UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C.  20460

	OFFICE OF CHEMICAL SAFETY

	AND POLLUTION PREVENTION

MEMORANDUM

Date:		04/30/2013

SUBJECT:	Pyraclostrobin:  Petition for the Establishment of Permanent
Tolerances and Registration for Use on Belgium Endive, Persimmon, and
Globe Artichoke. Request for Crop Group Expansions/Revisions for Bulb
Vegetable Group 3-07, Fruiting Vegetable 8-10,  Citrus Fruit Group
10-10, Pome Fruit Group 11-10, Berry Subgroups 13-07A, B, F, and G, and
Oilseed Group 20. Summary of Analytical Chemistry and Residue Data.

PC Code:  099100	DP Barcode: D410737,405065

Decision No.: 468304	Registration Nos.: 7969-187; 7969-199; 7969-186;
7969- 289

Petition No.: 2F8069	Regulatory Action:  Section 3 Registration

Risk Assessment Type: Single Chemical/Aggregate	Case No.: N/A

TXR No.: N/A	CAS No.: 175013-18-0

MRID Nos: 48897401, 48897402, 48897403	40 CFR: 180.582

FROM:	Stephen Funk, Senior Chemist

		Risk Assessment Branch III (RAB III)

		Health Effects Division (HED; 7509P)

THROUGH:	Christine Olinger, Branch Chief

		Risk Assessment Branch III (RABIII)

		Health Effects Division (HED; 7509P)

TO:		Barbara Madden

		Andrew Ertman

		Registration Division (RD; 7505P)

		And

		Barry O’Keefe, Senior Biologist

		Risk Assessment Branch III (RABIII)

		Health Effects Division (HED; 7509P)

Executive Summary

  SEQ CHAPTER \h \r 1 Pyraclostrobin, or methyl
[2-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]
phenyl]methoxycarbamate belongs to the strobilurin class of fungicides.
The fungicide is currently registered to BASF Corporation (BASF) for use
on a variety of field, vegetable, fruit, and nut crops.  It is
formulated as water-dispersible granules (WDG) or an emulsifiable
concentrate (EC) and is typically applied as foliar applications using
ground or aerial equipment at maximum seasonal rates of 0.3-3.0 lb ai/A.
 The 20% WDG formulation is also registered for use as a seed treatment
on some crops.

The Interregional Research Project Number 4 (IR-4) is proposing new uses
for pyraclostrobin on globe artichoke, Belgian endive, and persimmon and
is requesting certain crop group conversions.    The proposed use for
persimmon and globe artichoke is up to three applications of a WG
formulation with a seasonal maximum rate of 0.55 lb ai/acre and a 0 day
PHI.  The proposed use for Belgium endive is a root treatment with a WG
formulation with a total application rate of about 0.027 lb ai/1000 lbs
of root.

 IR-4 has proposed the establishment of a tolerance for the combined
residue of the fungicide pyraclostrobin (carbamic acid,
[2-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl]methoxy-,
methyl ester) and its desmethoxy metabolite
methyl-N-[[[1-(4-chlorophenyl) pyrazol-3-yl]oxy]o-tolyl] carbamate,
expressed as parent compound, in or on the following raw agricultural
commodities:

	Artichoke, globe………………………………….3.0 ppm

	Endive, Belgium………………………………….3.0 ppm

	Persimmon………………………………………..3.0 ppm

IR-4 has also proposed updating the existing crop groups to vegetable,
bulb, group 3-07 at 0.9 ppm; vegetable, fruiting, group 8-10 at 1.4 ppm;
fruit, citrus, group 10-10 at 2.0 ppm; fruit, pome, group 11-10 at 1.5
ppm;  oilseed, group 20 at 0.45 ppm; caneberry subgroup 13-07A at 4.0
ppm; bushberry subgroup 13-07B at 4.0 ppm; small fruit, vine climbing
subgroup (except fuzzy kiwi) 13-07F at 2.0 ppm; and low growing berry
subgroup 13-07G except cranberry at 1.2 ppm.  IR-4 has also proposed
removing tolerances for berry, group 13 at 4.0 ppm; fruit, citrus, group
10 at 2.0 ppm; fruit, pome, group 11 at 1.5 ppm; grape at 2.0 ppm;
strawberry at 1.2 ppm; vegetable, bulb, group 3 at 0.9 ppm; vegetable,
fruiting, group 8 at 1.4 ppm; borage, seed at 0.45 ppm; castor oil
plant, seed at 0.45 ppm; Chinese tallowtree, seed at 0.45 ppm; crambe,
seed at 0.45 ppm;  cuphea, seed at 0.45 ppm; echium, seed at 0.45 ppm;
euphorbia, seed at 0.45 ppm; evening primrose, seed at 0.45 ppm; flax
seed at 045 ppm; gold of pleasure, seed at 0.45 ppm; hare’s ear
mustard, seed at 0.45 ppm; jojoba, seed at 0.45 ppm; lesquerella, seed
at 0.45 ppm; lunaria, seed at 0.45 ppm; meadowfoam, seed at 0.45 ppm;
milkweed, seed at 0.45 ppm; mustard, seed at 0.45 ppm; niger seed, seed
at 0.45 ppm; oil radish, seed at 0.45 ppm; poppy, seed at 0.45 ppm;
rapeseed, seed at 0.45 ppm; rose hip, seed at 0.45 ppm; safflower, seed
at 0.45 ppm; stokes aster, seed ato 0.45 ppm; sunflower, seed at 0.45
ppm; sweet rocket, seed at 0.45 ppm; tallowwood, seed at 0.45 ppm; tea
oil plant, seed ato 0.45 ppm; and vernonia, seed at 0.45 ppm.

  SEQ CHAPTER \h \r 1 Tolerances have been established in 40 CFR
§180.582 for residues of the fungicide pyraclostrobin, including its
metabolites and degradates.  Compliance with the tolerance levels is to
be determined by measuring only the sum of pyraclostrobin (carbamic
acid, [2-[[[1-(4-chlorophenyl)-1H-
pyrazol-3-yl]oxy]methyl]phenyl]methoxy-, methyl ester) and its
desmethoxy metabolite (methyl
N-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl carbamate),
calculated as the stoichiometric  equivalent of pyraclostrobin .  The
established tolerances for plant food commodities range from 0.02 ppm
in/on wheat grain to 29 ppm in/on leafy vegetables, except Brassica.  A
Section 18 tolerance exists for Belgian endive. Tolerances for livestock
commodities are listed in 40 CFR §180.582 (a)(2) and are expressed in
terms of the combined residues of the fungicide pyraclostrobin and its
metabolites convertible to 1-(4-chlorophenyl)-1H-pyrazol-3-ol and
1-(4-chloro-2-hydroxyphenyl)-1H-pyrazol-3-ol, expressed as parent
compound.  The established tolerances for livestock commodities range
from 0.1 to 1.5 ppm; no tolerances are established for poultry
commodities.

HED (D278044, Metabolism Assessment Review Committee (MARC), 10/09/01)
has determined that for purposes of tolerance and dietary risk
assessments, the residues of concern in plant and rotational crop
commodities include pyraclostrobin and desmethoxy metabolite (BF 500-3).
 The residues of concern in livestock commodities include pyraclostrobin
and its metabolites convertible to 1-(4-chlorophenyl)-1H-pyrazol-3-ol
(BF 500-5) and 1-(4-chloro-2-hydroxyphenyl)-1H-pyrazol-3-ol (BF 500-8).

