UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES July 21st, 2004 MEMORANDUM:

SUBJECT: Revised Reregistration Eligibility Decision Document ( RED) of Pentachloronitrobenzene ( PCNB, PC Code 056502): Product and Residue Chemistry Considerations. Reregistration Case 0128. DP Barcode. D305653. MRID No. None.

FROM: Mohsen Sahafeyan, Residue Chemist Kenneth W. Dockter, Product Chemist Reregistration Branch 2 Health Effects Division ( 7509C)

THROUGH: Alan Nielsen, Branch Senior Scientist Reregistration Branch 2 Health Effects Division ( 7509C)

TO: Jill Bloom, CRM Reregistration Branch 2 Special Review and Reregistration Division ( 7508C)

Attached are the product chemistry and residue chemistry considerations for the tolerance reassessment of the fungicide, pentachloronitrobenzene ( PCNB). The chapters were assembled by Dynamac Corporation under supervision of HED. The data assessment has undergone secondary review in the branch and has been revised to reflect branch policies.

EXECUTIVE SUMMARY:

Several product chemistry data requirements remain outstanding.

All labels should restrict use on collards, kale, mustard greens to the state of GA.

All the current tolerance expressions which include PCNB per se should be changed to include PCNB, PCA, and PCTA.

Tolerances listed under § 180.319 should be reassigned to § 180.291( a) as timelimited or permanent tolerances.

All labels must specify that the treated crops can only be rotated to the registered crops.

Field accumulation in rotational crop studies on registered crops are required.

Additional residue data are required for cotton gin byproducts, seed treated crops, soybean ( forage, hay, seeds), wheat( forage, hay, straw, grain), peppers, tomatoes, peanuts, potatoes, garlic, beans, cottonseed and broccoli.

Development of a radiolabeled common moiety method for plants and animal commodities is recommended.

An enforcement method for animal commodities is required.

New / additional data on plant and animal metabolism studies are required.

Tolerances on livestock commodities must be established.

Residue data for ginseng should be generated in the representative countries and tolerance should be proposed.

Analytical reference standards for PCNB, and metabolites must be supplied as requested by the EPA National Pesticide Standards Repository.

cc : Chem F, M. Sahafeyan, K. Dockter, D. Locke RDI: ChemSAC: 5/ 5/ 04; A. Nielsen : 5/ 13/ 04 M. Sahafeyan, Rm. 712D CM2, 305 6872, mail code 7509C K. Dockter, Rm. 712G, CM2, 305 7886, mail code 7509C 2 Cl Cl Cl Cl Cl NO 2 PENTACHLORONITROBENZENE ( PCNB)

REREGISTRATION ELIGIBILITY DECISION:

PRODUCT CHEMISTRY CONSIDERATIONS PC Code 056502; Case No. 0128 DP Barcode D266923 DESCRIPTION OF CHEMICAL PCNB [ pentachloronitrobenzene] is a soil fungicide registered for use on beans, Brassica vegetables, cotton, garlic, peppers, peanuts, potatoes and tomatoes.

Empirical Formula: C 6 Cl 5 NO 2 Molecular Weight: 295.3 CAS Registry No.: 82 68 8 PC Code: 056502 IDENTIFICATION OF ACTIVE INGREDIENT PCNB is a white to off white crystalline solid with a melting point of 141 146 C, density of 1.72 g/ cc, octanol/ water partition coefficient ( log P ow) of 5.0, and vapor pressure of 5 x 10 5 mm Hg at 20 C. PCNB is practically insoluble in water ( 0.44 mg/ L at 20 C), and is soluble in ethanol ( 2 g/ 100 mL), dichloroethane ( 20% w/ w), and toluene ( 50% w/ w). PCNB is generally soluble in carbon disulfide, benzene, chloroform, ketones, and aromatic and chlorinated hydrocarbons.

MANUFACTURING USE PRODUCTS According to a search of the Reference Files System ( REFS) conducted 2/ 8/ 01, there are seven manufacturing use products ( MPs) registered under PC Code 056502; these are presented in Table 1. [ Note, these products were confirmed to still be active as of 8/ 23/ 02. No new actions are pending; personal communication M. Waller 8/ 23/ 02] The seven registered PCNB MPs are 4 subject to a reregistration eligibility decision.

Table 1. Registered PCNB manufacturing use products.

Formulation EPA Reg. No. Registrant 99.7% T 400 401 Uniroyal Chemical Company, Inc. 96.2% T 400 504 1 99.4% T 400 459 2 90% FI 400 414 96.2% T 5481 197 Amvac Chemical Corporation 80% FI 5481 438 80% FI 7501 45 Gustafson, Inc.

1 Repackaged from an EPA registered product; registered 9/ 00. 2 Transferred from Quimica Organica de Mexico ( EPA Reg. No. 10820 1) on 8/ 12/ 94.

REGULATORY BACKGROUND The PCNB Reregistration Standard was issued 6/ 30/ 86 and required additional product chemistry data concerning PCNB. The PCNB Guidance Document dated 1/ 87 required that all new product chemistry data be submitted for the reregistration of PCNB because new requirements had been introduced and previously submitted data needed to be updated. Data submitted in response to the Guidance Document for the MPs were evaluated in Agency reviews and in the PCNB Reregistration Standard Update dated 6/ 19/ 90 with regard to adequacy in fulfilling product chemistry requirements. The PCNB Update summarized the available product chemistry database and required additional data for the Uniroyal, Amvac, and Gustafson PCNB MPs.

Additional data were required for PCNB concerning potential impurities of concern, including chlorinated dibenzofurans/ dibenzodioxins and hexachlorobenzene ( HCB). The available dioxin data indicate that dioxins are not expected to form in technical PCNB at levels at or above the EPA specified Limits of Quantitation [ LOQs]. In conjunction with an Rebuttable Presumption Against Registration [ RPAR] Termination Notice dated 3/ 23/ 82, the Guidance Document required that the registrants submit annual progress reports summarizing efforts to implement measures to reduce levels of HCB in the TGAI to < 0.1%. Subsequent to the Guidance Document, the manufacturing processes for the technical PCNB products were refined to maintain HCB levels at less than 0.1%; quality control measures were also initiated to monitor HCB levels.

The current status of the product chemistry data requirements for the PCNB MPs is presented in the attached data summary tables. Refer to these tables for a listing of the outstanding product chemistry data requirements. 5 CONCLUSIONS Most pertinent product chemistry data requirements have been satisfied for the Uniroyal 99.7% and Amvac 95% T/ TGAIs. Additional data are required concerning UV/ visible absorption ( OPPTS 830.7050) for both technical products, and additional data are required for the Amvac 95% T only concerning preliminary analysis ( OPPTS 830.1700). The Uniroyal 96.2% T ( EPA Reg. No. 400 504) is repackaged from an EPA registered product; therefore, all product chemistry data requirements for this product will be satisfied by data for the source product. Additional data are required for the Uniroyal 96% T concerning description of the production process, oxidation/ reduction, explodability, storage stability, corrosion characteristics, and UV/ visible absorption ( OPPTS 830.1620, 6314, 6316, 6317, 6320, and 7050). TGAI data requirements for the Uniroyal, Amvac, and Gustafson FIs will be fulfilled by data for the technical source products; however, the following product specific data are required: ( i) for the Uniroyal 90% FI, all product specific data are outstanding except for description of materials used to produce the product and the formulation process and discussion of formation of impurities ( OPPTS 830.1600, 1650, and 1670); ( ii) for the Amvac 80% FI, data concerning certified limits, color, physical state, odor, and storage stability ( OPPTS 830.6302, 6303, 6304, and 6317); and ( iii) for the Gustafson 80% FI, data concerning enforcement methods, color, physical state, odor, oxidation/ reduction, explodability, storage stability, corrosion characteristics, pH, and density ( OPPTS 830.1800, 6302, 6303, 6304, 6314, 6316, 6317, 6320, 7000, and 7300). Provided that the registrants submit the data required in the attached data summary tables for the PCNB T/ TGAIs, and either certify that the suppliers of beginning materials and the manufacturing processes have not changed since the last comprehensive product chemistry reviews or submit complete updated product chemistry data packages, the Agency has no objections to the reregistration of PCNB with respect to product chemistry data requirements. 6 Case No. 0128 PC Code 056502 Case Name: PCNB Registrant: Uniroyal Chemical Company, Inc. Product( s): 99.7% T ( EPA Reg. No. 400 401)

PRODUCT CHEMISTRY DATA SUMMARY Guideline Number Requirement Are Data Requirements Fulfilled? 1 MRID Number 2 830.1550 Product identity and composition Y CSF 4/ 19/ 88, 41355401 3, 42890401 4, CSF 12/ 22/ 94 5 830.1600 Description of materials used to produce the product Y 41355401 3, 42890401 4 830.1620 Description of production process Y 41355401 3, 42890401 4 830.1670 Discussion of formation of impurities Y 41355401 3 830.1700 Preliminary analysis Y 41355402 3, 42890401 4 830.1750 Certified limits Y CSF 4/ 19/ 88, 41355402 3, 42890402 4, CSF 12/ 22/ 94 5 830.1800 Enforcement analytical method Y 40506101, 41355402 3, 42890403 4 830.6302 Color Y 41355403 3 830.6303 Physical state Y 41355403 3 830.6304 Odor Y 41355403 3 830.6313 Stability to normal and elevated temperatures, metals, and metal ions Y 41355403 3 830.6314 Oxidation/ reduction: chemical incompatibility Y 41355403 3 830.6315 Flammability N/ A 6 41355403 3 830.6316 Explodability Y 41355403 3 830.6317 Storage stability Y 41355403 3 830.6319 Miscibility N/ A 6 830.6320 Corrosion characteristics Y 41355403 3 830.7000 pH Y 41355403 3 830.7050 UV/ Visible absorption N 7 830.7100 Viscosity N/ A 6 830.7200 Melting point/ melting range Y 41355403 3 830.7220 Boiling point/ boiling range N/ A 6 830.7300 Density/ relative density/ bulk density Y 41355403 3, 42890404 4 830.7370 Dissociation constants in water N/ A 8 41355403 3 830.7550 Partition coefficient ( n octanol/ water), shake flask method Y 41355403 3, 42890404 4, 40609603 4, 9 830.7840 Water solubility: column elution method; shake flask method Y 41355403 3, 42890404 4 830.7950 Vapor pressure Y 41355403 3, 42890404 4 1 Y = Yes; N = No; N/ A = Not Applicable. We note that the data cited above were initially submitted in support of an alternate formulation source; based on the current CSF, this source is now the basic and only source product for the 99.7% T.

2 Bolded references were reviewed in the PCNB Reregistration Standard Update dated 6/ 19/ 90; and all other references were reviewed as noted. 7 3 DEB No. 6290, 2/ 15/ 90, S. Funk. We note that although Amvac was identified as the registrant in the review document, the data reviewed pertain to the Uniroyal registration.

4 RD Memorandum D194583, 9/ 16/ 93, A. Smith.

5 RD Memorandum D239579, 10/ 27/ 97, A. Smith reviewed the label claim in connection with the CSF; the CSF dated 12/ 22/ 94 was obtained from the product jacket.

6 Data are not required because the TGAI/ MP is a solid at room temperature.

7 The OPPTS Series 830, Product Properties Test Guidelines require data pertaining to UV/ visible absorption for the PAI.

8 Data are not required because PCNB does not dissociate in water.

9 RCB No. 3880, 8/ 19/ 88, N. Gray. 8 Case No. 0128 PC Code 056502 Case Name: PCNB Registrant: Uniroyal Chemical Company, Inc. Product( s): 96.2% T ( EPA Reg. No. 400 504)

PRODUCT CHEMISTRY DATA SUMMARY Guideline Number Requirement Are Data Requirements Fulfilled? 1 MRID Number 2 830.1550 Product identity and composition Y 3 CSF 7/ 20/ 00 830.1600 Description of materials used to produce the product N/ A 830.1620 Description of production process N/ A 830.1670 Discussion of formation of impurities N/ A 830.1700 Preliminary analysis N/ A 830.1750 Certified limits Y 3 CSF 7/ 20/ 00 830.1800 Enforcement analytical method N/ A 830.6302 Color N/ A 830.6303 Physical state N/ A 830.6304 Odor N/ A 830.6313 Stability to normal and elevated temperatures, metals, and metal ions N/ A 830.6314 Oxidation/ reduction: chemical incompatibility N/ A 830.6315 Flammability N/ A 830.6316 Explodability N/ A 830.6317 Storage stability N/ A 830.6319 Miscibility N/ A 830.6320 Corrosion characteristics N/ A 830.7000 pH N/ A 830.7050 UV/ Visible absorption N/ A 830.7100 Viscosity N/ A 830.7200 Melting point/ melting range N/ A 830.7220 Boiling point/ boiling range N/ A 830.7300 Density/ relative density/ bulk density N/ A 830.7370 Dissociation constants in water N/ A 830.7550 Partition coefficient ( n octanol/ water), shake flask method N/ A 830.7840 Water solubility: column elution method; shake flask method N/ A 830.7950 Vapor pressure N/ A 1 Y = Yes; N = No; N/ A = Not Applicable. The 96.2% T is repackaged from an EPA registered product; therefore, all product chemistry data requirements will be fulfilled by data for the source product.

2 The CSF was obtained from the product jacket.

3 We note that, although the product is 100% repackaged from an EPA registered product, the nominal concentration and certified limits on the CSF should reflect the actual levels of the ai in the product. 9 Case No. 0128 PC Code 056502 Case Name: PCNB Registrant: Uniroyal Chemical Company, Inc. Product( s): 99.4% T ( EPA Reg. No. 400 459)

PRODUCT CHEMISTRY DATA SUMMARY Guideline Number Requirement Are Data Requirements Fulfilled? 1 MRID Number 2 830.1550 Product identity and composition Y 3 40609601, 40609602 830.1600 Description of materials used to produce the product Y 40609601, 40609602 830.1620 Description of production process N 4 40609601, 40609602 830.1670 Discussion of formation of impurities Y 40609601, 40609602 830.1700 Preliminary analysis Y 40609601, 40609602 830.1750 Certified limits Y 3 40609601, 40609602 830.1800 Enforcement analytical method Y 40609602 830.6302 Color Y 40609603 830.6303 Physical state Y 40609603 830.6304 Odor Y 40609603 830.6313 Stability to normal and elevated temperatures, metals, and metal ions Y 40609603 830.6314 Oxidation/ reduction: chemical incompatability N 830.6315 Flammability N/ A 5 830.6316 Explodability N 830.6317 Storage stability N 830.6319 Miscibility N/ A 5 830.6320 Corrosion characteristics N 830.7000 pH Y 40609603 830.7050 UV/ Visible absorption N 6 830.7100 Viscosity N/ A 5 830.7200 Melting point/ melting range Y 40609603 830.7220 Boiling point/ boiling range N/ A 5 830.7300 Density/ relative density/ bulk density Y 40609603 830.7370 Dissociation constants in water N/ A 7 40609603 830.7550 Partition coefficient ( n octanol/ water), shake flask method Y 40609603 830.7840 Water solubility: column elution method; shake flask method Y 40609603 830.7950 Vapor pressure Y 40609603 1 Y = Yes; N = No; N/ A = Not Applicable. The Uniroyal 96% T was transferred from Quimica Organica de Mexico ( EPA Reg. No. 10820 1; 8/ 12/ 94), and the data cited above are based on data submitted by Quimica. The registrant must confirm that the manufacturing site and process have not changed since the product transfer; otherwise additional product chemistry data will be required.

2 All references were reviewed under RCB No. 3880, 8/ 19/ 88, N. Gray.

3 The current CSF dated 5/ 29/ 88 must be revised to reflect the product transfer, including the current registrant, registration number, and production site. In addition, we note that the label claim must be revised as required 10 under PR Notice 91 2 to reflect the nominal concentration of the active ingredient in the product ( 99.4%).

4 Because a purer TGAI is being produced which contains

0.1% HCB, an explanation is required regarding any changes that have been made in the manufacturing process for crude PCNB since the original submissions ( 1983 and 1985).

5 Data are not required because the TGAI/ MP is a solid at room temperature.

6 The OPPTS Series 830, Product Properties Test Guidelines require data pertaining to UV/ visible absorption for the PAI.

