Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

PC Code: 555550

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF 

CHEMICAL SAFETY

AND POLLUTION PREVENTION

MEMORANDUM

DATE: Jul-20-2010 

SUBJECT: Cyflufenamid: Chronic Aggregate Dietary (Food and Drinking Water) 

Exposure and Risk Assessments for the First Food Uses in Support of a

Section 3 Registration Action on Cucurbit Vegetables (Crop Group 9), 

Pome Fruit (Crop Group 11), Small Fruit Vine Climbing Except Fuzzy 

Kiwifruit (Subgroup 13-07F), and Low Growing Berry (Subgroup 13-07G), 

Except Cranberry.

PC Code: 555550 DP Barcode: 364559

Decision No.: 403833 Registration No.: 8033-RNG

Petition No.: 8F7488 Regulatory Action: Section 3 Registration

Risk Assessment Type: Single Chemical Case No.: NA

TXR No.: NA CAS No.: 180409-60-3

MRID No.: NA 40 CFR: NA

REVIEWER: Meheret Negussie, Chemist

Risk Assessment Branch III (RAB3)

Health Effects Division (HED, 7509P)

THROUGH: Thurston Morton, Senior Chemist

Breann Hanson, Biologist

Dietary Exposure Science Advisory Council (DESAC)/HED (7509P)

and

Paula Deschamp, Branch Chief

Risk Assessment Branch III/HED (7509P)

TO: Nancy Dodd, Chemist, Risk Assessor

Risk Assessment Branch III/HED (7509P)

and

Marc Suarez, RM#11

Insecticide Branch/Registration Division (RD, 7505P) 
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

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Executive Summary

Chronic aggregate dietary (food and drinking water) exposure and risk assessments were 

conducted for cyflufenamid using the Dietary Exposure Evaluation Model DEEM-FCIDTM, 

Version 2.03 which uses food consumption data from the U.S. Department of Agriculture’s 

Continuing Surveys of Food Intakes by Individuals (CSFII) from 1994-1996 and 1998. 

The analyses were performed to support Section 3 requests on cucurbit vegetables (Crop 

Group 9), pome fruits (Crop Group 11), small fruit vine climbing except fuzzy kiwifruit 

(Subgroup 13-07F), and low growing berry (Subgroup 13-07G), except cranberry. 

Cyflufenamid is a new active ingredient; therefore, this is the first dietary exposure 

assessment. 

Acute Dietary Exposure Results and Characterization

No toxic effects attributable to a single exposure to cyflufenamid have been identified; 

therefore, an acute reference dose (aRfD) has not been established and an acute dietary 

exposure assessment was not conducted. 

Chronic Dietary Exposure Results and Characterization

A partially refined chronic dietary assessment was conducted. The assumptions of this 

dietary assessment included average field trial residues for all proposed crops and 100% 

crop treated (CT). Empirical processing factors were used for apple juice and grape juice. 

A separate tolerance was set for grape, raisin; therefore, the processing factor for this 

commodity was set at 1. For all other processed commodities, DEEM version 7.81 default 

processing factors were assumed. The ground water estimated drinking water 

concentration (EDWC) value of 4.68 ug/L was incorporated directly into the dietary 

assessment (DP# 362954, R. Bohaty, 05/03/2010).

The non-cancer chronic dietary (food and drinking water) exposure to cyflufenamid is 

below HED’s level of concern [i.e., <100% Chronic Population Adjusted Doses (cPAD)] 

for the general U.S. population and all population subgroups. The chronic dietary exposure 

estimates are <1% of the cPAD for the general U.S. population and was 1% to all infants (< 

1 year old), the most highly exposed population subgroup. All other subgroups showed 

estimates <1% of the cPAD.

 

Cancer Dietary Exposure Results and Characterization

Cyflufenamid is a likely human carcinogen and requires a quantitative cancer risk 

assessment. The unit risk, Q1* = 6.61 X 10-3, of cyflufenamid is based upon male mouse 

liver combined adenoma and carcinoma tumor rates. The ground water EDWC (4.68 ug/L)

was incorporated into the dietary assessment (DP# 362954, R. Bohaty, 05/03/2010). The 

cancer dietary (food and drinking water) exposure estimate for the general U.S. population 

is 9.51 x 10-7

, which is below HED’s level of concern (1 x 10-6).

