Page 1 of 23 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460 OFFICE OF CHEMICA L SA FETY A ND POLLUTION PREVENTION MEMORANDUM Date: August 31 , 2010 SUBJECT: Fluazifop - P - Butyl. Request for the Registration of a Reduced Pre - Harvest Interval for

Application of the Venture L End - Use Product on Imported Potatoes. Summary of Analy tical Chemistry

and Residue Data. PC Code: 122809 DP Barcode: 372408 & 380010 Decision No.: 423996 Registration No. : 100 - 1001 Peti tion No.: 9E7651 Regulatory Action: New Use Registration Risk Assessment Type: NA Case No.: 2285 T XR No.: NA CAS No.: 79241 - 46 - 6 MRID No.: Summary Table Provided Below 40 CFR: 180. 411 FROM: Peter Savoia, Chemist

Risk Assessment Branch V Health Eff

ects Division (7509P) THRU: William H. Donovan, Ph.D., Chemist

Risk Assessment Branch V Health Effects Division (7509P) TO: Kathry

n Montague/Michael Walsh, RM Herbicide Branch Registration Division (7505P) MRID Sum ma ry Table MRID No. Stud y Type Com me nts 4 7920401 860.1 340 ( Residue Analytical Method ) 47 920402 .der.doc & 47920403.der.doc 47 920402 860.1500 ( potato ) 47 920402 .der.doc 47 920403 860.1500 ( potato ) 47 920403 .der.doc 47 920404 860.15 00 ( reduced PHI for potato ) No s eparate der 47 9204 05 860.1520 ( potato ) 47 920405 .der.docF luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 2 of 23 Prior actions made to develop the fluazifop - P - butyl herbicide active ingredient (ai) have identified a number of studies that are required for completing data gaps. In accordance, a number of Data Call - In (DCI ) sub missions have been provided by the registrant in order to satisfy these database requirements. These studies are as follows: • Carrot and endive nature of residue studies, test guideline 860.1300. • Ruminant and poultry

nature of residue studies, test guideline 860.1300. • Radiovalidation study

made for the tolerance enforcement method proposed for analy zing plants, test guideline 860.1340. • Method validation study made for the tolerance enforcement method proposed for analy zin g poultry , eggs and livestock, test guideline 860.1340. • Cattle and poultry

feeding studies, test guideline 860.1480. • Confined rotational crop study , test guideline 860.1850. Inall, an assessment of these studies is currently in progress and will be addressed in a separate memorandum in due course. Should the results of the studies submitted in response to the registration DCIimpact the conclusions reached in this summation, appropriate changes will be made at that time. No further discussion of th ese in review studies will be included in this memorandum. Executive Summary Fluazifop - P - butyl [(

R ) - 2 - (4 - ((5 - (trifluoromethyl) - 2 - py ridinyl)oxy

)phenoxy )propanoic acid, butyl ester] is a selective herbicide registered for postemergenc e control of perennial and annual grass weeds . It is the resolved isomer (R enantiomer) of fluazifop - butyl [( R,S ) - 2 - (4 - ((5 - (trifluoromethyl) - 2 - py ridinyl)oxy

)phenoxy ) propanoic acid, butyl ester]. After application fluazifop - P - butyl is rapidly hydroly zed to fluazifop acid (R enantiomer) where it accumulates in the meristems of grass weeds working to interrupt lipid sy nthesis in susceptible plants . Fluazifop - P - butyl end - use products are registered in the United States to Sy ngenta Crop Protection, Inc. under the trade names Fusilade ® , Fusion ® , Oramec ® , Tornado ® , and Ty phoon ®

. This herbicide active ingredient is the resolved isomer (R enantiomer) of fluazifop - butyl (PC code 122805) which has since been cancelled resulting in only flu azifop - P - butyl to be supported for re registration. The Residue Chemistry Chapter of the Fluazifop - P - Butyl TRED (referred to herein as the Residue Chapter) was issued on August 17, 2005 (DP No. 319907, S. L . Kinard, 08/17/2005). It provided the Residue Chemistry Assessments that went into the “Report on FQPA Tolerance Reassessment Progress and Interim Risk Management Decisions (TRED) for fluazifop - P - butyl.” Inthe current petition, Sy ngenta Crop Protection, Inc . requests the establishment of a tolerance f or the residues of fluazifop - P - butyl in/on imported potatoes and its processed commodities:

Potato , tuber s ................................ ................................ ........ 1.1 ppm P otato , wet peel ................................ ................................ .... 1. 1 ppm Potato , chips ................................ ................................ ......... 3.0 ppm Potato , granules/flakes ................................ ......................... 5.0 ppmF luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 3 of 23 The end - use product s relevant for this petition request are the VENTURE Land Fusilade® MAX(X) h erbicide E mulsifiable C oncentrate (EC) formulation s . These end - use products are identical with both of them containing approximately 1 4. 0 % fluazifop - P - butyl active ingredi ent (ai) equivalent to 125 g ai / L . For this action, Sy ngenta has requested to amend the label of the VENTURE Lproduct by adding this new use on potatoes . In addition, the registrant is requesting that the application instructions a lso be amended to allo w for treatments to be made at the late seasonal timed P re - Harvest In terval (P HI ) of 45 day s . Treatments of these products are to be made as a single foliar spray appli cation not to exceed the maximum labeled rate of 250 g ai/ha timed at a PHIof 45 or 90 day s . F luazifop - butyl isomers are L ist B chemicals with parent and fluazifop - acid (free and conjugated) regulated for tolerance expression as the residues of concern used to determine misuse (DP No. D319907, S. L . Kinard, 08/17/ 20 05). It s registered u ses include dry beans, carrot, cotton, endive (escarole) , macadamia nut, onion, peanut, pecan, soy bean, spinach, stone fruit, and sweet potato . It also carries tolerances with regional registrations on asparagus, coffee, pepper, and rhubarb along with bei ng registered for use on lawns as a weed control application. Tolerances are established under 40 CFR §180.411(a)(1) and (c)(1) for residues of fluazifop - butyl, including free and conjugated fluazifop, expressed as fluazifop . F or fluazifop - P - butyl , inclu ding free and conjugated fluazifop (R isomer), tolerances are likewise established under 40 CFR §180.411(a)(2) and (c)(2) with residues e xpressed as fluazifop . The nature of the residue in both plants and livestock cannot yet be described as adequately un derstood. For the current action, an acceptable soy bean metabolism study

is available, and the soy bean metabolism study

will also support the proposed uses on the other crops addressed herein. The Metabolism Assessment Review Committee (MARC) concluded that the residues of concern for tolerance expression for plants and animals are parent and fluazifop - acid (free and conjugated) since they are adequate to determine misuse . The MARC also concluded that the residues of concern in plants for risk assessment are parent, fluazifop - acid (free and conjugated), 5 - trifluoromethyl - 2 - py ridone, and 2 - (4 - hydroxy phenoxy ) propionic acid (free and conjugated). The residues of concern in animals for risk assessment are parent and fluazifop - acid (free and conjugated) (DP No. D 298939, S. L. Kinard, 6/22/ 20 04). There are adequate residue analy tical methods listed in PAM I I for tolerance enforcement and data collection. For the enforcement of tolerances for fluazifop - P - butyl residues of concern, a High Performance Liquid Chromatography /Ultra - Violet Spectrometry ( HPL C/UV ) method is available for crop commodities . In conjunction , HPL C/UV and Gas Chromatography /Mass Spectrometry ( GC/MS ) methods are available for milk and animal commodities. The stated qu antitation limits are 0.02 - 0.05 ppm for crop commodities, 0.01 ppm for milk, and 0.02 ppm for animal tissues. In addition, the FDA PESTDATA database dated 11/01 (PAM Volume I , Appendix I ) indicates that fluazifop - butyl (only