7 Data are not required because PCNB does not dissociate in water. 11 Case No. 0128 PC Code 056502 Case Name: PCNB Registrant: Uniroyal Chemical Company, Inc. Product( s): 90% FI ( EPA Reg. No. 400 414)

PRODUCT CHEMISTRY DATA SUMMARY Guideline Number Requirement Are Data Requirements Fulfilled? 1 MRID Number 2 830.1550 Product identity and composition N 3 40287901, 40506101, CSF 11/ 29/ 89 4 830.1600 Description of materials used to produce the product Y 40287901 830.1650 Description of formulation process Y 40287901 830.1670 Discussion of formation of impurities Y 40287901 830.1700 Preliminary analysis N/ A 5 40506101 830.1750 Certified limits N 3 40506101, CSF 11/ 29/ 89 4 830.1800 Enforcement analytical method N 6 40506101 830.6302 Color N 830.6303 Physical state N 830.6304 Odor N 830.6313 Stability to normal and elevated temperatures, metals, and metal ions N/ A 5 830.6314 Oxidation/ reduction: chemical incompatibility N 830.6315 Flammability N 830.6316 Explodability N 830.6317 Storage stability N 830.6319 Miscibility N 830.6320 Corrosion characteristics N 830.7000 pH N 830.7050 UV/ Visible absorption N/ A 5 830.7100 Viscosity N 830.7200 Melting point/ melting range N/ A 5 830.7220 Boiling point/ boiling range N/ A 5 830.7300 Density/ relative density/ bulk density N 830.7370 Dissociation constants in water N/ A 5 830.7550 Partition coefficient ( n octanol/ water), shake flask method N/ A 5 830.7840 Water solubility: column elution method; shake flask method N/ A 5 830.7950 Vapor pressure N/ A 5 1 Y = Yes; N = No; N/ A = Not Applicable. The 90% FI is manufactured from EPA registered products.

2 Bolded references were reviewed in the PCNB Reregistration Standard Update dated 6/ 19/ 90; and all other references were reviewed as noted.

3 The CSF must be revised to indicate that the product contains HCB at 0.05% or less. In addition the technical sources listed on the CSF must be amended because one of the products has been transferred. 12 4 RD Letter dated 7/ 27/ 00, from M. Waller, RD, to B. Katzman.

5 TGAI data requirements will be fulfilled by data for the technical source products.

6 Supporting validation data generated using the 90% FI are required for the enforcement methods. 13 Case No. 0128 PC Code 056502 Case Name: PCNB Registrant: Amvac Chemical Corporation Product( s): 96.2% T ( EPA Reg. No. 5481 197)

PRODUCT CHEMISTRY DATA SUMMARY Guideline Number Requirement Are Data Requirements Fulfilled? 1 MRID Number 2 830.1550 Product identity and composition Y 3 40668601, 40668602 4, CSF 2/ 12/ 98 5 830.1600 Description of materials used to produce the product Y 40668601 830.1620 Description of production process Y 40668601 830.1670 Discussion of formation of impurities Y 40668601 830.1700 Preliminary analysis N 6 40668602 4 830.1750 Certified limits Y 40668602 4, CSF 2/ 12/ 98 5 830.1800 Enforcement analytical method Y 40668602 4 830.6302 Color Y 40668602, 41795702 4 830.6303 Physical state Y 40668602, 41795702 4 830.6304 Odor Y 40668602, 41795702 4 830.6313 Stability to normal and elevated temperatures, metals, and metal ions Y 40668602, 41795702 4 830.6314 Oxidation/ reduction: chemical incompatibility N 830.6315 Flammability N/ A7 830.6316 Explodability N 830.6317 Storage stability N 830.6319 Miscibility N/ A 7 830.6320 Corrosion characteristics N 830.7000 pH Y 40668602, 41795702 4 830.7050 UV/ Visible absorption N 8 830.7100 Viscosity N/ A7 830.7200 Melting point/ melting range Y 40668602, 41795702 4 830.7220 Boiling point/ boiling range N/ A 7 830.7300 Density/ relative density/ bulk density Y 40668602, 41795702 4 830.7370 Dissociation constants in water N/ A 9 40668602, 41795702 4 830.7550 Partition coefficient ( n octanol/ water), shake flask method Y 40668602, 41795702 4 830.7840 Water solubility: column elution method; shake flask method Y 40668602, 41795702 4 830.7950 Vapor pressure Y 40668602, 41795702 4 1 Y = Yes; N = No; N/ A = Not Applicable.

2 Bolded references were reviewed in the PCNB Reregistration Standard Update dated 6/ 19/ 90; and all other references were reviewed as noted.

3 The label claim reflects the lower certified limit. As required under PR Notice 91 2, the registrant must revise the label claim to reflect the nominal concentration of 96.2%. 14 4 RD Memorandum, 8/ 21/ 91, H. Roldan. We note that this memorandum reviewed MRID 40668602, which was previously reviewed in the Update, and reviewed MRID 41795702 for physical/ chemical characteristics.

5 RD Memorandum D252703, 1/ 11/ 99, S. Mathur.

6 Additional data are required reflecting analysis of five current batches of the PCNB TGAI to confirm the levels of two impurities in current production lots.

7 Data are not required because the T/ TGAI is a solid at room temperature.

8 The OPPTS Series 830, Product Properties Test Guidelines require data pertaining to UV/ visible absorption for the PAI.

9 Data are not required because PCNB does not dissociate in water. 15 Case No. 0128 PC Code 056502 Case Name: PCNB Registrant: Amvac Chemical Corporation Product( s): 80% FI ( EPA Reg. No. 5481 438)

PRODUCT CHEMISTRY DATA SUMMARY Guideline Number Requirement Are Data Requirements Fulfilled? 1 MRID Number 2 830.1550 Product identity and composition Y 42232401, CSF 1/ 10/ 92 830.1600 Description of materials used to produce the product Y 42232401 830.1650 Description of formulation process Y 42232401 830.1670 Discussion of formation of impurities Y 42232401 830.1700 Preliminary analysis N/ A 3 830.1750 Certified limits N 4 42232401, CSF 1/ 10/ 92 830.1800 Enforcement analytical method Y 42232401 830.6302 Color N 5 42232401 830.6303 Physical state N 5 42232401 830.6304 Odor N 5 42232401 830.6313 Stability to normal and elevated temperatures, metals, and metal ions N 830.6314 Oxidation/ reduction: chemical incompatibility Y 42232401 830.6315 Flammability N/ A 6 830.6316 Explodability Y 42232401 830.6317 Storage stability N 5 42232401 830.6319 Miscibility N/ A 6 830.6320 Corrosion characteristics Y 42232401 830.7000 pH Y 42232401 830.7050 UV/ Visible absorption N/ A 3 830.7100 Viscosity N/ A 6 830.7200 Melting point/ melting range N/ A 3 830.7220 Boiling point/ boiling range N/ A 3 830.7300 Density/ relative density/ bulk density N 5 42232401 830.7370 Dissociation constants in water N/ A 3 830.7550 Partition coefficient ( n octanol/ water), shake flask method N/ A 3 830.7840 Water solubility: column elution method; shake flask method N/ A 3 830.7950 Vapor pressure N/ A 3 1 Y = Yes; N = No; N/ A = Not Applicable. The 80% FI is manufactured from an EPA registered product.

2 All references were reviewed under RD Memorandum D1782827, dated 6/ 12/ 92, A. Smith.

3 TGAI data requirements will be fulfilled by data for the technical source product.

4 Lower certified limits must be proposed for the inert ingredients. 16 5 Data referenced by the registrant were for the technical source product and do not apply to product specific requirements for the FI.

6 Data are not required because the MP is a solid at room temperature. 17 Case No. 0128 PC Code 056502 Case Name: PCNB Registrant: Gustafson, Inc. Product( s): 80% FI ( EPA Reg. No. 7501 45)

PRODUCT CHEMISTRY DATA SUMMARY Guideline Number Requirement Are Data Requirements Fulfilled? 1 MRID Number 2 830.1550 Product identity and composition Y 42624201, Letter 9/ 14/ 93 3, CSF 6/ 23/ 97 4 830.1600 Description of materials used to produce the product Y 42624201, Letter 9/ 14/ 93 3 830.1650 Description of formulation process Y 42624201, Letter 9/ 14/ 93 3 830.1670 Discussion of formation of impurities Y 42624201 830.1700 Preliminary analysis N/ A 5 830.1750 Certified limits Y 42624201, CSF 6/ 23/ 97 4 830.1800 Enforcement analytical method N 6 42624201, Letter 9/ 14/ 93 3 830.6302 Color N 830.6303 Physical state N 830.6304 Odor N 830.6313 Stability to normal and elevated temperatures, metals, and metal ions N/ A 5 830.6314 Oxidation/ reduction: chemical incompatibility N 830.6315 Flammability N/ A 7 830.6316 Explodability N 830.6317 Storage stability N 830.6319 Miscibility N/ A 7 830.6320 Corrosion characteristics N 830.7000 pH N 830.7050 UV/ Visible absorption N/ A 5 830.7100 Viscosity N/ A 7 830.7200 Melting point/ melting range N/ A 5 830.7220 Boiling point/ boiling range N/ A 5 830.7300 Density/ relative density/ bulk density N 830.7370 Dissociation constants in water N/ A 5 830.7550 Partition coefficient ( n octanol/ water), shake flask method N/ A 5 830.7840 Water solubility: column elution method; shake flask method N/ A 5 830.7950 Vapor pressure N/ A 5 1 Y = Yes; N = No; N/ A = Not Applicable. The 80% FI is manufactured from an EPA registered product.

2 All references were reviewed under D187966, 4/ 23/ 93, D. McNeilly, unless otherwise noted.

3 D195328, 12/ 13/ 93, F. Toghrol.

4 RD Memorandum D237246, 9/ 17/ 97, H. Podall. 18 5 TGAI data requirements will be fulfilled by data for the technical source product.

6 Additional validation data are required.

7 Data are not required because the MP is a solid at room temperature. 19 AGENCY MEMORANDA CITED IN THIS DOCUMENT CBRS No( s).: 3880 Subject: Product Chemistry Data Submission on PCNB. From: N. Gray To: L. Rossi/ H. Toma Dated: 8/ 19/ 88 MRID( s): 40609601 40609603 DEB No( s).: 6290 Subject: Product Chemistry Data Submission on PCNB for Registration Request. ID No. 5481 URT. Record No. 258324. From: S. Funk To: S. Lewis Dated: 2/ 15/ 90 MRID( s): 41355401 41355403 DP Barcode: RD Memorandum Subject: Product Chemistry Review on Technical Grade PCNB 96.2% EPA Reg. No. 5481 197. From: H. Roldan To: S. Lewis Dated: 8/ 28/ 91 MRID( s): 40668602 and 41795702 DP Barcode: RD MemorandumD178272 Subject: Product Chemistry Review; EPA Reg. No.: 5481 UGI; Product Name: 80% PCNB Manufacturing Concentrate. From: A. Smith To: PM 25 Dated: 6/ 12/ 92 MRID( s): 42232401 CBRS No( s).: 11340 DP Barcode: D187966 Subject: Pentachloronitrobenzene ( PCNB): Product Chemistry Data { Case 818950}. From: D. McNeilly To: S. Cerrelli Dated: 4/ 23/ 93 MRID( s): 42624201 20 DP Barcode: RD Memorandum D194583 Subject: Product Chemistry Review of Pentachloronitrobenzene Technical ( EPA Reg. No. 400 401). From: A. Smith To: E. Allen Dated: 9/ 16/ 93 MRID( s): 42890401 42890404 CBRS No( s).: 12606 DP Barcode: D195328 Subject: Pentachloronitrobenzene ( PCNB) Reregistration: List A Chemical No. 056502. Case No. 0128. Gustafson Response ( Letter dated 9/ 14/ 93) to Product Chemistry Data Requirements ( GLN 61 1, 61 2, and 62 3) for PCNB 80% FI ( EPA Reg. No. 7501 45) From: F. Toghrol To: L. Rossi/ L. Propst Dated: 12/ 13/ 93 MRID( s): None DP Barcode: RD Memorandum D237246 Subject: Product Chemistry Review of MP; EPA Reg./ File Symbol No.: 7501 45; Product Name: Gustafson Terraclor 80% Dust Concentrate; Company: Gustafson, Inc. From: H. Podall To: C. Welch/ T. Stowe Dated: 9/ 17/ 97 MRID( s): None DP Barcode: RD Memorandum D239579 Subject: Product Chemistry Review; EPA Reg./ File Symbol No.: 400 401; Product Name: Terraclor Technical; Company: Uniroyal Chemical Co., Inc. From: A. Smith To: S. Gardner Jenkins Dated: 10/ 27/ 97 MRID( s): None 21 DP Barcode: RD Memorandum D252703 Subject: Product Chemistry Review of TGAI; EPA Reg./ File Symbol No.: 5481 197; Product Name: Technical Grade PCNB 96.2%; Company: Amvac Chemical Corporation From: S. Mathur To: M. Waller Dated: 1/ 11/ 99 MRID( s): None DP Barcode: RD Letter Subject: Terraclor 90% Concentrate; EPA Reg. No. 400 414; Your Letter Dated February 24, 2000. From: M. Waller To: B. Katzman, Uniroyal Chemical Company Dated: 7/ 27/ 00 MRID( s): None PRODUCT CHEMISTRY CITATIONS Bibliographic citations include only MRIDs containing data which fulfill data requirements.

References ( cited):

40287901 Drozdick, M. ( 1987) Product Specific Data for Terraclor 90% Dust Concentrate, Part 1. Unpublished compilation prepared by Uniroyal Chemical Co., Inc. 16 p.

40506101 Drozdick, M. ( 1988) Preliminary Analysis, Certification Statement and Analytical Method for Terraclor 90% Dust Concentrate: Laboratory Project ID: MDD071687 1 thru 5. Unpublished compilation prepared by Uniroyal Chemical Co., Inc. 10 p.

40609601 Carrilo, F.; Mertz, J. ( 1988) Terrazan PCNB Technical 99%: Product Chemistry Data Product Identity and Composition. Unpublished compilation prepared by Quimica Organica de Mexico, S. A. de C. V. in cooperation with Uniroyal Chemical Co., Inc. 9 p.

40609602 Carrilo, F.; Blaszczynski, E. ( 1988) Terrazan PCNB Technical 99%: Product Chemistry Data Analysis and Certification of Product Ingredients: Project No. 8825. Unpublished compilation prepared by Quimica Organica de Mexico, S. A. de C. V. in cooperation with Uniroyal Chemical Co., Inc. 22 p.

40609603 Carrilo, F.; Batorewicz, W.; Woolson, E. ( 1988) Terrazan PCNB Technical 99%: Product Chemistry Data  A Compilation of Physical and Chemical Characteristics: Project No. 8817. Unpublished study prepared by Quimica Organica de Mexico, S. A. de C. V., and Uniroyal Chemical Co., Inc. in cooperation with EPL Bio Analytical Services, Inc. 17 p. 22 40668601 Feiler, W. ( 1988) PCNB: Product Identity and Composition. Unpublished compilation prepared by Amvac Chemical Corp. 42 p 40668602 Feiler, W. ( 1988) PCNB: Analysis and Certification of Product Ingredients. Unpublished study prepared by Amvac Chemical Corp. 23 p.

41355401 Yoshioka, T. ( 1989) PCNB: Product Identity and Composition. Unpublished study prepared by Mitsui Toatsu Chemicals, Inc. 14 p.

41355402 Yoshioka, T. ( 1989) PCNB: Analysis and Certification of Product Ingredients. Unpublished study prepared by Mitsui Toatsu Chemicals, Inc. 21 p.

41355403 Yoshioka, T. ( 1989) PCNB: Physical and Chemical Characteristics. Unpublished study prepared by Mitsui Toatsu Chemicals, Inc. 5 p.

41795701 Feiler, W. ( 1991) PCNB: Product Identity And Composition. Unpublished study prepared by Amvac Chemical Corp. 10 p.

41795702 Feiler, W. ( 1991) PCNB: Physical And Chemical Characteristics: Unpublished study prepared by Amvac Chemical Co. 76 p.

41838101 Braden, G.; Feiler, W. ( 1991) PCNB: Analysis and Certification of Product Ingredients. Unpublished study prepared by Amvac Chemical Corp. 25 p.

42232401 McClane, H. ( 1991) Product Specific Data: 80 Percent PCNB Manufacturing Concentrate: Lab Project Number: D: EPA/ AMVAC/ 54PCNB80. Unpublished study prepared by AmVac Chemical Corp. 6 p.

