	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

OFFICE OF CHEMICAL SAFETY AND

POLLUTION PREVENTION

MEMORANDUM

Date:		15-October-2011

Subject:	Spirodiclofen in/on Sugar Apple, Cherimoya, Atemoya, Custard
Apple, Ilama, Soursop, Biriba, Lychee, Longan, Spanish Lime, Rambutan,
Pulasan, Guava, Feijoa, Jaboticaba, Wax Jambu, Starfruit, Passionfruit,
Persimmon, and Acerola.  Summary of Analytical Chemistry and Residue
Data.

PC Code:  124871	DP Barcode:  D387339

Decision No.:  443557	Registration No.:  264-831

Petition No.:  0E7820	Regulatory Action:  Section 3 

Risk Assessment Type:  not applicable	Case No.:  7443

TXR No.:  not applicable	CAS No.:  148477-71-8

MRID Nos:  48332901, 48332902, and 48332903	40 CFR:  180.608



From:		Tom Bloem, Chemist

Risk Assessment Branch 1, Health Effects Division (RAB1/HED; 7509C)

Through:	George F. Kramer, Ph.D., Senior Chemist

		HED/RAB1 (7509P)

To:		Barbara Madden/Laura Nollen (RM 05)

		Registration Division (RD; 7505P) 

Interregional Research Project Number 4 (IR-4; Princeton, NJ) proposed a
Section 3 registration for application of spirodiclofen
(3-(2,4-dichlorophenyl)-2-oxo-1-oxaspiro[4.5]dec-3-en-4-yl
2,2-dimethylbutanoate; see attachment 1 for structure) to sugar apple,
cherimoya, atemoya, custard apple, ilama, soursop, biriba, lychee,
longan, Spanish lime, rambutan, pulasan, guava, feijoa, jaboticaba, wax
jambu, starfruit, passionfruit, persimmon, and acerola.  In conjunction
with the request, the petitioner proposed the establishment of the
following spirodiclofen per se tolerances:  sugar apple - 0.45 ppm;
cherimoya - 0.45 ppm; atemoya - 0.45 ppm, custard apple - 0.45 ppm;
ilama - 0.45 ppm; soursop - 0.45 ppm; biriba - 0.45 ppm; lychee - 3.5
ppm; longan - 3.5 ppm; Spanish lime - 3.5 ppm; rambutan - 3.5 ppm;
pulasan - 3.5 ppm; guava - 0.45 ppm; feijoa - 0.45 ppm; jaboticaba -
0.45 ppm; wax jambu - 0.45 ppm; starfruit - 0.45 ppm; passionfruit -
0.45 ppm; persimmon - 0.45 ppm; and acerola - 0.45 ppm.

Executive Summary

Background:  Spirodiclofen is a tetronic acid with acaricidal action
(group 23).  It acts by interfering with mite development and controls
such pests as Panonychus spp., Phyllocoptruta spp., Brevipalpus spp.,
and Aculus and Tetranychus species.  The petitioner stated that
spirodiclofen is active by contact to mite eggs, all nymphal stages, and
adult females (adult males are not effected).  Spirodiclofen is
currently registered for application to citrus fruit, grape, pome fruit,
stone fruit, tree nuts, bushberry subgroup 13-07B, avocado, black
sapote, canistel, mamey sapote, mango, papaya, sapodilla, star apple,
and hops with tolerances for residues of spirodiclofen per se of 0.10-30
ppm; milk, milk fat, and ruminant meat, meat byproduct, and fat
tolerance for the combined residues of spirodiclofen and BAJ 2510 are
also established (0.02-0.1 ppm).   

Proposed Application Scenarios:  The petitioner proposed use directions
for application of Envidor® 2 SC Miticide (suspension-concentrate; 2
lbs ai/gallon; EPA Reg. No. 264-831) to sugar apple, cherimoya, custard
apple, ilama, soursop, biriba, lychee, longan, Spanish lime, rambutan,
pulasan, guava, feijoa, jaboticaba, wax jambu, starfruit, passionfruit,
persimmon, atemoya, and acerola.  Application through irrigation
equipment and in enclosed structures is prohibited.  See Table 4 for a
summary of the proposed application scenario.  HED requests a revised
Section B which prohibits the addition of an adjuvant to the spray
solution for the proposed crops.  

