
                                       
                    UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                               WASHINGTON, D.C.  20460
                                       
					OFFICE OF
	CHEMICAL SAFETY AND
	POLLUTION PREVENTION

MEMORANDUM

Date:		05-JUN-2014

Subject:	Sulfentrazone.  Section 3 Registration Request to Add New Use on Apples.  Summary of Analytical Chemistry and Residue Data.

PC Code:  129081
DP Barcode:  D415626
Decision No.:  483232
Registration Nos.:  279-3370, 279-3189, & 279-3220
Petition No.:  3E8202
Regulatory Action:  Amended Section 3
Risk Assessment Type:  NA
Case No.:  7231
TXR No.:  NA
CAS No.:  122836-35-5
MRID No.:  49124501
40 CFR:  §180.498

From:		George F. Kramer, Ph.D., Branch Senior Chemist
		Registration Action Branch 1 (RAB1)
		Health Effects Division (HED, 7509P)

Through:	Charles W. Smith III, Branch Chief
		RAB1/HED (7509P)
         
         To:		Laura Nollen/Barbara Madden, RM 05
	Registration Division (RD, 7505P) 


Executive Summary

Sulfentrazone is an aryl triazolinone herbicide used to control a variety of broadleaf weeds.  The mode-of-action for controlling emerging weeds is by protoporphyrinogen oxidase (PPO) inhibition.  Sulfentrazone acts by the same mechanism as the diphenyl ether herbicides in which membrane disruption is initiated by the inhibition of PPO in the chlorophyll biosynthetic pathway and leads to the subsequent build-up of toxic intermediates.  Plants emerging from soils treated with sulfentrazone turn necrotic and die shortly after exposure to light.

The Interregional Research Project No. 4 (IR-4) has submitted a petition proposing the establishment of permanent tolerances for the combined residues of the free and conjugated forms of sulfentrazone, including its metabolites and degradates, in or on the commodities in the table below.  Compliance with the proposed tolerance levels specified below is to be determined by measuring only the sum of sulfentrazone (N-[2,4-dichloro-5-[4-(difluoromethyl)-4,5-dihydro-3-methyl-5-oxo-1H-1,2,4-triazol-1-yl]phenyl]methanesulfonamide) and its metabolites HMS (N-(2,4-dichloro-5-(4-(difluoromethyl)-4,5-dihydro-3-hydroxymethyl-5-oxo-1H-1,2,4-triazol-1-yl)phenyl)methanesulfonamide) and DMS (N-(2,4-dichloro-5-(4-(difluoromethyl)-4,5-dihydro-5-oxo-1H-1,2,4-triazol-1-yl)phenyl)methanesulfonamide, calculated as the stoichiometric equivalent of sulfentrazone in or on the following commodity:

Apple
0.15

A tolerance is currently established under 40 CFR §180.498(a)(1) for the combined residues of sulfentrazone and its major metabolite, HMS, in/on soybean seed at 0.05 ppm.  In addition, permanent tolerances are established under 40 CFR §180.498(a)(2) for the combined residues of sulfentrazone and its metabolites HMS and DMS in/on several food commodities; these established tolerances range from 0.15 ppm (various plant commodities) to 0.40 ppm (peanut meal and Brassica, leafy greens, subgroup 5B).  Tolerances for the combined residues of sulfentrazone and its metabolites HMS and DMS have been established under 40 CFR §180.498(c) in connection with regional registrations; these include tolerances for residues in/on succulent lima bean, succulent cowpea, and wheat grain at 0.15 ppm.  Finally, tolerances are established under 40 CFR §180.498(d) for inadvertent and indirect combined residues of sulfentrazone and its metabolites HMS and DMS in/on cereal grain (excluding sweet corn) bran, forage, grain, hay, hulls, stover, and straw at 0.1-0.6 ppm as a result of the application of sulfentrazone to growing crops.

The sulfentrazone end-use products (EPs) relevant for this registration request include Spartan[(R)] Herbicide (EPA Reg. No. 279-3189; 75% dry-flowable or DF formulation) and Spartan[(R)] 4F Herbicide (EPA Reg. No. 279-3220; 4 lb/gal flowable-concentrate (FlC) formulation).  The petitioner requests the amendment of these EP labels to incorporate a new use on apples.  These EPs are proposed for a maximum seasonal rate of 0.375 lb ai/A using ground equipment with a pre-harvest interval (PHI) of 14 days.

