Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 1 of 21 UNITED STA

TES ENVIRONMENTA L PROTECTION A GENCY WA SHINGTON, D.C. 20460 OFFICE OF CHEMICAL SAFETY AND

POLLUTION PREVENTION MEMORANDUM Date: April 13 , 2011 Subject: Triflusulfuron - methyl. Petition for the Establishment of Permanent Tolerances and Registration for Use on Garden Beets (PP 9E7669). Summary of Analy tical Chemistry

and Residue Data. PC Code: 129002 DP Barcode: D 388620 Decision No.: 425459 Re gistration No.: 352 - 569 Petition No.: 9E7669 Regulatory Action: Section 3 Assessment Type: Single Chemical Registration Case No.: NA TXR No.: None CAS No.: 126535 - 15 - 7 MRID No.: 47943201 40 CFR § 180.492 FROM: Elizabeth Holman, Chemist Risk Assessment Branch I I Health Effects Division (7509P) THROUGH: William T. Drew, Chemist

Risk Assessment Branch I I (RAB2) Health Effects Division (HED) (7509P) and Richard A. L oranger, Ph.D., Seni or Scientist Risk Assessment Branch I I Health Effects Division (7509P) TO: Laura Nollen/Barbara Madden Minor Use Team Registration Division (7505P) The residue chemistry

summary document completed 2/1 7/11 (D376350; E. Holman) has been revised to address an issue related to plant - back intervals for rotational crops .Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 2 of 21 Table of Contents Executive Summary ................................ ................................ ................................ ...................... 3 Residue Chemistry Deficiencies ................................ ................................ ................................ ... 4 Background ................................ ................................ ................................ ................................ ... 5 860.1200 Directions for Use ................................ ................................ ................................ ......... 6 860.1300 Nature of the Residue - Plants ................................ ................................ ..................... 8 860.1300 Nature of the Residue - Livestock ................................ ................................ ................ 8 860. 1340 Residue Analytical Methods ................................ ................................ ......................... 9 860.1360 Multiresidue Methods ................................ ................................ ................................ . 11 860.1380 Storage Stability ................................ ................................ ................................ .......... 11 860.1400 Water, Fish, and Irrigated Crops ................................ ................................ .............. 11 860.1460 Food Handling ................................ ................................ ................................ ............. 11 860.1480 Meat, Milk, Po ultry, and Eggs ................................ ................................ ................... 12 860.1500 Crop Field Trials ................................ ................................ ................................ ......... 12 860.1520 Processed Food and Feed ................................ ................................ ........................... 16 860.1650 Sub mittal of Analytical Reference Standards ................................ .......................... 18 860.1850 Confined Accumulation in Rotational Crops ................................ ........................... 17 860.1900 Field Accumulation in Rotational Crops ................................ ................................ .. 18 860.1550 Proposed Tolerances ................................ ................................ ................................ ... 18Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 3 of 21 Executive Summary Triflusulfuron - methyl is a sulfonylurea herbicide that inhibits the biosy nthesis of branched - chain amino acids in plan ts (via inhibition of the plant enzy me acetolactate sy

nthase). Marketed as UpBeet , a dry flowable (DF) formulation containing 50% active ingredient ( ai ) , triflusulfuron methyl is currently

approved for use on sugar beet commodities and chicory using broad cast (ground - or aerial - based) or band application methods at seasonal rates of up to 0.078 pounds ai per acre (lb ai/A) . UpBeet is not to be applied via any ty pe of irrigation sy stem. The existing label for UpBeet lists a pre - harvest interval (PHI ) of 60 day s for both sugar beet and chicory . The registrant, E. I . du Pont de Nemours and Company , has submitted a supplemental label for a proposed use on garden beets. The maximum proposed single application rate on this supplemental label is 0.0156 lb ai/A for agricultural use on garden beets for control of broadleaf weeds, with a maximum seasonal application rate of 0.047 lb ai/A . Consistent with the existing uses, the requested new use on garden beet involves aerial or groundboom application methods. The proposed PHIon garden beet is 30 day s, a value that is well supported by the garden beet field trial data submitted for this new use petition. The residue chemistry

database is relatively

complete and there are no residue chemistry issues that would pr eclude granting the requested new use and establishing permanent tolerances on garden beet roots and tops. The petitioner has previously submitted data depicting the nature of the residue in sugar beet and lactating goat. For the purposes of this petiti on on garden beet, the previously

reviewed sugar beet metabolism study is sufficient to support the requested use of triflusulfuron - methyl on garden beets. The proposed tolerance expression in/on garden beets should include only

the parent c ompound, trifl usulfuron - methyl. The registrant is pe titioning for tolerances of 0.01 ppm on garden beet roots and 0.0 2 ppm on garden beet tops. The existing tolerances on sugar beet and chicory commodities are 0.05 ppm. HED previously

reviewed the goat metabolism s tudy and cited deficiencies to be addressed should additional Section 3 registrations be pursued by the petitioner. However, based on residue levels observed in the goat metabolism study , finite residues are not expected in ruminant meat, meat by product, f at, or milk and tolerances are not required for these commodities. Therefore, the deficiencies cited by HED do not need to be addressed for the purposes of this new food use on garden beet. However, if future uses on large - acreage crops such as wheat, co rn, or soy bean are proposed, and consequently involve feedstuffs, then an adequate ruminant metabolism study should be provided. Adequate crop field trials and processing studies have been conducted to support tolerances in the plant commodities of sugar beet, chicory , and garden beet. Even at exaggerated rates (8X) for the field trial used to generate the processing study samples , no triflusulfuron - methyl was found in the sugar beet roots or processed commodities. DuPont Method 4480 was used to quantitate triflusulfuron - methyl residues in samples from the garden beet field trials currently under review via solvent extraction and High Performance L iquid Chromatography - Mass Spectrometry

/Mass Spectrometry

(HPL C - MS/MS) . With the exception of sugar beet tops at oneTriflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 4 of 21 location that contained residues at the L OQ of 0.01 ppm, these eight field trials yielded residues that were less than the limit of quantitation. A registered non - ionic surfactant (NI S) or crop oil concentrate (COC) was added to the spray mixture for each application at a rate of 0.25% by volume ( v/v ) at all garden beet field trials with the exception of a single trial conducted in Oregon. No impact on residue levels was observed in this non - adjuvant garden beet field trial. Therefore, adjuvant r estrictions on the supplemental label are not needed. There are no processed commodities or livestock feed items associated with garden beet. The review of these garden beet field trials was originally conducted by Canada’s Pest Management Regulatory Age ncy (PMRA) under a work share arrangement , but their conclusions have been reviewed by HED and are consistent with OCSPP policy . An analy tical standard for tr if

lu sulfuron - methyl is currently available in the National Pesticide Standards Repository