 
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

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I. Introduction

Dietary risk assessment incorporates both exposure and toxicity of a given pesticide. For 

acute and chronic assessments, the risk is expressed as a percentage of a maximum 

acceptable dose (i.e., the dose which HED has concluded will result in no unreasonable 

adverse health effects). This dose is referred to as the population adjusted dose (PAD). 

The PAD is equivalent to point of departure (POD, NOAEL, LOAEL, e.g.) divided by the 

required uncertainty or safety factors.

For acute and non-cancer chronic exposures, HED is concerned when estimated dietary risk 

exceeds 100% of the PAD. References which discuss the acute and chronic risk 

assessments in more detail are available on the EPA/pesticides web site: “Available 

Information on Assessing Exposure from Pesticides, A User’s Guide,” 21-JUN-2000, web 

link: http://www.epa.gov/fedrgstr/EPA-PEST/2000/July/Day-12/6061.pdf; or see SOP 

99.6 (20-AUG-1999).

This is the first DEEM-FCIDTM analysis conducted for cyflufenamid.

II. Residue Information

Cyflufenamid (also designated as NF-149) is a new fungicidal active ingredient for the 

control of a wide range of powdery mildews on various crops. This plant disease is known 

to develop resistance to existing fungicides quite rapidly and new mode-of-action 

fungicides are continually needed by the growers. Cyflufenamid is an amidoxime or 

benzenacetamide containing a fluorinated aromatic ring and a cyclopropylmethoxy group. 

Its biochemical mode of action has not yet been defined or classified. However, it is not 

cross resistant to strobilurines, quinoxyfen, triazoles, morpholines, or ethirimol resistant 

strains of powdery mildew.

The HED Residues of Concern Knowledge-based Subcommittee (ROCKS) reviewed the 

plant, rotational crop, and livestock metabolism studies for cyflufenamid, as well as 

toxicological and environmental fate data, for determination of the residues of concern. 

The ROCKS concluded that in primary plants, the residue of concern is cyflufenamid (Zisomer) for the purposes of tolerance and risk assessment (DP# 377139, G. Kramer,

05/18/2010). RAB3 will confirm with the petitioner that the analytical enforcement 

method can, in fact, separate the E- and Z-isomers. If this is not the case, then the E-isomer 

should be added to the tolerance expression.

The only livestock feedstuff associated with the proposed crop uses in this action is apple 

wet pomace. Based on the results of the goat metabolism study and the calculated dietary 

burden there is no reasonable expectation of finite cyflufenamid residues in meat, milk, 

poultry and eggs as a result of the proposed uses. The residues of concern in ruminants is 

cyflufenamid (Z-isomer), 2,3-difluoro-6-trifluoromethyl-benzamidine (149-F1), 2,3-

difluoro-6-trifluoromethylbenzamide (149-F6) , and cyclopropane carboxylic acid (CPCA) 

for the purposes of risk assessments (ROCKS memo DP# 377139, 05/18/2010). 

Tolerances for ruminant commodities are not required at this time. There no poultry or 

swine feed items associated with the proposed uses. 
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

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Residue information for the proposed food commodities included in the present analyses 

was taken from the cyflufenamid residue chemistry memo (DP# 364556, M. Negussie, 

07/01/2010). 

The chronic dietary analysis assumed average field trial residues for all proposed crops and 

100% CT. Field trial data were translated from the representative commodities to the nonrepresentative commodities according to HED SOP 2000.1:”Guidance for Translation of 

Field Trial Data from Representative Commodities in the Crop Group Regulation to other 

Commodities in Each Crop Group/Subgroup.” Empirical processing factors for apple juice 

and grape juice were used. A separate tolerance was set for grape, raisin; therefore, the 

processing factor for this commodity was set at 1. For all other processed commodities, 

DEEM version 7.81 default processing factors were assumed. 

Table 1 summarizes the cyflufenamid residue levels and processing factors for the 

proposed crops used in the chronic dietary assessments. 

Table 1. Residue Data and Processing Factors used for Chronic Dietary Risk Assessment.

