Penoxsulam Summarv of Analytical Chemistry and Residue Data DP Barcode D425013 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, DC 20460 

MEMORANDUM 

DATE: December 4, 2015 

OFFICE OF CHEMICAL SAFETY AND 

POLLUTION PREVENTION 

SUBJECT: Penoxsulam. Petition to Establish Permanent Tolerances (with Section 3 

Registration) for Residues Resulting from Use of the Herbicide on Pome Fruit, 

Stone Fruit, Olive, Pomegranate, and Fruit, Small, Vine Climbing (Subgroup I 3-

07F, Except Fuzzy Kiwifruit); and Crop Group Conversion for Tree Nuts. 

Summary of Analytical Chemistry and Residue Data. 

PC Code: I 1903 I DP Barcode: 0425013 

Decision Number: 497353 

Petition Number: 4E8330 

Risk Assessment Type: NA 

TXR Number: NA 

Registration Numbers: 62719-499, 62719-611 

Regulatory Action: Section 3 Registration 

Case Number: 7265 

CAS Number: 219714-96-2 

MRID Numbers: 49472601 and -02 40 CFR: § 180.605 

FROM: 

THRU: 

TO: 

Elizabeth Holman, Physical Scientist £/ly ,-~ J+£- ..__ 

Risk Assessment Branch II (RAB2) 

Health Effects Division (HED), 7509P 

William T. Drew, mist~ RAB2/HED. 7509P 

Sidney Jackson/Barbara Madden 

Minor Use and Emergency Response Branch 

Registration Division (7505P) 

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Penoxsulam Summar.' of Analytical Chemistrv and Residue Data DP Barcode D4250 I 3 

Table of Contents 

1.0 Executive Summary ...... ........ ................................................................................................ 4 

2.0 Regulatory Recommendations ............................................................................................ 2_6 

2. 1 Data Deficiencies/Data Needs ................................................... ....... ....... ..................... .... 6 

2.2 Tolerance Considerations ............... .... ......... ................ ........ ........... ................................... 6 

2.2.1 Enforcement Analytical Method/Multi-Residue Methods ........................................ 6 

2.2.2 Recommended Tolerances ............................................................ .......................... §+ 

2.2.3 Revisions to Petitioned-For Tolerances ........ .................... ......................... .......... ... 18 

2.2.4 International Harmonization .................... ............................................................. l+Q 

2.3 Label Recommendations .............................................................................................. l+Q 

2.4 Submittal of Analytical Reference Standards (860.1650) ..... .... ....... ....... ... .... ... ....... ... l+Q 

3.0 Chemical Identity ..... .... ........ ................. ........................................................................... ~++ 

3.1 Non1enclature ............................................................................................................... ~++ 

3.2 Physicochemical Characteristics ................... ........ ........ .... .... .... ....... ................. ... ....... . 2-R 

3.3 Pesticide Use Pattern/Directions for Use (860.1200) ... ............................................... 2-1-J 

4.0 Metabolite/Degradate Residue Profile ........................................................................... l.Q+4 

4. 1 Nature of the Residue ............................................................................................. ........ 14 

4.1. l Summary of Plant and/or Livestock Metabolism (860.1300) ........ ... ....... ........... l.Q+4 

4.1.2 Summary of Confined Rotational Crops (860.1850) ....... .................................... JlH 

4. 1.3 Summary of Rat Metabolism .......................... ................... ................................. Jl~ 

4. 1.4 Summary of Environmental Degradation ......................................................... .. 12-8 

5.0 Residue Profile .............................................. ....................................... .......................... UH 

5.1 Residue Analytical Methods (860. 1340) ................................ .............. ....... ....... ... ... _ll-8 

5.1.l Data Collection Methods .................. ......... ... ..... .... ............... ... ....... ....... .... ......... _ll-8 

5.2 Storage Stability (860.1380) ........... ......... ........ ............. .................. ........................... 13+6 

5.3 Residue Data .............................................................................................................. HM 

5.3.1 Crop Field Trials (860. 1500) ...... ..... .... ......... .... .... ... ........ .... ....... ....... .... ... .... ... ... .... 17 

5.3.2 Field Rotational Crops (860.1900) .. ............ ........................... .................. .......... 12±4 

5.3.3 Processed Food and Feed (860.1520) ................................................................. 12~ 

5.3.4 Meat, Milk, Poultry and Eggs (860.1 480) ...... ........ ........................................... . 12~ 

5.3.5. Food Handling (860.1460) ..................................................... ................................. 32 

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Penoxsulam Summary of Analytical Chemistry and Residue Data DP Barcode D425013 

5.3.6 Water, Fish and Irrigated Crops (860. 1400) ........................................................... 32 

5.4 Food Residue Profile .................................................................................................. il~ 

6.0 Tolerance Derivation ..................................................................................................... £1J;. 

References ..................................................................................................................................... 36 

Attachment I: International Residue Limit Status ....................................................................... 38 

Attachment 2: OECD MRL (Tolerance) Assessment Calculations .............................................. 40 

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Penoxsulam Summary of Analytical Chemistry and Residue Data DP Barcode D425013 

1.0 Executive Summary 

Penoxsulam is a sulfonamide herbicide currently registered for the selecti ve control of grass, 

broadleaf, and sedge weeds. In the U.S., it was first registered for use on rice and subsequently 

has been registered for use on turf and for use in aquatic weed control. The herbicide's mode of 

action at the cellular level involves the inhibition of acetolactate synthase (ALS). 

The Interregional Research Project Number 4 (IR-4) has submitted a Section 3 registration 

application for new uses of the herbicide penoxsulam. Specifically, the current proposal is for 

new uses on pome fruit group 11-10, stone fruit group 12-12. olive, and pomegranate; an 

extension of tolerances for grapes to the small fruit vine climbing subgroup l 3-07F, and a crop 

group update from the old tree nut crop group 14 to the new tree nut crop group 14-12. The uses 

are for the existing end-use product, Pindar® GT, an emulsifiable concentrate (EC) containing 

0.85% penoxsulam (EPA Reg. #62719-611 ). The maximum single application rate is 0.03 

pounds active ingredient per acre (lb ai/A) with a seasonal maximum, harvest to harvest, of 0.05 

pounds active ingredient per acre (lb ai/A). Penoxsulam may be used either as a pre- or 

postemergence weed control via ground application. 

In the current petition, PP#4E8330, IR-4 proposes the establishment of permanent tolerances for 

residues of the herbicide penoxsulam in/on the raw agricultural commodities (RA Cs) listed in 

Table 2.2.2 (below), at the levels shown therein. 

The nature of the residue in plants is adequately understood for the purposes of this new use 

petition, based on acceptable grape and rice metabolism studies. The nature of the residue in 

animals is adequately understood, based on acceptable ruminant and poultry metabolism studies. 

HED previously determined that, for tolerance enforcement and risk assessment purposes, the 

residue of concern (ROC) in both crops and livestock is parent penoxsulam only. In fish and 

shellfish, for risk assessment purposes the ROC is parent penoxsulam plus metabolite 5-0Hpenoxsulam, but for tolerance enforcement the ROC is parent penoxsulam only. 

Crop Field Trials: The number and geographic distribution of the field trials are adequate, and 

the use patterns are consistent with the proposed use patterns regarding maximum application 

rates, shortest pre-harvest intervals (PHls), and minimum re-treatment intervals (RTis). 

Adequate crop field trial studies were submitted for stone and pome fruit. HED previously 

concluded that field tri al data from pome fruit and stone fruit could be used to support tolerances 

on olive and pomegranate, assuming that no quantifiable residues were observed in any of these 

field trials (HED ChemSAC minutes. 09/01 /2010). Based on the pome and stone fruit field trial 

data reviewed for thjs petition, with no residues observed above the LOQ of 0.01 ppm, there is 

adequate data to support the proposed tolerances of 0.01 ppm on olive and pomegranate. In 

addition, there is adequate data to support crop group conversion for tree nuts (from group 14 to 

group 14-12) and establishing a new tolerance at the same level of 0.0 I ppm. Finally, the 

existing data on grape support establishing a crop group tolerance at 0.0 I ppm for fruit, small, 

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Penoxsulam Summary of Analytical Chemistry and Residue Data DP Barcode D425013 

vine climbing, subgroup 13-07F, except fuzzy kiwifruit. The available residue data support 

tolerances for residues of penoxsularn, as listed in Table 2.2.2 (below). 

Processing Studies: Separate processing studies were not submitted as part of the petition 

currently under review. As noted above, all pome fruit and stone fruit field trials had nonquantifiable residues (<0.01 ppm). Furthermore. in one of the apple field trials an exaggerated 

use rate was used (SX), with no quantifiable residues being observed in this trial. ln addition, in 

a single plum field trial, conducted at - 1.3X the proposed maximum seasonal use rate, residues 

were also below the LOQ in dried plum processed from plums harvested at a 63-day PHI. 

Finally, it is noted that in the previously reviewed grape processing study (- 5.8X the registered 

maximum seasonal rate for grape), there were no quantifiable residues in either the grape RAC 

or in the grape processed commodities. Based on the available data, penoxsulam residues do not 

concentrate in processed fractions. Therefore, HED concludes that the available data are 

adequate and that separate tolerances for processed commodities are not required for the 

proposed uses. 

Residue Analytical Methods: There are adequate enforcement methods available for the 

quantitation of penoxsulam in plant and animal commodities. 

Storage Stability: Adequate storage stability data are available to support the storage durations 

and conditions of samples from the submitted penoxsulam field trial studies. 

Meal. Milk, Poultry and Eggs: No additional data are required to support the proposed uses of 

penoxsuJam currently under review. HED continues to conclude that livestock tolerance are not 

required, as there is no expectation of finite residues in livestock commodities (i.e., there is a 40 

CFR §180.6(a)(3) situation). 

MRL Harmonization: There are no Codex, Canadian or Mexican maximum residue limits 

(MRLs) established for residues of penoxsulam on any crops, including those under review for 

this petition. Therefore, there are no harmonization issues with respect to the proposed 

agricultural uses. 

2.0 Regulatory Recommendations 

HED has examined the residue chemistry database for penoxsularn. Provided the submitted 

Section F is revised as noted below, there are no residue chemistry issues that would preclude 

granting the requested Section 3 registration for penoxsulam, and establishment of the 

recommended tolerances in the proposed commodities, as listed in Table 2.2.2 (below). 

Specifically, as discussed below in Section 2.2.3, the revised Section F should propose a revised 

tolerance expression for penoxsulam ( 40CFR § 180.605), with this expression being updated to 

include both coverage and compliance statements for enforcement purposes. In addition, as 

listed in Table 2.2.2, the revised Section F should also correct some of the commodity definitions 

for the proposed commodities. 

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Penoxsulam Summarv of Analvtical Chemistrv and Residue Data DP Barcode D425013 

2.1 Data Deficiencies/Data Needs 

None. 

2.2 Tolerance Considerations 

2.2.1 Enforcement Analytical Method/Multi-Residue Methods 

Resid ue Chemistry Summary 0355914; M. Doherty; 29 January 2009 

High performance liquid chromatographic methods with positive-ion electro spray interface 

(ESI) and tandem mass spectrometric detection (LC/MS/MS) were previously reviewed and 

found to be acceptable for tolerance enforcement of penoxsulam. Method GRM 01.25 was 

developed for rice commodities, and Method GRM 05.08 was developed for animal 

commodities. Successful validation of both methods was repo11ed by the registrant, and by an 

independent laboratory validation (ILV). No radiovalidation was required for either of these 

methods. The limit of quantitation (LOQ), detem1ined as the lowest level of method validation 

(LLMY), is 0.010 ppm for penoxsulam in all matrices. 

Testing results of penoxsulam analyzed according to the FDA Multi-Residue Method Test 

guidelines in PAM Vol. 1, Appendix 11 (1/94) were previously submitted in conjunction with the 

rice petition (PP# 3F6542; DP# 288 152, 8/11 /04, W. Cutchin). The multiresidue method data 

indicate that penoxsulam is not adequately recovered using any of the multi residue methods. 

2.2.2 Recommended Tolerances 

TABLE 2.2.2. Tolerance Summary for Penoxsulam (40CFR §180.605). 

Proposed o r Existing* Proposed or Existing* Recommended Correct Commodity Defl11itio11; 

Commodity Tolerance (oom) Tolerance (oom) Comments 

Fruit, Pome, group 11-10 0.01 0.01 Fruit. pome, group 11-10 

Fruit. Stone, group 12-12 0.01 0.01 Fruit, stone. f!.roup 12-12 

Fruit. small, vine 0.0 1 0.01 Based on available data on grape. 

climbing. subgroup 13-

07F, except fuzzy 

kiwifruit 

Nut, Tree group 14-12 0.01 0.01 Nut, tree, group 14-12; Conversion from 

tree nut group 14. 

Olive 0.01 0.01 Based on submitted stone fruit and 

Pomegranate 0.01 0.01 pome fruit field trial data. 

Nut, tree, group 14* 0.01 * Remove Conversion to tree nut J:?,roup 14- 12. 

Grape* 0.01* Remove Replace with tolerance on fruit, small, 

vine climbing, subgroup 13-07F, except 

fuzzy kiwifruit. 

Pistachio* 0.01 • Remove Replace with the tolerance on tree nut 

group 14-12. 

* A tolerance is currently established at the listed tolerance level in the corresponding commodity. 

