UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460      

	OFFICE OF CHEMICAL SAFETY

	AND POLLUTION PREVENTION

	

MEMORANDUM

Date:   October 3, 2012

			

SUBJECT:	1-Naphthaleneacetic acid (NAA), its salts, ester, and acetamide
.  Expansions of Existing Crop Group/Representative Commodity Uses to
Fruit, Pome, Group 11-10 and New Uses in/on Avocado, Mango, Mamey
Sapote, and Rambuttan.  Summary of Analytical Chemistry and Residue
Data. 

PC Code:  056002	DP Barcode:  399621

Decision No.: 461439	Registration Nos.:  5481-429 and 5481-541

Petition No.:  2E7991	Regulatory Action:  Amended Section 3

Risk Assessment Type:  NA	Case No.:  0379

TXR No.:  NA	CAS No.:  86-87-3

MRID Nos.:  48749901 and 02	40 CFR:  180.155

		              									

FROM:		Gary Otakie, Chemist

	Risk Assessment Branch 4

	Health Effects Division (7509P)

THROUGH:	Susan V. Hummel, Senior Scientist

				Elissa Reaves, PhD., Branch Chief

	Risk Assessment Branch 4

		Health Effects Division (7509P)

			

TO:			Thurston Morton, Risk Assessor

	Risk Assessment Branch 4

				Health Effects Division (7509P)

 				

				And

				Laura Nollen/Barbara Madden

				Risk Integration, Minor Use & Emergency Response Branch

				Registration Division (7505P)	

Action Requested

Under PP#2E7991, The Interregional Research Project Number 4 (IR-4) has
submitted a petition for the establishment of permanent tolerances for
residues of the plant growth regulator 1-Naphthaleneacetic acid (NAA) in
conjunction with requests for amended Section 3 registrations of  the
two pesticide formulations:  TRE-HOLD Sprout Inhibitor A112, and
Fruitone N.  The petitioner is proposing the establishment of the
following permanent tolerances for residues of NAA:

Avocado…..	0.05  ppm

Mango	0.05  ppm

Mamey Sapote                 …………………………………….
0.05 ppm

Rambuttan  ……………. …………………………………….
3.0  ppm

Fruit, pome, group 11- 10	………0.15  ppm

Discussion

1-Naphthaleneacetic acid (NAA), its salts, ester, and acetamide are
plant growth regulators (PGR) which are collectively referred to as
naphthalene acetates. The PGR activity of NAA is due to its structural
similarity to the natural plant hormone indole acetic acid (IAA). They
are currently registered for use on various orchard and fruit crops to
prevent preharvest drop of fruits, thin fruit trees, and delay flower
induction. They can also stimulate growth and delay leaf drop on
ornamentals.

New residue chemistry data on avocado and rambuttan were submitted to
support these uses, except for the Fruit, pome,  group 11-10, which is
an expansion of the current crop group tolerance on “Fruit, pome,
group 10”, and relies on existing residue data.

 Residues of NAA were below the LOQ (<0.05 ppm) in/on avocado harvested
9-11 days following either one or two paintbrush or sponge applications
of a 1.27-1.30% ai solution of the 15.1% EC formulation of NAA ethyl
ester.  

Following one foliar directed application of the 3.5% SC formulation of
NAA sodium salt at 90 and 900 ppm (i.e. 1X and 10X), respectively,
residues (and per trial averages) of NAA in/on rambutan fruit harvested
at a 2-day PHI were 0.0786-0.636 (0.108-0.621) and 1.25-5.06 (1.35-4.95)
ppm.  

There are an adequate number of avocado and rambuttan field trials with
acceptable field trial  data from representative geographical locations.


