![](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}**

28 December 2006

Subject: Desmedipham. Registrant's Response to Desmedipham Tolerance
Reassessment Eligibility Decision (TRED). Submission of Additional Sugar
Beet Field Trials.

+-------------+---------------+-------------+--------------------------+
| DP          | 327740        | Decision    | 364160                   |
| Barcodes:   |               | Number:     |                          |
+-------------+---------------+-------------+--------------------------+
| PC Code:    | 104801        | MRID No.:   | 46773001                 |
|             |               |             |                          |
|             |               |             | 42516500                 |
+-------------+---------------+-------------+--------------------------+
| 40 CFR 180. | 353           |             |                          |
+-------------+---------------+-------------+--------------------------+
| Chemical    | Phe           |             |                          |
| Class:      | nyl-carbamate |             |                          |
+-------------+---------------+-------------+--------------------------+

From: P. Yvonne Barnes, Chemist

Reregistration Branch 2

Health Effects Division (7509P)

Through: Alan Nielsen, Branch Senior Scientist

Reregistration Branch 2

Health Effects Division (7509P)

To:

Nathan Mottl, CRM

Reregistration Branch 1

Special Review and

Reregistration Division (7508P)

This document was originally prepared under contract by Dynamac
Corporation (1910 Sedwick Road, Building 100, Durham, NC 27713;
submitted 08/25/2006). The document has been reviewed by the Health
Effects Division (HED) and revised to reflect current Office of
Pesticide Programs (OPP) Policies.

**Executive Summary**

Desmedipham is a phenyl-carbamate herbicide (Group 5 herbicide)
currently used for the control of annual broadleaf weeds in sugar beets.
Permanent tolerances are established for residues of desmedipham \[40
CFR §180.353\] *per se* at 0.2 ppm in/on sugar beet roots and at 15 ppm
in/on sugar beet tops, and time-limited tolerances, set to expire
06/30/08.

[]{.mark}Desmedipham is currently registered to Bayer CropScience for
use on sugar beets and is marketed under the trade names Betanex®,
Betamix®, and Progress® Herbicides. All three products are EC
formulations; Bayer has canceled its registrations for wettable powder
(WP) formulations. Betanex® is a 1.3 lb/gal EC, and Betamix® and
Progress® are multiple active ingredient (MAI) formulations containing
0.6 to 0.65 lb/gal of desmedipham. The current use on sugar beets allows
for multiple foliar applications totaling up to 1.95 lb ai/A/season,
with a minimum retreatment interval (RTI) of 5 days and a preharvest
interval (PHI) of 75 days.

The nature of the desmedipham residues in plants and animals is
adequately understood. Based on an acceptable phenmedipham sugar beet
metabolism study, the Agency determined that phenmedipham and
desmedipham should be regulated in the same manner. Therefore, the
residue of concern in plants is desmedipham *per se*. Based on
acceptable poultry and ruminant metabolism studies reflecting oral
dosing of ^14^C-desmedipham, the Agency also determined that desmedipham
*per se* should be the regulated residue in animal commodities.

The LC/MS/MS method (Method AL/01/02) is available as a potential
tolerance enforcement method. The method has a validated limit of
quantitation (LOQ) of 0.05 ppm for desmedipham in/on beet roots and
tops, and the method has undergone a successful independent laboratory
validation (ILV) trial. However, this method must still undergo an
Agency method validation trial. Samples from the available sugar beet
field trials were analyzed using either the above LC/MS/MS method or an
adequate HPLC/UV method (Method D23023), which was validated in
conjunction with the analysis of the field trial samples. The LOQ for
the HPLC/UV method is 0.05 ppm for desmedipham in/on sugar beet roots
and tops.

[]{.mark}

Adequate data are available supporting the stability of desmedipham in
frozen sugar beet roots and tops for up to 8 months; however, samples
from the most recent field trials were stored for up to 14 months. Bayer
has cited data indicating that desmedipham residues are stable for up to
24 months in frozen roots and tops, but these data have not yet been
submitted. The 24-month month storage stability study should be
submitted to the Agency for review.

If acceptable storage stability data are provided, the available sugar
beet field trial data are adequate and will support the current use
patterns. The number and geographic distribution of the field trials are
adequate, and the appropriate samples were collected at the specified
PHI. In the five field trials referenced in MRID 42516500 dated 1992 and
the nine field trials conducted in 2004, desmedipham (1.3 lb/gal EC) was
applied to sugar beets as two broadcast foliar applications at 0.95 to
1.09 lb ai/A/application, at RTIs of 5 to 7 days, for a total of 1.93 to
2.09 lb ai/A (1x rate). The initial application was made from the 6-leaf
stage to full crop cover (BBCH stages 16 to 39), and all applications
were made using ground equipment, without the use of any adjuvant. In
the trials referenced in MRID 42516500, single control and treated
samples of tops were collected from each of the 5 trials at 75 days
after the last application (DAT), and in the 2004 studies, single
control and duplicate treated samples of tops and roots were collected
at 71 to 75 DAT. In the trials referenced in MRID 42516500, residues of
desmedipham in/on sugar beet tops were \<0.05 ppm to 6.54 ppm. In the
2004 trials, residues of desmedipham in/on sugar beets were \<0.05 ppm
for the 18 root samples and \<0.05 ppm to 0.135 ppm for the 18 tops
samples, with only 5 of the 18 samples of tops having residues \>LOQ.
Average residues were 0.025 ppm for roots and 0.045 ppm for tops from
the 2004 trials.

Using the reassessed tolerance of 5 ppm for sugar beet tops, the maximum
theoretical dietary burden of desmedipham for beef and dairy cattle are
4.3 ppm and 2.2 ppm, respectively. Based upon the data from the
available ruminant metabolism study, in which goats were dosed at 10 ppm
(1.1x), the Agency has concluded that infinite residues of desmedipham
are unlikely to occur in milk, meat and meat-byproducts of ruminants.
Therefore, a cattle feeding study and tolerances for livestock
commodities are not required. In addition, no tolerances are necessary
for hog or poultry commodities as sugar beet commodities are not
utilized in swine or poultry diets.

Although additional information is required to upgrade the existing
confined rotational crop study, the available data indicate that limited
and/or extensive field rotational crop studies are not required to
support the existing uses on sugar beets, and that rotational crop
restrictions are not necessary.

**Regulatory Recommendations and Residue Chemistry Deficiencies**

Provided that adequate storage stability data are submitted, the
requirements for desmedipham residue data on sugar beets are fulfilled
and tolerances can be reassessed. However, in addition to the required
storage stability data, the following minor deficiencies still require
resolution.