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Penoxsulam Summary of Analytical Chemistry and Residue Data DP Barcode D425013 

2.2.3 Revisions to Petitioned-For Tolerances 

The current tolerance expression for penoxsulam ( 40CFR § 180.605) needs to be updated to 

include both coverage and compliance statements for enforcement purposes in order to comply 

with HED's guidance on tolerance expressions (S. Knizner; 5/27/2009). Specifically, the 

tolerance expression for penoxsulam cited in 40 CFR § 180.605 should be revised to state: 

Tolerances are established for residues of penoxsulam, 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 

penoxsulam 2-(2,2-difluoroethoxy)-N-(5,8-dimethoxy[ I ,2,4]triazolo( 1,5-c] 

pyrimidin-2-yl)-6-(trifluoromethyl) benzenesulfonamide, in or on the commodity. 

The petitioner should submit a revised Section F using the correct commodity definitions 

provided in Table 2.2.2. All proposed tolerance values for these commodities are correct as 

listed and are identical to those recommended by HED. 

2.2.4 International Harmonization 

There are no Codex, Canadian or Mexican MRLs established for residues of penoxsulam on any 

crops, including those under review for this petition. Therefore, there are no harmonization 

issues with respect to the proposed agricultural uses. 

2.3 Label Recommendations 

None. 

2.4 Submittal of Analytical Reference Standards (860.1650) 

The analytical standard for penoxsulam, with an expiration date of 2 1 January 2017, is currently 

available in the EPA's National Pesticide Standards Repository (NPSR), per Email 

communication from Gregory Verdin of the Biological and Economic Analysis Division's 

(BEAD's) Analytical Chemistry Branch (ACB) on 14 September 2015. The registrant is 

required to maintain reasonable amounts of the analytical reference standard for penoxsulam in 

the NPSR. When necessary, a new reference standard, or updated certificate of analysis (COA), 

should be sent to the ACB, which is located at Fort Meade, MD. It should be sent to the 

attention of either Theresa Cole or Thuy Nguyen at the address listed below, along with a letter 

of transmittal. Please note that the full 9-digit ZIP Code is required, or the mail will be 

returned to the registrant. 

USEPA 

National Pesticide Standards Repository 

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Penoxsulam Summary of Analytical Chemistry and Residue Data 

Analytical Chemistry Branch/BEAD/OPP 

701 Mapes Road 

Fort George G. Meade, MD 20755-5350 

DP Barcode D4250 13 

The letter of transmittal should include the assay of the standard, name of the analytical method 

used, a statement of principal impurities, purification procedures employed, storage 

requirements, and special precautions for safe handling. Replacement of standards may be 

required periodically if supplies are exhausted, if the standards expire, or if decomposition 

occurs during storage. Material Safety Data Sheets (MSDSs) or, alternatively, SDSs that comply 

with the Globally Hannonized System of Classification and Labeling of Chemicals (GHS), 

should accompany all analytical standards, as specified in 29CFR § 1910.1200 by the 

Occupational Safety and Health Administration (OSHA). 

3.0 Chemical Identity 

The nomenclature of penoxsulam is summarized in Table 3. 1, and the physicochemical 

properties are summarized in Table 3.2. 

3.1 Nomenclature 

Table 3. 1. Penoxsulam Nomenclature. 

Compound F F 

) 0 ,.-CH, 

o o A 6:11 S N.._N ~N 

0 ll'N--{ H ....-:: ~ ~ N 

CF3 0 

"CH3 

Common name Penoxsulam 

Company experimental name XDE-638 

IUPAC name 3-(2,2-di Ouoroethoxy)-N-(5,8-dimethoxy[ 1,2,4)triazolo[ 1,5-c )pyrimidin-2-yl)-

a ,a,a-tri fluorotoluene-2-sul fonam ide 

CAS name 2-(2,2-di fluoroethoxy)-N-(5,8-dimethoxy[ 1,2,4]triazolo[ 1,5-c ]pyrimidin-2-yl)-6-

(tri fluoromethyl)benzenesul fonam ide 

CAS registry number 2 197 14-96-2 

End-use product (EP) Pindar® GT (EPA Reg. #62719-61 I) 

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3.2 Physicochemical Characteristics 

Table 3.2. Physicochemical Properties of Pcnoxsulam. 

Parameter Value Reference 1 

Me lting point/range Not available 

pH 5.2 MRID 45830707 

Density 1.61 g/mL at 20 °C MRJD 45830707 

Water solubility at 19 °C Unbuffered 4.91 mg/L MRID 45830720 

pH 5 5.66 mg/L 

pH 7 408 mg/L 

pH 9 1460 mg/L 

Solvent solubility at 19 °C Xylene 0.017g/L MRID 45830720 

1-0ctanol 0.035 g/L 

Methanol 1.48 gfL 

Ethyl acetate 3.23 g/L 

Acetonitrile 15.3 g/L 

Acetone 20.3 g/L 

Dimethylsulfoxide 78.4 gfL 

Vapor pressure 7.16 x 10·

16 mm Hg at 25 °C MRID 45830720 

Dissociation constant, pKa 5.1 (ambient) MJUD 45830720 

OctanoVwater partition coefficient. Unbuffered -0.354 MRID 45830720 

Log(Kow) pH 5 1.137 

pH 7 -0.602 

pH 9 -1.418 

UV/visible absorption spectrum Not available 1 As referenced m DP# 326985, 1/30/07. D. Soderberg. 

3.3 Pesticide Use Pattern/Directions for Use (860.1200) 

Penoxsulam is proposed for new uses on pome fruit group 11-10, stone fruit 12-12, olive, and 

pomegranate. Penoxsulam is also requested for an extension of the tolerances from grapes to the 

crop subgroup 13-07F and a crop group update to the new tree nut croup group 14-12. The 

proposed formulated end-use product is Pindar® GT, an emulsifiable concentrate containing 

0.85% penoxsulam (EPA Reg. #62719-611 ). A summary of the proposed new use directions is 

included in Table 3.3 below. 

Table 3.3. Summary of Proposed Uses for Penoxsulam. 

Applic. Timing, 

Formulation Applic. Rate Max. Seasonal PHI Use Directions (EPA Reg. Type, and Equip. No.) (Jb ai/A) Applic. Rate (lb ai/A) (days) and Limitations 

Pome Fruit Group 11- 10, Stone Fruit 12-12, Olive, and Pomegranate 

Crop Group extension from Grapes to Subgroup 13-07F 

Crop Group update to the new Tree Nut Group 14-12 

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Penoxsulam Summary of Analvtical Chemistry and Residue Data DP Barcode D4250 13 

Table 3.3. Summary of Proposed Uses for Penoxsulam. 

Applic . Timing, Formulation Applic. Ra te Max. Seasonal PHI Use Directions (EPA Reg. Type, and Equip. No.) {lb ai/A) Applic. Rate (lb ai/A) (days) and Limita tions 

Groundboom, Apply pre- or 

Backpack Sprayer, Emulsifiable 0.02 to 0.03 lb postemergence of 

Concentrate 0.05 lb ai/A 60 weeds in the Mechanically- (627 19-61 I) ai/A dormant period Pressurized Handgun before bud swell. 

Penoxsulam is also currently registered for occupational use on grapes, tree nuts, rice, turf grass, 

aquatic vegetation, non-cropland, non-bearing cropland, non-bearing fruit trees (including 

citrus), conifers, and eucalyptus. It is also registered for residential use on turfgrass and aquatic 

vegetation for weed control. 

Conclusions: The proposed use directions are adequate to allow evaluation of the residue data 

relative to the requested uses. The proposed maximum seasonal use rates, minimum RTis, and 

minimum PHTs are supported by the submitted crop field trial data. 

4.0 Metabolite/Degradate Residue Profile 

Residue Chemistry Summary; OP# 288152, 8/11 /04, W. Cutchin 

Residue Chemistry Summary; 0 355914; M. Doherty; 29 Janua ry 2009 

Plants: The metabolism of penoxsulam was previously investigated, and adequately described, 

in two different plants: rice and grape. HED notes that, should the use pattern for the proposed 

or existing uses change (i.e., from soil to foliar applications), or new uses are requested to 

expand beyond orchard crops, additional nature of the residue data may be needed. 

Animals: The metabolism of penoxasulm was previously studied, and adequately described, in 

both ruminants and poultry. 

4.1 Nature of the Residue 

Residue Chemistry Summa ry; DP# 288152, 8/11/04, W. Cutchin 

Residue Chemistry Summa ry; D355914; M. Doherty; 29 Janua ry 2009 

Refer to the previous residue chemistry summary documents for detailed descriptions of the 

plant metabolism studies with penoxsulam in rice and grape, and of the animal metabolism 

studies in lactating goats and laying hens. 

4.1.l Summary of Plant and/or Livestock Metabolism (860.1300) 

Residue Chemistry Summary; DP# 288152, 8/11/04, W. Cutchin 

Residue Chemistry Summary; D355914; M. Doherty; 29 J anuary 2009 

MARC Decision Memo TXR No. 0052740 (DP Ba rcode 0 305542, 7/ 19/04, W. Cutchin) 

Residue Chemistry Summa ry; DP Num: 326985, D. Soderberg, 1/30/07 

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Penoxsulam Summary of Analytical Chemisrrv and Residue Data DP Barcode D425013 

Data have been submitted and reviewed depicting the metabolism/degradation of penoxsulam in 

rice, grape, livestock and the environment. HED has determined the plant and animal ROCs for 

purposes of tolerance enforcement and risk assessment (see Table 4.1.1 , below). 

TABLE4.1.l Summary of Penoxsulam Metabolites and Degradates to be included in the Risk 

Assessment and Tolera nce E xpression. 

Matrix Residues Included in Risk Assessment Residues Included in Tolerance 

Expression 

Plants Primary crops Penoxsulam Penoxsulam 

Rotational crops Penoxsulam Penoxsulam 

Animals Ruminants Penoxsulam Penoxsulam 

Poultry Penoxsulam Penoxsulam 

Fish/shell fish Penoxsulam + 5-0H-penoxsulam Penoxsulam 

Drinking water Penoxsulam + BSTCA + 2-amino TCA + Not applicable 

5-0H-penoxsulam + SF A + sulfonamide 

+ 5,8-di OH* 

' See Attachment 2 for chemical structures of these compounds. 

Conclusion: The nature of the residue in plants and animals has been adequately delineated to 

support the current petition. If the use pattern expands in the future, additional plant metabolism 

data may be required. 

4.1.2 Summary of Confined Rotational Crops (860.1850) 

PP#3F6542; DP Barcode 02881 52, 8/ 11/04, W. Cutchin (45830720.der.wpd) 

An acceptable crop rotational crop study was previously reviewed in the rice petition 

(PP#3F6542). HED review of the study concluded that no quantifiable residues of penoxsulam 

or 5-0H XDE-638 arc expected to be present in the RA Cs of small grains, leafy vegetables, and 

root crops planted 90 days following treatment with penoxsulam at 0.045 or 0.090 lb ai/ A (1 X or 

2X the rate for rice). The data also indicate that residues of the metabolite BSTCA could be 

present at >0.01 ppm in the foliage of root crops planted 90 days following treatment at 0.090 lb 

ai/A (2X). The Metabolism Assessment Review Committee (MARC) determined that 

penoxsulam BSTCA is not a ROC for penoxsulam in rotated crops. 

It was noted that the submitted confined rotational crop study only included one plant-back 

interval (PBl), 90 days. If in the future PB Is other than 90 days are proposed, an additional 

confined rotational crop study reflecting the proposed PBI would be required. 

4.1.3 Summary of Rat Metabolism 

Risk Assessment 0 363910; C. Swa rtz; 9 April 2009 

In a metabolism study in rats, 14C-penoxsulam was rapidly and nearly completely absorbed at the 

low dose of 5.0 mg/kg, but at the high dose of 250 mg/kg, there was evidence that absorption 

was largely incomplete (i.e. absorption was saturated). Both gender and dose affected the 

excretion pattern. At the low dose, the major route of excretion of radioactivity was via the feces 

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Penoxsulam Summar.• of Analytical Chemistrv and Residue Data DP Barcode 0 4250 I 3 

in males and via the urine in females. At the high dose, radioactivity was predominantly 

excreted via the feces in both sexes. A significant enterohepatic circulation was observed, 

particularly in males. Most (>90%) of the administered dose was excreted within 36-48 hours. 

There was negligible radioactivity in tissues at 7 days and no evidence of accumulation in any 

tissue/organ. Although numerous metabolites were revealed in the urine, feces and bile, nearly 

all were <1 % of the administered dose. Parent compound and a 2-hydroxyphenyl derivative 

were the major compounds in urine and feces. 

4.1.4 Summary of Environmental Degradation 

EFED Drinking Water Memo; J. Wolf, 28 Aug 201 5, 042841 9 

Penoxsulam is expected to be moderately persistent in the aerobic terrestrial environments, and 

less persistent in anaerobic environments. The degradation products tend to be more persistent 

than the parent compound. Penoxsulam is expected to dissipate rapidl y in clear shallow waters 

through aqueous photolysis. Thus, in turbid, shaded or acidic waters, photolysis of penoxsulam 

is expected to be slower, and other degradation mechanisms are expected to predominate. 

Laboratory data indicates that the four photolytic half-lives reported for penoxsulam in water 

range from 1.5 to 3.1 days between pH 7 and pH 8, and 14 days at pH 5.8. A reported pKa value 

of 5.1 suggests that pH may have an effect upon the photolytic half-life. In aqueous 

environments, penoxsulam is stable to hydrolysis at pH 5, 7 and 9. 