A tolerance level of 0.15 ppm, for Fruit, pome, group 11-10 is
appropriate to cover the  use of NAA on the Fruit group 11.  The
Organisation for Economic and Co-operation Development (OECD) Tolerance
Estimation Procedures were used to determine appropriate tolerance
levels for Rambuttan, while for avocado the tolerance is based of the
level of quantitation (0.05 ppm).  A tolerance of 2.0 ppm rather than
3.0 ppm is required for rambuttan. Note that this tolerance level is
different than that proposed by the petitioner who used NAFTA tolerance
estimation procedures.  

Tolerances are established under 40CFR§180.155(a) for the combined
residues of 1-naphthaleneacetic acid and its conjugates calculated as
1-naphthaleneacetic acid from the application of 1-naphthaleneacetic
acid, its ammonium, sodium, or potassium salts, ethyl ester, and
acetamide in/on sweet cherry, fruit pome group 11, olive, orange,
pineapple, and tangerine.  A time-limited tolerance under
40CFR§180.155(b) is also established for avocado (expires 12/31/12) in
connection with a Section 18 emergency exemption.  The established
tolerances range from 0.05 ppm to 0.15 ppm.

The current tolerance expression for NAA is not in accord with our
current guidance.   See Conclusion below for appropriate wording.

Conclusion

  SEQ "CHAPTER" \*Arabic  1 

In brief, a revised Section F proposing a tolerance of 2.0 ppm for NAA
in/on Rambuttan is required.

HED has examined the residue chemistry database for NAA..  With regards
to NAA for PP#2E7991, pending submission and revised Sections B and  F
(see requirements under Recommended Label Changes and Tolerance
Recommendations), there are no residue chemistry issues that would
preclude granting amended  registrations for amended Section 3
registrations of six pesticide formulations: containing NAA for use on a
variety of crops, and  to expand currently registered foliar uses or
establishment of tolerances for residues of NAA only in/on the following
commodities:

Avocado…..	0.05  ppm

Mango	0.05  ppm

Mamey Sapote                 …………………………………….
0.05 ppm

Rambuttan  ……………. …………………………………….
2.0  ppm

Fruit, pome, group 11-10	………0.15  ppm

The amended registrations are limited to expansions to add the
commodities specified under the new crop groups/subgroups and Avocado,
Mango, Mamey Sapote, Rambuttan and do not include substantive changes to
currently registered use patterns (i.e., maximum use rates, retreatment
intervals, preharvest intervals, use of adjuvants, etc.).  

Tolerance Recommendations

A revised Section F is needed, proposing tolerances as follows:

Avocado…..	0.05  ppm

Mango	0.05  ppm

Mamey Sapote                 …………………………………….
0.05 ppm

Rambuttan  ……………. …………………………………….
2.0  ppm

Fruit, pome, group 11-10	………0.15  ppm

The current tolerance expression for NAA is not in accord with our
current guidance.  The tolerance expression should read:

Tolerances are established for the combined residues of
1-naphthaleneacetic acid, including its metabolites and degradates in/on
avocado at 0.05 ppm, mango at 0.05 ppm,  Mamey Sapote at 0.05 ppm,
Rambuttan at 2.0 ppm, and Fruit, pome, group 11 at 0.15 ppm.  
Compliance with the tolerance levels specified is to be determined by
measuring only 1-naphthaleneacetic acid and its conjugates, calculated
as the Stoichiometric equivalent of 1-naphthaleneacetic acid, in or on
the commodity.

Recommended Label Changes.  The Fruitone L label must have a pounds per
gallon statement.  Aerial application must be made in a minimum of 10
gallons/acre.

		

A human health risk assessment is forthcoming.

Note to PM:

* Use information was taken from Section B of the petition. Only use
information for the proposed new uses on Avocado, Mango, Mamey Sapote
and Rambuttan were reviewed.  HED has not checked the labels to ensure
that use directions for currently registered uses have not been revised.
The PM must ensure that the use directions for the remaining commodities
have not changed since any changes required in the RED were made.

Tolerances should be revised, as needed, to reflect the correct
commodity definitions as specified in Table 10.  

A human heath risk assessment is forthcoming.	