(NPSR). Residue Chemistry Deficiencies The residue chemistry

data set is complete with the exception of : 1. The following label amendments are needed: a) The requested 30 - day PHIfor garden beet needs to be added to the supplemental label. b) The use of the aerial application method needs to be clarified in the supplemental label. The submitted supplemental label for garden beet does not include the petition - requested 30 - day PHI , nor does it delineate the use of the aerial application method. Aerial ap plication method instructions are included in the existing label for sugar bee ts . 2 . Analy tical Method

– An adapted version of Du P ont Method 4480 (MRI D 48207101 ) was used in the submitted garden beet field trials under review in this petition. The enfo rcement method on record for triflusulfuron - methyl is method AMR 1930 - 91 (MRI D 42496873), an HPL C - U V method. Method AMR 2021 - 91 ( MRI D 42496872) is very similar to AMR 1930 - 91, with the addition of an automatic switching column protocol, and was used in th e previously submitted sugar beet and chicory

field trials. Method 4480 is also similar to both these methods, with the primary difference being the addition of a tandem mass spectrometric detection protocol in Method 4480. In addition, t

he independent l aboratory validation (I LV) of Method 4480 successfully demonstrated the reliability of the method on the first attempt . The registrant should clarify whether they

want to replace the existing enforcement method with Method 4480 when apply ing for future ne w uses, as this newer method does appear to be an acceptable enforcement method. Should the registrant decide to request Method 4480 be used for enforcement purposes, they will need to ensure that the standards are made available to the USEPA’s Analy tic al Chemistry

Branch (ACB) in the event that they differ from those used in method AMR 1930 - 91. Regulatory Recommendations There are no major deficiencies which would preclude the establishment of permanent tolerances for the use of triflusulfuron - methyl (as the DF formulation, UpBeet) on garden beet s . ProvidedTriflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 5 of 21 that the forthcoming human health risk assessment ( D373433 ; E. Holman ; January 2011 ) does not identify any issues of concern, the submitted data support tolerances for residues of triflusulfuron - m ethyl, including its metabolites and degradates, in or on garden beet roots and tops, at the levels listed below. Compliance with the tolerance levels specified below is to be determined by

measuring triflusulfuron - methyl only . Beet, garden, roots ................................ ............................... 0.01 ppm Beet, garden, tops ................................ ................................ . 0.02 ppm Note to RD: According to HED’s Interim Guidance on Tolerance Expressions (S. Knizner, 27 May 2009), the tolerance expression for triflusulfuron - methyl cited in 40CFR §180.492[a] should be revised to state: Tolerances a re established for residues of triflusulfuron - methyl, including its metabolites and degradates, in or on the commodities listed in the table below. Compliance with the tolerance levels specified below is to be determined by measuring only triflusulfuron - m ethyl (methyl 2 - [[[[[4 - (dimethylamino) - 6 - (2,2,2 - trifluoroethoxy) - 1,3,5 - triazin - 2 - yl]amino]carbonyl]amino]sulfonyl] - 3 - methylbenzoate) in or on the commodity . Background Triflusulfuron - methyl is a post - emergence selective herbicide which acts by inhibiti ng biosy nthesis of the essential amino acids valine , leucine and isoleucine, hence stopping cell division and plant growth. HED previously assessed and recommended in favor of the food uses of this herbicide on sugar beets and chicory (M. Doherty , et al ., D260076, 12 February 2002). Nomenclature and the phy sicochemical properties of triflusulfuron - methyl are summarized in Tables 1 and 2, below. TABLE 1. Test Com pound Nom enclature. Compound Chemical Structure 

### S O 2 

### N H C O N H N

N N N ( C H 3 

### ) 2 

### O C H 2 

### C F 3 

### C H 3 

### C O 2 

### C H 3

Common name Triflusulfuron - methyl Company experimental name DPX 66037 IUPAC name methyl 2 - [4 - dimethylamino - 6 - (2,2,2 - trifluoroethoxy) - 1,3,5 - triazin - 2 - ylcarbamoylsulfamoyl] - m - toluic acid CAS name methyl 2 - [[[[[4 - (dimethylamino) - 6 - (2,2,2 - trifluoroethoxy) - 1,3,5 - triazin - 2 - yl]amino] carbonyl]amino]su lfonyl] - 3 - methylbenzoate CAS # 126535 - 15 - 7Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 6 of 21 End - use product/(EP) UpBeet Herbicide* *Th e EP used in the submitted garden beet field trials under review was Safari 50DF, an EP that is equivalent to that of UpBe et.

TABLE 2. Physicochem ical Properties o f the Triflusulfuron - Methyl. Parameter Value Reference Melting point/range 155 - 158 o C PMRA REG99 - 03 pH Not indicated Density (g/mL) 1.45 absolute 0.56 (Bulk) Water solubility ( 25°C) pH ppm 3 1.0 5 2.7 7 110 9 11 000 PMRA REG99 - 03 Low solubility at pH3 and pH 5; soluble at pH 7; very soluble at pH 9. Solubility increase s with increas ing pH. Solvent solubility (mg/L) solvent mg/L hexane <0.0016 octanol 0.026 toluene 2.0 methanol 7.0 ethyl a cetate 27 acetonitrile 80 acetone 120 chloroform 160 methylene chloride 580 Vapor pressure at 25°C <1 x 10 - 7 mm Hg A relatively non - volatile compou nd; low potential for losses due to volatilization. Dissociation constant (pK a ) 4.4 This compound will dissociate and exist in its anionic form at most environmentally relevant pHs. Octanol/water partition coefficient (K OW ) pH K ow at 25°C 5 220 7 9.2 9 0.86 Low potential for bioaccumulation in biota. UV/visible absorption spectrum λ max = 395 nm absorption at λ>400 nm is not anticipated Potential to absorb sunlight in the UV/visible range of 290 - 400 nm. 860.1200 Directions for Use Summary of Existing Uses on Garden Beet and Chicory For sugar beet, UpBeet may be broadcast applied via ground or air equipment at up to 0.032 lbTriflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 7 of 21 ai/A/application. Multiple applications can be made at 5 - 10 day re - treatment intervals (RTI s) with the total application not to exceed 0.078 lb ai/A/season. For chicory , two applications may be made, at 0.024 lb ai/A and at 5 - to 10 - day RTI s , for a maximum seasonal application rate of 0.048 lb ai/A. This formulation may also be band - applied at rates equivalent to the broadcast rates (actual band rates are dependent upon crop row spacing). UpBeet is not to be applied via any ty pe of irrigation sy stem. The existing label for UpBeet lists a PHI of 60 day s for both sugar beet and chicory , representing a potential mid - season use. Plant - back intervals are 0 day s for sugar beets, 14 day s for all other crops except corn, and 21 day s for corn. A plant - back interval has not been proposed for chicory or garden beet. HED is satisfied with the 14 - day interval that these crops receive from being in the “other crop” category as listed on the current label. Proposed Use on Garden Beet Table 3 provides a summary of the proposed uses for DuPontTM UpBeet ® Herbicide ( DF , water dispersible granule , WDG, containing 50% triflusulfuron - methyl by weight) . The maximum single application rate is 0.0156 lb ai/A for agricultural use o n garden beets for control of broadleaf weeds. Triflusulfuron - methyl (as UpBeet) may be applied aerially

or with groundboom equipment. TABLE 3. Sum ma ry of Proposed Directions for Use of Triflusulfuron - Methyl on Garden Beets. Trade Name Application

T iming Application

Rate (lb ai/A) Max.

