Proposals to Amend the 
Maximum Residue Levels for 
Agricultural Compounds Food 
Notice December  2018   
 MPI Discussion  Paper  No: 2019/04  
 
 
 Prepared for public consultation  
By the Assurance Directorate of the Ministry for Primary Industries  
  ISBN No: 978 -1-98-859466- 8 (online)  
ISSN No: 2253- 3907 (online)  
    
June  2019 
 
 
Disclaimer  
 
While every effort has been made to ensure the information in this publication is accurate, 
the Ministry for Primary Industries does not accept any responsibility or liability for error of 
fact, omission, interpretation or opinion that may be present, nor for the consequences of any 
decisions based on this information.  
 
Requests for further copies should be directed to:  
 
Publications Logistics Officer  
Ministry for Primary Industri es 
PO Box 2526 
WELLINGTON 6140 
 
Email: brand@mpi.govt.nz  
Telephone: 0800 00 83 33 Facsimile: 04- 894 0300 
 
This publication is also available on the Ministry for Primary Industries website at  
http://www.mpi.govt.nz/news -and-resources/publications/
  
  
© Crown Copyright -  Ministry for Primary Industries   
i Contents  Page 
 
1 Submissions  2 
2 Introduction 3 
2.1 Background  3 
2.2 Summary of Proposed Amendments  5 
3 Proposals  8 
3.1 Proposal to amend the MRLs for clethodim  8 
3.2 Proposal to set MRLs for c oumatetralyl  9 
3.3  Proposal to amend the MRLs for difenoconazole 9 
3.4 Proposal to set MRLs for difethialone  12 
3.5 Proposal to set MRLs for diphacinone 13 
3.6 Proposal to amend the MRLs for eprinomectin  14 
3.7 Proposal to amend the MRLs for flufenacet  166 
3.8 Proposal to set MRLs for flumioxazin  17 
3.9 Proposal to amend the MRLs for flusilazole  188 
3.10 Proposal to set MRLs for isoflucypram  20 
3.11 Proposal to amend the MRLs for mandestrobin 21 
3.12 Proposal to amend the MRLs for metrafenone 22 
3.13 Proposal to set MRLs  for metribuzin 24 
3.14 Proposal to set MRLs for pyroxasulfone  25 
3.15 Proposal to set MRLs for tetran iliprole  27 
3.16  Proposal to exempt Chromobacterium subtsugae PrAA4-1T and its metabolites 
(including violacein)  27 
3.17  Proposal to amend the exemption for bromochlorodimethylhydantoin  29 
3.18  Proposal to exempt cross -linked polyacrylamide  29 
3.19  Proposal to exempt  vaccine and diagnostic  antigens  30  
2 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  1 Submissions  
The Ministry for Primary Industries (MPI) invites public comment on this discussion 
document, which outlines proposals to amend the New  Zealand (Maximum Residue Levels 
for Agricultural Compounds) Food Notice.  
 
 
For each compound  you are commenting on, please clearly answer the following questions. 
Any additional comment is welcome, along with supporting discussion, and data or examples 
to illustrate particular points.  
 
On balance, do you oppose any of the commodity MRLs proposed for this compound?  
 
Do you oppose an MRL being set at all  for this compound for the commodity? 
 
If an MRL is to be set for this compound for the commodity, do you disagree with the 
particular level proposed? If so, why do you disagree?  
 
Submissions close at 5pm on  6 August  2019 . Your comments should be sent to:  
 
MRL Amendments  
ACVM Programmes and Appraisals  
MPI Assurance Directorate  
PO Box 2526 
Wellington 6140 
 
Email: ACVM.Consultation@mpi.govt.nz . 
 Please include your name and address on your submission. If you are making comments on 
behalf of an organisation, also include your title and the name of the organisation.  
 Please make sure your comments can be clearly read, as a number of copies of your 
submission may be made.  
 
The Official Information Act  
The Official Information Act 1982 (the OIA) states that information is to be made available 
unless there are grounds for withholding it. The grounds for withholding information are 
outlined in the OIA.  Submitters may wish to indicate any grounds for withholding information 
contained in their submission.  Reasons for withholding information could include that 
informa tion is commercially sensitive or that the submitters wish personal information such 
as names or contact details to be withheld.  MPI will take such indications into account when determining whether or not to release information.  Any decision to withhold information 
requested under the OIA may be reviewed by the Ombudsman.   
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 3  
2 Introduction  
Agricultural compounds are natural or synthetic substances used in the management of 
plants and animals, and include veterinary medicines, fertilisers , and pesticides (fun gicides, 
herbicides and insecticides). Growers and farmers use agricultural compounds to manage disease in animals and crops, protect the food supply , and maximise the quantity and quality 
of the food they grow.  
Use of t hese agricultural compounds can leav e residues in the food from those crops and 
animals that must be managed . To ensure only the appropriate amount of agricultural 
compounds are used to achieve their intended purpose, a set of principles and methods 
known as good agricultural practice (GAP) are utilised.  GAP covers  the production of safe 
and good quality horticultural and animal  products.  
GAP is established for each agricultural compound by evaluating public health, crop safety, 
animal health and  safety, and occupational and environmental sa fety considerations for the 
range of treatments and use patterns . This involves determining the administration and 
application rates and ranges necessary for  an agricultur al compound to achieve its intended 
effects, while leaving the smallest amount of res idue practicable without compromising that 
efficacy.  
Once the GAP has been established for a use for an agricultural  compound, the residues 
resulting from its use up to the highest authorised dose or application rate is then used to 
establish maximum resi due levels (MRLs) in food commodities from crops and animals 
associated with that use.  The MRLs are then compared against the health based guidance 
value in an evaluation commonly referred to as the dietary exposure (or dietary risk) 
assessment. This is ex plained in more detail below.   
MRLs are the maximum legal levels for residues of agricultural compounds permitted in food 
for sale in New Zealand. They are established based on domestic uses of a particular 
compound, and are used to monitor GAP compliance in New Zealand while ensuring food 
safety . Because they are based on New Zealand authorised uses according to domestic 
GAP, MRLs  may differ from those established overseas for a similar use because their GAP 
may be different.  However, as noted below, impo rted food can also comply with Codex 
MRLs.  
To meet New Zealand’s obligations under the Agreement on the Application of Sanitary and 
Phytosanitary Measures  (the SPS Agreement)  the proposed MRL will be notified to the 
World Trade Organization. Any country may choose to comment if they believe the proposed MRL represents a barrier to their trade.  
2.1 BACKGROUND  
MRLs are set out in the New Zealand (Maximum Residue Levels for Agricultural Compounds) Food Notice. This Notice is amended two to three times each year to  reflect 
changes in the use of agricultural compounds in the production of food. The MRL Food Notice is available from the Ministry for Primary Industries (MPI) Food Safety website at: 
https://www.mpi.govt.nz/dmsdocument/19550- maximum- residue- levels -for-agricultural -
compounds .  
MPI administers the MRL Food Notice, with the final decision on any changes to the Notice 
resting with the Director -General of  MPI. The Food Notice is issued under section 405 of the 
Food Act 2014. When setting or amending MRLs, the Director -General must take into 
account:  
• the need to protect public health;   
4 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  • the desirability of avoiding unnecessary restrictions on trade;  
• the desir ability of maintaining consistency between New Zealand’s food standards 
and those  standards that apply  internationally;  
• New Zealand’s obligations under any relevant international treaty, agreement, 
convention, or protocol, and, in particular, under the Aus tralia -New Zealand Joint 
Food Standards Agreement; and  
• such other matters as appropriate.  
 
The requirements for the content of the MRL Food Notice are set out in Part 6 of the Food 
Regulations 2015, allowing for the promulgation of MRLs for agricultural co mpounds as well 
as the promulgation of exemptions from compliance with MRLs. In addition to establishing the requirements on domestically produced foods, Part 6 of the Food Regulations also 
outlines the residue level compliance requirements for imported foods. Clause 144 states 
that imported food must contain residues of agricultural compounds:  
- no greater than the MRLs specified for that food in a notice set under the Food 
Act 2014 (section (1)(a)); or  
- the default MRL of 0.1 mg/kg (section (1)(c)); or  
- the current editions of either the Maximum Residue Limits (MRLs) and 
Extraneous Maximum Residue Limits (EMRLs) for Pesticides (Codex Pesticides 
Residues in Food Online Database), or the Maximum Residue Limits for Veterinary Drugs in Food (Codex Veterinary Drug  Residue in Food Online 
Database) (section (1)(d)).  
 