• The current tolerance enforcement method listed in PAM Vol. II for
desmedipham is not adequate. However, an adequate LC/MS/MS method
(Method AL/01/02) is available that has undergone a successful ILV
trial. This method should be forwarded to the Analytical Chemistry
Branch for a method validation trial.

• Storage stability data are required to support frozen storage
intervals of up to 14 months for sugar beet roots and tops. The
registrant should submit the existing 24-month storage stability study
for review.

• Although data from the available confined rotational crop study
indicate that rotational crop restrictions are not required, the
Desmedipham RED (08/95) noted that sample storage information and
supporting storage stability data are required in order to upgrade the
existing confined study to acceptable.

Based on the available residue data, HED recommends reassessing
tolerances for residues of desmedipham in/on sugar beet roots and tops
to 0.1 ppm and 5 ppm, respectively.

**Background**

Desmedipham is a phenyl-carbamate herbicide (Group 5 herbicide) used for
the control of annual broadleaf weeds in sugar beets. The Reregistration
Eligibility Decision (RED) for desmedipham was issued on 08/21/95, and
the Tolerance Reassessment Eligibility Decision (TRED) was issued on
01/25/05. Permanent tolerances are established for residues of
desmedipham at 0.2 ppm in/on sugar beet roots and tops \[40 CFR
§180.353(a)\]. Time-limited tolerances are also established for residues
of desmedipham in/on red (garden) beets at 0.2 ppm for roots and at 15
ppm for tops; these tolerances are currently set to expire on 06/30/08
\[40 CFR §180.353(b)\].

Bayer CropScience, the basic producer of desmedipham, has submitted
additional field trial data on sugar beets in response to deficiencies
noted in the Desmedipham TRED. The nomenclature and physicochemical
properties of desmedipham are presented below in Tables 1 and 2.

+-------------------+--------------------------------------------------+
| **TABLE 1.        |                                                  |
| Desmedipham       |                                                  |
| Nomenclature.**   |                                                  |
+===================+==================================================+
| Compound          | ![                                               |
|                   | ](media/image2.wmf){width="3.4270833333333335in" |
|                   | height="0.8229166666666666in"}                   |
+-------------------+--------------------------------------------------+
| Common name       | Desmedipham                                      |
+-------------------+--------------------------------------------------+
| Company           | AE B038107                                       |
| experimental name |                                                  |
+-------------------+--------------------------------------------------+
| IUPAC name        | ethyl 3-phenylcarbamoyloxycarbanilate            |
+-------------------+--------------------------------------------------+
| CAS name          | ethyl                                            |
|                   | \[3-\                                            |
|                   | [\[(phenylamino)carbonyl\]oxy\]phenyl\]carbamate |
+-------------------+--------------------------------------------------+
| CAS registry      | 13684-56-5                                       |
| number            |                                                  |
+-------------------+--------------------------------------------------+
| End-use products  | Betanex^®^ Herbicide (1.3 lb/gal EC; EPA Reg.    |
| (EP)              | No. 264-620)                                     |
|                   |                                                  |
|                   | Betamix^®^ Herbicide (0.65 lb/gal EC; EPA Reg.   |
|                   | No. 264-621)                                     |
|                   |                                                  |
|                   | Progress^®^ Herbicide (0.6 lb/gal EC; EPA Reg.   |
|                   | No. 264-632)                                     |
+-------------------+--------------------------------------------------+

+--------------------------+-------------------------+-----------------+
| **TABLE 2.               |                         |                 |
| Physicochemical          |                         |                 |
| Properties of the        |                         |                 |
| Technical Grade          |                         |                 |
| Desmedipham.**           |                         |                 |
+==========================+=========================+=================+
| Parameter                | Value                   | Reference       |
+--------------------------+-------------------------+-----------------+
| Melting point/range      | 118-119 ° C             | Provided in     |
|                          |                         | MRID 46773001   |
+--------------------------+-------------------------+-----------------+
| pH                       | Not soluble in water    |                 |
+--------------------------+-------------------------+-----------------+
| Density                  | 1.320 g/ml              |                 |
+--------------------------+-------------------------+-----------------+
| Water solubility (g/L)   | pH 7 - 0.007            |                 |
| at RT                    |                         |                 |
|                          | pH 9 - 0.0134           |                 |
|                          |                         |                 |
|                          | pH 11 - 0.00442         |                 |
+--------------------------+-------------------------+-----------------+
| Solvent solubility (g/L) | Acetone 285             |                 |
| at RT                    |                         |                 |
|                          | Methanol 187            |                 |
|                          |                         |                 |
|                          | Ethyl Acetate 181       |                 |
|                          |                         |                 |
|                          | Methylene Chloride 19.9 |                 |
|                          |                         |                 |
|                          | Toluene 1.2             |                 |
|                          |                         |                 |
|                          | Hexane 0.02             |                 |
+--------------------------+-------------------------+-----------------+
| Vapor pressure           | \<-1.5 Torr (25 ° C)    |                 |
+--------------------------+-------------------------+-----------------+
| Dissociation constant,   | Does not dissociate in  |                 |
| pK~a~                    | water                   |                 |
+--------------------------+-------------------------+-----------------+
| Octanol/water partition  | 187                     |                 |
| coefficient, Log (K~OW~) |                         |                 |
+--------------------------+-------------------------+-----------------+
| UV/visible absorption    | Primary 273nm           |                 |
| spectrum                 |                         |                 |
|                          | Secondary 203 nm        |                 |
|                          |                         |                 |
|                          | Tertiary 236 nm         |                 |
+--------------------------+-------------------------+-----------------+

**860.1200 Directions for Use**

[]{.mark}Desmedipham is currently registered to Bayer CropScience and is
marketed under the trade names BETANEX^®^, BETAMIX^®^, and PROGRESS^®^
Herbicides (EPA Reg. Nos. 264-620, 264-621, and 264-632). All three
products are EC formulations: BETANEX^®^ is a 1.3 lb/gal EC containing
only desmedipham; BETAMIX^®^ is a multiple active ingredient (MAI)
formulation containing 0.65 lb/gal each of desmedipham and phenmedipham;
and PROGRESS^®^ is also a MAI formulation containing 0.6 lb/gal each of
desmedipham, phenmedipham, and ethofumesate. Bayer is no longer
supporting the use of wettable powder (WP) formulations of desmedipham.
The current use directions for sugar beets are summarized in Table 3.