No. Applic. per Season RTI 1

(days) Max.

Seasonal Applic. Rate (lb ai/A) PHI

(days) Use Directions and other

Limitations (i.e. grazing, type of application/equipment, plant - back interval, other) Garden Beets Up B eet® Herbicide Apply as a post emergent spray when garden beets are at the following stages: 2 - 4 leaf stage; 4 - 6 leaf stage; and 6 - 8 leaf stage. 0.0156 + NIS or COC (at 0.25% v/v) 3 See appli cation timing 0.047 30 a - Apply UpBeet ® Herbi cide with NIS or COC .

- Apply UpBeet ® Herbicide via groundboom or aerial application equipment. b

- Do not apply UpBeet ® Herbicide through any type of irrigation equipment.

1 RTI = retreatment interval Notes: a The label does not indicate a specific PH I for garden beets, however there is a general label statement that appears on the new proposed supplemental label indicating that “ UpBeet ® Herbicide must not be applied within 60 days of harvest” (PMRA# 1708273). The letter from the sponsor (PMRA# 1708271 ) and the letter of support from the registrant (PMRA# 1708272) both indicate a PHI of 30 days. According to the D.3.1 note to file (M2004 - 4211/cc050119.ntf.wpd), a clarifax was sent on 13 January 2005 to the sponsor to clarify the correct PHI. The sponsor indicated that the correct PHI is 30 days. Therefore, a specific PHI of 30 days for garden beets needs to be added to the supplem ental label. b The petition under review (9E7669, pg. 17) for the new use on garden beets lists both ground and aerial appli cation methods. The existing label for sugar beets covers both of these application methods. The proposed supplemental label for garden beet s covers only the ground application method. The sponsor has confirmed that aerial application is requested for t his new use. Therefore, the aerial application m ethod needs to be added to the supplem ental label.Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 8 of 21 Conclusions . The proposed labels are adequate to evaluate the residue data relative to the proposed uses. However, the proposed supplemental label for garden beet needs to be revised to reflect the requested 30 day PHIand the aerial application method. Therefore, the following label amendments are required for the proposed supplemental label for use of UpBeet ® Herbicide (Reg. N o . 352 - 569) on garden bee t: 1) Under the Directions for Use section: ADD: Do not apply

within 30 day s of harvest. 2) Aerial application method

– The use of the aerial application method needs to be delineated, either by reference to the existing label instructions for aerial ap plication on sugar beets or by including similar language on the supplemental label itself. 860.1300 Nature of the Residue - Plants MRI D 42496866

– Sugar Beet The initial step in the metabolic breakdown of triflusulfuron - methyl on sugar beet plants a ppears to be cleavage of the sulfonylurea bridge, forming triazine urea and ester sulfonamide. This process appears to occur readily on the leaf surfaces of the sugar beet. Triazine urea undergoes reduction and demethylation steps over time, eventually f orming N,N - bisdesmethyl triazine amine. The ester sulfonamide intermediate is rapidly converted to acid sulfonamide, which, over time, appears to form a conjugate with glucose. The confined rotational crop studies show that cleavage of the sulfonylurea b ond also occurs readily in soil. No parent compound was detected in any plant commodities, even from the shortest rotation interval of 30 day s, suggesting that it is rapidly cleaved and/or not translocated. However, the triazine side of the triflusulfuro n - methyl molecule appears to be more sy stemic and/or more persistent than the sulfonamide portion. Conclusions: For the purposes of this petition (9E7669) on garden beet, the previously reviewed sugar beet metabolism study is sufficient to support the n ew requested uses of triflusulfuron methyl on garden beets. The proposed tolerance expression should include only the parent compound, triflusulfuron - meth yl , as determined by HED [Per memo of J. Stokes (February 19 96) , meeting of 16 January 19 96]. 860.13 00 Nature of the Residue – Livestock MRI D 42991431 Based on the characterization performed on the liver, kidney , and milk (triazine - labeled only f or milk), the principle pathway s for metabolism of triflusulfuron - methy l in the goat appe ar to be hy drolysis of the sulfony lurea linkage and demethy lation of the dimethy

lamino group attached to the triazine ring (either before of after the sulfony lurea linkage is split). The triazine - labeled studies show that additional metabolic pathway s exist that involve con jugation with endogenous proteins, producing a highTriflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 9 of 21 proportion of covalently

bound or highly

polar, soluble residue. Conclusions: HED previously reviewed this goat metabolism study and cited deficiencies to be addressed if additional Section 3 registratio ns were pursued by the petitioner. However, HED has determined that measurable triflusulfuron - methyl residues above the limit of detection ( LOD; 0.005 ppm) will not be detectable in milk, meat, fat, muscle, or meat by products from the existing use on sugar beets and the new proposed use on garden beet. Therefore, the deficiencies cited in the HED memorandum of 7 June 19 93 (J. Herndon) do not need to be addressed for the purposes of this new food use on garden beet. However, if future uses on large - acreag e crops such as wheat, corn, or soy bean are proposed, and consequently involve feedstuffs, then an adequate ruminant metabolism study should be provided. 860.1340 Residue Analytical Methods MRID 42496873 – Method AMR 1930 - 91 Method AMR 1930 - 91 is the en forcement method on record for triflusulfuron - methy l, which was independently

validated (MRID 42517103). Frozen beet foliage or beet root samples are chopped prior to extraction. Samples (10 g.) are extracted with 20% acetonitrile (ACN) / 80% 0.1M (NH 4 ) 2 CO 3 buffer, macerated, centrifuged, and the resulting supernatant drawn off. The supernatant is acidified to between pH 2 - 3 and recentrifuged. The solutions are passed through pheny l solid phase extraction ( SPE ) cartridges and acidified (pH <3). The sample s are further purified using a pheny

l HPL C column and UV detector (232nm). The samples are eluted using 0.01 M potassium phosphate in 60% methanol (pH 3.5) and the fractions eluting around DPX 66037 ( retention time, RT , verified with a standard) are colle cted. The samples are acidified to between pH 2 - 3 and injected onto a C 18 HPL C column, eluted with 0.01 M potassium phosphate in 42% methanol (pH 7.0), with the DPX - 66037 peak detected by UV (232nm). The LOQ is 0.05 ppm. MRID 42496872 – Method AMR -2021 - 91 This AMR 2021 - 91 method is very similar to the enforcement method, AMR 1930 - 91. By using automated column switching equipment for the columns and elu a t e , the sample transfer from the pheny l to C 18 column can occur automatically . In addition, without the sample loss that occurs in the transfer of sample from the pheny l to C 18 column (only

