--------------- ------------------------------------- ------------------
  Primary                                               Date:
  Evaluator                                             

                  Christine L. Olinger, Chemist, RRB1   
  --------------- ------------------------------------- ------------------

This DER was originally prepared under contract by Dynamac Corporation
(2275 Research Boulevard, Suite 300; Rockville, MD 20850; submitted
07/18/2006). The DER has been reviewed by the Health Effects Division
(HED) and revised to reflect current Office of Pesticide Programs (OPP)
policies.

**[STUDY REPORTS]{.underline}:**

46531301 Pensyl J.W. (1993) Magnitude of the Residues of Lactofen and
its Metabolites in Green Peppers. Lab Project number: 1714/91/1027.
Unpublished study prepared by Valent U.S.A. Corporation, 239 p.

46597201 Pensyl J.W. (1996) Magnitude of the Residue of Lactofen and its
Metabolites in Tomatoes. Project number: VP-11576. Unpublished study
prepared by Valent U.S.A. Corporation, 241 p.

46597202 Kowalsky J. (2003) Magnitude of the Residues of Lactofen on
Peppers. Lab Project Number: V-03-25304. Unpublished study prepared by
Valent U.S.A. Corporation, 84 p.

46597203 Kowalsky J. (2003) Magnitude of the Residues of Lactofen on
Tomatoes. Lab Project Number: V-03-25291. Unpublished study prepared by
Valent U.S.A. Corporation, 75 p.

**[EXECUTIVE SUMMARY]{.underline}:**

Valent U.S.A. Corporation has submitted field trial data for lactofen on
the representative crops, pepper and tomato, of the fruiting vegetables
group, crop group 8. A total of three pepper trials were conducted in
Zone 3 (FL) during the 1991 (one bell pepper trial) and 2003 (one bell
and one nonbell pepper trial) growing seasons. A total of four tomato
field trials were conducted in Zone 3 (FL) during the 1990 (three
trials) and 2003 (one trial) growing seasons. We note that both tomato
varieties used in the crop field trials produce medium to large fruits.

For the pepper field trials, the 2 lb/gal emulsifiable concentrate (EC)
formulation of lactofen was applied at each test location as one
pre-transplant and one postemergence directed soil application to row
middles at 0.49-0.51 lb ai/A/application for a total seasonal
application rate of 0.98-1.1 lb ai/A. Shielded spray equipment was used
in the 2003 trials. The first applications were made one or 12 days
prior to transplanting, and the second applications were made at 46- to
67-day retreatment intervals. First applications were made in spray
volumes of 31-33 gal/A, and second applications were made in spray
volumes of 55-59 gal/A; nonionic surfactant (NIS) or crop oil
concentrate (COC) adjuvants were added to the spray mixtures for second
applications. Mature peppers were harvested 30 days following the second
application.

For the tomato field trials, the 2 lb/gal EC formulation of lactofen was
applied at each test location as one pre- or early post-transplant
application and one to two postemergence directed soil applications to
row middles at \~0.5 lb ai/A/application for total seasonal application
rates of 0.96 lb ai/A (2003 field trial) or 1.5 lb ai/A (1990 trials);
the 2003 trial included a treatment plot with two applications at an
exaggerated rate of \~2.5 lb ai/A/application for a total seasonal
application rate of \~5 lb ai/A. Shielded spray equipment was used for
all trials. The first applications were made one or 12 days prior to
transplanting or 5 days post-transplant; second applications were made
at 30- to 37-day retreatment intervals; and third applications were made
at 14- to 16-day retreatment intervals. First applications were made in
spray volumes of 31-34 gal/A, and second and third applications were
made in spray volumes of 55-60 gal/A; NIS or COC adjuvants were added to
the spray mixtures for all applications, except the pre-transplant
applications at the 2003 trial. Mature tomatoes were harvested 28-30
days following the last application.

Soil characteristics data were not provided for two pepper field trials
and one tomato trial; however, these data are not required at this time
because most of the relevant information is available from a reliable
public source. For future submissions, the petitioner is advised that
soil characteristics data must be provided for field trials reflecting
applications to soil.

The maximum storage intervals of samples from harvest to analysis were
60 days for peppers and 56 days for tomatoes. A freezer storage
stability study was conducted in conjunction with the 1990 magnitude of
the residue study on tomatoes. Residues of lactofen and metabolites
PPG-847, PPG-947, and PPG-2597 appeared to be relatively stable in/on
tomatoes stored frozen for up to 68 days. Residues of PPG-1576 were
found to decline in tomatoes, to \~60% of original value after 68 days
of storage. These data are adequate to support the storage intervals and
conditions of samples from the fruiting vegetable crop field trials.
Because residues of PPG-1576 were found to be below the LOD in/on all
tomato samples and below the LOQ in/on all pepper samples that were
analyzed for residues of PPG-1576, no correction for potential decline
during storage is needed.

Samples from the pepper and tomato field trials were [analyzed using
established gas chromatography with electron capture detection (GC/ECD)
enforcement methods or modified versions of established enforcement
methods. Pepper samples from the 1991 trial and tomato samples from the
1990 trials were analyzed for residues of lactofen and its metabolites
PPG-1576, PPG-2597, PPG-847, and PPG-947 using method RM-28 (Method B of
PAM Vol. II).]{.mark} The method was performed essentially as written
for analysis of tomatoes, but was modified significantly for analysis of
peppers. Samples of peppers and tomatoes from the 2003 trials were
[analyzed for residues of lactofen *per se* using method RM-28D-2 (rev.
8/12/03]{.mark}); method RM-28D is listed in the U.S. EPA Index of
Pesticide Analytical Methods. The validated limits of quantitation
(LOQs) were 0.01 ppm for peppers from the 1991 trial, and 0.02 ppm for
samples from all other trials. The methods are adequate for data
collection based on acceptable method validation and concurrent recovery
data.

[Residues of lactofen and metabolites were each below the LOQ (\<0.01
ppm for the 1991 pepper field trials and \<0.02 ppm for remaining pepper
and tomato field trials) in/on]{.mark} all samples of pepper and tomato
harvested \~30 days following a single pre- or early post-transplant and
one to two postemergence directed soil applications to row middles at
\~0.5 lb ai/A/application for total seasonal application rates of
\~1-1.5 lb ai/A.

No residue decline data were included in the submission; however,
because residues were below the LOQ in/on all samples, these data are
not required.

**[STUDY/WAIVER
ACCEPTABILITY/DEFICIENCIES/CLARIFICATIONS]{.underline}**:

Under the conditions and parameters used in the study, the field trial
residue data are classified as scientifically acceptable. The
acceptability of this study for regulatory purposes is addressed in the
forthcoming U.S. EPA Residue Chemistry Summary Document DP Barcode
D333151.

**[COMPLIANCE]{.underline}:**

Signed and dated Good Laboratory Practice (GLP), Quality Assurance and
Data Confidentiality statements were provided. No deviations from
regulatory requirements were reported which would have an impact on the
validity of the study.