The nature of the residue in plants is adequately understood.  Data concerning the metabolism of sulfentrazone following preemergent applications in soybeans and confined rotational crops were submitted in conjunction with the soybean petition (PP#4F04407, D211168).  The HED Metabolism Committee determined that sulfentrazone and its metabolite HMS are the residues of concern in soybeans, and that sulfentrazone and its metabolites HMS and DMS (free and conjugated) are the residues of concern in rotational crops (D226434, 6/14/96, G. Kramer).  In addition, HED concluded that the results of the rotational crop metabolism studies may be translated to support preemergent uses on all crops (D220548, 3/13/96, G. Kramer).  Data concerning the metabolism of sulfentrazone following postemergent applications in corn, soybean, and radish were submitted in conjunction with recent petitions (D389972, 5/9/12, G. Kramer).  The metabolism of sulfentrazone was similar to that following preemergent application; no additional major metabolites were identified.  HED thus concludes metabolism data are now available to support postemergence applications and that sulfentrazone and its metabolites HMS and DMS (free and conjugated) are the residues of concern.

The nature of the residue in livestock is adequately understood based on acceptable ruminant and poultry metabolism studies.  Sulfentrazone per se and its metabolites HMS and DMS were identified as the residues of concern in meat, milk, poultry, and eggs.  

There is an adequate residue analytical method for the purposes of tolerance enforcement.  A gas chromatography (GC) method for the determination of sulfentrazone and its metabolites DMS and HMS was submitted with a petition for a sulfentrazone tolerance on soybeans (PP#4F04407).  A petition method validation (PMV) was successfully completed by the Agency's Analytical Chemistry Laboratory (ACL).  The limit of quantitation (LOQ) and limit of detection (LOD) were determined to be 0.05 ppm and 0.005-0.025 ppm, respectively.  The method has been forwarded to the Food and Drug Administration (FDA) for inclusion in the Pesticide Analytical Methods Vol. II (PAM II).

The data requirements for multiresidue methods (MRMs) are fulfilled.  The FDA MRMs are not suitable as enforcement methods since sulfentrazone residues of concern were not successfully recovered by the FDA MRMs.

Samples of raw agricultural and processed commodities were analyzed for residues of sulfentrazone and its metabolites DMS and HMS using a liquid chromatograph equipped with tandem mass spectrometers (LC/MS/MS) method.  The validated LOQ was 0.025-0.05 ppm for each analyte.  These methods are adequate for data collection based on acceptable method validation and concurrent recovery data.

The submitted field trial residue data apple are adequate.  The field trial data reflect the proposed use patterns; an adequate number of trials were conducted in the appropriate geographic regions; and samples were analyzed for the residue of concern using validated data-collection methods.  The storage intervals were also validated.  

No quantifiable residues were found in apples treated at an exaggerated rate (5X); therefore, separate tolerances are not required for apple processed commodities.  

Analytical standards for sulfentrazone and its metabolites DMS and HMS are currently available at the EPA National Pesticide Standards.  However, as the existing stocks are depleted, the Repository has requested that the registrant provide additional amounts of sulfentrazone (5 g) and HMS (3 g).

No Codex, Canadian, or Mexican maximum residue limits (MRLs) have been established for sulfentrazone on apples.  Therefore, harmonization of MRLs and U.S. tolerances is not an issue at this time.  


Regulatory Recommendations and Residue Chemistry Deficiencies

There are no residue chemistry issues that would preclude granting an unconditional registration for the requested use on apples.  The proposed uses and the submitted data support the establishment of the following tolerances for the combined residues of free and conjugated sulfentrazone and its metabolites HMS and DMS in/on:

Apple
0.15

A human-health risk assessment is forthcoming.


Background

The chemical structure and nomenclature of sulfentrazone are presented in Table 1, and the physicochemical properties of the technical grade of sulfentrazone are presented in Table 2.

