![](media/image1.png){width="0.7993055555555556in" height="0.8in"}

**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY**

WASHINGTON, D.C. 20460

OFFICE OF

PREVENTION, PESTICIDES

AND TOXIC SUBSTANCES

**[MEMORANDUM]{.underline}**

Date: 05/12/08

Subject: Ethoprop. Petition for Registration of Uses on Mint and Hops.
Summary of Analytical Chemistry and Residue Data.

  ----------------------------------- -----------------------------------
  **PC Code:** 041101                 **DP Barcode:** 352231 and 352233

  **Decision No.:** 382076, 299884    **Registration No.:** 264-458,
                                      264-457, and 264-469

  **Petition No.:** 5E4491 and 7E7247 **Regulatory Action:** New
                                      Registration/Tolerance

  **Risk Assessment Type:** N/A       **Case No.:** N/A

  T**XR No.:** N/A                    **CAS No.:** 13194-48-4

  **MRID No.:** 47194001, 43588801,   **40 CFR:** 180.262
  43588802                            
  ----------------------------------- -----------------------------------

From: Felecia Fort, Senior Chemist

Christine L. Olinger, Senior Chemist

Reregistration Branch I

Health Effects Division (7509P)

Through: Toiya Goodlow, Chemist

Reregistration Branch I

Health Effects Division (7509P)

Michael S. Metzger, Chief

Reregistration Branch I

Health Effects Division (7509P)

To: Susan Stanton

Risk Integration, Minor Use & Emergency Response Branch

Registration Division (7505P)

This document was originally prepared under contract by Dynamac
Corporation (1910 Sedwick Road, Building 100, Suite B, Durham NC 27713;
submitted 12/03/2007). The document has been reviewed by the Health
Effects Division (HED) and revised to reflect current Office of
Pesticide Programs (OPP) policies.

**Executive Summary**

Number range CHAPTEREthoprop \[*S,S*-dipropyl *O*-ethyl
phosphorodithioate\] is an organophosphate insecticide/nematicide
registered for use on a variety of crops for the control of soil pests.
Ethoprop is manufactured by Bayer CropScience under the trade name
MOCAP*^®^* and is formulated as either an emulsifiable concentrate (EC)
or a granule (G).

In the current petitions, Interregional Research Project No. 4 (IR-4) is
proposing the use of ethoprop as a 6 lb/gal EC formulation (EPA Reg. No.
264-458) on hops and mint and as a 15% G formulation (EPA Reg. No.
264-457) on mint. The proposed use on hops is for a single broadcast or
banded soil application at up to 3.0 lb ai/A. Applications to new hop
plantings can be made pre-plant or preemergence, and applications to
established hop yards can be made either early in the season, prior to
stringing vines, or after vine harvest. The proposed preharvest interval
(PHI) is 90 days for hops. The proposed use on mint is for a single
broadcast soil application at up to 6.0 lb ai/A, either preplanting to
new fields or after the final harvest of the season to established mint
fields. The proposed PHI is 225 days for mint. For both hops and mint,
only ground equipment is allowed for application, and ethoprop must be
incorporated into soil following application. In conjunction with these
uses, IR-4 is proposing the following permanent tolerances for ethoprop:

> Hop, dried cones 0.02 ppm
>
> Mint, hay 0.02 ppm

Permanent tolerances are established for residues of ethoprop *per se*
in/on a variety of plant commodities at 0.02 ppm.

Number range CHAPTERNumber range CHAPTERThe qualitative nature of the
residue in plants is adequately understood based on cabbage, corn, and
potato metabolism studies. HED concluded that for acute and chronic
non-cancer dietary risk, the residues of concern in crops are parent and
Metabolites II and III (S-ME and O-ME); for cancer dietary risk, the
residues of concern are parent and Metabolites II through IV (S-ME, O‑ME
and M-1).

The qualitative nature of the residue in livestock is adequately
understood based upon acceptable ruminant and poultry metabolism
studies. Residues of potential concern detected were Metabolites III
and/or IV, which together accounted for ≤2% of the total radioactive
residues in liver of hens and goats. As the proposed uses on hops and
mint do not include any regulated livestock feedstuffs, issues
pertaining to livestock metabolism, analytical methods and storage
stability data for animal commodities, and residues in livestock
commodities are not relevant to the current petitions.

Adequate analytical methodology is available for enforcing tolerances of
ethoprop as currently defined. Two Gas Chromatography (GC)/sulfur
microcoulometric detection methods are available in PAM, Vol. II (Method
I and A), which both involve solvent extraction and clean-up by sweep
co-distillation. The reported limit of quantitation (LOQ) for most
commodities is 0.01 ppm for these methods. Another GC/flame photometric
detection (FPD) method has also been proposed for determining residues
of ethoprop and Metabolite IV in plant commodities. For this method,
residues are extracted with methanol and cleaned up using cation
exchange resin and nuchar/attaclay, and residues of Metabolite IV are
methylated with diazomethane. Residues are then partitioned into
methylene chloride, further cleaned up using gel permeation and/or
silica gel chromatography, and determined using GC/FPD in the phosphorus
mode. The LOQ is 0.01 ppm each for ethoprop and Metabolite IV in plant
commodities. This method has been adequately validated by an independent
laboratory, but has never undergone a petition method validation by the
Agency.

In the mint field trials and processing study, residues of ethoprop and
Metabolite IV were determined using a version of the above proposed
GC/FPD enforcement method. The method was adequately validated in
conjunction with the analysis of field trial and processing study
samples, and the validated LOQ for residues of ethoprop and Metabolite
IV was 0.01 ppm in mint commodities.

In the hop field trials, residues of ethoprop and Metabolites II, III
and IV were determined using a GC/FPD method that was derived from the
proposed GC/FPD enforcement method. For this method, residues were
extracted with methanol, cleaned up using SCX and Nexus solid-phase
extraction (SPE) cartridges, and partitioned into ethyl acetate.
Residues of Metabolite IV were ethylated using diazoethane, and all
residues then were cleaned up by NH~2~ SPE and determined by GC/FPD in
the phosphorous mode. The validated LOQ for ethoprop and each metabolite
was 0.02 ppm in dried hops. This method was adequately validated in
conjunction with the analysis of hops field trial samples.