) is completely

recovered using Multiresidue Methods Sections 302 (L uke Method; Protocol D) and 303 (Mills, Onley , and Gaither Method; Protocol E, nonfatty food). To support this petition, the field trial samples were analy zed for residues of total fluazifop using a High Performance Li quid Chromatography /Mass Spectrometry

/Mass Spectrometry

(HPL C/MS/MS) protocol. This procedure is a common moiety method which works by

hydroly zing the fluazifop ester or acid conjugates so that a total determination can be made. This protocol is adequate for data collection based upon acceptable method validation and concurrent method recoveries. The validated Li mit of Quantitation (L OQ) verified in potatoes is 0.010 ppm for this method.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 4 of 23 The proposed new uses included in this petition will request the establishment of tolerance s on potato crops which are commonly recognized as being livestock feedstuffs. Given that these uses will be established on imported commodities , residues of fluazifop - P - butyl in/on potatoes will not result in being a contributo r to the dietary burden of cattle. In accordance, it will not be necessary to provide a re - calculation of dietary

burden in support of this action. The conclusions determined for the secondary transfer of fluazifop - P - butyl residues to meat, milk, poultry , and eggs made prior for the pending uses established on dry beans and peanuts remain current. The submitted field trial data are adequate to support the proposed seasonal use pattern demonstrated on potatoes. The maximum residues of total fluazifop wer e 0.61 ppm in/on potatoes harvested at a PHIof 45 day s following a single broadcast foliar application of the 250 g ai/ha EC formulation made at the 1 x seasonal rate . These results demonstrate the application of the fluazifop - P - butyl herbicide made on po tatoes within the various geographic/climatological production regions of Canada. The number and location of field trials were sufficient in scope since they were undertaken in line with the requirements set forth in the PMRA Regulatory Directive to evalu ate this use. In accordance, MRI D No. 47920402 contains 13 field trials and MRI D No. 47920403 provides an additional 3 more to satisfy the Canadian requirement for a total of 16 studies in all. The field trial data were entered into the NAFTA tolerance/M RLspreadsheet which determines that a recommended tolerance of 1.0 ppm is appropriate for regulating residues of fluazifop - P - butyl in/on potatoes. The submitted processing study is adequate in providing a determination of residue concentration factors fo r fluazifop - P - butyl in potato processed commodities. Processing of the potato Raw Agricultural Commodity

( RAC ) bearing quantifiable residues of fluazifop resulted in no concentration of residues in the peel (1.1x processing factor). However, total fluazi fop residues were found to concentrate in the potato cooked product, chips and dried flakes at a processing factor of 1.4x, 3.3x, and 6.4x, respectively . The se data , along with the Highest Average Field Trial ( HAFT ) residue, indicate that a tolerance limi ts are needed for fluazifop - P - butyl residues of concern in potato chips at 2.0 ppm and granules/flakes at 4.0 ppm. Regulatory Recommendations and Residue Chemistry Deficiencies Provided that a revised Section F is submitted , there no residue chemistry issues that would preclude establishing tolerance limits for the use of fluazifop in/on potatoes . The proposed uses and the submitted data support the following tolerances for total fluazifop residues (fluazifop - P - butyl and free and conjugated fluazifop - P) expressed as fluazifop, in/on:

Potato ................................ ................................ ................... 1.0 ppm P otato, chips ................................ ................................ ......... 2.0 ppm P otato, granules/flakes ................................ ......................... 4.0 ppm A new human health risk assessment which includes potatoes is forthcoming in a separate document. 860.1 2 00 Directions for Use Th e submitted bridging study data made for the Venture L and Fusilade Maxx EC formulation s show that when they

are applied to potatoes at 1x the maximum seasonal rate, the resulting residues will be similar. If the registrant so chooses, a revised section B could be submitted which includes this use for both product formulations.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 5 of 23 860.1 380 Storage Stability Adequate storage stability data are available to support sample storage conditions incurred for the potato RAC, but none have been provided for the pro cessed commodities. This is required since the processed commodities do not appear to have been analy zed within thirty

(30) day s of production. 860.1550 Proposed Tolerances The proposed tolerances should be revised to reflect the recommended tolerance l evels and correct commodity

definitions as specified in Table 8 . Background Fluazifop - P - butyl [(

R ) - 2 - (4 - ((5 - (trifluoromethyl) - 2 - py ridinyl)oxy

)phenoxy )propanoic acid, butyl ester] is a selective herbicide used for the post - emergence control of perennial and annual grass weeds. It is the resolved isomer (R enantiomer) of fluazifop - butyl (PC code 122805) which has since been cancelled resulting in only fluazifop - P - butyl to be supported for re - registration. The fluazifop butyl isomers are L ist B chemicals with parent and fluazifop - acid (free and conjugated) regulated for tolerance expression as the residues of concern used to determine misuse (DP No. D319907, S. L . Kinard, 08/17/2005). T he Phase 4 Reviews for fl uazifop - butyl and fluazifop - P - butyl were completed on 02/26/1991. The subsequent Phase 5 review of these studies has also been completed as well. This includes the Residue Chemistry Science Assessments with respect to the Report on FQPA Tolerance Reasses sment Progress and Interim Risk Management Decisions (TRED) for fluazifop - P butyl issued on 08/17/2005. For review, the chemical structure and nomenclature of fluazifop - P butyl, including its free acid fluazifop - P a s well as the phy sicochemical properties of the technical grade of fluazifop - P - butyl are presented below in Tables 1 and 2. T able 1. Fluazifop - P - butyl Nom enclature. Compound

N F 3 C O O H C H 3 O O C 4 H 9 ( n )

Common name Fluazifop - P - butyl Company experimental name Not avai lable. IUPAC name B utyl (2 R ) - 2 - (4 - {[5 - (trifluoromethyl)pyridin - 2 - yl]oxy}phenoxy)propanoate CAS name (R ) - 2 - (4 - ((5 - (trifluoromethyl) - 2 - pyridinyl)oxy)phenoxy)propanoic acid, butyl ester CAS registry number 79241 - 46 - 6 End - use product (EP) Fusilade® DX (2 lb/gal EC; EPA Reg. No. 100 - 1070) Compound