Commodity Residues

(Average; ppm)

Processing Factors

Fruit, pome, group 11 Apple-0.014

Pear-0.024

Apple, juice = 0.3

Vegetable, cucurbit, group 9 Cucumber-0.014

Cantaloupe-0.016

Squash Summer0.022

Fruit, small vine climbing, subgroup 13-

07F, except fuzzy kiwifruit

Grape-0.037 Grape, juice = 0.2

Berry, low growing, subgroup 13-07G Strawberry-0.072

Grape, raisin 0.301 Grape, raisin = 1 1

Tolerance determined using processing study (HAFT-highest average field trial residue x 3.6 (processing factor

)

III. Drinking Water Data

The drinking water residues used in the dietary risk assessment were provided by the 

Environmental Fate and Effects Division (EFED; DP# 362954, R. Bohaty, 05/ 03/2010). 

Based on the modeling analysis performed for the proposed new uses, the estimated surface 

water concentrations are 0.03 ug/L and 0.01 ug/L (chronic and cancer assessment, 

respectively) and ground water concentration is not expected to be >4.68 ug/L. Typically, 

HED uses the higher of the surface or groundwater estimates when assessing dietary risk; 

therefore, the ground water EDWC (4.68 ug/L) was used in the dietary assessment. Water 

residues were directly incorporated in the DEEM-FCID into the food categories “water, 

direct, all sources” and “water, indirect, all sources.” 

This drinking water assessment (DWA) takes into account cyflufenamid, its isomer 149-

(E)-FB [(E)-N-(α-Cyclopropylmethoxyimino-2,3-difluoro-6-trifluoromethylbenzyl)-2-

phenylacetamide], and four known degradation products of equal toxicological concern, 

149-F [N-Cyclopropylmethoxy-2,3-difluoro-6-trifluoro-methylbenzamidine], 149-F1 [2,3-
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

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Difluoro-6-trifluoromethylbenzamidine], 149-F11 [(Z)-N-(α-Cyclopropylmethoxyimino2,3-difluoro-6-trifluoromethylbenzyl)carbamoyl acetic acid], and 149-F6 [2,3-Difluoro-6-

trifluoromethyl-benzamide]. These compounds are referred to collectively as total toxic 

cyflufenamid residues. 

Surface Water: Tier II EDWCs in surface water resulting from the proposed uses of 

cyflufenamid on cucurbit vegetables, low growing berries, pome fruit, outdoor landscape 

and outdoor nursery ornamentals, and small fruit vines are calculated using PRZM 

(Pesticide Root Zone Model) and EXAMS (Exposure Analysis Modeling System,) models.

Cyflufenamid applications to North Carolina apples provide the most conservative Tier II 

EDWCs for total toxic residues. Since the petitioner voluntarily withdrew the use on 

cranberries, the drinking water assessment conducted for cranberries was not included.

Tier II EDWCs for total toxic cyflufenamid residues on North Carolina apples are not 

expected to exceed 1.14 μg/L for the 1 in 10 year peak concentration, 0.03 μg/L for the 1 in 

10 year annual average concentration, and 0.01 μg/L for the 30 year annual average, as 

summarized in Table 2. 

Table 2: Tier II PCA Corrected Surface Water EDWCs of Total Toxic Cyflufenamid Residues From the 

Proposed New Uses on Cucurbit Vegetables, Low Growing Berries, Ornamentals, Pome Fruit, and Small 

Climbing Fruit Vines and Tier I Surface Water EDWCs of Total Toxic Cyflufenamid Residues From the

Proposed Use on Cranberry.

Crop Scenario 

[application date (DD/MM)]

Peak EDWC

μg/L 

(ppb)

Yearly Mean μg/L1

(ppb)

Average of Yearly 

Means 1

(ppb)

Pome Fruit Tier II: NC Apples (01/08) 1.14 0.03 0.01

Ground Water: Tier I groundwater EDWCs are estimated using SCI-GROW (Screening 

Concentration in Groundwater) for the proposed cyflufenamid uses. Cyflufenamid 

application to low growing berries, ornamentals, pome fruits, and small fruit vines are not 

expected to result in groundwater concentrations > 4.68 μg/L for total toxic residues as 

shown in Table 3. Applications to cucurbit vegetables are expected to be lower than the 

aforementioned uses. 

Table 3: Tier I Groundwater EDWCs for Total Toxic Cyflufenamid Residues From the Proposed

New Uses on Cucurbit Vegetables, Low Growing Berries, Ornamentals, Pome Fruit, and Small

Climbing Fruit Vines.