As imported food commodities can comply with either a Codex MRL or a MRL established in 
the MRL Food Notice, New Zealand’s obligations under the  SPS Agreement  are met.  
On the whole, the Regulations allow  for the management of residues in all foods consumed 
in New Zealand.  
2.1.1 National Estimated Dietary Intake  
The chronic dietary exposure to a substance is estimated by the NEDI calculation, encompassing all authorised uses of the agricultural compound, and using food consumption 
data based upon the 1997 National Nutritional Survey for adults and the 1995 National 
Nutrition Survey of Australia, for children. The NEDI calculation is made in accordance with 
Guidelines for predicting dietary intake of pesticide r esidues (revised) [World Health 
Organization, 1997]. The NEDI calculation provides an estimation of the potential chronic 
exposure to toxicologically relevant residues in all food derived from crops/livestock treated 
with the agricultural compound accordin g to the authorised use (GAP).  
The possible implications for consumer health are considered during the toxicological and dietary risk assessments, by comparing the NEDI with a HBGV. Provided the estimated 
dietary exposure of all toxicologically relevant residue components in all fresh and processed 
food is less than the HBGV, the use of an agricultural compound according to GAP is unlikely 
to pose a health risk to consumers.  
2.1.2 Health Based Guidance Values  
The HBGV used in determining the estimated dietary exposure may be either a Potential 
Daily Exposure (food) (PDE (food)) or an Acceptable Daily Intake (ADI). The ADI and PDE (food) 
are largely equivalent, as they are determined using the same set of toxicology data and through a very similar scientific process.  HBGVs are reported as milligrams of compound per 
kilogram bodyweight  per day  (mg/kg  bw/d ). 
A PDE
(food) is a value determined by a toxicological evaluation by the New Zealand 
Environmental Protection Authority (EPA) as part of its responsibility for managi ng public  
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 5 health under the Hazardous Substances and New Organisms Act 1996 (the HSNO Act).  A 
PDE (food) gives the potential daily exposure a person may be subject to from a substance, via 
food.  
An ADI is defined by the World Health Organization (WHO) as: “the daily intake which, during 
an entire lifetime, appears to be without appreciable risk on the basis of all the known facts at 
the time”. “Without appreciable risk” has been further defined as: “the practical certainty that 
injury will not result even a fter a lifetime of exposure”. ADIs are established by the WHO and 
Food and Agriculture Organization (FAO) of the United Nations joint expert committees, 
which are made up of toxicologists and residue specialists. The ADI information from these 
joint commit tees also feeds into the Codex Alimentarius Commission (Codex), which sets 
international MRLs.  
As required by the HSNO Act in New Zealand, MPI uses the PDE (food) set by the EPA as the 
HBGV for the estimation of dietary exposure when one is available. If t here is no PDE (food), 
the estimated dietary exposure is compared with the ADI, set by the WHO/FAO joint expert 
committees, the Australian Pesticides and Veterinary Medicines Authority (APVMA), the 
European Food Safety Authority (EFSA), or another regulator y authority. If none of these are 
available, the HBGV used will be an MPI -determined ADI.   
2.1.3 International MRLs and Trade  
The “Relevant International MRLs” table listed in each entry is a summary of the MRLs set by Codex and a selection of other international regulatory bodies reviewed to evaluate trade 
risk. For animal commodities, the MRLs set by our major trading partners (Australia, Canada, 
China, Codex, the European Union, Japan, and the United States) are reviewed and 
compared; for horticultural commodities, MRLs set by Codex and Australia are reviewed and 
compared. Other international MRLs are reviewed and reported in the table if there is a 
particular trade risk to be considered for those regions. If a particular international body or 
regulator does not have MRLs set for the species or crop for which a New Zealand MRL is 
being proposed, that international body or regulator is omitted from the “other international 
MRLs” section of the entry.  
 
 
2.2 SUMMARY OF PROPOSED AMENDMENTS  
The proposed MRLs have been thoroughly assessed in accordance with international 
methodologies published by the Organisation for Economic Cooperation and Development 
(OECD) , International Cooperation on Harmonisation of Technical Requirements for 
Registration of Veterinary Medicinal Products (VICH) , or FAO. Information on the technical 
assessment of each proposal is included in this document (refer section 3) and covers:  
 
• rationale;  
• chemical information;  
• good agricultural practice;  
• residues information;  
• dietary risk assessment;  
• toxico logical/public health assessment; and  
• MRLs set by Codex and other relevant authorities (e.g. Australia, Canada, China, EU, 
Japan, USA)  
 
Where an existing entry is proposed for revision, new or revised MRLs are highlighted in bold 
print, and MRLs proposed f or revocation are identified using a strikethrough.  
 MPI has reviewed the estimated dietary exposure assessments associated with all 
authorised and proposed uses according to what has been established as GAP for New 
Zealand, compared them with the appropr iate HBGV (the PDE
(food) or an ADI), and has  
6 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  concluded that residues arising from these uses are unlikely to present any public health or 
food safety concerns.  
2.2.1 Amendments to Schedule 1: New  and Amended MRLs  
MPI proposes to add new MRLs to the Food Notice, and/or amend the existing entries , for 
the following compounds:  
• Clethodim: 0.02(*)  mg/kg in grapes .  
• Coumatetralyl: 0.001(*) mg/kg in any food.  
• Difenoconazole: 0.05 mg/kg in grapes; 0.01 mg/kg in mammalian fat (except milk fat); 
0.01 mg/kg in mammalian meat ; 0.01 mg/kg in mammalian offal; and 0.01 mg/kg in 
milk.  
• Difethialone: 0.001(*) mg/kg in any food.  
• Diphacinone: 0.001(*) mg/kg in any food.  
• Eprinomec tin: 0.1 mg/kg in sheep fat; 0.05 mg/kg in sheep meat;  0.2 mg/kg in sheep 
offal; and 0.02 mg/kg in sheep milk. 
• Flufenacet: 0.01(*) mg/kg in potatoes.  
• Flumioxazin: 0.02(*) mg/kg in grapes; 0.02(*) mg/kg in kiwifruit; 0.02(*) mg/kg in pome 
fruits; 0.02(*) mg/kg in stone fruits; 0.02(*) mg/kg in mammalian fat, meat, and offal; and 0.02(*) mg/kg in milk.  
• Flusilazole: 0.01(*) mg/kg in grapes, 0.05(*) mg/kg in mammalian fat, 0.01(*) mg/kg in mammalian meat, 0.01(*) mg/kg in mammalian offal, and 0.01(*) mg/kg in milk.  
• Isoflucypram: 0.15 mg/kg in barley  grain ; 0.01(*) in eggs; 0.04 (*) mg/kg in mammalian 
fat; 0.0 1(*) mg/kg in mammalian  offal; 0.01 (*) mg/kg in mammalian meat; 0.005(*)  
mg/kg in milk;  0.01(*) in poultry meat; 0.02 mg/kg in poultry  offal; 0.02 mg/kg in wheat  
grain; and 0.02 mg/kg in triticale grain.  
• Mandestrobin: 1.5 mg/kg in head lettuce; and 10 mg/kg in leafy lettuce.  
• Metrafenone: 0.15 mg/kg in grapes; 0.01 (*) mg/kg in mammalian fat; 0.01 (*) mg/kg in 
mammalian meat ; 0.01 (*) mg/kg in mammalian offal; and 0.01 (*) mg/kg in milk.  
• Metribuzin: 0.01(*) mg/kg in potatoes.  
• Pyroxasulfone: 0.02(*) mg/kg in eggs; 0. 02(*) mg/kg in mammalian fat; 0.02(*) mg/kg 
in mammalian meat; 0.02(*) mg/kg in mammalian offal; 0.002(*) mg/kg in milk; 0.02(*) mg/kg in poultry meat; 0.02(*) mg/kg in poultry offal; 0.01(*) mg/kg in triticale; and 0.01 (*) mg/kg in wheat.  
• Tetraniliprole:  0.2 mg/kg in pome fruits.  
(*) indicates that the maximum residue level has been set at or about the limit of analytical quantification.  
2.2.2 Amendments to Schedule 2: New and Amended Ex emptions  from Maximum Residue 
Levels for Agricultural Chemicals  
• MPI proposes to add a new exemption for Chromobacterium subtsugae  PRAA4 -1T 
and its metabolites (including violacein) to the list of agricultural compounds  in 
Schedule 2 of the Food Notice for which no maximum residue levels apply. The 
organism and its metabolites are used for the control of mealybugs on grape vines.  
• MPI proposes to amend the current entry for b romochlorodimethylhydantoin in the list 
of agricultural compounds in Schedule 2 of the Food Notice, for which no maximum  
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 7 residue levels apply. The amendment i s being proposed to better represent the 
isomeric mixture s referred to as  bromochlorodimethylhydantoin by including four  
additional Chemical Abstract Service ( CAS) numbers associated with these mixtures .   
2.2.3 Amendments to Schedule 3: Exemptions from Maximum Residue Levels for Veterinary 
Medicines  
• MPI proposes to add a new exemption for cross -linked polyacrylamide to the list of 
agricultural compounds in Schedule 3 of the Food Notice, for which no maximum 
residue levels apply. The compound is used as an intra -articular arthritis treatment in 
horses.  
• MPI proposes to add a new exemption for antigens used in vaccines and for 
diagnostic purposes to the list of agricultural compounds in Schedule 3 of the Food 
Notice, for which no maximum residue levels apply.       
8 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  3 Proposals  
3.1 PROPOSAL TO AMEND THE MRLS FOR  CLETHODIM  
It is proposed that MRLs for clethodim  are amended to include an MRL to support the GAP 
use of the compound on grapes . 
The revised entry  for clethodim in Schedule 1 of the Notice will read as follows. Changes are 
shown in bold:  
Compound 
Common Name  CAS#  Residue to which the maximum 
residue l evel applies  Food  Maximum Residue 
Level (mg/kg)  
Clethodim  99129 -21-2 Sum of:  
Clethodim and its metabolites 
containing  
5-(2-ethylthiopropyl)cyclohexene- 3-
one and 5- (2-ethylthiopropyl) -5-
hydroxycyclohexene- 3-one moieties 
and their sulphoxides and sulphones  
Expressed as:  
Clethodim  Brassica vegetables  
Fruiting vegetables  
Grapes 
Leafy vegetables  
Legume vegetables  
Mammalian meat  
Mammalian offal  
Milk 
Stem vegetables  1 
1 
0.02(* ) 
1 
1 
0.2 
0.2 
0.05 
1 
(*) indicates that the maximum residue level has been set at or about the limit of analytical quantification.  
3.1.1 Amendment Rationale  
The MRL is being proposed to support a new use for clethodim in vineyards in accordance 
with the  application rates and withholding periods that are proposed as GAP in New Zealand.  
3.1.2 Good Agricultural Practice  
Clethodim is  a cyclohexene oxime herbicide sprayed around grape vines  at a rate of 61- 720 
gai/ha . The compound is applied to control actively growing gr ass weeds by application to 
the base of vines  before the start of flowering . Clethodim is not to be applied after the start of 
flowering, and therefore will not be applied when fruit is present .   
3.1.3 Residue Information  
The residue data for the use of clethodim to control weeds in vineyards  are sufficient to 
conclude that, when applied as per the proposed GAP use pattern  and complying with the 
use restrictions,  residues of clethodim and its metabolites would not exceed the limit of 
analytical quantification of  0.02 mg/kg. The p roposed MRL for grapes, set at 0.02 mg/kg, will 
therefore be sufficient to support GAP for this use pattern.   
The proposed use of the compound in vineyards also adds to the potential for animal 
residues from vineyard grazing. A review of all available residue and dietary burden data 
confirmed that the existing animal commodity MRLs will be sufficient to manage residues in 
animals grazed in vineyards. There are no changes proposed for the animal commodity 
MRLs for clethodim.  
The residue de finition used for the other foods, which applies to both GAP compliance and 
dietary intake, can apply to the use of clethodim on grapes.  
3.1.4 Dietary Risk Assessment  
The HBGV  of 0.005 mg/kg bw/d  and the stated dietary intake residue definition , was 
considered appropriate for use in the assessment.  
The dietary exposure risk assessment was based on the residue profile expected in food 
from crops treated with clethodim, as well as in animal products from livestock that  either  
consume treated animal feed crops or graze in treated vineyards. The assessment  
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 9 concluded that  the NEDI for clethodim would total less than 74% of the HBGV when the 
compound is used according to existing and proposed GAP uses.  
MPI has therefore determined that the use of clethodim  on grapes  according to the GAP 
specified above, in addition to the previously approved uses, is unlikely to pose any health 
risks from authorised use.   
3.1.5 Relevant International MRLs  
There are no MRLs set by either Australia or Codex for grapes.  
3.2 PROPOSAL TO SET MRLS FOR  COUMATETRALYL  
It is proposed that MRLs are set for coumatetralyl to support the GAP use of the compound as a rodenticide vertebrate toxic agent (VTA).  
There is currently no entry for coumatetralyl in the Notice. The new entry in Schedule 1 of the 
Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food  Maximum Residue 
Level (mg/kg)  
Coumatetralyl  5836- 29-3 Coumatetralyl  Any food  0.001(*)  
(*) indicates that the maximum residue l evel has been set at or about the l imit of analytical quantification.  
3.2.1 Amendment Rationale  
The MRL is being proposed to support the use of coumatetralyl in the management of 
vertebrate pests in New Zealand according to approved use patterns that are considered 
GAP. Though the use of the compound is not novel, the MRL is being proposed to ensure 
compliance with GAP  in food from exposed plants or animals .  
3.2.2 Good Agricultural Practice  
Coumatetralyl is a first -generation coumarin rodenticide used as a rodent bait on farm, 
commercial, and industrial buildings, and in priv ate residences and refuse dumps.  Sale and 
use of the compound is restricted to those approved by MPI as per the product label.   
3.2.3 Residue Information  
The established GAP for this compound dictates that it is used in such a way that there are 
no detectable residues in any food intended for human consumption. As such, the new MRL 
has been proposed to be set at the limit of analytical quantification to ensure a lack of 
residues in all food commodities.  
The residue definition is proposed to be set as the parent compound for all foods, in line with 
international residue definitions for coumatetralyl.  
3.2.4 Dietary Risk Assessment  
There is no HBGV available to calculate the dietary intake exposure for coumatetralyl. However, g iven the proposed control means there are no quantifiable residues permitted in 
any food , the dietary exposure can be expected to be negligible when the compound is used 
according to GAP. MPI has therefore determined that the use of coumatetralyl as a 
rodenticide according est ablished GAP is unlikely to pose any health risks from authorised 
use.
   