N F 3 C O O H O O H C H 3

Common name Fluazifop - P (free acid) Chemical name (R ) - 2 - (4 - [5 - (trifluoromethyl - 2 - pyridinyl ) oxy]phe noxy)propionic acidF luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 6 of 23 T able 2. Physicochem ical Pro perties of Fluazifop - P - butyl . Parameter Value Reference 1 Melting point/range Decomposes at 210 o C 164 o C at 0.02 mm Hg 2002 Farm Chemicals Handbook RCB No . 1674, 2/3/87, L. Cheng pH Not dispersible in water RCB No. 1674, 2/3/87, L. Cheng Density 1.22 g/cc (PAI) and 1.20 g/cc (T) at 20 o C RCB No. 809, 6/3/86, L. Cheng Water solubility 1 mg/L RCB No. 1674, 2/3/87, L. Cheng Solvent solubility Soluble in most organic solvents >500 g/L in acetone, dichloromethane, ethyl acetate, hexane, methanol, toluene, an d xylene 2002 Farm Chemicals Handbook RCB No. 1674, 2/3/87, L. Cheng Vapor pressure 3 x 10 - 8 KPa at 20 o C RCB No. 809, 6/3/86, L. Cheng Dissociation constant, pK a - 3. 1 (by calculation) RCB No. 809, 6/3/86, L. Cheng Octanol/water partition coefficient, Log(KOW ) 4.5 at 20 o C RCB No. 809, 6/3/86, L. Cheng UV/visible absorption spectrum Not available 1 DP No. D 348246, D. Soderberg , 09/16/2008 8 60.1200 Directions for Use A summary

of the proposed/amended use patterns for cultivating potatoes are presented in Table 3. The information presented in Table 3 was obtained from a specimen label provided by Sy ngenta for the Venture L ® Herbicide ( Canadian Reg. No. 21209 ). Table 3 . Summary of Directions for Use of Fluazifop - P - butyl . Applic. Timing, Type, and Equip. Formulation [EPA Reg. No.] Max. No. Applic. per Season Max. Season al

Applic. Rate ( g ai/ha ) PHI

(days) Use Directions and Limitations Potato Postemergence Ground Venture L ® Herbicide , 125 g ai / L EC [ 21209 ] 1 250 45 May be mixed with Lexone or sencore formulations for early post emergent application. The general lab el use directions specify that the Venture Lherbicide will be less effective when weeds are not growing rapidly because of stress from lack of moisture, excessive moisture, flooding, low temperature and/or very low humidity . Treatments should be applied to actively growing grass weeds that have 3 to 5 fully developed leaves for best results. Spray mist and drift is to be avoided with applications never to be made by aircraft or within 15 m of fish bearing waters . The use of adjuvants (crop oil concentrate, non - ionic surfactant, or other approved adjuvants) plus liquid nitrogen fertilizer may

be used on specified crops such as soy beans and potatoes . Conclusions : The label directions are adequate to allow evaluation of the residue data relative to the proposed use on potatoes .F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 7 of 23 860.1300 Nature of the Residue - Plants Residue Chemistry Memo, DP No. D 319907, 0 8/17/ 20 05, S. L. Kinard (TRED Residue Chemistry Chapter) HED MARC Decision Memo, DP No. D 298939, 0 6/22/ 20 04, S. L. Kinard The Fluazifop - P - Butyl Residue Chapter of the TRED (DP No. 319907, S. L . Kinard, 08/17/2005) concluded that the nature of the residue in soy beans is adequately

understood. No new plant metabolism studies for the proposed new use crops were submitted as part of the curren t petition. T he MARC has determined that for tolerance expression, parent and fluazifop - acid (free and conjugated) are the residues of concern since they are adequate to determine misuse. The MARC also concluded that the residues of concern in plants for risk assessment are parent, fluazifop - acid (free and conjugated), 5 - trifluoromethyl - 2 - py ridone, and 2 - (4 - hydroxy phenoxy ) propionic acid (free and conjugated). 860.1300 Nature of the Residue - Livestock Th e MARC has concluded that for tolerance express ion and risk assessment, parent and fluazifop acid (free and conjugated) are the residues of concern since they are adequate to determine misuse . 860.1340 Residue Analytical Methods Residue Chemistry Memo , DP No. D 319907 , 0 8 / 17 / 20 0 5 , S. L. Kinard (TRED Residue Chemistry Chapter) ; 47920401.der.doc, Residue Analytical Method

– Potato; 47920402.der.doc & 47920403.der.doc , Crop Field Trial /Residue Decline

– Potato ; 479204005.der.doc, Processed Food & Feed - Potato Enforcement m ethods For the enforcement of tolerances for fluazifop - P - butyl residues of concern, PAM Vol. I I lists two methods, Method Ifor animal tissues and milk and Method I I for oily and non - oily

crops. The stated detection limits are 0.02 - 0.05 pp m for crops, 0.01 ppm for milk, and 0.02 ppm for animal tissues. In Method I , samples (except fat) are extracted with acetonitrile/acetone/hexane, which separates residues of fluazifop and fluazifop - butyl (found in the acetonitrile/acetone layer) from res idues of fluazifop lipophilic conjugates (found in the hexane layer). Fluazifop and fluazifop - butyl are determined in milk using an HPL C/UV instrumental technique. In tissue samples, fluazifop - butyl is converted to fluazifop via hydroly sis, and then its residues are methylated using diazomethane, and determined by

GC/MS. Fluazifop lipophilic conjugates (for both milk and tissue samples) are cleaned up by

florisil chromatography , hydroly zed to fluazifop, and determined by HPL C/UV. For fat, samples are ex tracted with chloroform/methanol at reflux (2 hours) and residues of fluazifop, fluazifop - butyl, and lipophilic conjugates are hydroly zed to fluazifop, methylated, and determined by GC/MS. For Method I I, residues of fluazifop - butyl, fluazifop, and any est er or acid conjugates are extracted from crop samples using acetonitrile and hydrochloric acid. Residues are then hydroly zed to fluazifop and cleaned up using a coagulation procedure, solvent partitioning, and silica column chromatography for determinatio n by

HPL C/UV. Residues may be confirmed by

GC/MS following methylation with diazomethane. Consequently , neither of the enforcement methods distinguishes the optical isomers of fluazifop - butyl or fluazifop.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 8 of 23 Data collection method s ( MRI D No . 47920401) For this petition, field trials acquiring samples of potato tubers were analy zed for residues of total fluazifop (fluazifop - P - butyl, fluazifop free and conjugated) using an HPLC/MS/MS protocol. This procedure entitled, “Fluazifop - P - Butyl: Residue Analy tical Method for Total Fluazifop Analy sis in Crops (Bolygo 1998)”, is denoted as Zeneca Method RAM 287/02. It is a common moiety method used for data collection which works by hydroly zing the fluazifop ester or acid conjugates so that a total determination can be made. A complete copy of the original method, including any modifications made to this procedure, was included in the submission. Li kewise, a formal copy of the Zeneca RAM 287/02 protocol was also submitted as MRI D No. 47920401 to support this petition requesting a fluazifop - P - butyl import tolerance be established in/on potatoes. Method validation was conducted prior to the analy sis of field samples using a series of blanks and untreated potato samples fortified at 0.01, 0.05 , and 0.10 ppm. In doing so, the reported L OQ of 0.01 ppm was demonstrated as being achievable in potatoes when using this method. Following the criterion of obtaining a minimal response of 3:1 signal/noise, the L imit of Detection (L OD) was thus establis hed at 0.00330 ppm based upon fortifications analy zed at 3x below the L OQ. In addition, the performance of the method was likewise continuously monitored throughout this study by analy zing a series of blanks and fortified controls along with each analy tic al batch of samples. Samples of the potato RAC and its processed commodities were analy zed for total residues of fluazifop (fluazifop - P - butyl, fluazifop free and conjugated) using a GC/MS protocol. This procedure entitled, “Gaschromatograpische Bestmmung von Fluazifop und Fluazifop - P - butyl in Pflanzlichem Material”, is denoted as laboratory test protocol P - 14.077. It is a common moiety method which works by forming the methyl ester of fluazifop through extraction so that a total determination can be m ade. A detailed summary of the original method was provided within the submission. The validated L OQ for this methodology is 0.01 ppm for fluazifop - P - butyl expressed as total fluazifop in all potato matrices. It is based upon the analy sis of untreated s amples fortified with fluazifop - P - butyl worked up concurrently with the determination of the treated unknowns. The validated L OQ is therefore defined as the lowest fortification level yielding acceptable recoveries (70

