860. 18590

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

	OFFICE OF CHEMICAL SAFETY

	AND POLLUTION PREVENTION

MEMORANDUM

Date:  		04/14/14

SUBJECT:	Trifloxystrobin.  Application for Section 3 Registration for
Uses on Dry Peas, Chickpeas, and Lentils.  Summary of Analytical
Chemistry and Residue Data.

PC Code:  129112	DP Barcode:  D413711

Decision No.:  478982	Registration No.:  264-1055

Petition No.:  3F8180	Regulatory Action:  Section 3 Registration

Risk Assessment Type:  NA	Case No.:  NA

TXR No.:  NA	CAS No.:  141517-21-7

MRID No.:  See MRID Summary Table	40 CFR:  180.555



FROM:	Meheret Negussie, Chemist  SEQ CHAPTER \h \r 1 

		Risk Assessment Branch III (RAB3)

		Health Effects Division (HED), 7509P

THRU:	Steve Funk, Senior Chemist

Christine Olinger, Branch Chief

		RAB3/HED (7509P)

TO:		Nancy Tsaur, Chemist/Risk Assessor

		RAB3/HED (7509P)

			and

Tony Kish, RM 22

				Fungicide Branch/RD (7505P)

Summary of Submitted Residue Chemistry Studies

OCSPP 860 Series Guideline	MRID Number	Title

860.1500	49072801	49072801/PMRA# 2306694 Milo, J. and A. Harbin (2013)
Study title: FOX 325 SC Foliar Fungicide: Magnitude of Trifloxystrobin
Residue In/On Dry Bean (Phaseolus spp) Following Treatment with
SP102000010777 (Prothioconazole/Trifloxystrobin) Study No.: RAJAN003
Unpublished study prepared by Bayer CropScience. 456 pages.  

860.1500	49072802	49072802/PMRA# 2306696 Milo, J. and A. Harbin (2013)
Study title: FOX 325 SC Foliar Fungicide: Magnitude of Trifloxystrobin
Residue In/On Dry Pea (Pisum spp) Following Treatment with
SP102000010777 (Prothioconazole/Trifloxystrobin). Study No.: RAJAN004
Unpublished study prepared by Bayer CropScience. 555 pages. 





Executive Summary

ngs to the MAEs (β-methoxyacryl esters) class of fungicides, which are
synthetic analogs of strobilurin A (Fungicide Resistance Action
Committee Group 11).  It is a broad-spectrum preventative fungicide used
for control of many plant diseases in various fruit, nut, vegetable, and
field crops.

Under PP# 3F8180, Bayer CropScience (Bayer) is proposing the
establishment of permanent tolerances for residues of the fungicide
trifloxystrobin [benzeneacetic acid,
(E,E)-α-(methoxyimino)-2-[[[[1-[3-(trifluoromethyl)phenyl]ethylidene]am
ino]oxy]methyl]-, methyl ester] and the free form of its acid metabolite
CGA-321113
[(E,E)-(methoxyimino)-[2-[1-(3-(trifluoromethylphenyl)-ethylideneaminoox
ymethyl]-phenyl]acetic acid] in/on the following raw agricultural
commodities:

Pea, dry, seed	0.06 ppm

Pea, dry, hay	15 ppm

Pea, dry, vines 	4 ppm

Chickpea, seed	0.06 ppm

Chickpea, hay	15 ppm

Chickpea, vines 	4 ppm

Lentils 	0.06 ppm

In conjunction with this petition, Bayer is requesting registration of
USF 0728 325 SC, a 1.27 lb ai/gal suspension concentrate (SC)
formulation [EPA File Symbol No. 264-1055].  The product is a multiple
active ingredient (MAI) product that also contains prothioconazole at
1.49 lb ai/gal. 

The subject review only addresses the adequacy of the available data to
support the proposed uses of trifloxystrobin only. 

The proposed uses are dry peas, chickpeas, and lentils.  The product is
proposed for multiple foliar applications at single application rates of
0.12 lb ai/A/application of trifloxystrobin and maximum seasonal rates
of 0.24 lb ai/A.  Retreatment intervals (RTIs) of 10- 14 days, and
preharvest intervals (PHIs) of 0-days for forage/vines and hay and
30-days for seed are proposed. 

Tolerances are currently established for the combined residues of
trifloxystrobin and the free form of its acid metabolite CGA–321113
in/on various crop and livestock commodities ranging from 0.01 ppm to 38
ppm [40 CFR §180.555(a)].  

The qualitative nature of the residue in plants and livestock
commodities is adequately understood based on acceptable metabolism
studies reflecting direct application of trifloxystrobin to apples,
cucumbers, peanuts, sugar beets, and wheat, and metabolism studies on
goats and laying hens.  HED has concluded that both trifloxystrobin and
CGA-321113 are of concern for both regulatory and risk assessment
purposes for both plant and livestock commodities.  HED also determined
that for livestock commodities, the metabolite L7a (taurine conjugate of
trifloxystrobin) in liver should be included in the risk assessment.

An adequate gas chromatography method with nitrogen phosphorus detection
(GC/NPD), Method AG-659A, is available for enforcing tolerances for the
combined residues of trifloxystrobin and CGA-321113 in plant and
livestock commodities.  Samples from the submitted crop field trials on
dry peas (seed, forage, and hay) and chickpeas were analyzed for
residues of trifloxystrobin and CGA-321113 using a high performance
liquid chromatography method with tandem mass spectrometry detection
(LC/MS/MS).  Residues of CGA-321113 were converted to parent equivalents
using a molecular weight conversion factor.  The method was adequately
validated in conjunction with the analysis of crop field trial samples. 
The lowest level of method validation (LLMV) is equivalent to the limit
of quantitation (LOQ) which was 0.010 ppm for each analyte in/on all
matrices.

Adequate storage stability data are available to support the storage
durations and conditions of samples of dry pea commodities, chickpeas,
and lentils from the submitted crop field trial studies.  

