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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON D.C., 20460

OFFICE OF CHEMICAL

SAFETY AND POLLUTION'

PREVENTlON

.

..

PC Code: 129112

DP Barcodes: 413801

MEMORANDUM January 28, 2014

SUBJECT: Trifloxystrobin:Drinking Water Exposure Assessment in Support of a Proposed

New Use on Dry Peas, Chickpeas, and Lentils (Reg. Nos. 264-776 (technical) and

264-1055).

TO: Christine Olinger, Branch Chief

Nancy Tsaur, Chemist

Risk Assessment Branch 3

Health Effects Division (7509P)

Cynthia Giles-Parker, Branch Chief 

Tony Kish, Product Manager 

Dominic Schuler, Reviewer 

Registration Division (7505P)

FROM: Melanie Biscoe, Physical Scientist

Environmental Risk Branch 3

Environmental Fate and Effects Division

THROUGH: DanaSpatz,BranchChief h_ 1/2."11Z.,.lt

Environmental Risk Branch 3 '-

Environmental Fate and Effects Division (7507P)

Executive Summary

This drinking water assessment was conducted in response to Bayer Corporation'srequest to 

register tri:floxystrobin for use on dry peas, chickpeas, and lentils. When considering this 

request, the Environmental Fate and Effects Division (EFED) determined that a currently 

registered use, turf, continues to have the highest annual use rate (1.33 lb a.i./acre) of all the 

proposed and existing uses oftritloxystrobin, and would result in the highest estimated drinking 

water concentrations(EDWCs). This DWA takes into account tri:floxystrobin plus a major
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Drinking water 

source (model)

Model Scenario & 

Application Method

Acute Chronic Cancer

Units: μ/L

Surface Water 1

(PRZM-EXAMS)

Pennsylvania Turf 

scenario

Aerial Application

Peak

1-in-10 Year

Chronic

1-in-10 Year

30-year Annual

Average

29 ppb 23 ppb 19 ppb

Groundwater

(PRZM-GW 30-year 

simulation)

Wisconsin Corn 

scenario

Ground Application

Peak Post-Breakthrough Average 

427 ppb 365 ppb

degradate, CGA-321113, as recommended by the Metabolism Assessment Review Committee

(MARC)

1

using the total toxic residue (TTR) approach.

Surface water and groundwater EDWCs for turf, using the TTR approach, were previously

developed in a 2010 drinking water assessment (D378919).

2 Since the 2010 assessment, EFED 

has implemented the use of the PRZM-GW model to estimate groundwater concentrations. 

Therefore, this assessment relies on surface water EDWCs from the 2010 DWA and presents 

updated Tier I EDWCs for groundwater using the PRZM-GW model. Maximum surface water 

EDWCs from the 2010 DWA and maximum groundwater EDWCs developed for this assessment 

are reported in Table 1.

The Tier I groundwater EDWCs for trifloxystrobin total toxic residues in this assessment are 

greater than the surface water EDWCs from the 2010 DWA. The highest estimated peak 

(acute) concentration of total toxic residues in groundwater is 427 μg/L, and the highest 

estimated (chronic) concentration in groundwater is 365 μg/L (Table 1). EFED 

recommends using these values for the human health dietary risk assessment.

Table 1. Maximum estimated drinking water concentrations(EDWCs) of total toxic residues in 

parts per billion (μg/L) resulting from applications of trifloxystrobin on turf at an annual 

application rate of 1.33 lb a.i./acre

1Drinking Water Assessment for Tolerance Petition for New Uses of Trifloxystrobin in Trifloxystrobin Flowable

Fungicide [EPA Reg. No. 264-989]. D378919.

Background

Trifloxystrobin [E,E)-alpha-(methoxyimino)-2-[[[[1-[3-(trifluoromethyl) phenyl] 

ethylidene]amino]oxy]methyl]-methyl ester] is an active ingredient used in several agricultural 

fungicide products used to control fungal pathogens on various grain, vegetable, fruit, nut crops, 

ornamental plants, and turf. It is used via aerial, chemigation and ground applications, as well as 

in seed treatment. Trifloxystrobin is classified as an oximinoacetate fungicide in the strobilurin 

class.