– 120 % R) at analy sis. In addition, method performance was also monitored throughout the study by analy zing a series of blanks and fortified controls along with each analy tical batch of s amples. Conclusions . The existing GC/MS enforcement method , or this modified version, is adequate for c ollecting data on residues of fluazifop in/on potato commodities. Itis adequate for enforcing tolerance s on these commodities. T he data collection methods used by the registrant were likewise shown to be adequate for determining the magnitude of fluazif op residues in potato commodities acquired in support of this petition. 860.1360 Multiresidue Methods Residue Chemistry Memo , DP No. 319907 , 0 8 / 17 / 20 05 , S. L. Kinard (TRED Residue Chemistry Chapter) The FDA PESTDATA database date d 11/01 (PAM Volume I , Appendix I ) indicates that fluazifop butyl is completely

recovered using Multiresidue Methods Sections 302 (Luke Method; Protocol D) and 303 (Mills, Onley , and Gaither Method; Protocol E, nonfatty food); recovery

using Section 304 (M ills Method; Protocol F, fatty food) is variable.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 9 of 23 860.1380 Storage Stability Storage stability

data have been reviewed in conjunction with earlier actions undertaken for fluazifop P - butyl which indicate that its residues are stable in a wide variety of cr op commodities. As such, its s tability in frozen potatoes has previously been investigated in prior reports generated by Sy ngenta. These reports show that fortified potatoes demonstrate no loss of fluazifop - p - butyl when stored frozen at - 18°C for 18 months (DP No. D348246, D. Soderberg, 09/16/2008). Given the results obtained from the pr ior stability

study made on potatoes , adequate data are available to support the sample storage intervals and conditions incurred in th e field trial s ub missions . Althoug h adequate data are available to support sample storage conditions of the potato RAC, none were provided to substantiate the holding times that were incurred for the processed commodities. This is required since the processed commodities do not appear to have been analy zed within thirty

(30) day s of production. A summary of the storage durations and conditions of the samples from the crop field trials and processing studies provided to support this petition are presented below in Table 4 for review . T a ble 4 . Summary of Storage Conditions .

Matrix Storage Temperature (°C) Actual Storage Duration 1 Interval of Demonstrated Storage Stability Potato/ MRID No. 47920402 ≤ - 10 °C 63 - 142 days (2.1 - 4.7 months) 548 2

- Total fluazifop residues appear relatively stable under frozen conditions in/on potatoes for up to 1 8 months . Potato/ MRID No. 47920403 ≤ - 10 °C 94 - 142 days (3.1 - 4.7 months) 548 2

- Total fluazifop residues appear relatively stable under frozen conditions in/on potatoes for up to 1 8 months . Potato Processing/ MRID No. 47920402 Tuber ≤ - 18 °C 200 days (6.7 months) 548 2

- Total fluazifop residues appear relatively stable under frozen conditions in/on potatoes for up to 1 8 months . Peel None. Cooked Chips Granules/Flakes 1 Actual storage duration from harvest to analysis. 2 DP No. 348246, D. Soderberg, 09/16/2008 . Co nclusions : Previously

s ubmitted storage stability data demonstrate that total res idues of fluazifop P - butyl are stable in/on vari ety of crops which include the potato RAC. The se data are adequate in supporting all of the potato RAC sample storage conditions and durations that were incurred for testing relevant to th is petition request (PP#9E7651). However, no data were provided to substantiate the holding times that were incurred for any of the potato processed commodities which were analy zed . Given that none of the processed potato fractions appear to have been analy zed within thirty (30) day s of production , additional stability data may be required for these commodities. 860.1400 Water, Fish, and Irrigated Crops For the purpose of this summary , this guideline require ment is not relevant to this evaluation since Fluazifop - P - butyl has no registered or proposed use s on water or aquatic food and feed crops .F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 10 of 23 860.1460 Food Handling For the purpose of this summary , this guideline require ment is not relevant to this evaluation since Fluazifo p - P - butyl has no food - handling uses which are being proposed. 860.1480 Meat, Milk, Poultry, and Eggs Residue Chemistry Memo, DP No. D348246 , 09 /1 6 / 20 0 8 , D. Soderberg ( PP#7F7289 Residue Chemistry Chapter) Inevaluating the data provided to support this p etition, the establishment of tolerance limits will be recommended for several RACs commonly recognized for use as livestock feedstuffs. This would include establishing tolerance limits for citrus dried pulp and sugar beet tops which are requested in part with this action. The maximum theoretical dietary burdens to livestock were previously evaluated in the prior residue chemistry chapter prepared to support pending uses on dry beans and peanuts (DP No. D348246, D. Soderberg, 09/16/2008). The resulting theoretical dietary burdens of fluazifop - P - butyl to livestock were put forward with the updated version of Table 1 (Table 1 Feedstuffs June 2008) and are presented below in Table 5 for review. Table 5. Calculation of Dietary Burdens of Fluazifop - P - butyl Residues to Livestock. Feedstuff Ty pe 1 % Dry Matter 2 % Diet 2 Recommended Tolerance (ppm) Dietary Contribution

(ppm) 3 Beef Cattle Soybean, hulls R 90 20 2.5 0.555 Untreated CC CC NA 65 NA 0 Soybean, meal PC 92 15 2.5 0.408 TOTAL BURDEN -- -- -- 0.963 Dairy Cattle Soybean, hulls R 90 15 2.5 0.417 Untreated R R NA 30 NA 0 Carrot, culls CC 12 10 2.0 1.667 Untreated CC CC NA 35 NA 0 Soybean, seed PC 89 15 2.5 0.421 TOTAL BURDEN -- -- -- 2.505 Poultry Untreated CC CC NA 75 NA 0 Soybean, meal PC -- 25 2.5 0.625 TOTAL BURDEN -- -- -- 0.625 Swine Untreated CC CC NA 85 NA 0 Soybean, meal PC -- 15 2.5 0.375 TOTAL BURDEN -- -- 0.375 1 R: Roughage; CC: Carbohydrate concentrate; PC: Protein concentrate. 2 OPPTS 860.1000 Table 1 Feedstuffs ( June 2008). 3 Contribution = ([tolerance /% DM] X % diet) for beef and dairy cattle; contribution = ([tolerance] X % diet) for poultry and swine. 4 N/A: Not applicable. Tolerances/uses of Fluazifop - P - butyl have not been registered or proposed for th is feedstuff.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 11 of 23 These calculations are considered tentative because plant and animal metabolism studies remain outstanding and additional field trials are required for some crops. It was also noted that there are label restrictions against the grazing or harvesting of peanut hay as well as soy

bean forage and hay which are appropriate according to Table 1 of 860.1000. Inall, the addition of the use on peanut d id not affect the theoretical dietary burden of fluazifop residues to livestock. Soy beans were f

ound to have a larger impact and these matrices were incorporated into the previous dietary burden calculations. The effect of use on cowpea forage and hay along with residues on the soy bean aspirated grain fractions will be evaluated after these data hav e been submitted. Prior calculated dietary burden maximums of fluazifop - P - butyl were reported to beef/dairy cattle at 4.49 ppm, 1.00 ppm to poultry , and 0.70 ppm to swine. These differ significantly from the updated values presented in Table 5 due to the current calculations being based on a “reasonably balanced” diet and the reduction in the diet percentage for carrot culls. Nonetheless, in assessing the new uses pursuant to this petition, potato crops are commonly recognized as being livestock feedst uffs. Given that these uses will be established as import tolerances, residues of fluazifop - P - butyl in/on potatoes will not result in being a contributor to the dietary burden of cattle. As a result, it will not be necessary to provide a re - calculation o f dietary burden in support of this action. The prior calculations tentatively depicting the secondary

transfer of fluazifop - P - butyl residues to meat, milk, poultry , and eggs made for the pending uses established on dry beans and peanuts remain current. Conclusions : No change in the tolerances of meat, milk, poultry , and eggsis needed at this time. 860.1500 Magnitude of the Residue in Crops DER Reference s: 47 920402 .der.doc ( potato