Nature/Magnitude of the Residue - Livestock:  Based on the revised Table
1 feedstuffs (OPPTS 860.1000), none of the proposed crops have feed
commodities; therefore a discussion concerning the nature/magnitude of
the residue in livestock is unnecessary.  

Nature/Magnitude of the Residue - Rotational Crops:  Since all of the
requested crops are perennials, a discussion concerning the
nature/magnitude of the residue in rotational crops is unnecessary.   

Nature of the Residue - Primary Crops:  Based on the results of the
citrus, grape, and apple metabolism studies (Risk Assessment Document: 
D285047, M Clock-Rust et al., 22-Jun-2005); the apple, grape, and orange
processing studies (D341847, T. Bloem, 22-Jun-2005; D359773, T. Bloem,
24-Jun-2009; D390192, T. Bloem, 20-Jun-2011); and previous conclusions
relating to the residues of concern in hops (D346710, M. Sahafeyan,
3-Jan-2008); HED concludes that the residues of concern in the
currently-registered/proposed crops are as follows (see Table 5 for a
summary):  pome fruit, tree nut, and hops - the residue of concern for
risk assessment and tolerance enforcement is spirodiclofen per se and
grape, citrus fruit, stone fruit, berry (crop group (CG) 13), and
tropical fruit - the residue of concern for tolerance enforcement is
spirodiclofen per se and residues of concern for risk assessment are
spirodiclofen and BAJ 2510.  HED notes that following:  (1) BAJ 2510 is
included as a residue of concern in grape, citrus fruit, stone fruit,
berry (CG 13), and tropical fruit due to the demonstrated (grape and
citrus fruit) degradation of parent to BAJ 2510 during processing or due
to the lack of data eliminating this possibility (stone fruit, berry CG
13, and tropical fruit); (2) BAJ 2510 is only a residue of concern in
the processed commodities of grape, citrus fruit, stone fruit, berry (CG
13), and tropical fruit; and (3) if processing data for the combined
residues of spirodiclofen and BAJ 2510 are not available, then the
dietary analysis should incorporate default processing factors.  Based
on the results of the grape and orange processing studies, HED requests
that all future processing studies monitor for residues of
spirodiclofen, BAJ 2510, 3-OH-enol, and 4-OH-enol.  

Magnitude of the Residue - Primary Crops:  In support of the proposed
registration, the petitioner submitted field trial studies conducted
with lychee (n=3; North American Free Trade Agreement (NAFTA) Growing
Zone 13), sugar apple (n=3; NAFTA Growing Zone 13), and guava (n=3;
NAFTA Growing Zone 13).  Provided the label is revised to prohibit the
addition of adjuvants to the spray solution, the application scenario
employed in the field trials supports the proposed application scenario.
 Residues of spirodiclofen per se were as follows (method and storage
intervals are validated):  lychee - 0.579-1.54 ppm; sugar apple -
0.051-0.194 ppm; and guava - 0.033-0.247 ppm.  The number and locations
of the lychee, sugar apple, and guava field trials are adequate to
support registration for these crops.  Based on Table 1 of OPPTS
860.1000, processing studies are not required for the proposed crops.  