Submitted mobility data for three penoxsulam degradation products (BSTCA, 5-0Hpenoxsulam, and BST) indicate environmental mobility roughly equivalent to or slightly greater 

than the parent compound. The soil to water partition coefficients (Kd) derived from the 

seventeen soils and one sediment studied ranged from 0. 12 to 10.67 mL/g. Calculated Koes 

ranged from 12 to I , 141 mL/goc. The Koc values for the sediment were 11 18 and 1141 mL/goc 

(Kds = 1.38 and 1.41 mL/g). There are no data regarding the mobility of the remaining 

transformation products nor the combined parent/degradate residues. The lowest average Koc 

was 45.3 mL/goc for 5-0H-penoxsulam was used as an input for modeling as it is one of the 

ROCs and it appears to be one of the more persistent degradates. In drinking water, a total toxic 

residue (TTR) approach has been used, with estimated drinking water concentrations (EDWCs) 

used in risk assessment including parent plus six degradation products (BSTCA + 2-amino TCA 

+ 5-0H-penoxsulam + SF A + sulfonamide + 5,8-di OH). These major degradation products 

were observed in one or more environmental fate studies. 

5.0 Residue Profile 

5.1 Residue Analytical Methods (860.1340) 

5.1.1 Data Collection Methods 

MRID 49472601.dcr - Pome Fruit 

MRID 49472602.dcr - Stone Fruit 

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Penoxsulam Summarv of Analytical Chemistry and Residue Data DP Barcode 0425013 

Samples from all crop field trials associated with the petition currently under review were 

analyzed for residues of penoxsulam via LC/MS/MS, using the method, "Determination of 

Residues of Penoxsulam in Agricultural Commodities by High Performance Liquid 

Chromatography with Tandem Mass Spectrometry." A complete description of the method. 

including minor modifications, was provided in the submission. The method is similar to data 

collection method GRM 04.09 which was previously reviewed under DP# 3559 14 (l/29/2009, 

M. Doherty). The fortification levels used in concurrent method recovery were adequate to 

bracket expected residue levels. The LOQ, determined as the LLMV, was 0.010 ppm in all 

matrices. 

The petitioner also presented calculated values for the limit of detection (LOD) and LOQ based 

on the recoveries obtained at the LLMY fortification levels (0.0 1 ppm). The LOO was 

calculated by multiplying the standard deviation of recovery measurements at the LLMY by the 

one-tailed t-statistic (confidence level not reported) for seven replicates, and the LOQ was 

defined as 3X the LOD. The calculated LOD and LOQ in pome fruit were 0.001 18 ppm and 

0.00354 ppm, respectively. The calculated LOD and LOQ were 0.001 33 ppm and 0.00399 ppm, 

respectively, in stone fruit. 

Conclusions. No additional data are required in support of this data collection method. The data 

are adequate to support the proposed uses. 

5.2 Storage Stability (860.1380) 

MRID 4947260 l.der - Po me Fruit 

MRID 49472602.der - Stone Fru it 

PP#3F6542; DP# 288152, 8/ 11/04, W. Cutchin 

Residue Chemistry Summary; D355914; M. Doherty; 29 J anuary 2009 

Storage stability data were previously submitted (D288 l 52) and indicate that residues of 

penoxsulam are stable under frozen storage conditions in rice grain, straw, and immature forage 

for up to 732 days (24 months), and in processed rice bran, hulls, and polished rice for up to 390 

days ( 12.8 months). In addition, previously submitted data (0355914) indicate that residues of 

penoxsulam are stable under frozen storage conditions in grape and grape processed 

commodities for up to 359 days. 

In conjunction with the subject petition, IR-4 has submitted the results of a storage stability study 

with penoxsulam in pome fruit and stone fruit. Homogenized samples of untreated pome fruit 

and stone fruit were fortified with penoxsulam at 0.10 ppm, and stored frozen (at approximately -

l 5°C) for up to 349 days in pome fruit and 358 days in stone fruit. Pome and stone fruit samples 

were analyzed for residues of penoxsulam using LC/MS/MS Method " Determination of 

Residues of Penoxsulam in Agricultural Commodities by High Performance Liquid 

Chromatography with Tandem Mass Spectrometry." The method is similar to data collection 

method GRM 04.09 which was previously reviewed under DP# 355914 (l/29/2009. M. 

Doherty). The method is adequate for data collection based on acceptable concurrent method 

recovenes. The reported method LOQ is 0.0 I ppm for penoxsulam in/on pome fruit and stone 

Page 13of 25 
Penoxsulam Summarv of Analytical Chemistry and Residue Data DP Barcode D42501 3 

fmit. The data indicate that residues of penoxsulam are stable stored frozen for up to 349 days 

in/on pome fruit and up to 358 days in/on stone fru it. 

It is noted that no 0-day data were provided. These data are acceptable to support the storage 

conditions and durations of samples from the submitted field trials; however, storage stability 

studies should always include a 0-day sampling interval to establish the residue levels present at 

the lime samples are placed into storage (see OCSPP 860. l 380(d)(6)(i)). 

The storage durations and conditions of samples from the crop field trials and processing studies 

submitted to support this petition are presented in Table 5.2. 

Table 5.2. S umma r y of Storage Conditions a nd Durations of Samples from Crop Field Tria l a nd 

Processing Studies. 

Matrix Storage Actual Storage Duration 1 Interval of Demonstrated Storage 

Temperature Stability 

(OC) 

Pome fruit <-15 8-342 days (0.3-11 .3 months) Residues of penoxsulam are stable 

inion apple stored frozen for up to 

349 days. 

Stone fruits 8-3 89 days (0.3-1 2.8 months) Residues ofpenoxsulam were 

Dried plum 321 days ( I 0.6 months) stable in/on fresh and dried plums 

stored frozen for up to 358 days. 1 Duration from harvest to extraction. Samples were analyzed within 0-1 days of extraction. 

Conclusions. The submitted and previously submitted storage stability data are adequate to 

support the storage conditions and durations of samples from the submitted crop field trial 

studies currently under review. 

5.3 Residue Data 

5.3.1 Crop Field Trials (860.1500) 

MRID 49472601.der - Pome Fruit Field Tria ls 

MRID 49472602.der - Stone Fruit Field Tria ls 

MRID 47444403.der - Gr ape Field Tria ls 

Pome Fruit: A total of six field trials on pome fruit were conducted in the United States during 

the 201 2 and 2013 growing seasons. Four apple field trials were conducted in the North 

American Free Trade Agreement (NAFT A) Growing Zones 2 (NJ; I trial), 5 (MI; I trial), and I l 

(ID and WA; 2 trials), and two pear trials were conducted in Zones I 0 (CA; 1 trial) and 11 (ID; I 

trial). The Agency previously determined (Minutes of the 9/ 112010 ChemSAC Meeting) that a 

reduced number of tria ls (4 for apple and 2 for pear) would be acceptable, based on the 

expectation that residues would be nondetectable. 

Each fie ld site consisted of one untreated plot and one treated plot. Each treated plot received 

two soil directed applications of the 0.083 lb ai/gal emulsifiable concentrate (EC) formulation of 

Page 14 of25 
Penoxsulam Summary of Analvtical Chemistry and Residue Data DP Barcode D425013 

penoxsulam (PindarTM GT), a multiple active ingredient (MAI) formulation that also contains 

oxytluorfen at 3.93 lb ai/gal. Data and information pertaining to oxytluorfen are not addressed 

further herein. The first application was made at 0.0434-0.0459 lb ai/A, and the second 

application was made 28-30 days later at 0.0177-0.0186 lb ai/A, for a total seasonal rate of 

0.0611-0.0643 lb ai/A. At one trial (1017), an additional plot was treated at an exaggerated rate: 

the first application was made at 0.2272 lb ai/A, and the second application was made 30 days 

later at 0.0900 lb ai/ A, for a total seasonal rate of 0.3172 lb ai/ A (- 5X the field application rate). 

Broadcast applications were made to the orchard floor using ground equipment, in 12-25 gal/ A 

spray volumes with a crop oil concentrate (COC) or non-ionic surfactant (NIS) as an adjuvant. 

Samples were harvested at commercial maturity, at PHis of 56-61 days. Residue decline was not 

investigated. 

Samples were maintained frozen at the testing facilities, during shipping, and were stored frozen 

at the analytical laboratories until analysis. The maximum storage duration for samples between 

harvest and extraction was 342 days (11.3 months). For further details on these storage stability 

data, see Section 5.2. 

Samples were analyzed for residues of penoxsulam using LC/MS/MS. The LOQ was 0.0 l ppm. 

The LOQ was determined as the LLMV. Acceptable method validation and concurrent recovery 

data were reported for samples of pome fruit matrices fortified with penoxsulam at 0.0 l and O.l O 

ppm, thus validating the method. The fortification levels used in method validation and 

concurrent method recovery were adequate to bracket expected residue levels. Concurrent 

recoveries and residues in treated samples were not corrected for apparent residues in controls. 

A summary of the residue data is presented in Table 5.3.1.1 , below. Following two soil directed 

applications of a 0.083 lb ai/gal SC formulation of penoxsulam at a total application rate of 

0.0611-0.0643 lb ail A, residues of penoxsulam were below the LOQ (<0.0 I ppm) in/on all 

samples of apples and pears harvested at PHis of 56-61 days. The maximum total application 

rate used in these trials is - l .2-1.3X the maximum proposed seasonal application rate. Residues 

were also below the LOQ in/on apples from one trial harvested at a 60-day PHI following 

application at 0.3172 lb ai/ A (5X the rate used in the corresponding field trials). 

Page 15 of 25 
Penoxsulam Summary of Analvtical Chemistry and Residue Data DP Barcode D425013 

Table 5.3.1. 1. Summary of Residues from Pome Fru it Field Trials with Penoxsulam. 

Crop Matrix Analyte Total PHI nl Residues (ppm) 

Application (days) Min.2 Max.

2 LAFTJ HAFT3 Median3 MeanJ SD3 

Rate 

(lb ai/A) 

Apple Penoxsulam 0.0624-0.0643 56-6 I 4 <0.0 1 <0.0 1 <0.0 1 <0.0 1 0.01 0.01 0 

0.3 172 60 I <0.0 1 <0.0 1 <0.0 1 <0.0 1 0.01 0.01 0 

Pear 0.06 I I -0.0638 60 2 <0.0 1 <0.0 1 <0.01 <0.0 1 0.01 0.0 1 0 

1 n = number of lield trials. 2 Values based on total number of samples. 3 Values based on per-trial averages. LAFT = lowest average lield trial. I IAFr = highest average lield trial. SO= standard 

deviation. For computation of the LAFT. I IAf-T. median. mean. and standard deviation. values < LOO are assumed to be at the 

LOQ (0.0 1 ppm). 

Pome Fruit Conclusions: OCSPP Residue Chemistry Test Guideline 860.1500 (Table I) 

requirements indicate that 18 trials are needed for a pome fruit crop group tolerance, with 12 

trials on apple and 6 trials on pear. However, HED previously concluded that six total pome 

fruit trials (4 apple, 2 pear) for penoxsulam would be adequate, assuming that all residues were 

below the LOQ of0.01 ppm (Minutes of the 9/ 1/20 10 ChemSAC Meeting). Therefore, given 

that the submitted six field trials all had residues below the LOQ, the submitted field trial data is 

adequate to support the proposed pome fruit crop group tolerance at 0.01 ppm. An acceptable 

method was used for residue quantitation, and adequate storage stability data are available to 

support the sample storage conditions and durations. 

Stone Fruit: A total of nine stone fruit field trials were conducted in the United States during the 

20 12 and 20 13 growing seasons. Three sweet cherry field trials were conducted in NA FT A 

Growing Zones 5 (MT; 1 trial), I 0 (CA; I trial), and 11 (WA; 1 trial); one sour cherry field trial 

was conducted in Zone 5 (MI); two peach trials were conducted in Zones 2 (NJ; l trial) and 10 

(CA; I trial); and three plum field trials were conducted in Zones 5 (MI; I trial), l 0 (CA; l trial), 

and 12 (OR; l trial). The Agency previously determined (Minutes of the 9/ 112010 ChemSAC 

Meeting) that a reduced number of trials ( 4 for cherry, 2 for peaches, and 2 for plum) would be 

acceptable, based on the expectation that residues would be nondetectable. 

Each field site consisted of one untreated plot and one treated plot. Each treated plot received 

two soil directed applications of the 0.083 lb ai/gal SC formulation of penoxsulam (PindarTM 

GT), an MAI formulation that also contains oxyfluorfen at 3.93 lb ai/gal. Data and information 

pertaining to oxyfluorfen are not addressed further herein. The first application was made at 

0.0447-0.0563 lb ai/A, and the second application was made 26-33 days later at 0.0178-0.0198 lb 

ai/ A, for a total seasonal rate of 0.0629-0.0752 lb ail A. Broadcast applications were made to the 

orchard floor using ground equipment, in 15-27 gal/ A spray volumes with a COC or NlS as an 

adjuvant. Samples of cherries, peaches, and plums were harvested at commercial maturity, at 

PH ls of 51 -63 days. Additionally, at one plum trial (CA40) an additional sample was collected 

at a 63-day PHI and was processed at the field site to produce dried plum (prune). Residue 

decline was not investigated. 