1 Trifloxystrobin. Results of HED Metabolism Assessment Review Committee Meeting held 6/15/99. DP Barcode

257835. July 13, 1999.

2

Drinking Water Assessment for Tolerance Petition for New Uses of Trifloxystrobin in Trifloxystrobin Flowable

Fungicide [EPA Reg. No. 264-989]. D378919.
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The registrant, Bayer Corporation, requested new uses of trifloxystrobin on dry peas, chickpeas, 

and lentils. The proposed single application rate for these new uses is 12.0 fluid ounces of 

product per acre, or 0.12 lb ai/acre. The maximum annual application rate is 0.24 lb ai/acre. The 

minimum re-application interval for these proposed uses is 10 days.

The currently registered turf use has the highest single and annual application rates of all existing 

aerial, chemigation and ground uses of trifloxystrobin. The turf use has a single application rate 

over two times higher than the proposed new uses on chickpea, dry peas and lentils, and an 

annual application rate more than four times higher than these proposed new uses. It is therefore 

expected that EDWCs calculated for the turf use would be protective of the proposed new uses

on chickpea, dry peas, and lentils. Table 2 provides additional details concerning the proposed 

uses as compared to the turf use.

The turf use was assessed most recently in 2010 using the TTR approach (D378919), which 

considered drinking water exposures of parent trifloxystrobin and its free acid degradate CGA321113. The EDWCs from the 2010 assessment were 29 μg/L (1-in-10-year peak), 23 μg/L (1-

in-10-year annual average), and 19 μg/L (30-year average) for surface water (using PRZMEXAMS), and 5.87 μg/L for groundwater (using SCI-GROW).

3

Table 2. Comparison of Proposed Chickpea, Dry Peas, and Lentils Uses to Existing Turf

Uses.

Use Site Application

Method

Maximum

Single

Application 

Rate

Maximum

Annual 

Application 

Rate

Maximum 

Applications 

Per Year

1

Minimum

Reapplication 

Interval

lb ai/acre lb ai/acre days

Proposed Use

Chickpea, Dry 

peas, Lentils

Aerial, Ground, and 

Chemigation 

equipment

0.12 0.24 2 10

Existing Use

Turf,

Residential, 

Commercial, or 

Industrial

Aerial, Ground

Sprayer, Hand-held 

or Backpack 

Sprayer

0.34 1.08 3 14

Turf, golf 

course

Aerial, Ground

Sprayer, Hand-held 

or Backpack 

Sprayer

0.34 1.08 3 14

Ground Sprayer, 

Hand-Held or 

Backpack Sprayer

0.31 1.33 6 (4.3) 14

3

Drinking Water Assessment for Tolerance Petition for New Uses of Trifloxystrobin in Trifloxystrobin Flowable

Fungicide [EPA Reg. No. 264-989]. D378919.
4 USEPA Office of Pesticide Programs, Environmental Fate and Effects Division. Standardized Soil Mobility

Classification Guidance. April 21, 2006.

Page 4 of 14

Environmental Fate and Transport Characterization

The environmental fate and physiochemical properties of trifloxystrobin and its major

degradation product CGA-321113 are summarized in Table 3 and Table 4, respectively. Table 4

also includes the aerobic soil metabolism half-life for the total toxic residues. Chemical 

structures for trifloxystrobin and CGA-321113 are available in Appendix 1.

Parent: Trifloxystrobin

Trifloxystrobin has a low solubility (0.61 mg/L @ pH 7) in water. The vapor pressure is 2.55 x

10-8torr at 25 °C, and the calculated Henry’s Law Constant is 2.25 x 10-8atm-m

3 mol-1

. These 

values suggest that trifloxystrobin is non-volatile under field conditions from water and moist 

soil surfaces. Volatilization is not a likely route of dissipation.

Trifloxystrobin is non-persistent in soil. Laboratory studies indicate that biotransformation is an 

important route of trifloxystrobin transformation in aerobic soil. Trifloxystrobin degraded rapidly 

in aerobic soils with half-lives ranging between 0.41 and 0.91 days. In aerobic soils the major 

degradate is CGA-321113. Photodegradation in soil results in the isomerization and subsequent 

formation of CGA-321113. The photo-induced isomerization half-life (t1/2) was 2.1 days on soils. 

Based upon the soil organic carbon coefficient, Koc (median Koc =2709 mL/goc), trifloxystrobin

would fall into the slightly mobile class

4

.