Table 1.  Sulfentrazone Nomenclature.
Chemical structure
                                       
Common name
Sulfentrazone
Company experimental name
F6285; FMC 97285
IUPAC name
2',4'-dichloro-5'-(4-difluoromethyl-4,5-dihydro-3-methyl-5-oxo-1H-1,2,4-triazol-1-yl)methanesulfonanilide
CAS name
N-(2,4-dichloro-5-(4-(difluoromethyl)-4,5-dihydro-3-methyl-5-oxo-1H-1,2,4-triazol-1-yl)phenyl)methanesulfonamide
CAS registry number
122836-35-5
End-use product (EP)
4 lb/gal FlC formulation (Spartan[(R)] 4F Herbicide; EPA Reg. No. 279-3220) and 75% DF formulation (Spartan[(R)] Herbicide; EPA Reg. No. 279-3189)
Chemical structure of DMS metabolite
                                       
Common name
3-desmethyl sulfentrazone; DMS
Chemical name
N-(2,4-dichloro-5-(4-(difluoromethyl)-4,5-dihydro-5-oxo-1H-1,2,4-triazol-1-yl)phenyl)methanesulfonamide
Chemical structure of HMS metabolite
                                       
Common name
3-hydroxymethyl sulfentrazone; HMS
Chemical name
N-(2,4-dichloro-5-(4-(difluoromethyl)-4,5-dihydro-3-hydroxymethyl-5-oxo-1H-1,2,4-triazol-1-yl)phenyl)methanesulfonamide

Table 2.  Physicochemical Properties of Technical Grade Sulfentrazone.
Parameter
Value
Reference
Melting range
120-122 ºC
DP# 288712, 3/6/03, G. Kramer, G. Reddy, and L. Liu
pH
4.78 at 23 ºC

Density
0.53 g/cm[3]

Water solubility
4.0 x 10[2] ug/g

Solvent solubility
18.6% w/w in acetonitrile

Vapor pressure
8 x 10[-10] mm Hg

Dissociation constant, pKa
6.56

Octanol/water partition coefficient, Log(KOW)
1.49 at pH 5

UV/visible absorption spectrum
Not available



860.1200 Directions for Use

A list of the sulfentrazone end-use products relevant to this registration request is presented in Table 3.  The proposed crop use directions are summarized in Table 4A.  Information regarding rotational crop restrictions is listed in Table 4B.

Table 3.  Summary of Proposed End-Use Products.
Trade Name
                                   Reg. No.
                             ai (% of formulation)
                               Formulation Type
Target Crops
Target Pests
Spartan[(R)] 4F Herbicide
                                   279-3220
                                     39.6
                                 (4 lb ai/gal)
                                      FlC
Rhubarb, Turnips, Sunflower Subgroup 20B, Cowpeas, Wheat (Spring), Tree Nut Crop Group 14, Pistachio, Low-Growing Berry Crop Group 13-07, Citrus Fruit Crop Group 10-10, Nongrass Animal Feeds Crop Group 18
Broadleaf, grass, and sedge weeds.
Spartan[(R)] Herbicide
                                   279-3189
                                      75
                                      DF


                            F6285 4F CAL Herbicide
                                   279-3370
                              39.6 (4 lb ai/gal)
                                      FlC
Rhubarb, Turnips, Sunflower Subgroup 20B, Wheat (Spring), Tree Nut Crop Group 14, Pistachio, Low-Growing Berry Crop Group 13-07, Citrus Fruit Crop Group 10-10, Nongrass Animal Feeds Crop Group 18


Table 4.  Summary of Proposed Directions for Use of Sulfentrazone.
                         App. Timing; Type; and Equip.
                          Formulation (EPA Reg. No.)
                               Application Rates
                             Max. # App. per Year
                            Max. Yearly App. Rate 
                        Use Directions and Limitations
                       Citrus Fruit Crop Group 10-10[c]
Apply as soil application to orchard floors or as uniform band application directed towards base of the trunk of trees.

Ground, impregnated onto dry bulk fertilizer.
                             Spartan 4F Herbicide
                                  (279-3320)
                             0.125 - 0.375 lb ai/A
                                       
                                   Up to 3 
                                 0.375 lb ai/A
*General use directions:  min of 10 GPA.
PHI = 14 days.
RTI = 60 days.
Apply using ground equipment only; do not use airblast sprayer or apply by air.
Avoid direct or indirect spray contact with foliage and fruit.

                            F6285 4F CAL Herbicide
                                  (279-3370)
                                       
                                       
                                       


                               Spartan Herbicide
                                  (279-3189)
                                       
                                       
                                       


Conclusions:  The use directions are adequate to allow HED an assessment of whether the submitted residue data reflect the maximum residues likely to occur.  