10 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  3.2.5 Relevant International MRLs  
Country                                                          Food  Maximum Residue L evel 
(mg/kg)  
Australia  Pig fat  
Pig liver  
Pig meat  
  Pig offal (excep t liver ) 0.001  
0.004 
0.001 
0.003  
European Union  Any food  0.01 
Japan Any food (uniform limit)  0.01 
3.3 PROPOSAL TO  AMEND THE MRLS FOR  DIFENOCONAZOLE  
It is proposed that MRLs for difenoconazole are amended t o support the GAP use of the 
compound on grapes . Because this compound has not previously been approved for use on 
animal feed crops or pasture, it is also proposed that the entry in the Notice is amended to 
include MRLs for animal commodities to manage residues from vineyard grazing.  
The revised entry  for difenoconazole in Schedule 1 of the Notice will read as follows. 
Changes are shown in bold:  
Compound 
Common Name  CAS#  Residue to which the maximum 
residue level  applies  Food  Maximum Residue 
Level (mg/kg)  
Difenoconazole  119446 -68-3 Plant commodities: Difen oconazole  
 
Animal commodities: sum of difenoconazole and 1 -[2-chloro -4-(4-
chloro- phenoxy) - phenyl] -2-(1,2,4 -
triazol) -1-yl-ethanol), expressed as 
difenoconazole  Brassica vegetables  
Grapes Mammalian fat 
(except milk fat)  
Mammalian meat  
Mammalian  offal  
Milk 0.2 
0.05 
 
0.01 
0.01 
0.01 
0.01 
3.3.1 Amendment Rationale  
The MRL s are being proposed to support a new use for difenoconazole on grapes  in 
accordance with the application rates and withholding periods that are proposed as GAP in 
New Zealand.  
3.3.2 Good Agricultural Pr actice 
Difenoconazole is a triazole fungicide used in vineyards  as a single foliar spray of 6.25 
gai/100L  to manage powdery mildew.  It is to be applied over the infection period during 
active leaf and berry growth, up to or just after bunch closure. Use of  difenoconazole in this 
manner will attract a 56 day withholding period for grapes, and a two month pre -slaughter 
interval for animals grazed in treated vineyards.  
3.3.3 Residue Information  
The residue data for the use of difenoconazole on grapes  are sufficient  to conclude that, 
when applied as per the proposed GAP use pattern and complying with the use restrictions 
and withholding periods,  difenoconazole residues should not exceed 0.03 mg/kg in grapes . 
As with brassica vegetables, the residue data in grapes dem onstrated that the primary 
residue was parent difenoconazole and therefore the existing plant commodities residue 
definition will apply.   
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 11 The animal metabolism studies demonstrated that the primary residues for difenoconazole in 
animal commodities were the parent  compound and the 1- [2-chloro -4-(4-chloro- phenoxy) - 
phenyl] -2-(1,2,4 -triazol) -1-yl-ethanol  metabolite, also known as CGA 205375, in all tissues 
and milk. This is consistent with the assessment conducted by the Joint FAO/WHO Meeting 
on Pesticide Resi dues (JMPR) , which informed the Codex definition for both dietary intake 
and MRL compliance for animal commodities:  the sum of difenoconazole and 1- [2-chloro -4-
(4-chloro -phenoxy) - phenyl] -2-(1,2,4 -triazol) -1-yl-ethanol), expressed as difenoconazole.  This 
residue definition is considered appropriate to adopt for the promulgation of New Zealand 
MRLs for this compound.   
Animal r esidue data demonstrated that concentrations of difenoconazole and its metabolite, 
when used on grape vines according to  New Zealand GAP and observing the two month pre -
slaughter interval, should not exceed 0.01 mg/kg in all tissues  and milk. It is noted that the 
proposed New Zealand milk MRL exceeds that set by the EU. This is  likely  due to the 
difference in the residue definitions: the Codex residue definition, and that proposed for New 
Zealand, is the sum of the parent compound and its metabolite , whereas the EU residue 
definition is for parent compound only . The proposed GAP use of the compound in New 
Zealand would result in parent di fenoconazole residues that can be expected to be compliant 
with the EU milk MRL of 0.005 mg/kg.  
3.3.4 Dietary Risk Assessment  
The HBGV  of 0.0 05 mg/kg  bw/d  and the stated dietary intake residue definitions,  was 
considered appropriate for use in the assessment.  
Based on the residue profile expected in food from crops treated with di fenoconazole,  as well 
as in animal products from livestock that  graze in treated vineyards , the NEDI for 
difenoconazole is  estimated to total  less than 11% of the HBGV when the compound  is used 
according to existing and proposed GAP uses.  
MPI has therefore determined that the use of difenoconazole on grape vines  according to the 
GAP specified above, and the grazing of animals in treated vineyards, is unlikely to pose any 
health risks  with authorised use.    
12 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  3.3.5 Relevant International MRLs  
Country                                                      Food  Maximum Residue  
Level (mg/kg)  
Australia  Edible offal ( mammalian)  
Meat (mammalian)  
Milks                                     0.05 
0.05 
0.01 
Canada                   Liver of ruminants  
Meat byproducts of ruminants  
Meat of ruminants  0.1 
0.05 
0.05 
Codex  Edible offal (mammalian)  
Grapes                   
Meat (from mammals other than marine mammals , as fat)  
Milks                         1.5 
3 
0.2 
0.02 
European Union  Ruminant  muscle          
Ruminant  fat             
Ruminant liver          
Ruminant  kidney    
Ruminant edible offals (other than liver and kidney)      
Milk                          0.05 
0.05 
0.2 
0.2 
0.2 
0.005 
Japan  Mammalian muscle                           
Mammalian fat                                                              
Mammalian liver                                                              
Mammalian kidney                                       
Mammalian edible offal                  
Milk                                                0.2 
0.2 
2 
2 
2 
0.01 
United States  Cattle, goat, and sheep by products  
Cattle, goat, and sheep fat  
Cattle, goat, horse, and sheep kidney  
Cattle, goat, horse, and sheep liver  
Cattle, goat, horse, and sheep meat  
Milk                                      0.1 
0.1 
0.1 
0.4 
0.05 
0.02 
3.4 PROPOSAL TO SET MRLS FOR  DIFETHIALONE  
It is proposed that MRLs are set for difethialone to support the GAP use of the compound as 
a rodenticide VTA . 
There is currently no en try for difethialone in the Notice. The new entry in Schedule 1 of the 
Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food  Maximum Residue 
Level (mg/kg)  
Difethialone  104653- 34-1 Difethialone  Any food  0.001(* ) 
(*) indicates that the maximum residue l evel has been set at or about the limit of analytical quantification.  
3.4.1 Amendment Rationale  
The MRL is being proposed to support the use of difethialone in the management of 
vertebrate pests in New Zealand according  to approved use patterns that are considered 
GAP.  Though the use of the compound is not novel, the MRL is being proposed to ensure 
compliance with GAP.    
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 13 3.4.2 Good Agricultural Practice  
Difethialone is  a 4-thiochromenone rodenticide used in buildings and refuse dumps  in bait 
form to manage rodent pests . Sale and use of the compound is restricted to those approved 
by MPI as per the product label.   
3.4.3  Residue Information  
The established GAP for this compound dictates that it is used in such a way that there are 
no detectable residues in any food intended for human consumption. As such, the MRL has 
been proposed to be set at the limit of analytical quantification in New Zealand to ensure a 
lack of residues in all food commodities.  
The residue definition is proposed t o be set as the parent compound for all foods, in line with 
international residue definitions for difethialone.  
3.4.4 Dietary Risk Assessment  
There is no HBGV available to calculate the dietary intake exposure for difethialone. Given 
the proposed control means t here are no quantifiable residues permitted in any food 
however, the dietary exposure can be expected to be negligible when the compound is used according to GAP. MPI has therefore determined that the use of difethialone as a rodenticide 
according establis hed GAP is unlikely to pose any health risks from authorised use.
   