2 mL of the 10 mL

is transferred to the C 18 column in the AMR 1930 - 91 method), the method is able to achieve a lower LOQ (the registrant claims 0.02 ppm). For sugar beet roots at fortifications from 0.020 to 1.00, the registrant achieved recovery

values from 89 to 111% (average recovery of 101%, standard deviation of 7%). For sugar beet foliage at fortifications from 0.020 to 1.00, the registrant achieved recovery va lues from 89 to 106% (average recovery of 98%, standard deviation of 5%). MRID 48207101 – Method 4480 E.I . du Pont’s Method 4480 is proposed as a data - gathering method in plant matrices for the determination of residues of triflusulfuron - methyl (also re ferred to as DPX - 66037). TwoTriflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 10 of 21 separate HPLC protocols were developed, differing in detection instrumentation, with similar extraction and clean - up procedures for both methods. Processed samples of red beet and sugar beet matrices (roots and foliage) are e xtracted by homogenization with ACN / 0.1 M ammonium carbonate (2:1, v:v). Sodium chloride (NaCl) is added to induce phase separation and residues of triflusulfuron - methyl partition directly into the ACN lay er. An aliquot of the ACN lay er is removed, dilut ed with 0.1 M acetic acid and subjected to sequential clean - up by SPE using Bond Elut® and/or OasisTM HL B cartridges. Residues of triflusulfuron - methyl are eluted with ACN, and the eluate is evaporated to dry ness and redissolved in methanol (MeOH) /water (2 5:75, v:v) prior to analy sis by reverse - phase HPL C, with either tandem mass spectrometry (MS/MS) or ultraviolet (UV) detection. The methods are sensitive to the proposed analy te , with L OQs of 0.01 ppm for each method. While the L OD was not determined expe rimentally , it is assumed to be approximately 3 times the background around the RT of the peak of interest. In sugar beet and red beet samples spiked at the L OQ and analy

zed by HPL C/MS/MS following OasisTM HL B clean - up only , recoveries ranged from 81% to 104%, with all standard deviations (SDs) less than or equal to 8%. In samples cleaned - up by

sequential application to SAX and OasisTM HL B cartridges and analy zed by HPL C/MS/MS, recoveries in the same matrices ranged from 82% to 101% when spiked at the LOQ, with SDs less than or equal to 10%. Insamples spiked at the L OQ and analy zed by column - switching HPL C - UV, r ecoveries ranged from 82% to 105%, with SDs less than or equal to 10%. The good recoveries and low SDs in spiked samples indicate that Method 4480 is reliable and reproducible, regardless of the clean - up procedures and detection methods used. Control chr omatograms were provided for sugar beet foliage, sugar beet root, red beet foliage and red beet root. No interferences were noted at or near the RT s of triflusulfuron - methyl, indicating that the method is specific for the analy te in question. There was n o interference from reagents reported. Detector linearity was demonstrated for both methods, with coefficients of determination (r 2 ) greater than 0.9900 in sugar beet foliage analy zed by HPL C/MS/MS and red beet foliage analy

zed by column switching HPL C - UV . Extraction efficiency was not demonstrated for Method 4480. Conclusions: The review of Method 4480 was originally completed by

PMRA, but has been reviewed by

HED and is consistent with OCSPP policy . An adapted version of Method 4480 was utilized in th e garden beet field trials submitted for this new use petition. The independent laboratory validation (I LV) of Method 4480 successfully demonstrated the reliability of the HPL C/MS/MS method for the analy sis of residues of triflusulfuron - methyl in sugar beet foliage and sugar beet roots on the first attempt . Method 4480 also included a scientifically

acceptable rationale to waive the requirement of a radiovalidation study for this method, based on the similarities in extra ct ion steps between this method and those employ ed in a corresponding sweet potato metabolism study (received and reviewed by PMRA) . Therefore, method 4480 is considered acceptable as a data - gathering and enforcement method for the determination of triflusulfuron - methyl in plant matrice s (including garden beets).Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 11 of 21 The enforcement method on record for triflusulfuron - methyl is method AMR 1930 - 91 (MRI D 42496873). Method AMR 2021 - 91 ( MRI D 42496872) is very similar to AMR 1930 - 91 and was used in the previously

submitted sugar beet and chic ory field trials. Method 4480 is also similar to both these methods, with the primary difference being the addition of a tandem mass spectrometric detection protocol in Method 4480. The registrant should clarify whether they

want to replace the existing enforcement method with Method 4480 when apply ing for future new uses, as this newer method appear s to be an acceptable enforcement method. 860.1360 Multiresidue Methods MRID 42496874 Analy sis of DPX - 66037 was not applicable to FDA Multi - Residu e Protocol A (due to lack of N methy lcarbamate structure), Protocol B (due to lack of an acid of phenol structure), or Protocol E (due to lack of adequate recovery from Florisil). Testing through Protocol C produced responses that were greater than 50% fu ll scale deflection using several column/detector combinations. The laboratory noted that these responses may have been due to thermal degradation of DPX - 66037 rather than elution of DPX - 66037 itself. Recoveries of DPX - 66037 from sugar beets were tested u sing Protocol D. A 2% diethy lene gly col succinate ( DEGS ) on Chromosorb W - AW packed column was used in conjunction with an electroly tic conductivity

detector ( ELCD ) operated in the nitrogen mode. The following recoveries were achieved: 67 and 99% recovery from 0.02 ppm fortifications, and 92 and 106% recovery from 0.1 ppm fortifications. Conclusions : FDA’s multiresidue method Protocol D is suitable for analy sis or enforcement of triflus u lfuron - methyl residues. This information was previously forwarded t o FDA. 860.1380 Storage Stability Previously

submitted storage stability data indicate that triflusulfuron - methyl in/on sugar beet roots and tops is stable for periods of up to 18 months when stored frozen at - 25  C. The storage stability data submitted in support of the proposed use in garden beet roots and tops (leaves) demonstrated that residues were stable for up to ~15 months (436 day s) when stored frozen at

- 29  C to - 10  C. Conclusions : The available storage stability data indicate that residues of triflusulfuron - methyl are stable in frozen storage for up to approximately 15 months. Samples from the garden beet residue field tri al s were stored for up to ~13 months (381 day s). Therefore no additional storage stability data are needed for the prop osed use on garden beet. 860.1400 Water, Fish, and Irrigated Crops There are no proposed uses for triflusulfuron - methyl that are germane to this guideline. No evaluation is necessary

at this time. 860.1460 Food HandlingTriflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 12 of 21 There are no proposed uses for triflusulfuron - methyl that are germane to this guideline. No evaluation is necessary

at this time. 860.1480 Meat, Milk, Poultry, and Eggs Inan earlier review ( PP#4F4278) , the petitioner was granted a waiver of ruminant and poultry feeding studies ( and the tolerances in meat, milk, poultry , and egg associated with them ) for the existing use on sugar beets. The ruminant feeding study waiver was granted on the basis of estimated dietary consumption by dairy cattle of triflusulfuron - methyl from the three feed items associated with sugar beets