860.1300 Nature of the Residue  -  Plants 

The nature of the residue in plants is adequately understood.  Data concerning the metabolism of sulfentrazone following preemergent applications in soybeans and confined rotational crops were submitted in conjunction with the soybean petition (PP#4F04407, D211168).  The HED Metabolism Committee determined that sulfentrazone and its metabolite HMS are the residues of concern in soybeans, and that sulfentrazone and its metabolites HMS and DMS (free and conjugated) are the residues of concern in rotational crops (D226434, 6/14/96, G. Kramer).  In addition, HED concluded that the results of the rotational crop metabolism studies may be translated to support preemergent uses on all crops (D220548, 3/13/96, G. Kramer).  Data concerning the metabolism of sulfentrazone following postemergent applications in corn, soybean, and radish were submitted in conjunction with recent petitions (D389972, 5/9/12, G. Kramer).  The metabolism of sulfentrazone was similar to that following preemergent application; no additional major metabolites were identified.  HED thus concludes metabolism data are now available to support postemergence applications and that sulfentrazone and its metabolites HMS and DMS (free and conjugated) are the residues of concern.


860.1300 Nature of the Residue  - Livestock

Adequate ruminant and poultry metabolism studies were submitted in conjunction with the soybean petition (PP#4F04407).  The metabolism of sulfentrazone in livestock differs from that in plants as metabolism proceeds only by oxidation of the 3-methyl group to form HMS, followed by further oxidation to form sulfentrazone carboxylic acid which is decarboxylated to DMS.  Sulfentrazone per se and its metabolites HMS and DMS were identified as the residues of concern in meat, milk, poultry, and eggs.  


860.1340 Residue Analytical Methods

Enforcement Method

A GC analytical method for the determination of sulfentrazone, DMS, and HMS residues (free and conjugated) in/on various matrices was submitted with a petition for a sulfentrazone tolerance on soybeans (PP#4F04407).  A PMV was successfully completed by the Agency's ACL.  The LOQ and LOD were determined to be 0.05 ppm and 0.005-0.025 ppm, respectively.  HED concluded that the method is suitable for enforcement purposes (D233520, G. Kramer, 3/25/97).  The method was forwarded to FDA for inclusion in PAM II (Letter, G. Kramer, 9/18/98).  This method is suitable for enforcement of the tolerances associated with this petition.

Data-Collection Methods

Samples of raw agricultural commodities (RACS) and processed commodities were analyzed for residues of sulfentrazone and its metabolites DMS and HMS using a modified LC/MS/MS analytical method from study number P-3171 titled "Magnitude of the Residue of Sulfentrazone in/on Field Corn as a Rotated Crop Following Soybeans Treated with Authority Herbicide: Re-Analysis of Selected Trials using Revised Methodology."

Briefly, homogenized samples were refluxed with acetone:0.25N HCl (3:1, v:v) for 1 hour followed by filtration and concentration, then refluxed a second time with 1N HCI for 2 hours to free all conjugated analytes of concern and to completely convert sulfentrazone-3-carboxlic acid (SCA) to DMS.  The method quantifies residues of SCA as DMS and calculates SCA residues by a molecular weight-conversion factor (1.118).  SCA is a metabolism intermediate in formation of DMS.  After filtration, the aqueous solution was brought to volume with water and analyzed by LC/MS/MS.  Residues of the metabolites were not determined in parent equivalents.  The LOQ, determined as the lowest level of method validation (LLMV), was 0.025-0.05 ppm for all analytes in all matrices; the experimental LOD was 0.005-0.02 ppm.

The data-collection methods described above are adequate based on acceptable method validation and concurrent recovery data.


860.1360 Multiresidue Methods

MRM data for sulfentrazone and HMS were previously submitted and forwarded to FDA (Memo, 2/7/95, G. Kramer).  Neither compound was recovered by any of the protocols.  The FDA PESTDATA database dated 10/99 (PAM Vol. I, Appendix II) indicates that DMS is not recovered using MRM Sections 303 (Mills, Onley, and Gaither; Protocol E, nonfatty) and 304 (Mills, fatty food).  No information for recovery of DMS using Section 302 (Luke Method; Protocol D) is available.


860.1380 Storage Stability

IR-4 conducted concurrent storage stability studies with the apple field trials.  The results indicate that residues of sulfentrazone, DMS, and HMS are stable under frozen storage conditions in/on apple for up to 743 days (24.4 months).  Samples were stored frozen (<0 °C at the processing facility and analytical laboratory) from harvest/processing to analysis for 761 days (25 months) for apple (RAC), 783 days (25.8 months) for juice, and 748 days (24.6 months) for wet pomace.  