Laboratory studies indicate that trifloxystrobin is also not persistent in water. Hydrolysis of 

trifloxystrobin is dependent on pH; while trifloxystrobin is stable to hydrolysis under acidic 

conditions (pH 4), it readily hydrolyzes to CGA-321113 in alkaline conditions (t1/2 = 55.2 days at 

pH 7 and 0.83 days at pH 9). In the aquatic environment, the photo-induced isomerization halflife (t1/2) was 14.8 days. In an aerobic aquatic sediment system, the major transformation product 

was CGA-321113.

Trifloxystrobin demonstrated a biphasic degradation pattern in field dissipation studies

conducted in California, New York, and Georgia. For the first degradation phase, trifloxystrobin 

half-life values ranged from 1.9 to 24 days. In the second degradation phase, half-life values 

ranged from 6.5 days to 4 months.

Degradate of Concern: CGA-321113

CGA-321113 is the major transformation product identified in trifloxystrobin soil metabolism 

studies. Fate studies indicate that CGA-321113 is quite persistent in soil (DT50 250 to 350 days) 

and aquatic environments (DT50 = 289 days). It is stable to hydrolysis and metabolism;

therefore, CGA-321113 is expected to degrade at a slower rate than trifloxystrobin in both soil

and water. The aqueous solubility for CGA-321113 (30.9 mg/L) is three orders of magnitude 

higher than the aqueous solubility for trifloxystrobin. CGA-321113 is a carboxylic acid, and 

therefore being anionic, is expected to be more mobile than parent trifloxystrobin. The
5 USEPA Office of Pesticide Programs, Environmental Fate and Effects Division. Standardized Soil Mobility

Classification Guidance. April 21, 2006.

Page 5 of 14

Parameter Value Source

Molecular mass (molecular formula) 408.37 g/mol (C20H19F3N2O4)

2013 EPA Problem

Formulation

Vapor pressure (25°C) 2.55 x 10-8torr

a,b

Aqueous solubility (20C) 0.61 mg/L @ pH7 MRID 44502801

Henry’s Law Constant (25°C) 2.25 x10

-8

atm-m

3

/mol 2013 EPA Problem

Formulation

Log octanol-to-water partition coefficient

(log KOW) (25°C) 4.5 MRID 44502801

Hydrolysis half-life (25±1C)

pH 4: stable 

pH 7: 55.2 days 

pH 9: 0.83 days

MRID 44496727

Aqueous photolysis half-life (25±1C) 14.8 days @pH 5 MRID 44496727

Soil photolysis half-life (25±1C) 2.1 days MRID 44496729

Aerobic soil metabolism half-life [dissipation 

half-life A] (25±1°C)

0.74, 0.41, and 0.91 days

mean = 0.69 d, std = 0.25 d

MRID 44496732

MRID 44496730

MRID 44496731

Anaerobic aquatic metabolism half-life (20-

29C) 0.72 days MRID 44496733

Aerobic aquatic metabolism half-life

[dissipation half-life A] (25C) 0.60 days (supplemental) MRID 44496734

Freundlich soil-water partition coefficients 

(KF); organic carbon-normalized Freundlich 

coefficients (KFOC)

KF (mL/g);

6.8, 7.7, 16.0, 59.4, 91.8, 33.2

Mean = 35.82; Std = 33.8

KFOC( mL/gOC)

2354, 951, 3064, 3927, 9871, 951 

coefficient of determination (r

2

) = (Kf vs.

organic matter = 0.03)

MRID 44496802

adsorption/desorption mobility classification of CGA-321113 is mobile to moderately mobile5. 

Because of its persistence and mobility, CGA-321113 has greater potential for leaching than 

trifloxystrobin.

In contrast to laboratory data, CGA-321113 was not detected above 0.02 percent of the applied 

amount in leachates from a field lysimeter study. In field dissipation studies conducted in 

Georgia, California, and New York, under bare ground and cropped conditions, CGA-321113 

concentrations reached or were slightly above the Limit of Quantitation of 10 μg/L in 12-18 and

30-36 inch soil segments.

Table 3. Chemical Properties and Environmental Fate Parameters For Trifloxystrobin.

a USEPA Fact Sheet reports 3.4 x 10-6

torr (@25 °C)

b

PMRA Reg2004-03 and Trifloxystrobin (213) report 3.4 x 10-6Pa @ (@25 °C)
Page 6 of 14

Table 4. Chemical Properties and Environmental Fate Parameters For CGA-321113 and Residues 

of Concern (trifloxystrobin + degradate CGA-321113).