42293601 Feiler, W. ( 1992) PCNB: Product Identity and Composition; PCNB: Physical and Chemical Characteristics: Supplement to.... Unpublished study prepared by AMVAC Chemical Corp. 16 p.

42624201 Rockwell, J. ( 1991) Product Chemistry Information; Terracolor 80% Dust Concentrate. Unpublished study prepared by Gustafson Inc. and Uniroyal Chemical Corp. 10 p.

42890401 Stewart, R. ( 1993) PCNB: Product Identity and Composition: Supplement to MRID 41355401. Unpublished study prepared by Mitsui Toatsu Chemicals, Inc., c/ o Technology Sciences Group, Inc. 92 p.

42890402 Stewart, R. ( 1993) PCNB: Analysis and Certification of Product Ingredients: Supplement to MRID 41355402. Unpublished study prepared by Mitsui Toatsu Chemicals, Inc., c/ o Technology Sciences Group Inc. 13 p. 23 42890403 Stewart, R. ( 1993) PCNB: Analytical Method for Enforcement of Limits: Supplement to MRID 41355402. Unpublished study prepared by Mitsui Toatsu Chemicals, Inc. 23 p.

42890404 Stewart, R. ( 1993) PCNB: Physical and Chemical Characteristics: Supplement to 41355403. Unpublished study prepared by Mitsui Toatsu Chemicals, Inc., c/ o Technology Sciences Group Inc. 5 p. 24 PENTACHLORONITROBENZENE REREGISTRATION ELIGIBILITY DECISION RESIDUE CHEMISTRY CONSIDERATIONS PC Code 056502; Case 0128 DP Barcode D266923 TABLE OF CONTENTS page INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 REGULATORY BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 SUMMARY OF SCIENCE FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 OPPTS GLN 860.1200: Directions for Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 OPPTS GLN 860.1300: Nature of the Residue in Plants . . . . . . . . . . . . . . . . . . . . . . . . 30 OPPTS GLN 860.1300: Nature of the Residue in Livestock . . . . . . . . . . . . . . . . . . . . . 33 OPPTS GLN 860.1340: Residue Analytical Methods . . . . . . . . . . . . . . . . . . . . . . . . . . 35 OPPTS GLN 860.1360: Multiresidue Method Testing . . . . . . . . . . . . . . . . . . . . . . . . . . 36 OPPTS GLN 860.1380: Storage Stability Data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 OPPTS GLN 860.1500: Magnitude of the Residue in Crop Plants . . . . . . . . . . . . . . . . . 36 OPPTS GLN 860.1520: Magnitude of the Residue in Processed Food/ Feed . . . . . . . . . 45 OPPTS GLN 860.1480: Magnitude of the Residue in Meat, Milk, Poultry, and Eggs . . . 47 OPPTS GLN 860.1400: Magnitude of the Residue in Water, Fish, Irrigated Crops . . . . 50 OPPTS GLN 860.1460: Magnitude of the Residue in Food handling Establishments . . . 51 OPPTS GLN 860.1650: Submittal of Analytical Reference Standards . . . . . . . . . . . . . . . 51 OPPTS GLN 860.1850: Confined Accumulation in Rotational Crops . . . . . . . . . . . . . . 52 OPPTS GLN 860.1900: Field Accumulation in Rotational Crops . . . . . . . . . . . . . . . . . . 52 TOLERANCE REASSESSMENT SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 Tolerances Listed Under 40 CFR § 180.291( a): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 Tolerances Listed Under 40 CFR § 180.291( b): . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 Tolerances Listed Under 40 CFR § 180.319: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 79 Tolerances Needed Under 40 CFR § 180.291( a) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 80 DIETARY EXPOSURE ASSESSMENT SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 84 CODEX HARMONIZATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 85 AGENCY MEMORANDA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86 RESIDUE CHEMISTRY CITATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91 25 NO 2 Cl Cl Cl Cl Cl PENTACHLORONITROBENZENE ( PCNB)

REREGISTRATION ELIGIBILITY DOCUMENT RESIDUE CHEMISTRY CONSIDERATIONS PC Code 056502; DP Barcode D266923 INTRODUCTION Pentachloronitrobenzene ( PCNB) is an organochlorine fungicide registered for direct field use on beans, Brassica vegetables, cotton, garlic, peppers, peanuts, potatoes and tomatoes, and for use as a seed treatment on a variety of crops. PCNB formulations registered to the basic producers, Uniroyal Chemical Company and Amvac Chemical Corporation, for use on food/ feed crops include flowable concentrate ( FlC), water dispersible granular ( WDG), wettable powder ( WP), emulsifiable concentrate ( EC), granular ( G), dust ( D), and ready to use ( RTU) formulations. These products may be applied as pre plant incorporated applications, in furrow applications, broadcast applications, or banded applications using ground equipment or as seed treatments. Depending on the producer and the manufacturing procedure, PCNB impurities can include hexachlorobenzene ( HCB), pentachlorobenzene ( PCB) and tetrachloronitrobenzene ( TCNB).

REGULATORY BACKGROUND PCNB is a List A reregistration chemical that was the subject of a Registration Standard dated 6/ 30/ 86 and a Reregistration Standard Update dated 6/ 19/ 90. These documents summarized regulatory conclusions on the available residue chemistry data and specified that additional data were required for reregistration purposes. Several submissions of data have been received since the Reregistration Standard Update was issued. The information contained in this document outlines the current Residue Chemistry Science Assessments with respect to the reregistration of PCNB.

After examination of the toxicology and chemistry data submitted by Uniroyal and Amvac, the Hazard Identification Assessment Review Committee ( HIARC, 1992) concluded that the PCNB technical materials from both of these registrants are so dissimilar they needed to be considered as separate and distinct chemicals based on differences in impurities and contaminants associated with the different manufacturing processes of the two registrants. As these registrants could not 26 share information, separate data were required from both registrants fulfilling residue chemistry data requirements.

Tolerances limiting the amount of the impurities hexachlorobenzene ( HCB) and pentachlorobenzene ( PCB) have been proposed for residues of PCNB ( PP# 1F1083, Amendment of 1/ 83). Both registrants, Amvac and Uniroyal, have agreed for PCNB formulations to reduce the maximum level of HCB to 0.05%, and of PCB to 0.01%. The Agency has determined that these limits will reduce dietary risk from HCB and PCB as impurities to negligible levels for PCNB alone, pending a comprehensive risk assessment for all products containing HCB and PCB ( Letters, J. E. Housenger, SRRD to J. K. Smith, Amvac, and W. F. Cummings, Uniroyal, 10/ 4/ 94).

In a cumulative risk assessment for HCB and PCB from all sources, HED concluded that the risk due to these chemicals is below the level of concern ( William Smith, " Assessment of the Dietary Cancer Risk of Hexachlorobenzene and Pentachlorobenzene as impurities in Chlorothalonil, PCNB, Picloram, and several other pesticides. DP Barcode D243499. Chemical codes 061001 ( Hexachlorobenzene) & 081901 ( Chlorothalonil)", 2/ 26/ 98)

The Metabolism Assessment Review Committee ( MARC) met on October 4, 2001 to determine if the variability in the level of active ingredient of PCNB and its contaminants in the Uniroyal and Amvac test materials used for toxicity studies is significant enough to call into question current registrations for the Uniroyal and Amvac's PCNB technical grade of active ingredients. The ( MARC) could find no evidence that the chemical composition ( i. e. impurity levels) differences among the formulations tested in the toxicity studies affected the NOAELS/ LOAELS and endpoints found. Other factors likely were greater contributors to the differences in the side byside toxicity studies submitted by the two registrants. Furthermore, it is the MARC's opinion that the contaminants at the levels found in the tested batches and the levels mandated by the Agency in the 12/ 94 letter will not bias the results of the toxicity studies.

Permanent tolerances for PCNB residues have been established in/ on plant raw agricultural commodities ( RACs) under 40 CFR § 180.291, and " interim tolerances" for PCNB residues have been established under 40 CFR § 180.319. A permanent tolerance of 0.1 ppm for residues of PCNB per se in/ on cottonseed has been established [ 40 CFR § 180.291( a)]. Permanent tolerances for a regional registration have also been established for the combined residues of PCNB and its metabolites, pentachloroaniline ( PCA) and methyl pentachlorophenyl sulfide ( MPCPS, also abbreviated as PCTA) in/ on collards, kale and mustard greens at 0.2 ppm [ 40 CFR § 180.291( b)]. " Interim" tolerances for residues of PCNB per se have also been established at 0.1 ppm in/ on beans, broccoli, Brussels sprouts, cabbage, cauliflower, garlic, peppers, potatoes and tomatoes and at 1.0 ppm in/ on peanuts [ 40 CFR § 180.319].

The MARC met on April 16, 2003 to determine the residues of concern for tolerance expression and for risk assessment. The MARC decided that as all the metabolites of PCNB are polychlorinated phenyl compounds and thus of toxicological concern, PCNB and all its metabolites ( including minor metabolites) are of concern in plant and animal commodities; there are currently more than 80 identified metabolites of concern. However, the residues of concern for tolerance setting purposes in primary and rotational crops and livestock are PCNB, PCA, and 27 PCTA ( also abbreviated as MPCPS). The MARC also determined that the residues of concern in drinking water are PCNB, PCA, and PCP. ( Sahafeyan, M., " The Outcome of the HED Metabolism Assessment Review Committee Held on April 16th, 2003 to discuss residues of concern in risk assessment and tolerance expression of Pentachloronitrobenzene ( PCNB) Chemical 056502", TXR no. 0051921, 5/ 27/ 2003).

The Food Quality Protection Act ( FQPA) of 1996 has amended and strengthened the standard for establishing tolerances under the Federal Food, Drug, and Cosmetic Act ( FFDCA). All future tolerance petitions as well as reassessment of established tolerances must meet the requirements of the FFDCA as amended by the FQPA. OPP may require additional data to determine if the terms of the amended statute are met.

The Agency updated the list of raw agricultural and processed commodities and feedstuffs derived from crops ( Table 1, OPPTS 860.1000). As a result of changes to Table 1, additional PCNB residue data are now required for some commodities ( e. g. cotton gin byproducts); these data requirements have been incorporated into this document. These new data requirements will be imposed at the issuance of the PCNB RED but should not impinge on the reregistration eligibility decisions for PCNB.

A revised chronic dietary risk assessment was completed on March 31st, 2004. The results for food alone ( no water) indicates that the chronic dietary risk for all population subgroups are below the level of concern ( 100% cPAD); the highest risk was for the population subgroup children 1 2 years old at 34% cPAD. The chronic dietary risk for general U. S. population was at 12% cPAD. When water was added to the analysis, % cPAD exceeded 100% for all populations except youth 13 19 with % cPAD of 78% and adults 20 49 with % cPAD of 97%; all other population subgroups exceeded the 100% cPAD mark and thus are of concern. The estimated risk including water for general U. S. population is 105% cPAD and the highest estimated risk is for population subgroup all infants at 313% cPAD.

A semi quantitative dietary risk assessment of PCP based on the available information was also estimated since PCP has a different ( carcinogenic) end point. In this worst case analysis with the assumption of potential residues of PCP in all tuber crops and using the recently revised Q 1* ( 3/ 4 scaling factor) of 0.07 x 10 1 mg/ kg day, the potential risk may be 5 x 10 8 ( general population), which is not of concern. 28 NO 2 Cl Cl Cl Cl Cl NH 2 Cl Cl Cl Cl Cl S CH 3 Cl Cl Cl Cl Cl Figure A. Chemical name and structure of PCNB and its residues of concern for tolerance expression.

Common Name/ Chemical Name Chemical Structure PCNB Pentachloronitrobenzene PCA Pentachloroaniline MPCPS ( PCTA)

Methyl pentachlorophenyl sulfide 29 SUMMARY OF SCIENCE FINDINGS OPPTS GLN 860.1200: Directions for Use A search of the Agency's Reference Files System ( REFS) on 2/ 8/ 01 indicated that there are a total of 28 PCNB end use products ( EPs) with uses on food/ feed crops registered to Uniroyal and Amvac. These EPs are presented below by registrant.

PCNB End Use Products with Food/ Feed Uses Registered to Uniroyal Chemical Company.

EPA Reg No. Label Acceptance Date Formulation Class Product Name 400 399a 8/ 13/ 99 75% WP Terraclor ® Wettable Powder 400 400 11/ 10/ 97 2 lb/ gal EC Terraclor ® 2 lb Emulsifiable 400 402 8/ 13/ 99 10% G Terraclor ® 10% Granular 400 406b 3/ 13/ 98 10% G Terraclor Super X ® Granular 400 408c 8/ 31/ 99 6.5% G Terraclor Super X ® with Di Syston ® 400 411d 11/ 29/ 96 6.5% G Terraclor ® 6.5% plus Di Syston ® 6.5%

400 412e 1/ 2/ 97 6.5% G Terraclor ® 6.5% with Thimet ® 6.5%

400 453 8/ 13/ 99 4 lb/ gal FlC Terraclor ® Flowable Fungicide 400 455f 6/ 1/ 95 2 lb/ gal FlC Terraclor Super X ® Flowable 400 456g 8/ 24/ 99 15% G Terraclor Super X ® 18.8 Granular 400 457 12/ 30/ 99 15% G Turfcide ® 15G Turf & Ornamental Fungicide 400 458 12/ 30/ 99 15% G Terraclor ® 15% Granular 400 460h 8/ 15/ 1983 24% EC Terrazan 24% Emulsifiable Concentrate 400 475i 1/ 8/ 97 1.5 lb/ gal EC Terraclor Super X ® plus Di Syston ® EC 400 479 5/ 13/ 98 75% WDG Turfcide ® WDG Turf & Ornamental Fungicide a Includes SLN No. ME79000100 for use on potatoes. b EPA Reg. No. 400 406 is a MAI formulation that also contains 2.5% 5 Ethoxy 3( trichloromethyl) 1,2,4 thiadiazole and is registered for use only on cotton; Uniroyal has recently requested cancellation of this product ( FR Notice Vol. 66, 44131, 8/ 22/ 01). c EPA Reg. No. 400 408 is a MAI formulation that also contains 1.63% 5 Ethoxy 3( trichloromethyl) 1,2,4 thiadiazole and 6.5% disulfoton and is registered for use only on cotton. d EPA Reg. No. 400 411 is a MAI formulation that also contains 6.5% disulfoton and is registered for use only on cotton. e EPA Reg. No. 400 412 is a MAI formulation that also contains 6.5% phorate and is registered for use only on cotton. f EPA Reg. No. 400 455 is a MAI formulation that also contains 0.5 lb/ gal of 5 Ethoxy 3 ( trichloromethyl) 1,2,4 thiadiazole and is registered for use only on cotton. g EPA Reg. No. 400 456 is a MAI formulation that also contains 3.8% 5 Ethoxy 3( trichloromethyl) 1,2,4 thiadiazole and is registered for use only on cotton. h EPA Reg. No. 400 460 is registered for cotton, beans, beans, beans ( snap), beans ( dry), and garlic. i EPA Reg. No. 400 475 is a MAI formulation that also contains 0.4 lb/ gal 5 Ethoxy 3( trichloromethyl) 1,2,4 thiadiazole and 1.5 lb/ gal disulfoton, and is registered for use only on cotton. 30 PCNB End Use Products with Food/ Feed Uses Registered to Amvac Chemical Corporation.

EPA Reg No. Label Acceptance Date Formulation Class Product Name 5481 211 1/ 27/ 00 10% G PCNB 10% Granules Soil Fungicide 5481 212a 12/ 4/ 96 2 lb/ gal EC PCNB 2 E Liquid 5481 215 7/ 22/ 91 1.7 lb/ gal FlC PCNB 2LF Seed Treatment Fungicide 5481 279b 8/ 29/ 94 75% WP PCNB 75% Wettable Powder 5481 308c 2/ 23/ 94 30% D PCNB Thiram 30 30 Seed Treat 5481 311d 2/ 23/ 94 10% D PCNB Thiram 10 10 Seed Treat 5481 415e 4/ 4/ 90 6.5% G PCNB Disulfoton Granules 6.5 6.5 5481 441 10/ 4/ 94 75% WDG PCNB 75 DG 5481 442 10/ 12/ 94 2 lb/ gal RTU PCNB Flowable RTU seed Protectant 5481 445 9/ 2/ 93 1.7 lb/ gal FlC PCNB ST Liquid Flowable Seed Treatment Fungicide 5481 450 11/ 2/ 94 20% WDG PCNB 20% WDG Soil Fungicide 5481 453 8/ 1/ 95 75% WP PCNB 75 WSP 5481 471 12/ 2/ 98 6 lb/ gal FlC Win Flo ® 6F Flowable Soil Fungicide 5481 472f 8/ 31/ 99 4 lb/ gal FlC BlockerJ 4F Flowable Fungicide a Includes the SLN No. TX90001000 for use on cotton. b Includes the SLN No. TX92002400 for use on cotton. c EPA Reg. No. 5481 308 is a MAI formulation that also contains 30% thiram and is registered for use only on cotton. d EPA Reg. No. 5481 311 is a MAI formulation that also contains 10% thiram and is registered for use only on cotton. e EPA Reg. No. 5481 415 is a MAI formulation that also contains 6.5% disulfoton and is registered for use only on cotton. f Includes the SLN Nos. ID 00000800, OR00001900, and WA00003000 for use on potatoes.