Conclusions:  The available storage stability data for sulfentrazone are adequate to support the storage conditions and durations of samples from the submitted crop field trials and processing studies.  There are no storage stability issues and no corrections for storage stability need be applied to the field trial and processing studies.


860.1480 Meat, Milk, Poultry, and Eggs

HED previously determined that, based on the established sulfentrazone tolerances for soybean and cereal grain commodities and the results of the livestock metabolism studies, conventional feeding studies are not required.  

Wet apple pomace is the only significant new feedstuff for livestock (ruminants only).  As no quantifiable residues were found in apples treated at an exaggerated rate (5X) and tolerances are established for feed items at higher levels than the recommended tolerance for the combined residues of sulfentrazone, DMS, and HMS of 0.15 ppm for apple (e.g., 0.50 ppm for wheat forage), the proposed new use on apples is not expected to increase the livestock dietary burdens.  


860.1500 Crop Field Trials

DER Reference List	49124501.der1.docx

IR-4 has submitted field trial data for sulfentrazone on apple.  Twelve field trials were conducted in the United States during the 2009 growing season in the North American Free Trade Agreement (NAFTA) Growing Zones 1 (NY; 2 trials), 2 (NJ and NC; 2 trials), 5 (MI; 2 trials), 9 (CO; 1 trial), 10 (CA; 1 trial), and 11 (ID and WA; 4 trials).

Each trial consisted of one untreated plot and one treated plot.  At each trial location, the treated plot received a single soil broadcast or banded application of Spartan[(R)] 4F Herbicide made to each side of the orchard row at 0.360-0.393 lb ai/A (1X).  Applications were made using ground equipment in spray volumes of 11-40 gal/A without an adjuvant.  Samples of mature apples were harvested at a PHI of 13-15 days.  

In samples harvested at a 13- to 15-day PHI following a single soil broadcast or banded application of the 4 lb ai/gal SC formulation at a total seasonal rate of 0.360-0.393 lb ai/A, residues of sulfentrazone and metabolites DMS and HMS were each below the LOQ (<0.05 ppm) in/on all samples of apples.  Combined residues of sulfentrazone, DMS, and HMS (and per-trial averages) were <0.15 (<0.15) ppm.

No residue-decline data were submitted; however, these data are not required because residues were non-quantifiable in/on all samples at the earliest harvest time.

Conclusions:  The submitted residue data are adequate to fulfill data requirements apples.  The number and locations of the crop field trials are in accordance with OPPTS Guideline 860.1500 (Table 5).  The available data will support the proposed use pattern.

TABLE 5.  Trial Numbers and Geographical Locations.
NAFTA Growing Zones
                                     Apple

                                   Submitted
                                 Requested[1]

                                       
                                    Canada
                                     U.S.
1
                                       2
                                      --
                                      4/3
2
                                     2[2]
                                      --
                                      2/1
5
                                       2
                                      --
                                      3/2
9
                                       1
                                      --
                                      1/1
10
                                       1
                                      --
                                      1/1
11
                                       4
                                      --
                                      5/4
Total
                                      12
                                       
                                     16/12
[1]  As per OCSPP 860.1500, Tables 1 and 5 for apple.  The second number reflects a 25% reduction in the number of field trials allowed for the crop as a representative commodity in support of a crop group/subgroup tolerance or when application results in no quantifiable residues.
[2]  The Zone 2 trial conducted in NJ was located near the border of Zone 1.

As all residues were <LOQ, the recommended tolerance for the combined residues of sulfentrazone, DMS, and HMS is 0.15 ppm for apple.   

860.1520 Processed Food and Feed

DER Reference List	49124501.der2.docx

IR-4 has submitted a processing study with sulfentrazone on apple.  In one apple trial conducted in NY during the 2009 growing season, a treated plot received a single soil-banded application of Spartan[(R)] 4F Herbicide made to each side of the orchard row at a rate of 1.919 lb ai/A (~5X).  Applications were made using ground equipment in spray volumes of 25.6 gal/A without an adjuvant.  Samples of mature apples were harvested at a PHI of 15 days and processed into pasteurized juice and wet pomace using simulated commercial procedures.  Processing was conducted by A.C.D.S. Research, Inc. (North Rose, NY).  Adequate descriptions were provided of the processing procedures, including material balance summaries.