There are adequate residue analytical methods for tolerance enforcement.
   SEQ CHAPTER \h \r 1 The analytical methods for plant commodities are
liquid chromatography with tandem mass spectrometry (LC/MS/MS) and high
pressure liquid chromatography with ultraviolet detector (HPLC/UV),
which both measure pyraclostrobin and its desmethoxy metabolite.  The
analytical methods for livestock commodities, gas chromatography with
mass spectrometry (GC/MS) and LC/MS/MS, convert pyraclostrobin and
related metabolites to chlorophenylpyrazolol (BF 500-5) and hydroxylated
chlorophenylpyrazolol (BF 500-8) in goats and chlorophenylpyrazolol (BF
500-5) and a hydroxylated chlorophenylpyrazolol isomer of BF 500-8 (BF
500-9) in poultry.

Samples (artichoke, persimmon, Belgium endive) were analyzed for
pyraclostrobin and metabolite BF 500-3 using BASF Analytical Method
Number D9908 (Version 2), "Method for Determining BAS 500 F, BF 500-3
and BAS 510 F Residues in Plant Matrices using LC/MS/MS." (MRID
4670001). The lower limit of method validation (LLMV) in this study was
0.02 ppm for both pyraclostrobin and BF 500-3.  The LC/MS/MS method used
to determine residues of pyraclostrobin and BF 500-3 were adequately
validated in conjunction with the field sample analyses.  The average
recovery of all pyraclostrobin and BF 500-3 fortifications was adequate.
 The method is adequate for data collection.

The requirements for multiresidue methods testing data are fulfilled.
Pyraclostrobin was successfully evaluated through several of the FDA
protocols (complete recovery through protocols D and E), while recovery
of metabolite BF 500-3 was unsuccessful in all protocols.

Samples of artichoke from field trials were stored frozen for up to 21
months prior to analysis.  Samples of Belgium endive from field trials
were stored frozen for up to 10 months.  Samples of persimmon from field
trials were stored frozen for up to 18.4 months.  Adequate storage
stability data are available demonstrating that residues of
pyraclostrobin and its metabolite BF 500-3 are stable under frozen
conditions in/on the representative crop commodities of grape juice,
sugar beet tops and roots, tomatoes, and wheat grain and straw for up to
25 months, and in peanut nutmeat and processed oil for up to 19 months
(DP 269668, L. Cheng, 11/28/01).  These data are adequate to support the
storage conditions and durations of samples from the submitted field
trials.

There are no feed commodities associated with persimmon, artichoke, or
Belgium endive.  Therefore, the livestock diets are not impacted, and
the existing livestock commodity tolerances remain adequate.

IR-4 has submitted field trial data for three trials each for
pyraclostrobin in persimmon, in Belgium endive, and in globe artichoke
in the USA. At each persimmon and artichoke trial location, the treated
plots received three foliar directed applications of a 12.8% WDG
formulation (Pristine®) of pyraclostrobin at 0.19 lb ai/A, for a total
application rate of 0.55 lb ai/A.  The retreatment interval was 6 – 8
days.   Applications were made using ground equipment in spray volumes
of 10-75 gal/acre for artichoke and 55 – 97 gal/acre for persimmon.
Maturing commodities were present.  No adjuvants were used.   Samples of
mature commodities were taken at a PHI of 0 days.   For Belgium endive
(witloof chicory), two applications were made with a 12.8% WDG
formulation (Pristine®) of pyraclostrobin.  The first  was a broadcast
application to dormant chicory roots at a rate of 0.58 g ai/100 lbs of
root. The second was a broadcast application to roots packed in forcing
trays at budding stage at a rate of 0.092 g ai/ft2  or 8.8 lb ai/acre.
The PHI was 17 - 19 days for the pre-forcing application.

Residues (and per trial averages) of pyraclostrobin, BF 500-3, and
combined pyraclostrobin and BF 500-3 in/on artichoke flower heads
harvested at a 0-day PHI were 0.514-1.110 (0.618-1.045), <0.02-0.056
(<0.02-0.056), and <0.534-1.166 (<0.638-1.101) ppm, respectively.
Residues (and per trial averages) of pyraclostrobin, BF 500-3, and
combined pyraclostrobin and BF 500-3 in/on persimmon fruit harvested at
a 0-day PHI were 0.421-1.278 (0.092-1.155), <0.02-0.077 (<0.02-0.073),
and <0.103-1.355 (<0.112-1.228) ppm, respectively.  Following a
broadcast application of the 12.9% WDG formulation of pyraclostrobin to
post-dormancy chicory roots in packing trays, applied just before
forcing began, at 0.089-0.097 g ai/ft2 (treatment 03), residues (and per
trial averages) of pyraclostrobin and of combined pyraclostrobin and BF
500-3 in/on endive heads harvested at PHIs of 17-19-days were
0.1239-1.7620 (0.150-1.347) and <0.144-<1.782 (<0.170-<1.367) ppm,
respectively.  Residues were lower from a combined treatment of a single
broadcast application of the same formulation to dormant chicory roots
at 0.584-0.591 g ai/100 lb of roots, followed by a broadcast application
of the same formulation to post-dormancy chicory roots in packing trays,
applied just before forcing began at 0.092-0.101 g ai/ft2.

Analytical reference standards for pyraclostrobin and its regulated
metabolites are available at the EPA National Pesticide Standards
Repository.

Adequate confined, limited and extensive field rotational crop studies
are available supporting the existing tolerances for indirect residues
of pyraclostrobin in rotational crops.  These data support the 14-day
plant-back interval currently specified for crops without pyraclostrobin
uses.  No additional rotational crop data are required for purposes of
this petition.

Regulatory Recommendations and Residue Chemistry Deficiencies

HED  has examined the residue chemistry database for pyraclostrobin, and
there are no residue chemistry deficiencies that would preclude granting
Section 3 registration for the requested crop commodity uses of
pyraclostrobin, or establishment of tolerances for residues of
pyraclostrobin.  It is recommended that a tolerance be established for
residues of the fungicide pyraclostrobin, including its metabolites and
degradates, in or on globe artichoke at 3.0 ppm, in or on persimmon at
3.0 ppm, and in or on Belgium endive at 4.0 ppm.  Compliance with the
tolerance levels is to be determined by measuring only the sum of
pyraclostrobin (carbamic acid, [2-[[[1-(4-chlorophenyl)-1H-
pyrazol-3-yl]oxy]methyl]phenyl]methoxy-, methyl ester) and its
desmethoxy metabolite (methyl
N-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl carbamate),
calculated as the stoichiometric equivalent of pyraclostrobin.

The proposed updating of certain existing crop groups and the removal of
certain oilseed tolerances and certain previous crop group/subgroup
tolerances are acceptable.  However, an additional oilseed tolerance
will need to be removed, and IR-4 should request the following removal:
cotton undelinted cotton seed (0.3 ppm).

The Section 18 tolerance for Belgian endive should be removed concurrent
with the establishment of the Section 3 tolerance for Belgium endive

See Table 7 for details of the recommendations.

A human health risk assessment is forthcoming.

860.1200  Direction for Use

The proposed labels for Reg. No. 7969-199 (Pristine® fungicide), and
7969-187(Cabrio® EG fungicide)  provide directions for use on the low
growing berry subgroup.  Cranberry must be removed from the list of
crops.  The title “low growing berry subgroup” should be changed to
“low growing berry subgroup except cranberry.”

860.1550 Proposed Tolerances

The available data for Belgium endive will not support a tolerance level
of 3.0 ppm.  A revised Section F should be submitted with a tolerance
for endive, Belgium at 4.0  ppm. The existing tolerance for undelinted
cottonseed seed should be removed as it is replaced by the proposed and
recommended tolerance for oilseed group 20.  See Table 7.

	Background

Pyraclostrobin belongs to the strobilurin class of fungicides.
Strobilurins are synthetic analogs of a natural antifungal substance
which inhibits spore germination and mycelial growth and sporulation of
the fungus on the leaf surface.  The chemical structure and nomenclature
of pyraclostrobin are presented in Table 1.  The physicochemical
properties of the technical grade of pyraclostrobin are presented in
Table 2.