 

Background

The chemical structure and nomenclature of -Naphthaleneacetic acid
(NAA), its salts, ester, and acetamide and the physicochemical
properties are presented in Tables 1 and 2.  

 

 

 

 

 

 



Common name	NAA sodium salt	NAA ethyl ester

Molecular Formula	C12H10O2Na	C14H14O2

Molecular Weight	208.2	214.26

IUPAC name	sodium-2(1naphthyl)acetate	ethyl-2(1naphthyl)acetate

CAS name	1-Naphthaleneacetic acid, sodium salt	1-Naphthaleneacetic acid,
ethyl ester

CAS #	61-31-4	2122-70-5

PC Code	056007	056008



Table 2.  Physicochemical Properties of NAA1

Parameter	Value	Reference

Active Ingredient	NAA acetamide

Melting point/range	182-184 C	Farm Chemicals Handbook

pH of 1% aqueous suspension	5.1	Product CSF

Density or specific gravity	0.221 g/cm3	Product CSF

Water solubility  (20 C)	not available

	Solvent solubility (20 C)	not available

	Vapor pressure at 20 C	not available

	Dissociation constant (pKa)	not available

	Octanol/water partition coefficient (Kow)	not available

	UV/vis  absorption spectrum	not available

	Active ingredient	NAA

Melting point/range	130 C	Farm Chemicals Handbook

pH of 1% aqueous suspension	3.45	RD D265117, 5/15/00, B. Kitchens

Density or specific gravity	0.45 g/mL	CB Nos. 3468 and 3469, 6/3/88, F.
Suhre

Water solubility  (20 C)	0.042 g/100 mL	CB Nos. 3468 and 3469, 6/3/88,
F. Suhre

Solvent solubility (20 C)	xylene 5.5 g/100 mL

CCl4 1.06 g/100 mL

freely soluble in acetone, ether, and chloroform	CB Nos. 3468 and 3469,
6/3/88, F. Suhre

Farm Chemicals Handbook

Vapor pressure at 20 C	0.3 mm Hg at 26 C	CB Nos. 3468 and 3469, 6/3/88,
F. Suhre

Dissociation constant (pKa)	3.16 x 10-4	CB Nos. 3970 and 3971, 7/5/88,
F. Suhre

Octanol/water partition coefficient (Kow)	not applicable; polar compound

	UV/vis  absorption spectrum	not available

	Active ingredient	NAA sodium salt

Melting point/range	>300 C	CB Nos. 3468 and 3469, 6/3/88, F. Suhre

pH of 1% aqueous suspension	9.1	CB Nos. 3468 and 3469, 6/3/88, F. Suhre

Density or specific gravity	0.46 g/mL	CB Nos. 3468 and 3469, 6/3/88, F.
Suhre

Water solubility  (20 C)	340 g/100 mL	CB Nos. 3468 and 3469, 6/3/88, F.
Suhre

Solvent solubility (20 C)	insoluble in nonpolar solvents	CB Nos. 3468
and 3469, 6/3/88, F. Suhre

Vapor pressure at 20 C	not available

	Dissociation constant (pKa)	3.16 x 10-4	CB Nos. 3970 and 3971, 7/5/88,
F. Suhre

Octanol/water partition coefficient (Kow)	not applicable; polar compound

	UV/vis  absorption spectrum	not available

	Active ingredient	NAA ethyl ester

Boiling point/range	>150 C	Old unreviewed Union Carbide data

pH of 1% aqueous suspension	not available

	Density or specific gravity	1.11 at 20 C	Old unreviewed Union Carbide
data

Water solubility  (20 C)	insoluble	Old unreviewed Union Carbide data

Solvent solubility (20 C)	soluble in xylene, toluene, ethanol, acetone,
and methyl ethyl ketone	Old unreviewed Union Carbide data