Adequate storage stability data are available to support the mint and
hop field trials. The data indicate that ethoprop and Metabolite IV are
stable under the conditions and durations of sample storage in the mint
field trials and processing study. The data also indicate that ethoprop
and Metabolites II and III are stable under the conditions and durations
of sample storage in the hops field trials; however, Metabolite IV was
shown to degrade in dried hops stored at -20ºC. Therefore, the residue
data on Metabolite IV in hops were corrected to account for declines of
0.15%/day during storage.

The submitted hops and mint field trial data are adequate and support
the proposed use patterns. An adequate number of tests were conducted on
each crop in the appropriate geographical regions. Samples were analyzed
for residues of concern using adequate data collection methods, and the
sample storage conditions and intervals are supported by the available
storage stability data. Residues of ethoprop and Metabolite IV
(determined as methylated derivative) were determined in the mint field
trials and residues of ethoprop and Metabolites II, III and IV
(ethylated derivative) were determined in the hop field trials.

As quantifiable residues of ethoprop were detected (0.021 ppm) in mature
dried hops following soil applications at \~10x the proposed use rate,
the use on hops cannot be considered a non-food use. However, because
ethoprop residues were just at or below the LOQ (0.02 ppm) following a
\~10x application, the available field trial data will still support the
proposed 1x use rate, as ethoprop residues are unlikely to exceed the
LOQ in samples harvested at the proposed 90-day PHI. Following
applications at 10x, residues of Metabolites II and III were each \<0.02
ppm in/on dried hop cones, and residues of Metabolite IV (corrected for
storage declines) were \<0.054-0.086 ppm.

In the mint field trials, residues of ethoprop were \<0.01 ppm in/on
mint tops harvested 225-280 days after treatment (DAT) with ethoprop
(EC) at 1x the proposed rate. Residues of M-1 (Metabolite IV) were also
\<0.01 ppm in/on mint tops from four field trials (n=12), but were
detected at up to 0.073 ppm from one field trial (HAFT residues of 0.061
ppm). Although no mint field trials were conducted using the 15% G
formulation, the available data from the EC formulation will support the
use of the G formulation for purpose of this petition as (i) both
formulations are applied to the soil after the final harvest of the
season, (ii) the application to harvest interval is relatively long
(≥225 days); and (iii) residues of ethoprop in mint resulting from use
of the EC were \<LOQ at up to 10x the proposed rate (see CHEMSAC meeting
minutes of 1/16/08).

The submitted mint processing study is adequate and indicates the
ethoprop residues may concentrate in mint oil by \~4x. However, ethoprop
residues were \<LOQ (\<0.01 ppm) in/on mint tops (RAC) from all tests at
the 1x or 10x application rate. When average ethoprop residues in oil
(0.038 ppm) from the 10x application are adjusted to account for the
exaggerated use rate, residues in oil (0.004 ppm) would be below the
proposed tolerance for mint tops. Therefore, a separate tolerance is not
required for mint oil.

Number range CHAPTERAlthough hops are a perennial crop, and therefore,
not rotated, mint is rotated with other crops, typically on a 3-5 year
interval; therefore, rotational crop data requirements are relevant to
the petition for use on mint. Adequate confined and limited field
rotational crop studies are available and indicate that tolerances for
rotated crops are not required provided that labels are amended to
include a 30-day plantback intervals (PBI) for leafy vegetables, a
8-month PBI for small grains, and a restriction against the planting of
any root or tuber crops following ethoprop-treated crops. None of the
registrant's labels currently specify any rotational crop restrictions
for ethoprop.

Number range CHAPTER**Regulatory Recommendations and Residue Chemistry
Deficiencies**

No major deficiencies were noted in the subject petitions that would
preclude establishing permanent tolerances for residues of ethoprop *per
se* on hops and mint (peppermint and spearmint); however, label
amendments regarding rotational crop restrictions remain outstanding.
End-use labels for ethoprop must be amended to specify the recommended
PBIs for rotated crops. Tolerances should be established at 0.02 pm for
ethoprop in/on dried hop cones and tops of peppermint and spearmint. A
human health risk assessment for ethoprop is forthcoming.

[]{.mark}

**Background**

Number range CHAPTEREthoprop \[*S,S*-dipropyl *O*-ethyl
phosphorodithioate\] is an organophosphate (OP) insecticide/nematicide
registered for use on bananas/plantains, beans (lima and snap), cabbage,
citrus (non-bearing), corn, cucumbers, peanuts, pineapples, potatoes,
sugarcane, sweet potatoes, and tobacco. Ethoprop is manufactured by
Bayer CropScience under the trade name MOCAP^®^ and is formulated as
either an EC or G for application to food/feed crops. These products may
be applied as broadcast or banded preplant to preemergence applications
and as banded postemergence applications directed to the soil. Use
directions specify the use of only ground equipment, except on potatoes
where aerial applications are allowed.

IR-4 previously submitted a petition requesting the use of ethoprop (EC
and G) on mint in the U.S. (PP#5E4491). The mint petition was originally
submitted in 1995 and was reviewed by the Agency (DP# D214091, G.
Otakie, 8/14/1995), but later with the inception of FQPA was rendered
inactive pending completion of the OP cumulative risk assessment. Now
that the cumulative risk assessment has been completed, the petition has
been reactivated. Additionally, IR-4 has submitted a new petition
(PP#7E7247) requesting the use of ethoprop (EC) on hops in the U.S. In
conjunction with these uses, IR-4 is proposing the establishment of
permanent tolerances for ethoprop residues on mint and hops at 0.02 ppm.
The nomenclature and physicochemical properties of ethoprop and its
metabolites of concern are presented below in Tables 1 and 2.