The proposed use on dry peas does not result in an increased dietary
burden for livestock.  The existing tolerances on livestock commodities
are adequate. 

Adequate crop field trial data have been submitted to support the
requested uses on dry peas, chickpeas, and lentils.  The trials reflect
the proposed use pattern and the number and locations of the trials are
acceptable based on the ChemSAC minutes of 20 March, 2013.  Tolerances
for chickpea hay and vines are not needed since both commodities are not
significant livestock feed items.  Based on the Organization for
Economic Cooperation and Development (OECD) tolerance calculation
spreadsheet, the recommended tolerances are 0.06 ppm for pea, dry, seed;
15 ppm for pea, field, hay; 4 ppm for pea, field, vines; and 0.04 ppm
for chickpea, seed.  The recommended tolerance for chickpea seed at 0.04
ppm is increased to 0.06 ppm for harmonization purposes. The pea results
are translated to cover lentils. The proposed tolerances on chickpea
seed and lentil seed are not needed since pea dry seed includes these
commodities (40 CFR 180.1 (g)).  HED is recommending to establish a
tolerance on pea, dry, seed at 0.06 ppm in order to harmonize with the
Canadian recommended MRLs.  A revised Section F needs to be submitted to
reflect the correct commodity definitions.

There are no processed commodities associated with the proposed new
uses; therefore, no new processing studies were submitted or reviewed
for this petition. 

Adequate confined and field rotational crop data are available.  HED
previously concluded that the residues of concern in rotated crops are
trifloxystrobin and CGA-321113.  The available data support a 30-day
plant-back interval (PBI) for all crops not listed on the label for
direct use.  

Codex MRLs are expressed in terms of trifloxystrobin for plants; thus,
harmonization of MRLs is not possible.  The Codex residue definition for
livestock is the same as the US.  The Canadian residue definitions for
plants and livestock are the same as the US.  There are no Codex MRLs
established on the proposed crops.  Canadian MRLs exist for dry
chickpeas, dry lentils, and dry field peas at 0.02 ppm. This petition is
reviewed as a workshare with Canada; tolerances for the proposed crops
are harmonized. 

Regulatory Recommendations and Residue Chemistry Deficiencies

HED has examined the residue chemistry database for trifloxystrobin. 
Pending submission of a  revised Section F (see requirements under
Proposed Tolerances; Table 7), there are no residue chemistry issues
that would preclude granting a Section 3 registration and establishment
of tolerances for combined residues of trifloxystrobin and its acid
metabolite CGA-321113, as follows:

Pea, dry, seed	0.06 ppm

Pea, field, hay	15 ppm

Pea, field, vines 	4 ppm

A human health risk assessment is forthcoming.

860.1550 Proposed Tolerances

The petitioner needs to submit a revised Section F to reflect the
correct commodity definitions as presented in Table 7.

Background

The chemical structure and nomenclature of trifloxystrobin and its
regulated metabolite are presented in Table 1, and the physicochemical
properties of the technical grade of trifloxystrobin are presented in
Table 2. 

α E)- α
–(methoxyimino-[2-[[[(E)-1-[3-(trifluoromethyl)phenyl]-ethylidene]amin
o]oxy]methyl]benzeneacetic acid

CAS #	252913-85-2



Table 2.	Physicochemical Properties of Trifloxystrobin.

Parameter	Value	Reference1

Melting point	72.9ºC	MRID 44502801

pH	7.7 in 1% w/w aqueous dispersion at 25ºC

	Density	1.36 g/cm2 at 21ºC

	Water solubility	0.00061 g/L at 20ºC

	Solvent solubility (g/L at 25ºC)	methanol           76

acetone          >500

ethyl acetate  >500

n-hexane            11	dichloromethane >500

toluene                  500

n-octanol                 18

	Vapor pressure 	3.4 x 10-6 Pa at 25ºC

	Dissociation constant, pKa	none at pH of 2-12

	Octanol/water partition coefficient Log(POW)	4.5 at 25ºC

	UV/visible absorption spectrum

(molecular absorption coefficients)	17,500 at 250.7 µm (neutral)

17,300 at 250.2 µm (acidic)

15,900 at 252.3 µm (basic)

	1 RD Memo, DP# 254920, 4/23/99, A. Smith.

860.1200 Directions for Use

The petitioner has submitted a Section B along with a draft specimen
label for the 1.27 lb ai/gal SC formulation of Trifloxystrobin USF 0728
325 SC; EPA File Symbol No. 264-1055. The product is a multiple active
ingredient (MAI) product that also contains prothioconazole at 1.49 lb
ai/gal.  The Section B is limited to the crops for which tolerances are
being proposed including dry peas, chickpeas, and lentils.

A summary of the proposed use patterns is presented in Table 3.  

Table 3.	Summary of Directions for Use of Trifloxystrobin.

Applic. Timing; Type; and Equipment	Formulation

[EPA File Symbol No.]	Applic. Rate 

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

(lb ai/A)	PHI

(days)	Use Directions and Limitations1

Chickpeas

Foliar spray;

Ground, aerial, or chemigation	1.27 lb ai/gal SC

[264-1055]	12 fl oz/A

(0.12)	2	24 fl oz/A

(0.24)	7-Forage

30-Seed	The proposed RTI is 10-14 days. 

Dry peas

Foliar spray;

Ground, aerial, or chemigation	1.27 lb ai/gal SC

[264-1055]	12 fl oz/A

(0.12)	2	24 fl oz/A

(0.24)	7-Forage

30-Seed	The proposed RTI is 10-14 days.

Lentils

Dry peas

Foliar spray;

Ground, aerial, or chemigation	1.27 lb ai/gal SC

[264-1055]	12 fl oz/A

(0.12)	2 	24 fl oz/A

(0.24)	7-Forage

30-Seed	The proposed RTI is 10-14 days.

1 RTI = Retreatment interval.  All applications are to begin
preventatively and continue as needed (when multiple applications are
permitted).