Parameter Values1Source

CGA-321113

Molecular Formula C19H17F3N2O4 MRID 44496801

Molecular Weight 394.35 MRID 44496801

Solubility @ 20 ◦C 30.9 mg/L MRID 44496816

Vapor Pressure 7.5 x 10-08 mm Hg @ 20 ◦C MRID 44496801

Henry’s Constant 1.26 x 10

-09 atm m3 mol-1

Hydrolysis Half-life Stable MRID 44496727

Aquatic Photolysis Half-life Stable MRID 44496727

Photolysis on soil Half-life Stable MRID 44496727

Aerobic Aquatic Metabolism Halflife

Stable MRID 44496734

Anaerobic Aquatic Metabolism

Half-life

Stable MRID 44496733

Organic Carbon Partition

Coefficient (Koc) (mL/g)

127, 235, 130, 48, and 80

mean 124.0 mL/goc

median 127 mL/goc

Coef. Determination (r

2

) = 0.89 for

Kf vs. om

MRID 44496801

Soil Partition Coefficient (Kf) 

(mL/g)

Kf (texture class)

4.0 Loam (5.4% om)

1.9 Sand

3.2 Clay loam

0.28 Sandy loam (1% om)

0.65 Sandy loam

mean = 2.0 mL/g

[1/n = 0.81 to 0.85]

MRID 44496801

Persistence for Residues of Concern (parent trifloxystrobin + CGA-321113)(DP D309489 see Table 9)

[Residues of Concern]:

Aerobic Soil Metabolism Half-life

254.8 days

271.3 days

199.7 days

282.75 days

(90

th percent upper bound on mean) 

Median = 254.8 days

MRID 44496732

MRID 44496730

MRID 44496731
Page 7 of 14

Models and Model Scenarios Used

Detailed descriptions, documentation, and links for running the exposure models used in this 

assessment may be found at http://www.epa.gov/oppefed1/models/water/index.htm.

Groundwater EDWCs for total toxic residues of trifloxystrobin resulting from the turf use were 

derived with PRZM-GW (Pesticide Root Zone Model for Groundwater, version 1.0, August 31,

2012), using the GW-GUI (Graphical User Interface, version 1.0, August 31, 2012). EDWCs for 

the Screening Concentration in Groundwater model were calculated in a 2010 DWA and are 

reported in this assessment (SCI-GROW v2.3, compiled 08/08/03).

6 Surface water EDWCs

were derived using PRZM/EXAMS as described in the 2010 DWA.

Model Input Parameters

The model input parameters for PRZM-GW are summarized in Table 4. Model input values 

were prepared following EFED input guidance

7,8

.

For each PRZM-GW scenario, EDWCs were calculated for each year in a 30-year simulation 

where trifloxystrobin was applied at the maximum label rate for 30 consecutive years. The 

initial application date was assumed to be the date of emergence for the PRZM-GW scenario 

used. Figure 1 is the PRZM-GW User Interface that shows the model inputs for the 

trifloxystrobin total toxic residues and illustrates how multiple applications were included in the 

modeling.

Table 4. Input Values Used to Model Total Toxic Residue EDWCs in Groundwater for the

Trifloxystrobin Turf Use.

Model Input Parameter PRZM-GW Input Value and Unit Source/Comments

Maximum Application Rate

0.347 kg a.i./ha for the first four 

applications, 0.101 kg a.i./ha for the 

fifth application for an annual 

application rate of 1.489 kg a.i./ha

Label; Corresponds to four 

applications of 0.31 lb a.i./acre and a 

fifth application of 0.9 lb a.i./acre

for an annual application rate of

1.33 lb a.i./acre.

Maximum Number of Applications 5

The label indicates 6 applications 

may be made, but not at the 

maximum single application rate.

6

Drinking Water Assessment for Tolerance Petition for New Uses of Trifloxystrobin in Trifloxystrobin Flowable

Fungicide [EPA Reg. No. 264-989]. D378919.

7

Parameters are selected as per Guidance for Selecting Input Parameters in Modeling the Environmental Fate and

Transport of Pesticides; Version 2.1, October 22, 2009.