Vapor pressure at 20 C	not available

	Dissociation constant (pKa)	not available

	Octanol/water partition coefficient (Kow)	not available

	UV/vis  absorption spectrum	not available

	1 No physicochemical properties information was available concerning
the NAA potassium and ammonium salts.

Directions for Use

The petitioner has submitted copies of the proposed labels for Tre-Hold
Sprout Inhibitor A-112 and Fruitone L.  Tre-Hold Sprout Inhibitor A-112 
is a soluble concentrate formulation containing 15.1% NAA, ethyl ester
(1 lb/gal NAA).  Fruitone L is a soluble concentrate formulation
containing 3.5% NAA, sodium salt. The pounds per gallon statement is
missing. The proposed use directions are presented in Table 3 below.  

Table 3.  Summary of Directions for Use of NAA, potassium and sodium
salts

Applic. Timing, Type, and Equip.	Formulation

	Applic. Rate 

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

(lb ai/A)	PHI

(days)

Avocado, Mango, and Mamey Sapote

Foliar spray/

brush/sponge/ paint roller	TRE-Hold Sprout Inhibitor A-112, EPA Reg. No.
5481-429;

15.1 % NAA, ethyl ester (1 lb/ gal)	 0.078 lb ae/gal

 11 oz. product/gallon

(1.1% w/w)	

two per year



10 days



	Use Directions and Limitations:  Prune and treat pruned branches and
limbs within a few days.  Apply an average of 3 fluid ounces mixture per
tree.  A minimum 45-day RTI is specified.  The REI is 12 hours.

Rambutan 

Foliar spray	Fruitone L, EPA Reg No. 5481-541 (3.1 % NAA)	90 ppm
solution

	one per year



2 days



	Use Directions and Limitations:  Spray Rambuttan panicles to runoff. 
The REI is 12 hours.

Fruit, Pome, Group 11-10

For chemical thinning: Foliar spray, Aerial	Fruitone L, EPA Reg No.
5481-541 (3.1 % NAA)	0.5 to 4.0 fl oz/100 gal	NS	NS	Fruit set

	Use Directions and Limitations:  Apply at petal fall and/or early fruit
set.  Ensure uniform spray coverage using tree row volume.  For ground
applications use up to 500 gal water per acre.  For aerial applications,
use 5-10 gallons of water per acre.  Directions provided for apples and
pears.  For other fruits in crop group, follow directions for thinning.

To control pre-harvest drop:  Foliar spray, Aerial	Fruitone L, EPA Reg
No. 5481-541 (3.1 % NAA)	0.11	NS	150 g/A	2 days

	Use Directions and Limitations:  Use sufficient water to ensure
coverage, by air a minimum of 5 gallons.  A typical application is 8-32
fl oz per acre, made 1-4 weeks prior to harvest.  If needed, repeat at
weekly intervals.  Directions provided for apples and pears.



Conclusion.  The proposed use directions are adequate to allow
evaluation of the residue data relative to the proposed uses.  The
Fruitone L label must have a pounds per gallon statement.  Aerial
application must be made in a minimum of 10 gallons/acre.

 

860.1300 Nature of the Residue – Plants

RED Residue Chemistry Chapter D299296, 10 MARCH 2004, G. Otakie

Acceptable apple and olive metabolism studies have been previously
submitted and reviewed.  Based on the nature of residues identified from
the apple and olive metabolism studies, HED has previously determined
that the terminal residues of concern in plants are the parent
compounds, NAA and its conjugates and that the qualitative nature of the
residues in plants (i.e., orchard trees) is adequately understood.   For
purposes of the current petition the nature of the residue in plants is
adequately understood.

860.1300 Nature of the Residue - Livestock

RED Residue Chemistry Chapter D299296, 10 MARCH 2004, G. Otakie

An acceptable goat metabolism study has been previously submitted and
reviewed.  Based on these data, HED has previously concluded that the
qualitative nature of the residue in ruminants is adequately understood.
The terminal residues of concern in ruminants are the parent compounds,
NAA and its conjugates. 