HED has previously approved the following data translations (Reviewer(s
Guide and Summary of HED ChemSAC Approvals for Amending Commodity
Definitions [40 CFR (180.1(h)] and Crop Group/Subgroups [40 CFR
(180.41], B. Schneider, 14-June-2002; see Chemistry Science Advisory
Committee (ChemSAC) Database):  lychee to longan, Spanish lime,
rambutan, and pulasan; sugar apple to atemoya, custard apple, cherimoya,
ilama, soursop, and birida; and guava to feijoa, jaboticaba, wax jambu,
starfruit, passionfruit, and acerola.  In addition, the ChemSAC
previously approved the translation of spirodiclofen guava residue data
to persimmon provided the application scenario for each was identical
(ChemSAC minutes of the 17-Nov-2010 meeting).  Therefore, based on the
available residue data and the Organization for Economic Cooperation and
Development (OECD) tolerance calculator, HED concludes that the
following tolerances for residues of spirodiclofen per se are
appropriate (a revised Section F is requested):  lychee - 4.0 ppm;
longan - 4.0 ppm; Spanish lime - 4.0 ppm; rambutan - 4.0 ppm; pulasan -
4.0 ppm; sugar apple - 0.40 ppm; atemoya - 0.40 ppm; custard apple -
0.40 ppm; cherimoya - 0.40 ppm; ilama - 0.40 ppm; soursop - 0.40 ppm;
birida - 0.40 ppm; guava - 0.50 ppm; feijoa - 0.50 ppm; jaboticaba -
0.50 ppm; wax jambu - 0.50 ppm; starfruit - 0.50 ppm; passionfruit -
0.50 ppm; acerola - 0.50 ppm; and persimmon - 0.50 ppm.  

Analytical Enforcement Method:  HED determined that the Bayer analytical
method 109351 was appropriate for enforcement of the hop, citrus, grape,
pome fruit, stone fruit, and tree nut tolerances and forwarded this
method to Food and Drug Administration (FDA) for inclusion in the
Pesticide Analytical Manual (PAM; D368434, T. Bloem, 23-Sep-2009). 
Based on the similarities of the tolerance enforcement and the
adequately validated data collection methods, HED concludes that the
current enforcement method is appropriate for enforcement of the
tolerances recommended as part of the current petition.  

FDA Multiresidue Methods:  Spirodiclofen and BAJ 2510 were screened
through the FDA MRM protocols.  Since both spirodiclofen and BAJ 2510
are not N-methylcarbamates, naturally fluorescent, acids, phenols, or
substituted ureas, testing through protocols A, B, and G is unnecessary.
 Protocol C modules DG1 and DG10 gave acceptable results for BAJ 2510
and spirodiclofen, respectively (both are gas
chromatography/electron-capture detector (GC/ECD) systems).  Using
fortified orange samples, acceptable recoveries of spirodiclofen were
attained through Protocols D (80-103%) and E (54-77%).  Using fortified
ground beef samples, unacceptable recoveries of spirodiclofen were
attained through protocol F (16-30%).  BAJ 2510 was not recovered
through the florisil clean-up column, and therefore, gave unacceptable
recoveries for Protocol D (fortified orange samples) and F (fortified
ground beef samples).  Since BAJ 2510 was not recovered through Protocol
D, Protocol E was not tested.  These data have been forwarded to FDA
(D308565, T. Bloem, 29-Sep-2004).

Recommendations:  Provided revised Sections B and F are submitted, HED
concludes that the residue chemistry database supports an unconditional
registration for application of spirodiclofen to the proposed crops and
establishment of the following permanent tolerance for residues of only
spirodiclofen (180.608(a)(1)):  lychee - 4.0 ppm; longan - 4.0 ppm;
Spanish lime - 4.0 ppm; rambutan - 4.0 ppm; pulasan - 4.0 ppm; sugar
apple - 0.40 ppm; atemoya - 0.40 ppm; custard apple - 0.40 ppm;
cherimoya - 0.40 ppm; ilama - 0.40 ppm; soursop - 0.40 ppm; birida -
0.40 ppm; guava - 0.50 ppm; feijoa - 0.50 ppm; jaboticaba - 0.50 ppm;
wax jambu - 0.50 ppm; starfruit - 0.50 ppm; passionfruit - 0.50 ppm;
acerola - 0.50 ppm; and persimmon - 0.50 ppm.

In accordance with the most recent guidance concerning tolerance
expressions, HED recommends that the tolerance expression for
180.608(a)(1) and 180.6(a)(2) be changed as indicated below.  HED notes
that this alteration in the tolerance expression does not necessitate a
change in the currently established or recommended tolerance levels.  A
revised Section F specifying the new tolerance expression, the currently
established commodity/tolerance levels, and the HED-recommended
tolerances should be submitted.  