+--------------+-------+-------+-----+-----+---+---------------------+
| **Table 3.   |       |       |     |     |   |                     |
| Summary of   |       |       |     |     |   |                     |
| Existing Use |       |       |     |     |   |                     |
| Directions   |       |       |     |     |   |                     |
| for          |       |       |     |     |   |                     |
| Desmedipham  |       |       |     |     |   |                     |
| on Sugar     |       |       |     |     |   |                     |
| Beets.**     |       |       |     |     |   |                     |
+==============+=======+=======+=====+=====+===+=====================+
| Applic.      | F     | Ap    | M   | M   | P | Use Directions and  |
| Timing,      | ormul | plica | ax. | ax. | H | Limitations ^2^     |
| Type, and    | ation | tion. | No. | Se  | I |                     |
| Equipment    |       | Rate  | A   | aso |   |                     |
| ^1^          | \[EPA |       | ppl | nal | ( |                     |
|              | Reg.  | (lb   | ic. | R   | d |                     |
|              | No.\] | ai/A) | per | ate | a |                     |
|              |       |       | Sea |     | y |                     |
|              |       |       | son | (lb | s |                     |
|              |       |       |     | ai  | ) |                     |
|              |       |       |     | /A) |   |                     |
+--------------+-------+-------+-----+-----+---+---------------------+
| Conventional | 1.3   | 0.73  | 2   | 1   | 7 | Do not exceed 0.24  |
| broadcast    | l     | -1.20 |     | .95 | 5 | lb ai/A when beets  |
| foliar       | b/gal |       |     |     |   | are at cotyledon    |
| applications | EC    | \+    |     |     |   | stage.              |
| beginning at |       |       |     |     |   |                     |
| cotyledon    | \     | 0.73  |     |     |   | Apply in a minimum  |
| stage using  | [264- | -0.98 |     |     |   | of 5 or 20 gal/A    |
| ground or    | 620\] |       |     |     |   | for aerial and      |
| aerial       |       |       |     |     |   | ground              |
| equipment.   |       |       |     |     |   | applications. The   |
|              |       |       |     |     |   | use of spray        |
|              |       |       |     |     |   | adjuvants is        |
|              |       |       |     |     |   | prohibited. The     |
|              |       |       |     |     |   | specified RTI 7     |
|              |       |       |     |     |   | days.               |
+--------------+-------+-------+-----+-----+---+---------------------+
| Multiple low |       | 0.24  | NS  |     |   | Use pattern not     |
| rate         |       | -0.73 |     |     |   | allowed in CA. Do   |
| broadcast    |       |       |     |     |   | not exceed 0.24 lb  |
| foliar       |       |       |     |     |   | ai/A when beets are |
| applications |       |       |     |     |   | at cotyledon stage. |
| beginning at |       |       |     |     |   | Apply in a minimum  |
| cotyledon    |       |       |     |     |   | of 5 or 10 gal/A    |
| stage using  |       |       |     |     |   | for aerial and      |
| ground or    |       |       |     |     |   | ground              |
| aerial       |       |       |     |     |   | applications. The   |
| equipment    |       |       |     |     |   | use of spray        |
|              |       |       |     |     |   | adjuvants is        |
|              |       |       |     |     |   | prohibited. The     |
|              |       |       |     |     |   | specified RTI 5     |
|              |       |       |     |     |   | days.               |
+--------------+-------+-------+-----+-----+---+---------------------+
| Multiple     |       | 0.08  | 3+  |     |   | Use pattern not     |
| "micro" rate |       | -0.12 |     |     |   | allowed in CA. Do   |
| broadcast    |       |       |     |     |   | not exceed 0.08 lb  |
| foliar       |       |       |     |     |   | ai/A, prior to      |
| applications |       |       |     |     |   | 4‑leaf stage. Apply |
| beginning at |       |       |     |     |   | in a minimum of 5   |
| cotyledon    |       |       |     |     |   | or 10 gal/A for     |
| stage using  |       |       |     |     |   | aerial and ground   |
| ground or    |       |       |     |     |   | applications.       |
| aerial       |       |       |     |     |   | Applications may    |
| equipment    |       |       |     |     |   | include the use of  |
|              |       |       |     |     |   | modified seed oil   |
|              |       |       |     |     |   | at 1.5% spray       |
|              |       |       |     |     |   | volume. The         |
|              |       |       |     |     |   | specified RTI 5     |
|              |       |       |     |     |   | days.               |
+--------------+-------+-------+-----+-----+---+---------------------+
| Conventional | 0.65  | 0.36  | 2   | 0   | 7 | Do not exceed 0.12  |
| broadcast    | l     | -0.61 |     | .98 | 5 | lb ai/A when beets  |
| foliar       | b/gal |       |     |     |   | are at cotyledon    |
| applications | EC    | \+    |     |     |   | stage. Apply in a   |
| beginning at | ^3^   |       |     |     |   | minimum of 5 or 20  |
| cotyledon    |       | 0.36  |     |     |   | gal/A for aerial    |
| stage using  | \     | -0.49 |     |     |   | and ground          |
| ground or    | [264- |       |     |     |   | applications. The   |
| aerial       | 621\] |       |     |     |   | use of spray        |
| equipment.   |       |       |     |     |   | adjuvants is        |
|              |       |       |     |     |   | prohibited. The     |
|              |       |       |     |     |   | specified RTI 7     |
|              |       |       |     |     |   | days.               |
+--------------+-------+-------+-----+-----+---+---------------------+
| Multiple low |       | 0.24  | NS  |     |   | Use pattern not     |
| rate         |       | -0.36 |     |     |   | allowed in CA. Do   |
| broadcast    |       |       |     |     |   | not exceed 0.12 lb  |
| foliar       |       |       |     |     |   | ai/A when beets are |
| applications |       |       |     |     |   | at cotyledon stage. |
| beginning at |       |       |     |     |   | Apply in a minimum  |
| cotyledon    |       |       |     |     |   | of 5 or 10 gal/A    |
| stage using  |       |       |     |     |   | for aerial and      |
| ground or    |       |       |     |     |   | ground              |
| aerial       |       |       |     |     |   | applications. The   |
| equipment    |       |       |     |     |   | use of spray        |
|              |       |       |     |     |   | adjuvants is        |
|              |       |       |     |     |   | prohibited. The     |
|              |       |       |     |     |   | specified RTI 5     |
|              |       |       |     |     |   | days.               |
+--------------+-------+-------+-----+-----+---+---------------------+
| Multiple     |       | 0.08  | 3+  |     |   | Use pattern not     |
| "micro" rate |       | -0.12 |     |     |   | allowed in CA. Do   |
| broadcast    |       |       |     |     |   | not exceed 0.08 lb  |
| foliar       |       |       |     |     |   | ai/A, prior to      |
| applications |       |       |     |     |   | 4‑leaf stage. Apply |
| beginning at |       |       |     |     |   | in a minimum of 5   |
| cotyledon    |       |       |     |     |   | or 10 gal/A for     |
