i

EPA REGISTRATION DIVISION COMPANY NOTICE OF FILING FOR 

PESTICIDE PETITIONS PUBLISHED IN THE FEDERAL REGISTER 

EPA Registration Division contact: [James A. Tompkins. 703-305-5697] 

INSTRUCTIONS: Please utilize this outline in preparing the pesticide petition. In 

cases where the outline element does not apply, please insert “NA-Remove” and 

maintain the outline. Please do not change the margins, font, or format in your 

pesticide petition. Simply replace the instructions that appear in green, i.e., “[insert 

company name],” with the information specific to your action.

TEMPLATE: 

[ Monsanto Company]

[9F7644]

 EPA has received a pesticide petition ([9F7644]) from [Monsanto Company], 

[1300 I St., NW., Suite 450 East, Washington DC 20052] proposing, pursuant to 

section 408(d) of the Federal Food, Drug, and Cosmetic Act (FFDCA), 21 U.S.C. 

346a(d), to amend 40 CFR part 180.364

(Options (pick one)

 1. by establishing a tolerance for residues of 

 2. to establish an exemption from the requirement of a tolerance for NA-Remove

 [glyphosate N-(phosphonomethyl) glycine] in or on the raw agricultural 

commodity [corn, sweet, forage] at [9] parts per million (ppm). [In addition, PP 

9F7644 requests revision of the glyphosate tolerance in or on the raw agricultural 

commodity corn, sweet, kernels plus cob with husks removed at 3 ppm and 

correction of the glyphosate tolerance in the commodity poultry, meat from 4 ppm 

to 0.1 ppm.] EPA has determined that the petition contains data or information regarding 

the elements set forth in section 408 (d)(2) of FDDCA; however, EPA has not fully 

evaluated the sufficiency of the submitted data at this time or whether the data supports 

granting of the petition. Additional data may be needed before EPA rules on the petition. 

A. Residue Chemistry

 1. Plant metabolism. [The qualitative nature of glyphosate residues in plants 

and livestock is adequately understood. The terminal residue to be regulated in 

nontransgenic plants and transgenic crops modified to express the Agrobacterium 

sp. EPSPS and oxireductase genes is glyphosate per se. For crops (currently 
2

soybeans and corn) that have a transgenic variety engineered to express the 

microbial glyphosate acetyltransferase gene (gat4601), the combined residues to be 

regulated are glyphosate and N-acetyl-glyphosate. The qualitative nature of the 

glyphosate residue will not be changed as a result of the proposed tolerance changes. 

Glyphosate herbicides are not applied directly to livestock, so the only potential 

exposure is via glyphosate residues in their diet. On December 3, 2008, EPA 

published a final rule (EPA-HQ-OPP-2007-0147; FRL-8385-7) amending section 

180.364 to reflect that the terminal residue to be regulated in livestock (and in 

soybean commodities and grain aspirated fractions) is glyphosate and its metabolite 

N -acetyl-glyphosate, expressed as glyphosate.]

 2. Analytical method. [Adequate enforcement methods are available for 

analysis of residues of glyphosate and its metabolite AMPA in or on plant and 

livestock commodities. These methods include gas liquid chromatography (GLC), 

Method I in Pesticides Analytical Manual (PAM) II (0.05 ppm limit of detection), 

and High Performance Liquid Chromatography (HPLC) with fluorometric 

detection (0.0005 ppm limit of detection). Use of the GLC method is discouraged due 

to the lengthiness of the experimental procedure. The HPLC procedure has 

undergone successful Agency validation and was recommended for inclusion in 

PAM II. A gas chromatography/mass spectrometry (GC/MS) method for glyphosate 

in crops has also been validated by EPA’s Analytical Chemistry Laboratory (ACL). 

Thus, adequate analytical methods are available for residue data collection and 

enforcement of the proposed tolerances for glyphosate.]