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Penoxsulam Summary of Analytical Chemistry and Residue Data DP Barcode D4250 13 

Samples were maintained frozen at the testing facilities, during shipping, and were stored frozen 

at the analytical laboratories until analysis. The maximum storage durations for samples 

between harvest and extraction were 389 days ( 12.8 months) for fresh stone fru its and 32 1 days 

( 10.6 months) for dried plum. For further details on these storage stability data, see Section 5.2. 

Samples were analyzed for residues of penoxsulam using LC!MS/MS. The LOQ was 0.01 ppm. 

The LOQ was determined as the LLMV. Acceptable method validation and concurrent recovery 

data were reported for samples of stone fruit matrices fortified with penoxsulam at 0.01 and 0.10 

ppm, thus validating the method. The fo1tification levels used in method validation and 

concurrent method recovery were adequate to bracket expected residue levels. Concurrent 

recoveries and residues in treated samples were not corrected for apparent residues in controls. 

A summary of the residue data is presented in Table 5.3.1.2. below. Following two soil directed 

applications of a 0.083 lb ai/gal SC formulation of penoxsulam at a total application rate of 

0.0629-0.0752 lb ai/A, residues of penoxsulam were below the LOQ (<0.01 ppm) in/on all 

samples of cherries (sweet and sour), peaches, and plums harvested at PHis of 51-63 days. The 

maximum total application rate used in these trials is - l .3-l .5X the maximum proposed seasonal 

application rate. Residues were also below the LOQ in dried plum processed from plums 

harvested at a 63-day PHI. The registrant did not perform an exaggerated rate study to determine 

residue concentration during processing of plums to dried plums. Residues in all RAC samples 

were <LOQ, however. 

Table 5.3.J.2. Summary of Residues from Stone Fruit Field Trials with Penoxsulam. 

Crop Matrix Analytc Total PHI n1 Residues (ppm) 

Application (days) Min.

2 Max.2 LAFT3 llAFT3 Mcdian3 Mean3 SD3 

Rate 

(lbai/A) 

Cherry. sweet Pcnoxsulam 0.0629-0.0752 51 -6 1 4 <0.01 <0.01 <0.01 <0.01 0.01 0.01 0 

and sour 

Peach 0.0639-0.0644 57 2 <0.0 1 <0.01 <0.01 <0.0 1 0.0 1 0.0 1 0 

Plum 0.0642-0.0672 52-63 3 <0.0 1 <0.01 <0.01 <0.0 1 0.01 0.01 0 

1 n = number of field trials. 2 Values based on total number of samples. 3 Values based on per-trial averages. LAFT = lowest average field trial. 11/\FT = highest average fie ld trial. SD = standard 

deviation. For computation of the LAFT. 11/\FT. median. mean. and standard deviation. values < LOQ arc assumed to be at the 

LOQ (0.01 ppm). 

Stone Fruit Conclusions: OCSPP Residue Chemistry Test Guideline 860.1 500 (Table I) 

requirements indicate that 21 trials are needed for a stone fruit crop group tolerance, with 6 

cherry trials, 9 peach trials, and 6 plum (or fresh prune) trials. However, HED previously 

concluded that eight total stone fruit trials (4 for cherry, 2 for peaches, and 2 for plum) for 

penoxsulam would be adequate, assuming that all residues were below the LOQ of 0.0 I ppm 

(Minutes of the 9/1/2010 ChemSAC Meeting). Therefore, given that the submitted nine field 

trials (4 cherry, 2 peach, 3 plum) all had residues below the LOQ, the submitted field trial data is 

adequate to support the proposed stone fruit crop group tolerance at 0.0 I ppm. An acceptable 

Page 17 of25 
Penoxsulam Summary of Analvtical Chemistrv and Residue Data DP Barcode D425013 

method was used for residue quantitation, and adequate storage stability data are available to 

support the sample storage conditions and durations. 

Fruit, small, vi11e climbi11g, subgroup 13-07F, except f uzzy kiwifruit: Dow AgroSciences 

previously submitted crop field trial data for penoxsulam on grape. Four grape field trials were 

conducted in the United States in Zones I (NY; l trial), I 0 (CA; 2 trials), and 11 (WA; l trial), 

during the 2007 growing season. 

At each test location, two soil applications were made with a 25 g/L oil dispersion (OD) 

formulation of penoxsulam. The first application was made near the end of the grape vine 

dormant stage (bud swell; BBCH 0-5) at a target rate of 0.0357 lb ai/A, and the second 

application was made 81-130 days later, during the growing stage (BBCH 77-79), at a target rate 

0.0179 lb ai/A, for a total seasonal rate of- 0.054 lb ai/A. The application rates used in the study 

correspond to - 1. lX the maximum registered rates for applications at the dormant and growing 

stages, and to - l .2X the maximum registered seasonal rate. Broadcast applications were made 

to the vineyard floor, using ground equipment, in - 20-26 gal/A spray volumes with a COC as an 

adjuvant. Samples of untreated and treated grapes were harvested at commercial maturity, 59-60 

days after the last application. 

Grape samples were analyzed for residues of penoxsulam using LC/MS/MS Method ORM 

04.09. The method is adequate based on acceptable concurrent method recoveries. The 

validated LOQ is 0.0 I ppm for grapes. The storage stability data for grape submitted in 

conjunction with this previously submitted petition adequately supported the storage conditions 

and durations of samples from the grape field trials. 

The results of the grape field trials are summarized in Table 5.3. l.3. Residues of penoxsulam 

were nonquantifiable (<0.0 1 ppm) in/on all samples of grape harvested 59-60 days following two 

soil broadcast applications of the 25 g/L OD fomrnlation at a total rate of 0.054-0.056 lb ai/A. 

Table 5.3.1.3. Summary of Residue Da ta from Crop Field Trials with Pcnoxsulam. 

Crop matrix Total Applic. PHI Residue Levels (ppm) 

Rate (days) n Min. Max. HAFT1 Median Mean Std. 

(lbai/A) Dev. 

Grape 0.054-0.056 59-60 8 <0.01 <0.01 <0.01 <0.01 <0.01 --

Fruil. small. vine climbing, subgroup 13-07 F. excepl (uzzv kiwikuil Conclusions: Based on the 

available, previously submitted data on grape, HED concludes that there is adequate data to 

support the crop group tolerance at 0.01 ppm for fruit, small, vine climbing, subgroup l 3-07F, 

except fuzzy kiwifruit. 

Tree N ut Co11c/11sio11s: Data was previously submitted and reviewed for tree nuts (0 3359 14, M. 

Dohe11y, 01/29/2009) and a tolerance at 0.01 ppm was established. The use patterns, application 

Page 18of 25 
Penoxsulam Summary of Analytical Chemistry and Residue Data DP Barcode D425013 

rates, and representative commodities are the same for tree nut group 14 and tree nut group l 4-

12. Therefore, HED recommends in favor of allowing the conversion. 

Olive and Pomegranate Conclusions: HED previously concluded that field trial data from pome 

fruit and stone fruit could be used to support tolerances on olive and pomegranate, assuming that 

no quantifiable residues were observed in any of these field trials (HED ChemSAC minutes, 

09/01 /2010). Based on the pome and stone fruit field trial data reviewed for this petition, with 

no residues observed above the LOQ of 0.01 ppm, there is adequate data to support the proposed 

tolerances of 0.01 ppm on olive and pomegranate. 

5.3.2 Field Rotational Crops (860.1900) 

Because the proposed uses are all orchard crops, and therefore are not rotated. no data pertaining 

to rotational crops and no rotational crop restrictions are required to support the proposed uses. 

5.3.3 Processed Food and Feed (860.1520) 

MRID 49472601.der - Pome Fruit Field Trials 

MRID 49472602.der - Stone Fruit Field Trials 

MRID 47444403.de2.doc - Grape Processing 

Separate processing studies were not submitted as part of the petition currently under review. 

HED previously concluded that as long as all field trial residues were below the LOQ of 0.01 

ppm, the reduced submitted data set on pome fruit and stone fruit would be adequate to support 

the proposed uses on pome fruit, stone fruit, olive, and pomegranate (HED ChemSAC minutes, 

0910 I /20 I 0). In one of the apple field trials an exaggerated use rate was used (5X). with no 

quantifiable residues being observed in this trial. In addition, in a single plum field trial, 

conducted at - l .3X the proposed maximum seasonal use rate, residues were also below the LOQ 

in dried plum processed from plums harvested at a 63-day PHI. Finally, it is noted that in the 

previously reviewed grape processing study (- 5.8X the registered maximum seasonal rate for 

grape), there were no quantifiable residues in either the grape RAC or in the grape processed 

commodities. Therefore, HED concludes that the available data are adequate and that separate 

tolerances for processed commodities are not required for the proposed uses. 

5.3.4 Meat, Milk, Poultry and Eggs (860.1480) 

PP#SF7012; DP# 326985, 1/30/07, D. Soderberg 

No animal feeding studies were submitted with this petition. The only livestock feedstuff 

associated with the proposed uses is apple, wet pomace, which may be fed to dairy cattle; apple 

wet pomace is not considered a significant feedstuff of beef cattle, poultry, or swine. In addition, 

the only livestock feed item associated with the registered uses is almond hulls, which may also 

be fed to dairy cattle; almond hulls are not considered a significant feedstuff of beef cattle, 

poultry, or swine. 

Page 19 of25 
Penoxsulam Sumrnarv of Analvtical Chemistry and Residue Data DP Barcode 0425013 

A dietary burden for cattle, poultry, and swine was previously calculated based on the 

contribution of penoxsulam resulting from rice and aquatic uses (PP#5F70 12; DP# 326985, 

I /30/07, D. Soderberg). Dietary burdens of 0.220 ppm for beef and dairy cattle, 0. 170 ppm for 

poultry, and 0.166 ppm for swine were calculated, with the greatest contribution to each dietary 

burden (0. 150 ppm) coming from treated water. HED concluded that if no inadvertent residues 

occurred in crops irrigated with penoxsulam-treated water, the aquatic uses of penoxsulam could 

result in a 40 CFR §I 80.6(a)(3) situation for ruminant and poultry commodities; i.e., there would 

be no reasonable expectation of finite residues in ruminant and poultry commodities and no 

ruminant or poultry feeding study would need to be submitted. This conclusion was considered 

tentative, pending submission of a study on the magnitude of the residue in irrigated crops to 

support the aquatic uses. If significant residues are found in crops irrigated with penoxsulamtreated water, then livestock feeding studies may be required. 

Based on the available crop field trials for the existing and proposed uses, the dietary 

contribution of almond hulls and apple wet pomace to the dairy cattle dietary burden would be 

minimal (0.002 ppm). These calculations are summarized in Table 5.3.4, below. Therefore, 

livestock tolerances are not required for the proposed uses, as there is no expectation of fi nite 

residues in livestock commodities. 

Table 5.3.4. Calculation of Livestock Dietary Burden for Penoxsulam4 

Crop Commodity Type1 Residue % DM2 %Diet 

Dietary Contribution3 

ppm input (ppm) 

Beef Cattle 

Untreated feed NA NA NA NA NA 100 0 

Total NA NA NA NA NA 100 0 

Dairy Cattle 

Apples Pomace, wet cc 0.01 Median 40 10 0.002 

Untreated feed NA NA NA NA NA 90 0 

Total NA NA NA NA NA 100 0.002 

Poultry 

Untreated feed NA NA NA NA NA JOO 0 

Total NA NA NA NA NA 100 0 

Swine 

Untreated feed A NA NA NA 100 0 

Total NA NA NA 100 0 

I. R = Roughage; CC = Carbohydrate Concentrate; PC = Protein Concentrate. 

2. % DM = Percent Dry Matter. 

3. Contribution = ([STMR or HR ~ %OM] x %diet) for beef and dairy cart le. Contribution = (STMR or HR x 

%diet) for poultry and swine. 

4. Revisions of Feedstuffs in Table I of OPP TS Test Guideline 860. / 000 and Guidance on Constructing Maximum 

Reasonably Balanced Diets (MRBD).; Chem SAC memorandum; 30 June 2008. 

Page 20 of 25 
Penoxsulam Summary of Analytical Chemistry and Residue Data DP Barcode D4250 13 

Conclusions. No additional data are required to support the proposed uses of penoxsulam 

currently under review. Based on the available crop field trial results, the dietary contribution of 

almond hulls and apple wet pomace to the dairy cattle di etary burden would be minimal (0.002 

ppm). Therefore, HED continues to conclude that livestock tolerance are not required, as there is 

no expectation of fin ite residues in livestock commodities (i.e., there is a 40 CFR § l 80.6(a)(3) 

situation). 

5.3.5 Food Handling (860.1460) 

There are no proposed uses that are relevant to this guideline topic. 

5.3.6 Water, Fish, and Irrigated Crops (860.1400) 

There are no proposed uses that are relevant to this guideline topic. 

5.4 Food Residue Profile 

The data submitted in support of the current action (PP#4E8330) along with previously reviewed 

data, are adequate for purposes of risk assessment and tolerance assessment for the proposed 

uses under review. HED previously concluded that as long as all field trial residues were below 

the LOQ of 0.0 1 ppm, the reduced submitted data set on pome fruit and stone fruit would be 

adequate to support the proposed uses on pome fruit, stone fruit, olive, and pomegranate (HED 

ChemSAC minutes, 09/0 1/20 10). Residues were all below the LOQ (0.0 1 ppm) in submitted 

pome fruit and stone fruit field trials. These data are adequate to support the proposed tolerances 

at 0.01 ppm in pome fruit, stone fruit, olive, and pomegranate. In addition, based on previously 

submitted data, the proposed crop group conversion for tree nuts (from group 14 to group 14- 12) 

is appropriate and the data on grape is adequate to support a crop group tolerance at 0.0 I ppm for 

fruit, small, vi ne climbing, subgroup 13-07F, except fuzzy kiwifruit. Due to the lack of 

quantifiable residues in the available field trial data, residue decline could not be assessed over 

time. 