TABLE 1.	Test Compound Nomenclature.

Compound

Common name	Pyraclostrobin

Company experimental name	BAS 500 F

IUPAC name	methyl
2-[1-(4-chlorophenyl)pyrazol-3-yloxymethyl]-N-methoxycarbanilate

CAS name	methyl
N-[2-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl]-N-methoxyc
arbamate

CAS registry number	175013-18-0

End-use product (EP)	Headline® EC Fungicide, EPA Reg. No. 7969-186.

Cabrio® EG fungicide, EPA Reg. No. 7969-187

Pristine® fungicide, EPA Reg. No. 7969-199

,Headline® SC fungicide, EPA Reg. No 7969-289

TABLE 2.	Physicochemical Properties of Technical Grade Pyraclostrobin.

Parameter	Value	References1  (MRID)

Melting point/range	63.7-65.2ºC	45118213

pH	Not applicable

	Density	1.367 g/cm3 	45118214

Water solubility at 20 ºC	1.9 ±  0.17 mg/L (deionized water, pH 5.8)

	45118233

Solvent solubility	n-heptane (0.37 g/100mL);  2-propanol (3.0 g/100mL);
1-octanol (2.42 g/100mL);  olive oil (2.80 g/100m/L);  methanol  (10.08
g/100mL); >50 g/100mL in acetone, ethyl acetate , acetonitrile,
dichloromethane and toluene.	45118228

Vapor pressure	2.6 x 10-10 hPa at 20 ºC

	45118214

Dissociation constant, pKa	None (no dissociable moieties)

	Octanol/water partition coefficient, Log(KOW) at room temperature	3.990
mean log Pow; Pow is 9772

	45118215

UV/visible absorption spectrum	The structural identity of BAS 500 F was
confirmed by NMR and MS spectra. UV molecular extinction (e [1 mol-1
cm-1]): 2.5x104 at 205 nm; 2.4x104 at 275 nm.	1996/109552

1	Product Chemistry data were reviewed by the Registration Division (DP#
269848 and DP# 274191, 5/3/01, 5/15/01, and 6/7/01, S. Malak).

2	BASF  Document Number.

860.1200  Directions for Use

Proposed supplemental labels were provided for end use products 7969-186
(Headline® Fungicide), 7969-187 (Cabrio® EG fungicide) , 7969-199
(Pristine® fungicide), and 7969-289 (Headline® SC fungicide). Only
Pristine® fungicide is proposed for use on globe artichoke, persimmon,
and Belgium endive. The remaining labels are associated with crop group
conversions.

Pristine® contains two active ingredients, pyraclostrobin and boscalid.
 Only pyraclostrobin is considered in this document; boscalid is being
evaluated separately.

TABLE 3.  Summary of Proposed  Use Patterns of Pyraclostrobin.

Applic. Timing, Type, and Equip.	Formulation

[EPA Reg. No.]	Applic. Rate

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

(lb ai/A)	PHI

(days)	Use Directions and Limitations

Globe Artichoke

Foliar with ground equipment, aerial equipment, or sprinkler irrigation
12.8% Pristine® WG

7969-199	0.148- 0.184	3	0.55	0	Apply at 7-14 day intervals

Belgium Endive

Root spray-

(1)Pre-cold storage

(2) Forcing	12.8% Pristine® WG

7969-199	(1) 0.0064 – 0.0128 lb ai/1000 lbs root

(2) 0.0072 – 0.0144 lb ai/70 square feet forcing tray

[4.4 – 8. 9 lbs ai/acre]	1	0.0272 lb ai/1000 lbs root (approximate)	19
Make one application (1) to the roots when brought into cold storage
prior to forcing. Apply in 3.0 to 3.5 gals of water per 1000 lbs. root.
Make a second application (2) at the beginning of forcing after the
roots have been packed into forcing trays. Apply in about 100 fl ozs
water per 70 square feet of forcing tray.  A 70 square feet forcing tray
contains approximately 1000 lbs of roots.

Do not apply after the beginning of forcing.

Persimmon

Foliar with ground equipment, aerial equipment, or sprinkler irrigation
12.8% Pristine® WG

7969-199	0.148 – 0.184 	3	0.55	0	Apply at 7-14 day intervals

The proposed labels end use products7969-186 (Headline® Fungicide),
7969-187(Cabrio® EG fungicide) , 7969-199 (Pristine® fungicide), and
7969-289 (Headline® SC fungicide) include changes for crop
group/subgroup conversions.

.

Conclusions:  The submitted use directions are sufficient to allow for
evaluation of the submitted residue data relative to the proposed use
pattern for persimmon, Belgium endive, and globe artichoke.  The
proposed label changes related to crop group/subgroup conversions are
acceptable.

860.1300 Nature of the Residue - Plants

HED MARC, DP# 278044, L. Cheng, 10/9/01

PP#0F6139, DP# 269668, L. Cheng, 11/28/01

Adequate metabolism studies with pyraclostrobin on grapes, potatoes, and
wheat have been reviewed (D269668, 11/28/01, L. Cheng) in conjunction
with PP#0F06139.  The results of these studies indicate that the
metabolism of pyraclostrobin is similar in the three crops investigated.
 The HED Metabolism Assessment Review Committee (MARC) discussed the
results of these studies on 9/20/01, and concluded that the nature of
the residue in plants is understood.  For the purpose of tolerance and
risk assessment, the terminal residues of concern in plants consist of
pyraclostrobin and its desmethoxy metabolite (BF 500-3).

860.1300 Nature of the Residue – Livestock

HED MARC, DP# 278044, L. Cheng, 10/9/01

PP#0F6139, DP# 269668, L. Cheng, 11/28/01

The nature of the residue in livestock is adequately understood based on
acceptable ruminant and poultry metabolism studies.  In goat, the major
residues are pyraclostrobin and BF 500-3 in muscle and fat;
pyraclostrobin, BF 500-3, and BF 500-5 and its sulfate conjugate in
milk; pyraclostrobin, BF 500-3, and BF 500-5 and its sulfate conjugate,
and hydroxylated desmethoxy metabolite (500M67) in kidney; and
metabolites hydrolyzed to BF 500-5 and its hydroxylated compound (BF
500-8) in liver.  In poultry, the major residues are pyraclostrobin and
BF 500-3 in eggs; pyraclostrobin, BF 500-3, and hydroxylated BF 500-3
(500M64) in fat; and the glucuronic acid conjugate of hydroxylated BF
500-3 (500M32) in liver.  Radioactive residues were below detection in
muscle.  The main degradation reactions in livestock consist of
demethoxylation, hydroxylation, and conjugation, and breaking of the
ether bond.

HED  has determined that for the tolerance and risk assessment, the
residues of concern in livestock commodities consist of pyraclostrobin
and its metabolites convertible to 1-(4-chlorophenyl)-1H-pyrazol-3-ol
(BF 500-5) and 1-(4-chloro-2-hydroxyphenyl)-1H-pyrazol-3-ol (BF 500-8).

860.1340 Residue Analytical Methods

PP#0F6139, DP# 269668, L. Cheng, 11/28/01

PP#0F6139, DP# 269850, L. Cheng, 11/8/00

MRID: 48049201, W. Cutchin, in process

Enforcement:  Two adequate methods are available for enforcement
purposes for residues of pyraclostrobin and the metabolite BF 500-3
in/on plant commodities: an LC/MS/MS method (BASF Method D9908) and an
HPLC/UV method (Method D9904).  The validated method LOQ for both
pyraclostrobin and BF 500-3 is 0.02 ppm in all tested plant matrices,
for a combined LOQ of 0.04 ppm.  Adequate independent method validation
and radiovalidation data were submitted for both methods and forwarded
to Analytical Chemistry Branch/Biological and EconomicAnalysis Division
(ACB/BEAD) for a petition method validation.