180.608(a)(1):  Tolerances are established for residues of
spirodiclofen, including its metabolites and degradates, in or on the
commodities listed below.  Compliance with the following tolerance
levels is to be determined by measuring only spirodiclofen
(3-(2,4-dichlorophenyl)-2-oxo-1-oxaspiro[4.5]dec-3-en-4-yl
2,2-dimethylbutanoate).

180.608(a)(2):  Tolerances are established for residues of
spirodiclofen, including its metabolites and degradates, in or on the
commodities listed below.  Compliance with the following tolerance
levels is to be determined by measuring only spirodiclofen
(3-(2,4-dichlorophenyl)-2-oxo-1-oxaspiro[4.5]dec-3-en-4-yl
2,2-dimethylbutanoate) and its metabolite
3-(2,4-dichlorophenyl)-4-hydroxy-1-oxaspiro[4,5] dec-3-en-2-one.

Summary of Residue Chemistry Deficiencies:

(Revised Section B which prohibits the addition of an adjuvant to the
spray solution for the proposed crops.  

(Revised Section F.

Detailed Considerations

Background

Spirodiclofen is a tetronic acid with acaricidal action (group 23).  It
acts by interfering with mite development, and controls such pests as
Panonychus spp., Phyllocoptruta spp., Brevipalpus spp., and Aculus and
Tetranychus species.  The petitioner stated that spirodiclofen is active
by contact to mite eggs, all nymphal stages, and adult females (adult
males are not effected).  Tables 1 and 2 are summaries of spirodiclofen
nomenclature and physical chemical properties, respectively.



Common name	Spirodiclofen

Company experimental name	BAJ2740

IUPAC name	3-(2,4-dichlorophenyl)-2-oxo-1-oxaspiro[4,5]dec-3-en-4-yl
2,2-dimethylbutyrate

CAS name	3-(2,4-dichlorophenyl)-2-oxo-1-oxaspiro[4,5]dec-3-en-4-yl
2,2-dimethylbutanoate

CAS registry number	148477-71-8

End-use product (EP)	2 lb/gal FlC (ENVIDOR® 2 SC Miticide; EPA Reg. No.
264-831)



Table 2:  Physicochemical Properties of Spirodiclofen.

Melting point	94.8ºC	D315459, S. Mathur, 

50μg/L

	Solvent solubility (g/L at 20°C)	n-heptane  

xylene  

dichloromethane 

2-propanol

1-octanol

polyethylene glycol

acetone

ethyl acetate

acetonitrile

dimethylsulfoxide	20

>250

>250

47

44

24

>250

>250

>250

75

	Vapor pressure (20ºC)	3 x 10-7 Pa

	Dissociation constant, pKa	Not determinable due to the instability in
aqueous solutions at >pH 4

	Log(KOW) at pH 4 and 20ºC	5.83

	UV/visible absorption spectrum	λmax = 201 nm:  Not expected to absorb
UV at λ >350 nm

	

860.1200  Directions for Use

The petitioner proposed use directions for application of Envidor® 2 SC
Miticide (suspension-concentrate; 2 lbs ai/gallon; EPA Reg. No. 264-831)
to sugar apple, cherimoya, atemoya, custard apple, ilama, soursop,
biriba, lychee, longan, Spanish lime, rambutan, pulasan, guava, feijoa,
jaboticaba, wax jambu, starfruit, passionfruit, persimmon, and acerola. 
Table 3 is a summary of the proposed formulation and target pests and
Table 4 is a summary of the proposed application scenario.  HED requests
a revised Section B which prohibits the addition of an adjuvant to the
spray solution for the proposed crops.  

Table 3:  Summary of Proposed End-Use Product and Target Pests.