– leaves, molasses, and dried pulp. In the goat metabolism study the highest residue values (total radioactivity , expressed as triflusulfuron - methyl equivalents) occurred in the kidney s at 0.66 ppm and liver at 0.61 ppm (based on feeding 10 ppm of triazine - labeled triflusulfuron - methyl in the diet). The maximum expected residue level in ruminant liver/kidney was found to be <0.003 ppm, well below the LO Q of the enforcement methodology for triflusulfuron - methyl residu es in sugar beet commodities and the likely L OQ of a reasonable livestock analy tical method . There are no ruminant feed items associated with the new proposed use on garden beets. Therefore this new use should have no additional impact on the estimate d ruminant dietary consumption of triflusulfuron - methyl. Sugar and garden beet products are not utilized as poultry feedstuffs, therefore triflusulfuron methyl residues would not be expected in poultry commodities. Conclusions : Using information in the goat metabolism studies, residues of triflusulfuron methyl (as defined by

the livestock residue definition) are expected to be below the LOQ of a reasonable livestock analy tical method. Hence a 40 CFR 180.6(a)(3) situation (no expectation of finite r esidues) exists. Neither feeding studies nor tolerances in livestock commodities are required at this time. Feeding studies and analy tical methods may

be required to support future uses of triflusulfuron - methyl that involve significant livestock feed ite ms. 860.1500 Crop Field Trials Sugar Beet MRI D 42496868 , 42496867 No additional field trial residue data for sugar beets were submitted in this petition. The registrant previously

provided 3 volumes of residue data on sugar beet in PP 3G4161 (MRI D #’ s above, see 6/7/93 G. J. Herndon review, D184250 ). The registrant conducted residue trials in 1991 at sites in North Dakota, Michigan, Colorado, Nebraska, and California. These 5 states account for 47% of the sugar beet for sugar production ( Agricultural Statistics , 1994, USDA). Three applications of a 50% DF formulation were made one week apart to each treated plot at 0.5 or 1.0 oz ai/A (0.03 or 0.06 lb ai/A), which correspondsTriflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 13 of 21 to between 2X and 4X the maximum proposed seasonal use rate. Samples were h arvested between 101 and 126 day s after the last application. The samples were stored up to 8 months between harvest and analy sis. The samples were analy zed by method AMR 2021 - 91 (MRI D 42496872) for the parent compound (average recovery 92%), and method A MR 2187 - 91 (MRI D 42496875) for the 3 triazine metabolites (average recoveries of 79 to 81%). No residues of triflusulfuron - methyl, or its metabolites D8526, E7710, or M7222 were found in any of the samples (0.05 ppm LOQ for each analy te; LOD estimated at 0.005 ppm for parent and 0.02 ppm for triazine metabolites). The registrant included additional, non - GLP data from trials conducted in France. At similar application rates and PHI s from 119 to 162 day s, no triflusulfuron - methyl was found (0.02 ppm LOD ). No residues of D8526 or E7710 were found in any samples. Quantities of M7222 were detected in sugar beet foliage at levels up to 0.05 ppm at 160 day s. This is based on an LOD of 0.02 ppm. The registrant conducted field trials to determine the decline of triflusulfuron - methyl residues and the formation and decline of residues of the triazine metabolites D8526, E7710, and M7222 in sugar beet over time (MRI D 42496867). Field trials were conducted in I daho, North Dakota, and California in 1990 and 1991. Three applications of either 40% or 50% DF formulations were made one week apart at either 0.4 or 0.8 oz ai/A (0.025 or 0.05 lb ai/A) or 0.5 or 1.0 oz ai/A (0.03 or 0.06 lb ai/A), which corresponds to between 1.6X and 4X the maximum proposed seasonal use rate. Samples were harvested at intervals of about 0, 7, 14, 28, 56, 84, and 112 day s following the last application. The whole plant was analy zed up to 28 day s after last application; at 56 day s and bey ond, tops and roots were analy zed separately . The samples were stored up to 18 months between harvest and analy sis. The samples were analy zed by method AMR 2021 - 91 for the parent compound (average recovery 93%), and method AMR 2187 - 91 for the 3 triazine metabolites (average recoveries of 82 to 86%). Up to 2.56 ppm of triflusulfuron - methyl was found on the whole beet plants at 0 day s after treatment (DAT). At the next harvest, 7 DAT, and bey ond , no parent was detected in any of the samples ( the next sampling of the I daho trial occurred at 28 DAT, not 7 D AT, due to severe hail damage). This is based on an LOD of 0.005 ppm and an LOQ of 0.05 ppm. At 7 DAT and bey ond (28 DAT for I daho trial), no residues of D8526 or E7710 were found in any samples. Trace quantities of M7222 (0.03 ppm) were detected in sug ar beet foliage as long as 112 DAT in two of the three trials. This is based on an LOD of 0.02 ppm and an LOQ of 0.05 ppm. MRI D 43982901 Inresponse to the Agency 's request for field trial data reflecting the 60 day PHI , additional data (MRI D 43982901 , see 5/14/96 J. Stokes review, D 225643 ) from 12 trials conducted in the US (5), Germany

(6), and Sweden (1), as well as comments on the US sugar beet production areas and possible PHI s ( based upon US agricultural growing practices for sugar beet ) were submi tted. The PHI s of the US trials ranged from 45 to 56 day s at rates of 1.4 to 6 oz ai/A (0.09 to 0. 375 lb ai/A; 1.9X to 8X the proposed label seasonal maximum). In the Germany trials ( conducted at 1.1X the maximum proposed seasonal label rate ) samples wer e harvested and analy zed from 15, 16, 16, 26, 34, and 53 day s after the last application. In the Sweden trial, samples were analy zedTriflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 14 of 21 33 day s after the last application. Triflusulfuron - methyl residues were not detected (<0.02 ppm) in the samples. Theref ore, the field trial and residue decline data demonstrate that triflusulfuron - methyl is rapidly degraded after application to sugar beet plants. Chicory MRI D 45211101 No additional field trial data was submitted with this petition. The results from the supervised crop field trials study