**A. BACKGROUND INFORMATION**

[Lactofen \[1-(carboethoxy)ethyl-5-\[2-chloro-4-(trifluoromethyl)
phenoxy\]-2-nitrobenzoate\] is a selective contact, diphenyl ether
herbicide (Group 14) that is structurally related to acifluorfen and is
classified as a threshold carcinogen by EPA.]{.mark} Lactofen,
formulated as an EC, is currently registered by Valent U.S.A.
Corporation for preemergence and/or postemergence use on soybeans, snap
beans, and cotton for the control of broadleaf weeds, such as
nightshades, morning glories, pigweed, and ragweed. [Tolerances are
currently established for residues of the herbicide lactofen
(1-(carboethoxy)ethyl-5-\[2-chloro-4-(trifluoromethyl)phenoxy\]-2-nitrobenzoate)
on snap bean, cotton seed, peanut and soybean seed at 0.01 ppm and on
cotton gin products at 0.02 ppm \[40 CFR §180.432(a)\].]{.mark}

[Valent has submitted a petition (PP# 5E6930) proposing the use of
Cobra^®^ herbicide (EPA Reg. No. 59639-34) on fruiting
vegetables.]{.mark}

+-------------------+--------------------------------------------------+
| **TABLE A.1.      |                                                  |
| Lactofen          |                                                  |
| Nomenclature**.   |                                                  |
+===================+==================================================+
| Chemical          | ![                                               |
| structure         | ](media/image1.wmf){width="3.1798611111111112in" |
|                   | height="0.9006944444444445in"}                   |
+-------------------+--------------------------------------------------+
| Common name       | Lactofen                                         |
+-------------------+--------------------------------------------------+
| Company           | PPG-844                                          |
| experimental name |                                                  |
+-------------------+--------------------------------------------------+
| IUPAC name        | 1-(carboethoxy)ethyl-5-\[2-chl                   |
|                   | oro-4-(trifluoromethyl)phenoxy\]-2-nitrobenzoate |
+-------------------+--------------------------------------------------+
| CAS name          | 2-ethoxy-1-methyl-2-oxoethyl                     |
|                   | 5-\[2-chl                                        |
|                   | oro-4-(trifluoromethyl)phenoxy\]-2-nitrobenzoate |
+-------------------+--------------------------------------------------+
| CAS registry      | 77501-63-4                                       |
| number            |                                                  |
+-------------------+--------------------------------------------------+
| End-use product   | 2 lb/gal EC (Cobra ^®^ Herbicide; EPA Reg. No.   |
| (EP)              | 59639-34)                                        |
+-------------------+--------------------------------------------------+
| Chemical          | ![](media/image2.wmf){width="2.15in"             |
| structure of      | height="0.8986111111111111in"}                   |
| acifluorfen       |                                                  |
| (PPG-847)         | 5-\[2-ch                                         |
|                   | loro-4-(trifluoromethyl)phenoxy\]-2-nitrobenzoic |
|                   | acid                                             |
+-------------------+--------------------------------------------------+
| Chemical          | !                                                |
| structure of      | [](media/image3.wmf){width="2.740972222222222in" |
| desethyl lactofen | height="0.9006944444444445in"}                   |
| (PPG-947)         |                                                  |
|                   | 1-(carboxy)ethyl                                 |
|                   | 5-\[2-chl                                        |
|                   | oro-4-(trifluoromethyl)phenoxy\]-2-nitrobenzoate |
+-------------------+--------------------------------------------------+
| Chemical          | ![                                               |
| structure of      | ](media/image4.wmf){width="3.1798611111111112in" |
| amino lactofen    | height="0.9097222222222222in"}                   |
| (PPG-1576)        |                                                  |
|                   | 1-(carboethoxy)ethyl                             |
|                   | 5-\[2-chl                                        |
|                   | oro-4-(trifluoromethyl)phenoxy\]-2-aminobenzoate |
+-------------------+--------------------------------------------------+
| Chemical          | ![                                               |
| structure of      | ](media/image5.wmf){width="3.1798611111111112in" |
| N-formyl lactofen | height="0.9097222222222222in"}                   |
| (PPG-2597)        |                                                  |
|                   | 1-(carboethoxy)ethyl                             |
|                   | 5-\[2-chloro-                                    |
|                   | 4-(trifluoromethyl)phenoxy\]-2-formamidobenzoate |
+-------------------+--------------------------------------------------+
| Chemical          | ![                                               |
| structure of      | ](media/image6.wmf){width="3.1881944444444446in" |
| PPG-1530; Isomer  | height="0.9104166666666667in"}                   |
| A (internal       |                                                  |
| standard)         | 1-(carboethoxy)ethyl                             |
|                   | 5-\[2-chl                                        |
|                   | oro-4-(trifluoromethyl)phenoxy\]-6-nitrobenzoate |
+-------------------+--------------------------------------------------+

+-----------------+---------------------------------+-----------------+
| **TABLE A.2.    |                                 |                 |
| Physicochemical |                                 |                 |
| Properties of   |                                 |                 |
| Lactofen**      |                                 |                 |
+=================+=================================+=================+
| Parameter       | Value                           | Reference       |
+-----------------+---------------------------------+-----------------+
| Melting         | \>250°C                         | 44447003^1^     |
| point/range     |                                 |                 |
+-----------------+---------------------------------+-----------------+
| pH              | 7.2 (on Pure Active Ingredient, | 44447003^1^     |
|                 | 1% solution) at 25°C            |                 |
+-----------------+---------------------------------+-----------------+
| Density         | 1.34 at 24°C                    | 44447003^1^     |
| (specific       |                                 |                 |
| gravity)        |                                 |                 |
+-----------------+---------------------------------+-----------------+
| Water           | 0.97 ppm at 25°C                | 44447003^1^     |
| solubility      |                                 |                 |
|                 | 0.945 ± 0.131 ppm (column       | 44460902^2^     |
|                 | elution method at 20 ± 1 °C)    |                 |
+-----------------+---------------------------------+-----------------+
| Solvent         | [g/100 g at 23 °C]{.underline}  | 44447003^1^     |
| solubility      |                                 |                 |
|                 | kerosene 15.6                   |                 |
|                 |                                 |                 |
|                 | 2-ethyl-1-hexanol 18.4          |                 |
|                 |                                 |                 |
|                 | N-decanol 10.1                  |                 |
|                 |                                 |                 |
|                 | lactic acid 0.9                 |                 |
|                 |                                 |                 |
|                 | Lactofen is miscible at all     |                 |
|                 | proportions with the following  |                 |
|                 | solvents at -18°C or higher:    |                 |
|                 |                                 |                 |
|                 | DMSO, monochlorotoluene,        |                 |
|                 | dipropylene glycol dibenzoate,  |                 |
|                 | isophorone, cyclohexanone,      |                 |
|                 | mixed xylene, ethylene          |                 |
|                 | dichloride, acetone, DMF, amyl  |                 |
|                 | acetate, methyl isobutyl        |                 |
|                 | ketone.                         |                 |
+-----------------+---------------------------------+-----------------+
| Vapor pressure  | 3.69 ± 1.73 x 10^-5^ Pa (2.8 x  | 44460901^2^     |
|                 | 10-7 mm Hg)                     |                 |
+-----------------+---------------------------------+-----------------+
| Dissociation    | Not required                    | D241826,        |
| constant, pK~a~ |                                 | 1/16/98, H.     |
|                 |                                 | Podall          |
+-----------------+---------------------------------+-----------------+
| Octanol/water   | 1 x 10^5^ at ambient            | 44460903^2^     |
| partition       | temperature, estimated value    |                 |
| coefficient,    |                                 |                 |
| Log(K~OW~)      |                                 |                 |
+-----------------+---------------------------------+-----------------+
| UV/visible      | In Review ^3^                   | 44447003^3^     |
| absorption      |                                 |                 |
| spectrum        |                                 |                 |
+-----------------+---------------------------------+-----------------+

^1^ RD Memorandum, D241826, 1/16/98, H. Podall.