+-------------------+--------------------------------------------------+
| **Table 1.        |                                                  |
| Nomenclature of   |                                                  |
| Ethoprop and its  |                                                  |
| Metabolites of    |                                                  |
| Concern.**        |                                                  |
+===================+==================================================+
| Compound          | ![                                               |
|                   | ](media/image2.wmf){width="2.1041666666666665in" |
|                   | height="0.9270833333333334in"}                   |
+-------------------+--------------------------------------------------+
| Common name       | Ethoprop                                         |
+-------------------+--------------------------------------------------+
| Company           | Ethoprop                                         |
| experimental name |                                                  |
+-------------------+--------------------------------------------------+
| IUPAC name        | *O*-ethyl-*S,S*-dipropyl phosphorodithioate      |
+-------------------+--------------------------------------------------+
| CAS name          | *O*-ethyl-*S,S*-dipropyl phosphorodithioate      |
+-------------------+--------------------------------------------------+
| CAS registry      | 13194-48-4                                       |
| number            |                                                  |
+-------------------+--------------------------------------------------+
| End-use product   | 6 lb/gal EC (MOCAP^®^ EC Nematicide-Insecticide, |
| (EP)              | EPA Reg. No. 264-458)                            |
|                   |                                                  |
|                   | 15% G (MOCAP^®^ 15% Granular                     |
|                   | Nematicide-Insecticide, EPA Reg. No. 264-457)    |
+-------------------+--------------------------------------------------+
| Compound          | ![                                               |
|                   | ](media/image3.wmf){width="2.1145833333333335in" |
|                   | height="0.9270833333333334in"}                   |
+-------------------+--------------------------------------------------+
| Common name       | Metabolite II (ethoprop S-Me)                    |
+-------------------+--------------------------------------------------+
| Chemical name     | *O*-ethyl-*S*-methyl-*S*-propyl                  |
|                   | phosphorodithioate                               |
+-------------------+--------------------------------------------------+
| Compound          | ![                                               |
|                   | ](media/image4.wmf){width="2.1145833333333335in" |
|                   | height="0.9166666666666666in"}                   |
+-------------------+--------------------------------------------------+
| Common name       | Metabolite III (ethoprop O-Me)                   |
+-------------------+--------------------------------------------------+
| Chemical name     | *O*-ethyl-*O*-methyl-*S*-propyl                  |
|                   | phosphorodithioate                               |
+-------------------+--------------------------------------------------+
| Compound          | ![                                               |
|                   | ](media/image5.wmf){width="2.1145833333333335in" |
|                   | height="0.75in"}                                 |
+-------------------+--------------------------------------------------+
| Common name       | Metabolite IV (M-1)                              |
+-------------------+--------------------------------------------------+
| Chemical name     | *O*-ethyl-*S*-propyl phosphorodithioate          |
+-------------------+--------------------------------------------------+

  -----------------------------------------------------------------------
  **Table 2. Physicochemical                            
  Properties of Technical                               
  Grade Ethoprop.**                                     
  --------------------------- ------------------------- -----------------
  Parameter                   Value                     Reference

  Boiling point               86-91ºC at 0.2 mmHg       Ethoprop
                                                        Registration
                                                        Standard
                                                        (10/20/87)

  pH                          6.65 in saturated aqueous 
                              solution at 21ºC          

  Density                     1.097 g/mL at 15ºC        

  Water solubility            843 ppm at 21ºC           

  Solvent solubility          Completely miscible in    
                              hexane, xylene, acetone,  
                              and ethanol               

  Vapor pressure              3.89 x 10^-4^ Torr at     
                              24ºC                      

  Dissociation constant,      not available             
  pK~a~                                                 

  Octanol/water partition     3.59 at 21ºC              
  coefficient, Log(K~OW~)                               

  UV/visible absorption       not available             
  spectrum                                              
  -----------------------------------------------------------------------

**860.1200 Directions for Use**

There are currently three end-use products of ethoprop registered to
Bayer CropScience for use in the U.S. on food/feed crops. These EPs are
marketed under the trade name MOCAP^®^ and include a 6 lb/gal EC (EPA
Reg. No. 264-458), a 15% G (EPA Reg. No. 264-457), and a 20% G (EPA Reg.
No. 264-469). IR-4 is proposing the use of the 6 lb/gal EC formulation
for an early-season broadcast or banded application to hops for control
of garden symphylan and long-horned beetle, and use of the 6 lb/gal EC
and 15% G formulations for a post-harvest or preplant broadcast soil
application to mint for control of garden symphylan, nematodes, and mint
root borer. Example use directions were provided and are summarized
below in Table 3.

+-------------------+------+-----+------+--------+----+-------------+
| **Table 3.        |      |     |      |        |    |             |
| Summary of        |      |     |      |        |    |             |
| Directions for    |      |     |      |        |    |             |
| Use of            |      |     |      |        |    |             |
| Ethoprop.**       |      |     |      |        |    |             |
+===================+======+=====+======+========+====+=============+
| Applic. Timing,   | F    | A   | Max. | Max.   | P  | Use         |
| Type, and         | orm. | ppl | No.  | Se     | HI | Directions  |
|                   |      | ic. | App  | asonal |    | and         |
| Equip. ^1^        | \    | R   | lic. | A      | (d | Limitations |
|                   | [EPA | ate | per  | pplic. | ay |             |
|                   | Reg. |     | Se   | Rate   | s) |             |
|                   | N    | (lb | ason |        |    |             |
|                   | o.\] | ai  |      | (lb    |    |             |
|                   |      | /A) |      | ai/A)  |    |             |
+-------------------+------+-----+------+--------+----+-------------+
| **Hops**          |      |     |      |        |    |             |
+-------------------+------+-----+------+--------+----+-------------+
| **New             | 6    | 3.0 | 1    | 3.0    | 90 | Incorporate |
| plantings**:      | lb   |     |      |        |    | into the    |
| Single broadcast  | /gal |     |      |        |    | top 2-4" of |
| pre-plant or      | EC   |     |      |        |    | soil        |
| preemergence soil |      |     |      |        |    | immediately |
| application to    | \[2  |     |      |        |    | following   |
| baby hops.        | 64-4 |     |      |        |    | application |
|                   | 58\] |     |      |        |    | using       |
| **Established     |      |     |      |        |    | mechanical  |
| plantings**:      |      |     |      |        |    | means or by |
| single broadcast  |      |     |      |        |    | overhead    |
| or banded soil    |      |     |      |        |    | irrigation. |
| application prior |      |     |      |        |    |             |
| to stringing      |      |     |      |        |    |             |
| vines or after    |      |     |      |        |    |             |
| harvest of vines. |      |     |      |        |    |             |
|                   |      |     |      |        |    |             |
| Ground equipment  |      |     |      |        |    |             |
| only              |      |     |      |        |    |             |
+-------------------+------+-----+------+--------+----+-------------+
| **Mint**          |      |     |      |        |    |             |
+-------------------+------+-----+------+--------+----+-------------+
| Single broadcast  | 6    | 6.0 | 1    | 6.0    | 2  | Incorporate |
| soil application, | lb   |     |      |        | 25 | into the    |
| preplanting to    | /gal |     |      |        |    | top 2-4" of |
| new fields or     | EC   |     |      |        |    | soil        |
| after last        |      |     |      |        |    | immediately |
| harvest of the    | \[2  |     |      |        |    | following   |
| season to         | 64-4 |     |      |        |    | application |
| established       | 58\] |     |      |        |    | using       |
| fields.           |      |     |      |        |    | mechanical  |
|                   | 15%  |     |      |        |    | means or by |
| Ground equipment  | G    |     |      |        |    | overhead    |
| only              |      |     |      |        |    | irrigation. |
|                   | \[2  |     |      |        |    |             |
|                   | 64-4 |     |      |        |    | Apply in    |
|                   | 57\] |     |      |        |    | 20-30       |
|                   |      |     |      |        |    | gal/A.      |
+-------------------+------+-----+------+--------+----+-------------+