(MRI D 45211101 ; see 11/9/01 G. J. Herndon review, D279136 ) in chicory conducted in Mt. Vernon, WA, L a Conner, WA, Sedro Woolley , WA, and Manteca, CA, showed that the maximum residues in chicory , collected 59 to 62 day s following the last application of triflusulfuron - methyl (as 50% ai WDG) and treated at 0.75 oz ai/A (0.05 lb ai/A , equivalent to 1X the approved use rate ) , were below the LOD (0.016 ppm). The residues in these field trials were determined using Du P ont Me thod AMR 2021 - 91. Th ese data w ere sufficient to establish a 0.05 ppm tolerance in chicory roots . Data were also provided for dry pulp and inulin , although tolerances were not needed for these commodities . These analy tical results adequately demonstrated that in this limited setting the proposed use pattern would not result in residues that exceed this tolerance. Garden Beet MRI D 47943201 The sponsor, Interregional Research Project No. 4 (I R4), has submitted field trial data for triflusulfuron - methyl o n garden beets. Five garden beet field trials were conducted in the United States and 3 field trials were conducted in Canada for a total of eight field trials conducted during the 2005 growing season. Inthe United States, trials were located in New Yor k (Zone 1), Ohio (Zone 5), Oregon (Zone 12), Texas (Zone 6) and Wisconsin (Zone 5A). I n Canada, two trials were conducted in Quebec (Zone 5B) and one trial was conducted in Ontario (Zone 5). At each trial site, garden beets were treated with triflusulfuro n - methyl (formulated as Safari 50 DF) in 3 foliar broadcast applications at a rate of 0.016

– 0.017 lb ai/ A /application, at 5 - 12 day RTI s, for a maximum seasonal application rate ranging from 0.047

– 0.049 lb ai/ A . Garden beet roots and tops (leaves) were harvested at PHI s of 22 - 56 day s. A registered NI S or COC was added to the spray mixture for each application at a rate of 0.25% v/v at all trials except the trial conducted in Oregon. Garden beet samples were analy zed for residues of triflusulfuron - meth yl using a modified version of Du P ont method 4480 entitled “Analy tical Method for the Determination of Triflusulfuron - Methyl in sugar beets and red beets by HPL C/MS/MS and column switching HPL C - UV” (PMRA# 1708274). This method has been previously reviewed and deemed acceptable for both data - gathering and enforcement (M2005 - 0813

– PMRA# 1041650). The method was adequately validated in garden beet roots and tops at spiking levels of 0.01 ppm, 0.10 ppm, and 1.00 ppm (recoveries ranged from 94 - 118% in roots and from 90 - 107% in tops) indicating that the modifications to the method did not adversely affect the method’s data -Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 15 of 21 gathering capabilities. The instrument’s L OQ for this method was set at the lowest level of method validation (L LM V) of 0.01 ppm for each m atrix (roots and tops). The calculated/statistical L OQ values were 0.0069 ppm for roots and 0.0044 ppm for tops. The calculated/statistical L OD values were 0.0023 ppm for roots and 0.0015 ppm for tops. Method suitability was also evaluated concurrently with sample analy sis. Mean concurrent recoveries ± SD in garden been roots and tops spiked with 0.01 ppm (1x L OQ) of triflusulfuron - methyl were 99 ± 9% ( n = 8) and 98 ± 5% (n = 8), respectively . All recoveries fell within the generally recognized accepta

ble 70 - 120% range indicating that Du P ont method 4480 is reliable for the determination of residues of triflusulfuron - methyl in/on garden beet roots and tops. Treated garden beet root and top samples were stored frozen ( - 29 o C to - 10 o C) for 299 - 377 day s and 300 - 381 day s, respectively . The freezer storage stability of triflusulfuron - methyl residues in/on garden beets was demonstrated concurrently , with samples spiked at 0.10 ppm. The mean ± SD corrected residue recoveries (corrected for concurrent recoverie s of 114% and 107% in roots and tops , each spiked with 0.10 ppm of triflusulfuron - methyl, respectively ) of triflusulfuron - methyl in samples stored frozen for 436 day s were 92 ± 3% (n = 3) in roots and 92 ± 2% (n = 3) in tops, indicating that no significant degradation of residues occurred throughout this time interval. Therefore, there are no concerns with the stability of residues over time in this study . The data indicate that residues of triflusulfuron - methyl in/on garden beet roots were all below the LOQ of 0.01 ppm when treated at total rates of 0.047 - 0.048 lb ai/A (using a NI S/COC) and harvested at PHI s of 22 - 56 day s. Residues of triflusulfuron - methyl in/on garden beet tops (leaves) were ≤ 0.01 ppm when treated at total rates of 0.047 - 0.048 lb ai/A (using a NI S/COC) and harvested at PHI s of 22 - 56 day s. At the Oregon trial site where no NI S/COC was used in the spray mix tures, residues in roots and tops treated with a total of 0.049 lb ai/A and harvested at a PHIof 24 day s were all <0.01 ppm. Residue decline behaviour was not assessed in this study . TABLE 4. Summary of Residue Data fromCrop Field Trials with Triflusu lfuron - Methyl. Commodity Total Applic.

Rate (g a.i./ha) PHI

(days) Triflusulfuron - methyl Residue Levels (ppm) n Min. Max. HAFT * Median (STMdR) Mean

(STMR) Std. Dev. WITH a Non - Ionic Surfactant or Crop Oil Concentrate Garden Beet Tops (Leaves) 53. 0

– 54.3 a 22 - 56 14 <0.01 0.01 <0.01 <0.01 <0.01 0.00 Garden Beet Roots 53.0

– 54.3 22 - 56 14 <0.01 <0.01 <0.01 <0.01 <0.01 0.00 WITHOUT a Non - Ionic Surfactant or Crop Oil Concentrate Garden Beet Tops (Leaves) 54.6 b 24 2 <0.01 <0.01 <0.01 <0.01 <0.01 0.00 Garden Beet Roots 54.6 24 2 <0.01 <0.01 <0.01 <0.01 <0.01 0.00

a 53.0 - 54.3 g ai/ha = 0.047 - 0.048 lb ai/A b 54.6 g ai/ha = 0.049 lb ai/A * HAFT = Highest Average Field Trial. STMdR = supervised trial median residuesTriflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 16 of 21 STMR = supervised trial mean residues S td. Dev. = standard deviation Conclusions : The crop field trials for chicory and sugar beets were previously classified acceptable and satisfied the guideline requirement for crop field trials ( M. Doherty , et al ., D260076, 12 February