^2^ RD Memorandum D242241, 2/5/98, S. Mathur.

^3^ D332587, C. Olinger, In Review.

**B. EXPERIMENTAL DESIGN**

A total of three pepper trials were conducted in Zone 3 (FL) during the
1991 (one bell pepper trial) and 2003 (one bell and one nonbell pepper
trial) growing seasons. A total of four tomato field trials were
conducted in Zone 3 (FL) during the 1990 (three trials) and 2003 (one
trial) growing seasons.

The study use pattern is detailed in Table B.1.2. For the pepper field
trials, the 2 lb/gal EC formulation of lactofen was applied at each test
location as one pre-transplant and one postemergence directed soil
application to row middles at 0.49-0.51 lb ai/A/application for a total
seasonal application rate of 0.98-1.1 lb ai/A; shielded spray equipment
was used in the 2003 trials. The first applications were made one or 12
days prior to transplanting, and the second applications were made at
46- to 67-day retreatment intervals. First applications were made in
spray volumes of 31-33 gal/A, and second applications were made in spray
volumes of 55-59 gal/A; NIS or COC adjuvants were added to the spray
mixtures for second applications. Mature peppers were harvested 30 days
following the second application.

For the tomato field trials, the 2 lb/gal EC formulation of lactofen was
applied at each test location as one pre- or early post-transplant
application and one to two postemergence directed soil applications to
row middles at \~0.5 lb ai/A/application for total seasonal application
rates of 0.96 lb ai/A (2003 field trial) or 1.5 lb ai/A (1990 trials);
the 2003 trial included a treatment plot with two applications at an
exaggerated rate of \~2.5 lb ai/A/application for a total seasonal
application rate of \~5 lb ai/A. Shielded spray equipment was used for
all trials. The first applications were made one or 12 days prior to
transplanting or 5 days post-transplant; second applications were made
at 30- to 37-day retreatment intervals; and third applications were made
at 14- to 16-day retreatment intervals. First applications were made in
spray volumes of 31-34 gal/A, and second and third applications were
made in spray volumes of 55-60 gal/A; NIS or COC adjuvants were added to
the spray mixtures for all applications, except the pre-transplant
applications at the 2003 trial. Mature tomatoes were harvested 28-30
days following the last application.

Trial site conditions are presented in Table B.1.1. The crop varieties
grown are identified in Table C.3. Soil characteristics data were not
provided for the trials conducted at Citra, FL. These data would
generally be required because the submitted crop field trials reflect
directed application to the soil. However, these data will not be
required at this time because most of the relevant information is
available from a reliable public source. For future submissions, the
petitioner is advised that soil characteristics data must be provided
for field trials reflecting applications to soil. We note that both
tomato varieties used in the crop field trials produce medium to large
fruits.

The petitioner provided acceptable daily, monthly, and/or historical
weather data (temperature and rainfall) for all field trial sites, as
well as descriptions of cultural procedures; maintenance chemicals and
fertilizers used at each site were identified. Irrigation was used at
all sites. The weather was reported to be normal for all field trials
except the 1990 tomato field trials, where 10" of rain were received due
to a tropical storm 3 days before the third application. The petitioner
stated that this event was not believed to have significantly affected
the results of the study.

**B.1. Study Site Information**

+-----------------------+-----------------+--------+-------+---------+
| **TABLE B.1.1. Trial  |                 |        |       |         |
| Site Conditions.**    |                 |        |       |         |
+=======================+=================+========+=======+=========+
| Trial Identification  | Soil            |        |       |         |
| (City, State; Year;   | characteristics |        |       |         |
| Trial ID #); MRID     | ^1^             |        |       |         |
+-----------------------+-----------------+--------+-------+---------+
|                       | Type            | %OM    | pH    | CEC     |
|                       |                 |        |       |         |
|                       |                 |        |       | (meq/g) |
+-----------------------+-----------------+--------+-------+---------+
| **Pepper**            |                 |        |       |         |
+-----------------------+-----------------+--------+-------+---------+
| Myakka City, FL 1991; | Fine sand       | 0.8    | 7.0   | 4.2     |
| 46531301              |                 |        |       |         |
+-----------------------+-----------------+--------+-------+---------+
| Citra, FL 2003;       | NR \[Fine       | NR     | NR    | NR      |
| V25304-A; 46597202    | sand\]          | \[1%\] | \[    |         |
|                       |                 |        | 6.4\] |         |
+-----------------------+-----------------+--------+-------+---------+
| Citra, FL 2003;       | NR \[Fine       | NR     | NR    | NR      |
| V25304-B; 46597202    | sand\]          | \[1%\] | \[    |         |
|                       |                 |        | 6.4\] |         |
+-----------------------+-----------------+--------+-------+---------+
| **Tomato**            |                 |        |       |         |
+-----------------------+-----------------+--------+-------+---------+
| Immokalee, FL, 1990;  | Sand            | 1.8    | 6.8   | 3.8     |
| T-7554; 46597203      |                 |        |       |         |
+-----------------------+-----------------+--------+-------+---------+
| Bradenton, FL, 1990;  | Sand            | 1.6    | 6.7   | 5.1     |
| T-7555; 46597203      |                 |        |       |         |
+-----------------------+-----------------+--------+-------+---------+
| Bradenton, FL, 1990;  | Sand            | 1.9    | 7.0   | 5.3     |
| T-7556; 46597203      |                 |        |       |         |
+-----------------------+-----------------+--------+-------+---------+
| Citra, FL, 2003;      | NR \[Fine       | NR     | NR    | NR      |
| V-25291-A; 45697201   | sand\]          | \[1%\] | \[    |         |
|                       |                 |        | 6.4\] |         |
+-----------------------+-----------------+--------+-------+---------+

^1^ NR = Not reported; these data are required because the submitted
crop field trials reflect directed application to the soil. The
\[bracketed\] information was obtained by the study reviewer from
several University of FL Internet listings.