3.4.5 Relevant International MRLs  
Country                                                          Food  Maximum Residue  
Level (mg/kg)  
European Union  Any food  0.01 
Japan Any food (uniform limit ) 0.01 
3.5 PROPOSAL TO SET MRLS FOR  DIPHACINONE  
It is proposed that MRLs are set for diphacinone to support the GAP use of the compound as 
a rodenticide VTA . 
There is currently no entry for diphacinone in the Notice. The new entry in Schedule 1 of the 
Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum 
residue limit applies  Food  Maximum Residue 
Level (mg/kg)  
Diphacinone  82-66-6 Diphacinone  Any food  0.001(*)  
(*) indicates that the maximum residue l evel has been set at or about the limit o f analytical quantification.  
3.5.1 Amendment Rationale  
The MRL is being proposed to support the use of diphacinone in the management of 
vertebrate pests in New Zealand according to approved use patterns that are considered 
GAP.  Though the use of the compound is not novel, the MRL is being proposed to ensure 
compliance with GAP.   
3.5.2 Good Agricultural Practice  
Diphacinone is a first -generation indandione anticoagulant  rodenticide used as a rodent bait 
in farm, commercial, and industrial buildings,  as well as sewer lin es, scrubland, forestry and  
14 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  shelter belts, and other open areas. Sale and use of the compound is restricted to those 
approved by MPI as per the product label.   
3.5.3  Residue Information  
The established GAP for this compound dictates that it is used in such a way that there are 
no detectable residues in any food intended for human consumption. As such, the MRL has been proposed to be set at the or near the limit of analytical quantification  in New Zealand to 
ensure a lack of residues in all food commodities.  
The residue definition is proposed to be set as the parent compound for all foods, in line with 
international residue definitions for diphacinone.  
3.5.4 Dietary Risk Assessment  
There is no HBGV available to calculate the dietary intake exposure for diphacinone. Giv en 
the proposed control means there are no quantifiable residues permitted in any food 
however, the dietary exposure can be expected to be negligible when the compound is used 
according to GAP. MPI has therefore determined that the use of diphacinone as a 
rodenticide according established GAP is unlikely to pose any health risks from authorised 
use.  
3.5.5 Relevant International MRLs  
Country                                                          Food  Maximum Residue L evel 
(mg/kg)  
European Union  Any food  0.01 
Japan Any food (uniform limit)  0.01 
3.6 PROPOSAL TO AMEND THE MRLS FOR  EPRINOMECTIN  
It is proposed that MRLs for eprinomectin are amended to set MRLs for use of the compound 
in sheep.  
The revised entry  for eprinomectin in Schedule 1 of the Notice will read as follows. Changes 
are shown in bold:  
Compound 
Common Name  CAS#  Residue to which the maximum 
residue limit applies  Food  Maximum Residue Level 
(mg/kg)  
Eprinomectin  123997 -26-2 Eprinomectin B1a  Cattle fat  
Cattle kidney  
Cattle liver  
Cattle meat  
Cattle m ilk 
Sheep fat  
Sheep meat  
Sheep  offal  
Sheep milk  0.25 
0.3 
1.5 
0.05 
0.02 0.1 
0.05 0.2 
0.02 
 
3.6.1 Amendment Rationale  
The MRL s are being proposed to support  a new use for eprinomectin in sheep,  in 
accordance with the use pattern and withholding periods that are proposed as GAP in New 
Zealand.   
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 15 3.6.2 Good Agricultural Practice  
Eprinomectin is  an avermectin endoparasiticide used in food-producing and companion 
animals in  New Zealand. When used in sheep, the compound will be administered orally at a 
dose rate of 0.2 mg eprinomect in/kg body weight , when used in a multi -active formulation 
with oxfendazole and levamisole,  which will attract a meat withholding period of 16 days and 
a milk withholding period of 35 days.  
3.6.3 Residue Information  
The residue data for the use of eprinomectin in sheep  are sufficient to conclude that, when 
administered  as per the proposed GAP use pattern and observing the established 
withholding periods , residues should not exceed 0. 1 mg/kg in fat, 0.2 mg/kg in kidney, 0.2 
mg/kg in liver, 0.05 mg/kg in meat, and  0.02 mg/kg in milk from treated sheep. The data 
confirmed that the existing residue definition will be sufficient to manage GAP compliance in 
sheep.   
The residue data also confirmed that the residue definition for cattle, which applies to both 
GAP compli ance and dietary intake, can be applied to sheep.  
3.6.4  Dietary Risk Assessment  
The HBGV  of 0.01  mg/kg  bw/d  and the stated dietary intake residue definition,  was 
considered appropriate for use in the assessment.  
Based on the residue profile expected in product s derived from livestock treated with 
eprinomectin, the NEDI is  estimated to total less than 6 % of the HBGV when the compound 
is used according to existing and proposed GAP uses.  
MPI has therefore determined that the use of eprinomectin in sheep according  to the GAP 
specified above is unlikely to pose any health risks  with authorised use.   
3.6.5 Relevant International MRLs  
Country                                                      Food  Maximum Residue Level  (mg/kg)  
European Union  Ruminant fat                         
Ruminant kidney               
Ruminant liver                       
Ruminant meat                           
Milk                                  0.25 
0.3 
1.5 
0.05 
0.02 
Japan Other terrestrial mammals, fat  
Other terrestrial mammals, kidney  
Other ter restrial mammals, liver  
Other terrestrial mammals, meat  
Milk                                    0.1 
0.3 
0.3 
0.1 
0.02  
16 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  3.7 PROPOSAL TO AMEND THE MRLS FOR  FLUFENACET     
It is proposed that MRLs for flufenacet  are amended to support the GAP use of the 
compound on potatoes . 
The revised entry  for flufenacet in Schedule 1 of the Notice will read as follows. Changes are 
shown in bold:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food  Maximum Permitted 
Residue Level (mg/kg)  
Flufenacet  142459 -58-3 Sum of:  Flufenacet, flufenacet 
sulfonic acid, flufenacet 
thioglycolate sulfoxide and 
flufenacet oxalate 
 