2002). The newly submitted crop field trials are adequate to support the requested new use of triflusulfuron - methyl on garden beet. The review of these field trials was originally conducted by PMRA under a work share agreement , but their conclusions have been reviewed by HED and are consistent with OCSPP policy . The freezer storage stability of triflusulfuron - methyl residues in/on garden beets was demonstrated concurrently , with samples spiked at 0.10 ppm stored frozen for 436 day s. Analy sis of these samples showed no si gnificant degradation of residues occurred throughout this time interval. The maximum frozen storage time for garden beet samples was 381 day s, a duration that is shorter than the demonstrated residue stability period. Therefore, there are no concerns with the stability of residues over time in this study . The data indicates that residues of triflusulfuron - methyl in/on garden beet roots and tops were all ≤ 0.01 ppm when treated at total rates of 0.047 - 0.049 lb ai/A (using a NI S/COC or not) and harvested at PHI s of 22 - 56 day s. I t should be noted that the petition under review requests a 30 - day PHIfor garden beet, whereas a 60 - day PHIis currently

approved for sugar beets. The requested 30 - day

PHIfor garden beet is supported by the submitted field trial data. Of the 8 submitted garden beet field trials, 5 were conducted at PHI s of 30 day s or less (22, 23, 24, 24, 30) and 3 at PHI s greater than 30 day s (36, 42, 56). 860.1520 Processed Food and Feed Processing data were not submitted for garden beets. Such data are not required as there are no processed commodities from garden beets in which residues are expected to concentrate. A previously

submitted processing study (MRI D 42496869 ; see 6/7/93 G. J. Herndon review, D184250 ) was performed in North Dak ota where plots of sugar beet were treated one time at 45 day s before harvest with a 50% DF formulation of triflusulfuron - methyl at the rate of 6.0 oz ai/A (0.38 lb ai/A; 8X the proposed seasonal use rate). At harvest, roots and tops were separated and fr ozen. Sugar beet roots were processed into white sugar, molasses, and dried pulp, and the samples were shipped frozen to the registrant for analy sis. Samples were analy zed using method AMR - 2021 - 91 with modifications made to the sample extraction step for the processed fractions. Recoveries were as follows: sugar (range: 85 to 104%, average: 97%), molasses (range: 83 to 97%, average: 92%), and dried pulp (range: 86 to 111%, average: 97%). Up to 0.033 ppm of triflusulfuron - methyl was found i n the sugar be et tops at harvest (45 DAT). No triflusulfuron - methyl was found in the samples of sugar beet root , the raw agricultural commodity (RAC) , or in any of the processed commodities (sugar, molasses, or dried pulp). This is based on a 0.01 ppm LOD . No analy se s were performed to examine if any of the three triazine metabolites, D8526, E7710, and M7222, were present in any of the samples.Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 17 of 21 Conclusions . Based on the available data, the field trial and residue decline data demonstrate that triflusulfuron - methyl i s rapidly degraded after application to sugar beet plants. Even at exaggerated rates (8X), no triflusulfuron - methyl was found in the sugar beet roots (RAC) or processed commodities; therefore concentration of residues in processed commodities is unlikely at the currently

approved use rates on sugar beets. Additional residue decline data was not submitted for the garden beet proposed use currently under review. There are no known processed commodities for garden beets in which residues are expected to con centrate; thus , processed food and feed should not be an issue for this new food use petition. 860.1650 Submittal of Analytical Reference Standards An analy tical standard for tr if

lu sulfuron - methyl is currently available in the N PSR, via personal communication with Dallas Wright , of ACB, on October 4 2010 . Analy tical reference standards should be replenished as requested by the Repository . The reference standards should be sent to the AC B , which is located at Fort Meade, to the attention of Theresa Cole at the following address: USEPA National Pesticide Standards Repository /Analy tical Chemistry

Branch/OPP 701 Mapes Road Fort George G. Meade, MD 20755 - 5350 ( Please n ote that the mail will be returned if the extended zip co de is not used.) 860.1850 Confined Accumulation in Rotational Crops A confined rotational crop study was conducted using wheat, beetroot (red beet), and lettuce sown 30, 120, and 300 day s post - application and grown to maturity ( MRI D 42496865 ). The stud y was conducted using triflusulfuron - methy l labelled separately

with carbon - 14 in the triazine ring and at the ester carbony

l position, similar to the plant and animal metabolism studies. The confined rotational crop studies show that cleavage of the sulf ony lurea bond also occurs readily in soil. No parent compound was detected in any plant commodities, even from the shortest rotation interval of 30 day s, suggesting that it is rapidly cleaved and/or not translocated. However, the triazine side of the tri flusulfuron - methy l molecule appears to be more sy stemic and/or more persistent than the sulfonamide portion. Uptake of triazine residues into wheat straw has been observed. Conclusions: Additional rotational crop studies or rotational crop tolerances are not needed at this time. Such studies may

be needed if uses are proposed on major crops (e.g., wheat, cotton, corn, soy beans) due to the observed uptake of triazine - derived soil residues into wheat straw in the confined study . [ See memo of J. Stokes ( 31 January 19 96) for HED meeting of 16 January 19 96].Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 18 of 21 860.1900 Field Accumulation in Rotational Crops Additional rotational crop studies or rotational crop tolerances are not needed at this time. Such studies may

be needed if uses are proposed on major cr ops (e.g., wheat, cotton, corn, soy beans). 860.1550 Proposed Tolerances At this time, tolerances are not required in livestock commodities. For plant commodities, existing tolerances are in place for the previously assessed sugar beets and chicory . Ne w tolerances in/on garden beets are being requested in the petition under review (Petition 9E7669). The registrant has proposed that tolerances for the residues of the herbicide triflusulfuron methyl, or methyl 2 - [[[[[4 - (dimethylamino) - 6 - (2,2,2 - trifluoroe thoxy ) - 1,3,5 - triazin - 2 - yl ]amino]carbonyl]amino]sulfonyl] - 3 - methylbenzoate, be established on garden beet roots at 0.01 ppm (parent only

) and sugar beet tops at 0.02 ppm (parent only ). For the purposes of this tolerance petition, the compound to be regulat ed is parent only . A summary

of the petitioned - for tolerances and HED’s recommendations is provided in Table 5, below. The requested new use on garden beet is being assessed as part of a work share agreement with Canada’s PMRA. Therefore, implemented tolerances stemming from this new use will be harmonized with the PMRA review. The recommended tolerance for garden beet roots of 0.01 ppm is identical to that of PMRA’s, with all garden beet roots having concentrations less than the L OQ of 0.01 ppm in ob served field trials. However, the recommended tolerance of 0.02 ppm for garden beet tops is not harmonized with PMRA’s value of 0.01 ppm. Based on the submitted garden beet field trial data, garden beet tops had concentrations equal to 0.01 ppm at a sing le field trial in Texas (Trial 08043.05 - TX*19 ). Given the level of uncertainty

for quantification around the L OQ of 0.01 ppm and the limited number of field trials , HED does not consider setting the garden beet top tolerance at 0.01 ppm to be appropriate . Therefore, HED is concurring with the registrant - proposed tolerance of 0.02 ppm for garden beet tops. Table 5 . Tolerance Summary for Triflusulfuron - methyl Commodity Proposed Tolerance (ppm) Recommended