A comprehensive summary of the registered food/ feed use patterns of PCNB, based on the product labels registered to Uniroyal and Amvac, are presented in Tables A1 and A2. A tabular summary of the residue chemistry science assessments for reregistration of PCNB are presented for each registrant in Tables B1 and B2. The conclusions listed in Tables B1 and B2 regarding the reregistration eligibility of PCNB food/ feed uses are based on the use patterns registered by Uniroyal and Amvac, respectively.

Considering the current label directions and the available residue data, the following Uniroyal label changes are recommended:

$ Unless the registrants are intending to support direct field applications to soybeans, use directions for " Beans" should be amended to prohibit field applications to soybeans.

$ All labels should restrict use on collards, kale, mustard greens to the state of GA.

$ All labels should restrict rotation of crops only to the registered crops. 31 Considering the current label directions and the available residue data, the following Amvac label changes are recommended:

$ Use directions for " Beans" should be amended to include a minimum PHI and maximum seasonal use rate. Current crop field trial data would support a PHI of 40 days for dry and lima beans, and a maximum seasonal use rate of 7.5 lb ai/ A. For snap beans, Amvac must submit new trials at a specified PHI.

$ The maximum rate for in furrow applications to cotton, currently expressed in lb ai/ A, should be expressed in lb ai/ linear feet of row.

$ All labels should restrict use on collards, kale, mustard greens to the state of GA.

$ All labels should restrict rotation of crops only to the registered crops.

OPPTS GLN 860.1300: Nature of the Residue in Plants In response to the PCNB Reregistration Standard Update ( 6/ 90), Uniroyal submitted plant metabolism studies for PCNB on cabbage, potatoes ( 2 tests), and peanuts ( 2 tests).

In Uniroyal's cabbage metabolism study, [ 14C] PCNB was applied and incorporated into the soil at a rate of 48 lb ai/ A ( equivalent to 1.6x the maximum labeled rate). On the day of treatment, 27 day old cabbage plants were transplanted into the soil. Total radioactive residues ( TRR) were 4.1 7.9 ppm in immature plants collected 55 and 76 days post treatment. At maturity ( 160 days post treatment), TRR were 0.7 2.49 in cabbage heads and 11.0 17.9 ppm in wrapper leaves. Samples of wrapper leaves were used for metabolite analysis. Seven metabolites were tentatively identified in cabbage leaves, for a total of 57.5% of the TRR. The major metabolites in cabbage leaves were tertachlorophenyl methyl sulfoxide ( TCPM sulfoxide, 20.8% TRR) and tetrachlorophenyl methyl sulfone ( TCPM sulfone, 24.1% TRR). Other minor metabolites included: trichlorophenyl methyl sulfone ( RCPM sulfone, 5.1% TRR), trichlorophenol methyl sulfone ( RCHM sulfone, 2.1% TRR), N hydroxypentachloroaniline ( NOHPCA, 2.3% TRR), PCTA ( 0.3% TRR), and PCTA sulfoxide ( 2.8% TRR). In its initial review of the cabbage metabolism study, the Agency ( J. Abbotts, 4/ 24/ 96) concluded that the study was not adequate and required additional data characterizing 14C residues in acetone extracts and insoluble fractions that accounted for > 10% of the TRR.

In Uniroyal's initial peanut metabolism study, [ 14C] PCNB was applied and incorporated into the soil at a rate of 7.5 lb ai/ A ( equivalent to 3.8x the maximum labeled rate). Peanut seeds were immediately planted in the treated soil and mature plants were harvested 147 days later. At maturity, TRRs were 1520.8 ppm in roots, 42.3 ppm in vines, 128.3 ppm in shells, and 5.2 ppm in nutmeats. All four matrices were extracted and analyzed, but the extract from roots was used for metabolite identification. A total of 39.0 63.3% of the TRR was identified in roots, vines, and 32 shells, and 5.8% of the TRR was identified in nutmeats. The metabolites identified in roots, vines, and shells included: S( pentachlorophenyl) 2 N malonylcysteine ( PCP MalCys, 16.3 36.9% TRR), tetrachloroaniline ( TCA, 11.6 19.9% TRR), and S[( methylthio) tetrachlorophenyl] 2 thioacetic acid ( MTCP TAA, 5.6 11.1% TRR). The metabolite PCP MalCys also accounted for 5.8% of the TRR in nutmeats. In its initial review of the peanut metabolism study, the Agency ( J. Abbotts, 4/ 24/ 96) concluded that the study was not adequate.

Uniroyal subsequently submitted an additional peanut metabolism study. Greenhouse grown peanut plants were treated with [ 14C U phenyl] PCNB as either a preplant incorporated ( PPI) application at 15 lb ai/ A or as two banded applications over the plants at pegging, totaling 10 lb ai/ A. Samples of mature peanut and hay were collected from the different applications at 193 and 76 days post treatment, respectively. TRR were 13.0 and 2.14 ppm in/ on hay and nutmeats from the PPI application and 16.3 and 1.72 ppm in/ on hay and nutmeats from the post emergence application. Quantitative HPLC analyses of nutmeats and hay from the post emergence treatment identified 96.6% of the TRR in nutmeats and 91.7% of the TRR in hay. Metabolite identities were confirmed using GC/ ECD, GC/ MS and/ or LC/ MS. In nutmeats, the major 14C residue was PCNB, accounting for 96.6% of the TRR ( 1.7 ppm), along with trace levels of PCA. In hay, the main 14C residues included: PCNB ( 18.8% TRR, 3.1 ppm), PCP MalCys ( 53.1% TRR, 8.7 ppm), and N malonyl S( tetrachloroaminophenyl) cysteine ( Metabolite VI, 19.8% TRR, 3.2 ppm). Trace amounts of N malonyl S( tetrachloronitrophenyl) cysteine ( Metabolite IV) and tetrachloronitrophenyl glutathione ( Metabolite VII) were also identified in peanut hay. Although quantitative data were not provided from the analysis of shells, the principal solvent extractable 14C residues in peanut shells were PCNB and PCP MalCys, along with smaller quantities of Metabolite IV and tetrachloroaminophenyl sulphonic acid ( Metabolite V).

These data indicate that the metabolism of [ 14C] PCNB in peanuts primarily involves displacement of the nitro group with reduced glutathione, and the subsequent metabolism of the glutathione moiety. Provided the registrant submits information supporting the storage stability of 14C residues over the course of the study, the submitted peanut metabolism study is acceptable.

In Uniroyal's initial potato metabolism study, [ 14C] PCNB was applied and incorporated into the soil at a rate of 18.9 lb ai/ A ( Uniroyal currently has no registered uses on potatoes). Potato seed pieces were planted in the treated soil, and tubers were harvested 77 days later. TRRs were 2.39 ppm in/ on whole tubers, 11.26 in/ on peel and 0.76 ppm in/ on potato flesh. All three matrices were extracted and analyzed, but identification work focused primarily on the peel fraction. A total of 76.4% of the TRR was identified in extracts from peel. The major 14C residues in peel included: PCNB ( 24.4% TRR), PCA ( 18.3% TRR), S( pentachlorophenyl) cysteine ( PCP Cys, 8.5% TRR), and tetrachlorophenol ( TCP, 5.9% TRR). Other minor metabolites in peel included: PCTA ( 2.9% TRR), tetrachloronitrophenol ( TCNP, 3.6% TRR), NOHPCA ( 1.8% TRR), conjugates of pentachlorothiophenyl ( PCTP conjugates, 10.6% TRR), and pentachlorophenol glycoside ( PCP Gly, 0.4% TRR). Another  28% of the peel TRR was released by acid and base hydrolyses and identified as being comprised of PCA, PCP, and TCP. In whole potatoes, the major metabolites included: a PCTP conjugate ( 31.7% TRR), PCP Cys ( 17.5% TRR), and PCTA ( 9.5% TRR). Minor amounts of PCA ( 6.4% TRR) and NOHPCA ( 1.6% TRR) were also 33 detected in whole tubers. The initial review of the potato metabolism study cited several deficiencies in the study, but the study was later upgraded to acceptable.

Uniroyal submitted an additional potato metabolism study, in which [ 14C UL phenyl] PCNB was applied to potato plants growing outdoors as a preplant incorporated ( PPI) application to the soil at either 20 or 60 lb ai/ A. Treated soil was hilled around the plants twice during the growing season, as per standard agricultural practices. Samples of mature potato tubers were collected 95 days post treatment. TRR were 1.12 and 3.54 ppm in/ on tubers from the 20 and 60 lb ai/ A treatments, respectively. The overall recovery of radioactivity from tubers accounted for 100 102% of the TRR. Detailed quantitative analyses of the solubilized 14C residues identified parent and more than 45 metabolites in potato tubers. The metabolite profile was similar for both application rates, and the identified components together accounted for 60.1 64.1% of the TRR Although no single component accounted for > 10% of the TRR, approximately half of the identified radioactivity ( 27.0 29.8% TRR) was comprised of five components. The two most abundant 14C residues were PCNB ( 7.5 8.0% TRR) and PCP MalCys ( 9.8 10.1% TRR), followed by PCA ( 2.4 4.3% TRR), PCTA ( 2.7 3.5% TRR), and aminotetrachlorobenzene sulfonic acid ( AM TCB sulfonic acid; 3.9 4.8% TRR). The remaining 44 metabolites each accounted for  2.8% of the TRR. PCB was detected at 1.0 1.9% of the TRR (  0.014 ppm), but HCB was not detected. This potato metabolism study was deemed adequate.

Based on Uniroyal's two potato studies, the major routes of metabolism of [ 14C] PCNB in potatoes involve: the displacement of a chlorine atom by glutathione; displacement of the nitro group with reduced glutathione with the subsequent metabolism of the glutathione moiety; reduction of the nitro group; and reductive and oxidative dechlorination.

Amvac has also submitted metabolism studies on peanuts, potatoes, and cabbage. Each of these studies were deemed inadequate, but upgradable. In the peanut metabolism study, [ 14C] PCNB was applied at 33.8 lb ai/ A ( 3.3x the maximum rate) to the soil and incorporated immediately prior to planting. Immature vines were collected at 92 day after treatment ( DAT) and mature vines, hulls, and nutmeats were collected at 185 DAT. TRRs were 3.5 3.97 ppm in vines, 26.3 ppm in hulls, and 1.99 ppm in nutmeats. Approximately 29% of the TRR was identified in mature vines, 40% of the TRR was identified in hulls, and 65% of the TRR was identified in nutmeats. In addition to PCNB, the following metabolites were identified in peanuts: PCA, PCB, 2,3,5,6 tetrachloronitrobenzene ( 4 TCNB), 2,3,4,5 tetrachloronitrobenzene ( 6 TCNB), PCP MalCys, and S tetrachloronitrophenyl N malonylcysteine. However, the Agency has requested additional data characterizing Unknowns D and H.

In Amvac's potato metabolism study, [ 14C] PCNB was applied at 33.8 lb ai/ A ( 1.4x the maximum rate) to the soil and incorporated immediately prior to planting. Samples of foliage were collected at 92 DAT and samples of tubers and foliage were collected at 122 and 154 DAT. TRRs were 4.9 7.95 ppm in foliage and 0.96 18.0 ppm in tubers at maturity. Approximately 13 31% of the TRR was identified in tubers and 2 4% of the TRR was identified in mature foliage. In addition to PCNB, the following metabolites were identified in potatoes: PCA, PCTA, PCB, 4 TCNB, 6 TCNB, and HCB. To upgrade the study, the Agency requested additional data characterizing Unknowns D and H. 1 These TRR values ( 24.0 and 58.5) can be found in the previous Agency document ( J. Abbotts, D158943, 4/ 24/ 1996). However, the original studies ( MRIDs 41341205 and 41303301) do not contain these information. Calculated TRR for milk based on % TRR ( by Dynamac) suggests lower TRR values for milk (~ 8 ppm). Uniroyal is asked for further clarification.

34 In Amvac's cabbage metabolism study, [ 14C] PCNB was applied at 30.1 lb ai/ A ( 1x the maximum rate) to the soil and incorporated immediately prior to planting. Samples of cabbage were collected at 120 and 206 DAT. TRRs in/ on whole cabbage were 3.52 ppm at 120 DAT and 0.285 0.359 ppm in/ on cabbage from 206 DAT. Approximately 20% of the TRR was identified in immature cabbage and 6 7% of the TRR was identified in mature cabbage. In addition to PCNB, the following metabolites were identified in cabbage: PCA, PCB, PCTA, 6 TCNB, HCB and PCP MalCys, and S tetrachloronitrophenyl N malonylcysteine. As in the other two metabolism studies, the Agency requested additional data characterizing Unknowns D and H.

In considering all three of Amvacs' plant metabolism studies, the Agency ( D184350 and D181195, J. Abbotts, 4/ 16/ 96) noted that early metabolites in the peanut, potato, and cabbage studies are similar, and that the HPLC profiles of polar metabolites are also similar for these crops. Provided a new acceptable metabolism study were completed on potato or cabbage, including identification of metabolites D and H, the Agency would be willing to conclude that the nature of the residue in plants was adequately understood.

OPPTS GLN 860.1300: Nature of the Residue in Livestock In response to the PCNB Reregistration Standard Update ( 6/ 90), Uniroyal submitted both a ruminant and poultry metabolism study; these studies were recently upgraded to adequate.

In Uniroyal's ruminant metabolism study, two goats were dosed orally with [ 14C] PCNB for five consecutive days at levels equivalent to 770 or 1,400 ppm in the diet. Based on Uniroyal's currently registered uses for PCNB, these dietary levels are equivalent to 3850x and 7000x the maximum dietary burden. TRR in milk were 24.0 and 58.5 ppm from the low and high dose goats, respectively1. For the low dose goat, TRR in tissues were 32.1 ppm in kidney, 25.9 ppm in liver, 1.1 ppm in muscle, and 17.4 18.3 ppm in fat. For the high dose goat, TRR in tissues were 49.1 ppm in kidney, 45.5 ppm in liver, 2.3 ppm in muscle, and 21.8 ppm in fat. Analysis of milk and tissues from the high dose goat indicated that PCA was the major residue in milk ( 72% TRR) and fat ( 83 90% TRR). PCA also accounted for 16 and 26% of the TRR in liver and kidney, respectively, but the major metabolites in these tissues were the glucuronide conjugate of PCA, which accounted for 40% and 55% of the TRR in liver and kidney, respectively, and a glucuronide conjugate of N hydroxypentachloroaniline ( NOHPCA), which accounted for 28% of the TRR in liver. Other minor metabolites identified in liver and kidney each accounted for  4.5% of the TRR and included NOHPCA, tetrachloroaniline methyl sulfoxide ( TCAM sulfoxide), tetrachlorothioanisole ( TCTA), tetrachloro( methylthio) thiophenol ( TCTP S Met), and a pentachlorothiophenol ( PCTP) dimer. In muscle, the major 14C residues included PCA ( 40.9% 35 TRR), PCTP ( 10.5% TRR), and a combination of TCTA and tetrachlorophenyl methyl sulfoxide ( 37.3% TRR).