To limit the potential for development of disease resistance, no more
than two sequential applications of the product or any Group 11- or
Group 3-containing fungicide may be made before rotating with a
fungicide from a different group.

Conclusions.  The use directions are adequate to allow evaluation of the
residue data relative to the proposed uses.  The proposed maximum
seasonal rate, minimum PHIs, and minimum RTIs are supported by the
submitted field trial data.  

860.1300 Nature of the Residue - Plants

DP#287242, L. Cheng, 10/08/2003

DP#s 267787 and 272054, L. Cheng, 01/17/2002

DP#s 254208 and 257888, F. Ives, 07/22/1999

DP#257835, F. Ives and B. Greear, 07/13/1999

The qualitative nature of the residue in plants is adequately understood
based on acceptable metabolism studies reflecting direct application of
trifloxystrobin to apples, cucumbers, peanuts, sugar beets, and wheat. 
HED previously concluded that trifloxystrobin and the free form of its
acid metabolite, CGA-321113, are of concern for both regulatory and risk
assessment purposes for plant commodities.

860.1300 Nature of the Residue - Livestock

Residue Chemistry Memo DP#s 254208 and 257888, F. Ives, 7/22/99

Residue Chemistry Memo DP# 257835, F. Ives and B. Greear, 7/13/99

The qualitative nature of the residue in livestock is adequately
understood based on acceptable goat and poultry metabolism studies.  HED
previously determined that the residues of concern for livestock, both
for regulatory and risk assessment purposes, are trifloxystrobin and the
free form of its acid metabolite CGA-321113.  Additionally, metabolite
L7a (taurine conjugate of trifloxystrobin) in the liver is to be
included in risk assessment.

860.1340 Residue Analytical Methods

DP#265003, L. Cheng, 04/13/2000

Enforcement method:  An adequate GC/NPD method (Method AG-659A) is
available for enforcing tolerances for the combined residues of
trifloxystrobin and CGA-321113 in plant and livestock commodities.  This
method was validated by the Agency and forwarded to FDA for inclusion in
the Pesticide Analytical Manual (PAM), Vol. II.

 

Data collection method:  Samples from the submitted crop field trials on
dry peas and chickpeas were analyzed for residues of trifloxystrobin and
CGA-321113 using an LC/MS/MS method.  

Briefly, subsamples of the ground bean samples were extracted twice with
acetonitrile/water (4/1, v/v) using homogenization with a tissuemizer
and shaking, and brought to final volume. An aliquot of sample was
measured into a vial and further diluted.  Samples were analyzed using
high performance liquid chromatography with tandem mass spectrometry
(HPLC-MS/MS) in the positive ion mode under multiple reaction monitoring
(MRM) conditions, using ion transitions m/z 409 ( 186 for
trifloxystrobin and m/z 395 ( 186 for CGA 321113. Quantification with
internal standards was performed based on a linear regression curve of
trifloxystrobin and CGA 321113. The method LOQ was reported as 0.01 ppm
for each analyte.

The LC/MS/MS method was adequately validated in conjunction with the
analysis of field trial samples using control samples fortified
separately with trifloxystrobin and CGA-321113 at levels ranging from
0.01, 0.05, and 0.2 ppm.  Concurrent method recoveries were generally
within the acceptable range of 70-120% for all samples tested.  The
fortification levels used in concurrent method validation were adequate
to bracket residues found in treated samples of all commodities.

Conclusions.  The residue analytical methods data are adequate to
satisfy data requirements for the subject action.  Acceptable
enforcement methodology is available for tolerance enforcement purposes
for residues in/on crop commodities, and residues of trifloxystrobin and
CGA-321113 in/on dry peas and chickpeas were determined using an
acceptable data collection method.

860.1360 Multiresidue Methods

DP#s 254208 and 257888, F. Ives, 07/22/1999

The regulated residues were tested in accordance with the Pesticide
Analytical Method (PAM), Volume I, Appendix II.  Trifloxystrobin gave
adequate responses through protocol C, and was completely recovered from
fortified apple samples when analyzed through protocols D and E.  Acid
metabolite CGA-321113 was recoverable through protocol B and residues
from apples fortified with CGA-321113 were completely recovered through
Section 402 E2/C1 (extraction with methylene chloride).  These data were
forwarded to FDA.

860.1380 Storage Stability

DP# 286639, L. Cheng, 01/23/2003 (PP#3E06522)

DP#s 254213, 254217, 254218, and 254221, L. Cheng, 04/06/2000
(PP#9F5070)

Storage stability data are available indicating that residues of
trifloxystrobin and its metabolite CGA-321113 are stable during frozen
storage in a number of raw agricultural and processed commodities. 
Residues of both analytes were demonstrated to be stable in/on the
following RACs:  cucumbers, grapes, potato tubers, and wheat whole
plant, grain, and straw for up to 24 months; and apples, peanut
nutmeats, and peanut hay for up to 18.6 months.  In processed
commodities, residues of both analytes were demonstrated to be stable in
apple pomace, grape juice, peanut oil, and potato granules/flakes for up
to 18.6 months.  

HED previously concluded that the available data are adequate to support
storage stability requirements for fruit or fruiting vegetables,
non-oily grains, oily crops, and potatoes.  For processed commodities,
the available data are representative of oilseeds and fruits/fruiting
vegetables.  No storage stability data are available for high protein
content commodities, such as beans and peas.  However, the available
storage stability data on high water content commodities, high starch
content commodities, high acid content commodities, and high oil content
commodities indicate stability across a broad range of commodity types
and will be translated to beans and peas.

The storage durations and conditions of samples from the crop field
trials submitted to support this petition are presented in Table 4. 

Table 4.	Summary of Storage Conditions and Durations of Samples from
Crop Field Trial Studies.  