| stage using  |       |       |     |     |   | aerial and ground   |
| ground or    |       |       |     |     |   | applications.       |
| aerial       |       |       |     |     |   | Applications may    |
| equipment    |       |       |     |     |   | include the use of  |
|              |       |       |     |     |   | modified seed oil   |
|              |       |       |     |     |   | at 1.5% spray       |
|              |       |       |     |     |   | volume. The         |
|              |       |       |     |     |   | specified RTI 5     |
|              |       |       |     |     |   | days.               |
+--------------+-------+-------+-----+-----+---+---------------------+
| Conventional | 0.6   | 0.24  | 2   | 0   | 7 | Do not exceed 0.11  |
| broadcast    | l     | -0.38 |     | .65 | 5 | lb ai/A when beets  |
| foliar       | b/gal |       |     |     |   | are at cotyledon    |
| applications | EC    | \+    |     |     |   | stage. Apply in a   |
| beginning at | ^4^   |       |     |     |   | minimum of 5 or 20  |
| cotyledon    |       | 0.24  |     |     |   | gal/A for aerial    |
| stage using  | \     | -0.38 |     |     |   | and ground          |
| ground or    | [264- |       |     |     |   | applications. The   |
| aerial       | 632\] |       |     |     |   | use of spray        |
| equipment.   |       |       |     |     |   | adjuvants is        |
|              |       |       |     |     |   | prohibited. The     |
|              |       |       |     |     |   | specified RTI 7     |
|              |       |       |     |     |   | days.               |
+--------------+-------+-------+-----+-----+---+---------------------+
| Multiple low |       | 0.11  | NS  |     |   | Use pattern not     |
| rate         |       | -0.24 |     |     |   | allowed in CA       |
| broadcast    |       |       |     |     |   |                     |
| foliar       |       |       |     |     |   | Do not exceed 0.24  |
| applications |       |       |     |     |   | lb ai/A when beets  |
| beginning at |       |       |     |     |   | are at cotyledon    |
| cotyledon    |       |       |     |     |   | stage.              |
| stage using  |       |       |     |     |   |                     |
| ground or    |       |       |     |     |   | Apply in a minimum  |
| aerial       |       |       |     |     |   | of 5 or 10 gal/A    |
| equipment    |       |       |     |     |   | for aerial and      |
|              |       |       |     |     |   | ground              |
|              |       |       |     |     |   | applications. The   |
|              |       |       |     |     |   | use of spray        |
|              |       |       |     |     |   | adjuvants is        |
|              |       |       |     |     |   | prohibited. The     |
|              |       |       |     |     |   | specified RTI 5     |
|              |       |       |     |     |   | days.               |
+--------------+-------+-------+-----+-----+---+---------------------+
| Multiple     |       | 0.08  | 3+  |     |   | Use pattern not     |
| "micro" rate |       | -0.12 |     |     |   | allowed in CA. Do   |
| broadcast    |       |       |     |     |   | not exceed 0.08 lb  |
| foliar       |       |       |     |     |   | ai/A, prior to      |
| applications |       |       |     |     |   | 4‑leaf stage. Apply |
| beginning at |       |       |     |     |   | in a minimum of 5   |
| cotyledon    |       |       |     |     |   | or 10 gal/A for     |
| stage using  |       |       |     |     |   | aerial and ground   |
| ground or    |       |       |     |     |   | applications.       |
| aerial       |       |       |     |     |   | Application may     |
| equipment    |       |       |     |     |   | include the use of  |
|              |       |       |     |     |   | modified seed oil   |
|              |       |       |     |     |   | at 1.5% spray       |
|              |       |       |     |     |   | volume. The         |
|              |       |       |     |     |   | specified RTI 5     |
|              |       |       |     |     |   | days.               |
+--------------+-------+-------+-----+-----+---+---------------------+
| ^1^          |       |       |     |     |   |                     |
| Applications |       |       |     |     |   |                     |
| through      |       |       |     |     |   |                     |
| irrigation   |       |       |     |     |   |                     |
| systems are  |       |       |     |     |   |                     |
| prohibited.  |       |       |     |     |   |                     |
|              |       |       |     |     |   |                     |
| ^2^ All      |       |       |     |     |   |                     |
| three labels |       |       |     |     |   |                     |
| prohibit     |       |       |     |     |   |                     |
| rotation to  |       |       |     |     |   |                     |
| cereal grain |       |       |     |     |   |                     |
| crops for    |       |       |     |     |   |                     |
| 120 days     |       |       |     |     |   |                     |
| following    |       |       |     |     |   |                     |
| p            |       |       |     |     |   |                     |
| ostemergence |       |       |     |     |   |                     |
| application. |       |       |     |     |   |                     |
|              |       |       |     |     |   |                     |
| ^3^ This     |       |       |     |     |   |                     |
| formulation  |       |       |     |     |   |                     |
| is a MAI     |       |       |     |     |   |                     |
| also         |       |       |     |     |   |                     |
| containing   |       |       |     |     |   |                     |
| 0.65 lb/gal  |       |       |     |     |   |                     |
| of           |       |       |     |     |   |                     |
| p            |       |       |     |     |   |                     |
| henmedipham. |       |       |     |     |   |                     |
|              |       |       |     |     |   |                     |
| ^4^ This     |       |       |     |     |   |                     |
| formulation  |       |       |     |     |   |                     |
| is a MAI     |       |       |     |     |   |                     |
| also         |       |       |     |     |   |                     |
| containing   |       |       |     |     |   |                     |
| 0.6 lb/gal   |       |       |     |     |   |                     |
| each of      |       |       |     |     |   |                     |
| phenmedipham |       |       |     |     |   |                     |
| and          |       |       |     |     |   |                     |
| e            |       |       |     |     |   |                     |
| thofumesate. |       |       |     |     |   |                     |
|              |       |       |     |     |   |                     |
| RTI =        |       |       |     |     |   |                     |
| retreatment  |       |       |     |     |   |                     |
| interval.    |       |       |     |     |   |                     |
|              |       |       |     |     |   |                     |
| NS = not     |       |       |     |     |   |                     |
| specified.   |       |       |     |     |   |                     |
+--------------+-------+-------+-----+-----+---+---------------------+