388→194 for pyraclostrobin and m/z 358→164 for BF 500-3.

The LLMV in the studies was 0.02 ppm for each of pyraclostrobin and BF
500-3.  Concurrent recovery experiments were conducted at spiking levels
of 0.02 ppm and 2.0 ppm for each of pyraclostrobin and its metabolite
BF-500-3.   Concurrent recoveries from fortifications of artichoke
ranged from 73 98% for pyraclostrobin and from 70 – 101% for BF-500-3.
 Concurrent recoveries from fortifications of Belgium endive ranged from
78 – 97% for pyraclostrboin and from 86 – 97% for BF-500-3.
Concurrent recoveries from fortifications of persimmon ranged from 76
– 97% for pyraclostrobin and from 73 – 89% for BF-500-3.

Conclusions: There are adequate residue analytical methods for tolerance
enforcement and data collection.

860.1360 Multiresidue Methods

PP#0F6139, DP# 269668, L. Cheng, 11/28/01

Pyraclostrobin was successfully evaluated through several of the FDA
protocols, while recovery of BF 500-3 was unsuccessful in all protocols.
 Pyraclostrobin was completely recovered through Protocol D (in grape)
and E (in grape), and partially recovered through Protocol F (in
peanut).  Metabolite BF 500-3 had poor peak shape and inadequate
sensitivity with Protocol C columns, and therefore, was not further
analyzed under Protocol D, E, and F.  The results of the multiresidue
testing for pyraclostrobin were forwarded to FDA on 1/4/02 for the
purpose of updating the Pesticide Analytical Manual, Volume I (PAM I).

860.1380 Storage Stability

PP#0F6139, DP# 269668, L. Cheng, 11/28/01

Artichoke samples were stored frozen at <-5 °C from collection to
extraction for 628-644 days (20.6-21.2 months).  Samples were analyzed
within 0-1 days of extraction.  Belgium endive samples were stored
frozen (generally <-5 °C) from collection to extraction for 290-304
days (9.5-10.0 months).  Samples were analyzed within 0-2 days of
extraction.  Persimmon samples were stored frozen at <-5 °C from
collection to extraction for 532-560 days (17.5-18.4 months).  Samples
were analyzed within 0-1 days of extraction   Adequate storage stability
data are available demonstrating that residues of pyraclostrobin and its
metabolite BF 500-3 are stable under frozen conditions in/on fortified
samples of grape juice, sugar beet tops and roots, tomatoes, and wheat
grain and straw for up to 25 months, and in/on fortified samples of
peanut nutmeat and processed oil for up to 19 months.  It was concluded
that the plant commodities chosen for the storage stability study were
representative of all crops: an oilseed (peanut nutmeat), a non-oily
grain (wheat grain), a leafy vegetable (sugar beet tops), a root crop
(sugar beet roots), a fruit/fruiting vegetable (tomatoes), a dry feed
(wheat straw), and processed oil (peanut) and juice (grape) commodities
(DP#s 269668 etc., L. Cheng, 11/28/01).  These data are adequate to
support the storage conditions and durations of samples from the
submitted field trials.

Conclusions:  These data are adequate to support the storage conditions
and durations of samples from the artichoke, persimmon, and Belgium
endive studies.  No correction to residue values for loss during storage
are necessary.

860.1400 Water, Fish, and Irrigated Crops

This guideline requirement is not relevant to the current petitions as
there are no aquatic uses being proposed for pyraclostrobin.

860.1460 Food Handling

This guideline requirement is not relevant to the current petitions as
there are no food-handling uses being proposed for pyraclostrobin.

860.1480 Meat, Milk, Poultry, and Eggs

There are no feed items associated with the requested new uses
(artichoke, Belgium endive, persimmon).  The replacement of individual
oilseed tolerances with the oil seed crop group 20 tolerance effectively
raises the tolerance of undelinted cotton seed from 0.3 to 0.45 ppm.
This will have no effect on the calculated diets of livestock, which are
based on high residues from the field trials and processing studies.
Therefore, no new considerations are required for residues in meat,
milk, poultry, and eggs.

860.1500 Crop Field Trials

MRIDs: 48897401 - 48897403

Artichoke, Globe

A total of 3 crop field trials on artichoke (globe) were conducted in
the United States during the 2006 growing season in the North American
Free Trade Agreement (NAFTA) Growing Zone 10 (CA).  Each trial consisted
of one untreated (control) plot and one treated plot.  At each trial
location, the treated plots received three foliar directed applications
of the 12.8% WDG formulation of pyraclostrobin (Pristine®) during the
producing growth stage at rates of 0.178-0.188 lb ai/A/application
(0.199-0.211 kg ai/ha/application), for total seasonal rates of
0.549-0.562 lb ai/A (0.615-0.630 kg ai/ha).  Retreatment intervals
(RTIs) were 6-8 days.  Applications were made using backpack sprayers,
with CO2 as the propellant, in spray volumes of 10-75 gal/A of water
(94-702 L/ha), without any adjuvant.  Samples of mature artichoke buds
were harvested after the spray had dried following the final
application, reflecting a PHI of 0 days.

Following three foliar directed applications of the 12.8% WDG
formulation of pyraclostrobin at total rates of 0.549-0.562 lb ai/A,
residues (and per trial averages) of pyraclostrobin, BF 500-3, and
combined pyraclostrobin and BF 500-3 in/on artichoke flower heads
harvested at a 0-day PHI were 0.514-1.110 (0.618-1.045), <0.02-0.056
(<0.02-0.056), and <0.534-1.166 (<0.638-1.101) ppm, respectively.

Results are summarized in Table 4.

TABLE 4.	Summary of Residue Data from Globe Artichoke Crop Field Trials
with Pyraclostrobin.

Commodity	Total Applic. Rate

(lb ai/A)

[kg ai/ha]	PHI (days)	Analyte	Residue Levels1

 (ppm)

n	SampleMin.	Sample

Max.	LAFT2	HAFT2	Median	Mean	Std. Dev.

Artichoke Flower Head	0.549-0.562

(0.615-0.630)	0	Pyraclostro-bin	3	0.514	1.110	0.618	1.045	0.759	0.807
0.218

	BF 500-3	3	<0.02	0.056	<0.02	0.056	<0.028	<0.035	0.019

	Combined	3	<0.534	1.166	<0.638	1.101	<0.787	<0.842	0.236

1  Except for sample min/max, values reflect per trial averages; n = no.
of field trials.  For calculation of median, mean, and standard
deviation, the LLMV (0.02 ppm) was used for any results reported as
<LLMV in Table C.3.

2  LAFT = lowest average field trial; HAFT = highest average field
trial.

Conclusions:

The number and geographic distribution of the trials are adequate.  The
analytical method was demonstrated to be acceptable via concurrent
recoveries of fortified control samples.  The intervals of frozen
storage of samples are covered by previous storage stability studies,
and no corrections for loss of residue are needed.  The trials were
conducted according to the proposed label for the WG formulation (single
and seasonal application rates, PHI).  The results of the field trials
are acceptable for estimation of an artichoke tolerance and for dietary
risk assessment purposes.

Belgium endive (witloof chicory)

A total of 3 crop field trials on endive were conducted in the United
States during the 2008 growing season in NAFTA Growing Zone 10 (CA).