In Uniroyal's poultry metabolism study, three groups of laying hens were dosed orally with [ 14C] PCNB for six consecutive days at levels equivalent to 107, 274 or 512 ppm in the diet. Based on Uniroyal's currently registered uses for PCNB, these dietary levels are equivalent to 430x, 1100x, and 2050x the maximum dietary burden. For the high dose group ( 512 ppm dose level), TRR were 5.75 in egg yolks, 0.29 ppm in egg whites, 3.81 ppm in liver, 0.30 0.71 ppm in muscle, 10.1 ppm in fat, and 5.92 ppm in skin with attached fat. In fat, PCNB was identified as the major residue, accounting for 45.7% of the TRR. Other major metabolites identified in fat included PCA ( 13.7% TRR) and TCA sulfoxide ( 29.1% TRR). In liver, PCTP ( 55.9% TRR) and pentachlorothioanisole sulfoxide ( 18.6% TRR) were identified as the major solvent extractable residues; the major 14C residues in base hydrolysates ( 36.6% TRR) of liver post extracted solids ( PES) were identified as PCA and PCTA. In yolks, PCA ( 11% TRR), PCTA ( 2.1% TRR), and PCTP ( 4.0% TRR) were each identified, but the majority of radioactivity ( 75% TRR) in yolks remained unextracted. Base hydrolysis of the yolk PES released 28.8% of the TRR, which was composed primarily of PCTA, along with trace amounts of PCB, HCB, PCNB and PCA. In muscle, the major 14C residue was TCP sulfone ( 62% TRR), along with minor amounts of PCTA ( 5.6% TRR).

Amvac has also submitted separate ruminant and poultry metabolism studies. In Amvac's goat metabolism study, two goats were dosed orally with [ 14C] PCNB for five consecutive days at levels equivalent to 797 or 1,012 ppm in the diet; however, only milk and tissues from the low dose goat ( 797 ppm) were analyzed. TRR in milk reached a maximum of 5.98 ppm on Day 3 and declined to 2.37 ppm by the time of sacrifice. TRR in tissues were 10.3 ppm in kidney, 13.37 ppm in liver, 0.541 ppm in muscle, and 15.2 26.9 ppm in fat. PCA was identified as the principal metabolite in milk, kidney, muscle and fat, accounting for 31.2 59.2% of the TRR. Five unknown polar metabolites, each accounting for < 5% of the TRR, were also isolated from kidney, fat and/ or muscle. Minor amounts ( 1.5 6.4% TRR) of PCTA were also identified in these matrices. In liver, PCA and PCTA accounted for 9.6% and 1.3% of the TRR, respectively. However, the majority ( 40% TRR) of the radioactivity in liver was associate with an unknown polar metabolite released by base hydrolysis. The Agency concluded that this goat metabolism study is not adequate. Further analyses are required to characterize major unidentified radioactive unknown components in milk and tissues.

In Amvac's poultry metabolism study, two groups of laying hens were dosed orally with [ 14C] PCNB for five consecutive days at levels equivalent to 309 and 554 ppm in the diet. At sacrifice, TRR in egg yolks and whites were 1.22 ppm and 0.017 ppm, respectively, from the low dose group and 2.66 ppm and 0.038 ppm, respectively, from the high dose group. For the low dose group, TRR in tissues were 1.47 ppm in kidney, 1.97 ppm in liver, 0.13 ppm in muscle, 2.11 ppm in fat, and 1.12 ppm in skin with attached fat. For the high dose group, TRR in tissues were 1.85 ppm in kidney, 2.42 ppm in liver, 0.31 ppm in muscle, 4.25 ppm in fat, and 2.18 ppm in skin with attached fat. In muscle and fat, PCNB was the major 14C residue, accounting for 55.8% of the TRR in muscle and 59.8% of the TRR in fat. The metabolites PCA and PCTA were also detected in muscle at 4.7% and 2.1% of the TRR, respectively, and in fat at 6.4% and 10.3% of 36 the TRR, respectively. In liver extracts, PCNB, PCA and PCTA each accounted for  3.2% of the TRR; however, the majority of the radioactivity in liver was not adequately characterized. The Agency concluded that Amvac's poultry metabolism study is not adequate and that further analyses are required to characterize and identify the major radioactive components in eggs and tissues.

After considering the age of the samples from Amvac's ruminant and poultry metabolism studies, HED ( J. Abbotts, 4/ 16/ 96) recommended that Amvac should conduct new animal metabolism studies.

OPPTS GLN 860.1340: Residue Analytical Methods Adequate analytical methodology is available for enforcing tolerances of PCNB residues, as currently defined, in plant commodities. The Pesticide Analytical Manual ( PAM) Vol. II currently lists two GC method ( Methods A and I) for the determinating residues of PCNB per se. In addition, residues of PCNB, its metabolites PCA and MPCPS, and the impurities PCB and HCB are completely recovered through the multi residue methods listed in PAM Vol. I ( Methods 302, 303, and 304).

Uniroyal has submitted a method description and validation data for an adequate GC/ ECD method ( Method CAM 24 73 and its modifications) for collecting data on residues of PCNB, PCA, MPCPS, PCB, and HCB in plants commodities. This method is basically the same as the original ( Method CAM 11 72), with modifications in extraction solvents, clean up steps, and the use of more modern instrumentation ( e. g., capillary GC columns in place of the older, packed columns) in order to be able to analyze PCNB and degradates/ metabolites in other cotton matrices such as meal, soapstock, and oil. ( MRID 43976901, Gaydosh, K, Smudin, D., Terraclor 10G on Cotton: Processing Study).

Uniroyal also submitted a description for a GC/ ECD method ( CAM 11 72) for determining residues in cottonseed; however, method validation data were not provided for this method. Data are required validating Method CAM 11 72 as modified 10/ 28/ 87 and 3/ 15/ 88 for analysis in cottonseed.

In conjunction with their field trial data, Amvac has submitted a method description and validation data for adequate GLC/ ECD methods ( Amvac Methods MP PCNC MA1 and MP PCNC MA2) for collecting data on residues of PCNB, PCA, PCTA ( MPCPS), PCB, HCB, and TCNB in plant commodities.

In addition, the available residue data on livestock feed items indicate that tolerances will be required for animal commodities. Therefore, the registrants must submit methods for determining PCNB residues of concern in animal commodities. 37 It is the recommendation of the Agency that since all the identified metabolites of PCNB ( > 80 metabolites) are of concern, a radiovalidated common moiety method be developed by the registrants. The registrants should also make sure that any future submission clearly states the levels of Total Radioactive Residue ( TRR), PCNB, PCA, and PCTA.

OPPTS GLN 860.1360: Multiresidue Method Testing The Agency has determined that PCNB, PCA, MPCPS ( PCTA), PCB, and HCB are completely recovered through PAM Vol. I, Methods 302, 303 and 304. No additional data are required ( D. Edwards, 8/ 1/ 86).

OPPTS GLN 860.1380: Storage Stability Data The PCNB Update ( 6/ 90) cited storage stability data from Uniroyal indicating that PCNB, PCA, PCB, MPCPS, and HCB were stable in frozen wheat grain and kidney beans for up to 6 months; however, storage stability data on frozen corn grain, soybeans, peppers, tomatoes, catsup, and tomato pomace showed variable declines ( 20 40%) in these residues over 6 months of storage. Uniroyal later submitted additional data from this study examining storage intervals up to 14 months for kidney beans, peppers, tomatoes, and catsup. After 14 months of frozen storage, residues of PCNB, PCA, PCB, MPCPS, and HCB declined by 6 48% in kidneys beans, 43 75% in peppers, 55 92% in tomatoes, and > 92% in catsup.

More recent storage stability data from Uniroyal indicates that PCNB, PCA, PCB, HCB, and MPCPS are stable for at least 12 months in peanuts and cottonseed stored at < 0 C and in cabbage and potatoes stored at  20 C. Uniroyal has also submitted data indicating that residues of PCNB, its impurity HCB, and the metabolites PCA, PCB, TCA, MPCPS ( PCTA), TCTASOO and PCTASO are stable at  25 C for at least 24 months in lettuce, turnip tops and roots, and wheat forage, grain, and straw.

Amvac has submitted storage stability data on tomatoes, peanuts, potatoes, snap beans, and broccoli. Residues of PCNB, PCA, PCTA, HCB, PCB and TCNB ( both isomers) were stable in frozen ( 0< C) tomatoes, peanuts and broccoli residues for up to 439 days ( 14.4 months). Residues of PCNB, PCA, PCTA, HCB, PCB and 2,3,5,6 TCNB were stable for up to 439 days ( 14.4 months) in frozen potatoes. Residues of the metabolite 2,3,5,6 TCNB declined in frozen potatoes by 48% after 30 days of frozen storage, but remained relatively stable thereafter for up to 439 days. As 2,3,5,6 TCNB is not a currently regulated residue, the observed decline will have no impact on the acceptability of Amvac's potato field trials.

Amvac must submit storage stability data to support their cottonseed, peanut, potato, and tomato processing studies. 38 OPPTS GLN 860.1500: Magnitude of the Residue in Crop Plants As Uniroyal and Amvac are separately supporting the use of PCNB, the adequacy of the available field trial data will be considered separately for each registrant. Uniroyal has fulfilled requirements for magnitude of the residue data on the following crops/ commodities: garlic, Brassica vegetables, peppers and tomatoes; data for cottonseed are under review. Uniroyal has submitted adequate field trial data depicting residues of PCNB, PCA, MPCPS, PCB, and HCB in/ on these crops following applications made according to the current maximum labeled rates. Geographic representation is adequate and a sufficient number of trials reflecting representative formulation classes were conducted.

Amvac has not fulfilled requirements for magnitude of the residue data in/ on any crops. Brief summaries of the available field trial data are presented below by crop for each registrant.

Root and Tuber Vegetables Potatoes. An interim tolerance of 0.1 ppm has been in effect for residues of PCNB per se in or on potato. The new tolerance expression for supported plant and animal commodities includes PCNB, PCA, and PCTA based on the 4/ 16/ 2004 MARC's decision.

Uniroyal is supporting a SLN for state of ME with 75% WP formulation ( EPA SLN No. ME 790001) at 0.62 lb ai/ gal/ 2000 lb seed potatoes applied as a spray or dip just prior to cutting and/ or planting. Field trial data and processing data to support the SLN registration in ME are still outstanding.

Amvac has submitted inadequate residue data from 29 tests reflecting a single broadcast, pre plant incorporated ( PPI) application or an in furrow application of PCNB ( 10% G or 2 lb/ gal EC) to potato plants at planting at 25 lb ai/ A ( PPI) or at 11.6 11.7 lb ai/ 14,500 feet of row ( in furrow), a rate equivalent to 10 lb ai/ 12,400 linear feet of row ( each 1x the maximum labeled rate). Combined residues were < 0.030 0.238 ppm in/ on 28 potato samples harvested at maturity following application of PCNB ( 10% G) as either a broadcast PPI application or in furrow application. Combined residues were < 0.06 1.01 ppm in/ on 30 potato samples harvested at maturity following application of PCNB ( 2 lb/ gal EC) as either a broadcast PPI application or infurrow application.

Amvac has not fulfilled the required number of field trials in support of PCNB use on potato. An additional total of 36 field trials must be conducted with 10% G and 2 lb/ gal EC formulations for both PPI and in furrow applications in regions 1 ( 1 test), region 2 ( 1 test), region 5 ( 2 tests), region 9 ( 1 test), and region 11 ( 4 tests).

Bulb Vegetables 39 Garlic. An interim tolerance of 0.1 ppm is in effect for residues of PCNB per se in or on garlic. The new tolerance expression for supported plant and animal commodities includes PCNB, PCA, and PCTA based on the 4/ 16/ 2004 MARC's decision.

Residue data cited in the Reregistration standard ( 6/ 86) indicate that the combined residues of PCNB and its currently regulated residues are  0.008 ppm in/ on garlic following an application at [ 14C] PCNB 1.5x the maximum labeled rate. These data were originally submitted by Olin Mathieson Chemical Corporation ( now The Uniroyal Company).

Amvac magnitude of residue data for garlic remains outstanding.

Brassica Leafy Vegetables Head and Stem Brassica Vegetables Crop Subgroup Broccoli. An interim tolerance of 0.1 ppm is in effect for residues of PCNB per se in or on broccoli. The new tolerance expression for supported plant and animal commodities includes PCNB, PCA, and PCTA based on the 4/ 16/ 2004 MARC's decision.

Uniroyal has submitted residue data from 4 tests reflecting broadcast, banded, and transplant soildrench applications to broccoli using 10% G and 75% WP formulations at the maximum labeled rate ( 30 lb ai/ A). The combined residues of PCNB, PCA, MPCPS, PCB and HCB were < 0.01 0.0943 ppm in/ on 51 samples of broccoli harvested at maturity ( 64 83 days post treatment); HCB residues were < 0.002 in/ on all samples.

Amvac has submitted residue data from 15 tests reflecting a single banded, pre plant incorporated ( PPI) broadcast or soil drench application to broccoli plants at transplanting using 10% G or 75% WP formulations at the maximum labeled rate ( 30 lb ai/ A for banded and PPI application or 4.5 lb ai/ 100 gal. for soil drench). Following either a broadcast PPI or banded application of PCNB ( 75% WP), the combined residues of PCNB, PCA, and PCTA were < 0.03< 0.065 ppm in/ on 12 samples of mature broccoli from 6 tests. Following a soil drench application of PCNB ( 75% WP), the combined residues of PCNB, PCA, and PCTA were < 0.03< 0.089 ppm in/ on 6 samples of broccoli from 3 tests. Following either a broadcast PPI or banded application of PCNB ( 10% G), the combined residues of PCNB, PCA, and PCTA were < 0.03< 0.065 ppm in/ on 12 samples of broccoli from 6 tests. In addition to the currently regulated compounds, residues of PCB, TCNB ( two isomers), and HCB were each < LOD (< 0.005 ppm) in/ on all broccoli samples from each treatment.

Amvac needs to submit a total of 4 additional field trials in region 10; i. e., 1 test reflecting a single banded, pre plant incorporated ( PPI) broadcast at transplanting using 75% WP formulations at the maximum labeled rate ( 30 lb ai/ A) and 3 tests reflecting a soil drench application at transplanting using 10% G formulations at 4.5 lb ai/ 100 gal. PHI should be > 72 days. 40 Brussel sprouts and Cauliflower. Data from broccoli will be translated to support the equivalent uses on Brussels sprouts and cauliflower.

Cabbage. Uniroyal has submitted adequate residue data from 7 tests reflecting broadcast, banded, and transplant soil drench applications to cabbage using 10% G and 75% WP formulations at the maximum labeled rate ( 30 lb ai/ A). The combined residues of PCNB, PCA, MPCPS, PCB and HCB were < 0.01 0.0984 ppm in/ on 134 samples of cabbage harvested at maturity ( 67 125 days post treatment); HCB residues were  0.002 ppm. One sample had combined residues ( 0.1083 ppm) in excess of the 0.1 ppm tolerance, but this sample resulted from a soil drench application of the 75% WP at transplanting at 4.5 lb ai/ 100 gal solution. The maximum use rate for a soil drench application to Brassica vegetable on Uniroyal's labels is 1.5 lb ai/ 100 gal.

Amvac has submitted adequate residue data from 25 tests reflecting a single banded, PPI broadcast or soil drench application to cabbage plants at transplanting using 10% G and 75% WP formulations at the maximum labeled rate ( 30 lb ai/ A for banded and PPI applications or 4.5 lb ai/ 100 gal. for the soil drench). With the exception of four samples, residues of PCNB, PCA, and PCTA were each < 0.01 ppm (< LOQ; combined LOQ of 0.03 ppm) in/ on cabbage ( with and without wrapper leaves) samples ( n= 88) from each treatment. Three samples of cabbage ( RAC) from the soil drench application ( 75% WP) had PCNB residues of 0.012, 0.019, and 0.054 ppm and one of these samples had PCA residues of 0.013 ppm; one sample of cabbage ( RAC) from the broadcast application ( 10% G) had PCNB residues of 0.015 ppm. The maximum combined residues of PCNB, PCA, and PCTA, which are the currently regulated residues, were 0.077 ppm in/ on cabbage ( RAC) following a soil drench application of PCNB ( 75% WP). In addition to the regulated residues, residues of PCTA, TCNB ( both isomers), PCB and HCB were each < 0.005 ppm (< LOD) in/ on all cabbage samples.

Residue data from Uniroyal and Amvac support establishing a permanent tolerance at 0.1 ppm for the combined residues of PCNB, PCA, and PCTA in/ on head and stem Brassica vegetables Crop Subgroup. Additional residue data for broccoli from Amvac are required.

Leafy Brassica Greens Crop Subgroup Collards, Kale, Mustard greens. The PCNB Update ( 6/ 90) indicated that IR 4 has submitted adequate data to support the 0.2 ppm tolerance for the combined residues of PCNB, PCA, and MPCPS, provided that the use is restricted to GA.