^1^ Do not apply by air or through any type of irrigation equipment. For
banded applications, rates per acre should be lowered to reflect actual
area treated.

*Conclusions*. The label directions are adequate to allow evaluation of
the residue data relative to the proposed use. The available hops and
mint field trial data support the proposed use directions.

**860.1300 Nature of the Residue - Plants**

Ethoprop RED, DP# D239294, J. Abbots, 3/27/1998

Number range CHAPTERThe qualitative nature of the residue in plants is
adequately understood based on cabbage, corn, and potato metabolism
studies. HED concluded that for acute and chronic non-cancer dietary
risk, the residues of concern in crops are parent and Metabolites II and
III (S-ME and O-ME); for cancer dietary risk, the residues of concern
are parent and Metabolites II through IV (S-ME, O‑ME and M-1). HED has
also determined that the metabolite ethyl phosphate is not a residue of
concern.

**860.1300 Nature of the Residue - Livestock**

Ethoprop RED, DP# D239294, J. Abbots, 3/27/1998

Number range CHAPTERThe qualitative nature of the residue in livestock
is adequately understood based upon acceptable ruminant and poultry
metabolism studies. Ethoprop was not detected in milk, eggs or tissues
from goats and hens dosed orally for seven consecutive days with
\[^14^C\]ethoprop at levels equivalent to 32 ppm (865x) and 2.09 ppm
(105x), respectively, in the diet. Maximum total radioactive residues
were 9.26 ppm in goat liver and 1.22 ppm in chicken liver. Residues of
potential concern that were detected included Metabolites III and/or IV,
which together accounted for ≤2% of the total radioactive residues in
liver of hens and goats. Based on the data from the livestock metabolism
studies, the Agency has concluded finite residues of ethoprop are
unlikely to occur in livestock commodities \[40 CFR 180.6(a)(3)\].

**860.1340 Residue Analytical Methods**

Ethoprop RED, DP# D239294, J. Abbots, 3/27/1998

DP# D244335, S. Piper, 10/22/98

*Enforcement methods.* Number range CHAPTERAdequate analytical
methodology is available for enforcing tolerances of ethoprop as
currently defined. Method I in the Pesticide Analytical Manual (PAM),
Vol. II, is a GC/sulfur microcoulometric detection method that has
undergone a successful EPA method validation. This method involves
solvent extraction and clean-up by sweep co-distillation. Residues of
ethoprop are determined by GC using a sulfur microcoulometric detector.
PAM, Vol. II also lists Method A, which uses the same principles as
Method I, but employs different parameters for extraction and gas
chromatography. The limit of quantitation for ethoprop in or on plant
commodities is 0.01 ppm in each method.

A newer GC/FPD method has also been proposed as an enforcement method
for determining residues of ethoprop and Metabolite IV in plant
commodities. For this method, residues of ethoprop and Metabolite IV are
extracted with methanol, filtered, and cleaned up using cation exchange
resin and nuchar/attaclay. Residues are concentrated and redissolved in
methanol, and Metabolite IV is methylated with diazomethane. Ethoprop
and methylated Metabolite IV are then partitioned into methylene
chloride, concentrated, redissolved in methylene chloride, and further
cleaned up using gel permeation and/or silica gel chromatography prior
to analysis using GC/FPD in the phosphorus mode. The LOQ is 0.01 ppm
each for ethoprop and Metabolite IV in plant commodities. This method
has been adequately validated by an independent laboratory, but has
never undergone a petition method validation by the Agency.

*Data collection methods.* In the mint field trials and processing
study, residues of ethoprop and Metabolite IV were determined using a
version of the proposed GC/FPD enforcement method for plant commodities,
which is discussed above. The validated LOQ for residues of ethoprop and
Metabolite IV was 0.01 ppm in mint commodities. The method was
adequately validated in conjunction with the analysis of field trial and
processing study samples.

Residues of ethoprop and Metabolites II, III and IV were determined in
the hop field trials using a GC/FPD method that was derived from the
proposed GC/FPD enforcement method for lima beans. For this method,
residues were extracted with methanol and initially cleaned up by
elution through tandem SCX and Nexus SPE cartridges. Residues were then
concentrated, acidified and partitioned into ethyl acetate, and residues
of Metabolite IV were ethylated using diazoethane. Residues were next
cleaned up using an NH~2~ SPE cartridge and then determined by GC/FPD in
the phosphorous mode, using external standards. Residues are expressed
in terms of the individual analytes. The validated LOQ for ethoprop and
each metabolite was 0.02 ppm in dried hops. The above method was
adequately validated in conjunction with the analysis of hops field
trial samples.

[]{.mark}

*Conclusions.* Adequate methods are available for enforcing the proposed
tolerances on hops and mint, and the GC/FPD methods used for collecting
residue data from the field trials and mint processing study are
adequate for data collection.

**860.1360 Multiresidue Methods**

Acceptable multiresidue method testing data were submitted for ethoprop
and these data were forwarded to the U.S. FDA for further evaluation
(DP# 177243, L. Cheng, 5/28/1992). Ethoprop is completely recovered
using Method 303, but is poorly recovered (≤50-80%) through 303 and very
poorly recovered (\<50%) through protocol 304 (PAM Vol 1).

