CFR 180.492:

Plants: triflusulfuron methyl
2-[[[[[4-(dimethylamino)-6-(2,2,2-trifluoroethoxy)-1,3,5-triazin-2-yl]am
ino]carbonyl]amino]sulfonyl]-3-methylbenzoate	methyl
2-[4-dimethylamino-6-(2,2,2-trifluoroethoxy)-1,3,5-triazin-2-ylcarbamoyl
sulfamoyl]- m-toluate

None

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

	US	Canada	Mexico2	Codex

Beet, garden, roots	0.01	None



Beet, garden, tops	0.02









































































































	Completed: M. Negussie; 10/05/10

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.

Triflusulfuron-methyl (129002)	      Summary of Analytical Chemistry and
Residue Data	Barcode:  D388620

Page   PAGE  1  of   NUMPAGES  21 