Trade Name	EPA Reg. No.	concentration	Formulation Type	Label Date	Target
Pests

Sugar Apple, Cherimoya, Atemoya, Custard Apple, Ilama, Soursop, Biriba,
Lychee, Longan, Spanish Lime, Rambutan, Pulasan, Guava, Feijoa,
Jaboticaba, Wax Jambu, Starfruit, Passionfruit, Persimmon, and Acerola

Envidor® 2 SC Mticide	264-831	2 lb ai/gal	SC	not indicated	broad mite,
Carmine spider mite, citrus red mite, flat mite (black and red), persea
mite, sixspotted mite, Texas citrus mite, twospotted spider mite



Table 4:  Summary of Proposed Application Scenarios.

App. Timing; Type; and Equip.	Formulation (EPA Reg. No.)	App. Rate

(lb ai/acre)	Max. #. App. per Season	Max. Seasonal App. Rate (lb
ai/acre)	PHI

(days)	Use Directions and Limitations

Sugar Apple, Cherimoya, Atemoya, Custard Apple, Ilama, Soursop, Biriba,
Lychee, Longan, Spanish Lime, Rambutan, Pulasan, Guava, Feijoa,
Jaboticaba, Wax Jambu, Starfruit, Passionfruit, Persimmon, and Acerola

postemergence; foliar broadcast	2 lb ai/gal  SC

(264-831)	0.28-0.31	1	0.31	1	-Apply in a minimum of 50 GPA with ground
equipment.

-Application through irrigation equipment and in enclosed structures is
prohibited.



860.1300 Nature of the Residue - Plants

Table 5 below is a summary of the HED decisions concerning the residues
of concern in primary crops, livestock, and rotational crops.  For
additional information, see the Executive Summary.  

Table 5:  Residues of Concern for Tolerance Expression and Risk
Assessment.

Matrix	Residues included in

Risk Assessment	Residues included in

Tolerance Expression

Pome Fruit, Tree Nut, and Hops	spirodiclofen	spirodiclofen

Grape, Citrus Fruit, Stone Fruit, Berry (CG 13), and Tropical Fruit1
spirodiclofen, BAJ 2510	spirodiclofen

Livestock - Ruminants	spirodiclofen, BAJ 2510	spirodiclofen, BAJ 2510

Livestock - Poultry	no data submitted

Rotational Crops	no data submitted

1  BAJ 2510 is included as a residue of concern in grape, citrus fruit,
stone fruit, berry (CG 13), and tropical fruit due to the demonstrated
(grape and citrus fruit) degradation of parent to BAJ 2510 during
processing or due to the lack of data eliminating this possibility
(stone fruit, berry (CG 13), and tropical fruit).  BAJ 2510 is only a
residue of concern in the processed commodities of grape, citrus fruit,
stone fruit, berry (CG 13), and tropical fruit.  If processing data for
the combined residues of spirodiclofen and BAJ 2510 are not available,
then the dietary analysis should incorporate default processing factors.

860.1300 Nature of the Residue - Livestock

Based on the revised Table 1 feedstuffs (OPPTS 860.1000), none of the
proposed crops have feed commodities; therefore a discussion concerning
the nature of the residue in livestock is unnecessary.  

860.1340 Residue Analytical Methods

Tolerance Enforcement:  HED forwarded Bayer analytical method 109351 to
FDA for inclusion in the PAM (D368434, T. Bloem, 23-Sep-2009).  Briefly,
fruit samples are extracted with acetonitrile(ACN):water (2:1; v:v)
containing a small amount of aqueous 20% cysteine hydrochloride,
filtered, and acidified with HCl.  The extract is subjected to clean up
on an ENVI-carb cartridge preconditioned with dichloromethane (DCM),
methanol, and water with residues eluted with DCM under vacuum.  The
resulting eluent is concentrated to dryness and reconstituted in ACN and
water for analysis by high-performance liquid chromatography/mass
spectrometry/mass spectrometry (HPLC/MS/MS).  The limit of quantitation
(LOQ) was reported to be 0.01 ppm (limits of detection (LODs) ranged
from 0.001-0.006 ppm).  Based on the similarities of the tolerance
enforcement and the adequately validated data collection method (see
below), HED concludes that the current enforcement method is appropriate
for enforcement of the tolerances recommended as part of the current
petition.  