Matrix 	Storage Temperature

 (°C)	Actual Storage Duration

(days)	Interval of Demonstrated Storage Stability

Chickpea seed	-21 to -13	83-116	Residues of trifloxystrobin and
CGA-321113 are reasonably stable under frozen storage conditions in/on
cucumber, grape, potato, and wheat grain for up to ~2 years, and in/on
apple and peanut nutmeat for up to 18.6 months.

Dry Pea, Seed

108-131 

	Dry Pea, Vine 

184-202

	Dry Pea, Hay

185-203

	

Conclusions.  The available storage stability data are adequate to
support the storage durations and conditions of samples of dry pea and
chickpeas from the submitted crop field trial studies. 

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

Residue Chemistry Memo DP# 363108, W. Cutchin, 1/25/10

Residue Chemistry Memo DP# 338207, D. Rate, 4/10/07

Residue Chemistry Memo DP# 254208 and 257888, F. Ives, 7/22/99

Pea field seeds, hay, and vines are the livestock feedstuffs associated
with the proposed uses.  The dietary burden for beef cattle is not
affected since these commodities are not fed to beef cattle.  

Dietary burdens based on reasonably balanced diets (RBDs) for livestock
were most recently calculated (DP# 363108).  The calculated dietary
burdens for livestock were 3.40 ppm for beef cattle, 9.90 ppm for dairy
cattle, and 0.80 ppm for poultry and swine.

The livestock maximum reasonably balanced diets (MRBD) of
trifloxystrobin were recalculated  using the highest average field trial
(HAFT)/median residues for pea commodities and tolerance-level residues
for existing uses.  For cattle, corn forage contributes the entire
roughage component at a higher dietary contribution of trifloxystrobin
than pea hay.  A similar situation exists for the protein concentrate
fraction of the poultry and swine diets.  Soybean meal contributes the
entire protein concentrate component at a higher dietary contribution of
trifloxystrobin than pea seed.  The livestock dietary burden remains
unchanged.  Therefore, the established livestock tolerances are
sufficient.

Conclusions.  The dietary burdens for cattle, poultry and swine are
unaffected by the proposed amended uses on dry peas and chickpeas;
therefore, the established tolerances for livestock commodities will not
be affected.

860.1500 Crop Field Trials

Dry Beans (Chickpeas)

49072801.der.doc

Bayer has submitted field trial data for trifloxystrobin on dry beans
(Phaseolus spp).  Nine trials were conducted in Canada encompassing
Zones 5 (ON; 3 trials), 7 (SK; 3 trials), 7A (AB; 1 trial), and 14 (SK;
2 trials) during the 2012 growing season.

At each test location, two foliar applications of a 1.2 lb ai/gal
suspension concentrate (SC) formulation; (USF 0728 325SC, EPA File
Symbol No. 264-1055) were applied in a spray volume of approximately 15
gallons per acre (GPA) (140 L/ha) with a RTI of 10-14 days.  The
corresponding target rate for trifloxystrobin was 0.12 lb ai/A (132 g
ai/ha/application) for a target seasonal rate of 0.24 lb ai/A (264 g
ai/ha).  An adjuvant was not added to the spray mixture. Dry bean seed
was harvested at PHIs of 28 to 32 days.  Dry bean seed was collected
from one site at PHIs of 21, 25, 29, 36, and 40 days to determine
residue decline.  Forage samples were not collected.

Residues of trifloxystrobin and the metabolite CGA 321113 in dry bean
seeds were quantified using HPLC-MS/MS with stable-labeled internal
standards.  Validation and concurrent recoveries were generated by
spiking at levels of 0.01 ppm, 0.05 ppm, and 0.2 ppm for each analyte. 
All recoveries were in the acceptable range of 70-120%, thus validating
the method.  The limit of quantitation (LOQ) was reported as 0.01 ppm
for each analyte. 

Samples were stored for a maximum of 116 days before analysis.  Storage
stability data are available showing that residues of trifloxystrobin
and the metabolite CGA 321113 were stable in/on various raw agricultural
and processed commodities stored under frozen storage conditions for at
least 18.6 months, thus demonstrating the acceptability of storage
intervals and conditions in the study. 

≤ 0.013 ppm for the metabolite CGA321113, and ≤0.023 ppm for the
combined residues (trifloxystrobin and CGA 321113) at PHIs of 28-32 days
after two treatments at a total application rate of 0.23-0.24 lb ai/A
(258 to 271 g ai/ha) of trifloxystrobin.  Average residues of
trifloxystrobin were observed to decline from 0.0145 ppm to levels below
LOQ (<0.01 ppm) within a 4-day span (PHIs of 21-25 days).  Average
residues of the metabolite CGA321113 were also observed to decline from
0.016 ppm to 0.011 ppm over a period of 19 days (PHIs of 21-40 days).

Table 5. 	      Summary of Residue Data from Crop Field Trials with
Trifloxystrobin.

Analyte	Total Rate1 

lb ai/A

(g ai/ha)	PHI (days)	N	Residue Levels2 (ppm)





Min.	Max.	LAFT	HAFT	Median	Mean	Std. Dev.

Dry Beans

Trifloxystrobin	(0.23-0.24)

258-271	28-32	9	<0.01	<0.01	<0.01	<0.01	<0.01	<0.01	NA

CGA 321113



<0.01	0.013	<0.01	0.013	0.01	0.01	0.001

Combined Residues



<0.02	<0.023	<0.02	<0.023	0.02	0.02	0.001

1 Total rate refers only to trifloxystrobin in the USF 0728 325 SC
application.

2 Except for Min/Max, values reflect per trial averages based on the
combined residues trifloxystrobin and CGA 321113 calculated as parent
equivalents. A value of 0.01 ppm was used in any calculations involving
residues less than LOQ.

n = number of field trials; LAFT = Lowest Average Field Trial; HAFT =
Highest Average Field Trial

Dry Peas

49072802.der.doc

Bayer has submitted field trial data for trifloxystrobin on dry peas
(Pisum spp).  Nine trials were conducted in Canada and the US
encompassing Zones 7 (SK, ND; 4 trials), and 14 (AB, SK; 5 trials)
during the 2012 growing season.