Expressed as: Flufenacet  Barley  
Potatoes 
Wheat  0.05(*)  
0.01(*)  
0.05(*)  
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
3.7.1 Amendment Rationale  
The MRL is being proposed to support a new use for  flufenacet on potatoes  in accordance 
with the application rates and controls  that are proposed as GAP in New Zealand.  
3.7.2 Good Agricultural Prac tice 
Flufenacet  is an oxyacetamide herbicide in potato crops  at a rate of 600  gai/ha, together with 
440 gai/ha of metribuzin. The compound is used as  a pre -emergent broadcast soil treatment , 
and is applied as a spray to manage a number of weed species  in planted potato fields . Use 
of flufenacet on potato crops attracts a restriction that it is not to be used after crop 
emergence.  
3.7.3  Residue Information  
The residue data for the use of flufenacet  on potato crops  are sufficient to conclude that, 
when applied as per the proposed GAP use pattern and  complying with the use restriction, 
residues of flufenacet and its metabolites should not exceed the limit of quantification of 
0.01mg/kg  in potatoes. The proposed MRL will therefore be sufficient to ensure compliance 
with GAP.  
The residue metabolism profile for potatoes confirmed that the residue definition already set 
for barley and wheat, which applies to both GAP and dietary intake, can also apply to 
potatoes.  
3.7.4  Dietary Risk Assessment  
The HBGV  of 0.0 035 mg/kg  bw/d  and the stated dietary intake residue definition,  was 
considered appropriate for use in the assessment.  
Based on the residue profile expected in food from crops treated with flufenacet , the NEDI for 
the compound is estimated to total  less than 4% of the HB GV when the compound is used 
according to existing and proposed GAP uses.  
MPI has therefore determined that the use of flufenacet  on potatoes,  according to the GAP 
specified above, is unlikely to pose any health risks from authorised use.    
3.7.5 Relevant Inter national MRLs  
There are no MRLs set by either Australia or Codex for potatoes .   
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 17 3.8 PROPOSAL TO SET  MRLS FOR FLUMIOXAZIN  
It is proposed that MRLs are set for flumioxazin to support the GAP use of the compound on 
grapes, kiwifruit, pome fruit, and stone fruit, and to set MRLs in animal commodities to 
manage residues  resulting from vineyard grazing.  
There is currently no entry for flumioxazin in the Notice. The new entry in Schedule 1 of the 
Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum  
residue limit applies  Food  Maximum Residue 
Level (mg/kg)  
Flumioxazin  103361 -09-7 Flumioxazin  Grapes  
Kiwifruit  
Mammalian fat  
Mammalian meat   
Mammalian offal  
Milk 
Pome fruits  
Stone fruits  0.02(*) 
0.02(*)  
0.02(*)  
0.02(*)  
0.02(*)  
0.02(*)  
0.02(*)  
0.02(*)  
 (*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
3.8.1 Amendment Rationale  
The MRL s are being proposed to support the use of  the novel compound flumioxazin on fruit , 
in accordance with the application rates , restrictions, and withholding periods that are 
proposed as GAP in New Zealand.   
3.8.2 Good Agricultural Practice  
Flumioxazin  is a benzoxazine herbicide used as a contact and soil  treatment to  control a 
number of weeds in grape, kiwifruit, pome fruit,  and st one fruit crops. The compound is 
applied at a rate of 420  gai/ha as a spray , at a maximum of one application per year between 
final harvest and bud break  in all crops . Use of flumioxazin attracts a restriction that it is not 
to be applied after the start o f flowering, a two month pre- grazing interval for orchard grazing, 
and a two month clean feed period for animals that have been grazed in vineyards.   
3.8.3 Residue Information  
The residue data for the use of flumioxazin  are sufficient to conclude that, when applied as 
per the proposed GAP use pattern and complying with the applicable restrictions , residues of 
parent compound flumioxazin should not exceed 0.02 mg/kg in any fruit crops. When the pre-  
and post -grazing periods  proposed as GAP are observed in grazing  animals , flumioxazin 
residues in animal commodities should not exceed 0.02 mg/kg in any tissues or milk.     
The residue studies conducted in animals confirmed that the parent compound residues 
were the only residues that quantifiably accumulated in all ti ssues and milk. A residues 
definition limited to parent flumioxazin will therefore be sufficient to manage GAP compliance and dietary intake in both plant and animal commodities.  
3.8.4 Dietary Risk Assessment  
The HBGV  of 0.0 14 mg/kg  bw/d  and the stated dietary i ntake residue definitions,  was 
considered appropriate for use in the assessment.  
Based on the residue profile expected in food from crops treated with flumioxazin , as well as 
in animal products from livestock that are grazed in treated orchards and vineyards,  the 
NEDI for  the compound  is estimated to total  less than 2% of the HBGV . 
MPI has therefore determined that the use of flumioxazin, when use according to the GAP 
specified above, is unlikely to pose any health risks from authorised use.    
18 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  3.8.5 Relevant International MRLs  
Country                                                          Food  Maximum Residue L evel 
(mg/kg)  
Australia  Edible offal (Mammalian)  
Grapes                              
Meat [mammalian]  
Milks                                    0.01 
0.01 
0.01 
0.01 
Codex  Edible offal (mammalian)  
Grapes                              
Mammalian fats (except milk fats)                                   
Meat (from mammals other than marine mammals)                                                                             
Milks                                        
Pome fruits                                                                                                                                            
Stone fruits                                 0.02 
0.02 
0.02 
0.02 
0.02 
0.02 
0.02 
European Union                  Muscle, all mammalian species  
  Fat, all mammalian species  
        Liver, all mammalian species  
Kidney, all mammalian species  
Edible offals (other than liver and kidney), all mammalian                                                                                                                     
species                                                                                                                     
Milk                                      0.02 
            0.02 
0.02 
0.02 
 
0.02 
0.02 
3.9 PROPOSAL TO AMEND THE MRLS FOR  FLUSILAZOLE    
It is proposed that MRLs for flusilazole are amended to support the GAP use of the 
compound on grapes, and to set MRLs in animal commodities to manage residues resulting 
from vineyard grazing.  
The revised entry  for flusilazole in Schedule 1 of the Notice will read as follows. Changes are 
shown in bold:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food  Maximum Permitted 
Residue Level (mg/kg)  
Flusilazole  85509 -19-9 Plant commodities: Flusilazole  
 Animal commodities: 
flusilazole plus [bis(4 -
fluorophenyl)methyl]silanol   Apples  
Grapes 
Mammalian fat  
Mammalian  meat   
Mammalian offal  
Milk 
Onions  0.02(*) 
0.01(*)  
0.05( *) 
0.01(*)  
0.01(*)  
0.01(*)  
0.05 
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
 
3.9.1 Amendment Rationale  
The MRL s are being proposed to support a new use for flusilazole  on grapes  in accordance 
with the applicati on rates, controls, and withholding periods that are proposed as GAP in 
New Zealand.  
3.9.2 Good Agricultural Practice  
Flusilazole  is an organosilicon fungicide used to control dieback in grapes. The compound 
will be used as a spray at an application rate of 4  gai/100L of water during the dormant 
period after pruning and before sap flow. Flusilazole attracts a use restriction to the stated 
period, and a requirement that the compound is not applied once buds begin to swell. A six 
month slaughter interval and clean feed period also applies to animals grazed in treated 
vineyards .    
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 19 3.9.3  Residue Information  
The residue data for the use of  flusilazole  on grapes are sufficient to conclude that, when 
applied as per the proposed GAP use pattern, residues of parent compound flusilazole 
should not exceed the 0.01 mg/kg  limit of  quantification. The proposed MRL of 0.01 mg/kg in 
grapes  is therefore sufficient to support GAP for the use of flusilazole in vineyards . The 
residue definition applicable to the existing plant commodities , apples and onions, can also 
apply to the use of flusilazole on grapes.  
Animal  metabolism and elimination studies demonstrated that the primary residues were 
parent flusilazole and its silanol metabolite. Feeding studies evaluating flusilazole 
consumption in cattle found that tissue residue uptake was  minimal when used according to 
the New Zealand use pattern,  with no evidence of bioaccumulation of the compound or its 
metabolite . Given the use pattern on grape vines, data to support limited absorption and 
rapid elimination in exposed ruminants, and the application of a six -month slaughter interval, 
MRLs set at the limit of detection for animal tissues will be sufficient to support GAP for 
vineyard grazing.  As the silanol metabolite was a significant contrib utor to the residue profile, 
it is proposed that the residue definition includes both flusilazole and its metabolite. This 
aligns with the Codex residue definition for animal commodities .  
3.9.4 Dietary Risk Assessment  
The HBGV  of 0.0005  mg/kg  bw/d  and the stated dietary intake residue definitions,  was 
considered appropriate for use in the assessment.  
Based on the residue profile of flusilazole expected in food from crops treated according to 
existing and proposed GAP uses, and in animal commodities  after exposure  to the 
compound through vineyard grazing, the  NEDI is estimated to total  less than 6% of the 
HBGV  when the compound is  used according to existing and proposed GAP uses.  
MPI has therefore determined that the use of flusilazole  on grapes , according to the GAP 
specified above, is unlikely to pose any health risks from authorised use.   
3.9.5 Relevant International MRLs  
Country                                                          Food  Maximum Residue Level 
(mg/kg)  
Codex  Edible offal (mammalian)  
Grapes                              
Meat (from mammals other than marine mammals , in fat )                                                                             
Milks                                       2 
0.2 
1 
0.05 
European Union                Muscle, all mammali an species  
  Fat, all mammalian species  
        Liver, all mammalian species  
Kidney, all mammalian species  
Edible offals (other than liver and kidney), all mammalian                                                                                                                    
species                                                                                                                     
Milk                                      0.02 
0.02 
0.02 
0.02 
            