The available ruminant metabolism data are adequate to support the
proposed uses. There are no poultry feed items associated with currently
registered or proposed food uses of NAA; thus a poultry metabolism study
is not required.

860.1340 Residue Analytical Methods

RED Residue Chemistry Chapter D299296, 10 MARCH 2004, G. Otakie

Enforcement and data collection methods: The residue analytical methods,
currently listed in Volume II of the Pesticide Analytical Methods, are
inadequate for the enforcement of tolerances for residues of
a-naphthaleneacetic acid (Pesticide Reg. Sec. 180.155) and
a-naphthaleneacetamide (Pesticide Reg. Sec. 180.309) in/on plant
commodities because these methods use benzene, a hazardous or toxic
reagent.

An HPLC method using fluorescence detection (Method NAA-AM-001) for
apples and peas and a similar method for olives and olive oil (Method
NAA-AM-002) has been previously submitted for determination of NAA in
plant commodities. These methods include extraction with water and
incorporate a basic hydrolysis step to release bound residues.  These
methods do not use benzene or diazomethane which are being discouraged
by the Agency for safety reasons. Theses methods have been subjected to
successful independent laboratory validations. Acceptable recoveries
were obtained from apples, olives and olive oil fortified with NAA at
the method LOQ (0.01 ppm) and at 1.0 ppm.  This method is suitable for
enforcement.

Avocado samples were analyzed using an HPLC/UV method adapted from Morse
Laboratories, Inc.  Analytical Method NAA-AM-003 entitled “Recommended
Analytical Residue Method for 1-Naphthaleneacetic Acid,
1-Naphthaleneacetamide, and/or 1-Naphthaleneacetic Acid Ethyl Ester, in
Grape (red and white), Grapefruit, Tomato, and Green Bell Pepper
Matrices”.  The method is a common moiety method that converts
residues of NAA acetamide and NAA ethyl ester to NAA.  A number of minor
modifications to the method were specified including changes in clean-up
procedures, reagents, and sample sizes.  

Rambutan samples were analyzed using an HPLC method adapted from Morse
Laboratories, Inc. Analytical Method NAA-AM-003 entitled “Recommended
Analytical Residue Method for 1-Naphthaleneacetic Acid, 1
Naphthaleneacetamide, and/or 1-Naphthaleneacetic Acid Ethyl Ester, in
Grape (red and white), Grapefruit, Tomato, and Green Bell Pepper
Matrices”.  The method is a common moiety method that converts
residues of NAA acetamide and NAA ethyl ester to NAA.  A number of minor
modifications to the method were specified including changes in clean-up
procedures, reagents, and sample sizes.  

860.1360 Multiresidue Methods

D232463, D294854, 30 OCT 2003, G. Otakie

Multiresidue method (MRM) data have been submitted previously in support
of the registration of NAA, its salts, ester and acetamide. 
Naphthaleneacetamide was found to chromatograph satisfactorily using
Pesticide Analytical Manual (PAM) Vol. I, Section 302 DG 5. 
Naphthaleneacetamide was found to produce a 50% full scale deflection
(FSD) with a 50 nanogram injection and the relative retention time to
chlorpyrifos is approximately 0.8. Average recoveries for
naphthaleneacetamide spiked into pears at approximately 0.1 ppm and 1.0
ppm were 97.8 and 104%, respectively, for Section 302, method E1,
without Florisil cleanup. Apple spikes using this procedure could not be
quantified due to interference in the apple matrix. Naphthaleneacetamide
was found not to be recoverable through Florisil, so it would not be
recoverable through Protocols E or F.  Therefore, testing under PAM Vol.
I Protocol E, for apples and pears, and Protocol F, for olives, was
suspended prior to recovery experiments through the entire Sections 303
and 304 methods.  FDA MRM’s are not suitable as enforcement methods
for NAA.