At each test location, two foliar applications of a 1.2 lb ai/gal SC
formulation; (USF 0728 325SC, EPA File Symbol No. 264-1055) were applied
in a spray volume of approximately 15 GPA (140 L/ha) with a RTI of 11-14
days.  The corresponding target rate for trifloxystrobin was 0.12 lb
ai/A (132 g ai/ha/application) for a target seasonal rate of 0.24 lb
ai/A (264 g ai/ha).  An adjuvant was not added to the spray mixture. 
Dry pea vines (forage) and hay were collected at PHIs of 6 to 8 days and
dry pea seed was collected at PHIs of 29 to 31 days.  Samples were
collected from one site at PHIs of 0, 3, 7 and 13 days (forage and hay),
and 20, 25, 31, 34 and 40 days (seed) to determine residue decline. 

Residues of trifloxystrobin and the metabolite CGA 321113 in dry pea
seeds were quantified using HPLC-MS/MS with stable-labeled internal
standards. Validation and concurrent recoveries were generated by
spiking at levels of 0.01 ppm, 0.05 ppm, and 0.2 ppm for each analyte.
All recoveries were in the acceptable range of 70-120%, thus validating
the method. The LOQ was reported as 0.01 ppm for each analyte. 

Samples were stored frozen for a maximum of 203 days before analysis. 
Storage stability data are available showing that residues of
trifloxystrobin and the metabolite CGA 321113 were stable in/on various
raw agricultural and processed commodities stored under frozen storage
conditions for at least 18.6 months, thus demonstrating the
acceptability of storage intervals and conditions in the study. 

The results from these trials show that after applications at a total
rate of 0.23 to 0.24 lb ai/A (260 to 265 g ai/ha) for trifloxystrobin,
the maximum residues found on dry pea commodities were <LOQ (<0.01 ppm),
8.20 ppm, and 2.30 ppm for trifloxystrobin and 0.023 ppm, 0.49 ppm, and
0.055 ppm for CGA 321113, and 0.033, 8.43, 2.34 ppm for the combined
residues (trifloxystrobin and CGA 321113) on seed, hay, and vines
(forage), respectively.

In the decline trial, average combined residues of trifloxystrobin and
CGA 321113 were seen to decrease with increasing PHIs from 0.022 ppm at
20 days to 0.02 ppm at 40 days in seed, from 14.4 ppm at 0 day to 2.6
ppm at 13 days in hay, and from 2.8 ppm at 0 day to 0.7 ppm at 13 days
in vines (forage).

Table 6. 	Summary of Residue Data from Crop Field Trials with
Trifloxystrobin.

Analyte	Total Rate1

lb ai/ha 

(g ai/ha)	PHI (days)	n	Residue Levels2 (ppm)





Min.	Max.	LAFT	HAFT	Median	Mean	Std. Dev.

Dry Pea, Seed

Trifloxystrobin	0.23-0.24

(260-265)	29-31	9	<0.01	<0.01	<0.01	<0.01	<0.01	<0.01	NA

CGA 321113



<0.01	0.023	<0.01	0.022	0.011	0.013	0.004

Combined Residues



<0.02	<0.033	<0.02	<0.032	0.021	0.023	0.004

Dry Pea, Hay

Trifloxystrobin	0.23-0.24

(260-265	6-8	9	2.10	8.20	2.10	6.75	4.20	4.49	1.743

CGA 321113



0.04	0.49	0.09	0.40	0.25	0.24	0.097

Combined Residues



2.14	8.43	2.19	7.10	4.51	4.73	1.808

Dry Pea, Vines (Forage)

Trifloxystrobin	0.23-0.24

(260-265)	6-8	9	0.55	2.30	0.61	1.95	1.05	1.12	0.408

CGA 321113



0.023	0.055	0.026	0.052	0.039	0.038	0.008

Combined Residues



0.58	2.34	0.64	1.98	1.09	1.16	0.410

1 Total rate refers only to trifloxystrobin in the USF 0728 325 SC
application

2 Except for Min/Max, values reflect per trial averages based on the
combined residues trifloxystrobin and CGA 321113 calculated as parent
equivalents. A value of 0.01 was used in any calculations involving
residues less than LOQ.

n = number of field trials; LAFT = Lowest Average Field Trial; HAFT =
Highest Average Field Trial.

Conclusions.  Pending submission of a revised Section F, the submitted
dry peas and chickpeas field trial data are adequate to fulfill data
requirements in support of the proposed uses. The trials reflect the
proposed use pattern and the number and locations of the trials are
acceptable based on the ChemSAC minutes of 20 March, 2013.

The proposed tolerances for chickpea hay and vines are not needed since
both commodities are not significant livestock feed items.  Based on the
OECD tolerance calculation spreadsheet, the recommended tolerances are
0.06 ppm for pea, dry, seed; 15 ppm for pea, field, hay; 4 ppm for pea,
field, vines; and 0.04 ppm for chickpea, seed.  The recommended
tolerance for chickpea seed at 0.04 ppm is increased to 0.06 ppm for
harmonization purposes.  The pea results are translated to cover
lentils.  The proposed tolerances on chickpea seed and lentil seed are
not needed since pea dry seed includes these commodities (40 CFR 180.1
(g)).  HED is recommending to establish a tolerance on pea, dry, seed at
0.06 ppm in order to harmonize with the Canadian recommended MRLs.  A
revised Section F needs to be submitted to reflect the correct commodity
definitions.  Refer to Appendix I for the tolerance calculations.  

860.1520 Processed Food and Feed

There are no processed commodities associated with the proposed new
uses; therefore, no new processing studies were submitted or reviewed
for this petition. 