Endive is not grown in plots; all treatments occurred indoors.  The
production of Belgium endive requires the growing of a crop of chicory
plants in the field, harvesting the roots, and placing the chicory roots
in cold storage to break dormancy, which can occur in as little as one
week.  After dormancy is broken, the roots are packed in a tray standing
vertically, and the tray is placed in a forcing room, which is dark,
cool and moist.  Belgium endive heads then develop on the roots within
approximately 17 to 19 days.

Each trial for this study consisted of one untreated (control) group
(treatment 01) and three separate treatment groups (treatments 02, 03,
and 04).  Broadcast spray applications were made in two different ways.
In Treatment 02, dormant roots (before being placed into cold storage)
were sprayed as they passed by the sprayer on a conveyer belt.  For this
treatment, the rate of application was reported as the amount of product
applied per pound of roots.  In Treatment 03, roots were sprayed after
they had been broken from dormancy, removed from cold storage, and
packed vertically into forcing trays.  After they were sprayed, they
were placed into a forcing room.  For this treatment, the rate of
application was reported as the amount of product applied per ft2 of
sprayed trays.  Treatment 04 was a combination of the treatment 02 and
03 scenarios. All applications were made using a 12.9% water dispersible
granule (WDG) formulation of pyraclostrobin (Pristine®).  Samples of
mature endive heads were harvested at preharvest intervals (PHIs) of
25-27 days for treatment 02 and of 17-19 days for treatments 03 and 04.

Following a single broadcast application of a 12.9% WDG formulation of
pyraclostrobin to dormant chicory roots at 0.578-0.597 g ai/100 lb of
roots (treatment 02), residues (and per trial averages) of
pyraclostrobin and of combined pyraclostrobin and BF 500-3 in/on endive
heads harvested at PHIs of 25-27-days were <0.02-0.0679 (<0.023-0.059)
and <0.04-<0.088 (<0.043-<0.079) ppm, respectively.  Following a
broadcast application of the same formulation to post-dormancy chicory
roots in packing trays, applied just before forcing began, at
0.089-0.097 g ai/ft2 (treatment 03), residues (and per trial averages)
of pyraclostrobin and of combined pyraclostrobin and BF 500-3 in/on
endive heads harvested at PHIs of 17-19-days were 0.1239-1.7620
(0.150-1.347) and <0.144-<1.782 (<0.170-<1.367) ppm, respectively.
Following the combined treatment (treatment 04) of a single broadcast
application of the same formulation to dormant chicory roots at
0.584-0.591 g ai/100 lb of roots, followed by a broadcast application of
the same formulation to post-dormancy chicory roots in packing trays,
applied just before forcing began, at 0.092-0.101 g ai/ft2, residues
(and per trial averages) of pyraclostrobin and of combined
pyraclostrobin and BF 500-3 in/on endive heads harvested at PHIs of
17-19-days were 0.2250-0.8710 (0.256-0.771) and <0.245-<0.891
(<0.276-<0.791) ppm, respectively.  No residues of metabolite BF 500-3
were found at or above the LLMV (0.02 ppm) in/on endive heads harvested
following any of the three treatments.

The results are summarized in Table 5.

TABLE 5

 Summary of Residue Data from Belgium Endive Crop Field Trials with
Pyraclostrobin.

Com-modity	Rate1	PHI (days)	Analyte	Residue Levels2

(ppm)

n	SampleMin.	Sample

Max.	LAFT3	HAFT3	Median	Mean	Std. Dev.

Treatment 02: One pre-cold-storage application to roots

Belgium endive heads	0.578-0.597 g ai/100 lb of roots	25-27
Pyraclostro-bin	3	<0.02	0.0679	<0.023	0.059	<0.040	<0.041	0.018

	BF 500-3	3	<0.02	<0.02	<0.02	<0.02	<0.02	<0.02	N/A

	Combined	3	<0.04	<0.088	<0.043	<0.079	<0.06	<0.061	0.018

Treatment 03: One pre-forcing application to roots in packing tray

Belgium endive heads	0.089-0.097 g ai/ft2	17-19	Pyraclostro-bin	3	0.1239
1.7620	0.150	1.347	0.900	0.799	0.605

	BF 500-3	3	<0.02	<0.02	<0.02	<0.02	<0.02	<0.02	N/A

	Combined	3	<0.144	<1.782	<0.170	<1.367	<0.920	0.819	0.605

Treatment 04: One pre-cold-storage application to roots + One
pre-forcing application to roots in packing tray

Belgium endive heads	0.584-0.591 g ai/100 lb of roots and3

0.092-0.101 g ai/ft2	17-19	Pyraclostro-bin	3	0.2250	0.8710	0.256	0.771
0.551	0.526	0.258

	BF 500-3	3	<0.02	<0.02	<0.02	<0.02	<0.02	<0.02	N/A

	Combined	3	<0.245	<0.891	<0.276	<0.791	<0.571	<0.546	0.258

1  Rate for pyraclostrobin, as calculated by the study reviewer based on
the certificate of analysis of applied product in the study report.

2  Except for sample min/max, values reflect per trial averages; n = no.
of field trials.  For calculation of median, mean, and standard
deviation, the LLMV (0.02 ppm) was used for any results reported as
<LLMV in Table C.3.  N/A = Not Applicable.

3  LAFT = lowest average field trial; HAFT = highest average field
trial.

Conclusions:

The number and geographic distribution of the trials are adequate.  The
analytical method was demonstrated to be acceptable via concurrent
recoveries of fortified control samples.  The intervals of frozen
storage of samples are covered by previous storage stability studies,
and no corrections for loss of residue are needed.  The trials were
conducted according to the proposed label for the WG formulation (single
and seasonal application rates, PHI).  The trials were pre-forcing stage
treatment only (treatment 3) yielded commodities with  higher residues
than the combined pre-cold storage treatment and pre-forcing stage
treatment (treatment 4).   The results of the field trials are
acceptable for estimation of a Belgium endive tolerance and for dietary
risk assessment purposes.

Persimmon

A total of 3 crop field trials on persimmon were conducted in the United
States during the 2006 growing season in North American Free Trade
Agreement (NAFTA) Growing Zones 3 (FL), 10 (CA), and 13 (HI).

Each trial consisted of one untreated (control) plot and one treated
plot.  At each trial location, the treated plots received three foliar
directed applications of the 12.8% water dispersible granule (WDG)
formulation of pyraclostrobin (Pristine®) during the fruiting stage at
rates of 0.185-0.199 lb ai/A/application (0.207-0.223 kg
ai/ha/application), for total seasonal rates of 0.564-0.573 lb ai/A
(0.632-0.642 kg ai/ha).  Retreatment intervals (RTIs) were 7-8 days.
Applications were made using a backpack sprayer, a tractor-mounted
sprayer, or a Mistblower sprayer in spray volumes of 55-97 gal/A of
water (514-907 L/ha), without any adjuvant.  Samples of commercially
mature persimmon fruit were harvested after the spray had dried
following the final application, reflecting a preharvest interval (PHI)
of 0 days.

Following three foliar directed applications of the 12.8% WDG
formulation of pyraclostrobin at total rates of 0.564-0.573 lb ai/A,
residues (and per trial averages) of pyraclostrobin, BF 500-3, and
combined pyraclostrobin and BF 500-3 in/on persimmon fruit harvested at
a 0-day PHI were 0.421-1.278 (0.092-1.155), <0.02-0.077 (<0.02-0.073),
and <0.103-1.355 (<0.112-1.228) ppm, respectively.  There was no residue
decline study.

Results are summarized in Table 6.

TABLE 6.	Summary of Residue Data from Persimmon Crop Field Trials with
Pyraclostrobin.

Commodity	Total Applic. Rate

(lb ai/A)

[kg ai/ha]	PHI (days)	Analyte	Residue Levels1

 (ppm)

n	SampleMin.	Sample

Max.	LAFT2	HAFT2	Median	Mean	Std. Dev.