– 13 trials )

47 9204 0 3 .der.doc ( potato

– 3 trials ) For this curre nt petition, Sy ngenta is requesting that a new import tolerance for the residues of fluazifop - P - butyl in/on potatoes and its processed commodities be established. To satisfy data requirements, field trial studies have been made on potatoes within the vari ous geographic/climatological production regions of Canada and submitted by the registrant to support this petition. The number and location of field trials were sufficient in scope since they were undertaken in line with the requirements set forth in the PMRA Regulatory Directive to evaluate this use. In accordance, MRI D No. 47920402 contains 13 field trials and MRI D No. 47920403 provides an additional 3 more to satisfy the Canadian requirement for a total of 16 studies in all. A summary of the residue data acquired from these field trial studies which were undertaken are presented below in Table 6. T able 6 . Summary of Residue Data fromC rop Field Trials with Fluazifop - P - butyl . Commodity Total Rate

( g ai/ha ) PHI

(days) End - Use

Product Residue Lev els (ppm) n Min. Max. HAFT 1 Median 2 (STMdR) Mean 2

(STMR) Std. Dev. 2 Potato 0.250 44 - 46 Venture L 32 < 0.0033 0.61 0.55 0.0 65 0.11 0.1 3 1 HAFT = Highest Average Field Trial. 2 For mathematical purposes, in the calculation of the median, mean, and s tandard deviation, 0.00 165 ppm (half the LO D ) was used for residues reported as less than the LO D (<0.0 033 ppm). 3 Not Applicable (NA).F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 12 of 23 Potatoes (MRI D No. 47920402) To determine the magnitude of fluazifop - P - butyl residue found in/on potatoes within the various production regions of Canada, thirteen (13) field trials were conducted during the 2008 growing season. The thirteen (13) field trials held for this study were carried out in Canadian growing zones 1, 1A, 5, 5B, 7A, 12 and 14 all of which are known to be significant potato cultivation regions of the country . As such, two trials were held at New Glasgow, Elm Creek, and Malden along with single ones made at Albany , Branchton, St . Marc - sur - Richeilieu, Taber, Abbotsford, Minto, and Innisfall. Each trial site was managed according to the practices routinely followed by

Canadian commercial producers for cultivating potatoes. Test plots were roughly 10 - 100 square meters in size, lar ge enough to provide a 1 Kg sample of mature potato tubers to be collected from at least six (6) different plants. At each study

location, market quality

potato samples were cultivated using both untreated control and treated test plots. Each treated test plot received a single application of the VENTURE L end - use product made at the maximum labeled rate of 250 g ai/ha so that late seasonal treatments could be evaluated. In doing so, this comparison will provide sufficient data to support establishing a Pre Harvest Interval (PHI ) of 45 day s in addition to currently registered early

seasonal treatments made at 90 day s. The actual rate of application ranged from 94.2% to 103.4% of the targeted amount of product designated for treatment. The treatment r egimen also included two (2) residue decline studies made at the New Glasgow and Elm Creek sites with samples collected at - 7, 0, +7, +14 and +21 day s of normal commercial harvest. The application procedure followed was ty pical of the local agricultural p ractices with treatments being made using either tractor - mounted or hand - held boom spray ers. No adjuvant was added to the spray mixture for any

of the applications. To perform the determination of total fluazifop residues in/on potatoes, an accepta ble method was used and adequate data are available to support the sample storage durations of up 143 day s that were incurred. Total residue levels were observed ranging at levels between <0.0033 - 0.61 ppm for treatments made at the late seasonal timed P HIof 45 day s (± 1 day ) using the VENTURE L formulation of fluazifop. The results generated in the two decline studies illustrate demonstrate that concentrations of fluazifop will in fact decrease as greater PHI s for treatment are followed. In all, these data are adequate to support the proposed seasonal use pattern on potatoes put forward in this study . A summary

of the residue data obtained from the potato field trials made for this study are presented below in Table 7 for review. T able 7 . R esidu e Data fromC rop Field Trials with Fluazifop - P - butyl Presented in MRID No. 47920402 . Trial: City, Province ; Year (Trial ID # ) Zone Potato ; Variety # of

Treatments Total Rate

( g ai/ha ) PHI 1

(days) End - Use

Product Total

Fluazifop (ppm) New Glasgow, PE I; 2008 (T455) 1A Shepody 1 250 46 Venture L 0.16, 0.08 Albany, PEI; 2008 (T456) 1A Carlingford 1 250 36 Venture L < LOD 2 , <LOD New Glasgow, PEI; 2008 (T45 7

– Decline Study) 1A Goldrush 1 250 39 Venture L 0.28 46 0.61, 0.49 53 0.32 60 0.37 68 0.34F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 13 of 23 T able 7 . R esidu e Data fromC rop Field Trials with Fluazifop - P - butyl Presented in MRID No. 47920402 . Trial: City, Province ; Year (Trial ID # ) Zone Potato ; Variety # of

Treatments Total Rate

( g ai/ha ) PHI 1

(days) End - Use

Product Total

Fluazifop (ppm) Malden, NB; 2008 (T458) 1 Red Norland 1 250 46 Venture L 0.035, 0.036 Malden, NB; 2008 (T459) 1 Goldrush 1 250 46 Venture L 0.27, 0.28 Branchton, ON; 2008 (T460) 5 Goldrush 1 250 45 Venture L < LOQ 3 (0.0070), 0.016 Elm Creek , MB ; 2008 (T4 61 – Decline Study) 5 Shepody 1 250 37 Venture L 0. 020 44 0.016, 0.012 51 0.024 58 < LOQ (0.0070) 6 5 0.020 Elm Creek, MB; 2008 (T46 2 ) 5 Russet Burbank 1 250 44 Venture L < LOQ (0.0052), 0.036 St. Marc - sur - Richelieu, QC : 2008 (T463) 5B Kennebec 1 250 45 Venture L 0.044, 0.037 Taber, AB; 2008 (T464) 7A Russet Burbank 1 250 46 Venture L 0.14, 0.20 Abbotsford, BC; (T465) 12 WanBa 1 250 44 Venture L 0.043, 0.035 Minto, MB; 2008 (T466) 14 Norland 1 250 46 Venture L 0.14, 0 .16 Innisfall, AB; 2008 (T467) 14 Russet Burbank 1 250 45 Venture L 0.065, 0.050 1 PHI = Preharvest interval; interval from last application to harvest (petitioner reported PHI based on collection date). 2 LOD = Limit of Detection; 0.0033 ppm. 3 LOQ = Limit of Quantitation; 0.01 ppm. Potatoes (MRI D No. 4792040 3 ) To determine the magnitude of fluazifop - P - butyl residue found in/on potatoes within the various production regions of Canada, three (3) field trials were conducted during the 2007 growing sea son. The three (3) field trials were held at Hunter River (2 trials) and Portage la Prairie (1 trial) in Canada all of which are located in significant potato growing regions of the country . Each trial site was managed according to the practices routinel y followed by Canadian commercial producers for cultivating potatoes. Test plots were roughly 40 - 45 square meters in size, large enough to provide a 1 Kg sample of mature potato tubers to be collected from at least six (6) different plants.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 14 of 23 At each study