Quantifiable residues are not anticipated in livestock commodities, and livestock tolerances have 

not been established and are not required based on the proposed uses. Quantifiable residues of 

penoxsulam are not expected in rotational crops, given that all of the existing and registered 

crops are orchard crops. 

6.0 Tolerance Derivation 

Given that all field trial residues were below the LOQ of 0.01 ppm, tolerances are being set at 

0.01 ppm in the proposed commodities. Adequate field trial data were submitted in support of 

the proposed uses. 

Page 21 of 25 
Penoxsulam Summary of Analvtical Chemistry and Residue Data DP Barcode D4250 13 

The rationales for the establishment or revision of tolerances associated with the current action 

are listed in Table 6, below. 

An International Residue Limit Status sheet is appended as Attachment 1. There are no Codex, 

Canadian or Mexican MRLs established for residues of penoxsulam on any crops, including 

those under review for this petition. Therefore, there are no harmonization issues with respect to 

the proposed agricultural uses. 

TABLE 6. Tolerance Summary for Penoxsulam (40CFR .6 5). 

Proposed or Existing* Proposed or Existing* Recommended Correct Commodity Defi11itio11 ; 

Commodity Tolerance (ppm) Tolerance ( ppm) Comments 

Fruit, Pome, group I 1-10 0.01 0.01 Fruit, pome, p;roup 11-I 0 

Fruit, Stone, group 12-12 0.01 0.01 Fruit. stone, group 12-12 

Fruit, small, vine 0.01 0.01 Based on available data on grape. 

climbing, subgroup 13-

07F. except fuzzy 

kiwifruit 

Nut, Tree group 14-12 0.01 0.01 Nut, free, group 1./-12; Conversion from 

tree nut group 14. 

Olive 0.01 0.01 Based on submitted stone fruit and 

Pomegranate 0.01 0.0 1 pomc fruit field trial data. 

Nut, tree, !?TOUP 14 0.01 • Remove Conversion to tree nut group 14-12. 

Grape 0.01 • Remove Replace with tolerance on fruit, small, 

vine climbing, subgroup I 3-07F, except 

fuzzy kiwifruit. 

Pistachio 0.01• Remove Replace with the tolerance on tree nut 

group 14-12. 

* A tolerance is currently established at the listed tolerance level in the corresponding commodity. 

References 

Penoxsulam. Section 3 Registration Application for Us·e o.fGF-443 SC in Aquatic Sites and 

Request for a Tolerance Exemption (PP#5F7012) on Fish and Shellfish. Summmy of Analytical 

Chemistry and Residue Data; 0326985; 0. Soderberg; 1/30/07 

PP# 3F6542. New Chemical - Penoxsulam (XDE-638) inion Rice. Request for Petition Me/hod 

Validation; 0303172; W. Cutchin: 7/ 19/04 

Penoxsulam. Section 3 Registration Application For Use ofGF--143 T&V on Grape and Tree 

Nuts Including Pistachio. Summa1y of Analytical Chemist1y and Residue Data; D355914; M. 

Doherty; 29 January 2009. 

Penoxsulam: Revised Human Health Risk Assessment for Proposed Uses on Grapes and Tree 

Nuts; D3639 IO; C. Swartz; 9 April 2009 

Page 22of25 
Penoxsulam Summarv of Analvtical Chemistry and Residue Data DP Barcode D42SO 13 

Penoxsulam Drinking water exposure concentrations for the proposed new uses on pome fi-ttit 

group 11-10 (plus olive and pomegranate). stone fruit group (12-12), conversion of nut tree 

group 12 to tree nu/ group 14-12, and group expansion from grapes to include sma/lfruil vine 

climbing subgroup (13-07 F) and updaled assessmenl for drinking waler exposure for !he other 

uses. 0428419; J. Wolf; 28 Aug 2015. 

Minutes from ChemSAC meeting; Chemistry Science Advisory Council (ChemSAC), Health 

Effects Division (HED), Office of Pesticide Programs (OPP), Office of Chemical Safety and 

Pollution Prevention (OCSPP), USEPA; I September 2010. 

Revisions of Feedstuffs in Table 1 of OP PTS Test Guideline 860.1000 and Guidance on 

Constructing Maximum Reasonably Balanced Diets (MRBD).; ChemSAC. 

HED/OPP/OCSPP/USEPA; 30 June 2008. 

Attachments 

Attachment 1: International Residue Limit Status sheet. 

Attachment 2: Chemical Names and Structures of Penoxsulam and Metabolites. 

Page 23 of 25 
Penoxsulam Summary of Analytical Chemistrv and Residue Data DP Barcode 04250 13 

Attachment 1: International Residue Limit Status 

Penoxsulam (11903 l ; Request Date: 26 August 2015) 

Summarv of US and International Tolerances and Maximum Residue Limits 

Residue Definil ion: 

us Canada Mexico2 Codex 

40 CFR 180.605: None None 

Plant: penoxsulam (2-(2,2-difluoroethoxy)-N-

(5,8-dimethoxy[ l ,2,4] triazolol l ,5-c ]pyrimidin2-yl)-6-(trifluoromethyl)benzenesulfonamide) 

Tolerance (ppm) /Maximum Residue Limit 

Commodity' (mg k~) 

us Canada Mexico2 Codex 

Fruit, pome, group 11-l 0 0.01 

Fruit, stone, group 12-12 0.01 

Fruit, small, vine climbing, subgroup 0.01 l 3-07F, except fuzzy kiwifruit 

Nut, tree, group 14-12 0.01 

Olive 0.01 

Pomegranate 0.01 

Completed: M. Negussie; 09/03/15 

1 Includes only commodities of interest for this action. Tolerance values should be the HED recommendations and 

not those proposed by the applicant. 

2 Mexico adopts US tolerances and/or Codex MRLs for its export purposes. 

Page 24 of 25 
Penoxsulam Summary of Analytical Chemistry and Residue Data 

Attachment 2. Chemical Names and Struct ures of Pcnoxsulam and Metabolites. 

Common name: 

Company code 

Penoxsulam: XDE-638 

Penoxsulam-5-0H; 

5-0H XDE-638 

Penoxsu lam-5,8-DiOH: 

Di-OH XDE-638 

Chemical name 

2-(2,2-difluoroethoxy)-N-(5,8-

dimethoxy[ I ,2,4]triazolo[ 1,5-c] 

pyrimidin-2-yl)-6-(trifluoromethyl) 

benzenesul fonam ide 

2-(2,2-difluoroetheoxy)-N-(5,6-

dihydro-8-methoxy-5-

oxo[ 1,2,4]triazolo[ 1,5-c]-pyrimidin2-yl)-6-(tritluoromethyl)-

benzenesul fonam ide 

2-(2,2-difluoroethoxy)-N-

[ I ,2.4]triazolo[ 1,5-c ]pyrimidin-2-yl6-

( trifluoromethyl)benzenesul fonam ide 

Page 25 of 25 

Chemical structure 

DP Barcode D425013 
Penoxsulam (PC Code 11903 1 ]/Interregional Research Project No. 4 (IR-4) 

B.7.6 Residues Resulting from Supervised Trials 

(Annex IIA 6.3; Annex IHA 8.3) 

B. 7.6.1 Residues in Target Crops 

B.7.6.1.1 Pome Fruit 

Document ID: MRlD No. 49472601 

PMRA No. Not Available 

Report: Arsenovic, M. (2014) Penoxsulam+Oxytluorfen: Magnitude of the 

Residue on Pome Fruits. Laboratory Project ID: l 0944. l 3-WUR02. 

Unpublished study prepared by IR-4 Project. 171 p. 

Guidelines: EPA OCSPP Harmonized Test Guideline 860.1500 Crop Field Trials 

(August 1996) 

PMRA Regulatory Directive DIR98-02 - Residue Chemistry Guidelines, 

Section 9 - Crop Field Trials 

PMRA Regulatory Directive DIR20 l 0-05 - Revisions to the Residue 

Chemistry Crop Field Trial Requirements 

OECD Guideline 509 Crop Field Trial (September 2009) 

GLP Compliance: No deviations from regulatory requirements were reported which would 

have an impact on the validity of the study. 

Acceptability: The study is considered fully reliable. The acceptability of this study for 

regulatory purposes is addressed in the U.S. EPA Residue Chemistry 

Summary Document, 0425013, E. Holman, 12/04/2015. 

Evaluator: Douglas A. Dotson, Ph.D., Chemist /). j)~ 

Note: This Darn Evaluation Record (DER) was originally prepared under contract by Versar. Inc. (6850 Versar Center, 

Springfield. VA 2215 1; submitted 3/ 1Of 15). The DER has been reviewed by I !ED and revised to reflect current Otlice of 

Pesticide Programs (OPP) policies. 

EXECUTIVE SUMMARY 

The Interregional Research Project Number 4 (IR-4) submitted field trial data for the 

sulfonamide herbicide, penoxsulam, on pome fruit from six field trials conducted in the United 

States during the 2012 and 2013 growing seasons. Four apple field trials were conducted in the 

North American Free Trade Agreement (NAFTA) Growing Zones 2 (NJ; 1 trial), 5 (MI; l trial), 

and 11 (ID and WA; 2 trials), and two pear trials were conducted in Zones I 0 (CA; I trial) and 

11 (ID; I trial). The Agency previously determined (Minutes of the 9/ 1/2010 ChemSAC 

Meeting) that a reduced number of trials ( 4 for apple and 2 for pear) would be acceptable, based 

on the expectation that residues would be nondetectable. 

Each field site consisted of one untreated plot and one treated plot. Each treated plot received 

two soil directed applications of the 0.083 lb ai/gal suspension concentrate (SC) formulation of 

penoxsulam (PindarTM GT), a multiple active ingredient (MAI) formulation that also contains 

oxyfluorfen at 3.93 lb ai/gal. Data and information pertaining to oxytluorfen are not addressed 

further herein. The first application was made at 0.0434-0.0459 lb ai/A, and the second 

application was made 28-30 days later at 0.0177-0.0186 lb ai/A, for a total seasonal rate of 

EPA MRID #: 4947260 1 

Page I of7 

PM RA # of document: Not A vai I able 
Penoxsulam [PC Code 119031 ]/Interregional Research Project No. 4 (IR-4) 

0.0611-0.0643 lb ail A. At one trial (IO 17), an additional plot was treated at an exaggerated rate: 

the first application was made at 0.2272 lb ai/ A, and the second application was made 30 days 

later at 0.0900 lb ai/A, for a total seasonal rate of 0.3172 lb ai/A (- 5x the field application rate). 

Broadcast applications were made to the orchard floor using ground equipment, in l 2-25 gal/ A 

spray volumes with a crop oil concentrate (COC) or non-ionic surfactant (NIS) as an adjuvant. 

Samples were harvested at commercial maturity, at preharvest intervals (PHis) of 56-61 days. 

Residue decline was not investigated. 

Samples were maintained frozen at the testing facilities, during shipping, and were stored frozen 

at the analytical laboratories until analysis. The maximum storage interval for san1ples between 

harvest and extraction was 342 days (l 1.3 months). Samples were analyzed within l day of 

extraction. To support sample storage durations, a concurrent storage stability study was 

conducted with the field trial study. The data demonstrate that residues of penoxsulam were 

stable in/on fortified samples of apples stored frozen for up to 349 days; however, no 0-day data 

were provided. These data are acceptable to support the storage conditions and durations of 

samples from the submitted field trials; however, storage stability studies should always include 

a 0-day sampling interval to establish the residue levels present at the time samples are placed 

into storage (see OCSPP 860. l 380(d)(6)(i)). 

Samples were analyzed for residues of penoxsulam using a high performance liquid 

chromatography method with tandem mass spectrometry detection (LC/MS/MS). The limit of 

quantitation (LOQ) was 0.01 ppm. The LOQ was determined as the lowest limit of method 

validation (LLMV) Acceptable method validation and concurrent recovery data were reported 

for samples of pome fruit matrices fortified with penoxsulam at 0.0 l and 0.1 ppm, thus 

validating the method. The fortification levels used in method validation and concurrent method 

recovery were adequate to bracket expected residue levels. Concurrent recoveries and residues 

in treated samples were not corrected for apparent residues in controls. 

Following two soil directed applications of a 0.083 lb ai/gal SC formulation of penoxsulam at a 

total application rate of 0.0611-0.0643 lb ail A, residues of penoxsulam were below the LOQ 

( <0.0 I ppm) in/on all samples of apples and pears harvested at PH ls of 56-61 days. Residues 

were also below the LOQ in/on apples from one trial harvested at a 60-day PHI following 

application at 0.3172 lb ai/ A (5x the rate used in the corresponding field trials). 

I. MATERIALS AND METHODS 

A. MATERIALS 

Table B.7.6.1.1-1. Nomenclatu re for Pcnoxsulam. 