**860.1380 Storage Stability**

Ethoprop RED, DP# D239294, J. Abbots, 3/27/1998

Adequate Number range CHAPTERstorage stability data are available
indicating that ethoprop *per se* is stable at -20ºC in cabbage, potato,
pineapple commodities, peanut commodities (except meal), and corn
commodities for up to 6 to 12 months, in sugar cane and its processed
fractions for up to 15 month, and in peanut meal for up to 3 months at
-20ºC. At storage temperatures of ‑5ºC, ethoprop *per se* is stable for
6 to 12 months in the above commodities except for pineapple bran and
pulp, peanut hulls, and corn grain dust, in which ethoprop is stable for
\<3 months.

Metabolite IV (M-1) is stable for 6 to 12 months in the following
matrices stored at -20ºC: cabbage, potatoes, pineapple commodities
(except bran), peanut oil and nutmeats, and corn forage, meal, oil, and
grain dust. Metabolite IV is also stable at -20ºC for up to 15 months in
sugar cane and its processed fractions. However, Metabolite IV is stable
for ≤3 months at -20ºC in pineapple bran, corn grain, corn fodder, corn
starch, and in peanut meal, vine, hay, and hulls. At storage
temperatures of ‑5ºC, Metabolite IV is stable for up to 12 months in
cabbage, pineapple juice, peanut nutmeat, peanut crude oil, and corn
crude oil. Metabolite IV is stable at ‑5ºC for ≤3 months in potatoes;
pineapple fruit, bran, and pulp; peanut meal, vine, hay, hull, and
refined oil; and corn grain, forage, fodder, starch, meal, grain dust,
and refined oil.

In the Ethoprop RED, HED concluded that concurrent storage stability
studies should be conducted with any required field trials or processing
studies.

As the mint field trials and processing study were conducted prior to
issuance of the Ethoprop RED, no concurrent storage stability data were
submitted with the mint studies. However, the available stability data
on corn forage and oil and peanut hay and oil will support the mint
field trials and processing study.

To support the hop field trials, a concurrent freezer storage stability
study was conducted using control samples of dried hops fortified
separately with ethoprop and Metabolites IV (ethylated), II and III,
each at 0.5 ppm. The fortified samples were stored under the same
conditions (-20ºC) as the field trial samples. At the end of the
analytical phase, the stored samples were analyzed in triplicate along
with a control sample and control samples freshly fortified with each
analyte. The average recovery from the stored samples (corrected for
concurrent recoveries) were 105-112% for parent and Metabolites II and
III, indicating that these compounds were stable at -20ºC in dried hops
for up to 14.2 months. However, the average corrected recovery for
Metabolite IV was 37%, indicating a potential decline of 63% over 14.2
months (↓0.15%/day). Although no 0-day analyses were conducted on the
fortified samples prior to frozen storage, to verify the fortification
levels, the submitted storage stability data on dried hop cones is
adequate for purposes of this petition. These data are in agreement with
the demonstrated stability of ethoprop and Metabolite IV on other plant
matrices.

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

  ------------------------------------------------------------------------
  **Table 4.                                    
  Summary of                                    
  Storage                                       
  Conditions and                                
  Durations of                                  
  Samples from                                  
  Field Trials                                  
  and Processing                                
  Studies.**                                    
  -------------- ------------- ---------------- --------------------------
  Matrix         Storage       Actual Storage   Interval of Demonstrated
                 Temperature   Duration         Storage Stability (months)
                 (°C)          (months)         

  Dried hop      ≤-20          14.2             13.9 ^1^
  cones                                         

  Mint tops and  Frozen        2.7              3-12 ^2^
  oil                                           
  ------------------------------------------------------------------------

^1^ Supported by concurrent storage stability study. The data indicate
that Metabolite IV should be corrected for decline during storage.

^2^ Supported by data on corn forage and oil and peanut hay and oil.

*Conclusions*. The available storage stability data adequately support
the storage conditions and durations for ethoprop and Metabolite IV in
the mint field trials and processing study and for ethoprop and
Metabolites II and III in the hop field trials. However, the data also
indicate that Metabolite IV degraded in dried hops stored at -20ºC by
63% after \~14 months of storage (↓0.15% per day). Therefore, the
residue data on Metabolite IV were corrected to account for decline
during storage.

**860.1400 Water, Fish, and Irrigated Crops**

There are no proposed uses that are relevant to this guideline topic.

**860.1460 Food Handling**

There are no proposed uses that are relevant to this guideline topic.

**860.1480 Meat, Milk, Poultry, and Eggs**

There are no livestock feedstuffs associated with the proposed uses on
mint or hops. Therefore, data requirements pertaining to meat, milk,
poultry, and eggs are not relevant to these tolerance petitions.

**860.1500 Crop Field Trials**

DP# 214091, G. Otakie, 8/14/1995 (mint field trials)

47194001.der (hop field trials)

IR-4 previously submitted residue data from mint field trials, which
were reviewed by HED (DP# D218587, G. Otakie, 8/14/1995). IR-4 has also
submitted new field trial data supporting a proposed use of ethoprop
(EC) on hops. Number range CHAPTERThe results from the mint and hop
trials are discussed below and the residue data are summarized in
Table 5.

<table style="width:100%;">
<colgroup>
<col style="width: 12%" />
<col style="width: 12%" />
<col style="width: 7%" />
<col style="width: 9%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 8%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="11"><strong>Table 5. Summary of Residue Data from Mint and
Hops Field Trials with Ethoprop (EC).</strong></th>
</tr>
<tr class="odd">
<th rowspan="2">Crop matrix</th>
<th rowspan="2"><p>Total Applic. Rate</p>
<p>(lb ai/A)</p></th>
<th rowspan="2">PHI (days)</th>
<th rowspan="2">Analyte <sup>1</sup></th>
<th colspan="7">Residue Levels (ppm) <sup>2</sup></th>
</tr>
<tr class="header">
<th>n</th>
<th>Min.</th>
<th>Max.</th>
<th>HAFT <sup>3</sup></th>
<th>Median</th>
<th>Mean</th>
<th>Std. Dev.</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="11"><strong>Hops (proposed use = 3.0 lb ai/A total
application rate, 90-day PHI)</strong></td>
</tr>
<tr class="even">
<td rowspan="4">Hop, dried cones</td>
<td rowspan="4">30.1-34.3</td>
<td rowspan="4">118-135</td>
<td>Ethoprop</td>
<td>6</td>
<td>&lt;0.02</td>
<td>0.021</td>
<td>0.02</td>
<td>0.02</td>
<td>0.02</td>
<td>&lt;0.001</td>
</tr>
<tr class="odd">
<td>M-1 <sup>4, 5</sup></td>
<td>6</td>
<td>&lt;0.054</td>
<td>0.086</td>
<td>0.077</td>
<td>0.054</td>
<td>0.062</td>
<td>0.013</td>
</tr>
<tr class="even">
<td>O-Me</td>
<td>6</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>0.02</td>
<td>0.02</td>
<td>NA</td>
</tr>
<tr class="odd">
<td>S-Me</td>
<td>6</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>0.02</td>
<td>0.02</td>
<td>NA</td>
</tr>
<tr class="even">
<td colspan="11"><strong>Mint (proposed use = 6.0 lb ai/A total
application rate, 255-day PHI)</strong></td>
</tr>
<tr class="odd">
<td rowspan="2">Mint, tops</td>
<td rowspan="2">6.0</td>
<td rowspan="2">225-280</td>
<td>Ethoprop</td>
<td>15</td>
<td>&lt;0.01</td>
<td>&lt;0.01</td>
<td>&lt;0.01</td>
<td>0.01</td>
<td>0.01</td>
<td>NA</td>
</tr>
<tr class="even">
<td>M-1 <sup>5</sup></td>
<td>15</td>
<td>&lt;0.01</td>
<td>0.073</td>
<td>0.061</td>
<td>0.01</td>
<td>0.02</td>
<td>0.021</td>
</tr>
</tbody>
</table>