0.02 
0.02 
Canada Meat of cattle                       
Meat byproducts of cattle                                    0.01 
0.01 
China  Mammalian meat (except marine mammals) expressed as 
residue in fat                     
Mammalian offal                 
Milk                                  
1 
2 
0.05 
Japan     Muscle, all mammalian species  
  Fat, all mammalian species  
        Liver, all mammalian species  
Kidney, all mammalian species  
Edible offals (other than liver and kidney), all mammalian                                                                                                                    
species                                                                                                                     
Milk                                      0.1 
1 
2 
2 
 
2 
0.05  
20 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  3.10 PROPOSAL TO SET MRLS FOR ISOFLUCYPRAM  
It is proposed that MRLs are set for isoflucypram to support the GAP use of the compound 
on wheat, barley,  triticale , and ryegrass seed crops , and to set MRLs in animal commodities 
to manage residues stemming from treated cr ops being used as animal feed.  
There is currently no entry for isoflucypram in the Notice. The new entry in Schedule 1 of the 
Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food  Maximum Permitted 
Residue Level (mg/kg)  
Isoflucypram  1255734 -28-1 Isoflucypram  Barley  grain  
Eggs  
Mammalian fat  
Mammalian  offal  
Mammalian meat  
Milk 
Poultry meat  
Poultry offal  
Wheat grain  
Triticale grain  0.15 
0.01(*)  
0.04 
0.01(*)  
0.01(*)  
0.005(*)  
0.01(*)  
0.02 
0.02 
0.02 
 (*) indicates t hat the maximum residue limit has been set at or about the limit of analytical quantification.  
3.10.1  Amendment Rationale  
The MRLs are being proposed to support the use of  the novel compound isoflucypram  on 
grain crops  in accordance with the application rates and withholding periods that are 
proposed as GAP in New Zealand.   
3.10.2  Good Agricultural Practice  
Isoflucypram  is a pyrazole- carboxamide fungicide used on wheat, barley, triticale and 
ryegrass seed crops to control rusts, leaf blotches, and leaf spots. T he compound is applied 
at a rate of 75  gai/ha as a single foliar  spray  application at the first appearance of disease, 
and can be applied up to early flowering (BBCH61) in barley and ryegrass seed crops and up 
to the end of flowering (BBCH69) in wheat and triticale.  Use of isoflucypram  attracts 
withholding periods of 56 days for barley grain, 42 days for triticale and wheat grain, 42 days 
for barley forage, 28 days for triticale and wheat forage, and 49 days for ryegrass seed crops 
as animal feed.   
3.10.3  Residue Informati on 
The residue data for the use of  isoflucypram  are sufficient to conclude that, when applied as 
per the proposed GAP use pattern and complying with the applicable withholding period , 
residues of parent isoflucypram  should not exceed 0. 13 mg/kg in barley g rain and 0.02 
mg/kg in wheat or triticale grain.  Parent isoflucypram was the only residue detected in plant -
derived food commodities, and is therefore sufficient to function as both the residue definition for GAP compliance and dietary intake assessments f or these commodities.  
For animals fed grain or other animal feeds derived from treated crops, residues of parent 
isoflucypram should not exceed 0.04 mg/kg in fat, 0.01 mg/kg in  mammalian meat and offal , 
0.005 mg/kg in milk, 0.02 mg/kg in poultry offal, an d 0.01 mg/kg poultry meat and eggs  when 
the applicable withholding periods are observed.  
The metabolism of isoflucypram in animals was well characterised in the data. T hough the 
parent compound was a dominant residue in tissues, there were also quantifiabl e 
concentrations of nine metabolites in various animal tissues, most significantly in animal 
livers . While a parent -only residue definition will be sufficient to manage GAP compliance 
due to parent isoflucypram  being the most common residue in all animal t issues, the dietary 
intake definition will also need to include isoflucypram metabolites to ensure the dietary 
exposure residues are sufficiently evaluated.  Animal commodities will therefore be subject to  
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 21 a dietary intake residue definition evaluating the sum of isoflucypram and its free and 
conjugated –propanol, -2-propanol, -desmethyl -propanol metabolites, and its – desmethyl -
propandiol, –carboxylic and - desmethyl -carboxylic acid metabolites, expressed as 
isoflucypram.   
3.10.4  Dietary Risk Assessment  
The HBGV  of 0.028  mg/kg  bw/d , and the stated dietary intake residue definitions, were 
considered appropriate for use in the assessment.  
Based on the residue profile expected in food from crops treated with isoflucypram , as well 
as in animal products from livestock that are grazed on or fed treated crops or crop products,  
the NEDI is estimated to total less than 0.9% of the HBGV . 
MPI has therefore determined that the use of  isoflucypram , when use according to the GAP 
specified above, is unlikely to pose any health risk s from authorised use.   
3.10.5  Relevant International MRLs  
There are no MRLs set for isoflucypram by any international authority.  
3.11  PROPOSAL TO AMEND THE MRLS FOR M ANDESTROBIN  
It is proposed that the MRLs for mandestrobin are amended to support the GAP use of the  
compound on lettuces .  
The revised entry  for mandestrobin in Schedule 1 of the Notice will read as follows. Changes 
are shown in bold:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food  Maximum Permitted 
Residue Level (mg/kg ) 
Mandestrobin  173662 -97-0 Mandestrobin  Beans (with pods)  
Bulb onions  
Head lettuce 
Leafy lettuce  0.7 
0.01(*)  
1.5 
10 
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
 
3.11.1  Amendment Rationale  
The MRL s are being proposed to support a new use for mandestrobin on lettuces  in 
accordance with the applicati on rates and withholding periods that are proposed as GAP in 
New Zealand.  
3.11.2  Good Agricultural Practice  
Mandestrobin is a strobilurin fungicide used to control white rot and downy mildew on bulb 
onions and Sclerotina sclerotiorum on beans. The new use for which MRLs are required is 
the control of Sclerotinia  on head and leaf y lettuce. The compound will be used as a spray at 
an application rate of 300 gai/ha prior to disease development  after transplanting and  at 7-14 
day intervals, with no more than two consecutive applications per season. The use of 
mandestrobin on  lettuces attracts a seven day  withholding  period.   
3.11.3  Residue Information  
The residue data for the use of  mandestrobin on lettuces are sufficient to conclude that, 
when applied as per the proposed GAP use pattern and the withholding period is observed, 
residues of parent compound mandestrobin should not exceed 1.1 mg/kg in head lettuce and  
22 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  8 mg/kg in leaf y lettuce. The proposed MRLs of 1.5 mg/kg in head lettuce and 10 mg/kg in 
leafy lettuce are therefore sufficient to support GAP for the use of mandestrobin in lettuces .  
The residue definition of parent mandestrobin for GAP compliance and mandestrobin plus its 
4-OH-, 2-CH2OH - and De- Xy- metabolites  for dietary intake were previously assessed as 
sufficient to manage residues in vegetables. Based on metabolism data in the new crops, these definitions are also considered appropriate to manage residues in l ettuces. The current 
residue definition can therefore remain unchanged.  
3.11.4  Dietary Risk Assessment  
The HBGV  of 0.133 mg/kg  bw/d  and the stated dietary intake residue definition,  was 
considered appropriate for use in the assessment.  
Based on the residue prof ile of mandestrobin  expected in food from crops treated according 
to existing and proposed GAP uses, the  NEDI is estimated to total  less than 0.9% of the 
HBGV  when the compound is  used according to existing and proposed GAP uses.  
MPI has therefore determined that the use of mandestrobin on lettuces , according to the 
GAP specified above, is unlikely to pose any health risks from authorised use.   
3.11.5  Relevant International MRLs  
There are no MRLs set for mandestrobin in head lettuce or leafy lettuce by Australia or 
Codex.   
3.12 PROPOSAL TO  AMEND THE MRLS FOR  METRAFENONE  
It is proposed that the MRLs for metrafenone are amended to support a  revised  GAP use of 
the compound on grapes. Because this compound has the potential for animal exposure, it is 
also proposed that the entry in the Notice is amended to include MRLs for animal 
commodities to manage residues from vineyard grazing.  
The revised entry  for metrafenone  in Schedule 1 of the Notice will read as follows. Changes 
are shown in bold:  
Compound 
Common Name  CAS#  Residue to which the maximum 
residue limit applies  Food  Maximum Permitted 
Residue Level (mg/kg)  
Metrafenone  220899 -03-6 Metrafenone  Grapes  
Mammalian fat  
Mammalian  meat   
Mammalian offal  
Milk 
Pumpkin 
Winter Squash  0.15 
0.01(*)  
0.01(*)  
0.01(*)  
0.01(*)  
0.01(*)  
0.05(*) 
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
 