Common name Pcnoxsulam 

Identity 2-(2.2-difluorocthoxy)-N-(5.8-dimcthoxy[ I .2.4]triazolof I .5-c I pyrimidin-2-yl)-6-

(1rifluoromcthyl) benzcncsul fonamidc 

CAS no. 2197 14-96-2 

Comoany cxoerimental name XDE-638 

Other synonyms (if aoolicablc) NJ\ 

EPA MRID #: 49472601 

Page 2 of7 

PMRA # of document: ot Available 
Penoxsularn [PC Code 11903 1 )/Interregional Research Project No. 4 (IR-4) 

Table B.7.6.1.1-1. Nomenclature for Penoxsulam. 

B. Study Design 

1. Test Procedure 

Six field trials were conducted on apples and pears during the 2012 and 2013 growing seasons 

reflecting two soil directed applications with a 0.083 lb ai/gal SC formulation of pcnoxsulam 

(PindarTM GT) at a total rate of 0.061 1-0.0643 lb ai/ A. At one trial (ID 17), an additional plot 

was treated at a total rate 0 .3172 1 b ail A for the season. Field trial locations by N AFT A growing 

zone are summarized in Table B. 7 .6.1 . l-2. 

Table B.7.6. 1.1-2. Tria l Numbers and Geographical Locations. 

Crop o. NAFTA Gro\\ingZone Total 

Trials I 2 3 4 5 6 7 8 9 10 11 12 

Apple Sub. 1 1 1 2 4 

Req.2 4/3 2/ 1 3/2 I/I 1/ 1 514 16/ 12 

Pear Sub. 1 I I 2 

Req.2 1/1 3/2 4/3 816 1 The Agency previously determined (Minutes of the 9/1/20 I 0 ChcmSAC Meeting) that a reduced number of trials (4 for apple 

and 2 for pear) would be acceptable. based on the expectation that residues would be nondctectable. 2 As per Table 5 of 860.1500 for apple and pear: the second number renccts a 25% reduction in the number of field trials allowed 

for the crop as a representative commodity in support of a crop group/subgroup tolerance or when application results in no 

quantifiable residues. 

Locations and detailed use patterns for the trials are provided in Table 8.7.6.1 .1-3. 

Table B.7.6.1.1-3. Study Use Pattern. 

Location: City. End-use Application Surfactant/ 

State: Year Product 1 Method of Application: Timing of Volume Rate per Retreatment Total Rate Adjuvant2 

(Trial ID) Application (gal/A) Application Interval (lb ai/A) 

(lb ai/A) (days) 

Apple 

Filer. ID: 2012 0.083 lb I. Soil directed: Maturing fruit 25 0.0440 -- 0.0624 coc 

(1017) ai/gal SC 2. Soil directed: Maturing fruit 25 0.0184 30 

1. Soil directed; Maturing fruit 25 0.2272 -- 0.3172 coc 

2. Soil directed: Maturing fruit 25 0.0900 30 

Holt. Ml: 2013 0.083 lb I. Soil directed: Fruiting 20 0.0459 -- 0.0643 NIS 

(M IOI) ai/gal c 2. Soil directed: Fruit 20 0.0 184 30 

EPA MRID #: 49472601 

Page 3 of7 

PMRA # of document: Not Available 
Penoxsulam [PC Code 119031 ]/Interregional Research Project No. 4 (IR-4) 

Table B.7.6.1.1-3. Study Use Pattern. 

Location: City. End-use Application Surfactant/ 

State: Year Product 1 Method of Application: Timing of Volume Rate per Retrcatment Total Rate Adjuvant2 

(Trial 10 ) Application (gal/A) Application Interval (lb ai/A) 

(lb ai/A) (da)S) 

Cream Ridge, 0.083 lb I. Soil directed: Green/small fru it 13 0.0452 -- 0.0635 NIS 

NJ: 2012 ( J08) ai/gal SC 2. Soil directed: Green fruit 12 0.0183 28 

Prosser. WA: 0.083 lb I. Soil directed: rruiting 18 0.0449 -- 0.0629 IS 

2012 (W A35) ai/gal SC 2. Soil directed: Fruiting 17 0.0180 30 

Pear 

Davis, CA: 2012 0.083 lb I. Soil directed: Fruiting 22 0.0434 -- 0.06 11 coc 

(CAl47) ai/gal SC 2. Soil directed: Fruiting 23 0.0177 28 

Buhl. ID: 2013 0.083 lb I. Soil dircctc:d: Early fruit 20 0.0452 -- 0.0638 IS 

(IDOi) ai/gal SC 2. Soil directed: r ruiting 2 1 0.0186 29 .. 1 Multiple active ingn:dient (MAI) suspension concentrate (SC) fom1ulation (Pindar GT) containing 0.083 lb a1/gal penoxsulam 

and 3.93 lb ai/gal oxyfluorfen. 2 COC = crop oil concentrate: NIS = non-ionic surfactant. 

Apples and pears were grown and maintained according to typical agricultural practices. 

Irrigation was used to supplement rainfall at all trial sites with the exception of the MI and NJ 

sites. 1 o unusual weather conditions were reported to have adversely affected crop growth or 

yields during the study. 

Sample Handling and Preparation 

Duplicate control and treated samples of apples and pears were harvested 56-61 days after the 

last application. Samples were placed in frozen storage at the field sites within 1.5 hours of 

harvest, except for samples from the 2012 CA trial, which were transported directly to the 

analytical laboratory, IR-4 Western Region Laboratory at University of California, Davis (WRL; 

Davis, CA), on the day of harvest. Samples from the remaining 2012 trials were shipped frozen 

via ACDS freezer truck to the WRL, where they were homogenized in the presence of dry ice 

and stored frozen (<- I 5°C). Samples from these trials, along with samples prepared for the 

storage stability study, were subsequently transferred (within 197-303 days of receipt) via ACDS 

freezer truck to the Food and Environmental Quality Laboratory (FEQL; Richland WA) for 

analysis. Samples from the 2013 trials were shi pped via overnight air express on dry ice directly 

to FEQL. where they were homogeni zed in the presence of dry ice. At FEQL, samples were 

stored frozen (<-I 5°C) until extraction for analysis. 

2. Description of Analytical Procedures 

Residues of penoxsulam were determined in apples and pears using a working LC/MS/MS 

method similar to the method, ·'Determination of Residues of Penoxsulam in Agricultural 

Commodities by High Performance Liquid Chromatography with Tandem Mass Spectrometry." 

A complete description of method, including minor modifications, was provided in the 

submission. The method is similar to data collection method GRM 04.09 which was previously 

reviewed under DP# 355914 ( 1/29/2009, M. Doherty). 

EPA MRID #: 4947260 1 

Page4of 7 

PMRA # of document: Not Available 
Penoxsulam [PC Code 119031 ]/Interregional Research Project No. 4 (IR-4) 

Briefly, homog~nized s~p~e~ ~ere extracted wit acet~mitrij~ (ACN ~wat~! C§ ~)Q, :v) and 

centrifuged. An aliquot of the supernatant was diluted with 0.1 N HCI and purified by solid 

phase extraction (SPE) on Strata-XL cartridges. Residues were eluted with ACN. The eluate 

was brought to volume with a stable isotope internal standard solution of [' 5

N- 13C]penoxsulam, 

then was further diluted with ACN:methanol:water containing 0.1 % acetic acid (15: 15:70, v:v:v) 

and additional internal standard solution. The final solution was analyzed by LC/MS/MS. 

The LOQ (determined as the LLMV) was 0.01 ppm in pome fruits. The petitioner also presented 

calculated values for the LOO and LOQ based on the recoveries obtained at the LLMV 

fortification levels (0.0 1 ppm). The LOD was calculated by multiplying the standard deviation 

of recovery measurements at the LLMV by the one-tailed t-statistic (confidence level not 

reported) for seven replicates, and the LOQ was defined as 3x the LOO. The calculated LOD 

and LOQ were 0.00118 ppm and 0.00354 ppm, respectively. 

II. RESULTS AND DISCUSSION 

Method performance was evaluated during method validation and by use of concurrent recovery 

samples by fortifying samples of untreated pome fruit with penoxsulam at 0.0 I and. 0. 1 ppm. All 

recoveries were within the acceptable range of 70-120%; therefore the method was considered to 

be valid for the analysis of penoxsulam residues on pome fruits (Table B.7.6. 1.1-4). The 

fortification levels used in method validation and concurrent recovery were adequate to bracket 

expected residue levels. Method validation and concurrent recoveries were not corrected for 

apparent residues in controls. 

For determination of residues of penoxsulam, the detector response was linear (coefficient of 

determination, r2 2::0.9929) within the range of 0. 1-2.0 ng/mL. Representative chromatograms of 

control samples, fortified samples, and treated samples were provided. The control 

chromatograms generally had no peaks of interest above the chromatographic background. The 

fortified sample chromatograms contained only the analyte of interest, and peaks were 

symmetrical and well defined. Apparent residues of penoxsulam in controls were below the 

LOQ (<0.0J ppm). Residues in treated samples were not corrected for residues in controls. 

Table B.7.6. 1.1-4. Summary o f M ethod Va lida tion a nd Procedural/Concurrent Recoveries of Penoxsulam 

from Pom c Fruits. 

Matrix I Analyte I Fortification I Sample size I Recoveries1 

I Mean :I: Std. Dev. 

Level (ppm) (n) (%) (%) 

Method Validation 

Apple I Penoxsulam I 0.01-0. 1 I 6 I 75-99 I 88 ± 10 

Concurrent Recoveries 

Pome fruit I Penoxsulam I 0.01-0. 1 I 6 I 82-116 I 94 ± 16 

1 Each recovery value is the average of duplicate analyses. Method validation and concurrent recoveries were not corrected for 

apparent residues in controls. 

The field residue samples were stored frozen (<-15°C) for a maximum of 342 days (11.3 

months) from harvest to extraction for analysis (Table B.7.6. l. l-5a). All samples were analyzed 

within I day of extraction. To support sample storage durations, a concurrent storage stability 

study was conducted with the field trial study; the results are presented in Table B.7.6.1.1-5b. 

The data demonstrate that residues of penoxsulam were stable in/on fortified samples of apple 

EPA MRID #: 49472601 

Page 5 of7 

PMRA # of document: Not Available 
Penoxsu lam [PC Code 11 9031 )/Interregional Research Project No. 4 (IR-4) 

stored frozen for up to 349 days. No 0-day data were provided. These data are acceptable to 

support the storage conditions and durations of samples from the submitted field trials; however, 

storage stability studies should always include a 0-day sampling interval to establish the residue 

levels present at the time samples are placed into storage (see OCSPP 860. 1380(d)(6)(i)). 

Table B.7.6. I.I-Sa. S ummary of Storage Conditions. 

Matrix Anal)1e Storage Actual Storage Duration' Interval of Demonstrated Storage Stability 

Tempcrature 

(OC) 

Pomc fruit Penoxsulam <-15 8-342 days (0.3- I I .3 months) Residues of penoxsulam were stable in/on 

apples stored fTozen for up to 349 days. 2 

1 Interval from harvest 10 extracuon. Samples were analyzed within 0-1 days of extraction. 2 Refer to Table B.7.6. 1.1-Sb. 

Table B.7.6. 1.1-Sb. Stability of Pe noxsula m Residues in Apple Stored Frozen (<-15°C). 

Commodity /\nalyte Spike Storage Fresh Fortification Stored Sample Mean Corrected % 

Level interval Recovery(%) Recoveries (%) Recovery(%) recovery1 

(ppm) (days) 

Apple Pcnoxsulam 0. 1 349 97 98, 108. 122 109 11 3 

1 Corrected for recovery in the freshly fortified sample. 

The results from the submitted field trials are presented in Tables B.7.6. 1.1-6 and 8.7.6.1.1 -7. 

Following two soil directed applications of a 0.083 lb ai/gal SC formulation ofpenoxsulam at a 

total application rate of 0.0611-0.0643 lb ai/ A, residues of penoxsulam were below the LOQ 

(<0.01 ppm) in/on all samples of apples and pears harvested at PH Is of 56-6 1 days. Residues 

were also below the LOQ in/on apples from one trial harvested at a 60-day PHI following 

application at 0.3172 lb ai/ A (Sx the rate used in the corresponding field trials). 

T able B.7.6. 1.1-6. Residue Data from Pome Fruit Field Trials with Pcnoxs ulam. 1 

Location: City. State; Year Zone Crop Commodity Total Rate PHI Residues (ppm)2 [Average! 

(Trial ID) Variety (lb ail/\) (days) 

Apple 

Filer. ID: 2012 (ID 17) 11 Red Delicious Fruit 0.0624 60 NO. ND [<0.0 1) 

0.3172 60 ND. ND [<0.0 1) 

Holt. Ml: 2013 (MIOI) 5 Thome Empire Fruit 0.0643 6 1 ND, ND [<0.0 1] 

Cream Ridge. J: 2012 (NJ08) 2 Rome Fruit 0.0635 56 ND. ND [<0.0 1) 

Prosser. WA; 2012 (WA35) II Fuji Fruit 0.0629 6 1 ND. ND [<0.01) 

Pear 

Davis, C/\; 20 I 2 (CA 14 7) 10 Shinko Fruit 0.061 I 60 NO. ND [<0.0 1] 

Buhl. ID: 2013 (IDOi) I I Bartlett Fruit 0.0638 60 ND. ND [<0.0ll 

1 A multiple active ingredient (MAI) suspension concentrate (SC) formulation (Pindar GT) containing 0.083 lb ai/gal penoxsulam 

and 3.93 lb ai/gal oxyf1uorfen was used. 2 ND = 1

ot detected (<LOO). The LOQ was 0.01 ppm. and the LOO was 0.00118 ppm. Per-trial averages were calculated by 

the study reviewer using the LOQ for valu1:s reported as <LOQ. /\II samples were analyzed in duplicate. 