8 Baris, R.; Barrett, M.; Bohaty, R.; Echeverria, M.; Kennedy, I.; Malis, G.; Wolf, J.; Young, D. PRZM-GW Input

Parameter Guidance; Health Canada, U.S. Environmental Protection Agency, October 12, 2012.
Page 8 of 14

Model Input Parameter PRZM-GW Input Value and Unit Source/Comments

Method of Application CAM 1, Bare Ground Label

Date of Initial Application 120 days post-emergence

Emergence dates are specified in 

each PRZM-GW scenario.

Minimum Interval between

Applications

14 days Label

Soil Partition Coefficient Koc

(CGA-321113)

124 mL/goc

(mean)

MRID 44496801

Hydrolysis Half-Life

(CGA-321113) Stable MRID 44496727

Aerobic Soil Metabolism Half-Life

(parent trifloxystrobin + CGA321113)

282.75 days

(90

th percent upper bound on mean)

MRID 44496732

MRID 44496730

MRID 44496731
Page 9 of 14

Figure 1. Trifloxystrobin - Example of PRZM-GW User Interface and Inputs for Foliar

Applications to Turf.
Page 10 of 14

Modeling Results

Table 5 reports the EDWCs calculated for each PRZM-GW (i.e., groundwater) scenario for 

applications at 120 days post-emergence. EDWCs calculated for 0- and 60-days post-emergence 

were also calculated and yielded EDWCs approximately 10-30 μg/L in their respective 

scenarios. Peak EDWCs for all scenarios and application periods modeled ranged from 55 to

427 μg/L, and the post-breakthrough average EDWCs ranged from 48 to 365 μg/L. The 

Wisconsin Corn scenario resulted in the maximum EDWCs. The PRZM-GW time series graph 

for the Wisconsin Corn scenario EDWCs is presented in Figure 2.

EDWCs for the turf use were calculated using SCI-GROW in the 2010 DWA, which resulted in 

acute and chronic EDWC of 5.87 μg/L.

9

EFED recommends using the maximum peak and post-breakthrough average concentrations 

from the 30-year PRZM-GW simulation for the Wisconsin corn scenario for human health risk 

assessment (i.e., 427 and 365 μg/L). and are not expected to be greater than

Table 5. Tier I PRZM-GW Total Toxic Residue Estimated Drinking Water Concentrations

(EDWCs) for 30 Years for the Trifloxystrobin Turf Use.

Scenario Peak (μg/L)

PostBreakthrough 

Average (μg/L)

Average 

Breakthrough 

Time (days)

Throughputs*

First Application 120 Days Post-Emergence

FL Citrus 241 187 1250 8.8

DMV Corn 258 202 1239 8.8

FL Potato 55 49 2862 3.8

GA Peanuts 113 96 3023 3.6

NC Cotton 250 216 2056 5.3

WI Corn 427 365 2848 3.8

*Throughputs are the estimated pore volumes/retardation factors that occur in the simulation.

9

Drinking Water Assessment for Tolerance Petition for New Uses of Trifloxystrobin in Trifloxystrobin Flowable

Fungicide [EPA Reg. No. 264-989]. D378919.
Page 11 of 14

Figure 2. PRZM-GW Wisconsin Corn Scenario Time Series Graph for 30 Years

Trifloxystrobin Application to Turf (ppb is equivalent to μg/L total toxic residues).

Tier I PRZM-GW Modeling Assumptions

In estimating pesticide concentrations in water resources, OPP uses a tiered screening approach 

involving a combination of models and monitoring data. The intent of the screening approach is 

to estimate pesticide concentration in water from sites that are highly vulnerable to runoff or 

leaching so that the program can be confident that any pesticide that passes the screening tiers 

poses a low possibility of harming human health, wildlife, or the environment. Failing a tier, 

however, does not necessarily mean the chemical is likely to cause health or environmental 

problems, but rather that there is a need to move to a higher tier and conduct a more refined 

assessment. This tiered modeling system is designed to provide a thorough analysis of each 

pesticide, while at the same time focus OPP's efforts on those pesticides that pose the greatest 

potential risk.

In this assessment, PRZM-GW is used as a Tier-1 screen. In other words, the modeling 

conducted for this assessment preserves default conservative assumptions in the PRZM-GW 

model. As such, Tier 1 PRZM-GW modeling is expected to result in conservative groundwater 

EDWCs that would rarely, if ever, occur in the environment.