Crop Peak

(ug/L)

Cucurbit Vegetables 2.34

Low Growing Berry,

Ornamentals,

Pome Fruit, and

Small Climbing Fruit Vine

4.681

1

Bold font indicates highest value

IV. DEEM-FCIDTM Program and Consumption Information

Cyflufenamid chronic dietary exposure assessment was conducted using the DEEMFCIDTM version 2.03 modeling software. It uses food consumption data from the U.S. 
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

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Department of Agriculture (USDA) CSFII 1994-1996 and 1998 food intake surveys. The 

1994-96, 98 data are based on the reported consumption of more than 20,000 individuals 

over two non-consecutive survey days. Foods “as consumed” (e.g., apple pie) are linked to 

EPA-defined food commodities (e.g. apples, peeled fruit - cooked; fresh or N/S; baked; or 

wheat flour - cooked; fresh or N/S, baked) using publicly available recipe translation files 

developed jointly by USDA/ARS and EPA. For chronic exposure assessment, 

consumption data are averaged for the entire U.S. population and within population 

subgroups. Based on analysis of the 1994-96, 98 CSFII consumption data, which took into 

account dietary patterns of survey respondents, HED concluded that it is most appropriate 

to report risk for the following population subgroups: the general U.S. population, all 

infants (<1 year old), children 1-2, children 3-5, children 6-12, youth 13-19, adults 20-49, 

females 13-49, and adults 50+ years old.

For chronic dietary exposure assessments, an estimate of the residue level in each food or 

food-form (e.g., orange or orange juice) on the food commodity residue list is multiplied by 

the average daily consumption estimate for that food/food form to produce a residue intake 

estimate. The resulting residue intake estimate for each food/food form is summed with the 

residue intake estimates for all other food/food forms on the commodity residue list to 

arrive at the total average estimated exposure. Exposure is expressed in mg/kg body 

weight/day and as a percent of the cRfD. This procedure is performed for each population 

subgroup.

For acute exposure assessments, individual one-day food consumption data are used on an 

individual-by-individual basis. The reported consumption amounts of each food item can 

be multiplied by a residue point estimate and summed to obtain a total daily pesticide 

exposure for a deterministic exposure assessment, or “matched” in multiple random 

pairings with residue values and then summed in a probabilistic assessment. The resulting 

distribution of exposures is expressed as a percentage of the aPAD on both a user (i.e., only 

those who reported eating relevant commodities/food forms) and a per-capita (i.e., those 

who reported eating the relevant commodities as well as those who did not) basis. In 

accordance with HED policy, per capita exposure and risk are reported for all tiers of 

analysis. However, for tiers 1 and 2, any significant differences in user vs. per capita 

exposure and risk are specifically identified and noted in the risk assessment.

V. Toxicological Information

HED evaluated the toxicology database for cyflufenamid and established the chronic 

reference dose on 05/19/2010. To provide an overview of the toxicological profile, a

summary of the doses and endpoints selected for the relevant dietary exposure scenarios are 

provided in Table 4.
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

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Table 4. Summary of Toxicological Doses and Endpoints for Cyflufenamid for Use in Dietary Human Health 

Risk Assessments.

Exposure/

Scenario

Point of 

Departure

Uncertainty/FQPA 

Safety Factors

RfD, PAD, 

Level of 

Concern for 

Risk 

Assessment

Study and Toxicological Effects

Acute Dietary 

(General 

Population, 

including 

Infants and 

Children)

N/A

No hazard was identified. 

No observed effects were attributable to 

a single dose.

Acute Dietary

(Females 13-

49 years of 

age)

N/A

No hazard was identified. 

No observed effects were attributable to 

a single dose.

Chronic 

Dietary (All 

Populations)

NOAEL= 

4.4 

mg/kg/day

UFA= 10x

UFH= 10x

FQPA SF= 1x

Chronic RfD 

= 0.044 

mg/kg/day

cPAD = 

0.044 

mg/kg/day

Combined Chronic Toxicity/ 

Carcinogenicity Study in Rats

LOAEL = 22 mg/kg/day based on 

decreased body weight gain; increased 

thyroid/parathyroid weight, increased 

liver weight and centrilobular 

hepatocytic hypertrophy.