Legume Vegetables Beans. Uniroyal has submitted data from 25 tests depicting residues of PCNB, PCA, MPCPS, PCB, and HCB in/ on snap beans, lima beans, and dry beans harvested 14 78 days following the last of four soil band applications of the 75% WP at 0.5 5 lb ai/ A/ application or the 2 lb/ gal EC at 1.9 2 lb ai/ A/ application. Applications began at planting and were repeated at 2 week intervals, for a maximum seasonal rate of 8 lb ai/ A. The combined residues of PCNB, PCA, MPCPS, PCB and HCB were < 0.25  0.432 ppm in/ on 55 samples of snap beans harvested 14 DAT, < 0.25 41  0.255 ppm in/ on 22 samples of lima beans harvested 35 or 63 DAT, and < 0.25  0.366 ppm in/ on 34 samples of dry beans harvested 35 78 DAT. Residues of MPCPS, PCB and HCB were below the method LOQ (< 0.05 ppm) in all samples. Reanalysis of the bean samples from the above tests using a method with a lower LOQ ( 0.002 ppm) indicated that combined residues were < 0.01 0.242 ppm; however, the available storage stability data indicate that residues would have declined substantially during the intervals samples were held prior to the reanalysis.

Although residues exceeding the current 0.1 ppm tolerance were detected in beans, however, these tests were conducted at rates higher than the label rates. The current Uniroyal labels allow for only a single field application at planting to beans ( excluding cowpeas) at a maximum of 1.5 lb ai/ A. Data are required reflecting Uniroyal's current use pattern for beans in order to accurately assess residues in beans. In addition, the labeled use on dry beans could potentially include use on soybeans. Therefore, field trial data are required reflecting the use PCNB on soybeans at the maximum rate. Alternatively, the registrant could prohibit direct field applications to soybeans, in which case separate field trial data for soybeans would not be required. ( The Agency notes that Uniroyal has submitted two magnitude of the residue studies on snap beans and dry beans, MRIDs 43118202 and 43118203, which are currently under review.)

Amvac has submitted residue data from 10 tests on dry beans reflecting four banded applications of PCNB ( 75% WP or 2 lb/ gal EC) to dry beans totaling 7.5 lb ai/ A ( maximum seasonal labeled rate not specified). Mature dry beans were collected 41 64 days after the last application. The combined residues of PCNB, PCA, and PCTA were < 0.030< 0.194 ppm in/ on 10 dry bean samples treated with the 75% WP and < 0.030< 0.165 ppm in/ on 10 dry bean samples treated with the 2 lb/ gal EC formulation. In addition, residues of PCB, TCNB ( two isomers), and HCB were each < LOQ (< 0.01 ppm) in/ on all dry bean samples. The dry bean field trial data are not adequate, as the number of crop field trials and geographic representation are inadequate. An additional 4 tests must be conducted using each formulation in EPA Region 5 ( 2 tests) and Regions 7 and 8 ( 1 test each), for a total of eight additional tests.

Amvac has submitted residue data from 8 tests on snap beans reflecting four banded applications of PCNB ( 75% WP or 2 lb/ gal EC) to snap bean plants totaling 7.5 8.2 lb ai/ A ( maximum seasonal labeled rate not specified). Mature snap beans were collected either 7, 10, 14, or 20 days after the last application. The combined residues of PCNB, PCA, and PCTA were < 0.063 2.38 ppm in/ on 8 snap bean samples treated with the 75% WP and < 0.036 1.08 ppm in/ on 8 snap bean samples treated with the 2 lb/ gal EC formulation. In addition, residues of PCB, HCB, and 2,3,5,6 TCNB were each < LOD (< 0.005 ppm) in/ on all treated samples. Residues of 2,3,4,5 TCNB were also < LOD (< 0.005 ppm) in/ on 12 samples from 3 tests and < 0.005 0.014 ppm in/ on 4 samples from one test. The snap bean field trial data are not adequate, as the number of crop field trials and geographic representation are inadequate. No tests were conducted in EPA Region 5. In addition, different post treatment intervals ( 7, 10, 14, or 20 days) were utilized at each test site, resulting in substantial differences in the residue values. Additional field trial residue data are required from 12 tests ( 6 per formulation) at a PHI specified by the registrant. Tests should include locations in Region 5. 42 Amvac has submitted residue data from 6 tests on lima beans reflecting four banded applications of PCNB ( 75% WP or 2 lb/ gal EC, 3 tests each) to bean plants totaling 7.5 lb ai/ A ( maximum seasonal labeled rate not specified). Whole pods of mature lima beans were collected 42 57 days after the last application. The combined residues of PCNB, PCA, and PCTA were < 0.015< 0.147 ppm in/ on 6 lima bean samples treated with the 75% WP and < 0.015< 0.0409 ppm in/ on 6 samples treated with the 2 lb/ gal EC formulation. In addition, residues of PCB, TCNB ( two isomers), and HCB were each < LOD (< 0.005 ppm) in/ on all lima bean samples. The lima bean field trial data are not adequate, as the number of crop field trials and geographic representation are inadequate. An additional 3 tests must be conducted in EPA Region 2 ( 2 tests) and Region 11 ( 1 test) with each formulation ( 75% WP and 2 lb/ gal EC) for a total of six additional tests.

Soybeans. Both Uniroyal's and Amvac's labeled uses on dry beans could potentially include use on soybeans. Therefore, field trial data are required reflecting the use PCNB on soybeans at the maximum rate. Alternatively, the registrant could prohibit direct field applications to soybeans, in which case separate field trial data for soybeans would not be required.

Fruiting Vegetables ( except Cucurbits)

Peppers. Uniroyal has submitted adequate data depicting residues of PCNB, PCA, MPCPS, PCB, and HCB in/ on peppers harvested 71 104 days following either an in furrow application of the 75% WP at planting at 7.5 lb ai/ A ( 1x the maximum rate) or a soil drench application at transplanting at 3.75 lb ai/ 100 gal water ( 1.6x). Residues of PCNB, PCA, MPCPS, PCB and HCB were each  0.05 ppm in/ on 20 samples of peppers, for combined residues < 0.25 ppm. Reanalysis of the pepper samples from the above tests using a method with a lower LOQ ( 0.002 ppm) indicated that combined residues were < 0.01 ppm; however, the available storage stability data indicate that residues would have declined substantially during the intervals samples were held prior to the reanalysis. Considering only the currently regulated metabolites ( PCNB, PCA, and MPCPS) the maximum combined residues in/ on peppers would be < 0.15 ppm.

Amvac has also submitted residue data from 8 tests reflecting a single application of PCNB ( 75% WP) to pepper plants at planting as either a soil drench application ( 4 tests) at 3.75 lb ai/ 100 gal. or as an in furrow application ( 4 tests) at a rate equivalent to 7.5 lb ai/ A. Pepper fruit was harvested at normal crop maturity, 49 105 days after application. The combined residues of PCNB, PCA, and PCTA were < 0.03 ppm in/ on all 8 pepper samples from the soil drench application and < 0.03 0.091 ppm in/ on 8 pepper samples from the in furrow application. In addition, residues of PCB, TCNB ( two isomers), and HCB were each < LOD (< 0.005 ppm) in/ on all pepper samples. The pepper field trial data are not adequate, as the number and geographic representation of the field trials are inadequate. An additional 5 tests must be conducted in EPA Regions 2, 3, and 5 ( 1 test each) and Region 5 ( 2 tests) using each application type ( in furrow and soil drench) for a total of 10 additional tests. If a tolerance for PCNB residues in/ on all peppers is desired, then an additional 2 tests must also be conducted on non bell peppers using each application type ( in furrow and soil drench) for a total of 4 additional tests. 43 Tomatoes. Uniroyal has submitted adequate data from 9 tests depicting residues of PCNB, PCA, MPCPS, PCB, and HCB in/ on tomatoes harvested 69 113 days following either an in furrow application of the 75% WP at planting at 7.5 lb ai/ A ( 1x the maximum rate) or a soil drench application at transplanting at 3.75 lb ai/ 100 gal water ( 1.6x). Residues of PCNB, PCA, MPCPS, PCB and HCB were each  0.05 ppm in/ on 26 samples of tomatoes, for combined residues < 0.25 ppm. Reanalysis of 18 tomato samples from the above tests using a method with a lower LOQ ( 0.002 ppm) indicated that combined residues were < 0.01  0.02 ppm; however, the available storage stability data for tomatoes indicate that residues would have declined substantially during the intervals samples were held prior to the reanalysis. Considering only the currently regulated metabolites ( PCNB, PCA, and MPCPS) the maximum combined residues in/ on tomatoes would be < 0.15 ppm.

Amvac has submitted residue data from 10 tests reflecting a single application of PCNB ( 75% WP) to tomato plants at transplanting as either a soil drench application ( 5 tests) at 3.75 lb ai/ 100 gal. or as an in furrow application ( 5 tests) at a rate equivalent to 7.5 lb ai/ A. Tomato fruit was harvested at normal crop maturity 81 108 days after application. The combined residues of PCNB, PCA, and PCTA were < 0.030 ppm in/ on all 10 tomato fruit samples from the in furrow application and < 0.030< 0.042 ppm in/ on 10 tomato fruit samples from the soil drench application. Quantifiable PCNB residues were found only in one sample, which had residues of PCNB per se at 0.022 ppm. In addition, residues of PCB, TCNB ( two isomers), and HCB were each < LOQ (< 0.01 ppm) in/ on all tomato samples. The tomato field trial data are not adequate, as the number and geographic representation of the field trials are inadequate. An additional 11 tests using the soil drench application method and an additional 11 tests using the in furrow application method must be conducted; the tests, for each application method, should be in EPA Regions 1 and 3 ( 1 test each) and Region 10 ( 9 tests).

The available residue data from Uniroyal and Amvac would support establishing a permanent tolerance at 0.2 ppm for the combined residues of PCNB, PCA, and PCTA in/ on fruiting vegetables ( except Cucurbits), however, additional tests must be conducted by Amvac before a final decision can be made.

Miscellaneous Commodities Cotton. Uniroyal has submitted data from 20 tests on cotton reflecting an in furrow application at planting of a 2 lb/ gal EC or 10% G formulation at 2 lb ai/ A ( 1x Uniroyal's current maximum rate); however, these data are not adequate because the field trial samples were analyzed by Craven Laboratories. The PCNB Update ( 6/ 90) also required cotton field trial data reflecting the use of a WP formulation; however, considering that the application is a soil application applied at planting, the Agency concludes that cotton field trial data reflecting use of a WP formulation is not required. ( The Agency notes that Uniroyal has submitted additional field trial data on cotton, MRIDs 42534114, 42534115, and 43574901 reflecting use of G and EC formulations which are currently under review.)

Amvac has submitted residue data from 15 tests reflecting a single application of PCNB to cotton plants at planting as either a banded application ( 10% G in 5 tests) at 2.0 lb ai/ A or as an in 44 furrow application ( 10% G in 5 tests and 2 lb/ gal EC in 5 tests) at 0.15 lb ai/ 1000 linear feet of row, equivalent to 2.0 lb ai/ A ( 13,000 feet of row), which is equivalent to the maximum label rate. Cotton ( lint and seed) was harvested at normal crop maturity 135 173 days after application. The combined residues of PCNB, PCA, and PCTA were < 0.015< 0.017 ppm in/ on all 30 cottonseed regardless of application method or formulation used. Residues of PCNB, PCA, and PCTA were each < LOD ( 0.005 ppm) in/ on all samples, with the exception of three treated samples, which had PCNB residues of 0.005 0.007 ppm. In addition to the currently regulated compounds, residues of PCB, TCNB ( two isomers), and HCB were each < LOD (< 0.005 ppm) in/ on all cottonseed samples regardless of formulation or application method. The cotton field trial data are not adequate, as the number of crop field trials and geographic representation are inadequate. An additional 4 tests must be conducted in EPA Region 2 ( 1 tests) and Region 8 ( 3 tests) with each formulation application scenario ( 10% G in in furrow application, 10% G in banded application, and EC formulation in in furrow application) for a total of 12 additional tests.

Additional residue data are required from both Uniroyal and Amvac to support establishing a permanent tolerance for the combined residues of PCNB, PCA, and PCTA in/ on cottonseed. Data are also required from both Uniroyal and Amvac depicting PCNB residues in/ on cotton gin byproducts following application of PCNB at the maximum labeled rate.

Peanuts. The PCNB Update ( 6/ 90) required residue data supporting the use of EC, FlC, and G formulations of PCNB on peanuts. Uniroyal has submitted field trial data from 12 tests reflecting two broadcast or banded foliar applications of PCNB ( 10% G, 75% WP, 2 lb/ gal EC, or 4 lb/ gal FlC) to peanut plants beginning at pegging at 3 7 lb ai/ A/ application, for a total of 10 lb ai/ A/ season. A total of 12 tests were conducted on peanuts: 2 tests using two banded applications of the 10% G at 5 lb ai/ A/ application; 2 tests using two banded applications of the 75% WP at 7 lb ai/ A and then 3 lb ai/ A; 2 tests using broadcast ( chemigation) applications of the 75% WP at 6 lb ai/ A and then 4 lb ai/ A; 3 tests using two broadcast ( chemigation) applications of the 2 lb/ gal EC at 5 lb ai/ A; and 3 tests using two broadcast ( chemigation) applications of the 4 lb/ gal FlC at 5 lb ai/ A. Mature peanuts were collected 43 47 days after the last application. The combined residues of PCNB, PCA, and PCTA were 0.017 0.089 ppm in/ on 4 peanut nutmeat samples treated with the 10% G, 0.007 0.024 ppm in/ on 8 peanut nutmeat samples treated with the 75% WP, 0.093 0.330 ppm in/ on 6 peanut nutmeat samples treated with the 2 lb/ gal EC, and 0.021 0.156 ppm in/ on 6 peanut nutmeat samples treated with the 4 lb/ gal FlC. In addition, residues of PCB were < 0.001 0.057 ppm and residues of HCB were < 0.0005 0.0126 ppm in/ on all peanut samples from all use patterns.

The peanut field trial data are not adequate, as the number and geographic representation of the field trials are inadequate. Although a total of 12 trials were conducted on peanuts, four different formulations were used. The Agency notes that Uniroyal formulations currently registered for use on peanuts include two granular ( G) formulations, a wettable powder ( WP), and a flowable concentrate ( FlC), and each of these formulations specify a maximum seasonal use rate of 2 lb ai/ A. An additional 10 field trials should be conducted in EPA Regions 2 ( 8 tests), Region 3 and 8 ( each 1 test) with the each of the three supported formulation for a total of 30 field trials. Samples of peanut hay must be taken and be analyzed as well. 45 Amvac has submitted residue data from 6 tests reflecting a single post emergence application of PCNB ( 2 lb/ gal EC, 10% G or 75% WP) to peanuts at pegging as either a 12 inch banded application ( 5 tests) or as a broadcast chemigation ( 1 test) application at 10 lb ai/ A ( the maximum label rate). Mature peanuts were collected 44 51 days after application. The combined residues of PCNB, PCA, and PCTA were 0.158 0.544 ppm in/ on 6 nutmeat samples treated with the 10% G as a banded application, < 0.012 0.078 ppm in/ on 4 nutmeat samples treated with the 75% WP as a banded application, and 0.312 0.383 ppm in/ on 2 samples treated with the 2 lb/ gal EC as a broadcast application. In addition, residues of PCB were < 0.005 0.062 ppm, TCNB ( each isomer) residues were < 0.005 0.030 ppm, and HCB residues were < 0.005 0.014 ppm in/ on all peanut samples.

As all nutmeat samples from the field trials reported in MRID 41870206 were ground with the shells before analysis, the residue data from these samples are not useful for tolerance assessment.

Amvac's peanut field trial data are not adequate, as the number of crop field trials and geographic representation are inadequate. A total of 30 additional tests must be conducted: 1) An additional 9 tests must be conducted with 10% G formulation in EPA Region 2 ( 7 tests) and Regions 3 and 8 ( 1 test each). 2) An additional 10 tests must be conducted with 75% WP formulation in EPA Region 2 ( 7 tests), and Regions 3, 6, and 8 ( 1 test each). 3) An additional 11 tests must be conducted with 75% EC formulation in EPA Region 2 ( 8 tests), and Regions 3, 6, and 8 ( 1 test each).

Additional residue data are required from both Uniroyal and Amvac to support establishing a permanent tolerance for the combined residues of PCNB, PCA, and PCTA in/ on peanuts.