3.12.1  Amendment Rationale  
The MRL s are being proposed to support a revised use for metrafenone on grapes , in 
accordance with the application rates and withholding periods that are proposed as GAP in 
New Zealand.  
3.12.2  Good Agricultural Practice  
Metrafenone  is a benzophenone fungicide used to control powdery mildew in grapes. The 
compound was previously used at a rate of 10gai/100L of water sprayed at 14- 21 day  
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 23 intervals up to 80% cap -fall, with a maximum of two applications per season. The revised 
GAP for metrafenone uses the same application rate and maximum  applications per season, 
but reduces the retreatment interval to 10 -21 days and the withholding pe riod to 42 days pre -
harvest. A 14 day pre- grazing interval and a two month slaughter interval and clean feed 
period will apply to  animals grazed in treated vineyards.   
3.12.3   Residue Information  
The residue data for the use of  metrafenone  on grapes are sufficient to conclude that, when 
applied as per the proposed GAP use pattern, residues of parent compound metrafenone 
should not exceed 0.1 mg/kg. The proposed MRL of 0.15 mg/kg in grapes is therefore 
sufficient to support GAP for the use of metrafenone in vineyards.  
The information provided to support the revised use pattern was sufficient to confirm the risk 
of metrafenone residues in animal commodities will be similar to that previously assessed 
even with the change to the pre -grazing and slaughter intervals . Although the animal residue 
profile is essentially unchanged, animal commodity MRLs are being proposed to support 
GAP related to vineyard grazing and to provide clarity  and transparency  regarding animal 
exposure and MRL compliance. The animal metabolism and feeding study data is sufficient 
to conclude residues in all commodities from animals grazed in metrafenone- treated 
vineyards will remain below the limit of quantification, which is 0.01 mg/kg in all tissues and 
milk.  
The residue definition, parent metr afenone, is sufficient to support GAP compliance and 
dietary intake for both plant and animal commodities in New Zealand.  
3.12.4  Dietary Risk Assessment  
The HBGV  of 0.18 mg/kg  bw/d  and the stated dietary intake residue definition,  was 
considered appropriate for use in the assessment.  
Based on the residue profile of metrafenone expected in food from crops treated according to 
existing and proposed GAP uses, and in animal commodities exposed to the compound 
through vineyard grazing, the NEDI is estimated to total  less than 0.04% of the HBGV  when 
the compound is  used according to existing and proposed GAP uses.  
MPI has therefore determined that the use of metrafenone on grapes , according to the GAP 
specified above, is unlikely to pose any health risks from authorised use.    
24 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  3.12.5  Relevant International MRLs  
Country                                                          Food  Maximum Residue Level 
(mg/kg)  
Australia  Edible offal (Mammalian)                            
Grapes                                  
Meat [mammalian] [in the fat]                       
Milks                                  0.05 
1 
0.05 
0.01 
Codex  Edible offal (mammalian)  
Grapes                              
Meat (from mammals other than marine mammals, in fat)                                                                             
Milks                                       0.01 
5 
0.01 
0.01 
European Union                Muscle, all mammalian species  
  Fat, all mammalian species  
        Liver, all mammalian species  
Kidney, all mammalian species  
Edible  offals (other than liver and kidney), all mammalian                                                                                                                    
species                                                                                                                     
Milk                                      0.01 
0.01 
0.01 
0.01 
            
0.01 
0.01 
Japan               Muscle, all mammalian species  
  Fat, all mammalian species  
        Liver, all mammalian species  
Kidney, all mammali an species  
Edible offal  (other than liver and kidney), all mammalian                                                                                                                    
species                                                                                                                     
Milk                                      0.01 
0.01 0.01 
0.01 
            
0.01 
0.01 
3.13 PROPOSAL T O SET MRLS FOR METRIBUZIN 
It is proposed that MRLs are promulgated for metribuzin to support the GAP use of t he 
compound on potatoes.  
There is currently no entry for metribuzin in the Notice. The new entry in Schedule 1 of the 
Notice will read as follows:  
Compound 
Common Name  CAS#  Residue to which the maximum residue limit applies  Food  Maximum Permitted 
Residue L evel (mg/kg)  
Metribuzin  21087 -64-9 Metribuzin  Potatoes  
 0.01(*)  
(*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
3.13.1  Amendment Rationale  
The MRL is being proposed to support a new use for  metribuzi n in potatoes in accordance 
with the application rates and controls  that are proposed as GAP in New Zealand.  
3.13.2  Good Agricultural Practice  
Metribuzin  is a triazinone herbicide currently used on a variety of vegetable crops. The new 
use is as a pre- emergent broadcast soil treatment for potato crops at a rate of 440 gai/ha, 
together with 600 g ai/ha of flufenacet . Use of metribuzin on potato crops attracts a restriction 
that it is not to be used after crop emergence.  
3.13.3  Residue Information  
The residue data for the use of metribuzin are sufficient to conclude that, when applied as 
per the proposed GAP use pattern and complying with the use restriction, residues of  
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 25 metri buzin should not exceed the limit of quantification of 0.01 mg/kg  in potatoes. The 
proposed MRL wil l therefore be sufficient to ensure compliance with GAP.  
The data confirmed that the primary residue in potatoes is parent metribuzin. The residue 
definition can therefore be set at metribuzin for both GAP compliance and dietary intake.  
3.13.4   Dietary Risk Assessment  
The HBGV  of 0.0 09 mg/kg  bw/d  and the stated dietary intake residue definition,  was 
considered appropriate for use in the assessment.  
Based on the residue profile expected in food from crops treated with me tribuzin , the NEDI 
for the compound is est imated at less than 3 % of the HBGV when the compound is used 
according to existing and proposed GAP uses.  
MPI has therefore determined that the use of metribuzin  on potatoes,  according to the GAP 
specified above, is unlikely to pose any health risks from authorised use.  
3.13.5  Relevant International MRLs  
Country                                                      Food  Maximum Residue  
Level  (mg/kg)  
Australia  Potato                                                   0.05 
3.14 PROPOSAL TO SET MRLS FOR  PYROXASULFONE  
It is proposed that MRLs are set for pyroxasulfone to  support the GAP use of the compound 
on wheat  and triticale, and to set MRLs in animal commodities to manage residues resulting 
from treated crops being used as animal feed.  
There is currently no entry for pyroxasulfone  in the Notice. The new entry in Schedule 1 of 
the Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum 
residue limit applies  Food  Maximum Permitted 
Residue Level (mg/kg)  
Pyroxasulfone  447399 -55-5 Plant Commodities: 
Pyrox asulfone and its M -1 
metabolite ((5- difluoromethoxy -
1-methyl -3-trifluoromethyl -1H-
pyrazol -4-yl)methanesulfonic 
acid), expressed as 
pyroxasulfone.  
 
Animal Commodities:  
Pyroxasulfone and its  M-3 (5-
Difluoromethoxy -1-methyl -3-
trifluoromethyl -1H-pyrazole- 4-
carboxylic acid) metaboli te, 
expressed as pyroxasulfone  Eggs  
Mammalian fat  
Mammalian meat  
Mammalian  offal  
Milk   Poultry meat  
Poultry offal  
Wheat grain  
Triticale grain  0.02(*)  
0.02(*)  
0.02(*)  
0.02(*)  
0.002(*)  
0.02(*)  
0.02(*)  
0.01(*)  
0.01(*)  
 
 (*) indicates that the maximum residue limit has been set at or about the limit of analytical quantification.  
3.14.1  Amendment Rationale  
The MRLs are being proposed to support the use of  the novel compound pyroxasulfone on 
grain crops i n accordance with the application rates , controls,  and withholding periods that 
are proposed as GAP in New Zealand.    
26 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  3.14.2  Good Agricultural Practice  
Pyroxasulfone is an isoxazoline pre- emergent herbicide used on wheat  and triticale to control 
grass weeds . The compound is applied at a rate of 106 -128 g ai/ha as a single broadcast 
spray application before crop emergence and not after the end of July.  Use of pyroxasulfone 
attracts a 42 day livestock withholding period for forage and green feed.   
3.14.3  Residue Information  
The residue data for the use of  pyroxasul fone are sufficient to conclude that, when applied as 
per the proposed GAP use pattern and complying with the applicable controls and 
withholding periods , residues of parent compound and its metabolites  should not exceed 
0.13 mg/kg in barley grain and 0.01  mg/kg in wheat or triticale grain. The residue trial work 
demonstrated that the predominant residues were low levels of the parent compound the M1 
((5-difluoromethoxy -1-methyl -3-trifluoromethyl -1H-pyrazol -4-yl)methanesulfonic acid)  
metabolite in grain crops. It is therefore considered that the parent compound and its M1 
metabolite are appropriate markers for GAP compliance in plant commodities. Because the 
M3 (5-Difluoromethoxy -1-methyl -3-trifluoromethyl -1H-pyrazole- 4-carboxylic acid) metabolite 
could also be present in low levels in food, parent pyroxasulfone residues and the residues of 
both the M1 and M3 metabolites are included in the residue definition for dietary intake 
purposes.  
For animals fed grain or other animal feeds derived from treated crops, residues of parent pyroxasulfone should not exceed the limits of quantification specified in the proposed MRLs: 
0.02 mg/kg for all animal tissues , 0.02 mg/kg in eggs, and 0.002 mg/kg in milk. The animal 
metabolism studies demonstrated that f or animal commo dities, the  parent compound and the 
M3 metabolite w ere the most  consistently detected (at very low levels), and are  therefore the 
most appropriate compounds  to target for GAP compliance. As with  the plant commodities, 
both the M1 and M3 metabolites can occ ur in animal commodities and are therefore both are 
included in the dietary intake residue definition.  
3.14.4  Dietary Risk Assessment  
The HBGV  of 0.0 014 mg/kg  bw/d , and the stated dietary intake residue definitions, were 
considered appropriate for use in the ass essment.  
Based on the residue profile expected in food from crops treated with pyroxasulfone,  as well 
as in animal products from livestock that are grazed on or fed treated crops or crop products,  
the NEDI is estimated to total less than 8% of the HBGV . 
MPI has therefore determined that the use of  pyroxasulfone, when use according to the GAP 
specified above, is unlikely to pose any health risks from authorised use.    
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 27 3.14.5  Relevant International MRLs  
Country                                                          Food  Maximum Residue L evel 
(mg/kg)  
Australia  Cereal Grains                           
Edible offal (Mammalian)  
Eggs                                  
Meat [mammalian]  
Milks                                 
Poultry, Edible offal of                
Poultry mea t                 0.01 
0.02 
0.02 
0.002 
0.02 
0.02 
0.01 
Canada                                              Meat and fat of horses   
Meat of sheep, goats, poultry, hogs, and cattle  
                                     Fat of poultry  
             Fat of sheep, goats, hogs, and cattle 
                             Meat byproducts of sheep, goats, poultry, 
hogs, cattle, and horses  
Milk                              
Eggs                                    0.1 
0.01 
0.1 
0.01 
 