*Conclusion:* The current use directions on all three labels are
similar, with the two MAI formulations having proportionally lower use
rates than the 1.3 lb/gal EC. The use directions are for sugar beets are
supported by the available field trial data.

**860.1300 Nature of the Residue -- Plants**

DP Barcode D216436, Desmedipham RED, D. Miller, 08/18/95

The qualitative nature of the residue in plants is adequately understood
based on an acceptable sugar beet metabolism study using phenmedipham.
The Agency has concluded that that the metabolism of desmedipham in
plants mirrors that of phenmedipham, as the two compounds are
structurally similar, and that the two compounds should be regulated in
the same manner. Therefore, the residue of concern for desmedipham in
plants is desmedipham *per se*.

**860.1300 Nature of the Residue -- Livestock**

DP Barcode D216436, Desmedipham RED, D. Miller, 08/18/95

The nature of the residues in animals is adequately understood based on
acceptable poultry and ruminant metabolism studies reflecting oral
dosing of ^14^C-desmedipham. The Agency (DP Barcode D213531, D. Miller,
04/10/95) has determined that the residue to be regulated in animals is
desmedipham *per se*.

In the ruminant metabolism study, a lactating cow was dosed orally for 4
consecutive days with \[^14^C\]desmedipham uniformly labeled in the
phenyl ring with two substitutes at a rate equivalent to 10 ppm in the
diet. Based on residues in sugar beet tops, this dosing level is
equivalent to \~1.2x the maximum expected dietary burden. After 4 days,
total radioactive residues (TRR) were 0.307 ppm in kidney, 0.040 ppm in
liver, ≤0.01 ppm to 0.024 ppm in fat, and ≥0.01 ppm in muscle. Residues
in milk plateaued at 0.187 ppm after 3 days. Identified residues
comprised 85.8% of the TRR in kidney, 76.4% of the TRR in milk, and
25.5% of the TRR in liver. In kidney and milk, identified residues were
ethyl-*N*-3-hydroxyphenyl carbamate (EHPC) (76.7% TRR, 0.24 ppm in
kidney and 75.1% TRR, 0.14 ppm in milk) and 3-acetamidophenol (9.1% TRR,
0.03 ppm in kidney and 1.3% TRR, \<0.01 ppm in milk). In liver, the
principal residues were EHPC (13.5% TRR, \<0.01 ppm) and 3-aminophenol
(12.0% TRR, \<0.01 ppm). In omental and perirenal fat, extracted
residues were \<0.01 ppm and included EHPC, desmedipham,
3-acetamidophenol, and 3-aminophenol.

In the poultry metabolism study, laying hens were dosed orally for 10
consecutive days at a dose of 1.5 mg/hen/day. Radioactive residues in
excreta accounted for approximately 85.3% to 96.6 % of the administered
dose. During the dosing period, TRRs were 0.001 ppm to 0.017 ppm in egg
whites. The TRR in a pooled egg yolk sample collected on Day 10 was
0.046 ppm. Identified residues in yolks were 3-aminophenol (46.5% TRR,
0.022 ppm) and EHPC (26.5% TRR, 0.012 ppm) and with trace amounts of
3-acetamidophenol and desmedipham. All other tissues contained TRR
values of less than 0.01 ppm.

**860.1340 Residue Analytical Methods**

DP Barcode D216436, Desmedipham RED, D. Miller, 08/18/95

45942201.der, S. Kinard, 07/08/04

The Agency previously determined that the existing GC/ECD method for
determining total residues of desmedipham in sugar beets (Method I in
PAM Vol. II, Section 180.353) is not adequate for tolerance enforcement,
as naturally-occurring anilines may interfere with the analysis.
However, an adequate HPLC/UV detection method (Desmedipham Method R75)
was available, which had undergone a successful ILV trial. For this
method, residues in/on beets are extracted by refluxing in acidified
ethyl acetate. Residues of desmedipham are then filtered, concentrated
and cleaned up using Florisil and C~18~ columns. Purified residues are
redissolved in acetonitrile:water (1:1, v:v), acidified, and analyzed by
HPLC using a C~18~ column with UV detection (235 nm). The validated LOQ
for desmedipham is 0.05 ppm in/on roots and tops, and the reported LOD
is 0.004 ppm.

The Agency concluded that this HPLC/UV method could be adequate for
tolerance enforcement provided that the registrant submit additional
supporting raw data for the method and conduct an interference study
using propham and phenmedipham. After submission of the requested data,
the Agency would then conduct a method validation trial.

[]{.mark}

Since the review of the above HPLC/UV method, Bayer has submitted a
method description and validation data for a LC/MS/MS method (Method
AL/01/02) for determining residues of desmedipham in/on sugar beet tops
and roots. For this method, residues of desmedipham are extracted from
roots and tops by refluxing in ethyl acetate:methanol (4:1, v/v) for one
hour. Residues were then filtered, concentrated to dryness, and
reconstituted in acetonitrile/water (1:1, v/v) with 0.5% acetic acid.
Residues were determined by LC/MS/MS, using a Hypersil column with a
gradient of 0.1% acetic acid to acetonitrile, and residues were
quantified using the 301→182 m/z transition. Adequate method recoveries
were obtained using samples of tops and roots fortified with desmedipham
at 0.05 ppm to 2.5 ppm, and the method was also successfully validated
in an ILV trial using sugar beet tops fortified at 0.05 ppm to 1.0 ppm.
The validated LOQ is 0.05 ppm and the reported LOD is 0.008 ppm for
roots and 0.023 ppm for tops. As the this method is more specific then
the earlier HPLC/UV method and does not require the use of a
confirmatory method or conducting an interference study, the LC/MS/MS
method (Method AL/01/02) should be forwarded to the Analytical Chemistry
Branch for a petition method validation trial.

Samples from the sugar beet field trials were analyzed using adequate
data collection methods. Samples of tops from the sugar beet field
trials referenced in MRID 42516500/01 dated 1992 were analyzed using the
HPLC/UV method (Desmedipham Method/R75) and samples of roots and tops
from the more recent field trials (2001-2004) were analyzed using the
above LC/MS/MS method (Method AL/01/02).

An enforcement analytical method for desmedipham residues in animal
commodities are not needed because tolerances for animal commodities are
not required.

**860.1360 Multiresidue Methods**

The FDA multi-residue method testing data have been forwarded to FDA for
evaluation (memo to L. Sawyer from D. McNeilly, dated 04/14/92). The FDA
PESTDATA database dated 10/99 (PAM Vol. I, Appendix I) does not report
recoveries for desmedipham using any of the multiresidue methods in PAM
Vol. I.

**860.1380 Storage Stability**

The Desmedipham RED (08/95) noted that data are available supporting the
stability of desmedipham in frozen (-21ºC) sugar beet roots and tops for
up to 8 months. These data are adequate to support the storage
conditions and intervals from earlier field trials (MRID 42516500/01).
However, in the most recent field trials, samples of roots and tops were
stored frozen for up to 14 months (MRID 45824401) or 13.5 months (MRID
46773001). Each of these later field trials indicated that data were
available supporting frozen storage intervals of up to 24 months and
cited the following study:

> *Wrede, A. 2001. "Stability of Desmedipham and its Metabolite EHPC in
> Sugar Beet Root and Leaf During Deep Freeze Storage of 24 Months,
> Bayer CropScience Report No. C017679."*

However, these data have not been submitted to the Agency for review.