 3. Magnitude of residues. [Residue data submitted with this petition support 

the proposed tolerances for the agricultural commodities corn, sweet, forage at 9 

ppm and corn, sweet, kernel plus cob with husks removed at 3 ppm. Any 

secondary residues occurring in livestock commodities will be covered by existing 

tolerances. Currently available residue data support the proposed revision of the 

tolerance for glyphosate in the agricultural commodity poultry, meat.]

B. Toxicological Profile

[The existing toxicity database for glyphosate is complete and without data gaps. 

There is high confidence in the quality of the existing studies and the reliability of 

the toxicity endpoints identified for use in risk assessment. EPA has considered 

available information regarding the variability of the sensitivities of major 

identifiable subgroups of consumers, including infants and children. 

 1. Acute toxicity. [The nature of the acute toxic effects caused by glyphosate 

has been evaluated by the Agency. Glyphosate is of low acute toxicity by oral, 

dermal, and ocular routes of exposure, as all studies are in Toxicity Category III or 

IV. Acute oral toxicity of glyphosate in the rat and dermal toxicity in the rabbit are 

both greater than 5000 mg/kg (Toxicity Category IV) and any corneal opacity or 

irritation caused by glyphosate is temporary and clears up in 7 or less days (Toxicity 

Category III). Glyphosate is a mild skin irritant (Toxicity Category IV) and is not a 

dermal sensitizer. The acute inhalation study for glyphosate was waived due to 

glyphosate being a nonvolatile solid. An acute dietary endpoint for use in human 
3

health risk assessments was not selected for the general population, since an 

appropriate endpoint attributable to a single exposure was not identified in the 

toxicology data base. 

Table 1 Acute Toxicity Profile - Test Substance 

Guideline 

No. Study Type MRID(s) Results Toxicity Category

870.1100 Acute oral 41400601 LD50 > 5,000 mg/kg IV 

870.1200 Acute dermal 41400602 LD50 > 5,000 mg/kg IV 

870.1300 Acute inhalation None 

The requirement for an 

acute inhalation LC50

study was waived 

None 

870.2400 Acute eye irritation 41400603 

Corneal opacity or 

irritation clearing in 7 

days or less 

III 

870.2500 Acute dermal irritation 41400604 Mild or slight irritant IV 

870.2600 Skin sensitization 00137138 Not a sensitizer None 

] 

 2. Genotoxicity. [In vitro and in vivo genotoxicity studies have been conducted 

with glyphosate. Short term assays for genotoxicity consisting of a bacterial reverse 

mutation assay (Ames test), an in vitro assay for cytogenetic damage using Chinese 

hamster ovary cells, and in vivo cytogenic assay in rat bone marrow have been 

conducted on glyphosate. These studies all show a lack of genotoxicity.

Table 2 Genotoxicity Profile 

Guideline No./ Study 

Type

Results

Gene Mutation 

870.5265 

Non-mutagenic when tested up to 1000 ug/plate, in presence and 

absence of activation in S. typhimurium strains TA98, TA100, 

TA1535 and TA1537. 

Gene Mutation 

870.5300 

Non-mutagenic at the HGPRT locus in Chinese hamster ovary cells 

tested up to cytotoxic concentrations or limit of solubility, in 

presence and absence of activation. 

In Vivo Cytogenetics - 

Bone Marrow 870.5385 

Non-mutagenic in rat bone marrow chromosome assay up to 1000 

mg/kg in both sexes of Sprague Dawley rats. 
4

870.5550 

 Rec - Assay and Gene 

Mutation Assay 

There was no evidence of recombination in the rec-assay up to 

2,000 ug/disk with B. subtilis H17 (rec+) and M45 (rec-). Negative 

for reverse gene mutation, both with and without S-9, up to 5,000 

ug/plate (or cytotoxicity) with E.coli SP2hcrA and S. typhimuarium

TA98, TA100, TA1535, TA1537, and TA1538. 