Data Collection:  A summary of the lychee, sugar apple, and guava data
collection methods are provided below.  The studies indicated that the
DCM partition provided sufficient cleanup to make the ENVI-carb
cartridge cleanup step in the enforcement method unnecessary. 

Sugar Apple and Guava:  The sample homogenates were extracted with
ACN/water (2:1, v/v) mixed with a 20% aqueous cysteine hydrochloride
solution.  Following the addition of Celite, the extract was vacuum
filtered, blended with an acetone/DCM solution (1:2, v/v), and vacuum
filtered again.  The filtrate was allowed to separate and the organic
bottom layer was collected and diluted with acetone.  The sample was
then concentrated to dryness and partitioned with hexane and two
portions of ACN pre-saturated with hexane.  All of the transfer solvents
were collected, separated twice to collect the bottom ACN layers, and
then concentrated to dryness.  The samples were partitioned with DCM and
analyzed for residues of spirodiclofen per se using HPLC/MS/MS.  

Lychee:  The samples homogenates were extracted with ACN/water (2:1,
v/v) mixed with a 20% aqueous cysteine hydrochloride solution. 
Following the addition of Celite, the extract was vacuum filtered,
rinsed, and brought to volume with the extraction solution.  An aliquot
of the sample was mixed with 1.2N HCl, diluted with water, and shaken. 
The diluted sample was partitioned with DCM and the lower organic phase
was passed through sodium sulfate.  The sodium sulfate was rinsed with
DCM and evaporated to dryness.  The samples were partitioned with DCM
and analyzed for residues of spirodiclofen per se using HPLC/MS/MS.  

860.1360 Multiresidue Methods

Spirodiclofen and BAJ 2510 were screened through the FDA MRM protocols. 
Since both spirodiclofen and BAJ 2510 are not N-methylcarbamates,
naturally fluorescent, acids, phenols, or substituted ureas, testing
through protocols A, B, and G is unnecessary.  Protocol C modules DG1
and DG10 gave acceptable results for BAJ 2510 and spirodiclofen,
respectively (both are GC/ECD systems).  Using fortified orange samples,
acceptable recoveries of spirodiclofen were attained through Protocols D
(80-103%) and E (54-77%).  Using fortified ground beef samples,
unacceptable recoveries of spirodiclofen were attained through protocol
F (16-30%).  BAJ 2510 was not recovered through the florisil clean-up
column, and therefore, gave unacceptable recoveries for Protocol D
(fortified orange samples) and F (fortified ground beef samples).  Since
BAJ 2510 was not recovered through Protocol D, Protocol E was not
tested.  These data have been forwarded to FDA (D308565, T. Bloem,
29-Sep-2004).

860.1380 Storage Stability

The lychee, guava, and sugar apple samples from the field trials were
stored frozen for up to 350 days prior to analysis.  As part of the
lychee field trial study, the petitioner submitted storage stability
which indicate that residues of spirodiclofen per se are stable in/on
lychee when stored frozen for 354 days.  HED notes that these data did
not include a zero day analysis as requested in the OPPTS 860.1380
guidelines.  The petitioner previously submitted storage stability data
which indicated that residues of spirodiclofen per se are stable when
stored frozen for the following crop/intervals (D285249, T. Bloem,
18-Apr-2005):  391 days (grape), 231 days (raisin), 226 days (grape
juice concentrate), 231 days (apple juice concentrate), 231 days (dried
apple), 391 days (peaches), 306 days (prunes), 410 days (almond
nutmeat), and 305 days (almond hulls).  The almond hull data indicated a
26% reduction in residues for samples stored 410 days.  These data
support the storage intervals and conditions for the lychee, guava, and
sugar apple samples collected as part of the current study.

860.1480 Meat, Milk, Poultry, and Eggs

Based on the revised Table 1 feedstuffs (OPPTS 860.1000), none of the
proposed crops have feed commodities; therefore a discussion concerning
the magnitude of the residue in livestock is unnecessary.  