*Conclusion:*

1\) The 24-month storage stability study on sugar beets should be
submitted for review.

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

This guideline requirement is not relevant as there are no aquatic uses
for desmedipham.

**860.1460 Food Handling**

This guideline requirement is not relevant as there are no-food handling
uses for desmedipham.

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

Based on the reassess tolerance for sugar beet tops, the maximum
theoretical dietary burdens of desmedipham for beef and dairy cattle are
presented in Table 4.

+-------------------+--------+--------+-------------+-----------------+
| **Table 4.        |        |        |             |                 |
| Calculation of    |        |        |             |                 |
| Maximum Dietary   |        |        |             |                 |
| Burdens of        |        |        |             |                 |
| Livestock to      |        |        |             |                 |
| Desmedipham       |        |        |             |                 |
| Residues.**       |        |        |             |                 |
+-------------------+--------+--------+-------------+-----------------+
| Feed Commodity    | \% Dry | \%     | Reassessed  | Dietary         |
|                   | Mat    | D      | Tolerance   | Contribution    |
|                   | ter^1^ | iet^1^ | (ppm)       | (ppm)^2^        |
+-------------------+--------+--------+-------------+-----------------+
| **Beef Cattle**   |        |        |             |                 |
+-------------------+--------+--------+-------------+-----------------+
| > Beet, sugar,    | 23     | 20     | 5           | 4.3             |
| > tops            |        |        |             |                 |
+-------------------+--------+--------+-------------+-----------------+
| TOTAL BURDEN      |        | 20     |             | **4.3**         |
+-------------------+--------+--------+-------------+-----------------+
| **Dairy Cattle**  |        |        |             |                 |
+-------------------+--------+--------+-------------+-----------------+
| > Beet, sugar,    | 23     | 10     | 5           | 2.2             |
| > tops            |        |        |             |                 |
+-------------------+--------+--------+-------------+-----------------+
| TOTAL BURDEN      |        | 10     |             | **2.2**         |
+-------------------+--------+--------+-------------+-----------------+
| ^1^ Table 1       |        |        |             |                 |
| (OPPTS Guideline  |        |        |             |                 |
| 860.1000).        |        |        |             |                 |
|                   |        |        |             |                 |
| ^2^ Contribution  |        |        |             |                 |
| = (\[tolerance /  |        |        |             |                 |
| % DM\] X % diet)  |        |        |             |                 |
| for beef and      |        |        |             |                 |
| dairy cattle      |        |        |             |                 |
+-------------------+--------+--------+-------------+-----------------+

The administered dose in the submitted ruminant metabolism study
represented 1.1x the maximum expected dietary burden to beef cattle and
2.3x the maximum expected dietary burden to dairy cattle. Because
Desmedipham residues in milk and all tissues in the metabolism study
were \< 0.01 ppm, the Agency considers use of desmedipham on sugar beets
to be a 180.6(a)(3) situation for ruminants (i.e., there is no
expectation of finite residues in ruminant commodities). Therefore, a
cattle feeding study is not required, and no tolerances for ruminant
commodities need be established.

Sugar beet commodities are not listed as poultry or swine feed items in
Table 1 (OPPTS 860.1000); therefore, no tolerances for desmedipham
residues in poultry or swine commodities are required.

**860.1500 Crop Field Trials**

D184329, D. Miller, 12/22/92

45824401.der, S. Kinard, 07/08/04

46773001.der, P. Y. Barnes, 12/28/06

The results from sugar beet field trials, which used the adequate
HPLC/UV or LC/MS/MS methods for sample analysis, are discussed below and
summarized in Table 5. The Agency notes that Bayer is only supporting
the use of EC formulations on sugar beets.

<table style="width:100%;">
<colgroup>
<col style="width: 11%" />
<col style="width: 13%" />
<col style="width: 12%" />
<col style="width: 7%" />
<col style="width: 4%" />
<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 Sugar
Beet Field Trials with Desmedipham.</strong></th>
</tr>
<tr class="odd">
<th rowspan="2">Crop matrix</th>
<th rowspan="2">Formulation</th>
<th rowspan="2">Total Applic. Rate (lb ai/A)</th>
<th rowspan="2">PHI (days)</th>
<th colspan="7">Residue Levels (ppm) <sup>1</sup></th>
</tr>
<tr class="header">
<th>n</th>
<th>Min.</th>
<th>Max.</th>
<th>HAFT <sup>2</sup></th>
<th>Median</th>
<th>Mean</th>
<th>Std. Dev.</th>
</tr>
</thead>
<tbody>
<tr class="odd">
<td colspan="11"><strong>MRID 42516500/01 <sup>3</sup></strong></td>
</tr>
<tr class="even">
<td>Tops</td>
<td>1.3 lb/gal EC</td>
<td>1.95 (1x)</td>
<td>75</td>
<td>5</td>
<td>&lt;0.05</td>
<td>6.54</td>
<td>6.54</td>
<td>0.12</td>
<td>1.38</td>
<td>2.88</td>
</tr>
<tr class="odd">
<td colspan="11"><strong>MRID 45824401 <sup>4</sup></strong></td>
</tr>
<tr class="even">
<td>Tops</td>
<td rowspan="2">1.3 lb/gal EC</td>
<td rowspan="2">1.18-1.23 (0.6x)</td>
<td rowspan="2">75-76</td>
<td>28</td>
<td>&lt;0.05</td>
<td>0.24</td>
<td>0.23</td>
<td>0.025</td>
<td>0.042</td>
<td>0.054</td>
</tr>
<tr class="odd">
<td>Roots</td>
<td>28</td>
<td>&lt;0.05</td>
<td>&lt;0.05</td>
<td>&lt;0.05</td>
<td>0.025</td>
<td>0.025</td>
<td>NA</td>
</tr>
<tr class="even">
<td colspan="11"><strong>MRID 46773001</strong></td>
</tr>
<tr class="odd">
<td>Tops</td>
<td rowspan="2">1/3 lb/gal EC</td>
<td rowspan="2">1.93-2.09 (1x)</td>
<td rowspan="2">71-75</td>
<td>18</td>
<td>&lt;0.05</td>
<td>0.135</td>
<td>0.100</td>
<td>0.025</td>
<td>0.045</td>
<td>0.037</td>
</tr>
<tr class="even">
<td>Roots</td>
<td>18</td>
<td>&lt;0.05</td>
<td>&lt;0.05</td>
<td>&lt;0.05</td>
<td>0.025</td>
<td>0.025</td>
<td>NA</td>
</tr>
<tr class="odd">
<td colspan="11"><p><sup>1</sup> The method LOQ is 0.05 ppm. For
calculation of the median, mean and standard deviation, ½LOQ (0.025 ppm)
was used for samples with residues &lt;LOQ.</p>
<p><sup>2</sup> HAFT = Highest Average Field Trial.</p>
<p><sup>3</sup> The Agency’s review of this submission did not address
residues in roots.</p>
<p><sup>4</sup> This study was conducted to support the use of multiple
“micro” applications at up to 0.2 lb ai/A/application.</p></td>
</tr>
</tbody>
</table>