]

 3. Reproductive and developmental toxicity. [Developmental studies in rats and 

rabbits were conducted with glyphosate. In rabbits, a maternal NOAEL of 175 

mg/kg/day was determined based on mortality, diarrhea, and nasal discharge at the 

LOAEL of 350 mg/kg/day. This was the lowest NOAEL of all major studies. The 

developmental NOAEL was 350 mg/kg/day (HDT). 

In rats, developmental effects of unossified sternebrae and decreased fetal body 

weight were observed at a LOAEL of 3500 mg/kg/day (HDT) which was also the 

LOAEL for maternal toxicity. The maternal NOAEL was 1,000 mg/kg/day based 

on mortality, decreased body weight gain, inactivity, red matting on nose, mouth, 

forelimbs, and head, decrease in total implantations/dam and nonviable 

fetuses/dam. The developmental NOAEL in rats was 1000 mg/kg/day. 

No reproductive effects were observed in the multigeneration study and in the 2-

generation rat reproduction study, the offspring and parental NOAELs were 500 

mg/kg/day based on decreased pup body weight during lactation (offspring) and soft 

stools, decreased body weight and food consumption (parents) at the LOAEL of 

1500 mg/kg/day. The reproductive NOAEL was greater than or equal to 1500 

mg/kg/day (HDT). 

In developmental studies in rats and rabbits and reproductive findings in rates, 

developmental effects were only observed at maternally toxic doses. There was no 

evidence of any increased susceptibility of the young to the effects of glyphosate in 

developmental and reproductive toxicity studies in rats or rabbits. 

A developmental neurotoxicity study was not required. 

Table 3 Reproductive and Developmental Toxicity Profile

Guideline No./ Study 

Type

Results

870.3700a 

Prenatal developmental 

in rodents (Rat) 

Maternal NOAEL = 1000 mg/kg/day 

LOAEL = 3500 mg/kg/day based on reduced activity, mortality, 

and reduced body weight gain. 

Developmental NOAEL = 1000 mg/kg/day 

LOAEL = 3500 mg/kg/day based on increased incidence in the 

number of fetuses and litters with unossified sternebrae and 

decreased fetal body weight. 
5

Table 3 Reproductive and Developmental Toxicity Profile

Guideline No./ Study 

Type

Results

870.3700b 

Prenatal developmental 

in (Rabbit) 

Maternal NOAEL = 175 mg/kg/day 

LOAEL = 350 mg/kg/day (HDT) based on mortality, diarrhea, soft 

stools, and nasal discharge. 

Developmental NOAEL = 350 mg/kg/day (HDT) 

LOAEL = not established. 

870.3800 

Reproduction and 

fertility effects, 

2-generation (Rat) 

Parental/Systemic NOAEL = 500 mg/kg/day in males and females 

LOAEL = 1500 mg/kg/day (HDT) in males and females based on 

soft stools, decreased body weight gain and food consumption. 

Reproductive NOAEL ≥ 1500 mg/kg/day (HDT) in males and 

females 

Offspring NOAEL = 500 mg/kg/day (HDT) in males and females 

LOAEL = 1500 mg/kg/day in males and females based on 

decreased body weight gain during lactation. 

] 

 4. Subchronic toxicity. [In rodent feeding studies, glyphosate showed a 

NOAEL of 500 mg/kg/day in a 90-day mouse study and 1445 mg/kg/day (HDT) in a 

90-day rat study. In a 21/28-day rabbit dermal toxicity study the NOAEL was 1000 

mg/kg/day and the LOAEL was 5000 mg/kg/day based on slight erythema and 

edema on intact and abraded skin of both sexes. 

Table 4 Subchronic Toxicity Profile

Guideline No./ Study 

Type

Results

870.3100 

90-Day oral toxicity 

(Mouse) 

NOAEL = 500 mg/kg/day in males and females 

LOAEL = 2500 mg/kg/day (HDT) in males and females based on 

decreased body weight gains. 