Crops with Only Seed Treatment Uses Seed treatment uses of PCNB have been removed from all of Uniroyal's PCNB end use product labels; therefore, no additional data are required from Uniroyal pertaining to residues in crops with only seed treatment uses.

However, there are four PCNB end use products currently registered to Amvac with seed treatment uses on cereal grains ( barley, corn, oats, rice, sorghum and wheat) beans and peas, cotton, peanuts, safflower, soybeans, and sugar beets. Amvac has submitted a study following the uptake of radioactivity in corn, peas, rice, safflower, sugar beets, and wheat grown from seed treated with [ 14C] PCNB at 1.3 1.8x the maximum labeled rates. Based on this study, the Agency has concluded that Amvac's seed treatments are food/ feed uses. Data are required depicting residues of PCNB, PCA, MPCPS, PCB, and HCB in/ on RACs of barley, corn, oats, peas, rice, safflower, sorghum, sugar beets, and wheat grown from seed treated with PCNB at the maximum labeled rate.

Amvac has submitted adequate residue data from 7 tests reflecting a single seed treatment of PCNB ( 2 lb/ gal EC) to soybeans at 0.75 lb ai/ bushel ( 1.25 lb ai/ 100 lb seed), which is 10x the 46 maximum label rate. Soybean commodities were collected 125 145 days ( seeds), 80 118 days ( forage), and 91 145 days ( hay) after application. With the exception of one hay sample, the combined residues of PCNB, PCA, and PCTA were < 0.015 ppm (< LOD) in/ on 14 samples each of soybean seeds, forage, and hay. One hay sample had PCNB residues of 0.006 ppm, for combined residues of < 0.016 ppm. In addition, residues of PCB, TCNB ( two isomers), and HCB were each < LOD (< 0.005 ppm) in/ on all soybean seed, forage, and hay samples, with the exception of two hay samples from OH having PCB residues of 0.005 and 0.006 ppm. Amvac needs to submit additional 2 tests in region 4 and 11 tests in region 5. The available residue data would support establishing a separate tolerance at 0.02 ppm in/ on soybean forage, hay, and seeds for the combined residues of PCNB, PCA, and PCTA, however, additional tests must be conducted by Amvac before a final decision can be made.

Imported Crops Ginseng. Since extensive detected residues ( some times above 10 ppm) have been reported on ginseng by Food and Drug Administration monitoring program, residue data should be generated for ginseng in the representative countries and tolerance should be proposed.

OPPTS GLN 860.1520: Magnitude of the Residue in Processed Food/ Feed As Uniroyal and Amvac are separately supporting the use of PCNB, the adequacy of the available processing studies will be considered separately for each registrant. Uniroyal has submitted adequate processing studies for succulent beans, potatoes, and tomatoes. These studies indicate that PCNB residues and its impurities do not concentrate in regulated processed commodities derived from tomatoes; residues also did not concentrate in potato chips, flakes, or granules. Residues were shown to concentrate by 1.6x in bean cannery waste and 5.4x in wet potato peel. However, bean cannery waste is no longer a regulated feed item and Uniroyal is not supporting any uses on potatoes. Uniroyal has also submitted processing studies on cotton [ MRID 43976901] and peanuts [ MRID 43976902] that are under review.

Amvac has also submitted processing studies for succulent beans, cottonseed, peanuts, potatoes, and tomatoes. These studies indicate that PCNB residues and its impurities do not concentrate in regulated processed commodities derived from cottonseed, peanuts, and tomatoes. Residues also did not concentrate in potato granules, chips or flakes, but concentrated on average 7x in wet potato peel. However, supporting storage stability data are required to upgrade all of Amvac's processing studies to adequate. The processing studies are summarized below by crop.

Both registrants currently have uses on beans listed their current PCNB labels. As this use could include applications to soybeans, both registrants should conduct a soybean processing study. Alternatively the labels could be amended to prohibit direct field applications to soybean, in which case a processing study would not be required.

Beans, succulent. Uniroyal submitted an adequate succulent bean processing study using snap beans harvested 14 days after the last of multiple applications of PCNB totaling 40 lb ai/ A ( 26x 47 the current maximum rate). The combined residues of PCNB, PCA, MPCPS, PCB and HCB concentrated in cannery waste by 1.6x; however, bean cannery waste is no longer a regulated feed item.

Amvac also submitted a processing study using snap beans harvested 7 or 14 days following the last of four banded application of PCNB ( 75% WP) totaling 7.5, 22.5, or 37.5 lb ai/ A ( 1x, 3, and 5x). The study was deemed inadequate as residue data were provide only for the RAC treated at 1x and for the processed fractions ( processed beans and cannery waste) from the 5x treatment. However, no additional data are required as bean cannery waste is no longer a regulated commodity.

Cottonseed. Uniroyal previously submitted a cottonseed processing; however, the processing study is not adequate as the residue data were generated by Craven Laboratories. Uniroyal has since submitted an alternate cottonseed processing study ( MRID 43976901) that is currently under review.

Amvac has also submitted cottonseed processing studies using seed from plants treated with PCNB ( 2 lb/ gal EC) at 6 and 10 lb ai/ A ( 3x and 10x) as an in furrow application at planting. The data indicate that the combined residues of PCNB, PCA, MPCPS, PCB and HCB did not concentrate in cottonseed hulls, meal, soapstock, or crude and refined oil. However, supporting storage stability data for cottonseed processed fractions are required to upgrade this processing study. Samples from this processing study were stored frozen for 29 232 days prior to analysis.

Peanut. Uniroyal previously submitted a peanut processing; however, the study is not adequate as the residue data were generated by Craven Laboratories. Uniroyal has since submitted an alternate peanut processing study ( MRID 43976902) which is currently under review.

Amvac has also submitted peanut processing studies using peanuts treated with PCNB ( 75% WP) at 36 and 50 lb ai/ A ( 3.6 and 10x) as a banded application at pegging. The data indicate that the combined residues of PCNB, PCA, MPCPS, PCB and HCB did not concentrate in peanut presscake ( meal), soapstock or crude and refined oil. However, supporting storage stability data for peanut processed fractions are required to upgrade this processing study. Samples from this peanut processing study were stored frozen for 9 204 days prior to analysis.

Potato. As Uniroyal is no longer supporting the use of PCNB on potatoes, processing data on potatoes from Uniroyal are no longer necessary. However, the available Uniroyal potato processing studies are adequate and indicate that the combine residues of PCNB, PCA, MPCPS, PCB and HCB did not concentrate in chips, flakes or granules, but concentrated by 6.2x and 4.5x in wet peel from two tests ( average of 5.4x).

Amvac has also submitted potato processing studies using potatoes treated with PCNB ( 2 lb/ gal EC) at 12 and 50 lb ai/ A ( 1.2 and 5x) as an in furrow application at planting. The data indicate that the combined residues of PCNB, PCA, MPCPS, PCB and HCB did not concentrate in potato granules, chips or flakes, but concentrated on average by 2 12.7x ( average of 7x) in wet peel. Considering both the 7x concentration factor and the HAFT residues ( 0.95 ppm) from Amvac's 48 potato field trials, the maximum expected combined residues in wet peel would be 6.65 ppm. However, supporting storage stability data for processed potato fractions are required to upgrade this processing study. Samples from this potato processing study were stored frozen for 8 218 days prior to analysis.

Tomato. Uniroyal has submitted an adequate tomato processing study using tomatoes treated at 5x the maximum rate. Although residues of PCNB, PCA, MPCPS, PCB and HCB were not detected ( each at < 0.05 ppm) in whole tomatoes treated at 5x, the data indicate that the combined residues concentrated by 2x in dry pomace, but did not concentrate in juice, catsup, paste, puree, or wet pomace.

Amvac has also submitted a tomato processing study using tomatoes treated with PCNB ( 75% WP) at 75 lb ai/ A ( 10x) as an in furrow application at transplanting. The data indicate that the combined residues of PCNB, PCA, MPCPS, PCB and HCB did not concentrate in tomato puree, catsup, or juice, but concentrated on average by 32x in wet pomace and 63x in dry pomace. However, supporting storage stability data for tomato processed fractions are required to upgrade Amvac's tomato processing study. Samples from this processing study were stored frozen for 63 227 days prior to analysis.

OPPTS GLN 860.1480: Magnitude of the Residue in Meat, Milk, Poultry, and Eggs The calculation of dietary burden is shown in table below. As MARC decided that PCNB and all its metabolites (> 80) are of concern, TRR level residues in registered and unregistered crops which have associated feed items are used for estimating the dietary burden. This is because detected levels of PCNB and/ or its metabolites have been widely observed on unregistered crops that were sampled by PDP and FDA, substantiating the very long half life of PCNB and/ or its residues in soil ( 1555 days, C. A. Sutton, " Pentachloronitrobenzene, Revised Drinking Water Assessment", D291286, 12/ 22/ 2003) reported in literature. 49 Calculation of maximum dietary burdens of livestock animals for PCNB residues.

Feed Commodity 1, 3 % Dry Matter 2 % Diet 2 TRR ( ppm) 2 Dietary Burden from Registered and Unregistered Crops ( ppm) 3,4,5 Dietary Burden from Registered Crops ( ppm) 3,4 5 Beef Cattle potato waste 15 40 8.0 21.3 21.3 peanut meal 85 15 0.4 0.07 0.07 forage ( wheat source) 25 25 5.05 5.05

straw and hay ( wheat source) 88 20 25.9 5.89

TOTAL BURDEN 100 32.31 21.37 Dairy Cattle potato waste 15 40 8.0 21.3 21.3 peanut meal 85 15 0.4 0.07 0.07 forage ( wheat source) 25 25 5.05 5.05

straw and hay ( wheat source) 88 20 25.9 5.89

TOTAL BURDEN 100 32.31 21.37 Poultry peanut meal N/ A 25 0.4 0.1 0.1 wheat grain 89 75 0.38 0.285 0 TOTAL BURDEN 100 0.385 0.1 Swine potato culls N/ A 50 1.1 0.55 0.55 peanut meal N/ A 15 0.4 0.6 0.6 Other feed stuff  35 0 0 0 TOTAL BURDEN 100 1.15 1.15 1. Diet was chosen based on consultation with HED scientist, Jerry Stokes in Dec. 2003; personal communication.

2. From Table 1 of residue chemistry 860 guideline series ( August 1996).

3. Residues for potato waste are based on the TRR in potato metabolism study ( 1.12 ppm) and average concentration factor for potato wet peel in Amvac processing study ( 7x) and those for peanut meal are based on TRR in peanut metabolism study (~ 1.72/ 5 to get TRR for 1x use rate); the highest combined residues of PCNB, PCA, and PCTA from potato field trials is 1.01 ppm ( for 2 lb/ gal EC in in furrow application almost equal to 10 lb ai/ 12,400 linear feet of row with 50 PHI of 89 135 days), that for peanut nutmeat from field trials is 0.330 ppm ( for 2 lb ai/ gal EC for total application rate of 10 lb ai/ A with PHI of 45 47 days), and for peanut hulls, the highest combined residues of PCNB, PCA, and PCTA from field trials is 1.09 ppm ( for 10% G formulation in total application rate of 10 lb ai/ A and PHI of 43 45 days). The closeness of TRR from metabolism studies and field trial data further supports use of TRR values and that this value for potato waste, potato culls, and peanut meal is not an overestimate.

4. Contribution = [ TRR / % DM ( if cattle)] X % diet).

5. Dietary burden from registered and unregistered crops for beef cattle/ dairy includes contribution from rotated wheat forage/ hay/ straw which contain carried over residues of PCNB and its metabolites ( see MRID 41562905). Dietary burden from registered crops are presented for comparison.

Reregistration requirements for magnitude of the residue in meat, milk, poultry, and eggs are fulfilled. Adequate poultry and ruminant feeding studies are available depicting residues of PCNB, PCA, PCA, MPCPS, PCB and HCB in meat, milk, poultry and eggs. Results from these studies are summarized below.

In the available ruminant feeding study, Holstein cows ( 3 cows/ group) were fed a combination of PCNB and 5 ethoxy 3( trichloro methyl) 1,2,4 thiadiazole for up to 15 weeks. Based on daily feed consumption, the PCNB feeding levels were equivalent to 0.1, 1.0, 10, and 1000 ppm in the diet. Milk was sampled weekly, and fat biopsy samples were collected after 1, 2, 4, 6, and 8 weeks of dosing at the 0.1, 1.0, and 10 ppm dose levels. Cows in the 1000 ppm dose group were sacrificed after 1 month of dosing, and cows in the other dose groups were sacrificed after 12 15 weeks of dosing. Samples of milk, fat, liver, kidney, and muscle were analyzed for residues of PCNB, PCA, MPCPS, PCB, and HCB. Detection limits were reported to be 0.001 ppm for each analyte, except MPCPS ( LOD = 0.01 ppm). Residues of PCA ( 0.001 0.009 ppm) and HCB ( 0.001 0.018 ppm) were detected in milk from the 10 ppm dose group; all other analytes were nondetectable in milk. Only PCA ( 0.062 0.186 ppm) and HCB ( 0.036 0.347 ppm) were detected in tissues ( not specified) from the 10 ppm dose group, and only HCB was detected in fat from the 1 ppm ( HCB, 0.007 0.037 ppm) and 0.1 ppm ( HCB, ND 0.016 ppm) dose groups.

Possible tolerances for livestock ( cattle, goats, horses, and sheep) commodities were calculated using residue data for PCNB, PCA, and MPCPS from the 10 ppm dose group and adjusting for the dietary burdens of beef cattle and dairy cattle ( milk). Based on the above assumptions, a tolerance of 0.05 ppm should be established for residues in milk and tolerances of 1.0 ppm should be established for residues in meat, fat, and meat byproducts ( mbyp) of cattle, goats, horse, and sheep.

Data from the ruminant feeding study ( 1 ppm dose group) was used to assess potential tolerances for hog commodities. Residues of PCNB, PCA, and MPCPS were non detectable in cattle tissues from the 1 ppm dose group, but PCA residues were detected in the 10 ppm dose group. Therefore, tolerances for hog commodities ( meat, fat, and mbyp) should be established at the 51 enforcement method LOQ. However, an enforcement method for animal commodities is not currently available and both Uniroyal and Amvac must submit an enforcement method for animal commodities.

In a poultry feeding study, Red Comet Chickens were fed PCNB ( 98% ai, containing 1.5% HCB) at levels equivalent to 0.05, 1.0, 5.0, 15, 75, and 300 ppm in the diet for 13 15 weeks. Eggs were collected at 2 13 day intervals, and samples of fat, liver, and breast muscle were collected at sacrifice. Samples of egg yolks and white, fat, liver, muscle were analyzed for residues of PCNB, PCA, MPCPS, PCB, and HCB. Detection limits were not reported. Maximum combined residues are reported in the table below.

Maximum combined residues of PCNB, PCA, MPCPS, PCB, and HCB in tissues and eggs from poultry dosed with PCNB ( containing 1.5% HCB) in the diet for 13 15 weeks.

Matrix PCNB dose level ( ppm in diet)

0.05 1.0 5.0 15.0 75 300 fat

0.157 a

0.176

0.485

2.502

9.166 43.41 liver

0.017 b

0.033

0.123

0.172

1.059 7.08 breast muscle ND c ND ND ND

0.047 0.73 egg yolk

0.014 b NR d

0.182

0.544

3.307 12.58 egg whites ND

0.006 ND

0.002

0.010 0.05 a In fat from hens dosed at 0.05 ppm, combined residues were comprised of PCNB ( 0.018 ppm), PCA ( 0.073 ppm), and HCB ( 0.066 ppm). b Residues were comprised only of HCB in liver ( 0.017 ppm) and egg yolk ( 0.014 ppm) from hens dosed at 0.05 ppm. c ND = not detected ( level unspecified). The GC/ ECD method used was validated to 0.002 ppm for each analyte ( combined LOQ of 0.006 ppm for PCNB, PCA, and MPCPS). d Not reported in PCNB Registration Standard Residue Chemistry Chapter ( 6/ 30/ 86).

Possible tolerances for poultry commodities were calculated using residue data for PCNB, PCA, and MPCPS from the 1.0 ppm dose group and adjusting for the calculated dietary burden of poultry. Based on the above assumptions, a tolerance of 0.5 ppm should be established for poultry fat and tolerances of 0.05 ppm should be established for eggs and poultry mbyp. A tolerance of poultry meat is not required as detectable residues are unlikely to occur in meat.