In samples harvested at a 15-day PHI following a single soil-banded application of the 4 lb ai/gal SC formulation at a total seasonal rates of 1.919 lb ai/A, residues of sulfentrazone and metabolites DMS and HMS were each below the LOQ (<0.05 ppm) in/on all samples of apples (RAC), juice, and wet pomace.  Processing factors could not be calculated because residues were below the LOQ in both the RAC and processed commodities.

Conclusions:  These data indicate that significant concentration of sulfentrazone residues are unlikely to occur in the processed fractions of apples; therefore, separate tolerances are not required for apple processed commodities.


860.1650 Submittal of Analytical Reference Standards

Analytical standards for sulfentrazone (expiration date 7/1/15) and its metabolites DMS (expiration date 8/1/17) and HMS (expiration date 8/31/18) are currently available at the EPA National Pesticide Standards Repository (personal communication with Theresa Cole, 4/21/14).  However, as the existing stocks are depleted, the Repository has requested that the registrant provide additional amounts of sulfentrazone (5 g) and HMS (3 g).  They should be sent to the Analytical Chemistry Lab, which is located at Fort Meade, to the attention of either Theresa Cole or Thuy Nygen at the following address:

	USEPA
	National Pesticide Standards Repository/Analytical Chemistry Branch/OPP
	701 Mapes Road
	Fort George G. Meade, MD  20755-5350

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


860.1850/1900 Confined/Field Accumulation in Rotational Crops

As apple trees are not rotated, rotational crop issues are not relevant to the current petition.


860.1550 Proposed Tolerances

The HED Metabolism Committee has determined that the parent compound, sulfentrazone, and the metabolite HMS are the residues of concern in soybeans, and that sulfentrazone and the metabolites HMS and DMS are the residues of concern in rotational crops (D226434, 6/14/96, G. Kramer).  

Sulfentrazone tolerances are currently established under 40 CFR §180.498.  A tolerance is established under 40 CFR §180.498(a)(1) for the combined residues of sulfentrazone and its major metabolite, HMS, in/on soybean seed at 0.05 ppm.  Permanent tolerances are established under 40 CFR §180.498(a)(2) for "combined residues of the free and conjugated forms of sulfentrazone, including its metabolites and degradates, in or on the commodities in the table below.  Compliance with the tolerance levels specified below is to be determined by measuring only the sum of sulfentrazone (N-[2,4-dichloro-5-[4-(difluoromethyl)-4,5-dihydro-3-methyl-5-oxo-1H-1,2,4-triazol-1-yl]phenyl]methanesulfonamide) and its metabolites HMS (N-(2,4-dichloro-5-(4-(difluoromethyl)-4,5-dihydro-3-hydroxymethyl-5-oxo-1H-1,2,4-triazol-1-yl)phenyl)methanesulfonamide) and DMS (N-(2,4-dichloro-5-(4-(difluoromethyl)-4,5-dihydro-5-oxo-1H-1,2,4-triazol-1-yl)phenyl)methanesulfonamide, calculated as the stoichiometric equivalent of sulfentrazone in or on the following commodities." 

No Codex, Canadian, or Mexican MRLs have been established for sulfentrazone on the subject crop.  Therefore, harmonization of MRLs and U.S. tolerances is not an issue at this time.  An International Residue Limits form is appended to this Summary Document.

A tolerance summary for sulfentrazone is presented in Table 6.

Table 6.  Tolerance Summary for Sulfentrazone.
Commodity
                           Proposed Tolerance (ppm)
                        HED-Recommended Tolerance (ppm)
Correct Commodity Definition/Comments
Establish under 40 CFR §180.498(a)(2):
Apple
                                     0.15
                                     0.15



References

DP#:		389972
Subject:	Sulfentrazone.  Section 3 Registration Request to Add New Uses on Rhubarb, Turnips, Sunflower Subgroup 20B, Succulent Cowpea, Lima Bean, Vegetable Soybean, Wheat, Citrus Fruit Crop Group 10-10, Low-Growing Berry Crop Group 13-07, Tree Nut Crop Group 14, Clover, Alfalfa, and Pistachios.  Summary of Analytical Chemistry and Residue Data.
From:		G. Kramer
To:		K. Montague/B. Madden
Dated:		5/9/12
MRID(s):	483973-02 thru -09, 485148-01 thru -03