^1^ Analytes M-1, O-Me and S-Me are respectively equivalent to
Metabolites IV, III and II.

^2^ The LOQ is \~0.02 ppm for each analyte in hops, and 0.01 ppm for
parent and M-1 (determined as M-1-Me) in mint. For calculation of
median, mean and standard deviation, the LOQ was used for values \<LOQ.

^3^ HAFT = Highest average field trial result.

^4^ Data corrected for 63% degradation. The original data for the two
samples with detectable residues were 0.032 ppm and 0.025 ppm.

^5^ Metabolite M-1 was determined as ethylated M-1(M-1-Et)\_ in the hop
field trials and as methylated M-1 in the mint field trials.

**Hops.** In 3 field trials conducted during 2005 in Zones 11 and 12,
ethoprop (6 lb/gal EC) was applied to hop fields as either a single
broadcast soil application at 30.1 or 34.3 lb ai/A (\~10x rates, 2
tests) or as two banded soil applications (1 test) at 14.0 and 16.6 lb
ai/A/application at a retreatment interval of 6 days, for a total of
30.6 lb ai/A (10x rate). The 10x application rates were used in these
field trials because the petitioner was attempting to demonstrate that
the proposed use could be considered a non-food/feed use. The
applications were made early in the growing season, prior to stringing
vines when either some foliage was present or after pruning off new
growth. Applications were made using ground equipment at 14-50 gal/A,
and did not include the use of any spray adjuvants. Following
application, the ethoprop was incorporated into the soil by
irrigation/rainfall.

Duplicate control and treated samples of green hops were harvested from
each trial site at normal crop maturity, 118-135 DAT. The hop cones were
dried for 3-24 hours at 39-67ºC, as per commercial practices. After
cooling to ambient temperatures, samples were frozen and stored at -20ºC
for up to 14.2 months until extraction for analysis. Data from the
concurrent storage stability study indicate that ethoprop and
Metabolites S-Me and O‑Me (Metabolites II and III) are stable in dried
hops for the duration of frozen storage. However, M‑1 (Metabolite IV)
was shown to decline (↓0.15%/day) in hops during frozen storage;
therefore, the reported residues of M-1 have been corrected for decline
during storage.

Residues of ethoprop and its metabolites M-1, O-Me, and S-Me in/on dried
hop cones were determined using a GC/FPD method that was adequately
validated prior to and in conjunction with the analysis of the field
trial samples. The LLMV was 0.02 ppm for each analyte and the calculated
LOQ and LOD were respectively 0.02 and 0.007 ppm for ethoprop, 0.023 and
0.008 ppm for Metabolites M-1 (determined at M-1-Et), 0.011 and 0.004
ppm for O-Me, and 0.026 and 0.009 ppm for S-Me.

Following one or two early season soil applications of ethoprop at \~10x
the proposed use rate, residues of ethoprop were ≤0.021 ppm in/on 6
samples of dried hop cones harvested at 118-135 DAT, with residues \>LOQ
in only one sample (0.021 ppm). Residues of the Metabolites S-Me and
O-Me were each \<0.02 ppm in/on all samples. Residues of M-1, determined
as M-1-Et and corrected for storage declines, were \<LOQ in/on 4 samples
and 0.068 and 0.086 ppm in two samples from one test. Average residues
were calculated to be 0.02 ppm for parent, O-Me, and S-Me and 0.062 ppm
for M-1-Et. Residue decline data were not reported for hops; however,
these data are not required as the applications were made to the soil
and the treatment to harvest interval was fairly long (\>100 days).

**Mint**. Five field trials were conducted on mint in Zones 5, 11 and 12
during 1993-1994. In each field trial, ethoprop (6 lb/gal EC) was
applied to established fields of mint as a single broadcast application
at 6.0 lb ai/A (1x proposed rate) in the fall following the final
harvest. Single control and triplicate treated samples of mint hay were
collected from the first harvest the following season, at 225-280 DAT.
Samples were stored frozen for up to 82 days, an interval supported by
available storage stability data.

Mint samples were analyzed for residues of ethoprop and Metabolite M-1
using a GC/FPD method similar to a method that has previously been
proposed for tolerance enforcement. The method was adequately validated
in conjunction with the analysis of the field trial samples. The
validated LOQ is 0.01 ppm for both ethoprop and Metabolite M-1 in mint.

Following a single broadcast soil application of ethoprop at 6.0 lb ai/A
(1x proposed rate) in the fall after the last harvest, residues of
ethoprop were \<0.01 ppm in/on all samples of mint collected from the
first harvest in the following season (225-280 DAT). Residues of M-1
were also \<0.01 ppm in/on mint from four field trials (n=12), but were
detected at up to 0.073 ppm from one field trial in WI (HAFT residues =
0.061 ppm).

*Conclusions*. The hops and mint field trial data are adequate and
support the proposed use patterns. An adequate number of tests were
conducted on each crop in the appropriate geographical regions. Samples
were analyzed for residues of concern using adequate data collection
methods, and the sample storage conditions and intervals are supported
by the available storage stability data.