OPPTS GLN 860.1400: Magnitude of the Residue in Water, Fish, Irrigated Crops 52 PCNB is not registered for use on aquatic sites or crops; therefore, no residue chemistry data are required under this guideline topic.

OPPTS GLN 860.1460: Magnitude of the Residue in Food handling Establishments PCNB is not registered for use in food handling establishments; therefore, no residue chemistry data are required under this guideline topic.

OPPTS GLN 860.1650: Submittal of Analytical Reference Standards Analytical reference standards for PCNB have been submitted from both Amvac ( July 1999) and Uniroyal ( July 2001). However, reference standards are not available for the other two residues of concern, PCA and MPCPS. Both registrants should submit reference standards for PCA and MPCPS to the follow address.

USEPA National Pesticide Standards Repository/ Analytical Chemistry Branch/ OPP Attn: Richard ( Dick) Griffith or Charles Stafford 710 Mapes Road Fort George G. Meade, MD 20755 5350 OPPTS GLN 860.1850: Confined Accumulation in Rotational Crops Both Uniroyal and Amvac have submitted inadequate confined rotational crop studies.

Uniroyal submitted a confined rotational crop study in which [ 14C] PCNB was applied to a sandy loam soil at 2.0, 10, or 30 lb ai/ A. Turnips were planted 1 year after application at 2.0 or 10 lb ai/ A, and lettuce ( 10 lb ai/ A only) and wheat ( all rates) were planted 30, 120, and 365 days after treatment. Total radioactive residues were > 0.05 ppm in all samples except wheat grain planted 1 year after application at 2.0 lb ai/ A. Analyses of turnip tops and roots, lettuce, and wheat forage and straw of identified up to 30 metabolites, the majority of which accounted for only minor portions (< 10%) of the 14C residues, and the metabolic profile was similar between the three crops. PCNB was reduced to form PCA, which was the major non polar residue in rotational crops. PCNB may also undergo glutathione conjunction and cleavage to form PCTA. Subsequent oxidation and dechlorination reactions produced a number of tri, tetra, and pentachloro sulfonic acid, sulfoxide, and sulfone metabolites. The confined rotational crop study for PNCB is adequate only for 10 lb ai/ A use rate; the highest labeled use rate for PCNB on any rotated crop ( 30 lb ai/ A) was not used in this study for the three matrices ( used only for wheat forage). In the Uniroyal submitted rotational crops studies, the TRR was > 0.05 ppm, therefore requiring a complete characterization and identification of metabolites. Such a characterization and identification was conducted for lettuce, turnip and wheat forage and not for wheat grain. 53 Amvac also submitted a confined rotational crop study, which was originally reviewed by EFGWB ( D. Spatz, 5/ 3/ 93). In this study, [ 14C] PCNB was applied to a sandy loam soil at 31 lb ai/ A ( 1X). Lettuce, turnips, and wheat were planted at 30, 120, and 365 days after treatment in a greenhouse, and immature and mature plant samples were collected for analysis. Total radioactive residues ( TRR) in the various crops and crop parts ranged from 0.06 ppm ( lettuce) to 24.57 ppm ( wheat hulls).

The ChemSAC decided ( in June 2003) that based on all available data, PCNB treated crops should only be rotated to the labeled crops.

OPPTS GLN 860.1900: Field Accumulation in Rotational Crops:

The ChemSAC decided ( in June 2003) that based on all available data, PCNB treated crops should only be rotated to the labeled crops, therefore no field accumulation studies on ( unregistered) rotational crops are needed. However, such studies on registered crops are required as they are likely to contain residues exceeding the current tolerance level. Both Uniroyal and Amvac should submit field accumulation in registered rotated crops.

Uniroyal has submitted limited field rotational crop studies. However, these studies are not adequate as a representative root crop was not included at the 30 and 120 day plant back interval and because PCNB ( 10% G) was applied at 10 lb ai/ A/ season, which is not the highest use rate on rotated crops. In addition, these studies did not address rotation to registered crops. As noted above, field accumulation studies on registered rotational crops are required.

Amvac has not submitted field accumulation studies on rotational crops.

Field accumulation studies on registered rotational crops are required. Plant back interval in these studies should reflect the interval desired on product labels. The registrants are advised to consult the Agency in regard to which crops to be used in these studies. For information on conducting field accumulation studies on rotational crops, the registrant should refer to OPPTS Guideline No. 860.1900. 54 Table A1. Food/ Feed Use Patterns Subject To Reregistration for PCNB End use Products Registered to Uniroyal Chemical Company ( Case 0128).

Site Application Type Application Timing Application Equipment Formulation [ EPA Reg. No.] Maximum Application Ratea ( lb ai/ A) Use Limitations b, c Beans ( excluding cowpeas)

In furrow application at planting Ground equipment 10% G [ 400 402]

15% G [ 400 458]

2 lb/ gal EC [ 400 400]

75% WP [ 400 399]

4 lb/ gal FlC [ 400 453] 1.5 Feeding treated vines or hay to livestock is prohibited.

Soil drench to seedlings in beds or containers prior to transplanting Ground equipment 75% WP [ 400 399]

75% WDG [ 400 479]

4 lb/ gal FlC [ 400 453] 0.375 lb ai/ 100 gal ( 0.375 lb ai/ 5 cubic yards) One repeat application can be made 4 6 weeks after the first application, for a total of 0.75 lb ai/ 5 cubic yards of growing media.

Preplant incorporated into growing media of bedding plants Ground equipment 10% G [ 400 402]

15% G [ 400 458] 0.15 lb ai/ cubic yard Table A1. Continued.

Site Application Type Application Timing Application Equipment Formulation [ EPA Reg. No.] Maximum Application Ratea ( lb ai/ A) Use Limitations b, c 55 Brassica Leafy Vegetables Group In furrow at planting application or preplant incorporated banded or broadcast application Ground equipment 10% G [ 400 402]

15% G [ 400 458]

75% WP [ 400 399]

4 lb/ gal FlC [ 400 453] 30 Do not exceed 30 lb ai/ A/ season, regardless of the application method. Use on collards, kale, and mustard greens is restricted to the state of GA.

Soil drench immediately after transplanting Ground equipment 75% WP [ 400 399]

4 lb/ gal FlC [ 400 453] 1.5 lb ai/ 100 gal ( ½ pint plant)

Soil drench to seedlings in beds or containers prior to transplanting Ground equipment 75% WP [ 400 399]

75% WDG [ 400 479]

4 lb/ gal FlC [ 400 453] 0.375 lb ai/ 100 gal ( 0.375 lb ai/ 5 cubic yards) One repeat application can be made 4 6 weeks after the first application, for a total of 0.75 lb ai/ 5 cubic yards of growing media.

Preplant incorporated into growing media of bedding plants Ground equipment 15% G [ 400 457]

15% G [ 400 458]

10% G [ 400 402] 0.15 lb ai/ cubic yard Cotton In furrow application at planting Ground equipment 75% WP [ 400 399]

2 lb/ gal EC [ 400 400]

10% G [ 400 402]

15% G [ 400 458] 2.0 Do not exceed 2 lb ai/ A/ season regardless of formulations used. Apply over the seed and to the surrounding soil.

Do not allow grazing or feeding of cotton foliage by livestock.

4 lb/ gal FlC [ 400 453]

2 lb/ gal FlC [ 400 455]

15% G [ 400 456] 1.5 Table A1. Continued.

Site Application Type Application Timing Application Equipment Formulation [ EPA Reg. No.] Maximum Application Ratea ( lb ai/ A) Use Limitations b, c 56 1.5 lb/ gal EC [ 400 475]

6.5% G [ 400 408]

6.5% G [ 400 411]

6.5% G [ 400 412] 1.0 Garlic In furrow application at planting Ground equipment 75% WP [ 400 399]

2 lb/ gal EC [ 400 400]

4 lb/ gal FlC [ 400 453] 20 21 For in furrow application, apply over the seed clove and to the surrounding soil. For seed clove treatment, mix in sufficient water, add a sticker to the spray solution, and mist spray for complete coverage of cloves. Apply only at planting time, and do not apply more than 21 lb ai/ A,

regardless of application method.

Direct spray treatment of seed cloves prior to planting 10 lb ai/ 1,000 lb seed cloves Peanuts In furrow application at planting Ground equipment 10% G [ 400 402]

15% G [ 400 458]

75% WP [ 400 399]

4 lb/ gal FlC [ 400 453] 2.0 Do not exceed 2 lb ai/ A/ season regardless of formulations used. Feeding of vines to livestock and hogging down of peanuts are prohibited.

Do not use on peanuts grown in CA.

Peppers, hot ( direct seeded)

In furrow application at planting Ground equipment 10% G [ 400 402]

15% G [ 400 458]

4 lb/ gal FlC [ 400 453] 1.3 1.5 Apply over the seed and to the surrounding soil. Table A1. Continued.

Site Application Type Application Timing Application Equipment Formulation [ EPA Reg. No.] Maximum Application Ratea ( lb ai/ A) Use Limitations b, c 57 Peppers In furrow application at planting Ground equipment 15% G [ 400 458]

75% WP [ 400 399]

4 lb/ gal FlC [ 400 453] 7.2 7.5 Soil drench application at transplanting Ground equipment 75% WP [ 400 399]

4 lb/ gal FlC [ 400 453] 2.25 lb ai/ 100 gal Do not exceed 20 lb ai/ A/ season Soil drench to seedlings in beds or containers prior to transplanting Ground equipment 75% WP [ 400 399]

75% WDG [ 400 479]

4 lb/ gal FlC [ 400 453] 0.375 lb ai/ 100 gal ( 0.375 lb ai/ 5 cubic yards) One repeat application can be made 4 6 weeks after the first application, for a total of 0.75 lb ai/ 5 cubic yards of growing media.

Preplant incorporated into growing media of bedding plants Ground equipment 15% G [ 400 457]

15% G [ 400 458]

10% G [ 400 402] 0.15 lb ai/ cubic yard Table A1. Continued.

Site Application Type Application Timing Application Equipment Formulation [ EPA Reg. No.] Maximum Application Ratea ( lb ai/ A) Use Limitations b, c 58 Tomatoes In furrow application at planting Ground equipment 15% G [ 400 458]

75% WP [ 400 399]

4 lb/ gal FlC [ 400 453] 7.2 7.5 Do not exceed 7.2 7.5 lb ai/ A/ season.

Soil drench application at transplanting Ground equipment 75% WP [ 400 399]

4 lb/ gal FlC [ 400 453] 2.25 lb ai/ 100 gal Do not exceed 7.0 lb ai/ A/ season for planting of 5000 plants/ A or 16.5 lb ai/ A/ season for plantings of 11,733 plants/ A.

Soil drench to seedlings in beds or containers prior to transplanting Ground equipment 75% WP [ 400 399]

75% WDG [ 400 479]

4 lb/ gal FlC [ 400 453] 0.375 lb ai/ 100 gal ( 0.375 lb ai/ 5 cubic yards) One repeat application can be made 4 6 weeks after the first application, for a total of 0.75 lb ai/ 5 cubic yards of growing media.

Preplant incorporated into growing media of bedding plants Ground equipment 15% G [ 400 457]

15% G [ 400 458]

10% G [ 400 402] 0.15 lb ai/ cubic yard a A maximum of one application per season is allowed for all uses, with the exception of soil drench applications to vegetable bedding plants. Labels allow for up to two applications, with the second application made 4 6 weeks after the first.

b Planting root crops in PCNB treated fields within 12 months of broadcast and banding applications unless PCNB is registered for use on those crops is prohibited.

c A 12 hour restricted entry interval ( REI) is specified on each label, except for EPA Reg Nos. 400 408,  411,  412, and  475, which have REIs of 48 hours. 59 Table A2. Food/ Feed Use Patterns Subject To Reregistration for PCNB End use Products Registered to Amvac Chemical Company ( Case 0128).

Site Application Type Application Timing Application Equipment Formulation [ EPA Reg. No.] Maximum Single Application Rate Max. #

of Appl. Minimum RTIa ( Days) Use Limitations b, c Direct Crop or Soil Applications Beans ( excluding cowpeas)

In furrow application at planting Ground equipment 10% G [ 5481 211]

2 lb/ gal EC [ 5481 212]

75% WP [ 5481 279]

75% DF [ 5481 441]

20% DF [ 5481 450]

75% WP [ 5481 453]

6 lb/ gal FlC [ 5481 471]

4 lb/ gal FlC [ 5481 472] bush beans: 1.5 lb ai/ A or 14,500 linear ft.

pole beans: 1.5 lb/ 8,340 linear ft 1 Not Applicable ( NA) In furrow applications should be made at planting with only one treatment per season.

Do not feed treated vines or hay to livestock Repeated basally directed applications until bloom Ground equipment 2 lb/ gal EC [ 5481

212] 75% WP [ 5481 279]

75% DF [ 5481 441]

75% WP [ 5481 453] 1.5 lb ai/ A Not specified ( NS) 14 Except in CA, multiple basally directed applications can be made to dry and snap beans 2 3 week intervals. Do not apply after first bloom or exceed a maximum of 10 lb ai/ A/ season.

Do not feed treated vines or hay to livestock 6 lb/ gal FlC [ 5481 471]

4 lb/ gal FlC [ 5481 472] 2.0 lb ai/ A Multiple basally directed applications can be made to dry and snap beans at 2 3 week intervals.

Do not apply after start of pod formation,

and do not feed treated vines to livestock.

A maximum seasonal rate is not specified. Table A2 ( Continued)

Site Application Type Application Timing Application Equipment Formulation [ EPA Reg. No.] Maximum Single Application Rate Max. #

of Appl. Minimum RTIa ( Days) Use Limitations b, c 60 Brassica Leafy Vegetables Preplant incorporated broadcast application Ground equipment 6 lb/ gal FlC [ 5481 471]

4 lb/ gal FlC [ 5481 472] 30 lb ai/ A 1 Use on collards, kale, and mustard greens is restricted to the state of GA.

Do not apply more than 30 lb ai/ A/ season, regardless of the method of application or the formulation used.

Banded incorporated application immediately after planting Ground equipment 22.8 lb ai/ A Soil drench immediately after transplanting Ground equipment 1.5 lb ai/ 100 gal Broccoli, Brussels sprouts, Cabbage, and Cauliflower Preplant incorporated broadcast application Ground equipment 10% G [ 5481 211]

75% WP [ 5481 279]

75% DF [ 5481 441]

20% DF [ 5481 450]

75% WP [ 5481 453] 30 lb ai/ A 1 NA Banded incorporated application immediately after planting Ground equipment 22.5 lb ai/ A Soil drench immediately after transplanting Ground equipment 75% WP [ 5481 279]

75% DF [ 5481 441]

20% DF [ 5481 450]

75% WP [ 5481 453] 4.5 lb ai/ 100 gal Soil drench to seedlings grown in containers prior to transplanting Ground equipment 6 lb/ gal FlC [ 5481 471] 0.28 lb ai/ 100 gal ( 0.28 lb ai/ 5 cubic yards) 2 NS One repeat application can be made 4 6 weeks after the first application, for a total of 0.56 or 0.75 lb ai/ 5 cubic yards of growing media.

4 lb/ gal FlC [ 5481 472] 0.375 lb ai/ 100 gal ( 0.375 lb ai/ 5 cubic yards) Table A2 ( Continued)

Site Application Type Application Timing Application Equipment Formulation [ EPA Reg. No.] Maximum Single Application Rate Max. #

of Appl. Minimum RTIa ( Days) Use Limitations b, c 61 Cotton In furrow application at planting Ground equipment 10% G [ 5481 211]

2 lb/ gal EC [ 5481 212]

75% WP [ 5481 279]

75% DF [ 5481 441]

20% DF [ 5481 450]

75% WP [ 5481 453]

6 lb/ gal FlC [ 5481 471]

4 lb/ gal FlC [ 5481 472] 2.0 lb ai/ A 1 NA Apply over the seed and to the surrounding soil.

Do not allow grazing or feeding of cotton foliage by livestock.

Labels 5481 471 and  472 specify a maximum seasonal rate of 2.0 lb ai/ A.

30% D [ 5481 308] 1.5 lb ai/ A 10% D [ 5481 311]

6.5% G [ 5481 415] 1.0 lb ai/ A Garlic In furrow application at planting Ground equipment 2 lb/ gal EC [ 5481 212]

75% WP [ 5481 279]

75% DF [ 5481 441]

75% WP [ 5481 453]

6 lb/ gal FlC [ 5481 471]