860.1650 Submittal of Analytical Reference Standards

Analytical standards for trifloxystrobin (expiration 07/13/2016) and
CGA-321113 [trifloxystrobin acid (E,E); expiration 09/24/2015] are
currently available in the EPA National Pesticide Standards Repository
(communication with Theresa Cole, ACB, 06/18/2014).

860.1850 and 860.1900 Confined and Field Accumulation in Rotational
Crops

DP#s 254213, 254217, 254218, and 254221, 04/06/2000, L. Cheng
(PP#9F5070)

DP#s 254208 and 257888, 07/22/1999, F. Ives (PP#8F04955)

An adequate confined rotational crop study is available (PP#8F04955)
reflecting the application of 14C-trifloxystrobin at 2.0 lb ai/A (~8X
the maximum proposed seasonal application rate for the requested uses). 
Based on the data from the primary plant metabolism studies and the
confined rotational crop study, HED concluded that the residues of
concern in plants, including rotational crops, are parent and its free
acid metabolite CGA-321113. 

Adequate limited field rotational crop studies are also available
(PP#9F5070) reflecting the application of trifloxystrobin (water
granular (WG) formulation) to primary crops of squash or cucumbers as
four foliar applications at rates totaling 1.0 lb ai/A/ season (~4X the
maximum proposed seasonal application rate for the requested uses).  In
these two field trials, rotational crops of lettuce, turnips, and wheat
were planted at 30- and 120-day PBIs, and samples of the appropriate
RACs were collected and analyzed for residues of trifloxystrobin and
CGA-321113.  At both test locations, residues of trifloxystrobin and
CGA-321113 were <0.02 ppm (<LOQ) in all RAC samples from crops planted
30 days after the last application; therefore, no analysis was conducted
on the 120-day PBI samples.  

The available field rotational crop data support a 30-day PBI for all
crops not listed on the label for direct use.  

860.1550 Proposed Tolerances

The Agency has determined that the tolerance expression for primary and
rotational crops should include parent trifloxystrobin and its free acid
metabolite CGA-321113.  Permanent tolerances are currently established
for the combined residues of trifloxystrobin and CGA–321113 in/on
various plant and animal commodities ranging from 0.01 ppm to 38 ppm [40
CFR §180.555(a)].  The tolerance expression proposed under the current
petition is appropriate.

In support of registration of the 1.27 lb ai/gal SC formulation of
trifloxystrobin, the petitioner is proposing tolerances for the
following commodities:  chickpeas, dry peas, and lentils.  The proposed
and established tolerances, along with the recommendations of HED, are
presented in Table 7.

In support of the proposed tolerances, adequate field trial reflecting
the proposed use patterns were submitted for chickpeas and dry peas.

The proposed tolerances for chickpea hay and vines are not needed since
both commodities are not significant livestock feed items.  The OECD
statistical calculation procedure was utilized for determining
appropriate tolerance levels (refer to Appendix II).  The available data
will support the proposed tolerances of 0.06 ppm for pea, dry, seed; 15
ppm for pea, field, hay; 4 ppm for pea, field, vines; and 0.04 ppm for
chickpea, seed.  The recommended tolerance for chickpea seed at 0.04 ppm
is increased to 0.06 ppm for harmonization purposes. The pea results are
translated to cover lentils.  The proposed tolerances on chickpea seed
and lentil seed are not needed since pea dry seed includes these
commodities (40 CFR 180.1 (g)). HED is recommending to establish a
tolerance on pea, dry, seed at 0.06 ppm in order to harmonize with the
Canadian recommended MRLs.  A revised Section F needs to be submitted to
reflect the correct commodity definitions.  Refer to Appendix I for the
tolerance calculations.  

Codex MRLs are expressed in terms of trifloxystrobin for plants; thus
harmonization of MRLs is not possible.  The Codex residue definition for
livestock is the same as the US.  The Canadian residue definitions for
plants and livestock are the same as the US.  There are no Codex MRLs
established on the proposed crops.  Canadian MRLs exist for dry
chickpeas, dry lentils, and dry field peas at 0.02 ppm. This petition is
reviewed as a work share with Canada; tolerances for the proposed crops
are harmonized. 

Table 7. 	Tolerance Summary for Trifloxystrobin.  

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

Pea, dry, seed	0.06	0.06

	Pea, dry, hay	15	15	Pea, field, hay

Pea, dry, vines	4	4	Pea, field, vines

Chickpea, seed	0.06	Not Needed	Covered by pea, dry, seed/Harmonization

Chickpea, hay	15	Not Needed

	Chickpea, vines	4	Not Needed

	Lentil, seed	0.06	Not Needed	Covered by pea, dry, seed.



References

DP#:	254920

Subject:	Product Chemistry Review of CGA-279202 Technical.

From:	A. Smith

To:	J. Whitehurst 

Date:	04/23/1999

MRIDs:	44496601 and 44502801

DP#:	257835

Subject:	Trifloxystrobin.  Results of HED Metabolism Assessment Review
Committee Meeting held 6/15/99.

From:	F. Ives and B. Greear

To:	G. Kramer

Dated:	07/13/1999

MRIDs:	None

DP#s:	254208 and 257888

Subject:	PP#8F04955.  Request for Uses and Tolerances for
Trifloxystrobin (proposed ISO common name) on Cucurbit Vegetables,
Grapes, Peanuts, and Pome Fruit and a Tolerance for Imported Bananas.

From:	F. Ives

To:	C. Giles-Parker/J. Whitehurst

Dated:	07/22/1999

MRIDs:	44502801, 44496822-44966845, 44527505, 44496601-44496602,
44496812, 44496847-44496848, 44496817-44496820

DP#s:	254213, 254217, 254218, and 254221

Subject:	PP#9F5070.  Trifloxystrobin on Almond, Fruiting Vegetables,
Hops, Sugar Beet, Potato, and Wheat.  Review of Analytical Methods and
Residue Data.