860.1500 Crop Field Trials

48332901.der, 48332902.der, and 48332903.der

In support of the proposed registration, the petitioner submitted field
trial studies conducted with lychee (n=3; NAFTA Growing Zone 13), sugar
apple (n=3; NAFTA Growing Zone 13), and guava (n=3; NAFTA Growing Zone
13).  Provided the label is revised to prohibit the addition of
adjuvants to the spray solution, the application scenario employed in
the field trials supports the proposed application scenario.  Residues
of spirodiclofen per se were as follows (method and storage intervals
are validated; see Table 6 for a summary):  lychee - 0.579-1.54 ppm;
sugar apple - 0.051-0.194 ppm; and guava - 0.033-0.247 ppm.  The number
and locations of the lychee, sugar apple, and guava field trials are
adequate to support registration for these crops; HED notes that some of
the trials were conducted at the same location but were considered
separate trials due to different application days and due to the
recognized difficulty in finding adequate field trial locations for
these low-acreage crops.  Residue-decline data were included as part of
the lychee field trial study and indicated that per-trial average
spirodiclofen residues increased slightly as the preharvest interval
(PHI) increased from 1 day (1.54 ppm) to 3 days (1.73 ppm) and then
declined as the PHI increased to 14 days (0.62 ppm).

HED has previously approved the following data translations (Reviewer(s
Guide and Summary of HED ChemSAC Approvals for Amending Commodity
Definitions [40 CFR (180.1(h)] and Crop Group/Subgroups [40 CFR
(180.41], B. Schneider, 14-June-2002; see ChemSAC Database):  lychee to
longan, Spanish lime, rambutan, and pulasan; sugar apple to atemoya,
custard apple, cherimoya, ilama, soursop, and birida; and guava to
feijoa, jaboticaba, wax jambu, starfruit, passionfruit, and acerola.  In
addition, the ChemSAC previously approved the translation of
spirodiclofen guava residue data to persimmon provided the application
scenario for each was identical (ChemSAC minutes of the 17-Nov-2010
meeting).  Therefore, based on the available residue data and the OECD
tolerance calculator, HED concludes that the following tolerances for
residues of spirodiclofen per se are appropriate (see attachment 3; a
revised Section F is requested):  lychee - 4.0 ppm; longan - 4.0 ppm;
Spanish lime - 4.0 ppm; rambutan - 4.0 ppm; pulasan - 4.0 ppm; sugar
apple - 0.40 ppm; atemoya - 0.40 ppm; custard apple - 0.40 ppm;
cherimoya - 0.40 ppm; ilama - 0.40 ppm; soursop - 0.40 ppm; birida -
0.40 ppm; guava - 0.50 ppm; feijoa - 0.50 ppm; jaboticaba - 0.50 ppm;
wax jambu - 0.50 ppm; starfruit - 0.50 ppm; passionfruit - 0.50 ppm;
acerola - 0.50 ppm; and persimmon - 0.50 ppm.  

Table 6:  Summary of Spirodiclofen per se residue Data from the Lychee,
Sugar Apple, and Guava Field Trials.

Commodity	Analyte	Total App. 

Rate 

 (lb ai/A)	PHI

(days)	Residue Levels (spirodiclofen per se; ppm)1





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

Lychee fruit	Spirodiclofen	0.3164-0.3212	1	3	0.579	1.54	0.657	1.54	0.955
1.05	0.449

Sugar apple fruit	Spirodiclofen	0.3181-0.3196	1	3	0.051	0.194	0.095
0.138	0.122	0.118	0.022

Guava fruit	Spirodiclofen	0.3161-0.3243	1	3	0.033	0.247	0.085	0.230
0.192	0.169	0.075

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.

860.1520 Processed Food and Feed

Based on Table 1 of OPPTS 860.1000, processing studies are not required
for the proposed crops.  