870.3100 

90-Day oral toxicity 

(Rat) 

NOAEL = 1445 mg/kg/day (HDT) 

LOAEL = not established 

870.3200 

21/28-Day dermal 

toxicity (Rabbit) 

NOAEL = 1000 mg/kg/day in males and females 

LOAEL = 5000 mg/kg/day based on slight erythema and edema on 

intact and abraded skin of both sexes. 

]

 5. Chronic toxicity. [A chronic toxicity study in dogs showed no systemic 

effects found for all examined parameters in males and females at the highest dose 

tested, 500 mg/kg/day. Chronic feeding/carcinogenicity studies have been conducted 
6

in rodents with glyphosate and results show no evidence of carcinogenicity in mice 

or rats. In the mouse, a NOAEL of 750 mg/kg/day in males and females was 

established based on significant decreased body weight gain in both sexes and 

hepatocyte necrosis in males at the LOAEL of 4500 mg/kg/day. In the rat, a 

NOAEL of 362 mg/kg/day in males and 447 mg/kg/day in females based on 

decreased body weight gain in females and increased incidence of cataracts and lens 

abnormalities in males at te LOAEL of 940 mg/kg/day in males and 1183 mg/kg/day 

in females. Glyphosate has been classified as “a Group E” carcinogen—no evidence 

of carcinogenicity to humans—based on the absence of carcinogenicity in mice and 

rats. 

Table 5 Chronic Toxicity Profile

Guideline No./ Study 

Type

Results

870.4100b 

Chronic toxicity (dog) 

NOAEL = > 500 mg/kg/day in males and females (HDT) 

LOAEL = not established. 

870.4300 

Carcinogenicity 

(Mice) 

NOAEL = 750 mg/kg/day in males and females 

LOAEL = 4500 mg/kg/day in males and females based on 

significant decreased body weight gain in both sexes and 

hepatocyte necrosis in females. 

No evidence of carcinogenicity

870.4300 

Chronic/Carcinogenicity (Rat) 

NOAEL = 362 mg/kg/day in males, 447 mg/kg/day in females 

LOAEL = 940 mg/kg/day in males, 1183 mg/kg/day in females 

based on decreased body weight gain in females, increased 

incidence of cataracts and lens abnormalities in males. 

No evidence of carcinogenicity

]

 6. Animal metabolism. [In the rat metabolism study, absorption was estimated 

to be 30-36% in males and females. Glyphosate was excreted unchanged in the feces 

and urine (97.5% minimum). The only metabolite present in the excreta was small 

amounts of AMPA. Less than 1% of the absorbed dose remained in the carcass, 

primarily the bone. Repeated dosing did not alter metabolism, distribution, and 

excretion.]

 7. Metabolite toxicology. [The residue of concern for risk assessment purposes 

is glyphosate per se. The metabolite AMPA is not included in either the tolerance 

expression or the risk assessment. In a meeting of the HED Metabolism Committee 

held 8/19/92, the Committee determined that, based on toxicological considerations, 

AMPA need not be regulated and should be dropped from the tolerance expression 

(Memo, R. Perfetti, 10/10/92). Furthermore, in a meeting of the HED Metabolism 

Committee held 3/17/94, the Committee discussed whether uses that result in 

significantly higher residues of AMPA in plants and livestock commodities in the 

future would require that AMPA be reintroduced into the tolerance expression of 
7

glyphosate. The Committee determined that, based on toxicological considerations, 

AMPA need not be regulated regardless of levels observed in foods or feeds (Memo, 

R. Perfetti, 3/17/94).] 

 8. Endocrine disruption. [EPA is required under the FFDCA, as amended by 

FQPA, to develop a screening program to determine whether certain substances 

(including all pesticide active and other ingredients) “may have an effect in humans 

that is similar to an effect produced by a naturally occurring estrogen, or other such 

endocrine effects as the Administrator may designate.” Following recommendations 

of its Endocrine Disruptor and Testing Advisory Committee (EDSTAC), EPA 

determined that there was a scientific basis for including, as part of the program, 

the androgen and thyroid hormone systems, in addition to the estrogen hormone 

system. EPA also adopted EDSTAC’s recommendation that the Program also 

include evaluations of potential effects in wildlife. 