EPA MRID #: 49472601 

Page 6 of7 

PMRA # of document: Not Available 
Penoxsulam [PC Code 119031 )/Interregional Research Project No. 4 (I R-4) 

Table B.7.6. 1.1-7. Summary of Residues from Pomc Fruit Field Trials w ith Penoxsu lam. 

Crop Matrix Analyte Total PH I nl Residues (ppm) 

Applica1 ion (days) Min.

2 Max.1 LAFT3 l-IAFT3 lcdian3 Mean3 SD3 

Ra1e 

(lb ai/A) 

Apple Penoxsulam 0.0624-0.0643 56-61 4 <0.0 1 <0.01 <0.0 1 <0.0 1 0.01 0.0 1 NA 

0.3 172 60 I <0.01 <0.0 1 <0.01 <0.0 1 0.0 1 0.0 1 NA 

Pear 0.0611-0.0638 60 2 <0.01 <0.01 <0.01 ~H 0.01 . 0.01 NA 

1 n = number of field trials. · 2 Values based on 101al number of ampl~s. 3 Values based on per-trial averages. 1.,.AFT = lowest average field tria l, HAFT= highest average field trial. SD = standard 

deviation. For 'complilatfoh. of the L'AFi'. HAFT. median. mean. and stancfard deviation. values'< LOQ-are assumed to be at the 

LOQ{0.0 1 pptn): NA :;: Not applitable: ' ~ . ··! -.-. r '"· " • .... , - • • : •• • .. .. . ·: , • : 

Ill. CONCLUSIONS 

The pome fruit field trials are considered to be scientifically acceptable. Following two soil 

directed applications of a 0.083 lb ai/gal SC formulation of penoxsulam at a total application rate 

of 0.06 11-0.0643 lb ai/ A, residues of penoxsulam were below the LOQ ( <0.0 I ppm) inion all 

samples of apples and pears harvested at PHis of 56-61 days. Residues were also below the 

LOQ inion apples from one trial harvested at a 60-day PH I following application at 0.3 172 lb 

ail A (5x the rate used in the corresponding field trials). 

An acceptable method was used for residue quantitation, and adequate storage stability data were 

submitted to support the study. 

REFERENCES 

D355914, Penoxsulam. Section 3 Registration Application For Use of GF-443 T&V on Grape 

and Tree Nuts Including.Pistachio. Summary of Analytical Chemistry and Residue Data, M. 

Doherty, 1 /29/2009 

EPA MRID #: 4947260 1 

Page 7 of7 

PMRA # of document: Not Available 
Penoxsulam [PC Code 119031 ]/Interregional Research Project No. 4 (I R-4) 

B.7.6 Residues Resulting from Supervised Trials 

(Annex llA 6.3; Annex IHA 8.3) 

B.7.6.1 Residues in Target Crops 

B. 7.6.1.2 Stone Fruit 

Document ID: MRIO No. 49472602 

PMRA No. Not Available 

Report: Arsenovic, M. (20 14) Penoxsulam+Oxytluorfen: Magnitude of the 

Residue on Stone Fruits. Laboratory Project ID: I 0899.1 3-WURO I. 

Unpublished study prepared by IR-4 Project. 208 p. 

Guidelines: EPA OCSPP Harmonized Test Guideline 860. 1500 Crop Field Trials 

(August 1996) 

PMRA Regulatory Directive OIR98-02 - Residue Chemistry Guidelines, 

Section 9 - Crop Field Trials 

PMRA Regulatory Directive DIR20 I 0-05 - Revisions to the Residue 

Chemistry Crop Field Trial Requirements 

OECD Guideline 509 Crop Field Trial (September 2009) 

GLP Compliance: No deviations from regulatory requirements were reported whi ch would 

have an impact on the validity of the study. 

Acceptability: The study is considered to be fully reliable. The acceptability of this study 

for regulatory purposes is addressed in the U.S. EPA Residue Chemistry 

Summary Document, 0425013, E. Holman, 12/04/20 15. 

Evaluator: Douglas A. Dotson, Ph.D., Chemist IJ. ~ 

Note: This Data Evaluation Record (DER) was originally prepared under contract by Versar. Inc. (6850 Versar Center. 

Springfield, VA 22 151 ; submiucd 3/10/15). The DER has been reviewed by HED and revised to renect current Omce of 

Pesticide Programs (OPP) policies. 

EXECUTIVE SUMMA RY 

The Interregional Research Project Number 4 (IR-4) submitted field trial data for the 

sulfonamide herbicide, penoxsulam, on stone fruit from nine fi eld trials conducted in the United 

States during the 2012 and 2013 growing seasons. Three sweet cherry field trials were 

conducted in the North American Free Trade Agreement (NAFTA) Growing Zones 5 (MI; I 

trial), I 0 (CA; I trial), and 11 (WA; I trial); one sour cherry field trial was conducted in Zone 5 

(Ml); two peach trials were conducted in Zones 2 (NJ; l trial) and I 0 (CA; I trial); and three 

plum field trials were conducted in Zones 5 (MI; l trial), 10 (CA; l trial), and 12 (OR; l tri al). 

The Agency previously determined (Minutes of the 911 /20 10 ChemSAC Meeting) that a reduced 

number of trials (4 for cherry, 2 for peaches, and 2 for plum) would be acceptable, based on the 

expectation that residues would be nondetectable. 

Each field site consisted of one untreated plot and one treated plot. Each treated plot received 

two soil directed applications of the 0.083 lb ai/gal suspension concentrate (SC) formulation of 

penoxsulam (PindarTM GT), a multiple active ingredient (MAI) formulation that also contains 

oxyfluorfen at 3.93 lb ai/gal. Data and information pertaining to oxyfluorfen are not addressed 

EPA MRJD ff: 49472602 

Page I of8 

PMRA #of document: Not Available 
Penoxsulam [PC Code 11903 1 ]/Interregional Research Project No. 4 (IR-4) 

further herein. The first application was made at 0.0447-0.0563 lb a i/A, and the second 

application was made 26-33 days later at 0.0 178-0.0198 lb ail A, for a total seasonal rate of 

0.0629-0.0752 lb ai/A. Broadcast applications were made to the orchard floor using ground 

equipment, in 15-27 gal/ A spray volumes with a crop oil concentrate (COC) or non-ionic 

surfactant (NIS) as an adj uvant. San1ples of cherries, peaches, and plums were harvested at 

commercial maturity, at preharvest intervals (PHJs) of 51-63 days. Additionally, at one plum 

trial (CA40) an additional sample was collected at a 63-day PHI and was processed at the field 

site to produce dried plum (prune). Residue decline was not investigated. 

Samples were maintained frozen at the testing facilities, during shipping, and were stored frozen 

at the analytical laboratories until analysis. The maximum storage intervals for samples between 

harvest and extraction were 389 days (12.8 months) for fresh stone fruits and 321 days (10.6 

months) for dried plum. All samples were analyzed on the day of extraction. To support sample 

storage durations, a concurrent storage stability study was conducted with the field trial study. 

The data demonstrate that residues of penoxsulam were stable in/on fortified samples of fresh 

and dried plum stored frozen for up to 358 days; however, no 0-day data were provided. These 

data are acceptable to support the storage conditions and durations of samples from the submitted 

field trials; however, storage stability studies should always include a 0-day sampling interval to 

establish the residue leve ls present at the time samples are placed into storage (see OCSPP 

860. I 380(d)(6)(i)). 

Samples were anal yzed for residues of penoxsulam using a high performance liquid 

chromatography method with tandem mass spectrometry detection (LC/MS/MS). The limit of 

quantitation was 0.0 1 ppm. The LOQ was determined as the lowest limit of method validation 

(LLMV). Acceptable method validation and concurrent recovery data were reported for samples 

of stone fruit matrices fortified with penoxsulam at 0.0 I and 0.1 ppm, thus validating the 

method. The fortification levels used in method validation and concurrent method recovery were 

adequate to bracket expected residue levels. Concurrent recoveries and residues in treated 

samples were not corrected for apparent residues in controls. 

Following two soil directed applications of a 0.083 lb ai/gal SC formulation of penoxsulam at a 

total application rate of 0.0629-0.0752 lb ai/ A, residues of penoxsulam were below the LOQ 

(<0.0 I ppm) in/on all samples of cherries (sweet and sour), peaches, and plums harvested at PHis 

of 5 1-63 days. Residues were also below the LOQ in dried plum processed from plums 

harvested at a 63-day PHI. The registrant did not perform an exaggerated rate study to determine 

residue concentration during processing of plums to dried plums. Residues in all RAC samples 

were <LOQ, however. 

I. MATERIALS AND METHODS 

A. MATERIALS 

Table B.7.6. 1.2-1. Nomenclature fo r Penoxsulam. 

Common name Pcnoxsulam 

Identity 2-(2.2-difluoroethoxy)-N -(5.8-dirnethoxy[ 1.2.4Jtriazolof1.5-c j pyrimidin-2-yl)-6-

(tri fluoromcthyl) bcnzenesul fonamidc 

CAS no. 2 197 14-96-2 

Comnanv exuerimental name XDE-638 

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Table B.7.6. 1.2-1. Nomenclature fo r Penoxsulam. 

Other synonyms (if aoolicablc) I NA 

F I' 

) 0 ,.-CH, 

0 0 ~ 6:11 S N~ N " N 

0 l'N-1~ H .....-:: hN 

CF. 

, 0 

'CH 3 

B. Study Design 

1. Test Procedure 

Nine field trials were conducted on cherries (sweet and sour), peaches, and plums during the 

2012 and 2013 growing seasons refl ecting two soil directed applications with a 0.083 lb ai/gal 

SC formulation or penoxsulam (Pindar TM GT) at a total rate of 0.0629-0.0752 lb ai/ A. Field trial 

locations by NAFTA growing zone are summarized in Table B.7.6.1.2-2. 

Two cherry trials were conducted at the same location. HED has detem1ined that these trials are 

independent as detailed in the table below. 

Independent Trial Determination' 

Crop Trial Nos. Differences Decision 

Cherry Ml03 & Ml04 Same location Independent 

~: Ulster (sweet) vs. Montmorency (tan) 

Timing: 19-day offset in first soil directed application and 

26-day offset in harvest 

*No other differences found 1 All assc.:ssments are based on the replicate trial guidance presented in draft memo 568_Cntena for Independence of Trials 

04/23/2013 (EPA and PMRA). 

Table B. 7.6. 1.2-2. Tria l Numbers a nd Geograph ical Locations. 

Crop No. NAFTA Growing Zone Total 

Trials I 2 3 4 5 6 7 8 9 10 11 12 

Cherry. sour Sub.

1 I I 

(tan) Rcq. 2 1/1 5/4 I/I 1/0 816 

Cherry, sweet Sub. 1 I I I 3 

Req.2 2/2 2/2 3/2 1/0 8/6 

Peach Sub.1 I I 2 

Req.

2 I/I 413 110 I/I Ill 4/3 12/9 

Plum Sub.1 I I I 3 

Rcq.

2 1/1 514 1/0 111 816 

1 The Agency previously determined (Minutes of the 9/ 1/2010 ChemSAC Meeting) that a reduced number of trials (4 for cherry. 

2 for peach. and 2 for plum) would be acceptable. based on the expectation that residues would be nondetectablc. 2 As per Table 5 of 860.1500 for chc.:rry. peach. and plum; the second number rcnects a 25% reduction in the number of field 

1rials allowed for the crop as a representative commodity in suppon of a crop group/subgroup tolerance or when application 

results in no quantifiable residues. 

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Locations and detailed use patterns for the trials are provided in Table B.7.6.1 .2-3. 

Table B.7.6. 1.2-3. Study Use Pattern. 

Loca1ion: City. End-use Application Surfac1ant 

Stale: Year Product1 Method of Application: Timing of Volume Rate per Retreat- Total I 

(Trial ID) Application (gal/A) Application ment Rate /\djuvant2 

(lb ai/A) Interval (lb ai/A) 

(days) 

Cherry, sweet 

Parlier. CA: 2012 0.083 lb I. Soil directed: Bud swell 15 0.0452 -- 0.0630 NIS 

(C/\4 I) ai/gal SC 2. Soil directed; 131ooming/fruiting 15 0.0 178 29 

llolt. Ml: 2013 0.083 lb I. Soil direc1ed: Early bud 22 0.0492 -- 0.0687 NIS 

(MI03) ai/gal SC 2. Soil directed; Bud 22 0.0195 33 

Prosser. WA; 2012 0.083 lb I. Soil directed; 13ud 19 0.0447 -- 0.0629 NIS 

(WA ii } ai/gal SC 2. Soil directed; Setting fruit 18 0.0182 30 

Cherry. sour 

Hoh. Ml: 2013 0.083 lb I . Soil directed; Early bud 20 0.0563 -- 0.0752 NIS 

(Ml04) ai/gal SC 2. Soil directed: Bloom 21 0.0189 30 

Peach 

Parlier, CJ\; 20 12 0.083 lb I. Soil directed: Fruiting 25 0.0459 -- 0.0644 NIS 

(C/\42) ai/gal SC 2. Soil directed; Fruiting 26 0.0185 28 

Cream Ridge. NJ: 0.083 lb I. Soil directed; Small green fruit 18 0.0454 -- 0.0639 NI S 

2012 (NJ04) ai/gal SC 2. Soil directed: Green fruit 18 0.0185 28 

Plum 

Parlier. CA: 20 12 0.083 lb I. Soil directed: Fruiting 21 0.0458 -- 0.0642 coc 

(CA40) ai/gal SC 2. Soil directed: Fruiting 2 1 0.0184 26 

Holt. Ml: 20 13 0.083 lb I. Soil directed: Fruiting 1-2" 21 0.0476 -- 0.0657 NIS 

(M l02) ai/gal SC 2. Soil directed: Fruiting 20 0.0181 28 

Brooks. OR: 2012 0.083 lb I . Soil directed: Green frui t 26 0.0474 -- 0.0672 NIS 

(OR I?) ai/gal SC 2. Soil directed; Green frui t 27 0.0198 27 1 Muluple active ingredient (MAI) suspension concentrate (SC) fo nnulation (Pindar GT) containing 0.083 lb ai/gal penoxsulam 

and 3.93 lb ai/gal oxynuorfen. 2 COC = crop oil concentrate; NIS = non-ionic surfactant. 