location, market quality

potato samples were cultivated using both untreated control and treated test plots. Each treated test plot received a single application made at the maximum labeled rate of 250 g ai/ha timed so that early , mid and late seasonal treatments could be evaluated. This treatment program also included field testing the application of the VENTURE Land FUSI LADE MAXX fluazifop - p - butyl end - use products using side - by - side test plots. This comparison was only

made for treatments those timed at the early seasonal application interval as a means for providing bridging data on these EC formulations. The actual rate of application ranged from 92.5% to 103.6% of the targeted amount of product designated for treatment. The application procedure followed was ty pical of the local agricultural practices with treatments being made using either tractor - mounted or hand - held boom spray ers. No adjuvant was added to the spray mixture for any of the applications. For the determination of total fluazifop residues in/on potatoes, an acceptable method was used and adequate data are available to support the sample storage durations of up 142 day s that were incurred. Total residue levels were all observed to be at or below the L OQ (0.010 ppm) for treatments made at early seasonal timed PHI s (89 - 90 day s) using both fluazifop formulations. In conjunction, residue levels for mid - seasonal timed PHI s (60 - 61 day s) were found to range from 0.024 - 0.130 ppm and late seasonal timed PHI s (46 day s) at 0. 065 - 0.170 ppm. Inall, these data are adequate to support the proposed seasonal use pattern on potatoes put forward in this study . A summary of the residue data obtained from the potato field trials made for this study are presented below in Table 8 for review. T able 8 . Residue Data fromC rop Field Trials with Fluazifop - P - butyl Presented in MRID No. 47920403 . Trial: City, Province ; Year (Trial ID # ) Zone Potato ; Variety # of Treatments Total Rate

( g ai/ha ) PHI 1

(days) End - Use

Product Total

Fl uazifop (ppm) Hunter River, PEI; 2007 (T232) 1A Russet Burbank 1 250 90 Venture L < LOD 2 , <LOD Fusilade Maxx < LOD, <LOD 60 Venture L 0.042, 0.038 46 Venture L 0.065, 0.072 Hunter River, PEI; 2007 (T233) 1A Yukon Gold 1 250 90 Venture L < LOD, <LOD Fusilade Maxx < LOD, <LOD 60 Venture L 0.13, 0.11 46 Venture L 0.093, 0.085 Portage la Prairie, MB; 2007 (T234) 5 Burbank 1 250 89 Venture L < LOD, <LOD Fusilade Maxx 0.0048, <LOD 61 Venture L 0.024, 0.024 46 Venture L 0.17, 0.14 1 PHI = Preharvest interval; interval from last application to harvest (petitioner reported PHI based on collection date). 2 LOD = Limit of Detection; 0.0033 ppm.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 15 of 23 Conclusions : The submitted residue data made for pot ato tubers are adequate in fulfill ing these data requirements . T he number and location of field trials were in line with the Canadian regulatory requirements. To satisfy

the Canadian requirement for a total of 16 trials in all, the results from two studi es were compiled to provide a complete data submission. MRI D No. 47920402 contains 13 field trials and MRI D No. 47920403 provides an additional 3 more made on the premise of a bridging study for show ing the equivalency of Venture L and Fusilade Maxx EC fo rmulations. Inregard to this comparison, this bridging data along with the supplemental information in the CSF summary of each end - use product adequately demonstrate these end - use products to be equivalent. Nonetheless, the trials which were made approp riately reflect the proposed use pattern, and supporting storage stability data are available. The residue data compiled for the potato RAC were entered into the Agency ’s tolerance spreadsheet as specified by the Guidance for Setting Pesticide Tolerances Based on Field Trial Data SOP to determine an appropriate regulatory level ( Appendix I ) . The resulting spreadsheet provides a best estimate of a tolerance which is determined to be 1. 0 ppm for the potato RAC . 860.1520 Processed Food and Feed DER Referen ce s: 47 920405 .der.doc ( potato ) For this action, Sy

ngenta is requesting the establishment of a new import tolerance for residues of fluazifop - P - butyl in/on potatoes and its processed commodities. To satisfy data requirements, the registrant has submitt ed a processing study made for this herbicide ai on potatoes. A summary of the data acquired from this processing study is presented below in Table 9. TABLE C.3. Residue Data fromPotato Processing Study with Fluazifop - P - butyl . Trial: City, State; Year (Trial ID#) Processed Commodity Total Rate ( g ai/ha ) PHI

(days) Residues (ppm) Processing Factor 1 Büchen, Germany; 1993 (B2) Potato RAC (w/peel) 375 42 0.22 -- Potato Peel 0.25 1.1x Cooked Potato 0.32 1.4x Potato Chips 0.72 3.3x Dried Potato 1.41 6.4x 1 The processing factor was calculated by the study reviewer by dividing the residues in the processed sample by the residues i n the unprocessed RAC sample. P otato (MRI D No. 47920405) The field portion of this study was carried out by

Z ENECA AGRO based in Frankfurt using six (6) field trials held at separate sites within Germany to cultivate potatoes during the 1993 growing season. No details concerning the varieties of potatoes that were grown, the use of any maintenance pesticides and fertilizers, soil chemistry , weather data, or the use of supplemental irrigation was provided. The data submission only noted that each test location received an application of the Fusilade end - use product formulation of fluazifop - P - butyl applied at a late seasonal Pre - Harvest In terval (PHI ) of six weeks. These treatments were made at the targeted amount of 375 g ai/ha in order to provide each test plot with a total seasonal application that was equivalent to 1.5x the maximum labeled use rate. For this program, the field samples from the two trials observed with the highest residues of total fluazifop were processed into potato peels, cooked potatoes, chips and dried flakes for testing.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 16 of 23 For this study , the cultivation of market quality potato samples was made using individual untreated control and treated test plots. The collected potato samples were shipped chilled at temperatures of 4 - 6° C via common carrier to the laboratory of DR. SPECHT & PARTNER (Hamburg, Germany ) for processing. In doing so, this study would clarify

how residues of fluazifop which may be present in harvested potatoes degrade or concentrate when processed by ty pical household preparation methods. For these purposes, the samples from the Bienenbüttel - Varendorf and Büchen trials with the highest observed residues of total fluazifop were processed. All samples were stored frozen at the laboratory until processing which was initiated a week after harvest. Representative mixed samples were formed and processing was then carried out according to laboratory SOP# Q - 51.037.02 in order to simulate normal domestic preparation procedures. T he potato processing procedure was as follow s ( MRI D No. 447920405 ): 1. Cooked Potatoes About 2 Kg of peeled potatoes were covered with 2 L of water and b rought to a boil after the addition of 10 g of common salt. The potatoes were cooked for 20