Glyphosate is on the EPA list of the initial 67 pesticide active ingredients and 

pesticide inert high production volume chemicals to be screened under the first 

phase of EPA’s Endocrine Disruption Screening Program (EDSP). This is not a list 

of “endocrine disruptors” or “potential endocrine disruptors;” it is simply a list of 

chemicals to be the first to go through EPA’s evaluation process. The process that 

EPA used to prioritize substances for screening did not include a determination of 

potential endocrine activity of any of the substances, but rather the potential for 

exposure. Glyphosate, a widely-used herbicide with multiple uses, was included on 

this list of initial active ingredients to be tested because it met the exposure criteria. 

Test orders are expected to be issued for glyphosate in January of 2010. 

Glyphosate has undergone extensive testing, including a battery of acute, subchronic, and chronic tests, and a number of developmental and reproductive 

studies, mammalian and wildlife, capable of detecting effects on endocrine mediated 

events. The results from these studies, along with other scientifically relevant 

information, provide reliable and functionally equivalent information to the Tier 1 

screening assays and demonstrate that glyphosate is not an endocrine active 

substance.] 

C. Aggregate Exposure

[Aggregate exposure for glyphosate is the combination of chronic dietary exposure 

(food + drinking water) and short- and intermediate-term non-dietary oral exposure 

from residential (home lawn care) and recreational (golf, swimming) use exposure.] 

 1. Dietary exposure. [Tolerances have been established 

(40CFR 180.364) for the residues of glyphosate N-(phosphonomethyl) glycine 

resulting from the application of glyphosate, the isopropylamine salt of glyphosate, 

the ethanolamine salt of glyphosate, the dimethylamine salt of glyphosate, the 

ammonium salt of glyphosate, and the potassium salt of glyphosate in or on a 

variety of raw agricultural commodities, including meat and meat by-products. The 

dietary-exposure database is adequate to support the existing registrations. Chronic 

dietary risk assessments incorporate concentration estimates from the direct 
8

application of glyphosate to water, which represents a worst-case scenario, as the 

drinking water component of the assessment. 

The petitioner proposes to establish a tolerance for corn, sweet, forage at 9 ppm and 

to increase the tolerance for corn, sweet, kernels plus cob with husks removed from 

the present level of 0.1 ppm to 3.0 ppm. The proposed tolerance revision is not 

expected to increase the dietary burden for livestock; the existing tolerances for 

livestock commodities are sufficient.]

 i. Food. [No toxicological endpoint attributable to a single does of glyphosate 

has been identified; therefore, a quantitative acute dietary exposure assessment is 

not necessary. 

A dietary risk assessment was conducted by Monsanto using the Dietary Exposure 

Evaluation Model software (DEEM-FCIDTM), Version 2.16, which incorporates food 

consumption data from the United States Department of Agriculture (USDA) 1994-

1996 and 1998 Nationwide Continuing Surveys of Food Intakes by Individuals 

(CSFII). A conservative estimate of dietary exposure (Tier 1) was performed with 

the assumptions that 100% of crops with approved and proposed uses of glyphosate 

would be treated and that glyphosate residues would be present in each raw 

agricultural commodity at the tolerance level. Under these conservative 

assumptions and based on a chronic population adjusted dose (cPAD) for 

glyphosate of 1.75 mg/kg/day, the chronic dietary exposure estimates to glyphosate 

from food and drinking water is 5% of the cPAD for the general U.S. population. 

The chronic dietary exposure estimate for the most highly exposed subpopulation 

(children 1-2 years old) is 12% of the cPAD. 