+-------+-----+-------------------+-----+-----+----+-------+---------+
| **    |     |                   |     |     |    |       |         |
| TABLE |     |                   |     |     |    |       |         |
| B     |     |                   |     |     |    |       |         |
| .1.2. |     |                   |     |     |    |       |         |
| Study |     |                   |     |     |    |       |         |
| Use   |     |                   |     |     |    |       |         |
| Patte |     |                   |     |     |    |       |         |
| rn.** |     |                   |     |     |    |       |         |
+=======+=====+===================+=====+=====+====+=======+=========+
| Loc   | EP  | Application       |     |     |    |       | Tank    |
| ation | ^1^ |                   |     |     |    |       | Mix/    |
|       |     |                   |     |     |    |       | Ad      |
| (     |     |                   |     |     |    |       | juvants |
| City, |     |                   |     |     |    |       | ^4^     |
| S     |     |                   |     |     |    |       |         |
| tate; |     |                   |     |     |    |       |         |
| Year) |     |                   |     |     |    |       |         |
|       |     |                   |     |     |    |       |         |
| Trial |     |                   |     |     |    |       |         |
| ID    |     |                   |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | Method; Timing    | Vol | R   | RT | Total |         |
|       |     |                   | ume | ate | I^ | Rate  |         |
|       |     |                   |     |     | 3^ | (lb   |         |
|       |     |                   | (G  | (lb | (d | ai/A) |         |
|       |     |                   | PA) | ai  | ay |       |         |
|       |     |                   | ^2^ | /A) | s) |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
| **Pep |     |                   |     |     |    |       |         |
| per** |     |                   |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
| M     | 2.0 | 1\. Directed to   | 30  | 0.5 | \  | 1.0   | \--     |
| yakka | lb/ | soil; one day     |     |     | -- |       |         |
| City, | gal | before transplant |     |     |    |       |         |
| FL    | EC  |                   |     |     |    |       |         |
| 1991; |     |                   |     |     |    |       |         |
| 465   |     |                   |     |     |    |       |         |
| 31301 |     |                   |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 2\. Directed to   | 60  | 0.5 | 46 |       | NIS     |
|       |     | soil; crown fruit |     |     |    |       |         |
|       |     | 2" diameter;      |     |     |    |       |         |
|       |     | plant height 13"  |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
| C     | 2.0 | 1\. Directed to   | 31  | 0   | \  | 1.1   | \--     |
| itra, | lb/ | soil, shielded;   |     | .50 | -- |       |         |
| FL    | gal | 12 days before    |     |     |    |       |         |
| 2003; | EC  | transplant        |     |     |    |       |         |
| V253  |     |                   |     |     |    |       |         |
| 04-A; |     |                   |     |     |    |       |         |
| 465   |     |                   |     |     |    |       |         |
| 97202 |     |                   |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 2\. Directed to   | 59  | 0   | 67 |       | COC     |
|       |     | soil, shielded;   |     | .51 |    |       |         |
|       |     | fruiting, small   |     |     |    |       |         |
|       |     | to med-small      |     |     |    |       |         |
|       |     | fruit             |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
| C     | 2.0 | 1\. Directed to   | 31  | 0   | \  | 0.98  | \--     |
| itra, | lb/ | soil, shielded;   |     | .49 | -- |       |         |
| FL    | gal | 12 days before    |     |     |    |       |         |
| 2003; | EC  | transplant        |     |     |    |       |         |
| V253  |     |                   |     |     |    |       |         |
| 04-B; |     |                   |     |     |    |       |         |
| 465   |     |                   |     |     |    |       |         |
| 97202 |     |                   |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 2\. Directed to   | 56  | 0   | 67 |       | COC     |
|       |     | soil, shielded;   |     | .49 |    |       |         |
|       |     | fruiting, small   |     |     |    |       |         |
|       |     | to med-small      |     |     |    |       |         |
|       |     | fruit             |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
| **Tom |     |                   |     |     |    |       |         |
| ato** |     |                   |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
| Immok | 2.0 | 1\. Directed to   | 34  | 0.5 | \  | 1.5   | NIS     |
| alee, | lb/ | soil; shielded;   |     |     | -- |       |         |
| FL,   | gal | one day before    |     |     |    |       |         |
| 1990; | EC  | transplant        |     |     |    |       |         |
| T-    |     |                   |     |     |    |       |         |
| 7554; |     |                   |     |     |    |       |         |
| 465   |     |                   |     |     |    |       |         |
| 97203 |     |                   |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 2\. Directed to   | 60  | 0.5 | 35 |       | NIS     |
|       |     | soil; shielded;   |     |     |    |       |         |
|       |     | early bloom;      |     |     |    |       |         |
|       |     | plant height      |     |     |    |       |         |
|       |     | 20-26"            |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 3\. Directed to   | 60  | 0.5 | 14 |       | NIS     |
|       |     | soil; shielded;   |     |     |    |       |         |
|       |     | early fruit-set;  |     |     |    |       |         |
|       |     | plant height      |     |     |    |       |         |
|       |     | 28-34"            |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
| Brade | 2.0 | 1\. Directed to   | 32  | 0.5 | \  | 1.5   | NIS     |
| nton, | lb/ | soil; shielded; 5 |     |     | -- |       |         |
| FL,   | gal | days              |     |     |    |       |         |
| 1990; | EC  | post-transplant   |     |     |    |       |         |
|       |     |                   |     |     |    |       |         |
| T-    |     |                   |     |     |    |       |         |
| 7555; |     |                   |     |     |    |       |         |
| 465   |     |                   |     |     |    |       |         |
| 97203 |     |                   |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 2\. Directed to   | 52  | 0.5 | 37 |       | NIS     |
|       |     | soil; shielded;   |     |     |    |       |         |
|       |     | 1^st^ bloom       |     |     |    |       |         |
|       |     | cluster open;     |     |     |    |       |         |
|       |     | plant height 20"  |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 3\. Directed to   | 55  | 0.5 | 16 |       | NIS     |
|       |     | soil; shielded;   |     |     |    |       |         |
|       |     | 1^st^ hand fruit  |     |     |    |       |         |
|       |     | 2" diam.; plant   |     |     |    |       |         |
|       |     | height 28"        |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
| Brade | 2.0 | 1\. Directed to   | 32  | 0.5 | \  | 1.5   | NIS     |
| nton, | lb/ | soil; shielded; 5 |     |     | -- |       |         |
| FL,   | gal | days              |     |     |    |       |         |
| 1990; | EC  | post-transplant   |     |     |    |       |         |
|       |     |                   |     |     |    |       |         |
| T-    |     |                   |     |     |    |       |         |
| 7556; |     |                   |     |     |    |       |         |
| 465   |     |                   |     |     |    |       |         |
| 97203 |     |                   |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 2\. Directed to   | 52  | 0.5 | 37 |       | NIS     |
|       |     | soil; shielded;   |     |     |    |       |         |
|       |     | 1^st^ bloom       |     |     |    |       |         |
|       |     | cluster open;     |     |     |    |       |         |
|       |     | plant height 24"  |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 3\. Directed to   | 55  | 0.5 | 16 |       | NIS     |
|       |     | soil; shielded;   |     |     |    |       |         |
|       |     | 1^st^ hand fruit  |     |     |    |       |         |
|       |     | 1 ¾ -2" diam.;    |     |     |    |       |         |
|       |     | plant height      |     |     |    |       |         |
|       |     | 28-30"            |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
| C     | 2.0 | 1\. Directed to   | 3   | 0   | \  | 0.96  | \--     |
| itra, | lb/ | soil, shielded;   | 0.5 | .49 | -- |       |         |
| FL,   | gal | 12 days before    |     |     |    |       |         |
| 2003; | EC  | transplant        |     |     |    |       |         |
| V-252 |     |                   |     |     |    |       |         |
| 91-A; |     |                   |     |     |    |       |         |
| 456   |     |                   |     |     |    |       |         |
| 97201 |     |                   |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 2\. Directed to   | 5   | 0   | 30 |       | COC     |
|       |     | soil, shielded;   | 4.6 | .47 |    |       |         |
|       |     | small green       |     |     |    |       |         |
|       |     | fruit; plant      |     |     |    |       |         |
|       |     | height 2-3'       |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       | 2.0 | 1\. Directed to   | 3   | 2   | \  | 4.9   | \--     |
|       | lb/ | soil, shielded;   | 1.3 | .50 | -- |       |         |
|       | gal | 12 days before    |     |     |    |       |         |
|       | EC  | transplant        |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+
|       |     | 2\. Directed to   | 5   | 2   | 30 |       | COC     |
|       |     | soil, shielded;   | 6.3 | .40 |    |       |         |
|       |     | small green       |     |     |    |       |         |
|       |     | fruit; plant      |     |     |    |       |         |
|       |     | height 2-3'       |     |     |    |       |         |
+-------+-----+-------------------+-----+-----+----+-------+---------+