DP#:		288712
Subject:	Sulfentrazone  -  Briefing Memorandum for Meeting of Metabolism Assessment Review Committee
From:		G. Kramer
To:		Y. Donovan
Dated:		3/6/03
MRID(s):	None

DP#s:		287102, 286879, 287256, 287257
Subject:	PP#s 2F6391, 2E6498, 2E6405 & 2E6500.  Sulfentrazone in/on Dried Shelled Pea and Bean, Field Corn, Succulent Lima Bean, Potatoes and Asparagus.  Summary of Analytical Chemistry and Residue Data.
From:		G. Kramer
To:		D. Morgan/J. Miller
Dated:		1/10/03
MRID(s):	45537402, 45567404, 45739201, 45582201, 45752601, 45567403, 45582201

DP#:		276111
Subject:	PP#1E6311.  Sulfentrazone on Cabbage, Horseradish, and Mint.  Evaluation of Residue Data and Analytical Methods.
From:		G. Kramer
To:		S. Brothers/R. Forrest
Dated:		12/9/02
MRID(s):	45393501 and 45393502

DP#:		233520
Subject:	PP#4F04407.  Sulfentrazone (Authority Herbicide) for Use on Soybeans.  Results of Petition Method Validation (PMV).
From:		G. Kramer
To:		S. Robbins/K. Boyle
Dated:		3/25/97
MRID(s):	44118801 and 44118802

DP#:		226434
Subject:	HED Metabolism Committee of 5/20/96.  Sulfentrazone.  PP#4F04407.
From:		G. Kramer
To:		HED Metabolism Committee Members
Dated:		6/14/96
MRID(s):	None

DP#:		220548
Subject:	PP#4F04407.  Sulfentrazone for Use on Soybeans.  Data Waiver Request.
From:		G. Kramer
To:		J. Miller
Dated:		3/13/96
MRID(s):	None

DP#:		None
Subject:	Multiresidue Method Testing of sulfentrazone and 3-hydroxy methyl sulfentrazone.
From:		G. Kramer
To:		H. Hundley
Dated:		2/7/95
MRID(s):	43345416


Attachments:  
Appendix I - International Residue Limit Sheet.
































DOCUMENT TRACKING

RDI:  RAB1 Chemistry Team:  04/23/2014
Petition #:  3E8202
DP#s:  415626
PC Code:  129081

Template Version September 2005
Appendix I.  International Tolerances

International Residue Limits 
 
                       Sulfentrazone (129081; 4/15/2014)
Summary of US and International Tolerances and Maximum Residue Limits 
Residue Definition:
U.S.
Canada
Mexico[2]
Codex
40 CFR 180.498:
(2) sum of sulfentrazone (N-[2,4-dichloro-5-[4-(difluoromethyl)-4,5-dihydro-3-methyl-5-oxo-1H-1,2,4-triazol-1-yl]phenyl]methanesulfonamide) and its metabolites HMS (N-(2,4-dichloro-5-(4-(difluoromethyl)-4,5-dihydro-3-hydroxymethyl-5-oxo-1H-1,2,4-triazol-1-yl)phenyl)methanesulfonamide) and DMS (N-(2,4-dichloro-5-(4-(difluoromethyl)-4,5-dihydro-5-oxo-1H-1,2,4-triazol-1-yl)phenyl)methanesulfonamide, calculated as the stoichiometric equivalent of sulfentrazone 
Plants (except dry soybeans):  N-[2,4-dichloro-5-[4-(difluoromethyl)-4,5-dihydro-3-methyl-5-oxo-1H-1,2,4-triazol-1-yl]-phenyl]methanesulfonamide, including the metabolites N-[2,4-dichloro-5-[4-(difluoromethyl)-4,5-dihydro-3-hydroxymethyl-5-oxo-1H-1,2,4-triazol-1-yl]phenyl]methanesulfonamide and N-[2,4-dichloro-5-4-(difluoromethyl)-4,5-dihydro-5-oxo-1H-1,2,4-triazol-1-yl]phenyl]methanesulfonamide

                                       
None
Commodity[1]
Tolerance (ppm) /Maximum Residue Limit (mg/kg)

U.S.
Canada
Mexico[2]
Codex
Apple
0.15









































































Completed: M. Negussie; 04/16/2014
[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 U.S. tolerances and/or Codex MRLs for its export purposes.