Persimmon Fruit	0.564-0.573

(0.632-0.642)	0	Pyraclostro-bin	3	0.421	1.278	0.092	1.155	0.437	0.561
0.542

	BF 500-3	3	<0.02	0.077	<0.02	0.073	<0.02	<0.038	0.031

	Combined	3	<0.103	1.355	<0.112	1.228	<0.457	<0.599	0.571

1  Except for sample min/max, values reflect per trial averages; n = no.
of field trials.  For calculation of median, mean, and standard
deviation, the LLMV (0.02 ppm) was used for any results reported as
<LLMV in Table C.3.  N/A = Not Applicable.

2  LAFT = lowest average field trial; HAFT = highest average field
trial.

Conclusions:

The number and geographic distribution of the trials are adequate.  The
analytical method was demonstrated to be acceptable via concurrent
recoveries of fortified control samples.  The intervals of frozen
storage of samples are covered by previous storage stability studies,
and no corrections for loss of residue are needed.  The trials were
conducted according to the proposed label for the WG formulation (single
and seasonal application rates, PHI).  The results of the field trials
are acceptable for estimation of a persimmon tolerance and for dietary
risk assessment purposes.

860.1520 Processed Food and Feed

PP#0F6139, DP# 269668, L. Cheng, 11/28/01

MRID 48237401

No processing studies were submitted.  None are necessary for persimmon,
globe artichoke, or Belgium endive (witloof chicory).

860.1650 Submittal of Analytical Reference Standards

Analytical standards for pyraclostrobin and regulated metabolites (BF
500-3; BF 500-5; BF 500-8) are currently available in the EPA National
Pesticide Standards Repository (e-mail correspondence with T. Cole,
01/14/2013).

860.1850 Confined Accumulation in Rotational Crops

MARC, DP# 278044, L. Cheng, 10/9/01

PP#0F6139, DP# 269668, L. Cheng, 11/28/01

An adequate confined rotational crop study was reviewed in PP#0F6139.
The study showed that the metabolism of pyraclostrobin in rotated crops
is similar but more extensive than that in primary crops.
Pyraclostrobin undergoes demethoxylation to yield BF 500-3, followed by
further degradation to medium polar and polar metabolites, and
subsequent conjugation reactions and incorporation into natural
products.  The HED MARC has determined that the residues of concern in
rotational crops consist of pyraclostrobin and metabolite BF 500-3.

860.1900 Field Accumulation in Rotational Crops

PP#0F6139, DP# 269668, L. Cheng, 11/28/01

A limited field rotational crop study was reviewed in PP#0F6139.  The
results indicate that r  SEQ CHAPTER \h \r 1 esidues of pyraclostrobin
and its metabolite BF 500-3 were each less than the method LOQ (<0.02
ppm) in/on rotational crop matrices (radish, roots and tops; cabbage,
with and without wrapper leaves; and wheat forage, hay, and grain)
planted 14 days following the last of six sequential foliar applications
to the primary crop, cucumbers, of the 2 lb/gal EC formulation at 0.19 -
0.20 lb ai/A/application.  Residues of pyraclostrobin in/on one sample
of wheat straw from the CA test site were at the LOQ (0.02 ppm), but
residues of pyraclostrobin in/on a replicate sample from the same plot
were below the LOQ (0.012 ppm) for an average residue of <0.02 ppm.
Residues of metabolite BF 500-3 were nondetectable (<0.02 ppm) in/on all
samples of wheat straw.

The registered pyraclostrobin end-use product labels presently specify a
14-day plantback interval restriction for all crops that are not
registered.

860.1550 Proposed Tolerances

For the use of pyraclostrobin on globe artichoke, Belgium endive, and
persimmon, tolerances are required.   Based on evaluation of the field
trial data with the Organization of Economic Cooperation and Development
(OECD) tolerance calculation procedure (Appendix I), the tolerances
listed in Table 7 are appropriate.

Codex MRLs have been established for pyraclostrobin in/on globe
artichoke at 2 ppm.  The recommended US tolerance is 3 ppm.  Residue
definitions are different in the US and in Codex, and the US tolerance
is based on application of the OECD calculation procedure to the
validated field trial data.  The tolerance cannot be lowered to the
Codex level as this could result in apparent violations for crops
treated in accordance with the label.  Canada does not have
pyraclostrobin tolerances for globe artichoke, Belgium endive, or
persimmon. Therefore, there is no issue of harmonization with Canada.

Several crop group conversions were requested.  Most were crop group
updates. One request was to replace individual oilseed tolerances with
an oilseed crop group 20 tolerance. This was accompanied by a request to
remove numerous individual commodity oilseed tolerances.  These changes
have been made to the proposed labels. In addition to the requested
removals, the tolerance for cotton undelinted seed will be replaced by
oilseed, group 20, and IR-4 needs to make this request. The tolerance
covering undelinted cotton seed is raised from 0.3 ppm to 0.45 ppm.
This is acceptable as cottonseed is one of the three representative
commodities for the oilseed group (cottonseed, rapeseed, sunflower), and
the highest estimate from the three commodities is adopted for the
group. The changes are acceptable, as detailed in Table 7.

Table  7		Tolerance Summary for Pyraclostrobin.

Commodity	Proposed/Existing Tolerance (ppm)	Recommended/ Harmonized
Tolerance (ppm)	Comments; Correct Commodity Definition

40CFR§180.582(a) It is recommended that a tolerance be established for
residues of the fungicide pyraclostrobin, including its metabolites and
degradates, as indicated below. .  Compliance with the tolerance levels
is to be determined by measuring only the sum of pyraclostrobin
(carbamic acid, [2-[[[1-(4-chlorophenyl)-1H-
pyrazol-3-yl]oxy]methyl]phenyl]methoxy-, methyl ester) and its
desmethoxy metabolite (methyl
N-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl carbamate),
calculated as the stoichiometric  equivalent of pyraclostrobin

Artichoke, globe	3.0	3.0

	Endive, Belgium	3.0	4.0	OECD statistical calculation estimates  4.0
ppm.

Persimmon	3.0	3.0

	Vegetable, bulb, group 3-07	0.9	0.9	Group update

Vegetable, bulb, group 3	0.9	Remove	Group update

Vegetable, fruiting, group 8-10	1.4	1.4	Group update

Vegetable, fruiting, group 8	1.4	Remove	Group update

Fruit, citrus, group 10-10	2.0	2.0	Group update

Fruit, citrus, group 10	2.0	Remove	Group update

Fruit, pome, group 11-10	1.5	1.5	Group update

Fruit, pome, group 11	1.5	Remove	Group update

Oilseed group 20	0.45	0.45	Group creation.

Cotton, undelinted seed	0.3	Remove	To be replaced by oilseed, group 20.
IR-4 needs to request this removal.

Borage, seed	0.45	Remove	To be replaced by oilseed, group 20.

Castor oil plant, seed	0.45	Remove	To be replaced by oilseed, group 20.

Chinese tallowtree, seed	0.45	Remove	To be replaced by oilseed, group
20.

Crambe, seed	0.45	Remove	To be replaced by oilseed, group 20.

Cuphea, seed	0.45	Remove	To be replaced by oilseed, group 20.

Echium, seed	0.45	Remove	To be replaced by oilseed, group 20.

Euphorbia, seed	0.45	Remove	To be replaced by oilseed, group 20.

Evening primrose, seed	0.45	Remove	To be replaced by oilseed, group 20.

Flax, seed	0.45	Remove	To be replaced by oilseed, group 20.

Gold of pleasure, seed	0.45	Remove	To be replaced by oilseed, group 20.

Hare's ear mustard, seed	0.45	Remove	To be replaced by oilseed, group
20.