^1^ EP = End-use Product

^2^ GPA = Gallons per acre

^3^ RTI = Retreatment Interval

^4^ NIS = Nonionic surfactant; COC = crop oil concentrate

  -----------------------------------------------------------------------------------------
  **TABLE B.1.3.                                                                   
  Trial Numbers                                                                    
  and                                                                              
  Geographical                                                                     
  Locations**.                                                                     
  -------------- --------------- ----------- --------- --------------- ----------- --------
  NAFTA Growing  Pepper                                Tomato                      
  Zones                                                                            

                 Submitted       Requested             Submitted       Requested   
                                 ^1^                                   ^1^         

                                 Canada      U.S.                      Canada      U.S.

  1                                                                                1

  1A                                                                               

  2                                          1 (bell)                              1

  3              3 (2 bell and 1             1 (bell)  4                           2
                 non-bell)                                                         

  4                                                                                

  5                                          1 (bell)                              1

  5A                                                                               

  5B                                                                               

  6                                          1 (bell)                              

  7                                                                                

  7A                                                                               

  8                                                                                

  9                                                                                

  10                                         2 (bell)                              7

  11                                                                               

  12                                                                               

  13                                                                               

  14                                                                               

  15                                                                               

  16                                                                               

  17                                                                               

  18                                                                               

  19                                                                               

  20                                                                               

  21                                                                               

  Total          3                           6 bell +  4                           12
                                             3 nonbell                             
                                             ^2^                                   
  -----------------------------------------------------------------------------------------

^1^ As required by OPPTS 860.1500, Tables 2 and 5, for peppers and
tomatoes as representative members of the fruiting vegetables crop
group. The number of trials for each represents a 25% reduction due to
the crop being a representative commodity used to obtain a crop group
tolerance, or due to the pesticidal use resulting in no quantifiable
residues.

^2^ Specific regions are not recommended for non-bell peppers, because
only 3 trials are required; however, according to Table 6 of OPPTS
860.1500, U.S. production of non-bell peppers occurs in Zones 2 (4%), 3
(3%), 5 (4%), 8 (50%), 9 (15%), and 10 (18%).

**B.2. Sample Handling and Preparation**

Single control and duplicate treated samples of peppers and tomatoes
were harvested from each site at commercial maturity, 28-30 days
following the second or third application. For the 1990 tomato field
trials, the petitioner reported that mature green tomatoes were
harvested according to commercial agricultural practices. Pepper samples
were placed in frozen storage at the field sites within 30 minutes of
harvest. Tomato samples from the 2003 trial and green tomatoes from the
1990 trials were placed in frozen storage at the field sites within 3.5
hours of harvest; additional samples from the Bradenton, FL sites were
placed in a ripening room (temperature unspecified) immediately
following harvest, and were held there for 6 days until they had been
degreened; degreened tomatoes were then placed in frozen storage until
shipment. Samples were shipped frozen within 1-15 days of harvest to the
analytical laboratories: the Bioanalytical Laboratory; Oregon State
University (Corvallis, OR) for the 1991 pepper trial; Chevron Technical
Center (Richmond, CA) for the 1990 tomato trials; or Valent Technical
Center (Dublin CA) for the 2003 pepper and tomato trials. Samples were
stored frozen (\~-20 °C) at the analytical laboratories until
preparation for analysis via chopping or macerating with dry ice.

**B.3. Analytical Methodology**

Samples from the [pepper and tomato field trials were analyzed using
established GC/ECD enforcement methods or modified versions of
established enforcement methods.]{.mark} Pepper samples from the 1991
trial and tomato samples from the 1990 trials were analyzed for residues
of lactofen and its metabolites PPG-1576, PPG-2597, PPG-847, and PPG-947
using method RM-28 (Method B of PAM Vol. II). The method was performed
essentially as written for analysis of tomatoes, but was modified
significantly for analysis of peppers. Modifications to the analytical
method for peppers included: (1) conducting the acetonitrile
(ACN):hexane partitioning earlier in the procedure; (2) separation of
the acid metabolites (PPG-847 and PPG-947) from lactofen and the ester
metabolites (PPG-1576 and PPG-2597) for analysis; and (3) addition of a
two-column clean-up procedure for the acid metabolites. Samples of
peppers and tomatoes from the 2003 trials were analyzed for residues of
lactofen *per se* using method RM-28D-2 (rev. 8/12/03); method RM-28D is
listed in the U.S. EPA Index of Pesticide Analytical Methods.

Using the modified version of method RM-28, samples from the 1991 pepper
field trial were extracted 2x with ACN containing 1% triethylamine
(TEA):hexane (2:1, v:v) and filtered, and the extracts were combined.
Following phase separation, the ACN phase was extracted with two
additional aliquots of hexane; all hexane phases were discarded. The ACN
extract was combined with 5% NaCl solution and partitioned 3x with
hexane. The resulting extracts were combined to yield an aqueous ACN
extract and a hexane extract. The hexane extracts, containing lactofen
and the ester metabolites, were concentrated and applied to a silica gel
column for clean-up. Residues were eluted with dichloromethane
(DCM):hexane (70:30, v:v), and the eluate was concentrated, combined
with an internal standard mixture of CGA-1530 (lactofen Isomer A) and
CGA-1827 (standard was not identified), and reserved for GC analysis.
The aqueous ACN extract, containing the acid metabolites, was acidified
with 6 N HCl and extracted 3x with toluene. The combined toluene
extracts were applied to a basic alumina column, and residues were
eluted with 1% sodium bicarbonate solution. The eluate was acidified
with 6 N HCl and extracted 3x with DCM. Diazomethane was added to the
combined DCM extracts to methylate the acid metabolites, and the mixture
was reduced to dryness and re-dissolved in benzene, then applied to a
second alumina column. Residues were eluted with benzene, concentrated,
combined with the internal standard mixture, and reserved for GC
analysis. Lactofen and the ester metabolites were determined using an
SPB-5 column, and the acid metabolites were determined using a DB-1701
column. The validated LOQ was 0.01 ppm (lowest limit of method
validation; LLMV), and the reported limit of detection (LOD) was 0.005
ppm for lactofen and each metabolite.