Cancer (oral, 

dermal, 

inhalation)

Classification: Likely to be carcinogenic to humans

Q1* = 6.61 x 10-3 (mg/kg/day)-1

UF = uncertainty factor, UFA = extrapolation from animal to human (interspecies). UFH = potential variation 

in sensitivity among members of the human population (intraspecies). FQPA SF = Special FQPA safety 

factor, NOAEL = no observed adverse effect level, LOAEL = lowest observed adverse effect level, cPAD = 

chronic population adjusted dose, Rfd = reference dose, N/A = not applicable.

VI. Results/Discussion 

As stated above, for chronic assessments, HED is concerned when dietary risk exceeds 

100% of the PAD. The DEEM-FCIDTM analyses estimate the dietary exposure of the U.S. 

population and various population subgroups. The results reported in Table 5 are for the 

general U.S. Population, all infants (<1 year old), children 1-2, children 3-5, children 6-12, 

youth 13-19, females 13-49, adults 20-49, and adults 50+ years. 

Results of Chronic Dietary (Food and Drinking Water) Exposure Analysis

Chronic dietary risk analyses were conducted with the DEEM-FCIDTM model to form a

partially refined evaluation of exposure for cyflufenamid. All chronic analyses yielded risk 

estimates well below the 100% of the cPAD threshold level of concern for each population 

subgroup. For the general U.S. population, chronic aggregate dietary risk was calculated at 

<1% of the cPAD with an exposure level of 0.000144 mg/kg/day. For the subgroup with 

the highest calculated exposure, all infants (< 1 year old), chronic aggregate dietary risk 

occupied 1% of the cPAD with an exposure of 0.000423 mg/kg/day. The cancer dietary 

(food and drinking water) exposure estimate for the general U.S. population is 9.51 x 10-7

,

which is below HED’s level of concern. An overview summarizing the results of the 
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

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chronic dietary assessment, with the population subgroup having the highest exposure 

being noted in bold, is presented in Table 5.

Table 5. Summary of Dietary (Food and Drinking Water) Exposure and Risk for Cyflufenamid.

Population Subgroup

cPAD 

(mg/kg/day)

Chronic Dietary Cancer

Dietary 

Exposure 

(mg/kg/day)

% 

cPAD

Dietary 

Exposure

(mg/kg/day)

Risk

Q* = 6.61 x 10-3

General U.S. Population 0.2 0.000144 <1 0.000144 9.51 x 10-7

All Infants (< 1 year old) 0.2 0.0004231 1

NA2 NA

Children 1-2 years old 0.2 0.000330 <1

Children 3-5 years old 0.2 0.000271 <1

Children 6-12 years old 0.2 0.000157 <1

Youth 13-19 years old 0.2 0.000097 <1

Adults 20-49 years old 0.2 0.000121 <1

Adults 50+ years old 0.2 0.000136 <1

Females 13-49 years old 0.2 0.000123 <1

1

The population subgroup with the highest estimated chronic dietary (food + drinking water) exposure and 

risk is indicated by bold text.

2

NA = not applicable

VII. Characterization of Inputs/Outputs

The chronic dietary assessment for cyflufenamid is a partially refined analysis. The

analysis assumed average field trial residues, default/empirical processing factors (apples 

and grapes), 100% crop treated, and conservative EDWCs derived through EFED modeling 

which are unlikely to underestimate the concentration of cyflufenamid in drinking water

were utilized. (Refinements were made to upper bound exposure estimates specifically for 

use in the cancer assessment). For these reasons, it can be concluded that the DEEMFCIDTM analysis does not underestimate risk from chronic exposure to cyflufenamid for the 

general U.S. population and all its subgroups. Additional refinements may include %CT 

estimates and processing factors; however, the refinements are not necessary at this time. 

VIII. Conclusions

The partially refined chronic dietary risk assessment indicates that exposures to 

cyflufenamid are below HED’s level of concern. The non-cancer chronic dietary (food and 

drinking water) exposure estimates are <1% of the cPAD for the general U.S. population 

and was 1% to all infants (< 1 year old), the most highly exposed population subgroup. All 

other subgroups showed estimates <1% of the cPAD.

The cancer dietary (food and drinking water) exposure estimate for the general U.S. 
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

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population is 9.51 x 10-7, which is below HED’s level of concern. Therefore, HED is not 

concerned that the proposed new uses of cyflufenamid could result in unacceptable risk 

through the potential chronic dietary exposure from food and water sources. 