Cherries, peaches, and plums were grown and maintained according to typical agricultural 

practices. Irrigation was used to supplement rainfall at the CA and WA trial sites. No unusual 

weather conditions were reported to have adversely affected crop growth or yields during the 

study. 

Sample Handling and Preparation 

Duplicate control and treated samples of cherries, peaches, and plums were harvested 51-63 days 

after the last appl ication. Additionally, at the CA40 tri al, additional control and treated plum 

samples were harvested at a 63-day PHI, and subsamples were processed to produce dried plums 

(prunes) within I day of harvest. Samples of dried plum were prepared by drying halved fruit in 

a dryer for - 16 hours. All samples were placed in frozen storage at the field sites within 2. 75 

hours of harvest/processing. Samples from the 20 I 2 trials were shipped frozen via ACDS 

freezer truck to the analytical laboratory, IR-4 Western Region Laboratory at University of 

California, Davis (WRL; Davis, CA), where they were homogeni zed in the presence of dry ice 

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and stored frozen ( <- l 5°C). Samples from these trials, along with samples prepared for the 

storage stability study, were subsequently transferred (within 226-328 days of receipt) via ACDS 

freezer truck to the Food and Environmental Quality Laboratory (FEQL; Richland WA) for 

anal ysis. Samples from the 2013 trials were shipped frozen via ACDS freezer truck or overnight 

air express on dry ice directly to FEQL within 2-33 days of collection. At the analytical 

laboratory, samples were homogenized in the presence of dry ice and were stored frozen 

( <-l 5°C) until extraction for analysis. 

2. Description of Analytical Procedures 

Residues of penoxsulam were determined in stone fruits using a working LC/MS/MS method 

similar to the method, "Determination of Residues of Penoxsulam in Agricultural Commodities 

by High Perfonnance Liquid Chromatography with Tandem Mass Spectrometry." A complete 

description of method, including minor modifications, was provided in the submission. The 

method is similar to data coll ection method GRM 04.09 which was previously reviewed under 

OP# 3559 14 (1 /29/2009, M. Doherty). 

Briefly, homogenized samples were extracted with acetonitrile (ACN):water (80:20, v:v) and 

centrifuged. An aliquot of the supernatant was diluted with 0.1 N HCI and purified by solid 

phase extraction (SPE) on Strata-XL cartridges. Residues were eluted with ACN. The eluate 

was brought to volume with a stable isotope internal standard solution of [1 5N- 13C]penoxsulam, 

then was further diluted with ACN:methanol:water containing 0.1 % acetic acid ( 15: 15:70, v:v:v) 

and additional internal standard solution. The final solution was analyzed by LC/MS/MS. 

The LOQ (determined as the LLMV) was 0.0 I ppm on stone fruits. The petitioner also 

presented calculated values for the LOD and LOQ based on the recoveries obtained at the LLMV 

fortifi cation levels (0.0 I ppm). The LOO was calculated by multiplying the standard deviation 

of recovery measurements at the LLMV by the one-tailed t-statistic (confidence level not 

reported) for 9 (stone fruit) or 6 (dried plum) replicates, and the LOQ was defined as 3x the 

LOO. The calculated LOO and LOQ were 0.00 133 ppm and 0.00399 ppm, respectively, for 

stone fruit. The calculated LOD and LOQ were 0.00495 ppm and 0.01486 ppm, respectively, for 

dried plum. 

II. RESULTS AND DISCUSSION 

Method performance was evaluated during method validation and by use of concurrent recovery 

samples by fortifying samples of untreated stone fruits with penoxsulam at 0.0 I and 0. 1 ppm. 

Recoveries were generall y within the acceptable range of 70-120%; therefore, the method was 

considered to be valid for the analysis of penoxsulam residues on stone fruits (Table B.7.6.1.2-

4). The fortification leve ls used in method validation and concurrent recovery were adequate to 

bracket expected residue levels. Method validation and concurrent recoveries were not corrected 

for apparent residues in controls. 

For determination of residues of penoxsulam, the detector response was linear (coefficient of 

determination, 1

2 ;:::0.9898) within the range of 0.1-2.0 ng/mL. Representative chromatograms of 

control samples, fortified samples, and treated samples were provided. The control 

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chromatograms generally had no peaks of interest above the chromatographic background. The 

fortified sample chromatograms contained onl y the analyte of interest, and peaks were 

symmetri cal and well defined. Apparent residues of penoxsulam in controls were below the 

LOQ ( <0.0 l ppm). Residues in treated samples were not corrected for residues in controls. 

Table B.7.6.1 .2--t Summa ry of Method Va lidation and Procedural/Concurrent Recoveries of Penoxsulam 

from Stone Fru its. 

Matrix I Anal)1e I Fortification I Sample size I Recoveries1 

I Mean ± Sid. Dev.

2 

Level (ppm) (n) (%) (%) 

l\lethod Validation 

Stone fruits I Penoxsulam I 0.01-0. I I 6 I 79-112 I 93 :!: 12 

Dried plum I I 0.01-0. 1 I 6 I 106-115: 123. 123 I I IS ± 7.1 

Concurrent Recoveries 

Stone fruits I Penoxsulam I 0.01-0. 1 I 9 I 79-109 I 87 :!: 9.8 

Dried plum I I 0.0 1 I 3 I 86-91 I 89 ± 2.6 

1 Each recovery value is the average of duplicate analyses. Method val 1dat1on and concurrent recoveries were not corrected for 

apparent residues in controls. 2 Mean recovery and standard deviation for combined fortification levels were determined by study reviewer. 

The field residue samples were stored frozen ( <- 15°C) for a maximum of 389 days ( 12.8 

months) for fresh stone fruit and 321 days (I 0.6 months) for dried plum from harvest/processing 

to extraction for analysis (Table 8.7.6. 1.2-Sa). All samples were analyzed on the day of 

extraction. To support sample storage durations, a concurrent storage stability study was 

conducted with the field tri al study; the results are presented in Table B.7.6.1.2-Sb. The data 

demonstrate that residues of penoxsulam were stable in/on fortified samples of fresh and dried 

plum stored frozen for up to 358 days; no 0-day data were provided. These data are acceptable 

to support the storage conditions and durations of samples from the submitted field trials; 

however, storage stability studies should always include a 0-day sampling interval to establish 

the residue levels present at the time samples are placed into storage (see OCSPP 

860.1380(d)(6)(i)). 

Ta ble B.7.6. 1.2-Sa. Summa r y of Storage Conditions. 

Matrix Analyte Storage Actual Storage Duration1 Interval of Demonstrated Storage Stability 

Temperature 

(OC) 

Stone fruits Penoxsulam <-IS 8-389 days (0.3-12.8 months) Residues of penoxsu lam were stable in/on fresh 

Dried plum 32 1 days (I 0.6 months) and dried plums stored frozen for up to 358 days. 2 

1 Interval from harvest to extraction. Samples were analyzed on the day of extraction. 2 Refer to Table B. 7.6. 1.2-Sb. 

Table B.7.6.1.2-Sb. Stability of Penoxsulam Residues in Plum Ma trices Stored Frozen (<-15 °C). 

Commodity Analyte Spike Storage Fresh Fonification Stored Sample Mean 

Level interval Recoveries(%) Recoveries(%) Recovery(%) 

(ppm) (days) 

Plum Pcnoxsulam 0.1 358 11 6 104, 102, 106 104 

Dried plum 124 123. 124. 11 3 120 

1 Corrected for recovery in freshly fortified samples. 

Corrected % 

recovery1 

90 

97 

The results from the submitted field trials are presented in Tables B.7.6.1.2-6 and B.7.6.1.2-7. 

Following two soil directed applications of a 0.083 lb ai/gal SC formulation of penoxsulam at a 

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total application rate of 0.0629-0.0752 lb ail A, residues of penoxsulam were below the LOQ 

(<0.0 1 ppm) in/on all samples of cherries (sweet and sour), peaches, and plums harvested at PHTs 

of 5 1-63 days. Residues were also below the LOQ in dried plum processed from plums 

harvested at a 63-day PHI. 

Table B. 7.6. 1.2-6. Residue Da ta fro m Stone f ruit Field T ria ls with Penoxs ulam.

1 

Location: City. State: Year Zone Crop Commodity Total Rate Pill Residues (ppm)2 (Averagcj 

(Trial ID) Variety (lb ai/A) (days) 

Cherry, sweet 

Parlier. CA; 2012 (CA4 I) JO Bing Fruit 0.0630 59 ND. ND [<0.01] 

Holt. Ml: 2013 (M103) 5 Ulster Fruit 0.0687 51 ND. ND i<0.01) 

Prosser, \VA: 2012 (\VA 11 ) 11 Bony sweet Fruit 0.0629 61 ND, ND 1<0.01] 

Cherry, sour 

Holt. Ml: 2013 (M J04) 5 Montmorency tart Fruit 0.0752 61 ND. ND [<0.01) 

Peach 

Parlier. CA: 2012 (CA42) 10 June Flame Fruit 0.0644 57 ND. ND [<0.0ll 

Cream Ridge. NJ; 20 12 (NJ04) 2 Loring Fruit 0.0639 57 NO, ND [<0.0 1] 

Plum 

Parlier. CA; 2012 (CA40) 10 French prune Fruit 0.0642 63 ND, NO, (0.0024) [<0.01] 

Dried plum ND [<0.01] 

lloh, Ml: 2013 (M l02) 5 Stanley Fruit 0.0657 59 ND, (0.0014) f<0.01] 

Brooks. OR: 20 12 (OR 17) 12 Brooks Fru it 0.0672 52 NO, ND [<0.0 IJ 1 A multiple active ingredient (MA I) suspension concentrate (SC) formulation (Pindar GT) containing 0.083 lb ai/gal penoxsulam 

and 3.93 lb ai/gal oxyOuorfcn was used. 2 ND = Not detected (<LOD). The LOQ was 0.0 I ppm. and the LODs were 0.00133 and 0.00495 ppm for fresh and dried fruit. 

n.:spectivcly. Residues between the LOO and LOQ arc presented in parentheses. Per-trial averages were calculated by the study 

reviewer using the LOQ for values reported as <LOQ. All samples were analyzed in dupl icate. 

Table B.7.6. 1.2-7. Sum ma ry of Resid ues from Stone Fru it Field Trials with Penoxsulam. 

Crop Matrix Analyte Total PHI n' Residues (ppm) 

Application (days) Min.

2 Max.2 LAFTl llAFT3 Median3 Mean3 SD3 

Rate 

(lb ai/A) 

Cherry. sweet Penoxsulam 0.0629-0.0752 51-61 4 <0.01 <0.01 <0.01 <0.01 0.01 0.01 NA 

and sour 

Peach 0.0639-0.0644 57 2 <0.01 <0.01 <0.01 <0.01 0.01 0.01 NA 

Plum 0.0642-0.0672 52-63 3 <0.01 <0.01 <0.01 <0.01 0.01 0.01 NA 1 n = number of field trials. 1 Values based on total number of samples. 3 Values based on per-trial averages. LAFT = lowest average field trial, HAFT= highest average field trial, SO = standard 

deviation. for computation of the LAFT. I IAFT, median, mean, and standard deviation. values< LOQ arc assumed to be at the 

LOQ (0.0 I ppm). NA = Not applicable. 

III. CONCLUSIONS 

The stone fruit field trials are considered scientifically acceptabl e. Following two soil directed 

applications of a 0.083 lb ai/gal SC formulation of penoxsulam at a total application rate of 

0.0629-0.0752 lb ai/A, residues of penoxsul am were below the LOQ (<0.0 1 ppm) in/on all 

samples of cherries (sweet and sour), peaches, and plums harvested at PHis of 51 -63 days. 

Residues were also below the LOQ in dried plum processed from plums harvested at a 63-day 

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PHI. The registrant did not perfo1m an exaggerated rate study to determine residue 

concentration during processing of plums to dried plums. Residues in all RAC samples were 

<LOQ, however. 

An acceptable method was used for residue quantitation, and adequate storage stability data were 

submitted to support the study. 

REFERENCES 

D3559 14, Penoxsulam. Section 3 Registration Application For Use of GF-443 T & Von Grape 

and Tree Nuts Including Pistachio. Summary of Analytical Chemistry and Residue Data, M. 

Doherty, 1/29/2009 

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