Using method RM-28, samples from the 1990 tomato field trials were
extracted 2x with ACN containing 1% TEA and filtered. The resulting
extract was evaporated to dryness, re-dissolved in 5% NaCl solution,
then partitioned with DCM (3x). The resulting DCM phases were combined,
reduced to dryness, dissolved in ACN, and combined with diazomethane to
methylate the acid metabolites. The methylated extract was dissolved in
DCM:hexane (70:30, v:v), and applied to a silica gel column. Residues
were eluted with DCM:hexane (70:30, v:v), and the eluate was
concentrated, combined with an internal standard of CGA-1530 (lactofen
Isomer A) in toluene, and reserved for GC analysis using a DB-5 or
DB-1701 column. We note that the method included modified instructions
for analysis of residues of PPG1576 alone to improve recoveries; the
petitioner did not indicate whether these procedures were followed. The
validated LOQ (LLMV) was 0.02 ppm, and the LOD was 0.01 ppm for lactofen
and each metabolite.

Using method RM-28D-2, samples of peppers and tomatoes from the 2003
trials were extracted 2x with ethanol and filtered. The combined
extracts were reduced by rotary evaporation and sonicated with ACN
saturated with hexane, followed by 5% NaCl solution, and hexane. The
resulting ACN:water phase was re-extracted 2x with hexane, and the
hexane extracts were combined with the original hexane phase. The
combined hexane phase was evaporated to dryness and redissolved in
toluene:hexane (1:2, v:v), then applied to a silica gel column for
clean-up. Residues were eluted with hexane:diethyl ether (60:40, v:v),
and the eluate was evaporated to dryness and dissolved in toluene for
analysis by GC/ECD on a DB-17 column. The validated LOQ was 0.02 ppm
(LLMV), and the reported LOD was 0.01 ppm for lactofen in both matrices.

**C. RESULTS AND DISCUSSION**

Sample storage conditions and intervals are summarized in Table C.2.1.
The maximum storage intervals of samples from harvest to analysis were
60 days for peppers and 56 days for tomatoes. A freezer storage
stability study was conducted in conjunction with the 1990 magnitude of
the residue study on tomatoes. Untreated samples of tomato were
fortified with lactofen, PPG-847, PPG-947, PPG-1576, and PPG-2597 at 0.1
ppm each, and stored frozen. Stored samples were analyzed at 0-day and
following frozen storage for 32 and 68 days. Residues of lactofen, and
all metabolites except PPG-1576 appeared to be relatively stable (Table
C.2.2) in/on tomatoes stored frozen for up to 68 days. Residues of
PPG-1576 were found to decline in tomatoes, to \~60% of original value
after 68 days of storage. These data are adequate to support the storage
intervals and conditions of samples from the fruiting vegetable crop
field trials. Because residues of PPG-1576 were found to be below the
LOD in/on all tomato samples and below the LOQ in/on all pepper samples
that were analyzed for residues of PPG-1576, no correction for potential
decline during storage is needed.

Method validation and concurrent recovery data are presented in Table
C.1. Samples from the pepper and tomato field trials were analyzed using
established GC/ECD enforcement methods or modified versions of
established enforcement methods. Pepper samples from the 1991 trial and
tomato samples from the 1990 trials were analyzed for residues of
lactofen and its metabolites PPG-1576, PPG-2597, PPG-847, and PPG-947
using method RM-28 (Method B of PAM Vol. II). The method was performed
essentially as written for analysis of tomatoes, but was modified
significantly for analysis of peppers. Samples of peppers and tomatoes
from the 2003 trials were analyzed for residues of lactofen *per se*
using method RM-28D-2 (rev. 8/12/03); method RM-28D is listed in the
U.S. EPA Index of Pesticide Analytical Methods. The validated LOQ and
LOD were 0.01 ppm and 0.005 ppm, respectively, for peppers from the 1991
trial, and 0.02 ppm and 0.01 ppm, respectively, for samples from all
other trials. The methods are adequate for data collection based on
acceptable method validation and concurrent recovery data. Method
validation was conducted for method RM-28D-2 using tomato during method
development; recoveries were 103-104% for tomato fortified at 0.02 ppm.
Concurrent recoveries of lactofen ranged 90-93% for pepper fortified at
0.01 ppm and 93-117% for pepper and tomato fortified at 0.02 ppm.
Recoveries of the lactofen metabolites ranged 73-114% from samples of
pepper fortified at 0.01 ppm and tomato fortified at 0.02 ppm. Apparent
residues of lactofen and metabolites were nondetectable in/on all
samples of untreated pepper and tomato.

[The results of the fruiting vegetable crop field trials are reported in
Table C.3. A summary of the residue data is presented in Table C.4.
Residues of lactofen and metabolites were each below the LOQ (\<0.01 ppm
for the 1991 pepper field trials and \<0.02 ppm for remaining pepper and
tomato field trials) in/on all samples of pepper and tomato harvested
\~30 days following a single pre- or early post-transplant and one to
two postemergence directed soil applications to row middles at \~0.5 lb
ai/A/application for total seasonal application rates of \~1-1.5 lb
ai/A.]{.mark}

[]{.mark}

[No residue decline data were included in the submission; however,
because residues were below the LOQ in/on all samples, these data are
not required.]{.mark}

+--------------+--------+--------+---------+-----------------+---------+
| **TABLE C.1. |        |        |         |                 |         |
| Summary of   |        |        |         |                 |         |
| Method       |        |        |         |                 |         |
| Validation   |        |        |         |                 |         |
| and          |        |        |         |                 |         |
| Concurrent   |        |        |         |                 |         |
| Recoveries   |        |        |         |                 |         |
| of Lactofen  |        |        |         |                 |         |
| Residues     |        |        |         |                 |         |
| from Pepper  |        |        |         |                 |         |
| and          |        |        |         |                 |         |
| Tomato.**    |        |        |         |                 |         |
+==============+========+========+=========+=================+=========+
| Matrix       | A      | Spike  | Sample  | Recoveries      | Mean   |
|              | nalyte | level  | size    |                 | std dev |
| (Method)     |        |        |         | (%)             |         |
|              |        | (ppm)  | \(n\)   |                 | (%) ^1^ |
+--------------+--------+--------+---------+-----------------+---------+
| **Method     |        |        |         |                 |         |
| validation** |        |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
| Tomato ^2^   | La     | 0.02   | 3       | 103, 105, 105   | 104 ± 1 |
|              | ctofen |        |         |                 |         |
| (RM-28D-2;   |        |        |         |                 |         |
|              |        |        |         |                 |         |
| DB-17        |        |        |         |                 |         |
| column)      |        |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
| Tomato       | La     | 0.02   | 3       | 101, 103, 104   | 103 ± 2 |
|              | ctofen |        |         |                 |         |
| (RM-28D-2;   |        |        |         |                 |         |
|              |        |        |         |                 |         |
| DB-5 column) |        |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
| **Concurrent |        |        |         |                 |         |
| recovery**   |        |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
| Pepper       | La     | 0.01   | 2       | 90, 93          | 92      |
|              | ctofen |        |         |                 |         |
| (RM-28)      |        |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
|              | P      | 0.01   | 1       | 97              | \--     |
|              | PG-847 |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
|              | P      | 0.01   | 1       | 107             | \--     |
|              | PG-947 |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
|              | PP     | 0.01   | 2       | 81, 86          | 84      |
|              | G-1576 |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
|              | PP     | 0.01   | 2       | 100, 114        | 107     |
|              | G-2597 |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
| Pepper       | La     | 0.02   | 2       | 103, 117        | 110     |
|              | ctofen |        |         |                 |         |
| (RM-28D-2)   |        |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
|              |        | 0.1    | 2       | 98, 108         | 103     |
+--------------+--------+--------+---------+-----------------+---------+
| Tomato ^2^   | La     | 0.02   | 5       | 93, 93, 95, 96, | 95 ± 3  |
|              | ctofen |        |         | 100             |         |
| (RM-28)      |        |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
|              | P      | 0.02   | 5       | 89, 99, 104,    | 102 ± 9 |
|              | PG-847 |        |         | 106, 113        |         |
+--------------+--------+--------+---------+-----------------+---------+
|              | P      | 0.02   | 5       | 97, 98, 102,    | 101 ± 4 |
|              | PG-947 |        |         | 104, 105        |         |
+--------------+--------+--------+---------+-----------------+---------+
|              | PP     | 0.02   | 5       | 73, 75, 75, 78, | 77 ± 5  |
|              | G-1576 |        |         | 86              |         |
+--------------+--------+--------+---------+-----------------+---------+
|              | PP     | 0.02   | 5       | 76, 81, 87, 89, | 85 ± 7  |
|              | G-2597 |        |         | 93              |         |
+--------------+--------+--------+---------+-----------------+---------+
| Tomato       | La     | 0.02   | 2       | 108, 112        | 110     |
|              | ctofen |        |         |                 |         |
| (RM-28D-2)   |        |        |         |                 |         |
+--------------+--------+--------+---------+-----------------+---------+
|              |        | 0.10   | 1       | 87              | \--     |
+--------------+--------+--------+---------+-----------------+---------+