**MRID 42516501.** In the 5 field trials referenced in MRID 42516500/01
dated 1992 for growing zones 5, 7 and 10, desmedipham was applied to
sugar beets in side-by-side tests using the 70% WP and 1.3 lb/gal EC
formulations as two broadcast foliar applications at 0.975 lb
ai/A/application, one week apart, for a total of 1.95 lb ai/A (1x rate).
Single control and treated samples of tops were harvested from each test
at 75 DAT. Samples of tops were stored frozen for up to 8 months, and
were analyzed for residues of desmedipham using the adequate HPLC/UV
method (Desmedipham Method/R75). The method LOQ is 0.05 ppm for tops.

Following two applications totaling 1.95 lb ai/A (1x rate), residues of
desmedipham in/on sugar beet tops at 75 DAT were \<0.05-6.54 ppm for the
five samples from plots treated with the 1.3 lb/gal EC and 0.07 ppm to
13.86 ppm for the five samples from plots treated with the 70% WP.
Average residues in/on tops were 1.38 ppm for the EC formulation and
2.97 ppm for the WP formulation.

**MRID 45824401.** In 14 field trials conducted during 2001 in growing
zones 5, 7, 8, 9, 10 and 11, desmedipham (1.3 lb/gal EC) was applied to
sugar beets as six broadcast foliar applications at 0.19-0.21 lb
ai/A/application, at RTIs of 4-6 days, for a total of 1.18-1.23 lb
ai/A/season (0.6x rate). Applications were generally made beginning at
the 2 to 19 leaf stage and up to complete crop cover (BBCH 12-39). All
applications were made using ground equipment and included the use of
methylated seed oil as an adjuvant at (1.5%, v/v). Single control and
duplicate treated samples of tops and roots were harvested at 75-76 DAT.
At two test sites in MN and CA, single treated and control samples of
roots and tops were also harvested at 45 to 46, 60, 90 and 105 DAT to
examine residue decline. Samples of roots and tops were stored frozen
(≤0 ºC) for up to 14 months prior to analysis, and samples were analyzed
using an adequate LC/MS/MS method (Bayer Method AL/01/02). The method
LOQ is 0.05 ppm for both roots and tops, and reported LOD is 0.016 ppm
and 0.008 ppm for tops and roots, respectively.

Following six applications totaling \~1.2 lb ai/A (0.6x rate), residues
of desmedipham were \<0.05 ppm in/on all 28 samples of sugar beet roots
and \<0.05 ppm to 0.24 ppm in/on 28 samples of sugar beet tops harvested
at 75 to 76 DAT. Only three samples of tops had residues above the LOQ
(0.08, 0.22, and 0.24 ppm). The HAFT residues were \<0.05 ppm for roots
and 0.23 ppm for tops, and average residues were 0.025 ppm (½LOQ) for
roots and 0.042 ppm for tops. In the two residue decline trials,
residues were \<LOQ in/on roots samples at all intervals from both
trials and were also \<LOQ in/on tops at all intervals from the MN test.
In the CA test, residues in/on tops declined from 0.25 ppm at 45 DAT to
\<LOQ by 90 DAT.

**MRID 46773001.** In nine field trials conducted during 2004 in growing
zones 5, 7, 8, 9, 10 and 11, desmedipham (1.3 lb/gal EC) was applied to
sugar beets as two broadcast foliar applications at 0.95-1.09 lb
ai/A/application, at RTIs of 5 to 7 days, for a total of 1.93 to 2.09 lb
ai/A (1x rate). The initial application was made from the 6-leaf stage
to full crop cover (BBCH stages 16-39), and all applications were made
using ground equipment, without the use of any adjuvants. A single
control and duplicate treated samples of tops and roots were collected
at 71-75 DAT. Samples of roots and tops were stored frozen (≤-5ºC) for
up to 13.5 months prior to analysis, and samples were analyzed using an
adequate LC/MS/MS method (Bayer Method AL/01/02). The method LOQ is 0.05
ppm for both roots and tops, and the LOD is 0.008 ppm and 0.023 ppm for
tops and roots, respectively.

Following application at a 1x rate, residues of desmedipham in/on sugar
beets were \<0.05 ppm for the 18 samples of roots and \<0.05 ppm to
0.135 ppm for the 18 samples of tops harvested at 71-75 DAT, and only 5
of the 18 tops samples had residues \>LOQ. The HAFT residues were \<0.05
ppm for roots and 0.10 ppm for tops, and average residues were 0.025 ppm
for roots and 0.045 ppm for tops.

*Conclusions*. Pending submission of the requested storage stability
data, the available sugar beet field trial studies are adequate. The
earlier field trial data on tops (MRID 42516500/01) along with the more
recent field trial data on tops and roots (MRID 46773001) are sufficient
to support the current maximum use rate of desmedipham (EC) on sugar
beets, which allows for two applications totaling 1.95 lb ai/A. Although
residue data for roots are available from only 9 of the required 12
trials, the available root data are adequate as residues in/on all 18
samples were below LOQ. For the EC formulation, which is the only type
being supported, residues were \<0.05 ppm to 6.54 ppm in/on 27 samples
of sugar beet tops. Adequate data are also available to support the
labeled use of up to six low rate applications at 0.2 lb ai/A with the
inclusion of methylated seed oil (1.5%, v/v) as an adjuvant.

**860.1520 Processed Food and Feed**

DP Barcode D216436, Desmedipham RED, D. Miller, 08/18/95

An adequate sugar beet processing study is available. Residues of
desmedipham were nondetectable (\<0.05 ppm) in sugar beet processed
commodities (processed roots, cossettes, dried pulp, refined sugar, and
molasses) generated from sugar beet roots bearing nondetectable residues
following treatment at 2x the maximum seasonal rate (the highest
tolerated rate). As residues were \<LOQ in the RAC and processed
fractions following applications at the highest tolerated rate, separate
tolerances for sugar cane molasses, dried pulp, and sugar are not
required.

**860.1650 Submittal of Analytical Reference Standards**

As of 07/2006, an analytical reference standard for desmedipham is
available at the EPA National Pesticide Standards Repository.