860.1380 Storage Stability

RED Residue Chemistry Chapter D299296, 10 MARCH 2004, G. Otakie

Adequate storage stability data have been submitted and reviewed for
apples, pears, and olives. These data indicate that residues of
1-naphthaleneacetic acid are reasonably stable under frozen storage
conditions in/on the above commodities for up to 12 months. 

The current submission included storage stability data which showed NAA
and NAA ethyl ester stored in frozen avocado were stable for up to 27
months and stored in frozen Rambuttan stable up to 25 months.  The
storage stabilty data adequately support the storage conditions and
samples collected from the avocado and Rambuttan field trials.

860.1400 Water, Fish, and Irrigated Crops

There are no proposed uses that are relevant to this guideline topic.

860.1460 Food Handling

There are no proposed uses that are relevant to this guideline topic.

860.1480 Meat, Milk, Poultry, and Eggs

RED Residue Chemistry Chapter D299296, 10 MARCH 2004, G. Otakie

Livestock

There are no livestock feedstuffs associated with the current new
proposed uses.  At this time, the Agency has determined that NAA is in
Category 6(a)(3) (i.e., no reasonable expectations of finite residues of
concern in meat and milk). 

Poultry

There are no poultry feed items associated with the currently registered
or proposed food/feed uses of naphthalene acetates; thus, a poultry
feeding study is not required. Tolerances for the eggs and edible
tissues of poultry need not be established.

860.1500 Crop Field Trials

48749901.der

Avocado

Residue data from the avocado crop field trials are reported in Table 1.
 A summary of the residue data is presented in Table 2.  Residues of NAA
were below the LOQ (<0.05 ppm) in/on avocado harvested 9-11 days
following either one or two paintbrush or sponge applications of a
1.27-1.30% ai solution of the 15.1% EC formulation of NAA ethyl ester. 
Applications made to cut surface and surrounding branches. Samples were
harvested from each plot at a 2-day PHI.

In the residue decline trial, residues of NAA in/on avocado were below
the LOQ at all PHIs; therefore, residue decline could not be assessed.  

TABLE  6	Residue Data from Avocado Field Trials with NAA ethyl ester.

Trial ID (City, State; Year)1	Zone	Avocado

Variety	Commodity	Total Rate

(% solution)	PHI

(days)	NAA Residues2 [Average]

Homestead, FL; 2006 (-FL41)	3	Lula	Fruit	1 x 1.27%	10	<0.050, <0.050
[<0.050]





2 x 1.27%	11	<0.050, <0.050 [<0.050]

Exeter, CA; 2006 (-CA95)	10	Zutano	Fruit	1 x 1.27%	10 	<0.050, <0.050
[<0.050]





2 x 1.27%	9	<0.050, <0.050 [<0.050]

Irvine, CA; 2006 (-CA96, -CA97, and -CA98) [Target PHI]	10	Hass	Fruit	1
x 1.28-1.30%	10-11	<0.050, <0.050, <0.050, <0.050, <0.050,

<0.050 [<0.050]





2 x 1.28-1.30%	10	<0.050, <0.050, <0.050, <0.050, <0.050,

<0.050 [<0.050]

Irvine, CA; 2006 (-CA96) [Additional Decline PHIs]	10	Hass	Fruit	1 x
1.30%	1	<0.050, <0.050 [<0.050]





	7 	<0.050, <0.050 [<0.050]





	15	<0.050, <0.050 [<0.050]





	21	<0.050, <0.050 [<0.050]





2 x 1.30%	1	<0.050, <0.050 [<0.050]





	6 	<0.050, <0.050 [<0.050]





	14 	<0.050, <0.050 [<0.050]





	21	<0.050, <0.050 [<0.050]

1  HED has concluded that trials -CA96/-CA97/-CA98 constitute a single
trial with replicate samples for purposes of 860.1500 data requirements.

2  A total of two applications of solution were made at each trial site,
with samples collected after each application.

3  Residues of NAA ethyl ester were determined by a common moiety method
that converts residues of NAA acetamide and NAA ethyl ester to NAA.  The
LOQ was 0.05 ppm.  