^1^ Standard deviations were only calculated for samples sizes ≥3.

^2^ Including green and degreened tomatoes.

+-----------------+-----------------+-----------------+-----------------+
| **TABLE C.2.    |                 |                 |                 |
| Summary of      |                 |                 |                 |
| Storage         |                 |                 |                 |
| Conditions.**   |                 |                 |                 |
+=================+=================+=================+=================+
| Matrix          | Storage         | Actual Storage  | Interval of     |
|                 | Temperature     | Duration ^1^    | Demonstrated    |
|                 |                 |                 | Storage         |
|                 | (°C)            | (days)          | Stability       |
+-----------------+-----------------+-----------------+-----------------+
| Pepper          | -20             | 39-60           | Residues of     |
|                 |                 |                 | lactofen and    |
|                 |                 |                 | metabolites     |
|                 |                 |                 | were relatively |
|                 |                 |                 | stable in/on    |
|                 |                 |                 | tomato stored   |
|                 |                 |                 | frozen for up   |
|                 |                 |                 | to 68 days      |
+-----------------+-----------------+-----------------+-----------------+
| Tomato          | -20             | 22-56           |                 |
+-----------------+-----------------+-----------------+-----------------+

^1^ Interval from harvest to analysis; samples were analyzed within 2-9
days of extraction.

+---------+--------+--------+------------+--------------+-------------+
| **TABLE |        |        |            |              |             |
| C.2.2   |        |        |            |              |             |
| St      |        |        |            |              |             |
| ability |        |        |            |              |             |
| of      |        |        |            |              |             |
| L       |        |        |            |              |             |
| actofen |        |        |            |              |             |
| R       |        |        |            |              |             |
| esidues |        |        |            |              |             |
| in      |        |        |            |              |             |
| Frozen  |        |        |            |              |             |
| Toma    |        |        |            |              |             |
| toes.** |        |        |            |              |             |
+=========+========+========+============+==============+=============+
| Analyte | Spike  | S      | Freshly    | Stored       | Average     |
|         | Level  | torage | Fortified  | Sample       | Corrected   |
|         |        | in     | Recovery   | Residues (%) | Stored      |
|         | (ppm)  | terval | (%)        | \[Average\]  | Recovery    |
|         |        | (days) |            |              | (%)^1^      |
+---------+--------+--------+------------+--------------+-------------+
| L       | 0.1    | 0      | 101        | 97, 102      | 99          |
| actofen |        |        |            | \[100\]      |             |
+---------+--------+--------+------------+--------------+-------------+
|         |        | 32     | 96         | 91, 95       | 97          |
|         |        |        |            | \[93\]       |             |
+---------+--------+--------+------------+--------------+-------------+
|         |        | 68     | 101        | 79, 86       | 82          |
|         |        |        |            | \[83\]       |             |
+---------+--------+--------+------------+--------------+-------------+
| PPG-847 | 0.1    | 0      | 109        | 119, 121     | 110         |
|         |        |        |            | \[120\]      |             |
+---------+--------+--------+------------+--------------+-------------+
|         |        | 32     | 110        | 103, 109     | 96          |
|         |        |        |            | \[106\]      |             |
+---------+--------+--------+------------+--------------+-------------+
|         |        | 68     | 121        | 97, 101      | 82          |
|         |        |        |            | \[99\]       |             |
+---------+--------+--------+------------+--------------+-------------+
| PPG-947 | 0.1    | 0      | 101        | 99, 100      | 99          |
|         |        |        |            | \[100\]      |             |
+---------+--------+--------+------------+--------------+-------------+
|         |        | 32     | 94         | 91, 98       | 95          |
|         |        |        |            | \[95\]       |             |
+---------+--------+--------+------------+--------------+-------------+
|         |        | 68     | 107        | 89, 97       | 87          |
|         |        |        |            | \[93\]       |             |
+---------+--------+--------+------------+--------------+-------------+
| P       | 0.1    | 0      | 55         | 55, 57       | 102         |
| PG-1576 |        |        |            | \[56\]       |             |
+---------+--------+--------+------------+--------------+-------------+
|         |        | 32     | 92         | 69, 73       | 78          |
|         |        |        |            | \[72\]       |             |
+---------+--------+--------+------------+--------------+-------------+
|         |        | 68     | 86         | 48, 52       | 58          |
|         |        |        |            | \[50\]       |             |
+---------+--------+--------+------------+--------------+-------------+
| P       | 0.1    | 0      | 94         | 88, 94       | 97          |
| PG-2597 |        |        |            | \[91\]       |             |
+---------+--------+--------+------------+--------------+-------------+
|         |        | 32     | 76         | 70, 73       | 95          |
|         |        |        |            | \[72\]       |             |
+---------+--------+--------+------------+--------------+-------------+
|         |        | 68     | 96         | 85, 89       | 91          |
|         |        |        |            | \[87\]       |             |
+---------+--------+--------+------------+--------------+-------------+

^1^ Residues were corrected for recovery from freshly fortified samples.