**860.1850 Confined Accumulation in Rotational Crops**

DP Barcode D216436, Desmedipham RED, D. Miller, 08/18/95

The nature of the residues in rotational crops is adequately understood.
The available confined rotational crop study is adequate, provided the
dates of sample extraction and analysis for each crop matrix as well as
supporting storage stability data reflecting the storage intervals and
conditions of samples from the study are submitted. The existing study
used an application rate of 2.2 lb ai/A, which is \~1x the maximum use
rate for sugar beets.

Limited and/or extensive field rotational crop studies are not required
because residues of the regulated parent were predominately \<0.01 ppm
in/on rotational crop commodities from the 30-day plant-back interval.
Therefore, rotational crop restrictions are not necessary and no
plant-back intervals need be prescribed.

**860.1550 Tolerances**

The Agency has determined that the regulated residue for desmedipham in
plant and animal commodities is desmedipham *per se*. Permanent
tolerances are established for residues of desmedipham at 0.2 ppm in/on
sugar beet roots and tops \[40 CFR §180.353(a)\]. The existing
tolerances for sugar beet roots and tops are listed in Table 6, along
with the Agency's recommended reassessed tolerance levels.

As Bayer is only supporting the use of EC formulations of desmedipham,
only residue data from trials using EC formulations will be used for
tolerance reassessment. In the field trials conducted at a 1x rate,
residues in/on 27 samples of tops were \<0.05ppm - 6.35 ppm, with 16
samples having residues \<0.05 ppm, 10 samples having residues of 0.06
ppm to 2.19 ppm, and one sample having residues at 6.35 ppm. Based on
the maximum residue value, the tolerance for tops should be reassessed
to 5 ppm. The tolerance for roots can be reduced 0.1 ppm as residues
were \<LOQ (\<0.05 ppm) in/on all 18 samples of sugar beet roots.

There are no established or proposed Codex, Canadian or Mexican MRLs for
desmedipham (see International Residue Limit Status Sheet, attached).
Therefore, no compatibility questions exist with respect to the
recommended U.S. tolerances.

  ----------------- ------------- ------------- ---------------------------
  **Table 6.                                    
  Tolerance                                     
  Reassessment                                  
  Summary for                                   
  Desmedipham.**                                

  Commodity         Existing      Recommended   Comments
                    Tolerance     Tolerance     
                    (ppm)         (ppm)         

  Beet, sugar,      0.2           0.1           Following application of
  roots                                         the EC formulation at a 1x
                                                rate, residues were \<0.05
                                                ppm in/on 18 samples of
                                                roots and \<0.05-6.35 ppm
                                                in/on 27 samples of tops
                                                harvested around the
                                                labeled 75-day PHI.

  Beet, sugar, tops 0.2           5.0           
  ----------------- ------------- ------------- ---------------------------

RDI: P. Yvonne Barnes (11/07/2006), Donald Wilbur (11/20/2006).

**References**

DP Barcode: D184329

Subject: Desmedipham 6(a)(2) Submission form Nor-Am Chemical Company
dated October 15, 1992.

From: D. Miller

To: W. Allan

Dated: 12/22/92

MRID(s): 42516500 and 42516501

DP Barcode: D213531

Subject: Desmedipham. Outcome of 3/27/95 Meeting of HED Metabolism
Committee.

From: D. Miller

To: HED Metabolism Committee

Dated: 04/10/95

MRID(s): None

DP Barcode: D216436

Subject: Desmedipham. (104801) Product and Residue Chemistry Chapters
for the Reregistration Eligibility Decision (RED).

From: D. Miller

To: R. Gebken and A. Aikens

Dated: 08/18/95

MRID(s): None

Attachments:

International Residue Limit Status sheet

Template Version September 2005

+-------------------+--------------+--------------------+-------------+
| INTERNATIONAL     |              |                    |             |
| RESIDUE LIMIT     |              |                    |             |
| STATUS            |              |                    |             |
+===================+==============+====================+=============+
| Chemical Name:    | Common Name: | X Proposed         | Date:       |
| ethyl             | Desmedipham  | tolerance          | 08/25/2006  |
| \[3-\[\[(pheny    |              |                    |             |
| lamino)carbonyl\] |              | Reevaluated        |             |
| oxy\]             |              | tolerance          |             |
| phenyl\]carbamate |              |                    |             |
|                   |              | Other              |             |
+-------------------+--------------+--------------------+-------------+
| Codex Status      |              | Recommended U. S.  |             |
| (Maximum Residue  |              | Tolerances         |             |
| Limits)           |              |                    |             |
+-------------------+--------------+--------------------+-------------+
| X No Codex        |              | Petition Number:   |             |
| proposal step 6   |              | NA                 |             |
| or above          |              |                    |             |
|                   |              | DP Barcodes:       |             |
| No Codex proposal |              | D327440            |             |
| step 6 or above   |              |                    |             |
| for the crops     |              |                    |             |
| requested         |              |                    |             |
+-------------------+--------------+--------------------+-------------+
| Residue           |              | Reviewer/Branch:   |             |
| definition (step  |              | P. Yvonne Barnes,  |             |
| 8/CXL):           |              | RRB2               |             |
+-------------------+--------------+--------------------+-------------+
|                   |              | Residue            |             |
|                   |              | definition:        |             |
|                   |              | Desmedipham        |             |
+-------------------+--------------+--------------------+-------------+
| Crop (s)          | MRL (mg/kg)  | Crop(s)            | Tolerance   |
|                   |              |                    | (ppm)       |
+-------------------+--------------+--------------------+-------------+
|                   |              | Beet, sugar, roots | 0.1         |
+-------------------+--------------+--------------------+-------------+
|                   |              | Beet, sugar, tops  | 5.0         |
+-------------------+--------------+--------------------+-------------+
|                   |              |                    |             |
+-------------------+--------------+--------------------+-------------+
|                   |              |                    |             |
+-------------------+--------------+--------------------+-------------+
|                   |              |                    |             |
+-------------------+--------------+--------------------+-------------+
| Limits for Canada |              | Limits for Mexico  |             |
+-------------------+--------------+--------------------+-------------+
| X No Limits       |              | X No Limits        |             |
|                   |              |                    |             |
|  No Limits for   |              |  No Limits for    |             |
| the crops         |              | the crops          |             |
| requested         |              | requested          |             |
+-------------------+--------------+--------------------+-------------+
| Residue           |              | Residue            |             |
| definition:       |              | definition:        |             |
+-------------------+--------------+--------------------+-------------+
| Crop(s)           | MRL (mg/kg)  | Crop(s)            | MRL (mg/kg) |
+-------------------+--------------+--------------------+-------------+

Rev. 1998