TABLE  7  Summary of Residue Data from Avocado Field Trials with NAA
ethyl ester.

Commodity	Analyte	Total

Rate

(% solution)	PHI (days)	Residue Levels (ppm)1





n	Sample Min.	Sample Max.	LAFT2	HAFT2	Median	Mean	Std.  Dev.

Avocado, Fruit	NAA3	2 x 1.28-1.30%	10-11	3	<0.05	<0.05	<0.05	<0.05	0.05
0.05	N/A



2 x 1.28-1.30%	9-11	3	<0.05	<0.05	<0.05	<0.05	0.05	0.05	N/A

1  Except for sample min/max, values reflect per trial averages; n = no.
 of field trials.  N/A = not applicable.

2  LAFT = lowest average field trial; HAFT = highest average field
trial.

3  Residues of NAA ethyl ester were determined by a common moiety method
that converts residues of NAA acetamide and NAA ethyl ester to NAA.  

An issue was raised about the separation distance for the avocado field
trials.  The petitioner indicated that since the study was conducted in
2006, the trial separation guidance developed for 2012 studies was not
achievable because of the unique application method used in the study.

Conclusions

The submitted avocado field trial data are adequate.  Residues of NAA
were  below the LOQ (<0.05 ppm) in/on avocado harvested 9-11 days
following either one or two paintbrush or sponge applications of a
1.27-1.30% ai solution of the 15.1% EC formulation of NAA ethyl ester. 
In the residue decline trial, residues of NAA in/on avocado were below
the LOQ at all PHIs; therefore, residue decline could not be assessed.  

An acceptable method was used for residue quantitation, and adequate
data were submitted to support sample storage intervals and conditions.

48749902.der

Rambuttan

Residue data from the rambutan field trials are reported in Table 3.  A
summary of the residue data are presented in Table 4.  Following one
foliar directed application of the 3.5% SC formulation of NAA sodium
salt at 90 and 900 ppm, (i.e. 1X and 10X) sprayed to runoff
respectively, residues (and per trial averages) of NAA in/on rambutan
fruit harvested at a 2-day PHI were 0.0786-0.636 (0.108-0.621) and
1.25-5.06 (1.35-4.95) ppm.  

Residue decline data were not submitted and are not needed for crops
requiring three or fewer trials.

TABLE  8	Residue Data from Rambutan Field Trials with NAA sodium salt.

Trial ID (City, State; Year)	Zone	Rambutan

Variety	Commodity	Total Rate

(ppm)	PHI

(days)	NAA Residues1 [Average]

Kurtistown, HI; 2007 (-HI08)	13	Jit Lee	Fruit	90	2	0.0786, 0.137 [0.108]





900	2	1.25, 1.44 [1.35]

Pepeekeo, HI; 2007 (-HI09)	13	Jit Lee	Fruit	90	2	0.605, 0.636 [0.621]





900	2	4.83, 5.06 [4.95]

1  Residues were determined by a common moiety method that converts
residues of NAA acetamide and NAA ethyl ester to NAA.   Per trial
averages were calculated by the study reviewer.

TABLE  9  Summary of Residue Data from Rambutan Field Trials with NAA
sodium salt.

Commodity	Analyte	Total Rate

(ppm)	PHI (days)	Residue Levels (ppm)1





n	Sample Min.	Sample Max.	LAFT2	HAFT2	Median	Mean	Std.  Dev.

Rambutan, Fruit	NAA3	90	2	2	0.0786	0.636	0.108	0.621	0.365	0.365	0.363



900	2	2	1.25	5.06	1.35	4.95	3.15	3.15	2.55

1  Except for sample min/max, values reflect per trial averages; n = no.
of field trials.  

2  LAFT = lowest average field trial; HAFT = highest average field
trial.

3  Residues were determined by a common moiety method that converts
residues of NAA acetamide and NAA ethyl ester to NAA.   Per trial
averages were calculated by the study reviewer.