As quantifiable residues of ethoprop were detected in mature dried hops
following an application at \~10x the proposed use rate, the use on hops
cannot be considered a non-food use. However, because ethoprop residues
were ≤0.021 ppm following a \~10x application, the available field trial
data will still support the proposed 1x application of ethoprop (EC) to
hops as ethoprop residues are unlikely to exceed the LOQ in samples
harvested at the proposed 90-day PHI.

No mint trials were conducted using the 15% G formulation of ethoprop.
However, for purposes of this petition, the field trial data for the EC
formulation will be translated to support the 15% G formulation as (i)
both formulations are applied to the soil after the final harvest of the
season, (ii) the application to harvest interval is relatively long
(≥225 days); and (iii) residues of ethoprop in mint resulting from use
of the EC were \<LOQ at up to 10x the proposed rate (see processing
study below).

The available hop and mint field trial data will support tolerances for
residues of ethoprop *per se* in/on mint tops (spearmint and peppermint)
and dried hop cones at 0.02 ppm.

**860.1520 Processed Food and Feed**

DP# 214091, G. Otakie, 8/14/1995

In a mint processing study conducted in OR during 1993-1994, ethoprop (6
lb/gal EC) was applied to established mint at the 4-6 leaf stage as a
single broadcast application in the fall at rates of 30 or 60 lb ai/A
(5x and 10x rates). Samples of control hay and treated hay from the 10x
plot were harvested 225 DAT. Hay was processed into oil and spent hay on
the day of harvest using standard commercial distillation practices.
Samples were stored frozen for up to 82 days prior to analysis, an
interval supported by available storage stability data.

[]{.mark}

Samples of mint hay, oil and spent hay were analyzed for residues of
ethoprop and Metabolite M‑1 using the same GC/FPD method as used in the
mint field trials. The method was adequately validated in conjunction
with the analysis of the processing study samples. The validated LOQ is
0.01 ppm for both ethoprop and Metabolite M-1 in mint hay, oil and spent
hay.

Following a 10x application, residues of both ethoprop and M-1 were
\<LOQ (\<0.01 ppm) in mint hay (RAC) and spent hay. Residues of
Metabolite M-1 were also \<0.01 ppm in mint oil. Residues of ethoprop
were detected in mint oil at a maximum of 0.044 ppm and averaged 0.038
ppm following an application at 10x. Assuming residues at the LOQ for
mint hay, the processing factor for ethoprop in mint oil is 4x.

*Conclusions*. The mint processing study is adequate. Average residues
of ethoprop were 0.038 ppm in mint oil processed from mint treated at a
10x rate. Because ethoprop residues were \<LOQ (\<0.01 ppm) in all
samples of mint from the 1x rate and 10x rate field trials, the maximum
expected residues in oil at a 1x rate were estimated using the 10x field
trial data and adjusting for the degree of exaggeration. Accordingly,
the maximum expected residues on mint oil would be 0.0038 ppm, which is
below the proposed 0.02 ppm tolerance for mint. Therefore, a separate
tolerance is not required for mint oil.

Number range CHAPTER**860.1650 Submittal of Analytical Reference
Standards**

An analytical reference standard for ethoprop is currently available at
the EPA National Pesticide Standards Repository (correspondence with
Theresa Cole 9/18/2007).

**860.1850 Confined Accumulation in Rotational Crops**

Ethoprop RED, DP# D239294, J. Abbots, 3/27/1998

Number range CHAPTERAn adequate confined rotational crop study is
available and indicates that residues of ethoprop in rotational crops
are qualitatively similar to the residues resulting from the direct
application of ethoprop to the primary crops. Ethoprop residues of
concern were detected at \>0.01 ppm in/on spinach from the 31-day
plant-back interval, radish roots and wheat straw from 31- and 123-day
PBIs, and wheat forage from 31-, 123, and 365-day PBIs. Based upon
results of the confined rotational crop study, limited field
accumulation studies in rotational crops were required.

**860.1900 Field Accumulation in Rotational Crops**

Ethoprop RED, DP# D239294, J. Abbots, 3/27/1998

DP# D238977, J. Abbotts, 1/23/1998

DP# D245393, S. Piper, 10/07/1998

Rotational crop data are not relevant to the proposed use on hops, as
hops are a perennial crop. However, mint fields are rotated with other
crops, typically on a 3-5 year interval. None of the registrant's labels
currently specify any rotational crop restrictions for ethoprop.

[]{.mark}

Adequate data are available from limited rotational crop field trials.
Based on the results of this study and the registrant's response to the
Agency's review of the limited field trials, HED has concluded that a
30-day plantback restriction is appropriate for leafy vegetables and an
8-month plantback restriction is for small grains. In addition, the
registrant has indicated that the label will be amended to prohibit
rotation to any root or tuber crops following application of ethoprop.
Provided that labels are amended to include these restrictions, no
additional data or tolerances would be required for rotational crops.

**860.1550 Proposed Tolerances**

Number range CHAPTERTolerances for ethoprop are currently expressed in
terms of ethoprop *per se* and have been established at the limit of
quantitation (0.02 ppm) on the following plant commodities: banana,
beans (lima and snap), cabbage, corn commodities (forage, grain, stover,
and kernels plus cobs with husks removed), cucumber, peanut and peanut
hay, pineapple, potato, sugarcane and sweet potato \[40 CFR
§180.262(a)\]. The Residue Chemistry Chapter for the Ethoprop RED (J.
Abbotts, 3/27/98) previously recommended that the tolerance expression
for ethoprop be revised to include residues of both parent and
Metabolite IV (M-1), expressed as parent. However, HED has since revised
it position and is now recommending that the tolerance expression
include only parent ethoprop (DP# D277780, C. Swartz, 10/11/2001).

Based on the available field trial data, the tolerance for dried hop
cones should be set at the LOQ for the enforcement method (0.02 ppm) as
residues of ethoprop were either \<LOQ (\<0.02 ppm) or just above the
LOQ (0.021 ppm) in samples from the 10x rate field trials (Table 6).
Similarly, tolerances for mint (peppermint and spearmint) should be set
at the LOQ (0.02 ppm) as residues of ethoprop were \<0.01 ppm in all
samples of mint hay from the 1x rate field trials. Separate tolerances
should be established for peppermint tops and spearmint tops, rather
than on mint. Based on the results of the mint processing study, a
separate tolerance is not required for mint oil.