Jojoba, seed

	0.45	Remove	To be replaced by oilseed, group 20.

Lesquerella, seed	0.45	Remove	To be replaced by oilseed, group 20.

Lunaria, seed	0.45	Remove	To be replaced by oilseed, group 20.

Meadowfoam, seed	0.45	Remove	To be replaced by oilseed, group 20.

Milkweed, seed	0.45	Remove	To be replaced by oilseed, group 20.

Mustard, seed	0.45	Remove	To be replaced by oilseed, group 20.

Niger seed, seed	0.45	Remove	To be replaced by oilseed, group 20.

Oil radish, seed	0.45	Remove	To be replaced by oilseed, group 20.

Poppy, seed	0.45	Remove	To be replaced by oilseed, group 20.

Rapeseed, seed	0.45	Remove	To be replaced by oilseed, group 20.

Rose hip, seed	0.45	Remove	To be replaced by oilseed, group 20.

Safflower, seed	0.45	Remove	To be replaced by oilseed, group 20.

Stokes aster, seed	0.45	Remove	To be replaced by oilseed, group 20.

Sunflower, seed	0.45	Remove	To be replaced by oilseed, group 20.

Sweet rocket, seed	0.45	Remove	To be replaced by oilseed, group 20.

Tallowwood, seed	0.45	Remove	To be replaced by oilseed, group 20.

Tea oil plant, seed	0.45	Remove	To be replaced by oilseed, group 20.

Vernonia, seed	0.45	Remove	To be replaced by oilseed, group 20.

Caneberry subgroup 13-07A	4.0	4.0	Group update

Bushberry subgroup 13-07B	4.0	4.0	Group update

Small fruit, vine climbing subgroup (except fuzzy kiwi) 13-07F	2.0	2.0
Group update

Low growing berry subgroup 13-07G except cranberry	1.2	1.2	Group update

Berry, group 13	4.0	Remove	Group update.  Replaced with subgroups 13-07A
and 13-07B

Grape	2.0	Remove	Group update.  Replaced with subgroup 13-07F

Strawberry	1.2	Remove	Group update.  Replaced with subgroup 13-07G

40CFR§180.582(b) Section 18 emergency exemptions

Endive, Belgian	11.0	Remove	Replaced with Section 3 tolerance for
endive, Belgium

References

DP#s:	367409

Subject:	Pyraclostrobin.  Petition for New Uses and Tolerances on
Alfalfa.  Summary of Analytical Chemistry and Residue Data.

From:	W. Cutchin

To:	T. Kish/J. Bazuin

Dated:	10/19/09

MRIDs:	47584401

DP#s:	281042, 286732, 287729, 288459, 290342, 290343, 290369, 292440,
293088, 293684, 295893, 298178

Subject:	Pyraclostrobin.  PP#3F06581, 2F06431, 2E6473, 3E6548, 3E6553,
3E6774, and 2F06139.  Petitions for the establishment of permanent
tolerances to allow uses on corn (field, sweet, and pop), hops, mint,
pome fruits, edible-podded legume vegetables, succulent peas, sunflower,
Brassica leafy greens, soybeans, succulent beans, broccoli, cabbage,
lettuce (head and leaf), spinach, celery, turnip greens, and the import
commodities mango and papaya.  Application for amended Section 3
registration for citrus (reduced PHI).  Petitioner’s response to data
deficiencies identified in PP#0F06139 regarding storage stability data,
dried shelled peas and beans (reduced PHI), and uses on dry and
succulent peas.  Summary of Analytical Chemistry and Residue Data.

From:	L. Cheng

To:	C. Giles-Parker/J. Bazuin

Dated:	7/26/04

MRIDs:	45596211, 45623406, 45623407, 45623408, 45623410, 45645801,
45645802, 45645803, 45645804, 45702901, 45765401, 45832001, 45858801,
45858802, 45903601, 45903602, 46033901-04, 46084401-04, 46109101,
46109102

DP#s:	269668, 272771, 272789, 274095, 274192, 274471, 274957, 275843,
and 278429

Subject:	PP#0F06139.  Pyraclostrobin on Various Crops:  Bananas
(import), Barley, Berries, Bulb Vegetables, Citrus Fruits, Cucurbit
Vegetables, Dried Shelled Pea & Bean (except Soybean), Fruiting
Vegetables, Grapes, Grass, Peanut, Pistachio, Root Vegetables (except
Sugar Beet), Rye, Snap Beans, Stone Fruits, Strawberry, Sugar Beet, Tree
Nuts, Tuberous and Corm Vegetables, and Wheat.  Review of Analytical
Methods and Residue Data.

From:	L. Cheng

To:	C. Giles-Parker/J. Bazuin

Dated:	11/28/01

MRIDs:	45118428-451184-37, 45118501-45118512, 45118514-45118537,
45118601-45118625, 45160501, 45272801, 45274901, 45321101, 45367501,
45399401, and 45429901

DP#:	278044

Subject:	PP# 0F06139.  PC Code 099100.  Pyraclostrobin.  Outcome of the
HED Metabolism Assessment Review Committee (MARC) Meeting Held on
September 20, 2001.

From:	L. Cheng

To:	Y. Donovan

Dated:	10/09/01

MRIDs:	None

DP#:	269850

Subject:	PP# 0F06139.  Pyraclostrobin (BAS 500F) in or on Various Crops.
Request for Tolerance Method Validation (TMV) Trial.

From:	L. Cheng

To:	F. D. Griffith, Jr.

Dated:	11/8/00

MRIDs:	45118505, 45118504, 45118509, 45118510, 45118501, 45118503,
45118507, 45118514

DP#:	281042, 286732, 287729, 288459, 290342, 290343, 290369, 292440,
293088, 293684, 295893, 298178

Subject:	Pyraclostrobin.  PP#3F06581, 2F06431, 2E6473, 3E6548, 3E6553,
3E6774, and 2F06139.  Petitions for the establishment of permanent
tolerances to allow uses on corn (field, sweet, and pop), hops, mint,
pome fruits, edible-podded legume vegetables, succulent peas, sunflower,
Brassica leafy greens, soybeans, succulent beans, broccoli, cabbage,
lettuce (head and leaf), spinach, celery, turnip greens, and the import
commodities mango and papaya.  Application for amended Section 3
registration for citrus (reduced PHI).  Petitioner’s response to data
deficiencies identified in PP#0F06139 regarding storage stability data,
dried shelled peas and beans (reduced PHI), and uses on dry and
succulent peas.  Summary of Analytical Chemistry and Residue Data.

From:	L. Cheng

To:	Cynthia Giles-Parker

Dated:	7/26/04

MRIDs:	45596211, 45623406, 45623407, 45623408, 45623410, 45645801,
45645802, 45645803, 45645804, 45702901, 45765401, 45832001, 45858801,
45858802, 45903601, 45903602, 46033901-04, 46084401-04, 46109101,
46109102

International Residue Limits

Pyraclostrobin (099100; 02/19/2013)

Summary of US and International Tolerances and Maximum Residue Limits

Residue Definition:

US	Canada	Mexico2	Codex3

40 CFR §180.582.  Plants:  Tolerances are established for residues of
the fungicide pyraclostrobin, including its metabolites and degradates.
Compliance with the tolerance levels is to be determined by measuring on
the sum of pyraclostrobin (carbamic acid, [2-[[[1-(4-chlorophenyl)-1H-
pyrazol-3-yl]oxy]methyl]phenyl]methoxy-, methyl ester) and its
desmethoxy metabolite (methyl
N-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl carbamate),
calculated as the stoichiometric  equivalent of pyraclostrobin	methyl
[2-[[[1-(4-chlorophenyl)-1H-pyrazol-3-yl]oxy]methyl]phenyl]methoxycarbam
ate, including the metabolite [2-[[[1-(4-chlorophenyl)-1H-pyrazol-3-

yl]oxy]methyl]phenyl]carbamate	-	Pyraclostrobin.  Residue is NOT fat
soluble.