860.1850/860.1900 Confined and Field Accumulation in Rotational Crops

Since all of the requested crops are perennials, a discussion concerning
the nature/magnitude of the residue in rotational crops is unnecessary. 
 

860.1550 Proposed/Recommended Tolerances

Table 5 is a summary of the proposed and recommended tolerance for
residues of spirodiclofen per se.  There are no Codex, Canadian, or
Mexican maximum residue limits (MRLs) in/on the requested crops. 
Therefore, harmonization is not an issue for this petition.  

In accordance with the most recent guidance concerning tolerance
expressions, HED recommends that the tolerance expression for
180.608(a)(1) and 180.6(a)(2) be changed as indicated below.  HED notes
that this alteration in the tolerance expression does not necessitate a
change in the currently established or recommended tolerance levels.  A
revised Section F specifying the new tolerance expression, the currently
established commodity/tolerance levels, and the HED-recommended
tolerance should be submitted.  

180.608(a)(1):  Tolerances are established for residues of
spirodiclofen, including its metabolites and degradates, in or on the
commodities listed below.  Compliance with the following tolerance
levels is to be determined by measuring only spirodiclofen
(3-(2,4-dichlorophenyl)-2-oxo-1-oxaspiro[4.5]dec-3-en-4-yl
2,2-dimethylbutanoate.

180.608(a)(2):  Tolerances are established for residues of
spirodiclofen, including its metabolites and degradates, in or on the
commodities listed below.  Compliance with the following tolerance
levels is to be determined by measuring only spirodiclofen
(3-(2,4-dichlorophenyl)-2-oxo-1-oxaspiro[4.5]dec-3-en-4-yl
2,2-dimethylbutanoate) and its metabolite
3-(2,4-dichlorophenyl)-4-hydroxy-1-oxaspiro[4,5] dec-3-en-2-one.

Table 5:  Tolerance Summary.

Commodity	Proposed Tolerance (ppm)	HED-Recommended Tolerance (ppm)
Comments

Lychee	3.5	4.0	Based on the field trial data and the OECD tolerance
calculator, the appropriate tolerance for residues of spirodiclofen per
se in/on these crops is 4.0 ppm.

Longan	3.5	4.0

	Spanish lime	3.5	4.0

	Rambutan	3.5	4.0

	Pulasan	3.5	4.0

	Sugar apple	0.45	0.40	Based on the field trial data and the OECD
tolerance calculator, the appropriate tolerance for residues of
spirodiclofen per se in/on these crops is 0.40 ppm.

Atemoya	0.45	0.40

	Custard apple	0.45	0.40

	Cherimoya	0.45	0.40

	Ilama	0.45	0.40

	Soursop	0.45	0.40

	Biriba	0.45	0.40

	Guava	0.45	0.50	Based on the field trial data and the OECD tolerance
calculator, the appropriate tolerance for residues of spirodiclofen per
se in/on these crops is 0.50 ppm.

Feijoa	0.45	0.50

	Jaboticaba	0.45	0.50

	Wax jambu	0.45	0.50

	Starfruit	0.45	0.50

	Passionfruit	0.45	0.50

	Acerola	0.45	0.50

	Persimmon	0.45	0.50

	

Attachment 1:  Chemical Structures

Attachment 2:  Codex

Attachment 3:  Tolerance Calculation

  SEQ CHAPTER \h \r 1 RDI: RAB1 Chemists (28-Sep-2011)

T. Bloem:S10945:Potomac Yard 1:703-605-0217:7509P:RABI

Attachment 1:  Chemical Structures

Chemical Name	Structure

Spirodiclofen; BAJ2740

3-(2,4-dichlorophenyl)-2-oxo-1-oxaspiro[4,5]dec-3-en-4-yl
2,2-dimethylbutanoate	

BAJ 2510

 

3-OH-enol

 

4-OH-enol

 



Attachment 2:  International residue Limit Status

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ommodities 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.

Attachment 3:  Tolerance Calculation

Spirodiclofen	Summary of Analytical Chemistry and Residue Data	D387339

Page   PAGE  10  of   NUMPAGES  13 