Tolerance (ppm) Comments (correct commodity definition) Beet, garden, roots 0.01 0.01 -- Beet, garden, tops 0.0 2 0.0 2 -- References Triflusulfuron - methyl : Human Health Risk Assessment for the Section 3 Registration on Sugar Beets (PP#4F4278) and Chicory (PP#0E6214) . (M. Doherty , Ph.D., D260076 ; February 2002) PP#4F4278. Triflusulfuron - methy l (DPX - 66037) on Sugarbeets. E valuation of Analy tical Method and Residue Data. MRID#s 429914 - 01, 429914 - 02, and 429914 - 31. D P Barcodes# 211798 and 211802. CBTS# 15084 and 15085. (J. Stokes, January 31 , 1996)Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 19 of 21 PP#4F4278. Triflusulfuron - methy l (DPX - 66037) In

/O n Sugarbeet. Additional Comments on Proposed 60 - Day

PHI . Product Chemistry . MRI D#s 4 39829 - 00 and 439829 - 01. DP Barcode# D225643. (J. Stokes, May 14, 1996) PP#3G04161. Temporary Tolerance Pet ition and Experimental Use Permit for Use of Triflusulfuron - methy

l (DPX - 66037) on Sugar Beets; 000352 - EUP - RAN. Evaluation of Analy tical Method and Residue Data. (G. J. Herndon, D184250 , 6/7/93) MRI D Study

Title Date 42496865 Hawkins, D.; Kirkpatrick, D .; Dean, G.; et al. (1992) Confined

Accumulation Study

of (Carbon 14) - DPX - 66037 on Rotational Crops: L ab Project Number: HRC/DPT 222/911123: AMR - 1637 - 90. Unpublished study prepared by

Huntingdon Research Centre Ltd. 122 p. 30 - Sep 1992 42496866 Dietrich, R.; McAleer, N. (1992) Metabolism of DPX - 66037 in Sugar Beets:

Lab Project Number: EF - 90 - 312: AMR 1639 - 90. Unpublished study prepared by

Pan - Agricultural Laboratories Inc.; E.I . du Pont de Nemours & Co. 94 p. 30 - Sep 1992 42496868 Slates, R.; Desmond, P.; Devine, P.; et al. (1992) Magnitude of Residues of

DPX - 66037 Experimental Herbicide in Sugar Beets Following Multiple Applications: L ab Project Number: AMR 2004 - 91. Unpublished study prepared by

E. I . du Pont de Nemours & Co. 258 p. 30 - Sep 1992 42496873 Amoo, J.; Walker, D. (1991) Split Analy tical Method for the Quantitation of DPX - 66037 in Sugar Beets: Lab Project Number: AMR 1930 - 91. Unpublished study

prepared by

E. I . du Pont de Nemours & Co. 41 p. 30 - Sep 1992 42496872 Major L .; L arochelle, J.; Bedw ell, L .; et al. (1991) Automated Analy tical Method for the Quantitation of DPX - 66037 in Sugar Beets: Lab Project Number: AMR 2021 - 91. Unpublished study prepared by

E. I . du Pont de Nemours & Co. 42 p. 30 - Sep 1992 42496874 Fomenko, J. (1991) Testing of DP X - 66037 through FDA Multi - Residue

Protocols A through E: L ab Project Number: AMR - 2085 - 91: DUP91001. Unpublished study

prepared by

Spectraly tix Inc. 69 p. 30 - Sep 1992 42517103 Bruns, G. (1992) Independent Laboratory Validation of DPX - 66037 in Sugar Beet F oliage and Roots by L iquid Chromatography : L ab Project Number: AMR 2194 - 91: 92 - P1143.REP. Unpublished study prepared by

Enviro - Test Laboratories. 142 p. 30 - Sep 1992 45211101 Salzman, F. (2000) Triflusulfuron - Methyl: Magnitude of the Residue on

Chicory (R oots): L ab Project Number: 06709.99 - ABC03: 06709.97 - WA63: 06709.97 - WA64. Unpublished study prepared by

ABC Laboratories, Inc., Washington State University & Plant Sciences, Inc. 223 p. {OPPTS 12 - Sep 2000Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 20 of 21 860.1550} 47943201 Carpenter, D. (2008) Triflusulf uron - Methyl: Magnitude of the Residue on Beet (Garden). Project Number: 08043, 08043/05/MI R04, 08043/05/NY07. Unpublished study

prepared by

Interregional Research Project No. 4, I R - 4 North Central Analy

tical L ab and Cornell University . 247 p. 23 - Dec 2009

48207101 Peterson, B.; Walker, D.; Cabusas, M. (2001) Analy tical Method for the Determination of Triflusulfuron - Methyl in Sugar Beets and Red Beets by HPL C/MS/MS and Column - Switching HPL C - UV. Project Number: AAFC03/003, XENO3/88, AAFCO3/003/OCR. Unpublishe d study prepared by E.I . du Pont de Nemours and Company . 35 p. 42991431 Hawkins, D.; Kirkpatrick, D.; Dean, G.; et al. (1993) The Metabolism of

(carbon - 14) - DPX - 66037 in the Goat Following Administration at a L evel Equivalent to 10 PPM in the Diet: L ab Pr oject Number: AMR 1640 - 90: HRC/DPT 244/911287. Unpublished study prepared by

Dept. of Chemical Metabolism & Radiosy

nthesis, Huntingdon Research Centre L td. 123 p. 20 - Oct 1993Triflusulfuron - methyl (129002) Summary of Analytical Chemistry and Residue Data Barcode: D388620

Page 21 of 21 Attachment 1

– In ternational Residue L imits

Triflusulfuron - methyl 

### (PC Code 129002 ; 10/01/ 10) Summary of US and International Tolerances and Maximum Residue Limits Residue Definition : US Canada Mexico 2 Codex 3 40 CFR 180. 492 : Plants: triflusulfuron methyl 2 - [[[[[4 - (dimethylamino) - 6 - (2,2,2 - trifluoroethoxy

) - 1,3,5 - triazin - 2 - yl ]am ino]carbonyl]amino]sulfonyl] - 3 - methylbenzoate methyl 2 - [4 - dimethylamino - 6 - (2,2,2 - trifluoroethoxy

) - 1,3,5 - triazin - 2 - yl carbamoylsulfamoyl] - m toluate None

Commodity 1 Tolerance (ppm) /Maximum Residue Limit (mg/kg) US Canada Mexico 2 Codex Beet, garden, roo ts 0.01 None Beet, garden, tops 0.02

Completed: M. Negussie; 10/05/10 1 Includes only commodities of interest for this action. Tolerance values s hould be the HED recommendations and not those proposed by the applicant. 2 Mexico adopts US tolerances and/or Codex MRLs for its export purposes. 3 * = absent at the limit of quantitation; Po = postharvest treatment, such as treatment of stored grains. PoP = processed postharvest treated commodity, such as processing of treated stored wheat. (fat) = to be measured on the fat portion of the sample. MRLs indicated as proposed have not been finalized by the CCPR and the CAC.