Depending on the Tier I results, Tier II (or “refined”) EDWCs may be modeled to take into 

account usage data, well setback requirements, additional fate inputs, and an exposure duration 

specific to the exposure duration of concern for humans. A more representative scenario may

also be developed as part of Tier II EDWC modeling. This assessment has not calculated Tier II 

EDWCs using PRZM-GW, and thus does not consider trifloxystrobin usage data, well setbacks, 

additional fate inputs, specific exposure durations, or new scenario development. For more 

information on potential Tier II refinements in PRZM-GW modeling, see 

http://www.epa.gov/oppefed1/models/water/przm_gw/wqtt_przm_gw_guidance.htm).

The default PRZM-GW assumptions used in calculating Tier I groundwater EDWCs for 

trifloxystrobin total toxic residues include the following:
Page 12 of 14

 Trifloxystrobin is used at the maximum labeled rate for 30 consecutive years.

 There are no well setbacks.

 Removal of the pesticide via runoff or erosion is negligible.

 The saturated zone is a shallow (<100 feet), unconfined aquifer with a water table depth 

that corresponds to its respective scenario location.

 The well screen extends from the aquifer surface to 1 meter below the aquifer surface.

 The pesticide undergoes aerobic soil metabolism in the top 10 cm of soil; the aerobic soil 

metabolism rate declines linearly to 1 meter below the soil surface, below which only

abiotic degradation processes (i.e., hydrolysis) occur.

These assumptions are designed to introduce a high level of protection into the modeling results.

Monitoring Data

Surface water and groundwater data from one state and three nationwide pesticide monitoring 

programs were reviewed to provide additional context concerning the potential presence of 

trifloxystrobin in drinking water resources. These water monitoring programs do not target 

sample collection to peak use locations or application times for particular pesticides, nor do they

target sample collection to high precipitation events (i.e., high-runoff events). Additionally, the 

sampling frequency in these monitoring programs was not designed to capture peak 

concentrations. Therefore, the monitoring data reported by these programs may not represent the 

highest concentrations in drinking water source water, and are considered qualitative information 

for the purposes of this drinking water assessment.

USGS-EPA Pilot Reservoir Monitoring Program - Trifloxystrobin and CGA-321113 data were 

not analyzed as part of this program.

USGS National Water-Quality Assessment (NAWQA) Program Data - Trifloxystrobin data were 

available from USGS NAWQA surface water and sediment data. Surface water detections were 

from Cobb and Coweta counties in Georgia in 2010 (2 samples with detections less than 4.7 

ng/L), Cameron County in Texas in 2013 (1 sample with a detection less than 2 ng/L), and San 

Joaquin and Sacramento Counties in California in 2012 (11 samples with detections less than 4.7 

ng/L). In Georgia’s Cobb, Coweta, and Sumter counties, sediment samples taken from 2010 to

2011 had trifloxystrobin detections less than 1.4 ug/kg. Trifloxystrobin was not detected in 

groundwater. NAWQA has not analyzed surface water or groundwater samples for CGA321113. NAWQA program data are available at 

http://infotrek.er.usgs.gov/nawqa_queries/index.jsp.

California Surface Water Monitoring Program Data - The California Surface Water Monitoring 

Program represents pesticide occurrence data for surface waters in the Sacramento Valley, San 

Joaquin Valley, and other locations in the state. The California surface water and groundwater 

monitoring data included a total of 43 surface water detections for trifloxystrobin, all below the 

level of quantitation (LOQs of 0.02 to 0.05 μg/L) from Colusa, Sutter, Yolo and Yuba counties 

from 2006 to 2008. The California Surface Water Monitoring Program has not analyzed surface 

water or groundwater for CGA-321113. California Surface Water Monitoring Program data are 

available at http://www.cdpr.ca.gov/docs/emon/surfwtr/surfdata.htm.
Page 13 of 14

Pesticide Data Program (PDP) Data - The PDP drinking water monitoring project provides nontargeted pesticide occurrence data in raw water, finished water (treated/tap), and groundwater in 

the United States. The PDP has not analyzed surface water or groundwater for detections of 

trifloxystrobin or CGA-321113. PDP data are available at 

http://www.ams.usda.gov/AMSv1.0/pdp.
Page 14 of 14

Appendix 1. Chemical Structures for Trifloxystrobin and CGA-321113

Trifloxystrobin

CGA-321113