Glyphosate is classified as a not likely human carcinogen, so a cancer dietary 

exposure analysis was not performed.] 

 ii. Drinking water. [The Agency lacks sufficient monitoring exposure data to 

complete a comprehensive dietary exposure analysis and risk assessment for 

glyphosate in drinking water. Because the Agency does not have comprehensive 

monitoring data, drinking water concentration estimates are made by reliance on 

simulation or modeling taking into account data on the physical characteristics of 

glyphosate. Further information regarding EPA drinking water models used in 

pesticide exposure assessment can be found at 

http://www.epa.gov/oppefed1/models/index.htm. 

Glyphosate is registered for aquatic use to control weeds in bodies of water. 

Therefore, the Agency estimated the concentration in surface water resulting from 

direct application of the maximum single application rate of 3.75 pounds of 

glyphosate free acid per acre to a water body 6 feet deep. Based on this maximum 

application rate, the estimated concentration for use in the drinking water 

assessment is 230 μg/L (ppb). This estimate is based on a dilution model that does 

not take into account degradation in the water body and partitioning into the water 
9

column-sediment phases. 

Based on the generic expected environmental concentration (GENEEC) and 

screening concentration in groundwater (SCI-GROW) models, the estimated 

environmental concentrations (EEC’s) of glyphosate for acute exposures are 

estimated to be 21 ppb for surface water and 0.0038 ppb for ground water. The 

EEC’s for chronic exposures are estimated to be 0.83 ppb for surface water and 

0.0038 ppb for ground water, based on glyphosate treatment in crops.]

 2. Non-dietary exposure. [Glyphosate is registered for broadcast and spot 

treatments on home lawns and gardens, including for turf renovation. Glyphosate 

products for homeowner use are packaged as ready-to-mix formulations and readyto-use sprayers and are very common in home and garden stores in the U.S. 

Glyphosate products are also used by lawn care operators (LCOs) for broadcast and 

spot treatment weed control programs on homeowner lawns. Glyphosate products 

are also registered for weed control in recreational areas, including parks and golf 

courses, and for control of aquatic weeds in lakes, ponds and reservoirs. All 

recreational and residential exposures assessed do not exceed the Agency’s level of 

concern (MOEs <100). 

The term “residential exposure,” as used here, refers to non-occupational nondietary exposure (e.g., for lawn and garden weed control). A risk assessment was 

conducted using the following residential exposure assumptions: Based on the 

registered residential use patterns, there is a potential for short-term dermal and 

inhalation exposures to homeowners who apply products containing glyphosate 

(residential handlers). Additionally, based on the results of environmental fate 

studies, there is also a potential for short- and intermediate-term post-application 

dermal exposures by adults and toddlers and incidental ingestion exposures by 

toddlers. However, since short- and intermediate-term dermal and inhalation 

endpoints were not identified, no residential handler or post-application dermal 

assessment is required. Post-application toddler assessment for incidental ingestion 

exposures was performed; risk estimates ranged from 7,230 to greater than 106

. 

Based on the registered uses of glyphosate in recreational areas and for aquatic 

weed control, adult and child golfers are anticipated to have short-term, postapplication dermal exposure at golf courses and swimmers (adults, children and 

toddlers) are anticipated to have short-term post-application dermal and incidental 

ingestion exposures. However, since HIARC did not select dermal endpoints, no 

post-application dermal assessment is necessary. Post-application incidental 

ingestion exposure assessment was performed for adult, children and toddler 

swimmers; risk estimates ranged from 7,610 to 35,500. 