0.01 0.001 
0.01 
United States  Milk                                       0.003 
3.15 PROPOSAL T O SET MRLS FOR  TETRANILIPROLE  
It is proposed that MRLs are set for tetraniliprole to support the GAP use of the compound on 
pome fruits . 
There is currently no entry for tetraniliprole in the Notice. The new entry in Schedule 1 of the 
Notice will read:  
Compound 
Common Name  CAS#  Residue to which the maximum 
residue limit applies  Food  Maximum Permitted 
Residue Level (mg/kg)  
Tetraniliprole  1229654 -66-3 Tetraniliprole  Pome fruits  0.2 
3.15.1  Amendment Rationale  
The M RLs are being proposed to support the use of  the novel compound tetraniliprole on 
pome fruits  in accor dance with the application rate and withholding period  that are proposed 
as GAP in New Zealand.   
3.15.2  Good Agricultural Practice  
Tetraniliprole  is a diamide insecticide  used on apples, pears, and nashi to control codling 
moth, leafroller caterpillars, and bronze beetles.  The compound is applied at a rate of 3 
gai/ha as a  foliar  spray application up to three times:  once after petal fall, a repeat treatment 
applied at least 21 days later if required,  and the option of a further application up to 14 days 
before harvest for late season control. Use of tetraniliprole attracts a 14 day withholding 
period.   
3.15.3  Residue Information  
The residue data for the use of  tetranilipr ole are sufficient to conclude that, when applied as 
per the proposed GAP use pattern and complying with the applicable withholding period , 
residues of tetraniliprole should not exceed 0. 13 mg/kg in any fruit from treated crops. As 
such, the proposed MRL o f 0.2 mg/kg  will be sufficient to manage the GAP use of the 
compound.   
28 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  The predominant residue in treated crops was parent tetraniliprole, with the tetraniliprole- N-
methyl -quinazolinone metabolite being detectable in some plant commodities and processed 
food commodities at low levels. The residue definition for GAP compliance is therefore 
proposed to be set at parent tetraniliprole only, with the dietary intake definition to be set at 
the sum of tetraniliprole and its – quinazolinone metabolite expressed as tetraniliprole.   
3.15.4  Dietary Risk Assessment  
The HBGV  of 0.62 mg/kg  bw/d , and the stated dietary intake residue definition, were 
considered appropriate for use in the assessment.  
Based on the residue profile expected in food from crops treated with tetranili prole,  the NEDI 
is estimated to total less than 0.02% of the HBGV . 
MPI has therefore determined that the use of  tetraniliprole, when use according to the GAP 
specified above, is unlikely to pose any health risks from authorised use.   
3.15.5  Relevant International  MRLs  
There are no MRLs set for tetraniliprole by either Australia or Codex.   
3.16 PROPOSAL TO EX EMPT CHROMOBACTERIUM SUBT SUGAE PRAA4 -1T AND 
ITS METABOLITE S (INCLUDING  VIOLACEIN ) 
It is proposed that  Chromobacterium subtsugae PRAA4 -1T and its metabolites, including 
violacein , are included in Schedule 2 of the Notice. This will establish that the organism and 
its metabolites will be considered an agricultural chemical compound for which no MRLs 
apply .  
Chromobacterium subtsugae PRAA4 -1T is a soil isolate that is  used as a biological 
insecticide  on grape vines . The use of this organism and its metabolites falls outside the 
scope of the existing exemption for microbial active ingredients in Schedule 2 of the N otice 
because the residues of the metabolite violacein may  exceed what would be expected of 
background levels. This means that the use of the organism and its metabolit es, including 
violacein , requires its own exemption.  
Because the organism loses viability during processing for agricultural chemical use, the fi nal 
compound does not contain any living cells.  The killed  Chromobacterium subtsugae PRAA4 -
1T organisms themselves do not pose any  food safety risk s since at application they are 
non-viable, and when alive do not form spores and d o not produce any toxic me tabolites. 
The only quantifiable metabolite produced by the organism , violacein, has a very short half -
life and is therefore unlikely to accumulate or be detectable in food. Furthermore, in the unlikely occurrence of detectable residues, the available data confirmed that violacein is 
unlikely to result in toxicity with any exposure level.  
Based on the available data on the organism and its metabolites, it is therefore concluded that an exemption is appropriate.  
There is currently no entry in Schedule 2 fo r Chromobacterium subtsugae PRAA4 -1T or its 
metabolites.   
Ministry for Primary Industries  Proposals to Amend the Maximum Residue Levels for Agr icultural Compounds Food Notice Dec 2018  • 29 The proposed entry in Schedule 2 will read:  
Substance CAS#                                      Condition  
Chromobacterium subtsugae 
PRAA4 -1T and its metabolites, 
including violacein.  
Excludes meta bolites that have 
been isolated as independent 
compounds.  64-18-6 When used as an agricultural chemical.  
3.17 PROPOSAL TO  AMEND THE  EXEMPTION FOR  
BROMOCHLORODIMETHYLH YDANTOIN  
It is proposed that the exemption from compliance with an MRL for 
Bromochlorodimethyl hydantoin (BCDMH)  in Schedule 2 of the Notice  is amended by 
includ ing all four CAS numbers associated with the compound in the entry.  BCDMH was 
originally exempted based on how the compound is used in New Zealand and the low toxicity 
profile associated wit h that use. The use pattern and condition of exemption remains 
unchanged from that previously promulgated.  
BCDMH  is an isomeric mixture of four individual compounds in equilibrium, rather than a 
single compound attributed to one CAS number as it is current ly entered into the schedule. 
The isomeric mixture includes the following constituents:  
• 1-bromo -3-choloro- 5,5-dimethyl -imidazolidine -2,4-dione (CAS number 16079- 88-2); 
• 3-bromo -1-choloro- 5,5-dimethyl -imidazolidine -2,4-dione (CAS number 126 -06-7); 
• 1,3-dichol oro-5,5-dimethyl -imidazolidine -2,4-dione (CAS number 118- 52-5); 
• 1,3-dibromo- 5,5-dimethyl -imidazolidine -2,4-dione (CAS number 77 -48-5); and 
• CAS number 32718- 18-6, a mixture of CAS number s 16079 -88-2 and 126 -06-7 
above.  
The revised entry in Schedule 3 will r ead as follows . Changes are in bold:  
Substance CAS#  Condition  
Bromochlorodimethylhydantoin  77-48-5; 118 -52-5; 
126-06-7; 16079 -88-2; 
and 32718 -18-6 When applied  as a biocide to fruits and 
vegetables .  
 
This amendment will better  reflect the actual mixture of isomers that make up BCDMH when 
it is used as an agricultural chemical.  
3.18 PROPOSAL TO  EXEMPT CROSS- LINKED POLYACRYLAMIDE  
It is proposed that cross- linked polyacrylamide is added to Schedule 3 of the Notice. Poly 
acrylamide is used in the form of an in tra-articular injectable hydrogel as a treatment for 
arthritis in horse . When used in this manner , the compound is locally administered, locally 
acting, and is not systemically absorbed. This results in no quantifiable systemic residues 
from animals treated with polyacrylamide, and therefore no need to manage residues with the application of a MRL.    
30 • Proposals to Amend the Maximum Residue Levels for Agricultural Compounds Food Notice Dec 2018  Ministry for Primary Industries  The entry  will be specific to cross -linked polyacrylamide and the intra -articular use pattern, 
and will not apply to any other acrylamide compounds or agricult ural compound uses.   
 
The proposed  entry in Schedule 3 will read as follows:  
Substance CAS#  Condition  
Cross -linked polyacrylamide  9003 -05-8 When used as an intra -articular injectable veterinary 
medicine  in horses .  
3.19 PROPOSAL TO EXEMPT VAC CINE  AND DIAGNOS TIC ANTIGENS  
It is proposed that  vaccine and diagnostic antigens are made exempt  from compliance with 
an MRL in S chedule 3 of the Notice. Antigens are cells, subunits, or proteins administered to 
elicit an immune response in the treated animal. These antig ens do not result in residues in 
treated animals and therefore do not pose residue risks for animal -derived commodities. This 
exemption is being proposed to ensure clarity regarding v eterinary vaccines, and the 
management of residues in veterinary medicines that contain both biological and chemical 
active ingredients.  
The proposed  entry in Schedule 3 will read as follows:  
Substance CAS#  Condition  
Vaccine  and Diagnostic  Antigens  
This exemption applies when the 
antigen is derived from a viable 
or non- viabl e microorganism.  n/a  When derived from whole attenuated or killed 
microorganisms, inactivated microorganisms or 
fractions of microorganisms, or other biological -
derived proteins, and used as a veterinary medicine.