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

Date:	July 01, 2014 

SUBJECT:	2,6-Dichlorobenzamide (BAM).  An Assessment of BAM Dietary Exposure Based on Current Percent Crop Treated Data to Support Increased Fluopicolide Tolerances.   

            
PC Code:  027402 (BAM), 027412 (Fluopicolide), 027401 (Dichlobenil)
DP Barcode:  D421238
Decision No.:  481091
Registration No.:  59639-139
Petition No.: 3F8191
Regulatory Action: Section 3 
Risk Assessment Type: Not Applicable
Case No.: Not Applicable
TXR No.: Not Applicable
CAS No.: 2008-54-4
MRID No.: None
40 CFR: §180.627


FROM:	Peter Savoia, Chemist
		Risk Assessment Branch V/VII
		Health Effects Division (7509P)
				
THRU:	Michael S. Metzger, Branch Chief
		Risk Assessment Branch V/VII
		Health Effects Division (7509P)
		
TO:	Laura Nollen, Biologist
	Minor Use Team
		and
	Tony Kish, Product Manager 
	Fungicide Branch
	Registration Division (7505P)
	

2,6-dichlorobenzamide or "BAM", is a metabolite of two pesticide active ingredients, fluopicolide and dichlobenil.  Residues of BAM are considered to be of regulatory concern having separate toxicity data and endpoints selected for risk assessment.  Recently, the Valent U.S.A. Corporation submitted PP# 3F8191 to amend the fluopicolide tolerances established on tuberous and corm subgroup 1C vegetables and potato processed waste.  Because these increased tolerances do not add to the dietary exposure of BAM, the conclusions from the most recently conducted 2008 BAM human health risk assessment remain unchanged (D354111, D. Rate, 06/19/08).  Although it remains applicable in supporting this action, the dichlobenil percent crop treated estimates for some commodities underlying the BAM assessment generated in 2007 were found to have increased.  Other than the new estimate for pears, the percent crop treated estimates did not change or were negligible since they are all at the lower reporting limit and will not affect the overall BAM dietary exposure.  For pears, dietary analyses were thus performed to compare its contribution to exposure since the new percent crop treated estimate is appreciably higher (5% for the avg.).  In comparison, these results show that the impact from pears is negligible in contributing to the dietary exposure of BAM.  Therefore, the conclusions of the 2008 BAM human health risk assessment remain applicable to support the increased fluopicolide tolerances on tuberous and corm vegetables.    