– 25 minutes and then drained with the cooking liquid kept separately . 2. Chips About 2 Kg of peeled potatoes were cut into slices. Approximately 1 Kg of fat was h eated in a deep - frying - pan, and fried for 20 minutes. 3. Dried Potatoes About 1.5 Kg of peeled potatoes were sliced, distributed evenly on the racks of the desiccation apparatus and dried at level 3 for 6

– 8 hours. 4. Freezing The processed potatoes were froz en prior to analy sis. Before freezing cooked potatoes were homogenized, chips and dried potatoes were chopped coarsely . Sample storage conditions and durations are summarized in T able C.2. Based upon the information provided, the approximate maximum sto rage duration of the potato samples from harvest/processing to analy sis did not exceed 200 day s ( ≈6.7 months) for the study . To support the storage interval of the samples collected for this study , the stability of fluazifop - P - butyl in frozen potatoes has previously been investigated in prior reports generated by Sy ngenta. These reports show that fortified potatoes demonstrate no loss of fluazifop - p - butyl when stored frozen at - 18°C for 18 months (DP No. D348246, D. Soderberg, 09/16/2008). However, stora ge stability data are required to support the storage conditions and durations of the processed commodities. The results in this data submission provide a determination of residue concentration factors for fluazifop - P - butyl in potato processed commodities . It was appropriately carried out in line with the recommendations set forth in the OPPTS 860.1520 Residue Chemistry Test Guidelines for evaluating the concentration of residues in processed commodities. Processing of the potato RAC bearing quantifiable residues of fluazifop resulted in no concentration of residues in the peel (1.1x processing factor). However, total fluazifop residues were found to concentrate in p otato chips and dried flakes at a processing factor of 3.3x, and 6.4x, respectively . In all, these data are adequate for determining residue concentration factors for potato processed commodities.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 17 of 23 Conclusions . T he p otato pr oc essing results acquired in this study are adequate for satisfying these data requirements. The se results indicate that total fluazifop residues do not appear to concentrate in the potato peel s , but may do so in the chips and granules/flakes processed fractions . Residues of total fluazifop were therefore found to concentrate in potato chips and granules/flakes at pro cessing factors of 3.3x and 6.4x, respectively . B ased on the HAFT residue for potato (0. 55 ppm) and the se processing factor s, expected residues are 1.81 ppm in chips and 3.52 ppm for granules/flakes . In comparison , the expected residues of these processe d fractions are greater then the 1.0 ppm recommended tolerance for potato. Potato tolerances of 2.0 ppm in chips and 4.0 ppm for granules/flakes are thus recommended with no limits in peels being required . 860.1650 Submittal of Analytical Reference Standards Analy tical standards for fluazifop - p - butyl and fluazifop - p ( resolved (R) isomer of fluazifop acid) are currently available in the EPA National Pesticide Standards Repository . T he fluazifop - p - butyl standard expires 1/1/2011 . Analy tical reference standard s must be replenished as requested by the Repository . The reference standards should be sent to the Analy tical Chemistry

L ab, which is located at Fort Meade, to the attention of either Theresa Cole or Thuy Nguy en at the fol lowing address: USEPA National Pesticide Standards Repository /Analy tical Chemistry

Branch/OPP 701 Mapes Road Fort George G. Meade, MD 20755 - 5350 (Note that the mail will be returned if the extended zip code is not used.) 860.1850 /860.1900 Confined and Field Accumulation in Rotational Crops The following plantback restriction exists on the product label (EPA Reg. No. 100 - 1070): a 60 - day plantback interval for rotational crops such as corn, sorghum, and cereals. Th is plantback interval is also appropriate for sugar beet. 860.1550 Proposed Tolerances Ina meeting on March 3, 2004, the MARC concluded that for tolerance expression, parent and fluazifop - acid (free and conjugated) are the residues of concern since they are adequate to determine misuse (DP No. D298939, S. L . Kinard, 06/22/2004). An acceptable soy bean metabolism study

is available along with new studies made to a root crop and leafy vegetable which are currently undergoing Agency

review. In accordance, t olerances are established under 40 CFR §180.411(a)(1) and (c)(1) for residues of fluazifop - butyl, including free and conjugated fluazifop, expressed as fluazifop . F or fluazifop - P - butyl , including free and conjugated fluazifop (R isomer), tolerances are likewise est ablished under 40 CFR §180.411(a)(2) and (c)(2) with residues e xpressed as fluazifop . It s registered uses include asparagus, carrot, coffee, cotton, endive (escarole), garlic, macadamia nut, onion, pecan, pepper, rhubarb, soy beans, stone fruits, sweet pot ato, and yam. It also carries a registration for use on lawns as a weed control application . Subsequently , a petition for establishing tolerance limits on dry

beans and peanuts is currently pending.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 18 of 23 For this action, field trials on potatoes along wi th a corresponding study made on its pertinent processed commodities were submitted to support this petition request. In evaluating the field trials provided by

the registrant, these studies were found to be adequate in satisfying these residue chemistry data requirements. Total fluazifop residues in/on the potato RAC were found to be readily quantifiable at levels greater then the LOQ of the test method. Inaccordance, the Agency ’s Guidance for Setting Pesticide Tolerances Based on Field Trial Data was utilized for determining appropriate tolerance levels for potato tubers ( Appendix I ) . Based on these calculations, the proposed potato tolerance of 0.25 in roots is adequate and a limit of 1.0 ppm for top s is recommended . In regard to the corresponding p rocessing study data that were provided, it can be concluded that no additional tolerances are needed for the peel. However, residues of fluazifop were found to concentrate in potato chips (3.3x) and dried flakes (6.4x). Based on the potato HAFT of 0. 55 ppm and the processing factor s calculated for chips and dried flakes , expected residues in these fractions are 1.82 ppm and 3.52 ppm , respectively . As a result, the tolerances of 2 .0 ppm in chips and 4.0 ppm for dried flakes are recommended for these potato processed commodities. The proposed new uses included in this petition will request the establishment of tolerances on potato crops which are commonly recognized as being livestock feedstuffs. Given that these uses will be established on imported comm odities , residues of fluazifop - P - butyl in/on potatoes will not result in being a contributor to the dietary burden of cattle. In accordance, it will not be necessary to provide a re - calculation of dietary

burden in support of this action. The conclusions determined for the secondary transfer of fluazifop - P - butyl residues to meat, milk, poultry , and eggs made prior for the pending uses established on dry beans and peanuts remain current. The established tolerances for livestock commodities are 0.05 ppm fo r total fluazifop residues in milk and the meat and meat by products of cattle, goat, hog, horse, and sheep, and fat, meat and meat by products of poultry . These levels remain appropriate . Inall, the available residue data provided for fluazifop - P - butyl are adequate to support the establishment of new import tolerance levels recommended for the potato RACs proposed in this action. There are no Codex or Mexican established M aximum R esidue L imits (MRL s) for residues of fluazifop - P - butyl in/on potatoes. Ho wever, this petition is being put forward as a request for the establishment of import tolerances on potato commodities which will be cultivated in Canada. There are no established MRL s for residues of fluazifop - P - butyl in/on potatoes in Canada but the pr omulgation of regulatory level s by PMRA are in the process of being finalized. As a result, international harmonization with Canada is a consideration for this data evaluation concerning the establishment of tolerances on imported potato commodities . The proposed limits should therefore be revised and a new Section F submitted to reflect the recommended tolerance levels and correct commodity

definitions specified below in Table 8 . Table 8. Tolerance Summary for Fluazifop - P - butyl. Commodity Established Tolerance (ppm) Proposed