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

	US	Canada	Mexico2	Codex3

Artichoke, globe	3.0	None

2.

Belgium endive

(witloof chicory)	4.0	None

None

Persimmon	3.0	None

None

1 Includes only commodities of interest for this action.  Tolerance
values should be the HED recommendations and not those proposed by the
applicant.

2 Mexico adopts US tolerances and/or Codex MRLs for its export purposes.

3 * = absent at the limit of quantitation; Po = postharvest treatment,
such as treatment of stored grains.  PoP = processed postharvest treated
commodity, such as processing of treated stored wheat. (fat) = to be
measured on the fat portion of the sample. MRLs indicated as proposed
have not been finalized by the CCPR and the CAC.

Appendix I:  Determination of Tolerance for Pyraclostrobin in/on
Sugarcane and Its Processed Fractions

The Organization for Economic Cooperation and Development statistical
procedure was used to calculate tolerances for artichoke, Belgium
endive, and persimmon.   The estimates agree with the proposals of IR-4
for persimmon and artichoke.  For Belgium endive, the IR-4 tolerance
estimate is 3.0 ppm from application before cold storage and again at
pre-forcing.  However, the single application at pre-forcing yielded
higher residues, and these data were used to derive the tolerance
estimate of 4.0 ppm.  The average combined residue of pyraclostrobin and
BF 500-3 from each trial (n = 3)was used as the calculator entry value.

Pyraclostrobin		DP 410737

ഀࣆȀỰ⒐싁摧㾔Ñ	̀Ĥ␱愁Ĥ摧烴¥

hSJ

hSJ

h[

5

6

?

C

E

F

M

R

[

f

h

i

6

D

E

R

h

h

i

¡

i

p

s

˜

Ÿ

¡

¥

¹

Ä

Å

Æ

Ì

Ø

á

è

é

ì

 ¡

¹

Æ

ê

(

N

u

v

w

‰

Š

萏֠萑褐葞֠葠褐摧ⲅN᠀ì

'

v

w

hSJ

hSJ

hSJ

"w

‰

Š

‹

Ÿ

³

Ô

Õ

î

ï

hSJ

h

 h

h

 h

h

  h

h

h

@

@

 hë

H*

@

$

ô

ô

$

$

h

$

$

$

ô

$

$

ô

gd""

gd""

 h

h""

 h

 h

!

h""

h

h©

h""

h""

h""

h""

h""

$

1$gd""

 h

h$

h

@

gd

h

@

hh0

̆

̆

gdG

̆

gdG

̆

gdG

̆

gdG

̆

̆

̆

gdG

̆

gdG

̆

gdG

̆

gdG

gdG

gdG

ytG

ytG

ytG

ytG

 h

gdq

¶

ytq

gdq

gdq

¶

ytq

”ÿô

¶

ytq

gdq

gdq

gdq

gdq

¶

ytq

¶

ytq

gdq

 of   NUMPAGES   22


MEMORANDUM
TO: 		Air and Radiation Docket EPA-HQ-OAR-2015-0091
FROM: 	EPA Office of Transportation and Air Quality
DATE:		March 11, 2015
SUBJECT: 	Supporting Documentation for Pennycress Cultivation Emissions

The document "Pennycress data and calculations  -  for docket.xlsx" contains data and calculations used in the analysis of greenhouse gases attributable to the production of pennycress oil, including:
   * Assumptions about fertilizer use and other inputs for growing pennycress, and calculations of the greenhouse gas emissions from these inputs.

   There is currently limited published data on the optimal amount of fertilizer appropriate for pennycress production.  Therefore, we used a range of fertilizer inputs.  Some sources suggest that minimal fertilizers would be needed for pennycress.[,][,]  Therefore, we used zero fertilizer application rates for nitrogen, phosphorus, and potassium as a lower bound for our greenhouse gas estimates.

   As the upper bound of our greenhouse gas estimate of nitrogen inputs, we used 50 lbs/acre.  This assumption is based on a study that suggests that a nitrogen input of 50 lb/acre, split between the spring and fall, is optimal for pennycress.  This study tested fertilizer inputs between 0 and 125 lb N/acre in a growth chamber experiment, and 0 and 100 lb N/acre in a field experiment.  In the growth chamber experiment, the seed yield for 50 lb N/acre was higher than when lower inputs were used, but fertilizer inputs above 50 lb N/acre did not increase the yield.  In the field experiment, inputs of 75 and 100 lb N/acre did not result in seed yields that were significantly higher than the seed yield when 50 lb N/acre was split between the fall and spring.  Therefore, the study concluded that 50 lb N/acre, split between the fall and spring, was likely the optimal nitrogen input.  A nitrogen input of 50 lb/acre is lower than the nitrogen removal for one acre of pennycress production (for 2000 lb pennycress seed per acre, 76 lbs nitrogen are removed from the soil).  However, pennycress will also use the residual nitrogen in the soil from planting corn.[3]

   As the upper bound of our greenhouse gas estimate of phosphorus and potassium inputs, we used 20 lbs/acre each, as recommended by USDA.  These values are supported by a study that calculated the phosphorus and potassium inputs needed to exactly replace the nutrients removed from the field by harvesting pennycress.[5]  Using their phosphorus and potassium content of pennycress, and our yield of 1800 lbs pennycress seed/acre, we calculated a phosphorus input of around 35 lbs/acre and a potassium input of around 25 lbs/acre.  However, this study is based on calculated values rather than actual farming practices.  The study that looked at nitrogen inputs for pennycress did not mention phosphorus or potassium inputs, which suggests that the researchers did not believe additional phosphorus or potassium would be needed to increase yields.  Input from industry suggests that one of the benefits of growing pennycress as a winter cover crop is that it uses the existing nitrogen and phosphorus available in the soil after corn plantings to reduce nutrient runoff.[3]  Because pennycress is grown in rotation with corn and soybeans, it is likely that there would be excess phosphorus and potassium in the soil from these crops.  Therefore, we assumed slightly less phosphorus and potassium would be needed than calculated based on an exact replacement of nutrients.

   * Pennycress yield

   * Conversion factors

   * Calculations of the N2O emissions from fertilizer and crop residues, for pennycress and soybeans.

   Equations for direct and indirect emissions from these sources are from the Intergovernmental Panel on Climate Change.  To calculate the amount of crop residues from pennycress, and the nitrogen content of these crop residues, we used data on canola as a substitute for pennycress, because data on pennycress were not available, and both canola and pennycress are oilseed plants in the Brassicaceae family.  The nitrogen fertilizer application rates for soybeans are based on regional application rates used in the FASOM model.  These application rates are documented in the Final RFS2 Rulemaking Docket: EPA-HQ-OAR-2005-0161-3178.

   * Net returns for growing pennycress

   Planting, harvesting, and price per pound of pennycress seed were based on information from the petitioner.  The petitioner also provided information on the amount of seed that would need to be planted (lbs/acre) for yields of 1500 lbs seed/acre and 2500 lbs seed/per acre.  We interpolated these values to get the amount of seed that would need to be planted for a yield of 1800 lbs/acre.

   We have also received information from industry that suggests that farmers will be compensated $0.06/lb of pennycress, with industry paying for the seed, fertilizers, planting, harvesting, and transportation.[3]  At yields of 1800 lbs/acre, this translates to a return of $108/acre, which is similar to our calculated return of $121/acre using data from the petitioner.

   * Energy inputs and greenhouse gas emissions from extracting oil from pennycress seeds