[]{.mark}

<table>
<colgroup>
<col style="width: 14%" />
<col style="width: 5%" />
<col style="width: 9%" />
<col style="width: 11%" />
<col style="width: 8%" />
<col style="width: 6%" />
<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 C.3. Residue Data from Pepper and Tomato
Field Trials with Lactofen</strong></th>
</tr>
<tr class="odd">
<th rowspan="2"><p>Trial ID</p>
<p>(City, State; Year); MRID</p></th>
<th rowspan="2">Zone</th>
<th rowspan="2">Variety</th>
<th rowspan="2">Commodity or Matrix</th>
<th rowspan="2"><p>Total Rate</p>
<p>(lb ai/A)</p></th>
<th rowspan="2">PHI (days)</th>
<th colspan="5">Residues (ppm)<sup>1</sup></th>
</tr>
<tr class="header">
<th>Lactofen</th>
<th>PPG-847</th>
<th>PPG-947</th>
<th>PPG-1576</th>
<th>PPG-2597</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="11"><strong>Pepper</strong></td>
</tr>
<tr class="even">
<td>Myakka City, FL 1991; 46531301</td>
<td>3</td>
<td>Memphis</td>
<td>Bell pepper</td>
<td>1.0</td>
<td>30</td>
<td>&lt;0.01, &lt;0.01</td>
<td>&lt;0.01, &lt;0.01</td>
<td>&lt;0.01, &lt;0.01</td>
<td>&lt;0.01, &lt;0.01</td>
<td>&lt;0.01, &lt;0.01</td>
</tr>
<tr class="odd">
<td>Citra, FL 2003; V25304-A; 46597202</td>
<td>3</td>
<td>Camelot</td>
<td>Bell pepper</td>
<td>1.1</td>
<td>30</td>
<td>ND, ND</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="even">
<td>Citra, FL 2003; V25304-B; 46597202</td>
<td>3</td>
<td>Hot Beauty</td>
<td>Nonbell Pepper</td>
<td>0.98</td>
<td>30</td>
<td>ND, ND</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="odd">
<td colspan="11"><strong>Tomato</strong></td>
</tr>
<tr class="even">
<td>Immokalee, FL, 1990; T-7554; 46597203</td>
<td>3</td>
<td>Solar Set</td>
<td>Tomato (green)</td>
<td>1.5</td>
<td>28</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
</tr>
<tr class="odd">
<td rowspan="2"><p>Bradenton, FL, 1990;</p>
<p>T-7555; 46597203</p></td>
<td rowspan="2">3</td>
<td rowspan="2">Solar Set</td>
<td>Tomato (green)</td>
<td rowspan="2">1.5</td>
<td>30</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
</tr>
<tr class="even">
<td>Tomato (degreened)</td>
<td></td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
</tr>
<tr class="odd">
<td rowspan="2"><p>Bradenton, FL, 1990;</p>
<p>T-7556; 46597203</p></td>
<td rowspan="2">3</td>
<td rowspan="2">Sunny</td>
<td>Tomato (green)</td>
<td rowspan="2">1.5</td>
<td>30</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
</tr>
<tr class="even">
<td>Tomato (degreened)</td>
<td></td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
<td>ND, ND</td>
</tr>
<tr class="odd">
<td rowspan="2"><p>Citra, FL, 2003;</p>
<p>V-25291-A; 46597203</p></td>
<td rowspan="2">3</td>
<td rowspan="2">FLA47</td>
<td rowspan="2">Tomato</td>
<td>0.96</td>
<td>30</td>
<td>ND, ND</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
<tr class="even">
<td>4.9</td>
<td>30</td>
<td>ND, ND</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
<td>NA</td>
</tr>
</tbody>
</table>

^1^ ND = Nondetectable. NA = Not analyzed. The reported LOQs were 0.01
ppm for the 1991 pepper field trial, and 0.02 ppm for all other field
trials, and the reported LODs were 0.003 ppm for the 1991 pepper field
trial, and 0.01 ppm for all other trials; we note that values were
reported by the petitioner as \<0.01 ppm for all samples analyzed.

<table style="width:100%;">
<colgroup>
<col style="width: 13%" />
<col style="width: 12%" />
<col style="width: 7%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 7%" />
<col style="width: 9%" />
<col style="width: 12%" />
<col style="width: 10%" />
<col style="width: 10%" />
</colgroup>
<thead>
<tr class="header">
<th colspan="10"><strong>TABLE C.4. Summary of Residue Data from Pepper
Field Trials with Lactofen.</strong></th>
</tr>
<tr class="odd">
<th rowspan="2">Commodity</th>
<th rowspan="2"><p>Total Applic. Rate</p>
<p>(lb ai/A)</p></th>
<th rowspan="2">PHI (days)</th>
<th colspan="7"><p>Residue Levels</p>
<p>(ppm)<sup>1</sup></p></th>
</tr>
<tr class="header">
<th>n</th>
<th>Min.</th>
<th>Max.</th>
<th>HAFT<sup>2</sup></th>
<th><p>Median</p>
<p>(STMdR)</p></th>
<th><p>Mean</p>
<p>(STMR)</p></th>
<th>Std. Dev.</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="10"><strong>Lactofen</strong></td>
</tr>
<tr class="even">
<td>Pepper</td>
<td>0.98-1.1</td>
<td>30</td>
<td>6</td>
<td>&lt;0.01</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>&lt;0.01</td>
<td>&lt;0.01</td>
<td>0.0</td>
</tr>
<tr class="odd">
<td rowspan="3">Tomato</td>
<td>0.96</td>
<td>28-30</td>
<td>2</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>&lt;0.01</td>
<td>&lt;0.01</td>
<td>0.0</td>
</tr>
<tr class="even">
<td>1.5</td>
<td>30</td>
<td>10</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>&lt;0.01</td>
<td>&lt;0.01</td>
<td>0.0</td>
</tr>
<tr class="odd">
<td>4.9</td>
<td>30</td>
<td>2</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>&lt;0.02</td>
<td>&lt;0.01</td>
<td>&lt;0.01</td>
<td>0.0</td>
</tr>
</tbody>
</table>

^1^ The reported LOQs were 0.01 ppm for the 1991 pepper field trial, and
0.02 ppm for all other field trials. For calculation of the median,
mean, and standard deviation, a value of 0.01 ppm (½ the LOQ for the
majority of residue results) was used for samples with residues \<LOQ.

^2^ HAFT = Highest Average Field Trial.

**D. CONCLUSION**

The submitted field trial data are adequate and reflect a single pre- or
early post-transplant and one to two postemergence directed soil
applications to row middles at \~0.5 lb ai/A/application for a total
seasonal application rate of \~1-1.5 lb ai/A. [Residues were below the
LOQ in/on samples of mature peppers and tomatoes harvested \~30 days
following the last application. Acceptable methods were used for
quantitation of residues in/on peppers and tomatoes, and the data are
supported by acceptable storage stability data.]{.mark}

**E. REFERENCES**

DP Barcode: RD D241826

Subject: TGAI Product Chemistry Review/Action: 345. Reg. File Symbol
No.: 59639-94. Chemical: Lactofen---76.7% pure. Company: Valent U.S.A.
Corp.

From: H. Podall

To: S. Stanton

Date: 1/16/98

MRIDs: 44447001-44447003

DP Barcode: RD D242241

Subject: Product Chemistry Review of TGAI. Reg./File Symbol No.:
59639-94. Product Name: Lactofen Technical.

From: S. Mathur

To: J. Miller

Date: 2/5/98

MRIDs: 44460901-44460903

**F. DOCUMENT TRACKING**

RDI: COlinger (10/16/06)

Petition Number(s): 5E6930

DP Barcode(s): D333151

PC Code: 128888

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