There are no Canadian or Mexican MRLs for residues of ethoprop and no
Codex MRLs for residues of ethoprop on the proposed crops (see IRL
sheet). Therefore, there are no international harmonization issues
associated with these petitions.

  ----------------- --------------- -------------- -----------------------
  **Table 6.                                       
  Tolerance Summary                                
  for Ethoprop.**                                  

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

  Hop, dried cones  0.02            0.02           Adequate Residue Data
                                                   are available. *Hop,
                                                   cones, dried*

  Mint, hay         0.02            0.02           Adequate residue data
                                                   are available. Separate
                                                   tolerances should be
                                                   established for
                                                   *spearmint, tops* and
                                                   *peppermint, tops*
  ----------------- --------------- -------------- -----------------------

**References**

Number range CHAPTERDP Number: D214091

Subject: Number range CHAPTERPP#5E04491 - Ethoprop on Mint - Evaluation
of Field Trial and Processing Residue Data.

From: G. Otakie

To: D. Edwards, C. Anderson, and W. Hazel

Dated: 8/14/1995

MRID(s): 43588801 and 43588802

Number range CHAPTERDP Number: D238977

Subject: Ethoprop (041101), Reregistration Case No. 0106. Registrant
Rhône-Poulenc Ag Company. Residue Chemistry Guideline 860.1900, Limited
Rotational Crop Field Trials.Number range CHAPTER

From: J. Abbots

To: K. Farwell and J. Loranger

Dated: 1/23/1998

MRID(s): 44350201

Number range CHAPTERDP Number: D239294

Subject: Number range CHAPTEREthoprop (041101), Reregistration Case No.
0106. Product and Residue Chemistry Chapters for the Reregistration
Eligibility Decision (RED).

From: J. Abbots

To: K. Farwell

Dated: 3/27/1998

MRID(s): None

Number range CHAPTERDP Number: D245393

Subject: Number range CHAPTEREthoprop (041101). Reregistration Case No
0106. Registrant Rhone-Poulenc Ag Company. Registrant's Response to
Limited Rotational Crop Field Trials.

From: S. Piper

To: M. Metzger

Dated: 10/07/1998

MRID(s): None

Number range CHAPTERDP Number: D244335

Subject: Number range CHAPTEREthoprop (041101). Reregistration Case No
0106. Revision of the Enforcement Method for Ethoprop on Lima Bean Pods,
Vines, and Hay.

From: S. Piper

To: M. Metzger

Dated: 10/22/1998

MRID(s): 44495601

Number range CHAPTERDP Number: D277780

Subject: Number range CHAPTEREthoprop. List A Reregistration Case No.
0106/Chemical ID No. 041101). Data Requirements and Tolerance
Reassessment for the IRED.

From: C. Swartz

To: K. Farwell and B. Gregg

Dated: 10/11/2001

MRID(s): None

Number range CHAPTERAttachments:

International Residue Limit Status sheet

Template Version September 2005

+-------------------+--------------+-------------------+--------------+
| INTERNATIONAL     |              |                   |              |
| RESIDUE LIMIT     |              |                   |              |
| STATUS            |              |                   |              |
+-------------------+--------------+-------------------+--------------+
| Chemical Name:    | Common Name: | √ Proposed        | Date:        |
|                   | Ethoprop     | tolerance         | 11/30/07     |
| *O*-eth           |              |                   |              |
| yl-*S,S*-dipropyl |              | □ Reevaluated     |              |
| p                 |              | tolerance         |              |
| hosphorodithioate |              |                   |              |
|                   |              | □ Other           |              |
+-------------------+--------------+-------------------+--------------+
| Codex Status      |              | U. S. Tolerances  |              |
| (Maximum Residue  |              |                   |              |
| Limits)           |              |                   |              |
+-------------------+--------------+-------------------+--------------+
| □ No Codex        |              | Petition Numbers: |              |
| proposal step 6   |              | 5E4491, 7E7247    |              |
| or above          |              |                   |              |
|                   |              | DP#s: 342754,     |              |
| √ No Codex        |              | 342793            |              |
| proposal step 6   |              |                   |              |
| or above for the  |              | Other Identifier: |              |
| crops requested   |              |                   |              |
+-------------------+--------------+-------------------+--------------+
| Residue           |              | Reviewer/Branch:  |              |
| definition (step  |              | M. Sahafeyan/RAB1 |              |
| 8/CXL):           |              |                   |              |
| Ethoprophos       |              |                   |              |
+-------------------+--------------+-------------------+--------------+
|                   |              | Residue           |              |
|                   |              | definition:       |              |
|                   |              | Ethoprop          |              |
+-------------------+--------------+-------------------+--------------+
| Crop (s)          | MRL (mg/kg)  | Crop(s)           | Tolerance    |
|                   |              |                   | (ppm)        |
+-------------------+--------------+-------------------+--------------+
|                   |              | Hop, cones, dried | 0.02         |
+-------------------+--------------+-------------------+--------------+
|                   |              | Peppermint, tops  | 0.02         |
+-------------------+--------------+-------------------+--------------+
|                   |              | Spearmint, tops   | 0.02         |
+-------------------+--------------+-------------------+--------------+
| **Limits for      |              | **Limits for      |              |
| Canada**          |              | Mexico**          |              |
+-------------------+--------------+-------------------+--------------+
| √ No Limits       |              | √ No Limits       |              |
|                   |              |                   |              |
| □ No Limits for   |              | □ No Limits for   |              |
| the crops         |              | the crops         |              |
| requested         |              | requested         |              |
+-------------------+--------------+-------------------+--------------+
| Residue           |              | Residue           |              |
| definition: N/A   |              | definition: NA    |              |
+-------------------+--------------+-------------------+--------------+
| Crop(s)           | MRL (mg/kg)  | Crop(s)           | MRL (mg/kg)  |
+-------------------+--------------+-------------------+--------------+
|                   |              |                   |              |
+-------------------+--------------+-------------------+--------------+
|                   |              |                   |              |
+-------------------+--------------+-------------------+--------------+
|                   |              |                   |              |
+-------------------+--------------+-------------------+--------------+
| Notes/Special     |              |                   |              |
| Instructions:     |              |                   |              |
+-------------------+--------------+-------------------+--------------+