From:	L. Cheng

To:	C. Giles-Parker/J. Whitehurst 

Date:	04/06/200

MRIDs:	44757207, 44757208, 44757209, 44757210, 44757211, 44757212,
44757213, 44757214, 44757215, 44757216, 44757217, 44757218, and 44757219

DP#:	265003

Subject:	PP#8F04955.  Trifloxystrobin on Apples, Apple Pomace, Grapes,
Summer Squash, Peanut Hay, Peanuts, Cow Liver, Cow Milk, and Raisin. 
Evaluation of Tolerance Method Validation Report dated January 18, 2000.

From:	L. Cheng

To:	C. Giles-Parker/J. Whitehurst

Dated:	04/13/2000

MRID:	44496836

DP#s:	267787 and 272054

Subject:	PP#0F06121.  PC Code 129112.  CAS # 141517-21-7. 
Trifloxystrobin on Barley, Citrus, Corn (Field and Pop), Pecan,
Pistachio, Rice, and Stone Fruit.  Review of Analytical Methods and
Residue Data.

From:	L. Cheng

To:	C. Giles-Parker

Dated:	01/17/2002

MRIDs:	45080800, 45080806, 45080808, 45080809, 45080810, 45080811,
45126200, 45269400, 45269401, 45269402, 45276400, 45276401

DP#:	286639

Subject:	Trifloxystrobin.  Summary of Analytical Chemistry and Carrot
and Celery Residue Data.  PP#3E06522

From:	L. Cheng

To:	J. Whitehurst/C. Giles-Parker 

Date:	01/23/2003

MRIDs:	45784901 and 45784902

DP#:	287242

Subject:	Trifloxystrobin.  Summary of Wheat Metabolism Data. 
Conditional Data.

From:	L. Cheng

To:	J. Whitehurst/C. Giles-Parker

Dated:	10/08/2003

MRIDs:	45721803, 45721804

DP#:	338207

Subject:	Trifloxystrobin.  Petition for Tolerances on Grasses Grown for
Seed. Summary of Analytical Chemistry and Residue Data.  Petition
Number: 6F7024.

From:	D. Rate

To:	D. Rate

Dated:	04/10/2007

MRID:	46727801

DP#s:	357865 and 362063

Subject:	Trifloxystrobin.  Application for Section 3 Registration for
Use of Suspension Concentrate Formulations on Soybean.  Summary of
Analytical Chemistry and Residue Data.

From:	S. Funk

To:	T. Kish/B. Crowe

Dated:	06/23/2009

MRID:	47496202

DP#s:	363108

Subject:	Trifloxystrobin.  Application for Section 3 Registration for
Use on Field, Sweet, and Pop Corn.  Summary of Analytical Chemistry and
Residue Data.

From:	W. Cutchin

To:	T. Kish/J. Bauzin

Dated:	01/25/2010

MRID:	47521902

Attachments:  

International Residue Limit Status sheet

Appendix I - Tolerance Assessment Calculations

Trifloxystrobin (129112, Requested 2/25/14)

Summary of US and International Tolerances and Maximum Residue Limits 

Residue Definition:

US	Canada	Mexico2	Codex

40 CFR 180.555:

Plants and Livestock:  sum of trifloxystrobin, benzeneacetic acid,
(E,E)-α-(methoxyimino)-2-[[[[1-[3-(trifluoromethyl) phenyl]ethylidene]
amino]oxy]methyl]-, methyl ester, and the free form of its acid
metabolite CGA–321113, 

(E,E)-methoxyimino-[2-[1-(3-trifluoromethyl-phenyl)-ethylideneaminooxyme
thyl]-phenyl]acetic acid, calculated as the stoichiometric equivalent of
trifloxystrobin	Methyl
(α,E)-α-(methoxyimino)-2-[[[(E)-[1-[3-(trifluoromethyl)phenyl]ethylide
ne]amino]oxy]methyl]benzeneacetate, including the metabolite
(α,E)-α-(methyoxyimino)-2-[[[(E)-[1-[3-(trifluromethyl)phenyl]ethylide
ne]amino]oxy]methyl]benzeneacetic acid, expressed as trifloxystrobin

Plant: Trifloxystrobin

Livestock: sum of trifloxystrobin and
[(E,E)-methoxyimino-{2-[1-(3-trifluoromethylphenyl)ethylideneaminooxymet
hyl]

phenyl}acetic acid] (CGA 321113), expressed as trifloxystrobin. The
residue is fat-soluble.

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

	US	Canada	Mexico2	Codex

Pea, dry, seed	0.06	0.06

(proposed) (pea field, pea pigeon, chickpea, lentil) seed

0.02 dry (field peas, chickpeas, lentils)



Pea, field, hay	15



	Pea, field, vines	4

































	Completed: M. Negussie; 02/25/14

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.

Appendix I.  Tolerance Assessment Calculations.

The tolerance expression for trifloxystrobin is combined residues of
trifloxystrobin and CGA-321113.  The LOQ for each analyte in each
commodity was 0.01 ppm, for a combined LOQ of 0.02 ppm.

For the crops listed below, the OECD statistical calculation spreadsheet
was used for calculating recommended tolerances.  As specified in the
OECD document, the average residue value was used.  

The dataset used to establish tolerances for trifloxystrobin on dry pea
(seed, forage, hay) and chickpeas consisted of field trial data
representing application rates of 0.23-0.24 lb ai/A with a  28-32-day
PHIs for seed and 6-8-day PHIs for field pea forage (vines) and hay.  As
specified by the Guidance for Setting Pesticide Tolerances Based on
Field Trial Data (SOP), the field trial application rates and minimum
label PHIs are within 25% of the maximum label application rate. The
average residue values that were entered into the tolerance spreadsheet
are provided in Table I-1 and Table I-2 (below).  Using the OECD
tolerance calculation spreadsheet, the recommended tolerances are 0.06
ppm for pea, dry, seed, 15 ppm for pea, field, hay; 4 ppm for pea,
field, vines; and 0.04 ppm for chickpea, seed.  HED is recommending to
increase the tolerance for chickpea, seed to 0.06 ppm for harmonization
purposes. The proposed tolerances on chickpea seed and lentil seed are
not needed since pea dry seed includes these commodities (40 CFR 180.1
(g)).  HED is recommending to establish a tolerance on pea, dry, seed at
0.06 ppm in order to harmonize with the Canadian recommended MRLs.  A
revised Section F needs to be submitted to reflect the correct commodity
definitions.