Conclusions

The submitted rambutan field trial data are adequate.  Following one
foliar directed application of the 3.5% SC formulation of NAA sodium
salt at 90 and 900 ppm, respectively, residues (and per trial averages)
of NAA in/on rambutan fruit harvested at a 2-day PHI were 0.0786-0.636
(0.108-0.621) and 1.25-5.06 (1.35-4.95) ppm.  Residue decline data were
not submitted.

An acceptable method was used for residue quantitation, and adequate
data were submitted to support sample storage intervals and conditions.

Summary - Pome Fruit Group (Crop Group 11-10)

Representative crops for the pome fruit crop group are apples and pears.

D306440, 04/30/2009, G. Otakie

Per the referenced review this tolerance was revised to 0.15 ppm in
2009:

“New HED tolerance assessment procedures incorporating statistical
procedures (i.e. NAFTA MRL Calculator) subsequent to the NAA
Registration Standard indicate the 0.1 ppm tolerance for NAA in/on Pome
Fruits should be raised to 0.15 ppm.”

860.1520 Processed Food and Feed

There are no processed commodities associated with the proposed uses in
the current petition

860.1650 Submittal of Analytical Reference Standards

Analytical reference standards for NAA are available at the EPA National
Pesticide Standards Repository.  The tolerance expression includes only
NAA, so this is sufficient.

860.1850/ 860.1900 Confined/Field Accumulation in Rotational Crops

There are no rotational crop data requirements associated with the
proposed uses in the current petition. 

860.1550 Proposed Tolerances

Tolerances are established under 40CFR§180.155(a) for the combined
residues of 1-naphthaleneacetic acid and its conjugates calculated as
1-naphthaleneacetic acid from the application of 1-naphthaleneacetic
acid, its ammonium, sodium, or potassium salts, ethyl ester, and
acetamide in/on sweet cherry, fruit pome group 11, olive, orange,
pineapple, and tangerine.  A time-limited Section 18 emergency exception
tolerance under 40CFR§180.155(b) is also established for avocado
(expires 12/31/12).  The established tolerances range from 0.05 ppm to
0.15 ppm.  

No Codex, Canadian, or Mexican maximum residue limits (MRLs) have been
established for residues of (NAA), its salts, ester, and acetamide for
the use in this petition..

Table  10	Tolerance Summary for NAA

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

Tolerances Proposed Under PP#2E7991

Avocado	0.05



Mango	0.05



Mamey Sapote	0.05



Rambuttan	3.0	2.0

	Fruit, pome, group 11-10	0.15

















	Tolerances That Need Amended Under PP#2E7991

Rambuttan	Proposed  3.0  ppm (Section F)

	2.0	---



Attachments:  

Appendix I – Tolerance Assessment Calculations

F.	DOCUMENT TRACKING

RDI:  G. Otakie  10/03/12;  S. Hummel  10/03/12

Petition Number: 2E7991

DP#: 399621

PC Code: 129032

Template Version September 2005 

Appendix I – Tolerance Assessment Calculations

NAA

Rambutan

US

90 ppm 2-day PHI

 	 

Total number of data (n)	4

Percentage of censored data	0%

Number of non-censored data	4

Lowest residue	0.079

Highest residue	0.636

Median residue	0.371

Mean	0.364

Standard deviation (SD)	0.297

Correction factor for censoring (CF)	1.000

 	 

Proposed MRL estimate	 

 	 

- Highest residue	0.636

- Mean + 4 SD	1.553

- CF x 3 Mean	1.092

Unrounded MRL	1.553

 	 

Rounded MRL	2

 	 

 High uncertainty of MRL estimate.

[Small dataset]



Residues (mg/kg)	n

0.0786	1

0.137	1

0.605	1

0.636	1



NAA	Summary of Analytical Chemistry and Residue Data	DP#:   D399621

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