IX. List of Attachments

Attachment 1. Cyflufenamid Chronic/Cancer Dietary Analysis Input File - Food & Water.

Attachment 2. Cyflufenamid Chronic Dietary Analysis Results - Food & Water.

Attachment 3. Cyflufenamid Cancer Dietary Analysis Results - Food & Water
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

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Attachment 1. Cyflufenamid Chronic/Cancer Dietary Analysis Input File - Food & 

Water.

U.S. Environmental Protection Agency Ver. 2.00

DEEM-FCID Chronic analysis for CYFLUFENAMID 1994-98 data

Residue file: C:\Documents and Settings\MNEGUSSI\My 

Documents\DEEMFCID\Cyflufenamid\CancerCyflufenamid_avggroundwater.R98

 Adjust. #2 NOT used

Analysis Date 07-20-2010 Residue file dated: 07-20-2010/09:32:48/8

Reference dose (RfD) = 0.044 mg/kg bw/day

Comment:cancer; ground water; avg, Cucrbit Vegetables (9), Avf apple/grape inc PF Pome 

Fruits (11), Small Fruit Vine ex fuzzy kiwi (13-07F), Low Growing Berries (13-G)

--------------------------------------------------------------------------------

Food Crop Residue Adj.Factors Comment

EPA Code Grp Food Name (ppm) 

 #1 #2 

-------- ---- ------------------------------- ---------- ------ ------ -------

11000070 11 Apple, fruit with peel 0.014000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11000080 11 Apple, peeled fruit 0.014000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11000081 11 Apple, peeled fruit-babyfood 0.014000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11000090 11 Apple, dried 0.014000 8.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11000091 11 Apple, dried-babyfood 0.014000 8.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11000100 11 Apple, juice 0.014000 0.300 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11000101 11 Apple, juice-babyfood 0.014000 0.300 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11000110 11 Apple, sauce 0.014000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11000111 11 Apple, sauce-babyfood 0.014000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

09020210 9B Balsam pear 0.014000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

13020570 13B Blueberry 0.072000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620818

13020571 13B Blueberry-babyfood 0.072000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620818

09010750 9A Cantaloupe 0.016000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

09010800 9A Casaba 0.016000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

09020880 9B Chayote, fruit 0.022000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

09021020 9B Chinese waxgourd 0.014000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

11001290 11 Crabapple 0.014000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

09021350 9B Cucumber 0.014000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

95001750 O Grape 0.037000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47620817

95001760 O Grape, juice 0.037000 0.200 1.000 AVG FT

 Full comment: AVG FT MRID 47620817

95001761 O Grape, juice-babyfood 0.037000 0.200 1.000 AVG FT

 Full comment: AVG FT MRID 47620817

95001770 O Grape, leaves 0.037000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47620817

95001780 O Grape, raisin 0.300000 1.000 1.000 FT MRI

 Full comment: FT MRID 47620817

95001790 O Grape, wine and sherry 0.037000 1.000 1.000 FT MRI

 Full comment: FT MRID 47620817

09011870 9A Honeydew melon 0.016000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816
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11002100 11 Loquat 0.024000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11002660 11 Pear 0.024000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11002661 11 Pear-babyfood 0.024000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11002670 11 Pear, dried 0.024000 6.250 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11002680 11 Pear, juice 0.024000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

11002681 11 Pear, juice-babyfood 0.024000 1.000 1.000 AVG FT

 Full comment: AVG FT MRID 47638213

09023080 9B Pumpkin 0.022000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

09023090 9B Pumpkin, seed 0.022000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

11003100 11 Quince 0.024000 1.000 1.000 

09023560 9B Squash, summer 0.022000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

09023561 9B Squash, summer-babyfood 0.022000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

09023570 9B Squash, winter 0.022000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

09023571 9B Squash, winter-babyfood 0.022000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

95003590 O Strawberry 0.072000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620818

95003591 O Strawberry-babyfood 0.072000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620818

95003600 O Strawberry, juice 0.072000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620818

95003601 O Strawberry, juice-babyfood 0.072000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620818

86010000 O Water, direct, all sources 0.004680 1.000 1.000 

86020000 O Water, indirect, all sources 0.004680 1.000 1.000 

09013990 9A Watermelon 0.016000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816

09014000 9A Watermelon, juice 0.016000 1.000 1.000 AVG MR

 Full comment: AVG MRID 47620816
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

PC Code: 555550

______________________________________________________________________________________

Page 12 of 13

Attachment 2. Cyflufenamid Chronic Dietary Analysis Results File - Food & 

Water.