Table I-1.	Residue Data Used to Calculate Tolerance for Trifloxystrobin
on Chickpea.

Regulator:	EPA

Chemical:	Trifloxystrobin

Crop:	Chickpea (Dry beans)

PHI:	28-32 Day

App. Rate:	0.23-0.24 lb ai/A

Submitter:	Bayer CropScience

MRID Citation:	MRID 49072801

	Combined Residues of Trifloxystrobin and CGA-321113 (ppm)

	0.021

	0.02

	0.021

	0.023

	0.02

	0.02

	0.02

	0.022

	0.02



	

Table I-2.	Residue Data Used to Calculate Tolerance for Trifloxystrobin
on Dry Peas.

Regulator:	EPA	EPA	EPA

Chemical:	Trifloxystrobin	Trifloxystrobin	Trifloxystrobin

Crop:	Pea, field, seed	Pea, field, hay	Pea, field, forage (vines)

PHI:	29-31 Days	6-8 Days	6-8 Days

App. Rate:	0.23-0.24 lb ai/A	0.23-0.24 lb ai/A	0.23-0.24 lb ai/A

Submitter:	Bayer CropScience	Bayer CropScience	Bayer CropScience

MRID Citation:	MRID 49072802	MRID 49072802	MRID 49072802

	Combined Residues of Trifloxystrobin and CGA-321113 (ppm)

	0.032	4.51	0.94

	0.023	6.32	1.09

	0.026	2.19	1.35

	0.020	3.27	0.636

	0.020	3.58	0.812

	0.021	7.10	1.54

	0.022	5.55	0.95

	0.021	6.94	1.15

	0.020	3.17	1.98





	

Figure I-1.  Tolerance Spreadsheet Summary of Trifloxystrobin Field
Trial Data for Chickpeas.

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- Highest residue	0.023	 

 	- Mean + 4 SD	0.025	 

 	- CF x 3 Mean	0.039	 

 	Unrounded MRL	0.039	 

 	 	 	 

 	Rounded MRL	0.04	 

 	 	 	 

 	 High uncertainty of MRL estimate.	 

 	[High level of censoring]	 

 	 	 	 



Figure I-2.  Tolerance Spreadsheet Summary of Trifloxystrobin Field
Trial Data for Dry Pea Seed.

 	 	 	 

 	Trifloxystrobin	 

 	Dry Pea, Seed	 

 	EPA	 

 	0.23-0.24 lb ai/A	 

 	 	 	 

 	Total number of data (n)	9	 

 	Percentage of censored data	33%	 

 	Number of non-censored data	6	 

 	Lowest residue	0.020	 

 	Highest residue	0.032	 

 	Median residue	0.021	 

 	Mean	0.023	 

 	Standard deviation (SD)	0.004	 

 	Correction factor for censoring (CF)	0.778	 

 	 	 	 

 	Proposed MRL estimate	 	 

 	 	 	 

 	- Highest residue	0.032	 

 	- Mean + 4 SD	0.039	 

 	- CF x 3 Mean	0.053	 

 	Unrounded MRL	0.053	 

 	 	 	 

 	Rounded MRL	0.06	 

 	 	 	 

 	 	 

 	 	 

 	 	 	 



Figure I-3.  Tolerance Spreadsheet Summary of Trifloxystrobin Field
Trial Data for Pea Field Hay.

 	 	 	 

 	Trifloxystrobin	 

 	Dry Pea, Hay	 

 	EPA	 

 	0.23 - 0.24 lb ai/A	 

 	 	 	 

 	Total number of data (n)	9	 

 	Percentage of censored data	0%	 

 	Number of non-censored data	9	 

 	Lowest residue	2.190	 

 	Highest residue	7.100	 

 	Median residue	4.510	 

 	Mean	4.737	 

 	Standard deviation (SD)	1.806	 

 	Correction factor for censoring (CF)	1.000	 

 	 	 	 

 	Proposed MRL estimate	 	 

 	 	 	 

 	- Highest residue	7.100	 

 	- Mean + 4 SD	11.960	 

 	- CF x 3 Mean	14.210	 

 	Unrounded MRL	14.210	 

 	 	 	 

 	Rounded MRL	15	 

 	 	 	 

 	 	 

 	 	 

 	 	 	 



Figure I-4.  Tolerance Spreadsheet Summary of Trifloxystrobin Field
Trial Data for Pea Field Forage (Vines).

 	 	 	 

 	Trifloxystrobin	 

 	Dry Pea, Forage (Vines)	 

 	EPA	 

 	0.23 - 0.24 lb ai/A	 

 	 	 	 

 	Total number of data (n)	9	 

 	Percentage of censored data	0%	 

 	Number of non-censored data	9	 

 	Lowest residue	0.636	 

 	Highest residue	1.980	 

 	Median residue	1.090	 

 	Mean	1.161	 

 	Standard deviation (SD)	0.410	 

 	Correction factor for censoring (CF)	1.000	 

 	 	 	 

 	Proposed MRL estimate	 	 

 	 	 	 

 	- Highest residue	1.980	 

 	- Mean + 4 SD	2.802	 

 	- CF x 3 Mean	3.483	 

 	Unrounded MRL	3.483	 

 	 	 	 

 	Rounded MRL	4	 

 	 	 	 

 	 	 

 	 	 

 	 	 	 



Trifloxystrobin	Summary of Analytical Chemistry and Residue Data	DP#: 
413711

	Pg   PAGE  1  of   NUMPAGES  21 