Spray drift is always a potential source of exposure to residents nearby to spraying 

operations, particularly with aerial application, but, to a lesser extent, could also be 

a potential source of exposure from the ground application method employed for 

glyphosate. The Agency has been working with the Spray Drift Task Force, EPA 
10

Regional Offices and State Lead Agencies for pesticide regulation and other parties 

to develop the best spray drift management practices. ]

D. Cumulative Effects

[Unlike other pesticides for which EPA has followed a cumulative risk approach 

based on a common mechanism of toxicity, EPA has not made a common 

mechanism of toxicity finding as to glyphosate and any other substances, and 

glyphosate does not appear to produce a toxic metabolite produced by other 

substances. For the purposes of this tolerance action, therefore, EPA has not 

assumed that glyphosate has a common mechanism of toxicity with other 

substances. For information regarding EPA’s efforts to determine which chemicals 

have a common mechanism of toxicity and to evaluate the cumulative effects of such 

chemicals, see the final rule for Bifenthrin Pesticide Tolerances (62 FR 62961, 

November 26, 1997).]

E. Safety Determination

 1. U.S. population. [A chronic dietary risk assessment of glyphosate was 

conducted using the current and the proposed new and increased tolerances for 

sweet corn. The Tier 1 chronic dietary analysis for glyphosate is a conservative 

estimate of dietary exposure that uses tolerance level residues and 100% crop 

treated. Under this assumption, exposure to glyphosate from food and water will 

utilize only 5% of the chronic population adjusted dose (cPAD) for the general U.S. 

population. Based on its use pattern, chronic residential and recreational exposure 

to residues of glyphosate is not expected. 

Based on the completeness and reliability of the toxicity data and the conservative 

exposure assessment, it can be concluded that there is a reasonable certainty that no 

harm will result to the general U.S. population from chronic aggregate exposure to 

glyphosate residues.]

 2. Infants and children. [FFCDA Section 408 provides that EPA shall apply an 

additional tenfold margin of safety for infants and children in the case of threshold 

effects to account for prenatal and postnatal toxicity and the completeness of the 

database. EPA has previously evaluated the prenatal and postnatal sensitivity of 

glyphosate and the adequacy of the data base as indicated in the Reregistration 

Eligilibility Decision for glyphosate. There is no evidence of increased susceptibility 

in rats and rabbits to in utero and/or postnatal exposure to glyphosate. EPA has 

concluded that there is a complete toxicity data base for glyphosate and exposure 

data are complete or are estimated based on data that reasonably accounts for all 

potential exposures. EPA determined that the 10X safety factor to protect infants 

and children is not necessary as well as the FQPA. The use of generally high quality 

data, conservative models and/or assumptions in the exposure assessment, provide 

adequate protection of infants and children. 

Chronic dietary exposure to residues of current and proposed new and increased 
11

tolerances for sweet corn is estimated to utilize only 12% of the chronic population 

adjusted dose (cPAD) for children 1-2 years old, which is the population subgroup 

predicted to be most highly exposed. 

Use of glyphosate on turf does present a potential short- and intermediate-term 

exposure for children 1-2 years old. The aggregate MOE for the total short- and 

intermediate-term food and residential aggregate exposure are greater than 100, 

and, therefore, does not exceed the Agency’s level of concern. 

Based on the completeness and reliability of the toxicity data and the conservative 

exposure assessment, it can be concluded that there is a reasonable certainty that no 

harm will result to infants and children from chronic, short- and intermediate-term 

aggregate exposure to glyphosate residues.]

F. International Tolerances

 [The U.S., Mexico, and Codex residue definitions are established and 

harmonized for residues of glyphosate per se, whereas there are discrepancies with 

the Canadian residue definition which includes the combined residues of glyphosate 

and it major metabolite, aminomethylphosphonic acid (AMPA). Canada, Mexico 

and Codex have established MRLs for residues of glyphosate in/on several raw 

agricultural and livestock commodities, but several MRLs are not harmonized with 

U.S. tolerances. Current U.S. tolerance for corn, sweet, grain is 0.1 ppm and the 

Canadian MRL is currently 3 ppm. This petition seeks to harmonize the U.S. 

tolerance with the MRL for this agricultural commodity in Canada. Codex does not 

maintain a specific MRL for sweet corn (corn-on-the-cob or kernels) and the EU has 

an MRL of 0.1 mg/kg set at the lower limit of analytical determination for the 

commodity sweet corn.]