U.S. Environmental Protection Agency Ver. 2.00

DEEM-FCID Chronic analysis for CYFLUFENAMID (1994-98 data)

Residue file name: C:\Documents and Settings\MNEGUSSI\My 

Documents\DEEMFCID\Cyflufenamid\CancerCyflufenamid_avggroundwater.R98

 Adjustment factor #2 NOT used.

Analysis Date 07-20-2010/09:42:00 Residue file dated: 07-20-2010/09:32:48/8

Reference dose (RfD, Chronic) = .044 mg/kg bw/day

COMMENT 1: cancer; ground water; avg, Cucrbit Vegetables (9), Avf apple/grape inc PF 

Pome Fruits (11), Small Fruit Vine ex fuzzy kiwi (13-07F), Low Growing Berries (13-G)

===============================================================================

 Total exposure by population subgroup

-------------------------------------------------------------------------------

 Total Exposure

 -----------------------------------

 Population mg/kg Percent of 

 Subgroup body wt/day Rfd 

-------------------------------------- ------------- ---------------

U.S. Population (total) 0.000144 0.3%

U.S. Population (spring season) 0.000146 0.3%

U.S. Population (summer season) 0.000158 0.4%

U.S. Population (autumn season) 0.000137 0.3%

U.S. Population (winter season) 0.000136 0.3%

Northeast region 0.000140 0.3%

Midwest region 0.000145 0.3%

Southern region 0.000132 0.3%

Western region 0.000167 0.4%

Hispanics 0.000152 0.3%

Non-hispanic whites 0.000145 0.3%

Non-hispanic blacks 0.000125 0.3%

Non-hisp/non-white/non-black 0.000170 0.4%

All infants (< 1 year) 0.000423 1.0%

Nursing infants 0.000184 0.4%

Non-nursing infants 0.000514 1.2%

Children 1-6 yrs 0.000281 0.6%

Children 7-12 yrs 0.000148 0.3%

Females 13-19 (not preg or nursing) 0.000095 0.2%

Females 20+ (not preg or nursing) 0.000134 0.3%

Females 13-50 yrs 0.000129 0.3%

Females 13+ (preg/not nursing) 0.000132 0.3%

Females 13+ (nursing) 0.000190 0.4%

Males 13-19 yrs 0.000099 0.2%

Males 20+ yrs 0.000117 0.3%

Seniors 55+ 0.000137 0.3%

Children 1-2 yrs 0.000330 0.8%

Children 3-5 yrs 0.000271 0.6%

Children 6-12 yrs 0.000157 0.4%

Youth 13-19 yrs 0.000097 0.2%

Adults 20-49 yrs 0.000121 0.3%

Adults 50+ yrs 0.000136 0.3%

Females 13-49 yrs 0.000123 0.3%

-------------------------------------------------------------------------------
Cyflufenamid Dietary Exposure and Risk Assessment DP Number: 364559

PC Code: 555550

______________________________________________________________________________________

Page 13 of 13

Attachment 3. Cyflufenamid Cancer Dietary Analysis Results File - Food & 

Water. U.S. Environmental Protection Agency Ver. 2.00

DEEM-FCID Chronic analysis for CYFLUFENAMID (1994-98 data)

Residue file name: C:\Documents and Settings\MNEGUSSI\My 

Documents\DEEMFCID\Cyflufenamid\CancerCyflufenamid_avggroundwater.R98

 Adjustment factor #2 NOT used.

Analysis Date 07-20-2010/09:34:05 Residue file dated: 07-20-2010/09:32:48/8

Q* = 0.0066 

COMMENT 1: cancer; ground water; avg, Cucrbit Vegetables (9), Avf apple/grape inc PF 

Pome Fruits (11), Small Fruit Vine ex fuzzy kiwi (13-07F), Low Growing Berries (13-G)

===============================================================================

 Total exposure by population subgroup

-------------------------------------------------------------------------------

 Total Exposure

 -----------------------------------

 Population mg/kg Lifetime risk

 Subgroup body wt/day (Q*= .0066)

-------------------------------------- ------------- -------------

U.S. Population (total) 0.000144 9.51E-07