Tolerance (ppm) Recommended

Tolerance (ppm) Comments; Correct Commodity

Definition Tolerances Proposed for 40 CFR §180.411(a)(1) Potato, tubers -- 1.1 1.0 Potato Potato, chips -- 3.0 2.0 Potato, granules/flakes -- 5.0 4.0F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 19 of 23 Re ferences DP No.: D 319907 Subject: Fluazifop - P - butyl. REVI SED TRED

– Report on FQPA Tolerance Reassessment

Progress and Interim Risk Management Decisions. Residue Chemistry Considerations. Case No. 2285. From: S. L . Kinard To: D. L ocke Dated: 08/17/2 005 MRI D Nos.: 00093840 - 1, 00093843, 00093845, 00137763, 00144014, 00151494, 00157191,

001517193, 40140401, 40241901, 40341601, 40361104, 40361108, 40361111, 40693108, 40725701, 40831303 - 5, 40831307, 40831309 - 10, 41018001, 41373703. DP No.: D298939 Subjec t: Fluazifop - P - butyl. Report of the Metabolism Assessment Review Committee. From: S. L . Kinard To: Y. Donovan Dated: 0 3 / 17 / 20 0 4 MRI Ds: None DP No.: D 348246 Subject: Fluazifop - P - Butyl. Section 3 Registration Request to Add New Uses on Beans (Dry ), Peanuts and Soy

beans. Summary

of Analy tical Chemistry

and Residue Data. From: D. Soderberg To: J. Miller Dated: 9/16/2008 MRI D Nos.: 47285501 - 05; 46412503 Attachments: In ternational Residue L imit Status sheet Appendix I - Toleranc e Assessment Calculations Template Version September 2005F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 20 of 23 

### International Residue Limits

Fluazifop - P - butyl ( 122809 ; 08/26/2010) Summary of US and International Tolerances and Maximum Residue Limits Residue Definition : US Canada Mexico 2 Codex 3 40 CFR 180. 411 : Plant/Livestock : butyl(R) - 2 - [4 - [[5 - (trifluoromethyl) - 2 - p yr idinyl]oxy ]phenoxy ]propanoate, and the free and conjugated forms of the resolved isomer of fluazifop, (R) - 2 - [4 - [[5 - (trifluoromethyl) - 2 - py ridinyl]oxy ]phenoxy ]propanoic acid, expressed as f

luazifop. butyl ( RS ) - 2 - [4 - [[5 - (trifluoromethyl - 2 - py ridinyl]oxy ]phenoxy ] propanoate (calculated as acid) None

Commodity 1 Tolerance (ppm) /Maximum Residue Limit (mg/kg) US Canada Mexico 2 Codex Potato, tubers 1.0 None None Potato, chips 2.0 Potato , granules/flakes 4.0

Completed: M. Negussie/08/30/2010 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. 3 * = absent at the limit of quantitation; Po = postharvest treatment, such as treatment of stored grains. PoP = processed postharvest treated commo dity, such as processing of treated stored wheat. (fat) = to be measured on the fat portion of the sample. MRLs indicated as proposed have not been finalized by the CCPR and the CAC.F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 21 of 23 Appendix I Tolerance Assessment Calculations For each of the crops lis ted below, the Guidance for Setting Pesticide Tolerances Based on Field Trial Data ( SOP ) , along with the tolerance spreadsheet (January 2008 version) , was used for calculating recomm ended tolerances. Potato, tubers The dataset used to establish a toleran ce for fluazifop - P - butyl on potatoes consisted of field trial data representing application of the VENTURE Lend - use product made at the maximum labeled rate of 250 g ai/ha with a 45 day PHI . As specified by

the Guidance for Setting Pesticide Tolerances B ased on Field Trial Data SOP, the field trial application rates and PHI s are within 25% of the maximum label application rate and minimum label PHI , respectively . The residue values used to calculate the tolerance are provided in Table I - 1. Most of the 3 2 field trial sample results were above the L OQ (LOQ = 0.01 ppm). The fluazifop - P butyl - dry potato dataset was entered into the tolerance spreadsheet. Visual inspection of the lognormal probability

plot (Figure I - 1) provided in the spreadsheet indicates that the dataset is reasonably

lognormal. The result from the approximate Shapiro - Francia test statistic (Figure I - 2) confirmed that the assumption of log normality should not be rejected. Since the field trial data for fluazifop - P - butyl on potato repres ent a large dataset (i.e., more than 15 samples) and are reasonably lognormal, the minimum of the 95% upper confidence limit (UCL ) on the 95 th percentile and the point estimate of the 99 th percentile should be selected as the tolerance value. Using the ro unding procedure as outlined in the Guidance for Setting Pesticide Tolerances Based on Field Trial Data SOP, the 95% UCLon the 95 th percentile rounds to the value 0.80 ppm . For the use , the recommended tolerance level for potato tubers is 1.0 ppm based u pon this minimum value found in the UCL of the 95 th percentile .F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 22 of 23 Table I - 1. Residue data used to calculate tolerance for fluazifop - P - butyl on dry bean. Regulator: EPA Chem ical: Fluazifop - P - butyl Crop: Potato, tubers PHI: 45 Days App. Rate: 250 g ai/h a (1 application) Submitter: Syngenta Crop Protection, Inc. MRID Citation: MRID Nos.: 47 920402 & 47920403

Total Fluazifop Residues (Fluazifop - P - Butyl and Fluazifop free and

conjugated as Fluazifop) (ppm )

0.010 0.010 0.010 0.010 0.012 0.016 0.016 0.035 0.035 0.036 0.036 0.037 0.043 0.044 0.050 0.065 0.065 0.072 0.080 0.085 0.093 0.140 0.140 0.140 0.160 0.160 0.170 0.200 0.270 0.280 0.490 0.610F luazifop - P - butyl Summary of Analytical Chemistry and Residue Data DP No. 372408

Page 23 of 23 Figure I - 1 . Log norm al probability plot of fluazifop - P - butyl field trial data for potatoes bean. Lognormal Probability Plot

99.9 99 98 95 90 80 70 50 30 20 10 5 2 1 0.1 1.0000 0.5000 0.2500 0.1250 0.0625 0.0313 0.0156 0.0078 y = 1.1758x - 2.7884 R 2 = 0.9691

PercentilesConcentrations EPA Fluazifop-P-Butyl Potato (Import) 45 day PHI 0.250 lb ai/A Syngenta

Figure I - 2. Tolerance spreadsheet sum ma ry of fluazifop - P - butyl field trial data for potatoes . Regulator: EPA Chemical: Fluazifop-P-Butyl Crop: Potato (Import) PHI: 45 day PHI App. Rate: 0.250 lb ai/A Submitter: Syngenta

n: 32 min: 0.01 max: 0.61 median: 0.07 average: 0.11 95th Percentile 99th Percentile 99.9th Percentile 0.35 0.45 0.60 (0.45) (0.60) (--) 0.45 1.0 2.5 (0.80) (2.5) (--) #REF! 0.60 0.35 0.9691 p-value > 0.05 : Do not reject lognormality assumption Approximate Shapiro-Francia Normality Test EU Method I Normal

UCLMedian95th 95/99 Rule EU Method II Distribution-Free Mean+3SD